South East Water Limited – Burwash Water Supply Zone, Discolouration

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

Reference: SEW3582

Version Number: 5

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:

Asset Name	Reference
Burwash Water Supply Zone	Z009
Crowhurst Bridge Water Treatment Works	T032
Arlington and Crowhurst Bridge Supply Systems	Y029, Y032

Table 1: List of assets affected and associated reference numbers

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 01 September 2022 (and previously dated 01 January 2015), which states that there is or has been a significant risk of supplying water from Burwash Water Supply Zone (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
Consumer acceptability (discolouration)	Iron	Z009-DISTRIBUTION-A022 and T032-TREATMENT-A022
Consumer acceptability (discolouration)	Turbidity	Z009-DISTRIBUTION-A002 and T032-TREATMENT-A002
Consumer acceptability (discolouration)	Manganese	Z009-DISTRIBUTION-A023 and T032-TREATMENT-A023
Consumer acceptability (discolouration)	Aluminium	Z009-DISTRIBUTION-A021 and T032-TREATMENT-A021
Consumer acceptability (discolouration)	Discolouration	Z009-DISTRIBUTION-H057

Table 2: 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. Undertake risk-based enhanced (in addition to routine regulatory sampling) sampling to include:

• continuous monitoring for turbidity of the water leaving Crowhurst Bridge Water Treatment Works (WTW);
• enhanced monitoring of iron, manganese and turbidity following key treatment processes at Crowhurst Bridge WTW to assess the effectiveness of each process; and
• Enhanced monitoring for iron, manganese and turbidity throughout the Burwash Water Supply Zone (WSZ) on risk basis.
  Date: Ongoing for the duration of this Notice

2. 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
3. Continuation of the monthly review of the enhanced sampling completed under measure (a)1 results, to inform the programme of work and the on-going enhanced sampling programme.
   Date: On a monthly basis, ongoing for the duration of this Notice
4. Record and monitor customer contacts in appropriate detail and along with water quality data, keep under review to inform the programme of work.
   Date: Ongoing for the duration of this Notice
5. Maintain suitable response procedures to consumer contacts relating to discoloured water and respond accordingly.
   Date: Ongoing for the duration of this Notice
6. Continue the programme of risk-based proactive and reactive mains maintenance and cleaning in the Burwash WSZ, based on consumer contacts and discolouration risk.
   Date: Ongoing for the duration of this Notice
7. 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
8. Complete the inspection and cleaning of all service reservoirs within the Burwash WSZ (including all those supplied by Crowhurst Bridge WTW) at the Company defined frequency and in case, within every 10 years.
   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. Review and implement any necessary measures to optimise the SeaQuest dosing at Crowhurst Bridge WTW and maintain thereafter.
   Date: Complete
2. Investigation of the investment required to reduce discolouration risk in Three Cups, Punnets Town and Brightling Village DMAs.
   Date: Complete
3. Complete an investigation to identify and evidence the most appropriate interventions to reduce the risk of discolouration across the whole of the Burwash WSZ. The investigation must consider the impact of the historic and current elevated levels of iron and other relevant discolouration parameters leaving Crowhurst Bridge WTW and the potential sedimentation of iron within the downstream service reservoirs and network.
   Date: Complete
4. Develop a dynamic programme of work (‘the programme of work’) to reduce the risk of discolouration in the Burwash WSZ, informed by the findings from the measure (b)3 investigation, to achieve by 31 March 2025, a reduction in consumer contacts to 2 or less consumer contacts per 1000 population for discolouration (black/brown/orange) for the Burwash WSZ. Include within the programme of work, the required actions identified through measure (b)2.
   Date: Complete
5. Commence the programme of work (created under measure (b)4 and as updated under measure (b)6) to its completion by 31 October 2025 to achieve a reduction in consumer contacts to 2 or less consumer contacts per 1000 population for discolouration (black/brown/orange) for the Burwash WSZ.
   Date: Commence by 01 January 2024 thereafter, ongoing until its completion by 31 October 2025
6. Complete an annual review of the effectiveness of the programme of works and amend and update the programme accordingly.
   Date: Annually on 30 April
7. Complete a detailed review of the effectiveness of the iron, manganese, turbidity and aluminium removal treatment processes at Crowhurst Bridge WTW.
   Date: Complete
8. Implement measures to address the findings of the review completed under measure (b)7 to optimise the iron, manganese, turbidity and aluminium removal treatment processes at Crowhurst Bridge WTW.
   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).
   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 Burwash WSZ, 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. Report the findings of the SeaQuest optimisation review and any measure implemented as required under measure (b)1.
   Date: Complete
3. Provide findings of the investigation completed under measure (b)2.
   Date: Complete
4. Provide findings of the investigation completed under measure (b)3.
   Date: Complete
5. Provide the programme of work developed under measure (b)4 and confirm commencement of the programme of work (measure (b)5).
   Date: Complete
6. Submit any updates to the programme of work following the annual review completed under measure (b)6. Provide an evaluation of the programme of work impact since the previous annual update.
   Date: annually by 31 May
7. Report the effectiveness of the treatment processes at Crowhurst Bridge WTW review findings, as required under measure (b)7.
   Date: Complete
8. Confirm completion of measure (b)8.
   Date: Complete
9. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
   Date: Complete
10. Submit any revisions of the audit strategy produced under measure (c)2.
    Date: Within 1 month of a revision
11. 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
12. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 30 November 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
16 July 2024
Reference: SEW3582 v5