H V B V from gear unit size GMDXXn em GMDXXn e B4-KH-11-D Bevel-helical gear reducer B4

Flender/Flender Gear Units/Bevel-helical gear reducer B4

ure that its testing and maintenance are sufficient to confirm whether its systems and rotective equipment are operating in safe and reliable manner. 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 2 Case No. ____________ VERIFIED COMPLAINT 9. For example, records regardi ng battery testing are also grossly negligent or outright fraudulent. Backup batteries are essential to power protective relays and other critical safety devices in the event of loss of grid voltage and must be insp ected regularly. But Vernons battery test records contain pu rported measurements of cell voltages th at do not add up to the total reported battery voltage and are otherwise mplausible, suggesting that the numbers are made up or copied and that no actual cell-by-cell easurements were performed. ernons personnel appear to have copied strings of numbers from one document to another, in some instances pasting fifteen rows of measurement values taken from one document into another documen where only ten measurements should appear. This reflects at best sloppiness, at worst outright fraud, and either way complete disregard for Good Utility Practice and the oper ational reliability and maintenance of critical safety equipmen and protective devices. 9. The Citys refusal to allow Pla intiffs to inspect Vernons syst em and protective equipment is also alarming. Giv en the history of electrical dis turbances on Vernons systems, the damage to the Facilitys gearse ts, and the Citys apparent unwi llingness to bring ts protection systems into alignment with he intended design, physical ins pection of Vernons facilities is necessary and important to safe guard Plaintiffs, the Facility, and ratepayers who depend on the Facility and Vernons systems fo power. Other than desire hide its own misconduct and its failure to make needed repairs its systems, there is no just ification for Vernons barring Plaintiffs from exercising their