The NSDA's code of record lists DOE's worker safety and health rule, 10 CFR 851, as 'N/A', replaced by OSHA standards (29 CFR 1910/1926) under the contractor-owned model; a second table gives its applicability as 'Phased' and notes a 'DOE Idaho Operations Office exemption request in process for construction activities' pending a revision of 10 CFR 851, and Appendix C.4 says the OSHA approach for the construction phase was 'approved through the OTA' (Valar's statement; no DOE record of it was read). DOE-STD-1271, for its part, says that in some instances, such as worker industrial safety, DOE authorization is exempted from OSHA requirements. Neither document says which agency inspects or enforces worker safety at Ward 250 if DOE's rule is set aside and OSHA's own requirements do not reach a DOE-authorized facility. Radiation protection stays under DOE's rule 10 CFR 835 (occupational limit 5 rem a year), per the NSDA and the categorical exclusion. Minimum staffing in the NSDA: one Senior Reactor Operator and one Reactor Operator per shift, a 'Radiation Protection Technician: On-call', plus a facility director, a technical support engineer and a maintenance technician. Operators are qualified under the ANS-15.4 research-reactor standard instead of DOE's review (Appendix C.2); no NRC operator licences are involved, though Valar's documents call them 'licensed operators'. Valar's QA program says its Radiation Safety Lead function 'may be fulfilled by qualified USREL personnel under appropriate agreements'; the state lab advertised for its own Safety Manager in September 2026 (dir-006). Whether DOE granted the 10 CFR 851 exemption, and what applies to workers after construction, is not in any DOE record read.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “DOE Idaho Operations Office exemption request in process for construction activities”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Radiation Protection Technician: On-call”
• Ward250 San Rafael Facility Quality Assurance Program Description, No. 100474, Rev 02 (status: Approved) (Valar Atomics, 2025-10) primary company “This function may be fulfilled by qualified USREL personnel under appropriate agreements.”
• DOE-STD-1271-2025, Authorization Pathway for Nuclear Facilities (August 2025; DOE standard, copy posted by the Nuclear Innovation Alliance) (U.S. Department of Energy, Office of Nuclear Energy, 2025-08) primary government
• NEPA Determination DOE-ID-26-005: Valar Ward250 Research Reactor (categorical exclusion B5.26) (U.S. Department of Energy, Office of Nuclear Energy (Idaho), 2026-04-22) primary government