LIC-17-0052, License Amendment Request 17-04; Modification of License Condition 3.C to Delete Requirement for a Commission-Approved Cyber Security Plan

License Amendment Request 17-04; Modification of License Condition 3.C to Delete Requirement for a Commission-Approved Cyber Security Plan

ML17167A057
Person / Time
Site:	Fort Calhoun
Issue date:	06/16/2017
From:	Fisher M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF5854, CAC MF9559, LAR 17-04, LIC-17-0052
Download: ML17167A057 (17)

Text

10 CFR 50.90 UC-17-0052 June 16, 2017 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Fort Calhoun Station (FCS}, Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

License Amendment Request 17-04; Modification of License Condition 3.C to delete requirement for a Commission-approved Cyber Security Plan

References:

1. Letter from NRC (L. E. Wilkins) to OPPD (D. J. Bannister), "Fort Calhoun Station, Unit No.

1 - Issuance of Amendment: RE: Approval of Cyber Security Plan {TAC No. ME4380),"

dated July 27, 2011 (NRC-11-0082) (ML111801094)

2. Letter from NRC (C. F. Lyon) to OPPD (L. P. Cortopassi), "Fort Calhoun Station, Unit No. 1

-Issuance of Amendment RE: Revision to Cyber Security Plan Implementation Schedule Completion Date (CAC No. MF5854)," dated November 19, 2015 (NRC-15-096)

(ML15070A007)

3. Memorandum from NRC (R. Felts) to NRC (B. Westreich), "Review Criteria for Title 10 of the Code of Federal Regulations Part 73.54, Cyber Security Implementation Schedule Milestone 8 License Amendment Requests," dated October 24, 2013 (ML13295A467)

4. Letter from OPPD (M. J . Fisher) to NRC, "License Amendment Request 17-02; Request Extension for Milestone 8 of Cyber Security Plan Implementation Schedule," dated March 24, 2017 (LIC-17-0016) (CAC No. MF9559)

5. Letter from OPPD (T. J. Burke) to US NRC (Document Control Desk), "Certification of Permanent Removal of Fuel from the Reactor Vessel," dated November 13, 2016 (LIC-16-0074) (ML16319A254)

In accordance with the provisions of 10 CFR 50.4 and 10 CFR 50.90, the Omaha Public Power District (OPPD} is submitting a request for an amendment to Renewed Facility Operating License (RFOL}, No. DPR-40, for Fort Calhoun Station (FCS) Unit No. 1. The proposed amendment requests Nuclear Regulatory Commission (NRC) approval of the removal of the FCS Cyber Security Plan (CSP) from the FCS Operating License Condition.

444 South 16th Street Mall, Omaha, NE 68102-2247

U.S. Nuclear Regulatory Commission LIC-17-0052 Page 2 In Reference 1, the NRC issued an amendment to the FCS RFOL which approved the CSP and implementation schedule. The approved schedule stated the date that full implementation of the CSP for all Safety-Related, Security and Emergency Preparedness (SSEP) functions (MS8) would be completed. In Reference 2, the NRC issued an amendment revising the completion date for MS8 of the CSP based on justifications provided to meet the guidance in Reference 3. In Reference 4, OPPD requested an amendment revising the completion date for MS8 of the CSP based on justifications provided to meet the guidance in Reference 3. In Reference 5, OPPD notified the NRC of the permanent removal of fuel from the FCS Reactor Vessel.

Attachment 1 provides an evaluation of the proposed change.

This license amendment request (LAR) includes the existing RFOL marked up to show the proposed change (Attachment 2), a clean copy of the RFOL showing the proposed change (Attachment 3), the revised Cyber Security Commitment (Attachment 4), and the associated revised CSP Implementation Schedule (Attachment 5).

OPPD requests approval of the proposed amendment by April 7, 2018 with the amendment to be implemented within 90 days. The proposed changes have been reviewed and approved by the FCS Plant Operations Review Committee (PORC).

In accordance with 10 CFR 50.91, a copy of this amendment request, with attachments, is being provided to the designated State of Nebraska Official. There are no new regulatory commitments contained in this submittal.

If you should have any questions regarding this submittal, please contact Mr. Bradley H. Blome, Director Licensing & Regulatory Assurance, at 402-533-7270.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 16, 2017.

~~*

Mary J. Fisher Senior Director - FCS Decommissioning MJF/CJS/epm Attachment 1 - Evaluation of Proposed Change Attachment 2 - Proposed Markup of License Condition 3.C Attachment 3 - Clean License Condition 3.C Attachment 4 - Revised Cyber Security Commitment Attachment 5- Revised Cyber Security Plan Implementation Schedule c: K. M. Kennedy, NRC Regional Administrator, Region IV J. S. Kim, NRC Project Manager R. S. Browder, NRC Senior Health Physicist, Region IV Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

Ll C-17 -0052 Page 1 OPPD's Evaluation of the Proposed Change License Amendment Request 17-04:

Modification of License Condition 3.C to delete requirement for a Commission-approved Cyber Security Plan Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License DPR-40 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

Attachments:

Attachment 1 - Evaluation of Proposed Change Attachment 2- Proposed Markup of License Condition 3.C Attachment 3- Clean License Condition 3.C Attachment 4 - Revised Cyber Security Commitment Attachment 5 - Revised Cyber Security Plan Implementation Schedule

LIC-17 -0052 Page2 1.0

SUMMARY

DESCRIPTION The Omaha Public Power District (OPPD) is submitting a request for an amendment to Renewed Facility Operating License (RFOL) No. DPR-40 for Fort Calhoun Station (FCS), Unit No. 1. The license amendment request proposes the removal of the FCS Cyber Security Plan (CSP) from the FCS Operating License Condition. In Reference 6.1, the NRC issued an amendment to the FCS RFOL which approved the CSP and implementation schedule. The approved schedule stated the date that full implementation of the CSP for all Safety-Related, Security and Emergency Preparedness (SSEP) functions (MS8) would be completed. In Reference 6.2, the NRC issued an amendment revising the completion date for MS8 of the CSP based on justifications provided to meet the guidance in Reference 6.3. In Reference 6.4, OPPD requested an amendment revising the completion date for MS8 of the CSP based on justifications provided to meet the guidance in Reference 6.3.

OPPD has proposed to move the FCS MS8 compliance date from December 31, 2017 to December 28, 2018. This date was selected to permit sufficient time for OPPD to submit and the NRC to process a separate request for an amendment to remove the CSP from the FCS Operating License Condition. This amendment is that separate request. The December 28, 2018, date is past the time that analyses show that at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available from a partial drain down event where cooling of the spent fuel is not effective until the hottest fuel assembly reaches 900 degrees Celsius (0 C). Reference 6.5 shows this exact date to be April 7, 2018. This period of time will hereafter be referred to as the post zirconium fire accident scenario in the Spent Fuel Pool (SFP). contains the existing RFOL marked up to show the proposed change, Attachment 3 contains a clean markup of the proposed change, Attachment 4 contains the revised Cyber Security Commitment, and Attachment 5 contains the associated revised CSP Implementation Schedule.

2.0 DETAILED DESCRIPTION Cyber security requirements are codified in 10 CFR 73.54 and are designed to provide high assurance that digital computer and communication systems and networks are adequately protected against cyber-attacks up to and including the design basis threat established by 10 CFR 73.1. 10 CFR 73.54 specifically requires each licensee currently licensed to operate a nuclear power plant under part 50 of this chapter to implement a CSP that satisfies the requirements of the Rule in accordance with a NRC approved CSP implementation schedule.

On July 27, 2011, the NRC issued Amendment No. 266 to RFOL No. DPR-40 for FCS (Reference 6.1 ). Amendment No. 266 incorporated the CSP and associated implementation schedule, and revised the RFOL to provide a license condition requiring OPPD to fully implement and maintain in effect all provisions of the NRC-approved CSP. On November 19, 2015, the NRC issued Amendment No. 284 to RFOL No. DPR-40 for FCS (Reference 6.2).

Amendment No. 284 revised the MS 8 completion date. Any change to the NRC-approved CSP implementation schedule requires prior NRC approval pursuant to 10 CFR 50.90.

LIC-17-0052 Page3 On March 24, 2017, OPPD requested an amendment revising the completion date for MS8 of the CSP based on justifications provided to meet the guidance in Reference 6.3 (Reference 6.4). OPPD has proposed to move MS8 compliance date from December 31, 2017 to December 28, 2018. This date was selected to permit sufficient time for OPPD to submit and the NRC to process a separate request for an amendment to remove the Facility Operating License Condition for the CSP. This is that amendment request. The extension date is based on the analyses that show that at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available from a partial drain down event where cooling of the spent fuel is not effective until the hottest fuel assembly reaches 900 degrees Celsius ( 0 C).

This license amendment request proposes the removal of the FCS Cyber Security Plan (CSP) from the FCS Operating License Condition. The technical justification to support the removal of the CSP is provided in Section 3.0, below. The corresponding revision to the cyber security commitment is provided in Attachment 4. The revision to the MS8 completion date in the FCS I OPPD CSP Implementation Schedule is provided in Attachment 5.

3.0 TECHNICAL EVALUATION

The current regulatory language in 10 CFR 73.54 does not address the application of the cyber security rule to decommissioning nuclear power reactors that have filed certifications under 10 CFR 50.82, "Termination of license," but still have fuel in the spent fuel pool (SFP).

In Reference 6.6, on November 13, 2016, OPPD submitted a letter to NRC certifying permanent removal of fuel from the reactor vessel as required by 10 CFR 50.82.

The proposed amendment is based on the comparison of the risks at an operating nuclear power reactor as opposed to a nuclear power reactor that has permanently ceased operations and has removed all fuel from the reactor vessel. The spectrum of possible accidents are significantly fewer and the risk of an offsite radiological release is significantly lower for a permanently defueled reactor. The reduced cyber security risk is due, in part, to the fact that there are fewer critical digital assets (CDAs) at a decommissioning reactor in comparison to the number of CDAs at an operating reactor. For example, once spent fuel is moved from the reactor vessel and placed in the spent fuel pool (SFP), the digital computers and communication systems and networks that require cyber protection are primarily those associated with security and emergency preparedness (EP) functions, and those safety systems that support operation of the SFP.

Post zirconium fire: (1) there are no applicable design-basis events at Fort Calhoun that could result in an offsite radiological release exceeding the limits established by the U.S.

Environmental Protection Agency's early phase protective action guidelines of 1 rem at the exclusion area boundary; and (2) sufficient time would exist to take prompt mitigative actions in response to a postulated zirconium fire accident scenario in the SFP. Post zirconium fire, the fuel in the SFP cannot reasonably heat up to clad ignition temperature within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is sufficient time for plant staff to reliably implement required mitigation strategies to prevent spent fuel heat-up damage. This rationale is similar to the rationale used to justify a reduction of emergency preparedness requirements during decommissioning, as detailed in NUREG 1738 and documented in safety evaluations associated with decommissioning plant emergency preparedness exemption requests. (Reference 6.1 0)

L1 C-17 -0052 Page4 The NRC recently released several documents that support this position. The first is the Cyber Security Requirements for Decommissioning Nuclear Power Plants, dated December 5, 2016 (Reference 6. 7). The second document is the Draft Regulatory Basis Document titled Regulatory Improvements for Power Reactors Transitioning to Decommissioning, dated March 2017. (Reference 6.8)

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements I Criteria On July 27, 2011, the NRC issued Amendment No. 266 to RFOL No. DPR-40 for FCS (Reference 6.1 ). Amendment No. 266 incorporated the CSP and associated implementation schedule, and revised the RFOL to provide a license condition requiring OPPD to fully implement and maintain in effect all provisions of the NRC-approved CSP. On November 19, 2015, the NRC issued Amendment No. 284 to RFOL No. DPR-40 for FCS (Reference 6.2).

Amendment No. 284 revised the MS 8 completion date. Any change to the NRC-approved CSP implementation schedule requires prior NRC approval pursuant to 10 CFR 50.90.

4.2 Precedent On May 9, 2017, the NRC approved the removal of Kewaunee Power Station Cyber Security Plan. (Reference 6.9) 4.3 No Significant Hazards Consideration OPPD 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, "Issuance of amendment," as discussed below:

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

Response: No The proposed change to remove the Fort Calhoun Station Cyber Security Plan requirement 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.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

LIC-17 -0052 Page 5

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

Response: No The proposed change to remove the Fort Calhoun Station Cyber Security Plan requirement 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.

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

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

Response: No The amendment proposes the elimination of the CSP as set forth in the CSP Implementation Schedule and associated regulatory commitments. The elimination of the CSP does not involve modifications to any safety- related SSCs. The proposed amendment is based on the comparison of the risks at an operating nuclear power reactor as opposed to a nuclear power reactor that has permanently ceased operations and has removed all fuel from the reactor vessel. The spectrum of possible accidents are significantly fewer and the risk of an offsite radiological release is significantly lower for a permanently defueled reactor.

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

Based on the above, OPPD concludes that the proposed amendment does not involve a 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.

4.4 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 amendments will not be detrimental to the common defense and security or to the health and safety of the public.

LIC-17-0052 Page 6

5.0 ENVIRONMENTAL CONSIDERATION

A review of the proposed amendment has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 . Letter from NRC (L. E. Wilkins) to OPPD (D. J. Bannister), "Fort Calhoun Station, Unit No. 1 - Issuance of Amendment: RE: Approval of Cyber Security Plan (TAC No. ME4380)," dated July 27, 2011 (NRC-11-0082) (ML111801094) 6.2. Letter from NRC (C. F. Lyon) to OPPD (L. P. Cortopassi), "Fort Calhoun Station, Unit No. 1 - Issuance of Amendment RE: Revision to Cyber Security Plan Implementation Schedule Completion Date (CAC No. MF5854)," dated November 19, 2015 (NRC-15-096) (ML15070A007) 6.3. Memorandum from NRC (R. Felts) to NRC (B. Westreich), "Review Criteria for Title 10 of the Code of Federal Regulations Part 73.54, Cyber Security Implementation Schedule Milestone 8 License Amendment Requests," dated October 24, 2013 (ML13295A467) 6.4. Letter from OPPD (M. J. Fisher) to NRC, "License Amendment Request 17-02; Request Extension for Milestone 8 of Cyber Security Plan Implementation Schedule," dated March 24, 2017 (LIC-17-0016) (CAC No. MF9559) 6.5. Letter from OPPD (S. Marik) to USNRC (Document Control Desk), "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E," dated December 16, 2016 (LIC-16-0109) (ADAMS Accession No. ML16356A578) (CAC No.

MF9067) 6.6. Letter from OPPD (T. J. Burke) to USNRC (Document Control Desk), "Certification of Permanent Removal of Fuel from the Reactor Vessel," dated November 13, 2016 (LIC-16-0074) (ML16319A254) 6.7. Letter from NRC (V. M. McCree) to NRC Commissioners, "Cyber Security Requirements for Decommissioning Nuclear Power Plants", dated December 5, 2016 (ML16172A284) 6.8. Draft Regulatory Basis Document, "Regulatory Improvements for Power Reactors Transitioning to Decommissioning", dated March 2017. (NRC Docket ID: NRC-2015-0070) 6.9. Dominion Energy Kewaunee, Inc. Amendment to Facility Operating License Amendment No. 219 for License No. DPR-43, dated May 9, 2017.

LIC-17-0052 Page 7 6.1 0. Letter from OPPD (S. M. Marik) to US NRC (Document Control Desk), "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E," Dated December 16, 2016 (LIC-16-0109) (ML16356A578)

LIC-17 -0052 Page 1 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No: DPR-40 Proposed Markup of License Condition 3.C (Word-processor mark-ups using "double underline/strikeout" feature for "new text/deleted text" respectively, Bold text indicates previously submitted unapproved proposed changes for clarity of review.)

(4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or when associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

A. Maximum Power Level Omaha Public Power District is authorized to operate the Fort Calhoun Station, Unit 1, at steady state reactor core power levels not in excess of 1500 megawatts thermal (rate power).

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. XXX, are hereby incorporated in the license. Omaha Public Power District shall operate the facility in accordance with the Technical Specifications.

C. Security and Safeguards Contingency Plans The Omaha Public Power District shall fully implement and maintain in effect all provisions 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: "Fort Calhoun Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan," submitted by letter dated May 19, 2006.

OPPD shall fully implement and maintain in effect all provisions of tho Commission appro'led Cybor Security Plan (CSP), including changes mado pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). Tho OPPD CSP

'.Vas approved by License Amendment No. 266 and modified by License Amendment No. 284 and Amendment No. XXX Renewed Operating License No. DPR-40 Amendment No. 2:7+, XXX

Ll C-17 -0052 Page 1 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 Clean License Condition 3.C

Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or when associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the foHowing Commission regulations in 10 CFR Chapter 1: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

A Maximum Power Level Omaha Public Power District is authorized to operate the Fort Calhoun Station, Unit 1, at steady state reactor core power levels not in excess of 1500 megawatts thermal (rate power).

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. XXX, are hereby incorporated in the license. Omaha Public Power District shall operate the facility in accordance with the Technical Specifications.

C. Security and Safeguards Contingency Plans The Omaha Public Power District shall fully implement and maintain in effect all provisions 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: "Fort Calhoun Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan," submitted by letter dated May 19, 2006.

Ll C-17-0052 Page 1 Revised Cyber Security Commitment Fort Calhoun Station Unit 1 Renewed Facility Operating License No. DPR-40 (Word-processor mark-ups using "double underline/strikeout" feature for "new text/deleted text" respectively, Bold text indicates previously submitted unapproved proposed changes for clarity of review.)

LIC-17-0052 Page2

1. lm plementation Completion Basis Milestone Date 8 Fl::lll imf3lementatien ef Na lateF thaR 8y tt:le semJ3Ietien Elate, ~GS t Qp~g FGS 1- Qppg Gyeer DeGembeF 31, Gyl3eF Sesl::IFity ~lan 1~ttilll3e ft::~lly Sesl::IFity Plan feF all 2M+ imf3lemented fSF all SSE~ ft::~nstiens in SSE~ f1:1nstiens y,<illl3e No lateE than asseFdanse 1NitR ~ Q GFR 73.94. +t:lis Elate asRie'+<eEI. June 30. 2018 alse l3et::~nEis tRe G9FRJ3Ietien ef all inEii\<iEit::~al asset sesi:IFity sentFel Elesign Deleted FemeEiiatien astiens insi1:1Eiing tt:lese tt:lat FequiFe a refuel eutage fOF imf3lementatien.

Ihe Eeguested MSB e~:ten&ion to June 30 1 20~ 8 is based on additional time foE o~~g to submit and ME the NBG to gmsess a segaEate E&gue&t ME an amendment to Eemo¥e the Easilitv OgeEating l.isense Gondition that Eeguil:es imglementalion of the GS~.

Ll C-17-0052 Page 1 Revised FCS I OPPD Cyber Security Plan Implementation Schedule Fort Calhoun Statjon Unjt 1 Renewed Facility Operating License No.: DPR-40

UC-17-0052 Page2

1. Implementation Completion Basis Milestone Date 8 Deleted