May 23, 2007

Subject:  Conversation with Dana Morris, P.E. Environmental Engineer
with Kansas

   Department of Health and the Environment/ Permit Status of Gasifier
at Frontier 

   El Dorado Refining Company (Formerly known as El Dorado Texaco) 

   From:  José E. Labiosa, Chemical Engineer

	   Waste Minimization Branch

     To:    Administrative Record for RCRA-2002: FRL-7162-8/ Regulation
of Oil-

	  Bearing Hazardous Secondary Materials from the Petroleum Refining

              Industry Processed in a Gasification System to Produce of
Synthesis Gas.

	I called Dana Morris to find out about the current operational and
permit status of the gasifier at the Frontier El Dorado Refining
Company, formerly known as El Dorado Texaco.  The facility was
co-processing several RCRA hazardous wastes and coke in the gasifier for
almost 20 years.  No RCRA permit was required because the gasifier was
integrated with its petroleum refining operations and it was used to
generate steam.  The gasifier generated a syngas fuel primarily
comprised of H2 and CO.  Subsequent combustion of syngas fuel in a
turbine was regulated pursuant to Title V of the CAA. Potential
emissions from the gasification operations were addressed pursuant to
Prevention Source Deterioration requirements. The facility took the
gasifier out of service about one and a half year ago in order to offset
projected increases in SO2 emissions from upgrades at the facility
seeking increases in the production of ultra-clean diesel and gasoline
fuels (e.g. lower in sulfur content).  The gasifier is still onsite and
has not yet been decommissioned. 

