Fact safe-005
The NSDA PDF Valar posts (rev 02, October 2025, created 13 October 2025 per its file metadata) is marked 'Status: Draft' and 'issued for Public Release'. Valar's library page of the same date says DOE 'has approved' the NSDA under 10 CFR 830 and the DOE-Valar Other Transaction Agreement. The web summary describes a PDSA 'at 50% design completion' and a final DSA 'for the as-built facility', while the PDF proposes, as an alternative requirement, submitting the final DSA 'at 90% design completion' and verifying the as-built plant afterwards (Appendix C.5). The PDF asks DOE to accept six alternatives to standard requirements: ANS-15.8 instead of NQA-1 for quality assurance; ANS-15.4 operator qualification; on-site-only emergency response; OSHA rules instead of DOE's worker safety rule 10 CFR 851; early DSA submittal; and tailored DOE O 420.1C facility safety. The web summary lists three alternatives as approved (ANS-15.8 QA, ANS-15.4 conduct of operations, reduced surveillance). The PDF itself says the OSHA substitution for the construction phase was 'approved through the OTA' (Appendix C.4); that is Valar's statement, and no DOE record of it was read. Apart from it, no record read says whether DOE approved the emergency-planning, worker-safety and DSA-timing alternatives, and no DOE approval letter for the NSDA was found.
- Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Ward250 Alternative: Submit final DSA at 90% design completion”
- Ward250 Nuclear Safety Design Agreement (web summary, Valar library) (Valar Atomics, 2025-10-13) primary company “The Department of Energy has approved the Nuclear Safety Design Agreement (NSDA)”
- Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “This approach, approved through the OTA, provides appropriate worker protection”
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