Valar's April 7, 2025 post 'Valar Atomics is Suing the NRC' contains the claim that holding Ward One's spent fuel for five minutes gives the same exposure as a CAT scan (orig-017). Read 2026-09-29, the page carries a robots meta tag, 'noindex, nofollow', which asks search engines not to list it, and the site's page data marks it 'disableIndex: true'; no other Valar library post carries the tag. Internet Archive copies of the page from April 8, 2025 through March 23, 2026 have no such tag; copies from July 22 and August 25, 2026 have it. In every copy the claim's text is unchanged, and no correction or note has been added. The post is still listed in Valar's own library, so visitors to the site can still find it. The tag appeared some time after March 23, 2026. The record does not show who added it or why.

• Valar Atomics is Suing the NRC (Isaiah Taylor), live page read 2026-09-29 (Valar Atomics, 2025-04-07) primary company “holding the spent fuel from this system for five minutes”
• Same page as archived by the Internet Archive, 23 March 2026 (no robots tag) (Valar Atomics (archived copy, Internet Archive), 2026-03-23) primary company
• Same page as archived by the Internet Archive, 22 July 2026 (robots tag present) (Valar Atomics (archived copy, Internet Archive), 2026-07-22) primary company “noindex, nofollow”

No public record read shows a settlement of Texas et al. v. NRC. (1) The NRC General Counsel listed the case as active and in abeyance as of 27 January 2026 (dir-018). (2) Utah's Attorney General described it in January 2026 as stayed while the NRC considers rule revisions and exemptions (dir-019). (3) The NRC's May 2026 proposed Part 57 rule keeps the 'utilization facility' definition the suit attacks (dir-020). No final rule and no Federal Register notice about a settlement were found, and none of the NRC's 2026 Commission orders (CLI-26-1 to CLI-26-12) concerns the case. (4) The latest docket entry seen, in a commercial copy of the docket, is a joint status report of 2 September 2026, with no dismissal, stipulation or consent decree shown (dir-022). (5) Press in May 2026 reported only that the NRC had been willing to settle (dir-021). A settlement agreed but not yet filed cannot be ruled out from public records, and its terms, if any, are unknown. Ward 250 runs under DOE authorization either way (safe-028). (Updates safe-028.)

• Litigation Status Report (As of January 27, 2026), enclosure to SECY-26-0013 (U.S. Nuclear Regulatory Commission, Office of the General Counsel, 2026-01-27) primary government “The court has not yet acted on the request”
• Office of the Utah Attorney General 2025 Annual Report (Office of the Utah Attorney General, 2026-01-22) primary government “The case is currently stayed”
• Licensing Requirements for Microreactors and Other Reactors With Comparable Risk Profiles (proposed rule) (Federal Register (Nuclear Regulatory Commission), 2026-05-01) primary government “any nuclear reactor would meet both prongs and constitute a utilization facility”
• State of Texas et al v. U.S. Nuclear Regulatory Commission (6:24-cv-00507) (PacerMonitor (copy of PACER docket)) court docket aggregator “JOINT STATUS REPORT by U.S. Nuclear Regulatory Commission”
• Commission Orders for 2026 (U.S. Nuclear Regulatory Commission) primary government

Valar publishes one version of the Ward 250 Nuclear Safety Design Agreement (No. 100403, Revision 02, dated October 2025). The Internet Archive holds seven captures of that PDF (7 November 2025; 1 January, 3 March, 5 July, 6 July, 6 August and 18 September 2026); with the live file Valar Watch fetched on 29 September 2026, all eight are byte-identical (the same SHA-256), and each carries the fuel line 'Fuel Enrichment 4.95% U-235 LEU limits'. So the public copy was not revised after DOE's packaging review approved shipping HALEU fuel to Ward 250 (20 May 2026, safe-010) or after the reactor's first criticality (18 June 2026, orig-010). The agreement itself says that if the fuel differs from its specification, the safety assumptions will be updated in the later Preliminary Documented Safety Analysis, of which no public copy was found (safe-007); an updated analysis may exist. The companion Quality Assurance Program Description (No. 100474, Revision 02) is likewise unchanged across its six copies.

• Ward250 Nuclear Safety Design Agreement, No. 100403 Rev 02: Internet Archive copy of 7 Nov 2025 (Valar Atomics (via Internet Archive), 2025-10) primary company “Fuel Enrichment 4.95% U-235 LEU limits”
• Ward250 Nuclear Safety Design Agreement, No. 100403 Rev 02: Internet Archive copy of 18 Sept 2026 (Valar Atomics (via Internet Archive), 2025-10) primary company “Fuel Enrichment 4.95% U-235 LEU limits”
• Ward250 Nuclear Safety Design Agreement, No. 100403 Rev 02 (live file, fetched 29 Sept 2026) (Valar Atomics, 2025-10) primary company

Valar posted its Ward 250 safety agreement (NSDA) and Quality Assurance Program Description on its website on 13 October 2025, each on its own page linking the PDF (orig-071). Valar Watch compared every saved copy of Valar's library page (valaratomics.com/docs): Internet Archive captures of 16 October and 7 and 19 November 2025, and 5 July, 6 August and 25 August 2026, and the live page on 29 September 2026. In none is either safety-paper page among the library's listed posts; the library lists the NRC-lawsuit post, the Project NOVA release and Valar's other announcements. So since they went up, the only safety papers Valar publishes have been reachable only by a direct link (for example from the Ward 250 page's data or from outside reporting), not by browsing Valar's library. The record does not show why they were left unlisted.

• valaratomics.com/docs, Internet Archive captures Oct 2025 to Aug 2026 (Internet Archive (Wayback Machine)) primary company
• Docs (Valar Atomics library), live page read 29 Sept 2026 (Valar Atomics) primary company
• Ward250 Nuclear Safety Design Agreement (Valar library page, unlisted) (Valar Atomics, 2025-10-13) primary company

Read 2026-09-29, the page data behind Valar's library lists nine posts. Five are listed: 'Valar Atomics is Suing the NRC' (April 7, 2025), 'Roadmap to the American Nuclear Golden Age' (May 23, 2025), the DOE selection post (August 12, 2025), the Project NOVA release (November 18, 2025) and the Series B post (August 4, 2026). Four are not listed but load at their addresses: the Ward250 NSDA post and the QA Program Description post (both dated October 13, 2025), the 'Ward 250 By the Numbers' draft (June 28, 2026, with placeholders; orig-035) and the 'Ward Zero Whitepaper' (orig-058). The only technical documents published are two PDFs in the site's 'Public Documents' asset folder, the NSDA (document 100403, rev 02, marked Draft) and the QA Program Description (document 100474, rev 02), both linked only from the unlisted posts. Three placeholder posts seen in April 2025, with 'Lorem ipsum' bodies, are gone. Nothing on the site publishes the PDSA, the final DSA, the Technical Safety Requirements, DOE's safety evaluation, the readiness review, the startup approval, the OTA or any Ward Zero test data (safe-007, orig-055, orig-059). The press list has not been updated since February 28, 2026 (orig-048), and the Ward 250 page's progress list still stops at the September 2025 groundbreaking.

• Library | Valar Atomics (page and its embedded data) (Valar Atomics) primary company “The Valar Atomics knowledge base.”
• Ward 250 | Valar Atomics (page data lists all nine posts with their listing flags) (Valar Atomics) primary company
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft) (Valar Atomics, 2025-10) primary filing “issued for Public Release”
• Valar Atomics library page as archived by the Internet Archive, 8 April 2025 (Valar Atomics (archived copy, Internet Archive), 2025-04-08) primary company “Lorem ipsum”

Public DOE records found for Ward 250 as of 29 September 2026: the categorical exclusion DOE-ID-26-005 (signed 22 April 2026, posted with a June 2026 web path; csite-020); DOE's 18 June 2026 criticality release; and two DOE Packaging Certification Program documents on rampac.energy.gov (the Model 9979 fuel-shipment Safety Evaluation Report of 20 May 2026 and Valar's transport QA approval of 18 May 2026; safe-010, safe-012). Found on 30 September: the Office of Environmental Management's article of 14 July 2026, which says EM staff took part in DOE's readiness review for the four pilot reactors, naming Ward 250, and in reviewing contractor submittals for advanced microreactor designs, a sentence that does not name Ward 250 (dir-031). Not found on DOE's public sites: the NSDA approval letter, the PDSA and final DSA, the Technical Safety Requirements, DOE's Safety Evaluation Report on the DSA (which DOE-STD-1271 says the approval authority approves), the readiness-review report, the startup approval (signed by the Secretary of Energy or a delegate under the standard), any approval to exceed 100 kWth, and the DOE-Valar Other Transaction Agreement. The NSDA also refers to a Code of Record (document 100437, which it says was provided to DOE with the NSDA) and to a Physical Security Plan and a Material Control and Accountability Plan, which it calls separate controlled documents. The Idaho Operations Office's document server (id.energy.gov) refused our reader (HTTP 403), so its contents could not be checked. An absent posting is not proof a document is being withheld; it is what a FOIA request to the Idaho Operations Office would settle.

• 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
• Department of Energy Celebrates Second Advanced Reactor Achieving Criticality (U.S. Department of Energy, 2026-06-18) primary government
• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 for the Model 9979 Package, Docket 26-35-9979 (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-20) primary government
• 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 “A Safety Evaluation Report will be prepared using the guidance of DOE-STD-1104”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company

The NSDA's natural-hazard values are 'preliminary', based on 'regional seismicity and generic site conditions', with final values to follow site-specific studies: peak ground acceleration 0.2 g for its most important equipment, 130 mph design wind, 200 mph tornado wind, -20 to 115 F. DOE's categorical exclusion says no active faults, landslides or geologic hazards exist at or next to the site per Utah Geological Survey mapping, calls the region moderate seismic hazard, and names only the Wasatch Fault Zone, about 150 km (95 miles) northwest. A query of the Utah Geological Survey's Quaternary fault layer on 29 September 2026, from a point on Coal Haul Road beside the lab (39.244 N, 111.094 W; accurate to about 2 km), found no mapped fault closer than about 14.8 km (9 miles); six strands of the Joes Valley fault zone lie within 20 km: the nearest (last movement mapped as less than 2.6 million years ago) at about 14.8 km, and strands mapped as having moved within the last 15,000 years at about 15 to 19 km, all with slip rates under 0.2 mm a year. Allowing for the reference point's uncertainty, the nearest strand is roughly 13 to 17 km from the reactor. Flooding: the NSDA places the site on a mesa about 100 ft above the surrounding terrain, and the CX about 100 ft above Cottonwood Creek and outside FEMA-mapped flood areas; the CX notes the Adobe Wash Regulating Reservoir about 0.4 km southwest, which drains through a separate wash that does not cross the site's drainage. Fire and aircraft: the NSDA screens out wildland and industrial fire on a '10-mile separation distance' and aircraft on 'no nearby airports'; the CX describes the site as pinyon-juniper woodland and 'typical undisturbed rangeland', and the state's airport layer shows Huntington Municipal Airport about 20 km away. Water: the CX puts consumption under 1,000 gallons a day for domestic use, with no process-water discharge; the reactor is cooled by helium, not water. Whether the site-specific seismic study was done, and its result, is in the DSA, which was not found in public records. Our check of the earthquake value: the USGS design-maps service (ASCE 7-22, 29 September 2026) gives a maximum considered peak ground acceleration of about 0.21 g for the site on soft rock (site class BC), 0.23 g for class C and 0.26 g for class D; the paper's 0.2 g is close to the rock value, and the paper gives no soil class.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Preliminary seismic parameters based on regional seismicity and generic site conditions”
• 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 “The Wasatch Fault Zone is located approximately 150 km (95 miles) northwest of the site.”
• Utah Quaternary Faults (Utah Geological Survey, Hazards/quaternary_faults MapServer, distance queries) (Utah Geological Survey) primary government
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “screened based on 10-mile separation distance and natural barriers”
• AirportLocations (Utah Geospatial Resource Center, FAA airport points, distance query) (Utah Geospatial Resource Center) 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 “Elevated position approximately 100 feet above Cottonwood Creek eliminates flood risk.”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “approximately 100 feet above the surrounding terrain”
• U.S. Seismic Design Maps web service, ASCE 7-22, Risk Category IV, site class BC, at the USREL site (39.2395 N, 111.0866 W) (U.S. Geological Survey) primary government “"pgam": 0.21”

Valar's home page (read 29 September 2026) says its HTGR architecture has 'an unmatched safety profile and proliferation resistance when paired with TRISO fuel'; the joint NOVA release calls Valar's reactors 'inherently safe'; the state lab's Valar page says the design is engineered to 'remain impossible to melt under extreme conditions' (orig-012). Valar's own NSDA is more measured: TRISO retains more than 99.99% of fission products in normal operation and keeps its integrity 'up to 1600°C during postulated accidents', with a failure fraction under 1 in 10,000 at 1600°C, a peak fuel limit of 1,250°C, and an accident analysis that assumes some particles fail. DOE's Office of Nuclear Energy also describes TRISO as exceptionally robust (exp-001). The Union of Concerned Scientists' 2021 assessment of reactor types in general (it does not mention Valar) finds HTGRs have attractive safety features but that TRISO is 'far from meltdown-proof', releases fission products faster above about 1,600°C, depends on consistently manufacturing fuel to exacting specifications (not yet demonstrated, in its view), that HTGRs are vulnerable to air or water getting into the reactor, and that designs without leak-tight containment may cancel out the benefits; it also says using HALEU instead of lower-enriched uranium increases proliferation and terrorism risks, though far less than plutonium, and that TRISO fuel fabrication is harder to monitor than ordinary fuel fabrication. Ward 250 has no conventional containment by design (NSDA 'functional containment'), and its fuel shipped from Nevada is HALEU (safe-010).

• The New Atomic Age | Valar Atomics (home page) (Valar Atomics) primary company “This architecture has an unmatched safety profile and proliferation resistance when paired with TRISO fuel.”
• Valar Atomics | Utah San Rafael Energy Lab (Utah Office of Energy Development (Utah San Rafael Energy Lab)) primary government “remain impossible to melt under extreme conditions”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “maintain integrity up to 1600°C during postulated accidents”
• "Advanced" Isn't Always Better: Assessing the Safety, Security, and Environmental Impacts of Non-Light-Water Nuclear Reactors (executive summary) (Union of Concerned Scientists, 2021-03) analysis “the fuel is far from meltdown-proof, as some claim”
• Los Alamos National Laboratory and Valar Atomics Announce Project NOVA Criticality Milestone in Nevada (joint release on Valar's site) (Valar Atomics / Los Alamos National Laboratory, 2025-11-18) primary company

DOE named Valar on 30 September 2025 in 'the second round of conditional selections' for its Fuel Line Pilot Program, 'to support TRISO fuel fabrication for the Ward250 reactor deployment'; the program uses DOE authorization for fuel lines. Valar's QA program covers a 'Valarin Fuel Fabrication Facility' at the lab, based on German HOBEG methods and designed to stay below DOE Hazard Category 3 ('<HC3'; orig-038); DOE-STD-1271 bars adding nuclear material above Hazard Category 3 levels to a facility until the readiness review and startup approval are complete; a fuel line kept below that level would not reach that gate, and no record read says what review applies instead. DOE's categorical exclusion says the Ward 250 facility 'comprises the Reactor Complex and Fuel Laboratory', and Valar's QA program calls the Ward250 Fuel Laboratory a TRISO fuel manufacturing facility, but the CX's analysis does not mention fuel fabrication. Valar job postings open on 29 September 2026 seek engineers in Orangeville to 'install, troubleshoot, and optimize pilot scale uranium processing equipment' on a TRISO line (a fluidized-bed chemical vapor deposition coater; one posting asks for experience with wet chemistry or high-temperature processing), building on 'completed HAZOPs and existing safety analyses', a Nuclear Operations Manager to oversee 'both the reactor plant and the pilot TRISO fuel fabrication facility', and a material control and accounting specialist for special nuclear material 'at Valar Atomics TRISO manufacturing facilities'. DOE's selection release says each company bears all costs of building, operating and decommissioning its fuel facility. By comparison, Oklo announced in November 2025 that DOE's Idaho office had approved an NSDA for its fuel fabrication facility, the first under the fuel-line program. No NSDA, safety analysis, DOE authorization or state license for Valar's fuel line was found as of 29 September 2026. The Carbon County plan also includes fuel manufacturing (csite-007). The quality program gives no uranium inventory, enrichment or threshold for its <HC3 claim, and the safety agreement never mentions the fuel facility (it categorizes only the reactor, as Hazard Category 2), so the claim cannot be checked from Valar's public papers.

• Energy Department Selects Four Companies for Advanced Nuclear Fuel Line Pilot Projects (U.S. Department of Energy, 2025-09-30) primary government “To support TRISO fuel fabrication for the Ward250 reactor deployment”
• Ward250 San Rafael Facility Quality Assurance Program Description, No. 100474, Rev 02 (status: Approved) (Valar Atomics, 2025-10) primary company “ensures <HC3 categorization through multiple layers of inherent safety”
• 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 “The Ward250 facility comprises the Reactor Complex and Fuel Laboratory”
• Valar Atomics job board (92 open postings, public Greenhouse feed), read 2026-09-29 (Valar Atomics, 2026-09-29) primary company “install, troubleshoot, and optimize pilot scale uranium processing equipment”
• 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
• Ward250 San Rafael Facility Quality Assurance Program Description, No. 100474, Rev 02 (status: Approved) (Valar Atomics, 2025-10) primary company “The Ward250 Fuel Laboratory represents a state-of-the-art TRISO fuel manufacturing facility”
• Oklo Announces U.S. Department of Energy Approval for Nuclear Safety Design Agreement of Aurora Fuel Fabrication Facility (Oklo Inc. (Business Wire), 2025-11-11) primary company “has approved the Nuclear Safety Design Agreement (NSDA) for the Aurora Fuel Fabrication Facility”

In July 2025 E&E News reported that Valar had not contacted or met with the NRC and quoted CEO Isaiah Taylor asking why a company that believes the jurisdiction is wrong would engage (csite-022); the same month, Georgia Tech nuclear engineering professor Anna Erickson told the Utah Investigative Journalism Project that Valar had submitted nothing to the NRC, calling that secrecy a red flag, while other startups, including co-plaintiff Deep Fission, were in pre-application talks. Valar's job board on 29 September 2026 lists a Director of Licensing who 'serves as the senior company interface with regulators across DOE and NRC engagement pathways' and handles 'multiple concurrent licensing campaigns', plus licensing engineers and a licensing project manager, and a material control and accounting specialist working to DOE and NRC requirements. Whether Valar has opened NRC pre-application engagement could not be checked: nrc.gov refused our reader (HTTP 403).

• NRC lawsuit could hand states power over advanced reactors (E&E News by POLITICO, 2025-07-23) news “Valar Atomics has still not contacted or met with the commission.”
• Who is Valar Atomics? (Utah Investigative Journalism Project with Utah News Dispatch) (Utah Investigative Journalism Project / Utah News Dispatch, 2025-07-08) news “We can't take your word for it”
• Valar Atomics job board (92 open postings, public Greenhouse feed), read 2026-09-29 (Valar Atomics, 2026-09-29) primary company “serves as the senior company interface with regulators across DOE and NRC engagement pathways”

Valar's NSDA commits Ward 250 to DOE's occurrence reporting order (NE O 232.1), accident investigations (NE O 225.1), ES&H reporting, independent oversight, and DOE's employee concerns and differing professional opinion programs (which DOE-STD-1271 says allow no alternative). DOE's Occurrence Reporting and Processing System page says access to occurrence reports is restricted to approved DOE and DOE contractor personnel; that page describes the department-wide order (DOE O 232.2A), while the NSDA commits to the Office of Nuclear Energy's own order, and whether Ward 250's reports go into the same system is not stated in any record read. No public report of an incident, occurrence, violation, enforcement action or worker injury at Ward 250, NOVA or the fuel line was found in DOE, state or news sources read as of 29 September 2026. OSHA's site refused our reader (robots.txt 403), so its inspection database could not be searched. Absence of a public record is not evidence that nothing happened; DOE's occurrence reports for Ward 250 can be requested under FOIA. Valar's quality program (p.20) cites a different occurrence-reporting order, NE O 232.2; in DOE's own numbering 232.2 (2011) replaced 232.1 (1990s). The NE orders are not public, so which is current cannot be checked.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Occurrence Reporting and Processing of Operations Information”
• Occurrence Reporting and Processing System (U.S. Department of Energy, Office of Environment, Health, Safety and Security) primary government “access to occurrence reports is restricted to approved DOE and DOE contractor personnel”
• 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

DOE side, as the records name them: Robert (Bob) Boston, Manager of DOE's Idaho Operations Office, led the federal review that cleared Ward 250's criticality test and described the joint test group sign-off (ANS); DOE's May 2026 transport QA approval for Valar is addressed to him. Jason Anderson, a DOE NEPA Compliance Officer, signed the categorical exclusion on 22 April 2026. Julia C. Shenk, DOE Headquarters Certifying Official and Director of the Office of Packaging and Transportation, approved the Safety Evaluation Report prepared by Christopher P. Cable, manager of DOE's Packaging Certification Program, which recommends the fuel-package amendment (20 May 2026); she also signed the transport QA approval memo to Boston (18 May 2026). Dr. Rian Bahran, DOE Deputy Assistant Secretary for Nuclear Reactors, was quoted in the NOVA release; NOVA itself ran on Los Alamos's Comet assembly at NCERC, with LANL providing the facility safety envelope and NNSA's Nevada Field Office providing oversight (orig-008). Under DOE-STD-1271 the Energy Secretary (Chris Wright) is the startup approval authority for new reactors unless delegated. Company side: Valar's QA program gives the CEO (Isaiah Taylor) legal responsibility for the facility authorization and the COO/Chief Nuclear Officer oversight of nuclear operations, engineering and QA; Valar's mission page lists Mark Mitchell as Chief Nuclear Officer (orig-003). POWER reports Kiewit Nuclear Solutions was the engineering, procurement and construction contractor. Who signed Ward 250's startup approval is not public.

• Valar's Ward 250 reaches criticality in Utah (American Nuclear Society, Nuclear Newswire, 2026-06-22) news
• Issuance of Quality Assurance Program Approval 0049 (Rev 1) for Valar Atomics, memorandum to Robert Boston, Manager, Idaho Operations Office (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-18) 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
• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 for the Model 9979 Package, Docket 26-35-9979 (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-20) primary government “recommends approval and issuance of a letter amendment to the CoC”
• Los Alamos National Laboratory and Valar Atomics Announce Project NOVA Criticality Milestone in Nevada (joint release on Valar's site) (Valar Atomics / Los Alamos National Laboratory, 2025-11-18) primary company “Confirming core physics at zero power with oversight enables Valar's path to elevated operations”
• Ward250 San Rafael Facility Quality Assurance Program Description, No. 100474, Rev 02 (status: Approved) (Valar Atomics, 2025-10) primary company
• Valar Atomic's Ward 250 Becomes Second Reactor to Go Critical Under DOE Pilot Program (POWER magazine (Sonal C. Patel), 2026-06-19) news “Kiewit Nuclear Solutions served as the project's engineering, procurement, and construction contractor”

As of 29 September 2026: DOE's list of B5.26 advanced-reactor NEPA determinations names only 'Valar Ward250 Research Reactor' for Valar; no NSDA, QA program, safety analysis, emergency plan or radiation monitoring plan for any Carbon County facility appears in Valar's public documents, DOE sources or state records read. The state Trust Lands memorandum leaves the emergency planning zone to future licensing and relays Valar's own safety description (csite-009); it describes fuel manufacturing from HALEU, LEU+ or LEU on site (csite-007), spent-fuel storage only on land Valar would buy (csite-008), and both DOE and NRC as possible regulators (csite-010); Utah's 2026 waste-storage exemption fits state-owned test sites, not a private commercial campus (csite-023). Valar's Castle Country page is headed 'Carbon & Emery County, Utah' but its safety section describes only Ward 250 (csite-027). Which federal agency would review a Carbon reactor, and whether its environmental review would be public, is open.

• Categorical Exclusion Determinations: B5.26 (U.S. Department of Energy, Office of NEPA Policy and Compliance) primary government “CX-271015: Valar Ward250 Research Reactor”
• Castle Country | Valar Atomics (Valar Atomics) primary company “Carbon & Emery County, Utah”

Summary of this file as of 29 September 2026. Authority: Ward 250 runs on a DOE authorization under EO 14301 and DOE-STD-1271, with Valar as its own design authority and no public hearing step (safe-001, safe-002, safe-019); no public copy was found of the documents that define what it may do (DSA, TSRs, DOE's safety evaluation, startup approval) (safe-007); DOE says federal reviewers checked contractor safety submittals for the pilot reactors and took part in Ward 250's readiness review before startup (dir-031); and every approval date comes from Valar (safe-006, safe-027). Where the record disagrees with itself or with Valar: DOE's shipping review describes HALEU fuel for Ward 250, while the only public safety agreement lists 4.95% fuel (safe-010, disc-001); power at 250 kWt is allowed for one hour per run in the NSDA and up to one day, possibly a total, in a later Valar draft (safe-008); the accident inventory assumes 3 MWd against a 30 MWd limit (safe-009); outlet temperature 650 C limit versus 750 C goal (disc-002); worst-case boundary dose stated as under 0.5 rem and under 0.1 rem (safe-013); a 400 m public boundary that cannot fit inside the 20.6-acre lab (safe-014); the NSDA's 400 m dispersion factor is 3.1 to 12.3 times lower than standard rural methods give for its own stated weather (safe-014); it cites 18 criteria of a QA rule that lists 10 (safe-018); its 18-month lifecycle is shorter than its own schedule plus 12 months of operation (safe-009); a state lab director's 'no dose' assurance versus the analysis (safe-015); '72 hours' versus 'indefinitely' of walk-away cooling (safe-020); and DOE's environmental review naming only a fault 150 km away when the state maps one about 15 km away, and saying no major emission source lies within 10 miles when a coal plant is about 6 miles away (safe-021, safe-022). Company claims tested against independent sources: 'unmatched' and 'impossible to melt' go beyond Valar's own limits and UCS's assessment (safe-025); the spent-fuel 'CT scan' claim is disputed by engineers, and no correction was found (safe-026). Public records not found: emergency plan, exercises and any DOE decision on on-site-only planning (safe-016), monitoring data (safe-024), incident reports (safe-033), spent-fuel destination and state permit (safe-023), the fuel line's authorization (safe-031), and the Utah-DOE agreements the NSDA cites (safe-034). Claims that hold are in safe-039. None of this shows the reactor is unsafe; it shows the public cannot check that it is safe.

• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 for the Model 9979 Package, Docket 26-35-9979 (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-20) primary government
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company
• 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
• 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

Claims tested and found supported by the record: DOE confirms Ward 250 is DOE-authorized and completed a zero-power criticality on 18 June 2026 (orig-010). The February 2026 airlift carried the reactor without fuel, and the fuel moved separately from Nevada, consistent across World Nuclear News and DOE's packaging review (safe-012). DOE's packaging reviewers independently recalculated criticality safety for the fuel shipment and agreed with the applicant (safe-012). TRISO fuel's retention of fission products to about 1,600 C is stated in Valar's NSDA, and DOE says TRISO fuel is 'more resistant to neutron irradiation, corrosion, oxidation and high temperatures' than traditional reactor fuels. No active fault is mapped at the Ward 250 site (safe-021), and Valar's no-fault claim for the Carbon parcel checks out (mine-040); the flood reasoning for Ward 250 is consistent across documents (safe-021). The NOVA test was accurately described as operated by Los Alamos under NNSA oversight at zero power (orig-008). The 1 July electricity demonstration shows no sign of a commercial sale that would cross the EO 14301 line (safe-030). The company's 'passive cooling' design is consistent with its safety documents, though the June 26 test is known only from Valar (safe-020). Checked against Valar's own paper: its core-table arithmetic holds; its 100 m worker dispersion factor is at or above DOE's prescribed default; its 0.2 g earthquake value is close to the USGS design value for the site on soft rock (about 0.21 g; safe-021); Hazard Category 2 matches DOE's standard for a reactor this size; and its staffing of one senior operator and one operator per shift meets the NRC research-reactor benchmark.

• Department of Energy Celebrates Second Advanced Reactor Achieving Criticality (U.S. Department of Energy, 2026-06-18) primary government “successfully completed a zero-power fueled criticality demonstration”
• US microreactor transported by air (World Nuclear News, 2026-02-18) news
• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 for the Model 9979 Package, Docket 26-35-9979 (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-20) primary government
• TRISO Particles: The Most Robust Nuclear Fuel on Earth (U.S. Department of Energy, Office of Nuclear Energy, 2019-07-09) primary government “more resistant to neutron irradiation, corrosion, oxidation and high temperatures”

Valar's April 2025 lawsuit post, still online on 29 September 2026, says its analysis indicates that holding spent fuel from its 100 kWt 'Ward One' test reactor (planned life under a month) for five minutes gives radiation exposure equal to a CAT scan. Valar's Ward 250 safety paper, the NSDA, credits reactor shielding that 'cannot be inadvertently defeated', analyses fuel-handling accidents, and plans defueling into storage; DOE's categorical exclusion has the spent core leave in dry storage casks. No Valar correction or published calculation was found. For scale: a CT scan is about 1 to 10 millisieverts (FDA), so five minutes would need 12 to 120 millisieverts an hour; the post gives no amount of fuel, cooling time, distance or shielding.

• Valar Atomics is Suing the NRC (The Nuclear Necessity and our decision to sue the NRC) (Valar Atomics (Isaiah Taylor), 2025-04-07) primary company “gives the equivalent radiation exposure to receiving a CAT scan”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company
• The nuclear fuel cycle (Nuclear explained) (U.S. Energy Information Administration, 2023-10-26) “created when the uranium atoms were split apart”
• 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

Valar's public job board (Greenhouse, read 29 September 2026; postings updated 28 September) lists 92 openings: 71 in Torrance, California and 21 in Orangeville, Utah, and none in Carbon County, Price or Wellington. The Orangeville posts include plant operators, nuclear operations engineer and manager, instrumentation and electrical technicians, a site environmental health and safety specialist, a construction quality inspector, a development and construction finance director, and a Material Control and Accounting Specialist, whose post says the job leads the safeguards program for special nuclear material at Valar's TRISO manufacturing facilities under DOE and NRC requirements. Two fuel posts (a TRISO chemical plant process engineer, posted 16 July, and a TRISO chemical vapor deposition engineer, posted 31 July 2026) describe work to 'install, troubleshoot, and optimize pilot scale uranium processing equipment' in Orangeville; the second calls it a manufacturing 'pilot line' and says the engineer will build on 'completed HAZOPs and existing safety analyses' (a HAZOP is a structured hazard review) as 'the process transitions into production'. Set beside the record: in June 2026 Valar told Orangeville the fuel building would make it the largest US maker of this fuel once completed (loc-016); the job posts describe a pilot stage now; no DOE authorization for the fuel line was found in the public record (safe-031); and the local job figures in loc-004 cannot be matched to a payroll. Job boards change daily; these counts are as of 29 September 2026.

• Valar Atomics job board (Greenhouse public board API: 92 postings with locations and descriptions) (Valar Atomics) primary company “optimize pilot scale uranium processing equipment”
• Material Control and Accounting Specialist (Orangeville, Utah), Valar Atomics job posting (Valar Atomics, 2026-07-22) primary company
• Chemical Vapor Deposition Engineer (TRISO) (Orangeville, Utah), Valar Atomics job posting (Valar Atomics, 2026-07-31) primary company

Utah state job requisition 2646 (Department of Natural Resources), opened September 25, 2026 with an application deadline of October 1, 2026, says the Utah Office of Energy Development (OED) is seeking a Safety Manager to lead the environmental, health and safety program at the Utah San Rafael Energy Lab (USREL), 800 N Coal Haul Rd, Orangeville. The role covers work with hazardous chemicals, molten salts, compressed gases, high-temperature systems, electrical and mechanical equipment, radioactive materials and industrial operations; it is to inspect and audit the lab and partner work areas, review new experiments and equipment before authorization, lead incident investigations, run training and emergency drills, coordinate emergency preparedness with local responders and regulators, and coordinate with the lab's Radiation Safety Officer on radiological training, dosimetry, incident response and license conditions, and with UOSH and Utah DEQ. It reports to the Lab Director, with authority to stop work on an imminent hazard. Minimum: ten years of safety experience and a bachelor's degree; radiological safety experience is listed only as 'desirable'. The listing states: Schedule Code 'TL - Time Limited'; Background Check Required 'No'; Drug Test Required 'No'; full-time, in-office, salary '$58.00' (unit not stated). OED owns the lab and is Valar's landlord there (mine-014); Valar reported first electricity from Ward 250 at the lab on July 1, 2026. The listing does not say whether the position is new or a replacement, or who led lab safety before; it does show that a Radiation Safety Officer role and radiological license conditions already exist at the lab. Ward 250's own nuclear safety basis is Valar's, under DOE's authorization; this job is the state's lab-wide safety lead.

• Safety Manager (req2646), Utah San Rafael Energy Lab, Orangeville: Utah state job listing (Utah Department of Natural Resources, Office of Energy Development (State of Utah careers site), 2026-09-25) primary government “Schedule Code – TL - Time Limited”
• Castle Country (Valar Atomics) primary company

Under 'Fuel Feedstock Delivery & Handling', the memorandum says high-assay low-enriched uranium (HALEU), 'low-enriched uranium plus' (LEU+) or low-enriched uranium (LEU) may be delivered to the site in certified special-nuclear-material containers under NRC, DOT and DOE rules, and that the feedstock 'would then be manufactured into TRISO fuel pellets' for the reactors on site. The staff slides list 'Manufacture TRISO fuel' as a project purpose. The memo does not say which enrichment Valar would use, how much uranium would be kept on site, or which agency would license the fuel plant. Valar's own documents already disagree on whether Ward 250's fuel is 4.95% LEU or HALEU (disc-001, orig-040); the Carbon memo leaves all three grades open.

• 09.17.2026 TLA Board Packet (Item 10A: SULA 2095-OBA Board of Trustees Memorandum, Carbon County letter, lease map) (Utah Trust Lands Administration (Utah Public Notice Website), 2026-09-17) primary government “That uranium feedstock would then be manufactured into TRISO fuel pellets”
• TLA Board of Trustees meeting presentation, August 20, 2026 (Item 9A slides: SULA 2095 OBA) (Utah Trust Lands Administration (Utah Public Notice Website), 2026-08-20) primary government “Manufacture TRISO fuel”
• What is High-Assay Low-Enriched Uranium (HALEU)? (U.S. Department of Energy, Office of Nuclear Energy, 2024-12-03) primary government “HALEU is enriched between 5% and 20% in U-235”
• TRISO Particles: The Most Robust Nuclear Fuel on Earth (U.S. Department of Energy, Office of Nuclear Energy, 2019-07-09) primary government “They can be fabricated into cylindrical pellets or billiard ball-sized spheres”

The staff slides shown to the board on 20 August list among 'Safeguards': 'Storage of nuclear waste is strictly prohibited on the lease'. The memorandum's terms add that before any portion of the property may be used to store radioactive waste, 'that portion, as determined by TLA, must be purchased by the lessee', and that Valar must buy any portion needed for 'interim storage of spent fuel' before storing it; spent fuel may not be stored on land the trust still owns. So storage is barred on land under the lease but provided for on land Valar buys. Utah Code 19-3-301 separately bans placing 'high-level nuclear waste' in Utah unless, among other conditions, the Governor approves with the Legislature's concurrence (a 2026 exemption for test-reactor waste is in csite-023); Utah defines that term by the federal 'high-level radioactive waste' (42 U.S.C. 10101), which covers waste from reprocessing spent fuel plus other highly radioactive material the NRC by rule says needs permanent isolation, while federal law defines 'spent nuclear fuel' separately. Whether used TRISO fuel kept at a Carbon reactor would fall under Utah's ban is not answered in any record read.

• TLA Board of Trustees meeting presentation, August 20, 2026 (Item 9A slides: SULA 2095 OBA) (Utah Trust Lands Administration (Utah Public Notice Website), 2026-08-20) primary government “Storage of nuclear waste is strictly prohibited on the lease”
• 09.17.2026 TLA Board Packet (Item 10A: SULA 2095-OBA Board of Trustees Memorandum, Carbon County letter, lease map) (Utah Trust Lands Administration (Utah Public Notice Website), 2026-09-17) primary government “that portion, as determined by TLA, must be purchased by the lessee”
• Utah Code 19-3-301: Restrictions on nuclear waste placement in state (Utah State Legislature, 2023-02-27) primary government “high-level nuclear waste or greater than class C radioactive waste is prohibited”
• Utah Code 19-3-102: Definitions (Radiation Control Act) (Utah State Legislature, 2025-05-07) primary government
• 42 U.S.C. 10101: Definitions (Nuclear Waste Policy Act) (Office of the Law Revision Counsel, U.S. House) primary government “fuel that has been withdrawn from a nuclear reactor following irradiation”

The memorandum labels its safety statements as the applicant's: 'Information provided by Valar Atomics' says the reactors rely on negative temperature feedback, passive decay-heat removal without operators or outside power ('walk-away safety') and TRISO fuel that retains fission products. On emergencies, 'information provided by the applicant' says on-campus fire, hazmat and radiological response would be set up to match federal licensing, with the size of any Emergency Planning Zone (EPZ) set during licensing. Environmental monitoring 'could include' air, groundwater and surface-water stations, per Valar. Seismic information was also submitted by the applicant (it checks out against the state fault map: mine-040). The memo also relays, as the applicant's representation, that DOE approved preliminary safety documentation for the Ward 250 design and that Valar holds a Certificate of Readiness; those concern the Emery test reactor, not a Carbon reactor (mine-016). No site-specific safety analysis, emergency plan or independent review for the Carbon site appears in any record read. Staff's recommendation adds its own view that Valar 'has demonstrated their ability to perform in a safe and secure manner' at the San Rafael Energy Lab; the memo's support for that is the applicant's own account of its DOE approvals, and it says later permitting and licensing involve 'evaluation by experts'.

• 09.17.2026 TLA Board Packet (Item 10A: SULA 2095-OBA Board of Trustees Memorandum, Carbon County letter, lease map) (Utah Trust Lands Administration (Utah Public Notice Website), 2026-09-17) primary government “including Emergency Planning Zone (EPZ) sizing under federal requirements”
• 09.17.2026 TLA Board Packet (Item 10A: SULA 2095-OBA Board of Trustees Memorandum, Carbon County letter, lease map) (Utah Trust Lands Administration (Utah Public Notice Website), 2026-09-17) primary government “fully passive decay heat removal without operator action or external power (walk-away safety)”
• 09.17.2026 TLA Board Packet (Item 10A: SULA 2095-OBA Board of Trustees Memorandum, Carbon County letter, lease map) (Utah Trust Lands Administration (Utah Public Notice Website), 2026-09-17) primary government “has demonstrated their ability to perform in a safe and secure manner”
• 09.17.2026 TLA Board Packet (Item 10A: SULA 2095-OBA Board of Trustees Memorandum, Carbon County letter, lease map) (Utah Trust Lands Administration (Utah Public Notice Website), 2026-09-17) primary government “involves multiple touch points for public input and evaluation by experts”

PacerMonitor's public page for State of Texas et al. v. U.S. Nuclear Regulatory Commission, 6:24-cv-00507 (E.D. Tex.; Judge Jeremy D. Kernodle; filed 30 December 2024; nature of suit 899, APA review or appeal of agency decision; cause 5:702) lists eight plaintiffs (Texas, Utah, Louisiana, Florida, the Arizona State Legislature, Last Energy, Deep Fission and Valar) against the NRC and shows no termination date. The only entry shown is No. 57, Wednesday 2 September 2026: 'JOINT STATUS REPORT by U.S. Nuclear Regulatory Commission'. The report's text is not public on the page and was not read. A joint status report, not a stipulation of dismissal or a consent decree, is what parties file while a case is pending. The parties list is marked last checked 28 June 2025, so it cannot show whether any plaintiff has since left the case. This is a commercial copy of the docket; the official PACER docket was not read. (Updates safe-028.)

• State of Texas et al v. U.S. Nuclear Regulatory Commission (6:24-cv-00507), Texas Eastern District Court (PacerMonitor (copy of PACER docket)) court docket aggregator “JOINT STATUS REPORT by U.S. Nuclear Regulatory Commission”

Flooding struck Emery County beginning 29 August 2026: on 1 September the Emery County Commission declared a state of emergency for flooding 'beginning on August 29, 2026' from severe thunderstorms and excessive rainfall (minutes), and ETV reported the commission later sought federal watershed help (21 Sept). Orangeville's council held an emergency working meeting on 31 August 2026 on the response, recording sandbagging, damage to the ballfield and a question about how many families in apartments were displaced (minutes); at the 1 September county meeting the sheriff thanked volunteers who helped with 'the flooding event in Orangeville', noting many properties had water damage (minutes). No record read mentions the Valar site. DOE's categorical exclusion says the site is outside FEMA-mapped flood hazard areas and about 100 feet above Cottonwood Creek, which it says eliminates flood risk and any hydraulic connection to the creek (safe-021). Whether roads to the site or emergency services were affected during the flood is not in any record read.

• Orangeville City Council, August 31 emergency working meeting minutes (Orangeville City, 2026-08-31) primary government
• Emery County Commission Meeting Minutes, September 1, 2026 (CM09012026) (Emery County Commission, 2026-09-01) primary government “the flooding event in Orangeville”
• 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 “Elevated site position eliminates flood risk.”
• Emery County delays solar decision, pauses new conditional use permits (ETV News, 2026-09-21) news

ETV News (24 Aug 2026) reported the Emery County Business Chamber's 'Lunch and Learn' tour of Valar's site on 19 August 2026. The report says the reactor is now enclosed in cement block walls; that the site has exhaust equipment designed to detect radioactive particles and shut off the exhaust if there is any potential for outside contamination; and that the helium-cooled design lets the reactor shut down within seconds, 'completely removing the risk of a meltdown'. That last sentence is the paper's narration of what the group learned on the company's tour and is not attributed to a named speaker, so it cannot be treated as Valar's exact words. The report also says Valar discussed 'potential plans' to produce reactors for industrial businesses so heavy power users can move off the grid, citing the Price firm Intermountain Electronics 'strictly as an example'. Set beside the record: Valar's own Nuclear Safety Design Agreement (October 2025 draft) analyses a bounding 'maximum hypothetical accident' that assumes TRISO fuel particle failures beyond demonstrated limits and a release of radioactive material, and estimates the resulting dose at the site boundary (safe-013, loc-035); the Union of Concerned Scientists calls TRISO 'far from meltdown-proof' (safe-025). No public monitoring data for the exhaust system has been published (safe-024). Supplying reactors to private businesses would be commercial use, which the DOE research pathway Ward 250 runs under does not cover; that would need separate licensing (safe-030).

• Emery County Business Chamber gets an up-close look at Valar Atomics' progress (Stephanie Olsen) (ETV News, 2026-08-24) news “completely removing the risk of a meltdown”
• Ward250 Nuclear Safety Design Agreement (Document 100403, Revision 02, marked draft, October 2025) (Valar Atomics, 2025-10) primary company “TRISO fuel particle failures exceeding demonstrated limits”

The memorandum of understanding signed on 27 July 2026 by Energy Secretary Chris Wright and Gov. Spencer Cox to establish a Nuclear Lifecycle Innovation Campus (NLIC) in Utah (posted by OED; read from its page images) names, as the 'Historical Foundation' of the partnership, 'the successful permitting, development, and testing of Valar Atomics' Ward 250' test reactor at the San Rafael lab. It calls for a later Host Agreement that 'shall address the acceptance and management of out-of-state used nuclear fuel, spent nuclear fuel, high-level radioactive waste, and greater than class C radioactive waste'; says permanent disposal facilities at the campus would be NRC-licensed, with the state never the licensee; has DOE provide regulatory oversight under 10 CFR 830 for non-NRC activities; says decisions on public disclosure under FOIA or GRAMA 'will be made following consultation between the Parties'; and lets either side end it if no Host Agreement is signed by 30 September 2026. It also commits both sides to 'robust community engagement and transparency' (3.1), runs for 30 years, and extends federal nuclear-accident indemnity (AEA section 170d) to the state, campus tenants and contractors. The MOU names no site; the governor's March 2026 release named Tooele County as the candidate host (gov-015 sources), and no record read places the campus in Carbon or Emery County. Set beside the record: the only permitting on file for Ward 250 is DOE's (safe-001, safe-007); no state permit for it was found (gov-017).

• Memorandum of Understanding Between the Department of Energy and the State of Utah Concerning the Establishment of a Nuclear Lifecycle Innovation Campus in the State of Utah (signed July 27, 2026) (U.S. Department of Energy and State of Utah (posted by Utah Office of Energy Development), 2026-07-27) primary government “the successful permitting, development, and testing of Valar Atomics’ Ward 250”
• Utah and Tooele County explore response to U.S. Department of Energy opportunity for Nuclear Lifecycle Innovation Campus (Office of the Governor of Utah, 2026-03-27) primary government

DOE's HALEU Availability Program is the announced route by which companies get high-assay low-enriched uranium from federal stocks, including NNSA material. DOE's releases name the recipients of each round's conditional commitments (ten commitments to nine recipients; Radiant twice): round 1 (9 April 2025, 15 companies had applied) TRISO-X, Kairos, Radiant, Westinghouse and TerraPower; round 2 (26 August 2025) Antares, Standard Nuclear and Abilene Christian University/Natura; round 3 (23 July 2026) NASA and Radiant again. Valar is not in any of them. DOE's Fuel Line Pilot launch release makes each company responsible for 'the procurement of all nuclear material feedstock' (gov-007), and its 30 September 2025 selection release, which named Valar, says selected companies may apply for HALEU through the HALEU Availability Program (orig-032). Set beside that: Valar says it supplied the HALEU TRISO fuel for NOVA at Los Alamos's Nevada criticality center (orig-008), and DOE's own May 2026 packaging review cleared limited shipments of HALEU TRISO fuel compacts, packed in a Valar graphite fuel block holding about 235 grams of uranium-235 at under 20% enrichment, from that federal center to Ward 250, with DOE's Savannah River Operations Office as the applicant (safe-010, safe-012). No public record read says where Valar's HALEU came from, who owns it, whether it is federal material on loan, or on what terms. The pilot program's own Request for Application, as summarized by the law firm Hogan Lovells, told applicants needing HALEU to 'ensure they are in the allocation process' of that program (gov-032). This is a gap in the public record, not evidence of wrongdoing; the fuel may have been supplied under the OTA or another agreement that is not public (gov-003).

• U.S. Department of Energy to Distribute First Amounts of HALEU to U.S. Advanced Reactor Developers (U.S. Department of Energy, 2025-04-09) primary government “DOE received HALEU requests from 15 companies.”
• U.S. Department of Energy to Distribute Next Round of HALEU to U.S. Nuclear Industry (U.S. Department of Energy, 2025-08-26) primary government
• Energy Department to Distribute Third Round of HALEU to NASA and Radiant (U.S. Department of Energy, Office of Nuclear Energy, 2026-07-23) primary government
• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 (Docket 26-35-9979) (U.S. Department of Energy, Packaging Certification Program, 2026-05-20) primary government
• DOE's Office of Nuclear Energy issues Request for Application for Reactor Pilot Program (Daniel Stenger, Stewart Forbes, Valerie Marshall) (Hogan Lovells, 2025-07-01) analysis “ensure they are in the allocation process to receive HALEU”
• Energy Department Selects Four Companies for Advanced Nuclear Fuel Line Pilot Projects (U.S. Department of Energy, 2025-09-30) primary government “Companies may apply to receive high-assay low-enriched uranium (HALEU)”

DOE's Office of Environmental Management (EM) wrote on 14 July 2026 that 17 EM team members 'took part in DOE’s readiness review process for facility startup' and transition to operations for the four Reactor Pilot Program reactors that went critical by 4 July, naming Valar Atomics' Ward 250. It says readiness review team members reviewed documents, took part in onsite interviews and performance demonstrations, and 'prepared the final report with recommendation to the startup authorization authority' for approval to proceed with nuclear operations. They also reviewed corrective action plans and closure documents answering 'DOE-identified pre- and post-start findings'. The article does not say which reactor any finding concerned, or give each reactor's report or recommendation separately. It also says EM staff reviewed contractor safety submittals from preliminary to final design before recommendation to the safety basis approval authority. Separately, the DOE Nuclear Criticality Safety Program manager wrote in the program's Summer 2026 newsletter that NNSA's NA-ESH office 'has been helping out performing the federal readiness reviews for these reactors'. This is DOE's own confirmation of the kind of review Valar described to the state lab board in May (gov-037). The readiness report, its findings and the startup authorization remain unpublished (safe-007). (Updates gov-037.)

• EM Specialists Help DOE Achieve Criticality Milestones for Advanced Reactors (U.S. Department of Energy, Office of Environmental Management, 2026-07-14) primary government “prepared the final report with recommendation to the startup authorization authority”
• EM Specialists Help DOE Achieve Criticality Milestones for Advanced Reactors (U.S. Department of Energy, Office of Environmental Management, 2026-07-14) primary government “took part in DOE’s readiness review process for facility startup”
• NCSP Newsletter, Summer 2026: A Message from the NCSP Manager (U.S. DOE Nuclear Criticality Safety Program (hosted by LLNL), 2026-08-10) primary government “has been helping out performing the federal readiness reviews for these reactors”

DOE's NEPA determination DOE-ID-26-005, signed on 22 April 2026 by a DOE NEPA compliance officer, decided that Ward 250 fits categorical exclusion B5.26 and needs no further NEPA review (csite-020). Federal law defines a categorical exclusion as a category of actions an agency has determined 'normally does not significantly affect the quality of the human environment' (42 U.S.C. 4336e(1)). B5.26 still requires DOE to determine that a project's attributes 'reduce sufficiently the risk of adverse offsite consequences' (CX p. 6), and the determination summarizes what the 'Documented Safety Analysis demonstrates' (p. 5). Nuclear-safety authorization is a separate track with separate officials. Under DOE's nuclear safety rule, a contractor 'may not begin operation' of a new Hazard Category 1, 2 or 3 facility before DOE issues a safety evaluation report approving its safety basis (10 CFR 830.207(a)); Valar's NSDA names 10 CFR 830 as its governing rule and classes Ward 250 as Hazard Category 2. DOE-STD-1271-2025 makes DOE's Office of Nuclear Energy the Safety Basis Approval Authority, which approves the Safety Evaluation Report, and the Secretary of Energy (or a delegate) the Startup Approval Authority, and says satisfactory completion of a DOE readiness review 'results in DOE issuing Startup Approval'. DOE's Office of Environmental Management wrote on 14 July 2026 that readiness assessments 'are necessary for NE to authorize startup' and that its staff took part in the readiness review for the four pilot reactors, naming Ward 250 (dir-031). So the categorical exclusion is neither DOE's safety approval nor evidence that the safety review was skipped. What is public from each track: the NEPA determination is posted; from the safety track, DOE's statements that Ward 250 was authorized (orig-010) and that readiness reviews took place (dir-031) are public, while no public copy of the safety evaluation report, the approved safety basis or the startup approval was found (safe-007).

• 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 “reduce sufficiently the risk of adverse offsite consequences”
• 42 U.S.C. 4336e: Definitions (NEPA sec. 111) (Office of the Law Revision Counsel, U.S. House of Representatives (uscode.house.gov)) primary government “normally does not significantly affect the quality of the human environment”
• 10 CFR Part 830: Nuclear Safety Management (2024 edition), sec. 830.207(a) (U.S. Government Publishing Office (govinfo.gov), Code of Federal Regulations, 2024 annual edition, 2024-01-01) primary government “a contractor may not begin operation of the facility or modification prior to”
• DOE-STD-1271-2025, Authorization Pathway for Nuclear Facilities, sec. 3.0 and 9.1 (DOE standard; copy published by the Nuclear Innovation Alliance) (U.S. Department of Energy (hosted by Nuclear Innovation Alliance), 2025-08) primary government “Satisfactory completion of the DOE Readiness Review results in DOE issuing Startup Approval”
• EM Specialists Help DOE Achieve Criticality Milestones for Advanced Reactors (U.S. Department of Energy, Office of Environmental Management, 2026-07-14) primary government “The assessments are necessary for NE to authorize startup for the reactors.”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Hazard Category 2 designation based on material at risk”
• eCFR version history, 10 CFR Part 830 (latest amendment date 2020-11-18) (Office of the Federal Register, eCFR (ecfr.gov)) primary government

ETV News (16 July 2026) reported that at the Orangeville City Council meeting of 9 July 2026 a councilman said Orangeville ambulance availability was 13% during the past month, against 24% the month before; that closure of the Orangeville-Castle Dale ambulance garage was being considered if staffing could not be fixed; and that the county had tabled the EMS district's funding request. On 21 July the Emery County Commission voted to direct the first $200,000 of state payment-in-lieu-of-taxes money each year for five years to the emergency medical district, to raise on-call pay by $2 an hour (ETV, 28 July). Valar's safety agreement asks to plan for on-site emergencies only and relies on coordination with Emery County Emergency Management, Emery County Fire and local responders (safe-016); no public emergency plan or drill record for Ward 250 was found (safe-016). How often an ambulance would be available for the Valar site, which lies on Coal Haul Road west of Orangeville (Castle Dale minutes, 12 March 2026), is not in any record read. The city's own minutes confirm the 13% figure for June (9 July); record on 11 June the fire chief saying the ambulance had been 'only available 14% of the time' and a council report that county ambulance arrival times were averaging 25 minutes and that stations might be combined; and record the city fire chief saying on 19 February that he would meet Valar on its fire safety plan and reporting on 12 March that he had gone through Valar's safety protocols and 'everything is looking well'.

• Orangeville City Council approves resolutions, discusses EMS and Valar (Kevin Butler) (ETV News, 2026-07-16) news
• Emery County Commissioners Debate Solar, Data Centers and EMS Funding (Kevin Butler) (ETV News, 2026-07-28) news
• July 9, 2026 City Council Meeting Minutes (Orangeville) (Orangeville City, 2026-07-09) primary government “Orangeville Ambulance had a 13% availability for the month of June”
• June 11, 2026 City Council Minutes (Orangeville) (Orangeville City, 2026-06-11) primary government “County ambulance arrival time is averaging 25 minutes”
• February 19, 2026 City Council Meeting Minutes (Orangeville; notice text) (Orangeville City, 2026-02-19) primary government “will meet with valor on the Fire Safety Plan for the facilities”
• March 12, 2026 Regular Session Minutes (Orangeville) (Orangeville City, 2026-03-12) primary government “met with Valar Atomics to go through there safety protocols”
• Castle Dale City Council Meeting Minutes, March 12, 2026 (approved; scanned, read as page images) (Castle Dale City, 2026-03-12) primary government “the site is located on Coal Haul Road west of Orangeville”

Partnership for Global Security (its president, Ken Luongo, March 13, 2026) argues the C-17 flight was political and public-relations 'cinema'; that what flew was a single non-operational, unfueled unit delivered in three pieces; that the Wall Street Journal reported Valar paid for the flights, roughly estimated at under $1 million (WSJ not read); that U.S. military aircraft had carried small reactors before, including two Russian TOPAZ-II space reactors flown by C-5 in 1992; that Valar is not part of any military reactor project (the Defense Department's Project Pele reactor is being built by BWXT); and, citing former DOE nuclear chief Katy Huff, that a cold zero-power test does not show hot, full-power performance. It also wrote that no power production would occur at the Utah site; Valar says, and Deseret News reported, that Ward 250 made electricity there on July 1, 2026 (orig-013, orig-042). MIT Technology Review (July 9, 2026) reports that four pilot reactors, Valar's among them, reached zero-power criticality by the July 4 deadline; that criticality and running a reactor that can make electricity are two different things; that startup timelines deserve caution; and that a Third Way memo called the federal push an 'unhelpful diversion'. Both are analysis, not findings by a regulator.

• A Hollywood Highlight Reel for the Nuclear Renaissance (Ken Luongo) (Partnership for Global Security, 2026-03-13) analysis “What was transported was a single, non-operational, and unfueled unit, delivered in three pieces.”
• Four nuclear reactors hit a big milestone in the US (The Spark newsletter) (MIT Technology Review, 2026-07-09) analysis “reaching criticality and running a reactor that can produce electricity are two totally different things”

EO 14301 places advanced reactors under DOE rather than NRC jurisdiction when DOE exercises sufficient control and they do 'not ... produce commercial electric power'. Valar says Ward 250 generated electricity on 1 July 2026, 'directly powering an NVIDIA chip' (orig-013; Deseret News reported the event, orig-042), and Valar and NVIDIA said they were exploring a 30 MW data center powered by Valar reactors (orig-042). No record read shows Ward 250 selling electricity. The Nuclear Innovation Alliance notes that the Atomic Energy Act lets DOE retain 'for its own account' the commercial application of an initial demonstration reactor, that section 44 governs the sale of electricity incidental to test and demonstration reactors, and that sales of electricity to third parties 'raise unresolved regulatory questions' for DOE and the NRC. DOE-STD-1271 says the DOE pathway is meant to accommodate 'leveraging into an NRC license'. On the record read, the July 1 demonstration stays inside the non-commercial line; any commercial use of Valar reactors would need NRC licensing (csite-010).

• Executive Order 14301, Reforming Nuclear Reactor Testing at the Department of Energy, 90 FR 22591 (Executive Office of the President (Federal Register), 2025-05-29) primary government “and not to produce commercial electric power”
• Castle Country | Valar Atomics (Valar Atomics) primary company “directly powering an NVIDIA chip”
• A Review of Recent DOE Updates to Its Reactor Authorization Process (Nuclear Innovation Alliance) analysis “such sales raise unresolved regulatory questions for the DOE and NRC”
• 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 “intended to accommodate efficient and effective leveraging into an NRC license”

ETV News (3 July 2026) reported the Carbon County Commission meeting of Wednesday 1 July 2026 (ETV's text gives 'June 2' and 'June 1', but its publication date, the fire restrictions ahead of the Fourth of July and the NVIDIA announcement place it on 1 July; the commission's 1 July minutes record the same celebration, csite-026). As ETV reported it, Commissioner Jared Haddock described Ward 250 as having recently become 'the first government-approved commercial reactor' to achieve a self-sustaining reaction outside a federal lab, and Commissioner Tony Martines said that because Valar's reactor is gas-cooled and NVIDIA's chips are air-cooled, the planned data center won't need water. Set beside the record: Valar's own February 2026 release says Ward 250 is a research reactor and 'not a commercial power plant' (loc-003); DOE's pilot is for research and 'not' to demonstrate commercial suitability (gov-007); DOE's 'first DOE authorized reactor built outside of a national laboratory' holds (orig-010). On water, Valar's own account to Emery County was that the data center would use a closed-loop cooling system 'designed for low water consumption' and that it already had the water it needs, while seeking up to 1,000 more shares for other projects (ETV, 28 July; mine-042). The 'first outside a federal lab' part holds; 'commercial' and 'won't need water' go beyond what Valar and DOE say.

• Carbon County Commissioners urge safety ahead of July 4th, reflect on freedom and democracy (Stephanie Olsen) (ETV News, 2026-07-03) news “the first government-approved commercial reactor”
• Valar Atomics welcomes community for reactor facility open house (Valar Atomics press release) (ETV News, 2026-02-24) primary company “it is not a commercial power plant”
• Emery County Commissioners Debate Solar, Data Centers and EMS Funding (Kevin Butler) (ETV News, 2026-07-28) news

Valar's unlisted 'Ward 250 By the Numbers' draft (28 June 2026) embeds a chart titled 'Reactor Power Ascension - TE3401 thermocouples with Q_Total, Power, and Control Bank overlays'. The horizontal axis is 'Sample index' (0 to about 245), not time; no date or clock time appears. A black line 'Q_Total' on an unlabeled right-hand scale of 0 to 100 rises in steps (about 15, about 52, then about 95 to 100) and then drops to near zero around sample 230, when the 'Control Bank Steps' line also falls to zero, which looks like a shutdown. The ten thermocouple lines (TE3401-094 to -105 in the legend) read between about 30 and 80 degrees Fahrenheit, so they are not core temperatures. The title promises a 'Power' overlay that the legend does not show. If Q_Total is in kilowatts, the chart is consistent with a climb to about 100 kW followed by shutdown; the chart itself does not say so, and it cannot show when this happened, for how long, or whether it matches DOE's authorization. No DOE or independent power record has been published to compare it with (plan-006, safe-007).

• Reactor Power Ascension - TE3401 thermocouples with Q_Total, Power, and Control Bank overlays (chart image) (Valar Atomics, 2026-06-28) primary company
• Ward 250 By the Numbers (unlisted draft, dated 28 June 2026) (Valar Atomics, 2026-06-28) primary company

The NSDA's safety limits (page 25) set 'Maximum continuous power: 100 kWth' and 'Maximum short duration power (1hr): 250 kWth'; its design table (page 52) says '≤250 kWth (Limited tests)'. Valar's unlisted 'Ward 250 By the Numbers' page (28 June 2026, still containing placeholders such as 'July XX') says the reactor is 'licensed' for 30 effective full-power days at 100 kWt 'and up to one day at 250kWt'. If the page's day means one continuous day, it would be 24 times the NSDA's per-run limit; if it is a total across runs, the two can fit. Neither document says which. The final DSA and TSRs, which set the authorized limit, are not public, so which figure DOE approved is unknown. DOE's categorical exclusion and Valar's NSDA web summary describe Ward 250 simply as a 250 kWth reactor; ANS (June 2026) reports that Taylor 'has indicated the Ward 250 is a 100-kWt reactor', and POWER describes it as rated at 100 kWt initial test power (orig-011, orig-031). Ward 250 has no NRC license; 'licensed' is the company's word for a DOE authorization.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Maximum short duration power (1hr): 250 kWth”
• Ward 250 By the Numbers (unlisted company page with placeholders, signed Isaiah Taylor) (Valar Atomics (Isaiah Taylor), 2026-06-28) primary company “up to one day at 250kWt”
• 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 “Ward250 is a 250 kilowatt thermal (kWth) high temperature gas-cooled reactor”
• Valar's Ward 250 reaches criticality in Utah (American Nuclear Society, Nuclear Newswire, 2026-06-22) news “has indicated the Ward 250 is a 100-kWt reactor”
• Valar Atomic's Ward 250 Becomes Second Reactor to Go Critical Under DOE Pilot Program (POWER magazine (Sonal C. Patel), 2026-06-19) news “rated at 100 kWt initial test power and scalable to 5 MWe”

In its unlisted 'Ward 250 By the Numbers' draft (28 June 2026), Valar says its beliefs have led it to be 'a very open and transparent company', that its reactor has been more photographed and filmed than any other in history, and that it is sharing raw data to be refined by internal and external peer review over the following weeks. The page still contains placeholders ('July XX', '[xxx]') and one chart, 'Reactor Power Ascension', which plots an unlabelled 'Q_Total' on a 0-100 scale and thermocouple readings of about 30-80 F against a 'sample index', with no power units, dates or time scale, so it cannot be used to check the power reached. Of the safety documents the NSDA and DOE records name for Ward 250, two were found published by Valar: the NSDA (marked 'Draft', safe-005) and the QA Program Description (safe-018). Not published: the PDSA, final DSA and Technical Safety Requirements, the Code of Record (document 100437), the startup and commissioning plan, the radiation protection program, the transport QA program (document 100719, which DOE approved, safe-012) and any emergency plan. The Physical Security Plan and Material Control and Accountability Plan are security documents that are normally withheld. State officials praised Valar's openness at the Trust Lands hearings (csite-028).

• Ward 250 By the Numbers (unlisted company page with placeholders, signed Isaiah Taylor) (Valar Atomics (Isaiah Taylor), 2026-06-28) primary company “These beliefs have led us to being a very open and transparent company.”
• Reactor Power Ascension: TE3401 thermocouples with Q_Total, Power, and Control Bank overlays (chart image on the draft page) (Valar Atomics, 2026-06-28) primary company
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company
• Issuance of Quality Assurance Program Approval 0049 (Rev 1) for Valar Atomics, memorandum to Robert Boston, Manager, Idaho Operations Office (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-18) primary government

Valar's NSDA sets target performance for decay-heat removal: capacity for 100% of decay heat, natural circulation within 30 minutes, and 'No operator action required for 72 hours' (page 23); it credits a reactor cavity cooling system, a vessel auxiliary cooling path and conduction to the structures. DOE's categorical exclusion (April 2026), describing the project's attributes, states that the passive system keeps fuel below safety limits 'indefinitely' without operator action or outside power. Valar's Castle Country page says that on 26 June 2026 it shut Ward 250 down, switched off every active cooling system, simulated a total loss of electrical power and watched the reactor cool itself. That test came eight days after the first criticality DOE announced (18 June). ANS reported Valar's announcement that it reached 10 kWt on 22 June, and Valar's Castle Country page says full power came 'days later' than criticality; no DOE or independent record of the test, and no power log before it, was found; how much heat a reactor must shed after shutdown depends on how long and how hard it ran, which the NSDA's own accident method ties to operating history (safe-009). The claim of passive cooling is consistent with the design documents; the June 26 demonstration rests on the company's account.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “No operator action required for 72 hours”
• 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 “maintains fuel temperatures below safety limits indefinitely without operator action or external power”
• Castle Country | Valar Atomics (Valar Atomics) primary company “Then we watched the reactor cool itself safely, exactly as designed.”
• Valar's Ward 250 reaches criticality in Utah (American Nuclear Society, Nuclear Newswire, 2026-06-22) news “on June 22 announced it had reached a 10 kWt output”

The federal officials who deal with Valar, by role (see safe-036 for who signed which safety papers): Energy Secretary Chris Wright, the startup approval authority for new DOE reactors unless delegated, rode the Ward 250 airlift (orig-030) and in DOE's 18 June 2026 release said Valar 'is delivering achievements that mark a revolutionary moment'; before taking office he sat on the board of Oklo, another company in DOE's reactor and fuel-line pilots (orig-032), and Oklo's release (dated 6 Feb 2025 on its site) says he stepped down from its board on his confirmation as Secretary on 3 Feb 2025. Rian Bahran, DOE Deputy Assistant Secretary for Nuclear Reactors, was quoted praising NOVA (ppl-008 source); his ANS biography says he spent over a decade at Los Alamos (whose NCERC ran NOVA), then advised the Under Secretary of Defense for Policy and served at the White House science office. Robert (Bob) Boston, Manager of DOE's Idaho Operations Office, led the review that cleared Ward 250 (orig-011); DOE's page says he is the safety-basis approval authority for all existing and new reactors at INL, holds a master's degree in nuclear engineering, and has emeritus status as a professional engineer and certified health physicist. Deputy Secretary James Danly announced the pilot selections (orig-041) and a Defense under secretary flew with the reactor (orig-030). The pattern, from the record: the department that authorizes and oversees Ward 250's safety is also its most visible public promoter (safe-001, safe-002). No record read shows any of these officials holding a financial or employment tie to Valar.

• Department of Energy Celebrates Second Advanced Reactor Achieving Criticality (U.S. Department of Energy, 2026-06-18) primary government “Valar Atomics is delivering achievements that mark a revolutionary moment for advanced nuclear”
• Oklo Announces Board Transition Following Chris Wright's Confirmation as Secretary of Energy (Oklo Inc., 2025-02-06) primary company “has stepped down from Oklo’s Board to assume this critical role”
• Rian Bahran (speaker biography, 2025 ANS Winter Conference & Expo) (American Nuclear Society, 2025) analysis “an experimentalist and as a program manager”
• Robert Boston (U.S. Department of Energy, Office of Nuclear Energy) primary government
• Los Alamos National Laboratory and Valar Atomics Announce Project NOVA Criticality Milestone in Nevada (Valar Atomics, 2025-11-18) primary company “This milestone underscores collaborative efforts propelling nuclear innovation responsibly”

Approved minutes of the Utah Waste Management and Radiation Control Board's 11 June 2026 meeting (approved 9 July 2026) record that, under 'Commissioner Davis's Report', Commissioner Davis said the Valar test reactor in Orangeville (spelled 'Valor') was expected to go critical between then and 4 July. He described it as a small test reactor designed to generate a couple of hundred kilowatts of heat, not electricity. He said that 'once the reactor goes critical (on-line), oversight of the radioactive materials will transition' from the Division to the U.S. Department of Energy. He added that this was the first such transition he had been involved in and that such transitions are expected to become more common. The minutes do not say what radioactive materials were at the site, whether reactor fuel had arrived, or under what state authorization the Division oversaw them. The board's meeting agendas list no Valar item (csite-023); the remark came in the commissioner's report. The meeting audio is posted but was not reviewed. (Updates plan-025.)

• June 11, 2026, Waste Management and Radiation Control Board Meeting Minutes (approved July 9, 2026), Item IX (Utah Department of Environmental Quality (Utah Public Notice Website), 2026-07-09) primary government “once the reactor goes critical (on-line), oversight of the radioactive materials will transition”

Orangeville City Council minutes, 11 June 2026, public comment: Valar's Harry Hansen, who said he has a background with the state energy office, answered council questions. Asked how many local workers were hired, he said he would get an accurate number. Asked whether Valar's second building is another reactor, he said it is not: Valar will manufacture its own fuel there, the fuel is 'extremely safe', and 'Once completed they will be the largest manufacturer of this fuel in the United States'. Asked whether the energy would go to data centers, he said data centers 'could be purchasers' but the energy has no set destination or purchaser yet. Set beside the record: the fuel building matches the lab's January 2026 release and Valar's QA plan for a 'Valarin' TRISO fuel facility (loc-003, orig-038); no DOE safety authorization for the fuel line has been made public (safe-031); the 'largest' claim is about the future and cannot be tested now; selling Ward 250's energy would fall outside DOE's research-only basis for authorizing it (safe-030).

• June 11, 2026 City Council Minutes (Orangeville) (Orangeville City, 2026-06-11) primary government “Once completed they will be the largest manufacturer of this fuel”

State records show the San Rafael lab hosting or courting several nuclear developers besides Valar: NuCube (MOU with OED, 6 May 2025 per OED's slides; named with Valar to legislators in June 2025, gov-019), which POWER reports was instead selected with Idaho State University in April 2026 for DOE's Launch Pad USA, to site its test reactor on ISU's Pocatello campus; Natura Resources, which holds an NRC construction permit for a molten-salt reactor in Texas and whose project at the lab (medical isotopes, a planned test reactor) the Energy Research Board approved the same day as Valar's (13 Aug 2025, gov-013), and which OED told legislators is leasing 'the majority of the space' at the lab (Oct 2025); and Nuclea Energy, a Canadian company, whose MOU to explore siting a 3.5 MW electric test reactor the board approved on 11 February 2026 and OED signed on 2 June 2026, with OED offering to 'support licensing conversations' with DOE and the NRC and to help explore deployment 'beyond test reactors'. Valar itself proposed a 10 MW gas-fired heater for power-cycle tests (gov-014), is buying the 112-acre parcel next door for fuel fabrication and manufacturing (gov-022), and plans a TRISO fuel line (safe-031). The lab told its board in February 2026 it was adding perimeter fencing and ID checks 'to meet DOE standards'. No public safety analysis or environmental review for these other projects was found in the records read, as of 2026-09-29.

• Memorandum of Understanding between OED and Nuclea Energy USA Inc. (OED26142), signed June 2, 2026 (Utah Office of Energy Development, 2026-06-02) primary government “OED is willing to support licensing conversations with both the Department of Energy”
• Utah Energy Research Board Meeting Minutes, February 11, 2026 (Utah Energy Research Board, 2026-05-13) primary government “to explore siting a 3.5 MW electric test reactor at the lab”
• Board Meeting Minutes, Utah Energy Research Board, August 13th, 2025 (Utah Energy Research Board, 2025-11-13) primary government
• Office of Energy Development Update, PUET Interim Committee, October 15, 2025 (Utah Office of Energy Development, 2025-10-15) primary government
• From Pilot to Launch: DOE Names First Four Nuclear Energy Launch Pad Developers (Sonal C. Patel) (POWER, 2026-04-28) news

The New Republic (Colin Jones, 26 May 2026) reports that Valar's suit against the NRC 'had long been backburnered'. It says both sides filed a joint motion for a 60-day stay on 30 April (year not stated; the context points to 2026), that they file again whenever a stay expires, and that the case 'remains in abeyance today'. Citing Bloomberg Businessweek, it reports that earlier in April one of the plaintiffs' lawyers emailed colleagues that the NRC was willing to settle by ceding regulatory authority over some small reactors to state agencies, and that Utah is already moving to set one up. It also reports that in January (2026, by context) one of the corporate plaintiffs' lawyers withdrew from the case to join the Office of the Deputy Attorney General at DOJ. This is second-hand reporting of a private email. It describes a willingness to settle, not a settlement. The Bloomberg piece was not read. (Updates safe-028.)

• Donald Trump Is Going Nuclear (The New Republic, 2026-05-26) news “the NRC was willing to settle, ceding regulatory authority over some small reactors”

Named critics and assessors, with their professional standing as the sources give it: Nick Touran, a nuclear engineer who spent 16 years at TerraPower and runs WhatIsNuclear.com, disputed the spent-fuel 'CAT scan' claim (safe-026); Taylor replied, per UIJP, that 'a good engineer does not make claims about things he simply has no knowledge of', and promised a detailed write-up that Mother Jones says never came; by early 2026 Touran told The New Republic that Valar had updated its calculations and would not hold the fuel when it comes out of the reactor, while expecting the test reactor to be under-engineered; the magazine itself describes the original statement as Taylor having 'erroneously claimed' that spent fuel could be held. Gavin Ridley, a nuclear engineer, calculated a lethal dose in 85 milliseconds of contact, as Mother Jones reported (his inputs are not given in the record read; compare the worked check in pf-007). Anna Erickson, Georgia Tech nuclear engineering professor, called Valar's lack of NRC engagement a red flag: 'We can't take your word for it' (UIJP). Allison Macfarlane, former NRC chair, called start-up founders 'nuke bros' (MJ) and said none of these reactors 'exist' as products yet (TNR). Scott Morris, the NRC's former No. 2 career official, objected most to the lack of transparency in the new DOE pathways (TNR adds that there are no plans to make that regulatory work public); Doug Robison, founder of pilot-program peer Natura Resources, the only pilot company with an NRC construction permit, said bypassing the NRC 'scares the hell out of me'; Paul Dickman, retired Argonne policy fellow, dismissed the July 4 criticality goal (all TNR). Edwin Lyman (UCS) and former DOE nuclear chief Katy Huff are covered in safe-003 and orig-026. Their statements are opinions and analyses, not regulatory findings.

• Who is Valar Atomics? (Eric Peterson) (The Utah Investigative Journalism Project, 2025-07-08) news “We can’t take your word for it”
• Who is Valar Atomics? (Eric Peterson) (The Utah Investigative Journalism Project, 2025-07-08) news “a good engineer does not make claims about things he simply has no knowledge of”
• Donald Trump Is Going Nuclear (Colin Jones) (The New Republic, 2026-05-26) news “they’ve updated the calcs and understanding”
• Donald Trump Is Going Nuclear (Colin Jones) (The New Republic, 2026-05-26) news “Scares the hell out of me”
• At just 27 years old, this entrepreneur is remaking America's energy industry (Eva Terry) (Deseret News, 2026-03-17) news “a nuclear engineer who spent 16 years at TerraPower”
• Mother Jones (Kiera Butler), 26 Feb 2026 (May+June 2026 issue) (Mother Jones, 2026-02-26) news “I will follow up with a detailed writeup tonight or tomorrow”

A Los Alamos article on the NOVA experiment (LA-UR-26-20601), in the Spring 2026 newsletter of DOE's Nuclear Criticality Safety Program, says NOVA ran at NCERC over four weeks in November and December 2025 on the Deimos capability, with the inner core changed to 'a portion of the Ward250 reactor'. It says NOVA used many of Ward250's actual materials, including the type of graphite, control-rod material and fixed-absorber material. It says data were taken in 36 configurations, 10 of them critical, and that the fuel was the HALEU TRISO 'CNPS compacts previously used in Deimos'. LANL's December 2024 Deimos release says that experiment used components long in the NCERC inventory, 'such as the fuel'. LANL's Deimos paper says the CNPS fuel came from a 1980s Los Alamos experiment (dir-027). The joint LANL-Valar NOVA release on Valar's site (18 November 2025) says under 'Roles and Safeguards' that Valar Atomics provided the reactor core, TRISO fuel and system configuration, and ANS Nuclear News reported the same on 18 November 2025 (orig-008, orig-032, plan-014). The two accounts differ on where NOVA's fuel came from. No record read explains the difference. (Updates orig-008.)

• NCSP Newsletter, Spring 2026: 'Nuclear Observations for Valar Atomics (NOVA)', LA-UR-26-20601 (pp. 5-6) (U.S. DOE Nuclear Criticality Safety Program (Los Alamos article; hosted by LLNL), 2026-05-22) primary government “(HALEU) Tri IsoStructural (TRISO) CNPS compacts previously used in Deimos”
• Los Alamos conducts first critical experiment using high assay low enriched uranium in decades (Los Alamos National Laboratory, 2024-12-16) primary government “existing components that have long been in the NCERC inventory, such as the fuel”
• Los Alamos National Laboratory and Valar Atomics Announce Project NOVA Criticality Milestone in Nevada (Valar Atomics / Los Alamos National Laboratory (joint release on Valar's site), 2025-11-18) primary company “provided the reactor core, TRISO fuel, and system configuration.”
• Valar achieves cold criticality at LANL (American Nuclear Society, Nuclear News, 2025-11-18) news “Valar provided the reactor core, system configuration, and the TRISO fuel itself.”

The certificate half of DOE's May 2026 shipping review is a one-page memorandum dated 20 May 2026 from DOE's Headquarters Certifying Official (Director, Office of Packaging and Transportation) to the Manager of DOE's Savannah River Operations Office. Answering email requests of 30 April and 19 May 2026 made for the Savannah River Site Office Manager, it amends Certificate of Compliance 9979, Revision 20, to authorize 'limited shipments' of TRISO fuel compacts from the National Criticality Experiments Research Center in Nevada to the Valar Atomics Ward 250 reactor site in Utah. Its conditions are: 170 compacts per package, secured in the WARD250 fuel block (drawing V-002782); at most 234.94 g of U-235 per block; 'The maximum U-235 enrichment is less than 20 weight percent'; a criticality safety index of 1.0; and expiry on 30 June 2027 or at completion of shipments. The companion SER (safe-010) says the uranium is 'enriched to a maximum of 19.9 wt.% U-235'. Both are limits on what may be shipped, not a measurement of what was loaded. No earlier authorization for these contents in this package was found. Revision 21 of the same certificate (date of issuance 2 September 2026; answering a 1 December 2025 request supplemented 13 April 2026) and its SER do not mention Valar, Ward 250 or the letter amendment, and neither says whether the Valar authorization carries forward. (Updates safe-010.)

• Letter Amendment of Department of Energy Certificate of Compliance Number 9979 (memorandum, Revision 20 LA1) (U.S. Department of Energy, Office of Packaging and Transportation, 2026-05-20) primary government “The maximum U-235 enrichment is less than 20 weight percent.”
• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979, Docket 26-35-9979 (U.S. Department of Energy, Packaging Certification Program, 2026-05-20) primary government “enriched to a maximum of 19.9 wt.% U-235”
• Amendment of DOE Certificate of Compliance Number 9979, Revision 21 (memorandum and certificate) (U.S. Department of Energy, Office of Packaging and Transportation, 2026-09-02) primary government “Revision 21, for the Model 9979 package is issued for amendment”
• Safety Evaluation Report for Amendment of DOE CoC 9979, Docket 26-04-9979 (U.S. Department of Energy, Packaging Certification Program, 2026-09) primary government

The only fuel supply for Valar on the record is DOE's: a Safety Evaluation Report approved 20 May 2026 lets Savannah River's shipping package carry 'limited shipments' of HALEU TRISO fuel compacts from the National Criticality Experiments Research Center in Nevada to the Ward 250 site, at most 24 packages, one Valar-designed graphite fuel block each, expiring 30 June 2027 or when shipments end (safe-010, safe-011, safe-012). The report describes each block as 170 TRISO compacts holding 234.94 grams of uranium-235 at under 20% enrichment. Valar's own safety agreement (NSDA, October 2025, Table 6) lists the fuel enrichment as '4.95% U-235' on the basis of 'LEU limits'; the two documents describe different fuel, and no document read explains the difference (disc-001). No public record read gives the dates the fuel actually moved (plan-025). Neither that report nor Valar's NOVA release nor World Nuclear News's NOVA report (21 November 2025) names who fabricated the TRISO particles or compacts, or who owns the high-assay uranium; Valar is not in DOE's three announced HALEU allocation rounds (gov-008). Valar's Series B post says it 'will not rely on outside suppliers' and will make fuel in labs beside its reactors (orig-070), and its Carbon plan has uranium shipped in as HALEU, LEU+ or LEU (csite-007). But making TRISO still needs enriched uranium from an enrichment plant; Valar has no enrichment capacity, and a web search in the earlier pass found no supply contract with any U.S. enricher (Centrus, Urenco, Orano, General Matter). For comparison, World Nuclear News reported on 18 September 2026 that the fuel for Antares's criticality test, another DOE pilot reactor, was supplied by BWX Technologies, and that Antares had signed a multi-year HALEU supply contract with Centrus (the article gives no signing date). Valar is one of 84 signers of DOE's Defense Production Act fuel-cycle pact (gov-001), which is a framework, not a supply contract.

• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979, Revision 20 (Valar Atomics fuel elements) (U.S. Department of Energy, Packaging Certification Program, 2026-05-20) primary government “from the National Criticality Experiments Research Center in Nevada to the Valar Atomics”
• Valar Atomics project achieves early criticality milestone (World Nuclear News, 2025-11-21) news “NOVA uses the same fuel, moderator and reactivity-control scheme as Ward250”
• Announcing our $1B Series B Led By Sequoia (Valar Atomics, 2026-08-04) primary company “Valar will not rely on outside suppliers for the fuel needed to deploy and operate.”
• Antares, Centrus sign multi-year HALEU contract (World Nuclear News, 2026-09-18) news “The fuel for the criticality demonstration was provided by BWX Technologies, Inc.”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (October 2025), Appendix A, Table 6: Key design parameters (Valar Atomics, 2025-10) primary company “4.95% U-235”

A DOE Safety Evaluation Report, prepared by the manager of DOE's Packaging Certification Program and approved by DOE's Headquarters Certifying Official on 20 May 2026, reviews and recommends an amendment to the certificate of the Model 9979 shipping package to allow 'limited shipments' of high-assay low-enriched uranium (HALEU) TRISO fuel compacts from the National Criticality Experiments Research Center (NCERC) in Nevada to the Valar Ward 250 reactor site in Utah. Each package holds one hexagonal graphite 'WARD250 FUEL BLOCK' (Valar drawing V-002782) with 170 compacts; the U-235 in a block is 234.94 grams 'at less than 20% enrichment', the application describes the uranium in the particles as 'enriched to a maximum of 19.9 wt.% U-235', and the stated condition is 'less than 20 weight percent'. The report says the block's end use is as a fuel element in the Ward 250 microreactor. Valar's NSDA (October 2025, Table 6) lists Ward 250's fuel enrichment as '4.95% U-235' on the basis of 'LEU limits', and says that if the fuel differs from the specification its safety assumptions will be updated in the PDSA. The later PDSA and DSA are not public, so whether DOE's approved safety basis was updated to HALEU cannot be checked. This is the DOE record that disc-001 lacked: it matches the NOVA release's 'HALEU TRISO' wording (orig-008, orig-009) and a Valar speaker's statement that part of the core went critical in Nevada (mine-033), and conflicts with the NSDA's 4.95% figure (orig-034, orig-040). Per element, the NSDA's own figures imply 162.83 g of U-235 in 3.29 kg of heavy metal; DOE's block holds 234.94 g of U-235 in 1.18 kg of uranium. No single enrichment fits both (76 such blocks holding 250 kg would need 7.14%), so Table 6's equal per-element loading does not match the block DOE cleared, unless some of the 76 elements are unfueled or loaded differently, which the paper does not say.

• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 for the Model 9979 Package, Docket 26-35-9979 (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-20) primary government “limited shipments of high-assay low-enriched uranium (HALEU) tri-structural isotropic (TRISO) fuel”
• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 for the Model 9979 Package, Docket 26-35-9979 (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-20) primary government “The U-235 mass in the block is 234.94 grams at less than 20% enrichment.”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “4.95% U-235”
• Los Alamos National Laboratory and Valar Atomics Announce Project NOVA Criticality Milestone in Nevada (joint release on Valar's site) (Valar Atomics / Los Alamos National Laboratory, 2025-11-18) primary company “NOVA uses the same fuel, moderator, and reactivity-control scheme as Ward250”
• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-20) primary government “enriched to a maximum of 19.9 wt.% U-235”

The DOE Safety Evaluation Report (safe-010) notes that 'only 24 packages (24 fuel elements)' would be authorized under the amendment, one fuel block per package, each limited to 234.94 grams of U-235: at most about 5.64 kg of U-235 in all (24 x 234.94 g). At an enrichment under 20%, each block carries at least about 1.17 kg of uranium (234.94 g divided by 0.20), so 24 blocks hold roughly 28 kg of uranium or more. Valar's NSDA describes a core of 76 fuel elements with about 250 kg of heavy metal at 4.95%, which is about 12.4 kg of U-235 (250 kg x 4.95%). The authorization expires on 30 June 2027 or when shipments are complete. At the state Trust Lands hearing on 17 September 2026, a Valar speaker described Ward 250 as 'very lightly loaded' and not a fully loaded core (mine-033). Whether other fuel reached Ward 250 by another route is not stated in any record read. Per element, the NSDA's own figures imply 162.83 g of U-235 in 3.29 kg of heavy metal; DOE's block holds 234.94 g of U-235 in 1.18 kg of uranium. No single enrichment fits both (76 such blocks holding 250 kg would need 7.14%), so Table 6's equal per-element loading does not match the block DOE cleared, unless some of the 76 elements are unfueled or loaded differently, which the paper does not say.

• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 for the Model 9979 Package, Docket 26-35-9979 (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-20) primary government “only 24 packages (24 fuel elements) would be authorized for shipment”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company

World Nuclear News reports that Ward 250 was flown on 15 February 2026 'without its nuclear fuel', and, citing Reuters, that Energy Secretary Wright said the fuel would move separately from the Nevada National Security Site. DOE's packaging review (safe-010) followed: DOE's Savannah River Operations Office asked on 30 April 2026 to use the Model 9979 package (a 30-gallon drum inside a 55-gallon drum, a Type A fissile package) for the Ward 250 fuel blocks; the application, prepared by Savannah River National Laboratory, was revised on 18 May 'to correct decay heat and A2 mixture errors noted by DOE PCP staff'. DOE staff ran their own criticality calculations, which agreed with the applicant's, and the report, approved on 20 May, sets conditions (unsealed bagging, criticality safety index 1.0, at most 234.94 g of U-235 per package, expiry 30 June 2027 or when shipments end). Separately, DOE approved Valar's own radioactive-material packaging and transportation quality program (QA Program Approval 0049, issued 13 May 2026, corrected 18 May for Valar's address; expires 31 May 2031), covering Type B and fissile packagings. Neither DOE document states the shipping dates, route or mode, and no state or county notice of the shipments was found. Fresh (unused) TRISO fuel is only mildly radioactive: The application estimated the block's decay heat at about 0.0005 watts, which DOE's review accepted, and the review says shielding review is unnecessary for Type A fissile packages like this one.

• US microreactor transported by air (World Nuclear News, 2026-02-18) news “Fuel for the reactor will be transported separately from the Nevada National Security site”
• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 for the Model 9979 Package, Docket 26-35-9979 (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-20) primary government “to correct decay heat and A2 mixture errors noted by DOE PCP staff”
• Issuance of Quality Assurance Program Approval 0049 (Rev 1) for Valar Atomics, memorandum to Robert Boston, Manager, Idaho Operations Office (U.S. Department of Energy, Office of Packaging and Transportation (Packaging Certification Program), 2026-05-18) primary government

Minutes of the Utah Energy Research Board's 13 May 2026 meeting (PDF posted 14 August 2026) record Jess Housekeeper, Valar's Director of Utah Operations, saying in public comment that the final DOE readiness report was expected that Friday 'to prepare for receiving fuel and starting the reactor'. That reads as fuel not yet received (gov-037). DOE's letter amendment allowing fuel-compact shipments from Nevada to the Ward 250 site is dated 20 May 2026 (dir-025). DOE announced on 18 June 2026 that Ward 250 had completed a zero-power fueled criticality demonstration. So, on the record, fuel was on site by 18 June. It arrived after 13 May by Valar's account, and after 20 May if it came in the DOE-cleared package, the only route on record. DOE's categorical exclusion for Ward 250 (signed 22 April 2026) says 'Spent fuel is a single core loading' and 'No refueling occurs during the operational mission'. No record read gives the shipment date, route or mode, the date fuel was loaded, or how many of the 24 cleared blocks moved (plan-025, safe-011). (Updates plan-025.)

• Utah Energy Research Board, Meeting Minutes, May 13, 2026 (Utah Office of Energy Development (Utah Public Notice Website), 2026-08-14) primary government “to prepare for receiving fuel and starting the reactor”
• Letter Amendment of DOE Certificate of Compliance Number 9979 (memorandum) (U.S. Department of Energy, Office of Packaging and Transportation, 2026-05-20) primary government “Revision 20 is amended to authorize use of the Model 9979 for limited shipments”
• Department of Energy Celebrates Second Advanced Reactor Achieving Criticality (U.S. Department of Energy, 2026-06-18) primary government “successfully completed a zero-power fueled criticality demonstration”
• Categorical Exclusion Determination CX-271015 (DOE-ID-26-005), Valar Atomics Ward250 (U.S. Department of Energy, 2026-04-22) primary government “No refueling occurs during the operational mission.”

H.B. 78 (2026, 'Nuclear Regulatory Amendments', effective 6 May 2026) enacted Utah Code 19-3-321: the state's high-level-waste placement restrictions (csite-008) do not apply to interim storage of nuclear waste that is produced from a DOE-authorized project, is from a test reactor, and is produced at a facility owned by the state, if the project is permitted and licensed by the Division of Waste Management and Radiation Control (DWMRC). Ward 250 is a DOE-authorized test reactor at the state-owned San Rafael lab (orig-010). The Carbon memo requires Valar to buy any land used for spent-fuel storage (csite-008), so such storage would not be at a state-owned facility, and the campus is described as commercial. H.B. 78 also created a Nuclear Energy Regulatory Office in DWMRC and lets DWMRC, if the NRC authorizes it, license fuel-cycle work including fuel fabrication and storage of nuclear material. DWMRC's public-notice page listed no current hearing or comment period naming Valar on 29 September 2026 (it shows only current actions, not past ones). The Waste Management and Radiation Control Board's 14 meeting notices from June 2025 to 10 September 2026 list no Valar item (agenda text searched).

• Utah Code 19-3-321: Exemptions (Utah State Legislature, 2026-05-06) primary government “is produced at a facility owned by the state”
• H.B. 78 Nuclear Regulatory Amendments (2026, enrolled copy) (Utah State Legislature, 2026) primary government “establishes the Nuclear Energy Regulatory Office”
• Waste Management and Radiation Control Public Notices (Utah Department of Environmental Quality) primary government
• Waste Management and Radiation Control Board: notices (June 2025 to Sept 2026) (Utah Public Notice Website) primary government

2026 H.B. 78, 'Nuclear Regulatory Amendments' (Rep. Carl Albrecht, Sen. Derrin Owens; effective 6 May 2026), creates a Nuclear Energy Regulatory Office inside the Division of Waste Management and Radiation Control (DWMRC), lets the division regulate fuel-cycle activities (enrichment, fabrication, storage, waste) 'subject to authorization' by the NRC, directs it to weigh expanded Agreement State status, and requires a yearly report to the Natural Resources interim committee by 30 November. Its new 19-3-321 exempts from Part 3 of the Radiation Control Act, 'Placement of High Level Nuclear Waste' (whose licensing path requires approval by the governor and Legislature, 19-3-304), the interim storage of waste that is 'produced from a project authorized by' DOE, 'from a test reactor', and 'at a facility owned by the state', but only if the project 'is permitted and licensed by the division'. Ward 250 is the one DOE-authorized test reactor on state-owned property in Utah found in the record (csite-023, mine-035). No DWMRC permit or license naming Valar was found (open question in carbon_site.json); the lab itself holds low-level radioactive-material licenses, per its director's August 2025 remarks to the Energy Research Board (gov-013). The bill does not give the state any authority over a DOE-authorized reactor's operation, which stays with DOE (safe-034).

• H.B. 78 Nuclear Regulatory Amendments, 2026 General Session, Enrolled Copy (Utah State Legislature, 2026-03) primary government “is produced at a facility owned by the state”
• Utah Code Title 19, Chapter 3, Part 3, Placement of High Level Nuclear Waste (section list) (Utah State Legislature) primary government

The NRC announced proposed 10 CFR Part 57, 'Licensing Requirements for Microreactors and Other Reactors With Comparable Risk Profiles', on 24 April 2026 (News Release 26-047). It published the rule in the Federal Register on 1 May 2026 (91 FR 23628, FR Doc. 2026-08550, docket NRC-2025-0379, RIN 3150-AL36), with a correction on 15 May (C1-2026-08550); comments closed 15 June 2026. In section C, 'Utilization Facilities and General Licenses', the NRC says stakeholders had raised redefining 'utilization facility' to exclude some reactors from AEA section 103 licensing, and that it considered this. The proposal keeps the 1956 definition ('any nuclear reactor' other than plutonium or U-233 production reactors) and carries it into Part 57. The NRC's discussion of the AEA's safety and security prongs 'suggests that any nuclear reactor would meet both prongs' and so be a utilization facility regulated by the NRC. General licenses are proposed only for construction of certain components. The rule implements Executive Order 14300, which requires the final rule by 23 November 2026. The notice does not mention the lawsuit or any settlement. The proposal does not give the plaintiffs the redefinition they sued for; a final rule could differ.

• Licensing Requirements for Microreactors and Other Reactors With Comparable Risk Profiles (proposed rule), 91 FR 23628 (Federal Register (Nuclear Regulatory Commission), 2026-05-01) primary government “any nuclear reactor would meet both prongs and constitute a utilization facility”
• NRC Proposes a New Licensing Framework to Accelerate Safe, High-Volume Deployment of Microreactors (News Release 26-047) (U.S. Nuclear Regulatory Commission, 2026-04-24) primary government “Part 57 is designed to deploy microreactors with safety, scale, and speed.”

Emery County's commissioners in 2026 are Dennis Worwood (chair), Jordan Leonard and Keven Jensen (ETV News). On 17 February 2026 they commended Valar 'for their transparency' when the reactor arrived and approved a support letter (orig-046); Jensen said 'your visions and values line-up with ours'. At an April 2026 public hearing on selling county land next to the lab to Valar (ETV, 9 Apr 2026), state lab director Jaron Wallace, answering a concern about truck traffic, spoke of the economic benefits and noted the land was zoned as an industrial park for such expansion; when residents asked about a buffer zone, the reply, as ETV put it, was that 'with these small reactors the fence line is all the buffer zone needed' (ETV does not say who replied), and Worwood and Leonard, who had toured the nuclear project at Kemmerer, Wyoming, 'concurred with Valar'. Jensen noted permits would still come from the county; a letter of commitment to sell was approved subject to two appraisals, and a 10-acre staging-area agreement with a liability waiver. Set beside the record: Valar's own safety agreement puts the accident-analysis boundary 400 m from the reactor, farther than the 20.6-acre lab's fence reaches (safe-014), and estimates up to 5 rem for a worker 100 m away in its worst-case accident (safe-013). The buffer-zone answer, as reported, is not what Valar's own analysis assumes.

• Emery Commission public hearing receives comments on the sale of property to Valar Atomics (ETV News, 2026-04-09) news “with these small reactors the fence line is all the buffer zone needed”
• Valar Atomics announce the arrival of nuclear reactor to Emery County (ETV News, 2026-02-19) news “your visions and values line-up with ours in this area.”

POWER magazine's June 19, 2026 report says Ward 250's DOE Documented Safety Analysis received preliminary approval in February 2026 and final approval on April 23, 2026, ahead of the June 18 criticality. It describes Ward 250 as a TRISO-fueled modular HTGR with helium coolant and names applications including electricity, process heat, hydrogen and materials processing. The DSA itself was not read; whether it is public is an open question (see safety.json and government.json). POWER also names Kiewit Nuclear Solutions as the engineering, procurement and construction contractor. The Partnership for Global Security separately wrote in March 2026 that the government had approved Valar's preliminary safety analyses.

• Valar Atomic’s Ward 250 Becomes Second Reactor to Go Critical Under DOE Pilot Program (POWER Magazine, 2026-06-19) news
• A Hollywood Highlight Reel for the Nuclear Renaissance (Ken Luongo) (Partnership for Global Security, 2026-03-13) analysis “the U.S. government has approved its Preliminary Documented Safety Analyses”

The NSDA scheduled submittals of the NSDA (22 Sept 2025), PDSA (1 Nov 2025) and final DSA and TSRs (6 Jan 2026), each with a 45-day DOE review, construction complete by 13 April 2026 and initial criticality on 30 June 2026. POWER (19 June 2026) reports preliminary DSA approval in February 2026 and final DSA approval on 23 April 2026; its links for both dates go to Valar's LinkedIn posts, which require a login and were not read. Valar's Castle Country page says Ward 250 operates with 'DOE-approved safety documentation and a completed operational readiness review'. ANS reports, citing Boston's LinkedIn post, that the federal review was led by Bob Boston, a manager at DOE's Idaho Operations Office, and that a joint test group had to sign off on key start-up steps before DOE authorized the criticality test. DOE's 18 June 2026 release calls Ward 250 'the first DOE authorized reactor built outside of a national laboratory' but does not mention the DSA, the readiness review or the startup approval. DOE's categorical exclusion, signed 22 April 2026, already describes what 'the Documented Safety Analysis demonstrates', the day before the reported final approval (it may refer to the DSA as submitted). No DOE document approving the PDSA, DSA, TSRs or startup was found on DOE's sites as of 29 September 2026 (see safe-007). DOE's Office of Environmental Management wrote on 14 July 2026 that its staff took part in DOE's review of the pilot microreactor designs 'from preliminary to final design', and that 17 EM team members took part in the readiness review for the four pilot reactors that went critical by 4 July, naming Ward 250 (dir-031); the article gives no Ward 250 dates or documents. Under 10 CFR 830.207(a), the rule the NSDA names, a contractor may not begin operating a new Hazard Category 1, 2 or 3 facility before DOE issues a safety evaluation report approving its safety basis; DOE's statement that Ward 250 was authorized and went critical fits that step having been completed, though the report itself was not found (safe-041).

• Valar Atomic's Ward 250 Becomes Second Reactor to Go Critical Under DOE Pilot Program (POWER magazine (Sonal C. Patel), 2026-06-19) news
• Castle Country | Valar Atomics (Valar Atomics) primary company “DOE-approved safety documentation and a completed operational readiness review”
• Valar's Ward 250 reaches criticality in Utah (American Nuclear Society, Nuclear Newswire, 2026-06-22) news
• Department of Energy Celebrates Second Advanced Reactor Achieving Criticality (U.S. Department of Energy, 2026-06-18) primary government “the first DOE authorized reactor built outside of a national laboratory”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company
• 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 “The Documented Safety Analysis demonstrates”

DOE's NEPA determination DOE-ID-26-005, digitally signed on 22 April 2026 by a DOE NEPA compliance officer (the PDF's web address places its upload in June 2026), categorically excluded 'Valar Ward250 Research Reactor' at the Utah San Rafael Energy Research Center from further NEPA review under category B5.26. DOE created B5.26 by a Federal Register notice effective 2 February 2026 (comments were taken afterwards, to 4 March), under Executive Order 14301; it covers 'Authorization, siting, construction, operation, reauthorization, and decommissioning of advanced nuclear reactors' if DOE finds the risk of offsite release is sufficiently reduced and wastes can be managed, and says a project 'may include multiple reactors'. The notice states that reactors 'developed for additional purposes, such as power production and industrial applications' are also appropriate for it. DOE's B5.26 listing showed five determinations on 29 September 2026. No DOE NEPA document for a Carbon County site was found.

• 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 “the proposed action is hereby categorically excluded from further NEPA review”
• Categorical Exclusion for Advanced Nuclear Reactors, 91 FR 4550 (FR Doc. 2026-02071), DOE's posted copy (U.S. Department of Energy (Federal Register notice), 2026-02-02) primary government “For the purposes of this category, a project may include multiple reactors”
• Categorical Exclusion Determinations: B5.26 (U.S. Department of Energy, Office of NEPA Policy and Compliance) primary government

Valar's Nuclear Safety Design Agreement (October 2025) describes a lifecycle of about 18 months from authorization through decommissioning: a pre-operational phase, 12 months of nuclear operations in test campaigns, then defueling and decommissioning that returns the site to unrestricted use. DOE's environmental determination (22 April 2026) describes a 24-month research program: about 12 months of reactor operation, 6 months of in-vessel cooldown and 6 months of decommissioning, after which the single core of spent fuel goes in dry casks to an unnamed 'DOE-approved facility' (safe-023). DOE's agreement with Valar runs from October 2025 to 4 July 2027 (orig-055). If operations are counted from criticality in June 2026, the 12 months end around June 2027, and DOE's schedule puts the end of decommissioning around mid-2028; no record read gives the actual planned end date. Set beside this, Valar now describes the Utah site as permanent: its head of projects told the state trust-lands board the lab is 'no longer just a test facility' (ppl-006), it is buying the neighboring 112-acre parcel (gov-022), it was approved for a state tax credit that requires it to stay 10 years (fund-017), and its Castle Country page says 'we're ready to build more'. At the 1 July 2026 event Taylor said the fuel inside Ward 250 would let it keep running for 165 years (KSL/Deseret, 6 July); that describes the fuel's capacity at very low power, not the approved plan, which is about 12 months of operation with no refueling (DOE). The two are not necessarily in conflict (the test reactor can be removed while the company stays), but no public document says what replaces Ward 250 or whether Ward 250 will actually be torn down on the stated schedule.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (October 2025), page 8 (Valar Atomics, 2025-10) primary company “a structured lifecycle spanning approximately 18 months from authorization through decommissioning”
• NEPA Determination DOE-ID-26-005: Valar Ward250 Research Reactor (U.S. Department of Energy, Office of Nuclear Energy, 2026-04-22) primary government “consisting of approximately 12 months of reactor operation followed by 6 months”
• Castle Country (Valar Atomics, 2026-09) primary company “We think of this as home, and we're ready to build more.”
• New partnership touts nuclear-powered AI with minimal water use (KSL.com (Eva Terry, Deseret News), 2026-07-06) news “The fuel inside the Ward250 will let it continue running for 165 years”

The NSDA's accident doses are calculated for a site boundary 400 m from the reactor, described as 'the nearest point of public access', with the nearest residence at about 800 m and the nearest group at 1,200 m. DOE's categorical exclusion describes USREL as 'a 20.6-acre site', with Ward 250's reactor complex and fuel laboratory inside a security-fenced area of about 2 acres; ETV News (October 2025) reported Valar's allotment at the lab as 11 acres. A circle of 400 m radius covers about 124 acres (pi x 400 m squared = 502,655 square metres), so no point on a 20.6-acre site can be 400 m from every edge of it. The 400 m boundary must therefore run over land outside the lab, and no record read says who controls public access there. The NSDA's own dispersion factors show why it matters: the one it uses at 100 m is 16 times the one at 400 m (4.0e-3 versus 2.5e-4 s/m3), and its worst-case dose at 100 m is under 5 rem. Our check: the 100 m factor meets DOE's prescribed default, but the 400 m factor is 3.1 to 12.3 times lower than standard rural methods give for the paper's stated weather, so its 400 m bounds may be low by that factor (still far below 25 rem). In August 2026 Valar said it was buying about 110 acres north of the lab from Emery County, and later state records describe the land as purchased (mine-018); that could put more nearby land under Valar's control, but it post-dates the October 2025 NSDA and no record read says whether it covers the 400 m circle. No public copy of the approved DSA's site description, which would define the boundary, was found. DOE's categorical exclusion says 'Radiation monitoring and controlled access are maintained during operations', without saying where. No DOE document read sets 400 m as a required exclusion boundary for Ward 250; it is the distance at which Valar's draft paper calculates public doses.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “400m to site boundary, 800m to nearest residence”
• 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 “a 20.6-acre site in a rural area of central Utah”
• What's actually happening at the Utah San Rafael Energy Lab? (ETV News, 2025-10-10) news “Their buildings are currently under construction in their 11-acre allotment.”

DOE's categorical exclusion for Ward 250 states that no major emission sources exist within 10 miles of the site. The Utah Geospatial Resource Center's power-plant layer places the Hunter coal plant (listed at about 9.6 million tonnes of CO2 a year; the layer's figures carry a 2008 adjustment date) about 9.5 km (6 miles) and the Huntington coal plant (about 5.9 million tonnes) about 15 km (9 miles) from a point beside the lab (safe-021); given the reference point's uncertainty of about 2 km, Hunter is clearly inside 10 miles and Huntington is near that line. ANS's Nuclear Newswire describes the site as 'flanked by gigawatt-scale coal stations and active coal mines'. The NSDA separately screens out industrial fire hazards on a 10-mile separation. The CX sentence appears in its air-quality section, where the point is background air quality; it does not change the radiological analysis, but as written it is contradicted by the state's data.

• 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 “No major emission sources exist within 10 miles.”
• PowerPlants_CO2 (Utah Geospatial Resource Center layer of power plants, distance query) (Utah Geospatial Resource Center) primary government
• Valar's Ward 250 reaches criticality in Utah (American Nuclear Society, Nuclear Newswire, 2026-06-22) news “flanked by gigawatt-scale coal stations and active coal mines”

DOE's categorical exclusion describes the spent fuel as 'a single core loading' to be put in dry storage casks for transport to a 'DOE-approved facility', which it does not name; about 6 months of in-vessel cooldown and 6 months of decommissioning follow 12 months of operation. It estimates under 1 cubic metre a year of solid low-level waste (filters, clothing, small equipment) sent to a licensed disposal site, says no radioactive waste will be left on site after decommissioning, and says the site returns to unrestricted use. The NSDA says defueling will send spent fuel 'to appropriate storage' and decommissioning will return the site to unrestricted use. DOE-STD-1271 lists 'Responsibilities and Liabilities for Decommissioning and Disposition of Wastes' among the topics the DOE contract should cover; that contract (the OTA) is not public, and DOE's reactor-pilot release says companies bear all decommissioning costs (orig-041). Utah's 2026 law exempts interim storage of waste from a DOE-authorized test reactor at a state-owned facility from the state's high-level-waste ban, but only if the Division of Waste Management and Radiation Control permits and licenses it; no such permit or application naming Valar was found (csite-023). Where the spent fuel will go, when, and who pays if Valar cannot are not stated in any record read.

• 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 “dry storage casks for transport to DOE-approved facility”
• 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 “No radioactive waste will be left on site after decommissioning.”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Facility decommissioning returns the site to unrestricted use”
• 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 “Responsibilities and Liabilities for Decommissioning and Disposition of Wastes”

The categorical exclusion says routine discharge of liquid radioactive effluent is prohibited, with infrequent batch releases allowed only below DOE's derived concentration standards (NE O 458.1) and 'in accordance with local utility permits'; gaseous effluents are 'negligible'; HEPA-filtered ventilation keeps negative pressure; 'No Clean Air Act permits are required'; and the public dose limit is 100 millirem a year. The NSDA says radiological air emissions 'will be evaluated' for the EPA's radionuclide air standard (40 CFR 61 Subpart H), with EPA coordination through DOE's Idaho Operations Office, and promises environmental monitoring data sharing and 'Regular environmental reporting' to state agencies. The NSDA's continuous-monitoring list covers neutron flux (three channels), core outlet temperature, primary coolant pressure and area radiation levels, and it commits to real-time fission-product ('fission break') monitoring with shutdown required on high coolant activity; the CX describes that shutdown as automatic. No environmental monitoring results, EPA air-emission determination, utility discharge permit, or state report naming Ward 250 was found on DOE, EPA or Utah DEQ pages read as of 29 September 2026.

• 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 “Routine discharge of liquid radioactive effluent is prohibited.”
• 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 “No Clean Air Act permits are required.”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Radiological air emissions will be evaluated for compliance with 40 CFR 61 Subpart H”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Regular environmental reporting maintains transparency with state environmental agencies.”
• 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 “with automatic reactor shutdown on detection of elevated primary coolant activity”

DOE's Office of Nuclear Energy article '5 Fast Facts about DOE Reactor Authorization' (published 10 April 2026, updated 16 April) says the Atomic Energy Act gives DOE authority to authorize reactors for research, development and demonstration; that its process is 'fundamentally similar to the NRC process' in all aspects of reactor safeguards and security, and 'The main change is in how those requirements are spelled out'; and that the updated pathway emphasizes safety standards over 'the fine details' of how to meet them. It says the earlier DOE guidance ran over 1,500 pages with 17 steps before construction could begin, and the revamped pathway has 11 steps and eliminates more than 900 pages; it also says the NRC is monitoring the pilot reactors' progress. It states that the reactor developer is responsible for the reactor's safety, and DOE's job is to review designs and ensure authorized facilities protect workers, the public and the environment. This is DOE's published position; it does not answer UCS's specific points (safe-003) one by one.

• 5 Fast Facts about DOE Reactor Authorization (U.S. Department of Energy, Office of Nuclear Energy, 2026-04-10) primary government “Bottom line: the reactor developer is responsible for ensuring the safety of the reactor.”
• 5 Fast Facts about DOE Reactor Authorization (U.S. Department of Energy, Office of Nuclear Energy, 2026-04-10) primary government “The main change is in how those requirements are spelled out.”

At the same 7 April 2026 Emery County hearing, a resident asked about safety buffer zones; Valar's representative answered that every design has to be reviewed and approved by the Department of Energy. Asked about 'turmoil' between the state and the NRC, Valar's Max Ukropina said past laws had been burdensome and that President Trump had loosened some regulations. Set beside the record: for Ward 250 the answer holds, since DOE alone authorizes it (safe-001, gov-005). For what Valar has described next it is incomplete: three months later Valar told the state's incentive board it plans 'additional commercial units in the area' and behind-the-meter power sales (gov-033); the executive order behind the DOE route covers reactors that do not produce commercial electric power (gov-005); and DOE's own releases, and Hogan Lovells' summary of the law, place later commercial licensing with the NRC (gov-007, gov-032, csite-010). DOE's Launch Pad USA pathway can authorize non-federal sites, but no record read shows Valar using it for another site (gov-010).

• Emery County Commission Meeting Minutes, April 7, 2026 (public hearing on sale of parcel 04-0019-0030) (Emery County Commission (Utah Public Notice Website), 2026-04-07) primary government “every design has to be reviewed and approved by the Department of Energy”
• GOED Board Meeting Minutes, July 9, 2026 (Governor's Office of Economic Opportunity (Utah Public Notice Website), 2026-09-10) primary government “they plan to install additional commercial units in the area”
• Executive Order 14301 (90 FR 22591) (Federal Register (GPO govinfo), 2025-05-29) primary government “that do not produce commercial electric power”

ProPublica reported on 20 March 2026 (Avi Asher-Schapiro; republished by The Salt Lake Tribune on 13 April 2026) that 'a recent DOE memo seen by ProPublica cites cost savings on shielding for Valar's reactor to justify changing' the radiation-exposure limits, putting 'shielding-related cost reductions' at '$1-2 million per reactor', and that internal DOE documents show the department 'has been considering a fivefold increase' to the limit for public exposure to radiation. A DOE presentation made in its Idaho offices argued changing dose rules could cut some new reactors' cost by as much as 5%. ProPublica says whether the agencies will change the legal limits is an open question. DOE said its radiation standards protect people and the environment; the NRC declined to comment; Valar did not reply. The memo itself is not public. Valar's CEO has called radiation-exposure limits a top barrier to the industry's growth (orig-019).

• ProPublica, 20 March 2026 (Avi Asher-Schapiro): DOE memo on radiation limits citing Valar's reactor (ProPublica, 2026-03-20) news “cites cost savings on shielding for Valar's reactor to justify changing those limits”
• In pushing Trump nuclear plan, DOGE cracked jokes about risks to Utah residents (ProPublica, republished) (The Salt Lake Tribune, 2026-04-13) news

Castle Valley Special Service District (CVSSD) runs water and sewer for Castle Valley towns including Orangeville. Its approved minutes of 19 February 2026 record Valar's Jess Housekeeper presenting Valar's plans (by video), the board approving a $20,000 outside-district water connection for Valar contingent on all water shares being submitted to Orangeville, and the manager reporting that Valar 'will be required to apply to' the state Division of Water Quality (DWQ) for a sewer discharge permit, which DWQ would administer for four years, and that no sewer connection would be approved until DWQ approved the permit. The approved minutes of 19 March 2026 (whose opening line misdates the meeting to 19 February) record the manager's update: sewer plans 'were not submitted to the State as required', water service work was paused pending DWQ approval, 'Valar tied into the county sewer system without prior authorization', Valar was asking for ordinary sanitary sewer service for restrooms only with no process water, a site visit with the regional DEQ engineer was planned, and water service would not be provided until all sewer permits and approvals were in place; no action was taken. The district's May, July and August 2026 minutes (read; the June minutes, approved on 16 July, are not posted) do not return to the sewer issue, though the May minutes discuss annexing property near Orangeville 'that may be developed by Valor', and its 17 September agenda lists no Valar item. DOE's categorical exclusion puts water use under 1,000 gallons a day for domestic use, with no process-water discharges (safe-021), which matches the restrooms-only request. Whether DWQ issued a permit, and whether the tie-in the minutes report was corrected or penalized, is not in any record read.

• CVSSD Regular Meeting Minutes, February 19, 2026 (approved) (Castle Valley Special Service District, 2026-02-19) primary government “Valor will be required to apply to DWQ for a sewer discharge permit.”
• CVSSD Regular Meeting Minutes, March 19, 2026 (approved) (Castle Valley Special Service District, 2026-03-19) primary government “Valar tied into the county sewer system without prior authorization”
• CVSSD Regular Meeting Minutes, May 21, 2026 (approved; scanned, read as page images) (Castle Valley Special Service District, 2026-05-21) primary government
• CVSSD Regular Meeting Minutes, July 16, 2026 (approved; scanned, read as page images) (Castle Valley Special Service District, 2026-07-16) primary government
• CVSSD Board Meeting Minutes, August 20, 2026 (approved) (Castle Valley Special Service District, 2026-08-20) primary government
• Castle Valley Special Service District Board of Directors (public body 1361): notices June 2025 to September 2026 (Utah Public Notice Website) primary government
• CVSSD Notice of Regular Board Meeting, September 17, 2026 (agenda) (Castle Valley Special Service District, 2026-09-17) primary government

Castle Dale City Council minutes of 12 March 2026 record Valar's director of Utah operations, Jess Housekeeper, saying 'The reactor requires minimal water—about 10 acre-feet for industrial use' and that it mainly uses helium cooling. The minutes give no time period for the 10 acre-feet. If it is a yearly figure, 10 acre-feet is about 3.26 million gallons, or roughly 8,900 gallons a day on average. DOE's categorical exclusion for Ward 250, signed six weeks later (22 April 2026), describes water use only as 'less than 1000 gallons/day for domestic use', says no process water is discharged and that sanitary waste goes through the lab's infrastructure, and does not mention any industrial water use. The utility district's minutes say Valar asked for restroom sewer service only, with no process water (loc-015). The figures may describe different things (the reactor alone versus the whole site with its fuel laboratory, consumption versus a water-right allotment, or a yearly versus a one-time amount); no record read reconciles them. Separately, Valar says it holds the shares for its current needs and seeks up to 1,000 more for future development (loc-017).

• Castle Dale City Council Meeting Minutes, March 12, 2026 (approved; scanned, read as page images) (Castle Dale City, 2026-03-12) primary government “The reactor requires minimal water—about 10 acre-feet for industrial use”
• 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 “Water consumption is less than 1000 gallons/day for domestic use.”
• CVSSD Regular Meeting Minutes, March 19, 2026 (approved) (Castle Valley Special Service District, 2026-03-19) primary government “standard sanitary sewer service only for restrooms, with no process water proposed”

DOE announced categorical exclusion B5.26 on 2 February 2026 (91 FR 4550), already included in its procedures (the notice says it is 'effective on February 2, 2026'), and invited comments until 4 March 2026 (csite-020). On 4 March the Nuclear Information and Resource Service filed comments for itself and 25 groups, including HEAL Utah and Uranium Watch of Moab, arguing among other things that the exclusion expressly allows multiple reactors in one facility, that stacking exclusions and judging segmentation or 'extraordinary circumstances' would be shielded from public input, and that public involvement improves reviews. Uranium Watch wrote that coverage of the Valar reactor gave no information on worker and resident protection, emergency response planning, spent-fuel storage, who to contact, oversight or the need for NRC licensing if power is sold to non-federal entities. DOE's categorical-exclusion page, read 29 September 2026, still says DOE 'will consider' comments received by 4 March and links no response. DOE applied B5.26 to Ward 250 on 22 April 2026; that determination says no extraordinary circumstance applies, a category it defines to include scientific controversy about environmental effects. The exclusion's text, as printed in the determination, says 'a project may include multiple reactors within a nuclear facility'.

• Comments regarding DOE categorical exclusion for advanced nuclear reactors, Docket DOE-HQ-2025-0405 (NIRS and 25 co-signing groups incl. HEAL Utah and Uranium Watch) (Nuclear Information and Resource Service et al., 2026-03-04) analysis “the exclusion expressly would allow DOE to apply it to multiple reactors”
• Categorical Exclusion for Advanced Nuclear Reactors (DOE NEPA page) (U.S. Department of Energy, Office of NEPA Policy and Compliance) primary government “DOE will consider comments on this categorical exclusion received on or before March 4, 2026.”
• 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
• 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 “a project may include multiple reactors within a nuclear facility”
• Categorical Exclusion for Advanced Nuclear Reactors, 91 FR 4550 (FR Doc. 2026-02071), DOE's posted copy (U.S. Department of Energy (Federal Register notice), 2026-02-02) primary government “For the purposes of this category, a project may include multiple reactors”

E&E News (Francisco 'A.J.' Camacho, 25 February 2026) reports that in a 10 November letter to the NRC (2025, by context), which E&E obtained, Utah Department of Environmental Quality executive director Tim Davis asked the Commission to consider expanding the state's authority under the Atomic Energy Act to oversee uranium enrichment, microreactor licensing, fuel storage and reprocessing. It reports that the letter also asked the NRC to 'consider establishing a pilot project to streamline state environmental permitting'. The article describes the joint lawsuit with Texas, Last Energy and others as another route by which Utah seeks state power over small reactors. The article text served (185 words) mentions no NRC response. The letter itself was not found or read.

• Utah requests NRC authority to regulate nuclear power (E&E News by POLITICO, 2026-02-25) news “consider expanding the state’s authority under the Atomic Energy Act”

Minutes of the Emery County Fire Protection Special Service District: 17 November 2025, item 'Getting 3rd Party to Review Plans for Nuclear Power Plant': the district was asked to approve fire plans for the 'Nuclear test plant' at Orangeville; the chair had called the State Fire Marshal's office, which 'didn't want to touch it'; the board tabled it to get information on the fire code and whether there was adequate water flow (GPM) for the building classification. 15 December 2025: the chair said he would sign the fire protection plans as soon as the paperwork arrived (safe-016). 17 February 2026 (the minutes' header reads 'Tuesday, February 17th, 2025', misprinting the year), item 'Valar Atomics': fire chiefs were asked to review building plans; 'State agencies declined to perform plan review and recommended third-party review'; responsibility may fall to the district or a local fire authority because there is no county fire inspector; the review concerns building fire-code compliance, not reactor design. 16 March 2026: 'The issue has been addressed with chiefs and is not currently a concern.' The April, May and June 2026 minutes do not return to it. Separately, Emery County's commission voted Valar's building permit itself on 2 September 2025 because its building department had not issued one (gov-021), and Orangeville's fire chief reported on 12 March 2026 that he had gone through Valar's safety protocols (loc-008). No record read says whether a third-party plan review was done, who did it, or what it found.

• Emery County Fire Protection SSD meeting minutes, November 17, 2025 (Emery County Fire Protection Special Service District, 2025-11-17) primary government “Ben called the State Fire Marshall and they didn’t want to touch it.”
• Emery County Fire Protection SSD meeting minutes, December 15, 2025 (Emery County Fire Protection Special Service District, 2025-12-15) primary government
• Emery County Fire Protection SSD meeting minutes, February 17, 2026 (header misprints the year as 2025) (Emery County Fire Protection Special Service District, 2026-02-17) primary government “State agencies declined to perform plan review and recommended third-party review.”
• Emery County Fire Protection SSD meeting minutes, March 16, 2026 (Emery County Fire Protection Special Service District, 2026-03-16) primary government “The issue has been addressed with chiefs and is not currently a concern.”
• Emery County Fire Protection SSD notices, April to September 2026 (April, May and June minutes read, no Valar item; July has no minutes posted, August cancelled, September audio only) (Utah Public Notice Website) primary government

Reactor: built and heat-tested in Hawthorne, California (plan-008); loaded unfueled onto a C-17 at March Air Reserve Base on 15 February 2026 and flown to Hill Air Force Base, Utah, with the Energy Secretary and a Defense under secretary aboard (World Nuclear News, 18 February); from Hill it went 'by road' to Emery County (Valar's Castle Country page). No route, date or oversize-load permit for the road leg was found. Core test: the NOVA core was assembled and run at the National Criticality Experiments Research Center, Nevada, in November 2025 (orig-008). Fuel: World Nuclear News, citing Reuters, reported the Energy Secretary saying the fuel would move separately from the Nevada National Security Site; DOE's May 2026 packaging approval covers up to 24 single-block packages from NCERC to the Ward 250 site until 30 June 2027 (plan-014, safe-010, safe-012). Neither DOE document gives shipping dates, route or mode, and no state or county notice of a shipment was found (safe-012). Spent fuel: one core, to go in dry casks to an unnamed DOE-approved facility after operations (safe-023); Utah's July 2026 pact with DOE separately contemplates a campus that could accept out-of-state spent fuel (gov-030). For scale, World Nuclear News called the airlifted unit 'the 5 MW Ward250' able to power about 5,000 homes, without saying whether 5 MW means heat or electricity; Ward 250's safety papers limit it to 100 kW of heat, at most one-fiftieth of that, and it is not built to supply the grid (orig-031, plan-018).

• US microreactor transported by air (World Nuclear News, 2026-02-18) news “Fuel for the reactor will be transported separately from the Nevada National Security site”
• Castle Country (Valar Atomics, 2026-09) primary company “From Hill Air Force Base it came here, by road, to Emery County.”
• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979, Revision 20 (Valar Atomics fuel elements) (U.S. Department of Energy, Packaging Certification Program, 2026-05-20) primary government “This authorization expires on June 30, 2027, or at completion of shipments”
• NEPA Determination DOE-ID-26-005: Valar Ward250 Research Reactor (U.S. Department of Energy, Office of Nuclear Energy, 2026-04-22) primary government “Spent fuel will be transferred to dry storage for transport to a DOE-approved facility.”

In a statement dated 28 January 2026, the Union of Concerned Scientists said DOE had rewritten in 2025, without public notice, the body of safety and security directives it uses to authorize pilot-program reactors, cutting hundreds of pages of detailed requirements for vaguer standards that leave the private builders significant discretion. Edwin Lyman, UCS director of nuclear power safety, said DOE had created 'a legally dubious framework' to designate these reactors as 'test' reactors and bypass the NRC's authority, and called the changes 'a massive experiment in the deregulation of novel, untested nuclear facilities'. UCS added that pilot reactors used for commercial power would still need NRC licenses, but that the NRC had agreed with DOE to restrict the scope of its added reviews of DOE-authorized designs. The underlying NPR report was not read (npr.org blocks AI readers). Valar's NSDA does cite a set of Office of Nuclear Energy orders ('NE O 151.1', 'NE O 420.1', 'NE O 232.1' and others) rather than the department-wide DOE orders, consistent with a separate NE rulebook (safe-012). DOE's own April 2026 article confirms the scale of the rewrite: it says the old guidance ran over 1,500 pages and the new pathway 'eliminates more than 900 pages' (safe-004). That pages were cut is DOE's statement; that the result is vaguer and gives companies more discretion is UCS's assessment. DOE's published position is in safe-004.

• Breaking News Discovery of Rewritten Nuclear Safety, Security Directives by Department of Energy (Union of Concerned Scientists, 2026-01-28) analysis “a massive experiment in the deregulation of novel, untested nuclear facilities”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company
• 5 Fast Facts about DOE Reactor Authorization (U.S. Department of Energy, Office of Nuclear Energy, 2026-04-10) primary government “eliminates more than 900 pages of unnecessary, repetitive, and extraneous language”

The NRC Office of the General Counsel's Litigation Status Report (enclosure to SECY-26-0013, the annual report on court litigation for 2025; status as of 27 January 2026) lists Texas v. NRC among active cases. It records that Texas, Utah and Last Energy filed on 30 December 2024. On 17 March 2025 the NRC, through DOJ, moved to dismiss, arguing the challenge to an NRC rule could only be brought in a court of appeals under the Hobbs Act and was untimely as to Texas and Utah and so in the wrong venue. Plaintiffs instead filed an amended complaint on 7 April 2025 adding Florida, Louisiana, the Arizona Legislature, Deep Fission and Valar, and the NRC renewed its motion to dismiss on 28 April 2025. At the parties' request the case was placed in abeyance with periodic status reports. On 26 January 2026 the parties filed a joint status report asking for 45 more days of abeyance; the report says the court had not yet acted on that request. The entry records no settlement and no ruling on the motions to dismiss. (Updates safe-028.)

• Litigation Status Report (As of January 27, 2026), enclosure to SECY-26-0013 (Annual Report on Court Litigation, Calendar Year 2025) (U.S. Nuclear Regulatory Commission, Office of the General Counsel, 2026-01-27) primary government “the case has been placed in abeyance with the parties instructed to file status reports”

The Office of the Utah Attorney General's 2025 Annual Report (PDF created 22 January 2026) has an item headed 'Challenging federal overreach on small nuclear reactors'. It says Utah joined a multistate lawsuit challenging the NRC's authority to license certain small nuclear reactors, and that the case is currently stayed while the NRC considers rule revisions and possible exemptions. Elsewhere the report says a Government Operations attorney completed the documentation for a research nuclear reactor at the San Rafael Energy Lab; that passage does not name Valar. The report does not mention a settlement. A search of the office's posted news items for 'nuclear' and 'Regulatory Commission' found no release about the case. (Updates safe-028.)

• Office of the Utah Attorney General 2025 Annual Report (Office of the Utah Attorney General, 2026-01-22) primary government “The case is currently stayed while the NRC considers rule revisions and possible exemptions.”

The Breakthrough Institute (Spencer Toohill and Adam Stein, 2 Oct 2025) quotes DOE, in material it links to the pilot program's request for applications on the FedConnect portal (which our tools cannot read, gov-032), saying a pilot reactor is 'considered a DOE reactor, and still covered under Price-Anderson indemnification', while the private developers own the reactors and bear all costs, and that any 'particular requirement' would be set in each company's Other Transaction Agreement. The authors say this leaves developers and investors uncertain about liability in an accident. DOE's 2023 Federal Register notice summarizes the law: subsection 170d of the Atomic Energy Act (the Price-Anderson Act) provides that the Secretary of Energy 'shall enter into agreements of indemnification' with anyone doing work under a DOE contract that carries a risk of public liability and is not covered by the NRC's financial-protection system; the same notice set DOE's indemnification amount at $16,592,154,000 per incident in the United States. Indemnification means the government, not the company, stands behind compensation claims up to that amount. Valar's OTA is not public (gov-003), so whether and how Ward 250 is indemnified is not confirmed from a primary record, and DOE's statement is dated only to 2025. Valar's safety design agreement (NSDA) does not mention Price-Anderson or indemnity. The state takes the opposite position for its own part: Utah's MOU with Valar says the state energy office cannot indemnify Valar (gov-011).

• Making DOE's Nuclear Reactor Pilot Program Work (Spencer Toohill, Adam Stein) (The Breakthrough Institute, 2025-10-02) analysis “considered a DOE reactor, and still covered under Price-Anderson indemnification”
• Making DOE's Nuclear Reactor Pilot Program Work (Spencer Toohill, Adam Stein) (The Breakthrough Institute, 2025-10-02) analysis “developers and investors face real uncertainty about financial liability in the event of an incident”
• Adjustment of Indemnification Amount for Inflation (FR Doc. 2023-25030) (U.S. Department of Energy, Office of the General Counsel (Federal Register, via GPO govinfo), 2023-11-14) primary government “shall enter into agreements of indemnification with any person who may conduct activities”

The NSDA asks DOE to tailor its emergency-management order (NE O 151.1) to 'on-site emergency response only (no off-site planning required)', justified by the worst-case boundary dose and an 800 m distance to the nearest residence (Appendix C.3); it says 'Emergency planning requirements remain limited to on-site response'. It commits to coordination with Emery County Emergency Management, Emery County Fire and local responders: familiarization tours, table-top exercises, hazard information, direct notification links and annual coordination meetings. DOE-STD-1271 lets contractors use equivalent NRC or industry standards 'except where noted'; its Emergency Management entry (NE O 151.1) lacks the explicit 'may choose ... an alternative' sentence most other sections carry, and the Nuclear Innovation Alliance reads the standard as allowing equivalents 'except for Emergency Planning and Cybersecurity'. The standard's general text does still let a contractor request a 'self-generated equivalent' or an exemption for any listed item, decided by DOE's approval authority, so a request like Valar's is not ruled out on its face. Valar's web summary does not list emergency planning among the alternatives DOE approved (safe-005). Local record: the Emery County Fire Protection District's 15 December 2025 minutes record the board discussing the 'nuclear test plant proposed in Orangeville' and its fire protection plans, and the outgoing chair saying he would sign them when the paperwork arrived. No public emergency plan for Ward 250, no record of a table-top exercise, and no public notification arrangement for residents were found as of 29 September 2026. In comments to DOE (March 2026), Uranium Watch said news coverage of the Valar reactor gave no information on emergency response planning, spent fuel or who to contact. The paper's justification (p.54) calls boundary doses under 0.5 rem well below EPA's Protective Action Guides. EPA's lowest guide is 1 rem, a factor of 2, and the paper does not address EPA's 5 rem child-thyroid guide for potassium iodide, although it names iodine-131 as the main dose contributor.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Emergency planning requirements remain limited to on-site response”
• 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 “NE O 151.1 Comprehensive Emergency Management System”
• A Review of Recent DOE Updates to Its Reactor Authorization Process (Nuclear Innovation Alliance) analysis “Except for Emergency Planning and Cybersecurity, the Standard allows the Contractor to use any equivalent”
• Emery County Fire Protection District Meeting Minutes, December 15, 2025 (Emery County Fire Protection Special Service District, 2025-12-15) primary government “The Board discussed the nuclear test plant proposed in Orangeville”
• Comments regarding DOE categorical exclusion for advanced nuclear reactors, Docket DOE-HQ-2025-0405 (NIRS and 25 co-signing groups incl. HEAL Utah and Uranium Watch) (Nuclear Information and Resource Service et al., 2026-03-04) analysis “did not provide any information about the operation of the test reactor”
• 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 “The Contractor may also request a self-generated equivalent requirement”

The Utah San Rafael Energy Lab's FAQ page (a State of Utah site; created 3 Sept 2024, last modified 19 Nov 2025 per its WordPress record; read 29 Sept 2026) answers 'What is the permit and regulatory process for a test reactor?' by saying 'the planned reactor' is a research and test reactor that will go through 'the 10 CFR Part 50 process just like a full sized nuclear power plant would', meeting 'Class 104 standards', that 'The state and county will also negotiate details', and that operators 'will have to maintain a 10 CFR Part 55 operator license', with 'frequent testing by the NRC'. The page was first published on 3 September 2024, before Valar's MOU, and parts of it read as generic text (it describes worst cases involving 'pressurized steam' and a 'containment building', features of water-cooled plants rather than helium-cooled Ward 250), but it is about Valar's project: re-read on 29 September 2026, it names Valar Atomics several times, and its spent-fuel answer says 'Valar Atomics will not produce spent reactor fuel with this reactor' (disc-021, disc-033). It remains the lab's live public answer. Ward 250, the only reactor operating at the lab, is authorized by DOE under 10 CFR 830 with no NRC license planned (safe-001), and its operators are qualified under a research-reactor industry standard, with no NRC operator licences involved (safe-017); the county has no approval role over the reactor (gov-020). The lab's own Valar page, also live, says Ward 250 reached 'full-power fueled criticality' on 18 June (DOE, ANS and UIPA all describe a zero-power test; orig-012), that its fuel will 'remain impossible to melt' (see safe-025), and calls the lab 'the premier independent site for commercial advanced nuclear deployment' and a route 'directly from localized testing to the commercial grid', while DOE describes the pilot reactor itself as research that does 'not demonstrate reactors for commercial suitability', though DOE also calls the program a fast track toward later commercial licensing (gov-007). The state is Valar's host and landlord, not its regulator (ppl-018).

• FAQs | Utah San Rafael Energy Lab (Utah San Rafael Energy Lab (Utah Office of Energy Development), 2025-11-19) primary government “the 10 CFR Part 50 process just like a full sized nuclear power plant would”
• Valar Atomics | Utah San Rafael Energy Lab (Utah San Rafael Energy Lab (Utah Office of Energy Development)) primary government “the premier independent site for commercial advanced nuclear deployment”
• energylab.utah.gov page record for 'faq' (created 2024-09-03, modified 2025-11-19) (Utah San Rafael Energy Lab (WordPress API), 2025-11-19) primary government
• Second round of Launch Pad selections includes eight newcomers (American Nuclear Society, Nuclear Newswire, 2026-08-25) news “achieved zero-power fueled criticality with its 100-kWt Ward 250”

Valar's NOVA release (18 Nov 2025) quotes Sonat Sen as 'Valar Atomics' Lead Core Designer', saying NOVA gives real-world data on TRISO fuel performance in Valar's core and helps 'validate our proprietary software stack' used to design its reactors. An R. Sonat Sen of Idaho National Laboratory's Reactor Physics and Analysis group wrote INL report INL/EXT-20-60236 (Sept 2020), a benchmark for pebble-bed reactor fuel depletion; name and field match, but no source read states that the two are the same person. Valar's public safety documents name no individual designers. Valar's Quality Assurance Program Description (p.14) allows 'more modern and efficient' design codes to be used before their complete validation, relying on safety margins and Ward 250's data (safe-018), and the NSDA (p.38) repeats it as provisional use of modern HTGR codes.

• Los Alamos National Laboratory and Valar Atomics Announce Project NOVA Criticality Milestone in Nevada (Valar Atomics, 2025-11-18) primary company “validate our proprietary software stack, which we use to design our power reactors”
• Benchmark for Fuel Shuffling and Depletion for Pebble-Bed Reactors, INL/EXT-20-60236 Rev. 1 (R. Sonat Sen) (Idaho National Laboratory (via DOE OSTI), 2020-09) primary government
• Ward250 San Rafael Facility Quality Assurance Program Description, No. 100474, Rev 02 (status: Approved) (Valar Atomics (Public Documents), 2025-10) primary company “may be used prior to their complete validation”

Valar's own NOVA release (18 Nov 2025) says the experiment ran at NCERC, operated by Los Alamos inside the Nevada National Security Site, 'under the NNSA Nevada Field Office Oversight', supporting (not under) the Reactor Pilot Program, and quotes DOE Deputy Assistant Secretary Rian Bahran praising it. A release posted the same day by the Breakthrough Institute, a pro-nuclear policy group, went further: its headline says Valar achieved 'First Criticality in DOE Pilot Program' and its text calls Valar 'the first company in the U.S. to reach criticality' under the program, while also noting the Ward 250 project 'is separate'. DOE's own record says otherwise: its 4 June 2026 release calls Antares's Mark-0 at Idaho National Laboratory the first of the pilot projects to reach criticality, and its 18 June release calls Ward 250 the second (orig-010). The 'first in the pilot program' wording is the think tank's, not Valar's or DOE's; Valar's own 'first' claims are tested in orig-047 and orig-066.

• Los Alamos National Laboratory and Valar Atomics Announce Project NOVA Criticality Milestone in Nevada (Valar Atomics, 2025-11-18) primary company “The experiment was conducted under the NNSA Nevada Field Office Oversight”
• RELEASE: Valar Atomics Achieves First Criticality in DOE Pilot Program (The Breakthrough Institute, 2025-11-17) analysis “This milestone makes Valar the first company in the U.S. to reach criticality”
• Department of Energy Celebrates First Advanced Reactor Criticality (U.S. Department of Energy, 2026-06-04) primary government “we celebrate the first of the pilot projects to reach criticality”

Contrary Research's profile of Valar (marked 'Updated November 11, 2025'; the page discloses that Contrary is an investor in Valar, orig-021) compares Valar with Oklo. It says that, like other companies using HALEU fuels, Oklo's largest risk is fuel availability, 'something Valar’s LEU-TRISO dodges'. That description matches the 4.95% LEU figure in Valar's safety agreement, dated October 2025 (dir-009). It does not match the NOVA release a week later ('HALEU TRISO', orig-040), LANL's account that NOVA used 19.9% CNPS fuel (dir-026, dir-027), or DOE's May 2026 shipping review (HALEU, up to 19.9 wt.%, safe-010). This is an investor's description, not a statement by Valar. (Updates disc-001.)

• Report: Valar Atomics Business Breakdown & Founding Story (Contrary Research, 2025-11-11) analysis “something Valar’s LEU-TRISO dodges”

Valar's Ward250 Nuclear Safety Design Agreement (Rev. 02, October 2025, marked 'Draft') maps its safety analysis onto the chapters of NUREG-1537, the NRC's guide for research-reactor applications. In that table, 'Chapter 15: Financial Qualifications' is marked 'Excluded' and 'Not required for application' for both the preliminary and final safety analyses, and 'Chapter 17: Decommissioning' is excluded from the preliminary analysis, with an 'approach included in DSA', a document that is not public (safe-007). DOE's request for applications, as summarized by Hogan Lovells, told applicants they bear all costs through decommissioning and spent-fuel storage and asked whether each applicant's funding was 'sufficient to support all phases of reactor testing, from design to decommissioning' (gov-032). DOE's answer on Valar is not public. When the state's Energy Research Board approved the project on 13 Aug 2025, its minutes record only that members discussed 'the project's private funding', returning the site to 'Greenfield' and 'financial assurance for liability' before voting 7-0 (gov-013); no bond, insurance certificate or assurance document for Ward 250 has been found. By contrast, the Carbon County lease requires a reclamation and performance bond before construction (csite-011). Valar has announced large raises since (fund-008), but no public record shows money set aside for decommissioning Ward 250 or storing its spent fuel.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev. 02 (status: Draft), Table 2 and Appendix B (Valar Atomics (Public Documents), 2025-10) primary company “Not required for application”
• DOE's Office of Nuclear Energy issues Request for Application for Reactor Pilot Program (Daniel Stenger, Stewart Forbes, Valerie Marshall) (Hogan Lovells, 2025-07-01) analysis “funding sufficient to support all phases of reactor testing, from design to decommissioning”
• Board Meeting Minutes, Utah Energy Research Board, August 13th, 2025 (item 5, Project Valar) (Utah Energy Research Board (Utah Public Notice Website), 2025-08-13) primary government “financial assurance for liability”

Valar's Nuclear Safety Design Agreement for Ward 250 (document 100403 rev 02, October 2025, marked 'Draft' and 'issued for Public Release'; the company says DOE approved it) lists key design parameters: 100 kWth continuous as the license limit, up to 250 kWth for limited tests; TRISO-coated UCO fuel qualified on the AGR program basis; helium coolant at 3.0 MPa; 250 C inlet and 650 C nominal core outlet; a 1.8 m by 1.5 m core of 76 fuel elements holding about 250 kg of heavy metal; 4.95% U-235 enrichment; graphite reflector. It sets a 12-month operating period and an 18-month lifecycle ending in decommissioning and return of the site to unrestricted use, with DOE authorization only and no planned NRC licensing. At a July 2025 Emery County town hall the name was explained as a reference to the nation's 250th birthday on July 4, 2026 (orig-045); the 250 kWth test ceiling is a separate figure.

• Ward250 Nuclear Safety Design Agreement (Document 100403, Rev. 02) (Valar Atomics, 2025-10) primary filing “a ≤250 kWth High Temperature Gas-cooled Reactor (HTGR) research facility”
• Ward250 Nuclear Safety Design Agreement (Valar Atomics, 2025-10-13) primary company “The Department of Energy has approved the Nuclear Safety Design Agreement (NSDA)”

Valar's NSDA (October 2025) says Ward 250 directly uses hardware that has undergone full-scale testing, that design work focuses on nuclear-specific modifications to the proven WardZero configuration, and it credits Ward Zero testing for key safety points: natural circulation during a loss of coolant flow, and the capacity of the Reactor Cavity Cooling System. It also asks DOE to accept the final safety analysis at 90% design completion because the WardZero program has completed design, installation and testing of major safety-significant systems. Valar's QA Program Description, which Valar's October 13, 2025 post says DOE approved, has a section on using existing WardZero hardware: Ward Zero components may go into Ward 250 if they stay traceable and are evaluated, and Ward Zero operating data may count as design verification by comparison to 'similar proven systems'. Ward Zero was completed in February 2025 (orig-005), before that QA program was approved. Valar's June 2026 draft says the reactor underwent non-nuclear testing at its Hawthorne headquarters above 750 C and 6 MPa before shipment (orig-035). No Ward Zero test report, data set or DOE review of it has been published, and the page titled 'Ward Zero Whitepaper' holds no Ward Zero data (orig-058). Whether DOE examined the Ward Zero data would be shown by the non-public PDSA and DSA (safe-007).

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary filing “natural circulation capabilities demonstrated during WardZero testing”
• Ward250 San Rafael Facility Quality Assurance Program Description, No. 100474, Rev 02 (Valar Atomics, 2025-10) primary filing “Ward250 incorporates proven hardware designs and components from the WardZero facility.”
• Valar Atomics Quality Assurance Program Description (library post; not listed in Valar's library) (Valar Atomics, 2025-10-13) primary company “defines quality controls for integrating existing WardZero hardware components into the Ward250 design.”
• Ward 250 By the Numbers (unlisted draft page) (Valar Atomics, 2026-06-28) primary company “underwent extremely rigorous non-nuclear testing at our headquarters in Hawthorne, CA”

Valar's Quality Assurance Program Description (October 2025, status 'Approved'; the only published Valar document read that covers the fuel plant) treats the Ward250 reactor and the 'Valarin Fuel Fabrication Facility' as one 'VASR Facility' and scales its quality rules to the facility's 'limited operational duration of approximately 12 months' and 'low hazard category', with full implementation required before fuel receipt. It says the fuel lab will make TRISO particles in graphite compacts using German HOBEG methods and is designed to stay below DOE Hazard Category 3 (orig-038, safe-031). Set beside this: on 11 June 2026 Valar's representative told Orangeville the second building will make Valar 'the largest manufacturer of this fuel in the United States' once completed; July 2026 job posts describe 'pilot scale uranium processing equipment' and a process that 'transitions into production' (loc-019); DOE's program page still lists Valar's fuel-line selection (30 September 2025) as conditional, with no later status; POWER (25 August 2026), listing Valar among 13 projects added to DOE's Nuclear Energy Launch Pad, says Valar is developing a 'co-located Valarin facility' for TRISO particles and compacts, and notes that project scopes were not disclosed. No NSDA, safety analysis, DOE authorization or state license for the fuel plant has been published (safe-031), and no public document says how much uranium it may hold or produce. A quality program sized for a 12-month demonstration is a different thing from a production plant; the record does not show which rules would apply to production. The quality program gives no uranium inventory, enrichment or threshold for its <HC3 claim, and the safety agreement never mentions the fuel facility (it categorizes only the reactor, as Hazard Category 2), so the claim cannot be checked from Valar's public papers.

• Ward250 San Rafael Facility Quality Assurance Program Description, No. 100474, Rev 02 (October 2025) (Valar Atomics, 2025-10) primary company “limited operational duration of approximately 12 months”
• Orangeville City Council Regular Meeting Minutes, June 11, 2026 (Orangeville City, via Utah Public Notice Website, 2026-06-11) primary government “Once completed they will be the largest manufacturer of this fuel”
• TRISO Chemical Plant Process Engineer (Orangeville, Utah) (Valar Atomics (via Greenhouse), 2026-07-16) primary company
• Energy Department Fuel Line Pilot Program (U.S. Department of Energy, Office of Nuclear Energy, 2026-02-12) primary government
• NRIC Adds 13 Projects to Nuclear Energy Launch Pad (POWER Magazine (Sonal C. Patel), 2026-08-25) news “co-located Valarin facility to fabricate TRISO fuel particles and graphite compacts”
• Valar Atomics job board (public Greenhouse feed, 92 postings): Chemical Vapor Deposition Engineer (TRISO), Orangeville (Valar Atomics (via Greenhouse), 2026-07-31) primary company “as the process transitions into production”

Valar's Nuclear Safety Design Agreement (NSDA, document 100403 rev 02, October 2025) says Ward 250 is a contractor-owned, contractor-operated facility 'under DOE jurisdiction', authorized under the federal nuclear safety rule 10 CFR 830, with DOE-STD-1271-2025 as its primary authorization standard, and that no transition to NRC licensing is planned or intended. DOE's NEPA determination of 22 April 2026 says the same: the facility 'will operate under U.S. Department of Energy (DOE) authorization'. The legal basis is Executive Order 14301 (23 May 2025): section 3 finds that advanced reactors under enough DOE control that are not built 'to produce commercial electric power' fall within DOE's jurisdiction rather than the NRC's, and section 5 orders a pilot program outside the national laboratories under 42 U.S.C. 2140, approving at least three reactors 'with the goal of achieving criticality' in each by 4 July 2026. DOE-STD-1271 itself exempts anything the NRC regulates. The text of DOE-STD-1271 contains no public-hearing or public-comment step (searched for 'hearing', 'public comment', 'comment period'); its foreword only invites emailed suggestions for improving the standard itself.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Ward250 will operate exclusively under DOE authorization for its entire lifecycle.”
• 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 “The facility will operate under U.S. Department of Energy (DOE) authorization.”
• Executive Order 14301, Reforming Nuclear Reactor Testing at the Department of Energy, 90 FR 22591 (Executive Office of the President (Federal Register), 2025-05-29) primary government “and not to produce commercial electric power”
• 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 “Activities and facilities subject to regulation by the Nuclear Regulatory Commission (NRC) are exempt”

In the NSDA's Maximum Hypothetical Accident analysis (pages 34-36), the radioactive inventory is based on 'OpenMC neutronic analysis with 3 MWd total burnup' and 'Conservative 30 EFPD operation assumed for inventory buildup' (30 effective full-power days at 100 kW is 3 megawatt-days). Earlier (page 10) the NSDA says the analysis assumes operation at maximum licensed power long enough to reach equilibrium inventories. Its operating limits (page 25) set 'Fuel burnup limit: 30 megawatt-days', and its objectives call for 12 months of operation with availability above 80% and steady operation up to 250 kWth (page 8). The limit is ten times the burnup the accident inventory was built on. Valar's July 2025 county presentation (orig-045) and its June 2026 draft post (safe-008) both describe 30 effective full-power days, which matches the accident analysis rather than the 30 MWd limit. The lifecycle also differs: the NSDA gives about 18 months 'from authorization through decommissioning', DOE's categorical exclusion a 24-month program (12 months of operation, 6 of cooldown, 6 of decommissioning). The approved DSA, which would fix the inventory and limits, is not public. Our check using standard half-lives: going from 3 to 30 MWd at the same power would raise iodine-131 by about 8% and the iodine and noble-gas dose by about 4%; cesium-137 and strontium-90 would grow about tenfold but stay about 4% of the iodine-131 activity. The NSDA's 18 months is also shorter than its own schedule: Table 7's dates plus 12 months of operation already exceed 18 months before any decommissioning, unless counted from startup.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Conservative 30 EFPD operation assumed for inventory buildup”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Fuel burnup limit: 30 megawatt-days”
• 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 “approximately 12 months of reactor operation followed by 6 months of in-vessel cooldown”
• Ward 250 By the Numbers (unlisted company page with placeholders, signed Isaiah Taylor) (Valar Atomics (Isaiah Taylor), 2026-06-28) primary company

The NSDA's 'Maximum Hypothetical Accident' assumes a large break in the reactor vessel, complete loss of helium coolant pressure, TRISO failures at twice unspecified AGR-1/2 test-program values, no credit for the building, filters or cooling systems, a ground-level release and stable air with a 1 m/s wind. Its results are stated two ways. Pages 11, 14 and 54 say site-boundary doses are below 0.5 rem (500 millirem); page 11 puts the nearest residence below 0.1 rem. Pages 32 and 37-38 say the public dose at the 400 m site boundary is below 1 mSv (100 millirem), a co-located worker at 100 m below 5 rem (the annual worker limit), and the control room below 0.5 rem; I-131 and noble gases dominate. The two boundary figures differ by a factor of five; both are stated as upper bounds, so they do not strictly contradict, but the looser 0.5 rem is the one Appendix C.3 relies on to justify on-site-only emergency planning (safe-016). Both are far below the 25 rem evaluation guideline the NSDA uses for 'Safety Class' equipment; on that basis the NSDA designates no Safety Class equipment and a 'Hazard Category 2' facility 'based on material at risk rather than consequence'. For scale, DOE's categorical exclusion puts natural background radiation in central Utah at about 100-120 millirem a year. The approved DSA's final figures are not public. Our check: the 400 m dispersion factor it uses (2.5e-4 s/m3, p.36) is 3.1 to 12.3 times lower than standard rural methods give for its own stated weather; rescaled, the 0.1 rem bound would be about 0.31 to 1.23 rem, still far below 25 rem. Hazard Category 2 is what DOE's standard assigns any reactor under 20 MW.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “site boundary doses below 0.5 rem Total Effective Dose Equivalent”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Public dose at site boundary (400m): <1 mSv (100 mrem)”
• 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 “Natural background radiation in central Utah is approximately 100-120 mrem/year.”

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

Valar's Quality Assurance Program Description (document 100474 rev 02, October 2025, status 'Approved') applies ANSI/ANS-15.8-1995, the research-reactor QA standard, instead of the nuclear industry's NQA-1, which Valar's summary says DOE approved (safe-005). It covers both Ward 250 and the 'Valarin' fuel fabrication facility, together the 'VASR Facility'. It allows 'more modern and efficient computational codes for HTGR applications' to be used 'prior to their complete validation', relying on safety margins, with Ward 250's data to validate them. It permits design verification by people 'from the same organization' and by comparison with the non-nuclear WardZero prototype, and requires an independent QA assessment before fuel loading. The published 'Approved' document contains many unresolved editing marks: merged words ('Comprehensive Ddesign', 'VTalar Atomics', 'Valar AtomicsValarin'), sentences printed twice in old and new wording, and 'Figure 11: VSAR Facility' for 'Figure 1: VASR'. The document says it becomes effective on approval by Valar's own facility director and president, so 'Approved' marks internal approval. The NSDA separately says fuel particles are manufactured under an NQA-1 program. Whether the pre-fuel-load independent QA assessment took place, and by whom, is not public. The safety agreement's case for ANS-15.8 says the standard covers all 18 criteria of 10 CFR 830.122 (pp.49, 54); that rule lists 10 criteria, and 18 is the count in the NRC's Appendix B that NQA-1 follows (exp-025).

• Ward250 San Rafael Facility Quality Assurance Program Description, No. 100474, Rev 02 (status: Approved) (Valar Atomics, 2025-10) primary company “may be used prior to their complete validation”
• Ward250 San Rafael Facility Quality Assurance Program Description, No. 100474, Rev 02 (status: Approved) (Valar Atomics, 2025-10) primary company “Comprehensive Ddesign control processes”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Manufacturing under NQA-1 quality program”
• Ward250 San Rafael Facility Quality Assurance Program Description, No. 100474, Rev 02 (status: Approved) (Valar Atomics, 2025-10) primary company “becomes effective upon approval by the VASR Facility Director and Valar Atomics President”

The NSDA makes Valar the Design Authority for Ward 250, with the COO/Chief Nuclear Officer holding 'ultimate contractor responsibility for design safety decisions' (Valar's mission page lists Mark Mitchell as Chief Nuclear Officer, orig-003). Changes are screened by Valar's own Unreviewed Safety Question (USQ) process under 10 CFR 830.203; DOE's prior approval is needed only for changes to safety-basis assumptions, TSR limits, safety equipment functions or approved codes. Otherwise 'Design decisions within the approved authorization basis are made by Valar Atomics' Design Authority'. DOE-STD-1271 sets the same division: the OTA contractor is the Design Authority, final design adequacy is approved through the DSA, and after startup testing the contractor operates without asking permission for approved activities. The NSDA planned a Joint Test Group, required by the standard, as a TSR for post-startup testing; Valar's draft post dated 28 June 2026 says the company had 'graduated' from the Joint Test Group; the post says it has been 14 days since first criticality and that Valar made power on July XX, so it reads as drafted about 2 July under an earlier 28 June date field; the count fits DOE's 18 June date (disc-040). DOE's record of ending Joint Test Group oversight is not public.

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “Design decisions within the approved authorization basis are made by Valar Atomics' Design Authority”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “will be implemented as a TSR for post-startup testing activities”
• Ward 250 By the Numbers (unlisted company page with placeholders, signed Isaiah Taylor) (Valar Atomics (Isaiah Taylor), 2026-06-28) primary company “we have now graduated from the Joint Test Group”
• 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
• Ward 250 By the Numbers (unlisted company page with placeholders, signed Isaiah Taylor) (Valar Atomics (Isaiah Taylor), 2026-06-28) primary company “it’s been 14 days since we first went critical”

Valar's NSDA says that while Ward 250 is under DOE authority, Valar will coordinate with Utah DEQ, the Division of Waste Management and Radiation Control, Emery County Emergency Management, Emery County Fire and local responders; that state representatives 'may observe but not direct DOE regulatory activities'; and that 'The State of Utah maintains agreements with DOE regarding notification and coordination for nuclear facilities within the state', including environmental data sharing and emergency coordination. No such Utah-DOE agreement was found in state or DOE sources searched on 29 September 2026. The state's own pieces: the Office of Energy Development owns the lab and is Valar's landlord (mine-035); it advertised for a lab-wide Safety Manager in September 2026 (dir-006); Utah's 2026 H.B. 78 created a Nuclear Energy Regulatory Office and conditions spent-fuel storage on a DWMRC permit (csite-023). In its 2025 lawsuit post, Valar argued small test reactors could be regulated by states, some of which were creating regulatory bodies (safe-028).

• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “State representatives may observe but not direct DOE regulatory activities”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company “The State of Utah maintains agreements with DOE regarding notification and coordination”
• Valar Atomics is Suing the NRC (The Nuclear Necessity and our decision to sue the NRC) (Valar Atomics (Isaiah Taylor), 2025-04-07) primary company

The Nuclear Innovation Alliance's review of the DOE authorization changes says a 2019 DOE-NRC memorandum of understanding, and its Addendum No. 9 signed in October 2025, let NRC employees be detailed to DOE to help with safety reviews such as the DSA, with DOE training them on DOE requirements; that unresolved technical concerns raised by those detailed reviewers are resolved under DOE Idaho Operations Office procedure 01.OP.13 rather than the NRC's differing-professional-opinion process; and that NRC observers who are not detailed remain NRC staff learning for future licensing. It also notes both agencies are operating under constrained resources. Whether any NRC staff took part in the Ward 250 review is not stated in any record read. The addendum itself is on nrc.gov, which refused our reader; this fact rests on NIA's account.

• A Review of Recent DOE Updates to Its Reactor Authorization Process (Nuclear Innovation Alliance) analysis “will be resolved under the DOE's Idaho Management System Office Procedure 01.OP.13”

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”

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.”

ETV News (10 October 2025) quoted Jaron Wallace, identified as director of the Utah San Rafael Energy Lab (a state office), saying any nuclear company must show no dose at the site boundary in an accident, that in the worst case the public 'will never see a dose of radiation above background', and that Valar must prove radiation cannot pass the fence line of its 11 acres. Valar's own NSDA, dated the same month, does not claim zero: its worst-case analysis gives up to 0.1 or 0.5 rem at a 400 m boundary and up to 5 rem at 100 m (safe-013), and its standard is the 25 rem evaluation guideline, and it also cites a 1 rem figure labelled 'USNRC NPUF', which matches the NRC's test for sizing an emergency planning zone (1 rem over 96 hours, 10 CFR 50.33(g)(2)); neither is zero. As reported, the director's description (no dose at the boundary) differs from both the figures the NSDA measures against and the company's own analysis.

• What's actually happening at the Utah San Rafael Energy Lab? (ETV News, 2025-10-10) news “Any nuclear company is required to show no dose at the site boundary”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics, 2025-10) primary company

DOE's September 30, 2025 release is the primary record. In the second round of conditional selections for its Fuel Line Pilot Program, DOE selected Oklo, Terrestrial Energy, TRISO-X and Valar Atomics Inc (Hawthorne, CA), Valar's project being to support TRISO fuel fabrication for the Ward 250 deployment and possibly other high-temperature gas reactors. Each company pays all costs of building, running and decommissioning its fuel facility and must arrange its own nuclear feedstock; companies may apply for HALEU through DOE's HALEU Availability Program. DOE had earlier selected Standard Nuclear to build TRISO fuel facilities. World Nuclear News and Mother Jones ('one of four companies', 'last September') report the same selection, and Valar's NOVA release and Series B post list it. Set beside the record: DOE's May 2026 shipping review authorized HALEU TRISO fuel compacts to be shipped to Ward 250 from Los Alamos's criticality center in Nevada, where the NOVA test ran (safe-010); the NOVA release says Valar 'provided' the TRISO fuel, but no record read says who manufactured it; Valar's QA plan describes a 'Valarin' fuel lab at the Utah site (orig-038), for which no DOE authorization is public (safe-031); and the Series B post says Valar will make its own fuel beside its reactors (orig-070).

• Energy Department Selects Four Companies for Advanced Nuclear Fuel Line Pilot Projects (U.S. Department of Energy, 2025-09-30) primary government “To support TRISO fuel fabrication for the Ward250 reactor deployment”
• Los Alamos National Laboratory and Valar Atomics Announce Project NOVA Criticality Milestone in Nevada (Valar Atomics / LANL, 2025-11-18) primary company “Valar Atomics provided the reactor core, TRISO fuel, and system configuration.”
• US microreactor transported by air (World Nuclear News, 2026-02-18) news “a pilot programme to build advanced nuclear fuel lines”
• Mother Jones (Kiera Butler), 26 Feb 2026 (Mother Jones, 2026-02-26) news “the DOE named Valar as one of four companies”
• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 for the Model 9979 Package, Docket 26-35-9979 (U.S. Department of Energy, Packaging Certification Program, 2026-05-20) primary government “limited shipments of high-assay low-enriched uranium (HALEU) tri-structural isotropic (TRISO) fuel”

DOE-STD-1271-2025 (August 2025), written to carry out EO 14301, sets the path Ward 250 followed: a contract (for Valar, an Other Transaction Agreement), then a Nuclear Safety Design Agreement, a Preliminary Documented Safety Analysis at about 50% design, a final DSA with Technical Safety Requirements, a DOE readiness review, and startup testing under a Joint Test Group that includes a DOE representative. DOE's review standard is 45 days per document, and DOE 'will limit its comments' to issues affecting the safety of the public or workers. The contractor under an OTA is the Design Authority; DOE staff attend the company's design reviews 'as observers only', reserving comments for a clear deviation from a requirement, and DOE may use non-DOE experts. The Secretary of Energy is the Startup Approval Authority for new reactors (delegable), and DOE's Office of Nuclear Energy is the Safety Basis Approval Authority, which approves a Safety Evaluation Report. Fuel above Hazard Category 3 quantities may not be loaded until the readiness review and startup approval are complete. After startup testing, the contractor may operate 'without needing to request DOE permission for approved activities', subject to ongoing DOE oversight under the contract. The standard lets the contractor substitute NRC or industry standards, or its own 'self-generated' equivalents approved by DOE, for most listed DOE orders.

• 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 “The Secretary of Energy will be the Startup Approval Authority (SAA) for new reactors.”
• 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 “The DOE Review Team will participate as observers only”
• A Review of Recent DOE Updates to Its Reactor Authorization Process (Nuclear Innovation Alliance) analysis

The Utah Investigative Journalism Project's 'Who is Valar Atomics?' (Eric Peterson, 8 July 2025, with Utah News Dispatch) is the only investigative piece on Valar by a Utah newsroom found; its report of engineers' CT-scan calculations is cited elsewhere here only as reported, with the engineers' inputs unknown, until their own posts are archived (the claim itself: safe-026; a worked check: pf-007). It also reported: that over a dozen advanced reactor companies were listed on the NRC's website, 'but not Valar', while co-plaintiff Deep Fission was; that Valar's top engineers came from Ultra Safe Nuclear, which went bankrupt and sold its intellectual property to Nano Nuclear (ppl-015), with a University of Utah law professor noting possible litigation over ideas staff learned at earlier employers; that TRISO fuel is very robust but very expensive, with engineer Nick Touran saying 'just the fuel cost alone prevents that from even making sense at all' for factory-built reactors, and that maintaining a thousand-reactor farm would kill the concept; Touran's warning, 'In nuclear, an incident anywhere is an incident everywhere'; Georgia Tech nuclear engineer Anna Erickson: 'I don't know how you can claim your design is so safe without doing engineering'; and the state energy office director: 'Just because we have that MOU, there's still not a commitment at the moment'. Valar and its head of operations did not respond to the reporter's requests. Other Utah coverage found is news or opinion, not investigation: Salt Lake Tribune editorials (May and November 2025), a Utah News Dispatch opinion column (March 2026) drawing on Mother Jones, and the Tribune's republication of ProPublica (dir-011).

• Who is Valar Atomics? (Eric Peterson, Utah Investigative Journalism Project with Utah News Dispatch) (Utah Investigative Journalism Project, 2025-07-08) news “In nuclear, an incident anywhere is an incident everywhere”
• Who is Valar Atomics? (same article: Anna Erickson) (Utah Investigative Journalism Project, 2025-07-08) news “I don't know how you can claim your design is so safe without doing engineering”
• Tribune editorial: Spencer Cox's nuclear dream for Utah deserves careful scrutiny (headline only; paywalled) (The Salt Lake Tribune, 2025-05-30) analysis

Assessments of Valar's leadership, as published: Mother Jones (Feb 2026) quotes former NRC chair Allison Macfarlane calling Taylor and other nuclear start-up founders 'nuke bros' who 'don't know what they don't know', and writes that while there are now 'some seasoned nuclear engineers' in leadership, some top executives have as little nuclear experience as Taylor. The Utah Investigative Journalism Project (July 2025) reports Valar's top nuclear engineers and scientists came from Ultra Safe Nuclear, which went bankrupt and sold its intellectual property to Nano Nuclear (ppl-015), and quotes Georgia Tech professor Anna Erickson: 'I don't know how you can claim your design is so safe without doing engineering.' On the other side, Taylor told Deseret News Valar has hired many people 'who have Ph.D.s' and experience in nuclear engineering companies, and nuclear engineer Nick Touran, a critic of the spent-fuel claim (safe-026), told Deseret News the company is 'well plugged in' and has shown it can get things done. The record read supports parts of both: no nuclear-industry background appears for the founder or the operations head (ppl-001, ppl-004), while the Chief Nuclear Officer's announced background is in helium-cooled (HTGR) programs (ppl-003); two other named engineers share names with authors of pebble-bed research, a link no source read confirms (ppl-007, ppl-008).

• Mother Jones (Kiera Butler), 26 Feb 2026 (May+June 2026 issue) (Mother Jones, 2026-02-26) news “don’t know what they don’t know”
• Who is Valar Atomics? (Eric Peterson) (The Utah Investigative Journalism Project, 2025-07-08) news “I don’t know how you can claim your design is so safe without doing engineering.”
• At just 27 years old, this entrepreneur is remaking America's energy industry (Eva Terry) (Deseret News, 2026-03-17) news “well plugged in, they know the right people”

LANL's peer-reviewed Deimos design paper (Trellue et al., Nuclear Technology, published online 18 June 2025; accepted manuscript on DOE's OSTI) gives this history. The HALEU TRISO fuel was used in the 1980s Compact Nuclear Power Source (CNPS) critical experiment at Los Alamos and stayed in storage at Los Alamos until the 2000s, when it moved to NCERC in Nevada. LANL unpacked and reused it for the Deimos experiment in September 2024. The paper describes the kernels as 'CNPS fuel fabricated by General Atomics', uranium oxycarbide (UC0.3O1.7) at an average enrichment of 19.9% U-235. The compacts average 0.6214 cm in radius and 4.9426 cm long (called '2-in.' compacts) and weigh 14.73 g. Graphite cups about 95 cm long each hold nineteen compacts, and each cup held about 130 g of HALEU. Because of the fuel's unusually high particle packing, 'the compacts were crumbling and losing the small TRISO spheres', so they were placed in the graphite cups to protect them. The paper says extensive characterization was under way to verify the documented values. It does not mention Valar, and it does not say who owns the fuel. (Updates plan-014.)

• Design of a High-Assay Low-Enriched Uranium Tri-Structural Isotropic Critical Experiment for Advanced Reactor Validation (accepted manuscript), Sec. II (Los Alamos National Laboratory, in Nuclear Technology (via DOE OSTI), 2025-06-18) primary government “The kernels comprised UC0.3O1.7 and an average enrichment of 19.9% 235U”
• Design of a HALEU TRISO Critical Experiment for Advanced Reactor Validation, accepted manuscript, Sec. II (Los Alamos National Laboratory (via DOE OSTI), 2025-06-18) primary government “the compacts were crumbling and losing the small TRISO spheres”
• Design of a HALEU TRISO Critical Experiment for Advanced Reactor Validation, accepted manuscript, Sec. I (Los Alamos National Laboratory (via DOE OSTI), 2025-06-18) primary government “LANL recently unpacked and reused the CNPS fuel at NCERC”

Three state positions within six months, each from its own record. (1) In court: the State of Utah is a plaintiff, with Texas and Last Energy, in the suit filed on 29 December 2024 (per the release of Louisiana's environmental agency, which joined the suit in April 2025) in the U.S. District Court for the Eastern District of Texas, asking the court to set aside the NRC's reactor-licensing rule 'at least as applied to certain small, non-hazardous reactors' and to exempt the plaintiff states' research reactors and Last Energy's reactors from NRC licensing (World Nuclear News, 10 Jan 2025); Valar joined in April 2025 (orig-016, safe-028). (2) In its signed agreement: the OED-Valar MOU of 16 May 2025 names compliance with DOE regulations and does not mention the NRC (gov-011). (3) In public: KUTV (story dated 28 May 2025, from an interview days earlier; the only report of this remark found) reported Gov. Spencer Cox saying safety would be assured by working with the Nuclear Regulatory Commission through planning, building and implementation, and in July 2025 OED's director said Valar would have to follow all federal licensing rules (orig-065). The record: Ward 250 was authorized by DOE alone, with no NRC license planned (safe-001). The gap is between the governor's public account of NRC oversight and the state's own documents, which pointed to DOE and, in court, argued against NRC licensing of small reactors. What the governor was told before speaking is not in the record.

• Lawsuit challenges NRC on SMR regulation (World Nuclear News, 2025-01-10) news “at least as applied to certain small, non-hazardous reactors”
• Memorandum of Understanding between OED and Valar Atomics, May 16, 2025 (Utah Office of Energy Development, 2026-01-12) primary government “including Department of Energy (DOE) regulations”
• Utah's new 'advanced' nuclear reactor for research, won't produce energy (KUTV, 2025-05-28) news
• Louisiana Joins Legal Challenge to Unleash Nuclear Energy Innovation (Louisiana Department of Environmental Quality, 2025-04-08) primary government “The lawsuit, originally filed on December 29, 2024, by Texas, Utah, and Last Energy”

Executive Order 14301 (23 May 2025, 90 FR 22591), read in full on govinfo: section 3 finds that reactors under DOE's 'sufficient control' that do not produce commercial electric power are for research and fall within DOE's jurisdiction, rather than needing an NRC license; section 4 has DOE rewrite its rules to 'significantly expedite' approvals and, once an application is substantially complete, form a team from the Secretary's office, a national laboratory, DOE's General Counsel and any office able to 'deconflict, oppose, or approve' it, which 'shall provide assistance to the applicant to ensure expeditious processing', each member reporting to the Secretary; section 5 creates the pilot program 'outside the National Laboratories', orders the Secretary to approve at least three reactors with the goal of criticality in each by 4 July 2026, and assigns each approved applicant such an assistance team; section 6 orders NEPA reform, including new categorical exclusions (the one used for Ward 250, csite-020); section 7 has the Secretary implement the order with 'the DOGE Team Lead at the Department', OMB and OSTP. The order sets no public-hearing or comment step for reactor approvals.

• Executive Order 14301 of May 23, 2025, Reforming Nuclear Reactor Testing at the Department of Energy (90 FR 22591) (Federal Register (GPO govinfo), 2025-05-29) primary government “The team shall provide assistance to the applicant to ensure expeditious processing”

Three companion orders signed with EO 14301 on 23 May 2025, read on govinfo: EO 14300 orders the NRC to rewrite its rules within 18 months, set fixed licensing deadlines (18 months for a new reactor) and 'reconsider reliance on the linear no-threshold (LNT) model' and the 'as low as reasonably achievable' standard, consulting DOD, DOE and EPA; it calls those models flawed. EO 14302 directs DOE to seek Defense Production Act voluntary agreements with nuclear companies, to 'prioritize' firms with milestones such as DOE-approved conceptual safety design reports or the ability to privately finance their fuel, and allows procurement support or offtake guarantees for consortia (the agreement Valar signed, gov-001). EO 14299 has the Army operate a reactor at a domestic base by 30 September 2028 and has DOE start designating AI data centers at DOE sites as critical defense facilities where appropriate. No record read shows Valar selected for an Army reactor program.

• Executive Order 14300 of May 23, 2025, Ordering the Reform of the Nuclear Regulatory Commission (Federal Register (GPO govinfo), 2025-05-29) primary government “reconsider reliance on the linear no-threshold (LNT) model for radiation exposure”
• Executive Order 14302 of May 23, 2025, Reinvigorating the Nuclear Industrial Base (Federal Register (GPO govinfo), 2025-05-29) primary government “the ability to privately finance their fuel”
• Executive Order 14299 of May 23, 2025, Deploying Advanced Nuclear Reactor Technologies for National Security (Federal Register (GPO govinfo), 2025-05-29) primary government “no later than September 30, 2028”

The Utah Office of Energy Development (OED) owns and runs the San Rafael Energy Lab, is Valar's landlord there, and promotes the project. On 23 May 2025 Taylor announced the state deal on Bloomberg TV alongside Gov. Spencer Cox, who said of the July 2026 target, 'It's absolutely possible that we can do that' (The New Republic). OED's people, in their own words: Director Emy Lesofski said in July 2025 the state's agreement was a non-binding MOU, 'still not a commitment' (UIJP), and at the September 2025 groundbreaking called it 'a historic moment'. Lab director Jaron Wallace said in the same release that Valar's 'concentrated infrastructure' means industrial-scale power for Utah, told local news in October 2025 that Valar must show no dose at the fence (safe-015), and in April 2026 spoke for the sale of county land to Valar (ppl-021). Deputy Director Jake Garfield told the Trust Lands board on 20 August 2026 that Valar had been 'diligent in guaranteeing public safety' and worked with regulators 'both at the state and' DOE. Deputy Director Tracy Rees, who oversees the lab, told the board on 17 September that 'transparency and accessibility are ethos' for Valar. Set beside the record: Valar's own safety agreement says the state 'may observe but not direct' and the state agreements it cites were not found (safe-034); no state permit or license for the reactor was found (carbon_site open questions); the worst-case analysis does show a dose at the boundary (safe-013); and the Carbon site was not named in public until August 2026 (csite-028). On 25 Sept 2026 the lab posted a time-limited Safety Manager position; the listing does not say whether it is new (dir-006). These are statements of support by the office that hosts and promotes the project; none is a safety finding.

• Who is Valar Atomics? (Eric Peterson) (The Utah Investigative Journalism Project, 2025-07-08) news “Just because we have that MOU, there’s still not a commitment at the moment”
• Valar Atomics breaks ground at the Utah San Rafael Energy Lab (press release by OED, USREL and Valar Atomics) (Utah Office of Energy Development / Valar Atomics (via Utah Business), 2025-09-17) primary government “their unique focus on concentrated infrastructure means Utah will have the industrial-scale power”
• 2026-08-20 TLA Board of Trustees Meeting Audio Transcript (auto-generated) (Utah Trust Lands Administration (Utah Public Notice Website), 2026-08-24) primary government “They've been diligent in guaranteeing public safety and working with the regulators”
• 09.17.2026 TLA Board of Trustees Meeting Audio Transcript (auto-generated) (Utah Trust Lands Administration (Utah Public Notice Website), 2026-09-17) primary government “transparency and accessibility are ethos”
• 08.20.2026 FINAL TLA Minutes (Utah Trust Lands Administration (Utah Public Notice Website), 2026-09) primary government
• Donald Trump Is Going Nuclear (Colin Jones) (The New Republic, 2026-05-26) news “It’s absolutely possible that we can do that”
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft; issued for Public Release) (Valar Atomics (Public Documents), 2025-10) primary company “State representatives may observe but not direct DOE regulatory activities”

The memorandum of understanding between the Utah Office of Energy Development and Valar Atomics, dated and signed 16 May 2025 by OED Director Emy Lesofski and Valar's Max Ukropina, is posted on OED's website with signatures omitted (the file was uploaded 12 January 2026, per the site's media record; read and transcribed from its page images 29 Sept 2026). It sets a 'non-binding framework' to evaluate Valar 'activating a nuclear test reactor' and 'TRISO fuel fabrication' at the San Rafael Energy Lab 'for research'; OED would provide site, infrastructure and shared facilities, and Valar is responsible for design, operation and 'regulatory compliance'. It targets 'Test Reactor activation by July 2026, with milestones for approvals', a week before Executive Order 14301 (23 May 2025) set the 4 July 2026 criticality goal. Clause 5 says the MOU 'and related information are confidential and shall not be disclosed without both Parties' consent, except as required by law', and that OED 'requires Valar officer approval for external disclosures'; clause 4 treats information exchanged as confidential 'unless otherwise required by law', notes that OED is subject to GRAMA, and has the lab notify Valar of any records request touching Valar-designated confidential information; clause 8 says 'No publicity shall be issued without mutual consent'. Clause 6 names compliance with applicable laws 'including Department of Energy (DOE) regulations'; the NRC is not mentioned. Either side may end it on 30 days' notice; OED cannot indemnify Valar or spend money not appropriated. The confidentiality terms are not unique to Valar: OED's later nuclear MOUs posted on its website carry similar clauses, Deployable Energy's (18 Aug 2026) barring publicity 'without the prior written consent' of the other party, and Oklo's (27 March 2026) treating the MOU, its contents and 'the fact that the Parties are discussing' it as confidential. They are OED's common practice with nuclear developers, though not universal: its June 2026 MOU with Nuclea Energy has neither clause and says only that OED is subject to GRAMA.

• Memorandum of Understanding between the Office of Energy Development and Valar Atomics, dated May 16, 2025 (signatures omitted) (Utah Office of Energy Development, 2026-01-12) primary government “No publicity shall be issued without mutual consent.”
• energy.utah.gov media record for 'MOU-Valar-compressed (2)' (upload date 2026-01-12) (Utah Office of Energy Development (WordPress media API), 2026-01-12) primary government
• Memorandum of Understanding between the Office of Energy Development and Deployable Energy (MOU-OED27218), 18 August 2026 (Utah Office of Energy Development, 2026-08-18) primary government “No Party shall issue publicity or press releases related to this MOU”
• Memorandum of Understanding between Oklo Inc. and Utah Office of Energy Development, effective 27 March 2026 (Utah Office of Energy Development, 2026-07-31) primary government “the fact that the Parties are discussing the subject matter herein”
• Memorandum of Understanding between OED and Nuclea Energy USA Inc. (OED26142), signed June 2, 2026 (Utah Office of Energy Development, 2026-06-02) primary government

The First Amended Complaint (Document 10, filed 7 April 2025, 97 pages) is captioned State of Texas; State of Utah; State of Louisiana; State of Florida; Arizona State Legislature (through Senate President Warren Petersen and House Speaker Steve Montenegro); Last Energy, Inc.; Deep Fission, Inc.; and Valar Atomics Inc. v. United States Nuclear Regulatory Commission, No. 6:24-cv-00507, U.S. District Court for the Eastern District of Texas, Tyler Division. Arizona's party is its Legislature, not its Attorney General. The NRC's Office of the General Counsel cites the case as Texas v. NRC, No. 6:24-cv-00507-JDK (E.D. Tex.). The Prayer for Relief asks the court to vacate the Utilization Facility Rule (the definition of 'utilization facility') 'at least as applied to certain small, non-hazardous reactors', to remand for further rulemaking, and to declare the universities' reactors and each company's reactors exempt from NRC utilization-facility licensing while still subject to state radioactive-materials rules. The complaint (paras 17 and 233) says NRC licensing hurdles led Valar to launch its initial reactor projects overseas, in the Philippines. It also describes Valar's reactor as using 'low-enriched uranium, with a runtime of only one month' (para 232). These are the plaintiffs' assertions in a court filing, not findings. (Updates safe-028.)

• First Amended Complaint for Declaratory Relief and Vacatur, Case 6:24-cv-00507-JDK, Document 10 (U.S. District Court, E.D. Tex. filing (posted by the Arizona House of Representatives), 2025-04-07) primary filing “Hold unlawful and set aside (i.e., vacate) the Utilization Facility Rule”
• Litigation Status Report (As of January 27, 2026), enclosure to SECY-26-0013 (U.S. Nuclear Regulatory Commission, Office of the General Counsel, 2026-01-27) primary government “Texas v. NRC, No. 6:24-cv-00507-JDK (E.D. Tex.).”

Taylor's public statements on regulation and safety, read at their sources: (1) April 2025, announcing the NRC suit: operating Ward One in a remote US test area 'would not pose a threat' to public health under any reasonable accident, and because the NRC had not exempted it 'we are building and testing this reactor in the Philippines instead'; the same post made the spent-fuel 'CAT scan' claim that engineers disputed, as reported, and for which no supporting calculation was found (safe-026; worked check: pf-007). (2) May 2025: regulation should follow industry (orig-019). (3) July 2025, to E&E News: why engage with a regulator whose jurisdiction you think is wrong (csite-022). (4) November 2025, on X as quoted by Mother Jones: keep civilization alive by treating it as a frontier, 'not covering everything in bubble wrap'. (5) November 2025, NOVA release: zero-power criticality is 'a reactor's first heartbeat, proof the physics holds'. Set beside the record: Valar's first reactor to operate, Ward 250, was built in Utah under DOE authorization, while no public record of what became of the 100 kWt Ward One planned for the Philippines was found as of 2026-09-29 (orig-018); DOE, not Taylor, set the safety limits, and the documents that hold them are largely not public (safe-007); by 2026 Valar was hiring for NRC licensing (safe-032). His own NOVA release states that zero-power criticality proves the physics, not the power: 'Cold proves the physics. Hot proves the power.' (orig-026).

• Valar Atomics is Suing the NRC (Isaiah Taylor) (Valar Atomics, 2025-04-07) primary company “we are building and testing this reactor in the Philippines instead”
• Mother Jones (Kiera Butler), 26 Feb 2026 (May+June 2026 issue) (Mother Jones, 2026-02-26) news “not covering everything in bubble wrap”
• Los Alamos National Laboratory and Valar Atomics Announce Project NOVA Criticality Milestone in Nevada (Valar Atomics, 2025-11-18) primary company “Zero power criticality is a reactor’s first heartbeat, proof the physics holds”

The April 2025 lawsuit post describes Ward One as a 100 kWt high-temperature gas reactor using TRISO fuel, named, the founder writes, after a Manhattan Project-era relative of his, with a planned operating life of less than a month. It says the design relies on strong negative thermal reactivity feedback and low power density for fully passive decay-heat removal, and claims that holding its spent fuel for five minutes would give the same radiation exposure as a CAT (CT) scan. The later Ward 250 carries the same 100 kWt figure (orig-011, orig-034), which suggests Ward 250 grew out of the Ward One concept, though no source read says so directly. Ward One itself was still unbuilt in the Philippines as of April 2026 (orig-064). For scale: a CT scan is about 1 to 10 millisieverts (FDA), so five minutes would need 12 to 120 millisieverts an hour; the post gives no amount of fuel, cooling time, distance or shielding.

• Valar Atomics is Suing the NRC (Valar Atomics, 2025-04-07) primary company “Ward One, a 100kWt High Temperature Gas Reactor using TRISO fuel”

Valar's post of 7 April 2025 announces that it joined Texas, Utah, Louisiana, Florida and Arizona, with Last Energy and Deep Fission, in a lawsuit against the NRC. As Valar describes it, the suit argues that the Atomic Energy Act of 1954 limits NRC licensing to reactors significant to defense or public health and safety, and that the 1956 'Utilization Facility Rule', issued by the NRC's predecessor, the Atomic Energy Commission, which requires a license for any reactor, exceeds that authority; Valar says its planned 'Ward One' reactor is named in the suit and that states have begun creating regulatory bodies to host such tests. The Louisiana Department of Environmental Quality's release of 8 April 2025 says the case was filed on 29 December 2024 by Texas, Utah and Last Energy and positions Louisiana to benefit from a favorable ruling or settlement. E&E News (23 July 2025) reports the case is in the U.S. District Court for the Eastern District of Texas, that the NRC first moved to dismiss it, and that in June 2025 the NRC joined the plaintiffs in asking the court to extend a stay to 29 September 2025 to seek 'a mutually agreeable resolution'; the court granted it on 30 June. E&E also reports Valar had not contacted or met with the NRC, with Taylor asking why a company that believes the jurisdiction is wrong would engage (csite-022). The court docket (CourtListener, PACER), the Florida Attorney General's posted complaint and a co-plaintiff's SEC filing refused our reader, so the case's status after September 2025 is unconfirmed as of 29 September 2026. Ward 250 itself went forward under DOE authorization, not under the state-regulation model the suit argued for.

• Valar Atomics is Suing the NRC (The Nuclear Necessity and our decision to sue the NRC) (Valar Atomics (Isaiah Taylor), 2025-04-07) primary company “Valar Atomics' own Ward One is a reactor named in the suit.”
• Louisiana Joins Legal Challenge to Unleash Nuclear Energy Innovation (press release) (Louisiana Department of Environmental Quality, 2025-04-08) primary government “positions Louisiana to benefit from any favorable ruling or settlement”
• NRC lawsuit could hand states power over advanced reactors (E&E News by POLITICO, 2025-07-23) news “a mutually agreeable resolution that could avoid or limit further litigation”

March 2025 (GMA News and Daily Tribune, March 24; Power Philippines): speaking as president of Valar Atomics Research Institute, Kip Mock said Valar would build a 100 kW micro high-temperature gas reactor with the Philippine Nuclear Research Institute (PNRI) as a proof of concept, not connected to the grid and not generating electricity, at a cost in the 'tens of millions' of dollars; licensing with PNRI's regulatory arm had begun; he would not give a timeline or location. A US firm, EoS Organization, gave a 192-million-peso grant to the Philippine Nuclear Science Foundation in support of the reactor, and Mindanao State University-Iligan Institute of Technology joined as a partner. TechCrunch (February 2025) reported the PNRI contract covered a test-scale reactor and two full-scale reactors. Greenpeace Philippines condemned the deal (March 27, 2025). ANS (November 2025) described Valar Atomics Research Institute as a Philippine-incorporated subsidiary. The Philippine Collegian, the University of the Philippines student paper (April 2026), reports PNRI Director Carlo Arcilla said the project had Department of Science and Technology approval, aimed to finish within two to three years, and was seeking approval from the University of the Philippines to build within PNRI, which sits on UP Diliman land, and that the scientists' group AGHAM opposed it. Set beside Valar's April 2025 statement that it was building and testing this reactor in the Philippines (orig-018): a year later no reactor had been built there. Valar's claim of the world's first binding Coordinated Research Project with PNRI (orig-066) could not be checked: PNRI's website refuses our reader.

• US nuke firm partners with PNRI to build 'research reactor' in PH (GMA News Online, 2025-03-24) news “simply a proof-of-concept”
• Valar Atomics develops Phl's first nuke reactor (Maria Bernadette Romero) (Daily Tribune, 2025-03-24) news “developing a micro high-temperature gas reactor in the Philippines”
• Valar Atomics to build experimental nuclear reactor in the Philippines (Power Philippines, 2025-03-24) news “will not be connected to the grid or generate electricity”
• Greenpeace denounces PNRI-Valar Atomics nuclear deal: 'Filipinos are not guinea pigs' (Greenpeace Philippines, 2025-03-27) analysis “The company has no track record”
• New financing round benefits Valar (American Nuclear Society, Nuclear Newswire, 2025-11-13) news “a subsidiary of Valar incorporated in the country”
• Scientists, Students Oppose Construction of US-Linked Nuclear Reactor on UP Land (Philippine Collegian (published on its Substack), 2026-04-25) news “within the next two to three years”
• Valar Atomics comes out of stealth with $19M and a pilot reactor site (Mike Butcher) (TechCrunch, 2025-02-20) news “build two full-scale reactors before the first integrated reactor comes online”
• Valar Atomics is Suing the NRC (Isaiah Taylor) (Valar Atomics, 2025-04-07) primary company “we are building and testing this reactor in the Philippines instead”

Valar's website has a page titled 'Ward Zero Whitepaper', subtitled as a detailed account of how its first prototype reactor works, dated December 1, 2024 and credited to Isaiah Taylor, Kip Mock and Mark Mitchell. It is not listed in the library but loads at its public URL (read 2026-09-29), and its entry is carried in the data that the Ward 250 page loads. Its body says nothing about Ward Zero. Every one of its body sentences (66 by the first count, 68 by this pass's) matches, word for word, 'A Nuclear Curse and a Nuclear Blessing', an essay on Russian and Chinese reactor exports to the Middle East by Selim Sazak in the Fall 2019 issue of the Cairo Review of Global Affairs; the page names no source and still says the UAE's Barakah plant is expected to be fully operational by 2020. Archived copies show the same text on the page in April 2025, beside three other unlisted posts whose bodies read only 'Lorem ipsum', and again in October 2025, by when the placeholder posts were gone (orig-071). That fits leftover placeholder text rather than a finished paper (Valar has not said); the record does not show why it was used or why it remains. Either way, the one document Valar titled as a technical account of Ward Zero contains none (orig-059).

• Ward Zero Whitepaper (web page; not listed in Valar's library) (Valar Atomics, 2024-12-01) primary company “Detailed dive and abstract into how our first prototype nuclear reactor functions.”
• A Nuclear Curse and a Nuclear Blessing (Selim Sazak), Fall 2019 (The Cairo Review of Global Affairs, 2019) analysis “Out of the seventy-two new nuclear reactor export deals across the globe”
• Valar Atomics library page as archived by the Internet Archive, 8 April 2025 (page data lists the unlisted posts) (Valar Atomics (archived copy, Internet Archive), 2025-04-08) primary company “Lorem ipsum”
• Valar Atomics library page as archived by the Internet Archive, 16 October 2025 (page data carries the unlisted Ward Zero Whitepaper post) (Valar Atomics (archived copy, Internet Archive), 2025-10-16) primary company

A Business Wire release dated 29 April 2024 (linked from Valar's library) announced Mark Mitchell as Valar's Chief Nuclear Officer, to oversee nuclear operations including licensing and regulatory compliance, reactor and powerplant manufacturing planning, and client support and fleet services. It says his nuclear work began at the South African Pebble Bed Modular Reactor company and that he established and led the Micro Modular Reactor (MMR) program at Ultra Safe Nuclear (USNC); Deseret News (Mar 2026) says he was previously president of Ultra Safe Nuclear Corporation, and the September 2025 groundbreaking release issued by the Utah Office of Energy Development's lab and Valar calls him 'former USNC President Mark Mitchell'. The release then described Valar, based in El Segundo, as aiming to make synthetic fuels from CO2 and water with mass-built reactors, a goal the current mission page still lists, now beside hydrogen, data-center power and heavy industrial power (orig-001). Valar's quality plan gives the 'COO/Chief Nuclear Officer' role direct oversight of nuclear operations, engineering and quality assurance, reporting to the CEO (safe-019, safe-036); the mission page lists Mitchell as Chief Nuclear Officer, which would make his the senior nuclear-safety post, although the plan names roles, not people. What became of his earlier programs is in ppl-015.

• Advanced Nuclear Industry Innovator, Mark Mitchell, Joins Valar Atomics as Chief Nuclear Officer (Business Wire release, syndicated) (Valar Atomics via Business Wire, 2024-04-29) primary company
• Library | Valar Atomics (links the Mitchell release) (Valar Atomics) primary company “Advanced Nuclear Industry Innovator, Mark Mitchell, Joins Valar Atomics as Chief Nuclear Officer”
• At just 27 years old, this entrepreneur is remaking America's energy industry (Eva Terry) (Deseret News, 2026-03-17) news “previously served as president of Ultra Safe Nuclear Corporation”
• Mission | Valar Atomics (Valar Atomics) primary company “Mark Mitchell Chief Nuclear Officer”
• Valar Atomics breaks ground at the Utah San Rafael Energy Lab (press release by OED, USREL and Valar Atomics) (Utah Office of Energy Development / Valar Atomics (via Utah Business), 2025-09-17) primary government “led by former USNC President Mark Mitchell”
• Ward250 San Rafael Facility Quality Assurance Program Description, No. 100474, Rev 02 (status: Approved) (Valar Atomics (Public Documents), 2025-10) primary company “Direct oversight of nuclear operations, engineering, and quality assurance”

Coverage of the February 2026 airlift (World Nuclear News, ExecutiveGov, Deseret News) called Ward 250 a 5 MW or five-megawatt reactor able to power about 5,000 homes. POWER magazine (June 19, 2026) describes it as 100 kWt initial test power, scalable to 5 MWe, and ANS attributes the 100 kWt figure to Taylor; the Utah lab page says the design is meant to scale to 5 MW. Read together, 5 MW appears to be a design or scale-up rating, while the tested reactor is described by Valar at about 100 kW thermal for continuous running, roughly fifty times smaller. Valar's draft safety agreement (NSDA Rev 02) sets 'Maximum continuous power: 100 kWth' and allows 250 kWth for short (1-hour) runs; DOE's categorical exclusion describes Ward 250 as 'a 250 kilowatt thermal (kWth)' reactor. No DOE document stating the authorized power limit was read in this pass (see open questions).

• Valar Atomic’s Ward 250 Becomes Second Reactor to Go Critical Under DOE Pilot Program (POWER Magazine, 2026-06-19) news “100 kWt initial test power and scalable to 5 MWe”
• US microreactor transported by air (World Nuclear News, 2026-02-18) news “The Ward250 could provide power to about 5,000 homes.”
• At just 27 years old, this entrepreneur is remaking America's energy industry (Deseret News, 2026-03-17) news “flew with the five-megawatt reactor aboard three Air Force cargo planes”
• Valar’s Ward 250 reaches criticality in Utah (American Nuclear Society (Nuclear Newswire), 2026-06-22) news
• 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)
• Ward250 Nuclear Safety Design Agreement, No. 100403, Rev. 02 (status: Draft), Table 2 and Appendix B (Valar Atomics (Public Documents), 2025-10) primary company “Not required for application”

The November 2025 NOVA release says the NOVA core used HALEU TRISO fuel and 'the same fuel' as Ward 250. DOE defines HALEU as enriched between 5% and less than 20% U-235. Valar's October 2025 NSDA design table lists Ward 250 fuel enrichment as 4.95% U-235 under 'LEU limits', which is below the HALEU range. The October 2025 NSDA also gives two different outlet temperatures (650 C nominal in the design table, 750 C as a performance objective), and the company's NSDA web summary says testing up to 650 C. DOE's own shipping review (Safety Evaluation Report, May 20, 2026) authorized limited shipments of HALEU TRISO fuel compacts, enriched to at most 19.9% U-235, from Los Alamos's criticality center in Nevada, with their end use as fuel elements in Ward 250 (safe-010). That matches the NOVA wording, not the NSDA's 4.95%. Whether the approved safety analysis was updated to HALEU is not public; the DSA would settle it (disc-001).

• Los Alamos National Laboratory and Valar Atomics Announce Project NOVA Criticality Milestone in Nevada (Valar Atomics (joint announcement with LANL), 2025-11-18) primary company “a series of criticality experiments on a HALEU TRISO”
• Ward250 Nuclear Safety Design Agreement (Document 100403, Rev. 02) (Valar Atomics, 2025-10) primary filing “4.95% U-235”
• Safety Evaluation Report, Letter Amendment of Certificate of Compliance No. 9979 for the Model 9979 Package, Docket 26-35-9979 (U.S. Department of Energy, Packaging Certification Program, 2026-05-20) primary government “enriched to a maximum of 19.9 wt.% U-235”
• What is High-Assay Low-Enriched Uranium (HALEU)? (U.S. Department of Energy, Office of Nuclear Energy, 2024-12-03) primary government “By definition, HALEU is enriched between 5% and less than 20%”

Deseret News (17 Mar 2026, and again 18 Jun 2026) reports that Willem Kriel came out of retirement to help lead Valar's engineering team, and names him with Mark Mitchell and Muhammad Shahzad as experienced hires; it gives no earlier employer. A Willem Kriel co-authored 'PBMR Project - Pebble Fuel Advantages', a paper on South Africa's Pebble Bed Modular Reactor fuel given at a 2006 nuclear conference in Seoul and indexed by DOE's OSTI database; the record lists two affiliations, PBMR Ltd. (Gauteng, South Africa) and Westinghouse Electric Company (Windsor, US), and its marker places Kriel with the second group (Westinghouse), not with PBMR Ltd. The name and field match the Deseret account, but no source read states that the Valar engineer is that author, and his other papers found under that name could not be read (sources_not_read). Valar's own pages and public documents do not name him, and his title at Valar is not public. When he joined is not stated. For what became of PBMR, see ppl-015.

• At just 27 years old, this entrepreneur is remaking America's energy industry (Eva Terry) (Deseret News, 2026-03-17) news “came out of retirement”
• PBMR Project - Pebble Fuel Advantages (21st KAIF/KNS Annual Conference, Seoul) (U.S. DOE Office of Scientific and Technical Information (ETDEWEB), 2006-04-15) primary government