This property has a documented history as a facility using PFAS-containing firefighting foam going back to 1942. Historical insurance policies issued during those prior operations and through 1986 could fund a cleanup — and recover costs already spent.
Paine Field's fuel storage operations date to World War II, with underground storage tanks serving both military and civilian aviation across multiple decades — the East fuel farm USTs were in use during the war and upgraded in 1967, while the West fuel farm USTs were originally military installations reactivated in 1982. The site also hosted firefighting training exercises conducted by Paine Field and local fire departments, which involved extinguishing fires with aqueous film-forming foam (AFFF), a known source of PFAS contamination. UST closure and assessment activities spanned from 1994 to 2000, and PFAS-focused environmental investigations have been ongoing from 2018 through 2025, with planned remediation including excavation of an estimated 2,500 to 3,750 cubic yards of contaminated soil and treatment of 5,000 to 30,000 gallons of affected groundwater. That history could support an insurance cost recovery claim against carriers who issued insurance policies 40+ years ago.
Why Historical Insurance Policies May Be Accessible
Pre-1986 Commercial General Liability (CGL) policies were occurrence-based and did not contain an effective pollution exclusion in Washington. If contamination occurred while those policies were active, those historical insurance carriers may still have a legal obligation to fund the cleanup costs, even if the business closed or the property changed hands.
Fuel storage and fire training operations at this site began decades before 1986, when occurrence-based Commercial General Liability policies carried no effective pollution exclusion in Washington. Both the petroleum releases from World War II–era underground storage tanks and the PFAS contamination from AFFF use trace directly to operations conducted under those historical policies. With cleanup now under way — tank removal, large-scale soil excavation, and groundwater treatment — the responsible parties face substantial remediation costs that historical CGL carriers may be obligated both to reimburse and to fund going forward.
Restorical's role is to locate viable historical policies, determine whether a successful coverage claim is possible, and assist our clients and their legal counsel to obtain insurance coverage. Restorical then manages the claim, including accounting, to ensure the cleanup is funded in a timely manner.
What We Look For
- Historical insurance policies (pre-1986)
- Policy numbers, carrier names, and coverage periods
- Connection between contamination timing and policy period
- Evidence linking cleanup obligation to insured activity
What We Deliver
- Historical Coverage Chart
- Trigger Analysis & Property/Policy Nexus
- Coverage strategy with recommendations
- Insurance funding for your remediation
- Claims Management & Forensic Accounting
The Restorical Proven Process
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Contact UsThis analysis is preliminary and based on publicly available records. Restorical Research is not a law firm and does not provide legal advice.