# E C 

# / R Incorporated Providing Environmental Technical Support Since 1989

1 MEMORANDUM

TO: Bruce Moore

, EPA/OAQPS/SPPD/CCG

FROM: Bradley Nelson, EC/R, Inc.

DATE: December 5 , 201 1

SUBJECT: Summary of the December 1

, 20 11

, Meeting with REM Technology Incorporated

( RTI ) and the U.S. Environmental Protection Agency to D iscuss the Proposed Oil

& Gas NSPS/NESHAP

I. INTRODUCTION

REM Technology Inc. (RTI) requested this meeting with EPA to discuss questions on the proposed Oil and Gas NSPS (40 CFR Part 60, subparts KKK, LLL, and OOOO) and NESHAP (40 CFR Part 63, subpart s HH and HHH ). This meeting summary will be available in the docket for this rulemaking (Docket ID No. EPA

- HQ

- OAR

- 20 1 0

- 0 505 ). The proposed rule for the oil and natural gas sector wa s published in the Federal Register on August 23, 20 11 (7 6 FR 52738 ).

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

Bruce Moore Greg Nizich

REM Technology Incorporated

Veronica Nasser

Cam Dowler

EC/R Incorporated

D avid Hendricks Bradley Nelson2

III. SUMMARY OF DISCUSSION

Bruce Moore opened the meeting by stating that the proposed rules are currently still in the comment period and EPA could answer clarifying questions from the group, but could not provide any responses to comments on the proposed rules.

RTI is an engine ering design company specializing in the optimization, monitoring, diagnostics and control of reciprocating internal combustion engines/compressors

. In addition, RTI has developed capture and control systems for condensate tanks and other vented sources in the oil and gas industry. Their technology s ystems come as packaged control systems with application software, application

- specific vented source modifications and end devices.

RTI started the presentation, which is included as Attachment A in this do cument, by stating that

EPA wrote in the preamble that fugitive emissions from reciprocating compressor rod packing could not be captured and conveyed to a control device. RTI stated that they currently produce and sell a technology called SlipStream® tha t captures fugitive emissions from reciprocating compressor packing and uses the captured gas as a supplemental fuel source for natural gas engines. RTI noted that this technology is used in places where the measurement of greenhouse gases from vented sou rces is required. EPA stated that information from industry sources found that capture equipment caused back pressure in the compressor and forced the vented gas into the crankcase, which caused problems in the operation of the engine. RTI responded that their technology did not create back pressure in the engine.

RTI described the SlipStream® technology as an independent system designed to capture and route vented and hydrocarbons through a manifold and valve train assembly and then feed into an engine via the air intake and burned as fuel. The system can provide up to 8 standard cubic feet per minute (scfm) or 10% of the main engine fuel. They also stated that the technology can be used for capturing vented emissions from condensate tanks and glycol d ehydrators. The system can also provide, with additional equipment, greater than 30% of the main engine fuel. RTI provide examples of the Slip Stream® technology installed on reciprocating compressor engines operating in Texas. The system also includes an alarm to alert the operator when SlipStream® fuel flow rate reaches 6 scfm, which alerts the operator that the rod packing leak rate has increased. In addition, multiple engines can be fed into a single SlipStream® sy s tem
with the addition of a manifol d for each source. RTI also presented an application of the SlipStream® system on a condensate tank in Oklahoma. RTI stated that the SlipStream® costs $12,500 without installation, and estimates the fuel savings of $6,500 per year on a 4

- stroke natural ga s engine. The vendors also noted that the system will allow better maintenance on the rod packing and alleviate safety concerns.

RTI stated that the proposed rule currently excludes the option of using the SlipStream® system as a control option for reciprocating compressor rod packing emissions. EPA stated that they could include their system as an alternative option for reducing r od packing emissions from reciprocating compressors along as the captured gas is not vented. RTI stated that if the main engine using the captured gas is shut down, that the captured gas would be sent to a secondary engine. RTI also stated that they are currently working on technology to provide supplemental

fuel to turbines and glycol dehydrators.3 Attachment A

REM Technology Inc. Presentation to EPA on December 1, 2011