South West Water Limited – Blackdown Service Reservoir Contamination Risk

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

Reference: BRL-2022-00003

Version Number: 1

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): South West Water Limited, with registered number 02366665 (hereinafter called ‘the Company’).

Assets Affected:

• Blackdown Service Reservoir (R011)

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 25 November 2021, which state that there is or has been a significant risk of supplying water from Blackdown Service 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 I D
Contamination of service reservoir due to ingress caused by flooding of the stream that runs parallel to the reservoir	Contamination	R011Hazard0108
Contamination of service reservoir due to ingress caused by flooding of the stream that runs parallel to the reservoir	Total Coliforms	R011Hazard0100
Contamination of service reservoir due to ingress caused by flooding of the stream that runs parallel to the reservoir	Enterococci	R011Hazard0102
Contamination of service reservoir due to ingress caused by flooding of the stream that runs parallel to the reservoir	E. coli	R011Hazard0101
Contamination of service reservoir due to surface water ingress into service reservoir	Contamination	R011Hazard0097
Contamination of service reservoir due to surface water ingress into service reservoir	Total Coliforms	R011Hazard0011
Contamination of service reservoir due to surface water ingress into service reservoir	Enterococci	R011Hazard0093
Contamination of service reservoir due to surface water ingress into service reservoir	E. coli	R011Hazard0012

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.

3. 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. Maintain regulatory and operational sampling for E. coli and total coliforms (weekly) at Blackdown Service Reservoir (SR). 
   Date: Ongoing for the duration of this Notice
2. Maintain an appropriate contingency plan for Blackdown SR to remove the tank from supply in the event of an emergency (including definition of an emergency).
   Date: Ongoing for the duration of this Notice
3. Operate Blackdown SR in accordance with company policy, standards and procedures, aligning with recognised standards of good practice. To include:

• Maintain proactive external inspections, grounds maintenance, site security and asset maintenance including periodic inspection of hatches, seals, redundant assets, sample taps, overflows, washouts, and air valves.
• Maintenance of suitable records of remedial work completed on all assets.
• Escalation of all issues that present a risk to water quality. 
• 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

1. Maintain weekly monitoring of the stream. Photographing and recording a reading from the stream gauge to assess the risk of inundation from the stream over the reservoir / under the roof membrane.
   Date: Ongoing for the duration of this Notice
2. Maintain quarterly monitoring of the stream, embankment and structural integrity of Blackdown SR to identify any signs of distress or cracking in the wall of the structure and escalate any required actions as appropriate.
   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. Award the full contract for the construction and installation of the chosen solution.
   Date: 30 April 2023
2. Develop a detailed design of the chosen solution.
   Date: 31 May 2023
3. Complete the construction, installation, testing and commissioning of the chosen solution.
   Date: 31 August 2023
4. Undertake a physical internal inspection, clean and flood test of Blackdown SR and complete any remedial work required.
   Date: 31 October 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 March 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 Blackdown Service 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. Confirm and evidence the award of the full contract for the construction of the chosen solution.
   Date: 31 May 2023
3. Provide the detailed design of the chosen solution.
   Date: 30 June 2023
4. Confirm and evidence the completion of construction, installation, testing and commissioning of the chosen solution.
   Date: 30 September 2023
5. Provide the internal inspection report for Blackdown SR to confirm completion of measure (b)4.
   Date: 30 November 2023
6. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
   Date: 30 April 2023
7. Submit any revisions of the audit strategy produced under measure (c)2.
   Date: Within 1 month of a revision
8. 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
9. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
   Date: 31 October 2024

Further Details of this Notice:

4. Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
5. 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.
6. 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
27 February 2023
Reference: BRL-2022-00003