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Northumbrian Water Limited – AMP8 Lead Strategy

Water Industry Act 1991 (as amended) (“the Act”): Section 19(1)(b)

Reference: NES-2023-00010

Acceptance Notice:

The Drinking Water Inspectorate, on behalf of the Secretary of State for Environment, Food and Rural Affairs:

  1. Is satisfied that Northumbrian Water Limited “the Company” in supplying water from all company water zones which may be at risk of exceeding the standards for Lead. This means that the Company is likely to contravene its duty in respect of supplying water which meets the Regulations under Section 68(1)(a) of the Water Industry Act 1991 and meets the requirement set in regulation 4(2)(c) of the Water Supply (Water Quality) Regulations 2016 (as amended) (“the Regulations”).
  2. Has notified the Company on 8 November 2023 that the Secretary of State is considering making in relation to the company an enforcement order under Section 18 of the Act.
  3. Notes that the Company has on 5 March 2024 given a new undertaking under Section 19 (1) (b) of the Act, to take the following steps by the dates shown.

Steps to be taken:

  1. Ensure that the Lead parameter has been assessed as a hazard as part of the regulation 27 Risk Assessment for the supply system that includes the water supply zones listed in the Annex to this Schedule according to a Drinking Water Safety Plan approach. Ensure that regulation 28 documents are reviewed and updates provided as necessary.
    Date: Ongoing for the duration of the undertaking
  2. Keep under review the company’s strategy for the protection of public health and for compliance with drinking water quality standards with respect to lead.
    Date: Ongoing for the duration of the undertaking
  3. Step from Schedule of works Measures being delivered:

1. ‘Hot spot’ programme. Using our lead risk model, we will prioritise the replacement of lead supply and communication pipes up to the customer tap in those areas of greatest risk to lead levels. These areas are known as ‘hot spot’ schemes. Defined areas are under continuous review and may flex as information emerges, for example, following a lead sample investigation. Target: 8,471 properties. Date: 31 March 2030

2. Vulnerable groups programme. As a priority, we want to protect those most vulnerable from the effects of lead in drinking water by focusing on lead pipe replacement in public buildings frequented by children. We will replace the communication pipe and supply pipe up to one tap within the property. The scope of this option will cover educational, childcare (including childminders), and community establishments (including places of worship). Target: 1,814 properties. Date: 31 March 2030

3. Phosphate disengagement programme. We recognise phosphate dosing is not a permanent solution to the risks posed from lead pipes. Where we have a WTWs which is the sole supply to an area, and supplies that area only, we have the potential to disengage phosphate dosing once the risk from lead pipes is removed up to the customer tap. Phosphate disengagement will only commence in those areas once a thorough risk assessment has been completed through our Water Safety Plan process. This approach may also be used as an alternative to installing dosing in those areas without plumbosolvency control in the future. Target: 986 properties. Date: 31 March 2030

4. Produce a plan to achieve lead free drinking water supplies. This is incorporated within our Asset Group Strategy for Lead (Lead service pipe strategy). Date: 31 December 2027

5. Develop and submit the company’s draft Lead reduction plans for AMP9, demonstrating the required ramp-up pipe replacement rate.
Date: 31 August 2027

Reporting:

  1. Step from Schedule of works At regular intervals provide DWI with reports on progress made with carrying out the steps set out in the Action Plan. Reports to include at least the following details:

a) All data from the monitoring of treated water in the distribution systems named in the annex.

b) Details of the remedial steps that comprise the programme of work including commencement and completion dates for investigations, design, tendering, construction, and commissioning.

c) Current state of progress with the steps referred to in (b) above;

d) A statement of implications of any slippage of the programme and details of activities planned to bring programme back on target.

e) Whether the company has any other reason to believe it may not be able to meet any of the key dates set out in this Schedule of Work.
Date: Reporting periods are Jan – Dec. Reports to be submitted by 31 January each year that the Undertaking is in place.

  1. Continue to monitor at an enhanced frequency for Lead for a period of 12 months following commissioning of any work associated with the Action Plan to demonstrate the effectiveness of the remedial measures taken.
    Date: 31 March 2031
  2. Provide a final report to DWI on the efficacy of the remedial measures taken as part of the lead strategy. Include as evidence for closure for this scheme appropriate documentation to confirm that the actions set out in this Schedule of Work have been taken and that the company’s lead strategy is in place.
    Date: 30 April 2031

Further Details of this Acceptance Notice:

  1. The Secretary of State is satisfied that Northumbrian Water Limited has given and is complying with an undertaking to take all such steps as appear to the Secretary of State for the time being to be appropriate to secure or facilitate compliance with the requirement of regulation 4(2)(c) of the Water Supply (Water Quality) Regulations 2016 (as amended).

Authorised by the Secretary of State to sign in that behalf

Nicholas Adjei
Deputy Chief Inspector, Drinking Water Inspectorate
29 April 2024
Reference: NES-2023-00010

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