South East Water Limited – Discolouration Risk
Notice under regulation 28(4) of the Water Supply (Water Quality) Regulations 2016 (as amended)
Reference: SEW-2023-00001
Version Number: 1
Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): South East Water Limited, with registered number 02679874 (hereinafter called ‘the Company’).
Assets Affected:
- Whole Company
Details of this Notice:
- 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 2022, which state that there is or has been a significant risk of supplying water from the Company’s water supply zones (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:
|
Description of Risk |
Hazard/ Hazardous Event/ Parameter |
|---|---|
|
Consumer acceptability and discolouration risk. |
Iron |
|
Manganese | |
|
Aluminium | |
|
Turbidity | |
|
Discolouration |
- 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:
- Undertake risk-based enhanced (in addition to routine regulatory sampling) sampling, for iron, turbidity, manganese and aluminium, from the high-risk water supply zones (identified under measure (b)8 and as updated under measure (b)14) and their associated assets, including from associated treatment works and reservoirs.
Date: Ongoing for the duration of this Notice - Maintain suitable response procedures to prescribed concentration or value exceedances (in regulatory or enhanced sampling) for iron, manganese, aluminium and turbidity. Respond to any such exceedances in accordance with the procedure and the relevant regulatory requirements.
Date: Ongoing for the duration of this Notice - Record and monitor customer contacts in appropriate detail and along with water quality data, keep under review to inform the forward programme of work.
Date: Ongoing for the duration of this Notice - Maintain suitable response procedures to consumer contacts relating to discoloured water and respond accordingly.
Date: Ongoing for the duration of this Notice - Deliver a programme of proactive and reactive flushing work in the Company’s distribution network, based on consumer contacts and discolouration risk.
Date: Ongoing for the duration of this Notice - Optimisation of existing treatment processes, with particular regard to the removal of aluminium, manganese, iron, turbidity and other parameters relevant to discolouration.
Date: Ongoing for the duration of this Notice - Optimisation of any water supply zone discolouration treatment processes.
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:
Phase 1 – AMP 7 targets
- Undertake a root cause analysis for Hockers Lane and Rushmoor Water Supply Zones to understand the risk of discolouration within these zones and the high discolouration (black/brown/orange) contact rate per 1000 population. This analysis must as a minimum include a review of the raw water risks, the supplying treatment works’ performance, network seeding (including in service reservoirs) and network condition.
Date: 30 November 2023 - Using the outputs from the root cause analysis (measure (b)1), develop bespoke mitigation plans (with timescales) for Hockers Lane and Rushmoor Water Supply Zones and associated upstream assets, to achieve the company’s AMP 7 target of 2 or less consumer contacts for discolouration per 1000 population (individually in each zone) by 31 March 2025.
Date: 30 November 2023 - Deliver the mitigation plans (created under measure (b)2) to its completion, to achieve 2 or less consumer contacts for discolouration per 1000 population by 31 March 2025 in Hockers Lane Water Supply Zone and Rushmoor Water Supply Zone.
Date: Commence by 01 February 2024 thereafter, ongoing until its completion by 31 March 2025 - Investigate and implement measures to achieve a company average (across all the company’s water supply zones) discolouration consumer contact rate of 0.5 per 1000 population by 31 March 2025.
Date: 31 March 2025
Phase 2 – AMP 8 targets
- Review and update procedures for investigating consumer contacts for discolouration, sample failures of parameters listed above and water quality discolouration events.
Date: 31 December 2023
- Review and revise, as appropriate, the current discolouration risk assessment methodology (including discolouration root-cause analysis) and the current discolouration strategy to reduce the risk of discoloured water in water supply zones. The strategy must be developed in conjunction with relevant stakeholders and aligned to recognised standards of good practise and current industry good practise. The strategy must cover discolouration risks from:
- treatment works (including optimisation of treatment processes and risk from catchment sources of discolouration related parameters);
- service reservoirs (including settled deposits) ;
- trunk mains; and
- the zonal network.
Date: 29th February 2024
- Using the updated risk assessment methodology and discolouration strategy (measure (b)7), identify an AMP8 target rate for high-risk water supply zones (‘the high-risk water supply zones’) for further investigation and update the appropriate regulation 27 risk assessments. This will need to be proposed to and agreed by the Inspectorate and be in line with the wider industry discolouration performance.
Date: 31 March 2024 - Undertake a root cause analysis for the high-risk water supply zones to understand the risk of discolouration within these zones and the level of discolouration contact rate per 1000 population.
Date: 31 October 2024 - Using the outputs from the root cause analysis (measure (b)8), develop bespoke programmes of works (with timescales) for the high-risk water supply zones to achieve the Phase 2 (AMP 8) target by 31 March 2030 (‘Phase 2 programmes of works’).
Date: 31 March 2025 - Commence, on a risk prioritisation basis, the Phase 2 programmes of works (created under measure (b)9 and as updated under measure (b)14) to their completion, to achieve AMP8 target by 31 March 2030 in the high-risk water supply zones.
Date: Commence by 01 April 2025 thereafter, ongoing until its completion by 31 March 2030 - Agree Phase 2 (AMP 8) target company average (across all the company’s water supply zones) discolouration consumer contact rate with the Inspectorate, in any case to be a maximum of 0.5 consumer contacts for discolouration per 1000 population by 31 March 2030.
Date: 31 March 2024 - Investigate and implement measures to achieve the agreed company average discolouration consumer contact rate target by 31 March 2030.
Date: Commence by 01 April 2025 thereafter, ongoing until its completion by 31 March 2030
Annual reviews
- From 2025, on an annual basis, review the Company’s discolouration high-risk water supply zones to identify any new zones of high discolouration risk and to assess the ongoing effectiveness of the Phase 2 programmes of works.
Date: From 2025 at least annually by 30 April (ongoing for the duration of the notice) - For any new high-risk water supply zones identified under measure (b)13, develop bespoke programmes of works (with timescales) for these zones to be included within the Phase 2 programmes of works, to achieve AMP8 target by 31 March 2030 in the high-risk water supply zones.
Date: 5 months following identification. - From 2025, on an annual basis, review and update, as necessary, the Company’s risk assessment methodology for discolouration and the Company’s discolouration strategy. These reviews must be completed in conjunction with relevant stakeholders and aligned to recognised standards of good practise and current industry good practise.
Date: From 2025 at least annually by 30 April (ongoing for the duration of the notice)
(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).
Date: Complete - 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 company’s assets, 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. - Submit the root cause analysis and mitigation plans for Hockers Lane and Rushmoor Water Supply Zones. Confirm commencement of the mitigation plans.
Date: 29 February 2024 - Submit a report outlining the mitigation completed in Hockers Lane and Rushmoor Water Supply Zones (measure (b)3), and across the company (measure (b)4). Outline evidence to show whether the company has met the Phase 1 targets.
Date: 31 May 2025 - Outline the review completed under measure (b)7 and provide the updated procedure.
Date: 31 January 2024 - Outline the reviews completed under measure (b)6 and provide the updated methodology and discolouration strategy.
Date: 31 March 2024, and from 2025 annually on 31 May - Identify the high-risk water supply zones. From 2025 also outline the ongoing effectiveness of the Phase 2 programmes of works.
Date: 30 April 2024, and from 2025 annually on 31 May - Outline the findings of the root cause analysis for the high-risk water supply zones (measure (b)9).
Date: 30 November 2024 - Provide the Phase 2 programmes of works developed under measure (b)9 and confirm commencement. Outline the company wide discolouration measures developed under measure (b)12 and confirm commencement.
Date: 30 April 2025 - Submit and agree with the Inspectorate the proposed Phase 2 target.
Date: 30 April 2024 - Provide any updates to the Phase 2 programmes of works developed under measure (b)14.
Date: As required - Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
Date: 30 September 2023 - 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 final completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
Date: 30 April 2031
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).
Signed
Nicholas Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
19 December 2023
Reference: SEW-2023-00001