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Liabilities for Disposed Operations
12 Months Ended
Dec. 31, 2019
Environmental Remediation Obligations [Abstract]  
Liabilities for Disposed Operations Environmental Liabilities
The Company’s environmental liabilities relate to sawmills, pulp, paper and wood treating plants which have ceased operations other than environmental investigation and remediation activities. The Company owns or has liability for approximately twenty sites that are subject to various federal, state or provincial statutes, including but not limited to, the Resource Conservation and Recovery Act (“RCRA”), the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (“CERCLA”)
and the Environmental Protection Act in the United States, and similar laws in Canada and France, related to the investigation and remediation of environmentally-impacted sites.
The Company estimates its environmental liabilities based on its current interpretation of environmental laws and regulations when it is probable a liability has been incurred and the amount of such liability is estimable. The Company calculates estimates based on a number of factors, including the application and interpretation of current environmental laws, regulations and other requirements; reports and advice of internal and third-party environmental specialists; and management’s knowledge and experience with these and similar types of environmental matters. These estimates include potential costs for investigation, assessment, remediation, ongoing operation and maintenance (where applicable), and post-remediation monitoring of the sites, as well as the cost of legally-required financial assurance relating to the Company’s obligations on an undiscounted basis, generally for a period of 20 years. These environmental liabilities do not include potential third-party recoveries to which the Company may be entitled unless they are probable and estimable.
The following table provides detail for specific sites where current estimates exceed 10 percent of the total liabilities for disposed operations at December 31, 2019, 2018, or 2017. An analysis of the activity of the liabilities for disposed operations for the years ended December 31, 2019 and 2018 is as follows:
 
December 31, 2017 Liability
 
Payments
 
Increase (Decrease) to Liabilities (a)
 
December 31, 2018 Liability
 
Payments
 
Increase (Decrease) to Liabilities (a)
 
December 31, 2019 Liability
Port Angeles, Washington
$
43,667

 
$
(935
)
 
$
2,067

 
$
44,799

 
$
(1,404
)
 
$
11,045

 
$
54,440

Augusta, Georgia
21,175

 
(929
)
 
108

 
20,354

 
(683
)
 
1,876

 
21,547

Baldwin, Florida
21,170

 
(4,613
)
 
687

 
17,244

 
(450
)
 
383

 
17,177

All other sites
78,074

 
(5,489
)
 
5,672

 
78,257

 
(3,907
)
 
3,862

 
78,212

Total
164,086

 
$
(11,966
)
 
$
8,534

 
160,654

 
$
(6,444
)
 
$
17,166

 
171,376

Less: Current portion
(13,181
)
 
 
 
 
 
(11,310
)
 
 
 
 
 
(11,339
)
Non-Current portion
$
150,905

 
 
 
 
 
$
149,344

 
 
 
 
 
$
160,037


(a)
Included in the Increase (Decrease) to Liabilities during the year ended December 31, 2019 and 2018 is a $1 million increase and a $1 million decrease of the liability, respectively, due to foreign currency gains and losses.
A brief description of the above identified sites is as follows:
Port Angeles, Washington — The Company operated a pulp mill at this site from 1930 until 1997. The site and the adjacent marine areas (a portion of Port Angeles harbor) have been in various stages of the assessment process under the Washington Model Toxics Control Act (“MTCA”) since 2000, and several voluntary interim soil clean-up actions have been performed during this time. In addition, the Company may be liable under CERCLA for “natural resource damages” caused by releases from the site. As a result of an agreed order with the Washington State Department of Ecology (“Ecology”), the remainder of the MTCA regulatory process will be completed on a set timetable, subject to approval of all reports and studies by Ecology. Upon completion of all work required under the agreed order and negotiation of an approved remedy, additional remedial measures for the site and off-site areas may be necessary and, as a result, current cost estimates and the corresponding liability could change. During 2019 and 2018, the estimated liability increased by $10 million and $1 million, respectively, due to changes in the Company’s remediation cost estimates, partly offset by payments made during the year.
Augusta, Georgia — The Company operated a wood treatment plant at this site from 1928 to 1988. This site operates under a 10-year hazardous waste permit renewed and issued pursuant to RCRA in 2015. Ongoing remediation activities currently consist primarily of groundwater recovery and treatment. Current cost estimates and the corresponding liability could vary if recovery or discharge volumes change or if changes to current remediation activities are required in the future. During 2019 and 2018, the Company recorded an $1 million increase and a $1 million decrease in the liability, respectively, due to payments and to the change in the estimated costs related to the site’s operation and maintenance.
Baldwin, Florida — The Company operated a wood treatment plant at this site from 1954 to 1987. This site operates under a 10-year hazardous waste permit renewed and issued pursuant to RCRA in 2017. Ongoing remediation activities currently consist primarily of groundwater recovery and treatment. Additional remedial activities may be necessary in the future and, therefore,
current cost estimates and the corresponding liability could change. During 2018, the Company decreased the estimated liability by approximately $5 million due to payments and a decrease in the estimated costs related to the site’s remediation plan. During 2019, the reserve remained flat as payments during the year were essentially offset by an increase in the remediation cost estimates.
In addition to the estimated liabilities, the Company is subject to the risk of reasonably possible additional liabilities in excess of the established liabilities due to potential changes in circumstances and future events, including, without limitation, changes to current laws and regulations; changes in governmental agency personnel, direction, philosophy or enforcement policies; developments in remediation technologies; increases in the cost of remediation, operation, maintenance and monitoring of its disposed operations sites and providing financial assurance relating thereto; changes in the volume, nature or extent of contamination to be remediated or monitoring to be undertaken; the outcome of negotiations with governmental agencies or non-governmental parties; and changes in accounting rules or interpretations. Based on information available as of December 31, 2019, the Company estimates this exposure could range up to approximately $80 million, although no assurances can be given that this amount will not be exceeded given the factors described above. These potential additional costs are attributable to several of the above sites and other applicable liabilities. This estimate excludes liabilities which would otherwise be considered reasonably possible but for the fact that they are not currently estimable primarily due to the factors discussed above.
Subject to the previous paragraph, the Company believes its estimates of liabilities are sufficient for probable costs expected to be incurred over the next 20 years with respect to its disposed operations. However, no assurances are given these estimates of liabilities will be sufficient for the reasons described above, and additional liabilities could have a material adverse effect on the Company’s financial position, results of operations and cash flows.