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• Increased ongoing regional wastewater program staffing and other costs associated with <br /> maintaining MWMC's responsibilities to an additional partner, the costs of which would <br /> be signif cantly disproportionate to the customer base served in Coburg. <br /> Unlike Scenario One, this Scenario could not be accommodated by minor modifications to the <br /> MWMC IGA. It is assumed that significant amounts of time and resources would be spent <br /> negotiating the conditions of the partnership, drafting IGA amendment language supporting the <br /> negotiations, and processing the agreement through all four Governing Bodies. Like Scenario <br /> One, Additional IGAs would be needed depending on the level of ongoing support services <br /> Coburg would seek to contract with Eugene and/or Springfield to provide. <br /> ESTABLISHMENT OF REGULATORY REQUIREMENTS, REPORTING AND <br /> COMPLL~NCE ASSURANCE. <br /> The MWMC-owned regional wastewater facilities and the locally-owned collection systems in <br /> the metropolitan area are operated under a single National Pollutant Discharge Elimination <br /> .System (NPDES) permit, which is issued by the DEQ to the Cities of Eugene and Springfield <br /> and to MWMC. This permit, which enables MWMC to discharge treated wastewater to the <br /> Willamette River, carries numerous requirements the Cities and MWMC must meet to maintain <br /> .compliance with the Federal Clean Water Act and the State's water quality statutes and <br /> administrative rules. <br /> This section addresses the regulatory programs/requirements that are mandatory for Eugene and <br /> Springfield, and would need to be adopted and implemented in Coburg if Coburg were to <br /> become connected to the MWMC system. It also addresses obligations Coburg would.be <br /> expected to meet through ordinances and agreements. The activities and tasks staff has identified <br /> as needed are described below. An estimated time and cost for Eugene-Springfield wastewater <br /> program staff to support wastewater services to Coburg is provided in Attachment A. <br /> .Industrial Pretreatment Program and Pollution Management <br /> The Industrial Pretreatment Program is a federally mandated program that is intended, among <br /> other things, 1) to prevent discharge of pollutants to the sewerage system that may interfere with <br /> - the operation of the system or contaminate the resulting sludge, or pass through the system, <br /> inadequately treated, into receiving waters; 2) to protect the health of employees working in and <br /> around the sewerage system; and 3) to improve the opportunity to recycle and reclaim <br /> wastewater and sludge otherwise entering the sewerage system. In the Eugene-Springfield area, <br /> MWMC is delegated the authority to develop and enact the "model" pretreatment ordinance and <br /> corresponding pollutant limits. MWMC also enacts regulatory Pollution Management Practices <br /> for certain businesses and industries that are not regulated by permit, because they generate <br /> significant pollutants of concern. Eugene and Springfield are obligated to adopt local <br /> ordinances, enact rules, and implement programs that are identical to the MWMC-adopted <br /> models. <br /> If wastewater services are extended to Coburg, the Eugene-Springfield staff would need to plan <br /> .and conduct the following work activities: <br /> • Provide background information and technical assistance to Coburg staff and Council; <br /> • Assist Coburg with development, legal review, .and adoption of ordinances that <br /> implement the MWMC model pretreatment program, local limits; and that provide for <br /> City Council page 452 Page 16 <br /> <br /> _ <br /> <br />