Landfill and Environmental Costs

6 Months Ended

Jun. 30, 2019

Environmental Remediation Obligations [Abstract]

LANDFILL AND ENVIRONMENTAL COSTS

As of June 30, 2019, we owned or operated 190 active landfills with total available disposal capacity of approximately 5.1 billion in-place cubic yards. Additionally, we have post-closure responsibility for 129 closed landfills.

Accrued Landfill and Environmental Costs

A summary of accrued landfill and environmental liabilities as of June 30, 2019 and December 31, 2018 follows:


	2019		2018
Landfill final capping, closure and post-closure liabilities	$	1,330.4	$	1,292.0
Environmental remediation	521.7		540.2
Total accrued landfill and environmental costs	1,852.1		1,832.2
Less: current portion	(142.3)		(130.6)
Long-term portion	$	1,709.8	$	1,701.6

Final Capping, Closure and Post-Closure Costs

The following table summarizes the activity in our asset retirement obligation liabilities, which includes liabilities for final capping, closure and post-closure, for the six months ended June 30, 2019 and 2018:


	2019		2018
Asset retirement obligation liabilities, beginning of year	$	1,292.0	$	1,257.7
Non-cash additions	21.6		21.8
Acquisitions, net of divestitures and other adjustments	0.2		1.9
Asset retirement obligation adjustments	(0.5)		(17.6)
Payments	(23.8)		(22.1)
Accretion expense	40.9		40.6
Asset retirement obligation liabilities, end of period	1,330.4		1,282.3
Less: current portion	(76.8)		(81.0)
Long-term portion	$	1,253.6	$	1,201.3

We review annually, in the fourth quarter, and update as necessary, our estimates of asset retirement obligation liabilities. However, if there are significant changes in the facts and circumstances related to a site during the year, we will update our assumptions prospectively in the period that we know all the relevant facts and circumstances and make adjustments as appropriate.

The fair value of assets that are legally restricted for purposes of settling final capping, closure and post-closure liabilities was $30.1 million and $29.5 million as of June 30, 2019 and December 31, 2018, respectively, and is included in restricted cash and marketable securities in our consolidated balance sheets.

Landfill Operating Expenses

In the normal course of business, we incur various operating costs associated with environmental compliance. These costs include, among other things, leachate treatment and disposal, methane gas and groundwater monitoring, systems maintenance, interim cap maintenance, costs associated with the application of daily cover materials, and the legal and administrative costs of ongoing environmental compliance. These costs are expensed as cost of operations in the periods in which they are incurred.

Environmental Remediation Liabilities

We accrue for remediation costs when they become probable and can be reasonably estimated. There can sometimes be a range of reasonable estimates of the costs associated with remediation of a site. In these cases, we use the amount within the range that constitutes our best estimate. If no amount within the range appears to be a better estimate than any other, we use the amount that is at the low end of the range. It is reasonably possible that we will need to adjust the liabilities recorded for remediation to reflect the effects of new or additional information, to the extent such information impacts the costs, timing or duration of the required actions. If we used the reasonably possible high ends of our ranges, our aggregate potential remediation liability as of June 30, 2019 would be approximately $369 million higher than the amount recorded. Future changes in our estimates of the cost, timing or duration of the required actions could have a material adverse effect on our consolidated financial position, results of operations and cash flows.

The following table summarizes the activity in our environmental remediation liabilities for the six months ended June 30, 2019 and 2018:


	2019		2018
Environmental remediation liabilities, beginning of year	$	540.2	$	564.0
Net adjustments charged to expense	(10.3)		2.5
Payments	(17.8)		(21.2)
Accretion expense (non-cash interest expense)	9.6		10.1

Environmental remediation liabilities, end of period	521.7		555.4
Less: current portion	(65.5)		(69.5)
Long-term portion	$	456.2	$	485.9

Bridgeton Landfill. During the six months ended June 30, 2019, we paid $6.9 million related to management and monitoring of the remediation area for our closed Bridgeton Landfill in Missouri. We continue to work with state and federal regulatory agencies on our remediation efforts. From time to time, this may require us to modify our future operating timeline and procedures, which could result in changes to our expected liability. As of June 30, 2019, the remediation liability recorded for this site was $154.2 million, of which approximately $8 million is expected to be paid during the remainder of 2019. We believe the remaining reasonably possible high end of our range would be approximately $171 million higher than the amount recorded as of June 30, 2019.

West Lake Landfill Superfund Site. Our subsidiary Bridgeton Landfill, LLC is one of several currently designated Potentially Responsible Parties for the West Lake Landfill Superfund site (West Lake) in Missouri. On September 27, 2018, the U.S. Environmental Protection Agency (EPA) issued a Record of Decision Amendment for West Lake that includes a total undiscounted cost estimate of $229 million over a four to five-year design and construction timeline. On March 11, 2019, the EPA issued special notice letters under CERCLA to Bridgeton Landfill, LLC and the other currently designated Potentially Responsible Parties to initiate negotiations to implement the remedy. At this time we are neither able to predict the final design of that remedy, nor estimate how much of the future response costs of the site our subsidiary may agree or be required to pay. During any subsequent administrative proceedings or litigation, our subsidiary will vigorously contest liability for the costs of remediating radiologically-impacted materials generated on behalf of the federal government during the Manhattan Project and delivered to the site by an Atomic Energy Commission licensee and its subcontractor. Currently, we believe we are adequately reserved for our expected remediation liability. However, subsequent events related to remedy design, divisibility, or allocation may require us to modify our expected remediation liability.