Flare Tip Btu Value Calculation using Pilot Gas

[EnviroG]

I have found many mixed opinions from the flare mfg community, the EPA and other sources regarding including the Btu value of natural gas from flare pilots into the flare Btu calculation. The EPA is guided by the flare rules in 40CFR60.18 requiring either 200 Btu/scf for non-assisted flares or 300 Btu/scf for steam or air assisted flares. When calculating the waste gas Btu/scf and then adding the pilot gas value there is no issue with meeting either EPA limit. When not adding the pilot gas value or mixing that value with the waste gas value issues do sometimes come up. Anyone have any experience with this I could certainly use the help.