The Partnership had an accrual for estimated environmental remediation costs of $6.6 million and $12.8 million as of September 30, 2017 and December 31, 2016, respectively. The environmental remediation liability represents management’s estimate of payments to be made to remediate and monitor certain areas in and around Port Gamble Bay, Washington.

In December 2013, a consent decree and Clean-up Action Plan (CAP) related to Port Gamble were finalized with the Washington State Department of Ecology (DOE) and filed with Kitsap County Superior Court. In the third quarter of 2015, the Partnership selected a contractor to complete the remediation work. Remediation activity began in late September 2015. The required in-water portion of the cleanup was completed in January 2017 and the dredged sediments were removed by the end of September 2017, with the bulk of the sediments being relocated to property owned by the Partnership a short distance from the town of Port Gamble. This will be followed by cleanup activity on the millsite and by a monitoring period. Management’s cost estimates for the remainder of the project are based on amounts included in construction contracts, bids from contractors, and estimates for project management and other professional fees.

Certain environmental laws allow state, federal, and tribal trustees (collectively, the Trustees) to bring suit against property owners to recover damages for injuries to natural resources. Like the liability that attaches to current property owners in the cleanup context, liability for natural resource damages can attach to a property owner simply because an injury to natural resources resulted from releases of hazardous substances on that owner’s property, regardless of culpability for the release. The Trustees are alleging that Partnership has NRD liability because of releases that occurred on its property. The Partnership has been in discussions with the Trustees regarding their claims and the alleged conditions in Port Gamble Bay, and has also been discussing restoration alternatives that might address the damages the Trustees allege. Discussions with the Trustees may result in an obligation for the Partnership to fund NRD restoration activities and past assessment costs that are greater than it has estimated.

The environmental liability at September 30, 2017 is comprised of $3.4 million that management expects to expend in the next 12 months and $3.2 million thereafter.

Activity in the environmental liability is as follows:



(in thousands)	Balance at Beginning of the Period		Additions to Accrual		Expenditures for Remediation		Balance at Period-end
Year ended December 31, 2015	$	21,651	$	—	$	4,890	$	16,761
Year ended December 31, 2016	16,761		7,700		11,691		12,770
Quarter ended March 31, 2017	12,770		—		3,329		9,441
Quarter ended June 30, 2017	9,441		—		951		8,490
Quarter ended September 30, 2017	$	8,490	$	—	$	1,900	$	6,590