2023

Mirte van den Boogaard: "We need to do more and more to keep drinking water quality up to par."

WML (Water Management Company Limburg) appealed against the new discharge permit of chemical company Prayon in Wallonia. The drinking water company prefers to meet with discharging companies, as in the Mutual Gains Approach meeting with Circle Infra Partners, says Mirte van den Boogaard of WML.

WML supplies drinking water to more than 560,000 private customers and almost 14,500 business customers in Limburg. Self-evidently, the sources for drinking water - the Meuse and groundwater - should be of the best possible quality. This is what Mirte van den Boogaard deals with, as Advisor for Environmental Management Water Quality.

"Governments manage our resources, so we need to work with them to ensure the quality of our resources," she says. "We also seek cooperation with companies that discharge waste water into the surface water in the Meuse river basin."

The water quality of the Meuse can fluctuate greatly, she also says. "Due to changing production processes of companies or calamities, other substances may be discharged into the river. At the same time, it may be due to the weather: if it has rained a lot, there is more water to dilute discharges than when the river is low."

Appeal

Last September, WML submitted an appeal in Wallonia against the new discharge permits issued to Prayon, a Belgian chemical company that makes phosphate products such as plant food, fertiliser and baking products. "In their production process, a number of chemicals are released that cause difficulties for us when making drinking water," says Van den Boogaard. 

These are mainly di-isopropyl ether (DIPE) and tributyl phosphate (TBP). "These are substances that we absolutely do not want in our drinking water. So this does not belong in our sources either, because we don't have to remove what's not in them.” 

Abstraction stops

If there is an excessive amount of certain substances in surface water, a drinking water company is not allowed to extract water for drinking water production, according to the Drinking Water Regulations. WML has regularly had such abstraction stops in recent years. In 2023 it was for 126 days, in 2022 for 218 days, and in 2021 for 184 days. Van den Boogaard: "The number of days with abstraction stops has increased in recent years. For us, that means intervening and adjusting all the time."

Apart from increased discharges of harmful substances, this is because new techniques and innovation make it possible to measure more substances. "In addition, there is a connection with climate change," explains Van den Boogaard. "It has been very dry for a couple of years, which reduced the dilution of contaminants by rain. We'll see this more often in the future." 

She also says that in 2022, there was an abstraction stop for a long period of time because of explosive algae growth. This was caused by a lack of flow in the Grensmaas (Border Meuse), a higher water temperature and high solar radiation. "The substances released in the process, neophytadiene and heptadecane, were only identified after several weeks. As long as the investigation was ongoing, the abstraction of Meuse water was stopped as a precautionary measure."

Groundwater

The drinking water company does not directly purify the water that WML pumps from the Meuse, she continues explaining. First, the water enters a large reservoir, where it is pumped up via the bank after about two years. A well-filled reservoir also serves as a buffer in case of an abstraction stop. When no more water from the reservoir can be used, WML switches to groundwater.

However, drinking water companies are only allowed to pump up limited amounts of groundwater, as this could otherwise possibly have a negative impact on nature. The permits allow for little flexibility. "Basically we want to use the surface water as much as possible," says Van den Boogaard. "Groundwater is more calcareous, so you have to inform customers about that. This is not unhealthy, but can cause limescale deposits on household appliances."

Not future-proof

WML and Rijkswaterstaat discussed WML's problem due to Prayon's discharges with the Service Public de Wallonie (SPW), the public authority similar to Rijkswaterstaat that issues permits to Walloniancompanies. However, Prayon's new permit, issued in August 2023, was not a solution for WML. The drinking water company decided to appeal against the permit.

The permit states that Prayon is adapting a part of the plant, achieving a reduction of DIPE emissions from 300.9 tons to 88.8 tons per year from 2028. Van den Boogaard: "A big reduction, but unfortunately not enough, because even with that amount we have to shut off our abstraction at low Meuse flow rates." She adds to this: “The permit states that the company will commit to further reduction of DIPE and TBP after 2028, but this is not specified."

This new permit is valid for 20 years, until 2043. "The efforts to be made between 2028 and 2043 are unclear. In any case, a 20-year permit is extremely long," Van den Boogaard believes, "especially at a time when a lot is in flux, both in the sector in which Prayon operates and in the drinking water sector. In short, the permit contains good intentions, but it is not concrete, enforceable and future-proof."

Photo 5: Mirte van den Boogaard, Adviser for Environmental Management Water Quality at WML.

Water Framework Directive

According to WML, the permit is also a violation of the Water Framework Directive. "The water that Prayon is discharging is classified as ‘not in good condition’ and should not deteriorate further," explains WML’s adviser. "The European member states have agreed with each other that it should be possible to make drinking water from surface water with minimal interventions, and that is not possible with this kind of discharge." 

WML decided to appeal without involving other water companies and RIWA-Meuse, although they support the appeal, Van den Boogaard says. "WML is the only drinking water company with a direct interest in stopping these discharges. Our abstraction point is closest to Prayon's discharge point. At the other drinking water companies, the contaminants have already dissipated or diluted to the extent that an abstraction stop is not necessary." 

Understanding each other

WML would rather avoid these kinds of legal processes. Therefore, the drinking water company is participating in the Mutual Gains Approach (MGA) on Circle Infra Partners' discharge permit together with Circle Infra Partners (formerly Sitech Services BV), Evides, Dunea, Waterschap Limburg, the Province of Limburg, Het Waterlaboratorium and Rijkswaterstaat.

An MGA is a consultation about a particular permit, in which stakeholders meet regularly, with the idea of helping each other rather than getting in each other's way. WML is very positive about it. Van den Boogaard: "We make arrangements in advance so that we get a permit that is workable for all parties. As a result, you don't have to go down the legal route, or less so. Everyone serves their own interests, but they also have an understanding of each other." 

Finger on the pulse

The consultation started around 2017 following the permit of Circle Infra Partners (then Sitech Services BV) from 2016, which WML also appealed against at the time. The new permit was published in 2020.

The new permit of Circle Infra Partners contains over 600 substances. Van den Boogaard points out that the company discharges many of the substances in such low concentrations that WML is not affected. However, for AMPA for example, one of the drinking water-relevant substances, the situation is different. It was regularly found at the abstraction point in concentrations higher than the norm, which forced the drinking water company to stop the abstraction of Meuse water. 

The permit has been in use for a number of years, but the parties involved still meet several times a year. "For example, this permit contains concrete requirements on the reduction of AMPA," Van den Boogaard explains, "and states that the company will conduct research on microplastics. In such an MGA process you keep your finger on the pulse."

More effort

A company may have to modify a permit at some point because new purification techniques are available, or more is known about certain substances, she further states. "The developments follow each other quickly, so it's good to stay in a dialogue, and not just talk to each other when the permit needs to be changed." She emphasises: "Of course, we would prefer not to have harmful substances in the surface water, but we try to look at this with a realistic eye. This approach allows us to have a better understanding of what is being discharged and to bring in our interests." 

In short, WML, like other drinking water companies, faces challenges regarding water quality. But, says Van den Boogaard: "The drinking water that we ultimately supply to our customers remains of very high quality and we are obliged to do this. And then, very clean, safe drinking water just comes out of the tap. But that takes a lot of effort, raw materials and energy. "We need to do more and more to keep quality up to par."