The possibility of realizing Small Modular Reactors (SMRs) in the United States is increasing as the technology matures through the licensing process and inevitably is introduced to the nuclear energy market. As this technology is approved in the United States, a Nuclear Weapons (NW) State, certain nuclear safeguard differences must be taken into consideration if the technology were exported abroad to a Non-Nuclear Weapons (NNW) State that requires International Atomic Energy Agency (IAEA) oversight under the Nuclear Non-Proliferation Treaty (NPT). The concept of safeguards-by-design (SBD) has gained traction with new designs of conventional large reactors, however, the current light-water reactor SMRs that are most likely to get licensed have not mentioned taking into account SBD in their preliminary designs. Due to the modularity, fuel life, storage of spent fuel, and other attributes of these SMR designs, the conventional method of safeguarding light-water reactors must be rethought. This paper discusses these IAEA nuclear safeguards considerations for the specific category of light-water SMRs by taking into account the four major reactor designs being pushed through the Nuclear Regulatory Commission (NRC) and addressing the unique aspect of SMRs that can cause deviation from conventional IAEA inspection practices for light-water reactors. In particular, inspection and containment and surveillance requirements become stressed if multiple SMRs are located at one site with continuous refueling taking place in series from one reactor to the next. Some of these new designs are very compact making access to spent fuel pools or reactor vessel seals more difficult. Potential changes in either IAEA inspection regimes or recommendations on how to implement existing requirements are provided for the case of light-water SMRs under IAEA safeguards. These results must be evaluated closely in order for SMRs to be exported widely to other countries.
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