NATIONAL RENEWABLE ENERGY LABORATORY

ENVIRONMENTAL PERFORMANCE REPORT for 2008

(Annual Site Environmental Report per DOE Orders 231.1 and 5400.5)

Prepared by:

Environment, Health, and Safety Office

National Renewable Energy Laboratory 

NREL is a national laboratory of the 

U.S. Department of Energy and is 

Operated by the Alliance for Sustainable Energy, LLC

September 2009
Cover photo contributed by Bob Fiehweg, 2008 – View of Eldorado Canyon from the National 

Wind Technology Center.

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NREL Environmental Performance Report, 2008 Page iii

List of Acronyms

AEO Annual Energy Outlook 

AFUF Alternative Fuels User Facility

APEN Air Pollution Emission Notice

AST Aboveground storage tank

bgs Below ground surface 

BMP Best management practice

BTU British thermal unit

CDPHE Colorado Department of Public Health and Environment 

CEQ Council on Environmental Quality

CFR Code of Federal Regulations 

CGP Construction General Permit

CMS Chemical Management System

CSP Concentrating solar power 

CY Calendar Year

DBP Disinfection byproduct 

DFD Denver Fire Department

DOE U.S. Department of Energy 

DOE-GO Department of Energy Golden Field Office 

DSOC District Shops and Operation Center 

DWOP Denver West Office Park

EA Environmental Assessment

EHS Environment, Health, and Safety Office

EIA Energy Information Agency 

EISA Energy Independence and Security Act 

ELP Environmental Leadership Program

EMS Environmental Management System

EO Executive Order 

EPA U.S. Environmental Protection Agency 

EPCRA Emergency Reporting and Community Right-to-Know Act

ESH&Q Environmental Safety, Health, and Quality 

FEC Federal Electronics Challenge

FTLB Field Test Laboratory Building

FY Fiscal Year

GH Golden Hill 

GHG Greenhouse gas

gsf Gross square foot 

HABS Historic American Buildings Survey

HAER Historic American Engineering Record

HMIS Hazardous Materials Information System

HSS U.S. Department of Energy Office of Health, Safety, and Security 

IPM Integrated pest management

IRCA International Register of Certificated Auditors

ISM Integrated Safety Management

ISO International Organization for Standardization

IUF Industrial User Facility
NREL Environmental Performance Report, 2008 Page iv

JSF Joyce Street Facility

LDRD Laboratory directed research and development 

LEED Leadership in Energy and Environmental Design 

LEPC Local Emergency Planning Committee 

MCL Maximum contaminant levels

MtC/yr Million metrics tons of carbon per year 

NEPA National Environmental Policy Act

NESHAP National Emissions Standards for Hazardous Air Pollutant

NOI Notice of Intent 

NPDES National Pollutant Discharge Elimination System

NREL National Renewable Energy Laboratory 

NWTC National Wind Technology Center 

ODS Ozone-depleting substances 

PDU Process Demonstration Unit

ppm Parts per million

PV Photovoltaics 

PWSID Public Water Supply Identification Number 

RAA Running annual average 

RCRA Resource Conservation and Recovery Act 

RFHP Renewable Fuels Heat Plant

ReFUEL Renewable Fuels and Lubricants Research Laboratory

RQ Reportable quantity

RSF Research Support Facilities

RTD Regional Transportation District

S&TF Science and Technology Facility

SARA Superfund Amendments and Reauthorization Act 

SERC State Emergency Response Commission

SERF Solar Energy Research Facility

SERI Solar Energy Research Institute

SHPO State Historic Preservation Officer

SIC Standard industrial classification

SOP Safe operating procedure 

SRRL Solar Radiation Research Laboratory

STM South Table Mountain

TCPDU Thermochemical Process Demonstration Unit

TEAM Transformation Energy Action Management

TPQ Threshold planning quantity 

USACE U.S. Army Corps of Engineers 

USDA U.S. Department of Agriculture 

WHF Waste Handling Facility
NREL Environmental Performance Report, 2008 Page v

Table of Contents

List of Figures ............................................................................................................................... ix

List of Tables ................................................................................................................................. ix

1 Introduction ............................................................................................................................. 1

1.1 Purpose ................................................................................................................................ 1

1.2 Background ......................................................................................................................... 1

1.3 Site and Facility Description ............................................................................................... 3

1.3.1 South Table Mountain Site ......................................................................................... 9

1.3.1.1 Geology, Soils, and Hydrogeology ................................................................... 9

1.3.1.2 Surface Water .................................................................................................... 9

1.3.1.3 Vegetation ......................................................................................................... 9

1.3.1.4 Wildlife ............................................................................................................ 10

1.3.1.5 Land Use .......................................................................................................... 10

1.3.2 National Wind Technology Center ........................................................................... 10

1.3.2.1 Geology, Soils, and Hydrogeology ................................................................. 10

1.3.2.2 Surface Water .................................................................................................. 11

1.3.2.3 Vegetation ....................................................................................................... 11

1.3.2.4 Wildlife ............................................................................................................ 11

1.3.2.5 Land Use .......................................................................................................... 11

1.3.3 Denver West Office Park ......................................................................................... 12

1.3.4 Joyce Street Facility ................................................................................................. 12

1.3.5 Renewable Fuels and Lubricants Research Laboratory ........................................... 12

1.4 Site Environmental Conditions/Features ........................................................................... 12

1.4.1 Climate ..................................................................................................................... 12

2 Compliance Summary ........................................................................................................... 17

2.1 Laws and Regulations ....................................................................................................... 17

2.1.1 Air Quality Protection .............................................................................................. 17

2.1.2 Drinking Water Quality Protection .......................................................................... 17

2.1.3 Groundwater Quality Protection .............................................................................. 17

2.1.4 Wastewater ............................................................................................................... 17

2.1.5 Surface Water Quality Protection ............................................................................. 18

2.1.6 Waste Management .................................................................................................. 18

2.1.7 Storage Tanks ........................................................................................................... 18

2.1.8 Threatened and Endangered Species/Species of Concern ........................................ 19

2.1.9 EPCRA Compliance and Prevention of Toxic Releases .......................................... 19

2.1.10 Cultural Resources Protection ................................................................................ 19

2.1.11 2008 Events ............................................................................................................ 20

2.1.11.1 Nitric Acid Spill ............................................................................................ 20

2.1.11.2 Antifreeze Release ......................................................................................... 20

2.1.11.3 Propylene Glycol Spill on South Table Mountain ........................................ 20

2.1.11.4 Epoxy spill ..................................................................................................... 20

2.2 DOE Order 450.1, Environmental Protection Program .................................................... 20

2.3 Executive Orders ............................................................................................................... 21
NREL Environmental Performance Report, 2008 Page vi

2.3.1 Executive Order 13423, Strengthening Federal Environmental, Energy, and 

Transportation Management ........................................................................................ 21

2.3.2 Executive Order 11988, Floodplains Management .................................................. 21

2.3.3 Executive Order 11990, Wetlands Protection .......................................................... 21

2.4 Permit Summary ................................................................................................................ 21

3 NREL’s Role in the Environment – Global and Local ...................................................... 22

3.1 Energy Policy Changes in 2008 ........................................................................................ 22

3.2 NREL Research Helping Meet Legislative Goals ............................................................. 24

3.2.1 General Capabilities ................................................................................................. 24

3.2.2 Biofuels .................................................................................................................... 24

3.3 NREL – Research to Address Climate Change ................................................................. 25

3.3.1 Wind ......................................................................................................................... 26

3.3.2 Concentrating Solar Power ....................................................................................... 26

3.3.3 Photovoltaics ............................................................................................................ 27

4 Environmental Management System ................................................................................... 28

4.1 Policy ................................................................................................................................. 28

4.1.1 NREL’s EMS and Integrated Safety Management (ISM) System ........................... 29

4.1.2 Notable 2008 Activities ............................................................................................ 29

4.1.2.1 Federal Electronics Challenge ......................................................................... 29

4.1.2.2 Notable Practice among DOE Laboratories .................................................... 29

4.1.2.3 Lead Auditor Training – ISO 14001:2004 ...................................................... 30

4.1.2.4 Colorado Environmental Leadership Program ................................................ 30

4.1.3 Public Outreach ........................................................................................................ 31

4.2 Performance Indicators and Progress ................................................................................ 32

4.2.1 2008 Environmental Objectives and Progress toward Goals ................................... 32

4.2.2 State of Colorado ELP Commitments (2007 – 2010) .............................................. 32

4.2.2.1 “Campus Planning” ......................................................................................... 33

4.2.3 2009 Environmental Objectives ............................................................................... 33

4.3 Assessment and Improvement ........................................................................................... 34

4.3.1 2008 Assessment Activities ...................................................................................... 34

4.4 Sustainability and the Environmental Management System ............................................. 35

5 Environmental Programs ..................................................................................................... 36

5.1 Air Quality Protection ....................................................................................................... 36

5.1.1 Program Management .............................................................................................. 36

5.1.1.1 Criteria, Non-criteria, and Hazardous Pollutants ............................................ 36

5.1.1.2 Ozone-depleting Substances ............................................................................ 37

5.1.1.3 Street Sanding .................................................................................................. 37

5.1.2 Permitting ................................................................................................................. 37

5.1.3 2008 Activities ......................................................................................................... 37

5.2 Drinking Water .................................................................................................................. 38

5.2.1 Program Management .............................................................................................. 38

5.2.2 Permitting/Notifications ........................................................................................... 39

5.2.3 2008 Activities ......................................................................................................... 39

5.3 Groundwater ...................................................................................................................... 40

5.3.1 Program Management .............................................................................................. 40
NREL Environmental Performance Report, 2008 Page vii

5.3.2 Permitting ................................................................................................................. 42

5.3.3 2008 Activities ......................................................................................................... 42

5.4 Wastewater Discharge ....................................................................................................... 42

5.4.1 Program Management .............................................................................................. 42

5.4.2 Permitting ................................................................................................................. 43

5.4.3 2008 Activities ......................................................................................................... 43

5.5 Surface Water Protection (Stormwater and Erosion Control) ........................................... 43

5.5.1 Program Management .............................................................................................. 43

5.5.1.1 Past Investigations ........................................................................................... 43

5.5.1.2 Current Management Practices ....................................................................... 44

5.5.2 Permitting ................................................................................................................. 44

5.5.3 2008 Activities ......................................................................................................... 44

5.6 Waste Management ........................................................................................................... 44

5.6.1 Program Management .............................................................................................. 44

5.6.2 Permitting ................................................................................................................. 45

5.6.3 2008 Activities ......................................................................................................... 45

5.7 Storage Tanks (Underground and Aboveground) ............................................................. 46

5.7.1 Program Management .............................................................................................. 46

5.7.2 Permitting ................................................................................................................. 46

5.7.3 2008 Activities ......................................................................................................... 46

5.8 Hazardous Materials Management .................................................................................... 47

5.8.1 Program Management .............................................................................................. 47

5.8.2 Permitting ................................................................................................................. 48

5.8.3 2008 Activities ......................................................................................................... 49

5.9 Pollution Prevention and Sustainability ............................................................................ 49

5.9.1 Program Management .............................................................................................. 49

5.9.2 Permitting ................................................................................................................. 49

5.10 Vegetation Management .................................................................................................. 49

5.10.1 Program Management ............................................................................................ 49

5.10.2 Permitting ............................................................................................................... 51

5.10.3 2008 Activities ....................................................................................................... 52

5.11 Wildlife ............................................................................................................................ 52

5.11.1 Program Management ............................................................................................ 52

5.11.2 NWTC Site ............................................................................................................. 52

5.11.3 STM Site ................................................................................................................. 53

5.11.4 Permitting ............................................................................................................... 54

5.11.5 2008 Activities ....................................................................................................... 54

5.11.5.1 Migratory Birds and Raptors ......................................................................... 54

5.11.5.2 Large Mammals ............................................................................................. 55

5.11.5.3 Predators ........................................................................................................ 55

5.11.5.4 Small Mammals ............................................................................................. 55

5.11.5.5 Reptiles/Amphibians ..................................................................................... 56

5.12 Endangered Species/Species of Concern ........................................................................ 57

5.12.1 Program Management ............................................................................................ 57

5.12.2 Permitting ............................................................................................................... 58

5.12.3 2008 Activities ....................................................................................................... 58

5.13 Wetlands/Floodplains ...................................................................................................... 58

5.13.1 Program Management ............................................................................................ 58
NREL Environmental Performance Report, 2008 Page viii

5.13.2 2008-2009 Activities .............................................................................................. 58

5.14 Cultural Resources .......................................................................................................... 59

5.14.1 Program Management ............................................................................................ 59

5.14.1.1 Site Surveys ................................................................................................... 60

5.14.2 Permitting and Requirements ................................................................................. 61

5.14.3 2008 Activities ....................................................................................................... 61

5.15 National Environmental Policy Act ................................................................................ 61

5.15.1 Program Management ............................................................................................ 61

5.15.2 Permitting ............................................................................................................... 62

5.15.3 2008 Activities ....................................................................................................... 62

5.16 Radiological Program ...................................................................................................... 62

5.16.1 Program Management ............................................................................................ 62

5.16.2 Permitting ............................................................................................................... 63

6 Conservation Easement Lands ............................................................................................. 64

6.1 2008 Property Assessment ................................................................................................ 65

7 Contacts for Feedback or More Information ..................................................................... 66

8 References .............................................................................................................................. 67

9 Appendices ............................................................................................................................. 69

Appendix A – Summary of NREL Environmental Permits, Registrations, Notifications ...... 70

Appendix B – Wildlife Species Observed at NREL’s STM Site ............................................ 75
NREL Environmental Performance Report, 2008 Page ix

List of Figures

Figure 1. Regional map showing NREL locations in Jefferson County, CO ................................ 5

Figure 2. ReFUEL Facility location map, located in Denver County, CO ................................... 6

Figure 3. STM site detail ............................................................................................................... 7

Figure 4. NWTC site detail ........................................................................................................... 8

Figure 5. South Table Mountain site – west end of the site ........................................................ 14

Figure 6. South Table Mountain site – east view ........................................................................ 14

Figure 7. South Table Mountain site – Mesa Top facilities and amphitheater ........................... 15

Figure 8. South Table Mountain site – Denver West Office Park .............................................. 15

Figure 9. NWTC site – northwest view ....................................................................................... 16

Figure 10. NWTC site – northwest view with research facilities ............................................... 16

Figure 11. Energy policy changes in 2008 .................................................................................. 22

Figure 12. Primary energy use by source, 2007 .......................................................................... 23

Figure 13. Sources of energy and the expenditures of energy in the United States, summary ... 23

Figure 14. Seizing the moment to make transformational change .............................................. 24

Figure 15. Global and nationwide renewable resources are plentiful ......................................... 24

Figure 16. Building on existing renewable energy technologies ................................................ 25

Figure 17. Nationwide installed wind capacity ........................................................................... 26

Figure 18. NREL's IMM solar cell .............................................................................................. 27

Figure 19. Science on a Sphere exhibit ....................................................................................... 31

Figure 20. Sego Lily at the NWTC ............................................................................................. 50

Figure 21. Prairie Goldenpea Thermopsis at the NWTC ............................................................ 51

Figure 22. Vesper Sparrow at NWTC ......................................................................................... 53

Figure 23. Western Meadowlark on STM ................................................................................... 54

Figure 24. Red-tailed Hawk soaring over STM .......................................................................... 55

Figure 25. Black-tailed prairie dog at the NWTC ....................................................................... 56

Figure 26. Conservation easement lands ..................................................................................... 64

Figure 27. Site wildlife at sunset ................................................................................................. 66

List of Tables

Table 1. Summary of NREL Environmental Permits, Registrations, Notifications .....................70

Table 2. Wildlife Species Observed at NREL’s STM Site ..........................................................75
NREL Environmental Performance Report, 2008 Page x
NREL Environmental Performance Report, 2008 Page 1

1 Introduction

The National Renewable Energy Laboratory (NREL) is the nation's premier laboratory for 

renewable energy research and development, and a leading laboratory for energy efficiency 

research with programs in wind energy, solar energy, plant- and waste-derived fuels and 

chemicals, energy efficiency in buildings, geothermal energy, advanced vehicle design, hydrogen 

infrastructure, and fuel cells. Established in 1974, NREL began operating in 1977 as the Solar 

Energy Research Institute (SERI). It was designated a U.S. Department of Energy (DOE) 

national laboratory in September 1991 as the National Renewable Energy Laboratory. NREL 

conducts research primarily for DOE’s Office of Energy Efficiency and Renewable Energy. In 

October 2008, operations at NREL were transferred to the Alliance for Sustainable Energy, LLC, 

a partnership between the Midwest Research Institute and the Battelle Memorial Institute. The 

new operating contract has a 5-year duration and is overseen by the Department of Energy’s

Golden Office (DOE-GO).

1.1 Purpose 

This report presents a summary of NREL’s environmental protection programs and activities for 

2008. It is organized according to the different environmental media (e.g., air, waste, ground 

water, etc.), and includes a brief summary of how the program is managed in that area, any 

permitting or notification efforts that have been completed during the reporting period or are 

ongoing, and activities that have occurred during the reporting period in that environmental area. 

A description of the environmental condition and features of NREL’s sites is also included to 

provide a basis for the program overview. 

This report is organized to present many of the elements of the Global Reporting Initiative 

Sustainability Reporting Guidelines. It also incorporates DOE’s most recent guidelines for the 

Annual Site Environmental Report, as required by DOE Orders 231.1 and 5400.5. 

1.2 Background 

NREL’s mission is to develop renewable energy and energy efficiency technologies and 

practices, advance related science and engineering, and transfer knowledge and innovations to 

the private sector 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 NREL’s 

renewable energy and energy efficient technologies. 

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 increases the use of energy efficiency technologies and expands the 

use of renewable energy technologies in the building sector by working to develop new, costeffective, environmentally acceptable building equipment and envelope systems. 
NREL Environmental Performance Report, 2008 Page 2

Computational Sciences: This area includes basic and applied research using high-performance 

computing and applied mathematics. 

Distributed Power: Distributed power is modular electric generation or storage located near the 

point of use. NREL participates in the development of technologies, market structures, and 

policies that affect the incorporation of renewables and energy efficiency technologies in 

distributed power systems, maximizing the utilization of renewable energy and energy efficiency 

products. As a part of this initiative, NREL is involved in the development, design, and 

facilitation of the application of renewable and renewable/fossil hybrid distributed power 

systems in grid-connected applications. 

Electricity Technologies: These technologies include renewable energy, hydrogen, and 

superconductivity technologies, as well as utility resources. 

Energy Analysis: Research at NREL includes energy analysis for various programs and 

initiatives. 

Hydrogen: NREL serves as a leader in renewable hydrogen production technologies. NREL also 

leads in 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 labs and facilities allow state-of-the-art testing on 

photovoltaic cells, building technologies, and wind turbines. 

Photovoltaics: Photovoltaics (PV) enable the direct conversion of sunlight to electricity using 

solid-state materials. The National Center for Photovoltaics develops and deploys PV 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: These technologies—including concentrating solar power 

(CSP), solar water heating, and geothermal heat and power—generate power from heat or utilize 

heat from renewable resources.

Transportation: NREL works with industry to develop advanced vehicles and systems for 

transportation, and to develop viable vehicle systems that are integral to DOE transportation 

initiatives. NREL also works with energy companies and manufacturers of vehicles and engines 

to develop advanced motor vehicle fuels for improved energy and environmental performance. A 

systems approach is used to develop optimized engine management, fuel, and emission control 

technologies. 

Wind Energy: Through the National Wind Technology Center (NWTC), NREL develops, 

improves, and demonstrates the viability of wind technology for electricity generation and 

facilitates its utilization throughout the world. 
NREL Environmental Performance Report, 2008 Page 3

1.3 Site and Facility Description 

NREL facilities occupy five separate locations in Jefferson County, Colorado, near the city of 

Denver, and one within the boundaries of the City and County of Denver. The five facilities in 

Jefferson County include the Denver West Office Park (DWOP), Golden Hill (GH), the South 

Table Mountain site (STM), the Joyce Street Facility (JSF), and the NWTC. The Renewable 

Fuels and Lubricants Research Laboratory (ReFUEL) is located within the city limits of Denver. 

The DWOP, GH, and STM sites are approximately two miles (3.2 km) east of Golden and 12 

miles (19.3 km) west of central Denver. 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 site. The JSF is located at 6800 Joyce Street, about 5.5 miles (8.9 km) north of the DWOP 

and STM sites. The ReFUEL facility is located with the Regional Transportation District (RTD) 

District Shops and Operation Center (DSOC) at 1900 31st Street, Denver, about 12 miles east of 

the STM and DWOP sites. Figure 1 illustrates the locations of the STM, DWOP, NWTC, and 

JSF sites on a regional map. The location of the ReFUEL facility is shown in Figure 2. Figure 3

provides a more detailed map of the STM site, and Figure 4 provides detail for the NWTC site. 

The STM and NWTC sites are the two main sites where research operations are conducted and 

will be addressed separately in the discussion of environmental features. The DWOP is leased 

space used primarily for administrative functions and limited research activities. The JSF is also 

a leased space that is currently used for storage. The ReFUEL facility is a leased facility that 

consists of a small shop complex housed within the RTD/DSOC facility. NREL performs 

engine-testing activities pertaining to fuels and lubricants at the site.

A number of significant changes to the NREL South Table Mountain campus were made in 

2008. The new Renewable Fuels Heat Plant (RFHP) was constructed between the Field Test 

Laboratory Building and the Solar Energy Research Facility to provide heat to STM campus 

buildings. Using wood chips from forest thinning projects along Colorado's Front Range and 

other urban wood waste, the RFHP provides hot water through underground pipes to heat most 

of NREL's facilities on the STM site. The RFHP has an estimate output of 29 billion BTUs per 

year; however, it saves more than 40 billion BTUs of natural gas due to conversion efficiencies. 

The RFHP will offset fossil fuel CO2 emissions of 4.8 million pounds per year. 

In addition to the RFHP, a large solar panel array was constructed on NREL property on top of 

STM. The 750 kW Mesa Top Photovoltaic Array is expected to produce 1.2 gigawatt hours of 

solar electricity per year. The array ensures NREL will exceed the Energy Policy Act of 2005 

goal of 7.5% of a federal facility's electricity coming from renewable sources. In fact, the 

installation alone could provide as much as 7.2% of the electricity the lab uses. It will offset 2.4 

million pounds of fossil fuel CO2 production annually.
NREL Environmental Performance Report, 2008 Page 4
NREL Environmental Performance Report, 2008 Page 5

Figure 1. Regional map showing NREL locations in Jefferson County, CO

National Wind 

Technology Center

Joyce Street 

Facility

Denver West Office 

Park Site (Buildings 

3, 7, 15, 16, 17, 52)

Golden 

Hill
NREL Environmental Performance Report, 2008 Page 6

 

Figure 2. ReFUEL Facility location map, located in Denver County, CO

NREL

ReFUEL

Facility

I-25

I-70
NREL Environmental Performance Report, 2008 Page 7

Figure 3. STM site detail
NREL Environmental Performance Report, 2008 Page 8

Figure 4. NWTC site detail
NREL Environmental Performance Report, 2008 Page 9

1.3.1 South Table Mountain Site 

1.3.1.1 Geology, Soils, and Hydrogeology 

The South Table Mountain (STM) site is a roughly triangular parcel of land occupying portions 

of the top, sides, and lower south-facing slopes of STM. STM is composed of sedimentary rocks 

below a basalt lava cap, which is quite resistant to erosion. The STM feature is a mesa that stands 

about 150 meters above the adjacent lowlands. 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 site 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 the STM, 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 the STM is lavina loam. Loam is composed of a mixture of clay, 

sand, silt, and organic matter. The loam on the mesa top is a shallow, well-drained clayey soil. 

Soil on the upper side slopes of the STM 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, well-drained 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. 

1.3.1.2 Surface Water 

About 90% of the surface drainage off the site, both from the mesa top and across the lower 

portions of the site, is in the southerly direction toward Lena Gulch (a tributary of Clear Creek). 

Surface water from two drainage ways on the easternmost portion of the site ultimately flows 

into Lena Gulch. 

There is no permanent stream flow on the STM site. Only occasional flow derived 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. 

1.3.1.3 Vegetation 

Two primary vegetation types are present on the STM site: grasslands and shrublands. The most 

common plant communities on the STM site are mixed grasslands, composing 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 site: mountain mahogany 

shrublands, found on the shallow soils of the mesa, and upland shrublands, occurring in 
NREL Environmental Performance Report, 2008 Page 10

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

have identified limited wetland/riparian areas along drainages. The wetland communities 

identified on the STM site 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. 

1.3.1.4 Wildlife 

A wildlife survey was conducted on the site during 1986 and 1987, and additional surveys were 

done in 1999 over the conservation easement property. A survey to update the existing data 

began in 2004 and was completed in 2005 (see Section 5.11 for more detail). Mammals seen 

using the site during the surveys include mule deer, coyotes, gray foxes, red foxes, raccoons, 

long tailed weasels, striped skunks, spotted skunks, badgers, bobcats, mountain lions, rabbits, 

and yellow-bellied marmots.

 

Seventeen species of birds have been observed on the STM site, along with two species of 

raptors: American kestrels and two nesting pairs of red-tailed hawks. Amphibian species and 

snakes are known to inhabit the area as well. 

1.3.1.5 Land Use 

The STM site is a 327-acre 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 of the western portions of the STM site. Pleasant View has 

constructed a recreational park immediately south of the STM site. 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 site on top of the mesa. Jefferson County 

open space wraps around the northern and the eastern edge of the site. Portions of the DWOP 

and apartment homes lie to the east. 

More than half of the STM site (177 acres) 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. Trail development planned 

for implementation in phases by the County began in 2004 (see Section 6.0 for more detail). 

 

1.3.2 National Wind Technology Center 

1.3.2.1 Geology, Soils, and Hydrogeology 

The National Wind Technology Center (NWTC) site is located on a plain formed by stream 

deposits. The uppermost geological layer beneath the site is known as the Rocky Flats Alluvium 

(RFA). It is composed of cobbles, coarse gravel, sand, and gravelly clay. Below the RFA 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 RFA 

toward the east/southeast, and small perched zones are common. Groundwater occurs as 

confined aquifers in the deeper bedrock formations (EG&G Rocky Flats, Inc. 1992). 
NREL Environmental Performance Report, 2008 Page 11

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 (USDA 1995). 

1.3.2.2 Surface Water 

The area surrounding the NWTC site 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. 

1.3.2.3 Vegetation 

The NWTC is located in the transition area between the Great Plains and the Rocky Mountains 

(Plantae Consulting Services 2000). This location results in flora that contains elements from 

both mountain and prairie ecosystems, and associations that represent residual tall grass prairie, 

short-grass plains, ponderosa pine woodland, and foothill ravine flora (Plantae Consulting 

Services 2000). 

A vegetation study conducted between August 1999 and August 2000 identified 271 vascular 

plant species and defined five major habitat types on the NWTC site, including: seasonal 

wetlands/or ephemeral hydric soils, woodlands, shrublands, mixed grasslands, 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. 

1.3.2.4 Wildlife 

Prior to 1975, livestock heavily grazed the NWTC site, damaging a majority of the native 

vegetation. A wildlife survey was conducted in 1992 for the entire Rocky Flats Plant and buffer 

zone area, including the NWTC site. 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, whitetailed 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 

(birds of prey) 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 conducted in 2001 to 

2002 (see Section 5.11). Although seldom seen, rattlesnakes, bull snakes, racers, and several 

other reptilian and amphibian species are known to occupy the area. 

1.3.2.5 Land Use 

The NWTC facility occupies a 305-acre area surrounded largely by open space and grazing land. 

The former Rocky Flats Environmental Technology Site land borders the NWTC to the 

southeast, and a sand and gravel mining and processing operation is located along the southern 
NREL Environmental Performance Report, 2008 Page 12

and western boundaries of the site. A blasting company also has a small installation along the 

western site boundary. 

1.3.3 Denver West Office Park 

The Denver West Office Park (DWOP) is a relatively flat, landscaped office complex occupied 

by a number of four-story buildings, parking lots, and common areas. NREL-leased facilities at 

the DWOP are located approximately in the geographic center of the development, with the 

exception of one NREL-leased facility just north of West Colfax. The DWOP is bordered on the 

south by commercial areas (West Colfax strip), on the west by the Pleasant View residential 

area, Camp George West facility, and the STM site. The DWOP is within the City of Lakewood. 

1.3.4 Joyce Street Facility 

The Joyce Street Facility (JSF) 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 only. Support activities and limited dry lab research activities are currently 

conducted at the facility, and there are no staff offices at the JSF. 

1.3.5 Renewable Fuels and Lubricants Research Laboratory 

The Renewable Fuels and Lubricants Research Laboratory (ReFUEL) is used for research, 

testing, and support activities related to advanced fuels, engines, and vehicles to objectively 

evaluate performance, emissions, and energy efficiency impacts. The laboratory is also used to 

evaluate and develop heavy hybrid electric vehicles. 

The ReFUEL is a small shop complex housed within the RTD/DSOC facility. The RTD/DSOC 

facility occupies approximately 22 acres of land and serves as the primary maintenance facility 

for RTD’s bus and light rail train systems. The area around the RTD/DSOC 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 south, east, and northeast borders. 

1.4 Site Environmental Conditions/Features 

Photos for each site documenting the site features and development are included at the end of 

this section. Figures 5, 6, 7, and 8 show the STM and DWOP sites, and Figures 9 and 10 provide 

images of the NWTC site. The views on the STM site also illustrate the conservation easement 

property and the Camp George West property acquired in 1999. 

1.4.1 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 50 cm 

(20 inches). Almost half of the annual precipitation occurs from March to June. Summer showers 
NREL Environmental Performance Report, 2008 Page 13

contribute 33% of the annual precipitation total. Precipitation begins to decrease significantly in 

the fall, and reaches 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 site can generally expect to 

experience at least one heavy snowstorm with totals exceeding 15 to 25 cm (6 to 10 inches). 

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, season to season.
NREL Environmental Performance Report, 2008 Page 14

Figure 5. South Table Mountain site – west end of the site 

Figure 6. South Table Mountain site – east view
NREL Environmental Performance Report, 2008 Page 15

Figure 7. South Table Mountain site – Mesa Top facilities and amphitheater 

Figure 8. South Table Mountain site – Denver West Office Park
NREL Environmental Performance Report, 2008 Page 16

Figure 9. NWTC site – northwest view

Figure 10. NWTC site – northwest view with research facilities
NREL Environmental Performance Report, 2008 Page 17

2 Compliance Summary 

2.1 Laws and Regulations

2.1.1 Air Quality Protection 

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). 

NREL is not a major source for air pollutants, but does hold two site-wide permits for particulate 

air emissions from construction, one air emissions permit for a pilot-scale research project, and 

one air permit for the operation of the RFHP, a woodwaste-fired heating plant. Detailed 

information about NREL’s air quality protection program is provided in Section 5.1. 

National Emissions Standards for Hazardous Air Pollutants (NESHAP) requirements specific to 

radiological emissions from DOE facilities are regulated by the EPA. Details are provided in 

Section 5.16. 

 

During 2008, NREL had no air quality compliance issues. 

2.1.2 Drinking Water Quality Protection 

Drinking water quality is regulated for all public water suppliers in Colorado by the CDPHE, 

under authority delegated by the EPA. NREL purchases water that is delivered by truck to the 

NWTC, and holds a public water supply identification number to operate the NWTC distribution 

system. NREL has been conducting increased monitoring since the fourth quarter of 2006 for 

disinfection byproducts. Detailed information about system performance is provided in Section 

5.2. 

In 2008, NREL had no drinking water compliance issues. 

2.1.3 Groundwater Quality Protection 

Colorado groundwater quality standards are established by the CDPHE. Permits for groundwater 

wells are issued by the state engineer’s office. NREL has no known groundwater contamination 

and has obtained drilling permits for all of its monitoring wells. Detailed information about 

NREL’s groundwater program is provided in Section 5.3. 

In 2008, NREL had no groundwater compliance issues. 

2.1.4 Wastewater 

Wastewater from the majority of the STM site and the Denver West Office Park is discharged 

into the Pleasant View Water and Sanitation District’s (Pleasant View) collection system, and 

flows to the Metropolitan Wastewater Reclamation District (Metro) treatment plant. The federal 

Clean Water Act and Colorado Water Quality Control Act regulations are administered at 

NREL’s STM and DWOP via Pleasant View and Metro pretreatment program requirements. 

NREL’s wastewater discharge policy is in conformance with Metro’s discharge requirements. 
NREL Environmental Performance Report, 2008 Page 18

Wastewater at the NWTC site flows into two individual sewage disposal systems (septic and 

leach fields). These are regulated by CDPHE; inspection and permit issuance have been 

delegated by CDPHE to the Jefferson County Department of Health and Environment. There is 

also one individual sewage disposal system at the Solar Radiation Research Laboratory (SRRL) 

on the mesa top at the STM site. As is the case with NWTC septic systems, the mesa top system 

regulations are administered by Jefferson County. Additional detail about NREL’s wastewater 

discharge program can be found in Section 5.4. 

In 2008, NREL had no wastewater compliance issues. 

2.1.5 Surface Water Quality Protection 

Stormwater discharge regulations are administered by the EPA at federal sites in Colorado. As a 

result, NREL falls under the EPA Construction General Permit (CGP) program for the STM and 

NWTC sites for stormwater discharge from construction activities. Permit coverage for 

individual NREL activities is obtained when permit thresholds are triggered. 

At the STM, a Notice of Intent (NOI) was filed with the EPA in 2005 for the construction of a 

new research facility. This project was managed under the EPA’s Construction General Permit 

program. Sufficient vegetative coverage was achieved in mid-2008 and a Notice of Termination 

for the permit was filed with the EPA. 

At the NWTC, one small construction project was undertaken in 2007 that required a CGP. 

Sufficient vegetative coverage was achieved in mid-2008 and a Notice of Termination for the 

permit was filed with the EPA. Details of NREL’s surface water protection program are provided 

in Section 5.5. 

In 2008, NREL had no surface water compliance issues. 

2.1.6 Waste Management 

The Resource Conservation and Recovery Act (RCRA) established federal authority over 

hazardous waste. In Colorado, the CDPHE administers hazardous waste regulations under 

authority delegated by the EPA. NREL holds five EPA generator identification numbers for each 

of its sites. NREL’s waste management program is outlined in Section 5.6. Pollution prevention 

efforts at NREL are described in Section 5.9. 

A hazardous waste program improvement plan was developed in 2008 in response to an EPA 

inspection and warning letter issued in 2007. The EPA’s findings were addressed immediately 

and the agency issued a letter closing the matter in February 2008. Program details are discussed 

in Section 5.6. 

In 2008, NREL had no waste management compliance issues. 

2.1.7 Storage Tanks 

NREL has no underground storage tanks containing hazardous materials. Aboveground storage 

tanks (ASTs) that are larger than 660 gallons are regulated in Colorado by the Colorado 

Department of Labor and Employment’s Oil Inspection Section. NREL has two tanks larger than 
NREL Environmental Performance Report, 2008 Page 19

660 gallons on the STM site that are registered with the Colorado Department of Labor and 

Employment. Details about NREL’s AST program are provided in Section 5.7. 

No spills or releases from NREL’s ASTs occurred during 2008. 

2.1.8 Threatened and Endangered Species/Species of Concern

Wildlife is protected by a number of federal laws, including (but not limited to) the Endangered 

Species Act, the Migratory Bird Treaty Act, and the Golden and Bald Eagle Protection Act. The 

Endangered Species Act also protects threatened and endangered plant species. State laws 

designate and protect rare or unique plants and animals as well. No threatened or endangered 

species or species of concern have been documented on NREL’s sites. Details of NREL’s 

wildlife and vegetation surveys are provided in Sections 5.10 and 5.11. 

In 2008, NREL had no compliance issues regarding wildlife. 

2.1.9 EPCRA Compliance and Prevention of Toxic Releases 

Executive Order (EO) 13423 and DOE Order 450.1A outline requirements for Superfund 

Amendments and Reauthorization Act (SARA) Title III, Emergency Reporting and Community 

Right-to-Know Act (EPCRA) compliance, and Toxic Release Inventory reductions for DOE 

facilities. NREL maintains hazardous materials permits with West Metro Fire Rescue (West 

Metro) and provides chemical inventory information to West Metro for the STM site and 

Building 16 in the DWOP. NREL’s ReFUEL facility holds a Hazardous Materials Permit issued 

by the Denver Fire Department.

In 2008, NREL facilities had no releases exceeding the reportable quantity (RQ) of any material 

reportable under EPCRA. As a research and development laboratory, NREL does not 

manufacture or process any materials on the SARA Section 313 list in excess of the 4,526-kg 

(10,000-lb) threshold planning quantity. During 2008, the laboratory did not otherwise use any 

materials on the SARA Section 313 list in quantities exceeding the 4,526-kg (10,000-lb) 

threshold planning quantity. NREL’s compliance with EPCRA requirements is detailed in 

Section 5.8. 

NREL maintains an Emergency Management Policy (8-4) and supporting lab-level programs for 

credible on-site emergencies. Hazardous material releases are specifically identified as a credible 

emergency, and response procedures are in place. These procedures are routinely practiced by 

internal response groups and with external emergency response agencies. 

2.1.10 Cultural Resources Protection 

Various laws, including but not limited to, the National Historic Preservation Act and the Native 

American Graves Protection and Repatriation Act, protect cultural resources. NREL has two 

sites listed on the National Register of Historic Places (National Register) on its STM site. There 

are no known eligible sites at the NWTC (see Section 5.14). 

In 2008, NREL had no compliance issues regarding cultural resources. 
NREL Environmental Performance Report, 2008 Page 20

2.1.11 2008 Events

During the course of operating a major national laboratory, events occur which may have an 

impact on the environment. NREL experienced four incidents in 2008 that had minor 

environmental impacts. 

2.1.11.1 Nitric Acid Spill

On March 25, 2008, a cardboard box containing a bottle of nitric acid was being delivered to the 

Field Test Laboratory Building (FTLB) when it was dropped. The bottle broke in the box and 

some of the contents leaked onto the loading dock. Site personnel responded immediately, 

contained the spilled material, applied absorbent, and cleaned the area thoroughly. The area of 

the spill was restricted to a few square feet of concrete at the base of the loading dock.

Absorbents and cleaning materials were packaged for disposal. 

2.1.11.2 Antifreeze Release

On May 7, 2008, an 18-wheeler truck had a ruptured radiator and leaked 5 to 10 gallons of 

coolant onto the paved road immediately north of the Outdoor Test Facility (OTF). The coolant 

flowed down the gutter and pooled in an area downhill from the truck. Site personnel responded, 

applied absorbent material, and cleaned the area thoroughly. The area of the spill was restricted 

to the paved surface and a small area of unpaved ground where the coolant had pooled. The 

absorbents, cleaning materials, and a small amount of sand and soil were packaged for disposal. 

2.1.11.3 Propylene Glycol Spill on South Table Mountain

On May 30, 2008, approximately 175 gallons of propylene glycol and water was released onto a 

concrete and asphalt surface at the Solar Industrial Mesa Test Area, located on top of STM. The 

release was the result of a leaking PVC line serving a 28 ton chiller. The release occurred over a 

weekend and, when discovered on the following Monday, the spilled material had largely 

evaporated or was absorbed by the asphalt. 

2.1.11.4 Epoxy spill

On September 8, 2008, a truck carrying flooring materials for the RFHP was traveling on the 

north access road when a 5-gallon container of epoxy adhesive fell from the open tailgate. Site 

personnel responded and contained the material with absorbents. The area of the spill was 

restricted to the paved surface of the road. The absorbents and remnant epoxy materials were 

packaged for disposal. 

2.2 DOE Order 450.1, Environmental Protection Program 

DOE Order 450.1 required sites to implement an Environmental Management System (EMS) by 

integrating them with the site’s Integrated Safety Management System. Sites were required to 

have an EMS in place by December 31, 2005. The revised Order 450.1A requires that EMSs 

now be structured according to International Organization for Standardization (ISO) 14001

requirements by June 2009. NREL’s implementation of its EMS is described in Section 4.0 of 

this report. 
NREL Environmental Performance Report, 2008 Page 21

2.3 Executive Orders 

2.3.1 Executive Order 13423, Strengthening Federal Environmental, Energy, and 

Transportation Management

On January 24, 2007, the President signed EO 13423. This Order requires all federal agencies 

and departments to “conduct their environmental, transportation, and energy-related activities 

under the law in support of their respective missions in an environmentally, economically, and 

fiscally sound, integrated, continuously improving, efficient, and sustainable manner” (72 FR 

3919). DOE’s senior management, with NREL’s participation, has been working on a 

Transformational Energy Action Management (TEAM) Initiative to create and implement a plan 

intended to expedite meeting the EO requirements. NREL’s progress in meeting this EO is 

described in Section 4.2. 

2.3.2 Executive Order 11988, Floodplains Management 

EO 11988 was implemented in support of the National Environmental Policy Act (NEPA), the 

National Flood Insurance Act of 1968, and the Flood Disaster Protection Act of 1973 to 

minimize the adverse impacts associated with development and modification of floodplains. 

According to maps generated by the Jefferson County Department of Highways and 

Transportation as part of its urban drainage studies, NREL's STM site does not contain any 

floodplains, and no floodplains have been identified at the NWTC. As a best management 

practice (BMP); however, all construction activities that may cross a drainage channel are 

designed to meet the 100-year flood control standards (designed to withstand the equivalent of a 

100-year flood). Actions with the potential for environmental impact that are undertaken by 

NREL at subcontractor facilities are assessed for potential impacts on floodplains and wetlands 

at those sites through the use of an environmental checklist. 

2.3.3 Executive Order 11990, Wetlands Protection 

Under EO 11990, each federal agency 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. Limited wetland areas totaling less than 0.3 hectares (0.75 acres) 

occur on the STM site. These are narrow, linear wetlands supporting spikerush, baltic rush, 

sedges, bluegrass, hemlock, and field mint. Wetland areas at the NWTC are extremely limited in 

extent as well. These areas, along the site’s eastern boundary, total less than 0.4 hectares (1 acre). 

In 2008, NREL had no compliance issues regarding environment-related EOs.

2.4 Permit Summary 

Appendix A contains a table summarizing NREL’s permits, registrations, and notifications. 
NREL Environmental Performance Report, 2008 Page 22

Figure 11. Energy policy changes in 2008

Source: D. Arvizu, Nov. 2008 presentation

3 NREL’s Role in the Environment – Global and Local

As one of the nation’s premier resources for renewable energy information, research, and 

technology, NREL has a unique role in supporting the “nation’s energy and environmental 

goals.” NREL has a positive environmental presence, both in the operation of the laboratory 

facilities and in the major impacts to global conditions by research done at NREL. Laboratory 

operations follow the NREL Environmental Management System (EMS), which is described in 

detail below and in the following chapter. NREL has earned its designation as an environmental 

leader by implementing an EMS and promoting sound environmental and sustainability 

strategies and practices.

NREL’s mission is stated succinctly:

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. 

Among the environmental imperatives addressed by NREL, carbon mitigation and land and 

water use are critical to the 21st century. A major change in the nation’s energy policy has 

spurred new research efforts at NREL to help address these issues. Renewable energy 

technologies will be critical to help reduce carbon emissions that contribute to climate change 

and help the world move toward energy independence. 

3.1 Energy Policy Changes in 2008

In 2008, there was a major shift in the 

energy policy of the United States with the 

passage of new legislation designed to 

address what former President George H. 

W. Bush characterized as the nation’s 

addiction to foreign oil. In December 2007, 

the Energy Independence and Security Act 

(EISA) was signed into law, mandating 

significant changes in the energy policy of 

the United States over the coming decades.

The new legislation has numerous 

provisions impacting vehicle fuel efficiency, 

including transportation electrification; 

funding for increased biofuel research and 

production; expanded research on solar, 

geothermal, marine and hydrokinetic 

renewable technologies; support for research 

into carbon sequestration technologies; and provisions that will result in a modernization of the 

electrical transmission system known as Smart Grid. NREL has a critical role in helping the 

nation meet the legislative goals set in the EISA.

The Energy Information Agency (EIA), an independent arm of DOE, produces a summary 

document of energy use and projections called the Annual Energy Outlook (AEO). The 2008 
NREL Environmental Performance Report, 2008 Page 23

Figure 12. Primary energy 

use by source, 2007

Figure 13. Sources of energy and the expenditures of energy in the 

United States, summary (quadrillion BTUs)

AEO had been prepared with an early-release scenario in 2007, 

but was revised to account for the changes that the EISA 2007 

would have on primary energy consumption and the emission 

of greenhouse gases (GHG) associated with the use of fossil 

fuels. The EIA projected a reduction of 5.3 quadrillion BTUs in 

total energy consumption from 2008 to 2030 as a result of 

EISA, and a 7% annual reduction in GHG emissions.

By some estimates, the reduction of GHG emissions must be 

reduced by far greater amounts in the coming years (see the 

discussion below). Renewable energy is part of the solution to 

the nation’s growing appetite for energy. The EIA has 

summarized the sources of energy and the expenditures of 

energy in the United States (see Figure 13). Renewable energy 

is currently only a small contributor to the overall supply. 

Increased research activities at NREL in response to changes in the national policy are only one 

example of the interface of policy and renewable energy. In 2008, NREL studied the impacts of 

state policies on the development of renewable energy. Research into the effectiveness of 

policies that promote energy efficiencies and the use of renewable sources is in transition to a 

quantitative model. This work compiled and evaluated the status of “best-practice” state policy 

design and connected the existence of some policies with increased renewable energy 

development through correlation analysis. A strategy was developed to better understand the role 

of policy in renewable energy development, based on market-transformation principles.
NREL Environmental Performance Report, 2008 Page 24

Figure 14. Seizing the moment to make 

transformational change

Figure 15. Global and nationwide renewable 

resources are plentiful

3.2 NREL Research Helping Meet Legislative Goals

Since its origination as the Solar Energy 

Research Institute (SERI), NREL has been 

involved in the fundamental development of 

solar energy technologies. As a research 

institution, NREL ranks second among all 

U.S. laboratories in the number of energyrelated publications and has the unique 

distinction of having published the number 

one cited article in the energy field

(Contreras et al. 1999). 

3.2.1 General Capabilities

Through projects at the National Wind 

Technology Center (NWTC), the Alternative 

Fuels Users Facility (AFUF), and a number 

of related facilities and organizations, NREL has increased the portfolio of research activities to 

include wind, biofuels, and energy efficiency technologies for residential, commercial, and 

industrial applications. Recently, NREL has increased the level of activity in energy delivery and 

storage, including energy transmission and distribution, alternative fuels, and hydrogen delivery 

and storage. For example, NREL has developed a wind-to-hydrogen project at the NWTC to 

demonstrate the technologies of converting wind and solar energy into hydrogen through the 

electrolysis of water. In addition, the Hydrogen Test Facility began operations in 2007 where 

research is aimed at reducing the delivered costs of electrolytic hydrogen. Cost effective energy 

conversion and storage will greatly enhance the viability of renewable energy technologies, 

particularly those where energy production is intermittent, such as wind and solar. 

3.2.2 Biofuels

The EISA established rigorous goals, known as 

the Renewable Fuels Standard, for developing 

biofuel substitutes for petroleum-based fuels 

used for transportation (except ocean-going 

vessels). The Standard has now been expanded 

to require the annual production of 36 billion 

gallons of renewable fuel in motor fuels by 

2022. Of that, 21 billion gallons must be from 

advanced biofuels, which is defined as biofuel 

produced from feedstocks other than corn 

starch. The EISA mandates that advanced 

biofuels include cellulosic fuels and biomassderived diesel substitutes, and, further, that these 

fuels have at least 50% less GHG emissions 

than petroleum fuels. NREL is well positioned 

to contribute to the development of biofuels 

technologies that will facilitate meeting these ambitious goals.
NREL Environmental Performance Report, 2008 Page 25

Figure 16. Building on existing renewable 

energy technologies

From 1978 to 1996, NREL administered the Aquatic Species Program which was charged with 

developing renewable fuels from algae. NREL made significant progress in the science of 

manipulating algal metabolism and engineering microalgae production systems. Researchers 

screened and characterized more than 3,000 potential strains of algae, and identified about 300 

species of green algae and diatoms that had the demonstrated ability to produce oil and were 

adaptable to extreme conditions of temperature, salinity, and pH.

Record high petroleum prices in 2008 have sparked renewed interest in producing fuels from 

algal sources. Research and development efforts at NREL have been renewed with a 

combination of funding from several sources, including a cooperative research and development 

agreement with a major oil company to collaboratively develop techniques to research the 

production of liquid transportation fuels using microalgae. Within the laboratory, two laboratory 

directed research and development (LDRD) algae projects were approved in 2008. 

One of the LDRD projects makes use of the Illumina Genome Analyzer, a novel genesequencing technology for high-throughput transcriptomics analysis of microbial strains used for 

biofuel production. Transcriptomics is the study of gene expression patterns that vary with 

external environmental conditions. By examining the changes in messenger ribonucleic acid

populations within cells grown under conditions of enhanced lipid production, scientists can 

determine the biological triggers for lipid production in microalgae. This technology represents 

the latest generation in rapid DNA-sequencing methodology and allows for the generation of de 

novo genome sequences and whole transcriptome analyses to aid researchers in identifying genes 

and pathways involved in algal biofuel production. 

The second algae LDRD project funded in 2008 aims to engineer cyanobacteria (a form of 

prokaryotic algae) to divert biosynthetic pathways away from glycogen synthesis and toward 

lipid synthesis. Cyanobacteria are not considered good candidates for high-density biofuel 

production because they typically produce carbohydrates as storage products rather than lipids. 

This project takes advantage of advanced methods for genetic manipulation available for 

cyanobacteria.

3.3 NREL – Research to Address Climate Change

The energy policy shift embodied by the EISA 

establishes rigorous goals to bring the nation to 

energy independence, but it also acknowledges 

the growing concern over climate change. The 

goals for reducing GHG emissions just begin to 

address the problem, however. In a 2007 report 

produced by the American Solar Energy Society 

entitled “Tackling Climate Change in the U.S.”, 

research indicates that GHG emissions in the 

United States must be reduced by the equivalent 

of 1,100-1,300 million metrics tons of carbon 

per year (MtC/Yr) by 2030 to limit atmospheric 

carbon dioxide levels to between 450 and 500 

ppm. The report goes on to say that this level of 
NREL Environmental Performance Report, 2008 Page 26

Figure 17. Nationwide installed wind capacity

CO2 reduction can be achieved with a combination of energy efficiency improvements in the 

building, vehicles, and industrial sectors (57%), and renewable energy installations (43%). 

Of the 43% reduction (516 MtC/yr) projected to be achieved through the deployment of 

renewable energy technologies, a majority of the GHG reduction would come from wind energy 

(181 MtC/Yr). The additional reductions would be from concentrating solar power (CSP) (63), 

PV (63), biofuels (58), biomass (75) and geothermal (83). A recent survey of the growth of the 

first generation of these technologies from 2002 through 2007 shows that the installed capacity 

for wind generation has had the greatest increase. 

NREL is active in research in most of these areas, but particularly in wind, PV, and CSP. 

3.3.1 Wind

NREL has developed sophisticated methods 

of evaluating renewable energy resources.

Analysts track the development of wind 

generating sources on a state-by-state basis; 

Figure 17 shows the current installed 

capacity. In 2008, NREL led an analytic 

effort that resulted in the DOE report 20% 

Wind Energy by 2030; Increasing Wind 

Energy’s Contribution to the U.S. Electricity 

Supply. NREL’s analysis led to a new 

strategic framework for the wind energy 

program to help meet the challenges of 

producing 300 gigawatts of wind energy 

capacity by 2030.

3.3.2 Concentrating Solar Power

Concentrating solar power (CSP) technologies can be a major contributor to our nation's future 

need for new, clean sources of energy, particularly in the Western United States.

A reliable and affordable supply of electricity is essential to protect public health and safety, and 

to sustain a vigorous economy in the West. Constraints in natural gas supplies, low hydropower 

generation due to drought, and increasing demand for electricity have led to enormous volatility 

in the West's power market. And as the population in the western states continues to grow, 

energy demand will continue to increase. With the addition of thermal storage, CSP technologies 

can provide power during periods when demand on the utilities is at its peak, even if the sun isn't 

shining. This ability to provide dispatchable power during periods of peak demand establishes 

CSP technologies as a viable energy choice for the West.

Working in partnership with public and private organizations, NREL supports research and 

development that advances concentrating solar power technologies, with the goal of making 

them competitive in U.S. and global power markets. 
NREL Environmental Performance Report, 2008 Page 27

Figure 18. NREL's IMM solar cell

3.3.3 Photovoltaics

The development of technology that 

captures solar energy is at the core of 

research conducted at NREL. The laboratory 

has won numerous awards for its innovative 

work in producing ever more efficient 

photovoltaic (PV) configurations, including 

two prestigious R&D 100 Awards in 2008. 

One of NREL's R&D 100 awards 

recognized the IMM Solar Cell, a 

breakthrough in solar cell design and 

performance. The ultra-light, highly 

efficient solar cell represents a new class of 

solar cells with clear advantages in performance, 

engineering design, operation and cost. In this new method of development, the cell is grown 

upside down, allowing for greater absorption and use of sunlight. By turning the conventional 

approach to cells literally on its head, the result is an ultra-light and flexible cell that converts 

solar energy with record efficiency. Having already set a pair of world records for solar 

conversion efficiency when it was nominated, the cell has just set a third world record with a 

solar conversion rate exceeding 40%. 

The second R&D 100 award spotlights a new technology for manufacturing Hybrid CIGS—thin 

film PV employing layers of copper indium gallium diselenide. NREL, in partnership with 

HelioVolt, developed a method where hybrid CIGS cells are manufactured in layers by using 

ink-jet and ultrasonic technology to precisely apply metal-organic inks in separate layers directly 

into common building materials like metal and glass. This simple approach could integrate 

enough flexible PV film into windows, roofing and other structural components to turn entire 

buildings into small, self-sustaining power plants.
NREL Environmental Performance Report, 2008 Page 28

NREL Environmental Policy Statement

NREL exemplifies sustainability by maximizing efficient use of resources, minimizing waste and pollution, 

and serving as a positive force in economic, environmental, and community responsibility. To this end, NREL 

is committed to:

Economic Viability. Managing laboratory fiscal resources efficiently to meet applicable regulations and 

effectively accomplishing the laboratory's mission, taking sustainability into consideration.

Environmental Stewardship. NREL is committed to sound environmental management that serves as an 

example to others and supports the laboratory’s mission to protect natural resources through research, 

development, and deployment of renewable energy and energy efficiency technologies. . . . To this end, 

NREL is committed to: 

• Pollution Prevention. . . . Incorporating pollution prevention practices in research and support activities.

• Continuous Improvement. . . . Continuously improving the effectiveness of NREL’s environmental 

management system (EMS).

• Campus. . . . Managing the impact on the environment caused by the placement and general design of NREL 

structures; maintaining, protecting, and restoring natural and landscaped environments to sustain natural and 

native ecological systems, both on and adjacent to NREL campuses.

• Water. . . . Reducing water consumption and managing water discharges from the site.

• Electricity/Natural Gas. . . . Reducing energy use in building designs and operations, within available funds; 

using cost effective renewable energy sources for remaining energy needs; and purchasing power generated 

by renewable energy sources.

• Transportation. . . . Reducing the impact of local NREL travel on the environment; reducing the use of 

fossil-based gasoline/diesel fuel for NREL onsite and local operations through the use of alternative fuel 

vehicles or hybrids; and increasing the use of video and teleconferencing to reduce the environmental impacts 

of air travel.

• Materials. . . . Reducing the use of materials and the creation of waste by reducing, reusing, and recycling 

materials needed for laboratory operations; increasing the purchase and use of environmentally sensitive 

products and products with recycled content.

• Environmental Management. . . . Providing an environment that promotes efficiency, effectiveness, and 

sustainability, and encourages the creativity and personal motivation required for excellence in scientific, 

engineering, technology development, and support functions.

• Education/Communication. . . . Informing and providing outreach to workers about sustainability activities, 

including a method for interaction and feedback; educating workers about participating and contributing to 

sustainable activities. . . ; informing workers and the public about NREL’s environmental performance, 

including a method for interaction and feedback.

• Compliance with Requirements. . . . Complying with applicable federal, state, and other environmental 

requirements and exceeding those requirements, when feasible, by implementing environmental best 

management practices.

Public Responsibility. Working with local stakeholders to identify and implement collaborative projects to 

improve sustainability of the local community; educating others about sustainability through a variety of 

outreach mechanisms.

4 Environmental Management System 

NREL's Environmental Management System (EMS) provides effective environmental 

stewardship of its federally-owned sites and minimizes the environmental impacts of the lab 

activities. The laboratory's EMS efforts protect and enhance the vegetation, wildlife, and natural 

resources of the lab sites; comply with environmental requirements; and encourage continuous 

improvement in environmental protection. 

4.1 Policy

Environmental protection is a priority at NREL, as indicated by the laboratory’s Environmental 

Protection Policy: 
NREL Environmental Performance Report, 2008 Page 29

4.1.1 NREL’s EMS and Integrated Safety Management (ISM) System

NREL’s EMS implements the laboratory’s Environmental Protection Policy. It is a framework of 

policies, procedures, and programs integrated with normal management processes, and combined 

with the environmentally sound daily work practices of the Environment, Health, and Safety

(EHS) Office staff and personnel. Environmental protection must involve everyone at the lab to 

be effective. All activities conducted at NREL must comply with federal and state environmental 

laws and regulations, and DOE requirements.

As a DOE-owned facility, NREL is required by DOE Order 450.1A to implement its EMS as 

part of an ISM System. NREL’s EMS meets this requirement while also incorporating the 

elements of ISO 14001, the international environmental management standard. In addition, the 

criteria of EO 13423, Strengthening Federal Environmental, Energy, and Transportation 

Management, are incorporated into the EMS.

Policy 6-2: Environmental Protection, and supporting laboratory-level environmental programs 

and procedures that define the NREL EMS are coordinated and linked with Policy 2-1: 

Integrated Safety Management, Policy 2-7: Sustainable NREL, and the related supporting lablevel safety, health, and sustainability programs and procedures. An example of an integrated 

task specific procedure flowing down from the related policies and procedures is Procedure 6-

6.2: Hazard Identification and Control. 

4.1.2 Notable 2008 Activities 

4.1.2.1 Federal Electronics Challenge 

In 2008, NREL was accepted into the Federal Electronics Challenge (FEC), a partnership 

program between the Office of the Federal Environmental Executive and the EPA. The FEC 

recognizes federal facilities that voluntarily:

• Purchase greener electronic products 

• Reduce impacts of electronic products during use 

• Manage obsolete electronics in an environmentally safe way. 

The NREL FEC team, which met monthly throughout 2008, received a Silver-level Award by 

completing 23 projects, including:

• Ensuring computer monitors are ENERGY STAR®-rated and incorporate a "sleep" mode

• Hosting an employee personal computer and electronics recycling program 

• Using an environmentally friendly, third-party electronics recycler.

In 2009, NREL applied for and achieved the Gold-level FEC Award.

To learn more about the award, please see the NREL FEC poster summary (PDF 4 MB). 

Download Adobe Reader. Learn more about this voluntary program at the FEC Web site at 

http://www.federalelectronicschallenge.net/. 

4.1.2.2 Notable Practice among DOE Laboratories 

An external review of work practices for nanoscale material activities at DOE laboratories was 

completed in 2008 by the DOE Office of Health, Safety, and Security (HSS), Office of 
NREL Environmental Performance Report, 2008 Page 30

Independent Oversight. A final report identified several notable nanomaterials practices at the 

laboratory. The review team noted that the engineering and administrative controls employed at 

the laboratory are very effective in controlling exposures. 

Specific to the EMS, the report identified a notable practice, warranting consideration by other 

DOE sites: 

As part of the Environmental Management System Aspect/Impact Analysis in May 2008, 

research activities involving nanoscale materials were reviewed and incorporated.

This is a significant notable practice finding because EMS consideration of nanoscale materials 

is not currently a routine practice in the EMS of other facilities. NREL included nanomaterials 

research in the environmental aspect/impact spreadsheet analysis, which is among the systematic 

EMS tools.

4.1.2.3 Lead Auditor Training – ISO 14001:2004 

NREL EHS and Quality Assurance staff participated in a one-week training toward ISO 

14001:2004 Lead Auditor certification in August 2008. NREL staff received verification of the 

successful completion of the training requirements for certification as EMS Auditors/Lead 

Auditors by the RABQSA International, Inc. Management System Auditor Certification 

Program. The certificate is recognized by the International Register of Certificated Auditors 

(IRCA) as meeting the requirement for IRCA certification as EMS Auditors/Lead Auditors.

4.1.2.4 Colorado Environmental Leadership Program

NREL continued progress toward environmental performance commitments made as a Goldlevel Leader in Colorado’s Environmental Leadership Program (ELP). The Colorado ELP is the 

voluntary partnership between Colorado Department of Public Health and Environment 

(CDPHE) and participating private and public Colorado facilities, recognizing environmental 

leadership and performance. 

In early 2004, NREL was the first laboratory accepted into the Colorado ELP as a Gold-level 

leader and has maintained this leadership level to date. NREL sets voluntary three-year 

environmental performance goals as a component of ELP membership, in an effort to further 

enhance operations and performance at the laboratory. 

The CDPHE ELP recognizes facilities that voluntarily:

• Exceed regulatory requirements

• Implement EMSs (which focus on incorporating environmental considerations into 

normal management processes and improving internal environmental management 

effectiveness)

• Work closely with their communities 

• Set three-year goals focusing on measurable results. 

Learn more about this voluntary program at the CDPHE Web site at 

http://www.cdphe.state.co.us/el/elp/index.html. 
NREL Environmental Performance Report, 2008 Page 31

Figure 19. Science on a 

Sphere exhibit

Credit: Pat Corkery

4.1.3 Public Outreach 

NREL hosted several public meetings where discussion of environmental performance and other 

issues occurred. Example public meetings are described below. Approximately 14,000 people 

passed through NREL's Visitors Center in 2008. All are asked to sign in, and space is provided 

on the sign-in sheet for comments. Concerns about the lab’s environmental performance are 

relayed to appropriate staff. 

NREL and DOE-GO hosted a community meeting on November 12, 2008, inviting community 

members to learn about the laboratory’s 2009 research outlook and site development plans. More 

than 85 community members attended. Presentations made by the NREL Deputy Director, 

Director of NREL’s Infrastructure and Campus Development Office, and DOE-GO's 

Supervisory Engineer and Project Officer are available online at: 

http://www.nrel.gov/visitors_center/community_news.html. 

In July, 2008, NREL installed a new “Science on a Sphere”

exhibit. This unique visualization system is one of only about 

20 spheres operating around the world. The sphere consists of 

a 6-foot diameter globe-shaped screen, four digital projectors, 

and five computers. While the sphere is preloaded with more 

than 200 Earth science maps and charts, NREL generates 

unique energy-related programs, maps, and charts for the 

display. NREL is currently the only source for energy-related 

sphere programming, and shares this information at no cost 

with museums and visitors centers worldwide. 

A new public seminar series began in 2008 entitled, 

“Consumer Power for the 21st Century.” More than 160 people 

participated in these quarterly seminars occurring on 

Saturdays, capturing audiences who were unable to visit 

during standard Monday through Friday operating hours. 

Topics for the seminars included: Solar Power; Strategies, 

Devices, and Appliances for Using Energy Wisely; and 

Investment Opportunities. 

In addition, the public was invited to six “Smart Energy Living” workshops in 2008 at the NREL 

Visitors Center before and after the Denver Tour of Solar and Green Built Homes. More than 

155 attendees received information on renewable energy and energy efficient technologies for 

their homes. 

A series of "Power Lunches" open to the public are held monthly at the Visitors Center. In 2008, 

more than 630 attendees heard topics ranging from Zero Energy Housing to Xeriscaping Your 

Garden, Making Vehicle Power Electronics COOL, Net Metering, and Biofuels Sustainability. 

Visits to NREL by elected officials are common. In Fiscal Year (FY) 2008, NREL’s Visitors 

Program hosted 300 site visits for more than 3,000 VIP visitors, including 16 Members of 

Congress during the Democratic National Convention, U.S. Representative John Salazar (D-CO), 
NREL Environmental Performance Report, 2008 Page 32

Senator John Thune, New Zealand Minister of Research, Science & Technology, Pete Hodgson, 

Swiss Ambassador, Urs Ziswiler, U.S. Ambassador to Spain, Eduardo Aguirre, and Ireland's 

Chief Scientific Advisor, Professor Patrick Cunningham. 

The lab hosts a public Web site for visitors at: http://www.nrel.gov/visitors_center/. Past editions 

of “NREL Community News” are located on this site, with contact information for public 

comment to NREL. In addition, www.nrel.gov features links where the public can access copies 

of NREL's Sustainability Reports (http://www.nrel.gov/sustainable_nrel/) and Environmental 

Reports (http://www.nrel.gov/eshq/environmental_protection.html). 

4.2 Performance Indicators and Progress

4.2.1 2008 Environmental Objectives and Progress toward Goals 

Each fiscal year, in collaboration with DOE-GO, NREL develops environmental performance 

objectives for the upcoming year as part of the lab’s One-Year Plan. The FY 2008 One-Year 

Plan established the goal to “advance ESH&Q as a core value to protect the health and safety of 

NREL workers and the community and to strengthen environmental quality.” The environmental 

objectives for meeting this goal were:

• Implementation of integrated safety, health, and environmental management into 

laboratory operations/management systems;

• Effective response to laboratory challenges; and

• Response to environment, health, and safety issues.

NREL successfully completed the One-Year Plan objectives. Some noteworthy achievements in 

FY 2008 include: 

• Implementing a tracking system for safety inspection findings 

• Streamlining the process of developing and maintaining Safe Operating Procedures 

(SOPs)

• Meeting a 10% paper consumption reduction goal in the areas of document services 

center paper usage (copy center; about 11% reduction), and in copiers paper usage 

(deployed throughout the lab; about 13%) 

• Updating P-card users training on pollution prevention and green products 

• Using an integrated team approach to meet environmental goals for electronics 

management, incorporating all phases of the life cycle of electronics, resulting in external 

recognition through the FEC 

• Developing and implementing a Hazardous Waste Program Improvement Plan, including 

introduction of required annual training and identification of all satellite accumulation 

areas with inspectors for each area

• Conducting a nanomaterial safety program assessment, enhancement, and HSS audit. 

4.2.2 State of Colorado ELP Commitments (2007 – 2010) 

The following multi-year commitments, as stated in CDPHE ELP Annual Environmental 

Awards Program, support the laboratory-wide EHS objectives for both 2008 and the upcoming 

objectives for 2009. 
NREL Environmental Performance Report, 2008 Page 33

4.2.2.1 “Campus Planning” 

• NREL actively “walks the talk,” having made a tremendous start by achieving 

Leadership in Energy and Environmental Design (LEED) Platinum designation at the 

Science and Technology Facility (S&TF) in March 2007. In 2008, NREL began 

construction of the 220,000 gross square foot (gsf) Research Support Facilities (RSF)

with the goal of achieving a LEED Platinum designation. 

• NREL continues to reduce GHG emissions as required by the federal EO 13423, 

Strengthening Federal Environmental, Energy and Transportation Management. This is 

completed through the deployment of energy efficient and renewable energy technologies 

on site at NREL, and through the purchase of renewable energy certificates. 

• NREL has been accepted in the FEC, and completed projects that qualified for Silverlevel and Gold-level Awards given jointly by the Office of the Federal Environmental 

Executive and the EPA. 

Please see NREL’s 2008 Sustainability Report for progress in campus planning areas of 

sustainable building design, and GHG emissions. For results of the FEC application submittal, 

please see Section 4.1.2. 

As an additional indicator of NREL’s environmental performance in 2008, Sustainable NREL 

and EMS staff supported NREL efforts in receiving the following awards: 

• Transformation Energy Action Management (TEAM) Renewable Energy Award; 

awarded by DOE’s Federal Energy Management Program 

• Pollution Prevention STAR Award – Leadership in Environmental and Energy Design – 

S&TF; awarded by DOE

• Laboratory of the Year Special Mention Award; awarded by R&D Magazine

• ASHRAE Technology Award – Institutional Buildings (New Construction); awarded by

ASHRAE Region X

• Colorado Renewable Energy and Sustainable Design in Buildings Award – Institutional 

Buildings; awarded by the Colorado Renewable Energy Society 

• Federal Electronics Challenge – Silver-level Award; awarded by the Office of the Federal 

Environmental Executive and the EPA

• Continued recognition as a Gold-level Environmental Leader; awarded by the CDPHE 

Environmental Leadership Program. 

4.2.3 2009 Environmental Objectives 

The environmental objectives developed by NREL in collaboration with DOE-GO are to meet 

the EHS management goal stated in the Performance Evaluation Measurement Plan. The stated 

goal is “to demonstrate that EHS is a priority; that processes and practices are in place to 

effectively identify and manage risks to protect NREL workers, the local community, and the 

environment; and that the laboratory complies with all applicable DOE requirements, regulation, 

laws, and laboratory policies and procedures.” For FY 2009, the environmental objectives are: 

• A safe and healthful workplace based on identified and managed risks 

• Further ISM through the development of improved management systems 

• Transform environmental excellence to a sustainability strategy.
NREL Environmental Performance Report, 2008 Page 34

Progress toward the 2009 objectives will be reported in the NREL 2009 Environmental 

Performance Report. 

4.3 Assessment and Improvement

Periodic assessment and management review of NREL’s EMS and its components provide 

verification 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 maintain management support for NREL’s environmental goals. Assessments 

and management reviews also provide for continuous improvement of the EMS. 

There are three different types of assessments performed to evaluate the functionality of the EMS 

at NREL: EMS assessments, periodic compliance assessments, and third-party assessments. 

A team of NREL staff generally performs periodic assessments of NREL’s EMS internally. The 

scope of the assessments includes both the management of significant environmental aspects 

(areas where NREL activities have the potential for environmental effects, either positive or 

negative) and policy implementation. The team evaluates the EMS based on an appropriate set of 

criteria, such as ISO 14000 standards, DOE Order requirements, Colorado Environmental 

Leadership Program standards, or other applicable environmental management standards. 

Periodic compliance assessments are conducted of individual environmental programs to verify 

that each program, as written, meets all applicable legislative and regulatory requirements and 

that the program is implemented as intended (see Section 5.0 for examples). Improvements are 

developed and implemented as necessary, based on the results of each assessment. 

In addition to compliance assessments of individual NREL environmental programs, NREL has 

management system review processes in place for regular reviews and updates of the set of 

policies, lab-level programs, and task-specific procedures, including EMS policies and programs. 

NREL reviews its EHS policies and laboratory-level procedures as needed, but at least every five

years, making revisions as necessary. All SOPs are reviewed on an annual basis and are revised 

as necessary to help ensure the required controls are appropriate for the hazards present. 

Environmental hazards and controls are specifically called out in each SOP. 

Periodically, external third-party assessments may be conducted by technical experts for specific 

components of NREL’s environmental programs or for the EMS as a whole. These assessments 

are conducted on an as-needed basis. A third-party, external audit of the EMS is planned for 

2009 and every three years thereafter, as required by DOE Order 450.1A.

4.3.1 2008 Assessment Activities

In August 2008, NREL’s Quality Assurance team performed an assessment of the EMS to

measure the overall effectiveness and level of deployment and maturity of NREL’s EMS. 

The assessment was based on the ISO 14001:2004 standard, the NREL EMS description, and 

any related process documents such as lab-level and desk procedures. The assessment consisted 

of documentation review and interviews with EMS staff and other workers involved with or 

affected by the EMS. Several recommendations for improvement were identified and 
NREL Environmental Performance Report, 2008 Page 35

incorporated into corrective action plans. Corrective action plan elements are entered into the 

quality assurance organization’s action tracking database.

Annual EMS assessments, conducted by the NREL Quality Management and Systems Assurance 

assessment team, will continue to monitor performance of the system.

4.4 Sustainability and the Environmental Management System

NREL’s mission has always focused on a sustainable energy future for our nation and the world. 

Sustainability is defined as meeting the needs of the present without compromising the ability of 

future generations to meet their needs, and involves the simultaneous and balanced pursuit of 

economic viability, environmental stewardship, and public responsibility. 

The Sustainable NREL program was created to realize the vision of greater sustainability in 

NREL operations. It is an interdisciplinary initiative involving staff from numerous NREL 

centers and offices with the goals of maximizing efficient use of resources; minimizing waste 

and pollution; and serving as a positive force in economic, environmental, and public 

responsibility. Elements of the environmental stewardship component of Sustainable NREL 

include: 

• Renewable energy solutions 

• Sustainable green buildings, campus planning, and transportation 

• Water, electricity, and natural gas use reduction 

• GHG emission reductions 

• Reduce, reuse, and recycle materials use 

• Public responsibility/community outreach 

• Environmental management. 

Sustainable NREL carries out the laboratory’s commitments to, among other things, reducing 

energy use in its building operations, designing energy efficient and environmentally sensitive 

new buildings, reducing water consumption, decreasing GHG emissions, minimizing the impact 

of NREL local and air travel on the environment, using less fossil-based fuel for local operations, 

incorporating renewable energy technologies into its on-site STM and NWTC operations, and 

creating less waste by reducing, reusing, and recycling materials for laboratory operations. 

In addition, the EMS supports Sustainable NREL’s goals by focusing on protecting the natural 

and cultural resources on and around NREL sites by: 

• Minimizing NREL’s potential for environmental impacts through emissions, discharges, 

waste generation, purchases, and land use 

• Conducting required permitting activities 

• Managing site natural resources for protection and preservation of their natural character 

to the extent possible, while still fulfilling NREL’s mission

• Managing site cultural resources for documenting resources of significance and 

minimizing disturbances whenever possible 

• Recommending and coordinating measures to minimize any potential impacts NREL’s 

activities have on the environment. 
NREL Environmental Performance Report, 2008 Page 36

5 Environmental Programs

The overarching objective of NREL’s EMS and its component programs is responsible 

stewardship of the environment on its DOE-owned sites, leased properties, and to the extent 

practicable, on subcontractor and partner sites. NREL strives to protect the natural environment 

by minimizing or eliminating any adverse environmental impacts resulting from NREL 

activities. The laboratory’s EMS is integrated with other NREL management systems and applies 

to all research and operations activities. The EMS includes written environmental protection 

policy and program implementation documents. These are put into practice at all staff and 

management levels. 

NREL’s EMS includes components to address waste, air, water, site, natural and cultural 

resources, and land and soil issues, among others. Descriptions of the components of the EMS 

are provided in the following sections of this chapter; sections are organized by resource. Each 

section is composed of three areas of discussion: a summary of the environmental management 

of the resource, a discussion of any relevant permitting, and a summary of significant activities 

that have occurred throughout Calendar Year (CY) 2008. 

A summary of NREL’s permits, registrations, and notifications are presented in Appendix A. 

These permits are discussed in the following sections as applicable. 

5.1 Air Quality Protection

5.1.1 Program Management 

Management in this area is consistent with the following NREL programs: Environmental Permitting 

and Notification (6-2.1), Air Quality Protection (6-2.5), Ozone-Depleting Substances Management 

(6-2.6), and Particulate Emissions Control for Construction (6-2.14). 

5.1.1.1 Criteria, Non-criteria, and Hazardous Pollutants 

The Clean Air Act and Colorado laws and regulations delineate several main categories for air 

pollutants: 

• Criteria air pollutants (e.g., carbon monoxide, nitrogen oxides, sulfur dioxide, particulate 

matter, ozone, and lead) 

• Non-criteria pollutants (e.g., ammonia, hydrogen sulfide, pesticides, organic compounds, 

metallic compounds, and corrosives) 

• Hazardous air pollutants (e.g., organic compounds, metals, corrosives, asbestos, 

radionuclides, and pesticides) 

• Ozone-depleting substances (e.g., chlorofluorocarbons or “freons”). 

There are notification and permitting thresholds for criteria, non-criteria, and hazardous pollutants. 

The primary potential sources of these pollutants at NREL include boilers, emergency generators, 

experimental laboratory hoods, pilot-scale research projects, and small pieces of equipment with 

gasoline or diesel engines. NREL maintains air emission inventories to track potential air emissions 

and identify whether notification and permitting could be required for a particular facility or activity. 

Fugitive particulate emissions from construction activities occurring on NREL’s sites are also a 

potential source. 
NREL Environmental Performance Report, 2008 Page 37

5.1.1.2 Ozone-depleting Substances

Facilities that service refrigeration equipment containing ozone-depleting substances (ODS) are 

required to file an annual notification with the CDPHE. NREL employs EPA-certified 

technicians that service ODS-containing equipment. Another requirement of Colorado’s 

chlorofluoro carbon program is that all refrigeration equipment larger than 100 hp that uses ODS 

be registered with CDPHE. NREL has a total of three chillers that are registered with CDPHE; 

two located at the Solar Energy Research Facility (SERF) on the STM site, and one at the 

DWOP. 

Halon-based fire suppression systems previously used at NREL were eliminated by 1999, with 

all supplies of Halon being transferred to other DOE facilities for “banking.” 

 

5.1.1.3 Street Sanding 

CDPHE regulations require federal, state, and local government facilities to track street sanding 

in the wintertime, and to make efforts to minimize sand use. NREL complies with this 

requirement and files an annual sanding report with CDPHE. From October 2007 to May 2008, 

NREL used 25 tons of sand during 22 sanding episodes. NREL maintains 12.3 lane-miles of 

roads. From October 2008 to May 2009, NREL used 79 tons of sand during 24 sanding episodes, 

while continuing to maintain 12.3 lane-miles of road. 

5.1.2 Permitting 

Most potential sources of air emissions from NREL operations in 2008 were small scale and did 

not require permitting. Permitting thresholds vary, depending on the pollutant. Projected 

emissions for these sources were below thresholds for air permitting. 

Two site-wide permits for particulate emissions from construction activities have been issued to 

NREL by CDPHE. NREL has held such permits for a number of years. New site-wide permits 

were issued in February 2005 to replace previously held permits, at which the time period of 

applicability had expired. One permit covers the STM site and the other covers the NWTC.

NREL also holds one air emissions permit for an experimental pilot process in the Field Test 

Laboratory Building (FTLB) on the STM site. The permit was issued in 2000 for the operation of 

a thermal oxidizer emission control device for the experimental Thermochemical Process 

Demonstration Unit (TCPDU). An Air Pollution Emission Notice (APEN) update was filed with 

the Colorado Air Pollution Control Division in 2005. 

5.1.3 2008 Activities

Two APENs were filed in early 2005, one for the STM and one for the NWTC, for overlot 

grading and associated construction activities to address fugitive particulate emissions. These 

APENs for the NWTC will expire in 2010. In the fall of 2008, NREL filed a new APEN for 

upcoming major construction activities anticipated in the upcoming five years at STM.

Significant activities not associated with routine maintenance or small construction projects 

identified in the APEN submission were evaluated on a case-by-case basis in 2008. It was not 

necessary to submit an updated APEN. 
NREL Environmental Performance Report, 2008 Page 38

As required by CDPHE every five years, an APEN update was filed in May 2005 to update the 

information provided in the original APEN for TCPDU activities. There have been no significant 

changes to the operating parameters or air emissions of the TCPDU in the last eight years, 

including 2008. 

In early 2007, NREL received initial approval from CDPHE’s Air Pollution Control Division for 

the construction and operation of the RFHP, a woodwaste-fired boiler to provide building 

comfort heating for the STM campus. Prior to the completion of construction, additional 

information became available regarding the configuration of the equipment and it was necessary 

to request a permit modification. CDPHE issued an initial approval for the permit modification 

in the fall of 2008. Construction of the RFHP was completed and the equipment became 

operational in late 2008. In April 2009, NREL completed the self-certification process for final 

approval and submitted the required documentation to CDPHE.

5.2 Drinking Water

5.2.1 Program Management 

Management in this area is consistent with the following NREL programs: Drinking Water (6- 

2.3) and Environmental Permitting and Notification (6-2.1). 

Drinking water is provided to NREL’s STM and DWOP sites by a public water supply, 

Consolidated Mutual Water Company. Water to the JSF and ReFUEL is also provided by a 

public water supply. NREL supplies drinking water to its NWTC by trucking in water from local 

public water supplies through a subcontracted water hauler. NREL stores the water on site in a 

buried 15,000-gallon storage tank and in an above ground 2,000-gallon tank. The water hauler 

fills the 15,000-gallon tank, and water is pumped on demand to the 2,000-gallon tank where it is 

distributed to the Industrial User Facility (IUF), Building 251, and the hydrogen test pad on the 

west end of the site. 

Disinfection boosting is performed at the NWTC using an automated chlorine disinfection 

system. 

Monitoring for bacteria (total coliforms), chlorine levels, haloacetic acids, trihalomethanes 

(disinfection byproducts), and lead and copper is performed at the NWTC according to the 

requirements of CDPHE. NREL qualifies for reduced lead and copper monitoring. Current state 

requirements for the NWTC system monitoring are as follows: 

• Bacteria – monthly 

• Chlorine levels – weekly, or more frequently as needed 

• Haloacetic acids – quarterly 

• Total Trihalomethanes – quarterly 

• Lead and copper – triennially. 

Samples are collected from three locations at the NWTC: Building 251, the IUF, and the 

hydrogen test pad. No coliforms were detected in any of the samples taken in 2008. Monthly 

results for the bacterial analyses are provided to the state. 
NREL Environmental Performance Report, 2008 Page 39

Monitoring for lead and copper was completed as scheduled during the summer of 2008. All 

samples collected were well below the maximum contaminant levels (MCL). Five sampling 

locations were tested for lead and copper. Four of the five lead results were below detection, with 

the fifth result showing 0.002 ppm, well below the MCL of 0.015 ppm. Copper values ranged 

from 0.095ppm to 0.474 ppm, with an average value of 0.200 ppm, well below the MCL of 1.3 

ppm.

Chlorine residual monitoring of the NWTC drinking water system began with the installation of 

the chlorine disinfection system in 2000. Monitoring is performed to ensure the chlorine residual 

levels are detectable, with a target concentration of at least 0.2 milligrams per liter of chlorine 

present to provide sufficient disinfection at the monitoring locations. Colorado requires that 

chlorine residual monitoring occur when collecting monthly bacterial samples. NREL monitors 

chlorine residual levels in the system on a weekly basis and also measures chlorine levels of 

drinking water that is delivered to the NWTC. Results are provided to the state on a monthly 

basis. Chlorine was present at appropriate levels in all samples collected in 2008. The running 

annual average of the maximum residual disinfectant level for CY 2008 was 0.518 ppm. 

If any treatment is performed on supplied drinking water, state regulation requires that a statelicensed operator supervise the treatment. NREL hires a subcontracted operator with a Class A 

license to supervise the disinfection and filtration operations and to perform the necessary 

sampling. 

5.2.2 Permitting/Notifications

NREL has a registered Public Water Supply Identification Number (PWSID) issued by CDPHE 

for the drinking water distribution system at the NWTC. This identification number does not 

require periodic renewal; however, periodic testing, record keeping, and reporting are required. 

All other NREL facilities (STM, DWOP, GH, JSF, and ReFUEL) receive drinking water from 

municipal sources. 

5.2.3 2008 Activities

In 2008, 195,648 gallons of potable water were delivered to the NWTC, with an average daily 

consumption rate of 536 gallons. NREL conducted all required monitoring in 2008 and all 

reported results met drinking water standards. Bacteria were absent in all samples collected, and 

disinfectant was detected at all locations tested. The annual running average for chlorine was 

0.518 ppm. 

Quarterly monitoring for disinfection byproducts (DBPs) continued throughout 2008. The 

running annual average (RAA) for total trihalomethanes in 2008 was 0.051 mg/L, below the 

maximum contaminant level of 0.080 mg/L and in compliance with the water quality 

requirement. The RAA for haloacetics acids was 0.038 mg/L, below the maximum contaminant 

level of 0.060 mg/L, also in compliance with the water quality requirement. 

CDPHE’s Water Quality Control Division conducted a formal Sanitary Survey of the NWTC 

drinking water system on September 23, 2008, and found the system to be in compliance with all 

requirements. Three recommendations for improvement were identified during the survey: 
NREL Environmental Performance Report, 2008 Page 40

Observation 1: Monitoring, Reporting, and Data Verification 

“The system should continue to evaluate source water quality from the wholesaler, the system’s 

booster chlorination system, and the amount of residence time in the storage tank and 

distribution system in order to minimize formation of disinfection by products.” 

Observation 2: System Operations and Maintenance

“It is recommended that the system develop and implement a valve exercising program for 

valves in the distribution system in order to maximize the life of such devices.” 

Observation 3: Storage Management 

“It is recommended that the water system create a tank maintenance plan to evaluate and inspect 

the condition of the buried storage tank and to ensure the tank is a safe and viable component of 

the water system. Preventative maintenance and timely inspections will help prolong the life of 

the tanks and ensure early detection of needed repairs. The water system should examine the tank 

and piping, and look for signs of compromised integrity and leaks on a yearly basis.

Additionally, the water system should routinely inspect the integrity of the access manhole and 

vents on a frequent basis to ensure the sanitary integrity of these components. In addition to the 

tank maintenance plan, the water system should have the tank drained, cleaned, and 

professionally evaluated every three to five years (as recommended by the American Water 

Works Association).” 

Actions on these recommendations will be reported in the CY 2009 Annual Site Environmental 

Report. 

5.3 Groundwater

5.3.1 Program Management

Management in this area is consistent with NREL’s Groundwater Protection Program (6-2.4). 

Both the STM and NWTC are located at the western edge of the Denver Basin aquifer system 

that supplies water to urban, rural, and agricultural users along the Front Range of the Rocky 

Mountains in northeastern Colorado. The aquifers within the Denver Basin, which include the 

Dawson, Denver, Arapahoe, and Laramie-Fox Hills aquifers, form a layered sequence of rock in 

an elongated bowl-shaped structural depression. 

The shallowest aquifer is the Dawson formation located between 60’-100’ below ground surface 

(bgs) and extends to approximately 1,000 feet bgs. This is followed by the Denver aquifer, the 

Arapahoe aquifer, and finally the deepest aquifer, the Laramie-Fox Hills aquifer which extends 

from approximately 2,270-2,970 feet bgs. Thicknesses of the aquifers decrease with depth below 

ground surface ranging from 1,100 feet in the Dawson, 400-800 feet in the Denver, 500-600 feet 

in the Arapahoe, and 200 feet in the Laramie-Fox Hills aquifer. Limited connection exists among 

these deep aquifers and with the shallow alluvial aquifers associated with the South Platte River 

valley and its tributaries.
NREL Environmental Performance Report, 2008 Page 41

The STM site overlies the shallowest portions of the Denver, Arapahoe, and Laramie-Fox Hills 

aquifers. The NWTC site overlies the shallowest portions of the Arapahoe and Laramie-Fox 

Hills aquifers. The northern extent of the Dawson aquifer is located approximately 20 miles to 

the southeast of the STM site. Consequently, wells drilled at the STM site and NWTC would not 

intersect the Dawson aquifer. 

Because of the sensitive nature of the groundwater resource, NREL carefully evaluates all 

outdoor projects to eliminate potential impacts to groundwater quality. If any materials are used 

that pose a risk to groundwater, the laboratory typically insists that safeguards be established to 

protect groundwater. Safeguards include, but are not limited to, secondary containment for 

equipment with the potential to leak oil, double-walled tanks with leak detection for diesel fuel 

storage of NREL facilities’ emergency generators, and bermed areas to contain experimental 

materials.

In 1990 groundwater characterization began with the installation of a monitoring well network at 

the STM site. Eight wells were installed at the base of the mesa slope. Four upgradient wells 

were installed to investigate background water quality prior to its crossing NREL facility 

boundaries, and four wells were placed in a generally downgradient direction to verify that 

NREL activities had not adversely affected groundwater quality. Quarterly sampling was 

performed for five calendar quarters, followed by annual sampling for three years. No evidence 

of contamination was found. Groundwater quality at NREL was similar to other portions of the 

Denver Basin. In addition, routine follow-up sampling was done in 1997. Three of the initial 

eight wells were closed (in accordance with state requirements) due to construction activities in 

1993, and a fourth was found to be inaccessible during the 1997 sampling, also due to 

construction activity in the area. Therefore, follow-up samples were only collected from four of 

the original monitoring wells: three upgradient wells and one downgradient of NREL 

development. No evidence of contamination was found in the 1997 sampling. 

In June 1998, a diesel leak to the environment from a failed check valve on the Process 

Demonstration Unit (PDU) emergency generator aboveground storage tank at the AFUF 

occurred. The majority of contaminated soil was excavated and removed from the site for 

disposal at a permitted landfill. Three groundwater monitoring wells were installed at the site in 

September 1998, one upgradient and two downgradient. No hydrocarbon contamination was 

detected in the groundwater during the initial sampling of the three wells, or during follow-up 

sampling conducted in March and September 1999, and March 2000. These three monitoring 

wells were closed in 2006 in accordance with state requirements.

The NWTC currently has no open or active groundwater wells. A water supply well once 

provided water to Building 251 when DOE’s Rocky Flats Field Office operated the site. In 1993, 

NREL collected samples from the well and the associated water distribution and treatment 

system as part of an evaluation of alternatives for water supply to the site. Based on the sampling 

results, it was determined that the maintenance and repairs required to make the existing well and 

treatment system effective were extensive, and there was an indication of the potential for trace 

organic compounds in the water. Therefore, when DOE-GO assumed landlord responsibility for 

the site in 1993, the connection between the building and the well was severed. The water supply 

well was plugged and abandoned in accordance with state regulations in 1996. Potable water is 
NREL Environmental Performance Report, 2008 Page 42

currently transported to the site, as described in Section 5.2 of this report. NREL has done no 

other groundwater sampling at the site. 

NREL has not conducted groundwater monitoring at its leased DWOP site, as there have been no 

activities that pose an unusual risk to groundwater quality. If NREL had reason to suspect a 

groundwater quality problem, the issue would be addressed with DWOP management. DWOP 

management contracted with an engineering firm to conduct a groundwater monitoring study in 

1988 adjacent to the NREL-leased buildings. Two monitoring wells were drilled. There were no 

detections of significant levels of contaminants.

There have been no groundwater studies performed by NREL at either the JSF or the ReFUEL

Facility, as there have been no activities at these site that pose an unusual risk to ground water. 

There is currently no ongoing routine groundwater monitoring program on any NREL site. 

Groundwater sampling will be conducted if future activities pose a risk to the groundwater 

quality. 

5.3.2 Permitting

All groundwater monitoring wells installed by NREL at the STM sites have been permitted with 

the Colorado Department of Natural Resources. 

5.3.3 2008 Activities

In 2008, there were no new groundwater-related activities.

5.4 Wastewater Discharge

5.4.1 Program Management 

Management in this area is consistent with NREL’s Waste Management and Minimization 

Program (6-2.8). 

The majority of wastewater from NREL’s STM and DWOP facilities flows into the Pleasant 

View Water and Sanitation District’s system, and ultimately to Metropolitan Wastewater 

Reclamation District’s (Metro) treatment plant. There is a small septic system consisting of a 

tank and absorption field on the mesa top, serving the Solar Radiation Research Laboratory 

(SRRL), because there is no sewer line to the mesa top. Wastewater from the JSF and the 

ReFUEL Facility also flows to Metro’s treatment plant. The NWTC is not connected to a sewer 

system, but has two septic systems that include tanks and absorption fields for the treatment of 

wastewater. 

It is NREL policy that hazardous chemicals are not to be discharged to the sewer system, and 

NREL staff is trained in this policy. In addition, NREL sites have design criteria for waste drains 

in lab 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 any 

floor drains that are installed in lab areas. New research and operations activities, as well as 

ongoing activities that undergo significant modifications, are reviewed for their potential effect 

on wastewater character through NREL’s risk assessment process. 
NREL Environmental Performance Report, 2008 Page 43

5.4.2 Permitting 

No permitting for the majority of NREL’s wastewater discharges is required. NREL has no 

direct wastewater discharges to the environment at the DWOP, ReFUEL, GH, or JSF, so no 

National Pollutant Discharge Elimination System (NPDES) permitting is necessary. NREL 

maintains three individual sewage disposal systems, two at the NWTC and one at the STM site. 

The remainder of NREL facility wastewater is discharged to Metro through the sanitary sewer 

system. NREL facilities are currently classified by Metro as non-industrial water users at these 

sites. As non-industrial users, NREL sites do not need a permit from Metro for sewer discharge, 

and monitoring for pollutants in wastewater is not required. 

NREL maintains septic permits from Jefferson County (an authority delegated to the counties 

under a state of Colorado program) for the NWTC’s IUF and Building 251 septic systems, as 

well as for the SRRL facility on the STM site mesa top. 

5.4.3 2008 Activities 

In 2008, there were no new wastewater discharge activities.

5.5 Surface Water Protection (Stormwater and Erosion Control)

5.5.1 Program Management

Management in this area is consistent with the following NREL programs: Stormwater Pollution 

Prevention for Construction Activities at the STM (6-2.15), Stormwater Pollution Prevention for 

Construction Activities at the NWTC (6-2.16) and the Environmental Permitting and 

Notification (6-2.1). 

5.5.1.1 Past Investigations

Stormwater monitoring was conducted at the STM site during the summers of 1992 and 1993 to 

characterize stormwater quality at NREL, confirm that NREL’s activities were not adversely 

impacting stormwater quality leaving the STM site, and provide a baseline against which future 

sampling could be compared. 

Samples were collected at three locations: the western portion of the east drainage, the middle 

drainage, and the middle-west drainage located between the west and middle drainages. Water 

quality data indicate that NREL’s activities did not result in contamination of stormwater runoff.

For that reason, instream water quality samples of Lena Gulch, the receiving water to which 

stormwater from the STM site ultimately flows, were not collected.

Lena Gulch is a tributary to Clear Creek, a major waterway in the west Denver region. The 

Urban Drainage and Flood Control District has mapped the 100-year floodplains of this region 

and determined that none of the NREL facilities encroach on a floodplain. 

In 1998, surface water samples were taken in two drainages at the NWTC in connection with 

NREL’s weed control efforts. No traces of the herbicide applied to weed-infested areas were 

detected in the water samples collected. Stormwater and surface water quality monitoring has 

been conducted at NREL’s DWOP, JSF, and ReFUEL sites.
NREL Environmental Performance Report, 2008 Page 44

5.5.1.2 Current Management Practices

Outdoor research projects and building construction are reviewed during the planning stages 

through NREL’s NEPA, risk assessment, and design review processes for potential impacts to 

stormwater and receiving waters. Measures to prevent impacts to stormwater are incorporated, as 

appropriate, into the design for each project. Potential control measures include secondary 

containment and bermed areas for chemicals use and storage, covers or roofs to protect chemical 

use, and storage areas from precipitation and minimizing impervious areas to promote infiltration 

and decrease site runoff.

During construction, erosion and sediment controls are implemented according to the plans 

developed by contractors and reviewed by the laboratory’s EHS staff per NREL’s stormwater 

procedures. Regular inspections by contractors and periodic site inspections by NREL staff are 

conducted to verify that the controls are functioning properly and to identify any required 

repairs. Written reports are prepared for all inspections; prompt corrective actions are required to 

rectify any noncompliant conditions. 

5.5.2 Permitting

Stormwater quality on federal facilities in Colorado is regulated by the EPA Region 8. To obtain 

coverage under the EPA’s NPDES General Construction Stormwater permit, NREL must submit 

an NOI form. Both the site owner (DOE) and the site operator (Alliance for Sustainable Energy, 

LLC or previously, Midwest Research Institute) have filed NOIs with the EPA. 

In 2008, NREL filed a NOI for construction activities at the STM site for the RSF and associated 

stormwater detention basin and access road. In August of 2008, permit coverage for construction 

of a small Quonset-type metal building constructed at the NWTC for wind turbine blade 

preparation activities was terminated. No new NOIs were obtained for the NWTC in 2008 

because no construction activities involved more than 1 acre. Stormwater permits are not 

required for NREL’s routine operation. 

5.5.3 2008 Activities

In addition to implementing Stormwater Pollution Prevention Plans associated with permitted 

construction projects described above, NREL also applied numerous stormwater protection and 

erosion control practices and controls on small project sites for which General Construction 

Stormwater permits were not required. These were primarily located at the NWTC where the 

following activities occurred over the course of the year: placement of new data sheds and pads 

at Sites 3.3, 4.0, and 4.4; placement of a new trailer near Building 251; construction of 

foundations for wind turbines at Sites 1.2E, 3.3A, 3.3B, and 3.3C; construction of foundations 

for meteorological towers at Site 3.3; and construction of a hydrogen vehicle fueling island at the 

Distributed Energy Resources Test Facility. 

5.6 Waste Management

5.6.1 Program Management 

Management in this area is consistent with the following NREL Programs: Waste Management 

and Minimization (6-2.8) and Environmental Permitting and Notification (6-2.1). 
NREL Environmental Performance Report, 2008 Page 45

Hazardous wastes are handled and disposed of according to the Resource Conservation and 

Recovery Act (RCRA) and the Colorado Hazardous Waste Act. NREL’s waste primarily 

consists of a broad range of hazardous laboratory chemicals in small quantities. Wastes in solid 

or liquid form are collected in each laboratory or at each experiment site and prepared for off-site 

disposal by NREL EHS personnel. 

Hazardous waste is transported to EPA-permitted facilities for treatment and disposal. In 

addition, NREL has a conservative waste management policy where materials that are not 

regulated by RCRA, yet pose a potential hazard, are collected and disposed of as non-hazardous 

materials at RCRA-permitted disposal facilities. This category includes nanomaterial-bearing 

wastes, which were added to the waste procedure in 2008 (see Section 5.6.3).

NREL facilities also generate small quantities of low-level radioactive wastes. This waste 

normally consists of personal protective equipment, disposable labware, scintillation fluids, and 

water-based liquids. Radioactive waste is shipped off-site for disposal on an as-needed basis. 

5.6.2 Permitting 

NREL has five separate sites that have the potential to produce quantities of hazardous waste in 

various amounts. Each of the five sites has an RCRA waste generator identification number 

issued by Colorado. The STM location is classified as a "small quantity generator," generating 

less than 1,000 kg of waste per month. The other four sites—the JSF, the NWTC, the DWOP,

and the ReFUEL Facility—are classified as "conditionally exempt small quantity generators," 

generating less than 100 kg of waste per month. 

5.6.3 2008 Activities 

In CY 2008, NREL shipped 23,177 pounds (10,535 kg) of hazardous waste, 5,148 pounds (2,340 

kg) of non-RCRA regulated waste, and 5,407 pounds (2,548 kg) of universal waste for disposal 

and recycling from all five sites combined. Universal waste includes batteries, fluorescent light 

bulbs, and electronic equipment. In CY 2008, there was a 15% reduction in the amount of 

hazardous waste shipped from the CY 2007 levels. 

 

In 2008, no radioactive waste was shipped for off-site disposal. However, in September 2008, 

work began in the FTLB using phosphorus-32, a radioactive isotope. Waste generated by these 

activities will be shipped in CY 2009. Information regarding the types and quantities of 

radioactive materials used at NREL facilities is detailed in Section 5.16. 

In 2007, a number of national laboratories, including NREL, developed an approach for the 

management of nanomaterials at DOE facilities. In 2008, DOE directed the laboratories to 

implement control programs for nanomaterials and for wastes that contain these substances.

NREL developed a program that instituted administrative and engineering controls on the use of 

nanomaterials, the creation of nanoparticles, and the management of nanomaterial-bearing 

wastes. There is some uncertainty surrounding the risk of these substances to human health and 

the environment; therefore, DOE and the national laboratories have taken a conservative 

approach to the use and disposal of nanomaterials. In May 2008, the NREL Waste Management 

and Minimization procedure was updated to include a new section that imposes new 

requirements for the packaging and disposal of nanomaterial-bearing waste. This material is 
NREL Environmental Performance Report, 2008 Page 46

collected and stored as hazardous waste, and ultimately sent to licensed treatment storage and 

disposal facilities for disposal.

As reported in the CY 2007 Annual Site Evaluation Report, the EPA conducted RCRA site 

inspections at NREL’s leased facilities in the DWOP and at the STM facilities. The items noted 

by EPA inspectors for the STM facilities resulted in a warning letter issued on December 19, 

2007. NREL took immediate corrective actions to address and resolve the EPA findings and 

developed a Hazardous Waste Program Improvement Plan to fortify hazardous waste 

management activities at NREL. In CY 2008, NREL increased the waste management training 

requirements to once per year, implemented documented weekly inspections of all waste 

collection areas, and requested an intensive program audit from the laboratory’s Quality 

Assurance organization. The increase training requirements and the weekly inspections satisfy 

the regulatory requirements anticipated when waste production increases to above the large 

quantity generator threshold.

5.7 Storage Tanks (Underground and Aboveground) 

5.7.1 Program Management 

Management in this area is consistent with the following NREL programs: Aboveground Storage 

Tank Management (6-2.7) and Spill Prevention Control and Countermeasures (6-2.10). NREL 

does not have any underground tanks with hazardous materials. 

NREL facilities store diesel fuel for emergency generators and ethanol from research activities in 

aboveground storage tanks. NREL's tank management program focuses on proper tank design, 

operation, and inspection to protect against spills and leaks. The program is designed to meet 

regulatory requirements and is more stringent in many areas than regulations require. 

Several important mechanical and procedural safeguards have been incorporated into NREL’s 

tank management program to prevent any accidental releases of diesel fuel from the storage 

tanks. Mechanical safeguards include overfill and spill protection, as well as double wall tanks 

with sensors that result in an alarm if the inner tank wall is leaking. Procedural safeguards 

include written operating procedures and tank filling procedures. All tanks larger than 110 

gallons are visually inspected at least once per month. 

Due to the quantity of fuels stored on the STM, NWTC, and ReFUEL sites, a Spill Prevention 

Control and Countermeasures Plan is required. This plan describes the site topography and 

neighboring areas, and outlines the steps necessary to mitigate any spills or leaks of diesel fuel. 

To date, NREL has not had any off-site impacts related to tank activities. 

5.7.2 Permitting 

Aboveground tanks larger than 660 gallons require annual registration with the state of Colorado. 

Currently, only two tanks meet the registration threshold: the SERF emergency generator diesel 

storage tank and the PDU ethanol storage tank at the AFUF. Both are located on the STM site. 

5.7.3 2008 Activities 

An inspection of NREL’s regulated aboveground storage tanks (ASTs) was conducted by the 

Colorado Department of Labor and Employment’s Division of Oil and Public Safety on July 10, 
NREL Environmental Performance Report, 2008 Page 47

2008. The inspector found no deficiencies. No spills or releases from NREL’s ASTs occurred 

during 2008. 

5.8 Hazardous Materials Management 

5.8.1 Program Management 

Management in this area is consistent with the following NREL programs: Chemical Safety 

Program (6-4.6) and Asbestos Management Program (6-4.18) 

No active or abandoned hazardous waste sites have been identified on any of the laboratory sites. 

Therefore, many sections of the Comprehensive Environmental Response, Compensation, and 

Liability Act do not apply to NREL facilities. 

NREL facilities are subject to the emergency reporting requirements in Title III of the SARA, 

also known as the Emergency Reporting and Community Right-to-Know Act (EPCRA). Section 

302 of the EPCRA requires a facility to notify the State Emergency Response Commission 

(SERC) that it is subject to emergency planning and notification requirements if any chemicals in 

the facility's inventory are stored in quantities greater than prescribed threshold planning 

quantities (TPQs). NREL facilities first became subject to planning and notification requirements 

in 1988. 

EPCRA Section 304 requires facilities to immediately notify the Local Emergency Planning 

Committee (LEPC) if there is an accidental spill or release of more than the predetermined RQ. 

In accordance with Section 311 and 312 of the EPCRA, NREL provides Material Safety Data 

Sheets for chemicals that are stored on site in quantities greater than TPQs, and provides 

inventory reporting for these same chemicals in the form of Tier I or Tier II reports to emergency 

planning and response groups. 

When requested, NREL provides additional emergency response and reporting information to the 

Jefferson County LEPC, the SERC, the West Metro Fire Protection District, and the Rocky 

Mountain Fire Protection District. The Jefferson County LEPC uses hazard categories and 

threshold reporting quantities as defined by the Uniform Fire Code rather than those specified in 

SARA Title III, resulting in a larger number of individual hazard categories and lower reporting 

thresholds. NREL has been represented in the LEPC since its inception and is actively involved 

in the emergency planning concepts of SARA Title III with two acting members on the Jefferson 

County LEPC. 

The laboratory is also subject to reporting requirements in the event of a release of an RQ of any 

hazardous substance listed by the 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 TPQs. Although NREL is not a 

manufacturing facility and does not fall within any of the standard industrial classification (SIC) 

codes for which Section 313 reporting is required, EO 12856 requires all federal facilities to file 

a report, if applicable, regardless of SIC code. NREL, never having manufactured, processed, or 

otherwise used chemicals on the 313 list in quantities exceeding TPQs, has never had to report 

under Section 313. 
NREL Environmental Performance Report, 2008 Page 48

Section 112r of the Clean Air Act regulates numerous toxic and flammable substances, and, 

similar to the EPCRA, establishes threshold quantities for these materials. Unlike the EPCRA, 

however, the Section 112r TPQ applies to the amount of substance in a single process, not the 

entire facility. To date, NREL has not met the thresholds that trigger applicability of Section 

112r. 

NREL has a laboratory-wide chemical management system (CMS) that serves as a centralized 

chemical inventory as well as a tool for managing and reporting on chemicals used at the 

laboratory. Using an electronic bar-coding system, the CMS 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 CMS 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, 

LEPC, EPA, and DOE). 

In recent years, the CMS system was upgraded to new software and hardware to better serve 

these functions. The EHS organization coordinates the operation of the CMS, but other 

organizations are critical to keeping the system information up-to-date. Shipping and Receiving 

is responsible for chemical labeling and data entry, Information Services provides support for the 

dedicated server that hosts the CMS, and researchers are responsible for reporting the transfer 

and disposal of chemicals. 

Asbestos surveys have been conducted in a number of NREL facilities: the JSF, Building 251 at 

the NWTC, Building 16, the STM site, the older areas of the AFUF, the FTLB, and the SRRL. 

No asbestos was found at the JSF or the AFUF. The other facilities have limited amounts of 

asbestos-containing material in areas such as floor tile, lab countertops, caulking and sealants, 

and roofing materials. Asbestos-containing materials are left undisturbed whenever possible. If 

renovation is planned that will disturb asbestos-containing material, then certified asbestos 

removal contractors are used and strict asbestos removal procedures are followed. An Asbestos 

Management Program is in effect for all NREL facilities.

 

5.8.2 Permitting 

NREL obtains annual Hazardous Material Permits from West Metro Fire Protection District 

(West Metro) for the STM and DWOP sites. The permits are required by West Metro. NREL 

obtains permits for a total of six buildings where hazardous materials are stored and/or used. 

Prior to issuing the permits, a representative from West Metro conducts a walk-through 

inspection of the entire STM site and DWOP. 

The ReFUEL facility is within the jurisdiction of the City of Denver Fire Department (DFD) and 

is subject to the DFD Hazardous Materials Information System (HMIS) requirements. The 
NREL Environmental Performance Report, 2008 Page 49

ReFUEL facility’s inventory of listed materials, including various fuels such as biodiesel, must 

be reported to the DFD annually. DFD inspects the facility and issues a Hazardous Materials 

Permit.

5.8.3 2008 Activities

West Metro conducted a walk-through inspection of NREL’s STM and DWOP facilities in the 

summer of 2008. Annual Hazardous Materials Permits for the six buildings were issued 

following the inspection. The CMS was used to provide complete chemical inventories for each 

facility as part of the permit application process. 

Similarly, the CMS provided inventory information to meet the DFD’s HMIS requirements. The 

ReFUEL facility’s Hazardous Material Permit was renewed by the DFD in July 2008.

5.9 Pollution Prevention and Sustainability

5.9.1 Program Management

Management in this area is consistent with the following NREL programs: Environmental 

Management (6-2), Sustainable NREL (2-7), and NREL’s EMS description. Most of the 

activities conducted by the Sustainable NREL program are in the following areas:

• Waste minimization, recycling, and green purchasing 

• Transportation 

• Energy 

• Renewable energy 

• GHG emissions 

• Water conservation

• Sustainable building design

• Technical assistance and outreach. 

The Sustainable NREL Program publishes an annual report that provides the details of 

accomplishments in the areas of activities listed above. The 2008 report was not available at the 

time of this report; the reader is referred to http://www.nrel.gov/sustainable_nrel/ to find the 

latest report on Sustainable NREL activities and accomplishments.

5.9.2 Permitting

NREL has no permit requirements applicable to Pollution Prevention and sustainability 

management. As a DOE facility, NREL does set objectives to meet goals established by federal 

executive orders, (e.g., EO 13423), and DOE orders. 

5.10 Vegetation Management 

5.10.1 Program Management 

Vegetation management is consistent with NREL’s Weed Management Programs for the STM 

and NWTC (6-2.12 and 6-2.13, respectively) and the Sustainable Landscape Design and 

Management Program (6-2.19). 
NREL Environmental Performance Report, 2008 Page 50

NREL’s approach to vegetation management is to conserve existing 

ecosystems in their natural state as much as possible. There is some 

landscaping using non-native drought-tolerant species adjacent to 

some of the buildings, and even a few areas of bluegrass at the STM 

site. However, the native vegetation and natural character of the 

landscape is maintained over the majority of the site. 

Revegetation of areas to be left in their natural state following 

disturbance from construction or other outdoor activities is 

conducted using a native seed mix of grasses and forbs. These 

mixes are site-specific and are composed predominantly of native 

species that were originally present on the site before the 

disturbance. Seed mix and revegetation procedures are outlined in 

NREL’s Stormwater Pollution Prevention Programs for the STM 

and NWTC Sites. The use of native species is required at both the 

STM and NWTC whenever possible. When feasible, high-water 

demand species like Kentucky bluegrass are replaced with droughttolerant native species. The most recent vegetation survey of the 

STM was conducted between June 2001 and May 2002. Five 

general habitats were described on the STM site, comprising seven plant communities (Plantae 

Consulting Services 2002). No rare or imperiled plant species were found on the site. Areas of 

mixed foothills shrublands (also called tall upland shrubland) were identified on top of the mesa 

within the conservation easement area. This natural community is listed as rare and imperiled by 

the Colorado Natural Heritage Program. No development will occur in the conservation 

easement area. 

In Colorado, the Department of Agriculture Commissioner, in consultation with the state noxious 

weed advisory committee, local governments, and other interested parties, develops and 

implements state noxious weed management plans for three categories of weed species. Class A 

plants are targeted for eradication while Class B species are subject to management plans 

designed to stop the continued spread of these species. 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 goal of such plans will not be to stop the 

continued spread of these species but to provide additional education, research, and biological 

control resources to jurisdictions that choose to require management of List C species. Of the 

noxious weed species that have been identified on the STM site, three—Canada thistle, diffuse 

knapweed, and musk thistle—are Class B species and one, field bindweed, is on the Class C list.

A three-season vegetation survey of the NWTC site was performed between August 1999 and 

August 2000. The survey defined five general habitats on the NWTC site, comprising nine plant 

communities and 271 vascular plant species (Plantae Consulting Services 2000). No rare or 

imperiled plant species were found on the site. However, the survey identified a small area of 

xeric tallgrass prairie (defined as mesic mixed grassland in this study) located in the southwest 

corner of the NWTC. This natural community is listed as rare and imperiled by the Colorado 

Natural Heritage Program. This listing implies no legal designation or regulatory enforcement. It 

is so designated primarily for management purposes. This area of the NWTC is not impacted by 

research or construction activities on the site. 

Figure 20. Sego Lily at the 

NWTC

Credit: Bob Fiehweg
NREL Environmental Performance Report, 2008 Page 51

Of the weed species identified at the NWTC site, four are Class 

B species—Canada thistle, diffuse knapweed, musk thistle, and 

leafy spurge—and one, field bindweed, is on the Class C list.

Based on the survey, recommendations were made to continue 

using a comprehensive weed management program, founded on 

an integrated pest management (IPM) philosophy. 

The survey showed the native seed mix used for revegetation at 

the NWTC to be very successful in many areas of the site.

NREL is continuing the use of this seed mix for revegetation at 

the NWTC.

Weed control efforts have been ongoing since 1997 at the 

NWTC and 1998 at the STM site. NREL uses an IPM approach 

that incorporates various types of weed control methods. Some 

of these include mechanical practices (e.g., mowing), 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 and Canada thistle on the sites. The key 

aspect of the weed control program is to maintain flexibility to respond to the changes in weed 

populations from year to year. 

In 1998, aerial herbicide application of Tordon 22K was conducted using helicopter application 

over about 200 acres of the NWTC to target diffuse knapweed. It was very effective in 

controlling the weed, and healthy stands of native grasses have proliferated with the decrease in 

weed competition. Since that time, infested areas of the NWTC have been treated with groundapplied herbicide. 

Weed infestations at the STM site are much less severe than at the NWTC. Limited ground 

application of herbicides has been conducted at the STM since 1998. 

NREL promotes the sustainable management of its government-owned land by practicing 

environmentally sound, cost-effective landscaping practices. These practices reduce adverse 

impacts to the natural environment while providing essential shade and cooling for indoor and 

outdoor spaces, and a more aesthetically appealing appearance for the sites. This commitment is 

implemented by a sustainable landscape design and management program. 

5.10.2 Permitting 

There is no permitting applicable to vegetation management, although there is a state weed law 

that requires property owners to control certain species of invasive weeds (e.g., diffuse 

knapweed). For application of certain types of herbicides designated as “restricted use” by the 

EPA, a certified applicator must be used. 

Figure 21. Prairie Goldenpea 

Thermopsis at the NWTC

Credit: Bob Fiehweg
NREL Environmental Performance Report, 2008 Page 52

5.10.3 2008 Activities 

NREL routinely practices IPM using various weed control methods, as described in the previous 

section. These are implemented during the normal course of site operation. In addition to the 

reclamation, off-road driving restrictions, and other weed control methods, ground applications 

of herbicides occurred at the NWTC in the spring of 2008. Very limited herbicide application 

was conducted on the STM site in the spring of 2008, focusing primarily on areas adjacent to 

roadways and buildings. The spraying was performed using a four-wheel drive vehicle. Primary 

target weeds were diffuse knapweed, leafy spurge, Canada thistle, common teasel, and hoary 

cress at the NWTC. At the STM, target weeds were mainly diffuse knapweed and Canada thistle, 

with small areas of Dalmatian Toadflax. 

In 2006, the weed management plans for the NWTC and STM were consolidated into an 

integrated weed management plan. Weed management activities in 2008 were consistent with the 

integrated plan. 

A master plant list for NREL was compiled in 2007. This list is based on information gathered 

during comprehensive vegetation surveys of the STM and NWTC completed in FY 2000-02 by 

Plantae Consulting Services. No formal field work has been completed since the FY 2002 

survey, but the list is updated as NREL EHS staff becomes aware of species not on the list (see 

Appendix B).

5.11 Wildlife 

5.11.1 Program Management 

Wildlife habitat at the STM site is primarily grasslands, shrublands, and wetlands, while the 

habitat at the NWTC is comprised of grasslands, woodlands, shrublands, and wetlands. Both 

sites provide vegetation types for a variety of wildlife species, including birds, mammals, 

reptiles, and amphibians. The variety of vegetation types attracts species that may use the site as 

a year-round habitat, for breeding, during migration, or as winter habitat. Wildlife surveys were 

conducted on the STM site in 1987 and 2005, with follow-up verification surveys conducted in 

1998 and 1999. Follow-up surveys are planned for both the NWTC and STM in the near future. 

5.11.2 NWTC Site 

The NWTC site is located in the transition zone between the Great Plains and the Rocky 

Mountains, resulting in habitat that contains elements from both mountain and prairie 

ecosystems. DOE prepared a biological characterization inventory for the adjoining Rocky Flats 

site, including the NWTC, in 1992. At that time, 11 mammals and eight species of reptiles or 

amphibians were documented. Representative species currently using the site include the deer 

mouse, prairie vole, desert cottontail, coyote, mule deer, prairie rattlesnake, bullsnake, plains 

garter snake, and tiger salamander.

Following the 1992 inventory, field surveys of avian use patterns at the NWTC were conducted 

in 1994 and 1995 to identify potential impacts of wind-turbine research on birds. Several species 

of raptors, including the red-tailed hawk, American kestrel, and great-horned owl, were noted on 

the site, primarily resting and hunting; however, a pair of kestrels were found nesting during the 

spring. Birds of prey of concern, such as eagles, generally fly in excess of 152 meters (500 feet) 
NREL Environmental Performance Report, 2008 Page 53

over the site. No significant impacts to the birds from NREL activities 

were found during these surveys. 

In early 2001, a year-long monitoring project for birds and bats was 

initiated at the NWTC. Standardized plot surveys were conducted to 

document the occurrence of songbirds and raptors on the site and 

adjacent undeveloped areas. This work also included systematic 

searches of turbines and meteorological towers to document avian 

mortality. The study was completed in July 2002. Notable findings of 

the study were as follows (Schmidt, E. et al. 2003): 

• Abundances of individual raptor species on the NWTC site 

were similar to surrounding areas. However, the average 

number of species detected per count at the NWTC was nearly 

double that of surrounding areas in winter, the season when 

raptors are most abundant in the region. This difference is 

likely attributable to increased availability of perches at the 

site. Raptors flew and perched higher at the NWTC than in 

adjacent areas, again probably related to the wind turbines and other structures at the site. 

• Forty-six bird species were counted on grassland plots during this study. Only one 

differed in abundance between the NWTC and adjacent areas: the horned lark was about 

16 times more common offsite. This difference is attributable to cattle on Boulder Open 

Space, creating low-stature grasslands preferred by this species. 

• Bird abundance and variety on the undeveloped southern portion of the NWTC site were 

generally similar to the developed areas, except for the relative scarcity of raptors on the 

undeveloped site, which probably was due to a lack of perches. 

• The NWTC does not support a large diversity or abundance of bat species (possibly six 

species of bats use the site), but an area on the northwest side of the site, with trees close 

to a rocky outcrop, provides foraging and potential roosting habitat. 

• No raptor carcasses were found during the 12-month survey of the NWTC except one 

American kestrel that had died before the study began. Bird mortality associated with the 

site appears to be minimal. Extrapolating from four passerine (songbird) carcasses found 

during the searches, estimated annual bird mortality attributable to NWTC activities was 

24 individuals, all songbirds (Passeriformes). Most of these deaths were probably the 

result of collisions with support wires for the meteorological towers rather than the 

turbines themselves. No evidence was found of bat fatalities at the site. 

5.11.3 STM Site 

Similar to the NWTC, the STM site is located in the transition zone between the Great Plains and 

the Rocky Mountains, resulting in a habitat that contains elements from both mountain and 

prairie ecosystems. The most recent site-wide wildlife survey of the STM site began in April 

2004 and was completed in June 2005. The objectives of the survey were to update existing data 

in light of expanded development of both the site and the surrounding area, and to develop best 

management practices for future construction projects to maximize protection for site wildlife. 

Figure 22. Vesper 

Sparrow at NWTC

Credit: Bob Fiehweg
NREL Environmental Performance Report, 2008 Page 54

The survey included large and small mammals, 

predators, migratory birds and raptors, upland 

game birds, and invertebrates identified on an 

opportunistic basis (i.e., only as they are found 

during other surveys). A list of species 

observed at NREL is found in Appendix B; it 

includes the species observed during the yearlong STM wildlife survey. 

5.11.4 Permitting 

Scientific collection licenses must be obtained 

from the Colorado Division of Wildlife for the 

small mammal trapping portion of the wildlife 

surveys. NREL has no other permitting 

requirements for this area of environmental 

management. 

5.11.5 2008 Activities 

In compliance with the Migratory Bird Treaty Act, surveys for ground-nesting birds were 

completed prior to activities that could adversely affect these species. Surveys were conducted 

during the nesting season, from mid-April through mid-September. If an active nest was found, a 

buffer zone was set up around the nest to avoid impacts to nests during site activities. 

Several ground-nesting bird surveys were conducted in 2008 on the mesa top portion of the STM 

in advance of planned construction activities associated with the installation of the mesa top PV 

system. No active nests were found during any of these surveys, and construction activities were 

allowed to proceed. During these surveys, three additional bird species were seen on site that had 

not been observed in the 2005 wildlife survey: the lark sparrow, cliff swallow, and blue-gray 

gnatcatcher. 

In May 2008, two ground-nesting bird surveys were done at the NWTC in areas slated for 

herbicide application and mowing. Although a few ground-nesting bird species were observed, 

no active nests were found; approval was given to commence spraying and mowing. 

5.11.5.1 Migratory Birds and Raptors 

Many species of migratory birds were observed on the STM site, with many of these species 

potentially nesting on site. Additionally, the STM site provides important migration and winter 

habitat for migratory birds. For example, American tree sparrows are only observed on site 

during the winter, and northern harriers have been observed hunting on site only in the fall and 

winter. Several species were only observed during the fall, including the blue jay, downy 

woodpecker, red-breasted nuthatch, loggerhead shrike, and rock wren, suggesting that these 

species may use the STM site as a stopover during migration. Habitat for migrating birds is 

important, as some of these species may migrate as far south as Central and South America.

Figure 23. Western Meadowlark on STM

Credit: Bob Fiehweg
NREL Environmental Performance Report, 2008 Page 55

Several species of raptors were observed at the 

STM site, and two species were observed nesting 

on site by both studies (1987 and 2004-2005): the 

red-tailed hawk and the American kestrel. Both of 

these species were observed hunting on site during 

the 2004-2005 surveys, in addition to the Cooper’s 

hawk, which is known to nest along nearby Clear 

Creek. The NREL STM site provides habitat and a 

prey base of small birds and mammals for these 

raptor species. Species such as the Swainson’s 

hawk migrate thousands of miles each year to 

winter in Argentina, and return to the western 

United States and Canada to breed. Areas such as 

the STM site may provide a prey source for the 

Swainson’s hawk and other species during 

migration. 

5.11.5.2 Large Mammals 

Mule deer at the STM site have been observed in all habitat types. Mule deer were often 

observed in the amphitheater drainage or in the tall shrubland on the slope. When approached on 

the mesa top, the mule deer tended to move away from the disturbance and into the amphitheater 

drainage. 

The tall shrubland vegetation type may provide important hiding cover for this species. Spring 

pellet group surveys resulted in nearly double the amount of pellet groups and plots of the pellet 

groups than were observed in the fall surveys. This may suggest that winter use of the STM site 

by deer may be higher than summer use, or that deer use different habitats on site for these 

periods as affected by the availability of habitats and the location of survey plots; however, the 

single year of data is not sufficient to draw conclusions regarding seasonal variation. 

5.11.5.3 Predators 

Coyotes are one of the most widespread and adaptable carnivores in North America and occur at 

all elevation levels and in all ecosystems in Colorado (Fitzgerald, et al. 1994). Lagomorphs 

(rabbits) and rodents are an important part of the coyote’s diet, both of which are abundant on the 

STM site. Evidence of predation on cottontail rabbits (i.e., entrails and fur) was observed during 

site visits. Coyotes may breed on the STM site as two potential dens were observed in two of the 

site drainages. 

5.11.5.4 Small Mammals 

The deer mouse is the widest ranging and most common small mammal in North America 

(Fitzgerald et al. 1994), and based on the 1987 and 2004-2005 survey data, it is also the most 

common small mammal on the NREL STM site. Deer mice can occur anyplace where cover 

occurs (Fitzgerald et al. 1994) and were observed in the four vegetation types sampled on the 

STM site. This species is a generalist and is known to exploit disturbed habitats. 

Figure 24. Red-tailed Hawk soaring over 

STM

Credit: Bob Fiehweg
NREL Environmental Performance Report, 2008 Page 56

Mexican woodrats and prairie voles have more 

restricted ranges at the STM site. Mexican 

woodrats are associated with rocky slopes and 

do not build dens away from rocky areas 

(Fitzgerald et al. 1994); this habitat is limited 

at the STM site. Prairie voles are adapted to 

grasslands, constructing burrows and runway 

systems throughout the grassland, essentially 

limiting this species to the short grass and 

mixed grass vegetation types on the STM site. 

All of these species are active throughout the 

year. Winter surveys (2004-2005) were 

conducted during a warm weather trend, which 

may have contributed to the highest number of 

small mammals caught compared to the three 

other surveys. 

In November 2008, NREL developed a plan for the environmentally responsible removal of an 

estimated 50 prairie dogs from the western portion of the NWTC. A 1 MW photovoltaic array is 

planned for the area currently colonized by the prairie dogs, necessitating the removal. Biologists 

at NREL determined that the most cost-effective and environmentally responsible procedure 

included onsite relocation of the prairie dog colony to the northwest corner of the NWTC within 

one of the designated conservation management areas. By the end of 2008, a capture/relocation 

company was awarded a contract, monitoring of current conditions was completed, and trenching 

in the relocation area was initiated. This project continued into CY 2009 with the successful 

relocation of the colony. 

5.11.5.5 Reptiles/Amphibians 

Rattlesnakes are often observed on the STM site, usually in rocky areas, but also in the 

grasslands, and sometimes in and near the STM buildings. Snakes found near or in buildings are 

removed by NREL security or environmental personnel and relocated to remote areas of STM. 

Hibernation generally occurs in rock outcrops, with this species usually active from mid-April 

through late-September (Hammerson 1999). 

To avoid or minimize disturbance to wildlife species on site, site-wide best management 

practices (BMPs) are employed during ongoing normal site operations and future construction 

projects. The BMPs address migratory birds and raptors, mammals, all wildlife, and general site 

operations. For example, rattlesnakes found near STM buildings are relocated, not destroyed; the 

no-kill policy is a BMP. 

Figure 25. Black-tailed prairie dog at the NWTC

Credit: Bob Fiehweg
NREL Environmental Performance Report, 2008 Page 57

5.12 Endangered Species/Species of Concern 

5.12.1 Program Management 

The Endangered Species Act provides for the designation and protection of wildlife, fish, and 

plant species that are in danger of extinction, and preserves the ecosystems on which these 

species depend. For the purposes of site wildlife surveys, a species of concern is defined as one 

protected under federal statutes, including the Endangered Species Act of 1973, as amended, the 

Bald Eagle Protection Act of 1940, as amended, and the Colorado Division of Wildlife list of 

endangered, threatened, and wildlife species of concern. Federal agencies are also required to 

abide by the Migratory Bird Treaty Act of 1918, as amended; however, for this report, these 

species are not included as species of concern. For plant surveys, the Colorado Natural Heritage 

Program designation is also considered. Although this listing of rare species is not regulatory in 

nature, NREL uses it for management purposes. 

The U.S. Fish and Wildlife Service has identified eight species listed in accordance with the 

Endangered Species Act as threatened, endangered, or a candidate for listing, that could 

potentially occur within the STM site project area. Of Colorado’s species of concern, eight 

species may potentially occur at the STM site. None of these were observed during any of the 

site surveys. However, based on existing habitat, four species could potentially be found at the 

site: the American peregrine falcon, bald eagle, ferruginous hawk, and black-tailed prairie dog.

Although a similar comparison of existing habitat at the NWTC to listed species has not been 

done to date, there is a colony of black-tailed prairie dogs present at the NWTC. As mentioned, 

the colony has been relocated to the northwestern portion of the site, in one of the designated 

conservation management areas. 

The vegetation survey at NWTC, conducted between August 1999 and August 2000, identified a 

small area of xeric tallgrass (defined in the survey as mesic mixed grassland) prairie located in 

the southwest corner of the NWTC site. This natural community is listed as rare and imperiled 

by the Colorado Natural Heritage Program. This listing implies no legal designation, but is made 

primarily for management planning purposes. This xeric tallgrass prairie area has been 

designated by NREL as a conservation management area. Most of the conservation management 

areas on the NWTC are formally designated as areas on which building will not occur. However, 

as the xeric tallgrass prairie is in the active turbine testing area, it is not reasonable to preclude all 

development on portions of the site inhabited by this plant community. However, to the greatest 

extent possible, disturbance will be minimized on this biome. 

The STM site vegetation survey completed in May 2002 found no rare or imperiled plant species 

on the site, but areas of mixed foothills shrublands (also called tall upland shrubland) were 

identified along the top of the mesa within the conservation easement area. That natural 

community is listed as rare and imperiled by the Colorado Natural Heritage program. It is within 

a designated conservation easement area where no development will occur except trails being 

established by Jefferson County Open Space (see Section 6.1). 

As reported in Section 5.11.3, a site-wide wildlife survey of the STM site has recently been 

completed. No species observed on the STM site during the 1987 or the 2004-2005 wildlife 

surveys were present on either agency’s list. However, golden eagles were incidentally observed 
NREL Environmental Performance Report, 2008 Page 58

on the STM site (outside of raptor surveys) and are protected under the Bald and Golden Eagle 

Protection Act. Golden eagles were observed flying over the site and may use the site for 

hunting. No golden eagle nests or nesting activities were observed on the STM site. 

5.12.2 Permitting 

NREL has no permitting requirements for this area of environmental management. 

5.12.3 2008 Activities 

In 2008, the presence of the non-native Eurasian Collared Dove continued at NREL’s STM. This 

invasive species, first spotted at STM in 2006 as a new avian species, had just begun to inhabit 

the Denver area at that time. The Colorado Division of Wildlife considers this species to be a 

threat to native avian species.

5.13 Wetlands/Floodplains

Management in this area is consistent with the following NREL programs: Stormwater Pollution 

Prevention for Construction Activities at the STM (6-2.15), Stormwater Pollution Prevention for 

Construction Activities at the NWTC (6-2.16), and the Environmental Permitting and 

Notification (6-2.1). 

5.13.1 Program Management

Wetlands are defined by the EPA and the U.S. Army Corps of Engineers (USACE) as areas that 

are inundated or saturated by surface or ground water at a frequency and duration sufficient to 

support, and that under normal circumstances do support, a prevalence of vegetation typically 

adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, 

and similar areas. Wetlands became regulated in 1972 when, under the Clean Water Act, the 

definition of waters of the United States was expanded from only those waters capable of 

supporting interstate or foreign commerce, as defined under the Rivers and Harbors Act of 1899, 

to waters that also include tributaries to navigable waters, interstate wetlands, wetlands which 

could affect interstate or foreign commerce, and wetlands adjacent to other waters of the United 

States. 

Wetlands that meet hydric soils, vegetation, and hydrologic criteria are protected under Section 

404 of the Clean Water Act, which is administered by the USACE with program oversight 

provided by the EPA. Areas that do not meet the criteria established by the USACE may perform 

wetland functions and serve as valuable ecologic components, but do not fall within the 

jurisdiction of the USACE and are therefore not protected or regulated under Section 404 of the 

Clean Water Act. 

5.13.2 2008-2009 Activities

In early 2009, the USACE was invited to the STM site to determine whether the observed 

wetlands and drainages that cross the STM site are considered jurisdictional and, therefore, 

regulated by the USACE. The following six drainages were identified:

• East drainage (east of the Visitors Center)

• Middle drainage (originating upstream of the amphitheater and flowing between the 

FTLB and the SERF)

• Middle west drainage (above the Thermal Test Facility)
NREL Environmental Performance Report, 2008 Page 59

• West drainage (near the west entrance gate)

• Jefferson County easement drainage (south of Denver West Parkway and east of the 

“lower 25”) 

• Roadside drainages and trickle channel drainages (constructed drainages generally on the 

north side of Denver West Parkway). 

Following their site visit, the USACE issued a letter stating that all drainages examined were 

considered upland swales vegetated with upland vegetation and are, consequently, not 

regulated/protected by the USACE. They provided a jurisdictional determination documenting 

their finding. The USACE jurisdictional determination, valid for five years (through April 27, 

2014), enables NREL to perform work in the upland swales/wetlands without a USACE permit.

While the USACE did not consider wetlands located at STM to be jurisdictional, NREL regards 

them as ecologically functional wetlands. Vegetation surveys in 2000 and 2001 at STM and the 

NWTC identified wetland areas totaling 0.3ha (0.75 acres) and 0.4ha (1 acre), respectively.

These areas will continue to be protected for the benefits they provide, which include water 

quality filtration, attenuation of stormwater flows, and habitat for site fauna. 

5.14 Cultural Resources 

5.14.1 Program Management 

Cultural resources are protected under Section 106 of the National Historic Preservation Act of 

1966, as amended. Significant cultural resources are either eligible for, or listed in, the National 

Register. 

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 any other reason. 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 (e.g., arrowheads, bottles). 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 because of its association with cultural practices or beliefs of a living 

community that are rooted in the community’s history, and are important in maintaining the 
NREL Environmental Performance Report, 2008 Page 60

continuing cultural identity of the community. Traditional resources may include archaeological 

resources, buildings, neighborhoods, prominent topographic features, habitats, plants, animals, 

and traditional culture. 

5.14.1.1 Site Surveys 

Three formal surveys of historic and cultural resources have been performed on the STM site. 

These surveys were completed in 1980, 1987, and 2003. Two additional surveys of the Camp 

George West district involving the STM site have also been conducted. 

As a result of these STM surveys, three historical sites were recognized as significant cultural 

resources that should be preserved. These sites include an open-air amphitheater, a stone bridge 

spanning a natural drainage channel adjacent to the amphitheater, and a stone and concrete 

ammunition bunker below the amphitheater site. The three structures were constructed during the 

Works Progress Administration era in the 1930s. Through NREL's efforts, these sites have been 

added to the National Register, with the amphitheater and stone footbridge listed together as a 

single site. NREL also participated in an interagency survey of STM and Camp George West to 

identify historic structures and sites eligible for nomination to the National Register. Figure 7

provides an aerial view of the amphitheater. 

The Camp George West Historic District, also listed on the National Register, includes the 25-

acre parcel of NREL’s site, south of the DWOP. Two types of historic archaeological resources 

(firing range lines and a low rock wall) have been identified on this parcel. These resources have 

been determined to contribute to the National Register eligibility of the Camp George West 

Historic District. 

The Camp George West Historic District overlaps the NREL STM property by 25 acres. Two 

contributing resources, features within a historic district that contribute to the district’s overall 

eligibility for the National Register, occur within those 25 acres.

A 2003 cultural resource survey was conducted of the 25-acre parcel south of Denver West 

Parkway on the STM site. The survey confirmed the existence of the contributing features to the 

Camp George West Historic District occurring within the 25-acre parcel. The contributing 

resources are: 

• Two firing lines located on the 25 acres. There are also firing lines located south of the 

NREL property on land owned by Jefferson County Open Space and proposed for 

development as the Camp George West Park. 

• Portions of a low rock wall are also present on the 25 acres. There is also a rock wall 

located south of the NREL property. 

DOE consulted with the State Historic Preservation Office (SHPO) regarding the significant 

resources located on the 25 acres. DOE and the SHPO subsequently entered into a Memorandum 

of Agreement where DOE agreed to perform further surveys to fully document the resources on 

the 25 acres prior to any development of the parcel. 

In 2005, DOE-GO and NREL conducted documentation of the Camp George West firing range 

lines and low rock walls, which contribute to the Camp George West Historic District’s 
NREL Environmental Performance Report, 2008 Page 61

eligibility to the National Register. The documentation resulted in Level II documentation from 

the Historic American Buildings Survey (HABS) and the Historic American Engineering Record 

(HAER) that consisted of mapping, photographs, and detailed descriptions of the resources. The 

documentation was submitted using archival quality materials to the SHPO in late 2005. 

In January 2006, the Camp George West Level II HABS/HAER documentation (originally dated 

August 2005) was revised to include field drawings of the “low rock wall” as requested by the 

Colorado SHPO. This was the final report submitted to the SHPO. It is on file with the Colorado 

SHPO, and also at the DOE-GO and NREL offices. 

Also in CY 2006, a site survey for cultural resources was conducted in support of NREL/DOE 

EAs for the first of three site development projects (RFHP, and two potential solar field sites). 

The RFHP EA was completed in early summer 2007. 

An archaeological survey of the NWTC site was conducted in support of the 1996 

environmental assessment to supplement previous surveys so there were no gaps in cultural 

surveys on the site. No significant historical or archaeological resources were identified. 

However, the wooded ridge area on the west portion of the site was identified as a location with 

potential for cultural resources, so further testing or observation during excavation would be 

done should there be any future need for work in the utility corridor in the vicinity of the ridge. 

5.14.2 Permitting and Requirements 

NREL has no permitting requirements for this area of environmental management. In order to 

comply with cultural resource protection requirements, NREL instructs construction contractors 

at their site orientation that in the event they discover any evidence of cultural resources during 

ground disturbing activities at the STM or NWTC sites, they are to stop all work in the vicinity 

until a qualified archaeologist evaluates the significance of the find. 

5.14.3 2008 Activities 

In 2008, the NREL procedure 6-2.11 Cultural Resource Management was revised, effective 

December 22, 2008. This procedure is a management tool for achieving proper coordination 

regarding cultural resource protection among appropriate NREL managers and workers. In 2008, 

construction activities began on the RSF near the Site Entrance Building. During the preliminary 

excavations, a few items were unearthed that were reviewed under the Cultural Resource 

Management procedure; while of interest, no one were found to be of unique value. 

5.15 National Environmental Policy Act

5.15.1 Program Management 

Management in this area is consistent with NREL’s National Environmental Policy Act (NEPA) 

Implementation Program (6-2.2). 

As a federal agency, DOE is obligated to comply with NEPA by evaluating the potential for 

environmental impacts prior to conducting its activities. The Council on Environmental Quality 

(CEQ) issues regulations for compliance with the Act. DOE has also issued implementing 

regulations at 10 Code of Federal Regulations (CFR) that complement the CEQ requirements. 
NREL Environmental Performance Report, 2008 Page 62

DOE has written a site-wide EA for its activity at the STM site and DWOP, and separate EAs for 

the NWTC and JSF activities.

NREL has established procedures, with the approval of DOE-GO, to assist DOE in meeting their 

NEPA obligation. Proposed activities that will be conducted at NREL’s five sites are evaluated 

for their potential environmental effects using the appropriate level of NEPA review, in 

conjunction with DOE-GO. 

The NREL NEPA Handbook has been prepared to provide NREL project managers and 

procurement specialists with guidance on implementing the NEPA procedures, and training is 

provided to staff, as appropriate. 

5.15.2 Permitting 

NREL has no permitting requirements under NEPA. 

5.15.3 2008 Activities 

During 2008, numerous NEPA reviews of both onsite and offsite activities occurred through 

completion of NEPA Worksheets and NREL environmental checklists. As outlined in NREL’s 

NEPA implementation procedures, these reviews were coordinated among NREL project 

managers, subcontracting staff, the NREL NEPA coordinator, and the DOE-GO NEPA 

Compliance Officer. NEPA requirements were also coordinated with future program planning 

(e.g., development of NREL’s 2007 Grand Buildout Infrastructure Design) through interaction 

between NREL’s EHS Office director and NREL’s technology program and project managers. 

Requirements were also coordinated through participation in the NREL management annual 

planning process, Environmental Management System implementation, and other reviews of 

proposed projects for the upcoming FY 2009. 

In CY 2008, NREL began the EA process for the second STM site-wide EA supplement 

(DOE/EA 1441-S-2) to address proposed site development projects, including the Energy 

Systems Integration Facility, site infrastructure improvements (Phase II), a second full service 

access road, expansion of the Waste Handling Facility, and expansion of the Visitors Center. 

5.16 Radiological Program 

5.16.1 Program Management 

Management in this area is consistent with the following NREL programs: Air Quality 

Protection (6-2.5) and Radiation Safety (6-4.5). All radioactive material at NREL facilities is 

handled according to NREL’s Radiation Safety Program. Elements of the program include a 

Radiation Safety Committee, a Radiation Safety Lab-level Procedure, safe operating procedures, 

safe work permits, radiological control areas and postings, monitoring, training (Rad Worker 1: 

Radiation Equipment Safety and Rad Worker 1: Radiation Materials Safety), and purchasing 

controls for radioactive materials. 

There are no nuclear operations at NREL sites. All of NREL’s radiation sources are used/stored 

in facilities located on the STM site. These include three x-ray diffraction machines at the SERF, 

and one at the FTLB. In addition, one laboratory at the FTLB on the STM site occasionally uses 

small quantities of radioisotopes for biological labeling. A new x-ray fluorescence machine was 
NREL Environmental Performance Report, 2008 Page 63

installed in the SERF in 2008. All x-ray generating machines are inspected annually. A statelicensed surveyor inspects and certifies the x-ray machines and audits NREL's program for 

radiation safety in connection with operating the machines every other year. NREL’s radiation 

safety officer conducts the inspections in alternating years. 

Monitoring of equipment and facilities for removable contamination is performed in the 

laboratory where radioisotopes are used. Wipe tests are performed at least monthly, and more 

frequently if needed, on any laboratory surfaces that could have become contaminated by the 

radioisotope work. These wipes are analyzed using a scintillation counter. 

DOE Order 5400.5, “Radiation Protection of the Public and the Environment,” established 

radiation emission limits for DOE facilities. Such emissions are also regulated by Section 112 of 

the Clean Air Act as implemented by 40 CFR 61, Subpart H, promulgated by the EPA. 40 CFR 

61 established National Emission Standards for Hazardous Air Pollutants (NESHAPs), and, 

more specifically, Subpart H sets such standards for radiological materials, known as Rad 

NESHAPs. DOE facilities, including NREL, must annually demonstrate compliance with the 

Rad NESHAP, which limits emissions to amounts that would prevent any member of the public 

from receiving an effective dose of 10 millirem per year or greater. No radioactive air-emission 

monitoring is conducted at NREL because of the extremely low usage of radioactive material. 

Therefore, NREL demonstrates compliance with the Rad NESHAPs in 40 CFR 61, Subpart H by 

using the EPA’s COMPLY computer model to determine the potential dose to the public. NREL 

completed the 2008 report and the results of the COMPLY model showed that the potential dose 

to the public was well below the limit.

All radioactive waste generated during NREL activities is classified as low-level waste. Waste 

from the STM site is temporarily stored at the Waste Handling Facility (WHF) until disposal is 

arranged at an offsite facility permitted to accept low-level radioactive waste. 

5.16.2 Permitting 

NREL does not have a radioactive materials license from the state of Colorado as the laboratory 

is currently under DOE jurisdiction for radioactive materials handling.
NREL Environmental Performance Report, 2008 Page 64

6 Conservation Easement Lands 

In 1999, DOE granted a conservation easement for 177 acres of the STM site to Jefferson 

County. The purpose of the conservation easement is to preserve the natural character of the 

property, including its visual, biological, and recreational resources, especially in relation to the 

changing land uses adjacent to the NREL site and within the region. 

Figure 26. Conservation easement lands

Credit: Steve Wilcox

The goals of the easement are to: 

• Retain, preserve, and protect natural, scenic, ecological, and historical aspects of the 

conservation easement property; 

• Protect the ecosystem of the STM area and the sustainable habitat for diverse vegetation, 

birds, and terrestrial animals; 

• Ensure the scenic and biological integration with adjoining open-space land; 

• Prevent further industrial, commercial, or residential development of the conservation 

easement property; and 

• Preserve the conservation easement property as natural open space. 

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 

(Department of Energy, Golden Field Office, 1999). 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 

(geology, hydrology, vegetation, wildlife, and cultural resources).

Jefferson County began the development of the South Table Mountain Management Plan in 

2000, with a final version approved by the Jefferson County Open Space Advisory Committee 

and the Board of County Commissioners in 2004. 
NREL Environmental Performance Report, 2008 Page 65

6.1 2008 Property Assessment 

During 2008, there was no NREL activity on the conservation easement property having the 

potential to degrade the environmental condition of the property. Jefferson County Open Space 

conducted a site inspection during the summer of 2004; no degraded conditions or other 

environmental issues were found. 

Jefferson County Open Space has the responsibility to establish and maintain formal trails on the 

conservation easement property. The trail plan calls for establishing trails in phases. The first 

phase began in 2004, with Jefferson County Open Space installing two trails from Denver West 

Parkway (near the NREL Site Entrance) to the mesa top. Routine trail maintenance occurred in 

CY 2008. The access trail along the NREL entrance road was improved in 2008. 
NREL Environmental Performance Report, 2008 Page 66

7 Contacts for Feedback or More Information

We welcome your feedback and suggestions on this report and on NREL’s efforts at 

sustainability and environmental stewardship. To provide comments or to obtain additional 

information about NREL’s environmental and sustainability programs, please contact: 

Maureen Jordan John Eickhoff 

Director, EHS Senior Environmental Scientist 

maureen.jordan@nrel.gov john.eickhoff@nrel.gov

303-275-3248 303-275-3217 

Figure 27. Site wildlife at sunset

Credit: Steve Wilcox

National Renewable Energy Laboratory

1617 Cole Boulevard, Golden, Colorado 80401-3393 

303-275-3000 – www.nrel.gov

Operated for the U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

by the Alliance for Sustainable Energy, LLC

NREL- August 2009
NREL Environmental Performance Report, 2008 Page 67

8 References 

Armstrong, D.; Bock, C.; Piaggio, T.; Schmidt, E. (2001). NWTC Site wide Bat and Avian 

Impact Study Plan. May 1, 2001-July 31, 2002.

Contreras, M. A.; Egaas, B.; Ramanathan, K.; Hiltner, J.; Swartzlander, A.; Hasoon, F.; and 

Nufi, R. (1999). Progress Toward 20% Efficiency in Cu(In,Ga)Se2 Polycrystalline Thin-film 

Solar Cells. Prog. Photovolt. Res. Appli. 7.311-316. 

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

December 1992. Golden, Colorado. 

Felsburg Holt & Ullevig (2007). National Renewable Energy Laboratory South Table Mountain 

Facility Traffic Impact Study Update. Centennial, Colorado.

Handex of Colorado, Inc. (1997). Groundwater Monitoring Report, South Table Mountain Site. 

Golden, Colorado. 

National Renewable Energy Laboratory (Draft). EHS Program Number 6-2.12, 

Weed Management Program, STM Site. Golden, Colorado. 

National Renewable Energy Laboratory (1997). National Renewable Energy Laboratory 

Environmental Report for 1995 and 1996. Golden, Colorado. 

National Renewable Energy Laboratory (1999a). National Renewable Energy 

Laboratory Five-Year Plan, 2000-2004. Golden, Colorado.

National Renewable Energy Laboratory (1999b). NREL Policy Number 6-2, Environmental 

Management. Golden, Colorado. 

National Renewable Energy Laboratory (1999c). NREL Policy Number 6-6, Risk Assessment. 

Golden, Colorado. 

Piaggio, T, (18 July 2001). Telephone communication. Doctoral Candidate, Environmental, 

Population, and Organismic Biology, University of Colorado, Boulder. 

Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology 

Center. Boulder, Colorado. 

Plantae Consulting Services (2002). Vegetation Survey, NREL South Table Mountain Site. 

Boulder, Colorado 

Rust Environment & Infrastructure, Inc. (1993). Water Quality Monitoring, National Wind 

Technology Center. Englewood, Colorado. 
NREL Environmental Performance Report, 2008 Page 68

Rust Environment & Infrastructure, Inc. (1994). Final Report, Baseline Surface Water 

Monitoring Program: 1993. Englewood, Colorado. 

Rust Environment & Infrastructure, Inc. (1995a). Report, Wastewater Monitoring Program, 

Fourth Quarter, 1994 and Annual Report. Englewood, Colorado. 

Rust Environment & Infrastructure, Inc. (1995b). Final Report, Ground Water Monitoring, Third 

Quarter, 1994 and Fourth Annual Report, South Table Mountain Site. Englewood, Colorado. 

Schmidt, E.; Piaggio, A.J.; Bock, C.E.; Armstrong, D.M. (January 2003). National Wind 

Technology Center Site Environmental Assessment: Bird and Bat Use and Fatalities – Final 

Report. University of Colorado, Boulder, Colorado. 

Science Applications International Corporation (2005). Wildlife Survey (Including Migratory 

Birds and Raptors) at the National Renewable Energy Laboratory South Table Mountain Site, 

Golden, Colorado. Lakewood, Colorado. 

U.S. Department of Energy (1993). Site wide Environmental Assessment for the National 

Renewable Energy Laboratory, Golden, Colorado. DOE/EA-0850. 

U.S. Department of Energy (1998). Environmental Assessment, Right-of-Way Easement For 

Public Service Company of Colorado at the South Table Mountain Site, Golden, Colorado. 

DOE/EA-1254. 

U.S. Department of Energy (2002). Site-Wide Environmental Assessment of National Renewable 

Energy Laboratory’s National Wind Technology Center. DOE/EA 1378.

U.S. Department of Energy (2003). Site-Wide Environmental Assessment of the National 

Renewable Energy Laboratory’s South Table Mountain Complex. DOE/EA 1440. 

U.S. Department of Energy (2007). Final Environmental Assessment of Three Site Development 

Projects at the National Renewable Energy Laboratory South Table Mountain Site. DOE/EA 

1573. 

U.S. Department of Energy, Golden Field Office (1999). National Renewable Energy 

Laboratory (NREL) Site Conservation Easement Baseline Inventory. Golden, Colorado. 
NREL Environmental Performance Report, 2008 Page 69

9 Appendices 

Appendix A – Summary of NREL Environmental Permits, Registrations, Notifications

Appendix B – Wildlife Species Observed on the STM Site
NREL Environmental Performance Report, 2008 Page 70

Appendix A – Summary of NREL Environmental Permits, Registrations, Notifications

Table 1. Summary of NREL Environmental Permits, Registrations, Notifications

Tracking 

Number 

Permit or 

Registration 

Number 

Permit or Reg. 

Holder 

Permit Type Permit Description Issuing 

Agency 

Name

Location 

Description 

Status/Expiration 

Date

Reporting 

Required 

Permits

1 04JE1442L DOE Air Air Emission Permit 

for Land 

Development 

(fugitive dust from 

construction 

activities)

Colorado 

Dept. of 

Public Health 

and 

Environment 

(CDPHE)

NWTC 01/31/2010 (originally 

issued 3/1/2000)

None

2 04JE1443L DOE Air Air Emission Permit 

for Land 

Development 

(fugitive dust from 

construction 

activities)

CDPHE STM 01/31/2010 (originally 

issued 3/1/2000)

None

7 37232 SERI Groundwater 

Monitoring Well

Permit to Construct 

a Well (MW-1)

Colo. Div. Of 

Water 

Resources

STM Construction complete;

permit number active 

until well is closed

None

8 37229 SERI Groundwater 

Monitoring Well

Permit to Construct 

a Well (MW-2)

Colo. Div. Of 

Water 

Resources

STM Construction complete;

permit number active 

until well is closed

None

9 37228 SERI Groundwater 

Monitoring Well

Permit to Construct 

a Well (MW-3)

Colo. Div. Of 

Water 

Resources

STM Construction complete;

permit number active 

until well is closed

None

10 37231 SERI Groundwater 

Monitoring Well

Permit to Construct 

a Well (MW-4)

Colo. Div. Of 

Water 

Resources

STM Construction complete;

permit number active 

until well is closed

None

11 37230 SERI Groundwater 

Monitoring Well

Permit to Construct 

a Well (MW-5)

Colo. Div. Of

Water 

Resources

STM Construction complete; 

permit number active 

until well is closed

None
NREL Environmental Performance Report, 2008 Page 71

Tracking 

Number 

Permit or 

Registration 

Number 

Permit or Reg. 

Holder 

Permit Type Permit Description Issuing 

Agency 

Name

Location 

Description 

Status/Expiration 

Date

Reporting 

Required 

12 214960

Closed

NREL/DOE Groundwater 

Monitoring Well

Permit to Construct 

a Well (MW-11)

Colo. Div. Of 

Water 

Resources

STM Well closed October 

12, 2006. Permit 

number was active until 

well closed

None

13 214961

Closed

NREL/DOE Groundwater 

Monitoring Well

Permit to Construct 

a Well (MW-10)

Colo. Div. Of 

Water 

Resources

STM Well closed October 

12, 2006. Permit 

number was active until 

well closed

None

14 214962

Closed

NREL/DOE Groundwater 

Monitoring Well

Permit to Construct 

a Well (MW-09)

Colo Div. Of 

Water 

Resources

STM Well closed October 

12, 2006. Permit 

number was active until 

well closed 

None

15 99JE0400 NREL/DOE Air TCPDU air 

emissions

CDPHE STM Initial approval issued 

7/20/2000

None

16 20070617

through 

20070623

NREL Permit Hazardous material 

storage and use 

permit

West Metro 

Fire 

Protection 

District

7 STM facilities 

(Bldg 16, WHF, 

SERF, S&TF, 

FTLB, AFUF,

S&R) 

July 2010 Annual fee, fire 

dept. inspection; 

new chemical 

inventory 

provided 

annually

17 P15-07-00003 NREL BioSafety 

Permit

Sugarcane Bagasse USDA -

APHIS

STM 02/06/2010 None

18 PDEP-07-

00222

NREL BioSafety 

Permit

Wheat Streams USDA -

APHIS

STM 02/01/2008 None

19 PDEP-06-

00178

NREL BioSafety 

Permit

Oryza sativa leaves 

and stems

USDA -

APHIS

STM 12/05/2007 None
NREL Environmental Performance Report, 2008 Page 72

Tracking

Number 

Permit or 

Registration 

Number 

Permit or 

Reg. 

Holder 

Permit Type Permit 

Description 

Issuing 

Agency 

Name

Location 

Description 

Status/Expiration 

Date

Reporting 

Required 

Notifications and 

Registrations 

20 PWSID Number 

CO0230860

DOE Drinking Water Non-community 

Supply of 

hauled water 

from a surface 

water source

CDPHE NWTC N/A Periodic 

chlorine 

residual; 

monthly 

Bacteriological; 

Periodic lead 

and copper 

monitoring

21 CO4890000017 DOE Hazardous Waste Notification of 

Regulated 

Waste Activity

CDPHE DWOP Update recommended 

every 3-5 years, or 

sooner if substantial 

changes in activity 

occur. Last update: 

7/97

Annual fee to 

Colorado 

Hazardous 

Waste 

Commission

22 CO3890090076 DOE Hazardous Waste Notification of 

Regulated 

Waste Activity

CDPHE STM Update recommended 

every 3-5 years, or 

sooner if substantial 

changes in activity 

occur. Last update: 

9/07

Annual fee to 

Colorado 

Hazardous 

Waste 

Commission

23 COD980805162 DOE Hazardous Waste Notification of 

Regulated 

Waste Activity

CDPHE JSF Update recommended 

every 3-5 years, or 

sooner if substantial 

changes in activity 

occur. Last update: 

7/97

None

24 COD983802448 DOE Hazardous Waste Notification of 

Regulated 

Waste Activity

CDPHE NWTC Update recommended 

every 3-5 years, or 

sooner if substantial 

changes in activity 

occur. Last update: 

7/97

None
NREL Environmental Performance Report, 2008 Page 73

Tracking 

Number 

Permit or 

Registration 

Number 

Permit or 

Reg. 

Holder 

Permit Type Permit 

Description 

Issuing 

Agency 

Name

Location 

Description 

Status/Expiration 

Date

Reporting 

Required 

25 COR000207563 DOE Hazardous Waste Notification of 

Regulated 

Waste Activity

CDPHE ReFUEL Issued Jan 9, 2004 None

26 001 and 002 DOE Air: Ozone 

Depleting 

Substances

Registration of 

stationary 

appliances (2 

SERF chillers)

CDPHE SERF Annual renewal due 

July 1

None

27 N/A DOE Air: Ozone 

Depleting 

Substances

Facility 

Notification

CDPHE STM, NWTC Annual notification and 

fee due December 1

28 001 DOE Air: Ozone 

Depleting 

Substances

Registration of 

stationary 

appliance 

(chiller in 

DWOP)

CDPHE DWOP Annual renewal due 

July 1

29 2873-001 and 

2873-002

DOE Above Ground 

Storage Tank

Registration of 

aboveground 

storage tanks

Colorado 

Dept. of Labor

STM--PDU 

Ethanol 

Storage Tank, 

SERF 

Emergency 

Generator 

Tank

Annual registration and 

fee, due April/May

None

30 93000378 DOE Historic 

Registration

National 

Register of 

Historic Places

National Park 

Service

Colorado 

Amphitheater

No expiration None

31 93000379 DOE Historic 

Registration

National 

Register of 

Historic Places

National Park 

Service

Ammunition 

Igloo

No expiration None

32 AFP-CO-00255 DOE Alcohol (not an 

environmental 

permit)

Alcohol 

Producer's 

Permit

Bureau of 

Alcohol, 

Tobacco, and 

Firearms

AFUF (PDU) Annual renewal due 

July 1

Annual report 

due Jan 30
NREL Environmental Performance Report, 2008 Page 74

Tracking 

Number 

Permit or 

Registration 

Number 

Permit or 

Reg. 

Holder 

Permit Type Permit 

Description 

Issuing 

Agency 

Name

Location 

Description 

Status/Expiration 

Date

Reporting 

Required 

33 TF-CO-0331 DOE Alcohol (not an 

environmental 

permit)

Industrial 

Alcohol User 

Permit

Bureau of 

Alcohol, 

Tobacco, and 

Firearms

NREL-wide Annual renewal due 

July 1

None

34 N/A NREL Transportation Hazardous 

Material 

Transportation

U.S. 

Department of 

Transportation

NREL-wide Annual renewal and 

fee

None

35 85936 NREL Registration X-Ray Machine 

Certification 

Report

CDPHE SERF November 2007 None

36 85938

NREL

Registration X-Ray Machine 

Certification 

Report

CDPHE SERF November 2007 None

37 92056 NREL Registration X-Ray Machine 

Certification 

Report

CDPHE SERF November 2008 None

38 85937 NREL Registration X-Ray Machine 

Certification 

Report

CDPHE SERF November 2007 None

39 COR10CY5F ASE Notice of Intent 

(NOI)

Stormwater 

Discharges 

Associated with 

Construction 

Activity Under 

and NPDES 

General Permit

EPA RSF June 30, 2010 None

 
NREL Environmental Performance Report, 2008 Page 75

Appendix B – Wildlife Species Observed at NREL’s STM Site

The following is a list of common and scientific names of wildlife species observed during 

wildlife surveys at the National Renewable Energy Laboratory’s South Table Mountain site in

Golden, Colorado. 

Table 2. Wildlife Species Observed at NREL’s STM Site

Common Name Scientific Name

Reptiles

Bull snake1 Pituophis catenifer

Plains garter snake Thamnophis radix

Six-lined racerunner Cnemidophorus sexlineatus

Tiger salamander Ambystoma tigrinum

Western rattlesnake Crotalus viridus

Birds

American crow Corvus brachyrhynchos

American kestrel Falco sparverius

American robin Turdus migratorius

American tree sparrow Spizella arborea

Barn swallow Hirundo rustica

Black-billed magpie Pica pica

Black-capped chickadee Poecile atricapilla

Black-crowned night heron Nycticorax nycticorax

Blue jay Cyanocitta cristata

Brewer's blackbird Euphagus cyanocephalus

Brown headed cowbird Molothrus ater

Bullock's oriole Icterus bullockii

California gull Larus californicus

Canada goose Branta canadensis

Common nighthawk Chordeiles minor

Common raven Corvus corax

Common snipe Gallinago gallinago

Cooper’s hawk Accipiter cooperii

Dark-eyed junco Junco hyemalis

Downy woodpecker Picoides pubescens

European starling Sturnus vulgaris

Flycatcher Empidonax sp.

Golden eagle Aquila chrysaetos

Great blue heron Ardea herodias

Horned lark1 Eremophila alpestris

House finch Carpodacus mexicanus

House sparrow Passer domesticus

Killdeer Charadrius vociferous

Lark bunting Calamospiza melanocorys

Loggerhead shrike Lanius ludovicianus

MacGillivray’s warbler Oporornis tolmiei

Mallard Anas platyrhynchos

Mountain bluebird Sialia currucoides

Mourning dove Zenaida macroura

Northern flicker Colaptes auratus

Northern harrier Circus cyaneus

Osprey Pandion haliaetus
NREL Environmental Performance Report, 2008 Page 76

Common Name Scientific Name

Prairie falcon Falco mexicanus

Red-breasted nuthatch Sitta canadensis

Red-tailed hawk Buteo jamaicensis

Red-winged blackbird Agelaius phoeniceus

Rock dove Columba livia

Rock wren Salpinctes obsoletus

Say's phoebe Sayornis saya

Sharp-shinned hawk Accipiter striatus

Spotted towhee Pipilo maculates

Swainson’s hawk Buteo swainsoni

Tree swallow Tachycineta bicolor

Turkey vulture Cathartes aura

Unidentified sparrow 1 -

Unidentified sparrow 2 -

Unidentified species -

Unidentified warbler -

Vesper sparrow Pooecetes gramineus

Western kingbird Tyrannus verticalis

Western meadowlark Sturnella neglecta

Western scrub jay Aphelocoma californica

White-crowned sparrow Zonotrichia leucophrys

Mammals

Black-tailed jackrabbit1 Lepus californicus

Bushy-tailed woodrat1 Neotoma cinerea

Coyote Canis latrans

Deer mouse Peromyscus maniculatus

Fox squirrel Sciurus niger

Long-tailed weasel Mustela frenata

Mexican woodrat Neotoma mexicana

Mountain cottontail Sylvilagus nuttalli

Mule deer Odocoileus hemionus

Prairie vole Microtus ochrogaster

Raccoon Procyon lotor

Red fox Vulpes vulpes

Western harvest mouse Reithrodontomys megalotis 

White-tailed jackrabbit Lepus townsendii

Yellow-bellied marmot1 Marmota flaviventris 1 Species observed during the 1987 survey, but not during the 2004-2005 surveys.
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National Renewable Energy Laboratory Environmental Performance 

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231.1 and 5400.5)

5a. CONTRACT NUMBER

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5b. GRANT NUMBER

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This report presents a summary of NREL’s environmental protection programs and activities for 2008. It is organized 

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how the program is managed in that area, any permitting or notification efforts that have been completed during the 

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