Notice of Regulation: Lumley Works

THE WATER SUPPLY (WATER QUALITY) REGULATIONS 2016 (AS AMENDED)

NOTICE UNDER REGULATION 28(4)

NORTHUMBRIAN, ESSEX AND SUFFOLK WATER: LUMLEY WORKS

Lumley Works – T0700333

Supplying Zones:
Z0021446 – S204 Lumley
Z0021447 – S205 Sunderland City
Z0021448 – S209 Stoneygate Outlet
Z0021449 – S210 Wear Valley & Lumley
Z0021450 – S211 New Winning & Peterlee
Z0021451 – S213 Mill Hill Outlet
Z0021454 – S216 South Hylton

DWI Reference: NES-2020-00008

THE SECRETARY OF STATE:

1. has received reports from Northumbrian, Essex and Suffolk Water (the “Company”) dated 30 September 2019 and 20 January 2020 (the “Reports”) which states that there is or has been a significant risk of supplying water from Lumley Works – T0700333 that could be unwholesome due to the presence of Cryptosporidium oocysts.
2. GIVES NOTICE to the Company under regulation 28(4) of the Water Supply (Water Quality) Regulations 2016 (as amended) that it must satisfy the following requirements:

For risks associated with:

• Cryptosporidium oocysts

Requirements

(a) to maintain the following measures for the period specified

The following existing measures will be maintained at Lumley treatment works and its associated supply system:

1. To ensure that wholesome water is supplied to consumers at all times, in accordance with the requirements if Regulation 4.
   Date: Ongoing until revocation of Notice
2. Periodic catchment water safety plan review to ensure current hazard mitigation is in place and appropriate for the risk of Cryptosporidium oocysts.
   Date: Ongoing until revocation of Notice
3. Monthly maintenance of the River Quality Monitoring Station (RQMS) and the online monitoring equipment held within including; river level, pH, dissolved oxygen, temperature, turbidity, ammonia and conductivity.
   Date: Ongoing until revocation of Notice
4. Regular calibration and verification of the RQMS online equipment and operational checks of alarms into Lumley works SCADA system.
   Date: Ongoing until revocation of Notice
5. Continuous sampling for Cryptosporidium oocysts on final water and monitoring on the raw water in line with the Company Cryptosporidium monitoring strategy.
   Date: Ongoing until revocation of Notice
6. Up to date works operating manual defining normal operating ranges with appropriate triggers, responses and contingency procedures.
   Date: Ongoing until revocation of Notice
7. Include raw and inter-stage bacteriological analysis data in monthly treatment performance reviews of Lumley works.
   Date: Ongoing until revocation of Notice
8. Water quality response procedures for investigation of contraventions including process optimisation and reporting.
   Date: Ongoing until revocation of Notice
9. Contingency plans to protect human health in the event of a risk associated with drinking water quality, which should include liaison with local authorities and Public Health England.
   Date: Ongoing until revocation of Notice

(b) to review, revise and/or make operational the following measures, by the date specified below:

Catchment & River Quality Monitoring

1. Complete a policy review in relation to early warning monitoring systems for all surface water treatment works which must outline the minimum standards for early warning monitoring systems.
   Date: Complete
2. Update policy and complete an audit to identify any shortfalls against the new policy document for;
   • a. Lumley works
     Date: Complete
   • b. All other surface water treatment works
     Date: Complete
3. Develop an action plan to resolve gaps identified in (b)2 for;
   • a. Lumley works
     Date: Complete
   • b. All other surface water treatment works
     Date: Complete
4. Deliver action plans outlined in (b)3 for;
   • a. Lumley works
     Date: Complete
   • b. All other surface water treatment works
     Date: 31 March 2025

5. Review Lumley works control philosophy including;
   • a. Control logic for pump duty change over needs, with the aim to minimise the impact of pump duty change over on intake flow surges.
     Date: Complete
   • b. A focus on minimising potential impact on water quality and treatment process performance, particularly clarification treatment.
     Date: Complete
6. Improve the Lumley raw water sampling arrangements (including online monitoring equipment linked to works SCADA) to provide adequate and accurate representation of raw water quality entering the treatment works.
   Date: Complete
7. In parallel to completion of (b)6 review and update the standard operating procedure (SOP) for Lumley works controllers that includes guidance on management of raw water quality deterioration and considerations to help maintain treatment performance.
   Date: Complete

Chemical Coagulation & Flocculation

8. Undertake a review of;
   • a. All chemical dosing systems associated with the coagulation process at Lumley works with a focus on dose control, dosing point location and monitoring of each system.
     Date: Complete
   • b. Mixing performance and the suitability of online UV254 monitoring and associated improvements to coagulant dose control at Lumley works.
     Date: Complete
9. Following completion of (b)8 review and update the SOP for Lumley works operators that includes guidance and considerations to help maintain coagulation treatment performance. This should include determining the conditions for when polydadmac dosing is initiated and retracted.2
   Date: Complete
10. Update Lumley works SCADA to include;
    • a. A dedicated SCADA page for raw water quality parameters, coagulant dose and pH for improved visibility to Lumley works operators.
      Date: Complete
    • b. Travel time through Lumley treatment processes to provide works operators with improved understanding of lag times between changes made to treatment and their impact on water quality.
      Date: Complete

Clarification Process

11. Review options to provide flow monitoring within the two clarifier inlet channels at Lumley works to improve visibility of flow distribution.
    Date: Complete
12. Following (b)11 implement the most appropriate solution to provide flow monitoring within the two clarifier inlet channels at Lumley works.
    Date: Complete
13. Review options to improve turbidity monitoring and sample arrangements of the Lumley clarification stage.
    Date: Complete
14. Following (b)13 implement the most appropriate solution to improve turbidity monitoring and sample arrangements.
    Date: Complete
15. Review and update clarifier return to service procedure at Lumley works with the following considerations;
    Date: Complete
    • a. Run to waste length of time to discharge water that has not undergone full clarification.
    • b. Flow balance between inlet and run to waste
    • c. Sampling to confirm suitability of clarifier for return to service
    • d. Adjustments to inlet flow rate once ready to go into service
16. Develop company Best Operational Practice (BOP) document for clarification, this must include; design, operation, monitoring and maintenance.
    Date: Complete
17. Complete gap analysis of Lumley works against company clarification BOP.
    Date: Complete
18. Develop an action plan to resolve gaps identified in (b)17 for Lumley works.
    Date: Complete
19. Deliver action plan outlined in (b)18.
    Date: 31 March 2025

Rapid Gravity Filtration (RGF)

20. Undertake a review of the RGF stage valving and control philosophy at Lumley works to identify improvements to ensure impact from filter flow change is reduced, particularly when filters are removed and returned to service following a wash.
    Date: Complete
21. Following completion of (b)20 develop an action plan to be delivered.
    Date: Complete
22. Deliver the action plan outlined in (b)21.
    Date: 31 March 2023
23. Complete an assessment of the current Lumley backwash set-up and conditions, consideration should be given to the following areas;
    Date: Complete
    • a. Up-wash flow rates and benefit from temperature compensation to achieve appropriate bed expansion
    • b. Backwash sequence times to achieve optimum wash without over cleaning of media
    • c. Length of run to waste time
    • d. Length of slow start time
    • e. Water quality upon filter re-start
24. Following completion of (b)23 develop action plan for improvements.
    Date: Complete
25. Deliver action plan outlined in (b)24.
    Date: 31 March 2023
26. Develop a company Primary Filtration BOP that will cover the design, operation, monitoring, associated alarms and maintenance of the RGF stage for works.
    Date: Complete
27. Complete a gap analysis of Lumley works against company Primary Filtration BOP.
    Date: Complete
28. Develop an action plan to resolve gaps identified in (b)27 for Lumley works.
    Date: Complete
29. Deliver action plan outlined in (b)28.
    Date: Complete

30. Install and operate validated UV irradiation on the outlet of the Lumley RGFs to reduce the risk of viable Cryptosporidium oocysts entering supply and achieve a log removal as defined in the site specific disinfection policy.
    Date: Complete
31. Review and update procedures at Lumley works for dealing with inadequately disinfected water;
    • a. Under the current site arrangements.
      Date: Complete
    • b. Prior to the completion of RGF UV installation.
      Date: Complete
32. Review point of disinfection online monitoring instrument validation at Lumley works against current company policy to demonstrate compliance with industry standards.
    Date: Complete
33. Company to complete a review of the company’s disinfection policy.
    Date: Complete
34. Following completion of (b)33 the company must review and update the site specific disinfection policies of all surface water treatment works to ensure that required log removal from raw water pathogen indicator loading through works treatment processes is achieved under a range of site specific operating conditions.
    Date: Complete

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

1. Define and keep under continuous review an audit strategy to monitor the effectiveness of the above measures.
   Date: Within 2 months of Notice issue
2. Implement the audit strategy defined in (c)1.
   Date: For the duration of the Notice.

(d) Not to supply Water for regulation 4(1) purposes from Lumley Treatment Works

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 risk of supplying water that would constitute a potential danger to human health:

1. Provide a progress update annually by 31 January and against the following milestones:

Catchment & River Quality Monitoring

a) Submit action plan outlined in (b)3(a.
Date: Complete
b) Submit action plan outlined in (b)3(b.
Date: Complete
c) Confirm completion of action plan deliverables in (b)4(a.
Date: Complete
d) Confirm completion of action plan deliverables in (b)4(b.
Date: 30 April 2025

Raw Water

e) Provide summary of control philosophy review findings in (b)5.
Date: Complete
f) Confirm actions taken to improve Lumley raw water sampling arrangements in (b)6.
Date: Complete
g) Provide the associated SOP updated in (b)7.
Date: Complete

Chemical Coagulation & Flocculation

h) Confirm actions taken following (b)8 review of coagulation chemical dosing systems and provide the associated SOP updated in (b)9.
Date: Complete
i) Confirm completion of (b)10.
Date: Complete

Clarification Process

j) Provide summary of review options and agreed solutions under (b)11 and 13.
Date: Complete
k) Confirm solution delivery for (b)12 and 14.
Date: Complete
l) Submit updated clarifier return to service procedure for Lumley works ((b)15).
Date: Complete
m) Submit company BOP document for clarification in (b)16.
Date: Complete
n) Submit action plan outlined in (b)18.
Date: Complete
o) Confirm completion of action plan deliverables in (b)18.
Date: 30 April 2025

RGF

p) Submit action plan outlined in (b)21.
Date: Complete
q) Confirm solution delivery of improvements to RGF stage valving and control philosophy (b)22.
Date: 30 April 2023
r) Submit action plan outlined in (b)24.
Date: Complete
s) Confirm completion of action plan deliverables in (b)24.
Date: 30 April 2023
t) Submit Primary Filtration BOP document ((b)26).
Date: Complete
u) Submit action plan developed in (b)28.
Date: Complete
v) Confirm completion of action plan deliverables in (b)28.
Date: Complete

Disinfection Application

w) Confirm completion of (b)30.
Date: Complete
x) Provide summary of review findings against deliverable (b)31(a.
Date: Complete
y) Provide summary of review findings against deliverable (b)31(b.
Date: Complete
z) Provide summary of instrument validation review against current company policy at Lumley under (b)32.
Date: Complete
aa)Confirm completion of company disinfection policy review under (b)33.
Date: Complete
bb)Confirm completion of all surface water works site specific disinfection policy reviews under (b)34.
Date: Complete

2. Review the risk assessment for Lumley Treatment Works as required by regulation 27(3) and subsequently submit a revised regulation 28 report accompanied by a signed board level declaration.
   Date: Ongoing until revocation of notice
3. Submit a satisfactory completion report.
   Date: 30 April 2025

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Failure by the Company to comply with this Notice may result in enforcement proceedings under section 18 of the Water Industry Act 1991.

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Signed
Nicholas Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
30 May 2022
DWI Reference: NES 2020-00008
Version 2