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The following information was provided by the licensee via email: Pursuant to 10CFR 21.21 (a)(2), Paragon Energy Solutions, LLC is providing this interim notification of ongoing analysis for Part 21 reportability of a potential defect with a Schneider Electric Medium Voltage VR Type Circuit Breaker Part Number V5D4133Y000. On February 15, 2024, Paragon completed initial documentation of a potential defect with the subject circuit breaker in which Duke-Oconee had identified failure to close on demand or delayed operation to close with extended application of the remote closing signal. Since the primary safety function of the circuit breaker is to close and maintain continuity of power to downstream loads, failure to close could potentially contribute to a substantial safety hazard. This is the first reported instance of this failure mode, and Paragon suspects the issue to be related to aging of the circuit breaker's lubrication. Paragon requires more time to complete testing and analysis to confirm the failure mode and determine reportability. Date when evaluation is expected to be complete: 5/03/2024. Affected licensee: Oconee. Paragon is currently evaluating the extent of condition as it pertains to other plants and equipment that may utilize the same or similar circuit breakers.

• * * UPDATE ON 05/02/24 FROM R. KNOTT TO T. HERRITY VIA EMAIL AND PHONE CALL * * *

Due to inconclusive results, the completion date of the testing is revised to 05/31/2024. Notified R2DO (Miller) and Part 21/50.55 Reactors (email).

• * * UPDATE ON 5/31/2024 AT 1534 EDT FROM RICHARD KNOTT TO ERNEST WEST * * *

The following is a synopsis of the updated information received: The only known affected licensee is Oconee. Paragon is evaluating if the issue pertains to other equipment or plants. Paragon has conducted additional testing with the original equipment manufacturer, Schneider Electric, but will require more time to complete their evaluation. Evaluation is expected to be complete by 6/30/2024. Other circuit breaker types that may be affected are: 5GSB2-250-1200 (uses KVR type element) 5GSB2-350-1200 (uses KVR type element) 5GSB3-350-1200 (uses KVR type element) 5GSB3-350-2000 (uses KVR type element) Paragon recommends licensees with the breaker types listed above monitor for failure to close on demand or delayed. If any improper operation is found, report it to Paragon for evaluation. Contact Information: Richard Knott Vice President Quality Assurance Paragon Energy Solutions 817-284-0077 rknott@paragones.com Notified R2DO (Franke) and Part 21/50.55 Reactors (email).

• * * UPDATE ON 6/29/2024 AT 1137 EDT FROM RICHARD KNOTT TO ERNEST WEST * * *

The following is a synopsis of the updated information received: Paragon Energy Solutions has provided a new expected date for completion of their evaluation: 7/28/2024. The only known affected licensee remains Oconee. Notified R2DO (Suggs) and Part 21/50.55 Reactors (email).

The following information was provided by Paragon Energy Solutions, LLC via email: Pursuant to 10 CFR 21.21(d)(3)(i), Paragon Energy Solutions, LLC is providing this initial notification of a potential defect with Eaton/Cutler Hammer size 4 and 5 freedom series contactors that have been modified to include either a special coil and/or to improve the securing of shading coils. These contactors may have been supplied integral to a motor control center (MCC) cubicle or as spare parts. This condition, if left uncorrected, could potentially cause a substantial safety hazard. Paragon completed an initial evaluation of a failure of a size 4 freedom series contactor (PN: NLI-CN15NN3A-T16-MOD-M) supplied to Perry Nuclear Power Plant. The reported failure occurred 26 days following installation into its associated MCC Cubicle. Perry identified the screws holding the contact bar to the push bars had fallen out and were laying in the bottom of the molded base. This allowed the movable contact bar to sit on the stationary contacts and significantly degrade due to arcing and then fail in the energized position. This condition could prevent the contactor from performing its safety function to either energize or de-energize the attached load. The loose hardware is most likely a workmanship error since the contactor must be disassembled to complete the special coil and RTV modifications to the shading coils. In the fully re-assembled condition, inspection of this hardware for tightness is not possible. Affected plants: North Anna, Turkey Point, Harris, and Perry.

• * * UPDATE ON 08/25/23 AT 1448 EDT FROM RICHARD KNOTT TO ERNEST WEST * * *

Paragon Energy Solutions submitted their final report in accordance with 10 CFR 21.21(d)(4). Paragon reported completion of corrective actions including revising the test inspection procedure to ensure hardware tightness during contactor reassembly, identifying all projects containing the affected contactors and verifying appropriate inspections have been completed, restricted use of test inspection procedures issued prior to 8/2/2023 until a formal review is completed, and issued a technical bulletin (TB-Starter-2023-01 Rev 0) for use by affected clients. Paragon recommends affected licensees perform the steps contained in Technical Bulletin TB-Starter-2023-01 Rev 0 to verify this condition is not present as part of their next routine maintenance outage associated with the affected in use equipment, and at the earliest opportunity for stock spares. Affected plants: North Anna, Turkey Point, Harris, and Perry. Notified R2DO ( Miller), R3DO (Skokowski), and Part 21/50.55 Group via email.

The following information was provided by Paragon Energy Solutions, LLC via email: Pursuant to 10 CFR 21.21(d)(3)(i), Paragon Energy Solutions, LLC is providing initial notification of the identification of a defect potentially associated with a substantial safety hazard. The subject Automatic Transfer Switches contain Mar-Bal bus insulators. Based on Paragon testing performed, the insulators may have developed stress cracking due to over tightening of required mounting hardware during the assembly process which was not detected by inspection at Paragon. Stress cracks in the insulators could degrade the structural integrity of the automatic transfer switch to withstand seismic conditions which could potentially cause a substantial safety hazard. Only one customer, Talen Energy-Susquehanna, is affected by this issue. Serial numbers of the potentially effected units (QTY 4): 351029663-1 through 351029663-4. It is recommended the licensee inspect the insulators for the supplied automatic transfer switches for stress cracking and contact Paragon for any needed assistance to resolve any deficiencies identified. The date of discovery was 1/29/2023, and the date of the Part 21 Reportability determination was 3/2/2023. Formal notification will be submitted on or before 3/31/2023. Point of Contact: Richard Knott Vice President Quality Assurance Paragon Energy Solutions 817-284-0077 rknott@paragones.com

• * * UPDATE ON 03/31/23 AT 1607 EDT FROM PARAGON ENERGY SOLUTIONS TO BILL GOTT * * *

Paragon Energy Solutions submitted their final report in accordance with 10CFR 21.21(d)(4). Paragon recommends inspection of the 4 automatic transfer switches supplied to Talen Susquehanna for insulator cracking at the next regularly scheduled maintenance period and replacement of any insulators found to exhibit stress cracking. Notified R1DO (Schroeder) and Part 21/50.55 Group via email.

Pursuant to 10 CFR 21.21 (d)(3)(i), Paragon Energy Solutions is providing initial notification of the identification of a deviation. Condition that requires evaluation: NLI 280-ton Custom Chillers, Serial Numbers XHX-0001A / XHX-0001B / XHX-0001C. The Chillers were originally supplied by Nuclear Logistics under PO: NU-02SR726683 in 2010. The original seismic qualification was questioned by plant personnel related to the size of the bolting utilized for the diagonal cross braces on the two lower chiller frames. Paragon performed a review and additional analysis of the original qualification report. It was confirmed that the bolting which was utilized to install the pinned diagonal braces on the condenser and compressor frame sections does not have a sufficient load bearing capacity to support the application loading during a seismic event. The upset and emergency loading for the diagonal brace is 5.59 kip and 8.59 kip, respectively. Compared to the load capacity of 2.32 kip and 3.09 kip for upset and emergency, respectively, for the 3/8" bolt in single-shear configuration with threads included in the shear plane. This condition does not affect normal operation of the chiller. However, this deviation has the potential to impact the ability to maintain structural integrity during a seismic event. Date of Discovery: 6/8/2021 Formal notification will be submitted on or before 7/8/2021. Paragon contact: Tracy Bolt, Chief Nuclear Officer, Paragon Energy Solutions, 817-284-0077, tbolt@paragones.com. This equipment was supplied to V.C. Summer Nuclear Station.

• * * UPDATE FROM TRACY BOLT TO DONALD NORWOOD ON 6/28/2021 AT 1459 EDT * * *

The following information was recevied via E-mail: Pursuant to 10 CFR 21.21(b), Paragon Energy Solutions, LLC is providing written notification of the identification of a deviation. On 6/24/2021, Paragon has determined that we do not have the capability to perform the evaluation to determine if the deviation, if left uncorrected, could create a substantial safety hazard. VC Summer has been notified within five working days of this determination so that they can evaluate the deviation or failure to comply, pursuant to 10 CFR 21.21(a). Condition that requires evaluation: NLI 280-ton Custom Chillers, Serial Numbers XHX-0001A / XHX-0001B / XHX-0001C. The Chillers were originally supplied by NLI to VC Summer station under PO: NU-02SR726683 in 2010. Ref. P21-06102021-IN, Rev. 0 (ML21174A009) Name and address of the individual or individuals informing the Commission: Tracy Bolt, Chief Nuclear Officer. Paragon Energy Solutions, LLC, 7410 Pebble Drive, Ft. Worth, TX 76118. Notified R2DO (Miller), R4DO (Werner), and the Part 21/50.55 Reactors E-mail group.

The following is a summary of information received from Paragon Energy Solutions: On 3/29/2021, Dominion - North Anna Station has identified instances where size 1 and 2 starters have failed to function as expected in assemblies that were originally supplied by Nuclear Logistics LLC (NLI). The mechanical interlock exhibited binding that prevented the contactor from closing when energized. The identified failed starters are utilized in an application of operating Motor Operated Valves (MOV). This is an intermittent duty application. The issue was identified on Eaton Starter Model AN56DN*, AN56GN*, CN55DN*, CN55GN* style starters and contactors with supplied date codes T4514 (week 45 of year 2014) and T4215 (week 42 of year 2015). Paragon is in the process of identifying the date codes to provide the specific information to the identified plants. The following plants were supplied starters from September 2014 through October 2018: Beaver Valley, Columbia, Ergytech, Harris, Millstone, NEK KRSKO, North Anna, Prairie Island. The component design that exhibited the failure was revised by the original equipment manufacturer (Eaton) in October 2018. There have been no reported failures of the interlock mechanism in vintages manufactured before September 2014 or after October 2018. These recommendations are based on the specific application: The reversing starters and reversing contactors are typically wired in a configuration that will electrically lock out one of the contactors when the other one is being energized to prevent both contactors from being energized at the same time. Therefore, the mechanical interlock is not required to prevent both contactors from being closed at the same time when the electrical interlock configuration is being implemented. In this scenario, the mechanical interlocks are not required and can be removed. The motor control centers that contain the mechanical interlock should be monitored to ensure that there is no binding during operation. The evaluation being performed by Paragon is expected to be completed by May 29, 2021. Tracy Bolt Chief Nuclear Officer, CNO 817-284-0077 Paragon Energy Solutions, LLC 7410 Pebble Drive Ft. Worth, TX 76118

• * * UPDATE ON 5/3/2021 AT 1559 FROM TRACY BOLT TO BRIAN LIN * * *

The following revision was received from Paragon Energy Solutions via email and corrects the identified date code and includes the size and serial number of the starter that failed: The issue was identified on supplied Size 1, 73262-025-00028 (Date Code: T4515 - 45th week of 2015) and Size 2, 73262-028-00001 (Date Code: T4215 - 42nd week of 2015). Notified R1DO (Young), R2DO (Miller), R3DO (Orlikowski), R4DO (Deese), NMSS Events Notification, and Part 21 Group via email.

• * * UPDATE ON 5/28/2021 AT 1558 FROM TRACY BOLT TO KERBY SCALES * * *

The following update (Interim Report) was received from Paragon Energy Solutions via email: Paragon is submitting this Interim Report since this condition is currently under evaluation but will not be completed within 60 days. Paragon is in communication with EATON, the OEM for the starters/contactors to determine the extent of condition. The evaluation is expected to be completed by June 30, 2021. It was determined that Dominion - Millstone should not be included in the list of affected plants. Millstone will be removed from the list in the final revision of P21-03302021. Notified R1DO (Bower), R2DO (Miller), R3DO (Feliz-Adorno), R4DO (Gepford), NMSS Events Notification, and Part 21 Group via email.

• * * UPDATE ON 6/29/2021 AT 1658 EDT FROM TRACY BOLT TO BETHANY CECERE * * *

The following is a synopsis of an update (completion of the evaluation) received from Paragon Energy Solutions via email: Paragon has identified the date codes of the supplied starters and contactors to provide the specific information to the identified plants. This information has been provided directly to the specific plant." (Millstone was removed from the list of plants.) The component design that exhibited the failure was revised by the original equipment manufacturer (EATON) in September of 2014. The failed units were from Date Codes T4215 and T4515 which are in the 42nd and 45th weeks of 2015. In September 2018 the drawing was revised again. In discussions with the OEM the revision of the drawing was due to a change in material type and was not a result of binding issues. This condition has not been identified on assemblies manufactured after September 2018. Due to the number of starters that have been installed and in service without issue, it is highly unlikely that there is a defect within all the supplied starters in the date range of September 2014 through September 2018. To date, Paragon has been unable to obtain any conclusive information from EATON regarding the potential cause of the binding issue. One of the failed starters along with samples of binding and non-binding interlocks have been provided to EATON for them to perform their own analysis on the potential causes of the binding issue. Until more information is gathered from the OEM (EATON) Paragon recommends the following: The reversing starters and reversing contactors are typically wired in a configuration that will electrically lock out one of the contactors when the other one is being energized to prevent both contactors from being energized at the same time. Therefore, the mechanical interlock is not required to prevent both contactors from being closed at the same time when the electrical interlock configuration is being implemented. In this scenario, the mechanical interlocks are not required and can be removed at the plant's discretion. Replacement mechanical interlocks may be ordered to replace the existing interlocks from the affected date code range if the plant application will not allow for removal. The motor control center cubicles or starter assemblies with date codes within the September 2014 through September 2018 range should be monitored to ensure that there is no binding during operation. It is possible that if the starter is found to bind during operation, the bound condition could be released by cycling the power to the starter. This action may release the bound condition and will allow the starter to operate. Notified R1DO (Lilliendahl), R2DO (Miller), R3DO (Stone), R4DO (Werner), NMSS Events Notification, and Part 21 Group via email.

EN Revision Imported Date : 7/22/2020 PART 21 - FAILURE OF SIZE 1 AND 2 FREEDOM SERIES AUXILIARY CONTACTS The following is a summary of information received from Paragon Energy Solutions: DUKE Harris Nuclear Plant (HNP) has identified instances where Size 1 and 2 Eaton Freedom Series starters have failed to function as expected in assemblies that were originally supplied by NLI. The auxiliary contacts have degraded prematurely and have failed to change state when the starter was energized which has affected indication and other controlling actions within the circuit. The premature degradation of the auxiliary contacts with the old model NLI special coil, part number: 057018-COIL-1/2, has occurred on size 1 and 2 contactors that were continuously energized with significant run time after approximately 3 to 5 years of service time. HNP has provided information to manage the known degradation. The auxiliary contacts should be replaced at an increased frequency until new auxiliary contacts are installed along with the new design NLI special coil, part number: 057018-COIL-1/2-M. The nature of the defect is the pre-mature aging of the component within the auxiliary contact mechanism that is adjacent to the operating coil. The starter coil is potentially being subjected to voltages of a nature that elevates the temperature within the starter adjacent to the auxiliary contacts. It is recommended that the starters and coils be replaced in the applications where the units are being operated in a continuous duty application. It is also recommended that the control transformer be replaced with a true 4:1 ratio transformer. Paragon/NLI has developed a true 4:1 ratio transformer that will provide additional mitigation of this potential over-voltage condition. Replacing the transformer with a true 4:1 ratio reduces the control voltage that is being applied to the control circuit in a manner that will not prevent the unit from providing a sufficient voltage during a degraded voltage condition, and also will not subject the components to a voltage above the ratings when the supply voltage is operated above the nominal 480 VAC bus voltage. Paragon has no other recommendations as the accelerated aging of the components and the expected life based on the additional heat the units have been subjected to is unknown. Affected plants: Sharon Harris Oconee Turkey Point Columbia North Anna Waterford River Bend Beaver Valley Should you have any questions regarding this matter, please contact: Tracy Bolt Chief Nuclear Officer Paragon Energy Solutions 817-284-0077 tbolt@paragones.com

• * * UPDATE ON 7/21/20 AT 1241 EDT FROM TRACY BOLT TO ANDREW WAUGH * * *

The following is the summary of an email received from Paragon Energy Solutions: The root cause of the degraded component is due to the increased voltage and the overall temperature of the starter coil at the elevated voltage. This elevated voltage and temperature has degraded the mechanism of the auxiliary contact operator to a point to which it has become separated from the parent component. Paragon/NLI has developed a new version of the special coil (part number: 057018-COIL-1/2-M) that operates at a lower temperature than the original special coil that is currently in use at HNP. When the new version of the special coil is subjected to the same voltages, the temperature is lower. The affected plants have been revised to: Sharon Harris Oconee Turkey Point Columbia North Anna Notified R1DO (Carfang), R2DO (Miller), R4DO (Drake), and Part 21 Reactors Group (email).