Thames Water Pollution

Incident Reduction Plan

2020-2025 Version 1, September 2020

1

Overview

Our objectives for the next five years and beyond

Protection of the environment, including the responsible and sustainable use of natural resources, is

fundamental to our business. As a water company, our entire operational cycle links directly to the

natural environment. We need it to provide water for us to treat and put into supply, and we return

treated effluent back to the environment, providing flow that is needed to support the ecological health

and water quality of streams and rivers.

Wastewater is a pollutant that can potentially cause significant harm to the environment. Because of

this, everyone in our business works hard every day to protect the environment by taking steps to

prevent wastewater escaping from our network. These events most commonly occur from sewer

blockages but can also arise from leaks when mechanical equipment breaks down suddenly.

Our commitments

We recognise that we need to do more. In agreement with our regulators, we’ve committed to reducing

the number of incidents that cause a polluting effect by a minimum of 30% by 2025.

In addition, we’re also targeting a reduction in the number of the incidents that end up causing a serious

impact on the environment towards zero over the same period.

In order to deliver this improvement, we’ve developed a dedicated Pollution Incident Reduction Plan

(PIRP) to spearhead concerted action and reduce the number of pollution incidents over the next five

years. The plan identifies the various underlying root causes of pollution incidents, and we’ve developed

a series of interventions targeted at addressing these in a coordinated manner.

Aiming for positive impact

Our longstanding approach to being more sustainable has been to make sure we’re maintaining a

positive impact on society and the environment around us for many years. A key element of this is to

reduce the number of pollution events and protect the environment from harm.

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Our targets

A glide path for achieving a reduction in pollution numbers

We’re aiming to deliver a year-on-year reduction between now and 2025. This is to promote continuous

improvement on the previous year’s performance every year. To enable comparative assessment

between different sizes of water and sewerage companies (WaSCs) in England and Wales, the numbers

of pollution incidents are normalised per 10,000km of sewer network.

In 2019, we experienced 29.7 pollution incidents per 10,000km compared to the sector average of 37

incidents per 10,000km. For 2021-2025, we’ve set targets to reduce pollution numbers each year.

Total pollution targets 2020-2025

2020/21 2021/22 2022/23 2023/24 2024/25

Total Cat 1-3 pollution

incidents per 10,000km

24.5 23.7 23.0 22.4 19.5

All pollutions impact the environment, but the vast majority are classified as minor by the Environment

Agency, who are responsible for classifying all events from each WaSC. Unfortunately, a small number

of incidents do have a serious impact, often due to the nature of the incident or the sensitivity of the

environment. In this area, we’re targeting a stepped reduction towards zero by 2025. Due to the small

number of these events, we haven’t normalised the figures but focused on the total number of incidents.

Serious total pollution targets 2020-2025

2021 2022 2023 2024 2024/25

Total series pollution

incidents

<4 <4 <3 <3 <2

10.00

15.00

20.00

25.00

30.00

35.00

2020/21 2021/22 2022/23 2023/24 2024/25

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Format of the plan

A single management framework for all pollution reduction activity

We’ve set annual targets for pollution numbers that reduce every year between now and 2025.

Because pollutions are measured on a calendar year basis, our plan needs to reset every year to align

with the reporting period.

Therefore, we’ve designed the framework of our plan based on the structure of a management system,

and will follow a ‘Plan’-‘Do’-‘Check’-‘Act’ cycle on an annual basis.

Interventions

Every year we’ll conduct a robust root cause analysis to help identify the underlying causes of pollution

incidents. Based on the outcome of the root cause analysis, we’ll develop interventions to address the

most common underlying causes. We’ll deliver interventions within the year and monitor them closely

to evaluate performance. If the performance is off track, we’ll adjust interventions to recover

performance.

As the plan develops, we can begin to evaluate the performance of our interventions, opting to either

increase focus in these areas in following years or develop a different strategy with new interventions.

We’ve created an internal policy document that formalises this approach and embeds this activity

within our business structure. This internal document sets out the roles and responsibilities of identified

members of staff, the governance structure and an overview of the working methodology of the plan.

It also includes a list of the key processes specifically related to pollution reduction, identifying the

appropriate management systems as well as key pollution management and response procedures.

By designing our plan in this structure, we can incorporate it with our other management systems

under one single integrated management system.

Monitor performance of

individual interventions

Plan Do

CheckAct

Implement interventions against a delivery plan to achieve anticipated

pollution reduction

Identification of the

appropriate interventions

to reduce the number

of pollutions

Adjust interventions

when required

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Root cause analysis

Identifying the underlying cause of pollution incidents

Due to the size and scale of our operations, we have a large and comprehensive collection of root

cause asset failure information.Use of asset performance data to identify and prioritise investment is a

well-established principle of infrastructure management. For pollution events specifically, we’ve

designed a specific root cause methodology and software system to identify and record the underlying

issues that did cause, or nearly caused, a pollution incident.

The tool is split into two assessments – one to determine the asset-based failure mechanism and its

cause, and (when applicable) one to determine contributory factors such as human error or

organisational elements that may have been a factor in the event leading to a pollution.

Primary (asset failure)

Level 0 Asset type What type of operational asset failed?

Level 1 Process element Which part of the process?

Level 2 Implicated asset What type of asset failed and caused a pollution

incident to occur?

Level 3 Fault/issue What happened to the implicated asset?

Level 4 Cause Why did the fault occur?

Secondary (contributory factors)

Human Did any mistakes contribute to the severity of the incident?

Organisational Did the way we work or our management processes contribute

to the severity of the incident?

ICA Did any instrumentation, automation or control issue contribute

to the severity of the incident? (STW and SPS incidents only)

Example

A manhole chamber collapses as a result of ground movement. This restricts flows and causes debris

to accumulate. An engineer attends and incorrectly isolates the flows upstream when carrying out the

repair. As flow backs up in the upstream network, it leaks out of a manhole, spilling over into the

environment.

Primary assessment

Asset type Process – network

element

Implicated asset Fault issue Cause

Waste network Foul sewer Manhole chamber Structural failure Collapse

Secondary assessment

Human Organisational ICA

Human factor – Incorrect

isolation

N/A N/A

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Evaluation of historical root cause analysis data

In order to identify the appropriate interventions for the first year of our PIRP, we conducted a review of

our root cause data for all asset failure events in the period 2015-2020 that had the potential to impact

the environment. Firstly, we looked at the number of events by asset type to see where the biggest

pollution risk existed.

Proportion of incidents by asset type:

This demonstrated that the majority of operational failures that posed a pollution risk occurred from the

waste sewer network, either originating from a foul sewer or a surface water sewer.

We then investigated the most common faults associated with waste network pollutions. This showed

that the most common fault on the waste network was a blockage in the sewer. A blockage prevents

flow in the sewer (normally provided by gravity), which then backs up and forces its way out, normally

through a manhole or a weak joint in the system.

Incidents by Asset TypeProportion of incidents by asset type (top

Top 6

Foul sewer 57%

Surface water outfall 17%

Sewage treatment works 8%

Clean water asset 6%

Pumping station 6%

Pressure main (foul) 3%

Waste network faults Top 5

Blockage 50%

Misconnections 27%

Unidentified cause 10% Sewer defect 10%

Hydraulic overload 3%

Waste Network Faults

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We then considered the causes of each fault. The biggest causes were found to be ‘non-flushable’

rag/wet wipes incorrectly disposed of in the sewer, followed closely by large blocks of congealed fats,

oil and grease (FOG). Blockages were also caused by ingress into the sewer of roots as well as other

debris deposits, indicating no single cause can be simply applied to all events.

Waste pumping

Across our region, we own and operate thousands of individual pumping stations that range in size and

complexity. Irrespective of size, a pumping station collects flow from a series of sewers, pumping it

along the network towards our treatment works. Often, these stations are positioned at low points to

pass flows up hills or past obstructions. They normally include a series of pumps and valves and

operate automatically based on the flow levels recorded.

The most common faults were unplanned equipment failure of the pumps and issues with the power

supply at the site. We also found rag/wet wipes and FOG cause pollutions at pumping stations by

blocking pumps and valves.

Pumping Station Faults

Causes of blockages

Rag/Wet wipes 38%

FOG 33%

Roots 14%

Debris 11% Scale 4%

Unspecified 1%

SPS faults Top 5

Equipment failure 37%

Power failure 31%

Blockage 13% Hydraulic overload 9%

Incorrect site operation 5%

Causes of Blockages

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Waste treatment

Our treatment works collect wastewater from a sewerage catchment and treat it to strict quality

standards using a series of phased treatment stages. We then discharge the effluent into rivers and

streams, providing flow throughout the year.

These are larger, more complicated assets by design than sewers and pumping stations, and as such,

there’s a wider array of circumstances that can lead to an operational issue and cause a pollution.

Our analysis indicates that the most common occurrence is the unplanned failure of mechanical

equipment at the site – most often the inlet pumps, inter-stage pumps and aerators – so we’ll target our

interventions in this area to improve the performance and reliability of this equipment.

Cause of Equipment Failure

Implictated Asset at STWs

SPS equipment failure causes - Top 5

M+E breakdown 70% Automatic PLC error 17% Overheat (shutdown) 4% NRV failure 4% Impellor failure 2%

STW implicated assets

Pumps (inlet) 25% Pumps (inter-process) 17% Aerators 14%

Filter arms/rotation 9% Storm separation/tanks 8% Various other (combined) 27%

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Our interventions

Identifying appropriate interventions to reduce the number of incidents that can cause pollution

Like all water companies, our asset base is wide-ranging – from small, simple sewers to large, complex

treatment works with multiple treatment stages, serving catchments with over one million people.

Regardless of size or complexity, every asset can present a risk of environmental impact, as

demonstrated by our root cause analysis. Because pollutions from different asset types have different

causes, we’ve assigned our interventions by asset type based on the output of the root cause analysis.

This makes sure we can prioritise the correct areas and address the underlying causes in each case.

Irrespective of asset type, we’ve grouped our interventions into three general principles:

1.Prevention

Creating targeted initiatives to reduce the number of operational events that historically are at a higher risk of causing a pollution incident

2. Mitigation

Improving our response to such events to prevent or mitigate any polluting impact

3. Training and behaviour

Educating, training and motivating employees throughout all levels of our business to identify risks to the

environment and act urgently to prevent any impact – this includes developing and maintaining a

culture of openness and prioritising the best environmental outcome

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Waste sewer networks

Reducing flooding and pollution caused by sewer blockages.

Most of the potential pollutions we deal with every day are caused by blockages in our foul sewerage

system. This system is not designed to cope with excessive volumes of cooking fats, oils and greases

(FOG), along with ‘non-flushable’ sanitary products and wipes (rag) that have been incorrectly disposed

of. In more serious cases, building materials such as concrete and tarmac also cause blockages.

FOG and rag stick to the sides of our sewers as flow levels vary and begin to build up, eventually

blocking the sewer and forcing the contents to back up and spill from the nearest relief point. This is

often a manhole, potentially impacting people’s homes and gardens or the wider environment.

By reducing the number of blockages, especially at locations that are at higher risk of flooding and

pollution, we can prevent sewage being forced out of the sewers into the surrounding environment.

Hotspot mapping locations of blockages, flooding and pollutions

We record the location and the root cause of the reported blockages, flooding and pollution incidents on

a GIS system that also holds information on our network. Through this system we can identify hotspots;

link these hotspots to wider GIS information, such as development density, population information and

land use (e.g. location of food service establishments) to aid our analysis; and build a model to help

target our interventions.

The image below shows the frequency of blockages in our Greater London area as a heat map, clearly

highlighting the locations where blockages are more frequent than others.

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Our plan over the next five years to reduce blockages focuses on several interventions:

Increasing planned sewer cleaning

During a scheduled clean, we proactively flush out the foul sewer using specialist equipment. Although

this is an essential part of sewer maintenance, this activity can disrupt local residents with road closures

and noise, so it’s important we target sewers most at risk of blockages on a schedule that minimises

disruption.

Over the next five years, we aim to increase the volume of scheduled sewer cleans to a total of

9,500km. This is a substantial increase from previous years, so we need to prioritise our cleaning plan

based on the information we collect from the field and optimise the programme effectively. In

conjunction with hotspot mapping, we’re analysing potential environmental risk presented by a

blockage for each sewer section, ensuring that the cleaning programme is targeting areas that present

the biggest risk to the environment.

Developing an intelligent wastewater network system

Sewers are often buried beneath pavements and roads, but they also run under parks, fields and

woodlands. Historically, the first possible indication of a problem is only when symptoms such as a smell

or leaky manhole cover are noticed and reported.

New technology now makes it possible to gain a better insight into the live operation of our sewers than

ever before, with reliable, cost-effective wireless ‘sewer level monitors’ now readily available on the

commercial market. These can detect changes in the sewer levels and alert us to a potential problem

before the sewage is forced out of the network.

We’re fully behind this new shift in waste network management. We plan on installing 18,500 sensors to

give us a much clearer live picture of the hydraulic behaviour across our network at any one time.

As this is a dynamic and fast-paced market, we’re also keeping an eye out for further innovations in

case new technology becomes available.

What’s a ‘sewer level monitor’?

A sewer level monitor is an ultrasonic unit that is able to

detect changes in the flow level in a sewer.

They can be calibrated to signal when a certain level is

reached, communicating an alert wirelessly to a control

centre.

The sensors rest in at the top of a manhole chamber, so

they can be easily accessed by maintenance teams and

are out of the way of sewer flows, protecting them from

damage.

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Tackling the problem at source – preventing the incorrect disposal of products via the sewerage system

Whilst steps are being taken to mitigate the problem of blockages and prevent them from forming, the

ultimate success of this activity rests with addressing the problem at source - the incorrect disposal of

products via the sewerage system.

These don’t just cause blockages – a large amount also find their way into our treatment works and

pumping stations, causing damage to the equipment. On average, we unblock five household

blockages and remove 30 tonnes of ‘non-flushable’ material from just one of our sites each day.

We have two dedicated programs running to tackle this problem: our well-established ‘bin it – don’t

block it’ campaign and our more recently launched business customer network protection programme.

Bin it – don’t block it

Our ‘bin it – don’t block it’ programme has been running for several years. It’s been remarkably

successful in increasing our customers’ awareness of the problems associated with disposing of wet

wipes and cooking fats incorrectly. To maximise its benefits, we’re targeting the programme in specific

areas where our hotspot mapping identifies the most risk.

This includes letter and pamphlet drops at local addresses after we’ve removed a blockage as well as

billboards, radio adverts and social media activity. In some cases, targeted areas have seen a 26%

reduction in sewer blockages with 70% of residents saying they’ve changed their binning behaviours.

As part of our plan to reduce pollutions, we’re hoping to contact five million households by 2025.

We’re also working with manufacturers to correctly label wet wipes, as we know from experience that

the term ‘flushable’ isn’t accurate where sewers are concerned. These items still contain plastic, which

The problem with FOG and rag

Wet wipes and other unflushable materials congeal with

incorrectly disposed fats, oils and greases to create large,

immobile clumps in the sewer system.

They block sewer flows and cause sewage to force its way

out from the easiest point, which leads to pollution or flooding

in nearby homes and gardens.

Blockages like these are the biggest cause of sewage

pollution in the UK.

We recommend only flushing the ‘3Ps’– poo, pee and paper.

Look out for the Fine to Flush logo on products that meet the

strict standards to be flushed down the toilet.

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contributes to the clogging of pipes. We’re aiming to influence manufacturers to remove the plastics in

the wipes, as this makes the materials slow to break down and also harms the environment.

Business customer education

Our analysis shows that a blockage is significantly more at risk of forming at locations close to food

service establishments (FSEs). FSEs often produce a large volume of waste oil, which is commonly

disposed of via the foul sewerage system.

Increasing and enhancing sewer rehabilitation activity

Our foul sewerage network is vast, and if connected end to end, it would almost stretch around the

world three times over. Typically, sewers are long-lived assets with a low likelihood of structural failure,

but occasionally sections do become defective before their expected service life due to environmental

and operational pressures. Most often, a sewer either splits or collapses, causing sewage to leak out,

or a break in the sewer allows for groundwater or surface water to enter, which can restrict capacity

further down within the network. Both can be a cause of pollution.

We routinely inspect the condition of our sewers and identify defects before they become major issues,

and we intend to upscale our programme over the next five years. Phase 1 is beginning with a large

specialist CCTV survey of 400km, which will identify sections that need to be replaced or relined, with

prioritisation given based on the condition found. One technique involves re-lining sewers made of older

materials (such as ductile iron pipes with new CIPP polymer materials) to improve the structural stability

of old pipes and prevent corrosion from effluent without having to excavate along the whole length.

Resources for restaurants

We now have a dedicated team in place to liaise

directly with FSEs, and under our statutory powers, we

can inspect premises, provide advice and guidance

and, if necessary, enforce compliance.

Our target is to contact 11,500 businesses over the

next years, helping to make sure they’re always

compliant with wastewater disposal requirements.

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Identifying and resolving incorrectly connected drainage

Surface water outfalls are part of drainage systems designed to only discharge surface water (i.e.

rainwater) back into watercourses to prevent flooding in urban areas. However, due to the size of

drainage catchments and the nature of connections into the system, surface water flow can become

contaminated with urban pollutants such as wastewater, industrial/commercial wastes that contain

chemicals (paints and solvents), as well as oils and fuel from road run-off or illegal fly-tipping.

We own several surface water assets (although drainage systems under different ownership are

prevalent), and whil3 we’43 not liable for actions caused by individuals using these assets incorrectly,

we want to actively take steps to identify which outfalls are contaminated with diffuse urban pollutants.

Often working with local conservation groups, we have a comprehensive survey programme to inspect

outfalls and investigate the drainage catchment to identify the causes. This work goes a long way

towards improving the quality of the surface water discharge and stopping the polluting effects.

We have a dedicated team, well-established and in place for a number of years, who works closely with

local conservation groups and our regulator to improve multiple outfalls across our region. Between

2015 and 2020, we identified and improved a total of 200 individual outfalls following in-depth

catchment investigations to resolve the sources of contamination.

We’re continuing this programme as it forms a key part of the specific interventions we have in place for

our waste networks assets.

What is a ‘misconnection’?

A misconnection is when foul drainage (toilets, sinks

and washing machines) is incorrectly connected to

surface drainage (rainwater).

Under Section 109 Water Industry Act 1991, it’s

unlawful to discharge foul water into a sewer provided

for surface water where separate public sewers are

provided for foul water and surface water.

The property owner is responsible for fixing

misconnections, and the majority do as soon as they

become aware of the issue. A local plumber should

be contacted to resolve misconnections.

For more advice, visit www.connectright.org.uk

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Pumping and treatment sites

Upgrading our infrastructure - Delivery of capital investment programmes and asset improvements

We have one of the largest investment programmes in the UK water industry. This includes the

refurbishment and replacement of specialist equipment, site-wide upgrades to accommodate increased

growth in the local area, and enhanced treatment stages to achieve stricter environmental quality

standards on the treated effluent discharged at a site.

A wide-ranging series of upgrades is planned for 2020-2025, and we’ll align our PIRP with this capital

maintenance activity to prioritise the delivery of programmes with improved environmental protection,

wherever possible.

Our decision-making support tools are vital in identifying risk and prioritising capital investment. Over

the next five years, we’ll further enhance these tools with the information extracted from our root cause

analysis and equipment performance monitoring data. This will ensure we prioritise the right assets at

the right time, helping to reduce environmental risk and prevent pollution.

Ensuring optimum performance and reliability

Maintenance and operating policies

In addition to replacing and upgrading equipment and assets, a vital aspect of ensuring high

performance standards on-site is robust routine inspection and maintenance programmes in

conjunction with clear and effective site operating polices. These can range from simple activities, such

as the recommended frequency of general site tasks, to more complex instructions, such as testing the

capability of stand-by generators under ‘live test’ conditions at our largest operational sites.

We’ll review our routine maintenance standards and operating processes over the next five years to

ensure asset performance is efficient and reliable, reducing the frequency of equipment failure and the

potential impacts to the environment that can occur as a result. Initial focus will be on the systems and

procedures in place on alarm testing, power systems, pumping equipment and screen handling units,

but the scope will increase over the lifecycle of the plan.

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Our Environmental Management System (EMS) We operate our wastewater assets and activities under a dedicated Environmental Management

System (EMS). This is a framework of policies, processes and procedures that helps to minimise all

environmental impacts associated with our operating activities.

At Thames Water, our EMS is specifically designed around our operations, with processes and

procedures that are easy to access and that our teams follow. This makes sure we operate our assets

in the same consistent manner and take actions to continually improve in order to enhance

environmental performance.

Our Pollution Incident Reduction Plan will incorporate those elements of our EMS most targeted

towards preventing pollution and reducing environmental risk, with particular focus on site inspections

and audits, chemical storage and event learning.

How an EMS helps our teams

Managing our activities with an EMS helps our front-line teams.

“I can easily and

effectively

challenge issues

that may lead to

non-conformance”

“I know the

results my site

must achieve and

how this

contributes to

environmental

performance”

“I’m aware of our

environmental

policy and I

understand the

implications of not

complying with

the EMS”

“I understand the

environmental

impacts

associated with my

work and know

how to control

these risks”

“My role and

responsibilities

have been made

clear to me”

“The information I

need to do my job

is instantly

available on my

device”

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Effective remote control and monitoring

A major aspect of modern wastewater infrastructure management is automatic operation and remote

technology monitoring systems. Our telemetry systems are linked and enable the automatic operation

of most of our asset base, meaning we can direct resources to respond to non-routine events and

alarms. While our SCADA system is monitored at various locations, we conduct overall oversight at our

central Waste Operation Control Centre (WOCC). We manage our operational information, asset status

and response processes in accordance with a quality management system, which mandates periodic

reviews of performance to develop continuous improvement in this area.

Using predictive analytics tools

We utilise a bespoke software program that visually displays live operational information. Where

appropriate, we install equipment on site. The system has the capability to monitor and record a suite of

operational performance data, such as flow levels, power efficiency and equipment run times against

pre-identified tolerance limits. This is simplified with a basic ‘Red Amber Green’ status for each site,

such as whether duty, assist and standby pumps are available and operational. We can also see the

history of the site through links to our work management system, allowing us to review work (both

reactive and planned) that’s been assigned to the site, as well as important environmental information

like proximity to a watercourse and ‘time to spill’ in the event of pump failure.

A sudden change in a parameter like energy demand can provide an early indication that an asset or

piece of equipment isn’t operating under expected parameters, potentially indicating a developing fault.

We can raise an inspection ticket before a complete failure of the equipment occurs.

Through our PIRP, we’ll expand our analytical tools to extract and evaluate this data. This means we

can take a diagnostic, proactive approach to identifying potential problems, enabling intervention before

a pollution incident occurs. The figure below displays how comparative energy trends between sites can

be used to identify potential abnormal operation.

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Expanding and improving remote telemetry coverage

Over the past few years, we’ve invested in additional telemetry units to provide more information on the

live operational performance of our assets. Our plan is to further increase coverage in this area as well

as develop enhanced tools to manage the vast quantities of information we receive every day. This will

ensure key information is clearly recognised and acted upon without delay.

We plan to roll out an increased number of specialist telemetry units that allow for high resolution, real-

time effluent quality data to be acquired for multiple parameters. Typically, we install these meters at the

end of the treatment process to check whether the final discharged effluent is within environmental

limits. However, we plan to add additional monitors earlier in the treatment process following successful

pilot trials, as these demonstrated that events with the potential to impact final effluent could be

identified and resolved earlier. Our plan is to install approximately 100 of these units across our

treatment sites as part of the PIRP.

Adverse Weather Preparedness

Adverse weather is one of the key operational pressures on our asset base. High rainfall increases flows

within sewerage systems dramatically, storms can cause issues with power supply and transport

networks, and fluvial flooding can present a risk to our operational sites located adjacent to

watercourses. Severe temperature extremes also can impact equipment operation of the effectiveness

of our biological treatment plants.

Having a large degree of resilience to such events is therefore crucial, especially as our weather

patterns become more variable due to climate change. We have equipment and systems in place

ensure continued efficient running of our infrastructure during adverse weather events, and we will

continue to invest and improve in this area to increase the resilience of our asset base.

We use industry leading software to give us the most accurate and up to date weather information,

which can be broken down to a regional level. Using this information, we are beginning to develop set

levels for each weather state on a site by site basis to identify what operational action is required at

what stage, to ensure a consistent response every time.

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Thames Water already has dedicated Adverse Weather management processes that kick in during

these periods. In order to ensure that we are confident our sites are prepared for upcoming adverse

weather, we are producing site specific adverse weather limits, as a guide for local operators to take

the necessary steps under certain conditions to increase resilience.

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Training, capability and contingency planning

Training, Skills and Capability

In any industry, routine and effective staff training is required to improve, maintain or develop capability

and competency. At Thames Water, a dedicated Learning and Development team coordinate a wide

range of courses and programmes to cover our range of operations and training requirements.

We have recently refreshed our general operator training package with enhanced environmental and

pollution prevention material, which is shortly due to be rolled out and will be mandatory for all our front-

line staff and management. As we progress over the next five years, we will further expand our

environmental training, with particular focus on response and mitigation, upskilling our staff with the

knowledge to identify risk to the environment and the necessary steps to take to prevent pollution. We

will be working to develop, new online classroom courses on our training platform to ensure we can get

important information around environmental protection disseminated easily throughout our organisation.

We are also looking to provide our technical staff with the opportunity to earn external academic

qualifications. New for 2020, we are funding four of our Process Scientists to undertake a two-year

(part-time) MSc courses in wastewater management, which we intend to continue each year to enable

a significant cohort of our Process Science team to gain this qualification.

Responding to failure - mitigating impact and preventing serious pollution

Environmentally focused response

Located within our Control Centre is a 24hr Pollution Control team, which co-ordinates the

environmental response to any operational event or issue that could potentially cause, or has caused,

an environmental impact. When the desk is informed of an incident, staff are trained to assess the

possible impact and respond accordingly, calling on specialist resources where necessary, to ensure

the clean-up is dealt with in the most appropriate manner.

Our field teams are trained to identify, report and mitigate environmental impact using specialist

equipment. We will focus on maintaining and improving this capability through training and performance

reviews, evaluating the effectiveness of our pollution response.

We are looking to expand our resources in this area with the development of response manuals,

documenting best practice, mitigation strategies and general environmental guidance so our field teams

have access to specialist information whilst on location.

Response and mitigation equipment

Our plan is to always prevent a pollution incident where possible, but it is still important to take steps to

have the capacity to mitigate the impact when an incident does occur. We have an inventory of

specialist response equipment that is used to improve water quality following a pollution event.

It is often the case that aerators (mechanical equipment used to provide oxygen into a watercourse)

cannot be used in small, shallow watercourses because the sediment disturbance may increase harm

further. In conjunction with our Innovation team, we have developed two unique forms of ‘shallow water’

aerator unit using novel technology designed in-house. Following successful trials we aim to roll these

units out by the end of Summer 2020.

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Next Steps

Assessing performance, refining the interventions, and planning for the future.

Our ‘Plan-Do-Check-Act’ cycle is designed to include routine performance monitoring of our

interventions to check their effectiveness. Using this information we can then expand our resources in

areas that are effective, driving continual improvement. We will also be able to identify which

interventions require refinement or additional focus.

We will begin the Planning stage for our Year 2 Targets and interventions in October/November 2020. A

number of our programmes are phased over the five-year investment cycle, with some years containing

additional activity volumes.

As part of our ‘Planning Stage’, we will comprehensively review current performance and also engage

with our colleagues within our organisation, as well as with our regulators and stakeholders to ensure

everybody has an opportunity to contribute to the ongoing development of our PIRP.

The Future

This plan sets the foundations for our future ambition to cause zero harm to the environment.We aim to

operate our business in the most sustainable manner - contributing to the circular economy through

renewable energy generation, energy efficiency, responsible financing, a far-reaching water efficiency

programme and inspiring future engineers, are just some of the activities we’ve been driving.

However, in order to provide a better environment in the future, we need to reduce the environmental

impact of our day to day activities. This plan outlines the steps Thames Water will be taking to deliver

this commitment.