Industrial & Manufacturing cleanup site — Restorical Research
JBLM SS-34N
Tacoma, Pierce County
Restorical Research
Preliminary Site-Specific Analysis

This property has a documented history as a industrial and manufacturing facility predating 1986. Historical insurance policies issued during operations at this property and through 1986 could fund a cleanup — and recover costs already spent.

JBLM SS-34N occupies a light industrial use area within Joint Base Lewis-McChord, an active military installation located approximately seven miles south of downtown Tacoma. Trichloroethene (TCE) is the primary contaminant of concern, and by 1985 contamination from past on-base operations was already the subject of a formal Installation Restoration Program Phase II investigation. Primary remediation has centered on multi-phase in-situ chemical oxidation — sodium and potassium permanganate injections into groundwater since 2002 — supplemented by a pump-and-treat system for investigation-derived wastewater; compliance monitoring and remedial-action operations have been documented in annual reports from 2005 through 2019. That history could support an insurance cost recovery claim against carriers who issued insurance policies 40+ years ago.

Former Use
Former Industrial & Manufacturing
AddressTacoma, Pierce County
Historical UseIndustrial & Manufacturing
Est. Operating SincePre-1986
StatusCleanup Complete — Active O&M/Monitoring
Contamination & Investigation
Site Assessment Summary
ContaminantsTrichloroethylene (TCE) detected in groundwater
Media ImpactedSoil, Groundwater, Air
Regulatory ProgramMTCA — Standard Cleanup
Ecology Site #13019

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 TCE contamination at SS-34N traces to light industrial operations conducted on the base well before 1986, the threshold year before which occurrence-based Commercial General Liability policies lacked effective pollution exclusions. A 1985 DoD Installation Restoration Program Phase II report confirms that the contamination was already recognized as a legacy problem prior to that cutoff. The documented remediation costs — years of chemical oxidation injections, pump-and-treat operations, and nearly two decades of annual compliance monitoring — represent substantial expenditures tied directly to pre-1986 operations, creating a plausible claim on the historical CGL policies that covered the installation during that period.

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.