Portsmouth Water Limited –AMP8 Micro and Crypto Mitigation

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

Reference: PRT-2023-00005

Version Number: 1

Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Portsmouth Water Limited, with registered number 02536455 (hereinafter called ‘the Company’).

Assets Affected:

Asset Name	Reference
Maindell Treatment Works	TMAI
Slindon Treatment Works	TSLN
West Street Treatment Works	TWST

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 12 January 2023, 7 February 2023, 16 February 2023, 27 March 2023 and 4 April 2023, which states that there is or has been a significant risk of supplying water from, Maindell Treatment Works, Slindon Treatment Works and West Street 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
Failure to meet requirements of regulation 26, inadequate disinfection, due to a failure to demonstrate that disinfection contact time is met under all conditions.	Microbiological and viruses	PRT/HSH/TMAI/T-IPA-1.1.18 PRT/HSH/TMAI/T-IPA-1.1.23 PRT/HSH/TMAI/T-IPA-1.1.24 PRT/HSH/TMAI/T-IPA-1.2.3 PRT/BOG/TSLN/T-IPA-1.1.18 PRT/BOG/TSLN/T-IPA-1.1.23 PRT/BOG/TSLN/T-IPA-1.1.24 PRT/BOG/TSLN/T-IPA-1.2.3 PRT/HSH/TWST/T-IPA-1.1.18 PRT/HSH/TWST/T-IPA-1.1.23 PRT/HSH/TWST/T-IPA-1.1.24 PRT/HSH/TWST/T-IPA-1.2.3
Contaminant of concern – Cryptosporidium	Cryptosporidium	PRT/HSH/TMAI/T-IPA-1.3.1 PRT/HSH/TWST/T-IPA-1.3.1

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. Operate treatment processes which meet the requirements of regulation 26 in full, to disinfect the water at all times and under all flow conditions.
   Date: Ongoing for the duration of this Notice
2. Operate all processes within defined operating ranges, with appropriate triggers, responses and contingency procedures.
   Date: Ongoing for the duration of this Notice
3. Ensure the works control and shutdown system is operational and that monitors are calibrated at the predefined frequencies.
   Date: Ongoing for the duration of this Notice
4. Continuous monitoring to ensure that water being presented for disinfection is of the required standard to achieve disinfection and to verify that disinfection is taking place and is effective.
   Date: Ongoing for the duration of this Notice
5. Take action to prevent water leaving the treatment works when monitoring indicates that the water quality falls outside target range and that disinfection requirements are not met. The Company must take appropriate action to protect human health.
   Date: Ongoing for the duration of this Notice
6. Enhanced operational water quality monitoring to validate and verify the quality of water entering supply, as specified within the audit strategy.

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. Complete the planning, design and procurement of a permanent UV treatment process at West Street Treatment Works to secure the long-term protection of human health of those consumers receiving water from the associated supply system(s).
   Date: 31 March 2028
2. Complete the construction, installation, and commissioning into supply of the chosen solution identified in (b)1. Commissioning must include the following to account for the changes made:
   An appropriate maintenance regime for any installed (or modified) processes;
   Full integration of any new (or modified) processes into the site control and monitoring systems.
   Updating of the Site-Specific Disinfection Policy and any associated site-specific procedures;
   Updating of the Site Operating Manual and removal of all out-of-date material from circulation; and
   Provisions of adequate training for all relevant personnel on the operation, repair and maintenance of any installed (or modified) process and the revised procedures, policies and manual.
   Date: 31 March 2030
3. Complete the planning, design and procurement of a Cryptosporidium mitigation system for use at Maindell Water Treatment Works to secure the long-term protection of human health of those consumers receiving water from the associated supply system(s).
   Date: 31 March 2028
4. Complete the construction, installation, and commissioning into supply of a Cryptosporidium mitigation system detailed in (b)3. at Maindell Treatment Works. Commissioning must include the following to account for the changes made:
   An appropriate maintenance regime for any installed (or modified) processes;
   Full integration of any new (or modified) processes into the site control and monitoring systems.
   Updating of the any Site-Specific procedures;
   Updating of the Site Operating Manual and removal of all out-of-date material from circulation; and
   Provisions of adequate training for all relevant personnel on the operation, repair and maintenance of any installed (or modified) process and the revised procedures, policies and manual.

Date: 31 March 2030

5. Install and commission a Volatile Organic Compounds (VOCs) online monitor at Maindell Water Treatment Works.
   The monitor must be linked to appropriate alarms and integrated failsafe shutdown mechanisms that have been tested. It must also be positioned at appropriate locations to protect Company assets from hydrocarbon contamination.
   Design and operate a system of verification and maintenance for the VOC monitor.
   Update the site operating manuals and procedures, as appropriate, following the installation of the VOC monitor.
   Ensure all relevant staff are trained appropriately in the operation of the VOC monitor
   Date: 31 March 2030
6. Complete the construction of emergency connection arrangements (piping infrastructure etc) to allow for a mobile UV plant to be installed at Slindon Treatment Works to allow for an increase in output under drought conditions.
   Date: 31 March 2030

(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: 31 March 2024
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 Maindell Treatment Works, Slindon Treatment Works and West Street Treatment Works, or not to so supply unless the specified conditions below are satisfied:

Maindell WTW:

1. A full investigation into the quality of the raw water sources supplying Maindell Water Treatment Works, characterisation of the risks to water quality and appropriate actions to mitigate against Cryptosporidium in the final water have been completed; and
   Date: Until the completion of measures (b)4.
   
2. Enhanced monitoring for Cryptosporidium is implemented; and
   Date: Until the completion of measure (b)4.
   
3. Notification to the Inspectorate, with provision of the above information and anticipated duration of use.
   Date: Until the completion of measure (b)4.

(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. Submit a report outlining the planning, design and procurement of a permanent UV treatment process at West Street Treatment Works, as defined by measure (b)1.
   Date: 30 April 2028
3. Submit a report confirming the construction, installation, and commissioning into supply of the chosen solution at West Street Treatment Works.
   Date: 30 April 2030
4. Submit a report outlining the planning, design and procurement of a Cryptosporidium mitigation system for use at Maindell Water Treatment Works as defined by measure (b)3.
   Date: 30 April 2028
5. Submit a report confirming construction, installation, and commissioning into supply of a Cryptosporidium mitigation system at Maindell Treatment Works.
   Date: 30 April 2030
6. Submit a report confirming installation, and commissioning into supply of a VOC online monitors at Maindell Treatment Works.
   Date: 30 April 2030
7. Submit a report confirming the construction of emergency connection arrangements (piping infrastructure etc) to allow for a mobile UV plant to be installed at Slindon Treatment Works.
   Date: 30 April 2030
8. Submit the audit strategy for auditing the effectiveness of the measures, as specified in measure (c)1.
   Date: 30 April 2024
9. Submit any revisions of the audit strategy produced under measure (c)2.
   Date: Within 1 month of a revision
10. 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
11. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
    Date: 30 April 2031

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).
7. 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

Nicholas Adjei
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
5 February 2024
Reference: PRT-2023-00005 v1