“All effluent discharges are within permit limits.”
Management presentation, p. 14-
Discharge permit, condition 4.2: chemical oxygen demand (COD) limit of 250 mg/L.
Doc 07, p. 3 -
Monthly laboratory results, January to December.
Doc 22, sheets 1–12
COD exceeded the permit limit in 5 of 12 months, peaking at 410 mg/L. No regulator correspondence or corrective-action plan was provided in the data room.
- Severity
- High
- Evidence confidence
- High for the exceedances: a consistent twelve-month laboratory series. Medium for regulatory exposure: regulator correspondence was not provided.
- Transaction implication
- Potential enforcement exposure and effluent-treatment upgrade costs not reflected in the investment case.
- Recommended action
- Request regulator correspondence and an upgrade cost estimate before close; consider contractual protections with legal counsel.
- Timing
- Pre-close
- Review status
- Reviewed