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Notice of Regulation: Severn Trent Water – Service Reservoir Inspection Improvements

Completion Date: 28/02/2024
Ref: SVT-2020-00008

NOTICE UNDER REGULATION 28(4) OF THE WATER SUPPLY (WATER QUALITY) REGULATIONS 2016 (AS AMENDED)

Severn Trent Water Limited: Service Reservoir Inspection Improvements

Reference: SVT-2020-00008

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Severn Trent Water Limited, with registered number 02366686 (hereinafter called ‘the Company’).

Assets affected:
Refer to Annex 1 and Annex 2 at the end 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 2019 and 2020, which state that there is or has been a significant risk of supplying water from its service reservoirs (and associated assets as applicable) that could constitute a potential danger to human health.
  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:

Hazard/Hazardous Event/Parameter

Description of risks to drinking water quality and sufficiency

• Total Coliforms (Confirmed)

• E. coli (Confirmed)

• Clostridium Perfringens (Confirmed)

• Enterococci (Confirmed)

• Colony Counts at 22oC

• Residual Disinfectant – Total Chlorine

• Residual Disinfectant – Free Chlorine

To address the risk of ingress contamination and microbial growth.

  1. The Company are required to satisfy the following:

Requirements

(a) to maintain the following measures for the period specified in each case:

  1. Operate all DSRs in accordance with company procedures and industry good practice.
    Date: Ongoing for the duration of this Notice
  2. Carry out appropriate sampling in response to a microbiological exceedance at any of the sites listed in Annex 1 and Annex 2.
    Date: Ongoing for the duration of this Notice
  3. Implement an enhanced monitoring programme for all sites outside the 10-year cleaning frequency using a riskbased approach.
    Date: By August 2021 then ongoing for the duration of this Notice
  4. Proactive grounds maintenance on all service reservoir sites and at outflow discharge points and air valves.
    Date: Ongoing for the duration of this Notice
  5. Maintain records of remedial work completed on all cells.
    Date: Ongoing for the duration of this Notice
  6. Maintain an inspection and cleaning programme for water storage tanks, using a robust flood testing procedure.
    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 the procedure for responding to a microbiological exceedance at a service reservoir.
    Date: 30 September 2021
  2. Produce a dedicated plan and schedule of work to complete internal inspections and remedial works at all sites listed in Annex 1 including timescales for these to be completed and mitigations in place to materially reduce risk.
    Date: 31 December 2021
  3. Implement the schedule of work as defined in (b)2 to ensure DSRs within the Severn Trent network (as listed in Annex 1) have been inspected to within a maximum period of 10 years and then prioritised for inspection based on a thorough risk assessment (including historic structural failures, current asset condition etc.) for the future but at a maximum period of once every 10 years.
    Date: 31 January 2023
  4. For reservoirs in Annex 1 and Annex 2 (where applicable), carry out a 12-month demonstration of benefit phase for each reservoir upon its return to service.
    Date: For the 12 months following the return to supply of each reservoir
  5. Produce a risk-based schedule of work for all service reservoirs in the company to ensure all tanks remain within a maximum 10-year cleaning frequency in the future. The schedule should detail how the company intends to achieve the updated cleaning frequency according to current company policy.
    Date: 31 December 2022

(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 section (a) and (b).
    Date: 30 September 2021
  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 service reservoirs listed in Annex 2 of this Notice, or not to supply unless the specified conditions below are satisfied:

  1. The ‘Distribution Service Reservoir & Treated Water Tanks Re-Commissioning Procedure 204654’ procedure has been followed.
    Date: Ongoing for the duration of the Notice

(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 by 31 January and against the following milestones:
    Date: Annually by 31 January
    • Confirmation that the company are physically able to remove all service reservoirs from supply if required.
      Date: 31 August 2021
    • Confirm details of the strategy for auditing the effectiveness of the proposed measures as detailed in step (c)1.
      Date: 31 October 2021
    • Provide a copy of the procedure for responding to microbiological exceedances at service reservoirs as detailed in section (b)1.
      Date: 31 October 2021
    • Provide a copy of the plan and schedule of work produced as detailed in section (b)2.
      Date: 31 January 2022
    • Provide an update for reservoirs listed in Annex 1 for each cell entering and completing the 12-month demonstration of benefit period, as defined in sections (b)3 and 4.
      Date: Quarterly, one month after each quarter has ended (refer to table 1)
    • For reservoirs listed in Annex 2, should any be put back in supply, the Company shall update the Inspectorate.
      Date: Quarterly, one month after each quarter has ended (refer to table 1)
    • For reservoirs listed in Annex 2 the Company shall update the Inspectorate when a permanent solution has been agreed.
      Date: Quarterly, one month after each quarter has ended (refer to table 1)
    • Provide a copy of the schedule of work produced as defined in section (b)5.
      Date: 31 January 2023
  2. Submit a report in the event that any completed measure of this Notice needs to be altered in any way for any reason.
    Date: When required
  3. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 28 February 2024
  1. Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
  2. 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.
  3. 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).
  4. Contravention of a regulation 28(4)(d) requirement is an offence under regulation 33(1). If guilty of such an offence, the Company is liable on summary conviction, or on conviction on indictment, to a fine. Under regulation 33(2) it is a defence for the Company to show that it took all reasonable steps and exercised all due diligence to avoid the commission of the offence.

Signed
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
26 July 2021
Reference: SVT-2020-00008
Version 1