COLLECTION SYSTEMS REGULATORY UPDATE USEPA – SWRCB August 2010.
Overview by: Patrick Otsuji - SWRCB Michelle Beckwith - RWQCB.
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Transcript of 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
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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) [email protected]
• SMARTS Data Entry Questions/ProcessMichelle Beckwith(951) [email protected]
Contacts