Anglian Water Services Limited – Tank Inspections

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

Reference: ANH-2022-00005

Version Number: 2

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Anglian Water Services Limited, with registered number 02366656 (hereinafter called ‘the Company’).

Assets Affected:

Service reservoir and treated water storage tanks listed in Annex 1.

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 between 01 September and 01 October 2022, which state that there is or has been a significant risk of supplying water from service reservoirs and treated water storage tanks listed in Annex 1 (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 Multiple hazard lines e.g.:
Internal inspection/cleaning overdue	Total Coliforms	ANH-RAYL1-C001-ST0120; ANH-RATPB-C001-ST0120; ANH-RGGRF-C001-ST0120.
Internal inspection/cleaning overdue	E. coli	ANH-RAYL1-C002-ST0191; ANH-RATPB-C002-ST0191; ANH-RGGRF-C002-ST0191.
Internal inspection/cleaning overdue	Enterococci	ANH-RAYL1-C003-ST0210; ANH-RATPB-C003-ST0210; ANH-RGGRF-C003-ST0210.

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. Operate all tanks in accordance with current company policy, standards and procedures, that align to recognised standards of good practice.
   Date: Ongoing for the duration of this Notice
2. Maintain enhanced (in addition to statutory sampling) sampling for any tanks listed in Annex 1. This must include, as a minimum, colony counts, E. coli and coliforms.
   Date: Ongoing for the duration of this Notice
3. Maintain proactive external site inspections, grounds maintenance, site security and asset maintenance. This must include periodic inspections of hatches, seals, redundant assets, sample taps, overflows, washouts, and air valves.
   Date: Ongoing for the duration of this Notice
4. Maintain appropriate contingency plans (including liaison with relevant stakeholders as appropriate) to protect human health.
   Date: Ongoing for the duration of this Notice
5. 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

(b) To review, revise or make operational the following measures, by the dates specified in each case:

General

1. Develop a programme of works (that includes cleaning, robust ingression testing (e.g. flood/inundation) and completion of any tank remedial work required), using a risk-based approach, to carry out physical internal inspections of all tanks listed in Annex 1.
   Date: 28 February 2023
2. Review Annex 1 on at least an annual basis to ensure that all tanks that have not been cleaned and physically internally inspected in the last 10 years or more, are identified within the Annex. Update the regulation 28(1) risk assessment as appropriate.
   Date: Annually by 31 May
3. Within 3 months of the identification of a new tank requiring addition to Annex 1 (following a review completed under measure (b)2, update the programme of works (that includes cleaning, robust ingression (e.g. flood/inundation) testing and completion of any remedial work required) to include the physical internal inspections for the identified tank.
   Date: Annually by 31 August
4. Implement the programme of physical internal inspections developed in (b)1 (including any updates completed under measure (b)3) to completion. Maintain appropriate documentation of any remedial work completed.
   Date: Ongoing for the duration of the notice
5. Conduct a critical review of the effectiveness of the Company’s scheduling and delivery of internal inspections of tanks. Identify measures (as required) to address the findings of the critical review.
   Date: 31 March 2023
6. Implement the measures identified under (b)5 above.
   Date: 30 April 2023
7. Develop a risk-based approach to determine the cleaning and physical internal inspection frequency of all Company tanks, to include as a minimum:

• Time since last inspection
• Date of construction/age
• Materials of construction/ tank design
• Water quality history (to include as a minimum E. coli, coliforms and colony counts)
• Turnover and tank hydraulics
• Points of potential ingress (hatches, seals, redundant assets, overflows, washouts, and air valves)
• Sample tap conditions, tapping points, sample lines and material
• Any other risks related to individual tanks.
  Date: 31 March 2023

8. Implement the risk-based approach to cleaning and physical internal inspections of all tanks within the company’s supply area, developed under measure (b)7.
   Date: 30 April 2023

Internal Tank Inspection Procedure

9. Conduct a gap analysis of the company’s physical internal inspection and flood test procedures, including a review of how the company record and document remedial work identified and completed with the use of evidence (e.g. photographs before/after). The company should benchmark their procedure against industry good practice.
   Date: 31 May 2023
10. Update the company’s procedures based on the findings of the gap analysis completed under measure (b)9. 
    Date: 31 July 2023
11. Deliver training to all relevant staff on the updated procedures (as required in (b)11) for internal tank inspections and documenting evidence in internal inspection reports.
    Date: 30 November 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 the tanks listed in Annex 1, 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. Submit the programme of work for the physical internal inspection for tanks listed in Annex 1 as required under measure (b)1.
   Date: 31 March 2023
3. Submit a list of any newly identified tanks to be included in Annex 1, as required under measure (b)2. For any tanks listed in Annex 1, completed in advance of 30 April 2025, submit evidence demonstrating satisfactory completion of the internal inspection, ingression (e.g. inundation/flood) testing, and any remedial work completed with an accompanying regulation 28(1) report for the tank and an updated Annex 1 for this notice.
   Date: Annually by 30 June
4. Submit any updated programme of works for the physical internal inspection of any tanks identified under measure (b)2 (as required under measure (b)3).
   Date: Annually by 30 September
5. Outline the findings of the critical review and any resulting identified measures (measure (b)5).
   Date: 30 April 2023
6. Confirm and evidence completion of (b)6.
   Date: 31 May 2023
7. Outline the risk-based approach developed under measure (b)7.
   Date: 30 April 2023
8. Confirm implementation of the risk-based approach (measure (b)8).
   Date: 31 May 2023
9. Provide a summary report of the findings of the gap analysis and procedural review as required in measure (b)9.
   Date: 30 June 2023
10. Provide the updated procedures as required under measure (b)10.
    Date: 31 August 2023
11. Provide confirmation, including evidence, that all relevant staff have been trained on the updated procedures, as required in (b)11.
    Date: 31 December 2023
12. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
    Date: 30 April 2023
13. Submit any revisions of the audit strategy produced under measure (c)2.
    Date: Within 1 month of a revision
14. 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
15. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 30 April 2025

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
24 February 2023
Reference: ANH-2022-00005