Leviathan Project Review Apr23 2019
Leviathan Project Review Apr23 2019
Leviathan Project Review Apr23 2019
Homeland Guards
Box 4452
4 Ha-Shezif Street
30900 Zichron Yaacov
Israel
Prepared by:
Amnon Bar-Ilan, Shari Libicki
Ramboll US Corporation
7250 Redwood Blvd., Suite 105
Novato, California 94945
April 2019
1690010952
Contents
1.0 Introduction ....................................................................................................1
1.1 Leviathan Platform Overview ........................................................................ 1
1.2 Emissions Permit Review .............................................................................. 2
1.3 Ramboll Company Profile ............................................................................. 3
TABLES
Table 1. Summary comparison of LDAR requirements for TCEQ 28VHP and NSPS
Subpart OOOOa (VVa). ............................................................................. 8
Table 2. Summary of Leviathan platform annual emissions. ..................................... 11
Table 3. List of data reporting requirements by equipment type in GOADS................. 16
FIGURES
Figure 1. Cumulative distribution of annual NOx emissions for offshore platforms in the
Gulf of Mexico. ....................................................................................... 13
Figure 2. Cumulative distribution of annual VOC emissions for offshore platforms in the
Gulf of Mexico. ....................................................................................... 13
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Ramboll – Leviathan Gas Platform Emission Permit Review
1.0 Introduction
Noble Energy Inc. has proposed to build an offshore natural gas production platform in the
Mediterranean Sea, located approximately 9.7 km west of the coast of Israel near the city of
Haifa. The platform is designed to initially produce approximately 1,200 standard million
cubic feet of natural gas per day (approximately 1.4 million cubic meters per hour) during
Phase I of operation, with an additional 900 standard million cubic feet of natural gas per
day (approximately 1 million cubic meters per hour) during Phase II of operation. In
addition the platform will produce approximately 570 cubic meters per day of condensate
during Phase I of operation, increasing to approximately 1,000 cubic meters per day of
condensate during Phase II of operation. The proposed Leviathan platform will produce
from the Leviathan Gas Field in the Mediterranean Basin, located 125 km east of Haifa and
35 km east of the "Tamar" gas field. The depth of the water is between 1600 -1750 meters.
Noble Energy submitted a “Request for Emission Permit” to the Israel Ministry of
Environmental Protection in the fall of 2018, and subsequently submitted a revised Request
for Emission Permit in January 2019. This report refers only to the revised Request for
Emission Permit submitted in January 2019.
Homeland Guards, a non-profit organization based in Zichron Yaacov Israel, contracted with
Ramboll Corp. to review the revised Request for Emission Permit and provide comments on
the accuracy, completeness and reasonableness of the permit request.
Emissions from the platform consist of combustion sources and venting/fugitive sources.
Primary combustion sources include gas turbines for power and heat, heaters for separation
and treatment, and flares/combustors for waste gas destruction. Primary venting/fugitive
sources include fugitive emissions from pipeline components, venting from pipelines and
from storage tanks. Emissions of NOx, VOC, SOx, and CO (“criteria pollutants”) are
expected, as well as emissions of hazardous air pollutants (HAPs) such as benzene. The
primary focus of this review is on emissions of VOCs, although emissions of other pollutants
are discussed.
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Ramboll – Leviathan Gas Platform Emission Permit Review
In conducting this review, Ramboll reviewed the following documents associated with the
request for emission permit:
In addition, Ramboll reviewed CALPUFF dispersion modeling results for NO2 (Hourly, Yearly,
Max Yearly), NOx (Hourly, Daily), PM10 (Daily, Yearly), SO2 (Hourly, Daily, Yearly), and TSP
(3-Hour, Daily, Yearly).
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Ramboll – Leviathan Gas Platform Emission Permit Review
Ramboll’s Environment & Health practice is globally recognized, with 2,100 expert who have
earned a reputation for technical and scientific excellence, innovation, and client service.
Advances in science and technology and evolving regulatory, legal and social pressures
create increasingly complex challenges for Ramboll’s clients. Ramboll evolves to keep pace
with these changes – by adding new services, contributing to scientific advances and
expanding geographically.
Ramboll offers a comprehensive array of air quality management services in the oil and gas
sector, including facility-based services, strategic planning, and litigation support. Ramboll’s
principal and senior air sciences staff is internationally recognized in all areas relevant to
comprehensive air quality practices. Senior staff members are supported by scientists and
engineers with capabilities that encompass the entire range of air quality services.
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Ramboll – Leviathan Gas Platform Emission Permit Review
1. The provided process description and process diagrams, Chapter 2, included "LP Fuel
Gas and LP Flare Systems" which describes the lines going to the fuel gas or flare
system. We recommend the Ministry of Environmental Protection or other regulatory
agency to closely monitor the Fuel Gas Recovery Unit system reliability. Although we
have seen systems like this work for oil treatment systems, we have never seen
them deployed for gas systems. This system is critical to the destruction of
pollutants and the processing of waste gas throughout the life of the project;
therefore, particularly during the initial phase of operation of the platform, it is
recommended that such a system be instrumented to provide continuous monitoring
of its operation and any upset conditions be addressed immediately. Upset
conditions could include overpressurization of a vessel or a line, unlit or non-
operational flare, operational errors such as hatches left open, or other similar
conditions. In the U.S. recent research has been focusing on these abnormal or
upset conditions as a major source of emissions, and likely to drive the uneven
distribution of emissions from well sites1,2,3. We note that the fuel gas system is
designed to treat a number of waste gas streams. The request for emission permit
includes a simulated composition of the fuel gas system, indicating that the fuel gas
is suitable for combustion. However, no supporting information or backup
documentation is provided for this simulated composition. It is recommended that
such documentation be provided to confirm the suitability of the fuel gas for
combustion. In addition, once in operation the flare should be monitored as per
1
Zavala-Araiza, D., et al. (2015), Reconciling divergent estimates of oil and gas methane
emissions, Proceedings of the National Academy of Sciences, 112, 51, 15597-15602, doi:
www.pnas.org/cgi/doi/10.1073/pnas.1522126112.
2
Schade, G. W., and G. Roest (2016), Analysis of non-methane hydrocarbon data from a
monitoring station affected by oil and gas development in the Eagle Ford shale, Texas,
Elem. Sci. Anth., 4, 000,096, doi:10.12952/journal.elementa.000096.
3
Lyon, D.R., et al. (2016), Aerial Surveys of Elevated Hydrocarbon Emissions from Oil and Gas
Production Sites, Environmental Science & Technology,2016, 50, 4877-4886, doi:
10.1021/acs.est.6b00705.
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Ramboll – Leviathan Gas Platform Emission Permit Review
3. Flaring efficiency for the fuel gas system has been described in the request for
emission permit as 99% which is not a control efficiency value used in permitting in
the U.S. Flare destruction efficiency is typically cited as either 95% or 98%. EPA’s
AP-42 compendium of emission factors references 98% destruction efficiency:
“Properly operated flares achieve at least 98% destruction efficiency in the flare
plume, meaning that hydrocarbon emissions amount to less than 2 percent of the
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Ramboll – Leviathan Gas Platform Emission Permit Review
4
AP-42, Section 13.5 https://www3.epa.gov/ttn/chief/ap42/ch13/final/C13S05_02-05-18.pdf
5
CDPHE https://www.colorado.gov/pacific/sites/default/files/AP-Memo-15-03-AirPollutionControlEquipment.pdf
6
See Appendix B, pages 6 and 7. https://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/guidance_flashemission.pdf
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Ramboll – Leviathan Gas Platform Emission Permit Review
In order for such a system to function properly, it is likely that the operator expects
the gas to be dry (low water content) and dehydration is not required. This
information should be confirmed by the Ministry of Environmental Protection upon
startup of the project. If the gas is insufficiently dry for the use of a turboexpander
refrigeration system as described, a dehydration system (either a glycol contact
system or a molecular sieve) may be needed and emissions for such a system would
need to be estimated. Note that a molecular sieve system is a closed system that
does not generate continuous emissions.
10. The request for emission permit indicates that a number of large turbines will be
used to provide power to the platform. We note that turbines for this purpose are
meant to operate at a “sweet spot” of constant load. In the event that they are
operated at a load substantially lower or higher than this normal load condition,
substantially higher emissions of NOx can occur. The manufacturer test data will be
very specific in mapping the NOx emissions as a function of load. It is difficult to
know without seeing these specifications how high the NOx emissions can be.
11. Chapter 2 of the request for emission permit proposes to use TCEQ Method 28VHP –
instrument LDAR monitoring. USEPA standards would reference 40 CFR Part 60,
Subpart OOOOa which references Subpart VVa, “Standards of Performance for
Equipment Leaks of VOC in SOCMI.” Table 1 below provides a summary comparison
of the requirements of TCEQ 28VHP and NSPS OOOOa (VVa).
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Ramboll – Leviathan Gas Platform Emission Permit Review
Table 1. Summary comparison of LDAR requirements for TCEQ 28VHP and NSPS Subpart OOOOa (VVa).
Leak Definition
Monitoring Frequency Maintenance/Repair Requirements
(ppm)
Service
Equipment NSPS NSPS
Type
OOOOa 28VHP OOOOa 28VHP NSPS VVa & OOOOa 28VHP
(VVa) (VVa)
Compressors GV N/A Quarterlya N/A 2,000 Compressor are not an LDAR Under 28VHP, Periodic monitoring
equipment type under NSPS OOOOa. requirements do not apply to
They are regulated separately. equipment where the VOC has an
Pumps LL Monthly Quarterlya 2,000 2,000 - For M21 leak: 1st attempt at aggregate partial pressure of less
M21 & repair within 5 days and repair than 0.044 psia at 68°F (i.e.,
Weekly within 15 days definition of "HL components" under
Visual - For visual inspection: monitor NSPS regulations).
within 5 days to determine whether
For pumps, compressors, valves, or
there is a leak OR designate the
connectors emitting VOC in excess
visual indications of liquid dripping
of their respective leak threshold
as a leak.
OR found by visual inspection (e.g.,
HL N/A N/A 10,000 2,000 - For M21 leak: 1st attempt at dripping process fluids):
repair within 5 days and repair - First attempt at repair within 5
within 15 days days; and
- For visual inspection: monitor - Repaired within 15 days
within 5 days to determine whether
there is a leak OR eliminate the For pumps and compressors, seal
visual, audible, olfactory, or other systems designed and operated to
indication of a potential leak within 5 prevent emissions or seals equipped
days. with an automatic seal failure
- For HL equipment, no periodic detection and alarm system need
monitoring required (see HL valves) not be monitored.
Valves GV Monthly or Quarterlyb 500 500 - Any valve for which a leak is not For pressure relief valves equipped
LL Quarterly 500 500 detected for 2 successive months with a rupture disc upstream or
may be monitored the first month of venting to a control device, they are
every quarter, beginning with the not required to be monitored
next quarter, until a leak is detected.
- For M21 leak: 1st attempt at
repair within 5 days and repair
within 15 days
- No requirements for visual
indications of leaks
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Ramboll – Leviathan Gas Platform Emission Permit Review
Leak Definition
Monitoring Frequency Maintenance/Repair Requirements
(ppm)
Service
Equipment NSPS NSPS
Type
OOOOa 28VHP OOOOa 28VHP NSPS VVa & OOOOa 28VHP
(VVa) (VVa)
HL N/A N/A 10,000 500 - For M21 leak: 1st attempt at
repair within 5 days and repair
within 15 days
- For visual inspection: monitor
within 5 days to determine whether
there is a leak OR eliminate the
visual, audible, olfactory, or other
indication of a potential leak within 5
days.
Pressure GV Quarterly Quarterlyb 500 500 - For M21 leak: 1st attempt at repair
Relief Valves and within within 5 days and repair within 15
5 days of days
pressure - No requirements for visual
release indications of leaks
event
LL N/A 10,000 500 - For M21 leak: 1st attempt at
HL N/A N/A 10,000 500 repair within 5 days and repair
within 15 days
- For visual inspection: monitor
within 5 days to determine whether
there is a leak OR eliminate the
visual, audible, olfactory, or other
indication of a potential leak within 5
days.
Connectors GV Within 12 Weekly 500 500 - For M21 leak: 1st attempt at
(e.g., months of Visualc repair within 5 days, repair within 15
LL 500 500
flanges) the days, and follow-up monitoring
compliance within 90 days of repair
date and - No requirements for visual
every 1-8 indications of leaks (except for
years inaccessible, ceramic, or ceramic-
thereafter lined connectors)
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Ramboll – Leviathan Gas Platform Emission Permit Review
Leak Definition
Monitoring Frequency Maintenance/Repair Requirements
(ppm)
Service
Equipment NSPS NSPS
Type
OOOOa 28VHP OOOOa 28VHP NSPS VVa & OOOOa 28VHP
(VVa) (VVa)
HL N/A 10,000 500 - For M21 leak: 1st attempt at
repair within 5 days and repair
within 15 days
- For visual inspection: monitor
within 5 days to determine whether
there is a leak OR eliminate the
visual, audible, olfactory, or other
indication of a potential leak within 5
days.
Open-Ended All N/A N/A - No N/A 500 Each open-ended valve or line shall If a cap, blind flange, plug, or
Lines periodic be equipped with a cap, blind flange, second valve is not installed within
monitoring plug, or second valve at all times 72 hours of creating an open-ended
unless except during operations requiring line:
certain process fluid flow through the open- - Repair the open-ended line
conditions ended valve or line. Each open- within 24 hours; or
are metd ended valve or line equipped with a - Install a cap, blind flange, plug,
second valve shall be operated in a or second valve.
manner such that the valve on the
process fluid end is closed before the
second valve is closed.
a
Valves that begin operation must also be monitored within 30 days after the end of its startup period to ensure proper installation.
a
Pumps and compressors must be equipped with a shaft sealing system that prevents or detects emissions of VOC from the seal.
b
Replacements for leaking valves shall be re-monitored within 15 days of being placed back into VOC service.
c
Connectors must also have pressure testing OR gas analyzer monitoring performed within 15 days for new or reworked piping connections.
d
If an open-ended line is created (e.g., during isolation of equipment for hot work or the removal of a component for repair which results in an open-
ended line), the permittee must either:
Install a cap, blind flange, plug, or second valve on the line within 72 hours; or
Monitor once for leaks for a plant/unit turnaround lasting up to 45 days. For all other scenarios, monitor once within 72 hours of creating the
open-ended line and monthly thereafter.
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Ramboll – Leviathan Gas Platform Emission Permit Review
12. Chapter 3-6 of the request for emission permit indicates that two emergency diesel
generators would be on site for backup power. However, no emissions are assigned
to these generators. For safety purposes, emergency generators must typically be
operated for a specific number of hours per month or year to ensure they function
adequately. It is recommended that combustion emissions associated with minimal
safety firing of the emergency generators be included in the emissions totals for the
platform.
13. Forms provided in Chapter 3 were reviewed for the accuracy of specific quantitative
information:
a. Forms 3.1.2.2-1, 3.1.2.2-2, 3.1.2.2.-3 – the “name of material” entry for
different sources is “Nitrogen oxides (NOx/ NO2)” and “Sulphur oxides
(SOx/SO2)” with the same emission rate. Different agencies provide different
guidance for the ratios of NOx to NO2 and SOx to o2. SOx would be 100%
SO2; however, NOx from combustion can be a mixture of NO and NO2, of
which only NO2 has an established air quality standard (in the U.S.). We
would suggest that the request for emission permit include the ratios of NO to
NO2 for specific combustion units based on manufacturer’s specifications. The
request for emission permit should specify what the ratios need to be per
source as it can significantly impact predicted short-term ambient
concentrations of NO2.
b. Forms 3.1.2.2-2 and 3.1.2.2-3 and 3.5 – we note that HAPs, specifically
formaldehyde (HCHO), benzene, toluene, ethylbenzene, xylene (BTEX) and n-
hexane, have not been speciated. Particular to gas-fired engines, HCHO is
considered a HAP and can constitute 50% of the total engine VOC emissions.
BTEX and n-hexane tend to be present in larger concentrations in gas
treatment systems. USEPA designates a source as “major” for HAPs if any
single HAP (like HCHO) equals or exceeds 10 tons per year. Based on current
emission estimates of NMVOC from engines in the request for emission
permit, the proposed project would exceed USEPA major source standards if
30% or more of NMVOC is HCHO. Therefore it is critical that the HAP
speciation be indicated.
c. Form 3.3 C – fugitive emissions have been updated in the January 2019
revised request for emission permit, relative to the earlier version released in
fall 2018. However, we note that gas lines are still not included for fugitive
emissions based on the documents “Leviathan Valve Standards Letter” and
“LPP-T-FDE-PRS-RPT-0020 1-7” included in Appendix 14.
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Ramboll – Leviathan Gas Platform Emission Permit Review
Emissions of NOx and CO would lead the facility to be considered a “major source” under
USEPA designation, and would be subject to New Source Review (NSR) 7 and Prevention of
Significant Deterioration (PSD)8. If the platform were located in an attainment area in the
U.S., the facility would have to undertake PSD review per 40 CFR 52.21. In addition, a
project that is major for at least one criteria pollutant would be considered major for all
criteria pollutants and would be subject to PSD review for those pollutants that exceed
significant emission rates. In this case, the proposed Leviathan platform would trigger PSD
review for all criteria pollutants. In this case, the project would require:
Finally, sources that are major for criteria pollutants would trigger PSD for greenhouse
gases if the potential to emit exceeds 100,000 tons per year of carbon dioxide equivalent
(CO2e). This would require a Best Available Control Technology (BACT) evaluation for GHG
emissions. Such an evaluation would include a thorough review of technology options for
reducing emissions of GHGs, including aftertreatment systems, carbon capture systems, or
other available technologies.
7
https://www.epa.gov/nsr
8
https://www.epa.gov/nsr/prevention-significant-deterioration-basic-information
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Ramboll – Leviathan Gas Platform Emission Permit Review
Cumulative Distribution:
Platform-wide NOx Emissions (Logarithmic Scale)
(source: BOEM 2014 GOADS Emission Inventory)
BOEM Platform Emissions Leviathan Platform Emissions
NOx Emissions (annual metric tons/platform)
1000
100
10
0.1
0.01
0.001
0.0001
0.00001
0.000001
0% 20% 40% 60% 80% 100%
Note: Thi s graph i s not normalized to platform hydrocarbon output; platforms i n the bottom
ha l f of the graph produce no or very s mall quantities of hydrocarbons
Figure 1. Cumulative distribution of annual NOx emissions for offshore platforms in the
Gulf of Mexico.
Cumulative Distribution:
Platform-wide VOC Emissions (Logarithmic Scale)
(source: BOEM 2014 GOADS Emission Inventory)
BOEM Platform Emissions Leviathan Platform Emissions
VOC Emissions (annual metric tons/platform)
10000
1000
100
10
0.1
0.01
0.001
0.0001
0.00001
0% 20% 40% 60% 80% 100%
Note: This graph is not normalized to platform hydrocarbon output; platforms in the bottom
half of the graph produce no or very small quantities of hydrocarbons
Figure 2. Cumulative distribution of annual VOC emissions for offshore platforms in the
Gulf of Mexico.
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Ramboll – Leviathan Gas Platform Emission Permit Review
Figure 1 suggests that the Leviathan platform would be near the very highest percentile for
NOx emissions, similar to the less than 5% of the highest-emitting platforms in the Gulf of
Mexico. By comparison, Figure 2 suggests that approximately 30% of platforms in the Gulf
of Mexico would have higher VOC emissions than the Leviathan platform.
This suggests that NOx emissions from the Leviathan platform, as described in the request
for emission permit, are similar to the largest, highest-emitting platforms in the U.S. Gulf of
Mexico development area. Similarly, VOC emissions are comparable to the largest 30% of
platforms in the Gulf of Mexico. Based on discussions with BOEM, the VOC emissions from
the 70% of platforms below those of the Leviathan platform in the GOADS database are
from platforms with very little gas production or that are otherwise out of operation or
idled9. This suggests that for a high gas production platform such as the Leviathan
platform, much larger VOC emissions would be expected than those described in the
request for emission permit. Some of the comments made in section 2.1 above, if
addressed properly in the request for emission permit, would lead to an increase in the VOC
emission inventory for the proposed platform. We also note that the control system
proposed here is novel and its operation has not been demonstrated for such a large scale
operation. As noted above, close monitoring of this system is strongly recommended,
particularly in the initial phase of operation of the platform, to ensure that the control
efficiency as described in the request for emission permit is actually achieved.
9
Personal communication – John Filostrat, BOEM Public Affairs, March 2019.
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Ramboll – Leviathan Gas Platform Emission Permit Review
For source categories, an extensive list of data is required for each structure. Table 3 below
summarizes the basic data for each source category (more detailed information is available
through the GOADS system):
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Ramboll – Leviathan Gas Platform Emission Permit Review
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Ramboll – Leviathan Gas Platform Emission Permit Review
As shown in Table 3, the reporting requirements in the GOADS system are extensive and
include a number of categories (e.g. vessel loading at platforms, cold vents associated with
upsets) that are not currently evaluated in the Leviathan request for emission permit.
17