H3-VH-5-A flender pte ltd Helical gear reducers H3

Flender/Flender Gear Units/Helical gear reducers H3

cility to continue to operate until permanent replacement the gearset could be accomplished. 7. On April 2, 2, the Facility was powering up following the cheduled spring outage when it experienced sev ere slip of the STG gearset inc ident to voltage excursion. While healthy gearset likel would have survived, the temporary rep air of the damaged gearset did not 4 Vernons failures are not limite to electrical systems. The City also has failed to properly maintain its natural gas lines in accordance with federal regul ations. According to an August 2, 2 warning letter Vernon from the United States Department of Transportation (DOT), Vernons safety failures date ack to at least 2. The DOT wa rned Vernon that it was potentially subject to millions fines for its numerous violations. The atural gas lines are the very same that supply the Facility with its fue . Plaintiffs are unaware of an measures taken by Vernon to remediate the issues raised in the DOT letter. See https://primis.phmsa.dot.gov/comm /reports/enforce/documents/5 1/5_NOPV%2 PCO_0.pdf (last visited Feb. 2, . 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 and the Facility was forced to remain in outage until May 5, 2 1 while further temporary fix was established. . 2: Vernons Attempt to Manufacture Default to Avoid Its Obligations Under the Parties Agreements 7. Once the Facility was back online, Plaintiffs moved quickly to schedule time to replace the damaged STG gearset , which would require an outage. In June 2, Plaintiffs notified Vernon that it would take the Fa cility offline from November 1 to 8, 2, to repair the gearset the soonest this could be done fter the summer months, when ou tages are prohibited under the PPTA. Plaintiffs also proposed to schedule Capacity test for November 1, 2, directly after the Fall outage. 7. Initially, Ver