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South Staffordshire Water Plc – Springsmire Reservoir

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

Reference: SST-2022-00001

Version Number: 1

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): South Staffordshire Water Plc, with registered number 02662742 (hereinafter called ‘the Company’).

Assets Affected:

  • Springsmire Reservoir (RSPR1)
  • Springsmire East (ZSPE)
  • Springsmire West (ZSPW)

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 2022, which states that there is or has been a significant risk of supplying water from Springsmire Reservoir (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 ID

Structural failure of walls

Microbiological

RSPR1002

Structural failure of roof

Microbiological

RSPR1006

Loss of water quality due to biofilm growth

Microbiological

RSPR1013

Poor construction leading to introduction of contamination

Microbiological

RSPR1018

RSPR1021

RSPR1022

Build up of bacterial growths and deposits due to ineffective operation

Microbiological

RSPR1026

Coliform Bacteria (Indicator)

Coliform Bacteria (Indicator)

RSPR1037

E. coli (faecal coliforms Confirmed)

E. coli (faecal coliforms Confirmed)

RSPR1038

Enterococci

Enterococci (Confirmed)

RSPR1089

Cryptosporidium

Cryptosporidium (Confirmed)

RSPR1090

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 Springsmire Reservoir in accordance with company policy, standards, and procedures, aligning with recognised standards of good practice.
    Date: Ongoing for the duration of this Notice
  2. Carry out investigatory sampling in response to any microbiological exceedances.
    Date: Ongoing for the duration of this Notice
  3. Maintain enhanced sampling (in addition to statutory sampling) at Springsmire Reservoir. This must include, as a minimum, colony counts, E. coli and total coliforms.
    Date: Ongoing for the duration of this Notice
  4. Maintain proactive, external site inspections, grounds maintenance, site security and asset maintenance, including periodic inspections of hatches, seals, redundant assets, sample taps, overflows, washouts, and air valves. Ensure these checks are documented. 
    Date: Ongoing for the duration of this Notice 
  5. Maintain an appropriate contingency plan for Springsmire Reservoir (including liaison with relevant stakeholders as appropriate) in the event of the site needing to be removed from supply to protect human health. 
    Date: Ongoing for the duration of this Notice 
  6. 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 
  7. Maintain records and evidence of the identification, decision making, and completion of remedial work at Springsmire Reservoir, to ensure a robust audit trail. 
    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. Develop a plan for the mitigation actions required to remove Springsmire Reservoir from supply in the event of an emergency and update the regulation 27 risk assessments to reflect this risk.
    Date: 30 April 2023
  2. Develop a plan and schedule of works (with timescales) to isolate Springsmire Reservoir from supply for a physical internal inspection (including clean and flood test) and to complete any remedial work required.
    Date: 30 April 2023
  3. Complete the enabling works required to provide resilience to the Springsmire Zone and undertake a trial isolation of Springsmire reservoir to confirm the effectiveness of the zonal resilience works.
    Date: 30 September 2023
  1. Isolate Springsmire Reservoir from supply. Undertake a physical internal inspection, clean and flood test of Springsmire Reservoir.
    Date: 31 October 2023
  1. Complete any remedial work required and return Springsmire Reservoir to service.
    Date: 31 March 2024

(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: 30 June 2023
  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 Springsmire Reservoir, 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: by 31 January each year
  2. Provide the plan of the mitigation actions required to remove Springsmire Reservoir from supply in the event of an emergency and provide an updated risk assessment.
    Date: 31 May 2023
  3. Provide the plan and schedule of work (with timescales) to isolate Springsmire Reservoir from supply for a physical internal inspection (including clean and flood test) and to complete any required remedial work.
    Date: 31 May 2023
  4. Provide a report confirming and evidencing the completion of the internal inspection, flood test, clean and remedial work required.
    Date: 30 November 2023
  1. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
    Date: 31 July 2023
  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 measures of this Notice need 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. To include a report confirming and evidencing the completion of remedial work required and the subsequent return to supply of Springsmire Reservoir
    Date: 30 April 2024

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
12 April 2023
Reference: SST-2022-00001

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