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program implementation and enforcement, including adoption of the Enforcement <br /> Response Guide; <br /> • Assist Coburg with development of a program and implementation plan, or develop the <br /> program for implementation through a service contract with Coburg; <br /> • Conduct a formal review of Eugene-Springfield regulatory "local ,(pollutant) limits" in <br /> .accordance with DEQ and EPA guidelines to determine adequacy, whether they will need <br /> to be adjusted to accommodate Coburg's industrial pollutant load, and how reserve <br /> . capacities will be established and apportioned to enable industrial growth in Eugene, <br /> Springfield and Coburg; and <br /> • Work with Coburg to develop enforcement authority, responsibility, and program <br /> compliance assurance within Coburg's city limits, including the ability to assess and <br /> collect fees and charges, and to implement any and all regulations. and Pollution <br /> Mana ement Practices as ado ted b MWMC. <br /> g <br /> p Y . <br /> The scope, timing and costs of the Eugene-Springfield efforts/resources that would be needed is <br /> difficult to assess, and would depend on the amount of assistance needed by Coburg to enact, <br /> implement, and enforce a program that is identical to Eugene's and Springfield's under the <br /> governance of MWMC. A rough estimate is provided in Attachment A. <br /> Collection System Construction, Maintenance, and Rehabilitation Reauirements <br /> If Coburg were to connect to the MWMC system, collection system design, operation, <br /> maintenance, and long-term rehabilitation would be another set of program parameters where <br /> regulatory conformity with Eugene, Springfield and 1VIWMC, along with ongoing resource <br /> allocation, would be required. MWMC, Eugene, and Springfield (as co-signators to the NPDES <br /> <br /> - permit and co-operators of the overall system) are obliged to meet system performance standards <br /> under peak wet weather flow conditions. These standards, which prohibit sanitary sewer <br /> overflows (SSOs) except under extreme storms or catastrophic events, are met in the Eugene- <br /> Springfield area through several regulatory vehicles. <br /> The NPDES permit incorporates the Wet Weather Flow Management Plan, adopted by MWMC <br /> and the two Cities in 2001, .including policies for system performance and level of treatment, as <br /> well as ongoing system hydraulic modeling, and targets for infiltration and inflow reduction <br /> through system rehabilitation and regulatory enforcement. Although Coburg would connect to <br /> the MWMC system with a newly constructed collection system, it would need to be built to <br /> standards approved by-MWMC, and the City would need to ensure conformance with standards <br /> established in the Eugene-Springfield area for ensuring compliance with the NPDES permit, as <br /> well as State and Federal rules prohibiting SSOs. The Governing Bodies and/or MWMC would <br /> need to address whether sanctions would need to be determined in the event that Coburg failed to <br /> comply; resulting in greater amounts of peak flows that planned. <br /> If wastewater services are extended to Coburg, the Eugene-Springfield staff would need to plan <br /> and conduct the following work activities: <br /> • Review and process for approval, Coburg's collection system design specifications; <br /> • Ensure that Coburg maintains a duly authorized and certified System Operator or that <br /> Eugene-Springfield personnel are contracted and authorized in that capacity; and <br /> • Provide assistance to Coburg to establish ongoing system maintenance, management and <br /> rehabilitation programs, including system monitoring and reporting (this program will <br /> City Council page 453 Page 17 <br /> <br />