Letter Sequence Other |
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Results
Other: LIC-03-0164, Response to a RAI on Measurement Uncertainty Recapture Power Uprate, LIC-04-0006, Closure of NRC Tack Issues for Fort Calhoun Station Unit No. 1, LIC-04-0061, Notification of Technical Issues Associated with License Amendment No. 225, ML032870394, ML040210313, ML040400333, ML040490383, ML041060362, ML041310501, ML041390246, ML043370117, ML050530011, ML050600428, ML050610222, ML050750059
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MONTHYEARLIC-03-0067, Amendment Request for License DPR-40 Measurement Uncertainty Recapture Power Uprate2003-07-18018 July 2003 Amendment Request for License DPR-40 Measurement Uncertainty Recapture Power Uprate Project stage: Request ML0328703942003-10-14014 October 2003 Withholding from Public Disclosure, Calculation Number FC-6896-P, Secondary Calorimetric Uncertainty Analysis Project stage: Other ML0328705202003-10-14014 October 2003 RAI, Measurement Uncertainty Recapture Power Uprate Project stage: RAI LIC-03-0148, Response to Request for Additional Information - Measurement Uncertainty Recapture Power Uprate2003-10-31031 October 2003 Response to Request for Additional Information - Measurement Uncertainty Recapture Power Uprate Project stage: Response to RAI LIC-03-0164, Response to a RAI on Measurement Uncertainty Recapture Power Uprate2003-12-15015 December 2003 Response to a RAI on Measurement Uncertainty Recapture Power Uprate Project stage: Other LIC-03-0166, Response to Request for Additional Information Regarding Measurement Uncertainty Recapture Power Uprate2003-12-22022 December 2003 Response to Request for Additional Information Regarding Measurement Uncertainty Recapture Power Uprate Project stage: Response to RAI ML0402007572004-01-16016 January 2004 Issuance of License Amendment 224 Revising the Renewed Operating License and the TSs to Increase the Licensed Rated Power by 1.6 Percent from 1500 Megawatts Thermal (Mwt) to 1524 Mwt Project stage: Approval ML0402103132004-01-16016 January 2004 Tech Spec Pages for Amendment 224 Revising the Renewed Operating License and the TSs to Increase the Licensed Rated Power by 1.6 Percent from 1500 Megawatts Thermal (Mwt) to 1524 Mwt Project stage: Other ML0404003332004-02-0909 February 2004 Fort Calhoun Station, Unit 1 - Public Notice of Application for Amendment to Facility Operating License Project stage: Other ML0404903832004-02-13013 February 2004 Amendment, Changes Implementation Date from 30 Days to 120 Days for Amendment No. 224 Issued on 01/16/2004 That Approved Measurement Uncertainty Uprate to Increase Licensed Rated Power by 1.6 Percent from 1500 Megawatts Thermal to 1524 Project stage: Other ML0405803462004-02-18018 February 2004 RAI, License Amendment Request Administrative TS Changes (Tac. MC1535) Project stage: RAI ML0410603622004-04-14014 April 2004 Memo to File, E-mail Regarding Fort Calhoun Emergency Diesel Generating Starting Air System Project stage: Other LIC-04-0061, Notification of Technical Issues Associated with License Amendment No. 2252004-05-0505 May 2004 Notification of Technical Issues Associated with License Amendment No. 225 Project stage: Other ML0413105012004-05-10010 May 2004 5/10/04, Fort Calhoun, Unit 1 - Public Notice of Application for Amendment to Facility Operating License Project stage: Other ML0413901262004-05-14014 May 2004 5/14/04, Fort Calhoun, Unit 1 - TS - Issuance of Amendment Project stage: Approval ML0413902462004-05-14014 May 2004 License Amendment, Amendment Restores Licensed Thermal Power from 1524 Mega Thermal Project stage: Other LIC-04-0073, Response to Request for Additional Information Regarding License Amendment Request, Addition of Diesel Generator Fuel Oil, Diesel Generator Lubricating Oil, & Diesel Generator Starting Air Requirements2004-07-0202 July 2004 Response to Request for Additional Information Regarding License Amendment Request, Addition of Diesel Generator Fuel Oil, Diesel Generator Lubricating Oil, & Diesel Generator Starting Air Requirements Project stage: Response to RAI ML0421202032004-07-23023 July 2004 Tech Spec Pages for Amendment 228 Various Administrative and Editorial Changes Project stage: Acceptance Review ML0421104112004-07-23023 July 2004 Issuance of License Amendment 228 Various Administrative and Editorial Changes Project stage: Approval ML0424300272004-08-27027 August 2004 RAI, Modify Technical Specification 2.3.(4) Project stage: RAI ML0430205742004-10-21021 October 2004 Issuance of License Amendment No. 229, Changing TS 2.7, TS Table 3-5 and TS 5.0 to Modify Requirements for the Diesel Generator Fuel Oil for Consistency with Improved Standard TS Project stage: Approval ML0433501352004-10-21021 October 2004 Tech Spec Pages for Amendment No. 229, Changing TS 2.7, TS Table 3-5 and TS 5.0 to Modify Requirements for the Diesel Generator Fuel Oil for Consistency with Improved Standard TS Project stage: Acceptance Review LIC-04-0102, Request for Additional Information (RAI) Regarding License Amendment Request (Lar), Trisodium Phosphate (TSP) Dodecahydrate Volume.2004-10-29029 October 2004 Request for Additional Information (RAI) Regarding License Amendment Request (Lar), Trisodium Phosphate (TSP) Dodecahydrate Volume. Project stage: Request ML0432705302004-11-0808 November 2004 Issuance of License Amendment No. 230 Relocating Requirements of TS 3.3(1)a and Other Components Subject to ASME XI Boiler & Pressure Vessel Code Inspection and Testing Surveillance and TS 3.4 to Update UFSAR Project stage: Approval ML0433701172004-11-0808 November 2004 TS Pages for Amendment No. 230 Relocating Requirements of TS 3.3(1)a and Other Components Subject to ASME XI Boiler & Pressure Vessel Code Inspection and Testing Surveillance and TS 3.4 to Update UFSAR Project stage: Other LIC-04-0133, Response to NRC RAI on Trisodium Phosphate (TSP) License Amendment Request2004-12-16016 December 2004 Response to NRC RAI on Trisodium Phosphate (TSP) License Amendment Request Project stage: Response to RAI ML0505300112005-02-18018 February 2005 Tech Spec Page for Amendment 231 Elimination of Requirements to Provide Monthly Operating/Annual Occupational Radiation Exposure Reports Project stage: Other ML0505500612005-02-18018 February 2005 Issuance of License Amendment 231 Elimination of Requirements to Provide Monthly Operating/Annual Occupational Radiation Exposure Reports Project stage: Approval ML0506004282005-03-0101 March 2005 Amendment, Revision of TS Section 2.3(4) & TS Section 3.6(2)d.(i) Project stage: Other ML0506102222005-03-0101 March 2005 Technical Specifications, Revision of TS Section 2.3(4) & TS Section 3.6(2)d.(i) Project stage: Other ML0507500592005-03-11011 March 2005 Tech Spec Pages for Amendment 233 Revising TS 5.9.5 to Be Consistent with Specification 5.6.5 of NUREG-1432 Project stage: Other ML0507505342005-03-11011 March 2005 Issuance of License Amendment 233 Revising TS 5.9.5 to Be Consistent with Specification 5.6.5 of NUREG-1432 Project stage: Approval LIC-04-0006, Closure of NRC Tack Issues for Fort Calhoun Station Unit No. 12005-07-0101 July 2005 Closure of NRC Tack Issues for Fort Calhoun Station Unit No. 1 Project stage: Other 2004-02-18
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Category:Letter type:LIC
MONTHYEARLIC-23-0007, Response to Fort Calhoun, Unit 1 & Independent Spent Fuel Storage Installation Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements Request for Additional Information2023-12-0606 December 2023 Response to Fort Calhoun, Unit 1 & Independent Spent Fuel Storage Installation Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements Request for Additional Information LIC-23-0005, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 20232023-08-24024 August 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - 2nd Request for Additional Information (EPID L-2021-LIT-0000) June 2, 2023 LIC-23-0004, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2023-04-20020 April 2023 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-23-0003, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2023-03-15015 March 2023 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-23-0001, Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information2023-02-27027 February 2023 Response to Fort Calhoun Station, Unit No. 1 - Review of License Amendment Request to Add License Condition to Include License Termination Plan Requirements - Request for Additional Information LIC-23-0002, Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report2023-02-20020 February 2023 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report LIC-22-0010, Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information2022-06-15015 June 2022 Response to Fort Calhoun Station, Unit No. 1 - Review of License Termination Plan Requirements - Request for Additional Information LIC-22-0005, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2022-04-20020 April 2022 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-22-0009, Annual Decommissioning Funding / Irradiated Fuel Management Status Report2022-03-30030 March 2022 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-22-0006, Reactor Head Disposition Project Overview2022-03-17017 March 2022 Reactor Head Disposition Project Overview LIC-22-0004, Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report2022-02-17017 February 2022 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report LIC-21-0008, Organizational and Management Change2021-10-28028 October 2021 Organizational and Management Change LIC-21-0007, ISFSI Only Emergency Plan Update2021-09-0808 September 2021 ISFSI Only Emergency Plan Update LIC-21-0004, Radiological Effluent Release Report and Radiological Environmental Operating Report2021-04-29029 April 2021 Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-21-0003, Independent Spent Fuel Storage Installation - 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report2021-03-30030 March 2021 Independent Spent Fuel Storage Installation - 2021 Annual Decommissioning Funding / Irradiated Fuel Management Status Report LIC-21-0002, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2021-02-22022 February 2021 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-20-0015, Correction to Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report 2019 (ML20121A092)2020-07-29029 July 2020 Correction to Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report 2019 (ML20121A092) LIC-20-0014, Submittal of Revision 8 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP)2020-07-15015 July 2020 Submittal of Revision 8 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) LIC-20-0012, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration and Certification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2020-05-18018 May 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration and Certification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool LIC-20-0011, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-05-0707 May 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0009, (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report2020-04-30030 April 2020 (FCS) Radiological Effluent Release Report and Radiological Environmental Operating Report LIC-20-0008, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-04-13013 April 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0006, (Fcs), Unit 1, Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E2020-03-26026 March 2020 (Fcs), Unit 1, Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E LIC-20-0004, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-03-10010 March 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-20-0003, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2020-02-27027 February 2020 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-20-0002, Independent Spent Fuel Storage Installation - Submittal of Revision 7 to Physical Security Plan2020-02-27027 February 2020 Independent Spent Fuel Storage Installation - Submittal of Revision 7 to Physical Security Plan LIC-20-0001, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2020-02-0606 February 2020 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0025, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-12-19019 December 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0007, Post-Shutdown Decommissioning Activities Report2019-12-16016 December 2019 Post-Shutdown Decommissioning Activities Report LIC-19-0021, Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme2019-11-20020 November 2019 Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme LIC-19-0022, Independent Spent Fuel Storage Installation (ISFSI) Cask Registration2019-11-18018 November 2019 Independent Spent Fuel Storage Installation (ISFSI) Cask Registration LIC-19-0018, Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP)2019-11-14014 November 2019 Submittal of Revision 6 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) LIC-19-0020, Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis2019-10-17017 October 2019 Independent Spent Fuel Storage Installation - Updated Information Submittal and Revision 1 of the Blast Analysis LIC-19-0017, Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 20042019-08-0808 August 2019 Clarification to Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 An LIC-19-0010, License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associa2019-05-20020 May 2019 License Amendment Request (LAR) 19-03; Revised Fort Calhoun Station License in Support of the Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated LIC-19-0008, Submittal of 2018 Annual Report2019-04-0404 April 2019 Submittal of 2018 Annual Report LIC-19-0004, Independent Spent Fuel Storage Installation - Submittal of Revision 4 to Physical Security Plan (PSP)2019-03-28028 March 2019 Independent Spent Fuel Storage Installation - Submittal of Revision 4 to Physical Security Plan (PSP) LIC-19-0005, 2019 Annual Decommissioning Funding I Irradiated Fuel Management Status Report2019-03-28028 March 2019 2019 Annual Decommissioning Funding I Irradiated Fuel Management Status Report LIC-19-0001, License Amendment Request (LAR) 19-01: Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme2019-02-28028 February 2019 License Amendment Request (LAR) 19-01: Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme LIC-19-0003, Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 and Relaxation R2019-02-28028 February 2019 Revised Response to Orders for Interim Safeguards and Security Compensatory Measures and Implementation of Additional Security Measures Associated with Access Authorization for Fort Calhoun Station Dated 9 November, 2004 and Relaxation Requ LIC-19-0002, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2019-01-0303 January 2019 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report LIC-18-0031, Independent Spent Fuel Storage Installation - Transmittal of Emergency Plan Update2018-12-17017 December 2018 Independent Spent Fuel Storage Installation - Transmittal of Emergency Plan Update LIC-18-0030, Request for Partial Site Release Phase 22018-11-12012 November 2018 Request for Partial Site Release Phase 2 LIC-18-0028, Letter of Intent to Submit Request for Additional Partial Site Release2018-10-18018 October 2018 Letter of Intent to Submit Request for Additional Partial Site Release LIC-18-0027, Submittal of Foreign Ownership, Control or Influence Five-Year Renewal Filing and NRC Facility Clearance Update2018-10-0303 October 2018 Submittal of Foreign Ownership, Control or Influence Five-Year Renewal Filing and NRC Facility Clearance Update LIC-18-0003, License Amendment Request (LAR) 18-01; Revised Fort Calhoun Station Permanently Defueled Technical Specifications to Align to Those Requirements for Permanent Removal of Spent Fuel from Spent Fuel Pool2018-09-28028 September 2018 License Amendment Request (LAR) 18-01; Revised Fort Calhoun Station Permanently Defueled Technical Specifications to Align to Those Requirements for Permanent Removal of Spent Fuel from Spent Fuel Pool LIC-18-0025, Guarantee of Payment of Deferred Premiums for the Period of July 1, 2018 to June 30, 20192018-07-19019 July 2018 Guarantee of Payment of Deferred Premiums for the Period of July 1, 2018 to June 30, 2019 LIC-18-0023, Fort Calhoun Station, Unit 1 Request for Partial Site Release2018-06-29029 June 2018 Fort Calhoun Station, Unit 1 Request for Partial Site Release LIC-18-0021, Transmittal of Revision 3 to the Physical Security Plan (PSP) and Revision 4 to the FCS Protective Strategy (Safeguards Contingency Plan)2018-06-0606 June 2018 Transmittal of Revision 3 to the Physical Security Plan (PSP) and Revision 4 to the FCS Protective Strategy (Safeguards Contingency Plan) LIC-18-0017, Submittal of Revision 2 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) and Revision 3 of the FCS Protective Strategy2018-04-26026 April 2018 Submittal of Revision 2 to the Fort Calhoun Station (Fcs), Physical Security Plan (PSP) and Revision 3 of the FCS Protective Strategy 2023-08-24
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Omaha Public PoweArDistrct Fort Calhoun Station P.O. Box 550, Highway 75 Fort Calhoun, NE 68023-0550 December 15, 2003 LIC-03-0164 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
References:
- 1. Docket No. 50-285
- 2. Letter from OPPD (S. K. Gambhir) to NRC (Document Control Desk) dated August 28, 2003, Fort Calhoun Station (FCS) Unit No. 1 License Amendment Request, "Measurement Uncertainty Recapture Power Uprate" (LIC-03-0122)
- 3. Letter from NRC (A. B. Wang) to OPPD (R. T. Ridenoure) dated October 14, 2003, "Fort Calhoun Station Unit No. 1 - Measurement Uncertainty Recapture Power Uprate" (TAC No. MC0029) (NRC 198)
- 4. Letter from OPPD (S. K. Gambhir) to NRC (Document Control Desk) dated October 21, 2003, Response to Request for Additional Information - Measurement Uncertainty Recapture Power Uprate (LIC-03-0148)
SUBJECT:
Response to Additional Request for Information - Measurement Uncertainty Recapture Power Uprate (TAC No. MC0029)
The Reference 3 letter from the NRC included a Request for Additional Information (RAI) to support staff review of the Reference 2 License Amendment Request. The Reference 4 letter provided the Omaha Public Power District (OPPD) response to the RAI.
On December 5, 2003, a telephone call between NRC/NRR staff members and OPPD resulted in an additional request for information concerning instrument setpoint methodology. This request and the OPPD response are included in the attachment.
Please contact T. C. Matthews at (402) 533-6938 if you require additional information.
pea;1 Emplopynent wvith Equal Opportunity
U.S. Nuclear Regulatory Commission LIC-03-01 64 Page 2 I declare under penalty of perjury that the forgoing is true and correct. (Executed on December 15, 2003) No commitments to the NRC are made in this letter.
Sincerely, ambhir Division Manager Nuclear Projects TCM/tcm Attachment c: B. S. Mallett, Regional Administrator, NRC Region IV A. B. Wang, NRC Project Manager J. G. Kramer, NRC Senior Resident Inspector Division Administrator - Public Health Assurance, State of Nebraska
LIC-03-0164 Attachment Page 1 NRC Request for Information (Instrument Setpoint Methodology):
Discuss the instrument setpoint methodology used to calculate trip setpoints and allowable values of the plant parameters affected by the power uprate. If you use method 3 specified in ISA S67.04.02, then confirm that a check calculation is performed to account for all loop uncertainty not measured during the Channel Operational Test /
Channel Functional Test. Provide a sample calculation to demonstrate this.
NOTE: If your methodology has not been previously reviewed by the NRC staff, then submit a copy of plant instrument setpoint methodology for staff's review and approval.
OPPD Response:
The question is taken as a request to describe how we account for all components of instrument uncertainty when checking setpoints as part of a periodic functional check or a refueling frequency as-found operability check. Method 3 of ISA-RP67.04.02 allows certain components of uncertainty to be removed from the nominal trip setpoint in the determination of an allowable value. The inference in the RAI is that there is a need to perform a check calculation when using an allowable value, as defined in the ISA recommended practice, for periodic setpoint checks.
Uncertainty calculations for RPS and ESF at Fort Calhoun Station were reconstituted in the early 1990s using the 67.04 methodology. Since setpoints and associated procedural tolerances already existed prior to the reconstitution effort, uncertainty calculations were performed with the intent of demonstrating that total instrument loop uncertainty (TLU) was bounded by the current setpoint values identified in plant calibration procedures.
There was no attempt to make use of allowable values as defined in method 3 of section 7.3 of ISA-RP67.04.02. The setpoint tolerance utilized for quarterly functional checks is used as a component of the overall loop uncertainty and therefore is accounted for in the loop calculation. The concept of allowable value was intended as a means to remove some of the conservatism from the loop uncertainty calculation for periodic setpoint checks. This was not needed at FCS for RPS and ESF setpoints, because historical trends showed that there was very little drift in these setpoints.
Since method 3 of ISA-RP67.04.02 is not utilized at FCS to calculate and apply allowable values, there is no need to perform a check calculation. There is always adequate margin between the analytical limit and the worst case setpoint to account for all of the required components included in the TLU calculation. If a setpoint is found outside the tolerance permitted in the calibration or functional check procedure, the loop is considered inoperable and action is taken to restore it to the proper range.
It should be mentioned that, as part of the instrument uncertainty reconstitution project, some of the upgraded calculations did include a separate calculation for allowable value.
LIC-03-0164 Attachment Page 2 Furthermore, the FCS-specific methodology includes instructions on how to calculate allowable value. However, as mentioned above, FCS has not made use of this allowable value in calibration procedures or functional checks since it was not considered necessary.
Because the current RPS and ESF setpoints do not incorporate allowable values as defined by method 3 of ISA-RP67.04.02, any change to these setpoints to incorporate method 3 allowable values would require prior NRC approval of changes to applicable Technical Specifications.