Many parameters have been either incorporated into federal flare regulations or specific flare CD requirements over the past 30 years. The current parameters that are federally enforceable, tip velocity and a static NHV in the flare header, have been demonstrated to be inadequate in controlling combustion efficiency at the flare tip and guaranteeing greater than 98% combustion efficiency. Additionally, parameters that are enforceable only to those with whom the EPA has negotiated the recent flare CDs may provide greater correlation and control of the combustion efficiency at the flare tip. Inclusion of these "new" parameters and removal of existing parameters in federal rulemaking may prove to be that on which the combustion efficiency paradigm of the future is built. However, there are discussions amongst industry advocates regarding the adequacy and/or relevance of some of the parameters that are contained within the CDs. It is not yet clear which, if any, of the new parameters will be included in the next proposed rule making for flares. Research continues to be conducted with respect to identifying the "holy grail" parameter upon which to develop the combustion efficiency paradigm to ensure greater than 98% combustion efficiency at the flare tip.
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