United States

Environmental Protection

Agency

Office of Water

Washington, D.C.

EPA 832-F-99-020

September 1999

Storm Water

Management Fact Sheet

Internal Reporting

DESCRIPTION

Internal reporting provides a framework for

"chain-of-command" reporting of storm water

management issues. Typically, a facility develops a

Storm Water Pollution Prevention Team (SWPPT)

concept for implementing, maintaining, and revising

the facility's Storm Water Pollution Prevention Plan

(SWPPP). The purpose of identifying a SWPPT is

to clarify the chain of responsibility for storm water

pollution prevention issues and to provide a point of

contact for personnel outside the facility who need

to discuss the SWPPP.

APPLICABILITY

The U.S. EPA first identified internal reporting as a

BMP in the late 1970s. Currently, internal reporting

has evolved into the development of a SWPPT for

facilities implementing a SWPPP as part of their

NPDES storm water discharge permit. This

SWPPT concept is a new and innovative part of the

SWPPP.

ADVANTAGES AND DISADVANTAGES

Internal reporting is an essential part of any good

record keeping program. When properly

implemented, an internal reporting program can

clearly define individual’s roles and responsibilities

for implementing and maintaining the SWPP,

thereby making it easier to prevent and contain

potential storm water contamination. 

Limitations involved in developing an internal

reporting system are:

• Corporate commitment in designating

appropriate funds may be lacking. 

• Inadequate staff hours may be available for

proper implementation.

• Low motivation from SWPPT members

could inhibit the transfer of key storm water

pollution information.

KEY PROGRAM COMPONENTS

When establishing an internal reporting structure, it

is important to select appropriate personnel at all

levels to serve on the team. Both team and

individual responsibilities should be designated with

clear goals defined for proper storm water

management. Internal reporting should be tied to

other baseline BMPs, such as employee training,

individual inspections, and record keeping to ensure

proper implementation. Figure 1 illustrates an

example SWPPT organization chart.

IMPLEMENTATION

The key to implementing internal reporting as a

BMP is to establish a qualified SWPPT. When

setting up a SWPPP, it is important to identify key

people on-site who are most familiar with the

facility and its operations and who can also provide

adequate structure and direction to the facility's

entire storm water management program.

The performance and effectiveness of a facility’s

internal reporting system is highly variable and

dependent upon several factors. Key factors

include:
FIGURE 1 EXAMPLE OF A SWPPT ORGANIZATION CHART

C Commitment of senior management. 

C Sufficient time and financial resources.

C Quality of implementation.

C Background and experience of the SWPPT.

To ensure that an internal reporting system remains

effective, the person or team responsible for

maintaining the SWPPP must be aware of any

changes in plant operations or with key team

members to determine if modifications must be

made in the overall execution of the SWPPP.

COSTS

Costs associated with implementing an internal

reporting system are those associated with

additional staff hours and related overhead costs.

Annual costs can be estimated using the example

shown in Table 1. Table 2 can be used as a

worksheet to calculate the estimated costs for an

internal record keeping program.

REFERENCES

1. U.S. EPA, 1981. NPDES BMP Guidance

Document. 

2. U.S. EPA, 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
Title Quantity Average

Hourly

Rate ($)

Overhead*

Multiplier

Estimated

Yearly Hours

on SW

Training

Estimated

Annual

Cost ($)

Stormwater 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 between 1 and 3) that takes into account those costs associated with payroll expenses, building

expenses, etc.

 Source: U.S. EPA, 1992.

TABLE 1 EXAMPLE OF ANNUAL INTERNAL REPORTING COSTS

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.

TABLE 2 EXAMPLE OF ANNUAL INTERNAL REPORTING COST WORKSHEET

For more information contact:

Municipal Technology Branch

U.S. EPA

Mail Code 4204

401 M St., S.W.

Washington, D.C., 20460

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.