In the wake of a pipeline release, beyond notifying all required federal and state government agencies, an operator should keep in mind another important notification—its insurer.  Most insurance policies contain mandatory conditions, including notice of claims and cooperation with the insurer.  Failure to comply with these conditions may result in a denial of coverage.  The

The issuance of a Corrective Action Order (CAO) can have significant and ongoing consequences for a pipeline operator.  A powerful enforcement tool typically associated with the shutdown of a pipeline facility, a CAO often means numerous compliance obligations and significant disruption of normal operations, not to mention the stigma accompanying a CAO’s pre-requisite finding that continued operation of a pipeline facility would be “hazardous to life, property, or the environment.”  49 U.S.C. 60112(a)(1).
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