Two Permits, No PFAS Monitoring: The Discharge Consent Structure at Hillhouse

Document research conducted in March 2026 has identified a regulatory arrangement at the Hillhouse site that is not immediately apparent from the publicly described investigation.

AGC Chemicals Europe Ltd holds an Integrated Pollution Prevention and Control / Industrial Emissions Directive permit (EPR/BU5453IY) covering the Hillhouse site. This permit governs what enters the on-site drainage and effluent treatment infrastructure — including the treatment of process wastewater.

The discharge consents for the actual outfall pipes — the points at which water exits the site and enters the River Wyre estuary and Royles Brook — are held by a separate entity.

Thornton Facilities Management Limited

Thornton Facilities Management Limited (Companies House number 04673430) is a property management company registered at One St Peter’s Square, Manchester. Its SIC code is 68320: management of real estate on a fee or contract basis. Its operating address is listed as Hillhouse International, Fleetwood Road North, FY5 4QD. The company was incorporated on 20 February 2003 — originally under the shelf company name Inhoco 2814 Limited.

Thornton Facilities Management holds two Environment Agency discharge consents for outfalls from the Hillhouse site.

Permit 017290033 — Wyre Estuary

Receiving water: Wyre Estuary (tidal river / estuary)
Type: Trade discharge — site drainage (contaminated surface water)
Grid reference: SD3475043750
Permit issued: 31 July 2008
Current version: 14

This permit covers the discharge of contaminated surface water from the site into the Wyre Estuary. It is the outfall that corresponds to the discharge point measured in independent research as containing PFAS at concentrations significantly above proposed regulatory limits.

The permit contains no PFAS monitoring requirements.

Permit 017290384 — Royles Brook

Receiving water: Royles Brook (freshwater river, flows into the River Wyre)
Type: Sewage and trade combined surface water
Grid reference: SD3429043400
Permit first issued: 21 January 1999
Current version: 1

This permit was first issued on 21 January 1999. It is at version 1. It has not been updated in 27 years. PFAS compounds were not a regulatory focus in 1999; EEA-NH4, the chemical currently discharged to the River Wyre from this site in quantities of approximately 793 kg per year, was not identified as a substance of concern at that time.

The permit contains no PFAS monitoring requirements.

The Regulatory Picture

The result is a split structure. AGC Chemicals Europe holds the permit governing what enters the treatment system on site. Thornton Facilities Management — a property management company, not a chemical manufacturer — holds the consents for the pipes that carry material out of the site and into public waterways.

Neither permit requires monitoring for the PFAS compounds that independent research has measured in the receiving waters. The Environment Agency’s own risk evaluation (2023) estimates approximately 793 kg/year of EEA-NH4 currently discharges from the site to the River Wyre. Peer-reviewed research (Cousins, Dalmijn et al., Environmental Science & Technology, 2025) measured PFOA at concentrations exceeding 20,000 ng/L near the site’s outfall — a figure substantially above the proposed UK Environmental Quality Standard of 100 ng/L for PFOA in surface water.

The discharge consent for the Wyre Estuary outfall (permit 017290033) has been revised 14 times since 2008. The most recent revision does not include PFAS monitoring conditions. The discharge consent for the Royles Brook outfall (permit 017290384) has not been revised at all since it was first issued in January 1999.

Questions Raised

This structure raises questions that have been submitted formally to the Environment Agency:

How do AGC’s IED permit and Thornton FM’s discharge consents interact in regulatory terms?
Is the EA satisfied that the current permit conditions for permits 017290033 and 017290384 are adequate given the PFAS concentrations documented in the receiving waters?
Why has permit 017290384 not been updated since 1999?
Does the EA consider the split permit structure to present any regulatory gaps in terms of PFAS accountability at the point of discharge?

Responses will be published here when received.

Sources: Companies House — Thornton Facilities Management Limited (04673430). Environment Agency Discharge Consent Register — permits 017290033 (v14, issued 31/07/2008) and 017290384 (v1, issued 21/01/1999). Environment Agency Risk Evaluation for EEA-NH4, 2023. Cousins, Dalmijn et al., “Per- and Polyfluoroalkyl Substances in Water and Sediment near a Fluoropolymer Manufacturing Facility,” Environmental Science & Technology, 2025 (PMC12312159, DOI: 10.1021/acs.est.5c07856). AGC Chemicals Europe IED permit EPR/BU5453IY.