Materially Affected Party Comments to awea draft Standard 1 – 2009, “Small Wind Turbine Performance and Safety Standard”




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НазваниеMaterially Affected Party Comments to awea draft Standard 1 – 2009, “Small Wind Turbine Performance and Safety Standard”
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No. 21: Brent Summerville, Small Wind Certification Council

Number

Comment

Recommended Response

Rcmd. Action

21.1

1.3.2: This line is unnecessary: In a horizontal-axis wind turbine this equates to a rotor diameter of ~ 16 m (~ 52 ft)

This is a clarifying sentence, since 200 m2 is not easily understood by most people.

None

21.2

1.5.1 and throughout the document: IEC 61400-121 should be IEC 61400-12-1

See response to Comment 10.1

The references will be updated.

21.3

Throughout the document: check all IEC section references to the latest revision of the IEC standards.

See response to Comment 10.1

The references will be updated.

21.4

4.2: I have seen plenty of harmful tower/turbine interactions, and none of the turbines were constant/dual speed. I think this paragraph could simply state: The wind turbine and tower(s) must be shown to avoid potentially harmful dynamic interactions.

Were these problems related to dynamics or “static strength”? The committee’s experience is that dynamics, per se, have not been a problem in variable speed small wind turbines. To throw proof back on the manufacturer sets a virtually impossible requirement.

None

21.5

5.2.1: this line is already in IEC 61400-2 section 9.4.1 therefore it is unnecessary.

Need to check. My copy of -2 (Feb. 03) says 3,000 hours. If the latest version is now 2,500 hours then 5.2.1 is unnecessary.

Check latest edition of 61400-2

21.6

5.2.2: this requirement for 25 hours of operation in 15 m/s winds and above is for a Class II SWT per IEC 61400-2 section 6.2. Does this mean a manufacturer can specify any SWT class I through IV but the 25 hour requirement must meet class II requirements?

We do not reference the IEC classes.

None

21.7

5.2.3: a minimum operational time fraction of 90% is already specified in IEC 61400-2 section 9.4.2.1. OTF is also well-defined in that section. This line seems unnecessary and availability is not defined.

That is correct. But it is one of the major requirements and no harm is done by listing it in the AWEA document

None

21.8

Appendix A: L _SWCC should be L_AWEA







No. 22: Christian Martel, AeroJoule (manufacturer)

Note: This commenter edited numerous sections of the draft in addition to offering specific comments. The edited version of the standard by Mr. Martel is attached. The items below are the specific comments and those edits deemed significant enough for a response. All of the other recommended edits are not accepted because they are not deemed significant enough to warrant deviation from the “BWEA version”.

Number

Comment

Recommended Response

Rcmd. Action

22.1

Sections on Towers and Safety need more work. Comments from all parties received by the AWEA/SWCC should be compiled:

  • into the next draft and held for release until work completed

  • or, tower and safety excluded from a first official release and SWCC refer to appropriate standards elsewhere for safety and towers

Updates to the standard are anticipated

None

22.2

>>> The IEEE 1547 series of standards has many sections that are still at the Draft stage and yet many utilities refer to these draft documents in their technical requirements. This might be an approach in delivering this standard in stages, and does not exclude the SWCC from using portions or the entire AWEA Small Wind Turbine Performance, Quality and Safety Standard as a working basis. For sections that could seriously use more work such as the sections on Tower, Safety and Quality, SWCC could refer to other standards, as in the case of Towers the ANSI/EIA/TIA 222 standard.

It is common engineering practice in industry that an engineer seal, sign and date documents as being suitable. For areas that still need work this should be considered an acceptable route for SWCC.

Updates to the standard are anticipated

None

22.3

In the sections discussing installation the topic of fall circles should be discussed. It should be noted that fall circle restrictions should be similar to that imposed on:

  • Silos on farms, which are in general grouped with other buildings along with the house

  • Electric poles that are often on the lawn or end of the property; close enough for the pole or lines to fall on the home`s lawn. Contrary to electric lines, even if a turbine were to fall, once on the ground it poses no threat, whereas electric lines may still be energized.

  • Communications towers

  • Adjacent buildings with little or no allowances for separation

This is beyond the scope of the current standard

None

22.4

In the Forward to this standard (not included in this copy of the document):

  • Mention that the standard is there to ensure quality but there are few quality requirements listed for manufacturing, installation or operation

The committee takes a limited scope of the “quality” issues we cover. It is not comprehensive.

None

22.5

In the IEC 61400 series of standards, there are some design aspects, such as wind capabilities, ice loading capabilities, lightning protection, etc. If the basic certification should not include, for example, mandatory lightning protection or ice loading capability, these optional capabilities should be listed by the certifying agency should indicate on the certificate, clearly indicating to what level of ice loading, or lightning protection has been designed for.

The AWEA standard does not cover all the issues covered in the IEC standard.

None

22.6

The standard should include reference to a climate data set should be referenced to indicate where these options, and to what level, these options are mandatory. For example a wind turbine going to be installed in Florida should have a mandatory requirement for maximum lightning protection.


These options and their levels of design or protection should be listed.

This is beyond the scope of the current standard

None

22.7

Like the National Electric Code, it would be useful for all concerned to have a guide to the standards and a compilation of Best Practices or Lessons Learned, to avoid repeating history, and facilitate less technical parties in understanding the implication of the standard.

Good idea, but it will have to be developed as we get experience implementing the standard

File for future reference




Edits to Draft Standard







22.8

Revise 1.3.2: “This standard applies to wind turbines having a rotor swept area of 200 m2 or less. In a horizontal-axis wind turbine this equates to a rotor diameter of ~ 16 m (~ 52 ft) net generator or pump output equivalent to 100kW and less.”

The 200m2 limitation is in the scope of IEC 61400-2 and relates to the applicability of the simplified equations for loads in the safety analysis. The issue is under review at the IEC , where there seems to be a consensus that larger turbines should be covered. The IEC has tasked several members with developing a plan for the inclusion of larger turbines. The IEC’s goal is to have a draft international small wind standard by the end of 2009. We should not delay the current standard this improvement.

Defer issue for next edition or IEC

22.9

Revise 1.3.5: Except as noted in Sections 2.1.1, 4.2, 5.2.5, 5.2.6, and 6.1.7.1, tTowers and foundations are not part of the scope of this standard because it is assumed that conformance of the tower structure to the International Building Code, Uniform Building Code or their local equivalent will be required for a building permit. shall be designed to a recognized tower standard such as EIA/TIA/ANSI 222 rev F or G, or CSA S37.1, with proper adaptation for wind turbines, such the requirement for locking nuts, and ensuring the turbine does not cause resonance in the tower leading to premature failures. Tower designs must be sealed by a licensed professional engineer, insured and in good standing with their professional order. The engineer will have reviewed pertinent literature on tower designs for turbines.

See response to Comment 6.5

None

22.10

Eliminate 1.5.2.1, AWEA Rated Power

Comment: The parameter of power at 11.0 m/s will cause confusion in the mind of the

customer and may lead to a mistaken sense of performance. In the end only

annual energy output for a given wind resource really matters.

See response to Comment 14.1

None

22.11

Remove “(metric)” in 1.6.1

Comment: SI is based on mks units and an inertia, metric is based on cgs and gravity, the two systems are fundamentally different and not equivalent. Canada and Europe, contrary to many publications are SI. Only Russia uses some form of modified Metric system.

The existing language communicates intent effectively

None

22.12

Make 2.1.16 an option

Comment: This is an unnecessary and unfair obstacle to manufacturers that have this capability. For the given reference Weibull curve of average wind speed of 5m/s with a Rayleigh distribution, then the % of energy between the 14 m/s and 25 m/s is insignificant. Using Bergey`s excellent WindCAD tool, XL.1.R, with a tower height of 60m, anemometer at hub height, average wind speed of 5.0m/s at hub height, wind shear factor of 0.2, turbulence factor of 0% (reasonable for tall towers in many cases), the annual probability of wind speeds above 14m/s is 0.12%, representing 0.64% of annual production. This test should not be part of Base Certification but should be an OPTION.

This doesn’t seem to add any burden at all since the highest filled bin is sufficient

None

22.13

Comment on 2.2: Turbulence intensity measurement method indicated.

Comment not understood

?

22.14

Add spectral analysis requirement to 3.1.6

Comment: Spectral analysis is very inexpensive these days and would be a worthwhile document to include.

That may be true for non-statistical short-term tests, but taking octave data for a wind system is not inexpensive.

None

22.15

Add Section 3.1.7: Only approved anemometers shall be used and a calibration certificate from the manufacturer or recognized test center shall be supplied. A calibration of the anemometer at the end of the test data set acquisition shall be supplied as well.

Comment: This is not that expensive and makes a big difference as to the credibility of the test data set.

This is covered in Section 3.2 of IEC 61400-12

None

22.16

Concerning Section 4.2 (showing avoidance of harmful dynamic interactions)

Comment: How must they show this?

That is up to the technical reviewers at the certifying agency, but one possibility would be to show what frequencies they are avoiding and provide an example for a tower selection.

N/A

This concludes the comments received before the deadline (Feb. 28, 2009)




On March 23rd, Hal Link of NREL submitted detailed comments on the power performance section of the AWEA draft standard in the form of a forwarded memo to Trudy Forsyth dated August 4, 2008. The comments, per the attached memo, provide recommended edits to wording in Sections 1.5.2.4, 2.1, and 4.4. He also makes numerous suggestions on aligning the AWEA draft with the IEC performance standard, in most cases recommending that AWEA “effectively adopt” the IEC language.

The AWEA Subcommittee has reached broad agreement on these numerous distinctions and they do not rise to the level of justifying deviation from the “BWEA version”.

Not adopted. But Link’s comments will be passed on to the current active IEC small turbine standards group.
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