5 unchanged sentences
We establish reserves for specific legal matters when we determine that the likelihood of an unfavorable outcome is probable and the loss is reasonably estimable.
+Added: The Company reviews the developments in contingencies that could affect the amount of the reserves that have been previously recorded.
+Added: The Company adjusts provisions and changes to disclosures accordingly to reflect the impact of negotiations,
+Added: settlements, rulings, advice of legal counsel, and updated information.
+Added: Significant judgment is required to determine both the probability and the estimated amount of any potential losses.
Some environmental laws, such as the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (also known as “CERCLA” or the “Superfund law”) and similar state statutes, can impose liability upon former owners or operators for the entire cost of investigating and remediating contaminated sites regardless of the lawfulness of the original activities that led to the contamination.
−Removed: In July 2000, an entity which later became a subsidiary of the Company received a Section 104(e) Request for Information (“RFI”) from the National Park Service (“NPS”), pursuant to CERCLA, regarding the presence of radioactive material at a site within a national park, which site was operated by an alleged predecessor to our subsidiary over 50 years ago.
+Added: In July 2000, an entity which later became a subsidiary of the Company received a Section 104(e) Request for Information (“RFI”) from the National Park Service (“NPS”), pursuant to CERCLA, regarding the presence of radioactive material at a site within a national park, (“Orphan Mine”), which site was operated by an alleged predecessor to our subsidiary over 50 years ago.
Following our subsidiary’s response to the RFI, the NPS directed it and another alleged former operator to perform an Engineering Evaluation and Cost Analysis (“EE/CA”) of a portion of the site.
2 unchanged sentences
To our knowledge, the EE/CA has not been released and a public comment period has yet to be opened.
−Removed: Following completion of the EE/CA, the NPS may seek reimbursement for its investigative and remedial efforts to date, or direct one or more of the potentially responsible parties to perform any remediation that may be required by CERCLA or may enter an alternative dispute resolution proceeding to attempt to resolve each party’s share.
−Removed: In addition, the NPS may seek to recover damages for loss of use of certain natural resources.
+Added: The Environmental Protection Agency (“EPA”) episodically updates its electronic databases concerning pending Superfund sites.
+Added: As of June 2023, the entry in EPA’s Superfund database for this site states that this “[s]ite does not qualify for the NPL [National Priorities List] based on existing information.
+Added: The EPA has determined that no further federal action (NFFA) will be taken at this site.” As a result, DRS has eliminated the Orphan Mine reserve as a liability is no longer probable or estimable.
+Added: However, it remains possible that the NPS may seek to recover damages, including for remediation and/or loss of use of certain natural resources.
We believe that we have legitimate defenses to our subsidiary’s potential liability and that there are other potentially responsible parties for the environmental conditions at the site, including the U.S.
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Wallace 57 Executive Vice President, Business Operations
−Removed: Lynn has been a director since 2012 and has been our Chief Executive Officer since January 2012.
+Added: Lynn has been a director since 2012 and our Chief Executive Officer since January 2012.
Lynn also serves as Chairman of our Board.
35 unchanged sentences
As the Company’s chief legal officer, Mr.
−Removed: Dorfman oversees the Company's legal and regulatory affairs, including transactions, litigation, corporate governance, internal audit, contracts, insurance, intellectual property protection, and ethics and compliance programs (including environmental health and safety, international trade, and industrial and cyber security).
+Added: Dorfman oversees the Company's legal and regulatory affairs, including transactions, litigation, corporate governance, internal audit, contracts, insurance, intellectual property protection, and ethics and compliance programs (including environmental health and safety, international trade, and industrial and cybersecurity).
Dorfman joined the Company in 2005 as corporate counsel and was promoted multiple times between 2006 and 2011 to his current executive leadership position.
14 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.