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Overview for Compliance Entry into the Storm Water Multiple Application & Report Tracking System. Overview by: Patrick Otsuji - SWRCB Michelle Beckwith - RWQCB. Today’s Training. SMARTS vs CIWQS data entry How to enter an inspection record? How to enter a violation record?
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Overview for Compliance Entry into theStorm Water Multiple Application & Report Tracking System Overview by: Patrick Otsuji - SWRCB Michelle Beckwith - RWQCB
Today’s Training • 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
SMARTS vs CIWQS • 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.
Inspections In SMARTS • 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
Inspection Demo • 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
Enter the Inspection • 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
Violations In SMARTS • 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
Violation Demo • 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
Enter the Violation • 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
Enforcement Actions • 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
Formal vs Informal per Enforcement Policy Informal • 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
Project or Liability Project or Liability Milestone Milestone Milestone Milestone Enforcement Actions • Informal • Formal • Create Project • Example: SEP • Create SEP Milestone • Liability • Monetary Milestones Enforcement Action
Enforcement Action Demo - Informal • 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 Entry - Informal • 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 – InformalEnforcement Dates • 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 – InformalLink Multiple Violations • 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 Demo - Formal • 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 Entry - Formal • 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 – FormalEnforcement Dates • 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 – FormalLink Multiple Violations • 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 – FormalCreate New Project/Liability record • 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 a Milestone 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
Expedited Payment Letter • 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
Contacts • 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