NATIONAL RENEWABLE ENERGY LABORATORY 

ENVIRONMENTAL PERFORMANCE REPORT for 2004 

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

Prepared by: 

Environment, Safety & Health 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 2005 
NREL Environmental Performance Report- 2004

 

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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...............................................................................................28

4.3 Assessment and Improvement ............................................................................................................30

4.4 Sustainability and the Environmental Management System ..............................................................33

5 ENVIRONMENTAL PROGRAMS...........................................................................................................34

5.1 Air Quality Protection........................................................................................................................34

5.1.1 Program Management ................................................................................................................34

5.1.2 Permitting...................................................................................................................................35

5.1.3 2004 Activities...........................................................................................................................36

5.2 Drinking Water ..................................................................................................................................36

5.2.1 Program Management ................................................................................................................36

5.2.2 Permitting...................................................................................................................................37

5.2.3 2004 Activities...........................................................................................................................37

5.3 Ground Water Protection...................................................................................................................38

5.3.1 Program Management ................................................................................................................38

5.3.2 Permitting...................................................................................................................................40

5.3.3 2004 Activities...........................................................................................................................40

5.4 Wastewater Discharge .......................................................................................................................40

5.4.1 Program Management ................................................................................................................40

5.4.2 Permitting...................................................................................................................................41

5.4.3 2004 Activities...........................................................................................................................41

5.5 Surface Water Protection (Storm Water and Erosion Control).........................................................41

5.5.1 Program Management ................................................................................................................41

5.5.2 Permitting...................................................................................................................................42

5.5.3 2004 Activities...........................................................................................................................42

5.6 Waste Management............................................................................................................................43

5.6.1 Program Management ................................................................................................................43

5.6.2 Permitting...................................................................................................................................43

5.6.3 2004 Activities...........................................................................................................................44

5.7 Storage Tanks (Underground and Above Ground)............................................................................44

5.7.1 Program Management ................................................................................................................44

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5.7.2 Permitting...................................................................................................................................45

5.7.3 2004 Activities...........................................................................................................................45

5.8 Hazardous Materials Management....................................................................................................45

5.8.1 Program Management ................................................................................................................45

5.8.2 Permitting...................................................................................................................................47

5.8.3 2004 Activities...........................................................................................................................47

5.9 Pollution Prevention & Sustainability ...............................................................................................48

5.9.1 Waste Minimization, Recycling, and Green Purchasing............................................................48

5.9.2 Vehicles......................................................................................................................................50

FIGURE 5.1: NREL TRANSPORTATION BY MODE................................................................................................52

5.9.3 Energy ........................................................................................................................................52

5.9.4 Renewable Energy .....................................................................................................................54

5.9.5 Water Conservation....................................................................................................................55

5.9.6 Sustainable Building Design ......................................................................................................56

5.9.7 Technical Assistance and Outreach............................................................................................56

5.10 Vegetation ..........................................................................................................................................57

5.10.1 Program Management ................................................................................................................57

5.10.2 Permitting...................................................................................................................................59

5.10.3 2004 Activities...........................................................................................................................60

5.11 Wildlife...............................................................................................................................................60

5.11.1 Program Management ................................................................................................................60

5.11.2 Permitting...................................................................................................................................61

5.11.3 2004 Activities...........................................................................................................................62

5.12 Endangered Species/Species of Concern ...........................................................................................65

5.12.1 Program Management ................................................................................................................65

5.12.2 Permitting...................................................................................................................................66

5.12.3 2003 Activities...........................................................................................................................66

5.13 Wetlands/Floodplains........................................................................................................................66

5.14 Cultural Resources.............................................................................................................................67

5.14.1 Program Management ................................................................................................................67

5.14.2 Permitting...................................................................................................................................69

5.14.3 2004-5 Activities........................................................................................................................69

5.15 National Environmental Policy Act (NEPA)......................................................................................69

5.15.1 Program Management ................................................................................................................69

5.15.2 Permitting...................................................................................................................................70

5.15.3 2004 Activities...........................................................................................................................70

5.16 Radiological Program........................................................................................................................70

5.16.1 Program Management ................................................................................................................70

5.16.2 Permitting...................................................................................................................................72

5.16.3 2004 Activities...........................................................................................................................72

6 CONSERVATION EASEMENT LANDS .................................................................................................73

7 REFERENCES.............................................................................................................................................74

8 APPENDICES..............................................................................................................................................76

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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 

Figure 5.1 – NREL Transportation by Mode .................................................................... 51 

Figure 5.2 – NWTC Vegetation ....................................................................................... 58 

Figure 5.3 – STM Site Wildlife ........................................................................................ 64 

Figure 5.4 – STM Site Wildlife ........................................................................................ 64 

Figure 5.5 – STM Site Wildlife ........................................................................................ 66 

 

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 2004. It is organized according to the different environmental media 

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

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

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

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

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

basis for the program overview. 

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

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

guidelines for the 2004 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 the private sector to address the nation’s energy and 

environmental goals. 

NREL fulfills its mission through technology portfolios; a brief description of each 

major technology area follows. 

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- 2004

 

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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 develop resource information for solar, 

wind, biomass, and geothermal energy applications. 

Site and Facility Description

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

the city of Denver, and one within the boundaries of the City and County of Denver. 

The four facilities in Jefferson County include the Denver West Office Park 

(DWOP), the South Table Mountain site (STM), the Joyce Street Facility (JSF and 

the National Wind Technology Center (NWTC).The Renewable Fuels and Lubricants 

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

Joyce Street

Facility

National Wind 

Technology Center 

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N

 

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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

N
Site Environmental Conditions/Features

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

end of this section. Figures 1.5, 1.6, 1.7 and 1.8 show the South Table Mountain and 

Denver West Office Park sites, and Figures 1.9 and 1.10 provide images of 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 from the mesa top and across the 

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

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

the site ultimately flows into Lena Gulch. 

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

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

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

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

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

season. 

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 existing 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. Amphibian species are known to inhabit the area 

as well. 

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 constructing 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 

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 25-acre parcel, 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 2004.

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 

(CGP) 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 2004, no activities requiring permit coverage were 

conducted on the STM site. Excel Energy ran a gas pipeline across the NWTC site 

during the reporting period, and both a Notice of Intent and a Notice of Termination 

were filed with EPA for coverage under the CGP. 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 

NREL Environmental Performance Report- 2004

 

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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. 

In 2004, 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 jurisdictional fire department. 

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

any materials, and during 2004, 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 

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

the Native American Graves Protection and Repatriation Act, protect cultural 

resources. NREL has two sites listed on the National Register of Historic Places on its 

STM Site. There are no known eligible sites at the NWTC. In 2005, the DOE Golden 

Field Office and NREL conducted additional surveying of some of the features 

remaining from the former Camp George West. NREL’s Cultural Resources program 

and additional details regarding the 2005 survey will be described in the 2005 report. 

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.

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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 

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 three incidents with environmental implications during 2004 at the STM 

site. 

At the STM site on March 11, 2004 at NREL’s Thermal Test Facility, approximately

20 gallons of dilute propylene glycol overflowed from a catch basin at an outdoor 

boiler pad and seeped into the ground. The overflow resulted from a malfunction in a 

hot water recirculation loop in which the pressure relief valve stuck open. All of the 

solution percolated into the ground before reaching surface water; no soil or 

groundwater contamination occurred because of the low environmental toxicity of 

propylene glycol. The direct cause of the overflow was a failed pressure relief valve. 

In addition, a computer software crash contributed to the problem, and the root cause 

was determined to be the lack of any way of knowing if a pressure relief event is 

occurring from inside the TTF. Corrective actions taken included modifying

procedures to require the operator to shutdown the boiler in the event of a software or

computer malfunction or power failure, adding a temperature limit controller to 

automatically shut down the boiler if a pressure relief event is occurring, and replacing

the faulty pressure relief valve combined with inspecting it more frequently. 

At the STM site on May 6, 2004, natural gas accumulated (at non-hazardous levels) 

inside a laboratory at the Field Test Laboratory Building due to a partially open

laboratory gas valve in a biological safety cabinet. The cabinet was cluttered, 

increasing the potential that a gas valve could be inadvertently opened. The valve was 

shut off, gas monitoring was done; there was no detectable concentration by the time 

ES&H staff arrived with the meter. The lab was closed and allowed to ventilate

normally. To minimize the chance of recurrence, the cabinet was cleared of unneeded 

items and electrical cords were contained.

At the STM site on June 21, 2004, a researcher at the FTLB set a controller for a 

solvent drying activity at an excessively high setting to promote rapid heat up of the 

apparatus. The researcher left the lab, forgetting to turn the setting on the equipment 

back down to a low level. The apparatus overheated, resulting in a brief, small, 

contained flame. Any emissions resulting from the fire were negligible, as the

quantities of materials in the apparatus were very small (e.g. 400 ml of solvent was 

used). Corrective actions included revising procedures for conducting work and 

communication between organizations using the equipment, additional training of staff 

operating the equipment, and additional oversight. The need for over temperature 

controls on the apparatus was also being considered. 

NREL Environmental Performance Report- 2004

 

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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. To this end, NREL is committed to: 

• Pollution Prevention. Incorporating pollution prevention practices in research

and support activities. 

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

environmental management system (EMS). 

• Campus. Managing the impact on the environment caused by the placement and

general design of NREL structures; maintaining, protecting, and restoring natural 

and landscaped environments to sustain natural and native ecological systems,

both on and adjacent to NREL campuses. 

• Water. Reducing water consumption and managing water discharges from all 

NREL sites. 

• Electricity/Natural Gas. Reducing energy use in building designs and 

operations; within available funds, using cost effective renewable energy sources 

for remaining energy needs; and purchasing power generated by renewable energy

sources. 

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

reducing the use of fossil-based gasoline/diesel fuel for NREL onsite and local

operations through the use of alternative fuel vehicles or hybrids; and increasing 

the use of video and teleconferencing to reduce the environmental impacts of air 

travel. 

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

reusing, and recycling materials needed for Laboratory operations; increasing the

purchase and use of environmentally sensitive products and products with recycled

content. 

• Environmental Management. Providing an environment that promotes 

efficiency, effectiveness, and sustainability, and encourages the creativity and 

personal motivation required for excellence in scientific, engineering, technology

development, and support functions. 

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

sustainability activities, including a method for interaction and feedback;

educating workers about participating and contributing to sustainable activities.

Informing workers and the public about NREL’s environmental performance, 

including a method for interaction and feedback. 

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

other environmental requirements and exceeding those requirements, when 

feasible, by implementing environmental best management practices.

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 & Health (ES&H) 

Office staff and personnel 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 an

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

Environmental Management Policy (6-2) and 19 supporting laboratory-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). 

Notable 2004-5 Activities

In early 2004, NREL was accepted into the EPA National Environmental Performance

Track (NEPT) Program and the Colorado Environmental Leadership Program (CELP). 

The NEPT program is a national voluntary partnership between EPA and participating

private and public U.S. facilities that recognizes environmental leadership and 

performance; the CELP program is a similar state-level voluntary partnership. As a

component of these programs, each year NREL sets voluntary performance goals in an 

effort to further enhance environmental performance at the Laboratory. NREL was 

one of the first two DOE national laboratories to be accepted into NEPT. 

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

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

In August 2005, representatives from EPA Region 8 and the Colorado Department of 

Public Health and Environment (CDPHE) visited NREL to review the Laboratory’s

commitment to the NEPT and CELP programs. During the site visit, EPA and 

CDPHE were impressed with NREL’s commitment to going beyond compliance in the 

NREL Environmental Performance Report- 2004

 

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areas of environmental performance and sustainability. EPA found NREL’s

sustainability practices to demonstrate leadership, its public outreach program to be 

very strong, and its environmental management system to be sound and well

documented. 

4.2 Performance Indicators and Progress 

2004 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 2004, the objectives were: 

• 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 NEPT, 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. 

As mentioned in the preceding section, in early FY2004, NREL was accepted into 

EPA’s NEPT Program and the State of Colorado CELP Program. This has furthered 

the collaboration between Sustainable NREL and the ES&H Office EMS activities. 

The performance commitments made through NEPT and CELP programs are being

implemented at NREL via the Sustainable NREL program. The commitments made

are to reduce overall energy usage, reduce water use, reduce greenhouse gas 

emissions, and reduce carbon monoxide air emissions. 

NREL participated in two DOE Golden Field Office Surveillances in 2004: NREL’s 

Hazardous Waste Specific Waste Streams and Storm Water Compliance for the 

Science and Technology Facility (S&TF) Construction. Additional information can 

be found in Section 4.3 below. 

Sustainable NREL and EMS staff worked together to compile pollution prevention 

data on waste generation, recycling, and green purchasing. NREL received a DOE P2 

Star award for Petroleum Fuel Reduction Through Alternative Fuels. This is the result 

of efforts by Sustainable NREL to improve the sustainability of NREL’s vehicle fleet. 

A wildlife survey (including migratory birds) of the STM Site was begun in the spring

of 2004; it was completed in Spring 2005. Further details are provided in Section 

5.11. 

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A detailed cultural resources survey of the historic features on the southernmost parcel 

of NREL’s STM Site was conducted during the spring and summer of 2005. It will be 

discussed further in the 2005 report. 

National Environmental Performance Track Commitments

NREL’s performance commitments under the NEPT program are three-year 

commitments, to be in place throughout NREL’s three-year participation in the 

program, from 2004 through the end of 2006. NREL’s commitments are as follows. 

Commitment #1: Reduce emissions of greenhouse gases by 10% from the 2002 

baseline year. 

NREL is on track to meet this commitment. In 2003, NREL installed on-line site 

metering data for employees and building area engineers. In 2004, this metering data 

was monitored so that energy and peak load management strategies can be evaluated 

at individual buildings on campus. 

A number of projects involving energy management were initiated in 2004. They

were implemented to reduce NREL’s total energy use and resulting CO2 emissions. 

These projects include two HVAC equipment replacement projects, one at NREL’s 

FTLB laboratory building and the other at the main building, Building 251, at NREL’s 

NWTC. Other projects include an upgrade of NREL’s direct digital building power 

controls; installation of a natural gas boiler at the NWTC Building 251; a supply fan

upgrade at the AFUF laboratory building; an Energy Center Expansion project at the 

SERF laboratory building (central plant expansion with new high efficiency chiller

and room for future high efficiency condensing boiler); and two programmable 

thermostat upgrades at the NWTC Data Shed and Shipping and Receiving facilities. 

Commitment #2: Reduce water use by 5% from the 2002 baseline year. 

NREL has already met this 5% water use reduction goal. Therefore, the Laboratory

has extended its commitment to reduce water use even further. In 2005, NREL

committed to a reduction in total water use of 20% from the 2002 baseline. The 2004 

annual consumption was lower than would normally be expected, because one of the 

four evaporative cooling units at the SERF building was down for significant periods 

of time for repair and maintenance. In addition, some of the water usage data is 

comprised of estimated figures, due to a water supply company meter error.

In 2004, NREL implemented two best management practices to reduce water 

consumption. These include: 1) cooing tower management, that involved changing

the chemical to water ratio; and 2) conducting distribution system audits, leak 

detection, and repair. 

Commitment #3: Reduce emissions of carbon monoxide. 

This goal was to be accomplished by obtaining a greater percentage of NREL’s fleet 

vehicles as alternative fuel vehicles from the U.S. government’s General Services 

NREL Environmental Performance Report- 2004

 

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Administration, the supplier of NREL’s fleet vehicles. In 2004, NREL requested three 

additional ethanol-85 fleet vehicles from GSA. The vehicles were not available, and 

our emissions were unchanged from the 2002 baseline. 

Commitment #4: Reduce total energy use by 3% from the 2002 baseline year. 

NREL has already met the original 2006 performance goal of 3% energy use 

reduction. Therefore, the Laboratory is extending our commitment to a reduction in 

energy use of 7% from the 2002 baseline. 

A number of projects involving energy management were initiated in 2004. These 

projects are described above in the greenhouse gas commitment (#1). 

2005 Objectives

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

fiscal year 2005 are: 

• Participate in the GO surveillance program. 

• Complete self-assessments of selected environment, Safety and health 

programs 

• Support GO STM and NWTC Site-wide EA analyses consistent with proposed 

site development plans. 

• Demonstrate progress toward achieving NEPT goals. 

• Initiate identification and analysis of operational impacts presented to the

NWTC by the impending Rocky Flats closure. 

Progress toward the 2005 goals will be reported in the NREL 2005 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 assessments. 

A team of NREL staff generally performs assessments of NREL’s EMS internally on a 

periodic basis, The team generally includes NREL Environment, Safety & Health 

staff and staff involved in the Sustainable NREL initiative. The scope of the 

assessments includes both the management of significant environmental aspects and 

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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. 

In addition to regular compliance assessments of individual NREL environmental 

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

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

procedures, including EMS policies and programs. NREL reviews its 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. EPA has established 

a new requirement, as part of its NEPT Program, for external EMS audits of 

participating facilities every 3 years. As NREL is a member of NEPT, the Laboratory

will begin conducting external audits on the 3-year frequency.

2004 Assessment Activities

A self-assessment of NREL’s EMS was begun in mid-2004. A surveillance by the 

DOE Golden Field Office was conducted concurrently. The self-assessment was 

performed by a team of NREL ES&H 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 

assessment team evaluated the EMS using international Global Environmental 

Management Initiative (GEMI) criteria, which are based on the ISO 14001 standard, 

and NEPT standard criteria. The Surveillance and Self-Assessment activities were

completed in late 2004. 

The objectives of the Self-Assessment were to: 

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• evaluate environmental performance 

• verify compliance with legal and other requirements 

• meet the established environmental goals of the Laboratory

• provide for continuous improvement of the EMS

• provide information on the results of the assessment to management 

NREL determined that it meets all legal requirements and is well positioned to meet

its other applicable requirements, such as DOE and Executive Orders, within the 

timelines set out by those orders. The assessment team also identified a number of

areas for continuous improvement, including seven priorities for improvement. These 

priorities include: 

1. Update the Integrated Safety Management System (ISMS) description to more 

fully incorporate the EMS.

2. Improve coordination of environmental goals and objectives across various

laboratory sectors. 

3. Develop additional quantitative performance measures in areas of significant 

environmental impact. 

4. Implement an EMS database tool that would capture all the EMS elements into

a single integrated system. 

5. Develop new procedures or modify existing procedures to better address early

identification of environmental concerns. 

6. Consolidate NREL’s environmental policy into a single document. 

7. Develop an integrated report of sustainability information and environmental 

information. 

It is anticipated that implementation of the potential continuous improvements 

identified during the assessment will be a multi-year effort. An action plan to 

implement the potential improvements identified in the EMS Self-Assessment and 

Surveillance has been developed. Progress in implementing improvements will be

reported in the 2005 ASER. 

Also in late 2004, DOE-GO conducted two additional activity-focused surveillances: 

Hazardous Waste Specific Waste Streams and Storm Water Compliance for the S&TF

construction. There were no DOE findings as a result of either surveillance, and no 

corrective actions were required. The DOE Golden Field Office report for the Storm

Water surveillance stated that NREL maintains exceptionally thorough records that

facilitate NREL’s compliance with current regulations. 

NREL Environmental Performance Report- 2004

 

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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 

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

energy use in its building operations; designing energy efficient and environmentally

sensitive new buildings; reducing water consumption; decreasing greenhouse gas 

emissions; minimizing 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 system supports Sustainable NREL’s goals, with the 

EMS focusing on protecting the natural and cultural resources on and around NREL

sites by reviewing NREL’s potential for environmental impacts through emissions, 

discharges, waste generation, and land use; conducting required permitting activities; 

and recommending and coordinating measures to minimize any potential impacts 

NREL’s activities have on the environment. There is synergism between Sustainable

NREL and environmental protection activities of the ES&H Office in that both 

address different components of NREL’s environmental footprint. Together, 

Sustainable NREL and the EMS, as implemented by the ES&H Office, form a single

environmental program that is integrated with NREL’s other management processes. 

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. 

NREL Environmental Performance Report- 2004

 

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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 on its DOE-owned sites, leased 

properties, and to the extent practicable, on subcontractor and partner sites as well. NREL

strives to protect the natural environment by minimizing or eliminating any adverse

environmental impacts resulting from NREL activities. The Laboratory’s EMS is integrated

with other NREL management systems and applies to all research and operations activities. 

The EMS includes written environmental protection policy and program implementation 

documents. These are put into practice at all staff and management levels. 

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

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

EMS are provided in the following sections of this chapter. Sections are organized by

resource. Each section is 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- 2004

 

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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). EPA-certified 

technicians must service this equipment, 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 located at the Solar Energy Research Facility (SERF) on the STM Site, 

and one at the DWOP. 

Halon-based fire suppression systems previously used at NREL were 

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

facilities for “banking”. 

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. . NREL has held such permits for a number

of years. New site-wide permits were issued in February 2005 to replace 

previously-held permits on which the time period of applicability had expired. 

One permit covers the STM site, and the other is in effect for the NWTC. 

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Requiring construction subcontractors to follow control measures identified in 

a Particulate Emissions Control Plan controls particulate air emissions. NREL

also holds one air emissions permit for an experimental pilot process in the

FTLB on the STM Site. 

5.1.3 2004 Activities

No APENS were filed in 2004. 

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 a buried 15,000-gallon storage tank and an above ground 2000-

gallon tank. The water hauler fills the 15,000-gallon tank, 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, chlorine levels, haloacetic acids and trihalomethanes 

(disinfection by-products), 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 levels – weekly, or more frequently as needed 

• Haloacetic acids (HAA5) – annually

• Trihalomethanes (TTHM) - annually

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. Quarterly

reporting is provided to the State for chlorine residuals. 

NREL Environmental Performance Report- 2004

 

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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 and 2005. All lead and copper 

levels were below action levels. 

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. 

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 2004 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 

NREL Environmental Performance Report- 2004

 

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pervasive problem throughout the FTLB domestic plumbing system. Lead was 

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, 

semi-annual sampling was conducted in February and July, with no lead 

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

decreased to every 12 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 

NREL Environmental Performance Report- 2004

 

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

and bermed areas to contain experimental materials. 

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 (in accordance with 

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 DOE’s Rocky

Flats Office operated the site. 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.

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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 

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

warehouse. No ground water studies have been performed by NREL in 

proximity to the ReFUEL facility, as it is located in a heavily industrialized 

area and NREL has not had any releases to the environment that would pose a 

risk to groundwater. 

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 2004 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 

NREL Environmental Performance Report- 2004

 

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

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

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

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

the treatment of wastewater. 

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

sewer system, and NREL staff 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, 

ReFUEL 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 2004 Activities

There were no new significant activities during 2004 in this area. 

5.5 Surface Water Protection (Storm Water and Erosion Control)

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)

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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. 

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 2004 Activities

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

which erosion and sediment control programs were developed. These were

NREL Environmental Performance Report- 2004

 

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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 of coverage under the EPA’s Construction General 

Permit for this project was filed with EPA in August of 2004.

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&H 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 lab ware, 

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

5.6.2 Permitting

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

quantities of hazardous materials. Each of the five 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 three 

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

ReFUEL Facility, are classified as "conditionally exempt small quantity

generators," generating less than 100 kg of waste per month. 

NREL Environmental Performance Report- 2004

 

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5.6.3 2004 Activities

In calendar year 2004 NREL shipped 12,113 pounds (5,506 kg) of hazardous 

waste, and 1,495 pounds (680 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. 

There was no radioactive waste shipped for off-site disposal in 2004. 

Information regarding the types and quantities of radioactive materials used at

NREL facilities is detailed in Section 5.15. 

In 2004, 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. 

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. 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 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 

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. 

NREL Environmental Performance Report- 2004

 

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5.7.2 Permitting

Tanks larger than 660 gallons require registration 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 2004 Activities

There were no spills or leaks from NREL tanks during 2004. There was no

state inspection in 2004.

5.8 Hazardous Materials Management 

5.8.1 Program Management

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

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

No active or abandoned hazardous waste sites have been identified on any of 

the Laboratory sites. Therefore, many sections of the Comprehensive 

Environmental Response, Compensation, and Liability Act (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 provides additional emergency response and reporting information to 

the Jefferson County Emergency LEPC, the SERC, and West Metro Fire 

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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 bar-coding system, the 

CMS tracks chemicals from the point of receipt through end-use and disposal. 

The system also contains technical data and reporting information for many of 

the chemicals in the CMS database. Key functions of the system include: 

• Providing current inventories by room, building, and/or site 

• Improving research efficiency and minimizing hazardous waste 

generation by allowing staff to determine if needed chemicals are

already available on site prior to making chemical purchases 

• Providing quick access to chemical inventories and hazard information 

during emergency responses 

• Facilitating accurate and efficient reporting to external agencies (e.g. 

fire districts, 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. 

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;

NREL Environmental Performance Report- 2004

 

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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 Fire 

Protection District 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 2004 Activities

West Metro conducted a walk-through inspection of NREL’s STM and DWOP 

facilities in the spring of 2004. 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: 

placarding buildings outside of TTF if they contain batteries, and placing a 

placard on the door to the hazardous waste storage room in Building 16. 

The CMS was used to provide complete chemical inventories for each facility

to West Metro when applying for Hazardous Materials Permits in 2004. The 

CMS was also used to post individual laboratory chemical inventories on the 

ES&H website, which were updated monthly. 

In 2004, 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 2004, 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 2004, the Laboratory did not use any

materials on the Section 313 list in quantities exceeding the 4536-kg (10,000-

lb) threshold planning quantity.

NREL Environmental Performance Report- 2004

 

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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&H 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 required for use in the immediate future, knowing that additional

quantities can be quickly acquired if needed. The ES&H Office reviews all 

chemical purchases made using the bankcards. 

Recycling and reuse activities are important components of NREL’s pollution 

prevention program. A crosscutting committee comprised of staff from 

around the Laboratory, and led by Sustainable NREL manages NREL’s 

recycling program. Items currently recycled or reused at NREL include the 

following: 

• computer monitors 

• fluorescent bulbs 

• batteries

• styrofoam peanuts and other packing materials 

• freon from refrigerator units 

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• 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 

Fourteen 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 2004, NREL generated 266 metric tons of solid waste and diverted 82 

metric tons to recycling, or 31% of the total. Data for some of the materials 

recycled by NREL during 2004 follow. Quantities listed below are those 

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 2004. 

Quantities are not tracked for all materials that are recycled; therefore, the list 

below does not include all recycled materials. 

 Batteries 2,038 lb 

 Fluorescent bulbs 356 lbs 

 Mixed metal 105,100 lb 

Commingled containers 29,204 lb 

 Cardboard 23,400 lb 

 Misc. paper 128,032 lb 

 Computer monitors 3,194 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 2004, 

some of the products purchased containing recovered content included 

carpeting, uncoated-printing paper, and toner cartridges. One hundred percent 

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(100%) of NREL’s supply of uncoated printing and writing paper, and toner 

cartridges purchased in 2004 contained recovered content. 

5.9.2 Vehicles

Transportation at the Laboratory falls into three main categories: fleet vehicles, 

air travel, and employee commuting. Figure 5.1 illustrates a percentage 

breakdown of transportation by mode. In an effort to describe the impact that 

transportation has on the footprint of the Laboratory, a calculation was done 

illustrating the kilograms of CO2 emitted into the atmosphere. Fifteen percent 

of NREL’s total footprint was due to transportation. This breakdown serves as 

a way to examine NREL’s transportation issues and proactively provide 

solutions to reduce the impact of transportation. 

Sustainable NREL’s Transportation strategy is directed by two Federal 

guidelines. The first, EPACT of 1992 states that 75% of the light duty vehicle 

(LDV) fleet shall be Alternative Fuel Vehicles (AFV). Secondly, Executive 

Order 13149, Greening the Government through Federal Fleet and 

Transportation Efficiency and DOE compliance strategy for this Executive 

Order states that there shall be a 20% decrease of fleet petroleum use by 2005 

as compared to a 1999 baseline. In order to meet these goals, NREL’s fleet

currently has 36 AFV’s in their total fleet of 47 vehicles. This decreased our 

petroleum use to 7691 gallons in FY04. This is far exceeding the goal that 

DOE had set for NREL of 9800 gallons or less by FY05. The Laboratory is 

converting its fleet to 100% AFVs as soon as possible given their availability

for leasing through the General Services Administration. Laboratory fleet 

transportation vehicle types include 19 ethanol (E85), 9 compressed natural gas 

bi-fuel (CNG/bi), 4 CNG, 15 petroleum-fueled (11 regular unleaded and 4 

diesel [1 leased]) vehicles (1). 

The Laboratory has made a major commitment to the use of bio-based fuels in 

its fleet. Forty percent (40%) or 19 of the 47 fleet vehicles are fueled by e85. 

The Laboratory was an early adopter with its first e85 vehicles entering the 

fleet in 1997. The fleet used 11,645 gallons of e85 and biodiesel in FY04. 

This represents some 71% of the total fleet usage of 16,405 gallons of total gas 

and equivalent fuel. Although we are actively using e85-fueled vehicles, 

biodiesel is also an option being explored. As of this date, NREL will fuel a

Kubota tractor, a Gradall lift and a Ford 555 backhoe with biodiesel B20 fuel 

as a pilot project. 

Fleet vehicles are only part of the transportation initiative at the Laboratory.

Sustainable NREL also actively encourages alternative commuting for 

employees. In the spring of each year, employees receive an on-line survey

regarding their commuting habits. In FY04, 375 employees out of 942 

responded. 132 of the respondents use alternative modes of commuting. 

While these numbers are strong, there are ways to improve them. For instance, 

NREL Environmental Performance Report- 2004

 

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NREL offers bus passes to all full-time employees. In FY04 alone, 59 

employees reported taking public transportation at least three times a week.

NREL also works actively with the Denver Regional Council of Governments 

to provide employees with carpool and vanpool resources. 150 employees 

participate in car-pooling. Additionally, as of April of 2004, 38 employees had 

purchased hybrid vehicles for their personal automobile. 

Biking and walking are also viable commuting options for NREL employees 

living within a reasonable proximity and the Laboratory wants to make these

easy options for all who choose them. NREL has showering facilities, locker 

rooms, and bike lockers on-site. Bike vests were given to our bike commuters 

for an added measure of safety. External biking programs are also promoted

such as Colorado’s Bike to Work Day in June of 2004. NREL had 75 

employees who participated. In FY04, 53 employees biked regularly and 13

walked. 

Air travel is also a concern for NREL. The Laboratory has two offices, one in 

Golden, Colorado the other in Washington, DC. Employees were able to 

decrease air travel back and forth from these two offices by utilizing

teleconferencing equipment. In FY04 alone, approximately 31 trips were 

saved due to the use of video and/or phone conferencing. While air travel at

some point is always necessary for Laboratory business, there are ways to 

reduce it. 

The Laboratory also addresses future campus planning with transportation in

mind. In 2003, NREL published its General Development Vision. This is a 

25-year framework for developing campus facilities. The transportation piece 

of this plan includes an inner shuttle loop and an exterior service road. Parking

will be consolidated and will only have 1500 parking spaces. 

NREL Environmental Performance Report- 2004

 

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Figure 5.1: NREL Transportation by Mode 

 

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 

FY2004 TOTAL NREL (DOE-owned) 256,650 

FY2004 TOTAL NREL (w/ Wind Source Credit) 239,289 

Comparing total NREL energy consumption in FY 2004 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. 

NREL Environmental Performance Report- 2004

 

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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 2004, 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 chilled water plant feeds the SERF’s process-cooling load. Adding a heat

exchanger between the process cooling load and the heat recovery system

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

NREL Environmental Performance Report- 2004

 

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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. Supplier’s 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 was 

begun in 2001. 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 now institutionalized and is installed on each computer through out the

Laboratory. 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. NREL generates about 58,000 kWh of electricity from gridconnected PV panels each year. These panels are located at the Solar Energy Research

Facility, the Site Entrance Building, the Outdoor Test Facility, NWTC Site Entrance Building

and DER Test Facility, and remote applications including signs, walkway and parking lighting.

The National Wind Technology Center (NWTC) has approximately 1,600 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. The turbines produce 

over 80,000 kWh per year, most of which is used to offset simultaneous NWTC site energy

use. The total self-generated electricity at NREL is over 138,000 kWh each year. 

NREL Environmental Performance Report- 2004

 

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Purchased renewable energy. In FY2004, 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. In FY2004, NREL implemented two more BMPs: 1) 

Cooling Tower Management (changing the chemical to water ratio); and 2)

Distribution System Audits, Leak Detection and Repair. 

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 

FY2004 – TOTAL NREL 7.0 

NREL Environmental Performance Report- 2004

 

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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. 

Construction began on the Science and Technology Facility (S&TF) in early

2005. The facility has been designed 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.

NREL staff designed the NWTC Site Entrance Building (SEB) in-house. 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. 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. As a component of its outreach efforts to 

disseminate information regarding sustainability, NREL has received a number

of awards. Examples of these awards are: CU Wirth Chair Award in 

Environmental and Community Development Policy, DOE Departmental 

NREL Environmental Performance Report- 2004

 

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Energy Management Achievement Award: Effective Program Implementation 

– Sustainable NREL, and DOE Best-In-Class Pollution Prevention Awards. In

2004, 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 and NREL NOW, internal electronic publications; and an NREL

Sustainability Report that is distributed both internally to NREL staff and to

the public. 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 of bluegrass at the STM site. However the

native vegetation and natural character of the landscape is maintained over the

majority of the site. Revegetation of areas to be left in their natural state 

following disturbance from construction or other outdoor activities is 

conducted using a native seed mix of grasses and forbs. 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. 

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). 

NREL Environmental Performance Report- 2004

 

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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). Figure 5.2 illustrates a portion of 

the NWTC site and shows the diverse vegetation mix present. No rare or 

imperiled plant species were found on the site. However, the survey identified 

a small area of xeric tallgrass prairie (defined as mesic mixed grassland in this

study) located in the southwest corner of the NWTC. This natural community

is listed as rare and imperiled by the Colorado Natural Heritage Program. This 

listing implies no legal designation or regulatory enforcement. It is so 

designated primarily for management purposes. This area of the NWTC is not 

impacted by research or construction activities on the site. 

Figure 5.2 - Lush vegetation growth along the NWTC north fenceline. 

NREL Environmental Performance Report- 2004

 

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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: Canada thistle, diffuse knapweed, field bindweed, musk thistle, and 

leafy spurge. 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. 

Weed control efforts have been ongoing since 1997 at the NWTC and 1998 at 

the STM site. NREL uses an IPM approach that incorporates various types of 

weed control methods. Some of these include mechanical practices (e.g. 

mowing), cultural (e.g. reclamation of disturbed areas), prevention (e.g. 

limiting or eliminating driving of vehicles off established roadways), and 

herbicide treatment. The effectiveness of control methods is periodically

assessed. The use of multiple strategies for control has been successful in 

significantly reducing populations of diffuse knapweed and Canada thistle on 

the sites. The key aspect of the weed control program is to maintain flexibility

to respond to the changes in weed populations from year to year. 

In 1998, aerial herbicide application of Tordon 22K was conducted using

helicopter application over about 200 acres of the NWTC to target diffuse

knapweed. It was very effective in controlling the weed, and healthy stands of

native grasses have proliferated with the decrease in weed competition. Since 

that time, infested areas of the NWTC have been treated 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). 

NREL Environmental Performance Report- 2004

 

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5.10.3 2004 Activities

NREL routinely practices IPM using various weed control methods, as 

described in the previous section. These are implemented during the normal 

course of site operation. In addition to the reclamation, off-road driving

restrictions, and other weed control methods, ground applications of herbicides 

occurred at the NWTC in the spring of 2004 and 2005. Very limited herbicide 

application was conducted on the STM site in the spring of 2004 and 2005,

focusing primarily on areas adjacent to roadways and buildings. The spraying

was performed using a four-wheel drive vehicle. Primary target weeds were 

diffuse knapweed, leafy spurge, Canada thistle, common teasel, and hoary

cress at NWTC. At the STM, target weeds were mainly diffuse knapweed and 

Canada thistle. 

NREL promotes the sustainable management of its government-owned land by

practicing 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. This commitment is implemented by a

Sustainable Landscape Design and Management Program. 

5.11 Wildlife

5.11.1 Program Management

NREL Environmental Performance Report- 2004

Wildlife habitat at the STM site is comprised of grasslands, shrublands, and

wetlands. The STM site provides vegetation types for a variety of wildlife 

species including birds, mammals, and reptiles and amphibians. The variety of

vegetation types present on site attracts species that may use the site as yearround habitat, for breeding only, during migration, or as winter habitat. 

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 has just been completed, 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 survey indicated that 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 during the survey. 

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 

 

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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. 

• 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

A scientific collection license was obtained from the Colorado Division of 

Wildlife for the small mammal trapping portion of the recent STM wildlife

survey. NREL has no other permitting requirements for this area of

environmental management. 

NREL Environmental Performance Report- 2004

 

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5.11.3 2004 Activities

A site-wide wildlife survey of the STM site was begun in April 2004 and was 

completed in June 2005. The objectives of the survey were to update existing

data in light of expanded development of both the site and the surrounding

area, and to develop best management practices for future construction projects 

to maximize protection for site wildlife.

The survey included large and small mammals, predators, migratory birds and 

raptors, upland game birds, and invertebrates identified on an opportunistic 

basis (i.e. only as they are found during other surveys). 

A listing of species observed during the year-long STM wildlife survey is 

attached as Appendix B. A summary of the survey results follows: 

Migratory Birds and Raptors 

Many species of migratory birds were observed on the STM site, with many of 

these species potentially nesting on site. In addition, the STM site may provide 

important migration and winter habitat for migratory birds. For example, the 

American tree sparrow was only observed on site during Winter surveys and 

the northern harrier was observed hunting on site only in the Fall and Winter 

seasons. Several species were only observed during the Fall season including

downy woodpecker, red-breasted nuthatch, blue jay, loggerhead shrike, and

rock wren, suggesting that these species may use the STM site as a stopover 

during migration. Habitat for migrating birds is important, as some of these 

species may migrate as far south as Central and South America. 

Several species of raptors were observed at the STM site and, two species were 

observed by both studies (1987 and 2004-2005) nesting on site, the red-tailed 

hawk and the American kestrel. Both of these species were observed hunting

on site during the 2004-2005 surveys, in addition to the Cooper’s hawk. The 

NREL STM site provides habitat and a prey base of small birds and small 

mammals for these raptor species. Species such as the Swainson’s hawk 

migrate thousands of miles each year, wintering as far south as Argentina, and 

returning to the western United States and Canada to breed. Areas such as the 

STM site may provide a prey source for the Swainson’s hawk and other 

species during migration.

Large Mammals 

Mule deer at the STM site have been observed in all habitat types. Mule deer 

were often observed in the amphitheater drainage or in the tall shrubland on the 

slope. When approached on the mesa top, the mule deer tended to move away

from the disturbance and into the amphitheater drainage. The tall shrubland

vegetation type may provide important hiding cover for this species. Spring

pellet group surveys resulted in nearly double the amount of pellet groups and 

plots the pellet groups were observed in than Fall surveys. This may suggest 

that winter use of the STM site by deer may be higher than summer use or that 

NREL Environmental Performance Report- 2004

 

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deer utilize different habitats on site for these periods as affected by the

availability of habitats and the location of survey plots, although the single

year of data is not sufficient to draw conclusions regarding seasonal variation. 

Predators 

Coyotes are one of the most widespread and adaptable carnivores in North 

America and occur at all elevation levels and in all ecosystems in Colorado 

(Fitzgerald et al. 1994). Lagomorphs (rabbits) and rodents are an important

part of the coyote’s diet, both of which are abundant on the STM site. 

Evidence of predation on cottontail rabbits (i.e., entrails and fur) was observed 

during site visits. Coyotes may breed on the STM site as two potential dens 

were observed on site in two of the site drainages.

Small Mammals 

The deer mouse is the widest ranging and commonest small mammal in North 

America (Fitzgerald et al. 1994) and based on the 1987 and 2004-2005 survey

data, it is also the most common small mammal on the NREL STM site. Deer

mice can occur anyplace where cover occurs (Fitzgerald et al. 1994) and were 

observed in the four vegetation types sampled on the STM site. This species is 

a generalist and is known to exploit disturbed habitats. Mexican woodrats and 

prairie voles were more restricted than the deer mouse in the habitats they

occupied on the STM site. Mexican woodrats are associated with rocky slopes 

and do not build dens away from rocky areas (Fitzgerald et al. 1994). This 

species is therefore limited as to where it can occur on the STM site. Prairie

voles are adapted to the grasslands, constructing burrows and runway systems 

throughout the grassland, essentially limiting this species to the short grass and 

mixed grass vegetation types on the STM site. All of these species are active 

throughout the year. Winter surveys (2004-2005) were conducted during a

warm weather trend, which may have contributed to the highest number of

small mammals caught compared to the three other surveys. 

Reptiles/Amphibians 

Several rattlesnakes were observed on the STM site, more often in rocky areas, 

but also in the grassland. A rattlesnake den may be present in the rocks near

the top of the mesa slope north of the Visitor’s Center (near E-2-3) as four 

rattlesnakes were observed within a few feet of each other, one in the open and 

three in a rock crevice. Hibernation generally occurs in rock outcrops, with 

this species usually active from mid-April through late-September

(Hammerson 1999). Although only three species of reptiles and one species of 

amphibian were observed on the STM site, no specific survey methods were 

employed to identify or count these groups of wildlife at STM. 

To avoid or minimize disturbance to wildlife species on site, site-wide best 

management practices (BMPs) were developed as a result of this survey for

consideration during ongoing normal site operations and future construction 

projects. The BMPs address migratory birds and raptors, mammals, all 

NREL Environmental Performance Report- 2004

 

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wildlife, and general site operations. They will be applied as appropriate to 

site activities and future site development. 

Some of the STM Site wildlife species are shown on the photos in Figures 5.2, 

5.3, and 5.4. 

Figure 5.3 – Raccoon napping in the shade of the SERF On the STM site. 

Figure 5.4 – In the photo on the left, a rattlesnake rests in the leaf litter. On the right, 

a bull snake and a rabbit take shelter from the heat of the day under staff cars in one 

of the STM parking lots. 

NREL Environmental Performance Report- 2004

 

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Figure 5.5 – A long-tailed weasel peaks out from underneath the CNG cylinders 

on the STM site. In the photo on the right, a rare sighting of an amphibian; a 

tiger salamander.

5.12 Endangered Species/Species of Concern

5.12.1 Program Management

The Endangered Species Act provides for the designation and protection of

wildlife, fish, and plant species that are in danger of extinction and preserves 

the ecosystems on which these species depend. For the purposes of site 

wildlife surveys, a species of concern is defined as those species protected 

under Federal statutes, including the Endangered Species Act of 1973, as 

amended, the Bald Eagle Protection Act of 1940, as amended, and the 

Colorado Division of Wildlife list of endangered, threatened, and wildlife 

species of concern. Federal agencies are also required to abide by the 

Migratory Bird Treaty Act of 1918, as amended, but for this report, these 

species are not included as species of concern. For plant surveys, the Colorado 

Natural Heritage Program designation is also considered. Although this listing

of rare species is not regulatory in nature, NREL uses it for management 

purposes. 

No threatened or endangered species or candidate wildlife species for 

endangered designation or other sensitive species have been found on either

the STM or NWTC sites during any site wildlife surveys. . Likewise, no 

threatened, endangered, candidate, or other sensitive plant species were

identified in any survey of the STM or NWTC sites, as there was no suitable

habitat present for any of the sensitive species. 

NREL Environmental Performance Report- 2004

 

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The vegetation survey at NWTC, conducted between August 1999 and August 

2000, identified a small area of xeric tallgrass (defined in the survey as mesic 

mixed grassland) prairie located in the southwest corner of the NWTC site. 

This natural community is listed as rare and imperiled by the Colorado Natural 

Heritage Program. This listing implies no legal designation, but is made 

primarily for management planning purposes. This xeric tallgrass prairie area 

has been designated by NREL as a Conservation Management Area. Most of 

the Conservation Management Areas on the NWTC are formally designated as 

areas on which building will not occur. However, as the xeric tallgrass prairie

is in the active turbine testing area, it is not reasonable to preclude all 

development on portions of the site inhabited by this plant community; but 

disturbance will be minimized on the area.

The vegetation survey completed on the STM site in May 2002 found no 

rare/or imperiled plant species on the site, but areas of mixed foothills 

shrublands (also called tall upland shrubland), were identified along the top of

the mesa within the Conservation Easement area. That natural community is

listed as rare and imperiled by the Colorado Natural Heritage program. It is

within a designated conservation easement area where no development will 

occur except planned trails being established by Jefferson County Open Space 

(See Section 6.0 for a discussion of trails). 

5.12.2 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 has 

recently been completed. No species observed on the STM site during the 1987 

or the 2004-2005 wildlife surveys were present on either agency’s list. 

However, golden eagles were incidentally observed on the STM site (outside 

of raptor surveys) and are protected under the Bald Eagle Protection Act. 

Golden eagles were observed flying over the site and may use the site for 

hunting. No golden eagle nests or nesting activities were observed on the STM 

site. 

5.13 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. 

NREL Environmental Performance Report- 2004

 

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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

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, 

NREL Environmental Performance Report- 2004

 

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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. Figure 1.7 provides an aerial 

view of the amphitheater.

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 contributes to the Camp George West Historic District. 

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 in the vicinity until a qualified archaeologist completely evaluates the

significance of the find. 

NREL Environmental Performance Report- 2004

 

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5.14.2 Permitting

NREL has no permitting requirements for this area of environmental 

management. 

5.14.3 2004-5 Activities

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 district’s overall eligibility for the National Register. 

A 2003 cultural resources survey was conducted of the 25-acre parcel south of 

Denver West Parkway on the STM Site. The survey found evidence of two

contributing features to the Camp George West Historic District occurring within the 

25-acre parcel. 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 consulted with the State Historic Preservation Officer (SHPO) over the 

resources newly discovered on the 25 acres. DOE and the SHPO entered into 

a Memorandum of Understanding in which DOE agreed to perform further 

surveys to fully document the resources on the 25 acres prior to any

development of the parcel. 

In 2005, the DOE Golden Field Office and NREL conducted additional 

surveying of the Camp George West Firing Range Lines and Low Rock Walls, 

which contribute to the Camp George West Historic District’s eligibility to the

National Register of Historic Places. The survey resulted in Level II

HABS/HAER documentation. The survey will be more fully described in the 

2005 ASER.

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. The 

Council of Environmental Quality (CEQ) issues regulations for compliance 

NREL Environmental Performance Report- 2004

 

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with the Act. 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, and training is provided to staff, as appropriate. 

5.15.2 Permitting

NREL has no permitting requirements under NEPA. 

5.15.3 2004 Activities

During 2004, an EA was conducted for a proposed Low Wind Speed Turbine 

Demonstration Project in Carbon County, Wyoming. The EA process was

initiated in October 2004, and a Finding of No Significant Impact was signed 

in January 2005. 

In addition to the EA, numerous NEPA reviews of both onsite and offsite 

activities occurred through completion of NREL Environmental 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&H 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 

NREL Environmental Performance Report- 2004

 

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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 

three x-ray diffraction machines at the SERF on the STM Site, one x-ray

diffraction machine in Building 16 on the DWOP site, and two sealed source 

level gauges at the AFUF (STM Site) used on pilot scale processes to measure 

the level of material inside process tanks. In addition, one laboratory at the 

Field Test Laboratory Building (FTLB), on the STM site, occasionally uses

small quantities of radioisotopes for biological or chemical labeling.

The three X-ray diffraction machines located at the SERF 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. The one machine in Building 16 was moved from the SERF and is 

not presently being used.

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. 

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. 

NREL Environmental Performance Report- 2004

 

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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 2004 Activities

During 2004, the total quantity of radioisotopes used at NREL was 1.812 mCi, 

used in one laboratory at NREL’s FTLB. A laboratory hood exhaust emitted 

any emissions generated by this work. 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 0.043 mrem/yr, well 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 

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. 

There were no shipments of radioactive waste for disposal in 2004. 

In 2004, there was a modification to the lab where radioisotopes are used: a 

fan that handles the two chemical fume hoods located in that lab was replaced, 

and an additional backup fan was installed. 

There were no unplanned releases of radioisotopes in 2004. 

NREL Environmental Performance Report- 2004

 

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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.

2004 Assessment of the Property

During 2004 there was no NREL activity on the conservation easement property having the 

potential to degrade the environmental condition of the property. Jefferson County Open 

Space conducted a site inspection during the summer of 2004. No degraded conditions or 

other environmental issues were found. Photos taken in 2003 showing the representative 

areas of the easement lands are included in Section 2 of the 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- 2004

 

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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- 2004

 

 Page 74
Rust Environment & Infrastructure, Inc., (1995b). Final Report, Ground Water Monitoring, 

Third Quarter, 1994 and Fourth Annual Report, South Table Mountain Site. Englewood, 

Colorado. 

Schmidt, E., Piaggio, A.J., Bock, C.E., Armstrong, D.M, (January 2003). National Wind 

Technology Center Site Environmental Assessment: Bird and Bat Use and Fatalities – Final 

Report. University of Colorado, Boulder, Colorado. 

Science Applications International Corporation, (2005). Wildlife Survey (Including Migratory

Birds and Raptors) at the National Renewable Energy Laboratory South Table Mountain Site, 

Golden, Colorado. Lakewood, Colorado. 

U.S. Department of Energy, (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- 2004

 

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NREL Environmental Performance Report- 2004 

 

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8 APPENDICES 

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

Appendix B – Wildlife Species Observed on the South Table Mountain Site 
APPENDIX A – SUMMARY OF NREL ENVIRONMENTAL PERMITS, REGISTRATIONS, NOTIFICA

Tracking

Number 

Permit or 

Registration

Number 

Permit or Reg. 

Holder 

Permit Type Permit Description Issuing

Agency Name

Location

Description 

Status

Permits

1 04JE1442L DOE AIR Air Emission Permit

for Land Development(fugitive dust fromconstruction activities)

Colorado Dept. of PublicHealth andEnvironment(CDPHE) 

NWTC site 2/07/05 (

issued 3/

2 04JE1443L DOE AIR Air Emission Permit

for Land Development(fugitive dust fromconstruction activities)

CDPHE STM site 2/07/05 (

issued 3/

7 37232 SERI Groundwater

Monitoring Well 

Permit to Construct a Well (MW-1) 

Colo. Div. OfWater Resources 

STM construct

permit nuuntil wel

8 37229 SERI Groundwater

Monitoring Well 

Permit to Construct a Well (MW-2) 

Colo. Div. OfWater Resources 

STM construct

permit nuuntil wel

9 37228 SERI Groundwater

Monitoring Well 

Permit to Construct a Well (MW-3) 

Colo. Div. OfWater Resources 

STM construct

permit nuuntil wel

10 37231 SERI Groundwater

Monitoring Well 

Permit to Construct a Well (MW-4) 

Colo. Div. OfWater Resources 

STM construct

permit nuuntil wel

11 37230 SERI Groundwater

Monitoring Well 

Permit to Construct a Well (MW-5) 

Colo. Div. OfWater Resources 

STM construct

permit nuuntil wel

NREL Environmental Performance Report- 2004 
Tracking

Number 

Permit or 

Registration

Number 

Permit or Reg. 

Holder 

Permit Type Permit Description Issuing

Agency Name

Location

Description 

Status/ 

D

12 214960 NREL/DOE Groundwater

Monitoring Well 

Permit to Construct a Well (MW-11) 

Colo. Div. OfWater Resources 

STM construct

completenumber awell is cl

13 214961 NREL/DOE Groundwater

Monitoring Well 

Permit to Construct a Well (MW-10) 

Colo. Div. OfWater Resources 

STM construct

completenumber awell is cl

14 214962 NREL/DOE Groundwater

Monitoring Well 

Permit to Construct a Well (MW-09) 

Colo Div. OfWater Resources 

STM construct

completenumber awell is cl

15 99JE0400 NREL/DOE Air TCPDU air emissions CDPHE STM initial ap

issued 7/

16 20030373 thru

20030378 

NREL Permit Hazardous material

storage and use permit

West Metro Fire ProtectionDistrict 

6 STM facilities 

(Building 16,

WHF, SERF, 

FTLB, AFUF, 

Shipping &

Receiving

Facility)

2004 

Notifications and

Registrations

17 PWSID

Number 

CO0230860 

DOE DRINKING

WATER

Non-community supply of hauledwater from asurface water source 

CDPHE NWTC site N/A 

NREL Environmental Performance Report- 2004 
Tracking

Number 

Permit or 

Registration

Number 

Permit or 

Reg. Holder

Permit Type Permit 

Description 

Issuing

Agency Name

Location

Description 

Status/ 

D

18 CO4890000017 DOE HAZARDOUS

WASTE 

Notification ofRegulated Waste Activity

CDPHE DWOP update re

every 3-5 sooner if changes occur. L7/97 

19 CO3890090076 DOE HAZARDOUS

WASTE 

Notification ofRegulated Waste Activity

CDPHE STM update re

every 3-5 sooner if changes occur. L7/97 

20 COD980805162 DOE HAZARDOUS

WASTE 

Notification ofRegulated Waste Activity

CDPHE JSF update re

every 3-5 sooner if changes occur. L7/97 

21 COD983802448 DOE HAZARDOUS

WASTE 

Notification ofRegulated Waste Activity

CDPHE NWTC update re

every 3-5 sooner if changes occur. L7/97 

22 COR000207563 DOE HAZARDOUS

WASTE 

Notification ofRegulated Waste Activity

CDPHE ReFUEL Issued Ja

23 001 and 002 DOE AIR: OZONE

DEPLETING SUBSTANCES

Registration ofstationaryappliances (2 SERF chillers) 

CDPHE SERF annual re

July 1 

24 N/A DOE AIR: OZONE 

DEPLETING SUBSTANCES

FacilityNotification

CDPHE STM, NWTC annual no

and fee dDecembe

NREL Environmental Performance Report- 2004 
Tracking

Number 

Permit or 

Registration

Number 

Permit or 

Reg. Holder

Permit Type Permit 

Description 

Issuing

Agency Name

Location

Description 

Status/ 

D

25 001 DOE AIR: OZONE

DEPLETING SUBSTANCES

Registration ofstationaryappliance (chiller in DWOP) 

CDPHE DWOP annual re

July 1 

26 2873-001 and

2873-002 

DOE ABOVE GROUND

STORAGE TANK

Registration ofabovegroundstorage tanks

Colorado Dept. of Labor 

STM--PDU

Ethanol Storage

Tank, SERF 

Emergency

Generator Tank

annual reand fee, dApril/Ma

27 93000378 DOE Historic Registration National Register 

of Historic Places

National ParkService 

Colorado 

Amphitheater 

no expira

28 93000379 DOE Historic Registration National Register 

of Historic Places

National ParkService 

Ammunition

Igloo 

no expira

29 AFP-CO-00255 DOE Alcohol (not an

environmental permit) 

AlcoholProducer's Permit

Bureau ofAlcohol,Tobacco, and Firearms

AFUF (PDU) annual re

July 1 

30 TF-CO-0331 DOE Alcohol (not an

environmental permit) 

Industrial Alcohol User Permit 

Bureau ofAlcohol,Tobacco, and Firearms

NREL-wide annual re

July 1 

31 N/A NREL Transportation Hazardous

Material Transportation

U.S. Department ofTransportation

NREL-wide annual re

fee 

32 76381 NREL Registration X-Ray Machine

CertificationReport

CDPHE SERF Expires 6

33 68808 Registration

NREL

X-Ray Machine

CertificationReport

CDPHE SERF Expires 2

34 61007 NREL Registration X-Ray Machine

CertificationReport

CDPHE SERF Expires 1

NREL Environmental Performance Report- 2004 
REL Environmental Performance Report- 2004 

Tracking

Number 

Permit or 

Registration

Number 

Permit or 

Reg. Holder

Permit Type Permit 

Description 

Issuing

Agency Name

Location

Description 

Status/ 

D

35 7309L NREL Registration X-Ray Machine

CertificationReport

CDPHE SERF Expires 1

36 COR10000F DOE Notice of Intent

(NOI) 

Stormwater Discharges Associated withConstruction Activity Under anNPDES General Permit 

EPA S&TF Active 

37 COR10000F NREL/MRI Notice of Intent

(NOI) 

Stormwater Discharges Associated withConstruction Activity Under anNPDES General Permit 

EPA S&TF Active 

N
APPENDIX B 

Common and Scientific Names of Wildlife Species Observed During 

Wildlife Surveys at the National Renewable Energy Laboratory South

Table Mountain Site, Golden, Colorado

NREL Environmental Performance Report- 2004
Wildlife Species Observed at the National Renewable Energy Laboratory 

South Table Mountain Site, Golden, Colorado. 

COMMON NAME SCIENTIFIC NAME

Reptiles 

Bull snake1 Pituophis catenifer

Plains garter snake Thamnophis radix 

Six-lined racerunner Cnemidophorus sexlineatus 

Tiger salamander Ambystoma tigrinum

Western rattlesnake Crotalus viridus 

Birds 

American crow Corvus brachyrhynchos 

American kestrel Falco sparverius 

American robin Turdus migratorius 

American tree sparrow Spizella arborea 

Barn swallow Hirundo rustica 

Black-billed magpie Pica pica 

Black-capped chickadee Poecile atricapilla 

Black-crowned night heron Nycticorax nycticorax 

Blue jay Cyanocitta cristata

Brewer's blackbird Euphagus cyanocephalus

Brown headed cowbird Molothrus ater 

Bullock's oriole Icterus bullockii 

California gull Larus californicus 

Canada goose Branta canadensis 

Common nighthawk Chordeiles minor

Common raven Corvus corax 

Common snipe Gallinago gallinago 

Cooper’s hawk Accipiter cooperii 

Dark-eyed junco Junco hyemalis 

Downy woodpecker Picoides pubescens 

European starling Sturnus vulgaris 

Flycatcher Empidonax sp.

Golden eagle Aquila chrysaetos 

Great blue heron Ardea herodias 

Horned lark1 Eremophila alpestris 

House finch Carpodacus mexicanus 

House sparrow Passer domesticus 

Killdeer Charadrius vociferous 

Lark bunting Calamospiza melanocorys 

Loggerhead shrike Lanius ludovicianus 

MacGillivray’s warbler Oporornis tolmiei 

Mallard Anas platyrhynchos 

Mountain bluebird Sialia currucoides 

Mourning dove Zenaida macroura 

Northern flicker Colaptes auratus 

Northern harrier Circus cyaneus 

Osprey Pandion haliaetus 

Prairie falcon Falco mexicanus 

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COMMON NAME SCIENTIFIC NAME

Red-breasted nuthatch Sitta canadensis 

Red-tailed hawk Buteo jamaicensis 

Red-winged blackbird Agelaius phoeniceus 

Rock dove Columba livia 

Rock wren Salpinctes obsoletus 

Say's phoebe Sayornis saya 

Sharp-shinned hawk Accipiter striatus

Spotted towhee Pipilo maculates 

Swainson’s hawk Buteo swainsoni 

Tree swallow Tachycineta bicolor

Turkey vulture Cathartes aura

Unidentified sparrow 1 - 

Unidentified sparrow 2 - 

Unidentified species - 

Unidentified warbler - 

Vesper sparrow Pooecetes gramineus 

Western kingbird Tyrannus verticalis 

Western meadowlark Sturnella neglecta

Western scrub jay Aphelocoma californica 

White-crowned sparrow Zonotrichia leucophrys 

Mammals

Black-tailed jackrabbit1 Lepus californicus 

Bushy-tailed woodrat1 Neotoma cinerea 

Coyote Canis latrans 

Deer mouse Peromyscus maniculatus

Fox squirrel Sciurus niger

Long-tailed weasel Mustela frenata 

Mexican woodrat Neotoma mexicana 

Mountain cottontail Sylvilagus nuttalli 

Mule deer Odocoileus hemionus 

Prairie vole Microtus ochrogaster

Raccoon Procyon lotor

Red fox Vulpes vulpes 

Western harvest mouse Reithrodontomys megalotis 

White-tailed jackrabbit Lepus townsendii 

Yellow-bellied marmot1 Marmota flaviventris

 1 Species observed during the 1987 survey, but not during the 2004-2005 surveys.

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