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Flender/Flender Gear Units/Bevel-helical speed reduction gearbox B4

svoltage disturbances, loss of auxiliary power, full plant trips, loss of generation, and othe events that could cause da mage to the Facilityhave long been rampant on Vernons electrical sy stems and continue to this day . 5. The January 2 event and the con tinuing electrical disturbanc es raised concerns that Vernon was not operating its ystem in safe and reliable manner consistent with Good Utility Practice and its obligation under th parties agreements. It lso raised significant concerns that Vernon had done little to address th gaps in its procedures an protective schemes that caused the January 2 event and that MGS was at risk of future event similar magnitude and damage. 6. In December 2, following the settlement entered into by the parties regarding the January 2 event, Plaintiffs ook steps to check Vernons pro tective schemes, .., the relays, breakers and other equipment and settings maintained by Vernon on its system to ensure the Facility was adequately and corre ctly protected from faults wit hin Vernons system. Plaintiffs retained an independent engineer ing firm to conduct review an assessment of the protective 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 facilities that Vernon was suppose to maintain on its systems under the ITSA (the Protection and Control System Review). opy of the Protection and Control System Review is attached as Ex. 3; copy of the Malburg Generati ng Station Generator Protectio Setting Assessment (Protection Setting Assessment) is attache as Ex. 4. The Protection and Control System Review and Protection Setting Assessment are referred to collectively as he Protection Review and Assessment. 6. While the Protection Review and ssessment found that the origi nal protection scheme design was suitable, it concluded that Vernon has failed to properly implement the design features and thus left MGS nd Vernons own facilities