Transmission Interconnection Requirements for Inverter-Based Generation

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Transmission Requirements for Inverter-Based Generation June 25, 2018 Page 1

Overview: Every generator interconnecting to the transmission system must adhere to all applicable Federal and State jurisdictional requirements including but not limited to the NERC Reliability Standards governed by the North American Electric Reliability Corporation, and the Open Access Transmission Tariff (OATT) (http://www.oatioasis.com/soco/socodocs/southern-oatt_current.pdf) filed with the Federal Energy Regulatory Commission (FERC), as applicable. This document is intended to assist generation Customers and potential generation developers by increasing awareness of regulatory requirements and providing guidance in meeting these and other relevant requirements as they apply to inverter-based generation to achieve reliable and operationally-efficient interconnection configurations. Nothing in this document is intended to supersede provisions in the OATT, the NERC Standards, or other regulatory requirements. All inverter-based generation connected to Southern Companies transmission system (Point of (POI) > 40 kv) shall comply with the requirements contained in this document, which may change over time. Generator interconnection studies will determine the required interconnection facilities and transmission system upgrades, evaluate whether the generation developer s initial generating facility design and equipment can comply with these requirements, and may prescribe additional requirements for specific sites/interconnections. The Generating Facility s final design and equipment will be further reviewed and its performance evaluated during the Trial Operation period, prior to the approval for Commercial Operation. The generator owner/operator is expected to continue to comply with these requirements as a condition of interconnection with Southern Companies transmission system. The generator owner/operator must provide advance written notice of any changes to generating facility equipment or any changes to equipment settings or programming. The Transmission Provider will evaluate such changes to ensure that compliance with these requirements is maintained. Unless otherwise defined herein, all capitalized terms within this document shall be defined as per the LGIP and SGIP in Southern Companies OATT. Implementation of Generator Agreements involves six phases of activity, with each phase separated by a key Milestone Date: Agreement Executed Notice to Proceed Land Transfer Deadline In-Service Initial Synchronization Readiness for Commercial Operation Request Agreement Pre- Construction Activities Construction of Transmission Facilities Pre-Sync Activities Pre-COD Activities/Trial Operation Page 2

This document will highlight key features of the first phase during the interconnection process for an inverter-based generation facility. For more information on the other phases, see the Southern Company Transmission Generator Agreement Implementation Process document that can be found in the Business Practices, Waivers, and Exemptions/Business Practices folder on the Home page of Southern Companies OASIS website (www.oatioasis.com/soco) Page 3

Table of Contents: I. Procedures for Requesting a New Generator 1. Generator Request...5 II. Point of Considerations for a New Generator 1. s to Transmission Lines Operated Normally Radial 6 2. Multiple s on a Single Transmission Line...6 3. s to Transmission Lines Connected to Nuclear Generating Plants..8 4. s to Transmission Lines Near Synchronous Generating Plants....8 III. IV. Design and Technical Requirements for a New Generator 1. Transmission System Protection and Coordination......9 i. Main Generator Step-Up (GSU) Winding Configuration ii. Anti-islanding Requirements iii. Protective Devices 2. Power Quality...13 i. Transformer Energization Studies 3. Insulation and Insulation Coordination...14 4. Voltage, Reactive Power and Power Factor Control...15 i. Reactive Power/Power Factor Design Criteria ii. Voltage Schedule Operating Requirements iii. Voltage Deviation 5. Generator Performance......15 i. Frequency Response/Regulation ii. Voltage Ride Through iii. Frequency Ride Through iv. Active Power/Reactive Power Priority Control Settings (P/Q-Priority) v. Voltage Control Stability 6. Metering and Telecommunications...18 Agreement through Pre-COD Activities/Trial Operation Page 4

I. Procedures for Requesting a New Generator Southern Company Services (SCS), as agent for Alabama Power Company, Georgia Power Company, Gulf Power Company, and Mississippi Power Company, collectively (Company), will coordinate any request for interconnection to the transmission system (POI > 40 kv) of any of these utilities. A request for interconnection to the distribution system (POI < 40 kv) of any of these utilities should be made directly with the utility according to their distribution interconnection procedures and requirements. It is important to note that the typical Request requires approximately twelve (12) months or more to work through the study process. 1. Generator Request A complete Generator Request for transmission shall include the following: i. A completed small generator ( 20 MW) or large generator (> 20 MW) interconnection application, and associated generating facility technical data, including: Inverter-based wind, electric storage, or solar generators require an additional generating facility data form in addition to the standard application. Single-line diagram of the generating facility signed and stamped by a licensed, Professional Engineer. Site layout map, with sufficient detail to determine the property boundaries and proposed location of interconnecting substation. Dynamic modeling data, formatted for the appropriate Siemens PSS/E Version(s) as specified in the generating facility data form. Any other relevant technical data listed in the data form, such as equipment specification sheets, harmonic values, etc. The application and additional generating facility data forms for inverter-based generation can be found in the Generator folder on the Home page of Southern Companies OASIS website (www.oatioasis.com/soco). ii. Appropriate application deposit which will b e applied toward the interconnection study costs, along with a completed deposit form and W-2. iii. Demonstration of site control. Site control is documentation reasonably demonstrating ownership of, option to purchase/lease, leasehold interest in, or right to develop a site for purpose of constructing the Generating Facility. Once the Application, supporting documentation, and deposit have been received, SCS will review the interconnection application and supporting documentation, and notify the Customer of any deficiencies. After all deficiencies have been resolved, the application will be considered a complete request and the Request may proceed to the study phase. Page 5

II. Point of Considerations for a New Generator 1. s to Transmission Lines Operated Normally Radial Much of the Company s sub-transmission system (<100kV) and several 115 kv lines are operated in a normal radial configuration, with a normally-open switch at some point on the line. Requests to such lines will be studied only for the normal radial configuration of the line. Once the Generating Facility is operational, any time the Company requires the line to be switched to an alternate configuration, the Generating Facility may be required to cease operations while the line is in the alternate configuration. 2. Multiple s on a Single Transmission Line While the Company may perform interconnection studies for multiple Requests with POIs on the same transmission line, multiple interconnecting substations on a single transmission line add operational complexity and exposure impacting the reliability of the transmission system. In such cases, the Company may determine at any time during or after the interconnection study process and prior to notice to proceed that an alternate interconnection configuration is required. Such alternate configurations may include combining multiple interconnections into a single, larger ring-bus substation. This may require a developer near a planned new or existing substation on the same line to arrange for and build a generator tie line to a substation beyond their site. This may be different than the interconnection configuration initially studied. See the example in Figure 1. Page 6

IC-#2 OPCO Legend: Existing Transmission Facilities New Operating Company Facilities New Customer Facilities Network Substation #1 Prior Queued Request Facilities IC-#2 OPCO Option A: Point of Network Substation #2 New IC-#2 Interconnecting Substation New IC-#1 Interconnecting Substation Point of Standard Starting Point New Configuration Optional Configuration Explored During Study Network Substation #1 Network Substation #2 New IC-#1 and #2 Interconnecting Substation OPCO IC-#2 Point of Option B: Point of Optional Configuration Explored During Study Optional Configuration Explored During Study Network Substation #1 Option C: Point of Network Substation #2 New IC-#1 Interconnecting Substation Point of Figure 1. Example of revised interconnection due to multiple generators on a network line. Page 7

3. s to Transmission Lines Connected to Nuclear Generating Plants Southern Companies will not accept Requests for inverter-based Generating Facilities that identify a Point of ( POI ) on a transmission line that terminates at a nuclear generating plant s transmission substation ( Nuclear Plant Switchyard ) including Requests with a POI at a Nuclear Plant Switchyard. There are numerous operational, scheduling, and regulatory challenges associated with the interconnection of an inverter-based Generating Facility in such a location for both the initial interconnection and the continued operation of the new Generating Facility as well as an increased risk to nuclear generating units. The policy document can be found at: http://www.oatioasis.com/soco/socodocs/-near- Nuclear-Policy.pdf. 4. s to Transmission Lines Near Synchronous Generating Plants s in electric proximity to synchronous generating plants may produce harmonic components that can exceed the specified machine ratings of the synchronous generators (e.g. permissible continuous equivalent negative-sequence current capability). Therefore, such interconnections may require detailed harmonic penetration studies. These considerations are further discussed in Section III.2 Power Quality. Page 8

III. Design and Technical Requirements for a New Generator 1. Transmission System Protection and Coordination i. Main Generator Step-Up (GSU) Winding Configuration In general, the following criteria shall be used to determine the winding configuration of the main step-up transformer connecting the inverter-based generator to the system. Any deviation from this criterion must be agreed to by the Transmission Owner. 1. If the generator is requesting to connect to existing < 100 kv transmission via a dedicated line or feeder (no load on line or feeder), the high side (utility side) of the main step-up transformer s winding configuration shall be one of the following a. Delta configuration (preferred) b. Y-grounded configuration (with delta on the generator side) An example is shown in Figure 2. 2. If the generator is requesting to connect to a 230 kv radial facility, and the Transmission Owner has determined a tap configuration is appropriate, the high side (utility side) of the main step-up transformer shall be connected in Delta configuration. An example is shown in Figure 3. 3. If the generator is requesting to connect to a > 100 kv network facility, and the Transmission Owner has determined a tap configuration is appropriate, the high side (utility side) of the main step-up transformer s winding configuration shall be one of the following: a. Delta configuration (preferred) b. Y-grounded configuration (with delta on the generator side) An example is shown in Figure 4. 4. If the generator is requesting to connect to > 100 kv network facility, and the Transmission Owner has determined a ring or straight bus configuration is appropriate, the main step-up transformer s winding configuration shall be one of the following: a. Y-grounded on high side (utility side) and Delta on the low side. b. Y-grounded on high side (utility side) and low side with buried delta tertiary winding. An example is shown in Figure 5. Page 9

Figure 2. Example of Main GSU Criteria 1. Figure 3. Example of Main GSU Criteria 2. Page 10

Figure 4. Example of Main GSU Criteria 3. Figure 5. Example of Main GSU Criteria 4. Page 11

ii. Anti-islanding Requirements The interconnection configuration shall not allow the generator to island with other customer load. Company considerations include: 1. Potential for adding load taps on the existing line. If additional load taps are planned, antiislanding protection will be considered. 2. Load-to-generation ratio to assess risk of islanding. For inverter-based generation: a. If the minimum load to total generation (sum of existing, if any, and proposed) ratio is less than 2, anti-islanding protection will be required. i. Solar: Minimum load during day time is considered for solar generation. ii. If historical load data is not available, 15% of peak non-industrial load may be used for evaluation. b. For interconnections where anti-islanding protection is required, the individual inverter anti-islanding protection will not be sufficient. Appropriate anti-islanding protection will be installed on the transmission system in order to disconnect the generator in a potential islanding scenario. This typically involves pilot relaying on the transmission system via fiber or power line carrier. 3. Generators may not be allowed to operate when the system is placed in an abnormal configuration (such as for unplanned outages, maintenance, construction, etc.) and it is determined that the existing protection may not be sufficient to prevent a potential islanding condition in such configuration. 4. Generators connected to lines operated radially will be studied for the normal expected configuration only. Generators may not be able operate when the system is placed in an abnormal configuration. iii. Protective Devices Various protective devices are required to permit the safe and reliable operation of the interconnection. During the interconnection studies, the Company will determine the necessary protection requirements (type, equipment, and settings) for both the interconnection with the Generating Facility, and for the Company s transmission system. The Generator s interconnection protective equipment and settings (if applicable) must be reviewed and accepted by the Company prior to the In-Service Date. 1. Relays - Protective relays are required to promptly sense abnormal system conditions and initiate the isolation of the problem area. Protective relays can generally be categorized into two major groups: industrial grade and utility grade. Utility grade relays have a higher degree of reliability and accuracy, and are required in all cases. All relay settings for the inter-tie protection must be reviewed and approved by the appropriate Company Protection and Control department before implementation. Page 12

2. Instrument Transformers - Instrument transformers that are used to provide quantities representative of the high voltage power system to the relays are a critical part of the protection package. These current transformers (CT s) and voltage transformers (VT s) are available with different current and voltage ratings and accuracy class ratings. It is important that any current transformers involved in protective schemes are rated as relaying accuracy class devices. Revenue metering CT s are not suitable for protective relaying applications. 3. Circuit Breakers - The study will determine the inter-tie minimum circuit breaker rating that is sufficient. Upgrading or replacing existing circuit breakers within or outside the area of the interconnection may be required due to the increased fault current levels. Circuit breakers owned by the Company are dedicated to utility protection and operation purposes and will not be used for the synchronization of the generator. 4. Communication Channel - In most cases, the tie-line between the interconnecting station and the generator site is very short. A communication channel between the two sites may be necessary for high speed protection. The communication channel is required in cases where it is necessary to remotely send a signal to remove the generator from the transmission system due to a fault or other abnormal conditions that cannot be sensed by the protective devices at the generator location. Another possible need for a communications channel is for monitoring or control purposes. The communication channel is typically fiber optic cable, but could also be based on power line carrier, radio, or other means. In some cases, redundant communication channels are also required. The Generator is responsible for installing the appropriate communication channels between the generating facility and the Company s interconnecting substation for both protection coordination and data exchange. 2. Power Quality All inverter-based generation shall comply with the Southern Company Power Quality Policy or limits specified by the Company, which can be found in the Generator folder on the Home page of Southern Companies OASIS website (www.oatioasis.com/soco). Note that a permanent power quality monitoring device will be installed by the Company at the POI to monitor that inverter-based generation performs in adherence with the Southern Company Power Quality Policy. Furthermore, during the interconnection studies, harmonic penetration studies may be performed to determine: 1. The impact of inverter-based generation produced harmonic components on electrically close synchronous generators to ensure that the levels are within the specified machine ratings (i.e., permissible continuous equivalent negative-sequence current capability). 2. Determine if mitigation measures will be necessary to meet the machine ratings. Note that this analysis could result in stricter harmonic current injection limits than those specified in the Southern Company Power Quality Policy. In addition, harmonic planning studies may be Page 13

conducted to determine the potential impact of inverter-based generation injected harmonics on existing Southern Companies harmonic filter banks (i.e., impact of harmonics on individual filter component ratings). Three-phase analysis may also be performed when necessary. i. Transformer Energization Studies Whenever a power transformer is energized, a large transient current (referred to as transformer inrush) is generated. The magnitude of the inrush current depends upon many factors such as the transformer rating, point-on-wave at time of energization, residual flux in the core, etc. The primary effects of inrush currents on the transmission system include: power quality (RMS voltage drops and temporary over-voltages due to harmonics), and protection system mis-operation. To mitigate transformer inrush effects, power transformers are generally energized from the high-side using switching devices equipped with closing resistors or controlled point-on-wave voltage closing. Therefore, during the interconnection studies, transformer energization studies will be performed to determine the RMS voltage drop at the source bus (POI). The resultant RMS voltage will be compared against the Rapid Voltage Change (RVC) limits set forth in the Southern Company Power Quality Policy. 3. Insulation and Insulation Coordination The objective of insulation coordination is to coordinate equipment insulation levels and protective device ratings. It is the responsibility of the interconnecting facility to ensure that the Southern Company substation equipment is protected against lightning and switching-induced surges that originate in the interconnection facility through insulation design and protection that meets the latest IEEE C62 standards. Basic Lightning Impulse Insulation Level (BIL) for individual station equipment shall meet or exceed Southern Company s standard ratings listed in Table 1. Also, preferred surge arrester ratings for different system voltage levels have been provided. Nominal kv (Line-Line) Station BIL (kv) Table 1. Preferred Arrester Ratings. Transformer Winding BIL (kv) Preferred Surge Duty Cycle (kv) Arrester Ratings MCOV (kv) 46 250 250 39 31.5 69 350 350 54 42 115 550 450 96 76 161 750 230 144 115 230 900 750 192 152 500 1800 Use Nameplate BSL 396 318 Page 14

4. Voltage, Reactive Power and Power Factor Control i. Reactive Power/Power Factor Design Criteria The Reactive Power Requirements for Generating Facilities Interconnecting to the Southern Companies Transmission System document can be found in the Generator Operating Requirements folder on the Home page of Southern Companies OASIS website (www.oatioasis.com/soco). ii. Voltage Schedule Operating Requirements All Generators must comply with the Voltage Schedule Procedures posted in the Generator Operating Requirements folder on the Home page of Southern Companies OASIS website (www.oatioasis.com/soco). iii. Voltage Deviation In general, for inverter-based generation interconnecting to the transmission system at an operating voltage between 40 kv and 100 kv, a criterion of 2.5% maximum voltage deviation at the POI is used. 5. Generator Performance All inverter-based generation connected to Southern Companies transmission system (POI > 40kV) shall comply with the following requirements related to frequency response/regulation and frequency and voltage ride-through. i. Frequency Response / Regulation Frequency response and frequency regulation are necessary to maintain nominal frequency whenever system load and generation imbalances occur. Like conventional generators, inverterbased generators shall have the capability to provide primary frequency response during frequency events, if operating in a condition that would allow for them to respond. The overall response of the plant shall meet the following performance aspects: Droop: Droop is defined as the ratio of per unit change in frequency to per unit change in active power output. The active power-frequency control system shall have an adjustable proportional droop characteristic with a default value of 5%. The droop response should include the capability to respond in both the upward (under frequency) and downward (over frequency) directions. Transmission Provider may request a more responsive droop setting. Deadband: The active power-frequency control system should have a deadband that is adjustable with a default value not to exceed ± 36 mhz. The primary frequency response control functions shall be enabled at all times, and shall not be blocked or disabled, except under system conditions which require active power prioritization to support system voltage outlined in Section IV, without the express written permission of the Transmission Provider. Page 15

POI RMS Voltage (pu) ii. Voltage Ride Through All inverter-based generation shall remain connected to the system and operating at normal expected output 1 during and following transmission system faults including three phase faults with a clearing time not exceeding 9 cycles. The voltage ride-through requirements shall be met at the point of interconnection, and are listed in Table 2 2 and depicted in Figure 6. It should be noted that the curves depicted in Figure 6 apply to all voltage excursions regardless of the type of initiating event. Voltage trip settings shall be set as wide as practical while ensuring equipment protection and personnel safety to support grid reliability. This aligns with the concept that the region outside of the No Trip Zone is interpreted as the May Trip Zone and not the Must Trip Zone. Fundamental frequency component of the voltage shall be used when comparing to the RMS voltage ride-through curve. Table 2. Voltage Ride-Through Requirements. High Voltage Ride-Through Low Voltage Ride-Through Voltage (p.u.) Time (sec) Voltage (p.u.) Time (sec) 1.2 Instantaneous Trip Allowed < 0.45 0.15 1.175 0.20 < 0.65 0.30 1.15 0.50 < 0.75 2.00 1.1 1.00 < 0.90 3.00 1.3 1.25 1.2 1.15 1.1 1.05 0.95 1 0.9 0.85 0.8 0.75 0.7 0.65 0.6 0.55 0.5 0.45 0.4 0.35 0.3 0.25 0.2 0.15 0.1 0.05 0 May Trip Zone No Trip Zone May Trip Zone 0 0.5 1 1.5 2 2.5 3 3.5 4 Time (sec) Figure 6. Voltage Ride-Through Requirements. 1 For the purposes of this requirement, operating at normal expected output means the generation shall not momentarily cease to operate within the No Trip Zone. 2 NERC Alert: Industry Recommendation Loss of Resources during Transmission Disturbances due to Inverter Settings II May 1, 2018. Page 16

Frequency (Hz) iii. Frequency Ride Through All inverter-based generation shall remain connected to the system and operating at normal expected output 3 during frequency excursions as described in Table 3 4,5 and depicted in Figure 7. Frequency trip settings shall be set as wide as practical while ensuring equipment protection and personnel safety to support grid reliability. This aligns with the concept that the region outside of the No Trip Zone is interpreted as the May Trip Zone and not the Must Trip Zone. Table 3. Frequency Ride-Through Requirements. High Frequency Ride-Through Low Frequency Ride-Through Frequency (Hz) Time (sec) Frequency (Hz) Time (sec) 61.8 2 57.8 5 60.5 10 (90.935-1.45713*f) 59.5 10 (1.7373*f-100.116) < 60.5 Continuous Operation > 59.5 Continuous Operation 63 62 May Trip Zone 61 60 No Trip Zone 59 58 May Trip Zone 57 0.1 1 10 100 1000 10000 Time (sec) Figure 7. Frequency Ride-Through Requirements. 3 For the purposes of this requirement, operating at normal expected output means the generation shall not momentarily cease to operate within the No Trip Zone. 4 NERC Alert: Industry Recommendation Loss of Resources during Transmission Disturbances due to Inverter Settings June 20, 2017. 5 NERC Report 1200 MW Fault Induced Solar Photovoltaic Resource Interruption Disturbance Report June 2017. Page 17

iv. Active Power/Reactive Power Priority Control Settings (P/Q-Priority) Inverters shall have the capability to provide voltage support to the grid by prioritizing Mvar output over MW output during voltage excursion events. The inverter must operate in the Q-Priority mode (i.e., this control function must be enabled at the inverters). Q-Priority is a feature for inverters to optimize its available MVA rating to produce more reactive power during abnormal, low-voltage conditions. For instance, with the Q-Priority feature enabled, the inverter control system activates reactive current injection logic when the voltage dips below a pre-determined set-point (V dip). Once the voltage has recovered (> V dip), the inverter returns to steady-state operating mode. v. Voltage Control Stability The Generator Owner must design its facility to reliably operate for the Short-Circuit Ratio (SCR) range that is provided in the interconnection studies (i.e., System Impact and Facilities Study). The SCR is calculated by dividing the three-phase short circuit MVA capacity at the Point of by the maximum rated MW output of the facility under a variety of normal and contingency operating conditions. Relative system strength conditions will change over time. While the interconnection study will include factors such as local area generating resources and a local transmission line outage as part of the analysis, these studies cannot anticipate all possible future system conditions. 6. Metering and Telecommunications The Company will install and verify metering equipment at the Point of prior to any operation of the generating facility, and shall own, operate, test and maintain such metering equipment. Power flows to and from the generating facility shall be measured at the Point of. The Company will provide metering quantities to the generating facility via a Generator-provided communication circuit (typically fiber from the generating facility to the interconnecting substation). The Generator Owner shall be responsible for contacting and coordinating with the appropriate electric service provider (which may or may not be the Company) to arrange for retail station service. The Point of metering equipment does not include the generating facility s retail station service metering equipment unless approved as such by the Company. Page 18

IV. Agreement through Pre-COD Activities/Trial Operation Agreement Executed Notice to Proceed Land Transfer Deadline In-Service Initial Synchronization Readiness for Commercial Operation Request Agreement Pre- Construction Activities Construction of Transmission Facilities Pre-Sync Activities Pre-COD Activities/Trial Operation The Generator shall coordinate with Southern Companies to complete all requirements necessary for the initial synchronization of the Generating Facility to Southern Companies Electric System. Generator interconnection implementation guidelines will be provided to the Generator upon execution of the Generator Agreement. A complete list of specific project requirements and milestones to be completed prior to initial synchronization of the Generating Facility will be provided to the Generator at Notice to Proceed. Customers should consider the following when selecting milestone dates for new Requests: The Trial Operation period between the Customer s requested Synchronization Date to the Commercial Operation Date must allow at least three months to complete both the customer s pre-cod activities and Southern Companies pre-cod requirements. Once all testing/commissioning by the Customer is complete, the Trial Operation performance validation process typically takes 4-6 weeks and will be extended as needed if generator fails to meet interconnection requirements. Southern Companies cannot accommodate a planned COD in the month of December or the first two weeks of January due to performance scheduling challenges and time requirements for other essential year-end activities. For more information on the other phases, see the Southern Company Transmission Generator Agreement Implementation Process document that can be found in the Business Practices, Waivers, and Exemptions/Business Practices folder on the Home page of Southern Companies OASIS website (www.oatioasis.com/soco) Revision Effective Date Description 0 09/19/2016 Initial document created 1 06/25/2018 Added Section II and renumbered remaining Sections accordingly; modified Sections III.2 and III.5; general document cleanup Page 19