FOREST SERVICE HANDBOOK NATIONAL HEADQUARTERS (WO) WASHINGTON, DC

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FOREST SERVICE HANDBOOK
NATIONAL HEADQUARTERS (WO)
WASHINGTON, DC
FSH 6509.11m - SERVICEWIDE ACCRUAL HANDBOOK
CHAPTER 30 - ACCRUING ENVIRONMENTAL AND DISPOSAL LIABILITIES
Amendment No.: 6509.11m-2011-1
Effective Date: April 26, 2011
Duration: This amendment is effective until superseded or removed.
Approved: DONNA M. CARMICAL
Chief Financial Officer (CFO)
Date Approved: 04/14/2011
Posting Instructions: Amendments are numbered consecutively by handbook number and
calendar year. Post by document; remove the entire document and replace it with this
amendment. Retain this transmittal as the first page(s) of this document. The last amendment to
this handbook was 6509.11m-2008-3 to 6509.11m_contents.
New Document
6509.11m_30
29 Pages
Superseded Document(s)
by Issuance Number and
Effective Date
6509.11m_30
(Amendment 6509.11m-2007-3, 10/11/2007)
25 Pages
Digest:
30 - Revises chapter title from “Accruing Environmental Cleanup Liabilities” to “Accruing
Environmental and Disposal Liabilities” to comply with wording changes adopted by the Office
of Management and Budget, Circular A-136, “Financial Reporting Requirements”.
30.1 - Adds 40 CFR 312.10 as authority setting forth the qualifications for an “Environmental
Professional”.
30.4 - Updates Responsibilities to reflect organization changes.
30.5 - Adds new definitions and revises to clarify others.
31 - Revises entire section to update the requirements of the accounting process with more
detailed descriptions and current methods.
WO AMENDMENT 6509.11m-2011-1
EFFECTIVE DATE: 04/26/2011
DURATION: This amendment is effective until superseded or removed.
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FSH 6509.11m - SERVICEWIDE ACCRUAL HANDBOOK
CHAPTER 30 - ACCRUING ENVIRONMENTAL AND DISPOSAL LIABILITIES
Table of Contents
30.1 - Authority........................................................................................................................... 3
30.4 - Responsibility ................................................................................................................... 4
30.41- Chief Financial Officer ................................................................................................ 4
30.41a - Director of Audit and Assurance .............................................................................. 4
30.41b - Director of Financial Reporting and Reconciliation................................................. 4
30.41c - Director of Financial Management Systems ............................................................. 5
30.41d - Director of Financial Policy ..................................................................................... 5
30.41e - Director of the Albuquerque Service Center-Budget and Finance ........................... 5
30.42 - Deputy Chief for the National Forest System ............................................................ 6
30.42a - Washington Office Director of Engineering ............................................................. 6
30.43 - Deputy Chief for the National Forest System, Regional Foresters, Station Directors,
Area Director, Forest Products Laboratory Director, International Institute of
Tropical Forestry Director, and the Job Corps National Office Director ................... 6
30.44 - Forest Supervisors, Research Project Leaders, and Job Corps’ Field Representatives
..................................................................................................................................... 7
30.5 - Definitions ........................................................................................................................ 8
31 - ENVIRONMENTAL CLEANUP LIABILITY ACCOUNTING PROCESS ................ 11
31.1 - Identify and Classify Incidents of Damage to the Environment .................................... 13
31.2 - Estimate Cleanup Costs for Each Government-Related Environmental Damage Site .. 13
31.21 - Activities Considered in the Cost Estimate .............................................................. 13
31.22 - Development of Cost Estimates................................................................................ 14
31.23 - Cost Estimate Documentation .................................................................................. 14
31.24 - Cost Estimate Updates .............................................................................................. 15
31.3 - Maintain the Inventory of All Environmental Cleanup Sites ......................................... 16
31.4 - Gather Information and Determine the Accrual Amount ............................................... 16
31.5 - Determine Financing for Environmental Cleanup ......................................................... 20
31.51 - Possible Financing Options ...................................................................................... 20
31.52 - Unfunded Cleanup Sites Become Funded ................................................................ 22
31.53 - All Financed Cleanup Projects Have Special Accounting Structure ........................ 24
31.6 - Prepare and Record the Accrual Entry ........................................................................... 24
31.7 - Analyze the Results of Accrual Methodology................................................................ 26
31.8 - Accrual Documentation and Reconciliation ................................................................... 26
WO AMENDMENT 6509.11m-2011-1
EFFECTIVE DATE: 04/26/2011
DURATION: This amendment is effective until superseded or removed.
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FSH 6509.11m - SERVICEWIDE ACCRUAL HANDBOOK
CHAPTER 30 - ACCRUING ENVIRONMENTAL AND DISPOSAL LIABILITIES
30.1 - Authority
1. Financial Accounting Standards Advisory Board (FASAB) Statements of Federal
Financial Accounting Standards (SFFAS) No. 5, “Accounting for the Liabilities of the
Federal Government” (http://fasab.gov). This standard instructs Federal agencies on
accounting for liabilities.
2. FASAB SFFAS No. 6, “Accounting for Property, Plant, and Equipment.” This
standard instructs Federal agencies on accounting for property, plant, and equipment.
3. FASAB SFFAS No. 12, “Recognition of Contingent Liabilities Arising from
Litigation: An Amendment of SFFAS No. 5, Accounting for Liabilities of the Federal
Government.” This standard instructs Federal agencies about accounting for liabilities
arising from litigation.
4. USDA Financial and Accounting Standards Manual
(http://www.ocfo.usda.gov/acctpol/pdf/fasm.pdf). This manual instructs USDA agencies
on accounting policy and principles for measuring, recognizing, and reporting liabilities
associated with environmental restoration cleanup liabilities.
5. U.S. Treasury Financial Management Service “United States Standard General Ledger
- Treasury Financial Manual, Section 1 Chart of Accounts, Section II Account
Descriptions, and Section III Accounting Transactions”
(http://www.fms.treas.gov/ussgl/). These Treasury Financial Manual sections provide
information to all Federal agencies about the United States Standard General Ledger
accounts, their descriptions, and their application to transactions.
6. FASAB Federal Financial Accounting and Auditing Technical Release No. 2:
“Determining Probable and Reasonably Estimable for Environmental Liabilities in the
Federal Government” (http://www.fasab.gov/pdffiles/codification_report2010.pdf). This
technical release supplements the relevant Federal standards, but is not a substitute for
and does not take precedence over the standards issued by General Accountability Office
(GAO) and the Office of Management and Budget which have precedence over these and
other authoritative guidance for Federal entities.
7. FASAB Technical Bulletin 2006-1: “Recognition and Measurement of AsbestosRelated Cleanup Costs”, issued by the Federal Accounting Standards Advisory Board,
September 28, 2006. Implementation of this Technical Bulletin is pending issuance of
detailed guidance.
8. Title 40, Code of Federal Regulations, Part 312.10. This regulation sets forth the
qualifications required for an “Environmental Professional”.
WO AMENDMENT 6509.11m-2011-1
EFFECTIVE DATE: 04/26/2011
DURATION: This amendment is effective until superseded or removed.
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CHAPTER 30 - ACCRUING ENVIRONMENTAL AND DISPOSAL LIABILITIES
9. Resource Conservation and Recovery Act of 1976 (RCRA). RCRA gave the
Environmental Protection Agency (EPA) the authority to control hazardous materials
from the “cradle-to-grave”. This includes the generation, transportation, treatment,
storage, and disposal of hazardous wastes. RCRA also set forth a framework for the
management of non-hazardous wastes. (http://www.epa.gov).
30.4 - Responsibility
30.41- Chief Financial Officer
It is the responsibility of the Chief Financial Officer to ensure the quality and integrity of the
financial data in the agency core financial system and its subsidiary systems.
30.41a - Director of Audit and Assurance
It is the responsibility of the Director of Audit and Assurance to:
1. Maintain and analyze historical statistics and trends of unfunded liabilities recorded in
standard general ledger (SGL) 2995. Annually, review the accuracy of the accruals
retrospectively, to improve upon the current methodology and increase the accuracy and
reliability of the amounts accrued.
2. Coordinate and collaborate with the Washington Office Engineering staff as required
to obtain from the field, the detailed information for auditor requests and transaction
sampling of environmental cleanup liabilities.
30.41b - Director of Financial Reporting and Reconciliation
It is the responsibility of the Director or Financial Reporting and Reconciliation to:
1. Ensure the amount of environmental cleanup liabilities in the general ledger reflects
the amount recorded on the related spreadsheet from the Washington Office Engineering
staff on a quarterly basis.
2. Report the Forest Service’s liabilities in a timely and accurate manner in the financial
statements.
3. Provide the quality assurance and monitoring required to ensure the correct timing and
recording of the accruals and liabilities.
WO AMENDMENT 6509.11m-2011-1
EFFECTIVE DATE: 04/26/2011
DURATION: This amendment is effective until superseded or removed.
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30.41c - Director of Financial Management Systems
It is the responsibility of the Director of Financial Management Systems to implement and
maintain the appropriate posting models to allow for proper analysis, compilation, and recording
of accounting data to generate the related accruals.
30.41d - Director of Financial Policy
It is the responsibility of the Director of Financial Policy to:
1. Issue accounting policy and procedures governing the recognition and accrual of
environmental liabilities.
2. Collaborate with the ASC-B&F staff and the Washington Office Engineering staff
regarding questions about or updates to the procedures in this directive.
30.41e - Director of the Albuquerque Service Center-Budget and Finance
It is the responsibility of the Director of the Albuquerque Service Center - Budget and Finance
(ASC-B&F) to:
1. Provide the quarterly accrual calculation spreadsheet and the financial information
from the financial system on all government-related environmental cleanup activity.
Financial information must be retrieved for data elements such as: obligations,
expenditures, and unpaid expenditures, recorded in job codes established with the special
job code model described in this directive, designated for environmental cleanup projects.
2. Use environmental cleanup cost estimates provided by the regions, stations, and Area
through the Washington Office Engineering staff, and retrieved from the financial
system, to calculate the quarterly Environmental Cleanup Costs Covered and Not
Covered by Budgetary Resources.
3. Record the quarterly accrual of Environmental and Disposal Liabilities in the core
financial system.
4. Collaborate with the Washington Office Engineering staff and the Washington Office
Financial Policy staff regarding questions about or updates to the procedures in this
directive.
5. Maintain related spreadsheets provided by Washington Office Engineering staff in a
central file for audit examination.
WO AMENDMENT 6509.11m-2011-1
EFFECTIVE DATE: 04/26/2011
DURATION: This amendment is effective until superseded or removed.
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CHAPTER 30 - ACCRUING ENVIRONMENTAL AND DISPOSAL LIABILITIES
30.42 - Deputy Chief for the National Forest System
It is the responsibility of the Deputy Chief for the National Forest System to maintain day to day
quality, continuity, and integrity in National Forest System operations related to financial matters
such as accruals.
30.42a - Washington Office Director of Engineering
It is the responsibility of the Washington Office Director of Engineering to:
1. Collaborate with the ASC-B&F staff and the Washington Office Financial Policy staff
regarding questions about or updates to the procedures in this directive.
2. Participate as required in the annual financial statement audit meetings. Provide
supporting documentation for the total current liability estimate as reported on the
quarterly accrual spreadsheet, in response to auditor requests and sampled liability items.
3. Distribute the quarterly accrual spreadsheet of government-related cleanup sites
provided by the ASC-B&F Service Wide and Accounts Maintenance (SWAM) staff to
the regional foresters, station directors, Area Director, Forest Products Laboratory
Director, International Institute of Tropical Forestry Director, and National Job Corps
Office Director for their update of the estimated cleanup costs. When the updated
spreadsheets are returned, review them for accuracy and completeness, and consolidate
them into one spreadsheet. Forward the consolidated, updated accrual spreadsheet to the
ASC-B&F SWAM staff by the requested due date.
30.43 - Deputy Chief for the National Forest System, Regional Foresters, Station
Directors, Area Director, Forest Products Laboratory Director, International
Institute of Tropical Forestry Director, and the Job Corps National Office Director
It is the responsibility of the Deputy Chief for the National Forest System, Regional Foresters,
Station Directors, Area Director, Forest Products Laboratory Director, International Institute of
Tropical Forestry Director, and Job Corps National Office Director to:
1. Ensure the quality and integrity of financial data processed in their areas of
responsibility; including the accurate, timely recording of obligations and accruals.
2. Comply with direction for hazardous materials/chemical management and
environmental cleanup and disposal provided in FSM 2160.
3. Ensure compliance with the procedure set forth in this directive, which includes the
following:
WO AMENDMENT 6509.11m-2011-1
EFFECTIVE DATE: 04/26/2011
DURATION: This amendment is effective until superseded or removed.
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a. Ensure that the inventory of environmental cleanup and disposal sites is complete
and the sites have been entered into the Center for Environmental Excellence (CEE)
database.
b. Ensure all funded environmental cleanup and disposal projects have an appropriate
job code (sec. 31.8) to facilitate the reporting of liabilities.
c. Update the environmental cleanup and disposal site’s status (that is, not-started,
on-going, or complete) in the CEE database, ensuring completion by mid-August of
each year.
d. Ensure qualified staff meeting the definition of an environmental professional
prepares the cleanup cost estimates for funding requests and government-related site
liability reporting.
e. Ensure that the cleanup cost estimates for government-related site liability
reporting are accurately estimated and updated when funding is received and
maintained for timely recording on the quarterly accrual spreadsheet.
f. Ensure updates to the quarterly accrual spreadsheet reflect any new sites and/or
additional information that is obtained for current sites.
g. Ensure adequate, appropriate documentation to support cleanup cost estimates for
government-related sites is maintained and provided upon audit request.
30.44 - Forest Supervisors, Research Project Leaders, and Job Corps’ Field
Representatives
Forest Supervisors, Research Project Leaders, and Job Corps’ Field Representatives
responsibilities include:
1. Ensure the quality and integrity of financial data processed in their areas of
responsibility; including the accurate, timely recording of obligations and accruals.
2. Comply with direction for hazardous materials/chemical management and
environmental cleanup and disposal provided in FSM 2160.
3. Comply with the procedure set forth in this directive, which includes the following:
a. Ensure the inventory of environmental cleanup and disposal sites is complete and
all funded environmental cleanup and disposal projects have an appropriate job code
(sec. 31.53) to facilitate the reporting of environmental and disposal liabilities.
b. Ensure qualified staff meeting the definition of an environmental professional
(sec. 30.5) prepares the cleanup cost estimates.
WO AMENDMENT 6509.11m-2011-1
EFFECTIVE DATE: 04/26/2011
DURATION: This amendment is effective until superseded or removed.
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c. Ensure all environmental cleanup and disposal sites are entered in the CEE
database and updated whenever the status (for example, not-started, on-going, or
complete) changes.
d. Provide the Regional Environmental Engineer with individual government-related
site cleanup accrual cost estimates for financial statement reporting as identified in
section 31.4 Exhibit 02. Include any new sites and/or additional information obtained
for current sites.
e. Maintain adequate, appropriate documentation to support government-related site
cleanup cost estimates; provide documentation upon audit request.
30.5 - Definitions
Abandoned Mine Lands (AML). A category of locations where there is no longer an
unpatented mining claim under the 1872 General Mining Law where extraction and
processing activity have been determined to be inactive or permanently stopped.
Center for Environmental Excellence Database (CEE). The primary record system for
environmental cleanup and disposal sites for the Forest Service.
CERCLA. Comprehensive Environmental Response, Compensation, and Liability Act of
1980 defined liability and compensation for hazardous substances releases. Under the
auspices of CERCLA, Forest Service manages an active hazardous substances cleanup
program, pursues parties responsible for environmental damage, mounts emergency
response to environmental damage incidents, sets cleanup goals, and plans environmental
protection business activities.
Contingency. An existing condition, situation, or set of circumstances involving
uncertainty as to possible gain or loss to an entity that will ultimately be resolved when
one or more future events occur or fail to occur. In some cases, contingencies may be
identified but the degree of uncertainty is so great that no reporting, recognition or
disclosure is necessary in the general purpose federal financial statements. However, law
may require disclosure of remote contingencies in special purpose reports.
Disclose (Disclosure). Information presented in formal notes to the financial statements
is considered an integral part of the required, basic financial statements. A disclosure for
liabilities should include the nature of any contingency and an estimate of the total range
of possible liability costs.
Environmental Compliance and Protection (ECAP) Program. Forest Service created
ECAP to implement Executive Order (EO) 13148 which requires all Federal agencies to
integrate environmental accountability into their agency’s day-to-day decision making
procedures and operations across all mission elements, activities, and functions.
WO AMENDMENT 6509.11m-2011-1
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DURATION: This amendment is effective until superseded or removed.
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Washington Office Engineering staff administers, manages, and coordinates the ECAP
Program with other Washington Office program staff with delegated areas of
responsibility as identified in FSM 2160.41.
Environmental Cleanup and Disposal Liabilities (EDLs). The Federal government’s
probable and measurable future outflow of resources to clean up or prevent damage to the
environment caused by hazardous substances/ materials/wastes. EDLs may be predicated
on either government-related or government-acknowledged events (see the definitions for
government-related and government–acknowledged events). In general, environmental
compliance and operation and maintenance activities are not considered EDLs.
Environmental Professional. In accordance with 40 CFR 312.10, someone who possesses
sufficient specific education, training, and experience necessary to exercise professional
judgment to develop opinions and conclusions regarding conditions indicative of
hazardous substance(s) release(s) on, at, or to National Forest System land.
Government-Acknowledged Event. Events that are of financial consequence to the
Federal government when it did not cause or contribute to the contamination and it is not
otherwise liable for cleanup costs, but it chooses to respond to an event resulting in
environmental damage or contamination, in order to provide for the public’s general
welfare. For example, hazardous substances released from an abandoned mine may
affect water quality downstream.
Government-Related Event. Events resulting in environmental damage or contamination
where the Federal government caused the contamination or is otherwise related to it, in
such a way that the Federal government is legally and financially responsible for the
cleanup; for example, environmental damage from Federal operations resulting in
hazardous substances and/or hazardous waste that the Federal government is required by
statutes and/or regulations to clean up, remove, contain or dispose of.
Hazardous Material/Substance/Waste. A solid, liquid or gaseous material, or
combination of these materials, which because of its quantity, concentration, or physical,
chemical, or infectious characteristics may cause or significantly contribute to an increase
in mortality or an increase in serious irreversible, or incapacitating reversible, illness or
pose a substantial present or potential hazard to human health or the environment when
improperly treated, stored, transported, disposed of, or otherwise managed. For example,
solvent is a hazardous material or hazardous substance that is used to clean chainsaws or
paintbrushes. With repeated use, the solvent becomes dirty and unserviceable, therefore,
a hazardous waste.
Liability. As used in this chapter, the term “liability” refers to a financial rather than a
legal obligation. A financial liability is the probable and measurable future outflow of
resources arising from past transactions or events. See the definitions of Probable and
Measurable.
WO AMENDMENT 6509.11m-2011-1
EFFECTIVE DATE: 04/26/2011
DURATION: This amendment is effective until superseded or removed.
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CHAPTER 30 - ACCRUING ENVIRONMENTAL AND DISPOSAL LIABILITIES
Liabilities Covered by Budgetary Resources. Liabilities incurred that are covered by
realized budgetary resources as of the balance sheet date. Budgetary resources
encompass not only new budget authority but also other resources available to cover
liabilities for specified purposes in a given year. Available budgetary resources include:
(1) new budget authority, (2) unobligated balances of budgetary resources at the
beginning of the new year or net transfers of prior year balances during the year,
(3) spending authority from offsetting collections (credited to an appropriation or fund
account), and (4) recoveries of unexpired budget authority through downward
adjustments of prior year obligations. Liabilities are considered covered by budgetary
resources if they are to be funded by permanent indefinite appropriations, which have
been enacted and signed into law as of the balance sheet date, provided that the resources
may be apportioned by the Office of Management and Budget (OMB) without further
action by the Congress and without a contingency having to be met first.
Liabilities Not Covered by Budgetary Resources. This category is for liabilities which
are not considered to be covered by budgetary resources, as provided in the previous
paragraph.
Measurable. According to the Financial Accounting Standards Advisory Board, a
liability must be “measurable”, that is, that which can be determined with reasonable
certainty or is reasonably estimable. Measurable means that an item has a relevant
attribute that can be quantified in monetary units with sufficient reliability to be
reasonably estimable. Liabilities reported in the financial statements are measured by
different attributes depending on the item (such as historical cost of a similar work
project, fair market value, current cost, present value, expected value, and settlement
value).
Obligations. Amounts of orders placed, contracts awarded, services received, and other
transactions occurring during a given period that would require payments during the same
or a future period.
Probable. According to the Financial Accounting Standards Advisory Board, a liability
must be “probable”, that is, that which can reasonably be expected or believed to be more
likely than not on the basis of available evidence or logic but which is neither certain nor
proven. The probability of a future outflow or other sacrifice of resources is assessed on
the basis of current facts and circumstances, including the law that provides general
authority for federal entity operations and specific budget authority to fund programs.
Reasonably Estimable. Reasonably estimable relates to the ability to reliably quantify in
monetary terms the outflow of resources that will be required.
Recognition (or Recognize). To determine the amount, timing, classification, and other
conditions precedent to the acceptance and entry of a transaction; hence, to give
expression on the books of account. Recognition is the process of formally recording or
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incorporating an item into the financial statements of an entity as an asset, liability,
revenue, expense, or the like. A recognized item is depicted in both words and numbers,
with the amount included in the statement totals. Explanatory narrative may be included
in the financial statement footnotes.
Resource Conservation and Recovery Act of 1976 (RCRA). RCRA gave the
Environmental Protection Agency (EPA) the authority to control hazardous materials
from the “cradle-to-grave”. This includes the generation, transportation, treatment,
storage, and disposal of hazardous wastes. RCRA also set forth a framework for the
management of non-hazardous wastes. (http://www.epa.gov).
Standard General Ledger (SGL). The Standard General Ledger provides a uniform Chart
of Accounts and technical guidance to be used in standardizing Federal agency
accounting, which supports the preparation of required standard external reports. The
Treasury Financial Manual’s United States Standard General Ledger (USSGL)
Supplement (released annually) is composed of five major sections: Chart of Accounts,
Account Descriptions, Accounting Transactions, USSGL Attributes, and Report
Crosswalks. A copy of the USSGL Supplement is available on Treasury’s website,
http://www.fms.treas.gov/ussgl/index.html.
31 - ENVIRONMENTAL CLEANUP LIABILITY ACCOUNTING PROCESS
Environmental cleanup and disposal cost liabilities arise from the need to clean up or prevent
further release of hazardous substances, materials, and wastes into the environment. Forest
Service is required to recognize a liability for environmental cleanup costs as a result of past
transactions or events when a future outflow or other sacrifice of resources is probable and
reasonably estimable.
For assistance in determining probable and reasonably estimable liabilities related to
environmental cleanup, refer to the Federal Accounting Standards Advisory Board’s (FASAB)
Federal Financial Accounting and Auditing Technical Release No. 2: “Determining Probable
and Reasonably Estimable for Environmental Liabilities in the Federal Government”
(http://www.fasab.gov/pdffiles/codification_report2010.pdf).
Forest Service’s inventory of environmental cleanup and disposal sites is kept electronically in
the U. S. Department of Agriculture’s Center for Environmental Excellence (CEE) database.
Environmental and disposal liabilities (EDL) may be recorded in three standard general ledger
(SGL; see sec. 30.1, numbered paragraph 5) liability accounts, depending on the character and
circumstances of the environmental damage site or project (the stage of its life). The three
accounts and their related Forest Service handbook direction are identified in exhibit 01, as
follows:
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31 - Exhibit 01
Liability Accounts for Environmental Cleanup and Disposal Liabilities
Environmental Damage
Circumstance
1. Funded cleanup projects’ contracts and
agreements are accrued using a mathematical
process (ASC-B&F Service-Wide and Accounts
Maintenance staff).
2. Government related sites only. Includes
unfunded cleanup work that is inventoried and
given an estimate; and funded cleanup work that
may be obligated in SGL 4801, Unliquidated
Orders, reduced by payments made to date.
3. An external party initiates legal action against
the Forest Service for alleged environmental
damage.
FS Accrual
Handbook
Section
FSH 6509.11m,
Chapter 20
SGL Account
2190 - Other Liabilities
FSH 6509.11m,
Chapter 30
2995 - Environmental
Cleanup Liabilities
FSH 6509.11m,
Chapter 40
2920 - Contingent
Liabilities
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DURATION: This amendment is effective until superseded or removed.
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CHAPTER 30 - ACCRUING ENVIRONMENTAL AND DISPOSAL LIABILITIES
31.1 - Identify and Classify Incidents of Damage to the Environment
Unit level employees shall identify all incidents of damage to the environment caused by
hazardous substances, materials, and waste within their respective areas of responsibility. Units
shall report those cleanup sites to their respective region, station or Area (R/S/A) environmental
engineer. The R/S/A environmental engineer shall analyze the initial report to confirm that
environmental damage or “release” occurred. If the damage or a release is confirmed, the R/S/A
environmental engineer shall:
1. Consult with the Office of General Counsel as needed, to classify the site damage in
terms of financial liability (refer to sec. 30.5 for the definition of liability), using the
following categories:
a. Government Related Event (Accidents; sec. 30.5).
b. Government Acknowledged Event (sec. 30.5).
2. Establish a possible financing option (sec. 31.5).
3. Contact the Washington Office Engineering staff’s Environmental Compliance and
Protection Program (ECAP) group for advice about environmental cleanup issues.
31.2 - Estimate Cleanup Costs for Each Government-Related Environmental
Damage Site
31.21 - Activities Considered in the Cost Estimate
Environmental and Disposal Liabilities (EDL) cost estimates include any cleanup activity or
uncompleted portion of an activity, such as:
1. Studies, plans, cleanup activities, and cleanup operations and maintenance costs
necessary to comply with applicable legal and regulatory requirements, and the costs of
contractors, engineers, and consultants. Exclude from the estimate, operations and
maintenance (O&M) costs associated with routine facility and agency operations. The
only occasion when O&M costs are included is the closure of a facility operation in
accordance with environmental regulatory permits. For example, if a R/S/A was
operating an active landfill, the O&M costs associated with the landfill’s routine
operations or infrastructure would not be considered an EDL. Even environmental
sampling, analysis and reporting required under a RCRA permit during operation would
not be an EDL. However, O&M costs associated with an environmental cleanup action
or the closure of an inactive site (for example, a closed landfill), such as the O&M
associated with a groundwater treatment system, would be an EDL.
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2. Machinery and equipment dedicated to a response action (removal or remedial) that
do not have alternative uses, and their associated operating and maintenance costs are an
EDL cost element.
3. Compensation and benefits of government personnel that devote significant time to an
environmental cleanup effort are an EDL cost element.
4. Long-term monitoring (LTM) associated with a response action is an EDL cost
element.
31.22 - Development of Cost Estimates
The Financial Accounting Standards Advisory Board (FASAB) requires agencies to develop a
total cleanup cost estimate for “probable” and “reasonably possible” EDLs if it is reasonable to
do so. Cost estimates should be prepared within one fiscal year of EDL identification. If a total
cleanup cost estimate cannot be developed (possibly because a study has not been completed and
insufficient information is available regarding the type or extent of contamination), the R/S/A
Environmental Professionals must develop a cost estimate for the portion of the cleanup (interim
cleanup activities) that are known and estimable (such as the cost to study).
A range of the total cleanup costs should be reported if site conditions have not yet been fully
determined, such as the extent and/or nature of contamination or if several cleanup alternatives
are possible and a preferred alternative has not been selected. Reporting a range of costs allows
the R/S/A Environmental Professional to capture the uncertainty inherent when predicting future
cleanup costs early in the cleanup process. The assumptions used to develop the low and high
end of the cost estimate range must be documented such that the estimate is reproducible and
easy to revise as new site information becomes available.
For sites regulated under CERCLA that have one or more potentially responsible parties (PRPs),
the R/S/A Environmental Professional may develop a cost range that reflects the agency’s likely
cleanup responsibilities (such as oversight of the cleanup or long-term monitoring) on the low
end of the range, and the total cleanup costs on the high end of the range. The assumptions used
for creating such a range should be documented.
31.23 - Cost Estimate Documentation
The R/S/A Environmental Professional ensures that all cost estimates are documented such that
costs and underlying assumptions are clearly presented and understood. This includes backup
materials that support the cost estimate for interim cleanup activities and total site cleanup
(including assumptions used). The detailed backup materials that demonstrate how the costs
were derived need to be maintained in the project files at the corresponding R/S/A field office.
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If only a portion of the total cleanup cost is estimable, then supporting documents applicable to
the interim cleanup action costs will be developed and maintained. Cost estimates are presented
by activity based work elements and include all capital costs, all labor costs, annual O&M costs
(if applicable), and any periodic costs related to the cleanup action.
Applicable documentation should be readily accessible for review even after the EDL is removed
from the agency EDL inventory. Therefore, EDL records and documents are maintained for no
less than two years after the site cleanup action is completed. Note: this retention requirement
does not supersede applicable regulatory requirements for document and file retention.
31.24 - Cost Estimate Updates
Changes or updates to cleanup cost estimates are required so that cost figures reported on the
periodic financial statements are fairly presented. At least annually, between August 1st and
13th, or when there is a material change in the status of the site, the cost estimate will be
reviewed by the R/S/A environmental professional and adjusted as needed. Any changes to the
estimate must be documented in the detailed backup materials supporting the cost estimate.
Examples of new facts or clarifying information that could affect a cost estimate include:
1. Further delineation of the nature and extent of contamination at the site.
2. Identification, number and financial position of potentially responsible parties (PRPs).
3. Allocation of costs among PRPs and the government based on court judgments,
assessments, or consent decrees.
4. Results of an Engineering Evaluation/Cost Analysis (EE/CA), Remedial
Investigation/Feasibility Study (RI/FS), Corrective Measures Study (CMS) or other
study.
5. Approval of a Records of Decision (ROD) or other decision document.
6. Refinements of the remediation plan, including technology and methodology.
7. The type and duration of post-closure monitoring required.
8. New laws and regulations which will affect the site remediation.
If no new site information has been obtained that would alter the cost estimate, the previous cost
estimate generated would be appropriate for current use; however, the R/S/A environmental
professional shall adjust the previous estimate annually for work completed and inflation.
R/S/A environmental professionals shall update the cost estimates for government-related
cleanup projects when funding is received. Each estimate must include both the funded and the
known unfunded amounts.
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Government-related cleanup cost estimates that have not already been updated during the current
fiscal year shall be adjusted by applying the inflation factor current for the year. All updates
must be made to the quarterly accrual spreadsheet as noted in sec. 31.4, exhibit 01.
31.3 - Maintain the Inventory of All Environmental Cleanup Sites
Each R/S/A must maintain an inventory of all environmental cleanup sites located on the lands
or in the facilities under their management. The CEE database is the primary system of record
for this inventory.
The Washington Office and R/S/A environmental engineers record new cleanup sites, identifying
the affected location or facility, and updates data on existing cleanup sites. All of Forest
Service’s environmental cleanup and disposal sites for government related and government
acknowledged events are identified in CEE.
31.4 - Gather Information and Determine the Accrual Amount
Exhibit 01 illustrates the steps required to gather the financial information and determine the
environmental cleanup costs accrual amount.
R/S/A environmental engineers may estimate cleanup costs for all new sites on a “life-cycle”
basis for budgeting purposes, but need only to provide estimates for government-related sites for
the financial statements according to direction in FASAB Federal Financial Accounting and
Auditing Technical Release No. 2, “Determining Probable and Reasonably Estimable for
Environmental Liabilities in the Federal Government.” Forest Service policy is to include all
obligations involving Government-acknowledged sites in the mathematical model used to
determine accrual amounts. Exhibit 02 illustrates the basis for determining the “Total
Outstanding Liability Estimate” amount for government-related sites that should be in column F
in the quarterly accrual spreadsheet following Technical Release No. 2 guidance.
Although there is not a “one size fits all” for these incidents, the clean up process happens in
basically four phases, as follows:
1. Phase One - A study/assessment is underway, to determine if contamination exists.
2. Phase Two - The study/assessment is complete. Forest Service evaluates the extent of
the clean up and the cleanup options available. At this point, for government-related
incidents, a cleanup option is chosen and estimated costs are refined.
3. Phase Three - The Forest Service implements clean up procedures.
4. Phase Four - During this post-implementation or final phase, Forest Service continues
to monitor the site to ensure that the site is contained and no new contamination is
identified.
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31.4 - Exhibit 01
Environmental Cleanup Liability Accrual Amount’s
Composition and Calculation
Calculation Step
1. Chief Financial Officer (CFO) Financial Reporting & Reconciliation
(FR&R) staff obtains the environmental financial information and initiates the
accrual spreadsheet for the new quarter and sends it to ASC-B&F Servicewide
& Accounts and Maintenance (SWAM) staff. For the first quarter of the fiscal
year, the beginning balance in Column F is calculated by subtracting
September’s actual expenditures from the prior year’s ending accrual amount
for liability (Column L). The calculation is included in the spreadsheet that is
provided to WO Engineering staff.
2. WO Engineering staff receives the quarterly accrual spreadsheet and the
financial information from ASC-B&F SWAM. The financial information
includes obligations, expenditures and unpaid obligations for all environmental
cleanup projects that are recorded in job codes established with the special job
code model described in this directive.
3. WO Engineering staff distributes the quarterly accrual spreadsheet to the
R/S/A environmental engineers to obtain their updates to the total outstanding
liability estimate and verification of expenditures from their project site
documentation. [Follow 31.4 - Exhibit 02 for total current liability estimate
amount determination.]
4. WO Engineering staff reviews R/S/A input for accuracy and completeness
and then compiles the responses into one spreadsheet.
5. WO Engineering staff submits the quarterly accrual spreadsheet to the ASCB&F SWAM staff showing the calculation of the environmental cleanup cost
accrual.
6. ASC-B&F SWAM staff forwards the accrual spreadsheet to the CFO FR&R
staff for review and concurrence.
7. CFO FR&R staff reviews the accrual spreadsheet and requests clarification
or additional information from WO Engineering staff if needed. Any necessary
changes are made with concurrence from WO Engineering staff.
8. ASC-B&F SWAM is notified of concurrence from CFO FR&R staff and the
accrual is posted to the financial system. If changes are made (from Step 7),
the updated quarterly accrual spreadsheet will be forwarded to ASC-B&F
SWAM staff as well as instructions to record the new accrual amount in the
financial system.
Responsible
Area
FR&R/ASCB&F
WO
Engineering
WO
Engineering
WO
Engineering
WO
Engineering
ASCB&F/FR&R
FR&R
ASC-B&F
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31.4 - Exhibit 02
Total Outstanding Liability Estimate Amount Determination Process
Phase
Process
Prior to
Phase 1
If probable cleanup activity would be accomplished on the site if the contamination
level requires it, develop an estimate that is either based on experience with a similar
site or the estimated cost of a study or assessment if a similar site is not available.
Phase 1
Once a study or assessment is underway, the estimate would be the actual cost
associated with that full activity. For example, the Total Current Liability Estimate
would include the obligation for a company doing the study, plus force account
charges, supplies, and so forth, similar to the all-inclusive list of costs included in
the WorkPlan system. Throughout the assessment activity, modify the estimate
according to situations at the site by recording the needed increase or decrease to the
total estimate in column G.
Between
If there is a time delay in selecting a cleanup option, report the costs for the option
Phase 1
with the lowest amount of cost.
&2
Phase 2
Option is selected awaiting funding; estimate would be based on the option selected
and any known additional expense for employees and/or supplies, etc., until funding
for the option is received and through the cleanup activity (that is, what would be
included in WorkPlan for the entire space of time for cleanup, even if it is
anticipated to take 2 or more years).
Phase 3
Once funding is received and the selected option work is initiated, the estimate
would essentially be the same as in Phase 2 with modification for actual cost
contracts and known changes to other requirements. Throughout the cleanup
activity, modify the estimate according to situations at the site by recording the
needed increase or decrease to the total estimate in column G.
Phase 4
Estimate the cost for monitoring the site after the cleanup activity is completed
using either the study’s estimate for monitoring costs or an engineer’s estimate if the
study did not include post-cleanup site monitoring. Throughout the monitoring
activity, modify the estimate according to situations at the site by recording the
needed increase or decrease to the total estimate in column G.
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31.4 - Exhibit 02--Continued
Phase
Process
Phase 1,
[Note: At the beginning of each fiscal year, the Current Fiscal Year Beginning
2, 3, & 4
Liability Estimate (Column F) is populated with the Accrual Amount for Liability
with
for the 4th Quarter (Column L) less September’s actual expenditures.
expenses
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31.5 - Determine Financing for Environmental Cleanup
Environmental cleanup sites listed in CEE are initially unfunded. Many cleanup sites remain in
CEE for many, many years due to the unavailability of funds.
31.51 - Possible Financing Options
Program National Forest System Minerals and Geology (NFMG) is ECAP’s designated
appropriated funds. Generally, a government-related cleanup project qualifies for the NFMG or
USDA financing options if the original event that caused the damage (such as a spill or release)
occurred on or prior to October 17, 1986 when the Superfund Amendments and Reauthorization
Act (“SARA”) was enacted. Government-acknowledged cleanup projects, on the other hand,
generally qualify for the NFMG or USDA financing options regardless of the date when the
original event that caused the damage occurred. Both NFMG and USDA funding are allocated
on a competitive basis. If neither NFMG nor USDA funding is forthcoming and a cleanup is
essential, then cleanup must be financed by the program identified by a primary purpose
analysis. Program funds, identified by applying the primary purpose principle, finance the
cleanup of environmental damage caused by government-related events that occurred after
October 10, 1986.
The three possible financing options are set out in exhibit 01 as follows:
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31.51 - Exhibit 01
FINANCING OPTIONS FOR ENVIRONMENTAL CLEANUP WORK
Date of the Event That
Caused the Damage
Government-Related Events
occurring on or prior to
10/17/1986
Government-Acknowledged
Event Regardless of Date
Government-Related or
Government-Acknowledged
Event Regardless of Date
Government-Related Events
occurring on or prior to
10/17/1986 or GovernmentAcknowledged Event
Regardless of Date
Appropriate Financing
Treasury
Symbol
12X1106 “National Forest
System
Fund/Program Fund/Program
Name
NFNF/NFMG
National Forest
System/
Minerals and
Geology
Management
12X1106 “National Forest
NFNF/NFMG
National Forest
System
System/
Minerals and
Geology
Management
Forest Service Financing is Determined by Applying the
Primary Purpose Principle
Reimbursable Agreement
with USDA, Financed by
12X0500 “Hazardous
Materials Management,
Agriculture”
Forest
Service’s
NFEX/NFEX
(12X1106)
National Forest
System
External
Reimbursable
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31.52 - Unfunded Cleanup Sites Become Funded
Unfunded cleanup sites become funded in a variety of ways, as follows:
1. In Conjunction with a Forest Land Management Project on the Same Site. A
previously unfunded site’s cleanup work may become funded because the cleanup must
be completed in connection with a new work project on the same site. For example, an
illegal trash dump must be cleaned up before construction can begin on the same site to
build a new campground. In these cases, the same funds used for the construction of the
campground are also used for the cleanup of the illegal dump. This financing method is
called the primary purpose principle.
2. In Priority Order. The regions, stations, Area, and Job Corps (R/S/A) environmental
engineer, Washington Office Engineering staff, and the USDA Environmental
Management Division (EMD) collaborate to prioritize cleanup sites for financing. This
cooperation occurs before each fiscal year begins and frequently during the year as
conditions change. Cleanup work is prioritized according to the following criteria:
a. The cleanup site violates environmental statutes such as the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) and
the Resource Conservation and Recovery Act of 1976 (RCRA).
b. The degree of potential, or existing, harm to life and property (public health risks).
c. The availability of Forest Service appropriated funds, either NFMG (ECAP’s
designated appropriated funds), or other appropriated funds determined by applying
the primary purpose principle.
d. The availability of U.S. Department of Agriculture funds to finance reimbursable
agreements for environmental cleanup projects on Forest Service lands.
e. Under special circumstances, funding may be available from Environmental
Protection Agency (EPA) Superfund and/or the Coast Guard Oil Spill Trust Fund.
Washington Office Deputy Chiefs, regions, stations, Area, and Job Corps allocate funding on a
discretionary basis within the budget of the particular program area with primary responsibility
(determined by applying the primary purpose principle) for the event that caused or threatens to
cause the contamination.
Exhibit 01 illustrates the financing of environmental cleanup costs:
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31.52 - Exhibit 01
FINANCING ENVIRONMENTAL CLEANUP COSTS
Status of Environmental
Cleanup Site
1. Unfunded Work Standard General Ledger
Account 2995, Unfunded
Environmental Cleanup
Liability
2. Cleanup Work Required
in Conjunction with A
Resource Project on the
Same Site. Apply the
Primary Purpose Principle.
3. Work Funded by Forest
Service Appropriated Funds,
as An Environmental
Cleanup Project. Damage
occurred on or before
10/17/1986.
4. Environmental damage
occurred after 10/17/2006.
Apply the Primary Purpose
Principle.
5. Work Funded by Forest
Service Appropriated Funds,
as A Discretionary
Environmental Cleanup
Project.
6. Cleanup Work Financed
by the USDA Hazardous
Materials Management
Division, Under a
Reimbursable Agreement
With the Forest Service
Treasury
Symbol
Fund
Program
12X1106 - National
Forest System
NFNF - National
Forest System
NFMG - Minerals
and Geology
Management
Same As the
Resource Project
Same As the
Resource Project
Same As the
Resource Project
12X1106 - National
Forest System
NFNF - National
Forest System
NFMG - Minerals
and Geology
Management
Analyze the Original Event that Caused the Damage to Identify
the Treasury Symbol, Fund, and Program to Finance the
Cleanup.
Analyze the Original Event that Caused the Damage to Identify
the Treasury Symbol, Fund, and Program to Finance the
Cleanup.
Forest Service Side:
12X1106
USDA Side:
12X0500
“Hazardous
Materials
Management,
Agriculture”
Forest Service
Side: NFEX
“External
Reimbursable”
Forest Service
Side: NFEX
“External
Reimbursable”
N/A
N/A
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31.53 - All Financed Cleanup Projects Have Special Accounting Structure
Environmental cleanup projects, regardless of financing source, use a special accounting
structure. The special format facilitates the electronic retrieval of project expenditures which are
an essential element in the environmental liability accrual process. All environmental cleanup
projects shall have this mandatory accounting structure, as displayed in the Structure Guide
maintained on the ASC B&F Budget Policies and Procedures website, as follows:
http://fsweb.asc.fs.fed.us/bfm/programs/budget-execution/fieldGuidance.php.
31.6 - Prepare and Record the Accrual Entry
The Engineering staff’s ECAP group must provide the environmental cleanup cost accrual
spreadsheet to ASC-B&F SWAM by the 20th of the last month in each fiscal quarter. (If the 20th
falls on a Saturday, submit the day before. If it falls on a Sunday, submit the day following.) The
amount accrued is the sum of unfunded and funded cleanup work, less the amount of
expenditures made on the funded projects (sec. 31.4).
The ASC-B&F SWAM staff will forward the accrual spreadsheet to the CFO FR&R staff for
review and concurrence. The CFO FR&R staff will review the accrual spreadsheet and request
clarification or additional information from Washington Office Engineering staff as needed.
Any necessary changes shall be made with concurrence from Washington Office Engineering
staff. Once ASC-B&F SWAM staff are notified of concurrence by the CFO FR&R staff, the
ASC-B&F SWAM prepares the service-wide estimated accruals for environmental clean-up
costs and enters them in the financial system quarterly, at a national level in region 17
(“servicewide accounting center” 17), reversing the previous quarter’s accrual at the same time.
The accrual spreadsheet is retained for audit. Data elements for the accrual entry are displayed
in exhibit 01 below. For brevity, one general fund/program is illustrated.
Environmental Liabilities are recorded in Standard General Ledger (SGL) account 2995,
Environmental Cleanup Cost Liability, defined as the estimated liability for projected future
cleanup costs (not yet due and payable) associated with removing, containing and /or disposing
of (1) hazardous materials from property, or (2) material and/or property consisting of hazardous
materials at permanent or temporary closure or shutdown of associated property, plant and
equipment. SGL 2995 Environmental Cleanup Cost Liability has two liability attributes:
1. Not Covered by Budgetary Resources. The Forest Service has not received funding to
cover the outflow of resources, and
2. Covered by Budgetary Resources. The Forest Service has received funding to cover
the outflow of resources.
Forest Service’s entry in SGL 2995 must be the sum of the two types of projects, those unfunded
and those funded but undelivered. The field’s entries in the accrual spreadsheet are the basis for
the amount in SGL 2995.
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31.6 - Exhibit 01
Accruing Environmental Cleanup Liabilities:
Standard General Ledger Postings
Fund/Program
NFNF/NFMG - Minerals and
Geology Management
(Note: For brevity, only one
general fund/program
combination is displayed.)
Standard General
Ledger Postings
Proprietary:
Debit: 6800 Future
Funded Expenses
Credit: 2995
Estimated Cleanup Cost
Liability
Budgetary:
None
Vendor
Identification
Code
FS ACCRUAL
Budget
Object
Code
2540
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31.7 - Analyze the Results of Accrual Methodology
Audit and Assurance staff, Internal Quality Assurance Branch performs periodic analysis, at least
annually, of accrual methodologies to determine necessary adjustments for current and/or future
reliable estimates of accruals.
31.8 - Accrual Documentation and Reconciliation
ASC-B&F SWAM group maintains the accrual spreadsheet and adjustment document relating to
these accruals in a central file.
CFO FR&R reviews the accruals for environmental cleanup and disposal costs for
reasonableness quarterly.
The accrual spreadsheet columns are described in exhibit 01, as follows:
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31.8 - Exhibit 01
QUARTERLY ACCRUAL SPREADSHEET FIELDS
Column
Column Title
Description
A
#
Sequential number assigned to each site. Please add any new sites
at the bottom of the spreadsheet.
B
Site
Site name, including any descriptive information that will assist
with cost estimation.
C
Region, City,
State
Site location information, including enough descriptive
information to facilitate site visit planning.
D
Accounting (Job)
Code
Project accounting (job) code, including any new accounting (job)
codes established since the last quarterly accrual.
E
Is the liability
probable and
estimable?
If the liability is probable and estimable, enter “Y”, if not, enter
“N”. If the liability is NOT probable and estimable, STOP. Do
not enter any further information for the site on the spreadsheet.
F
Current Fiscal
Year: Beginning
Liability Estimate
Amount in the current fiscal year which will be accrued if all
criteria in SFFAS 5 are met. For the first quarter of the year, this
column is pre-populated with a calculated balance using prior
year’s ending balance less any expenses incurred in September.
Adjustments resulting from the addition of a new site or updated
information should be recorded in Column G.
G
Increase or
Decrease to
Beginning
Liability Estimate
Increases or decreases to the current liability estimate are recorded
here. Changes to the current liability estimate may result from
additional information regarding an existing site as well as the
addition of a new site.
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31.8 - Exhibit 01--Continued
Column
Column Title
Description
H
Total Current
Liability Estimate
(Column F + G)
This is an automatically calculated field and no entry is required.
This field is the summation of Column F (Current Fiscal Year
Beginning Liability Estimate) and Column G (Increase or
Decrease to Beginning Liability Estimate).
I
Amount of
Liability Funded
in Current Year
Amount of the Total Current Liability Estimate (Column H) that
is funded in the current year. Note: This amount never exceeds
the amount in Column H.
J
Unpaid
Expenditures as of
2nd Month of the
(Current) Quarter
Amount of YTD cumulative unpaid expenditures from the EDL
Expenditure Status Report that is provided with the quarterly
accrual spreadsheet.
K
Paid Expenditures
YTD through 2nd
Month of the
(Current) Quarter
Amount of YTD paid expenditures from the EDL Expenditure
Status Report that is provided with the quarterly accrual
spreadsheet.
L
Accrual Amount
for Liability for
(Current) Quarter
20yy (Column H
– J-K)
This is an automatically calculated field and no entry is required.
This field subtracts Column J (Unpaid Expenditures as of 2nd
Month of the Quarter) and Column K (Paid Expenditures YTD
through 2nd Month of the Quarter) from Column H (Total Current
Liability Estimate).
M
Previous Quarter
Accrual Amount
for Liability
(Previous) Quarter
20yy)
Accrual amount for the previous quarter.
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31.8 - Exhibit 01—Continued
Column
Column Title
Description
N
Percentage
Difference
between the
current quarter
and the previous
quarter
This is an automatically calculated field and no entry is required.
The amount in Column N is the percentage difference between
EDL liability compiled for prior quarter and current quarter.
O
Explanation if
difference is
>20%
Detailed explanation for accrual amount changing by more than
20% from the previous quarter is required.
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