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Portsmouth Water Limited – Funtington Treatment Works, Risk to Disinfection and Cryptosporidium Risk

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

Reference: PRT-2020-00010

Version Number: 5

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Portsmouth Water Limited, with registered number 02536455 (hereinafter called ‘the Company’).

Assets Affected:

  • Funtington Treatment Works – TFUN
  • Lavant North Supply Zone – ZLV1
  • Lavant South Supply Zone – ZLV2

Details of this Notice:

  1. 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 20 October 2017, alongside subsequent reports dated 31 October 2018, 18 October 2019 and 07 February 2023,, which states that there is or has been a significant risk of supplying water from Funtington Treatment Works (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

Failure to meet requirements of regulation 26, inadequate disinfection, due to a failure to demonstrate that disinfection contact time is met under all conditions.

Microbiological and viruses

Failure to demonstrate chlorine contact time within the contact main.

Microbiological and viruses

Disinfection – Inadequate disinfection (failure to meet CT time).

Microbiological and viruses

Contaminant of concern – Cryptosporidium

Cryptosporidium

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 a treatment process which meets the requirements of regulation 26 in full, to disinfect the water at all times and under all flow conditions.
    Date: Ongoing for the duration of this Notice
  2. Continuously review all critical control points and mitigation measures with a view to updating the Notice with additional measures where required. Ensure that any new risk identified is assessed in accordance with the Company’s Drinking Water Safety Plan (DWSP) methodology.
    Date: Ongoing for the duration of this Notice
  3. Operate all processes within defined operating ranges, with appropriate triggers, responses and contingency procedures.
    Date: Ongoing for the duration of this Notice
  4. Ensure the works control and shutdown system is operational and that monitors are calibrated at the predefined frequencies.
    Date: Ongoing for the duration of this Notice
  5. Continuous monitoring to ensure that water being presented for disinfection is of the required standard to achieve disinfection and to verify that disinfection is taking place and is effective.
    Date: Ongoing for the duration of this Notice
  6. Take action to prevent water leaving the treatment works when monitoring indicates that the water quality falls outside target range and that disinfection requirements are not met. The Company must take appropriate action to protect human health.
    Date: Ongoing for the duration of this Notice
  7. Maintain documented procedures for the escalation and investigation of any deviation from expected results or consumer complaints.
    Date: Ongoing for the duration of this Notice
  8. Take all reasonable operational steps (and continue to enhance the effectiveness) to ensure that water that is not compliant with the requirements of regulations 4 and 26 is prevented from entering supply.
    Date: Ongoing for the duration of this Notice
  9. Enhanced operational water quality monitoring to validate and verify the quality of water entering supply.
    Date: Ongoing for the duration of this Notice
  10. Maintain continuous monitoring for Cryptosporidium.
    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. Complete the construction, installation (or modification of the existing) and commissioning of the chosen disinfection and treatment process (designed under Notice PRT3918, which this Notice replaces). Commissioning must include the following to account for the changes made:
    • Updating of the Site-Specific Disinfection Policy and any associated site-specific procedures;
    • Updating of the Site Operating Manual and removal of all out-of-date material from circulation; and
    • Provision of adequate training to operators on the chosen solution installed (or modified) and site operating manual under this measure.
      Date: Complete
  1. Following the completion of the requirements of the Regulation 27(4) Notice PRT-2020-00002 for the Company’s catchment risk assessments for Funtington Treatment Works, complete a gap analysis between the reviewed and/or new risks assessment reports (as required under PRT-2020-00002) and the capabilities of the existing treatment in place.
    Date: Complete
  2. Carry out continuous monitoring for Cryptosporidium and enhanced frequency (weekly sampling for microbiological parameters and sampling of individual boreholes) monitoring for faecal indicator organisms for a minimum of two years to verify the Company’s catchment risk assessment and review the capabilities of the existing treatment in place.
    Date: Complete
  3. Implement measures to mitigate the risk of ingress and water quality deterioration, including:
    • Measures to address the risk of ingress from the borehole headworks and head pit; and
    • Investigation of the underground pipework and implementation of appropriate measures to address any risk to water quality.
      Date: Complete
  4. Design a solution to address the risk of Cryptosporidium and any unmitigated risks identified through the completion of the gap analysis required under measure (b)3.
    Date: Complete
  1. Implement and commission the chosen solution developed under measure (b)5. Commissioning must include the following to account for the changes made:
    • An appropriate maintenance regime for any installed (or modified) processes;
    • Full integration of any new (or modified) processes into the site control and monitoring systems.
    • Updating of the Site-Specific Disinfection Policy and any associated site-specific procedures;
    • Updating of the Site Operating Manual and removal of all out-of-date material from circulation; and
    • Provisions of adequate training for all relevant personnel on the operation, repair and maintenance of any installed (or modified) process and the revised procedures, policies and manual.
      Date: 30 June 2024
  1. Install temporary treatment to mitigate the risk of Cryptosporidium until such time as measure (b)6 has been delivered.
    Date: Complete

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

  1. Update the audit strategy to monitor the effectiveness of the measures specified in sections (a) and (b).
    Date: Complete
  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 TREATMENT WORKS OR SUPPLY SYSTEMS, or not to so supply unless the specified conditions below are satisfied:

  1. A full investigation into the quality of the raw water sources supplying Funtington Treatment Works, characterisation of the risks to water quality and appropriate actions to mitigate against the risk of Cryptosporidium in the final water have been completed.
    Date: Ongoing until completion of measures (b)4 and (b)6 or (b)7.
  2. Notification to the Inspectorate, with provision of the investigation and measures implemented under measure (d)1. and the anticipated duration of use.
    Date: Ongoing until completion of measures (b)4 and (b)6 or (b)7.

(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: by 31 January each year.
  2. Confirmation of completion of measure (b)1.
    Date: Complete
  3. Submit a report summarising the performance of the solution, installed under measure (b)1, over the year since its installation.
    Date: Complete
  4. Submit a report outlining the findings of the gap analysis required under measure (b)2.
    Date: Complete
  5. Submit a report detailing the results of the enhanced monitoring to verify the Company’s catchment risk assessment, and the review of the capabilities of the existing treatment based on the verified catchment risk assessment using a minimum of two years enhanced monitoring data. Confirm the projected completion dates for measures (b)4 and (b)5.
    Date: Complete
  6. Submit a report outlining the Company’s chosen solution (measure (b)5).
    Date: Complete
  7. Confirm the measures implemented under measure (b)4 and confirm implementation and commissioning of the chosen solution (measure (b)6).
    Date: 31 July 2024
  8. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
    Date: Complete
  9. Confirm the implementation and commissioning of measure (b)7.
    Date: Complete
  10. Submit any revisions of the audit strategy produced under measure (c)2.
    Date: Within 1 month of a revision
  11. 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
  12. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 31 July 2025

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).
  4. Contravention of a regulation 28(4)(d) requirement is an offence under regulation 33(1). If guilty of such an offence, the Company is liable on summary conviction, or on conviction on indictment, to a fine. Under regulation 33(2) it is a defence for the Company to show that it took all reasonable steps and exercised all due diligence to avoid the commission of the offence.

Signed

Nicholas Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
22 February 2024
Reference: PRT-2020-00010 v5

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