Environmental Damage Caused by Cebu Drilling Company

8/2/2019 Environmental Damage Caused by Cebu Drilling Company

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Environmental Damage Caused by

Cebu Drilling Company

July 24th, 2011


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Claim by EPC Munai

Between July 12th and July 16th Cebu Drilling Company

willfully and deliberately dumped an estimated 15-20 barrels

of contaminated waste oil in Block 8.

Between July 12th and July 16th Cebu Drilling Company

willfully and deliberately buried solid waste in three areas

adjacent to the drilling site for the Sholkara 10-1x.


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Specifics

Cebu tried to hide the contaminated waste oil and solids by

placing them in the old well sites for the Sholkara G-4, G-5,

and G-7 sites. EPC Munai has monitored these sites over the

last 4 years and I will attest personally that no oil was present

in the Shol G-5 area during my visits in 2007, 2008, & 2009.

Moreover, our ecological survey does not indicate thepresence of oil in the Shol G-5 area. No other operations have

taken place in this area and the company that prepared the

well site has too few vehicles to generate the amount of

waste oil found at the dump site.


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Evidence:

Tire marks which indicate the Cebu loader was used to transport the

waste oil to the dump site. The tread marks of the Cebu excavator are

identical to the tread marks at the dump site.

Teeth marks from the excavator match the teeth marks on the solid waste

sites.

Oil is very fresh waste oil and does not date from the ruptured tank, this

tank dates from 1979-1980 and any oil present would have already beenbio-degraded.

Oil is seeping into the ground leaving visible traces, when exposed fresh

earth was uncovered under the oil, indicating a surface spill as opposed to

a lateral seep.

Road is evident from the Shol 10-1x well site to the Shol G-5 dump site.

Contaminated waste oil is likely to have been from the four diesel

generators which were serviced prior to start-up.


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Risks for EPC Munai:

1. EPC Munai is required by the subsoil law to take on all Soviet era wells on

balance. This means that any ecological damage on Block 8 will be placed as theresponsibility of EPC Munai. Should an inspection take place, EPC Munai, not

Cebu will be held responsible for the recent dumping of oil.

2. If the oil fully seeps into the ground at the dump site, a future inspection may

consider this as a toxic site which will require a major expense to EPC Munai to

clean up.

3. The environmental authorities may also consider the oil as originating from the

Shol-5 well. Even though the leak is 15 meters from the well head the oil may be

considered as a griffen (leaking oil along a fault from outside the casing). If this

is the case EPC Munai may be required to pull the damaged casing and cement

the well, this may prove to be very costly to EPC Munai.

4. In the extreme case, the directors of EPC Munai may be charged with a crime and

subject to arrest, court trials, heavy fines, and deportation.


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Additional Information

Behind the Cebu Base Camp there is a large amount of recent trash,

including vodka bottles. When asked about this the Cebu representative

replied We did not do it, it was already here. When I pointed out that our

people visited the site 2 months ago he replied; Maybe somebody came

at night and dumped it?

When I asked the Cebu Manager about the waste oil he said the same thingwe were not here, someone else did it before we got here.When I pointed

out the tire marks were identical, he said you did not see us do it, you can

not prove we did it.

Summary: Both the dumping of waste oil and the large amount of alcoholpresent are in direct violations of the contract between EPC Munai and Cebu

Drilling Co.


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Rubbish and Trash Left by Cebu Behind Camp


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Vodka Bottles Left by Cebu Behind Camp


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Cebu

Excavator

Tooth marks

Note: Oil

soaked plant

indicating avery recent

dump of oil


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Cebu

ContaminatedOil Dump

Trying to hide

in Old Tank


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Waste Oil

Placed inside

tank


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Cebu Loader Tread marks at dump site in Shol G-4


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Cebu

Excavator

Tread marks

Note: Oil is on top of tread mark indicating it was after dumping


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Cebu

Excavator

Tread marks

at dump site

Note: Ground was wet from recent rains


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Cebu

Excavator

tooth marks

Cebu Loader

Tread marks


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Unstained oilislands

exposed as

oil seeps into

ground,

evidence of

dumping


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Cebu Loader

Tread marks

Sholkara G-5

& G-4 site

Solid waste

burial site


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Cebu Loader

Tread marks


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Cebu

Excavator

Tread marks

in Shol 10-1x


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Cebu

Excavator

Tread marks

in Shol 10-1x


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Cebu

Excavator

Tread marks


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Note: Fresh

soil line

indicatingtank has

been

recently

moved from

location


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Cebu

Excavator

Tread marks

Note: Fresh

soil line

indicating

tank hasbeen

recently

moved from

location

Puncture

mark from

Cebu Loader


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Recommended Actions

1. Collect samples of contaminated waste oil as soon

as feasible

2. Order Cebu Drilling to stay away from site of

criminal waste dumping3. Send environmental team to site as soon as

feasible to make independent assessment and

assign cleanup procedures4. Arrange meeting with Cebu Senior Management

soon as independent assessment is complete

Documents

Environmental Damage Caused by Cebu Drilling Company