I had this issue too, thought it was the RMS, but in my case it was the two bolts at the back of my oil pan were not tight enough. I fixed that and have not have any leak at all back there. But I have had three TJs now and the other two needed the RMS replaced. Most with the 4.0 do sooner or later. But at least you can go through the oil pan, don't have to pull the Trans or Engine to get to it.