UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
REPLY TO ATTENTION OF
ECW-15J
VIA ELECTRONIC MAIL
Mayor Curtis McCall Sr.
City of Cahokia Heights
103 Main Street
Cahokia, Illinois 62206
ymccall@cahokiaillinois.org
Subject: July 25-28, 2022, MS4 Inspection Report for the City of Cahokia Heights
Dear Mayor McCall:
The U.S. Environmental Protection Agency conducted an NPDES Municipal Separate Storm
Sewer System (MS4) Inspection at the City of Cahokia Heights on July 25-28, 2022. Enclosed,
please find a copy of EPA's MS4 Inspection Report that documents the observations made by
the EPA inspection team during the inspection. Pages 9-11 of the enclosed report summarize the
areas of concern identified during the inspection.
If you have any questions or concerns regarding this letter, or the inspection report, please
contact Dean Maraldo of my staff at (312) 353-2098 or maraldo.dean@epa.gov.
Sincerely,
digitally signed by Bahr,
rt/an
Date: 2022.08.05
08:57:26 -05'00'
Ryan J. Bahr,
Supervisor, Section 2 Water Enforcement and Compliance Assurance Branch
Enclosure
cc: Corey Allen, City of Cahokia Heights [callen@cahokiaillinois.org]
Keith Nolden, City of Cahokia Heights [knolden@cahokiaillinois.org]
Todd Bennett, Illinois EPA [Todd.Bennett@Illinois.gov]
Wayne Caughman, Illinois EPA [Wayne.Caughman@Illinois.gov]
Joe Stitely, Illinois EPA [Joe.Stitely@Illinois.gov]
Bahr,
-------
4% United States
Environmental Protection
^1 #%Agency
REGION 5 Enforcement and Compliance Assurance Division
MS4 Inspection Report
Inspection Date(s):
07/25/2022 - 07/28/2022
Announced: Yes
Time:
Entry: 01:30 PM (CT)
Exit: 09:10 AM (CT)
Media:
Water
Statute(s)/Program(s):
Clean Water Act, NPDES
Type of inspection:
MS4 - Municipal Separate Storm Sewer System Inspection
Access:
Granted
Permittee Name:
City ofCahokia Heights
Facility or Site Name:
Cahokia Heights Public Works Department
Facility/Site Physical Address:
726 S. 50th Street
(City, state, zip code)
Cahokia Heights, IL 62207
County/Parish:
St. Clair
Facility GPS Coordinates:
38.57490, 90.12032
Mailing address:
(If different)
(City, state, zip code)
Facility/Site Identifier:
ILU330001
Permit Number:
Unpermitted Facility
SIC or NAICS:
Persons Participating in Inspection:
Title
Name
Phone
Email
Present at
Opening Conf.
Present at
Closing Conf.
Lead Inspector
Dean Maraldo
3123532098
Maraldo.Dean@e
pa.gov
Yes
Yes
Inspector
Joan Rogers
(312) 886-2785
rogers.joan@epa.
gov
Yes
Yes
Inspector
Ted Flatebo
(312) 886-9402
Flatebo.Ted@epa
gov
Yes
No
City Public Works
Director
Corey Allen
(618) 610-7961
callen@cahokiailli
nois.org
Yes
Yes
City Assistant
Public Works
Director
Keith Nolden
(618)530-7544
knolden@cahokia
illinois.org
Yes
No
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
Storm Water
Coordinator
Wayne Caughman
(618) 346-5125
Wayne.Caughma
n@lllinois.gov
Yes
No
St. Clair County
James Harms
(618) 233-1392-18
James. Harms@co
.st-clair.il.us
Yes
No
City Assistant
Public Works
Director
Tom Hill
Yes
No
Hurst-Rosche, Inc.
Terry Sudholt
(618) 398-0890
tsudholt@hurst-
rosche.com
Yes
No
Gonzalez Companies
LLC
TonySchenk
(618)222-2221-
101
tschenk@gonzale
zcos.com
No
No
Gonzalez Companies
LLC
John Schaller
No
No
Lead Inspector:
Dean Maraldo
[Signature]
niMH Digitally signed by DINO
1N ^ MARALDO
MARALDO
REGION 5
maraldo.dean@epa.gov
(312) 353-2098
Supervisor Review:
Ryan Bahr
[Signature]
Digitally signed by Bahr,
Bahr, RyanRyan
Date: 2022.08.05
08:56:10 -05'00'
REGION 5
bahr.ryan@epa.gov
SECTION I - INTRODUCTION
Site Entry and Inspection Objectives
The City of Cahokia Heights operates a small municipal separate storm sewer system (MS4). In May 2021, the
former communities of Centreville, Alorton, and the Village of Cahokia merged into the City of Cahokia Heights.
The purpose of the inspection was to determine the status of MS4 permit coverage for the newly formed City of
Cahokia Heights, and to review the City's implementation of MS4 permit program requirements.
The Phase II National Pollutant Discharge Elimination System (NPDES) regulations automatically cover, on a
nationwide basis, any MS4 "located in an urbanized area as determined by the latest Decennial Census by the
Bureau of the Census" (unless the MS4 qualifies for a waiver) 40 CFR § 122.32(a)(1). "Urbanized areas," as defined
by the Census Bureau when the Phase II regulations were issued, comprise areas "that together have a minimum
population of 50,000 people." 64 Fed. Reg. 68722, 68751 (December 8, 1999).
The universe of regulated small MS4s in urbanized areas expands every 10 years, according to the 1999
stormwater Phase II final rule. A "small MS4" is any MS4 not already covered under Phase I of the NPDES
stormwater program. The City of Cahokia Heights is within the St. Louis, MO-IL urbanized area (UACE#77770), as
defined by the U.S. Census Bureau, and subject to NPDES stormwater regulation as a small MS4.
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Cahokia Heights MS4
Inspection Date(s): 07/25/2022 - 07/28/2022
I, U.S. EPA inspector Dean Maraldo, arrived at the Cahokia Heights Public Works Department (the "City" or
"Facility"), located at 726 S. 50th Street, at 01:30 PM (CT) on 07/25/2022 for an announced inspection. I
presented my inspector credentials to Corey Allen and informed him that this was a U.S. EPA inspection to
determine compliance with the Clean Water Act (CWA) and the NPDES permit program. I was joined by U.S. EPA
inspectors Joan Rogers and Ted Flatebo. I led the inspection under the authority of the Federal CWA, Section
308. The table above identifies the attendees that participated in the inspection. This report is based on
information supplied by the City of Cahokia Heights Department of Public Works representatives, observations
made by U.S. EPA inspectors, and records and reports maintained by the City and U.S. EPA inspectors, including:
direct observations made by the U.S. EPA inspectors, photographs taken by U.S. EPA inspectors, verbal or
written statements made by or information supplied by City representatives during or subsequent to the on-
site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted
to the U.S. EPA inspectors by the City during or subsequent to the on - site Inspection. In addition, information
gathered prior to or subsequent to the Inspection from a review of U.S. EPA, State, and public records may be
included in this report.
Facility/Site Description
The inspection opening conference was held in the garage of the City of Cahokia Heights Public Works building,
located at 726 S. 50th Street. I began the inspection by reviewing the inspection plan, including review of MS4
permit status and the physical inspection of the Public Works facility at 726 S. 50th Street. Prior to the
inspection, I requested the City provide the most recent notice of intent ("NOI") for coverage under Illinois
EPA's NPDES General Permit for Discharges from Small MS4s ("GP ILR40", see Appendix 3), and any program
plans developed pursuant to the permit. I asked the City representatives if the City applied for coverage under
GP ILR40 since the May 2021 merger. Corey Allen ("Director") said the City has not submitted an NOI for the
MS4 permit. With this information, I asked if the City developed any of the storm water management programs
required under GP ILR40. The Director said they have not. Wayne Caughman added that on July 13, 2021, Illinois
EPA sent a letter notifying the City of its obligation to seek coverage under GP ILR40. He provided the Director
with a copy of the letter (see Appendix 3).
Inspection Units
Unit/Area
Description
General Permit NOI Process
Interview questions
Operations
Review of Illinois General MS4 Permit Minimum Control Measures
Stormwater System Conveyance and Mapping
Pollution Prevention/Good Housekeeping for Municipal Operations
Physical inspection
Stormwater Observations
73rd Street, Cahokia Heights
N 82 and Belleview Ave, Cahokia Heights
N. 82nd Street, Cahokia Heights
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Cahokia Heights MS4
Inspection Date(s): 07/25/2022 - 07/28/2022
Without an MS4 program to evaluate, I suggested we revise the inspection plan to include a review of the
general permit NOI process and go over the requirements of GP ILR40.1 asked if the City still uses the City Public
Works facility on Levin Drive. The Director said the Levin Drive facility is no longer used and all Public Works
operations are now managed from the 726 S.50th Street location. I proposed to conduct the physical inspection
of the Public Works facility at 726 S. 50th Street to assess Pollution Prevention and Good Housekeeping
measures for the City's municipal operations. The City representatives agreed and we concluded the opening
conference and began the interview portion of the inspection.
SECTION II - OBSERVATIONS
Observations may not be in sequential order.
Location: Interview/General Permit NOI Process Contains CBI: No
Observation #: DM1-OB-001 Date: 07/25/2022
I reviewed the requirement to submit an NOI under Illinois EPA's NPDES General Permit for Discharges from
Small MS4s ("GP ILR40"). Wayne Caughman (Illinois EPA) mentioned that St. Clair County has a MS4 Co-
permittee group that includes many communities. He was not sure if the City of Cahokia Heights officially joined
the group. However, James Harms (St. Clair County) later confirmed that the City of Cahokia Heights has officially
joined the St. Clair County MS4 Co-permittee group. Wayne Caughman added that the Co-permittee group has
quarterly meetings and the Director added that City of Cahokia Heights representatives attended the last
meeting. James Harms mentioned that the St. Clair County MS4 Co-permitteegroup has a new consultant
charged with assisting members with implementation of parts of the MS4 program.
Location: Interview/Operations Contains CBI: No
Observation #: DM1-OB-004 Date: 07/25/2022
I started the discussion on operations with a question about ditch maintenance. The Director said the ditches
are maintained on a regular basis, along with culverts. The City obtained a vacuum truck as a result of the
merger with the Village of Cahokia which helps with culvert cleaning. I asked if there were written plans and
schedules regarding ditch and culvert maintenance. The Director said there are no written plans or schedules
and maintenance is based on "trouble areas". I asked about the City's "Fresh Start" program. The Director
described the program which is designed to clear vacant properties of abandoned personal property and waste.
The program relies entirely on City personnel and equipment. The goal is to focus on one area then move to the
next.
I asked about hours of operation and staffing levels. The Director said normal operating hours are between
8:30am-4:30pm, Monday thru Friday. The department currently has 11 total staff including the Director and
Assistant Directors. However, they normally operate with a total of 12 staff. The operations staff are divided by
area and job function, with four staff designated for the former Centreville and Alorton portions of the City, four
staff designated for the former Village of Cahokia portion of the City, and four staff dedicated to demolition
work. The staff work across these operational areas as needed. The department is responsible for maintaining
streets and drainage, plowing, and demolition. The Director reports to the Mayor.
Complaints are few, according to the Director. He added that complaints are often received through City Hall,
and in written form or via phone. Lately, complaints and any related work orders are recorded on paper and
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stored in the Director's office.
U.S. EPA inspector Joan Rogers asked what resources the department might need to improve operations. The
Director mentioned a few items, including more staff (ideally a total of 18 staff), road resurfacing equipment,
and a new street sweeperto replace the old Village of Cahokia sweeper, which is out of operation due to lack of
available parts.
Location: Interview/Review of Illinois General MS4 Contains CBI: No
Permit Minimum Control Measures
Observation #: DM1-OB-002 Date: 07/25/2022
I went overeach of the Illinois EPA General Permitfor Small MS4 Minimum Control Measure requirements. The
Public Works Director's provided the information below.
1) Public Education and Outreach: The City has no MS4 Public Education and Outreach program.
2) Public Involvement/Participation: The City has no MS4 Public Involvement/Participation program. However,
they hope to benefit from St. Clair County Co-permittee group resources in this area.
3) Illicit Discharge and Elimination: The City has no MS4 Illicit Discharge and Elimination program and no past
experience with Illicit Discharge and Elimination. The Director mentioned known illicit discharges on 82nd Street
and Pocket Road.
4) Construction Site Storm Water Runoff Control: The City has no Construction Site Storm Water Runoff Control
program, and the Director was not sure if the City has construction stormwater-related ordinances.
5) Post-Construction Storm Water Management in New Development and Redevelopment: The City has no Post-
Construction Storm Water Management in New Development and Redevelopment program. James Harms (St.
Clair County) mentioned that the Co-permittee group provides some annual MS4 training.
6) Pollution Prevention/Good Housekeeping for Municipal Operations: The City has no formal Pollution
Prevention/Good Housekeeping program for Municipal Operations.
In summary, the City is not implementing any of the Illinois EPA GP ILR40 MS4 Minimum Control Measure
requirements.
Location: Interview/Stormwater System Contains CBI: No
Conveyance and Mapping
Observation #: DM1-OB-003 Date: 07/25/2022
I asked the City representatives about the availability of MS4 system maps. Keith Nolden stated he believed
paper maps of the former Village of Cahokia storm sewer exist. The Director said he was not aware of any maps
of the former Centreville and Alorton storm sewers. James Harms (St. Clair County) mentioned the former Co-
permittee consultant may have some digital maps of storm sewers but wasn't sure. He said he would look into it.
I asked about areas in the City with piped storm sewers and inlets. The Director said that most of the City's
system consists of ditches. I asked about sewer inlets observed in the community north of Canal #1. The
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
Director said that storm water is collected through pipes in the area around Pittsburgh, 63rd Street, Piat Place,
and Laura. This system drains toward 1-255. Keith Nolden added that the former Village of Cahokia has lots of
storm water pipes and inlets. Last, I asked about the former Village of Alorton. The Director said the area around
Alcoa has some storm water pipes and inlets, along with areas around 47th and Market and 41st and Market.
Location: Public Works Facility /Pollution Contains CBI: No
Prevention/Good Housekeeping for Municipal
Operations
Observation #: DM1-OB-005 Date: 07/25/2022
Physical inspection of Pollution Prevention/Good Housekeeping for Municipal Operations.
We began the physical inspection of the City of Cahokia Heights Public Works facility, located at 726 S. 50th
Street, at2:55 pm onJuly25, 2022.1 asked the Director if it was ok to take photographs and if there wereany
confidential business information concerns. The Director granted permission to take photographs with no
concerns.
We observed staining on the gravel ground beneath a public works truck. At the time of the inspection there
was a pan underneath the truck collecting oil dripping from the rear of the vehicle (see Photo Log image
CCHM001).
The group walked over to the salt storage area and I observed a corrugated metal pipe inlet in front of the salt
storage structure (see Photo Log image CCHM004). The salt storage structure was covered, but the front of the
structure was exposed and salt debris was observed within the inlet of the corrugated metal pipe. The pipe led
to a ditch running along the southwest boundary of the facility. I observed the outlet of the metal corrugated
pipe and noticed white staining and debris on the gravel at the outlet and leading into and along the ditch (see
PhotoLog image CCHM002). The ditch continued southeast toward the rear of the facility and 1-255. The white
staining and debris continued along the ditch (see Photo Log image CCHM003).
We walked toward the rear of the public works yard and noticed some large debris and waste piles (See Photo
Log images CCHM005). U.S. EPA inspector Joan Rogers asked about the Public Works department's waste and
debris collection practices. The Director said the crews pick up trash all day and deliver all waste here to the
Public Works yard. They haul waste daily to a nearby landfill. The Director said they separate tires and twice a
year send tires to the County as part of a state tire recycling program. Inspector Rogers noted that they may want
to consider shredding or covering tires while temporarily stored on site to minimize potential insect breeding.
Walking along the southwest boundary of the facility, I observed the ditch running along the boundary. I took a
photograph of the ditch (see Photo Log image CCHM006) looking southeast and downgradient from the point we
observed the corrugated metal pipe from the salt storage structure.
The group then headed across the yard toward the northeast and observed another large debris pile and two
uncovered dumpsters filled with debris (see Photo Log images CCHM007 and CCHM 008).
As we walked back toward the facility garage I observed three above-ground tanks (two diesel and one gas
tank) in the center of the lot (see Photo Log image CCHM009). The Director said the tanks are abandoned and
no longer used. He said the diesel tanks are empty and they are waiting for a pump to drain whatever is
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
remaining in the gas tank.
The last area observed was the new fuel storage area. The area is covered and contains two new above-ground
fuel tanks (see Photo Log image CCHM010). The Director said the tanks were installed within the last three
months. The new above-ground fuel tanks did not have secondary containment, but the Director believed they
were double-walled tanks.
I also observed two damaged, uncapped, and nearly filled drums in the new fuel storage area (see Photo Log
image CCHM Oil). I asked the Director if he knew what was in the drums. Public Works Assistant DirectorTom
Hill dipped the drums and noted that the liquid appeared to be waste oil.
We concluded the physical inspection of the City of Cahokia Heights Public Works facility, located at 726 S. 50th
Street, at 3:25 pm on July 25, 2022. We agreed to meet and close out the MS4 inspection the next day (July 26)
in the afternoon, as the U.S. EPA inspection team had a meeting in the morning regarding another matter
outside of Cahokia Heights.
During the early hours of July 26, 2022, a severe rain event occurred in the St. Louis area, including Cahokia
Heights. Over 6 inches of rain fell over Cahokia Heights over a 12 hour period from 1:00 am to noon on July 26
(based on National Weather Service data for the St. Louis Downtown Airport, located in Cahokia Heights). As a
result of the storm, which caused widespread flooding throughout the region, the City's Public Works staff were
deployed to respond to emergencies throughout the City on July 26 and July 27. We postponed the inspection
close out conference (conducted via telephone) to the morning of July 28, 2022.
Photo(s)
1. CCHM001.JPG
2. CCHM002.JPG
3. CCHM003.JPG
4. CCHM004.JPG
5. CCHM005.JPG
6. CCHM006.JPG
7. CCHM007.JPG
8. CCHM008.JPG
9. CCHM009.JPG
10. CCHM010.JPG
11. CCHM011.JPG
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
Location: Stormwater Observations/73rd Street, Contains CBI: No
Cahokia Heights
Observation #: DM1-OB-007 Date: 07/26/2022
On July 26, 2022,1 observed a surcharging sanitary sewer manhole (see Photo Log image CHWW0030) on 73rd
Street in Cahokia Heights. The roadside ditches along the street were completely inundated with floodwater,
along with sanitary sewage discharging from the manhole. I also captured video of the surcharging manhole and
inundated ditches on 73rd Street.
Photo(s)
1. CHWW0030.JPG
Location: Stormwater Observations/N 82 and Contains CBI: No
Belleview Ave, Cahokia Heights
Observation #: DM1-OB-008 Date: 07/26/2022
On July 26, 2022,1 observed inundated roadside ditches and a partially submerged lift station structure on
Belleview Ave (see Photo Log CHWW0038).
Photo(s)
1. CHWW0038.JPG
Location: Stormwater Observations/N. 82nd Street, Contains CBI: No
Cahokia Heights
Observation #: DM1-OB-006 Date: 07/26/2022
On July 26, 2022,1 observed a sanitary sewer overflow (SSO) from sewer cleanout along N. 82nd Street. The SSO
discharges into a roadside ditch (see Photo Log image CCWW0055) that discharged to a ditch that flowed
through the backyards of a several homes and then through twin culverts under N. 80th Street and into Canal #1
(see Photo Log image CHWW0047). I also captured video of both the SSO discharge and the ditch discharge to
Canal #1.
Photo(s)
1. CHWW0055.JPG
2. CHWW0047.JPG
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
Location: Interview/Call with St. Clair County Co- Contains CBI: No
Permittee Consultant
Observation #: DM1-OB-009 Date: 07/27/2022
On July 27, 2022,1 arranged for a close out conference call for 1pm with the City, Illinois EPA, St. Clair County
representatives, and representatives of Gonzalez Companies, LLC (St. Clair County Co-permittee group
consultant). However, the City Public Works representatives were still occupied with flood emergencies and
could not attend. During the call, Gonzalez Companies LLC representative Tony Schenk clarified his company's
role in supporting St. Clair County's Co-permittee MS4 permit implementation efforts. In general, Gonzalez
Companies LLC provides the member communities with technical support and assistance in implementing the
various MS4 program responsibilities. However, the cities are responsible for implementing most program
requirements. The company helps to prepare the annual reports required under the MS4 permit and can also
conduct sampling tasks. Tony Schenk believed they could prepare an MS4 general permit NOI for the City of
Cahokia Heights within 30 days, assuming the City is willing to coordinate efforts in a timely fashion. We
concluded the call and then I contacted Keith Nolden (City Assistant Director of Public Works) to reschedule the
MS4 inspection close out conference for 9am the next morning (Thursday, July 28, 2022).
SECTION III - AREAS OF CONCERN
Areas of Concern may not be in sequential order. The presentation of areas of concern does not constitute a
formal compliance determination or violation.
Location: Opening Conference
Area: Permitting
DM1-OC-FD
The Director said the City has not submitted an NOI for Illinois
MS4 General Permit ILR40. The City has not developed any of
the storm water management programs required under GP
ILR40.
Citations: Illinois EPA GP ILR40; 40 CFR §
122.32(a)(1)
Location: Interview
Area: Review of Illinois General MS4Permit
Minimum Control Measures
DM1-OB-002
The City is not implementing any of the Illinois EPAGP
ILR40 MS4 Minimum Control Measure requirements.
Citations: Illinois EPA GP ILR40; 40 CFR §
122.32(a)(1); 40 CFR § 122.33
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
Location: Public Works Facility, 726 S. 50th Street, Cahokia Heights
Area: Pollution Prevention/Good
Housekeeping for Municipal Operations
DM1-OB-005
I observed two damaged, uncapped, and nearly filled drums in the
new fuel storage area (see Photo Log image CCHM011). Public
Works Assistant DirectorTom Hill dipped the drums and noted that
the liquid appeared to be waste oil.
Citations: Illinois EPA GP ILR40; 40 CFR §
122.33
I observed two uncovered dumpsters filled with debris in
northeast portion of the yard (see Photo Log images CCHM007
and CCHM008).
Inspector Rogers noted that they may want to consider
shredding or covering tires while temporarily stored onsite to
minimize potential insect breeding.
I observed a corrugated metal pipe inlet in front of the salt storage
structure (see Photo Log image CCHM004). The salt storage
structure was covered, but the front of the structure was exposed
and salt debris was observed with the inlet of the corrugated metal
pipe. The pipe led to a ditch running along the southwest boundary
of the facility. I observed the outlet of the metal corrugated pipe
and noticed white staining and debris on the gravel at the outlet
and leading into and along the ditch (see Photo Log image
CCHM002).
The ditch continued southeast toward the rear of the facility and
I-255. The white staining and debris continued along the ditch (see
Photo Log image CCHM003).
We observed staining on the gravel ground beneath a parked public
works truck. At the time of the inspection there was a pan
underneath the truck collecting oil dripping from the rear of the
vehicle (see Photo Log image CCHM001).
10 of 39
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
Location: Stormwater Observations
Area: N. 82nd Street, Cahokia Heights
DM1-OB-006
On July 26, 2022,1 observed a sanitary sewer overflow (SSO) from
sewer cleanout along N. 82nd Street. The SSO discharges into a
roadside ditch (see Photo Log image CCWW0055) that discharged
to a ditch that flowed through the backyards of a several homes
and then into Canal #1 (see Photo Log image CHWW0047).
Citations: Section 301(a) of the Clean Water
Act, 33 U.S.C. Section 1311(a)
Location: Stormwater Observations
Area: 73rd Street, Cahokia Heights
DM1-OB-007
On July 26, 2022,1 observed a surcharging sanitary sewer manhole
(see Photo Log image CHWW0030) on 73rd Street in Cahokia
Heights. The roadside ditches along the street were completely
inundated with floodwater, along with sanitary sewage discharging
from the manhole.
Citations: Section 301(a) of the Clean Water
Act, 33 U.S.C. Section 1311(a)
Location: Stormwater Observations
Area: N 82 and Belleview Ave, Cahokia
Heights
DM1-OB-008
On July 26, 2022, 1 observed inundated roadside ditches and a
partially submerged lift station structure on Belleview Ave (see
Photo Log CHWW0038).
Citations: Section 301(a) of the Clean Water
Act, 33 U.S.C. Section 1311(a)
SECTION IV - CLOSING CONFERENCE
Closing Conference
The MS4 inspection closing conference was held via telephone on July 28, 2022, at 9am CT. The Director
represented the City. I reviewed the preliminary areas of concern, including the need for MS4 permit coverage
and the lack of a City municipal stormwater program. I recapped the discussion with Gonzalez Companies LLC,
including the possibility of submitting an NOI for the City for the IEPA general permit for small MS4 within 30
days. I also summarized the consultant's ability to support the members of the co-permittee group, and
emphasized that the City will be responsible for meeting the MS4 permit requirements. The Director had no
questions, so I provided an estimated timeframe for preparing an inspection report, and concluded the close out
conference.
Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. No
follow up items were requested by the inspector at the time of the inspection.
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
Communication Log
No additional information received by EPA after concluding the inspection on 07/28/2022.
SECTION VII - LIST OF APPENDICES
1. Photo Log
2. Document Log
3. Reference Documents
APPENDIX 1: PHOTOLOG
Staining on gravel parking lot beneath Public
Works truck.
CCHM001.JPG
07/25/2022 02:56 PM(CT)
Dean Maraldo
Public Works Facility/Pollution Prevention/Good
Housekeeping for Municipal Operations
NoCBI
NoPil
Outlet of corrugated metal pipe draining salt
storage area.
CCHM002.JPG
07/25/2022 02:58 PM (CT)
Dean Maraldo
Public Works Facility /Pollution Prevention/Good
Housekeeping for Municipal Operations
NoCBI
NoPII
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
Ditch along southwest boundary of the facility.
CCHM003.JPG
07/25/2022 02:58 PM (CT)
Dean Maraldo
Public Works Facility/Pollution Prevention/Good
Housekeeping for Municipal Operations
NoCBI
No PI!
Note white staining and debris along ditch.
Front of salt storage structure and inlet of
corrugated pipe.
CCHM004.JPG
07/25/2022 02:59 PM (CT)
Dean Maraldo
Public Works Facility/Pollution Prevention/Good
Housekeeping for Municipal Operations
NoCBI
NoPil
Note salt observed within the corrugated metal
pipe which drains to the ditch along the
southwest boundary of the facility.
Debris pile in rear of facility.
CCHM005.JPG
07/25/2022 03:03 PM (CT)
Dean Maraldo
Public Works Facility/Pollution Prevention/Good
ousekeeping for Municipal Operations
NoCBI
NoPII
13 of 39
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
Ditch running along the southeast boundary.
CCHM0G6.JPG
07/25/2022 03:06 PM (CT)
Dean Maraldo
Public Works Facility/Pollution Prevention/Good
Housekeeping for Municipal Operations
NoCBI
No PI I
View looking southeast toward rear of property
and 1-255, and downstream from the point we
observed the corrugated metal pipe from the salt
storage structure.
Debris pile and uncovered dumpster.
CCHM007.JPG
07/25/2022 03:08 PM (CT)
Dean Maraldo
Public Works Facility /Pollution Prevention/Good
Housekeeping for Municipal Operations
NoCBI
NoPII
Uncovered dumpster.
CCHM008.JPG
07/25/2022 03:13 PM (CT)
Dean Maraldo
Public Works Facility/Pollution Prevention/Good
Housekeeping for Municipal Operations
NoCBI
NoPII
14 of 39
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
Abandoned diesel and gas tanks.
CCHM009.JPG
07/25/2022 03:14 PM (CT)
Dean Maraldo
Public Works Facility/Pollution Prevention/Good
Housekeeping for Municipal Operations
NoCBI
NoPII
New Fuel Tank Storage Area.
CCHM010.JPG
07/25/2022 03:14 PM (CT)
Dean Maraldo
Public Works Facility/Pollution Prevention/Good
Housekeeping for Municipal Operations
NoCBI
NoPII
The area is covered and contains two new above-
ground fuel tanks.
New Fuel Storage Area - waste oil drums
CCHM011.JPG
07/25/2022 03:16 PM(CT)
Dean Maraldo
Public Works Facility/Pollution Prevention/Good
Housekeeping for Municipal Operations
NoCBI
NoPII
I observed two uncapped, filled, and damaged
waste oil drums.
15 of 39
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Cahokia Heights MS4
Inspection Date(s): 07/25/2022 - 07/28/2022
Surcharging sanitary sewer manhole on 73rd
Street in Cahokia Heights.
CHWW0030.JPG
07/26/2022 07:48 AM (CT)
Joan Rogers
StormwaterObservations/73rd Street, Cahokia
Heights
NoCBi
NoPil
The roadside ditches along the street were
completely inundated with floodwater, along
with sanitary sewage discharging from the
manhole.
N82nd and Belleview Ave.
CHWW0038.JPG
07/26/2022 08:11 AM (CT)
Dean Maraldo
StormwaterObservations/N 82 and Belleview
Ave, Cahokia Heights
NoCBI
NoPII
Inundated roadside ditches and a partially
submerged lift station structure on Belleview Ave.
16 of 39
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Cahokia Heights MS4
Inspection Date(s):
07/25/2022 - 07/28/2022
Stormwater discharge to Canal #1
CHWW0047.JPG
07/26/202211:23 AM (CT)
Dean Maraldo
Stormwater Observations/N. 82nd Street,
Cahokia Heights
NoCBI
NoPII
Photo of stormwater discharge to Canal #1.
Stormwater discharges through a pair of culverts
under N. 80th Street. The stormwater collects
from roadside ditches throughout the area, and
includes discharge from a sanitary sewer overflow
location on N. 82nd Street.
Sanitary sewer overflow (SSO) from sewer
cleanout along N. 82nd Street
CHWW0055.JPG
07/26/2022 02:20 PM (CT)
Dean Maraldo
Stormwater Observations/N. 82nd Street,
Cahokia Heights
NoCBI
NoPII
The SSO discharges into a roadside ditch that
discharged to a ditch that flows through the back
yards of a several homes and then into Canal #1
(see Photo Log image CHWW0047).
x. 6 (Personal Privs cy)
APPENDIX 2: DOCUMENT LOG (Documents included in Appendix 3)
Document Type
Document Name
Contains
CB!
Contains
PI]
Pages
Date Received
MS4 Permit ILR40
general-ms4-permit.pdf
No
No
07/25/2022
Communications
ILU330001_IEPA_MS4Letter_2021071
3.pdf
No
No
1
07/27/2022
17 of 39
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