6.4 Operating Records, Logbooks, Reports & Data Integrity

Operating Records, Logbooks, Reports & Data Integrity

The ABC criteria list "maintain records of operation of treatment facilities," "evaluate and maintain operating records," "complete reports on plant operation," "complete equipment maintenance and repair records, including work orders," and "complete required regulatory reports." Records are the operator's product as much as the treated water is - and in an enforcement action, they are the only version of events that exists.

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1. The Daily Operating Log

What belongs in it

How entries are made

• Contemporaneously. Write it when it happens, not at the end of the week.
• In permanent ink, in a bound book with pre-numbered pages, or in a controlled electronic system with an audit trail. Loose leaf and pencil are not records.
• Signed or initialed by the person making the entry.
• Corrections: a single line through the error, the correct value written beside it, initialed and dated. Never erase, never white out, never write over, never obliterate. A corrected entry that is still legible is credible; an obliterated one is not.
• No blank lines or blank days. If nothing happened, write that. A gap invites the question of what was removed.
• Facts, not conclusions. "Effluent turbidity 0.42 NTU at 0930; filter 3 removed from service" is a record. "Filter 3 acting up again" is not.

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2. Reports

The MOR and DMR are compiled from the daily log and the laboratory records. They should be traceable line by line back to a bench sheet and a log entry; if they are not, the reviewer's next question is where the numbers came from.

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3. Laboratory Records and Chain of Custody

Bench sheets

The raw record of an analysis: sample identification, date and time of collection and analysis, analyst, method, instrument, standards and reagents used with lot numbers and expiration dates, raw readings, calculations, and the final result. The bench sheet, not the report, is the primary record.

Quality control records

Method blanks, duplicates, matrix spikes, laboratory control samples, calibration and calibration verification, control charts, and the acceptance criteria applied. A result without its QC context is not defensible.

Chain of custody

A chain of custody form documents that the sample was in the possession of an identified person, or in a secured location, at every moment from collection to analysis. It records:

• Sample identification, collection date, time, and location;
• Collector's name and signature;
• Sample type, preservation, and container;
• Each transfer, with the signature of the person relinquishing and the person receiving, and the date and time;
• Condition on receipt, including temperature; and
• Any anomalies.

For routine process control samples chain of custody is unnecessary. For any sample that may support an enforcement action, a permit determination, or a legal proceeding, it is essential - a perfect analytical result on a sample with a broken chain may be inadmissible.

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4. Retention Periods

When in doubt, keep it longer. Storage is cheap; a missing record during an enforcement action is not.

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5. Electronic Records and SCADA

Most plants now generate more data electronically than on paper, which creates its own compliance obligations.

• Access control. Who can change a setpoint, an alarm limit, or a historized value must be defined, and each user must have an individual account. Shared logins destroy accountability.
• Audit trail. Any system holding compliance data must record who changed what, when, and what the prior value was. A spreadsheet on a shared drive has no audit trail and is not an acceptable compliance record.
• Backup and restoration. Backups on a defined schedule, stored off the control network, and tested by actually restoring them. An untested backup is a hope.
• Retention of historian data at the same intervals as the paper records it replaced, at a resolution adequate to demonstrate compliance - a 15-minute turbidity requirement means 15-minute data must survive.
• Time synchronization across PLCs, historians, analyzers, and the SCADA server, so that a sequence of events during an incident can actually be reconstructed.
• Manual entry and validation. Where an operator enters a value into an electronic form, the system should require identification and should flag out-of-range entries rather than accepting them silently.

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6. Data Integrity

This is the section with career consequences.

What falsification looks like in practice

It is rarely a dramatic invention. It is:

• "Drylabbing" - recording a result for a test that was not run;
• Recording a plausible number when the instrument was down;
• Selecting the best of several results and discarding the others without documented cause;
• Re-sampling until a passing result is obtained without recording the failing results;
• Adjusting a time so a holding time appears to have been met;
• Backdating a log entry or a calibration;
• Reporting a process-control result on a compliance report;
• Omitting a violation from a DMR.

Why it is different from other mistakes

1. The DMR certification carries the statement that there are significant penalties for submitting false information, including the possibility of fine and imprisonment. Operators have been criminally prosecuted for falsified DMRs.
2. 18VAC160-30-320 2 makes obtaining, maintaining, renewing, or reinstating a license by false or fraudulent representation a prohibited act, and 18VAC160-30-320 6 covers negligence and misconduct. Under 18VAC160-30-290 the Board may impose probation, a monetary penalty of up to $2,500 per violation under Sect. 54.1-202, suspension, or revocation.
3. 18VAC160-30-340 places the licensee's primary obligation with the public and requires notifying appropriate authorities when a judgment about a substantial threat to public health is overruled.

What to do instead

• If a test was not run, record that it was not run and why. A monitoring violation is a Tier 3 matter that is survivable. A falsified result is not.
• If an instrument is down, say so in the log, take a manual measurement if possible, and report the gap.
• If a result is bad, report it. Self-reported violations are treated fundamentally differently from discovered ones.
• If you are directed to falsify, refuse, document the direction in writing, and escalate. 18VAC160-30-340 A is written for precisely this situation, and it requires notifying appropriate authorities - not just declining.

A useful test for any record: would you be comfortable if this entry were read aloud, in your presence, in a deposition, five years from now? If not, do not write it.