New Search
ultimately be required to meet federal "CMOM" requirements), and to develop data <br /> collection and reporting necessary to provide annual NPDES reports, and to support <br /> future updates to the regional Wet Weather Flow Management Plan. <br /> The scope, timing and costs 'of the Eugene-Springf eld efforts/resources needed to complete <br /> these activities is difficult to assess, and would depend on the amount of coordination and <br /> .assistance needed to enact and implement Coburg programs that are consistent with Eugene's <br /> and Springfield's under the NPDES permit. A rough estimate is provided in.Attachment A. <br /> NPDES Permit Limits, TMDLs. and Waste Load Allocations <br /> The NPDES permit contains numerous pollutant limits and a Temperature Management Plan <br /> (TMP), which was required by the DEQ pending completion of the Total. Maximum Daily Load <br /> (TMDL) process. The Willamette River TMDLs (currently in draft form) address specific water <br /> quality problems, which locally include temperature, mercury, and bacteria. Upon completion of <br /> the TMDL process, and through renewal of our NPDES permit, we will be issued a Waste. Load <br /> Allocation (WLA) for the total amount of thermal load the treatment plant can discharge, and <br /> will eventually be issued limits on mercury as well. <br /> The MWMC Facilities Plan includes projects to implement reuse of treated effluent as a means <br /> of achieving temperature limitations during the summer months. Facilities intended to support <br /> up to ten million gallons per day of reuse are planned, however, it is anticipated that this will fall <br /> short of meeting MWMC's temperature reduction requirement. Further regulation of <br /> temperature should be anticipated, which would necessarily extend to the regulation of <br /> temperature/thermal load of Coburg's discharge. This could be anticipated in the form of <br /> increased Pretreatment Program and/or PMP requirements, as well as the potential for Coburg to <br /> participate directly in a prorated share of additional reuse projects that are not currently included <br /> in the MWMC Facilities Plan. <br /> Similarly, Coburg would need to plan to participate in the regulation and prevention of mercury <br /> discharges to the MWMC system. While the current levels of mercury in the MWMC system <br /> are extremely low, the treatment facilities are not designed to remove mercury from the <br /> wastewater stream. MWMC will necessarily rely on local regulation of mercury through <br /> Industrial Pretreatment Program and pollution management requirements. <br /> Finally, because MWMC has no land use or growth management authorities, further evaluation <br /> would need to be conducted to determine whether total mass, and potentially other effluent limits <br /> would need to be applied to Coburg's discharge. This would be a possible measure to ensure <br /> that growth in Coburg would not result in unanticipated increases in wastewater loadings that <br /> may compete for treatment plant capacity and performance that is planned to serve the Eugene- <br /> <br /> - Springfield urbanizable area. <br /> Insufficient information is available at this time to estimate the scope, timing and costs of <br /> addressing the various regulatory program and permitting issues described above. A placeholder <br /> work task and time line is included in Attachment A to recognize that this work would need to be <br /> undertaken.. <br /> General System Administration, Monitoring and Compliance Requirements <br /> In addition to the specific programs outlined above, the connection of Coburg to the 1VIWMC <br /> system, would. necessitate that certain authorities and specific. regulations be established within <br /> Coburg's municipal code, enabling sewer utility administration in a mariner parallel to Eugene <br /> and Springfield. Coburg would also need to establish programs, including providing the staff <br /> Page 18 ~ <br /> City Council page 454 <br /> r` <br /> <br />