What condition is necessary to recognize an environmental liability?
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Favorited Content Show Publication date: 26 Nov 2019 us PP&E and other assets guide 9.4 Environmental remediation liabilities arise when a reporting entity is, or was previously, associated with a site at which remedial actions must take place. Per ASC 410-30-25-3, involvement can occur through a number of activities, including (1) past or present ownership of the site, (2) past or present operation of the site, (3) contribution or transportation of waste to the site. If one of these types of involvement has occurred on or before the date of the financial statements, ASC 410-30-25-1 requires that a liability for an environmental remediation obligation be recognized when the amount is probable and can be reasonably estimated. This guidance is consistent with that required by ASC 450, Contingencies. However, in addition to the recognition requirements under ASC 450, ASC 410-30 includes additional implementation guidance for applying these criteria to environmental remediation obligations. This is because the complexities and legal requirements surrounding hazardous material and waste remediation may pose challenges in terms of evaluating the ASC 450 criteria of "probable" and "reasonably estimable." 9.4.1 Environmental remediation obligations – “probable”ASC 450 requires recognition of liabilities when the event of loss is considered both "probable" and "reasonably estimable." Of the two criteria, the probability threshold generally requires less judgment. Evidence linking a reporting entity to environmental contamination, whether discovered through an internal review or notification of potentially responsible party status by a regulatory agency (e.g., through a notice received from the EPA or another regulatory agency), would suggest a liability is probable. However, notification by a regulatory agency is not a requirement to conclude that the “probable” criterion has been met. If an entity concludes that pollution or contamination of a site has occurred on or before the date of the financial statements and it is probable that remediation will be necessary, the “probable” criterion is considered to have been met, even if notice from a regulatory agency has not been received. In assessing the probability criterion, ASC 410-30-25-6 indicates that there is a presumption that the outcome of litigation, claims, and assessments against a reporting entity for environmental remediation will be unfavorable if two specified conditions exist. ASC 410-30-25-6 Given the legal framework within which most environmental remediation liabilities arise, there is a presumption that the outcome of such litigation, claim, or assessment will be unfavorable if both of the following conditions exist: a. Litigation has commenced or a claim or an assessment has been asserted, or if commencement of litigation or assertion of claim or assessment is probable. b. The reporting entity is associated with the site – that is, it in fact arranged for the disposal of hazardous substances found at a site or transported hazardous substances to the site or is the current or previous owner or operator of the site. The presumption may be overcome only by persuasive factual evidence to the contrary (e.g., if the entity was erroneously named as a potentially responsible party). In cases involving on-site waste disposal the determination of whether it is probable that a liability has been incurred by the entity is typically straightforward. Figure PPE 9-1 is a flowchart summarizing the guidance of ASC 410-30 as to whether the “probable” criterion is met. Figure PPE 9-1 Question PPE 9-1 includes an analysis as to whether the “probable” criterion has been met for an environmental remediation liability. Question PPE 9-1 A reporting entity is aware of hazardous waste contamination at a particular site. The site is owned by the reporting entity and there is no evidence of contamination to any other person's land. State environmental regulations require the reporting entity to remediate the contamination if state regulators became aware of the contamination. However, there has been no action taken against the reporting entity by these regulators. The reporting entity has currently fenced-in the area to restrict access and has no plans to perform any further remediation efforts in the foreseeable future. Instead, the reporting entity plans to wait until it is forced by the state regulatory agencies to remediate the contamination, which it believes is likely were the agency to become aware of the contamination. No site study has been prepared to assess the cost of remediation. Has the “probable” criterion under ASC 410-30 been met? PwC response It is likely that the “probable” criterion under ASC 410-30 has been met as the entity is legally responsible for remediation under currently enacted law and it is probable that a claim would be asserted if state regulators were to discover the contamination. As the reporting entity owns the contaminated site and it is probable that regulatory agencies would assert a claim were they to become aware of the contamination, there is a presumption that the outcome for the reporting entity would be unfavorable. As such, the “probable” criterion has likely been satisfied under ASC 410-30. The reporting entity should also consult with legal counsel to evaluate all facts in determining that the “probable” criterion has been met under ASC 410-30. 9.4.2 Environmental remediation obligations – “estimable”ASC 410-30-25-7 indicates that given their nature, it may be difficult to estimate the total cost of environmental remediation liabilities. A variety of factors may raise uncertainty as to the total cost of remediation, especially early in the remediation process. Given these challenges, a reporting entity’s initial estimates may later require adjustment due to, but not limited to, the factors, which are outlined in ASC 410-30-25-7. Excerpt from ASC 410-30-25-7 The following are some of the factors that are integral to developing cost estimates: a. The extent and types of hazardous substances at a site b. The range of technologies that can be used for remediation c. Evolving standards of what constitutes acceptable remediation d. The number and financial condition of other potentially responsible parties and the extent of their responsibility for the remediation (that is, the extent and types of hazardous substances they contributed to the site). Despite these complicating factors, a reporting entity should attempt to reasonably estimate the cost of environmental remediation when it has determined that an obligation is probable. As the base of knowledge throughout the business community continues to grow concerning environmental remediation costs, it is increasingly difficult for a reporting entity to support delayed recognition of an environmental remediation liability because of an inability to reasonably estimate it. Given the nature of environmental obligations, a “point” estimate of the total cost for remediation is often difficult to determine. ASC 410-30-25-9 and ASC 410-30-25-10 include guidance for when there is a range of estimates. ASC 410-30-25-9 An estimate of the range of an environmental liability typically is derived by combining estimates of various components of the liability (such as the costs of performing particular tasks, or amounts allocable to other potentially responsible parties but that will not be paid by those other potentially responsible parties), which are themselves likely to be ranges. For some of those component ranges, there may be amounts that appear to be better estimates than any other amount within the range; for other component ranges, there may be no such best estimates. Accordingly, the overall liability that is recorded may be based on amounts representing the lower end of a range of costs for some components of the liability and best estimates within ranges of costs of other components of the liability. ASC 410-30-25-10 In the early stages of the remediation process, particular components of the overall liability may not be reasonably estimable. This fact should not preclude the recognition of a liability. Rather, the components of the liability that can be reasonably estimated should be viewed as a surrogate for the minimum in the range of the overall liability. An environmental remediation liability is typically comprised of several components. For some of these components, the facts may indicate a best estimate within a range. For other components, there may be no best estimate within the range. For still others, there may be no reasonable estimate of the range. As such, the overall liability (i.e., the sum of all of the components) may be based on a combination of amounts representing the low ends for components for which there is a reasonable estimate of a range and, for other components, the best estimate within ranges. Even when the range is very wide, at a minimum, the lower end of the range should be accrued. This requirement is akin to the recognition criteria of ASC 450-20-30-1, which requires accrual of “the amount that appears to be a better estimate than any other estimate within the range, or accrual of the minimum amount in the range if no amount within the range is a better estimate than any other amount.” It is the reporting entity's responsibility to undertake reasonable measures to comply with the requirements of ASC 450 and ASC 410-30. It is reasonable that the amount of a probable environmental liability would not be determinable immediately upon discovery of the situation and that a reasonable period of time would be required to gather sufficient data to estimate the amount. However, the credibility of "inestimability" as justification for not recording a probable environmental liability diminishes with the passage of time, particularly when applying the components concept prescribed by ASC 410-30-25-9. Generally, some amount would be accrued when involvement in remediating a site is probable. Question PPE 9-2 outlines considerations for a reporting entity upon notification by a governmental agency that it is one of multiple potentially responsible parties (PRPs) in regard to an environmental waste site. Question PPE 9-2 A reporting entity has been notified by a governmental agency that it one of several PRPs with regard to an environmental waste site. The reporting entity believes it is not the biggest offender in terms of volume or severity of waste. No site study has been prepared. How should the reporting entity determine the possible effects on its financial statements? PwC response Once the reporting entity has confirmed it is associated with the site, ASC 410-30 concludes that the "probable" criterion has been met. The reporting entity should discuss the site with the governmental agency involved to ascertain the total extent of waste, particularly given joint and several liability statutes, and to inquire as to other PRPs involved. The reporting entity should review site operating records or disposal records to determine what materials the reporting entity was likely to have disposed of and in what quantities. The reporting entity may have available past history from similar sites upon which to base estimates of cost. The reporting entity could also engage an environmental consulting firm to perform a preliminary review of the site. At a minimum, accrual of the estimated cost to perform the remediation study is required. If the reporting entity is one of many PRPs, but not the "lead" PRP (or in the group of "primary" PRPs), the reporting entity may be subject to the timetable established by the regulatory agency and lead PRP. In such instances, information concerning work related to determining the extent and type of remedial actions, the remedial investigation and feasibility study, and remediation estimates may be available and such estimates would be a starting point for a reporting entity to make an estimate of its share. 9.4.3 Environmental remediation obligations – estimabilityThere are several factors that may make estimating an environmental remediation liability difficult. Example of these factors include:
9.4.4 Environmental remediation obligations – PRP allocationPotentially responsible parties (PRPs) may be jointly and severally liable for cleanup and a PRP may be held responsible for the entire cost of cleanup. It may not matter who is the most responsible for the contamination; rather, liability can be ascribed to those who can pay. Having more than one PRP can complicate the determination of the amount of loss each party will bear. Many Superfund sites involve numerous PRPs and the EPA may pursue the most responsible and financially viable PRPs, leaving it up to the "primary" PRPs to seek recovery from any other parties. PRPs fall into one of several categories, as described in ASC 410-30-30-2. The specific category of the PRPs may affect the determination of a reporting entity’s allocable share of the joint and several liability. See ASC 410-30-30-1 through ASC 410-30-30-7 for more information. ASC 410-30-30-2 For purposes of estimating an entity's allocable share of the joint and several remediation liability for a site, those parties that are potentially responsible for paying the remediation liability belong to one of the following five potentially responsible party categories: a. Participating potentially responsible parties b. Recalcitrant potentially responsible parties c. Unproven potentially responsible parties d. Unknown potentially responsible parties e. Orphan share potentially responsible parties. ASC 410-30-30-8 states that an environmental remediation liability is comprised of two elements: (1) the allocable share of the liability for a specific site, and (2) the amounts related to the site that will not be paid by other PRPs or the government (when the liability is joint and severable). ASC 410-30-30-1 through ASC 410-30-30-7 discusses the issue of allocation among PRPs. However, if a probable range of loss is determinable, the most likely amount within the range should be recorded, or if no amount is more likely than any other amount, the low end of the range should be recorded in accordance with the measurement guidance in ASC 450. The larger PRPs are often the best informed of developments at a site and are the first to accrue losses. Thus, an awareness of what other PRPs are doing may be important in determining when enough information is available to permit recognition of a loss. The ability of other PRPs to pay their allocated share should also be reviewed. Question PPE 9-3 and Question PPE 9-4 outline considerations for determining a reporting entity’s (individual PRP’s) share of a total environmental remediation obligation. Question PPE 9-3 A reporting entity is one of many parties involved at a remediation site. A preliminary remediation study has been performed, noting a range of remediation costs under various alternatives of $50-$150 million. How does the reporting entity determine its share of this component of the liability? PwC response An estimate of the reporting entity's share may be based on the relative proportion of waste (in terms of weight, volume, or toxicity). In some instances, legal action between PRPs may be protracted. However, steps should be taken to determine a range of probable loss and record the most probable amount in the range; if no amount is a better estimate than any other amount, the low end of the range should be recorded (in accordance with ASC 450-20-30-1). For example, if the reporting entity is responsible for 8-10% of the waste (based on some measurable criteria such as volume), a minimum accrual of 8% of $50 million (the low end of the range) plus other soft costs (such as cost of remediation study, legal fees) would be appropriate. The reporting entity would also be responsible for its share of costs of other PRPs (those responsible for the other 90-92%) that are unable to pay their share of the total obligation. Assessing other PRPs’ ability to pay requires a thorough understanding of the legal environment (e.g., whether joint and several liability applies) and the financial condition of other PRPs. Question PPE 9-4 The EPA has incurred $10 million to perform a Phase I clean-up of a Superfund site. A reporting entity has been notified it is a PRP, along with five other companies. Based on the reporting entity's records, the reporting entity contributed 25% of the hazardous materials dumped at the site. No remediation study has been completed with respect to the remaining clean up; however, additional costs will be incurred. One PRP is in Chapter 7 bankruptcy proceedings; another PRP is disputing that it disposed of any materials at the site. How should the reporting entity account for the claim? PwC response Although the eventual percentage responsibility among the PRPs is not yet determinable, the reporting entity can reasonably estimate it has a minimum liability based on its 25% contribution to the site for the Phase I activity. The reporting entity should accrue $2.5 million for the governmental assessment element of the liability. Because of the Chapter 7 filing of another PRP, it may need to accrue more than its allocated share (as there are indications that PRP may not be able to pay their share of the total obligation). Assessing other PRPs’ ability to pay requires a thorough understanding of the legal environment (e.g., whether joint and several liability applies) and the financial condition of other PRPs. With regard to the Phase II remediation, the reporting entity should attempt to estimate the cost based on prior experience or other available data. 9.4.5 Environmental remediation obligations – benchmarksASC 410-30-25-15 provides the stages (i.e., benchmarks) for environmental remediation liabilities. A reporting entity is required, at a minimum, to evaluate its estimates of environmental remediation liabilities upon the occurrence of each of these benchmarks. The benchmarks discussed in ASC 410-30-25-15:
See ASC 410-30-25-15 for a detailed discussion of each of these recognition benchmarks, including the impact on the recognition and measurement of the related environmental remediation liability. 9.4.5.1 Costs and activities included in environmental obligationsASC 410-30-30-10 defines costs to be included in the measurement of remediation liabilities as (a) incremental direct costs of the remediation effort, and (b) costs of compensation and benefits for employees to the extent of time expected to be spent directly on the remediation effort. Additionally, ASC 410-30-30-11 requires that the remediation effort be evaluated on a site-by-site basis when recognizing and measuring an environmental remediation liability. The implementation guidance in ASC 410-30-55-1 and ASC 410-30-55-2 provide examples of incremental direct costs of the remediation effort that should be included in the measurement of the environmental remediation liability. ASC 410-30-55-1 This implementation guidance illustrates
paragraphs 410-30-30-10 through
30-11. Examples of incremental direct costs of the remediation effort include the following: a. Fees to outside law firms for work related to determining the extent of remedial actions that are required, the type of remedial actions to be used, or the allocation of costs among potentially responsible parties b. Costs related to completing the remedial investigation-feasibility study c. Fees to outside engineering and consulting firms for site investigations and the development of remedial action plans and remedial designs d. Costs of contractors performing remedial actions e. Governmental oversight costs and past costs; usually this is based on the cost incurred by the Environmental Protection Agency or other governmental authority dealing with the site f. The cost of machinery and equipment that is dedicated to the remedial actions and that does not have an alternative use g. Assessments by a potentially responsible party group covering costs incurred by the group in dealing with a site h. Costs of operation and maintenance of the remedial action, including the costs of postremediation monitoring required by the remedial action plan ASC 410-30-55-2 Examples of employees who may devote a significant amount of time directly to the remediation effort include the following: a. The internal legal staff that is involved with the determination of the extent of remedial actions that are required, the type of remedial action to be used, and the allocation of costs among potentially responsible parties b. Technical employees who are involved with the remediation effort. The costs of services related to routine environmental compliance matters and litigation costs involved in obtaining potential recoveries or reimbursements of costs from other parties are not part of the remediation effort. ASC 410-30-30-14 includes guidance for legal costs incurred relating to potential recoveries. ASC 410-30-30-14 Litigation costs involved with potential recoveries shall be charged to expense as incurred until realization of the claim for recovery is considered probable and an asset relating to the recovery is recognized, at which time any remaining such legal costs shall be considered in the measurement of the recovery. The determination of which legal costs are for potential recoveries (i.e., not considered part of the remediation effort) rather than for allocating costs among PRPs or other remediation matters (i.e., considered part of the remediation effort – and therefore included in the measurement of the environmental liability) will depend on specific facts and circumstances. Routine environmental compliance matter costs should be charged to expense as incurred. Legal costs associated with litigation, claims, and assessments not directly related to environmental remediation activities (e.g., lawsuits filed by individuals or groups for health effects of environmental contamination, fines imposed by regulatory agencies) are not within the scope of ASC 410-30 and should instead be evaluated under the framework of ASC 450-20. 9.4.5.2 Discounting environmental remediation liabilitiesASC 410-30-35-12 concludes that discounting environmental remediation liabilities, or components of environmental remediation liabilities, to reflect the time value of money is allowed but not required. Discounting would be allowed when the amount of the obligation and the timing of payments are fixed or reliably determinable. Given the nature of environmental liabilities (e.g., uncertainties in amount of obligation and time period over which these obligations are settled), it may be difficult for a reporting entity to support that they have met both of the requirements of ASC 410-30-35-12 for the discounting of the liability. We believe this means that the estimate of the expected costs to be incurred must be based on a site-specific plan for the clean-up and the amount and timing of cash payments must be based on objective and verifiable information. These conditions would not apply to liabilities that are measured based on the lowest amount within a range or on current cost estimates. The undiscounted estimated cash flows should include estimates of inflation and should be computed using explicit assumptions and methods derived from the remediation plan. When applying the discounting guidance on a component basis, as discussed in ASC 410-30-35-12, certain components of the remediation liability may meet the criteria for discounting, such as the annual operating costs for postremediation monitoring equipment. Other components may not meet the criteria for discounting. ASC 450-20-S99-1, SAB Topic 5.Y, Question 1 sets forth the discount rate the SEC staff believes is appropriate, which is a settlement rate in an arm’s length transaction (if readily determinable). Given that this rate will most likely not be determinable, the SAB sets forth a ceiling on the rate, that is, it should not exceed the interest rate on risk-free monetary assets with maturities comparable to those of the liability. See FSP 11.5.2 for the financial statement disclosure requirements when discounting is applied. 9.4.5.3 Capitalization of environmental remediation costsEnvironmental costs should generally be charged to expense in the period incurred. However, there are exceptions that allow for the capitalization of environmental costs to the extent they are recoverable and any one of the criteria included in ASC 410-30-25-18 are met. ASC 410-30-25-18 Those costs may be capitalized if recoverable but only if any one of the following criteria is met: a. The costs extend the life, increase the capacity, or improve the safety or efficiency of property owned by the entity. For purposes of this criterion, the condition of that property after the costs are incurred must be improved as compared with the condition of that property when originally constructed or acquired, if later. b. The costs mitigate or prevent environmental contamination that has yet to occur and that otherwise may result from future operations or activities. In addition, the costs improve the property compared with its condition when constructed or acquired, if later. c. The costs are incurred in preparing for sale that property currently held for sale. ASC 410-30-55-18 through ASC 410-30-55-26 include several illustrations of whether costs to treat environmental contamination should be capitalized or charged to expense. Question PPE 9-5 and Question PPE 9-6 address the capitalization of environmental remediation costs. Question PPE 9-5 A reporting entity has ground water contamination from waste at its plant. In order to clean up existing contaminated water, a filtration system is installed that also serves to filter water used in current plant operations. Should the cost of the filtration system be capitalized? PwC response Yes. As the filtration system benefits future operations by mitigating/preventing additional groundwater contamination that would otherwise result from continuing plant operations and thereby improves the safety of the property in comparison to the original construction, the cost may be capitalized under the first or second criterion of ASC 410-30-25-18. Question PPE 9-6 A reporting entity has ground water contamination from waste at its plant, which is no longer operating. In order to clean up the existing contaminated water, a filtration system is installed. The reporting entity has met the held for sale criteria for the non-operating plant. Should the cost of the filtration system be capitalized? PwC response Yes. The cost of the filtration system should be capitalized as permitted under the third criterion of ASC 410-30-25-18, subject to a recoverability test. See PPE 5.5 for additional information on the impairment of long-lived assets to be disposed of by sale. 9.4.5.4 Accounting for recoveries of environmental costsASC 410-30-35-8 requires that an environmental liability be evaluated independent from any potential claim for recovery and the loss arising from the recognition of an environmental liability be reduced only when a claim for recovery from third parties is probable of realization. Further, the guidance stipulates that a rebuttable presumption exists that recovery is not probable of realization in instances when the recovery claim is the subject of litigation. The amount of a potential recovery should be measured based on all available information. The measurement of the potential recovery should also incorporate the time value of money (i.e., discounting) in situations when the related liability is discounted. ASC 720-20, Other expenses, Insurance Costs, addresses various aspects of the accounting for retroactive insurance contracts and claims-made insurance policies by an insured entity, including an insurance entity that purchases insurance unrelated to its core insurance operations. ASC 720-20 should be considered when assessing the accounting for claim recoveries from insurance companies. See PPE 8.2 for information surrounding the accounting for insurance costs, including insurance recoveries relating to environmental claims. Probable recoveries should be reflected separately as an asset in the balance sheet and should not be netted against the related environmental liability. This is consistent with the guidance of ASC 210-20, Balance Sheet, Offsetting. ASC 410-30-45-2 states that it would be rare that the environmental remediation liabilities, related receivables, and potential recoveries would meet the criteria of ASC 210-20. Question PPE 9-7 addresses a scenario in which a reporting entity believes certain environmental remediation costs may be covered by a general liability insurance policy. Question PPE 9-7 A reporting entity has been named as a potentially responsible party in connection with hazardous waste it disposed. The reporting entity believes its general liability insurance in effect at the time should cover any loss. What should the reporting entity record? PwC response In accordance with ASC 410-30, assessment of the potential recovery should be independent of the assessment of the remediation obligation; recovery may be recognized only if it is probable of realization. Investigation should be made as to the financial viability of the insurance carrier. The reporting entity should review the policy to determine whether there were exclusions concerning environmental matters, passage of time, or other matters. Determination of "probable" in the case of an insurance recovery generally requires strong evidence, as many insurance companies will choose to litigate rather than pay the claim. ASC 410-30 stipulates the rebuttable presumption that claims subject to litigation are not probable of recovery. Question PPE 9-8 addresses a scenario in which a reporting entity purchases a retroactive insurance contract to cover certain environmental liabilities. Question PPE 9-8 A reporting entity purchases a retroactive insurance contract to cover environmental liabilities. The company has a pre-existing accrual for environmental costs of $50 million. It then buys an insurance policy for $30 million to cover that liability (the $20 million difference relates primarily to the fact that the insurance policy is priced to take into consideration the present value of the expected future cash flows). How should the amount paid to the insurance company be reported? PwC response ASC 720-20 addresses various aspects of the accounting for retroactive insurance contracts and claims-made insurance policies by an insured entity, including an insurance entity that purchases insurance unrelated to its core insurance operations. Purchased retroactive insurance contracts that indemnify the insured entity should be accounted for in a manner similar to the way in which retroactive reinsurance contracts are accounted for under ASC 720-20-25-3 through ASC 720-20-25-5. Accordingly, the amounts paid for retroactive insurance should be expensed immediately. If collection of insurance proceeds is probable , a receivable should be established for the expected recoveries related to the underlying insured event. If the receivable established exceeds the amounts paid for the insurance, the resulting gain is deferred. If the amounts and timing of the insurance recoveries can be reasonably estimated, the deferred gain should be amortized using the interest method over the estimated period over which the entity expects to recover substantially all amounts due under the terms of the insurance contract. If the amounts and timing of the insurance recoveries cannot be reasonably estimated, the proportion of actual recoveries to total estimated recoveries should be used to determine the amount of the amortization. Immediate gain recognition and liability derecognition are not appropriate because the liability has not been extinguished per the guidance in ASC 405-20-40-1, Liabilities, Extinguishment of Liabilities. Additionally, the liability incurred as a result of a past insurable event and amounts receivable under the insurance contract do not meet the criteria for offsetting under ASC 210-20. PwC. All rights reserved. PwC refers to the US member firm or one of its subsidiaries or affiliates, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details. This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.
Please ensure When must a company recognize an environmental provision?IAS 37 Provisions, Contingent Liabilities, and Contingent Assets re- quired a provision should be recognised when and only when: “(a) an entity has a present obligation (legal or constructive) as a result of a past event; (b) it is probable (i.e more likely than not) that an outflow of resources embodying economic ...
What is environmental law liability?Environmental liability refers to the potential environmental costs that a buyer incurs when purchasing or leasing an asset. The liabilities arise when a buyer is conducting due diligence on the property and will be required to take ownership of the asset and all liabilities associated with the asset post-acquisition.
What are environmental liabilities accounting?An environmental liability is defined by the Federal Accounting Standards Advisory Board (FASAB) as a probable, measurable and reasonably estimable future outflow or expenditure of resources that exist as of the financial reporting date for environmental cleanup costs resulting from past transactions or events.
What potential business liabilities can result from environmental risk?Overlapping liabilities
There are numerous sources of potential environmental liabilities, stemming from voluntary remediation, landfill taxes, regulatory action, third party claims, contractual disputes and negative publicity.
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