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Karen Kaika August 7, 1996 Page 6 Cal.App,3d 1320. See also Prudential-LME Commercial Ins. Co. v. Reliance Ins. Co. (1994) 22 Cal.App.4th 1508 (criticizing ACL Technologies for not considering drafting history)_ In Iight of Montrose, we submit that a strong argument can now be made to distinguish the Shell line of cases construing the pollution exclusion. The refusal of these courts to consider the drafting history of the pollution exclusion is plainly inconsistent with the California Supreme Court's decision in o se.' in conclusion, Royal's drafting history may reveal that "sudden and accidental" was inserted to mean unexpected and unintended; two elements that we have demonstrated here. Additionally, even if there were one or more noncovered causes of the contamination, there should be no application of the pollution exclusions here by virtue of the doctrine of concurrent causation. In State Farm Mutual Auto Ins. Co. v. Partridge (1973) 10 Cal.3d 94, 102, the California Supreme Court held that where injury or damage results fxom two concurrent causes, one covered by an insurance policy and one excluded, the policy must afford coverage. At TFS, there may be both covered and noncovered causes of the contamination such as both sudden and accidental and a non-sudden release, and the contamination may be indivisible (allocation to particular causes is not feasible). Therefore, the pollution exclusion would not bar coverage. There are myriad causes for UST releases, any of which may have been at play here. USTs' releases are caused by corrosion in some cases. 52 Ted. Reg. 12, 666 (1987). A variety of factors, including soil conditions, groundwater location, and tank or piping characteristics affect the rate and extent of corrosion damage to a UST. Corrosion occurs when hard, manufactured metal breaks down into its natural form as a soft ore. Installation failure is also cited as a cause for leaking USTs. The Environmental Protection Agency ("EPA") has estimated that about 25% of releases The refusal to consider extrinsic evidence is also inconsistent with California Civil Code § 1647, which provides that "[a] contract may be explained by reference to the circumstances under which it was made" and the California Supreme Court's decisions regarding the Parol Evidence Rule. These decisions bold that a court may consider extrinsic evidence to determine whether a contract term is ambiguous. See Pacific Gas & Electric Co. v. G.W. Thomas Drayage & Rigging Co., Inc. (1968) 69 Cal.2d 33, 37-40. rr . i r-. ur^.nrru n 11nnau IFUT��TM ". .or CC )Ll �lf1H