1 IN THE HIGH COURT OF JUSTICE CLAIM NO ... - Platform

suggesting that the incidents that occurred in thesecommunities were more severe than those that affected theother communities.23.3.3 In two thirds of the contaminated land sites close to oilindustry facilities the soil contamination exceeded Nigeriannational standards.23.3.4 In 41 sites the hydrocarbon levels in the groundwater were inexcess of international standards.23.3.5 Hydrocarbon contamination was found in water taken from28 wells at 10 communities adjacent to contaminated sites. 7wells showed 1,000 times higher concentrations thanpermitted under Nigerian drinking water standards.Clean Up and Remediation24. The Claimant avers that following the eventual inspections and clamping of theoil spills by the Defendant, no clean up or remediation has been undertaken bythe Defendant to restore the impacted creeks, waterways and land to their prespillstate or to the condition as required by Nigerian law.25. After both oil spills had been capped, the Ministry of the Environment of RiversState wrote to the Defendant on 15 January 2009 and 11 February 2009requesting a meeting to take place between the Claimant and the Defendant withregard to the said oil spills. 3 The Defendant failed to respond to the said letters.26. The National Oil Spill Detection and Response Agency (“NOSDRA”), anagency of the Federal Government of Nigeria, conducted an investigation intothe causes of the said oil spills in 2009. The Defendant failed to respond to the3 Annex 211