You assume correctly, all of our systems are elevated. We have three air assist and two steam assist flares. One air assist and one steam assist utilize TCs. The others use ionization detection with IR backup (which as I indicated are unreliable).
Your suggestions and assumptions are valid...
Our facility operates several flares, which are subject to the pilot monitoring requirements of 40 CFR 60.18(f)(2). Our delema is that we chose to use ionization detection to indicate flame presence. This system is either off (0) when in normal operation or on (1) when in an alarm state. The...