1
Grid Code Impact on Generating Stations: A
Generator Owner and Operator’s Perspective
C. Schaeffer, P.E., Sr Engineer, Duke Energy, Z. Salami, Ph.D., Associate Professor, The University
of North Carolina at Charlotte, Z. Wieger, Member, IEEE PES
Abstract— The evolution of new grid code requirements
should impact the choices of new equipment, the performance of
current equipment and the design of the generating station.
However, the current state of plant planning and licensing may
not include a consideration of the Grid Codes and sometimes, the
proposed codes are based on a simplified approach used to model
generation plants in the transmission system models. This paper
focuses on how NERC Standards (grid codes in other countries)
may affect generating plant equipment or configuration and
what tools would be useful from plant OEM and designers from
a utilities point of view. It also describes the concerns and expe-
rience the Generation Owner and Operator have regarding im-
plementing the grid codes for generating stations and how some
are being addressed, the constraints around model verification
activities, and suggested plant analyses and tools needed to help
comply with grid codes and protect equipment are discussed.
Index Terms—Power system modeling, Bulk Electric System
(BES), reliability, power grid, reactive power, voltage control,
leading/lagging power factor, Under-Frequency Load Shed pro-
tective relaying, excitation system, Automatic Voltage Regulator
(AVR), Speed Governor, Coordination, Federal Energy Regula-
tory Commission (FERC), North American Electric Reliability
Corporation (NERC), Regional Reliability Organization (RRO),
Reliability Standards, power grid, Power system modeling, pro-
tective relaying, reactive power, voltage control, North American
Generator Forum (NAGF), North American Transmission Fo-
rum (NATF), EPRI NERC Standards Technical Focus Groups
(EPRI TFG), SERC Reliability Corporation Generation Sub-
committee (SERC GS), Institute of Nuclear Power Operations
(INPO)
I. INTRODUCTION
U PCOMING and active reliability standards have an im-
pact on the generating station’s operation and resource
requirements. Generator Owners (GO) and Generator Opera-
tors (GOP) are working to comply with these standards in the
most efficient way possible. As the NERC standards are in
essence electrical system design requirements for generation
plants, new “Smart Tools” would be desirable to help facili-
tate future compliance activities.
A significant challenge to GOs and GOPs is the fact that
the requirements in these standards are constantly changing,
sometimes being adjusted by several parallel NERC initia-
tives. The present language in many standards was developed
during a period prior to 2005, when there was little organized,
active participation of generation owners. In addition, region-
al standards in these areas have been and continue to be de-
veloped in parallel with the NERC standard creating multiple
978-1-4673-2729-9/12/$31.00 ©2012 IEEE
and confusing requirements applicable to plants of a single
GO or GOP.
The standards can be loosely grouped into 3 areas, Cyber
Security (CIP), Protection System (PRC) and Grid Modeling,
Plant Ratings and voltage schedule issues (MOD/FAC/VAR)
standards. This paper will focus on the PRC and MOD stand-
ards.
II. EVOLVING INDUSTRY ORGANIZATION DUE TO
COMPETITION AND MANDATORY STANDARDS
In some regions, the fundamental structure of the electrical
energy industry has been changed due to pressures from
FERC to encourage competition in energy. Other areas are
still largely vertically integrated with some pockets of inde-
pendent power producers. NERC has attempted to address
these differences by developing a Reliability Functional Mod-
el which defines functions required to assure reliability. Func-
tions for the GO and GOP have been defined and standards
have evolved. In 2005, the US congress passed legislation
requiring mandatory grid reliability standards and responsibil-
ity was assigned to FERC. FERC engaged NERC, whose
function is to develop and enforce mandatory reliability stand-
ards under FERC oversight. Many NERC standards became
mandatory as of June 2007.
Recently, several Generation Owner/Operator groups have
been formed to facilitate discussion of the generation applica-
ble standards, including the SERC GS, NAGF, a Nuclear Peer
Group and the EPRI TFGs. Discussion is ongoing that NERC
compliance activities should be modeled on the nuclear indus-
try’s self regulated INPO approach; however, non-nuclear
generation has not used this model and resources are scarce.
Multiple groups with common interests are inefficient and it
is likely that these groups will consolidate. An approach tak-
en by the EPRI TFG is to form three technical focus groups
(CIP, PRC and MOD) to facilitate the involvement of tech-
nical experts in reviewing and providing consensus responses
to draft NERC standards and these groups sometimes collabo-
rate with NATF technical groups.
III. INDUSTRY DISAGGREGATION AND
FERC/NERC/RRO/IEEE/INDUSTRY STANDARDS
Generation plants were historically designed based on the
local load requirements; however, today the trend is to imple-
ment standard plant designs as a means of reducing cost.
Some functions which traditionally have been a transmission
responsibility in a vertically integrated organization, namely
plant/BES relay coordination, model ownership, and valida-

tion of model data, have been reassigned to Generation Func-
tions based on equipment ownership. Also, engineering for
plant design and changes are outsourced to external design
organizations, which is a function not addressed in the NERC
Functional Model.
To support reliable system operation, Transmission System
design requirements need to be in place to provide direction
for Generation Plant design activities. While some issues,
such as AVR modeling activities are already ingrained into
IEEE standards typically used by Generation Plant designers,
other issues (such as mandatory Frequency Response) have
not been included and in fact, may not be technically feasible.
The new functional approach may be viable, but to be practi-
cal will require the communication by Transmissions Opera-
tions and Planning of the technical requirements. The tech-
nical requirements include: all of the plant equipment and
assumptions being made in all system (Planning and Operat-
ing) models, such that the Generation owners have knowledge
of what plant equipment is relied upon to assure BES reliabil-
ity, and when plant changes need to be reported.
A new plant within the footprint of different Regional Reli-
ability Organizations may have different minimum standards
for needed equipment. This paper has not attempted to weigh
this and develop a standard set of equipment that would be
acceptable in all RROs. The plant designer should consider
regional requirements when developing a specific design.
Some of the proposed standard requirements will require
significant changes in the power plant industry. This would
include major changes to plant system and equipment design
standards (both U.S. and International). This process alone
will take years to accomplish. Manufacturers will then have
to design, build, and test plant systems and equipment to meet
the new requirements. It is unlikely that a new power plant
that can meet the new requirements could be designed and
constructed in less than 10 years, especially if all standards
that impact plant design are not coordinated for completion at
the same time. In the future, NERC and the RROs should
better coordinate related issues as opposed to having multiple
projects, which only creates confusion, and collaborate with
the newly formed generation trade groups to develop reasona-
ble standards. Issues should be addressed through IEEE Pow-
er Engineering Society activities to correctly balance the
equipment risk considerations and incorporate changes into
new Plant Designer processes.
An area of future focus for NERC should be to assure the
TO/TOP’s are providing the appropriate system design re-
quirements and the GOPs have the high level design pro-
grams/standards/requirements in place to assure Grid Reliabil-
ity issues are implemented. NERC standards should be less
specific in documenting how to comply, which likely will
vary depending on local systems and new technology. This
approach would serve to stimulate the appropriate interfaces
needed.
IV. TRENDS IN GENERATION
For years, small fossil fired plants have served as a genera-
tion workhorse due to the abundance/cost advantages of coal.
Many plants commissioned years ago have smaller units than
typical new units and were likely connected to lower voltage
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busses (100KV). Due to environmental pressures, the trend is
to replace the older units with new, larger units, equipped with
the latest technology, connected to higher voltage systems.
The electrical implication of this trend is higher available
Short Circuit MVA for plants already connected to the higher
voltage systems. Some of the PRC standards discussed below
are intended to address the ability of a plant to correctly trip
for short circuit conditions. Since the available short circuit
power may increase, existing plants should have their designs
evaluated periodically to assure the available fault currents do
not exceed the installed breaker ratings, which would be both
a Grid Reliability and personnel safety issue. It is suggested
that this review be done based on projected 5 year grid condi-
tions so corrective actions can be planned and implemented.
To perform this review, the GO/GOP would need to request
projected Short Circuit MVA from the transmission operator,
and have the analytic tools as discussed in other sections of
this paper.
V. NERC PRC STANDARDS
A. Protection System Coordination, Maintenance, Testing
and Misoperations Standards
NERC Technical Reference document “Power Plant and
Transmission System Protection Coordination” should be con-
sidered as part of new plant design bases to comply with PRC
standards. The generating station needs to have
• Proper Generator protection coordinated with Grid
Protective Relays per PRC-001and a clear under-
standing of when issues at the plant may need to have
the transmission system protection system reviewed.
It’s not clear that coordination of plant V/Hz limiters
and protection with grid Underfrequency Load Shed-
ding (UFLS) protection has been considered.
• Draft PRC-024 Plant Voltage and Frequency Relay
Coordination issues. A new plant design needs to
consider regional Underfrequency Load Shed Pro-
grams and coordinate their relays with the grid pro-
tection if possible. If not, the inability to coordinate
needs to be specifically addressed with the plants
Transmission Protection Engineering. Some regions
are developing regional specific underfrequency load
shedding standards that include Generator Owner re-
quirements. Due to differences in industry structure,
some regional requirements specify that the GO must
report their underfrequency (UF) and overfrequency
(OF) trip set points (SERC, whose approaches pre-
dominantly reflect a vertically integrated industry),
while others specify UF set point limits for GOs or
require that the GO make load shedding arrange-
ments with Distribution Providers (RFC, which pre-
dominantly reflects a disaggregated structure with
separate GO/GOPs from Transmission Organiza-
tions). Standardizing responsibilities and the ap-
proach in the NERC Functional Model seems to be
needed. In addition, NERC is considering a project

for standard development entitled “Undervoltage
Load Shedding (PRC-010 and PRC-022)”. This de-
velopment identifies a need to expand the scope of
the standards’ applicability to include generator own-
ers and improved coordination with generator station
under voltage protection as well as improved coordi-
nation with other protection systems. The full extent
of the impact cannot yet be determined, but seems
redundant to the PRC-024 Standard efforts related to
plant ride through performance. It is suggested that
NERC better coordinate such related issues as op-
posed to having multiple projects, which only creates
confusion.
• Any protective relaying that can impact the bulk elec-
tric system (BES) needs to be specially identified for
applicability of mandatory misoperations reporting
requirements. A new plant designer should work
with the Transmission Operator’s protective relay
engineering to develop a clearly defined subset of
plant relays and protection system components that
are considered to affect BES reliability which must
o Have relay operations investigated per PRC-
004 and
o Have proof of maintenance activities per-
formed documented per PRC-005. Further,
the current proposed revisions to this stand-
ard, draft PRC-005-2, contains prescriptive
minimum maintenance activities and maxi-
mum maintenance intervals for Protection
System components.
• Plant battery systems
o Need to have a maintenance schedule defined
and results documented (PRC-005)
o EOP-005-2 and EOP-009 requirements for
black start unit capabilities. Need to consid-
er the blackout recovery time requirements.
The batteries need to be able to supply pow-
er until the plant in a blackout can supply its
own power again.
• Circuit Breakers - Currently, the breaker trip circuits
need to be tested, however, no requirements are cur-
rently planned to assure the mechanical functions re-
quired to open a specific breaker are being main-
tained, nor are there requirements to assure plant
equipment interrupting ratings remain adequate over
time.
• Appropriate Disturbance Monitoring Equipment (Digi-
tal Fault Recorder/Phasor Measurement Units, Se-
quence of Events recorders) should be provided.
PRC-002-1 standard requires Disturbance Monitor-
ing Equipment (DME) at a specific subset of net-
worked substations where generation is attached.
PRC-018-1 is the data reporting, maintenance and
testing requirements for this equipment. PRC-002-2
is in “informal development”, and it will replace the
current PRC-002-1 and PRC-018-1. The current
proposal expands the GO locations for DME installa-
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tion. The NPCC region just approved an even more
stringent DME equipment requirement location
standard (PRC-002-NPCC-1). Current trends are to
use units with synchro-phasor capabilities. These
devices should include input of field and exciter field
voltage & current and governor controls to facilitate
use of data from grid excursions to validate dynamic
models.
• Protection System Redundancy - A NERC project is
under consideration for standard development enti-
tled “Reliability of Protection Systems” which is es-
sentially a Protection System Redundancy standard.
If this comes to pass, GOs would be required to in-
stall duplicative protection systems such that the fail-
ure of any part of a protection system will not elimi-
nate protection for a power system element. Nuclear
plants historically have considered these issues
through Single Point Vulnerability (SPV) evaluations
intended to minimize unit trips due to the large eco-
nomic consequence of trips. A similar standard SPV
approach based on unit size may be economically
justified for non-nuclear generation.
• Relay Loadability - A new NERC project being con-
sidered entitled “Phase 2 of Relay Loadability: Gen-
eration” whose scope is to establish acceptable
thresholds for power plant Protection System relay
settings in consideration of system events. In most
cases, setting specifications to be included in this
standard would require a relaxation of the conserva-
tively set protective relays that protect the generator,
the generator step up transformer, and station auxilia-
ry transformers. This mandated reconsideration of
generating plant Protection System settings would
increase concern of equipment risk and exposure due
to more liberal relay settings. These issues should
instead be addressed through IEEE Power Engineer-
ing Society activities to correctly balance the equip-
ment risk considerations and incorporate changes in-
to new Plant Designer processes.
• Coordination of Generator capability curves, Protec-
tion and Excitation System Limiter functions per
draft PRC-019.
o There needs to be a documented study and ver-
ification testing to prove coordination be-
tween capability curves, excitation limits
and protective functions and generator pro-
tective relays.
o These studies may be used as the engineering
basis for MOD-025 leading capability as
generating unit testing cannot typically
prove this level of support due to grid volt-
age limits. Any modeled capabilities for
leading reactive power should be based on
the under excitation limiter (UEL) or mini-
mum excitation limiter (MEL) and not the
generator capability curve.

o The UEL/MEL should be set as the most limit-
ing, but not too conservative as to unneces-
sarily limit leading reactive support.
o This should be part of a “Smart Tool” similar
to existing relay coordination study capabili-
ties.
• Smart Tools that can consolidate these issues and sim-
plify management and documentation required by
NERC would be helpful. A modern power system
tool that can perform needed load flow, motor start,
and Short Circuit studies along with serving as a
“NERC Related” PRC equipment maintenance and
characteristic repository would be useful.
B. Plant Performance Issues (New Voltage and Frequency
Ride Through Criteria)
When load is suddenly changing during transients, genera-
tors can go over (load trips) or under (trips by other generation
sources) speed. Several standards have been developed to set
up an underfrequency load shed system to drop load in order
to restore the balance of load to generation during severe loss-
es of generation. In parallel with this, PRC-024 is being
drafted by NERC. This standard was initially developed as
generation plant relay coordination criteria considering typical
steam turbine off-nominal frequency limitations, however
FERC has been pushing for plant performance criteria. Un-
fortunately, it’s not clear that the curve that was developed
can be supported by all generation plant equipment. For ex-
ample:
• For a low frequency ride through nuclear plants have a un-
der frequency relay for reactor protection that’s more lim-
iting than PRC-024 proposed curves.
• Bus trips and or transfers on undervoltage, motor stalling or
contactor drop out can occur during low voltage ride
through after a system fault.
From a GO/GOP perspective, it is the right goal for a plant
to have a realistic voltage and frequency ride through curve
defined and if possible, it should match the final curve docu-
mented in PRC-024.
VI. MOD/FAC/VAR STANDARDS
These standards reflect the need for the transmission group
to have accurately modeled plant equipment and generator
capabilities, validated through testing or appropriate engineer-
ing analyses. System models are used for Steady State, Dy-
namic and Real Time Contingency Analyses. To maintain
models, communication is needed by Transmissions Opera-
tions and Planning of technical requirements and all the plant
equipment and assumptions being made in all system models
such that the Generation owners have the knowledge of what
plant equipment is used to assure BES reliability and when
changes need to be reported. However, the MOD standards
have not yet progressed to that point and there is not currently
a standard method to define data requirements. Different sys-
tem model tools are used with different plant assumptions for
the various tools used to assure reliable system operation
(EMS/Real Time, Short Circuit and Load Flow), so in order to
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complete these tasks and comply with active reliability stand-
ards, the GO/GOP’s have to make assumptions based on what
they believe the reliability standard is asking for.
A. System Steady State Models and Validation, Facility Rat-
ings and Coordination Issues
In complying with grid codes, plant equipment should not
be called upon to operate outside its safe operating limitations.
If operating restrictions occur, adjustments may need to be
made to other equipment (exciter, governor, transformer taps
settings, etc) in order to comply or changes to models should
occur to allow GO/GOP’s to actually meet the requirements.
Generators are typically manufactured to be able to continu-
ously operate at rated MVA within 95 to 105% voltage. Varia-
tion of the generator terminal voltage beyond these limits is
possible, but the generator capability must be appropriately
de-rated to support this operation. It is important to recognize
that many generating units supply station service directly from
the generator terminals. It’s not clear that modeling efforts
that use a +- 10% acceptance band for grid voltage tolerances
are appropriately considering the generator voltage operating
limitations. Without correct equipment limitations, the mod-
els may inappropriately calculate system voltages, which
would then be translated into VAR-002 voltage schedules.
Where fixed tap station auxiliary transformers are used
(common traditional plant design), the station auxiliary system
equipment voltage limits may be more restrictive, limiting the
generator operating voltage limits to less than the 95-105%
range. For example, it is not unusual at nuclear plants to have
restrictions on generator voltage tighter than normal due to
nuclear plant offsite power licensing requirements, which
should be modeled as limitations. It’s not clear that plant op-
erating limitations (such as generator bus or aux bus voltage
limits) are always included in the models and thus reliability
tools may call for operation the plant cannot support.
Standard MOD-010 calls for this data to be reported and is
currently mandatory and enforceable. However, MOD-011,
which calls for regional definitions of the required data, has
not been approved by FERC. In the eastern interconnection,
all Regional Reliability Organizations are to feed data into the
ERAG MMWG such that interconnections studies may be
performed. However, the different RROs in the eastern inter-
connection have different opinions on what the standard data
requirements are. Grid models currently use some plant char-
acteristics as limitations. These sometimes include
• Summer and winter values for Pmax and Pmin,
• Qmax (typically assumes limits based on the manu-
facturer’s lagging power factor or upper capability
curve, but has not always considered plant aux
load requirements),
• Qmin (this should be based on under excitation lim-
its, which should be coordinated with all other
leading capability limitations for draft standard
PRC-019)
In spite of not having compiled standard term definitions,
NERC has made MOD-024 (MW validations) and MOD-025
(MVAR Validations) mandatory and the generation plants are
faced with having to develop validation programs when much

confusion is present on what is trying to be accomplished. A
clear set of definitions of modeled generation plant character-
istic is needed. The North American Generator Forum is cur-
rently working on a Powerflow Model Guidelines to attempt
to define consistent model terms and approaches which in-
cludes the appropriate plant equipment limitations.
The NERC MOD-025 Standard Drafting Team continues to
push for validation of MVAR capability through testing in
spite of a long time industry understanding that a plant cannot
typically reach the unit capability curves under normal grid
voltage conditions due to either: grid, generator or aux system
voltage limitations. An example of a recent validation test
effort is shown to demonstrate the concern.
Fig. 1. The actual capability of the generator due to voltage limitations af-
ter a validation effort.
As the example above demonstrates, the results from testing
for many generating units do not represent a unit’s true reac-
tive capability under stressed grid conditions and thus valida-
tion through testing does not meet reliability goal of verifying
the capability limits used in the Transmission Planner and
Operator models, which are typically based on the manufac-
turer’s capability curve. This has been recognized for many
years as demonstrated in IEEE paper “Reactive Capability
Limitation of Synchronous Machines” published in ~1993. In
2010, the SERC Generation Subcommittee compiled the re-
sults of member validations which clearly demonstrate the
impossibility of proving expected unit capability through on
line testing and this data is available if needed.
A clear basis for new plant operating voltage limits
should be included in future plants and standard industry
guidelines for how to validate capabilities through “Engi-
neering Analyses” is needed. Transformer tap coordination
studies are needed for the aux transformer tap settings to
optimize the ability of a generating unit to provide voltage
support during normal conditions and also provide adequate
Vars during stress grid conditions. New plants should in-
clude appropriate studies to identify any limitations more
restrictive than the normal 95 to 105% generator bus volt-
age limits due to in-plant equipment design limitations.
Real time data capabilities that can help evaluate the abil-
ity to provide MVAR support under stressed conditions
would be helpful as opposed to attempting to a staged test.
B. Facility Ratings (FAC) Standards
Other standards have been developed intended to assure
that main power system components (GSU transformers,
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Iso-phase Bus (IPB), CTs, flex links, etc) are appropriately
designed to support the modeled unit capabilities.
• FAC-008/009 - A unit cannot be counted on to support a
summer full capability if an IPB cooler is degraded or
some transformer coolers are out of service. Interest-
ingly, even though this has reached the level of a
NERC standard, there is still much confusion about
how these limitations need to be considered in the grid
models. The best understanding right now is that FAC-
008/009 ratings must be consistent with the GSU trans-
former ratings reported per MOD-010. New plants
should design main power equipment with adequate
ratings to support full generator capabilities, provide
design calculations that demonstrate how ratings are
supported during worst case ambient temperature con-
ditions, provide temperature indications at expected hot
spots and supply allowable short term/emergency rat-
ings if equipment cooling systems are not functioning.
• PRC-019 (Draft Standard) Coordination Studies identify
the equipment most limiting to unit capabilities such
that modeled capabilities are not incorrectly based sole-
ly on generator capability curves. The example of a
capability test shown previously shows the leading co-
ordination documented for that unit. Thus, prior to
performing MVAR capability validations, PRC-019 re-
views should be performed.
Plant designs need to be based on the actual worst case am-
bient temperature, instead of an assumed 40C. Smart tools
that can help manage capability data, PRC-019 studies, FAC-
008/009 ratings and evaluate appropriate aux system tap set-
tings based on GSU taps settings would be helpful.
C. VAR-002 Voltage Schedules
Historically, the plant voltage regulated was generator bus
voltage, handled by the AVR and direction for changes came
from the BES system operating center. With development of
issues related to VAR-002, current practices seem to be mov-
ing to requiring the GO/GOP to periodically monitor bus volt-
age on the high side of the GSU transformer and regulate that
voltage.
For voltage schedules to be meaningful for BES reliability,
there needs to be clear bases for switchyard bus voltage
schedule bands, but presently, there does not appear to be a
consistent approach to schedule development based on BES
Reliability. However NERC has made mandatory standard
VAR-002, which requires the GO/GOP to regulate voltage.
There are two methods in practice by the Transmission Opera-
tor/Planner that might be used to define voltage schedules,
1. System economic dispatch studies are sometimes used to
define a target voltage with a set tolerance band above and
below the target. Issues with the inability to maintain voltage
schedule may arise when the voltage schedules are developed
using models that do not accurately reflect the actual capabil-
ity of the generator or more importantly, were developed
based on projected system configurations that may not match
the current configuration due to unexpected trips. If this is the
case the schedules may be technically unachievable. Operat-

ing to an economically based voltage schedule is a good prac-
tice; however violations of schedules developed with this ap-
proach likely do not rise to the level of a Reliability Issue.
2. Some entities use practices based on actual equipment
limitations which are clearly reliability related, based on con-
trolling voltage conditions on the BES system which may
damage equipment, such as
• To ensure acceptable voltage at load centers (which may
be remote from the plant switchyard).
• Low limits on plant switchyard Transient or Voltage Sta-
bility Limitations
The need to operate generators with a leading pf is being
driven by initiatives to add MVAR support to the grid. Be-
cause set points for the capacitor banks are typically wider
than the AVR controls, they would not switch off as long as
the GO/GOP is managing the voltage schedule per VAR-002.
Thus, generators are more likely to need to operate leading to
maintain schedule. Plant designers should provide clear al-
lowed or safe operating envelopes for MVAR support and
provide this information in plant computer systems.
New plant items needed due to VAR-002: 1) A clear link of
voltage schedule to grid reliability, 2) The ability to more au-
tomatically regulate grid bus voltage, 3) The status of the units
AVR automatically reported to the Grid Operating system
with an alarm response to trigger reporting and documenting
the communication, 4) Plant computer screens with the safe
operating capability clearly defined, both lagging and leading
and 5) Auxiliary transformer taps need to be selected to sup-
port operating within voltage limitations. If generator fed, the
selected taps should not restrict voltage within the 95-105%
generator normal ratings. If switchyard fed, either the grid
limits need to reflect plant limitations or on-line tap changers
should be included in the plant design. This is especially im-
port at nuclear power plants, which must be designed to sup-
port safety system operation under “Degraded Grid” voltage
conditions.
D. System Dynamic Models and Validation
Dynamic models include Generator/Exciter characteris-
tics, AVR block diagrams and associated parameters and
plant response to frequency deviations including Speed
Governor and/or other plant controls that would regulate
MW power. NERC Planning standards require certain dy-
namic studies to be performed to determine when invest-
ments in the grid must be made. Poor system models would
either require unnecessary investments to be made or possi-
bly miss conditions where stability might be threatened.
A large effort over the years to validate dynamic models
has been made and this is the subject of MOD-026 (Excit-
er/AVR/Generator Model Validations) and MOD-027 (Fre-
quency response validations), but limited resources have the
technical expertise needed to make valid tuning. New
software (Power Plant Parameters Derivation or PPPD) and
a technical working group were developed through EPRI to
tune dynamic model parameters and share experiences.
This now makes it cost effective to perform revalidations
after new plant commissioning, or after significant changes
(generator rewinds, AVR retuning or replacement, etc).
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New plants should include these validations in commission-
ing test plans and change processes.
A trend has been identified where plant responses to grid
frequency events are not as modeled and that many plants
are not responding. Issues with units having plant controls
that override “Free Governor Response” assumptions and
units which may operate normally with “valves wide open”
are typical causes of a mismatch. This would be an exam-
ple of inadequate model assumptions being used, possibly
due to an industry misunderstanding of plant design re-
quirements and the Frequency Response issue. It’s not
clear that new plant designers recognize these issues, as we
still see new plant governor models being submitted that
over estimate the response of a proposed new unit.
The concept of frequency response needs to be included in
the design basis for new plants and at a minimum, accurate
models need to be provided. New units are needed which can
actually provide some response to help mitigate the impact of
the unit trips and other contingencies which are inherent to the
operation of an interconnected power system, but no econom-
ic incentives are currently available to drive this. There is
some discussion about making this mandatory. New plant
designs should consider including some level of response in
their design bases, should provide expected response to both
frequency increases and decreases, and perform verification
tests during commissioning. For units which can respond, a
feature that would allow for step response test initiation, simi-
lar to the voltage step signal possible in AVR systems, might
be desirable.
VII. NEW PLANT DESIGN DOCUMENTATION
Clear documentation of all plant electrical equipment which
is related to reliable BES operation and their design bases is
needed. It would be helpful for a plant to have a “Grid Relia-
bility” System Description document with all known issues
documented. This should also include how the FERC Stand-
ard Interconnection Requirements are accounted for, Plant PM
programs needed to meet mandatory maintenance and periodic
testing programs.
All plant electrical equipment should be included in a sys-
tem modeling tool capable of Load Flow, Motor Start and
Short Circuit/Coordination analyses to allow for evaluations
of changes to plant designs. New tools are being developed
that incorporate these needs into the plant equipment database
which is suggested, as this would minimize the need to man-
age multiple plant databases for different purposes.
All equipment supplied should have dynamic models al-
ready included in the applicable grid dynamic software prior
to commissioning to eliminate the need for special User De-
fined Models. All manufactures of generators should adopt a
standard method of reporting data needed for all modeling
software (PSSE, PSLF, ETAP, etc) as different OEM report-
ing approaches and symbols (e.g. saturated vs. unsaturated
reactances) have led to confusion.
Commissioning activities should include validation of the
models, along with MW and Reactive Capabilities.
Protective relay coordination with BES relays, Capability
Curves and AVR limiting functions should be documented.

VIII. BETTER GRID TOOLS
The GO/GOPs understand that there are issues with system
models not being correct, but believe the right approach to
resolving this issue lies in a better model configuration control
process and not by requiring repeated generator test evolu-
tions. For example, there are several different software pro-
grams being used to analyze the interconnected BES, includ-
ing load flow, transient stability, real time/EMS and short cir-
cuit studies. Each of these may use different equipment data
bases. A smart tool that can support the different analyses
using a single database that could be more efficiently managed
to incorporate on-going changes and use real time data to
identify where mismatches between the models and reality are
should allow for a more efficient model maintenance process.
IX. TRAINING
To facilitate a better GO/GOP understanding of how the
grid standards are incorporated in new plant design, a training
course needs to be established. This course would focus on
meshing plant equipment design and operating procedures
with grid standards.
X. ACKNOWLEDGMENT
The authors gratefully acknowledge the contributions of T.
L. Crawley, T. A. Higgins, and W. D. Shultz from Southern
Company and J. Clark from Duke Energy for their work on
this document.
XI. REFERENCES
Periodicals:
[1] Adibi, M.M.; Milanicz, D.P.; , "Reactive capability limitation of syn-
chronous machines," Power Systems, IEEE Transactions on , vol.9,
no.1, pp.29-40, Feb 1994
Standards:
[2] System Restoration from Blackstart Resources, NERC Standard EOP-
005-2, Aug 5, 2009.
[3] Documentation of Blackstart Generating Unit Test Results, NERC
Standard EOP-009-0, Apr 1, 2005.
[4] Facility Ratings, NERC Standard FAC-008-3, May 24, 2011.
[5] Establish and Communicate Facility Ratings, NERC Standard FAC-
009-1, Oct 7, 2006.
[6] Steady-State Data for Modeling and Simulation of the Interconnected
Transmission System, NERC Standard MOD-010-0, Apr 1, 2005.
[7] Maintenance and Distribution of Steady-State Data Requirements and
Reporting Procedures, NERC Standard MOD-011-0, Apr 1, 2005.
[8] Verification of Generator Gross and Net Real Power Capability, NERC
Standard MOD-021-1, Feb 7, 2006.
[9] Verification of Generator Gross and Net Reactive Power Capability,
NERC Standard MOD-025-1, Feb 7, 2006.
[10] Verification of Models and Data for Generator Excitation Control Sys-
tem Functions and Plant Volt/Var Control Functions, NERC Standard
MOD-026-1, Draft 2, June 15, 2011.
[11] Verification of Models and Data for Turbine/Governor and Load Con-
trol or Active Power/Frequency Control Functions, NERC Standard
MOD-027-1, Draft 1, June 15, 2011.
[12] System Protection Coordination, NERC Standard PRC-001-1, Nov 1,
2006.
[13] Define Regional Disturbance Monitoring and Reporting Requirements,
NERC Standard PRC-002-1, Aug 2, 2006.
[14] Disturbance Monitoring, NERC Standard PRC-002-NPCC-01, Nov 4,
2010.
7
[15] Analysis and Mitigation of Transmission and Generation Protection
System Misoperations, NERC Standard PRC-004-2a, Feb 17, 2011.
[16] Transmission and Generation Protection System Maintenance Testing,
NERC Standard PRC-005-1a, Feb 17, 2011.
[17] Technical Assessment of the Design and Effectiveness of Undervoltage
Load Shedding Program, NERC Standard PRC-010-0, Feb 8, 2005.
[18] Disturbance Monitoring Equipment Installation and Data Reporting,
NERC Standard PRC-018-1, Aug 2, 2006.
[19] Coordination of Generating Unit or Plant Voltage Regulating Controls
with Generating Unit or Plant Capabilities and Protection, NERC
Standard PRC-019-1, Draft 2, June 15, 2011.
[20] Under-Voltage Load Shedding Program Performance, NERC Standard
PRC-022-1, Feb 7, 2006.
[21] Generator Performance During Frequency and Voltage Excursions,
NERC Standard PRC-024-1, Draft 2, June 15, 2011.
[22] Generator Operation for Maintaining Network Voltage Schedules,
NERC Standard VAR-002-1.1b, Feb 10, 2009.
[23] Reliability of Protection Systems, NERC Draft Standard, Jan 14, 2009.
Technical References:
[24] NERC System Protection and Control Subcommittee, “Power Plant and
Transmission System Protection Coordination,” North American Electric
Reliability Corporation, Princeton, NC, July 2010.
XII. BIOGRAPHIES
Dr. Zia Salami is Associate Professor of Electri-
cal and Computer Engineering in UNC Charlotte,
graduated in 1998 with Ph.D. degree in Electrical
Engineering, Power Systems and Control. His
prior experience before joining the university
includes 13 years of domestic and international
industry experience in the nuclear power and
energy market working with AREVA Inc. He has
served in several leadership roles as an advisory
engineer, technical consultant, project manager, and coordinator. Dr. Salam is
a Senior Expert in electric power system network and his research and focus
area are mainly in electric power system generation and distribution system
dynamic modeling, design and analysis, power system equipment protection,
Grid and interconnection study.
Chris Schaeffer, P.E., Sr Engineer, Generation Maintenance Services,
Duke Energy. Chris has over 20 years experience in plant power systems and
equipment support, served as the Chair and Vice Chair of the SERC Genera-
tion Subcommittee and supported regional meetings related to Grid Reliability
as the Manager of Engineering at SERC. He participated in several NERC
standards drafting teams and in the SERC Generator Model Validation Task
Force. He served as the Electrical systems technical lead for development of
chapter 8 for the U.S. EPR nuclear power plant Design Certification applica-
tion, working to incorporate proposed Grid Codes and grid interface require-
ments into the plant design bases.
Zachary Wieger is an undergraduate student in Electrical Engineering at
the University of Tennessee Knoxville, co-oping at Duke Energy. Zach is
currently the Chairperson for the student branch of IEEE at UT-K and served
as Vice-Chairperson in 2010-2011. Zach is a member of IEEE and the Power
and Energy Society. He has experience involving High Performance Compu-
ting Electrical Systems at Oak Ridge National Laboratory, Utilities System
Operations at Clinton Utilities Board and Instrumentation and Metering at
Tennessee Valley Authority.