Comment submitted by Randy Stocker, Emerson Climate

A. Require quarterly of 1) leak rate by asset with refrigerant type and asset capacity 2) maintenance (repair) events and service (fill) events with technician EPA number. This services the purpose of proactively policing the leak rate but also provides valuable and actual data to the EPA of refrigerants in use, location of failures and how much refrigerant is being vented that has mostly been anecdotal information to date. B. Require fill events to be auditable through 2 way comparison of service event record against invoice (for 3rd party service), or weighed cylinders log (internal service). This would not be submitted but records must be on file. This provides on-site data that can be audited. If the EPA wants to be serious about refrigerant venting to the atmosphere then these two must be included in the EPA608 update. The entities that fall under EPA608 regulation already have several mandatory monthly, quarterly and annual reporting requirements to municipal, county, state and federal agencies (Labor Dept, Dept of Ag, Waste Water Treatment, Landfill, etc) so the infrastructure to collect this data and the staff to prepare it already exists. This would not be a hardship or burden to require collection and submission of this data. Randy Stocker Emerson Climate