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COMMITMENTS, CONTINGENCIES AND LEGAL PROCEEDINGS | 9 Months Ended
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Sep. 30, 2024
Commitments and Contingencies Disclosure [Abstract] |
COMMITMENTS, CONTINGENCIES AND LEGAL PROCEEDINGS | COMMITMENTS, CONTINGENCIES AND LEGAL PROCEEDINGS Fox River - Neenah, Wisconsin Background We have previously reported that we face liabilities associated with environmental claims arising out of the presence of polychlorina ted biphenyls (“PCBs”) in sediments in the lower Fox River, on which our former Neenah facility was located, and in the Bay of Green Bay, Wisconsin (collectively, the “Site”). Over the past several years, we and certain other PRPs completed all remedial actions pursuant to applicable consent decrees or a Unilateral Administrative Order. Under the Glatfelter consent decrees, we are primarily responsible for long-term monitoring and maintenance in OU1-OU4a and for reimbursement of government oversight costs paid after October 2018. The monitoring activities consist of, among others, testing fish tissue, sampling water quality and sediment, and inspections of the engineered caps. In 2018, we entered into a fixed-price, 30-year agreement with a third party for the performance of all of our monitoring and maintenance obligations in OU1 through OU4a with limited exceptions, such as, for extraordinary amounts of cap maintenance or replacement. Our obligation under this agreement is included in our total reserve for the Site. We are obligated to make the regular payments under that fixed-price contract until the remaining amount due is less than the OU1 escrow account balance. We are permitted to pay for this contract using the remaining balance of the escrow account established by us and WTM I Company (“WTM I”) another PRP, under the OU1 consent decree during any period that the balance in the escrow account exceeds the amount due under our fixed-price contract. As of September 30, 2024, the balance in the escrow exceeds the amounts due under the fixed-price contract by approximately $0.7 million. At September 30, 2024, the escrow account balance totaled $9.3 million which is included in the condensed consolidated balance sheet under the caption “Other assets.” Under the consent decree, we are responsible for reimbursement of government oversight costs paid from October 2018 and later over approximately the next 30 years. We anticipate that oversight costs will decline as activities at the site have transitioned from remediation to long-term monitoring and maintenance. Reserves for the Site Our reserve for past and future government oversight costs and long-term monitoring and maintenance totaled $12.1 million at September 30, 2024, of which $0.7 million is recorded in the accompanying September 30, 2024 condensed consolidated balance sheet under the caption “Environmental liabilities” and the remaining $11.4 million is recorded under the caption “Other long-term liabilities.” Range of Reasonably Possible Outcomes Based on our analysis of all available information, including but not limited to decisions of the courts, official documents such as records of decision, discussions with legal counsel, cost estimates for future monitoring and maintenance and other post-remediation costs to be performed at the Site, we do not believe that our costs associated with the Fox River matter could exceed the aggregate amounts accrued by a material amount.

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