Most of us who work in the wastewater field know we need to keep records as part of our permit requirements. But with so many things to do during the day it seems hard to justify adding more record keeping to our schedules. So why do more than what is required? One reason is to evaluate trends or plant upsets so that you can maximize plant performance. You can also use relevant records to develop and maintain a preventative maintenance program. In both situations the little extra record keeping more than pays for itself in cost savings and increases overall plant and personnel efficiency.
Another reason is to protect yourself and your facility from unnecessary litigation and unjust claims. Odor problems, sewer backups, permit violations, work-related accidents are all events where proper resolution is dependent on clear and precise record keeping. Memories of events don’t count – only the records of these events and of your remedial actions do.
Use a bound notebook with numbered pages and use permanent ink for all record keeping. Never remove a page from the bound book. If you make any mistakes while writing, do not erase or use “white-out,” simply draw a line through the mistake and add your initials next to it. Always keep your records neat, organized, and secure.
For NPDES purposes, you must keep your monitoring records for three years.
Most of your sludge monitoring records must be retained for five years or more. Details of these are outlined in Title 40 Code of Federal Regulations (40 CFR) part 122 and in 40 CFR part 503. Use common sense when disposing old records. You should keep all records beyond the minimum retention time that will aid you in evaluating operating trends or in anything that is part of, or may be part of, litigation.
While it is in your best interests to keep records of all aspects of wastewater treatment and collection systems, the EPA expects you to keep certain monitoring records. These include recording the date, exact place, and time of sampling or measurements; individual who performed sampling or measurements; dates analyses were performed; individual who performed analysis; analytical techniques used; and the results of the analyses. EPA takes your records seriously. Any person who “falsifies, tampers with, or knowingly renders inaccurate any monitoring device or method required” may be fined up to ten thousand dollars and spend two years in jail. And that’s just the beginning. It gets worse from there. Never cook the books.
Also, be aware that many errors that occur in record keeping happen when transferring data. Be consistent with labels. Use the same symbols, abbreviations, or names for a sample from collection to the final report. A problem I’ve experienced started with a sample bottle labeled “underflow” for the gravity belt underflow sample. On the lab TSS calculation sheet it is listed as “BTU” for BelT Underflow. The result was transferred to “Underflow – TSS” in the lab log, and finally the result is entered into the computer program under the heading “Supnt TSS.” Different departments in the facility had their own code system for record keeping. The problem was that one sample type had four different names. Being consistent in your labeling will not only aid you in reducing data transfer errors, it will help regulatory inspectors navigate through your records.
Another source of error occurs when measurement units must be changed.
Results for metals, for example, are often reported in lab reports as mg/L, but your regulatory agency may require you to report these in your NPDES permit as ug/L. It can look like there is a violation when there is none.
Always double check the units you must report in.
Finally, be consistent in the order in which data is recorded or transferred. For instance, if you must transfer the results of ammonia, TKN, nitrate, and nitrite from the lab log to a data acquisition computer program, make sure both the log and computer program list these nitrogen species in the same order. Otherwise it is too easy to switch results around, especially when you’re hurrying to get the data transferred before the end of the work day.
The information in this article is very general. As usual, check your federal, state, and local regulations. You may have additional regulations or requirements that you must meet.
If you have any questions, suggestions, or comments, please contact NEWEA Lab Practices Committee Chair Tim Loftus at (508) 949-3865 (firstname.lastname@example.org).