Record Keeping
United States
Office of Water
832-F-99-005
Environmental Protection
Washington, D.C.
September 1999
Agency
Storm Water
Management Fact Sheet
Record Keeping
DESCRIPTION
C
All original strip chart recordings for
continuous monitoring equipment.
Keeping records of spills, leaks, and other
discharges can help a facility run more efficiently
C
Records of any non storm water discharges.
and cleanly. Records of past spills contain useful
information for improving Best Management
Figure 1 shows a sample worksheet for tracking
Practices (BMPs) to prevent future spills. Typical
spills and leaks.
items that should be recorded include the results of
routine inspections, and reported spills, leaks, or
Record keeping is usually coordinated with internal
other discharges.
reporting and other BMPs, and is often integrated
into the development of a facility’s Storm Water
Records should include:
Pollution Prevention Plan (SWPPP) as part of the
facility’s NPDES storm water discharge permit.
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The date, exact place, and time of material
inventories, site inspections, sampling
APPLICABILITY
observations, etc.
Records keeping is a basic business practice and is
C
Names of inspector(s) and sampler(s).
applicable to all facilities. If a separate record
keeping system for tracking BMPs, monitoring
C
Analytical information, including the date(s)
results, etc., is not currently in place at a facility,
and time(s) analyses were performed or
existing record keeping structures can be easily
initiated, the analysts’ names, analytical
adapted to incorporate this data. An ideal tool for
techniques or methods used, analytical
implementation is the record keeping procedures
results, and quality assurance/quality control
laid out in an SWPPP.
results of such analyses.
ADVANTAGES AND DISADVANTAGES
C
The date, time, exact location, and a
complete characterization of significant
Record keeping is a simple, easily implemented, and
observations, including spills or leaks.
cost effective management tool. Complete, well-
organized records can help ensure proper
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Notes indicating the reasons for any
maintenance of facilities and equipment and can aid
exceptions to standard record keeping
in determining the causes of spills and leaks; thus,
procedures.
record keeping can protect water quality by helping
to prevent future leaks and spills.
C
All calibration and maintenance records of
instruments used in storm water monitoring.
Limitations of a record keeping system may
including the following:
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Records must be updated regularly.
for Modification to Water Quality Order
No. 91-13 DWQ Waste Discharge
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Personnel completing and maintaining
Requirements for Dischargers of Storm
records must be trained to update records
Water Associated with Industrial Activities,
correctly.
Draft Wording, Monitoring Program and
Reporting Requirements.
C
The records need to be readily accessible.
2.
U.S. EPA, 1981. NPDES BMP Guidance
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Records containing any confidential
Document.
information must be secured.
3.
U.S. EPA, Pre-print, 1992. Storm Water
IMPLEMENTATION
Management for Industrial Activities:
Developing Pollution Prevention Plans and
The key to maintaining records is continual
Best Management Practices. EPA 832-R-
updating. Ensure that new information, such as
92-006.
analytical results, is added to existing inspection
records or spill reports as it becomes available. In
ADDITIONAL INFORMATION
addition, update records if there are changes to the
number and location of discharge points, principal
Center for Watershed Protection
products, or raw material storage procedures.
Tom Schueler
Maintain records for least five years from the date
8391 Main Street
of sample observation, measurement, or spill report.
Ellicott City, MD 21043
Some simple techniques used to accurately
document and report results include:
Northern Virginia Planning District Commission
David Bulova
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Field notebooks.
7535 Little River Turnpike, Suite 100
Annandale, VA 22003
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Timed and dated photographs.
Oklahoma Department of Environmental Quality
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Videotapes.
Don Mooney
Water Quality Division, Storm Water Unit
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Drawings and maps.
P.O. Box 1677
Oklahoma City, OK 73101-1677
C
Computer spreadsheets and database
programs.
Southeastern Wisconsin Regional Planning
Commission
COSTS
Bob Biebel
916 N. East Avenue, P.O. Box 1607
Costs are those associated with staff hours used to
Waukesha, WI 53187
develop and implement a record keeping system,
costs for analyzing samples, and company overhead
United States Postal Service
costs. Figure 2 is a sample worksheet that can be
Charles Vidich
used to determine annual record keeping costs.
6 Griffin Road North
Table 1 is an example of a completed record
Windsor, CT 06006-7030
keeping costs sheet.
The mention of trade names or commercial products
REFERENCES
does not constitute endorsement or recommendation
for the use by the U.S. Environmental Protection
1.
California Environmental Protection
Agency.
Agency, August 17, 1992. Staff Proposal
Worksheet
LIST OF SIGNIFICANT SPILLS AND LEAKS
Completed by: ___________________________________
Title: ___________________________________________
Date: ___________________________________________
Directions: Record below all significant spills and significant leaks of toxic or hazardous pollutant that have occurred at the facility in the three years prior to the
effective date of the permit.
Definitions:
Significant spills include, but are not limited to, releases of oil or hazardous substances in excess of reportable quantities.
1st Year
Prior
Description
Response Procedure
Date
Spill
L
Location
Type of
Quantity
Source, If
Reason
Amount of
Material No
Preventive Measure Taken
(mo/day/yr)
e
(as indicated
Material
Known
Material
Longer
a
on site map)
Recovered
Exposed to
k
Storm Water
(True / False)
2nd Year
Prior
Description
Response Procedure
Date
Spill
L
Location
Type of
Quantity
Source, If
Reason
Amount of
Material No
Preventive Measure Taken
(mo/day/yr)
e
(as indicated
Material
Known
Material
Longer
a
on site map)
Recovered
Exposed to
k
Storm Water
(True / False)
3rd Year
Prior
Description
Response Procedure
Date
Spill
L
Location
Type of
Quantity
Source, If
Reason
Amount of
Material No
Preventive Measure Taken
(mo/day/yr)
e
(as indicated
Material
Known
Material
Longer
a
on site map)
Recovered
Exposed to
k
Storm Water
(True / False)
Source: U.S. EPA, 1992.
FIGURE 1 SAMPLE WORKSHEET FOR TRACKING SPILLS AND LEAKS
Title
Quantity
Average
Overhead
Estimated
Estimated Annual Cost($)
Hourly
Multiplier
Yearly Hours on
Rate ($)
SW Training
_______
_______
x
_________
x
________
x
____________
=
________ (A)
_______
_______
x
_________
x
________
x
____________
=
________ (B)
_______
_______
x
_________
x
________
x
____________
=
________ (C)
_______
_______
x
_________
x
________
x
____________
=
________ (D)
Total Estimated Annual Reporting Cost ________
(Sum of A+B+C+D)
Source: U.S. EPA, 1992.
FIGURE 2 SAMPLE ANNUAL RECORD KEEPING COST WORKSHEET
TABLE 1 EXAMPLE OF ANNUAL RECORD KEEPING COSTS
Title
Quantity
Average
Overhead*
Estimated Yearly
Estimated Annual
Hourly
Multiplier
Hours on SW
Cost ($)
Rate ($)
Training
Storm Water
1
x
15
x
2.0
x
20
=
600
Engineer
Plant
5
x
20
x
2.0
x
10
=
2,000
Management
Plant
100
x
10
x
2.0
x
5
=
10,000
Employees
Total Estimated Annual Cost:
$12,600
*Note: Defined as a multiplier (typically ranging between 1 and 3) that takes into account those costs associated
with payroll expenses, etc
Source: U.S. EPA, 1992.
For more information contact:
Municipal Technology Branch
U.S. EPA
Mail Code 4204
401 M St., S.W.
Washington, D.C., 20460
