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

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

Environmental Performance Report 2011

Annual Site Environmental Report per the U.S. Department of Energy Order 231.1B
This report was prepared as an account of work sponsored by an agency of the United States government. Neither the United States government nor any agency thereof, nor 

any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, 

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

or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States 

government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States government or any 

agency thereof.

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

Cover Photo: Native, water efficient landscaping at the RSF.

Photo by Robb Williamson, NREL/PIX 20958
ENVIRONMENTAL PERFORMANCE REPORT 2011 1

This report requires a tremendous amount of data, 

collaboration, and review to be made possible. Thank you to 

all who contributed their time and effort to this publication.

NREL’s Environment, Health, and Safety Office staff provided 

their subject-matter expertise by authoring content, providing 

data, and conducting technical reviews:

Brenda Beatty • Genny Braus • Larry Durbin • John Eickhoff 

• Bob Fiehweg • Maureen Jordan • Tom Ryon • Kurt 

Schlomberg • Eric Schmitz.

Frank Rukavina and the Sustainable NREL team provided 

the report’s sustainability content. Grace Griego with NREL’s 

Communications team provided editing and project support.

Lori Gray, Robert Smith, and Amy Van Dercook, with the 

DOE Golden Field Office, worked closely with Alliance for 

Sustainable Energy, LLC (Alliance) staff to continuously 

improve the report and conducted the review and 

approval process. 

Acknowledgements Contact Us

We welcome your feedback and suggestions on this 

report and on NREL’s efforts toward sustainability and 

environmental stewardship. To provide comments, 

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

additional information about NREL’s environmental and 

sustainability programs, please contact:

Maureen Jordan, Director, EHS

maureen.jordan@nrel.gov

303-275-3248 

John Eickhoff, Environmental Manager

 john.eickhoff@nrel.gov

303-275-3217

Kerry Masson, Director, Public Affairs Office

kerry.masson@nrel.gov

303-275-4083

This report and reports from prior years are available 

online at:

www.nrel.gov/ehsq/environmental_protection.html 

National Renewable Energy Laboratory

15013 Denver West Parkway, Golden, CO 80401

303-275-3000

www.nrel.gov
2 ENVIRONMENTAL PERFORMANCE REPORT 2011

Nomenclature

ARRA—American Recovery and Reinvestment Act

AEO—Annual Energy Outlook

AFUF—Alternative Fuels User Facility

AFV—Alternative Fuel Vehicle

APCD— Air Pollution Control Division of CDPHE

APEN—Air Pollutant Emission Notice

ASHRAE—American Society of Heating, Refrigerating, and Air-Conditioning Engineers

AST—Aboveground Storage Tank

AWS—Alternative Work Schedule

BMP—Best Management Practice

CCR—Colorado Code of Regulations

CDLE—Colorado Department of Labor and Employment 

CDPHE—Colorado Department of Public Health and Environment

CELP—Colorado Environmental Leadership Program

CEQ—Council on Environmental Quality

CERC—Colorado Emergency Response Commission 

CESQG— Conditionally Exempt Small Quantity Generator 

CFR— Code of Federal Regulations 

CGP—Construction General Permit

CLOMR—Conditional Letter of Map Revision

CMS—Chemical Management System

CNHP—Colorado Natural Heritage Program

CO2—Carbon Dioxide

CO2e—Carbon Dioxide Equivalent

CRADA—Cooperative Research and Development Agreement

CSP—Concentrating Solar Power

CWA—Clean Water Act

CX—Categorical Exclusion

DFD—Denver Fire Department

DNR— Colorado Department of Natural Resources

DSOC—District Shops and Operations Center

DOE—U.S. Department of Energy

DOE GO—Department of Energy Golden Field Office 

DOE O—Department of Energy Order

DOPS—Division of Oil & Public Safety of the Colorado Dept. of Labor & Employment

DWOP—Denver West Office Park

DWP/DWMB—Denver West Parkway/Denver West Marriott Boulevard

EA—Environmental Assessment

EERE— DOE Office of Energy Efficiency and Renewable Energy

EHS—Environment, Health, and Safety 

EIA—Energy Information Administration

EIS—Environmental Impact Statement

EISA—Energy Independence and Security Act

EMS—Environmental Management System

EPA—Environmental Protection Agency

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

ERT—Emergency Response Team

ESA—Endangered Species Act

ESIF—Energy Systems Integration Facility

ESPC—Energy Savings Performance Contract 

EO—Executive Order

FEC—Federal Electronics Challenge

FIFRA—Federal Insecticide, Fungicide, and Rodenticide Act

FONSI—Finding of No Significant Impact

FOA—Funding Opportunity Announcement

FTLB—Field Test Laboratory Building 

FY—Fiscal Year

GHG—Greenhouse Gas

GP—Guiding Principles

GWP—Global Warming Potential

HAP—Hazardous Air Pollutant

HEPA—High-Efficiency Particulate Air

HMIS—Hazardous Materials Information System

HMWMD— Hazardous Materials and Waste Management Division of CDPHE

HP—Horsepower

IBRF—Integrated Biorefinery Research Facility

ILA—Industrial, Landscaping, and Agricultural

ISDS—Individual Sewage Disposal System

ISM—Integrated Safety Management

ISMS—Integrated Safety Management System 

ISO—International Organization for Standardization

JSF—Joyce Street Facility

kg—Kilogram

kW—Kilowatt 

LEED—Leadership in Energy and Environmental Design

LEPC—Local Emergency Planning Committee

LOMR—Letter of Map Revision

LOS—Level of Service

LQG—Large Quantity Generator 

MAP—Mitigation Action Plan

MBTA—Migratory Bird Treaty Act

MCL—Maximum Contaminant Level

MOU—Memorandum of Understanding

MMtC/Yr—Million Metric Tons of Carbon Per Year 

mrem—Millirem

MRR—Mandatory Reporting Rule

MSDS—Material Safety Data Sheet

MT—Metric Ton 

MW—Megawatt 

NAAQS—National Ambient Air Quality Standards

NEPA—National Environmental Policy Act

NHPA—National Historic Preservation Act 

NREL—National Renewable Energy Laboratory

NWTC—National Wind Technology Center

NESHAP—National Emission Standards for Hazardous Air Pollutants

NOI—Notice of Intent

NOX— Nitrogen Oxides

N2O—Nitrous Oxide

ODS—Ozone Depleting Substance

OPA—Oil Pollution Act

PEMP—Performance Evaluation and Measurement Plan

PM—Particulate Matter

PPA—Power Purchase Agreement

PPI—Pollution Prevention Initiative

PSD—Prevention of Significant Deterioration 

PUE—Power Usage Effectiveness

PV—Photovoltaic 

RCRA—Resource Conservation and Recovery Act

REC—Renewable Energy Certificate

ReFUEL—Renewable Fuels and Lubricants Laboratory 

RFA—Rocky Flats Alluvium

RFHP—Renewable Fuels Heat Plant 

RFP—Request for Proposal

RFS—Renewable Fuel Standard

RQ—Reportable Quantity

RSF—Research Support Facility

RTD—Regional Transportation District

SARA—Superfund Amendments and Reauthorization Act

SDWA—Safe Drinking Water Act

SERF—Solar Energy Research Facility

SERI—Solar Energy Research Institute

SF6—Sulfur Hexafluoride

SHPO—State Historic Preservation Officer

SITES—Sustainable Sites Initiative

SO2—Sulfur Dioxide

SPCC—Spill Prevention Control and Countermeasures

SQG—Small Quantity Generator

SRRL—Solar Radiation Research Laboratory 

SSP—Site Sustainability Plan

SSPP—Strategic Sustainability Performance Plan

S&TF—Science & Technology Facility

STM—South Table Mountain

SWPPP—Stormwater Pollution Prevention Plan

TDM—Transportation Demand Management

TESC—Threatened, Endangered or Species of Concern

TES—Thermal Energy Storage

TPQ—Threshold Planning Quantity

TTB— Alcohol & Tobacco Tax & Trade Bureau of the U.S. Department of the Treasury

USACE—U.S. Army Corps of Engineers 

USFWS—U.S. Fish and Wildlife Service

VOC—Volatile Organic Compound

WHF— Waste Handling Facility
ENVIRONMENTAL PERFORMANCE REPORT 2011 3

Table of Contents

NREL Environmental Performance Report 2011

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

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

Nomenclature...................................................................................................... 2

Executive Summary........................................................................................... 4

1 Introduction....................................................................................................11

1.1 Purpose ..................................................................................................11

1.2 Our Mission...........................................................................................11

1.3 Site Facility Description....................................................................12

1.4 Site Environmental Conditions/Features...................................15

2 Significant Activities in 2011.....................................................................15

2.1 Major and Minor Construction Projects.....................................16

2.2 Integrated Environmental Stewardship in Construction 

Management...............................................................................................17

3 Environmental Management System....................................................19

3.1 Environmental Management System Structure......................19

3.2 Performance Indicators and Progress.........................................21

3.3 Assessment and Improvement......................................................21

3.4 2011 Awards and Recognition.......................................................22

4 Sustainability..................................................................................................24

4.1 Site Sustainability Planning............................................................24

4.2 2011 SSPP Goal Performance.........................................................25

5 NREL’s Role in the Environment—Global and Local.........................27

5.1 Energy Policy Update........................................................................27

5.2 NREL Research Helping Meet Legislative Goals......................28

6 Compliance Summary.................................................................................30

7 Air Quality Protection..................................................................................40

8 Water Quality Protection............................................................................42

8.1 Drinking Water.....................................................................................42

8.2 Groundwater........................................................................................43

8.3 Surface Water.......................................................................................44

8.4 Wastewater ...........................................................................................46

9 Hazardous Materials and Waste Management ..................................48

9.1 Hazardous Materials Management..............................................48

9.2 Regulated Waste Management.....................................................50

9.3 Aboveground Storage Tank Management................................51

9.4 Spill Prevention and Response ......................................................52

9.5 Pollution Prevention..........................................................................54

9.6 Radiological Materials and Waste Management.....................55

10 National Environmental Policy Act (NEPA)........................................56

11 Natural and Cultural Resources Protection ......................................58

11.1 Wildlife Management.....................................................................58

11.2 Endangered Species and Species of Concern .......................62

11.3 Vegetation Management..............................................................63

11.4 Wetlands and Floodplains.............................................................68

11.5 Cultural Resources...........................................................................69

12 Conservation Easement Lands..............................................................71

13 Traffic Management ..................................................................................72

Appendix A Plant Communities at the STM and the NWTC .............75

Appendix B Wildlife Species Observed at the

STM and the NWTC..........................................................................................80
4 ENVIRONMENTAL PERFORMANCE REPORT 2011

Executive Summary

Purpose

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

environmental management activities for 2011 including information on environmental and sustainability performance, environmental compliance activities and status, and environmental 

protection programs, highlights, and successes. 

This report is prepared in accordance with the U.S. Department of 

Energy (DOE) Order 231.1B, Environment, Safety and Health Reporting, which was implemented to ensure that DOE receives timely, 

accurate information about events that have affected or could 

adversely affect the health, safety and security of the public or 

workers, the environment, or the operations of DOE facilities. 

Mission and Programs

NREL is the principal research laboratory for DOE’s Office of Energy 

Efficiency and Renewable Energy (EERE). The laboratory also 

conducts research for the Office of Science and the Office of Electricity Delivery and Energy Reliability. The laboratory is managed 

for EERE by the Alliance for Sustainable Energy, LLC, a partnership 

between the Battelle Memorial Institute and MRIGlobal.

NREL is the only national laboratory solely dedicated to advancing renewable energy and energy efficiency technologies from 

concept to commercial application. For 35 years, the laboratory’s 

innovations, analysis, and expertise have enabled the emergence 

of a U.S. clean energy industry and led to numerous success 

stories from across the laboratory. The laboratory’s 327-acre main 

campus at South Table Mountain (STM) in Golden, Colorado, is 

a living model of sustainable energy. The laboratory also operates the National Wind Technology Center (NWTC) on 305 acres 

located 13 miles north of its main campus.

NREL develops renewable energy and energy efficiency technologies and practices, advances related science and engineering, 

and transfers knowledge and innovations to address the nation’s 

energy and environmental goals. The laboratory’s research and 

development achievements have helped shape clean-energy 

alternatives for powering our homes and businesses, and the 

nation’s transportation infrastructure. NREL’s science and technology teams span the full spectrum of innovation, from fundamental 

science and market-relevant research to systems integration, and 

testing and validation. 

NREL’s areas of expertise include: 

■ Renewable Fuels—Biomass, hydrogen and fuel cells, and 

vehicle technologies

■ Renewable Electricity—Solar, wind, water, geothermal, smartgrid technology, and building technology and efficiency

■ Energy Science—Chemical and biosciences, scientific computing, and materials science

■ Strategic Energy Analysis—Technology, markets, public policy, 

security, and government programs

About NREL

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. NREL conducts research 

primarily for DOE EERE. 

Established in 1974, NREL began operating in 1977 as the 

Solar Energy Research Institute (SERI). It was designated 

a DOE national laboratory in September 1991 as NREL. 

Since October 2008, NREL has been operated by the 

Alliance for Sustainable Energy, LLC, a partnership 

between MRIGlobal and the Battelle Memorial Institute. 

The new operating contract has a five-year duration and 

is overseen by DOE’s Golden Field Office (DOE GO).

Entrance to NREL’s South Table Mountain campus. Photo by Dennis 

Schroeder, NREL/PIX 18298
ENVIRONMENTAL PERFORMANCE REPORT 2011 5

■ Commercialization and Technology Transfer—Sponsored 

research and development agreements and licenses with 

private industry to develop commercial products

■ Deployment—Information and tools to help communities, 

industry, and government select the most impactful technologies to reduce their fossil energy use.

Significant Activities in 2011

Several major construction projects were in progress this year at 

the STM and NWTC sites. To manage the extensive development 

currently underway the laboratory uses a design-build approach 

that partners NREL with design-build industry leaders. This 

approach incorporates rigorous project controls and earned-value 

methodologies to provide the laboratory with world-class, energyefficient, and sustainable facilities. These facilities are critical to 

conduct and support the energy research and development for 

our world’s energy future. Some of the major projects in progress 

or completed include:

■ The third wing of the Research Support Facility (RSF), an office 

building designed to house 800 employees, was completed 

in late 2011. The building produces as much energy as it 

consumes on-site, meets world-class energy and environmental design standards, and achieved the U.S. Green Building 

Council’s Leadership in Energy and Environmental Design 

(LEED) Platinum certification.

■ Construction of a new 1800 spot parking garage commenced 

and will meet the parking needs of the increased number of 

staff located at the STM site relocated from leased space at 

Denver West Office Park (DWOP).

■ A major expansion of the Integrated Biorefining Research Facility (IBRF), formerly the Alternative Fuels User Facility (AFUF), 

was completed that enhances the capabilities of the facility 

and adds more office space. The facility received LEED Gold 

certification.

■ A new south entrance to the STM campus commenced 

construction. The entrance includes a site entrance building 

designed to achieve LEED Platinum certification. Due to the 

relocation of staff from DWOP to the STM site, an increase 

in vehicle traffic to the site will occur. The new entrance is 

designed to improve traffic flow to the campus by redirecting much of the traffic from the current Denver West Parkway 

entrance when opened in 2012.

■ Construction commenced on the Energy Systems Integration 

Facility (ESIF). The 183,000 square foot (ft2) building will house 

about 200 researchers. ESIF is being designed to achieve LEED 

Gold certification and construction is expected to be completed in late 2012.

■ Construction of a detention basin was begun to improve 

stormwater management from STM site development.

Environmental and Sustainability

Performance

INTERNATIONAL ORGANIZATION FOR STANDARDIZATION (ISO) 14001 REGISTRATION DEMONSTRATES

 LEADERSHIP

In 2011, NREL achieved ISO 14001:2004 certification for its environmental management system (EMS) after receiving a rigorous thirdparty assessment through NSF-International Strategic Registrations. ISO 14001 is a globally recognized standard that defines the 

structure of an organization’s EMS to improve its environmental 

performance. The certification represents a major accomplishment 

and demonstrates the laboratory’s leadership in environmental 

stewardship. The laboratory’s EMS is integrated with its Integrated 

Safety Management System (ISMS).

Prestigious Environmental Sustainability Awards Received

The laboratory received several important recognitions in 2011 

for its environmental and sustainability accomplishments. The 

prestigious GreenGov Presidential Award was achieved for the RSF 

green data center. The GreenGov Presidential Award is a federal 

government award that celebrates extraordinary achievement in 

the pursuit of President Obama’s challenge to lead by example 

toward a clean energy economy. 

Two DOE EStar Awards were received for the laboratory’s overall 

sustainability planning and performance and for its waste reduction and laboratory-wide composting program. DOE EStar Awards 

highlight environmental sustainability projects and programs 

within the DOE complex that reduce environmental impacts, 

enhance site operations, reduce costs, and demonstrate excellence in pollution prevention and sustainable environmental 

stewardship. 

Assessments Identified Continual Improvement 

Opportunities

Several reviews were conducted during the year to determine 

conformance with internal procedures and with regulatory 

requirements. 

Registered

to ISO 14001
6 ENVIRONMENTAL PERFORMANCE REPORT 2011

2011 ENVIRONMENTAL OBJECTIVES AND RESULTS

Goal Type 2011 Objectives 2011 Results

PEMP Further ISM, which includes environmental 

stewardship, through the development of improved 

management systems. 

Reviewed processes and activities and initiated actions such as: 

• Achieved laboratory-wide ISO 14001 certification

• Initiated install of high-efficiency particulate air (HEPA) filtration on exhaust systems 

in a number of research facilities for purposes of controlling nano-material (very small 

particle) air emissions

• Completed wildlife and vegetation surveys

PEMP Transform environmental excellence into a 

sustainability strategy.

• Received two DOE EStar awards: Cradle to Cradle—Waste Management and Living 

Laboratory—Sustainable Campus

• Received the White House GreenGov award: Green Innovation

• Completed green janitorial contract

• Negotiated purchase of renewable energy certificates (RECs) from on-site wind 

turbines

• Hosted numerous community and DOE sustainability groups meetings and tours 

• The RSF achieved LEED Platinum and the IBRF expansion achieved LEED Gold.

CELP Demonstrate environmental leadership by attaining 

ISO 14001 registration for its EMS.

• Achieved laboratory-wide ISO 14001 certification.

CELP Reduce the impacts of employee commuting by 

reducing individual vehicle miles travelled and 

implementing a traffic mitigation plan for its STM 

campus. This will include alternative work schedules 

(AWSs) and telecommuting.

• The 2011 Commuter Survey indicates:

• 6% reduction in single occupant commute trips compared to 2007

• 19% of staff telecommute at least one day per week

• 25% of staff work AWSs.

• To date, traffic volume thresholds identified in the Traffic Mitigation Action Plan (MAP) 

have not been exceeded (see section 13 Traffic Management for more information).

• NREL offers incentives for employees to participate in alternative commuting options 

such as access to mass transit, vanpool discounts, preferred parking for carpool/

vanpool vehicles, rideshare coordination, and bicycle and pedestrian infrastructure 

(bicycle maintenance stations, bicycle parking, extension of sidewalks, etc.).

CELP The laboratory will support its long term goal of 

achieving a net-zero energy campus by seeking to 

reduce electricity use per square foot by 3% per 

year, starting with a 2008 baseline.

• In 2011, NREL exceeded its goal of 3% per year reduction in energy use per square 

foot, reducing energy use from 277 to 176 kBTU/ft2. The reduction was largely due 

to the RSF, which increased square footage with only a small increase in site energy 

consumption.

CELP The RSF at the STM campus will implement 

measures to seek certification in the Sustainable 

Sites Initiative (SITES)–Pilot Program on Landscaping 

Green Certification for Sustainable Landscaping. 

• The RSF’s landscaping features native Colorado plants and trees; landscaping walls 

built from stone repurposed from excavating the foundation of the RSF; pavers 

designed to infiltrate and enhance water quality for the area’s watershed; and, a drip 

irrigation system with multiple zones providing efficient use of water.

• NREL’s SITES participation is being expanded beyond the initial goal to certify RSF 

and will include two new major construction projects as well, the STM stormwater 

detention basin project and the new parking garage and south entrance.
ENVIRONMENTAL PERFORMANCE REPORT 2011 7

An internal compliance evaluation was conducted to verify 

compliance with environmental legal and other requirements 

applicable to the laboratory across a sampling of activities and 

programs. The review included compliance with federal, state, 

and local regulations and DOE requirements including permits, 

equipment and other registrations and certifications, and reports 

and notifications. The review also evaluated completion of requirements by environmental program area, including requirements 

for such activities as inspection, monitoring, training, certifications, etc. Program areas reviewed included Cultural Resources 

Protection, Drinking Water Quality, Endangered Species Act, EMS, 

Regulated Waste Management, National Environmental Policy 

Act (NEPA), Wetlands, and Wildlife Management. No actions were 

identified for follow up or correction. 

In addition to the internal compliance evaluation, an internal 

assessment of sixteen environmental management program 

areas was conducted to verify conformance with the ISO 14001 

standard and internal procedures, and identify opportunities for 

continual improvement. Interviews were conducted with program 

managers and document and records reviews were completed. 

Seven findings were made in the areas of document control and 

operational control and eleven opportunities for improvement 

were identified. The findings were related to documents not 

having version control and minor inaccuracies. The majority of the 

actions from this assessment have been completed and several 

remaining actions will be finalized in 2012.

To achieve ISO 14001 certification, the laboratory received a 

third-party certification assessment to confirm conformance with 

the standard. The assessment involved several rounds of review 

including a “desk audit” of EMS procedures and documentation, an 

“on-site readiness review” of the major elements of the management system, and a final audit conducted by a team of auditors 

involving site visits to all major facilities, interviews with staff at 

all levels of the organization, observation of processes in place, 

and review of documents and records. The extensive certification assessment resulted in several findings and opportunities for 

improvement. Corrective actions will address deficiencies in document version control and an internal procedure for identifying 

environmental aspects. All actions are expected to be completed 

in 2012.

Progress Toward Objectives and Targets

Each year, the laboratory sets measurable objectives and targets 

for environmental improvement through its internal Performance 

Evaluation and Measurement Plan (PEMP), Site Sustainability Plan 

(SSP), and for the Colorado Environmental Leadership Program 

(CELP). Progress through the course of the year on each of these 

goals is tracked using an online software tracking system and 

results are reported annually. Some examples of performance for 

2011 are shown in the Environmental Objectives and Results table 

on page 6.

ENVIRONMENTAL COMPLIANCE

NREL is subject to many federal, state, and local environmental 

laws and regulations, as well as executive orders, DOE orders, and 

memoranda of understanding with government agencies. The 

laboratory continued its excellent record of environmental compliance in 2011. 

■ No violation notices were received from any regulatory agency. 

■ All required permits were received or renewed, required 

registrations were completed, and required notifications and 

reports were submitted.

■ There were no spills or releases of any materials requiring 

reporting in 2011.

ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) 

NREL’s EMS implements a framework of policies, procedures, and 

programs that integrates environmental protection into daily work 

practices. Through the EMS, the laboratory commits to environmental stewardship, pollution prevention, compliance with 

environmental requirements, and continual improvement in environmental protection and sustainability performance. The EMS is 

structured based on a plan-do-check-feedback continual improvement framework depicted in the graphic and is implemented as 

part of an ISMS. Program highlights in 2011 include:

■ The EMS became ISO 14001:2004 certified.

■ Training was provided to staff regarding our commitments 

to the environment laid out in the environmental protection policy. Training and communication efforts included a 

20-minute online course incorporating videos, graphics, and 

quizzes; employee badge cards updated policy commitments; regular emails and intranet articles; and “road shows” 

presented to hundreds of employees across at least 12 internal 

organizations. 

Define Scope

Analyze

H

a

zards,

Perform Work

Develop Controls

Feedback &

Improvement

Environment

Quality Safety

Impacts

& Issues
8 ENVIRONMENTAL PERFORMANCE REPORT 2011

■ The laboratory’s environmental protection policy was simplified to clearly state our key commitments to environmental 

protection. The EMS procedures underwent a comprehensive 

review and revision. This thorough review clarified, streamlined, 

and improved the effectiveness of the EMS procedures.

■ The process used to identify potential environmental impacts 

from our activities was updated in 2011 to simplify and streamline management and communication.

SUSTAINABILITY

Sustainability is integral to both our research and operations 

and we are committed to demonstrating federal leadership in 

sustainability and continuously improving performance. Sustainable NREL, an interdisciplinary initiative involving staff from across 

the organization, fosters environmental and social responsibility, 

working to establish the laboratory as a global model for sustainability. Sustainable NREL is responsible for advocating for all executive orders, federal regulations, DOE orders, and goals related to 

sustainable facility operations. 

Each year, Sustainable NREL develops a SSP to report on steps 

taken to meet the national and DOE sustainability objectives and 

outline plans for the upcoming year. The laboratory has currently 

identified 20 objectives to enhance sustainability and continues to 

make significant progress toward these objectives. 

ENVIRONMENTAL MANAGEMENT PROGRAMS

The laboratory continues to meet or exceed compliance requirements and strives to make continual improvements in environmental management. Program highlights by major environmental 

media are provided below. A more complete discussion of the 

laboratory’s environmental management programs, including 

compliance information and achievements are included in this 

report. 

AIR QUALITY PROTECTION

The laboratory maintains several air permits issued by the Colorado Department of Public Health and Environment (CDPHE) for 

“minor” sources including one site-wide permit for particulate air 

emissions from construction, two air emissions permits for pilotscale research, one permit for the operation of the Renewable Fuel 

Heat Plant (RFHP), and five permits for emergency generators. An 

internal evaluation was conducted for compliance with Environmental Protection Agency (EPA) and state permitting and emissions control requirements which confirmed that the laboratory is 

in compliance with all Colorado and EPA requirements. 

The laboratory has three chillers that are larger than 100 horsepower (hp), contain ozone depleting substances (ODS), and 

are thus registered with CDPHE. During 2011, the laboratory 

performed the required annual notification that maintenance 

activities occur, renewed the registration for the three chillers, and 

confirmed that all technicians servicing ODS-containing equipment are EPA-certified.

Due to a switch from sand to a deicer product, no sand was 

applied for traction control to the laboratory’s roadways during 

the 2010 to 2011 winter season. This resulted in the reduction 

of 50 tons of sand used compared to the 2009 to 2010 season, 

providing a direct air quality benefit to both our neighbors and the 

Denver metro area by reducing particulate emissions. The required 

sanding report for the 2009-2010 season was supplied to the state.

The laboratory’s annual greenhouse gas (GHG) emissions inventory showed that emissions were below the exempt level for EPA 

reporting and permitting rules. In 2011, carbon dioxide equivalent 

(CO2e) emissions were 4,020 U.S. tons, or 3,555 metric tons (MT). 

The laboratory’s emissions of GHGs are not expected to meet 

reporting requirement thresholds into the foreseeable future.

WATER QUALITY PROTECTION

NREL operates a drinking water distribution system at the NWTC, 

serving about 150 employees. Drinking water is purchased from 

local municipalities and transported by truck to the site. The 

drinking water system is subject to regulatory requirements to 

monitor for specific parameters. In 2011, all monitored parameters 

met applicable requirements and triennial sampling for lead and 

copper confirmed that the concentration of these metals was well 

below regulatory thresholds.

The laboratory seeks to preserve the quality of receiving waters 

to which the STM and NWTC campuses discharge stormwater. 

Water quality protection is accomplished through management 

of runoff emanating from active construction sites, inclusion of 

project design elements that promote infiltration and detention, 

and management of campus areas not under construction to 

minimize erosion and support infiltration. In 2011, several projects 

supported these goals:

■ Completed the STM stormwater detention basin to a point 

where it can now temporarily detain a significant portion of 

the runoff from the site, thus greatly improving the quality and 

quantity of runoff leaving the STM campus, and helping to 

protect downstream areas from potential flooding. The project 

will be completed in 2012. 

■ Completed modifications to Denver West Parkway at STM to 

redirect accumulated runoff in the roadway toward drainage 

conveyance swales.

■ Completed addition of curb and gutter along the north side 

of the STM Field Test Laboratory Building (FTLB) Service Road 

which will reduce sediment entrainment in runoff originating 

from adjacent areas.

■ All projects, regardless of acreage, draw upon low impact 

design elements such as porous pavement and vegetated 

bioswales to improve stormwater detention.

■ Seven construction projects at STM, and three at the NWTC, 

required coverage under the EPA Construction General Permit 

(CGP). Permit coverage was obtained or was continued for 
ENVIRONMENTAL PERFORMANCE REPORT 2011 9

each. Three permits for completed projects were terminated 

in 2011. All activities were conducted according to compliance requirements. Several construction sites received periodic 

monitoring from local regulatory officials; no non-compliances 

were noted.

HAZARDOUS MATERIALS AND WASTE MANAGEMENT 

As a major national laboratory, NREL has a variety of chemicals 

and materials, some of which are hazardous, for use in research 

activities. Hazardous materials are stored, used, and managed in 

a manner that is protective of laboratory personnel, the general 

public, and the environment.

NREL facilities are subject to the emergency reporting provision 

of the Emergency Planning and Community Right-to-Know Act 

(EPCRA) and in 2011 the laboratory submitted the required Tier 

II report to CDPHE for reporting year 2010, identifying diesel fuel, 

petroleum oil and sulfuric acid in lead-acid batteries. West Metro 

Fire Rescue conducted an annual hazardous material inspection 

and issued permits for all major research facilities on the STM 

campus. The inventory of materials at the Renewable Fuels and 

Lubricants Research Laboratory (ReFUEL) facility was provided to 

the Denver Fire Department. There were no releases of hazardous 

materials requiring reporting.

NREL maintains unique EPA Hazardous Waste Generator Identification numbers for each of its five facilities: STM, DWOP, NWTC, Joyce 

Street Facility (JSF), and ReFUEL. In accordance with state and 

federal regulations, annual hazardous waste generator notifications were made and applicable fees paid to the state based on 

monthly volumes of hazardous waste generated at each facility. Due to three calendar months of episodic hazardous waste 

generation at volumes totaling more than 1,000 kilograms (kg) 

per month and in anticipation of additional pilot plant research 

experiments, the waste generator status of STM changed to Large 

Quantity Generator in October 2011. The remaining facilities are 

categorized as Conditionally Exempt Small Quantity Generators.

The laboratory seeks to minimize the risk of underground soil and 

water contamination from storage tanks by utilizing only aboveground storage tanks (ASTs). Unlike underground tanks, aboveground installations provide access for regular visual leak inspections and allow for less costly repair and cleanup should that be 

necessary. In 2011, no spills or releases from ASTs or related fueling 

activities occurred and AST registrations were submitted to the 

state for two registered ASTs. All tanks were reviewed to confirm 

adherence to recently revised regulations. AST and spill prevention and response training was provided to all personnel identified 

as having responsibility for operating and fueling ASTs and those 

providing initial spill response. 

The laboratory seeks to prepare for and continually improve spill 

response. Formal spill prevention, control, and countermeasures 

(SPCC) plans have been developed for three facilities. The plans 

are designed to minimize the number and size of spills from oilcontaining equipment and reduce response and cleanup time. In 

2011, the laboratory’s SPCC plans were revised to address changes 

to EPA SPCC regulations and Colorado’s AST regulations. No spills 

requiring reporting occurred in 2011. Staff responded to 31 minor 

spills of diesel or hydraulic fluids at the STM and two at the NWTC; 

the size of spills ranged from less than 0.1 gallon to 15 gallons. 

Each spill was cleaned up promptly and did not result in any 

significant impact to the environment. 

NREL actively seeks opportunities to prevent pollution, going 

above and beyond compliance requirements to reduce potential 

impacts to our environment. The laboratory has made a formal 

commitment to pollution prevention through its laboratory-wide 

environmental protection policy. In 2011, three pollution prevention assessments were completed and the results are being evaluated for possible implementation. Sustainable NREL initiated a 

pilot Pollution Prevention Initiative (PPI), which provided staff with 

the opportunity to identify and implement new pollution prevention practices at the laboratory. Project proposals were submitted 

by staff to help achieve reductions in waste, materials, water, air 

emissions, and energy use. Three projects were funded including 

an idling reduction campaign, a research pump replacement, and 

a switch from hardcopy to electronic journals for a collection at 

NREL’s library.

Unlike many DOE facilities, NREL does not conduct work involving 

nuclear materials and does not have legacy radiological contamination issues associated with past nuclear weapons production 

or research activities. However, the laboratory uses several x-ray 

diffraction analytical techniques and occasionally uses small quantities of radioisotopes for biological labeling in research. All materials used have very low activity levels and are used in extremely 

small amounts. In 2011, the estimated effective dose equivalent 

to the public from laboratory activities was 0.0054 mrem (millirem) per year, far below the 10 mrem per year regulatory limit. No 

low-level radioactive waste was generated. No radionuclides were 

released from the site for the reporting period.

NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)

NREL’s NEPA program provides a mechanism to consider environmental factors in the decision-making process and promotes 

sustainable and environmentally responsible operations. Staff 

members conduct reviews under the NEPA process for a wide 

range of activities prior to work commencing. Five hundred and 

fifteen NEPA reviews were conducted for project activities on 

and off site during 2011. Of these, 30 activities underwent a more 

in-depth environmental review given their potential to cause an 

environmental impact. For each of these, work commenced only 

after DOE reviewed the submittal and provided a signed NEPA 

determination which specified any mitigation actions needed 

to avoid impacts. Two projects were determined to require an 

Environmental Assessment (EA). The laboratory initiated a Supplemental EA to address a proposed action for enhancements to the 

RFHP and a site-wide EA was initiated for proposed continued and 

enhanced operations at the NWTC.
10 ENVIRONMENTAL PERFORMANCE REPORT 2011

NATURAL AND CULTURAL RESOURCES PROTECTION 

NREL is committed to responsible stewardship of our natural 

ecosystems, native wildlife and vegetation, and important cultural 

resources. Natural resources at the STM and NWTC sites are 

managed appropriately to ensure research needs are met while 

protecting wildlife and vegetation. During 2011, STM and NWTC 

site-wide wildlife surveys, avian and bat mortality surveys, and 

vegetation surveys were completed. These surveys enable staff to 

compare current conditions to those found in previous studies, 

establish environmental conditions for future NEPA EAs, and make 

informed wildlife and vegetation management decisions. No 

protected species have been identified on-site. 

A Migratory Bird Conservation Plan was developed to provide 

guidance for specific types of projects that have the potential to 

impact migratory birds and provide best management practices 

to eliminate or minimize impacts for identified risk areas including 

disturbance of vegetation, building maintenance, and collisions with buildings, windows, meteorological towers, and wind 

turbines. Bird-friendly glass was installed on the laboratory’s new 

STM parking garage, which is scheduled to open in 2012. The glass 

in this structure is patterned with a 50% frit that appears etched 

but still allows for visibility. This special glass was installed on all 

glass breeze-ways and critical areas of glass stairwells to reduce 

the potential for bird collisions, lessening impacts on migratory 

birds. 

NREL’s approach to vegetation management is to:

■ Conserve existing ecosystems

■ Replace disturbed vegetation with native species

■ Prevent the spread of noxious weeds and implement measures 

to control these species

■ Develop and maintain sustainable landscaping. 

Based on lessons learned from previous revegetation efforts, 

landscaping plans for current construction projects were adjusted 

to optimize plant establishment, withstand difficult shading and 

snow conditions, and deter animal browsing while providing 

wildlife habitat. Weeds were treated on approximately 200 acres at 

the NWTC and two acres at the STM.

Wetlands adjacent to Lena Gulch that were impacted by the 

construction of a new south entrance to the STM campus were 

delineated in 2011. Bridge construction activities associated 

with the project resulted in the permanent loss of 0.25 acres 

of wetlands along Lena Gulch. A U.S. Army Corps of Engineers 

(USACE) Nationwide Permit No. 14 for Linear Transportation Projects was obtained, and this loss was mitigated through acquisition 

of wetland banking credits through the South Platte Wetlands 

Bank in Brighton, Colorado. A Conditional Letter of Map Revision 

(CLOMR) was filed with Jefferson County with Urban Drainage and 

Flood Control District concurrence for the bridge construction 

since a number of bridge elements such as abutments and headwalls would be in the floodplain. With Urban Drainage and Flood 

Control District approval, a Jefferson County Floodplain Development permit was obtained for the new bridge.

 Three historic structures at STM are recognized as significant 

cultural resources and are listed on the National Register of 

Historic Places. These 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. The three structures were built during 

the Works Progress Administration era in the 1930s. The Camp 

George West Historic District, also listed on the National Register of 

Historic Places, includes the 25-acre parcel of the STM site south of 

Denver West Parkway. Two types of contributing historic archaeological resources have been identified on this parcel: firing range 

lines and a low rock wall. In 2011, the Colorado State Historic 

Preservation Officer (SHPO) concurred that construction of the 

south entrance to the STM would impact two firing lines that are 

contributing features of the Camp George West Historic District 

and that impacts should be mitigated. A memorandum of agreement was signed to mitigate impacts to these features and an 

interpretive sign will be placed in Pleasant View Community Park. 

TRAFFIC MANAGEMENT

The STM campus draws hundreds of commuter vehicles daily, as 

well as visitor and delivery traffic coming to and leaving the site. 

As the laboratory continues to relocate staff to STM from leased 

space, traffic in the area is expected to increase. A Mitigation 

Action Plan (MAP) addresses potential environmental impacts 

from changes in traffic at STM and supports an EA Finding of No 

Significant Impact for several projects at the laboratory. The MAP 

specifies the methods for implementing mitigation measures to 

ensure that the impacts of continued and expanded laboratory 

operations are not significant. The laboratory seeks to reduce traffic using such measures as:

■ Mass transit, ridesharing (carpool and vanpool), and bicycling

■ Telecommuting one or more days per week

■ Flexible work schedules and AWSs

■ Teleconferencing, video conferencing, and web-conferencing.

During 2011, 25% of staff daily commute trips were made with 

alternative transportation, up 8% from 2007. The laboratory 

measured traffic counts during 2011 and found that while traffic increased at monitored locations, MAP thresholds were not 

exceeded.
ENVIRONMENTAL PERFORMANCE REPORT 2011 11

1.1 PURPOSE 

This report presents a summary of NREL’s 2011 environmental 

management activities including: 

■ Environmental protection programs

■ Environmental and sustainability performance

■ Environmental compliance activities and status with respect 

to requirements that are applicable to NREL such as required 

permitting, notification, and monitoring 

■ Environmental management highlights and successes. 

This report incorporates DOE’s most recent guidelines for the 

Annual Site Environmental Report, as required by DOE Order (DOE 

O) 231.1B, Environment, Safety, and Health Reporting. 

1.2 OUR MISSION 

NREL’s mission is focused on advancing DOE’s and our nation’s 

energy goals. This focus is captured in the mission statement: 

NREL develops renewable energy and energy efficiency technologies and practices, advances related science and engineering, 

and transfers knowledge and innovations to address the nation’s 

energy and environmental goals. 

NREL fulfills its mission through technology portfolios. A brief 

description of each major technology area follows. 

■ Basic science. Fundamental research is conducted in the 

sciences that underlie NREL’s renewable energy and energy 

efficient technologies. 

■ Bioenergy. NREL currently has major programs in biomassderived 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, 

cost-effective, environmentally acceptable building equipment 

and envelope systems. 

■ 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 renewable and energy efficiency technologies in distributed power 

systems, thus maximizing the utilization of renewable energy 

and energy efficient 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. 

A researcher collecting algae samples. Photo by Dennis Schroeder, NREL/

PIX 18297

Jr. Solar Sprint and Hydrogen Fuel Cell Car Competition. Photo by Dennis 

Schroeder, NREL/PIX 19196

NREL creates fuel from renewable energy to power hydrogen fuel cell 

vehicles and buses. Photo by Chris Ainscough, NREL/PIX 19512

1 Introduction
12 ENVIRONMENTAL PERFORMANCE REPORT 2011

■ 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 laboratories and facilities 

allow state-of-the-art testing on photovoltaic (PV) cells, building technologies, and wind turbines. 

■ PV. PV enables 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 experts 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 NWTC, NREL develops, improves, 

and demonstrates the viability of wind technology for electricity generation and facilitates its utilization throughout the 

world.

1.3 SITE AND FACILITY DESCRIPTION 

NREL facilities occupy five separate locations in Jefferson County, 

Colorado, near the city of Denver, and one within the boundaries 

of the City and County of Denver. These include:

■ Denver West Office Park (DWOP)

■ Golden Hill

■ South Table Mountain (STM)

■ Joyce Street Facility (JSF)

■ National Wind Technology Center (NWTC)

■ ReFUEL (located within the city limits of Denver).

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. DWOP is leased space 

used primarily for administrative functions and limited research 

activities. Similarly, Golden Hill is leased office space for administrative functions. The JSF is leased space currently used for storage. 

The ReFUEL facility is a leased facility that consists of a small shop 

complex housed within the Regional Transportation District (RTD) 

District Shops and Operations Center (DSOC) facility in Denver. 

Laboratory staff also conduct work at additional locations as 

needed, for example at the Solar Technology Acceleration Center 

(SolarTAC) described below.

SOUTH TABLE MOUNTAIN (STM) SITE 

The STM site is the main research center for NREL. With new office 

facilities now occupied in 2011, roughly 78% of the laboratory’s 

staff have their offices and laboratories at the STM site. The STM 

site is approximately two miles (3.2 km) east of Golden and 12 

miles (19.3 km) west of central Denver.

Geology, Soils, and Hydrogeology 

The 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 492 feet (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 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 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 

NREL’s STM campus. Photo by Dennis Schroeder, NREL/PIX 19095
ENVIRONMENTAL PERFORMANCE REPORT 2011 13

side slopes of 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. 

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 drainageways 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. 

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 drainages lacking active channels as 

well as drainages with associated wetlands. Field surveys have 

identified limited wetland and riparian areas along drainages. 

The wetland communities identified on the STM 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. A vegetation survey of the STM campus was 

conducted in 2010 (see section 11.3 Vegetation Management for 

more information).

Wildlife 

Several comprehensive wildlife surveys have been conducted on 

the site, starting with the original study in 1987. Additional surveys 

were done in 1999, 2005, and 2011 (see section 11.1 Wildlife 

Management for more information). 

Mammals seen using the site during the surveys included mule 

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

striped and spotted skunks, badgers, bobcats, mountain lions, 

rabbits, yellow-bellied marmots, and various smaller mammals. 

More than 50 species of birds have been recorded on the STM 

site by the formal wildlife surveys and supplemental employee 

observations. A number of raptor species have been recorded at 

or above the STM site, especially during spring migration. Two 

raptor species are resident at the site: American kestrel (Falco 

sparverius) and red-tailed hawks (Buteo jamaicensis). Reptiles and 

amphibians inhabit the area as well. Most notably, the western 

diamondbacked rattlesnake is routinely encountered around the 

campus area. 

Land Use 

The STM site is a 327-acre area predominantly bordered by open 

space, a residential area, grassland zoned for recreation and lightcommercial activity. Portions of the community of Pleasant View 

are located immediately to the south and west 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 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 

(see section 12 Conservation Easement Lands for more detail).

NATIONAL WIND TECHNOLOGY CENTER (NWTC) 

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

just east of the foothills of the Rocky Mountains, the NWTC has 

abundant wind resources that are critical for the variety of projects 

conducted at the site. The NWTC is located near the intersection 

of Highways 93 and 128, between Boulder and Golden, and is 

approximately 15 miles (24.2 km) north of the STM site.

Geology, Soils, and Hydrogeology 

The 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 

 Wildlife at an NREL PV installation. Photo by Dennis Schroeder, NREL/PIX 

19912
14 ENVIRONMENTAL PERFORMANCE REPORT 2011

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.1

The NWTC has a strongly developed soil defined as a very cobbly, 

sandy loam. The soil is characterized by a large amount of cobble 

and gravel in the soil volume, and subsoil dominated by clay. 

Surface Water 

The area surrounding the NWTC 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. 

Vegetation 

The NWTC is located in the transition area between the Great 

Plains and the Rocky Mountains2. This location results in a flora that 

contains elements from both mountain and prairie ecosystems, 

and associations that represent residual tall grass prairie, shortgrass plains, ponderosa pine woodland, and foothill ravine flora2

. 

Vegetation surveys conducted at the site have identified nearly 

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. The most recent 

vegetation survey was completed in 2011 (see section 11.3 

Vegetation Management for more detail).

Wildlife 

Prior to 1975, livestock heavily grazed the NWTC site, damaging 

a majority of the native vegetation. DOE prepared a biological 

characterization inventory in 1992 for the entire Rocky Flats plant 

including the NWTC site, which was part of the no activity buffer 

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

and mountain lions were identified. Other mammals known to 

feed at the site are mule deer, coyotes, desert cottontail rabbits, 

white-tailed jackrabbits, black-tailed jackrabbits, deer mice, prairie 

voles, and thirteen-lined ground squirrels. Approximately 20 

different species of birds were sighted at or near the site. Raptor 

surveys were conducted at the NWTC in 1994 and 1995, and 

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

avian survey was also completed in 2002 and updated in 2011 (see 

section 11.1 Wildlife Management for more information). Although 

seldom seen, rattlesnakes, bull snakes, racers, and several other 

reptilian and amphibian species are known to occupy the area. 

Land Use 

The NWTC facility occupies a 305-acre area surrounded largely 

by open space and grazing land. The Rocky Flats National Wildlife 

Refuge borders the NWTC to the southeast, and a sand and gravel 

mining and processing operation is located along the southern 

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

small installation along the western site boundary. State Highway 

128 borders the NWTC to the north. Boulder County Open Space 

lies to the north of the highway.

DENVER WEST OFFICE PARK (DWOP) AND GOLDEN HILL

DWOP is approximately two miles (3.2 km) east of Golden and 12 

miles (19.3 km) west of central Denver. 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 

DWOP are approximately located in the geographic center of the 

development, with the exception of one leased facility just north 

of I-70. DWOP is bordered on the south by commercial areas (West 

Colfax strip), and on the west by the Pleasant View residential area, 

Camp George West facility, and the STM site. DWOP is within the 

City of Lakewood. Golden Hill is an office building on the south 

side of West Colfax about one half mile east of DWOP. A small 

portion of the building is leased for office space.

JOYCE STREET FACILITY (JSF) 

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 laboratory research activities are currently 

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

JSF is located at 6800 Joyce Street, about 5.5 miles (8.9 km) north 

of DWOP and STM sites.

Aerial view of the NWTC. Photo by Dennis Schroeder, NREL/PIX 19016

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

2 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, Colorado.
ENVIRONMENTAL PERFORMANCE REPORT 2011 15

RENEWABLE FUELS AND LUBRICANTS LABORATORY 

(ReFUEL) 

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. 

ReFUEL is a small shop complex housed within the RTD DSOC 

at 1900 31st Street, Denver, about 12 miles east of the STM and 

DWOP sites. 

The RTD DSOC facility occupies approximately 22 acres of land 

and serves as the primary maintenance facility for RTD’s bus and 

lightrail 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 southern, eastern, and northeastern borders. 

ADDITIONAL LOCATIONS 

Laboratory staff may also conduct work at additional locations as 

needed. One such location is SolarTAC, operated by MRIGlobal, 

located near Denver International Airport northeast of the intersection of East 26th Avenue and North Hudson Road in Aurora, 

Colorado. SolarTAC is a partnership of solar equipment manufacturers, research organizations and electric utilities that want to 

make use of a real-world outdoor site to develop, test, validate 

or showcase solar products. Approximately 33 miles east of the 

STM campus, the facility is comprised of 74 acres to provide users 

with readily accessible land and all the necessary infrastructure 

and resources needed to rapidly and economically install their 

technologies. NREL currently leases several acres at the site. The 

primary projects currently being developed by NREL include:

■ Concentrator PV (CPV) Demonstration. This system will demonstrate and quantitatively compare performance of CPV systems 

installed in Japan and the U.S.

■ Thermal Energy Storage (TES) Test Facility. This facility will 

provide a pilot scale TES demonstration project. 

1.4 SITE ENVIRONMENTAL CONDITIONS/FEATURES 

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 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 to10 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 and season to 

season.

In 2011, the most visible activity on the STM and NWTC campuses 

was construction. Several major and minor construction projects 

were underway throughout the year. From concept to design to 

occupancy, environmental stewardship is integrated into 

Aerial view of the SolarTAC test facility in Aurora, CO. Photo by Dennis 

Schroeder, NREL/PIX 19101

2 Significant Activities in 2011

 King County Metro Transit bus being tested at ReFUEL. Photo by John 

Ireland, NREL/PIX 17948
16 ENVIRONMENTAL PERFORMANCE REPORT 2011

construction project management to deliver world-class energy 

performance and environmentally sensitive and sustainable 

buildings. 

2.1 MAJOR AND MINOR CONSTRUCTION PROJECTS

■ At the STM campus, the third wing of the RSF was completed 

in late 2011. The RSF achieved the U.S. Green Building Council’s 

LEED Platinum certification, indicating that the building meets 

world-class energy and environmental design standards. 

The RSF is a 222,000 ft2building constructed to house 800 

employees and designed and managed to be highly energy 

efficient and consume only as much energy as can be generated by renewable power on or near the building. The RSF 

showcases numerous high-performance design features, many 

of which are a direct result of NREL’s research efforts, including 

passive energy strategies and renewable energy technology. 

With the completion of the third wing, NREL has vacated nearly 

all of its leased space in DWOP.

■ To meet the parking needs of the increased number of staff 

located at the STM site, construction of a new 1800 spot 

parking garage commenced in 2011 and will be completed in 

early 2012.

■ A major expansion of the IBRF was completed to enhance the 

capabilities of the facility and add more office space. The IBRF 

received LEED Gold certification. 

■ A new south entrance to the STM campus, including a 

site entrance building designed to achieve LEED Platinum 

certification, commenced construction. Due to the relocation 

of staff from DWOP to the STM site, an increase in vehicle traffic 

to the site will occur. The new entrance is designed to improve 

traffic flow to the campus by redirecting much of the traffic 

from the current Denver West Parkway entrance when opened 

in 2012.

■ Construction commenced on the ESIF. The building will be 

about 183,000 ft2 and will house about 200 researchers. ESIF 

is being designed to achieve LEED Gold certification and 

construction is expected to be completed in late 2012. The 

building will support: 

● High performance computing at the one-half petaflop 

scale

 The RSF showcases numerous high-performance design features. 

Photo by Dennis Schroeder, NREL/PIX 18477

Map of STM main facilities
ENVIRONMENTAL PERFORMANCE REPORT 2011 17

● State-of-the-art electric systems simulation and 

visualization

● Component and systems testing at MW-scale power

● Integration of functioning systems with utility system simulations for real-time, real-power evaluation.

■ Construction of a stormwater detention basin was begun to 

improve stormwater management from STM site development.

Additional smaller projects completed or underway included: 

■ Infrastructure improvements including a new guard building 

at the west gate, sidewalk and curb and gutter improvements, 

and expansion of a multi-building shared heating and cooling 

system.

■ Constructed the Vehicle Testing and Integration Facility used 

by engineers to develop strategies to meet the demands of 

electric vehicle-grid integration and minimize fuel consumption related to vehicle climate control. 

■ The SRRL was expanded to add office and research space on 

the mesa top at STM.

■ A geothermal system was installed to supplement mesa top 

facility heating and cooling systems. 

■ Stormwater enhancements were made along roadways to 

improve drainage and reduce potential for erosion.

■ FTLB Central Plant upgrades included six high efficiency 

condensing boilers and a variable speed 450 ton chiller. 

■ PV-covered visitor parking was constructed for the RSF. 

■ Construction of a cafeteria at the STM campus was initiated.

■ The NWTC Dynamometer facility was expanded to allow for 

enhanced research and testing.

■ NWTC pedestrian safety modifications and infrastructure 

improvements were completed including installation of handrails from trailers and parking areas for use during high winds, a 

walkway enclosure to shelter staff from high winds, additional 

parking for 50 vehicles, a bus pullout to provide a designated 

loading and unloading area, and improved outdoor lighting.

2.2 INTEGRATED ENVIRONMENTAL STEWARDSHIP IN 

CONSTRUCTION MANAGEMENT

NREL designs and builds new facilities using an approach that 

integrates planning, design, and construction. An interdisciplinary team collaborates on each project beginning with planning 

and selection of design and continuing through construction. 

This integrated approach allows the laboratory to achieve mission 

needs while addressing environmental, health, safety, and 

community considerations. 

PROJECT PLANNING AND DESIGN

Environmental management staff participate in an interdisciplinary team from a project’s initiation and continuing through 

construction. These staff assist with the development and review 

of Requests for Qualifications and Requests for Proposals (RFPs), 

facilitate the inclusion of environmental requirements into project 

designs, and monitor proposed changes throughout the project 

to confirm potential environmental impacts are considered. Some 

examples of sustainable design features used in recent projects 

include:

■ Producing energy on-site. New construction is designed to 

take advantage of the sun’s rays by using angled roofs and 

awnings that can support PV panels in optimal conditions. The 

RSF was designed to be a net-zero energy building, using only 

energy produced on-site. To help the RSF achieve the goal to 

produce as much energy on-site as used by the building, a 1.6 

megawatt (MW) PV system is being installed on the building 

and adjacent covered parking areas. The roof system incorporates more than 1,800 panels. A power purchase agreement 

(PPA) with Sun Edison and Xcel Energy will absorb the upfront 

installation costs.

■ Heating and cooling strategies. Passive design allows buildings 

to stay cool in summer and warm in winter. Radiant heating 

and cooling use water as the cooling and heating medium 

instead of forced air. For example, 42 miles of piping courses 

through the RSF carrying water for radiant heating and cooling. 

NREL takes an integrated approach to planning, design and 

construction. Photo by Ben Kroposki, NREL/PIX 16598

 The ESIF laboratory under construction. Photo by Dennis Schroeder, 

NREL/PIX 20047
18 ENVIRONMENTAL PERFORMANCE REPORT 2011

Waste energy from the data center is reused to maximize building heating. Evaporative cooling systems supplement passive 

cooling. 

■ Underfloor ventilation. Demand-controlled, dedicated 

outside air systems provide fresh air supplied via a raised floor 

distribution system. 

■ Occupant controlled windows. Operable windows help reduce 

the use of air conditioning and give employees considerable 

control over their own comfort. When outdoor air conditions 

are temperate, employees are notified by automated systems 

on their computers that it’s okay to open windows. Building 

control systems automatically operate remaining windows 

when optimum conditions are met.

■ No and low VOC materials. Only products that produce no, or 

low, amounts of volatile organic compounds (VOCs) are used 

in building interiors to maintain excellent air quality for occupants. Because employees spend most of their working hours 

indoors, the quality of indoor air is important for employee 

health and well being. To ensure that no, and low, VOC products are used, products are selected from reputable, certified 

product label systems such as Green Seal, EcoLogo, and EPA’s 

WaterSense program.

■ Daylighting and lighting management. NREL strives to design 

buildings that utilize natural lighting to the extreme, resulting 

in tremendous energy savings, as well as health and wellness 

benefits for occupants. External lighting using timers, motionsensors, and downward-facing, covered lights also minimizes 

light pollution impacts on neighbors.

■ Wildlife-friendly design. Selection of wildlife-sensitive features 

helps to minimize the impacts of buildings to birds and other 

animals. For example, the parking garage atrium, stair towers, 

and bus shelters have glass with specialized glazing designed 

to prevent bird collisions. Wildlife-friendly perimeter fencing 

was selected to allow wildlife to travel freely across property 

boundaries. Campus development carefully considers wildlife 

movement patterns and seeks to preserve existing travel zones.

■ Site-sensitive drainage and vegetation. Design teams incorporate low impact design elements to retain stormwater on-site 

through infiltration. Features such as bio-swales, vegetated 

filters, and porous pavers and asphalt encourage stormwater 

and snowmelt to seep into the soil instead of running off. 

Native and drought-resistant vegetation and a smart irrigation system automatically adjust landscape watering based on 

plant needs and daily local weather conditions. Native plants 

are used because they are adapted to the local climate, can 

thrive without additional watering once established, and are 

beneficial to other native species.

ENVIRONMENTALLY RESPONSIBLE CONSTRUCTION 

PRACTICES

During construction, staff continue to participate in weekly 

construction team meetings, monitor performance criteria, and 

provide ongoing feedback to the project team regarding environmental management. Some examples of environmentally 

responsible construction practices include:

■ Pre-construction review of project plans. Staff conduct a preconstruction orientation with the project team to review the 

environmental elements of the project plan. 

■ Plan of the day. On a daily basis, subcontractors submit a “plan 

of the day” to the prime contractor the day before any work is 

to be performed. The prime contractor evaluates all plans for 

potential environmental and safety hazards and communicates 

these plans with all subcontractors on the job site. 

■ Stormwater controls. Erosion and sediment controls, proper 

chemical storage and fueling procedures, and good housekeeping practices are implemented during construction. Regular inspections by contractors and periodic site inspections 

by NREL staff are conducted to verify that the implemented 

controls are functioning properly. Any repairs are documented 

on an inspection report; prompt actions are required to correct 

any noncompliant conditions. 

■ Keeping wildlife safe. Prior to commencing construction, biologists conduct surveys for nesting birds and have the authority 

to delay construction or instruct workers to avoid sensitive 

areas if necessary until young birds fledge the nest. Areas 

with planned construction are mowed in the weeks prior to 

construction to discourage birds from nesting. When snakes 

are encountered they are safely relocated away from active 

construction areas.

■ Waste reduction, reuse, and recycling. Construction contractors 

diverted 88% of their waste in fiscal year (FY) 2011 by recycling 

and reusing materials. Contractors are encouraged to retain 

materials on-site whenever possible to reduce transportation 

costs, fuel use, GHGs, and other air emissions. For example, 

excess excavated dirt is often used as fill on-site and may be 

shared between projects on campus. Instead of transporting 

excavated rock off-site, it’s used in gabion retaining walls as an 

attractive landscaping feature.

Operable windows minimize use of air conditioning. Photo by Patrick 

Corkery, NREL/PIX 17092
ENVIRONMENTAL PERFORMANCE REPORT 2011 19

■ Minimizing and cleaning up spills. NREL specifies that new or 

like new equipment must be used during construction on-site 

to minimize the potential for drips, leaks, and spills of fuel, 

oil, and hydraulic fluids. When spills do occur, contractors are 

instructed to quickly stop the source, control spilled material, 

and contact NREL to monitor cleanup activities.

■ Dust control. Contractors must control dust to minimize 

impacts to neighbors and adjacent habitat. Water trucks are 

used to spray down dust prone areas, driving speeds are 

limited, and excavation during high winds is restricted. 

NREL’s EMS provides effective environmental stewardship and 

minimizes the environmental impacts of laboratory activities and 

operations. The EMS is a framework of policies, procedures, and 

programs that integrates environmental protection into daily work 

practices. The laboratory’s EMS efforts:

■ Protect and enhance the vegetation, wildlife, and natural 

resources of the laboratory sites

■ Prevent pollution

■ Comply with environmental requirements

■ Encourage continual improvement in environmental protection and sustainability performance. 

While the EMS is managed by the Environment, Health, and Safety 

(EHS) Office, environmental protection must involve everyone at 

the laboratory to be effective. The EMS is implemented as part of 

an ISMS. 

3.1 ENVIRONMENTAL MANAGEMENT SYSTEM 

STRUCTURE

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

continual improvement framework described below and depicted 

in the graphic. 

PLANNING

■ Environmental policy. NREL states its commitments to the environment through this overarching policy. The policy commits 

specifically to:

● Environmental stewardship

● Pollution prevention 

● Compliance with legal requirements and voluntary 

commitments

● Continual improvement of environmental and sustainability performance.

■ Environmental aspects. NREL’s environmental aspects are 

those activities, products, or services that have the potential to 

interact with the environment. The significance of an identified 

aspect is determined by assigning a frequency of occurrence 

and a severity. Using this method, EHS staff review potential 

impacts to the environment annually and activities in the EMS 

are prioritized by the identified significant aspects. 

NREL also utilizes a robust hazard identification and control 

process as part of its ISMS to manage environmental risks. 

■ Legal and other requirements. NREL maintains a formal process 

to identify regulations and standards that are necessary and 

sufficient to address specific environmental hazards, including federal laws and regulations, state and local requirements, 

executive orders, and DOE requirements.

In 2011, the EMS became 

certified to the ISO 

14001:2004 standard 

for environmental 

management systems. 

ISO 14001 is a globally 

recognized standard that 

defines the structure 

of an organization’s 

EMS to improve 

its environmental 

performance. ISO 

14001 requires an organization to identify potential 

environmental impacts and establish controls needed 

to minimize impacts, to monitor and communicate 

environmental performance, and to establish a formal 

process for continually improving the system.

Define Scope

Analyze

H

azards,

Perform Work

Develop Controls

Feedback &

Improvement

Environment

Quality Safety

Impacts

& Issues

Registered

to ISO 14001

3 Environmental Management System
20 ENVIRONMENTAL PERFORMANCE REPORT 2011

■ Objectives and targets. Regular planning of activities and 

programs are necessary to achieve NREL’s environmental 

goals. The EHS Office and Sustainable NREL plan, implement, 

monitor, and report on environmental stewardship goals and 

actions to generate continual improvement (see section 3.2 

Performance Indicators and Progress for more details).

IMPLEMENTATION

■ Structure and responsibility. NREL policies and procedures 

establish roles and responsibilities for environmental management within the organization.

■ Competence, training, and awareness. NREL verifies that 

workers are competent on the basis of education, training, or 

experience and implements a robust environment, health, and 

safety training program.

■ Communication. NREL provides a number of avenues for 

communication between the laboratory and the community, 

such as community meetings, lunch-and-learn events, publicfacing websites, periodic newsletters, and mailings. NREL tracks 

and responds to all environmentally related concerns through 

the Public Affairs Office.

■ Operational control. NREL plans and manages operations and 

activities in line with its environmental policy and objectives. 

Staff continually identify and review activities that could have 

impacts to the environment and engineering and administrative controls are put in place to minimize or avoid impacts to 

the environment.

■ Document and record control. Policies and procedures ensure 

that the current, correct versions of documents are available for 

use and that records are maintained to meet requirements. 

CHECKING AND CORRECTIVE ACTION

■ Monitoring and measurement and evaluation of compliance. NREL monitors key activities, tracks performance and 

In 2011, NREL conducted a thorough review and 

revision of its environmental aspects and developed 

a new list of significant environmental aspects:

■ Air emissions

■ Discharges to surface water or groundwater

■ Wastewater discharges

■ Waste generation and management

■ Resource use or conservation (energy, water, 

land, biological, cultural)

■ Community. 

Each of these aspects is addressed by the 

environmental management system.

2011 Accomplishments and Highlights

■ In 2011, NREL achieved ISO 14001:2004 certification 

for its EMS. In July, a team of external auditors from 

NSF-International Strategic Registrations conducted a 

comprehensive and rigorous independent assessment of the policies, procedures, tools and roles and 

responsibilities used in environmental management 

at NREL. NREL completed an integrated certification 

effort along with its safety and quality management 

systems, conserving staff time and cutting the costs of 

receiving these certifications. The certification represents a major accomplishment and demonstrates our 

leadership in environmental stewardship.

■ In 2011, NREL invested considerable effort into 

communicating with staff regarding the ISO certification effort. In particular, staff focused on communicating our commitments to the environment laid out in 

the environmental protection policy. The key points of 

this policy were communicated to all staff through a 

variety of efforts. Some examples of this effort include:

● A 20-minute online training was developed for 

all staff, including dynamically presented content 

with videos, graphics, and quizzes.

● All employee badge cards were updated to 

include the newly revised continual improvement 

cycle graphic and policy commitments (shown 

above).

● Regular emails and internal news articles were 

sent to all staff.

● EHS and Quality Assurance staff presented “road 

shows” for hundreds of employees across at least 

12 internal organizations. 

■ In 2011, NREL stepped up the number of assessments of its programs to focus on finding areas of 

continual improvement and in preparation for the 

planned 2011 ISO 14001 assessment. In addition, 

DOE conducted assessments of NREL’s environmental 

programs. For details, see section 3.3 Assessments and 

Improvement. 

■ NREL’s environmental protection policy was simplified 

to clearly state our key commitments to environmental protection. 

■ The EMS procedures underwent a comprehensive 

review and revision. This thorough review clarified, 

streamlined, and improved the effectiveness of the 

EMS procedures and helped prepare for certification 

in 2011.

■ NREL’s environmental aspects were updated in 2011. 

This update simplified and streamlined our aspects 

from a list of nineteen to six, making the aspects 

process easier to communicate.
ENVIRONMENTAL PERFORMANCE REPORT 2011 21

progress toward environmental objectives, and conducts 

periodic assessments of compliance with legal requirements.

■ Internal assessment. NREL periodically conducts assessments 

to verify that its EMS is operating as intended. A formal system 

for tracking corrective and preventive actions supports continual improvement of the management system (see section 3.3 

Assessment and Improvement for details).

MANAGEMENT REVIEW

■ Management Review. NREL conducts regular management 

reviews of the EMS so that executive management can provide 

feedback and direction to the environmental management of 

the organization.

3.2 PERFORMANCE INDICATORS AND PROGRESS

Each year, NREL sets measurable objectives and targets for environmental improvement. Goals are set through several mechanisms including:

■ PEMP. Each fiscal year, in collaboration with DOE GO, performance objectives are developed for the upcoming year. 

■ Colorado Environmental Leadership Program (CELP). As a 

member of CELP, NREL voluntarily sets three-year goals for 

environmental improvement. Each year progress toward these 

goals is reported to the state. 

■ Site Sustainability Plan (SSP). For 2011, Sustainable NREL developed a SSP to establish sustainability performance commitments for 2011 and document activities in support of Executive Order (EO) 13514 requirements. Results of the 2011 plan 

are presented in the next chapter of this report. 

Goals are owned by individuals and groups throughout the laboratory, including the EHS Office and Sustainable NREL. Progress 

through the course of the year on each of these goals is tracked 

using an online software tracking system and results are reported 

annually. Some examples of performance for 2011 are described 

in the 2011 Environmental Objectives and Results table (shown on 

page 6 in the Executive Summary).

For FY 2012, NREL’s environmental and sustainability objectives 

under the PEMP are: 

■ Maintain a safe and healthful workplace based on identified 

and managed risks.

■ Further ISM through development of improved management 

systems.

■ Maintain leadership in sustainable science and laboratory 

operations.

3.3 ASSESSMENT AND IMPROVEMENT

Assessments are key to supporting the continual improvement 

of environmental management at NREL. Periodic assessment of 

NREL’s EMS and its components provide assurance that the EMS 

continues to be an effective tool to achieve and maintain compliance with regulatory and legal requirements, meet the established environmental goals of the laboratory, and demonstrate to 

ourselves and others that we are “walking the talk.” 

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

■ Internal assessment. NREL staff perform regular internal assessments of NREL’s EMS against the ISO 14001 standard. The scope 

of internal 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. 

■ External assessment. 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 as a 

part of continual improvement efforts and to maintain ISO 

certification. 

■ Evaluation of compliance. Periodic internal environmental 

compliance evaluations are conducted to verify that NREL 

activities meet all applicable legal and other requirements. 

Improvements are developed and implemented as necessary 

based on the results of each evaluation. 

2011 ASSESSMENTS

In 2011, a number of assessments were conducted, allowing NREL 

to focus on finding areas of continual improvement, improve 

program effectiveness, and make substantial environmental 

performance improvements.

The following assessment activities took place in 2011:

■ Internal assessments. In January 2011, an internal assessment 

was conducted within the EHS Office by the EMS Coordinator. Scheduled interviews were conducted with environment 

program owners and document reviews of environment 

program procedures were completed. Programs reviewed 

included:

● AST Program

● Air Quality Protection Program

● Cultural Resource Management Program

● Drinking Water Program

● Groundwater Protection Program

● Emergency Response Team (ERT) Program

● Hazardous Waste Management Program

● Material Safety Data Sheets (MSDS) Program

● NEPA Program

● Natural Resource Conservation Program

● Ozone-Depleting Substances (ODS) Management Program

● SPCC Program

● Sustainable Landscaping Program

● Wastewater Management Program

● Weed Management Program.

Four findings were made in the areas of document control and 

operational control and seven opportunities for improvement 
22 ENVIRONMENTAL PERFORMANCE REPORT 2011

were identified. Several documents did not have added version 

control indicating the current version of the document. Several 

procedures contained inaccuracies and needed to be updated. 

While the majority of the actions from this assessment have 

been completed, several are outstanding due to length of 

time needed to implement corrective actions. All actions are 

expected to be completed in 2012.

In November 2011, an internal assessment of NREL’s Construction Stormwater Management program was conducted 

within the EHS Office by the EMS Coordinator. Interviews 

were conducted with the program manager and document 

and records reviews were completed. Several procedures and 

inspection forms contained deficiencies and needed to be 

updated. Three findings were made regarding operational 

controls and four opportunities for improvement were identified. All actions are expected to be completed in 2012.

■ Evaluations of compliance. In February 2011, NREL conducted 

an internal evaluation of compliance. The evaluation was 

conducted to verify compliance with environmental legal and 

other requirements applicable to NREL across a sampling of 

activities and programs for 2010. No actions were identified for 

follow up or correction. 

The review included compliance with federal, state, and local 

regulatory deliverables and DOE requirements including 

permits, equipment and other registrations and certifications, and reports and notifications. The review also evaluated 

NREL’s completion of requirements by environmental program 

area, including requirements for such activities as inspection, 

monitoring, training, certifications, etc. Environmental areas 

reviewed included:

● Cultural Resources Protection

● Drinking Water Quality

● Endangered Species Act

● EMS 

● Regulated Waste Management

● NEPA

● Wetlands Protection

● Wildlife Protection.

■ External assessments. In 2011, NREL sought and achieved 

certification under ISO 14001 and received a third-party certification assessment to confirm conformance with the standard. 

The assessment involved rounds of review including:

● A “desk audit” of EMS procedures and documentation

● An “on-site readiness review” of the major elements of the 

management system

● A final audit involving site visits by a team of auditors to 

all major facilities, interviews with staff at all levels of the 

organization, observation of processes in place, and review 

of documents and records. 

The extensive certification assessment resulted in several 

findings and opportunities for improvement. Corrective actions 

will address deficiencies in document version control and 

NREL’s procedure for identifying environmental aspects. All 

actions are expected to be completed in 2012.

3.4 2011 AWARDS AND RECOGNITION

In 2011, NREL received several awards and recognition of its environmental and sustainability achievements including:

■ GreenGov Presidential Award

■ DOE EStar Awards

■ Federal Electronics Challenge (FEC) Platinum Award

■ CELP Gold-level Leader.

GREENGOV PRESIDENTIAL AWARD

In 2011, NREL received the prestigious GreenGov Presidential 

Award for “Sustainable Information Technology Innovation at 

Work in NREL’s RSF Green Data Center.” The GreenGov Presidential 

Award is a federal government award that celebrates extraordinary 

achievement in the pursuit of President Obama’s challenge to lead 

by example toward a clean energy economy. 

DOE ESTAR AWARDS

In 2011, NREL received two DOE EStar Awards for its nominations 

including “Living Lab—Building the Sustainable Campus of the 

Future” and “Cradle to Cradle—Near-Zero Materials Waste and 

Beyond.” DOE EStar Awards highlight environmental sustainability projects and programs within the DOE complex that reduce 

environmental impacts, enhance site operations, reduce costs, and 

demonstrate excellence in pollution prevention and sustainable 

environmental stewardship. 

FEC PLATINUM AWARD

In 2011, NREL achieved the platinum-level FEC Award. FEC is 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. 

Learn more about this voluntary program at the FEC Website at 

www.federalelectronicschallenge.net/.

CELP GOLD-LEVEL LEADER

In 2011, NREL was again recognized as a CELP gold-level leader. 

CELP is a voluntary partnership between CDPHE and participating 

private and public Colorado facilities, and is intended to recognize 

environmental leadership and performance. 

In early 2004, NREL was the first laboratory accepted into CELP as a 

gold-level leader and has maintained this leadership level since. As 

a component of CELP membership, NREL’s voluntary environmental performance goals, described above, further enhance opera-
ENVIRONMENTAL PERFORMANCE REPORT 2011 23

tions and performance at the laboratory. CELP recognizes facilities 

that voluntarily:

■ Exceed regulatory requirements

■ Implement EMS (which focus on incorporating environmental considerations into normal management processes and 

improving internal environmental management effectiveness)

■ Work closely with their communities

■ Establish three-year goals focusing on measurable results.

Learn more about this voluntary program at CDPHE Website, 

www.cdphe.state.co.us/oeis/elp/index.html. 

Benefits of NREL’s EMS

Mission. NREL’s EMS supports the organization’s overall mission and 

improves effectiveness by systematically addressing environmental 

opportunities and risks, ensuring compliance with regulations, and implementing voluntary commitments to achieve superior performance.

Environmental and sustainability performance. While NREL 

benefits as an organization from each of the efforts highlighted here, the 

larger benefit is in reduced impacts to the quality of the air, water, land, 

and to the flora and fauna that share the campus and community. 

Reduced risk. NREL’s Hazard Identification and Control Program 

incorporates environmental risk assessment.

Cost savings. Any avoided impact represents cost savings, specifically 

in the event of spills and incidents. Cost savings are realized through 

energy efficiency projects, new renewable energy installations, and waste 

reduction and recycling.

Environmental awareness. Staff are made aware of the potential 

environmental impacts from their work activities through the NREL Now 

newsletter, postings on the NREL intranet, new employee orientation 

and activity specific trainings, policies and procedures, management 

communications, Sustainable NREL communications, and special events 

such as Staff Awards (an annual employee recognition event), Earth Day, 

and Bike 2 Work Day.

Empowered individuals. Staff are empowered to reduce NREL’s 

environmental footprint including participation in programs and events 

for recycling single-stream materials, batteries, electronic equipment, 

and shredded paper, as well as a composting program. Staff at the new 

RSF are able to support a new, ultra high-efficiency energy goal for the 

building by reducing their energy use in the office. 

Organizational culture and operations. NREL strives to maintain 

a high level of awareness in the laboratory around safety, health, and 

environmental responsibilities. This is accomplished through a variety of 

means, including regular communications from executive management, 

as well as at-the-ground-level through daily EHS interaction with lab and 

operations staff in trainings, inspections, and risk assessments.

Real property asset management. NREL strives to achieve, at 

a minimum, LEED Gold certification for all new buildings and major 

renovations.

Community relations. NREL seeks to improve community relations 

by responding to, and tracking all community input through phone calls, 

email, community meetings, and the NEPA process. NREL takes proactive 

measures to engage the community with public tours, newsletters, and 

mailings to neighborhoods surrounding its facilities.

Cooperative conservation. NREL regularly works with community 

stakeholders to improve the community. For example, with the growth of 

the STM, NREL implemented a traffic mitigation plan to reduce forecasted 

impacts of increased traffic to the facility.
24 ENVIRONMENTAL PERFORMANCE REPORT 2011

The Sustainable NREL Program was formed to implement sustainable applications within the laboratory. This collaborative and 

interdisciplinary initiative involves staff from across the organization to meet NREL’s goals to maximize the efficient use of resources; minimize waste and pollution; and serve as a positive force in 

economic, environmental, and public responsibility. Environmental 

stewardship components include: 

■ Renewable energy and energy efficiency solutions 

■ High performance sustainable buildings, landscaping, campus 

planning, and transportation 

■ Water, electricity, and natural gas use efficiency and 

management 

■ GHG emission analysis and management 

■ Reduce, reuse, and recycle materials use 

■ Pollution prevention

■ Sustainable acquisitions

■ Sustainable policies and operating practices

■ Public responsibility and community outreach.

Sustainable NREL: 

■ Provides technical knowledge and recommendations

■ Oversees data collection and analysis of performance metrics 

for federal reporting

■ Integrates energy, water and material resource conservation 

and efficiency applications into NREL’s daily research and 

operations

■ Generates short-term and long-term planning measures for 

building NREL’s “Campus of the Future.”

NREL integrates sustainability into its EMS. Technical experts from 

Sustainable NREL and the EHS Office work together regularly to 

improve operations and implement programs including:

■ Site sustainability and pollution prevention data tracking and 

reporting to DOE

■ Sustainability and environmental management planning

■ Measurement and tracking of environmental objectives, 

targets, and actions

■ Pollution prevention assessments and improvements

■ Awareness and engagement of staff and community members.

4.1 SITE SUSTAINABILITY PLANNING

EO 13514, Federal Leadership in Environmental, Energy, and Economic Performance, specifies environmental sustainability performance 

goals for federal agencies. DOE O 436.1, Departmental Sustainability, implements the requirements of the executive order for DOE. 

Each year, DOE prepares a Strategic Sustainability Performance 

Plan (SSPP) that describes how the department will meet the 

requirements of EO 13514 and DOE O 436.1. Each DOE facility 

must then develop an annual SSP. Each site’s plan is used to report 

on steps taken to meet the national and DOE sustainability objectives and also outlines plans for the upcoming year. 

The following content has been extracted from NREL’s SSP 

for FY 2012. The full report is located online at www.nrel.gov/ 

sustainable_nrel/.

SITE MANAGEMENT VISION

Integral to both research and operations, NREL’s sustainability 

efforts support the laboratory’s mission—the innovative research, 

development, and commercialization of renewable energy and 

energy efficiency technologies. Leading by example, NREL operates in a manner that balances environmental, economic, and 

social values in the delivery of our mission. 

Fostering environmental and social responsibility, NREL is working 

to establish the laboratory as a global model for sustainability. The 

laboratory strives to accomplish this by:

■ Advocating for all executive orders, federal regulations, DOE 

orders, and goals related to sustainable facility operations

■ Executing NREL-specific goals to reduce our impacts on the 

community and environment 

■ Providing technical expertise to other organizations within the 

laboratory

■ Providing leadership within the federal government and our 

community by actively mentoring and collaborating with other 

organizations to move sustainability into a new paradigm. 

NREL’s campus is a living laboratory that showcases new technologies, design practices, and operating behaviors. In all campus 

development, NREL looks for opportunities to integrate energy 

efficiency and renewable energy, high-performance buildings, and 

sustainable transportation options. On-site deployment of technologies developed by NREL researchers is also emphasized.

MAJOR PLANNING ASSUMPTIONS, ISSUES, FUNDING 

STRATEGIES

NREL is planning for significant future growth as represented in 

our long term campus plan—with a projected 83% increase in 

staff and 300% increase in campus footprint from FY 2008 to FY 

2020. While currently experiencing growth, the current economic 

climate is uncertain. In this context, NREL is preparing to accommodate future growth through the construction of new highperformance buildings and renewable energy systems that take 

4 Sustainability
ENVIRONMENTAL PERFORMANCE REPORT 2011 25

advantage of alternative financing mechanisms, including PPAs, 

energy savings performance contracts (ESPCs), partnerships with 

energy service companies, and cooperative research and development agreements (CRADAs). NREL also continues to review the 

use of overhead funds, cost savings reinvestment, and leveraging 

of alternative finance for retrofits or new projects. 

4.2 2011 HIGHLIGHTS AND ACHIEVEMENTS

As market demand for renewable energy and energy efficiency 

continues to expand, NREL responds. In FY 2011, our staff levels 

increased 20% from 2010, and NREL’s campus square footage 

expanded 48%. This expansion was necessary to help support 

the growing market demand for energy efficiency and renewable energy technologies. This pace of campus construction will 

continue through FY 2012 with the addition of six new structures 

on campus. This growth poses challenges in NREL’s pursuit of 

DOE’s energy and sustainability goals. Even with all new construction meeting LEED Gold or Platinum certification standards, NREL’s 

first net-zero energy building, and additional new on-site renewable systems, NREL’s demand for energy and water will increase. 

Subsequently, GHG emissions from purchased energy and travel 

will continue to grow even though impacts are being reduced on 

a per capita basis. Scope 3 GHG emissions will continue to be a 

high priority for NREL in our development of innovative solutions.

Staffing increases affect energy and resource consumption. To 

mitigate our impacts on the community and the environment 

while strongly promoting the laboratory’s mission, NREL is educating staff on behavior changes necessary to uphold sustainability 

goals that meet reductions required by EO 13514. Using a range 

of programs, procedures, and projects, Sustainable NREL supports 

the dynamic processes of creating a sustainable research campus. 

4.3 2011 SSPP GOAL PERFORMANCE

The following table summarizes each of DOE’s SSPP goals and 

NREL’s performance status. 

2011 Highlights and Achievements

To reduce energy consumption with expected staff growth, 

NREL constructed two high-performance sustainable buildings 

and four on-site renewable energy installations in FY 2011. 

These buildings allow NREL to vacate leased space and move 

staff into a more efficient and sustainable work environment. 

In FY 2011, NREL:

■ Achieved LEED Platinum certification from the U.S. Green 

Building Council for the new RSF

■ Completed the IBRF, which achieved LEED Gold 

certification 

In FY 2011, NREL also deployed new on-site renewable-energy 

systems, including: 

■ PV on the STM campus—a 524 kilowatt (kW) array on the 

roof over the RSF visitor’s parking lot and a 449 kW array on 

the RSF itself.

Campus construction continues through FY 2012 with a new 

cafeteria, parking garage and associated roadway infrastructure, a new Site Entrance Building, a new wing addition to 

the RSF, and the ESIF on the STM campus, and a new 5 MW 

dynamometer at the NWTC. 

FY 2011 also saw many innovative accomplishments for NREL, 

including:

■ Communicating NREL’s campus-wide no-idling policy 

■ Establishing NREL’s first green janitorial contract

■ Enhancing NREL’s office supply contract for sustainable 

acquisition

■ Completing the first interagency Sustainability Challenge 

with DOE, EPA Region 8, General Services Administration, 

and City of Lakewood, Colorado.

■ Participating in the international Katerva Challenge

■ Achieving net-zero energy performance for the RSF

■ Implementing a campus-wide composting program.

As educators, NREL also hosted 233 tours of the net-zero 

energy RSF to share pioneering energy efficiency technologies, 

and sustainable practices.

The Gamesa G9X-2.0 turbine assembled at the NWTC is the latest 

addition to NREL’s collection of multi-megawatt wind turbines. 

Photo by Dennis Schroeder, NREL/PIX 20864

PV panel installation on the roof at the RSF. Photo by Dennis Schroeder, 

NREL/PIX 17843
26 ENVIRONMENTAL PERFORMANCE REPORT 2011

NREL’S PERFORMANCE STATUS TOWARD DOE SSPP GOALS

SSPP Goal # DOE SSPP Goal Performance Status in FY 2011

1.1 28% Scope 1 and 2 GHG reduction by FY 2020 from 

a FY 2008 baseline

NREL reduced Scope 1 and 2 emissions 86% from the 2008 baseline (including RECs).

1.2 30% energy intensity reduction by FY 2015 from a FY 

2003 baseline.

Energy intensity decreased 35% since 2003.

1.3 Individual buildings or processes metering for 90% 

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

natural gas, and chilled water (by October 1, 2015)

NREL connected electricity, hot and chilled water, and natural gas meters to the Energy 

Dashboard.

1.4 Cool roofs, unless uneconomical, for roof 

replacements unless project already has CD-2 

approval (New roofs must have thermal resistance of 

at least R-30.)

50% of NREL campus have cool roofs, a 27% increase from FY 2010.

1.5 7.5% of annual electricity consumption from 

renewable sources by FY 2013 and thereafter (5% FY 

2010—FY 2012)

28% of NREL’s total power comes from on-site sources.

1.6 10% annual increase in fleet alternative fuel 

consumption by FY 2015 relative to a FY 2005 

baseline

Alternative fuel use has grown 143% since 2005.

1.7 2% annual reduction in fleet petroleum 

consumption by FY 2020 relative to a FY 2005 

baseline

NREL established a campus-wide no-idling policy.

Petroleum fuel usage has grown 92.6% since 2005.

1.8 75% of light duty vehicle purchases to consist of 

alternative fuel vehicles (AFVs) by FY 2000 and 

thereafter

One compressed natural gas vehicle was added to the fleet in FY 2011.

1.9 Fleet inventory reduction by 35% within the next 

three years relative to a FY 2005 baseline

NREL disposed of seven vehicles, 15% of the fleet in FY 2011.

2.1 13% Scope 3 GHG reduction by FY 2020 from a FY 

2008 baseline

NREL Scope 3 emissions increased 10% from the 2008 baseline.

3.1 15% of existing buildings greater than 5,000 GSF to 

be compliant with the Guiding Principles (GPs) of 

HPSB by FY 2015

NREL currently has three buildings (13%) compliant with the GPs. 

NREL performed GP assessments on three additional buildings this year.

3.2 All new construction, major renovations, and 

alterations of buildings greater than 5,000 GSF to 

comply with the GPs; and where the work exceeds 

$5 million, each are to be LEED Gold certified or 

equivalent

In FY 2011, NREL received LEED Platinum certification for RSF and LEED Gold certification for 

IBRF.

4.1 26% water intensity reduction by FY 2020 from a FY 

2007 baseline

NREL reduced water intensity by 48% from FY 2007 baseline.
ENVIRONMENTAL PERFORMANCE REPORT 2011 27

As the nation’s premier resource for renewable energy information, 

research, and technology, NREL has a unique role in supporting 

the nation’s energy and environmental goals. 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 a shift to a greater use of renewable energy are 

critical to the 21st century. Major changes in the nation’s energy 

policy have spurred new research efforts at NREL to help address 

these issues. Renewable energy technologies will have a role in 

mitigating the effects of climate change and in moving forward to 

energy independence.

5.1 ENERGY POLICY UPDATES

In 2008, there was a major shift in the energy policy of the United 

States with the passage of the Energy Independence and Security Act (EISA) which mandated significant changes in the energy 

production and use in the United States over the coming decades. 

The EISA 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

■ Revisions to the renewable fuel standard (RFS) provisions of the 

Clean Air Act

■ 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 Administration (EIA), an independent arm 

of DOE, evaluates energy use and projections in the Annual Energy 

Outlook (AEO). The EIA tracks energy use by source and predicts 

changes in energy demands by gauging the effects of economic 

trends and the impacts of energy policy changes implemented 

5 NREL’s Role in the Environment –

 Global and Local

NREL’S PERFORMANCE STATUS TOWARD DOE SSPP GOALS

SSPP Goal # DOE SSPP Goal Performance Status in FY 2011

4.2 20% water consumption reduction of industrial, 

landscaping, and agricultural (ILA) water by FY 2020 

from a FY 2010 baseline

NREL does not use ILA water. 

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

excluding construction and demolition debris, by 

FY 2015

NREL diverted 77% of campus waste from landfill; rolled out PPI Pilot Program; and 

performed three pollution prevention assessments.

5.2 IDivert at least 50% of construction and demolition 

materials and debris by FY 2015

NREL diverted 88% of its construction waste from landfill in FY 2011.

6.1 Procurements to meet sustainability requirements 

and include sustainable acquisition clause (95% each 

year)

NREL awarded its first green janitorial contract.

The office supply contract was enhanced to include EO 13514 sustainable acquisition 

requirements.

7.1 All data centers to be metered to measure a monthly 

power usage effectiveness (PUE) (100% by FY 2015)

NREL’s RSF data center measures monthly PUE.

7.2 Maximum annual weighted average PUE of 1.4 by 

FY 2015

PUE for the RSF data center is 1.16.

7.3 Electronic Stewardship—100% of eligible PCs, 

laptops, and monitors with power management 

actively implemented and in use by FY 2012

Power management is enabled on 100% of devices.
28 ENVIRONMENTAL PERFORMANCE REPORT 2011

by new legislation and regulation. The EIA also assesses the 

impacts on energy demands from changes to tax credit structures 

as incentives to use alternative sources, such as the biofuels tax 

credit, and the effects of new or revised fuel standards, such as the 

Corporate Average Fuel Economy standard or the RFS, both now 

established by the EPA.

The AEO projects that the strongest growth in fuels in the outlook 

period would be in renewable fuels used for the generation of 

electricity and for liquid fuels used for transportation. Total U.S. 

consumption of liquid fuels, including fossil fuels and biofuels, are 

predicted to increase from 18.8 million barrels per day in 2009 to 

21.9 million barrels per day in 2035.

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 2011, NREL continued to make advances in 

renewable energy technologies that will contribute to the growth 

of this segment of the overall energy economy and support the 

energy sector expected to have the strongest growth in the next 

25 years.

5.2 NREL RESEARCH HELPING MEET LEGISLATIVE GOALS

Since its origination as 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 energy-related publications and has the 

distinction of having published the number-one cited article in 

the energy field3. In 2009, a journal article co-authored by three 

NREL researchers currently ranks as one of the most read articles 

over the past 12 months by the Environmental Science & Technology journal4

. With the addition of the NWTC, the IBRF, 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. In 2011, construction began for the new 

ESIF, a laboratory that will house research into this critical area. 

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.

BIOFUELS

EISA established rigorous goals for developing biofuel substitutes for petroleum-based fuels used for transportation (except 

ocean-going vessels). The RFS 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 grain or corn starch. The EISA 

mandates that advanced biofuels include cellulosic fuels and 

biomass-derived 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. 

The EIA predicts that the 2022 goal will not be met—projecting 

a total of 25.7 billion gallons production capacity. The shortfall is 

attributed to economic and technical factors preventing cellulosic 

biofuels (i.e., biofuels derived from materials other than corn grain 

or corn starch) production from providing the credits needed to 

meet the requirement. However, the EIA continues to predict that 

the production of biofuels ultimately surpasses the RFS requirements by 2035. 

In 2011, NREL completed construction of the new IBRF. The IBRF 

is designed to be a place for the laboratory and industry to test 

demonstration-scale projects and accelerate the commercialization of biofuels. The facility is a $33.5 million pilot plant and facility 

upgrade capable of supporting a variety of advanced biofuels 

projects. The IBRF boasts a 27,000 ft2 high bay with one area 

available to industry partners for equipment testing, as well as 

upgraded laboratories, additional office space, and access to NREL 

expertise.

NREL RESEARCH MITIGATING 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 

The IBRF boasts a 27,000 ft2 high bay with one area available to industry. 

Photo by Dennis Schroeder, NREL PIX 19805

 3 Contreras, M. A.; Egaas, B.; Ramanathan, K.; Hiltner, J.; Swartzlander, A.; Hasson, F.; and Nuff, R. (1999) Progress Toward 20% Efficiency in Cu(In,Ga)Se2 Polysrustalline Thin-film Solar Cells. 

Prog. Photovoltaic Res. Appli. 7.311-316.

4 Williams P. R, D.; Inman, D.; Aden, A.; and Heath, G. (2009). Environmental and Sustainability Factors Associated With Next-Generation Biofuels in the U.S.: What Do We Really Know? 

Environ. Sci. Tech. 43, 4763-75.
ENVIRONMENTAL PERFORMANCE REPORT 2011 29

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 to 1,300 million metrics 

tons of carbon per year (MMtC/Yr) by 2030 to limit atmospheric 

CO2 levels to between 450 and 500 ppm. A stabilized level of 450 

ppm CO2 is, according to this report, a level which can ward off 

the worst effects of climate change. The report goes on to say that 

this level of CO2 reduction can be achieved with a combination 

of energy efficiency improvements in the building, vehicle, and 

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

Of the 43% reduction (516 MMtC/yr) projected to be achieved 

through the deployment of renewable energy technologies, a 

majority of the GHG reduction would come from wind energy 

(181 MMtC/Yr). The additional reductions would be from CSP (63 

MMtC/Yr ), PVs (63 MMtC/Yr ), biofuels (58 MMtC/Yr), biomass (75 

MMtC/Yr), and geothermal (83 MMtC/Yr). 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 actively engaged in most of these research areas—particularly wind, PV, and CSP. 

WIND

NREL continues to advance wind energy technologies at the 

NWTC and elsewhere. In 2011, DOE announced that NREL would 

receive nearly $4 million to help spur offshore wind development. NREL will receive $1.5 million to improve computer-aidedengineering tools to design and assess a wide range of floating 

offshore wind platform concepts. Another $1.2 million was awarded to produce an offshore wind farm simulation tool to improve 

designs by maximizing energy capture and minimizing structural 

fatigue from wave and wind impacts. NREL will also receive 

$400,000 to develop software to simulate offshore conditions, 

including wind and waves associated with extreme events such as 

hurricanes, to help design more robust offshore wind turbines.

CONCENTRATING SOLAR POWER (CSP)

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. Large CSP installations require substantial investments, with costs potentially exceeding $1 billion. NREL has been 

deeply involved in the continuing effort to reduce the cost of CSP 

by improving thermal energy storage (TES). In May 2011, NREL, 

DOE, and Sandia National Laboratories held a TES workshop in 

Golden. The objective was to engage the university and laboratory 

research communities to identify research directions for developing new high-temperature materials and systems that advance TES 

for CSP technologies. To communicate the results, NREL recently 

published “Summary Report for Concentrating Solar Power Thermal Storage Workshop: New Concepts and Materials for Thermal 

Energy Storage and Heat-Transfer Fluids.” 

The workshop enabled researchers to better define the challenges 

in this field, and clarified the direction of research needed on heat 

transfer fluids, sensible energy storage, phase-change storage, and 

thermochemical storage.

One motivation to conduct the workshop was the DOE SunShot 

Initiative. SunShot is a collaborative national initiative to make solar 

energy technologies cost-competitive with other forms of energy 

by reducing the cost of solar energy systems by about 75% before 

2020. Among other things, SunShot calls for reducing the total 

levelized cost for utility-scale solar electricity to roughly 6 cents per 

kilowatt-hour, without subsidies, by 2020.

PHOTOVOLTAICS (PV)

The development of technology to capture solar energy is at 

the core of research conducted at NREL. Three solar technologies developed at NREL have been named among 2011’s most 

significant innovations by R&D Magazine. The technologies—the 

Innovalight Silicon Ink process, the Flash Quantum Efficiency 

System for Solar Cells, and the Optical Cavity Furnace—were 

recognized with R&D 100 Awards. The awards, known as the 

“Oscars of Invention,” identify revolutionary technologies newly 

introduced to the market, and NREL has received 50 R&D 100 

Awards since 1982.

■ Silicon Ink Saves Money, Improves Quality. NREL scientists 

teamed with Innovalight, Inc., to invent the Innovalight Silicon 

Installation of a 2.5 MW Alstom wind turbine at the NWTC. Photo by 

Dennis Schroeder, NREL/PIX 18888

Concentrating solar power research lab on STM. Photo by Patrick Corkery, 

NREL/PIX 17775
30 ENVIRONMENTAL PERFORMANCE REPORT 2011

Ink process. The silicon ink, a liquid form of silicon, was developed for use in solar cells. This marks the first time that silicon 

has been sold in the marketplace as a liquid.

With the Innovalight Silicon Ink process, a screen printer is 

added to the manufacturing line, which produces an immediate increase in solar cell efficiency by allowing lighter doping, 

thereby enhancing response to the blue portion of the 

spectrum.

The new product boosts the bottom line of a typical solar 

production plant by 20%, which for an average-size factory 

is $100 million, while boosting the efficiency of the cells by 

about 6%.

More information on this technology is available in the new 

report, “High Efficiency, Low Cost Solar Cells Manufactured 

Using ‘Silicon Ink’ on Thin Crystalline Silicon Wafers” by 

Homer Antoniadis, Innovalight, Inc. available at www.nrel.gov/

docs/fy11osti/50824.pdf. 

■ Faster Assessment of Solar Cell Quality. NREL scientists teamed 

with Tau Science Corporation to develop “Flash Quantum 

Efficiency System for Solar Cells,” a way to assess the quality of 

solar cells at a speed that is about 1,000 times faster than previous methods.

The instrument—marketed by Tau as FlashQE—uses lightemitting diodes, high-speed electronics, and mathematical 

algorithms to measure the quantum efficiency of solar cells 

orders of magnitude faster than before. What used to take 

20 minutes, and therefore, could be done only with random 

samples of cells, now can be done in a second.

This means every single cell on a manufacturing line can be 

assessed, which can provide much needed process feedback 

information to the line and each cell can be sorted by its 

spectral response. Cells that respond best to a particular color 

of light can be connected to form a solar module. That way, 

a mismatched cell on a module won’t put the brakes on all the 

work the rest of cells are doing. And that means more efficient 

conversion of photons into electricity.

■ Furnace Bolsters Efficiency, Lowers Cost. The NREL Optical 

Cavity Furnace could revolutionize the solar cell manufacturing 

industry in the United States by producing higher quality and 

higher efficiency solar cells at a fraction of the cost of conventional, thermal ovens. The new furnace, which uses photons to 

uniformly heat crystalline solar cells and semiconductor materials, has increased the efficiency of the cells by 3% to 4%. And 

it costs 75% less than an industrial thermal or infrared furnace.

The Optical Cavity Furnace, licensed to AOS Solar, Inc., uses 

light enclosed within a highly reflective chamber to achieve a 

level of temperature uniformity that is impossible with other 

furnaces. It virtually eliminates energy loss by lining the cavity 

walls with ceramic materials of high reflectance and high thermal insulation, and by using an optimal geometric design.

AOS Solar manufactured the furnace, which the company 

branded as the Optical Processing Furnace, and it is operating 

at NREL’s Process Development Integration Laboratory.

NREL is subject to many federal, state, and local environmental 

laws and regulations, as well as executive orders and DOE orders, 

and memoranda of understanding with government agencies. 

NREL continues its excellent record of environmental compliance. 

In 2011, NREL received no violation notices from any regulatory 

agency. All required permits were received or renewed, required 

registrations were completed, and required notifications and 

reporting were submitted. There were no spills or releases of materials requiring reporting in 2011.

The table titled Federal, State, and Local Environmental Laws and 

Regulations Applicable to NREL, page 31, includes a brief description of the statute or regulation and how compliance requirements were met this year. More detailed information for each area 

of compliance is found in the referenced sections of this report. 

Also, see the table below: Environmental Permits, Registrations, 

and Notifications Applicable to NREL During 2011.

FlashQE is one of three NREL-developed, game changing technologies 

to be honored with a 2011 R&D 100 Award. Photo by Dennis Schroeder, 

NREL/PIX 18965

6 Compliance Summary
ENVIRONMENTAL PERFORMANCE REPORT 2011 31

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & Requirement

Air Quality 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 EPA. Several main categories 

for air pollutants are regulated: criteria air pollutants, non-criteria 

pollutants, hazardous air pollutants (HAPs), and ozone-depleting 

substances.

EPA regulation 40 CFR 82, Protection Of Stratospheric Ozone, 

requires that servicing records must be kept for appliances 

containing more than 50 pounds of Class 1 or 2 ODS refrigerant.

CDPHE regulations require federal, state, and local government 

facilities to track street sanding in the wintertime, and to minimize 

sand use with the goal of reducing particulate pollution in the 

Denver area.

EPA regulations require that certain facilities which emit GHG 

emissions track and report the amount of those emissions. 

Reporting and permitting of GHGs is required under the EPA 

Prevention of Significant Deterioration (PSD) regulation, Title V 

Tailoring Rule, and the EPA GHG Mandatory Reporting Rule.

NREL facilities did not exceed air permit standards or other 

regulatory requirements. 

For 2011, an internal evaluation of compliance confirmed 

that NREL is in compliance with all Colorado and EPA permit 

requirements and that all NREL facilities and individual 

permitted equipment are classified as minor sources.

On behalf of the CDPHE Air Pollution Control Division 

(APCD), Jefferson County completed an air inspection of the 

NWTC Site 4.0 emergency generator in November 2011. No 

issues were identified.

All required registrations and permit renewals were 

performed during 2011 for air pollutant emitting equipment 

and ozone depleting substance-containing equipment. 

Operators must maintain records of service for appliances 

containing more than 50 pounds of ODS refrigerant. NREL 

facilities servicing refrigeration equipment were registered. 

Confirmed that all NREL refrigeration service personnel 

have obtained the EPA and Colorado required training and 

certification.

Annual street sanding reporting was provided to the state 

and Jefferson County in 2011.

NREL’s 2011 GHG inventory shows that emissions are below 

the exempt level for EPA reporting and permitting rules.

EPA:

40 Code 

of Federal 

Regulations

 (CFR) 82 

CDPHE:

5 Colorado 

Code of 

Regulations 

(CCR) 1001-18, 

Reg. 16

Drinking 

Water Quality

The Safe Drinking Water Act (SDWA) establishes minimum drinking 

water standards and monitoring requirements for drinking water 

supplies. Drinking water quality is regulated for all public water 

suppliers in Colorado by CDPHE, under authority delegated by the 

EPA.

The NWTC drinking water system is subject to the 

regulatory requirement. In 2011, all monitored parameters 

met applicable SDWA requirements.

Triennial sampling for lead and copper was conducted in 

2011; the concentration of these metals was well below 

the Maximum Contaminant Levels (MCLs) at all sample 

locations.

EPA:

40 CFR 141–149

CDPHE:

5 CCR 1003-1

Groundwater 

Quality

Colorado groundwater quality standards are established by 

CDPHE. Permits for groundwater wells are issued by the Colorado 

Department of Natural Resources (DNR).

There are no compliance activities associated with the NREL 

Groundwater Program. NREL currently has five permitted 

monitoring wells at the STM site. The wells are not currently 

used for monitoring activities.

CDPHE:

5 CCR 1002-41

2 CCR 402-7

Surface Water 

Quality

Construction-related stormwater discharge regulations are 

administered by the EPA at federal facilities in Colorado. 

Non-federal facility construction-related stormwater discharges 

in Colorado are regulated by the Water Quality Control Division of 

CDPHE. 

Ten construction projects required coverage under the EPA 

CGP. Coverage was obtained or continued for each project. 

Notices of Termination were filed with the EPA for three 

projects.

A CDPHE National Pollutant Discharge Elimination System 

Program stormwater permit was obtained for the south 

entrance project as this project exists entirely outside of the 

STM site boundaries.

EPA:

40 CFR 122.26

CDPHE:

5 CCR 1002-61

Reg. 61
32 ENVIRONMENTAL PERFORMANCE REPORT 2011

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & Requirement

Wastewater 

Management

The federal Clean Water Act (CWA) and Colorado Water Quality 

Control Act regulations apply to wastewater management at NREL’s 

STM and DWOP. The Metro Wastewater and Reclamation District 

manages wastewater for much of the Denver metro area, receiving 

wastewater from a number of smaller wastewater districts, 

including the Pleasant View Water and Sanitation District.

Inspection and permitting of individual sewage disposal systems 

(ISDSs) have been delegated to Jefferson County by CDPHE.

All program activities were in compliance with 

requirements.

NREL coordinated with the Pleasant View Water and 

Sanitation District on large volume discharges related to 

construction activities. Water line flushing and sanitizing 

were conducted in accordance with requirements. 

Improvements to one ISDS at the NWTC were completed in 

accordance with requirements.

EPA:

40 CFR 122-136

CDPHE:

5 CCR 1002-31

Hazardous 

Materials 

Management

EO 13423 outlines requirements for Superfund Amendments and 

Reauthorization Act (SARA) Title III, EPCRA compliance, and Toxic 

Release Inventory reductions for DOE facilities. 

Annual hazardous material permits are required by West Metro 

Fire Rescue for the STM and DWOP sites. ReFUEL, located within 

the City and County of Denver, is subject to the Denver Fire Dept. 

Hazardous Materials Information System (HMIS) requirements, 

including permitting, inventory, and annual inspection. 

There were no releases of hazardous materials requiring 

reporting.

EPRCA requirements including notification, release 

reporting, and MSDS/Chemical Inventory requirements 

were met. An EPCRA Sec 311-312 Tier II report was submitted 

for reporting year 2010, identifying diesel fuel, petroleum oil 

and sulfuric acid in lead-acid batteries.

West Metro Fire Rescue conducted an annual hazardous 

material inspection and issued permits for all major research 

facilities on the STM campus. The inventory of materials 

at the ReFUEL facility was provided to the Denver Fire 

Department. A required permit was maintained and an 

inspection was conducted by Denver Fire.

EPA:

40 CFR 355,

370, 372

Waste 

Management

The Resource Conservation and Recovery Act (RCRA) established 

requirements for the management of regulated waste. In Colorado, 

CDPHE administers waste regulations under authority delegated 

by the EPA. 

NREL holds five EPA generator identification numbers, one 

for each of its sites. All regulatory notifications were updated 

and applicable waste generator fees were paid. 

Due to three calendar months of episodic hazardous 

waste generation at volumes greater than 1000 kg per 

month and in anticipation of additional pilot plant research 

experiments, the STM facility revised its waste generator 

status to large quantity generator in October 2011. 

Four NREL facilities are categorized as conditionally exempt 

small quantity generators.

EPA:

40 CFR 260— 

280

CDPHE:

6 CCR 1007-3

Storage Tank 

Management

ASTs are regulated in Colorado by the Colorado Department of 

Labor and Employment (CDLE) Oil Inspection Section under the 

Colorado AST regulation 7 C.C.R. 1101-14. Colorado requires that 

ASTs 660 gallons or larger be permitted prior to installation and 

registrations submitted annually.

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

activities occurred during 2011. 

Annual AST registrations were submitted to the CDLE for 

two registered ASTs.

A 6,000-gallon stainless steel ethanol storage tank, which 

was temporarily removed from service in 2010, was placed 

back into service in June 2011, following replacement of 

piping.

CDLE:

Division of Oil 

and Public 

Safety (DOPS) 

Storage Tank 

Regulations,

7 C.C.R. 1101-14
ENVIRONMENTAL PERFORMANCE REPORT 2011 33

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & Requirement

Spill 

Prevention 

and 

Response

SPCC plans are required by EPA and Colorado regulations for 

facilities that meet certain oil storage criteria. In general, a facility 

must have an SPCC plan if the facility stores more than 1,320 

gallons of oil or where a spill has the potential to enter a Water of 

the United States.

Three SPCC plans (for the STM, NWTC and ReFUEL facilities) 

were revised to address changes to EPA SPCC regulations 

and the Colorado AST regulations.

No spills requiring reporting occurred in 2011.

NREL responded to 31 minor spills of diesel or hydraulic 

fluids at STM and two at the NWTC; the size of spills ranged 

from less than 0.1 gallon to 15 gallons. Each spill was cleaned 

up promptly and did not result in any significant impact to 

the environment.

EPA:

Oil Pollution 

Prevention 

40 CFR 112

CDLE:

DOPS 

Storage Tank 

Regulations,

7 C.C.R. 1101-14

Radiological 

Materials 

and Waste 

Management

Emissions are also regulated by Section 112 of the Clean Air Act 

and implemented by the EPA. 40 CFR Part 61 established National 

Emission Standards for Hazardous Air Pollutants (NESHAPs), and, 

more specifically, Subpart H, sets such standards for radiological 

materials.

DOE O 458.1, Radiation Protection of the Public and the Environment

cancelled DOE O 5400.5. This order establishes radiation emission 

limits for DOE facilities. 

The effective dose equivalent to the public from NREL 

activities was 0.0054 mrem per year, far below the 10 mrem 

per year limit.

Internal procedures govern generation, storage and disposal 

of radioactive wastes and incorporate the applicable 

provisions of DOE orders for low-level wastes. 

No low-level radioactive waste was generated. Small 

quantities of low-level radioactive waste are currently 

in storage awaiting off-site disposal. No other types of 

radioactive wastes are generated.

EPA:

40 CFR 61,

Subpart H

DOE:

DOE O 5400.5 

DOE O 458.1

NEPA NEPA requires that federal agencies determine environmental 

impacts of proposed federal actions and alternatives. DOE 

implements NEPA in 10 CFR 1021.

NREL was in compliance with the DOE NEPA Implementing 

Regulations. 

Five hundred and fifteen NEPA reviews were conducted for 

project activities on and off site. Of these, a more detailed 

environmental review was conducted for 30 activities. Two 

projects were determined to require an EA.

Council for

Environmental 

Quality:

40 CFR 

1500–1508

DOE:

10 CFR 1021

Wildlife 

Management

The Migratory Bird Treaty Act (MBTA) of 1918 is the main driver for 

protection of migratory birds in the United States. The MBTA and 

amendments implements several treaties between the U.S., Great 

Britain, Mexico, Japan, and the former Soviet Union. The MBTA 

prohibits the taking, killing, or possession of migratory birds, nests, 

and eggs.

Under Colorado Revised Statute 33-6-128: Damage or Destruction 

of Dens or Nests—Harassment of Wildlife, no wildlife dens or nests, 

young or eggs may be damaged or destroyed unless permitted by 

the Colorado Division of Parks and Wildlife and it is unlawful for any 

person to willfully harass wildlife including birds.

Under the “Memorandum of Understanding (MOU) between 

DOE and the USFWS Regarding Implementation of EO 13186, 

Responsibilities of Federal Agencies to Protect Migratory Birds” 

DOE agrees to integrate migratory bird conservation principles, 

measures, and practices into agency activities, and avoid or 

minimize adverse impacts on migratory bird resources and their 

habitats.

The Wildlife Management Program implements measures 

to allow NREL to meet or exceed regulatory requirements. In 

2011, activities demonstrating compliance included: 

A Migratory Bird Conservation Plan for NREL sites was 

developed. This plan provides guidance for specific types of 

projects that have the potential to impact migratory birds 

and provides best management practices.

Bird-friendly glass windows, designed to minimize bird 

collisions, were installed at the new STM parking garage 

scheduled to open in 2012.

No migratory birds were taken intentionally during the 

conduct of any of the laboratory’s activities.

Several wildlife surveys were conducted at the STM and 

NWTC sites to better inform wildlife management.

U.S. Fish & 

Wildlife Service:

MBTA 16 USC 

703-712

Colorado 

Division of Parks 

and Wildlife: 

CRS 33-6-128

MOU between 

DOE and the 

U.S. Fish and 

Wildlife Service 

(USFWS) 

EO 13186
34 ENVIRONMENTAL PERFORMANCE REPORT 2011

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & Requirement

Endangered 

Species and 

Species of 

Concern

The Endangered Species Act (ESA) is intended to protect 

threatened and endangered wildlife and plant species and 

associated critical habitat. 

The USFWS lists seven species in accordance with the ESA as 

threatened, endangered, or a candidate for listing that could 

potentially occur in Jefferson County. Of these, three have 

the potential to occur on the STM or NWTC sites including 

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

orchid, and the Colorado butterfly plant. 

NREL periodically conducts surveys for declining wildlife 

species and rare plants focusing on species that are federally 

protected, state protected, or otherwise considered 

imperiled or declining. In 2010 at STM and 2011 at the 

NWTC, surveys were conducted and no protected species 

were found at the STM or NWTC sites. 

U.S. Fish & 

Wildlife Service:

50 CFR 17

Vegetation 

Management

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) 

regulates the use, storage, and disposal of herbicides and 

pesticides. For application of certain types of herbicides designated 

as “restricted use” by the EPA, a certified applicator must be used.

EO 13112, Invasive Species requires the control of invasive species 

at federal facilities. In Colorado, the Department of Agriculture 

Commissioner develops and implements state noxious weed 

management plans for three categories of weed species. Class A 

plants are targeted for eradication. Class B species are subject to 

management plans designed to stop their continued spread. Class 

C species are subject to plans designed to support the efforts of 

local governing bodies to facilitate more effective integrated weed 

management on private and public lands. 

Herbicide and pesticide applications are conducted in 

accordance with regulations and label requirements. 

Restricted-use herbicides are applied by certified 

applicators.

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. 

Approximately two-thirds of the NWTC was treated for 

noxious weeds by herbicide application. Approximately two 

acres of Canada thistle were treated at STM.

Contractors and NREL workers doing landscape 

maintenance were asked to compost landscaping waste, 

including weeds, to reduce the propagation of listed weeds. 

EPA:

40 CFR 162

—171(f)

EO 13112

Wetlands and 

Floodplains

Under EO 11990, Wetlands Protection, federal agencies must 

provide leadership and take action to minimize the destruction, 

loss, or degradation of wetlands, and to preserve and enhance 

the natural and beneficial values of wetlands. Wetlands that meet 

certain soils, vegetation, and hydrologic criteria, are protected 

under the CWA Section 404, which is administered by the USACE.

Jefferson County requires approval of development proposed in 

floodplains within its jurisdiction.

Under 10 CFR 1022, Compliance with Floodplain and Wetlands 

Environmental Review Requirements, for projects that occur in 

floodplains or could affect wetlands, DOE must determine the 

potential impacts, document this in a floodplain and wetland 

assessment, and complete notices of availability to appropriate 

government agencies and interested parties, as well as make a 

public notification in the local area.

None of the wetlands present at NREL facilities have been 

designated “jurisdictional” by the USACE. The STM and 

NWTC sites do not contain any floodplains. However, several 

actions were taken to maintain compliance with wetlands 

and floodplains requirements for the south entrance 

project, located off of DOE property.

A USACE Nationwide Permit No. 14 for Linear Transportation 

Projects was obtained for the permanent loss of 0.25 acres 

of wetlands associated with the south entrance project. This 

loss was mitigated through acquisition of wetland banking 

credits via the South Platte Wetlands Bank in Brighton, 

Colorado. 

A Jefferson County Floodplain Development permit 

was obtained for the south entrance project due to the 

construction of bridge abutments, headwalls, wingwalls, 

riprap and other structural elements within the floodplain. 

In accordance with 10 CFR 1022, a floodplain and wetland 

assessment was prepared to describe the potential impacts 

associated with the construction of the new south access 

road to the STM campus. The public and federal and state 

agencies were notified of the availability of the assessment 

in May 2011 via letter and newspaper advertisement. 

DOE posted a Statement of Findings in June 2011 and 

determined that this project would not result in adverse 

impacts to the 100 year floodplain.

EO 11990

USACE:

CWA Section 

404

10 CFR 1022
ENVIRONMENTAL PERFORMANCE REPORT 2011 35

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & Requirement

Cultural 

Resources

Cultural resources are protected under Section 106 of the National 

Historic Preservation Act (NHPA). Significant cultural resources 

are either eligible for, or listed in, the National Register of Historic 

Places. Cultural resources are defined as any prehistoric or historic 

district, site, building, structure, or object considered important 

to a culture, subculture, or community for scientific, traditional, 

religious, or other reason. NHPA is administered in Colorado by the 

Colorado SHPO.

Two structures at the STM site are listed on the National 

Register of Historic Places. There are no known eligible 

structures at the NWTC.

Construction activities were completed on the new addition 

to the RSF. During preliminary excavations, a few items were 

unearthed that were reviewed for cultural significance, 

though none were found to be of unique value.

As part of the south entrance project, a memorandum of 

agreement was signed with the Colorado SHPO to address 

adverse affects to the two southern most firing lines that 

are contributing features to the Camp George West Historic 

District. To mitigate impacts to these, an interpretive sign 

will be placed in Pleasant View Community Park.

Advisory 

Council 

on Historic 

Preservation:

36 CFR 60

36 CFR 63

36 CFR 79

36 CFR 800

16 USC 470

EMS and 

Sustainability

DOE O 436.1, Departmental Sustainability cancelled DOE O 

450.1A, Environmental Protection Program and DOE O 430.2B, 

Departmental Energy, Renewable Energy and Transportation 

Management. The Order implements the objectives of EO 13423, 

Strengthening Federal Environmental, Energy, and Transportation 

Management, and 13514, Federal Leadership in Environmental, 

Energy, and Economic Performance, which direct federal agencies 

to conserve natural resources, reduce energy use, develop 

renewable energy, reduce GHG emissions, and manage buildings 

and transportation in a sustainable manner.

DOE O 436.1 requires that DOE develop a SSPP to ensure that the 

sustainability goals established in EO 13423 and 13514 are met. 

Individual DOE facilities must develop site specific SSPs designed 

to set goals for the coming year and discuss performance for the 

prior year. 

DOE O 436.1 also requires that DOE facilities implement EMSs that 

are independently verified to meet the requirements of ISO 14001. 

Each year, a SSP is developed to report on past performance 

and set goals for the coming year. These performance goals 

are integrated with the laboratory’s EMS and progress is 

tracked throughout the year. 

NREL’s EMS was registered in August 2011 to the ISO 

14001:2004 international standard for environmental 

management systems by a third party registrar. Annual 

assessments by the registrar verify that NREL meets the ISO 

standard and is continually improving performance.

DOE:

DOE O 436.1

DOE O 450.1A

DOE O 430.2B

N/A DOE O 231.1B, Environment, Safety and Health Reporting was 

implemented to assure that DOE receives timely, accurate 

information about events that have affected or could adversely 

affect the health, safety and security of the public or workers, the 

environment, the operations of DOE facilities. The order requires 

that DOE facilities report specific site environmental information 

annually including environmental management performance, 

environmental occurrences and response, compliance with 

environmental standards and requirements, significant programs 

and efforts, and property clearance activities for property 

contaminated with radiological materials.

NREL reports annually via this Annual Site Environmental 

Report.

DOE:

DOE O 231.1B
36 ENVIRONMENTAL PERFORMANCE REPORT 2011

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & Requirement

Traffic A MAP, finalized in May 2008, was developed to address potential 

environmental impacts from changes in traffic at STM and to 

support an EA Finding of No Significant Impact (FONSI) for several 

projects at the laboratory. The MAP specifies the methods for 

implementing mitigation measures to ensure that the impacts of 

continued and expanded laboratory operations are not significant. 

The MAP requires that: 

• The Denver West Parkway/Denver West Marriott Boulevard 

(DWP/DWMB) intersection operates at a Level of Service (LOS) of D 

or better. 

• The Quaker St. /South Golden Road intersection operates at 

a LOS of D or better.

• Traffic flow to and from the STM east entrance will be 

monitored semi-annually.

• Specific Transportation Demand Management (TDM) 

strategies be implemented as needed to ensure the traffic 

thresholds are not exceeded. Strategies include AWS’s, expanded 

shuttle services, expanded carpools, encouraging walking and 

bicycling, increased use of the Quaker St. entrance, infrastructure 

improvements, and traffic flow control measures.

TDM measures required by the MAP were continued in 2011. 

PM peak hour traffic averages at the DWP/DWMB 

intersection were 260 vehicle trips. The monitoring period 

was October 2010 through April 2011. The MAP threshold 

of LOS D or better is equivalent to a maximum of 387 

vehicle trips per hour entering or leaving the site at the east 

entrance at the afternoon rush hour.

PM peak hour LOS at the DWP/DWMB intersection was at 

LOS B, which does not exceed the MAP threshold of LOS D 

or better.

PM peak hour LOS at the Quaker St. /South Golden Road 

intersection was at LOS B, which does not exceed the MAP 

threshold of LOS D or better.

NEPA EA

Traffic MAP
ENVIRONMENTAL PERFORMANCE REPORT 2011 37

ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS APPLICABLE TO NREL DURING 2011

Type Location/ Description Category Issuing Agency ID # Permit or Registration 

Status

AST for petroleum 

storage

STM PDU AST Registration DOPS 2873-2 Completed

AST for petroleum 

storage

STM SERF AST Registration DOPS 2873-1 Completed

Air Laboratory-wide servicing of CFC-containing 

equipment

Registration APCD 647 Completed

Air DWOP CFC-containing stationary source Registration APCD 647 Completed

Air STM SERF CFC-containing stationary source Registration APCD 647 Completed

Air STM FTLB waste gas combustor Permit APCD 99JE0400 Active

Air STM RFHP wood waste boiler Permit APCD 07JE0277 Active

Air STM fugitive dust from construction activities Permit APCD 08JE0889L Active

Air STM RSF diesel-fired emergency generator #1 Permit APCD 10JE1400 Active

Air STM RSF diesel-fired emergency generator #2 Permit APCD 11JE1303 Active

Air STM FTLB diesel-fired emergency generator Permit APCD 10JE1630 Active

Air NWTC Site 4.0 diesel-fired emergency generator Permit APCD 10JE1712 Active

Air STM parking garage diesel-fired emergency 

generator

Permit APCD 11JE1997 Active

Air STM ESIF diesel-fired emergency generator Permit APCD 11JE3542 Active

Alcohol STM IBRF alcohol fuel production Permit TTB AFP-CO-00255 Active

Alcohol STM tax-free alcohol use Permit TTB TF-CO-0331 Active

Drinking water system NWTC drinking water system ID number Registration WCQD CO0230860 In Effect; Does Not 

Expire

Earth disturbance STM parking lot grading permit Permit Jefferson County 10-127351GP Active

Earth disturbance STM stormwater swale grading permit Permit Jefferson County 09-106687GP Closed

Groundwater well STM groundwater monitoring well MW-1 Permit DWR 37232 Active
38 ENVIRONMENTAL PERFORMANCE REPORT 2011

ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS APPLICABLE TO NREL DURING 2011

Type Location/ Description Category Issuing Agency ID # Permit or Registration 

Status

Groundwater well STM groundwater monitoring well MW-2 Permit DWR 37229 Active

Groundwater well STM groundwater monitoring well MW-3 Permit DWR 37228 Active

Groundwater well STM groundwater monitoring well MW-4 Permit DWR 37231 Active

Groundwater well STM groundwater monitoring well MW-5 Permit DWR 37230 Active

Hazardous materials STM WHF hazardous material storage and use 

permit

Permit West Metro Fire 

Rescue 

4976 Active

Hazardous materials STM SERF hazardous material storage and use 

permit

Permit West Metro Fire 

Rescue 

4982 Active

Hazardous materials STM S&TF hazardous material storage and use 

permit

Permit West Metro Fire 

Rescue 

4979 Active

Hazardous materials STM FTLB hazardous material storage and use 

permit

Permit West Metro Fire 

Rescue 

4977 Active

Hazardous materials STM IBRF (AFUF) hazardous material storage and 

use permit

Permit West Metro Fire 

Rescue 

4978 Active

Hazardous materials STM Shipping & Receiving hazardous material 

storage and use permit

Permit West Metro Fire 

Rescue 

4980 Active

Hazardous materials DWOP building 16 hazardous material storage and 

use permit

Permit West Metro Fire 

Rescue 

4981 Active

Hazardous materials ReFUEL hazardous material storage and use permit Permit Denver Fire 

Department

32178 Active

Hazardous waste DWOP RCRA hazardous waste generator status 

EPA ID

Notification HMWMD CO4890000017 Completed

Hazardous waste STM RCRA hazardous waste generator status EPA ID Notification HMWMD CO3890090076 Completed

Hazardous waste JSF RCRA hazardous waste generator status EPA ID Notification HMWMD COD980805162 Completed

Hazardous waste NWTC RCRA hazardous waste generator status EPA 

ID

Notification HMWMD COD983802448 Completed

Hazardous waste ReFUEL RCRA hazardous waste generator status 

EPA ID

Notification HMWMD COR000207563 Completed

Historic registration STM amphitheater Registration NPS 93000378 In effect; does not 

expire
ENVIRONMENTAL PERFORMANCE REPORT 2011 39

ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS APPLICABLE TO NREL DURING 2011

Type Location/ Description Category Issuing Agency ID # Permit or Registration 

Status

Historic registration STM stone bunker Registration NPS 93000379 In effect; does not 

expire

Stormwater NWTC pedestrian safety construction project Permit EPA COR10ES2F Active

Stormwater STM stormwater detention basin construction 

project

Permit EPA COR10EL5F Active

Stormwater STM stormwater detention Basin A construction 

project

Permit EPA COR10EU5F Active

Stormwater STM ESIF construction project Permit EPA COR10EH4F Active

Stormwater STM parking garage and south entrance 

construction project

Permit EPA COR10EE0F Active

Stormwater NWTC dynamometer expansion construction 

project

Permit EPA COR10EP6F Active

Stormwater STM RSF1 infrastructure Zone 1 construction 

project

Permit EPA COR10CY5F Closed

Stormwater STM RSF infrastructure Zone 2 construction project Permit EPA COR10DH3F Closed

Stormwater STM RSF II Construction Project Permit EPA COR10E21F Active

Stormwater STM IBRF construction project Permit EPA COR10DA6F Active

Stormwater STM west gate improvements construction project Permit EPA COR10E08F Active

Stormwater STM vehicle test pad construction project Permit EPA COR10E12F Active

Stormwater NWTC PV installation construction project Permit EPA COR10DD2F Closed

Stormwater NWTC row 4 infrastructure construction project Permit EPA COR10DB4F Closed

Stormwater NWTC site entrance construction project Permit EPA COR10E06F Active
40 ENVIRONMENTAL PERFORMANCE REPORT 2011

The Air Quality Protection program is intended to achieve a 

number of goals including minimization of all types of air emissions, tracking of air emissions from the larger on-site sources, 

confirmation that on-site sources have air permits as required, 

and meeting EPA and Colorado air emissions and permitting 

requirements.

NREL’s goal is to maintain its air emissions at a low level, maximizing air quality and minimizing permitting and compliance requirements. Minimizing air emissions creates direct health benefits to 

both surrounding neighbors and the Denver metropolitan area in 

general. In general terms, the more air emissions a facility puts into 

the air, the more complex the air permit must be that allows such 

emissions. Such permits also require more extensive and expensive emission tests and reporting of those emissions.

NREL environmental staff actively participate in project planning, 

safety evaluations, readiness verifications, and operations activities. 

This participation results in awareness of planned air emissions 

and allows environmental staff to obtain necessary regulatory 

approval for those emissions and to maintain a current and accurate air emission inventory.

PROGRAM MANAGEMENT

The EPA Clean Air Act requires specific permitting and emission 

controls when specific facility emission levels are exceeded or 

individual equipment sizes are reached. For example, a Title V air 

permit would be required if an NREL facility emission level were to 

exceed 100 tons per year for a criteria pollutant such as: nitrogen 

oxides (NOx), VOC, particulate matter (PM10), carbon monoxide 

(CO), or sulfur dioxide (SO2). Under that same regulation, a Title V 

permit would be required if a single HAP level were to exceed 10 

tons per year, or the total emissions of all HAP pollutants at one 

facility were to exceed 25 tons per year.

The Colorado APCD requires reporting of HAP emissions at much 

more stringent limitations. The limitations vary for different HAPs 

based on their toxicity and the distance of the release from a facility property boundary. The reporting levels can vary from 50 to 

5,000 pounds per year.

Colorado reporting of air emissions is required for an item of 

equipment that emits 1 ton per year or more of any criteria air 

pollutant. A Colorado air permit may be required if an item of 

equipment emits as little as 1 ton per year of any criteria pollutant. 

The trigger level varies from 1 to 10 tons per year depending on 

the pollutant and whether the source is located in an attainment 

or non-attainment area for that specific pollutant.

During 2011, NREL maintained nine Colorado air permits. Five of 

these permits are for emergency generators, one is for the RFHP, 

two are for specific research activities, and an additional permit is 

for fugitive emissions from construction.

Criteria, Hazardous, Non-Criteria Pollutants, and ODS 

The Clean Air Act and State of Colorado laws and regulations 

delineate several main categories for air pollutants: 

■ Criteria air pollutants, e.g., carbon monoxide, nitrogen oxides, 

sulfur dioxide, particulate matter, respirable particulate (PM10

and PM2.5), ozone, and lead, all of which have been issued 

National Ambient Air Quality Standards (NAAQS) by the EPA

■ Non-criteria pollutants (e.g., ammonia, hydrogen sulfide, 

pesticides, certain VOCs classified as ozone precursors, metallic 

compounds, GHGs, and corrosives). Non-criteria pollutants are 

not associated with an EPA-specified NAAQS.

■ HAPs (includes a specific list of organic compounds, metals, 

corrosives, asbestos, radionuclides, and pesticides established 

by the EPA)

■ Ozone-depleting substances (e.g., chlorofluorocarbons or 

“Freon” and hydro chlorofluorocarbons that are being phased 

out of use in comfort heating and cooling systems and 

equipment)

■ GHG compounds that have been implicated in global 

warming.

There are various Colorado and EPA notification, permitting and 

reporting thresholds for criteria, non-criteria, hazardous, and GHG 

pollutants. The primary potential sources of these pollutants 

at NREL include process heat boilers, process cooling systems, 

comfort heating and cooling systems, emergency generators, 

experimental laboratory hoods and ventilation systems, pilot and 

large-scale research projects, and small equipment with gasoline 

or diesel engines. NREL maintains an air emission inventory to 

7 Air Quality Protection

2011 Accomplishments and Highlights

■ Updated NREL’s air emissions database including 

new sources and the use of equipment specific 

emission factors where possible. This has resulted 

in a more accurate emission inventory. 

■ Created an inventory of HAP emissions associated 

with PV laboratory research activities. This allows 

more accurate assessment of NREL compliance 

with HAP reporting and permitting requirements.
ENVIRONMENTAL PERFORMANCE REPORT 2011 41

track potential air emissions and identify whether notification and 

permitting could be required for a particular facility or activity. 

Certain equipment and emissions are exempt from reporting and 

permitting by CDPHE APCD. NREL maintains several air permits 

issued by CDPHE for “minor” sources including emergency generators and pollution control systems at the STM and NWTC sites. All 

of these individual emission sources and each NREL facility are 

considered by the EPA and APCD to be minor sources with minimal permit and compliance requirements.

Fugitive particulate emissions from construction activities occur at 

NREL’s STM and NWTC sites. Particulate emissions from construction sites larger than 25 acres are subject to APCD fugitive particulate emissions permits. Appropriate permits have been obtained 

and are in effect for construction activities at the STM and NWTC 

facilities. One such Air Pollutant Emission Notice (APEN) was in 

effect for construction at the NWTC at the beginning of 2010. As 

the construction area at the NWTC became smaller, the APEN was 

no longer needed and was allowed to expire by its own terms and 

conditions. A fugitive particulate emissions permit is not currently 

needed for the NWTC.

Permitting 

Most sources of air emissions from NREL laboratory and facility 

operations in 2011 were of small scale and did not require permitting. While permitting thresholds may vary, depending on the 

pollutant, the APCD must be notified if more than one ton per 

year of one or more criteria pollutants is emitted from an individual item of equipment. Emergency generators generally require 

permitting even if criteria emissions are less than one ton per year. 

Projected emissions for new sources were evaluated and air emission reporting and permitting was performed as required. 

NREL holds one site-wide permit for particulate air emissions from 

construction, two air emissions permits for pilot-scale research, 

one for the operation of the RFHP, and five permits for emergency 

generators.

An evaluation of HAP emissions for NREL activities indicated that 

those emissions were well below all reporting and permitting 

threshold values. HAP emissions reporting and permitting trigger 

levels vary with the HAP compound, the height of the emission 

point and distance of that point from the nearest property boundary. Those trigger levels can vary from approximately 50 pounds 

per year to more than 2,000 pounds per year. The expected 

ammonia emissions from the IBRF project previously mentioned 

will exceed the applicable Colorado reporting criteria. Therefore, 

an air permit to install and operate an ammonia scrubber is being 

obtained from CDPHE APCD. That permit is expected to be issued 

by the APCD in 2012.

Additional air permit applications were submitted to the APCD 

during 2011 for the new STM parking garage emergency generator and an emergency generator for the ESIF laboratory (currently 

under construction). The APCD is expected to issue these air 

permits during 2012. 

Ozone-Depleting Substances

EPA regulation 40 CFR 82, Protection Of Stratospheric Ozone, 

requires that appliances and stationary appliances containing 

more than 50 pounds of Class I or II ODS refrigerant must meet 

specific EPA record keeping, ODS recovery, leak monitoring and 

leak repair requirements.

There are three categories of ozone-depleting substances (ODSs) 

registration and certification in Colorado (5 CCR 1001-19, Regulation 15, Control of Emission of Ozone Depleting Compounds):

1. Facilities where maintenance activities are performed on 

refrigeration equipment containing ODS are required to file an 

annual notification with CDPHE

2. Technicians that service ODS-containing equipment must be 

EPA-certified

3. Refrigeration equipment larger than 100 hp containing ODSs 

must be registered annually with CDPHE. Refrigeration equipment that uses non-ODS compounds are not required to be 

registered.

The laboratory has a total of three chillers that are larger than 

100 hp, contain ODS compounds and are thus registered with 

CDPHE—two located at the Solar Energy Research Facility (SERF) 

on the STM site, and one at DWOP. During 2011 NREL performed 

the necessary annual notification that maintenance activities 

occurred, renewed the registration for the three chillers and 

confirmed that all technicians servicing ODS-containing equipment are EPA-certified.

While the vast majority of refrigeration appliances at NREL contain 

non-ODS refrigerants or only very small amounts of ODS refrigerants, the laboratory does have several appliances containing more 

than 50 pounds of ODS material. As such, operators must maintain 

records of service for this equipment.

Street Sanding 

CDPHE regulations (5 CCR 1001-18, Regulation 16, Street Sanding 

Emissions) require federal, state, and local government facilities to 

track street sanding in the wintertime, and to minimize sand use. 

Sanding of roads followed by vehicle activity turns sand and gravel 

into ever finer particulate which becomes airborne easily due 

to that traffic. The resulting fine particulate (PM10 or smaller) is a 

significant contributor to particulate pollution in the Denver area. 

That pollution contributes to breathing and health problems for 

susceptible individuals and prompted EPA and Colorado to issue 

regulations to minimize this source of air pollution.

NREL complies with the Colorado sanding requirements and files 

an annual sanding report with CDPHE. From October 2009 to 

May 2010, NREL used 50 tons of sand and 36 tons of deicer in 25 

deployments while maintaining 12 miles of roadway. From October 2010 to May 2011, NREL applied 50.5 tons of deicer during 20 

deployments while maintaining the same length of roadway. The 

deicer used does not contain sand and minimizes fugitive particulate emissions from snow removal operations. No sand was used 
42 ENVIRONMENTAL PERFORMANCE REPORT 2011

during the 2010-2011 winter season and the reduction of 50 tons 

of sand compared to the 2009—2010 period provided a direct air 

quality benefit to both NREL neighbors and the Denver area.

GHG Emissions Tracking and Permitting

EPA regulations require that certain facilities which emit GHGs 

track and report the amount of those emissions. The purpose of 

this reporting is to better identify actual emissions of such gases 

across the United States and provide the EPA with data upon 

which to base future GHG regulations. The reporting and permitting of these emissions is required under the EPA PSD regulation, 

Title V Tailoring Rule (Tailoring Rule), and the EPA GHG Mandatory 

Reporting Rule (MRR). The Tailoring Rule requires air emission 

permitting of GHG emissions if CO2e emissions are greater than 

100,000 U.S. tons per year. The MRR requires annual GHG reporting 

to EPA if CO2e emissions are greater than 25,000 MT per year.

GHGs include CO2, methane, nitric oxide (N2O), and ODS chlorofluorinated hydrocarbons including hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and certain other fluorinated gases. 

For more information on how NREL is reducing its emission of 

GHGs, please see section 4 Sustainability. 

2011 COMPLIANCE SUMMARY AND ACTIVITIES

Compliance with the wide variety of air permit and emission limitation requirements is an on-going and significant activity at NREL. 

The nature of research experimental activity may require significant changes in technical direction and equipment based on the 

results obtained during those experiments. Such changes may 

alter air emissions. Achieving compliance in a research environment is both necessary and challenging.

The following compliance activities were performed during 2011, 

assuring compliance with air regulations and improved implementation of the Air Quality Protection program:

■ All program activities were in compliance with requirements.

■ NREL did not exceed any air permit standard or other air regulatory requirement at any facility.

■ On behalf of the CDPHE APCD, Jefferson County completed 

an air inspection of the NWTC Site 4.0 emergency generator in 

November 2011. No issues were identified.

■ Completed an evaluation of NREL’s compliance with EPA 

and APCD permitting and emissions control requirements. It 

was confirmed that NREL is in compliance with all Colorado 

and EPA permit requirements and that all NREL facilities and 

individual permitted equipment items are classified as minor 

sources.

■ Obtained air permits for two emergency generators necessary for newly constructed laboratory facilities. Obtained an 

air permit for an ammonia scrubber and particulate baghouse 

used to eliminate ammonia and particulate emissions from the 

IBRF cellulose digestion large pilot-scale project. Performed 

emission testing and submitted necessary forms to the APCD 

to convert construction permits to final air permits for two 

emergency generators. All existing NREL air permits were 

renewed during 2011.

■ All required registrations and permit renewals were performed 

during 2011 for Ozone Depleting Substance-using equipment. 

NREL facilities servicing refrigeration equipment were registered. Confirmed that all NREL refrigeration service personnel 

have obtained the EPA and Colorado required training and 

certification.

■ Evaluated NREL’s 2010 CO2

e and GHG emissions. The GHG 

inventory shows that NREL GHG emissions are below the 

exempt level for EPA reporting and permitting rules. NREL’s 

2011 CO2e inventory is 4,020 U.S. tons, or 3,555 MT. NREL emissions of GHGs are not expected to meet reporting requirement 

thresholds into the foreseeable future.

■ The required street sanding report was provided to the APCD 

and Jefferson County in 2011.

Water quality is critical to human health and the health of our 

natural ecosystems. At NREL, the focus of water quality protection 

is on four main areas: 

1. Drinking water

2. Wastewater

3. Groundwater

4. Surface water. 

8.1 DRINKING WATER

NREL operates a drinking water distribution system at the NWTC, 

serving about 150 employees. Drinking water is purchased from 

local municipalities and transported by truck to the site, where 

it is transferred to a large holding tank with a capacity of 15,000 

gallons. Water is pumped from the holding tank to a day tank from 

which it is circulated around the site for use. There is no treatment 

of the water, but chlorine is added to boost disinfectant levels. 

The system is permitted by the State of Colorado, which requires 

monitoring for a number of parameters on an annual basis. The 

water is tested for residual chlorine levels, bacteria, disinfectant 

by-products, and lead and copper in the same ways municipal 

water systems are tested. NREL provides good, safe drinking water 

to the NWTC employees, and has not exceeded any of the drinking water standards over the past five years.

There are a number of organizations that can take credit for the 

success of the NWTC water system. NREL’s Site Operations Office 

provides primary oversight for the day-to-day operation of the 

8 Water Quality Protection
ENVIRONMENTAL PERFORMANCE REPORT 2011 43

system, aided by a state-licensed contract operator who visits 

the site weekly to check the details of the system operation 

and performance. The NREL EHS Office assists Site Operations 

in tracking state requirements and completing required reports 

and managing contacts with regulators. NREL’s management of 

the drinking water system is subject to assessments by DOE and 

compliance inspections by CDPHE. 

PROGRAM MANAGEMENT

As a public water system regulated by the state of Colorado, the 

NWTC water system must comply with the SDWA and federal and 

state regulations based on the SDWA authority. EPA has established allowable levels for drinking water constituents known as 

MCLs, which can be found at 40 CFR 141. Colorado has adopted 

these MCLs into the Colorado Primary Drinking Water Regulations 

at 5 CCR 1003-1. These regulations establish the state’s authority 

to regulate drinking water providers to assure safe, reliable water 

supplies, and to implement EPA’s special rules. 

The primary requirement is to test the water quality following a 

monitoring plan issued by the state each year. The plan identifies 

which tests are to be performed and at what frequency. Monthly 

tests are required for bacteria and disinfectant levels, while disinfectant by-products (DBPs) are sampled for once a year, and lead 

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

shows the results of the chlorine monitoring for 2011.

The NWTC has not exceeded any of the SDWA’s MCLs in the 

past five years. Once, in 2006, NREL exceeded the MCL for 

trihalomethanes, a class of DBPs. One sample taken was 0.1 part 

per billion over the maximum of 80. The levels dropped below the 

MCL in the next quarterly sample and have remained there, allowing the monitoring frequency to return to an annual basis.

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ All monitored parameters in 2011 met applicable SDWA 

requirements.

■ Triennial sampling for lead and copper was conducted in 2011; 

the concentration of these metals was well below the MCLs at 

all sample locations.

■ An external assessment of the drinking water system in 

2011 found no non-conformities with program or regulatory 

requirements. Several recommendations for program improvements were made, each of which is being addressed.

8.2 GROUNDWATER

Groundwater protection in the West is particularly important 

because these resources are limited yet relied upon by increasing numbers of residents for water supplies. NREL’s groundwater 

protection program is based on the philosophy that the prevention of groundwater contamination is far better than remediation. 

Both the STM and the NWTC sites 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 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 Dawson formation is the shallowest of the Denver 

Basin aquifers and is the one most relied upon by the groundwater users in the basin. The northern extent of the Dawson aquifer 

is located approximately 20 miles to the south and east of the STM 

site; consequently, wells drilled at either the STM site or the NWTC 

2011 Accomplishments and Highlights

■ In 2011, 400,000 gallons of drinking water was 

safely provided to NWTC users. 

Results of 2011 chlorine monitoring

Average Monthly Chlorine Residual 2011

5.00

4.00

3.00

2.00

1.00

0

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

Cl2 Residual,

mg/L

Month

Maximum

Allowed

Average Monthly

Chlorine Residual
44 ENVIRONMENTAL PERFORMANCE REPORT 2011

would not intersect the Dawson aquifer, nor would a source of 

contamination affect the groundwater quality in this 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 to protect groundwater be established. 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, either temporary or permanent, to contain materials associated with construction activities or on-going research.

PROGRAM MANAGEMENT

The state of Colorado regulates the installation of groundwater 

wells through the state engineer’s office, which requires a permit 

for drinking water, groundwater monitoring, or geothermal 

installations. 

There are currently five permitted monitoring wells at the STM site 

and none at the NWTC. There are currently no ongoing groundwater monitoring activities being conducted, however these wells 

remain open for possible future use. Should we conduct activities that could impact groundwater, a groundwater monitoring 

program would be implemented and additional groundwater 

monitoring wells would be installed as needed.

2011 COMPLIANCE ACTIVITIES

There are no compliance activities associated with the 

Groundwater Program.

8.3 SURFACE WATER

NREL’s Surface Water Protection program seeks to preserve the 

quality of receiving waters to which the STM and NWTC campuses 

discharge. These receiving waters include Lena Gulch at the STM 

site and Coal Creek and Rock Creek at the NWTC site. Water quality protection is accomplished through management of runoff 

emanating from active construction sites, inclusion of project 

design elements that promote infiltration and detention, and 

management of campus areas not under construction to minimize erosion and support infiltration.

Due to the large number of active construction sites at both 

campuses, the focus of NREL’s water quality protection program 

during 2011 has been to manage construction site runoff which 

2011 Accomplishments and Highlights

A major administrative improvement for groundwater 

protection was made in 2011 when NREL revised its 

procedure for management of ASTs and completely 

rewrote spill prevention, control and countermeasure 

plans for the STM and NWTC sites (see section 9.3 

Aboveground Storage Tank Management for details). 

The spill plans describe in detail all areas where 

petroleum oil products are stored, potential pathways 

should there be a release, and the immediate actions 

to be take in such an event. Careful planning and 

preparation for events such as spills from ASTs bolster 

NREL’s defenses against groundwater contamination.

Receiving waters include Lena Gulch southeast of the STM campus. 

Photo by Genny Braus, NREL/PIX 20953

Rain water from the RSF passes through landscaped areas before 

release to the storm sewer. Photo by Robb Williamson, NREL/PIX 20954
ENVIRONMENTAL PERFORMANCE REPORT 2011 45

has the potential to significantly impact rivers, lakes, ditches, and 

other waters of the United States. Sediment, debris, and chemicals transported to these water bodies via stormwater runoff can 

harm or kill fish and other wildlife either directly or by destroying 

aquatic and riparian habitat. High volumes of sediment can result 

in stream bank erosion and clogging of waterways.

Prior to construction, NREL implements an interdisciplinary planning and design process that involves NEPA reviews and approvals, and the assessment of design documents for potential impacts 

to stormwater and receiving waters. Design teams are encouraged 

to incorporate low impact design elements to retain stormwater 

on-site through infiltration and promote evapotranspiration. NREL 

continues to monitor final design documents and construction 

implementation to look for additional opportunities to reduce 

runoff quantity and enhance runoff quality. 

Erosion and sediment controls, proper chemical storage, fueling 

procedures, and good housekeeping practices are implemented 

during construction according to the stormwater plans developed 

by contractors and reviewed by NREL EHS staff. Regular inspections by contractors and periodic site inspections by NREL staff 

are conducted to verify that the controls are functioning properly. 

Any repairs or modifications to the plans are documented on 

an inspection report; prompt actions are required to correct any 

noncompliant conditions. 

Management of campus areas not under construction is intended 

to minimize erosion, support infiltration of rain water and snowmelt, and prevent contamination of stormwater with hazardous 

materials. Vegetation and landscaping are maintained to prevent 

erosion. Infiltration of precipitation is achieved through detention 

basins and grassy swales as well as design elements including 

porous pavement and diversion of roof and perimeter drains to 

landscaped areas. Dumpsters are kept covered, hazardous wastes 

are stored indoors or in covered areas, and outdoor spills of fuels, 

hydraulic fluids, and other materials are cleaned up immediately.

2011 Accomplishments and Highlights

■ Completion of the STM stormwater detention basin to 

a point where it can now detain runoff from the STM 

Middle Drainage Basin, thus greatly improving the quality and quantity of runoff leaving the STM campus. The 

project will be finalized in 2012. 

■ Modifications to Denver West Parkway in the STM West 

Campus to redirect accumulated runoff in the roadway 

toward the NREL drainage conveyance swales, thus 

reducing the potential for surpassing the available 

volume of off-site conveyances.

■ Addition of curb and gutter along the north side of the 

STM FTLB service road which drastically reduces sediment entrainment in runoff originating from the roadside parking areas, Vehicle Testing and Integration Facility 

and the adjacent steep slopes. Riprap was also placed 

on the upper banks of the Middle Drainage where the 

roadway runoff enters the middle drainage to further 

drop any sediment load and protect bank stability.

■ All projects, regardless of acreage, draw upon low impact 

design elements such as: 

● Porous pavement. Porous pavers were included in 

the STM RSF courtyards and driveways, the North 

and East Loop Roads, and in the new garage entryway to promote infiltration. 

● Vegetated bioswales. These landscape elements 

were used in the RSF courtyards to promote infiltration and to filter roof drainage and stormwater runoff 

diverted from perimeter drains and in select areas 

surrounding the new parking garage for infiltration 

and pollutant uptake by vegetation.

● Native prairie grasses, shrubs, and trees. Vegetation 

was planted to prevent erosion and sedimentation due to stormwater and snowmelt, especially 

on steep slopes. Native plants are used as they are 

adapted to the local climate and can thrive without 

additional watering once established.

Melting snow from the roof of the RSF flows into containment 

structures and then into landscaping around the building. Photo by 

Dennis Schroeder, NREL/PIX 18640

Erosion control blanket and hydromulch stormwater BMPs at the STM 

campus. Photo by Kurt Schlomberg, NREL/PIX 21210
46 ENVIRONMENTAL PERFORMANCE REPORT 2011

PROGRAM MANAGEMENT

The federal CWA, amendments, and implementing regulations in 

40 CFR Part 122 apply to stormwater discharges from construction 

activities that disturb greater than one acre. As a federally owned 

facility, the EPA is the regulating authority for stormwater at the 

NREL campuses. For construction sites that disturb greater than 

one acre, a Notice of Intent (NOI) must be filed with the EPA to be 

covered under the CGP and a site-specific Stormwater Pollution 

Prevention Plan (SWPPP) must be prepared.

At NREL, the SWPPP implements both the requirements of the 

EPA’s CGP and NREL-specific requirements. The SWPPP is developed by the subcontractor using a template provided by NREL 

which includes the required elements that must be incorporated. 

The SWPPP must be signed and certified per EPA CGP signatory 

requirements and must be accepted by the EHS Office prior to 

filing of NOIs. 

While construction sites less than one acre are not regulated 

by the EPA and typically involve minimal disturbance within a 

short timeframe, these sites still have the potential to contribute 

pollutants to stormwater runoff. For these sites, NREL may require 

subcontractors to comply with basic elements of stormwater 

pollution prevention including development of an abbreviated 

SWPPP to document basic contact, project, and best management 

practice (BMP) information, as well as a site-specific erosion and 

sediment control plan showing the locations of key site characteristics and BMPs. 

EISA Section 438 requires agencies reduce stormwater runoff from 

federal development projects to protect water resources. Agencies 

can comply using low impact design elements such as porous 

pavers, cisterns, and bioswales. In addition, EO 13514, Federal 

Leadership in Environmental, Energy and Economic Performance 

sets requirements for efficient water use, reuse, and stormwater 

management. The laboratory’s efforts to conserve water and 

preserve water quality through low impact design are described 

above, with additional information provided in the Sustainability 

chapter. 

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ Seven construction projects at STM, and three at the NWTC, 

required coverage under the EPA CGP. Permit coverage was 

obtained or was continued for each. Three permits were terminated in 2011. For a list of permits, see section 6 Compliance 

Summary. 

■ In addition, a state stormwater permit was obtained for the 

construction of a new south entrance to the STM campus. 

Because this project exists entirely outside of the STM site 

boundaries, a CDPHE, National Pollutant Discharge Elimination 

System Program stormwater permit was required. 

■ For construction activities that did require permits, all activities were conducted according to compliance requirements. 

Several construction sites received periodic monitoring from 

local regulatory officials; no non-compliances were noted.

■ Drainage studies for the NWTC and the STM central drainage were conducted as part of master planning efforts and 

to demonstrate compliance with both EISA Section 438 and 

local drainage regulations. Both studies identified existing and estimated buildout runoff volumes. The new STM 

stormwater detention basin outfall plate, originally sized for 

local jurisdictional release rates, was redesigned to slow the 

outflow of water to historic release rates, thereby meeting EISA 

requirements.

■ Two assessments were conducted of the program. An internal 

assessment identified three non-conformities with internal 

program requirements. Several procedures and inspection 

forms contained deficiencies and needed to be updated. 

In addition, an external assessment was conducted on the 

program. No non-conformities with program requirements 

were identified and three opportunities for improvement were 

noted, along with several best practices. All non-conformities 

and opportunities for improvement from each assessment are 

being addressed.

8.4 WASTEWATER

The majority of wastewater from the STM and DWOP facilities 

flows into the Pleasant View Water and Sanitation District’s (Pleasant View) system, and ultimately to the Metropolitan Wastewater 

Reclamation District’s (Metro) central treatment plant. Wastewaters 

from the JSF and the ReFUEL facility also flow to Metro’s treatment 

plant. There is a small septic system consisting of a tank and leach 

field on the mesa top at STM, serving the Solar Radiation Research 

Laboratory (SRRL), because there is no sanitary service to that area. 

The NWTC also lacks sanitary service, so the site has two septic 

systems that include tanks and leach fields for the treatment of 

wastewater. 

Layers of stormwater BMPs preventing erosion and controlling 

sediment. Photo by Kurt Schlomberg, NREL/PIX 21211
ENVIRONMENTAL PERFORMANCE REPORT 2011 47

PROGRAM MANAGEMENT

Non-domestic wastewater discharges to the Metro District must 

comply with the district’s rules and regulations, which incorporate 

a number of requirements of the CWA, specifically the provision of 

the Pretreatment Program. Pretreatment is the set of regulations 

applied to industries and commercial operations that generate non-domestic wastewaters with potentially high levels of 

pollutants that could have an impact on treatment facilities and 

the environment. NREL does not have any of the types of operations that CWA regulations have targeted, nor does the laboratory 

discharge a volume of water that would make NREL a Significant 

Industrial User, which would require a formal discharge permit 

from the Metro District. The discharge agreement in place for NREL 

gives the laboratory direction for using the system, and provides 

assurance to the Metro District that the laboratory-generated 

wastewaters are compatible with their requirements.

It is NREL policy to comply with all requirements of Metro’s 

Pretreatment Program, including the list of general prohibitions that protect the collection and treatment systems. The 

list of prohibitions includes hazardous materials, highly viscous 

substances, radioactive material, excessive oil and grease, and 

similar substances that could cause material harm to the sanitary system. NREL staff is trained in this policy. In addition, NREL 

sites have design criteria for waste drains in laboratory areas to 

minimize the possibility of a hazardous material discharge. These 

criteria include measures such as secondary containment for any 

chemicals used near sinks in laboratory exhaust hoods, no floor 

drains in laboratory areas unless a specific need can be shown, 

and caps for any floor drains that are installed in laboratory 

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. 

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ In addition to the program improvements described above, 

NREL also worked with the Pleasant View District on largevolume discharges related to construction activities. Water 

lines included in new construction must be sanitized prior to 

use and these lines were disinfected and the water used in that 

process was discharged with Pleasant View’s approval. Large 

flows over small time periods can be problematic to sanitary 

collection systems, so the laboratory worked with the district 

to minimize impacts.

■ All wastewater activities in 2011 were in compliance with the 

Metro District’s rules and regulations. 

2011 Accomplishments and Highlights

While most of the wastewater discharged from NREL 

facilities is domestic, one facility occasionally discharges wastewater under an agreement with the Metro 

District. NREL endeavors to minimize non-domestic 

wastewater discharges, but when the sanitary system 

is the best option for waste management, NREL works 

with the districts to ensure that there are no adverse 

impacts to their facilities or the environment. 

In 2011, the IBRF, formerly the Alternative Fuels User 

Facility, was significantly expanded to accommodate 

an increase in research activities in the area of biofuels. 

The IBRF has pilot scale operations that take cellulosic 

materials such as switch grass or corn stover and 

convert the cellulose to fermentable sugars that lead 

to ethanol production. These operations generate 

wastewater, which is discharged to the sanitary collection system. 

Representatives of the Metro District and Pleasant 

View were invited to tour the new facility and review 

the discharge agreement. Because no change had 

been made to the discharge point or the processes 

generating wastewater, the districts were satisfied 

that the existing agreement to use the approved 

kill method for fermentation wastes and to monitor 

the discharge for pH were adequate controls for the 

IBRF discharge. As future projects involve new and 

different materials and treatment regimes, the district 

will be notified and the discharge monitored to their 

specifications.

Improvements were also made to one of the NTWC 

septic systems in 2011. The system received a larger 

tank and an expanded leach field. The system 

upgrades improved flow through the system and 

increased the capacity of the leach field, improving 

system operation.
48 ENVIRONMENTAL PERFORMANCE REPORT 2011

At NREL, responsible acquisition, use, and disposal of materials 

and wastes is critical to meeting our commitments to compliance, 

preventing pollution, and environmental stewardship. NREL seeks 

to purchase materials that are sourced responsibly and contain 

recycled content and lower impact materials. Use of materials is 

thoughtfully controlled with internal procedures designed to limit 

health and environmental risks. Wastes are carefully managed 

and disposed of through select contractors. These elements, if 

mismanaged, have the potential to increase disposal costs, generate cleanup costs, and increase potential for spills and contamination. Areas of focus include:

■ Hazardous materials management

■ Regulated waste management

■ Storage tank management

■ Pollution prevention

■ Radiological materials and waste management.

9.1 HAZARDOUS MATERIALS MANAGEMENT

As a major national laboratory, NREL has a variety of chemicals 

and materials, some of which are hazardous, for use in research 

activities. Hazardous materials are stored, used and managed in 

a manner that is protective of laboratory personnel, the general 

public and the environment. NREL has also taken steps to plan 

emergency responses in the event there is a spill or release of a 

hazardous material; these plans are coordinated with local emergency responders, such as the West Metro Fire Protection District 

and the Jefferson County Local Emergency Planning Committee 

(LEPC). 

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

Properly labeled chemical, including NREL barcode. Photo by Bob 

Fiehweg, NREL/PIX 21213

9 Hazardous Materials and 

Waste Management

2011 Accomplishments and Highlights

Software upgrades for the CMS were installed in 2011 

that improved the system’s functionality, accessibility, 

and reporting capabilities. 

The laboratory manages its inventory of chemicals using its CMS. 

Photo by Bob Fiehweg, NREL/PIX 21214
ENVIRONMENTAL PERFORMANCE REPORT 2011 49

■ Facilitating accurate and efficient reporting to external agencies (e.g., fire districts, LEPC, EPA, and DOE). 

Hazardous materials are rigorously managed, starting with the 

chemical inventory system that tracks chemical amounts, locations and hazards. Each week, laboratory safety personnel receive 

a list of all chemicals and their hazards shipped to the laboratory for the previous week. Researchers and safety personnel 

ensure that chemicals are properly stored in locations suitable for 

any hazards, such as storing flammable materials in designated 

flammables cabinets. In addition to the measures taken to safely 

transport, transfer and store these materials without releases to 

the environment, there are reporting requirements triggered by 

certain quantity levels, discussed below.

PROGRAM MANAGEMENT

NREL facilities are subject to the emergency reporting provision 

of the EPCRA, Section 302, which requires a facility to notify the 

State Emergency Response Commission (the Colorado Emergency Response Commission, CERC) if any extremely hazardous substances in the facility’s inventory are stored in quantities 

greater than prescribed threshold planning quantities (TPQ). NREL 

facilities first became subject to planning and notification requirements in 1988.

EPCRA Section 304 requires facilities to immediately notify the 

LEPC if there is an accidental spill or release of more than the 

predetermined reportable quantity (RQ). In accordance with 

Section 311 and 312 of EPCRA, NREL provides MSDS for chemicals that are stored on-site in quantities greater than TPQs, and 

provides inventory reporting for these same chemicals in the form 

of a Tier II report to emergency planning and response groups. 

When requested, NREL provides additional emergency response 

and reporting information to the Jefferson County LEPC, the CERC, 

the West Metro Fire Protection District, the Denver Fire Department (DFD) 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. This results 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 active 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 

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, 

Federal Compliance With Right-To-Know Laws and Pollution Prevention Requirements, requires all federal facilities to file a report, if 

applicable, regardless of SIC code. NREL has never manufactured, 

processed, or otherwise used chemicals on the 313 list in quantities exceeding TPQs, so has never had to report under Section 313. 

NREL is also subject to permitting requirements through local 

jurisdictions. NREL obtains annual hazardous material permits from 

West Metro Fire Rescue for the STM and DWOP sites as required 

by West Metro Fire Rescue. NREL obtains permits for a total of six 

buildings where hazardous materials are stored, used, or both. 

Prior to issuing the permits, a representative from West Metro Fire 

Rescue conducts a walk-through inspection of the entire STM site 

and DWOP. 

The ReFUEL facility is within the jurisdiction of the City and County 

of Denver and is subject to the DFD Hazardous Materials Information System (HMIS) requirements. The ReFUEL facility’s inventory 

of listed materials, including various fuels such as biodiesel, must 

be reported to the DFD annually. The DFD inspects the facility and 

issues a hazardous materials permit.

2011 COMPLIANCE SUMMARY AND ACTIVITIES

In early 2011, NREL submitted a Tier II report to CDPHE for reporting year 2010, identifying diesel fuel, petroleum oil and sulfuric 

acid in lead-acid batteries. See table on EPCRA Reporting for 

details.

■ West Metro Fire Rescue conducted an annual hazardous 

material inspection and issued permits for all major research 

facilities on the STM campus. 

■ The inventory of materials at the ReFUEL facility was provided 

to the Denver Fire Department.

■ There were no releases of hazardous materials requiring 

reporting.

2011 EPCRA REPORTING

EPCRA Section Description of Reporting Status

EPCRA Section 

302-303

Planning Notification Not required

EPCRA Section 

304

Extremely Hazardous Substance 

Release Notification

Not required

EPCRA Section 

311-312

Material Safety Data Sheet/

Chemical Inventory

Yes

EPCRA Section 

313

TRI Reporting Not required

“Yes" indicates that the laboratory reported under the provision.

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

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

extremely hazardous substance release).
50 ENVIRONMENTAL PERFORMANCE REPORT 2011

■ All program activities were in compliance with requirements.

9.2 REGULATED WASTE MANAGEMENT 

NREL is committed to the appropriate management of regulated 

waste generated through its daily operations. Research and development activities and general facility operations at the laboratory 

can create several types of wastes including those containing toxic 

chemicals or metals. These wastes must be handled, stored, and 

disposed of responsibly to minimize the potential for health and 

environmental impacts due to a release or improper disposal.

Research in such areas as PV, bioenergy, wind energy, transportation technologies, and energy storage use a vast range of chemical products that, in turn, generate hazardous and non-hazardous 

waste in form of solids, liquids, and gases. Proper planning ensures 

that the resulting waste streams are reduced in volume and 

managed in an environmentally friendly manner. 

Waste management and minimization efforts begin in the planning stages of all experimental and operational activities. Processes are evaluated based on the quantities and toxicities of products 

that will be brought on-site prior to commencement of an activity 

all the way through to how byproducts and waste materials will 

be managed for disposal. Hazardous materials proposed for use 

are assessed for the potential substitution of less hazardous products, resulting in less hazardous waste streams. 

All waste items are handled in a manner that incorporates a high 

level of safety and environmental stewardship for NREL and its 

surrounding neighbors. Waste management activities on-site are 

conducted in a manner that will minimize potential effects on 

human health and the environment. 

PROGRAM MANAGEMENT

Regulated wastes are handled and disposed of according to RCRA 

in Title 40 of the Code of Federal Regulations and implemented in 

the state of Colorado by CDPHE’s Hazardous Materials and Waste 

Management Division (HMWMD) through the Colorado Hazardous 

Waste Act under 6 CCR 1007-3. Additional applicable regulatory 

requirements fall under the realm of Title 49 of the Code of Federal 

Regulations, Transportation. 

NREL implementation of regulatory requirements with regard to 

waste management is multi-faceted including but not limited to:

■ Documented waste management and minimization program

■ Annual training for all staff who generate waste

■ Regular inspection and tracking of all waste containers

■ Storage, packaging, shipment, and tracking until final disposition via a fully-permitted waste disposal or recycling facility

■ Active monitoring of waste volumes to determine generator 

status

■ Maintaining records that are generated through “cradle to 

grave” waste management activities per applicable federal and 

DOE records management protocols.

NREL typically disposes of the following categories of waste:

■ Hazardous waste (as defined by environmental regulations)

■ Non-hazardous waste (not within the definition of hazardous 

waste and could include such items as propylene glycol from 

building chillers or select pretreatment liquors from biomass 

processing, etc.; does not include municipal solid waste)

■ Universal waste (less stringent environmental regulations 

governing the management of such items as mercury-containing light bulbs, lead-acid batteries, aerosol cans, and electron2011 Accomplishments and Highlights

The laboratory strives to divert waste from municipal 

solid waste landfills whenever possible. As a best 

management practice, staff began collecting toxicitycompliant light bulbs in conjunction with its universal 

waste lamps for subsequent off-site shipment and 

recycling. 

A comparison of waste volumes generated in CY 2010 

and CY 2011 is summarized in the table: Comparison 

of Four Waste Categories Generated at NREL Facilities 

in 2010 and 2011.

COMPARISON OF FOUR WASTE CATEGORIES 

GENERATED AT NREL FACILITIES IN 2010 AND 2011

(LBS. NET WEIGHT)

Hazardous 

Waste

Non-Hazardous 

Waste

Electronic

Waste

Other Universal 

Waste

2010 18,322 12,129 11,676 5791

2011 20,557 6156 29,549 3539

% change 12.20 -49.24 153.07 -38.89

Hazardous wastes are handled and disposed of according to RCRA. 

Photo by Eric Schmitz, NREL PIX 20960
ENVIRONMENTAL PERFORMANCE REPORT 2011 51

ics waste such as circuitry, solder, display monitors, etc.) 

■ Low-level radioactive waste is generated in small quantities in 

one designated laboratory and normally consists of personal 

protective equipment, disposable labware, scintillation fluids, 

and water-based liquids containing small amounts of low-level 

isotopes. Radioactive waste is shipped off-site for disposal 

as needed (see section 9.6 Radiological Materials and Waste 

Management for more information).

NREL maintains unique EPA identification numbers for each of 

its five facilities: STM, DWOP, NWTC, JSF, and ReFUEL. Pursuant 

with state and federal regulations, annual generator notifications 

are made and applicable fees are paid to the HMWMD based on 

monthly volumes of hazardous waste that are generated at each 

facility. The three waste generator classifications are:

■ Large Quantity Generator (LQG): generates ≥ 1000 kg of 

hazardous waste in a calendar month (or > 1 kg of acutely toxic 

hazardous waste)

■ Small Quantity Generator (SQG): generates > 100 kg but < 

1000 kg of hazardous waste in a calendar month (and < 1 kg of 

acutely hazardous waste)

■ Conditionally Exempt Small Quantity Generator (CESQG): 

generates < 100 kg of hazardous waste in a calendar month 

(and < 1 kg of acutely hazardous waste)

The table—2011 Generator Status for NREL Facilities—provides 

data for each NREL facility. Four out of five NREL facilities fall under 

the waste generator category of CESQG, generating minimal 

amounts of hazardous waste per calendar month. STM typically 

produces quantities of hazardous waste well within the category 

of SQG; however, due to pilot scale research experiments, STM can 

episodically elevate to that of LQG in one or more months during 

the year. 

NREL has a conservative waste management policy where select 

materials that are not regulated by RCRA, yet pose a potential 

hazard, are collected and disposed of as non-hazardous materials 

at EPA-permitted disposal facilities. For example, non-hazardous, 

nanomaterial-bearing wastes are not RCRA-regulated, but due 

to the potential for health risk, these wastes are managed and 

disposed of via the same management methods used for hazardous waste. In a general order of preference, waste items are 

shipped off site for final disposition through recycling, reclamation, 

incineration, treatment, and landfill. 

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with requirements.

■ All regulatory notifications were updated and applicable waste 

generator fees were paid for five NREL facilities in calendar year 

2011. 

■ Due to three calendar months of episodic hazardous waste 

generation at volumes totaling more than 1000 kg per month 

and in anticipation of additional pilot plant research experiments, the STM facility waste generator status was changed to 

LQG in October 2011. Since making notification of this change 

to the HMWMD, STM monthly waste generation volumes 

remained within the SQG classification for the remainder of 

2011.

■ The implementation of one opportunity for improvement 

identified in a 2010 external assessment of NREL’s hazardous waste program commenced in CY 2011. In accordance 

with 6 CCR 1007-3, toxicity-compliant fluorescent light bulbs 

may be disposed of as municipal solid waste. However, as a 

best management practice these items are now collected, 

packaged and shipped for recycling and capture of the trace 

amounts of metals contained within.

9.3 ABOVEGROUND STORAGE TANK (AST) 

MANAGEMENT

Poor management can lead to spills or leaks of fuels or oils, resulting in the contamination of soils, surface water, groundwater, 

and drinking water. In addition, spill cleanup is costly and time 

consuming. Proper management of storage tanks is an important 

part of minimizing the number and size of potential spill events 

and is critical to our commitment to maintain a clean and healthy 

environment for both neighbors and employees.

The AST Management program applies to petroleum fuel tanks 

and is intended to:

■ Minimize releases from tanks

■ Confirm that safety features are present and functional

■ Confirm that compliance requirements are met.

NREL seeks to minimize the risk of underground soil and water 

contamination from storage tanks by utilizing only aboveground 

tanks where storage is required. Unlike underground tanks, 

aboveground installations provide access for regular visual leak 

inspections and allow for less costly repair and cleanup should 

that be necessary.

NREL maintains eight ASTs at the STM facility with a total of 10,357 

gallons capacity, one AST at DWOP with a capacity of 500 gallons, 

and seven ASTs at the NWTC facility with a total of 1,565 gallons 

2011 GENERATOR STATUS FOR NREL FACILITIES.

Facility Name 2011 Generator Status

STM SQG/LQG

DWOP—Bldg. 16 CESQG

NWTC CESQG

JSF CESQG

ReFUEL CESQG
52 ENVIRONMENTAL PERFORMANCE REPORT 2011

capacity.

PROGRAM MANAGEMENT

ASTs are regulated in Colorado by the CDLE’s Oil Inspection 

Section under the Colorado AST regulation 7 C.C.R. 1101-14. Colorado requires that ASTs 660 gallons or larger be permitted prior to 

installation, be inspected by the CDLE following installation, and 

be registered within 30 days following commencement of use. EPA 

regulations require that ASTs are constructed and installed according to specific standards, are regularly inspected, those inspections 

are documented, and that facilities meeting certain oil storage 

limits employ the use of an SPCC plan to facilitate management of 

oil sources 55 gallons or larger. Those plans must include specific 

information, training requirements and response and cleanup 

guidance designed to minimize the number and size of spills and 

speed the control and cleanup of spilled materials.

NREL facilities store diesel fuel for emergency generators and 

ethanol from research activities in ASTs. The AST management 

program focuses on proper tank design, operation, training, and 

inspection to protect against spills and leaks. The program is 

designed to meet, at a minimum, EPA and Colorado regulatory 

requirements.

Several important mechanical and procedural safeguards have 

been incorporated into the AST management program to 

prevent an accidental release of diesel fuel from the storage 

tanks. Mechanical safeguards include overfill and spill protection, 

double-wall tanks for diesel fuel equipped with sensors that result 

in an alarm if the inner tank wall is leaking, and exterior concrete 

containment structures for an ethanol storage tank and one 

single-wall diesel fuel tank. Procedural safeguards include written 

operating and tank filling procedures, monthly inspections, and 

record keeping of inspection results. ASTs larger than 110 gallons 

are visually inspected once per month.

Staff across departments participate in project planning, project 

safety evaluations, readiness verifications and training activities. 

This participation promotes:

■ Awareness of planned ASTs and their contents

■ Timely achievement of necessary regulatory approval for ASTs

■ Maintenance of a current and accurate AST inventory 

■ Procurement and placement of spill cleanup supplies to assist 

timely response to a spill event, whether large or small.

Training is performed annually of personnel who operate and 

manage ASTs. AST training occurs for individuals who are responsible for AST operation and maintenance. This training is combined 

with SPCC training for individuals who are responsible for AST 

operation and maintenance, fuel or other liquid transfer activities, 

and emergency response to AST spills. The intent of this combined 

training is to inform NREL staff of the inventory of oil-containing 

equipment at each site, discuss inspection and response requirements, review the oil spill history of each site and discuss lessons 

learned, and review and discuss recent changes in rules and 

regulations.

2011 COMPLIANCE SUMMARY AND ACTIVITIES

NREL maintained two ASTs at the STM facility during 2011 which 

were required to be registered, including a 6000g ethanol tank 

at the IBRF and an 800g diesel tank for an emergency generator 

at the SERF. Both of these ASTs have been in use at NREL for a 

number of years and comply with Colorado and EPA requirements. 

There are no ASTs at the NWTC which are required to be permitted or registered. It is anticipated that one or more additional ASTs 

requiring permitting and registration will be installed in 2012.

■ All program activities were in compliance with requirements.

■ No spills or releases from NREL’s ASTs or related fueling activities occurred during 2011. 

■ Annual AST registrations were submitted to the CDLE DOPS for 

two NREL registered ASTs.

■ The IBRF PDU 6,000-gallon stainless steel ethanol storage tank, 

which was temporarily removed from service in 2010, was 

placed back into service in June 2011, following the replacement of piping. 

■ In early 2011, DOE GO issued a report of its AST program 

surveillance, completed in late 2010. The surveillance identified 15 findings, five opportunities for improvement, and 

three noteworthy practices. Some areas identified as findings 

included venting and leak detection, internal audit, emergency 

power-off switch requirements, fire extinguisher requirements, 

training, SPCC plans, and hazard warning signage. All corrective 

actions were completed by August 2011.

9.4 SPILL PREVENTION AND RESPONSE

Spills of chemicals, fuels, and oils can result in contamination to 

soil, surface water, and groundwater, potentially causing damage 

to ecosystems, wildlife habitat, and human health. Comprehensive 

planning processes can reduce spills and limit impacts when spills 

do occur.

2011 Accomplishments and Highlights

■ Governing procedures for AST management were 

updated to reflect revised regulations.

■ AST and spill prevention and response training was 

provided by the EHS Office to all NREL personnel 

identified as having responsibility for operating 

and fueling ASTs and those providing initial spill 

response. Over 30 NREL personnel attended these 

trainings.

■ The NREL AST inventory was revised to reflect new, 

moved, and removed ASTs at all NREL facilities.

■ All tanks were reviewed to confirm adherence to 

recently revised regulations.
ENVIRONMENTAL PERFORMANCE REPORT 2011 53

The laboratory seeks to prepare for and continually improve spill 

response. Formal SPCC plans have been developed for three 

facilities. The plans are designed to minimize the number and size 

of spills and speed the control and cleanup of spilled materials. 

Formal emergency notification and hazardous materials procedures are in place to provide additional support for spill response. 

Proper preventive planning and aggressive spill response enhances the protection of our local water and ecological resources. 

PROGRAM MANAGEMENT

SPCC plans are required by EPA and Colorado regulations for 

facilities that meet certain oil storage criteria. Federal regulations 

40 CFR 110, regarding Discharge of Oil, and 40 CFR 112, regarding 

Oil Pollution Prevention, are implemented by the EPA. The CDLE 

implements the DOPS Storage Tank Regulations 7 C.C.R. 1101-14. 

In general, facilities that store more than 1,320 gallons of oil and 

have the potential for a spill to enter a Water of the United States 

must have an SPCC plan. SPCC regulations require that any equipment or containers with the capacity to store 55 gallons or more 

of oil be included in the plan. The plan must address such items as:

■ Topography and location of waterways

■ Location and quantity of oil sources

■ Possible transport mechanisms

■ Spill scenarios and potential spill volumes

■ Spill prevention and response training

■ Spill notification procedures and contact information

■ Emergency response plans.

Due to the quantity of fuels stored on the STM, NWTC, and ReFUEL 

sites, an SPCC plan is required for each of these locations. NREL’s 

SPCC plans are updated every three years or whenever there is a 

significant change in regulations, operations, or equipment that 

renders the plan incomplete or inaccurate. 

NREL maintains an effective notification and spill reporting 

program and follows the procedures in the respective SPCC plans 

for spills that might occur at any facility. Spill response carts and 

caches are maintained at multiple locations allowing response 

and cleanup activities to occur quickly. Given the potential for 

spills of hydraulic fluids and fuels at construction sites, construction contractors are also required to implement controls through 

SWPPPs for each major construction site on campus (see section 

8.3 Surface Water).

SPCC training occurs annually for individuals who are responsible 

for AST operation and maintenance, fuel, or other liquid transfer 

activities, and emergency response to AST spills. This training is 

combined with training for AST operation and maintenance. The 

intent of this combined training is to inform staff of the inventory 

of oil-containing equipment at each site, discuss inspection and 

response requirements, review the oil spill history of each site and 

discuss lessons learned, and review and discuss recent changes in 

rules and regulations.

While in a given year, the laboratory typically does not experience spills that require notification to the state, incidental spills 

do occur on occasion. Typically, these are small hydraulic system 

leaks and fuel transfer spills which occur during normal construction and maintenance activities. In order to assess the frequency of 

spill occurrences, a log of spills and clean-up responses is maintained. This record demonstrates that spills are generally small and 

infrequent, and the responses are adequate to prevent the spread 

of contamination. Lessons learned from clean-up activities help 

improve future contingency planning. 

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with requirements.

■ Three SPCC plans, for the STM, NWTC, and ReFUEL facilities, 

were revised to address changes to EPA SPCC regulations and 

the Colorado AST regulations.

■ No spills requiring reporting occurred in 2011. 

■ Thirty-one minor spills of diesel or hydraulic fluids at STM and 

two at the NWTC were responded to. The size of spills ranged 

from less than 0.1 gallon to 15 gallons. About half of the spills 

2011 Accomplishments and Highlights

■ SPCC plans for the STM, NWTC, and ReFUEL facilities, including oil spill response procedures, were 

updated to reflect revised regulations and incorporate additional best management practices.

■ Emergency notification and hazardous materials 

event notification procedures were updated to 

facilitate the proper notifications and documentation in the event of a reportable spill event.

Thorough cleanup of a small hydraulic fluid leak from a boom lift. Photo 

by Matt Ogle, NREL/PIX 21215
54 ENVIRONMENTAL PERFORMANCE REPORT 2011

were on impervious surfaces and half were to soil. In all, a 

total of roughly 61 gallons of oil or diesel were spilled at STM, 

primarily from construction related activities, and about five 

gallons at the NWTC. Each spill was cleaned up promptly and 

did not result in any significant impact to the environment. 

9.5 POLLUTION PREVENTION

NREL actively seeks opportunities to prevent pollution, going 

above and beyond compliance requirements to reduce potential 

impacts to our environment. Pollution prevention can come in 

many forms and can reduce impacts from activities such as: using 

and storing fuel, petroleum products, and chemicals; laboratory 

chemical use; purchasing, recycling and composting; employee 

commuting and travel; energy and water use; and building design 

and construction. 

The positive impact of reducing pollution from NREL’s activities 

comes in many forms: 

■ Replacing toxic chemicals with safer alternatives where 

possible reduces potential exposure to employees, the public, 

and local ecosystems.

■ Choosing bio-based and recycled-content products reduces 

upstream impacts on natural systems.

■ Encouraging employees to telecommute, take alternative 

transportation, and supporting web-based meetings reduces 

air pollution and traffic and health effects on surrounding 

communities.

■ Using sustainable, low energy and low water use designs for 

buildings reduces GHG emissions and use of Colorado’s limited 

water supplies.

NREL has made a formal commitment to pollution prevention 

through its laboratory-wide environmental protection policy (see 

section 3 Environmental Management System). NREL fulfills this 

commitment by implementing a variety of controls to reduce the 

potential environmental impacts in various areas of laboratory 

operations. 

While the majority of NREL’s environmental management 

programs were established to meet compliance requirements, 

many of these programs also strive to go beyond compliance 

requirements to continually improve environmental performance. 

In addition, staff regularly identify opportunities to prevent pollution through the implementation of NREL’s hazard identification 

and control process.

NREL dedicates resources for sustainable operations through the 

Sustainable NREL program. 

Formal pollution prevention assessments are conducted to 

identify opportunities to reduce pollution and improve program 

effectiveness. 

Staff are available to provide guidance and assistance in the reduction of environmental impacts and prevention of spills.

2011 Accomplishments and Highlights

In FY 2011, three pollution prevention assessments were 

successfully completed:

■ Printer Reduction. This assessment estimated the environmental benefits and cost savings of removing desktop printers to encourage greater use of multi-function devices (all-inone printer, copier, scanner, and fax device). The assessment 

was conducted in one major building on the STM campus 

and verified existing printer inventories and the functionality 

of existing multi-function devices for color printing, copying, 

scanning, and faxing. The assessment determined that 50 to 

60 devices could be removed with little or no impact to users. 

As a result, a printer consolidation project is currently under 

consideration for this building.

■ Sulfur Hexafluoride (SF6

) Reduction. This assessment 

determined the current uses of SF6, the feasibility to capture 

or reduce emissions, and estimated the potential environmental benefits of a capture or reduction program. SF6

 is a 

compound that, when released to the atmosphere, contributes to global warming. SF6

 has the highest known global 

warming potential (GWP) at roughly 23,000 times that of CO2. 

One use of SF6 on campus is as a tracer gas for American Society of Heating, Refrigerating, and Air-Conditioning Engineers 

(ASHRAE) 110 fume hood testing. Based on this assessment, 

SF6 alternatives will be considered for future NREL fume hood 

commissioning. 

■ Aerosol Can Recycling. This assessment evaluated the 

number of aerosol cans NREL uses to understand the environmental impacts of this waste stream. The study estimated 

that roughly 400 empty aerosol cans per year are being 

disposed of. Any cans that still contain hazardous materials 

are disposed of via a qualified waste contractor. Establishing a 

recycling program for aerosol cans is being considered based 

on this assessment to reduce generation of solid waste and 

conserve resources. 

Sustainable NREL initiated a pilot Pollution Prevention Initiative, which provided staff with the opportunity to identify and 

implement new pollution prevention practices at the laboratory. 

Project proposals were submitted by staff to help the laboratory 

achieve reductions in waste, materials, water, air emissions, and 

energy use. Three projects were funded in 2011 including: 

■ Idling Reduction. This project created new guidance based 

on best practices and developed a site-wide education 

program for idling reduction. Estimated reductions include 

1,700 gallons/yr and $6,400/yr in diesel fuel use for NREL 

shuttles. 

■ Pump Replacement. This project replaced an existing oilbased wet pump with an energy-efficient sealed pump in a 

research laboratory. This replacement will reduce oil waste 

and energy usage associated with the pump.

■ NREL Library Reduce and Recycle. This project replaced 85 

linear feet of print journals with electronic journals to reduce 

paper use and the footprint required for the scientific reference library. This project reduced collection shelving requirements by 30%, saving both material and energy costs.
ENVIRONMENTAL PERFORMANCE REPORT 2011 55

PROGRAM MANAGEMENT

DOE O 436.1, Departmental Sustainability became effective in May 

2011 and cancels DOE O 450.1A, Environmental Protection Program

and DOE O 430.2B, Departmental Energy, Renewable Energy and 

Transportation Management. The order implements the objectives of EOs 13423, Strengthening Federal Environmental, Energy, 

and Transportation Management, and 13514, Federal Leadership in 

Environmental, Energy, and Economic Performance, which direct 

federal agencies to conserve natural resources, reduce energy use, 

develop renewable energy, reduce GHG emissions, and manage 

buildings and transportation in a sustainable manner. DOE O 436.1 

also requires that DOE facilities comply with the Pollution Prevention Act of 1990 at DOE facilities and support pollution prevention.

Through the implementation of NREL’s hazard identification and 

control process, staff regularly identify opportunities to prevent 

pollution. In addition, resources are dedicated for sustainable 

operations and pollution prevention through the Sustainable 

NREL program. Formal pollution prevention assessments are 

conducted to identify opportunities to reduce pollution and 

improve program effectiveness. The PPI provides staff with an 

opportunity to identify and implement new pollution prevention 

practices at the laboratory.

2011 COMPLIANCE SUMMARY AND ACTIVITIES

While there is no requirement to conduct pollution prevention 

assessments, such assessments are conducted periodically and are 

used to identify opportunities to reduce pollution, reduce costs, 

and improve internal processes.

9.6 RADIOLOGICAL MATERIALS AND WASTE 

MANAGEMENT

NREL is involved in a wide range of research activities, some of 

which, from time to time, include investigations using radioactive 

materials. NREL uses several x-ray diffraction analytical techniques 

and occasionally uses small quantities of radioisotopes for biological labeling in research. All of the materials used at NREL have 

very low activity levels and are used in extremely small amounts. 

Unlike many DOE facilities, NREL does not conduct work activities 

involving nuclear materials and does not have legacy radiological contamination issues associated with past nuclear weapons 

production and research activities.

NREL has established strict protocols for equipment containing 

sources or for the use of radioisotopes in laboratory experiments 

through its Radiation Safety program. Some of these controls 

include:

■ Confining work with radioisotopes to a single laboratory

■ Monitoring of equipment and facilities for removable contamination is performed in the laboratory where radioisotopes are 

used 

■ Inspecting x-ray equipment regularly

■ Assuring that future users are not at risk for receiving contaminated materials—no equipment used on-site will be surplused 

until background levels of radiation present are achieved. 

PROGRAM MANAGEMENT

Radiation emissions are regulated under Section 112 of the Clean 

Air Act as implemented by 40 CFR 61, Subpart H, promulgated by 

the EPA. 40 CFR 61 established NESHAPs, and, more specifically, 

Subpart H, sets such standards for radiological materials, known as 

Rad NESHAPs. 

DOE O 458.1, Radiation Protection of the Public and the Environment

cancelled DOE O 5400.5. This order establishes radiation emission 

limits for DOE facilities. 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 equivalent of 10 millirem 

(mrem) 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 (version 1.6) to determine the effective dose equivalent to 

the public. 

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 off-site facility permitted to accept low-level radioactive waste. 

Internal procedures prohibit the clearance of property unless it has 

been decontaminated to background levels. 

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ NREL began the development of an Environmental Radiation 

Protection Plan to provide information about the laboratory’s management of radioactive materials and efforts to 

prevent exposures of these materials to the public and the 

environment.

■ All program activities were in compliance with requirements.

■ The effective dose equivalent to the public from NREL activities 

was 0.0054 mrem per year, far below the 10 mrem per year 

limit.

■ No low-level radioactive waste was generated. Small quantities 

of low-level radioactive waste are currently in storage awaiting 

off-site disposal.

■ No planned or unplanned radiological releases occurred.

2011 Accomplishments and Highlights

■ In 2011, there were no activities at the laboratory 

involving radioactive materials except for the use 

of sealed sources in tritium exit signs, gauging 

devices, and monitoring equipment check sources.
56 ENVIRONMENTAL PERFORMANCE REPORT 2011

NREL’s National Environmental Policy Act (NEPA) program provides 

a mechanism to consider environmental factors in the decisionmaking process and promotes sustainable and environmentally 

responsible operations. Staff conduct reviews under the NEPA 

process (described below) of a wide range of activities prior to 

work commencing. 

Examples of activities receiving a NEPA review include new or 

revised laboratory research, construction activities, CRADAs and 

other partnering arrangements, and feasibility studies or data 

analyses performed for other government agencies. 

PROGRAM MANAGEMENT

NEPA is a federal law that requires potential environmental 

impacts to be considered for activities with a federal connection, 

such as those using federal funds, property, facilities, equipment, 

and staff paid using federal funds. The Act requires that federal 

agencies integrate the NEPA process into their activities at the 

earliest possible time. Soon after NEPA was passed, the president’s 

Council on Environmental Quality (CEQ) promulgated regulations 

[40 CFR Parts 1500-15081] implementing NEPA which are binding on all federal agencies. Subsequently, DOE established NEPA 

Implementing Procedures (10 CFR 1021) which DOE (and NREL) 

use to comply with section 102(2) of the National Environmental 

Policy Act (NEPA) of 1969 (42 U.S.C. 4332(2)) and CEQ regulations 

for implementing the procedural provisions of NEPA (40 CFR parts 

1500-1508). The DOE procedures supplement, and are to be used 

in conjunction with, CEQ regulations.

NREL has developed a NEPA procedure to provide a mechanism 

to consider environmental factors in the decision-making process 

at NREL and to promote environmentally responsible decisions 

during project planning activities. 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. 

2011 Accomplishments and Highlights

■ In 2011, NEPA reviews were a top priority given the 

extensive on-site construction activities, as well as 

numerous off-site projects, many in response to 

American Recovery and Reinvestment Act (ARRA) 

funding opportunities.

■ Provided project-specific NEPA training for several 

NREL programs, including Wind for Schools, Solar 

Incubator, and Work for Others wind assessment programs. With a better understanding of 

NEPA requirements for specific types of recurring 

projects, project managers can more effectively 

consider the potential for environmental impacts 

during their project planning activities. 

■ Worked collaboratively with NREL’s ISMS and EMS 

teams to strengthen NEPA procedures and daily 

activities.

■ Provided extensive NEPA support in the preparation of proposals for DOE Funding Opportunity Announcements (FOAs) that support DOE’s 

mission and the nation’s energy objectives. 

■ Participated in outreach activities by discussing 

NEPA requirements and potential environmental 

impacts during a webinar related to the Wind for 

Schools program. The webinar was attended by 

representatives from several colleges and universities across the country who will in turn communicate environmental requirements and potential 

impacts to participating schools. 

10 National Environmental Policy Act 

(NEPA)

EXAMPLES OF ACTIVITIES THAT COULD HAVE ENVIRONMENTAL IMPACTS

Activities Potential Impacts

Chemical handling, storage, and 

disposal

Impacts to surface water 

resources if chemicals mishandled 

or disposed of improperly

Excavation and dirt moving during 

construction and maintenance

Fugitive dust

Damage to historic or cultural 

resources

Increased traffic or noise

Impacts to wetlands

Mowing, maintenance, or off-road 

activities

Migratory birds impacts such as 

nest abandonment or bird deaths

Disturbance of asbestoscontaining materials during indoor 

modifications or renovations

Employee health impacts due to 

inhalation of asbestos
ENVIRONMENTAL PERFORMANCE REPORT 2011 57

The laboratory initiates NEPA reviews and supports the DOE GO in 

making NEPA determinations before work can begin. In accordance with DOE NEPA Implementing Procedures (10 CFR 1021), all 

NREL activities, other than routine, office, laboratory, or research 

activities, must undergo a NEPA environmental review. The 

outcome of this review is considered the NEPA determination. A 

NEPA determination is required before federal funds are expended, 

before a contract award can be made, and before project activities 

begin. 

In most cases, proposed activities have either been evaluated in 

an existing site-wide EA or supplement or fall under a Categorical 

Exclusion (CX). A CX applies to activities that, based on agency 

experience, will normally have no significant individual or cumulative effect on the quality of the human environment. Examples of 

DOE CXs include information gathering, data analysis, feasibility 

studies, bench-scale research and development, and minor interior modifications. The NEPA review is initiated by preparing either 

a NEPA worksheet or checklist.

Worksheets

For activities where the potential for environmental impact 

does not exist or for types of activities that have been previously 

analyzed in existing NREL site-wide NEPA documents, a NEPA 

worksheet is completed. The NEPA worksheet is a simple one page 

form that lists the proposed project and documents the appropriate CX or NREL site-wide NEPA document related to the proposed 

work. Allowable types of projects include office work, such as 

computer modeling or programming, data analysis, or preparation 

of educational materials, routine maintenance activities, minor 

interior modification of existing facilities, and bench-scale research 

and testing in an existing facility. For projects recorded on NEPA 

worksheets, the work can go forward upon receipt and review of 

the project information by EHS.

Checklists

For proposed projects where there is a potential for environmental 

impact a NEPA checklist is completed. The information included 

on the checklist helps the NEPA reviewer to evaluate the potential 

environmental impacts of the project (e.g., utilization of hazardous 

materials, generation of hazardous waste or air emissions, ground 

disturbing activities, presence of floodplains, wetlands, endangered species, or critical habitats, potential for noise and visual 

impacts, etc.). Projects such as onsite construction, pilot-scale 

research and testing, installation of meteorological towers for wind 

resource assessments, and prototype deployment of renewable 

energy technologies are examples of projects that are typically 

reviewed using the NEPA checklist.

For a project recorded on a NEPA checklist, work may not 

commence until GO has reviewed the submittal and provided a 

signed NEPA determination by a DOE NEPA Compliance Officer. 

GO may include provisional language in the NEPA determination, 

which may limit the type of work that can be done until additional 

information is received, or which may specify the kind of mitigation actions that must be taken to avoid impacts. 

Environmental Assessment

If the proposed action is not included in the description provided 

in the CXs established by DOE, or there are extraordinary circumstances (such as impacts to historic resources, endangered 

species, floodplains or wetlands, etc.), or the proposed action fits 

within a category of actions that DOE has determined to typically 

require an EA, then NREL and DOE GO prepare an EA. The purpose 

of an EA is to determine the significance of the environmental 

effects and to look at alternative means to achieve the agency’s 

objectives. An EA is prepared for classes of activities such as 

siting, construction, and operation of energy system demonstration actions including wind resource, hydropower, geothermal, 

biomass, and solar energy projects and operations. An EA provides 

sufficient evidence and analysis for determining whether to 

prepare an environmental impact statement (EIS). The EA provides 

an opportunity for public review and comment and demonstrates 

compliance with NEPA when no EIS is necessary, i.e., it helps to 

identify better alternatives and mitigation measures. The EA also 

facilitates preparation of an EIS when one is necessary. 

An EA provides a brief discussion of the need for the proposal, 

alternatives to the proposal, the environmental impacts of the 

proposed action and alternatives, and a list of agencies and 

persons consulted. The EA process concludes with either a Finding 

of No Significant Impact (FONSI) or a determination to proceed 

to preparation of an EIS. The FONSI documents the reasons why it 

has been concluded that there are no significant environmental 

impacts that would occur if the project or activities were implemented. The EA and FONSI can include mitigation measures or 

alternatives that would be desirable to consider and adopt even 

though the impacts of the proposal will not be “significant.” NREL 

has completed site-wide EAs for both the NWTC and STM facilities.

Environmental Impact Statement

An EIS provides a detailed analysis of projects that the proposing 

agency views as having significant prospective environmental 

impacts. The EIS provides a discussion of significant environmental impacts and reasonable alternatives (including a No Action 

alternative) which would avoid or minimize adverse impacts or 

enhance the quality of the human environment. An EIS is also 

made available for public review and comment. As a final step, 

a Record of Decision (ROD) is prepared which states the decision, the alternatives considered, including the environmentally 

preferred alternative, and discusses mitigation plans, including any 

enforcement and monitoring commitments. It should be noted 

that no NREL activities have required an EIS to date.

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ Five hundred and fifteen NEPA reviews were conducted for 

project activities on and off site during 2011. Of these, 30 NEPA 

“checklists” were completed given their potential to cause an 

environmental impact. For each of these, work commences 

only after DOE reviews the submittal and provides a signed 

NEPA determination which specifies any needed mitigation 

actions that must be taken to avoid impacts. Two projects were 

determined to require an EA.
58 ENVIRONMENTAL PERFORMANCE REPORT 2011

■ A Supplemental EA was initiated to address a proposed action 

for enhancements to the RFHP.

■ A site-wide EA was initiated for proposed continued and 

enhanced operations at the NWTC.

■ This program was in compliance with the DOE NEPA 

Implementing Regulations. 

NREL is committed to responsible stewardship of our natural 

ecosystems, native wildlife and vegetation, and important cultural 

resources. Natural resources at the STM and NWTC facilities are 

managed appropriately to ensure our research needs are met 

while protecting native wildlife and vegetation. Responsible 

management not only benefits our environment, but also NREL 

employees and the surrounding community, and demonstrates 

the laboratory’s leadership in the DOE and federal government as 

a whole. Management focuses on these key areas:

■ Wildlife management 

■ Endangered species and species of concern 

■ Vegetation management

■ Wetlands and floodplains

■ Cultural resources

■ Conservation easement lands.

11.1 WILDLIFE MANAGEMENT

The Wildlife Management program is intended to promote 

responsible wildlife and habitat management and gather information to better consider impacts to wildlife when implementing 

projects on-site. NREL is committed to responsible land stewardship and the proper management of wildlife populations into 

the future. Many surrounding landowners, including residential 

neighborhoods and the Jefferson County Open Space value 

the benefits of maintaining wildlife habitat and opportunities to 

observe wildlife. Proper wildlife management provides an important benefit to our community.

NREL biologists work with project managers and decision makers 

as part of an integrated project team on construction projects to 

minimize impacts to wildlife and maintain habitat by avoiding 

sensitive areas and reclaiming lands once disturbance is complete. 

At STM, a long term objective is to maintain wildlife movement 

through campus by retaining linkages between the open space 

areas north of campus and Pleasant View Community Park and 

Lena Gulch to the south. At the NWTC, ecologically sensitive areas 

are preserved within the site and linkages with surrounding open 

space areas are maintained. At both sites, periodic monitoring 

using wildlife surveys informs responsible management. 

When control of pest wildlife species is necessary, a graded 

approach is used to humanely eradicate pests and minimize other 

potential impacts. Building design features and administrative 

controls are the first line of defense against pests. When these are 

not fully effective, additional controls are used. Pests are relocated 

whenever possible. When pests must be destroyed, mechanical 

methods are preferred over poisoning. When necessary, pesticides 

are selected to minimize secondary impacts. 

11 Natural and Cultural Resources 

Protection

2011 Accomplishments and Highlights

■ STM and NWTC site-wide wildlife and vegetation 

surveys were completed. These surveys enable 

staff to compare current conditions to those found 

in previous studies, establish environmental conditions for future NEPA EAs (see section 10 National 

Environmental Policy Act ), and make informed 

wildlife management decisions.

■ Avian use, and avian and bat mortality surveys, 

were conducted at the NWTC to gauge potential 

impacts associated with the installation of three 

next-generation, multi-megawatt wind turbines 

(see 2011 Compliance Summary and Activities 

below).

■ Several bee swarms were found on campus. 

Two swarms naturally moved off-site, but a third, 

which settled into a building cavity to construct 

a new hive, was safely relocated by a professional 

beekeeper.

■ Numerous rattlesnakes that posed a hazard to 

workers were relocated to nearby habitat on NREL 

sites.

Bee swarm outside the RSF. Photo by Brenda Beatty, PIX 21212
ENVIRONMENTAL PERFORMANCE REPORT 2011 59

PROGRAM MANAGEMENT

Several federal laws, an executive order, and a Colorado statute 

comprise the regulatory framework for this program.

The MBTA of 1918 (16 U.S.C. 703-712; Ch. 128; July 13, 1918; 40 

Stat. 755) is the main driver for protection of migratory birds in the 

United States. In the biological sense, a migratory bird is a bird that 

has a seasonal and somewhat predictable pattern of movement. 

Generally, this includes all native birds in the U.S., except those 

non-migratory species such as quail and turkey that are managed 

by individual states as game species.

Under the MBTA, it is unlawful “by any means or manner to 

pursue, hunt, take, capture [or] kill” any migratory birds except 

as permitted by regulations issued by the U. S. Fish and Wildlife 

Service (USFWS). The term “take” is not defined in the MBTA, but 

the USFWS has defined it by regulation to mean to “pursue, hunt, 

shoot, wound, kill, trap, capture or collect” any migratory bird or 

any part, nest or egg of any migratory bird covered by the conventions, or to attempt those activities.

The USFWS has developed a system of permits for activities that 

involve the take of migratory birds, including those governing 

scientific collection and bird banding, and lethal and non-lethal 

measures taken to prevent depredation of agricultural crops and 

to protect public health and safety. Existing migratory bird permit 

regulations authorize take for specific types of activities, such as 

collecting birds for scientific or educational purposes, or lethal 

control of birds damaging agricultural crops or other personal 

property. The USFWS does not authorize take resulting from 

activities such as forestry or agricultural operations, construction 

or operation of power lines, and other activities where an otherwise legal action might reasonably be expected to take migratory 

birds, but is not the intended purpose of the action. Therefore, 

NREL property managers do not have a permitting option for their 

activities unless for scientific, educational or property damage. 

Construction activities do not have permitting options. 

In response to EO 13186, Responsibilities of Federal Agencies to 

Protect Migratory Birds the USFWS issued guidance identifying 

goals for federal program activities. The USFWS highlighted the 

need to identify means and measures to avoid and/or minimize 

potential for take of migratory birds, eggs, and active nests, including but not limited to (1) project modification, (2) time-of-year 

restrictions on vegetation clearing, (3) avoidance of cavity trees, 

colonial bird nests, and other active nests, and (4) avoidance of 

nests of species of concern. The USFWS also seeks to ensure that 

environmental analyses of federal activities under the NEPA or 

other established environmental review processes evaluate the 

effects of actions and agency plans on migratory birds, particularly 

on species of concern.

Wildlife is considered a state resource under Colorado law. Under 

Colorado Revised Statute 33-6-128: Damage or Destruction of 

Dens or Nests—Harassment of Wildlife, no wildlife dens or nests, 

young, or eggs may be damaged or destroyed unless permitted 

by the Colorado Division of Parks and Wildlife. It is unlawful for any 

person to willfully harass wildlife. This statute gives district wildlife 

managers the power to ticket offenders and enforce a similar 

provision to the MBTA and to protect mammalian wildlife species.

On August 1, 2006, a MOU was finalized between the USFWS and 

the DOE regarding the protection of migratory birds. Under the 

MOU, DOE agrees to integrate migratory bird conservation principles, measures, and practices into agency activities, and avoid or 

minimize, to the extent practicable, adverse impacts on migratory 

bird resources and their habitats.

NREL’s Wildlife Management Program was developed to implement measures to allow NREL to meet or exceed the regulatory 

requirements discussed and to minimize or avoid impacts to 

wildlife species and their habitats while achieving the mission of 

NREL. Several activities occur periodically to achieve the program’s 

intent:

■ Monitoring 

● Prior to ground or vegetation disturbing activities conducted between March 15 and September 15, NREL biologists 

conduct a nesting bird survey. If nests are found, the area is 

closed with a proper buffer area until nestlings fledge.

● Periodic surveys are conducted on a site-wide basis to 

document biological conditions at NREL facilities.

■ Research Studies

● Periodically, research studies are conducted to better 

understand the potential impacts of projects or site 

management. 

■ Vegetation management

● Areas that may be impacted by outdoor activities are 

surveyed then mowed to reduce vegetative cover, discouraging bird nesting in that area.

■ Project Reviews

● Biologists conduct project reviews to assess potential 

impacts to avian species including consideration of 

window glazings to reduce bird collisions and timing 

construction activities to start before or after the nesting 

season. 

■ Coordination

● Biologists coordinate with local, state and federal agencies 

to improve wildlife management where possible.

These activities are conducted in concert with surveys for threatened and endangered species and habitats (see section 11.2 

Endangered Species and Species of Concern). Because habitat is 

as much of a concern as the wildlife species themselves, program 

activities often overlap with vegetation management. 

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with requirements.

■ Developed a Migratory Bird Conservation Plan for NREL sites. 

This plan is used as guidance for specific types of projects that 
60 ENVIRONMENTAL PERFORMANCE REPORT 2011

have the potential to impact migratory birds and provides 

BMPs that are recommended to eliminate or minimize impacts 

for identified risk areas including:

● Disturbance of vegetation

● Building maintenance

● Collisions with buildings, windows, meteorological towers, 

and wind turbines.

The plan also outlines strategies for monitoring of avian 

species of special concern, such as eagles and other raptors. 

The plan is intended to be a guidance document that meets 

NREL’s obligations under the MOU described above.

■ Bird-friendly glass windows were installed on the laboratory’s 

new STM parking garage set to open in 2012. The glass in 

this structure is patterned with a 50% frit that appears etched 

but still allows for visibility. This special glass was installed on 

all glass breeze-ways and critical areas of glass stairwells. This 

design should reduce the potential for bird collisions, lessening 

impacts on migratory birds. 

In 2011, wildlife surveys were completed at STM and the NWTC. 

Surveys were conducted during 2010 and 2011 to include all four 

seasons of the year. Survey methods were those typically used in 

baseline surveys: point count for birds, live small mammal trapping, scent posts for carnivores, recorded call surveys for amphibians and owls, and bat acoustic surveys. Results include:

STM 

■ One-hundred and two wildlife species were detected: five 

herptiles, 86 birds, and 11 mammals. In comparison, previous 

survey efforts observed a total of 31 species in 1987, and 69 

species in 2005.

■ The seasonal average for wildlife species richness, diversity 

(dominance) and total number of detections all approximately 

doubled since reported for 2005. This is explained by an 

increased survey effort.

■ One special status species was observed, the peregrine falcon 

(Falco pereginus), a State Species of Special Concern.

■ Small mammal trapping resulted in a low species richness with 

only three species captured on-site over two survey periods 

including Mexican woodrat (Neotoma Mexicana), deer mouse

(Peromyscus maniculatus), and western harvest mouse (Reithrodontomys megalotis).

■ Mammalian predator surveys detected red fox (Vulpes vulpes), 

coyote (Canis latrans), and striped (Mephitis mephitis) and 

spotted skunk (Spilogale gracilis). Only coyotes had been 

detected previously.

■ Amphibian call surveys detected one species, Woodhouse’s 

toad (Bufo woodhousii).

■ Playback surveys failed to detect any owls. 

■ No bat species were detected. 

NWTC

■ Seventy three wildlife species were detected including: three 

herptiles, 45 birds, 17 mammals, and eight insect species. In 

comparison, previous survey efforts observed a total of 31 

species in 1987, and 69 species in 2005. Thirty five species were 

observed in off-site reference areas.

■ High species richness for small mammals indicates that the site 

has high biodiversity value, especially for small mammals and 

their predators.

■ Six species were added to the list of species previously 

documented on-site: Boreal Chorus Frog, Woodhouse’s Toad, 

Masked Shrew, Western Harvest Mouse, Meadow Vole, and 

American Elk.

■ Bat acoustic monitoring documented that bat activity was 

highest from mid-July to mid-September.

Avian use and avian and bat mortality surveys at NWTC

Installation of three newer generation multi-MW wind turbines 

at the NWTC has raised concerns regarding the potential for 

mortality impacts to avian and bat species at the NWTC. To 

identify species or species groups that may be at risk from NWTC 

operations and development, NREL conducted a year-long survey 

completed in 2011 to document avian use and to document bird 

and bat mortalities. Avian use surveys included breeding bird 

surveys during the spring and summer, raptor migration surveys 

during the spring, and weekly avian site use (including raptors and 

non-raptors) surveys over the entire year. Avian and bat mortality surveys were also conducted weekly over the entire year. In 

addition, wildlife surveys, including bat surveys were conducted 

during 2010 and 2011. All surveys were conducted using standard 

methodologies used at other wind facilities.

The data collected from these surveys will be used to make 

informed decisions regarding wildlife impacts under continued 

site use and future development scenarios. These data will be 

used to evaluate methods that could be used to avoid, minimize, 

or mitigate wildlife impacts in the future, including the potential 

use of bird diverters to make meteorological tower guy wires more 

visible, and changing turbine cut-in speeds during times when 

bats are most at risk of collision (i.e., during spring and fall migration). Results of these surveys are discussed below. 

BREEDING BIRD SURVEYS

Spatial distribution of grassland songbirds was evaluated in 

relation to vertical structures, including wind turbines and 

meteorological towers. Grassland bird species observed during 

the breeding season included western meadowlark (Sturnella 

neglecta), vesper sparrow (Pooecetes gramineus), grasshopper sparrow (Ammodramus savannarum), savannah sparrow (Passerculus 

sandwichensis), and horned lark (Eremophila alpestris). Based on 

survey results, grassland breeding bird (other than vesper sparrow) 

distribution does not appear to be affected by the current distribution of turbines at the site. For the vesper sparrow, there were 
ENVIRONMENTAL PERFORMANCE REPORT 2011 61

fewer detections east of Row 3 road, than to the west, likely due 

to increased human presence and activity where the medium and 

large turbines are located.

RAPTOR MIGRATION SURVEYS

The eastern front of the Southern Rocky Mountains in central 

Colorado (i.e., the Front Range) is used annually by raptors residing 

in the intermountain west, particularly for spring migration north 

from lower latitudes. Since wind turbines, antennae, and meteorological towers have been shown to cause bird collisions and 

fatalities, a survey of migrating raptors was conducted for 20 days 

during April 2010. Migratory and resident raptors were observed. 

A total of 378 raptor species were observed. The most abundant 

species observed were the turkey vulture (Cathartes aura) (114 

observations), American kestrel (85), and red-tailed hawk (65). 

Of the total number of observations, 126, or 33%, were migratory. Only five migrant raptors were detected within the NWTC 

airspace. However, it should be noted that the year-to-year variation in April migrant routes is large. For example, in 2010, most 

migrating raptors were observed flying to the west of the NWTC, 

over the foothills. In previous years, the flight path was much to 

the east of the site, As a result, depending on each year’s migration 

route, there could be a greater or lesser presence of raptors flying 

over the NWTC, in the vicinity of large-scale turbines, which would 

result in a greater or lesser risk of collision with aerial structures.

Of the five migratory raptors that passed within NWTC airspace, 

flight height ranged from zero to 820ft (250m) and averaged 338ft 

(103m). In contrast to the low migrant presence over the site, 

resident raptors engaged in semi-constant use of the landscape 

during April 2010, particularly tall towers and guywires. Flight 

height for resident raptors ranged from zero to 1050ft (320m) 

above the ground for the three resident species (American kestrel, 

red-tailed hawk, and turkey vulture). The majority of resident 

raptor flights occur at heights similar to the majority of towers, 

structures and associated guywires. Turbine heights onsite range 

from 29ft (9m) to 295ft (90 m), meteorological towers range in 

height from 29ft (9m) to 443ft (135m), and rotor swept areas range 

from 23ft (7m) to 36ft (11m) above the ground (for the smallest 

turbine onsite) to an area covering 131ft (40m) to 459ft (140m) 

above the ground (for the largest turbine onsite). No collisions 

or dead raptors resulting from structure collisions were observed 

during the April 2010 migrating raptor survey. However, since 

resident raptors tend to spend more time hunting onsite than 

migrating raptors, they may be at higher risk of collision.

AVIAN SITE USE

Six fixed point surveys were conducted over the course of a year 

onsite at the NWTC, as well as at two offsite reference locations 

(three fixed points on Boulder County Open Space, and three fixed 

points on the Rocky Flats National Wildlife Refuge). Surveys were 

conducted weekly during the spring, summer, and fall, and every 

other week during the winter. Both raptors and non-raptors were 

counted during the surveys to characterize the bird community 

using the site throughout the year.

Non-raptor mean use was highest during the summer among all 

surveyed seasons (12.85 birds/20 minutes). Western meadowlark, 

red-winged blackbird (Agelaius phoeniceus), horned lark, and grasshopper sparrow were among the most numerous non-raptors 

observed. Of these species, only horned larks and grasshopper 

sparrows were observed flying at rotor swept area (RSA) height 

(0.08 and 0.03 birds flying at RSA height/20 min, respectively). 

Horned larks are susceptible to collision during the breeding 

season because male horned larks fly to heights of 262ft (80m) 

to 820ft (250m) for breeding displays. While other species, such 

as the barn swallow (Hirundo rustica), song sparrow (Melospiza 

melodia), common raven (Corvus corax), black-billed magpie (Pica 

hudsonia), and mourning dove (Zenaida macroura) were also 

observed flying at RSA height, their low site use and frequency of 

encounter indicate that mortalities are likely to be few. 

Raptor mean use was highest during the spring and early summer 

among all surveyed seasons (0.25 birds/30 minutes and 0.29 

birds/30 minutes, respectively). Raptor species with the highest 

mean use included red-tailed hawk, turkey vulture, and American 

kestrel. Of raptor species observed during point count surveys, 

only turkey vultures, American kestrels, red-tailed hawks and ferruginous hawks (Buteo regalis) were observed flying at RSA height 

during all point count surveys and all other raptors were observed 

flying below the RSA height of the three large turbines.

The scientific literature indicates that raptor mortality appears to 

be low (less than 0.15 raptors/MW/yr) when raptor use is low (i.e., 

less than 1.0 birds/20 min), which is the case for raptor use at the 

NWTC during all seasons. 

BAT SITE USE

Of the 18 species of bats known to occur within Colorado, 11 have 

been documented in Jefferson County or neighboring counties. 

Bat species that were documented at the NWTC during 2010 

wildlife surveys include big brown bat (Eptesicus fuscus), hoary bat 

(Lasiurus cinereus), silver-haired bat (Lasionycteris noctivagans), eastern red bat (Lasiurus borealis), fringed myotis (Myotis thysanodes), 

and other unidentified myotis species . None of the bat species 

observed onsite are threatened or endangered at the federal or 

state level. 

 Killdeer. Photo by Brenda Beatty, NREL/PIX 21232
62 ENVIRONMENTAL PERFORMANCE REPORT 2011

MORTALITY SURVEYS

Surveys were conducted over the course of a year to document 

whether avian and bat fatalities were occurring as a result of interactions with wind turbines and other vertical structures (including 

guy wires). Results of mortality surveys are discussed below. 

Thirteen bat fatalities were found during standardized carcass 

searches from August 2010 through September 2011. Species 

found include hoary bat, silver-haired bat, big brown bat and two 

unidentified bat species. Bat fatalities were found only during 

summer and fall seasons. All bat carcasses were found beneath 

turbines. In general, bat fatalities documented at wind farms 

are highest during mid to late summer and early fall and tend 

to involve migratory tree roosting species (e.g., hoary bat and 

silver-haired bat). Peaks in fatality rates appear to coincide with 

increasing bat activity levels associated with southward migration. Although NWTC is not a wind farm, peaks in bat activity and 

subsequent mortalities were similar to those found at wind farms.

A total of five avian carcasses representing three species and two 

unidentifiable carcasses were found. Avian fatalities were found in 

every season except winter and included a black-billed magpie, 

mourning dove, red-winged blackbird, an unknown sparrow, 

and an unknown songbird. Except for the unknown songbird, all 

other species were discovered underneath meteorological towers, 

indicating guy wire strikes.

The above values indicate the number of bird and bat carcasses 

observed during the survey. The actual number of fatalities is 

dependent upon how efficient the searcher is at locating carcasses and how long the carcass persists on the ground before being 

removed by scavengers (or by other means such as grass/brush 

mowing). To account for these variances, searcher efficiency trials 

and carcass persistence trials were conducted, using standard 

methodologies used at other wind facilities. Results indicated that 

overall searcher efficiency was estimated at 49%. 

For the carcass persistence trials (where a carcass is placed 

randomly onsite and monitored for 30 days to ascertain the length 

of time fatalities would remain before being removed [i.e., before it 

could be observed and counted]), the estimate for average mean 

persistence across seasons was 16.3 days (the fewer days the 

carcass persists on the ground, the less likely it would be observed 

during the survey).

Under current operating conditions, and based upon 2010–2011 

fatalities, searcher efficiency trials, and carcass persistence trials, 

three avian fatalities and 16 bat fatalities are estimated to occur on 

the NWTC site during fall/winter seasons. During spring/summer 

seasons, 10 avian fatalities and 17 bat fatalities are estimated to 

occur on the NWTC site. 

11.2 ENDANGERED SPECIES AND SPECIES OF CONCERN

NREL manages its research and facility-related activities to 

preserve and protect environmental quality and strives to practice 

good land stewardship at its facilities. The laboratory is committed 

to the protection of imperiled wildlife species and monitors for 

these species at its two main research sites: STM and the NWTC. 

Periodically, surveys are conducted for declining wildlife species 

and rare plants including species that are federally or state protected or otherwise considered imperiled or declining. Biologists also 

survey for potential habitat for these species. Should potential 

habitat be found, more targeted surveys may be conducted. These 

surveys identify the presence or absence of rare species or their 

habitats and aid in siting and planning new projects. While no 

protected or declining species have been detected at an NREL 

facility, appropriate steps would be taken should such a species 

be found. 

2011 Accomplishments and Highlights

■ Completed site-wide rare plant and animal surveys 

at the STM and NWTC. NREL conducted surveys for 

federally threatened species including Ute ladies’ 

tresses orchid (Spiranthes diluvialis), Colorado 

butterfly plant (Gaura neomexicana Woot. ssp. 

Coloradensis) at STM, and Colorado butterfly plant 

and Preble’s meadow jumping mouse (Zapus 

hudsonius preblei) at the NWTC. 

● All surveys completed resulted in clearance 

at STM; therefore, no NREL projects need to 

address listed species.

● Surveys at the NWTC resulted in clearance for 

rare plants and potential habitat for the Preble’s 

mouse (including critical habitat). 

● Survey results were shared with the USFWS to 

provide continued assurance that NREL activities do not impact rare species.

Ute ladies’ tresses orchid at Prospect Park, Lakewood, CO. Photo 

by Bob Fiehweg, NREL/PIX 20956
ENVIRONMENTAL PERFORMANCE REPORT 2011 63

PROGRAM MANAGEMENT

The Endangered Species Act (ESA; 16 USC §1531-1544 as amended) provides for the designation and protection of wildlife, fish, 

and plant species that are in danger of extinction, and preserves 

the habitats on which these species depend. Federal agencies are 

required to abide by the ESA and ensure that their actions do not 

adversely affect species that are federally listed under the ESA as 

threatened, endangered, or candidate species. 

Additional federal and state laws and regulations protect wildlife, 

such as the Bald and Golden Eagle Protection Act. The Colorado 

Division of Parks and Wildlife identifies a list of endangered, threatened, and wildlife species of concern for Colorado. Furthermore, 

the Colorado Natural Heritage Program (CNHP) has a list of rare 

species that, while not regulatory in nature, is useful as it is the 

only designation besides the ESA that considers rare plants. The 

list of threatened, endangered, candidate species and species of 

concern (i.e., bald and golden eagles, state listed species, CNHP 

species) are all considered imperiled species and can be referred 

to as a group known as “Threatened, Endangered or Species of 

Concern (TESC)” species. 

The USFWS lists seven species in accordance with the ESA as 

threatened, endangered, or a candidate for listing that could 

potentially occur in Jefferson County. Of these seven species, 

three have potential to occur on the STM or the NWTC sites. These 

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

orchid, and the Colorado butterfly plant. Periodic surveys are 

conducted for these three species to document their presence or 

absence on the STM or NWTC sites. 

NREL also considers other plant and animal species that may be 

state listed or generally in decline. Current information is obtained 

from both the Colorado Division of Parks and Wildlife and the 

CNHP. These two entities work together to track declining species 

and habitats throughout Colorado. Although not required by 

federal regulation, periodic surveys are conducted for species that 

may occur at NREL sites, typically, every five years when baseline 

vegetation and wildlife studies are conducted. These baseline 

surveys are a vital part of NREL’s NEPA program where impacts to 

natural resources from mission activities are assessed. 

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with requirements.

■ The USFWS has designated critical habitat for the Preble’s 

meadow jumping mouse on the adjacent Rocky Flats National 

Wildlife Refuge, and a small portion of this designated habitat 

extends onto the NWTC. NREL and DOE reviewed the area 

with a representative from the Colorado Field Office of 

USFWS. Although the habitat extending onto the NWTC site 

is of marginal habitat quality, USFWS has no mechanism to 

declassify critical habitat once it is designated. The area will be 

managed in accordance with its ecological importance. 

11.3 VEGETATION MANAGEMENT

Native plants have evolved over long periods of time in harmony 

with the local climate and surrounding soil, growing alongside microorganisms and resident wildlife to create bio-diverse 

ecosystems. Through this evolution, native plants have developed 

defenses against pests and diseases specific to their locale. When 

non-native plants are introduced into an environment, they often 

overcome indigenous plants, attracting new types of pests and 

diseases, while also sometimes depriving wildlife of nutrients 

and shelter. Plants such as kochia (Bassia scoparia), Canada thistle 

(Cirsium arvense), russian olive (Elaeagnus angustifolia), diffuse 

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

and myrtle spurge (Euphorbia myrsinites) are examples of nonnative plants that can have destructive effects on natural habitats.

For these reasons, the focus of NREL’s approach to vegetation 

management is as follows:

■ Conserve existing ecosystems in their natural state as much as 

possible.

■ Strive to replace disturbed vegetation with native species, or 

with adaptive species when necessary. 

■ Implement a program of weed management to prevent the 

spread of noxious weeds and implement measures to control 

these species.

■ Implement a sustainable landscape design and maintenance 

program. 

Approximately 60 acres of land within the NWTC site boundaries 

are managed as a conservation area. This includes on-site seeps 

and ephemeral drainages and ponds, native grassland habitat, and 

remnant tallgrass prairie. The purpose of conserving these areas is 

to avoid development to protect the site’s natural resources. 

Where removal of native vegetation cannot be avoided, reseeding 

is done using grass and forb seed mixes native to the local area. A 

Sulphur flower (Eriogonum umbellatum). Photo by Brenda Beatty, NREL/

PIX 20957
64 ENVIRONMENTAL PERFORMANCE REPORT 2011

palette of native flowering plants, shrubs, and trees has been identified for use on both the STM and NWTC campuses to enhance 

ecosystem diversity and integrity. NREL staff continually evaluate and modify revegetation techniques as needed to promote 

healthy plant establishment. 

To maintain the existing native vegetation and to ensure the 

success of revegetated areas, the laboratory has developed 

sustainable landscape management practices to: 

■ Minimize water use

■ Reduce the need for pesticides and fertilizers

■ Reduce maintenance costs

■ Maximize ground cover to reduce soil erosion

■ Establish a variety of habitats to support diverse wildlife

■ Create an aesthetically pleasing landscape environment.

During construction of the RSF, NREL participated in the SITES 

two year pilot program, a partnership of the American Society of 

Landscape Architects, the Lady Bird Johnson Wildflower Center 

at the University of Texas at Austin, and the United States Botanic 

Garden, along with a diverse group of other stakeholders. The 

purpose of this program is to develop the first national rating 

system for sustainable landscapes. While there currently exists 

a green building rating system (LEED certification) for new and 

existing buildings, there is no similar rating system for landscaped 

environments. 

RSF landscaping was designed and installed with sustainability 

in mind, and includes features such as native plantings, Xeriscape principles appropriate for arid climates, and infiltration of 

stormwater to provide water and nutrients. The landscaping was 

designed so that the RSF would give the impression of “rising out 

of the prairie” instead of being a structure on the landscape. 

NREL uses an integrated weed management approach that 

incorporates various types of weed control methods including 

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. The weed control program maintains the flexibility needed 

to respond to changes in weed populations from year to year. 

Periodic mapping of weed infestation areas assists in targeting 

weed control efforts.

NREL continues to refine and optimize this program with interdisciplinary participation, bringing together the expertise of 

biologists, landscape architects, water quality specialists, and 

maintenance staff.

PROGRAM MANAGEMENT

The vegetation management program meets the requirements of 

EO 13112, Invasive Species and the Colorado Noxious Weed Act, 

which require the control of invasive weeds. 

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 noxious weed management plans for three categories of weed species. Class A species are targeted for eradication. 

Class B species are subject to management plans designed to stop 

the continued spread of these species. Local governments can 

manage Class C-listed species at their discretion. If they do choose 

to manage them, the state provides funding for certain programs. 

The laboratory continues to address the control of these species 

using the integrated weed management approach described 

above. The weed maps below show the results of recent weed 

surveys at STM and the NWTC. These surveys are used to inform 

management and control of weeds at the sites. The table below 

lists noxious weed species at the STM and NWTC. 

STM 

No rare or imperiled plant species have been found at STM in 

recent surveys. Areas of mixed foothills shrublands (also called tall 

upland shrubland) have been identified at STM on top of the mesa 

within NREL’s conservation easement area. This natural community 

is listed as rare and imperiled by the CNHP. No development will 

occur in the conservation easement area. 

Native, water efficient landscaping at the RSF. Photo by Robb Williamson, 

NREL/PIX 20958
ENVIRONMENTAL PERFORMANCE REPORT 2011 65

NWTC

No rare or imperiled plant species were found on the site. 

However, the survey identified a small area of remnant 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 CNHP. 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, and 

was specifically protected during construction activities associated 

with the installation of an eight-acre PV array. 

For information on rare and imperiled plant species, see section 

11.2 Endangered Species and Species of Concern section for more 

information.

The FIFRA regulates the use, storage, and disposal of herbicides 

and pesticides. For application of certain types of herbicides designated as “restricted-use” by the EPA, a certified applicator must 

be used. Application of restricted-use herbicides is conducted in 

accordance with the regulation. NREL currently uses contractors 

for this type of application.

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with requirements.

■ The application of restricted-use herbicides was conducted 

using certified applicators. This included treatment of approximately 200 acres at the NWTC and two acres at STM.

■ Requested that contractors and NREL workers doing landscape 

maintenance compost landscaping waste, including weeds, 

to reduce the waste stream and to reduce the propagation of 

listed weeds.

2011 Accomplishments and Highlights

● Surveyed and mapped vegetation at STM and 

the NWTC. These surveys were done in anticipation of their use in the upcoming NEPA EAs 

in 2012, and to evaluate any changes that may 

have occurred since previous surveys. Maps 

were developed showing vegetation communities, wetlands and drainages, conservation 

areas, disturbed areas, and concentrations of 

noxious weeds. 

● Based on lessons learned from previous revegetation efforts, landscaping plans for current 

construction projects were adjusted to optimize plant establishment, withstand difficult 

shading and snow conditions, and deter animal 

browsing while providing wildlife habitat (i.e., 

spaces for nesting birds, plants for pollinators 

such as hummingbirds, and protective cover 

for other species).

● Developed landscaping plans for a stormwater 

detention basin using a significantly larger 

palette of grasses and other native vegetation to accommodate the variety of moisture 

conditions anticipated. This plant selection 

will stabilize soils and create habitat for wildlife 

anticipated to utilize the basin. 

● Conservation of existing ecosystems is 

accomplished to the maximum extent possible 

during design review of proposed construction 

projects, at an early stage when modifications 

to site layout are still possible. This approach 

was used successfully at the NWTC when a 

megawatt-scale turbine base was resituated 

to avoid a unique community of native plants 

along the site’s eastern border. 

Lark sparrow on mullein stalk. Photo by Brenda Beatty, 

NREL/PIX 20959

NOXIOUS WEED SPECIES IDENTIFIED AT THE

STM AND THE NWTC

Noxious Weed Class Species Present at STM Species Present at NWTC

Class A: Myrtle spurge None

Class B: Canada thistle

Common teasel

Dalmation toadflax

Diffuse knapweed

Hoary cress (whitetop) 

Hound’s tongue

Musk thistle

Russian olive 

Scotch thistle

Canada thistle

Chicory

Dalmation toadflax

Diffuse knapweed

Hoary cress (whitetop)

Leafy spurge

Musk thistle

Sulfur cinquefoil

Class C: Field bindweed

Cheatgrass 

Field bindweed

Cheatgrass
66 ENVIRONMENTAL PERFORMANCE REPORT 2011

Weed survey results at the STM. Illustration from Walsh
ENVIRONMENTAL PERFORMANCE REPORT 2011 67 Weed survey results at the NWTC. Illustration from Walsh
68 ENVIRONMENTAL PERFORMANCE REPORT 2011

11.4 WETLANDS AND FLOODPLAINS 

Floodplains are land areas adjacent to rivers and streams that 

are subject to recurring inundation. Wetlands are lands that are 

inundated or saturated by surface or ground water at a frequency 

and duration sufficient to support distinct soil types and plant 

communities. Wetland areas typically take the form of swamps, 

marshes, bogs and groundwater seeps and are frequently located 

within or adjacent to a floodplain. 

Both wetlands and floodplains play a key role in providing floodwater storage, reducing flood flow rate, and filtering floodwater. 

The resulting enriched floodplain soils promote the growth of 

wetland and riparian vegetation that provide habitat for a rich 

diversity of terrestrial and aquatic plants and animals. NREL seeks 

to preserve the important natural functions of its wetlands and 

floodplains, thereby protecting the physical, biological and chemical integrity of receiving waters and riparian areas on and adjacent 

to STM and the NWTC.

NREL protects its wetlands and floodplains through several means 

including:

■ Periodic vegetation surveys and wetland delineations

■ Mapping of wetland areas potentially affected by proposed 

construction

■ Identification of potential impacts

■ Coordination with other jurisdictions on the control of floodwaters leaving NREL sites.

PROGRAM MANAGEMENT

Wetlands became regulated in 1972 when, under the CWA, 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 certain soils, vegetation, and hydrologic criteria, are protected under the CWA Section 404, which is 

administered by the USACE, with program oversight provided by 

the EPA. Areas that do not meet the criteria above and do not fall 

within the jurisdiction of the Corps are not protected or regulated under Section 404. However, such areas may still perform 

wetland functions as described above and act as valuable ecologic 

components.

In 2009, the USACE visited the STM campus, after which they 

issued a jurisdictional determination stating that all drainages 

examined were considered upland swales and consequently are 

not regulated by the USACE. The jurisdictional determination, 

which is valid for a period of five years (through April 27, 2014), 

enables NREL to perform work in the upland swales without a 

USACE permit. As stated above, a preliminary wetland assessment 

and delineation was jointly conducted with the USACE on the 

NWTC site. A formal delineation will be submitted to the USACE in 

2012 to obtain a jurisdictional determination for the NWTC.

Counties typically map the 100-year floodplain boundaries within 

their jurisdiction and then develop regulations that control the 

type and amount of development within those areas. Jefferson 

County has no 100-year floodplain boundaries that affect the 

NWTC or STM. However, the new south entrance to the STM 

campus, which is being constructed on county and private property adjacent to STM, is located in the Lena Gulch 100-year floodplain. Lena Gulch is a small tributary of Clear Creek. To do work in 

the floodplain, a Floodplain Development permit is required from 

Jefferson County and Urban Drainage and Flood Control District. 

In order to obtain the permit, one must determine how their 

project alters the floodplain and then develop a Conditional Letter 

2011 Accomplishments and Highlights

● Vegetation surveys were performed at the 

NWTC and STM. This information will be used 

to guide campus development and weed 

management activities to protect wetland 

plant communities. 

● A preliminary wetland assessment of the NWTC 

drainages was jointly conducted with the U.S. 

Army Corp of Engineers (USACE). In addition 

to serving as the basis for conducting wetland 

delineations and accurate mapping, this effort 

helps protect and potentially improve valuable 

wetland areas.

● As part of recent construction, improvements 

were made to STM’s Middle Drainage, including widening the channel bottom, sloping the 

channel banks, and realigning the channel to 

more efficiently convey and store flood waters 

and prevent erosion. 

Ephemeral pond, NWTC conservation management area. Photo by 

Brenda Beatty, NREL/PIX 21687
ENVIRONMENTAL PERFORMANCE REPORT 2011 69

of Map Revision (CLOMR). Once approval is given the project can 

proceed. Once the project is completed, a final Letter of Map Revision (LOMR) is recorded.

Federal regulation 10 CFR 1022, Compliance with Floodplain and 

Wetlands Environmental Review Requirements, establishes policy 

and procedures for discharging DOE’s responsibilities under E.O. 

11988, Floodplain Management, and E.O. 11990. For projects 

that occur in floodplains or have the potential to affect wetlands, 

DOE must determine the potential impacts to the floodplain or 

wetlands, document this in a floodplain and wetland assessment, 

and complete notices of availability to appropriate government 

agencies (e.g., federal emergency management organizations and 

state and local governments) and to persons or groups known to 

be interested in or potentially affected by the proposed floodplain 

or wetland action. For such actions, DOE must also distribute the 

notification in the area where the proposed action is to be located 

(e.g., by publication in local newspapers). After the consideration 

of public and agency comments, the process concludes with the 

preparation of a Floodplain and Wetland Statement of Findings.

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ Delineated regulatory wetlands adjacent to Lena Gulch that 

were impacted by the construction of a new south entrance to 

the STM campus. Bridge construction activities associated with 

the project resulted in the permanent loss of 0.25 acres along 

Lena Gulch. A USACE Nationwide Permit No. 14 for Linear 

Transportation Projects was obtained and this loss was mitigated through acquisition of wetland banking credits through 

the South Platte Wetlands Bank in Brighton, Colorado. 

■ A CLOMR was filed with Jefferson County with Urban Drainage 

and Flood Control District concurrence for bridge construction 

associated with the new south entrance road since a number 

of bridge elements such as abutments and headwalls would 

be in the floodplain. A letter of concurrence regarding the 

CLOMR was received on February 25, 2011. With Urban Drainage and Flood Control District approval, a Jefferson County 

Floodplain Development permit was obtained for the new 

south entrance bridge. 

■ A floodplain and wetland assessment was prepared to 

describe the potential floodplain and wetland impacts associated with the construction of the new south access road 

to the STM campus. Because the project would cross the 

100-year floodplain of Lena Gulch and have the potential to 

affect wetlands in this same area, in accordance with 10 CFR 

1022, a floodplain and wetland assessment was prepared and 

the public and federal and state agencies were notified of 

the availability of the assessment in May, 2011 via letter and 

newspaper advertisement. DOE determined that this project 

would not result in adverse impacts to the 100 year floodplain 

and impacts to wetlands were properly mitigated, as discussed 

above. Temporary disturbance within the floodplain will cease 

following completion of construction activities. Proper erosion 

and sediment control measures are being utilized and site 

restoration will be done following completion of construction 

activity in 2012. DOE determined that the action would not 

result in any increase in the base flood elevations from the 

project conditions to post-project conditions or other longterm impacts to the floodplain and its functionality. No effects 

to lives and property associated with floodplain disturbance 

are anticipated. No substantive comments were received from 

the public or agencies, and a Floodplain and Wetland Statement of Findings was issued in June 2011.

■ This program was in compliance with all local and federal 

requirements.

11.5 CULTURAL RESOURCES

Cultural resources are defined as any prehistoric or historic 

district, site, building, structure, or object considered important 

to a culture, subculture, or community for scientific, traditional, 

religious, or other reasons. NREL identifies and protects cultural 

resources in several ways:

■ An established cultural resources program oversees preservation of artifacts that may be found at any of the NREL facilities. 

■ Surveys are periodically conducted to document presence 

or absence of cultural or historic resources, while considering 

project impacts to the human environment. When surveys 

reveal artifacts, staff work with the SHPO to determine if the 

artifacts are eligible for consideration as cultural or historic 

resources. 

■ Construction contractor site orientation training informs workers that in the event they discover any evidence of cultural 

resources during ground-disturbing activities at STM or the 

NWTC, workers are to stop all work in the vicinity until a qualified archaeologist evaluates the significance of the find. 

The STM site has had a long history as a location with a variety 

of human uses over the decades. In 1903, the Colorado National 

Guard established the State Rifle Range at a location three miles 

east of Golden, Colorado. The site was designated as “Camp 

George West” in 1934 honoring civil war veteran and Golden business man, George West. George West was Adjutant General from 

1887-1889 and editor and publisher of the Transcript newspaper 

in Golden, Colorado. He was credited as the first person to recommend this land parcel be used by the Colorado National Guard. 

This site became an integral part of Colorado National Guard activities throughout the first half of the 1900s. By the 1920s, the camp 

totaled 750 acres and many buildings were added throughout 

the 1930s and 1940s. During World War II, much of Camp George 

West was leased to the federal government for military training 

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

up residence at Camp George West, including the Colorado State 

Highway Courtesy Patrol, the Colorado Law Enforcement Training 

Academy, and the Colorado Correctional Center. In 1981, 300+ 

acres were transferred to the federal government for solar energy 

research purposes. An additional 25 acres was transferred to DOE 

in 2003. Today, the STM site totals 327 acres.
70 ENVIRONMENTAL PERFORMANCE REPORT 2011

PROGRAM MANAGEMENT

Cultural resources are protected under Section 106 of the NHPA of 

1966, as amended. Significant cultural resources are either eligible 

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

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, pottery, tools). Prehistoric 

resources that predate the advent of written records in a region 

range from a scatter composed of a few artifacts to village sites 

and rock art. Historic resources may include campsites, roads, 

fences, trails, dumps, battlegrounds, mines, and a variety of other 

features. 

Architectural resources include standing buildings, dams, canals, 

bridges, and other structures of historic or aesthetic significance. 

Architectural resources generally must be more than 50 years old 

to be considered for protection under existing cultural resource 

laws. However, more recent structures, such as Cold War facilities, may warrant protection if they manifest the potential to gain 

significance in the future. 

A traditional cultural resource can be defined as a property that 

is eligible for inclusion in the National Register of Historic Places 

because of its association with cultural practices or beliefs of a 

living community that are rooted in the community’s history, and 

are important in maintaining the continuing cultural identity of 

the community. Traditional resources may include archaeological resources, buildings, neighborhoods, prominent topographic 

features, habitats, plants, animals, and traditional culture. 

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 limited surveys of the 

Camp George West District involving the STM site have also been 

conducted. 

Three historical sites were recognized as significant cultural 

resources that should be preserved. These resources include:

■ An open-air amphitheater

■ A stone bridge spanning a natural drainage channel adjacent 

to the amphitheater

■ A stone and concrete ammunition bunker below the amphitheater. 

The three structures were constructed during the Works Progress 

Administration era in the 1930s. Through NREL’s efforts, these 

structures have been added to the National Register, with the 

amphitheater and stone footbridge listed together as a single 

resource. 

The Camp George West Historic District, also listed on the National 

Register of Historic Places, includes the 25-acre parcel of the STM 

site south of Denver West Parkway. Two types of contributing 

historic archaeological resources have been identified on this 

parcel: firing range lines and a low rock wall. Contributing resources are those features within a historic district that contribute to the 

district’s overall eligibility for the National Register. 

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with requirements.

■ Construction activities were completed on the new addition 

to the RSF. During preliminary excavations, a few items were 

unearthed that were reviewed for cultural significance, though 

none were found to be of unique value. 

■ In 2010, a Class III Cultural Resource Inventory was completed 

on the final configuration of the new south entrance to STM, 

which lies within the Camp George West Historic District. SHPO 

concurred that construction would impact a 500-yard firing 

line and a 600-yard firing line, both of which are contributing 

features of the Camp George West Historic District, and that 

impacts should be mitigated. In 2011, DOE signed a memorandum of agreement with the SHPO to mitigate impacts to these 

features and an interpretive sign will be placed in Pleasant View 

Community Park. 

“Review” of the 157th infantry, 1934. Used with permission from the 

Denver Public Library.

Encampment at Camp George West looking northeast toward STM. 

Used with permission from the Jefferson County Historical Society.
ENVIRONMENTAL PERFORMANCE REPORT 2011 71

■ In 2009, DOE signed a memorandum of agreement with the 

SHPO for the removal of a 200-yard firing line, a 300-yard 

firing line, and a target area as part of the construction of a 

new surface parking lot. As mitigation, DOE was required to 

prepare a Historic American Buildings Survey Historic American 

Engineering Record (HABS/HAER) report prior to the removal 

of the firing lines and target area. In addition to these required 

actions, the 300-yard firing line was salvaged and moved in 

2011 to the new stormwater detention feature at the STM 

campus. Now the firing line is a prominent feature of an 

interpretive trail surrounding the stormwater detention area. In 

addition, an interpretive sign will provide a brief description of 

the firing line.

In 1999, DOE granted a conservation easement for 177 acres of 

the STM site to Jefferson County. The purpose of the 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. 

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 

■ 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 property5. The baseline 

inventory includes a description of the geographical setting and 

adjacent property owners, access and use of the property by the 

public, and a description of the existing environmental conditions 

of the property (including geology, hydrology, vegetation, wildlife, 

and cultural resources).

Jefferson County Open Space maintains formal trails on the 

conservation easement property. Two trails cross the easement, 

connecting Denver West Parkway (near the NREL site entrance) 

to the trails on the mesa top. NREL staff and the public use these 

trails daily.

2011 PROPERTY ASSESSMENT 

During 2011, 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 and no degraded conditions or other 

environmental issues were found.

Open-air amphitheater on the STM Site. Photo by Warren Gretz, 

NREL/ PIX 12596 

Pistol range at Camp George West. Used with permission from the Denver 

Public Library.

12 Conservation Easement Lands

 5 U.S. Department of Energy, Golden Field Office (1999). National Renewable Energy Laboratory (NREL) Site Conservation Easement Baseline Inventory. Golden, Colorado. 
72 ENVIRONMENTAL PERFORMANCE REPORT 2011

The STM campus draws hundreds of commuter vehicles daily, as 

well as visitor and delivery traffic coming to and leaving the site. 

NREL continued to bring staff on-site, moving them into offices in 

the RSF building throughout 2011. However, many of those staff 

were parking in off-site parking locations while on-site parking 

was being constructed. Traffic management for the site is important for minimizing negative impacts to traffic flow on Denver 

West Parkway and in nearby neighborhoods and business areas. 

Reducing traffic also reduces noise and light pollution, vehicle 

emissions, fuel use, parking requirements, and road maintenance 

costs.

The laboratory seeks to reduce traffic by encouraging:

■ Alternative modes of commuting, such as mass transit, ridesharing (carpool and vanpool), and bicycling 

■ Telecommuting one or more days per week

■ Flexible shifts and alternate work schedules

■ Teleconferencing, videoconferencing, and web-based tools for 

conducting meetings and trainings remotely.

Periodic traffic monitoring at the STM site provides information 

regarding total traffic volumes and peak vehicle trips. Baseline 

traffic levels were established prior to moving increased numbers 

of staff to STM and traffic has been monitored during 2011 

to measure changes in traffic volumes to better inform traffic 

management. 

Traffic analysis is periodically performed to measure NREL-generated traffic volumes, as well as volumes at the Denver West Parkway/ 

Marriott Boulevard (DWP/DWMB) intersection and the Quaker 

St./South Golden Road intersection. Monitoring is conducted to 

confirm that traffic flow has not degraded to an unacceptable 

level. Monitoring will continue to be conducted as additional staff 

are relocated to STM.

Capacity improvements and the addition of a right-turn lane at 

the DWP/DWMB intersection are planned for the near future. The 

planned capacity improvements will increase acceptable peak 

hour thresholds. An additional entrance to the STM site is anticipated to be completed in May 2012, at which point it is expected 

that traffic volumes using the east entrance will substantially 

decrease, shifting a portion of volume to the new south entrance. 

PROGRAM MANAGEMENT

A mitigation action plan (MAP), finalized in May 2008, was developed to address potential environmental impacts from changes 

in traffic at STM and to support an EA FONSI for several projects 

at the laboratory. The MAP specifies the methods for implementing mitigation measures to ensure that the impacts of continued 

and expanded laboratory operations are not significant. The MAP 

requires that: 

■ The DWP/DWMB intersection operates at a LOS of D or better. 

13 Traffic Management

2011 Accomplishments and Highlights

■ Conducted a commuting survey of employees to 

identify commuting methods and measure the 

effectiveness of previous traffic reduction efforts. 

Key results include:

● Twenty-five percent of staff currently work 

AWSs.

● Nineteen percent of staff telecommute one 

time per week and 5% telecommute at least 

two times per week.

● Twenty-five percent of staff daily commute 

trips were made with alternative transportation, up 8% from 2007. The table, Commuter 

Habits Comparison, shows the results of the 

commuter survey.

■ NREL’s telecommuting program was implemented 

laboratory-wide in 2011. 

COMMUTER HABITS COMPARISON, 2007 TO 2011

Mode 2007 Survey 2011 Survey Change

Drove Alone 81 % 75% -8%

Bicycle 3% 4% +1%

Transit (bus) 6% 7% +1%

Carpool/Vanpool 6% 8% +2%

Walk 2% 1% -1%

Telecommute 1% 5% +4%

Other 1% 1% 0%
ENVIRONMENTAL PERFORMANCE REPORT 2011 73

■ The Quaker St./South Golden Road intersection operates at a 

LOS of D or better.

■ Traffic flow to and from the STM east entrance will be monitored semi-annually. 

■ A report on the implementation and effectiveness of the 

STM traffic mitigation measures will be published in the NREL 

Annual Site Environmental Report.

The MAP also identified specific mitigation strategies to be 

implemented as needed to ensure that the traffic thresholds are 

not exceeded. These actions include TDM strategies such as AWSs, 

expanded shuttle services, expanded carpools, encouraging 

walking and bicycling, increased use of the Quaker St. entrance, 

infrastructure improvements, and traffic flow control measures. 

The TDM measures implemented are described below.:

Alternative Modes of Commuting

■ Eco Passes provided to employees encourage use of the RTD 

public transportation system. This includes unlimited RTD 

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

■ Shuttle routes provide connections between NREL facilities in 

Golden and three regional RTD transit stations in Lakewood, 

Wheat Ridge, and Boulder. 

■ Incentive parking is provided for vanpools and carpools at STM, 

Golden Hill and Denver West sites. 

■ Vanpool subsidies are available for participants who commute 

in formal organized vanpools.

■ Bike racks and bicycle maintenance stations are in key locations on the STM site. Bike racks on shuttle vehicles permit staff 

to take their bikes with them when they commute or move 

between buildings.

■ RideShare Connections intranet site allows staff to post and 

search listings for potential carpool and vanpool partners 

within NREL.

■ Literature kiosks in key building locations provide shuttle and 

RTD schedules, bicycle maps, and telecommuting information.

■ Information sharing events promote safe bicycling, rideshare 

(carpool and vanpool) and RTD services.

Flexible Workplace Practices

Conferencing by video, telephone, and the internet as well as 

Alternative Work Schedules (AWS) provide flexibility in how 

people work, saving staff time, energy, and money. An AWS policy 

allows employees to work varying schedules (with management 

approval), including four-day workweeks, reduces the miles driven 

by employees to and from the laboratory. 

Telecommuting

A pilot telecommuting program initiated in the fall of 2009 was 

opened laboratory-wide in the first quarter of 2011. Laboratorywide employee surveys have confirmed that adoption of this 

program has been very strong.

Teleconferencing

The laboratory promotes and encourages use of teleconferencing 

and videoconferencing for meetings to decrease local vehicle trips 

and air travel. 

2011 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with requirements.

■ Transportation on Demand (TDM) management measures 

required by the MAP were continued in 2011. 

■ PM Peak Hour traffic averages at the DWP/DWMB intersection 

were 260 vehicle trips. The monitoring period was October 

2010 through April 2011. The MAP threshold of LOS D or better 

is equivalent to a maximum of 387 vehicle trips per hour entering or leaving the site at the east entrance at the afternoon 

rush hour.

■ PM peak hour LOS at the DWP/DWMB intersection was at 

LOS B, which does not exceed the MAP threshold of LOS D or 

better.

■ PM peak hour LOS at the Quaker St./South Golden Road 

intersection was at LOS B, which does not exceed the MAP 

threshold of LOS D or better.

Detailed Traffic Metrics and Results 

Previously conducted traffic studies indicated that the greatest impact to traffic in the local area from NREL activities occurs 

between 4:30 p.m. and 5:30 p.m. This hour has been designated 

the PM Peak Hour. Solar powered radar traffic counters were 

installed at the east (main) entrance to the STM site in June 2010. 

The counters continually recorded traffic volumes coming to and 

leaving the sites to monitor traffic as it relates to the MAP threshold. Traffic counts for the PM peak hour were extracted from the 

complete dataset for the recording period and compared against 

the MAP threshold. The MAP threshold indicates the amount 

of traffic that would cause degradation to the LOS at the DWP/

DWMB intersection.

The figure on page 74 shows the median hourly distribution of 

traffic counts at the east entrance to STM by hour during a six 

week monitoring period in February and March 2011. The allowable threshold and the median traffic flow volumes are indicated 

on the figure. 

The applicable traffic volume threshold identified in the MAP 

is 387 vehicle trips in the PM Peak Hour (from 4:30 p.m. to 5:30 

p.m.) at the DWP/DWMB intersection. This threshold identifies the 

acceptable number of vehicle trips NREL can contribute to the 

intersection without causing significant degradation to flow. In 

2011, PM Peak Hour traffic volume averages remained below the 

MAP threshold. 

■ PM Peak Hour Average (average for six months from October 

2010 to April 2011) = 260 vehicle trips 

A summary of the PM peak hour volumes for each weekday is 

presented in the table on page 74.
74 ENVIRONMENTAL PERFORMANCE REPORT 2011

In April 2011, the radar traffic counters were relocated to accommodate new signage at the east site entrance. As a result of the 

relocation, traffic data was inaccurate and unusable for the period 

May 2011 through December 2011. 

In December 2011, in order to confirm that traffic counts had 

not increased to the point of degrading the LOS at the key 

intersections identified in the MAP, traffic analyses were conducted 

at the DWP/DWMB and Quaker St./South Golden Road intersections. The results indicate:

■ The LOS at the DWP/DWMB intersection is at LOS B during the 

PM peak hour. LOS B is within the MAP allowed service levels.

■ The LOS at the intersection of Quaker St. and South Golden 

Road is at LOS B during the PM peak hour. LOS B is within the 

MAP allowed service levels.

The analysis indicates that while NREL traffic volumes have 

increased, LOS remains at acceptable levels. The analysis also 

shows that background traffic has not substantially increased. This 

suggests that the NREL generated PM peak hour traffic volume 

thresholds identified in the MAP could be adjusted to better 

reflect current conditions. PM peak hour traffic thresholds could 

be increased from 387 vehicle trips per hour to 747 trips per hour 

while still maintaining an acceptable LOS. 

Median Hourly Distribution

12 am1:30am

400

350

300

250

200

150

100

50

0

1:30am2:30 am2:30am3:30 am3:30am4:30 am4:30am5:30 am5:30am6:30 am7:30am8:30 am8:30am9:30 am9:30am10:30 am10:30am11:30 am11:30am12:30 pm12:30pm1:30 pm1:30pm2:30 pm2:30pm3:30 pm3:30pm4:30 pm4:30pm5:30 pm5:30pm6:30 pm6:30pm7:30 pm7:30pm8:30 pm8:30pm9:30 pm9:30pm10:30 pm10:30pm12 am6:30am7:30 am

Total (Incoming/Outgoing) Threshold

During 6 Week Monitoring Period in February 2011 to March 2011

Traffic Counts by Time of Day at the East Entrance to STM.

SUMMARY OF PM PEAK TRAFFIC FLOWS, VEHICLE 

TRIPS IN PM PEAK HOUR

Statistics for Total PM Peak Hour (4:30 p.m. to 5:30 p.m.) October 2010 through 

April 2011

Mon. Tue. Wed. Thu. Fri. Weekday

Average 263.0 278.1 275.5 261.7 220.8 259.8
ENVIRONMENTAL PERFORMANCE REPORT 2011 75

In 2011, vegetation surveys were completed for STM and the 

NWTC. Plant communities and species were identified for each 

of the sites. Changes in results from similar surveys completed in 

2000 are noted.

STM PLANT COMMUNITIES

The majority of vegetation at STM belongs to the grassland 

community type. Within that association, there are two distinct 

community types: short-grass grassland on the mesa top and 

mixed-grass grassland located on the slopes and toe area. Other 

mapped vegetation communities at STM include ravine shrubland, tall shrubland, short shrubland, and wetlands. The plant 

communities are described below and mapped as illustrated in 

the figure below.

SHORT-GRASS GRASSLAND

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

dominant grass species are blue grama (Chondrosum gracile), 

a native prairie species, and cheatgrass (Anisantha tectorum), a 

noxious weed. Populations of diffuse knapweed (Acosta diffusa) 

and Dalmatian toadflax (Linaria genistifolia subsp. dalmatica) are 

scattered throughout the whole community. These two noxious 

weeds comprise approximately 1% of the short-grass. 

Alyssum (Alyssum parviflorum), an introduced species, is the dominant forb. Several species of prickly pear cactus (Opuntia fragilis, O. 

macrorhiza, O. phaeacantha, and O. polyacantha) occur throughout 

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

viridiflorus) and pincushion cacti (Coryphantha missouriensis and 

C. vivipara var. vivpara). Well-draining hillocks often support thick 

stands of needle-and-thread grass (Hesperostipa comata) and 

yucca (Yucca glauca). Some short shrubs such as rubber rabbitbrush (Chrysothamnus nauseosus subsp.), chokecherry (Padus 

virginiana), and skunkbrush (Rhus aromatica subsp. trilobata) occur 

infrequently in the shortgrass area and concentrate along the 

rimrock areas. Several large hackberry trees (Celtis reticulata) are 

clustered at the very edge of the mesa top.

Historically, this short-grass grassland was probably dominated 

by blue grama grass and other short-grass species such as buffalo 

grass (Buchloë dactyloides), intermixed with the other species 

associations described above. However, this entire mesa-top area 

has become dominated by cheatgrass, an aggressive noxious 

weed. This weed is changing the appearance and general species 

composition of the area by apparently out-competing native 

plants.

MIXED-GRASS GRASSLAND

The mesa slopes and toe areas on the STM site also support 

blue grama and cheatgrass, but are dominated by a mixed-grass 

species association of needle-and-thread grass and western 

wheatgrass (Pascopyrum smithii), with smaller amounts of big 

bluestem (Andropogon gerardii), side-oats grama (Bouteloua curtipendula), three-awn (Aristida purpurea), and green needle grass 

(Nassella viridula). As in the short-grass areas, a large number of 

forbs also occur in the mixed-grass grassland.

A few patches of anomalous vegetation occur within the mixedgrassland where subsurface water appears to be close to the 

surface. These areas support wide swaths of mat muhly (Muhlenbergia richardsonis). One is located on a southern-facing slope, 

near the eastern property boundary. The other is located on a 

southwestern-facing slope of the ravine north of the Visitor Center. 

This area is notable for a large population of poison ivy (Toxicodendron rydbergii), which grows in thickets of tall (one meter and larger) 

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

of plains cottonwood (Populus deltoides) saplings, skunkbrush, 

chokecherry, and snowberry occur in this patch as well.

The mixed-grass areas grade into both the upland and ravine 

shrublands and contribute the majority of the understory in these 

areas. Some mixed-grass areas also blend into disturbed areas, 

where reclamation species such as crested wheatgrass (Agropyron 

cristatum) and smooth brome have been planted and have subsequently spread into the mixed-grass community.

UPLAND SHRUBLANDS

Shrubland habitat occurs along the upper sides of ravines, and on 

the steeper mesa slopes, becoming more prominent as elevation 

increases up to the top of the mesa. The upland shrubland habitat, 

which excludes the shrublands in the ravine bottoms, comprises 

tall shrubland and short shrubland communities very similar in 

overall composition but distinguished by the dominant species. 

TALL SHRUBLAND

The tall shrubland areas are defined by stands of mountainmahogany (Cercocarpus montanus) that occur along the rim of 

the mesa, usually where volcanic cap rock is exposed, and on the 

upper mesa slopes below rimrock areas. The understory is notably 

sparse throughout this community, with a large amount of bare 

soil. Cheatgrass is the most common herbaceous species in these 

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

cacti.

SHORT SHRUBLAND

The short shrublands occur on elevated flat areas amidst the 

surrounding grasslands, some of which appear to have experienced surficial disturbance in the past. These areas are distinctive 

because of their dominance by rubber rabbitbrush. The other 

common location for short shrublands is on the outer slopes of 

the ravines. Skunkbrush defines these and other short shrublands 

along the upper portions of the steepest slopes of the mesa. These 

communities usually grade into the ravine shrublands along the 

Appendix A: Plant Communities at 

STM and the NWTC
76 ENVIRONMENTAL PERFORMANCE REPORT 2011

Vegetation survey results at STM. Illustration from Walsh 
ENVIRONMENTAL PERFORMANCE REPORT 2011 77

drainage bottoms and the tall shrublands near the top of the mesa 

slopes. The short shrubland community also has a sparse understory of the same grasses and forbs as the tall shrub community. 

RAVINE SHRUBLANDS

Ravine shrublands are limited to the lower sides and bottoms 

of the drainages that cut down through the mesa slopes. These 

communities support a variety of shrubs such as skunkbrush, 

chokecherry, and wild plum (Prunus americana), often growing in 

dense, impassible thickets. A few plains cottonwoods and peachleaf willow (Salix amygdaloides) trees occur at the top of the ravine 

channels and in other portions of the channel where the subsurface water table appears to be relatively high. A diverse herbaceous component is found in these drainages. In one instance 

near the southeast site boundary, a ravine shrubland grades into 

an ephemeral drainage at the toe of the mesa. This drainage is 

vegetated with grassland species and conducts only occasional 

surface water run-off. 

WETLANDS

Five very small communities on the STM site were found to 

support wetland vegetation. These communities were not examined for the soils and hydrology that would classify them as functioning wetlands; rather they are noted only for their domination 

by wetland vegetation. These are limited to very small areas (less 

than half an acre in total). One is in a shallow swale at the mouth 

of the ravine at the southwestern corner of the project boundary 

where surface water and/or subsurface drainage have created a 

pocket of saturated soil. Species here include sedges (Carex spp.), 

rushes (Juncus spp.), bulrush (Schoenoplectus sp.), and peach-leaf 

willow. The second wetland could have formed as a result of past 

construction activities. This linear depression supports wetland 

vegetation along the central portion of the western site boundary, northeast of the solar facility. Perhaps where equipment was 

once staged, this area appears to hold seasonal water for enough 

consecutive growing seasons to support some wetland vegetation including arctic rush (Juncus arcticus), American speedwell 

(Veronica americana), and broadleaf cattail (Typha latifolia). 

The wetland at the mouth of the ravine may no longer experience 

the hydrology that originally allowed these plants to establish 

there. In 2002, this plant community supported populations of 

cattails that were not observed in 2010. 

Three small seeps are located on the hill slope between the Visitor 

Center and the public trail on the far eastern boundary of the 

site. These seeps are dominated with sedges, rushes, and Canada 

thistle (Cirsium arvensis).

A seventh wetland community that was observed by Plantae, in 

20007, no longer appears to support wetland vegetation. In 2002, 

cattail species near an old stock tank in the eastern-most drainage 

appeared to have been supported by a pipe coming out of the 

hillside. Although the stock tank was observed in 2010, it appears 

the cattails have not persisted in the intervening years. 

DISTURBED/RECLAIMED

This habitat type comprises all of the areas at the site that have 

experienced surface disturbance to vegetation caused by human 

activities. These mostly occur on the perimeter of the buildings, 

roads, parking lots, and soil dumping areas. Most of these areas 

appear to have been re-vegetated and support a combination of 

native grassland plants, planted ornamental revegetation species, 

and native and introduced weeds.

NWTC PLANT COMMUNITIES

The majority of the vegetation at the NWTC site belongs to the 

mixed-grass prairie association of the grassland formation. Mixedgrass prairie is defined by the presence of grass species typical 

of the tall-grass or true prairie such as big bluestem (Andropogon 

gerardii), little bluestem (Schizachyrium scoparium), and prairie 

dropseed (Sporobolus heterolepis), with species more typical of the 

short-grass prairie such as blue grama (Chondrosum gracile) and 

buffalo grass (Buchlöe dactyloides). Intermediate grasses (midgrasses) such as the needle grasses (Hesperostipa and Nassella 

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

Thinopyrum spp.), and blue grasses (Poa spp.) are also important 

constituents of mixed-grass prairie. 

The grasslands at the NWTC fall into the xeric mixed grassland 

community type identified and classified primarily on available 

soils and soil moisture, reflected in xeric mixed grassland plant 

species assemblages. 

A number of changes in vegetation patterns noted since the 

NWTC site was previously mapped (DOE 19986 , Plantae 20007) are 

discussed by specific plant community below. 

The plant communities are described below and mapped as illustrated in the figure below.

XERIC MIXED GRASSLAND 

Xeric mixed grassland is by far the largest and most widespread 

community type at the NWTC site. These areas do not have access 

to regular soil moisture (xeric conditions) and are dominated by 

typical short- and mixed-grass prairie species. This plant community includes a large variety of native grass species as well as a 

diverse forb component, typical of mixed grasslands. Dominant 

species noted include big bluestem, little bluestem, and prairie 

dropseed, blue grama, and buffalo grass. Intermediate grasses 

(mid-grasses) such as the needle grasses, wheat grasses, and blue 

grasses are also important constituents of mixed-grass prairie. 

Species flowering in late spring include little bluestem, cheatgrass, 

sand lily (Leucocrinum montanum), wild iris (Iris missouriensis), 

Lambert locoweed (Oxytropis lambertii), mouse-ear (Cerastium 

strictum), western wallflower (Erysimum capitatum), and prairie 

golden pea (Thermopsis rhombifolia). 

MESIC MIXED GRASSLAND

A distinctive single area dominated by big bluestem was mapped 

as mesic mixed grassland in the southwestern portion of the 

6 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.

7

 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, Colorado.
78 ENVIRONMENTAL PERFORMANCE REPORT 2011

Vegetation mapping at the NWTC. Illustration from Walsh
ENVIRONMENTAL PERFORMANCE REPORT 2011 79

NWTC site by Plantae in 2000 . The relative size of the area, as 

well as the complete dominance of big bluestem, was distinctive enough to designate this community in the current survey 

as well. Dominant species noted include big bluestem, smooth 

brome, Canada thistle (Cirsium arvense), and Canada bluegrass 

(Poa compressa). Species flowering in late spring include lambert 

locoweed. 

PONDEROSA PINE WOODLAND

One woodland habitat, defined by a single community, the 

ponderosa pine (Pinus ponderosa) woodland, occurs in the 

northwestern corner of the site along a granite outcrop. This small 

area supports a very diverse native plant community including 

common grassland and foothills species, as well as a number of 

introduced and noxious weeds. Dominant species noted include 

ponderosa pine (Pinus ponderosa), smooth bromegrass, crested 

wheatgrass, and green needlegrass (Nassella viridula). Species flowering in late spring include sand lily, western snowberry (Symphoricarpus occidentalis), groundsel (Senecio sp.), and wax current (Ribes 

cereum). 

UPLAND SHRUBLAND

A small upland shrub community is located to the southeast of 

the ponderosa pine woodland, where the same ridge arises to a 

lesser degree from the surrounding grassland community. This 

rocky ridge supports shrub species interspersed with grasses and 

forbs representative of the surrounding grasslands. Dominant 

species noted include western snowberry, Canada wild rye (Elymus 

canadensis), Canada bluegrass, Kentucky bluegrass (Poa pratense), 

and little bluestem. Species flowering in late spring include prairie 

goldenpea. 

An isolated group of hawthorn (Crataegus erthyropoda) shrubs 

occurs along the western site boundary, within the NWTC site 

boundary. These trees are at the top of the slope and occur 

directly east of an active area of construction disturbance, which is 

outside the NWTC site boundary. 

PALUSTRINE EMERGENT WETLAND

Two wetlands on the site fall into the palustrine emergent 

category. The first is a linear depression on the southern side of 

the south road. This area appears to have developed as the result 

of soil excavation intercepting sufficient surface water run-off from 

the adjacent road to support sedge species (Carex spp.). A second 

wetland is located on the southern boundary in an area previously 

disturbed from the neighboring industrial activities. This wetland 

comprises a center of cattails (Typha angustifolia) surrounded by a 

stand of coyote willow (Salix exigua). 

Two palustrine emergent wetlands were mapped in the mesic 

mixed grassland in the 2000 growing season. These areas appear 

to have dried considerably in the intervening ten years. The 

small wetland pockets of cattails (Typha spp.) that occurred in the 

southern portions of this area are no longer present, apparently 

replaced, by large stands of Canada thistle. Dead remnants of 

Baltic rush (Juncus balticus) can be found in the area litter (prior 

years’ herbaceous vegetation). The dominant species noted was 

smooth bromegrass. 

HEADWATER WETLAND

Areas of headwater wetland occur along the two ephemeral drainages on the NWTC site. Both drainages occur in the northeastern 

portion of the site, one flowing east and one flowing north. Both 

show evidence of intermittent surface flow. The northern-most 

drainage is a tributary of Coal Creek and the second drainage is a 

tributary to Rock Creek. 

Surface flow in the drainage to the northeast appears to be 

augmented by outflow from the groundwater seep wetland 

on the western bank. The second and larger drainage conducts 

surface flows through the center of the site off to the eastern 

fence line. The upper reaches of this drainage are a shallow 

grassland swale (also shown in the NWTC weed map). This channel deepens as it flows east across the site. At its eastern reaches, 

this drainage clearly intercepts subsurface water, although not 

in sufficient quantities to produce consistent surface flow. At the 

point where this drainage leaves the NWTC site, there is a humanconstructed rock wall. Dominant species noted include Canada 

thistle, Baltic rush, curly dock (Rumex crispus), common eveningprimrose (Oenothera villosa), smooth bromegrass, and western 

wheatgrass (Pascopyrum smithii). 

GROUNDWATER SEEP WETLAND

Two areas of groundwater seep wetland are located on the NWTC 

site. The first occurs west of the ponderosa pine woodland, in the 

northwestern portion of the site along the northern fenceline. 

The species in and surrounding this draw comprise more upland 

species than noted in 2000.

The second occurs over a very small area on the banks of the 

northern drainage. This community is a clearly demarcated area of 

primarily wetland plants amidst the surrounding grassland. Fifty 

plant species were identified in this community in 2000, many of 

which also occur in the headwater wetland to the south. Dominant species noted include sedges (Carex sp.) and rushes (Juncus 

sp.). Common teasel (Dipsacus fullonum) has invaded the northern 

drainage area. Species flowering in late spring include common 

teasel, showy milkweed (Asclepias speciosa), wild iris, fieldmint 

(Mentha arvensis) and Canada thistle. 

SEASONAL POND 

A seasonal pond and pond margin occur at the northwestern 

corner of the site, west of the southern terminus of the ponderosa 

pine woodland. This area appears to depend on an elevated spring 

and early summer water table for the hydric soil moisture conditions that support this community. Observers have noted that the 

pond depression often contains standing water in the spring and 

early summer in some years8 However, no standing water was 

observed in this area during the most recent survey. These drier 

soil conditions are reflected in a shift of dominant plant species in 

8 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, Colorado.
80 ENVIRONMENTAL PERFORMANCE REPORT 2011

this community between the 2000 and 2011 surveys. Dominant 

species noted include curly dock, Canada bluegrass, smooth 

bromegrass, and Canada thistle. 

Disturbed 

These plant associations reflect surface disturbance due to human 

activities on the site. These areas include roadsides, pad sites, 

parking lot perimeters, construction sites, and storage areas. Some 

of these areas have been revegetated and now include a combination of species from surrounding natural plant communities, 

reclamation species, and adventive (non-native) or ruderal (native 

or adventive, disturbance colonizer) species. Dominant species 

noted include smooth bromegrass and cheatgrass. 

Ornamental Trees/Shrubs 

Disturbed areas around buildings have been planted with a 

combination of native and ornamental trees and shrubs. The trees 

include multiple species of junipers (Sabina spp.) and pines (Pinus 

spp.) interspersed with ornamental deciduous trees. Shrubs in 

these areas are mainly chokecherry (Padus virginiana) and rose 

(Rosa spp.) bushes.

The following are lists of common and scientific names of wildlife 

species observed at STM and the NWTC. The species for the NWTC 

were identified during surveys completed in 2011. The species 

listed for STM were observed by staff and/or observed in surveys 

completed in 1987, 2005, and 2011.

WILDLIFE SPECIES AT THE STM

SPECIES COMMON NAME SCIENTIFIC NAME Seen in 1987 Survey Seen in 2005 Survey Seen in 2011 Survey Observed at 

other times

BIRDS

American crow Corvus brachyrhynchos X X

American goldfinch Carduelis tristis X

American kestrel Falco sparverius X X X

American pipit Anthus rubescens X

American redstart Setophaga ruticilla X

American robin Turdus migratorius X X X

American tree sparrow Spizella arborea X X

American white pelican Pelecanus erythrorhynchos X

Bald eagle Haleatus leucocephalus X

Barn swallow Hirundo rustica X

Black-billed magpie Pica hudsonia X X X

Black-capped chickadee Poecile atricapilla X

Black-crowned night heron Nycticorax nycticorax X

Appendix B: Wildlife Species Observed

at STM and the NWTC
ENVIRONMENTAL PERFORMANCE REPORT 2011 81

WILDLIFE SPECIES AT THE STM

SPECIES COMMON NAME SCIENTIFIC NAME Seen in 1987 Survey Seen in 2005 Survey Seen in 2011 Survey Observed at other 

times

Black-headed grosbeak Pheucticus melanocephalus X

Blue-gray gnatcatcher Polioptila caerulea X

Blue jay Cyanocitta cristata X X

Brewer's blackbird Euphagus cyanocephalus X X

Brewer’s sparrow Spizella breweri X

Broad-tailed 

hummingbird

Selasphorus platycercus X

Broad-winged hawk Buteo platypterus X

Brown-headed cowbird Molothrus ater X X X

Bullock's oriole Icterus bullockii X X

Bushtit Psaltriparus minimus X

California gull Larus californicus X

Canada goose Branta canadensis X X

Cedar waxwing Bombycilla cedrorum X

Cassin’s kingbird Tyrannus vociferans X

Chestnut-collared 

longspur

Calcarius ornatus X

Chipping sparrow Spizella passerina X

Cliff swallow Petrochelidon pyrrhonota X

Common grackle Quiscalus quiscula X

Common nighthawk Chordeiles minor X X X

Common raven Corvus corax X X

Common snipe Gallinago delicata X
82 ENVIRONMENTAL PERFORMANCE REPORT 2011

WILDLIFE SPECIES AT THE STM

SPECIES COMMON NAME SCIENTIFIC NAME Seen in 1987 Survey Seen in 2005 Survey Seen in 2011 Survey Observed at other 

times

Cooper's hawk Accipiter cooperii X X

Dark-eyed junco Junco hyemalis X X

Double-crested 

cormorant

Phalacrocorax auritus X

Downy woodpecker Picoides pubescens

Eastern kingbird Tyrannus tyrannus X

Eurasian collared dove Streptopelia decaocto X

European starling Sturnus vulgaris X X X

Golden eagle Aquila chrysaetos X

Grasshopper sparrow Ammodramus savannarum X

Great blue heron Ardea herodias X X

Green-tailed towhee Pipilo chlorurus X

Hepatic tanager Piranga flava X

Hermit thrush Catharus guttatus X

Horned lark Eremophila alpestris X X

House finch Carpodacus mexicanus X X

House sparrow Passer domesticus X X

House wren Troglodytes aedon X

Killdeer Charadrius vociferous X X X

Lark bunting Calamospiza melanocorys X X

Lark sparrow Chondestes grammacus X

Lazuli bunting Passerina amoena X

Lesser goldfinch Carduelis psaltria X
ENVIRONMENTAL PERFORMANCE REPORT 2011 83

WILDLIFE SPECIES AT THE STM

SPECIES COMMON NAME SCIENTIFIC NAME Seen in 1987 Survey Seen in 2005 Survey Seen in 2011 Survey Observed at other 

times

Loggerhead shrike Lanius ludovicianus X

MacGillivray's warbler Oporornis tolmiei X

Mallard Anas platyrhynchos X

Mountain bluebird Sialia currucoides X X

Mountain chickadee Poecile gambeli X

Mourning dove Zenaida macroura X X

Northern flicker Colaptes auratus X X

Northern goshawk Accipiter gentilis X

Northern harrier Circus cyaneus X

Osprey Pandion haliaetus X

Peregrine falcon Falco mexicanus X

Pine siskin Carduelis pinus X

Prairie falcon Falco mexicanus X

Red-breasted nuthatch Sitta canadensis X

Red-tailed hawk Buteo jamaicensis X X

Red-winged blackbird Agelaius phoeniceus X

Rock dove Columba livia X

Rock wren Salpinctes obsoletus X

Ruby-crowned kinglet Regulus calendula X

Sage thrasher Oreoscoptes montanus X

Say's phoebe Sayornis saya X

Sharp-shinned hawk Accipiter striatus X
84 ENVIRONMENTAL PERFORMANCE REPORT 2011

WILDLIFE SPECIES AT THE STM

SPECIES COMMON NAME SCIENTIFIC NAME Seen in 1987 Survey Seen in 2005 Survey Seen in 2011 Survey Observed at other 

times

Spotted towhee Pipilo maculates X

Swainson's hawk Buteo swainsoni X

Tree swallow Tachycineta bicolor X X

Turkey vulture Cathartes aura X

Vesper sparrow Pooecetes gramineus X

Virginia’s warbler Oreothlypis virginiae

Violet-green swallow Tachycineta thalassina X

Western kingbird Tyrannus verticalis X X

Western meadowlark Sturnella neglecta X X

Western scrub-jay Aphelocoma californica X

White-crowned sparrow Zonotrichia leucophrys X

White-faced ibis Plegadis chihi X

White-throated swift Aeronautes saxatalis X

Yellow-breasted chat Icteria virens X

Yellow-rumped warbler Dendroica coronata X

MAMMALS

Black-tailed jackrabbit Lepus californicus X X

Bushy-tailed woodrat Neotoma cinerea X

Coyote Canis latrans X X X

Deer mouse Peromyscus maniculatus X X

Fox squirrel Sciurus niger X

Long-tailed weasel Mustela frenata X 
ENVIRONMENTAL PERFORMANCE REPORT 2011 85

WILDLIFE SPECIES AT THE STM

SPECIES COMMON NAME SCIENTIFIC NAME Seen in 1987 Survey Seen in 2005 Survey Seen in 2011 Survey Observed at other 

times

Mexican woodrat Neotoma mexicana X X

Mountain cottontail Sylvilagus nuttalli X X X

Mule deer Odocoileus hemionus X X X

Prairie vole Microtus ochrogaster X X

Raccoon Procyon lotor X X X

Red fox Vulpes vulpes X X

Striped skunk Mephitis X

Western harvest mouse Reithrodontomys megalotis X X X

Western spotted skunk Spilogale gracilis X

White-tailed jackrabbit Lepus townsendii X

Yellow-bellied marmot Marmota flaviventris X

REPTILES AND AMPHIBIANS

Bull snake Pituophis catenifer X

Plains garter snake Thamnophis radix X X

Prairie lizard Sceloporus undulatus X

Racer Coluber constrictor X

Six-lined racerunner Cnemidophorus sexlineatus X

Tiger salamander Ambystoma tigrinum X X

Western rattlesnake Crotalus viridus X X X

Woodhouse’s toad Bufo woodhousii X

Note: No terrestrial arthropod genera of specific concern were detected during surveys in 2010.
86 ENVIRONMENTAL PERFORMANCE REPORT 2011

WILDLIFE SPECIES AT THE NWTC

SPECIES COMMON NAME SCIENTIFIC NAME

BIRDS

American crow Corvus brachyrhynchos

American goldfinch Spinus tristis

American kestrel Falco sparverius

American pipit Anthus rubescens

American robin Turdus migratorius

American tree sparrow Spizella arborea

Bald eagle Haliaeetus leucocephalus

Barn swallow Hirundo rustica

Black-billed magpie Pica hudsonia

Black-capped chickadee Poecile atricapillus

Blue jay Cyanocitta cristata

Brewer's blackbird Euphagus cyanocephalus

Brewer's sparrow Spizella breweri

Broad-tailed hummingbird Selasphorus platycercus

Brown-headed cowbird Molothrus ater

Bullock's oriole Icterus bullockii

Canada goose Branta canadensis

Cedar waxwing Bombycilla cedrorum

Chipping sparrow Spizella passerina

Common grackle Quiscalus quiscula

Common raven Corvus corax

WILDLIFE SPECIES AT THE NWTC

SPECIES COMMON NAME SCIENTIFIC NAME

BIRDS

Common snipe Gallinago delicata

Dark-eyed junco Junco hyemalis

Downy woodpecker Picoides pubescens

Eurasian collared-dove Streptopelia decaocto

European starling Sturnus vulgaris

Ferruginous hawk Buteo regalis

Franklin's gull Larus pipixcan

Golden eagle Aquila chrysaetos

Grasshopper sparrow Ammodramus savannarum

Gray catbird Dumetella carolinensis

Great blue heron Ardea herodias

Great horned owl Bubo virginianus

Hairy woodpecker Picoides villosus

Horned lark Eremophila alpestris

House finch Carpodacus mexicanus

Killdeer Charadrius vociferus

Lark bunting Calamospiza melanocorys

Loggerhead shrike Lanius ludovicianus

Long-billed curlew Numenius americanus

Mallard Anas platyrhynchos

Mountain bluebird Sialia currucoides
ENVIRONMENTAL PERFORMANCE REPORT 2011 87

WILDLIFE SPECIES AT THE NWTC

SPECIES COMMON NAME SCIENTIFIC NAME

BIRDS

Mountain chickadee Poecile gambeli

Mourning dove Zenaida macroura

Northern flicker Colaptes auratus

Northern harrier Circus cyaneus

Red-headed woodpecker Melanerpes erythrocephalus

Red-tailed hawk Buteo jamaicensis

Red-winged blackbird Agelaius phoeniceus

Rough-legged hawk Buteo lagopus

Ruby-crowned kinglet Regulus calendula

Sandhill crane Grus canadensis

Savannah sparrow Passerculus sandwichensis

Say's phoebe Sayornis saya

Song sparrrow Melospiza melodia

Spotted towhee Pipilo maculatus

Swainson's hawk Buteo swainsoni

Tree swallow Tachycineta bicolor

Turkey vulture Cathartes aura

Vesper sparrow Pooecetes gramineus

Western kingbird Tyrannus verticalis

Western meadowlark Sturnella neglecta

WILDLIFE SPECIES AT THE NWTC

SPECIES COMMON NAME SCIENTIFIC NAME

MAMMALS

American elk Cervus canadensis

Big brown bat Eptesicus fuscus

Coyote Canis latrans

Deer mouse Peromyscus maniculatus

Desert cottontail Sylvilagus audubonii

Eastern red bat Lasiurus borealis

Fringed myotis Myotis thysanodes

Hoary bat Lasiurus cinereus

Masked shrew Sorex cinereus

Meadow vole Microtus pennsylvanicus

Mexican woodrat Neotoma mexicana

Mule deer Odocoileus hemionus

Myotis bats Myotis sp.

Prairie vole Microtus ochrogaster

Silver-haired bat Lasionycteris noctivagans

Thirteen-lined ground squirrel Spermophilus tridecemlineatus

Western harvest mouse Reithrodontomys megalotis
88 ENVIRONMENTAL PERFORMANCE REPORT 2011

WILDLIFE SPECIES AT THE NWTC

SPECIES COMMON NAME SCIENTIFIC NAME

REPTILES AND AMPHIBIANS

Boreal chorus frog Pseudacris maculata

Bull snake Pituophis catenifer

Woodhouse’s toad Bufo woodhousii

TERRESTRIAL ARTHROPODS

Aphrodite fritillary Speyeria aphrodite

Cabbage white Pieris rapae

Checkered white Pontia protodice

Common wood nymph Cercyonis pegala

Dainty sulphur Nathalis iole

Gray hairstreak Strymon melinus

Orange sulphur Colias eurytheme

Western white Pontia occidentalis
ENVIRONMENTAL PERFORMANCE REPORT 2011 89
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