Iran’s Nuclear Program: Status

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Iran’s Nuclear Program: Status

Paul K. Kerr

Analyst in Nonproliferation

Updated December 20, 2019

Congressional Research Service

7-....

www.crs.gov

RL34544

Iran’s Nuclear Program: Status

Summary

Iran’s nuclear program began during the 1950s. The United States has expressed concern since

the mid-1970s that Tehran might develop nuclear weapons. Iran’s construction of gas centrifuge

uranium enrichment facilities is currently the main source of proliferation concern. Gas

centrifuges can produce both low-enriched uranium (LEU), which can be used in nuclear power

reactors, and weapons-grade highly enriched uranium (HEU), which is one of the two types of

fissile material used in nuclear weapons.

Is Iran Capable of Building Nuclear Weapons?

The United States has assessed that Tehran possesses the technological and industrial capacity to

produce nuclear weapons. But Iran has not yet mastered all of the necessary technologies for

building such weapons. Whether Iran has a viable design for a nuclear weapon is unclear. A

National Intelligence Estimate made public in 2007 assessed that Tehran “halted its nuclear

weapons program” in 2003. The estimate, however, also assessed that Tehran is “keeping open

the option to develop nuclear weapons” and that any decision to end a nuclear weapons program

is “inherently reversible.” U.S. intelligence officials have reaffirmed this judgment on several

occasions.

Obtaining fissile material is widely regarded as the most difficult task in building nuclear

weapons. As of January 2014, Iran had produced an amount of LEU containing up to 5%

uranium-235, which, if further enriched, could theoretically have produced enough HEU for as

many as eight nuclear weapons. Iran had also produced LEU containing nearly 20% uranium235; the total amount of this LEU, if it had been in the form of uranium hexafluoride and further

enriched, would have been sufficient for a nuclear weapon.. After the Joint Plan of Action, which

Tehran concluded with China, France, Germany, Russia, the United Kingdom, and the United

States (collectively known as the “P5+1”), went into effect in January 2014, Iran either converted

much of its LEU containing nearly 20% uranium-235 for use as fuel in a research reactor located

in Tehran, or prepared it for that purpose. Iran has diluted the rest of that stockpile so that it

contained no more than 5% uranium-235. In addition, Tehran has implemented various

restrictions on, and provided the IAEA with additional information about, its nuclear program

pursuant to the July 2015 Joint Comprehensive Plan of Action (JCPOA), which Tehran concluded

with the P5+1.

Although Iran claims that its nuclear program is exclusively for peaceful purposes, the program

has generated considerable concern that Tehran is pursuing a nuclear weapons program. The U.N.

Security Council responded to Iran’s refusal to suspend work on its uranium enrichment program

by adopting several resolutions that imposed sanctions on Tehran. Despite evidence that sanctions

and other forms of pressure have slowed the program, Iran continued to enrich uranium, install

additional centrifuges, and conduct research on new types of centrifuges. Tehran has also worked

on a heavy-water reactor, which was a proliferation concern because its spent fuel would have

contained plutonium—the other type of fissile material used in nuclear weapons. However,

plutonium must be separated from spent fuel—a procedure called “reprocessing.” Iran has said

that it will not engage in reprocessing.

Who Is Monitoring Iran’s Nuclear Program?

The International Atomic Energy Agency (IAEA) monitors Iran’s nuclear facilities and has

verified that Tehran’s declared nuclear facilities and materials have not been diverted for military

purposes. The agency has also verified that Iran’s compliance with the JCPOA. On the JCPOA’s

Implementation Day, which took place on January 16, 2016, all of the previous Security Council

resolutions’ requirements were terminated. The nuclear Nonproliferation Treaty (NPT) and U.N.

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Security Council Resolution 2231, which the council adopted on July 20, 2015, compose the

current legal framework governing Iran’s nuclear program. Iran has continued to comply with the

JCPOA and Resolution 2231. Iran and the IAEA agreed in 2007 on a work plan to clarify

outstanding questions regarding Tehran’s nuclear program, most of which concerned possible

Iranian procurement activities and research directly applicable to nuclear weapons development.

A December 2015 report to the IAEA Board of Governors from then-agency Director-General

Yukiya Amano contains the IAEA’s “final assessment on the resolution” of these outstanding

issues.

How Soon Could Iran Produce a Nuclear Weapon?

Then-Under Secretary of State for Political Affairs Wendy Sherman explained during an October

2013 hearing of the Senate Committee on Foreign Relations that Iran would need as much as one

year to produce a nuclear weapon if the government decided to do so. At the time, Tehran would

have needed two to three months to produce enough weapons-grade HEU for a nuclear weapon.

Iran’s compliance with the JCPOA increased that time frame to one year, according to U.S.

officials. These estimates apparently assume that Iran would use its declared nuclear facilities to

produce fissile material for a weapon. However, Tehran would probably use covert facilities for

this purpose; Iranian efforts to produce fissile material for nuclear weapons by using its known

nuclear facilities would almost certainly be detected by the IAEA.

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Contents

Background ..................................................................................................................................... 1

Proliferation Concerns .............................................................................................................. 1

Scope and Purpose of Iran’s Nuclear Program ......................................................................... 3

Recent Nuclear Controversy............................................................................................................ 6

Iran’s Cooperation with the IAEA ........................................................................................... 11

Possible Military Dimensions ............................................................................................ 11

Other IAEA Cooperation Issues........................................................................................ 14

Status of Iran’s Nuclear Facilities ................................................................................................. 17

Uranium Enrichment Facilities ............................................................................................... 18

Natanz Commercial Facility ............................................................................................. 19

Natanz Pilot Facility ......................................................................................................... 20

Fordow Enrichment Facility ............................................................................................. 22

Enriched Uranium Containing Nearly 20% Uranium-235................................................ 24

Future Centrifuge Facilities .............................................................................................. 25

Inconsistent Progress ........................................................................................................ 26

Uranium Conversion ............................................................................................................... 27

Plutonium ................................................................................................................................ 28

Arak Reactor and Redesign .............................................................................................. 29

Bushehr Reactor ................................................................................................................ 31

Possible Future Reactors ................................................................................................... 32

Fuel Manufacturing Facilities ................................................................................................. 33

Uranium Mines and Mills ....................................................................................................... 33

Effects of Sanctions and Sabotage on Iran’s Enrichment Program ............................................... 33

Sanctions ................................................................................................................................. 33

Sabotage .................................................................................................................................. 35

Nuclear Weapon Development Capabilities .................................................................................. 36

Timelines ................................................................................................................................. 40

Declared Versus Undeclared Nuclear Facilities ................................................................ 42

Does Iran Have a Nuclear Weapons Program? .............................................................................. 43

Government Estimates ............................................................................................................ 46

Living with Risk...................................................................................................................... 49

Other Constraints on Nuclear Weapons Ambitions ................................................................. 50

Appendixes

Appendix A. Iranian Statements on Nuclear Weapons .................................................................. 52

Appendix B. Organization of Iran’s Nuclear Program .................................................................. 54

Appendix C. Multilateral Diplomacy Concerning Iran’s Nuclear Program .................................. 58

Appendix D. Trump Administration Joint Cooperative Plan of Action Policy ............................. 71

Appendix E. Possible Military Dimensions of Iran’s Nuclear Program ....................................... 75

Appendix F. Iranian Centrifuge Workshops and Related Entities ................................................. 78

Appendix G. Post-2003 Suppliers to Iran’s Uranium Enrichment Program ................................. 82

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Contacts

Author Contact Information .......................................................................................................... 85

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Background

Iran’s nuclear program began during the 1950s. Construction of a U.S.-supplied research reactor,

called the Tehran Research Reactor (TRR), located in Tehran began in 1960; the reactor went

critical in 1967.1 During the 1970s, Tehran pursued an ambitious nuclear power program.

According to contemporaneous U.S. documents, Iran wanted to construct 10-20 nuclear power

reactors and produce more than 20,000 megawatts of nuclear power by 1994.2 Iran also began

constructing a light-water nuclear power reactor near the city of Bushehr, and it considered

obtaining uranium enrichment and reprocessing technology.

Proliferation Concerns

Iran took steps to demonstrate that it was not pursuing nuclear weapons. For example, Tehran

signed the nuclear Nonproliferation Treaty (NPT) in 1968 and ratified it in 1970. Iran also

submitted a draft resolution to the U.N. General Assembly in 1974 that called for establishing a

nuclear-weapons-free zone in the Middle East. Nevertheless, mid-1970s U.S. intelligence reports

expressed concern that Iran might pursue a nuclear weapons program.3 Although Iran cancelled

its nuclear program after its 1979 revolution, a 1981 Department of State draft paper argued that

Iran might develop a nuclear weapons program in response to a then-suspected Iraqi nuclear

weapons program, although Iran was not one of several countries of “near to medium term

proliferation concern” cited in the paper.4

Tehran “reinstituted” its nuclear program in 1982.5 According to International Atomic Energy

Agency (IAEA) reports, Iran conducted experiments during the 1980s and early 1990s related to

uranium conversion, heavy-water production, and nuclear reactor fuel fabrication. A 1985

National Intelligence Council report, which cited Iran as a potential “proliferation threat,” stated

1 The United States and Iran signed a nuclear cooperation agreement in 1957; it entered into force in 1959. The two

countries negotiated another such agreement during the 1970s, but it was never concluded. For a summary of these

negotiations, see William Burr, “A Brief History of U.S.-Iranian Nuclear Negotiations,” Bulletin of the Atomic

Scientists, January/February 2009.

2 The United States was willing to supply Iran with reprocessing technology, according to 1975 and 1976 National

Security Council documents. Tehran also had a 1976 contract for a pilot uranium-enrichment facility using lasers (see

Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions 1737

(2006) and 1747 (2007) in the Islamic Republic of Iran, Report by the Director General, GOV 2007/58, November 15,

2007. In addition, according to a 1976 State Department cable, Iran engaged in uranium exploration in Iran and other

countries, planned to reprocess spent reactor fuel in the future, and had contemplated building its own enrichment

facility (U.S. Embassy Tehran Airgram A-76 to State Department, “The Atomic Energy Organization of Iran,” April

15, 1976).

3 Prospects for Further Proliferation of Nuclear Weapons, Special National Intelligence Estimate, August 23, 1974. A

1975 Department of State memorandum referred to the “uncertainty over” Iran’s “long-term objectives despite its NPT

status” (“Memorandum for the Assistant to the President for National Security Affairs: Department of State Response

to NSSM 219 [Nuclear Cooperation with Iran],” April 18, 1975). A 1975 CIA report identified Iran as one state with

the “potential … to cross the explosives threshold within the next ten years.” (Managing Nuclear Proliferation: The

Politics of Limited Choice, Research Study, CIA, December 1975.) A 1988 CIA report (Middle East-South Asia:

Nuclear Handbook) indicated that Iran had conducted nuclear weapons “design work” before the 1979 revolution.

4 “Request for Review of Draft Paper on the Security Dimension of Non-Proliferation,” Special Assistant for Nuclear

Proliferation Intelligence, National Foreign Assessment Center, Central Intelligence Agency, to Resource Management

Staff, Office of Program Assessment et al., April 9, 1981. Iraq pursued nuclear, chemical, and biological weapons

during the 1980s. The paper argued that Iraq’s nuclear program was “intended to provide the option of developing

nuclear explosives in the future.”

5 Middle East-South Asia: Nuclear Handbook, CIA, May 1988.

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that Tehran was “interested in developing facilities that ... could eventually produce fissile

material that could be used in a [nuclear] weapon.” The report, however, added that it “would

take at least a decade” for Iran to do so.6 A 1986 CIA report went further, citing “the advantage of

long-range missiles to deliver warheads quickly, virtually without warning, and-unlike aircraftwithout facing any defense” as a “factor” that would incentivize Iranian development of nuclear

weapons “in the late 1990s.”7 A 1995 U.S. intelligence report stated that Iran was “aggressively

pursuing a nuclear weapons capability and, if significant foreign assistance were provided, could

produce a weapon by the end of the decade.”8 Somewhat less urgently, an Arms Control and

Disarmament Agency report covering 1995 observed that “Iran's rudimentary program has

apparently met with limited success so far, [but] we believe Iran has not abandoned its efforts to

expand its nuclear capabilities with a view to supporting nuclear weapons development.”9

In 1996 congressional testimony, then-Director of Central Intelligence John Deutch described

Iranian efforts to acquire from the former Soviet Union fissile material for a nuclear weapon:

In an attempt to shorten the timeline to a weapon, Iran has launched a parallel effort to

purchase fissile material, mainly from sources in the former Soviet Union.

Iranian agents have contacted officials at nuclear facilities in Kazakhstan on several

occasions, attempting to acquire nuclear-related materials. For example, in 1992, Iran

unsuccessfully approached the Ulba Metallurgical Plant to obtain enriched uranium.

In 1993, three Iranians believed to have had connections to Iran’s intelligence service

were arrested in Turkey while seeking to acquire nuclear material from smugglers from

the former Soviet Union.10

More recently, the Iranian government has said that it plans to expand its reliance on nuclear

power to generate electricity. This program will, Tehran says, reduce Iran’s oil and gas

consumption and allow the country to export additional fossil fuels; the previous Iranian regime

also made this argument.11 Iran has begun to operate the Bushehr reactor, and Tehran says it

intends to build additional reactors to generate 20,000 megawatts of power within the next 20

years.12 The 2015 Joint Comprehensive Plan of Action (JCPOA) requires Iran to refrain from

6 The Dynamics of Nuclear Proliferation: Balance of Power and Constraints, National Intelligence Council, September

1985. A 1985 CIA report articulated a more sanguine view, observing that “there is no evidence that Iran is resuming

nuclear research to develop nuclear weapons.” (“Overview of Iran's Renewed Efforts for Nuclear Development,”

Central Intelligence Agency Directorate of Intelligence, August 5, 1985).

7 Iran-Iraq: Ballistic Missile Warfare and Its Regional Implications, An Intelligence Assessment, Central Intelligence

Agency Directorate of Intelligence, March 1986.

8 The Weapons Proliferation Threat, Nonproliferation Center, March 1995.

9 A 1994 report from the same agency contains identical language. (U.S. Arms Control and Disarmament Agency,

Threat Control through Arms Control, Report to Congress, 1994.) A 1992 Arms Control and Disarmament Agency

report refers to “Iran's efforts to acquire from other countries nuclear weapons technology.” (U.S. Arms Control and

Disarmament Agency, Adherence to And Compliance with Agreements, June 24, 1992.)

10 Statement for the Record by John Deutch, Director of Central Intelligence, to the Permanent Subcommittee on

Investigations of the Senate Committee on Government Affairs, March 20, 1996.

11 For example, according to a 1976 State Department cable, the President of the Atomic Energy Organization of Iran

cited these arguments as reasons for starting an ambitious nuclear program (U.S. Embassy Tehran Airgram A-76 to

State Department, 1976). Ambassador Ali Asghar Soltanieh, then Iran’s Permanent Representative to the International

Atomic Energy Agency, has explained that nuclear power would only meet “perhaps a small portion” of the projected

national electricity demand (“Interview with Iran’s Ambassador to IAEA,” Campaign Against Sanctions and Military

Intervention in Iran, June 29, 2008; published July 2, 2008).

12 “Iran to Follow Nuclear Timetable Regardless of IAEA Reports—Official,” Islamic Republic of Iran News Network,

February 25, 2009. A spokesperson for the Atomic Energy Organization of Iran stated on January 11, 2016, that the

country “needs to generate 20,000 megawatts of nuclear electricity” and should produce 12,000 megawatts of nuclear

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building heavy-water-moderated reactors for 15 years. Pursuant to the agreement, Iran has

pledged to refrain from constructing any such reactors indefinitely. Iranian officials say that

Tehran has begun design work on its first indigenously produced light-water reactor, to be

constructed at Darkhovin. According to official U.S. and Iranian sources, France agreed to

construct the reactor during the 1970s but ended the project after the 1979 revolution in Iran.13

Atomic Energy Organization of Iran (AEOI) President Ali Akbar Salehi stated in September 2016

that “we are almost about to sign a contract for designing” the reactor, “but it will take a rather

long time.”14

Scope and Purpose of Iran’s Nuclear Program

Iranian officials have repeatedly asserted that the country’s nuclear program is exclusively for

peaceful purposes (see Appendix A). Nevertheless, prior to the JCPOA, the United States and

other governments argued that Iran may be pursuing, at a minimum, the capability to produce

nuclear weapons. Discerning a peaceful nuclear program from a nuclear weapons program can be

difficult because much nuclear technology is dual-use. In addition, a military nuclear program

may coexist with a civilian program, even without an explicit governmental decision to produce

nuclear weapons. Jose Goldemberg, Brazil’s former secretary of state for science and technology,

observed that a country developing the capability to produce nuclear fuel

does not have to make an explicit early [political] decision to acquire nuclear weapons. In

some countries, such a path is supported equally by those who genuinely want to explore

an energy alternative and by government officials who either want nuclear weapons or just

want to keep the option open. 15

Some analysts argue that several past nuclear programs, such as those of France, Sweden, and

Switzerland, illustrate this approach.16 A Swedish official involved in that country’s nuclear

weapons program “argued that the main aim should be the generation of nuclear energy, with

plutonium production, which would make possible the manufacture of nuclear weapons as a sideeffect.”17

The main source of proliferation concern generated by Iran’s nuclear program has been Tehran’s

construction of gas centrifuge uranium-enrichment facilities. Gas centrifuges enrich uranium by

spinning uranium hexafluoride gas at high speeds to increase the concentration of the uranium235 isotope. Such centrifuges can produce both low-enriched uranium (LEU), which can be used

electricity by 2025 (Sara Ma’sumi, Interview with Behruz Kamalvandi, “Less Than Seven Day to the Implementation

of the JCPOA [Joint Comprehensive Plan of Action],” E’temad, January 11, 2016).

13 “Iran Asks France to Remain Committed to N. Power Plant Construction Deal,” FARS News Agency, October 28,

2014. Director of Central Intelligence, Joint Atomic Energy Intelligence Committee, Iran’s Nuclear Program: Building

a Weapons Capability, February 1993. France completed 5% of the project, according to former President of Iran’s

Atomic Energy Organization Reza Amrollahi (“If We Want Nuclear Energy, We Should Not Make a Fuss,” Sharq,

September 7, 2013).

14 “Iran to Build More Power Plants—Nuclear Chief,” IRTV2, September 10, 2016.

15 Jose Goldemberg, “Looking Back: Lessons From the Denuclearization of Brazil and Argentina,” Arms Control

Today, April 2006.

16 See James Acton, “The Problem with Nuclear Mind Reading,” Survival, February-March 2009, pp. 119-142; Paul M.

Cole, “Atomic Bombast: Nuclear Weapon Decision-making in Sweden 1945-1972,” The Henry L. Stimson Center,

1996; “Neutral States: Sweden and Switzerland,” in T.V. Paul, Power Vs. Prudence: Why Nations Forgo Nuclear

Weapons (Montreal: McGill University Press), 2000, pp. 84-98; and Bruno Tertrais, “Has Iran Decided to Build the

Bomb? Lessons from the French Experience,” January 30, 2007.

17 Thomas Jonter, “The Swedish Plans to Acquire Nuclear Weapons, 1945-1968: An Analysis of the Technical

Preparations,” Science & Global Security, 18:61-86, 2010.

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in nuclear power reactors, and highly enriched uranium (HEU), which is one of the two types of

fissile material used in nuclear weapons. HEU can also be used as fuel in certain types of nuclear

reactors.18 Iran also has a uranium-conversion facility, which converts uranium ore concentrate

into several compounds, including uranium hexafluoride.19 This program is currently constrained

by the JCPOA. German Minister of State Niels Annen argued in a February 19, 2019, speech that

the JCPOA “effectively prevents Iran from acquiring a nuclear weapon for as long as the

agreement stands.”20

However, following the May 8, 2018, U.S. announcement that the United States would no longer

participate in the JCPOA and would reimpose sanctions that had been suspended pursuant to the

agreement, Iranian President Hassan Rouhani ordered the AEOI to “go ahead with adequate

preparations to resume enrichment at the industrial level without any limit.”21 A year later,

Rouhani announced additional Iranian responses. (see Appendix C, “Multilateral Diplomacy

Concerning Iran’s Nuclear Program”).

Iran claims that it wants to produce LEU fuel for its planned light-water nuclear power reactors,

as well as the Tehran Research Reactor (TRR) and other planned future research reactors. The

latter reactors will be used to produce isotopes for medical purposes, according to Tehran.

Although Iran has expressed interest in purchasing nuclear fuel from other countries, the

government asserts that the country should have an indigenous enrichment capability as a hedge

against possible fuel supply disruptions.22 President Rouhani ordered AEOI President Salehi on

December 13, 2016, to provide a plan “for designing and manufacturing nuclear-propulsion

system to be used in maritime transportation,” as well as producing fuel for such a system.23

However, Iranian officials have indicated that Tehran would not produce enriched uranium

exceeding JCPOA-established enrichment limits.24 In a January 2018 letter, Iran informed the

IAEA of the government’s “decision … to construct naval nuclear propulsion in future.”25 Tehran

explained in an April 2018 letter to the agency that “[f]or the first five years, no [nuclear] facility

will be involved” and the “[n]uclear fuelled engines/reactors will be used for civilian purpose.”26

Salehi stated in early February 2019 that at the project will take “at least 15 years” to complete.27

18 Highly enriched uranium used in nuclear weapons typically contains about 90% uranium-235, whereas low-enriched

uranium used in nuclear reactors typically contains less than 5% uranium-235.

19 For a detailed description of the nuclear fuel cycle, see CRS Report RL34234, Managing the Nuclear Fuel Cycle:

Policy Implications of Expanding Global Access to Nuclear Power, coordinated by Mary Beth D. Nikitin.

20 “Opening Remarks by Minister of State Niels Annen at the SWP Conference on U.S. Foreign Policy under the

Trump Administration,” February 19, 2019.

21 “Iran Accepts Remaining in JCPOA Under Condition,” Islamic Republic News Agency, May 9, 2018.

22 What Are Iran’s “Practical Needs” and Why Does Iran Want to Fuel Reactors on Its Own?, nuclearenergy.ir, July

2014. “Soltaniyeh: Iran Has No Alternative but to Enrich Uranium,” Islamic Republic News Agency, October 2, 2008;

“Interview with Iran’s Ambassador to IAEA,” 2008.

23 “Following U.S Delay, Negligence and Violation of JCPOA; President Orders FM, AEOI Head to Implement Legal

Procedures, Produce Nuclear Fuel, Propulsion System,” December 13, 2016. Available at http://president.ir/en/96776.

24 “Iran Nuclear Propulsion Bids to ‘Heed’ 2015 Deal,” Tasnim News Agency Website, December 26, 2016; “Salehi

Discusses Nuclear Propulsion Systems, Content of Rouhani’s Order with Amano”, Islamic Republic News Agency,

December 21, 2016; “AEOI Official: Russia, China Willing to Build Small N. Reactors in Iran,” FARS News Agency,

January 23, 2018.

25 Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution

2231 (2015), Report by the Director General, International Atomic Energy Agency, GOV/2018/7, February 22, 2018.

26 Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution

2231 (2015), Report by the Director General, International Atomic Energy Agency, GOV/2018/24, May 24, 2018.

27 “Iran Vows to Expand Nuclear Industry,” FARS News Agency, February 1, 2019.

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A reactor moderated by heavy water, which Iran was constructing at Arak, has also been a source

of concern. Although Tehran says that the reactor is intended for the production of radioisotopes

for medical purposes, the reactor previously under construction was a proliferation concern

because its spent fuel would have contained plutonium well-suited for use in nuclear weapons.

Spent nuclear fuel from nuclear reactors contains plutonium, the other type of fissile material

used in nuclear weapons. In order to be used in nuclear weapons, however, plutonium must be

separated from the spent fuel—a procedure called “reprocessing.” Iran has said that it will not

engage in reprocessing. This reactor is designed to use natural uranium fuel, which does not

require enrichment. Iran has rendered the Arak reactor’s original core inoperable pursuant to the

JCPOA, which also commits Tehran to redesign and rebuild the reactor based on a design agreed

to by the P5+1.

In addition to the dual-use nature of the nuclear programs described above, Iran’s inconsistent

cooperation with the IAEA contributed to suspicions that Tehran had a nuclear weapons

program.28 In the past, Iran has taken actions that interfered with the agency’s investigation of its

nuclear program, including concealing nuclear activities and providing misleading statements.

Then-IAEA Director-General Mohamed ElBaradei explained in a 2008 interview that Iran’s

cooperation lagged behind IAEA demands:

[T]hey [the Iranians] have concealed things from us in the past, but that doesn’t prove that

they are building a bomb today. They continue to insist that they are interested solely in

using nuclear power for civilian purposes. We have yet to find a smoking gun that would

prove them wrong. But there are suspicious circumstances and unsettling questions. The

Iranians’ willingness to cooperate leaves a lot to be desired. Iran must do more to provide

us with access to certain individuals and documents. It must make a stronger contribution

to clarifying the last unanswered set of questions—those relating to a possible military

dimension of the Iranian nuclear program. 29

Consistent with ElBaradei’s statement, then-IAEA Director-General Yukiya Amano explained in

a 2012 interview that the IAEA did not claim that “Iran [has] made a decision to obtain nuclear

weapons.”30 Notably, Tehran has implemented various restrictions on, and provided the IAEA

with additional information about, its uranium enrichment program and heavy-water reactor

program pursuant to the JCPOA.

Iran and the IAEA agreed in August 2007 on a work plan to clarify the outstanding questions

regarding Tehran’s nuclear program, most of which concerned possible Iranian procurement

activities and research directly applicable to nuclear weapons development. A December 2015

report to the IAEA Board of Governors from Amano contains the IAEA’s “final assessment on

the resolution” of these outstanding issues.31

Iran also has extensive programs to develop ballistic missiles and cruise missiles. (For more

details on Iran’s ballistic missile program, see CRS Report R42849, Iran’s Ballistic Missile and

Space Launch Programs, by Steven A. Hildreth.)

28 For a detailed description of Iran’s compliance with its international obligations, see CRS Report R40094, Iran’s

Nuclear Program: Tehran’s Compliance with International Obligations, by Paul K. Kerr.

29 “Interview with IAEA Boss Mohamed ElBaradei,” Der Spiegel, June 11, 2008.

30 Jay Solomon and David Crawford, “An Interview With IAEA’s Yukiya Amano,” Wall Street Journal, June 9, 2012.

31 Final Assessment on Past and Present Outstanding Issues Regarding Iran’s Nuclear Programme, GOV/2015/68,

December 2, 2015.

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Recent Nuclear Controversy

The public controversy over Iran’s nuclear program began in August 2002, when the National

Council of Resistance on Iran (NCRI), an Iranian exile group, revealed information during a press

conference (some of which later proved to be accurate) that Iran had built nuclear-related

facilities at Natanz and Arak that it had not revealed to the IAEA. The United States had been

aware of at least some of these activities, according to knowledgeable former officials.32 During

the mid-1990s, Israel’s intelligence services detected Iranian “efforts to develop a military nuclear

industry,” according to a 2004 Israeli Knesset committee report.33

Iran ratified the nuclear Nonproliferation Treaty (NPT) in 1970. States-parties to the treaty are

obligated to conclude a comprehensive safeguards agreement with the IAEA; Tehran concluded

such an agreement in 1974. In the case of nonnuclear-weapon states-parties to the treaty (of

which Iran is one), such agreements are designed to enable the IAEA to detect the diversion of

nuclear material from peaceful purposes to nuclear weapons uses, as well as to detect undeclared

nuclear activities and material. As a practical matter, however, the IAEA’s ability to inspect and

monitor nuclear facilities, as well as obtain relevant information, pursuant to a comprehensive

safeguards agreements is limited to facilities that have been declared by the government.34

Additional Protocols (see text box below) to IAEA safeguards agreements increase the agency’s

authority to inspect certain facilities and demand additional information from states-parties,

thereby augmenting the agency’s ability to investigate clandestine nuclear facilities and

activities.35 The IAEA’s statute requires the agency’s Board of Governors to refer cases of

noncompliance with safeguards agreements to the U.N. Security Council. Prior to the NCRI’s

revelations, the IAEA had expressed concerns that Iran had not been providing the agency with

all relevant information about its nuclear programs, but the IAEA had never found Iran in

violation of its safeguards agreement.

32 CRS analyst interview with knowledgeable former U.S. official, October 3, 2019. Gary Samore, Former Senior

Director for Nonproliferation and Export Controls on the National Security Council, personal communication June 5,

2008; Former Director of Central Intelligence George J. Tenet, “DCI Remarks on Iraq’s WMD Programs,” February 5,

2004. According to former Deputy Secretary of State William Burns, the U.S. intelligence community “began to track”

these sites in “late 2001.” (William J. Burns, The Back Channel: A Memoir of American Diplomacy and the Case for

Its Renewal [New York: Random House], 2019, p. 706.)

33 Report—Volume 1 (Unrestricted section), The Committee of Enquiry into the Intelligence System in Light of the

War in Iraq, The Knesset Foreign Affairs and Defence Committee, March 2004.

34 The IAEA does have other investigative tools, such as monitoring scientific publications from member-states. For

more information, see CRS Report R40094, Iran’s Nuclear Program: Tehran’s Compliance with International

Obligations, by Paul K. Kerr.

35 NPT states are not required to conclude Additional Protocols. However, applicable U.N. Security Council resolutions

require Iran to conclude such a protocol.

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Selected Provisions of the IAEA Model Additional Protocol

Additional protocols to comprehensive safeguards agreements increase the IAEA’s ability to investigate undeclared

nuclear facilities and activities in nonnuclear-weapon states by increasing the agency’s authority to inspect certain

nuclear-related facilities and demand information from member states.

Information

Article 2 of the Model Additional Protocol requires a state to provide the IAEA with information about a variety

of nuclear-related activities. The information most relevant to Iran’s enrichment and heavy water reactor

programs (the programs of greatest proliferation concern for the international community) would be a “general

description of and information specifying the location of nuclear fuel cycle-related research and development

activities not involving nuclear material.” These activities include those “specifically related to any process or

system development aspect” of uranium enrichment and spent fuel reprocessing. The Protocol also requires the

state to “make every reasonable effort to provide” the IAEA with a “general description of and information

specifying the location of nuclear fuel cycle-related research and development activities not involving nuclear

material which are specifically related to enrichment.”

The Protocol also requires the state to provide a “description of the scale of operations for each location engaged

in the activities specified in Annex I” to the Protocol. This Annex covers a variety of activities related to

enrichment, reprocessing, and nuclear reactors.

Locations

Depending on the type of facility, the IAEA may request access to a location in order to “assure the absence of

undeclared nuclear material and activities” in the facility or to “resolve a question relating to the correctness and

completeness” of Iran’s declaration pursuant to Article 2 of the Model Additional Protocol. The methods and

activities (e.g., environmental sampling, radiation detection) that IAEA inspectors may undertake when accessing

such a location vary depending on the facility’s type. In general, the Protocol would allow the IAEA access to the

following types of nuclear locations:

Uranium mines, uranium mills, and uranium ore processing facilities located at the mines.

Locations around and including facilities with nuclear material that Iran has declared under its

safeguards agreement. In Iran, these would include entire facilities where declared nuclear material

is located; such facilities are normally within a perimeter boundary, such as a security fence.

Locations of nuclear fuel cycle-related research and development activities not involving nuclear

material.

Locations engaged in activities specified in Annex I of the Model Additional Protocol. These

activities include the manufacture of some components related to enrichment, reprocessing, and

nuclear reactors.

In fall 2002, the IAEA began to investigate Iran’s nuclear activities at Natanz and Arak;

inspectors visited the sites the following February. During a June 2003 meeting, the IAEA board

first expressed “concern” about Iran’s past undeclared nuclear activities and urged Tehran to

cooperate with the agency’s investigation. The IAEA board’s first resolution, which was adopted

during a September 2003 meeting, called on Tehran to increase its cooperation with the agency’s

investigation and to suspend its uranium enrichment activities. (For more detail about Iran’s

nuclear organization, see Appendix B).

President Rouhani identified the Atomic Energy Organization of Iran (AEOI) as “the authority

that was,” prior to the June 2003 IAEA board meeting, “basically handling all political and

technical issues concerning” the agency’s investigation of Iran’s nuclear program.36 Following

that meeting, Iran’s Supreme National Security Council created the Supreme Nuclear Committee,

which was composed of officials from various agencies, including the AEOI and the ministries of

36 “Beyond the Challenges Facing Iran and the IAEA Concerning the Nuclear Dossier,” Rahbord, September 30, 2005,

pp. 7-38.

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defense, foreign affairs, and intelligence.37 After the IAEA board adopted its September 2003

resolution, the government placed Rouhani, who was the head of the Supreme National Security

Council at the time, in charge of the negotiations concerning Iran’s nuclear program. Rouhani

explained the resulting nuclear decisionmaking process in 2011:

Even though some people thought the nuclear team was operating with complete

prerogatives, the facts were otherwise. The work procedure for every issue was that we

first had to discuss the matter in the Supreme Nuclear Committee, then we took that result

to the Meeting of Leaders, and finally we acted in accordance with the decision of the

leaders.38

In October 2003, Iran concluded an agreement with France, Germany, and the United Kingdom,

collectively known as the “E3,” to suspend its enrichment activities, sign and implement an

Additional Protocol to its IAEA safeguards agreement, and comply fully with the IAEA’s

investigation.39 As a result, the IAEA board decided to refrain from referring the matter to the

U.N. Security Council, despite U.S. advocacy for such a referral.40 Statements from current and

former Iranian officials indicate that, during fall 2003, Tehran feared that the United States might

use Security Council referral as a means to undertake military action or other coercive measures

against Iran.41 Rouhani argued in February 2005 that the United States would not take such action

as long as Iran was cooperating with the IAEA and negotiating with the E3.42

After October 2003, Iran continued some of its enrichment-related activities, but Tehran and the

E3 agreed in November 2004 to a more detailed suspension agreement. During negotiations

between fall 2003 and summer 2005, both Iran and the E3 offered a number of proposals,

although the two sides never reached agreement.43 The IAEA’s investigation, as well as

information Tehran provided after the October 2003 agreement, ultimately revealed that Iran had

engaged in a variety of clandestine nuclear-related activities, some of which violated Iran’s

safeguards agreement. These activities included plutonium separation experiments, uranium

enrichment and conversion experiments, and importing various uranium compounds.

Current and former Iranian officials have depicted a government deeply divided during this time

over diplomatic approaches regarding its nuclear program. For example, Seyed Hossein

Mousavian, who was Iran’s spokesperson during the government’s 2003-2005 negotiations with

France, Germany, and the United Kingdom, explained that in 2003 “there were two schools of

37 Dr. Hasan Rouhani, National Security and Nuclear Diplomacy (Tehran: Center for Strategic Research), 2011, pp. 24-

28. The Supreme Council on New Technologies, which Iran formed in 1998 to focus on the nuclear program, “rarely

met” after the June 2003 IAEA board meeting, according to Rouhani.

38 Rouhani 2011, p. 245.

39 The text of the agreement is available at http://www.iaea.org/NewsCenter/Focus/IaeaIran/

statement_iran21102003.shtml. Iran signed its Additional Protocol in December 2003, but has not ratified it.

40“Ex-chief Negotiator Says Iran Leaders Decided to Suspend Nuclear Enrichment,” Aftab-e Yazd, April 7, 2009; John

Bolton, Surrender Is Not an Option: Defending America at the United Nations and Abroad (New York: Threshold

Editions), 2008, p. 139; Christopher Ford, “A New Paradigm: Shattering Obsolete Thinking on Arms Control and

Nonproliferation,” Arms Control Today, November 2008. For more details about noncompliance with IAEA safeguards

agreements and Security Council referral, see CRS Report R40094, Iran’s Nuclear Program: Tehran’s Compliance

with International Obligations, by Paul K. Kerr.

41 Aftab-e Yazd, April 7, 2009; Keyhan, July 23, 2005; David Patrikarakos, Nuclear Iran: The Birth of an Atomic State

(New York: I.B. Tauris), 2012, p. 181; Seyed Hossein Mousavian, The Iranian Nuclear Crisis: A Memoir (Washington,

DC: Carnegie Endowment for International Peace), 2012, p. 76.

42 “Iranian Official Rowhani Gives Interview, Discusses Talks With EU, Criticizes U.S.,” Tehran Vision of the Islamic

Republic of Iran Network 2, February 7, 2005.

43 These proposals are available at http://www.armscontrol.org/factsheets/Iran_Nuclear_Proposals.

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thought in Iran. One group advocated engagement with the West, while others were proponents of

resistance.”44 President Rouhani, who headed the 2003-2005 negotiations, explained during a July

2005 interview that certain parts of the Iranian government opposed the diplomatic track, adding

that “[t]he problems included both disharmony and sabotage.”45 Indeed, Rouhani later argued that

Iran’s Supreme National Security Council took charge of the diplomacy concerning the nuclear

program because

the Foreign Ministry was not able to be responsible for this task in a good way because

some organizations did not pay sufficient attention to this ministry’s decisions, especially

since there had been disagreements for months between the Foreign Ministry and the

Atomic Energy Organization.46

In a 2005 article, an Iranian Foreign Ministry official explained that the decision to delegate

responsibility for the nuclear issue to the Supreme National Security Council was

aimed at creating domestic consensus and preventing any possible discrepancies in the

decision making process and its implementation at the national level. It was demonstrated

in practice that this decision was crucial in preventing the friction between the government,

parliament and all other relevant agencies.47

Iran resumed uranium conversion in August 2005 under the leadership of then-President

Ahmadinejad, who had been elected two months earlier. On September 24, 2005, the IAEA Board

of Governors adopted a resolution that, for the first time, found Iran to be in noncompliance with

its IAEA safeguards agreement. The board, however, did not refer Iran to the Security Council,

choosing instead to give Tehran additional time to comply with the board’s demands. Iran

announced in January 2006 that it would resume research and development on its centrifuges at

Natanz. In response, the IAEA board adopted a resolution on February 4, 2006, that referred

Iran’s case to the Security Council. Two days later, Tehran announced that it would stop

implementing its Additional Protocol.

In March 2006, the U.N. Security Council President issued a statement, which was not legally

binding, that called on Iran to “take the steps required” by the February IAEA board resolution.

The council subsequently adopted six resolutions concerning Iran’s nuclear program: 1696 (July

2006), 1737 (December 2006), 1747 (March 2007), 1803 (March 2008), 1835 (September 2008),

and 1929 (June 2010). The second, third, fourth, and sixth resolutions imposed a variety of

restrictions on Iran. In addition, these resolutions required Tehran to cooperate fully with an

ongoing IAEA investigation of its nuclear activities, suspend its uranium enrichment program,

suspend its construction of a heavy-water reactor and related projects, and ratify the Additional

Protocol to Iran’s IAEA safeguards agreement. Resolution 1929 also required the government to

refrain from “any activity related to ballistic missiles capable of delivering nuclear weapons” and

to comply with a modified provision (called code 3.1) of Iran’s subsidiary arrangement to its

IAEA safeguards agreement. Beginning in June 2006, Iran held multiple rounds of talks with

China, France, Germany, Russia, the United Kingdom, and the United States, collectively known

44 Ali Vaez, “Seyed Hossein Mousavian: The West is Pushing Iran in the Wrong Direction,” Bulletin of the Atomic

Scientists, November 18, 2011.

45 Mehdi Mohammadi,“Nuclear Case From Beginning to End in Interview with Dr. Hasan Rowhani (Part 1): We Are

Testing Europe,” Keyhan, July 23, 2005

46 Rouhani 2011, p. 71.

47 Hamid Baeidi-Nejad, “Khatami’s Nuclear Policy,” Iranian Journal of International Affairs, vol. 18, No. 1 (Spring

2005), p. 61. An Iranian Foreign Ministry official with the same name was a participant in Iran’s negotiations regarding

its nuclear program.

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as the “P5+1,” concerning various proposals for resolving the nuclear dispute. Saeed Jalili, thenhead of Iran’s Supreme National Security Council, conducted Iran’s nuclear negotiations.

Following his June 2013 election, Iranian President Rouhani delegated the “nuclear negotiations

portfolio” to the Foreign Ministry, he explained in a September 2013 interview.48 The AEOI

continued to be responsible for Tehran’s negotiations with the IAEA and Supreme Leader

Ayatollah Ali Khamene’i was the ultimate decisionmaker regarding Iran’s diplomacy concerning

the Joint Comprehensive Plan of Action. Then-Under Secretary of State for Political Affairs

Wendy Sherman explained during a December 2013 hearing that Khamene’i “is the only one who

really holds the nuclear file—makes the final decisions about whether Iran will reach a

comprehensive agreement to forego much of what it has created in return for the economic relief

it seeks.”

The Supreme Leader remained in charge of decisions regarding the nuclear program following

Rouhani’s 2013 election. Deputy Foreign Minister Seyed Abbas Araqchi explained in July 2016

that the nuclear issue was “under the senior management” of Khamene’i, adding that

With regards the major foreign policy issues the more the decision making progresses and

enters important levels the higher the level of engagement; it moves up from the ministry

to the administration level and from the administration to the level of Supreme National

Security Council and at the end to the supreme leader.49

Iran and the P5+1 met three times before concluding an agreement called the Joint Plan of Action

(JPA) on November 24, 2013. This agreement placed certain limitations on Iran’s nuclear

program and established an approach toward reaching a long-term comprehensive solution to

international concerns regarding Iran’s nuclear program. The two sides began implementing the

JPA on January 20, 2014. The P5+1 and Iran reached a framework of a Joint Comprehensive Plan

of Action (JCPOA) on April 2, 2015, and finalized the JCPOA on July 14, 2015. The parties

began implementing the JCPOA on January 16, 2016. On that day, all of the previous Security

Council resolutions’ requirements were terminated. The NPT and U.N. Security Council

Resolution 2231 compose the current legal framework governing Iran’s nuclear program.50

On May 8, 2018, President Donald Trump announced that the United States would no longer

participate in the JCPOA. The United States subsequently reimposed sanctions that had been

suspended pursuant to the agreement. Other P5+1 countries immediately reiterated their support

for the JCPOA and announced that they intend to fulfill their JCPOA commitments and protect

their companies from the effects of any U.S.-imposed sanctions. President Rouhani has pledged

to continue implementing the accord, provided Iran continues to receive the economic benefits of

the agreement. (For more information about multilateral diplomacy concerning Iran’s nuclear

program, including the JCPOA’s status, see Appendix C. For more information about the Trump

administration’s JCPOA policy, see Appendix D.)

48 “Iranian President Hassan Rouhani Speaks with NBC News’ Ann Curry in Tehran,” September 18, 2013. A Foreign

Ministry spokesperson told an Iranian news agency that the Supreme National Security Council would continue

coordinating the talks, but the foreign ministry would have the lead. (“FM: Iran Restructuring Team of Negotiators in

Upcoming N. Talks with World Powers,” FARS News Agency, September 9, 2013.)

49 “The Current Restrictions Have Nothing to do with the JCPOA,” Iran Newspaper, July 13, 2016.

50 “Joint Statement by EU High Representative Federica Mogherini and Iranian Foreign Minister Javad Zarif,” January

16, 2016.

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Iran’s Cooperation with the IAEA

As noted, the IAEA investigation of Iran’s nuclear program began in 2002. Iran and the IAEA

agreed in August 2007 on a work plan to clarify the outstanding questions regarding Tehran’s

nuclear program.51 Most of these issues,52 which had contributed to suspicions that Iran had been

pursuing a nuclear weapons program, were essentially resolved by June 2008. However, thenIAEA Director-General ElBaradei told the IAEA Board of Governors on June 2, 2008, that there

is “one remaining major [unresolved] issue,” which concerns questions regarding “possible

military dimensions to Iran’s nuclear programme.”

Possible Military Dimensions

Iran and the IAEA subsequently held a series of discussions regarding these issues. The agency

provided Iran with documents or, in some cases, descriptions of documents, which had been

provided to the IAEA by several governments. The documents indicated that Iranian entities may

have conducted studies related to nuclear weapons development. The subjects of these studies

included uranium conversion, missile reentry vehicles for delivering nuclear warheads, and

conventional explosives used in nuclear weapons. Iranian officials have claimed that the

documents are not authentic,53 but ElBaradei told the IAEA board on June 17, 2009, that there

was “enough in these alleged studies to create concern in the minds of our professional

inspectors.” Iranian officials acknowledged that some of the information in the documents is

accurate, but they argued that the activities described were exclusively for nonnuclear purposes.54

Tehran has provided some relevant information about these matters to the IAEA, but ElBaradei

reported in August 2009 that the government should “provide more substantive responses” to the

IAEA, as well as “the opportunity to have detailed discussions with a view to moving forward on

these issues, including granting the agency access to persons, information and locations identified

in the documents.”55

Then-IAEA Director-General Amano issued a report to the IAEA board in November 2011 stating

that Iran had not “engaged with the agency in any substantive way” on the alleged studies since

51 The text of the work plan is available at http://www.iaea.org/Publications/Documents/Infcircs/2007/infcirc711.pdf.

52 These issues included plutonium experiments, research and procurement efforts associated with two types of

centrifuges, operations of a uranium mine, and experiments with polonium-210, which (in conjunction with beryllium)

is used as a neutron initiator in certain types of nuclear weapons.

53 In a September 28, 2008, letter to the IAEA, Iran described some characteristics of the documents discussed above.

The letter stated that some of the information from the United States was shown to Iranian officials as PowerPoint

presentations. In addition, some of the documents are “in contradiction with typical standard Iranian documentation”

and lack “classification seals,” the letter said. See, Permanent Mission of the Islamic Republic of Iran, Explanatory

Comments by the Islamic Republic of Iran on the Report of the IAEA Director General to the September 2008 Board of

Governors (GOV/2008/38), September 28, 2008. INFCIRC/737. Iran also complained that the IAEA has not provided

Tehran with original versions of some documentation related to the alleged “military dimensions” of Iran’s nuclear

program. Several reports from ElBaradei have stated that the agency has not had permission to provide this

documentation from the governments that provided it. In his November 2009 report, ElBaradei again called on such

governments to authorize the IAEA to share additional information with Iran.

54 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions 1737

(2006), 1747 (2007) and 1803 (2008) in the Islamic Republic of Iran, Report by the Director General, GOV/2008/15,

May 26, 2008.

55 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions 1737

(2006), 1747 (2007), 1803 (2008) and 1835 (2008) in the Islamic Republic of Iran, Report by the Director General,

GOV/2009/55, August 28, 2009.

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August 2008.56 According to this report, which provided the most detailed account to date of the

IAEA’s evidence regarding Iran’s suspected nuclear weapons-related activities, the agency has

“credible” information that Iran has carried out activities “relevant to the development of a

nuclear explosive device,” including

acquisition of “nuclear weapons development information and documentation,”

work to develop “an indigenous design of a nuclear weapon including the testing

of components,”

efforts “to procure nuclear related and dual use equipment and materials by

military related individuals and entities,”

and work to “develop undeclared pathways for the production of nuclear

material.”

Although some of these activities have civilian applications, “others are specific to nuclear

weapons,” the report notes. Most of these activities were conducted before the end of 2003,

though some may have continued. (See Appendix E and “Nuclear Weapon Development

Capabilities” for more details.)

The IAEA Board of Governors adopted a resolution on November 18, 2011, stating that “it is

essential” for Iran and the IAEA “to intensify their dialogue aiming at the urgent resolution of all

outstanding substantive issues.” IAEA and Iranian officials met 10 times between January 2012

and May 2013 to discuss what the agency termed a “structured approach to the clarification of all

outstanding issues related to Iran’s nuclear programme.”57 However, during an October 2013

meeting, IAEA officials and their Iranian counterparts decided to adopt a “new approach” to

resolving these issues. Iran signed a joint statement with the IAEA on November 11, 2013,

describing a “Framework for Cooperation.” According to the statement, Iran and the IAEA

agreed to “strengthen their cooperation and dialogue aimed at ensuring the exclusively peaceful

nature of Iran’s nuclear programme through the resolution of all outstanding issues that have not

already been resolved by the IAEA.” Tehran subsequently provided the IAEA with information

about several of the outstanding issues and later agreed in May 2014 to provide information to the

agency by August 25, 2014, about five additional issues, including alleged Iranian research on

high explosives and “studies made and/or papers published in Iran in relation to neutron transport

and associated modelling and calculations and their alleged application to compressed materials.”

Iran subsequently provided information about four of these issues.58

Road Map to Assessing Possible Military Dimensions

The July 2015 JCPOA states that Tehran was to “complete” a series of steps set out in an IranIAEA “Roadmap for Clarification of Past and Present Outstanding Issues.” According to thenIAEA Director-General Amano, this road map, which the two sides concluded in July 2015, set

out “a process” under the November 2013 JPA “to enable the Agency, with the cooperation of

Iran, to make an assessment of issues relating to possible military dimensions to Iran’s nuclear

56 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions in the

Islamic Republic of Iran, GOV/2011/65, November 8, 2011.

57 A September 2012 IAEA Board of Governors resolution reiterated the board’s support for the agency’s negotiations

with Tehran, and stated that “Iranian cooperation with IAEA requests aimed at the resolution of all outstanding issues

is essential and urgent in order to restore international confidence in the exclusively peaceful nature of Iran’s nuclear

programme.”

58 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions in the

Islamic Republic of Iran, Report by the Director General, GOV/2015/34, May 29, 2015.

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programme.”59 According to a December 2, 2015, report to the IAEA Board of Governors from

Amano, “[a]ll the activities contained in the road-map were implemented in accordance with the

agreed schedule.”60 The road map required Amano to present this report, which contains the

agency’s “final assessment on the resolution” of the aforementioned outstanding issues.

In response, the board adopted a resolution on December 15, 2015, that notes Iran’s cooperation

with the road map and “further notes that this closes the Board’s consideration” of the

“outstanding issues regarding Iran’s nuclear programme.”61 Because the IAEA has verified that

Iran has taken the steps required for Implementation Day to take effect, the board is no longer

focused on either Iran’s compliance with past Security Council resolutions or past issues

concerning Iran’s safeguards agreement. Instead, the board is focused on monitoring and

verifying Iran’s JCPOA implementation “in light of” United Nations Security Council Resolution

2231, which the council adopted on July 20, 2015. The December 2015 IAEA resolution requests

the Director General to issue quarterly reports to the board regarding Iran’s “implementation of

its relevant commitments under the JCPOA for the full duration of those commitments.” The

Director General is also to report to the IAEA Board of Governors and the Security Council “at

any time if the Director General has reasonable grounds to believe there is an issue of concern”

regarding Tehran’s compliance with its JCPOA or safeguards obligations.62

Parchin

Parchin is an Iranian military site. As part of its investigation into “possible military dimensions”

of Iran’s nuclear program, the IAEA requested that Tehran respond to information which the

agency obtained from unnamed governments regarding activity at the military site. Information

provided to IAEA indicated that in 2000 “Iran constructed a large explosives containment vessel”

at Parchin to conduct experiments related to the development of nuclear weapons, according to

Amano’s November 2011 report.63 The report did not say whether Iran actually built the vessel or

conducted these experiments. IAEA inspectors visited the site twice in 2005, but they did not visit

the location “believed to contain the building which houses the explosives chamber.”64 The

agency requested access to this latter building in February 2012, but Iran did not provide such

access until September 2015 as part of the road map described above. At that time, IAEA officials

conducted and supervised verification activities, including “visual observation and environmental

sampling,” but they “did not observe a chamber or any associated equipment inside the

59 For more information about the Joint Plan of Action and the JCPOA, see CRS Report R43333, Iran Nuclear

Agreement, by Kenneth Katzman and Paul K. Kerr.

60 Final Assessment on Past and Present Outstanding Issues Regarding Iran’s Nuclear Programme, GOV/2015/68,

December 2, 2015.

61 Joint Comprehensive Plan of Action Implementation and Verification and Monitoring in the Islamic Republic of Iran

in Light of United Nations Security Council Resolution 2231 (2015), Resolution Adopted by the Board of Governors,

GOV/2015/72, December 15, 2015.

62 The JCPOA and U.N. Security Council Resolution 2231 contain a variety of reporting provisions for the IAEA. For

example, the resolution requests the agency’s Director General

to provide regular updates to the IAEA Board of Governors and, as appropriate, in parallel to the

Security Council on Iran’s implementation of its commitments under the JCPOA and also to report

to the IAEA Board of Governors and in parallel to the Security Council at any time if the Director

General has reasonable grounds to believe there is an issue of concern directly affecting fulfilment

of JCPOA commitments.

63 GOV/2011/65.

64 Ibid.

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building.”65 Iranian officials told their IAEA counterparts in October 2015 that the building in

question “had always been used for the storage of chemical material for the production of

explosives,” but the “information available” to the IAEA, “does not support Iran’s statements on

the purpose of the building.”66 Beginning in February 2012, Iran apparently undertook efforts to

remove evidence of past nuclear-related activities at the site. These efforts, which included

landscaping, refurbishing buildings, demolishing buildings, and removing and replacing external

wall structures, “seriously undermined the Agency’s ability to conduct effective verification,”

according to Amano’s December 2, 2015, report.

Iranian officials have implied that the government’s refusal to allow IAEA post-2005 access to

Parchin was due to Defense Ministry resistance. Fereydoun Abbasi-Davani, then-AEOI President,

indicated in 2012 that allowing inspectors to the site was the Iranian military’s decision.67

Rouhani in 2011 described a contentious internal debate regarding access to Parchin:

In the area of Agency inspections and especially the inspections of military centers such as

Parchin, this was debated for months inside the country and this issue was therefore raised

in various meetings over the circumstances in which these inspections would take place.

There was serious opposition to the Agency’s request to inspect Parchin; the nation’s

domestic political climate was vigorously opposed to inspectors inspecting Parchin and

military centers in general.68

For more information about the Parchin site, see Appendix E.

Other IAEA Cooperation Issues

Iran cooperated with the IAEA in other respects, albeit with varying consistency. The IAEA was

(and still is) able to verify that Iran’s declared nuclear facilities and materials have not been

diverted for military purposes. Moreover, Tehran provided the agency with “information similar

to that which Iran had previously provided pursuant to the Additional Protocol,” ElBaradei

reported to the IAEA board in February 2008, adding that this information clarified the agency’s

“knowledge about Iran’s current declared nuclear programme.”69 Iran, however, provided this

information “on an ad hoc basis and not in a consistent and complete manner,” the report said.

Indeed, the IAEA requested in April 2008 that Iran provide “as a transparency measure, access to

additional locations related ... to the manufacturing of centrifuges, research and development

(R&D) on uranium enrichment, and uranium mining.”70 Tehran provided such access pursuant to

the 2013 JPA.

ElBaradei’s February 2008 report underscored the importance of full Iranian cooperation with the

IAEA investigation, as well as Tehran’s implementation of its Additional Protocol:

Confidence in the exclusively peaceful nature of Iran’s nuclear programme requires that

the Agency be able to provide assurances not only regarding declared nuclear material, but,

equally importantly, regarding the absence of undeclared nuclear material and activities in

Iran.... Although Iran has provided some additional detailed information about its current

activities on an ad hoc basis, the Agency will not be in a position to make progress towards

65 GOV/2015/68.

66 Ibid.

67 “Iran: Military Decides if IAEA Can Visit Parchin,” Reuters, February 29, 2012.

68 Rouhani 2011, p. 244.

69 GOV/2008/4.

70 GOV/2008/15.

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providing credible assurances about the absence of undeclared nuclear material and

activities in Iran before reaching some clarity about the nature of the alleged studies, and

without implementation of the Additional Protocol.71

The IAEA also asked Iran to “reconsider” its March 2007 decision to stop complying with a

portion of the subsidiary arrangements for its IAEA safeguards agreement.72 That provision

(called code 3.1), to which Iran agreed in February 2003, requires Tehran to provide design

information for new nuclear facilities “as soon as the decision to construct, or to authorize

construction, of such a facility has been taken, whichever is earlier.” Previously, Iran was required

to provide design information for a new facility 180 days before introducing nuclear material into

it.73 Iran invoked the March 2007 decision when it withheld from the IAEA until September 2009

“preliminary design information” for the planned Darkhovin reactor; the agency first requested

the information in December 2007. Although Iran provided the agency with preliminary design

information about the Darkhovin reactor in a September 22, 2009, letter, the IAEA requested

Tehran to “provide additional clarifications” of the information.74 Amano reported in September

2010 that Iran had “provided only limited design information with respect to” the reactor.75

Arak Reactor

Tehran also refused to provide updated design information for the Arak reactor—a decision

which, according to a May 2013 report from Amano, had “an adverse impact on the Agency’s

ability to effectively verify the design of the facility.”76 As part of the JPA, Iran submitted this

information to the IAEA on February 12, 2014.77 Pursuant to the JCPOA, Iran has committed to

redesign and rebuild the Arak reactor based on a design agreed to by the P5+1 so that it will not

produce weapons-grade plutonium. Iran has rendered the reactor’s original core inoperable.

Iran had also refused to allow IAEA officials to conduct an inspection of the Arak reactor in order

to verify Iranian-provided design information. ElBaradei argued in a June 2009 report to the

IAEA board that this continued refusal “could adversely impact the Agency’s ability to carry out

effective safeguards at that facility,” adding that satellite imagery was insufficient because Iran

has completed the “containment structure over the reactor building, and the roofing for the other

buildings on the site.”78 However, IAEA inspectors visited the reactor facility in August 2009 to

71 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions 1737

(2006) and 1747(2007) in the Islamic Republic of Iran, Report by the Director General, GOV/2008/4, February 22,

2008.

72 According to the 2001 IAEA Safeguards Glossary, subsidiary arrangements describe the “technical and

administrative procedures for specifying how the provisions laid down in a safeguards agreement are to be applied.”

73 For more detail about Iran’s safeguards obligations and reporting requirements, see CRS Report R40094, Iran’s

Nuclear Program: Tehran’s Compliance with International Obligations, by Paul K. Kerr.

74 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions 1737

(2006), 1747 (2007), 1803 (2008) and 1835 (2008) in the Islamic Republic of Iran, Report by the Director General,

GOV/2008/59, November 19, 2008.

75 Implementation of the NPT Safeguards Agreement in Relevant Provisions of Security Council Resolutions in the

Islamic Republic of Iran, Report by the Director General, GOV/2010/46, September 6, 2010. IAEA reports since 2012

do not appear to address this issue.

76 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions in the

Islamic Republic of Iran, Report by the Director General, GOV/2013/27, May 22, 2013.

77 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions in the

Islamic Republic of Iran, Report by the Director General, GOV/2014/10, February 20, 2014.

78 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions 1737

(2006), 1747 (2007), 1803 (2008) and 1835 (2008) in the Islamic Republic of Iran, Report by the Director General,

GOV/2009/35, June 5, 2009.

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verify design information, according to ElBaradei’s report issued the same month. IAEA

inspectors had last visited the reactor in August 2008. Inspectors have visited the facility several

more times, according to reports from Amano.

Fordow Fuel Enrichment Plant

In addition, Iran failed to notify the IAEA until September 2009 that it was constructing a

uranium enrichment facility, called the Fordow Fuel Enrichment Plant, near the city of Qom. Iran

revealed in September 2009 that it had been constructing the facility and provided some details

about it to the IAEA in a September 21, 2009, letter. Four days after the IAEA received the letter,

British, French, and U.S. officials revealed that they had previously developed intelligence on the

facility. The three governments provided a detailed intelligence briefing to the IAEA after the

agency received Iran’s letter. U.S. officials have said that, despite its letter to the agency, Iran

intended for the facility to be kept secret. Tehran placed the facility under IAEA safeguards after

its September 2009 letter. (For more details, see the “Fordow Enrichment Facility” section

below.) Pursuant to the JCPOA, Iran has begun to convert its Fordow enrichment facility into “a

nuclear, physics, and technology centre” in which no nuclear material will be present.

In a letter published on October 1, 2009, the IAEA asked Iran to provide additional information

about the facility, including “further information with respect to the name and location of the pilot

enrichment facility, the current status of its construction and plans for the introduction of nuclear

material into the facility.” The letter also requested that Tehran provide IAEA inspectors with

access to the facility “as soon as possible.” IAEA officials inspected the facility and met with

Iranian officials in late October 2009. According to a November 2009 report from ElBaradei to

the IAEA board, Tehran “provided access to all areas of the facility,” which “corresponded with

the design information provided by Iran” a week before the visit. IAEA officials have since

conducted regular inspections of the facility. Although Iran provided additional design

information about the facility to the IAEA, the agency still had questions about the facility’s

“purpose and chronology” and wished to interview other Iranian officials and review additional

documentation, according to ElBaradei’s report. Amano reported in May 2012 that Iran had

provided the IAEA with some requested information regarding the Fordow construction decision,

but the agency still wanted more information from Tehran.79 Tehran, according to Amano’s

November 2015 report, has not yet provided all of this information.80 Subsequent IAEA reports

have not addressed the issue.

Heavy-Water Reactor

The IAEA has also requested additional information about Iran’s production of heavy water. As

noted, Iran is constructing a heavy-water nuclear reactor. ElBaradei’s November 2009 report

states that, during an inspection of Iran’s uranium conversion facility the previous month, IAEA

inspectors “observed 600 50-litre drums said by Iran to contain heavy water.”81 The inspectors

visited the facility to verify updated design information submitted by Iran in August 2009. The

inspectors observed the drums after gaining access to an area of the facility that agency inspectors

79 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions in the

Islamic Republic of Iran, Report by the Director General, GOV/2012/23, May 25, 2012.

80 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions in the

Islamic Republic of Iran, GOV/2015/65, Report by the Director General, November 18, 2015.

81 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions 1737

(2006), 1747 (2007), 1803 (2008) and 1835 (2008) in the Islamic Republic of Iran, Report by the Director General,

GOV/2009/74, November 16, 2009.

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had not previously visited.82 Tehran told the IAEA that the water originated in Iran and permitted

agency inspectors to count the number of drums and weigh a “small number of randomly selected

drums.”83 For a time, Tehran did not permit the agency to take samples of the heavy water, but the

government did allow such access in February 2014.84 Similarly, Iran for some time did not grant

repeated IAEA requests for “further access” to the country’s heavy-water production plant since

agency inspectors visited the facility in August 2011.85 However, Iran granted such access in

December 2013.86

The IAEA apparently resolved a discrepancy discovered during an August 2011 inspection of an

Iranian research laboratory that had been used to conduct uranium conversion experiments. IAEA

measurements revealed that Iran had overstated the amount of material in the facility, described in

Amano’s November 2011 report as “natural uranium metal and process waste,” by almost 20

kilograms.87 Iran and the IAEA appear to have resolved the issue in 2013.88

Status of Iran’s Nuclear Facilities

Some nongovernmental experts and former U.S. officials have argued that, rather than producing

fissile material for nuclear weapons indigenously, Iran could obtain such material from foreign

sources.89 A November 2007 National Intelligence Estimate (NIE) states that the intelligence

community “cannot rule out that Iran has acquired from abroad—or will acquire in the future—a

nuclear weapon or enough fissile material for a weapon.”90 A senior intelligence official

characterized such acquisition as “an inherent option” for Iran.91 However, Tehran’s potential

ability to produce its own fissile material is a greater cause of concern; the official explained that

“getting bits and pieces of fissile material from overseas is not going to be sufficient” to produce

a nuclear arsenal.92 As noted, uranium enrichment facilities can produce highly enriched uranium

(HEU), which is one of the two types of fissile material used in nuclear weapons. The other type

is plutonium, which is separated from spent nuclear reactor fuel.

According to a November 14, 2013, IAEA report, Iran had generally stopped expanding its

enrichment and heavy-water reactor programs during the negotiations leading up to the JPA,

82 CRS analyst interview with a U.S. official, December 17, 2009.

83 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions 1737

(2006), 1747 (2007), 1803 (2008) and 1835 (2008) in the Islamic Republic of Iran, Report by the Director General,

GOV/2010/10, February 18, 2010.

84 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions in the

Islamic Republic of Iran, Report by the Director General, GOV/2015/15, February 19, 2015.

85 Ibid.

86 GOV/2015/65.

87 Ibid.

88

GOV/2013/27.

89 See, for example, then-Under Secretary of State for U.S. Arms Control and International Security Robert Joseph’s

testimony before the Senate Committee on Foreign Relations, February 9, 2006, and then-Director of Research Institute

for National Strategic Studies National Defense University Stephen Cambone’s testimony before the Senate Committee

on Governmental Affairs, September 21, 2000.

90 Iran: Nuclear Intentions and Capabilities, National Intelligence Estimate, November 2007.

91 “Unclassified Key Judgments of the National Intelligence Estimate: Iran: Nuclear Intentions and Capabilities,”

background briefing with senior intelligence officials, December 3, 2007.

92 Ibid.

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which the parties finalized later that month.93 That agreement essentially froze most aspects of

Iran’s nuclear program to allow time to negotiate the July 2015 JCPOA. When the JPA went into

effect in January 2014, Iran had enough uranium hexafluoride containing up to 5% uranium-235

to yield—if further enriched—weapons-grade HEU for as many as eight nuclear weapons.94 If it

had been further enriched, the total amount of Iranian uranium hexafluoride containing 20%

uranium-235 would have been sufficient for a nuclear weapon. Pursuant to the JCPOA, Iran has

restricted and/or dismantled various portions of its nuclear program. Iran currently lacks enough

low-enriched uranium hexafluoride to produce a nuclear weapon.

Since the JCPOA’s Implementation Day, Iran has imported items for its nuclear program via a

JCPOA-established “procurement channel,” which, according to the agreement, is to last for a

duration of 10 years.95 A Procurement Working Group, which is part of the JCPOA-established

Joint Commission, reviews proposals for nuclear-related transfers to Iran. The working group

provides its recommendations to the UN Security Council, which approves any exports. The

JCPOA requires Iran to provide the IAEA with “access to the locations of intended use of all

items, materials, equipment, goods and technology” listed in the NSG’s “Guidelines for Nuclear

Transfers.”96 Tehran is also to permit exporting governments to “verify the end-use of all items,

materials, equipment, goods and technology” listed in the NSG’s “Guidelines for Transfers of

Nuclear-Related Dual-Use Equipment, Materials, Software, and Related Technology.”97

According to a December 2019 report by Marc Pecsteen de Buytswerve, Security Council

Facilitator for the Implementation of Resolution 2231(2015), the Security Council had received

44 nuclear-related export proposals since Implementation Day; the council approved 30 of those

proposals and disapproved five. Nine proposals were withdrawn by the submitting states.98 The

report states that “the procurement channel continues to function, and the Joint Commission

continues to review proposals.” However, the number of export proposals has decreased

significantly since the May 2018 U.S. withdrawal from the JCPOA; de Buytswerve’s report states

that the group had received no new proposals during the previous six-month period.99

Uranium Enrichment Facilities

Iran has used three centrifuge facilities to enrich uranium: a pilot centrifuge facility and a larger

commercial facility, both located at Natanz, and the Fordow centrifuge facility located near the

city of Qom. Iran has also had a variety of facilities and workshops involved in the production of

centrifuges and related components. (See Appendix F and CRS Report R42443, Israel: Possible

Military Strike Against Iran’s Nuclear Facilities, coordinated by Jim Zanotti.) During a July 31,

93 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions in the

Islamic Republic of Iran, Report by the Director General, GOV/2013/56, November 14, 2013.

94 Colin Kahl, Deputy Assistant to the President and National Security Adviser to the Vice President, “Arms Control

Association Annual Meeting: Unprecedented Challenges for Nonproliferation and Disarmament,” May 14, 2015.

95 Information about the procurement channel is available at https://eeas.europa.eu/delegations/iran/8711/jcpoaprocurement-channel_en.

96 INFCIRC/254/Rev.12/Part 1.

97 INFCIRC/254/Rev.9/Part 2.

98 Eighth Six-Month Report of the Facilitator on the Implementation of Security Council Resolution 2231 (2015),

S/2019/952/Rev.1, December 16, 2019.

99 Ibid. A June 2019 letter from Russia to the UN Security Council suggests that the United States is attempting to

prevent transfers via the channel (Letter dated 11 June 2019 from the Chargé d’affaires of the Permanent Mission of

the Russian Federation to the United Nations Addressed to the Secretary-General and the President of the Security

Council, S/2019/482, June 12, 2019).

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2015, press briefing about possible Iranian undeclared nuclear facilities, then-U.S. Secretary of

Energy Ernest Moniz stated that “we feel pretty confident that we know their current

configuration.”100

Natanz Commercial Facility

This facility was to have held approximately 50,000 centrifuges.101 Former Vice President

Gholamreza Aghazadeh, who also headed the AEOI until July 2009, explained in February 2009

that Iran intended to install all of the centrifuges by 2015.102 Iran began enriching uranium in the

facility after mid-April 2007; as of November 5, 2013, the facility had produced 10,357

kilograms of low-enriched uranium hexafluoride containing up to 5% uranium-235. This quantity

of LEU, if it had been further enriched, would have yielded enough weapons-grade HEU for as

many as eight nuclear weapons.103 As of October 31, 2015, the facility had produced 15,525

kilograms of uranium hexafluoride containing up to 5% uranium-235. However, Iran had only

approximately 8,305 kilograms of this material because the rest had been converted into various

other chemical forms.104

Individual centrifuges are linked together in cascades; each cascade in the commercial facility

contained either 164 or 174 centrifuges. As of May 17, 2015, Tehran had installed about 15,400

first generation (IR-1) centrifuges, approximately 9,150 of which were enriching uranium. Iran

had also installed about 1,000 centrifuges of greater efficiency, called IR-2m centrifuges, in the

facility. The IR-2m centrifuges were not enriching uranium.105 Amano reported in February 2017

100 See also Colin H. Kahl, “Not Time to Attack Iran: Why War Should Be a Last Resort,” Foreign Affairs, January 17,

2012.

101 A 2008 IAEA report states that Iran was planning to install 16 cascade units, each containing 18 164-centrifuge

cascades. The total number of centrifuges would have been 47,232. Iran, however, installed some cascades containing

174 centrifuges (Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council

Resolutions 1737 [2006], 1747 [2007] and 1803 [2008] in the Islamic Republic of Iran, Report by the Director

General, GOV/2008/15, May 26, 2008). According to September 25, 2009, Obama Administration talking points, the

facility “is designed to house 54,000 centrifuges.” Gholamreza Aghazadeh, who headed Iran’s Atomic Energy

Organization (AEOI), said in February 2009 that Iran would install 50,000 centrifuges (“Iran to Follow Nuclear

Timetable Regardless of IAEA Reports—Official,” Islamic Republic of Iran News Network, February 25, 2009). A

2012 AEOI report gives the facility’s “overall capacity” as 48,000 centrifuges (Nuclear Industry in Iran: An Overview

on Iran’s Activities and Achievements in Nuclear Technology, Atomic Energy Organization of Iran, 2012, p. 16).

102 Islamic Republic of Iran News Network, February 25, 2009.

103 Colin Kahl, Deputy Assistant to the President and National Security Adviser to the Vice President, “Arms Control

Association Annual Meeting: Unprecedented Challenges for Nonproliferation and Disarmament,” May 14, 2015. See

also calculations from Iran’s Nuclear, Chemical, and Biological Capabilities: A Net Assessment, International Institute

for Strategic Studies [IISS], 2011, p. 72. This number of nuclear weapons probably assumes that 25 kilograms of

uranium-235 (approximately 27.8 kilograms of uranium containing 90% uranium-235) would be necessary for one

HEU-based nuclear weapon. The IAEA term for this amount of uranium is “significant quantity,” defined as the

“approximate amount of nuclear material for which the possibility of manufacturing a nuclear explosive device cannot

be excluded.” The latter report points out that Iran would likely need to produce more uranium-235 to build its first

nuclear weapon because “the fabrication of an initial bomb would involve an amount of unavoidable wastage” (p. 69).

Some types of weapons could be developed using less uranium-235. The term “significant quantity” should be

understood in the context of IAEA safeguards objectives. One such objective, according to the agency, is the “timely

detection of diversion of significant quantities of nuclear material from peaceful nuclear activities to the manufacture of

nuclear weapons or of other nuclear explosive devices or for purposes unknown.”

104 GOV/2015/65. Iran’s Fordow centrifuge facility also produced low-enriched uranium hexafluoride containing up to

5% uranium-235 (see “Fordow Enrichment Facility”). In addition, Iran produced uranium hexafluoride of a similar

isotopic composition by converting low-enriched uranium hexafluoride containing nearly 20% uranium-235.

105 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions in the

Islamic Republic of Iran, GOV/2015/34, Report by the Director General, May 29, 2015.

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that, pursuant to its JCPOA commitments, Iran had 5,060 IR-1 centrifuges installed in the facility

and had removed all other centrifuges.106 Iran shipped out most of its LEU to Russia on

December 28, 2015, to reduce its stockpile to the required levels.107 Until July 1, 2019, IAEA

reports stated that Iran’s total stockpile of low-enriched uranium hexafluoride did not exceed 300

kilograms since Tehran began implementing its JCPOA commitments.108 But the agency reported

on that date, however, that it had verified that this stockpile had exceed the 300 kilogram limit.109

As of August 19, 2019, Iran’s stockpile of low-enriched uranium hexafluoride was

approximately 372 kilograms, based on information from a November 11 report by IAEA Acting

Director General Cornel Feruță.110

Until July 2019, IAEA reports stated that Iran had been producing enriched uranium hexafluoride

continuing no more than 3.67% uranium-235, as mandated by the JCPOA. According to a July 8

IAEA report, the agency verified that the uranium-235 content of Tehran’s LEU exceeded the

JCPOA-mandated limits. “Iran informed the Agency that, based on the operator’s assessment, the

[LEU] enrichment level … is about 4.5%,” the report says.111 Tehran has since been “enriching

uranium up to” this concentration of uranium-235.112 AEOI spokesperson Behrouz Kamalvandi

stated in a November press conference that the AEOI “is capable of enriching uranium to 5, 20 or

60 per cent.”113

Natanz Pilot Facility

Iran began enriching uranium up to 20% uranium-235 in the Natanz pilot facility in February

2010. Iranian officials stated that this enriched uranium was to serve as fuel in Iran’s Tehran

Research Reactor (TRR), as well as future such research reactors.114 Construction of the U.S.supplied TRR began in 1960, and it went critical in 1967. Initially fueled by U.S.-supplied HEU,

106 Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution

2231 (2015), GOV/2017/10, Report by the Director General, February 24, 2017.

107 “Press Release on the Export of Enriched Uranium from Iran Assisted by Russia as Part of Preparation for JCPOA

Implementation,” Ministry of Foreign Affairs of the Russian Federation, December 29, 2015. Daily Press Briefing,

Department of State, December 28, 2015. Ambassador Stephen Mull, then-Coordinator for Implementation of the

JCPOA, told the Senate Foreign Relations Committee on December 17, 2015, that the exported material “will end up at

a safeguarded facility” in Russia.

108 Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution

2231 (2015), Report by the Director General, International Atomic Energy Agency, GOV/2019/10, February 22, 2019.

109 Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution

2231 (2015), GOV/INF/2019/8, Report by the Director General, July 1, 2019. Based on information in the report,

Iran’s stockpile of low-enriched uranium hexafluoride was approximately 304 kilograms.

110 Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution

2231 (2015), Report by the Director General, International Atomic Energy Agency, GOV/2019/55, November 11,

2019. The stockpile’s composition as of November 3 was approximately 213 kilograms of LEU containing as much as

3.67% uanium-235 and 160 kilograms of LEU containing as much as 4.5% uranium-235.

111 Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution

2231 (2015), GOV/INF/2019/9, Report by the Director General, July 8, 2019.

112 GOV/2019/55.

113 “Iran Capable of Enriching Uranium Up to 60 per Cent – Official,” BBC Monitoring, November 10, 2019.

114GOV/2012/23. Iran will need to provide fuel for “at least 4 other research reactors,” according to the text of a June

Iranian proposal to the P5+1 (“Full Text of Iran’s Proposals to Six World Powers in Moscow Talks,” Fars News

Agency, July 7, 2012). Abbasi stated in an April 2012 interview that Iran plans to design and build another 10 megawatt

“strong pool reactor.” He indicated that the reactor would also use fuel enriched to the level of the TRR fuel, but he

provided no additional details (“Nuclear Chief: Iran Sees No Reason For Suspending Fordo Activities,” Iranian

Students’ News Agency, April 8, 2012).

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the reactor was converted to use LEU fuel in 1994 after Argentina agreed to supply the reactor

with such fuel in 1987.115 Fereydun Abbasi-Davani, then-President of the Atomic Energy

Organization of Iran, stated in a 2012 interview that once Iran had “enough” uranium enriched to

this level, the country would use its enrichment facilities to produce enriched uranium containing

3.5% uranium-235.116

Centrifuge Research and Development

Iran has tested several types of more-advanced centrifuges in the pilot facility; these centrifuges

could increase the other enrichment facilities’ capacity.117 Tehran has altered this facility to

comply with the JCPOA’s limits on Iranian centrifuge research and development.118 Iran’s

development of new centrifuges has apparently been less successful than development of the IR-1

centrifuge;119 past estimates from Iranian officials regarding the deployment of more-advanced

centrifuges have been excessively optimistic.120 According to a 2012 report from a U.N. panel of

experts, the advanced centrifuge program’s lack of success may have been “the result of sanctions

limiting” Tehran’s “ability to procure items necessary for its centrifuge programme,” as well as

“[o]ther variables, including design and manufacturing limitations, or a shortage of other

necessary materials.”121

The JCPOA contains a detailed description of centrifuge research and development (R&D) that

Iran is permitted to conduct under the agreement. Iran is to conduct centrifuge R&D with uranium

only at the Natanz pilot facility and will conduct mechanical testing of centrifuges only at the

pilot facility and the Tehran Research Centre. Iran submitted an “enrichment R&D plan” to the

IAEA in January 2016 as part of Tehran’s initial declaration for its Additional Protocol.122 Iranian

adherence to that plan is a JCPOA requirement. Beginning in September 2019, Iran has installed,

115 This information is contained in a February 18, 2010, letter from Iran to the IAEA (GOV/INF/2010/5). An undated

paper from an AEOI official places the conversion date at November 1993 (Mohammad Zaker, “Conversion and Start

Up of Tehran Research Reactor with LEU Fuel,” no date given. Available at http://www.iaea.org/inis/collection/

NCLCollectionStore/_Public/35/044/35044382.pdf).

116 Iranian Students’ News Agency, April 8, 2012.

117 Iran has experimented with a variety of advanced centrifuges. A June 2009 report from ElBaradei states that Iran

was testing four other more-advanced centrifuges; Iran informed the IAEA in February 2012 that it intended to install

three new types of centrifuges, according to a 2012 IAEA report (Implementation of the NPT Safeguards Agreement

and Relevant Provisions of Security Council Resolutions in the Islamic Republic of Iran, Report by the Director

General, GOV/2012/9, February 24, 2012). Iran’s IR-2m could “improve the enrichment of the Iranian centrifuges

threefold,” according to a 2012 Israeli intelligence report (Report 9342, Iran/Nuclear/Program Status, October 22,

2012. Available at http://www.aljazeera.com/news/2015/02/leaks-netanyahu-misled-iran-nuclear-programme-guardianiran-nuclear-speech-2012-150218165622065.html).

118 Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution

2231 (2015), Report by the Director General, GOV/INF/2016/1, January 16, 2016.

119 Analyst interview with U.S. official, June 25, 2009; “Iran May Be ‘Struggling’ with New Nuclear Machines,”

Reuters, February 28, 2012.

120 For example, then-Atomic Energy Organization President Aghazadeh indicated in February 2009 that at least one

new type of centrifuge would be installed in the “near future” (Islamic Republic of Iran News Network, February 25,

2009). Then-Atomic Energy Organization President Ali Akbar Salehi stated in a December 2009 interview that Iran

hoped to have the new types of centrifuges operational by early 2011 (“Iran to Produce New Generation of

Centrifuges—Nuclear Chief,” Fars News Agency, December 18, 2009).

121 Final Report of the Panel of Experts Established Pursuant to Resolution 1929 (2010), June 12, 2012.

122 Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution

2231 (2015), Report by the Director General, GOV/2016/8, February 26, 2016.

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as well as begun testing with uranium hexafluoride, quantities and types of advanced centrifuges

at this facility in violation of its JCPOA commitments.123

Fordow Enrichment Facility124

In December 2011, Iran began enriching uranium up to 20% uranium-235 in the Fordow Fuel

Enrichment Plant, according to IAEA reports. As of November 1, 2013, Iran was feeding uranium

hexafluoride into four cascades (696 centrifuges) of IR-1 centrifuges125 and had installed a total

of 2,710 IR-1 centrifuges in the facility. Tehran had planned to install a total of 16 cascades

containing approximately 3,000 centrifuges. Tehran told the IAEA that the facility would be

configured to produce both uranium enriched to 5% uranium-235 and 20% uranium-235. Iran

also told the IAEA that “the facility could be reconfigured to contain centrifuges of more

advanced types should Iran take a decision to use such centrifuges in the future.”126

Iran agreed under the JCPOA to convert the facility into “a nuclear, physics, and technology

centre.” Pursuant to this commitment, Iran decreased the number of IR-1 centrifuges to 1,044 and

removed all nuclear material from the facility. Beginning in November, however, Iran transferred

uranium hexafluoride to the facility and began enriching uranium in two cascades, each of which

contain 174 IR-1 centrifuges; the JCPOA prohibits both of these activities.127

Pursuant to its JCPOA commitments, Iran has modified two cascades “for the production of

stable isotopes” for medical and industrial uses.128 However, the Russian company TVEL stated

on December 6 that it had cancelled its work on these modifications, which the company had

conducted since 2017, because Iran had begun in November to feed uranium hexafluoride into

other cascades in the same facility (see below). “Uranium enrichment and stable medical isotope

production cannot be sustained in the same room,” the statement explained, adding that “[a]ir and

equipment are exposed to [uranium hexafluoride] leftovers, making the produced stable medical

isotopes unsuitable for medical purposes.”129 Russian and Iranian officials have stated that the

two governments are attempting to resolve this issue.130 According to an article published

December 9, Kamalvandi stated that Iran “can continue production of stable isotopes even

123 GOV/2019/55; Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security

Council Resolution 2231 (2015), Report by the Acting Director General, GOV/INF/2019/10, September 8, 2019.

124 Unless otherwise noted, this section is based on a September 21, 2009, letter from Iran to the IAEA and September

25, 2009, background briefings from U.S. officials, along with associated Obama Administration talking points. See

also CRS Report R43333, Iran Nuclear Agreement.

125 GOV/2012/23.

126 GOV/2009/74.

127 GOV/2019/55.

128 GOV/INF/2016/1. An AEOI official announced in late August 2016 that Iran had opened a “semi-industrial unit” at

its uranium conversion facility in order to “produce raw materials for stable isotopes” (“Iran Opens Stable Isotope

Materials Production Unit,” Mehr News Agency, August 29, 2016).

129 “TVEL Company Statement Regarding Fordow Project, Iran,” December 6, 2019.

130 “Iran Says Talks With Russia on Stable Isotopes in Progress,” Fars News Agency, December 5, 2019. “Russia to

Analyze Impact of U.S. Restrictions on Fordow Nuclear Project – Senior Diplomat,” ITAR-TASS, December 5, 2019. A

Chair’s statement following a December 6 meeting of the JCPOA-established Joint Commission explained that the

remaining JCPOA parties “expressed strong support to the efforts of Russia to continue implementation of the stable

isotope project.” (Chair’s Statement Following the 6 December Meeting of the Joint Commission of the JCPoA,

December 6, 2019.)

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without the Russians,” adding that Tehran is “building a center” at the Fordow facility “which

will be constructed a few months later to produce stable isotopes without using centrifuges.”131

As noted, Iran revealed in September 2009 that it had been constructing the facility. That same

month, Tehran provided some details about the facility to the IAEA. The United States had been

“observing and analyzing the facility for several years,” according to September 25, 2009, Obama

Administration talking points, which added that “there was an accumulation of evidence” earlier

in 2009 that the facility was intended for enriching uranium.132 Some of this evidence apparently

indicated that “Iran was installing the infrastructure required for centrifuges earlier” in 2009.133

U.S. officials have not said exactly when Iran began work on the facility, which is “located in an

underground tunnel complex on the grounds of an Islamic Revolutionary Guard Corps” base near

the Iranian city of Qom. Nevertheless, the Atomic Energy Organization of Iran (AEOI), rather

than the Iranian military, is responsible for the development and management of the facility,

according to the September 2009 U.S. talking points described above.134 According to a

November 2009 report from then-IAEA Director-General ElBaradei, Iran informed the IAEA that

construction on the site began in the second half of 2007.135 However, citing information in its

possession that appears to contradict Tehran’s claim, the IAEA asked Iran to provide more

information about the facility’s chronology.136

U.S. officials suggested that the facility may have been part of a nuclear weapons program.

President Obama stated on September 25, 2009, that “the size and configuration of this facility is

inconsistent with a peaceful program.” But the Administration’s talking points were somewhat

more vague, stating that the facility “is too small to be viable for production of fuel for a nuclear

power reactor,” although it “could be used” for centrifuge research and development or

“configured to produce weapons-grade uranium.”137 The facility “would be capable of producing

approximately one weapon’s worth” of HEU per year, according to the talking points.138

Iran’s failure to inform the IAEA of the Fordow plant’s existence until well after Tehran had

begun constructing it raised concerns that the country may have had other covert nuclear

facilities. A November 2009 IAEA Board of Governors resolution stated that Iran’s declaration of

the Fordow facility “reduces the level of confidence in the absence of other nuclear facilities and

gives rise to questions about whether there are any other [undeclared] nuclear facilities under

construction in Iran.” Furthermore, then-UK Foreign Office Minister Alistair Burt told Parliament

in February 2012 that the Fordow facility “which Iran initially kept secret from the IAEA, also

131 “AEOI Spokesman: Iran Capable of Producing Stable Isotopes Without Russia’s Help,” Fars News Agency,

December 9, 2019.

132 “Q&A on the Qom Enrichment Facility,” September 25, 2009, available at

https://www.iranwatch.org/sites/default/files/us-wh-qomqandas-0909.pdf.

133 A 2011 Fact Sheet from the State Department indicates that construction on the facility began as early as 2006 (U.S.

Department of the Treasury, “Fact Sheet: E.O. 13382 Designations on Iran,” November 21, 2011).

134 “Q&A on the Qom Enrichment Facility,” September 25, 2009.

135 GOV/2009/74.

136 Majlis speaker Ali Larijani, who was formerly Iran’s lead nuclear negotiator, indicated that Iran had been

constructing the facility for approximately three years. (“Iran Speaker Says Country has Fully Mastered Nuclear

Technology,” Islamic Republic News Agency, September 27, 2009.)

137 “Q&A on the Qom Enrichment Facility,” September 25, 2009.

138 Ibid. Such estimates depend on several variables, including the number and type of centrifuges used, as well as the

degree to which the uranium hexafluoride feedstock is enriched. This particular estimate appears to assume the use of

3,000 IR-1 centrifuges; the other assumed parameters are unclear. For more information on the facility’s potential

weapons-grade HEU production capability, see Iran’s Nuclear, Chemical and Biological Capabilities: A Net

Assessment, February 2011, p. 67.

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raises our concerns that there may also be other, undeclared sites in Iran that could be engaged in

work” related to nuclear weapons.139

Tehran’s shifting explanations regarding the facility’s purpose also raised concerns that Iran

would, in the future, use the facility to produce fissile material for nuclear weapons. Iran’s 2009

letter to the IAEA described the Fordow facility as a “new pilot fuel enrichment plant” that would

produce uranium enriched to no higher than 5% uranium-235. Tehran subsequently changed the

plant’s stated purpose several times. For example, Tehran, as noted, later told the IAEA that the

facility would be configured to produce both uranium enriched to 5% uranium-235 and 20%

uranium-235. Apparently suggesting that Iran might later produce uranium containing higher

levels of uranium-235, a U.S. official told the IAEA Board of Governors on March 8, 2012, that

“[w]e cannot help but wonder ... whether Iran has finally informed us of the ultimate purpose of

this facility.”140

For its part, Iran has asserted that the facility is for peaceful purposes and that the government has

acted in accordance with its international obligations. As noted, Tehran argued that it was

producing enriched uranium containing up to 20% uranium-235 for use as fuel in research

reactors, to be used to produce isotopes for medical purposes. Regarding the facility’s secret

nature, Iranian officials argued that Tehran was not previously obligated to disclose it to the

IAEA141 and stated on several occasions that the facility was concealed to protect it from military

attacks.142 Iran told the IAEA in 2009 that the Fordow facility was to serve as a “contingency

enrichment plant, so that the enrichment activities shall not be suspended in the case of any

military attack.”143 The Natanz commercial facility “was among the targets threatened with

military attacks,” Iran explained.144 Iranian officials stated during a June 2012 meeting with the

P5+1 that the Fordow facility is “not a military base” and is “not located on a military base.”145

Enriched Uranium Containing Nearly 20% Uranium-235

As noted, Iran argued that it was producing LEU containing nearly 20% uranium-235 for use in

research reactors; as of January 20, 2014, when the Joint Plan of Action (JPA) went into effect,

Tehran had used the Natanz pilot facility and the Fordow facility to produce a total of 447.8

kilograms of uranium hexafluoride containing up to 20% uranium-235.146 Iran’s production of

uranium enriched to this level has caused concern because such production requires

approximately 90% of the effort necessary to produce weapons-grade HEU, which contains about

90% uranium-235.147 If further enriched, this amount of material would have been sufficient for a

139 “Written Answers to Questions,” Daily Hansard, February 7, 2012.

140 “U.S. Statement to the Board of Governors on Iran,” March 8, 2012.

141 For more information, see CRS Report R40094, Iran’s Nuclear Program: Tehran’s Compliance with International

Obligations, by Paul K. Kerr.

142 See, for example, “Iranian Nuclear Negotiator Says 5+1 Talks ‘Positive,’” Islamic Republic of Iran News Network,

October 1, 2009.

143 GOV/2009/74.

144 Ibid.

145 “Full Text of Iran’s Proposals to Six World Powers in Moscow Talks,” Fars News Agency, July 7, 2012. Rouhani

argued in February 2005 that Iran could enrich uranium “under mountains,” explaining that “[i]f we go there, no

American bomb or missile can be effective.” “Iranian Official Rowhani Gives Interview, Discusses Talks With EU,

Criticizes U.S.,” Tehran Vision of the Islamic Republic of Iran Network 2, February 7, 2005.

146 GOV/2014/10.

147 Former IAEA Deputy Director General Olli Heinonen, “Dealing with a Nuclear Iran: Redlines and Deadlines,”

Center for Strategic and International Studies, February 6, 2013; U.S. Secretary of Energy Ernest Moniz, Senate

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nuclear weapon. Iran would need approximately 215 kilograms of uranium hexafluoride

containing 20% uranium-235 to produce approximately 27.8 kilograms of uranium containing

90% uranium-235—a sufficient amount of weapons-grade HEU for a nuclear weapon.148 This is a

conservative estimate; the specific characteristics of Iran’s enrichment facilities may necessitate

using more than 215 kilograms of such material. Then-Director of National Intelligence James

Clapper suggested during a February 16, 2012, Senate Armed Services Committee hearing that “a

number of factors” could impede Tehran’s ability to produce weapons-grade HEU from uranium

enriched to 20% uranium-235.149

As of January 20, 2014, approximately 160 kilograms of the LEU described above was in the

form of uranium hexafluoride and, therefore, available to be further enriched in the near term.150

Since that date, Iran has either converted much of that material for use as fuel in the Tehran

Research Reactor or prepared it for that purpose.151 Iran diluted the rest of that stockpile so that it

contained no more than 5% uranium-235. AEOI spokesperson Kamalvandi said in February 2014

that Iran had “the necessary reservoirs of fuel for 5 years for the Tehran research reactor.”152

Future Centrifuge Facilities

Iranian officials indicated in the past that Tehran intended to construct 10 additional centrifuge

plants—a goal that many analysts argued was virtually unachievable. Then- Atomic Energy

Organization (AEOI) President Ali Akbar Salehi stated in 2009 that Iran is investigating locations

for the sites. (Salehi was president of the organization from 2009 to 2010; he became president

again in August 2013.)153 In 2012, then-AEOI President Abbasi argued that “mastering”

centrifuge enrichment technology would enable Iran to “develop [centrifuge] sites in various

locations to avoid any threat by foreign enemies.” According to the JCPOA, Iran is to enrich

uranium only at the Natanz commercial facility for 15 years.154 Expiration of the agreement’s

enrichment restrictions will be “followed by gradual evolution, at a reasonable pace” of Iran’s

enrichment program. According to the JCPOA, Iran’s centrifuge-testing program may proceed

under strict limits, which will begin to ease approximately eight years after the beginning of the

agreement’s implementation. An AEOI spokesperson stated in January 2016 that Iran’s nuclear

Committee on Armed Services, “Impacts of the Joint Comprehensive Plan of Action (JPCOA) on U.S. Interests and the

Military Balance in the Middle East,” July 29, 2015.

148 This number of nuclear weapons assumes that 25 kilograms of uranium-235 (approximately 27.8 kilograms of

uranium containing 90% uranium-235) would be necessary for one HEU-based nuclear weapon. The IAEA term for

this amount of uranium is “significant quantity,” defined as the “approximate amount of nuclear material for which the

possibility of manufacturing a nuclear explosive device cannot be excluded.” Some types of weapons could be

developed using less uranium-235.

149 “Current and Future Worldwide Threats to the National Security of the United States,” Senate Armed Services

Committee, February 16, 2012.

150 GOV/2014/10. In addition to the 43 kilograms of this material that is being prepared for use as fuel, Iran has altered

another 1.6 kilograms of the material, which now contains less than 5% uranium-235.

151 This process has generated scrap that contains LEU with up to 20% uranium-235. Iran also retains 0.6 kilograms of

uranium hexafluoride containing up to 20% uranium-235, which “had been used as reference material for mass

spectrometry” (Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council

resolutions in the Islamic Republic of Iran, Report of the Director General, International Atomic Energy Agency,

GOV/2015/34, May 29, 2015).

152 Sara Massoumi, Hamed Shafiei, “20% Enrichment Is Not Iran’s Need Today,” Iranian Diplomacy, February 8,

2014.

153 Fars News Agency, December 18, 2009.

154 After 10 years Iran may produce enriched uranium at the pilot centrifuge facility as part of R&D work.

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program “will begin to accelerate from the 13th or 14th year onwards,”155 adding that Tehran plans

to increase its enrichment capacity by approximately “20-fold” by the end of the 15th year.156 Iran

plans to produce enough enriched uranium to fuel five or six nuclear reactors, Deputy Foreign

Minister Araqchi stated in August 2015.157

AEOI spokesperson Kamalvandi explained in June 2018 that Iran would begin the process of

“manufacturing and assembly of centrifuge rotors,” which are critical components of such

machines.158 Iran “will begin building a centrifuge rotor plant,” he noted.159 In addition, Salehi

announced in June that Iran has completed building a centrifuge assembly center in the Natanz

facility; Tehran had not previously disclosed this facility publicly.160 The facility’s completion

“does not mean that we are going to produce these centrifuges now,” Salehi said in September

2018, adding that the facility provides Iran with the capability to mass-produce such centrifuges,

should the government decide to do so.161 Feruță’s November 2019 report indicates that Tehran is

manufacturing centrifuges in violation of the JCPOA.162

Inconsistent Progress

A senior U.S. intelligence official said in 2007 that a country needs to be able to “operate large

numbers of centrifuges for long periods of time with very small failure rates” in order to be able

to “make industrial quantities of enriched uranium.”163 Iran’s record indicates that the country has

not always met this standard. The 2007 National Intelligence Estimate stated that Iran still faced

“significant technical problems operating” its centrifuges. Although a 2008 report to Congress

submitted by the Deputy Director for National Intelligence described the amount of LEU that Iran

produced in 2008 as a “significant improvement” over the amount it had produced during the

previous year,164 data from an August 2015 Institute for Science and International Security report

indicate that the average per-centrifuge performance at that facility peaked in 2010 and

subsequently fluctuated.165

The extent to which Iran’s progress is sustainable is open to question. Former Pakistani nuclear

official Abdul Qadeer Khan described Pakistan’s first-generation centrifuges as “unsuccessful” in

155 Specifically, the JCPOA states that “Iran will commence, upon start of implementation of the JCPOA,” testing of

Iran’s IR-6 and IR- 8 centrifuges “on single centrifuge machines and its intermediate cascades and will commence the

testing of up to 30 centrifuges machines from one and a half years before the end of year 10. Iran will proceed from

single centrifuges to small cascades to intermediate cascades in a logical sequence.”

156 Interview with Behruz Kamalvandi, January 11, 2016.

157 “AEOI: Iran Starts Injecting UF6 into IR-8 Centrifuges,” Fars News Agency, January 28, 2017.

158 “Nuclear Chief: Iran To Start New Centrifuge Production In Natanz Tomorrow,” Fars News Agency, June 5, 2018.

159 “Iran to Inform IAEA of Plan to Boost Enrichment —Fuller Report,” Iranian Students’ News Agency, June 4, 2018.

160 “Iran Completes Facility to Build Advanced Centrifuge,” Islamic Republic of Iran Broadcasting, July 18, 2018.

161 Jon Gambrell and Nasser Karimi, “AP Interview: Iran Nuclear Chief Hopes Deal Will Survive,” The Associated

Press, September 11, 2018.

162 GOV/2019/55. Specifically, Iran has produced components to “manufacture centrifuges … for activities beyond

those specified in the JCPOA, such as the installation of the new cascades” at the Natanz Pilot Facility.

163 Background briefing with senior intelligence officials, December 3, 2007.

164 Unclassified Report to Congress on the Acquisition of Technology Relating to Weapons of Mass Destruction and

Advanced Conventional Munitions, Covering 1 January to 31 December 2008.

165 David Albright, Serena Kelleher-Vergantini, Andrea Stricker, and Daniel Schnur, ISIS Analysis of the IAEA Iran

Safeguards Report, Institute for Science and International Security, August 27, 2015. Calculating the average

performance of Iran’s centrifuges became more difficult after November 2010, when the IAEA stopped reporting

information about the Natanz commercial facility’s average product enrichment level.

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a 1998 interview.166 Furthermore, Mark Fitzpatrick of the International Institute for Strategic

Studies observed that “[i]t can be years before it is clear whether an enrichment programme is

working well,” observing that centrifuges at a Japanese enrichment facility “started to crash seven

years after installation.”167 And, as noted, Iran has struggled to develop and deploy moreadvanced centrifuges. Nevertheless, historical experience indicates that sustained operation of gas

centrifuges appears to be a manageable task for governments with even modest technical

capabilities.168 According to a U.S. Nuclear Regulatory Commission document, some centrifuges

of simple design “have operated 30 years with a failure rate of less than one percent.”169 (See also

“Effects of Sanctions and Sabotage on Iran’s Enrichment Program.”)

Uranium Conversion

As noted, uranium conversion is a process whereby uranium ore concentrate is converted into

several compounds, including uranium hexafluoride—the feedstock for Iran’s centrifuges. Iran

produced approximately 541 metric tons of uranium hexafluoride between March 2004 and

August 10, 2009, using both imported uranium ore concentrate and domestically produced

uranium ore concentrate.170 Iran has not produced any uranium hexafluoride since August 2009,

according to IAEA reports, although Tehran has transferred domestically produced uranium ore

concentrate to the uranium conversion facility. The 2012 U.N. Panel of Experts report concluded

that, based on data from Amano’s February 2012 report, Iran had “an ample supply of uranium

hexafluoride to maintain current levels of enrichment for the foreseeable future.”171 On June 27,

2018, Iran’s official news agency announced that Iran has resumed operations at the conversion

facility.172

According to a report from the Director of National Intelligence to Congress covering 2011, Iran

had “almost exhausted” its supply of imported uranium ore concentrate.173 Tehran apparently did

not import any more such material prior to December 2015. According to the 2012 U.N. Panel of

Experts report, “a number” of governments believed that Tehran was “seeking new sources of

uranium ore to supply its enrichment efforts”; the report added that “the Panel is not aware of any

confirmed cases of actual transfers.”174 British Foreign and Commonwealth Office official Tobias

Ellwood informed Parliament in June 2015 that the British government was “not aware of” any

166 “A Talk with A.Q. Khan: Pakistan’s Top Nuclear Scientist Talks About Nuclear Weapons,” Jane’s Foreign Report,

July 24, 1998.

167 Mark Fitzpatrick, The Iranian Nuclear Crisis: Avoiding Worst-Case Outcomes, Adelphi Paper 398, International

Institute for Strategic Studies, May 2008, p. 50.

168 R. Scott Kemp, “The Nonproliferation Emperor Has No Clothes: The Gas Centrifuge, Supply-Side Controls, and the

Future of Nuclear Proliferation,” International Security, Spring 2014, vol. 38, no. 4, pp. 39-78.

169 USNRC Technical Training Center: Uranium Enrichment Processes, Module 4.0 of the Uranium Enrichment

Processes Directed Self-Study Course 9/08 (Rev 3), Directed Self Study. The document appears to have been published

in 2008.

170 Based on data from GOV/2009/74. Iran imported 531 metric tons of uranium ore concentrate in 1982, according to

Implementation of the NPT Safeguards Agreement in the Islamic Republic of Iran, Report by the Director General,

GOV/2003/75, November 10, 2003.

171 Panel of Experts, 2012.

172 “Iran UF6 Factory Resumes Work,” Islamic Republic News Agency, June 27, 2018.

173 Unclassified Report to Congress on the Acquisition of Technology Relating to Weapons of Mass Destruction and

Advanced Conventional Munitions, Covering 1 January to 31 December 2011.

174 Panel of Experts, 2012.

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recent reports that Iran had attempted to purchase foreign uranium.175 Former State Department

official Richard Nephew wrote in September 2015 that there had “not been any verified transfer

of uranium to Iran aside from fuel for the Bushehr power reactor.”176 In late December 2015, Iran

imported between 200 and 220 metric tons of uranium ore concentrate in exchange for LEU that

Iran shipped to Russia in order to reduce its stockpile to JCPOA-required levels.177 The IAEA

verified Iran’s receipt in February 2017 of approximately 125 metric tons of uranium ore

concentrate.178 During March 2017, Iranian officials stated that the country had imported between

382 and 384 metric tons of this material since concluding the JCPOA.179 The imported uranium

ore concentrate is to serve as fuel for the Bushehr reactors, according to Iranian officials.180

Prior to 2009, Tehran apparently improved its ability to produce centrifuge feedstock of sufficient

purity for light-water reactor fuel; information in a 2010 IAEA report indicated that Iran was

purifying its centrifuge feedstock.181 Whether Iran is currently able to produce feedstock pure

enough for weapons-grade HEU is unclear, however.

Plutonium

Iran acknowledged to the IAEA in 2003 that it had conducted plutonium-separation

experiments—an admission that contributed to suspicions that Iran could have a program to

produce plutonium for nuclear weapons. The IAEA, however, continued to investigate the matter;

then-IAEA Director-General ElBaradei reported in August 2007 that the agency had resolved its

questions about Iran’s plutonium activities.182 As noted above, Iran has said that it does not plan

to engage in reprocessing, and then-IAEA Director-General Amano’s November 2011 report

described an “absence of any indicators that Iran is currently considering reprocessing irradiated

nuclear fuel to extract plutonium.”183 Amano’s November 2015 report states that the agency could

“confirm that there are no ongoing reprocessing related activities” at the Iranian facilities to

which the agency has access.184

175 Iran: Nuclear Weapons: Written Question-1913. Answered by Tobias Ellwood on June 15, 2015.

176 Richard Nephew, “How the Iran Deal Prevents a Covert Nuclear Weapons Program,” Arms Control Today,

September 2015.

177 Interview with Behruz Kamalvandi, January 11, 2016. “Atomic Chief: Iran Completes Swap of Surplus Enriched

Uranium with Russia,” Vision of the Islamic Republic of Iran Network,” December 29, 2015; Secretary of State John

Kerry,” Arms Control and International Security: An Update on Progress Toward Implementation Day of the JCPOA,”

December 28, 2015.

178 GOV/2017/10.

179 “Iran Plans to Buy 950 Tonnes of Yellowcake from Kazakhstan: Salehi,” IRIB News Agency, March 7, 2017; “Iran’s

Atomic Chief Calls Critics of Nuclear Deal ‘Unfair,’” IRIB News Agency, March 10, 2017.

180 “Iran to Use Russian Yellow Cake at Esfahan, Bushehr Sites—Official,” Iranian Young Journalists’ Club Website,

February 26, 2017.

181 IISS Strategic Comments, “Nuclear Iran: How Close Is It?,” September 2007; Paul Kerr, “Iran Continues Security

Council Defiance,” Arms Control Today, June 2007; analyst interview with State Department official October 28,

2008. Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions 1737

(2006), 1747 (2007), 1803 (2008) and 1835 (2008) in the Islamic Republic of Iran, Report by the Director General,

GOV/2010/28, May 31, 2010. A footnote in the report states that some enriched uranium hexafluoride “was present in

the feed purification cylinder.”

182 Implementation of the NPT Safeguards Agreement in the Islamic Republic of Iran, Report by the Director General,

GOV/2007/48, August 30, 2007.

183 GOV/2011/65.

184 Ibid.

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The JCPOA prohibits Iran from reprocessing spent reactor fuel, except to produce “radio-isotopes

for medical and peaceful industrial purposes.” The JCPOA text states that Iran “does not intend”

to engage in reprocessing after the 15-year period expires and specifies Iran’s intention to

ship out all spent fuel for all future and present nuclear power and research reactors, for

further treatment or disposition as provided for in relevant contracts to be concluded

consistent with national laws with the recipient party.

According to the IAEA, Iran has adhered to this requirement.

Arak Reactor and Redesign185

Iran says that its reactor under construction at Arak is intended for the production of medical

isotopes and various other purposes. According to a 2008 presentation by Ambassador Soltanieh,

the reactor, which was originally designed to be moderated by heavy water, is to substitute for the

“outdated” Tehran Research Reactor (TRR), which has been in operation since 1967.186 As noted,

Iran subsequently decided to refuel the TRR. According to a 2012 AEOI report, the reactor has

several objectives:

a suitable replacement for the aging Tehran Research Reactor using local

engineers and scientist [sic] with the least dependency to foreign countries;

medical, industrial and research radioisotope production of [sic] the country;

performing research in the fields of neutron physics, reactor chemistry, thermalhydraulics, and health physics;

obtaining technological and scientific experience in design and construction of

nuclear reactors using local experts within the country;

training of specialists in the nuclear field; and

enhancing the technological levels of the local industries in design and

manufacturing of various components such as reactor vessels, heat exchangers,

pumps, etc. using nuclear standards.187

Iran told the IAEA in 2012 that the reactor was scheduled to begin operating during the second

half of 2013.188 The project was about 75% complete as of July 2011.189 Iran suspended several

aspects of the reactor’s construction pursuant to the 2013 Joint Plan of Action.190

The originally designed Arak reactor was a proliferation concern because its spent fuel would

have contained plutonium better suited for nuclear weapons than the plutonium produced by

light-water moderated reactors, such as the TRR and Bushehr reactor. The original Arak reactor, if

it had been completed, could have produced enough plutonium for between one and two nuclear

185 Iran informed the IAEA in April 2017 that Tehran was renaming the facility the “Khondab Heavy Water Research

Reactor.” (Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council

Resolution 2231 [2015], Report by the Director General, International Atomic Energy Agency, GOV/2017/24, June 2,

2017).

186 “Iran’s Exclusively Peaceful Nuclear Programs and Activities,” Briefing for NGOs, May 5, 2008.

187 Nuclear Industry in Iran: An Overview on Iran’s Activities and Achievements in Nuclear Technology, Atomic

Energy Organization of Iran, 2012, p. 29.

188 GOV/2012/23.

189 Nuclear Industry in Iran, p. 29.

190 Iran pledged to refrain from commissioning the reactor, transferring fuel or heavy water to the reactor site, testing

and producing additional reactor fuel, and installing remaining reactor components.

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weapons per year.191 In addition, Iran would have been able to operate the reactor with natural

uranium and, therefore, would not have been dependent on supplies of enriched uranium.

The JCPOA requires Tehran to render the Arak reactor’s original core inoperable. Iran has met

this requirement.192 According to former U.S. officials Eric Brewer and Richard Nephew, “the

path to actually completing and starting” the Arak reactor according to its previous design “would

be a long and uncertain one.”193 The agreement also commits Tehran to redesign and rebuild the

Arak reactor based on a design agreed to by the P5+1 so that the reactor will not produce

weapons-grade plutonium. Tehran is “trying to complete the project in five years,” an AEOI

spokesperson said in January 2016.194 AEOI President Salehi stated in September 2016 that China

will supply the reactor’s first fuel load “in the next five-year time.”195 Iran will subsequently

produce the reactor fuel, he said. Iran is to export the spent fuel from this reactor and all other

nuclear reactors. In addition, the JCPOA requires Iran to refrain from building heavy-watermoderated reactors for 15 years, and Tehran has pledged to refrain from constructing any such

reactors indefinitely.

According to IAEA reports and Iranian officials, Iran began to operate its heavy-water production

plant located near Arak in August 2006.196 IAEA reports since the start of JCPOA implementation

indicate that the plant, which is to produce heavy water for the reactor and deuterated solvents, is

operating.197 Pursuant to the JCPOA, Tehran has committed to refrain from accumulating heavy

water “beyond Iran’s needs.” Iran is to “sell any remaining heavy water on the international

market for 15 years.” According to the agreement, these “needs” are 130 metric tons of “nuclear

grade heavy water or its equivalent in different enrichments” prior to commissioning the

redesigned Arak reactor and 90 metric tons after the reactor is commissioned.198

Iran’s stock of heavy water has exceeded 130 metric tons on three occasions since the JCPOA

began implementation. On February 17, 2016, the IAEA verified that Tehran’s heavy-water stock

had exceeded 130 metric tons; on November 8, 2016, the IAEA verified that Iran’s stock of heavy

water had again exceeded the JCPOA limit. Iran resolved the issue on both occasions by

exporting the excess heavy water. Tehran sent this material to Russia and the United States,

shipping at least some of it via Oman.199 Iran told the IAEA on June 18, 2017, that it had

transferred 19.1 metric tons of heavy water to a destination outside the country.200 According to

191 Colin Kahl, Deputy Assistant to the President and National Security Adviser to the Vice President, “Arms Control

Association Annual Meeting: Unprecedented Challenges for Nonproliferation and Disarmament,” May 14, 2015.

192 GOV/INF/2016/1.

193 Eric Brewer and Richard Nephew, “Seeing Red in Trump’s Iran Strategy,” Arms Control Today, July/August 2019.

194 Interview with Behruz Kamalvandi, January 11, 2016.

195 IRTV2, September 10, 2016.

196 “‘Peaceful’ Iran Has a Transparent Nuclear Program: Ahmadinejad; Arak Heavy Water Plant Launched,” Mehr

News Agency, August 26, 2006; “Iran’s Heavy Water Research Reactor Project on Track, Says Official,” Fars News

Agency, August 26, 2006. A 2005 IAEA report (GOV/2005/67) describes the plant as “currently being commissioned”;

a 2007 IAEA report (GOV/2007/8) states that the plant is operational.

197 Nuclear Industry in Iran, p. 27.

198 The plant has a “maximum annual capacity” of 20 metric tons, Iran informed the IAEA in 2017. A special assistant

to AEOI President Salehi asserted in October 2019 that the facility can produce “up to 25” metric tons of heavy water

annually (“Secondary Circuit of Iran’s Arak Nuclear Reactor to Be Operational Within Two Weeks: Official,” Reuters,

October 20, 2019).

199 Iran has also shipped “a smaller amount to other countries,” a spokesperson for Iran’s Atomic Energy Organization

said in March 2018 (“Iran to Unveil ‘Heavy Water Achievements’ on 9 April,” Fars News Agency, March 26, 2018).

200 Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution

2231 (2015), Report by the Director General, International Atomic Energy Agency, GOV/2017/35, August 31, 2017.

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an April 2018 State Department report covering 2017, “[m]ost Iranian excess heavy water has

been sold and delivered to international buyers; the remainder is awaiting sale and is stored in a

location outside Iran, under IAEA seal, though it remains Iranian property.”201 Tehran has

continued to ship heavy water outside Iran.202 The IAEA verified on November 17, 2019, that Iran

had 131.5 metric tons of heavy water.203

Bushehr Reactor

Iran is also operating a 1,000-megawatt nuclear power reactor, moderated by light water, near the

city of Bushehr. The original German contractor, which began constructing the reactor in 1975,

abandoned the project following Iran’s 1979 revolution.204 Russia agreed in 1995 to complete the

reactor, but the project subsequently encountered repeated delays; both Russian and Iranian

officials attributed those delays to technical issues. In February 2005, Moscow and Tehran

concluded an agreement stating that Russia would supply fuel for the reactor for 10 years.

Atomstroyexport, a subsidiary of Rosatom, the Russian company, sent the first shipment of LEU

fuel to Iran on December 16, 2007, and the reactor received the last shipment near the end of

January 2008. The fuel, which is under IAEA seal, will contain no more than 3.62% uranium-235,

according to an Atomstroyexport spokesperson.205 An August 2014 IAEA inspection revealed that

the reactor “was operating at 100% of its nominal power.”206

Before 2002, the United States had urged Moscow to end the project, citing concerns that it could

aid an Iranian nuclear weapons program by providing the country with access to nuclear

technology and expertise.207 However, U.S. officials said in 2002 that Washington would drop

these public objections if Russia took steps to mitigate the project’s proliferation risks. The 2005

deal requires Iran to return the spent nuclear fuel to Russia.208 This measure is designed to ensure

that Tehran will not separate plutonium from the spent fuel. Moscow argues that the reactor will

The report does not name the heavy water’s destination.

201 Adherence to and Compliance with Arms Control, Nonproliferation, and Disarmament Agreements and

Commitments, Department of State, April 2018.

202 Verification and Monitoring in the Islamic Republic of Iran in Light of United Nations Security Council Resolution

2231 (2015), Report by the Acting Director General, GOV/INF/2019/17, November 18, 2019; GOV/2019/55.

203 GOV/INF/2019/17.

204 The contractor, Kraftwerk Union, completed about 85% of the first reactor and 55% of the second (“Iran’s Nuclear

Ambitions: Persistence Despite Manpower Problems,” Central Intelligence Agency Directorate of Intelligence, October

1986).

205 “Atomstroyexport Completes Latest Shipment of Fuel to Bushehr Nuclear Plant,” Interfax, December 28, 2007.

206 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions in the

Islamic Republic of Iran, Report by the Director General, GOV/2014/43, September 5, 2014.

207 For example, then-Deputy Assistant Secretary of Defense Marshall Billingslea testified before the Senate on July

29, 2002, that the United States was “concerned that the Bushehr nuclear power project is, in reality, a pretext for the

creation of an infrastructure designed to help Tehran acquire atomic weapons.” Similar concerns are expressed in a

2005 State Department report (Adherence to and Compliance with Arms Control, Nonproliferation, and Disarmament

Agreements and Commitments, U.S. Department of State, August 2005, p.77.) Then-Under Secretary of State for

International Security and Arms Control John Bolton told the House International Relations Committee in June 2003

that Iran could build “over 80 nuclear weapons” if it had access to sufficient fuel, operated the reactor for five to six

years, and chose to withdraw from the NPT. During a June 12, 2008, House Foreign Affairs Committee hearing, thenActing Under Secretary of State for Arms Control and International Security John Rood agreed with a Department of

Energy assessment that the reactor’s spent fuel would contain enough plutonium for between 50 and 60 nuclear

weapons. These estimates assume that Iran possesses a reprocessing facility, which the country does not have.

208 Estimates for the length of time the spent fuel must stay in Iran to cool range from two to five years. See Paul Kerr,

“Iran, Russia Reach Nuclear Agreement,” Arms Control Today, April 2005.

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not pose a proliferation risk because it will operate under IAEA safeguards. It is worth noting that

light-water reactors are generally regarded as more proliferation-resistant than other types of

reactors. Although the U.N. Security Council resolutions restricted the supply of nuclear-related

goods to Iran, they did permit the export of nuclear equipment and fuel related to light-water

reactors.

Experts have expressed strong doubts regarding Iran’s ability to produce fuel for the reactor.209

According to a July 2014 Iranian government report, Russia and Iran may renew the fuel supply

agreement, but they are also “engaged in negotiations ... to engage in cooperative arrangements

for the domestic manufacturing of fuel for the facility after the expiration of the current

contract.”210 According to an interview published in April 2017, AEOI Deputy Director Pezhman

Rahimian stated that the two governments had almost completed a “road map” for such

manufacturing.211

Possible Future Reactors

Iran and Russia signed a contract in November 2014 for the construction of two additional lightwater nuclear power reactors in Bushehr, according to Rosatom, the Russian company.212 The

project’s construction began in September 2016 and is expected to take 10 years to complete.213 A

Rosatom official told the IAEA General Conference in September 2018 that “[p]ractical work to

build the second and third” Bushehr power plant units “has begun.”214 These reactors are to be in

operation by 2025 and 2027.”215

Iran was also “negotiating with China for building two 100 megawatt power plants,” Salehi

stated in a July 2015 speech.216 Iran informed the IAEA in an October 2017 letter that Tehran had

decided to “design and construct a critical facility (Light Water Critical Reactor) … for research

purposes in near future.” Iran “provided preliminary design information for the facility,” which

indicates that the reactor fuel is to contain “up to 3.67%” uranium-235.217

209 See, for example, Robert Einhorn, “Will Iran Play Ball in Nuke Talks?,” The National Interest, January 14, 2015.

210 What Are Iran’s “Practical Needs”?, NuclearEnergy.ir, July 2014.

211 Hadi Mohammadi: “Tehran Reactor's Fuel Is Entirely Made in Iran; Country's Yellow Cake Stockpile Has

Doubled,” Khorasan, April 8, 2017.

212 “The Foundation Stone Ceremony Held on the Bushehr Phase II Construction Site (Iran),” Communications

Department of ROSATOM, September 13, 2016. Available at http://tinyurl.com/jsc9z89.

213 Ibid. “Inauguration of Two New Power Plant Units Construction in Bushehr,” Atomic Energy Organization of Iran,

September 18, 2016. Available at http://tinyurl.com/h7bl7jl.

214 “Rosatom Starts Work at third Bushehr NPP Unit in Iran,” Interfax, September 17, 2018.

215 “Iran’s Two New Power Plant Units to Be Operational by 2027,” Vision of the Islamic Republic of Iran Network 1,

November 10, 2019. The second reactor “is scheduled to come on stream in 6 years, while the third unit will be

finished in 8 years,” according to a November Fars News Agency report (Iran’s Nuclear Electricity Capacity to Hit

3000 MW by 2027,” Fars News Agency, November 10, 2019).

216 “Excerpts of the Speech Presented by H.E Dr. A.A.Salehi, President’s Deputy and Head of AEOI in the Presence of

Organization’s Personnel,” July 20, 2015. Available at http://tinyurl.com/gllptz5.

217 GOV/2007/48.

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Fuel Manufacturing Facilities

Iran intended its fuel manufacturing plant to produce fuel for the Arak and Darkhovin reactors.218

The plant started the process of producing fuel for the pre-JCPOA Arak reactor.219 Iran’s Fuel

Plate Fabrication Plant has produced fuel for the Tehran Research Reactor.220

Uranium Mines and Mills

Iran has a uranium mill and a uranium mine located at a site called Bandar Abbas, which is

sometimes referred to as Gchine. Iran also has a uranium mine at a site called Saghand and an

associated uranium mill called the Ardakan Yellowcake Production Plant. Salehi stated in a

January 30, 2019, interview that Tehran plans to construct several more such mills. Iranian

officials acknowledge that the country’s uranium deposits are insufficient for its planned nuclear

power program.221 These reserves are sufficient, however, to produce 250-300 nuclear weapons,

according to a past U.S. estimate.222 Salehi indicated in February 2019 that Iran continues to

explore for uranium.223

Effects of Sanctions and Sabotage on Iran’s

Enrichment Program

A number of governments employed sanctions and, apparently, sabotage to impede Iran’s nuclear

program.

Sanctions

Iran has tried to improve its capabilities to produce materials and components for its centrifuge

program, according to former IAEA Deputy Director General Olli Heinonen.224 Some Iranian

officials have claimed that the country can manufacture centrifuges on its own. For example,

then-Iranian Ambassador to the IAEA Ali Asghar Soltanieh said in 2012 that Iran “has ‘fully

mastered’ the nuclear energy technology and can produce all the 90 pieces of a centrifuge

machine on its own and without foreign assistance.”225 However, other Iranian officials have

suggested that Tehran is not yet able to produce all of the necessary centrifuge components. ThenPresident of Iran’s Atomic Energy Organization Abbasi stated during a 2012 television broadcast

that “Iran could not claim that it did not need other countries” for its enrichment program, adding

that “domestic production of all items was not economically viable.”226 AEOI Director Salehi

218 “Aqazadeh: Iran Heralds Peaceful Nuclear Program,” Islamic Republic News Agency, April 8, 2008.

219 GOV/2015/65.

220 Ibid.

Installation of Centrifuges Continues in Natanz—Iran Nuclear Official,” Iranian Students’ News Agency, April 17,

2007; Thomas W. Wood, Matthew D. Milazzo, Barbara A. Reichmuth, and Jeffrey Bedell, “The Economics Of Energy

Independence For Iran,” Nonproliferation Review, vol. 14, No. 1, March 2007.

222 Paul Kerr, “Iran Nuclear Abilities Limited,” Arms Control Today, September 2005.

223 “Iran Opens Heavy Oxygen Isotope Plant,” FARS News Agency, February 5, 2019.

224 Analyst interview, January 18, 2012.

225 “Nuclear Official Stresses Iran’s Domestic Capability to Produce Centrifuge Machines,” FARS News Agency,

December 3, 2012.

226 “Nuclear Chief Says West Aware of Significance of Iran Achievements,” Vision of the Islamic Republic of Iran

221

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stated in 2014 that Iran was purchasing some items for its nuclear program “from some

developing and growing Eastern countries.”227

Non-Iranian sources also cast doubt on the self-sufficiency claims described above. A 2014 U.N.

Panel of Experts report observed that the “quality of such [Iranian-produced] equipment is not

known.”228 Moreover, then-Principal Deputy Assistant Secretary of State for International

Security and Nonproliferation Vann Van Diepen said that Iran in 2014 was still attempting to

“procure items” for the nuclear program.229 Nevertheless, according to the 2014 Panel of Experts

report, several governments told the panel that, since mid-2013, there had been a “been a decrease

in the number of detected [Iranian] attempts ... to procure items for prohibited programmes, and

related seizures.”230 A 2015 Panel of Experts report states that the panel had not “identified cases

of procurement for activities prohibited” by Security Council resolutions in force at the time.231

No governments reported any such cases, the report adds. It is worth noting that a special

assistant to AEOI President Salehi asserted in October 2019 that “[o]ne-hundred percent of Iran's

nuclear industry activities have been indigenized and today, we are self-sufficient in designing

and manufacturing various kinds of centrifuges”232

According to various sources, international sanctions complicated Iranian efforts to obtain

components and materials for its centrifuge program. For example, the U.N. Panel of Experts

2011 report stated that “sanctions are constraining Iran’s procurement of items related to

prohibited nuclear and ballistic missile activity and thus slowing development of these

programmes.”233 Similarly, the 2012 U.N. Panel of Experts report observed that “[s]anctions are

slowing the procurement by the Islamic Republic of Iran of some critical items required for its

prohibited nuclear programme.”234 A June 2013 report from the same panel suggested that this

condition still existed, arguing that “Iran’s reliance on procurement abroad continues to provide

the international community with opportunities to limit Iran’s ability to maintain and expand

certain activities.”235 Then-UK Foreign Secretary William Hague wrote in 2013 that “[w]e judge

that sanctions have been effective in slowing the nuclear programme to some degree.”236

U.S. officials have argued that the sanctions have impeded Iran’s ability to acquire technology for

its nuclear programs. Then-State Department Special Advisor for Nonproliferation and Arms

Control Robert Einhorn told a Washington audience in 2011 that “[w]e believe Iran has had

difficulty in acquiring some key technologies and we judge this has had an effect of slowing some

of its programs.”237 Similarly, then-National Security Adviser Tom Donilon argued in 2011 that

“[s]anctions and export control efforts have made it more difficult and costly for Iran to acquire

Network 2, February 15, 2012.

227 “Some in East Colluding with West in Iran Nuclear Sabotage: AEOI,” Press TV, August 25, 2014.

228 Final Report of the Panel of Experts Established Pursuant to Resolution 1929 (2010), June 11, 2014.

229 William Maclean, “Iran Pursuing Banned Items for Nuclear, Missile Work: U.S. Official,” Reuters, March 16, 2014.

230 Panel of Experts, 2014.

231 Final Report of the Panel of Experts Established Pursuant to Resolution 1929 (2010), June 2, 2015.

232 “Official: Iran’s Fordow Nuclear Site at Full Swing,” Fars News Agency, October 29, 2019.

233 Panel of Experts Established Pursuant to Resolution 1929 (2010): Final Report, June 2011.

234 Panel of Experts, 2012.

235 Final report of the Panel of Experts Established Pursuant to Resolution 1929 (2010), June 5, 2013.

236 Letter to Richard M. Ottaway MP, May 14, 2013.

237 Robert J. Einhorn, “The Impact of Sanctions on Iran’s Nuclear Program,” Arms Control Association, March 9,

2011.

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key materials and equipment for its enrichment program, including items that Iran can’t produce

itself.”238

However, the extent to which sanctions slowed Tehran’s program is unclear. Donilon also cited

“mistakes and difficulties in Iran” as obstacles to the program’s progress. Former IAEA Deputy

Director General Heinonen stated that “[w]e do not know” whether Iran’s delays in deploying

advanced centrifuges are attributable to “lack of raw materials or design problems,” according to

a 2012 press report.239 Furthermore, reports from the Office of the Director of National

Intelligence covering 2009-2011 stated that “some obstacles slowed” the progress of Iran’s

nuclear program during those years, but the report did not name those obstacles.240

Sabotage

The extent to which alleged efforts by the United States and other governments, including

Israel’s, to sabotage Iran’s centrifuge program have affected Tehran’s nuclear program is unclear.

The New York Times reported in 2009 that such efforts have included “undermin[ing] electrical

systems, computer systems and other networks on which Iran relies,” according to unnamed

senior U.S. and foreign government officials.241 One effort involved foreign intelligence services

sabotaging “individual power units that Iran bought in Turkey” for Tehran’s centrifuge program.

“A number of centrifuges blew up,” according to the Times.242 Western governments have

reportedly made other efforts to sabotage centrifuge components destined for Iran, according to

some nongovernmental experts.243 Iranian officials have asserted that Western countries have

tampered with components in transit to Iran’s enrichment facilities, directly sabotaged those

facilities, and conducted espionage in the country.244 In addition, New York Times reporter James

Risen wrote in 2006 that, according to unnamed U.S. officials, the United States engaged in a

covert operation to provide Iran with flawed blueprints for a device designed to trigger a nuclear

explosion.245

The United States and Israel have also reportedly executed cyberattacks on Iran’s nuclear

facilities. Perhaps the best known of these used the Stuxnet computer worm, which was

discovered in 2010 and probably developed by a government to attack Iran’s enrichment

238 Tom Donilon, “Iran and International Pressure: an Assessment of Multilateral Effort to Impede Iran’s Nuclear

Program,” The Brookings Institution, November 22, 2011.

239 “Iran May Be ‘Struggling’ with New Nuclear Machines,” Reuters, February 28, 2012.

240 Unclassified Report to Congress on the Acquisition of Technology Relating to Weapons of Mass Destruction and

Advanced Conventional Munitions, Covering 1 January to 31 December 2009; Unclassified Report to Congress on the

Acquisition of Technology Relating to Weapons of Mass Destruction and Advanced Conventional Munitions, Covering

1 January to 31 December 2010; Unclassified Report to Congress on the Acquisition of Technology Relating to

Weapons of Mass Destruction and Advanced Conventional Munitions, Covering 1 January to 31 December 2011.

241 David E. Sanger, “U.S. Rejected Aid for Israeli Raid on Nuclear Site,” New York Times, January 11, 2009.

242 David E. Sanger and William J. Broad, “U.S. Sees an Opportunity to Press Iran on Nuclear Fuel,” New York Times,

January 3, 2010. Iranian officials alluded to this incident, according to a January 2007 Iranian press report (Ayande-ye

Now, January 6, 2007).

243 James Blitz, Roula Khalaf, and Daniel Dombey, “Suggestions of Iran Nuclear Sabotage,” Financial Times, July 22,

2010.

244 “Iran Atomic Energy Officials Discuss ‘Thwarted’ Nuclear ‘Sabotage’ Attempts,” Tehran Hamshahri Online,

September 6, 2014. Foreign Minister Zarif stated that there had been no such sabotage since concluding the JCPOA

(“Zarif Series: On the Nuclear Deal, US Relations,” July 19, 2017. Available at

http://iranprimer.usip.org/blog/2017/jul/19/zarif-series-nuclear-deal-us-relations).

245 James Risen, State of War: The Secret History of the CIA and the Bush Administration (New York: Free Press),

2006.

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facilities.246 Some governments have reportedly assassinated Iranians associated with Iran’s

nuclear program.247 The United States also may have obtained information from Iranian officials

who defected as part of a CIA program to induce them to do so.248

Nuclear Weapon Development Capabilities

Statements from the U.S. intelligence community indicate that Iran has the technical capability to

produce nuclear weapons. For example, the 2007 National Intelligence Estimate (NIE) assessed

that “Iran has the scientific, technical and industrial capacity eventually to produce nuclear

weapons if it decides to do so.”249 More recently, then-Director of National Intelligence Clapper

stated during a February 2016 Senate Armed Services Committee hearing that Iran “does not face

any insurmountable technical barriers to producing a nuclear weapon.”250

Obtaining fissile material is widely regarded as the most difficult task in building nuclear

weapons. As noted, Iran is enriching uranium, but whether and to what extent Tehran has taken

the other steps necessary for producing a nuclear weapon is unclear. A 2008 report from former

IAEA Director-General ElBaradei points out that the IAEA, with the exception of a document

related to uranium metal, has “no information ... on the actual design or manufacture by Iran” of

components, nuclear or otherwise, for nuclear weapons.251 However, according to then-IAEA

Director-General Amano’s November 2011 report, the IAEA has “credible” information that Iran

has carried out activities “relevant to the development of a nuclear explosive device.”252 These

include acquisition of “nuclear weapons development information and documentation” and work

to develop “an indigenous design of a nuclear weapon including the testing of components.”

Although some of these activities have civilian applications, “others are specific to nuclear

weapons,” the report notes.253 Most of the report provides additional details about Iranian

activities applicable to nuclear weapons development that were described in previous IAEA

246 David Albright, Paul Brannan, Andrea Stricker, Christina Walrond, and Houston Wood, Preventing Iran From

Getting Nuclear Weapons: Constraining Its Future Nuclear Options, Institute for Science and International Security,

March 5, 2012; R Scott Kemp, “Worm Holes—Virus Attacks Iran’s Enrichment Operation,” Jane’s Intelligence

Review, September 15, 2011; David E. Sanger, “Obama Order Sped Up Wave of Cyberattacks Against Iran,” New York

Times, June 1, 2012; Ellen Nakashima, Greg Miller, Julie Tate, “U.S. and Israel Created ‘Flame’,” Washington Post,

June 20, 2012. For more information about Stuxnet, see CRS Report R41524, The Stuxnet Computer Worm: Harbinger

of an Emerging Warfare Capability, by Paul K. Kerr, John W. Rollins, and Catherine A. Theohary. See also, Geoff

McDonald, Liam O. Murchu, Stephen Doherty, Eric Chien, Stuxnet 0.5: The Missing Link, Symantec Security

Response, February 26, 2013; and Ralph Langner, To Kill a Centrifuge: A Technical Analysis of What Stuxnet’s

Creators Tried to Achieve, The Langner Group, November 2013.

247 See, for example, Ulrike Putz, “Sabotaging Iran’s Nuclear Program,” Der Spiegel, August 2, 2011; Artin Afkhami,

“Tehran Abuzz as Book Says Israel Killed 5 Scientists,” New York Times, July 11, 2012.

248 Greg Miller, “CIA Has Recruited Iranians to Defect; The Secret Effort Aims to Undermine Tehran’s Nuclear

Program,” Los Angeles Times, December 9, 2007.

249

Iran: Nuclear Intentions and Capabilities, November 2007.

250 Statement for the Record Worldwide Threat Assessment of the US Intelligence Community, Senate Armed Services

Committee, February 9, 2016.

251 Implementation of the NPT Safeguards Agreement and Relevant Provisions of Security Council Resolutions 1737

(2006), 1747 (2007),1803 (2008) and 1835 (2008) in the Islamic Republic of Iran, Report by the Director General,

GOV/2008/59, November 19, 2008.

252 GOV/2011/65.

253 An annex to the report details these activities and provides a detailed explanation of the suspected weapons

program’s organizational structure.

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reports, although it does contain some previously unreported material.254 The program’s purpose

was “to develop a nuclear warhead for the Shahab-3 missile,” a senior Administration official

stated during a November 8, 2011, briefing about Amano’s November 2011 report.255 A 2012

Department of Defense report described Amano’s report as containing “extensive evidence of

past and possibly ongoing Iranian nuclear weapons-related research and development work.”256

(See Appendix E for more details about the IAEA’s information regarding suspected military

aspects of Iran’s nuclear program.)

Amano’s November 2011 report states that, according to information available to the IAEA,

Iranian activities related to building a nuclear explosive device “took place under a structured

programme” prior to the end of 2003. That program, however, “was stopped rather abruptly

pursuant to a ‘halt order’ instruction issued in late 2003 by senior Iranian officials,” the report

says. The weapons-related activities were consolidated under the “AMAD Plan” and “appear to

have been conducted during 2002 and 2003.” Nevertheless, “[t]here are also indications that some

activities relevant to the development of a nuclear explosive device continued after 2003, and that

some may still be ongoing,” according to the report. According to an August 2014 State

Department announcement, Iran established the Organization of Defensive Innovation and

Research (SPND), which “is primarily responsible for research in the field of nuclear weapons

development,” in 2011. The SPND “took over some of the activities related to Iran’s undeclared

nuclear program,” the announcement said.257 According to a 2012 Israeli intelligence report, the

SPND

was established for the purposes of preserving the technological ability and the joint

organizational framework of Iranian scientists in the area of R&D of nuclear weapons, and

for the purposes of retaining the skills of the scientists. This is [to] allow renewal of the

activity necessary to produce weapon immediately when the Iranian leadership decides to

do so.258

This report also indicates that Iran had not restarted the nuclear weapons program.

During a March 2019 press briefing, a senior U.S. official described the SPND as

an organization, chunks of which seem to have been created precisely in order to employ

people on dual-use things that could easily be repurposed into the very kind of work that

was being done before on the weapons program and…in a sense, to keep their skills sharp

and available to the Iranian clerical regime.259

Amano’s December 2, 2015, report assesses that Iran conducted “a range of activities relevant to

th

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