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GAO-10-515R: 

United States Government Accountability Office: 
Washington, DC 20548: 

March 23, 2010: 

The Honorable Joseph I. Lieberman:
Chairman:
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Jon Kyl:
Ranking Member:
Subcommittee on Terrorism and Homeland Security: 
Committee on the Judiciary:
United States Senate: 

Subject: Firms Reported in Open Sources as Having Commercial Activity 
in Iran's Oil, Gas, and Petrochemical Sectors: 

Iran's oil and gas industry is vital to its economy and government. 
Oil export revenues have accounted for more than 24 percent of Iran's 
gross domestic product and between 50 and 76 percent of the Iranian 
government's revenues in recent years.[Footnote 1] Iran has the 
world's third largest oil reserves and second largest gas reserves, 
according to the Congressional Research Service (CRS), and is the 
world's fourth largest producer of crude oil, according to the Central 
Intelligence Agency (CIA) World Factbook.[Footnote 2] However, Iran 
has not reached peak crude oil production levels since 1978, does not 
produce sufficient natural gas for domestic use, and lacks the 
refining capacity to meet domestic demand for gasoline, according to 
the Department of Energy (DOE) and IHS Global Insight.[Footnote 3] IHS 
Global Insight reports that Iran's priorities for the next five years 
are to (1) raise oil production and exports as much as possible, (2) 
increase natural gas production for domestic use, and (3) expand 
refining capacity if financially and technically possible. CRS 
reported that the Deputy Minister of the National Iranian Oil Company 
said in November 2008 that Iran would need about $145 billion in new 
investment over the next 10 years to build a thriving energy sector. 
Accordingly, Iran is seeking the participation of foreign firms in 
providing financing and technical assistance in numerous oil, gas, and 
petrochemical projects, according to DOE. Although Iran prohibits non-
Iranian firms from obtaining an ownership interest by investing in oil 
and gas fields, Iran allows them to enter into "buy-back" arrangements 
in which the foreign firms may receive entitlements to oil or gas for 
a limited time in exchange for the funds they expend on the project, 
according to DOE.[Footnote 4] 

U.S. law restricts U.S. firms from investing in Iran's energy sector 
through a variety of sanctions administered by the Department of the 
Treasury to discourage Iran from supporting terrorism and developing 
nuclear weapons.[Footnote 5] In addition, the Iran Sanctions Act, as 
amended, provides for sanctions against persons, including foreign 
firms, who invest more than $20 million in Iran's energy sector in any 
12-month period.[Footnote 6] For example, the Act allows the 
President, who delegated authority under the Act to the Secretary of 
State, to restrict loans to sanctioned firms and ban them from U.S. 
government procurement.[Footnote 7] The Secretary of State may waive 
the sanctions if the Secretary determines that it is important to the 
national interests of the United States to do so.[Footnote 8] For 
example, in 1998, the Secretary of State waived sanctions against a 
consortium of foreign firms due, in part, to the high level of 
cooperation with the European Union on counterproliferation and 
counterterrorism efforts involving Iran.[Footnote 9] See enclosure IV 
for more on the Iran Sanctions Act. 

Our December 2007 report on Iran sanctions included a list of foreign 
firms potentially investing in Iran's energy sector from 2003 to 2007. 
[Footnote 10] In 2009, a majority of members of Congress sponsored the 
Iran Refined Petroleum Sanctions Act of 2009, which would impose 
sanctions against firms that export gasoline and other refined 
petroleum products to Iran.[Footnote 11] As of March 2010, Congress 
was considering this proposed legislation. This correspondence (1) 
provides a list of foreign firms reported in open sources as engaging 
in commercial activity in Iran's oil, gas, or petrochemical sectors 
from 2005 to 2009 and (2) provides information about these sectors. 
[Footnote 12] We define commercial activity as having signed an 
agreement to conduct business, invested capital, or received payment 
for the provision of goods or services in the Iranian oil, gas, or 
petrochemical sectors. We did not review the contracts and documents 
underlying these transactions and did not independently verify these 
transactions. We did not attempt to determine whether the firms in 
this list meet the legal criteria for an investment specified in the 
Iran Sanctions Act. The Secretary of State is responsible for making 
such determinations. 

To accomplish our objectives, we reviewed open source information, 
including industry standard trade publications and corporate 
statements. We listed a firm as having commercial activity in Iran's 
oil, gas, or petrochemical sectors if three reputable industry 
publications or the firm's corporate statements reported the firm to 
have signed an agreement to conduct business; invested capital; or 
received payment for providing goods or services in connection with a 
specific Iranian oil, gas, or petrochemical project. We provided the 
firms on our list an opportunity to comment on the information in our 
table. While we obtained information from DOE, the Department of 
State, and U.S. intelligence agencies, we used only open source data 
for this report. See enclosure I for a full description of our scope 
and methodology. 

We conducted our work from September 2009 to March 2010 in accordance 
with all sections of GAO's Quality Assurance Framework that are 
relevant to our objective. The framework requires that we plan and 
perform the engagement to obtain sufficient and appropriate evidence 
to meet our stated objective and discuss any limitations in our work. 

Forty-One Foreign Firms Had Commercial Activity in Iran's Oil, Gas, or 
Petrochemical Sectors from 2005 to 2009, According to Open Source 
Information: 

Based on our review of open source information, we identified 41 
foreign firms that had commercial activity in the development of the 
Iranian oil, gas, and petrochemical sectors from 2005 to 2009. These 
firms are listed in table 1. Open source information stated that these 
firms supported activities throughout Iran that involved the 
exploration and development of oil and gas, petroleum refining, or 
petrochemicals, including the construction of pipelines and tankers 
for the transport of oil or gas. (See figure 1 for a map of Iranian 
oil, gas, and petrochemical activities). According to the open source 
information, the firms provide technical expertise, equipment, or 
funding that enables Iran to increase the productive capacity and 
profitability of its oil, gas, and petrochemical sectors. See 
enclosure II for a more detailed description of the firms' reported 
activities in Iran, and see enclosure III for a glossary of terms used 
in this report. 

The following table presents information gathered from reputable 
industry standard publications and firms' public statements. We did 
not attempt to determine whether the firms in this list meet the legal 
criteria specified in the Iran Sanctions Act. 

Table 1: Foreign Firms' Publicly Reported to Have Commercial Activity 
in the Iranian Oil, Gas, or Petrochemical Sectors: 

Firm: Amona; 
Country[A]: Malaysia; 
Sector: Oil exploration and production. 

Firm: Belneftekhim; 
Country[A]: Belarus; 
Sector: Oil exploration and production. 

Firm: China National Offshore Oil Corporation; 
Country[A]: China; 
Sector: Natural gas. 

Firm: China National Petroleum Corporation; 
Country[A]: China; 
Sector: Oil exploration and production, natural gas. 

Firm: Costain Oil, Gas & Process Ltd.; 
Country[A]: United Kingdom; 
Sector: Natural gas. 

Firm: Daelim; 
Country[A]: South Korea; 
Sector: Natural gas. 

Firm: Daewoo Shipbuilding & Marine Engineering; 
Country[A]: South Korea; 
Sector: Oil tankers. 

Firm: Edison; 
Country[A]: Italy; 
Sector: Oil exploration and production. 

Firm: ENI; 
Country[A]: Italy; 
Sector: Oil exploration and production. 

Firm: Gazprom; 
Country[A]: Russia; 
Sector: Oil exploration and production, pipeline. 

Firm: GS; 
Country[A]: South Korea; 
Sector: Natural gas. 

Firm: Haldor Topsoe; 
Country[A]: Denmark; 
Sector: Refining. 

Firm: Hinduja; 
Country[A]: United Kingdom; 
Sector: Oil exploration and production, natural gas. 

Firm: Hyundai Heavy Industries; 
Country[A]: South Korea; 
Sector: Oil tankers. 

Firm: INA; 
Country[A]: Croatia; 
Sector: Oil exploration and production, natural gas. 

Firm: Indian Oil Corporation; 
Country[A]: India; 
Sector: Natural gas. 

Firm: Inpex; 
Country[A]: Japan; 
Sector: Oil exploration and production. 

Firm: JGC Corporation; 
Country[A]: Japan; 
Sector: Refining. 

Firm: Lukoil; 
Country[A]: Russia; 
Sector: Oil exploration and production. 

Firm: LyondelBasell; 
Country[A]: Netherlands; 
Sector: Petrochemicals. 

Firm: Oil India Ltd.; 
Country[A]: India; 
Sector: Natural gas. 

Firm: Oil and Natural Gas Corporation; 
Country[A]: India; 
Sector: Oil exploration and production, natural gas. 

Firm: OMV; 
Country[A]: Austria; 
Sector: Natural gas. 

Firm: ONGC Videsh Ltd.; 
Country[A]: India; 
Sector: Natural gas. 

Firm: Petrobras; 
Country[A]: Brazil; 
Sector: Oil exploration and production. 

Firm: Petrofield; 
Country[A]: Malaysia; 
Sector: Natural gas. 

Firm: Petroleos de Venezuela S.A.; 
Country[A]: Venezuela; 
Sector: Natural gas. 

Firm: Petronet LNG; 
Country[A]: India; 
Sector: Natural gas. 

Firm: PGNiG; 
Country[A]: Poland; 
Sector: Natural gas. 

Firm: PTT Exploration & Production; 
Country[A]: Thailand; 
Sector: Natural gas. 

Firm: Repsol; 
Country[A]: Spain; 
Sector: Natural gas. 

Firm: Royal Dutch Shell; 
Country[A]: Netherlands; 
Sector: Natural gas. 

Firm: Sinopec; 
Country[A]: China; 
Sector: Oil exploration and production, refining. 

Firm: SKS Ventures; 
Country[A]: Malaysia; 
Sector: Natural gas. 

Firm: Snamprogetti; 
Country[A]: Italy; 
Sector: Pipeline. 

Firm: StatoilHydro; 
Country[A]: Norway; 
Sector: Oil exploration and production, natural gas. 

Firm: Tecnimont; 
Country[A]: Italy; 
Sector: Petrochemicals. 

Firm: Total; 
Country[A]: France; 
Sector: Natural gas. 

Firm: Turkish Petroleum Company; 
Country[A]: Turkey; 
Sector: Natural gas. 

Firm: Uhde; 
Country[A]: Germany; 
Sector: Petrochemicals. 

Source: GAO analysis of open source information. 

[A] The country listed is the physical location of the firm as 
reported in open sources. 

[B] ABB Lummus no longer exists as a firm. ABB of Switzerland sold the 
Lummus Group in 2007 to Chicago Bridge and Iron Company (CB&I) of the 
United States. ABB and CB&I told us they no longer have commercial 
activity in Iran. 

[End of table] 

Figure 1: Map of Iranian Oil, Gas, and Petrochemical Activities: 

[Refer to PDF for image: illustrated map of Iran] 

The following items are depicted on the map: 

Oilfield; 
Oil pipeline; 
Gasfield; 
Gas pipeline; 
Refinery; 
Gas-processing plant; 
Tanker terminal; 
Agreed-upon maritime boundary. 

Source: GAO analysis of U.S. Department of Energy data. 

[End of figure] 

Foreign Firms Are Reportedly Supporting Multiple Iranian Oil, Gas, or 
Petrochemical Sector Activities: 

According to open sources, foreign firms are supporting Iranian 
activities in oil and gas exploration and production, refining, 
petrochemicals, and pipelines and tankers. While some firms are 
reported to be involved in multiple activities, most were involved in 
a single activity. Using open source information, we identified 14 
firms as involved in exploration and production of crude oil 
resources, 4 firms in expanding refining capacity, 23 firms in the 
development of natural gas resources, 4 firms in the production of 
petrochemicals, and 4 firms in oil and gas pipelines and tankers. Open 
source information reported that 8 firms were involved in multiple 
activities (such as natural gas and petrochemicals), and these firms 
are counted in each of the activity descriptions. 

Oil Exploration and Production: 

Using open source information, we identified 14 foreign firms as 
having commercial activity in Iran's crude oil exploration and 
production efforts. For example, the China National Petroleum 
Corporation is reported to be financing 90 percent of the development 
of the North Azadegan oil field, in an agreement estimated at more 
than $2 billion. As of January 2010, Iran faces a funding shortage and 
is reportedly prioritizing foreign investment in oil exploration and 
development efforts at the expense of downstream sectors, according to 
IHS Global Insight. Iran particularly needs technological assistance 
to increase the level of oil production in fields where oil reserves 
have declined over time, according to DOE. According to the IMF, 
Iran's oil production has remained virtually flat in recent years and 
will likely stagnate in the medium term due to insufficient 
investment. Iran requires increasingly modern and advanced enhanced 
oil recovery technologies in order to stop natural declines of oil 
production, but has found advanced technology difficult to import due 
to international sanctions and high costs. As a result, Iran depends 
on older methods to maintain oil recovery from its mature oil fields, 
such as injecting massive quantities of natural gas into oil 
reservoirs, according to DOE and IHS Global Insight. Due to the lack 
of investment, the natural decline in oil reserves, and other factors, 
Iran has been unable to continue producing oil at its peak level of 
over 5 million barrels per day since 1978.[Footnote 13] 

Refining Capacity: 

Using open source information, we identified 4 firms that are involved 
in expanding and upgrading the refining capacity of Iran. For example, 
JGC Corporation of Japan is reported to be assisting in the expansion 
of the Arak refinery, in an agreement estimated at $25 million. 
According to DOE, Iran does not currently have sufficient refining 
capacity to meet its domestic demand for gasoline. In 2007 and 2008, 
Iranian gasoline production averaged less than 300,000 barrels per 
day, while daily domestic gasoline consumption averaged approximately 
400,000 barrels. Although Iran imposed gasoline rationing in 2007, it 
imported approximately 130,000 barrels of gasoline per day in 2009, as 
well as other refined products such as diesel fuel. Iran's nine 
refineries are operated by the National Iranian Oil Refining and 
Distribution Company (NIORDC), according to DOE. With the potential 
participation of foreign companies, Iran plans to add capacity at 8 
refineries to fully meet domestic demand for gasoline by 2013 or 2014, 
according to CRS and DOE officials. However, Iran's plans for doing so 
may fall behind schedule because it has recently placed a higher 
priority on finding and developing crude oil to address funding 
shortages, according to IHS Global Insight. 

Natural Gas: 

Using open source information, we identified 23 firms as having 
commercial activity in the development of Iran's natural gas 
resources. For example, Hinduja of the United Kingdom and Oil and 
Natural Gas Corporation of India reportedly signed an agreement in 
December 2009 for a 40 percent stake in developing phase 12 of Iran's 
massive South Pars offshore gas field, a project estimated to cost 
$7.5 billion. Iran's domestic consumption of natural gas has increased 
rapidly over the past 20 years, and development of natural gas 
resources would better position Iran to meet domestic demand. 
According to U.S. officials, between 20 and 25 percent of Iran's 
natural gas is currently reinjected into mature oil fields to enhance 
oil recovery. According to IHS Global Insight, Iran has failed to 
develop its natural gas production quickly enough and is only 
preventing shortages by importing natural gas from other countries, 
such as Turkmenistan. Iran also plans to expand its development of 
liquefied natural gas (LNG), but this plan requires significant 
investment from international partners and has become less of a 
priority as Iran has recently focused limited funds on oil exploration 
and production projects. However, Iran continues to have three major 
LNG projects in various stages of development--Iran LNG, Pars LNG, and 
Persian LNG--all of which are associated with a phase of the South 
Pars development.[Footnote 14] 

Petrochemicals: 

Using open source information, we identified 4 firms as involved in 
the production of petrochemicals. For example, LyondelBasell of the 
Netherlands is reported to be licensing technology for a petrochemical 
plant that is expected to increase capacity by 300,000 metric tons per 
year. The main raw materials used in petrochemical production are 
derived from oil and natural gas, according to DOE. Natural gas and 
other products of the refining process are shipped to chemical plants, 
where they are used to manufacture more complex petrochemicals and 
plastics. Petrochemical products include ethylene, propylene, benzene, 
and similar nonfuel products, such as asphalt, road oil, lubricants, 
solvents, and wax. According to Oil and Gas Journal, expanding 
petrochemical production allows a country with large oil and natural 
gas resources to use them more profitably. 

Pipelines and Tankers: 

Using open source information, we identified 4 firms as having 
commercial activity in Iran's oil and gas pipelines and tankers. For 
example, in 2009, Daewoo Shipbuilding and Marine Engineering of South 
Korea reportedly delivered crude oil tanker ships to Iran, as part of 
a contract valued at $384 million. Iranian officials have stated that 
Iran needs large investments in its natural gas infrastructure, 
including pipelines. In addition, while Iran has over 40 tankers, Iran 
recently purchased additional tankers for shipping crude oil. The 
total capacity of Iran's tankers is 9.56 million deadweight tons (for 
a total capacity of 70 million barrels, or about 2.4 percent of the 
world total oil tanker capacity). 

Agency Comments: 

We provided a draft report to the Department of State and Department 
of Energy for their review. The agencies provided technical comments 
which were incorporated into the report. 

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 interested 
committees, the Secretary of State, and the Secretary of Energy. In 
addition, the report will be available at no charge on the GAO Web 
site at [hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at 202-512-8979 or christoffj@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Major contributors to this report 
include Tetsuo Miyabara (Assistant Director), JoAnna Berry, Colleen 
Candrl, Jon Fremont, Phillip Farah, Lauren Membreño, and Pierre 
Toureille. Technical support was provided by Martin De Alteriis, Grace 
Lui, Rebekah Boone, and Patrick Breiding. 

Sincerely, 

Signed by: 

Joseph A. Christoff: 
Director, International Affairs and Trade: 

[End of section] 

Enclosure I: Scope and Methodology: 

To develop this report, we analyzed open source information that was 
determined to be credible and comprehensive by information specialists 
and an energy expert within GAO. Open source information data is 
overt, publicly available information, as opposed to covert or 
classified sources. Open source information is a key component of 
traditional intelligence and information-gathering agencies, such as 
the Central Intelligence Agency. Open source information can provide a 
very broad range of useful data for analysis, but the validity of an 
analysis can be put at risk if it relies on open sources that contain 
inaccurate, imprecise, incomplete, or otherwise faulty information. We 
took a series of steps to mitigate this risk in developing our 
analysis. 

First, we relied only on government reports and information, energy 
industry trade publications from around the world, corporate web site 
information, and professional trade association analysis. We obtained 
reports and information from the Department of Energy (DOE), the 
Congressional Research Service (CRS), other U.S. government agencies, 
the International Monetary Fund, and the Organization of Petroleum 
Exporting Countries (OPEC). We searched information from approximately 
200 industry trade publications from January 2005 to December 2009, 
including Oil and Gas Journal, Oil and Gas News, Platt's Publications, 
Petroleum Economist, Energy Compass, and World Refining & Fuels Today. 
We excluded sources deemed insufficiently reliable, such as newspaper 
reports, newswires, and direct news releases from the Iranian 
government. We searched company web sites for press releases and 
corporate statements that made their activities in Iran public, or 
corrected information that had been publicly reported. In addition, we 
interviewed officials from the Department of Energy, the Department of 
State, and U.S. intelligence agencies. 

Second, we required multiple corroborating sources of information for 
every entry in our list of firms reported to have commercial activity 
in Iran's oil, gas, and petrochemical sectors (see tables 1 and 2). We 
collected and reviewed thousands of articles; extracted relevant 
information about firms involved in Iran; organized and analyzed the 
information using data-analysis software designed to aid in processing 
unstructured data from multiple sources; and developed a final listing 
based on an evidentiary threshold established through consistently- 
applied decision rules. We generated a preliminary listing of firms 
reported to have commercial activity in Iran's oil, gas, or 
petrochemical sectors. We defined commercial activity as having signed 
an agreement to conduct business, invested capital, or received 
payment for the provision of goods or services in the Iranian oil, 
gas, or petrochemicals sectors. To generate the preliminary listing, 
we analyzed information in Oil and Gas Journal's WorldWide 
Construction Update reports from 2005 through 2009. This publication 
conducts a global survey of ongoing and planned oil and gas 
contractors and firms working in sectors such as pipelines, refining, 
and engineering, and is greatly trusted and utilized by other U.S. 
government agencies and those familiar with the international oil 
industry. We verified the survey methodology with Oil and Gas 
Journal's Survey Editor and found it was sufficiently reliable for our 
purposes. We then began to confirm these firms' commercial activity in 
Iran by conducting searches in approximately 200 industry trade 
publications between January 2005 and December 2009. The trade 
publications were compiled by Nexis and include publications where 
more than 60 percent of the stories pertain to the oil industry. This 
generated several thousand additional articles listing firms with 
potential commercial activity in Iran. To expand the scope of our 
searches, we searched our sources for specific firms named in U.S. 
government reports as investors in Iran's oil, gas, or petrochemical 
sectors. The U.S. government reports were from DOE, CRS, and other 
government agencies. Finally, we reviewed the source information and 
extracted details about the firm and their projects in Iran, such as 
the purpose of the projects, the amount of the firm's commercial 
activity, and the projects' status. These details were systematically 
organized and tracked using software designed to synthesize large 
quantities of textual information. 

To determine whether the preliminary listing reflected sufficient 
evidence that a firm had commercial activity in Iran, a team of 
analysts reviewed the list and confirmed that one of the following 
criteria had been met: (1) at least three standard industry 
publications cited the firm as having commercial activity in a 
specific project, or (2) the firm provided information on its 
corporate web site about its involvement in a specific project and the 
firm's involvement in the specific project was also cited by at least 
one standard industry publication. If not all analysts were completely 
satisfied that these criteria were met, the firm was not included in 
our listing. Like all GAO products, our evidence also had to convince 
independent GAO fact-checkers--who confirmed that the appropriate 
criteria had been met for all firms--before it could be included in 
our final listing. Our list, therefore, represents a minimum of firms 
with commercial activity in Iran's oil, gas, or petrochemical sectors. 

After confirming that a firm had commercial activity in a specific 
project in Iran, we obtained additional information presented in the 
table--including the firm's commercial activity and the project's 
status--from the industry standard publications. When reports varied 
about certain details of a firm's project, we presented the 
information reported in the most recent source available. Where 
information was not available on the value of a specific firm's 
commercial activity, we reviewed the relevant sources to determine the 
total value of the project in which the firm was involved. In some 
cases, specific information was not reported and is reflected as such 
in the tables. 

Finally, analysts fluent in the appropriate language contacted the 
firms directly by telephone in order to introduce GAO, explain our 
project, and obtain an appropriate point of contact within the firm to 
officially comment on the reported information. Beginning January 14, 
2010, we e-mailed the firms a letter containing information from 
enclosure II concerning the firms' reported activities, giving each 
firm an opportunity to comment. As of March 22, 2010, 13 of the firms 
responded and we have incorporated these responses into enclosure II. 

[End of Enclosure I] 

Enclosure II: Publicly Reported Commercial Activity of Foreign Firms 
in the Iranian Oil, Gas, or Petrochemical Sectors: 

The following table presents information gathered and organized from 
reputable industry standard publications and firms' public statements. 
The details and terminology presented in the table are as reported in 
the original sources. See enclosure III for a glossary of terms 
presented in this table. We provided all firms with an opportunity to 
comment on the information found in open sources. We did not attempt 
to determine whether the firms in this list meet the legal criteria 
specified in the Iran Sanctions Act. 

Table 2: Foreign Firms Publicly Reported Commercial Activity in Iran 
and Firms' Comments Regarding Their Activity: 

Firm/country[A]: ABB Lummus/Not applicable[B]; 
Firm activity: Catalytic cracker in a refining expansion in Abadan; 
Status: Expected completion 2009-2010; 
Commercial activity: Total project to expand refinery estimated to 
cost $450 million; 

Firm activity: Continuous catalytic regenerative in refinery upgrade 
in Bandar Abbas, helping to increase capacity by 80,000 bbl/d; 
Status: Expected completion 2010; 
Commercial activity: Part of $512 million contract; 

Firm activity: Licensed technology to produce ethylene in 
petrochemical expansion in Bandar Imam (moved to Gachsaran in 2007); 
Status: Delayed until 2011; 
Commercial activity: Part of $320 million contract; 

Firm comment: ABB and Chicago Bridge and Iron Company (CB&I) confirmed 
ABB sold Lummus Group to CB&I in 2007. ABB indicated Iran activities 
were part of the Lummus sale. CB&I indicated it prohibited all Lummus 
companies from activities with or in Iran, and CB&I has no current 
activities in Iran. 

Firm/country[A]: Amona/Malaysia; 
Firm activity: Rehabilitation of the Resalat oil field in the Lavan 
area. Drilling 30 wells and building a processing plant, to increase 
output to 47,000 bbl/d; 
Status: Expected completion September 2011; 
Commercial activity: Project valued at $1.53 billion; 
Firm comment: Contacted on February 17, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Belneftekhim/Belarus; 
Firm activity: Oil production in Jofeir field, increasing production 
by 40,000 bbl/d; 
Status: Talks under way to produce oil as of June 2009; 
Commercial activity: Two-year contract signed in 2007 valued at $450 
million; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm/country[A]: China National Offshore Oil Corporation (CNOOC)/China; 
Firm activity: Development of natural gas field and construction of 
liquefied natural gas (LNG) plant; 
Status: Initial agreement reached 2006-2007; final agreement signed 
2009; expected completion in 2015; 
Commercial activity: Project valued at $16 billion. CNOOC to receive 
50% share of LNG product; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm/country[A]: China National Petroleum Corporation (CNPC)/China; 

Firm activity: Oil exploration and development in Masjed-i-Suleiman 
oil field; 
Status: Agreement approved and drilling started in 2007; 
Commercial activity: CNPC has a 75% holding in project; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm activity: Development of the North Azadegan oil field; 
Status: Contract signed in January 2009; 
Commercial activity: Providing 90% of the financing for Azadegan under 
a buy-back contract, a more than $2 billion investment; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm activity: LNG project in South Pars phase 11; 
Status: Contract signed June 2009; 
Commercial activity: 12.5% share of project valued at more than $13 
billion; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Costain Oil, Gas & Process Ltd./United Kingdom; 
Status: Gas refinery/processing plant at Bid Boland II; 
Commercial activity: Expected completion 2009; 
Part of consortium whose contract is valued at $1.7 billion; 
Firm comment: Contacted on January 14, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Daelim/South Korea; 
Status: Construction of liquid storage tanks for Iran LNG project that 
will be fed by phase 12 of South Pars gas field; 
Commercial activity: Expected completion by January 2011; 
Total cost of Iran LNG project is $5 billion, which includes other 
components; 
Firm comment: Confirmed role in project is an engineering and 
procurement contractor, and the value of their work is $162 million. 

Firm/country[A]: Daewoo Shipbuilding and Marine Engineering/South 
Korea; 
Status: Construction of crude oil tanker ships; 
Commercial activity: Delivery was scheduled for 2009, as of 2005; 
Contract for $384 million. Total cost of Iranian tanker building 
program estimated at $2.4 billion; 
Firm comment: Confirmed delivery of tanker ships in August 2009, at an 
estimated contract cost of $384 million. No other sales planned. 

Firm/country[A]: Edison/Italy; 
Firm activity: Oil exploration in offshore Dayyer block in the Persian 
Gulf; 
Status: In 2009, signed contract for four-year exploration period; 
Commercial activity: Four-year contract valued at around $44 million; 
Firm comment:Noted the exploration contract was signed on January 8, 
2008 and not in 2009. 

Firm/country[A]: ENI/Italy; 
Firm activity: Development and operation of first and second phases of 
onshore Darkhovin oil field; 
Status: Signed 5.5 year buy-back contract in 2001; submitted 
feasibility study of third phase in 2009; 
Commercial activity: 2001 contract worth $1 billion and 60% stake; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm activity: Development of phases 4 and 5 of South Pars; 
Status: Completed as of 2006; 
Commercial activity: Buy-back contract with 60% stake; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Gazprom/Russia; 
Firm activity: Construction of new gas pipeline from Iran to Armenia; 
Status: Pipeline inaugurated May 2009; 
Commercial activity: Project valued at $120 million, with Gazprom's 
share at 45%; 
Firm comment: Contacted on February 11, 2010; no response as of March 
22, 2010. 

Firm activity: Exploration and development of Azar oil fields of 
Anaran block; field expected to produce up to 65,000 bbl/d when fully 
developed; 
Status: Memorandum of Understanding signed in November 2009; 
Commercial activity: Not reported; 
Firm comment: Contacted on February 11, 2010; no response as of March 
22, 2010. 

Firm activity: Possible exploration and development of Azadegan oil 
field; 
Status: General cooperation agreement between Iran and Gazprom signed 
in July 2008. Talks continuing as of July 2009; 
Commercial activity: Not reported; 
Firm comment: Contacted on February 11, 2010; no response as of March 
22, 2010. 

Firm/country[A]: GS/South Korea; 
Firm activity: Gas sweetening facility in Phases 6-8 of the South Pars 
gas field; 
Status: Agreement signed October 2009; 
Commercial activity: Value of contract is $1.24 billion; 
Firm comment: Contacted on February 11 and 19, 2010; no response as of 
March 22, 2010. 

Firm activity: Development of South Pars phases 9 and 10, which is 
expected to produce 50 million cubic meters per day of natural gas; 
Status: Expected completion in March 2009; 
Commercial activity: $1.6 billion development contract with GS to lead 
consortium; project valued at $4 billion; 
Firm comment: Contacted on February 11 and 19, 2010; no response as of 
March 22, 2010. 

Firm/country[A]: Haldor Topsoe/Denmark; 
Firm activity: Licensor of a hydrotreater for refinery in Esfahan; 
Status: Completed in 2009; 
Commercial activity: Not reported; 
Firm comment: Confirmed activity. Noted expected completion of 
activity is 2013 to 2014. 

Firm/country[A]: Hinduja/United Kingdom; 
Firm activity: Development of natural gas field in South Pars phase 12; 
Status: Agreement signed in December 2009; 
Commercial activity: Along with India's ONGC, 40% stake in project, 
estimated to cost $7.5 billion to develop; 
Firm comment: GAO letter was sent on February 18, 2010, to the only 
Hinduja entity in the United Kingdom listed on Hinduja's web site. The 
entity responded on March 5, 2010, that it was not the firm cited in 
our sources. A representative did not address our repeated requests 
for contact information for Hinduja (United Kingdom). 

Firm activity: Project to convert natural gas into LNG for export; 
Status: Agreement signed in December 2009; 
Commercial activity: Along with India's ONGC and Petronet LNG, 20% 
stake in project, estimated cost of plant is $4.35 billion; 
Firm comment: GAO letter was sent on February 18, 2010, to the only 
Hinduja entity in the United Kingdom listed on Hinduja's web site. The 
entity responded on March 5, 2010, that it was not the firm cited in 
our sources. A representative did not address our repeated requests 
for contact information for Hinduja (United Kingdom). 

Firm activity: Development of the Azadegan oil field; 
Status: Company involvement reported in 2008 and 2009; 
Commercial activity: Along with India's Oil and Natural Gas 
Corporation (ONGC), 45% stake in the project. Cost of development 
estimated at $2.5 to $3 billion;
Firm comment: GAO letter was sent on February 18, 2010, to the only 
Hinduja entity in the United Kingdom listed on Hinduja's web site. The 
entity responded on March 5, 2010, that it was not the firm cited in 
our sources. A representative did not address our repeated requests 
for contact information for Hinduja (United Kingdom). 

Firm/country[A]: Hyundai Heavy Industries/South Korea; 
Firm activity: Construction of crude oil tanker ships; 
Status: Delivery was scheduled for 2009, as of 2005; 
Commercial activity: Total cost of Iranian tanker building program 
estimated at $2.4 billion; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm/country[A]: INA/Croatia; 
Firm activity: Exploration of Moghan 2 oil and gas block project in 
Ardebil province; 
Status: Contract signed April 2008; 
Commercial activity: Contract worth at least $140 million; 
Firm comment: Confirmed activity. Noted contract value is $40 million. 

Firm/country[A]: Indian Oil Corporation/India; 
Firm activity: Development of Farzad-B natural gas field in the Farsi 
block; 
Status: Part of consortium that is exploring the Farsi block and that 
submitted a 2009 plan to develop the gas field over a 7-to 8-year 
period; 
Commercial activity: 40% stake in the project, with an estimated total 
investment of $5 billion; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Inpex/Japan; 
Firm activity: Development of Azadegan oil field; 
Status: Initial agreement in 2004, revised in 2006. Iran proceeding 
with initial development using local companies; 
Commercial activity: 75% share was reduced to 10% in 2006; 
Firm comment: Confirmed share was reduced to 10% in October 2006, and 
the role of operator was transferred to an Iranian company. 

Firm/country[A]: JGC Corporation/Japan; 
Firm activity: Expansion of Arak refinery to produce 250,000 bbl/d; 
Status: Completion was estimated for 2009; 
Commercial activity: Arak refinery expansion project worth $25 million; 
Firm comment: Confirmed activity. Noted involvement was in the initial 
project design, and their activity was completed nearly 5 years ago. 

Firm/country[A]: Lukoil/Russia; 
Firm activity: Oil exploration and development of the Anaran block in 
Zagros Mountains, including Azar, Changuleh West, Dehloran, and Musian; 
Status: Activities reported halted in 2007 due to threat of U.S. 
sanctions; 
Commercial activity: Lukoil had 25% stake in project; project cost is 
more than $1 billion; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm/country[A]: LyondelBasell/The Netherlands; 
Firm activity: Supplying technology for new HDPE petrochemical plant 
in Kermanshah, increasing capacity by 300,000 metric tons per year; 
Status: Expected completion 2009 to 2010; 
Commercial activity: Not reported; 
Firm comment: Confirmed activities. Noted that profits from the two 
projects are small compared to its European operations. 

Firm activity: Supplying technology for LDPE plant in Sanandaj; 
Status: Startup was scheduled for 2008; 
Commercial activity: Not reported; 
Firm comment: Confirmed activities. Noted that profits from the two 
projects are small compared to its European operations. 

Firm/country[A]: Oil India Ltd. (OIL)/India; 
Firm activity: Development of Farzad-B natural gas field in the Farsi 
block; 
Status: Part of a consortium that is exploring the Farsi block and 
that submitted a 2009 plan to develop the gas field over a 7- to 8-
year period; 
Commercial activity: 20% stake in the project, with an estimated total 
investment of $5 billion; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Oil and Natural Gas Corporation (ONGC)/India; 
Firm activity: Development of natural gas field in South Pars phase 12; 
Status: Agreement signed in December 2009; 
Commercial activity: Along with United Kingdoms's Hinduja, 40% stake 
in project, estimated to cost $7.5 billion to develop; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm activity: Project to convert natural gas from South Pars into LNG 
for export; 
Status: Agreement signed in December 2009; 
Commercial activity: Along with Hinduja and India's Petronet LNG, 20% 
stake in project. Estimated cost of plant is $4.35 billion; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm activity: Development of the Azadegan oil field; 
Status: Company involvement reported in 2008; 
Commercial activity: Along with Hinduja, 45% stake in the project. 
Cost of development estimated at $2.5 to $3 billion; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm/country[A]: OMV/Austria; 
Firm activity: Development of South Pars natural gas fields and share 
of Iran LNG; 
Status: Signed preliminary agreement in 2007; 
Commercial activity: Total project value is potentially $30 billion; 
Firm comment: Confirmed that agreement was signed with the National 
Iranian Oil Company in 2007 to develop South Pars phase 12 and Iran 
LNG. Since 2007, further nonbinding negotiations. Also noted a 2001 
exploration contract for Mehr block that ended in 2009 due to 
technical and economical constraints. 

Firm/country[A]: ONGC Videsh Ltd. (OVL)/India; 
Firm activity: Development of Farzad-B natural gas field in the Farsi 
block; 
Status: Part of consortium that is exploring the Farsi block and which 
submitted a 2009 plan to develop the gas field over a 7-to 8-year 
period; 
Commercial activity: 40% stake in the project (along with India Oil 
Corporation and Oil India Ltd.), with an estimated total investment of 
$5 billion; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Petrobras/Brazil; 
Firm activity: Completed exploratory activities in the Tusan block; 
Status: Returned its concession in 2009; 
Commercial activity: Spent $178 million before returning its 
concession; 
Firm comment: In 2004, a subsidiary of Petrobras signed service 
contract to explore Tusan; 
contract expired in July 2008. Confirmed project costs of $178 
million. Currently no activities or plans in Iran. 

Firm/country[A]: Petrofield[C]/Malaysia; 
Firm activity: Developing an LNG plant on Iran's gulf coast to process 
natural gas from the Golshan and Ferdos fields in southern Iran; 
Status: Agreement made in 2008; 
Commercial activity: Will finance 100% of the LNG plant. Investment 
will be repaid in 7 years through the sale of gas and related products; 
Firm comment: Contacted on February 10, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Petroleos de Venezuela S.A. (PDVSA)/Venezuela; 
Firm activity: Development of natural gas field in South Pars phase 12; 
Status: Project initiated in 2009; 
Commercial activity: 10% stake in project, valued at $760 million; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Petronet LNG/India; 
Firm activity: Project to convert natural gas from South Pars into LNG 
for export; 
Status: Memorandum of Agreement signed December 2009; 
Commercial activity: Part of a consortium with India's ONGC and UK's 
Hinduja to take a 20% stake in the project; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm/country[A]: PGNiG/Poland; 
Firm activity: Development of natural gas fields; 
Status: Memorandum of Intent signed February 2008; 
Commercial activity: Not reported; 
Firm comment: Contacted on February 11, 2010; no response as of March 
22, 2010. 

Firm activity: Development of offshore natural gas field at Lavan; 
Status: Project under negotiation in 2008; 
Commercial activity: Buy-back agreement with Iranian Offshore Oil 
Company valued at $2 billion; 
Firm comment: Contacted on February 11, 2010; no response as of March 
22, 2010. 

Firm/country[A]: PTT Exploration and Production/Thailand; 
Firm activity: Exploration and development of the Saveh block natural 
gas field; 
Status: Signed a 25-year contract in 2005; 
Commercial activity: Has a 100% stake in the Saveh block; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Repsol/Spain; 
Firm activity: Development of South Pars natural gas fields (also 
known as Persian LNG); 
Status: Signed a framework agreement; 
Commercial activity: 25% stake in project, with an estimated total 
cost of $10 billion; 
Firm comment: Contacted on February 9, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Royal Dutch Shell/The Netherlands; 
Firm activity: Development of South Pars natural gas fields (also 
known as Persian LNG); 
Status: Signed a framework agreement; 
Commercial activity: 25% stake in project, with an estimated total 
cost of $10 billion; 
Firm comment: Confirmed signing a framework agreement. Stated that the 
agreement would give it a 50% share in development of South Pars 
phases and 25% share of liquefaction company. Stated that it has not 
yet decided whether to proceed. 

Firm/country[A]: Sinopec/China; 
Firm activity: Development of Yadavaran oil field; 
Status: Contract signed in 2007; 
Commercial activity: Contract valued at $2 billion;
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm activity: Expansion and upgrade of the Arak refinery; 
Status: As of 2008, estimated completion was 2011; 
Commercial activity: Contract valued at $2.8 billion; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm/country[A]: SKS Ventures/Malaysia; 
Firm activity: Development of two offshore natural gas fields Golshan 
and Ferdos in southern Iran; 
Status: Signed a contract in 2008; 
development expected to take over 5 years; 
Commercial activity: Buy-back contract is valued at $5 to $6 billion; 
Firm comment: Contacted on February 19, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Snamprogetti[D]/Italy; 
Firm activity: Feasibility study of underwater route for Iran-India 
pipeline from South Pars; 
Status: Study being conducted in 2005; 
Commercial activity: Not reported; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm/country[A]: StatoilHydro/Norway; 
Firm activity: Development of South Pars natural gas fields; 
Status: Froze new investments in Iran in 2008; 
Commercial activity: Acquired 37% share in 2002; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm activity: Oil exploration and development of the Anaran block in 
Zagros Mountains, including Azar, Changuleh West, Dehloran, and Musian; 
Status: Activities reported halted in 2007 due to threat U.S. 
sanctions; 
Commercial activity: StatoilHydro had 75% stake in the project; 
project cost is more than $1 billion; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Tecnimont/Italy; 
Firm activity: Engineering, procurement, and construction contractor 
for a LDPE plant in Sanandaj that will produce 300,000 metric tons per 
year; 
Status: Startup was scheduled for 2008; 
Commercial activity: Not reported; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Total/France; 
Firm activity: Development of South Pars natural gas fields; 
Status: No final agreement or investment as of December 31, 2009; 
Commercial activity: Possible 30% share of a $4 billion project; 
Firm comment: Confirmed that Total has been a significant investor in 
the Iranian energy sector for the past 20 years. Confirmed discussions 
with Iranian authorities regarding development of South Pars phase 11 
and the Pars LNG project. Does not anticipate new investments in the 
near future. 

Firm/country[A]: Turkish Petroleum Company (TPAO)/Turkey; 
Firm activity: Development of natural gas field in South Pars phases 
22-24. Total production is projected to be 35 billion cubic meters per 
year; 
Status: Preliminary agreement to be finalized by February 2010; 
Commercial activity: Memorandum of Understanding agreement signed in 
2007; 
Firm comment: Contacted on February 9, 2010; no response as of March 
22, 2010. 

Firm/country[A]: Uhde/Germany; 
Firm activity: Building new petrochemical plant in Kermanshah, 
increasing capacity by 300,000 metric tons per year; 
Status: Expected completion 2009 to 2010; 
Commercial activity: Not reported; 
Firm comment: Contacted on February 18, 2010; no response as of March 
22, 2010. 

Source: GAO analysis of open source information. 

[A] The country listed is the physical location of the firm as 
reported in open sources. 

[B] ABB Lummus no longer exists as a company. ABB of Switzerland sold 
the Lummus Group in 2007 to Chicago Bridge and Iron Company (CB&I) of 
the United States. Both ABB and CB&I commented that they no longer 
have any commercial activity in Iran. 

[C] Petrofield is a subsidiary of SKS Ventures. 

[D] Snamprogetti is a subsidiary of ENI. 

[End of table] 

End of Enclosure II] 

Enclosure III: Glossary of Terms and Abbreviations:[Footnote 15] 

Barrel: A unit of volume equal to 42 U.S. gallons. 

bbl: The abbreviation for barrel(s). 

bbl/d: The abbreviation for barrel(s) per day. 

Butane: A normally gaseous hydrocarbon extracted from natural gas or 
refinery gas streams. 

Butylene: A hydrocarbon recovered from refinery processes. 

Buy-back contract: Under "buy-back" arrangements, foreign firms may 
receive entitlements to oil or gas for a limited time in exchange for 
the funds they invest. 

Buy-back oil: Crude oil acquired from a host government whereby a 
portion of the government's ownership interest in the crude oil 
produced in that country may or should be purchased by the producing 
firm. 

Catalytic cracking: The refining process of breaking down the larger, 
heavier, and more complex hydrocarbon molecules into simpler and 
lighter molecules. Catalytic cracking is accomplished by the use of a 
catalytic agent and is an effective process for increasing the yield 
of gasoline from crude oil. 

Catalytic hydrocracking: A refining process that uses hydrogen and 
catalysts with relatively low temperatures and high pressures for 
converting middle boiling or residual material to high octane 
gasoline, reformer charge stock, jet fuel, or high-grade fuel oil. 

Catalytic hydrotreating: A refining process for treating petroleum 
fractions from atmospheric or vacuum distillation units (e.g., 
naphthas, middle distillates, reformer feeds, residual fuel oil, and 
heavy gas oil) and other petroleum (e.g., cat cracked naphtha, coker 
naphtha, gas oil, etc.) in the presence of catalysts and substantial 
quantities of hydrogen. 

Commercial activity: We define commercial activity as having signed an 
agreement to conduct business, invested capital, or received payment 
for the provision of goods or services in the Iranian oil, gas, or 
petrochemicals sectors. 

Consortium: Group of companies formed to promote a common objective or 
engagement in a project of benefit to all members. The relationship 
normally entails cooperation and a sharing of resources, sometimes 
even common ownership. 

Construction: An energy-consuming subsector of the industrial sector 
that consists of all facilities and equipment used to perform land 
preparation and construct, renovate, alter, install, maintain, or 
repair major infrastructure or individual systems therein. 
Infrastructure includes buildings; industrial plants; and other major 
structures, such as tanks, towers, monuments, roadways, tunnels, 
bridges, dams, pipelines, and transmission lines. 

Crude oil: A mixture of hydrocarbons that exists in liquid phase in 
natural underground reservoirs and remains liquid at atmospheric 
pressure after passing through surface separating facilities. Liquids 
produced at natural gas processing plants are excluded. Crude oil is 
refined to produce a wide array of petroleum products, including 
heating oils; gasoline, diesel, and jet fuels; lubricants; asphalt; 
ethane, propane, and butane; and many other products used for their 
energy or chemical content. 

Deadweight tons: The lifting capacity of a ship expressed in long tons 
(2,240 pounds), including cargo, commodities, and crew. 

Development: The preparation of a specific mineral deposit for 
commercial production; this preparation includes construction of 
access to the deposit and of facilities to extract the minerals. The 
development process is sometimes further distinguished between a 
preproduction stage and a current stage, with the distinction being 
made on the basis of whether the development work is performed before 
or after production from the mineral deposit has commenced on a 
commercial scale. 

Diesel fuel: A fuel composed of distillates obtained in a petroleum 
refining operation or blends of such distillates with residual oil 
used in motor vehicles. The boiling point and specific gravity are 
higher for diesel fuels than for gasoline. 

Downstream: When referring to the oil and gas industry, this term 
indicates the refining and marketing sectors of the industry. More 
generically, the term can be used to refer to any step further along 
in the process. 

Ethane: A normally gaseous hydrocarbon extracted from natural gas and 
refinery gas streams. 

Ethanol: A clear, colorless, flammable oxygenated hydrocarbon. Ethanol 
is typically produced chemically from ethylene, or produced 
biologically from fermentation of various sugars from carbohydrates 
found in agricultural crops and cellulosic residues from crops or wood. 

Ethylene: A hydrocarbon recovered from refinery processes or 
petrochemical processes. Ethylene is used as a petrochemical feedstock 
for numerous chemical applications and the production of consumer 
goods. 

Exploration, drilling: Drilling done in search of new mineral 
deposits, on extensions of known ore deposits, or at the location of a 
discovery up to the time when the company decides that sufficient ore 
reserves are present to justify commercial exploration. Assessment 
drilling is reported as exploration drilling. 

Exploratory well: A hole drilled: (a) to find and produce oil or gas 
in an area previously considered to be an unproductive area; (b) to 
find a new reservoir in a known field (i.e. one previously producing 
oil and gas from another reservoir); or (c) to extend the limit of a 
known oil or gas reservoir. 

Field: An area consisting of a single reservoir or multiple reservoirs 
all grouped on, or related to, the same individual geological 
structural feature or stratigraphic condition. There may be two or 
more reservoirs in a field that are separated vertically by 
intervening impervious strata or laterally by local geologic barriers, 
or by both. 

Firm: An association, company, corporation, estate, individual, joint 
venture, partnership, or sole proprietorship, or any other entity, 
however organized, including (a) charitable or educational 
institutions; (b) the federal government, including corporations, 
departments, federal agencies, and other instrumentalities, and state 
and local governments. A firm may consist of (1) a parent entity, 
including the consolidated and unconsolidated entities (if any) that 
it directly or indirectly controls; (2) a parent and its consolidated 
entities only; (3) an unconsolidated entity; or (4) any part or 
combination of the above. 

Gas: A nonsolid, nonliquid combustible energy source that includes 
natural gas, coke-oven gas, blast-furnace gas, and refinery gas. 

Gas plant operator: Any firm, including a gas plant owner, which 
operates a gas plant and keeps the gas plant records. A gas plant is a 
facility in which natural gas liquids are separated from natural gas 
or in which natural gas liquids are fractionated or otherwise 
separated into natural gas liquid products or both. 

Gas processing unit: A facility designed to recover natural gas 
liquids from a stream of natural gas that may or may not have passed 
through lease separators or field separation facilities. Another 
function of natural gas processing plants is to control the quality of 
the processed natural gas stream. Cycling plants are considered 
natural gas processing plants. 

Gas sweetening: conditioning for the removal of acid gases, which can 
cause corrosion to gas flowlines (pipelines) and can also be harmful 
to consumers. 

Gas to liquids (GTL): A process that combines the carbon and hydrogen 
elements in natural gas molecules to make synthetic liquid petroleum 
products, such as diesel fuel. 

HDPE: High-density polyethylene, a petrochemical derivative. 

Hydrocarbon: An organic chemical compound of hydrogen and carbon in 
the gaseous, liquid, or solid phase. The molecular structure of 
hydrocarbon compounds varies from the simplest (methane, a constituent 
of natural gas) to the very heavy and very complex. 

Hydrotreater: See catalytic hydrotreating. 

LDPE: Low-density polyethylene, a petrochemical derivative. 

LNG: Liquefied natural gas. 

Liquefied natural gas (LNG): Natural gas (primarily methane) that has 
been liquefied by reducing its temperature to -260 degrees Fahrenheit 
at atmospheric pressure. 

Mcf: One thousand cubic feet. 

Methane: A colorless, flammable, odorless hydrocarbon gas (CH4), which 
is the major component of natural gas. It is also an important source 
of hydrogen in various industrial processes. 

Metric ton: A unit of weight equal to 2,204.6 pounds, used to measure 
products such as LDPE and HDPE. 

MMbbl/d: One million barrels of oil per day. 

Natural gas: A gaseous mixture of hydrocarbon compounds, the primary 
one being methane. 

Natural gas liquids (NGL): Those hydrocarbons in natural gas that are 
separated from the gas as liquids through the process of absorption, 
condensation, adsorption, or other methods in gas processing or 
cycling plants. Generally, such liquids consist of propane and heavier 
hydrocarbons and are commonly referred to as lease condensate, natural 
gasoline, and liquefied petroleum gases. Natural gas liquids include 
natural gas plant liquids (primarily ethane, propane, butane, and 
isobutane) and lease condensate (primarily pentanes produced from 
natural gas at lease separators and field facilities). 

Natural gas liquids production: The volume of natural gas liquids 
removed from natural gas in lease separators, field facilities, gas 
processing plants, or cycling plants during the report year. 

Natural gas processing plant: Facilities designed to recover natural 
gas liquids from a stream of natural gas that may or may not have 
passed through lease separators or field separation facilities. These 
facilities control the quality of the natural gas to be marketed. 

Offshore: That geographic area that lies seaward of the coastline. In 
general, the coastline is the line of ordinary low water along with 
that portion of the coast that is in direct contact with the open sea 
or the line marking the seaward limit of inland water. 

Offshore reserves and production: Unless otherwise dedicated, reserves 
and production that are in either state or federal domains, located 
seaward of the coastline. 

Oil: A mixture of hydrocarbons usually existing in the liquid state in 
natural underground pools or reservoirs. Gas is often found in 
association with oil. Also see petroleum. 

OPEC (Organization of the Petroleum Exporting Countries): An 
intergovernmental organization created in 1960 whose stated objective 
is to "coordinate and unify the petroleum policies of member 
countries." Current members include Algeria, Angola, Ecuador, Iran, 
Iraq, Kuwait, Libya, Nigeria, Qatar, Saudi Arabia, United Arab 
Emirates, and Venezuela. 

Operated: Exercised management responsibility for the day-to-day 
operations of natural gas production, gathering, treating, processing, 
transportation, storage, or distribution facilities or a synthetic 
natural gas plant. 

Petrochemical feedstocks: Chemical feedstocks derived from petroleum 
principally for the manufacture of chemicals, synthetic rubber, and a 
variety of plastics. 

Petrochemicals: Organic and inorganic compounds and mixtures that 
include but are not limited to organic chemicals, cyclic 
intermediates, plastics and resins, synthetic fibers, elastomers, 
organic dyes, organic pigments, detergents, surface active agents, 
carbon black, and ammonia. 

Petroleum: A broadly defined class of liquid hydrocarbon mixtures. 
Included are crude oil, lease condensate, unfinished oils, refined 
products obtained from the processing of crude oil, and natural gas 
plant liquids. 

Petroleum products: Petroleum products are obtained from the 
processing of crude oil (including lease condensate), natural gas, and 
other hydrocarbon compounds. Petroleum products include unfinished 
oils, liquefied petroleum gases, pentanes plus, aviation gasoline, 
motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, 
kerosene, distillate fuel oil, residual fuel oil, petrochemical 
feedstocks, special naphthas, lubricants, waxes, petroleum coke, 
asphalt, road oil, still gas, and miscellaneous products. 

Petroleum refinery: An installation that manufactures finished 
petroleum products from crude oil, unfinished oils, natural gas 
liquids, other hydrocarbons, and alcohol. 

Processing plant: A surface installation designed to separate and 
recover natural gas liquids from a stream of produced natural gas 
through the processes of condensation, absorption, adsorption, 
refrigeration, or other methods and to control the quality of natural 
gas marketed or returned to oil or gas reservoirs for pressure 
maintenance, repressuring, or cycling. 

Production, crude oil: The volumes of crude oil that are extracted 
from oil reservoirs. These volumes are determined through measurement 
of the volumes delivered from lease storage tanks or at the point of 
custody transfer. 

Production, natural gas: The volume of natural gas withdrawn from 
reservoirs less (1) the volume returned to such reservoirs in cycling, 
repressuring of oil reservoirs, and conservation operations; less (2) 
shrinkage resulting from the removal of lease condensate; and less (3) 
nonhydrocarbon gases where they occur in sufficient quantity to render 
the gas unmarketable. Volumes of gas withdrawn from gas storage 
reservoirs and native gas, which has been transferred to the storage 
category, are not considered production. Flared and vented gas is also 
considered production. 

Production, oil and gas: The lifting of oil and gas to the surface and 
gathering, treating, field processing (as in the case of processing 
gas to extract liquid hydrocarbons), and field storage. The production 
function shall normally be regarded as terminating at the outlet valve 
on the lease or field production storage tank. If unusual physical or 
operational circumstances exist, it may be more appropriate to regard 
the production function as terminating at the first point at which 
oil, gas, or gas liquids are delivered to a main pipeline, a common 
carrier, a refinery, or a marine terminal. 

Propylene: Propylene is intended for use in nonfuel applications such 
as petrochemical manufacturing. Nonfuel propylene includes chemical- 
grade propylene, polymer-grade propylene, and trace amounts of 
propane. Nonfuel propylene also includes the propylene component of 
propane/propylene mixes where the propylene will be separated from the 
mix in a propane/propylene splitting process. Nonfuel propylene 
excludes the propylene component of propane/propylene mixes where the 
propylene component of the mix is intended for use as fuel. 

Refined petroleum products: Refined petroleum products include but are 
not limited to gasolines, kerosene, distillates, liquefied petroleum 
gas, asphalt, lubricating oils, diesel fuels, and residual fuels. 

Refiner: A firm or the part of a firm that refines products or blends 
and substantially changes products, refines liquid hydrocarbons from 
oil and gas field gases, or recovers liquefied petroleum gases 
incident to petroleum refining and sells those products to resellers, 
retailers, reseller/retailers, or ultimate consumers. "Refiner" 
includes any owner of products that contracts to have those products 
refined and then sells the refined products to resellers, retailers, 
or ultimate consumers. 

Refinery: An installation that manufactures finished petroleum 
products from crude oil, unfinished oils, natural gas liquids, other 
hydrocarbons, and oxygenates. 

Reinjected: The forcing of gas under pressure into an oil reservoir in 
an attempt to increase recovery. 

Reserve: That portion of the demonstrated reserve base that is 
estimated to be recoverable at the time of determination. The reserve 
is derived by applying a recovery factor to that component of the 
identified coal resource designated as the demonstrated reserve base. 

Upstream: The exploration and production portions of the oil and gas 
industry. 

[End of Enclosure III] 

Enclosure IV: Iran Sanctions Act: 

Under the Iran Sanctions Act, a person can be sanctioned for an 
investment, made on or after August 5, 1996, of $20 million or more 
(or any combination of investments of at least $5 million each, which 
in the aggregate equals or exceeds $20 million in any 12 month 
period).[Footnote 16] However, this investment must be made with 
actual knowledge and it must be an investment that directly and 
significantly contributed to the enhancement of Iran's ability to 
develop the petroleum resources of Iran.[Footnote 17] 

The act requires the President, delegated to the Secretary of State, 
to impose at least two of the following sanctions: 

* denying Export-Import Bank assistance for exporting to the foreign 
person; 

* banning licenses to export controlled technologies to the sanctioned 
person; 

* banning U.S. financial institutions from loaning the sanctioned 
person more than $10 million in a 1-year period unless such person is 
engaged in activities to relieve human suffering and the loans or 
credits are provided for such activities; 

* if the sanctioned person is a financial institution, prohibiting the 
designation of that institution as a primary dealer in U.S. government 
debt instruments or serving as an agent for the U.S. government or as 
repository for U.S. government funds; and: 

* banning U.S. government procurement from the sanctioned person, and: 

* as well as other sanctions that fall under the powers of the 
International Emergency Economic Powers Act (IEEPA), including IEEPA- 
derived executive orders, to restrict imports with respect to the 
sanctioned person.[Footnote 18] 

The President may waive these sanctions if the President determines 
that doing so is important to the national interest of the United 
States.[Footnote 19] 

[End of Enclosure IV] 

Footnotes: 

[1] Based on International Monetary Fund (IMF) data from 2005 to 2008, 
and data from the Economist Intelligence Unit (The Economist), Iran 
Country Report (Dec. 8, 2009). 

[2] Central Intelligence Agency, World Factbook, [hyperlink, 
https://www.cia.gov/library/publications/the-world-
factbook/rankorder/2173rank.html?cou], accessed on February 18, 2010. 

[3] IHS Global Insight provides economic and financial information for 
the energy industry on a contract basis, including analysis and 
forecasting for the Iranian oil, gas, and petrochemical sectors 
discussed in this report. 

[4] Foreign firms typically hand over operations to the National 
Iranian Oil Company after the development phase, according to DOE. 

[5] See e.g. Exec. Order 13,059, 62 Fed. Reg. 44,531 (Aug. 19, 1997). 

[6] Iran-Libya Sanctions Act of 1996, Pub. L. No. 104-172, § 5, 110 
Stat. 1541, 1543 as amended. The act also allows for sanctions against 
persons providing goods, technology, or services to Iran knowing that 
such provision would contribute materially to Iran's ability to 
acquire or develop chemical, biological, or nuclear weapons or related 
technologies; or acquire or develop destabilizing numbers and types of 
advanced conventional weapons. 

[7] Pub. L. No. 104-172, § 6; Memorandum: Delegation of 
Responsibilities Under the Iran and Libya Sanctions Act of 1996, 61 
Fed. Reg. 64,249 (Nov. 21, 1996). Other sanctions include a denial of 
Export-Import Bank assistance, a ban on issuing licenses to export 
controlled technologies to the sanctioned firm, and other sanctions 
that fall under the powers of the International Emergency Economic 
Powers Act (IEEPA). 

[8] Pub. L. No. 104-172, § 9; 61 Fed. Reg. 64,249. 

[9] This instance was the first and only time that the United States 
has publicly made a determination that a firm's investment violated 
the Iran Sanctions Act. 

[10] GAO, Iran Sanctions: Impact in Furthering U.S. Objectives Is 
Unclear and Should Be Reviewed, [hyperlink, 
http://www.gao.gov/products/GAO-08-58] (Washington, D.C.: Dec. 18, 
2007). 

[11] Iran Refined Petroleum Sanctions Act of 2009, H.R. 2194, 111th 
Cong. (2009). We will issue an additional report on firms that export 
refined petroleum products to Iran. 

[12] We present the activities from what are considered "upstream" 
sectors, such as drilling for oil, to "downstream" sectors, such as 
exporting refined products in tankers. 

[13] According to the 2009 Economist Intelligence Unit (The Economist) 
Iran Country Report, oil production was at 3.8 million barrels per day 
in 2008. 

[14] According to DOE, South Pars natural gas field has a 25 phase 
development scheme spanning 20 years. 

[15] The U.S. Energy Information Administration, an independent agency 
within the U.S. Department of Energy, was the primary source for 
definitions contained in this glossary. 

[16] Pub. L. No. 104-172, § 5, as amended. 

[17] Id. 

[18] Pub. L. No. 104-172, § 6, as amended. 

[19] Pub. L. No. 104-172, § 9, as amended. 

[End of section] 

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