UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	January 20, 2011

SUBJECT:	Technical Support Document for Maryland’s Amendment to the
Definition of “Fuel-Burning Equipment”

			/s/

FROM:	Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO:		File

			/s/	

THRU: 	Cristina Fernandez, Associate Director 

Office of Air Program Planning

A.  BACKGROUND  

The term “fuel-burning equipment” was originally defined in order to
differentiate between a boiler that involves the indirect heating of air
or water and fuel-burning installations that involve direct heat
exchange.  Fuel-burning installations, such as a kiln, are subject to
the general requirements for sulfur dioxide (SO2) and particulate
matter, whereas fuel-burning equipment is subject to different standards
in the form of pounds of SO2 per million Btu per hour heat input or the
sulfur content of the fuel.

Since a “furnace” is usually direct heat exchange, Maryland
concludes that it should not be included in the definition of
fuel-burning equipment.  There is no federal definition of the term
“fuel-burning equipment,” however, the term “fuel-burning
equipment” is consistent with the Federal definition of the term
“boiler.”

In Maryland, there are few examples of indirect heat exchange furnaces. 
In search of any affected facility, Maryland had found only one indirect
heat exchange furnace in the State.  That furnace, however, has been
subject to the general requirements as a fuel-burning installation and
not subject to “boiler” requirements.  Therefore, there are no
affected sources by this revision, and as such, no expected emission
reductions.

B.  STATE SUBMITTAL

On December 15, 2010, Maryland Department of the Environment (MDE)
submitted to EPA a SIP revision concerning the definition of
“fuel-burning equipment.”  This SIP revision includes amendments to
Regulation .01 under COMAR 26.11.01, General Administrative Provisions
and Regulation .01 under COMAR 26.11.09, Control of Fuel-Burning
Equipment, Stationary Internal Combustion Engines, and Certain
Fuel-Burning Installations.  The revisions are as follows:

COMAR 26.11.01.01 – Definitions are amended as follows by removing the
term “furnace” from the definition of “fuel-burning equipment”:

Section .01(B)(17)(a):   “Fuel-burning equipment” means any boiler
that has the primary function of heating air, water, or any other medium
through indirect heat transfer from the burning of fuels.

COMAR 26.11.01.09.01 – Definitions are amended by removing the
redundant definition of “fuel-burning equipment.”

C.  EPA EVALUATION

The State of Maryland has removed the word “furnace” from the
definition of “fuel-burning equipment” in COMAR 26.11.01.01(B)(17). 
The amended definition is more consistent with the Federal definition of
“boiler.”  Maryland has also removed the redundant definition of
“fuel-burning equipment” from COMAR 26.11.09.01.  The revision to
Maryland’ SIP reflects these amendments, and therefore, this revision
is consistent with the Federal use of the term “fuel-burning
equipment.” 

D.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION

EPA approval of the SIP revision is recommended.

