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Dŵr Cymru Cyfyngedig – Discolouration

Notice under regulation 28(4) of the Water Supply (Water Quality) Regulations 2018

Reference: DWR-2022-00004

Version Number: 3

Water undertaker as appointed under section 6 of The Water Industry Act 1991 (as amended): Dŵr Cymru Cyfyngedig, with registered number 02366777 (hereinafter called ‘the Company’).

Assets Affected:

  • Dŵr Water Supply Zones as listed in Annex one

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 2018 (‘the Regulations’) from the Company dated 21 October 2021, which states that there is or has been a significant risk of supplying water from all water supply zones (WSZ) (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 Welsh Ministers, under regulation 28(4) for the assets listed above, for risks associated with:

Description of Risk

Hazard/ Hazardous Event/ Parameter

Hazard ID

Consumer acceptability (discolouration)

Turbidity

Multiple risk assessment reports (Annex 1). For example, Z1010B23 Conwy: D122245

Consumer acceptability (discolouration)

Aluminium (Total)

D122236

Consumer acceptability (discolouration)

Manganese (Total)

D122238

Consumer acceptability (discolouration)

Iron (Total)

D122237

Consumer acceptability (discolouration)

Discolouration

D104800

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.
  1. 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 regulatory and enhanced monitoring as defined within section (c)1 from treatment works, reservoirs and any water supply zones identified as being at risk of discolouration.
    Date: Ongoing for the duration of this notice
  2. Optimisation of treatment for manganese, iron and aluminium at all water treatment works.
    Date: Ongoing for the duration of this notice
  3. Optimisation of pH to manage the corrosive nature of the treated water.
    Date: Ongoing for the duration of this notice
  4. Adequate risk assessment, with appropriate sign-off, before completion of any planned work in order to consider and reduce the risk of customer impact.
    Date: Ongoing for the duration of this notice
  5. Training of field operatives to facilitate more effective network operation and management and minimise disruption to customer supplies through the Company’s activities.
    Date: Ongoing for the duration of this notice
  6. 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
  7. Investigate any failure of a discolouration parameter (Aluminium, Iron, Manganese or Turbidity) and determine root cause.
    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. Develop a discolouration strategy to reduce the risk of discoloured water in water supply zones, which is benchmarked against industry good practice.
    To include:
  • Treatment works
  • Service Reservoirs
  • Trunk mains
  • Zonal network

Date: Complete

  1. Review and update procedures for investigating consumer contacts for discolouration, sample failures of parameters listed above and water quality discolouration events.
    Date: Complete
  2. Develop a dynamic risk assessment methodology for water supply zones, utilising all relevant sources of data and with input from relevant stakeholders, to prioritise zones for further investigation and remedial work to reduce the risk of consumer contacts regarding discoloured water.
    To include:
  • Treatment works
  • Service Reservoirs
  • Trunk mains
  • Zonal network

Date: Complete

  1. Develop a discolouration root cause analysis methodology to understand the reasons for discolouration, utilising all relevant sources of data, with input from relevant stakeholders.
    Date: Complete
  2. Review discolouration data from all sources and complete risk assessments for all zones. Update regulation 28 reports where necessary.
    Date: 30 April 2023 and then by 30 April annually for the duration of the notice
  3. Undertake a root cause analysis for the zones identified as high and medium risk within (b)5, to understand discolouration within the zones. Identify bespoke solutions for each zone.
    Date: 30 June 2023 for high-risk zones, 30 September 2023 for medium risk zones. Annually by 30 June for new high and medium risk zones for the duration of the notice
  4. Using the outputs from the root cause analysis in (b)6., and risk assessment in (b)5., develop a detailed plan with timescales for all high and medium risk zones to reduce the risks of discolouration to consumers. This should be specific to each zone and include as required.
    • Treatment works optimisation
    • Service reservoir risk assessment and cleaning
    • Work on Trunk mains and pumping stations
    • Water quality zones and DMAs
      Date: 31 March 2024 for 50% of the high risk zones and for all medium risk zones 31 March 2025 for the remaining high risk zones, then annually by 30 September for all new high and medium risk zones for the duration of the notice
  1. Implement bespoke solutions as identified in (b)7., prioritising zones to an agreed programme with highest risks for discolouration, consumer contacts and consumer acceptability to achieve the following;
    • Phase 1 (AMP7) – By 2025 a reduction in discolouration contacts to a company average of 1.4 per 1000 population regionally. As a minimum, zones with a contact rate of above 1.08 per 1000 population to be included in Appendix 1.
      Date: 31 March 2025
    • Phase 2 (AMP8) – Agree phase 2 target with the Inspectorate, to be a maximum of 0.7 per 1000 population regionally. Zones with a contact rate above 0.94 to be included in Appendix 1.
      Date: Complete
    • Phase 2 (AMP8) – Complete planned improvement works by 2029 to allow a demonstration of benefit period to achieve the discolouration target by 2030.
      Date: 31 March 2029
    • Phase 2 (AMP8) – By 2030 a reduction in consumer contacts for discolouration to below the target of 0.7 per 1000 population regionally.
      Date: 31 March 2030
    • Phase 3 (AMP9) – Agree with the Inspectorate a phase 3 target for reduction on discolouration contacts regionally (to be a maximum of 0.4 contacts per 1000 population) and for individual zones (to be a maximum of 2 contacts per 1000 population). The regional target should be in line with the rest of the drinking water industry anticipated average.
      Date: 31 March 2029
    • Phase 3 – Develop a strategy to deliver required work for improvements in discolouration contacts in AMP9 (for example, treatment works upgrades to reduce network seeding, mains replacement, etc.), taking into account performance improvements attained in AMP8.
      Date: 28 February 2027
    • Phase 3 (AMP9) – Implement AMP9 strategy developed in (b)8.f. to completion and achieve the targets agreed in (b)8.e.
      Date: 31 March 2035
  1. Document all optimisation that has been carried out as part of (a)2. at treatment works to minimise discolouration and identify outstanding actions with timelines.
    Date: 31 May 2024 and then annually by 30 June for the duration of the Notice

(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 all water supply zones, 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 copy of the discolouration strategy developed in (b)1.
    Date: Complete
  3. Provide a copy of revised procedures as developed under (b)2.
    Date: Complete
  4. Provide a report detailing the dynamic risk assessment methodology developed in (b)3.
    Date: Complete
  5. Provide a report detailing the root cause analysis methodology developed in (b)4.
    Date: Complete
  6. Provide a report providing an overview of risk per zone (high, medium, low) from risk assessments carried out in (b)5. for all zones. Include which zones will be added to this legal instrument, based upon consumer contact rates for discolouration being >1.08 per 1000 population for phase 1, 0.94 for phase 2 and the agreed target for phase 3. Submit an updated Appendix 1 with associated evidence to the Inspectorate for approval.
    Date: Annually by 31 May 2023 onwards for the duration of the Notice
  7. Provide a report into the outputs of the root cause analysis and the bespoke solutions identified in (b)6.
    Date: 31 July 2023 for high risk zones. 31 October 2023 for medium risk zones.
    Then annually by 31 July for all new high and medium risk zones for the duration of the notice.
  8. Provide a report with evidence detailing which high and medium risk zones have had successful work undertaken where they no longer meet the criteria for high and medium risk zones (phase 1 – 1.08 per 1000 population per zone, phase 2-0.94 per 1000 population and phase 3 zonal targets to be agreed). Any zones which have met this requirement and have had an updated Regulation 28(1) risk assessment may be removed from Appendix 1. This report should include information on the measures undertaken to manage and reduce the risks of discolouration along with an independent assessment of actions and results.
    Date: Annually by 31 May 2023 onwards for the duration of the Notice
  9. Provide the detailed plan with timescales for the schedule of work as detailed in (b)7 for high and medium risk zones and any updates annually for new zones in Appendix 1.
    Date: 30 April 2024 for 50% of the high risk zones and for all medium risk zones – complete
    30 April 2025 for all remaining high risk zones – complete
    Then annually by 31 October for all new high and medium risk zones for the duration of the notice
  10. Provide a report to confirm the agreed target for AMP8 for reduction in discoloured water contacts (b)8.b. in the region.
    Date: Complete
  11. Provide a report for work completed to date and confirm the company has met phase 1 target as defined within (b)8.a.
    Date: 30 April 2025
  12. Provide a copy of the discolouration strategy for AMP9 as defined in (b)8.f and submit a PR29 scheme for consideration if required.
    Date: 31 March 2027
  13. Provide a report to confirm the agreed target for reduction in discoloured water contacts (b)8.e. in the region and zones.
    Date: 30 April 2029
  14. Provide a report to confirm the company has met the phase 2 target as defined within (b)8.d.
    Date: 30 April 2030
  15. Provide a report to confirm the company has met the phase 3 target as defined within (b)8.g.
    Date: 30 April 2035
  16. Provide the document produced in (b)9 showing the actions completed to optimise treatment processes and a timeline for future work.
    Date: 30 June 2024 and then annually by 31 July for the duration of the Notice
  17. Provide a report to measure progress, from the previous calendar year, on the planned works detailed in (b)7.
    Date: Annually by 30 April
  18. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
    Date: Complete
  19. Submit any revisions of the audit strategy produced under measure (c)2.
    Date: Within 1 month of a revision
  20. 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
  21. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 30 April 2036

Further Details of this Notice:

  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 Welsh Ministers, 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).

Signed

Nicholas Adjei
Deputy Chief Inspector, on behalf of the Welsh Ministers
5 November 2024
Reference: DWR-2022-00004 v2

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