Problem:

A local industrial company was issued an enforcement action by the state regulatory agency. This company values a high degree of environmental compliance and sought to correct their compliance program so as to avoid the fines and repercussions of enforcement actions in the future.

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Solution:

Cor was hired after an enforcement action was issued to the client for an NPDES permit violation. Cor’s task was to create a compliance program to ensure that enforcement actions do not occur again. Cor’s program consists of a detailed compliance calendar, including calls to actions, due dates, and delegated responsibilities. The compliance program consists of monthly audits, data evaluation, regulatory reporting, records checks, communications with staff on the ground, communications with regulators, and corrective action recommendations.  In addition, because Cor was overseeing many of this client’s sites, Cor created electronic inspection forms that could easily be accessed by staff from their smartphone for each site. The forms are uploaded and are stored on a secure cloud server. In this way many sites may be managed easily and remotely. Cor ensures all documents are accounted for, accurate, complete, and corrective actions addressed. Cor communicates with staff to address elements that require correction.

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Cor gains an understanding of each site’s operations and functions to recommend the most prescriptive best management practices (BMPs) that positively impact stormwater quality. Under Cor’s program management, no site had triggered any treatment-level corrective action for four years and counting. It is Cor’s belief that a proactive approach mitigates pollutant levels, thereby reducing the need for costly treatment actions.

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Outcome:

Cor’s proactive stormwater compliance program eliminated the need for costly end-of-pipe treatment for this client’s several sites.