NATIONAL RENEWABLE ENERGY LABORATORY 

ENVIRONMENTAL PERFORMANCE REPORT for 2003 

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

Prepared by: 

Environment, Safety & Security Office 

National Renewable Energy Laboratory 

NREL is a national laboratory of the 

U.S. Department of Energy and is 

Operated by Midwest Research Institute and Battelle 

September 2004 
NREL Environmental Performance Report- 2003 

 

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TABLE OF CONTENTS 

1 INTRODUCTION..........................................................................................................................................6

PURPOSE...............................................................................................................................................................6

BACKGROUND ......................................................................................................................................................6

SITE AND FACILITY DESCRIPTION.........................................................................................................................8

SITE ENVIRONMENTAL CONDITIONS/FEATURES .................................................................................................13

CLIMATE.............................................................................................................................................................13

1.1 South Table Mountain Site .................................................................................................................13

1.2 National Wind Technology Center.....................................................................................................15

1.3 Denver West Office Park....................................................................................................................17

1.4 Joyce Street Facility...........................................................................................................................17

1.5 Renewable Fuels and Lubricants Research Laboratory ....................................................................17

2 COMPLIANCE SUMMARY......................................................................................................................21

2.1 Laws and Regulations........................................................................................................................21

2.2 Executive Orders................................................................................................................................23

2.3 Permit Summary.................................................................................................................................24

3 ENVIRONMENTAL OCCURRENCES....................................................................................................25

4 ENVIRONMENTAL MANAGEMENT SYSTEM...................................................................................26

4.1 Description.........................................................................................................................................26

4.2 Performance Indicators and Progress...............................................................................................27

4.3 Assessment and Improvement ............................................................................................................28

4.4 Sustainability and the Environmental Management System ..............................................................30

5 ENVIRONMENTAL PROGRAMS...........................................................................................................31

5.1 Air Quality Protection........................................................................................................................31

5.1.1 Program Management ................................................................................................................31

5.1.2 Permitting...................................................................................................................................32

5.1.3 2003 Activities...........................................................................................................................33

5.2 Drinking Water ..................................................................................................................................33

5.2.1 Program Management ................................................................................................................33

5.2.2 Permitting...................................................................................................................................34

5.2.3 2003 Activities...........................................................................................................................34

5.3 Ground Water Protection...................................................................................................................35

5.3.1 Program Management ................................................................................................................35

5.3.2 Permitting...................................................................................................................................37

5.3.3 2003 Activities...........................................................................................................................37

5.4 Wastewater Discharge .......................................................................................................................37

5.4.1 Program Management ................................................................................................................37

5.4.2 Permitting...................................................................................................................................38

5.4.3 2003 Activities...........................................................................................................................38

5.5 Surface Water Protection (Storm Water)...........................................................................................38

5.5.1 Program Management ................................................................................................................38

5.5.2 Permitting...................................................................................................................................39

5.5.3 2003 Activities...........................................................................................................................39

5.6 Waste Management............................................................................................................................40

5.6.1 Program Management ................................................................................................................40

5.6.2 Permitting...................................................................................................................................40

5.6.3 2003 Activities...........................................................................................................................40

5.7 Storage Tanks (Underground and Above Ground)............................................................................41

5.7.1 Program Management ................................................................................................................41

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5.7.2 Permitting...................................................................................................................................42

5.7.3 2003 Activities...........................................................................................................................42

5.8 Hazardous Materials Management....................................................................................................42

5.8.1 Program Management ................................................................................................................42

5.8.2 Permitting...................................................................................................................................44

5.8.3 2003 Activities...........................................................................................................................44

5.9 Pollution Prevention & Sustainability ...............................................................................................45

5.9.1 Waste Minimization, Recycling, and Green Purchasing............................................................45

5.9.2 Vehicles......................................................................................................................................47

5.9.3 Energy........................................................................................................................................47

5.9.4 Renewable Energy .....................................................................................................................49

5.9.5 Water Conservation....................................................................................................................50

5.9.6 Sustainable Building Design......................................................................................................51

5.9.7 Technical Assistance and Outreach............................................................................................51

5.10 Vegetation ..........................................................................................................................................52

5.10.1 Program Management ................................................................................................................52

5.10.2 Permitting...................................................................................................................................54

5.10.3 2003 Activities...........................................................................................................................54

5.11 Wildlife...............................................................................................................................................55

5.11.1 Program Management ................................................................................................................55

5.11.2 Permitting...................................................................................................................................57

5.11.3 2003 Activities...........................................................................................................................57

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

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

5.12.2 Permitting...................................................................................................................................59

5.12.3 2003 Activities...........................................................................................................................59

5.13 Wetlands/Floodplains ........................................................................................................................59

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

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

5.14.2 Permitting...................................................................................................................................61

5.14.3 2003 Activities...........................................................................................................................61

5.15 National Environmental Policy Act (NEPA)......................................................................................62

5.15.1 Program Management ................................................................................................................62

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

5.15.3 2003 Activities...........................................................................................................................62

5.16 Radiological Program........................................................................................................................63

5.16.1 Program Management ................................................................................................................63

5.16.2 Permitting...................................................................................................................................64

5.16.3 2003 Activities...........................................................................................................................64

6 CONSERVATION EASEMENT LANDS .................................................................................................66

7 REFERENCES.............................................................................................................................................67

8 APPENDICES..............................................................................................................................................69

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LIST OF FIGURES 

Figure 1.1 – Regional Map ................................................................................................. 9 

Figure 1.2 – ReFUEL Facility Location Map ................................................................... 10 

Figure 1.3 – STM Site Detail............................................................................................ 11 

Figure 1.4 – NWTC Site Detail ........................................................................................ 12 

Figure 1.5 - South Table Mountain Site – West end of the site........................................ 18 

Figure 1.6 - South Table Mountain Site – West view....................................................... 18 

Figure 1.7 - South Table Mountain Site – NW and mesa top view .................................. 19 

Figure 1.8 – South Table Mountain Site – Denver West Office Park............................... 19 

Figure 1.9 – NWTC Site – NW View............................................................................... 20 

Figure 1.10 – NWTC Site – NW View with research facilities........................................ 20 

 

LIST OF TABLES 

Table 5.1 – Energy Consumption .................................................................................. 47 

Table 5.2 – Water Consumption ................................................................................... 51 

Table 5.3 – Common Wildlife Found at the South Table Mountain Site ......................... 55 

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1 INTRODUCTION 

The National Renewable Energy Laboratory (NREL) is a U.S. Department of Energy (DOE) 

national laboratory, and conducts research primarily for DOE’s Office of Energy Efficiency 

and Renewable Energy (EERE). The Midwest Research Institute and Battelle operate NREL 

under the oversight of the DOE Golden Field Office (GO). 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 wastederived fuels and chemicals, energy efficiency in buildings, geothermal energy, advanced 

vehicle design, and hydrogen infrastructure and fuel cells. 

Purpose

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

activities for 2003. It is organized according to the different environmental media 

(e.g. air, waste, ground water, etc.), and includes a brief summary of how the program 

is managed in that area, any permitting or notification efforts that have been

completed during the reporting period or are ongoing, and activities that have 

occurred during the reporting period in that environmental area. A description of the 

environmental condition and features of NREL’s sites is also included to provide a 

basis for the program overview. 

This report is generally organized to present many of the elements of the Global 

Reporting Initiative (GRI) Sustainability Reporting Guidelines. It also incorporates 

DOE guidelines for the 2003 Annual Site Environmental Report, as required by DOE 

Orders 231.1 and 5400.5. 

Background

NREL’s mission: 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. 

Photovoltaics: Photovoltaics is the direct conversion of sunlight to electricity using 

solid-state materials. The National Center for Photovoltaics develops and deploys 

photovoltaic (PV) technology for the generation of electric power. 

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

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

generation and facilitates its deployment throughout the world 

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Bioenergy: NREL currently has major programs in both biomass-derived fuels 

(biofuels) and biomass-derived electricity (biopower), and projects in biomassderived chemicals and materials. 

Renewable Thermal Technologies: These technologies generate power from heat or 

utilize heat from renewable resources. They include concentrating solar power, solar 

water heating, and geothermal heat and power. 

Distributed Power: Distributed power is modular electric generation or storage 

located near the point of use. NREL participates in the development of technologies, 

market structures, and policies that affect the incorporation of renewables and energy 

efficiency technologies in distributed power systems, maximizing the deployment of 

renewable energy and energy efficiency products. As a part of this initiative, NREL 

is involved in the development, design, and deployment facilitation of renewable and 

renewable/fossil hybrid distributed power systems in grid-connected applications. 

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, and environmentally acceptable building equipment 

and envelope systems. 

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

as well as in advanced storage and sensor development, and codes and standards 

development. 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. 

Transportation: NREL works with industry to develop advanced vehicles and 

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

DOE transportation initiatives. NREL also works with energy companies and 

manufacturers of vehicles and engines to develop advanced motor vehicle fuels for 

improved energy and environmental performance. A systems approach is used to 

develop optimized engine management, fuel, and emission control technologies. 

Basic Science: Fundamental research is conducted in the sciences that underlie 

NREL’s renewable energy and energy efficient technologies. 

Computational Sciences: This area includes basic and applied research using highperformance computing and applied mathematics. 

Electricity Technologies: These technologies include renewable energy, hydrogen, 

and superconductivity technologies, plus utility resources. 

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

and initiatives. 

NREL Environmental Performance Report- 2003 

 

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Measurements and Testing: NREL labs and facilities allow state-of-the-art testing on 

photovoltaic cells, building technologies, and wind turbines. 

Renewable Energy Resources: Researchers find resource information for solar, wind, 

biomass, and geothermal energy applications. 

Site and Facility Description

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

the city of Denver. The five facilities are the Denver West Office Park (DWOP), the 

South Table Mountain site (STM), the Joyce Street Facility (JSF), the National Wind 

Technology Center (NWTC), and the Renewable Fuels and Lubricants Research 

Laboratory (ReFUEL). The DWOP and STM sites are approximately 2 miles 

(3.2 km) east of Golden and 12 miles (19.3 km) west of central Denver. The NWTC 

is located near the intersection of Highways 93 and 128, between Boulder and 

Golden, and is approximately 15 miles (24.2 km) north of the STM site. It is adjacent 

to the DOE Rocky Flats Environmental Technology Site. The JSF is located at 6800 

Joyce Street, approximately 5.5 miles (8.9 km) north of the DWOP and STM sites. 

The ReFUEL Facility is located with the Regional Transportation District (RTD) 

District Shops and Operation Center (DSOC) located at 1900 31st Street, Denver, 

about 12 miles east of the STM and DWOP sites. Figure 1.1 illustrates the locations 

of the STM, DWOP, NWTC, and JSF sites on a regional map. The location of the 

ReFUEL Facility is shown on Figure 1.2. Figure 1.3 provides a more detailed map of 

the STM site, and Figure 1.4 provides detail for the NWTC site. 

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

conducted. These two sites will be addressed separately in the discussion of 

environmental features. The DWOP is leased space used primarily for administrative 

functions and limited research activities. The JSF is also a leased space that is 

currently used for storage. The ReFUEL Facility is a leased facility that consists of a 

small shop complex housed within the RTD/DSOC facility. NREL performs enginetesting activities pertaining to fuels and lubricants at the site. 

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Figure 1.1 – Regional Map 

National Wind 

Technology Center 

Joyce Street 

Facility

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NREL En

 

vironmental Performance Report- 2003 

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I-70 

I-25 

RTD and

ReFUEL 

LOCATION 

Figure 1.2 – ReFUEL Facility Location Map 
Figure 1.3 – STM Site Map 

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Figure 1.4 – NWTC Site Map

NREL En
Site Environmental Conditions/Features

Photos for each site documenting the site features and development, as they existed 

during 2003, are included at the end of this section. Figures 1.5, 1.6, 1.7 and 1.8 

illustrate the South Table Mountain and Denver West Office Park sites, and Figures 

1.9 and 1.10 illustrate the National Wind Technology Center site. The views on the 

STM site also illustrate the Conservation Easement property and the Camp George 

West property acquired in 1999. 

Climate

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

typified by limited precipitation, low relative humidity, abundant sunshine, and large 

daily and seasonal temperature variations. 

The area experiences moderate precipitation, with average annual rainfall less than 

50 cm (20 in). 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 to 10 in.). 

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. 

1.1 South Table Mountain Site 

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 South Table Mountain. South Table 

Mountain is composed of sedimentary rocks below a basalt lava cap, which is quite 

resistant to erosion. The South Table Mountain feature is a mesa that stands about 

150 meters above the adjacent lowlands. The mesa was formed as weak sedimentary 

rocks surrounding the lava were eroded away, leaving the lava-capped mesa in relief. 

Below the lava caprock, the sedimentary rocks are part of the Denver Formation that 

consists of layers and lenses of claystone, sandstone, and conglomerate. Sedimentary 

rocks of the Arapahoe Formation underlie the Denver Formation. 

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Both the Arapahoe and Denver Formations are considered to be aquifers in portions 

of the Denver Basin. The Denver Formation underlies the areas on which most 

NREL construction has taken place. Groundwater on the STM site occurs primarily 

in the weathered and fractured silts and sands of the Denver Formation. There may 

also be some groundwater in the form of perched aquifers below the basaltic lava cap 

on the South Table Mountain and within the materials above the Denver Formation, 

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

southeasterly direction. 

The soil covering the top of South Table Mountain is Lavina Loam. A loam is 

composed of a mixture of clay, sand, silt, and organic matter. The loam on the mesa 

top is a shallow, well-drained clayey soil. Soil on the upper side slopes of South 

Table Mountain is also a loam consisting of extremely stony soils with significant 

amounts of clay. Much of the remainder of the site, including the area designated for 

major development, has a deep, 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 the mesa top and across the 

lower portions of the site, is in the southerly direction toward Lena Gulch (a tributary 

of Clear Creek). Surface water from two drainage ways on the easternmost portion of 

the site ultimately flows into Lena Gulch. 

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

from extended periods of precipitation, usually during the late winter and early 

spring, is found in the drainage channels with seasonal springs evident along some of 

the mesa slopes. There is one seep on the mesa top that is often active throughout 

much of the year, but the water infiltrates and evaporates quickly during the dry 

season. 

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, comprising over 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. Recent field surveys 

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

communities identified on the STM site are a very minor component of the total 

vegetation cover, accounting for less than 1% of the vegetation over an area of less 

than 0.3 ha (0.75 ac). Riparian shrub communities also occur adjacent to the 

emergent wetlands. 

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Wildlife

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

surveys were done in 1999 over the Conservation easement property. A new survey 

to update the data began in 2004 (see section 5.11 for more detail). Mammals seen 

using the site during the surveys include mule deer, coyote, gray fox, red fox, 

raccoon, long tailed weasel, striped skunk, spotted skunk, badger, bobcat, mountain 

lion, rabbits, and yellow-bellied marmots. Seventeen species of birds have been 

observed on the STM site, along with two species of raptors: kestrels and two 

nesting pairs of red-tailed hawks. NREL personnel have reported numerous sightings 

of snakes as well as a golden eagle. A variety of amphibian species are expected to 

inhabit the area. 

Land Use

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

recreation and light-commercial activity. Portions of the community of Pleasant 

View are located immediately to the south and west of the western portions of the 

STM site. Pleasant View is currently planning a recreational park immediately south 

of the STM site. Offices, shops, and a tree nursery owned by the Colorado State 

Forest Service are located at the far western edge. Undeveloped state land and a 

Colorado State Highway Patrol pursuit driver-training track are located along the 

northwestern boundary of the STM site on top of the mesa. Jefferson County open 

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

DWOP and apartment homes lie to the east. 

More than half of the STM site (177 acres) has been set aside in a Conservation 

Easement. No development is allowed on that land, with the exception of some

existing utility easements and recreational trails to be established by Jefferson County 

Open Space. Trail development is planned for implementation in phases by the 

County, and was begun in 2004. (See Section 6.0 for more detail.) 

1.2 National Wind Technology Center 

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 Formation, Fox Hills Sandstone, and Pierre Shale. These rock formations 

consist primarily of claystones with some siltstones. Unconfined groundwater flow 

occurs in the RFA toward the east/southeast, and small perched zones are common. 

Groundwater occurs as confined aquifers in the deeper bedrock formations (EG&G 

Rocky Flats, Inc., 1992). 

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 a 

subsoil dominated by clay (USDA, 1995). 

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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 

Mountains (Plantae Consulting Services, 2000). This location results in a flora that 

contains elements from both mountain and prairie ecosystems and associations that 

represent residual tall grass prairie, short-grass plains, ponderosa pine woodland, and 

foothill ravine flora (Plantae Consulting Service, 2000). 

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

vascular plant species and defined five major habitat types on the NWTC site 

including the following: 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. 

Wildlife

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

native vegetation. A wildlife survey was conducted in 1992 for the entire Rocky 

Flats Plant and buffer zone area, including the NWTC site. Signs or tracks of bears 

and mountain lions were identified. Other mammals known to feed at the site are 

mule deer, coyotes, desert cottontail rabbits, 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 

(birds of prey) surveys were conducted at the NWTC in 1994 and 1995, and 

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

also conducted in 2001 to 2002; it is described further in Section 5.10. 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 Environmental Technology Site borders the NWTC to 

the southeast, and a sand and gravel mining operation is located along the southern 

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

along the western site boundary. 

A piece of land of about 25 acres, located at the southeast corner of the NWTC, was

recently designated for inclusion within the NWTC by the National Defense 

Authorization Act (see Figure 1.3). Two test sites and unimproved roads are located 

on this land. The transfer of this land parcel from DOE Rocky Flats was completed 

in 2003.

1.3 Denver West Office Park 

The 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 located approximately in the geographic center of the development. The 

DWOP is bordered on the south by commercial areas (West Colfax strip), on the west 

by the Pleasant View residential area, Camp George West facility, and the STM site. 

DWOP is within the City of Lakewood. 

1.4 Joyce Street Facility 

The JSF is located in a commercial area surrounded by agricultural land, residential 

neighborhoods, and small businesses. It is currently used by NREL as warehouse 

space only. No research or support activities are currently conducted at the facility, 

and there are no staff offices at JSF. 

1.5 Renewable Fuels and Lubricants Research Laboratory 

The ReFUEL facility 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 will also be used to evaluate and 

develop heavy hybrid electric vehicles. 

 

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

RTD/DSOC facility occupies approximately 22 acres of land, serves as the primary 

maintenance facility for RTD’s bus and light rail train systems. The area around the 

RTD/DSOC facility consists of commercial and light industrial development. 

The site lies on relatively flat terrain with a slight gradient to the northwest. The 

general area is highly developed with concentrated industrial and commercial 

activities. Very little natural vegetated habitat exists onsite or in the immediate 

vicinity. There are trees and shrubs lining the South Platte River adjacent to the site’s 

south, east and northeast. 

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Figure 1.5 – STM Site – Aerial view looking west, showing facilities at the western end of the site. 

Figure 1.6 – STM Site – View looking west, showing Camp George West acreage 

acquired in 1999,a portion of the Pleasant View neighborhood, and the Conservation Easement lands. 

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Figure 1.7 – STM Site – View looking northwest at the historic amphitheater and the mesa top facilities. The 

Colorado State Highway Patrol pursuit driver-training facility is located on the right side of the photo.

Figure 1.8 – STM Site – View looking northwest, over Interstate 70 at the NREL/DOE buildings in the Denver 

West Office Park. 

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Figure 1.9 – NWTC – View looking northwest

Figure 1.10 – NWTC – View to the northwest with research facilities shown. 

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2 COMPLIANCE SUMMARY 

2.1 Laws and Regulations 

Air Quality Protection 

The Colorado Department of Public Health and Environment (CDPHE) administers 

Clean Air Act implementing regulations for all point sources (facilities or other types 

of operations) in Colorado, under authority delegated by the U.S. Environmental 

Protection Agency (EPA). NREL holds two site-wide permits for particulate air 

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

project. Detailed information about NREL’s air quality protection program is 

provided in Section 5.1. 

National Emissions Standards for Hazardous Air Pollutants (NESHAPs) requirements 

specific to radiological emissions from DOE facilities are regulated by the U.S. EPA. 

NREL’s potential emissions are calculated annually using a computer model, and are 

well below the threshold level. Details are provided in section 5.15. 

Drinking Water Quality Protection 

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

CDPHE, under authority delegated by EPA. NREL purchases water that is delivered 

by truck to the NWTC, and holds a public water supply identification number to 

provide that water to NWTC site occupants. Detailed information about compliance 

efforts is provided in Section 5.2. 

Ground Water Quality Protection 

Colorado ground water standards are established by the Colorado Department of 

Natural Resources. That department also issues permits for ground water wells. 

NREL has no known groundwater contamination and has obtained drilling permits for 

all of its monitoring wells. Detailed information about NREL’s groundwater program

is provided in Section 5.3. 

Waste Water 

Waste water from the majority of the STM Site and the Denver West Office Park 

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

and from there flows to the treatment plant at Metro Wastewater Reclamation District 

(Metro). Federal and State Clean Water Act implementing wastewater discharge 

regulations are administered at NREL’s STM and DWOP via Pleasant View and 

Metro requirements. NREL’s wastewater discharge policy is in conformance with 

Metro’s discharge requirements. Wastewater at the NWTC site flows into two 

individual sewage disposal systems (septic and leach fields). These are regulated by 

CDPHE; inspection and permit issuance have been delegated by CDPHE to the 

Jefferson County Department of Health and Environment. There is also one 

individual sewage disposal system at the Solar Radiation Research Laboratory on the 

mesa top at the STM Site. As is the case with NWTC septic systems, the mesa top 

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system regulations are administered by Jefferson County. Additional detail about 

NREL’s wastewater discharge program can be found in Section 5.4. 

Surface Water Quality Protection 

The authority for implementing storm water discharge regulations at federal sites in 

Colorado rests with EPA. NREL falls under the EPA Construction General Permit 

Program for the STM and NWTC sites for storm water discharge from construction 

areas. Permit coverage for individual NREL activities is obtained when permit 

thresholds are triggered based on factors such as acreage involved, slope, and soil 

characteristics. During 2003, no activities requiring permit coverage were conducted. 

Details of NREL’s surface water protection program are provided in Section 5.5. 

Waste Management

The Resource Conservation and Recovery Act (RCRA) established laws that apply to 

hazardous waste. In Colorado, CDPHE implements hazardous waste regulations 

under authority delegated by EPA. NREL holds five EPA generator ID numbers for 

each of its sites. (An additional ID number for the newly-leased ReFUEL Facility was 

issued by CDPHE in January 2004.) NREL’s waste management program is outlined 

in Section 5.6. Pollution Prevention efforts at NREL are described in Section 5.9. 

Storage Tanks

NREL has no underground storage tanks containing hazardous materials; NREL stores 

only water in underground tanks at the NWTC. Above ground storage tanks that are 

larger than 660-gallons are regulated in Colorado by the Colorado Department of 

Labor, Oil Inspection Section. NREL has two tanks larger than 660 gallons on the 

STM site that are registered with the Colorado Department of Labor. Details about 

NREL’s tank program are provided in Section 5.7. 

Threatened and Endangered Species/Species of Concern 

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

Endangered Species Act, Migratory Bird Treaty Act, and Golden and Bald Eagle 

Protection Act. The Endangered Species Act also protects threatened and endangered 

plant species. State laws also designate and protect rare or unique plants and animals. 

No threatened or endangered species or species of concern have been documented on 

NREL’s sites. Details of NREL’s wildlife and vegetation surveys are provided in 

Section 5.11. 

EPCRA Compliance and Prevention of Toxic Releases: 

Executive Order (E.O.) 13148 outlines requirements for SARA Title III, Emergency 

Reporting and Community Right-to-Know Act (EPCRA) compliance and Toxic 

Release Inventory reductions for government facilities. NREL maintains hazardous 

materials permits with West Metro Fire Rescue (West Metro) and provides chemical 

inventory information to West Metro for the STM site and Building 16 in the DWOP. 

NREL Environmental Performance Report- 2003 

 

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In 2003, NREL facilities had no release exceeding the reportable quantity (RQ) of any 

material reportable under EPCRA. NREL did have quantities of three chemicals on 

site that exceeded the EPCRA threshold planning quantity for each chemical, so 

MSDSs and Tier II reports were filed with the state and local emergency planning 

organizations and with the fire department. 

As a research and development laboratory, NREL does not manufacture or process 

any materials, and during 2003, the Laboratory did not otherwise use any materials on 

the SARA Section 313 list in quantities exceeding the 4526-kg (10,000 lb) threshold 

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

Section 5.8. 

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

programs, including an Emergency Response Team Program (8-4.1), for credible on 

site emergencies. Hazardous material releases are specifically called out as a credible 

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

practiced by internal response groups and with external emergency response agencies. 

Cultural Resources Protection 

Cultural resources are protected by various laws, including but not limited to, the 

National Historic Preservation Act and the Native American Graves Protection and 

Repatriation Act. NREL has two sites listed on the National Register of Historic 

Places on its STM Site. There are no known eligible sites at the NWTC. NREL’s 

Cultural Resources program is described in Section 5.13. 

2.2 Executive Orders 

Executive Order 13148 

In March 2000, E.O. 13148, Greening the Government Through Leadership in 

Environmental Management was issued, requiring that all Federal agencies ensure that 

environmental accountability is integrated into day-to-day decision making and longterm planning processes. In February 2001, DOE issued a notice (DOE N 450.4) 

outlining requirements for DOE contractors under Executive Order 13148. NREL’s 

compliance with these requirements is explained below. 

Specific requirements under E.O. 13148 require federal facilities to develop and 

implement environmental management systems, comply with environmental 

regulations, report as required under EPCRA, reduce the release and use of toxic 

chemicals, practice pollution prevention, reduce the use of ozone-depleting substances 

(ODSs) by maximizing the purchase and use of safe alternatives, and implementing 

sustainable landscaping practices to reduce adverse impacts on the environment. 

Details of NREL’s Environmental Management System (EMS) and information on the 

environmental programs that implement the EMS are provided in Section 4.0 and 5.0, 

respectively. Compliance with environmental regulations at NREL, including EPCRA 

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is described in Section 2.1, above. ODS and alternative use at NREL are outlined in 

Section 5.1, and sustainable landscaping is discussed in Section 5.10. 

Executive Order 11988, Floodplains Management: 

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

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

any floodplains, and no floodplains have been identified at the NWTC. As a Best 

Management Practice (BMP), however, all construction activities that may cross a 

drainage channel are designed to meet the 100-year flood control standards (designed 

to withstand the equivalent of a 100-year flood). 

Actions undertaken by NREL at subcontractor facilities are assessed for potential 

impacts on floodplains and wetlands at those sites through the use of an environmental 

checklist. 

Executive Order 11990, Wetlands Protection: 

Limited wetland areas totaling less than 0.3 ha (0.75 ac) occur on the STM site. These 

are narrow, linear wetlands supporting spikerush, baltic rush, sedges, bluegrass, 

hemlock, and field mint. These wetlands will be protected from adverse impacts as 

site development continues. 

Wetland areas at the NWTC are extremely limited in extent as well. These areas, 

along the site’s eastern boundary, total less than 0.4 ha (1 ac), and will also be 

protected from adverse impacts. 

2.3 Permit Summary 

A table is provided in Appendix A that summarizes NREL’s permits, registrations, 

and notifications. 

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3 ENVIRONMENTAL OCCURRENCES 

There were two incidents with environmental implications during 2003 at the STM 

site, and one at the NWTC. 

At the STM site on March 5, 2003, a small fire occurred in a hood in SERF laboratory 

W214 while researchers were heating a beaker of dimethylsulfoxide (DMSO). When 

the DMSO reached the appropriate temperature, the hot plate was inadvertently turned 

to its highest temperature setting instead of “off.” The DMSO boiled over, contacted 

the hot plate, and ignited. The ensuing fire was immediately extinguished. Damages 

were minor, the work area was cleaned up, and work resumed. An investigation was 

conducted into the causes of the incident. Corrective actions to prevent recurrence 

included changes to procedures for heating the solution, replacing the hot plate, and 

changes to associated equipment. 

At the NWTC on May 2, 2003, Approximately 16-18 gallons of hydraulic oil leaked 

from a damaged gauge stem onto the floor, apparently passed through cracks in the 

slab floor, and flowed into a hose trench in the Dynamometer Facility hydraulic room. 

Absorbent was deployed, and spilled oil was cleaned from the floor and collected from 

the hose trench. The trench was monitored until oil seepage ceased, with oil being 

continually cleaned as it seeped into the trench. The investigation revealed that the 

gauge stem was apparently damaged by a passerby or equipment. Corrective actions 

to prevent recurrence included eliminating the gauge that failed; procedures to use best 

practices for guarding, installing, and system monitoring on future installations of 

gauges or fittings; inspection of all hydraulic installations in NWTC buildings for 

improper or deficient hydraulic fitting installations and immediate corrective action; 

and outfitting all hydraulic reservoirs with shut-off valves that can be closed when the 

systems are not in use. 

At the STM site on July 31, 2003, two large propane cylinders were discovered inside 

a recycling dumpster. Valves had been removed, but one cylinder appeared to be 

releasing residual gas due to sunlight heating the cylinder. The cylinders were purged 

with nitrogen to be sure there was no fire or explosion hazard and the cylinders were 

inert. The cylinders were relocated to NREL’s Waste Handling Facility to arrange for 

proper disposal. The investigation could not determine how the cylinders got into the 

metal recycling bin, as it is accessible to all NREL workers. Signage was posted in 

the area of the roll-off to inform users what materials are and are not acceptable in the 

metal recycling bin. The information was communicated with staff who routinely use 

the roll-off, and general information on metal recycling guidelines has been added to 

the Sustainable NREL Recycling homepage. 

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4 ENVIRONMENTAL MANAGEMENT SYSTEM 

4.1 Description 

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

environmental policy: 

 NREL is committed to sound environmental management that serves as an 

example to others and supports the Laboratory’s mission to protect natural 

resources through research, development, and deployment of renewable energy 

and energy efficiency technologies. NREL is committed to: 

• Applying sustainability concepts to the design and operation of its campuses 

and facilities

• Protecting natural and cultural resources 

• Incorporating pollution prevention practices in research and support activities 

• Improving the effectiveness of NREL’s environmental management system 

(EMS) 

• Providing leadership in environmental excellence through consistently high 

performance and open, responsive communications 

• Complying with applicable federal, state, and local environmental 

requirements and exceeding those requirements, when feasible, by 

implementing environmental best management practices. 

The Environmental Management System (EMS) is in place to implement NREL’s 

environmental policy, and is comprised of a framework of policies and procedures that 

are integrated with NREL’s normal management processes, combined with the 

environmentally sound daily work practices of Environment, Safety & Security 

(ES&S) Office staff and staff throughout the Laboratory. Environmental protection 

must involve everyone at the Lab in order for it to be effective. All activities 

conducted at NREL must comply with federal and state laws and regulations, and 

DOE requirements. 

As a DOE-owned facility, NREL is required to implement its EMS as part of a 

Integrated Safety Management (ISM) System, according to DOE direction. The 

Environmental Management Policy (6-2) and 19 supporting Lab-level environmental 

programs that define the NREL EMS have been coordinated and linked with the ISM 

Policy (2-1), the ES&H Policy (6-1), the supporting ES&H Policies (6-3 through 6-6), 

and approximately 40 supporting Lab-level safety and health programs. The EMS is 

further integrated with ISM via task specific procedures that flow down from the 

policies and programs, such as Safe Operating Procedures (SOP). 

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Notable 2003-4 Activities

In the fall of 2003, NREL applied for participation in the EPA National Environmental 

Performance Track (NEPT) Program and the Colorado Environmental Leadership 

Program (CELP). NREL was accepted into both programs in early 2004.

An NREL Self-Assessment and DOE-GO Surveillance of NREL’s EMS was 

conducted in 2004. More detail is provided in Section 4.3 of this report. 

4.2 Performance Indicators and Progress 

2003 Environmental Objectives and Progress Toward Goals

Each fiscal year, NREL in collaboration with the DOE Golden Field Office (DOEGO) develop environmental objectives for the upcoming year as part of NREL’s OneYear Plan. For fiscal year 2003, the objectives were: 

• Complete a self-assessment of the NREL Waste Management Program. 

• Complete the STM Site-Wide Environmental Assessment 

• Coordinate Sustainable NREL with NREL’s EMS 

• Pursue an EMS recognition by EPA or other recognized external organization 

• Implement improvements identified through assessments and reviews.

The NREL Waste Management Program Self-Assessment/Surveillance was conducted 

in 2003. Additional information can be found in Section 4.3 below. 

The STM Site-wide EA was initiated in May 2002, and was completed in July 2003. 

It provided a comprehensive review of different development options for NREL’s 

STM Site, analyzing development opportunities by zone on the site. The EA was 

coordinated with the NREL General Development Planning process that resulted in 

the Final NREL General Development Vision in November 2003. 

Sustainable NREL and EMS staff worked together to compile pollution prevention 

data on waste generation, recycling, and green purchasing. NREL received a DOE 

Best-In-Class award for its pollution prevention efforts through Sustainable NREL. 

Sustainable NREL and the EMS were further coordinated in 2003 through the 

application process for acceptance into EPA’s NEPT Program and the State of 

Colorado CELP. NEPT and CELP provide recognition for NREL’s EMS, and the 

performance commitments made through these programs are being implemented at 

NREL via Sustainable NREL. The commitments made are to reduce overall energy 

usage, reduce water use, reduce greenhouse gas emissions, and reduce carbon 

monoxide air emissions. NREL was accepted into the program in early 2004. 

2004 Objectives

Environmental objectives developed by NREL in collaboration with DOE-GO for 

fiscal year 2004 are: 

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• Continue coordination of Sustainable NREL with NREL’s EMS 

• Develop scope statements and budget requirements for migratory bird, 

wildlife, and cultural resource surveys in support of planned development of 

the STM Site. 

• Continue the pursuit of EMS leadership recognition through the EPA NEPA, 

as initiated in FY03. 

• In conjunction with the EPA NEPT, simultaneously pursue EMS leadership 

recognition through the CDPHE Environmental Leadership Program. 

• Implement improvements identified through assessments and reviews. 

Progress toward the 2004 goals will be reported in the NREL 2004 Environmental 

Performance Report. 

4.3 Assessment and Improvement 

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

provide verification that the EMS continues to be an effective tool to: achieve and 

maintain compliance with regulatory and legal requirements, meet the established 

environmental goals of the Laboratory, and maintain management support for NREL’s 

environmental goals. Assessment and management review also provide for 

continuous improvement of the EMS. 

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

of the EMS at NREL: EMS assessments, periodic compliance assessments, and thirdparty audits. 

Assessments of NREL’s EMS are generally performed internally by a team of NREL 

staff periodically, but at least every three years. The team generally includes NREL 

Environment, Safety & Security staff and staff involved in the Sustainable NREL 

initiative. The scope of the assessments includes both the management of significant 

environmental aspects and policy implementation. The team evaluates the EMS based 

on an appropriate set of criteria, such as ISO 14000 standards, EPA National 

Environmental Performance Track standards, or other applicable environmental 

management standard. The assessment team selects the most appropriate set of 

criteria for each assessment. 

Periodic compliance assessments are conducted of individual environmental programs 

to verify that the program, as written, meets all applicable legislative and regulatory 

requirements and that the program is implemented as intended. Improvements are 

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

NREL has established an ES&H self-assessment program to conduct these compliance 

assessments. These are normally conducted in coordination with the DOE Golden 

Field Office (DOE-GO) ES&H Surveillance Program. A specific set of Lab-level 

environment, safety, and health programs are selected for assessment each year based 

on criteria established by the GO/NREL Operations Team, with the selected set 

including environmental programs that are part of the EMS. 

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In addition to regular compliance assessments of individual NREL environmental 

programs, NREL has management system auditing processes in place for regular 

reviews and updates of the set of policies, Lab-level programs, and task specific 

procedures, including EMS policies and programs. NREL reviews its ES&H policies 

as needed, but at least every 4 years, and makes revisions as necessary. All SOPs are 

reviewed on an annual basis and are revised as necessary to help ensure the required 

controls are appropriate for the hazards present. Environmental hazards and controls 

are specifically called out in each SOP. 

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

for specific components of NREL’s environmental programs or for the EMS as a 

whole. These assessments are conducted on an as-needed basis. In addition, 

regulatory agencies may periodically conduct assessments for compliance with 

environmental programs, at the discretion of the agency. 

2003 Assessment Activities

A self-assessment of NREL’s EMS was begun in mid-2004. A DOE Golden Field 

Office surveillance was conducted concurrently. The self-assessment was performed 

by a team of NREL ES&S staff and staff involved in the Sustainable NREL initiative. 

DOE-GO staff also participated in the assessment team data collection activities, 

including interviews. The scope of the assessment included both the management of 

significant environmental aspects and policy implementation. The team evaluated the 

EMS using international Global Environmental Management Initiative (GEMI) 

criteria, which are based on the ISO 14001 standard, and NEPT standard criteria. 

Self-assessment and Surveillance reports are now being finalized. Results will be

discussed in the 2004 Environmental Performance Report. 

In 2003, NREL participated in the CDPHE Hazardous Materials and Waste 

Management Division’s (HMWMD) Self-Audit Pilot Study. Concurrently with this 

activity, NREL completed a self-assessment of the waste management program and 

the DOE Golden Field Office conducted a surveillance of the program. 

 

The HMWMD intends to develop a compliance assistance program to advise and 

assist waste generators with the interpretation and application of the Division’s 

regulations. The self-audit pilot study would enable the Division to collect actual 

compliance/non-compliance activities and provide trending data with which to 

develop and implement the compliance assistance program, while focusing on those 

areas that cause the most confusion and non-compliance. Participation in the pilot 

study was voluntary, and potential candidates were randomly selected from a list of 

facilities that were scheduled to have an enforcement inspection during the next 

twelve months. No significant issues or items of non-compliance were identified 

during the audit, self-assessment, or surveillance.

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4.4 Sustainability and the Environmental Management System 

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

the world. Sustainability is defined as the simultaneous and balanced pursuit of 

economic viability, environmental stewardship and public responsibility. 

 

The Sustainable NREL Program was created to realize the vision of greater 

sustainability in NREL operations. It is an interdisciplinary initiative comprised of

staff from numerous NREL centers and offices with the goals of maximizing efficient 

use of resources; minimizing waste and pollution; and serving as a positive force in 

economic, environmental, and public responsibility. Elements of the environmental 

stewardship component of Sustainable NREL include: 

• Campus and Transportation 

• Water, Electricity, and Natural Gas 

• Reduce, Reuse, Recycle, Rebuy 

• Education and Communications 

• Environmental Management 

NREL is committed to, among other things, reducing energy use in its building 

operations; designing energy efficient and environmentally sensitive new buildings; 

cutting water consumption; decreasing greenhouse gas emissions; reducing the impact 

of local NREL travel on the environment; using less fossil-based fuel for local 

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

NWTC operations; and creating less waste by reducing, reusing and recycling 

materials for Laboratory operations. 

The environmental management component of Sustainable NREL is implemented 

through the EMS, with the EMS focus on protecting the natural and cultural resources 

on and around NREL sites and minimizing any potential impacts NREL’s activities 

have on the environment. There is also overlap between the EMS and some of the 

other components of Sustainable NREL. 

More detail is provided elsewhere in this report about the following sustainabilityrelated efforts at NREL: 

• Sustainable landscaping is described in Section 3.10, Vegetation Management. 

• Pollution Prevention activities are discussed in Section 3.9, Pollution 

Prevention. 

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5 ENVIRONMENTAL PROGRAMS 

The overarching objective of NREL’s Environmental Management System and its component 

programs is responsible stewardship of the environment, both on its DOE-owned sites and 

leased properties. NREL strives to protect the natural environment by minimizing or 

eliminating any adverse environmental impacts resulting from NREL activities. The 

Laboratory’s EMS is integrated with other NREL management systems and applies to all 

research and operations activities. The EMS includes written environmental protection policy 

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

management levels. 

NREL’s EMS includes components to address waste, air, water, natural resources, and land 

and soil issues, among others. Descriptions of the components of the EMS are provided in the 

following sections of this chapter. Sections are organized by resource. Each section is 

comprised of three areas of discussion: a summary of the environmental management of the 

resource, a discussion of any relevant permitting, and finally a summary of significant 

activities that have occurred throughout the year. 

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

These permits are discussed in the relevant sections below. 

5.1 Air Quality Protection 

5.1.1 Program Management

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

Environmental Permitting and Notification (6-2.1), Air Quality Protection (6-

2.5), Ozone-Depleting Substances Management (6-2.6), and Particulate 

Emissions Control for Construction (6-2.14). 

Criteria, Hazardous, and Non-Criteria Pollutants

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, ozone, and lead) 

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

compounds, metallic compounds, and corrosives)

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

corrosives, asbestos, radionuclides, and pesticides) 

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

There are notification and permitting thresholds for criteria, hazardous, and 

non-criteria pollutants. The primary potential sources of these pollutants at 

NREL include boilers, emergency generators, experimental laboratory hoods, 

NREL Environmental Performance Report- 2003 

 

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pilot scale research projects, and small pieces of equipment with gasoline or

diesel engines. NREL maintains air emission inventories to track potential air 

emissions and identify whether notification and permitting could be required 

for a particular facility or activity. Fugitive particulate emissions from

construction activities occurring on NREL’s sites are also a potential source. 

Ozone Depleting Substances

Facilities that service refrigeration equipment containing ozone-depleting 

substances (ODSs) are required to file an annual notification with the Colorado 

Department of Public Health and Environment (CDPHE). This equipment 

servicing must be conducted by EPA-certified technicians, and NREL has

certified technicians on staff that perform this type of service. 

Another requirement of the State of Colorado’s CFC program is that all 

refrigeration equipment larger than 100 hp that uses ODSs be registered with 

CDPHE. NREL has a total of three chillers that are registered with CDPHE, 

two chillers at its Solar Energy Research Facility (SERF) on the STM Site, and 

one at the DWOP. 

Halon-based fire suppression systems previously used at NREL were 

eliminated by 1999, with all supplies of Halon being transferred to other DOE 

facilities for “banking”. 

Street Sanding

CDPHE regulations require federal, state, and local government facilities to 

track wintertime street sanding, and to make efforts to minimize sand use. 

NREL complies with this requirement and files an annual sanding report with 

CDPHE. During the period of October 2002 to May 2003 NREL used 31 tons 

of sand during 13 sanding episodes. During the period of October 2003 to 

May 2004, NREL used 20 tons of sand during 10 sanding episodes. NREL 

maintains 4 lane-miles of roads. 

5.1.2 Permitting

Most potential sources of air emissions from NREL laboratory and facility 

operations in 2003 were small scale and did not require permitting. Permitting 

thresholds are generally 50, 500, 1000, or 2000 pounds, depending on the 

pollutant. Projected emissions for these sources were either below thresholds 

for air permitting or the state reviewed the operation and determined emissions 

to be negligible in terms of impacts to the environment. 

Two site-wide permits for particulate emissions from construction areas have 

been issued to NREL by CDPHE. One permit covers the STM site, and the 

other is in effect for the NWTC. Particulate air emissions are controlled by 

requiring construction subcontractors to follow control measures identified in a 

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Particulate Emissions Control Plan. NREL also holds one air emissions permit 

for an experimental pilot process in the FTLB on the STM Site. 

5.1.3 2003 Activities

No APENS were filed in 2003. 

5.2 Drinking Water 

5.2.1 Program Management

Management in this area is consistent with the following NREL Programs: 

Drinking Water (6-2.3) and Environmental Permitting and Notification (6-2.1). 

Drinking water is provided to NREL’s STM and DWOP sites by a public 

water supply, Consolidated Mutual Water Company. Water to the Joyce Street 

and ReFUEL Facilities is also provided by a public water supply. NREL 

supplies drinking water to its NWTC by trucking in water from the Boulder 

public water supply through a subcontracted water hauler. NREL stores the 

water on site in an underground 15,000-gallon storage tank and an above 

ground 2000-gallon tank. The 15,000-gallon tank is filled by the water hauler, 

and water is pumped on demand to the 2000-gallon tank, where it is distributed 

to the Industrial User Facility (IUF) and Building 251. 

Disinfection boosting is performed at the NWTC using a chlorine disinfection 

system. 

Testing for bacteria, lead, and copper is performed at the NWTC according to 

the requirements of CDPHE. NREL qualifies for reduced lead and copper 

monitoring. Current state requirements for NREL’s site are as follows: 

• Bacteria – monthly 

• Lead and copper – triennially 

• Chlorine residual – monthly, or more frequently as needed 

All samples are taken from one of the taps connected to the system. No 

coliform was detected in any of the samples taken during 2003. 

Monitoring for lead and copper was completed as scheduled during the 

summer of 2002. All samples collected were well below the action levels, and 

sampling according to NREL’s reduced monitoring plan with CDPHE was not 

to be required again until the summer of 2005. However, the State requested 

NREL collect lead and copper samples in 2004. All lead and copper levels 

were below action levels. 

NREL Environmental Performance Report- 2003 

 

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Chlorine residual monitoring of the NWTC drinking water system began with 

the installation of the chlorine disinfection system in 2000. Monitoring is 

performed to ensure the chlorine residual levels are detectable, with a target 

concentration of at least 0.2 mg/L of chlorine present to provide sufficient 

disinfection at the taps for both Building 251 and the IUF. The state requires 

that chlorine residual monitoring occur when collecting bacterial samples 

(monthly). NREL monitors chlorine residual levels in the system on a weekly 

basis and also measures chlorine levels of drinking water that is delivered to 

the NWTC. 

Although potable water delivered to the NWTC is from the Boulder supply 

that has already been treated and filtered, drinking water at the NWTC is 

filtered on site using a 1-micron filter. This would filter out any 

microorganisms (e.g. cryptosporidium or giardia) that are resistant to 

disinfection. The filters used by NREL are third-party tested to confirm that 

they actually filter particles as small as 1 micron in size. 

If any treatment is performed on supplied drinking water, state regulation 

requires that a State-licensed operator supervise the treatment. NREL hires a 

subcontracted operator with a Class A license to supervise the disinfection and 

filtration operations and to perform the necessary sampling. 

5.2.2 Permitting

NREL has a Public Water Supply Identification Number (PWSID) issued by 

CDPHE for the drinking water it provides at the NWTC. This identification 

number does not require periodic renewal, but periodic testing and record 

keeping is required in connection with the PWSID. No identification is needed 

for NREL’s STM, DWOP, JSF, or ReFUEL sites, as water is piped from a

municipal supplier, and NREL does not alter or treat the water in any way.

5.2.3 2003 Activities

Water sampling in the FTLB, on the STM Site, was initiated in November 

2001 in an attempt to isolate the root cause of poor taste with the water supply. 

Samples were analyzed for total organic carbon, total coliform, nitrate, nitrate 

+ nitrite, sulfate, turbidity, chromium, copper, iron, nickel, lead, zinc, residual 

free chlorine, and total alkalinity. There were no materials detected in the 

sampling that would have affected taste; it is hypothesized that reservoir 

conditions in 2001 could have been responsible for the poor taste. As a result 

of this sampling, however, lead was detected in two samples. NREL 

investigated the lead detection in the potable water supply as a separate issue. 

In-depth sampling for lead was completed in April and May of 2002, and 

based on those results, it was determined that lead contamination was not a 

pervasive problem throughout the FTLB domestic plumbing system. Lead was 

NREL Environmental Performance Report- 2003 

 

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not detected in the samples representing water coming into the building 

through the water main or the service connection that carries water from the 

water main to the building. Samples representing the plumbing upstream of 

the individual outlets were non-detectable or very low. In most cases, lead 

sources appear to be within the outlets or the plumbing leading from the outlets 

to the lateral piping. 

As a result of these findings, AquaPure AP1L3 filters were installed where

lead contamination was considered to be a risk for potable water, and sink 

hardware was changed in several locations. Subsequent monitoring for lead at 

the FTLB was conducted on a quarterly basis throughout 2003. That sampling 

verified the effectiveness of the filters and hardware change-outs. In 2004, 

quarterly sampling was conducted in February and July, with no lead detected 

above EPA action levels. Therefore the sampling frequency will be decreased 

to every 6 months for future sampling. 

At the end of 2003 chlorine residual testing at the NWTC indicated that 

chlorine was dissipating too rapidly within the water distribution system. After 

investigation, NREL determined this was the result of decreased water usage 

from proactive water saving measures implemented in 2002. 

An engineering solution was developed to increase water flow through the 

piping via a recirculation loop on the system. This involved increasing the 

amount of chlorine being added to the system, while recirculating water that is 

in storage in the piping prior to its distribution at potable outlets. This solution 

was implemented in 2004. 

In May 2004, one of the routine bacteriological samples tested positive for 

coliform. The required follow-up samples were collected and analyzed, with 

no detection of bacteria. 

5.3 Ground Water Protection 

5.3.1 Program Management

Management in this area is consistent with NREL’s Groundwater Protection 

Program (6-2.4). 

Because of the sensitive nature of the ground water resource, NREL is careful 

to evaluate all outdoor projects to attempt to eliminate their potential to impact 

ground water quality. If there are any materials used that could pose a 

potential ground water risk, the Laboratory typically insists that safeguards to 

protect ground water be established, such as secondary containment for 

equipment that could have the potential to leak oil, double wall tanks with leak 

detection for diesel fuel storage for NREL facilities’ emergency generators, 

and bermed areas to contain experimental materials. 

NREL Environmental Performance Report- 2003 

 

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Ground water characterization was begun on the STM site in 1990 with the 

installation of a monitoring well network. Eight wells were installed at the 

base of the mesa slope. Four wells were installed upgradient of NREL 

development in order to provide an indicator that contaminants were not being 

transported onto the NREL site, and four wells were placed in a generally 

downgradient direction to verify that NREL activities had not adversely 

affected ground water quality. Quarterly sampling was performed for five 

calendar quarters, followed by annual sampling for three years. There was no 

evidence of contamination found. In addition, routine follow-up sampling was 

done in 1997. Three of the initial eight wells were closed (according to state 

requirements) due to construction activities in 1993, and a fourth was found to 

be inaccessible during the 1997 sampling, presumably also due to construction 

activity in the area. Therefore follow-up samples were only collected from

four of the original monitoring wells: three upgradient wells and one 

downgradient of NREL development. No evidence of contamination was 

found in the 1997 sampling. 

NREL has not conducted groundwater monitoring at its leased DWOP site, as 

there have been no activities that pose an unusual risk to groundwater quality. 

If NREL had reason to suspect a groundwater quality problem, the issue would 

be addressed with Denver West Management. DWOP management contracted 

with an engineering firm to conduct a cursory groundwater monitoring study in 

1988 adjacent to the NREL-leased buildings. Two monitoring wells were 

drilled. There were no detections of significant levels of contaminants. 

The NWTC currently has no open or active groundwater wells. There was a 

water supply well that provided water to Building 251 when the site was 

operated by DOE's Rocky Flats Office. In 1993, NREL collected one round of 

water samples from this well and the associated water distribution and 

treatment system for the purpose of determining the most feasible alternative 

for water supply to the site. Based on the sampling results, it was determined 

that the maintenance and repairs required to make the existing well and 

treatment system effective were extensive, and there was an indication of the 

potential for trace organic compounds in the water. Therefore, when DOE's

Golden Field Office assumed landlord responsibility for the site in 1993, the 

connection between the building and the well was severed. The water supply 

well was plugged and abandoned in accordance with state regulations by an 

NREL subcontractor in 1996. Potable water is currently transported to the site, 

as described in section 5.2. NREL has not done any other groundwater 

sampling at the site. Groundwater sampling will be conducted if future 

activities pose a risk to the groundwater quality.

There has been no ground water study performed by NREL at the JSF, as 

NREL has not conducted any activities at the site that pose an unusual risk to 

ground water. All activities at the site are conducted inside the facility with the 

NREL Environmental Performance Report- 2003 

 

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exception of routine deliveries and pick-up of inventory stored in the 

warehouse. 

There is currently no ongoing routine ground water monitoring program on any 

NREL site, because, with one exception, there have been no activities 

identified that currently or historically posed a significant risk to ground water. 

The one occurrence that had the potential to impact ground water was a diesel 

leak to the environment in June 1998 from a failed check valve on the PDU 

emergency generator above ground storage tank at the Alternative Fuels User 

Facility. The majority of contaminated soil was excavated and removed from

the site for disposal at a permitted landfill. Three ground water monitoring 

wells were installed at the site in September 1998, one upgradient, and two 

downgradient. No hydrocarbon contamination was detected in the ground 

water during the initial sampling of the three wells, nor during follow-up 

sampling conducted in March and September 1999, and March 2000. Based 

on the results of these follow-up samples no further samples will be collected. 

5.3.2 Permitting

All ground water monitoring wells installed by NREL at the STM site have 

been permitted with the Colorado Department of Natural Resources. 

Abandonment paperwork has also been filed with the State of Colorado for the 

three wells that were plugged in 1993. 

5.3.3 2003 Activities

Plans are being developed to close the three monitoring wells installed in 

September 1998. 

5.4 Wastewater Discharge 

5.4.1 Program Management

Management in this area is consistent with NREL’s Waste Management and 

Minimization Program (6-2.8). 

The majority of wastewater from NREL’s STM and DWOP facilities flows 

into the Pleasant View Water and Sanitation District’s system and ultimately to 

Metro Wastewater Reclamation District’s (Metro) treatment plant. There is a 

small septic system consisting of a tank and absorption field, on the mesa top 

serving the Solar Radiation Research Laboratory (SRRL), because there is no 

sewer line to the mesa top. Wastewater from the JSF and the ReFUEL Facility 

also flows to Metro’s treatment plant. The NWTC is not connected to a sewer 

system, but has two septic systems that include tanks and absorption fields for 

the treatment of wastewater. 

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It is NREL policy that hazardous chemicals are not to be discharged to the 

sewer system, and NREL staff are trained in this policy. In addition, NREL 

sites have design criteria for waste drains in lab areas to minimize the 

possibility of a hazardous material discharge. These criteria include measures 

such as secondary containment for any chemicals used near sinks in laboratory 

exhaust hoods, no floor drains in laboratory areas unless a specific need can be 

shown, and caps for any floor drains that are installed in lab areas. New 

research and operations activities as well as ongoing activities that undergo 

significant modifications are reviewed for their potential effect on wastewater 

character through NREL’s risk assessment process. 

5.4.2 Permitting

No permitting for the majority of NREL’s wastewater discharges is required. 

NREL has no direct wastewater discharges to the environment at the DWOP or 

JSF, so no National Permit Discharge Elimination System (NPDES) permitting 

is necessary. NREL maintains three individual sewage disposal systems, two 

at the NWTC and one at the STM site. The remainder of NREL facility 

wastewater is discharged to Metro through the sanitary sewer system. NREL 

facilities are currently classified by Metro as non-industrial water users at these 

sites. As non-industrial users, NREL sites do not need a permit from Metro for 

sewer discharge, and monitoring for pollutants in wastewater is not required. 

NREL maintains septic permits from Jefferson County (an authority delegated 

to the counties under a State of Colorado program) for the NWTC IUF septic 

system as well as for the SRRL facility on the STM site mesa top. 

5.4.3 2003 Activities

There were no new significant activities during 2003 in this area. 

5.5 Surface Water Protection (Storm Water) 

5.5.1 Program Management

Management in this area is consistent with the following NREL Programs: 

Storm Water Pollution Prevention for Construction Activities at the STM, and 

Storm Water Pollution Prevention for Construction Activities at the NWTC (6-

2.15 and 6-2.16, respectively) 

Limited storm water monitoring was conducted at the STM site during the 

summers of 1992 and 1993 to characterize surface water quality at NREL's 

existing level of activity at that time, and to confirm that NREL's activities

were not adversely impacting storm water quality on the STM site. Sampling 

indicated that NREL's activities are not resulting in contamination of storm 

water runoff. 

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No storm water monitoring has been conducted at NREL’s other sites. In 

1998, surface water samples were taken in two drainages at the NWTC in 

connection with NREL’s weed control efforts. No traces of the herbicide 

applied to weed-infested areas were detected in the water samples. 

Outdoor research projects are reviewed during the planning stages, through 

NREL’s NEPA and risk assessment processes, for potential impacts to surface 

water. Measures to prevent such impacts are incorporated, as appropriate, into 

the design for each project. Such control measures could include secondary 

containment and bermed areas where chemicals will be used, or installation of

a cover or roof to protect chemical use and storage areas from precipitation and 

adverse weather conditions. 

Storm Water Pollution Prevention Plans (SPPP) have been written for 

construction activities on both the STM and NWTC (6-2.15 and 6-2.16, 

respectively). Erosion and sediment controls are implemented according to the 

plans, and periodic site inspections are conducted to verify that the controls are 

functioning properly and to identify any repairs to the erosion and sediment 

controls that are needed. Written reports are issued for each inspection, with 

corrective actions assigned to responsible staff when necessary. The SPPPs 

also provide for prompt revegetation of disturbed areas. Provisions of the 

SPPPs are implemented through coordination with NREL’s construction 

subcontractors. 

5.5.2 Permitting

NPDES notification for storm water discharges on federal facilities in 

Colorado is under the jurisdiction of the Environmental Protection Agency 

(EPA). NREL is currently covered under EPA’s general permit for storm 

water discharge associated with construction activities on the STM and NWTC 

sites. Both Midwest Research Institute, as operator, and DOE, as site owner, 

have filed Notices of Intent for appropriate construction activities on the STM 

and NWTC Sites. No permits are required for NREL’s routine operations. 

5.5.3 2003 Activities

In 2003 there were a few research-related and paving construction projects for 

which erosion and sediment control programs were developed. These were 

minor in terms of the extent of soil disturbance. The only major project during 

2003 was the construction of a natural gas pipeline at the NWTC. The project 

began in late 2003 and was completed in early 2004. Reseeding was 

completed, and revegetation is considered complete as of September 2004. A 

Notice of Termination on the project will be filed with EPA in the Fall of

2004.

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5.6 Waste Management 

5.6.1 Program Management

Management in this area is consistent with the following NREL Programs: 

Waste Management and Minimization (6-2.8), and Environmental Permitting 

and Notification (6-2.1). 

Hazardous wastes are handled and disposed according to the Resource 

Conservation and Recovery Act (RCRA). NREL facilities' waste profile 

consists of a broad range of hazardous laboratory chemicals in small quantities. 

Chemicals in solid or liquid form are collected in each laboratory or at each 

experimental site. These wastes are periodically collected from the 

laboratories and prepared by the NREL ES&S Office for off-site disposal. 

Treatment and disposal is conducted at EPA-permitted treatment, storage, and 

disposal facilities. In addition, NREL facilities have adopted a conservative 

waste disposal policy in which materials that are not regulated by RCRA, yet 

pose a potential hazard, are collected and disposed of as non-hazardous 

material at a RCRA-permitted disposal facility. 

NREL facilities also generate low-level radioactive wastes. This waste 

normally consists of personal protective equipment, disposable labware, 

scintillation fluids, and water-based liquids. Radioactive waste is shipped offsite for disposal on an as-needed basis. 

5.6.2 Permitting

NREL has four separate sites that have the potential to produce limited 

quantities of hazardous materials. Each of the four sites has a Resource 

Conservation and Recovery Act (RCRA) waste generator identification 

number issued by the State of Colorado. The South Table Mountain and 

Denver West Office Park locations are classified as "small quantity 

generators," generating less than 1000 kg of waste per month. The other two 

sites, the Joyce Street Facility and the National Wind Technology Center, are 

classified as "conditionally exempt small quantity generators," generating less 

than 100 kg of waste per month. 

5.6.3 2003 Activities

In calendar year 2003 NREL shipped 20,638 pounds (9,381 kg) of hazardous 

waste, and 5,232 pounds (2,378 kg) of non-RCRA regulated waste for 

disposal. These quantities are approximations only. The materials are 

normally not weighed when picked up by disposal or recycling vendors. 

Typically, a vendor will provide its good faith estimate of quantity based on

practical experience. 

NREL Environmental Performance Report- 2003 

 

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The quantity of low level radioactive waste shipped for off-site disposal in 

2003 was 715 pounds (325 kg), which included 209.46 MBq (5.655 mCi) of 

carbon-14 and tritium. Information regarding the types and quantities of 

radioactive materials used at NREL facilities is detailed in Section 5.15. 

Data entered into the DOE Pollution Prevention database, which represent 

waste generated on a fiscal year (October 1 through September 29) basis are as 

follows for fiscal year 2003: 21,725 lbs of hazardous waste, 5469 lbs of nonRCRA regulated waste, 21.9 cu ft low level liquid radioactive waste, and 14.6 

cu ft. low level solid radioactive waste. 

In 2003, NREL participated in the DOE Materials Exchange program by 

sharing the list of chemicals available for redistribution with other DOE 

facilities. This effort may contribute to waste reduction within the DOE 

organization. 

An assessment of the Waste Management and Minimization Program was 

conducted by both NREL and the Colorado Department of Public Health & 

Environment in 2003. Details are discussed in Section 4.3. 

5.7 Storage Tanks (Underground and Above Ground) 

5.7.1 Program Management

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

Aboveground Storage Tank Management (6-2.7) and Spill Prevention Control 

and Countermeasures (6-2.10) 

NREL facilities store diesel for emergency generator and research use in 

aboveground storage tanks. The NREL tank inventory is presented in 

Appendix B. NREL's tank management program focuses on proper tank 

design, operation, and inspection to protect against spills and leaks. The 

program is designed to meet regulatory requirements, and it is more stringent 

than the regulations require in many areas. 

Several important safeguards have been incorporated into NREL’s tank 

management program to prevent any accidental releases of diesel fuel from the 

storage tanks. These safeguards include both mechanical safeguards, such as 

double wall tanks with sensors that result in an alarm if the inner tank wall is 

leaking, overfill prevention, and spill protection; and procedural safeguards 

such as written operating procedures and tank filling procedures. All tanks 

larger than 110 gallons are visually inspected at least once per month. 

Due to the quantity of diesel fuel stored on the STM site, a Spill Prevention 

Control and Countermeasures Plan is required to be in place. This Plan 

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describes the site topography and neighboring areas, and outlines the steps 

necessary to mitigate any spills or leaks of diesel fuel. To date, NREL has not 

had any offsite impacts related to tank activities. 

5.7.2 Permitting

Tanks larger than 660 gallons are required to be registered with the State of 

Colorado, with the registration renewed annually. Currently, only two tanks 

meet the registration threshold, the SERF emergency generator diesel storage 

tank and the Process Demonstration Unit (PDU) ethanol storage tank at the 

Alternative Fuels User Facility (AFUF), both located on the STM site. 

5.7.3 2003 Activities

There were no spills or leaks from NREL tanks during 2003. There was no 

state inspection in 2003.

5.8 Hazardous Materials Management 

5.8.1 Program Management

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

Chemical Safety Program (6-4.6), and Asbestos Management Program (6-4.18) 

No hazardous waste sites have been identified on any of the Laboratory sites. 

Therefore, many sections of the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) do not apply to NREL facilities. 

NREL facilities are subject to the emergency reporting requirements in Title III 

of the Superfund Amendments and Reauthorization Act (SARA), also known 

as the Emergency Planning and Community Right-To-Know Act (EPCRA). 

Section 302 of these regulations requires a facility to notify the State 

Emergency Response Commission (SERC) that it is subject to emergency 

planning and notification requirements if any chemicals in the facility's

inventory are stored in quantities greater than prescribed threshold planning 

quantities (TPQs). NREL facilities first became subject to planning and 

notification requirements in 1988. 

EPCRA Section 304 requires facilities to immediately notify the Local 

Emergency Planning Committee (LEPC) if there is an accidental spill or 

release of more than the predetermined reportable quantity (RQ). 

According to Section 311 and 312 of EPCRA, NREL provides Material Safety 

Data Sheets (MSDSs) for chemicals that are stored on-site in quantities greater 

than TPQs, and provides inventory reporting for these same chemicals in the 

form of Tier I or Tier II reports to emergency planning and response groups. 

NREL Environmental Performance Report- 2003 

 

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NREL provides additional emergency response and reporting information to 

the Jefferson County Emergency LEPC, the SERC, and West Metro Fire 

Protection District when requested. The Jefferson County LEPC uses Uniform

Fire Code hazard categories and threshold reporting quantities rather than

those specified in SARA Title III, resulting in a larger number of individual 

hazard categories and lower reporting thresholds. NREL has an active 

involvement in the emergency planning concepts of SARA Title III, in that the 

Laboratory currently has two acting members on the Jefferson County LEPC, 

and has been represented since the LEPC’s inception. 

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 EPA for any chemical that is manufactured, processed, or otherwise 

used in quantities exceeding Threshold Planning Quantities (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, Executive Order 12856 requires all federal facilities to file a report, 

if applicable, regardless of SIC code. 

Section 112r of the Clean Air Act regulates numerous toxic and flammable 

substances, and threshold quantities are established under Section 112r of the 

Clean Air Act. All thresholds are 500, 100, 2500, 500, 10,000, 15,000, or 

20,000 pounds, depending on the material. The threshold quantity applies to 

the quantity of substance in a single process, not at the facility as a whole. 

NREL has a Laboratory-wide chemical management system 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 barcoding system, the 

CMS tracks chemicals from the point of receipt through disposal. The system

also contains technical data and reporting information for many of the 

chemicals in the CMS database. Key functions of the system include: 

• Providing current inventories by room, building, and/or site 

• Improving research efficiency and minimizing hazardous waste 

generation by allowing staff to determine if needed chemicals are 

already available on site prior to making chemical purchases 

• Providing quick access to chemical inventories and hazard information 

during emergency responses 

• Facilitating accurate and efficient reporting to external agencies (e.g. 

fire districts, EPC, EPA, DOE) 

 

To maintain the CMS database, a physical inventory of each lab and work area 

in which chemicals are used or stored is conducted periodically. 

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NREL has not identified any areas within its facilities that contain residual 

contamination requiring special decommissioning. Asbestos surveys have 

been conducted in a number of NREL facilities: Joyce Street Facility; 

Building 251 at the NWTC; Building 16, and at the STM Site the AFUF (only 

older areas of the building), FTLB and SRRL. No asbestos was found at the 

Joyce Street Facility and the AFUF. The other facilities have limited amounts 

of asbestos-containing material in areas such as floor tile, lab countertops, 

caulking and sealants, and roofing material. Asbestos-containing materials are 

left undisturbed whenever possible. If renovation is planned that will disturb 

asbestos-containing material, then certified asbestos removal contractors are 

used and strict asbestos removal procedures are followed. An Asbestos 

Management Program is in effect for all NREL facilities. 

5.8.2 Permitting

NREL obtains annual Hazardous Material Permits from West Metro for the 

STM and DWOP sites. The permits are required by the West Metro and are 

issued by building. NREL obtains permits for a total of six buildings where 

hazardous materials are stored and/or used. Prior to issuing the permits, a 

representative from West Metro conducts a walk-through inspection of the 

entire South Table Mountain Site and DWOP. 

5.8.3 2003 Activities

In 2003, the U.S. EPA conducted soil sampling at NREL’s NWTC Site. 

Sampling results were compared to standard criteria by EPA. Based on the 

results, EPA issued a letter clarifying that NWTC is not on the CERCLA list of 

potential Superfund Sites. 

West Metro conducted a walk-through inspection of NREL’s STM and DWOP 

facilities in the spring of 2003. Annual hazardous materials permits for the six 

buildings were issued following the inspection. West Metro provided a few 

recommendations as a result of that inspection. Recommendations included: 

labeling natural gas lines in four labs at the AFUF, installing hazard placards 

on doors in four labs at the FTLB, installing a hazard placard on the south side 

of the Waste Handling Facility, replacing warning signs at the SERF loading 

dock area that had faded, and placing 55-gallon drums in secondary 

containment. All recommendations have been implemented with the exception 

of the last, which is still being discussed with West Metro. 

The CMS was used to provide complete chemical inventories for each facility 

to West Metro when applying for Hazardous Materials Permits in 2003. The 

CMS was also used to post individual laboratory chemical inventories on the 

ES&H website, which were updated monthly. 

NREL Environmental Performance Report- 2003 

 

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In 2003, NREL had three chemicals on-site in quantities that exceeded the 

TPQs, sulfuric acid, hydrofluoric acid, and hydrogen selenide. The proper 

MSDSs and Tier II forms were submitted to state and local emergency 

response organizations and the local fire department. 

In 2003, NREL facilities had no release exceeding the RQ of any reportable 

material under EPCRA. 

As a research and development Laboratory, NREL does not manufacture or 

process any materials, and during 2003, the Laboratory did not use any 

materials on the Section 313 list in quantities exceeding the 4536-kg (10,000-

lb) threshold planning quantity. 

5.9 Pollution Prevention & Sustainability 

5.9.1 Waste Minimization, Recycling, and Green Purchasing 

(Purchasing Materials With Recovered Content)

As a facility that focuses on the research, development, and deployment of 

renewable energy and energy efficiency technologies, NREL is committed to 

responsible environmental stewardship. A significant part of this effort is 

pollution prevention. NREL's Waste Management and Minimization Program

outlines pollution prevention principles that are consistent with the EPA's 

hierarchy of preventing or reducing pollution at the source; recycling or 

reusing waste materials that cannot be prevented; and environmentally safe 

treatment and disposal of waste that cannot be prevented, recycled, or reused. 

The current pollution prevention program includes training on waste handling, 

waste minimization, and methods to eliminate releases to air, soil, or 

wastewater. In addition, the ES&S Office integrates pollution prevention

awareness into NREL activities in a number of ways. The proposed use of 

chemicals in projects are evaluated prior to use during project planning 

reviews, Safe Operating Procedure reviews, and Readiness Verifications 

conducted according to NREL’s Hazard Identification and Control Program

(ESH 6-6.2). During these reviews, NREL staff evaluates opportunities for 

chemical substitution as well as methods of reducing the volume of chemicals 

used and waste streams generated. 

The use of bankcards for chemical purchases has been another means of 

reducing the volume of chemicals purchased, stored and disposed at NREL. 

Under the bankcard chemical purchasing system, a small group of chemical 

users are given privileges to order chemicals directly from the vendor using 

their bankcards. Because bankcard purchasing expedites chemical purchases 

over conventional purchasing processes at NREL, users order only the 

chemicals they foresee they’ll need in the immediate future, knowing that they 

NREL Environmental Performance Report- 2003 

 

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can quickly obtain more if needed. The ES&S Office reviews all chemical 

purchases made using the bankcards. 

Recycling and reuse activities are important components of NREL’s pollution 

prevention program. NREL’s recycling program is managed by a crosscutting 

committee comprised of staff from around the Laboratory, and led by 

Sustainable NREL. Items currently recycled or reused at NREL include the 

following: 

• fluorescent bulbs 

• batteries

• styrofoam peanuts and other packing materials 

• freon from refrigerator units 

• scrap metal 

• wooden pallets 

• laser printer cartridges 

• aluminum and tin cans 

• glass 

• plastics (1 & 2 only) 

• newspaper 

• white and mixed paper 

• corrugated cardboard 

• boxboard 

• books and magazines 

• transparencies, and 

• tyvek envelopes 

Several central recycling locations are available for most recycling needs 

throughout NREL facilities. NREL also offers a chemical redistribution 

program where chemicals in original containers are made available to staff at 

NREL and other DOE facilities to be reissued for research activities at no cost. 

The NREL CMS is used for redistributing chemicals to new users. 

In 2003, NREL generated 218 metric tons of solid waste and diverted 72 

metric tons to recycling, or 33% of the total. Data for some of the materials 

recycled by NREL during 2003 follow. The data below are the quantities 

entered into the DOE Pollution Prevention database, which tracks recycling on 

a fiscal year (October 1 through Sept. 29) basis. Data are for fiscal year 2003. 

Quantities are not tracked for all materials that are recycled, so the list below 

does not include all recycled materials. 

 Batteries 2,590 lb 

 Fluorescent bulbs 203 lbs 

 Mixed metal 56,720 lb 

Commingled containers 25,646 lb 

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 Cardboard 24,300 lb 

 Misc. paper 175,677 lb 

 Computer monitors 3,219 lbs 

NREL also performed an analysis of its solid waste stream to determine the 

recyclable content. It was determined that some 30% of the waste stream was 

recyclable material. This analysis serves as the basis for defining the focus of 

recycling activity for FY2004 and beyond. 

When possible, NREL purchases products with recovered content. In 2003, 

some of the products purchased containing recovered content included 

carpeting, uncoated-printing paper, and toner cartridges. One hundred percent 

(100%) of NREL’s supply of carpet, uncoated printing and writing paper, and 

toner cartridges purchased in 2003 contained recovered content. 

5.9.2 Vehicles

NREL leases 47 vehicles from the General Services Administration. These 

vehicles are used for a variety of transportation and special purpose activities, 

such as equipment moving and servicing, grounds maintenance, and travel 

between the NREL sites. Of those vehicles, 29 are alternative fueled vehicles 

or hybrid vehicles. It is NREL policy to replace standard vehicles with 

alternative fuel vehicles whenever a suitable vehicle is available from GSA, 

with an ultimate NREL goal of 100% AFVs and hybrids. In fiscal year 2003, 

NREL was able to reduce its petroleum usage by 30% over the base year, 

1999. The goal set by E.O. 13149 for all federal agencies is to reach a 20% 

petroleum use reduction by 2005. 

5.9.3 Energy

NREL has already met the 2005 and 2010 Federal requirements for reduction 

in energy use per square foot in laboratory and industrial facilities using a DOE 

1990 baseline. The baseline is the average for all DOE Laboratory and 

Industrial Facilities in 1990. For NREL, this baseline is 352,540 BTU/SF and 

will be applicable to NREL facilities from 2002 forward. 

Table 5.1 includes the FY 1990 baseline and summarizes the energy 

consumption per gross square foot for Total NREL facilities, which includes 

both the South Table Mountain and National Wind Technology Center sites. 

Table 5.1 – Energy Consumption 

BTU/GSF

FY1990 BASE YEAR 352,540 

FY2001 TOTAL NREL (DOE-owned) 271,247 

FY2002 TOTAL NREL (DOE-owned) 270,495 

FY2003 TOTAL NREL (DOE-owned) 257,887 

FY2003 TOTAL NREL (w/ Wind Source Credit) 240,525 

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Comparing total NREL energy consumption in FY 2003 to the baseline, the 

energy consumption is 27% lower than the FY 1990 baseline. In addition, the 

total NREL energy consumption with wind source Credit is 32% lower than 

the FY 1990 baseline. 

Individual Building Metering & Individual Energy Saving Program. NREL 

previously received gas and electrical utility billing from the utility company, 

Xcel, on a monthly basis for NREL’s two sites. The electrical utility billing 

was not broken down into individual buildings within each site; Xcel only

provided the total electrical power consumption and billing data for the entire 

site. In 2002, NREL completed installation of individual power meters at each 

major facility on the STM and NWTC sites. Individual metering will allow 

better understanding of energy use and identify further opportunities for energy 

use and peak demand reductions. 

In 2003, NREL’s efforts were focused on organizing the metering data and 

making it accessible to NREL management, building managers, and building 

occupants as a method of providing feedback on building energy use. As a 

result of these efforts, all individual building metering information is on an 

energy performance data website on the NREL intranet. The website contains 

information about current and historical energy use patterns. A program to

educate building occupants on energy saving opportunities is also being 

implemented. The objective of providing feedback and education on energy 

saving opportunities is to reduce energy use at the individual level. 

In addition to improving the organization and accessibility of energy use data, 

in 2003 NREL also installed an energy analysis software package that is used 

to identify opportunities to reduce peak power demand using the site metering 

data. A more robust demand management program will be implemented using 

this analysis software and site metering data to secure additional peak demand 

savings. 

Building Energy Retrofits. In 2003, two upgrades to existing building systems 

were made to improve energy efficiency and reduce energy use: SERF 

exhaust fan upgrades and installation of a SERF processed water heat 

exchanger. 

Prior to the upgrade, SERF exhaust systems in the west and center wings 

introduced dilution air into its exhaust system to maintain duct static. With the 

installation of variable speed drives on the exhaust fans in the west and center 

wings, the dilution air was reduced and allowed the fan to operate at a lower 

speed, which reduced energy consumption. 

The SERF process cooling load is fed by the chilled water plant. Adding a 

heat exchanger between the process cooling load and the heat recovery system

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provides free cooling which will minimize the usage of the chilled water from

the chiller and reduce energy consumption by 20,000 therms/year. 

Energy Efficiency Specifications for Renovations/New Construction. NREL 

has always emphasized significantly greater levels of energy efficiency than 

federal standards with all of its DOE-owned buildings, with a goal to reduce 

energy use by 30% compared to the federal standard reference for building 

systems at 10 CFR 434. Energy efficiency criteria have been incorporated into 

the established NREL design standards and specifications for all construction 

projects. All new buildings must meet, at a minimum, Leadership in Energy 

and Environmental Design (LEED) Silver criteria, established by the U.S. 

Green Building Council. In addition, all new laboratory buildings are designed 

according to the principles of the Laboratories for the 21st Century Program. 

See the “Sustainable Building Design” section below for more detailed 

information. 

Computer/Monitors Purchasing. NREL Information Services (IS) provides a 

standard hardware list of recommended Energy Star products for PC and MAC 

computers, monitors and peripherals. Staff is encouraged to purchase Energy 

Star hardware items through the "Basic Ordering Agreement" (BOA) 

contracts. Suppliers websites provide energy information for standard 

products. Flat panel monitors, that use significantly less energy than standard 

monitors, have been added to NREL’s standard supply list and are the priority 

purchase recommendation. 

Computer Power Management. A computer power management project, 

begun in 2001, made significant progress toward full implementation in 2003. 

The project involved piloting computer power management software to 

centrally control implementation of aggressive suites of power management 

settings and automatically shut down computers at prescribed times at the end 

of workdays and on weekends. Baseline data collection using this tool was 

completed. Implementation of the tool on a Laboratory-wide basis is in 

progress and will be completed in FY2004 and FY2005. NREL has also 

developed a web-interface so that computer power management data for 

individual computer, organizational, and Lab-wide use is available. 

Printers and Copiers. Networked printers are configured automatically to 

enter a low-power mode of 15-45 watts or less after a period of inactivity (this 

time period differs with models). Seventy-one duplex modules were purchased 

in FY 2001 and installed on network printers configured to default duplexing. 

Users can control one-sided printing through the applications print feature. All 

copiers are Energy Star rated. 

5.9.4 Renewable Energy

Self-generated electricity. In 2003, NREL generated about 61,290 kWh of 

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electricity from grid-connected PV panels each year. These panels are located 

on the Solar Energy Research Facility, the Site Entrance Building, and the 

Outdoor Test Facility. 

The NREL NWTC has approximately 1600 kW of installed wind turbine 

capacity used for research purposes. When the turbines are running, the 

energy that they produce is used to offset simultaneous NWTC site energy use. 

In 2003, actual energy produced by the NWTC wind turbines was 59,750 

KWH. 

Purchased renewable energy. In FY2003, NREL purchased 1,981,200 kWh 

of wind-generated electricity from the local utility company, Xcel Energy. 

This purchase represents about 10% of NREL’s annual electrical usage. 

NREL has committed to purchase another 1,981,200 kWh of wind-generated 

electricity for FY2004 and will be negotiating agreements for FY2005 and 

beyond. 

5.9.5 Water Conservation

In 2002, NREL completed a Water Efficiency Plan that also identifies and 

ranks available water savings best management practices (BMPs) in 

accordance with the Federal Energy Management Program (FEMP) guidelines. 

In fiscal year 2002, one BMP was implemented: NREL installed low-flow 

toilets, waterless urinals, and low-flow showerheads in 100% of existing 

facilities. In fiscal year 2003, NREL implemented the Public Information and 

Education Programs and Water Efficient Landscaping BMPs at 100% of DOEowned buildings. 

Water use data for the STM site is obtained from the water supply company, 

Consolidated Mutual Water. All of the facilities that require water on the STM 

site have dedicated water meters. There are also water sub-meters on all three 

cooling towers at the STM site. 

The NWTC site is a remote site that has no wells or water supply. Boulder 

Public Water Supply water is delivered weekly to the NWTC, as described in 

Section 5.2. Currently water usage at the NWTC is measured by the amount of 

water delivered to the site. 

 

The water use for all NREL sites is summarized in Table 5.2. Water 

consumption was 24% lower in FY2003 as compared to FY2000 base year. 

Table 5.2 – Water Consumption 

Million Gallons per Year (MGY) 

FY2000 (BASE YEAR – TOTAL NREL) 12.9 

FY2002 – TOTAL NREL 10.9 

FY2003 – TOTAL NREL 9.8 

NREL Environmental Performance Report- 2003 

 

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5.9.6 Sustainable Building Design

Several of NREL's buildings, including the Thermal Test Facility (TTF) and 

Solar Energy Research Facility (SERF) are models of energy efficiency. The 

SERF's annual energy costs are 40 percent below that of a similar building 

designed to meet federal energy standards, and the TTF operates on 63 percent 

less energy than a building designed to meet the Federal Energy Code. The 

TTF building received a 2002 Federal Energy Saver Showcase Award. 

The proposed Science and Technology Facility (S&TF), slated for construction 

in early 2005, has been designed to be at the LEED Gold Level. Its projected 

energy cost reduction is 50% better than the requirement for federal facilities 

(10 CFR 434). The S&TF is a Laboratories of the 21st Century Pilot Partner 

Project.

The NWTC Site Entrance Building (SEB) was designed in-house by NREL 

staff during fiscal year 2002. Construction was completed in early 2003. The 

building was designed to be a near zero energy building; its systems are fully 

monitored. The NWTC SEB is 16’x 10’, and uses NREL technologies to 

reduce the power demand of the building. Such technologies include 

daylighting, passive solar heating, good thermal envelope, natural ventilation 

through the windows, low-e windows, overhangs for shade control, a Trombe 

wall, occupancy and daylight sensors, high-efficiency lighting with dimming 

fixtures, and the use of energy efficient flat screen computer monitors. These 

technologies, along with a roof mounted 768 W photovoltaic array, and two 

1000 W wind turbines, reduce the amount of electricity drawn from the utility 

grid and feed excess electricity produced back to the grid. 

5.9.7 Technical Assistance and Outreach

Outreach by Leadership. In 2003, NREL staff developed a Sustainable Design 

Guide for Los Alamos National Laboratory. NREL FEMP staff have assisted 

in developing both Energy Management and Water Management Plans at 

NREL. In addition, NREL FEMP staff developed the Department of 

Commerce agency-wide energy plan and are in the process of assisting several 

other agencies in their energy planning processes. NREL researchers work 

with DOE, EPA, the US Green Building Council, and others on a variety of 

assistance and outreach programs and activities related to energy and water 

use. Examples include standards development, conferences, classes and 

workshops, tours, publications, websites, and energy and water analysis 

software. NREL’s activities in this regard can be surveyed through the most 

recent Institutional Plan or Performance Assessments, accessible on NREL’s 

website (www.nrel.gov). 

Outreach by Recognition. In 2003, as a component of its outreach efforts to 

disseminate information regarding sustainability, NREL applied for and 

NREL Environmental Performance Report- 2003 

 

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received a number of awards. The awards were: CU Wirth Chair Award in 

Environmental and Community Development Policy, DOE Departmental 

Energy Management Achievement Award: Effective Program Implementation 

– Sustainable NREL, and DOE Best-In-Class Pollution Prevention Awards. 

The latter award was specifically for Sustainable NREL’s New Buildings

Program; Recycling Program; and Education, Outreach, and Information 

Sharing Program.

Internal and External Outreach. NREL has produced a number of 

publications with the goal of sharing the details of NREL’s Sustainability

Program with staff and the public. These include the Sustainable NREL 

Pioneer, an internal electronic publication; an NREL Sustainability Report, that 

will be distributed, in FY2004 and FY2005, both internally to NREL staff and 

to the public; and a Life Cycle Assessment paper that estimates NREL’s 

carbon dioxide (CO2) footprint. Also as part of Sustainable NREL’s internal 

outreach program, in 2004, the Laboratory began implementation of a webpage 

with an enhanced suite of sustainability tools for employees, for example, tools 

that address alternative commuting, computer power management, and CO2

emissions equivalents from employee activities and laboratory operations. 

5.10 Vegetation 

5.10.1 Program Management

Management in this area is consistent with NREL’s Weed Management 

Programs for the STM and NWTC (6-2.12 and 6-2.13, respectively) and the 

Sustainable Landscape Design and Management Program (6-2.19). 

NREL’s basic philosophy regarding vegetation is to conserve the ecosystems 

on the site in their natural state as much as possible. There is some

landscaping using non-native drought-tolerant species adjacent to some of the 

buildings, and even a few areas at the STM site of bluegrass. However the 

native vegetation and natural character of the landscape is maintained over the 

majority of the site. Revegetation of areas to be left in their natural state 

following disturbance from construction or other outdoor activities is 

conducted using a native seed mix of grasses and forbs. This mixes are sitespecific and are comprised predominantly of natives that were originally 

present on the site before disturbance. That seed mix and revegetation 

procedures are outlined in NREL’s Storm Water Pollution Prevention 

Programs for the STM and NWTC Sites. The use of native species is required 

at both the STM and NWTC whenever feasible. When possible, replacement 

of high water demand species, like Kentucky bluegrass, with drought-tolerant 

species is encouraged. 

NREL Environmental Performance Report- 2003 

 

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A vegetation survey of the STM site was conducted in support of the 1993 site 

wide Environmental Assessment, and a site reconnaissance was performed by 

Dames & Moore biologists in November 1997 (U.S. DOE, 1998, page 3-1). 

In 1999, a verification survey of STM site vegetation was performed on the 

Conservation easement property to identify any changes to habitat character or 

species types that may have occurred since the 1993 and 1997 surveys. An 

effort was made to determine whether any sensitive species or habitats that 

could potentially support such species were present on the site. No sensitive 

species or potential habitats were identified on the STM site. 

A vegetation survey of the STM was conducted between June 2001 and May 

2002. Five general habitats were described on the STM site, comprising seven 

plant communities (Plantae Consulting Services, 2002). No rare or imperiled 

plant species were found on the site. Areas of mixed foothills shrublands (also 

called tall upland shrubland) were identified on top of the mesa within the

Conservation Easement area. This natural community is listed as rare and

imperiled by the Colorado Natural Heritage program. No development will 

occur in the Conservation Easement area. 

Eleven noxious weed species were located on the STM site. Four of these 

belong to Colorado’s top ten prioritized-for-control weed species. These four 

include Canada thistle, diffuse knapweed, field bindweed, and musk thistle. 

A three-season vegetation survey of the NWTC site was performed between 

August 1999 and August 2000. The survey defined five general habitats on 

the NWTC site, comprising nine plant communities and 271 vascular plant 

species (Plantae Consulting Services, 2000). No rare or imperiled plant 

species were found on the site. However, the survey identified a small area of 

xeric tallgrass prairie (defined as mesic mixed grassland in this study) located 

in the southwest corner of the NWTC. This natural community is listed as rare

and imperiled by the Colorado Natural Heritage Program. This listing implies 

no legal designation or regulatory enforcement. It is made primarily for 

management purposes. This area of the NWTC is not impacted by research or 

construction activities on the site. 

The survey identified eleven noxious weed species on the NWTC site. Five of 

these are recognized as belonging to the top ten prioritized weed species in 

Colorado. Based on the survey, recommendations were made to continue 

using a comprehensive weed management program, based on integrated pest 

management (IPM) philosophy. 

The survey showed the native seed mix used for revegetation at the NWTC to 

be very successful in many areas of the site. NREL is continuing the use of 

this seed mix for revegetation at the NWTC. 

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Weed control efforts have been ongoing since 1997 at the NWTC and 1998 at 

the STM site. NREL uses an IPM approach that incorporates various types of 

weed control methods. Some of these include mechanical practices (e.g. 

mowing), cultural (reclamation of disturbed areas), prevention (e.g. limiting or 

eliminating driving of vehicles off established roadways), and herbicide 

treatment. The effectiveness of control methods is periodically assessed. The 

use of multiple strategies for control has been successful in significantly 

reducing populations of diffuse knapweed and Canada thistle on the sites. The 

key aspect of the weed control program is to maintain flexibility to respond to 

the changes in weed populations from year to year. 

In 1998, aerial herbicide application of Tordon 22K was conducted using 

helicopter application over about 200 acres of the NWTC to target diffuse 

knapweed. It has been very effective in controlling the weed, and healthy 

stands of native grasses have proliferated with the decrease in weed 

competition. Since that time, infested areas of the NWTC have been treated 

using ground application with herbicide. More information regarding 2003 

herbicide application is provided in Section 5.10.3. 

Weed infestations at the STM site are much less severe than at the NWTC. 

Limited ground application of herbicides has been conducted at the STM since 

1998. 

5.10.2 Permitting

There is no permitting applicable to vegetation management, although there is 

a State weed law that requires property owners to control certain species of

invasive weeds (e.g. diffuse knapweed). For application of certain types of 

herbicides designated as “restricted use” by EPA, a certified applicator must be 

used. Herbicide applications at NREL are always performed by a certified 

applicator. The exceptions are herbicides used for control of undesirable 

vegetation along walkways, roadways, and adjacent to facilities. These are 

typically Round-Up and Weed-B-Gon and are applied by NREL Site 

Operations staff according to an NREL Safe Operating Procedure (SOP). 

5.10.3 2003 Activities

NREL routinely practices IPM using various weed control methods, as 

described in the previous section. These are implemented during the normal 

course of site operation. In addition to the reclamation, offroad driving 

restrictions, and other weed control methods, limited ground applications of 

herbicides occurred at the NWTC and STM in the spring of 2003 and 2004. At 

the NWTC, spot spraying using tractor and backpack applicators was 

performed. Primary target weeds were diffuse knapweed, Leafy spurge, 

Canada thistle, common teasel, hoary cress, sulfur cinquefoil, and St. 

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Johnswort. At the STM, target weeds were mainly diffuse knapweed and 

Canada thistle. 

NREL promotes the sustainable management of its government-owned land by 

implementing environmentally sound, cost-effective landscaping practices that 

reduce adverse impacts to the natural environment while providing essential 

shade and cooling for indoor and outdoor spaces and a more aesthetically

appealing appearance for the sites. In order to formalize this commitment, 

NREL completed a new Sustainable Landscape Design and Management 

Program in 2003. 

5.11 Wildlife

5.11.1 Program Management

Wildlife habitat at the STM site is comprised of grasslands, shrublands, and 

wetlands. The Colorado Division of Wildlife has estimated that these habitats 

may support up to 14 species of reptiles, 36 mammal species, 82 bird species, 

and four amphibian species. However, due to the lack of aquatic sites, the 

presence of amphibians is unlikely. A resident population of mule deer 

inhabits the STM site. One or two mature cottonwood trees are located in the 

upper sections of site drainages and provide perching sites for raptors such as 

red-tailed hawks and owls. Common wildlife found at the NREL STM site 

are listed in the following table. 

Table 5.3 – Common Wildlife Found at the South Table Mountain Site 

Mammals 

Coyote Canis latrans 

Deer mice Peromyscus maniculatus 

Desert cottontail Sylvilagus auduboni 

Gray fox Urocyon cinereoargenteus 

Mexican woodrat Neotoma mexicana 

Mountain cottontail Sylvilagus nuttalli 

Mule deer Odocoileus hemionus 

Prairie vole Microtus ochrogaster 

Red fox Vulpes vulpes

Birds 

American goldfinch Carduelis tristis 

American robin Turdus migratorius 

Black-billed magpie Pica pica 

Chipping sparrow Spizella passerina 

Dark-eyed junco Junco hyemalis 

European starling Sturnus vulgaris 

Great Horned Owl Bubo virginianus 

Green-tailed towhee Pipilo chlourus 

Horned lark Eremophila alpestris

MacGillivray’s warbler Opoornis tolmiei 

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Mourning dove Zenaida macroura 

Raven Corvus corax 

Red-tailed hawk Buteo jamaicensis

Vesper sparrow Pooecetes gramineus 

Western bluebird Sialia mexicana 

Western meadowlark Sturnella neglecta 

Reptiles 

Bullsnake Pituophis catenifer 

Eastern fence lizard Sceloporous undulatus 

Plains garter snake Thamnophis radix 

Prairie rattlesnake Crotalus viridis 

Source: NREL (Dames & Moore), 1999, and NREL (ERO), 1998. 

A wildlife survey was conducted on the STM sites in 1987. Follow-up 

verification surveys were conducted in 1998 and 1999. A new site-wide 

wildlife survey is currently underway, and is described in Section 5.11.3. 

Field research into avian use of the NWTC was conducted during 1994 and 

1995 in an effort to identify potential impacts on birds from wind-turbine 

research. While several species of raptors, including red-tailed hawks, 

kestrels, and a great-horned owl were noted on the site, they were primarily 

transient in nature. The NWTC appears to be used primarily for resting and 

hunting, although one pair of kestrels nested in an old concrete pole during the 

spring. Birds of prey of concern, such as eagles, generally fly in excess of 152 

m (500 ft) over the site. No significant impacts to the birds from NREL 

activities were found. 

A year-long monitoring project for birds and bats was initiated on the NWTC 

in early 2001. Standardized plot surveys were conducted to survey songbirds 

and raptors on the NWTC and adjacent, undeveloped areas. NREL also 

conducted systematic searches of turbines and meteorological towers on the 

NWTC to document avian mortality. The study was completed in July 2002. 

Salient findings of the study were as follows (Schmidt, E., et al., 2003): 

• Abundances of individual raptor species on the NWTC site were 

similar to surrounding areas. However, the average number of species 

detected per count at the NWTC was nearly double that of surrounding 

areas in winter, the season when raptors are most abundant in the 

region. This difference is likely attributable to increased availability of 

perches at the site. Raptors flew and perched higher at the NWTC than 

in adjacent areas, again probably related to the wind turbines and other 

structures at the site. 

• Only 1 of 46 bird species counted on grassland plots during this study 

differed in abundance between the NWTC and adjacent areas – the 

horned lark, which was about 16 times more common off site. This 

difference is attributable to cattle on Boulder Open Space creating lowstature grasslands preferred by this species. 

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• Bird abundance and variety on the...[newly acquired 25-acre parcel, 

south of the previous NWTC boundary] slated for future use were 

generally similar to the developed areas, except for the relative scarcity 

of raptors on the undeveloped site, which probably was due to a lack of 

perches. 

• The NWTC does not support a large diversity or abundance of bat 

species (possibly six species of bats use the site), but an area on the 

northwest side of the site, with trees close to a rocky outcrop, provides 

foraging and perhaps roosting habitat. 

No raptor carcasses [were found] during the 12-month survey of the NWTC, 

except one American kestrel that had died before the study started. Bird 

mortality associated with the site appears to be minor. Extrapolating from four 

passerine (songbird) carcasses found during the searches, estimated annual bird 

mortality attributable to the NWTC was 24 individuals, all songbirds 

(Passeriformes). Most of these deaths were probably the result of collisions 

with support wires for the meteorological towers rather than the turbines 

themselves. No evidence [was found] of bat fatalities at the site.

5.11.2 Permitting

NREL has no permitting requirements for this area of environmental 

management. 

5.11.3 2003 Activities

A site-wide wildlife survey of the STM site was begun in April 2004 and will 

be completed in June 2005. The objectives of the survey are to update existing 

data in light of expanded development of both the site and the surrounding 

area, and to develop best management practices for future construction projects 

to maximize protection for site wildlife. 

The survey includes large and small mammals, predators, migratory birds and 

raptors, upland game birds, and invertebrates identified on an opportunistic 

basis (i.e. only as they are found during other surveys). To date, no 

unexpected species have been identified, and no threatened or endangered 

species have been identified. The final results of the survey will be discussed 

in the 2004 Annual Environmental Performance Report. 

5.12 Endangered Species/Species of Concern 

5.12.1 Program Management

NREL Environmental Performance Report- 2003 

The Endangered Species Act provides for the designation and protection of 

wildlife, fish, and plant species that are in danger of extinction and preserves 

the ecosystems on which these species depend. A wildlife survey was 

completed on the STM site in 1987 (The FORUM Associates, Inc., 1987a), at 

which time no threatened or endangered species or candidate wildlife species 

 

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for endangered designation were found. A vegetation survey of the STM site 

was completed in 1999 for the National Renewable Energy Laboratory 

(NREL) Site Conservation Easement Baseline Inventory (U.S. DOE 1999). No 

threatened, endangered, or candidate plant species were identified in the 

survey. 

Additional surveys of wildlife on the Conservation Easement property were 

conducted in 1999, also for the Baseline Inventory. The U.S. Fish and Wildlife 

Service lists five threatened and endangered animal species that may 

potentially occur in the property area, including American peregrine falcon, 

bald eagle, Eskimo curlew, Mexican spotted owl, and Preble's meadow 

jumping mouse. The Colorado Natural Heritage Program database lists three 

animal species of interest that may potentially occur in the property area, 

including common shiner, arogos skipper, and ottoe skipper. No suitable 

habitat is present for any of these species on the Conservation easement 

property. 

No threatened, endangered, or candidate species of either plants or animals 

have been identified to date on the NWTC site. A vegetation survey conducted 

between August 1999 and August 2000 identified a small area of xeric 

tallgrass (defined in the survey as mesic mixed grassland) prairie located in the 

southwest corner of the NWTC site. This natural community is listed as rare 

and imperiled by the Colorado Natural Heritage Program. This listing implies 

no legal designation, but is made primarily for management planning purposes. 

This xeric tallgrass prairie area has been designated by NREL as a 

Conservation Management Area. Most of the Conservation Management 

Areas on the NWTC are formally designated as areas on which building will 

not occur. However, as the xeric tallgrass prairie is in the active turbine testing 

area, it is not reasonable to preclude all development on portions of the site 

inhabited by this plant community; but disturbance will be minimized on the 

area. 

A 3-season vegetation survey was completed on the STM site in May 2002. 

Details of the survey are presented in Section 5.10.1. The survey found no 

rare/or imperiled plant species on the site, but areas of mixed foothills 

shrublands (also called tall upland shrubland), were identified along the top of 

the mesa within the Conservation Easement area. That natural community is 

listed as rare and imperiled by the Colorado Natural Heritage program. It is 

within a designated conservation easement area where no development will 

occur except planned trails being established by Jefferson County Open Space 

(See Section 6.0 for a discussion of trails) . 

5.12.2

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Permitting

NREL has no permitting requirements for this area of environmental 

management. 

5.12.3 2003 Activities

As reported in Section 5.11.3, a site-wide wildlife survey of the STM site is 

ongoing. To date, no threatened or endangered species have been identified. 

5.13 Wetlands/Floodplains 

Limited wetland areas totaling less than 0.3 ha (0.75 ac) occur on the STM site 

in the drainage bottom located north of the Visitor’s Center. These are narrow, 

linear wetlands supporting spikerush, baltic rush, sedges, bluegrass, hemlock, 

and field mint. These wetlands will be protected from adverse impacts as site 

development continues. 

Wetland areas at the NWTC are extremely limited in extent as well. These 

areas, along the site’s eastern boundary, total less than 0.4 ha (1 ac). 

According to maps generated by the Jefferson County Department of 

Highways and Transportation as part of its urban drainage studies, NREL's 

STM site does not contain any floodplains, and no floodplains have been 

identified at the NWTC. As a best-management practice, however, all 

construction activities that may cross a drainage channel are designed to meet 

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

100-year flood). 

5.14 Cultural Resources 

5.14.1 Program Management

Cultural resources are defined as any prehistoric or historic district, site, or 

building, structure, or object considered important to a culture, subculture, or 

community for scientific, traditional, religious or any other reason. Cultural 

resources can be divided into three major categories: 

1. Prehistoric and historic archaeological resources. 

2. Architectural resources. 

3. Traditional cultural resources. 

Prehistoric and historic archaeological resources are locations where human 

activity measurably altered the earth or left deposits of physical remains (e.g., 

arrowheads, bottles). Prehistoric resources that predate the advent of written 

records in a region range from a scatter composed of a few artifacts to village 

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sites and rock art. Historic resources may include campsites, roads, fences, 

trails, dumps, battlegrounds, mines, and a variety of other features. 

Architectural resources include standing buildings, dams, canals, bridges, and 

other structures of historic or aesthetic significance. Architectural resources 

generally must be more than 50 years old to be considered for protection under 

existing cultural resource laws. However, more recent structures, such as Cold 

War facilities, may warrant protection if they manifest the potential to gain 

significance in the future. 

A traditional cultural resource can be defined as a property that is eligible for 

inclusion in the National Register because of its association with cultural 

practices or beliefs of a living community that are rooted in the community’s 

history and are important in maintaining the continuing cultural identify of the 

community. Traditional resources can include archaeological resources, 

buildings, neighborhoods, prominent topographic features, habitats, plants, 

animals, and minerals that Native Americans or other groups consider essential 

for the persistence of their traditional culture. 

Cultural resources are protected under Section 106 of the National Historic 

Preservation Act (NHPA) of 1966, as amended. Significant cultural resources 

are either eligible for, or listed on, the National Register. 

Three formal surveys of historic and cultural resources have been performed 

on the STM site. These surveys were completed in 1980, 1987, and 2003 (see 

Section 5.14.3 for more detail about the 2003 survey). Two additional surveys 

of the Camp George West district involving the STM site have also been 

conducted. 

As a result of these STM surveys, three historical sites were recognized as 

significant cultural resources that should be preserved. These sites include an 

open-air amphitheater, a stone bridge spanning a natural drainage channel 

adjacent to the amphitheater, and a stone and concrete ammunition bunker 

below the amphitheater site. The three structures were constructed during the 

Works Progress Administration (WPA) era in the 1930s. Through NREL's 

efforts, these sites have been added to the National Register of Historic Places 

(National Register), with the amphitheater and stone footbridge listed together 

as a single site. NREL also participated in an interagency survey of South 

Table Mountain and Camp George West to identify historic structures and sites 

eligible for nomination to the National Register. 

The Camp George West Historic District, located south of the STM Site’s 

Denver West Parkway, was also listed, and includes the 25-acre parcel recently 

transferred to NREL. Two architectural resources, firing range lines and low 

rock walls, have been identified on that 25-acre parcel on NREL’s STM Site 

that contribute to the Camp George West Historic District. 

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An archaeological survey of the NWTC site was conducted in support of the 

1996 Environmental Assessment to supplement previous surveys so there were 

no gaps in cultural surveys on the site. No significant historical or 

archaeological resources were identified. However, the wooded ridge area on 

the west portion of the site was identified as a location with potential for 

cultural resources, so further testing or observation during excavation would be 

done should there be any future need for work in the utility corridor in the 

vicinity of the ridge. 

Should any evidence of cultural resources be discovered at any time during 

ground disturbing activities at the STM or NWTC sites, NREL will stop all 

work would stop in the vicinity until a qualified archaeologist completely 

evaluates the significance of the find. 

5.14.2 Permitting

NREL has no permitting requirements for this area of environmental 

management. 

5.14.3 2003 Activities

During 2003, a cultural resources survey was conducted of the 25-acre parcel 

south of Denver West Parkway on the STM Site. The survey found that the 

parcel has the potential for archaeological buried deposits and should be 

systematically tested prior to construction. 

The Camp George West Historic District overlaps the NREL STM property by 

25 acres. Two contributing resources occur within those 25 acres. 

Contributing resources are those features within a historic district that 

contribute to the districts overall eligibility for the National Register. The 

contributing resources are as follows: 

• Two firing lines located on the 25 acres. There are also firing lines located 

south of the NREL property on land owned by Jefferson County Open 

Space and proposed for development as the Camp George West Park. 

• Portions of a low rock wall are also present on the 25 acres. There is also a 

rock wall located south of the NREL property. 

DOE has consulted with the State Historic Preservation Officer (SHPO) over 

the resources newly discovered on the 25 acres. DOE and the SHPO have 

entered into a Memorandum of Understanding in which DOE agrees to 

perform further surveys to fully document the resources on the 25 acres prior 

to any development of the parcel.

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5.15 National Environmental Policy Act (NEPA) 

5.15.1 Program Management

Management in this area is consistent with NREL’s NEPA Implementation 

Program (6-2.2). 

As a federal agency, DOE is obligated to comply with NEPA by evaluating the 

potential for environmental impacts prior to conducting its activities. 

Regulations for compliance with the Act are issued by the Council of

Environmental Quality (CEQ). DOE has also issued implementing regulations 

at 10 CFR that complement the CEQ requirements. DOE has written a site 

wide Environmental Assessment (EA) for its activity at the STM Site and

DWOP, and separate EAs for the NWTC and JSF activities.

NREL has established procedures, with the approval of the DOE GO, to assist 

DOE in meeting their NEPA obligation. Proposed activities that will be 

conducted off of NREL’s four sites are evaluated for their potential 

environmental effects using the appropriate level of NEPA review, in 

conjunction with GO. 

The NREL NEPA Handbook has been prepared to provide NREL project 

managers and procurement specialists with guidance on implementing the 

NEPA procedures. 

5.15.2 Permitting

NREL has no permitting requirements under NEPA. 

5.15.3 2003 Activities

During 2003, activity continued on developing an EA for one potential site for 

a geothermal direct use project (district heating system), in Canby, California. 

The EA process was initiated in 2002 for the Canby, California site, and the 

EA was completed and a Finding of No Significant Impact (FONSI) signed in 

early 2003. 

In 2001 a subcontractor was hired and began writing the new Site wide EA for 

the NWTC, and the EA was completed in May 2002. 

Internal scoping began in 2001 for the new Site wide EA for the STM site. In 

2002 the contractor was hired and began writing the EA. The EA for the STM 

site was completed and a FONSI signed in 2003. 

In addition to the EA activity, numerous NEPA reviews of both onsite and 

offsite activities occurred through completion of NREL Environmental 

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Checklists. As outlined in NREL’s NEPA implementation procedures, these 

reviews were coordinated with NREL project managers, subcontracting staff, 

the NREL NEPA Coordinator, and the DOE Golden Field Office NEPA 

Compliance Officer. NEPA requirements were also coordinated with future 

program planning through interaction between NREL’s ES&S Office Director 

and NREL’s Technology Program and Project Managers, as well as through 

participation in the NREL management Annual Operating Plan process and 

other reviews of proposed projects for the upcoming year. 

5.16 Radiological Program 

5.16.1 Program Management

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

Quality Protection (6-2.5), and Radiological Control (6-4.5). 

All radioactive material at NREL facilities is handled according to NREL’s 

Radiological Control Program. Elements of the program include a radiological 

control organization, a radiation safety policy and control manual, safe 

operating procedures, safe work permits, radiological control areas and 

postings, monitoring, training, and purchasing controls for radioactive 

materials.

There are no nuclear operations at NREL sites. All of NREL’s radiation 

sources are used/stored in facilities located on the STM site. These include four 

x-ray diffraction machines at the SERF and two sealed source level gauges at 

the AFUF used on pilot scale processes to measure the level of material inside 

process tanks. In addition, two laboratories at the Field Test Laboratory 

Building (FTLB), on the STM site, occasionally use small quantities of 

radioisotopes for biological or chemical labeling. 

The four X-ray diffraction machines are registered with the State of Colorado 

and are inspected every two years by a state-licensed surveyor. The surveyor 

inspects and certifies the X-ray machines and audits NREL's program for 

radiation safety in connection with operating the machines. 

Monitoring of equipment and facilities for removable contamination is 

performed in the laboratories where radioisotopes are used. Wipe tests are 

performed on any laboratory surfaces that could have become contaminated by 

the radioisotope work at least monthly and more frequently if needed. These 

wipes are analyzed using a scintillation counter. 

U.S. Department of Energy (DOE) Order 5400.5, “Radiation Protection of the 

Public and the Environment,” established radiation emission limits for DOE 

facilities. Such emissions are also regulated by Section 112 of the Clean Air 

Act as implemented by 40 CFR 61, Subpart H, established by the U.S. 

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Environmental Protection Agency (EPA). According to 40 CFR 61, Subpart 

H, all DOE facilities, including NREL, must annually demonstrate compliance 

with the radionuclide emission limit to the ambient air not exceeding an 

amount that would result in any member of the public receiving an effective 

dose of 10 mrem/yr 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 National 

Emission Standards for Hazardous Air Pollutants (NESHAP) in 40 CFR 61, 

Subpart H, by utilizing the EPA’s COMPLY computer model to determine the 

effective dose equivalent to the public. 

All radioactive waste generated during NREL activities is classified as lowlevel waste. Waste from the STM site is temporarily stored at the Waste 

Handling Facility (WHF) until disposal is arranged at an offsite facility 

permitted to accept low-level radioactive waste. 

5.16.2 Permitting

NREL does not have a radioactive materials license from the State of 

Colorado, as the Laboratory is currently under DOE jurisdiction for radioactive 

materials handling. 

5.16.3 2003 Activities

During 2003, the total quantity of radioisotopes used was 3.287 mCi used in 

one laboratory at NREL’s FTLB. Any emissions generated by this work were 

emitted by a laboratory hood exhaust. In addition, much of NREL’s 

radioisotope inventory (including waste quantities) is in containers on which 

the manufacturer’s original seal was broken. In 2003 the potential dose to the 

public was calculated as though the contents of all unsealed containers was 

exhausted to the atmosphere, including the amount actually used in 2003. P-32 

and S-35 waste that is stored in the Waste Handling Facility and has decayed 

past ten half-lives was not included in this calculation. 

The distance from the source in the FTLB to the nearest potential receptor is 

119 m (fence line of nearest resident). For the WHF, the distance from the 

source to the nearest potential receptor is 311 m.

According to the COMPLY computer model, the potential dose to the nearest 

member of the public is 0.046 mrem/yr, below the emission limit of 10 

mrem/yr, and NREL is in compliance with the NESHAP for radionuclides. 

Because the dose is calculated rather than measured, it represents a potential or 

estimated rather than an actual dose.

The resulting calculated off-site whole body doses are small, but are still likely 

overestimates of potential radionuclide doses. The COMPLY formula assumes 

NREL Environmental Performance Report- 2003 

 

 Page 64
that the entire quantity of the radionuclide in all open containers was released, 

and that the receptor raises and consumes all his/her own milk, meat, and 

vegetables at home. These assumptions are extremely conservative. 

The total amount of low-level radioactive waste shipped off-site for disposal in 

2003 was 209.46 MBq (5.655 mCi) of Carbon-14 and tritium (H-3) waste 

material.

In 2003 there was no construction or modifications to the labs where 

radioisotopes are used. 

There were no unplanned releases of radioisotopes in 2003. 

NREL Environmental Performance Report- 2003 

 

 Page 65
6 CONSERVATION EASEMENT LANDS 

During 1999, DOE placed 177 acres of the STM site in a Conservation Easement. The 

purpose of the Conservation Easement is to preserve the natural character of the property, 

including its visual, biological, and recreational resources, especially in relation to the 

changing land uses adjacent to the NREL site and within the region. 

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 South Table Mountain area and the sustainable habitat 

for biodiverse vegetation, birds, and terrestrial animals; 

• Ensure the scenic and biological integration with adjoining open-space land; 

• Prevent further industrial, commercial, or residential development of the 

conservation easement property; and 

• Preserve the conservation easement property as natural open space. 

A baseline inventory of the property was prepared in June 1999 to document the current 

condition of the easement property and to assess the conservation value of the property 

(Department of Energy, Golden Field Office, 1999). The baseline inventory includes a 

description of the geographical setting and adjacent property owners, access and use of the 

property by the public, and a description of the existing environmental conditions of the 

property (geology, hydrology, vegetation, wildlife, cultural resources). There are also photos 

incorporated into the report that document the condition of the property. 

2003 Assessment of the Property

During 2003 there was no NREL activity on the conservation easement property having the 

potential to degrade the environmental condition of the property. A site inspection was 

conducted by Jefferson County Open Space, NREL, and DOE during the summer of 2003. 

No degraded conditions or other environmental issues were found. Photos taken in 2003 

showing the representative areas of the easement lands are included in Section 2 of this report. 

Jefferson County Open Space has the responsibility to establish and maintain formal trails on 

the Conservation Easement Property. The trail plan calls for establishing trails in phases. The 

first phase began in 2004, with Jefferson County Open Space installing two trails from 

Denver West Parkway (near the NREL Site Entrance) to the mesa top. 

NREL Environmental Performance Report- 2003 

 

 Page 66
7 REFERENCES 

Armstrong, D.,C. Bock, T. Piaggio, and E. Schmidt (2001). NWTC Site wide Bat and Avian 

Impact Study Plan: May 1, 2001-July 31, 2002. 

EG&G Rocky Flats, Inc., (1992). Rocky Flats Plant Site Environmental Report, January 

Through December 1992. Golden, Colorado. 

Handex of Colorado, Inc. (1997). Groundwater Monitoring Report, South Table Mountain 

Site. Golden, Colorado 

National Renewable Energy Laboratory, (Draft). ES&H Program Number 6-2.12, 

Weed Management Program, STM Site. Golden, Colorado. 

National Renewable Energy Laboratory, (1997). National Renewable Energy Laboratory 

Environmental Report for 1995 and 1996. Golden, Colorado. 

National Renewable Energy Laboratory, (1999a). National Renewable Energy 

Laboratory Five-Year Plan, 2000-2004. Golden, Colorado.

National Renewable Energy Laboratory, (1999b). NREL Policy Number 6-2, Environmental 

Management. Golden, Colorado. 

National Renewable Energy Laboratory, (1999c). NREL Policy Number 6-6, Risk Assessment. 

Golden, Colorado. 

Piaggio, T., Doctoral Candidate, Environmental, Population, and Organismic Biology, 

University of Colorado, Boulder, telephone, communication. July 18, 2001. 

Plantae Consulting Services, (2000). Vegetation Survey, NREL National Wind Technology 

Center. Boulder, Colorado. 

Plantae Consulting Services, (2002). Vegetation Survey, NREL South Table Mountain Site. 

Boulder, Colorado 

Rust Environment & Infrastructure, Inc., (1993). Water Quality Monitoring, National Wind 

Technology Center. Englewood, Colorado. 

Rust Environment & Infrastructure, Inc., (1994a). Final Report, Baseline Surface Water 

Monitoring Program: 1993. Englewood, Colorado. 

Rust Environment & Infrastructure, Inc., (1995a). Report, Wastewater Monitoring Program, 

Fourth Quarter, 1994 and Annual Report. Englewood, Colorado. 

NREL Environmental Performance Report- 2003 

 

 Page 67
Rust Environment & Infrastructure, Inc., (1995b). Final Report, Ground Water Monitoring, 

Third Quarter, 1994 and Fourth Annual Report, South Table Mountain Site. Englewood, 

Colorado. 

Schmidt, E., Piaggio, A.J., Bock, C.E., Armstrong, D.M, (January 2003). National Wind 

Technology Center Site Environmental Assessment: Bird and Bat Use and Fatalities – Final 

Report. University of Colorado, Boulder, Colorado. 

U.S. Department of Energy, (1998). Environmental Assessment, Right-of-Way Easement For 

Public Service Company of Colorado at the South Table Mountain Site, Golden, Colorado. 

DOE/EA-1254. 

U.S. Department of Energy, Golden Field Office, (1999). National Renewable Energy 

Laboratory (NREL) Site Conservation Easement Baseline Inventory. Golden, Colorado. 

U.S. Department of Energy, (1993). Site wide Environmental Assessment for the National 

Renewable Energy Laboratory, Golden, Colorado. DOE/EA-0850. 

U.S. Department of Energy, (2002). Site-Wide Environmental Assessment of National 

Renewable Energy Laboratory’s National Wind Technology Center. DOE/EA 1378. 

U.S. Department of Energy, (2003). Site-Wide Environmental Assessment of the National 

Renewable Energy Laboratory’s South Table Mountain Complex. DOE/EA 1440. 

NREL Environmental Performance Report- 2003 

 

 Page 68
NREL Environmental Performance Report- 2003 

 

 Page 69

8 APPENDICES 

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

Appendix B – Above Ground Storage Tank Inventory 

APPENDIX A – SUMMARY OF NREL ENVIRONMENTAL PERMITS, REGISTRATIONS, NOTIFICAT

Tracking

Number 

Permit or 

Registration

Number 

Permit or 

Reg. Holder

Permit Type Permit Description Issuing 

Agency Name

Location

Description 

Status/ Exp

Dat

Permits

1 00JE0010L DOE AIR Air Emission Permit

for Land Development(fugitive dust fromconstruction activities)

Colorado Dept. of PublicHealth and Environment(CDPHE) 

NWTC site 1/31/05 (issu

3/1/00)

2 00JE0009L DOE AIR Air Emission Permit

for Land Development(fugitive dust fromconstruction activities)

CDPHE STM site 1/31/05 (issu

3/1/00)

7 37232 SERI Groundwater

Monitoring Well 

Permit to Construct a Well (MW-1)

Colo. Div. OfWater Resources 

STM construction

complete, penumber activwell is close

8 37229 SERI Groundwater

Monitoring Well 

Permit to Construct a Well (MW-2)

Colo. Div. OfWater Resources 

STM construction

complete, penumber activwell is close

9 37228 SERI Groundwater

Monitoring Well 

Permit to Construct a Well (MW-3)

Colo. Div. OfWater Resources 

STM construction

complete, penumber activwell is close

10 37231 SERI Groundwater

Monitoring Well 

Permit to Construct a Well (MW-4)

Colo. Div. OfWater Resources 

STM construction

complete, penumber activwell is close

11 37230 SERI Groundwater

Monitoring Well 

Permit to Construct a Well (MW-5)

Colo. Div. OfWater Resources 

STM construction

complete, penumber activwell is close

NREL Environmental Performance Report- 2003 Pa
Tracking

Number 

Permit or 

Registration

Number 

Permit or 

Reg. Holder

Permit Type Permit Description Issuing 

Agency Name

Location

Description 

Status/ Exp

Dat

12 214960 NREL/DOE Groundwater

Monitoring Well 

Permit to Construct a Well (MW-11)

Colo. Div. OfWater Resources 

STM construction

complete, penumber activwell is close

13 214961 NREL/DOE Groundwater

Monitoring Well 

Permit to Construct a Well (MW-10)

Colo. Div. OfWater Resources 

STM construction

complete, penumber activwell is close

14 214962 NREL/DOE Groundwater

Monitoring Well 

Permit to Construct a Well (MW-09)

Colo Div. Of Water Resources 

STM construction

complete, penumber activwell is close

15 99JE0400 NREL/DOE Air TCPDU air emissions CDPHE STM initial approv

issued 7/20/2

16 20030373 thru

20030378

NREL Permit Hazardous material

storage and use permit

West Metro Fire Protection District 

6 STM facilities 

(Building 16, 

WHF, SERF,

FTLB, AFUF,

Shipping & 

Receiving 

Facility) 

2004 

Notifications and Registrations

17 PWSID Number

230860

DOE DRINKING

WATER 

Non-communitysupply of hauled water from a surface water source 

CDPHE NWTC site N/A 

NREL Environmental Performance Report- 2003 Pa
Tracking

Number 

Permit or 

Registration

Number 

Permit or 

Reg. Holder

Permit Type Permit 

Description 

Issuing 

Agency Name

Location

Description 

Status/ Exp

Dat

18 CO4890000017 DOE HAZARDOUS

WASTE 

Notification ofRegulated Waste Activity 

CDPHE DWOP update recom

every 3-5 yesooner if subchanges in aoccur. Last 7/97

19 CO3890090076 DOE HAZARDOUS

WASTE 

Notification ofRegulated Waste Activity 

CDPHE STM update recom

every 3-5 yesooner if subchanges in aoccur. Last 7/97

20 COD980805162 DOE HAZARDOUS

WASTE 

Notification ofRegulated Waste Activity 

CDPHE JSF update recom

every 3-5 yesooner if subchanges in aoccur. Last 7/97

21 COD983802448 DOE HAZARDOUS

WASTE 

Notification ofRegulated Waste Activity 

CDPHE NWTC update recom

every 3-5 yesooner if subchanges in aoccur. Last 7/97

22 COR000207563 DOE HAZARDOUS

WASTE 

Notification ofRegulated Waste Activity 

CDPHE ReFUEL Issued Jan 9

23 001 and 002 DOE AIR: OZONE 

DEPLETING SUBSTANCES

Registration of stationaryappliances (2SERF chillers) 

CDPHE SERF annual renew

July 1 

24 N/A DOE AIR: OZONE

DEPLETING SUBSTANCES

Facility Notification

CDPHE STM, NWTC annual notifi

and fee due December 1 

NREL Environmental Performance Report- 2003 Pa
Tracking

Number 

Permit or 

Registration

Number 

Permit or 

Reg. Holder

Permit Type Permit 

Description 

Issuing 

Agency Name

Location

Description 

Status/ Exp

Dat

25 001 DOE AIR: OZONE

DEPLETING SUBSTANCES

Registration of stationaryappliance (chiller in DWOP) 

CDPHE DWOP annual renew

July 1 

26 2873-001 and

2873-002 

DOE ABOVE GROUND

STORAGE TANK

Registration of aboveground storage tanks 

Colorado Dept. of Labor

STM--PDU 

Ethanol Storage 

Tank, SERF 

Emergency

Generator Tank

annual registand fee, dueApril/May 

27 93000378 DOE Historic Registration National Register 

of Historic Places

National ParkService 

Colorado

Amphitheater 

no expiration 

28 93000379 DOE Historic Registration National Register 

of Historic Places

National ParkService 

Ammunition 

Igloo 

no expiration 

29 AFP-CO-00255 DOE Alcohol (not an

environmentalpermit) 

AlcoholProducer's Permit

Bureau ofAlcohol,Tobacco, and Firearms

AFUF (PDU) annual renew

July 1 

30 TF-CO-0331 DOE Alcohol (not an

environmentalpermit) 

Industrial AlcoholUser Permit 

Bureau ofAlcohol,Tobacco, and Firearms

NREL-wide annual renew

July 1 

31 N/A NREL Transportation Hazardous

Material Transportation 

U.S.Department of Transportation 

NREL-wide annual renew

fee 

32 76381 NREL Registration X-Ray Machine

CertificationReport 

CDPHE SERF Expires 6/06 

33 68808

NREL 

Registration X-Ray Machine

CertificationReport 

CDPHE SERF Expires 2/05 

34 61007 NREL Registration X-Ray Machine

CertificationReport 

CDPHE SERF Expires 11/0

NREL Environmental Performance Report- 2003 Pa
Tracking

Number 

Permit or 

Registration

Number 

Permit or 

Reg. Holder

Permit Type Permit 

Description 

Issuing 

Agency Name

Location

Description 

Status/ Exp

Dat

35 7309L NREL Registration X-Ray Machine

CertificationReport 

CDPHE SERF Expires 11/0

NREL Environmental Performance Report- 2003 Pa
APPENDIX B - ABOVEGROUND STORAGE TANK INVENTORY 

Tank

ID

Size Contents Class Use Date On-Line S

S

No. 1 1010 gallons Diesel II FTLB Emergency Generator

(UST) 

1983 C

No. 2 800 gallons Diesel II SERF Emergency Generator 10/93 In

Double-walled, interstitial monitor, no secondary containment 

No. 3 6000 gallons Ethanol, 50% IC PDU Ethanol Storage 12/95 In

Single-walled, remote monitoring, 7500 gal concrete containment 

No. 4 564 gallons Diesel II PDU Emergency Generator 8/95 In- 

Double-walled, interstitial monitor, no secondary containment 

No. 5 560 gallons Diesel II FTLB Emergency Generator 6/96 In

Double-walled, interstitial monitor, concrete secondary containment 

No. 6 400 gallons Diesel II IUF Emergency Generator 3/97 In

 Double-walled, no secondary containment

No. 7 80 gallons Diesel II 251 Emergency Generator 1980 No. 8 500 gallons Diesel II NWTC Hybrid Power Test

Bed (HBTB) Convault, popup interstitial monitor 

 6/97 In

No. 9 500 gallons Diesel II Bldg 16 Emergency Generator

Single-walled, no interstitial 

monitor, 537-gal secondary

containment

1990 In

No. 10 100 gallons Diesel II NWTC NPS Daytank

Double-walled, no interstitial monitor 

6/96 In

NREL Environmental Performance Report- 2003 Pa
Tank

ID

Size Contents Class Use Date On-Line S

S

No. 11 100 gallons Diesel II NWTC HPTB North Daytank

(SIM#1) Single-walled, nointerstitial monitor 

6/97 In-Se

No. 12 100 gallons Diesel II NWTC HPTB South Daytank

(SIM#2) Single-walled, nointerstitial monitor 

6/97 In-Se

No. 13 50 gallons Diesel II SunWize (West of HPTB) 

Single-walled, 36-gal steelcatch basin 

5/98 NC

No. 14 200 gallons Diesel II 251 Stand-by Generator 

Double-walled, no interstitial monitor 

9/98 In-Se

No. 15 100 gallons Diesel II AFUF Emergency Generator

Double-walled, no interstitial monitor 

6/94 TC 

No. 16 50 gallons Diesel II Bergey Hybrid System

(Site 1.8) Double-walled, no interstitial monitor 

1/00 NC

No. 17 173 gallons Diesel II NWTC Hybrid 80 (Sim #4) 

Double-walled, no interstitial monitor 

3/01 In-Se

No. 18 336 gallons Diesel II NWTC Hybrid 125 (Sim #3) 

Double-walled, no interstitial monitor 

3/01 In-Se

No. 19 500 gallons Propane - NWTC East Met Tower - No. 20 500 gallons Propane - NWTC West Met Tower - 

NREL Environmental Performance Report- 2003 Pa
Tank

ID

Size Contents Class Use Date On-Line Serv

Statu

No. 21 500 gallons Propane - Capstone Micoturbine - 

Service Status  In-Service (IS)  Out-of-Service (OS) 

Temporary Closure (TC)Permanent Closure (PC) 

 Change-In-Service (CIS) 

 NC—not covered by this Program

NREL Environmental Performance Report- 2003 Pa