Commitments and Contingencies

6 Months Ended

Jun. 30, 2020

Commitments and Contingencies Disclosure [Abstract]

Commitments and Contingencies

Note 9. Commitments and Contingencies

Legal Proceedings   We are involved in various legal proceedings in the ordinary course of business. These proceedings are subject to the uncertainties inherent in any litigation. We are defending ourselves vigorously in all such matters, and we believe that the ultimate disposition of such proceedings will not have a material adverse effect on our financial position, results of operations or cash flows.

Bureau of Safety and Environmental Enforcement Penalty Assessment In July 2020, we received a penalty assessment of approximately $136,000 from the federal Bureau of Safety and Environmental Enforcement related to an alleged unauthorized discharge from an offshore platform located in the Gulf of Mexico, formerly owned by Noble Energy and sold to Fieldwood Energy, Inc. (Fieldwood), in April 2018. The unauthorized discharge is alleged to have occurred in May 2018, during the transition period when Noble Energy operated the platform on behalf of Fieldwood. Fieldwood is required to fully indemnify Noble Energy for any liabilities that arose during the transition period. Noble Energy has notified Fieldwood of the penalty and is currently seeking a resolution of this matter with Fieldwood. While we cannot predict the outcome of this matter, we do not believe the resolution will have a material adverse effect on our financial position, results of operations or cash flows.

MOEP Notifications In April and May 2020, we received two separate notices of intent (NOIs) from Israel’s Ministry of Environmental Protection (MOEP), notifying us of potential enforcement and imposition of monetary sanctions for alleged violations of Israeli environmental laws relating to our Leviathan facility. MOEP’s April NOI alleges breaches of the Leviathan facility’s effluent discharge permit for discharges that occurred primarily before startup of the Leviathan facility and seeks a penalty of approximately $1.2 million, net to the Company's interest in the Leviathan facility, pursuant to Israel’s Prevention of Sea Pollution from Land-Based Sources Law. In the May NOI, MOEP alleges violations of the Leviathan facility's air permit for the alleged failure to transmit to MOEP continuous monitoring data for flares, along with other alleged administrative infractions of Israel's Clean Air Law. Pursuant to Israel's Clean Air Law, MOEP seeks a penalty of approximately $147,000, net to the Company's interest in the Leviathan facility.

In July 2020, a NOI was received from the MOEP notifying us of a potential enforcement and imposition of a monetary sanction of approximately $632,000, net to the Company's interest in the Leviathan facility, pursuant to the Clean Air Law following alleged violations of the emissions permit during the activation of the Leviathan facility's flares.

We have discussed the NOIs with MOEP enforcement staff and anticipate further meetings regarding a potential settlement of the alleged violations. Given the ongoing status of settlement discussions, we are currently unable to predict the ultimate outcome of this action, but believe the resolution will not have a material adverse effect on our financial position, results of operations or cash flows.

Colorado FracFocus Matter In July 2019, we received a Notice of Alleged Violation (NOAV) from the Colorado Oil and Gas Conservation Commission (COGCC) advising us of alleged violations of COGCC rules for delinquent disclosures to the FracFocus Chemical Disclosure Registry following commencement of certain hydraulic fracturing activities. We responded to the NOAV in July 2019, confirming with the COGCC that required disclosures had been made prior to issuance of the NOAV. In May 2020, COGCC enforcement staff proposed an administrative penalty in the amount of approximately $149,000 to resolve the enforcement of this matter. We are in the process of reviewing the proposed settlement document. Given the ongoing status of settlement discussions, we are currently unable to predict the ultimate outcome of this action, but believe the resolution will not have a material adverse effect on our financial position, results of operations or cash flows.

Colorado Clean Water Act Referral Notice In September 2018, we received a letter from the Department of Justice (DOJ) providing notification of referral from the Environmental Protection Agency (EPA) of alleged Clean Water Act violations at an upstream production facility and a midstream gathering facility in Weld County, Colorado. In April 2019, we met with the DOJ and EPA enforcement personnel to discuss potential settlement of the alleged violations. Given the ongoing status of settlement discussions, we are currently unable to predict the ultimate outcome of this action, but believe the resolution will not have a material adverse effect on our financial position, results of operations or cash flows.