Annual report pursuant to section 13 and 15(d)

ACCRUED CLOSURE COSTS

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ACCRUED CLOSURE COSTS
12 Months Ended
Dec. 31, 2011
ACCRUED CLOSURE COSTS [Abstract]  
ACCRUED CLOSURE COSTS
NOTE 12
ACCRUED CLOSURE COSTS

We accrue for the estimated closure costs as determined pursuant to Resource Conservation and Recovery Act (“RCRA”) guidelines for all fixed-based regulated operating and discontinued facilities, even though we do not intend to or have present plans to close any of our existing facilities.  The permits and/or licenses define the waste, which may be received at the facility in question, and the treatment or process used to handle and/or store the waste.  In addition, the permits and/or licenses specify, in detail, the process and steps that a hazardous waste or mixed waste facility must follow should the facility be closed or cease operating as a hazardous waste or mixed waste facility. Closure procedures and cost calculations in connection with closure of a facility are based on guidelines developed by the federal and/or state regulatory authorities under RCRA and the other appropriate statutes or regulations promulgated pursuant to the statutes.  The closure procedures are very specific to the waste accepted and processes used at each facility.  We recognize the closure cost as a liability on the balance sheet. Since all our facilities are acquired facilities, the closure cost for each facility was recognized pursuant to a business combination and recorded as part of the purchase price allocation of fair value to identifiable assets acquired and liabilities assumed. The closure calculation is increased annually for inflation based on RCRA guidelines, and for any approved changes or expansions to the facility, which may result in either an increase or decrease in the approved closure amount.  If there is a change to the closure estimate, we record this change in the liability and asset, with the asset depreciated in accordance with our depreciation policy.  Annual inflation factor increases are expensed during the current year.  In 2009 to 2011, we increased our asset retirement obligations for various facilities as follows due to changes in estimates of the costs to close these facilities based on federal/state regulatory guidelines: increases of $1,980,000 for DSSI (due to authorization for PCB storage and treatment) and $158,000 for PFSG in 2009; increase of $499,000 in 2010 for PFNWR; and reduction of $504,000 in 2011 for PFNWR.

During 2011, the accrued long-term closure cost decreased by $425,000 to a total of $11,937,000 as compared to the 2010 total of $12,362,000 for our continuing operations.  This decrease was principally a result of the change in estimate to close our PFNWR facility as discussed above and normal inflation factor increases.  During 2011, long-term accrued closure cost for our discontinued operations decreased by $65,000 to a total of $540,000, as compared to the 2010 total of $605,000.  The decrease of approximately $70,000 was principally the release of our closure requirement from the Florida Department of Environmental Protection resulting form the divestiture of our PFO facility on October 14, 2011. The remaining increase was primarily due to normal inflation factor adjustments.  We are waiting on the release of closure requirement from the appropriate government agency for our PFFL facility.