I see the point you are making and understand that as the regulations currently sit by definition it would seem an SML would not be needed.
Laws evolve and change as technology does, was there a law covering ISL uranium mining before it was invented? No there wasn't.
Recently you would have seen in the news synthetic drugs were able to be purchased in stores, because there was no law covering them. Legislation has now been written to cover them making them controlled and illegal.
AB tech will have to cross these bridges as it progresses, I am not sure if the actual process would need an SML or the Unit could be plonked on site with a 3rd party that already has an SML, or it may not need one at all. All this is yet to be defined and the NRC will have to do it now they are aware of it.
cheers
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