H2-KV-22B redutores de velocidade flender Helical gear reducer H2

Flender/Flender Gear Units/Helical gear reducer H2

at risk. The Protection Review and Assessment found host of failings in Vernons implementation, operations, and maintenance of its protection facilities, includi ng improper custody, care, co ntrol, and disregard for Good Utility Practice. 6. The Protection Review and Assessmen concluded that Vernons mplementation contains several dev iations from the Design Criteria. For exa mple, number of existing protection functions and relays ha ve been disabled including: () Vernon had disconnected the trip switches that ordinarily ould cause the Citys back-up ge nerator to turn on in the event of an outage on its system; () relays did not trip as designed becau se Vernon disabled them; () breaker failure protection, while speci fied in the design, did not exis in the field; ( ) other protective schemes, such as synchronism checks or closing supervisionwhic would have prevented the 2 switching error and subsequent gear slippagewere non-exis tent despite being called for in the original design. These sorts of protective devices are esse ntial to prevent the types of disturbances that regularly occu on Vernons systems from dama ging the Facility. 6. Plaintiffs also could not find ( and Vernon failed to produce wh en asked) records showing that Vernon was maintaini ng its system in safe and re liable manner as required by the ITSA and Good Utility Practice. In particular, there were no re gular maintenance records, including records of the testing of protec tive devices. More troublingly, Vernon apparently did not have (or would not share with Plaintiffs) updated and complete industry- standard line diagrams and schematics showing the as-built lay-out of its protective facil ities. Such diagrams are essential to 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 understand how system operates and to determine whether it is properly implemented in accordance with the underlying