Bulk Plant cleanup site — Restorical Research
US Navy FISC Manchester PCB Site 302
Manchester, Kitsap County
Restorical Research
Preliminary Site-Specific Analysis

This property has a documented history as a bulk fuel distribution terminal going back to 1955. Historical insurance policies issued during those prior operations and through 1986 could recover the cleanup costs already paid.

This property served as an active disposal area for ship bilge waste and transformer oil within the US Navy's Naval Supply Center at Manchester, Washington, with disposal operations running from 1955 through the mid-1970s, when an oily waste treatment plant was constructed to replace the practice. Jet fuel tank cleaning operations also took place on-site during the mid- to late-1960s. A Remedial Investigation/Feasibility Study evaluated multiple cleanup alternatives — soil excavation, on-site stabilization and incineration, impervious containment covers, water collection and treatment systems, and institutional controls — with estimated present-worth costs reaching up to $1.3 million. The site has since reached 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
AddressManchester, Kitsap County
Historical UseBulk Plant
Est. Operating Since1955
StatusNo Further Action
Contamination & Investigation
Site Assessment Summary
ContaminantsPolychlorinated biphenyls (PCBs) from transformer oil disposal and petroleum hydrocarbons (ship bilge waste, jet fuel) detected in soil and shallow water
Media ImpactedSoil, Groundwater, Surface Water
Regulatory ProgramMTCA — Standard Cleanup
Ecology Site #523

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.

PCB and petroleum contamination at this facility built up through roughly twenty continuous years of disposal — 1955 through the mid-1970s — each year generating a new occurrence under the CGL policies that Navy contractors and Supply Center operators carried throughout that period. Because those policies predate the 1986 pollution-exclusion era by a decade or more, every annual policy issued during that long disposal window is a potential source of coverage. The documented remediation cost trail — multi-alternative feasibility study, excavation and treatment options, long-term monitoring — represents liabilities that trace directly to that two-decade operational history and may still be recoverable from the carriers who insured it.

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.