Sutton and East Surrey Water Plc – Tank Inspection Contamination Risk

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

Reference: SES-2022-00001

Version Number: 1

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Sutton and East Surrey Water Plc, with registered number 02447875 (hereinafter called ‘the Company’).

Assets Affected:

• TWWD – Westwood Water Treatment Works
• Y09 – Kent Hatch Supply System
• TKTW – Kenley Water Treatment Works
• Y02 – Caterham Supply System
• Y18 – How Green Supply System
• Y12 – Tillingdown Supply System
• Y14 – Warlingham Supply System
• TETW – Elmer Treatment Works
• Y01 – Alderstead Supply System
• Y05- Effingham Supply System
• Y07- Highlands Farm Supply System
• Y11- Salfords Supply System
• Y13- Dorking Supply System
• Y16- Betchworth Supply System
• Y17- Burgh Heath & Margery Supply System
• Y25- Headley Supply System

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 21 October 2021 and 21 January 2022, which state that there is or has been a significant risk of supplying water from Westwood, Kenley and Elmer water treatment works (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
Poor hygiene / contamination by persons on-site.	Microbiological	TWWD-TT080 TKTW-TT100 TETW-TT101
Structural / asset failure	Microbiological	TWWD-TT060 TKTW-TT080 TETW-TT081
To address the risk of ingress contamination and microbial growth.	E. coli	TWWD-TR001 TKTW-TR001 TETW-TR001
To address the risk of ingress contamination and microbial growth.	Enterococci	TWWD-TR002 TKTW-TR002 TETW-TR002
To address the risk of ingress contamination and microbial growth.	Total Coliforms	TWWD-TR003 TKTW-TR003 TETW-TR003

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 is 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 existing sampling programme (in addition to routine regulatory sampling) for the tanks covered by this notice.
   Date: Ongoing for the duration of this notice
2. Maintain proactive external site inspections, grounds maintenance, site security and asset maintenance and keep appropriate records. This must include periodic inspections of hatches, seals, redundant assets, sample taps, overflows, washouts, air valves and animal activity on site.
   Date: Ongoing for the duration of this notice
3. Maintain appropriate contingency plans for Westwood, Kenley and Elmer works (including liaison with relevant stakeholders as appropriate) 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:

General

1. Conduct a gap analysis of the company’s physical internal inspection procedure and flood testing procedure benchmarking against industry good practice. 
   Date: 31 March 2023
2. Update the company’s procedures based on the findings of the gap analysis completed under measure (b)1.
   Date: 30 September 2023
3. Conduct a gap analysis of the company’s Operational Risk Assessment (ORA) procedure and Method statement procedure, benchmarking against industry good practice.
   Date: 31 March 2023
4. Update the company’s procedures based on the findings of the gap analysis completed under measure (b)3.
   Date: 30 September 2023

Westwood Water Treatment Works (treated water tank and contact tank)

1. Develop a plan and programme of works to improve the resilience at Westwood water treatment works.
   Date: 31 December 2022
2. Implement the plan and programme of works specified in (b)5. to completion. Ensure any newly installed equipment is commissioned and fully operational.
   Date: 31 March 2025

Kenley Water Treatment Works (contact tank and treated water pump sump)

1. Develop a plan and programme of works to improve the resilience at Kenley water treatment works.
   Date: 31 December 2022
2. Implement the plan and programme of works specified in (b)7. to completion. Ensure any newly installed equipment is commissioned and fully operational.
   Date: 31 March 2025

Elmer Water Treatment Works (contact tank)

1. Develop a plan and programme of works to improve the resilience at Elmer water treatment works.
   Date: 31 December 2022
2. Implement the plan and programme of works specified in (b)9. to completion. Ensure any newly installed equipment is commissioned and fully operational.
   Date: 31 March 2025

(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 December 2022
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 Westwood Water Treatment Works or Kenley Water Treatment Works or Elmer 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.
   Date: by 31 January each year.
2. Provide a summary report of the findings of the gap analysis of the company’s physical internal inspection procedure and flood test procedure, as required in measure (b)1 and the findings of the gap analysis into the company’s ORA and Method statement procedures as required in measure (b)3. 
   Date: 30 April 2023
3. Provide the company’s updated internal inspection and flood testing procedures as required in (b)2 and the updated ORA and method statement procedures as required in (b)4.
   Date: 31 October 2023
4. Provide the plan and programme of works, as specified in (b)5., (b) 7. and (b) 9.
   Date: 31 January 2023
5. Confirm completion of the resilience improvements at Westwood, Kenley and Elmer water treatment works, as specified in (b)6, (b)8 and (b)10. Provide evidence confirming completion, including updated / new procedures, updated training records, and confirmation of how long Westwood contact tank and treated water tank, Kenley contact tank and treated water pump sump and Elmer contact tank can be removed from supply for with no impact on downstream resilience.
   Date: 30 April 2025
6. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
   Date: 31 January 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: 30 April2026

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
01 November 2022
Reference: SES-2022-00001 (V1)