Bulk Plant cleanup site — Restorical Research
JBLM Fuel Vault 1and 2 BLDG 1197
update, Pierce County
Restorical Research
Preliminary Site-Specific Analysis

This property has a documented history as a bulk fuel distribution terminal going back to 1970. Historical insurance policies issued during operations at this property and through 1986 could fund a cleanup.

This site is a petroleum bulk storage and distribution facility at Joint Base Lewis-McChord, consisting of concrete fuel vaults and fuel lines connecting underground tanks to McChord Air Field runways, originally constructed in the 1970s. The vaults — operated by the Defense Logistics Agency — contain pipes, valves, and gaskets from which jet fuel has migrated into the vault structures and the surrounding environment. A Phase II investigation has been completed, involving removal and disposal of hazardous soil and water (Investigation Derived Waste) and post-fieldwork site repair; Ecology has designated the site as contaminated and requiring remedial action under MTCA, and has recommended inspecting additional vaults. A multi-year cleanup effort is anticipated. That history could support an insurance cost recovery claim against carriers who issued insurance policies 40+ years ago.

Former Use
Former Bulk Plant
Addressupdate, Pierce County
Historical UseBulk Plant
Est. Operating Since1970
StatusAwaiting Cleanup
Contamination & Investigation
Site Assessment Summary
ContaminantsJet fuel (petroleum hydrocarbons) detected in soil and surrounding vault environment from leaking fuel lines, valves, and gaskets
Media ImpactedSoil, Groundwater
Regulatory ProgramMTCA — Standard Cleanup
Ecology Site #15472

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.

The jet fuel contamination at this site originated from fuel infrastructure built and placed into service in the 1970s — more than a decade before 1986, when occurrence-based Commercial General Liability policies still provided broad pollution coverage without effective exclusions. Releases from aging fuel lines, valves, and gaskets are precisely the type of slow, progressive contamination those pre-1986 policies were written to address. The remediation costs now facing this site — investigation-derived waste disposal, site repair, MTCA-mandated remedial action, and inspection of additional vault structures — could plausibly be funded by historical carriers whose policies were in force during the decades of operation prior to 1986.

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.