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facilit ,industrial discharge limitations would be significantly lower. <br /> Comment 3: Do the increased penalties reflect what programs of other cities <br /> and OTWs of similar size and design to Eugene's are doing? <br /> Findin :This proposed rule change does not deal with the maximum <br /> 9 <br /> amo nt of the administrative penalty that the City of Eugene can assess for a <br /> violat on of the pretreatment program regulations or permit requirements. The <br /> maxi um administrative penalty authority for these violations was raised by the City <br /> Coun it in Ordinance No. 20075, approved by the Council in January 1997. This <br /> rule c ange only deals with proposed changes to the City's Enforcement Response <br /> Guid ,which outlines how the penalties are assessed. <br /> The maximum administrative penalty amounts at other wastewater treatment <br /> agen ies in Oregon vary. The $25,000 maximum penalty in Eugene is not unique; <br /> the nified Sewerage Agency in Washington County, which has wastewater <br /> treat ent facilities of similar size to the Eugene/Springfield regional treatment <br /> facilit ,also has a $25,000 maximum penalty. <br /> Comment 4: Has the City of Springfield, which shares the regional POTW <br /> with ugene, also incorporated increased penalty amounts such as these? <br /> Finding: No, the City of Springfield has not implemented higher penalties. <br /> <br /> ' Sprin field's City Charter does not permit the City to assess any penalties higher <br /> than 500 per day. Springfield is in the process of taking steps to refer a charter <br /> ame ment to the voters to raise the penalty authority. <br /> Comment 5: Has the 100,000 gallons per day qualifier been based on <br /> proje ed impact to the POTW or was this an arbitrary selection to impact specific <br /> Indus ries? This qualifier appears to only effect one industry. <br /> Finding: The penalty multiplier for high-flow industries begins at a flow of <br /> 100, 00 gallons per day. This flow value was chosen as a reasonable cut-off point <br /> betty en the high-flow industries and others. At present there are four industrial <br /> users in Eugene with daily average flows over 100,000 gallons per day, with another <br /> expe ted to begin discharging before the end of this year. The 100,000 gallons per <br /> day lue was not selected to impact any one specific industry. <br /> Comment 6: Is it not possible to assess penalties based on something other <br /> than flow? Have industries paid incurred flow based costs when System <br /> Deve opment Charges are assessed? <br /> Finding: The Industrial Pretreatment Program regulates industrial <br /> disch rgers to the wastewater collection system to protect the regional wastewater <br /> treat ent plant biological processes, to protect water quality in the Willamette River, <br /> Administrati a Order - 3 10/22/97 <br /> <br />