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“[My time at ACA] prepared me very well for the position that I took following that with the State Department, where I then implemented and helped to implement many of the policies that we tried to promote.”
– Peter Crail
Business Executive for National Security
June 2, 2022
SECTION 2: Understanding the Joint Plan of Action
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The November 24 Joint Plan of Action contains first-phase steps for Iran and the P5+1 to take over a six-month period that address urgent concerns of both sides. It also contains the broad parameters of a comprehensive agreement. This breakthrough accord was reached after three rounds of talks between the P5+1 and Iran, following Rouhani’s inauguration as president of Iran and his appointment of a new negotiating team led by Foreign Minister Mohammed Javad Zarif.

The framework agreement’s first-phase steps verifiably freeze progress in all areas of acute concern regarding Iran’s nuclear program. It also rolled back Iranian capabilities in some areas and significantly increased IAEA monitoring and verification of Iranian nuclear activities.

In exchange, Iran received some relief from proliferation-related sanctions imposed by the United States and the European Union, including the repatriation of $4.2 billion in frozen Iranian oil revenue, and a pledge that new nuclear-related sanctions would not be imposed for the duration of the agreement. Meanwhile, the core of the existing international financial and oil sanctions regime against Iran would remain in place.

Implementation of the agreement began on January 20. The six-month time frame for the first-phase actions will end on July 20, but can be extended for another six months if both parties agree.

Under the interim agreement, the IAEA submits monthly reports on the status of the implementation. Also, the Joint Plan of Action set up a joint commission to evaluate any disputes that might arise over the course of the six-month period. The rationale was that these issues should be separate from the negotiations on a comprehensive agreement.

Enriched Uranium

Implementation of the first phase of the agreement rolled back Iran’s uranium-enrichment program by capping the levels of enrichment, freezing the number of centrifuges enriching uranium, and neutralizing the most proliferation-sensitive aspect of Iran’s nuclear program: its stockpile of uranium enriched to 20 percent.

In the Joint Plan of Action, Iran committed to enrich uranium to no more than 5 percent over the course of the agreement.

On January 20, the IAEA confirmed that Iran halted production of uranium enriched to 20 percent at Fordow and the Pilot Fuel Enrichment Plant at Natanz. Fordow, which only produced uranium enriched to 20 percent, was repurposed by the Iranians to produce reactor-grade uranium, but the cascades at Fordow cannot operate in an interconnected design as they had in the past.

As part of the agreed monitoring and verification mechanism, the Joint Plan of Action allows the IAEA to visit Natanz and Fordow on a daily basis and the IAEA installed real-time monitoring to ensure that Iran does not begin operating additional centrifuges or restart enriching uranium to 20 percent. Under the terms of the agreement, Iran can replace broken or damaged centrifuges, but not put any new centrifuges into operation.

On January 20, Iran’s stockpile of uranium hexaflouride gas enriched to 20 percent was 209.1 kilograms, just short of the estimated 240 to 250 kilograms that, when further enriched, is enough for one weapon. In May, the IAEA reported that Iran’s stock of uranium enriched to 20 percent was 38.4 kilograms as a result of the implementation of the agreement.

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In the Joint Plan of Action, Iran committed to take steps to reduce the threat posed by its stockpile of uranium enriched to 20 percent. Half of its 20 percent stockpile of hexafluoride gas was to be down-blended to 3.5 percent-enriched uranium hexafluoride gas; the other half is being converted into a powder form that can be used to make fuel plates for the Tehran Research Reactor.

The powder form can be reconverted to gas, but Iran committed not to set up a line to do so, and the IAEA has confirmed that no such line exists. During any reconversion process, Iran would lose a significant quantity of material, perhaps as much as 30 percent, according to some experts.

The April 17, 2014, IAEA report on implementation confirmed that Iran completed the dilution of half of the 20 percent-enriched material to reactor-grade levels within the first three months, which was the time frame required by the agreement.

As of the May 23 IAEA report, Iran had converted 67 kilograms of 20 percent enriched uranium hexafluoride gas to powder form. An additional 38 kilograms remain to be converted.

Iran is allowed to continue enriching uranium to 3.5 percent under the November 24 agreement, but Tehran agreed to convert the uranium enriched to that level during the six months of the initial deal to a powder form that can be used to fuel nuclear power reactors.

In total, Iran’s stockpile of uranium enriched to 3.5 percent was about 7,600 kilograms at the time that implementation of the Joint Plan of Action began in January. Since January, the stockpile has grown to 8,475 kilograms, according to the May 23 IAEA report.

This growth is a result of the continued production of uranium enriched to 3.5 percent and the dilution of 105 kilograms of uranium enriched to 20 percent. Iran did not complete construction of the conversion plant that will allow it to convert the 3.5 percent-enriched uranium hexafluoride gas to uranium dioxide powder until May 2014. Conversion should begin in June 2014.

Iran originally said that the facility would begin operations in December 2013. Iran maintains that, despite the delay, it will be able to complete the necessary conversion of the 3.5 percent-enriched uranium to ensure that there is no net growth in the stockpile between January 20 and July 20.

Natanz

Under the November 24 agreement, Iran committed not to install any additional centrifuges at the Natanz Fuel Enrichment Plant and not to operate any more centrifuges than were operating at the time of the November agreement.

The monthly IAEA reports confirm that the number of centrifuges installed at Natanz remained the same: 15,420 IR-1 machines in 90 cascades and 1,008 IR-2M machines.

The number of IR-1 centrifuges enriching uranium to 3.5 percent at Natanz is unchanged from the November report, with about 9,200 IR-1 machines operating in 54 cascades.

An additional two cascades that had been producing uranium enriched to 20 percent at the Pilot Fuel Enrichment Plant at Natanz have been converted to enrich uranium to 3.5 percent and are no longer enriching in an interconnected design.

The IAEA has set up additional surveillance at Natanz that will allow the agency to confirm that Iran does not begin operating any additional centrifuges on the days that it does not visit the facility.

Fordow

Iran committed to halt uranium enrichment to 20 percent at the Fordow facility and not to operate or install any additional centrifuges at the facility as part of the November 24 agreement. Iran also said it would no longer operate the four cascades running at Fordow in an interconnected design.

On January 20, Iran halted enrichment of uranium to 20 percent in the 696 IR-1 centrifuges operating at Fordow and notified the IAEA that it would begin enriching to 3.5 percent using the same 696 centrifuges. The monthly IAEA reports confirm these actions and that the agency has surveillance in place to ensure that Iran does not begin operating any of the 12 additional cascades at Fordow.

Centrifuge Production and Monitoring

Under the Joint Plan of Action, the IAEA was allowed managed access for the first time to Iran’s centrifuge assembly workshops, rotor production sites, and centrifuge storage areas. This access will help the IAEA ensure that Iran has limited its production of IR-1 centrifuges to those needed to replace damaged machines, as per the conditions of the November 24 agreement.

This access will help guard against the pursuit of any clandestine enrichment programs because it will give the IAEA greater oversight of Iran’s centrifuge production capabilities and allow it to better track the total number and locations of centrifuges Iran has produced.

As part of the agreement, Iran committed not to move forward on any new centrifuge enrichment plants over the agreement’s six-month time span. In 2010, Iran declared that it intended to construct an additional 10 facilities, but did not give any time frame for these plants or information to the IAEA about the facilities. As part of separate negotiations with the IAEA, Iran provided these details in early 2014, but they have not been made public.

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Arak

Under the November 24 agreement, Iran was required to provide the IAEA with updated design information for the heavy-water reactor at Arak (IR-40), refrain from installing any major components, and halt production of fuel assemblies. Also, Iran committed not to engage in any reprocessing activities or build a facility to reprocess plutonium from spent fuel.

As originally designed, the 40-MWt Arak heavy-water reactor poses a proliferation threat because when operational, the spent fuel would contain plutonium, which, when separated, is useable for nuclear weapons.

According to the May IAEA report, the agency has monthly access to the reactor as required under the Joint Plan of Action. The monthly reports confirm that no major components were installed since the November 2013 report and that updated design information was provided to the IAEA in February and March. The reports also confirm that Iran halted production of the fuel assemblies for the Arak reactor. As of the November IAEA report, Iran had produced 11 fuel assemblies made of natural uranium. The reactor is designed to contain 150 fuel assemblies.

The IAEA was able to access the Heavy Water Production Plant at the Arak site in December 2013 for the first time in more than two years. The IAEA reported that the plant has produced 100 tons of reactor-grade heavy water since it began operations in 2006.

The quarterly May 2014 IAEA report said that the agency is working with Iran to conclude a safeguards agreement for the Arak heavy-water reactor. On May 5, Iran and the IAEA met to continue discussions on the appropriate safeguards approach. The parties committed to complete the updated safeguards approach by August 25.

Research and Development

Under the terms of the November 24 agreement, Iran is allowed to continue its R&D activities under existing IAEA safeguards.

According to the IAEA’s quarterly report issued in May, Iran is continuing to test its advanced centrifuges (the IR-2M, IR-4, IR-6, and IR-6s machines) as single machines and in cascades at its R&D plant at Natanz. Iran also has an IR-5 centrifuge at the facility that it is not yet testing.

On December 4, Iran informed the IAEA that it will begin testing a new model, the IR-8. According to the May 2014 report, the IAEA noted that as of December 2013, a new centrifuge casing was installed in the R&D area but it was not yet connected for testing.

Sanctions Relief

In return for Iran’s actions limiting and rolling back its nuclear activities, the P5+1 committed to provide relief from proliferation-related sanctions over the course of the first-phase agreement. The Joint Plan of Action also committed the United States, the EU, and UN Security Council from passing any further sanctions related to proliferation concerns.

As part of the sanctions relief package, when implementation of the deal began on January 20, the United States and the EU suspended sanctions that prohibited the purchase of Iranian petrochemical products and trade with Iran using gold or other precious medals.

The United States also suspended sanctions on Iran’s auto industry and allowed for the supply of spare parts for civilian aircraft and installation services for the necessary repairs. On April 4, Boeing Co. announced that it received a license from the U.S. Department of the Treasury that will allow it to export spare aircraft parts.

Sanctions relief also targeted Iran’s oil sector. A December 2011 U.S. law required countries to stop importing oil from Iran unless granted a six-month waiver by the United States. Failure to comply would result in exclusion from the U.S. financial system. The waivers were renewable if countries continued to reduce their oil imports from Iran. Beginning in July 2012, the EU began its own oil embargo for all member states.

By the time of the November 24 agreement, Iran’s oil exports were limited to six countries: China, Japan, South Korea, India, Turkey and Taiwan. In total, this amounted to approximately 1 million barrels per day by mid-2013, roughly one-third of what Iran exported in mid-2011.

Under the November 24 agreement, the United States suspended its requirement that countries continually reduce their oil imports from Iran and froze Iran’s export levels at the November 2013 levels.

In addition, the agreement enabled the repatriation of $4.2 billion in Iranian oil revenue held abroad. Provisions that went into effect in 2013 prevented Iran from transferring oil payments back to Iran and required that the money only be used for trade between the country holding the funds and Iran. This has resulted in billions of dollars of Iranian oil revenues being held in foreign banks. The $4.2 billion was repatriated to Iran over the course of the first-phase agreement. Some of the payments were tied to the completion of Iranian actions, such as completion of the dilution of uranium enriched to 20 percent.

The first-phase agreement established a financial channel to facilitate humanitarian trade using the oil revenues held abroad. This channel was designed to allow for the purchase of food, medicine, and medical products and to pay for Iran’s UN obligations and tuition for Iranian students abroad.

The EU announced on January 20 a 10-fold increase in the authorizations for nonsanctioned trade with Iran.

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