Title/Name/Summary
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 thousand (6,000) and twelve thousand (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, an extensive lead service pipe replacement effort has been underway since 2016, because of the Flint water crisis. Currently, the EPA is in draft of what will be required for states to follow.
In Illinois, under Public Act 099-0922, which took effect in 2017, community water supplies have been required to submit annual service line material inventories to 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 supplies 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 prioritize and strategize the replacement of known lead service lines within their water distribution system. Public Works has contracted with Baxter & Woodman to assist in our inventory and replacement plan reporting and provide for expertise with state requirements.
While the LSLRNA was initially due April 15, 2024, the Village applied for and received an extension to September 1, 2024, in order to submit our inventory to IEPA. The reason at time of extension was to allow PMI to finish our meter replacement program and subsequent report, and allow staff to review the data.
Up until 2024, the Village of Orland Park was not aware of any lead mains or lead services from main to the Buffalo box (B-box). Our current Village code, along with most of the surrounding villages, states that the Village is responsible 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 through the Meter Replacement Program done by PMI, each residence or business was verified. Out of over twenty-two thousand (22,000) meter locations, there were only four (4) services that were identified as lead. As such, LSLRNA now must be followed by the Village.
Currently, the IEPA considers the water services to be a municipality’s responsibility all the way up to meter in the home or business, rather than the B-box, which is more extensive for municipalities. It is still undetermined if the EPA will differ or agree with IEPA. In addition, other metals like cast iron are considered by IEPA as “lead”.
Once Public Works was notified about the four (4) service locations, letters were sent to the four (4) impacted residents with the lead services and informing them of their situation per IEPA.
Staff is currently investigating the four (4) residences to determine the feasibility to replace the lead service from the B-box to the meter due to the EPA law that will start in 2027, where the Village will have to replace the lines from the water main to the meter. In addition, the Village will have to 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. Also, if the resident sells their house, the Village will have to remedy the lead service line in a timely manner at the Village’s expense.
Currently, any grants being offered are for inventory efforts for predominately disadvantaged communities. Staff has investigated grants/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. Cook County does offer a program to replace lead services lines for licensed home-based childcare providers through their LeadCare program.
Other possible funding opportunities include:
HUD Community Development Block Grants - Some 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 be 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, they will be required to finance the entire replacement while utilizing those funds. Public Work staff feels the Village wouldn’t quality for any of these programs.
There are two options for the Village:
1. Require homeowner to fix within next three (3) years by sending letters to homeowners, send in the annual reports, and retain Baxter & Woodman for a yearly cost to keep our plan current and updated and send it to the IEPA/ EPA for next three (3) years. Then be required by IEPA/EPA to pay for the replacement in 2027 if they do not replace it.
2. Replace the four (4) service lines from the B-box to the meter at the Village’s expense and become compliant that we do not have any lead in our system. Report would no longer be required. The cost to replace the four (4) service lines would be approximately $60,000.00. Staff feels $10,000.00 per house with $20,000.00 contingency would be sufficient for the replacement of the lead services lines.
Under option #2, a scope of work will be bid out for contractors to bid on. While it might be costly now, it will be costlier years from now with the cost of materials (copper) rising and labor costs increase with contractors doing this work throughout the United States. In addition, there will undoubtedly be materials shortages which will delay replacement even further.
Financial Impact
Should option #2 be chosen, funds are available in FY2024 account 5008150-5705000.
Recommended Action/Motion
I move to recommend to the Village Board to approve Option 2, to replace the four (4) service lines from the B-box to the meter at the Village’s expense, at a cost of $10,000.00 per house with $20,000.00 contingency.