Flender/Flender Gear Units/Bevel-helical gearboxes B4
vance of the date the outage is to comme nce. Other than an unexpected fo rced outage, the CAISO Tariff

does not permit Bicent to commence an outage unless CAISO has een properly notified. . 2: Vernons Air Quality Aff

ects Facility Operations 5. By 2, it became apparent that the poor ambient air quality Vernon was interfering with the

Facilitys safe and fficient operations, requiring frequent air filter replacements, upkeep and water ashing beyond what was anticipa ted in

the Facilitys original design and as represented by Vernon pr ior to Bicents acquisiti on of the Facility. 5. Vernons well-documented pollutio and air quality problems sev erely affected MGS, whose air intake filters ar regularly clogged with partic ulates at far higher rate than comparable powerplants in other communities. As result, Bice nt spent more time and money cleaning and replacing filters han it anticipated and than Ver non did when it operated the Facility itself. This led to dispute be tween the partie regarding th burden of cleaning filters and the increased outage time such clean ing and water washing of the Fa cility required. On December 1, 2, the parties resolved this dispute by executing an amendme nt to the PPTA, which allowed for regular cleaning of the Facility air intake filters. Vernon agreed that this cleaning would not count against Bicents sc heduled outage hour limit. 5. In addition, Vernons poor air qu ality contributed to the fatig ue and eventual failure of the Facilitys two gas turb ine compressor sections in 2. This failure led to an extensive forced outage, at considerable cost to Plaintiffs, and also pro mpted the turbines original equipment manufacturer to release produc upgrade to users who operate turbines in corrosive environments such as Vernon. To prevent further damage, Plain tiffs use HEPA-quality air inlet filters on the compressors, which are significantly more expens ive and require more frequent replace