Former IAEA Deputy Director Olli Heinonen says that 24 days is enough for Iran to clean up any sites that the IAEA may suspect of harboring activities to develop nuclear weapons. He is concerned about “smaller covert facilities that are used toward the end of the nuclear weapons process” rather than large sites like the Natanz enrichment facility. 

Another former inspector, Thomas Shea, disagrees and says that the IAEA’s technology will allow detection after 24 days.

Where does that 24 days come from? And who’s right?

For sites that have been declared to the IAEA as nuclear-related sites, inspection will be continuous, with video and other electronic surveillance and physical access to the sites. In Annex I, paragraph L.65 of the Joint Comprehensive Plan of Action (JCPOA), Iran says that it will abide by Modified Code 3.1 of the Subsidiary Arrangement to its Safeguards Agreement. This provision requires requires Iran to provide design information for new nuclear facilities “as soon as the decision to construct, or to authorize construction, of such a facility has been taken, whichever is earlier.” (See p. 6 of this report.)

Paragraph C.15 of the JCPOA says that a reliable mechanism to ensure speedy resolution of access concerns will remain in place for 15 years. The specifics for access to sites are in Annex I, Section Q.

Paragraph Q.74 sets out specific limitations that one might think are common sense. However, Iran has felt that earlier efforts by the IAEA to access sites, based on information from other countries, have been unfair and possibly in the service of gaining intelligence on activities not related to its nuclear program. Hence these assurances. Paragraph Q.75 specifies that the IAEA must make the basis for its concerns known to Iran, which Iran claims it has not always done.

Iran would then provide an explanation to the IAEA. If that explanation fails to satisfy the IAEA, it must present its concerns in writing, with supporting material (Q.76). Iran may propose alternative means to resolving the matter (Q.77). If no resolution can be reached by these means within 14 days of the IAEA’s original request for access, the matter will be brought to the Joint Commission, which will come to a decision within 7 days, and Iran will have 3 days to implement that decision (Q.78). 14 + 7 + 3 = 24 days.

Repeating for emphasis: A potential delay of up to 24 days applies only to sites that have not been declared to the IAEA. Declared sites are under more or less continuous surveillance, and the IAEA has access to them at any time.

In the past, Iran has delayed IAEA requests to visit suspect sites and has made extensive changes to those sites during the delay. So skeptics of the deal have historical precedent to suspect that Iran will use such tactics again. Heinonen gives the Kalaye Electrical Company as an example; but the IAEA did in fact find traces of depleted, natural, and enriched uranium there, indicating that enrichment activities took place.

I don’t know the full details of IAEA’s capabilities or procedures, but from what I know, here is how I would proceed.

Once a suspicious site was identified, satellite surveillance should be tasked to the area. That may be able to show and identify equipment being removed. The Volunteer Verification Corps would swing into action with whatever information leaked about the site and available overhead photos.

Planning for various inspection scenarios would begin with examining the information about the facility and Iran’s relevant past activities. Is production or research activity suspected? Production facilities would be larger and harder to scrub, research facilities smaller. What kind of activity is suspected? Uranium enrichment? Plutonium extraction? Explosives development? Something else? Each has distinctive equipment, which should be listed and described for the on-the-ground inspectors. Each also has a chemical signature, which can be used to develop a sampling plan.

The approach of the JCPOA is to load the verification onto the production of fissile material. This is consistent with safeguards philosophy in general. Fissile material is essential for a bomb and the most difficult part of the bomb to produce. If you don’t have highly enriched uranium or plutonium, you don’t have a nuclear bomb. Heinonen admits that the smaller facilities he is concerned about would come toward the end of bomb production, which depends on having that fissile material. If Iran were interested in producing numbers of bombs in the double digits or more, the facilities would be the size of small factories. Equipment would have to be removed, buildings destroyed, and earth moved.

Only a small facility could be scrubbed in 24 days, and traces would linger in the environment. Satellite photos would tell the story. It’s not as easy as renovating your home. And raise your hand if your home renovation has taken 24 days or less.


Update: Nice graphic on access to sites.

Another update: Secretary of Energy Ernest Moniz says that tests were done by the DOE to check that 24 days would be enough. I’d like to see a little more detail. Maybe it will come out later.



Top Photo: A park at Lavisan-Shian, Iran, the result of a scrubbed site. It’s hard to tell from that link and this, but the scrubbing seems to have taken more than 24 days.


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