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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.

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.”

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.  

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

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.

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

 

Some of us remember the Brent Spar saga (1995). The subsequent Brent field decommissioning activities have been less controversial, including the removal of the Brent C topsides on July 9. The Allseas single lift technology is most impressive. Check out the video!

Jean-Louis Daeschler, is an artist and pioneering subsea engineer. A native of France (Brittany), he has worked in the offshore industry worldwide and lives in Scotland. His wife is from Singapore and his children and grandchildren live in England and Canada.

Before beginning his engineering career, JL had the distinct honor of exhibiting his artwork at the French National Assembly (Parliament) in Paris (article below). How many offshore engineers can say that? None would be a good guess.

JL also exhibited in le Havre, Singapore, Houston, Edinburgh, Calgary, and elsewhere. He works mainly with acrylics, and his preferred subjects are boats, maritime scenes, harbors and the working environment associated with the sea. Of course!

JL worked on an early semi-submersible rig offshore Malaysia in 1969 (see his account of a serious near-miss), met with George HW Bush when he was building a new rig for Zapata Offshore, was instrumental in the first production in the UK sector of the North Sea (1975) from a converted semi-submersible drilling rig in the Argyll Field, designed a new BOP concept, and holds patents for seabed drilling templates and subsea control systems.

When he was called upon to work in Total’s onshore office, his boss told him “the best offshore job is in the office!” The photo below suggests that JL made the most of those onshore assignments! 😀

JL Daeschler, part of Total’s subsea team, enjoying his onshore assignment in 1985

Congratulations to JL on his many contributions to the offshore industry, art, and society!

….as long as they are aligned with the preordained political decision. 😠

No where has this been more apparent over the years than in Alaska. Most recently, the North Slope Borough filed suit to challenge the Bureau of Land Management (BLM) rule making the National Petroleum Reserve in Alaska (NPR-A) off limits to oil and gas development.

Mayor Josiah Patkotak of the North Slope Borough

“The rule would significantly and irrevocably harm the North Slope’s right to self-determination and ability to provide essential services for residents. This suit is filed alongside the complaints of the Voice of the Arctic Inupiat and the State of Alaska, demonstrating the unity of North Slope communities and Alaskans in opposing the BLM’s unjust and unilateral action to harm the livelihoods of the residents of the North Slope,” the borough explained in a press statement.

“When I was sworn in as Mayor of the North Slope Borough, I made a solemn promise to protect and provide essential services for the people of the North Slope Borough. The BLM claims to act on our behalf but what they are truly doing is undermining my ability to fulfill that fiduciary obligation,” said Mayor Josiah Patkotak. “We on the North Slope don’t have the luxury of keeping quiet and waiting for a new industry to swoop in and replace our largest economic driver. We have to speak up for our future as a people.”

Other important points raised in the Must Read Alaska article:

  • NPR-A is entirely within the boundaries of the North Slope Borough (NSB).
  • The NSB represents the ancestral homelands of the Inupiat people.
  • The NSB is the largest employer in the region and provides the majority of essential services depended upon by residents.
  • Taxes on infrastructure account for 95% of the Borough’s revenue.
  • Members of the North Slope Inupiat Tribes, Village Corporations, Regional Corporations, and their elected leaders have been unanimous in their opposition to the rule.
  • The Supreme Court’s decision in Loper, which removed the Chevron Deference, restricts the authority of Federal agencies to take regulatory actions without clear legislative authority.
  • The State of Alaska also filed a lawsuit claiming that the Fed govt had not consulted with affected parties, and that the BLM had exceeded its congressional authorization.

This should be an easy win for Alaska and the NSB.

BOEM’s land rush approach to offshore wind leasing will add up to 1086 turbine towers and 28 offshore substations (OSSs) in the Atlantic just from active projects with approved Records of Decision (RODs). (See the table below.) Another 17 active Atlantic commercial projects have yet to reach the ROD stage. Those projects should increase the total number of structures to >3000. Five more Atlantic wind lease sales are scheduled.

projectturbine towersoffshore substations
Coastal VA Offshore Wind2023
Revolution Wind1002
Sunrise Wind941
Atlantic Shores South200up to 10
Ocean Wind 198up to 3
Vineyard Wind 11002
Empire Wind 1 & 21472
New England Wind (phases 1&2)1505

Per the Construction and Operations Plan (COP) for Vineyard Wind, the topsides for a conventional electrical service platform (ESP) (also known as an offshore substation or OSS) are 45 x 70 x 38 m, which is larger in surface area than a typical 6-pile oil and gas platform (~30 x 30 m), and is comparable in size to a large jackup drilling rig.

The Atlantic Shores plan calls for 10 small, 5 medium, or 4 large OSSs. (Uncertainty regarding the number and types of structures seems rather common in wind COPs.) The large OSSs have topsides that are 90 m by 50 m and rise to 63 m above MLLW. These are large offshore structures whether for wind or oil and gas.

Vineyard Wind ESP

Despite the looming decommissioning obligations, BOEM’s financial assurance requirements have been relaxed to facilitate wind development.

Per BOEM, the “Rule to Streamline and Modernize Offshore Renewable Energy Development” is intended to “make offshore renewable energy development more efficient, [and] save billions of dollarsUnfortunately, the savings associated with relaxed financial assurance requirements translates to increased risk for power customers and taxpayers.

BOEM signaled their intentions on offshore wind (OSW) decommissioning three years ago when they granted a precedent setting financial assurance waiver to Vineyard Wind. Despite compelling concerns raised by commenters, the “streamlining” regulations codified this decision.

No one knows what the financial future will be for wind projects and the responsible companies. Financial assurance should therefore be established when the structures are installed, not years into the future as allowed by the revised regulations. What leverage will BOEM have then?

Nordsee One substation, Germany. Rystad Energy projects 137 new power substations offshore continental Europe this decade, requiring $20 billion in total investment.