REM Technology, Inc.

Presentation to:

United States Environmental Protection Agency (EPA)

Subject: Docket ID Number EPA-HQ-OAR-2010-0505

Paragraph Citation 76 FR 52746

Page 52746

December 1, 2011
Docket ID Number EPA-HQ-OAR-2010-0505

Paragraph Citation 76 FR 52746

Page 52746

We are also proposing VOC standards to reduce emissions from gas- driven pneumatic devices. We are 

proposing that each pneumatic device is an affected facility. Accordingly, the proposed standards would apply to 

each newly installed pneumatic device (including replacement of an existing device). At gas processing plants, we 

are proposing a zero emission limit for each individual pneumatic controller. The proposed emission 

standards would reflect the emission level achievable from the use of non-gas-driven pneumatic controllers. At other 

locations, we are proposing a bleed limit of 6 standard cubic feet of gas per hour for an individual pneumatic 

controller, which would reflect the emission level achievable from the use of low bleed gas- driven pneumatic 

controllers. In both cases, the standards provide exemptions for certain applications based on functional 

considerations. In addition, the proposed rule would require measures to reduce VOC emissions from 

centrifugal and reciprocating compressors. As explained in more detail below in section VI.B.4, we are 

proposing equipment standards for centrifugal compressors. The proposed standards would require the use of dry 

seal systems. However, we are aware that some owners and operators may need to use centrifugal compressors 

with wet seals, and we are soliciting comment on the suitability of a compliance option allowing the use of wet seals 

combined with routing of emissions from the seal liquid through a closed vent system to a control device as an 

acceptable alternative to installing dry seals. Our review of reciprocating compressors found that piston rod 

packing wear produces fugitive emissions that cannot be captured and conveyed to a control device. As a 

result, we are proposing operational standards for reciprocating compressors, such that the proposed rule 

would require replacement of the rod packing based on hours of usage. The owner or operator of a 

reciprocating compressor affected facility would be required to monitor the duration (in hours) that the 

compressor is operated. When the hours of operation reaches 26,000 hours, the owner or operator would 

be required to change the rod packing immediately. However, to avoid unscheduled shutdowns when 

26,000 hours is reached, owners and operators could track hours of operation such that packing 

replacement could be coordinated with planned maintenance shutdowns before hours of operation reached 

26,000. Some operators may prefer to replace the rod packing on a fixed schedule to ensure that the hours 

of operation would not reach 26,000 hours. 
Docket ID Number EPA-HQ-OAR-2010-0505

Paragraph Citation 76 FR 52746

Page 52746

We solicit comment on the appropriateness of a fixed replacement frequency and other 

considerations that would be associated with regular replacement. We are also proposing VOC 

standards for new or modified storage vessels. 

The proposed rule, which would apply to individual vessels, would require that vessels meeting 

certain specifications achieve at least 95-percent reduction in VOC emissions. Requirements would 

apply to vessels with a throughput of 1 barrel of condensate per day or 20 barrels of crude oil per 

day. These thresholds are equivalent to VOC emissions of about 6 tpy. For gas processing plants, 

we are updating the requirements for leak detection and repair (LDAR) to reflect procedures and 

leak thresholds established by 40 CFR 60, subpart VVa. The existing NSPS requires 40 CFR part 

60, subpart VV procedures and thresholds. For 40 CFR part 60, subpart LLL, which regulates SO2 

emissions from natural gas processing plants, we determined that affected facilities with sulfur feed 

rate of at least 5 long tons per day or H2S concentration in the acid gas stream of at least 50 

percent can achieve up to 99.9-percent SO2 control, which is greater than the existing standard. 

Therefore, we are proposing revision to the performance standards in subpart LLL as a result of this 

review. For a more detailed discussion of this proposed determination, please see section VI.B.1 of 

this preamble
Natural Gas Star Program – US EPA

Pressure Packing Data

Quick reference to Standard Pressure packing flow rate data provided 

by the Natural Gas Star Program.
A Patented REM Technology System

For the reduction of Vented Emissions from Reciprocating 

Compressor Packing Vents, Condensate Tanks and other vented 

sources.
SlipStream® Development

 SlipStream® originally designed for reducing fuel cost by utilizing 

vented hydrocarbons as a supplemental fuel source for natural gas 

engines and thereby increasing fuel efficiency

 Today, due to environmental regulations for Green House Gas 

auditing, and vented emissions reduction, SlipStream® is applied 

where the measurement and reduction of CO2(e), and VOC’s, from 

varying vented sources is required. 

 An increased in fuel efficiency is inherent feature to the system. 
Vented Sources

 Vented hydrocarbon emissions are found at most compression facilities 

involved in the production, processing and transportation of natural 

gas. Vented emissions can be comprised of methane, ethane, propane, 

butane, CO, H2, BTEX* (> 99.5% reduction)

Sources include:

 Condensate tanks

 Instrument gas vents

 Compressor packing leaks

 I/Ps and pneumatic devices

 Pig Chambers

 Crankcase and packing vents

 Dehydrators

 Compressor purging

and blow-down gas

 Pneumatic pumps

 (Engine start gas)

*BTEX = Benzene, Toluene, Ethyl-benzene, Xylene
What is SlipStream® ?

• SlipStream® Stand Alone (SA) is an independent system designed 

to receive vented undiluted and diluted hydrocarbons through a 

manifold and valve train assembly and then feed into the engine via 

the air intake and burned as fuel. SlipStream® Stand Alone (SA) Is a 

VRU system that does not require recompression.

• The System ... 

• Provides control of vented hydrocarbon flows up to 8 scfm or 10% of the main 

engine fuel, which ever is less

• Is compatible with 3rd party and OEM air-fuel ratio control systems 

• Provides continuous fuel flow measurement

• Provides integrated greenhouse gas data logging, (Subpart W), for emissions 

reporting

• Provides a fail safe operation
SlipStream® SA Safety

 Maximum flow limit designed into system

 Two shut-off valves with fail closed design

 Two check valves for release of high flow rates

 Watchdog for SlipStream® controller - Shuts SlipStream® system off if 

processor locks-up

 Over-sized filter to remove contaminants
Additional SlipStream Capacity 

Dependant upon available vented hydrocarbons, SlipStream® can 

operate in three additional model ranges for higher volumes. 

 0 to 10 % - (Full Authority)

 10 to 30% - (Full Authority)

 > 30% - (Full Authority)

 Full Authority requires the use of our REMVue 500 Air/Fuel 

Control System for a safe, reliable operation. 
SlipStream® SA – Installation on 

Compressor Pressure Packing Vent

The following slides provide an example of SlipStream® SA on a 

compressor pressure packing vent application.

 Engine Type: White Superior 8GTL-825 driving a 4 throw Ariel 

Compressor.

 TCEQ inspection results prompted measures to reduce/eliminate vented 

hydrocarbons from being emitted into atmosphere.

 Location: Dallas/Ft. Worth Region
SlipStream® SA

Instrument 

Gas

Packing Vents 

(recips)

Pneumatic 

Pumps

SlipStream 

Control Unit

To Engine

Air Intake

Atmospheric 

Vent

Condensate 

Tanks

Additional vent sources can be added to a

Single SlipStream® SA by adding a 

manifold for each source. 
How is pressure packing vented emissions captured ?

“Goose neck is tied into 1⁄2” 

tubing, from each throw, and 

then into a common header Two stage, three 

throw compressor
How is pressure packing vented emissions captured ?

Common 

header in most 

cases vents to 

atmosphere
How is pressure packing vented emissions captured ?

Common header to 

Outside of

building. 

SlipStream

Manifold 

Is tied in. 
SlipStream® SA Panel

Information gathered

From PLC: RPM, 

Exhaust temps., A/F, and 

Flow calculations. 

Provides SlipStream HMI display.

Valve train in

background
SA SlipStream from Compressor Packing Vent

Manifold and Valve Train

Valve train ships assembled. 

Includes flow measurement control

Valve and solenoid

SlipStream fuel line to air 

Intake.

Manifold - device to

Regulate over-pressurization

Vent to atmosphere

Demister to remove 

contamination
SlipStream SA from Packing Vents 

Air Intake Line to Air Intake

After air 

Filter, 

before

Turbo 

Flow rate 

entering airintake line 

typically 5” WC 

of vacuum 
How is pressure packing vented emissions captured ?

SlipStream® gas addition, 

installation to intake air
Control Test Results

 This next graph shows a trend of the engine RPM, 

SlipStream® Flow and main fuel flow

 The SlipStream® flow is turned off and on abruptly to 

observe how the REMVue® control system handles this 

sudden change in fuel to the engine

 In addition to the trend graph, two videos of these events 

were taken with a FLIR infrared camera

 The videos show the vent pipe at the top of the engine 

building when the SlipStream® Flow is turn on and off per 

the trend graph

 This FLIR shows methane leaks that are invisible to the 

naked eye.
Control Test Results

 This next graph shows a trend of the engine RPM, 

SlipStream® Flow and main fuel flow

 The SlipStream® flow is turned off and on abruptly to 

observe how the REMVue® control system handles this 

sudden change in fuel to the engine

 In addition to the trend graph, two videos of these events 

were taken with a FLIR infrared camera

 The videos show the vent pipe at the top of the engine 

building when the SlipStream® Flow is turn on and off per 

the trend graph

 This FLIR shows methane leaks that are invisible to the 

naked eye.
SlipStream® Results

Minimal engine RPM change

Full vented flow turned

off abruptly, then on 

abruptly
SlipStream® SA Environmental Benefits

and Fuel Cost Savings 

Based on 

$3.85/mcf

and flow rate 

at time of 

snap shop

CO2(e)

Flow rate at time of 

snap shot

Flow rate 

fluctuates 

with RPM

Actual totals

Actual 

Fuel gas savings to 

Date of snap shot 
Alarm Settings and Benefits

 Flow rate is continuously measured

 A high flow rate alarm is set at 6 SCFM, (customer specified), to 

notify operators when pressure packing leak rate increases. 

 This allows for scheduled maintenance to be performed, possibly at 

time when other maintenance tasks are due. Unscheduled down 

time, and lost production is avoided. 

 Vented hydrocarbons are eliminated and compliance is meet at all 

times.

 The vented hydrocarbons are used as supplemental fuel. The entire 

time the pressure packing is leaking, SlipStream is capturing and 

burning in the engine as fuel.
Multiple Engine/Compressors feed into Single 

SlipStream System

• Additional engine/compressors can be feed into a single SlipStream 

system with the addition of a manifold for each source

• Each engine/compressor is isolated with a manual shut-off valve

• Where SlipStream is receiving vented emissions from multiple 

compressors, should the primary engine, (engine where SlipStream is 

installed), shut down, a control system is in place to switch the “feed” 

to a secondary engine. 
Other SlipStream® SA Applications

Condensate Tanks

The following slides provide an example of SlipStream® SA on a 

condensate tank application.

 Engine Type: Cat 3516LE driving a 4 throw Ariel Compressor.

 Location: Oklahoma City Region
Example of SlipStream on Condensate Tank to Cat 3516LE 

Application
Controlling Leaks from Thief Hatches

 In order for SlipStream® SA to operate as designed, it is necessary to 

eliminate leaks that may exist through the thief hatches. It is 

recommended that thief hatches be replaced with an ENARDO ES600, or a thief hatch of similar design.
SlipStream® SA on CAT 3516LE

Vent Gas 3”pipe from

Tank to SlipStream 

System
SlipStream® SA on CAT 3516LE 

(Outside of Oklahoma City)

3” line to 

SlipStream

SlipStream 

Panel
SlipStream® SA on CAT 3516LE

Valve Train

Knock-out 

pot
SlipStream® SA on CAT 3516LE

SlipStream fuel

After the air

Filter, before the 

Turbo. 
Communications MODBUS Communications

SCADA

Cellular

Radio

Ethernet

485, 232

LAN

WAN
SlipStream® 

Economics

One time SlipStream System cost:

 Per engine average: $ 12,500.00, without installation

 Fuel cost savings based on a 4 throw compressor with moderate leak 

rate: $ 6,500.00/year.

 Environmentally compliant: Priceless!

 Significant GHG Reduction: Priceless!

 Maintenance cost and downtime cost savings: TBD by customer
SlipStream Panel
REMVue®

Getting a free boost!
Thank You

 Thank you for the opportunity to present to you today. Our hope is that the 

EPA will evaluate our SlipStream technology as a sound, reliable alternative 

to the proposed packing change out every 26,000 run hours. 

 By allowing the user a choice to implement an alternative solution like 

SlipStream to completely eliminate vented emissions, environmental 

compliance is met at all times, thereby benefiting the gas producer from an 

economical stand point, and the regulator from a compliance stand point. 

 By implementing SlipStream the proposed rule requirements are exceeded 

by eliminating the vented emissions with an economic payback to the gas 

producer.