v>EPA
United States
Environmental Protection
Agency
Office of Water
Washington, D.C.
832-F-99-005
September 1999
Storm Water
Management Fact Sheet
Record Keeping
DESCRIPTION
Keeping records of spills, leaks, and other
discharges can help a facility run more efficiently
and cleanly. Records of past spills contain useful
information for improving Best Management
Practices (BMPs) to prevent future spills. Typical
items that should be recorded include the results of
routine inspections, and reported spills, leaks, or
other discharges.
Records should include:
• The date, exact place, and time of material
inventories, site inspections, sampling
observations, etc.
• Names of inspector(s) and sampler(s).
• Analytical information, including the date(s)
and time(s) analyses were performed or
initiated, the analysts' names, analytical
techniques or methods used, analytical
results, and quality assurance/quality control
results of such analyses.
• The date, time, exact location, and a
complete characterization of significant
observations, including spills or leaks.
• Notes indicating the reasons for any
exceptions to standard record keeping
procedures.
• All calibration and maintenance records of
instruments used in storm water monitoring.
• All original strip chart recordings for
continuous monitoring equipment.
• Records of any non storm water discharges.
Figure 1 shows a sample worksheet for tracking
spills and leaks.
Record keeping is usually coordinated with internal
reporting and other BMPs, and is often integrated
into the development of a facility's Storm Water
Pollution Prevention Plan (SWPPP) as part of the
facility's NPDES storm water discharge permit.
APPLICABILITY
Records keeping is a basic business practice and is
applicable to all facilities. If a separate record
keeping system for tracking BMPs, monitoring
results, etc., is not currently in place at a facility,
existing record keeping structures can be easily
adapted to incorporate this data. An ideal tool for
implementation is the record keeping procedures
laid out in an SWPPP.
ADVANTAGES AND DISADVANTAGES
Record keeping is a simple, easily implemented, and
cost effective management tool. Complete, well-
organized records can help ensure proper
maintenance of facilities and equipment and can aid
in determining the causes of spills and leaks; thus,
record keeping can protect water quality by helping
to prevent future leaks and spills.
Limitations of a record keeping system may
including the following:
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• Records must be updated regularly.
• Personnel completing and maintaining
records must be trained to update records
correctly.
• The records need to be readily accessible.
• Records containing any confidential
information must be secured.
IMPLEMENTATION
The key to maintaining records is continual
updating. Ensure that new information, such as
analytical results, is added to existing inspection
records or spill reports as it becomes available. In
addition, update records if there are changes to the
number and location of discharge points, principal
products, or raw material storage procedures.
Maintain records for least five years from the date
of sample observation, measurement, or spill report.
Some simple techniques used to accurately
document and report results include:
• Field notebooks.
• Timed and dated photographs.
• Videotapes.
• Drawings and maps.
• Computer spreadsheets and database
programs.
COSTS
Costs are those associated with staff hours used to
develop and implement a record keeping system,
costs for analyzing samples, and company overhead
costs. Figure 2 is a sample worksheet that can be
used to determine annual record keeping costs.
Table 1 is an example of a completed record
keeping costs sheet.
REFERENCES
1. California Environmental Protection
Agency, August 17, 1992. Staff Proposal
for Modification to Water Quality Order
No. 91-13 DWQ Waste Discharge
Requirements for Dischargers of Storm
Water Associated with Industrial Activities,
Draft Wording, Monitoring Program and
Reporting Requirements.
2. U.S. EPA, 1981. NPDES BMP Guidance
Document.
3. U.S. EPA, Pre-print, 1992. Storm Water
Management for Industrial Activities:
Developing Pollution Prevention Plans and
Best Management Practices. EPA 832-R-
92-006.
ADDITIONAL INFORMATION
Center for Watershed Protection
Tom Schueler
8391 Main Street
Ellicott City, MD21043
Northern Virginia Planning District Commission
David Bulova
7535 Little River Turnpike, Suite 100
Annandale, VA 22003
Oklahoma Department of Environmental Quality
Don Mooney
Water Quality Division, Storm Water Unit
P.O. Box 1677
Oklahoma City, OK 73101-1677
Southeastern Wisconsin Regional Planning
Commission
Bob Biebel
916 N. East Avenue, P.O. Box 1607
Waukesha, WI53187
United States Postal Service
Charles Vidich
6 Griffin Road North
Windsor, CT 06006-7030
The mention of trade names or commercial products
does not constitute endorsement or recommendation
for the use by the U.S. Environmental Protection
Agency.
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LIST OF SIGNIFICANT SPILLS AND LEAKS
Workshee
Complete
Title:
it
dbv:
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
Date
(mo/day/yr)
2nd Year
Prior
Date
(mo/day/yr)
3rd Year
Prior
Date
(mo/day/yr)
Spill
L
e
a
k
Location
(as indicated
on site map)
Description
Type of
Material
Quantity
Source, If
Known
Reason
Response Procedure
Amount of
Material
Recovered
Material No
Longer
Exposed to
Storm Water
(True / False)
Preventive Measure Taken
Spill
L
e
a
k
Location
(as indicated
on site map)
Description
Type of
Material
Quantity
Source, If
Known
Reason
Response Procedure
Amount of
Material
Recovered
Material No
Longer
Exposed to
Storm Water
(True / False)
Preventive Measure Taken
Spill
L
e
a
k
Location
(as indicated
on site map)
Description
Type of
Material
Quantity
Source, If
Known
Reason
Response Procedure
Amount of
Material
Recovered
Material No
Longer
Exposed to
Storm Water
(True / False)
Preventive Measure Taken
Source: U.S. EPA, 1992.
FIGURE 1 SAMPLE WORKSHEET FOR TRACKING SPILLS AND LEAKS
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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
Engineer
Plant
Management
Plant
Employees
1 x 15 x 2.0 x 20
5 x 20 x 2.0 x 10 =
100 x 10 x 2.0 x 5
Total Estimated Annual Cost:
600
2,000
10,000
$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
IMTB
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