ETV News (10 Oct 2025) quoted Jaron Wallace, director of the state-run Utah San Rafael Energy Lab that hosts Ward 250: 'Any nuclear company is required to show no dose at the site boundary during an accident event', adding that in the worst case 'the site boundary and thus the public will never see a dose of radiation above background'; the article also paraphrased him that Valar must prove no damage or radiation can pass the fence line of its 11 acres. Set beside the record: Valar's own Ward250 Nuclear Safety Design Agreement (revision 02, October 2025, marked draft) models a bounding 'maximum hypothetical accident' that assumes fuel-particle failures beyond demonstrated limits, a breach of the pressure boundary and stable, light-wind weather (Class F, 1 m/s) that the paper calls the most conservative. It puts the dose at the 400-metre site boundary below 0.5 rem (500 millirem) in one section and below 100 millirem in another, and below 0.1 rem at the nearest home about 800 metres away (safe-013). It measures these against a 25 rem evaluation guideline, not against zero. DOE's categorical exclusion gives natural background radiation in central Utah as about 100-120 millirem a year, and the routine public dose limit as 100 millirem a year. So the company's own analysis does not show 'no dose' at the boundary: it shows a small calculated dose in an accident it treats as a worst case, far below the guidelines it uses. Whether the lab director meant routine operation or a different standard is not in the record; this rests on one news report of his words.

• What’s actually happening at the Utah San Rafael Energy Lab? (Susanna Watts) (ETV News, 2025-10-10) news “Any nuclear company is required to show no dose at the site boundary”
• Ward250 Nuclear Safety Design Agreement (Document 100403, Revision 02, marked draft, October 2025) (Valar Atomics, 2025-10) primary company “Preliminary results indicate site boundary doses below 0.5 rem Total Effective Dose Equivalent”
• 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) primary government “Natural background radiation in central Utah is approximately 100-120 mrem/year.”