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:

-------
      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.

-------
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

-------
    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
                                                  Excelence fh compliance through optimal technical soLtron^
                                                  MUNICIPAL TECHNOLOGY

-------