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 “fuelburning 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 “fuelburning equipment.”

D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

EPA approval of the SIP revision is recommended.