# 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 CO 2 

### (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, H 2 

### , 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, T

oluene, Ethyl

-benzene, X

ylene

# 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 3 rd 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, i nstallation 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 REM Vue® 

## 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 REM Vue® 

## 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 ES 600, 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

# REM Vue®



# 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 

### .