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.
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.
“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 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?
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.
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.”
“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.
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?
Secret Service being scrutinized following assassination attemptHeroic 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.
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.
A Bell 212 helicopter is in the news following the crash that killed Iran’s President and Foreign Minister. Given the difficult weather conditions and mountainous terrain, the crash was most likely an accident.
As noted in this vintage newsletter (p. 8), we flew to Georges Bank drilling rigs in the early 1980’s in a Bell 212 contract helicopter, owned and operated by Petroleum Helicopters Inc (PHI).
The Bell 212 was chosen by the USGS aviation expert because of its range, reliability, and IFR capabilities that enabled flying in limited visibility. Because of difficult fog conditions on Georges Bank, drilling rigs were sometimes not visible until we were descending to land.
For the most part, the offshore industry has replaced Bell 212 helicopters with newer models, but the 212 was in use for many years and had an excellent performance record.
PHI Bell 212 prepares to land at a platform in the Gulf of Mexico, 1974, Vertiflite.
Nord Stream AG has responded to their insurers’ “a goverment did it, so we don’t have to pay” defense. Nord Stream’s full response, courtesy of Swedish engineer Erik Andersson, a leader in seeking the truth about the the pipeline sabotage, is linked.
Key excerpts from the Nord Stream AG filing (p.5):
(a) On their proper construction, in the context of Exclusion 2.i as a whole, the words “destruction of or damage to property by or under the order of any government or public or local authority” relate only to destruction or damage that arises out of or is related to the confiscation, nationalisation or requisition of therelevant property (and/or attempts thereat). In the premises, those words do not apply to the Damage.
(b) Alternatively, in the event that the Defendants establish that the Damage does constitute destruction of or damage to property by or under the order of any government, then it is therefore covered by the Deliberate Damage clause because it would have been “loss, damage, liability, cost or expense caused or inflicted by order of any governmental or regulatory body or agency” and Exclusion 2(i) to Section I does not apply: paragraphs 8 and 9.2 above are repeated.
If the insurers contend that one or more governments were responsible, shouldn’t they have to identify the government(s)? That would be nice. However, Erik doesn’t think the Nord Stream AG response puts the insurers in that politically difficult position. I agree. This case is about getting the insurers to pay for the damages, not identifying the responsible parties, something that the Swedes, Danes, and Germans have shied away from.
JL Daeschler, pioneering subsea engineer and BOE contributor, recounted a frightening incident in 1976, a year after UK North Sea production began:
We found ourselves in a drastic situation. While working on a subsea well, the wireline retrievable tubing safety valve got tangled up in the tree area. We had an open well situation and couldn’t cut the wire in the subsea tree. Further, the weather was bad, and keeping on location was difficult. The riser hydraulic release was faulty, so there was an imminent high risk of a “jammed ” subsea tree, bent/damaged riser, and uncontrollable well flow.
We got through this, but recognized that improved well control capabilities were needed during workover operations. Management decided that any future workover operations on a subsea tree/well would require a small diameter workover BOP with shearing capability immediately above the Xmas tree. A year later, we had the hybrid kit pictured below (with JL). Note that the guide funnels are slim to run on guide lines and not overshoot the guide base posts.
JL’s story reminds us once again that safety achievement is dependent on continuous improvement driven by experience, research, and technological advances.
When I was a young engineer with the US Geological Survey, the OCS safety regulator at the time, my boss and mentor Richard Krahl (known as “Mr. OCS” for his commitment to offshore safety) slammed😀 a copy of the first edition of API RP 14C (Analysis, Design, Installation, and Testing of Safety Systems for Offshore Production Facilities) on my desk and told me to read it carefully. That pioneering process safety document has grown with the offshore industry and is now in its 8th edition.
Similarly, API RP 2A-WSD (Planning, Designing, and Constructing Fixed Offshore Platforms— Working Stress Design) is now in its 22nd edition and API STD 53 (Well Control Equipment Systems for Drilling Wells) is in its 5th edition. There are countless other examples of the progression in safety equipment and practices.
As individuals, companies, agencies, and collectively as an industry, there can be no standing still. Nothing is routine and the challenges continue to grow: deeper wells, more complex geology, higher temperature and pressure, deeper water, harsher environments, remote locations, new security risks, and more. We get better or we get worse, and the latter is not an option. Onward!
