The primary purpose of the independent investigation is to prevent recurrences at this or other projects in the US and worldwide. Available data suggest that blade failures are far too common.
Contrary to the regulations, Vineyard Wind was authorized to begin the fabrication of facilities beforeBOEM “received and offered no objections to the their Facility Design Report (FDR) and Fabrication and Installation Report (FIR).” The approval letter is attached, and excerpts (emphasis added) are pasted below. [Note: The requirement that was then at §585.700(b) is found at §585.632 in the current regulations.]
“Vineyard Wind requests a regulatory departure from §585.700(b) requiring that fabrication of approved facilities not begin until BOEM provides notification that it has received and has no objections to the submitted Facility Design Report (FDR) and Fabrication and Installation Report (FIR). Vineyard Wind proposes to fabricate, but not install the following project elements: 1) Monopile foundations; 2) Electrical service platform; 3) Export cable; 4) Inter-array cables; and 5) Wind turbine generator facilities.
….allowing these fabrication activities to take place earlier in time would allow Vineyard Wind to adhere to its construction schedule, maintain its qualification for the Federal Investment Tax Credit, and meet its contractual obligations under the Power Purchase Agreements with Massachusetts distribution companies.
30 cfr 585.103 requires that a departure provide safety and environmental protection equal to or greater than the provision in the regulations that is waived. BOEM’s letter fails to explain how allowing fabrication to begin before fundamental design and fabrication reports are submitted and reviewed meets this test.
Perhaps even more troubling is BOEM’s response to subsequent requests by other companies to waive the FDR and FIR requirement (example). In these responses, BOEM asserts that their “current interpretation” is that no departure is needed because “the regulation prohibits only fabrication and installation activities on the Outer Continental Shelf (OCS) itself.” How does that make sense given the important activities, including the fabrication of turbine blades and other turbine components, that take place onshore?
In their letters approving the Vineyard Wind and other departures, BOEM implies that their review of these reports is unnecessary because “the design and fabrication of these components would occur under the supervision of the approved CVA” (Certified Verification Agent). That assertion misconstrues the role of the CVA. These agents, nominated and funded by the operator, provide third party oversight that is complementary to, not a substitute for, BOEM/BSEE project reviews.
According to this memo, DNV was the CVA for Vineyard Wind. Their insights on the turbine blade failure will presumably be included in BSEE’s investigation report.
“While we continue to work to finalize our root cause analysis, our investigation to date indicates that the affected blade experienced a manufacturing deviation,” said GE Vernova CEO Scott Strazik. “We have not identified information indicating an engineering design flaw in the blade or information of a connection with the blade event we experienced at an offshore wind project in the UK, which was caused by an installation error out at sea. We are working with urgency to scrutinize our operations across offshore wind. Pace matters here. But we are going to be thorough, instead of rushed.”
“It’s been 11 days since the event, and just to reinforce from the start, we have no indications of an engineering design flaw,” Strazik said. “We have identified a material deviation or a manufacturing deviation in one of our factories that, through the inspection or quality assurance process, we should have identified. Because of that, we’re going to use our existing data and reinspect all of the blades we’ve made for offshore wind. For context, this factory in Gaspé, Canada where the material deviation existed we’ve made about 150 blades.
Any comments from the CVA, assuming there was one?
Meanwhile, Nantucket will renegotiate their “Good Neighbor Agreement” with Vineyard Wind. Is this a lesson for other municipalities?
🚨 Nantucket Select Board chair Brooke Mohr just announced that the town intends to renegotiate the terms of the Good Neighbor Agreement with Vineyard Wind.
“The emergency has also revealed the inadequacy of Vineyard Wind’s coordination & communication required by the GNA” pic.twitter.com/bkaVJs6r5k
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.
Bud's Offshore Energy (BOE) 