Industrial & Manufacturing cleanup site — Restorical Research
ATI Millersburg Operations
Linn County
Restorical Research
Preliminary Site-Specific Analysis

This property has a documented history as an industrial and manufacturing facility going back to 1960. Historical insurance policies issued during operations at this property and through 1986 could help fund the ongoing and future cleanup under Oregon DEQ oversight.

This industrial property has been in continuous operation since at least the early 1960s under Teledyne Wah Chang and successor ATI, with wastewater sludges disposed in seven unlined storage ponds adjacent to the Willamette River prior to 1980 and radium-contaminated sludge spread across a 50-acre field before 1976. The site was added to the National Priorities List in December 1982, and extensive groundwater contamination — including VOCs, metals, and radionuclides — led to the installation of multiple pump-and-treat systems that have operated continuously since 2000. EPA enforcement actions span decades, from the 1987 Consent Order through a 1996 Consent Decree, and a groundwater use restriction easement recorded in February 2024 confirms that contamination persists; no No Further Action determination has been issued for the groundwater operable unit. That history could support an insurance coverage claim against the carriers who issued policies more than 40 years ago — coverage that could help fund the cleanup ahead.

Former Use
Former Industrial & Manufacturing
LocationLinn County
Historical UseIndustrial & Manufacturing
Est. Operating Since1960
Project StatusAssigned
Contamination & Investigation
Site Assessment Summary
ContaminantsVOCs, heavy metals, radionuclides, and chlorinated solvents in soil, groundwater, and sediment
Regulatory ProgramOregon DEQ — Cleanup Program / VCP
DEQ ECSI #0315

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 Oregon — and those policies may provide coverage that remains enforceable today. 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 contamination at this property originated from industrial operations beginning in the early 1960s — including disposal of wastewater sludges in unlined ponds before 1980 and spreading of radium-contaminated sludge before 1976 — more than two decades before 1986. The ongoing pump-and-treat systems, continued regulatory oversight in Oregon, and unresolved groundwater remediation confirmed by use restrictions recorded as recently as 2024 represent substantial costs this property still faces, and pre-1986 carriers whose policies were in effect during those early decades of operation may be obligated to fund that work 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

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 viable insurance coverage exists to fund the cleanup, 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.