Claims vs Record disc-005
unresolvedsafety Worst-case dose built on 30 full-power days (3 megawatt-days); the same paper's burnup limit reads 30 megawatt-days
What was said
- Valar Atomics (safety agreement, accident analysis, page 34) (2025-10): Builds the worst-case radioactive inventory "Based on OpenMC neutronic analysis with 3 MWd total burnup", with "Conservative 30 EFPD operation assumed for inventory buildup".Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), pages 34-37 (Valar Atomics, 2025-10)
- Valar Atomics (safety agreement, page 10) (2025-10): Says the accident source term assumes "continuous operation at maximum licensed power" long enough to reach equilibrium fission product inventories.Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), page 10 (Valar Atomics, 2025-10)
- Valar Atomics (July 2025 slides to Emery County) (2025-07-08): Ward 250 "operates for 30EFPD, in 12 months".Valar Atomics + SRERC in Emery County (slide deck marked confidential, posted on the Utah Public Notice Website) (Valar Atomics, 2025-07-08)
- Isaiah Taylor (June 2026 page) (2026-06-28): The reactor is "licensed for 30 Effective Full Power Days at 100kWt".Ward 250 By the Numbers (Isaiah Taylor; unlisted page that still carries placeholders) (Valar Atomics, 2026-06-28)
What the record shows
- The same safety agreement's operating limit (page 25) is 'Fuel burnup limit: 30 megawatt-days'. At the 100 kW continuous limit, 30 MWd is 300 full-power days: ten times the 30 days (3 MWd) the accident inventory was built on.Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), page 25 (Valar Atomics, 2025-10)
- Its objectives (page 8) call for completing tests 'within the 12-month operational period' with 'availability factors exceeding 80%': 12 months at 80% is about 292 days, which at 100 kW is about 29 MWd, matching the 30 MWd limit rather than the 3 MWd analysis.Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), page 8 (Valar Atomics, 2025-10)
- The paper names iodine-131 and noble gases as the main contributors to the worst-case dose and does not show how the dose would change with ten times the fuel use, so the size of the effect cannot be read from it.Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), pages 34-37 (Valar Atomics, 2025-10)
- DOE's environmental review describes about 12 months of operation and says less than 1% of the initial fissile material is consumed; it gives no burnup figure.NEPA Determination DOE-ID-26-005: Valar Ward250 Research Reactor (categorical exclusion B5.26) (U.S. Department of Energy, Office of Nuclear Energy, 2026-04-22)
- The EPA gives iodine-131, which the safety paper names its 'primary dose contributor', a half-life of 8 days ('Iodine-131’s short half-life of 8 days'). By that half-life, 30 days of steady running builds iodine-131 to about 93% of the most it can reach at that power (1 minus 0.5 to the power 30/8); running ten times longer at the same power adds at most about 8% more. Slower-decaying materials the paper lists (such as cesium-137) keep accumulating with use, on the paper's own 'inventory buildup' premise, so they are not bounded the same way.Radionuclide Basics: Iodine (U.S. Environmental Protection Agency, 2026-01-22)
- Every other Valar statement of the operating plan gives 30 full-power days: the accident inventory itself ('Conservative 30 EFPD operation', p. 34), the July 2025 slides ('30EFPD, in 12 months') and the June 2026 draft page ('30 Effective Full Power Days at 100kWt'). Only the page-25 limit reads '30 megawatt-days'. A 30-day figure written in the wrong unit would produce exactly this tenfold gap: a plausible reading, not a confirmed one.Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), pages 25 and 34 (Valar Atomics, 2025-10)
- The page-8 goal is 'availability factors exceeding 80% during test campaigns'. Availability describes readiness during campaigns; it does not say the reactor runs at full power that long, so by itself it does not imply about 29 megawatt-days.Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), page 8 (Valar Atomics, 2025-10)
The gap: The accident inventory assumes 30 full-power days at 100 kW (3 MWd), matching every other Valar statement of the plan. One line of the same draft sets the burnup limit at 30 megawatt-days, ten times that, and its method statement calls for inventory at maximum licensed power to equilibrium. The likeliest innocent reading is a unit slip (30 days written as 30 megawatt-days); only the approved Technical Safety Requirements, which are not public, can confirm it. Even if the reactor ran ten times longer at the same power, iodine-131, which the paper names as the main contributor to dose, would rise by less than a tenth because it nears its maximum within weeks; slower-decaying materials would grow. Our check: the iodine and noble-gas dose would rise about 4%; cesium-137 and strontium-90 about tenfold, but still about 4% of the iodine-131 activity. Even scaling the whole 100 millirem bound up tenfold gives 1 rem, far below the paper's 25 rem guideline.
In plain termsIn a nuclear accident, what can escape depends partly on how much radioactive material has built up in the fuel. Valar's worst-case calculation assumed the reactor had run the equivalent of 30 days at full power, and Valar has said '30 days' everywhere else too. But one line of the same paper sets the fuel-use limit at '30 megawatt-days', which is ten times more. That line may simply use the wrong unit; the rest of the paper points that way. It also matters less than it sounds: the main contributor to the worst-case dose, iodine-131, loses half its strength every 8 days, so after a month of running it is already near its peak and running longer adds little. Slower-fading materials would keep growing. The approved limits that would settle it are not public.
Why it matters: The accident inventory underlies the dose at the fence, the request for on-site-only emergency planning and the absence of 'Safety Class' equipment; which limit governs decides whether that inventory is the right one.
What would settle it: FOIA to DOE Idaho Operations Office for the source term and burnup assumptions in the approved DSA accident analysis (Chapter 13), the TSR burnup limit, and DOE's Safety Evaluation Report on the DSA.