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, 2011

SUBJECT: Summary of the December 1, 2011, Meeting with REM Technology Incorporated 

(RTI) and the U.S. Environmental Protection Agency to Discuss 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, subparts HH and HHH). This meeting summary will be available in the docket 

for this rulemaking (Docket ID No. EPA-HQ-OAR-2010-0505). The proposed rule for the oil 

and natural gas sector was published in the Federal Register on August 23, 2011 (76 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

David Hendricks

Bradley Nelson 
2

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 engineering 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 systems 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 document, 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® that 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 sources 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 dehydrators. 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® system 

with the addition of a manifold 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 gas 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 rod 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