July 11, 2019

Mindy West
Chief Financial Officer
Murphy USA Inc.
200 Peach Street
El Dorado, Arkansas 71730-5836

       Re: Murphy USA Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed February 19, 2019
           File No. 1-35914

Dear Ms. West:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Segment Results
Marketing Segment, page 31

1.    Please add a footnote to the table of key metrics to disclose how you
determine same store
      sales.

Key Fuel Operating Metrics, page 32

2.    Please expand the items disclosed in the table so that readers are able
to recompute the
      total fuel contribution and total retail fuel contribution metrics and
reconcile them with
      amounts presented on the income statements. These amounts appear to
include: 1) total
      cost of RINs, 2) PS&W volumes, 3) PS&W sales and 4) PS&W cost of sales.
 Mindy West
Murphy USA Inc.
July 11, 2019
Page 2
3.    It appears Retail fuel margin (cpg excluding credit card fees) disclosed
in the table is a
      non-GAAP measure that should be reconciled by disclosing the amount of
credit card
      fees. Please revise and also provide the other required disclosures in
Item 10(e)(i) of
      Regulation S-K.
Consolidated Statements of Cash Flows, page F-6

4.    We note you recognized a decrease in restricted cash of $68.8 million
classified as an
      investing activity for the year ended December 31, 2016. This
presentation does not
      appear to comply with ASU 2016-18. Please refer to the transition
guidance and revise
      your presentation or tell us how the presentation complies with ASU
2016-18.



Notes to Consolidated Financial Statements
Note 10 - Incentive Plans, page F-18

5.    Please disclose the total fair value of restricted stock units and
performance-based
      restricted stock units vested during each year presented and the
intrinsic value of restricted
      share units as of year end. Refer to ASC 718-10-50-2d and ASC
718-10-50-2e.


        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

     You may contact Ta Tanisha Meadows, Staff Accountant, at (202) 551-3322 or
Bill
Thompson, Accounting Branch Chief, at (202) 551-3344 with any questions.



                                                             Sincerely,
FirstName LastNameMindy West
                                                             Division of
Corporation Finance
Comapany NameMurphy USA Inc.
                                                             Office of Consumer
Products
July 11, 2019 Page 2
cc:       Donald Smith, Controller
FirstName LastName