aft and the speed is converted to high speed The d B4-VV-9-D Bevel-helical gear boxes B4

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

tal led. These controls re essential to help avoid or limit damage to MGS from any future events simila to the 2 episode that damaged MGSs CTG gearset. See Part .1 above. 6. Vernon agreed to look into the issue and also promised to see if they could find additional diagrams of Vernons systems and equipment. Vernon proposed to meet again in one 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 months time, yet never sche duled follow-up meeting. Vernon deferred other actions to correct protection defic iencies. 6. It appears that Ver non has not implemented any of the fixes dis cussed and identified in the Protection Review and Asse ssment and that it continues ot to maintain its systems and associated protective equipmen to ensure that they can operate in safe and reliable manner.4 It also appears that the City lacks sufficient procedures, protoco ls and oversight regarding the testing, maintenance, and operation of its systems and protective scheme . 6. Despite Vernons own findings from their internal review of the 2 event, the recommendations of the Protec tion Review and Assessment provide by Plaintiffs to Vernon, and follow-up meetings to address thes issues, Vernon has yet to orrect the known and acknowledged deficiencies in its protection scheme. 3. 2: Electrical Disturbance Even ts Cause Cumulative Damage to MGS 7. Meanwhile, continuing electrical disturbances on Vernons syste ms appear to have contributed to inflicting dama ge on MGS. In April 2, while he Facility was in outage for routine but major maintenance and cleaning, Plaintiffs discover ed an eight-millimeter misalignment of the STG gearset . contributi ng factor to the gear slip appears to have been the stress caused by repeated electri cal disturbances, which strain ed the gearset in much the same manner that occurred in Januar 2. Plaintiffs prepared te mporary fix that would allow the Fa