Item A: City of Coburg Request for Connection to Regional Wastewater Facilities

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