South East Water Limited – Company Storage Points Integrity
Notice under regulation 28(4) of the Water Supply (Water Quality) Regulations 2016 (as amended)
Reference: SEW-2025-00040
Version Number: 1
Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): South East Water Limited, with registered number 02679874 (hereinafter called ‘the company’).
Assets Affected:
All company service reservoirs
All company break pressure tanks
All company water towers
All company contact tanks
Any other treated water storage tanks operated by the company
Excluding those covered by individual legal instruments.
Details of this Notice:
- The Drinking Water Inspectorate (‘the Inspectorate’) has received a regulation 28(1) report of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’) from the company dated 1 September 2025, which states that there is or has been a significant risk of supplying water from company tanks and service reservoirs (and associated assets as applicable) that could constitute a potential danger to human health or could be unwholesome.
- Consequently, this Notice is served on the company by the Inspectorate on behalf of the Secretary of State, under regulation 28(4) for the assets listed above, for risks associated with:
|
Description of Risk |
Hazard/ Hazardous Event/ Parameter |
|---|---|
|
Potential risks from storage of water in tanks; including contamination from ingress or egress, and microbiological re-growth. |
Coliform Bacteria |
|
Escherichia coli (E. coli) | |
|
Enterococci | |
|
Clostridium Perfringens | |
|
Colony Counts | |
|
Residual disinfectant (chlorine free and total) |
Table 1: Table of the hazards, hazardous events, and/or parameters covered by this Notice, including the Hazard I D numbers and the description of risks.
- The company are required to satisfy the following requirements.
The date given is that until or by which the requirements must be maintained or satisfied, as appropriate.
Requirements:
(a) To maintain the following measures for the period specified in each case:
- Operate all tanks in accordance with current company policy, standards and procedures, that align to recognised standards of good practice.
Date: Ongoing for the duration of this Notice - Maintain risk-based enhanced (in addition to routine regulatory sampling) sampling for any tanks outside maximum 10 year inspection frequency. This must include, as a minimum, colony counts, E. coli and coliforms (full scope of enhanced monitoring to be determined under Company’s audit strategy (measure (c)1).
Date: Ongoing for the duration of this Notice - Maintain proactive external site inspections, grounds maintenance, site security and asset maintenance.
Date: Ongoing for the duration of this Notice - Maintain appropriate contingency plans (including liaison with relevant stakeholders as appropriate) to protect human health.
Date: Ongoing for the duration of this Notice
(b) To review, revise or make operational the following measures, by the dates specified in each case:
- Develop a service reservoir, water tower and tanks asset health policy setting out expected company standards. This must include but not be limited to;
- Inspection frequency (internal and external)
- Flood testing methods
- Age and construction type
- Contamination from ingress
- Tank hydraulics
- Turnover/ age of water
- Telemetry information associated with cells
- Sample line, tap and kiosk expectations
- Hatch and air vent conditions
- Ability to remove asset from supply for inspection and maintenance
- Redundant assets or equipment not disconnected
Date: 31 March 2027
- Following completion of measure (b)1, ensure the whole company is working consistently across all areas to new policy and expected standards. Implement revised training to water quality and operational teams to facilitate this policy update.
Date: 31 March 2027 - Introduce methodology based on robust risk assessment tools to determine a risk-based inspection frequency of all company service reservoirs, water towers and tanks.
Date: 30 June 2027 - Utilising the methodology developed in measure (b)3, complete individual assessments of all company service reservoirs, water towers and tanks, demonstrating risk-based decisions on inspection frequencies. Reference the methodology in the asset health policy. Date: 31 July 2027
- Confirm all service reservoirs, water towers and tanks that are over the company’s maximum inspection frequency standard and all tanks that are inoperable, including those that cannot be removed from supply without enabling works. Date: 31 July 2027
- Following completion of (b)5. determine enabling work required to remove and inspect all identified inoperable service reservoirs, water towers and tanks.
Date: 31 July 2028 - Review the justification and operation of booster chlorination for all relevant company service reservoirs, water towers and tanks. Date: 31 July 2027
- Following completion of (b)6. produce an action plan of immediate and longer-term measures, to mitigate identified risks and complete necessary work to allow all company service reservoirs, water towers and tanks to be removed from supply for internal inspection and maintenance. This should be completed for all sites, and apply to the following risk-based categorisations:
- Inoperable tanks – water treatment works
- Inoperable tanks – network
- In exceedance of inspection frequency standard – water treatment works
- In exceedance of inspection frequency standard – networks
Date: 31 October 2029
- Deliver the action plan produced in (b)8 to complete all enabling works to allow all company service reservoirs, water towers and tanks to be removed from supply for internal inspection and maintenance (allowing for any emergency, reactive changes in risk). Date: 31 March 2030
- Review the company’s existing resource capacity to ensure the effective and timely delivery of the tanks and service reservoir inspection programme. Date: 31 December 2027
(c) To audit whether the measures have been effective by the following means:
- Define an audit strategy to monitor the effectiveness of the measures specified in sections (a) and (b).
Date: 31 July 2026 - Implement, and keep under continuous review, the audit strategy defined in measure (c)1.
Date: Following completion of measure (c)1. onwards.
(d) Not to supply water for regulation 4(1) purposes from company treatment works or supply systems, or not to so supply unless the specified conditions below are satisfied:
- Not applicable
(e) To provide the following information in the time and manner specified below to enable monitoring of progress towards the mitigation of the risks:
- Provide a progress report annually.
Date: by 31 January each year. - Submit the service reservoir, water tower and tanks asset health policy, as specified in measure (b)1.
Date: 30 April 2027 - Submit a report providing evidence of the implementation of the revised training provided to water quality and operational teams to facilitate the asset health policy, as specified in measure (b)2.
Date: 30 April 2027 - Submit a report detailing the methodology introduced to determine a risk-based inspection frequency of all company service reservoirs, water towers and tanks, as specified in measure (b)3.
Date: 31 July 2027 - Submit a report containing the individual completed assessments of the company service reservoirs, water towers and tanks, demonstrating risk-based decisions on inspection frequencies, as specified in measure (b)4.
Date: 31 August 2027 - Submit a report confirming the list of all service reservoirs, water towers and tanks that are over the company’s maximum inspection frequency standard and all tanks that are inoperable, including those that cannot be removed from supply without enabling works, as specified in measure (b)5.
Date: 31 August 2027 - Submit a report confirming the enabling work required to remove and inspect the inoperable service reservoirs, water towers and tanks, as specified in measure (b)6. Date: 31 August 2028
- Submit a report providing evidence of the company’s review of the justification and operation of booster chlorination for all relevant service reservoirs, water towers and tanks, as specified in measure (b)7. Date: 31 August 2027
- Submit the action plan of immediate and longer-term measures, to mitigate identified risks and complete necessary work to allow all company service reservoirs, water towers and tanks to be removed from supply for internal inspection and maintenance, as specified in measure (b)8. Date: 30 November 2029
- Submit a report providing evidence of the delivery of the action plan specified in measure (b)9. Date: 30 April 2030
- Submit a report providing evidence of the company’s review of the resources required to ensure the effective and timely delivery of the tanks and service reservoir inspection programme, as specified in measure (b)10.
Date: 31 January 2028
- Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
Date: 31 August 2026 - Submit any revisions of the audit strategy produced under measure (c)2.
Date: Within 1 month of a revision - Submit a report in the event that any completed measures of this Notice need to be altered in any way, for any reason.
Date: Ongoing for the duration of this Notice - Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
Date: 31 May 2030
Further Details of this Notice:
- Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
- Under regulation 28(6) the Inspectorate, on behalf of the Secretary of State, may by notice served on the company, revoke or vary this Notice.
- Failure by the company to comply with this Notice may result in enforcement proceedings under section 18 of the Water Industry Act 1991 (as amended).
Signed
Nicholas Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
11 May 2026
Reference: SEW-2025-00040