Abstract in English:
As a result of the gas discoveries, the State of Israel has recognized the connection of offshore drilling to the shore as a national infrastructure project, and therefore, the need to implement a National Master Plan (NOP) on the subject was raised. The main conclusions of NOP 37/H “Receiving and Treatment of Natural Gas – from the Offshore Discovery to a National Transmission System” (2014) is the designation of two areas, a northern and a southern one, each of which extends to both the marine polygon and land territories. In addition, the NOP states that the construction of facilities is dependent on, among other things, the preparation of an Environmental Management and Monitoring Plan that is a condition for issuing the building permit.
The development of natural gas discoveries requires treatment facilities, for, among other things, drying and separating liquids and condensates from the natural gas as a precondition for commencing its discharge into the transmission system. Gas treatment carries with it safety, health, and environmental risks, which should be carefully considered. In Israel, there are also security threats to infrastructure facilities, including gas treatment facilities, which are part of the overall considerations for the location of these facilities. In accordance with NOP 37/H, the state approved the Leviathan reservoir development plan of Noble Energy in February 2016. More than a year and a half later, when Noble Energy had already invested more than $1.5 billion in the project, in accordance with government decision 476 which required such a deposit, a public debate arose as to whether the treatment facility’s location approved by the State in the northern Polygon of NOP 37/H was the correct location or whether it should be moved to a floating platform above the Leviathan gas field.
The decision on the location of the treatment facility involves various considerations, including the characteristics of the reservoir, the operation, production and installation of the rig, reliability, safety and health, and environmental, economic, security and other considerations. According to the NOP, it was considered appropriate to locate the treatment facility on land, together with a small platform near the shore for reducing the gas pressure before it comes on land; however, this alternative was disqualified because of the strong opposition of the residents in the area (mainly Zichron Yaakov and Hof HaCarmel). Following this opposition and court discussions, the regulations of NOP 37/H were amended and it was determined that preference would be given to maximum treatment of the gas at sea.
In accordance with the decision of the High Court of Justice and the approved NOP 37/H (2015), the construction of a permanent barge for the treatment of natural gas from the Leviathan field was approved, located opposite Dor Beach at a distance of approximately 10 km from the shore. This alternative was discussed in all planning forums and all the necessary approvals were obtained. However, it should be noted that the alternative of a floating barge above the wellhead was not discussed at all in the framework of NOP 37/H and was rejected out of hand on the grounds that solutions located outside Israel’s territorial waters should not be discussed. The construction of the platform is in its advanced stages and pipes are already being deployed from the rig’s location at sea to the shore.
Nonetheless, public opposition persists, arguing that the current development outline is unique in the world and dangerous. It is claimed that the platform will cause air pollution that will reach the shore, as well as sea pollution, especially in the case of a possible malfunction, which could cause irreversible damage. The opponents demand that the development plan be changed to a floating platform on the wellhead at a distance of 120 km from the shoreline. The position of the government offices is that the location of the Leviathan rig cannot be changed and any postponement of the field development will delay for an unknown period the time of the start of the Leviathan gas flow, and in effect lead to the project being cancelled. The Ministry of Energy claims, furthermore, that if the project is delayed, the immediate result will be the continued operation of the coal power plants in Hadera and the continued resulting harm to public health. On the other hand, the opponents claim that the Leviathan project has signed only a few contracts for supplying gas in Israel (less than 10% of the expected gas consumption in 2020) and most of the gas is intended for export, so it is not to be “blamed” for resorting to a return to using coal. In addition, the Karish and Tanin reservoirs are supposed to supply gas as early as 2020, and it is possible to import gas through the Hadera gas terminal, so that the planned transition from coal to gas in 2022 can be realized without delays. In this context, the Ministry of Energy explains that the Tanin and Karish reservoirs will not be operational before the second quarter of 2021, and that, in terms of energy redundancy, power stations cannot be converted to gas while the State of Israel depends on only two gas reservoirs. The actions taken by government ministries to reduce the use of polluting fuels and coal will lead to a huge dependence on natural gas.
When considering the environmental impact, it is not enough to relate specifically to Leviathan, but to see the broad picture. All the neighboring countries, that is, Egypt, Cyprus, and Lebanon, are about to develop gas fields, and it is important to understand the region as a whole. The simulations presented show the possible impact of foreign gas fields on Israel.
It should be noted that the distancing of the gas treatment to the wellhead is not a magic solution that will make the potential damage disappear. This alternative also poses the danger of condensate leakage, and it will be even greater because of the need to store the condensate in quantities of hundreds of thousands of barrels as compared to only 2,000 barrels, which would be stored in the permanent rig, because it cannot be discharged to shore. A leak from the wellhead area would endanger a larger area, including Lebanon and Cyprus. On the other hand, the opponents claim that a leak from a coastal rig will reach the shore in a short period of time that will not allow treatment within hours, while a leak from a floating remote rig will allow a response time of about 10 days and treatment to prevent the contamination from reaching coastal areas and the locations of the majority of the marine life, that is, the continental shelf.
The discussion focused on the actions that must be taken to ensure that maximum steps are taken to reduce the risk of harm to the environment and public health, and to improve the level of supervision and control over the establishment and operation of the platform.
Recommendations proposed for minimizing the impacts of production the rig at sea:
Construction and maintenance
- It is recommended that the emission permits be based on more stringent conditions, such that the developer will be required to install the best available technologies (BAT) to control and minimize emissions at the base and land installations.
- The implementation of global industry standards should be required to promote environmental and safety management systems on the platform and at the ground facilities. An engineering specification of the implementation of these standards should be required.
- The contractor should perform improved planning and allocate resources (manpower and budget) for preventive maintenance, in order to reduce equipment leaks and to respond to emergency events and ensure the safety of the current operation of the platform and land facilities.
Monitoring and reporting
- Monitoring systems should be established as soon as possible in the vicinity of the residents in the area, including those for monitoring organic materials. The urgency of the construction stems from the need to collect background data before the platform begins to operate.
- A good estimate of emissions and discharges, focal and non-focal, from all sources in the platform should be conducted. This assessment should be performed by independent organizations.
- Accurate reporting and continuous monitoring of air pollution, discharge into the sea, and flora and fauna around the rig, and their publication to the public, must be ensured to warrant compliance with the emission permit requirements.
Enforcement
- The activity must be supervised by an extreme model of strict and meticulous supervision and strict enforcement that currently does not exist.
- Regulations should be significantly strengthened, including the engagement of excellent professionals and the allocation of appropriate budgets.
Insurance
- Insurance of the rigs, drilling, and piping should be required to cover environmental damage, so that, in the case of failure, the cost will not fall on the citizens and the state.
Planning
- A detailed characterization of the inland sites specified in NOP 37/H should be conducted. The characterization should include possible functions and adjustment of the size of the required area according to future functions, since, according to the known requirements, small areas are sufficient for gas reception sites, smaller than those allocated in the NOP.
