Iran Nuclear Agreement: The International Atomic Energy Agency's Authorities, Resources, and Challenges
Published: 2016-06-09T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In July 2015, multilateral talks with Iran culminated in an agreement called the JCPOA, through which Iran committed to limits on its nuclear program in exchange for relief from sanctions put in place by the United States and other nations. IAEA, an independent international organization that administers safeguards designed to detect and deter the diversion of nuclear material for nonpeaceful purposes, was requested to verify and monitor Iran's implementation of these commitments. The U.S. Department of State coordinates the United States' financial and policy relationship with IAEA.
GAO was asked to review the authorities and resources IAEA has to carry out its activities regarding the JCPOA. This report, which updates the preliminary findings from an interim report released in February 2016 (GAO-16-417), examines (1) the JCPOA commitments that IAEA has been asked to verify and monitor and its authorities to do so, (2) the resources IAEA has identified as necessary to verify and monitor those JCPOA commitments, and (3) potential challenges and mitigating actions IAEA and others have identified with regard to verifying and monitoring the JCPOA. GAO analyzed the JCPOA and key IAEA documents and interviewed current and former IAEA officials, U.S. government officials, national laboratory representatives, and experts from research institutions.
section_title: What GAO Found
paragraphs: As outlined in the Joint Comprehensive Plan of Action (JCPOA), the International Atomic Energy Agency (IAEA) was asked to verify and monitor Iran's implementation of a range of nuclear-related commitments. IAEA is using its safeguards authorities and conducting additional activities agreed to by Iran under the JCPOA to do so. Iran's commitments include limits on uranium enrichment levels and on enriched uranium inventories. IAEA is verifying and monitoring Iran's implementation of these commitments through a range of activities conducted by its Safeguards Department, such as inspecting Iran's nuclear facilities, analyzing environmental samples, and monitoring Iran's uranium mines and mills. Under the JCPOA, Iran agreed to provisionally apply the Additional Protocol, an agreement that will give IAEA's inspectors access to an expanded range of locations, including where the agency seeks assurance regarding the absence of undeclared nuclear material and activities. The JCPOA also includes a mechanism in which participants to the agreement commit to resolve an access request from the agency within 24 days after the request is made.
IAEA has identified the financial, human, and technical resources necessary to verify and monitor Iran's nuclear-related commitments in the JCPOA. IAEA has estimated that it needs approximately $10 million per year for 15 years in additional funding above its current safeguards budget for JCPOA verification. According to IAEA documents, this $10 million will be entirely funded through extra-budgetary contributions through 2016. IAEA officials said that the agency intends to propose that of the $10 million approximately $5.7 million for all Additional Protocol activities and inspector costs attributable to the JCPOA be funded through IAEA's regular budget after 2016; approximately $4.4 million will be supported through extra-budgetary contributions from member states, such as the United States. IAEA also plans to transfer 18 experienced inspectors to its Office of Safeguards Verification in Iran from other safeguards divisions and to hire and train additional inspectors. According to IAEA officials, existing safeguards technical resources are sufficient to implement the JCPOA.
IAEA may face potential challenges in verifying and monitoring Iran's implementation of certain nuclear-related commitments in the JCPOA. According to current and former IAEA and U.S. officials and expert organizations, these potential challenges include (1) integrating JCPOA-related funding into IAEA's regular budget and managing human resources in the safeguards program, (2) access challenges depending on Iran's cooperation and the untested JCPOA mechanism to resolve access issues, and (3) the inherent challenge of detecting undeclared nuclear materials and activities. IAEA has identified mitigating actions, such as utilizing remote monitoring and cost-free experts to address potential understaffing of IAEA safeguards activities in other countries as additional experienced inspectors are transferred to work on Iran-related safeguards. In addition, according to IAEA and U.S. officials as well as a former IAEA official GAO interviewed, IAEA has improved its capabilities in detecting undeclared activity. For example, according to U.S. officials, IAEA has adapted its inspector training program to focus on potential indicators of undeclared activities.
section_title: What GAO Recommends
paragraphs: GAO is not making any recommendations.

section_title: Letter
paragraphs: Iran’s past efforts to develop a nuclear weapons program threatened  regional and global security and presented significant challenges to the  United States. The United States and other nations imposed sanctions on  Iran that adversely affected the Iranian economy. In July 2015,  multilateral talks with Iran culminated in an agreement—the Joint  Comprehensive Plan of Action (JCPOA)—in which the United States,  France, Germany, the United Kingdom, Russia, and China, with the High  Representative of the European Union for Foreign Affairs and Security  Policy, agreed to reciprocal commitments with Iran. These commitments  include providing sanctions relief if Iran implements its nuclear  commitments as laid out in the JCPOA.
The JCPOA details Iran’s commitments related to its nuclear facilities,  equipment, materials, and activities, among other things. On July 20,  2015, the United Nations Security Council endorsed the JCPOA and  requested that the International Atomic Energy Agency (IAEA) verify and  monitor these commitments. IAEA—an independent international  organization based in Vienna, Austria, and affiliated with the United  Nations—has the dual mission of promoting the peaceful uses of nuclear  energy and verifying that nuclear technologies and materials are used for  peaceful purposes and not diverted to nuclear weapons. Specified U.S.,  European Union, and United Nations nuclear-related sanctions on Iran  were lifted on January 16, 2016—the JCPOA’s “Implementation Day”— when IAEA verified and reported that Iran had fully implemented its  commitments defined in Annex V, paragraph 15, of the JCPOA. The  JCPOA also provides for a “Transition Day,” when the United States and  European Union will take further steps to eliminate nuclear-related  sanctions on Iran, either on October 18, 2023, or earlier if IAEA reaches  what it calls a “broader conclusion” regarding the peaceful nature of Iran’s  nuclear program.
The Treaty on the Nonproliferation of Nuclear Weapons (NPT), which  came into force in 1970, requires non-nuclear weapon states that are  party to the treaty—countries that had not manufactured and detonated a  nuclear device before January 1, 1967, such as Iran—not to acquire  nuclear weapons and to subject all nuclear material used in peaceful  activities to IAEA safeguards. IAEA has previously found Iran to be in  noncompliance with its safeguards obligations.
You asked us to review the authorities and resources IAEA has to carry  out its activities to monitor and verify certain nuclear-related commitments  under the JCPOA. In February 2016, we issued an interim report on our  preliminary findings. This report, which updates the preliminary findings  in the interim report, examines (1) the JCPOA commitments that IAEA  has been asked to verify and monitor, and its authorities to do so; (2) the  resources IAEA has identified as necessary to verify and monitor Iran’s  nuclear-related commitments under the JCPOA; and (3) potential  challenges and mitigating actions, if any, IAEA and others have identified  with regard to verifying and monitoring Iran’s nuclear-related  commitments under the JCPOA.
To identify the nuclear-related commitments in the JCPOA that IAEA has  been asked to verify and monitor and IAEA’s authorities for verifying and  monitoring these commitments, we analyzed the JCPOA, and IAEA  documentation concerning the safeguards legal framework, including the  Statute of the IAEA (the Statute), information circular (INFCIRC)/153,  which provides the basis for a comprehensive safeguards agreement  (CSA), Iran’s CSA, and INFCIRC/540,which provides the basis for an  Additional Protocol. To examine the resources IAEA has identified as  necessary to verify and monitor Iran’s nuclear-related commitments under  the JCPOA, we reviewed IAEA planning and budget documents and  statements by the IAEA Director General. In addition, to further  understand IAEA authorities and resource needs, and to examine  potential challenges and mitigating actions IAEA and others have  identified with regard to verifying and monitoring Iran’s nuclear-related  commitments under JCPOA, we interviewed officials of IAEA, the  Department of State (State Department), and the Department of Energy’s  (DOE) National Nuclear Security Administration (NNSA); as well as  representatives of Oak Ridge National Laboratory, Los Alamos National  Laboratory, Sandia National Laboratories, Lawrence Livermore National  Laboratory, and Brookhaven National Laboratory. We also interviewed 9  former IAEA officials, 10 former U.S. government and national laboratory  officials, and officials from 10 expert organizations—research institutions  and nongovernmental organizations with knowledge in the areas of  nuclear verification, monitoring, and safeguards. Appendix I provides a  more detailed discussion of our objectives, scope, and methodology.
We conducted this performance audit from July 2015 to June 2016 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: This section describes (1) IAEA’s structure and budget, (2) IAEA  safeguards, (3) the nuclear fuel cycle, and (4) Iran’s nuclear program.
subsections: section_title: IAEA’s Structure and Budget
paragraphs: IAEA is structured into six major programs, including Nuclear Verification,  which carries out the agency’s safeguards activities. Other IAEA  programs are generally intended to help promote safe and secure uses  and applications of nuclear energy for civilian purposes. For example,  IAEA’s Technical Cooperation program helps member states achieve  their sustainable development priorities by providing relevant nuclear  technologies and expertise. IAEA funds its programs primarily through (1)  its regular budget, for which all member countries are assessed, and (2)  voluntary extra-budgetary contributions from certain member countries  and other donors to meet critical needs. IAEA’s operational budget  requirements for 2016 totaled to $436.6 million, including $155.3 million  for the nuclear verification program (i.e., safeguards). See table 1 for  IAEA projected budget requirements for 2016 by program.
IAEA has a Board of Governors, which provides overall policy direction  and oversight for the agency. A Secretariat, headed by the Director  General, is responsible for implementing the policies and programs of the  IAEA General Conference and the Board of Governors. The State  Department coordinates the United States’ financial and policy  relationship with IAEA.
section_title: IAEA Safeguards
paragraphs: IAEA safeguards are a set of technical measures and activities by which  IAEA seeks to verify that nuclear material subject to safeguards is not  diverted to nuclear weapons or other proscribed purposes. To carry out  its safeguards activities, inspectors and analysts in IAEA’s Safeguards  Department collaborate to verify that the quantities of nuclear material  that non-nuclear weapon states have formally declared to the agency are  correct and complete.
Most countries have concluded a CSA with IAEA that covers all nuclear  material in all peaceful nuclear activities and serves as the basis for the  agency’s safeguards activities. Most countries with a CSA have also  brought into force an Additional Protocol to their CSAs, which requires  that country to provide IAEA with a broader range of information on the  country’s nuclear and nuclear-related activities. IAEA developed the  Additional Protocol to obtain additional information about and access to  countries’ nuclear and nuclear-related activities as part of its response to  the discovery in 1991 of a clandestine nuclear weapons program in Iraq.  The Additional Protocol gives the agency’s inspectors access to an  expanded range of locations, including those where the agency seeks to  assure the absence of undeclared nuclear material and activities.  Undeclared nuclear material and activities are those a state has not  declared and placed under safeguards but is required to do so pursuant  to its CSA or Additional Protocol. Iran’s CSA entered into force in May  1974. According to IAEA officials, Iran applied the Additional Protocol  beginning in December 2003, ceased to do so in February 2006, and has  been provisionally applying it since January 16, 2016. IAEA regards Iran’s  provisional application as if the Additional Protocol were in force.
IAEA implements safeguards through a range of activities and techniques  to help ensure that all nuclear material is where it was declared to be and  to verify that there was no misuse of the facility, no diversion of declared  nuclear material, and no undeclared nuclear material or activities.  Safeguards activities include on-site inspections, environmental sampling,  and remote monitoring. For example, to verify nondiversion of nuclear  material, IAEA inspectors count items (e.g., containers of uranium or  plutonium), measure attributes of these items (e.g., isotopic composition),  and compare their findings with records and declared amounts.  Inspectors typically verify the nuclear material inventory by reviewing a  facility’s nuclear material accounting documentation (e.g., reports and  records) and through, for example, visual observation, radiation detection  and measurement, and application of seals and other identifying and  tamper-indicating devices, according to IAEA documents. Visual  observation allows inspectors to observe the processes within a location  and the equipment it contains, and to check the consistency of  observations with declarations. Inspection activities are supported by off- site safeguards activities, such as analysis of the environmental samples  collected during inspections, remote monitoring through the equipment  installed, analysis of commercial satellite imagery, and analysis of open  source documents, such as technical journals.
IAEA may conduct three types of inspections pursuant to comprehensive  safeguards agreements: ad hoc, routine, and special inspections. For  example, IAEA may conduct ad hoc inspections to verify a state’s initial  declaration under the CSA and any changes to these declarations.  Routine inspections give IAEA access to strategic points at a location to  verify, among other things, the location, identity, quantity, and  composition of all nuclear material subject to safeguards under the CSA.  Notification of inspections can be transmitted from 1 week to 24 hours in  advance or less. Routine inspections may also be unannounced. IAEA  may also conduct special inspections in certain circumstances, either in  addition to the routine or ad hoc inspection effort or involving access to  locations or information beyond those subject to a routine or ad hoc  inspection.
The Additional Protocol also authorizes “complementary access” for  IAEA, which is access to nuclear sites and other locations related to a  state’s nuclear fuel cycle—beyond declared nuclear facilities that are  routinely subject to inspections under the CSA— including locations at  which nuclear fuel-cycle research and development not involving nuclear  material is carried out; manufacturing and import locations; and all  buildings on a nuclear site, including undeclared locations.
IAEA may also negotiate “managed access” with a state to prevent the  dissemination of proliferation-sensitive information, meet safety or  physical protection requirements, or protect proprietary or commercially  sensitive information. According to an IAEA document, an example of  managed access is the designation by the operator, based on  arrangements made with IAEA, of the routes to be followed on a site to  prevent the exposure of inspectors to high levels of radiation or to protect  proprietary sensitive information associated with certain equipment.  Furthermore, managed access should not hinder IAEA inspectors or  prevent them from fulfilling the purposes of the complementary access— that is, the arrangements shall not preclude the agency from conducting  activities necessary to provide credible assurance of the absence of  undeclared nuclear material and activities at the location in question.
IAEA plans inspections according to its reporting requirements and its  goals for timely detection. The safeguards agreements with a given  country, its nuclear materials, and the nature of its fuel cycle and facilities  to be safeguarded inform the frequency of inspections and other in-field  activities. For example, according to IAEA documents, in countries  without an Additional Protocol in force or where IAEA has not drawn a  broader conclusion, IAEA’s inspections would be timed to detect the  diversion of unirradiated direct use material—nuclear material that can be  used for the manufacture of nuclear explosive devices in its present  form—within 1 month. The goal for irradiated direct use material, such as  spent fuel, which would require more time and effort to be converted to  components of nuclear explosive devices, would be to detect any  diversion in 3 months. The goal for all other nuclear material, such as  depleted, natural, and low-enriched uranium, as well as thorium, would be  to detect any diversion in a year. IAEA plans its supporting safeguards  activities—such as analysis of satellite imagery before inspections, of  Additional Protocol declarations, and of information obtained during  inspections (such as environmental samples)—in proportion to the  frequency of inspections.
section_title: The Nuclear Fuel Cycle
paragraphs: )—timeliness would be several months for tens of  kilograms of material. efficient at producing plutonium under certain circumstances; the  operating power, among other things, influences how much plutonium is  produced.
The fuel cycle—the series of processes used to make fuel for and  manage spent fuel from nuclear reactors—may also be used to produce  special nuclear material for weapons. The uranium nuclear fuel cycle  consists of three stages: (1) the front end, in which uranium is mined,  milled, enriched, and fabricated into fuel; (2) reactor operation; and (3) the  back end, in which spent fuel is either disposed of (open fuel cycles) or  processed to produce new fuel (closed or partially closed fuel cycles).  IAEA verifies that nuclear material subject to safeguards is not diverted.  Under a CSA, the starting point of safeguards is when nuclear material  reaches the stage in the nuclear fuel cycle where it is suitable, by  composition and purity, for enrichment or fuel fabrication and leaves the  plant or the process stage by which it has been produced, or when  material that has not yet reached such a stage is imported into the state  or exported to a non-nuclear weapon state. See figure 1 for an illustration  of the nuclear fuel cycle.
section_title: Iran’s Nuclear Program
paragraphs: Iran’s nuclear program includes two uranium mines and mills—the Gchine  uranium mine and mill, the Saghand mine, and the Ardakan mill. Iran  operates a conversion facility and fuel fabrication plant in Esfahan, the  Tehran Research Reactor, and the Bushehr Nuclear Power Plant. Iran’s   nuclear program also includes the Arak/IR-40 heavy water reactor,  enrichment facilities at Natanz and Fordow, and a heavy water production  plant in Arak. See figure 2 for a map of major facilities in Iran’s nuclear  program.
Iran had previously failed to declare some of these facilities to IAEA. For  example, in 2002, IAEA was informed by member states of previously  undeclared nuclear facilities—a uranium enrichment plant in Natanz and  a heavy water production plant in Arak. In the same year, IAEA started to  become increasingly concerned about the possible existence of  undisclosed nuclear-related activities in Iran involving military-related  organizations and, in 2011, reported to the Board of Governors on  outstanding issues related to possible military dimensions (PMD) to Iran’s  nuclear program. The information indicated that Iran had carried out  activities relevant to the development of a nuclear explosive device, such  as studies in high explosives and exploding bridgewire detonators, and  work to manufacture neutron initiators.
IAEA has also previously found instances where Iran was in non- compliance with its obligations under its CSA. For example, in June 2003,  IAEA’s Director General reported that Iran had failed to meet its  obligations under its CSA with respect to the reporting of nuclear material  imported into Iran, among other things. In November 2003, the Director  General concluded that Iran had failed to report uranium conversion  experiments and the separation of plutonium from material irradiated in its  Tehran Research Reactor, and had failed to provide IAEA design  information for various nuclear facilities. In 2009, the Board of Governors  noted that Iran’s failure to notify the agency of the construction of the  Fordow uranium enrichment plant until September of that year was  inconsistent with its obligations under the subsidiary arrangements to its  CSA.
In July 2015, Iran made commitments under the JCPOA related to its  nuclear facilities, equipment, materials, and activities, among other things,  and the United Nations Security Council endorsed the JCPOA and  requested that IAEA verify and monitor these commitments.
section_title: IAEA Uses Its Safeguards Authorities to Carry Out Verification and Monitoring Activities under the JCPOA
paragraphs: IAEA has been requested by the United Nations Security Council, and  authorized by the Board of Governors, to verify and monitor Iran’s  implementation of a range of nuclear-related commitments. To do so,  IAEA is using its safeguards authorities and conducting additional  verification and monitoring activities agreed to by Iran.
subsections: section_title: IAEA Has Been Asked to Verify and Monitor Iran’s Implementation of a Range of Nuclear-Related Commitments under the JCPOA
paragraphs: The JCPOA commitments IAEA has been asked to verify include limits on  Iran’s nuclear program, including those on numbers of centrifuges (for example, no more than 5,060 of specified  centrifuges at Natanz for 10 years); uranium enrichment levels (no more than 3.67 percent for 15 years);  stocks of enriched uranium (no more than 300 kilograms for 15  years); heavy water inventories; and  centrifuge manufacturing. stockpile limit. metallurgy, or activities that could contribute to the design and  development of a nuclear explosive device. The duration of certain  commitments ranges from 8 years for certain centrifuge restrictions to 25  years for monitoring of uranium ore concentrate. The JCPOA does not  contain any provisions relating specifically to Iran’s Bushehr Nuclear  Power Plant, so according to IAEA, the agency will not carry out  verification or monitoring activities in relation to the JCPOA at Bushehr  beyond its standard safeguards under Iran’s CSA and Additional Protocol.
Iran also agreed to fully implement the “Roadmap for Clarification of Past  and Present Outstanding Issues.” The roadmap sets out a process for  IAEA to address issues relating to the possible military dimensions of  Iran’s nuclear program. IAEA issued a report on the results of its PMD  investigation in December 2015, and the Board of Governors  subsequently adopted a resolution closing its consideration of the “past  and present outstanding issues.” The resolution noted the board’s  decision to transition IAEA’s work in Iran from under previous Board of  Governors and United Nations Security Council resolutions to JCPOA  implementation and verification, in light of United Nations Security Council  Resolution 2231. State Department officials noted that the board, in its  resolution, stated that it will be watching closely to verify that Iran fully  implements its commitments under the JCPOA and will remain focused  going forward on the full implementation of the JCPOA to ensure the  exclusively peaceful nature of Iran’s nuclear program.
section_title: IAEA Is Using Its Safeguards Authorities and Conducting Additional Activities to Verify and Monitor Iran’s Commitments
paragraphs: According to officials in IAEA’s Office of Legal Affairs, the agency draws  on its safeguards authorities to verify and monitor Iran’s implementation  of its nuclear-related commitments. For example, using its safeguards  authorities, including the CSA, IAEA will verify and monitor Iran’s  implementation of most of its nuclear-related commitments largely  through a range of traditional safeguards approaches and techniques that  it has used in the past, such as inspecting nuclear facilities and  conducting nuclear material accountancy to verify quantities of nuclear  material declared to the agency and any changes in the quantities over  time. Under the JCPOA, Iran agreed to provisionally apply, and seek  ratification of the Additional Protocol, which gives the agency’s  inspectors access to an expanded range of locations, including those  where the agency seeks assurance regarding the absence of undeclared  nuclear materials and activities. According to IAEA officials, Iran  previously applied the Additional Protocol beginning in December 2003  but ceased to do so in February 2006, and has been provisionally  applying it since Implementation Day (January 16, 2016). IAEA regards  this as if the Additional Protocol were in force.
Under the JCPOA, IAEA is also conducting certain additional verification  and monitoring activities agreed to by Iran, such as containment and  surveillance measures for monitoring Iran’s uranium mines and mills,  according to IAEA officials. Containment and surveillance measures  include the use of video cameras to detect any movement of nuclear  material and any tampering with agency equipment as well as seals that  indicate whether the state has tampered with installed IAEA safeguards  systems. Material in mining or ore processing activities (e.g., uranium at  mines and mills) is not yet suitable for enrichment and so is not subject to  the agency’s safeguards under a CSA, though the Additional Protocol  does require states to declare the location and status, among other  things, of uranium mines and uranium and thorium mills.
Iran also committed under the JCPOA to cooperate with IAEA and  facilitate its safeguards activities. For example, Iran agreed to make  arrangements to allow for the long-term presence of IAEA inspectors by  issuing long-term visas, among other things. Iran also agreed to permit  the use of modern technologies, such as online enrichment monitors, to  increase the efficiency of monitoring activities. The JCPOA includes a  mechanism in which its participants commit to resolve access issues with  the agency regarding an undeclared location within 24 days after the  request is made. The JCPOA also describes a dispute resolution  mechanism through which a participant in the agreement can bring a  complaint if it believes that commitments are not being met and which  allows the participant to cease performance of its commitments in certain  cases if dispute resolution fails to resolve the participant’s concerns.
Iran also agreed, under the JCPOA, to fully implement Modified Code 3.1  of the subsidiary arrangements to its CSA. According to IAEA, the text  of the Modified Code 3.1 in Iran’s subsidiary arrangements is based on  model language under which a country is required to provide preliminary  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.”
Furthermore, Iran has agreed to import any enumerated nuclear-related  and nuclear-related dual-use materials and equipment exclusively  through a new “procurement channel” established under the JCPOA and  United Nations Security Council Resolution 2231. The JCPOA details  the establishment of a Joint Commission comprising representatives of  participants in the agreement, under which a procurement working group  will review and make recommendations on proposed imports.  Furthermore, pursuant to United Nations guidance, the exporting state will  provide information to IAEA on these proposed imports. Under the  JCPOA, IAEA may access the locations of intended use of specified  nuclear-related imports. IAEA officials told us that they expect the  information provided through the procurement channel to support the  agency’s efforts to detect undeclared activity.
section_title: IAEA Has Identified the Financial, Human, and Technical Resources Necessary to Verify and Monitor Iran’s Nuclear- Related Commitments in the JCPOA
paragraphs: IAEA has estimated the financial, human, and technical resources  necessary to verify and monitor Iran’s implementation of its nuclear- related commitments in the JCPOA. IAEA’s process for estimating  resource needs is based on the frequency of its verification and  monitoring activities, which, as previously noted, is driven by timely  detection goals and reporting requirements. IAEA reports to the Board of  Governors on its work under the JCPOA quarterly.
subsections: section_title: Financial Needs
paragraphs: IAEA has estimated that it needs approximately $10 million per year for  15 years in additional funding above its current safeguards budget to fund  additional inspections, among other things, under the JCPOA. Of this  amount, IAEA estimates that it will need about $3.3 million for costs  associated with implementing the Additional Protocol; about $2.4 million  for other inspector and direct staff costs; and about $4.4 million in other  costs, such as travel, equipment, and support services beyond those  associated with Additional Protocol implementation (see table 2).
IAEA officials said that consistent with its Statute, the Director General  intends to propose to the Board of Governors that the approximately $5.7  million in costs associated with Additional Protocol activities and inspector  and other direct staff costs attributable to the JCPOA be funded through  IAEA’s regular budget after 2016. These officials said that the remaining  $4.4 million in estimated funding needs in each of the following 15 years  will remain unfunded in the regular budget and therefore be supported  through extra-budgetary funding. Under its Statute, IAEA is to apportion  the costs of implementing safeguards, which would include inspector  salaries and the cost of implementing the Additional Protocol, through  assessments on member countries. As previously noted, such  assessments form IAEA’s regular budget. IAEA’s Statute also states that  any voluntary contributions may be used as the Board of Governors, with  the approval of the General Conference, may determine. The JCPOA  was not finalized in time for the agency to include these costs for 2016 in  its assessments. Consequently, according to a 2015 IAEA report, all of  IAEA’s JCPOA work through 2016 will be funded through extra-budgetary  contributions. According to IAEA officials, how quickly the $5.7 million in  JCPOA costs are incorporated into the regular budget depends on  member state support. These officials told us that IAEA hopes to resolve  the questions about funding the JCPOA through the regular budget by the  June 2016 Board of Governors meeting.
IAEA’s estimate of $10 million per year for funding requirements related  to JCPOA activities is approximately 6 percent of the agency’s $155.3  million operational safeguards requirements for 2016. These  requirements are consistent with historical operational safeguards  expenditures from 2006 to 2014—the latest year for which expenditure  data are available. During this timeframe, IAEA’s operational safeguards  expenditures ranged from $127.1 million to $202.6 million, with amounts  from $10.8 million to $46.9 million coming from extra-budgetary  contributions (see table 3).
As we previously noted, funding for IAEA’s safeguards activities— including those related to the JCPOA—comes from member state  contributions to IAEA’s regular budget and from member state extra- budgetary voluntary contributions to IAEA. According to State Department  officials, the balance of JCPOA-related costs not covered by IAEA’s 2017  regular budget will require extra-budgetary contributions from member  states. The total level of voluntary contributions needed in fiscal year  2017 to cover JCPOA-related requirements remains unclear pending  resolution of IAEA’s 2017 budget process.
IAEA officials told us that many member states have pledged financial  support for JCPOA implementation. Regarding funding from the United  States, the State Department and DOE have requested approximately  $190 million for fiscal year 2017 to support IAEA generally and JCPOA- related IAEA activities specifically, in the form of both regular  contributions to the IAEA budget and extra-budgetary funding:  The State Department has requested approximately $101.1 million for fiscal year 2017 to be contributed to IAEA’s regular budget. State Department officials told us that they expect some of the regular budget contribution to support IAEA safeguards, but that the budget request does not designate a specific amount within this total for IAEA’s safeguards program or JCPOA verification and monitoring activities. According to IAEA officials, contributions to the agency’s regular budget cannot be designated for specific IAEA programs or activities.
The State Department has requested $89.8 million for fiscal year 2017 for its extra-budgetary contribution to IAEA. State Department officials told us that some of this funding may be used to support JCPOA verification and monitoring activities, but that none of this funding is specifically designated for these activities. State officials said the final amount of U.S. voluntary contributions to JCPOA-related funding requirements will depend on the amount of international donor support made available to IAEA, but that the United States plans to provide ongoing support to IAEA to meet these requirements. Furthermore, because the United States pays its assessed (regular budgetary) contribution on a largely deferred basis, the funds requested for fiscal year 2017 will be largely used to pay 2016 calendar year assessments, which include no JCPOA-related costs.
The United States’ extra-budgetary contribution to IAEA generally includes funding for the U.S. Support Program to IAEA Safeguards, which was established in 1977 to augment IAEA’s regular budget for safeguards activities with U.S.-sponsored expertise, equipment, and techniques. The program supports IAEA’s overall safeguards mission, and some of what it funds may benefit JCPOA implementation. The program may fund, among other things, equipment (for example, cameras or seals), research and development of safeguards technologies, subsidies for the analysis of environmental samples at IAEA’s Network of Analytical Laboratories, and training for IAEA inspectors at DOE laboratories. This training covers, among other  things, the use and analysis of safeguards tools and equipment, as  well as concealment scenarios—for example, where material being  measured may have been altered to mislead the detectors.
DOE has requested $1 million for fiscal year 2017 for IAEA verification and monitoring related to the JCPOA, as part of $13 million to support JCPOA implementation. This $1 million includes funding for any DOE staff loaned to IAEA to assist with the agency’s JCPOA-related activities or contractors who are made available on a short-term basis to IAEA.
section_title: Human Resource Needs
paragraphs: IAEA’s annual $10 million funding estimate includes approximately $7.5  million in funding to cover estimated human resource costs associated  with additional inspectors and support services under the JCPOA. IAEA  officials told us that the agency identified the need for 18 experienced  inspectors and nearly twice that number of other staff for its Iran Task  Force—now the Office of Safeguards Verification in Iran. The agency  plans to transfer these inspectors from divisions within its Safeguards  Department that cover countries and regions beyond Iran. According to  IAEA officials, the other Safeguards divisions would backfill the vacancies  created by the transfer of inspectors to verification and monitoring related  to Iran by hiring and training new inspectors. State Department officials  noted that IAEA may draw on U.S. and other member-state support to  temporarily fill vacated positions until new staff can be permanently hired  and brought into place.
section_title: Technical Resource Needs
paragraphs: According to IAEA officials, IAEA’s existing technical resources are  sufficient to implement its verification and monitoring activities under the  JCPOA. IAEA officials generally did not specify the technical measures  that IAEA will use to verify and monitor each of Iran’s nuclear-related  commitments under the JCPOA. However, some technical measures that  IAEA generally uses to supplement visual observations and examination  of records include the following:
Portable radiation detectors and gamma spectrometers to take measurements—for example, on pipework and equipment—to verify that nuclear material is as declared (for example, at the declared level of enrichment).
Tamper-indicating seals and cameras for containment and surveillance over previously verified material and equipment. Such measures increase the efficiency of safeguards by reducing inspection costs and allowing IAEA to focus inspection efforts where most needed. See figure 3 for an image of an inspector replacing a seal.
Mass spectrometers to analyze environmental samples for traces of undeclared material and activity. IAEA conducts bulk and particle analysis of environmental samples. Particle analysis provides information on the history of a facility’s operation—for example, whether enrichment had occurred beyond the level declared. Bulk analysis provides information on the average enrichment level in a facility and the presence of trace elements that may provide information about where material is from or what processes it had been subject to.
Under the JCPOA, Iran agreed to allow IAEA to use online enrichment  measurement. IAEA’s online enrichment monitor (OLEM) continuously  monitors enrichment levels, allowing for more efficient enrichment  monitoring. IAEA is using the OLEM in the Natanz Fuel Enrichment Plant  to confirm that enrichment levels are at or below 3.67 percent, as per  Iran’s commitment under the agreement. IAEA has previously used  continuous enrichment monitors, but the OLEM is a newer technology  that improves upon older monitoring systems.
section_title: IAEA May Face Challenges in Verifying and Monitoring Iran’s Nuclear-Related Commitments and Has Identified Some Mitigating Actions
paragraphs: IAEA may face challenges in verifying and monitoring Iran’s  implementation of certain nuclear-related commitments in the JCPOA.  These potential challenges include (1) detecting undeclared nuclear  materials and activities, (2) accessing sites in Iran, and (3) managing  safeguards budgetary, human, and technical resources. IAEA has  identified mitigating actions for some of these challenges.
subsections: section_title: IAEA Faces an Inherent Challenge in Detecting Undeclared Nuclear Materials and Activities and Has Taken Steps to Mitigate This Challenge
paragraphs: Detection of undeclared nuclear materials and activities is an inherent  challenge for IAEA; IAEA and member states have taken some steps to  improve the agency’s ability to detect undeclared activities. According to  IAEA, the agency can draw a broader conclusion that all nuclear material  in Iran remains in peaceful activities only after the agency has completed  its evaluations and found no indications of diversion of declared nuclear  material from peaceful nuclear activities and no indications of undeclared  nuclear material or activities in the state as a whole.
subsections: section_title: Challenges in Detecting Undeclared Nuclear Materials and Activities
paragraphs: According to current U.S. officials, a former U.S. official, some former  IAEA officials, and officials from several expert organizations we  interviewed, detection of undeclared nuclear material and activities is an  inherent challenge for IAEA. Iran has previously failed to declare activity  to IAEA. For example, according to IAEA documents and officials, prior to  2003, Iran failed to provide IAEA with information on a number of nuclear  fuel cycle-related activities and nuclear material. In addition, according to  IAEA documents, Iran also failed to notify the agency at the time of its  decision to construct the Fordow enrichment facility, as required under  Modified Code 3.1 of the subsidiary arrangements to Iran’s CSA.
To detect undeclared material and activities, IAEA looks for indicators of  such activities, including equipment and infrastructure necessary for the  activities, as well as nuclear and nonnuclear material or traces of such  material in the environment, according to an IAEA document. According  to current U.S. and IAEA officials, some former U.S. officials, some  former IAEA officials, and officials from several expert organizations,  IAEA faces inherent challenges and limitations in identifying indicators of  undeclared activity. For instance:
Some activities may not be visible to IAEA—for example, through satellite imagery—or do not involve nuclear material, and may not leave traces in the environment, such as centrifuge manufacturing and some weapons development activities. According to a former U.S. official, some former IAEA officials, and officials from several expert organizations, this poses a challenge for IAEA in detecting undeclared activity.
The Board of Governors’ decision to close its consideration of the PMD issue without a complete accounting of Iran’s past nuclear program could reduce indicators of potential undeclared activity, according to one expert organization. Officials from this organization said that without a complete accounting, only part of Iran’s nuclear program is visible to IAEA, and IAEA is missing information that could inform future safeguards planning.
The procurement channel established under the JCPOA may serve as a source of indicators for IAEA on potential undeclared activities in Iran, according to current and two former U.S. officials as well as officials from two expert organizations. However, IAEA officials told us that there is additional work to be done in informing exporting countries of their obligations and standardizing the data that the countries would report to IAEA so that they are usable to the agency. These officials told us that ensuring that countries report the data as required is particularly challenging for countries that do not have a robust export control system.
section_title: Efforts to Mitigate Challenges in Detecting Undeclared Nuclear Material and Activities
paragraphs: Current IAEA and U.S. officials as well as a former IAEA official said that  IAEA has taken steps to improve its ability to detect undeclared nuclear  activities and materials and told us that there are other mitigating factors  to the challenges IAEA faces in this area.
First, according to a current IAEA official, current U.S. officials, and a  former IAEA official, IAEA has improved its capabilities in detecting  undeclared activity. For example, according to U.S. officials, IAEA has  adapted its inspector training program to focus on potential indicators of  undeclared activity beyond the agency’s traditional safeguards focus on  nuclear materials accountancy. IAEA also has analytical tools at its  disposal, some of which IAEA officials demonstrated to us, to detect  undeclared activities worldwide. IAEA also receives member-state  support in detecting undeclared activities. For example, member states  provided some of the information that formed the basis of IAEA’s PMD  investigation.
In addition, State Department officials said that they have conducted  outreach to exporters and exporting countries about the procurement  channel so that the suppliers know their responsibilities and  requirements. According to State Department officials, this outreach  included sending cables to all posts with instructions to inform host  countries and their industries of procurement channel requirements. The  United Nations has provided information regarding the procurement  channel on its website.
Further, according to IAEA and U.S. officials, Iran’s application of the  Additional Protocol improves IAEA’s ability to investigate indicators of  undeclared activities in Iran. For instance, on the PMD issue, DOE  officials noted that under the JCPOA, IAEA will have the authorities of the  Additional Protocol and enhanced transparency measures of the JCPOA  with which to investigate any indication of undeclared activities, including  those activities suspected of having possible military dimensions or  potential weaponization activities not involving nuclear materials.  Furthermore, State Department officials noted that the JCPOA puts IAEA  in a better position to detect such activities in Iran, as inspectors will have  increased access to information and locations to clarify and resolve  inconsistencies or other indicators of noncompliance and will have an  increased scope of materials accountancy at various sites, such as  mining and milling processes.
section_title: IAEA’s Work toward a Broader Conclusion for Iran
paragraphs: IAEA officials told us that any uncertainties regarding the peaceful nature  of Iran’s nuclear program that may arise would have to be resolved for the  agency to reach a broader conclusion that all nuclear material in Iran  remains in peaceful activities. As noted above, broader conclusion refers  to IAEA’s determination for a country that, for a given year, all nuclear  material remained in peaceful activities. The JCPOA states that the  United States and European Union will take further steps to eliminate  nuclear-related sanctions on Iran either on October 18, 2023, or before if  IAEA reaches a broader conclusion. According to State Department  officials, on October 18, 2023, under the JCPOA, the United States and  European Union would take these steps to eliminate these sanctions on  Iran regardless of whether IAEA has reached a broader conclusion.
IAEA officials told us that the agency does not draw a broader conclusion  lightly, for any state, and that it has taken on average 3 to 5 years for  states with CSAs and Additional Protocols. The estimates for the  amount of time needed for IAEA to reach a broader conclusion for Iran  varied among the former IAEA and U.S. officials and the expert  organization officials we interviewed. Some former U.S. officials, two  former IAEA officials, and officials from two expert organizations stated  that it is possible for IAEA to reach a broader conclusion before October  18, 2023. The former U.S. officials stated that this could be possible if  Iran cooperates with IAEA and provides the access and information  needed.
Others we interviewed did not believe IAEA would be able to reach a  broader conclusion in that time frame, citing examples of countries in  which IAEA took considerable time to reach broader conclusions. For  instance, a former U.S. official and an official from one expert  organization told us that it took IAEA 10 years to reach a broader  conclusion for Turkey even with the country’s relatively basic fuel cycle.  Both also stated that Turkey’s former involvement in the illicit  procurement network and black market contributed to the length of time to  reach a broader conclusion in that country. The former U.S. official also  said that the broader conclusion for Taiwan took from 6 to 8 years, noting  that Taiwan, which had a weapons program, made a strategic decision to  shut down the program and fully cooperate with IAEA. An official from one  expert organization stated that the broader conclusion process is very  technical and complex, and that even in compliant countries such as  Australia and Canada, arriving at a broader conclusion is an “incredibly  difficult feat” for IAEA.
State Department officials told us that in their view it would not be an  impediment to the JCPOA if IAEA does not reach a broader conclusion  regarding Iran’s nuclear program by October 18, 2023. These officials  said that they believed it is more important for IAEA to draw a broader  conclusion in an appropriate manner and time frame, and less important  that a broader conclusion be reached before the United States and  European Union take further steps to eliminate sanctions in October  2023. These officials added that Iran’s nuclear-related commitments  under the JCPOA extend beyond this date, as well as IAEA’s authorities  and capabilities to continue to verify the peaceful nature of Iran’s nuclear  program.
section_title: IAEA May Face Access Challenges, but the Additional Protocol and the JCPOA’s Access Mechanism May Mitigate These Challenges
paragraphs: IAEA may face challenges in gaining access to sites in Iran, according to  officials and expert organizations we interviewed. IAEA officials stated  that access depends on the cooperation of the member state and the  operators of its facilities under safeguards. However, two former U.S.  officials, a former IAEA official, and officials from one expert organization  we interviewed told us that Iran has a history of denying access to IAEA  inspectors. For example, IAEA requested access in February 2012 to the  Iranian military complex at Parchin—where high explosive experiments  were believed to have been conducted—and Iran did not allow access  until the fall of 2015 as part of IAEA’s PMD investigation. In addition,  earlier IAEA reports stated that Iran did not cooperate with IAEA on  access to the Heavy Water Production Plant, although Iran eventually  granted the agency managed access in December 2013. Prior IAEA  reports also stated that Iran had denied the agency’s requests for access  to locations related to the manufacturing of centrifuges, research and  development on uranium enrichment, and uranium mining and milling,  among other things.
IAEA and U.S. officials said that IAEA is taking action to facilitate access  and cooperation. For instance, IAEA officials stated that they plan to work  to train operators in Iran who are less experienced in working with IAEA  and who may be less experienced in keeping records that facilitate the  agency’s safeguards activities, such as the operators of the Heavy Water  Production Plant, which IAEA officials stated was the only type of facility  subject to verification and monitoring under the JCPOA that is new to the  agency.
Iran’s agreement to provisionally apply the Additional Protocol will  facilitate the agency’s access to sites in Iran, according to IAEA officials.  Specifically, they told us that, under the Additional Protocol, the agency  has authority to access any part of a site that it is inspecting within 2  hours’ notice and any other location within 24 hours. Furthermore, IAEA  officials disputed the view of one expert organization that Iran’s limited  cooperation during the PMD investigation may have set a precedent for  limiting IAEA access going forward. IAEA officials told us that the closure  of the PMD investigation would not preclude future IAEA access requests  to the sites that were part of the investigation, should IAEA determine that  such access is warranted. These officials added that IAEA’s PMD  investigation was conducted without the Additional Protocol, and that any  future investigations into potential undeclared activity would be conducted  under the expanded legal authority of the Additional Protocol.
In addition, as we noted earlier, the JCPOA includes a mechanism that  limits the time for resolution of access issues between the participants to  24 days for matters related to JCPOA implementation. IAEA officials told  us that the 24-day period under the mechanism would begin once the  agency raises a given access issue. Appendix II discusses this  mechanism in detail. Officials and expert organizations we interviewed  discussed two potential challenges regarding the mechanism. First, they  noted that the mechanism is untested and may not facilitate access.  Second, they differed on whether the mechanism’s 24-day limit would  help IAEA gain timely access before Iran could hide certain activities.
First, a former IAEA official and an official from one expert organization  told us that the mechanism is untested in that an access dispute has not  yet arisen under the JCPOA; therefore, it is too soon to tell how it will  work and whether it will improve access. Specifically, according to the  official from the expert organization, the agreement is not clear about how  the Joint Commission will coordinate with the Board of Governors or IAEA  as a whole if the mechanism is invoked. Furthermore, a former U.S.  official expressed concern that the politics among members of the Joint  Commission may mean that access disputes raised by IAEA may not be  resolved in IAEA’s favor. Nonetheless, State Department officials said  that the JCPOA access mechanism provides additional recourse to IAEA  and is supplementary to the Additional Protocol, and that it does not take  authority away from the Board of Governors. IAEA officials also said that  if Iran were to deny an IAEA request for access at any site, the agency  has various options for resolving the matter, including referral to IAEA’s  Board of Governors, the Joint Commission, or both.
Second, officials and expert organizations differed on whether the  mechanism’s 24-day time frame could allow Iran to hide activities from  IAEA before the agency gained access. These officials and expert  organizations differed on the activities that Iran could hide within 24 days  and the proliferation significance of such activities. For example, two  former IAEA officials and officials from two expert organizations  specifically stated that small-scale enrichment activities and activities not  including nuclear material could be hidden within the 24-day time frame.  A former U.S. official also said that Iran could clean up traces of nuclear  materials within 24 days and, even if it were unable to hide all evidence, it  could create enough ambiguity to preclude further investigation or action.  However, other officials and expert organizations said that the potential  for a 24-day access delay in the mechanism was generally not a concern.  Specifically, several former IAEA officials, some former U.S. officials, and  officials from some expert organizations noted that nuclear material, even  in trace amounts, cannot be cleaned up within that time. A former IAEA  official also stated that much of what IAEA is looking for is not easily  disguised, cleaned, or removed in 24 days.
U.S. officials stated that they believed that it is unlikely that Iran would risk  reinstatement of sanctions by denying IAEA access. For instance, State  Department officials told us that refusal by Iran to comply with the access  provisions of the Additional Protocol or JCPOA could lead to the  reinstatement of sanctions. Additionally, DOE officials said that the  JCPOA’s provisions for the reinstatement of sanctions will encourage  Iranian cooperation with and access for IAEA.
section_title: IAEA May Face Resource Challenges and Is Taking Actions to Mitigate Them
paragraphs: IAEA faces potential resource management challenges stemming from  the monitoring and verification workload in Iran, and is taking actions to  mitigate them. These challenges include (1) integrating the additional  JCPOA-related funding needs that IAEA has identified into the agency’s  regular budget, (2) managing human resources within the safeguards  program, which could affect IAEA’s safeguards efforts internationally, and  (3) addressing potential challenges with technical resources.
subsections: section_title: The Reliability of Long-Term Funding for JCPOA Activities
paragraphs: State Department officials told us that they are confident that IAEA will  obtain the funding it needs for JCPOA activities in the near term, but IAEA  officials expressed concerns about the reliability of long-term funding.  State Department officials told us that the United States and other  member states would provide extra-budgetary contributions to support  IAEA’s JCPOA activities. However, IAEA officials expressed concerns,  which State Department officials acknowledged, about possible donor  fatigue with regard to extra-budgetary contributions in the long run, as  IAEA will be conducting certain JCPOA verification activities for 10 or  more years. We have previously concluded that IAEA cannot necessarily  assume that donors will continue to make extra-budgetary contributions at  the same levels as in the past. IAEA and State Department officials, as  well as a former IAEA official and an official from one expert organization,  stated that funding the JCPOA from the IAEA regular budget—rather than  through extra-budgetary contributions—would give the safeguards  program a more stable and predictable funding base for its verification  and monitoring activities.
As we previously noted, IAEA proposes to integrate approximately $5.7  million in JCPOA costs into IAEA’s regular budget after 2016. However,  IAEA may face challenges in integrating some JCPOA funding needs into  its regular budget. IAEA officials, as well as a former IAEA official, two  former U.S. officials, and an official from one expert organization stated  that the proposal to move funding for verification and monitoring efforts  under the JCPOA into IAEA’s safeguards regular budget could face  resistance from some member states without corresponding budget  increases for other IAEA programs, such as the Technical Cooperation  program, which supports nuclear power development and other civilian  nuclear applications.
State Department officials said that delay or failure to incorporate costs  into the regular budget would increase IAEA’s reliance on extra-budgetary  contributions but would not prevent IAEA from carrying out JCPOA- related activities as long as those contributions are forthcoming. State  Department officials also told us that no member state has opposed  integration of certain JCPOA costs into the regular budget or proposed  corresponding increases for other programs. These officials added that  they recognize that long-term reliance on extra-budgetary contributions  risks donor fatigue, and that they will plan for providing support with a  view toward filling any future funding gaps that arise.
section_title: Managing Human Resources in the Safeguards Program
paragraphs: IAEA also faces a potential human resource management challenge in its  safeguards program as it implements actions to verify and monitor the  JCPOA, which could affect its broader international safeguards mission.  Specifically, IAEA’s strategy of transferring inspectors to its Office of  Safeguards Verification in Iran from other safeguards divisions may pose  a challenge to IAEA and its safeguards work in other countries because  of the extensive time it takes IAEA to hire and train new inspectors for  those divisions.
According to current IAEA and U.S. officials as well as two former IAEA  officials and officials from two expert organizations we interviewed, hiring  and training qualified inspectors can take years. A former IAEA official  and current officials said that recruiting inspectors is difficult because their  skills are highly specialized—typically requiring a combination of nuclear  engineering knowledge with analytical abilities. These officials also said  that IAEA’s hiring process requires multiple interviews and examinations.  Furthermore, current IAEA officials and two former IAEA officials, as well  as an official from one expert organization, said that training new  inspectors to be proficient in executing their safeguards responsibilities  can be a time-consuming process. As a result, IAEA faces a potential  challenge as it prioritizes JCPOA activities in meeting the need for  additional experienced inspectors to work on Iran-related safeguards,  while ensuring that other safeguards efforts in other countries are not  understaffed. IAEA officials have said that its work in Iran is its priority.
IAEA officials, as well as a former IAEA official, some former U.S.  officials, and officials from several expert organizations told us that IAEA  could mitigate human resources challenges in the short term through  remote monitoring and the use of cost-free experts in its headquarters.  According to State Department officials, the United States, as well as  other IAEA member states, have provided a list of qualified candidates  to IAEA to backfill positions of IAEA staff transferred within the agency  for JCPOA work to avoid gaps while full-time staff are hired and trained.  Many of these have previously worked as IAEA inspectors and are  already trained.
section_title: Potential Technical Resource Challenges
paragraphs: As we previously noted, IAEA officials told us that the agency’s existing  technical resources are sufficient for JCPOA verification and monitoring.  However, IAEA officials also noted that they expect an increase in  environmental sampling as a result of the JCPOA. IAEA laboratories  handle approximately 500 environmental samples a year at IAEA’s  Environmental Sample Laboratory in Seibersdorf, Austria, and other  laboratories within the Network of Analytical Laboratories. The IAEA  laboratory at Seibersdorf handles about 20 percent of the overall  environmental sample analysis, with the other network facilities  processing the remainder.
According to IAEA officials, particle analysis is time-consuming and  expensive. IAEA uses a spectrometer called the Large Geometry  Secondary Ionization Mass Spectrometer (LG-SIMS) for particle analysis  at its Seibersdorf Analytical Laboratory. IAEA officials at the laboratory  told us that the LG-SIMS is expensive and is operating at capacity, raising  concerns about IAEA’s ability to meet any future environmental sampling  demands at the Seibersdorf laboratory alone. These officials told us that a  second LG-SIMS would cost approximately $5 million, plus additional  personnel costs to operate and maintain the equipment. Other IAEA  officials and some U.S. officials told us, however, that other laboratories  in the network could accommodate increases in environmental sampling  analysis workload, and that there was no need at this time for IAEA to  procure a second LG-SIMS in light of other critical funding priorities for  technical needs.
section_title: Agency Comments
paragraphs: We are not making any recommendations in this report. We provided the  Departments of State and Energy and the International Atomic Energy  Agency a draft of this report to for their review and comment. State, DOE,  and IAEA provided technical comments, which we incorporated as  appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to appropriate congressional  committees, the Secretaries of State and Energy, and other interested  parties. In addition, the report will be available at no charge on the GAO  website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-3841 or trimbled@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report examines (1) the Joint Comprehensive Plan of Action  (JCPOA) commitments that the International Atomic Energy Agency  (IAEA) has been asked to verify and monitor and its authorities to do so,  (2) the resources IAEA has identified as necessary to verify and monitor  Iran’s nuclear-related commitments under the JCPOA, and (3) potential  challenges and mitigating actions, if any, IAEA and others have identified  with regard to verifying Iran’s nuclear-related commitments under the  JCPOA.
To identify the nuclear-related commitments in the JCPOA that IAEA has  been asked to verify and monitor and IAEA’s authorities for verifying and  monitoring these commitments, we analyzed the JCPOA, in close  coordination with IAEA and the Department of State. We also analyzed  IAEA documentation concerning the safeguards legal framework,  including the Statute of the IAEA, which authorizes the agency to apply  safeguards, at the request of parties, to any bilateral or multilateral  arrangement; “The Structure and Content of Agreements Between the  Agency and States Required in Connection with the Treaty on the Non- Proliferation of Nuclear Weapons” (information circular (INFCIRC)/153),  which provides the basis for the comprehensive safeguards agreement  that most countries have concluded with IAEA and that covers all of the  countries’ nuclear material in peaceful activities; Iran’s Comprehensive  Safeguards Agreement (INFCIRC/214); the Model Additional Protocol  (INFCIRC/540), which provides the basis for an Additional Protocol that  most countries with a CSA have concluded with IAEA to provide  additional information about countries’ nuclear and nuclear-related  activities; and the November 2011 IAEA Safeguards Report, which  details items concerning “possible military dimensions” of Iran’s nuclear  program; IAEA’s report on its investigation of the possible military  dimensions; and the related Board of Governors’ resolution. We also  analyzed the Treaty on the Non-Proliferation of Nuclear Weapons and  United Nations Security Council Resolution 2231, which requests IAEA to  undertake the necessary verification and monitoring of Iran’s  commitments.
To examine the resources IAEA has identified as necessary to verify and  monitor Iran’s nuclear-related commitments under the JCPOA, we  reviewed IAEA planning and budget documents, such as “The Agency’s  Programme and Budget 2016 –2017,” the Director General’s report titled  “Verification and Monitoring in the Islamic Republic of Iran in light of  United Nations Security Council Resolution 2231 (2015),” and pertinent  Director General’s statements to the Board of Governors.
In addition, to further understand IAEA authorities and resource needs,  and to examine potential challenges and mitigating actions IAEA and  others have identified with regard to verifying and monitoring Iran’s  nuclear-related commitments under the JCPOA, we interviewed officials  of IAEA, the Department of State, and the Department of Energy’s (DOE)  National Nuclear Security Administration (NNSA); as well as  representatives of Oak Ridge National Laboratory, Los Alamos National  Laboratory, Sandia National Laboratories, and Brookhaven National  Laboratory. We also held classified interviews with officials in the Office of  the Director of National Intelligence and representatives of Lawrence  Livermore National Laboratory. The information from these interviews is  not reflected in this report.
We also interviewed 8 former IAEA officials,10 former U.S. government  and national laboratory officials, and officials from 10 expert  organizations—research institutions and nongovernmental organizations  with knowledge in the areas of nuclear verification, monitoring, and  safeguards. We selected these expert organizations by first identifying  organizations that had previously served as sources of IAEA subject  matter experts for GAO. To ensure a wide range of viewpoints, we  supplemented our initial selection with individuals and organizations  identified through a literature search and by recommendations from our  initial set of expert organizations. We requested interviews from all the  identified officials from expert organizations and suggested contacts and  interviewed all who agreed to participate (officials from 2 expert  organizations provided written responses in lieu of in-person interviews).  We analyzed their responses and grouped them into overall themes  related to different elements of the objective. When referring to these  categories of interviewees throughout the report, we use “some” to refer  to three members of a group, “several” to refer to four or five members of  a group, and “many” to refer to more than five members of a group.
We conducted this performance audit from July 2015 to June 2016 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Procedures for Resolving International Atomic Energy Agency Access Issues under the Joint Comprehensive Plan of Action
paragraphs: Section Q of Annex I of the Joint Comprehensive Plan of Action (JCPOA)  details procedures for the International Atomic Energy Agency (IAEA)  access to sites in Iran. These procedures together total no more than 24  days, as follows:  1.  If IAEA has concerns about undeclared materials or activities—or  activities otherwise inconsistent with the JCPOA—at locations that  have not been declared under the comprehensive safeguards  agreement or additional protocol, the agency may first seek  clarification from Iran and if Iran’s explanations do not resolve IAEA’s  concerns, then request access to the sites in question.  2.  Iran may propose means other than access to the site for resolving  IAEA’s concerns, but if IAEA cannot verify the absence of undeclared  nuclear materials and activities or activities inconsistent with the  JCPOA after implementation of the alternative means or the two sides  cannot come to an agreement on alternative means within 14 days of  the agency’s original request for access, Iran, in consultation with the  Joint Commission, would resolve IAEA’s concerns through necessary  means agreed upon with IAEA. 3.  If there is no agreement between Iran and IAEA, the Joint  Commission would, by consensus or a vote of 5 or more of its 8  members, advise on the necessary means to resolve the IAEA’s  concerns. This process would not exceed 7 days. Iran would then  have 3 days to carry implement the necessary means.
According to IAEA, these procedures are for the purpose of JCPOA  implementation and are without prejudice to the Comprehensive  Safeguards Agreement (CSA) and Additional Protocol. Generally, IAEA  notifies the state of a request for access (e.g., inspections and  complementary access), specifying the location, date and time, purpose,  and activities to be carried out as required in the CSA and Additional  Protocol. The state is to confirm the receipt of the notification and  facilitate IAEA’s access. If there were issues related to the  implementation by the member state of its obligations under the CSA or  the Additional Protocol, the Director General would inform the Board of  Governors. In the case of Iran, if there were issues affecting the fulfilment   of JCPOA commitments, the Director General would inform the Board  and in parallel the Security Council, as appropriate. Should IAEA’s  concerns regarding undeclared nuclear materials or activities, or activities  inconsistent with the JCPOA continue to be unresolved after engaging  with Iran, the access procedures set out above, from Section Q of Annex I  of the JCPOA, may be used.
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, William Hoehn (Assistant  Director), Alisa Beyninson, Antoinette Capaccio, R. Scott Fletcher,  Bridget Grimes, Joseph Kirschbaum, Grace Lui, Thomas Melito, Alison  O’Neill, Sophia Payind, Timothy M. Persons, Steven Putansu, Vasiliki  Theodoropoulos, and Pierre Toureille made key contributions to this  report.