APPENDIX A

Comments and Responses for Amendments to 

Rule 4308 (Boilers, Steam Generators, and Process Heaters - 

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

December 17, 2009 
SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DISTRICT 

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

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Final Staff Report with Appendices 

 For Amendments to Rule 4308

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SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DISTRICT 

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

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Final Staff Report with Appendices 

 For Amendments to Rule 4308

SUMMARY OF SIGNIFICANT WRITTEN COMMENTS AND 

RESPONSES FOR PROPOSED RULE 4308

The following is a brief summary significant comments received and the District 

responses to those comments. 

US EPA Region IX Staff Comments: 

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

November 5, 2009. 

ARB Comments: 

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

Stakeholder’s written comments: 

Cleaning Equipment Trade Association (CETA) 

Alkota Cleaning Systems, Inc. (Alkota) 

Air-Conditioning, Heating, and Refrigeration Institute (AHRI) 

General Comments

1. Comment: Pressure washers are used considerably less than a 

typical unit in this category (520 hrs annually). Eighty 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 low-use exemption 

for these units would help (Alkota).

Response: A low-use exemption is not included in this rule because 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 washers used 

for cleaning and sanitation, using fuels such as diesel, natural gas, and 

electricity. Pressure washers have to heat 2-10 GPM (gallons per 

minute) of water instantaneously, which requires high BTU input with 

very limited heat-exchange area. Complying with the 20 ppmv NOx 

would drop the BTU input, making it difficult to heat the water 

sufficiently for sanitation purposes. Technology is not available at this 

point in time for the pressure washer industry to comply with Rule 4308 

(CETA, Alkota).

 
SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DISTRICT 

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

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Final Staff Report with Appendices 

 For Amendments 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, therefore there is no 

need for specification (AHRI). 

 Response: These definitions are added for clarification and also for 

consistency with similar rules from other California 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 extra year would be 

beneficial (AHRI).

Response: In previous discussion with stakeholders, information was 

given that a year from rule adoption to rule implementation was 

sufficient time. Many other rules give only a one year sell through 

provision. Because of this, the rule implementation dates are a year 

after the rule is amended and adopted.