ML23131A190
| ML23131A190 | |
| Person / Time | |
|---|---|
| Issue date: | 05/26/2023 |
| From: | Dan Dorman NRC/EDO |
| To: | Mayock A Council on Environmental Quality |
| Shared Package | |
| ML23131A151 | List: |
| References | |
| SRM-OGC210219-3-ADM | |
| Download: ML23131A190 (4) | |
Text
Enclosure Fiscal Year 2023 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 directs 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 to be updated annually. The plan outlined below sets forth progress that the agency has made since the fiscal year (FY) 2022, Tackling the Climate Crisis at Home and Abroad, submission regarding its own facilities and operations, as opposed to the facilities owned and operated by its licensees. The U.S. Nuclear Regulatory Commission (NRC) is committed to maintaining awareness of the state of climate change science and to applying lessons to agency operations as appropriate and applicable. This document summarizes the NRCs progress on previous and future steps to its facilities and operations to 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 Action Plan.
Responsibility The Director in the Office of Administration is designated as the NRCs 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 civilian use of byproduct, source, and special nuclear materials, to ensure adequate protection of public 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 considered in licensing decisions related to natural hazards for a facility (e.g., external flooding from various flood-causing mechanisms such as storm surge, local intense precipitation, and 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 NRC 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 its own operations have on the environment. The NRC does not own or lease real property, nor does it manage public lands and waters. Each NRC facility is occupied via an Occupancy Agreement between the NRC and the General Services Administration (GSA). NRC does, however, have delegated authority through GSA to operate and maintain two of its headquarters buildings located in Rockville, MD
2 (One White Flint North (OWFN) and Two White Flint North (TWFN) respectively), and has done so since their construction in the early 1990s. In addition to the OWFN and TWFN buildings, the NRC has also made improvements to the Three White Flint North (3WFN) building, which is operated under a GSA lease on NRCs behalf. The NRC has successfully and progressively made significant investments over the last 15 years, as documented in the agencys FY 2022, Tackling the Climate Crisis at Home and Abroad, submission to reduce the energy consumption and water usage in both buildings. As a result, the agency has reduced water consumption by 44 percent as compared to 2012, and electric consumption has reduced by 64 percent as compared to 2012. The NRC continues to pursue more efficient ways of operating the buildings; however, due to the successes of the robust investments and upgrades already implemented, there are few opportunities to significantly reduce energy and water usage further, beyond the implementation of measures that the agency may take as it renovates OWFN on a floor-by-floor basis (pending available funding).
Electric Usage Mitigation Measures From 2012 to Present Since 2012, the agency has progressively implemented energy savings strategies, allowing the agency to exceed its reduction targets for energy intensity. The NRC continues to evaluate trends and identify other potential energy reduction measures for future efforts. Examples of energy saving strategies that have been implemented and have contributed to the reductions stated above include:
Progressive replacements of old equipment with newer high efficiency designs to the maximum extent practicable.
Upgrade of two floors of OWFN with more efficient building systems, including the improved LED lighting and controls, light harvesting, and other passive design features to optimize the use of natural lighting.
The NRC purchases 100 percent of its electricity from the Potomac Electric Power Company (Pepco), using a GSA areawide contract. As part of the contract, 20 percent of the electricity that the NRC uses comes from renewable energy sources. In FY 2023, this amounts to approximately 1,688,335 kilowatt hours of energy. Agera Energy provides this renewable energy to Pepco from wind resources in Texas.
As reported in the FY 2022 submission, 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 that demonstrate a predefined energy reduction strategy and agree to reduce their demand at times when the grid is under stress. There is strict compliance with GSA recommended building operation guidelines regarding space temperature and occupancy schedules. In FY 2019, the NRC installed meters in the uninterruptible power supply room and the data center of 3WFN to support its Data Center Infrastructure Management software. These meters are being used to create power usage effectiveness reports, which help determine the energy efficiency of the 3WFN data center.
3 Water Usage Mitigation Measures 2012 to Present Regarding the reduction of water usage, the NRC has implemented several water-saving strategies, as documented in the FY 2022 submission, and continues to evaluate water usage trends to identify other ways to reduce water consumption. Examples of the progress of water saving strategies that have been implemented from FY 2022 to present are primarily related to the floor-by-floor renovations in OWFN and are highlighted below:
Installation of a new filtered drinking water system with water fountains that have an integrated water-bottle filler.
Upgrade of high-flow restroom fixtures to more efficient low-flow fixtures to reduce the amount of water usage associated with wastewater.
The energy and water saving measures documented in the FY 2022 submission and additional implementations from FY 2022 to present have proven to be cost-effective. The NRC will continue to implement these measures as it renovates the OWFN building, as well as search for other new efficiencies and technologies that may further reduce consumption. Consistent with the reduction of energy and water usage, the agencys costs for electricity have been reduced by 64 percent and water costs by 44 percent as compared to 2012, despite the ever-increasing costs per unit for utilities.
For the illustration of financial risks per EO 14030, Subsection 5(d), Climate Action Plan, the table below contains the NRCs future funding needs to further reduce our impact on climate change.
FY 2024 NRC Request Goal Total Investment ($M)
Goal 1: 100 percent carbon free electricity by 2030
$0.35M Goal 2: Transition to a zero-emission vehicle fleet
$0 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 $1.78M, which includes 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 energy from renewable sources is not specified in the contract, 20 percent of $1.78M is $0.35M, as noted in the table above. The additional cost to achieve 100 percent carbon free electricity 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 costs, in coordination with GSA and Pepco, will be considered in future budget submissions.
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- 2) The NRC currently leases 25 vehicles from GSA, including vehicles for the Office of Inspector General and our regional offices. Some vehicles are hybrid, but none are fully electric vehicles. In FY 2023, an order was placed for one fully electric vehicle at a one-time additional cost of $12K. It is estimated that there will be an additional cost of
$0.5M to change the entire fleet to fully electric vehicles leased from GSA. This would also require an estimated additional $0.5M of infrastructure costs to install electric charging stations. The NRC is considering these additional costs, incrementally, in the FY 2025 budget submission and beyond.
- 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 replace the gas water heaters with electrical water heaters is $75K, and funding to do so has been requested through the FY 2025 budgetary process.
- 4) Current staffing and human capital is sufficient to ensure successful implementation of Federal sustainability goals and requirements. Therefore, no additional funding is being requested for this purpose.
Summary 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 remains committed to continuous reduction of its energy and water usage by incorporating efficient sustainability practices within its building operations and other applicable areas to build on the successful implementation of the measures already incorporated. Where possible, the agency will also initiate new efforts to reduce its environmental impacts. Given the investments already made to increase the efficiency of the buildings that the NRC operates and maintains as documented in the FY 2022 submission, there are few opportunities for progress that will significantly reduce energy and water consumption much further beyond upgrades associated with the renovations in OWFN.