South West Water Limited – Knapp Mill Water Treatment Works, Replacement Treatment Process
Notice under regulation 28(4) of the Water Supply (Water Quality) Regulations 2016 (as amended)
Reference: SWB-2021-00010
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:
- Knapp Mill Water WTW (T9200F)
- Knapp Mill Supply System (Y9200)
Details of this Notice:
- The Drinking Water Inspectorate (‘the Inspectorate’) has received multiple regulation 28(1) reports (of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’)) from the Company dated 22 January 2020 and 20 October 2020, which state that there is or has been a significant risk of supplying water from Knapp Mill Water Treatment Works (and associated assets as applicable) that could constitute a potential danger to human health or could be unwholesome.
- 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 raw water risk and potential risks generated by the treatment process:
|
Hazard/ Hazardous Event/ Parameter |
Hazard I Ds Multiple Hazard lines including: |
|---|---|
|
Colour |
7797 |
|
Algae |
7092 |
|
Geosmin |
7985 |
|
Taste |
7825 |
|
Odour |
7826 |
|
Total organic carbon (including dissolved organic carbon) |
7811 |
|
Disinfection by-products, including trihalomethanes |
7976 |
|
Pesticides |
7986 |
|
Oil/Fuel |
7904; 7975 |
|
Cryptosporidium |
7980 |
|
Colony Counts |
7981; 7823 |
|
E. coli |
7821 |
|
Enterococci |
7808 |
|
Total coliforms |
7982; 31756 |
|
Clostridium perfringens |
7834 |
|
Turbidity |
7827; 31246 |
|
pH (and resulting corrosivity effects) |
7824 |
|
Bromate |
7817 |
|
Manganese |
7913 |
- 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:
- Maintain contingency plans to protect human health in the event of a risk to human health associated with drinking water quality, which should include proactive liaison with local and regional public health officials.
Date: Following the completion of measure (b)3. onwards. - Monthly inspection of hatch integrity and remediation of any identified issues, for hatches over partially or fully treated water.
Date: Following the completion of measure (b)3. onwards. - Continue effective liaison with relevant stakeholders to allow appropriate response to upstream sewage events.
Date: Following the completion of measure (b)3. onwards. - Ongoing suitable maintenance inspections for treated or partially treated water storage tanks.
Date: Following the completion of measure (b)3. onwards. - Raw water continuous monitoring for ammonia, dissolved oxygen, conductivity, pH, turbidity, oil and colour, with suitable alarm triggers and response procedures in place.
Date: Following the completion of measure (b)3. onwards. - Undertake catchment management initiatives within the River Avon and Stour catchments, as outlined in the National Environment Programme.
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:
- Carry out a review of all potential pathways through which Cryptosporidium could enter source waters, with particular regard to upstream sewage assets.
Date: Complete - Complete sufficiently detailed design to enable the construction of an adequate treatment process (capable of mitigating the raw water challenge to replace the existing treatment process at Knapp Mill Water Treatment Works), to proceed. The design must also specify and justify any of the existing assets that are to be incorporated into the replacing treatment process.
Date: 31 August 2023 - Complete the planning, procurement, construction and installation of the chosen new/replacing treatment solution designed under (b)2. to enable wet process commissioning.
Date: 30 November 2025 - Commission the new/replacing treatment solution (providing wholesome water) into supply through a controlled blending scheme.
Date: Between 30 November 2025 and 31 March 2026 - Provide all treated water from Knapp Mill Water Treatment Works from the new/replacing treatment solution (to enable use as designed), and accordingly:
- Issue an updated Site-Specific Disinfection Policy and any associated site-specific procedures;
- Issue an updated Site Operating Manual and remove out-of-date material from circulation; and
- Complete training and sign-off of operators on the chosen treatment solution installed and the revised documentation listed above.
Date: 31 March 2026
- Undertake any necessary consumer engagement mitigation measures as determined on the basis of risk, to ensure consumer acceptability is maintained during and after the switch to the replacing treatment process. This must include the monitoring and review of consumer contacts during the blending phase (undertaken under measure (b)4.), with appropriate resulting actions taken to ensure consumer acceptability is maintained.
Date: Between 16 June 2022 and 31 March 2027
(c) To audit whether the measures have been effective by the following means:
- Define an audit strategy to monitor the effectiveness of the measures specified in sections (a) and (b). The audit strategy must include:
- Detailed specification of enhanced monitoring to be undertaken (parameters and frequencies);
- Ownership of the audit strategy (roles and responsibilities);
- Specified review of all monitoring data and resulting action; and
- Consumer acceptability.
Date: 31 August 2022
- 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 Knapp Mill Water Treatment Works, or not to so supply unless the specified conditions below are satisfied:
- 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:
- Provide a progress report annually.
Date: by 31 January each year. - Report summarising the review of Cryptosporidium pathways (measure (b)1.).
Date: Complete - Report outlining the chosen replacement or modified treatment process design. The report must also clearly outline and justify any existing assets that are to become part of the new treatment process (measure (b)2.).
Date: 30 September 2023 - Confirm the completion of the construction and installation of the chosen new/replacing treatment process (measure (b)3.) to allow for wet process commissioning to begin.
Date: 31 December 2025 - Confirm the new/replacing treatment process is solely in supply (measure (b)5.), associated updated documentation has been issued and necessary training completed.
Date: 30 April 2026 - Provide regular updates, through Company – Inspectorate liaison meetings, on any consumer engagement actions taken and monitoring of consumer contact levels. (measure (b)6.).
Date: Ongoing for the duration of the Notice - Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
Date: 30 September 2022 - Submit any revisions of the audit strategy produced under measure (c)2.
Date: Within 1 month of a revision - 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 - Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
Date: 30 April 2027
Further Details of this Notice:
- Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
- 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.
- 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).
Nicholas Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
16 June 2022
Reference: SWB-2021-00010