Problem:

A local citizens group had issued a notice of intent to sue for violations of the Clean Water Act, alleging lack of compliance with the NPDES permit. The client did not have a compliance program in place, had occasionally missed samples, and did not have complete records to provide to the citizens group in response to the notice of intent. Finally, the client was required to install a treatment system as a corrective action. 

​

Solution:

Cor understands of the requirements of the NPDES permit. Cor was able to retroactively document the corrective actions that the client had taken over the recent years by reviewing receipts and other records. From this investigation work, it was apparent that the client was diligent in taking corrective actions, but were not as diligent in record-keeping. Cor prepared the supporting documentation in defence of the client to the citizens group.

Further, Cor created a compliance program that the client adopted, which was more aligned with meeting their stormwater goals. The program consisted of a revamp of the stormwater plan, which previously appeared to have been a more general stormwater plan. Cor deleted vague best management practices (BMPs) that were not tailored to their site and revised it to include site-specific protocols that are effective at pollutant mitigation, specific to their site. Cor created the employee training program and continues to deliver it each year. Cor created inspection forms that were site-specific and made them electronic and easily accessible from any smartphone. Cor assisted with identifying necessary actions and delegation of roles and responsibilities. Cor continues as an on-call support to this day.

Cor delivered an efficient storwmater treatment design that was approved by the state agency. The solution consisted of re-using older stormwater infrastructure as structural components to the proposed treatment system, thereby significantly reducing construction costs. 

 

Outcome:

The client is no longer threatened by enforcement actions or lawsuits due to Cor’s proactive, programmatic approach to stormwater compliance. Cor delivered a cost-effective and efficient stormwater treatment solution, satisfying the regulatory requirements, and continuing to remove pollutants to this day.