Notice of Regulation: Saddlescombe Water Treatment Works

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

NOTICE UNDER REGULATION 28(4)

South East Water Limited: Saddlescombe Water treatment works

Reference: SEW-2018-00003

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:
T017 Saddlescombe Works
Z040 Saddlescombe Water Supply Zone
Z049 Underhills Water Supply Zone

  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 1 September 2018, which states that there is or has been a significant risk of supplying water from Saddlescombe 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:
    • Failure to meet requirements of Regulation 26, inadequate disinfection, due to a failure to demonstrate that disinfection contact time is met under all conditions.
    • Residual Disinfectant- Free
    • Residual Disinfectant- Total
    • Microbiological

  1. The Company are required to satisfy the following:

Requirements

(a) to maintain the following measures for the period specified in each case

  1. Optimisation of all existing treatment processes.
    Date: Ongoing for duration of this notice
  2. Operation of all processes within defined normal operating ranges with appropriate triggers, responses and contingency procedures.
    Date: Ongoing for duration of this notice
  3. Online turbidity and chlorine monitoring with appropriate alarms and failsafe shutdown.
    Date: Ongoing for duration of this notice
  4. Enhanced and large volume operational monitoring for microbiological parameters at Saddlescombe works and at the downstream commercial property supplied.
    Date: Ongoing for duration of this notice

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

  1. Assess the quality of the water leaving the works with a view to the subsequent first downstream property. The company should reassess the flow conditions and actual disinfection values being achieved.
    Date: Complete
  2. Install interim monitoring on a suitable downstream location after disinfection to provide information for the verification of disinfection.
    Date: Complete
  3. The Company shall undertake an investigation of the existing disinfection system and confirm a programme of work to provide adequate disinfection under all circumstances and flow rates and include the following:
    Date: Complete
    • The point in the treatment process whereby disinfection is achieved (the point of disinfection) must be clearly defined.
    • The final sample point must be located at the end of the treatment process and be representative of water leaving the treatment process.
    • The disinfection system must take into account flow dynamics through the treatment works and contact main, and this must be established using appropriate techniques.
    • The disinfection system must provide safeguards such as automatic shutdown or failsafe systems to prevent untreated or partially treated water entering into supply.
    • Installation of monitoring for turbidity and chlorination to provide verification of disinfection.
    • Provide clearly defined critical control points, and real time evidence that the target chlorine contact time is achieved.
  4. Install (or modify the existing) and commission the chosen disinfection system as defined by (b)3.
    Date: Complete
  5. Review the Site Specific Disinfection Policy with associated site specific procedures and report revisions of the document to the Inspectorate.
    Date: Complete
  6. Update the Site Operating Manual and remove all out of date material from circulation.
    Date: 30 June 2021
  7. Provide adequate training to operators as part of the commissioning process and for any revision of the Site Operating Manual completed under (b)6.
    Date: 30 June 2021

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

  1. Define a strategy for auditing the effectiveness of the above measures.
    Date: Complete
  2. Implement the audit strategy outlined in (c)1. above.
    Date: Until the revocation of this Notice

(d) not to supply water for regulation 4(1) purposes from Saddlescombe works, or not to 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 risk of supplying water that would constitute a potential danger to human health:

  1. Provide a progress report annually by 31 January and against the following milestones:
    • Provide a report on completion of (b)1 including details of the assessment and any subsequent actions taken to protect consumers if required.
      Date: Complete
    • Provide a report on completion of (b)2.
      Date: Complete
    • Provide annually a summary of results from the interim monitoring in (b)2 including any subsequent actions taken.
      Date: Annually by 31 January until completion of (b)4
    • Provide a design specification for the proposed disinfection scheme described in (b)3 with dates for commissioning and completion of work.
      Date: Complete
    • Submit a report on completion of the commissioning of the system as defined by (b)4 with an updated Site Specific Disinfection Policy required under measure (b)5 and evidence of completed training required under measure (b)7.
      Date: 30 June 2021
    • Report to confirm details of the strategy for auditing the effectiveness of the measures as specified in (c)1.
      Date: Complete
  2. Submit any revisions of the audit strategy produced under measure (c)2.
    Date: Within 1 month of a revision
  3. Submit a report in the event that any completed measure of this Notice needs to be altered in any way for any reason.
    Date: Ongoing for the duration of this notice
  4. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 31 May 2022

  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
Laura Moss
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
16 June 2021
Reference: SEW-2018-00003
Version 2

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