Offshore Wind Electrical Safety Standards

Harmonization: Workshop Proceedings

Walter Musial,1 Chloe Constant,1 Aubryn Cooperman,1
Michelle Fogarty,1 Emily J. Chambers,2 Brandon W. Burke,2
Edgar DeMeo3
1 National Renewable Energy Laboratory
2 Business Network for Offshore Wind
3 Renewable Energy Consulting Services, Inc.

NREL is a national laboratory of the U.S. Department of Energy Technical Report

Office of Energy Efficiency & Renewable Energy NREL/TP-5000-76849
Operated by the Alliance for Sustainable Energy, LLC June 2020

This report is available at no cost from the National Renewable Energy National Renewable Energy Laboratory
Laboratory (NREL) at www.nrel.gov/publications. 15013 Denver West Parkway
Golden, CO 80401
Contract No. DE-AC36-08GO28308 303-275-3000 • www.nrel.gov
 Offshore Wind Electrical Safety
Standards Harmonization: Workshop
Proceedings
Walt Musial,1 Chloe Constant,1 Aubryn Cooperman,1
Michelle Fogarty,1 Emily J. Chambers,2 Brandon W.
Burke,2 Edgar DeMeo3
1 National Renewable Energy Laboratory
2 Business Network for Offshore Wind
3 Renewable Energy Consulting Services, Inc.

Suggested Citation
Musial, Walter, Chloe Constant, Aubryn Cooperman, Michelle Fogarty, Emily J.
Chambers, Brandon W. Burke, Edgar DeMeo. 2020. Offshore Wind Electrical Safety
Standards Harmonization. Golden, CO: National Renewable Energy Laboratory.
NREL/TP-5000-76849. https://www.nrel.gov/docs/fy20osti/76849.pdf.

NREL is a national laboratory of the U.S. Department of Energy Technical Report

Office of Energy Efficiency & Renewable Energy NREL/TP-5000-76849
Operated by the Alliance for Sustainable Energy, LLC June 2020

This report is available at no cost from the National Renewable Energy National Renewable Energy Laboratory
Laboratory (NREL) at www.nrel.gov/publications. 15013 Denver West Parkway
Golden, CO 80401
Contract No. DE-AC36-08GO28308 303-275-3000 • www.nrel.gov
 NOTICE

This work was authored [in part] by the National Renewable Energy Laboratory, operated by Alliance for
Sustainable Energy, LLC, for the U.S. Department of Energy (DOE) under Contract No. DE-AC36-
08GO28308. Funding provided by the U.S. Department of Energy Office of Energy Efficiency and
Renewable Energy Wind Energy Technologies Office. The views expressed herein do not necessarily
represent the views of the DOE or the U.S. Government.

This report is available at no cost from the National

Renewable Energy Laboratory (NREL) at
www.nrel.gov/publications.

U.S. Department of Energy (DOE) reports produced

after 1991 and a growing number of pre-1991
documents are available free via www.OSTI.gov.

Cover Photo courtesy of George Nichol, GE Renewable Energy

NREL prints on paper that contains recycled content.

Acknowledgments
This study was funded by the U.S. Department of the Interior, Bureau of Safety and
Environmental Enforcement (BSEE), and the Bureau of Ocean Energy Management (BOEM)
through interagency agreement number M19PG00026 with the U.S. Department of Energy
National Renewable Energy Laboratory (NREL). The authors would like to thank the many
people who contributed to the content of this report, including Cheri Hunter (BSEE), David
Nedorostek (BSEE), John Cushing (BSEE), Darryl Francois (BOEM), and Sid Falk (BOEM), as
well as other Bureau team members for their thoughtful reviews, comments, and suggestions.

We also want to thank the NREL contributors including Tiffany Byrne, who coordinated the
project schedule and deliverables, and Rebecca Green, who was instrumental in up-front
planning and coordination. Cyndi Edgley coordinated the logistics for the workshop and
provided support throughout the project. Technical editing was provided by Sheri Anstedt. Any
errors or omissions are the sole responsibility of the authors.

Lastly, we would like to thank all the workshop participants who took time from their busy
schedules to participate. The list of these participants is contained in Appendix A.

iv
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
List of Acronyms
AC alternating current
AEIC Association of Edison Illuminating Companies
ANSI American National Standards Institute
API American Petroleum Institute
ASTM American Society of Testing Materials
ATS Acceptance Testing Specifications
AWEA American Wind Energy Association
BOEM Bureau of Ocean Energy Management
BS British Standard
BSEE Bureau of Safety and Environmental Enforcement
CFR Code of Federal Regulations
CIGRE Conseil International des Grands Réseaux Électriques (International
Council for Large Electric Systems)
CSA Canadian Standards Association
CVA certified verification agent
DC direct current
DNV GL Det Norske Veritas – Germanischer Lloyd
DOE U.S. Department of Energy
EMSR Renewables Electrical and Mechanical Safety Rules (Avangrid internal)
EPRI Electric Power Research Institute
EN European norm
EMC electromagnetic compatibility
GFCI ground fault circuit interrupter
GIS gas-insulated switchgear
GW gigawatt
HVDC high-voltage direct current
ICEA Insulated Cable Engineers Association
IEC International Electrotechnical Commission
IECRE IEC System for Certification to Standards Relating to Equipment for Use
in Renewable Energy Applications
IEEE Institute of Electrical and Electronics Engineers
IP ingress protection
ISO International Organization for Standardization
ISO independent system operator
kV kilovolt
LCOE levelized cost of energy
MW megawatt
NEC National Electric Code (U.S.)
NESC National Electrical Safety Code
NERC North American Electrical Reliability Corporation
NETA International Electrical Testing Association
NEMA National Electrical Manufacturers Association
NFPA National Fire Protection Association (United States)
NREL National Renewable Energy Laboratory (United States)

v
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
NRTL nationally recognized testing laboratory (U.S. Department of
Labor/Occupational Safety and Health Administration)
OCRP Offshore Compliance Recommended Practices
OEM original equipment manufacturer
OSHA Occupational Safety and Health Administration (U.S. Department of
Labor)
PES Power & Energy Society (part of IEEE)
PPE personal protective equipment
PSCCC Technical Committee on Power System Communications and
Cybersecurity (part of IEEE PES)
RCD residual current device
RSSI Renewables System Safety Instructions
SDO standards developing organization
SGRE Siemens Gamesa Renewable Energy
SMS safety management system
S0 IEEE PES PSCCC Cybersecurity Subcommittee
UL Underwriters Laboratories
UPS uninterruptable power supplies
USCG United States Coast Guard
V volt
VAC volt alternating current
VDC volt direct current

vi
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Table of Contents
Acknowledgments ..................................................................................................................................... iv
List of Acronyms ......................................................................................................................................... v
Table of Contents ...................................................................................................................................... vii
List of Tables ............................................................................................................................................ viii
Introduction ................................................................................................................................................. 1
1.1 Caveats .......................................................................................................................................... 2
2 Key Findings ......................................................................................................................................... 4
2.1 General .......................................................................................................................................... 4
2.2 Turbines......................................................................................................................................... 5
2.3 Substations .................................................................................................................................... 6
2.4 Submarine Cables.......................................................................................................................... 7
3 Summary of Plenary Session .............................................................................................................. 8
3.1 BSEE Perspective on U.S. Offshore Wind Electrical Safety Issues ............................................. 8
3.2 Overview of Offshore Wind National Standards Initiative ........................................................... 9
3.3 U.S. Offshore Wind Recommended Practices Status.................................................................. 11
3.4 Original Equipment Manufacturer Approach to Electrical Safety Standards ............................. 11
3.5 Assessment of Secondary System Issues .................................................................................... 12
3.6 Offshore Substations and Equipment Standards and Lessons Learned....................................... 13
3.7 Overview of Electrical Safety at RWE Windfarms During Construction and Commissioning .. 14
3.8 Assessment of U.S. Electrical Safety Regulations ...................................................................... 14
3.9 Status of AWEA Working Group 5 Recommended Practices for Submarine Cables ................ 15
4 Assessment of Relevant Electrical Safety Standards for Offshore Wind Turbines .................... 17
4.1 A. Safety Design ......................................................................................................................... 18
4.2 B. Safety Procedures ................................................................................................................... 24
4.3 C. Reliability Design ................................................................................................................... 25
4.4 General Comments and Recommendations................................................................................. 28
5 Assessment of Relevant Electrical Safety Standards for Offshore Substations ............................................ 30
5.1 A. Safety Design (e.g., Lightning Protection, Switchgear, and Transformers) ........................... 30
5.2 B. Safety Procedures (e.g., Personal Protective Equipment, Lockout/Tagout Procedures, and
Equipment Guarding) .................................................................................................................. 30
5.3 C. Reliability Design (e.g., Marine Cables and Uninterruptable Power Supplies) ..................... 31
5.4 General Discussion ...................................................................................................................... 31
5.5 A. Safety Design ......................................................................................................................... 32
5.6 B. Safety Procedures ................................................................................................................... 41
5.7 C. Reliability Design ................................................................................................................... 42
6 Assessment of Relevant Electrical Safety Standards for Submarine Cables .............................. 51
6.1 Scope ........................................................................................................................................... 51
6.2 Submarine Cable Route Planning................................................................................................ 51
6.3 Submarine Cable Design, Manufacturing, and Testing............................................................... 52
6.4 Submarine Cable Installation ...................................................................................................... 54
6.5 Submarine Cable Flammability ................................................................................................... 55
6.6 Operation and Maintenance......................................................................................................... 55
6.7 Decommissioning ........................................................................................................................ 56
7 Next Steps ........................................................................................................................................... 57
8 References .......................................................................................................................................... 58
9 List of Primary Standards .................................................................................................................. 59
Appendix A. Attendee Information ................................................................................................... 66
Appendix B. Workshop Agendas ...................................................................................................... 68
Appendix C. Workshop Presentation Materials .............................................................................. 71
Appendix D. Standards Comparison Table ................................................................................... 109

vii
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
List of Tables
Table 1. List of Primary Standards Referenced in Report .................................................................... 59
Table A-1. Workshop Attendee List ........................................................................................................ 66
Table B-1. Day 1 – Plenary Session (February 11, 2020) ...................................................................... 68
Table B-2. Day 2 – Breakout Group Discussions (February 12, 2020) ................................................ 70
Table D-1. U.S. and International Offshore Wind Electrical Safety Standards Comparison Table. 110

viii
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Introduction
Offshore wind development activity is accelerating in the United States, with over 10 gigawatts
(GW) of capacity likely to be installed on the Atlantic Coast before 2030. In addition, states have
made commitments to procure over 29 GW of offshore wind. Experienced European offshore
wind energy developers are beginning to make large investments in offshore wind projects in
American waters, and some U.S. developers have submitted key design documents for regulatory
review. European offshore wind developers possess extensive experience in other geographic
markets, which greatly increases confidence that the U.S. offshore wind industry will be
successful. Nonetheless, existing U.S. electrical standards and European electrical standards are
significantly different. If not addressed, these differences could impact worker safety.

To date, there has not been a comprehensive effort to compare U.S. electrical standards to
European electrical standards in the offshore wind context. The Bureau of Ocean Energy
Management (BOEM) and the Bureau of Safety and Environmental Enforcement (BSEE), both
part of the U.S. Department of the Interior, are obligated to address these differences as part of a
safe and efficient project approval process.

The federal regulations governing the development of offshore wind facilities, 30 Code of
Federal Regulations (CFR) § 585, were published in 2009. These regulations outline the
development process for an offshore wind project in U.S. waters. However, because the U.S.
offshore wind industry was less mature in 2009, adequate U.S. standards did not exist. For this
reason, no specific standards were incorporated by reference into 30 CFR § 585. Rather, the
regulations prescribe that “best practices” be used, with the expectation that these practices
would evolve as the U.S. offshore wind industry gained experience.

The formal process of defining “best practices” for the U.S. offshore wind industry has been
undertaken by the U.S. wind industry (sponsored jointly by the U.S. Department of Energy
(DOE), BOEM, and BSEE) through the development of recommended practices under a
standards development process established by the American Wind Energy Association (AWEA),
pursuant to an agreement with the American National Standards Institute (ANSI). This formal
AWEA/ANSI approval process is critical for the acceptance of standards by the regulators. U.S.
ANSI-approved consensus standards and guidelines include vital procedural safeguards that
guide regulators with respect to project design and approval. These consensus standards can also
be referenced in potential future revisions to 30 CFR § 585. If appropriate, they can also be
explicitly quoted by BOEM/BSEE in 30 CFR § 585 or other regulations.

This AWEA/ANSI U.S. offshore wind standards initiative began in September 2017. The
AWEA Wind Standards Committee formed an offshore wind subcommittee to oversee the
development of five working groups to address deficiencies in the current suite of U.S. offshore
wind standards, including electrical safety. This new suite of recommended practices will (a)
help clarify design requirements for developers, and (b) enable BOEM/BSEE to create
regulations that better reflect industry best practices; but publication is not expected until late
2021. For the near term, there is insufficient guidance in the public domain to establish best
practices for U.S. offshore projects.

1
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
The electrical infrastructure of an offshore wind power plant is extremely complex. To
adequately cover all the electrical subsystems, a broad range of skills from varying disciplines is
required. In the interest of minimizing delays to offshore wind project approvals, BOEM/BSEE
commissioned the National Renewable Energy Laboratory (NREL) to convene a group of
technical experts and conduct a workshop to help identify relevant issues. The workshop
proceedings (this report) are intended to document these matters, such that regulators can use this
report as guidance while the formal consensus recommended practices are being developed
through the AWEA/ANSI U.S. Standards Initiative.

To execute the workshop and write these proceedings, NREL formed a team including internal
staff, technical staff from the Business Network for Offshore Wind, and NREL consultant Ed
DeMeo, who is an experienced wind technology expert. The NREL team identified the world’s
most qualified subject matter experts possessing specific skills vital to our understanding of
offshore wind facility electrical design and safety, and the harmonization of European and U.S.
standards. These experts were drawn from the membership of the AWEA/ANSI Offshore
Compliance Recommended Practice (OCRP) working groups, relevant AWEA wind standards
committees, recommendations from BOEM and BSEE, and the U.S. offshore wind supply chain
and developer community. More than 50 technical experts from a diverse range of organizations
gathered on February 11―12, 2020, at NREL’s Flatirons Campus near Boulder, Colorado.
During the course of the workshop, these experts shared their knowledge of the constituent
electric systems that together comprise an offshore wind power plant from the turbines and
offshore substations (i.e., electric service platform) to the subsea electric cables and grid
connections.

The workshop organizers compiled input received from workshop presentations and verbal
discussions into this set of proceedings, with the primary goal of publishing these proceedings as
a near-term reference to inform project design and approvals. In addition, we envision that these
proceedings may help inform U.S. industry recommended practices, which are under
development by the AWEA Wind Technical Standards subcommittee.

1.1 Caveats
This document represents the viewpoints of a wide variety of subject matter experts on the topics
of electric safety in offshore wind plant design, installation, and operation. Although the authors
made every attempt to document and translate the views expressed during the workshop and peer
review process, the interpretations are those of the authors and may not convey the intentions of
the attendees in all cases.

The complexity of the design and operation of the electrical systems of an offshore wind farm
are immense, requiring the application of dozens of standards. Therefore, the recommendations
made herein represent a first step toward reducing the conflicts that may arise during these
processes; however, the authors make no claim that these recommendations will eliminate
conflicts or safety concerns. All projects must engage certified verification agents as required by
BOEM and BSEE to oversee project development, and, where appropriate, retain the services of
a third-party owner’s engineer.

It is important to note that there are several instances in which more than one group at the
workshop addressed the same topic but may not have identical guidance. In some instances, the

2
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
recommendations may conflict. In these cases, we attempted to provide both viewpoints to allow
for the possibility that there may be multiple pathways to achieving the necessary levels of
safety. In other cases, these viewpoints may not be conflicting but may address separate issues
on the same topic. For the full scope of the workshop proceedings on a specific topic, reference
the topic within each of the sections for the corresponding discussion and recommendations from
the turbine, cables, and substations groups, respectively. In all cases where two different
viewpoints were offered, we recommend considering both opinions and the developer and its
certified verification agent (CVA) conduct their own thorough investigation of the issue.

3
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
2 Key Findings
The workshop’s presentations and discussions benefitted from the extensive breadth and depth of
expertise of the workshop participants. Major findings and key insights from the workshop
include the following, which are organized into four categories that parallel the section headings:
General, Wind Turbines, Substations, and Subsea Cables.

2.1 General
• The U.S. offshore wind industry is progressing toward construction and operations sooner
than the availability of supporting standards, guidelines, and regulatory frameworks. For that
reason, interim regulatory guidelines are needed until comprehensive consensus standards
can be finalized. The Offshore Wind Electrical Safety Standards Harmonization workshop
delivered informed input to provide this preliminary guidance. Workshop attendees
commended BOEM/BSEE for convening this meeting and recommended continuing
interactions among BOEM, BSEE, the industry, and those pursuing standards harmonization.
Ongoing engagement is important, as guidelines and best practices will need to be updated
and refined as the domestic offshore wind sector advances. Recognizing that more formal
guidance for U.S. projects may not be available until late 2021, the overall aim is to provide
guidance to help proposed offshore wind projects move forward in the absence of definitive
U.S. standards.
• A standards comparison table provided to participants in advance of the workshop helped
focus workshop discussions. This table was drafted by BSEE technical staff and reviewed by
several members of the offshore industry prior to the workshop. The table, along with initial
feedback from the industry, gave rise to a number of questions considered by the workshop
participants both during and after the workshop. Through discussion of the table, a number of
standards—both U.S. and European—were added or deleted, and appropriate commentary
was added to offer interim guidance. That table, amended to reflect the workshop
deliberations, is included in Appendix D (Table D-1).
• An initial objective of the workshop was to identify and resolve inconsistencies
(harmonizing) among U.S. and European standards addressing similar topics. However, the
workshop discussions generally revealed differences rather than inconsistencies. In many
cases, the differing standards may achieve essentially the same objective (i.e., a similar level
of personnel and equipment safety). See Section 2.2 for further discussion.
• Strong support was broadly expressed for performance-based as opposed to prescriptive
standards. The attendees generally felt that applying prescriptive standards may impose costs
without increasing safety.
• Workshop participants were highly qualified in the topical areas being considered, ranging
from experts in equipment and safety to certification, with a variety of technical and cultural
workplace perspectives.
• In general, worker safety protocols and technical design decisions inform each other; they
cannot be separated without compromising one or the other. Therefore, we recommend
ongoing and expanded communication between technical design engineers and safety
cultures. Both perspectives need to be well-represented and considered together in
deliberations on project economics.
• In general, a consensus emerged that U.S. standards, if or where applicable, should be
applied. However, if adherence to an International Electrotechnical Commission (IEC)

4
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 standard results in the same level of safety, then the IEC standard should also be acceptable.
Code mixing should be avoided and ensuring consistency in the use of codes, standards, and
practices across the complete electrical system (e.g., the onshore substation, offshore
substation, and wind turbine electrical interface) is paramount. It will be incumbent upon
project developers to demonstrate to the CVA and regulatory bodies that an adequate level of
safety will be achieved. Workshop participants indicated that the use of an IEC standard in
place of a corresponding U.S. standard is more likely to occur in the case of wind turbines
that already have IEC-type certification, or for submarine cable systems, for which no U.S.
standard exists, than for substations, which are project-specific, custom-designed
installations.
• Competition among standards organizations (e.g., Institute of Electrical and Electronics
Engineers [IEEE], IEC, AWEA) impedes standards harmonization. These standards
developing organizations (SDOs) appear increasingly reluctant to defer to similar standards
developed by another SDO. In the past, standards bodies collaborated on producing
standards, but this has become less common. Workshop participants would welcome greater
cooperation and less competition.
• The terms “high,” “medium,” and “low” voltage are subjective and prone to
misinterpretation. The terms refer to different voltage ranges in various standards and can
also vary across jurisdictions. Workshop participants emphasized that when referencing a
standard or procedure, it is important to verify that the range of voltages covered by that
standard or procedure is appropriate.
• Wiring systems and nonsubmarine cables should not be overlooked. BOEM/BSEE or AWEA
should identify a group to be responsible for reviewing wiring and cabling topics and
determining which standards are most applicable.
• Although grid integration was not the focus of this meeting and is itself a separate and
significant topic, it is important to realize that, with injections of 1 GW or more at the land-
based point of interconnection, offshore wind power plants will be subject to the North
American Electric Reliability Corporation’s (NERC’s) jurisdiction. Offshore wind facilities
will impact system reliability of the land-based receiving independent system operator (ISO)
or utility. As a result, additional requirements and regulatory standards on offshore wind
systems may be imposed because Federal Energy Regulatory Commission/NERC and
regional organizations like the Northeast Power Coordinating Council define regulatory
requirements focused on the bulk energy system and bulk power system, reliability, and
cybersecurity.
• The industry should move away from IEC 61400-22, which is superseded by IEC System for
Certification to Standards Relating to Equipment for Use in Renewable Energy Applications
(IECRE) OD-501 and -502. Many turbine suppliers have already adopted the new IECRE
system, and it is expected that most offshore turbines will be required to have IECRE
certificates going forward. Therefore, IEC 61400-22 is an outdated standard. IECRE OD-501
and –502 are referenced in Section 2.2 and Section 2.3.

2.2 Turbines
The following statements summarize the notable, key findings from the turbines group workshop
discussions:

5
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
• Turbines are generally purchased “off the shelf,” with a suite of components based on IEC-
type certification. Replacing components to meet U.S. standards is a design undertaking for
each model and imposes costs for manufacturers. This practice of replacing components for
compliance should not be required if the project developer provides justification that the
turbine, as currently designed, meets the requisite level of safety. Some participants in the
turbine group were more inclined to favor international standards, whereas others advocated
for U.S. standards, as done in land-based wind. Participants also expressed that, if a
component or subsystem has already been certified by a nationally recognized testing
laboratory (NRTL) in the United States or as part of an IEC-type-certification process, it
should not be required to undergo repeated evaluation and testing.
• To illustrate the previous finding, consider spacing of equipment cabinets with dangerous
interior voltages. In the United States, the Occupational Safety and Health Administration
(OSHA)under the assumption that dangerous voltages are exposed when the cabinet is
openedrequires clearances around cabinets. This requirement generally dictates larger
clearances to aid maneuverability of service personnel. However, IEC standards do not allow
dangerous voltages to be exposed within cabinets. For example, exposed voltages can be
accessed with a suitable probe, but not with a finger. As a result, the hazard that is addressed
by the OSHA standard does not exist in a system designed pursuant to IEC standards, so the
spacing requirement can be relaxed.
• As a corollary to the two previous findings, applying an IEC standard rather than a
corresponding U.S. standard simply to reduce costs should only be acceptable if it can be
demonstrated that safety of personnel and equipment are not compromised.
• Offshore turbine technicians will require a higher level of training to enter and perform work
on an offshore turbine than technicians that are trained for land-based turbines. This
additional training should anticipate and cover specific differences between the offshore
wind power plant’s electrical design and the base training received by U.S. electrical
workers.

2.3 Substations
The following statements summarize the notable, key findings from the substations group
workshop discussions:
• Because of the similarity between offshore wind substations and offshore oil and gas
platforms, on most issues, the substation group defaulted to American Petroleum Institute
(API), ANSI, and IEEE standards. The rationale is that technicians involved in the
construction and operation of substations will primarily have U.S. backgrounds, training, and
experience. Also, major suppliers of electrical components are generally able to meet most
global standards for multiple scenarios. Each substation is a custom product, so sourcing
components that comply with U.S. standards should not impose undue hardship or costs.
• API Recommended Practice14F, “Design and Installation of Electrical Systems for Offshore
Production Platforms” (see 30 CFR § 250.114(c)), was frequently identified as an applicable
U.S. standard because specific electrical safety requirements for electrical installations
located offshore are covered. These include recommendations for low- and medium-voltage
switchgear, heliports, weather decks, lighting, transformers, and all types of electrical
equipment and installations for offshore applications. Other participants observed that the
API electrical standards are relevant for some aspects of the offshore wind substation, but
that they were originally intended for offshore oil extraction platforms, which may have

6
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 different electrical design requirements than offshore wind substation platforms. Reference
was also made to API RP 14C, “Analysis, Design, Installation, and Testing of Basic Surface
Safety Systems for Offshore Production Platforms” (see 30 CFR § 250.1628(c)).
• Different approaches emerged concerning workforce utilization. Some companies use the
same technicians to service land-based and offshore equipment, whereas others have separate
specialized land-based and offshore workforces. A prescriptive standard may not be required
in these instances, as this is more a question of operational strategy. However, it was
emphasized during the workshop that inconsistencies (code mixing) across codes and
standards can result in unintended safety-related consequences during
operation/maintenance.
• U.S. and international standards differ on the need for visual confirmation of contact status
(i.e., open or closed) for switchgear. This difference needs to be addressed to inform
substation design and construction. In general, offshore wind electrical installations and
switching equipment must be designed and installed with the appropriate arc flash protection
and facilities to comply with OSHA lockout/tagout requirements.

2.4 Submarine Cables

The following statements summarize the notable, key findings from the cables group workshop
discussions:

• Submarine cables for voltages up to 60 kilovolts (kV) are covered by IEC 63026, which was
recently published.
• Existing U.S. standards apply to components of submarine cables, but there is no
comprehensive U.S. standard for the entire submarine cable system. IEC standards describe
methods for testing and type-certifying complete cable systems but need to be combined with
Conseil International des Grands Réseaux Électriques (CIGRE) recommendations for
electrical and mechanical testing of submarine cables. Acceptance of the relevant IEC
standards is recommended.

7
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
3 Summary of Plenary Session
This section summarizes the information exchanged during the plenary session of the workshop,
which took place on February 11, 2020. The purpose of the plenary session was to provide
background on the workshop objectives, and to allow members from the industry to present their
unique, and sometimes divergent, perspectives on the issues. During the plenary session, eight
speakers presented their viewpoints on issues relevant to electrical design and safety standards
for offshore wind facilities, and how they are adapting and attempting to comply with U.S.
market conditions.

3.1 BSEE Perspective on U.S. Offshore Wind Electrical Safety Issues

A presentation was made by Cheri Hunter, BSEE renewable energy program coordinator, Darryl
Francois, BOEM Office of Renewable Energy Programs, and David Nedorostek, BSEE senior
electrical engineer. The purpose of this introductory presentation was to set the stage for the
workshop, and to explain why it was not only necessary but urgent to develop interim regulatory
guidelines for U.S. offshore wind installations. The presentation covered the federal regulatory
background, noting that the Department of the Interior is the federal agency that will be
principally responsible for regulating and enforcing safety and health requirements for renewable
energy projects located on the Outer Continental Shelf.

Offshore wind projects traditionally follow international standards, but conflicts may arise if
consideration is not given to the prevailing national and local standards. BSEE and BOEM have
a due diligence requirement to ensure that the safest standards are used, and the public expects
these agencies to conduct a robust comparison of U.S. standards with a focus on safety.

BOEM and BSEE are separate entities but work closely together to review industry submissions,
such as construction and operation plans, facility design reports (FDRs), and fabrication and
installation reports related to offshore wind project development within the approval process.

They noted that U.S. offshore wind recommended practices are currently under development
through AWEA’s Offshore Wind Standards Initiative, but it is expected that these ANSI-
approved recommended practices will not be available until the end of 2021. As such, BSEE
created a comparison of U.S. versus international electrical safety standards to assist
BSEE/BOEM engineers in performing a comprehensive assessment of project electrical designs
for the first U.S. offshore wind projects. This resulted in the creation of the Electrical Safety
Standards Comparison Table (hereafter “the table”), which included a list of standards that was
edited and distributed by the NREL team prior to the February 2020 workshop. The original
table was intended to be a starting point for establishing U.S.-specific expectations for offshore
wind electrical safety. BSEE indicated that the table will continue to evolve through the feedback
received from the February 2020 workshop proceedings and as BSEE, BOEM, and the offshore
wind industry identify best practices through experience. As such, the table was updated by the
authors of this report based on the feedback received through this workshop and is presented in
Appendix D.

The table identifies available standards from the United States, Europe, Canada, and harmonized
standards that may incorporate international- and U.S-specific requirements. It focuses on what

8
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
BSEE and BOEM have initially identified to be the most safety-critical electrical equipment and
procedures. The table is subdivided into the following three categories:
• Safety Design (e.g., arc flash, switchgear, and transformers)
• Safety Procedures (e.g., personal protective equipment, lockout/tagout procedures, and
equipment guarding)
• Reliability Design (e.g., marine cables and uninterruptable power supplies).
Workshop participants reviewed the table and considered the following sample questions
including, but not limited to:
• Does the list of standards focus on most safety critical electrical equipment?
• Is critical electrical equipment categorized properly?
• Are all the applicable electrical safety standards for each electrical component captured?
• Should certification be done by a NRTL for functionality and performance?
This initial BSEE/BOEM presentation helped frame the discussions throughout the remainder of
the workshop. The presentation concluded that the next steps were to continue a peer review of
international and U.S. electrical standards by the experts in attendance and to document these
discussions. In this manner, these workshop proceedings can inform near-term U.S. project
development and the ongoing development of ANSI-approved recommended practices for U.S.
offshore wind.

3.2 Overview of Offshore Wind National Standards Initiative

Walter Musial is a principal engineer at NREL and is the chairman of the AWEA Offshore Wind
Standards Subcommittee, which is also known as the Offshore Wind Technical Advisory Panel
(OWTAP). He presented an overview of the history of U.S. offshore wind recommended
practices and the current efforts to develop new ones under the AWEA/ANSI rules. The U.S.
offshore wind standards development effort is jointly sponsored by BOEM and DOE and is
further supported by the efforts of the Business Network for Offshore Wind and AWEA.

From 2009 to 2012, the U.S. offshore wind industry, in collaboration with BOEM, NREL, DOE,
and AWEA, developed a roadmap from existing standards to facilitate the development of “best
practices” for U.S. offshore wind installations, known as the AWEA OCRP 2012. Over 50
members of the offshore wind industry participated in the development of AWEA OCRP 2012,
which covers all aspects of fixed-bottom offshore wind facility development, from design
through to decommissioning (American Wind Energy Association. 2012). OCRP refers to over
100 standards, guidelines, and technical specifications. After its publication in October 2012, it
became the de facto reference for offshore wind development in the United States and has been
used as an informative framework for regulators, developers, and CVAs.

However, for several reasons, AWEA OCRP 2012 no longer satisfies the regulatory
requirements for BOEM/BSEE and the offshore wind development community. First, when it
was written, the formal process for review and approval by ANSI had not yet been adopted by
AWEA; this approval process is critical for the acceptance of standards by the regulators, and
allows the standards documents to be referenced by BOEM/BSEE if appropriate. In addition, the
scope of AWEA OCRP 2012 was too narrow. It did not cover key aspects of the current U.S.
offshore wind industry such as floating wind turbines. Finally, in addition to the noted missing
elements in AWEA OCRP 2012, the document is over 8 years old and does not adequately

9
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
reflect the knowledge gained through the installation of over 27 GW of offshore wind globally,
and does not capture the extensive U.S. project development experience that has occurred since it
was written.

The AWEA Offshore Wind Standards Subcommittee was formed in 2017 to oversee the
initiative to upgrade the U.S. offshore wind recommended practices. On October 23, 2017, the
AWEA Offshore Wind Standards Subcommittee met for the first time, formed five working
groups, and assigned two conveners to each working group. These groups and their conveners
are:

• OCRP 1 - Working Group 1: AWEA OCRP Edition 2, under the leadership of Rain Byars
and Graham Cranston
• OCRP 2 - Working Group 2: AWEA U.S. Floating Wind Systems Recommended Practices,
under the leadership of Lars Samuelsson and Leif Delp
• OCRP 3 - Working Group 3: AWEA U.S. Offshore Wind Metocean Conditions
Characterization Recommended Practices, under the leadership of Mike Drunsic and Lorry
Wagner
• OCRP 4 - Working Group 4: AWEA U.S. Recommended Practices for Geotechnical and
Geophysical Investigations and Design, under the leadership of Matt Palmer and Mathieu
Guinard
• OCRP 5 - Working Group 5: AWEA Recommended Practices for Submarine Cables, under
the leadership of Georg Engelmann and Bob Hobson.
Each recommended practice will provide a roadmap for U.S. offshore wind development in its
respective area, with a view toward adding transparency and consistency to the regulatory
approval process, as this can provide benefits to developers, regulators, and the general public.
These nationally focused recommend practice documents will account for the unique offshore
conditions on the U.S. Outer Continental Shelf, but they will also be applicable to potential
offshore wind installations in state waterways (e.g., the Great Lakes). They will provide
reasonable requirements for commercial offshore development and will cover a range of project
development activitiesproject design, construction, and deployment practices; operations;
safety; inspection; and decommissioningwhile anticipating the new and quickly evolving
nature of offshore wind technology. This suite of offshore recommended practices will help
clarify the requirements for developers beyond what was provided by AWEA OCRP 2012 and
will enable BOEM and BSEE to adopt regulatory requirements that better reflect industry best
practices.

The recommended practice documents that will result from this effort will clarify the
requirements for offshore wind in the United States. However, they will not be publicly available
for reference or citation until late 2021. Therefore, the results of this workshop will serve, in part,
as interim guidance until these OCRP documents are published. OCRP-1 and OCRP-5 cover
particularly relevant parts of this offshore electrical safety compliance and were described in the
plenary session later by members of those committees: Albert Fisas and Bob Hobson,
respectively.

10
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
3.3 U.S. Offshore Wind Recommended Practices Status
Albert Fisas, advanced technologies manager for offshore wind at GE Renewable Energy,
presented an overview of the electrical content in the draft “Offshore Compliance Recommended
Practices (OCRP)” maintenance document, which will be the second edition that supersedes and
replaces AWEA OCRP 2012. This revision is currently underway, with over 100 members from
the international offshore wind community contributing. Albert is a key member of the
development team and was representing the working group in the absence of its conveners. The
working group plans to release a draft for public review later this year. A draft of the current
version of this OCRP-1 RP was distributed among the participants of the workshop for review.

Albert pointed out that electrical design and safety standards are covered in several parts of the
revised draft OCRP document, including in some of the general sections (i.e., introductory
content, design basis, standards hierarchy, terms and definitions, references). Additionally, major
references reside in the design sections of Chapter 5, including:

• Section 5.6 (Design of Offshore Wind Turbine)

o Section 5.6.4 (Electrical Design)
o Section 5.6.5 (Design for Occupational Health and Safety)
• Section 5.7 (Design of Offshore Substation)
o Section 5.7.4 (Electrical Design)
o Section 5.7.5 (Design for Occupational Health and Safety).
Note that submarine cables are addressed in OCRP-5, which is currently being developed by
working group 5.

The intent of the OCRP-1 working group and the participants of the electrical safety standards
harmonization workshop was to collectively align with the recommendations within OCRP-1.
However, workshop participants were not constrained by the content of the OCRP-1 edition 2
draft, which is still under development. As such, the OCRP-1 working group may potentially
benefit from the additional insights revealed during the 2-day workshop. We suggest that the
ORCP-1 consider new references to documents recommended by workshop participants as
appropriate for offshore wind facility installations.

3.4 Original Equipment Manufacturer Approach to Electrical Safety

Standards
Samuel Hawkins, chief engineer for offshore wind emerging markets at Siemens Gamesa
Renewable Energy (SGRE), gave a presentation titled, “OEM Approach to Electrical Safety
Standards.” SGRE is the world’s offshore wind turbine leader in terms of total installed offshore
capacity. A brief company overview was provided, which included a description of their new
turbine, the SG 11.0-193 DD, which is scheduled for commercial deployment in 2022.

Samuel introduced the methods that SGRE uses for selecting design standards, which includes
the definition of the company’s global design basis, and a formal evaluation and adaptation for
the U.S. market. The process commences early in the design phase, to develop and document the

11
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
design basis for each module of the system. SGRE incorporates best practices from previous
designs, and regularly updates the process to account for fleet performance, reliability, safety,
changes and improvements in technology, and revisions and updates to design standards. They
have a listing of standards applied to each product, which is used during the type certification
process. These standards cover a wide range of topics, including electrical design and safety.
Health, safety, and environmental design requirements are created, reviewed, and distributed to
design teams.

In summary, for general global supply, SGRE takes the following actions for offshore wind
turbines:

• Turbine designs comply with international codes and standards

• Turbine models are type certified against this design basis, in accordance with IECRE OD
501.
Additional actions taken for offshore wind turbines in the United States include:

• Evaluating the design basis relative to OSHA regulations, United States Coast Guard
(USCG) regulations, and leading standards from IEEE, National Fire Protection Association
(NFPA), and others to meet safety objectives
• Evaluating the gaps between the global design basis and U.S. codes and standards on a case-
by-case basis. If safety can be improved with reasonable effort, design modifications are
made.
The type certificate serves as confirmation that the turbine design is compliant with its design
basis.

3.5 Assessment of Secondary System Issues

Steven Kunsman, director of product management and applications at ABB, delivered two
presentations during the plenary session. This is a general summary of both.

ABB is a major global supplier of large electrical hardware components that are used in multiple
parts of offshore wind farms. As a global supplier, they can comply with any standards
requirement. In ABB’s view, it is more important to have a transparent specification than to align
with a given set of standards.

Steve covered several topics that are relevant to the offshore wind industry as it enters the U.S.
market. Some of the key points indicated were:

• Offshore wind farms will need to comply with NERC critical infrastructure protection
regulations. The design impacts of this necessity should be considered.
• Offshore substations will likely be maintained by U.S.-trained electricians and high-voltage
electrical workers, the same as for land-based substations. As such, there is a strong need to
standardize equipment and training around U.S.-based standards (e.g., National Electric Code
[NEC]) to avoid possible safety concerns.
• From ABB’s experience, BSEE will likely use OSHA standards first if applicable. BSEE will
consider international standards and codes if they are more applicable.

12
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
• IEC 60255 series have been harmonized with IEEE C37.90 series standards, which is a
positive step. However, this IEC/IEEE cooperation does not appear to be continuing in the
future. IEC and IEEE are competing more, which is leading to less harmonization and more
potential conflicts.
• Steve also chairs the IEEE Power & Energy Society Technical Committee on Power System
Communications and Cybersecurity (PSCCC) Cybersecurity Subcommittee (S0). He
indicated that cybersecurity standards, such as CIP-013-1, will be enforceable commencing
July 2020; he cautioned the group not to overlook or downplay the importance of this
growing issue.

In 2015, Moffatt & Nichol published a report (https://www.boem.gov/723AA), funded by

BOEM, that recommended standards to be used for offshore substations. Prior to this workshop,
there was considerable interest in understanding whether this report had merit and should be used
as a guide. The presentation by Steve Kunsman and subsequent discussion indicated that this
report contained a collection of lessons learned from the Cape Wind offshore substation
development process. Although the report captured all of the standards that were (or should have
been) used for Cape Wind, the general group discussion indicated that the report may be biased
toward structural design elements, and that some portions pertaining to electrical design and
safety may be outdated.

3.6 Offshore Substations and Equipment Standards and Lessons

Learned
George Nichol, project director, Grid Solutions for GE Renewable Energy, gave a presentation
focused on his experience with substation design and implementation, totaling 4.7 GW of
offshore wind grid connections. His presentation provided background information related
specifically to offshore wind substations that GE has deployed in recent years in the United
Kingdom. He elaborated on the project development steps, and provided an overview of the
Galloper substation, a 336-megawatt (MW), 33/132-kV, offshore substation. This substation and
land-based delivery system features a state-of-the-art dynamic reactive compensation system
located at the land-based substation near Leiston, Suffolk, in the United Kingdom, which is
representative of new project experience. The benefits of this system include appropriate voltage
control and reactive power support for the Galloper Wind Farm in compliance with U.K. grid
code requirements.

Although the substation represented only a fraction of the project’s overall capital cost, the
presentation stressed the importance of lowering cost to achieve competitive levelized cost of
energy (LCOE) strike prices in the $50/megawatt-hour range. Going forward, the research
indicates that standards will continue to evolve as more offshore wind is connected to the grid.
Grid codes will reflect changing requirements resulting from modeling, testing, and
demonstrating the technology. Developers will need to pay more attention to the specification of
nonstandard items and focus on efforts to continuously lower LCOE. In all cases, however,
safety is essential and has the highest priority.

13
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
3.7 Overview of Electrical Safety at RWE Windfarms During
Construction and Commissioning
Hendrik Berends, senior electrical engineer at RWE, gave an overview about the electrotechnical
project structure used for installation and commissioning of some selected RWE wind farms
according to German electrical safety rules. He first provided some background on the recent
merger between EoN and Innogy to form RWE, which is now the fourth largest developer of
renewable energy projects worldwide. He reviewed RWE’s internal commitments to health and
safety. Henrik reviewed RWE’s experience with two German offshore wind installations:
Arkona, a 385-MW wind farm commissioned in 2019 using 6.0-MW Siemens turbines and
located in the Baltic Sea; and Amrumbank offshore wind farm, which was commissioned in
2015, using Siemens 3.6-MW turbines and located in the North Sea. He noted that all substations
are normally unmanned in accordance with DNV GL OS J-201/ST-0145 and were fully
commissioned in the harbor prior to load-out.

3.8 Assessment of U.S. Electrical Safety Regulations

Joseph Cunningham, health & safety compliance manager for ScottishPower (part of Avangrid
Renewables), presented an overview of Avangrid’s internal Renewables Electrical and
Mechanical Safety Rules (EMSR), which were established in the United Kingdom, and then
outlined the challenges for U.S. implementation. He began by describing their safety rules,
which enable Avangrid to meet minimum legal obligations, but did note that the EMSR often
exceed minimum legal requirements. These rules are mandatory for all work conducted on sites
where voltage exceeds 1,000 volts (V) alternating current (VAC), or 1,500 volts direct current
(VDC). The EMSR are applied to ensure persons working on or near electrical/mechanical
equipment are safeguarded from inherent dangers arising from those systems. The EMSR
provide an overarching “philosophy” handbook and are supported by renewables system safety
instructions. The EMSR may have some parallels with the emerging U.S. federal regulatory
system, but further comparisons are not made in this report.

Joseph’s presentation identified the following challenges to U.S. implementation:

• Safety control boundaries between the developer and the contractor may vary. In the United
States, The NEC classifies any use of electrical service less than 1,000 V as low voltage.
• Potential conflicts may arise between a developer’s or operator’s established EMSR and
wind turbine contractor’s safety system of work/safety rules. This may be especially true if
BOEM/BSEE establish different requirements for their safety management system (SMS) as
part of the permitting and approval process.
• Some conflicts might also be expected in establishing Safety Control Boundaries with a
turbine supplier.
• Evaluation of competencies, training, and certification is needed for safety team members
managing the developer’s safety management system and should consider any union
requirements.
• U.S. license requirements for high-voltage switching in offshore wind farms (including land-
based assets) and time required to obtain them may present some conflicts.
• Compatibility issues may arise with the “host” ISO’s safety rules at the connection boundary.

14
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
• Other potential issues may arise as a result of differences in the regulations, such as the use
of U.S. ground fault circuit interrupters (GFCI), which are more sensitive than the European
residual current devices (RCDs).

3.9 Status of AWEA Working Group 5 Recommended Practices for

Submarine Cables
Bob Hobson, principal designer at NKT HV Solutions and a co-convener of the AWEA Offshore
Wind Working Group on submarine cables, gave a presentation on the progress and content of
the draft recommended practices document, titled “Recommended Practices for Design,
Deployment, and Operation of Submarine Cables in the United States (OCRP-5).”

Bob recognized his co-convener Georg Engelmann, chief operating Officer at Excipio Energy,
and Darin Lawton from Burns and McDonnell, who is the secretary for the OCRP-5 working
group. The working group has deliberated over the correct framework to specify best practices
for power cable systems in offshore wind farms. Cables are a critical part of an offshore wind
installation; accordingly, they require proper attention over the entire lifecycle of the power
plant, from conception to decommissioning.

Bob acknowledged that the OCRP-5 working group does not need to “reinvent the wheel,” as
there are ample existing global standards covering the relevant technical requirements. The
working group need not write new standards but must simply provide a roadmap for the existing
standards. The short-term approach of the working group is to adhere to functional performance-
based standards.

For the following reasons, the working group has concluded that IEC standards should be
preferred:

• IEC-based standards are based on performance and test the complete cable system.
• IEC requires prequalification testing of the entire cable system, and type testing of the entire
cable system, both electrical and mechanical.
• IEC standards have an established track record of success in Europe for both submarine and
offshore wind industries.
• IEEE and other U.S. standards are more prescriptive, and component-based, especially for
power cables.
• The philosophy of U.S.-based standards is to allow interchangeability of components and
manufacturers in a cable system.
• IEC standards are applicable for low-, medium-, and high-voltage systems based on years of
development and implementation experience.
The OCRP-5 working group will provide a roadmap to best practices for export cables and
interarray submarine cable systems. The working group identified more than 34 standards
organizations and more than 127 standards that may apply to submarine power cables. The goal
for the OCRP-5 recommended practice is to provide a roadmap, or reference, that leads the
reader to the appropriate recommended standard. For example, “Cable Ampacity in Duct”
designers should go to this standard as described by the OCRP-5 for details on how it should be
applied. The OCRP-5 recommended practice will provide a list of standards with definitive
useful information that can be directly referenced. It will also provide a list of standards that

15
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
reference other standards containing instructive information. The recommended practice has
approximately 100 subject headings related to the “cradle to grave” of an offshore wind facility’s
submarine power cable system. The OCRP-5 working group has more than 100 members
contributing from a diverse group of users, of which approximately 20 attend their biweekly
calls.

The working group expects to have a draft for AWEA Offshore Wind Technical Advisory Panel
internal review by summer of 2020, with the final document ready to go out for public comment
later in 2020 following the AWEA/ANSI consensus standard development approach.

Bob then discussed more general trends and challenges associated with offshore wind submarine
power cables. He noted that offshore wind project sizes are growing at a rapid rate and the cable
system designs will be challenged to keep up. For example, the Block Island Wind Farm, the
only operating offshore wind project in the United States, is a 30-MW project. Projects are now
being bid between 800 and 1,100 MW. Even larger projects are being planned, with the world’s
largest offshore wind farm being Dominion Energy’s 2,640-MW proposed array. In addition,
bigger turbines, 12 MW and larger, are being developed; these machines will challenge
conventional array cable systems. Floating wind turbines with dynamic cables and deeper water
are also on the horizon and require additional testing and development. Higher-voltage AC array
cables are moving quickly to market at 66 kV currently. Future DC array cables are possible at
even higher voltages. As distances from shore continue to increase, we will need longer export
cables. New high-voltage alternating current and high-voltage direct current (HVDC) offshore
transmission grid systems will also be needed. We will need standards that work for both the
developer and U.S. regulators, like BSEE and BOEM.

With over 29 GW of U.S. state-level offshore wind commitments, U.S. demand in 2030 is
predicted to be 691 km/year (430 miles/year) to 1,113 km/year (692 miles/year). European
demand for offshore cables in 2030 is estimated at 1,800 to 2,000 km/year. Lloyd Warwick
International Claims Database (2002―2019) reports that 83% of the total value of offshore wind
insurance claims concern cable failures, so it was stressed that the U.S. offshore wind regulatory
system take steps to ensure this record of cable failures is improved upon for U.S. installations.

16
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
4 Assessment of Relevant Electrical Safety Standards
for Offshore Wind Turbines
The Turbines Breakout group’s (hereinafter, “the group”) approach was to discuss selected
topics in depth. Because of time constraints, only topics A-1, A-3, A-6, A-13, C-1, and C-6 were
addressed during the Turbines Breakout session. Group members were willing to provide
insights where they felt competent, but some were generally hesitant to endorse or exclude
specific standards. Postworkshop individual correspondence between Turbine Breakout session
members and the Turbine Breakout session chair yielded additional feedback on already-covered
topics and additional topics.

This section details the topics from the Electrical Safety Standards Comparison Table
(hereinafter “the table”) that were discussed either: (a) during the Turbines Breakout session of
the February 2020 workshop, or (b) via postworkshop correspondence between a session
participant and the session chair.

Note that in the text boxes associated with each of the upcoming subsections, when the word
“add” appears next to a particular standard it indicates that the standard was added to the table
found in Appendix D (Table D-1). When “remove” appears in a text box, it indicates that the
standard in question was removed from the table and is no longer recommended.

Please also note that the questions and discussion issues raised herein may not always represent
the most pertinent issues for a given topic and may not characterize the remaining issue(s)
completely. Nevertheless, they are addressed in the section to best reflect the discussion as it was
recorded and interpreted. The topics considered are as follows:

• A. Safety Design (e.g., arc flash, switchgear, and transformers)

o A-1, Arc Flash/Arc Blast Analysis
o A-3, Spaces Around Cabinets and Compartments and Equipment
o A-5, Adjustable Speed Drives
o A-6, Switchgear (High Voltage)
o A-7, Switchgear (Medium Voltage)
o A-9, Transformers
o A-10, Safety of Machinery
o A-13, Wind Turbine Electrical Systems
o A-15, Converter/Inverter
o A-16, Fixed ladder inside wind turbine.

• B. Safety Procedures (e.g., personal protective equipment, lockout/tagout procedures, and

equipment guarding)

17
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 o B-1, Working on or near live equipment
o B-3, Lockout/Tagout.

• C. Reliability Design (e.g., wiring methods and uninterruptable power supplies)

o C-1, Safety (Testing/Fit for purpose) – Acceptance Testing
o C-6, Cable Flammability Testing
o C-10, Slip Rings
o C-11, Alternators, Generators, and Motors
o C-13, Wiring Within the Turbine
o C-15, Pitch, Yaw, Other Control Panels
o C-19, Lighting.

4.1 A. Safety Design

A-1 Arc Flash/Arc Blast Analysis, Arc Flash Labeling
The Turbines Breakout group indicated IEEE 1584 and NFPA 70E are the most appropriate
standards for the U.S. market. NFPA 70E and Canadian Standards Association (CSA) Z462 are
essentially the same document (CSA is the Canadian standard and is harmonized with NFPA
70E). The group suggested that there was no harm in retaining CSA Z462 in the table since it is
harmonized with NFPA 70E.

Discussion Issue: “Arc flash labeling requirements are new in the U.S.”

Clarification was provided to indicate this labeling effort is standard for U.S. land-based wind
but may be new to offshore vendors with more experience in other markets. For example, in
European markets, hazards are addressed in design, lockout/tagout, or via instructions.
Application of an arc flash sticker is not standard practice in those markets. The suggested
solution is to rephrase as follows: “Since IEC standards will yield the same safety, use of IEC
standards should constitute compliance; in addition, the arc flash label can be applied per IEEE
1584/NFPA 70E.”

Discussion Issue: “What is needed to have a compliant Safety Management System?”

The developer shall establish an SMS that complies with 30 CFR 585 and is approved by
BOEM/BSEE.

Discussion Issue: “Should BSEE recommend that developers utilize NFPA 70E or IEEE
approaches on arc flash labeling requirements?”

The group reviewed the draft of OCRP Working Group 1 (OCRP-1) “5.6.4.7 Arc Flash” and
agreed with the manner in which arc flash is addressed. BSEE should use the draft as guidance
on this topic until the OCRP-1 process is completed through ANSI.

18
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Discussion Issue: “Are the following approaches for switchgear sufficient?”

The group concluded that the issue concerns switchgear design and suggested that it be
addressed in A-6 switchgear (high voltage).

Discussion Issue: “Should the IEC standards listed in the A-1 section of the table in Appendix
D, IEC 61482-2, IEC TR 61641, IEC 62271-200, IEC 60909-0, be followed for wind
applications?”

The suggested solution is to rephrase as follows, “With proper justification, these IEC standards
could be followed for wind applications.”

It should be noted that some participants believe that the IEC standards will yield the same level
of safety as the U.S. standards. Others believe this statement is too broad and that it has not been
shown that the arc flash requirements and definitions of the two standards approaches are the
same at all levels. If a sticker is used on IEC-tested and rated equipment, the boundary statement
and other critical details should correlate to the IEC-defined levels. While either system could be
acceptable for safety, the boundary or class definitions should not be mixed. Mixing of
requirements from various IEC and U.S. standards should not be allowed.

The following questions, although discussed, still remain open issues:

• Regarding NFPA 70E, which is addressed in OCRP-1, will this standard still be an issue if
OCRP-1 interpretation is utilized?
• Does using IEEE 1584 for the topic of arc flash conflict with the use of this standard in the
OCRP-1 document?
A-1
Standards addressed:

• Recommended standards: IEEE 1584, NFPA 70E, OCRP-1 “5.6.4.7 Arc Flash”
• IEEE 1584: arc flash analysis and methodology for calculating arc flash boundary
• NFPA 70E: arc flash safety guidance procedure.

4.1.1 A-3 Spaces Around Cabinets and Compartments and Equipment

The group indicated IEC 60364-7-729 is less stringent than OSHA. IEC 62271-200 does not
cover working spaces around cabinets and is perhaps irrelevant to this section.

Discussion Issue: “Requirements from IEC 60364, IEC 60204-1, IEC 60204-11, and IEC
61936-1 require measures to protect from electric shock, such as isolation of hazardous energy
and the use of protective barriers. Are these the best standard to eliminate the shock hazard?”

These standards are more relevant to A-13 and do not need to be included in the list for A-3.
However, if they are used, the hazard is eliminated.

The group thought it important to clarify that exposed live voltage is not necessary in turbine
cabinet design. In fact, IEC standards prohibit exposed live voltage, whereas OSHA and

19
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
IEEE/National Electrical Safety Code (NESC) standards require increased space around
electrical cabinets based on the possibility of exposed live voltages.

It is suggested that BSEE ask the turbine original equipment manufacturer (OEM) if the turbine
cabinets have exposed voltage. If yes, then A-3 should be pursued in detail; if not, these
standards may not be as important or relevant.

It is also suggested that BSEE consider the safety ensured by the IEC standard to be equal to or
greater than the IEEE standard. The group reviewed OPRC-1 draft, “5.6.4.6 Working Space
around cabinets with exposed live voltages,” and found it addresses only cabinets with exposed
live voltages. The group agreed the minimum distance requirements should only be relevant to
cabinets with exposed voltage.

A-3
Standards addressed:

• Recommended standards: none explicitly identified

• IEC 60364-7-729 is less stringent than OSHA
• IEC 62271-200 does not cover working spaces around cabinets and is perhaps
irrelevant to this section
• IEC 60364, IEC 60204-1, 60204-11, and IEC 61936-1 are more relevant to A-13 and
do not need to be included in the list for A-3. However, if they are used, the hazard
should be eliminated.

A-5 Adjustable Speed Drives

This topic was not addressed by the group; the individual that provided feedback indicated that
the standard Underwriters Laboratories (UL) 508C should be removed and replaced by UL
61800-5-1.

A-5

Standards addressed:

• Remove UL 508C and replace with UL 61800-5-1.

20
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
A-6 Switchgear (High Voltage)
The group suggested adding “turbines” to the ‘relevance’ column, adding IEC 62271-203
because it addresses > 52 kV, and noting that IEEE 1547 refers to grid code compliance and is
not specific to switchgear design.

A-6

Standards addressed:

• Recommended standards: none explicitly identified

• Add IEC 62271-203 because it addresses > 52 kV
• IEEE 1547 refers to grid code compliance and is not specific to switchgear design.

A-9 Transformers
Discussion Issue: “Which standards are acceptable?”

The original standards table listed NFPA 70B. A turbine-group member with extensive
certification experience indicates that this is not a product certification standard. Therefore,
NFPA 70B has been removed from the table.

Discussion Issue: “When installed inside the tower or nacelle, should a dry transformer with
nonflammable liquid be used? Should a transformer with “less-flammable” liquid rather than
“nonflammable” liquid be used?”

The term “less flammable” appears to be subjective. However, as defined in NEC 450.23, a
liquid is considered less flammable if its ignition point is 300 °C or higher. This is equivalent to
a Class K liquid according to IEC 61039.

A-9
Standards addressed:

• Recommended standards: none explicitly identified.

A-13 Wind Turbine Electrical Systems

The group suggested adding IEC 61936-1 and UL 6141, and that EN 61400-3 is outdated and
should be replaced by IEC 61400-3-1 and IEC 61400-3-2.

The following clarifications were provided:

• IEC 61400-1 covers the initial design to be type certified

• IEC 61400-3-1 covers fixed offshore turbines and is used to assess the suitability of the type
certificate

21
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
• IEC 61400-3-2 covers floating turbines and is used to assess the suitability of the type
certificate
• IECRE OD-502 is an operational document describing a method of approving a design for a
particular project (i.e., similar to the CVA process)
• CAN/CSA-C22.2 No. 272 is similar to UL 6141
• CAN/CSA-C61400-3 is harmonized to an older version of IEC 61400-3 and is not updated to
harmonize with the 2019 version of IEC 61400-3 that includes 61400-3-1 and 61400-3-2.

The group suggested this section should list preferred U.S. standards and international standards
with a caveat that “these international standards may be used with justification.”

Discussion Issue: “Are the following standards acceptable: CAN/CSA C61400-3, UL 6141, and
CAN/CSA-C22.2 No. 272?”

The group provided a response and justification for each:

• CAN/CSA C61400-3 is redundant with the outdated version of the IEC 61400-3 and is not
acceptable.
• UL 6141 is acceptable and should be added.
• CAN/CSA-C22.2 No. 272 is similar to UL 6141 and therefore is acceptable.

Discussion Issue: “How should EN 61400-3 be used? Significant revision and expansion of the
Electrical Systems section is included in the 2019 revision of the 61400-01 wind turbine design
standard.”

It is recommended that in general a European norm (EN) version should not be used when an
IEC version exists.

Discussion Issue: “Regarding certification, should there be no requirement for repeated

evaluation and testing by an NRTL? Wind turbine electrical system is type tested and certified as
part of the type certification process (IECRE OD-501).”

The suggested solution is to rephrase as follows: “Regarding certification, there should be no

requirement for repeated evaluation. Wind turbine electrical system is type tested and certified as
part of the type certification process (IECRE OD-501 or e.g., UL 6141).” If something is
certified, no reevaluation is needed unless it changes or if there are details beyond what is
certified.

22
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
The group reviewed the draft of OCRP-1 “5.6.4.1 General Requirements” and finds the
statements acceptable, although not necessarily complete.

A-13

Standards addressed:

• Recommended standards: IEC 61400-3-1, IEC 61400-3-2, IEC 61936-1, UL 6141,

CAN/CSA-C22.2 No. 272, and OCRP-1 “5.6.4.1 General Requirements”
• Add IEC 61936-1 and UL 6141
• CAN/CSA C61400-3 is redundant with the outdated version of IEC 61400-3 and
should be removed
• EN 61400-3 is outdated and should be replaced by IEC 61400-3-1 and IEC 61400-3-2
• An EN version should not be used when an IEC version exists.

A-15 Converter/Inverter
Discussion Issue: “Should a low-voltage converter comply with IEC 62477-1 and a medium-
voltage converter with IEC 62477-2?”

The terms low voltage and medium voltage need to be quantified. IEC 62477-1 is suitable for
voltages no greater than 1,000 VAC or 1,500 VDC. IEC 62477-2 is suitable for voltages from
1,000 VAC or 1,500 VDC up to 36 kV AC or 54 kV DC.

A-15

Standards addressed:

• Recommended standards: none explicitly identified.

A-16 – Fixed Ladder Inside Wind Turbine

An offshore industry safety manager offers this recommendation: fixed ladders should comply
with OSHA standards inside the United States and its waters. European standards have not
provided enough clearances for personnel and in the land-based industry, and OSHA will not
give a variance for noncompliant ladders from Europe. AWEA has lobbied on this point for
years and OSHA will not budge. The fixed ladder standard in OSHA is well-established and
should be utilized in the United States. A participant from a different breakout group also
expressed support for this recommendation.

23
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Additional input from an OEM suggested the following: OSHA requirements are prescriptive
and must accommodate general industry, where the level of personal protective equipment (PPE)
is not consistent. OSHA’s reluctance to provide a variance on their rules for land-based wind was
necessary to maintain a precedent that rules, as written, must be adhered to for workplaces where
OSHA is the agency having jurisdiction. OSHA has not, to date, adopted a performance-based
approach to safety regulation that permits the use of additional risk-reduction measures to
achieve a desired safety level. For offshore wind, a developer’s SMS should include basic PPE
guidance and the use of a helmet when working in a wind turbine, especially when traversing
fixed ladders. The mandatory use of a helmet significantly lowers the risk of harm as a result of
encroachment into the area around the fixed ladder. It is recognized that the clearance
requirements from ISO standards are less than those prescribed by OSHA. However, when the
application of the ISO standards is combined with appropriate PPE, the level of safety meets or
exceeds what would be accomplished through the OSHA requirements alone.

A-16

Standards addressed:

• Recommended standards: OSHA 29 CFR 1910.23, OSHA 29 CFR 1910.269(h), ISO

14122-1, and ISO 14122-4.

4.2 B. Safety Procedures

B-1 Working on or Near Live Equipment
An offshore industry safety manager offers this recommendation: OSHA and NFPA 70E should
be the only allowable standards for the U.S. market. American technicians and personnel across
all industries are already trained to, and familiar with, these regulations. These are well-
established in the United States and manufacturers should not be allowed to dictate safety
procedures. A participant from a different breakout group also expressed support for this
recommendation.

Additional input from an OEM suggested the following: work on live equipment is generally
prohibited in offshore wind. Instead, written isolation procedures are put in place to ensure that
hazardous energy is removed from a system before work commences. Technicians are duly
trained and evaluated on their competence in understanding these energy isolation procedures
and the application of isolations. This training is a mandatory component of becoming a
qualified person capable of performing work in an offshore wind turbine. The regime for
evaluating and enforcing this competency is a necessary part of a developer’s SMS. IEC and ISO
design standards include strict requirements on the provision of energy isolation points for both
electrical and fluid power systems, so that such energy isolation procedures may be created and
followed.

24
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 B-1

Standards addressed:

• Recommended standards: OSHA 29 CFR 1926.960, OSHA 29 CFR 1910 Subparts

R,S, and NFPA 70 E Ch1 Art.100-130.

B-3 Lockout/Tagout
An offshore industry safety manager offers this recommendation: only U.S. lockout/tagout
standards and practices should be followed. Project owners will not allow anyone who does not
follow NFPA 70 E and OSHA standards for control of hazardous energies and lockout/tagout to
work on a project site. A participant from a different breakout group also expressed support for
this recommendation.

Additional input from an OEM suggested the following: international standards include
requirements for the design of equipment for lockout/tagout, which should be considered
compatible with the process requirements from OSHA and NFPA 70E. These standards include
IEC 60204-1 (e.g., Section 5.4) for electrical installations, as well as ISO 12100 (e.g., Section
6.2.11.1) for general machine safety and ISO 4413 (e.g., Section 5.4.7.2.1) for fluid power
systems (hydraulics). The expression “isolation of hazardous energy” is a commonly used
reference to lockout/tagout internationally.

B-3

Standards addressed:

• Recommended standards: NFPA 70E, NFPA 70B, NFPA 70, and OSHA 29 CFR
1910.

4.3 C. Reliability Design

C-1 Safety (Testing/Fit for Purpose) – Acceptance Testing
The group suggested:

• IEC 61400-22 be replaced with IECRE OD-501

• ‘BS’ (British Standard) be removed from EN 61400-22
• BS PD IEC WT 01 be removed from the table
• ISO 9001 be added to the table.
Clarification was provided that IEC 61400-1 and IEC 61400-3-1 include commissioning testing
requirements, whereas other standards include (such as IEC 60204-1) verification and testing
requirements. CSA SPE-1000-13 is used for field evaluation of electrical equipment.

Discussion Issue: “Are the following standards most acceptable? DNV GL, CSA, or
ANSI/International Electrical Testing Association (NETA) standards?”

25
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
The group was not familiar enough with the DNV GL, CSA, or ANSI/NETA standards to
determine which are most acceptable.

Discussion Issue: “Should BSEE recommend that developers conduct tests on electrical
equipment to determine if it is fit for service before going live?”

The group suggests acknowledging this is already being done.

C-1

Standards addressed:

• Recommended standards: IECRE OD-501 and ISO 9001

• Replace IEC 61400-22 with IECRE OD-501
• Remove ‘BS’ from EN 61400-22
• Remove BS PD IEC WT 01
• Add ISO 9001.

C-6 Cable Flammability Testing

The group suggests adding smoke visibility EN 61034-2 (e.g., IEC document 61034-2-2005) to
the table, and suspects additional relevant standards need to be added to the table as well.

The distinction was made that the United States and Europe prioritize different hazards. The
United States is more concerned about smoke than the toxicity of the emissions, so it makes
cables with halogen. By contrast, Europe prioritizes reduction of the toxicity of emissions and
requires a halogen-free design.

Discussion Issue: “Are all listed standards acceptable?”

The group noted the standards are not equivalent. The group’s understanding from conversation
with BSEE is that if OEMs use the U.S. standard, that will be acceptable. Alternately, if OEMs
elect to use the IEC standard instead, the OEM must justify it.

The following question, although discussed, is still an open issue: The group’s understanding
from conversation with BSEE is that if OEMs use the U.S. standard, that will be acceptable.
Alternately, if OEMs elect to use the IEC standard instead, the OEM must justify it.

C-6

Standards addressed:

• Recommended standards: none explicitly identified

• Add EN 61034-2 (e.g., IEC document 61034-2-2005).

26
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 C-10 Slip Rings
The table states that UL 6141 references IEC 60204-1 as compatible. However, the word
“compatible” could oversimplify the issue, because equipment evaluated to the separate
standards is not certain to be compatible. UL 6141 explains that testing of the slip ring must
consider the ratings and certifications of upstream overcurrent protection. A slip ring evaluated
to UL508 may not be compatible with upstream equipment evaluated to IEC 60204-1.

UL 6141 states: Typical U.S. overcurrent devices have a 135% overload rating, and IEC
overcurrent devices often have a 1.45 overload rating. The maximum clearing time permitted for
most overcurrent protective devices is commonly 1 or 2 hours and depends upon the device type,
current rating, and applicable standard.

It is suggested the table comment be changed from “The UL 6141 standard references these as
compatible” to “The UL 6141 standard accepts either IEC 60204-1 or UL 508 compliance.”

C-10

Standards addressed:

• Recommended standards: none explicitly identified.

C-11 Alternators, Generators, and Motors

Similar to C-10, the original standards table states that UL 6141 references the IEC series as
compatible. Again, the word “compatible” is misleading.

It is suggested the table comment should be changed to: “UL 6141 accepts compliance with
either the UL 1004 series or the IEC 60034 series.”

C-11

Standards addressed:

• Recommended standards: none explicitly identified.

C-13 Wiring Within the Turbine

Although both IEC and U.S. standards are acceptable, a preference was expressed for use of the
NFPA standards because U.S. technicians will be trained to those standards.

In the initial review of this report, another participant suggested there be consistency across the
turbine, land-based and offshore substation electrical system because the electrical technician
could work in all areas. Lack of consistency across the entire electrical system could result in
safety issues. For example, the color coding of wires is inconsistent between IEC wiring tables
and IEEE wiring diagrams.

Additional input from an OEM suggested the following: the developer’s SMS should include
requirements for minimum levels of training for technicians to be considered as qualified persons

27
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
and competent to carry out work on electrical systems. This training must include the ability to
read and interpret wind turbine manufacturer electrical diagrams and follow written electrical
isolation procedures. This basic level of training can be used to ensure that wind turbine designs
that include the use of international standards can be safely installed and maintained. To
reinforce this, it is necessary that the electrical systems of the wind turbines are fully
documented, including electrical schematics that match the specific designs installed at a project.

An additional participant emphasized U.S. wind turbine technicians know that wind turbine
wiring can be in accordance with international standards and consistency, good training, and
documentation are essential.
C-13

Standards addressed:

• Recommended standards: NFPA 70 (NEC) and NFPA 79.

4.3.1 C-19 Lighting

It is suggested the U.S. safety certification standard for luminaires, UL 1598, be added to the
table.

C-19

Standards addressed:

• Add UL 1598.

4.4 General Comments and Recommendations

Regarding the turbine standards overall, if an offshore wind project is following codes and
regulations that require NRTL testing, an NRTL should be used. Likewise, if using IEC
standards, testing should be done with an accredited lab appropriate for those standards. This was
the general sense of the group’s breakout discussion, but additional input received after the
workshop indicated differing views on the degree of required testing by an NRTL. These views
are reflected in the following italicized statement, which, with appropriate variations, has been
added to a number of the items in the Appendix D Standards Comparison Table: regarding
certification, components normally come with type-testing documentation from the supplier.
Some participants recommend against a requirement for repeated testing by an NRTL. However,
others recommend the following approach: if using U.S. codes and regulations that require
NRTL certification, then an NRTL should be used to certify. If using IEC standards, then tests
with alternative accredited labs for those standards may be acceptable.

In general, the group encourages the use of performance-based, rather than prescriptive,
standards. This common-sense approach will facilitate achieving the shared goal of project and
worker safety.

28
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
It should be expected that deviations from a standard are permissible, but deviations need to be
justified to BOEM/BSEE. When an OEM deviates from a standard, there should be a mechanism
to justify the deviation and explain why it achieves an equivalent or better result.

The group cautions against using vague “high,” “medium,” and “low” terms for voltage (e.g., in
A-3, A-6, A-7). These terms are subjective and are often defined differently. The group
recommends that standards be designed for a clearly stated voltage. Regardless of the
terminology used (low, medium, high), a standard should be applied only when it is applicable
for the actual voltage range of a component, subsystem, system, or technology in question.

The group suggests changing the statement in the “Certification” column in A-10, A-13, A-15,
and C-15 from “Intertek certifies wind turbines to the listed UL and CAN/CSA standards” to
“There are organizations to evaluate wind turbines to the listed UL and CAN/CSA standards.”
This change removes identifying a specific company, and uses proper terminology, as these
organizations “evaluate” rather than “certify.”

Regarding the development of BSEE’s guidelines for electrical safety, the group provided
several suggestions to accelerate progress. The original Electrical Safety Standards Comparison
Table, which was disseminated in advance of the conference, included irrelevant standards, and
was missing relevant standards. The group expressed that, while the February 2020 workshop
was a productive exercise, there was not enough time to conduct a complete review of the table.
Therefore, BSEE should consider all input to make the table as complete as possible.

Because the U.S. offshore wind industry is moving quickly, the group recommends that
BOEM/BSEE support more workshops like this one while OCRP recommendations are being
finalized. Additionally, BOEM/BSEE should engage with the land-based wind community and
NRTLs to incorporate their experience integrating the international land-based wind industry
into the U.S. market.

Finally, BOEM/BSEE should engage in face-to-face meetings with individual

industry/stakeholder representatives to learn more and gather information. These face-to-face
events will facilitate a more effective and efficient transfer of knowledge than emails and
documents. They are also likely to yield more candid sharing of information than in a group
setting. Once BOEM/BSEE collect information in individual meetings and identify common
concerns, a group meeting should be convened to achieve consensus within the OSW industry.

A question for BSEE: Do the turbines and substations groups need to come to consensus on the
standards? The philosophy of OCRP is that turbines are generally mass-produced and consistent
with IEC-type certifications, whereas substations are project-specific custom designs.
Consequently, standards language regarding turbines uses more permissive suggestions (i.e.,
“should”), whereas standards language relevant to substations employs more prescriptive
requirements (i.e., “shall”).

One OEM indicated it is following the same process for their offshore work as for their land-
based work in the United States and uses an IEC-type certificate + NEC-UL base design.

29
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
5 Assessment of Relevant Electrical Safety Standards for
Offshore Substations
The following topics from the Electrical Safety Standards Comparison Table (hereinafter “the
table”), found in Appendix D (Table D-1), were discussed during the substations breakout
session of the February 2020 workshop. Additional input from the substations breakout group
(hereinafter ‘the group’) was sought via correspondence subsequent to the workshop.

Note that in the text boxes below, when the word “add” appears next to a particular standard it
indicates that the standard was added to the table. When “remove” appears in a text box it
indicates that the standard in question was removed from the table.

Please also note that the questions and discussion issues raised herein may not always represent
the most pertinent issues for a given topic and may not characterize the remaining issue(s)
completely. Nevertheless, they are addressed in the section to best reflect the discussion that was
recorded. The topics considered are listed as follows.

5.1 A. Safety Design (e.g., Lightning Protection, Switchgear, and

Transformers)
• A-1, Arc Flash/Arc Blast Analysis
• A-2, Emergency Stop – Design
• A-3, Spaces Around Cabinets and Compartments and Equipment
• A-4, Electrical Safety Equipment (GFCI – RCD)
• A-6, Switchgear (High Voltage)
• A-7, Switchgear (Medium Voltage)
• A-8, Switchgear (Low Voltage)
• A-9, Transformers
• A-10, Safety of Machinery
• A-11, Lightning Protection
• A-12, Electrical Enclosures/Control Panel (Degrees of Protection)
• A-14, Fire Prevention and Fire Protection
• A-15, Converter/Inverter
• A-16, Fixed Ladder Insider Wind Turbine.

5.2 B. Safety Procedures (e.g., Personal Protective Equipment,

Lockout/Tagout Procedures, and Equipment Guarding)
• B-1, Working on or Near Live Equipment
• B-2, PPE
• B-3, Lockout/Tagout
• B-4, Equipment Guarding (Energized Component).

30
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
5.3 C. Reliability Design (e.g., Marine Cables and Uninterruptable
Power Supplies)
• C-1, Safety (Testing/Fit for purpose) – Acceptance Testing
• C-2, Wiring Methods (High Voltage)
• C-3, Wiring Methods (Medium Voltage)
• C-4, Wiring Methods (Low Voltage)
• C-5, Wiring Methods
• C-7, Harmonics
• C-9, Uninterruptable Power Supplies (UPS)
• C-11, Alternators, Generators, and Motors
• C-14, Surge Protection/Suppression Component
• C-19, Lighting
• C-20, Illumination Levels for Emergency Evacuation
• C-21, Emergency and Standby Power Systems
• C-22, Power Sockets and Plugs
• C-23, Cable Trays
• C-24, Cable Cleats for Electrical Installations
• C-25, Cathodic Protection
• C-26, Grounding and Bonding.

5.4 General Discussion

The substations breakout group began by identifying topics that group members deemed most
pressing, or controversial, regarding offshore substations. The group identified the following
topics as most pressing:

1. IEC vs. IEEE

2. A-1: Arc flash/arc blast
3. A-3: Space around equipment (low voltage) and working online equipment
4. Standards for drawings/schematics and associated worker training
5. A-6: High-voltage and low-voltage switchgear (personnel and equipment)
6. NRTL certification for offshore substations.

After identifying the previously mentioned key topics, the substations breakout group discussed
all standards applicable to substations in the Electrical Safety Standards Comparison table. A
total of 32 standards were discussed. Remaining standards were not addressed for different
reasons, some because they were more appropriately considered by the turbines or cables
breakout groups, and some because more clarification or information was necessary to
comprehensively address the applicable standards. For example, the category name for that
standard may have been too vague or broad to be able to determine which standards are
applicable for that topic.

Standards C-3, C-4, and C-5, regarding wiring methods, were one exception to this process.

31
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
At the outset of the workshop, the substations group delegated these standards to the cables
group for consideration. After the cables group reviewed C-3, C-4, and C-5, it was determined
that the substation group was better suited to address these topics.

The requirements for NRTL certifications were discussed frequently during the workshop.
References to these discussions can be found in greater detail in the upcoming discussions for
each topic. However, one participant commented that, in general, NRTL certifications do does
not appear to be a requirement for engineered systems, such as fire protection systems, or for
some components within the system (e.g., the regulators). The following recommendations were
noted but further discussion may be required:

• NRTL certification of individual components shall be required only if there is a

commonly used certification standard for that component.
• The entire system does not need to be NRTL certified, only the individual components.
• Systems can be comprised of components certified by different NRTLs.
Note that in general, the substations breakout group defaulted to answer the question: “Are the
standards listed in the Standards Comparison Table (Appendix D) applicable and or acceptable
for this topic?” (in terms of substation electrical safety), but other discussion issues were
considered on a case-by-case basis, especially if an issue was specifically listed in the table.

5.5 A. Safety Design

A-1 Arc Flash/Arc Blast Analysis
The group agreed that arc flash is a critical issue. There was consensus that the small spaces in
offshore substations make arc flash challenging to address. The group agreed that the substation
design must account for the arc flash boundary for worker safety. It was noted that the arc flash
boundary would be lower for offshore substations because of the space constraints.

The appropriate PPE would be dictated by the equipment used and space needed, which is
unique to each substation design. Some participants recommended that land-based standards for
arc flash should be used; universal agreement on this point could not be reached.

The group expressed that IEEE 1584 has already addressed this issue in the OCRP document.
Some members of the substation group expressed concern that relying upon IEEE 1584, for arc
flash in particular, may conflict with the revised OCRP document. This still remains an open
issue.

The group also recommended referring to the general requirements for NFPA 70E and ANSI
specifications for both equipment and PPE. Additionally, it was noted that within NFPA 70E,
IEEE 1584 is referenced for the calculation of arc flash/blast risks. It is important to note the
distinction that IEEE 1584 is the evaluation and calculation methodology for arc flash, whereas
the practice of arc flash mitigation and personnel protection is in NFPA 70E.

Additionally, other participants recommended that API RP 14F be utilized for the working
clearances around electrical equipment as defined in this standard.

32
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
The group was in agreement that the purpose of this standard is for arc flash safety guidance
procedure and workplace safety guidance. There was agreement that the outlined
procedure should be followed, as it directs the user toward ANSI standards.

There was no discussion regarding CSA Z462, other than the fact that it remains applicable to
this topic.
A-1

Standards addressed:

• Recommended standards: IEEE 1584, NFPA 70E, and CSA Z462

• IEEE 1584: arc flash analysis and methodology for calculating arc flash boundary
• NFPA 70E: arc flash safety guidance procedure and personal protection guidance
• Add: API RP 14F: working clearances around electrical equipment.

A-2 Emergency Stop — Design

The group debated the precise definition of emergency stop, and how far this process may
extend. It was agreed that emergency stop can be defined as de-energizing the system. Some
participants from this group went so far as to recommend that “emergency stop” be replaced by
“remote de-energization,” stating that a system should be in place to open all the line-side
breakers in an offshore substation from a land-based location. Additionally, it was noted that the
resolution to the definition of “emergency stop” has already been addressed in DNV GL
standards; although, these standards were not specified by the group discussion.

It was also debated whether or not an emergency stop system includes emergency evacuation
systems, and if manned or unmanned facilities should be addressed. This discussion did not
reach a clear resolution.

The group agreed that every facility must have an emergency stop system in place. Although the
issue was not fully resolved, the group made progress in asking questions to help define what an
emergency stop means, such as:

• What equipment in the offshore substation needs to be shut down to maximize safety for the
personnel and the environment?
• When personnel return to the substation facility, what equipment needs to be de-energized to
ensure safety?
Overall, there was general agreement that the purpose of an emergency stop system is for the
protection of the environment and personnel. No standards were specifically recommended to be
added or removed from the list in Table D-1.
A-2

No standards were explicitly addressed during the discussion. Appendix D applies.

33
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
A-3 Spaces Around Cabinets and Compartments and Equipment
The group decided it was necessary to agree on a definition for low, medium, and high voltage.
The group agreed with the NEC definition, which defines voltage classes as follows:

• Low voltage: < 1 kV

• Medium voltage: 1–52 kV
• High voltage: 52+ kV.
All participants in the electrical safety standards workshop generally agreed that the voltage for
equipment should always be specified, rather than relying on subjective low-, medium-, or high-
voltage language.

Upon addressing the voltage classification, the substation group also discussed the difference
between troubleshooting exposed versus unexposed live (i.e., energized) parts. There was a
difference of opinion regarding troubleshooting of live system components. A participant argued
that one cannot troubleshoot a de-energized component, whereas others agreed that the part must
be de-energized and grounded when troubleshooting for safety. Another participant
recommended that in either case, whether energized or de-energized, the electrical equipment
should be tested per the manufacturer’s recommendations.

The group generally agreed that spaces around cabinets, compartments, and equipment are
primarily an issue for low-voltage panels. This is because high-voltage components are typically
not exposed. Regarding egress and ingress, the group recommended that the offshore substation
health, safety, and environmental plan should address the voltage class. There was general
agreement that, during the design phase, the full lifecycle of the project and equipment should be
considered, including the location for installing the switchgear.

A concern was raised about whether the battery room would be considered a classified zone if
API 14F is mandated, knowing that classifying the battery room would greatly increase costs.
The question still remains as to which standard should be used for calculating acceptable
hydrogen levels without leading to a classified zone.

The group did not fully address which standards are applicable for medium voltage.

A-3

Standards addressed:

• Recommended standards: NEC NFPA 70E Articles 110.26, 110.34

• Low-voltage NEC (NFPA 70)
o NFPA 70: national electric code for low-voltage and high-voltage gear
o NEC: smaller distances.
• Add: API RP 14F, as this allows smaller distances for low and medium voltages than
required by NFPA

34
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
A-4 Electrical Safety Equipment (GFCI – RCD)
The group acknowledged that offshore locations are not formally within OSHA’s jurisdiction (as
a result of earlier agreements made bilaterally between BSEE and OSHA) but that BSEE will
enforce OSHA regulations offshore to ensure personnel safety. With respect to using GFCI
versus RCD, it was recommended that the NEC requirements be followed. It was noted that
additionally, NEC could also be used for PPE. Another participant recommended that NEC be
applied to all electrical systems in the offshore substation of 600 V or less.

A-4

Standards addressed:

• Recommended standards: NFPA 70E

• NFPA 70E: for low voltage and safety
• Add: API RP 14F.

A-6 Switchgear (High Voltage)

The group reinforced the need to precisely define the low-, medium-, and high-voltage classes
before discussing high-voltage switchgear because various jurisdictions where offshore wind
turbines might be installed often define voltage classes differently. Some countries have different
voltage specification brackets for these voltage terms, whereas other countries do not distinguish
the voltage with the terms low, medium, and high at all.

The group ultimately reached a general agreement that, from a safety perspective, low and high
voltage is recognized. By contrast, for operating equipment, the terms low, medium, and high
voltage are recognized. It was not clear to the substations group whether this “safety vs.
equipment” distinction exists only in the United States.

There was some alignment among the substation participants to accept IEC standards for
switchgear and associated equipment. It was, however, noted that U.S. and European standards
differ regarding the need for visual confirmation of contact status (i.e., open or closed) for
switchgear. This difference needs to be addressed relative to substation design and construction.
However, one participant disagreed and stated that ANSI and UL switchgear and Merchant
Category Code standards are preferred over IEC standards.

There was additional conversation regarding using IEC’s gas-insulated switchgear (GIS) (e.g.,
viewing windows). It was noted that the IEEE C37.122 standard does not appear to be fully
implemented by any vendors of GIS above 52 kV. All available GIS at the high voltages
required for an offshore substation are built and tested to IEC 62271. Therefore, vendors can
customize IEC’s GIS to meet additional requirements of IEEE but the Factory Acceptance Tests
are performed according to IEC and the tests are different from IEEE.

One participant noted that there are gaps in IEEE C37.122 and recommended using this standard
in conjunction with IEEE C37.21. It was suggested to allow the use of fully IEC- compliant local
control cabinets or hybrid local control cabinet designs that are built to IEC standards, but that
they should also meet all of the practical requirements of IEEE C37.21.

35
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Additionally, it was suggested by one participant that if LCCs are fully IEC compliant, then IEC
cables should be used between GIS and LCCs. If a hybrid IEC/IEEE LCC is used, then
type/colors of cables used will ensure a consistent design.

Finally, there was discussion of NRTL testing of switchgear. Two participants of the substations
group provided input on NRTL testing as follows: for systems at 600 V or less, the NEC should
be followed. Higher than 600 V, the NESC should be followed. NRTL testing is not required.
The basis for this is that NRTL testing for components above 34.5 kV does not appear to exist.
NESC does not require NRTL certification. There are limited manufacturers of components up to
34.5 kV, so adding this additional requirement would be too restrictive for substation designers
and may have negative unintended consequences on cost and safety. At 600 V and below, NRTL
certified components are common, and NRTL certification demonstrates compliance with NEC.
One can also use components that are not NRTL certified, but in these cases demonstration of
NEC compliance must be made.

A-6

Standards addressed:

• Recommended standards: IEEE C37.122

• Add: IEEE C37.122, for gas-insulated switch gear, specific to high voltage
• Add: IEC 62271
• Remove: IEEE C37.20.2: for medium voltage only.

A-7 Switchgear (Medium Voltage)

The group’s consideration of medium voltage switchgear was brief, and mainly led to a NRTL
discussion. The substations group concluded that, if IEC standards are used, the equipment must
still be NRTL certified.

Similar to the argument made in A-7, the same comment on NRTL certification was made for
MV switchgear. For systems at 600 V or less, the NEC should be followed. Higher than 600 V,
the NESC should be followed but NRTL testing is not required. At 600 V and below, NRTL-
certified components are common, and NRTL certification demonstrates compliance with NEC.
One can also use components that are not NRTL certified, but then demonstration of NEC
compliance must be made.

One participant noted that as the tests for IEC-type switchgear are different, the previous IEC-
type tests may be not applicable and the National Electrical Manufacturers Association

A-7

Standards addressed:

• Add: IEEE C37.20.2, IEEE C37.20.09: for ANSI MV

• Add: IEEE C37.20.7: if using arc gear for LV and MV; must be NRTL certified as well.

36
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
(NEMA)/ANSI tests will need to be performed to comply with the requirements of the ANSI,
IEEE, and UL standards.

A-8 Switchgear (Low Voltage)

The low-voltage switchgear conversation led to questions about the scope of the term. For
example, should motor control equipment and exhaust fans be considered low-voltage
switchgear? Some participants stated that motor control equipment is covered by the UL 845
standard and is not switchgear, and that it does not have the same requirements as ANSI
C37.20.1 (i.e., it does not have a short time short circuit withstand rating, wherein low-voltage
switchgear requires a 1-second withstand rating.) At the conclusion, there was still some
question about whether motor control equipment should be classified as low-voltage switchgear.
It remains unclear whether switchgear for exhaust fans should be included in this category.

The group came to a consensus that NEMA standards will be included with the other
recommended standards. However, a path should be made for acceptance of IEC standards as
well, as it was noted that IEC low voltage takes up considerably less space, and conserving space
is important for offshore substations in particular. Additionally, the group acknowledged that UL
has adopted many of the IEC standards, specifically IEC 947.

A-8

Standards addressed:

• Recommended standards: UL 891 (for low-voltage switchboard)

• Add UL 508: enclosed protection systems and enclosed cabinets
• Add UL 845: motor control
• Add UL 1558
• Add UL 1053: safety covering ground fault protection
• Remove: IEEE C37 series—all does not apply.

A-9 Transformers
The group first agreed on the scope of what equipment and accessories would be considered
within the term “transformers” for the purpose of addressing this standard. From this discussion,
there was alignment that the transformer and its accessories including reactors, circuit breakers,
GIS equipment, and lightning protection would be considered. It was not unclear if shunt
reactors should also be included in this list of transformer accessories. Although, it was
recommended by one participant that the use of IEC transformers and shunt reactors, including
IEC control cabinets, should be permitted.

The group came to a general agreement that the consideration of flammable liquids, open or
closed systems, and other issues depends upon the substation design specifications. There was
agreement that most offshore components are located in enclosed indoor spaces, though some
transformers are outside. This is a function of the “semiclosed” versus “semiopen” design, which
is often country-specific. Structural design of the transformer was discussed. All of the design

37
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
questions are left to the developer to address as design specifications, including the
“nonflammable” or “less flammable” liquid issue.

One participant recommended that if IEEE transformers are specified, special attention must be
given to the following: a) plug-in bushings b) oil-SF6 bushings (if used), and c) control cabinet
interfaces.

Additionally, another participant recommended using IEC 62271-211 for interfaces between a
gas-insulated busbar and transformer bushing (oil-SF6), and that special attention is required
when using IEEE transformers to ensure there are no IEC/IEEE interface issues.

A-9

Standards addressed:

• Recommended standards: IEEE/ANSI C57 series

• C57 series: for low-voltage transformers and reactors.

Other participants addressed the standardization between European and U.S. standards regarding
transformers. One participant added that until harmonized standards between IEC and IEEE
become available, n-load tap changers should be designed and tested to meet IEC standards. Yet
another participant noted that until there are more U.S. suppliers of high-voltage transformers
accessories, compliance with European standards should be permitted.

A-10 Safety of Machinery

For the purposes of this workshop, the group limited the term “machinery” to substations only,
and specifically excluded turbines from the discussion. The group agreed that it would be
beneficial to classify machinery as either necessary or backup systems. There was alignment that
backup systems include air compressors; heating, ventilation, and air conditioning systems and
ventilation systems; backup generators (diesel); and other ancillary systems. Fire detection, gas
detection, and fire suppression systems are considered necessary machinery. Although this was
the majority of the group’s definitions for classifying machinery, there were differing opinions
that separated machinery into ancillary systems, and emergency response or emergency
shutdown systems. The classification of machinery for the purpose of this discussion remains an
open issue.

The substations group was challenged in addressing the standards listed because different
standards apply for different types of equipment.

A-10

No standards were explicitly addressed, discussion only.

38
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
A-11 Lightning Protection
Some members of the group noted that offshore oil and gas platforms generally include limited
lightning protection measures. For offshore wind substations, the group recommended the
following standards.

A-11

Standards addressed:

• Recommended standards: consider IEC 61400-24 and NFPA 780 (sparing standards)
• Add: IEEE 998 - lightning protection for (land-based) substations.

A-12 Electrical Enclosures/Control Panel (Degrees of Protection)

The group reached consensus that this category refers to low-voltage electrical enclosures and
control panels only. The Ingress Protection (IP) rating of these enclosures and control panels was
discussed, in addition to the incorporation of any fiber optic cables within these fixtures. The
substations group was not aware of any ANSI standards concerning integration of fiber optic
cables into power cables.

A-12

Standards addressed:

• Recommended standards: UL 508A, NEMA ANSI/IEC 60529, NEMA 250

• UL 508A: enclosed assembled equipment
• NEMA ANSI/IEC 60529
• NEMA 250: rating.

A-14 Fire Prevention and Fire Protection

The substations group addressed who is responsible for fire protection, prevention, and
suppression. The group generally agreed that fire suppression is driven by insurance company
requirements, whereas fire protection is overseen by BSEE. In both cases, the substation’s
emergency response plan outlines these responsibilities, and outlines the contractor’s
responsibilities in the event of an offshore substation fire. The group agreed that it is the
substation operator’s responsibility to ensure that an emergency response plan is in place, and
that the emergency response contractors are properly informed as to what regulatory documents
need to be submitted regarding the fire protection and prevention plan. One participant
recommended that fire detection should be required, but the installation of fire suppression
systems be provided only after a proper “As Low As Reasonably Possible” analysis, thereby
demonstrating the need and value of such a system.

The group also discussed NRTL certification with respect to fire protection and prevention and
agreed that NRTL certification is required for fire protection. When and how to follow
manufacturer’s certifications was also considered. The group reached consensus that the
manufacturer’s certification can generally be relied upon. However, if the manufacturer does not

39
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
operate in the country where the equipment is installed, then the equipment in question must be
re-certified to adhere to local requirements. For example, offshore wind equipment manufactured
in Germany would be required to obtain NRTL certification before it could be used in a U.S.
offshore wind installation.

It is important to note that in Europe, fire protection/suppression is generally incumbent upon

insurance companies. Regarding fire alarm system control, one participant commented that
NFPA 2001 calls for a local logic controller for a fire extinguishing system controller. For
typical European projects, the control of this system is under the fire alarm system, which
minimizes the installation cost as well as the size/weight of the equipment installed on the
offshore substation, and maintenance requirements. Therefore, it was suggested to allow the fire
alarm system to control the fire extinguishing system equipment directly rather than using a
separate fire extinguishing system controller. Another participant also recommended to allow
European fire ratings for walls and penetrations for passive fire protection design.

Regarding helideck firefighting systems, one participant added that the U.S. standard for the
helideck firefighting system, NFPA 418, requires a duration of a 10-minute (min) discharge;
thus, a larger, heavier skid than CAP 437 (10 min in NFPA 418 vs. 5 min in CAP 437). The
USCG has recognized CAP 437 as an acceptable alternative to the helideck deck firefighting
system with respect to CFRs. Therefore, it was recommended that both CAP 437 and NFPA 418
are acceptable, while noting the differences in discharge timing.

A-14

Standards addressed:

• Add: NFPA 2001, “clean agent”/inert-gas fire suppression standard

• Add: API RP 14C
• Add: DNV GL ST 145, for passive/active suppression
• Add: NFPA 16, for water-based foam systems.

A-15 Converter/Inverter
The substations group did not address this standards category in depth. One participant
commented that there are specific requirements for inverters to be operated and integrated into
the U.S. power grid. It was therefore recommended to add the standard UL 1741, which is the
Standard for Inverters, Converters, Controllers and Interconnection System Equipment for Use
With Distributed Energy Resources for inverters for U.S.-based installations.

40
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
The following question arose during the discussion: Would UPS systems be included in this
category, or do DC UPS systems fall under this concern, within the substation? One participant
recommended that UPS systems not be included in this category. Instead, it was recommended
that UPS systems be addressed in the utilities and support systems, as they would be used to keep
the control and communication systems functional during a brief power outage.

A-15

Standards addressed:

• Add: UL 1741: Standard for Inverters, Converters, Controllers and Interconnection

System Equipment for Use With Distributed Energy Resources.

5.6 B. Safety Procedures

B-1 Working on or Near Live Equipment
The substation group agreed that this topic was fully covered by NFPA 70E and OSHA 29 CFR
§ 1910 Subparts R, S.

B-1

Standards addressed:

• Recommended standards: NFPA 70E, OSHA 29 CFR § 1910, Subparts R, S.

B-2 Personal Protective Equipment

The group agreed that the American Society of Testing Materials (ASTM) F1506 provides the
best reference for PPE requirements, and generally aligns with NFPA and OSHA standards, as
listed in the corresponding recommended standards textbox (B-2). The group did not address
whether or not NFPA 70B applies to PPE, or if this standard is only relevant to O&M.
B-2
Standards addressed:

• Recommended standards: ASTM F1506, NFPA 70E, OSHA 29 CFR § 1910.137.

B-3 Lockout/Tagout
The substation group agreed that lockout/tagout is applicable for all voltages. There was
consensus that the developer must define the lockout/tagout procedure and criteria within their
design specifications, as these approaches can vary for different equipment.

41
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
One participant recommended that that the IEC-based electrical equipment highlighted in the
wind turbine section be provided with specific provisions for lockout/tagout that are compatible
with the OSHA-mandated lockout/tagout requirements.

B-3

Standards addressed:

• Recommended standards: NFPA 70E

• Specify: OSHA 29 CFR § 1910 is general, whereas OSHA 29 CFR § 1910.147 is specific
to lockout/tagout.

B-4 Equipment Guarding (Energized Component)

The group agreed that USCG rules do not require guardrails for fixed structures. The group also
agreed that guarding for high-voltage GIS equipment is unnecessary. There was agreement that
only energized equipment must be guarded. This is different than space around equipment,
which is focused on permitting ingress and egress.

B-4

Standards addressed:

• Add: IEEE C2 (NESC)

• Add: API RP 14F.

The group agreed to exclude floating wind energy substations from this conversation, which will
be addressed by other standards initiatives.

It remains an open issue whether or not USCG IEEE C2 Sub.J is applicable, although this issue
may not represent the most pertinent issue(s) for this topic.

5.7 C. Reliability Design

C-1 Safety (Testing/Fit for Purpose) – Acceptance Testing
The substation group agreed that the question of safety acceptance testing should be deferred to
the CVA. It was agreed that each OEM creates its own pre and postenergization inspection and
test protocols. Additionally, developers have their own commissioning and execution plans.

The group further agreed that BSEE should recommend that developers test electrical equipment
before energizing, but observed that this testing can vary by project, developer, or manufacturer.
Proof-of-concept testing should be conducted by the OEM. The group generally agreed that
commissioning activities are project- and equipment-manufacturer/type specific. The
ANSI/NETA acceptance testing specifications (ATS) should still be considered for
recommended guidelines.

42
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Generally, it is recommended that the industry move away from IEC 61400-22 and adopt IECRE
OD-501 and -502. Work has been done so that it can result in certificates of higher quality and
also allows for better mutual recognition. Many turbine suppliers have already adopted the
IECRE system, and it is expected that in the future most offshore turbines will be required to
have IECRE certificates. IEC 61400-22 is an outdated standard and is no longer recognized by
IEC or the U.S. National Committee. IECRE OD-501 and –502 are referenced in both the
turbines and substations sections.

C-1

Standards addressed:

• Remove: IEC 61400-22

• Remove: BS EN 61400-22
• Add: IECRE OD-501 and -502
• Add: CIGRE B3.26
• Add: ANSI/NETA ATS.

C-2 Wiring Methods High Voltage

The substations group did not discuss this topic in depth. One participant commented that there
are high-voltage cables used in the platform that are not submarine cables(e.g., between the GIS
and transformer). It is recommended that these cables also be built and tested to IEC standards
rather than the Insulated Cable Engineers Association (ICEA) to avoid creating unnecessary
IEC/ICEA interfaces that may require specialized IEC/ICEA cable joints and different types of
cable terminations.

Another participant commented that European designs typically use plug-in termination for high-
voltage cables (e.g., Pfisterer Connex). These can be dry type or oil-immersed. There are no
equivalent U.S. standards for these types of terminations above 52 kV. It was recommended to
allow the use of plug-in terminations (e.g., Pfisterer Connex) according to relevant IEC/EN
standards.
C-2

No standards were explicitly addressed, discussion only.

C-3 Wiring Methods Medium Voltage

The substations group did not discuss this topic in depth but agreed to include API RP 14F and
NEC NFPA 70 to the list of relevant standards.
C-3

Standards addressed:

• Add: API RP 14F

• Add: NEC NFPA 70.

43
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
C-4 Wiring Methods Low Voltage
The substations group concluded that NFPA 70 is the recommended standard. The group agreed
that additional information would be needed to properly address the topic of low-voltage wiring
methods; either a submarine cable or interconnection cable.

The question arose during the workshop as to what a low-voltage submarine cable is. One
participant commented that there is no such cable. They noted that [submarine cables] are
intended for power transmission over some distance and can be available in medium-voltage or
high-voltage applications. Rather, this participant suggested that low-voltage wiring methods
specifically apply to the substation facility, with a focus on marine applications. Therefore, they
recommend that API RP 14 F be added to the current reference to the NEC (NFPA 70) to be
used for the recommended wiring methods for low-voltage applications for offshore facilities in
the United States. This was added to address specific requirements for marine use and exposure
to corrosive, salt-laden environments.

C-4

Standards addressed:

• Recommended standards: NFPA 70 (NEC)

• Add: API RP 14F.

C-5 Wiring Methods

The group felt it necessary to discuss and clarify the term “marine shipboard cable.” The group
questioned whether this term refers to actual “shipboard” cables (a special designation of cable),
or if it was referencing any kinds of cables that are found onboard an offshore wind substation
platform. The group agreed that it is important to clarify that for substations, marine shipboard
cables are not the only cables to be used. Therefore, the group suggested removing “shipboard
cable” from both the standard category column, and from the NRTL certification column. It was
noted that IEEE 1580 should be allowed for marine shipboard cable to be used without being
installed in accordance with IEEE 45, as this could be a viable option for armored cables
installed outside on the platform. Also, it was recommended by one participant that all types of
armored cables be allowed to be installed in a cable tray.

One participant recommended that “Type P cable” could replace “marine shipboard cable” in the
category column of Table D-1, as this is the designation that is currently published in the 2020
version of the NEC (NFPA 70) that refers to the same type of cable design suitable for marine-
type environments. Another participant suggested allowing all types of armored cable to be
installed in a cable tray.

The question arose during the discussion to clarify the suggested wiring methods. One
participant commented that in the United States, the term “wiring methods” refers to
interconnection cables. Another participant suggested the following recommendations regarding
the conflicting low-voltage wire coloring schemes within using the standards listed in the
upcoming text box. The following color scheme should be used: protective ground (equipment
grounding conductor) cables should be green or green with yellow strips. Neutral cables should
be white or light grey. Both of these requirements are from NFPA 70. For DC cables, +ve should

44
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
be red and -ve should be black. All other cables coloring (i.e., L1, L2, and L3 for 480 V/277 V
and 208 V/120 V, control wiring) should be at the discretion of the designer provided a
consistent approach is used.

Another participant suggested to add low-smoke or halogen-free U.S. standards that align with
the European ones, as low-smoke/low-halogen cables are preferred for an offshore substation.
These standards are listed in the following text box.

C-5

Standards addressed:

• NFPA 70 and API RP 14F: wiring methods beyond marine shipboard cables
• Add: NFPA 70: allows the manufacturer to choose their own kind of wiring method
• Add: API RP 14F: wiring practices for offshore
• Add: IEC 60331-1, -2, -21 for fire resistivity
• Add: IEC 60754-1 and –2: halogen-free standard
• Add: IEC 61034-1 and -2: low-smoke standard
• Remove from category name column: “marine shipboard cable”
• Remove from certification column: “Cables should be listed as a marine shipboard cable
by a NRTL”
• All other standards listed are for marine shipboard cables.

C-6 Cable Flammability Testing

There was consensus that cables are typically “flame retardant.” The group found it necessary to
distinguish between fire-rated cables, fire-retardant cables, and fire-resistant cables. One
participant commented that submarine cables will not have flammability standards applied but
will utilize external coverings applied at the substations to provide the degree of protection
required by the standards. Another participant commented that the standards referenced within
API RP 14 F will provide distinctions between the terms fire-rated, fire-retardant, and fire-
resistant.

It was recommended by one participant to add IEC 60331-1, -2, and -21 standards to
accommodate a broader range of potential cable vendors.

Additionally, it was agreed that both the substations group and the cables group would address
the issue of cable flammability testing.

45
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 C-6

Standards addressed:

• Add: API RP 14F

o Reveals which applications require low-smoke, low-halogen cables
o Defines where fire-related cables should be used
o Defines which kind of fire-related cables should be used
• Add: IEC 60331-1, -2, and -21.

C-7 Harmonics
The group agreed that the developer must address any harmonics issues within the offshore
substation, whereas the grid operator must address onshore substation harmonics.

C-7

Standards addressed:

• Recommended standards: IEEE 519

o Applies at the point of interconnection
o This standard is sufficient; not required inside of substation, but just at the
point of common coupling.

C-9 Uninterruptable Power Supplies

The group agreed that UPS are a combination of DC and AC components. It was also agreed that
it is necessary to establish a bridging system through the start cycle, and to establish power from
the diesel system. It was noted that UL 62109-1 is a USCG requirement for Safety of Life at Sea.

C-9

Standards addressed:

• Add: IEEE 946

• Add: IEEE 44 or 484.

C-14 Surge Protection/Suppression Component

The group discussed switching operation surges and agreed that the IEEE C37 90.1 standard
should be added.

46
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 C-14

Standards addressed:

• Add: IEEE C37 90.1.

C-19 Lighting
The group recommended removing all of the information in the last column; the developer
should define this, as it is not relevant to electrical safety.

It was recommended by one participant that lighting details for boat landings may not be
addressed within these standards. It was recommended that the boat should provide emergency
egress illumination without needing permanently installed lighting along egress ladders and boat
landings.

C-19

Standards addressed:

• Recommended standards: IEEE C2 (NESC)

• Add: API RP 14F: minimal lighting levels for offshore locations, included servicing.

C-20 Illumination Levels for Emergency Evacuation

The substation group briefly discussed this topic and recommended API RP 14F to address it.

C-20

Standards addressed:

• Add: API RP 14F.

C-21 Emergency and Standby Power Systems

The group discussed how to define “emergency power systems.” There was consensus that usage
of the term “emergency power” may trigger certain USCG regulatory requirements. The group
instead recommended using the terms “standby” or “essential” power systems and added API RP
14F.

C-21

Standards addressed:

• Add: API RP 14F.

47
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
C-22 – Power Sockets and Plugs
The group agreed that the listed standards are acceptable. It was recommended to remove
“Receptacle NEMA 4x protection” verbiage in the table’s certification column.

C-22

Standards addressed:

• Add: NEC (NFPA 70)

• Add: API RP 14F.

It was recommended by one participant to add the NEC (NFPA 70) and API RP 14 F to address
the selection and installation for receptacles for offshore wind facilities. This would also cover
the requirements for GFCI protection of these devices depending on their location and type of
service.

C-23 Cable Trays

The group discussed the different materialsaluminum, stainless steel, and fiberglass―used to
manufacture cable trays. There was consensus that the standards listed appropriately address the
various materials used to create cable trays.

One participant recommended API RP 14 F for the design and installation of cable tray systems
for offshore wind facilities in the United States because this standard covers the sizing, type,
placement, and installation methods for cable tray systems to be used in an offshore marine
environment.

C-23

Standards addressed:

• UL 2277: construction specifications

• Add: API RP 14F.

C-24 Cable Cleats for Electrical Installations

The group agreed that there was no manufacturer stipulation on this topic, and that the cable
group should address it.

During the review of this document, a participant from the cables group commented that the
group is addressing this topic only in relation to the clamping of the cables going to the first GIS
connection. It was recommended that the clamps be tested according to IEC 61914 “Cable cleats
for electrical installations” and spacing of clamps should be specified by cable manufacturer
based in installation parameters. This international standard specifies requirements and tests for
cable cleats and intermediate restraints used for securing cable in electrical installations. Cable
cleats provide resistance to electromechanical forces where declared. This standard includes
cable cleats that rely on a mounting surface specified by the manufacturer for axial and/or lateral
retention of cables.

48
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
C-25 Cathodic Protection
The substation group agreed that cathodic protection is a developer-implemented corrosion
mitigation technique.

C-25

Standards addressed:

• Recommended standards: NACE RP-01

• NACE RP-01: corrosion protection.

C-26 Grounding and Bonding

This substation group agreed to add the standards API RP 14F , IEEE 837, and IEEE 80.

C-26

Standards addressed:

• Recommended standards: UL 467

• UL 467: grounding and bonding equipment
• Add: API RP 14F (covers grounding for offshore)
• Add: IEEE 837
• Add: IEEE 80.

General Comments and Recommendations

The substation breakout group discussions revealed that many of the identified standards pertain
to the design of the substation itself. This was a common theme throughout the group discussion,
because substations are generally individually designed to suit local site conditions. Accordingly,
a developer’s specifications tend to more heavily influence substation design than does an
electrical safety perspective. For example, the lengthy discussion of arc flash/arc blast boundary
ultimately resulted in the need for design specifications to further clarify the applicable
standards.

In general, the U.S.-based IEEE or ANSI standards were considered to be defaults in many
instances. When a U.S. standard was not available, IEC or other international standards were
incorporated. This leads to the overarching question of how standards should be interpreted for
worker training to ensure safety. Participants expressed different viewpoints regarding workforce
utilization. Some companies use the same technicians to service on and offshore equipment,
whereas others have separate specialized land-based and offshore workforces. A prescriptive
standard may not be required in these instances, as this is more a question of operational strategy.

Additionally, it was recommended to not use the subjective low/medium/high descriptions for
voltage; rather, voltage classes should be specifically stated in accordance with the NEC
definitions, which was stated in the general key findings (Section 2.1). Across the board, greater

49
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
specificity should reduce confusion and miscommunication, leading to safer offshore substations.

50
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
6 Assessment of Relevant Electrical Safety Standards
for Submarine Cables
Electrical safety standards for subsea cables are considered in the scope of work being completed
by the AWEA OCRP Working Group (WG) 5, which is currently developing its
recommendations. The cables breakout group included members of WG 5, as well as
representation from submarine cable manufacturers, offshore wind project developers and
operators, certification organizations, and BSEE. The organization of this section is intended to
be consistent with the draft outline of the OCRP WG 5 document, which will have a similar
structure.

6.1 Scope
The cables breakout group (hereinafter “the group”) focused on array and export cables, with the
scope defined in line with the WG 5 scope. Array cables are defined as extending between the
terminations of the offshore wind facility structures, typically from the wind turbine to the
substation. For export cables, the scope covers the cable between the termination on the offshore
wind facility structure and where the submarine cable either terminates or transitions to a land
cable design in a transition joint (splice).

Voltages for an offshore wind power plant array and export cables are generally 35 kV and
above. In Table D-1, array and export cables primarily fall in the “high-voltage” category,
although standards listed under “medium voltage” may also be applicable to array or export
cables with ratings at the lower end of the range. Although Europe and China are beginning to
adopt HVDC systems for wind farms located far from shore, workshop participants do not
anticipate any HVDC installations in the United States prior to the completion of the AWEA
OCRP update that is scheduled for publication in 2021. Accordingly, standards for HVDC cables
were not considered in detail during this workshop.

Electrical safety standards were discussed primarily in the context of reliability. There was broad
consensus that a well-designed and properly installed cable should—barring external factors
such as an anchor strike—not require any human interaction for the remainder of its lifetime.
Ensuring reliability and minimizing the need for repairs is the best method for assuring safety.
The other main approach to safety is having a repair plan in place in advance, in which all of the
relevant standards and best practices are considered before they are urgently needed.

DNV GL-ST-0359 (Subsea power cables for wind power plants) and DNV GL-ST-0360 (Subsea
power cables in shallow water) provide useful information relevant to submarine cables in all
stages of the offshore wind plant lifecycle; however, they are recommended practices rather than
U.S. or internationally recognized standards.

6.2 Submarine Cable Route Planning

Guidance from the AWEA OCRP 2012 recommended practice document remains relevant for
cable route planning. A cable route should be planned based on data from the site
characterization study and a desktop study of the seabed between the project site and proposed

51
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
cable landing point. The North American Submarine Cable Association 1 and the International
Cable Protection Committee 2 provide resources for identifying submarine cable locations and
ownership. If other cables or pipelines are found to intersect the proposed route, the developer
should, before construction begins, contact the owners of those facilities to negotiate the
appropriate legal agreements regarding crossing and proximity. Documents that provide
guidance for route surveys include:

• BOEM’s guidelines for providing geological and geophysical hazards and archaeological
information pursuant to 30 CFR § 585
• Minimum requirements for the foundation of offshore wind turbines and power cable route
burial assessments; Bundesamt für Seeschifffahrt und Hydrographie (Federal Maritime and
Hydrographic Agency of Germany), August 2003
• International Cable Protection Committee Recommendation No. 3. Issue 9A: criteria to be
applied to proposed crossings between submarine telecommunications cables and
pipelines/power cables; Issue 2A: minimum technical requirements for a desktop study.

6.3 Submarine Cable Design, Manufacturing, and Testing

The application of standards to the design, manufacturing, and testing of export and array cables
for offshore wind power plants is complicated by the absence of comprehensive standards for
submarine power cables. Standards suitable for cables installed on land do not cover the
additional requirements for submarine cables used in offshore wind systems, which typically
include multiple cores, optical fiber, bedding, armor, and an outer jacket. IEC 63026 (Submarine
power cables with extruded insulation and their accessories for rated voltages from 6 kV up to 60
kV - Test methods and requirements) is the only internationally recognized standard covering
both mechanical and electrical testing specifically adapted for submarine cable systems.

In the absence of standards specific to high-voltage subsea cables, the recommended practice is
to follow standards for high-voltage land-based cables in combination with the guidance
provided in CIGRE TB 490 (Recommendations for testing of long AC submarine cables with
extruded insulation for system voltage above 30 to 500 kV) and CIGRE TB 623
(Recommendations for mechanical testing of submarine cables). CIGRE TB 496
(Recommendations for testing HVDC extruded cable systems for power transmission at a rated
voltage up to 500 kV) provides guidance for HVDC cables. Examples of acceptable
combinations of standards include:

• IEC 60840 (Power cables with extruded insulation and their accessories for rated voltages
above 30 kV up to 150 kV – Test methods and requirements) and CIGRE TB 490
• IEC 62067 (Power cables with extruded insulation and their accessories for rated voltages
above 150 kV up to 500 kV – Test methods and requirements) and CIGRE TB 490.
Participants in the cables group expressed different views regarding non-IEC standards. Some
participants recommended using only IEC standards, whereas others believed that other
standards should be allowed. A broad conclusion from the discussion was that if a relevant party,

1
https://www.n-a-s-c-a.org/
2
https://www.iscpc.org

52
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
such as a developer or interconnecting utility, requests cable core insulation wall thickness to be
in compliance with standards issued by another SDO (such as the Association of Edison
Illuminating Companies [AEIC] or ICEA), that could be acceptable as long as the cable system
is type tested and prequalified following the procedures described in the relevant IEC and
CIGRE standards documents. The added testing and potential increase in cable mass would
likely increase costs and lead time associated with cable installation.

CIGRE TB 722 (Recommendations for additional testing for submarine cables from 6 KV up to
60 kV) provides guidance on recommended testing for wet and semiwet cable designs.

Prequalification and type testing of a cable system for a given voltage can also qualify a lower-
voltage cable system of the same design, as described in IEC 60840 and IEC 62067.

For the calculation of current ratings, IEC 60287 (Electric cables - Calculation of the continuous
current rating of cables) is recommended. The method and process for ampacity calculation is
explained and examples of the calculation process are given in the EPRI Underground
Transmission Systems Reference Book—2016 Edition, Chapter 11. If the cable will be
dynamically rated, site-specific data on wind speeds and proposed turbine capacity will be
required to calculate the appropriate current rating. A conference paper, “CIGRE B1-303_2016:
Systematic Description of Dynamic Load for Cables for Offshore Wind Farms. Method and
Experience” outlines the methodology for reducing that data to calculate the current rating for
dynamic loading. Appendix D4 in CIGRE TB 610 (Offshore generation cable connections) also
provides information on dynamic loading calculations.

C-2 (Wiring Methods High Voltage)

Submarine cable standards addressed:

• Recommended standards:
o IEC 63026
o Not specific to subsea cable, should be used in conjunction with CIGRE
documents below: IEC 62067, IEC 60840, and IEC 60228
o DNVGL-ST-0359
o CIGRE TB 490, CIGRE TB 496, CIGRE TB 610, CIGRE TB 623, and
CIGRE TB 784.
• Other relevant standards (not specific to subsea cable; should be used in conjunction with
CIGRE documents mentioned earlier):
o AEIC CS9, ICEA S-108-720
o IEEE C2 (NESC), IEEE 404, and IEEE 1300.

53
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 C-12 (Cable Testing)

Standards addressed:

• Recommended standards:
o IEC 60230, IEC 60229, IEC 60287, and IEC 60811-501
o CIGRE TB 303, CIGRE TB 490, CIGRE TB 623, and CIGRE TB 722
• Other relevant standards (not specific to subsea cable):
o AEIC CS8 and AEIC CS9
o ICEA P-32-382, ICEA P-45-482, ICEA S-94-649, ICEA T-24-380, ICEA T-
31-610, ICEA T-32-645, and ICEA T-34-664
o IEEE 48.

6.4 Submarine Cable Installation

The installation process presents the highest risk for human error to impact cable performance.
Careful planning and qualified personnel can mitigate some of the risks inherent to installation.
Specific standards for cable installation are provided in the AWEA OCRP 2012.

Guidance for submarine cable joints and terminations can be found in:

• CIGRE TB 490 and CIGRE TB 610

• IEC 60859 (Cable Connections for Gas-Insulated Metal-Enclosed Switchgear for Rated
Voltages of 72.5 kV and Above – Fluid-filled and Extruded Insulation Cables – Fluid-Filled
and Dry Type Cable - Terminations). Please note, however, that this standard has been
withdrawn and replaced by IEC 62271-209 (High-voltage switchgear and controlgear - Part
209: Cable connections for gas-insulated metal-enclosed switchgear for rated voltages above
52 kV - Fluid-filled and extruded insulation cables - Fluid-filled and dry-type cable-
terminations)
• IEEE 48 (Standard for Test Procedures and Requirements for Alternating-Current Cable
Terminations Used on Shielded Cables Having Laminated Insulation Rated 2.5 kV through
765 kV or Extruded Insulation Rated 2.5 kV through 500 kV)
• IEEE 404 (Standard for Extruded and Laminated Dielectric Shielded Cable Joints Rated 2.5
kV to 500 kV); one participant stated that this standard is incompatible with the IEC/CIGRE
submarine cable standards
• IEEE 1300 (Guide for Cable Connections for Gas-Insulated Substations); one participant
noted that this is a copy of the IEC 60859 standard
• CIGRE TB 784 (Standard design of a common, dry type plug-in interface for GIS and power
cables up to 145 kV)
• Joining two different types of cable: CIGRE TB 303 (Revision of qualification procedures
for high voltage and extra high voltage AC extruded underground cable systems).

54
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
6.5 Submarine Cable Flammability
Although cable flammability is not a concern underwater, it should be considered for the portion
of the cable that enters a wind turbine or substation and is exposed to air. The level of fire
protection required depends on the classification of the offshore structure (e.g., manned,
unmanned, not normally manned) and the corresponding risk that personnel could be exposed to
a fire. CIGRE TB 720 (Fire issues for insulated cables in air) provides guidance on the selection
of materials for fire safety as well as fire suppression techniques. Other standards relevant to
cable flammability testing are listed under item C-6 in Table D-1.

Submarine cables will not be supplied with a coating over the individual cable cores that is flame
resistant or retardant. Where the cable cores are broken out of the armor protection after the
armor hang-off, the cable cores should be either placed in a metallic, nonmagnetic cable raceway
or, alternately, continuously covered with a flame-retardant tape or covering material from the
hang-off to the cable termination to protect the cable core jackets from flames and to contain a
cable jacket fire. See CIGRE TB 720 for recommendations to protect cable. If halogen gas or
smoke is of concern, the raceway or covering should be designed to route the gas or smoke away
from the areas of concern and to vent to a safe exterior location in the case of a cable fire.
Locating and/or pulling the cables into individual conduits or pipes will most likely not be
practical and could be more of a safety hazard to the crew trying to pull the cables into pipes.

API RP 14F was identified during the workshop as a potential source of information for
determining the classification of the offshore structure. When examined in detail, however, the
standard’s references to umbilical cables are specific to the oil and gas industry and do not apply
to offshore wind array and export cables.

C-6 (Cable flammability testing)

Standards addressed:

• Recommended standards:
o CIGRE TB 720.

6.6 Operation and Maintenance

Normal operation of submarine power cables should not require active intervention. Periodic
inspection along the cable route should be carried out to detect any changes in the depth of
buried cables—in particular, exposure as a result of scour, subsidence, sand waves, and so on—
or mechanical damage to the cable. Cables may also be designed with integrated fiber optic
sensors that can detect changes in burial depth, strain, or temperature along the cable. If a cable
becomes exposed, reburial or additional protection may be needed. Initial cable characterization
using a method such as optical time domain reflectometry can provide a basis for comparison if a
fault occurs.

Advance preparation of a repair plan is strongly recommended. After a fault has occurred, repair
planning becomes time critical and mistakes or omissions that compromise safety are more
likely. Guidance for developing a repair plan can be found in CIGRE TB 773 (Fault location on

55
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
land and submarine links (AC & DC)). The information in IEEE 1234 (Guide for Fault-Locating
Techniques on Shielded Power Cable Systems) is similar, but its focus is primarily on power
cables installed on land. Key elements of a repair plan include:

• Obtaining spare parts and cable

• Storing spare stock appropriately so that it achieves its expected shelf life and replacing it as
needed
• Identifying local contractors with expertise and equipment available for cable locating, fault
locating, and cable repair
• Establishing agreements with identified contractors to provide timely response and repair for
any cable problem that may arise
• Specifying a safe operating plan for repair operations.

The safe operating plan should cover shutdown procedures, lockout/tagout procedures and
communication, and induced voltage procedures. Acceptable standards for safe working
practices near subsea cables are listed under item B-5 in Table D-1. IEEE 1727 (Guide for
Working Procedures on Underground Transmission Circuits with Induced Voltage) and CIGRE
B1-115_2018 (Safe Work on HV Extruded Insulation Cable Systems under Induced Voltages),
which provide guidance on safety for working on a deenergized line in proximity to an energized
line. Safety during diving operations is covered by the Association of Diving Contractors
International Consensus Standards for Commercial Diving and Underwater Operations (6th Ed.,
Rev. 6.3, 2019) and the International Marine Contractors Association (IMCA) international code
of practice for offshore diving (IMCA D 014 Rev. 2.1, 2019).

B-5 (Work on Submarine Cables)

Standards addressed:

• Recommended standards:

o IEC 60204
o CIGRE TB 773
o IEEE 1727 and IEEE 1234.

6.7 Decommissioning
Current guidance from BOEM in 30 CFR § 585 requires developers to include the cost of
decommissioning (i.e., removing the cable and returning the site to its original condition, subject
to an environmental impact assessment). Because of the disturbance to the seabed when
removing a buried cable, the conclusion of the environmental impact assessment may be a
recommendation to leave the cables in situ.

56
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
7 Next Steps
Understanding the design and safety implications of the various proven European design
methods and existing U.S. codes and standards is essential for the maturation of the U.S.
offshore wind industry. The Offshore Wind Electrical Safety Standards Harmonization
Workshop held on February 11–12, 2020, at NREL’s Flatirons Campus near Boulder, Colorado,
and this report, which documents the proceedings of the workshop, represent a major step in the
process to implement safe design and safety practices for offshore wind facilities on the U.S.
Outer Continental Shelf.

This publication can now serve as a near-term reference to inform project design and approvals,
thereby leveraging these workshop proceedings to help inform U.S. industry-recommended
practices, which are under development by the AWEA Wind Technical Standards subcommittee.
The primary next step is to complete the current AWEA/ANSI U.S. offshore wind standards
initiative and publish a suite of five offshore recommended practices documents. A formal
AWEA/ANSI approval process for these recommended practices includes vital procedural
safeguards that will allow BOEM/BSEE to reference them in future revisions to 30 CFR § 585,
and, if appropriate, explicitly quote them in regulations.

In the interim period, we recommend that work continue to update Table D-1 to reflect the most
current thinking, as there was not enough time during the workshop to complete this discussion.
This could be accomplished through additional workshops held while the more formal OCRP
recommendations are being finalized. This would allow BOEM/BSEE to engage individually
with industry representatives to gather more candid information.

Additionally, BOEM/BSEE could engage directly with the land-based wind community and
NRTLs to incorporate their experience integrating the international land-based wind industry
into the U.S. market.

Finally, a key component to the safety of workers employed during the construction and
operation of U.S. offshore wind facilities will be proper workforce training. It is essential that the
U.S. industry develop workforce training and health and safety protocols that integrate with the
electrical safety standards discussed in this report, and which comply with and facilitate the
BOEM/BSEE safety management system requirements. These activities should be initiated
immediately and proceed in parallel with the development of the OCRP recommended practices.

57
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
8 References
American Wind Energy Association. 2012. AWEA Offshore Compliance Recommended
Practices. Recommended Practices for Design, Deployment, and Operation of Offshore Wind
Turbines in the United States. https://offshorewindhub.org/sites/default/files/resources/awea_9-
16-2012_oswrecommendedpractices.pdf.

Electric Power Research Institute. 2016. EPRI Underground Transmission Systems Reference
Book: 2016, Chapter 11

CIGRE. 2016. Systematic description of dynamic load for cables for offshore wind farms.
Method and experience. CIGRE B1-303_2016. https://e-cigre.org/publication/B1-303_2016

CIGRE. 2018. Safe Work on HV Extruded insulation Cable Systems under induced Voltages.
CIGRE B1-115_2018. https://e-cigre.org/publication/SESSION2018_B1-115.

58
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
9 List of Primary Standards
This list represents the standards that are referred to in the body of the report but is not a
comprehensive list of the standards in Table D-1.

Table 1. List of Primary Standards Referenced in Report

Standards # Topic Covered

AEIC CS9 Specification for extruded insulation power cables and their accessories
rated above 46 kV through 345 kVAC

ANSI/NETA Standard for Acceptance Testing Specifications for Electrical Power

ATS Equipment and Systems

ANSI C57 Standard for Low-Voltage Transformers and Reactors

Series

API RP 14C Analysis, Design, Installation, and Testing of Basic Surface Safety Systems
for Offshore Production Platforms; 30 CFR 250.1628(c)

API RP 14F Design and Installation of Electrical Systems for Offshore Production
Platforms; 30 CFR 250.114(c)

ASTM F1506 Standard Performance Specification for Flame Resistant and Electric Arc
Rated Protective Clothing Worn by Workers Exposed to Flames and Electric
Arcs

AWEA OCRP AWEA Offshore Compliance Recommended Practices 2012

2012

CIGRE B1- “Safe Work on HV Extruded insulation Cable Systems under induced
115_2018 Voltages”

CIGRE B1- “Systematic description of dynamic load for cables for offshore wind farms.
303_2016 Method and experience”

CIGRE B3.26 Guidelines for the Design and Construction of AC Offshore Wind Farms

CIGRE TB 303 Revision of qualification procedures for high-voltage and extra-high-voltage

AC extruded underground cable systems

CIGRE TB 490 Recommendations for testing of long AC submarine cables with extruded
insulation for system voltage above 30 (36) to 500 (550) kV

59
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Standards # Topic Covered

CIGRE TB 496 Recommendations for Testing DC Extruded Cable Systems for Power
Transmission at a Rated Voltage up to 500 kV

CIGRE TB 610 Offshore Generation Cable Connections

CIGRE TB 623 Recommendations for Mechanical Testing of Submarine Cables

CIGRE TB 720 Fire issues for insulated cables in air

CIGRE TB 722 Recommendations for additional testing for submarine cables from 6 KV up
to 60 KV

CIGRE TB 773 Fault location on land and submarine links (AC and DC)

CIGRE TB 784 Standard design of a common, dry-type plug-in interface for GIS and power
cables up to 145 kV

CAN/CSA- Wind Turbine Electrical Systems

C22.2 No. 272

CSA C22.2 CSA C22.2 No. 0.4 - Bonding of Electrical Equipment

CSA C22.2 CSA C22.2 No. 41 - Grounding and Bonding Equipment

CSA SPE-1000- Model Code for the field evaluation of electrical equipment
13

CSA Z462 Workplace Electrical Safety (Based on NFPA 70E)

DNVGL-ST- Subsea power cables for wind power plants

0359

DNVGL-ST- Subsea power cables in shallow water

0360

DNVGL-ST-145 Offshore substations

EN 61034-2 Measurement of smoke density of electric cables burning under defined

conditions - Part 2: Test procedure and requirements

ICEA S-108-720 Standard for Extruded Insulation Power Cables Rated Above 46 Through
500 KV AC

60
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Standards # Topic Covered

IEC 60034 Rotating electrical machines

series

IEC 60204-1 Safety of machinery - Electrical equipment of machines - Part 1: General

requirements

IEC 60204-11 Safety of machinery - Electrical equipment of machines - Part 11:

Requirements for equipment for voltages above 1,000 V AC or 1,500 V DC
and not exceeding 36 kV

IEC 60287 Electric cables - Calculation of the current rating

IEC 60364 Low-voltage electrical installations

IEC 60364-7- Low-voltage electrical installations - Part 7-729: Requirements for special
729 installations or locations - Operating or maintenance gangways

IEC 60502-2 Power cables with extruded insulation and their accessories for rated
voltages from 1 kV (Um = 1,2 kV) up to 30 kV (Um = 36 kV) – Part 2: Cables
for rated voltages from 6 kV (Um = 7,2 kV) up to 30 kV (Um = 36 kV)

IEC 60840 Power cables with extruded insulation and their accessories for rated
voltages above 30 kV (Um = 36 kV) up to 150 kV (Um = 170 kV) – Test
methods and requirements

IEC 60909-0 Short-circuit currents in three-phase a.c. systems - Part 0: Calculation of

currents

IEC 61034-2- Measurement of smoke density of cables burning under defined conditions
2005 - Part 2: Test procedure and requirements

IEC 61039 Classification of insulating liquids

IEC 61400-1 Wind energy generation systems – Part 1: Design requirements

IEC 61400-3-1 Wind energy generation systems – Part 3-1: Design requirements for fixed
offshore wind turbines

IEC 61400-3-2 Wind energy generation systems – Part 3-2: Design requirements for
floating offshore wind turbines

IEC 61482-2 European equivalent to ASTM F1506 for the thermal hazards of an arc
flash. The standard includes requirements for material testing and
additional information for garments constructed from compliant materials.

61
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Standards # Topic Covered

This is required for selling garments for arc flash protection in the European
Union.

IEC 61936-1 Power installations exceeding 1 kV a.c. - Part 1: Common rules

IEC 61914 Cable Cleats for Electrical Installations

IEC 62067 Power cables with extruded insulation and their accessories for rated
voltages above 150 kV (Um = 170 kV) up to 500 kV (Um = 550 kV) – Test
methods and requirements

IEC 62271-200 High-voltage switchgear and controlgear - Part 200: AC metal-enclosed

switchgear and controlgear for rated voltages above 1 kV and up to and
including 52 kV

IEC 62271-203 High-voltage switchgear and controlgear - Part 203: Gas-insulated metal-
enclosed switchgear for rated voltages above 52 kV

IEC 62477-1 Safety requirements for power electronic converter systems and
equipment - Part 1: General

IEC 62477-2 Safety requirements for power electronic converter systems and
equipment – Part 2: Power electronic converters from 1,000 V AC or 1,500
V DC up to 36 kV AC or 54 kV DC

IEC 63026 Submarine power cables with extruded insulation and their accessories for
rated voltages from 6 kV (Um = 7,2 kV) up to 60 kV (Um = 72,5 kV) - Test
methods and requirements

IEC TR 61641 Enclosed low-voltage switchgear and controlgear assemblies - Guide for
testing under conditions of arcing due to internal fault

IECRE OD-501 Type and component certification scheme

IECRE OD-502 Project certification scheme

IEEE C2 (NESC)

IEEE C37.20 Guide for low-voltage and medium-voltage arc gear

IEEE C37 90.1 Standard for Surge Withstand Capability (SWC) Tests for Relays and Relay
Systems Associated with Electric Power Apparatus

62
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Standards # Topic Covered

IEEE C37.122 Guide for Gas-Insulated Switchgear, specific to High Voltage

IEEE 1234 Guide for Fault-Locating Techniques on Shielded Power Cable Systems

IEEE 1300 Guide for Cable Connections for Gas-Insulated Substations

IEEE 1547 EEE Standard for Interconnection and Interoperability of Distributed Energy
Resources with Associated Electric Power Systems Interfaces

IEEE 1584 IEEE Guide for Performing Arc Flash Hazard Calculations

IEEE 1727 Guide for Working Procedures on Underground Transmission Circuits with
Induced Voltage

IEEE 404 Standard for Extruded and Laminated Dielectric Shielded Cable Joints Rated
2.5 kV to 500 kV

IEEE 519 Standard for Point of Interconnection

IEEE 946 Recommended Practice for the Design of DC Auxiliary Power Systems for
Generating Stations

IEEE 80 Guide for Safety in AC Substation Grounding

IEEE 837 Standard for Qualifying Permanent Connections Used in Substation

Grounding

IEEE 44 (or Recommended Practice for Installation Design and Installation of Vented
484) Lead-Acid Batteries for Stationary Applications

ISO 12100 Safety of machinery – General principles for design – Risk assessment and
risk reduction

ISO 14122-1 Safety of machinery ― Permanent means of access to machinery ― Part 1:

Choice of fixed means and general requirements of access

ISO 14122-4 Safety of machinery ― Permanent means of access to machinery ― Part 4:

Fixed ladders

ISO 4413 Hydraulic fluid power — General rules and safety requirements for systems
and their components

ISO 9001 Quality Management

63
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Standards # Topic Covered

NACE RP-01 Corrosion Protection

NEMA 250 Enclosures for Electrical Equipment (1,000 Volts Maximum)

NEMA Degrees of Protection Provided by Enclosures (IP Code) (Identical National

ANSI/IEC Adoption)
60529

NFPA 70 Standard for Electrical Safety in the Workplace, Chapter 1, Articles 100-130
― Working on or near live equipment

NFPA 70B Recommended Practice for Electrical Equipment Maintenance

NFPA 70E Standard for Electrical Safety in the Workplace; Chapter 1, Articles 100-130
― Working on or near live equipment

NFPA 79 Electrical Standard for Industrial Machinery

NFPA 780 Lightning Protection

NFPA 2001 Standard for Clean Agent/Inert Gas Fire Suppression

OSHA 29 CFR Occupational Safety and Health Standards

1910

OSHA 29 CFR Special Industries

1910 Subpart R

OSHA 29 CFR Electrical

1910 Subpart S

OSHA 29 CFR Ladders

1910.23

OSHA 29 CFR Personal Protection Equipment

1910.137

OSHA 29 CFR Lockout/Tagout (LO/TO)

1910.147

OSHA 29 CFR Electric Power Generation, Transmission, and Distribution ― Fixed ladders
1910.269(h) inside wind turbine towers

64
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Standards # Topic Covered

OSHA 29 CFR Working on or near exposed energized parts (Construction)

1926.960

UL 1004 series Standard for Rotating Electrical Machines

UL 1598 Luminaires

UL 467 Standard for Grounding and Bonding Equipment

UL 508 Standard for Industrial Control Equipment

UL 508A Standard for Industrial Control Panels

UL 508C Standard for Power Conversion Equipment

UL 2277 Standard for Construction Specifications

UL 6141 Standard for Wind Turbines Permitting Entry of Personnel

UL 61800-5-1 Standard for Adjustable Speed Electrical Power Drive Systems - Part 5-1:
Safety Requirements – Electrical, Thermal and Energy

UL 845 Standard for Motor Control

UL 1053 Standard for Safety Covering Ground Fault Protection

UL 1558 Standard for Metal-Enclosed Low-Voltage Power Circuit Breaker Switchgear

65
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Appendix A. Attendee Information
The table below provides a list of the attendees of the workshop who were the primary subject
matter experts who guided the content of this report.

Table A-1. Workshop Attendee List

Attendee Name Attendee Affiliation Break-Out Group

Tom Buchal Independent Consultant Turbines
Edgar DeMeo Renewable Energy Consulting Services Turbines
Jens Brix Due Siemens Gamesa Renewable Energy Turbines
Albert Fisas GE Renewable Energy Turbines
Michelle Fogarty National Renewable Energy Laboratory Turbines
(NREL)
Jonas Gertz Jensen Ørsted Turbines
Samuel H. Hawkins Siemens Gamesa Renewable Energy Turbines
Cheri Hunter Bureau of Safety and Environmental Turbines
Enforcement (BSEE)
Geoff Neild Vineyard Wind Turbines
Benjamin Palethorpe GE Renewable Energy Turbines
Christian Pohl Nexans Turbines
Christian Storbeck UL LLC Turbines

Jack Arruda Vineyard Wind Substations

Hendrik Berends RWE Renewables GmbH Substations
Brandon Burke Business Network for Offshore Wind Substations
Dave Burns Shell Substations
Emily Chambers Business Network for Offshore Wind Substations
Darryl Francois Bureau of Ocean Energy Management Substations
Jonathan Howie Energie Baden-Württemberg North Substations
America
Svein Johansen Equinor ASA Substations
Daniel Katz Ørsted Substations
Steven Kunsman ABB Substations
Nick Matone Burns & McDonnell Substations
Walt Musial NREL Substations

66
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 George Nichol GE Substations
Shane O’Sullivan Ørsted Substations
Juan Luis Paredes Ortiz Avangrid Substations
Stephan Schwab WSP Substations
Hongbiao Song GE Substations

Chloe Constant NREL Cables

Aubryn Cooperman NREL Cables
Joseph Cunningham Scottish Power/Avangrid Cables
Georg Engelmann Excipio Energy Cables
David Grassbaugh Ørsted Cables
Robert Hobson NKT Cables
Paul Knapp UL LLC Cables
Darin Lawton Burns & McDonnell Cables
Sabrina Morelli American Wind Energy Association Cables
David Nedorostek BSEE Cables
Maxime Toulotte Nexans Cables
Bill Wall LS Cable America Cables

67
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Appendix B. Workshop Agendas
Offshore Wind Electrical Safety Standards Harmonization Workshop

Tuesday, February 11 through Wednesday, February 12, 2020, at the Flatirons Campus
National Renewable Energy Laboratory (NREL)
18200 Highway 128 Boulder, CO 80303

Table B-1. Day 1 – Plenary Session (February 11, 2020)

Time Activity Speaker

8:00― 8:15 a.m. Flatirons Campus Arrival and Check- NREL’s Flatirons Guard Gate
In
8:15― 8:45 a.m. Network/Lite Breakfast All
8:45― 9:00 a.m. Welcome, Meeting Objectives, and Walt Musial (NREL
Introductions Cheri Hunter (Bureau of Safety and
Environmental Enforcement [BSEE])
Darryl Francois (Bureau of Ocean Energy
Management)
9:00― 9:30 a.m. BSEE Perspective on U.S. Offshore Cheri Hunter and David
Wind Electrical Safety Issues Nederostek/Darryl Francois
(BSEE/BOEM)
“Why are we here?”
9:30―9:45 a.m. Overview of Offshore and Offshore Walt Musial (NREL)
Wind National Standards Initiative
9:45– 10:15 a.m. U.S. Offshore Wind Recommended Albert Fisas (GE) Offshore Compliance
Practices Status – Offshore Recommended Practices – Maintenance
Compliance Recommended Practice Team Delegate – “Status of OCRP-1”
(OCRP)-1
10:15― 10:30 a.m. Break All
10:30―noon Session 1: Participant Presentations Chair: Ed DeMeo―(NREL Consultant;
on Wind Plant Electrical Safety and Workshop Chair)
Discussion
Industry Speakers:
• Samuel Hawkins (Siemens
Gamesa) “OEM approach to
electrical safety standards”
• Steven Kunsman (ABB)
“Assessment of Secondary system
issues including protection,
control, automation, and cyber
security”
• George Nichol (GE) “Offshore
substations & equipment
standards and lessons learned

68
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Time Activity Speaker
(gas-insulated switchgear and
high-voltage DC)”
12:00― 1:00 p.m. Lunch (brought in) All
1:00 2:30 p.m. Session 2: Participant Presentations Chair: Ed DeMeo―Workshop Chair
on Electrical Safety for Offshore
Substations and Discussion Industry Speakers:
• Joseph Cunningham (Avangrid)
“Assessment of U.S. Electrical
Safety Regulations”
• Hugo Avila (presented by Steven
Kunsman) (ABB) “Assessment of
High Voltage Primary Equipment
Issues”
• Steven Kunsman
(ABB)“BOEM/Moffat and Nichols
Report”
2:30―2:45 p.m. Break All
2:45― 3:45 p.m. Session 3: Participant Presentations Chair: Ed DeMeo
on Electrical Safety for Offshore
Subsea Cables and Discussion Industry Speaker:
• Bob Hobson (NKT Inc.) “Status of
AWEA Working Group 5
Recommended Practices for
Submarine Cables”
3:45― 4:00 p.m. Break All
4:00― 5:00 p.m. Introduce Breakout Groups Facilitation: Ed DeMeo; Breakout Groups
1) Turbines Will Briefly Assemble and Work Out
2) Substations Reporting, Facilitation, and Protocols.
3) Subsea Cables Create a List of Key Issues to be Discussed
on Day 2
5:00 p.m. Adjourn for the Day All
6:30 p.m. No-Host Dinner (TBD) Sign-Up at Registration

69
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Table B-2. Day 2 – Breakout Group Discussions (February 12, 2020)
Time Activity Speaker
8:00―8:15 a.m. Flatirons Campus Arrival and NREL’s Flatirons Guard Gate
Check-In
8:15―8:45 a.m. Network/Lite Breakfast All
8:45―9:00 a.m. Review Plenary Breakout Group Ed DeMeo (NREL Consultant)
Objectives and Report-Out
Guidance
9:00―9:15 a.m. Break and Assemble into All
Breakout Sessions
9:15―noon (Three) Facilitated Break-Out Breakout Organizers:
Sessions Meet Concurrently: 1) Facilitator/Chapter Lead
Turbines, 2) Substations, and 3)
Subsea Cables Turbines: Ed DeMeo/Michelle
Fogarty
Breakout Facilitators Will Substations: Brandon Burke/Emily
Prescribe Their Own Coffee Chambers
Breaks When Convenient Subsea Cables: Chloe
Constant/Aubryn Cooperman
Notetakers Will be Assigned to
Each Breakout Froup
12―1:00 p.m. Lunch (brought in) All
1:00―2:30 p.m. Breakout Groups Report-Out (30 Breakout Facilitators
min Each with Q&A)
Presentation: Hendrik Berends
(RWE) “Overview of Electrical Safety
at RWE Windfarms during
Construction and Commissioning”
2:30―3:00 p.m. Wrap-UpSteps Forward, Ed DeMeo (NREL Consultant)
Assignments
3:00 p.m. Adjourn

70
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Appendix C. Workshop Presentation Materials

71
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Offshore Wind Electrical Safety
Standards Harmonization Workshop
Welcome and Opening
Walt Musial
Principal Engineer, National Renewable Energy Laboratory (NREL)
Chairman, American Wind Energy Association (AWEA) Offshore
Wind Subcommittee

Offshore Wind Electrical Safety Standards Harmonization Workshop

Tuesday, Feb 11-12, 2020, at the Flatirons Campus,
National Renewable Energy Laboratory
National Wind Technology Center
 Opening Comments

• Welcome
• Introductions
• Call-in protocol
• Meals and refreshments
• Bureau of Ocean Energy Management (BOEM)/Bureau of
Safety and Environmental Enforcement (BSEE) Opening
Remarks
• NREL overview
NREL | 2
 Electrical Standards Project Objectives
• Objective for the Overall Project:
– Develop and document published, publicly available “record of expert opinion” for application of
relevant electrical safety standards in domestic offshore wind installations
– Inform Offshore Compliance Recommended Practices (OCRP)-1 to help deliver an American
National Standards Institute (ANSI)-approved offshore wind electrical safety standard
• Project Approach
– Develop a list of relevant standards
– Compare and contrast relevant standards from both Europe and the United States
– Identify significant differences, and offer recommendations on resolution or acceptance of
differences, based on understood real-world consequences (level of risk)
– Produce a public guidance report on Workshop outcome
• Objectives for the Workshop:
– Review recent efforts to identify relevant standards from both Europe and the United States
– Identify and assess commonalities and differences; highlight differences to understand magnitude
of material consequences
– Discuss differences and propose resolutions for most significant discrepancies
– Summarize range of views in cases not amenable to immediate resolution
– Compile information from the discussions relevant to preparation of the guidance document
NREL | 3
Messaging + Blue
NREL Science
Infographic
Drives Innovation
Content

Renewable Sustainable Energy Energy Systems

Power Transportation Efficiency Integration
Solar Bioenergy Buildings Grid Integration
Wind Vehicle Technologies Advanced Manufacturing Hybrid Systems
Water
Hydrogen Government Energy
Geothermal Management
NREL | 4
NREL Quick Facts
• 2,685 Employees, Postdoctoral Researchers,
Interns, Visiting Professionals, and
Subcontractors
• Patents Issued for NREL Technologies to Date 571
• More than 1,700 Scientific and Technical Materials
Published Annually
• 3 National Centers
• 16 Research Programs
• 871 Active Partnerships with Industry,
Universities, Foundations, and Governments
• More than 70 Countries Represented by Staff
• 65 R&D 100 Awards

NREL | 5
 NREL’s Flatirons Campus
• The National Wind Technology Center (NWTC) at the Flatirons Campus was established in 1977 and is an ideal setting
for evaluating the reliability and performance of wind turbines. Approximately 150 staff work on-site in Wind and
Marine Hydrokinetic technology.
• Key land-based and offshore wind research facilities:
 Structural research  Field validation sites
 Dynamometer research  Composites Manufacturing Education and Technology (CoMET)
 Controllable Grid Interface (CGI)  High-Performance Computing (HPC)
 Energy storage  Integrated energy systems at scale

NREL | 6
Workshop Agenda—Page 1

NREL | 7
Workshop Agenda—Page 2

NREL | 8
 Offshore Wind Electrical Safety Standards Workshop Roles
Plenary Session
Facilitator: Ed DeMeo
Chapter Leads: Brandon Burke and Emily Chambers

Turbine Breakout Substations Breakout Submarine Cables Breakout

Facilitator: Ed DeMeo Facilitator: Brandon Burke Facilitator: Chloe Constant
Chapter Lead: Michelle Fogarty Chapter Lead: Emily Chambers Chapter Lead: Aubryn Cooperman
Medium/small conference room Large conference room East Conference Room

Logistics: Cyndi Edgley Contracting: Tiffany

Report: Walt/Ed (overall)
• Food and refreshments • Business Network for Offshore
• Outline (Walt)
• Site access Wind (BNOW)
• Compile/post presentations
• Communication • BOEM/BSEE
• Key findings
• Badges and registration • Reporting
• Chapters – chapter leads
• Social event planning • Ed DeMeo
• Editing and oversight
• Project meetings
 Workshop Organizing Team

• Walt Musial—Principal Investigator and host

• Ed DeMeo—Workshop lead moderator
• Brandon Burke—BNOW
• Emily Chambers—BNOW
• Michele Fogarty—NREL
• Chloe Constant—NREL
• Aubryn Cooperman—NREL
• Cyndi Edgley—NREL
• Rebecca Green—NREL

NREL | 10
 Workshop Sponsors—BSEE and
BOEM
• Cheri Hunter—BSEE

• David Nederostek—BSEE

• Darryl Francois—BOEM

NREL | 11
Why We Are Here

David Nedorostek, BSEE Senior Electrical Engineer

Cheri Hunter, BSEE Renewable Energy Program Coordinator
Darryl Francois, BOEM Office of Renewable Energy Programs

Offshore Wind Electrical Safety Standards Harmonization Workshop

Tuesday, Feb 11-12, 2020 at the Flatirons Campus,
National Renewable Energy Laboratory
National Wind Technology Center NREL | 12
 Contents

1 Workplace Safety
2 OCS Renewable Energy Authorization Process
3 Industry Plan Review
4 Comparison of Electrical Safety Standards
5 Next Step: Peer Review

NREL | 13
 Workplace Safety

• The Department of the Interior (DOI) is the principal federal

agency for the regulation and enforcement of safety and
health requirements for outer continental shelf (OCS)
renewable energy
– Offshore wind traditionally uses international standards
– BSEE/BOEM have due diligence requirement to ensure
the safest standards are used
– Public expectation is a robust comparison to U.S.
standards with a focus on safety
NREL | 14
 OCS Renewable Energy
Authorization Process
Construction
Planning & Site
Leasing &
Analysis Assessment
Operations

2 Years 1-2 Years 5 Years 2 Years (+25)

• Intergovernmental task • Proposed sale notice • Site characterization • Construction &

force (i.e., geophysical and operations plan
• Final sale notice geological surveys,
• Call for information & biological surveys, and • Facility design report
nominations (Call) • Auction
so on)
• Fabrication and
• Area identification • Issue leases installation report
• Site assessment plan
• Environmental reviews • Decommissioning

NREL | 15
 Industry Plan Review

• BSEE partners with BOEM to review industry submissions

(construction and operations plans, facility design reports,
fabrication and installation reports)
• U.S. offshore electrical wind industry standards are under
development
• BSEE created a comparison of U.S. versus international
electrical safety standards to assist BSEE/BOEM engineers in
performing a comprehensive assessment of a project’s
electrical design
NREL | 16
 Comparison of Electrical Safety
Standards
• The list of standards is a starting point for establishing U.S.-specific
expectations for offshore wind electrical safety
• The list of standards will continue to evolve as BSEE/BOEM and
industry identify best practices
• Purpose:
– Highlight available standards
• United States
• European
• Canadian
• harmonized
• (incorporating international and U.S-specific requirements)

NREL | 17
 Comparison of Electrical Safety
Standards
• Includes a list of electrical equipment subdivided into three
categories:
– Design (lightning protection, switchgear, transformer)
– Procedures (personal protective equipment [PPE], lock-
out/tag-out [LO/TO], equipment guarding ) and
– Reliability design (marine cable, uninterruptable power supply
(UPS)

The list focuses on what BSEE/BOEM have initially identified to be the

most safety-critical electrical equipment and procedures.
NREL | 18
 Comparison of Electrical Safety
Standards
• Table review:
– Does the list of standards focus on most safety-critical
electrical equipment?
– Is critical electrical equipment categorized properly?
– Are all the applicable electrical safety standards for each
electrical component captured?
– Should certification be done by a Nationally Recognized
Testing Laboratory for functionality and performance?

NREL | 19
 Comparison of Electrical Safety
Standards
Why We Are Here
Next step: Peer review
• International and U.S. electrical standards experts
• Members of Offshore Wind Technical Advisory Committee
(U.S. industry consensus-based, ANSI-approved,
recommended practice document)

NREL | 20
 U.S. Offshore Wind
Standards Initiative
Walt Musial
Principal Engineer, NREL
Chairman, AWEA Offshore Wind Subcommittee

Offshore Wind Electrical Safety Standards Harmonization Workshop

Tuesday, Feb 11-12, 2020 at the Flatirons Campus,
National Renewable Energy Laboratory
National Wind Technology Center
Organizers and Sponsors

Walt Musial

Liz Burdock
Elizabeth Barminski

Sabrina Morelli
Michele Mihelic
Tom Vinson

Mike Derby
Gary Norton

Darryl Francois
Dan O'Connell
Sid Falk
Cheri Hunter/John Cushing – BSEE
BOEM/BSEE Authority to Regulate Offshore Wind
 The Energy Policy Act of 2005 authorized BOEM to grant leases on
the Outer Continental Shelf for offshore renewables and to
promulgate any necessary regulations
 30 CFR 585 rule was issued in 2009, covering the offshore wind
facility development process cradle to grave; does not specify
standards and requires best practices to be used
 From 2009-2012, the industry developed AWEA OCRP 2012, a
consensus-based roadmap to facilitate “best industry practices”

 U.S. consensus standards and guidelines can be:

 Adopted by developers to guide project design and approval
 Referenced by BOEM in 30 CFR 585
 Explicitly quoted in regulations
 Initiative on U.S. Offshore Wind Standards

Project Objective
To develop a comprehensive set of consensus-based roadmaps to navigate the
existing standards and guidelines to:
• Facilitate safe designs and orderly deployment of U.S. offshore wind energy
• Account for the unique offshore conditions on the U.S. Outer Continental
Shelf and state waterways
• Provide DOI with recommended practices of industry best practices with
procedural protections provided by ANSI process
 Why Do We Need U.S. Standards Roadmaps?

• Enable a more efficient regulatory process

• Provide more confidence in design approvals by regulators
• Increase clarity in the regulatory requirements for
developers and certified verification agents
• Create more transparency for the public
• Increase worker safety throughout the life of project
• Lower project cost
 AWEA Offshore Compliance Recommended Practice (OCRP) 2012
Current Best Practices

 AWEA OCRP 2012 is structured to mirror BOEM 30 CFR 585 “cradle

to grave”
 Dozens of standards and guidelines from various industries and
certifying bodies are cited and mapped to development process
 50+ stakeholders/subject matter experts participated between
2009 and 2012
 AWEA OCRP published in October 2012 as a Recommended
Practice Graphic source: NREL

http://awea.files.cms-plus.com/FileDownloads/pdfs/AWEA%20Offshore%20RP2012%20FINAL%202012%20October%2010.pdf

AWEA OCRP 2012 is a roadmap on how to use existing standards.

 Working Groups and Conveners

(WG1) AWEA Offshore Compliance Rain Byars – Shell Renewables

Recommended Practices (OCRP) Graham Cranston—SG&H Consultants
Maintenance Working Group OCRP1

(WG2) AWEA U.S. Floating Offshore Wind Lars Samuelsson—ABS

Systems Working Group OCRP2 Leif Delp—Equinor

(WG3) AWEA U.S. Offshore Wind Michael Drunsic—WSP

Metocean Conditions Characterization Lorry Wagner
Working Group OCRP3

(WG4) AWEA U.S. Geotechnical and

Matt Palmer—WSP
Geophysical Investigations and Design
Mathieu Guinard—Atkins
Working Group OCRP4

(WG5) AWEA Offshore Wind Submarine Georg Engelmann—Excipio Energy

Cables Working Group OCRP5 Bob Hobson—NKT HV Cables AB
U.S Offshore Wind Standards Initiative Organizational Structure

Electrical Electrical
Standards Standards
Major Steps in Developing the Recommended Practices
• Develop outline for recommended practice document
• Write first draft of recommended practice document
• Internal review of first draft (90 days)
Internal working group draft
Internal Working
•
• Final draft submitted for OWTAP and working groups
Group:
• OWTAP review comment period (60 days)
About 12 – 24
• Resolve OWTAP comments months
• Final committee draft

• Final draft submitted for approval by WTSC

• 30-day ballot period
External Working Group:
• Working Group resolves comments
About 12 months
• AWEA staff submit BSR-8 to ANSI
• Public comment is open for 45 days
• Review and resolve public comments
• (Optional appeal process)
• AWEA staff submit BSR-9 to ANSI
• ANSI approval process and publication

Process to finalize guidelines under AWEA/ANSI process may take too long.
Electrical Content in Draft Offshore Compliance
Recommended Practices (OCRP) 2nd Edition

Albert Fisas, GE Renewable Energy

Member OWTAP &
OCRP Working Group

February 10, 2020

Boulder, CO

Photo Credit : Dennis Schroeder-NREL

 Overview of OCRP WG1 Effort
The Working Group
● Offshore Wind Technical Standards Committee formed in Oct 2017 under
AWEA Wind Standards Committee, Chaired by Walt Musial
● Working Groups kicked off April 2018
● All volunteer, wide industry representation
● Working Group 1 – OCRP second edition

The OCRP
● Serves as a Roadmap for application of international and US requirements
to Offshore Wind in U.S. waters
● Addresses gaps, overlaps, and conflicts
● Does not intend to create new requirements
● Committee Draft on track for mid-2020
● Will be published as an American National Standard through AWEA/ ANSI
 Electrical Author Team
● Electrical standards identified as one of the gaps in 2012 OCRP

● Electrical sections in 2nd edition draft are written by a 28 member

author team made up of volunteers from across the industry
• Regulators • Consultants
• Developers • Contractors
• OEMs • Supply Chain
• CVAs • Academics

● Author team has conducted monthly or bi-weekly web-meetings and

bi-annual face to face meeting throughout 2018 and 2019 to reach
consensus on structure, topics, content, and reference standards.
 Electrical Content in Draft OCRP ed. 2

● General Sections
(introductory content, design basis, standards hierarchy, terms and
definitions, references)

● Chapter 5 – Design
• 5.6 Design of Offshore Wind Turbine

• 5.6.4 Electrical Design

• 5.6.5 Design for Occupational Health and Safety
• 5.7 Design of Offshore Substation
• 5.7.4 Electrical Design
• 5.7.5 Design for Occupational Health and Safety

Note: Sub-sea cables are addressed in RP being developed by WG5

 Standards referenced

See Chapter 11 of Draft OCRP

Electrical Standards Include

● US Electrical Standards (NFPA, ANSI, IEEE,
NEMA, UL, others)
● International Standards (IEC, ISO, CIGRE )
● US Offshore O&G Electrical Standards (API)
 Mapping – Workshop Topics/ Draft OCRP
Workshop Topic OCRP Chapter
A. Safety Design
A-1 Arc Flash 5.6.4.7 and 5.7.4.7
A-2 Emergency Stop 5.6.4.9
A-3 Spaces Around Cabinets 5.6.4.6 and 5.7.4.6
A-6, A-7 Switchgear 5.7.9.4
A-9 Transformers 5.6.4.8 and 5.7.4.8
A-11 Lightning Protection 5.6.4.10 and 5.7.4.10
A-13 WTG Electrical Systems 5.6.4.1
 Mapping – Workshop Topics/ Draft OCRP
Workshop Topic OCRP Chapter
B. Safety Procedures
B-3 Lock-Out Tag-Out 5.6.5.6 and 5.7.5.5
B-4 Equipment Guarding 5.6.4.5 and 5.7.4.5

C. Reliability Design
C-1 Safety Acceptance Testing 5.6.4.3 and 5.7.4.3
C-17 Wind Turbine Elevators 5.6.5.4
C-18 Hoist/ Winch/ Cranes 5.6.5.5 and 5.7.5.4
C-21 Emergency Power 5.6.4.13 and 5.7.4.13
C-22 Sockets and Plugs 5.6.4.11 and 5.7.4.11
C-25 Cathodic Protection 5.6.3.4.2 and 5.6.3.4.3
C-26 Grounding and Bonding 5.6.4.10 and 5.7.4.10
 Recommendations
• Use recommended practices and reference
standards from draft OCRP Ed 2
• Understand context of electrical sections within larger recommended
practice (introductory sections, design basis approach, interfaces,
different types of design oversight, acceptance testing, etc.)
Appendix D. Standards Comparison Table
Over the past several years, the Bureau of Safety and Environmental Enforcement (BSEE) has
been actively preparing for growth in applications for offshore wind power plants planned for the
U.S. Outer Continental Shelf. To this end, BSEE technical staff have been compiling electrical
safety standards to apply to domestic offshore installations. Recognizing that most existing
offshore wind power plants have been built in Europe and certified to European standards, BSEE
is examining similarities and differences among corresponding U.S. and European standards.
A key step in that process was BSEE’s assembly of a table listing relevant standards applicable
to major components, processes, and procedures associated with offshore wind construction and
operation. Table items were organized into three categories: safety design, safety procedures, and
reliability design. For each item, European and U.S. standards were listed side by side. 3 In early
2019, with the aim of improving the accuracy of the table contents, BSEE sought and received
feedback from several wind turbine original equipment manufacturers. That process elicited a
number of suggestions and proposed changes.
In late 2019, BSEE engaged NREL’s organizing team for the workshop covered in this report to
shape the draft table and its contents into a form likely to engender discussion and feedback from
a larger group of offshore wind industry participants. For each item in the table, the team posed a
number of questions, based on comments from BSEE and the previous original equipment
manufacturer reviewers. The revised table was sent to all participants prior to the workshop to
prompt relevant discussion during the event. Subsequent to the workshop, the table was revised
to reflect input from the meeting’s discussions. In addition, many of the questions were restored
to their original format as comments.
The revised postworkshop table was then sent to the members of the turbine breakout group for
additional feedback. The table was subsequently refined, based on additional input received.
Finally, the table was reviewed by all participants as part of their review of the entire workshop
report and revised once again to reflect additional input. For many of the table’s entries, there is
broad agreement. For others, there are differing views. In those cases, the organizers have
attempted to include the range of views expressed.
Through the iterative process described earlier, the organizing team believes that this table
provides relevant and accurate guidance to offshore wind power plant regulators as they consider
applications for offshore wind projects in the interim period before definitive regulatory
guidelines become available. It should be viewed as a work in progress that will evolve as the
offshore wind industry and BSEE engage over the coming months. Although the way forward is
clear in many cases, significant questions remain. For those cases open questions, the organizing
team’s hope is that this table provides information helpful to regulators as they apply their best
judgment to resolve any open issues.
The standards table in its current form follows.

3
In some cases, particular standards are listed in the table with double or even triple designations (e.g., International
Electrotechnical Commission (IEC) 61400-25-2 and DS/EN 61400-25-2 or IEC 60204-1, EN/IEC 60204-1, and BS EN
60204-1). Users of this table should be aware that there may or may not be material differences between versions of
standards with the same numbers. In most cases, the IEC version would be most applicable for U.S. installations.

109
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Table D-1. U.S. and International Offshore Wind Electrical Safety Standards Comparison Table

A. Safety Design

Ref Category Relevance International IEC and European Union (EU) United States Certification
Electrotechnical Directives
Commission (IEC)
A-1 Arc Flash/Arc Turbines IEC 61482-2 Occupational Safety and Health (OSH) Institute of Electrical and
Blast Analysis and IEC TR 61641 Framework Directive 89/391/EEC Electronics Engineers
Arc Flash Labeling i Substations IEC 62271-200 European Norm (EN) 50110-1 (IEEE) 1584
IEC 60909-0 National Fire Protection
Association (NFPA) 70E
Canadian Standards
Association (CSA) Z462
A-1 Comments
• All listed standards have similar requirements, but IEC and IEC and EU do not include arc flash labeling requirements.i
• The labeling requirement is standard for U.S. land-based wind, but perhaps new to offshore vendors in other markets. For other markets, hazards
are addressed in design and lockout/tagout (LO/TO) instructions, but application of an arc flash sticker is not standard. A suggested approach for
resolving this difference follows: IEC standards will yield a level of safety similar to that with the U.S. standards. Hence, use of IEC standards should
be acceptable to justify compliance, and then the arc flash sticker can be applied per IEEE 1584/NFPA 70E. However, if a sticker is used on IEC-
tested and -rated equipment, the boundary statement and other critical details should correlate to the IEC-defined levels. Although either system
could be acceptable for safety, the boundary or class definitions should not be mixed.
• The Bureau of Safety and Environmental Enforcement (BSEE) recommends that developers utilize NFPA 70E or IEEE approaches on arc flash labeling
requirements.
• Industry views IEEE 1584 and NFPA 70E as the most appropriate standards for the U.S. market.
• Arc flash labeling requirements can be aligned through BSEE’s Safety Management System.
• The above IEC standards could be followed for wind applications, with proper justification.
• CSA Z462 is essentially the same as, and harmonized with, NFPA 70E.
• On labeling, but not for arc flash, IEEE and NFPA require breaker panels to include panel schedule labeling. The corresponding IEC standards do not.

110
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-2 Emergency Stop – Turbines IEC 60204-1 DS/EN Independent System Operator NFPA 79 Certification
Design and (ISO) 13850 should be carried
Substations DS/EN 61400-25-2 CSA C22.2 No. 301 out in accordance
ISO 13850; ISO 13849-1 with the design
DNVGL-ST-0438 standards used
EN/IEC 60204-1 and employ
British Standard (BS) EN 60204-1 nationally
recognized
testing laboratory
(NRTL) approval if
called for in those
standards.
A-2 Comments
• The following standards are acceptable: ISO 13850, IEC 60204-1 (aka EN 60204-1), NFPA 79, and CSA C22.2 No.301.
• Addition of ISO 13849-1 is recommended because it is also heavily used for the design of the overall emergency stop systems.
• A new Canadian standard was published in 2016: CSA C22.2 No. 301. This standard draws heavily on several standards for core material, including
IEC 60204-1 and NFPA 79. CSA C22.2 No. 301 uses identical definitions for stop-function categories.

111
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-3 Spaces Around Turbines Low Voltage Low Voltage Low Voltage Certification
Cabinets and and IEC 60364-7-729 EN 50110-1 NEC (NFPA 70) should be carried
Compartments Substations IEC 61439 EU Directive Article 110.26 out in accordance
and Equipment 2014/35/EU Article 110.34 with the design
- Low Voltage High Voltage NFPA 70B; NFPA 70E standards used
- High Voltage IEC 61482 High Voltage OSHA 29 CFR 1910.269 and employ NRTL
(Adequate IEC 60298 EN 50110-1 OSHA 29 CFR 1910.305 approval if called
Workspace) IEC 62271-200 OSHA 29 CFR 1926.403 for in those
High Voltage standards.
IEEE C2 (National
Electrical Safety Code
[NESC])

A-3 Comments
• The terms “high voltage” and “low voltage” are subjective. Actual voltage ranges should be used instead.
• EU directive (low voltage) and EN 50110-1 (high voltage) are acceptable because of their close alignment with OSHA 29 CFR 1910.269.
• Initially, BSEE recommended that the listed IEC standards not be used, because they are less stringent than the EU directives and EN standards.
However, the following comments offer an alternative view.
• For cabinets with exposed live voltages, the EU/EN standards will usually require space around electrical cabinets to be increased to comply with
OSHA and IEEE-NESC.
• Going forward, it should be recognized that the NFPA, OSHA, and IEEE guidance primarily refers to work on or near exposed live parts. Exposed live
parts are generally prohibited in much of the IEC guidance.
• Requirements from IEC 60364, IEC 60204-1, IEC 60204-11, and IEC 61936-1 include measures to protect from electric shock, such as isolation of
hazardous energy and the use of protective barriers.
• Because the distances around electrical cabinets from IEC standards take shock hazard into consideration, BSEE should consider accepting these
distances if exposed live parts are not present when the cabinets are opened.

112
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-4 Electrical Safety Turbines IEC 60364 NFPA 70E
Equipment and IEC 61439 Underwriters
(Ground Fault Substations IEC 60204-1 Laboratories (UL) 943;
Circuit UL 1053
Interrupter [GFCI] OSHA: 29 CFR
– Residual 1926.404(b)(1)(ii)
Current Device
[RCD])

A-4 Comments
• OSHA regulations and NFPA 70E are acceptable because of corrosive environments.
• IEC-60204-1, which refers to IEC-60364-4-41, has been added per industry recommendation for protection against electrical shock.
• UL 943 has been added per industry recommendation.
• Europe focuses on RCDs. European RCD breakers are not equivalent to the U.S. GFCI breakers. The trip level of an RCD is significantly higher than
the 4-6 mA point of a GFCI, so they are not interchangeable. This distinction is addressed in the following comment.
• BSEE could consider allowing RCDs and residual current circuit breakers with overcurrent protection [RCBO] devices designed to IEC standards (e.g.,
IEC 60364-6), as long as trip time vs. fault current as defined in UL 943 is fulfilled. Note that, while RCDs and RCBOs may have higher fault current
ratings, they often have faster trip times than GFCIs.
• Based on the NFPA 70/UL 943 selector guide, Class C protection is sufficient when all relevant tools are double isolated and/or grounded.
Commonly used 30 mA RCBOs designed toward IEC standards can fulfill the trip time vs. fault current requirements as defined for Class C.

113
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-5 Adjustable Speed Turbines IEC 61800-1 (DC) BS EN 61800-1 (DC) UL 1741; UL 61800 Certification
Drives IEC 61800-2 (AC) BS EN 61800-2 (AC) UL 61800-5-1 should be carried
IEC 61800-4 BS EN 61800-3 (test methods) UL 61800-5-2 out in accordance
IEC 61800-5-1 BS EN 61800-4 UL 62109 with the design
IEC 62477‐1 BS EN 61800-5-1 National Electrical standards used
BS EN 61800-5-2 Manufacturers and employ NRTL
BS EN 61800-9-1 Association (NEMA) approval if called
Danish Standard (DS)/Cenelec Industrial Control and for in those
Technical Report (CLC/TR) 61800-6 Systems (ICS) 61800-1 standards.
(DC)
NEMA ICS 61800-2 (AC)
NEMA ICS 61800-4 (AC)
CSA-C22.2 No. 274
IEEE 1566
A-5 Comments
• Acceptable standards include UL 61800-5 series, NEMA ICS 61800 series, and BS EN 61800 series.
• IEC 61800-5-1 and IEC 62477-1 could also be considered as acceptable standards, with suitable justification, even though BS standards may be
more stringent in some areas.
• Regarding certification, frequency drives used for motors, and so on, are provided by the suppliers with certificates of compliance with relevant
standards, which often includes IEC standards. This is also the case for the wind turbine main converters.
• UL 508C has been withdrawn and replaced by UL 61800-5-1.

114
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-6 Switchgear (High Turbines IEC 62271 Series BS 6867; BS EN 62271-104 IEEE 1547 Certification
Voltage) and IEC 62271-1 BS PD IEC/TR 62271-307 IEEE C37 series should be carried
Substations IEC 62271-100 German Institute for Standardization IEEE C37.100.1 out in accordance
IEC 62271-102 (DIN) IEC/TR 62271-307 IEEE C37.20.2 with the design
IEC 62271-103 DIN EN 62271-200 IEEE C37.301 standards used
IEC 62271-106 DS/EN 62271-1; DS/EN 62271-100 IEEE/IEC C37.60 and employ NRTL
IEC 62271-200 DS/EN 62271-106; DS/EN 62271-202 IEEE/IEC 62271-37-013 approval if called
IEC 62271-203 DS/EN 62271-205 IEEE/IEC 62271-37-082 for in those
IEC 62271-205 DS/EN IEC 62271-102 standards.
IEC TR 62271-307 DS/IEC/IEEE 62271-37-013
IEC TS 62271-210 EN IEC 62271-205
AS 62271.1; AS 62271.200

A-6 Comments
• Acceptable standards are IEC/IEEE and/or DS/IEC/IEEE. These are harmonized standards.
• IEC 62271-203, applicable for voltages above 52 kilovolts (kV), has been added per industry recommendation.
• For < 52-kV products, the switchgear is designed and tested according to IEC 62271-200.
• For > 52 (72.5-kV) products, the switchgear is designed and tested according to IEC 62271-203, with the internal arc classification according to IEC
62271-200 and/or IEC 62271-203.
• Regarding certification, switchgear items receive numerous type tests during their development. Switchgear are type tested toward IEC and IEEE
standards by accredited laboratories. For example, PEHLA provides type-testing services toward both IEC and IEEE standards. Some participants
recommend against a requirement for repeated testing by an NRTL. However, others recommend the following approach: if using U.S. codes and
regulations that require NRTL certification, then an NRTL should be used to certify. If using IEC standards, then tests with alternative accredited labs
for those standards may be acceptable.
• Applicable standards may change for switchgear with a circuit breaker design (European) and not interrupter design (mainly used in the United
States). For example, the following standards are applicable having a circuit breaker design: IEEE Std C37.100 (Common), 37.04/06/09/10 (CB),
37.122 (gas-insulated switchgear [GIS]).

115
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-7 Switchgear Substations IEEE C37.010 Certification
(Medium IEEE C37.04 should be carried
Voltage) IEEE C37.06 out in accordance
IEEE C37.09 with the design
IEEE C37.13 standards used
IEEE C37.20.2 and employ NRTL
IEEE C37.20.6 approval if called
IEEE C37.24 for in those
American National standards.
Standards Institute
(ANSI)/NEMA C37.54
ANSI/NEMA C37.55
NEMA SG 10
National Electrical
Contractors Association
(NECA) National
Electrical Installation
Standards (NEIS) 430
CSA-C22.2 No. 31

A-7 Comments
• IEEE harmonized standards are acceptable for addressing both medium- and high-voltage switchgear.
• Industry recommends that BSEE includes IEC standards for switchgear among acceptable standards.
• Regarding certification, switchgear items receive numerous type tests during their development. Switchgear are type tested toward IEC and IEEE
standards by accredited laboratories. For example, PEHLA provides type-testing services toward both IEC and IEEE standards. Some participants
recommend against a requirement for repeated testing by an NRTL. However, others recommend the following approach: if using U.S. codes and
regulations that require NRTL certification, then an NRTL should be used to certify. If using IEC standards, then tests with alternative accredited labs
for those standards may be acceptable.

116
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-8 Switchgear Substations IEC 60947-1&2&3 BS UL 60947-1 Certification
(Low Voltage) IEC 60947-4-1 BS 6423 UL 60947-4-1 should be carried
IEC 60947-4-2 BS EN 60947-4-1 UL 60947-4-2 out in accordance
IEC 60947-5-1 DS UL 60947-5-1 with the design
IEC 60947-5-2 DS/EN 61439-1 UL 60947-5-2 standards used
IEC 60947-7-1 DS/EN 61439-2 UL 60947-7-1 and employ NRTL
IEC 60947-7-2 UL 60947-7-2 approval if called
IEC 60947-7-3 UL 60947-7-3 for in those
IEC 60947-7-4 UL 60947-7-4 standards.
IEC 61439-1 (above items
IEC 61439-2 harmonized with IEC
IEC 61439-3 60947 series)
IEC 61439-4 IEEE C37 series
IEC 60204-1 IEEE C37.20.1
IEC 60364-5-53 CSA-C22.2No.60947-4-1
IEC TR 61912-1 Low-Voltage
Switchboards
IEEE C37 series
NECA NEIS 400
UL 891
A-8 Comments
• Acceptable standards include UL 60947 series, CSA-C22.2 No. 60947 series, and BS EN 60947 series.
• Note that CSA and BS EN are harmonized with UL 60947 series.
• IEC-60204-1 has been added per industry recommendation.
• IEC-60439 has been replaced by IEC-61439 series.
• For grounding protection, IEC-60204-1 and IEC-60364-5-54 can be used for calculating the grounding electrode.
• IEC 60364-5-53 has been added per industry recommendation.
• Regarding certification, components normally come with type-testing documentation from the supplier. Some participants recommend against a
requirement for repeated testing by an NRTL. However, others recommend the following approach: if using U.S. codes and regulations that require
NRTL certification, then an NRTL should be used to certify. If using IEC standards, then tests with alternative accredited labs for those standards
may be acceptable.

117
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-9 Transformers Turbines IEC 60076 series EN 60076-16 29 CFR part 1910 subpart S Certification
and IEC 60076-1 EN 61558-1 Electrical section 305 (j) (5); should be
Substations IEC 60076-11 EN 61558-2-16 National Electric Code (NEC) carried out in
IEC 60076-13 EN 61558-2-4 sections 450.21 through accordance with
IEC 60076-3 EN 61558-2-6 450.27 and 450 Part III; the design
IEC 60076-5 BS EN 60076-11 NESC Rule 152 Location and standards used
IEC 60076-8 BS EN 60076-16 arrangement of power and employ
IEC 60076-16 BS PD IEC TS 60076-20 transformers and regulators, NRTL approval if
IEC 61936-1 DS/EN 60076-16 and Rule 124 Guarding live called for in
Austrian Standard (OVE/ONORM) parts those standards.
EN 60076-16
UL 1561 UL 1562
IEEE/ANSI C57 Series
IEEE/IEC 60076-16
IEEE 4 IEEE 259
IEEE 1276 IEEE 1538
IEEE C2 (NESC)
Low Voltage
UL 5085-1 UL 5085-2
UL 5085-3
CAN/CSA-C802.1
CSA-C22.2 No. 66.1 & .2 &.3
A-9 Comments
• Acceptable standards include IEEE/IEC 60076 and/or BS EN 60076 harmonized standard.
• Note that when installed inside the tower or nacelle, a dry transformer or a transformer with nonflammable liquid should be used. There is also
industry support for a “less-flammable” liquid rather than a “non-flammable” liquid. Liquids having a fire point higher than 300 C meet the
requirements for “less-flammable” liquid, as defined in NEC 450.23. This is equivalent to Class K liquid according to IEC 61039. Adequate
justification would also be needed.
• IEC 61936-1, applicable for overall installation of transformers, has been added per industry recommendation.
• IEC 60076-16, because it is specific to wind turbines, has been added per industry recommendation.
• Regarding certification, type testing is often carried out on the transformer by IEC-accredited laboratories. Some participants recommend against a
requirement for repeated evaluation and testing by an NRTL. However, others recommend the following approach: if using U.S. codes and
regulations that require NRTL certification, then an NRTL should be used to certify. If using IEC standards, then tests with alternative accredited labs
for those standards may be acceptable.
• Additional U.S. codes and regulations for transformer installation and protection have been added to the table.

118
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-10 Safety of Turbines IEC 60204-1 EN/IEC 60204-1, -11 NFPA 79 Certification
Machinery and IEC 60204-11 EN/IEC ISO 12100 NFPA 70 should be
Substations IEC 62061 ISO 12100 ISO 13849-1 CSA-C22.2 No. 301 carried out in
IEC 62745 ISO 13849-2 ISO 14119 accordance with
ISO 14120 ISO 14122-1 the design
Note that voltage levels ISO 14122-2 ISO 14122-3 standards used
above 36 kV are not ISO 14122-4 and employ
covered by the above BS EN ISO 13849-1 NRTL approval if
standards. BS EN ISO 13849-2 called for in
BS EN ISO 14122-1 those standards.
BS EN ISO 14122-2
BS EN ISO 14122-3
BS EN ISO 14122-4
BS EN IEC 60204-11
DS/EN ISO 13850
EU Directive: 2006/42/EC
DNVGL-ST-0361
BS EN 50308
A-10 Comments
• Standard CSA-C22.2 No. 301 is acceptable, as it is reasonably well-aligned with NFPA 79.
• BSEE will also accept EN/IEC 60204-1, -11 and EN/IEC ISO 12100, which are harmonized to the IEC and EN standards. Intertek uses both standards
as part of their certification process.
• This is a very broad topic. Overall design for machine safety for wind turbines involves the overall control and operation strategy, as well as specific
measures to protect from rotating equipment, electrical shock, fluids under pressure, and many other hazards.
• Regarding certification, design for machine safety is evaluated and certified as part of the overall turbine type certification process. Some, but not
all, participants believe there should be no requirement for repeated testing by an NRTL.
• NFPA is also relevant and has been added to the table.

119
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-11 Lightning Turbines IEC 61400-24 BS EN/IEC 62305 NFPA 780
Protection and IEC 62305-3 BS EN 61400-24 CSA IEC 61400-24
Substations IEC 62305-4 EN 61400-24 ANSI/CAN/UL 96
DIN EN 61400-24
A-11 Comments
• An acceptable standard is the CSA IEC 61400-24 harmonized standard.
• However, industry recommends using IEC 61400-24 rather than the CSA-harmonized version to avoid any potential deviations.

Ref Category Relevance IEC IEC and EU Directives United States Certification
A-12 Electrical Turbines IEC 60529 BS EN 60529 NEMA ANSI/IEC 60529 Certification
Enclosures/ and IEC 61936-1 AS 60529 NEMA 250 should be
Control Panel Substations UL 50 carried out in
(Degrees of UL 508A accordance with
Protection) UL 50E the design
standards used
and employ
NRTL approval if
called for in
those standards.
A-12 Comments
• An acceptable standard is the NEMA ANSI/IEC 60529 harmonized standard.
• Note that UL 50E “Type” ratings and IEC 60529 “Ingress Protection (IP)” ratings are acceptable, but there are some incompatibilities with the ratings
systems, especially with respect to protection from oil or hydraulic fluid.
• There should be a focus on IP terminology.

120
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-13 Wind Turbine Turbines IEC 61400-1 DNVGL-ST-0076 CAN/CSA-C22.2 No. 272 Certification
Electrical Systems IEC 61400-3-1 (fixed) EU Directive 2006/42/EC CAN/CSA-C61400-1 should be
IEC 61400-3-2 (floating) BS EN 50308 CAN/CSA-C61400-3 carried out in
IEC System for DIN EN 61400-3 (superfluous) NFPA 70 (NEC) accordance with
Certification to EN IEC 61400-3 (superfluous) NFPA 70B the design
Standards Relating to NFPA 70E standards used
Equipment for Use in OSHA 29 CFR 1910.269 and employ
Renewable Energy UL 6141 NRTL approval if
Applications (IECRE) called for in
Operational Document those standards.
(OD)-502
IEC 61936-1
A-13 Comments
• Acceptable standards include UL 6141 and CAN/CSA-C22.2 No. 272 (which is similar to UL 6141).
• Canadian (CAN)/CSA C61400-3 is redundant relative to the outdated version of IEC 61400-3.
• Note that the above standards are harmonized and reference IEC 61400-3. Intertek uses these standards as part of their certification process.
• Some industry representatives recommend focusing on IEC 61400-3-1 and IEC 61400-3-2, and adding IEC 61400-1 as an acceptable standard.
Significant revision and expansion of the Electrical Systems section is included in the 2019 revision of the IEC 61400-1 wind turbine design standard.
• Others recommend following U.S. codes and regulations stated in this table as primary references for the design basis of offshore wind turbines in
the United States.
• In general, industry recommends against using an EN version when a corresponding IEC version exists.
• For example, DIN EN 61400-3 and EN IEC 61400-3 seem superfluous.
• BS EN 50308 applies more to A-10 than A-13. It has been added there. Also, EU Directive 2006/42/EC applies here as well as in A-10. It has been
added here.
• If using U.S. codes and regulations for the wind turbine electrical system, then an NRTL should be used to certify the electrical components of the
system. If something has already been certified, then no reevaluation is needed unless it has been changed or there are details beyond what has
been certified.
• Regarding certification, the wind turbine electrical system is type tested and certified as part of the type certification process (IECRE OD-501). Some
industry representatives recommend against a requirement for repeated evaluation and testing by an NRTL. However, others recommend the
following approach: if using U.S. codes and regulations for the wind turbine electrical system, then an NRTL should be used to certify the electrical
components of the system. If something has already been certified, then no reevaluation is needed unless it has been changed or there are details
beyond what has been certified.

121
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-14 Fire Prevention Turbines ISO 19353 ISO 7240-8 OSHA 29 CFR 1926.24 Certification
and Fire and ISO/TS 7240-9 OSHA 29 CFR 1926.150 should be
Protection Substations DNVGL-SE-0077 OSHA 29 CFR 1926.151 carried out in
DNVGL-ST-0438 NFPA 72 accordance with
BS 5839-1 BS EN 12094-9 NFPA 850 the design
BS ISO 7240-8 NEMA SB 11 standards used
EN 54 NEMA SB 23 and employ
EU Directive: 2006/42/EC UL 864 NRTL approval if
(section 1.5.6) called for in
DIN EN 12094-9 those standards.
DS/EN 12094-9 DS/EN 54-29
ONORM EN 12094-9
A-14 Comments
• Further assessment is needed to determine which IEC standards are compatible with U.S. regulations and standards.
• On an interim basis, the following standards are acceptable: OSHA regulations, NFPA 72, and NEMA standards.
• Industry recommends including ISO 19353 as an acceptable standard.
• A fire risk assessment of the wind turbine is often performed in cooperation with third-party fire risk assessment experts. This assessment can be
reviewed during the certified verification agent process.
• Regarding certification, this topic is also covered in the wind turbine type certificate. Some industry representatives recommend against a
requirement for repeated certification by an NRTL. Others recommend the following approach: if using U.S. codes and regulations that require
NRTL certification, then an NRTL should be used to certify.
• Evaluation of fire resistance and fire prevention are included in the IECRE-OD501 type certification process.
• See also comments on fire and smoke behavior under C-6.

122
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
A-15 Converter/ Turbines IEC 62477-1&2 BS PD IEC/TR 60146-1-2 UL 347A Certification
Inverter and IEC 62909-1 BS EN 61400-7 UL 508C should be
Substations IEC 61800 series DIN EN 62477-1 UL 1741 carried out in
UL 61800‐5‐1 accordance with
UL 61800‐5‐2 the design
UL 62109-1 standards used
CAN/CSA-C22.2 No. 14 and employ
CAN/CSA-C22.2 No 107.1 NRTL approval if
called for in
those standards.
A-15 Comments
• The following standards are acceptable: UL 508C, CAN/CSA C22.2 No 107.1, UL 1741, UL 61800‐5‐1, UL 61800‐5‐2, UL 62109-1, and CAN/CSA-C22.2 No. 14.
• Industry recommends that converters comply to IEC 62477-1 and IEC 62477-2, respectively.
• Industry recommends including the IEC 61800 (series) of standards as acceptable. These are the leading standards for converter/inverter design
and testing and have been included in the above list.
• For medium-voltage converters, UL 347A has been added to the table.

Ref Category Relevance IEC IEC and EU Directives United States Certification
A-16 Fixed Ladder Turbines ISO 14122-1 OSHA 29 CFR 1910.23
Inside Wind ISO 14122-4 OSHA 29 CFR 1910.269(h)
Turbine BS EN ISO 14122-4 ANSI/American Society of
EN50308 Safety Professionals (ASSP)
A1264.1
American Ladder Institute
(ALI) ANSI Accredited
Standards Committee (ASC)
A14.3
A-16 Comments
• Any of the listed standards are acceptable.
• Some industry representatives recommend compliance with the European standards, which they view as more practicable (EN50308). Others disagree.
• Note that work on wind turbines generally requires use of a hard hat as PPE. This provides risk reduction when climbing ladders in areas with
restricted clearance.
• An industry safety manager recommends that fixed ladders should comply with OSHA standards inside the United States and its waters. European
standards have not provided enough clearances for personnel and in the onshore industry OSHA will not give a variance for non-compliant ladders
from Europe. The fixed ladder standard in OSHA is well established and should be utilized in the United States.

123
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 B. Safety Procedures

Ref Category Relevance IEC IEC and EU United States Certification

Directives
B-1 Working On Turbines and IEC 60364‐ BS 6626 BS 7671 OSHA 29 CFR 1926.960
or Near Live Substations 5‐52 EU Directive OSHA 29 CFR 1910 Subparts R, S
Equipment 2009/104/EC NFPA 70E Ch.1 Art.100-130
B-1 Comments
• In BSEE’s preliminary assessment, the following standards are acceptable: EU directive (2009/104/EC), BS standards, and IEC 60364‐5‐52.
• However, one industry original equipment manufacturer (OEM) believes that further assessment is needed to determine which IEC standards and
EU directives are compatible with U.S. regulations and standards.
• A-3 comments also apply here.
• An industry safety manager recommends that OSHA and NFPA 70E should be the only allowable standards for the United States. These are
regulations that technicians and personnel are already trained in across all U.S. industries. These are well-established in the United States, and
manufacturers should not be allowed to dictate safety procedures.

Ref Category Relevance IEC IEC and EU United States Certification

Directives
B-2 Personnel Turbines and IEC 61482- OSH Framework ASTM F1506 NEMA ABP 10
Protective substations 2 Directive NFPA 2112
Equipment (European 89/391/EEC NFPA 70 NEC – Art. 110.16
(PPE) Equivalent NFPA 70B NFPA 70E
to OSHA 29 CFR 1910.137
American - OSHA refers to Subpart I requirements,
Society of which refer to ANSI and ASTM standards
Testing - NFPA also refers to applicable ANSI and
Materials ASTM standards
[ASTM]
F1506)
B-2 Comments
• In BSEE’s preliminary assessment, the following standards are acceptable: OSH Framework Directive (89/391/EEC) and/or IEC 61482-2.
• However, one industry OEM believes that further assessment is needed to determine which IEC standards and EU directives are compatible with
U.S. regulations and standards.
• Industry recommends enforcing NFPA 70E to address arc flash risk.
• Note that, relative to electrification risk, the European standards are more restrictive than the U.S. standards.

124
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Ref Category Relevance IEC IEC and EU United States Certification
Directives
B-3 Lockout- Turbines and IEC 60204- EU Dir. 2009/104/EC NFPA 70E NFPA 70B NFPA 70
Tagout Substations 1 EU Dir. 2006/42/EC OSHA 29 CFR 1910
(LO/TO) EN ISO 14118 ANSI/ASSP Z224.1
AS 4024.1603
ISO 12100 (6.2.11.1)
ISO 4413 (5.4.7.2.1)
B-3 Comments
• NFPA 70E is an acceptable standard.
• Industry recommends that IEC 60204-1 (e.g. §5.4) be included in the list of acceptable standards, because it addresses design of equipment for
LO/TO.
• Industry recommends including IS0 12100 (see §6.2.11.1) and ISO 4413 (see 5.4.7.2.1) as additional standards applicable for LO/TO (often referred
to as “isolation of hazardous energy” internationally). The industry recommendations have been added to the above list.
• An industry safety manager recommends that only U.S. LO/TO standards and practices should be followed. As project owners, they will not allow
anyone to work on their project site who does not follow NFPA 70 E and OSHA standards for control of hazardous energies and LO/TO.

Ref Category Relevance IEC IEC and EU United States Certification

Directives
B-4 Equipment Turbines and IEC 60204 EN ISO 12100 OSHA 29 CFR 1910.212 (Sub.O)
Guarding Substations ISO 14120 ISO NFPA 70 NFPA 70E NFPA 79 NFPA 70B
(Energized 13857 AMT ANSI B11.19
Component) AS 4024.1601
BS EN ISO 14120
EN 50308
ISO 14119
ISO 14122-3
B-4 Comments
• An acceptable standard is EN ISO 12100 harmonized for equipment guarding (energized component).
• EN 50308, ISO 14119, and ISO 14122-3 (guard rails) have been added per industry recommendation.

125
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Ref Category Relevance IEC IEC and EU United States Certification
Directives
B-5 Work on Cable Conseil IEEE 1727
Submarine International des IEEE 1234
Cables Grands Réseaux
Électriques
(International
Council for Large
Electric Systems)
(CIGRE) TB 773
B-5 Comments
• CIGRE B1-115_2018 (conference paper) is also recommended for safe working practices in the presence of induced voltages.
• Consult Association of Diving Contractors International and International Marine Contractors Association for standards related to diving operations
near high-energy systems including submarine power cables.

C. Reliability Design
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-1 Safety Turbines IECRE OD-502 DNVGL-SE-0074 ANSI/International Electrical Certification per OD-
(Testing/Fit and IECRE OD-501 DNVGL-SE-0441 Testing Association (NETA) 501&2 should be done by
for Purpose) Substations ISO 9001 Acceptance Testing an IECRE-accepted
–Acceptance Specifications (ATS) renewable energy
Testing ii CSA SPE-1000-13 certification body).
NFPA 79
C-1 Comments
• In BSEE’s preliminary assessment, the following standards are acceptable: DNV, CSA, or ANSI/NETA standards. However, one industry OEM believes
further assessment is needed.
• BSEE recommends that developers conduct tests on electrical equipment to determine if it is fit for service before going live. This is routinely being
done by the industry. OEMs indicate that they do routinely carry out operational tests of wind turbine generators at the factory, including
generator and converter operation and operation of yaw motors fans, the pitch system, and so on.
• Standardized precommissioning and commissioning processes are also followed to ensure safe operation of all systems before startup. Also, service
manuals cover checks during lifetime. These manuals and checklists are required and reviewed as part of type certification according to IECRE OD-
501.
• NFPA 79 has been added because it includes verification testing.

126
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-2 Wiring Cable IEC 63026 DNVGL-ST-0359 OSHA 29 CFR1910.269 The cable systems must
Methods Not specific to subsea CIGRE TB 490 IEEE C2 (NESC) be covered by an existing
High Voltage cable: CIGRE TB 610 prequalification test and
(Submarine IEC 62067 CIGRE TB 623 type test that is
Cable) IEC 60840 CIGRE TB 784 witnessed by a
IEC 60228 competent witnessing
body or performed at an
independent test
laboratory.

C-2 Comments
• IEC 63026 is the only internationally recognized standard covering both mechanical and electrical testing specifically adapted for submarine cable
systems up to 60 kV (Um = 72.5 kV).
• Standards that are not specific to subsea cables should be used in combination with CIGRE TB 490 and CIGRE TB 623, which provide guidance on
testing for submarine applications.
• Information in DNVGL-ST-0359 is useful but it provides guidance, not a standard.
• Industry recommends consulting Appendix D4 of CIGRE TB 610 and CIGRE B1-303_2016 (conference paper) for information required to calculate
the current rating under dynamic loading.

127
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-3 Wiring Cable IEC 63026 DNVGL-ST-0359 IEEE 1120 The cable systems must
Methods Not specific to subsea CIGRE TB 490 be covered by an existing
Medium cable: CIGRE TB 623 prequalification test and
Voltage IEC 60840 type test according to IEC
(Submarine) IEC 60502-2 63026. See standards for
IEC 60228 the description of the
range of approvals for
each of the tests. The
prequalification test and
type test must have been
witnessed by a
representative of a
competent witnessing
body or performed at an
independent test
laboratory.
C-3 Comments
• IEC 63026 is the only internationally recognized standard covering both mechanical and electrical testing specifically adapted for submarine cable
systems up to 60 kV (Um = 72.5 kV).
• Standards that are not specific to subsea cables should be used in combination with CIGRE TB 490 and CIGRE TB 623, which provide guidance on
testing for submarine applications.
• Information in DNVGL-ST-0359 is useful but it provides guidance, not a standard.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-4 Wiring Substations DNVGL-ST-0359 NFPA 70 (NEC)
Methods Turbines BS 7671 NFPA 70E
Low Voltage and Cable Norme Francaise (NF) C15- UL 1277
(Substation 100 29 CFR 1910.305
and Wind DIN Verband der ANSI/NEMA WC 71/Insulated
Turbine) Elektrotechnik (VDE) 0276- Cable Engineers Association
620 (ICEA) S-96-659
EU Directive: 2009/104/EC ANSI/NEMA WC 70/ICEA S-95-
EU Directive: 2006/42/EC 658
C-4 Comments
• DNVGL-ST-0359 is an acceptable standard because it directly relates to the offshore wind industry.
• The following standards are also acceptable: ANSI, NEMA, ICEA, BS, EU Directive, UL, and DIN.

128
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-5 Wiring Cable IEC 60092-353 BS 6883 IEEE 1580 Cables should be listed as
Methods ISO 29400 UL 1309 a marine shipboard cable
(Marine Military Specification MIL- by an NRTL.
Shipboard DTL-24643C
Cable) MIL-DTL-24640C
CSA C22.2 No. 245
C-5 Comments
• All of the listed standards are acceptable.
• However, so far there are no shipboard cables on any offshore wind power plants.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-6 Cable Cable IEC 60332-1-2 CIGRE TB 720 API Recommended Practice
Flammability IEC 60332-3-22 EN 61034-2 (or IEC 61034- (RP) 14f
Testing 2-2005) for smoke visibility IEEE 1202
UL 1581 UL 1685
C-6 Comments
• All of the listed standards are acceptable.
• Some industry representatives recommend using API RP 14f to identify fire protection needs and CIGRE TB 720 to select fire protection methods.
Others disagree.
• Note that the United States and Europe prioritize different hazards. Common practice in the United States suggests greater concern about smoke
than the toxicity of emissions. U.S. manufacturers make cables with halogen, whereas European designs are halogen-free.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-7 Harmonics Turbines IEC 61000-3-2 IEC 61000- EN IEC 61000-3-2 IEEE 519
and 4-7 IEC 61000-4-15 EN 50160
Substations IEC 61000-4-30
C-7 Comments
• The prevention of harmonics needs to be discussed between the offshore wind farm developer and grid owner.
• Requirements are typically set by the transmission system operator/grid owner.

129
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-8 Systems of Turbines IEC 61857-31 UL 1446 Certification should be
Insulating IEC 60721-1 IEEE 1776 carried out in
Materials IEC 60071-1&2 accordance with the
IEC 60664-1&3 design standards used
IEC 60085 and employ NRTL
approval if called for
in those standards.

C-8 Comments
• The U.S. and/or IEC standards are acceptable. For example, Intertek certifies wind turbines to both IEC and U.S. standards that address systems of
insulating materials.
• IEC 60071-1 and 60071-2 (applicable for general requirements on insulation coordination), and, for low voltage, 60664-1 and 60664-3, have been
added per industry recommendation.
• The overriding standard for evaluation of insulation systems is IEC 60085. It has been added above.
• Regarding certification, design toward electrical safety standards is covered as part of type certification. Some participants recommend against a
requirement for repeated testing and/or evaluation by a NRTL. Others recommend the following approach: If using U.S. codes and regulations that
require NRTL certification, then a NRTL should be used to certify. If using IEC standards, then tests with alternative accredited labs for those
standards may be acceptable.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-9 Uninterrupt Turbines IEC 62040‐1 BS EN 62040-5-3 UL 1778 UL 62109‐1 Certification should be
-able Power and IEC 61056-1 BS EN 62040-1 UL 6141 carried out in
Supplies Substations IEC 60896-21 CAN/CSA-C813.1 accordance with the
CAN/CSA-C381.2 design standards used
CSA-C22.2 No. 60896-21 and employ NRTL
IEEE 1106 IEEE 1184 approval if called for
IEEE 1115 in those standards.
NECA NEIS 411
C-9 Comments
• The IEC and BS EN standards are acceptable. The UL 6141 standard references both as compatible.
• Regarding certification, uninterruptable power supply (UPS) systems are provided by the supplier with type-test certification and documentation.
Some participants recommend against a requirement for repeated testing and/or evaluation by an NRTL. Others recommend the following
approach: if using U.S. codes and regulations that require NRTL certification, then an NRTL should be used to certify. If using IEC standards, then
tests with alternative accredited labs for those standards may be acceptable.

130
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-10 Slip Rings Turbines IEC 60204‐1 AS 60204‐1 UL 508
IEC 60364-1 UL 347
IEC 60664-1 UL 6141

C-10 Comments
• The IEC slip rings standard IEC 60204-1 is acceptable. The UL 6141 standard accepts either IEC 60204-1 or UL 508 compliance.
• UL 6141 explains that testing of the slip ring must consider the ratings/certifications of upstream overcurrent protection. A slip ring evaluated to UL
508 may not be compatible with upstream equipment evaluated to IEC 60204-1.
• IEC 60364-1 and IEC 60664-1 could be considered applicable. IEC 60664-1 focuses primarily on electromagnetic compatibility (EMC) requirements,
whereas IEC 60364-1 covers more general electrical requirements. These have been added to the above list per industry suggestion.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-11 Alternators, Turbines IEC 60034 Series ISO 281 UL 1004 Series Certification should be
Generators, IEC 60034-1 IEC 60034-2-1 UL 4143 UL 1004-1&4 carried out in
and IEC 60034-2-2 UL 6141 accordance with the
Motors Note: ANSI is harmonizing the ANSI/NEMA MG 1 design standards used
ANSI C50 series with IEC NEMA MG 2 and employ NRTL
60034 ANSI C50 series approval if called for
IEEE 1310 in those standards.
C-11 Comments
• The IEC Alternators, Generators, and Motors series of standards are acceptable. The UL 6141 standard accepts compliance with either the UL 1004
series or IEC 60034 series.
• UL 6141 explains that testing of the item must consider the ratings/certifications of upstream overcurrent protection. An item evaluated to UL 1004
may not be compatible with upstream equipment evaluated to IEC 60034.
• Regarding certification, generators go through extensive component certification testing. Motors are provided by the supplier with type-test
certification and documentation. Some participants recommend against a requirement for repeated testing and/or evaluation by an NRTL. Others
recommend the following approach: if using U.S. codes and regulations that require NRTL certification, then an NRTL should be used to certify. If
using IEC standards, then tests with alternative accredited labs for those standards may be acceptable.

131
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-12 Cable Cable IEC 60230 CIGRE TB 303 ICEA P-32-382
Testing IEC 60229 CIGRE TB 490 ICEA P-45-482
IEC 60287 CIGRE TB 623 ICEA T-24-380
IEC 60811-501 CIGRE TB 722 ICEA T-31-610
ICEA T-32-645
ICEA T-34-664
Association of Edison
Illuminating Companies (AEIC)
CS8 AEIC CS9

C-12 Comments
• Note that this testing does not apply to submarine cables.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-13 Wiring Turbines IEC 60364‐5‐52 BS 7671 NFPA 70 (NEC) NFPA 79
Within the IEC 60364-1 UL 6141 UL 508
Turbine IEC 60204-1 UL 2277 Outline
UL 1651 UL 1072

C-13 Comments
• Both the IEC and U.S. standards are acceptable. As required by UL 6141, the OEM needs to state which set of standards is used and remain
consistent in the design.
• Note that the requirements for wiring in Section 4.2 of UL 6141 address wiring design, installation, and marking. NFPA 70 or IEC 60364‐5‐52 align
with UL requirements.
• Industry recommends that wiring be fully documented in electrical diagrams made available to technicians. This could be beneficial to addressing
differences between the NFPA and IEC; for example, wire color coding.
• Industry recommends using the NFPA standards, and that they be acceptable (technicians will be trained to these standards).
• Note that these standards apply only for voltages under 1,000 volts alternating current (VAC) (1,500 VDC).

132
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-14 Surge Turbines IEC 61643‐11 BS DD CLC TS 50539-22 UL 1449
Protection/ and IEC 60099-4 DIN CLC/TS 50539-22 IEEE C62.23
Suppression Substations IEEE C62.21
Component

C-14 Comments
• In BSEE’s preliminary assessment, the UL and IEEE standards, or the IEC standards, are acceptable. However, one industry OEM believes further
assessment is needed to determine which IEC standards are compatible with U.S. standards.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-15 Pitch, Yaw, Turbines IEC 61400-3 EN IEC 61400-3 UL 508A Certification should be
Other DS/EN 61400-3 CAN/CSA-C22.2 No 14 carried out in
Control CAN/CSA-C61400-3 accordance with the
Panels design standards used
and employ NRTL
approval if called for
in those standards.
C-15 Comments
• In BSEE’s preliminary assessment, the following standards are acceptable: UL 508A, CAN/CSA C22.2 No 14, and CAN/CSA C61400-3. However, one
industry OEM believes further assessment is needed to determine which IEC standards are compatible with U.S. standards.
• Note that Intertek certifies wind turbines to the above standards.
• Consider splitting this category into separate topics, given its broad coverage. Control panels are designed to comply with numerous IEC and ISO
standards on both electrical safety, ingress protection, EMC, adequate working space, guarding, and so on.
• Industry recommends including relevant IEC/ISO standards among acceptable standards.
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-16 Gearboxes Turbines IEC 61400-4 DS/EN 61400-4 ANSI/American Gear
OVE/ONORM EN 61400-4 Manufacturers
DIN EN 61400-4 Association/American Wind
BS EN 61400-4 Energy Association 6006-A03
UL 508
UL 73
C-16 Comments
• Any of the above standards are acceptable for gearboxes.

133
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-17 Wind Turbines EN 81-44 (in development) CSA B44.8/American Society
Turbine 2006/42/EC (machinery) of Mechanical Engineers
Tower EN 1808 (ASME) A17.8
Elevators ASME A17.8
ANSI/ASSP A10.4

C-17 Comments
• In BSEE’s preliminary assessment, any of the above standards are acceptable for wind turbine elevators. However, one industry OEM believes
further assessment is needed to determine which EN standards are compatible with U.S. standards.
• EN 1808 has been added to the listing per industry recommendation.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-18 Hoist, Turbines IEC 60204-32 AS 1418.2 AS 2550.1 UL 1340
Winch, and BS EN 14492-1
Cranes EN 13001-1&2&3
IEC 60204-32
EN 12999
EN 14492-1&2
DIN 15400
EN 12385-4
EN13411-6
EN1993-6
C-18 Comments
• UL 1340 is an acceptable standard.
• Some industry representatives recommend including the following as acceptable standards: EN 13001-1, EN 13001-2, and EN 13001-3 for general
crane requirements; IEC 60204-32 for electrical requirements toward hoisting machines; EN 12999 for specific requirements toward hydraulic
powered cranes; EN 14492-1 and EN 14492-2 for winches and hoists; DIN 15400 for lifting hooks; EN 12385-4 and EN 13411-6 for steel wire ropes;
and EN 1993-6 for crane rail systems.
• All of these additional standards have been added to the above list.
• However, one industry OEM believes further assessment is needed to determine which EN standards are compatible with U.S. standards.

134
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-19 Lighting Turbines BS EN 12464-2 OSHA 29 CFR 1926.26 Internal lighting
and OSHA 29 CFR 1926.56 fixtures – NEMA 4
Substations Proposed additions for ANSI/IES RP-7-17 protection (IP 65 can
consideration: IEEE C2 (NESC) - minimum be accepted)
EN 50308 illumination intensities for
EN 12464-1 different areas of operation External lighting
EN1838 fixtures – NEMA 6
EN1837 UL 1598 protection (IP 67 can
be accepted)
C-19 Comments
• In BSEE’s preliminary assessment, any of the originally listed standards are acceptable for lighting. Proposed additions need to be considered.
• Some industry representatives recommend expanding the list of standards to include EN 50308, which is specific to wind turbines; EN 12464-1 for
indoor lighting and EN 1838 for emergency lighting; and EN 1837, as the more general lighting standard.
• However, one industry OEM believes further assessment is needed to determine which EN standards are compatible with U.S. standards.
• Another recommended addition is UL 1598, the safety standard for luminaires. It is added to the above list.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-20 Illumination Turbines Australian Standard/New NFPA 110
Levels for and Zealand Standard (AS/NZS) NFPA 111
Emergency Substations 2293.1 NESC
Evacuation
EN 50308
EN 1838
C-20 Comments
• The NFPA and AS/NZS standards listed above are acceptable.
• EN 50308 and EN 1838 have been added to the list per industry recommendation.

135
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
Ref Category Relevance IEC IEC and EU Directives United States Certification
C-21 Emergency Turbines IEC 62034 CSA-C282
and and IEC 61892-2 CSA-C22.2 No. 141
Standby Substations IEC 62040-1&2&3&4 NFPA 110
Power NFPA 111
Systems
C-21 Comments
• The CSA and NFPA standards are acceptable for emergency and standby power systems.
• Some industry representatives recommend including the following as acceptable standards: IEC 62040-1, IEC 62040-2, IEC 62040-3, and IEC 62040-
4, which are leading standards for UPS design and testing. These have been added to the above list. However, this recommendation is not
supported by all.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-22 Power Turbines IEC 60309 UL 498 Receptacle NEMA 4X
Sockets and and NFPA 70 (NEC) protection.
Plugs Substations

C-22 Comments
• The UL, NFPA, and NEMA standards listed above are acceptable.
• Industry recommends adding IEC 60309, which would be used for special OEM equipment operating at higher voltages (400 V, 690 V); 120-V
sockets and plugs are likely to use NEMA 5-20R.
• Occasionally, European outlets have been mistakenly installed in some turbines for simple 110-V circuits.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-23 Cable Trays Turbines IEC 61537 DS/EN 61537 UL 2277 Outline
and IEC 60364-5-52 BS EN 61537 UL 6141
Substations NEMA VE 1
NFPA 70 (NEC) Art.320
CSA C22.2 No. 230 & No.126.1
C-23 Comments
• In BSEE’s preliminary assessment, any of the standards listed above are acceptable. However, one industry OEM believes further assessment is
needed to determine which EN standards are compatible with U.S. standards.
• Note that routing of cables can be done according to IEC 60364-5-52. This may relate to the configuration of cable trays, but not necessarily to the
cable trays themselves.

136
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.
 Ref Category Relevance IEC IEC and EU Directives United States Certification
C-24 Cable Cleats Turbines IEC 61914 BS EN 61914 UL 1565
for and DS/EN 61914 UL 6141
Electrical Substations Proposed additions: DIN EN 61914 NFPA 70
Installations IEC 61238-1-1&2&3
C-24 Comments
• In BSEE’s preliminary assessment, the standards originally listed above are acceptable. However, one industry OEM believes further assessment is
needed to determine which IEC standards are compatible with U.S. standards.
• Industry recommends adding IEC 61238-1-1, IEC 61238-1-2, and IEC 61238-1-3 to the list of acceptable standards.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-25 Cathodic Turbines DNVGL-RP-B401 National Association of
Protection and DS/EN 12473 Corrosion Engineers (NACE)
Substations EN 12495 RP-01
ISO 12473
BS/EN 13173
C-25 Comments
• Any of the standards listed above are acceptable.

Ref Category Relevance IEC IEC and EU Directives United States Certification
C-26 Grounding Turbines IEC 60364-5-54 IEC/BS EN 62305-3 NFPA 70 (NEC)- Art. 250
and and IEC 60204-1 CSA C22.2 No. 0.4 & No. 41
Bonding Substations IEC 60364-5-4 UL 467
IEEE 3003.2
C-26 Comments
• In BSEE’s preliminary assessment, the following standards are acceptable: NFPA 70, CSA, UL, and IEEE. However, one industry OEM believes further
assessment is needed to determine which IEC standards are compatible with U.S. standards.
• IEC-60204-1 has been added per industry recommendation.
• Industry recommends adding IEC 60364-5-4 to the list of acceptable standards because it is part of the design basis and is well-established in the industry.

i
NOTE: Arc flash does not apply only to transformer and high-voltage equipment, as low-voltage circuits have the potential for arc flash as well. Protection
against electrical shock and arc flash are not equivalent.
ii
NOTE: ANSI/NETA ATS-2017 (Standard for Acceptance Testing Specifications for Electrical Power Equipment and Systems) is an acceptable method for
ensuring electrical equipment and systems are operational, are within applicable standards and manufacturer’s tolerances, and are installed in accordance
with design specifications prior to going live.

137
This report is available at no cost from the National Renewable Energy Laboratory at www.nrel.gov/publications.