Article III. Procedures for Responding to Noncompliance
14.05.060 Documenting noncompliance.
(a) An enforcement action summary (EAS) is used to maintain the chronology of industry responses to violations as well as to document the WSSC’s rationale for the enforcement action taken in response to a specific violation.
Each EAS contains the following information:
(1) Industry name;
(2) Status of the enforcement action;
(3) Violations being cited and dates;
(4) Anticipated defenses by the industry (if known or suspected);
(5) Referenced documents including letters or plans; and
(6) Additional notes or comments including the proposed enforcement action should another violation occur.
(b) The proposed enforcement action is circulated to the Industrial Investigations Supervisor(s), and to the Unit Coordinator for review before issuance. A copy of the enforcement action and EAS is kept in a chronological file specific to each industry.
(c) All violations are documented on an NOV, which informs the IU that a violation has occurred. Each NOV specifies the date the violation occurred, a description and location of the violation, and instructions for follow-up measures. The original NOV is sent via certified mail to the IU. A yellow copy is made of the NOV for the IU’s file, and a pink copy is given to the Industrial Investigations Supervisor to be placed in the Enforcement Log book.
(d) Generally, an NOV will direct the violator to submit a written explanation within seven working days from the date of the NOV. In certain circumstances where an explanation has already been received, a plan of corrective measures may be requested from the IU. If the plan is accepted, a written directive containing established compliance dates is then issued. If the plan is not accepted, a written directive requesting additional information is issued. (Industrial discharge control program enforcement response plan § II(A), dated April 22, 2013)