Enforcement Order – Section 18 of the Water Industry Act 1991
Southern Water Services Limited
Reference: SRN-2022-00001 Burham FEO
Version Number: 1
Water undertaker as appointed under section 6 of the Water Industry Act 1991: Southern Water Services Limited, with registered number 02366670 (hereinafter called ‘the Company’).
Details of this Order:
- The Company has failed to carry out the steps identified in the regulation 28(4) notice served on it.
2. The Company was notified on 13 January 2023 about the Inspectorate’s intention to make an enforcement order under section 18 of the Act in respect of contraventions of regulation 28(4)(b) of the Water Supply (Water Quality) Regulations 2016 (‘the Regulations’).
3. The Inspectorate has considered any representations or objections to the proposed order, which were duly made and not withdrawn.
4. The Chief Inspector of Drinking Water makes this enforcement order under section 18(1) of the Act for the purposes of securing compliance with requirements imposed under regulation 28(4) of the Regulations.
Requirements:
1. The Company is hereby required to complete the steps and reporting outlined in the attached Schedule of Works with effect from the day after this order is made.
Signed
Marcus Rink
Chief Inspector of Drinking Water on behalf of the Secretary of State for Environment, Food and Rural Affairs
20 February 2023
Reference: SRN-2022-00001
Schedule of Works
Southern Water Services Limited
Date: 20 February 2023
Reference: SRN-2022-00001
Version Number: 1
Water undertaker as appointed under section 6 of the Water Industry Act 1991 (as amended): Southern Water Services Limited, with registered number 02366670 (hereinafter called ‘the Company’
Water Treatment Works and Connected Supply System
- Burham WSW – TK001
- Medway Supply System – Y006
Steps to be taken
The Company is required to implement the following steps by the date given in each case.
Steps to be maintained for the duration of the order
1. Continually review and optimise the clarifier desludging process.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
2. Create and follow site specific operating plan for filter backwashes, including visual checks of backwashes.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
3. Document and implement works restart operating plan to ensure compliant site restarts.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
4. Enhance the frequency of interstage sampling to enable more granular monitoring and optimisation of the treatment process.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
5. Enhanced monitoring (as a minimum 3 times per week) for Cryptosporidium in the raw and treated water.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
6. Enhanced monitoring for coliforms and E. coli in the treated water supplied.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
7. Establish a standard emergency safe operating plan including minimum SSDP requirements for periods when the raw water turbidity challenge is such that normal operating limits are unachievable.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
8. Establish and maintain an action plan in the event of a microbiological detection in the water supplied from the site.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
9. Establish and maintain in place until improvement works are completed such enhanced operational measures as necessary to ensure that consumers are protected and water supplied from the site is adequately treated and wholesome.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
10. Liaise with Public Health England and local authorities in the event of any breach of a health based standard.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
11. Maintain and operate existing works treatment in accordance with WSW site specific maintenance schedule and Routine Site Task Lists.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
12. Monitoring on a weekly frequency for animalcules in the treated water.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
13. Produce a daily working weekday trends review in accordance with WSM 202.06 to flag all risks and potential opportunities for process optimisation.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
14. Review the rapid gravity filter trends on a daily basis during the working week only, investigate and resolve any unusual trends.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
15. Undertake jar tests to inform coagulant dose requirements at a frequency which is commensurate with treatment changes.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
16. Validate dosing flow monitoring at a frequency commensurate with treatment changes and as a minimum in line with manufacturer’s instructions.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
17. Continuous on-line monitoring of chlorine concentration and turbidity with appropriate alarm levels and automatic shutdown pre and post disinfection.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
18. Carry out routine checks on GAC adsorbers to include.
a) Visual monitoring of GACs during backwashing
b) Monthly measurements of media as per procedure to ensure no media loss.
c) Removal of GAC of service for reactive maintenance if issues arise.
d) Continuous close monitoring of water quality post GAC to identify any increase in turbidity on treated water.
e) Adopt an operational plan to show maximum flows to GACs with/without ozone.
Date: Ongoing for the duration of this Order.
19. Adopt an operational plan to show maximum flows to GACs with/without ozone.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
Steps to review, revise or make operational
20. Badenoch and Bouchier compliance. Undertake a review of works compliance with the recommendations of Badenoch and Bouchier.
Date: Complete
21. Intake and Eccles Lake Storage: Complete the programme of works to mitigate risks associated with Intake and Eccles Lake Storage, to include.
a) Evaluate the suitability of current raw water storage provided by Eccles Lake and complete a dredging survey.
Date: Complete
b) Assess the condition of the draw off tower and its seized valves and refurbish or replace as required.
Date: 30 September 2029
c) Complete commissioning of the refurbishment of the draw off tower and its seized valves.
Date: 31 March 2030
22. Low Lift Pumps: Complete the programme of works to mitigate risks associated with Low Lift pumps, to include.
a) Assess the condition of the strainers, low lift pumps and power distribution system.
Date: 31 December 2023
b) Refurbish/replace the short-term mitigations for the strainers, low lift pumps and power distribution system where required.
Date: 30 September 2025
c) Commission the short-term mitigations for the strainers, low lift pumps and power distribution system where required.
Date: 31 March 2026
23. Ozone: Complete the programme of works to mitigate risks associated with Ozone, to include.
a) Assess the condition and refurbish or replace where necessary to optimise the performance.
Date: 31 March 2025
b) Replace ozone monitoring.
Date: 31 March 2025
c) Clean the pre-ozone contact tank.
Date: 31 March 2025
d) Complete commissioning the actions outlined in step 23(a) to (c) above.
Date: 30 September 2026
24. Clarification: Complete the programme of works to mitigate risks associated with Clarification, to include.
a) Outlet launders to be assessed and those impacting the efficacy of the clarifiers to be replaced where required and access steelworks built to improve access for cleaning and maintenance.
Date: Complete
b) Make flow meters on polymer dosing lines operational.
Date: Complete
c) Assess the performance and condition of the rest of the clarifier launders and refurbish where necessary to meet current standards.
Date: 30 September 2025
d) Commission the clarifier launders.
Date: 31 March 2026
e) Assess the performance and condition of the clarifiers.
Date: 31 December 2025
f) Install flow meters on each clarifier, with a set of valves to aid future maintenance and complete as necessary, pipework modifications to aid clarifier cleaning.
Date: 31 March 2030
g) Commission installed flow meters on each clarifier, with a set of valves to aid future maintenance and complete as necessary, pipework modifications to aid clarifier cleaning.
Date: 31 March 2031
25. Auto-Coagulation: Complete the programme of works to mitigate risks associated with the Auto-coagulation system, to include:
a) Complete the Installation the new auto coagulation system.
Date: Complete
b) Commission the new auto coagulation system.
Date: 30 June 2023
c) Review and commission plant shutdown following coagulation failure and implement the resulting identified improvements required improvements.
Date: 30 June 2023
d) Removal of obsolete auto coagulation system.
Date: 31 March 2023
26. Floc blanket monitoring:
a) Implement improvements to desludging rate control.
Date: 30 September 2025
b) Commission improvement to desludging rate control.
Date: 31 December 2026
27. Rapid Gravity Filtration: Complete the programme of works to mitigate risks associated with Rapid Gravity Filtration, to include.
a) Complete necessary short-term improvement works to comply with Badenoch and Bouchier recommendations where required.
Date: Complete
b) Design a solution to assess the performance and condition of the Rapid Gravity Filters.
Date: Complete
c) Refurbish or rebuild where necessary, including the installation of individual Rapid Gravity Filters (RGF) flow metering, to meet current standards and reduce carryover to the ozone tank and Granular Activated Carbon (GAC) adsorbers.
Date: 30 September 2029
d) Commission Rapid Gravity Filters (RGF), including flow metering, to meet current standards and reduce carryover to the ozone tank and Granular Activated Carbon (GAC) adsorbers.
Date: 30 June 2030
e) Carry out decommissioning of existing RGF assets.
Date: 30 June 2031
28. Algal growth:
a) Review the means of controlling algae growth in the clarifiers and implement an effective solution.
Date: 30 September 2025
b) Complete commissioning of algal control in the clarifiers.
Date: 31 December 2026
29. Granular Activated Carbon adsorbers: Complete the programme of works to mitigate risks associated with GAC, to include.
a) Produce a structural report for the GAC using information gathered from the nozzle replacement project to steer future investment.
Date: Complete
b) Review the regeneration frequency of GAC media and adjust if necessary.
Date: Complete
c) Complete surveys and asset condition report on GAC including recommended solution for implementation.
Date: 30 June 2024
d) Implement and commission modifications to GAC to ensure resilience.
Date: 30 September 2028
30. Surge Vessel:
a) Replace or reline the surge vessel.
Date: Complete
b) Complete commissioning of the surge vessel.
Date: 31 January 2023
31. Contact Tank:
a) Upgrade the vent covers on the contact tank to ensure protection against vermin.
Date: Complete
b) Inspect and clean tanks and produce a condition report to assist with the prioritisation of further remedial works needed.
Date: Complete
32. Clearwater Tank:
a) Seal all cable entries into the tank.
Date: 31 March 2024
b) Inspect tank. Replace and/or refurbish defective valves, pumps, and monitoring equipment.
Date: 31 March 2024
c) Complete commissioning of actions associated with the Clearwater Tank.
Date: 30 September 2024
33. Chemical dosing and storage: Complete the programme of works to mitigate risks associated with chemical dosing and storage, to include.
a) Replace Sodium hydroxide storage tanks and dosing equipment.
Date: Complete
b) Review and replace or refurbish chemical storage and dosing systems, including for hypochlorite, bisulphite, main polyelectrolyte, orthophosphate, to ensure resilience and compliance.
Date: 30 June 2026
c) Commission chemical dosing and storage systems including for hypochlorite, bisulphite, main polyelectrolyte, orthophosphate to ensure resilience and compliance.
Date: 31 March 2027
d) Review and replace or refurbish remaining chemical storage systems (Alum, sodium hydroxide, PACl) to ensure resilience and compliance.
Date: 30 September 2029
e) Commission remaining chemical storage systems (Alum, sodium hydroxide, PACl) to ensure resilience and compliance.
Date: 31 March 2030
34. Monitoring and Control: Complete the programme of works to mitigate risks associated with monitoring and control, to include.
a) Ensure future site process improvements are integrated into the RTS framework being delivered in AMP6.
Date: Complete
b) Ensure the tapping point for the final water triple validation monitors provides a representative sample.
Date: 30 September 2025
c) Commission tapping point for the final water triple validation monitors provides a representative sample.
Date: 31 March2026
d) Carry out a review of the existing monitoring and control equipment at Burham WSW and implement a site wide PLC/SCADA/Network upgrade except for Rapid Gravity Filters which shall be addressed in the programme of work outlined in step 27.
Date: 31 March 2027
e) Commission site wide PLC/SCADA/Network upgrade except for Rapid Gravity Filters which shall be addressed in the programme of work outlined in step 27..
Date: 31 December 2027
35. Site Drainage and Discharges: Complete the programme of works to mitigate risks associated with Site Drainage and Discharges, to include.
a) Carry out a site drainage and discharge study and recommend phased improvements.
Date: 31 December 2023
b) Complete Phase 1 site drainage and discharge study improvements.
Date: 31 March 2025
c) Complete Phase 2 site drainage and discharge study improvements.
Date: 30 September 2032
d) Assess the performance of the sludge treatment plant.
Date: 30 June 2026
e) Complete Phase 1 sludge treatment plant improvements.
Date: 31 March 2028
f) Commission Phase 1 sludge treatment plant improvements.
Date: 30 September 2028
g) Complete Phase 2 sludge treatment plant improvements.
Date: 30 September 2032
h) Commission Phase 2 sludge treatment plant improvements.
Date: 30 September 2033
36. High Lift pumps and power supply: Complete the programme of works to mitigate risks associated with High lift pumps and power supply, to include:
a) Refurbish or replace generator(s) to ensure resilience.
Date: Complete
b) Replace the high voltage switch gear, high lift pumps and motors.
Date: 30 September 2027
c) Complete commissioning of all actions associated with High Lift pumps and power supply.
Date: 30 September 2028
37. Power and Resilience: Complete the programme of works to mitigate risks associated with power and resilience, to include:
a) Carry out risk assessment investigation for the recommendations from the HazOps report, providing likelihood and severity of risks. Provide programme of works and timeframe for completion and short-term mitigation steps.
Date: 31 January 2023
b) Confirm completion of high priority works in programme from step 37a).
Date: 31 December 2027
c) Commission high priority works in programme from step 37a) above
Date: 31 December 2028
Steps to audit the effectiveness of steps completed
38. Define an audit strategy to monitor the effectiveness of the steps specified in this order.
Date: One month from date order is made.
39. Implement, and keep under continuous review, the audit strategy defined in step 38.
Date: Following completion of step 38 onwards.
Reporting
Provide the Inspectorate with the following reports as specified.
1. Provide a progress report annually.
Date: by 31 January each year.
2. At regular intervals, provide the Inspectorate with reports on progress made with carrying out the steps set out in the Action Plan.
Date: Bi-annually, on last day of May and November for the duration of the Order.
3. Submit a report establishing short term mitigation measures required for duration of this Order as per step 9.
Date: 31 March 2023
4. Submit the audit strategy for auditing the effectiveness of the steps
Date: Two months from date order is made.
5. Submit any revisions of the audit strategy.
Date: Within 1 month of a revision.
6. Submit a report in the event that any completed measures of this Order need to be altered in any way, for any reason.
Date: As soon as reasonably practicable after being made aware and in any case, within one month; ongoing for the duration of the order
7. Submit a satisfactory completion report accompanied by a revised regulation 28(1) report with Board level Director sign-off.
Date: 31 October 2034