B2-CV-5-D inued Thermal capacities PG kW type B n rpm co Bevel-helical gear Reduction Boxes B2

Flender/Flender Gear Units/Bevel-helical gear Reduction Boxes B2

ment than the filters us ed pursuant to the Facilitys or iginal design. 1 2 3 4 5 6 7 8 9 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 2 2 1 Case No. ____________ VERIFIED COMPLAINT . Vernon Fails to Maintain it Sys tems and Protective Devices in Safe and Reliable Manner in Accordance with Good Utility Practice 5. Under the PPTA and ITSA, Vernon is obligated to ensure the con tinued interconnection of the Generati ng Facility with the Distributio System in safe and reliable manner. This includes monito ring and testing Vernons protect ive equipment and its configurations and settings to prev ent excessive voltage distur bances occurring on Vernons system from damaging the Facility and Bicen ts equipment. Unfortunatel , one manifestation of Vernons track record of corruption and ncompetence is its ongoing inab ility or refusal to comply with this critical obligation. Vernons Pub lic Utilities Department, whic oversees Vernons electrical systems, is not operating comp etently. As result, Vernon has failed to maintain its electrical infrastructure despite Plainti ffs repeated efforts to bring th problems to the Citys attention and to work with the City to address them. 1. 2: An Operational Switching Error on Vernons System Causes Damage to the CTG Gearbox 5. On January 2, 2, deficiencies Vernons interconnection nd distribution system and the Citys failure to use Good Utility Practice caus ed full-plant trip and severe damage to one of MGSs CTG gearboxes. 5. Vernon induced the trip by making switching erro on its dist ribution system. This inadvertently islanded (.., iso lated from the CAISO grid) the Facilitys combustion turbine generators and caused the units to go overspeed and operate out of phase with the CAISO grid. When Vernon discovered the mista ke (prompted by notice from MGS Operators), the City made another switching error while try ing to restore its system cond ition to normal. Vernon reconnected MGS