  We use rigorous nonequilibrium thermodynamic arguments to establish that (i)
the nonequilibrium entropy S(T_{0}) of any system is bounded below by the
experimentally (calorimetrically) determined entropy S_{expt}(T_{0}), (ii)
S_{expt}(T_{0}) is bounded below by the equilibrium or stationary state (such
as the supercooled liquid) entropy S_{SCL}(T_{0}) and consequently (iii)
S(T_{0}) cannot drop below S_{SCL}(T_{0}). It then follows that the residual
entropy S_{R} is bounded below by the extrapolated S_{expt}(0)>S_{SCL}(0) at
absolute zero. These results are very general and applicable to all
nonequilibrium systems regardless of how far they are from their stationary
states.
