Overview by:Patrick Otsuji - SWRCB

Michelle Beckwith - RWQCB

Overview for Compliance Entry into the

Storm Water Multiple Application & Report Tracking System

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• 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

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• 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

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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?

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• 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

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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

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• 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

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• 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

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• 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

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• 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?

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• 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