If completed, the Fordow Fuel Enrichment Plant (FFEP) will be Iran's second pilot enrichment plant. [2] The plant's site was originally a tunnel facility associated with Iran's IRGC. An IAEA report stated that the Agency had obtained commercial satellite images indicating construction at the site between 2002 and 2004. [3] However, it is unclear whether those activities were related to the FFEP. The Institute for Science and International Security (ISIS) assessed that Iran began constructing the FFEP between 10 June 2006 and 17 June 2007. [4] This contradicts Tehran's claim that construction began in the second half of 2007. [5] The facility is intended to hold 16 IR-1 gas centrifuge cascades with a total of approximately 3,000 centrifuges, and is still under construction. [6]

Tehran revealed the facility in a 21 September 2009 letter to the IAEA. [7] However, the letter did not indicate the facility's location. Thereafter, a 25 September 2009 joint statement by President Obama, President Sarkozy, and Prime Minister Brown revealed the site's location as near Qom. [8] The three Western leaders argued that the new facility was a violation of Iran's IAEA Safeguards Agreement (INFCIRC/214). IAEA Director General Mohamed El-Baradei also asserted that "Iran should have informed the IAEA the day they had decided to construct the facility," an argument based on Tehran's Modified Code 3.1 agreement. [9] In 2003, Iran agreed to modify its Subsidiary Arrangements (Modified Code 3.1) with the IAEA. The original arrangement required it to report new facilities no later than 180 days before they were scheduled to receive nuclear material, while the modified arrangement required Iran to immediately report planned nuclear facilities.[10] Iran countered that it had backed out of the arrangement in protest of UN sanctions in March 2007, and justified its unilateral abrogation of the arrangement by claiming that its parliament, the Majilis, never ratified Modified Code 3.1.[11] However, Iran - like every other state that deals with the IAEA - modifies its subsidiary arrangements without parliamentary ratification, effectively negating this argument.[12] The IAEA also disputes Iran's ability to unilaterally withdraw from its Subsidiary Arrangements, and has never accepted Iran's 2007 decision to do so.[13] Regardless of the validity of Iran's claim, satellite imagery and intelligence sources indicate that construction began no later than 2005, at least two years before Iran's attempted withdrawal from Modified Code 3.1. Thus, experts such as Jeffrey Lewis and James Acton argue that Iran should be considered in violation of its Safeguards Agreement. [14]

The plant's size, secrecy, and location on an IRGC base have also led some analysts in the U.S. government to question the facility's true purpose - they argue that Iran constructed it in order to covertly produce weapons-grade highly enriched uranium (HEU).[15] Iran disputes such assertions and claims that the facility was hidden underground due to the risk of a U.S. or Israeli attack.[16] Iranian officials also insist that the plant will only enrich uranium up to the 5% U-235 required for nuclear power.[17] Economically, however, this makes little sense. A 3,000-centrifuge cascade is not sufficient for industrial-scale production of low enriched uranium (LEU) for nuclear reactor fuel.[18] Ivan Oelrich and Ivanka Barzashka of the Federation of American Scientists (FAS) concluded that the FFEP is "neither ideal for commercial nor for military purposes..."[19] According to their assessment, it would take Iran four years to enrich natural uranium to HEU levels for one nuclear bomb.[20] ISIS analysts David Albright and Paul Brannan contested this, arguing that Iran could enrich natural uranium to HEU levels within one year.[21]

On 4 October 2009, Iran agreed to give IAEA inspectors full access to the FFEP. [22] On 26 and 27 October 2009, Agency inspectors verified that the facility conformed to initial design specifications provided by Iran and that no centrifuges or nuclear material had been introduced, although the FFEP was already at an advanced stage of construction.[23] Following the inspection, the IAEA continued to question the FFEP's initial construction date and intended purpose. The Agency also said that Iran's late declaration of the FFEP "gives rise to questions about whether there were any other nuclear facilities in Iran which had not been declared to the Agency." Iran responded by stating that there are no other unreported nuclear facilities under construction, and that any such facilities would "be reported to the Agency according to Iran's obligations to the Agency."[24] However, Iran's obligations under Modified Code 3.1 of the Subsidiary Arrangement remain under dispute with the IAEA. As of November 2010, construction at the facility was ongoing but no centrifuges had been introduced. [25]

Sources:
[1] ISIS satellite imagery analysis indicates that the FFEP is 30km northeast of Qom. According to a 16 November 2009 IAEA report, the FFEP is "about" 20km north of Qom. See: Institute for Science and International Security, "New Satellite Imagery of Suspected Gas Centrifuge Site Near Qom, Iran," Institute for Science and International Security Imagery Brief, 27 September 2009, www.isis-online.org; International Atomic Energy Agency, "Implementation of the NPT Safeguards Agreement and relevant provisions of Security Council Resolutions 1737 (2006), 1747 (2007), 1803 (2008), and 1835 (2008) in the Islamic Republic of Iran," Report by the Director General, 16 November 2009, www.iaea.org.
[2] David Sanger and William Broad, "U.S. and Allies Warn Iran over Nuclear Deception," The New York Times, 25 September 2009.
[3] International Atomic Energy Agency, "Implementation of the NPT Safeguards Agreement and relevant provisions of Security Council Resolutions 1737 (2006), 1747 (2007), 1803 (2008), and 1835 (2008) in the Islamic Republic of Iran," Report by the Director General, 16 November 2009, www.iaea.org.
[4] Paul Brannan, "New satellite image further narrows Fordow construction start date," Institute for Science and International Security, 18 November 2009, p. 1, www.isis-online.org.
[5] International Atomic Energy Agency, "Implementation of the NPT Safeguards Agreement and relevant provisions of Security Council Resolutions 1737 (2006), 1747 (2007), 1803 (2008), and 1835 (2008) in the Islamic Republic of Iran," Report by the Director General, 16 November 2009, www.iaea.org.
[6] "Implementation of the NPT Safeguards Agreement and relevant provisions of Security Council resolutions in the Islamic Republic of Iran," Report by the Director General, 23 November 2010, www.iaea.org.
[7] David Sanger and William Broad, "U.S. and Allies Warn Iran over Nuclear Deception," The New York Times, 25 September 2009.
[8] The White House Office of the Press Secretary, "Statements by President Obama, French President Sarkozy, and British Prime Minister Brown on Iranian Nuclear Facility," 25 September 2009, www.whitehouse.gov.
[9] "IAEA to Inspect Iran's Qom Site October 25," Reuters, 4 October 2009.
[10] James Acton, "Iran Violated International Obligations on Qom Facility," Carnegie Endowment for International Peace, 25 September 2009, www.carnegieendowment.org.
[11] Mark Heinrich, "FACTBOX - Iran's second nuclear enrichment plant," Reuters (Vienna), 29 September 2009; Nima Gerami and James Acton, "What Else is Iran Hiding," Foreign Policy, 28 September 2009.
[12] Nima Gerami and James Acton, "What Else is Iran Hiding," Foreign Policy, 28 September 2009.
[13] James Acton, "Iran Violated International Obligations on Qom Facility," Carnegie Endowment for International Peace, 25 September 2009, www.carnegieendowment.org.
[14] Jeffrey Lewis, "Qom Enrichment Facility Roundup," Arms Control Wonk Blog, 28 September 2009, www.armscontrolwonk.com; James Acton, "Iran Violated International Obligations on Qom Facility," Carnegie Endowment for International Peace, 25 September 2009, www.carnegieendowment.org.
[15] David Sanger and William Broad, "U.S. and Allies Warn Iran over Nuclear Deception," The New York Times, 25 September 2009.
[16] Mark Heinrich, "FACTBOX - Iran's second nuclear enrichment plant," Reuters (Vienna), 29 September 2009.
[17] Mark Heinrich, "FACTBOX - Iran's second nuclear enrichment plant," Reuters (Vienna), 29 September 2009.
[18] According to FAS, in order to enrich enough LEU for one year of fuel at a standard 1,000MW reactor, a 3,000-centrifuge cascade would require 90 years of operation. See: Ivanka Barzashka, "The QOM Enrichment Facility - What and How Do We Know?" FAS Strategic Security Blog, 29 September 2009, www.fas.org.
[19] Ivan Oelrich and Ivanka Barzashka,"A technical evaluation of the Fordow fuel enrichment plant," Bulletin of the Atomic Scientists, 23 November 2009, www.bulletin.org.
[20] Ivan Oelrich and Ivanka Barzashka, "A technical evaluation of the Fordow fuel enrichment plant," Bulletin of the Atomic Scientists, 23 November 2009, www.bulletin.org.
[21] The dispute between the analysts evolved around differing assessments of the separative power of Iran's IR-1 centrifuges. Oelrich and Barazshka calculated a separative power of 0.44 Separative Work Units (SWU) per year, based on the recent performance of the IR-1 centrifuges at the enrichment plant in Natanz. Albright and Brannan assumed an enrichment output of approximately 1.0-1.5 SWU per year, stating that Oelrich and Barzashka significantly underestimate the performance of the Natanz facility. See: David Albright and Paul Brannan, "Critique of Recent Bulletin of Atomic Scientists Article on the Fordow Enrichment Plant," Institute for Science and International Security, 30 November 2009, www.isis-online.org; Ivan Oelrich and Ivanka Barzaska, "Calculating the Capacity of Fordow," FAS Issue Brief, Federation of American Scientists, 1 December 2009; David Albright and Paul Brannan, "Further comments regarding the BAS article on Fordow," Institute for Science and International Security, 4 December 2009, www.isis-online.org.
[22] Parisa Hafezi, "IAEA to inspect Iran's Qom site Oct. 25," Reuters (Tehran), 5 October 2009.
[23] International Atomic Energy Agency, "Implementation of the NPT Safeguards Agreement and relevant provisions of Security Council Resolutions 1737 (2006), 1747 (2007), 1803 (2008), and 1835 (2008) in the Islamic Republic of Iran," Report by the Director General, 16 November 2009, www.iaea.org.
[24] International Atomic Energy Agency, "Implementation of the NPT Safeguards Agreement and relevant provisions of Security Council Resolutions 1737 (2006), 1747 (2007), 1803 (2008), and 1835 (2008) in the Islamic Republic of Iran," Report by the Director General, 16 November 2009, www.iaea.org.
[25] International Atomic Energy Agency, "Implementation of the NPT Safeguards Agreement and relevant provisions of Security Council Resolutions 1737 (2006), 1747 (2007), 1803 (2008), and 1835 (2008) in the Islamic Republic of Iran," Report by the Director General, 23 November 2010, www.iaea.org.