ML22308A169

Enclosure - Climate Action Plan in Response to EO 14008 Tackling the Climate Crisis at Home and Abroad

ML22308A169
Person / Time
Issue date:	11/28/2022
From:	Dan Dorman NRC/EDO
To:	Mayock A Council on Environmental Quality
Shared Package
ML22308A167	List: ML22308A168 ML22308A169
References
SRM-OGC210219-3-ADM
Download: ML22308A169 (5)

Text

Climate Action Plan in Response to EO 14008 Tackling the Climate Crisis at Home and Abroad

Purpose

On January 27, 2021, President Biden issued Executive Order (EO ) 14008, Tackling the Climate Crisis at Home and Abroad. Section 211 of the EO direc ts each agency to develop a Climate Action Plan to describe steps that the agency can take relevant to its facilities and operations to mitigate the effects of climate change. The below sets forth steps that the agency can take with regard to its own facilities and operations, as o pposed to the facilities owned and operated by its licensees. The U.S. Nuclear Regulatory Commissi on (NRC) is committed to maintaining awareness of the state of climate change science an d to applying lessons to agency operations as appropriate and applicable. This document serves as the NRCs progress on previous and future steps to its facilities and operations t o bolster adaptation and increase resilience to climate change impacts per the requirements of EO 14008 and outlines the agencys financial risks per EO 14030 subsection 5(d) Climate A ction Plan.

Responsibility

The Director, Office of Administration, is designated at the NR Cs Chief Sustainability Officer and is responsible for agency efforts related to sustainability, including compliance, as appropriate, with EO 14008.

NRCs Mission

The NRCs mission is to license and regulate the Nations civil ian use of byproduct, source, and special nuclear materials, to ensure adequate protection of pub lic health and safety, to promote the common defense and security, and to protect the environment. The NRCs regulatory activities, conducted under its independent regulatory mission, are outside the scope of section 211 of EO 14008.

As a part of its regulatory activities, the NRC conducts safety and environmental reviews to support its licensing decisions. Nuclear power plants and fuel cycle facilities are owned, managed, and operated by licensees. Climate impacts are conside red in licensing decisions related to natural hazards for a facility (e.g., external flood ing from various flood-causing mechanisms such as storm surge, local intense precipitation, an d riverine and coastal flooding; low water conditions; extreme temperatures; and high winds) and are assessed as part of the NRCs safety review. The environmental review is focused on the impact that a facility has on the environment. In accordance with Commission direction, the N RC considers carbon dioxide and other greenhouse gas emissions in its environmental reviews for major licensing actions under the National Environmental Policy Act.

NRC Facilities Operations and Maintenance

The NRC is committed to reducing any detrimental effects that i ts own operations have on the environment. The NRC does not own or lease real property, nor d oes it manage public lands and waters. Each NRC facility is occupied via an Occupancy Agre ement between the NRC and the General Services Administration (GSA). The NRC does, howeve r, have delegated authority through GSA to operate and maintain two of its headquarters bui ldings located in Rockville, MD (One White Flint North (OWFN) and Two White Flint North (TWFN) respectively) and has done so since their construction in the early 1990s. This report is limited to the two buildings the NRC

Enclosure 2

operates and maintains. The NRC has successfully and progressiv ely made significant investments over the last 15 years, as illustrated below, to re duce the energy consumption and water usage in both buildings. As a result, the agency has redu ced water consumption by 44 percent as compared to 2012, and electric consumption has reduc ed by 64 percent as compared to 2012. More recently, year over year reductions are similarly illustrated below. The NRC continues to pursue more efficient ways of operating the bu ildings, however due to the successes of the robust investm ents and upgrades already implemented, there are few opportunities to significantly reduce energy and water usage fu rther.

Electric Usage Mitigation Measures From 2012 to Present

Since 2012, the agency has progressively implemented energy sav ings strategies, allowing the agency to exceed its reduction targets for energy intensity. Th e NRC continues to evaluate trends and identify other potential energy reduction measures f or future efforts. Examples of energy saving strategies that have been implemented and have co ntributed to the reductions stated above include:

• progressive replacements to old equipment with newer high effi ciency designs;

• installation of a new building automation system to control th e heating and cooling systems in the buildings;

• improvements to TWFN during a recent renovation including repl acement of chillers with high efficiency magnetic bearing units and the incorporation of cross connect systems between the tenant and base chill water to enable a single chil ler to cool the entire building;

• replacement of the elevator drive system, electrical motor con trollers, door operators and mechanical hoist way equipment in TWFN;

• incorporation of water-cooled heat pumps into the building hea ting, ventilation, and air conditioning (HVAC) system and elimination of electric resistan ce heating, allowing for use of rejection heat from data closets/telephone rooms to heat office areas;

• upgrading of highly efficient ENERGY STAR certified heat pump units throughout OWFN and TWFN (in fiscal year (FY) 2020 the NRC upgraded a total of 13 units);

• installation of new light-emitting diode (LED) light fixtures in TWFN that are connected to office area occupancy sensors were installed on every TWFN floo r, each floor was designed to use new technologies to implement light-harvesting techniques in office spaces;

• LED light replacement in the OWFN garage

• replacement of large air-handling units with high-efficiency m otors; and

• upgrading OWFN, floor by floor, with more efficient building s ystems including the improved LED lighting and controls, light harvesting, and other passive design features to optimize the use of natural lighting.

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The NRC purchases 100% of its electricity from the Potomac Elec tric Power Company (Pepco),

using a GSA areawide contract. As part of the contract, 20 perc ent of the electricity that the NRC uses comes from renewable energy sources. In FY 2021, this amounts to approximately 1,258,759 kilowatt hours of energy. Agera Energy provides this renewable energy to Pepco from wind resources in Texas.

In FY 2018, to support grid reliability and lower utility costs, the NRC enrolled in a demand response program. This program offers payments to businesses th at demonstrate a predefined energy reduction strategy and agree to reduce their demand at t imes when the grid is under stress. Strict compliance with GSA recommended building operati on guidelines regarding space temperature and occupancy schedules. In FY 2019, the NRC instal led meters in the uninterruptible power supply room and the data center of anothe r headquarters location, Three White Flint North (3WFN) to support its Data Center Infrastruct ure Management software.

These meters are being used to create power usage effectiveness reports, which help determine the energy efficiency of the 3WFN data center.

Water Usage Mitigation Measures 2012 to Present

Regarding the reduction of water usage, the NRC has implemented several water-saving strategies and continues to evaluate water usage trends to iden tify other ways to reduce water consumption. Examples of water saving strategies that have been implemented over time that have contributed to the reductions stated above include:

• upgrade of high-flow restroom fixtures to more efficient low-f low fixtures in all OWFN and TWFN restrooms;

• installation of chemical free cooling tower water treatment wh ich reduced the need for blowdown;

• upgrade to cooling tower make-up water systems which included installing redundant alarms for cooling tower overflow;

• installation of a new filtered drinking water system with wate r fountains that have an integrated water-bottle filler;

• a focus on upgrading high-flow restroom fixtures to more effic ient low-flow fixtures to reduce the amount of water usage associated with wastewater;

• installation of sub-meters for the cooling towers, for NRC sta ff to monitor water usage associated with the HVAC system more closely; and

• installation of sub-meters and monitoring water usage associat ed with irrigation, which allows the agency to detect leaks within the irrigation system as well as broken sprinkler heads and system malfunctions.

The energy and water saving measures already implemented and li sted above, have proven to be life cycle and cost-effective. The NRC will continue to impl ement those measures as it renovates the OWFN building, as well as search for other new ef ficiencies and technologies that may further reduce consumption. Consistent with the reduction o f energy and water usage, the 4

agencys costs for electricity has reduced by 64 percent and wa ter costs by 44 percent as compared to 2012, despite the ever increasing costs per unit fo r utilities.

For the illustration of financial risks per EO 14030 subsection 5(d) Climate Action Plan below are the NRCs future funding needs to further reduce our impact on climate change. The below was also submitted to the Office of Management and Budget regar ding funding levels in NRCs FY 2024 budget request (for the items outlined in EO 14057 rega rding the reduction of fossil fuel emissions in Federal Government facilities and operations).

FY 2024 NRC Request

Goal Total Investment ($M)

Goal 1: 100 percent carbon free electricity by 2030 $0.38M

Goal 2: Transition to a zero-emission vehicle fleet $0.025M

Goal 3: Enable net-zero emission buildings, facilities, installations $0 Goal 4: Develop staffing and human capital to ensure successful implementation of Federal sustainability goals and requirements $0

1) The total electric costs for OWFN and TWFN is $1.9M, which i ncludes 20 percent of its electricity from renewable sources through a contract with GSA and Pepco. Due to fluctuations in energy prices and the fact that the cost of ene rgy from renewable sources is not specified in the contract, 20 percent of $1.9M is $0.38M, as specified in the table above. The additional cost to achieve 100 percent carbon free e lectricity by 2030 is estimated to be 50 to 75 percent above the NRCs current costs for electricity, which would require an additional $1.0M to $1.4M. The additional cost s, in coordination with GSA and Pepco, will be considered in future budget submissions.

2) The NRC currently leases 25 vehicles from GSA, including veh icles for the Office of Inspector General and our regional offices. Some vehicles are h ybrid, but none are fully electric vehicles. The NRCs FY 2024 request included $0.025M t o fund the lease costs for two fully electric vehicles. It is estimated that there wil l be an additional cost of $0.5M to change the entire fleet to fully electric vehicles leased fr om GSA. This would also require an estimated additional $0.5M to install electric charg ing stations. The NRC will consider these additional costs in future budget submissions.

3) OWFN and TWFN are very close to the goal of net-zero fossil fuel emissions. Only two commercial gas water heaters remain. The estimated cost to repl ace the gas water heaters with electrical water heaters will be considered in fut ure budget submissions.

4) After careful consideration, the NRC has determined it is no t necessary to dedicate additional human capital resources to ensure the agencys succe ssful implementation of Federal sustainability goals and requirements outlined in this addendum. The NRC will utilize existing resources and consider emergent resource needs related to the implementation of the Federal substainablity goals and requirem ents in future budget submissions, as appropriate.

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Summary

The NRC remains committed to continue to reduce its energy and water usage by incorporating efficient sustainability practices within its building operatio ns and other applicable areas to build on the successful implementati on of the measures already incorp orated. The agency will also initiate new efforts where possible to reduce its environmental impacts. The NRC is committed to meeting and exceeding the goals set forth by both EO 14008, Tackling the Climate Crisis at Home and Abroad. The NRC will continue to improve upon its eff icient use of energy and water; however, given the investments already made to increase the efficiency of the buildings the NRC operates and maintains, there are few opportunities to significantly reduce energy and water consumption much further.