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:

C The date, exact place, and time of material

inventories, site inspections, sampling

observations, etc.

C Names of inspector(s) and sampler(s).

C 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.

C The date, time, exact location, and a

complete characterization of significant

observations, including spills or leaks.

C Notes indicating the reasons for any

exceptions to standard record keeping

procedures.

C All calibration and maintenance records of

instruments used in storm water monitoring.

C All original strip chart recordings for

continuous monitoring equipment.

C 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, wellorganized 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:
C Records must be updated regularly.

C Personnel completing and maintaining

records must be trained to update records

correctly.

C The records need to be readily accessible.

C 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:

C Field notebooks.

C Timed and dated photographs.

C Videotapes.

C Drawings and maps.

C 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-R92-006.

ADDITIONAL INFORMATION

Center for Watershed Protection

Tom Schueler

8391 Main Street

Ellicott City, MD 21043

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, WI 53187

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

Worksheet

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 

(mo/day/yr)

Spill L

e

a

k

Location

(as indicated

on site map)

Type of

Material

Quantity Source, If

Known

Reason Amount of

Material

Recovered

Material No

Longer

Exposed to

Storm Water

(True / False)

Preventive Measure Taken

2nd Year

Prior

Description Response Procedure

Date 

(mo/day/yr)

Spill L

e

a

k

Location

(as indicated

on site map)

Type of

Material

Quantity Source, If

Known

Reason Amount of

Material

Recovered

Material No

Longer

Exposed to

Storm Water

(True / False)

Preventive Measure Taken

3rd Year

Prior

Description Response Procedure

Date 

(mo/day/yr)

Spill L

e

a

k

Location

(as indicated

on site map)

Type of

Material

Quantity Source, If

Known

Reason 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

Hourly

Rate ($)

Overhead

Multiplier

Estimated

Yearly Hours on

SW Training

Estimated Annual Cost($)

_______ _______ 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

Hourly

Rate ($)

Overhead*

Multiplier

Estimated Yearly

Hours on SW

Training

Estimated Annual

Cost ($)

Storm Water

Engineer

1 x 15 x 2.0 x 20 = 600

Plant

Management

5 x 20 x 2.0 x 10 = 2,000

Plant

Employees

100 x 10 x 2.0 x 5 = 10,000

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