PFAS cleanup site — Restorical Research
JBLM Building A1033 AOC9-2
Joint Base Lewis-Mcchord, Pierce County
Restorical Research
Preliminary Site-Specific Analysis

This property has a documented history as a facility using PFAS-containing firefighting foam predating 1986. Historical insurance policies issued during those prior operations and through 1986 could fund a cleanup.

The AOC9-2 area at Joint Base Lewis-McChord is a PFAS-impacted site where historical use of Aqueous Film-Forming Foam (AFFF) at multiple fire training areas — including documented fire training pits and a former practice firefighting area — is the primary identified contamination source. A PFAS Preliminary Assessment and Site Inspection completed in 2020 identified 12 Areas of Potential Impact across the installation largely associated with that AFFF use. The site is enrolled in Washington's Standard Cleanup program and currently awaits active remediation; no cleanup work at this area of concern has commenced. That history could support an insurance cost recovery claim against carriers who issued insurance policies 40+ years ago.

Former Use
Former PFAS
AddressJoint Base Lewis-Mcchord, Pierce County
Historical UsePFAS
Est. Operating SincePre-1986
StatusAwaiting Cleanup
Contamination & Investigation
Site Assessment Summary
ContaminantsPer- and polyfluoroalkyl substances (PFAS) from Aqueous Film-Forming Foam (AFFF) at multiple fire training areas
Media ImpactedSoil, Groundwater
Regulatory ProgramMTCA — Standard Cleanup
Ecology Site #13021

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.

AFFF was the standard fire suppression agent at U.S. military installations for decades prior to 1986 — the same period when occurrence-based Commercial General Liability policies lacked effective pollution exclusions and were routinely issued to government contractors and facility operators. The PFAS contamination at JBLM AOC9-2 is tied directly to those pre-1986 fire training operations, and the 2020 PA/SI represents only the opening phase of what PFAS remediation projects consistently require: years of investigation, design, and active cleanup expenditures. Historical carriers whose CGL policies covered base operations or associated contractors during that pre-1986 window may be obligated to fund the substantial costs that lie ahead.

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

Task 1 — Research and Analysis
Restorical searches for viable historical insurance policies, researches the site history, analyzes the contamination impacts, and underwrites potential coverage — including a proprietary trigger analysis. At the end of Task 1, we provide a clear yes or no on whether a successful cost recovery is possible, along with a strategy and recommendation specific to your situation, even if you are not the policyholder.
Task 2 — Coverage and Funding
When Task 1 confirms viable coverage, Restorical works with your legal counsel to tender the claim, negotiate and secure insurance coverage. Restorical will manage the ongoing claim process, including accounting to ensure the insurance companies are funding your remediation in a timely manner.

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This analysis is preliminary and based on publicly available records. Restorical Research is not a law firm and does not provide legal advice.