Title
Village of Orland Park Lead Service Replacement Plan
History
The Flint water crisis was a public health crisis that started in 2014 after the drinking water for the city of Flint, Michigan, was contaminated with lead. In April 2014, Flint changed its water source from Lake Huron and the Detroit River to the Flint River. Residents complained about the taste, smell, and appearance of the water. Officials failed to apply corrosion inhibitors to the water, which resulted in lead from aging pipes leaching into the water supply, exposing around one hundred thousand (100,000) residents to elevated lead levels. Between six and twelve thousand (6,000 and 12,000) children were exposed to drinking water with high levels of lead. Children are particularly at risk from the long-term effects of lead poisoning, which can include a reduction in intellectual functioning and IQ, and an increased chance of Alzheimer's disease.
Throughout the nation, because of the Flint water crisis, an extensive lead service pipe replacement effort has been underway since 2016. Currently, the Environmental Protection Agency (EPA) is in the draft stages of nationwide regulations which states will have to follow.
In Illinois, under Public Act 099-0922, which took effect in 2017, community water suppliers have been required to submit annual service line material inventories to the Illinois Environmental Protection Agency (IEPA). To address the known and unknown burden of lead service lines in the state, the Lead Service Line Replacement and Notification Act (LSLRNA) was passed. This Act requires community water suppliers to continue inventorying activities while developing and implementing plans to identify and remove lead service lines. In addition, it requires community water supplies to give owners and occupants notifications about lead service lines serving their homes or buildings and construction activities that may release lead into drinking water. The Act also prohibits partial lead service line replacement except in certain circumstances.
The first purpose of the LSLRNA is to require owners and operators of community water supplies to develop, implement, and maintain a comprehensive water service line material inventory and replacement plan. A well-developed materials inventory will allow communities to be able to prioritize and strategize the replacement of known lead service lines within their water distribution system. The Village of Orland Park Public Works Department has contracted with Baxter & Woodman to assist in our inventory and replacement plan reporting, and provide for expertise in complying with state requirements.
Village of Orland Park Inventory
Up until 2024, the Village of Orland Park did not have any known lead services from the water main to the Buffalo box (B-box). Our current village code, along with most of the surrounding villages, provides that the Village is responsible for the service line from the water main to the B-box in the parkway. Public Works did not know of any lead services in its water distribution system beyond the B-box, but as part of the Meter Replacement Program done in 2023 by PMI, each residence or business was verified. Out of over twenty-two thousand (22,000) meter locations, there were four (4) services that were identified as lead. As such, LSLRNA now must be followed by the Village.
Currently, IEPA and the Illinois Department of Public Health (IDPH) views service lines the responsibility of municipalities from the main all the way up to meter in the home or business, which is more extensive than our code. It is still undetermined if the EPA’s final regulations will differ or agree with IEPA as to this allocation of responsibility. In addition, other metals like galvanized pipe are considered by the IEPA as “lead,” but not by the EPA.
Once Public Works was notified about the four (4) service locations, letters were sent to the four (4) affected residents with the lead services informing them of their situation per IEPA. Staff is currently investigating the four (4) houses to determine the feasibility to replace the lead service from the B-box to the meter, due to the mandate coming in 2027 that the Village will have to replace ten percent (10%) of lead service lines per year until all are removed from the system. For Orland Park, that is one (1) per year for four (4) years.
LSLRNA Reporting
In addition, the Village must complete a time consuming yearly report that will have to be sent to the EPA, the IEPA, and IDPH until all the lead is removed from the system. Letters will have to be sent yearly to the four (4) residents. The Village also must conduct water sampling of sixty (60) sites within the Village including the four (4) lead service sites every six (6) months until all lead services are replaced.
We currently have one (1) of the four (4) residences refusing to allow us to take samples from their home. They have been difficult and unresponsive to our requests. Unfortunately, due to the resident’s unwillingness to participate, we are now in violation status with the IEPA, and will have to report the violation in our 2026 Consumer Confidence Report (CCR) to the residents of Orland Park. Also, if the resident sells the house, the Village will have to remedy the lead service line in a timely manner.
Grant Funds for Replacement
Currently, any grants being offered are for inventory efforts for predominately disadvantaged communities. Staff has investigated grants and/or programs to help offset the cost of replacing the services. In terms of available funding to replacement of lead service lines, there currently is no grant program readily available due to the minimal nature of the remediation required.
Cook County does offer a program to replace lead services lines for licensed home-based childcare providers through their LeadCare program. However, none of the four (4) homes would qualify.
The other possible funding opportunities would include:
-United States Department of Housing and Urban Development (HUD) Community Development Block Grants - Some select communities have had success utilizing these obtaining and utilizing these funds for replacements.
-U.S. Congressional Directed Spending Funds - These are appropriated by the U.S. Senate Committee, and are allocated on an annual basis.
-IEPA Public Water Supply Loan Program - The Village can request up to five (5) years of funds, and for lead service line replacements specifically, IEPA is offering a 0% loan for thirty (30) years. There is principal forgiveness for communities considered disadvantaged. Note that a project plan needs to developed, submitted to IEPA, and approved by IEPA to have funds reserved.
If the Village opts to utilize state or federal funds to replace lead service lines, we will be required to finance the entire replacement while utilizing those funds. However, Public Works staff has concluded that the Village wouldn’t quality for any of these programs.
Options for Replacement
Staff has developed three (3) options for the Village:
Option 1 - The Village does not replace the service line within next two (2) years. We send letters to homeowners, send in the annual reports, report our IEPA violation in CCR, do the required sampling every six (6) months, and retain Baxter & Woodman for a yearly cost to keep our plan current and updated and send it to the IEPA/ EPA for the next two (2) years. We continue to be in violation with the IEPA due to one (1) resident not participating in the sampling until all four locations have been fixed. The Village will then be forced by IEPA/EPA to pay for the replacement starting in 2027 if the resident doesn’t replace it on their own beforehand, and will be obligated by law to replace one (1) service line a year until all four have been replaced.
Option 2 - Replace the four (4) service lines from the B-box to the meter at the Village’s expense, and become compliant by not having any lead services in our system. Reports and sampling every six (6) months would be drastically reduced and eventually eliminated. The replacement cost for the four (4) service lines would be between $60,000.00 and $80,000.00 total. Staff estimates that $10,000.00 to $15,000.00 per house with $20,000.00 contingency would be sufficient for the replacement of the lead services lines. Those cost numbers are what communities around Orland Park are currently paying contractors to replace a service line from the main to the meter.
Option 3 - Pass an ordinance that requires the residents to participate in replacing their service line by the Village by 2027, or have their water turned down and a lien placed on their home until they comply with the replacement.
Staff is recommending Option 2. A scope of work will be bid out for contractors to bid on. With the cost of materials (copper) and labor increasing with contractors doing this work throughout the United States, delay will almost undoubtedly result in additional cost. In addition, there will be materials shortages which will delay replacement even further. In 2027, we will be obligated by law to replace one (1) service line a year until all four (4) have been replaced. Also, until all four (4) services are replaced and the Village gets full participation from those residents, we will be in violation status with the IEPA and will have to regularly attempt to obtain sampling data from homeowners who have expressed unwillingness to cooperate.
Should the Village choose to wait to replace the service lines until 2027 when we would be obligated to replace them, additional costs will be incurred over the next two (2) years including:
-Employee time obtaining samples every six (6) months until all lead services are replaced.
-Maintaining a contract with Baxter & Woodman to oversee our program for the foreseeable future.
-The cost testing all the samples that are taken for the foreseeable future.
-Increased material costs as they will become scarce due to nationwide replacement requirements.
-Labor costs will go up as demand for skilled contractors becomes acute due to replacement requirements.
Financial Impact
Funds for service line replacement are available in FY2025 in account 5008150-443800.
Recommended Action/Motion
I move to recommend that Public Works pursue replacement of four (4) lead services lines with copper from B-box to meter this fiscal year at the Village’s expense.