Iran: The agency’s evaluations are based on unreliable documents provided by the Zionist regime

Following the publication of the reports of the Director General of the International Atomic Energy Agency to the Council of Governors, the Permanent Representative of the Islamic Republic of Iran to the United Nations Office and other international organizations based in Vienna announced its opinions and considerations in the form of an explanatory note.

The full text of the memorandum of the Iranian delegation is as follows:

The Permanent Representative of the Islamic Republic of Iran to the United Nations and other international organizations wishes to be in Vienna. Share your comments and observations on the reports of the Director General to the Board of Governors of the International Atomic Energy Agency (GOV/2024/8) and (GOV/2024/7) as follows:

A) General comments:
1- The Islamic Republic of Iran has always fully adhered to its obligations, including the Comprehensive Safeguard Agreement (CSA-INFCIRC/214) and has made every effort so that the Agency can Effectively carry out its verification activities in Iran, including monitoring and surveillance (C/S) measures regarding Iran’s nuclear materials and activities.

2- Segregation Subjects divided into two different reports are not properly observed. Some cases related to the JCPOA are repeated in the NPT safeguards report, and vice versa, some cases related to the NPT safeguards are seen in the JCPOA report. For example, verification and monitoring activities related to the construction of centrifuge rotor tubes and bellows, which are defined in the framework of the JCPOA, should not be reported under the NPT Safeguards Agreement agenda.

3- Following the illegal withdrawal of the United States from the JCPOA in May 2018 and the failure of the European Union and the three European countries Germany, England and France to fulfill their obligations, Iran, in line with the exercise of its rights according to clauses 26 and 36 of the JCPOA, all voluntary clarifying measures beyond The Comprehensive Safeguard Agreement, including the implementation of the Amended Code 1/3 (as specified in paragraph 65 of Annex I of the JCPOA) stopped in February 2021.

4- Decision Iran stopped implementing its obligations under the JCPOA in full accordance with the country’s inherent rights according to Articles 26 and 36 of the JCPOA and in response to the illegal withdrawal of the United States from the JCPOA, along with the inability of three European countries to adhere to their commitments. This obvious fact cannot in any way be a basis for the three European countries to refuse to fulfill their obligations. itself, which is specified in paragraph 20 of Annex Five (V) of the JCPOA on the day of transition (October 18, 2023), is an illegal act and another clear example of the significant failure to implement their obligations in violation of both JCPOA documents and UN Security Council Resolution 2231

8- In the light of greater cooperation with the Agency, in recent years, Iran implemented voluntary measures within the framework of several joint statements, including the joint statement of March 4, 2023.

b) Comments on the report of the “background” section of the report (GOV/2024/8):

9- Paragraph 2 of this report states : “Comprehensive evaluation of all safeguards-related information available to the Agency to ensure that there is no indication of diversion of declared nuclear material from peaceful nuclear activities, no indication of production or processing of undeclared nuclear material at declared facilities and off-site facilities (LOFs) ) and also there is no indication of undeclared nuclear materials and activities in a country with a comprehensive safeguards agreement, it is necessary”. “text-a..”>- Agency reference in footnote 4 of GOV/2024/8, as reflected in the Annual Safeguards Implementation Report (SIR), for those countries with the Comprehensive Safeguards Agreement (CSA) and the Protocol Appendices (AP) are applicable: “To ensure that there are no indications of undeclared nuclear material or activities in the country, the Agency shall assess the consistency of the country’s declared nuclear program with the results of the Agency’s verification activities under safeguards agreements.” relevant and additional protocols…”.

– Considering that Iran’s commitment is only limited to the Comprehensive Safeguard Agreement (CSA), applying such an approach in The case of Iran is cause for concern.

10- The Director General expressed on different occasions in his report using words that do not express an objective, specialized and technical explanation, but a political approach. He thought that he should have avoided it. The director general’s reference to “insufficient cooperation” has completely ignored Iran’s cooperation with the Agency in various fields, including in joint statements. 11- Regarding paragraph 6 of the report. (GOV/2024/8), it should be noted that the Islamic Republic of Iran has repeatedly emphasized that there are no places that should be declared under the Comprehensive Safeguards Agreement (CSA), including through explanatory notes INFCIRC/1159 dated November 23 2023, INFCIRC/1131 dated September 14, 2023, INFCIRC/996 dated June 7, 2022 and INFCIRC/967 dated December 3, 2021. In addition, the Agency’s claim regarding undeclared locations lacks the provision of reliable information, documents and evidence related to safeguards. /p>

12- Paragraph 8 of the report states “…the Agency’s assessment of the undeclared nuclear activities carried out by Iran in Marivan remains unchanged”, as As stated in paragraph 6 above, the agency’s assessment should not be based on unreliable and invalid documents and information. In addition, there is no added value in referring to some previous arguments which, as a result of subsequent information, have confirmed and led to the resolution of this matter, as set out in the Director-General’s previous report (GOV/2023/26). However, the relevant details have already been reflected in paragraph 8 of Explanatory Memorandum INFCIRC/1094 dated 7 June 2023.

c) Considerations on the section related to “Subjects Mohm Padmani” report (GOV/2024/8):

13- Regarding paragraph 9 “Varamin”, the following should be considered:

– As has been repeatedly explained by the Islamic Republic of Iran, there have been no undeclared locations (the declaration of which is required) under the Comprehensive Safeguards Agreement (CSA).

– The claim of the existence of an “undeclared pilot-scale factory that was used between 1999 and 2003” lacks reliable information and verified authentic documents, but is based on fake and false documents. provided by a well-known entity.

– The agency’s reference only to low-quality satellite images to assess that “… the containers taken out of Varamin were finally transferred to Torquzabad …” is not enough and correct, because thousands of similar containers are moving around the country. The claim of moving a container from one place to another cannot be planned and followed up only with low quality satellite images. “, as already explained, the following should be emphasized:

– Agency assessment is not based on valid information and evidence. Turquzabad is actually an industrial place that includes all kinds of warehouses and storage places for detergents, chemicals, food, fabrics and textiles, tires and auto parts, pipes and fittings and some industrial waste. This place in such an area is not suitable for storing nuclear materials.

– As it has been said many times, the place in question is an industrial waste warehouse where container handling is an integral necessity. Is. The moving of containers from one industrial site to another, which is merely the only evidence of the agency’s claim, cannot be considered as a strong reason for any claim. Therefore, the charge of moving nuclear materials and equipment is not justified. In our extensive investigation into the history of activities carried out at this location, the Islamic Republic of Iran has not found the source of the particles reported by the agency. There has been no nuclear activity or storage at this location. Therefore, no technical clues have been found regarding the origin of the reported particles, however, the possibility of such particles being present through sabotage cannot be ruled out.

– Regarding the assumption The agency’s false claim that the containers were taken out of this place intact, the information that proves the agency’s assumption is not correct has already been provided to the agency.

15- About In paragraph 10 of the report, “…particles of nuclear material detected in Varamin and Torquzabad…”. It should be emphasized that:

– the use of the term “nuclear material particles” instead of “uranium particles” as reflected in the report (GOV/20243/8), It leads to misinterpretation.

– The mere presence of a few uranium particles in one place should not be considered as the basis for the agency’s conclusion.

16- In the report of the agency in section C.2, it is stated: “In the letter dated February 7, 2024, Iran submitted the required modified nuclear material audit reports to the agency.” According to these reports, the agency considers the discrepancy in the balance of nuclear materials to be rectified in UCF, it should be noted that:

– Regarding inventory verification (PIV) at the Jaber Ibn Hayyan Laboratory (JHL), as reflected in document GOV/2015/68 dated December 2, 2015, “The Agency re-evaluated this information in 2014 and estimated that the amount of natural uranium concerned in The range of uncertainty is associated with nuclear material audits and related measurements”. Uranium conversion, UCF (IRK-) has been received, repeatedly reported by the operator and verified by the Agency since 2003, that the relevant 90(a) and 90(b) statements have been satisfactorily reflected each year thereafter. In addition, these materials were subject to ongoing Agency C/S controls and surveillance during their storage at the JHL facility (IRL-) and remained under seal when transferred to UCF (IRK-). In addition, since no activity has been performed on this sealed material, its contents cannot necessarily be changed. This institution measures U-236 in soluble waste (the method used by the Agency), due to the large amount of uncertainty associated with measuring U-236 and also ignoring the process for dissolving the so-called dirty waste in large tanks, and with A big error is involved.

– In Iran’s letter dated August 9, 2023, it is emphasized that the discrepancy mentioned in the IRK Institute is due to the irregular process of recovering uranium from the waste known as ” “Dirty waste” contains a variety of unknown elements as impurity created, basically from a technical point of view, such differences are predictable and unavoidable in this recovery process. Furthermore, this should not lead to requests for changes in the audit reports of the originating institution (IRL-).

– However, during technical discussions between the Agency and Iran In Vienna on November 8, 2023, a presentation was made regarding the due diligence in IRK- to address dirty waste based on solid technical evidence, which is not properly reflected in this report (i.e. GOV/2024/8). In addition, the Islamic Republic of Iran agreed to conduct additional verification activities at UCF in the near future in order to resolve this technical issue.

– More Agency verification activities in this regard It took place on 21-22 November 2023, 03-4 December 2023 and on 20 December 2023. During the course of these follow-up activities at IRK-, the operator provided audit details for the recovery of uranium metal impure tailings. The required nuclear material audit was submitted to the agency. Amended nuclear material audit reports indicate that all of the declared amount of uranium in solid waste sent from JHL to UCF for liquidation was received at UCF, but the noted discrepancy is due to recovery activities due to the nature of the conversion processes.

– In its official letter to Iran, which is available, the agency confirmed that the discrepancy in the amount of uranium in the solid waste sent from JHL to UCF has been resolved. However, contrary to this conclusion, in paragraph 15 of GOV/2024/8 and in footnote 23 of GOV/2024/7, the word “amended” is used, which is not consistent with the letter received from the Agency in this regard. Again, the Agency has not provided any indication of a change from resolved to amended with respect to a previously circulated report (GOV/2024/7) which was subsequently amended without notice.

– While the resolution of this issue is announced in statement 90 (a), the last sentence of paragraph 38 that says “this new element requires further investigation by the agency” is not justified and acceptable. is not. Furthermore, it should be emphasized that during the technical talks on January 29, 2024, both parties agreed that the modification of the report would be limited to IRK only and without any reference to IRL. Based on this agreement, the modified IRK audit reports were provided to the Agency, which were subsequently approved by the Agency through the said 90 (a) statement.

17- Noting To section C.3 of the Safeguard Report (amendment code 1/3), the acceptance of the implementation of the amendment code 1/3 was one of the transparency and confidence-building measures, which is reflected in paragraph 65 of the JCPOA Annex. Following the withdrawal of the United States from the JCPOA and the non-implementation of the EU/E3 obligations under this agreement, Iran decided to fulfill its obligations solely according to its Comprehensive Safeguards Agreement in using its rights based on paragraphs 26 and 36 of the JCPOA. However, in good faith and in the light of the understanding reached with the Director General, Iran has already provided general information about the planning of the new institutions and announced that the relevant safeguards information will be provided to the Agency at the appropriate time.

d) Considerations regarding the “joint statement” section of the report (GOV/2024/8):

18- Regarding Paragraph 24, Iran has repeatedly declared its readiness to carry out mutual cooperation based on goodwill and based on the provisions of the joint statement. Two important elements of the statement, namely the framework of the Comprehensive Safeguard Agreement (CSA) and modality, should be considered. It is a pity that only Iran’s cooperation under the joint statement was not appreciated in the Director General’s report, but this cooperation was deliberately ignored.

19- Regarding paragraph 27 Director General’s report, it should be clear that Mr. Eslami has never questioned the cooperation as specified in the joint statement. In the meeting of September 25, 2023, Mr. Eslami had said that according to the law approved by the Islamic Council: “Strategic Action Plan to Lift Sanctions and Protect the Interests of the Iranian Nation”, Iran in exercising its rights based on clauses 26 and 36 of JCPOA, only itself commits Iran to the Comprehensive Safeguard Agreement and that it should not be expected that Iran will fully fulfill its obligations under the JCPOA while unjustified unilateral sanctions continue. Therefore, paragraph 27 of the report is not a true reflection of the said meeting, and there is a possibility of misunderstanding regarding Mr. Eslami’s statements.

20- Regarding paragraphs 29, 30 and 33 (GOV/2024/8) as well as paragraphs 25, 26 and 31 in (GOV/2024/7) regarding the cancellation of the appointment of agency inspectors, the following facts should be considered:

– As made clear in Article 9(a)(ii) of the (CSA) between Iran and the Agency (INFCIRC/214), Iran asserts its sovereign right to object to the appointment of Agency inspectors, not only at the time of the appointment proposal, but also at any other time after the appointment. It does not affect Iran itself.

– While the Islamic Republic of Iran accepted the appointment of 14 inspectors proposed by the agency on two occasions (October 2023 and February 2024), but Unfortunately, this issue is not properly reflected in the report.

– Currently, the agency has a total of 120 appointed inspectors for the Islamic Republic of Iran. This clearly shows that Iran is willing to enable the agency to carry out its tasks by benefiting from the expertise of various inspectors.

21- Regarding the opinion presented in Paragraph 34, it is worth mentioning that in this meeting, Iran clearly mentioned how to provide more information and access to the agency if needed, but this part of Mr. Eslami’s comment was ignored in this report.

e) Considerations regarding the “summary” section of the report (GOV/2024/8):

22- Islamic Republic Iran is of the opinion that although its cooperation with the Agency is on the right track, it is unnecessary to express regret in this report for what is still going on.

23 – In addition to the explanation provided in paragraph 18 above, it should be noted that the report of the director general is not fully reflected in footnote 33. The last important part of the footnote, which concludes: “In 2014, the Agency re-evaluated this information and assessed that the amount of natural uranium involved is within the uncertainty associated with nuclear material audits and related measurements” is omitted. Instead, a very unusual conclusion was given that “this new element requires further investigation by the Agency”.

24- Iran voluntarily granted access to the Agency. He provided information and explanations about these places to the agency. Meanwhile, the Agency did not submit a valid documents to Iran regarding its claim of “non -declared nuclear materials and nuclear -related activities”, and Iran was never obliged to consider invalid and fabricated documents as information related to the sanctity. Reply agency requests. However, unfortunately, the Agency considers all fabricated documents and fake information provided by the Israeli regime. This has led the agency to have a misconception and unreliable assessment.

25- In paragraph 42, the Director General is unjustly to “convict The intense “what the” sudden cancellation of the appointment of several of the IAEA inspectors is called by Iran … “continues, it should be noted that the Director General is expected to submit his report based on facts, not emotions. Therefore, the expression of “strongly condemn” is not a professional and should be avoided. The Islamic Republic of Iran also expresses concern over the politicization of the issue that is reflected in statements and reports with political and non -constructive motives and exclusively criticized and condemned Iran for its legitimate rights. The Agency must be fully respected by Iranian law in accordance with the CSA Comprehensive Saffron Agreement, including Article 9. Any attempt to deny or violate Iran’s sovereignty will not be accepted.

26- In the case of the Director General Reference to the Joint Declaration (paragraph 43), it should be noted that the joint statement It is voluntary in itself and its proper realization requires mutual good intentions. It should not be expected that Iran will accept the burden of realization alone without the useful effort of the other party. In addition, these voluntary measures require an agreement on the method of doing so.

27- in response to paragraph 44, as officially announced on various occasions. Nuclear weapons never have any place in the Islamic Republic of Iran’s defense doctrine. Therefore, there is no basis for interpreting individual statements in public statements. The Director-General is not expected to submit a safeguards based on individual views that such a conclusion is not legally and professionally compared to the CSA.

28- The Islamic Republic of Iran has so far provided its full cooperation with the CSA. It should be reiterated that all Iran’s nuclear materials and activities have been fully announced to the Agency and have been verified by the Agency.

29- The Islamic Republic of Iran is rightly expected. The Agency of its reports on verification activities in Iran on the basis of neutrality, professional and objectively. Iran has been fully announced to the Agency and has passed through a very strong verification system. Although the Islamic Republic of Iran has no obligation to answer agency questions based on fabricated and invalid documents, Iran has voluntarily and cooperative approach, Iran has provided all the necessary information, backup documents and accessories requested by the Agency.

31- The Islamic Republic of Iran reiterates the importance and value of cooperation provided to the Agency. This constructive cooperation should not be weakened by short -sighted political interests. Accordingly, the Agency is obliged to demonstrate its rationality in dealing with such issues in a diligent way to prevent the distortion of the larger image of cooperation between Iran and the Agency.

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