Bulk Plant cleanup site — Restorical Research
Unocal Bulk Plant 0321
Kelso, Cowlitz County
Restorical Research
Preliminary Site-Specific Analysis

This property has a documented history as a bulk fuel distribution terminal going back to 1929. Historical insurance policies issued during those prior operations and through 1986 could recover the cleanup costs already paid.

This property was purchased by Union Oil of California in 1929 and operated continuously as a bulk fuel plant for six decades, with above-ground storage tanks, product transfer lines, loading racks, and an underground containment tank in service until 1989. All bulk plant infrastructure was removed in 1992, after which investigation confirmed petroleum-impacted soil and groundwater, including lead — a marker of historical leaded gasoline handling — across the property. Remediation under the Voluntary Cleanup Program included excavation and offsite disposal of 3,095 tons of petroleum-impacted soil in 2012, application of Oxygen Release Compound for in-situ bioremediation at the groundwater interface, and multi-year groundwater monitoring from 1993 through 2008, with new monitoring wells installed in 2013. The site has since received No Further Action status. That history could support an insurance cost recovery claim against carriers who issued insurance policies 40+ years ago.

Former Use
Former Bulk Plant
AddressKelso, Cowlitz County
Historical UseBulk Plant
Est. Operating Since1929
StatusNo Further Action
Contamination & Investigation
Site Assessment Summary
ContaminantsPetroleum hydrocarbons and lead detected in soil and groundwater
Media ImpactedSoil, Groundwater, Air
Regulatory ProgramMTCA — Voluntary Cleanup Program
Ecology Site #3788

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.

Union Oil's bulk fuel operations at this site began in 1929 and ran for more than fifty years before 1986, the period during which occurrence-based Commercial General Liability policies were the prevailing industry form and carried no effective pollution exclusion in Washington. The presence of lead in soil samples confirms that contamination originated from leaded gasoline handled here well before that threshold year. The documented remediation costs — excavation of over 3,000 tons of impacted soil, in-situ groundwater treatment, and fifteen-plus years of monitoring — represent expenditures directly traceable to that pre-1986 operational history, which historical carriers may be obligated to recover.

Restorical's role is to locate viable historical policies, determine whether a successful cost recovery claim is possible, and assist our clients and their legal counsel to obtain insurance coverage for costs already incurred. Restorical's forensic accounting team works to re-establish and document past cleanup expenditures, ensuring the strongest possible basis for recovery.

Recovering Costs from an Older Cleanup

If this site reached No Further Action years ago, the original cleanup expenditures may be difficult to reconstruct. Restorical's forensic accounting team specializes in re-establishing and documenting past cleanup costs — even decades later — to build the strongest possible basis for an insurance recovery claim.

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 — Cost Recovery
When Task 1 confirms viable coverage, Restorical works with your legal counsel to tender the claim and negotiate recovery of costs already incurred. Restorical's forensic accounting team re-establishes and documents past cleanup expenditures, managing the claim process to ensure the insurance companies fulfill their obligation 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.