ponds started migrating through the soil to underlying groundwater almost immediately after beginning pond operation in 1960.” Accordingly, the district court correctly concluded as a matter of law that property damage occurred upon initial exposure in 1960, and should have concluded as a matter of law that property damage occurred in each policy period from 1961-70. [Id. at 995-96 (citations omittedXemphasis added).] The court rejected the insurers’ argument that the insured had failed to demonstrate “actual injury” during the relevant policy periods and held that “[u]nder the continuous trigger theory, proof of actual injury in the sense of manifestation of injury is not required.” Ibid. See also Armotek Indus., Inc. v. Employers Ins. of Wausau, 952 F.2d 756, 763 (3d Cir.1991)(<HOLDING>). In Wisconsin Electric Power Co. v. California
holding that  exposure and manifestation occurred at the time of the damage causing oil spill holding that termite damage does not fall within the meaning of property damage in the policy because the alleged misrepresentations did not cause the damage the termites did holding that canadian citizens have standing to intervene in nepa based suit against agency on the basis of citizenss claims that possible oil spill from transalaskan oil pipeline might cause damage to canada holding that a similar exclusion denies coverage for property damage to the particular part of the real property that is the subject of the insureds work at the time of the damage if the damage arises out of those operations holding that property damage occurred when homeowners noticed damage not when house was improperly constructed