Enforcement Order – Section 18 of the Water Industry Act 1991
Southern Water Services Limited
Reference: SRN-2022-00009 Testwood 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’) as well as section 68(1)(b) of the Act.
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 The Inspectorate has considered any representations or objections to the proposed order, which were duly made and not withdrawn.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 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
20 February 2023
Reference: SRN-2022-00009
Schedule of Works
Southern Water Services Limited
Date: 20 February 2023
Reference: SRN-2022-00009
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
- Testwood WSW – TH001
- Testwood Industrial WSW – TH025
- Testwood 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. 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. Carry out tests of ferric concentration on the clarifier and RGF outlets.
Date: From the day after the final enforcement order is made and thereafter, ongoing for the duration of the order.
18. Carry out weekly checks of polyelectrolyte dosing to meet the instructions for use and/or national requirements and the prescribed concentration of 0.1µg/l acrylamide.
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
19. Abstraction: Complete the programme of works to mitigate risks associated with Abstraction, to include:
a) Install flood protection around abstraction works.
Date: Complete
b) Install raw water monitoring on Testwood Lakes (to include; Ammonia, Dissolved Oxygen, Turbidity, pH, Conductivity and Temperature).
Date: 31 March 2026
c) Commission raw water monitoring on Testwood Lakes (to include Ammonia, Dissolved Oxygen, Turbidity, pH, Conductivity and Temperature).
Date: 31 October 2026
d) Request discharge licence variation with Environment Agency, or complete works necessary to return wash water to head of works.
Date: Complete
e) Replace or refurbish low lift pump arrangement to ensure long term resilient operation.
Date: 30 June 2029
f) Deliver appropriate solution to manage silt build up within the river intakes.
Date: 30 September 2027
g) Commission step 19(e) (new low lift pump arrangement) and 19(f) (Solution to manage silt build up within river intakes).
Date: 30 June 2030
20. Clarification: Complete the programme of works to mitigate risks associated with Clarification, to include:
a) Survey the subsidence of Accentric Clarifier and confirm the required scope of work.
Date: Complete
b) Assess existing clarifiers (5, 6 & 7) condition and confirm scope and programme to design and construct replacements where needed.
Date: Complete
c) Confirm scope of new clarification process and programme of works including removal of Enelco filters (RGFs 13 & 14) from service.
Date: 31 December 2023
d) Construct and install new clarification process.
Date: 31 December 2029
e) Commission new clarification process.
Date: 31 December 2030
21. Filtration: Complete the programme of works to mitigate risks associated with Filtration, to include.
a) Cover Rapid Gravity Filters 13 & 14 (the Enelco filters).
Date: Complete
b) Replace flap valves and rubber seals on RGFs 13 & 14.
Date: Complete
c) Install run to waste on RGFs 13 &14.
Date: Complete
d) Install additional interim mitigation to reduce the risk from Enelco filters (RGF 13 & 14).
Date: 31 March 2025
e) Remove Enelco filters (RGFs 13 & 14) from service and physically disconnect associated pipework.
Date: 31 December 2030
f) Complete decommissioning of the Enelco filters (RGFs 13 & 14).
Date: 31 December 2031
g) Complete decommissioning of the old contact tank and build a new backwash tank.
Date: Complete
h) Commissioning changes following decommissioning the old contact tank and build a new backwash tank.
Date: 30 September 2023
i) Improve the condition of RGFs 1-12 including; valve replacement to prevent filters letting by, air blower replacement, improve the surrounding building and complete upgrade/refurbishment where needed. Connect to new backwash system. Remove RGFs 5 to 8 from service to mitigate water quality risks.
Date: Complete
j) Improve the condition of RGFs 5 to 8 including valve replacement to prevent filters letting by, air blower replacement, improve the surrounding building and complete upgrade/refurbishment where needed. Connect to new back wash system.
Date: 31 January 2023
k) Commission and handover RGFs 1-12 as per steps 21(i) and 21(j) above.
Date: 30 September 2023
l) Install run to waste facilities post main dose chlorination (RGFs 1 to 14).
Date: 30 June 2026
m) Commission run to waste facilities post main dose chlorination (RGFs 1 to 14).
Date: 31 December 2026
22. Disinfection (Part A- Short term stabilisation): Complete the programme of works to mitigate risks associated with Disinfection, to include:
a) Install balancing main pipework to enable all contact tank and treated water storage tanks to be isolated from supply.
Date: Complete
b) Complete the isolation, inspection and any required remediation of the South and North contact tanks, the East “Industrial” treated water tank and the West “Potable” treated water storage tank.
Date: Complete
c) Install a temporary ultraviolet treatment unit, post contact tank.
Date: Complete
d) Integrate temporary ultraviolet treatment into sites existing telemetry and control systems.
Date: 30 June 2023
e) Deliver a long term solution such that the break pressure tank and pump sump no longer constitute a single point of failure at the treatment works.
Date: Complete
f) Install UPS to system elements necessary to enable ramp-down of the applied chlorine dose in the event of a power failure or WQSD.
Date: 31 January 2023
g) Commission the UPS to system elements necessary to enable ramp-down of the applied chlorine dose in the event of a power failure or WQSD.
Date: 30 September 2023
23. Disinfection (Part B – Medium and Long term improvement): Complete the programme of works to mitigate risks associated with Disinfection, to include:
a) Confirm programme of works for long term ultraviolet treatment.
Date: 31 October 2023
b) Install long term requirements for ultraviolet treatment.
Date: 31 December 2029
c) Complete commissioning of all actions associated with Disinfection (Part B).
Date: 31 December 2030
24. Taste and Odour (Part A – Short term stabilisation): Complete the programme of works to mitigate risks associated with Taste and Odour (Part A), to include:
a) Undertake a study of taste and odour compounds in the raw water, including projected trends and evaluate the most appropriate carbon treatment to mitigate the risk.
Date: Complete
b) Install smell bells on streams 2 and 3.
Date: 31 December 2026
c) Commission smell bells on streams 2 and 3.
Date: 31 March 2027
25. Taste and Odour (Part B – Medium and Long term improvement): Complete the programme of works to mitigate risks associated with Taste and Odour (Part B), to include:
a) Confirm programme of works for long term solution for taste and odour.
Date: 31 March 2025
b) Implement long term solution for taste and odour.
Date: 31 December 2029
c) Complete commissioning of all actions associated with long term solution for taste and odour.
Date: 31 December 2030
26. Chemical dosing and storage: Complete the programme of works to mitigate risks associated with Chemical dosing and storage, to include:
a) Planning and installation of a new auto- coagulation system for each treatment stream and removal of the existing redundant auto-coagulation unit.
Date: Complete
b) Assess the ferric chloride bulk storage and day tanks and associated pumps and controls, orthophosphoric acid bund protection, and bisulphite tanks. Upgrade or replace where required.
Date: Complete
c) Replace polyelectrolyte dosing system.
Date: Complete
d) Replace hypochlorite dosing skid(s) to include appropriate automatic duty/ standby arrangement at pre-clarifier, post-clarifier and main dose points to prevent failure.
Date: Complete
e) Investigate and ensure chlorine monitoring is stable and not impacted by presence of orthophosphoric acid in sample water.
Date: 31 March 2023
f) Move orthophosphoric acid dosing point if necessary and commission changes made.
Date: 31 December 2023
g) Install monitoring on the pre-clarifier applied hypochlorite dosing.
Date: 30 September 2023
h) Review of PAC Storage & Dosing system condition and upgrade.
Date: Complete
i) Complete commissioning of all actions associated with chemical dosing and storage.
Date: 31 March 2024
27. High lift pumping: Complete the programme of works to mitigate risks associated with High lift pumping, to include:
a) Replace or refurbish high lift pump arrangement to ensure long term resilient operation.
Date: 30 June 2029
b) Commission step 27 (a). (New high lift pump arrangement).
Date: 30 June 2030
28. Site control: Complete the programme of works to mitigate risks associated with Disinfection, to include.
a) Install full Water Quality Shut Down functionality on chlorine main dose and final water quality.
Date: 30 June 2026
b) Commission full Water Quality Shut Down functionality on chlorine main dose and final water quality.
Date: 30 June 2027
29. 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.
Date: 31 January 2023
b) Completion of high priority works in programme in step 29(a) above.
Date: 30 September 2028
c) Commissioning of high priority works in programme in step 29(b).
Date: 30 September 2029
30. Decommission: Decommission redundant assets and demolish in accordance with the Company’s policy for asset decommissioning.
Date: 31 December 2031
Steps to audit the effectiveness of steps completed
31. Define an audit strategy to monitor the effectiveness of the steps specified above.
Date: One month from date order is made
32. Implement, and keep under continuous review, the audit strategy defined in step 31.
Date: Following completion of step 31 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 March and September 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 January 2033