Given the investigation’s significance, not only for Vineyard Wind, but for other offshore wind projects planned or under construction, how is the delay in issuing the report acceptable?
Keep in mind that the lengthy and complex National Commission, BOEMRE, Chief Counsel, and NAE reports on the Macondo blowout were published 6 to to 17 months after the well was shut-in.
“GE Vernova is aiming to deploy small nuclear reactors across the developed world over the next decade, staking out a leadership position in a budding technology that could play a central role in meeting surging electricity demand and reducing carbon dioxide emissions.“
As the above examples illustrate, turbine blade failures, like the Vineyard Wind incident near Nantucket, are not unique to GE Vernova. GE’s rivals, Siemens Gamesa and Vestas, have also experienced serious quality control issues.
Per ReviewEconomy (2023), “Unexpected and increasing wind turbine failure rates, largely in newer and bigger models, are savaging the profits of some of the world’s biggest manufacturers, as Siemens Gamesa, GE and Vestas report heavy repair and maintenance losses.”
In light of the manufacturing challenges, all 3 companies report increased emphasis on quality control. Why has quality control to date been inadequate and how will the past problems be corrected?
Has the wind industry’s sense of entitlement, as evidenced in their tax credit, rate increase, and departure expectations, affected their safety and quality culture? Has industry and governmental wind energy promotion rushed development and compromised design and fabrication decisions? It’s time for wind developers, manufacturers, and regulators to make sure their priorities are in order.
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.