Industrial Wastewater Violations: What Are They and How to Handle Them?

Roei, we want to talk about industrial wastewater violations. Tell me briefly, what are violations?

In 2014, regulations were established regarding the discharge of industrial wastewater into the sewage system. These regulations define which parameters are measured at the point of discharge. They also detail the parameters to be measured and the standard values for each type of plant. Generally, wastewater is divided into "Permitted Thresholds" and "Prohibited Thresholds," while for very specific parameters, there is also a threshold for "Excess Permitted Wastewater." What does this mean? Excess permitted wastewater can be discharged, but it is still considered a violation, resulting in an additional payment, though it is lower.

Who actually enforces these regulations?

According to the regulations, payments are required for both excess permitted and prohibited wastewater. For prohibited discharge, the payment is high, and for excess permitted, it is lower. Who pays? The discharger. The plant discharging the wastewater pays levies, and the entity collecting the money is the regional Water Utility, or if one doesn't exist, the company operating the municipal Wastewater Treatment Plant (WWTP). Sometimes these are companies owned by the local council, a local development company, or a franchisee.

How do the authorities know if there are violations?

Every plant has a sampling plan. This plan details the samples to be taken, the frequency, the type of sampling, and the parameters to be measured in each instance. The sampling plan is public and can be viewed online. A certified sampler from a laboratory authorized by the Ministry of Environmental Protection arrives and takes the sample. They test pH and conductivity on-site, and the rest is taken to the lab for in-depth analysis.

The sampling point varies from plant to plant. In principle, sampling should be conducted at the unified industrial flow—meaning, at the final manhole containing all flows exiting the plant. This also includes domestic wastewater such as toilets, sinks, etc.

Is the sampling time scheduled in advance?

Usually, it is a time window based on the sampling plan.

What should a plant do if it exceeds the limits?

That is a very general question. It depends on the violation. Let's break it down.

If it involves "excess permitted wastewater," it is often not worth doing anything other than paying. The payment is not high, and there is no legal prohibition on discharging it. In most cases, treating wastewater to reach permissible levels without deviations from Table B values (according to Water and Sewage Corporations Law) will cost more than paying the small violation fine—depending on the flow rates discharged. For prohibited wastewater, however, there are several options. The cheapest option would be to apply for a specialized discharge permit. This involves asking the Ministry of Environmental Protection for a change in standards for the specific plant, which usually comes with a set tariff; you pay a fixed price and receive approval for the deviation. Generally, this is the cheaper solution. If approval isn't granted because the deviation is too large—for example, in heavy metals or salts where it’s harder to get permanent approval—you must treat it. A wastewater treatment plant must be established, and it must be operated correctly and systematically. In many cases, proper operation of the treatment facility can prevent violations. This isn’t always true; not every facility can prevent every violation. It depends heavily on the equipment and the wastewater characteristics.

Is a violation a criminal matter?

When violations occur, there is an economic aspect. Beyond economics, discharging prohibited wastewater without a permit is a breach of the law—a criminal offense. I’m not an expert on all the details, but basically, the plant is obligated to discharge only what is permitted. For those who exceed this, the Ministry of Environmental Protection can issue a warning, followed by a hearing, and it can even lead to court-ordered closure of plants and prosecution of plant managers. The law stipulates that imprisonment is possible for violations. As far as I know, this hasn’t happened in Israel yet, but the provision exists.

What is the escalation process from the first violation until a manager faces imprisonment?

It’s a long road. I don’t know every detail, but generally, the Ministry of Environmental Protection notifies that a violation exists and that if not resolved, they will summon the parties to a hearing. If the Ministry is ignored, the problem isn't solved, and violations continue—you get called to a hearing, which is very unpleasant and problematic for the plant.

A plant with a problem wants to build a facility, but can't do it overnight. How do authorities handle this?

With a lot of understanding. This means that once the Ministry or the Water Utility sees that a plant is building a treatment facility and taking the matter seriously, they are often willing to postpone fines or convert them into conditional fines. This helps settle matters. Not always—sometimes the Utility still wants its money—but in many cases, they are willing to work with plants that show serious intent to solve the problem.

Earlier you mentioned that violations require building industrial wastewater treatment facilities, but what about the situation where a facility exists and there are still violations?

Not every facility can solve every violation. I must say that authorities are much more lenient toward a plant that has a serious, functioning facility treating most parameters, even if a small violation remains at the end. For example, a DAF system that removes all organic matter, metals, oils, and fats, but leaves a slight salt violation—in this case, it’s often possible to get a permit for the salts and continue as usual. This varies by location, but it's often an option. However, if the facility isn't working well—for example, if you have a DAF system but still have oil and grease violations—it means you aren't doing everything necessary to solve the problem, and there is less leniency. The authorities demand that the facility be operated optimally and efficiently.

Whether I have a facility or not, what should I do the moment I know I'm in violation?

If there is no facility, you should talk to the authorities, inform them that you intend to build one, and start the process. How do you set up a facility? You should consult an expert to guide you or contact a company to provide a proposal. At this stage, I suggest working with companies that offer a full range of technology rather than a single solution, so they don't have a biased interest. Often, a solution's capabilities are stretched because it's the only one a vendor knows how to provide. Work with a company that has the full arsenal of solutions to fit the right one to your needs.

If you have a facility and it’s underperforming, you can contact a company that specializes in this, like Greenfield Eco.

If my facility currently has a violation and I know about it in real-time, what should I do?

If you identify a violation in real-time, you must address it, fix the cause, and notify the authorities of a malfunction. Short-term malfunctions are generally permitted, especially if the discharge isn't a terrible substance causing catastrophic damage. If it is a highly hazardous substance, like Hexavalent Chromium (Chrome 6) or Cyanide, there is the option to evacuate the wastewater to a treatment facility or landfill.

If I have a wastewater treatment plant, how can there still be a violation?

A wastewater treatment plant that is not operated efficiently and correctly will not do the job and will cause violations. Furthermore, a treatment plant that is operated perfectly but is not designed to remove the specific pollutant being discharged will not help, and there will be a violation.

If there is a pollutant the facility isn't built to remove, there's the option to separate that specific stream at the source and dispose of a small volume of wastewater rather than contaminating the plant's entire effluent with a non-treatable pollutant.

For example, in a plant using hydrochloric acid: if we add this stream to the general flow, we get a chloride violation. If we separate it and send it to the sea or dispose of it as is, that could be the right solution for a pollutant that the plant's facility cannot treat.

In summary?

To avoid violations, all you need is the right treatment facility operated correctly and efficiently. When you have both, there is no reason for violations to occur.