Environmental impact assessments carried out for the Leviathan natural gas platform by Noble Energy Mediterranean Ltd. “grossly underestimate” the quantity of emissions that will pollute Israel’s air, contain “a series of flaws,” rely on “overly simplistic” models and should be redone more professionally, an independent scientific study has found.

The work was published Saturday by the prestigious, peer-reviewed Environmental Impact Assessment Review.

It backs the demands of citizens’ groups, local authorities and environmental NGOs to re-evaluate the location of the platform — currently under construction and due to start operating by the end of this year — just 9.7 kilometers (6 miles) north of the coastal town of Caesarea, close to densely populated areas of the country, and to weigh moving it further out toward the production wells 120 kilometers (75 miles) offshore.

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The Environmental Protection Ministry’s former chief scientist said the findings were “very disturbing” and charged that “public trust is being compromised once again.”

Yoni Sappir, chairman of Home Guardians, a citizens’ group that has been campaigning to have the gas platform moved further out to sea, said Noble Energy had provided neither the government nor the public with any technical specifications relating to a system it had promised to install to reduce emissions by 99 percent. He also accused the government of failing in its duty to insist on receiving such critical information.

“This turns us all into guinea pigs for the first system of its kind in the world, for which there is no proof and no accumulated knowledge about its effectiveness,” Sappir said.

“The Israeli regulator must not bury its head in the sand and give this disastrous project a license to harm the public’s health, state assets and the marine environment.”

Publication of the study comes just a couple of weeks after Israel’s Environmental Protection Ministry published its own annual environmental emissions inventory, which was based on reports from the polluting factories and industries themselves.

The ministry provided figures showing impressive reductions in air pollution, including drops in emissions of 10% to 45% reported by companies in the Haifa Bay, where much of the country’s heavy industry is based.

Those figures appeared to be at odds with a stinging report from the state comptroller published in June, which said that there was little to no difference in Haifa’s air quality in the last four years, and that residents of Israel’s third-largest city and the surrounding metropolitan area — about 900,000 people — were being exposed to carcinogenic pollutants just as much as when a national plan was developed and accepted by the Environmental Protection Ministry in 2015.

The ministry report also revealed that Noble Energy’s active Tamar natural gas platform remained by far the most polluting facility in Israel, emitting more than 50% of the country’s carcinogenic benzene between 2013 and 2018.

Report exposes ‘limited critical ability’ of environment ministry

Sinaia Netanyahu, the former chief scientist at the Environmental Protection Ministry, whose post has not been filled since her departure some 18 months ago, told The Times of Israel that the new study’s findings were “very disturbing.”

They reflected the “insufficient and inadequate professional capacity within the Ministry of Environmental Protection,” she said, and exposed its “limited internal ability to create original knowledge and to examine in a critical way the Environmental Impact Assessments (EIAs) submitted by certain industries.”

The study also revealed the lack of “capacity and/or ability and/or intention of the gas partners to provide the government with accurate information.”

She added, “Regardless of the reason, public trust is being compromised once again.

“The State of Israel has decided to rely on natural gas for 80% of the country’s electricity production, at least up to 2030 and probably much beyond,” she continued. “Therefore, it would be advisable to hire well-trained and experienced professionals, perhaps from abroad, as well as to follow in the footsteps of the Bureau of Ocean Energy Management (BOEM) of the the US Department of Interior.”

In 2015, the bureau signed a contract with the National Academies of Sciences, Engineering and Medicine to establish a National Academies​ Committee on Offshore Science and Assessment, which, according to its website, provides “independent, scientifically credible and objective information on issues relevant to BOEM’s environmental studies and assessment activities and supports discussions on relevant issues.”

Noble Energy: A ‘series of flaws’

Texas-based Noble Energy and its partners in Leviathan — including Delek Drilling LP, a unit of the Delek Group, and Ratio — have been operating the Tamar rig since 2013. They discovered the much larger Leviathan gas field — one of the biggest of its kind in the world — in 2010.

Noble Energy initially planned to locate processing for the Leviathan field near the wells on an FPSO (Floating, Production, Storage and Offloading), a large floating vessel.

But in 2016, the government decided — for reasons that have never been made clear — to locate the platform just off the popular Dor Beach, where it is currently being built. The Energy Ministry told The Times of Israel last year that the location was chosen “after many tests, an environmental impact assessment and the considerations of the security establishment.”

The new scientific research — carried out by David Broday (of Haifa Technion’s Faculty of Civil and Environmental Engineering), Uri Dayan (Geography Department, Hebrew University, Jerusalem), Einat Aharonov (Institute of Earth Sciences, Hebrew University, Jerusalem), physicist Mike Adel and data analyst Dror Laufer (both connected with Home Guardians) — found a “series of flaws” in the Environmental Impact Assessment that Noble Energy was required to produce as part of its 2010 request for a building permit for the Leviathan platform.

The researchers compared the company’s predicted emissions of NMVOCs — volatile organic compounds excluding methane but including carcinogenic benzene — for both the Tamar processing platform and the Leviathan rig with actual emissions from one Mediterranean, 24 UK, 17 Norwegian and two Gulf of Mexico platforms, some producing oil, some gas, and some a combination of both. They also used industry benchmarks in the comparison.

Noble Energy predicted 30 tons of NMVOC emissions annually from the Leviathan platform, which the academics found to be “unrealistic.”

Said the study, “Based on a comprehensive review of over 40 existing large oil and gas processing platforms worldwide, not a single platform that is processing at least ten oeBCM/yr (oil equivalent billion cubic metres of natural gas a year) has annual NMVOC emission below 600 tons, as suggested for Leviathan.” (Oil equivalent is a standardized measurement for oil, gas, or a combination of the two). By comparison, Leviathan is set to produce 12 oeBCM/yr, increasing gradually to a total of 20 oeBCM/yr.

The report revealed that in December, the Environmental Protection Ministry itself rejected a request from Noble Energy for an operations permit for Leviathan because an independent expert had pinpointed six times the sources for potential emissions than Noble Energy had cited in its submission.

Noble Energy’s EIA was based on regular, uniform emissions, the researchers found, and failed to address unusually large emissions either in situations such as pressure buildups in gas storage containers or when things go wrong.

This failure “hides” possibly greater risks to the exposed population than might be assumed for the data presented, the researchers found.

The company’s predictions for the Leviathan platform were that 99% of all gases would be neutralized by the rig’s flare, and that only 1% would be released into the atmosphere.

But, given weather and wind conditions near the flare, this was also “unrealistic,” because it failed to consider periods when the flare was inactive due to factors such as ignition failure or scheduled maintenance.

Furthermore, a 2017 report from the US Bureau of Safety and Environmental Enforcement (BSEE) for wells on the outer continental shelf of the Gulf of Mexico found that between 28% and 41% of emissions were flared over the years 2011 to 2015, with the remainder released into the atmosphere.

Beyond Noble Energy’s predictions of improbably low pollutant emissions, “their fate in the atmosphere was modeled incorrectly,” the scientists also discovered.

The company had failed to take into account increased pollution concentrations downwind from the rig as well as a winter phenomenon called cold pooling, which could see pollutants accumulating in the low-lying areas of the Sharon-Carmel plain, facing the Leviathan platform, the report said.

Citing their key findings as “alarming,” given the close proximity of the Leviathan processing platform to the densely populated coastline, the researchers concluded that there are grounds for completely reassessing the environmental and health risks associated with the current plan and reevaluating the “rather enigmatic” government decision to construct the platform so close to the Israeli shoreline rather than near the actual gas well out at sea.

“A new EIA should be done, relying on reliable and conservative scenarios, using a realistic flare efficiency, intermittent large emissions, and comprehensive wind field data,” the researchers said.

Noble energy underestimated Tamar rig’s emissions

The Tamar rig stands 23 kilometers (14 miles) offshore, close to the southern city of Ashkelon. Its wells, like those of Leviathan, are 120 kilometers away in the deep sea.

In 2012, Noble Energy submitted data as part of an EIA predicting annual NMVOC emissions from Tamar at 38 tons — some 30 times lower than the actual emissions of 1,160 tons recorded in 2016 and published by the Environmental Protection Ministry in 2017.

According to the ministry, actual emissions from Tamar in 2016 that were “known or suspected to be carcinogenic” equaled the total of such emissions from 570 large industrial plants across the country, including the Haifa oil refineries.

That situation has apparently not yet been remedied, despite an Environmental Protection Ministry claim to the contrary (see below). Noble Energy has said that a flare on the Tamar platform will not be operational before the end of 2021.

The company’s response appears at the bottom of this article.

In fact, according to the latest environmental emissions inventory, the Tamar platform remains by far the most polluting facility in Israel, emitting more than 50% of the country’s carcinogenic benzene between 2013 and 2018 and a staggering 20,000 tons of methane, whose effect as a greenhouse gas is equivalent to 600,000 tons of carbon dioxide — and that is a conservative estimate. Methane emissions should also be prevented by a flare.

Mike Adel, one of the researchers who worked on the new study, told The Times of Israel, “How Noble Energy was allowed by its own executive to build such a massive gas processing facility in 2013 without any operational flare is a question that remains open and is a strong indication of the absence of any environmental corporate governance whatsoever.”

Ministry insists: Leviathan emissions won’t exceed 1%

The Environmental Protection Ministry said in a statement — received before the publication Saturday of the scientists’ report — that the Tamar platform was located outside of Israel’s territorial waters and built without any environmental conditions because of “legal complications pertaining to the ministry’s authority” at the time.

Following a legal opinion from the deputy attorney general, which found that the Clean Air Act did apply in territorial waters, the ministry began to deal with emissions and enforce the law on the Tamar rig.

Following its demands to reduce emissions, Noble Energy had installed systems to absorb and burn gases and to create energy, the statement went on.

“This system has reduced gas emissions by 99%.”

A draft emissions permit for Tamar had been published for members of the public to comment and an open meeting had been held to discuss selected concerns. These were currently being considered by the ministry official in charge, the statement said.

Regarding the Leviathan platform, the statement said that the ministry had demanded stringent emissions controls from the platform’s planning stage and had included them in the draft emissions permit “to ensure that operations will not impact the quality of air along the coastline.” Analyses carried out by the ministry under different conditions showed that less than 1% of emissions would be released into the air, the statement said.

Noble Energy responds

The following statement from Noble Energy is printed in full:

“The Homeland Guardian’s ‘review’ which you cite as the basis for your column is based on false assumptions most of which are not relevant to Noble Energy’s current operations in Israel. For example, the flawed report assumes that the Leviathan Production Platform operates under the same operating system as the Tamar Platform and therefore will have similar emissions. This is patently false as has been explained to representatives of the Homeland Guardians on several occasions in multiple forums. Furthermore, as has been widely published, even in Tamar — which has undergone a $36 million upgrade— BTEX emissions [benzene, toluene, ethylbenzene and xylene] have been reduced by more than 99 percent below the emissions levels originally reported. All of this should have been clear to Science Direct and their publisher had they performed a cursory review of the facts. That they didn’t do so shouldn’t excuse this website from performing a basic fact check.

“This is just the latest, in a string of failed attempts, by those seeking to delay the benefits of this world-class project for the people of Israel and the region. Fortunately, the Leviathan project remains on schedule for first gas production before the end of the year. With the flow of natural gas from Leviathan, Israel is poised to enjoy cleaner and healthier air as the use of polluting coal is reduced, increased government revenues to be invested in education, health care and infrastructure and improved ties with countries in the region through exports. It is disturbing that there remains a small (although shrinking) group who remain committed to scaring the public through false reports that don’t even contain a patina of scholarly rigor. It is sad that the Times of Israel has allowed itself, time and again, to be used in this failed effort.”