overview by: patrick otsuji - swrcb michelle beckwith - rwqcb

Overview by:Patrick Otsuji - SWRCB

Michelle Beckwith - RWQCB

Overview for Compliance Entry into the

Storm Water Multiple Application & Report Tracking System

2

• SMARTS vs CIWQS data entry• How to enter an inspection record?• How to enter a violation record?• How to enter an enforcement action?• Entering a informal enforcement action?• Entering a formal enforcement action?• Questions

Today’s Training

• Inspections, Violations, and Enforcement Actions are entered through the NOI record.

• Links to the Owner/Operator, Site information, Regional Water Board, and WDID are automatically created in background.

• No Wizards in SMARTS• Basic business rules should be similar• SMARTS has pre-defined compliance reports or

downloadable text files. • MS4 Phase I tracking currently in CIWQS.

General Permits in SMARTS.

SMARTS vs CIWQS

4

• Record of a site visit• Photos, Inspection Report, Field Data, etc…

• Evaluate compliance • General Permit requirements

• To enter into SMARTS• Must have a SMARTS Account• Must have Regional Board Storm Water Staff

user rights

Inspections In SMARTS

• Scenario 1: Site inspection performed by RB Staff on 2/1/2013• Enter completed inspection • Upload/attach photo documentation and/or

inspection report

• Go to SMARTS

Inspection Demo

• Open SMARTS and search for the NOI record• Perform Administrative Tasks Maintain NOI/NOT data

Search for NOI record• Click on the Inspections Tab• Add New Inspection• Mandatory Fields

• Inspection Type, Inspection Date, Follow Up Action, Inspector Type, Inspector Name.

• Agency Name and Agency Inspector Name are only mandatory if 3rd party is selected

• Optional Fields• Inspection Contact, General Notes• Attachments: Inspection Report or Notes

Violation Details• Can start a new violation once the initial inspection record is saved

• Print Inspection Details

Enter the Inspection

Questions on Inspection Entry?

• Instance of non-compliance• Inspections, paperwork.

• To enter into SMARTS• Must have a SMARTS Account• Must have Regional Board Storm Water Staff

rights

• Each Violation Entered Separately

8

Violations In SMARTS

• Scenario 1: Inspection performed by RWQCB Staff on 2/1/2013. BMP violations were noted from inspection• Enter a violation and link to the inspection record

• Scenario 2: Late Annual Report • Results from Outstanding Annual Report • Enter a violation and manually select Report to

link.

• Go to SMARTS

Violation Demo

• Open SMARTS and search for the NOI record• Perform Administrative Tasks Maintain NOI/NOT data

Search for NOI record• Click on the Violations Tab (or from Inspection Record)• Add New Violation• Mandatory Fields

• Violation Source, Violation Type, Serious Violation, Exempt from MMP, Occurrence Date, Source ID, Determined By, Violation Priority, and Status

• Optional Fields• Discovery Date, Memo Field, and Violation Description

• Enforcement Actions• Can start a new Enforcement action once the initial violation

record is saved

Enter the Violation

Questions on Violation Entry?

12

• An action taken by the Water Boards in response to one or more violations

To enter into SMARTS• Must have a SMARTS Account• Must have Regional Board Storm Water Staff

rights

• Must be linked to a Violation Record

Enforcement Actions

13

Formal vs Informal per Enforcement PolicyInformal• Oral Communication• Staff Enforcement

Letter (SEL)• Notice of Violation

(NOV)Expedited Payment

Letter (EPL)

Formal• Notice to Comply (NTC)• Notice of Non-

Compliance (NNC)• Technical Reports and

Investigations (13267 Letter)

• Cleanup and Abatement Order (CAO)

• Cease and Desist Order (CDO)

• Administrative Civil Liability (ACL)

• 1st NNC – AR• 2nd NNC – AR

14

• Informal• Formal

• Create Project• Example: SEP

• Create SEP Milestone

• Liability• Monetary Milestones

Enforcement Actions

Project orLiability

Project orLiability

MilestoneMilestoneMilestone Milestone

Enforcement Action

• Scenario: Based on the Inspection performed by RB Staff on 2/1/2013 that resulted in BMP violations being observed. Staff Enforcement Letter sent to discharger to correct violations. • Create an Informal Enforcement Action• Upload attachments• Link Violations• Modify Record

• Go to SMARTS

Enforcement Action Demo - Informal

16

• Open SMARTS and search for the NOI record• Perform Administrative Tasks Maintain NOI/NOT data

Search for NOI record• Click on the Enforcement Action Tab (or from Violation record).• Add New Enforcement Action• Mandatory Fields

• Enforcement Action Type, Status, Description, Issuance Date, Due Date, Attachments

• Optional Fields• Corrective Action/Response • Due Date – only if status is Draft

• NOTE: Order/Resolution Number, Economic Benefit, and Staff Costs are for Formal Enforcement Actions.

Enforcement Action Entry - Informal

• Compliance Date• Received Date

• If multiple items are being request• All other dates in the drop down are used for

Formal Actions• ACL Complaint Issuance• Adoption/Issuance Date• Expiration Date/Review Date• Hearing Waived/ACL Settled

Enforcement Action Entry – InformalEnforcement Dates

• Click on link to Violation Details• From drop down select Violation Record and

click Link Violations• Repeat to link additional violations• Staff can delink violations

Enforcement Action Entry – InformalLink Multiple Violations

Questions onInformal Enforcement Action entry?

• Scenario: Enforcement action based on the Outstanding Annual Report and discharger is subject to monetary penalties• Create ACL for late Annual Report• Link Violations• Enter Project\Liability• Create Milestones• Upload/Attach Order• Modify Record

• Go to SMARTS

Enforcement Action Demo - Formal

21

• Open SMARTS and search for the NOI record• Perform Administrative Tasks Maintain NOI/NOT data

Search for NOI record• Click on the Enforcement Action Tab (or from Violation record)• Add New Enforcement Action• Mandatory Fields

• Enforcement Action Type, Status, Description, Issuance Date, Due Date, Order/Resolution Number, and Attachments

• Economic Benefit, Staff Costs if applicable• Optional Fields

• Corrective Action/Response• Due Date – if status is Draft

• Once the initial enforcement action is saved, you can then start the Project/Liability record.

Enforcement Action Entry - Formal

• Click on link to Enforcement Dates• Select the Date Type from the drop down

• Received Date• Compliance Date• ACL Complaint Issuance• Adoption/Issuance Date• Expiration Date/Review Date• Hearing Waived/ACL Settled

• Enter the Date Value and save

Enforcement Action Entry – FormalEnforcement Dates

• Click on link to Violation Details• From drop down select Violation Record and

click Link Violations• Repeat to link additional violations• Staff can delink violations

Enforcement Action Entry – FormalLink Multiple Violations

• Click on link to Projects/Liabilities• Click Create New Project/Liability• Mandatory Fields: Name, Description, Type,

Sub Type (Project Only), Addresses MMP. • Milestone Dependent Fields (Calculated

Fields)• Date Planned, Date Actual, Status

• Note: Assessed Amount will display once the milestone(s) are entered

Enforcement Action Entry – FormalCreate New Project/Liability record

• Click on the link to Milestones• Click Add New Milestone• Mandatory Fields: Description, Type, Water Code,

Date Planned, Assessed Amount, Status• Accounting Fields: Date Actual, Spent Amount

(project), Balance Amount (liability), Received Amount

• Note: Always enter and keep the initial amount assessed• Change status to superceeded • Enter ACLO as additional milestone(s) i.e. payment plan

Enforcement Action Entry – FormalCreate a Milestone record

26

• If the EPL is accepted, the same record is changed to an ACL when the EO signs the order, add Hearing Waived/ACL Settled Date and change the type to ACL

• EPLs address MMPs in the MMP Report run by OE

• EPLs do not appear on the ACL Report• EPLs not converted to an ACL after 9 months

is considered null (or never final, or never settled, or never accepted..) regardless of the status code of the action

Expedited Payment Letter

Questions onFormal Enforcement Actions

Entry?

27

• SMARTS Issues & Enhancement RequestsPatrick Otsuji(916) 341-5292patrick.otsuji@waterboards.ca.gov

• SMARTS Data Entry Questions/ProcessMichelle Beckwith(951) 782-4433michelle.beckwith@waterboards.ca.gov

Contacts