We have a project where there is a 3000kW generator that is serving as "Optional" Standby System per Article 702 of the NEC. This generator feeds a switchgear that has a pair of breakers that serve as an ATS to switch between utility and generator (see attached partial single line diagram). The generator feeder terminates in a 4000A breaker with ground fault function. The generator does not have an output circuit breaker between the alternator and the breaker in the switchgear. The generator has a controller and voltage regulator that has overcurrent (50/51) protection, but not ground fault. The generator has EPO that is lockable and we are not paralleling so this satisfies the Disconnecting Mean Required per 445.18 exception. Since the generator breaker in the switchboard has ground fault protection, everything downstream would be protected in the event of fault to ground. My question is if this would suffice for the Ground-Fault Protection of Equipment requirement Per 240.13? Do I need to add Ground Fault Relay at the generator that will shut down generator? The only issue I see is if there was a fault to ground between the generator and switchgear. The feeder will be underground in PVC, but there will be a ground conductor. Generator output is 3Ø3W no neutral.