First, there is no exception for situations that are not considered a significant safety concern. The NSAL also fails to define a significant safety concern. The NSAL suggests that the licensee, not just the regulator, can make an exception to meeting design requirements or licensing criteria.
Furthermore, an increased focus upon the design requirements of the ANS Standard , and how they work in concert with federal nuclear safety regulations (e.g., 10 CFR 50), and Standard Review Plans (SRPs or NUREG 0800) could help the NRC review staff to perform more effective reviews of LARs. This could result in more robust (i.e., complete) licensing bases, supported by relevant analyses and evaluations that definitively demonstrate compliance with all applicable design requirements, particularly the nonescalation design requirement that is important in ANS Conditions II and III. 153554b96e