BLOWOUT ENDORSEMENT SUPERSEDES POLLUTION EXCLUSION AND MOLD EXCLUSION

The Corpus Christi court held in Century Surety Co. v. John DeLoach d/b/a DeLoach Vacuum Service and DeLouach Oil & Gas Waste Well, that the Blowout Endorsement expands coverage rather than limits existing coverage. The court noted that the express language in the endorsement indicated that the purpose of the endorsement was to add coverage for a blowout and cratering hazard. The court then concluded that as no occurrence covered under the Blowout Endorsement could arise in the absence of pollution, there is a conflict between the Pollution Exclusion and the endorsement. Therefore, the Blowout Endorsement supersedes the Pollution Exclusion. The court also concluded that application of the Mold Exclusion would render the Blowout Endorsement meaningless, and thus, the Blowout Endorsement also supersedes the Mold Exclusion.