UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103 DATE: January

20, 2011 SUBJECT: Technical Support Document for Mary land’s Amendment to the Definition of

“Fuel - Burning Equipment” /s/ FROM: Irene Shandruk, Phy sical 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 originall y defined in order to di fferentiate 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 (SO 2 ) and particulate matter, whereas fuel - burning equipment is subject to different standards in the form of pounds of SO 2 per million Btu per hour heat input or the sulfur content of the fuel. Since a “furnace” is usually direct heat exchange, Maryland conclu des 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 Mary land, there are few examples of indirect heat exchange furnaces. In search of any affected facility , Maryland had found onl y 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 b y this revision, and as such, no expected emission reductions. B. STATE SUBMITTAL On December 15, 2010, Maryland Department of the Environme nt (MDE) submitted to EPA a SI P revision concerning the definition of “fuel - burning equipment . ” This SIP revision includ es amendments to Regulation .01 under COMAR 26.11.01, General Administrative Provisions andRegulation .01 under COMAR 26.11.09, Contro l of Fuel - Burning Equipment, Stationary I nternal 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 an y other medium through indirect heat transfer from the burning of fuels. COMAR 26.11.01.09.01

– Definitions ar e amended by removing the redundant definition of “fuel - burning equipment.” C. EPA EVALUATION The State of Mary land has removed the word “furnace” from the definition of “fuel - burning equipment” in COMAR 26.11.01.01 ( B ) (17). The amended definiti on is m ore consistent with the F ederal definition of “boiler . ” Maryland has also removed the redundant definition of “fuel burning equipment” from COMAR 26.11.09.01. The revision to Maryland’ SI P reflects these amendments, and therefore, this revision is consis tent with the Federal use of the term “fuel burning equipment.” D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION EPA approval of the SIP revision is recommended.