NREL is a national laboratory of the U.S. Department of Energy, Office of Energy Efficiency

and Renewable Energy, operated by the Alliance for Sustainable Energy, LLC.

ENVIRONMENTAL PERFORMANCE

REPORT 2014 Annual Site Environmental Report per the

U.S. Department of Energy Order 231.1B
This report was prepared as an account of work sponsored by an agency of the United States government. Neither the United 

States government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any 

legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process 

disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, 

process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, 

recommendation, or favoring by the United States government or any agency thereof. The views and opinions of authors expressed 

herein do not necessarily state or reflect those of the United States government or any agency thereof.

Printed with a renewable-source ink on 100% recycled paper and 100% post consumer waste.

Cover Photo: Aerial view of the National Wind Technology Center (NWTC) and surrounding property.

Photo by Dennis Schroeder, NREL 30775
ENVIRONMENTAL PERFORMANCE REPORT 2014 1

This report requires a tremendous amount of data, 

collaboration, and review. Thank you to all who 

contributed their time and effort to this publication.

The National Renewable Energy Laboratory’s 

(NREL’s) Environment, Health, and Safety (EHS) 

Office staff provided their subject matter expertise 

by authoring content, providing data, and 

conducting technical reviews:

Brenda Beatty 

Genevieve Braus 

Larry Durbin 

John Eickhoff 

Bob Fiehweg 

Maureen Ray 

Tom Ryon

Kurt Schlomberg

Eric Schmitz

Frank Rukavina and the Sustainable NREL team 

provided the report’s sustainability content. Lissa 

Myers provided content for the Traffic Management 

section of the report.

Adrienne Elmore and Kathryn Ruckman with NREL’s 

Communications and Public Affairs Office provided 

project support and editing.

Lori Gray, Laura Margason, Lisa Jorgensen, 

Robert Smith, and Robin Sweeney, with the U.S. 

Department of Energy Golden Field Office, worked 

closely with staff of the Alliance for Sustainable 

Energy, LLC, to continuously improve the report and 

conducted the review and approval process.

ACKNOWLEDGEMENTS CONTACT US

We welcome your feedback and suggestions on this 

report and on NREL’s efforts toward sustainability and 

environmental stewardship. To provide comments, 

to request a printed copy of this report, or to obtain 

additional information about NREL’s environmental 

programs, please contact:

Maureen Ray

Director, Environment, Health, and Safety Office 

maureen.ray@nrel.gov

303-275-3248

John Eickhoff 

Environmental Manager 

john.eickhoff@nrel.gov 

303-275-3217 

Joe Chervenak

Acting Director, Communications & 

Public Affairs Office

joe.chervenak@nrel.gov

303-275-4029

This report is available online at:

www.nrel.gov/about/ehs.html

National Renewable Energy Laboratory 

15013 Denver West Parkway, Golden, CO 80401 

303-275-3000 

www.nrel.gov
2 ENVIRONMENTAL PERFORMANCE REPORT 2014

Acknowledgements............................................................................1

Contact Us...............................................................................................1

Nomenclature........................................................................................4

About NREL ............................................................................................4

Executive Summary.............................................................................5

1 Introduction......................................................................................9

1.1 Purpose.......................................................................................9

1.2 Our Mission ...............................................................................9

1.3 Site and Facility Description..............................................11

2 Significant Site Activities in 2014 ...........................................17

2.1 Construction Projects..........................................................17

2.2 Integrated Environmental Stewardship in 

Construction Management................................................18

3 Environmental Management System and

Pollution Prevention ...................................................................19

3.1 Environmental Management System Structure.........20

3.2 Pollution Prevention ............................................................21

3.3 Performance Indicators and Progress............................22

3.4 Assessment and Improvement ........................................22

3.5 2014 Awards and Recognition .........................................24

4 Sustainability .................................................................................27

4.1 Site Sustainability Planning...............................................28

4.2 2014 SSPP Goal Performance............................................29

4.3 Climate Change Adaptation Management..................32

5 Compliance Summary................................................................33

6 Air Quality Protection .................................................................42

TABLE OF CONTENTS

NREL Environmental Performance Report 2014

The 1 MW solar array at the National Wind Technology Center. It was installed in February of 2010. Photo by Dennis Schroeder, NREL 18660
ENVIRONMENTAL PERFORMANCE REPORT 2014 3

7 Water Quality Protection...........................................................45

7.1 Drinking Water.......................................................................45

7.2 Groundwater...........................................................................47

7.3 Surface Water..........................................................................47

7.4 Wastewater..............................................................................49

8 Hazardous Materials and Waste Management..................51

8.1 Hazardous Materials Management.................................51

8.2 Regulated Waste Management........................................53

8.3 Aboveground Storage Tank Management...................55

8.4 Spill Prevention and Response.........................................56

8.5 Radiological Materials and Waste Management........58

9 National Environmental Policy Act........................................60

10 Natural and Cultural Resources Protection.........................63

10.1 Wildlife Management........................................................63

10.2 Endangered Species and Species of Concern..........67

10.3 Vegetation Management.................................................68

10.4 Wetlands and Floodplains...............................................71

10.5 Cultural Resources..............................................................72

11 Conservation Easement Lands ...............................................75

12 Traffic Management....................................................................78

Appendix A: Plant Communities at the 

STM and the NWTC............................................................................81

Appendix B: Wildlife Species Observed at the

STM and the NWTC............................................................................88

Appendix C: Environmental Permits, Registrations,

and Notifications Applicable to NREL During 2014...............94
4 ENVIRONMENTAL PERFORMANCE REPORT 2014

NREL is the principal research laboratory for DOE’s 

Office of Energy Efficiency and Renewable Energy. 

The laboratory also conducts research for the Office 

of Science and the Office of Electricity Delivery and 

Energy Reliability. The laboratory is managed for 

the Office of Energy Efficiency and Renewable 

Energy by the Alliance for Sustainable Energy, LLC, 

a partnership between MRIGlobal and the Battelle 

Memorial Institute.

NREL is the only national laboratory solely dedicated 

to advancing renewable energy and energy 

efficiency technologies from concept to commercial 

application. The laboratory’s innovations, analysis, 

and expertise have enabled the emergence of a 

U.S. clean energy industry and led to numerous 

success stories from across the laboratory. NREL’s 

two campuses, the 327-acre South Table Mountain 

main campus in Golden, Colorado, and the 305-acre 

National Wind Technology Center in northern 

Jefferson County, are living models of sustainable 

energy integration.

NREL develops renewable energy and energy 

efficiency technologies and practices, advances 

related science and engineering, and transfers 

knowledge and innovations to address the nation’s 

energy and environmental goals. The laboratory’s 

research and development achievements have 

helped shape clean-energy alternatives for 

powering our homes and businesses, and the 

nation’s transportation infrastructure. NREL’s science 

and technology teams span the full spectrum of 

innovation, from fundamental science and marketrelevant research, to systems integration and testing 

and validation. 

NOMENCLATURE

ABOUT NREL

APCD – Air Pollution Control Division of CDPHE

APEN – Air Pollutant Emission Notice

AST – Aboveground Storage Tank

CCR – Colorado Code of Regulations

CDLE – Colorado Department of Labor and Employment 

CDPHE – Colorado Department of Public Health and Environment

CFR – Code of Federal Regulations 

CGI – Controllable Grid Interface 

CGP – Construction General Permit

CO2 – Carbon Dioxide

CO2e – Carbon Dioxide Equivalent

CRS – Colorado Revised Statute

CWA – Clean Water Act

CX – Categorical Exclusion

DERTF – Distributed Energy Research Test Facility

DOE – U.S. Department of Energy

DOE Order – Department of Energy Order

DOPS – Division of Oil and Public Safety of the Colorado 

Department of Labor and Employment

DWOP – Denver West Office Park

EA – Environmental Assessment

EERE – Energy Efficiency and Renewable Energy

EHS – Environment, Health, and Safety 

EIS – Environmental Impact Statement

EMS – Environmental management system

EPA – U.S. Environmental Protection Agency

EPCRA – Emergency Planning and Community Right-to-Know Act 

ESA – Endangered Species Act

ESIF – Energy Systems Integration Facility

EO – Executive Order

FTLB – Field Test Laboratory Building

FY – Fiscal Year

IBRF – Integrated Biorefinery Research Facility

ISO – International Organization for Standardization

MBTA – Migratory Bird Treaty Act

mrem – Millirem

MW – Megawatt 

NEPA – National Environmental Policy Act

NREL – National Renewable Energy Laboratory

NWTC – National Wind Technology Center

ODS – Ozone Depleting Substances

OTF – Outdoor Test Facility

PM – Particulate Matter

RFHP – Renewable Fuel Heating Plant

RSF – Reseach Support Facility

RTD – Regional Transportation District

SDS – Safety Data Sheet

SERF – Solar Energy Research Facility

SPCC – Spill Prevention Control and Countermeasures

SRRL – Solar Radiation Research Laboratory

SSP – Site Sustainability Plan

SSPP – Strategic Sustainability Performance Plan

S&TF – Science and Technology Facility

STL – Structural Testing Laboratory

STM – South Table Mountain

TTF – Thermal Test Facility

USACE – U.S. Army Corps of Engineers 

USFWS – U.S. Fish and Wildlife Service

VTIF – Vehicle Testing and Integration Facility

WQCD – Water Quality Control Division of CDPHE
ENVIRONMENTAL PERFORMANCE REPORT 2014 5

PURPOSE

The National Renewable Energy Laboratory’s (NREL’s) Environmental Performance Report provides a description of 

the laboratory’s environmental management activities for 

2014, including information on environmental and sustainability performance, environmental compliance activities 

and status, and environmental protection programs, highlights, and successes.

The purpose of this report is to ensure that the U.S. Department of Energy (DOE) and the public receive timely, 

accurate information about events that have affected or 

could adversely affect the health, safety, and security of 

the public or workers, the environment, or the operations 

of DOE facilities. This report meets the DOE requirements 

of the Annual Site Environmental Report and has been 

prepared in accordance with the DOE Order 231.1B Chg 1, 

Environment, Safety and Health Reporting. 

ENVIRONMENTAL AND 

SUSTAINABILITY PERFORMANCE

The laboratory is committed to environmental stewardship, pollution prevention, compliance with environmental 

requirements, and continual improvement in environmental protection and sustainability performance. NREL’s 

Environmental Management System implements a framework of policies, procedures, and programs that integrates 

environmental protection into daily work practices. The 

Environmental Management System is structured based on 

a plan-do-check-act continual improvement management 

model and is implemented as part of an Integrated Safety 

NREL hosts dignitaries from many countries. Management System.

Here, President of Iceland Olafur Grimsson (middle) 

experiences the Insight Collaboration Laboratory in 

the Energy Systems Integration Facility. Photo by 

Dennis Schroeder, NREL 24989

EXECUTIVE SUMMARY
6 ENVIRONMENTAL PERFORMANCE REPORT 2014

Each year, the laboratory sets measurable objectives and 

targets for environmental improvement through the NREL 

Environmental Management System planning process. 

Goals are established through the Performance Evaluation 

Measurement Plan and the Site Sustainability Plan. Progress 

of all goals is tracked throughout the year using an online 

software tracking system. A summary is prepared annually 

for the DOE Golden Field Office on Performance Evaluation 

Measurement Plan results and for DOE Headquarters on 

Site Sustainability Plan results. 

Sustainability is integral to both NREL’s research 

and operations, and the laboratory is committed to 

demonstrating federal leadership in sustainability and 

continuously improving performance. Sustainable NREL, 

an interdisciplinary initiative involving staff from across 

the organization, fosters environmental and social 

responsibility, working to establish NREL as a global model 

for sustainability.

Each year, Sustainable NREL develops a Site Sustainability 

Plan to report on steps taken to meet the national and 

DOE sustainability objectives and to outline plans for the 

upcoming year. The laboratory has currently identified 20 

objectives to enhance sustainability and continues to make 

significant progress toward these objectives.

During 2014, NREL continued its excellent record of 

environmental leadership and sustainability performance. 

The following are some of the laboratory’s key 

accomplishments:

■ Achieved key short-term internal environmental and 

sustainability goals, and made progress toward longterm goals (For more details, see sections 3 and 4.)

■ Received several awards and recognitions for environmental and sustainability accomplishments (see sidebar 

page 7)

■ Maintained International Organization for Standardization 14001:2004 environmental management system 

certification

■ Maintained Colorado Environmental Leadership 

Program Gold-Level Leader status, the highest level 

awarded by the state-sponsored program

■ Reduced the total area of impervious surfaces at the 

South Table Mountain campus by removing approximately 15,000 square feet of asphalt parking lot, increasing stormwater infiltration

■ Initiated climate resilience planning by identifying risks 

to NREL’s operations and mission as a result of climate 

change, and subsequently developed a method to 

analyze, compare, and rank those risks

■ Completed Site-Wide Environmental Assessments for 

both the South Table Mountain and National Wind 

Technology Center campuses that identify potential 

impacts to the human and natural environment relative to future master plans, thus allowing DOE to make 

informed campus management decisions as the laboratory continues to grow 

■ Completed a validation of accuracy of the site chemical 

inventory tracking system 

■ Added a window film visible to birds in order to prevent 

collisions with glass at the Energy Systems Integration 

Facility; shared the laboratory’s experience in reducing 

impacts to migratory birds within DOE and among other 

federal agencies

■ Partnered with industry in developing a prototype radar 

system capable of detecting large birds; ultimately this 

system is intended to provide wind operators with a 

means of early detection of avian species from which 

operational modifications can be made to reduce birdturbine strikes

■ Reduced impacts of employee commuting by supporting alternative work schedules, telecommuting, and 

alternative commuting options such as access to mass 

transit, vanpool discounts, preferred parking for carpool/

vanpool vehicles, ride-share coordination, and bicycle 

and pedestrian infrastructure. NREL researchers are using algae to develop alternative 

renewable fuels, capable of greatly decreasing greenhouse 

gas emissions. Photo by Christy Eschenfeldt, NREL 33208 
ENVIRONMENTAL PERFORMANCE REPORT 2014 7

ENVIRONMENTAL COMPLIANCE 

AND MONITORING

NREL is subject to many federal, state, and local environmental laws and regulations, as well as executive orders, 

DOE requirements, and agreements with government 

agencies. Unlike many other DOE facilities, NREL does 

not conduct work involving nuclear materials and does 

not have legacy radiological or other contamination 

issues associated with past nuclear weapons production 

or research activities; therefore, continuous radiation or 

radiological contamination monitoring is not conducted.

The laboratory continued its excellent record of environmental compliance in 2014. No violation notices were 

received from any regulatory agency and all required 

permits were received or renewed; required registrations 

were completed; and required notifications and reports 

were submitted. Actions were taken in two instances to 

correct circumstances that could lead to a violation.

NREL is committed to protecting wildlife on campus and 

workers are encouraged to notify staff biologists of 

New blades are being installed for testing on a 3MW wind turbine at NREL’s National Wind Technology Center. Photo by 

Lee Jay Fingersh, NREL 33210 

Prestigious Environmental 

Sustainability Awards Received

NREL received several important recognitions 

in 2014 for its environmental and sustainability 

accomplishments including:

■ A DOE Green Buy Program Gold Award 

for purchasing 13 products in six different 

categories, achieving DOE’s Green Buy 

leadership goal

■ Environmental Protection Agency Federal 

Green Challenge recognition both nationally 

and in Region 8 for green purchasing

■ A DOE Sustainability Award for Green IT 

Stewardship, for exemplary performance 

related to power management, sustainable 

electronics acquisition, and data center 

sustainability.
8 ENVIRONMENTAL PERFORMANCE REPORT 2014

situations that could impact wildlife. Reports of birds 

colliding with building windows at the Energy Systems 

Integration Facility resulted in retrofitting select windows 

with bird-visible markers. Inspections and feedback 

received during the three months following installation 

indicate no additional collisions have occurred. 

Environmental Management Programs

The laboratory continues to meet or exceed compliance 

requirements and strives to make continual improvements 

in environmental management. Major environmental 

program areas include:

■ Air quality protection, including air permitting, ozone 

depleting substance management, and greenhouse 

gas emissions monitoring

■ Water quality protection, including construction 

stormwater management, drinking water monitoring, 

and preventing unallowable sanitary sewer system 

discharges

■ Hazardous materials and waste management, including pollution prevention, spill response, proper storage, 

use, and disposal of hazardous chemicals and materials, as well as planning, permitting, and reporting 

regarding use and emissions of such materials

■ National Environmental Policy Act reviews

■ Natural and cultural resources protection, including 

wildlife, vegetation, protected species, wetlands, and 

cultural resources management.

The laboratory continued to improve its environmental 

management and performance in 2014. This was demonstrated by a track record of excellent compliance with 

regulatory requirements and established leadership in 

environmental and sustainability management.

NREL’s Continued International 

Organization for Standardization 

14001 Certification Demonstrates 

Commitment to Environmental 

Leadership 

In 2014, the laboratory maintained International 

Organization for Standardization 14001:2004 

certification of its environmental management 

system. A team of external auditors conducted 

an independent assessment of the policies, 

procedures, tools, and roles and responsibilities 

used in environmental management. The 

assessment verified that the laboratory 

continues to meet the requirements of the 

International Organization for Standardization 

14001 standard and demonstrates the 

laboratory’s commitment to environmental 

stewardship.
ENVIRONMENTAL PERFORMANCE REPORT 2014 9

1.1 PURPOSE 

This report presents a summary of the National Renewable Energy Laboratory’s (NREL’s) 2014 environmental 

management activities, including:

■ Environmental protection programs

■ Environmental and sustainability performance

■ Environmental compliance activities and status

■ Environmental management highlights and successes.

This report incorporates the U.S. Department of Energy’s 

(DOE’s) most recent guidelines for the Annual Site 

Environmental Report, as required by DOE Order 231.1B 

Admin. Chg. 1, Environment, Safety, and Health Reporting.

1.2 OUR MISSION 

NREL’s mission is focused on advancing the energy goals 

of DOE and our nation. This focus is captured in the 

mission statement: 

NREL develops renewable energy and energy efficiency 

technologies and practices, advances related science 

and engineering, and transfers knowledge and innovations to address the nation’s energy and environmental 

goals.

NREL fulfills its mission through technology portfolios. A 

brief description of each major technology area follows. 

■ Basic science–Fundamental research is conducted 

in the sciences that underlie renewable energy and 

energy efficient technologies. 

NREL scientists have enhanced a software tool used to 

simulate the motions of thousands of atoms. The research 

has led to a greater understanding of how molecular 

models work to further advance biofuels technology. 

Photo by Dennis Schroeder, NREL 24348

1

INTRODUCTION
10 ENVIRONMENTAL PERFORMANCE REPORT 2014

■ Bioenergy–NREL currently has major programs in 

biomass-derived fuels (biofuels) and biomass-derived 

electricity (biopower), and projects in biomass-derived 

chemicals and materials. 

■ Building energy–NREL supports research and 

development of technologies and practices for energy 

efficiency, working closely with the building industry 

and manufacturers; promotes energy and moneysaving opportunities to builders and consumers; 

and works with state and local regulatory groups to 

improve building codes and appliance standards.

■ Computational sciences–This area includes basic and 

applied research using high-performance computing 

and applied mathematics.

■ Distributed power–Distributed power draws upon 

small-scale power generation sources (e.g., photovoltaic cells/arrays and wind turbines) located close to 

where the electricity is used (e.g., a home or business) and therefore provides an alternative to or an 

enhancement of the traditional electric power grid. 

NREL participates in the development of technologies, market structures, and policies that affect the 

incorporation of renewable and energy efficiency 

technologies in distributed power systems.

■ Electricity technologies–Research is conducted to 

support electricity technologies that include renewable energy, hydrogen, and superconductivity technologies, as well as utility resources.

■ Energy analysis–Energy analysis at NREL is performed 

to inform policy and investment decisions as energyefficient and renewable energy technologies advance 

from concept to commercial application to market 

penetration.

■ Hydrogen–NREL is a leader in renewable hydrogen 

production technologies and the development of 

codes, standards, and advanced storage and sensors. 

Basic and applied research and material development 

using biology, physics, and chemistry enable and 

support the development of hydrogen production, 

storage, and end-use systems.

■ Measurements and testing–NREL laboratories and 

facilities allow state-of-the-art testing on photovoltaic 

cells, building technologies, and wind turbines. 

■ Photovoltaics–Photovoltaic cells enable the direct 

conversion of sunlight to electricity using solid-state 

materials. The National Center for Photovoltaics 

An NREL process engineer stirs a 1,450-liter fermentation vessel 

as part of biofuels research being conducted at the Integrated 

Biorefinery Research Facility. Photo by Dennis Schroeder, NREL 31690

Research being conducted at NREL’s Automated Home Energy 

Laboratory, housed at the Thermal Test Facility, seeks to identify the 

complex interactions of multiple household appliances with the 

power distribution grid, and ultimately determine convenient 

means for homeowners to save energy and money. Photo by 

Dennis Schroeder, NREL 20162 

Energy Systems Integration Facility researchers inspect the vanadium 

redox flow energy storage system, which is being tested to assess its 

ability to provide uninterrupted power supply from renewable energy 

sources. Photo by Dennis Schroeder, NREL 31367
ENVIRONMENTAL PERFORMANCE REPORT 2014 11

develops and deploys photovoltaic technology for the 

generation of electric power. 

■ Renewable energy resources–Researchers develop 

resource information for solar, wind, biomass, and 

geothermal energy applications. 

■ Renewable thermal technologies–Research is 

conducted in thermal technologies, including 

concentrating solar power, solar water heating, and 

geothermal heat and power, which generate power 

from heat or utilize heat from renewable resources.

■ Transportation–NREL works with industry experts 

to develop advanced vehicles and transportation 

systems. NREL also works with energy companies and 

manufacturers of vehicles and engines to develop 

advanced motor vehicle fuels for improved energy and 

environmental performance. 

■ Wind energy–Through the National Wind Technology 

Center, NREL develops, improves, and demonstrates 

the viability of wind technology for electricity 

generation and facilitates its utilization throughout 

the world.

1.3 SITE AND FACILITY DESCRIPTION 

NREL facilities occupy four separate locations in Jefferson 

County, Colorado, and one location in the City and County 

of Denver. These include:

■ National Wind Technology Center (NWTC)

■ South Table Mountain (STM) 

■ Denver West Office Park 

■ Joyce Street Facility 

■ Renewable Fuels and Lubricants Research Laboratory.

The STM and NWTC campuses are the two main sites 

where research operations are conducted; these will be 

addressed separately in the discussion of environmental 

features. The Denver West Office Park is leased space used 

primarily for administrative functions and limited research 

activities. The leased Joyce Street Facility space is primarily used for storage. The Renewable Fuels and Lubricants 

Research Laboratory facility is a leased research space 

that consists of a single vehicle high bay and small office 

area housed within the Regional Transportation District’s 

District Shops and Operations Center facility in Denver. 

Laboratory staff also conduct work at additional locations 

as needed; for example, at the Solar Technology Acceleration Center described below.

Climate

The climate for the geographic region of NREL operations is classified as semi-arid, typified by limited 

precipitation, low relative humidity, abundant sunshine, 

and large daily and seasonal temperature variations.

The area experiences moderate precipitation, with an 

average annual rainfall of less than 20 inches (50 centimeters [cm]). Almost half of the annual precipitation 

occurs from March to June. Summer showers contribute 33% of the annual precipitation total. Precipitation 

begins to decrease significantly in the fall, reaching the 

minimum during winter. Winter is the driest season, 

contributing less than 10% of the annual precipitation, 

primarily in the form of snowfall.

Spring is a season of unstable air masses with strong 

winds along the foothills and the Front Range. The 

highest average snowfall occurs in March, and the STM 

campus can generally expect to experience at least one 

heavy snowstorm with totals exceeding 6 to 10 inches 

(15 to 25 cm).

The solar radiation (sunlight energy) of the region is 

excellent for outdoor research and testing of solar 

energy conversion devices and systems. Sunshine is 

abundant throughout the year and remarkably consistent from month to month and season to season.

An NREL employee works in the hub of the wind turbine rotor 

installed on the Controls Advanced Research Turbine at the National 

Wind Technology Center. Photo by Lee Jay Fingersh, NREL 14902 
12 ENVIRONMENTAL PERFORMANCE REPORT 2014

South Table Mountain Campus 

The STM campus is the main research center for NREL—

nearly 80% of the laboratory’s staff have their offices and 

laboratories there. The STM campus is approximately 

two miles (3.2 kilometers [km]) east of Golden and 

12 miles (19.3 km) west of central Denver.

Land Use

The STM campus is a roughly triangular parcel of land 

occupying portions of the top, sides, and lower southfacing slopes of South Table Mountain, a mesa that stands 

approximately 492 feet (150 meters) above the adjacent 

lowlands. South Table Mountain is composed of sedimentary rocks below a basalt lava cap, which is quite resistant 

to erosion.

The STM site is a 327-acre (132 hectares) area predominantly bordered by open grassland zoned for recreation 

and light-commercial activity. Portions of the community 

of Pleasant View are located immediately to the south and 

west. Pleasant View has constructed a recreational park 

immediately south of the STM campus. Offices, shops, 

and a tree nursery owned by the Colorado State Forest 

Service are located at the far western edge. Undeveloped 

state land and a Colorado State Highway Patrol pursuit 

driver-training track are located along the northwestern 

boundary of the STM campus on top of the mesa. Jefferson County open space wraps around the northern and 

eastern edges of the site. Portions of the Denver West 

Office Park and apartment homes lie to the east.

More than half of the STM campus (177 acres / 72 hectares) has been set aside in a conservation easement. No 

development is allowed on that land, with the exception 

of some existing utility easements and recreational trails 

to be established by Jefferson County Open Space. 

(For more details, see section 11, Conservation 

Easement Lands.)

Geology, Soils, and Hydrogeology 

The mesa was formed as weak sedimentary rocks 

surrounding the lava were eroded away, leaving the 

lava-capped mesa in relief. Below the lava caprock, the 

sedimentary rocks are part of the Denver Formation that 

consists of layers and lenses of claystone, sandstone, 

and conglomerate. Sedimentary rocks of the Arapahoe 

Formation underlie the Denver Formation.

Both the Arapahoe and Denver Formations are considered to be aquifers in portions of the Denver Basin. The 

Denver Formation underlies the areas on which most 

NREL construction has taken place. Groundwater on the 

STM campus occurs primarily in the weathered and fractured silts and sands of the Denver Formation. There may 

also be some groundwater in the form of perched aquifers below the basaltic lava cap on South Table Mountain, 

and within the materials above the Denver Formation, 

which are largely the result of stream deposits. Groundwater flow on the site is in a southeasterly direction.

The soil covering the top of South Table Mountain is 

lavina loam. Loam is composed of a mixture of clay, sand, 

NREL’s South Table Mountain campus. Photo by Dennis Schroeder, NREL 30709 

South Entrance

Employee 

Parking

Café

RSF

STM Stormwater

Detention Basin

West Entrance

East Entrance

Education Center

Visitor Parking

ESIF

RFHP SERF

S&TF

IBRF

TTF

OTF

FTLB

VTIF

HighFlux 

Solar Furnace

Photovoltaic

Arrays SRRL
ENVIRONMENTAL PERFORMANCE REPORT 2014 13

silt, and organic matter. The loam on the mesa top is a 

shallow, well-drained clayey soil. Soil on the upper side 

slopes of South Table Mountain is also a loam consisting 

of extremely stony soils with significant amounts of clay. 

Much of the remainder of the site, including the area 

designated for major development, has a deep, welldrained soil referred to as Denver clay loam. It consists 

of clayey material containing some calcium carbonate. 

There are also two smaller soil areas on the southwestern 

portion of the site, both of similar character to other site 

soils—cobbly clay loam and very stony clay loam.

Surface Water 

About 90% of the surface drainage from the site, both 

from the mesa top and across the lower portions of the 

site, flows in a southerly direction toward Lena Gulch 

(a tributary of Clear Creek). While there is no permanent 

stream flow on the STM campus, occasional flow from 

extended periods of precipitation, usually during the 

late winter and early spring, is found in the drainage 

channels, with seasonal springs evident along some of 

the mesa slopes. There is one seep on the mesa top that 

is often active throughout much of the year, but the 

water infiltrates and evaporates quickly during the 

dry season.

Vegetation 

Two primary vegetation types are present on the STM 

campus: grasslands and shrublands. The most common 

plant communities on the STM campus are mixed grasslands, comprising more than 80% of the vegetation on 

the site. These communities are generally dominated 

by short- and mid-grass species. Two primary upland 

shrub communities occur on the STM campus: mountain 

mahogany shrublands, found on the shallow soils of the 

mesa, and upland shrublands, occurring in drainages 

lacking active channels as well as drainages with associated wetlands. Field surveys have identified limited 

wetland and riparian areas along drainages. The wetland 

communities identified on the STM campus are a minor 

component of the total vegetation cover, accounting for 

less than 1% of the vegetation over an area of less than 

0.3 hectares (0.75 acres). Riparian shrub communities also 

occur adjacent to the emergent wetlands. A vegetation 

survey of the STM campus was conducted in 2010. (For 

more details, see section 10.3, Vegetation Management.)

Wildlife 

Several comprehensive wildlife surveys have been 

conducted on the site, starting with the original study 

in 1987. Additional surveys were done in 1999 of the 

conservation easement property. Surveys to update 

existing data were completed in 2005 and in 2011. 

(For more details, see section 10.1, Wildlife Management.)

Mammals identified during the surveys included mule 

deer, coyotes, gray foxes, red foxes, raccoons, long-tailed 

weasels, striped and spotted skunks, badgers, bobcats, 

mountain lions, rabbits, yellow-bellied marmots, and various smaller mammals. More than 50 species of birds have 

been recorded on the STM campus by the formal wildlife 

surveys and supplemental employee observations. A 

number of raptor species have been recorded at or above 

the STM campus, especially during spring migration. Two 

raptor species are resident at the site: American kestrel 

(Falco sparverius) and red-tailed hawk (Buteo jamaicensis). 

Reptiles and amphibians inhabit the area as well. Most 

notably, the western rattlesnake is routinely encountered 

around the campus area.

National Wind Technology Center

The NWTC is the main facility for NREL’s wind turbine technology research. Located on the Jefferson-Boulder County 

border just east of the foothills of the Rocky Mountains, 

the NWTC has abundant wind resources that are critical 

for the variety of projects conducted at the site. The NWTC 

is located near the intersection of Highways 93 and 128, 

between Boulder and Golden, and is approximately 15 

miles (24.2 km) north of the STM campus.

Land Use 

The NWTC facility occupies a 305-acre (124-hectares) area 

surrounded largely by open space and grazing land. The 

Rocky Flats National Wildlife Refuge borders the NWTC 

to the southeast, and a sand and gravel mining and 

processing operation is located along the southern and 

western boundaries of the site. A blasting company also 

has a small installation along the western site boundary. 

Red-tailed hawk soaring over the South Table Mountain campus. 

Photo by Tom Ryon, NREL 33065
14 ENVIRONMENTAL PERFORMANCE REPORT 2014

State Highway 128 borders the NWTC to the north; 

Boulder County open space lies to the north of 

the highway.

Geology, Soils, and Hydrogeology 

The NWTC campus is located on a plain formed by stream 

deposits. The uppermost geological layer beneath the site 

is known as the Rocky Flats Alluvium. It is composed of 

cobbles, coarse gravel, sand, and gravelly clay. Below the 

Rocky Flats Alluvium are the Laramie Formation, Fox Hills 

Sandstone, and Pierre Shale. These rock formations consist 

primarily of claystones with some siltstones. Unconfined 

groundwater flow occurs in the Rocky Flats Alluvium 

toward the east/southeast, and small perched zones are 

common. Groundwater occurs as confined aquifers in the 

deeper bedrock formations.1

The NWTC has a strongly developed soil defined as a very 

cobbly, sandy loam. The soil is characterized by a large 

amount of cobble and gravel in the soil volume, and 

subsoil dominated by clay. 

Surface Water 

The area surrounding the NWTC campus is drained by five 

streams: Rock Creek, North Walnut Creek, South Walnut 

Creek, Woman Creek, and Coal Creek. Rock Creek flows 

eastward and is located southeast of the NWTC. North 

Walnut Creek and South Walnut Creek flow eastward into 

the Great Western Reservoir. Woman Creek drains eastward into Standley Lake. Coal Creek flows in a northeasterly direction across the City of Boulder Open Space north 

of the NWTC.

The majority of the NWTC drains into a tributary to Rock 

Creek. Some of the northern portions of the site drain into 

Coal Creek or its tributaries.

Vegetation 

The NWTC is located in the transition area between the 

Great Plains and the Rocky Mountains.2 This location 

results in a flora that contains elements from both mountain and prairie ecosystems, and associations that represent residual tallgrass prairie, shortgrass plains, ponderosa 

pine woodland, and foothill ravine flora.3

Vegetation surveys conducted at the site have identified 

271 vascular plant species and defined five major habitat types on the NWTC campus, including xeric mixed 

grasslands, pine woodlands, shrublands, wetlands, and 

disturbed areas.

Along the northwestern ridge is a ponderosa pine 

woodland area. Vegetation found in this area includes 

woody species with an understory of grasses, forbs, 

and shrubs. The most recent vegetation survey was 

completed in 2011. (For more details, see section 10.3, 

Vegetation Management.)

NREL’s National Wind Technology Center campus. Photo by Dennis Schroeder, NREL 30766

Building 251 Switch Gear 

Building

Grid Storage

Pads

Test Prep

Building

CGI

5 MW

Dynamometer

2.5 MW 

Dynamometer STL

Modal 

Lab DERTF A-60

1 EG&G Rocky Flats, Inc. (1992). Rocky Flats Plant Site Environmental Report, January Through December 1992. Golden, Colorado.

2 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, Colorado.

3 Ibid.
ENVIRONMENTAL PERFORMANCE REPORT 2014 15

Wildlife 

Prior to 1975, livestock heavily grazed the NWTC campus, 

damaging a majority of the native vegetation. DOE 

prepared a biological characterization inventory in 1992 

for the entire Rocky Flats plant, including the NWTC 

campus, which was part of the no-activity buffer zone of 

the Rocky Flats plant at the time. Signs or tracks of bears 

and mountain lions were identified. Other mammals 

known to feed at the site are mule deer, coyotes, desert 

cottontail rabbits, white-tailed jackrabbits, black-tailed 

jackrabbits, deer mice, prairie voles, and thirteen-lined 

ground squirrels. Approximately 20 different species of 

birds were sighted at or near the site. Raptor surveys were 

conducted at the NWTC in 1994 and 1995, and identified 

seven raptor species on or in the vicinity of the site. An 

avian survey was also completed in 2002 and updated in 

2011. (For more details, see section 10.1, Wildlife Management.) Although seldom seen, rattlesnakes, bull snakes, 

racers, and several other reptilian and amphibian species 

are known to occupy the area.

Denver West Office Park

The Denver West Office Park, located within the City 

of Lakewood approximately two miles (3.2 km) east of 

Golden and 12 miles (19.3 km) west of central Denver, is 

a relatively flat, landscaped office complex occupied by a 

number of four-story buildings, parking lots, and common 

areas. NREL-leased facilities at this location are situated 

approximately in the geographic center of the development. The Denver West Office Park is bordered on the 

south by commercial areas (West Colfax strip), and on the 

west by the Pleasant View residential area, Camp George 

West facility, and the STM campus. In addition to office 

spaces, activities at the Denver West Office Park include 

low-risk research related to fuel and battery characterization, thermal analyses of vehicle cooling loops, vehicle 

electrical systems analysis, and photo-electrochemical 

hydrogen production. 

Joyce Street Facility

The Joyce Street Facility is located in a commercial area 

surrounded by agricultural land, residential neighborhoods, and small businesses. It is currently used by NREL 

primarily as warehouse space; there are no staff offices at 

this location. The Joyce Street Facility is located at 6800 

Joyce Street, about 5.5 miles (8.9 km) north of Denver 

West Office Park and the STM campus.

Renewable Fuel and Lubricants 

Research Laboratory 

The Renewable Fuels and Lubricants Research Laboratory 

is used for research, testing, and support activities related 

to advanced fuels, engines, and vehicles to objectively 

evaluate performance, emissions, and energy efficiency 

impacts, including the evaluation and development of 

heavy-duty hybrid vehicles. The laboratory consists of a 

single vehicle high bay and small office area housed within 

the Regional Transportation District’s District Shops and 

Operations Center located at 1900 31st Street, Denver, 

approximately 12 miles (20 km) east of the STM campus. 

The District’s Shops and Operations Center facility occupies 

approximately 22 acres (9 hectares) of land and serves as 

the primary maintenance facility for the Regional Transportation System’s bus and light rail train systems. The 

area around the facility consists of commercial and light 

industrial development.

The site lies on relatively flat terrain with a slight gradient 

to the northwest. The general area is highly developed 

with concentrated industrial and commercial activities. 

Very little natural vegetated habitat exists on-site or in the 

immediate vicinity. There are trees and shrubs lining the 

South Platte River adjacent to the site’s southern, eastern, 

and northeastern borders.

Additional Locations 

■ Laboratory staff also conducts work at additional locations as needed. One such location is the Solar Technology Acceleration Center, operated by MRIGlobal, 

located near Denver International Airport, northeast 

of the intersection of East 26th Avenue and North 

Hudson Road in Aurora, Colorado. The Solar Technology Acceleration Center is a partnership of solar 

equipment manufacturers, research organizations, and 

electric utilities that want to make use of a real-world 

outdoor site to develop, test, validate, and showcase 

NREL researchers analyze micro-grid synchronization wave forms at 

the NWTC’s Distributed Energy Resources Test Facility to facilitate 

interconnection and grid integration of renewable energy sources. 

Photo by Dennis Schroeder, NREL 21937
16 ENVIRONMENTAL PERFORMANCE REPORT 2014

solar products. Approximately 33 miles (54 km) east 

of the STM campus, the 74-acre (30-hectare) facility provides users with readily accessible land and all 

the necessary infrastructure and resources needed 

to rapidly and economically install their technologies. NREL currently leases several acres at the site. 

The primary projects currently being conducted by 

NREL include:

■ Concentrating Photovoltaics Demonstration – 

This project, which was terminated in late 2014, 

demonstrated and quantitatively compared performance of concentrating photovoltaic systems installed 

in Japan and the United States. 

■ Thermal Energy Storage Test Facility – NREL used this 

facility to provide a pilot-scale demonstration project 

related to thermal storage. This facility has since been 

transferred to MRIGlobal, and NREL will have no further 

involvement. 

An NREL engineer monitors data from a test run on a chassis 

dynamometer in the control room at the Renewable Fuels 

and Lubricants Research Laboratory. Photo by Dennis Schroeder, 

NREL 22761
ENVIRONMENTAL PERFORMANCE REPORT 2014 17

■ Regional Test Center – This project continues to 

test photvoltaic technologies through partnerships 

with manufacturers.

In 2014, numerous minor construction projects were 

either begun, continued, or completed. From concept 

to design to completion, environmental and sustainable 

stewardship are integrated into the management of 

infrastructure and building projects.

2.1 CONSTRUCTION PROJECTS

A brief description of the significant projects undertaken 

on NREL campuses in 2014 is as follows:

STM Campus

■ The 15 megawatt (MW) electrical upgrade to the 

campus-wide electrical system was completed, which 

will provide 5 MW of additional electrical capacity 

required to support operation of the Energy Systems 

Integration Facility Data Center at full build out without taxing the power needed to support the rest of 

the campus. The project also connected the photovoltaic array system on the roof of the employee parking 

garage to the Xcel Energy power grid. 

■ Installation of the E85 fueling station was completed 

and is currently being used to fuel fleet and test vehicles. Use of E85 fuel in fleet vehicles reduces NREL’s 

overall greenhouse gas emissions.

■ The Hydrogen Fueling Station was moved from the 

NWTC to the STM campus to facilitate additional 

research currently being conducted at the Energy 

Systems Integration Facility. 

■ Exterior improvements at the Solar Energy 

Research Facility and the Science and Technology 

Facility began. Ultimately the project will provide 

enhanced pedestrian movement and outdoor 

collaboration spaces. 

2

SIGNIFICANT SITE

ACTIVITIES IN 2014

An NREL worker uses the newly installed E85 tank on the 

STM campus to fill an NREL On-Demand van. Photo by 

Dennis Schroeder, NREL 32161
18 ENVIRONMENTAL PERFORMANCE REPORT 2014

■ Improvements to the drainage swale that crosses 

Jefferson County Open Space property and that 

discharges to the stormwater detention basin were 

completed. The channel bottom stabilization as well 

as reseeded side slopes will reduce sediment delivery 

to the STM campus stormwater detention basin, thus 

decreasing the risk of sediment ultimately reaching Lena Gulch, the offsite water body to which the 

campus drains.

NWTC Campus

■ The 10 MW Electrical Storage/Controllable Grid 

Interface project was completed. This project allows 

manufacturers and system operators to test integration 

of utility-scale wind and solar generation technologies 

to the electrical power grid. 

■ Major roadway repairs were completed to address 

damage incurred during the 2013 100-year flood 

event. 

2.2 INTEGRATED ENVIRONMENTAL 

STEWARDSHIP IN CONSTRUCTION 

MANAGEMENT

NREL designs and builds new facilities using an approach 

that integrates planning, design, and construction. An 

interdisciplinary team collaborates on each project 

beginning with planning and selection of design, 

continuing through construction. This integrated 

approach allows the laboratory to achieve mission needs 

while addressing environmental, health, safety, and 

community considerations.

Project Planning and Design

Environmental staff participates in an interdisciplinary 

project management team from a project’s initiation, 

continuing through construction. This includes 

developing and reviewing scopes of work, facilitating 

the inclusion of environmental requirements and best 

management practices (such as bird-friendly windows) 

into project designs, and monitoring proposed changes 

throughout the project to confirm that potential 

environmental impacts are considered and addressed. 

Some of the 2014 projects that demonstrate the 

integration of environmental considerations in planning 

and design are: 

■ A highly engineered drainage swale intended to 

minimize erosion and offsite sedimentation while 

maintaining a natural appearance to hikers on a nearby 

park trail 

■ A custom-designed spill control gate to prevent fuel 

spills from entering the storm drain system

■ Design of landscaping improvements intended 

to increase wildlife habitat, promote stormwater 

infiltration, and minimize watering of vegetation.

Environmentally Responsible 

Construction Practices

During construction, DOE and NREL environmental staff 

participates in weekly construction team meetings, 

monitors performance criteria, and provides ongoing 

feedback to the project team regarding environmental 

management. Environmentally responsible construction 

practices include pre-construction review of project plans, 

performing nesting-bird surveys prior to commencing 

earth-disturbing activities, using a “plan of the day” 

to coordinate and control activities, implementation 

of stormwater controls prior to starting excavations, 

minimizing impacts to wildlife, tracking waste 

diversion, proper storage of hazardous materials, and 

controlling dust.
ENVIRONMENTAL PERFORMANCE REPORT 2014 19

NREL’s Environmental Management System (EMS) 

provides effective environmental stewardship and minimizes the environmental impacts of laboratory activities and operations. The EMS is a framework of policies, 

procedures, and programs that integrates environmental 

protection into daily work practices. The laboratory’s 

EMS efforts include:

■ Protection and enhancement of vegetation, wildlife, 

and natural resources of the laboratory sites

■ Pollution prevention

■ Compliance with environmental requirements

■ Encouragement of continual improvement in environmental protection and sustainability performance.

The laboratory strives to continually minimize waste and 

prevent pollution, thus reducing its environmental footprint. Pollution prevention is implemented through the 

laboratory’s EMS, the Hazard Identification and Control 

program, and the Sustainable NREL program.

Requirements

A federal Executive Order, EO 13423, Strengthening 

Federal Environmental, Energy, and Transportation 

Management, and DOE Order 436.1, Departmental 

Sustainability, require that the laboratory implement an 

EMS that conforms to the ISO 14001 structure. The EMS 

is implemented as part of a DOE-required Integrated 

Safety Management System, which systematically 

integrates safety and environmental protection into 

management and work practices at all levels to protect 

the public, the worker, and the environment. 

Additionally, EO 13514, Federal Leadership in 

Environmental, Energy, and Economic Performance,

together with the above-referenced executive and 

DOE orders, direct the laboratory to conserve natural 

3 

ENVIRONMENTAL

MANAGEMENT SYSTEM 

AND POLLUTION 

PREVENTION

Green purchasing at NREL includes office products made of 

recycled materials. Photo by Christina Chase, NREL 19796
20 ENVIRONMENTAL PERFORMANCE REPORT 2014

resources, reduce energy use, develop renewable energy, 

reduce greenhouse gas emissions, manage buildings 

and transportation in a sustainable manner, and support 

pollution prevention.

3.1 ENVIRONMENTAL MANAGEMENT 

SYSTEM STRUCTURE

The EMS is structured based on a plan-do-check-act 

continual improvement framework described below and 

depicted in Figure 1. 

Planning

■ Environmental policy – NREL states its commitments 

to the environment through this overarching policy. 

The policy commits specifically to:

● Environmental stewardship

● Pollution prevention 

● Compliance with legal requirements and 

voluntary commitments

● Continual improvement of environmental and 

sustainability performance.

■ Environmental aspects – NREL’s environmental 

aspects are those activities, products, or services that 

have the potential to interact with the environment. 

The significance of an identified aspect is determined 

by assigning a frequency of occurrence and a severity. 

Using this method, NREL’s EHS staff reviews potential 

impacts to the environment annually, and activities 

in the EMS are prioritized by the identified significant 

aspects. NREL also utilizes a robust hazard identification and control process as part of its Integrated Safety 

Management System to manage environmental risks.

■ Legal and other requirements – NREL maintains a 

formal process to identify regulations and standards 

that are necessary and sufficient to address specific 

environmental hazards, including federal laws and 

regulations, state and local requirements, executive 

orders (EOs), and DOE orders.

■ Objectives and targets – Regular planning of activities and programs are necessary to achieve NREL’s 

Define Scope

Analyze

H

a

zards,

Perform Work

Develop Controls

Feedback &

Improvement

Environment

Quality Safety

Impacts

& Issues

ISO 14001:2004 Certified

NREL’s EMS is certified to the International 

Organization for Standardization (ISO) 

14001:2004 standard for environmental 

management systems. ISO 14001 is a 

globally recognized standard that defines the 

structure of an organization’s EMS to improve 

its environmental performance. ISO 14001 

requires an organization to identify potential 

environmental impacts and establish controls 

needed to minimize impacts, to monitor and 

communicate environmental performance, and 

to establish a formal process for continually 

improving the system.

Figure 1. NREL’s continual improvement cycle.

NREL’s Environmental Aspects

NREL conducts an annual review of its activities 

that could potentially affect the environment. 

The laboratory’s significant environmental 

aspects for 2014 were:

■ Air emissions

■ Surface water and groundwater discharges

■ Wastewater releases

■ Waste generation and management

■ Resource use or conservation (energy, water, 

land, biological, cultural)

■ Community. 

Each of these aspects is addressed by the EMS.
ENVIRONMENTAL PERFORMANCE REPORT 2014 21

environmental goals. The EHS Office and Sustainable 

NREL plan, implement, monitor, and report on environmental stewardship goals and actions to generate 

continual improvement. (For more details, see section 

3.3, Performance Indicators and Progress.) 

Implementing

■ Structure and responsibility – NREL policies and 

procedures establish roles and responsibilities for environmental management within the organization.

■ Competence, training, and awareness – NREL verifies 

that workers are competent on the basis of education, 

training, or experience, and implements a robust environment, health, and safety training program.

■ Communication – NREL provides a number of avenues 

for communication between the laboratory and the 

community, such as community meetings, lunch-andlearn events, publically available websites, periodic 

newsletters, and community mailings. NREL tracks 

and responds to all environmentally related concerns 

through the Public Affairs Office. Internal communication regarding environmental issues is provided via 

intranet sites, newsletters, emails, meetings, posters, 

trainings, and personal interaction with EHS staff.

■ Operational control – NREL plans and manages operations and activities in line with its environmental policy 

and objectives. Staff continually identifies and reviews 

activities that could impact the environment, and engineering and administrative controls are put in place to 

minimize or avoid impacts to the environment.

■ Document and record control – Policies and procedures ensure that the current, correct versions of 

documents are available for use and that records are 

maintained to meet requirements.

Checking and Corrective Action

■ Monitoring, measuring, and evaluating compliance – 

NREL monitors key activities, tracks performance 

and progress toward environmental objectives, and 

conducts periodic assessments of compliance with 

legal requirements.

■ Internal assessment – NREL periodically conducts 

assessments to verify that its EMS is operating as 

intended. A formal system for tracking corrective and 

preventive actions supports continual improvement of 

the management system. (For more details, see section 

3.4, Assessment and Improvement.)

Management Review

■ Management Review – NREL conducts regular 

management reviews of the EMS so that executive 

management can provide feedback and direction to 

the environmental management of the organization.

3.2 POLLUTION PREVENTION

NREL has made a formal commitment to pollution prevention through its laboratory-wide environmental policy. 

NREL fulfills this commitment by implementing a variety 

of controls to reduce the potential environmental impacts 

of laboratory operations. These operations include NREL’s 

use and storage of chemicals and fuels, as well as laboratory activities such as employee commuting and travel, 

and energy and water use. NREL’s hazard identification 

and control process helps staff regularly identify opportunities to prevent pollution, and formal pollution prevention assessments are conducted periodically to identify 

opportunities to reduce pollution and improve program 

effectiveness. In addition, resources are dedicated for 

sustainable operations and pollution prevention through 

the Sustainable NREL program. While the majority of 

NREL’s environmental management programs were established to meet compliance requirements, many of these 

programs go beyond compliance requirements, continually improving environmental performance. 

Management and Reduction 

of Regulated Refrigerants 

Certain refrigerants and other chemicals are more highly 

regulated than others due to their ability to damage the 

Earth’s protective ozone layer. NREL’s Ozone-Depleting 

Substances (ODS) management program provides guidance for the management of refrigerants used at NREL, as 

well as the substitution and reduction of regulated refrigerants when possible. (For more details, see section 6, 

An EHS staff member leads a nature walk on the mesa top for NREL 

employees as part of Earth Week and Bring-Your-Child-To-Work Day 

activities. Photo by Dennis Schroeder, NREL 29860
22 ENVIRONMENTAL PERFORMANCE REPORT 2014

Air Quality Protection.) The policies used to reduce regulated refrigerant use and limit their releases include: 

■ Regular monitoring of the availability of acceptable 

substitutes for regulated refrigerants 

■ Purchasing prohibition of any new refrigeration equipment using an ODS refrigerant

■ Evaluation of proposed research activities to determine 

if any refrigerants used are ODS, and if so, investigation 

into the use of an EPA-approved alternative

■ Strict adherence to requirements for ODS equipment 

refrigerant recovery, leak detection, and repair to minimize ODS emissions

■ Where feasible, removal of ODS refrigeration equipment and recycling of the refrigerant.

3.3 PERFORMANCE INDICATORS 

AND PROGRESS

Each year measurable goals for environmental improvement are set. Goals are set through the following:

■ Performance Evaluation Measurement Plan – 

DOE requires every national laboratory to develop 

performance goals through a Performance Evaluation 

Measurement Plan. Each fiscal year, in collaboration 

with the DOE Golden Field Office, NREL’s performance 

objectives are developed to enhance the function and 

compliance of laboratory activities.

■ Site Sustainability Plan – Sustainable NREL develops a 

Site Sustainability Plan each year to establish sustainability performance commitments for the year and 

document activities in support of EO 13514, Federal 

Leadership in Environmental, Energy, and Economic 

Performance requirements. Results of the plan are 

presented in the next chapter of this report.

Goals are owned by individuals and groups throughout 

the laboratory. Progress on each of these goals is tracked 

throughout the year and results are reported annually. 

Some examples of performance for the year are described 

in Table 1.

 3.4 ASSESSMENT AND IMPROVEMENT

Assessments support the continual improvement of 

environmental management. Periodic assessment of the 

EMS and its components provides assurance that the EMS 

continues to be an effective tool to achieve and maintain 

compliance with regulatory and legal requirements, meet 

the established environmental goals of the laboratory, and 

demonstrate to ourselves and others that NREL is “walking 

the talk.” Internal and external assessments are performed 

to evaluate the functionality of NREL’s EMS.

■ Internal assessment – Staff performs regular internal 

assessments to evaluate consistency of the EMS with 

the ISO 14001 standard, legal, and other requirements.

■ External assessment – Periodically, external third-party 

assessments may be conducted by technical experts 

for specific components of environmental programs as 

part of continual improvement efforts. Annual surveillance assessments and triennial recertification assessments are conducted for the EMS as a whole to maintain ISO certification. 

Improvements are developed and implemented as necessary based on the results of each assessment performed.

2014 Assessments

In 2014, a number of assessments were conducted that 

allowed NREL to improve program effectiveness and make 

substantial environmental performance improvements.

The following assessment activities took place in 2014:

Reducing Pollution

Examples of positive impacts of reducing 

pollution from NREL’s activities include:

■ Replacing toxic chemicals with safer alternatives where possible to reduce potential 

exposure to employees, the public, and 

local ecosystems

■ Choosing bio-based and recycled-content 

products to reduce impacts on natural 

systems

■ Encouraging employees to telecommute, take alternative transportation, and 

supporting Web-based meetings to reduce 

traffic, air pollution, and health effects on 

surrounding communities

■ Using sustainable, low-energy, and lowwater use designs for buildings to reduce 

greenhouse gas emissions and use of Colorado’s limited water supplies.
ENVIRONMENTAL PERFORMANCE REPORT 2014 23

■ Internal assessments – An internal assessment was 

conducted of the laboratory’s National Environmental Policy Act Program. Scheduled interviews were 

conducted, and reviews of relevant procedures and 

records were completed. Eight non-conformities and 

six opportunities for improvement were identified; 

implementation of solutions and improvements are 

currently in progress.

■ External assessments – NREL was recertified under 

ISO 14001. The assessment was conducted by a team 

of external auditors and included visits to a sampling 

of the lab’s facilities, interviews with staff at all levels 

of the organization, observations of processes in 

place, and reviews of documents and records. The 

assessment resulted in five findings and several 

opportunities for improvement. Corrective actions are 

underway to address deficiencies regarding training 

documentation and completion rates, labeling, record 

control, and environmental policy communication. 

TABLE 1. 2014 ENVIRONMENTAL GOALS AND ACHIEVEMENTS

2014 Goals 2014 Examples Goal Met?

Integrate environmental 

planning to effectively 

contribute to the 

execution of NREL 

programs and projects by 

ensuring environmental 

requirements are met in a 

timely manner.

Enhanced the capital project process workflow and supporting documentation to identify 

and include a discrete environmental review of proposed projects

Revised the Five-Year Plan and Ten-Year Plan review cycles to incorporate an 

environmental review step

Environment staff participated in monthly campus project meetings to review 

environmental planning and the status of current projects.

Yes

Actively identify potential 

EHS risks and modify 

practices accordingly.

Improved spill response readiness by deploying additional spill response materials in 

various locations around campus 

Developed “Standard Erosion and Sedimentation Control Notes” that must be added to 

all construction designs and drawings that involve earth disturbance

Identified and addressed EHS considerations related to the NREL/CU-Boulder lease 

development, including National Environmental Policy Act requirements, operational 

activities, and environmental and safety liabilities.

Yes

Demonstrate continuous 

improvement of ISO 14001 

and OSHAS 18001 

management systems. 

Completed third-party recertification audit that verified the laboratory’s continued 

conformance with the ISO 14001 and Occupational Health & Safety Advisory Services 

(OHSAS) 18001 management system standards

Completed corrective actions and opportunities for improvement from the prior year ISO/

OHSAS surveillance audit

Completed an internal audit of the National Environmental Policy Act Program

Improved completion rates for EHS trainings by:

■ Sending monthly training reports to line managers

■ Developing and implementing effective metrics and oversight

■ Reviewing training completion status on a quarterly basis

■ Providing automatic notifications to workers regarding upcoming and 

overdue trainings.

Yes
24 ENVIRONMENTAL PERFORMANCE REPORT 2014

3.5 2014 AWARDS AND RECOGNITION

In 2014, NREL received several awards and recognition 

of its environmental and sustainability achievements 

including:

■ DOE Green Buy Program Gold Award

■ DOE Sustainability Award 

■ Federal Green Challenge Award

■ Colorado Environmental Leadership Program GoldLevel Leader.

DOE Green Buy Program Gold Award

NREL received the gold-level DOE GreenBuy Award for 

achieving excellence in sustainable acquisition. This is the 

third year in a row that NREL has received the gold-level 

recognition. To achieve this award, NREL met the goals for 

13 product types in six different categories. 

DOE Sustainability Award 

NREL received the DOE Sustainability Award for “Green IT 

Stewardship,” which recognizes exemplary performance 

in implementing Green IT (Information Technology), 

including power management, sustainable electronics 

acquisition, and data center sustainability. DOE Sustainability Awards recognize teams and individuals for their 

outstanding contributions to the DOE’s sustainability 

mission, including accomplishments in managing pollution, waste, energy, water, and vehicle fleets.

Federal Green Challenge Award

NREL received the EPA Region 8 Federal Green Challenge 

Award for “Overall Achievement” in sustainability performance. The Federal Green Challenge recognizes efforts 

to advance sustainability and leadership in reducing the 

environmental footprint of federal government activities.

Colorado Environmental Leadership 

Program Gold-Level Leader

NREL maintained its status as a Colorado Environmental 

Leadership Program Gold-Level Leader, the highest level 

awarded by the program. The Colorado Environmental 

Leadership Program is a voluntary partnership 

between the Colorado Department of Public Health 

and Environment and participating private and public 

2014 Accomplishments and Highlights

■ NREL was successfully recertified to the ISO 

14001:2004 standard. A team of external 

auditors conducted an independent assessment of the policies, procedures, tools, and 

roles and responsibilities used in environmental management. The assessment verified 

that the laboratory continues to meet the 

requirements of the ISO 14001 standard and 

demonstrates our commitment to environmental stewardship.

■ The laboratory continued to enhance the 

integration of environmental considerations 

into planning processes.

■ An internal assessment of the National Environmental Policy Act Program was conducted, identifying several areas for continual 

improvement. (For more details, see section 

3.4, Assessment and Improvement.)

An NREL researcher cleans individual photovoltaic cells at the 

Outdoor Test Facility to measure the variance in performance 

between an uncleaned cell and a cell cleaned daily of dirt and 

pollutants. Photo by Dennis Schroeder, NREL 21326

Figure 2. NREL maintained its Colorado Environmental Leadership 

Program Gold Leader status.
ENVIRONMENTAL PERFORMANCE REPORT 2014 25

Reduced risk to facility/organizational mission

NREL’s Hazard Identification and Control Program 

incorporates environmental risk assessment. System 

improvements also support reduced risk of non-compliance 

with requirements and reduced risk of potential 

enforcement actions. For example, due to management 

system improvements, EHS training completion rates have 

risen from 86% a year ago to 94% today.

Improved fiscal efficiency and/or cost avoidance

Cost savings are realized through energy efficiency projects, 

new renewable energy installations, waste reduction and 

recycling, and reduced environmental incidents such as spills.

Greater understanding and recognition 

of environmental issues at all levels of the 

organization

Staff are made aware of the potential environmental 

impacts from their work activities through the NREL Now

internal newsletter; postings on the NREL intranet; new 

employee orientation and activity-specific trainings; 

policies and procedures; management communications; 

Sustainable NREL communications; and special events such 

as Staff Awards (an annual employee recognition event), 

Earth Day, and Bike 2 Work Day. Improved awareness of 

environmental issues supports environmental performance 

throughout the lab.

Empowerment of individuals to contribute to the 

betterment of the organization’s environmental 

footprint

Staff are empowered to reduce the lab’s environmental 

footprint by participating in programs and events for 

recycling single-stream materials, batteries, electronic 

equipment, and shredded paper, as well as a composting 

program. 

Integration of environment into organizational 

culture and operations

NREL strives to maintain a high level of awareness in the 

laboratory around safety, health, and environmental 

responsibilities. This is supported through regular 

communications from executive management, trainings, 

inspections, and risk assessments.

Integration of environment into real property 

asset management

NREL includes environmental considerations into long-term 

planning for the STM and NWTC campuses. Long-term site 

plans consider wildlife movement across campus, surface 

water management, and climate change impacts.

Improved community relations

The laboratory works to improve community relations 

by responding to and tracking all community input 

through phone calls, email, community meetings, and 

soliciting feedback from stakeholders through the National 

Environmental Policy Act process. NREL takes proactive 

measures to engage the community with public tours, 

newsletters, and mailings to neighborhoods surrounding 

its facilities.

Improved effectiveness in overall mission

NREL’s EMS supports the organization’s overall mission 

and improves effectiveness by systematically addressing 

environmental opportunities and risks, ensuring 

compliance with regulations, and implementing voluntary 

commitments to achieve superior performance.

Improved collaborative conversation with 

other groups

The laboratory actively works in collaborating with 

stakeholders on environmental issues, such as 

sustainability, renewable energy, and resource conservation 

and management. This includes cooperating with 

other agencies in controlling noxious weeds and the 

management of conservation areas. Additionally, NREL 

is a member of the West Environmental Sustainability 

Team, a partnership that provides outreach and resources 

to help the community save energy, conserve resources, 

use environmentally friendly products, and practice 

sustainability. More information is available at: http://www.

lakewood.org/getgreen/.

Benefits of the EMS to NREL

Colorado facilities, and is intended to recognize 

environmental leadership and performance.

In early 2004, NREL was the first laboratory accepted into 

the program as a Gold-Level Leader and has maintained 

this leadership level ever since. As a component of the 

program membership, the laboratory’s voluntary environmental performance goals, described above, further 

enhance operations and performance at the laboratory. 

Colorado Environmental Leadership Program recognizes 

facilities that voluntarily:

■ Exceed regulatory requirements

■ Implement EMS (which focuses on incorporating 

environmental considerations into normal 

management processes and improving internal 

environmental management effectiveness)

■ Work closely with their communities

■ Establish three-year goals focusing on measurable results.

■ Learn more about this voluntary program at the state 

website https://www.colorado.gov/pacific/cdphe/

environmental-leadership-program.
26 ENVIRONMENTAL PERFORMANCE REPORT 2014

Improved overall compliance management

NREL maintains a formal process to identify regulations 

and standards applicable to NREL, including federal laws 

and regulations, state and local requirements, executive 

orders, and DOE orders. In addition, compliance with 

these requirements is regularly reviewed through a 

variety of mechanisms, including internal assessments, 

inspections, and monitoring.

Personnel health and safety

Continually improving environmental, safety, and 

quality management helps make NREL a safer, more 

environmentally responsible workplace and enhances 

the quality of our work processes.

Pollution prevention

Staff regularly identifies opportunities to prevent 

pollution through NREL’s hazard identification and 

control process. Resources are dedicated for sustainable 

operations and pollution prevention through the 

laboratory’s sustainability program.

Improved air and water quality

The EMS goals relating to the use of alternative 

energy sources, the use of clean burning fuels, and 

the minimization of the quantity of chemicals used on 

campus contribute toward improved air quality. Through 

refinement and implementation of requirements related 

to the management of runoff, operations, and outdoor 

storage/use of materials at both temporary construction 

sites and throughout campus grounds, NREL continually 

strives to protect water quality on site and offsite. 

Improved hazardous material, hazardous waste, 

and solid waste management

Hazardous material tracking through the NREL chemical 

inventory reduces the purchase of new supplies by 

allowing staff to determine if a needed chemical already 

exists on campus. This in turn minimizes the generation 

of hazardous waste. The laboratory has averaged above 

a 75% landfill diversion rate for solid waste for several 

years, greatly exceeding DOE goals for waste diversion.

Improved conservation of water, natural 

resources, energy in facilities, fuel in vehicles

The laboratory sets goals for water, energy, and fuel 

usage annually and monitors progress toward each 

throughout the year. 

Reduced number of permits needed to operate

Implementation of the EMS provides a mechanism to 

identify, evaluate, and implement pollution prevention 

opportunities including waste minimization, product 

substitution, and process modification. These efforts can 

reduce the number of regulatory requirements that the 

laboratory must meet.

Benefits of the EMS to the Environment 
ENVIRONMENTAL PERFORMANCE REPORT 2014 27

Sustainable NREL is a long-standing laboratory program 

that fosters environmental and social responsibility, 

working to establish the lab as a global model for 

sustainability. The program executes specific goals to 

reduce impacts on the community and environment, 

and provides technical expertise to organizations within 

the lab. Sustainable NREL provides leadership within 

the federal government and the community by actively 

mentoring and collaborating with other organizations to 

move sustainability into a new paradigm. NREL’s campus 

is a living laboratory that showcases new technologies, 

design practices, and operating behaviors. In all campus 

development, opportunities to integrate energy 

efficiency and renewable energy, high-performance 

buildings, and sustainable transportation options are 

sought. On-site deployment of technologies developed 

by NREL researchers is also emphasized. 

NREL integrates sustainability into its Environmental 

Management System. Technical experts from Sustainable NREL and the EHS Office work together regularly to 

improve operations and implement programs, including:

■ Site sustainability and pollution prevention data 

tracking and reporting to DOE

■ Sustainability and environmental management 

planning

■ Measurement and tracking of environmental 

objectives, targets, and actions

■ Awareness and engagement of staff and community 

members.

Planning is also underway related to the management of 

future impacts to the laboratory and laboratory operations as a result of climate change. Sustainable NREL is 

leading this effort with involvement of staff throughout 

NREL and selected external stakeholders. 

4 

SUSTAINABILITY

Solar panels on the Research Support Facility. 

Photo by Dennis Schroeder, NREL 31139 
28 ENVIRONMENTAL PERFORMANCE REPORT 2014

Requirements

A federal order, EO 13514, Federal Leadership in Environmental, Energy, and Economic Performance, specifies 

environmental sustainability performance goals for federal 

agencies. In addition, DOE Order 436.1, Departmental 

Sustainability, requires DOE facilities to prepare and implement an annual Site Sustainability Plan (SSP). Each site’s 

plan is used to report on steps taken to meet the sustainability objectives of the executive and DOE orders and also 

outlines plans for the upcoming year.

Two executive orders and a DOE guidance document 

provide direction to NREL as to efforts that must be taken 

to prepare for potential risks to its operations resulting 

from climate change. EO 13514, Federal Leadership in 

Environmental, Energy and Economic Performance, issued 

in 2009, is intended to develop an integrated strategy of 

sustainability within the federal government. The executive 

order requires each federal agency to identify and evaluate 

the potential risks and vulnerabilities to their mission and 

operations resulting from climate change. The Council on 

Environmental Quality prepared a progress report in 2010 

that recommended that each federal agency develop a 

climate adaptation plan that identifies aspects of climate 

change likely to impact the agency’s ability to achieve 

its mission. Guidelines issued in 2011 by the Council on 

Environmental directed agencies to prepare their plans by 

June 4, 2012. 

EO 13653, Preparing the United States for the Impacts of 

Climate Change, issued in 2013, further focused these 

plans by requiring each agency to continue to develop, 

implement, and update comprehensive plans that 

integrate consideration of climate change into agency 

operations and overall mission objectives. The executive 

order defines the required contents of the plan, which 

include risk identification, policies/programs, and plans 

already in place to manage climate risk; how the agency 

will improve climate adaptation and resilience (including 

the costs and benefits of those improvements); and 

interagency coordination efforts. These plans are to be 

approved by the Council on Environmental Quality and 

Office of Management and Budget and updated annually. 

DOE issued its first agency-wide climate action plan in 

2012 as an addendum to the 2011 Strategic Sustainability 

Performance Plan (SSPP). 

Recent guidance from DOE requires that DOE sites, including NREL, determine climate change-related risks and build 

climate change resilience within their operations. Sites are 

required to describe current and ongoing efforts to identify and assess climate related impacts and the work being 

done to build climate change resilience capacity among 

site personnel. To support this requirement and as part of 

a pilot project for DOE’s Sustainability Performance Office, 

NREL is undergoing a formal climate-change vulnerability 

assessment and resilience planning effort. This assessment 

and planning effort aims to develop a replicable process 

that could be used at other DOE sites.

4.1 SITE SUSTAINABILITY PLANNING

The following content, which describes NREL’s site sustainability planning efforts, has been extracted from NREL’s SSP 

for Fiscal Year (FY) 2015. The full report is located online. 

Download at: http://www.nrel.gov/docs/fy15osti/63257.pdf.

An NREL employee completes a blade inspection of a 3MW wind turbine at the NWTC campus. Photo by Dennis Schroeder, NREL 27198
ENVIRONMENTAL PERFORMANCE REPORT 2014 29

Site Management Vision

As the nation’s only federal laboratory dedicated to the 

research, development, commercialization, and deployment of renewable energy and energy efficiency, NREL 

takes sustainability seriously. While implementing its 

mission to advance the science and technologies needed 

for energy security and economic prosperity in the nation, 

NREL strives to operate its facilities as a model of environmental sustainability. The laboratory uses an integrated 

management approach, including engineering, administrative controls, and behavior change to facilitate sustainability across the laboratory as a whole. 

Planning

Since 2008, the baseline year used for DOE’s greenhouse 

gas reduction goal, NREL has seen a substantial expansion 

in both population and square footage on its campus—

a 95% increase in population and a 147% increase in 

campus footprint. This growth has allowed NREL to move 

its mission forward; it has also required innovation and 

creative thinking to overcome the resulting challenges to 

meeting sustainability goals on campus. 

Sustainability planning efforts in FY 2014 included: 

■ Continued execution of the Campus Master Plan, which 

includes established policies that promote sustainable 

design, operations, and maintenance practices 

■ Developed a Greenhouse Gas Reduction Plan, which will 

be finalized and implemented in FY 2015 

■ Continued work on a Strategic Energy Management 

Plan, to be finalized in FY 2015 

■ Participated in stakeholder planning efforts with the 

Regional Transportation District, Jefferson County, 

and other regional partners to improve local land use 

decisions and transportation facilities that support 

sustainability

■ Updated the Fleet Management Plan 

■ Updated the Water Management Plan, to be finalized in 

FY 2015 

■ Implemented a Landscape Maintenance Plan, which 

was developed as part of the Sustainable Sites Initiative 

program 

■ Created an On-Site Renewables Master Plan 

■ Developed a Climate Change Resilience Plan, initiated in 

FY 2014, to be finalized in FY 2015. 

These planning efforts continue to reveal the technologies, 

design ideas, behavior changes, and outreach goals that 

help NREL meet its sustainability goals.

4.2 2014 STRATEGIC SUSTAINABILITY 

PERFORMANCE PLAN GOAL 

PERFORMANCE

Table 2 summarizes each of DOE’s SSPP goals and NREL’s 

performance status. For more specific information, please 

refer to the full SSP referenced above.

NREL employees check out some electric and hybrid vehicles owned 

by fellow NREL employees as part of Earth Day events at NREL. Photo 

by Dennis Schroeder, NREL 29890

2014 Accomplishments and Highlights 

■ NREL was recognized with several prestigious 

awards that acknowledged the laboratory’s 

exemplary performance in sustainability. (For 

more details, see section 3, Environmental 

Management System and Pollution 

Prevention.)

■ The Renewable Fuel Heat Plant, which is a 

wood-fired boiler system that supplies heat 

to major STM campus buildings, provided 

33% of all space heating through use of 

reclaimed wood such as beetle kill pine and 

sawmill residue. The displaced natural gas 

reduced NREL’s greenhouse gas emissions 

by 20%. 

■ The Leadership in Energy & Environmental 

Design (LEED) Platinum-rated Research 

Support Facility met its goals for operating 

one full year at net-zero energy from April 

2013 through April 2014.
30 ENVIRONMENTAL PERFORMANCE REPORT 2014

TABLE 2. SSPP PERFORMANCE SUMMARY

SSPP 

Goal # DOE SSPP Goal NREL Performance Status in FY 2014 Status

1.1 28% greenhouse gas reduction from sources such 

as heating, cooling, and electricity use by FY 2020 

from a FY 2008 baseline

Emissions from energy use decreased 84% from the FY 

2008 baseline.

 On 

Track

1.2 13% greenhouse gas reduction from sources such 

as air travel and commuting by FY 2020 from a FY 

2008 baseline 

Emissions from sources such as air travel and commuting 

decreased 14% from the FY 2008 baseline.

On 

Track

2.1 30% building energy use per square foot (energy 

intensity) reduction by FY 2015 from a FY 2003 

baseline 

Energy intensity reduced 54% from the FY 2003 baseline. On 

Track

2.2 Perform energy and water audits of 75% of covered 

buildings during a 4-year cycle

Audited 91% of covered facilities during the current 

4-year cycle.

On 

Track

2.3 Individual buildings metering for 90% of electricity 

(by October 1, 2012); for 90% of steam, natural gas, 

and chilled water (by October 1, 2015)

100% of buildings have energy meters, chilled water

meters, and hot water meters. No steam is used for 

comfort heating.

On 

Track

2.4 Energy efficient cool roofs, unless uneconomical, 

for roof replacements 

Cool roofs make up 69% of roof areas. On 

Track

2.5 15% of existing buildings that are greater than 

5,000 gross square feet are compliant with the 

Guiding Principles of High Performance Sustainable 

Buildings by FY 2015

18% of existing buildings (4 out of 22 buildings) are 

compliant with the Guiding Principles of High Performance 

Sustainable Buildings.

On 

Track

2.6 All new construction, major renovations, and 

alterations of buildings greater than 5,000 gross 

square feet must comply with the Guiding 

Principles of High Performance Sustainable 

Buildings 

All new construction complied with the Guiding Principles 

of High Performance Sustainable Buildings.

On 

Track

2.7 Increase regional and local planning coordination 

and involvement

Coordinated with Denver Regional Council of Government’s 

WayToGo program to promote commuter options.

Participated in Colorado Recovery Office Statewide 

Resilience Working Group.

Supported Council on Environmental Quality’s Colorado 

Preparedness Pilot Project.

Finalized the NWTC and STM campus-wide environmental 

assessments.

Worked with Jefferson County Planning and Zoning to 

improve drainage swale on the STM campus.

On 

Track

3.1 10% annual increase in fleet alternative fuel 

consumption by FY 2015 relative to a FY 2005 

baseline

Increased alternative fuel use 48% from the FY 2005 

baseline. 

NOTE: The ability to increase alternative fuel use is 

challenging due to the low number of fleet miles traveled. 

In addition, most fleet vehicles are already alternative 

fuel vehicles.

Not On 

Track
ENVIRONMENTAL PERFORMANCE REPORT 2014 31

TABLE 2. SSPP PERFORMANCE SUMMARY

SSPP 

Goal # DOE SSPP Goal NREL Performance Status in FY 2014 Status

3.2 2% annual reduction in fleet petroleum 

consumption by FY 2020 relative to a FY 2005 

baseline

Increased petroleum fuel use 63% from the FY 2005 

baseline.

NOTE: Overall, petroleum use is higher than the FY 2005 

baseline and lower than FY 2013 use. The increase from 

the baseline year is due to the increased use of the diesel 

shuttle buses since FY 2009.

Not On 

Track

3.3 100% of light-duty vehicle purchases must 

consist of Alternative Fuel Vehicles by FY 2015 and 

thereafter (75% FY 2000–2015)

No light-duty vehicles were purchased in FY 2014. Not

Applicable

4.1 26% potable water intensity (gallons per gross 

square foot) reduction by FY 2020 from a FY 2007 

baseline 

Reduced potable water intensity 43% from the FY 2007 

baseline.

On 

Track

4.2 20% water consumption reduction of industrial, 

landscaping, and agricultural water by FY 2020 

from a FY 2010 baseline

NREL does not use industrial, landscaping, or agricultural 

water.

Not

Applicable

5.1 Divert at least 50% of non-hazardous solid waste, 

excluding construction and demolition debris, by 

FY 2015

Diverted 75% of campus waste from the landfill in FY 2014. On 

Track

5.2 Divert at least 50% of construction and demolition 

materials and debris by FY 2015

Diverted 87% of construction waste from the landfill in 

FY 2014.

On 

Track

6.1 Procurements meet sustainability requirements 

and include sustainable acquisition clause (95% 

each year)

All construction and custodial contracts met sustainable 

acquisition requirements.

On 

Track

7.1 All data centers are metered to measure energy 

efficiency by FY 2015

The Research Support Facility and Energy Systems 

Integration Facility data centers are equipped with meters 

to measure monthly energy efficiency.

On 

Track

7.2 Maximum annual weighted average energy 

efficiency rating (Power Usage Effectiveness) of 1.4 

by FY 2015

The average energy efficiency rating for the Research 

Support Facility data center was 1.18.

On 

Track

7.3 100% of eligible personal computers, laptops, 

and monitors with power management actively 

implemented and in use by FY 2012

Power management is enabled on 100% of applicable 

devices.

Goal 

Met

8.1 20% of annual electricity consumption from 

renewable sources by FY 2020

20% of electricity consumption was generated on-site from 

renewable sources in FY 2014.

On 

Track

9.1 Address DOE Climate Change Adaptation Plan 

goals

Initiated climate resiliency planning. On 

Track

10.1 Utilize energy performance contracts Pursued alternative financing mechanisms such as Power 

Purchase Agreements and Energy Savings Performance 

Contracts to the extent possible. To date, NREL has 

initiated one Energy Savings Performance Contract project 

(Renewable Fuels Heating Plant) and has installed 2.35 MW 

of photovoltaics using Power Purchase Agreements.

On 

Track
32 ENVIRONMENTAL PERFORMANCE REPORT 2014

4.3 CLIMATE CHANGE ADAPTATION 

MANAGEMENT

With the potential for temperature increases, more 

frequent droughts, flash flooding, disease outbreaks, heat 

waves, floods, and winter storms, climate change has the 

potential to create additional challenges for NREL operations. Recognizing the increasing importance of current 

and future climate, NREL is proactively engaging in planning efforts to identify and manage site-specific climate 

risks, develop options for adapting to climate change, and 

improve resiliency in the face of climate change.

Program Management

NREL initiated its climate resilience planning in 2014. Key 

planning components include:

■ Developing a general understanding of relevant 

climate science

■ Translating science into site-specific climate change 

vulnerabilities

■ Evaluating the associated risks to NREL’s operations 

and mission from these vulnerabilities 

■ Developing an adaptation and resiliency plan to 

address these risks 

■ Engaging stakeholders both internal and external 

to NREL to gain information and build consensus on 

climate vulnerabilities, organizational risks, and resiliency options.

The Climate Change Resilience Plan is intended to establish 

a framework to continually review and update the impacts 

and risk determinations as needed. The information collected will be used to enhance ongoing and existing planning 

and preparedness efforts at the lab. 

In addition to efforts focused on the development of the 

Climate Change Resilience Plan, NREL has begun to engage 

external stakeholders for the purpose of a regional symposium to share what has been learned through the plan 

development, learn what community partners are doing to 

plan for climate change, and identify opportunities for local 

partnerships and cooperation. It is the goal of this outreach 

to initiate a long term dialogue to improve the collective understanding of climate change science, share best 

practices and data, and establish regional coordination in 

adaptation planning and policy.

Floodwaters at the STM campus that resulted from unusual back-toback storm events. Photo by Dennis Schroeder, NREL 27625

Electric vehicle charging stations at the STM campus parking garage. 

The 36 charging stations are part of a research project to test the 

impact of charging scenarios on the electrical distribution network. 

Use of electric cars has the potential to reduce carbon dioxide 

emissions that contribute to climate change. Photo by Erik Nelsen, 

NREL 26488 
ENVIRONMENTAL PERFORMANCE REPORT 2014 33

NREL is subject to many federal, state, and local environmental laws and regulations, as well as Executive Orders 

(EOs) and DOE orders and memoranda of understanding 

with government agencies. NREL continues its excellent 

record of environmental compliance.

Table 3 includes a brief description of the statute or regulation and how compliance requirements were met this year. 

More detailed information for each area of compliance is 

found in the referenced sections of this report. For information on required permits, registrations, and notifications, see Appendix C.

5 

COMPLIANCE SUMMARY

Building stacks at the Field Test Laboratory Building. 

Photo by Genevieve Braus, NREL 33336
34 ENVIRONMENTAL PERFORMANCE REPORT 2014

TABLE 3. FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Climate

Change

Management

EO 13514, Federal Leadership in 

Environmental, Energy and Economic 

Performance, and EO 13653, Preparing the 

United States for the Impacts of Climate 

Change, require federal agencies to 

identify and evaluate the potential risks 

and vulnerabilities to their mission and 

operations resulting from climate change. 

Each federal agency is also required to 

develop a climate adaptation plan and 

report on their progress in their annual 

Site Sustainability Plan documents. DOE 

guidance further requires reporting on 

climate change adaptation management in 

facilities’ Annual Site Environmental Report.

Initiated climate resilience planning by 

identifying risks to NREL’s operations and 

mission as a result of climate change, and 

subsequently developed a method to 

analyze, compare and rank those risks.

Executive Orders:

EO 13514 

EO 13653 

Air Quality The Colorado Department of Public Health 

and Environment (CDPHE) administers the 

Clean Air Act implementing regulations for 

all point sources (facilities or other types of 

operations) in Colorado, under authority 

delegated by the U.S. Environmental 

Protection Agency (EPA). Several main 

categories for air pollutants are regulated: 

criteria air pollutants, hazardous air 

pollutants (HAPs), ozone-depleting 

substances, and greenhouse gases.

EPA regulation 40 Code of Federal 

Regulations (CFR) 82, Protection Of 

Stratospheric Ozone, requires that servicing 

records must be kept for appliances 

containing more than 50 pounds of 

Class 1 or 2 Ozone Depleting 

Substances refrigerant.

EPA regulations require that certain facilities 

which emit greenhouse gas emissions track 

and report the amount of those emissions. 

Reporting and permitting of greenhouse 

gases is required under the EPA Prevention 

of Significant Deterioration regulation, Title 

V Tailoring Rule, and the EPA Greenhouse 

Gas Mandatory Reporting Rule.

CDPHE regulations require federal, state, 

and local government facilities to track 

street sanding in the wintertime, and 

to minimize sand use with the goal of 

reducing particulate pollution in the 

Denver area.

All program activities were in compliance 

with requirements. NREL did not exceed 

any air permit standard or other air 

regulatory requirement at any facility.

One new source, a diesel-fueled electrical 

generator, was issued a Permit to Construct, 

and subsequently issued a Permit to 

Operate following submittal of the Air 

Pollution Control Division (APCD) of CDPHE 

- required Self Certification package.

Inspections of the Integrated Biorefinery 

Research Facility ammonia scrubber and 

particulate baghouse and the Integrated 

Biorefinery Research Facility Standby 

Generator were performed by the Jefferson 

County Health Department on behalf of the 

APCD in May, 2014, with no violations noted. 

An evaluation of hazardous air pollutant 

emissions indicated that emissions were 

well below reporting and permitting 

thresholds.

All required ODS equipment registrations 

were completed. Facilities servicing 

refrigeration equipment were registered 

and all refrigeration service personnel 

maintain the federal and state required 

training and certification.

The laboratory evaluated carbon dioxide 

equivalent (CO2e) and greenhouse gas 

emissions and emissions were below 

the threshold for federal reporting and 

permitting rules.

The required annual street sanding 

report was provided to the state and 

Jefferson County.

National Ambient 

Air Quality Standards:

40 CFR 50

ODS:

40 CFR 82 and CDPHE 

Colorado Code of 

Regulations (CCR) 1001-19, 

Reg. 15

New Source Performance 

Standards:

40 CFR 60

New Source Review, 

Prevention of Significant 

Deterioration:

40 CFR 51

Title V:

40 CFR 70 and 71

National Emission Standards 

for Hazardous Air Pollutants, 

Hazardous Air Pollutant:

40 CFR 63 and CDPHE 

5 CCR 1001-5, Reg. 3

Permitting:

CDPHE 5 CCR 1001-5, 

Reg. 3

Greenhouse Gas:

40 CFR 98 and 40 CFR 

51, 52, 70, 71

Street Sanding:

CDPHE 5 CCR 1001-18, 

Reg. 16
ENVIRONMENTAL PERFORMANCE REPORT 2014 35

TABLE 3. FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Drinking 

Water 

Quality

The Safe Drinking Water Act establishes 

minimum drinking water standards and 

monitoring requirements for drinking 

water supplies. Drinking water quality is 

regulated for all public water suppliers 

in Colorado by CDPHE, under authority 

delegated by the EPA.

All program activities were in compliance with 

requirements.

465,563 gallons of drinking water were provided to 

NWTC users.

EPA:

40 CFR 141-149

CDPHE:

5 CCR 1002-11 

Reg. 11

Groundwater

Quality

Colorado groundwater quality standards 

are established by CDPHE. Permits 

for groundwater wells are issued by 

the Colorado Department of Natural 

Resources.

There are no compliance activities associated with 

the NREL groundwater program. NREL currently has 

five permitted monitoring wells at the STM campus. 

The wells are not currently used for monitoring 

activities.

CDPHE:

5 CCR 1002-41

2 CCR 402-2

2 CCR 402-10

Surface 

Water 

Quality

Surface water quality is controlled 

through the federal Clean Water Act, 

Energy Independence and Security Act 

of 2007, E.O. 13514, Federal Leadership 

in Environmental, Energy, and Economic 

Performance, and the Colorado Water 

Quality Control Act. Construction-related 

stormwater discharge regulations are 

administered by the EPA at federal facilities 

in Colorado. 

Non-federal facility construction-related 

stormwater discharges in Colorado are 

regulated by the Water Quality Control 

Division of CDPHE. 

All program activities were in compliance with 

requirements. 

Permit coverage was obtained under the EPA 

Construction General Permit (CGP) for one new 

construction project at the STM campus. Permits 

are now in effect for three STM construction 

projects. Two permits for completed projects were 

terminated in 2014. No permits are in effect at the 

NWTC.

Monthly stormwater inspections were performed 

for construction sites where EPA CGP permit 

coverage continues during the restoration phase 

of these projects. Weekly inspections occurred for 

construction sites with active EPA CGP stormwater 

permits. 

Successful revegetation, defined in the EPA 

construction stormwater permit as vegetative cover 

equivalent to 70% of pre-disturbance cover, was 

achieved at two major construction sites. Carefully 

selected seed mixes and mulches together with 

weed management and temporary irrigation were 

instrumental in achieving the EPA criteria.

EPA:

40 CFR 122.26

CDPHE:

5 CCR 1002-61

Regs. 38, 61, 65, 

and 93

Executive Orders:

EO 13514

WasteWater 

Management

The federal Clean Water Act and Colorado 

Water Quality Control Act regulations apply 

to wastewater management at NREL’s STM 

and Denver West Office Park. The Metro 

Wastewater and Reclamation District 

manages wastewater for much of the 

Denver metro area, receiving wastewater 

from a number of smaller wastewater 

districts, including the Pleasant View Water 

and Sanitation District.

Inspection and permitting of individual 

sewage disposal systems have been 

delegated to Jefferson County by CDPHE.

All program activities were in compliance with 

requirements.

In 2014, plans were developed for a new clean room 

in the Science and Technology Facility. Activities 

contemplated for the new clean room, in which 

controls are put in place to eliminate dust and other 

contaminants as required for research related to the 

development of solar cell technology, will generate 

a large volume of corrosive waste which will be 

neutralized prior to discharge. It is not anticipated 

that the volumes will exceed the 25,000 gallon-perday limit that defines a significant industrial user 

under the Metro District’s Rule and Regulations, but 

NREL will provide notification to both the Metro 

District and Pleasant View of the newly installed 

neutralization process before discharge begins.

EPA:

40 CFR 122-136

CDPHE:

5 CCR 1002-62, 63

Table 3 continued on page 36
36 ENVIRONMENTAL PERFORMANCE REPORT 2014

TABLE 3. FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Hazardous 

Materials

Management 

EO 13423 Strengthening Federal Environmental, Energy, and 

Transportation Management, outlines requirements for 

Superfund Amendments and Reauthorization Act Title III, 

Emergency Planning and Community Right-to-Know Act 

of 1986 (EPCRA) compliance, and Toxic Release Inventory 

reductions for DOE facilities. 

NREL facilities are subject to various parts of EPCRA, which 

include Sections 302, 304, 311, 312 and 313. Section 302 

of EPCRA, which requires a facility to notify the state and 

local emergency response and planning agencies if any 

extremely hazardous substances in the facility’s inventory 

are stored in quantities greater than regulatory thresholds. 

EPCRA Section 304 requires facilities to immediately notify 

the state and local emergency response and planning 

agencies if there is an accidental spill or release of more 

than the predetermined reportable quantity. 

In accordance with Sections 311 and 312 of EPCRA, 

NREL provides Safety Data Sheets or SDS (per OSHA’s 

new hazard communication requirements, the term 

SDS replaces MSDS or Material Safety Data Sheets) for 

chemicals that are stored on-site in quantities greater than 

regulatory thresholds, and provides inventory reporting 

for these same chemicals in the form of an annual Tier II 

hazardous materials report to state and local emergency 

response agencies and local fire departments.

The laboratory is also subject to reporting requirements 

in the event of a release of a reportable quantity of any 

hazardous substance listed by EPCRA. EPCRA Section 

313 requires that a toxic chemical release inventory 

report (Form R) be filed with the EPA for any chemical 

that is manufactured, processed, or otherwise used in 

quantities exceeding regulatory thresholds. Although not 

a manufacturing facility and not characterized by the 

standard industrial classification codes for which EPCRA 

Section 313 reporting is required, EO 13423, Strengthening 

Federal Environmental, Energy, and Transportation 

Management, requires that all federal facilities file a 

report, if applicable, regardless of the standard industrial 

classification code. NREL has never manufactured, 

processed, or otherwise used chemicals on the EPCRA 

Section 313 list in quantities exceeding regulatory 

thresholds, so has never had to report under EPCRA 

Section 313. 

Annual hazardous material permits are required by 

West Metro Fire Rescue for the STM and DWOP sites. 

Renewable Fuels and Lubricants Research Laboratory, 

located within the City and County of Denver, is subject 

to the Denver Fire Dept. Hazardous Materials Information 

System requirements, including permitting, inventory, and 

annual inspection. 

All program activities were in 

compliance with requirements. 

NREL submitted reporting year 2013 

Tier II hazardous material reports to the 

state, county Local Emergency Planning 

Committees, and fire departments for 

three NREL facilities (STM, NWTC and 

Solar Technology Acceleration Center), 

identifying diesel fuel, petroleum oil, 

and sulfuric acid in lead-acid batteries. 

Toxic Release Inventory reporting under 

EPCRA was not required by NREL for 

reporting year 2013.

West Metro Fire Rescue conducted an 

annual hazardous material inspection 

and issued permits for seven facilities 

on the STM campus. The inventory of 

materials at the Renewable Fuels and 

Lubricants Research Laboratory facility 

was provided to the Denver 

Fire Department.

EEPA:

40 CFR 355, 370, 

372

Executive:

Orders:

EO 13423
ENVIRONMENTAL PERFORMANCE REPORT 2014 37

TABLE 3. FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Regulated

Waste 

Management

The Resource Conservation 

and Recovery Act established 

requirements for the management 

of regulated waste. In Colorado, 

CDPHE administers waste 

regulations under authority 

delegated by the EPA. 

All program activities were in compliance with 

requirements. 

All regulatory notifications were updated and applicable 

waste generator fees were paid for five NREL facilities. 

A Biennial Hazardous Waste Report for the STM campus 

(which detailed hazardous waste activities for calendar year 

2013) was submitted to the state.

A joint compliance inspection of the STM campus waste 

program was conducted by the EPA, and the Hazardous 

Materials and Waste Management Division of CDPHE on 

April 16, 2014. Areas of focus involved waste container 

management, proper documentation of regulated 

waste handling activities, employee training and facility 

contingency planning. A compliance advisory was issued 

for one instance of potential incompatible materials stored 

in close proximity to each other. This issue has been 

addressed and closed out by the state on May 5, 2014.

EPA:

40 CFR 260-280

CDPHE:

6 CCR 1007-3

Aboveground

storage

tank

management

Aboveground Storage Tanks (ASTs) 

are regulated in Colorado by the 

Colorado Department of Labor and 

Employment Oil Inspection Section 

under the Colorado AST regulation 

7 C.C.R. 1101-14. Colorado requires 

that ASTs 660 gallons or larger be 

permitted prior to installation and 

registrations submitted annually.

All program activities were in compliance with 

requirements.

No reportable spills or releases from NREL’s ASTs or related 

fueling activities occurred. 

A state inspection of registered ASTs was completed with 

no violations noted.

A 1,000 gallon E85 fleet vehicle fuel tank was installed at the 

STM campus and registered with the Division of Oil 

and Public Safety of the Colorado Department of Labor 

and Employment.

One 2,500 gallon AST at the Solar Technology Acceleration 

Center facility was transferred to another entity and is being 

removed from the inventory of NREL-registered ASTs.

CDLE:

Division of Oil 

and Public Safety 

(DOPS) Storage 

Tank Regulations,

7 C.C.R. 1101-14

Spill 

Prevention

and

Response

Spill prevention, control, and 

countermeasures (SPCC) plans 

are required by EPA and Colorado 

regulations for facilities that meet 

certain oil storage criteria. In 

general, a facility must have an 

SPCC plan if the facility stores more 

than 1,320 gallons of oil or where 

a spill has the potential to enter 

waters of the United States.

All program activities were in compliance with 

requirements.

Workers who manage and/or operate oil-containing 

equipment received annual SPCC training. 

There was one reportable spill of approximately one gallon 

which was reported to the Water Quality Control Division 

of CDPHE. This spill resulted from residual hydraulic fluid 

remaining from a vehicle-related spill. No hydraulic fluid left 

NREL property; no violation or compliance action resulted. 

No additional action was required by the state.

Twenty-one minor spills of diesel, lubricant, coolant, and 

hydraulic fluids occurred at the STM campus, and one spill 

occurred at the NWTC. The size of spills ranged from less 

than 0.1 gallon to 12 gallons (0.38 to 45 liters). The majority 

of these spills were the result of leaks from vehicles and 

construction equipment. Each spill received immediate 

remedial action and did not result in any significant impact 

to the environment.

EPA:

Oil Pollution 

Prevention 

40 CFR 112

CWA Section 319

CDLE:

DOPS Storage Tank 

Regulations,

7 C.C.R. 1101-14

CWCC:

25-8-205 C.R.S

Table 3 continued on page 38
38 ENVIRONMENTAL PERFORMANCE REPORT 2014

TABLE 3. FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Radiological

materials

and waste

Management

Air emissions are regulated by Section 

112 of the Clean Air Act and implemented 

by the EPA. 40 CFR Part 61 established 

National Emission Standards for 

Hazardous Air Pollutants, and, more 

specifically, Subpart H, sets such standards 

for radiological materials.

DOE Order 458.1, Radiation Protection of 

the Public and the Environment establishes 

radiation emission limits for DOE facilities. 

All program activities were in compliance with 

requirements. No planned or unplanned radiological 

releases occurred.

Only small quantities of low-level radioactive waste 

were generated and are currently in storage awaiting 

off-site disposal.

The effective dose equivalent to the public from 

NREL activities was 0.036 mllirem (mrem) per year, far 

below the 10 mrem per year limit.

EPA:

40 CFR 61, 

Subpart H

DOE:

DOE Order 458.1

National

Environmental

Policy

Act

National Environmental Policy Act (NEPA) 

requires that federal agencies determine 

environmental impacts of proposed 

federal actions and alternatives. DOE 

implements NEPA in 10 CFR 1021.

All program activities were in compliance with 

requirements.

Three hundred ninety NEPA reviews were conducted 

for project activities on- and off-site during 2014. 

Site-Wide Environmental Assessments and Findings 

of No Significant Impact were completed for the STM 

and NWTC campuses. Public meetings and 30-day 

public review and comment periods were completed 

as part of these EAs.

Council for

Environmental 

Quality:

40 CFR 1500-1508

DOE:

10 CFR 1021

Wildlife 

Management

The Migratory Bird Treaty Act (MBTA) of 

1918 is the main driver for protection of 

migratory birds in the United States. The 

MBTA and amendments implements 

several treaties between the U.S., Great 

Britain, Mexico, Japan, and the former 

Soviet Union. The MBTA prohibits the 

taking, killing, or possession of migratory 

birds, nests, and eggs.

Under Colorado Revised Statute (CRS) 

33-6-128: Damage or Destruction of Dens or 

Nests—Harassment of Wildlife, no wildlife 

dens or nests, young or eggs may be 

damaged or destroyed unless permitted 

by the Colorado Division of Parks and 

Wildlife and it is unlawful for any person to 

willfully harass wildlife including birds.

Under the “Memorandum of 

Understanding (MOU) between DOE and 

the USFWS Regarding Implementation 

of EO 13186, Responsibilities of Federal 

Agencies to Protect Migratory Birds” DOE 

agrees to integrate migratory bird 

conservation principles, measures, and 

practices into agency activities, and avoid 

or minimize adverse impacts on migratory 

bird resources and their habitats.

NREL completed bird-friendly retrofits to selected 

windows at the Energy Systems Integration Facility. 

This effort is consistent with the requirements of the 

MBTA and DOE’s Memorandum of Understanding 

with the U.S. Fish and Wildlife Service (USFWS). 

NREL and DOE included MBTA discussions as part of 

the Endangered Species Act consultations with the 

U.S. Fish and Wildlife Service that were conducted as 

part of the Site-Wide Environmental Assessments for 

the NWTC and STM campuses. 

Per EO 13186, Responsibilities of Federal Agencies to 

Protect Migratory Birds, DOE and NREL provided an 

accounting of efforts at NREL campuses to protect 

migratory birds which was submitted for inclusion in 

the 2013 Council for the Conservation of Migratory 

Birds Annual Report .

U.S. Fish and 

Wildlife Service:

MBTA 16 U.S.C. 

703-712

Colorado Division 

of Parks and 

Wildlife: CRS 

33-6-128

Memorandum of 

Understanding 

between DOE and 

the U.S. Fish and 

Wildlife Service 

Executive Orders:

EO 13186
ENVIRONMENTAL PERFORMANCE REPORT 2014 39

TABLE 3. FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Endangered Species

and 

Species of 

Concern

The Endangered Species Act (ESA) is 

intended to protect threatened and 

endangered wildlife and plant species 

and associated critical habitat. 

All program activities were in compliance with requirements.

The USFWS lists nine species in accordance with the ESA as 

threatened, endangered, or a candidate for listing that could 

potentially occur in Jefferson County or Boulder County. Of these, 

three have the potential to occur on the STM or NWTC campuses 

including the Preble’s meadow jumping mouse, the Ute ladies’ 

tresses orchid, and the Colorado butterfly plant. While the Preble’s 

meadow jumping mouse does not occur on site, the USFWS 

mapped critical Preble’s habitat within the upper reaches of Rock 

Creek, including a small area at the southeast corner of the NWTC. 

This area may not be disturbed without coordination with 

the USFWS.

NREL assisted DOE in ESA consultations with the USFWS that 

were conducted as part of the development of the Site-Wide 

Environmental Assessments for the NWTC and STM campuses.

In support of informal Section 7 ESA consultations, past surveys 

were used to document the potential for occurrence of threatened 

or endangered species listed in Jefferson County. No species or 

species habitat are found at either NREL campus. 

In support of formal Section 7 ESA consultations, Biological 

Assessments for the NWTC and the STM campuses were prepared 

that evaluated potential depletion of water to the South Platte 

River system from continued and proposed site activities. 

Biological Opinions for the NWTC and STM campuses were 

received from the USFWS that indicated that the proposed waterrelated actions of the two Site-Wide Environmental Assessments 

are covered under the Programmatic Biological Opinion 

developed for the Platte River Recovery Implementation Program.

U.S. Fish 

and Wildlife 

Service:

50 CFR 17

Vegetation 

Management

EO 13112, Invasive Species requires the 

control of invasive species at federal 

facilities. In Colorado, the Department 

of Agriculture Commissioner develops 

and implements state noxious weed 

management plans for three categories 

of weed species. Class A plants are 

targeted for eradication. Class B species 

are subject to management plans 

designed to stop their continued 

spread. Class C species are subject to 

plans designed to support the efforts 

of local governing bodies to facilitate 

more effective integrated weed 

management on private and 

public lands.

The Federal Insecticide, Fungicide, 

and Rodenticide Act regulates the use, 

storage, and disposal of herbicides 

and pesticides. For application of 

certain types of herbicides designated 

as “restricted use” by the EPA, a 

certified applicator must be used. 

 All program activities were in compliance with requirements.

In addition to mechanical and cultural control methods, 

herbicides were applied at the NWTC and the STM campuses as 

follows: At the NWTC, herbicides were applied to control B- and 

C-listed weeds to approximately 60 acres in April, 17 acres in June, 

and 40 acres in August. 

At the STM campus, herbicides were applied to control B- and 

C-listed weeds to approximately 27 acres in May, 13 acres in June, 

and 4 acres in October.

Executive 

Orders:

EO 13112

EPA:

40 CFR 162-

171(f)

CRS 35-5.5

Department 

of Agriculture:

Federal 

Noxious 

Weed Act of 

1974 (Public 

Law 93-629, 

88 Statute 

2148)

Plant Protection Act 

(Public Law 

106-224)

Table 3 continued on page 40
40 ENVIRONMENTAL PERFORMANCE REPORT 2014

TABLE 3. FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Wetlands 

and 

Floodplains

EO 11988, Floodplain Management, 

requires federal agencies to provide 

leadership and shall take action to 

reduce the risk of flood loss, to minimize 

the impact of floods on human safety, 

health and welfare, and to restore and 

preserve the natural and beneficial values 

served by floodplains in carrying out its 

responsibilities.

Under EO 11990, Wetlands Protection, 

federal agencies must provide leadership 

and take action to minimize the 

destruction, loss, or degradation of 

wetlands, and to preserve and enhance 

the natural and beneficial values of 

wetlands. Wetlands that meet certain 

soils, vegetation, and hydrologic criteria, 

are protected under the CWA Section 

404, which is administered by the U.S. 

Army Corps of Engineers (USACE).

Jefferson County requires approval of 

development proposed in floodplains 

within its jurisdiction.

All program activities were in compliance with 

requirements; no actions occurred that affected wetlands or 

floodplains.

None of the wetlands present at NREL facilities have been 

designated “jurisdictional” by the USACE. 

The STM and NWTC campuses do not contain 

any floodplains. 

Executive 

Orders:

EO 11988

EO 11990

USACE:

CWA 

Section 404

DOE:

10 CFR 1022

Cultural 

Resources

Cultural resources are protected under 

Sections 106 and 110 of the National 

Historic Preservation Act. Federal agencies 

must establish preservation programs—

commensurate with their mission and 

the effects of their activities on historic 

properties—that provide for the careful 

consideration of historic properties. 

Significant cultural resources are either 

eligible for, or listed in, the National 

Register of Historic Places. Cultural 

resources are defined as any prehistoric or 

historic district, site, building, structure, or 

object considered important to a culture, 

subculture, or community for scientific, 

traditional, religious, or other reason. 

The National Historic Preservation Act is 

administered in Colorado by the 

Colorado Office of Archaeology & 

Historic Preservation (State Historic 

Preservation Officer).

All program activities were in compliance with 

requirements.

DOE initiated consultation with the State Historic 

Preservation Officer under Section 106 of the National 

Historic Preservation Act for proposed actions of the STM 

Site-Wide Environmental Assessment. The State Historic 

Preservation Officer’s primary concern involved indirect 

visual impacts to the amphitheater and ammunition bunker 

from proposed new development near and within the 

viewshed of these resources. The State Historic Preservation 

Officer and DOE concluded that the best approach going 

forward will be to initiate consultations on a project-byproject basis when individual components of the proposed 

action are funded or authorized.

DOE submitted the Memorandum of Agreement Summary 

Report, thereby completing DOE and NREL responsibilities 

per the 2011 Memorandum of Agreement for mitigation of 

impacts to the Camp George West firing lines resulting from 

construction of Research Road.

Advisory 

Council 

on Historic 

Preservation:

36 CFR 60

36 CFR 63

36 CFR 79

36 CFR 800

16 U.S.C. 470
ENVIRONMENTAL PERFORMANCE REPORT 2014 41

TABLE 3. FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

EMS and 

Sustainability

DOE Order 436.1, Departmental Sustainability

implements the objectives of EO 13423, Strengthening 

Federal Environmental, Energy, and Transportation 

Management, and EO 13514, Federal Leadership in 

Environmental, Energy, and Economic Performance, 

which direct federal agencies to conserve natural 

resources, reduce energy use, develop renewable 

energy, reduce greenhouse gas emissions, and 

manage buildings and transportation in a 

sustainable manner.

DOE Order 436.1 requires that DOE develop a SSPP 

to ensure that the sustainability goals established in 

EO 13423 and 13514 are met. Individual DOE facilities 

must develop site specific SSPs designed to set goals 

for the coming year and discuss performance for the 

prior year. 

DOE Order 436.1 also requires that DOE facilities 

implement EMSs that are independently verified to 

meet the requirements of ISO 14001. 

Each year, a Site Sustainability Plan is 

developed to report on past performance 

and set goals for the coming year. These 

performance goals are integrated with the 

laboratory’s EMS and progress is tracked 

throughout the year. 

NREL’s EMS has been registered to the 

ISO 14001:2004 international standard for 

environmental management systems since 

2011. Annual assessments by the registrar 

verify that NREL meets the ISO standard 

and is continually improving performance. 

Executive Orders:

EO 13423

EO 13514

DOE:

DOE Order 436.1

DOE Order 450.1A

DOE Order 430.2B

N/A DOE Order 231.1B, Environment, Safety and Health 

Reporting was implemented to assure that DOE 

receives timely, accurate information about events 

that have affected or could adversely affect the 

health, safety and security of the public or workers, 

the environment, or the operations of DOE facilities. 

The order requires that DOE facilities report specific 

site environmental information annually including 

environmental management performance, 

environmental occurrences and response, compliance 

with environmental standards and requirements, 

significant programs and efforts, and property 

clearance activities for property contaminated with 

radiological materials.

NREL reports annually via this 

Environmental Performance Report.

DOE:

DOE Order 231.1B

Traffic

Management

There are no traffic regulations that pertain to the 

NREL campuses. Traffic demand management 

strategies are implemented to minimize traffic 

impacts in the local area. 

Average 2014 PM (4:30 p.m. to 5:30 p.m.) 

peak hour traffic volume measured at the 

STM intersection of Denver West Parkway 

and Denver West Marriott Boulevard was 

342 vehicle trips per hour. This traffic 

volume remained below the threshold 

to ensure a Level of service “D” or better 

(equivalent to 522 vehicle trips per hour) 

entering or leaving the site during the 

afternoon rush hour.

Traffic volumes at the other NREL 

campuses are considered to be minimal at 

this time. Traffic analysis will be conducted 

in the future at those locations should 

increases in staff population and/or 

activities warrant such studies.

DOE/EA-1440-S-I

(May 2008)

Traffic Mitigation 

Action Plan
42 ENVIRONMENTAL PERFORMANCE REPORT 2014

NREL strives to protect air quality by minimizing air emissions, monitoring air emissions from the larger on-site 

sources, and meeting federal and state air emissions and 

permitting requirements. Minimizing air emissions creates 

direct health benefits for neighbors immediately adjacent 

to the laboratory and for those in the Denver metropolitan 

area. Staff actively participates in project planning, safety 

evaluations, readiness verifications, and operations activities. This participation results in awareness of projects and 

planned air emissions while allowing staff to obtain the 

necessary regulatory approval for those emissions and 

maintain a current and accurate air emission inventory.

Requirements 

The Clean Air Act, which is administered by both the 

EPA and the state, regulates several main categories of 

air pollutants:

■ Criteria air pollutants – including carbon monoxide, 

nitrogen oxides, sulfur dioxide, particulate matter, 

respirable particulates, ozone, and lead

■ Non-criteria pollutants – these include any air 

pollutant that is not defined as a criteria air pollutant. 

Regulated categories of these include the following:

● Hazardous Air Pollutants – including specific 

organic compounds, metals, corrosives, asbestos, 

radionuclides, and pesticides established by 

the EPA

● Greenhouse gas compounds – including carbon 

dioxide, methane, nitrous oxide, and many manmade refrigerant gases that contribute to climate 

change

● Ozone-Depleting Substances (ODS) – 

including chlorofluorocarbons or “Freon” and 

hydrochlorofluorocarbons that are being phased 

out of use in comfort heating and cooling systems 

and equipment.

6 

AIR QUALITY PROTECTION

Diesel generator at the NWTC, used to supply emergency 

power to a portion of the site. Photo by Genevieve Braus, 

NREL 33064
ENVIRONMENTAL PERFORMANCE REPORT 2014 43

For facilities and stationary sources that emit criteria air 

pollutants and hazardous air pollutants, there are various 

federal and state requirements for permitting, reporting, 

emission controls, and operations, depending upon the 

type and amount of air pollutants emitted. Generally, these 

requirements become stricter as the quantity of air pollutants emitted increases or based upon the potential harm or 

effect of the air pollutants.

Greenhouse gases emitted by certain facilities are required 

by federal regulations to be tracked and reported, if the 

emissions are greater than 27,557 U.S. tons (25,000 metric 

tons) of carbon dioxide equivalent per year. The purpose of 

this reporting is to better identify actual emissions of such 

gases across the United States and provide the EPA with 

data upon which to base future greenhouse gas regulations. Additionally, federal permitting of greenhouse gases is 

required if carbon dioxide equivalent emissions are greater 

than 100,000 U.S. tons (90,718 metric tons) per year. 

Certain refrigerants and other chemicals are more highly 

regulated than others due to their ability to damage the 

Earth’s protective ozone layer. Federal and state regulations 

for these ODS, depending upon the quantity of ODS and the 

size of the comfort heating and cooling equipment, include 

registration, recordkeeping, refrigerant recovery, and leak 

monitoring and repair requirements. Most importantly, 

these regulations prohibit the intentional venting of these 

substances into the atmosphere.

There are several state air regulations for sources of particulate pollution, including large construction sites and street 

sanding operations in the winter. Particulate emissions, 

such as dust, from construction sites larger than 25 acres 

(10.1 hectares), or occurring for longer than six months, 

are subject to state fugitive particulate emissions permits. 

Winter road sanding in Colorado can also result in particulate 

emissions when vehicle activity turns road-applied sand into 

finer particulates that then become airborne. These particulates may contribute to breathing and health problems for 

susceptible individuals. State regulations require federal, 

state, and local government facilities to track street sanding 

in the winter and to minimize sand use. 

The primary sources of regulated pollutants at NREL are a 

result of burning fuel, laboratory chemical use, and facility 

operations. Sources include process heat boilers, process 

cooling systems, comfort heating and cooling systems, 

standby electrical generators, small equipment with gasoline 

or diesel engines, bench- and pilot-scale research activities 

using chemicals, and facility operations maintenance activities. Sand is not applied to roadways at NREL campuses.

Program Management

Criteria Pollutants and Hazardous 

Air Pollutants Permitting

The laboratory maintains an air emission inventory to track 

potential emissions and identify whether notification and 

permitting could be required for a particular facility or 

activity. Projected emissions for new sources are evaluated 

and air emission reporting and permitting are performed 

as required.

The laboratory maintains several air permits issued by the 

state for “minor” sources (such as standby electrical generators and pollution control systems) that are subject to minimal permit and compliance requirements. Currently, Title V 

“major” permitting is not required because all pollutant emissions are well below the permitting thresholds. 

The laboratory also has a fugitive emission permit in place 

for the STM campus due to the construction activity over 

the last several years. To further minimize the generation 

of airborne particulates, NREL uses a non-sand deicer 

to maintain roadways. This minimizes potential fugitive 

particulate emissions from snow removal operations, 

contributing to improved air quality for neighbors and in 

the Denver metro region.

Greenhouse Gas Emissions Tracking and Permitting

Permitting and reporting of greenhouse gases are not 

currently required for NREL facilities as emissions are below 

EPA permitting and reporting thresholds. A summary of 

NREL facility estimated annual air pollutant emissions is 

included in Table 4.

2014 Accomplishments and Highlights 

■ Updated the air emissions inventory, including use of equipment-specific emission factors 

where available. This has resulted in a more 

accurate emission inventory and an estimated 

10% decrease in the laboratory’s nitrogen oxide 

emissions.

■ Evaluated hazardous air pollutant emissions 

estimates and engineering controls used by 

research staff in the design of a laboratory 

renovation.

■ Completed the annual evaluation of compliance 

with federal and state facility-wide permitting 

and emissions control requirements. All facilities and individual permitted equipment items 

remain classified as minor sources.
44 ENVIRONMENTAL PERFORMANCE REPORT 2014

TABLE 4. STM, NWTC AND DENVER WEST OFFICE PARK ESTIMATED 

ANNUAL AIR POLLUTANT EMISSIONS (IN U.S. TONS PER YEAR)1

CRITERIA POLLUTANTS GREENHOUSE GASES HAPs

Year CO NOx VOC PM10 SO2 CO2 CH4 N2O Total

2011 5.82 8.03 0.44 0.97 0.15 8,310.00 0.24 0.17 0.1900

2012 6.35 16.28 1.09 2.37 0.22 7,175.00 0.41 0.17 0.3100

2013 6.02 13.83 0.47 3.16 0.360 8,584.00 0.51 0.25 0.5100

2014 5.82 14.06 0.99 1.39 0.10 6,263.41 0.30 0.11 0.1663

Ozone-Depleting Substances Permitting

The majority of refrigeration equipment at NREL either 

contains non-ODS refrigerants or uses very small amounts 

of regulated refrigerants. The only equipment containing 

more than 50 pounds (23 kilograms [kg]) of regulated 

refrigerant are the two chillers located in the Solar Energy 

Research Facility at the STM campus. Operators of 

these chillers must maintain records of service for

 this equipment.

NREL annually registers with the state those facilities 

where ODS maintenance activities occur, maintains EPAapproved training certification for all technicians servicing 

ODS-containing equipment, and renews registrations for 

ODS-containing equipment as necessary. The two previously mentioned Solar Energy Research Facility chillers 

also meet the requirements to be registered with the state 

(contain ODS compounds and have more than 100 horsepower of compression). 

2014 Compliance Summary and Activities

■ Program activities were in compliance with requirements. The laboratory did not exceed any air permit 

standard or other air regulatory requirement at 

any facility.

■ A compliance inspection was conducted by the 

Jefferson County Health Department, on behalf of the 

state, of the permitted Integrated Biorefinery Research 

Facility ammonia scrubber and particulate baghouse. 

No deficiencies were identified.

■ An evaluation of Hazardous Air Pollutant emissions 

indicated that emissions were well below reporting 

and permitting thresholds.

■ NREL provided the required annual street sanding 

report to the state and Jefferson County confirming 

that no sand was used.

■ The laboratory evaluated and concluded that carbon 

dioxide equivalent and greenhouse gas emissions 

were below the threshold for federal reporting and 

permitting rules.

■ All required ODS equipment registrations were 

completed. Facilities servicing refrigeration equipment 

were registered and all refrigeration service personnel 

maintained their certification.

■ One new source, a diesel-fueled electrical generator 

located at the Energy Systems Integration Facility, was 

issued a state Permit to Construct, and subsequently a 

state Permit to Operate, following NREL’s submittal of a 

self-certification package. 

1

 Abbreviations: HAPs – Hazardous Air Pollutants, CO – carbon monoxide, NOx – nitrogen oxides, VOC – volatile organic carbon, PM10 – 

respirable particulate matter less than 10 microns in aerodynamic diameter, SO2 – sulfur dioxide, CO2 – carbon dioxide, CH4 – methane, 

N2O – nitrous oxide.
ENVIRONMENTAL PERFORMANCE REPORT 2014 45

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■

■

■

■

■

■

■

■

■

■

■

■

■

■

■

■

■

■

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■

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■

Water quality is critical to human health and the health of 

our natural ecosystems. At NREL, the focus of water quality protection is on four main areas: 

■ Drinking water

■ Groundwater

■ Surface water

■ Wastewater

7.1 DRINKING WATER

Drinking water at the STM campus is provided by the 

public water provider Consolidated Mutual Water 

Company. The water is treated at the Maple Grove Water 

Treatment Plant through an advanced membrane water 

treatment method.

The NWTC does not have access to a public drinking 

water supply. For this reason, NREL operates a drinking 

water distribution system at the NWTC, serving about 

150 employees. Drinking water is purchased from local 

municipalities and transported by truck to the site, where 

it is transferred to a large holding tank with a capacity of 

15,000 gallons (56,781 liters). Water is pumped from the 

holding tank to a day tank where it is circulated around 

the site for use. There is no treatment of the water, but 

chlorine is added to boost disinfectant levels. The system 

is permitted by the state of Colorado. The water is tested 

monthly and annually in the same ways municipal water 

systems are tested for residual chlorine levels, bacteria, 

disinfection byproducts, lead, and copper. 

Requirements

As a public water system regulated by the state of Colorado, the NWTC water system must comply with the Safe 

Drinking Water Act and federal and state regulations. The 

EPA has established allowable levels for drinking water 

7 

WATER QUALITY PROTECTION

Drainage from much of the STM campus is routed through 

this energy dissipation structure and culvert to a large 

detention basin that promotes settling and infiltration, and 

provides habitat for wildlife. Photo by Dennis Schroeder, 

NREL 23206
46 ENVIRONMENTAL PERFORMANCE REPORT 2014

constituents known as Maximum Contaminant Levels. 

Colorado has adopted these Maximum Contaminant 

Levels into the Colorado Primary Drinking Water Regulations. These regulations establish the state’s authority to 

regulate drinking water providers to assure safe, reliable 

water supplies, and to implement EPA’s special rules.

Program Management

The primary means by which NREL manages its drinking water system at the NWTC is through water quality 

testing as required by the monitoring plan issued by 

the state each year. The plan identifies which tests are 

to be performed and at what frequency. Monthly tests 

are required for bacteria and disinfectant levels, while 

disinfection byproducts (haloacetic acids [HAA5] and 

trihalomethanes [TTHM]) are sampled once per year, and 

lead and copper are tested on a three-year rotating basis. 

Figures 3 and 4 show the results of the chlorine and disinfection byproducts monitoring for 2014.

2014 Compliance Summary and Activities

■ All program activities were in complinace with 

requirements.

■ All other monitored parameters in 2014 met applicable 

requirements.

■ 465,563 gallons (1,762,348 liters) of drinking water 

were provided to NWTC users.

Average Monthly Chlorine Residual, 2014

5.00

4.00

3.00

2.00

1.00

0

1 2 3 4 5 6 7 8 9 10 11 12

Chlorine

Residual

mg/L

Month

Maximum Allowed

Average Monthly

Chlorine Residual

Figure 4. Comparison of disinfection byproducts monitoring, 2010 through 2014

Figure 3. Results of 2014 average monthly chlorine residual monitoring

Disinfection Byproducts

80

70

60

50

40

30

20

10

0

2010 2011 2012 2013 2014

Amount

Present,

ppb

TTHM MCL*

TTHM

HAA5

HAA5 MCL* 

*MCL – Maximum Contaminant Level 
ENVIRONMENTAL PERFORMANCE REPORT 2014 47

7.2 GROUNDWATER

The Denver Basin aquifer system underlies an area of 

approximately 7,000 square miles that extends from Greeley south to near Colorado Springs and from the Front 

Range east to near Limon. The aquifer provides groundwater supplies to urban, rural, and agricultural users. The 

aquifers within the Denver Basin aquifer system, which 

include the Dawson, Denver, Arapahoe, and Laramie-Fox 

Hills aquifers, form a layered sequence of rock in an elongated, bowl-shaped structural depression. Both the STM 

and the NWTC campuses are located at the western edge 

of the Denver Basin aquifer system.

The STM campus overlies the shallowest portions of the 

Denver, Arapahoe, and Laramie-Fox Hills aquifers. The 

NWTC campus overlies the shallowest portions of the 

Arapahoe and Laramie-Fox Hills aquifers. The Dawson 

formation is the shallowest of the Denver Basin aquifers 

and is the one most relied on by the groundwater users 

in the basin. The northern extent of the Dawson aquifer is 

located approximately 20 miles (33 km) to the south and 

east of the STM campus; consequently, wells drilled at 

either the STM campus or the NWTC would not intersect 

the Dawson aquifer, nor would a source of contamination 

affect the groundwater quality in this aquifer. 

Despite the limited ability of reaching the Dawson aquifer, 

NREL’s groundwater management program is focused on 

the control of potential pollutant sources that could affect 

this important source.

Requirements

The state of Colorado regulates the installation of 

groundwater wells, requiring a permit for drinking water, 

geothermal, irrigation, livestock watering, dewatering, 

monitoring, and geothermal well installations. Groundwater quality is regulated by the state through the establishment of basic standards and site specific standards. 

Program Management

Groundwater quality was previously monitored at the 

STM campus using a series of monitoring wells. There are 

currently five permitted monitoring wells that remain in 

place but there is no active monitoring being conducted 

at this time. Should the laboratory conduct activities in 

the future that could impact groundwater, a monitoring 

program would be implemented and additional groundwater monitoring wells would be installed as needed. 

There are two permitted closed-loop geothermal systems 

in operation at the STM Solar Radiation Research Laboratory and at the STM South Site Entrance Building. 

To protect groundwater quality, NREL carefully evaluates 

all outdoor projects to eliminate, substitute, or control 

potential sources of pollution. If any materials are used 

that pose a risk to groundwater, the laboratory incorporates safeguards such as secondary containment, doublewalled tanks, leak detection, and collection and offsite 

disposal of concrete wash water. 

2014 Compliance Activities

An assessment of the groundwater program was conducted that resulted in one finding and two opportunities for 

improvement. The finding identified the need to properly 

abandon or obtain a variance in accordance with state 

regulations for those wells that have not been sampled or 

monitored for more than two years. Corrective actions are 

currently in progress. 

7.3 SURFACE WATER

Surface water protection efforts seek to protect the quality of nearby receiving waters into which the STM and 

NWTC campuses drain. These receiving waters include 

Lena Gulch at the STM campus and Coal Creek and 

Rock Creek at the NWTC campus. Sediment, debris, and 

chemicals transported to these water bodies via stormwater runoff can harm or kill fish and other wildlife either 

directly or by destroying aquatic and riparian habitat. 

High volumes of sediment can result in stream bank 

erosion and clogging of waterways.

2014 Accomplishments and Highlights 

There were no spills or releases that impacted 

groundwater in 2014. Improvements and erosion control measures at the Jeffco Swale. 

Photo by Karri Bottom, NREL 32736
48 ENVIRONMENTAL PERFORMANCE REPORT 2014

Water quality protection is accomplished through federal 

and state stormwater permitting, management of runoff 

that flows across active construction sites, inclusion of 

project design elements that promote infiltration and 

detention, and management of campus grounds to minimize erosion and support infiltration.

Requirements

The federal Clean Water Act, amendments, and implementing regulations apply to stormwater discharges from 

construction activities that disturb greater than one acre. 

The EPA is the regulating authority for stormwater at NREL, 

which is a federally owned facility. For onsite construction projects that disturb greater than one acre, a Notice 

of Intent must be filed with the EPA to be covered under 

their Construction General Permit and a site-specific 

Stormwater Pollution Prevention Plan must be prepared. 

The Stormwater Pollution Prevention Plan implements 

both the requirements of the EPA’s Construction General 

Permit and NREL-specific requirements. For construction 

projects off federal property, such as at the Solar Technology Acceleration Center facility, Colorado Discharge 

Permit System stormwater permits may be required.

The Energy Independence and Security Act requires agencies to reduce stormwater runoff from federal development projects to protect water resources. Agencies can 

comply using low-impact design elements such as porous 

pavers, cisterns, and bioswales, or retain stormwater 

runoff and release at predevelopment levels. In addition, 

EO 13514, Federal Leadership in Environmental, Energy, 

and Economic Performance, sets requirements for efficient 

water use, reuse, and stormwater management. 

Program Management

The surface water program focuses on managing 

construction site runoff, which has the potential to impact 

receiving waters into which NREL campuses drain. 

Prior to construction, NREL implements an interdisciplinary planning and design process that involves reviews and 

approvals for compliance with the National Environmental 

Policy Act, and the assessment of design documents for 

potential impacts to stormwater and receiving waters. 

Design teams are encouraged to incorporate low-impact 

design elements that promote infiltration and evapotranspiration. NREL continues to monitor final design 

documents and construction implementation to look for 

additional opportunities to reduce runoff quantity and 

enhance runoff quality.

Erosion and sediment controls, proper chemical storage, 

fueling procedures, and good housekeeping practices 

are implemented during construction according to the 

2014 Accomplishments and Highlights 

■ The laboratory completed improvements 

to the drainage swale that crosses Jefferson 

County Open Space property (referred to 

as the Jeffco swale) and discharges into the 

stormwater detention basin for the central 

STM campus. The improvements include a 

low-flow infiltration channel in the swale 

bottom, armoring of the swale bottom and 

side slopes with geotextile fabrics, energy 

dissipation structures, reseeding, and the 

addition of irrigation sprinklers to enhance 

re-vegetation success and consequently 

soil stability. As the swale is partly located 

off campus, construction activities required 

permitting and inspections from the neighboring jurisdiction. 

■ Development of stabilization solutions 

for severe slopes located near the Integrated Biorefinery Research Facility and 

the Field Test Laboratory Building were 

initiated. Erosion in these areas was significantly worsened as a result of the rains 

associated with the 2013 flood event that 

was discussed in the 2013 NREL Annual 

Environmental Performance Report. 

(Download here: http://www.nrel.gov/docs/

fy14osti/62296.pdf).

■ The laboratory removed approximately 

15,000 square feet (1,400 square meters) 

of asphalt parking lot at the STM campus, 

replacing it with native grasses. This 

will increase infiltration and decrease 

runoff delivered to the STM stormwater 

detention basin. 

■ Successful revegetation, defined in the 

federal stormwater permit as vegetative 

cover equal to 70% of pre-disturbance 

cover, was achieved at two major construction sites, thus allowing termination of 

EPA stormwater permit coverage. Carefully 

selected seed mixes and mulches, together 

with weed management and temporary 

irrigation, were instrumental in achieving 

the EPA criteria.
ENVIRONMENTAL PERFORMANCE REPORT 2014 49

stormwater management plans developed by contractors 

and reviewed by project staff for both EPA permitted sites 

and those for which an EPA permit is not required. While 

construction projects that disturb less than one acre are 

not regulated by the EPA and typically involve minimal 

disturbance within a short timeframe, these projects still 

have the potential to contribute pollutants to stormwater 

runoff. For these projects, elements of the NREL stormwater pollution prevention program are followed, including the development of an abbreviated Stormwater Pollution Prevention Plan documenting basic contact, project, 

and best management practice information. An illustration showing the area of disturbance and locations of key 

site characteristics and best management practices is 

also required.

Regular inspections by contractors and staff are conducted throughout construction to verify that required 

controls are functioning properly. Any repairs or modifications to the plans are documented on an inspection report; prompt actions are required to correct any 

noncompliant conditions.

Management of campus areas outside active construction 

sites minimizes erosion, supports infiltration of rain water 

and snowmelt, and prevents contamination of stormwater 

with hazardous materials. Vegetation and landscaping are 

maintained to prevent erosion. Infiltration of precipitation 

is achieved through detention basins and grassy swales, 

as well as design elements including porous pavement 

and diversion of roof and perimeter drains to landscaped 

areas. In addition, hazardous wastes are stored indoors 

or in covered areas, and campus roads and sidewalks are 

swept to reduce sediment and other potential pollutants 

from entering the stormwater conveyance system. 

2014 Compliance Summary and Activities

■ Program activities were in compliance with 

requirements

■ Permit coverage was obtained in 2014 under the EPA 

Construction General Permit for one new construction 

project at the STM campus. Permits are now in effect 

for three STM construction projects; there are no active 

construction stormwater permits at the NWTC.

■ Two permits for completed projects were terminated 

in 2014

■ Weekly stormwater inspections were performed per 

EPA stormwater regulations where active construction occurs; monthly stormwater inspections were 

performed for construction sites where EPA Construction General Permit coverage continues during the 

restoration phase of these projects.

7.4 WASTEWATER

Untreated or poorly treated wastewater has the potential to contaminate surface and groundwater used for 

drinking water, irrigation, industrial, commercial, and 

recreational purposes. The majority of wastewater from 

the STM and Denver West Office Park facilities flows into 

the Pleasant View Water and Sanitation District’s (Pleasant 

View) system, and ultimately to the Metropolitan Wastewater Reclamation District’s (Metro District) central treatment plant. Wastewater from the Joyce Street Facility and 

the Renewable Fuels and Lubricants Research Laboratory 

also flows to the Metro District’s treatment plant. 

Research activities at the STM Integrated Biorefinery 

Research Facility develop, test, evaluate, and demonstrate 

processes for the production of bio-based products and 

fuels. Acids and bases are used in pilot-scale processes 

for converting cellulosic biomass into a variety of fuels 

and chemicals. The pH of the effluent from this process 

is adjusted prior to discharge into the sanitary sewer 

system. The Metro District and Pleasant View system 

managers periodically tour the facility and review the 

operational controls.

For those facilities that lack sanitary service, there are three 

small septic systems in place, each consisting of a tank 

and a leach field. One is located at the STM mesa top Solar 

Radiation Research Laboratory and two are at the NWTC 

campus. A preventative maintenance and inspection 

program is in place to confirm proper system function.

Requirements

Non-domestic wastewater discharges to the Metro 

District must comply with the Metro District’s rules and 

regulations, which incorporate requirements of the 

Revegetation success at the NWTC. Photo by Genevieve Braus, 

NREL 32621 
50 ENVIRONMENTAL PERFORMANCE REPORT 2014

Clean Water Act, such as the Pretreatment Program. The 

Pretreatment Program is the set of regulations applied to 

industries and commercial operations that generate nondomestic wastewaters with potentially high levels of pollutants that could have an impact on wastewater treatment 

facilities and the environment. 

The program includes specific regulations for certain types 

of industries, for dischargers of large quantities of industrial wastewater, and for all non-domestic wastewater 

discharges. NREL’s operations are not among those identified as requiring specific discharge regulations, nor does 

the laboratory discharge a volume of water that would 

trigger requirement of a formal discharge permit from the 

Metro District for large industrial wastewater users. The lab 

does comply with all applicable requirements including 

the general probitions for all non-domestic wastewater 

discharges that protect Metro District’s collection and treatment systems. These prohibitions include the discharge of 

hazardous materials, highly viscous substances, radioactive 

material, excessive oil and grease, or other substances that 

could cause material harm to the wastewater treatment 

system and the environment. 

Program Management

NREL’s wastewater management program is multi-faceted 

and encompasses all activities at the site, from green cleaning supplies to minimization of harmful chemicals in laboratory operations, and is intended to adhere to requirements 

and minimize potential impacts to the treatment processes.

NREL staff are trained in the requirements of the Metro 

District’s rules and regulations. In addition, NREL sites have 

design criteria for waste drains in laboratory areas to minimize the possibility of a hazardous material discharge. These 

criteria include measures such as secondary containment for 

any chemicals used near sinks in laboratory exhaust hoods, 

no floor drains in laboratory areas unless a specific need 

can be shown, and caps for floor drains that are installed in 

laboratory areas. New research and operations activities as 

well as ongoing activities that undergo significant modifications are reviewed through NREL’s risk assessment process 

for their potential effect on wastewater character. 

2014 Compliance Summary and Activities

■ Program activities were in compliance with requirements. 

■ In 2014, plans were developed for a new clean room 

in the Science and Technology Facility. The clean 

room would support solar cell technology research 

and would include the washing and etching of silicon 

wafers with basic and acidic solutions. Through integrated environmental stewardship in construction 

management, as discussed in section 2.2, NREL ensured 

that the project design included an appropriate wastewater neutralization system. It is not anticipated that 

the volumes will exceed the 25,000 gallon-per-day limit 

that would require NREL to obtain a permit as a significant industrial user under the Metro District’s Rules and 

Regulations, but NREL will provide notification to both 

Metro District and Pleasant View of the newly installed 

neutralization process before discharges begin.
ENVIRONMENTAL PERFORMANCE REPORT 2014 51

Responsible acquisition, use, and disposal of materials and 

wastes are critical to meeting our commitments to compliance, preventing pollution, and environmental stewardship. NREL seeks to purchase materials that are sourced 

responsibly and contain recycled content and lower impact 

materials. Use of materials is thoughtfully controlled with 

internal procedures designed to limit health and environmental risks. Wastes are carefully managed and disposed of 

through select contractors. Areas of focus include:

■ Hazardous materials management

■ Regulated waste management

■ Aboveground storage tank management

■ Spill prevention and response 

■ Radiological materials and waste management.

8.1 HAZARDOUS MATERIALS 

MANAGEMENT

A variety of chemicals and materials, some of which are 

hazardous, are used in research activities. Hazardous materials are stored, used, and managed in a manner that is 

protective of laboratory personnel, the general public, and 

the environment. 

Requirements

Hazardous material management is regulated at the 

federal level through the requirements of the Superfund 

Amendments and Reauthorization Act, which is also 

known as the Emergency Planning and Community 

Right-to-Know Act of 1986 (EPCRA). EPCRA was created 

to help communities plan for emergencies involving 

hazardous substances. EPCRA requires hazardous 

chemical emergency planning by federal, state, and local 

governments, and industry. It also requires industry to 

report on the storage, use, and releases of hazardous 

chemicals to federal, state, and local governments. 

8

HAZARDOUS MATERIALS AND 

WASTE MANAGEMENT

Laser microscope image of a cross section of corn stover, 

from which NREL researchers have developed a less toxic 

method of creating a precursor to the production of nylon. 

NREL 20331
52 ENVIRONMENTAL PERFORMANCE REPORT 2014

NREL facilities are subject to various parts of EPCRA, which 

include Sections 302, 304, 311, 312 and 313. Please refer to 

Table 5, for NREL’s EPCRA reporting status.

NREL is also subject to permitting requirements through 

local jurisdictions and obtains annual hazardous material 

permits from West Metro Fire Rescue for the STM campus 

and Denver West Office Park facilities. These permits are 

issued for a total of seven buildings where hazardous materials are stored and/or used. Prior to issuing the permits, 

a representative from West Metro Fire Rescue conducts a 

walk-through inspection of the entire STM campus and 

Denver West Office Park. 

The Renewable Fuels and Lubricants Research Laboratory is 

within the jurisdiction of the City and County of Denver and 

is subject to the Denver Fire Department Hazardous Materials Information System requirements. This facility’s inventory 

of listed materials, including various fuels such as biodiesel, 

must be reported to the Denver Fire Department annually. 

The Denver Fire Department inspects the facility and issues 

a hazardous materials permit.

Program Management

In addition to the EPCRA reporting obligations described 

above, a cornerstone of NREL’s hazardous material 

management program is its laboratory-wide chemical 

management system, which serves as a centralized 

chemical inventory, as well as a tool for managing and 

reporting on chemicals used at the laboratory. Using an 

electronic barcoding system, the chemical management 

system tracks chemicals from the point of receipt through 

end-use and disposal. The system also contains technical 

data and reporting information for many of the chemicals 

in the chemical management system database. Key 

functions of the system include: 

■ Providing current inventories by room, building, 

and/or site 

■ Improving research efficiency and minimizing hazardous waste generation by allowing staff to determine if 

needed chemicals are already available on-site prior to 

making chemical purchases

■ Providing quick access to chemical inventories and 

hazard information during emergency responses

■ Facilitating accurate and efficient reporting to external 

agencies (e.g., fire districts, state and local emergency 

response agencies, EPA, and DOE). 

Hazardous materials are rigorously managed, starting 

with the chemical management system that tracks chemical amounts, locations, and hazards. Each week, safety 

personnel receive a list of the chemicals and their hazards 

that were shipped to NREL during the previous week. 

NREL researchers strive to limit their use of hazardous chemicals. 

Photo by Dennis Smith, NREL 33209

2014 Accomplishments and Highlights 

■ A site wide validation of accuracy of the 

chemical inventory was conducted at the 

STM campus, Renewable Fuels and Lubricants 

Research Laboratory, Denver West Office 

Park, and the NWTC. Over the course of the 

six-month effort, each chemical container’s 

barcode number, chemical name, and physical location were physically verified. 

■ There were no releases of hazardous materials requiring reporting.

TABLE 5. 2014 EPCRA REPORTING

EPCRA 

Section Description of Reporting Status

EPCRA Section 302 Planning Notification Not 

required

EPCRA Section 304 Extremely Hazardous 

Substance Release Notification

Not 

required

EPCRA Section 

311-312

Safety Data Sheet/

Chemical Inventory Reported 

EPCRA Section 313 Toxics Release 

Inventory Reporting

Not 

required

 “Not required” indicates that the laboratory was not required to 

report under the provision (e.g., did not meet the threshold or did 

not have an extremely hazardous substance release).
ENVIRONMENTAL PERFORMANCE REPORT 2014 53

Researchers and safety personnel ensure that chemicals 

are properly stored in locations suitable for any hazards, 

such as storing flammable materials in designated flammables cabinets. 

When requested by the state and local emergency 

response agencies or local fire departments, additional 

emergency response and reporting information is provided. NREL has been represented in the Jefferson County 

Local Emergency Planning Committee since its inception and is actively involved in the emergency planning 

concepts of EPCRA, with two active members on 

the committee.

Emergency response plans are also in place in the event of 

a spill or release of a hazardous material; these plans are 

coordinated with state and local emergency planning and 

response agencies and first responders, such as the West 

Metro Fire Rescue, Rocky Mountain Fire Rescue, and the 

Jefferson County Local Emergency Planning Committee. 

2014 Compliance Summary and Activities

■ All laboratory program activities were in compliance 

with requirements. 

■ Tier II hazardous materials reports were submitted to 

the required state and local emergency response and 

planning agencies, as well as local fire departments, 

for three facilities for reporting year 2013. Chemicals 

reported included diesel fuel, petroleum oil, and sulfuric 

acid in lead-acid batteries. 

■ West Metro Fire Rescue conducted an annual hazardous 

material inspection and issued permits for seven 

facilities. 

■ The inventory of hazardous materials at the Renewable 

Fuels and Lubricants Research Laboratory was provided 

to the Denver Fire Department.

8.2 REGULATED WASTE MANAGEMENT

Research and development activities and general facility 

operations create a variety of waste streams, including those 

containing toxic chemicals or metals. 

NREL typically disposes or recycles the following categories 

of waste:

■ Hazardous waste (as defined by environmental 

regulations)

■ Non-hazardous waste such as propylene glycol from 

building chillers, diesel fuel, or spent biomass processing materials; does not include municipal solid waste, 

such as regular trash

■ Universal waste such as mercury-containing light 

bulbs, lead-acid batteries, aerosol cans, and electronic 

waste such as computers, monitors, and research 

instrumentation containing electronic circuitry.

Requirements

Regulated wastes are handled and disposed of according to the federal Resource Conservation and Recovery 

Act and the State of Colorado hazardous waste regulations. Additional applicable requirements for hazardous 

material transportation fall under the U.S. Department of 

Transportation regulations. 

NREL maintains unique EPA identification numbers for each 

of its five facilities: STM, Denver West Office Park, NWTC, 

Joyce Street Facility, and Renewable Fuels and Lubricants 

Research Laboratory. Per state and federal regulations, 

Batteries used at NREL are collected and either recycled or disposed 

of in an environmentally sensitive manner. IStock Photo 43191436

2014 Accomplishments and Highlights

■ As a best management practice, all NREL 

facilities are managed to the stringent Large 

Quantity Generator status hazardous waste 

regulatory requirements, including those for 

personnel training, contingency planning, and 

container management.

■ Research staff continued to incorporate sound 

waste management practices during the early 

design phases of new research projects. 

■ Seventy-six cubic yards of internationally 

imported sugarcane bagasse was transported 

and disposed of in accordance with guidelines 

set forth by the United States Department 

of Agriculture’s Animal and Plant Health 

Inspection Service. 
54 ENVIRONMENTAL PERFORMANCE REPORT 2014

annual generator notifications are made and applicable fees 

are paid to the state based on monthly volumes of hazardous waste that are generated at each facility. The three 

waste generator classifications are:

■ Large Quantity Generator

■ Small Quantity Generator 

■ Conditionally Exempt Small Quantity Generator.

Four out of five of NREL’s EPA-permitted waste facilities 

fall under the waste generator category of Conditionally 

Exempt Small Quantity Generator because they generate 

minimal amounts of hazardous waste per calendar month. 

The STM campus typically produces quantities of hazardous 

waste well within the category of Small Quantity Generator; 

however, due to pilot-scale research experiments, the STM 

campus can episodically elevate to that of Large Quantity 

Generator category in one or more months during the year. 

Program Management

Waste management and minimization efforts begin in the 

planning stages of all experimental and operational activities. Processes are evaluated based on the quantities and 

toxicities of products that will be brought on-site before an 

activity begins and lasting until material use is complete and 

it is ready for disposal. Hazardous materials proposed for 

use are also assessed for the potential substitution of 

less hazardous products, resulting in less hazardous 

waste streams. 

The laboratory is committed to the appropriate management of regulated waste generated through its daily 

operations. These wastes are handled, stored, and disposed 

of responsibly and per regulatory requirements to minimize 

the potential for health and environmental impacts that 

could result from a release or improper disposal.

Implementation of regulatory requirements includes:

■ Documented waste management and minimization 

program

■ Annual training for all staff who generate and/or 

handle regulated waste

■ Regular inspection and tracking of all waste containers

■ Storage, packaging, shipment, and tracking until final 

disposition at a fully permitted waste disposal or recycling facility

■ Active monitoring of waste volumes to determine 

generator status

■ Maintaining records that are generated through “cradle 

to grave” waste management activities.

For select unregulated materials that still pose a potential 

hazard, NREL follows a conservative waste management 

policy through collection and disposal as non-hazardous 

materials at federally permitted disposal facilities. For 

example, non-hazardous, nanomaterial-bearing wastes are 

not federally regulated, but because they pose a potential 

health risk, are managed and disposed of via the same 

management methods used for hazardous waste. Waste 

streams are accumulated on site for timeframes well within 

regulatory limits prior to being shipped for final disposal. 

Inspecting hazardous waste packaging prior to offsite shipment and 

disposal. Photo by Eric Schmitz, NREL 32737

TABLE 6. COMPARISON OF FOUR WASTE 

CATEGORIES GENERATED AT ALL NREL 

FACILITIES [LBS. (KGS) NET WEIGHT]

Hazardous 

Waste

Non-Hazardous 

Waste

Universal 

Electronic

Waste

Other 

Universal 

Waste

2011 20,557

(9,324) 

6,156

(2,792)

29,549 

(13,403)

3,539

(1,605)

2012 33,386 

(15,144)

8,805

(3,994)

41,355 

(18,758)

4,803

(2,179)

2013 14,974

(6,792)

4,477

(2,031)

38,096 

(17,280)

19,063

(8,647)

2014 14,683

(6,659)

15,198

(6893)

28,551

(12,949)

6,738

(3,056)
ENVIRONMENTAL PERFORMANCE REPORT 2014 55

In a general order of management preference, hazardous waste items are shipped off-site for final disposal via 

incineration, treatment, and landfill. Universal wastes are 

recycled or reclaimed.

Table 6 provides a summary of quantities and types of waste 

generated at NREL for the past four years.

2014 Compliance Summary and Activities

■ Program activities were in compliance with requirements.

■ All regulatory notifications were updated and applicable waste generator fees were paid for five NREL 

facilities.

■ A Biennial Hazardous Waste Report for the STM 

campus (which detailed hazardous waste activities for 

calendar year 2013) was submitted to the state.

■ A joint hazardous waste compliance inspection of the 

STM campus was conducted, by the EPA and the state. 

Areas of focus involved waste-container management, 

proper documentation of regulated waste handling 

activities, employee training, and facility contingency 

planning. A compliance advisory was issued for one 

instance of potential incompatible materials stored 

in close proximity to each other. This issue has been 

addressed and closed out by the state.

8.3 ABOVEGROUND STORAGE TANK 

MANAGEMENT

Proper tank management prevents or minimizes the size of 

spills and leaks of fuels or oils, avoiding contamination of 

soils, surface water, groundwater, and drinking water, and 

supports the laboratory’s commitments to environmental 

stewardship and pollution prevention.

The aboveground storage tank management program 

applies to petroleum fuel tanks and is intended to:

■ Minimize releases from tanks

■ Confirm that safety features are present and functional

■ Ensure compliance with tank design, operation, training, and inspection requirements.

The risk of underground soil and water contamination from 

storage tanks is minimized by using only aboveground 

tanks where storage is required. Unlike underground tanks, 

aboveground installations provide access for regular visual 

leak inspections and allow for less costly repair and cleanup.

NREL operates several aboveground storage tanks (ASTs) 

that it maintains using best management practices and 

according to applicable regulations.

Requirements

ASTs in Colorado are regulated by the state, which 

requires that ASTs with capacities of 660 gallons (2,498 

liters) or larger be permitted prior to installation, be 

inspected by the state following installation, and be registered with the state within 30 days following commencement of use. Regulations require that ASTs be constructed 

and installed according to specific standards, be regularly inspected, that those inspections are documented, 

and that facilities meeting certain oil storage quantities 

employ a Spill Prevention, Control, and Countermeasures 

plan to manage oil sources 55 gallons (208 liters) or larger. 

(For more details, see section 8.4, Spill Prevention 

and Response.)

Eighteen ASTs are maintained at the STM campus with 

a total capacity of 13,222 gallons (50,045 liters); one AST 

2014 Accomplishments and Highlights 

■ Annual AST training was provided to all staff 

identified as having responsibility for operating and fueling ASTs.

■ A 1,000-gallon (3,785-liter) E85 vehicle fleet 

fuel tank was installed at the STM campus.

■ A retrofit of a high-level-fill, audible alarm on 

the Solar Energy Research Facility standby 

generator diesel tank was completed.

■ All tanks were reviewed to confirm continued 

adherence to recently revised regulations.

E85 fuel tank and fueling station at the STM campus. Photo by 

Larry Durbin, NREL 32761
56 ENVIRONMENTAL PERFORMANCE REPORT 2014

at Denver West Office Park with a capacity of 500 gallons 

(1,893 liters); and four ASTs at the NWTC with a total 

capacity of 1,006 gallons (3,808 liters). There are no ASTs 

at the NWTC that need to be permitted or registered. One 

2,500-gallon (9,463-liter) AST is located at the Solar Technology Acceleration Center. Five ASTs at the STM and the 

Solar Technology Acceleration Center AST are registered 

with the state.

In late 2014, the Solar Technology Acceleration Center 

tank and related experimental equipment was transferred 

to another entity and will be removed from the AST inventory. This tank will no longer be required to be registered 

by NREL with the state.

Program Management

NREL AST management program consists of permit 

compliance, inspections, tank maintenance and improvements, training, and spill response. 

There are five tanks at the STM campus that are permitted 

with the state. There are no permitted ASTs at the NWTC, 

Joyce Street, Renewable Fuels and Lubricants Research 

Laboratory, or Solar Technology Acceleration Center facilities. 

Staff actively participates in the program through:

■ Participating in project planning, safety evaluations, 

and readiness verifications

■ Conducting regular tank inspections and maintenance 

activities 

■ Achieving timely necessary regulatory approval 

■ Maintaining a current and accurate AST inventory

■ Placing spill response supplies in key locations 

■ Planning and documentation of annual training 

activities.

Personnel who operate and manage ASTs are trained 

annually on program requirements including inspection 

and response requirements, spill history of each 

site, lessons learned, and recent changes in rules 

and regulations.

Several important mechanical and procedural safeguards 

have been incorporated into NREL’s AST management 

program to prevent an accidental release of diesel or 

E85 fuel from the storage tanks. Mechanical safeguards 

include overfill and spill protection, double-wall tanks 

equipped with sensors that result in an alarm if the inner 

tank wall is leaking, and secondary containment for 

single-wall tanks. Procedural safeguards include written operating and tank-filling procedures, monthly and 

annual inspections, and recordkeeping of inspection 

results. ASTs larger than 110 gallons (416 liters) are visually inspected monthly and all double-walled ASTs are 

inspected annually to confirm that there is no liquid in the 

interstitial space.

2014 Compliance Summary and Activities

■ All program activities were in compliance with EPA and 

state AST requirements.

■ A state inspection of registered ASTs was completed 

with no violations noted.

■ The new E85 fleet vehicle fuel tank at the STM campus 

was registered with the state.

■ One 2,500-gallon (9,463-liter) AST at the Solar Technology Acceleration Center facility was sold to another 

entity and is being removed from the AST inventory 

and list of NREL-registered ASTs.

8.4 SPILL PREVENTION AND 

RESPONSE

Spills of chemicals, fuels, and oils can result in contamination to soil, surface water, and groundwater, potentially 

causing damage to ecosystems, wildlife habitat, and human 

health. Comprehensive planning using spill prevention, 

control, and countermeasures plans (SPCC) can reduce spills 

and limit impacts to the environment when spills do occur. 

Requirements

SPCC plans are required by the EPA and state of Colorado for facilities that meet certain oil storage criteria. In 

general, facilities that store more than 1,320 gallons (5,000 

liters) of oil and have the potential for a spill to enter a 

waters of the United States or a Colorado water must have 

a SPCC plan. SPCC regulations require that any equipment 

or containers with the capacity to store 55 gallons (208 

liters) or more of oil be included in the plan.

The plan must address such items as: 

■ Topography and location of waterways

■ Location and quantity of oil sources

■ Possible spill pathways

■ Spill scenarios and potential spill volumes

■ Spill prevention and response training

■ Spill notification procedures and contact information

■ Emergency response plans.

Due to the quantity of oils stored at the STM, NWTC, 

Renewable Fuels and Lubricants Research Laboratory, and 

Solar Technology Acceleration Center facilities, an SPCC 

plan is required for those locations.
ENVIRONMENTAL PERFORMANCE REPORT 2014 57

Program Management

The laboratory prepares for and continually improves 

spill response. Formal SPCC plans have been developed 

for four facilities. The plans are designed to minimize 

the number and size of spills, and speed the control and 

cleanup of spilled materials. SPCC plans are updated every 

three years, or whenever there is a significant change in 

regulations, operations, or equipment. This aggressive 

approach to spill prevention and control exceeds the EPA’s 

requirement that SPCC plans be updated at least every 

five years.

Emergency notification and hazardous materials procedures are in place to provide additional support for spill 

response. Proper preventive planning and training minimizes the potential for spills, and advance preparation for 

spill response protects water and ecological resources.

SPCC training occurs annually for individuals who are 

responsible for oil-containing equipment and aboveground storage tank operation and maintenance. SPCC 

training is combined with aboveground storage tank 

training and educates staff on oil-containing equipment at each site. Training also includes inspection and 

response requirements, location and use of spill response 

equipment, and notification and spill reporting protocols.

The laboratory typically does not experience spills that 

require notification to federal and state agencies. Small, 

incidental hydraulic system leaks, lubricant leaks, and fuel 

transfer spills may occur on occasion. Lessons learned 

from spill incidents and clean-up activities are used to 

improve management and spill response planning.

2014 Compliance Summary and Activities

■ Program activities were in compliance with all environmental requirements.

■ Workers who manage and/or operate oil-containing 

equipment received annual SPCC training. 

■ There was one reportable spill of approximately 

one gallon (3.8 liters) of hydraulic fluid from a 

Best management practices used when transferring ethanol from primary storage tank to smaller shipping containers are identified. 

Lessons learned from both NREL and industry experiences have been incorporated into NREL protocols. Photo by Tom Bain, NREL 33028 

2014 Accomplishments and Highlights 

■ The laboratory SPCC training course was 

updated to include new facilities and revised 

SPCC plans.

■ A special spill control gate was installed near 

the new E85 fuel tank to prevent fuel from 

entering a nearby storm drain in the event of 

a spill.

■ Four additional large portable spill control kits 

were placed at key STM campus locations to 

provide a more rapid response capability.

Containment

■ DOT shipping container purged of oxygen 

to reduce flammability potential

■ Secondary containment provided

■ Bonding and grounding to control static 

electricity.

Filling

■ Low-flow diaphragm pump provided to 

slow filling and minimize vapor emissions

■ Extra-long fill pipe used to prevent splashing and minimize generation of vapor 

emissions

■ DOT shipping container only filled to 80% 

capacity to minimize potential for overflow.
58 ENVIRONMENTAL PERFORMANCE REPORT 2014

vehicle-related release that entered a Colorado water. 

The fluid did not leave NREL property and resulted 

in no violation or compliance action. Immediate 

notification was made to the state and a written report 

was submitted to the state following completion 

of cleanup activities that included deployment of 

sorbent materials in the forebay of the STM stormwater 

detention basin. No additional action was required by 

the state.

■ Twenty-one minor spills of diesel, lubricant, coolant, 

and hydraulic fluids occurred at the STM campus, 

and one spill occurred at the NWTC. The size of spills 

ranged from less than 0.1 gallon to 12 gallons (0.38 to 

45 liters). The majority of these spills were the result of 

leaks from vehicles and construction equipment. Each 

spill received immediate remedial action and did not 

result in any significant impact to the environment.

8.5 RADIOLOGICAL MATERIALS AND 

WASTE MANAGEMENT

NREL conducts a wide range of research and operational 

activities that incorporate the use of radiological 

materials. The laboratory occasionally uses small 

quantities of radioisotopes for biological labeling and 

electron microscopy staining. All of the radioisotopes 

have very low activity levels and are used in extremely 

small amounts. A number of sealed sources are present 

in analytical and process equipment, check sources, and 

emergency exit signs. Unlike many DOE facilities, NREL 

does not have legacy radiological contamination issues 

associated with past nuclear weapons production 

and research.

Requirements

Radiological air emissions are regulated by the EPA. DOE 

Order 458.1, Radiation Protection of the Public and the 

Environment, establishes radiation emission limits for DOE 

facilities. These facilities, including NREL, must annually 

demonstrate compliance with EPA radiological air standards that limit emissions to amounts that would prevent 

any member of the public from receiving an effective 

dose equivalent of 10 mrem per year or greater.

Program Management

NREL has established strict protocols for radiation-generating devices, equipment containing sources of radiation 

or for the use of radioisotopes in laboratory experiments 

through its radiation safety program. Some of these

controls include:

■ Confining work with radioisotopes to a small number 

of specific laboratories

■ Limiting the types and quantities of radioisotopes 

onsite

■ Monitoring equipment and facilities for removable 

contamination or sealed-source leakage.

No radioactive air emission monitoring is conducted 

at the laboratory because of the extremely low usage 

of radioactive material. Therefore, NREL demonstrates 

compliance with radiological air emission standards by 

using an EPA computer model (COMPLY Version 1.6) to 

determine the effective dose equivalent to the public. 

Current laboratory procedures prohibit any activity that 

may result in a radioactive waste that is also federally 

regulated under the Resource Conservation and 

Recovery Act and thus categorized as “mixed waste.” 

To understand effective dose equivalent, you must 

first define dose and dose equivalent:

■ Dose –a generic term to describe the amount of 

radiation a person receives.

■ Dose Equivalent – a measure of the biological 

risk of the energy that the radiation deposited in 

tissue, which depends on the type of radiation 

and the tissues exposed. The units of dose equivalent are called rems, and a thousandth of a rem is 

called a millirem, abbreviated as mrem.

■ Effective Dose Equivalent – the total of the dose 

equivalent to the organ or tissue multiplied by 

weighting factors applicable to each of the body 

organs or tissues that are exposed to radiation.

An average person in the United States receives 

about 310 mrem each year from natural sources and 

an additional 310 mrem from medical procedures 

and consumer products.

What Is “Effective Dose Equivalent?”
ENVIRONMENTAL PERFORMANCE REPORT 2014 59

Therefore, all radioactive waste generated is classified 

solely as low-level waste. Waste is temporarily stored 

on-site until disposal is arranged at an off-site facility 

permitted to accept low-level radioactive waste. Internal 

procedures prohibit the clearance of property unless it 

has been decontaminated to background levels.

2014 Compliance Summary and Activities

■ Program activities were in compliance with 

requirements. 

■ Only small quantities of low-level radioactive waste 

were generated and are currently in storage awaiting 

off-site disposal.

■ The effective dose equivalent to the public was 0.036 

millirem (mrem) per year, far below the 10 mrem per 

year limit.
60 ENVIRONMENTAL PERFORMANCE REPORT 2014

9 

NATIONAL ENVIRONMENTAL 

POLICY ACT

NREL’s National Environmental Policy Act (NEPA) 

program provides a mechanism to consider the potential 

for environmental impacts in decision-making processes 

and to promote sustainable and environmentally 

responsible operations. Under this program, the staff 

analyze the potential impacts for a wide range of activities prior to spending funds or commencing work. 

Examples of activities requiring a NEPA analysis include 

new or revised laboratory research, construction activities, partnering arrangements, feasibility studies, and 

data analyses.

Requirements

NEPA is a federal law that requires potential 

environmental impacts to be considered for activities 

with a federal connection, such as those using federal 

funds, property, facilities, and equipment. NEPA 

represents the federal government’s mandate to 

consider the environment equally to other factors when 

making decisions. It directs federal agencies to take 

into account, and publicly disclose, the environmental 

consequences of proposed actions. 

Soon after NEPA was passed at the end of 1969, the 

president’s Council on Environmental Quality enacted 

regulations that provided direction to federal agencies 

on how NEPA should be implemented. Subsequently, 

DOE established its NEPA Implementing Procedures that 

it, and NREL, use to comply with NEPA and the Council 

on Environmental Quality regulations. 

Under NEPA, federal agencies consider and document 

environmental factors in decision-making processes 

using one of three levels of analysis: 

■ Categorical Exclusion (CX)

■ Environmental Assessment (EA)

■ Environmental Impact Statement (EIS).

Sun Edison 1.1 MW photovolatic array at the NWTC. 

Photo by Dennis Schroeder, NREL 30551
ENVIRONMENTAL PERFORMANCE REPORT 2014 61

Categorical Exclusion

A CX determination is the lowest level of NEPA review 

and can be applied to activities that are known not to 

have a significant individual or cumulative effect on the 

quality of the human and natural environment. Each 

agency has a unique set of CXs based on their own 

routine activities. Examples of DOE’s include information 

gathering and data analysis; specific types of site and 

facility maintenance and improvement; small-scale 

renewable energy research and development projects; 

and environmental monitoring.

Environmental Assessment

If the proposed action does not fit into a DOE CX, or there 

are extraordinary circumstances present (such as potential effects to environmentally sensitive areas or resources 

and public controversy), or the proposed action fits within 

a category of actions that DOE has determined to typically 

require an EA, then an EA must be prepared. The purpose 

of an EA is to determine the significance of the environmental effects and to look at alternative means to achieve 

the agency’s objectives. The EA also provides sufficient 

evidence and analysis for determining whether or not to 

prepare and EIS, and facilities preparation of an EIS when 

one is necessary. 

An EA is prepared for classes of activities such as siting, 

construction, and/or operation of energy system demonstration actions including wind, hydropower, geothermal, 

biomass, and solar energy projects and operations. The EA 

allows for public review and comment, and demonstrates 

compliance with NEPA (i.e., it helps to identify better alternatives and mitigation measures). When environmental 

analysis and interagency review conducted during the EA 

process conclude that no significant impacts will occur 

related to the quality of the environment, a Finding of No 

Significant Impact is issued. 

Environmental Impact Statement

An EIS provides a detailed analysis of projects that have 

significant prospective environmental impacts. The 

EIS provides a discussion of significant environmental 

impacts and reasonable alternatives that would avoid 

or minimize adverse impacts or enhance the quality 

of the human and natural environment (including the 

consideration to not pursue the project). An EIS is also 

made available for public review and comment. As a 

final step, a Record of Decision is prepared, which states 

the decision, the alternatives considered, including the 

environmentally preferred alternative, and discusses 

mitigation plans, including any enforcement and 

monitoring commitments. It should be noted that NREL, 

to date, has had no activities have required an EIS.

Program Management

NREL employees initiate the NEPA process and provide 

support to DOE Golden Field Office in conducting a NEPA 

analysis before an activity begins. In accordance with 

regulations, all NREL activities (both on- and off-site) must 

undergo a NEPA environmental review. The outcome of 

this review is considered the NEPA determination. A final 

determination must be completed before federal funds 

are expended, before a contract award can be made, and 

before project activities begin.

NREL and DOE Golden Field Office use a type of programmatic NEPA document unique to DOE to streamline the 

2014 Accomplishments and Highlights 

■ Completed the NWTC Site-Wide Environmental Assessment and Finding of No Significant 

Impact. This included a public meeting and a 

30-day public review and comment period.

■ Completed the STM Site-Wide Environmental 

Assessment and Finding of No Significant 

Impact. This included a public meeting and a 

30-day public review and comment period.

■ Continued to provide NEPA support in the preparation of proposals for DOE Funding Opportunity Announcements that support DOE’s 

mission and the nation’s energy objectives.

An NREL postdoctoral fellow operates an ultra-high vacuum surface 

analysis cluster tool at the Science and Technology Facility to 

decrease solar cell material costs through the optimization of earthabundant inorganic materials. Photo by Dennis Schroeder, NREL 29029
62 ENVIRONMENTAL PERFORMANCE REPORT 2014

environmental review process. These programmatic NEPA 

documents, known as Site-Wide EAs, are comprehensive 

site-wide analyses of potential environmental impacts 

associated with NREL’s current and future actions over a 

period of five to ten years. These serve as planning tools 

that aid ongoing and future operational and development 

decisions related to NREL’s sites. The Site-Wide EAs for the 

STM and NWTC provide a baseline environmental analysis 

that streamlines future environmental reviews; improves 

and coordinates site and agency planning; and maximizes 

cost savings. 

If proposed activities have not already been evaluated 

in an existing Site-Wide EA or supplemental NEPA document, then further environmental analysis must be 

conducted. Potential environmental impacts of an activity 

are evaluated and measures are taken, as needed, to avoid 

or minimize those impacts. The level of review conducted 

is appropriate to the potential impacts of the proposed 

activity. A planned construction project, for example, 

receives a more rigorous review than routine office or 

laboratory work

2014 Compliance Summary and Activities

■ Complied with program activities requirements

■ Conducted 390 NEPA reviews for project activities onand off-site during 2014

■ Finalized both the NWTC and the STM Site-Wide EAs 

and Findings of No Significant Impact in 2014 

■ Completed two assessments of the NEPA program, 

resulting in identification of several findings and 

opportunities for improvement. These findings related 

to inconsistencies in the application of the NREL NEPA 

procedure. The assessment results will be addressed 

in 2015. 

Western Kingbird nest in a tree near the Research Support Facility. 

Photo by Bob Fiehweg, NREL 32754
ENVIRONMENTAL PERFORMANCE REPORT 2014 63

10

NATURAL AND CULTURAL 

RESOURCES PROTECTION

NREL is committed to responsible stewardship of its 

natural ecosystems, native wildlife, vegetation, and 

important cultural resources. Natural resources at the 

STM and NWTC facilities are managed appropriately to 

ensure NREL’s research needs are met while protecting 

native wildlife and vegetation. Responsible management not only benefits our environment, but also 

NREL employees and the surrounding community, and 

demonstrates the laboratory’s leadership in the DOE and 

federal government as a whole. Management focuses on 

these key areas:

■ Wildlife management

■ Endangered species and species of concern

■ Vegetation management

■ Wetlands and floodplains

■ Cultural resources.

10.1 WILDLIFE MANAGEMENT

The wildlife management program promotes responsible 

wildlife and habitat management, and gathers information to better consider impacts to wildlife when implementing projects onsite. 

Many surrounding landowners, including residential 

neighbors and Jefferson County Open Space, value 

the benefits of maintaining wildlife habitat and 

opportunities to observe wildlife. Proper wildlife 

management at NREL therefore provides an important 

benefit to our community.

A variety of wildlife are seen at NREL campuses, where 

efforts are made to protect wildlife and preserve and 

enhance habitat. Photo by Brent Nelson, NREL 23922
64 ENVIRONMENTAL PERFORMANCE REPORT 2014

Requirements

A Colorado statute, several federal laws, and an executive order comprise the regulatory framework for NREL’s 

wildlife management program. (Please refer to section 9, 

National Environmental Policy Act, and 10.2, Endangered 

Species and Species of Concern, for discussion of other 

federal laws relating to wildlife management.) 

Wildlife is considered a state resource under Colorado 

law, and no wildlife dens or nests, young, or eggs may be 

damaged or destroyed unless permitted by the Colorado 

Division of Parks and Wildlife. It is unlawful for any person 

to willfully harass wildlife.

The Migratory Bird Treaty Act is the main driver for 

protecting migratory birds in the United States. In the 

biological sense, a migratory bird is a bird that has a 

seasonal and somewhat predictable pattern of movement. Generally, this includes all native birds in the United 

States, except those non-migratory species such as quail 

and turkey that are managed by individual states as game 

species. Currently, there are 1,026 species of birds protected by this law.

2014 Accomplishments and Highlights

■ Continued acoustic bat monitoring at two NWTC 

locations and documented the presence of several 

species of bats at the NWTC. This monitoring from 

May through October 2013 and April through June 

2014 provided information on bat activity and 

usage of the site. Data results are shown in Figures 

5 and 6 see page 66. 

■ Retrofitted the Energy Systems Integration 

Facility windows in August 2014 with visible 

markers (i.e., dots) to reduce the potential for bird 

strikes. From August 2013 through November 

of 2013, several birds collided with the facility’s 

windows. After the windows were retrofitted, no 

additional bird strikes occurred from September to 

mid-November 2014.

■ Installed a series of nest boxes around the 

stormwater detention basin for the STM campus 

to provide housing for a number of species, which 

include kestrels, bluebirds, wood ducks, bats, 

mason bees, and chickadees.

■ Continued monitoring of mammalian predators at 

the STM and NWTC campuses in 2014. Collected 

data from two motion detection cameras at each 

site. STM cameras confirmed continued use of the 

site by several species, including red fox (Vulpes 

vulpes), coyote (Canis latrans), and striped skunk 

(Mephitis mephitis). NWTC cameras, once again, 

recorded two mammalian predators, coyote and 

bobcat (Felis rufus). Interesting coyote behavior 

was recorded: checking the scent station as a pack, 

and reacting to deer protecting themselves from 

the potential predator.

■ Developed a prototype radar system that can 

detect large birds with the collaboration of staff 

biologists, NWTC wind researchers, and an industry 

partner during the 2014 spring and summer 

seasons. The intention of the prototype would 

be to detect raptors as they enter the airspace of 

wind farms. Biologists performed raptor surveys 

surrounding the NWTC and recorded species, time, 

distance, and altitude while the radar equipment 

was operational. The survey results were used to 

evolve the radar software into the next phase of 

the project, which was the use of a trained falcon 

able to carry a GPS device to record location data 

during flight. The radar system holds promise in 

allowing wind farms early detection of large birds, 

from which operational modifications can be made 

to reduce bird-turbine strikes.

■ Held a community open-house with DOE Golden 

Field Office in October 2014, during which 

information concerning environmental stewardship 

at NREL campuses was presented. Topics discussed 

included the vegetation at the STM campus, past 

wildlife studies, cultural resources, and how NREL 

assesses environmental impacts. 

■ Provided staff assistance to DOE Golden 

Field Office in documenting migratory bird 

protection measures incorporated into STM 

infrastructure projects. DOE Golden Field Office 

subsequently received national recognition for 

the collaborative efforts.
ENVIRONMENTAL PERFORMANCE REPORT 2014 65

The Migratory Bird Treaty Act makes it a federal crime to 

“take” birds or bird parts, including feathers, or to kill birds 

unless permitted by regulations issued by the U.S. Fish and 

Wildlife Service. The term “take” means to pursue, hunt, 

shoot, wound, kill, trap, capture, or collect any protected 

migratory bird or any part, nest, or egg of any protected 

migratory bird or to attempt those activities. The U.S. Fish 

and Wildlife Service has developed a system of permits for 

activities that involve the “take” of migratory birds, including those governing scientific collection and bird banding, and lethal and non-lethal measures taken to prevent 

depredation of agricultural crops and to protect public 

health and safety. 

In 2001, EO 13186, Responsibilities of Federal Agencies to 

Protect Migratory Birds, set requirements for federal agencies to minimize their impacts to migratory birds, to work 

cooperatively with the U.S. Fish & Wildlife Service, and to 

establish an interagency migratory bird committee for 

collobration and information sharing. Additionally, the U.S. 

Fish & Wildlife Service issued guidance identifying goals 

for federal program activities based upon this executive 

order. This guidance highlighted measures to avoid and/or 

minimize potential impacts to migratory birds, eggs, and 

active nests, including but not limited to:

■ Project modification

■ Time-of-year restrictions on vegetation clearing

■ Avoidance of cavity trees, colonial bird nests, and other 

active nests

■ Avoidance of nests of species of concern.

The U.S. Fish & Wildlife Service also works to ensure that 

environmental analyses of federal activities under NEPA or 

other established environmental review processes evaluate the effects of actions and agency plans on migratory 

birds, particularly on species of concern.

The 2013 Memorandum of Understanding between DOE 

and the U.S. Fish & Wildlife Service regarding implementation of EO 13186 formalizes DOE’s commitments regarding 

the protection of migratory birds. Under the MOU, DOE 

agrees to integrate migratory bird conservation principles, 

measures, and practices into agency activities, and avoid 

or minimize, to the extent practicable, adverse impacts on 

migratory bird resources and their habitats.

Program Management

NREL’s wildlife management program was developed to 

implement measures to allow the laboratory to meet or 

exceed the regulatory requirements discussed above and 

to minimize or avoid impacts to wildlife species and their 

habitats while achieving NREL’s mission. 

Staff biologists work with project managers and decisionmakers as part of an integrated project team on construction projects to minimize impacts to wildlife and maintain 

habitat by avoiding sensitive areas and reclaiming lands 

once disturbance is complete.

A long-term objective is to maintain wildlife movement 

through the STM campus by retaining linkages between 

the open space areas north of the site, and Pleasant View 

Community Park and Lena Gulch to the south. At the 

NWTC, ecologically sensitive areas are preserved within 

the site and linkages with surrounding open space areas 

are maintained. At both campuses, periodic monitoring 

using wildlife surveys informs responsible management.

When control of pest wildlife species is necessary, a graded 

approach is used to humanely control pests and minimize other potential impacts. Building design features 

and administrative controls are the first line of defense 

against pests. When these are not fully effective, additional 

controls are used. Pests are relocated whenever possible. 

A coyote pack is captured by motion detection camera near an 

NWTC scent station. Photo by Tom Ryon, NREL 32776

The Gyrfalcon (nicknamed Houdini) and handler prepare for radar 

testing on the Rocky Flats Refuge south of the NWTC. NREL staff 

coordinated with the U.S. Fish and Wildlife Service Refuge Office to 

use the refuge for research aimed at reducing raptor/turbine blade 

interactions. Photo by Jason Roadman, NREL 32614
66 ENVIRONMENTAL PERFORMANCE REPORT 2014

When pests must be destroyed, mechanical methods are 

preferred over poisoning. When necessary, pesticides 

are selected that pose the least harmful effects to 

non-target wildlife. 

Several activities occur periodically to achieve the 

program’s intent:

Monitoring – The laboratory conducts nesting bird 

surveys prior to any ground- or vegetation-disturbing 

activities conducted between March 15 and September 

15 every year. If nests are found, the area is closed with a 

proper buffer area until nestlings fledge. Staff conducts 

periodic surveys on a site-wide basis to document biological conditions at NREL facilities. 

Surveys currently underway involve monitoring bat presence at the NWTC. Using microphones mounted on two 

meteorological towers (NWTC1 and NWTC2), bat calls 

have been collected from May through October 2013, and 

April through July 2014. Using the calls as an approximation of the number of times bats passed the meteorological towers, September 2013 results showed 50 passes, 

while June 2013 results indicated more than 3,000 bat 

passes (Figure 5). By comparing the recorded calls with 

Estimated Bat Passes at the NWTC

2013 and 2014

4000

3500

3000

2500

2000

1500

1000

500

0

May

13

June

13

July

13

Aug

13

Sept

13

May

14

Apr

14

Jun

14

Jul

14

Estimated

Number

of Passes

NWTC 1

NWTC 2

Figure 6. Bat species detected at the NWTC during 2013 and 2014 monitoring periods

Figure 5. Bat detections at the NWTC during 2013 and 2014 monitoring periods

Estimated Bat Passes by Species at the NWTC

2013 and 2014

0

500

1000

1500

2000

May

13

June

13

July

13

Aug

13

Sept

13

May

14

Apr

14

Jun

14

Jul

14

Estimated

Passes

Identified

by Species

Brazilian free-tail bat

Undetermined species

Hoary bat

Silver-haired bat

Big brown bat
ENVIRONMENTAL PERFORMANCE REPORT 2014 67

standard calls of a particular species, the following bats 

were detected: Big brown bat (Eptesicus fuscus), the 

Silver-haired bat (Lasionycteris noctivagans), the Hoary bat 

(Lasiurus cinereus), the Brazilian free-tailed bat, and three 

species of Myotis (Figure 6). These data provide information on bat activity and usage of the site.

Project Reviews – Biologists conduct project reviews to 

assess and reduce potential impacts to wildlife.

Coordination – Biologists coordinate with local, state, 

and federal agencies to improve wildlife management. 

They conduct these activities in concert with surveys 

for threatened and endangered species and habitats. 

(For more details, see section 10.2, Endangered Species 

and Species of Concern.) Because habitat is as much of 

a concern as the wildlife species themselves, program 

activities often overlap with vegetation management.

2014 Compliance Summary and Activities

■ Completed bird-friendly retrofits to the glass located in 

the Energy Systems Integration Facility main entrance 

and all east facing windows. This effort is consistent 

with the requirements of the Migratory Bird Treaty Act. 

■ Included Migratory Bird Treaty Act discussions as part 

of the Endangered Species Act consultations with the 

U.S. Fish and Wildlife Service for the Site-Wide Environmental Assessments for the NWTC and STM campuses. 

■ Reported on migratory bird protection activities on 

NREL campuses for the 2013 Council for the Conservation of Migratory Birds Annual Report. This is required 

by 13186, Responsibilities of Federal Agencies to Protect 

Migratory Birds.

10.2 ENDANGERED SPECIES AND 

 SPECIES OF CONCERN

NREL manages research and operational activities to 

preserve and protect environmental quality. The laboratory is committed to the protection of imperiled species, 

and monitors for these species at its two main campuses: 

the STM and the NWTC.

Periodically, surveys are conducted for declining wildlife 

species and rare plants, including species that are federally or state protected, or otherwise considered imperiled 

or declining. Biologists also survey for potential habitat 

for these species. Should potential habitat be found, more 

targeted surveys may be conducted. These surveys identify the presence or absence of rare species or their habitats and aid in siting and planning new projects. While no 

protected or declining species have been detected at an 

NREL facility, appropriate steps would be taken should 

such a species be found.

Requirements

The federal Endangered Species Act provides for the 

designation and protection of wildlife, fish, and plant 

species that are in danger of extinction, and preserves the 

habitats on which these species depend. Federal agencies 

are required to abide by the Endangered Species Act and 

ensure that their actions do not adversely affect species 

that are federally listed under the Endangered Species Act 

as threatened, endangered, or candidate species.

The U.S. Fish and Wildlife Service (USFWS), which administers the Endangered Species Act, lists nine species in as 

threatened, endangered, or a candidate for listing that 

could potentially occur in Jefferson and Boulder Counties 

combined. Of these species, three have the potential to 

occur at the STM or the NWTC campuses, including the 

Preble’s meadow jumping mouse, the Ute ladies’ tresses 

orchid, and the Colorado butterfly plant.

Additional federal and state laws and regulations protect 

wildlife, such as the Bald and Golden Eagle Protection 

Act. The Colorado Division of Parks and Wildlife identifies 

a list of endangered, threatened, and wildlife species of 

concern for Colorado. Furthermore, the Colorado Natural 

Heritage Program has a list of rare species that, while not 

regulatory in nature, is useful as it is the only designation besides the Endangered Species Act that considers 

rare plants. The list of threatened, endangered, candidate 

species, and species of concern (i.e., bald and golden 

eagles, state-listed species, and Colorado Natural Heritage 

Program species) are all considered imperiled species 

Energy Systems Integration Facility main entrance windows after 

a special film was applied to help prevent bird collisions. Photo by 

Dennis Schroeder, NREL 31185
68 ENVIRONMENTAL PERFORMANCE REPORT 2014

and can be referred to as a group known as “Threatened, 

Endangered, or Species of Concern” species.

Program Management

NREL conducts periodic surveys for the three listed 

species that have the potential to occur at the STM and 

NWTC campuses in order to document their presence or 

absence. While the Preble’s meadow jumping mouse does 

not occur on-site, the USFWS designated critical Preble’s 

habitat within the upper reaches of Rock Creek, including a small area at the southeast corner of the NWTC. This 

area may not be disturbed without coordination with 

the USFWS.

NREL also considers other plant and animal species 

that may be state listed or generally in decline. Current 

information is obtained from both the Colorado Division 

of Parks and Wildlife and the Colorado Natural Heritage 

Program. These two entities work together to track declining species and habitats throughout Colorado. Although 

not required by federal regulation, periodic surveys 

are conducted for species that may occur at NREL sites, 

typically every five years when baseline vegetation and 

wildlife studies are conducted. These baseline surveys are 

a vital part of NREL’s National Environmental Policy Act 

program where impacts to natural resources from mission 

activities are assessed.

The USFWS lists five other species occurring in the 

Platte River watershed in Nebraska in accordance with 

the Endangered Species Act as species that must be 

considered for projects in Colorado and Wyoming that 

may deplete water supplies to the Platte River system. 

These include three birds, the piping plover (Charadrius 

melodus), the whooping crane (Grus americana), and the 

least tern (Sternula antillarum); a fish, the pallid sturgeon 

(Scaphirhynchus albus); and a plant, the western prairie 

fringed orchid (Platanthera praeclara). For any NREL activities that may deplete water in the Platte River system, 

a consultation with the USFWS must be completed to 

determine potential impacts. 

2014 Compliance Summary and Activities

■ Program activities were in compliance with 

requirements.

■ NREL assisted DOE in Endangered Species Act consultations with the USFWS that were conducted as part 

of the development of the Site-Wide Environmental 

Assessments for the NWTC and STM campuses. 

■ NREL and DOE prepared Biological Assessments for the 

NWTC and the STM campuses that evaluated potential 

depletion of water to the South Platte River system 

from continued and proposed site activities included 

in the Site-Wide Environmental Assessments. 

■ Biological Opinions for the NWTC and STM campuses 

were received from the USFWS that indicated that the 

proposed water-related actions are covered under the 

Programmatic Biological Opinion developed for the 

Platte River Recovery Implementation Program. 

10.3 VEGETATION MANAGEMENT

Native plants have evolved over long periods of time in 

harmony with the local climate and surrounding soil, 

growing in association with microorganisms and resident 

wildlife to create bio-diverse ecosystems. Through this 

evolution, native plants have developed natural defenses 

against pests and diseases specific to their locale. When 

non-native plants are introduced into an environment, 

they often overcome indigenous plants, attracting new 

types of pests and diseases and out-competing native 

plants for nutrients and water, while also sometimes 

depriving wildlife of nutrients and shelter. Plants such as 

kochia (Bassia scoparia), Canada thistle (Cirsium arvense), 

Russian olive (Elaeagnus angustifolia), diffuse knapweed 

(Centaurea diffusa), dalmation toadflax (Linaria vulgaris), 

and myrtle spurge (Euphorbia myrsinites) are examples of 

non-native plants that can have destructive effects on 

natural habitats.

Landscaped areas near buildings and common areas at 

both campuses are designed and installed with sustainability in mind, and include features such as native plantings, xeriscape principles appropriate for arid climates, 

and infiltration of stormwater to provide water and nutrients to landscape plants and to recharge groundwater in 

the area. 

Requirements

Vegetation management at NREL must meet the requirements of EO 13112, Invasive Species, the Federal Noxious 

Weed Act, and the Federal Insecticide, Fungicide and 

Rodenticide Act. 

The Federal Insecticide, Fungicide, and Rodenticide Act 

regulates the use, storage, and disposal of herbicides and 

pesticides. For application of certain types of herbicides 

designated as “restricted-use” by the EPA, a person with a 

certified applicator license must be used. Application of 

restricted-use herbicides is conducted in accordance with 

the regulation. NREL currently uses contractors for this 

type of application.

At the STM campus, vegetation management of 177 

acres are under a conservation easement agreement with 
ENVIRONMENTAL PERFORMANCE REPORT 2014 69

Jefferson County, which requires that the unique landscapes within the easement are left undisturbed. 

(For more details, see Section 11, Conservation 

Easement Lands.) 

NREL voluntarily complies with the Colorado Noxious 

Weed Act. 

Program Management

The focus of NREL’s vegetation management program 

is to:

■ Conserve existing ecosystems in their natural state as 

much as possible 

■ Strive to replace disturbed vegetation with native 

species, or with adapted but non-invasive species 

when necessary

■ Implement a program of weed management to 

prevent the spread of noxious weeds and implement 

measures to control these species

■ Implement a sustainable landscape design and maintenance program.

Approximately 60 acres of land within the NWTC campus 

boundaries are managed as conservation areas. As within 

the STM’s 177-acre conservation easement, the laboratory 

limits development in these areas at the NWTC campus 

and manages them to conserve specific features including seeps, ephemeral drainages, ponds, native grassland 

habitat, areas supporting ancient soils (a soil structure in 

association with plant species forming a stable ecological community that is resistant to weed invasion), a small 

area designated as critical habitat for the Preble’s meadow 

jumping mouse, an area of remnant tallgrass prairie, 

and a rocky outcropping supporting ponderosa pine 

and shrublands.

To maintain the existing native vegetation and to ensure 

the success of revegetated areas, the laboratory has 

developed sustainable landscape management 

practices that:

■ Provide supplemental water during seedling growth 

and establishment, and minimize water use thereafter

■ Reduce the need for and use of pesticides and 

fertilizers

■ Reduce maintenance costs

■ Maximize ground cover to reduce soil erosion

■ Establish a variety of habitats to support diverse 

wildlife

■ Create an aesthetically pleasing landscape 

environment.

Where removal of native vegetation cannot be avoided, 

reseeding is done using grass and forb seed mixes native 

to the local area. A palette of native flowering plants, 

shrubs, and trees has been identified for use on both the 

STM and NWTC campuses to enhance ecosystem diversity and integrity. NREL staff continually evaluates and 

modifies revegetation techniques as needed to promote 

healthy plant establishment.

During construction of the Research Support Facility, NREL participated in the Sustainable Sites Initiative 

two-year pilot program, which was established by the 

American Society of Landscape Architects, the Lady Bird 

Johnson Wildflower Center at the University of Texas at 

Austin, the United States Botanic Garden, and a diverse 

group of other stakeholders. While a green-building rating 

system (i.e., Leadership in Energy and Environmental 

2014 Accomplishments and Highlights 

■ Monthly review and coordination meetings 

were conducted to assess the success 

of seasonal herbicide applications and 

revegetation efforts.

■ Knapweed is under control at the NWTC 

campus.

■ Canada thistle, houndstongue (Cynoglossum 

officinale), and myrtle spurge (Euphorbia 

myrsinites) continue to be under control at the 

STM campus. 

■ Regular maintenance will be performed to 

continue the control of these species.

Wildflowers at the NWTC. Photo by Warren Gretz, NREL 05303
70 ENVIRONMENTAL PERFORMANCE REPORT 2014

Design (LEED) certification) for new and existing buildings currently exists, there is no similar rating system for 

landscaped environments. The purpose of the Sustainable 

Sites Initiative program is to develop the first national 

rating system for sustainable landscapes. NREL received a 

rating of three out of four stars for the development of our 

Sustainable Sites Initiative pilot program, the implementation of which is ongoing. 

NREL uses an integrated weed management approach 

that incorporates various types of weed control methods 

including mechanical practices (e.g., mowing or hand 

pulling), cultural (e.g., reclamation of disturbed areas), 

prevention (e.g., limiting or eliminating driving of vehicles 

off established roadways), and herbicide treatment. The 

effectiveness of control methods is periodically assessed. 

The use of multiple strategies for control has been 

successful in significantly reducing populations of diffuse 

knapweed (Centaurea diffusa) and Canada thistle (Cirsium 

arvense). The weed control program maintains the flexibility needed to respond to changes in weed populations 

from year to year. Periodic mapping of weed infestation 

areas assists in targeting weed control efforts.

The laboratory continues to address the control of 

these species using the integrated weed management 

approach described above. Comprehensive sitewide 

weed surveys and mapping are performed approximately every 5 years; smaller areas of both campuses are 

assessed annually. A list of noxious weed species identified at the STM and the NWTC is found in Table 7.

For information on rare and imperiled plant species, see 

section 10.2, Endangered Species and Species of Concern. 

2014 Compliance Summary and Activities

■ Program activities were in compliance with 

requirements.

■ In June, a representative from the Colorado Department of Agriculture was invited to tour the area near 

the historical ammunition bunker on the STM campus 

to advise on methods to eliminate the A-listed noxious 

weed, myrtle spurge. It was recommended that hand 

pulling of the remaining sprigs would be an effective method in the late summer. This was completed 

in August.

■ At the NWTC campus, herbicides were applied to 

control B- and C-listed weeds to approximately 60 

acres in April, 17 acres in June, and 40 acres in August. 

■ At the STM campus, herbicides were applied to control 

B- and C-listed weeds to approximately 27 acres in 

May, 13 acres in June, and 4 acres in October.

TABLE 7. NOXIOUS WEED SPECIES IDENTIFIED 

AT THE STM AND THE NWTC

Noxious Weed 

Class

Species Present at 

STM

Species Present at 

NWTC

Class A: Myrtle spurge None

Class B:

Canada thistle

Common teasel

Dalmation toadflax

Diffuse knapweed

Hoary cress 

(whitetop) 

Hound’s tongue

Musk thistle

Russian olive 

Scotch thistle

Canada thistle

Chicory

Dalmation toadflax

Diffuse knapweed

Hoary cress 

(whitetop)

Leafy spurge

Musk thistle

Sulfur cinquefoil

Class C: 

Field bindweed

Cheatgrass 

Field bindweed

Cheatgrass

Native grass and natural landscape materials provide food and 

shelter for NREL wildlife. Photo by Michelle Slovensky, NREL 27577
ENVIRONMENTAL PERFORMANCE REPORT 2014 71

10.4 WETLANDS AND FLOODPLAINS 

Floodplains are land areas adjacent to rivers and streams 

that are subject to recurring inundation. Wetlands are 

lands that are inundated or saturated by surface or 

groundwater at a frequency and duration sufficient 

to support distinct soil types and plant communities. 

Wetland areas typically take the form of swamps, marshes, 

bogs, and groundwater seeps and are frequently located 

within or adjacent to a floodplain.

Both wetlands and floodplains play a key role in providing 

floodwater storage, reducing flood flow rate and filtering floodwater. The resulting enriched floodplain soils 

promote the growth of wetland and riparian vegetation 

that provide habitat for a rich diversity of terrestrial and 

aquatic plants and animals. NREL preserves the important 

natural functions of its wetlands and floodplains, thereby 

protecting the physical, biological, and chemical integrity 

of receiving waters and riparian areas on and adjacent to 

the STM and NWTC campuses.

Requirements

Wetlands became regulated in 1972 when, under the 

Clean Water Act, the definition of waters of the United 

States was expanded to include tributaries to navigable 

waters, interstate wetlands, wetlands that could affect 

interstate or foreign commerce, and wetlands adjacent to 

other waters of the United States. Wetlands that fit within 

the definition and that meet certain soils, vegetation, and 

hydrologic criteria are federally protected under programs 

administered by the U.S. Army Corps of Engineers, with 

program oversight provided by the EPA. These regulated 

wetlands are known as jurisdictional wetlands. Areas 

that do not meet the criteria above are not protected or 

regulated but still perform wetland functions and act as 

valuable ecologic components. 

Wetland areas identified at the STM and NWTC campuses 

are managed as a valuable natural resource and in a 

manner consistent with the Clean Water Act as well as EO 

11990, Protection of Wetlands, which requires that federal 

agencies minimize the destruction, loss, or degradation of 

wetlands; follow DOE policy to carry out the requirements 

of EO 11990; and preserve and enhance the natural 

and beneficial values of wetlands in carrying out the 

agency’s responsibilities.

Counties regulate floodplains by mapping the 100-year 

floodplain boundaries within their jurisdiction in coordination with the Federal Emergency Management Agency 

and then develop regulations that control the type and 

amount of development within those areas. Federal facilities must further manage their impacts on floodplains 

per the requirements identified in EO 11988, Floodplain 

Management. This executive order requires federal 

agencies to minimize the impact of floods on human 

safety, health and welfare, and restore and preserve the 

natural and beneficial values served by floodplains. 

NREL campuses and facilities do not fall within a 

100-year floodplain. 

Program Management

NREL protects its wetlands and floodplains through 

several means:

■ Periodic vegetation surveys and wetland delineations

■ Mapping of wetland areas potentially affected by 

proposed construction

Worker uses a backpack sprayer to spot-spray noxious weeds at 

NWTC. This method, although labor intensive, targets only the 

appropriate plants and uses only the minimum amount of herbicide. 

Photo by Tom Ryon, NREL 32775

2014 Accomplishments and Highlights 

■ Qualified laboratory staff reviewed wetland 

vegetation (see Appendix A) and wetland 

mapping for both the STM and NWTC 

campuses. 

■ A seasonal pond at the NWTC campus was 

delineated as a wetland. This area captures 

precipitation primarily during the spring 

and summer, allowing a new community of 

wetland plants to emerge.
72 ENVIRONMENTAL PERFORMANCE REPORT 2014

■ Identification of potential impacts

■ Coordination with other jurisdictions on the control of 

floodwaters leaving NREL’s STM and NWTC campuses.

At the STM campus, the U.S. Army Corps of Engineers 

issued a jurisdictional determination stating that all drainages examined are considered upland swales and consequently are currently not regulated. 

Non-jurisdictional functional wetlands are considered 

valuable features, and the laboratory seeks to preserve 

these. Some wetlands have been delineated at the NWTC 

campus. While jurisdiction determinations have not been 

received from the U.S. Army Corps of Engineers, a request 

for a jurisdictional determination or other guidance will 

be submitted if activities that disturb these areas 

are proposed.

2014 Compliance Summary and Activities

■ Program activities were in compliance with regulations.

■ No NREL projects or activities that could impact 

wetlands or floodplains occurred in 2014.

10.5 CULTURAL RESOURCES

Cultural resources are defined as any prehistoric or 

historic district, site, building, structure, or object considered important to a culture, subculture, or community for 

scientific, traditional, religious, or other reasons.

Cultural resources can be divided into three major 

categories:

■ Prehistoric and historic archaeological resources

■ Architectural resources

■ Traditional cultural resources.

Prehistoric and historic archaeological resources are 

locations where human activity measurably altered 

the earth or left deposits of physical remains, such as 

arrowheads, pottery, and tools. Prehistoric resources that 

predate the advent of written records in a region range 

from a scatter composed of a few artifacts to village sites 

and rock art. Historic resources may include campsites, 

roads, fences, trails, dumps, battlegrounds, mines, and a 

variety of other features.

Architectural resources include standing buildings, dams, 

canals, bridges, and other structures of historic or aesthetic significance. Architectural resources generally must be 

more than 50 years old to be considered for protection 

under existing cultural resource laws. However, more 

recent structures, such as Cold War facilities, may warrant 

protection if they manifest the potential to gain significance in the future.

A traditional cultural resource can be defined as a 

property that is eligible for inclusion in the National 

Register of Historic Places because of its association with 

cultural practices or beliefs of a living community that 

are rooted in the community’s history, and its importance 

in maintaining the continuing cultural identity of 

the community. Traditional resources may include 

archaeological resources, buildings, neighborhoods, 

prominent topographic features, habitats, plants, 

animals, and traditional culture.

The STM campus has had a long history as a location with 

a variety of human uses. In 1903, the Colorado National 

Guard established the State Rifle Range at a location 3 

miles (4.8 km) east of Golden, Colorado. The site, designated as “Camp George West” in 1934 in honor of Civil War 

veteran and Golden business man George West, became 

an integral part of Colorado National Guard activities 

throughout the first half of the 1900s. By the 1920s, the 

camp totaled 750 acres (303 hectares) and many buildings 

were added throughout the 1930s and 1940s. 

During World War II, much of Camp George West was 

leased to the federal government for military training 

purposes. From the 1930s to the 1970s, several state 

entities took up residence at Camp George West, including the Colorado State Highway Patrol, the Colorado Law 

Enforcement Training Academy, and the Colorado Correctional Center. In 1981, more than 300 acres (121 hectares) 

were transferred to the federal government for solar 

energy research purposes, which would become NREL’s 

main campus. An additional 25 acres (10.1 hectares) were 

transferred to DOE in 2003. Today, the STM campus totals 

327 acres (132 hectares).

Seasonal wetlands appear annually following spring snow melt 

and rain. These shallow depressions are found on the STM mesa 

top in various locations and are important habitat for insects and 

amphibians, especially Woodhouse’s toad (Bufo woodhousii). 

Photo by Tom Ryon, NREL 33063
ENVIRONMENTAL PERFORMANCE REPORT 2014 73

The NWTC campus was established in the 1970s, so 

all current NWTC structures and buildings have been 

constructed since then. Consequently, none of the current 

structures or buildings have reached the 50-year threshold required for listing consideration by the National 

Register of Historic Places, nor have they been determined 

to be of exceptional importance for earlier consideration.

Requirements

Cultural resources are protected under the National 

Historic Preservation Act of 1966. Federal agencies must 

establish preservation programs commensurate with their 

mission and the effects of their activities on historic properties that provide for the careful consideration of historic 

properties. Significant cultural resources are either eligible 

for, or listed in, the National Register of Historic Places.

Program Management

Cultural resources are protected at NREL in several ways:

■ Integrating cultural resource management into site 

activities and minimizing and/or mitigating impacts to 

historic properties and features.

■ Implementing procedures to manage historic features 

and to protect undiscovered cultural resources 

and artifacts.

■ Periodically conducting surveys to document presence or absence of cultural or historic resources while 

considering project impacts to the human environment. When surveys reveal artifacts, staff works with 

the Colorado Office of Archaeology and Historic 

Preservation to determine if the artifacts are eligible for 

consideration as cultural or historic resources.

■ Requiring construction contractors to provide workers 

with site orientation training that includes guidance 

on what to do in the event they discover any evidence 

of cultural resources during ground-disturbing activities. Workers are to stop all work in the vicinity until a 

qualified archaeologist evaluates the significance of 

the find.

Several formal surveys of historic and cultural resources 

have been performed on the STM campus. As a result, 

three historical sites were recognized as significant 

cultural resources that should be preserved. These 

resources include:

■ An open-air amphitheater

■ A stone bridge spanning a natural drainage channel 

adjacent to the amphitheater

■ A stone and concrete ammunition bunker below the 

amphitheater.

The three structures were constructed in 1930s and 

early 1940s during the Works Progress Administration 

era. Through NREL’s efforts, these structures have been 

added to the National Register, with the amphitheater 

and stone footbridge listed together as a single resource. 

Additionally, a portion of STM campus south of Denver 

West Parkway lies within the 98-acre Camp George West 

Historic District. 

An archeological survey of the NWTC campus was 

conducted in support of the 1996 environmental assessment to supplement previous surveys so no gaps in 

cultural surveys occurred. No significant historical or 

archeological resources were identified.

Aerial photo of Camp George West in the 1930’s. The STM campus 

was a part of the Camp George West parcel at its largest extent of 

about 700 acres. Used with permission from the Denver Public Library

2014 Accomplishments and Highlights 

The State Historic Preservation Office provided 

positive feedback to DOE and NREL for the Camp 

George West informational display that was 

constructed to mitigate impacts of the STM south 

acces road. The State Historic Preservation Officer 

stated, “The quality and content of the interpretative panel is commendable and we hope that this 

feature enhances the visitor experience to the Camp 

George West Historic District.” 
74 ENVIRONMENTAL PERFORMANCE REPORT 2014

2014 Compliance Summary and Activities

■ DOE completed National Historic Preservation Act 

consultations for the completion of the STM Site-Wide 

Environmental Assessment. The primary concern 

involved indirect visual impacts to the amphitheater 

and ammunition bunker from proposed new development near and within the viewshed of these resources. 

The State Historic Preservation Officer and DOE agreed 

that the best approach would conduct future consultations on a project-by-project basis when individual 

components of the proposed action are funded 

or authorized. 

■ DOE submitted the Memorandum of Agreement 

Summary Report, thereby completing DOE and NREL 

responsibilities per the 2011 Memorandum of Agreement for mitigation of impacts to the Camp Goerge 

firing lines from construction of the south access road 

to the STM campus. 

Remnants of a stone bridge located on the STM campus.

Photo by Kurt Schlomberg, NREL 33061
ENVIRONMENTAL PERFORMANCE REPORT 2014 75

In 1999, DOE granted a conservation easement for 177 

acres (72 hectares) of the STM campus to Jefferson 

County. The purpose of the easement is to preserve the 

natural character of the property, including its visual, 

biological, and recreational resources.

The goals of the easement are to:

■ Retain, preserve, and protect the natural, scenic, 

ecological, and historical aspects of the conservation 

easement property

■ Protect the ecosystem and sustainable habitat for 

diverse vegetation and wildlife

■ Ensure the scenic and biological integration with 

adjoining open-space land

■ Prevent further industrial, commercial, or residential 

development of the conservation easement property

■ Preserve the conservation easement property as 

natural open space.

Local policies established by Jefferson County, Golden, 

and Lakewood reflect community sensitivity with respect 

to the visual qualities provided by natural resources 

in the area around the STM campus. Specifically, the 

Jefferson County General Land Use Plan characterizes 

North and South Table Mountain as “unique landscapes,” 

and states that “maintaining landscapes that have a 

unique visual quality” is key to maintaining the quality of 

life in Jefferson County.

Figure 7 illustrates the location of the conservation easement at the STM campus. Vegetation within the easement area includes grasslands interspersed with shrubland communities, primarily in the drainages. Several 

seeps also occur throughout the area.

11 

CONSERVATION EASEMENT 

LANDS

Grasslands in the conservation easement at the STM 

campus. Photo by Kurt Schlomberg, NREL 33062
76 ENVIRONMENTAL PERFORMANCE REPORT 2014

Figure 7. Conservation Easement at the STM Campus.
ENVIRONMENTAL PERFORMANCE REPORT 2014 77

A baseline inventory of the property was prepared in June 

1999 to document the current condition of the easement 

property and to assess the conservation value of the property.4 The baseline inventory includes a description of the 

geographical setting and adjacent property owners, access 

and use of the property by the public, and a description 

of the existing environmental conditions of the property 

(including geology, hydrology, vegetation, wildlife, and 

cultural resources).

Jefferson County Open Space maintains formal trails on 

the conservation easement property. Two trails cross the 

easement, connecting Denver West Parkway (near the 

NREL east campus entrance) to the trails on the mesa top. 

NREL staff and the public use these trails frequently.

2014 Compliance Summary and Activities

■ During 2014, NREL conducted a visual inspection of the 

conservation easement. Potential improvements to the 

management of the easement were noted, including 

addressing social trails, erosion, and weed control.

■ There was no NREL activity on the conservation easement property having the potential to degrade the 

environmental condition of the property.

■ A representative from Jefferson County Open Space 

conducted the annual assessment of the conservation easement. The resulting Conservation Easement 

Monitoring Report highlighted the significant natural 

features of the parcel, including wildlife habitat and 

unique landforms, as well as the passive recreational 

amenities provided by the public trails that cross the 

area. No significant changes to the land use and condition were observed from baseline observations. 

■ Signs were posted along the conservation easement 

boundary to deter unauthorized access to restricted 

DOE property. These signs also serve to protect 

the native grassland ecosystem located within 

the easement.

4 U.S. Department of Energy, Golden Field Office (1999). National Renewable Energy Laboratory (NREL) Site Conservation Easement Baseline Inventory. Golden, Colorado.
78 ENVIRONMENTAL PERFORMANCE REPORT 2014

Detailed Traffic Metrics and Results The STM campus is the destination of hundreds of 

commuter vehicles daily, as well as visitor and delivery 

traffic entering and leaving the site. Traffic management 

for the site is important for minimizing negative impacts 

to traffic flow on Denver West Parkway and in nearby 

neighborhoods and business areas. Reducing traffic also 

reduces noise and light pollution, vehicle emissions, fuel 

use, parking requirements, and road maintenance costs. 

Requirements

In 2008, as part of a National Environmental Policy Act 

assessment for the construction of additional buildings on the STM campus and the moving of additional 

employees to the campus from off-site leased locations, 

12 

TRAFFIC MANAGEMENT

NREL employees opted for bicycles instead of their cars on 

the 2014 Bike-to-Work Day. Photo by Dennis Schroeder, 

NREL 30467

2014 Accomplishments and Highlights

■ NREL’s April 2014 lab-wide commuter survey 

(see Table 8) indicates a positive trend in 

commuting habits with a 16% decrease of 

commuters who drive to work alone and an 

increase in hybrid, electric, and alternative 

fueled vehicles since 2007. Both public transit 

use and telecommuting have increased by 

8% since 2007. The survey, administered 

every three years, provides a snapshot of 

commuter behaviors and guides the development and implementation of NREL’s commuting program and infrastructure to reduce 

greenhouse gas emissions and other environmental impacts from employee commuting.

■ NREL 2014 traffic monitoring indicated 

NREL-generated traffic volumes and inter 

section level of service remained within 

acceptable levels.
ENVIRONMENTAL PERFORMANCE REPORT 2014 79

a traffic Mitigation Action Plan was prepared to ensure 

that traffic impacts would not become significant. This 

plan established periodic monitoring at affected intersections, the development of traffic thresholds, and actions 

to be taken to reduce the traffic volumes. These measures 

have been incorporated in the laboratory’s traffic management program described below.

Periodic traffic monitoring at the STM campus provides 

information regarding total traffic volumes and peakhour vehicle trips. Baseline traffic levels were established 

in 2008 prior to moving increased numbers of staff into 

newly constructed buildings at the STM campus. Since 

2008, traffic has been monitored to measure changes in 

traffic volumes to better inform traffic management.

Intersection traffic analysis, referred to as Level of Service 

analysis, has also periodically been performed to measure 

the impacts of NREL-generated traffic volumes on traffic 

flow at the nearby intersections of Denver West Parkway 

and Denver West Marriott Boulevard, as well as at Quaker 

Street and South Golden Road. The analysis is conducted 

to confirm that traffic flow at the intersections adjacent 

to the STM campus has not degraded to an unacceptable 

level. Level of Service is a measure of traffic flow based 

on the average delay per vehicle trips at an intersection. Typically, a Level of Service of “D” or better indicates 

acceptable conditions at an intersection. From its traffic 

analyses, NREL has developed specific traffic thresholds 

for NREL-generated traffic volumes at the nearby intersections. Monitoring will continue to be conducted on an 

as-needed basis.

Program Management

NREL has implemented an active transportation demandmanagement program to reduce traffic impacts on 

the surrounding community and to reduce petroleum 

fuel use and greenhouse gas emissions by promoting 

alternative modes of transportation. Program activities 

include encouraging and supporting alternative modes of 

commuting, flexible workplace practices, telecommuting, 

teleconferencing, and periodic traffic monitoring. These 

activities are described below. 

Alternative Modes of Commuting

■ EcoPasses provided to employees encourage use of 

the Regional Transportation District (RTD) public transportation system. This includes unlimited RTD regional, 

express, local, light rail, and Call-n-Ride services.

■ Shuttle routes provide connections between NREL 

facilities in Golden and RTD transit stations in Lakewood and Wheat Ridge.

■ Incentive parking is provided for vanpools and 

carpools at the STM campus and at the Denver West 

Office Park.

■ Vanpool incentives are available for participants who 

commute in formal organized vanpools.

■ Bike racks, bike lockers, and bicycle maintenance 

stations are in key locations on the STM campus. Bike 

racks on shuttle vehicles permit staff to take their bikes 

with them when they commute or move between 

buildings.

■ RideShare Connections, an intranet site, allows staff 

to post and search listings for potential carpool and 

vanpool partners within NREL. 

■ Literature kiosks in key building locations provide 

shuttle and RTD schedules, bicycle maps, and telecommuting information.

TABLE 8. NREL LAB-WIDE COMMUTER SURVEY 

RESULTS, 2007–2014

Mode

2007

Survey 

Responses

2011

Survey 

Responses

2014

Survey 

Responses

% Change 

from 2007

Drive Alone 81% 73% 65% -16%

Walk 2% 1% 0% -2%

Bicycle 3% 4% 4% 1%

Carpool 6% 7% 5% -1%

Vanpool 6% 1% 2% 2%

Transit 6% 7% 14% 8%

Motorcycle/

Scooter N/A* 2% 1% -1%

Telework 1% 5% 9% 8%

N/A* Motorcycle/Scooter included in Drive Alone in 2007

Strong winds and blowing snow can wreak havoc on area roads. 

NREL employees utilize alternative modes of commuting to decrease 

single-car ridership through vanpools, RideShare Connections, and 

RTD Ecopasses. Photo by David Parsons, NREL 06915
80 ENVIRONMENTAL PERFORMANCE REPORT 2014

■ Information-sharing events promote safe bicycling, 

rideshare (e.g., carpool and vanpool), and RTD services.

Flexible Workplace Practices

Conferencing by video, telephone, and the internet as 

well as alternating work schedules provide flexibility in 

how people work, saving staff time, energy, and money. 

An alternating work schedule policy allows employees to 

work varying schedules, with management approval, and 

reduces the miles driven by employees to and from 

the laboratory.

Telecommuting

Telecommuting allows staff, with management approval, 

to work from home at least one day per week or occasionally, as needed, reducing the days they commute to the 

lab. Laboratory-wide employee surveys have confirmed 

that adoption of this program has been very strong.

Teleconferencing

The laboratory promotes and encourages the use of 

teleconferencing and videoconferencing for meetings 

to decrease local vehicle trips and air travel.

2014 Compliance Summary and Activities

■ Active transportation demand management 

activities were continued in 2014.

■ In 2014, the average afternoon (4:30 p.m. to 5:30 

p.m.) peak-hour traffic volume measured at the intersection of Denver West Parkway and Denver West 

Marriott Boulevard was 342 vehicle trips per hour. 

This traffic volume remained below the threshold to 

ensure a Level of Service “D” or better (equivalent to 

522 vehicle trips per hour) entering or leaving the 

site during the afternoon rush hour. 

Detailed Traffic Metrics and Results

Previously conducted traffic studies indicated that the 

greatest impact to traffic in the local area from NREL STM 

activities occurs between 4:30 p.m. and 5:30 p.m. This 

hour has been designated the PM peak hour. 

PM peak-hour video traffic surveillance was conducted 

in 2014 over three, 3-week periods during May, August, 

and December at the STM east entrance (intersection of 

Denver West Parkway and Denver West Marriott Boulevard), west entrance (intersection of Quaker Street and 

South Golden Road), and the south entrance (at South 

Golden Road and Research Road). Table 9 shows the traffic 

count results at these three locations.

Traffic counts were evaluated at the east and west 

entrances. At the east entrance, traffic counts were 

compared against the threshold, which identifies the 

acceptable number of vehicle trips NREL can contribute 

to the intersection of Denver West Parkway and Denver 

West Marriott Boulevard without causing significant 

degradation to flow. The applicable traffic volume threshold identified at this location is 522 vehicle trips in the 

PM peak hour (from 4:30 p.m. to 5:30 p.m.). In 2014, the 

PM-peak-hour traffic volume averaged 342 vehicle trips, 

thus remaining below the NREL-established threshold. 

At the west entrance, NREL has identified a traffic threshold of 36 vehicle trips in the PM peak hour. In 2014, the 

PM-peak-hour traffic volume average remained below the 

threshold at 14 vehicle trips.

As the south entrance was not constructed at the time of 

the original traffic analysis, 2014 traffic count data cannot 

be compared to a vehicle trip number threshold.

TABLE 9. 2014 TRAFFIC COUNTS AND COMPARISON 

WITH THRESHOLD VALUES

Gate 

(Affected 

Intersection)

PM Peak-Hour Vehicles 

 (in- and out-bound)

May14Aug14Dec14 Average Threshold

East Entrance (Denver 

West Parkway/Denver 

West Marriott Blvd.)

349 319 358 342 522

West Entrance 

(Quaker St./South 

Golden Road)

17 14 10 14 36

South Entrance 

(South Golden Road/

Research Rd.)

205 178 169 184 N/A

A flex fuel E-85 shuttle used on NREL’s STM campus allows staff to 

take their bikes with them when they commute or move between 

buildings. Photo by Dennis Schroeder, NREL 32218
ENVIRONMENTAL PERFORMANCE REPORT 2014 81

APPENDIX A:

PLANT COMMUNITIES AT 

THE STM AND THE NWTC

Vegetation surveys are periodically completed for the 

STM and NWTC campuses, with the most recent survey 

occurring in 2011. Plant communities and species were 

identified for each campus at that time, and changes 

from similar surveys completed in 2000 are noted below.

STM Plant Communities

The majority of vegetation at the STM campus belongs 

to the grassland community type. Within that association, there are two distinct community types: short 

grassland on the mesa top and mixed grassland located 

on the slopes and toe area. Other mapped vegetation 

communities at the STM campus include ravine shrubland, tall shrubland, short shrubland, and wetlands. The 

plant communities are described below and mapped as 

illustrated in Figure 8.

Short Grassland

Short grassland is found on the flat top of the mesa. The 

dominant grass species are blue grama (Chondrosum 

gracile), a native prairie species, and cheatgrass (Anisantha tectorum), a noxious weed. Populations of diffuse 

knapweed (Acosta diffusa) and Dalmatian toadflax (Linaria genistifolia subsp. dalmatica) are scattered throughout the whole community. These two noxious weeds 

comprise approximately 1% of the short grassland.

Alyssum (Alyssum parviflorum), an introduced species, is 

the dominant forb. Several species of prickly pear cactus 

(Opuntia fragilis, O. macrorhiza, O. phaeacantha, and O. 

polyacantha) occur throughout the short grassland on 

the mesa top, as well as hen-and-chicks (Echinocereus 

viridiflorus) and pincushion cacti (Coryphantha missouriensis and C. vivipara var. vivpara). Well-draining hillocks 

often support thick stands of needle-and-thread grass 

(Hesperostipa comata) and yucca (Yucca glauca). Some 

short shrubs such as rubber rabbitbrush (Chrysothamnus 

nauseosus subsp.), chokecherry (Padus virginiana), and 
82 ENVIRONMENTAL PERFORMANCE REPORT 2014

Figure 8. STM land cover types surveyed in 2011. Note: map was updated in 2012 to reflect campus building changes.
ENVIRONMENTAL PERFORMANCE REPORT 2014 83

skunkbrush (Rhus aromatica subsp. trilobata) occur infrequently in the short grassland area and concentrate along 

the rimrock areas. Several large hackberry trees (Celtis 

reticulata) are clustered at the very edge of the mesa top.

Historically, this short grassland was probably dominated 

by blue grama grass and other short-grass species such 

as buffalo grass (Buchloë dactyloides), intermixed with the 

other species associations described above. However, the 

entire mesa-top area has become dominated by cheatgrass, an aggressive noxious weed. This weed is changing 

the appearance and general species composition of the 

area by apparently out-competing native plants.

Mixed Grassland

The mesa slopes and toe areas on the STM campus also 

support blue grama and cheatgrass, but are dominated by 

a mixed-grass species association of needle-and-thread 

grass and western wheatgrass (Pascopyrum smithii), with 

smaller amounts of big bluestem (Andropogon gerardii), 

sideoats grama (Bouteloua curtipendula), three-awn (Aristida purpurea), and green needlegrass (Nassella viridula). 

As in the short grassland areas, a large number of forbs 

also occur in the mixed grasslands.

A few patches of anomalous vegetation occur within the 

mixed grasslands where subsurface water appears to be 

close to the surface. These areas support wide swaths of 

mat muhly (Muhlenbergia richardsonis). One is located on 

a southern-facing slope, near the eastern property boundary. The other is located on a southwestern-facing slope 

of the ravine north of the NREL Education Center, formerly 

known as the Visitors Center. This area is notable for a 

large population of poison ivy (Toxicodendron rydbergii), 

which grows in thickets of tall (one meter and larger) 

plants that have a woody, shrub-like growth form. A small 

number of plains cottonwood (Populus deltoides) saplings, 

skunkbrush, chokecherry, and snowberry occurs in this 

patch as well.

The mixed-grass areas grade into both the upland and 

ravine shrublands and contribute the majority of the 

understory in these areas. Some mixed-grass areas also 

blend into disturbed areas, where reclamation species 

such as crested wheatgrass (Agropyron cristatum) and 

smooth brome have been planted and have subsequently 

spread into the mixed-grass community.

Upland Shrublands

Shrubland habitat occurs along the upper sides of ravines 

and on the steeper mesa slopes, becoming more prominent as elevation increases up to the top of the mesa. The 

upland shrubland habitat, which excludes the shrublands 

in the ravine bottoms, comprises tall shrubland and short 

shrubland communities very similar in overall composition but distinguished by the dominant species.

Tall Shrubland

The tall shrubland areas are defined by stands of mountain mahogany (Cercocarpus montanus) that occur along 

the rim of the mesa, usually where volcanic cap rock is 

exposed, and on the upper mesa slopes below rimrock 

areas. The understory is notably sparse throughout this 

community, with a large amount of bare soil. Cheatgrass 

is the most common herbaceous species in these areas, 

intermixed with needle-and-thread grass, yucca, and 

many cacti.

Short Shrubland

The short shrublands occur on elevated flat areas amidst 

the surrounding grasslands, some of which appear to 

have experienced surficial disturbance in the past. These 

areas are distinctive because of the dominance of rubber 

rabbitbrush. The other common location for short shrublands is on the outer slopes of the ravines. Skunkbrush 

defines these and other short shrublands along the 

upper portions of the steepest slopes of the mesa. These 

communities usually grade into the ravine shrublands 

along the drainage bottoms and the tall shrublands near 

the top of the mesa slopes. The short shrubland community also has a sparse understory of the same grasses and 

forbs as the tall-shrub community.

Ravine Shrublands

Ravine shrublands are limited to the lower sides and 

bottoms of the drainages that cut down through the 

mesa slopes. These communities support a variety of 

shrubs such as skunkbrush, chokecherry, and wild plum 

(Prunus americana), often growing in dense, impassible 

thickets. A few plains cottonwoods and peachleaf willow 

(Salix amygdaloides) trees occur at the top of the ravine 

channels and in other portions of the channel where the 

subsurface water table appears to be relatively high. A 

diverse herbaceous component is found in these drainages. In one instance near the southeast campus boundary, a ravine shrubland grades into an ephemeral drainage 

at the toe of the mesa. This drainage is vegetated with 

grassland species and conducts only occasional surface 

water runoff.

Wetlands

Five very small communities on the STM campus were 

found to support wetland vegetation. These communities were not examined for the soils and hydrology that 

would classify them as functioning wetlands; rather, they 
84 ENVIRONMENTAL PERFORMANCE REPORT 2014

are noted only for their dominance of wetland vegetation. 

These are limited to very small areas (less than half an acre 

in total). One is in a shallow swale at the mouth of the 

ravine at the southwestern corner of the campus boundary where surface water and/or subsurface drainage have 

created a pocket of saturated soil. Species here include 

sedges (Carex spp.), rushes (Juncus spp.), bulrush (Schoenoplectus spp.), and peachleaf willow. The second wetland 

could have formed as a result of past construction activities. This linear depression supports wetland vegetation 

along the central portion of the western campus boundary, northeast of the photovoltaic array. Perhaps situated 

where equipment was once staged, this area appears 

to hold seasonal water for enough consecutive growing 

seasons to support some wetland vegetation including 

Arctic rush (Juncus arcticus), American speedwell (Veronica 

americana), and broadleaf cattail (Typha latifolia).

The wetland at the mouth of the ravine may no longer 

experience the hydrology that originally allowed these 

plants to establish there. In 2002, this plant community 

supported populations of cattails that were not observed 

in the 2011 survey.

Three small seeps are located on the hill slope between 

the Education Center and the public trail on the far eastern boundary of the campus. These seeps are dominated 

with sedges, rushes, and Canada thistle (Cirsium arvensis).

A seventh wetland community that was observed by Plantae5

 no longer appears to support wetland vegetation. In 

2002, cattail species near an old stock tank in the easternmost drainage appeared to have been supported by a 

pipe coming out of the hillside. Although the stock tank 

was observed in the 2011 survey, it appears the cattails 

have not persisted in the intervening years.

Disturbed/Reclaimed

This habitat type comprises all of the areas at the campus 

that have experienced surface disturbance to vegetation 

caused by human activities. These mostly occur on the 

perimeter of the buildings, roads, parking lots, and soil 

dumping areas. Most of these areas appear to have been 

re-vegetated and support a combination of native grassland plants, planted ornamental re-vegetation species, 

and native and introduced weeds.

NWTC Plant Communities

The majority of the vegetation at the NWTC campus 

belongs to the mixed-grass prairie association of the 

grassland formation. Mixed-grass prairie is defined by the 

presence of grass species typical of the tallgrass or true 

prairie such as big bluestem (Andropogon gerardii), little 

bluestem (Schizachyrium scoparium), and prairie dropseed (Sporobolus heterolepis), with species more typical of 

the short-grass prairie such as blue grama (Chondrosum 

gracile) and buffalograss (Buchlöe dactyloides). Intermediate grasses (mid-grasses) such as the needle grasses 

(Hesperostipa and Nassella spp.), wheat grasses (Pascopyron, Agropyron, Elytrigia, Elymus, and Thinopyrum spp.), and 

blue grasses (Poa spp.) are also important constituents of 

mixed-grass prairie. 

The grasslands at the NWTC fall into the xeric mixedgrassland community type identified and classified 

primarily on available soils and soil moisture, reflected in 

xeric mixed-grassland plant species assemblages.

A number of changes in vegetation patterns noted since 

the NWTC campus was previously mapped (Plantae 

20006) is discussed below by specific plant community.

The plant communities are described below and mapped 

as illustrated in Figure 9.

Xeric Mixed Grassland 

Xeric mixed grassland is by far the largest and most widespread community type at the NWTC site. These areas do 

not have access to regular soil moisture (xeric conditions) 

and are dominated by typical short- and mixed-grass prairie species. This plant community includes a large variety 

of native grass species as well as a diverse forb component, typical of mixed grasslands. Dominant species noted 

include big bluestem, little bluestem, prairie dropseed, 

blue grama, and buffalo grass. Intermediate grasses (midgrasses) such as the needle grasses, wheat grasses, and 

blue grasses are also important constituents of mixedgrass prairie. Species flowering in late spring include little 

bluestem, cheatgrass, sand lily (Leucocrinum montanum), 

wild iris (Iris missouriensis), Lambert locoweed (Oxytropis 

lambertii), mouse-ear (Cerastium strictum), western wallflower (Erysimum capitatum), and prairie golden pea

(Thermopsis rhombifolia). 

Wet Meadow

Three locations support wet meadows7 at the NWTC. 

One is south of the SunEdison solar array, the second is at 

the upper end of the Rock Creek tributary along Row 4, 

and the third is adjacent to the Building 251 east parking 

lot. A wet meadow is a type of grassland that transitions 

between mesic and hydric conditions (i.e., an transition 

area between upland grasslands and wetlands). These 

5, 6 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, Colorado.

7 In the 2000 and 2011 surveys, wet meadows were identified as mesic mixed grassland. These areas were reclassified in 2012 as wet meadows due to an 

apparent change in vegetation and hydric conditions.
ENVIRONMENTAL PERFORMANCE REPORT 2014 85

Figure 9. NWTC land cover types surveyed in 2012.
86 ENVIRONMENTAL PERFORMANCE REPORT 2014

areas support Arctic rush, Canada bluegrass (Poa compressa), redtop bentgrass (Agrostis stolonifera), Canada thistle, 

western wheatgrass, common three-square (Schoenoplectus pungens), showy milkweed (Asclepias speciosa), and 

wild iris (Iris missouriensis). 

Ponderosa Pine Woodland

One woodland habitat, defined by a single community of 

the ponderosa pine (Pinus ponderosa) woodland, occurs 

in the northwestern corner of the campus along a granite 

outcrop. This small area supports a very diverse native 

plant community including common grassland and 

foothills species, as well as a number of introduced and 

noxious weeds. Dominant species include ponderosa pine 

(Pinus ponderosa), smooth bromegrass, crested wheatgrass, and green needlegrass (Nassella viridula). Species 

flowering in late spring include sand lily, western snowberry (Symphoricarpus occidentalis), groundsel (Senecio sp.), 

and wax current (Ribes cereum).

Upland Shrubland

A small upland shrub community is located to the southeast of the ponderosa pine woodland, where the same 

ridge arises to a lesser degree from the surrounding grassland community. This rocky ridge supports shrub species 

interspersed with grasses and forbs representative of the 

surrounding grasslands. Dominant species noted include 

western snowberry, Canada wild rye (Elymus canadensis), 

Canada bluegrass, Kentucky bluegrass (Poa pratense), and 

little bluestem. Species flowering in late spring include 

prairie golden pea.

An isolated group of hawthorn (Crataegus erthyropoda) 

shrubs occurs along the western campus boundary, within 

the NWTC campus boundary. These trees are at the top 

of the slope and occur directly east of an active area of 

construction disturbance, which is outside the NWTC 

campus boundary.

Palustrine Emergent Wetland

Two wetlands on the campus fall into the palustrine 

emergent category. The first is a linear depression on the 

southern side of the south road. This area appears to have 

developed as the result of soil excavation intercepting 

sufficient surface water runoff from the adjacent road to 

support sedge species (Carex spp.). A second wetland is 

located on the southern boundary in an area previously 

disturbed from the neighboring industrial activities. This 

wetland comprises a center of cattails (Typha angustifolia) 

surrounded by a stand of coyote willow (Salix exigua).

Two palustrine emergent wetlands were mapped in the 

mesic mixed grassland in the 2000 growing season. These 

areas appear to have dried considerably in the intervening 10 years. The small wetland pockets of cattails (Typha 

spp.) that occurred in the southern portions of this area are 

no longer present, apparently replaced by large stands of 

Canada thistle. Dead remnants of Baltic rush (Juncus 

balticus) can be found in the area litter (prior years’ 

herbaceous vegetation). The dominant species noted 

was smooth bromegrass.

Headwater Wetland

Areas of headwater wetland occur along the two ephemeral drainages on the NWTC campus. Both drainages 

occur in the northeastern portion of the campus, one 

flowing east and one flowing north. Both show evidence 

of intermittent surface flow. The northern-most drainage 

is a tributary of Coal Creek, and the second drainage is a 

tributary of Rock Creek.

Surface flow in the drainage to the northeast appears to 

be augmented by outflow from the groundwater seep 

wetland on the western bank. The second and larger 

drainage conducts surface flows through the center of the 

campus off to the eastern fence line. The upper reaches of 

this drainage are a shallow grassland swale. This channel 

deepens as it flows east across the campus. At its eastern 

reaches, this drainage clearly intercepts subsurface water, 

although not in sufficient quantities to produce consistent 

surface flow. At the point where this drainage leaves the 

NWTC campus, there is a human-constructed rock wall. 

Dominant species noted include Canada thistle, Baltic 

rush, curly dock (Rumex crispus), common evening primrose (Oenothera villosa), smooth bromegrass, and western 

wheatgrass (Pascopyrum smithii).

Groundwater Seep Wetland

Two areas of groundwater seep wetland are located on the 

NWTC campus. The first occurs west of the ponderosa pine 

woodland, in the northwestern portion of the campus 

along the northern fence line. This area now includes more 

upland species than noted in 2000.

The second occurs over a very small area on the banks 

of the northern drainage. This community is a clearly 

demarcated area of primarily wetland plants amidst the 

surrounding grassland. Fifty plant species were identified 

in this community in 2000, many of which also occur in the 

headwater wetland to the south. Dominant species noted 

include sedges (Carex sp.) and rushes (Juncus sp.). Common 

teasel (Dipsacus fullonum) has invaded the northern drainage area. Species flowering in late spring include common 

teasel, showy milkweed (Asclepias speciosa), wild iris, fieldmint (Mentha arvensis), and Canada thistle.
ENVIRONMENTAL PERFORMANCE REPORT 2014 87

Seasonal Pond 

A seasonal pond and pond margin occur at the 

northwestern corner of the campus, west of the southern 

terminus of the ponderosa pine woodland. This area 

appears to depend on an elevated spring and early 

summer water table for the hydric soil moisture conditions 

that support this community. Observers have noted that 

the pond depression often contains standing water in 

the spring and early summer in some years.8 However, no 

standing water was observed in this area during the most 

recent survey. These drier soil conditions are reflected in a 

shift of dominant plant species in this community between 

the 2000 and 2011 surveys. Dominant species noted 

include curly dock, Canada bluegrass, smooth bromegrass, 

and Canada thistle.

Disturbed 

These plant associations reflect surface disturbance due to 

human activities on the site. These areas include roadsides, 

pad sites, parking lot perimeters, construction sites, and 

storage areas. Some of these areas have been revegetated 

and now include a combination of species from surrounding natural plant communities, reclamation species, and 

adventive (non-native) or ruderal (native or adventive, 

disturbance colonizer) species. Dominant species noted 

include smooth bromegrass and cheatgrass.

Ornamental Trees/Shrubs 

Disturbed areas around buildings have been planted with 

a combination of native and ornamental trees and shrubs. 

The trees include multiple species of junipers (Sabina 

spp.) and pines (Pinus spp.) interspersed with ornamental 

deciduous trees. Shrubs in these areas are mainly 

chokecherry (Padus virginiana) and rose (Rosa spp.) bushes.

8 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center, Boulder, Colorado.
88 ENVIRONMENTAL PERFORMANCE REPORT 2014

APPENDIX B:

WILDLIFE SPECIES OBSERVED 

AT THE STM AND THE NWTC

The following are lists of common and scientific names of 

wildlife species observed at the STM and NWTC campuses. 

The species for the NWTC were identified during surveys 

completed in 2011. The species listed for STM were 

observed by staff and/or observed in surveys completed in 

1987, 2005, and 2011.

TABLE 10. WILDLIFE SPECIES AT THE STM*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

BIRDS

American crow Corvus brachyrhynchos X X

American goldfinch Carduelis tristis X

American kestrel Falco sparverius X X X

American pipit Anthus rubescens X

American redstart Setophaga ruticilla X

American robin Turdus migratorius X X X

American tree sparrow Spizella arborea X X

American white pelican Pelecanus erythrorhynchos X

Bald eagle** Haleatus leucocephalus

Barn swallow Hirundo rustica X

Black-billed magpie Pica hudsonia X X X

Black-capped chickadee Poecile atricapilla X

Black-crowned night heron Nycticorax nycticorax X

Black-headed grosbeak Pheucticus melanocephalus X

Blue-gray gnatcatcher Polioptila caerulea X

Blue jay Cyanocitta cristata X X

Brewer’s blackbird Euphagus cyanocephalus X X

Brewer’s sparrow Spizella breweri X

Broad-tailed hummingbird Selasphorus platycercus X

Broad-winged hawk Buteo platypterus X

Brown-headed cowbird Molothrus ater X X X

Bullock's oriole Icterus bullockii X X

Bushtit Psaltriparus minimus X

California gull Larus californicus X

Canada goose Branta canadensis X X

Cedar waxwing Bombycilla cedrorum X

Cassin’s kingbird Tyrannus vociferans X

Chestnut-collared longspur Calcarius ornatus X

Chipping sparrow Spizella passerina X

Cliff swallow Petrochelidon pyrrhonota X
ENVIRONMENTAL PERFORMANCE REPORT 2014 89

Table 10 continued on page 90

TABLE 10. WILDLIFE SPECIES AT THE STM*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

BIRDS

Common grackle Quiscalus quiscula X

Common nighthawk Chordeiles minor X X X

Common raven Corvus corax X X

Common snipe Gallinago delicata X

Cooper's hawk Accipiter cooperii X X

Dark-eyed junco Junco hyemalis X X

Double-crested cormorant Phalacrocorax auritus X

Eastern kingbird Tyrannus tyrannus X

Eurasian collared dove** Streptopelia decaocto

European starling Sturnus vulgaris X X X

Golden eagle Aquila chrysaetos X

Grasshopper sparrow Ammodramus savannarum X

Great blue heron Ardea herodias X X

Green-tailed towhee Pipilo chlorurus X

Hepatic tanager Piranga flava X

Hermit thrush Catharus guttatus X

Horned lark Eremophila alpestris X X

House finch Carpodacus mexicanus X X

House sparrow Passer domesticus X X

House wren Troglodytes aedon X

Killdeer Charadrius vociferous X X X

Lark bunting Calamospiza melanocorys X X

Lark sparrow Chondestes grammacus X

Lazuli bunting Passerina amoena X

Lesser goldfinch Carduelis psaltria X

Loggerhead shrike Lanius ludovicianus X

MacGillivray's warbler Oporornis tolmiei X

Mallard Anas platyrhynchos X

Mountain bluebird Sialia currucoides X X

Mountain chickadee Poecile gambeli X

Mourning dove Zenaida macroura X X

Northern flicker Colaptes auratus X X

Northern goshawk Accipiter gentilis X

Northern harrier Circus cyaneus X

Osprey Pandion haliaetus X

Peregrine falcon Falco peregrinus X

Pine siskin Carduelis pinus X

Prairie falcon Falco mexicanus X

Red-breasted nuthatch Sitta canadensis X

Red-tailed hawk Buteo jamaicensis X X

Red-winged blackbird Agelaius phoeniceus X

Rock dove Columba livia X

Rock wren Salpinctes obsoletus X

Ruby-crowned kinglet Regulus calendula X

Sage thrasher Oreoscoptes montanus X

Say's phoebe Sayornis saya X
90 ENVIRONMENTAL PERFORMANCE REPORT 2014

*No terrestrial arthropod genera of specific concern were detected during surveys in 2010.

**Species observed at a time other than in a survey.

TABLE 10. WILDLIFE SPECIES AT THE STM*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

BIRDS

Sharp-shinned hawk Accipiter striatus X

Spotted towhee Pipilo maculates X

Swainson's hawk Buteo swainsoni X

Tree swallow Tachycineta bicolor X X

Turkey vulture Cathartes aura X

Vesper sparrow Pooecetes gramineus X

Virginia’s warbler Oreothlypis virginiae X 

Violet-green swallow Tachycineta thalassina X

Western kingbird Tyrannus verticalis X X

Western meadowlark Sturnella neglecta X X

Western scrub-jay Aphelocoma californica X

White-crowned sparrow Zonotrichia leucophrys X

White-faced ibis Plegadis chihi X

White-throated swift Aeronautes saxatalis X

Yellow-breasted chat Icteria virens X

Yellow-rumped warbler Dendroica coronata X

MAMMALS 

Black-tailed jackrabbit Lepus californicus X X

Bushy-tailed woodrat Neotoma cinerea X

Coyote Canis latrans X X X

Deer mouse Peromyscus maniculatus X X

Elk** Cervus canadensis

Fox squirrel Sciurus niger X

Long-tailed weasel Mustela frenata X 

Mexican woodrat Neotoma mexicana X X

Mountain cottontail Sylvilagus nuttalli X X X

Mule deer Odocoileus hemionus X X X

Prairie vole Microtus ochrogaster X X

Raccoon Procyon lotor X X X

Red fox Vulpes vulpes X X

Striped skunk Mephitis X

Western harvest mouse Reithrodontomys megalotis X X X

Western spotted skunk Spilogale gracilis X

White-tailed jackrabbit Lepus townsendii X

Yellow-bellied marmot Marmota flaviventris X

REPTILES AND AMPHIBIANS

Bull snake Pituophis catenifer X X

Plains garter snake Thamnophis radix X X

Prairie lizard Sceloporus undulatus X

Racer Coluber constrictor X

Six-lined racerunner Cnemidophorus sexlineatus X

Tiger salamander Ambystoma tigrinum X X

Western rattlesnake Crotalus viridus X X X

Woodhouse’s toad Bufo woodhousii X
ENVIRONMENTAL PERFORMANCE REPORT 2014 91

Table 11 continued on page 92

TABLE 11. WILDLIFE SPECIES AT THE NWTC*

SPECIES COMMON NAME SCIENTIFIC NAME 1996 Survey 2003 Survey 2011 Survey

BIRDS

American crow Corvus brachyrhynchos X

American goldfinch Spinus tristis X X

American kestrel Falco sparverius X X X

American pipit Anthus rubescens X

American robin Turdus migratorius X X

American tree sparrow Spizella arborea X

Bald eagle Haliaeetus leucocephalus X

Barn swallow Hirundo rustica X X

Black-billed magpie Pica hudsonia X X

Black-capped chickadee Poecile atricapillus X X

Blue-gray gnatcatcher Polioptila caerulea X

Blue jay Cyanocitta cristata X

Brewer's blackbird Euphagus cyanocephalus X X

Brewer's sparrow Spizella breweri X

Broad-tailed hummingbird Selasphorus platycercus X X

Broad-winged hawk Buteo platypterus X

Brown-headed cowbird Molothrus ater X X

Bullock's oriole Icterus bullockii X

Canada goose Branta canadensis X

Cedar waxwing Bombycilla cedrorum X

Chipping sparrow Spizella passerina X X

Cliff swallow Petrochelidon pyrrhonota X

Common grackle Quiscalus quiscula X X

Common nighthawk Chordeiles minor X

Common raven Corvus corax X X

Common snipe Gallinago delicata X

Cooper’s hawk Accipiter cooperii X

Dark-eyed junco Junco hyemalis X

Double-crested cormorant Phalacrocorax auritus X

Downy woodpecker Picoides pubescens X

Eurasian collared-dove Streptopelia decaocto X

European starling Sturnus vulgaris X X

Ferruginous hawk Buteo regalis X X

Franklin's gull Larus pipixcan X

Golden eagle Aquila chrysaetos X X X

Grasshopper sparrow Ammodramus savannarum X X

Gray catbird Dumetella carolinensis X

Great blue heron Ardea herodias X X

Great horned owl Bubo virginianus X

Green-tailed towhee Pipilo chlorurus X

Hairy woodpecker Picoides villosus X

Horned lark Eremophila alpestris X X

House finch Carpodacus mexicanus X X

Killdeer Charadrius vociferus X
92 ENVIRONMENTAL PERFORMANCE REPORT 2014

TABLE 11. WILDLIFE SPECIES AT THE NWTC*

SPECIES COMMON NAME SCIENTIFIC NAME 1996 Survey 2003 Survey 2011 Survey

BIRDS

Lark bunting Calamospiza melanocorys X

Lark sparrow Chondestes grammacus X

Loggerhead shrike Lanius ludovicianus X

Long-billed curlew Numenius americanus X

Mallard Anas platyrhynchos X X

Merlin Falco columbarius X

Mountain bluebird Sialia currucoides X X

Mountain chickadee Poecile gambeli X

Mourning dove Zenaida macroura X X

Northern flicker Colaptes auratus X X

Northern goshawk Accipiter gentilis X

Northern harrier Circus cyaneus X X X

Osprey Pandion haliaetus X

Peregrine falcon Falco peregrinus X X

Prairie falcon Falco mexicanus X X

Red-headed woodpecker Melanerpes erythrocephalus X

Red-tailed hawk Buteo jamaicensis X X X

Red-winged blackbird Agelaius phoeniceus X X

Rough-legged hawk Buteo lagopus X X X

Ruby-crowned kinglet Regulus calendula X

Sandhill crane Grus canadensis X

Savannah sparrow Passerculus sandwichensis X

Say's phoebe Sayornis saya X X

Sharp-shinned hawk Accipiter striatus X

Song sparrow Melospiza melodia X

Spotted towhee Pipilo maculatus X

Swainson's hawk Buteo swainsoni X X

Tree swallow Tachycineta bicolor X

Turkey vulture Cathartes aura X X X

Vesper sparrow Pooecetes gramineus X X

Western kingbird Tyrannus verticalis X X

Western meadowlark Sturnella neglecta X X

Wilson’s warbler Wilsonia pusilla X

Yellow-rumped warbler Dendroica coronata X
ENVIRONMENTAL PERFORMANCE REPORT 2014 93

TABLE 11. WILDLIFE SPECIES AT THE NWTC*

SPECIES COMMON NAME SCIENTIFIC NAME 1996 Survey 2003 Survey 2011 Survey

MAMMALS

Big brown bat Eptesicus fuscus X

Black-tailed prairie dog** Cynomys ludovicianus

Bobcat** Felis rufus

Coyote Canis latrans X

Deer mouse Peromyscus maniculatus X

Desert cottontail Sylvilagus audubonii X

Eastern red bat Lasiurus borealis X

Elk Cervus canadensis X

Fringed myotis Myotis thysanodes X

Hoary bat Lasiurus cinereus X

Masked shrew Sorex cinereus X

Meadow vole Microtus pennsylvanicus X

Mexican woodrat Neotoma mexicana X

Mule deer Odocoileus hemionus X

Myotis bats Myotis sp. X

Prairie vole Microtus ochrogaster X

Silver-haired bat Lasionycteris noctivagans X

Thirteen-lined ground squirrel Spermophilus tridecemlineatus X

Western harvest mouse Reithrodontomys megalotis X

REPTILES AND AMPHIBIANS

Boreal chorus frog Pseudacris maculata X

Bull snake Pituophis catenifer X

Woodhouse’s toad Bufo woodhousii X

TERRESTRIAL ARTHROPODS

Aphrodite fritillary Speyeria aphrodite X

Cabbage white Pieris rapae X

Checkered white Pontia protodice X

Common wood nymph Cercyonis pegala X

Dainty sulphur Nathalis iole X

Gray hairstreak Strymon melinus X

Orange sulphur Colias eurytheme X

Western white Pontia occidentalis X

*The 1996 study addressed only raptors. Mammals, reptiles, amphibians, or terrestrial arthropods were not the subject of a survey at the 

NWTC until the 2011 baseline survey.

**Species observed at a time other than in a survey.
94 ENVIRONMENTAL PERFORMANCE REPORT 2014

TABLE 12. NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2014

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

AST for petroleum 

storage

STM ESIF AST Registration DOPS 19275-1 Completed

AST for petroleum 

storage

STM PDU AST Registration DOPS 2873-2 Completed

AST for petroleum 

storage

STM RSF2 AST Registration DOPS 19211-1 Completed

AST for petroleum 

storage

STM SERF AST Registration DOPS 2873-1 Completed

AST for petroleum 

storage

E85 AST Registration DOPS 2873-4 Completed

AST for petroleum 

storage

SolarTAC AST Registration DOPS 19325-1 Completed

Air Laboratory-wide servicing of CFC-containing 

equipment Notification APCD 647 Active

Air STM SERF, 2 CFC-containing stationary sources Registration APCD 647 Active

Air STM FTLB waste gas combustor Permit APCD 99JE0400 Active

Air STM RFHP wood waste boiler Permit APCD 07JE0277 Active

Air STM fugitive dust from construction activities Permit APCD 08JE0889L Active

Air STM RSF 1 diesel-fired standby electrical 

generator

Permit APCD 10JE1400 Active

Air STM RSF 2 diesel-fired standby electrical 

generator

Permit APCD 11JE1303 Active

Air STM FTLB diesel-fired standby electrical generator Permit APCD 10JE1630 Active

Air NWTC Site 4.0 diesel-fired standby electrical 

generator

Permit APCD 10JE1712 Active

Air STM parking garage diesel-fired standby electrical 

generator

Permit APCD 11JE1997 Active

Air STM ESIF diesel-fired standby electrical generator Permit APCD 11JE3542 Active

Air STM ESIF research electrical generator #3 Permit APCD 13JE2829 Active

Air STM IBRF scrubber and baghouse Permit APCD 11JE1798 Active

Air STM ESIF research electrical generator #1 APEN APCD 12JE1734 XP Active

APPENDIX C:

ENVIRONMENTAL PERMITS, 

REGISTRATIONS, AND 

NOTIFICATIONS APPLICABLE 

TO NREL DURING 2014
ENVIRONMENTAL PERFORMANCE REPORT 2014 95

TABLE 12. NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2014

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

Air STM ESIF research electrical generator #2 APEN APCD 12JE1735 XP Active

Air STM IBRF standby electrical generator APEN APCD 13JE2276 XP Active

Air NWTC STL standby electrical generator APEN APCD 13JE2271 XP Active

Air NWTC Building 251 standby electrical generator APEN APCD 13JE2272 XP Active

Alcohol STM IBRF alcohol fuel production Permit TTB AFP-CO-00255 Active

Alcohol STM tax-free alcohol use Permit TTB TF-CO-0331 Active

Drinking water 

system NWTC drinking water system ID number Registration WQCD CO0230860 In Effect; Does Not Expire

Earth disturbance STM stormwater detention basin grading permit Permit Jefferson 

County 10-126950GP Terminated

Earth disturbance STM parking lot grading permit Permit Jefferson 

County 10-127351GP Terminated

Groundwater well STM groundwater monitoring well MW-1 Permit DWR 37229 Active

Groundwater well STM groundwater monitoring well MW-2 Permit DWR 37228 Active

Groundwater well STM groundwater monitoring well MW-3 Permit DWR 37231 Active

Groundwater well STM groundwater monitoring well MW-4 Permit DWR 37230 Active

Groundwater well STM groundwater monitoring well MW-5 Permit DWR 37233 Active

Hazardous materials STM WHF hazardous material storage and 

use permit Permit WMFR 4976 Active

Hazardous materials STM SERF hazardous material storage and 

use permit Permit WMFR 4982 Active

Hazardous materials STM S&TF hazardous material storage and use permit Permit WMFR 4979 Active

Hazardous materials STM FTLB hazardous material storage and 

use permit Permit WMFR 4977 Active

Hazardous materials STM IBRF hazardous material storage and 

use permit Permit WMFR 4978 Active

Hazardous materials STM Shipping and Receiving hazardous material 

storage and use permit Permit WMFR 4980 Active

Hazardous materials DWOP building 16 hazardous material storage and 

use permit Permit WMFR 4981 Active

Hazardous materials ReFUEL hazardous material storage and use permit Permit Denver Fire 

Department 32178 Active

Hazardous waste DWOP RCRA hazardous waste generator status 

EPA ID Notification HMWMD CO4890000017 Completed

Hazardous waste STM RCRA hazardous waste generator status EPA ID Notification HMWMD CO3890090076 Completed

Hazardous waste JSF RCRA hazardous waste generator status EPA ID Notification HMWMD COD980805162 Completed

Hazardous waste NWTC RCRA hazardous waste generator status 

EPA ID Notification HMWMD COD983802448 Completed

Hazardous waste ReFUEL RCRA hazardous waste generator status 

EPA ID Notification HMWMD COR000207563 Completed

Historic registration STM amphitheater Registration NPS 93000378 In effect; does 

not expire

Historic registration STM stone bunker Registration NPS 93000379 In effect; does 

not expire

Table 12 continued on page 96
96 ENVIRONMENTAL PERFORMANCE REPORT 2014

TABLE 12. NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2014

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

Stormwater STM ESIF construction project Permit EPA COR12A60F Active

Stormwater STM electrical upgrade project Permit EPA COR12B06F Active

Stormwater NWTC dynamometer expansion construction 

project Permit EPA COR12A41F Terminated

Stormwater STM RSF II Construction Project Permit EPA COR12A62F Terminated

Stormwater STM SERF & STF Landscape Improvements/DWP 

Safety Enhancements (FTLB) Permit EPA COR12AW4F Active

Acronyms used in the table

APCD – Air Pollution Control Division of Colorado Department of Public Health and the Environment (CDPHE)

APEN – Air Pollutant Emission Notice

AST – Aboveground Storage Tank

CFC – Chlorofluorocarbon

DFD – Denver Fire Department

DOPS – Division of Oil and Public Safety of the Colorado Department of Labor and Employment

DWOP – Denver West Office Park

DWR – Division of Water Resources

EPA – Environmental Protection Agency

ESIF – Energy Systems Integration Facility

FTLB – Field Test Laboratory Building 

HMWMD – Hazardous Materials and Waste Management Division of CDPHE

IBRF – Integrated Biorefinery Research Facility

NPS – National Park Service of the U.S. Department of the Interior

NWTC – National Wind Technology Center

PDU – Process Development Unit

RCRA – Resource Conservation and Recovery Act

ReFUEL – Renewable Fuels and Lubricants Research Laboratory 

RFHP – Renewable Fuel Heat Plant 

RSF – Research Support Facility

S&TF – Science and Technology Facility

SERF – Solar Energy Research Facility

STM – South Table Mountain

TTB – Alcohol and Tobacco Tax and Trade Bureau of the U.S. Department of the Treasury

WHF – Waste Handling Facility

WMFR – West Metro Fire Rescue

WQCD – Water Quality Control Division of CDPHE

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303-275-3000 • www.nrel.gov

NREL is a national laboratory of the U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy 

Operated by the Alliance for Sustainable Energy, LLC

NREL/MP-1900-64208 • August 2015

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