In Its briefs dated September 15 And November E, 19E5, N.O.C. did not Invoke as being a withdrawal, any action from SDN-OIL In ceasing performance before the Request for Arbitration was filed, other than the “force mejeure” excuse. Its argumentation was different. N.O.C. considered that, assuming that SUN-OIL had not withdrawn from the EPS* In 1962, there would be withdrawal If SUM-OIL does not resume, or does not show that it intends to resume, the Exploration Operations in spite of the Arbitral Tribunal's award regarding the Invalidity of the force majeure excuses. In such case, SUN-OIL would have to pay N.O.C. the costs of the uncompleted portion of the Exploration Program, as provided under Art. 3.4. of the EPSA.