Southern Water Services Limited – Ground Water Treatment Works HazRev

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

Reference: SRN3926

Version Number: 6

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’).

Assets Affected:

• All groundwater treatment works in the Southern Water supply area.

Details of this Notice:

1. The Drinking Water Inspectorate (‘the Inspectorate’) has received a regulation 28(1) report of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’) from the Company dated 17 October 2019, which states that there is or has been a significant risk of supplying water from Ground 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
Pathogenic bacteria ingress route and failure of treatment process	E. coli	For example: 43790
Pathogenic bacteria ingress route and failure of treatment process	Enterococci	For example: 43791
Pathogenic Protozoa breakthrough presenting risk to public health	For Example: Cryptosporidium	For example: 43786
Increasing nitrate in source waters	Nitrate	For example: 43811
Insufficient water supply to downstream consumers	No Supply	For example: 43845, 43846, 43847
Failure of treatment poses risk to wholesomeness	Lead	For example: 43822
Failure of treatment poses risk to wholesomeness	Hydrocarbons e.g. PAH	For example: 43839
Discolouration in downstream network	For example: Manganese, Iron	For example: 43829, 43828
Failure of treatment poses risk to wholesomeness	Other chemical public health	For example: 43844
Compromised disinfection process	Turbidity	For example: 70083
Treatment by-products	Tetrachloromethane	For example: 43832
Failure of treatment poses risk to wholesomeness	Pesticides (e.g. Aldrin)	For example: 43806
Failure of treatment poses risk to wholesomeness	Taste	For example: 43837
Failure of treatment poses risk to wholesomeness	Odour	For example: 43838

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. Ensure all water quality related, scheduled operational and maintenance tasks are carried out at the current prescribed schedule.
   Date: Ongoing for the duration of this Notice
2. Ensure that any new risk identified is assessed in accordance with the drinking water safety plan methodology.
   Date: Ongoing for the duration of this Notice
3. Ensure that treatment works start-up protocols are followed when restarting each site.
   Date: Ongoing for the duration of this Notice
4. Ensure that the existing site specific disinfection policies are annually reviewed and kept up to date with existing alarm and shutdown levels.
   Date: Ongoing for the duration of this Notice
5. Ensure the treatment works control and shutdown systems are operational and that all monitors are calibrated at the predefined frequencies.
   Date: Ongoing for the duration of this Notice
6. Continue to track borehole headworks condition and risk via the borehole headworks database and drinking water safety plan.
   Date: Ongoing for the duration of this Notice
7. Use site specific procedures where appropriate, including manual intervention or run to waste.
   Date: Ongoing for the duration of this Notice
8. Issue advice to consumers, where required, of improperly disinfected water.
   Date: Ongoing for the duration of this Notice
9. Provide bi-monthly updates at transformation meetings on progress of actions to include predicted float, actions completed to date and any major changes in delivery.
   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:

1. Carryout mitigation of regulatory risk statements as identified in Appendix A:
   a) Completion of all Phase 1 actions as detailed in appendix A.
   Date: Complete
   
   b) Completion of all Phase 2 actions as detailed in appendix A.
   Date: Complete
   
   c) Commission all Phase 1 and Phase 2 as detailed in appendix A.
   Date: Complete
   
   d) Completion of all Phase 1A, 2A and 3 actions as detailed in appendix A.
   Date: Complete
   
   e) Commission all Phase 1A, 2A and 3 actions as detailed in appendix A.
   Date: Complete
   
   f) Completion of all Phase 2B, 3A and 4 actions as detailed in appendix A.
   Date: 30 March 2024
   
   g) Commission all Phase 2B, 3A and 4 actions as detailed in appendix A.
   Date: 30 September 2024
   
   h) Completion of all Phase 4A, 5 and 6 actions as detailed in appendix A.
   Date: 31 March 2025
   
   i) Commission all Phases 4A, 5 and 6 actions as detailed in appendix A.
   Date: 30 September 2025
   
2. Put in place interim mitigation for Lower risk severity regulatory risk statements as identified as Phase 6.
   Date: Complete
3. Provide confirmation of dates for completion of solutions for Lower risk severity regulatory risk statements as identified as Phase 6.
   Date: Complete

(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). To include confirmation of works completion at each Phase, an annual audit of operator and maintenance tasks completed at each works
   Date: Complete
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 Groundwater 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 report detailing interim mitigation in place for Lower risk severity regulatory risk statements (Phase 6) as specified in (b)2.
   Date: Complete
3. Provide a report confirming the dates of completion for solutions for Lower risk severity regulatory risk statements (Phase 6) as specified in (b)3.
   Date: Complete
4. Provide a report confirming completion of all Phase 1 and 2 actions.
   Date: Complete
5. Provide a report confirming commissioning of all Phase 1 and 2 actions.
   Date: Complete
6. Provide a report confirming completion of all Phase 1A, 2A and 3 actions.
   Date: Complete
7. Provide a report confirming commissioning of all Phase 1A, 2A and 3 actions.
   Date: Complete
8. Provide a report confirming completion of all Phase 2B, 3A and 4 actions.
   Date: 31 April 2024
9. Provide a report confirming commissioning of all Phase 2B, 3A and 4 actions.
   Date: 31 October 2024
10. Provide a report confirming completion of all Phase 4A, 5 and 6 actions.
    Date: 30 April 2025
11. Provide a report confirming commissioning of all Phase 4A, 5 and 6 actions.
    Date: 31 October 2025
12. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
    Date: Complete
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: 31 October 2026

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

Nick Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
18 April 2024
Reference: SRN3926 v6