2023

Sylvia Vanhommerig and Karin Meeuwsen: "This transparent permit means we are miles ahead”

Drinking water companies view the discharge permit of Circle Infra Partners, formerly SitechServices BV, as an example. The company purifies the waste water from 60 factories at the Chemelot industrial estate in Limburg. There has been a lot of criticism in the media. We discussed this with Sylvia Vanhommerig and Karin Meeuwsen from Circle Infra Partners.

The waste water from the factories on the Chemelot site ends up in the Integral waste-water Treatment Plant, or IAZI, of Circle Infra Partners. After treatment, the water flows through a branch of the Ur into the Meuse, near the Natura 2000 site known as the Grensmaas. About 30 kilometres downstream, the Limburg drinking water company WML draws water from the Lateral Canal, after which the water is purified for use as drinking water.

The current discharge permit for this, which has been in force since the end of 2020, has been drawn up in cooperation with the Limburg water board, the provincial authorities, Rijkswaterstaat and the drinking water companies. For drinking water companies, this permit is a model for other permits: it lists all substances that could be discharged, with reduction targets for the discharge of a number of harmful substances.

A total of 630 substances are listed in the permit. "We have described at substance level what we discharge and in what concentrations," says Sylvia Vanhommerig, Director of Operations. "Other chemical companies may discharge more substances, but they only mention a few substance groups in the permit, not every substance in them.” Her colleague Karin Meeuwsen, QESH Permits Manager: "By being so transparent, we really are miles ahead of the rest in the Netherlands."

The reason

According to the Environment Act, which incorporates most of the Water Act, all substances discharged by a company must be listed in a permit, but – strangely enough – this often does not happen. In many cases, relatively general parameters are included in permits that are important for proper biological treatment. The complete picture is often still missing, for instance for all Substances of Very High Concern (ZZS), which are on the RIVM list, and for substances that are difficult to purify by drinking water companies.

So why do the permits for the Chemelot plant include all the substances? The reason was an incident in 2015, Vanhommerig and Meeuwsen recount: one of the factories had discharged the harmful substance pyrazole in quantities that were well above the drinking water standard in the Meuse. Vanhommerig: "We never wanted to see that again and that’s when we gained momentum. As Chemelot and Circle Infra Partners, we want to ensure that the water we release does not cause problems for drinking water and ecology." 

The drinking water companies have seen fewer incidents from Chemelot since the permit came into force: fewer harmful discharges from the factory site. "When we exceed the standard, which fortunately happens less and less, we contact the drinking water companies directly," says Meeuwsen. "Because then they can be alert to it in their abstraction. Drinking water companies would be able to trace the source and act much faster if all companies had transparent permits like us."

Photo 1: The Integral Waste-Water Treatment Plant, or IAZI, of Circle Infra Partners.

Alternative substances

In the past, the drinking water companies that use the Meuse as a source often had to deal with, for example, the substance AMPA, which ended up in the Meuse both as a breakdown product of herbicides in agriculture and from the Chemelot site. In recent years, the emission of this substance from Chemelothas been greatly reduced. A number of companies used a substance that was converted into AMPA during biological treatment to prevent deposits and corrosion in cooling water systems. The cooling water can then be reused. "The companies have started using alternatives to this AMPA-forming substance that are not as harmful to drinking water or not as difficult to purify," says Meeuwsen. "A number of installations have been converted and experiments have been done. Not all products were equally effective, but we eventually found good alternatives."

Circle Infra Partners is continuing to work on reducing the substances on the list of Substances of Very High Concern (SVHCs). Meeuwsen: "We are obliged to minimise the SVHCs. But at a certain point, technically, it hits a limit." She cites mercury as an example. "We have already done a great deal, and only 200 grammes were discharged last year. Removing these kinds of quantities from the treated waste-water - more than 3,500 Olympic swimming pools a year - is a nonstarter."

More and more substances discovered

In searching for possibilities to reduce the discharge of Substances of Very High Concern, Circle Infra Partners also looks at the source, namely the factory on the Chemelot site where a specific substance originates. "There still might be some room for improvement," says Meeuwsen. "Smarter purchasing of materials, trying alternative substances. We will keep looking, because we need to reduce emissions of SVHCs.” In addition, she said: "We see that we have been a little too ambitious on some of the regulations in the permit and that we are running into technical limits."

Her colleague explains: "As measuring and analysis techniques continue to improve, we are discovering more and more substances in the water. Of course, we want the quality of the water we are discharging to be good, but how far should you go? That is a trade-off we have to make. Should you put all your energy into those substances that are found in very small quantities or first make sure that those larger quantities are well regulated? Especially because the ecology and drinking water quality is now reasonably well guaranteed. We can't do everything at once."

Photo 2: Sylvia Vanhommerig, Director of Operations and Karin Meeuwsen, QESH-Permits Manager at Circle Infra Partners.

Criticism in the media

The drinking water companies are satisfied with the current permit and the course of action by Circle Infra Partners, but there is a lot of criticism from the media, politicians and environmental organisations. "There is a perception that we pollute more, discharge more than other companies," says Meeuwsen. "It is difficult to explain that you discharge 630 substances and that this is actually better than five groups of substances."

Vanhommerig adds to this: "We're still figuring out how to better explain that. For example, we want to engage more in a dialogue. In what form and with whom is still an ongoing search.”

Cold feet

RIWA-Meuse fears that, because the waste-water permit for Chemelot chemical park is so under fire, other companies will get cold feet and be reluctant to opt for a similar extensive discharge permit. "A justifiable fear," Vanhommerig responds. "But to gain social acceptance, transparency is ultimately needed."

The ambition of Circle Infra Partners is to eventually stop discharging harmful substances into the Meuse altogether and continue to reuse all the water. In other words: to make all processes circular. "Unfortunately, this will not be possible tomorrow, but hopefully will be in 20 or 30 years, depending on how fast technological development occurs," says Vanhommerig. "We are aware that the environment will soon no longer accept the discharge of any substance, in any small quantity."

Sharing the burden together

Both interviewees point out that even if the chemical industry stops discharging, many harmful substances will still end up in the water. "We understand that the water board wants us to continue to improve, but we argue that this should also apply to other types of discharges, such as from other industries, from farms and from municipal waste-water treatment plants."

They would also like to see more shared responsibility within the chemical sector. "We are front-runners, which means we have to figure out a lot of things," says Vanhommerig. "For that, we need a lot of people and have to incur a lot of costs." This, she explains, is detrimental to the competitive position of the companies on the site and also to the investment climate: new users are being subjected to more stringent permit requirements than on other sites.

Finally, she says: "We don't want to run away from this responsibility; we are all served by this, but other big dischargers can now ride along for free. We'd rather do that innovation together, learn from each other and share the costs."