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Archive for July, 2024

Should wind leasing and development be paused until the Vineyard Wind investigation is completed?

Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Offshore Wind, Regulation, tagged , , , , , on July 23, 2024| 1 Comment »

The Vineyard Wind turbine incident, which littered Nantucket beaches, has also tarnished the US offshore wind program. BSEE has prudently halted Vineyard Wind operations and construction pending an investigation into the blade failure.

Offshore wind development is structure rich, so public confidence in the design of turbines and support platforms is critical. BOEM lists 37 active wind leases on the US OCS. Most of these leases have not yet reached the construction phase. A hold on the approval of any Construction and Operations Plans would seem to be appropriate pending completion of the Vineyard Wind investigations.

Per the leasing schedule below, BOEM intends to hold 4 wind sales during the remainder of 2024, all within a 3 month period. Only 1 sale is scheduled for each of the following 2 years. Deferring the 2024 sales until the investigations are complete would assist potential lessees by ensuring that the issues of concern were fully understood.

Unfortunately, BOEM’s failure to conduct a 2024 oil and gas lease sale has boxed in the wind program. The Inflation Reduction Act prohibits BOEM from issuing wind leases unless an oil and gas sale has been held within the previous year. Lease Sale 261 was held on 12/20/23 meaning that no wind leases may be issued after 12/20/24. BOEM has compressed the wind leasing schedule, presumably to beat the legislative deadline. It would have been better for both the oil and gas and the wind programs if at least one oil and gas sale had been held in 2024 as has been customary since the 1950s.

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Vineyard Wind’s financial assurance waiver cites robust insurance policies, proven technology, and guaranteed electricity sales

Posted in accidents, decommissioning, Offshore Wind, tagged , , , , , on July 22, 2024| 2 Comments »

Nantucket Current photo: damaged Vineyard Wind turbine

Pasted below is an excerpt from the BOEM letter waiving the“pay as you build” financial assurance requirement for the Vineyard Wind project.

Comments on the 3 risk reduction factors cited in the letter:

Factor 1: Those “robust insurance policies” may soon be tested given the costs associated with the turbine blade incident and potential law suits. (The notice pasted below informs that Nantucket officials will meet on Tuesday to consider litigation. A question for attorneys is the extent to which Nantucket is compromised by their good “Good Neighbor Agreement” with Vineyard Wind. That agreement essentially calls on Nantucket to promote the Vineyard Wind projects in return for payments that seem modest relative to the economic benefits from tourism and fishing.)

Factor 2: To the extent that GE Vernova Haliade-X 13 megawatt turbines are proven technology (and that is very much in doubt), the use of proven technology doesn’t prevent premature abandonment associated with unexpected incidents.

Factor 3: Reliable power generation and predictable long-term income remain to be demonstrated.

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Messy situation at “abandoned” platform in TX State waters

Posted in decommissioning, Gulf of Mexico, Offshore Energy - General, oil spill response, tagged , , , , , , on July 20, 2024| Leave a Comment »

Pictures from Click2Houston:

This is yet another example of the importance of proper well plugging, platform removal, and decommissioning financial assurance. It’s noteworthy that Texas is among the states suing to block BOEM’s financial assurance rule for Federal waters. A serious collaborative Federal, State, and industry effort to address decommissioning issues is long, long overdue.

Key points from the Facebook post by State Representative Terri Leo Wilson (full post pasted below):

  • 8 miles offshore Galveston County (TX State waters extend 3 marine leagues/9 nautical miles/10.35 statue miles offshore)
  • flowline riser leaking natural gas and condensate (badly corroded platform)
  • no recoverable oil
  • abandoned platform
  • additional research is needed to fully determine ownership of the leak source (???)

HIGH ISLAND BLOCK 98-L INCIDENT :

The Texas General Land Office (GLO) is sharing the following information:

On Sunday, July 14, 2024, at 8:00 pm, the Oil Spill La Porte Office Response Officer received notification of a natural gas/oil discharge off the coast of Crystal Beach, Galveston County. The spill was reported to be from a platform in High Island Block 98-L, about eight miles offshore in the Gulf of Mexico. Oil Spill personnel traveled via response boat to investigate on Monday morning and determined the discharge to be from a flowline riser leaking natural gas and condensate. Although the leak can be seen from the water, no recoverable oil was visible. The platform is abandoned, as defined by the Texas Railroad Commission, placing it within the Railroad Commission’s statutory authority for administration. The wells are not covered as part of the GLO’s current well plugging MOU with the Railroad Commission. The platform and associated wells are documented in the Oil Spill program’s abandoned well listings.

On Wednesday, July 17, La Porte office staff, with US Coast Guard and Railroad Commission personnel, inspected the platform area again. The leak is still present but has not increased. Railroad Commission staff stated that additional research is needed to fully determine ownership of the leak source.

The Coast Guard reports receiving a call from Channel 2-KPRC (NBC) in Houston regarding the leak and also seeing social media posts by a local area fishing group.

At this time: No injuries reported, No impact to commerce, No impact to wildlife.

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Vineyard Wind: regulatory observations

Posted in accidents, Offshore Wind, tagged , , , , on July 19, 2024| 1 Comment »

Nantucket Current photo: Vineyard Wind turbine AW38 with a damaged blade that has caused thousands of pieces of debris to wash ashore on Nantucket since Tuesday.

Vineyard Wind statement (7/18):

  • “This morning, a significant part of the remaining GE Vernova blade detached from the turbine. Maritime crews were onsite overnight preparing to respond to this development, though current weather conditions create a difficult working environment.”
  • “We are staying apprised of GE Vernova’s efforts to manage the situation, including the removal and recovery of the remaining blade attached to the turbine.”
  • Staying apprised? As operator, Vineyard Wind is fully responsible. This is their situation to manage.

BSEE statement:

  • BSEE has ordered Vineyard Wind to suspend power production and wind turbine generator construction.
  • Kudos to BSEE for their decisive and timely action. They need to better understand what happened before allowing operations and construction to continue.
  • Imagine the pressure on the regulator if the project was providing a significant portion of the region’s electricity.
  • BSEE’s comment that there has been “no harm to any marine resources or mammals from the incident” is premature given the extensive marine debris and the associated risks to mammals.

What about the CVA?

  • The regulations at 30 CFR § 285.707-712 assign important responsibilities to Certified Verification Agents (CVAs), independent third parties with established technical expertise. These responsibilities include detailed reviews of the design, fabrication, and installation plans.
  • Oddly, the CVA’s “Statement of Qualifications” and “Scope of Work and Verification Plan” have been redacted in their entirety from Vineyard Wind’s Construction and Operations Plan (COP) (see Appendix I-C and I-D).
  • Who was the CVA and why was that important information redacted?
  • Were any of the CVA requirements waived per 258.705?

BOEM:

  • Will BOEM, the lessor and Federal wind program manager, be making a statement? Will they be reassessing their COP review procedures?
  • BOEM should temper their over-the-top promotion of offshore wind. The complete shutdown of the first utility scale offshore wind farm heightens public concerns about the intermittency of this power source, and the need for reliable backup sources.

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Caught in the middle – another Santa Ynez Unit “Catch 22”

Posted in California, energy policy, Offshore Energy - General, tagged , , , , , , on July 18, 2024| Leave a Comment »

caught in the middle?

Earlier this month we awarded a Chutzpah Award to groups that helped block every attempt to resume production in the Santa Ynez Unit and are now suing to terminate the leases for non-production. 

We now learn that the State Fire Marshall has rejected the resumption of production because Sable, the current operator, is not installing automatic shutdown valves on the oil pipeline. The catch is that Sable was denied permits needed to install the valves. So, on the one hand the Fire Marshall is requiring shutdown valves (a reasonable requirement), and on the other hand the County is prohibiting the installation of those valves!

According to the Fire Marshall’s office, this is the first time a company has been denied permits to install valves mandated by the State – yet another dubious distinction for the Santa Ynez Unit.

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Debris poses a significant risk to marine mammals

Posted in accidents, Offshore Wind, tagged , , , , on July 17, 2024| 1 Comment »

In the wake of the Vineyard Wind turbine blade incident, it’s important to note that marine debris is a significant risk factor for mammals. This is a particular concern for baleen whales, like the endangered right whale, which filter large amounts of water. Per NOAA:

Marine Mammals: Many species of marine mammals have also been confirmed to eat marine debris. A review by Kühn and van Franeker found that 69 species of marine mammals have been found to ingest debris – that’s 56% of all marine mammals! This includes 44 species of odontocetes (toothed whales), manatees, and multiple seal species. Marine mammals are highly protected, which can make it difficult to research them. Most research on marine mammals takes place after an animal dies, making it difficult to understand what marine debris live animals eat. However, we do know that because baleen whales filter extremely large amounts of water while feeding, they may get plastic debris entangled in their baleen plates. 

An Argentinian study describes the “finding of plastic litter in the digestive tract of a southern right whale (Eubalaena australis) juvenile male, which was found dead on the shores of Golfo Nuevo, Chubut, Argentina in 2014.”

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Vineyard Wind operations shut down

Posted in accidents, Offshore Wind, tagged , , , on July 17, 2024| 1 Comment »

Nantucket Current photo

Appropriate response by BSEE.

Late Tuesday afternoon, the Bureau of Safety and Environmental Enforcement said all operations are shut down until further notice.

“A team of BSEE experts is onsite to work closely with Vineyard Wind on an analysis of the cause of the incident and next steps,” the agency said in a statement.  

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Vineyard Wind turbine blade incident

Posted in accidents, Offshore Energy - General, Offshore Wind, tagged , , , , , , on July 17, 2024| 2 Comments »

Photo by Capt. Carl Bois shared with the Nantucket Current
Ack4whales photo of the damaged turbine

On Sunday (7/14), Capt. Carl Bois, of the fishing charter Topspin out of Nantucket, told the Current he noticed a significant amount of debris in the Vineyard Wind lease area.

“There was so much debris at the wind farm,” Bois said. “We covered many miles and only saw the debris at the wind farm site: big sheets of fiberglass with foam core and lots of loose foam.”

On Saturday night (7/13) the Coast Guard warned Mariners as follows: “Coast Guard received a report of 03 floating debris 10 meters by 2 meters in the vicinity of approximately 26 NM SE of Marthas Vineyard and 22 NM SW of Nantucket in position 40 59.559N 070 25.404W. All marines are requested to use extreme caution while transiting the area.“

On Monday (7/15), Vineyard Wind confirmed that a turbine blade incident occurred on 7/13: “On Saturday evening, Vineyard Wind experienced blade damage on a wind turbine in its offshore development area. No personnel or third parties were in the vicinity of the turbine at the time, and all employees of Vineyard Wind and its contractors are safe and secure.”

On 7/16, Vineyard Wind issued another statement advising that they were deploying teams to Nantucket to clean up debris from the incident.

Comments:

  • Not a good look for the first large-scale offshore wind project in the US.
  • It’s unclear what the status of operations was at the time of the incident.
  • Vineyard Wind seems to be passing the buck a bit when they note that “GE, as the project’s turbine and blade manufacturer and installation contractor, will now be conducting the analysis into the root cause of the incident.” While GE’s findings are critical, Vineyard Wind, as operator, is fully responsible and accountable for the incident and should be leading the analysis.
  • Was their a third party review of the turbine design?
  • Was the incident reported to BSEE, the safety regulator for offshore wind? State and local government?
  • BSEE and the Coast Guard should ensure that Vineyard Wind’s findings and their own independent report are made publicly available in a timely manner. Ditto for Safety Alerts.
  • What other incidents have occurred during offshore wind facility construction and operations?
  • In 2017, Vineyard Wind requested to defer providing the full amount of the required financial assurance until year 15 of actual operations. That request was denied, but was approved when resubmitted in 2021. The regulations have now been revised to allow such deferrals of financial assurance on all offshore wind projects.

Vineyard Wind is a joint venture between Avangrid, a Spanish company, and Copenhagen Infrastructure Partners. They were

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The Secret Service, OCS incident data, and high consequence events

Posted in accidents, drilling, Offshore Energy - General, Uncategorized, tagged , , , , , on July 16, 2024| Leave a Comment »

Secret Service being scrutinized following assassination attempt
Heroic volunteer fire chief Corey Comperatore, who died shielding his family at the Trump rally

As is the case with many Federal and corporate entities, the Secret Service website is long on promotion and short on substantive details and performance data. The limited “Measurable Impact” statistics on their webpage advise that the Secret Service protected 6623 foreign and domestic visits “without incident” in Fiscal Year 2022, which ended 22 months ago.

Their 2024 budget request overview includes a bit more information (pasted below). The Secret Service gives themselves a perfect score if protectees arrive and depart safely. When your scores are always 100%, your performance measures are clearly inadequate.

Like drilling blowouts, assassinations are low frequency, high consequence events. Prevention requires gathering data on lesser events, identifying leading indicators, and tracking high-potential precursors. You don’t prevent high consequence events by only tracking high consequence events.

Inspections are also critical. Does the Secret Service inspect events to assess protective measures such as verifying that the surrounding areas are cleared and being observed? If so, what do those numbers look like.

BSEE, the OCS safety regulator, does a good job of collecting data, but fails to compile and post updates in a timely manner. Their latest incident tables are for 2022, and even those data are incomplete. Panel investigations, which are conducted for the more serious incidents, now take 2.5 years to complete. This is unacceptable for an organization with BSEE’s talent, resources, and safety mandate.

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“The most common error of a smart engineer is to optimize a thing that should not exist.” ~Elon Musk

Posted in accidents, Uncategorized, well control incidents, tagged , , , , , , on July 15, 2024| Leave a Comment »

This is very true, but engineers may not have a choice when directed to optimize a flawed decision.

Gaza pier

For example, the installation of the Gaza pier was a political decision imposed on military engineers without assessing the operational risks. The $230 million pier was in operation for only 20 days, long enough for several serious injuries to result from the reckless decision.

Some of the worst offshore drilling incidents were largely the result of culture or management driven attempts to save time and money. Modest cost savings were prioritized over verifying well integrity during both the Montara and Macondo well suspensions. The Santa Barbara blowout was the result of eliminating a casing string during development drilling, which virtually assured an uncontrolled flow in the event of a well kick.

Danenberger slide

 

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