Emergency planning: Valar asked for on-site only, cited state-DOE agreements and drills; none found in public records

unresolvedsafety

What was said

Valar Atomics (safety agreement, code of record and Appendix C.3) (2025-10): Asks to tailor DOE's emergency order to "On-site emergency response only" (no off-site planning), justified by the boundary dose and an 800 m distance to the nearest residence.
Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), pages 45 and 54 (Valar Atomics, 2025-10)
Valar Atomics (safety agreement, state and local coordination) (2025-10): "The State of Utah maintains agreements with DOE regarding notification and coordination" for nuclear facilities; promises responder tours, "Table-top exercises", direct notification links and annual coordination meetings with Emery County.
Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), pages 20-21 (Valar Atomics, 2025-10)

What the record shows

No Utah-DOE notification agreement, public emergency plan, record of a table-top exercise or notification arrangement for residents was found in state, county or DOE records as of late September 2026 (safe-016).
Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), pages 20-21 (Valar Atomics, 2025-10)
The Nuclear Innovation Alliance reads DOE-STD-1271 as allowing equivalents 'Except for Emergency Planning and Cybersecurity'; the standard's general text still lets a contractor request an exemption. Valar's web summary does not list emergency planning among the alternatives it says DOE approved.
A Review of Recent DOE Updates to Its Reactor Authorization Process (Nuclear Innovation Alliance, 2025-12-01)
Emery County's fire district minutes: the State Fire Marshal's office 'didn't want to touch it' (November 2025); 'State agencies declined to perform plan review and recommended third-party review' (February 2026); the county has no fire inspector; by March the minutes say 'The issue has been addressed with chiefs and is not currently a concern.' (In December 2025 the district's chairman said he would sign the plans once he received the paperwork.)
Emery County Fire Protection SSD meeting minutes, February 17, 2026 (header misprints the year) (Emery County Fire Protection Special Service District, 2026-02-17)
Orangeville's minutes record its ambulance available 13% of the time in June 2026.
July 9, 2026 City Council Meeting Minutes (Orangeville) (Orangeville City (Utah Public Notice Website), 2026-07-09)
In comments NIRS filed with 25 groups, Uranium Watch told DOE that coverage of the Valar reactor gave no information on emergency response planning or who to contact.
Comments regarding DOE categorical exclusion for advanced nuclear reactors, Docket DOE-HQ-2025-0405 (NIRS and co-signers incl. HEAL Utah and Uranium Watch) (Nuclear Information and Resource Service et al., 2026-03-04)
The safety agreement required equivalency and exemption requests to 'receive DOE approval prior to DSA submittal'. POWER reported that Valar received final DSA approval on 23 April 2026, so under that rule any decision on on-site-only emergency planning came before then; no such decision was found in public records as of late September 2026; Valar's own list of DOE-approved alternatives does not include it.
Ward250 Nuclear Safety Design Agreement, No. 100403, Rev 02 (status: Draft), page 20 (Valar Atomics, 2025-10)

The gap: Valar asked DOE to require only on-site emergency response and told DOE that state-DOE notification agreements and local drills would back it up. No DOE decision on the request, state-DOE agreement, emergency plan or drill record was found in public records as of late September 2026. The State Fire Marshal declined to review the reactor building's fire plans; by March 2026 the county fire district's minutes said the issue had been addressed with the chiefs and was not currently a concern. The paper's justification (p.54) calls boundary doses under 0.5 rem well below EPA's Protective Action Guides. EPA's guide for sheltering or evacuation starts at 1 rem over four days, 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.

In plain termsNuclear plants normally plan how to warn and, if needed, move people nearby; Valar's paper calls that 'off-site evacuation planning.' Valar asked DOE to require planning only inside its own site, arguing that even its worst case stays small beyond the fence. It told DOE that Utah already has agreements with DOE for notifying people and that it would run drills with Emery County responders. No such agreement, no emergency plan and no drill record could be found in public records. The state fire marshal's office declined to review the building's fire plans (by March 2026 the county fire district said the issue had been addressed and was not currently a concern), and in June the local ambulance was available 13% of the time. Plans may exist that were not found in public records; records requests could show it.

Why it matters: If something goes wrong, neighbors and first responders depend on plans that no public record shows exist.

What would settle it: FOIA to DOE Idaho Operations Office for the approved emergency management program and DOE's decision on the on-site-only request; GRAMA to Emery County Emergency Management, the Emery County Fire Protection District and the Sheriff for plans, agreements and exercise records; GRAMA to Utah DEQ and the Division of Emergency Management for any DOE notification agreement.

facts safe-016, loc-018, loc-008, safe-029 · checked 2026-10-02: Checked for fairness to Valar, late September 2026: looked for any DOE decision, state-DOE agreement, emergency plan or drill record in the NSDA, NSDA web summary, CX, DOE releases, county and fire-district minutes; none found. The NSDA's page-20 rule dates any decision to before the DSA; the web summary's approved list omits emergency planning, which is consistent either with DOE refusing the request (full DOE emergency order applies) or with a decision that was not found in public records. Absence is 'none found', not proof none exists. Status stays unresolved; summary line literally true. | Earlier check: Re-read in late September 2026: NSDA pp. 20-21, 45, 54 (quotes exact), NIA review, fire district minutes of 17 Nov 2025 and 17 Feb 2026, Orangeville 9 July 2026 minutes, NIRS comments. Absence is 'none found', not proof none exists. | Revised before publication (late September 2026): gap adds EPA's sheltering-or-evacuation guide (1 rem, a factor of 2) and the unaddressed 5 rem child-thyroid guide. | Revised before publication (late September 2026): verification wording updated.