PUBLIC UTILITIES ADVISORY BOARD AGENDA ITEM
ACTION REQUESTED:
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Receive the Quarterly Water Utility Regulatory Report
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DEPARTMENT: Water Utilities
SUBMITTED BY: Darrell Blenniss, Director of Water Utilities
BOARD/COMMISSION REVIEW:
N/A
BACKGROUND:
The year 2026 represents a period of high-intensity execution for the Department of Public Utilities. The utility is actively managing a convergence of federal oversight from the U.S. Environmental Protection Agency (USEPA) and state-level enforcement by the Illinois EPA (IEPA). The era of "voluntary" improvements has effectively transitioned into a framework of statutory deadlines and enforceable standards.
Key regulatory drivers for 2026 include:
● Lead Elimination: The accelerated eradication of lead service lines under the Lead and Copper Rule Improvements (LCRI).
● Nutrient Reduction: Capital-intensive mandates for phosphorus removal at the Springbrook Water Reclamation Center (WRC).
● Emerging Contaminants: Strict enforcement of PFAS standards and the monitoring of biosolids disposal liabilities.
● Cybersecurity: New state requirements under Illinois HB3576 to harden critical infrastructure.
DISCUSSION:
Drinking Water Compliance: Lead Service Line Replacement Program
Staff continues to aggressively implement the Lead Service Line Replacement (LSLR) program. The utility has adopted a "full replacement" strategy to ensure compliance with the Illinois Lead Service Line Replacement and Notification Act, replacing both public and private portions of the line simultaneously.
● Inventory Status: The electronic inventory submitted to the IEPA indicates lead and galvanized service lines constitute less than 1% of the City’s 47,000+ connections. Approximately 100 lines remain to be addressed as of Q3 2026.
● Operational Progress: Following the successful replacement of 71 lines in 2025, operations have moved into the final phase.
● Funding: The City has successfully secured a zero-interest loan through the IEPA State Revolving Fund (SRF). This funding, combined with the Water Capital Charge, ensures the program remains fiscally sustainable while aiming for a "Lead-Free" designation by 2028.
Regulatory Permitting: NPDES Renewal Status
Staff has been engaged in protracted negotiations with the IEPA regarding the renewal of the National Pollutant Discharge Elimination System (NPDES) permit for the Springbrook WRC.
● Status: Negotiations are nearing a conclusion. The IEPA suggested additional modeling to address the 0.1 mg/L phosphorus limits advocated by Environmental Action Groups (EAGs). After careful review, the Workgroups have informed the IEPA that further modeling is unlikely to shift the current consensus, as the EAGs’ position appears to be rooted in fundamental policy goals rather than technical data. Consequently, the costs associated with additional modeling are not expected to provide a practical benefit to the process.
● Timeline: We anticipate the IEPA will issue the draft permit for Public Notice within the next 30 to 60 days. This will trigger a mandatory 30-day public comment period. Staff will conduct a final technical review of the draft language upon release.
Wastewater Capital Program: Springbrook WRC Revitalization
The revitalization of the Springbrook WRC is the primary capital focus for 2026, driven by the need to meet future phosphorus limits.
● Regulatory Driver: While the plant operates under a current phosphorus limit of 1.0 mg/L, the upgrades are designed to meet a future limit of 0.5 mg/L.
● Construction Milestones:
○ Influent Pump Station and South Plant Forcemain ($7.3mil): Final completion date was May 2026.
○ Nutrient Removal & North Plant Aeration ($66.4M): Final design has been completed, and bidding is anticipated in January 2027.
○ South Plant Grit & RAS Improvements ($14.1M): Scheduled for substantial completion in February 2027.
○ South Plant Improvements ($59.3M): Active construction throughout 2026, Substantial Completion May 2028.
○ Cloth Media Disc Filters ($36.0M): Consultant selection underway with engineering design in 2026 and 2027.
Financing: Unlike the lead program, these projects are funded primarily through General Obligation Bonds (Series 2025 issuance), supported by revenue from the dedicated Phosphorus Surcharge.
Emerging Contaminants (PFAS) and Biosolids
Naperville’s drinking water remains fully compliant with federal PFAS standards, thanks to the high quality of our Lake Michigan source water purchased from the DuPage Water Commission.
● Biosolids Management: The primary risk remains the presence of PFAS in wastewater biosolids. Staff is currently disposing of biosolids via land application. However, we are closely monitoring USEPA interim guidance and state legislative trends that could restrict this practice. A shift to landfilling would result in significantly higher operational costs. Staff will continue to monitor this regulatory environment throughout 2026.
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Cybersecurity Compliance
Cybersecurity is now a regulated operational requirement under Illinois HB3576.
● Implementation: Staff is proceeding with the development of the formal Cybersecurity Program mandated by the state. This includes finalizing asset inventories and incident response plans.
● Audit Status: Staff has issued RFP-25-126 for a comprehensive Cyber Security Audit. The findings from this audit will be used to validate network segmentation and access controls, ensuring compliance with both state law and USEPA Sanitary Survey requirements.
● VADR Review: Staff concluded Validated Architecture Design Review (VADR) with CISA. The report from this cybersecurity design review recognized our team's robust emergency action plan, effective cybersecurity awareness campaigns, and knowledgeable team.
Watershed Management
Staff continues to participate in the DuPage River Salt Creek Workgroup (DRSCW) to manage chloride compliance.
● TLWQS Re-Evaluation: 2026 marks the 5-year re-evaluation point for the Time Limited Water Quality Standard (TLWQS) variance. Staff is assisting the DRSCW in aggregating data to demonstrate the effectiveness of our Best Management Practices (BMPs), such as the use of brine and calibrated spreaders, to maintain this variance. Please note that much of the chloride management is conducted by the Department of Public Works.