This property has a documented history as a farm and agricultural operation predating 1986. Historical insurance policies issued during those prior operations and through 1986 could recover the cleanup costs already paid.
The Frey Property operated as the Warren Frey Dairy farm, a Farmers Home Administration property in Onalaska, with a 500–700-gallon steel gasoline underground storage tank serving the agricultural operation. The UST was unregistered and nonregulated under Washington's tank registration framework, and its permanent closure — including tank removal — was completed in May 1993. Subsequent investigation confirmed lead, benzene, and petroleum hydrocarbons in groundwater; Ecology issued a No Further Action determination in 2017. The property has since been subdivided into residential parcels. 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.
The steel gasoline UST on this dairy farm predated Washington's late-1980s underground storage tank registration requirements, and the circumstantial record — an unregistered agricultural tank on a long-standing FmHA property, removed in 1993 — is consistent with installation well before 1986. Occurrence-based CGL policies in effect during that pre-1986 operational window carried no effective pollution exclusion in Washington. The documented remediation expenditures — tank removal, site investigation, groundwater monitoring through to the 2017 No Further Action determination — represent cleanup costs that historical carriers who insured the dairy operation may still be obligated to cover.
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
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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.