GNRO-2015/00029, License Amendment Request - Cyber Security Plan Implementation

License Amendment Request - Cyber Security Plan Implementation

ML15180A376
Person / Time
Site:	Grand Gulf
Issue date:	06/29/2015
From:	Kevin Mulligan Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2015/00029
Download: ML15180A376 (19)

Text

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~Entergy Entergy Operations, Inc.

P.o. Box 756 Port Gibson, MS 39150 Kevin Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2015/00029 June 29, 2015 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

License Amendment Request - Cyber Security Plan Implementation Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. NRC Internal Memorandum to Barry Westreich from Russell Felts, Review Criteria for 10 CFR 73.54, Cyber Security Implementation Schedule Milestone 8 License Amendment Requests, dated October 24, 2013

2. NRC letter to Entergy, Issuance of Amendment Re: Approval of Cyber Security Plan, dated July 27,2011 (GRNI-2011/00088) (ML111940165)

3. NRC letter to Entergy, Issuance of Amendments Re: Cyber Security Implementation Schedule Revision, dated December 12,2014 (GNRI-2014/00165) (ML14311A479)

Dear Sir or Madam:

Pursuant to 10 CFR 50.4 and 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests an amendment to the Renewed Facility Operating Licenses for Grand Gulf Nuclear Station (GGNS), Unit 1. In accordance with the guidelines provided by Reference 1, this request proposes a change to the GGNS Cyber Security Plan Milestone 8 full implementation date as set forth in the Cyber Security Plan Implementation Schedule approved by References 2 and 3.

Attachment 1 provides an evaluation of the proposed change. Attachment 2 contains proposed marked-up operating license pages for the Physical Protection license condition for G'qNS to reference the commitment change provided in this submittal.

GNRO-2015/00029 Page 2 of 3 contains the proposed revised operating license pages. Attachment 4 contains a change to the date of Implementation Milestone 8.

The proposed changes have been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c), and it has been determined that the changes involve no significant hazards consideration. The bases for these determinations are included in .

Entergy requests this license amendment be effective as of its date of issuance. Although this request is neither exigent nor emergency, your review and approval is requested prior to June 30, 2016.

The revised commitment contained in this submittal is summarized in Attachment 5. Should you have any questions concerning this letter, or require additional information, please contact James Nadeau at (601) 437-2103 I declare under penalty of perjury that the foregoing is true and correct. Executed on June 29, 2015.

Sincerely,

'-v-----'-----.. 2 KJM/ss Attachments: 1. Analysis of the Proposed Change

2. Proposed GGNS Operating License Change (mark-up)

3. Revised GGNS Operating License Page (clean)

4. Revised Cyber Security Plan Implementation Schedule

5. List of Regulatory Commitments cc: See next Page

GNRO-2015/00029 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission ATIN: Mr. A. Wang, NRRlDORL (w/2)

Mail Stop OWFN 8 B1 Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATIN: Mr. Marc Dapas (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Mr. B. J. Smith Director, Division of Radiological Health Mississippi State Department of Health Division of Radiological Health 3150 Lawson Street Jackson, MS 39213 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment 1 GNRO-2015/00029 Analysis of the Proposed Change GNRO-2015/00029 Page 1 of 7 1.0

SUMMARY

DESCRIPTION This license amendment request (LAR) includes a proposed change to the Grand Gulf Nuclear Station (GGNS) Cyber Security Plan (CSP) Implementation Schedule Milestone 8 full implementation date and a proposed revision to the existing operating license Physical Protection license condition.

2.0 DETAILED DESCRIPTION In Reference 1, the NRC provided criteria to be used for evaluation of a license amendment request to revise the Cyber Security Implementation Schedule Milestone 8 date. In Reference 2, the NRC issued license amendments that approved the GGNS CSP and associated implementation milestone schedule. The CSP Implementation Schedule approved by Reference 2 was utilized as a portion of the basis for the NRC's safety evaluation report provided in Reference 2. In Reference 3, the NRC issued license amendments that approved a revised implementation milestone schedule. Entergy Operations, Inc. (Entergy) is proposing a change to the Milestone 8 date from to June 30, 2016, to December 15, 2017, for full implementation of the CSP for all applicable safety, security, and emergency preparedness (SSEP) functions.

3.0 TECHNICAL EVALUATION

In November 2009, in accordance with 10 CFR 73.54 (nuclear cyber security rule), each Entergy licensee submitted a proposed schedule for achieving full compliance with the rule. The schedule was approved (Reference 2) and consists of eight milestones, with Interim Milestones 1 through 7 being completed by December 31, 2012, and Milestone 8 (full compliance) to be completed by December 15, 2014. During the process of accomplishing Interim Milestones 1 through 7 and commencing Milestone 8 work, it became evident to Entergy that additional time would be required, and a schedule extension request to June 30, 2016, was approved by the NRC (Reference 3). However, it has subsequently become evident that an additional extension request is necessary. The extension requested herein is for a Milestone 8 date of December 15,2017.

Below is Entergy's discussion of the eight evaluation criteria provided by Reference 1:

1. Identification of the specific requirement or requirements of the CSP that the licensee needs additional time to implement.

The CSP Sections 3 and 4 describe requirements for application and maintenance of cyber security controls listed in Nuclear Energy Institute (NEI) 08-09, Revision 6, Cyber Security Plan for Nucieer Power Reactors, Appendices D and E. Application of the controls is accomplished after completion of detailed analyses (the cyber security assessment process) that identify "gaps," or the difference between current configuration and a configuration that satisfies each cyber security control. Gap closure can require any combination of physical, logical (software-related) or programmatic/procedural changes.

GNRO-2015/00029 Page 2 of 7

2. Detailed justification that describes the reason additional time is required to implement the specific requirement or requirements identified.

a. Entergy hosted a "pilot" Milestone 8 inspection at the Indian Point site in March 2014.

During the pilot, insight was gained into NRC interpretation on how to apply the cyber security controls listed in NEI 08-09, Revision 6. Prior to the pilot there was not an endorsed document describing this interpretation. During the pilot inspection, the NRC team reviewed several examples of critical digital assets (CDAs) with Entergy and indicated the level of detail and depth expected for the technical analyses against cyber security controls referenced in NEI 08-09. Based on this review, it is evident to Entergy that the detail and depth far exceeds Entergy's prior understanding and requires a significantly greater effort to achieve than initially anticipated.

b. During 2015, each operating Entergy licensee is undergoing an inspection of compliance with Interim Milestones 1 through 7. The preparation for and support of these inspections has required a significant commitment of time from Entergy's most knowledgeable subject matter experts on nuclear cyber security, exceeding the estimate previously developed and therefore, drawing those resources away from Milestone 8 implementation activities.

c. Development of an endorsed written standard for interpreting and applying the NEI 08-09 cyber security controls has continued to be a work-in-proqress for the Commission and the industry for over the past five years. NEI 13-10, Revision 2,' a guideline intended to provide some reduction of controls implementation based on equipment safety significance, has been endorsed. However, an initial screening of Entergy CDAs using this guideline indicates the reduction in both analytical work and actual application of controls would not be significant.

d. In June 2014, NEI submitted a petition for rulemaking to the Commission. The petition was subsequently found acceptable for review. The petition proposes a change to the rule to more precisely align the scope of the rule with the underlying objective of preventing radiological sabotage, which NEI estimates could potentially result in a reduction in the scope of cyber security implementation. While Entergy does not intend to suspend any implementation work in anticipation of the petition being approved, the petition being submitted is indicative that the final process for implementing the rule has not stabilized, and Entergy needs additional time to receive any implementation benefit from such rulemaking.

e. Benchmarking data gathered on Milestone 8 implementation schedules for non-Entergy licensees indicates that a significant number of licensees have either gained approval for a new Milestone 8 date or submitted an extension request significantly beyond Entergy's current due date; therefore, Entergy's request is consistent with the industry.

3. Proposed completion date for Milestone 8 consistent with the remaining scope of work to be conducted and the resources available.

The proposed completion date for Milestone 8 is December 15, 2017.

GNRO-2015/00029 Page 3 of 7

4. Evaluation of the impact that the additional time to implement the requirements will have on the effectiveness of the overall cyber security program in the context of milestones already completed.

The impact of the requested additional implementation time on the effectiveness of the overall cyber security program is considered to be very low, because the Interim Milestones that have already been completed have resulted in a high degree of protection of safety-related; important-to-safety; and security COAs against threat vectors associated with external connectivity (both wired and wireless) between portable digital media and devices. Additionally, extensive physical and administrative measures are already in place for COAs because they are plant components, pursuant to the GGNS Security Plan and Technical Specification Requirements. In the context of cyber security Milestones already completed, the following is noted:

a. An Entergy Cyber Security Assessment Team (CSAT) has been implemented consisting of highly experienced personnel knowledgeable in reactor and balance-of-plant design, licensing, safety, security, emergency preparedness, information technology and cyber security. The CSAT is provided with the authority, via written procedure, to perform the analyses and oversight activities described in the CSP. Entergy employs a single overall fleet-wide CSAT to ensure consistency of results among the fleet.

b. Critical systems and COAs have been identified, documented and entered in a controlled database.

c. The plant process computer network and the plant security computer network have been deterministically isolated per the requirements of cyber security Interim Milestone 3.

d. Safety-related, important-to-safety and security COAs have been extensively reviewed and verified (or modified) to be deterministically isolated and not to employ wireless network technology.

e. Procedures have been implemented for portable digital media and devices periodically connected to COAs, per NEI 08-09, Revision 6, Appendix 0, Section 1.19.

f. COAs associated with physical security target sets have been analyzed per the requirements of the CSP Section 3.1.6 and either (1) verified to satisfy the Technical Cyber Security Controls described in NEI 08-09, Revision 6, Appendix 0 or (2) actions required to satisfy the Technical Cyber Security Controls described in NEI 08-09, Revision 6, Appendix 0 are captured in the Corrective Action Program (CAP).

g. Employees have been provided with training on cyber security awareness; tampering; and control of portable digital media and devices periodically connected to COAs.

GNRO-2015/00029 Page 4 of 7

h. Entergy has transitioned from the previous cyber security program described by NEI 04-04. Revisions have been made to procedures that control plant modifications, planning and maintenance, establishing ties to cyber security procedures for COA analysis and control of portable digital media and devices periodically connected to COAs.

5. Description of the methodology for prioritizing completion of work for CDAs associated with significant SSEP consequences and with reactivity effects in the balance of plant.

Because COAs are plant components, prioritization follows the normal work management process that places the highest priority on apparent conditions adverse to quality in system, structure, and component design function and related factors such as safety risk and nuclear defense-in-depth, as well as threats to continuity of electric power generation in the balance-of-plant (BOP). Further, in regard to deterministic isolation and control of portable media devices (PMO) for safety-related, important-to-safety (including BOP) and security COAs, maintenance of one-way or air-gapped configurations and implementation of control of PMO remains high priority. This prioritization enabled completion of cyber security Interim Milestones 3 and 4. High focus continues to be maintained on prompt attention to any emergent issue with these COAs that would potentially challenge the established cyber protective barriers. Additionally it should be noted that these COAs encompass those associated with physical security target sets.

6. Discussion of the cyber security program performance up to the date of the license amendment request.

There has been no identified compromise of SSEP function by cyber means. Additionally, a Quality Assurance (QA) audit was conducted in the fourth quarter of 2014 pursuant to the physical security program review required by 10 CFR 73.55(m). The QA audit included review of cyber security program implementation. There were no significant findings related to overall cyber security program performance and effectiveness.

7. Discussion of cyber security issues pending in the CAP.

There are presently no significant (with 'significant' meaning, "constituting a threat to a COA via cyber means or calling into question program effectiveness") nuclear cyber security issues pending in the CAP. Several non-significant issues identified during the Quality Assurance audit described above and identified during NRC inspections of compliance with nuclear cyber security Interim Milestones 1 through 7 have been entered into CAP.

Additionally, when the Reference 4 internal NRC memorandum was shared with Entergy, the actions described regarding cyber security Interim Milestone 4 were entered into CAP for evaluation by the CSAT.

GNRO-2015/00029 Page 5 of 7

8. Discussion of modifications completed to support the cyber security program and a discussion of pending cyber security modifications.

Modifications completed include those required to deterministically isolate the Level 3 and 4 CDAs, as required by Interim Milestone 3, by data diode or air gap. Potential modifications not yet implemented include automated security information event monitoring systems for monitoring activity on networks of CDAs, pursuant to NEI 08-09, Revision 6, Appendix 0-2 (Audit and Accountability), and Appendices E-3.4 (Monitoring Tools and Techniques), 3.5 (Security Alerts and Advisories), and 4.3 (Personnel Performing Maintenance and Testing Activities), and additional physical controls for CDAs outside the Protected Area pursuant to NEI 08-09, Revision 6, Appendix E-5.1 (Physical and Operational Environment Protection Policies and Procedures). '

This LAR includes the proposed change to the existing operating license condition for "Physical Protection" (Attachments 2 and 3) for GGNS. This LAR also contains the proposed Revised CSP Implementation Schedule (Attachment 4) and provides a revised list of regulatory commitments (Attachment 5).

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 73.54 requires licensees to maintain and implement a cyber security plan (CSP). Grand Gulf Nuclear Station Facility Operating License No. NPF-29 includes a Physical Protection license condition that requires Entergy Operations, Inc. (Entergy) to fully implement and maintain in effect all provisions of the Commission-approved CSPs, including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

4.2 Significant Safety Hazards Consideration Entergy is requesting an amendment to the GGNS Facility Operating Licenses to revise the Physical Protection license condition as it relates to the CSP. This change includes a proposed change to a CSP Implementation Schedule milestone date and a proposed revision to the GGNS Facility Operating License to include the proposed deviation. Specifically, Entergy is proposing a change to the Implementation Milestone 8 completion date.

Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "lssuance of Amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change to the CSP Implementation Schedule is administrative in nature.

This change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability of the structures, systems and components relied upon to mitigate the consequences of postulated accidents and has no impact on the probability or consequences of an accident previously evaluated.

GNRO-2015/00029 Page 6 of 7 Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change to the CSP Implementation Schedule is administrative in nature.

This proposed change does not alter accident analysis assumptions, add any initiators or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability of the structures, systems, and components relied upon to mitigate the consequences of postulated accidents and does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Plant safety margins are established through limiting conditions for operation, limiting safety system settings, and safety limits specified in the technical specifications. The proposed change to the CSP Implementation Schedule is administrative in nature. In addition, the milestone date delay for full implementation of the CSP has no substantive impact because other measures have been taken which provide adequate protection during this period of time. Because there is no change to established safety margins as a result of this change, the proposed change does not involve a significant reduction in a margin of safety.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusion In conclusion, based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment provides a change to the CSP Implementation Schedule. The proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51.22(c)(12). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact GNRO-2015/00029 Page 7 of 7 statement or environmental assessment needs to be prepared in connection with the issuance of the amendment.

6.0 REFERENCES

1. NRC Internal Memorandum to Barry Westreich from Russell Felts, Review Criteria for 10 CFR 73.54, Cyber Security Implementation Schedule Milestone 8 License Amendment Requests, dated October 24, 2013

2. NRC letter to Entergy, Issuance of Amendment Re: Approval of CSP, dated July 27, 2011 (GRNI-2011/00088) (ML111940165)

3. NRC letter to Entergy, Issuance of Amendments Re: Cyber Security Implementation Schedule Revision, dated December 8, 2014 (GRNI-2014/00165) (ML14311A479)

4. NRC internal memorandum from the Director Cyber Security Directorate, Office of Nuclear Security and Incident Response, to the Region I through IV Directors of Reactor Safety, Enhanced Guidance for Licensee Near- Term Corrective Actions to Address Cyber Security Inspection Findings and Licensee Eligibility for "Good-Faith" Attempt Discretion, Enclosure 2, Milestone 4 Resolution Actions, dated July 1,2013

Attachment 2 GNRO-2015/00029 Proposed GGNS Operating License Change (mark-up)

(h) This license condition shall expire upon satisfaction of the requirements in paragraph (f) provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw or unacceptable flaw growth that is caused by fatigue.

D. The facility required exemptions from certain requirements of Appendices A and J to 10 CFR Part 50 and from certain requirements of 10 CFR Part 100. These include: (a) exemption from General Design Criterion 17 of Appendix A until startup following the first refueling outage, for (1) the emergency override of the test mode for the Division 3 diesel engine, (2) the second level undervoltage protection for the Division 3 diesel engine, and (3) the generator ground over current trip function for the Division 1 and 2 diesel generators (Section 8.3.1 of SSER #7) and (b) exemption from the requirements of Paragraph III.D.2(b) (ii) of Appendix J for the containment airlock testing following normal door opening when containment integrity is not required (Section 6.2.6 of SSER #7). These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. In addition, by exemption dated December 20, 1986, the Commission exempted licensees from 10 CFR 100.11(a) (1), insofar as it incorporates the definition of exclusion area in 10 CFR 100.3(a),

until April 30, 1987 regarding demonstration of authority to control all activities within the exclusion area (safety evaluation accompanying Amendment No. 27 to License (NPF-29). This exemption is authorized by law, and will not present an undue risk to the public health and safety, and is consistent with the common defense and security. In addition, special circumstances have been found justifying the exemption. Therefore, these exemptions are hereby granted pursuant to 10 CFR 50.12. with the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act and the rules and regulations of the Commission.

E. The licensee shall fully implement and maintain in effect all provision of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Physical Security, Safeguards Contingency and Training and Qualification Plan," and were submitted to the NRC on May 18, 2006.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP),

including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee's CSP was approved by License Amendment No. 186 as supplemented by a change approved by License Amendment No.

192 and ~.

16f Amendment No. ++G,+73, ~ +9-l-; m ~

Attachment 3 GNRO-2015/00029 Revised GGNS Operating License Page (clean)

(h) This license condition shall expire upon satisfaction of the requirements in paragraph (f) provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw or unacceptable flaw growth that is caused by fatigue.

D. The facility required exemptions from certain requirements of Appendices A and J to 10 CFR Part 50 and from certain requirements of 10 CFR Part 100. These include: (a) exemption from General Design Criterion 17 of Appendix A until startup following the first refueling outage, for (1) the emergency override of the test mode for the Division 3 diesel engine, (2) the second level undervoltage protection for the Division 3 diesel engine, and (3) the generator ground over current trip function for the Division 1 and 2 diesel generators (Section 8.3.1 of SSER #7) and (b) exemption from the requirements of Paragraph III.D.2(b) (ii) of Appendix J for the containment airlock testing following normal door opening when containment integrity is not required (Section 6.2.6 of SSER #7). These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. In addition, by exemption dated December 20, 1986, the Commission exempted licensees from 10 CFR 100.11(a) (1), insofar as it incorporates the definition of exclusion area in 10 CFR 100.3(a),

until April 30, 1987 regarding demonstration of authority to control all activities within the exclusion area (safety evaluation accompanying Amendment No. 27 to License (NPF-29). This exemption is authorized by law, and will not present an undue risk to the public health and safety, and is consistent with the common defense and security. In addition, special circumstances have been found justifying the exemption. Therefore, these exemptions are hereby granted pursuant to 10 CFR 50.12. with the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act and the rules and regulations of the Commission.

E. The licensee shall fully implement and maintain in effect all provision of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Physical Security, Safeguards Contingency and Training and Qualification Plan," and were submitted to the NRC on May 18, 2006.

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP),

including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee's CSP was approved by License Amendment No. 186 as supplemented by a change approved by License Amendment No.

192 and 16f Amendment No. -l-+(),+78, +86 -l-9-l, -l-92-;- ~

Attachment 4 GNRO-2015/00029 Revised Cyber Security Plan Implementation Schedule GNRO-2015/00029 Page 1 of 1 Revised Cyber Security Plan Implementation Schedule Completion

1. Implementation Milestone Basis Date 8 Full implementation of Grand Dec 15,2017 By the completion date, the GGNS Gulf Nuclear Station (GGNS) Cyber Security Plan will be fully Cyber Security Plan for all implemented for all SSEP functions in safety, security, and emergency accordance with 10 CFR 73.54. This preparedness (SSEP) functions date also bounds the completion of all will be achieved. individual asset security control design remediation actions including those that require a refueling outage for implementation.

Attachment 5 GNRO-2015/00029 List of Regulatory Commitments GNRO 2015-00029 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this 'document, Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED (Check One) COMPLETION COMMITMENT DATE ONE-TIME CONTINUING (If Required)

ACTION COMPLIANCE Full implementation of Grand Gulf Nucieer X December 15, 2017 Station (GGNS) Cyber Security Plan for all safety, security, and emergency preparedness functions will be achieved.