Enforcement Order – Section 18 of the Water Industry Act 1991
Southern Water Services Limited
Reference: SRN-2022-00010 Hardham FEO
Version Number: 1
Water undertaker as appointed under section 6 of the Water Industry Act 1991: Southern Water Services Limited, with registered number 02366670 (hereinafter called ‘the Company’).
Details of this Order:
- The Company has failed to carry out the steps identified in the regulation 28(4) notice served on it.
- The Company was notified on 13 January 2023 about the Inspectorate’s intention to make an enforcement order under section 18 of the Act in respect of contraventions of regulation 28(4)(b) of the Water Supply (Water Quality) Regulations 2016 (‘the Regulations’).
- The Inspectorate has considered any representations or objections to the proposed order, which were duly made and not withdrawn.
- The Chief Inspector of Drinking Water makes this enforcement order under section 18(1) of the Act for the purposes of securing compliance with requirements imposed under regulation 28(4) of the Regulations.
Requirements:
- The Company is hereby required to complete the steps and reporting outlined in the attached Schedule of Works with effect from the day after this order is made.
Signed
Marcus Rink
Chief Inspector of Drinking Water on behalf of the Secretary of State for Environment, Food and Rural Affairs
20 February 2023
Reference: SRN-2022-00010
Schedule of Works
Southern Water Services Limited
Date: 20 February 2023
Reference: SRN-2022-00010
Version Number: 1
Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Southern Water Services Limited, with registered number 02366670 (hereinafter called ‘the Company’
Water Treatment Works and Connected Supply System
- Sussex North – Y008
Steps to be taken
The Company is required to implement the following steps by the date given in each case.
Steps to be maintained for the duration of the order
1. Continually review and optimise the clarifier desludging process.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
2. Create and follow site specific operating plan for filter backwashes, including visual checks of backwashes.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
3. Document and implement works restart operating plan to ensure compliant site restarts.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
4. Enhance the frequency of interstage sampling to enable more granular monitoring and optimisation of the treatment process.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
5. Enhanced monitoring (as a minimum 3 times per week) for Cryptosporidium in the raw and treated water.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
6. Enhanced monitoring for coliforms and E. coli in the treated water supplied.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
7. Establish a standard emergency safe operating plan including minimum SSDP requirements for periods when the raw water turbidity challenge is such that normal operating limits are unachievable.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
8. Establish and maintain an action plan in the event of a microbiological detection in the water supplied from the site.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
9. Establish and maintain in place until improvement works are completed such enhanced operational measures as necessary to ensure that consumers are protected and water supplied from the site is adequately treated and wholesome.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
10. Liaise with Public Health England and local authorities in the event of any breach of a health based standard.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
11. Maintain and operate existing works treatment in accordance with WSW site specific maintenance schedule and Routine Site Task Lists.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
12. Monitoring on a weekly frequency for animalcules in the treated water.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
13. Produce a daily working weekday trends review in accordance with WSM 202.06 to flag all risks and potential opportunities for process optimisation.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
14. Review the rapid gravity filter trends on a daily basis during the working week only, investigate and resolve any unusual trends.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
15. Undertake jar tests to inform coagulant dose requirements at a frequency which is commensurate with treatment changes.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
16. Validate dosing flow monitoring at a frequency commensurate with treatment changes and as a minimum in line with manufacturer’s instructions.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
17. Ongoing enhanced monitoring of alpha gross radiation at the raw and treated water at Hardham Water Supply Works.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
18. Ongoing enhanced monitoring of indicative dose as required.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
19. Maintain or implement suitable operational measures at Hardham Water Treatment Works to ensure adequate chlorine contact time is met at all times and that water that is not compliant with the requirements of regulations 4 and 26 is prevented from entering supply.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
20. Continuous on-line chlorine and turbidity monitoring which is linked to appropriate alarms and integrated failsafe shutdown mechanisms.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
21. Ongoing enhanced monitoring of final water turbidity.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
22. Automated treatment works shutdown for high turbidity.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
23. Divert dirty wash water from the head of the works to discharge when it is at risk of causing elevated turbidity in the treatment process.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
24. Operational treatment blending plans for raw water sources to be implemented and monitored at all times to ensure wholesomeness is maintained at the final sample point.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
Steps to review, revise or make operational
25. Radioactivity (gross alpha): Complete a review of the risk of radioactivity (gross alpha) at Hardham WTW. This must include
a) Speciation Sampling of raw water and assessment of the associated total indicative dose for the potential to breach the prescribed concentration.
Date: Complete
b) If required, undertake seasonal sampling for relevant radioactivity parameters.
Date: Complete
c) An investigation into the source of radiation (artificial or natural).
Date: Complete
26. Following the completion of step 25(a) to 25(c) above, investigate options to mitigate any identified risks. This may include an investigation into the effectiveness of the water treatment process at removing radioactivity.
Date: Complete
27. Implement any required steps, as identified under step 26 above to mitigate any radioactivity risk (as identified under step 25).
Date: Complete
28. Groundwater Abstraction: Complete the programme of works to mitigate risks associated with Groundwater Abstraction, to include
a) Reinstate raw water cryptosporidium monitoring to establish the risk.
Date: Complete
b) Review the raw water cryptosporidium monitoring data generated by monitors installed for step 28(a) above to assess if further treatment is required on site.
Date: Complete
c) Refurbish headworks of boreholes 6, 10 and 12 and ensure all boreholes have appropriate sanitary seals).
Date: 31 March 2025
d) Address issues with deployable output constraints experienced at all boreholes due to infill.
Date: 30 September 2027
29. River Rother Abstraction: Complete the programme of works to mitigate risks associated with Groundwater Abstraction, to include
a) Replace all obsolete raw water quality analysers, at the river intake.
Date: 31 May 2027
b) Commission all replaced raw water quality analysers, at the river intake.
Date: 30 September 2027
c) Remove the silt from within the River Rother intake structure.
Date: 31 March 2025
d) Investigate risk of PLC Failure of River Rother Low Lift Pump Station MCC 06 and scope remedial works to mitigate risk of PLC failure.
Date: 30 September 2025
e) Undertake remedial works to mitigate risk of PLC Failure in MCC 06.
Date: 30 April 2028
f) Commission remedial works to mitigate risk of PLC Failure.
Date: 30 September 2028
30. Ozone: Complete the programme of works to mitigate risks associated with Ozone, to include
a) Replace ozone diffusers and clean ozone contact tank.
Date: Complete
b) Replace residual ozone monitors.
Date: Complete
c) Refurbish ozone generator 2.
Date: Complete
d) Replace ozone and GAC PLCs
Date: Complete
31. Clarification: Complete the programme of works to mitigate risks associated with Clarification, to include
a) Install leak detection on coagulation PACL dosing lines and integrate into SCADA and clarifier PLC.
Date: Complete
b) Replace post clarifier turbidity monitors.
Date: Complete
c) Replace and relocate clarifier coagulation polymer dosing pumps.
Date: 31 January 2025
d) Commission coagulation polymer dosing pump.
Date: 31 March 2025
e) Carry out detailed structural survey to establish required remedial works to clarifiers.
Date: 31 July 2026
f) Carry out remedial actions arising from step 31(e) above.
Date: 31 July 2027
g) Commission remedial actions arising from step 31(f) above.
Date: 30 September 2027
32. Rapid Gravity Filtration: Complete the programme of works to mitigate risks associated with Rapid Gravity Filtration, to include:
a) Replace post RGF turbidity monitors.
Date: Complete
b) Investigate risk of RGF MCC 03 failure and scope mitigation.
Date: 30 September 2025
c) Investigate risk of RGF PLC failure and scope remedial works to mitigate risk of PLC failure.
Date: 30 September 2026
d) Undertake remedial works required from step 32(b) and 32(c).
Date: 31 May 2028
e) Commission remedial works required from step 32(b) and 32(c).
Date: 30 September 2028
f) Cover the RGF inlet channel.
Date: 31 January 2025
g) Replace RGF flow control valves with fit for purpose valves and actuators.
Date: 31 May 2027
h) Commission works associated with steps 32(f) and 32(g).
Date: 30 September 2027
i) Complete a condition survey and assessment of all RGF cell media and determine improvement requirements and provide scope of works.
Date: 31 March 2024
j) Complete and commission RGF Media improvement works as defined in step 32(i).
Date: 31 March 2027
k) Investigate RGF Backwash tank capacity and scope any requirements to mitigate risks associated with capacity.
Date: 30 September 2025
l) Complete and commission works as defined by scope of step 32(k).
Date: 30 September 2028
33. Granular Activated Carbon adsorbers (Part A): Complete the programme of works to mitigate risks associated with Granular Activated Carbon (Part A), to include:
a) Complete condition assessment of GAC MCC to determine operational maintenance requirements.
Date: Complete
b) Increase GAC media volume in line with the required empty bed contact time, including all necessary enabling works.
Date: 31 March 2027
c) Replace GAC flow control valves and actuators.
Date: 30 November 2026
d) Complete monitoring and control modifications to incorporate differential pressure and turbidity backwash triggers to GAC system.
Date: 30 November 2026
e) Complete commissioning of all actions associated with the GAC adsorbers as outlined above in steps 33(a) to 33(d).
Date: 31 March 2027
34. Granular Activated Carbon adsorbers (Part B): Complete the programme of works to mitigate risks associated with Granular Activated Carbon (Part B), to include:
a) Complete an assessment of the under-floor area to GAC adsorbers 1, 2, 3, 4 and 6.
Date: 31 March 2027
b) Replace GAC nozzles.
Date: 31 March 2027
c) Following the completion of the assessment of under-floor area to GAC adsorbers 1, 2, 3, 4 and 6, complete any necessary remedial works.
Date: 30 November 2028
d) Complete commissioning and handover of all actions associated with the GAC adsorbers as outlined above in steps 34(a) to 34(c).
Date: 30 November 2029
35. Disinfection: Complete the programme of works to mitigate risks associated with Disinfection, to include:
a) Investigate solution to ensure that the contact tank at Hardham Water Treatment Works is not used for blending with other supplies.
Date: Complete
b) Following the completion of step 35(a) above, produce a detailed design (including timescales for completion) to mitigate the identified risk as appropriate.
Date: Complete
c) Implement any required steps as identified under step 35(b) to mitigate the identified risk as appropriate.
Date: Complete
d) Update the site-specific disinfection policy for Hardham Water Treatment Works following the completion of step 35(c) to demonstrate unequivocally how disinfection is met at the works.
Date: Complete
e) Complete a survey of main dose chlorine analysers and develop solution to ensure representative monitoring.
Date: Complete
f) Carry out a Regulation 31 inspection of service water system and post contact tank connections and complete remedial actions.
Date: Complete
g) Review and complete design for a rationalisation of service and motive water systems.
Date: 31 March 2025
h) Upgrade service and motive water system to meet site chemical dosing systems’ capacity requirements and have sufficient backflow protection.
Date: 30 November 2026
i) Commission service and motive water system.
Date: 31 March 2027
36. Disinfection, Flow Control: Complete the programme of works to mitigate risks associated with Disinfection, Flow Control, to include:
a) Develop a contingency plan for control valve failure.
Date: Complete
b) Complete inspection of the flow control valve between the clear water tank and the high lift pumps. Provide scope of remedial steps.
Date: 30 September 2025
c) Complete suitable remedial steps as outlined in step 36(b).
Date: 31 May 2027
d) Commission suitable remedial steps as outlined in step 36(b).
Date: 30 September 2027
37. Orthophosphate dosing: Replace control panel with potential relocation to new kiosk.
Date: 30 November 2025
38. Orthophosphate dosing: Complete commissioning of the control panel as installed in step 37.
Date: 31 March 2026
39. Run to Waste Complete the programme of works to mitigate risks associated with Run to Waste, to include:
a) Install treated water run to waste.
Date: 31 May 2027
b) Commission treated water run to waste.
Date: 30 September 2027
40. Sludge Handling: Complete the programme of works to mitigate risks associated with Sludge Handling, to include:
a) Rectify the identified deficiencies with the centrifuge.
Date: Complete
b) Design solution for polymer mixing facility.
Date: 31 March 2024
c) Install and commission solution for polymer mixing facility.
Date: 30 September 2024
41. Site Control and Data Acquisition (SCADA): Upgrade site SCADA system capacity to cover all asset needs on site.
Date: 31 May 2030
42. Site Control and Data Acquisition (SCADA): Complete commissioning of site SCADA system upgrades to cover all asset needs on site
Date: 30 September 2030
43. Water Quality Shutdown: Replace the HMI in the WQSD panel with a higher capacity unit.
Date: Complete
44. High Lift Pumps: Complete the programme of works to mitigate risks associated with High Lift Pumps, to include.
a) Installation of a new substation and a new switchboard for new High Lift Pumps.
Date: Complete
b) Decommissioning of current switch gear.
Date: Complete
c) Replacement of high voltage pumps and switch gear with low voltage equivalents.
Date: Complete
d) Replacement of the Variable Speed Drives and associated control systems.
Date: Complete
45. Power and Resilience: Complete the programme of works to mitigate risks associated with Power and Resilience, to include:
a) Carry out risk assessment investigation for the recommendations from the HazOps report, providing likelihood and severity of risks. Provide programme of works and timeframe for completion.
Date: 31 January 2023
b) Confirm completion of high priority works in programme from step 45(a).
Date: 31 May 2030
c) Commission high priority works in programme from step 45(a).
Date: 31 May 2031
Steps to audit the effectiveness of steps completed
46. Define an audit strategy to monitor the effectiveness of the steps specified above.
Date: One month from date order is made.
47. Implement, and keep under continuous review, the audit strategy defined in step 46.
Date: Following completion of step 46 onwards.
Reporting
Provide the Inspectorate with the following reports as specified.
1. Provide a progress report annually.
Date: by 31 January each year.
2. At regular intervals, provide the Inspectorate with reports on progress made with carrying out the steps set out in the Action Plan.
Date: Bi-annually, on last day of May and November for the duration of the Order.
3. Submit a report establishing short term mitigation measures required for duration of this Order as per step 9.
Date: 31 March 2023
4. Submit the audit strategy for auditing the effectiveness of the steps
Date: Two months from date order is made.
5. Submit any revisions of the audit strategy.
Date: Within 1 month of a revision
6. Submit a report in the event that any completed steps of this Order need to be altered in any way, for any reason.
Date: As soon as reasonably practicable after being made aware and in any case, within one month; ongoing for the duration of the order
7. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
Date: 31 January 2032