IAEA DESIGN INFORMATION VERIFICATION AUTHORITIES FOR SMALL MODULAR REACTORS: POTENTIAL CHALLENGES AND SOLUTIONS

摘要

A key benefit of many small modular reactor(SMR) designs is the ability to construct majorreactor components in a factory setting forsubsequent onsite assembly. However, this approachcould pose challenges for International AtomicEnergy Agency (IAEA) design informationverification (DIV) activities. The IAEA conducts DIVat reactor construction sites in order to verify thatcomponents match the declared facility designsbefore they are fully integrated and becomeinaccessible to inspectors. It is through DIV that theIAEA can design a safeguards approach thateffectively addresses potential diversion and misusescenarios and confirm its continued adequacy overtime. Under Comprehensive Safeguards Agreements,the IAEA’s authority to conduct DIV adheres at“facilities,” defined by either the presence of nuclearmaterial in certain quantities or by certain functionalaspects irrespective of the presence of nuclearmaterial. Power reactors have traditionally beenconstructed and operated in the same location, whereDIV could be conducted throughout. For some SMRdesigns in development, however, certain reactorcomponents may be fully installed at a factory ratherthan the ultimate construction/operation site, raisingthe prospect that some SMRs may be manufactured,fueled, and/or operated in different locations, or evendifferent countries (with different safeguardsagreements and obligations). As a result, locationsother than an SMR’s final site of operation maybecome potentially significant for DIV, while it is asyetunclear whether or how the IAEA’s authority toconduct DIV extends to such locations, particularlyin international supply scenarios.These developments may require the IAEA toadapt the way that it interprets its legal authoritiesand conducts technical verification measures. Twoissues are particularly important. First, the NuclearNon-Proliferation Treaty (NPT) obligates only nonnuclearweapon states under its framework to acceptIAEA safeguards, which include access for IAEAdesign verification. This raises important questionsabout whether and how the IAEA might conduct DIVactivities for reactors being supplied by a nuclearweapon state to a non-nuclear weapon state. Second,certain IAEA verification authorities pertain tolocations that handle nuclear materials. For SMRfabrication sites where no nuclear materials will bepresent, inspectors may have to invoke a differentbasis for access than IAEA has used in the past, orpossibly contend with more limited access rights anda less robust toolkit to verify reactor designs.This paper reviews different safeguardsagreements (including INFCIRC/153 and the ModelAdditional Protocol) and discusses IAEA legalauthorities that may be relevant to DIV for smallmodular reactors. By considering different modes ofSMR construction, it identifies potential legal gaps orlimitations that may affect the IAEA’s ability toconduct rigorous design verification. It concludes bycommenting on the general steps to address any suchgaps, including legal and policy measures anddirections for future technical work.