| Abstract |
The recent 2012 Flare Consent Decrees (CD) issued by the U.S. Environmental Protection Agency (EPA) have been precipitated by alleged flare over-steaming practices in most all industrial applications. The impact of over-steaming on the subsequent degradation of combustion efficiency was revealed in 2005 when the ambient air monitor at the Meredith Hitchens Elementary School in Addyston Ohio began reporting significantly higher than background levels of 1,3 butadiene. The ensuing investigation eventually concluded that one of the flares at the nearby INEOS Lanxess Butadiene Plant was being significantly over-steamed, resulting in atmospheric emissions of butadiene at rates which were magnitudes of order greater than previously estimated. An investigation led by Texas Commission on Environmental Quality (TCEQ) - conducted between 2003-2006 in the Houston Brazoria counties - also focused on flares and it also highlighted the need to seriously address industrial flare operations. Over-steaming became and remains an area of intense interest. A further technical study commissioned by the TCEQ in 2008 further provided quantitative analysis on the significance of over-steaming practices and clearly demonstrated that air or steam-assisted flares can easily be "over assisted" resulting in very low combustion efficiencies. The TCEQ study clearly demonstrated the complex and inter-related impacts of multiple variables on flare performance, indicating that the management of flare combustion efficiency is a highly dynamic process. The EPA's response to this growing body of information has been enforcement first, with no regulatory improvement to date. |
