Since most US SMR vendors will apply for a ‘reference’ plant design to be certified by the NRC with multiple modules included in the reference design, the NRC had to consider how it should issue the license(s) to the reference plant. Should the NRC issue a facility license to the multiple-modular plant, or should it issue a license for each module? The NRC’s consideration of this issue was addressed in SECY-11­0079 (12 June 2011). The NRC staff recommended that the reference plant can be reviewed and issued a design certification for all modules. NRC will permit a single design certification if the modules are a generic design that will support a single licensing review, SER and public hearing.

However, it decided that each module should be issued a separate license with attendant specific technical (but largely generic) specifications. This recommendation was mainly based on the phased deployment of modules, and the operation and maintenance of each module over its operating life — it may be deployed, operated, maintained, and decommissioned separately from each other module. International licensing of a multiple-module plant should consider and address these same licensing issues.

11.2.3.1 Manufacturing license

SMR modules will be manufactured in a factory-like setting and then the modules will be transported to the site for final fabrication and installation. Manufacturing in this manner offers advantages in quality and efficiency through replication, assembly-line construction, and the maintenance of a stable and skilled workforce. NRC requirements in 10 CFR 52.167 permit the issuance of a manufacturing license with necessary and sufficient ITAACs to ensure the reactor is manufactured and operated in accordance with its license. Although no application has been submitted for a manufacturing license under Part 52, the US nuclear industry recommends that the NRC develop further licensing guidance on these requirements and how ITAAC provisions will be applied both in the plant and at the site. NRC requirements also do not address the export of SMR modules since these reactors will be licensed by the importing or host country. The importing country and customer must meet all US law and regulatory export requirements, including NRC’s requirements in 10 CFR 110, ‘Export and Import of Nuclear Equipment and Material’, and DOE’s requirements in 10 CFR 810, ‘Assistance to Foreign Atomic Energy Activities.’ These requirements are in the process of revision and should be considered by both exporters of US SMRs and importing countries and companies.