1. Overview by: Patrick Otsuji - SWRCB Michelle Beckwith - RWQCB

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 2

3. 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.

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 4

5. 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 SMARTSSMARTS

6. Open SMARTS and search for the NOI recordSMARTS 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 3 rd 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

8. 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

9. 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 SMARTSSMARTS

10. Open SMARTS and search for the NOI recordSMARTS 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

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 12

13. 13 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) 1 st NNC – AR 2 nd NNC – AR

14. Informal Formal Create Project Example: SEP Create SEP Milestone Liability Monetary Milestones 14 Project or Liability Project or Liability Milestone Enforcement Action

15. 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 SMARTSSMARTS

16. Open SMARTS and search for the NOI recordSMARTS 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. 16

17. 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

18. 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

20. 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 SMARTSSMARTS

21. Open SMARTS and search for the NOI recordSMARTS 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. 21

22. 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

23. 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

24. 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

25. 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

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 26

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28. SMARTS Issues & Enhancement Requests Patrick Otsuji (916) 341-5292 patrick.otsuji@waterboards.ca.gov patrick.otsuji@waterboards.ca.gov SMARTS Data Entry Questions/Process Michelle Beckwith (951) 782-4433 michelle.beckwith@waterboards.ca.gov michelle.beckwith@waterboards.ca.gov