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    Cahokia Heights EPA Complaint

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    Kavahn Mansouri
    The EPA has identified potential Clean Water Act violations from sanitary sewer overflows in the Commonfields of Cahokia Public Water District. EPA inspectors observed overflows and operations and maintenance deficiencies. Overflows have been documented on at least 25 occasions since January 2021. The EPA is offering Commonfields an opportunity to meet and provide information for the EPA to consider regarding overflows and staffing during an upcoming merger period. If violations are found, the EPA will consider enforcement actions under the Clean Water Act.

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    Cahokia Heights EPA Complaint

    Uploaded by

    Kavahn Mansouri
    2K views2 pages
    The EPA has identified potential Clean Water Act violations from sanitary sewer overflows in the Commonfields of Cahokia Public Water District. EPA inspectors observed overflows and operations and maintenance deficiencies. Overflows have been documented on at least 25 occasions since January 2021. The EPA is offering Commonfields an opportunity to meet and provide information for the EPA to consider regarding overflows and staffing during an upcoming merger period. If violations are found, the EPA will consider enforcement actions under the Clean Water Act.

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    Cahokia Heights EPA Complaint

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    The EPA has identified potential Clean Water Act violations from sanitary sewer overflows in the Commonfields of Cahokia Public Water District. EPA inspectors observed overflows and operations and maintenance deficiencies. Overflows have been documented on at least 25 occasions since January 2021. The EPA is offering Commonfields an opportunity to meet and provide information for the EPA to consider regarding overflows and staffing during an upcoming merger period. If violations are found, the EPA will consider enforcement actions under the Clean Water Act.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    2K views2 pages

    Cahokia Heights EPA Complaint

    Uploaded by

    Kavahn Mansouri
    The EPA has identified potential Clean Water Act violations from sanitary sewer overflows in the Commonfields of Cahokia Public Water District. EPA inspectors observed overflows and operations and maintenance deficiencies. Overflows have been documented on at least 25 occasions since January 2021. The EPA is offering Commonfields an opportunity to meet and provide information for the EPA to consider regarding overflows and staffing during an upcoming merger period. If violations are found, the EPA will consider enforcement actions under the Clean Water Act.

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    of 2

    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

    REGION 5
    77 WEST JACKSON BOULEVARD
    CHICAGO, IL 60604-3590

    REPLY TO ATTENTION OF
    ECW-15J

    VIA ELECTRONIC MAIL

    Curtis McCall Sr., Chairman


    Commonfields of Cahokia Public Water District
    2525 Mousette Lane
    Cahokia, Illinois 62206

    [email protected]

    Subject: Notice of Opportunity to Confer Regarding Potential Violations of the Clean Water
    Act

    Dear Chairman McCall:

    This letter is an offer to confer regarding potential Clean Water Act (CWA) violations that the
    U.S. Environmental Protection Agency has identified as a result of its ongoing investigation of
    sanitary sewer overflows (“SSOs”) in the Commonfields of Cahokia Public Water District
    (“Commonfields”), located in Centreville, Illinois. EPA inspectors observed SSOs and serious
    operations and maintenance deficiencies during inspections of the sanitary sewer systems in
    Commonfields. EPA previously provided Inspection Reports documenting these issues and
    observed SSOs to Commonfields. SSOs have been documented on at least 25 occasions since
    January 26, 2021, based on EPA field observations and SSO reports submitted to EPA by
    Commonfields. EPA’s Inspection Reports are also available on EPA’s East Saint Louis Area
    SSO website at https://www.epa.gov/il/communities-east-st-louis-area-and-sanitary-sewer-
    overflows. SSOs that reach waters of the U.S. are point source discharges and prohibited under
    the CWA.

    A systematic operation, maintenance, and rehabilitation program is an essential element in the


    management of a sanitary sewer collection system. Implementing such a program requires a
    sufficient number of properly trained operation and maintenance staff members. EPA is
    concerned about the potential impact that the merger between Commonfields, Alorton, Cahokia
    and Centreville into Cahokia Heights and the subsequent transition period may have on sewer
    utility staffing, given the number of manually operated sewer lift stations in Commonfields and
    the lack of automated sewer system controls and overflow alarms. Failure to maintain sufficient
    sewer utility staffing may result in additional SSOs that can contaminate waters, causing serious
    water quality problems, and back-up into yards and homes, causing property damage and
    threatening public health. Because SSOs contain raw sewage, the overflows can carry bacteria,
    viruses, protozoa (parasitic organisms), helminths (intestinal worms), inhaled molds and fungi.
    As a result, SSOs may cause diseases ranging in severity from mild gastroenteritis (causing
    stomach cramps and diarrhea) to life-threatening ailments such as cholera, dysentery, infections
    hepatitis, and severe gastroenteritis.

    Opportunity to Confer

    As the Chairman of the Commonfields Board of Trustees and Mayor-Elect of the City of
    Cahokia Heights (“City”), EPA is extending to you an opportunity to advise the Agency of any
    additional information EPA should consider regarding SSOs and sewer utility staffing during the
    merger and following transition period. If you agree to a meeting, please plan for technical and
    management personnel from Commonfields and the City to attend the meeting. You may have an
    attorney represent you at this meeting. The EPA contact in this matter is Dean Maraldo. You or
    your staff may call him at (312) 353-2098 or email him at [email protected] to make
    arrangements for the meeting. Given the urgency, we propose meeting virtually during the week
    of May 3, 2021, or at your earliest convenience.

    Next Steps

    If the Agency ultimately determines that Commonfields and/or the City is not in compliance with
    applicable requirements, then EPA will consider enforcement options available under Section
    309 of the CWA, which may include the issuance of an administrative compliance order,
    issuance of an administrative penalty order, and pursuing a judicial civil or criminal action.

    We look forward to receiving your response.

    Sincerely,
    Digitally signed by
    MICHAEL MICHAEL HARRIS
    Date: 2021.04.30
    HARRIS 09:31:02 -05'00'

    Michael D. Harris
    Director
    Enforcement and Compliance Assurance Division

    cc: La Mar Gentry, Village of Alorton Administrator [[email protected]]


    Mayor Marius Jackson, City of Centreville [[email protected]]
    Mayor Curtis McCall, Jr., Village of Cahokia [[email protected]]
    Dennis Traiteur, Commonfields of Cahokia [[email protected]]
    Todd Bennett, Illinois EPA [[email protected]]
    Sanjay Sofat, Illinois EPA [[email protected]]
    Joe Stitely, Illinois EPA [[email protected]]

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