# APPENDIX A

Comments and Responses for Amendments to Rule 4308 (Boilers, Steam Generators, and Process H eaters -

0.075 MMBtu/hr to less than 2.0 MMBtu/hr)

December 17, 2009SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses for Rule 4308 December 17, 2009

A-2

Final Staff Report with Appendices

For Am endments to Rule 4308 (This page is intentionally blank)SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses for Rule 4308 December 17, 2009

A-3

Final Staff Report with Appendices

For Am endments to Rule 4308 

### SUMMARY OF SIGNIFICANT WRITTEN COMMENTS AND

RESPONSES FOR PROPOSED RULE 4308

The following is a brief summary significant commen ts received and the District responses to those comments.

US EPA Region IX Staff Comments:

No comments have been received from EPA for the Pro posed Rule 4308 dated

November 5, 2009.

ARB Comments:

ARB has reviewed the documents and does not have co mments at this time.

Stakeholder’s written comments: Cleaning Equipment Trade Association (CETA) Alkota Cleaning Systems, Inc. (Alkota) Air-Conditioning, Heating, and Refrigeration Instit ute (AHRI)

General Comments

1. Comment: Pressure washers are used considerably less than a typical unit in this category (520 hrs annually). E ighty percent of the units are portable with 20 percent being stationary . Of the stationary units, 90 percent are 0.45 MMBtu/hr and lower. A l ow-use exemption for these units would help (Alkota).

Response: A low-use exemption is not included in this rule b ecause it is an attrition rule. Also, low-use exemptions are appropriate only for larger units at permitted facilities where low-use can be verified.

2. Comment: This product line includes hot high pressure washer s used for cleaning and sanitation, using fuels such as di esel, natural gas, and electricity. Pressure washers have to heat 2-10 GPM (gallons per minute) of water instantaneously, which requires hi gh BTU input with very limited heat-exchange area. Complying with the 20 ppmv NOx would drop the BTU input, making it difficult to he at the water sufficiently for sanitation purposes. Technology is not available at this point in time for the pressure washer industry to c omply with Rule 4308 (CETA, Alkota).SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses for Rule 4308 December 17, 2009

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Final Staff Report with Appendices

For Am endments to Rule 4308 Response: District staff has communicated our willingness to continue to work with the Association over the next year to help them identify feasible approaches to rule compliance.

3. Comment: PUC-gas and Retrofit kit do not need to be defined. PUCgas is already defined by the gas companies, theref ore there is no need for specification (AHRI).

Response: These definitions are added for clarification and a lso for consistency with similar rules from other Californi a air districts.

4. Comment: Manufacturers need more time to begin production of new, compliant units to get out to distributers. Sellers need time to sell through all the old product. Giving industry and ex tra year would be beneficial (AHRI).

Response: In previous discussion with stakeholders, informati on was given that a year from rule adoption to rule implem entation was sufficient time. Many other rules give only a one y ear sell through provision. Because of this, the rule implementatio n dates are a year after the rule is amended and adopted.