RE: ACOA Request for Input - Designation Request for the Small Modular Reactor Demonstration Project

Good morning Joseph,

I am writing to confirm that your understanding of ACOA’s support to NB Power is correct and agree with your conclusion that ACOA has not exercised a power or performed a duty or function that would permit the physical activity to be carried out.

We are available to discuss in greater detail at any time.

Regards,

Danika LeBlanc, CPA, CGA

From: Reactor-Reacteur (IAAC/AEIC) <Reactor-Reacteur@iaac-aeic.gc.ca (mailto:Reactor-Reacteur@iaac-aeic.gc.ca)>
Sent: Monday, November 28, 2022 1:14 PM
To: Danika LeBlanc <Email addresses removed>
Cc: <Email addresses removed>
Subject: RE: ACOA Request for Input - Designation Request for the Small Modular Reactor Demonstration Project

Hello Danika and Luke,

Thank you for providing ACOA’s response to our request for input on this file. We have been progressing through the designation request process, and are preparing the analysis and final recommendation to our Minister for his decision under subsection 9(1) of the Impact Assessment Act.

I wanted to follow-up and close the loop on ACOA’s input, and check if you had any further questions or matters you may want to discuss in terms of how your input was considered.

We understand that ACOA provided funding to NB Power to undertake foundational activities to prepare for deployment and demonstration of small modular reactor (SMR) technologies in New Brunswick. Activities that ACOA has provided funding for include engineering support and review services, establishing baseline site designs, addressing environmental and regulatory requirements, and project planning and financing activities. Based on the information ACOA provided, we understand that ACOA did not provide funding for the construction, operation, or decommissioning of the proposed ARC-100 SMR Demonstration Project, or the carrying out of any associated physical activity that may result in environmental effects.

Based on this understanding, we are of the view that ACOA has not exercised a power or performed a duty or function that would permit the physical activity to be carried out. Therefore, the Minister is not limited in his ability to designate the project as per subsection 9(7) of the Impact Assessment Act.

We will inform our Minister that he has the ability to designate the ARC-100 SMR Demonstration Project, and our analysis and recommendation will focus on whether or not he should consider doing so.

If you feel any of the above is incorrect or if we have misrepresented ACOA’s input, or if you wish to discuss anything further, please do not hesitate to get in touch.

Take care,

Joseph Vigder

(he/him | il)

Project Manager, Atlantic Region

Impact Assessment Agency of Canada / Government of Canada

joseph.vigder@iaac-aeic.gc.ca (mailto:joseph.vigder@iaac-aeic.gc.ca) / Tel : 902-229-9637

Gestionnaire de projets, région atlantique
Agence d’évaluation d’impact du Canada / Gouvernement du Canada
joseph.vigder@iaac-aeic.gc.ca (mailto:joseph.vigder@iaac-aeic.gc.ca) / Tél : 902-229-9637

From: Danika LeBlanc <Email address removed>>
Sent: October 25, 2022 4:36 PM
To: Reactor-Reacteur (IAAC/AEIC) <Reactor-Reacteur@iaac-aeic.gc.ca (mailto:Reactor-Reacteur@iaac-aeic.gc.ca)>
Cc: <Email addresses removed>
Subject: RE: Request for Input - Designation Request for the Small Modular Reactor Demonstration Project

Hello Joseph,

Please find attached the completed Request for Federal Expert Advice, in relation to the Designation Request for the Proposed Small Modular Reaction Demonstration Project under the Impact Assessment Act. ACOA’s responses are in reference to the ACOA funded project. Below is additional context and detail around ACOA’s involvement with the Énergie NB Power’s Small Modular Reactor Program, Phase II, and it’s deliverables:

ACOA Project Description:

“This project will enable NB Power to undertake activities to prepare for deployment and demonstration of small modular reactor (SMR) technologies at an approved nuclear site in New Brunswick. The project will focus on foundational activities such as establishing baseline site designs and addressing environmental and regulatory requirements. Project deliverables will include creating preliminary site designs, negotiating power purchase agreements, coordinating with the Canadian Nuclear Security Commission for vendor design review, establishing a fuel supply, and overseeing project planning and financing. NB Power will also be pursuing engagements with First Nations and the public as part of this project.”

• Énergie NB Power’s Small Modular Reactor Program, Phase II, includes the following activities:

• • Engineering support and review services:
    • To support the development of conceptual and preliminary designs of both the Moltex and ARC technologies,
    • Site evaluation and placement studies,
    • Utilities Requirement Document (URD) which outlines key safety, design, operational and project attributes the Owner/Operator requires.

• • Licensing and Regulatory:
    • Reviews and advice to ARC as they complete the Vendor Design Review (VDR) Phase 2,
    • Initiation of discussions with the CNSC related to WATSS and used fuel recycling,
    • Working with the technology vendors to prepare the License To Prepare Site (LTPS) application,
    • Conduct preliminary discussions with CNSC on pre-licensing, LTPS, IA, and License to Construct

• • Environment and Engagement:
    • Conduct specific environmental and baseline studies,
    • Prepare draft Project Descriptions for both technologies,
    • Conduct engagement activities with First Nations, the Public, and key stakeholders.

• • Operations and Management System Development:
    • Develop management system framework, initial policies and procedures for the Owner/Operator,
    • Provide advice to both ARC and Moltex relating to management systems,
    • Provide operations input into both vendor designs,
    • Conduct initial planning activities associated with recruitment, staffing, and training operational staff for the SMR demonstration units.

• • Finance and Business:
    • Develop Owner/Operator costs and controls,
    • Develop overall project plan and schedule(s),
    • Provide review and advice to ARC and Moltex on project plans, and cost estimates,
    • Prepare a framework for the Power Purchase Agreement(s) (PPA),
    • Establish a framework for the Owner/Operator consortium,
    • Interface and work with NB Power Transmission and Marketing on the integration of SMRs into the New Brunswick electrical grid,
    • Begin initial stages of the Phase 2 of the SMR Supply Chain assessment.

Additionally, for clarification, I want to underline the fact ACOA has not directly supported the ARC technology research or development, on which this Request for Input is focused. The NB Power project ACOA has supported has undergone both our internal Impact Assessment and Duty to Consult processes, and did not trigger either for further assessment or consultation, respectively. I would be happy to connect and discuss this further at your convenience,

Thank you,

Danika LeBlanc, CPA, CGA

Manager, Innovation

Atlantic Canada Opportunities Agency / Government of Canada

Danika.leblanc@acoa-apeca.gc.ca (mailto:Danika.leblanc@acoa-apeca.gc.ca) / Tel : 506-381-8718 / TTY: 7-1-1

Gestionnaire, Innovation

Agence de promotion économique du Canada atlantique / Gouvernement du Canada

Danika.leblanc@acoa-apeca.gc.ca (mailto:Danika.leblanc@canada.ca) / Tél. : 506-381-8718 / ATS : 7-1-1

From: Reactor-Reacteur (IAAC/AEIC) <Reactor-Reacteur@iaac-aeic.gc.ca (mailto:Reactor-Reacteur@iaac-aeic.gc.ca)>
Sent: Wednesday, October 5, 2022 11:18 AM
To: <Email addresses removed>
Cc: <Email addresses removed>
Subject: Request for Input - Designation Request for the Small Modular Reactor Demonstration Project

Hello All,

Please find attached a letter and related information from the Impact Assessment Agency of Canada regarding a request sent to the Minister of Environment and Climate Change to designate the Small Modular Reactor Demonstration Project at Point Lepreau, NB. The Agency is requesting your input by October 25, 2022 in order to help inform the Minister on whether the project should be designated.

If you have any questions, do not hesitate to get in touch.

Regards,

Joe Vigder

(he/him | il)

Project Manager, Atlantic Region

Impact Assessment Agency of Canada / Government of Canada

joseph.vigder@iaac-aeic.gc.ca (mailto:joseph.vigder@iaac-aeic.gc.ca) / Tel : 902-229-9637

Gestionnaire de projets, région atlantique
Agence d’évaluation d’impact du Canada / Gouvernement du Canada
joseph.vigder@iaac-aeic.gc.ca (mailto:joseph.vigder@iaac-aeic.gc.ca) / Tél : 902-229-9637