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Iran’s Critique of May 24, 2011 IAEA Safeguards Report: Arguments Not Based on Facts

by Paul Brannan

August 12, 2011

The International Atomic Energy Agency (IAEA) recently circulated a communication it received from Iran regarding the IAEA’s latest safeguards report from May 24, 2011. In the letter, Iran addresses the safeguards report and criticizes much of the content. The arguments that Iran makes, however, lack key information and are not supported by the facts.

Section A, Paragraph 6:

In Section A of the communication, Iran takes issue with language in the recent IAEA report that claims “Iran is not providing the necessary cooperation.” Iran denies this and points to the amount of detail in the safeguards reports on Iran’s program as evidence of its cooperation:

“Reporting so many technical details proves that the Agency has the full access to all nuclear material and facilities in the Islamic Republic of Iran…Therefore, claiming that ‘Iran is not providing the necessary cooperation’ is incorrect and misleading”

The amount of detail in the IAEA reports, however, reflects the lack of cooperation from Iran. For instance, Iran has constructed enrichment plants without informing the IAEA and has stated that it will continue to do so in the future. The existence of undeclared enrichment plants under construction, and their potential use as covert facilities to make highly enriched uranium, raises the importance of the IAEA and member states knowing the details of information such as the amount of enriched material stockpiled at the Natanz enrichment facility.

Furthermore, the amount of detail in IAEA reports on Iran does not in itself suggest a “necessary” level of cooperation. The language in the latest report that Iran is “not providing the necessary cooperation” is a reference to the lack of insight the Agency has into Iran’s nuclear program due to its failure to implement the Additional Protocol. Key elements of the Protocol that Iran does not implement include early and specific notification to the Agency regarding the construction of enrichment plants and providing the Agency with information on and access to gas centrifuge component manufacturing and assembly facilities.

Section D, Paragraphs 1-4

In this section, Iran provides a chronology of its submissions of Design Information Questionnaires (DIQ) for the Fordow enrichment plant as well as language from IAEA safeguards reports in which the Agency confirms that its observations of the plant correspond with the submitted DIQ. In the fourth paragraph, Iran states that “…the Islamic Republic of Iran has fulfilled its obligations in providing the required design information of FFEP [Fordow Fuel Enrichment Plant] to the Agency…” Iran does not specify the purpose of Section D of this communication, but it may be a response to stated IAEA requests for further information on the chronology of the construction of the Fordow facility.

In several safeguards reports, the IAEA has stated that it has requested further information from Iran regarding the “chronology of the design and construction of FFEP, as well as its original purpose…” and that Iran has not answered these questions. As seen in commercial satellite imagery going back several years, construction of the Fordow enrichment facility began at least by the first half of 2007 and potentially as early as 2006. The IAEA has reported that it dates the beginning of renewed construction activity to 2006. Therefore, the IAEA has requested clarification from Iran regarding its statement to the Agency that construction did not being until the second half of 2007. The Fordow plant is located at the site of two previously existing tunnel entrances that were built starting in 2002. Providing documentation on the chronology of the construction of these tunnels would help the IAEA determine any original alternate purpose of the enrichment facility.

The IAEA has also sought clarification from Iran regarding how the Fordow plant fits into Iran’s general enrichment program. Iran described Fordow as a “contingency enrichment facility,” reflecting the threat of a military strike against the Natanz enrichment plant. The Natanz facility, however, is designed to hold 50,000 centrifuges to produce low enriched uranium for power reactors. Holding only 3,000 machines, Fordow is not capable of performing the same role as the Natanz facility.

That Iran was building a relatively small enrichment plant in secret raised concerns that it was intended as a covert enrichment facility for making highly enriched uranium. IAEA requests to Iran for more information regarding the chronology and purpose of the facility are intended to address these concerns.