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.
Naval Base Kitsap - Manchester has operated as a military fuel depot since the early 1940s, with a Firefighter Training Area active from 1942 through 1967 during which Aqueous Film-Forming Foam (AFFF) was used and stored at Building 12. A site inspection evaluated 11 areas across the installation and identified 8 as potential or confirmed PFAS release areas, with the Former Firefighter Training Area and AFFF drum storage confirmed as the primary release sources. Investigation-derived soil cuttings (34 drums) and aqueous waste (2,530 gallons) have been collected and disposed of offsite, and while several discrete sites — including Tank 50 and Sites 302, 303, and 304 — have reached no-further-action status, active PFAS cleanup has not yet commenced. 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.
AFFF use and storage at this installation began in 1942 — more than four decades before 1986, when occurrence-based Commercial General Liability policies had no effective pollution exclusion and routinely covered releases from firefighting and fuel-handling operations. The PFAS contamination now confirmed across eight areas of the base traces directly to those pre-1986 training activities. Historical carriers whose policies were in force during the Firefighter Training Area's 1942–1967 operational window may still be obligated to fund the investigation and remediation costs the property now faces.
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.


