# Iran’s Nuclear Program: Status > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/crs%3ARL34544 ## Record - **Collection:** Congressional research report - **Document type:** CRS Report - **Published:** December 20, 2019 - **Citation:** RL34544 ## Text 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. Congressional Research Service Iran’s Nuclear Program: Status 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. Congressional Research Service Iran’s Nuclear Program: Status 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 Congressional Research Service Iran’s Nuclear Program: Status Contacts Author Contact Information .......................................................................................................... 85 Congressional Research Service Iran’s Nuclear Program: Status 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. Congressional Research Service 1 Iran’s Nuclear Program: Status 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 Congressional Research Service 2 Iran’s Nuclear Program: Status 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. Congressional Research Service 3 Iran’s Nuclear Program: Status 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. Congressional Research Service 4 Iran’s Nuclear Program: Status 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. Congressional Research Service 5 Iran’s Nuclear Program: Status 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. Congressional Research Service 6 Iran’s Nuclear Program: Status 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. Congressional Research Service 7 Iran’s Nuclear Program: Status 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. Congressional Research Service 8 Iran’s Nuclear Program: Status 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. Congressional Research Service 9 Iran’s Nuclear Program: Status 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. Congressional Research Service 10 Iran’s Nuclear Program: Status 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. Congressional Research Service 11 Iran’s Nuclear Program: Status 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. Congressional Research Service 12 Iran’s Nuclear Program: Status 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. Congressional Research Service 13 Iran’s Nuclear Program: Status 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. Congressional Research Service 14 Iran’s Nuclear Program: Status 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. Congressional Research Service 15 Iran’s Nuclear Program: Status 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. Congressional Research Service 16 Iran’s Nuclear Program: Status 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. Congressional Research Service 17 Iran’s Nuclear Program: Status 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). Congressional Research Service 18 Iran’s Nuclear Program: Status 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. Congressional Research Service 19 Iran’s Nuclear Program: Status 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). Congressional Research Service 20 Iran’s Nuclear Program: Status 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. Congressional Research Service 21 Iran’s Nuclear Program: Status 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.) Congressional Research Service 22 Iran’s Nuclear Program: Status 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. Congressional Research Service 23 Iran’s Nuclear Program: Status 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 Congressional Research Service 24 Iran’s Nuclear Program: Status 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. Congressional Research Service 25 Iran’s Nuclear Program: Status 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. Congressional Research Service 26 Iran’s Nuclear Program: Status 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 Fe [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/crs%3ARL34544. Public record. Not legal advice.