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Notice of regulation: Affinity Water Limited – Service Reservoir and Treated Water Storage Tank Inspections

Notice under regulation 28(4) of the Water Supply (Water Quality) Regulations 2016 (as amended)

Reference: AFW-2022-00002

Version Number: 1

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Affinity Water Limited, with registered number 02546950 (hereinafter called ‘the Company’).

Assets Affected:

  • Farthing Common Reservoir 1 (RS606);
  • Egham Treated Water Tank South Cell (TN320).

Details of this Notice:

  1. The Drinking Water Inspectorate (‘the Inspectorate’) has received a set of regulation 28(1) reports of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’) from the Company dated 01 October 2021, which state that there is or has been a significant risk of supplying water from Farthing Common Reservoir 1 and Egham Treated Water Tank South Cell (and associated assets as applicable) that could constitute a potential danger to human health or could be unwholesome.
  2. 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

Hazard I D

Potential risk of ingress and microbial regrowth.

Coliform bacteria

AFW-TN320-BAC-C001-TOTCYN; AFW-RS606-BAC-C001-TOTCYN.

Potential risk of ingress and microbial regrowth.

E. coli (confirmed)

AFW-TN320-BAC-C002-E.COLI; AFW-RS606-BAC-C002-E.COLI.

Potential risk of ingress and microbial regrowth.

Enterococci (confirmed)

AFW-TN320-BAC-C003-ENTERO; AFW-RS606-BAC-C003-ENTERO.

Potential risk of ingress.

Cryptosporidium

AFW-TN320-BAC-C111-CRYPTO; AFW-RS606-BAC-C111-CRYPTO.

Microbial ingress into contact tank, treated water tank and service reservoir.

Microbiological

AFW-TN320-NST-H033-MIINTT; AFW-TN320-NST-H033-MIINCT; AFW-RS606-NSS-H033-MIINRE.

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.
  1. 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:

  1. 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
  2. Maintain enhanced (in addition to routine regulatory sampling) sampling for any tanks listed in this Notice. This must include, as a minimum, colony counts, E. coli and coliforms.
    Date: Ongoing for the duration of this notice
  3. Maintain proactive external site inspections, grounds maintenance, site security and asset maintenance. This must include periodic inspections of hatches, seals, redundant assets, sample taps, overflows, washouts, and air valves.
    Date: Ongoing for the duration of this notice
  4. Maintain appropriate contingency plans (including liaison with relevant stakeholders as appropriate) to protect human health.
    Date: Ongoing for the duration of this notice
  5. Keep under review residual chlorine concentrations to ensure appropriate set points and trigger values are in place to prevent a deterioration of drinking water quality.
    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:

  1. Confirm the programme of works (that includes cleaning, robust ingression testing (e.g. flood/inundation) and completion of any tank remedial work required), using a risk-based approach, to carry out physical internal inspection of Egham Treated Water Tank South Cell.
    Date: 30 June 2022
  2. Complete the programme of works developed in (b)1. Maintain appropriate documentation of any remedial work completed.
    Date: 30 September 2022
  3. Complete the replacement of Farthing Common Reservoir 1 Cell with the new cells, complying with regulation 31.
    Date: 31 March 2023
  4. Confirm a risk-based approach to determine the cleaning and physical internal inspection frequency of all Company tanks, to include as a minimum:
    • Time since last inspected;
    • Date of construction/age;
    • Materials of construction/tank design;
    • Water quality history (to include as a minimum E. coli, coliforms, and colony counts);
    • Turnover and tank hydraulics;
    • Points of potential ingress (hatches, seals, overflows, redundant assets, washouts, and air valves);
    • Sample tap condition, tapping points, sample lines and material; and
    • Any other risks related to individual tanks.
      Date: 31 December 2022
  1. Implement the risk-based approach to cleaning and physical internal inspections of all tanks within the company’s supply area, developed under measure (b)4.
    Date: 31 January 2023

(c) To audit whether the measures have been effective by the following means:

  1. Define an audit strategy to monitor the effectiveness of the measures specified in sections (a) and (b).
    Date: 31 July 2022
  2. 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 Farthing Common Reservoir 1 or Egham Treated Water Tank South Cell, or not to so supply unless the specified conditions below are satisfied:

  1. 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:

  1. Provide a progress report annually.
    Date: Annually by 31 January each year
  2. Submit the confirmed programme of work for the physical internal inspection for Egham Treated Water Tank South Cell, as required under measure (b)1.
    Date: 31 July 2022
  3. Confirm completion of the programme of works (measure (b)2).
    Date: 31 October 2022
  4. Confirm completion of the replacement of Farthing Common Reservoir Cell 1.
    Date: 30 April 2023
  5. Provide the risk-based approach developed under measure (b)4.
    Date: 31 January 2023
  6. Confirm the implementation of the risk-based approach (measure (b)5), including evidence to demonstrate implementation.
    Date: 28 February 2023
  7. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
    Date: 31 August 2022
  8. Submit any revisions of the audit strategy produced under measure (c)2.
    Date: Within 1 month of a revision
  9. 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
  10. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 31 May 2023

Further Details of this Notice:

  1. Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
  2. 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.
  3. 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
26 May 2022
Reference: AFW-2022-00002 (V1)

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