University Of South Carolina
Department of Environmental Health and Safety
Office of Hazardous Waste
Environmental Audit Program
Chlorofluorocarbons, Federal Insecticide, Fungicide and Rodenticide Act,
and Polychlorinated Biphenyl Programs
Issued: July 31, 2007
USC EHS Office of Hazardous Waste
(EHS-F-122) Environmental Audit Program
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Issue Date: 7/31/07
Reviewed:______
TABLE OF CONTENTS
CHLOROFLOUROCARBON (CFC) PROGRAM .......................................................................................... 3
CFC Program Audit Report ............................................................................................................................ 4
CFC Audit Checklist......................................................................................................................................... 5
FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT (FIFRA) PROGRAM ................ 10
FIFRA Program Audit Report ...................................................................................................................... 11
FIFRA Audit Checklist................................................................................................................................... 12
POLYCHLORINATED BIPHENYL (PCB) PROGRAM.............................................................................. 15
PCB Audit Report ........................................................................................................................................... 16
PCB Transformers Audit Checklist .............................................................................................................. 17
PCB Audit Checklist for Laboratories ......................................................................................................... 18
PCB Ballasts Audit Checklist ........................................................................................................................ 20
USC EHS Office of Hazardous Waste
(EHS-F-122) Environmental Audit Program
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CHLOROFLOUROCARBON (CFC) PROGRAM
USC EHS Office of Hazardous Waste
(EHS-F-122) Environmental Audit Program
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Reviewed:______
CFC Program Audit Report
Auditors Name
Date
Location
Auditors Signature
Time of Audit
Project Manager
Findings:
Regulatory Requirements:
USC EHS Office of Hazardous Waste
(EHS-F-122) Environmental Audit Program
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Recommendations:
CFC Audit Checklist
Program Qualification
Yes
No
N/A
1. Does your facility own or operate any of the following appliances and refrigerant
equipment types, using a CFC or HCFC refrigerant?
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2. Does your facility use company employees to service, maintain
or repair appliances and equipment involving refrigerant?
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3. Do you own or lease EPA-certified refrigerant recovery equipment?
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4. Are all recovery equipment units left unaltered?
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5. Have you submitted to EPA a recovery equipment certification form?
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6. Do all your service technicians have the appropriate certification under Section 608
of the Clean Air Act (e.g. Type I for small appliances, Type II for high or very high
pressure appliances, Type III for low pressure appliances and Universal for all types
of equipment)?
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[ ] Comfort cooling [ ] Other Refrigeration
[ ] Industrial Process Refrigeration [ ] Commercial Refrigeration
[ ] Small appliances < 5 pounds [ ] Trucks, buses, trains or planes with R-22
Industrial Process Refrigeration, Comfort Cooling,
Commercial and Other Refrigeration
7. For each service technician do you have a record of his/her name, certification level,
certification number, testing agency and the type of equipment he or she services
(e.g. small, high pressure, low pressure)?
8. Does your facility send used refrigerant to an EPA-approved reclamation facility?
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9. Have you converted any of your equipment to a new refrigerant?
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USC EHS Office of Hazardous Waste
(EHS-F-122) Environmental Audit Program
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10. Are the new refrigerant(s) approved under EPA’s Significant New Alternatives
Policy (SNAP) Program?
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11. Was a new refrigerant label installed on the equipment?
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12. Do any of the refrigerant equipment types checked in question 1 contain more
than 50 pounds of refrigerant?
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14. Does your facility keep service records on all 50+ pound units that document the
date and type of service as well as the quantity of refrigerant added?
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15. Does that facility calculate the leak rate on all 50+ pound units?
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19. Does your facility service, maintain, or repair motor vehicle air
conditioners (MVAC)?
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20. List all refrigerant that the facility uses. – (e.g. H-134A)
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21. Are the refrigerants other than CFC-12 listed above approved under
EPA’s Significant New Alternatives Policy (SNAP) Program?
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22. Does the facility have a refrigerant identifier?
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23. Have the following been recorded for each piece of recovery equipment:
a. the manufacturer's name
b. the model number
c. type of machine (e.g. recover-only)
d. rated refrigerants
____
____ ____
13. Has each of the following been recorded for each unit containing more than
50 pounds of refrigerant:
a. the location
b. company
c. designation
d. manufacturer
e. model #
f. serial # from name plate
g. refrigerant type
h. refrigerant charge
i. method used to determine full charge.
NOTE: The leak rate that triggers mandatory repairs is 15%
Comfort & Other and 35% for Industrial Process & Commercial
in a 12 month period.
16. Are leaks above the allowable leak rate repaired within 30 days, Or 120 days if
an industrial process shut down is required?
17. If no repairs were conducted or repairs failed, was a retrofit or retirement plan
prepared and available for review?
18. FOR INDUSTRIAL PROCESS ONLY: If leak repairs have been conducted, was
a. An initial verification test conducted?
b. A follow-up verification test conducted within 30 days of the successful
initial verification test?
Motor Vehicles
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e. whether the equipment has been certified by Underwriters Laboratory (UL)
or ETL Testing Laboratories, Inc.(ETL) to meet EPA requirements.
24. For recovery-only equipment, is refrigerant recycled on-site, or reclaimed off-site by
an approved reclaimer?
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____ ____
25. Have you submitted to EPA a recovery equipment certification form?
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26. Are your service technicians trained and certified by an accredited program?
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35. Does the facility own recovery equipment?
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36. For each piece of recovery equipment have the following been recorded:
a. the manufacturer’s name
b. the year manufactured
c. the model number
d. serial number
e. the rated refrigerants?
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37. Have you submitted to EPA a recovery equipment certification form?
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38. When you recover refrigerant from MVACs, do you reduce the system pressure to
or below 102 mm of mercury vacuum?
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39. Does your facility send recovered refrigerant to either:
a. an EPA-approved reclamation facility
b. a facility that services MVACs.
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40. Is your recovery equipment certified under Section 609 of the Clean Air Act?
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27. For each service technician do you have a record of his/her name, certification
number, and training program.
28. Does the facility have in stock the following for refrigerant listed
other than CFC-12?
____
Unique Service Fittings
Permanent Labels
Barrier Hoses (required only for blends that contain R-22)
Compressor Shutoff Switch (required only for A/C systems that include a
high-pressure cutoff switch).
29. Has any of your recovery/recycling equipment been converted to alternative
(non-CFC-12) refrigerant service?
30. Have unique fittings been permanently attached to converted equipment?
31. Do you take the final step in the disposal process of motor vehicle
air conditioners (MVACs)?
32. Estimate your weekly volume of MVACs received?
[ ] 0 - 10 [ ] 20 - 30 [ ] 40 - 50
[ ] 10 - 20 [ ] 30 - 40 [ ] 50+
33. Do you accept MVACs with the refrigerant charge intact?
34. Who recovers the refrigerant from the MVAC at your facility?
[ ] a. owner, operator, employee of the disposal facility
[ ] b. contractor to the disposal facility
[ ] c. technicians who service MVACs
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41. Are you selling the refrigerant to technicians who are trained and certified under
Section 609 of the Clean Air Act?
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42. Do you retain invoices that indicate the name of the purchaser, the date of sale,
and the quantity of the refrigerant purchased?
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43. Do you allow MVAC service technicians to recover (i.e., remove refrigerant in
any condition from an appliance and store it in a container without testing or
processing) refrigerant at your facility?
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44. Are the technicians trained and certified under Section 609 of the Clean Air Act?
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45. Are the technicians using recovery equipment certified under Section 609
of the Clean Air Act?
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46. Do you accept MVACs where the refrigerant has been evacuated from
the appliance previously?
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47. Is it verified that the refrigerant has been evacuated from the appliance
previously by either:
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48. Have you notified the suppliers of your appliances that refrigerant must be properly
removed before the delivery of the items to the facility (e.g warning signs, letters
to suppliers)?
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49. Do you keep your verification statements and/or contracts with suppliers at the
facility for three years?
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a. accepting a signed statement from the person delivering the appliance that
all refrigerant that had not leaked previously has been properly recovered from
the appliance (This statement must include the name and address of the person
who recovered the refrigerant and the date the refrigerant was recovered); or
b. establishing a contract with suppliers that refrigerant will be removed prior
to delivery.
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FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT (FIFRA)
PROGRAM
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FIFRA Program Audit Report
Auditors Name
Date
Location
Auditors Signature
Time of Audit
Project Manager
Findings:
Regulatory Requirements:
Recommendations:
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FIFRA Audit Checklist
Administrative
Yes
No
N/A
1. Are all personnel who apply pesticides over the age of 18?
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2. Have all personnel passed the examinations required for the
chemicals that they are applying?
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3. Are persons registered to use restricted use pesticides in any of the following
highlighted categories of commercial pesticide-application operations:
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5. Do all personnel have a current license and registration?
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6. Have the personnel taken the 10 Continuing Certification hours required
to meet the requirements listed below?
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7. Are the applicator records organized well and available for review?
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a. Agricultural Pest Control (Category 1).
i.
Plant (Category 1A).
ii.
Animal (Category 1B).
iii.
Stored Product Pest Control (Category 1C).
b. Forest Pest Control (Category 2).
c. Ornamental and Turf Pest Control (Category 3).
d. Seed treatment (Category 4).
e. Aquatic Pest Control (Category 5).
f. Right-of-way Pest Control (Category 6).
g. Industrial, Institutional, Structural and Health-Related Pest Control (Category 7).
i.
General (Category 7A).
ii.
Fumigation (Category 7B).
Note: USC is involved in 2,3,5, & 7 as highlighted above
4. Have commercial applicators accomplished the following:
a. Pass the Core examination, a basic test dealing with the
minimum amount of subject matter considered essential to
the safe use of restricted use pesticides.
b. Pass a separate Category examination for each of the practice
areas listed above.
Note: passing the core exam without passing a category exam
does not entitle the applicant to use or supervise the use of
Restricted Use Pesticides or perform pest control activities
in categories for which licensing is required.
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8. Do applicator records list:
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9. Are the records for pre-construction termite-control treatments (“pretreats”),
including the installation of bait systems and baits containing active
ingredients, records of termiticide application must be maintained
for a period of five (5) years?
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10. Are the records for post-construction termite-control treatments, including
the installation of bait systems and baits containing active ingredients,
records of termiticide application must be maintained for a period of
two (2) years from the date of application?
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11. Is there a licensed applicator within 30 (thirty) minutes of the application
site by ordinary ground transportation and immediately available by
telephone or radio?
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12. Does the applicator of all fumigants have an a valid Commercial Applicators
License in Category 7B, Category 1C, or other appropriate category as
determined by the Department, and is physically present on site and
supervising the application at all times when pesticide is being applied.
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13. Does the applicator of all pesticides classified as “restricted use” by the
EPA or the Department, have an a valid Applicators License in the Category
and is within 30 (thirty) miles by ordinary ground transportation of the
application site and immediately accessible by telephone or radio?
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14. Does the applicator of all pesticides which has the signal word “danger”
or “warning” will require the licensee supervising the application to be within
60 (sixty) miles by ordinary ground transportation of the application site and
immediately accessible by telephone or radio?
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15. Does the applicator of all pesticides which has the signal word “Caution”
will require the licensee supervising the application to be within 100
(one-hundred) miles by ordinary ground transportation of the application
site and immediately available by telephone or radio?
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16. Are all pesticides stored in quantity stored in securely locked well ventilated
rooms, well away from all food or feed items?
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17. Are Pesticides separated during storage, preferably in bins, depending upon
the type of pesticide. Each type of pesticide, i.e., herbicides, insecticides,
fungicides, et cetera, must be stored separately from each other?
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18. Are the Herbicides not stored in a bin on top of, or located above, any
other type of pesticide, to preclude accidental contamination of other
pesticides by leakage or spillage?
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a. the quantity of each pesticide used, received, or purchased?
b. the common chemical name of the active ingredient(s)
(not the product name)?
c. the pest or purpose for which the pesticide was applied?
d. the date and place of application?
Note: It is not necessary to list the pests involved for general household
insect control or for general insect control measures in commercial and
industrial establishments. In these cases the record may indicate merely
“household pests” or “general insect control.”
Handling
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19. Are there any leaking containers?
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20. Are any leaking containers stored in an “overpack” container or similar
device that is sufficient to contain the leak?
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21. Has any residue been cleaned up by an appropriate decontamination method?
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22. Has the location where any pesticide material has been spilled been
immediately decontaminated by a method appropriate to the material spilled?
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23. Do the vehicles used to transport pesticides to and from the application site,
or used in the actual application of pesticides, have an identification symbol,
furnished by the Department, on both the right and left sides of the vehicle?
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24. Is the symbol maintained clean and recognizable from a minimum distance
of one hundred feet?
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Transportation.
Disposal
25. Are unwanted pesticides and pesticide containers disposed of in accordance
with the regulations promulgated by the South Carolina Department of Health
and Environmental Control?
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POLYCHLORINATED BIPHENYL (PCB) PROGRAM
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PCB Audit Report
Auditors Name
Date
Location
Auditors Signature
Time of Audit
Project Manager
Findings:
Regulatory Requirements:
Recommendations:
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PCB Transformers Audit Checklist
Documentation
Yes
No
N/A
1. Have all PCB and PCB contaminated transformers been inventoried?
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2. Are all transformers registered with the US EPA?
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3. Are registration records available onsite?
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4. Is an Annual Records Log maintained onsite?
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5. Is an Annual Document Log maintained onsite?
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6. Are manifests available for all PCB shipments?
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7. Is a certificate of disposal available for all waste that has manifested?
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8. Is all documentation retained onsite for a period of three (3) years?
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Marking
9. Is each room or vault containing a transformer marked with a TSCA
compliant PCB mark?
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10. Is each transformer marked with a TSCA compliant PCB mark?
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Inspections
11. Are all PCB transformers with a PCB concentration of 60,000 ppm or greater
inspected quarterly, with a minimum of 30 days between inspections?
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12. Are all PCB transformers with a PCB concentration of less than 60,000 ppm
inspected annually, with a minimum of 180 days between inspections?
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13. Are combustible materials stored outside of the transformer vault?
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14. Is the transformer free of leaks?
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15. Are leaks monitored and documented daily?
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16. Are leaks cleaned up within 48 hours of discovery?
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17. Is the area around the transformer free of any drain valves, floor drains,
expansion joints, sewer lines or other openings that would allow potential
leaks to escape?
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18. Are the drain valves, floor drains, expansion joints, sewer lines or other
openings blocked from potential leaks?
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19. Is the flooring free of Cracks?
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20. Does the area have adequate roofing and walls to prevent storm
water from entering?
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21. Are PCB items disposed of within one year of the date they were placed into storage? ____
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Waste Management
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PCB Audit Checklist for Laboratories
Documentation
Yes
No
N/A
1. Have all PCB and PCB contaminated transformers been inventoried?
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2. Are all PCB items inspected annually?
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3. Are all laboratory PCBs maintained at a concentration less than 50ppm?
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4. Is an Annual Records Log maintained onsite?
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5. Is an Annual Document Log maintained onsite?
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6. Are manifests available for all PCB shipments?
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7. Is a certificate of disposal available for all waste that has manifested?
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8. Is all documentation retained onsite for a period of three (3) years?
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Marking
9. Is each room or laboratory containing PCBs marked with a TSCA
compliant PCB mark?
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10. Is each PCB container marked with a TSCA compliant PCB mark?
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11. Are all containers holding PCBs closed?
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12. Are all containers holding PCBs free of leaks?
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22. Are leaks monitored and documented daily?
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13. Are leaks cleaned up within 48 hours of discovery?
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14. Are all containers holding PCBs stored in secondary containment?
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15. Is the secondary containment vessel in good condition and free of cracks and holes? ____
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16. Is the secondary containment vessel adequate to contain 100% of the volume
of the PCB container?
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17. Is the area around the container free of any drain valves, floor drains,
expansion joints, sewer lines or other openings that would allow potential
leaks to escape?
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18. Are the drain valves, floor drains, expansion joints, sewer lines or other
openings blocked from potential leaks?
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19. Is the flooring free of cracks?
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Inspections
20. Does the area have adequate roofing and walls to prevent stormwater from entering? ____
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Waste Management
21. Is the date that the PCB items become waste clearly marked on the storage container? ____
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22. Is hazardous PCB waste disposed of within 90-days of the date that
they were placed into storage?
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23. Is non-hazardous PCB waste disposed of within one year of the date they
were placed into storage?
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PCB Ballasts Audit Checklist
Documentation
Yes
No
N/A
1. Are manifests available for all PCB ballast shipments?
____
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____
2. Are PCB ballasts disposed of through a TSCA approved disposal facility?
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3. Is all documentation retained onsite for a period of three (3) years?
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Marking
4. Is each drum containing waste PCB ballasts marked with a TSCA
compliant PCB mark?
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5. Are all PCB ballasts disposed of in 55-gallon drums?
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6. Are all drums holding PCBs closed?
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7. Are all drums holding PCBs free of leaks?
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8. Is the drum in good condition and free of cracks and holes?
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9. Is the date that ballasts become waste clearly marked on the storage drum?
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10. Are PCB Ballasts disposed of within one year of the date they
were placed into storage?
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Inspections
Waste Management
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