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Notice of Regulation: South West Water – Maintenance and Resilience Hazard Review

NOTICE UNDER REGULATION 28(4) OF THE WATER SUPPLY (WATER QUALITY) REGULATIONS 2016 (AS AMENDED)

South West Water Limited: Maintenance and Resilience Hazard Review of Water Treatment Facilities

Reference: SWB-2020-00002

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:
Water treatment works listed in Annex 1.

  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 on 15 June 2021, which state that there is or has been a significant risk of supplying water from water treatment works in the South West Water Ltd. supply region (and associated assets as applicable) that 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 hazards associated with:

Hazards

Hazard ID

No supply and subsequent specific hazards identified in measure (b) iv below will be listed for each treatment works and recorded in Annex 1 throughout the progression of the Notice.

Multiple Hazard lines for No Supply e.g.

1191

13007

1770

  1. The Company are required to satisfy the following:

Requirements

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

  1. Proactive maintenance and weekly reviews of asset failures by the field reactive maintenance team. Where asset failures are highlighted, these shall be escalated and discussed by the Senior Management Team. Where failures are deemed critical, remedial action shall be prioritised by the company.
    Date: Ongoing for the duration of this Notice
  2. Internal daily reporting of operational status and production issues.
    Date: Ongoing for the duration of this Notice
  3. Maintain a register of asset risk, with regular review and assessment.
    Date: Ongoing for the duration of this Notice
  4. Risk assessment of all planned maintenance operations and work, which are recorded and reviewed on a regular basis.
    Date: Ongoing for the duration of this Notice
  5. Adherence to company start-up and shutdown procedures.
    Date: Ongoing for the duration of this Notice
  6. Maintain central and personal logs of actions taken during water quality near-misses, incidents or events.
    Date: Ongoing for the duration of this Notice
  7. Maintain contingency plans to ensure drinking water quality and sufficiency can be maintained in the event of a risk associated with drinking water quality.
    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. Design a framework for the completion of site-specific hazard reviews of critical water treatment assets, to address asset failure and ensure a consistent approach to maintenance. This framework will be based on Drinking Water Safety Plan (DWSP) principles and will include:
    Date: 31 December 2021
    • a. A review of asset criticality and the risk of any single points of failure.
    • b. A review of critical asset performance, as defined in the company’s Maintenance and Resilience Methodology.
    • c. A review of critical site valves (to include condition, status, location and number).
    • d. A review of contingency plans at all sites covered by this notice.
    • e. A review of the use of alarm and shutdown systems, to identify any further remedial measures to both.
    • f. An appraisal of operational and maintenance tasks, including a review of the frequency of maintenance tasks, the scope of those tasks, the completion criteria and any remedial action required.
  2. Develop a process for the completion of assessment of raw water challenges/abstraction risks and appropriateness of treatment and control measures in place.
    Date: 31 December 2021
  3. Develop a plan, including timescales, for completing the site-specific reviews using the framework developed in (b)1. and process developed in (b)2. for each water treatment works (populate dates in Annex 1). The programmes should be kept under regular review and a risk-based approach should be used to determine the priority order of sites.
    Date: 31 March 2022
  4. Complete the programme of site-specific reviews in (b)3. for each treatment works.
    Date: 31 December 2025
  5. Following completion of the site-specific review at each water treatment works, as specified in (b)4., populate Annex 1 and the Site-Specific Review proforma with any residual risks identified, work required and dates for delivery.
    Date: Within six months of completion of each site specific review.
  6. Implement interim mitigation(s) where required to control any residual risks identified at each site reviewed in step (b)5. above, within a maximum of 12 months from the date of each site-specific review.
    Date: See Annex 1 for delivery dates.
  7. Implement permanent solution(s) for any residual risk identified by the date specified in Annex 1.
    Date: See Annex 1 for individual delivery dates and by 31 December 2025 for nonPR24 schemes.
  8. For any permanent solutions identified in (b)5., that are to be included in the Price Review 2024 (PR24) submissions, develop a risk-based quality enhancement programme of work detailing timescales for delivery.
    Date: 31 December 2022

(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 January 2022
  2. Implement, and keep under continuous review, the audit strategy defined in measure (c)1., and the company’s Maintenance and Resilience Methodology.
    Date: Following completion of measure (c)1. onwards

(d) not to supply water for regulation 4(1) purposes from all treatment works, 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 by 31 January and against the following milestones:
    Date: Annually by 31 January
    • a) Provide the methodology framework for site-specific hazard reviews, developed in measure (b)1.
      Date: 31 January 2022
    • b) Provide the process for the completion of assessment of raw water challenges/abstraction risks and appropriateness of treatment and control measures in place, developed in measure (b)2.
      Date: 31 January 2022
    • c) Populate Annex 1 to provide the riskbased plan for completing the sitespecific reviews, as described in measure (b)3.
      Date: 30 April 2022 and within one month of any riskbased revision of the plan.
    • d) Following completion of each sitespecific review, submit a summary report using the relevant proforma of the hazard review findings and populate Annex 1 with the relevant delivery dates. Ensure regulation 28(1) reports are kept up to date following each works site-specific review.
      Date: Six monthly submissions by 31 January and 31 July each year, commencing on 31 July 2022. Submission for each water treatment works site-specific review completed between 01 January to 30 June, and 01 July to 31 December each year.
    • e) Confirm completion of all water treatment works site-specific hazard reviews.
      Date: 31 January 2026
    • f) For sites where residual risks have been permanently mitigated (completion of (b)6.), submit a summary completion report providing evidence of implementation and commissioning of permanent mitigation(s) and evaluation against the audit strategy defined in (c)1. Include a revised Annex 1 with each summary report submission.
      Date: Six monthly submissions for the duration of this notice.
    • g) Provide the risk-based quality enhancement programme of work detailing timescales for delivery for any permanent solutions to be included in the PR24 submissions.
      Date: 31 January 2023
  2. Submit the strategy for auditing the effectiveness of the measures, as specified in (c)1.
    Date: 28 February 2022
  3. Submit any revisions of the audit strategy produced under measure (c)2., and/or any substantial revisions of the company’s Maintenance and Resilience Methodology.
    Date: Within 1 month of a revision.
  4. 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.
  5. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 31 January 2027 (date will be subject to change following (e)1. c) and (e)1. e) submissions).
  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
Nick Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
19 November 2021
Reference: SWB-2020-00002
Version 1

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