Enforcement Order – Section 18 of the Water Industry Act 1991
Southern Water Services Limited
Reference: SRN-2022-00008 Otterbourne 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.
- 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’) as well as section 68(1)(b) of the Act.
- The Inspectorate has considered any representations or objections to the proposed order, which were duly made and not withdrawn.
- 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 and section 68(1)(b) of the Act.
Requirements:
- 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
28 February 2023
Reference: SRN-2022-00008
Schedule of Works
Southern Water Services Limited
Date: 28 February 2023
Reference: SRN-2022-00008
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
- Otterbourne Ground Water WSW – TH002
- Otterbourne Surface Water WSW – TH003
- Otterbourne Supply System – Y002
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 the 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. Annual cleaning of clarifiers and sedimentation tanks.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
17. Review routinely and test alarms on the RGF system.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
18. Implement a comprehensive set of MSTs for maintenance and cleaning of the microfiltration plant and the instrument sample lines.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
19. Flush the supernatant return turbidity monitor daily.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
20. Calibrate coagulant flow monitors 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.
Steps to review, revise or make operational
21. Carry out a robust investigation to identify the source of Cryptosporidium and pathway into supplies from Otterbourne Ground and Surface Works
Date: Complete
22. Identify all options for additional risk mitigation to secure the long-term protection of public health to consumers receiving water from the Otterbourne Ground and Surface Works’ supply system. Assess the risk of short-circuiting of flow through the RGFs. Take action to alter the flow if any filters are found to have a significant Cryptosporidium risk due to short-circuiting of flow Cryptosporidium risk due to short-circuiting of flow
Date: Complete
23. Update the regulation 28 risk assessment for the site and supply system upon the conclusion of the above investigation.
Date: Complete
24. Replace sodium hypochlorite storage tanks.
Date: Complete
25. Model flows within the contact tanks, taking into account the balance pipe between the ground water and surface water contact tanks, to review whether Regulation 26 is breached under any flow scenario. If the review identifies that disinfection could be compromised at any time, undertake remedial measures.
Date: Complete
26. Review and implement measures required to ensure that routine maintenance of the disinfection system at Otterbourne GWTW can be carried out without risk of breaching Regulation 26 of the Water Supply (Water Quality) Regulations 2016.
Date: Complete
27. Improve asset condition, resilience, and control of the RGF including:
a) Replace outlet valve and backwash valve mechanism.
b) Replace main dose chlorine filtered water channel covers.
c) Seal RGF outlet valve covers to prevent vermin ingress, check outlet valve covers, record and action findings as part of routine operations.
d) Clean RGF outlet channels.
e) Replace media and refurbish under-drain system.
Date: Complete
28. Review and update equipment and procedures relating to all dosing pumps at Otterbourne ground and surface works (except carbon dosing, referenced below) to mitigate the risks of under or overdosing chemical including installation of an automatic coagulation control system.
Date: Complete
29. Install orthophosphoric delivery bund.
Date: Complete
30. Install auto shutdown on low lift pumping station (abstraction).
Date: Complete
31. Replace ferric dosing system.
Date: Complete
32. Site Power: Make safe high voltage cables above the borehole access track.
Date: Complete
33. Abstraction and Borehole works: Complete borehole and well improvements including:
a) Flood mitigation for all BHs including raising BH headworks C.
b) Refurbish headworks.
c) Install and commission individual Turbidity monitoring and control.
d) Decommission borehole D.
e) Ensure the wells are secured to prevent ingress.
f) Commissioning and handover of a) to e) above.
Date: 30 September 2023
34. Assess the abstraction transformer bunds with respect to the risk of groundwater contamination.
Date: 31 December 2025
35. Ensure abstraction transformer bunds are compliant with respect to risk of groundwater contamination.
Date: 30 June 2026
36. Ensure appropriate power supply resilience for each borehole.
Date: 31 March 2025
37. Commission power supply resilience for each borehole.
Date: 31 March 2026
38. Assess the structural integrity borehole access bridge and carryout necessary remediation.
Date: 31 March 2028
39. Provide borehole run to waste facilities.
Date: 30 September 2025
40. Commission borehole run to waste facilities.
Date: 31 March 2026
41. UV and Contact Tank: Complete the programme of works to mitigate risks associated with UV and Contact Tank, to include:
a) Complete repurposing of the existing contact tank in line with new disinfection strategy.
b) Design and build a new combined surface and groundwater capacity contact tank and associated dosing systems for the full, combined works flow.
c) Construct and commission ultraviolet treatment for the full, combined works flow.
d) Install and commission new intermediate and high lift pumps, including sample points.
e) Install new final run to waste facility to ensure non-compliant water cannot enter distribution.
Date: 31 December 2024
42. Maintenance and improvements to existing work: Complete the programme of works to mitigate risks associated with Maintenance and Improvements to existing works to include:
a) Refurbish the low lift pumping station (abstraction).
Date: 31 December 2023
b) Carry out repairs to the RGF hall roof, install ventilation, replace non-compliant handrail and install new backwash pumps in accordance with SWS standards.
Date: 31 December 2024
c) Replace the wash water pump.
Date: 31 August 2023
d) Improve access to clarifier sedimentation tanks for more regular cleaning.
Date: 31 March 2025
e) Improve access to the groundwater works balancing tank for increased regular cleaning.
Date: 30 September 2025
f) Assess the condition of the MCC4 and associated equipment, refurbish and replace where required.
Date: 30 September 2025
g) Complete commissioning of all actions associated with Maintenance and Improvements to existing works.
Date: 31 March 2026
43. Chemical storage and dosing: Complete the programme of works to mitigate risks associated with Chemical dosing and storage, to include:
a) Provide polyelectrolyte duty standby dosing pumps in accordance with SWS standards.
Date: 31 December 2023
b) Ensure the main dose hypochlorite dosing is compliant with SWS standards.
Date: 31 December 2024
c)Install and commission new hypochlorite pre-disinfection dosing system, controls, and monitoring.
Date: 31 December 2024
44. Taste and Odour: Complete the programme of works to mitigate risks associated with Taste and odour, to include:
a) Review the carbon treatment system in context of the long-term water resources plan.
Date: 30 April 2023
b) Develop short-medium term operational plan to control taste and odour risk.
Date: 30 April 2023
c) Investigate and report on works to expedite delivery of third-party HV supply.
Date: 30 April 2023
d) Construct and commission new carbon treatment system.
Date: 30 June 2031
45. Site Control: Complete the programme of works to mitigate risks associated with Site Control:
a) Upgrade SCADA, Water Quality Shut Down, site monitoring and control systems.
Date: 31 December 2024
b) Install new RGF PLC.
Date: 30 September 2023
c) Replace post RGF turbidity monitors.
Date: 30 September 2023
46. Site Control: Complete the programme of works to mitigate risks associated with Site Control:
a) Provide individual borehole pump controls.
Date: 30 September 2025
b) Repair or replace the river ammonia monitor.
Date: 30 September 2025
c) Commission the borehole pump controls and river ammonia monitor.
Date: 31 March 2026
47. Site Control: Complete the programme of works to mitigate risks associated with Site Control:
a) Add visibility of the alarm status of the band screens to SCADA.
Date: 30 September 2025
b) Commission the alarm status of the band screens to SCADA.
Date: 31 March 2026
48. Site Control: Complete the programme of works to mitigate risks associated with Site Control:
a) Improve visibility key microfiltration plant operating parameters on SCADA.
Date: 31 March 2028
b) Repair or replace MCC5
Date: 31 March 2028
c) Commission key microfiltration plant operating parameters on SCADA and MCC5.
Date: 30 September 2028
49. Site Power: Complete the programme of works to mitigate risks associated with Site power to include:
a) Install and commission new High voltage equipment.
Date: 31 December 2024
b) Assess the condition of site generators and associated equipment. Refurbish or replace site generators following assessment of condition and as required.
Date: 31 March 2025
c) Complete commissioning of the actions associated with Site Power.
Date: 31 December 2026
50. 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 Power Survey (V1 dated 5/11/21) report, providing likelihood and severity of risks. Provide programme of works and timeframe for completion and short-term mitigation steps.
Date: Complete
b) Confirm completion of Phase 1 programme of works in step 50(a) above.
Date: 30 September 2027
c) Commissioning of Phase 1 programme of works in step 50(a)
Date: 30 June 2029
d) Confirm completion of Phase 2 programme of works in step 50(a)
Date: 30 September 2032
e) Commissioning of Phase 2 programme of works in step 50(a).
Date: 30 June 2033
51. Dead Legs: Investigate, cut, and cap and commission redundant pipework, including Otterbourne Hill South.
Date: 31 December 2027
Long Term Strategy
52. Confirm the draft long-term water resources plan and pre-disinfection treatment requirements.
Date: 31 January 2023
53. Confirm the final long-term water resources plan and pre-disinfection treatment requirements
Date: 30 April 2023
54. Review the wash water recovery system in context of the long-term water resources plan. Confirm plan for wash water recovery system.
Date: 30 April 2023
55. Review GW turbidity risk to confirm need for GW pre-disinfection treatment. Develop short-medium term operational plan to control risk.
Date: 30 April 2023
56. Confirm alignment of full Works treatment capacity upgrade capacity with Water for Life Hampshire (Havant Thicket) input.
Date: 30 April 2023
57. Construction and installation of the long-term pre-disinfection treatment and wash water recovery system as agreed in writing with DWI following the submission of the final strategy document dated 30 April 2023.
Date: 30 June 2030
58. Commission of the long-term pre-disinfection treatment and wash water recovery system as agreed in writing with DWI following the submission of the final strategy document dated 30 April 2023.
Date: 30 June 2031
Steps to audit the effectiveness of steps completed
59. Define an audit strategy to monitor the effectiveness of the measures specified in this order.
Date: One month from date order made.
60. Implement, and keep under continuous review, the audit strategy defined in step 59.
Date: Following completion of step 59 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 April and October 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 steps 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 July 2034