Notice of Regulation: Southern Water – Service Reservoir Integrity

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

NOTICE UNDER REGULATION 28(4)

Southern Water Services Ltd: Service Reservoir Integrity

All service reservoirs, break pressure tanks, water towers and contact tanks.

Legal Instrument Database Reference number: SRN3923

THE SECRETARY OF STATE:

1. has on 20 October 2017 received a set of reports from Southern Water Services Ltd. (the “Company”) dated with various dates (the “Reports”) which state that there is or has been a significant risk of supplying water from treated water storage vessels (contact tanks, break pressure tanks, water towers and service reservoirs) that could constitute a potential danger to human health.
2. GIVES NOTICE to the Company under regulation 28(4) of the Water Supply (Water Quality) Regulations 2016 that it must satisfy the following requirements:

For risks associated with:

• Bacteria and parasites due to the risk of ingress of surface water through the structures.
• Loss of supplies.

Requirements

(a) to maintain the following measures for the period specified.

1. Continue to undertake scheduled Southern Water operator site inspections of treated water storage assets.
   Date: Ongoing for the duration of the Notice.
2. Continue to undertake grounds maintenance at the standard frequency.
   Date: Ongoing for the duration of the Notice.
3. Continue to externally flood test and internally inspect treated water storage assets according to Southern Waters current reservoir programme.
   Date: Ongoing for the duration of the Notice.
4. Continue to monitor treated water storage levels via the Southern Water Regional Control Centre.
   Date: Ongoing for the duration of the Notice.
5. Continue to carryout maintenance tasks in accordance with Southern Water standards.
   Date: Ongoing for the duration of the Notice.
6. Continue to sample treated water storage assets to check compliance at the frequency defined by the annual Southern Water Sampling Programme.
   Date: Ongoing for the duration of the Notice.

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

1. Develop a programme of work to ensure all treated water storage assets (water service reservoirs, water towers, break pressure tanks and contact tanks) are internally inspected and flood tested on a risk assessed basis where any asset that fails a microbiological standard is prioritised immediately and the remainder at a maximum frequency of assessment of 10 years inspection frequency.
   Date: Complete
2. Identify and keep under continuous review those assets that cannot be internally inspected and flood tested by the end of March 2020.
   Date: Complete
3. Undertake a gap analysis of sampling facilities at water treated water storage structures against the regulatory requirements for representativeness and produce and develop a programme of work including a phased risk based priority list for replacement or renovation.
   Date: Complete
4. Review company procedure for flood testing with industry good practice.
   Date: 30 June 2018
5. Produce and implement a new company standard for flood testing.
   Date: 30 September 2018
6. Produce a new company asset standard for sampling facilities at treated water storage assets.
   Date: 30 September 2018
7. Produce a new company standard for grounds maintenance at treated water storage assets.
   Date: 30 September 2018
8. Complete the internal inspection and flood testing of all treated water storage assets identified as being removable from supply in AMP6 as per the programme of work in step (b)1 and undertake all remedial measures necessary to ensure the integrity of the asset.
   Date: 31 March 2020
9. Complete phase 1 and 2 of the sampling facility improvements in accordance with the priority list defined in Step (b)3 ensuring that the new and/or renovated sampling facilities are compliant with the new company asset standard described in Step (b)6.
   Date: 31 March 2020
10. Plan and undertake enabling works to remove the remaining treated water storage assets from supply for inspection and flood testing.
    Date: 31 March 2024
11. Complete the inspection and flood testing on a risk assessed basis and where necessary, complete remedial works at the treated water storage assets previously un-removable from supply as described in step (b)2 achieving a maximum 10 year inspection frequency for all water service reservoirs, water towers and break pressure tanks.
    Date: 31 March 2025
12. Produce and implement a refined risk based programme of inspection and flood testing to ensure all treated water storage structures are inspected and flood tested as far as is practicable at a maximum frequency of 5 years where the risk is low, moving to a 3 and 1 year frequency of inspections where the risk is medium and high respectively. Keep this programme under continuous review taking into account network and water resources constraints.
    Date: 31 December 2025
13. Upon the discovery of active ingress into any treated water storage assets;
    Date: For the duration of the notice
    • Implement immediate short term mitigation measures to ensure public health is protected.
    • Remove the asset from supply and complete the required remedial works.
    • Where the company are unable to meet part (b)13, devise and implement a solution to remove the asset from supply at the earliest opportunity.

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

1. Define an audit strategy which includes;Date: Complete
   • A monthly water quality performance report for each treated water storage asset including average daily volume, average daily flow, daily hourly flow, total viable count, chlorine and coliform trends.
   • A rolling programme of sampling facility audits to ensure hygienic conditions are maintained, with a monthly report produced on all nonconformities identified.

(d) 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 the new company flood testing standard and a report detailing where any changes to the existing protocol have been made.
     Date: 31 October 2018
   • Provide a report detailing the programme of work to ensure all treated water storage assets (water service reservoirs, water towers and break pressure tanks) are internally inspected and flood tested at a 10 year inspection frequency. In addition, identify those assets that cannot be in internally inspected and flood tested by the end of AMP6.
     Date: 30 April 2018
   • Provide a report detailing the high level programme of work for the phased replacement or renovation of sampling facilities at treated water storage assets.31 July 2018
   • Provide a report detailing the audit strategy.
     Date: Complete
2. Where ingress has been found and the company are unable to take the asset out of supply immediately, the company shall submit an action plan to detail how the company intends to mitigate the risks associated with ingress in the medium to long term.
   Date: As required for the duration of the notice, within 2 months of discovering ingress.
3. Review the risk assessment for all treated water storage tanks as required by Regulation 27(3) and subsequently submit a revised regulation 28 report accompanied by a signed board level declaration.
   Date: As required, for the duration of the Notice and within 2 months of completion of all work.
4. Submit a satisfactory completion report.
   Date: 31 December 2026

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Failure by the Company to comply with this Notice may result in enforcement proceedings under section 18 of the Act.

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Signed by authority of the Secretary of State
Milo Purcell
Deputy Chief Inspector
2 October 2018
DWI ref: SRN3923
Version 2