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

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

Annual Site Environmental Report per the U.S. Department of Energy Order 231.B 

ENVIRONMENTAL 

PERFORMANCE REPORT 2015 
Printed with a renewable-source ink on 100% recycled paper and 100% post consumer waste.

Cover Photo: NREL researcher characterizes the electrical properties of a solar cell and assesses the functionality of a large prototype 

collimating tube. Photo by Dennis Schroeder, NREL 35526 

This report was prepared as an account of work sponsored by an agency of the United States government. Neither the United 

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

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

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

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

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

herein do not necessarily state or reflect those of the United States government or any agency thereof. 
ENVIRONMENTAL PERFORMANCE REPORT 2015

 

 

 

 

This report requires a tremendous amount of data, 

collaboration, and review to be made possible. 

Thank you to all who contributed their time and 

effort to this publication. 

The National Renewable Energy Laboratory’s 

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

Office staff provided their subject matter expertise 

by authoring content, providing data, and 

conducting technical reviews: 

Brenda Beatty 

Genevieve Braus 

Theodore DeVito 

Larry Durbin 

John Eickhoff 

Maureen Ray 

Tom Ryon 

Kurt Schlomberg 

Eric Schmitz 

Frank Rukavina and the Sustainable NREL team 

provided the report’s sustainability content. 

Lissa Myers and Suzanne Belmont provided content 

for the Climate Change Adaptation Management 

and Traffic Management sections of the report. 

Leigh Ramsey and Kathryn Ruckman with NREL’s 

Communications and Public Affairs Office provided 

project support and editing. 

Lisa Jorgensen, Laura Margason, Nicole Serio, and 

Robin Sweeney, with the U.S. Department of Energy 

Golden Field Office, worked closely with staff of the 

Alliance for Sustainable Energy, LLC, on their review 

and approval of this document. 

ACKNOWLEDGEMENTS CONTACT US 

We welcome your feedback and suggestions on this 

report and on NREL’s efforts toward sustainability and 

environmental stewardship. To provide comments, 

request a printed copy of this report, or obtain 

additional information about NREL’s environmental programs, please contact any of the NREL staff 

members listed below: 

Maureen Ray 

Director, Environment, Health, 

and Safety Office 

maureen.ray@nrel.gov 

303-275-3248 

John Eickhoff 

Environmental Manager 

john.eickhoff@nrel.gov 

303-275-3217 

Sarah Sloan 

Director, Communications & 

Public Affairs Office 

sarah.sloan@nrel.gov 

303-275-3650 

This report is available online at: 

www.nrel.gov/about/ehs.html 

National Renewable Energy Laboratory 

15013 Denver West Parkway, Golden, CO 80401 

303-275-3000 

www.nrel.gov 

1 
ENVIRONMENTAL PERFORMANCE REPORT 2015

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

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

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

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

About NREL ............................................................................................ 6 

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

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

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

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

2 Significant Site Activities in 2015 ...........................................17 

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

2.2 Integrated Environmental Stewardship in 

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

3 Environmental Management System and 

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

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

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

3.3 Assessment and Improvement ........................................23 

3.4 2015 Awards and Recognition .........................................24 

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

4.1 Sustainability Goals Performance ...................................28 

4.2 Climate Change Adaptation Management..................32 

5 Compliance Summary ................................................................34 

6 Air Quality Protection .................................................................43 

7 Water Quality Protection ...........................................................47 

7.1 Drinking Water .......................................................................47 

TABLE OF CONTENTS 

NREL Environmental Performance Report 2015 

Panoramic view of the eastern portion of the South Table Mountain site. Photo by Dennis Schroeder, NREL 30254 

2 
ENVIRONMENTAL PERFORMANCE REPORT 2015

7.2 Groundwater...........................................................................49
 

7.3 Surface Water..........................................................................50
 

7.4 Wastewater..............................................................................52
 

8 Hazardous Materials and Waste Management..................53
 

8.1 Hazardous Materials Management.................................53
 

8.2 Regulated Waste Management........................................55
 

8.3 Aboveground Storage Tank Management...................57
 

8.4 Spill Prevention and Response.........................................58
 

8.5 Radiological Materials and Waste Management........59
 

9 National Environmental Policy Act ........................................61
 

10 Natural and Cultural Resources Protection.........................64
 

10.1 Wildlife Management........................................................65
 

10.2 Endangered Species and Species of Concern ..........68
 

10.3 Vegetation Management.................................................69
 

10.4 Wetlands and Floodplains ...............................................72
 

10.5 Cultural Resources..............................................................73
 

11 Conservation Easement Lands ...............................................76
 

12 Traffic Management ....................................................................79
 

Appendix A: Plant Communities at the 


STM Site and the NWTC ...................................................................82
 

Appendix B: Wildlife Species Observed at the
 

STM Site and the NWTC ...................................................................89
 

Appendix C: Environmental Permits, Registrations,
 

and Notifications Applicable to NREL During 2015...............96
 

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ENVIRONMENTAL PERFORMANCE REPORT 2015

NOMENCLATURE 

APCD – Air Pollution Control Division of CDPHE 

APEN – Air Pollutant Emission Notice 

AST – Aboveground Storage Tank 

CCR – Colorado Code of Regulations 

CDLE – Colorado Department of Labor and Employment 

CDPHE – Colorado Department of Public Health and Environment 

CFR – Code of Federal Regulations 

CO2 – Carbon Dioxide 

CO2e – Carbon Dioxide Equivalent 

CRS – Colorado Revised Statute 

CWA – Clean Water Act 

CX – Categorical Exclusion 

DOE – U.S. Department of Energy 

DOE Order – Department of Energy Order 

DOPS – Division of Oil and Public Safety of the Colorado Department of 

Labor and Employment 

DWOP – Denver West Office Park 

EA – Environmental Assessment 

EERE – Energy Efficiency and Renewable Energy 

EHS – Environment, Health, and Safety 

EIS – Environmental Impact Statement 

EMS – Environmental Management System 

EPA – U.S. Environmental Protection Agency 

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

ESA – Endangered Species Act 

ESIF – Energy Systems Integration Facility 

EO – Executive Order 

FTLB – Field Test Laboratory Building 

FY – Fiscal Year 

IBRF – Integrated Biorefinery Research Facility 

ISO – International Organization for Standardization 

MBTA – Migratory Bird Treaty Act 

mrem – Millirem 

MW – Megawatt 

NEPA – National Environmental Policy Act 

NREL – National Renewable Energy Laboratory 

NWTC – National Wind Technology Center 

ODS – Ozone Depleting Substances 

RFHP – Renewable Fuel Heating Plant 

RSF – Reseach Support Facility 

RTD – Regional Transportation District 

SDS – Safety Data Sheet 

SERF – Solar Energy Research Facility 

SPCC – Spill Prevention Control and Countermeasures 

S&TF – Science and Technology Facility 

STL – Structural Testing Laboratory 

STM – South Table Mountain 

USACE – U.S. Army Corps of Engineers 

WQCD – Water Quality Control Division of CDPHE 

4 
ENVIRONMENTAL PERFORMANCE REPORT 2015

EXECUTIVE SUMMARY 

The Peregrine supercomputer at NREL’s Energy Systems 

Integration Facility is capable of performing more than 

a quadrillion calculations per second. Ninety percent of 

the computer’s waste heat is captured and used as the 

primary heat source for the Energy Systems Integration 

Facility offices and laboratory space. Photo by 

Dennis Schroeder, NREL 31716 

Purpose 

The National Renewable Energy Laboratory’s (NREL’s) 

Environmental Performance Report provides a description of the laboratory’s environmental management 

activities for 2015, including information on environmental and sustainability performance, environmental 

compliance activities and status, and environmental 

protection programs, highlights, and successes. 

The purpose of this report is to ensure that the U.S. 

Department of Energy (DOE) and the public receive 

timely, accurate information about events that have 

affected or could adversely affect the health and safety of 

the public or workers, the environment, or the operations 

of DOE facilities. This report meets the DOE requirements 

of the Annual Site Environmental Report and has been 

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

Environment, Safety and Health Reporting. 

Environmental and 

Sustainability Performance 

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

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

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

environmental protection into daily work practices. The 

Environmental Management System is structured based on 

a plan-do-check-act continual improvement management 

model and is implemented as part of an Integrated Safety 

Management System. 

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ENVIRONMENTAL PERFORMANCE REPORT 2015

ABOUT NREL 

NREL is the principal research laboratory for DOE’s 

Office of Energy Efficiency and Renewable Energy. 

The laboratory also conducts research for the Office 

of Science and the Office of Electricity Delivery 

and Energy Reliability. The Alliance for Sustainable 

Energy, LLC, a partnership between MRIGlobal 

and the Battelle Memorial Institute, manages the 

laboratory for the Office of Energy Efficiency and 

Renewable Energy. 

NREL is the only DOE national laboratory solely 

dedicated to advancing renewable energy and 

energy efficiency technologies from concept 

to commercial application. The laboratory’s 

innovations, analysis, and expertise have enabled 

the emergence of a U.S. clean energy industry 

and led to numerous success stories from across 

the laboratory. NREL’s two sites, the 327-acre 

(132 hectares) South Table Mountain site in Golden, 

Colorado, and the 305-acre (124 hectares) National 

Wind Technology Center in northern Jefferson 

County, are living models of sustainable energy 

integration. 

NREL develops renewable energy and energy 

efficiency technologies and practices, advances 

related science and engineering, and transfers 

knowledge and innovations to address the nation’s 

energy and environmental goals. The laboratory’s 

research and development achievements have 

helped shape clean-energy alternatives for 

powering our homes and businesses, and the 

nation’s transportation infrastructure. NREL’s science 

and technology teams span the full spectrum of 

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

testing and validation. 

Each year, the laboratory sets measurable goals for environmental improvement through the NREL Environmental 

Management System planning process. Goals are also 

established through the Performance Evaluation Measurement Plan and the Site Sustainability Plan. Progress of 

all goals is tracked throughout the year using an online 

software tracking system. A summary is prepared annually 

for the DOE Golden Field Office on Performance Evaluation Measurement Plan results and for DOE Headquarters 

on Site Sustainability Plan results. The laboratory identified 

several goals in 2015 to enhance sustainability and environmental performance and continues to make significant 

progress toward them. 

Sustainability is integral to both NREL’s research and operations, and the laboratory is committed to demonstrating federal leadership in sustainability and continuously 

improving performance. Sustainable NREL, an interdisciplinary initiative involving staff from across the organization, 

fosters environmental and social responsibility, working to 

establish NREL as a global model for sustainability. 

The following are some of the laboratory’s key 

accomplishments: 

■■	 Achieved key short-term internal environmental and 

sustainability goals, and made progress toward 

long-term goals (For more details, see section 3, 

Environmental Management System and Pollution 

Prevention, and section 4, Sustainability) 

■■	 Received several awards and recognitions for 

environmental and sustainability accomplishments 

(see sidebar on page 7) 

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

certification 

An NREL technician replaces an anemometer on a NWTC 

meteorological tower. Anemometers provide wind speed data 

that, along with other data collected, allow NREL staff and industry 

partners to evaluate the performance of wind turbines under 

varying environmental conditions. Photo by Jerry Hur, NREL 36267 

6 
ENVIRONMENTAL PERFORMANCE REPORT 2015

■■	 Maintained Colorado Environmental Leadership 

Program Gold-Level Leader status, the highest level 

awarded by the state-sponsored program 

■■	 Received commendation from Jefferson County Public 

Health for detailed and comprehensive management 

of the National Wind Technology Center drinking water 

system and for the extent of protection of the water 

from delivery to consumption 

■■	 Successfully restored, after more than two years of 

restoration efforts that included temporary irrigation and weed management, a portion of the South 

Table Mountain site disturbed as part of construction 

of the Energy Systems Integration Facility, thus allowing termination of Environmental Protection Agency 

stormwater permit coverage 

■■	 Developed slope stabilization designs for steep hillsides at the South Table Mountain site which, when 

implemented, will stabilize areas that became unstable 

in the significant rain events of recent years, and 

restore native vegetation and habitat for area wildlife 

■■	 Held a community open-house in coordination with 

the DOE Golden Field Office during which information 

was presented concerning environmental stewardship 

at NREL 

■■	 Held a workshop sponsored by the DOE Golden Field 

Office and led by the U.S. Fish and Wildlife Service 

covering topics that included the Migratory Bird Treaty 

Act and associated case law, related regulations, and 

how these regulations specifically apply to DOE sites 

■■	 Installed nest boxes in areas around the South Table 

Mountain site that were used by tree swallows to 

successfully fledge several broods 

In the Systems Performance Laboratory, engineers connect 

electric vehicles and smart appliances to a simulated grid to study 

the dynamics of how they interact. Photo by Dennis Schroeder,

 NREL 32474 

■■	 Girdled and applied herbicide to 15 Russian olive trees 

across the South Table Mountain site and within the 

South Table Mountain Conservation Easement 

to kill the trees and prevent the spread of this 

invasive species 

■■	 In cooperation with the Colorado Department of Agriculture, introduced a rust fungus (Puccinia punctifomis) 

at two locations, one on the South Table Mountain site 

and the other on the National Wind Technology Center, 

to combat Canada thistle a noxious weed 

■■	 Hosted the spring quarterly meeting of the Colorado 

Noxious Weed Network 

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

alternative commuting options such as providing 

access to mass transit, vanpool discounts, preferred 

parking for carpool/vanpool vehicles, ride-share coordination, and bicycle and pedestrian infrastructure. 

ENVIRONMENTAL COMPLIANCE 

AND MONITORING 

NREL is subject to many federal, state, and local environmental laws and regulations, in addition to executive 

orders, DOE requirements, and agreements with government agencies. Unlike many other DOE facilities, NREL 

does not conduct work involving nuclear materials and 

does not have legacy radiological or other contamination 

issues associated with past nuclear weapons production 

or research activities; therefore, continuous radiation or 

radiological contamination monitoring is not conducted. 

Prestigious Environmental 

Sustainability Awards Received 

NREL received several important recognitions 

in 2015 for its environmental and sustainability 

accomplishments including: 

■■	 A DOE Green Buy Program Gold Award
 

for purchasing 13 products in six different
 

categories, achieving DOE’s Green Buy
 

leadership goal
 

■■	 Three Star Electronic Product Environmental 

Assessment Tool Purchases Award from the 

Green Electronics Council for excellence in 

green procurement of electronics 

7 
ENVIRONMENTAL PERFORMANCE REPORT 2015

The laboratory continued its excellent record of environmental compliance in 2015. No violation notices were 

received from any regulatory agency and all required 

permits were received or renewed; required registrations 

were completed; and required notifications and reports 

were submitted. 

Environmental Management Programs 

The laboratory continues to meet or exceed compliance 

requirements and strives to make continual improvements 

in environmental management. Major environmental 

program areas include: 

■■	 Air quality protection including air permitting, ozone 

depleting substance management, and greenhouse 

gas emissions monitoring 

■■	 Water quality protection including construction 

stormwater management, drinking water monitoring, 

and preventing unallowable sanitary sewer 

system discharges 

■■	 Hazardous materials and waste management including 

pollution prevention, spill response, proper storage, 

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

regarding use and emissions of such materials 

■■ National Environmental Policy Act reviews 

■■ Natural and cultural resources protection, including 

wildlife, vegetation, protected species, wetlands, and 

cultural resources management. 

NREL’s Continued International 

Organization for Standardization 

14001 Certification Demonstrates 

Commitment to Environmental 

Leadership 

The laboratory maintained International 

Organization for Standardization 14001:2004 

certification of its environmental management 

system. A team of external auditors conducted 

an independent assessment of the policies, 

procedures, tools, and roles and responsibilities 

used in environmental management. 

The assessment verified that the laboratory 

continues to meet the requirements of 

the International Organization for 

Standardization 14001 standard and 

demonstrates he laboratory’s commitment 

to environmental stewardship. 

The laboratory continued to improve its environmental 

management and performance in 2015, as demonstrated 

by a track record of excellent compliance with regulatory 

requirements and established leadership in environmental and sustainability management. 

8 
ENVIRONMENTAL PERFORMANCE REPORT 2015

 

 

1 INTRODUCTION 

An engineer operating the silicon cluster tool in the Science 

and Technology Facility. The tool is used to develop 

techniques to explore and enhance potential industry 

practices for fabricating silicon solar cells. Photo by 

Pat Corkery, NREL 16555 

1.1 PURPOSE 

This report presents a summary of the National 

Renewable Energy Laboratory’s (NREL’s) environmental 

management activities in 2015, including: 

■■	 Environmental protection programs 

■■	 Environmental and sustainability performance 

■■	 Environmental compliance activities and status 

■■	 Environmental management highlights and successes. 

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

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

Environmental Report, as required by DOE Order 231.1B 

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

1.2 OUR MISSION 

NREL’s mission focuses on advancing the energy goals 

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

mission statement: 

NREL develops renewable energy and energy efficiency 

technologies and practices, advances related 

science and engineering, and transfers knowledge 

and innovations to address the nation’s energy and 

environmental goals. 

NREL fulfills its mission through technology portfolios. A 

brief description of each major technology area follows. 

■■	 Basic science – Fundamental research is conducted 

in the sciences that underlie renewable energy and 

energy efficient technologies. 

■■	 Bioenergy – NREL has major programs in biomassderived fuels (biofuels) and biomass-derived 

electricity (biopower), and projects in biomassderived chemicals and materials. 

9 
ENVIRONMENTAL PERFORMANCE REPORT 2015

An NREL engineer analyzes fluids from materials such as corn 

stover and beetle kill wood that have the potential to be used as 

renewable transportation fuels or high value chemicals. Photo by 

Dennis Schroeder, NREL 33050 

■■	 Building energy – NREL supports research and 

development of technologies and practices for energy 

efficiency, working closely with the building industry 

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

and works with state and local regulatory groups to 

improve building codes and appliance standards. 

■■	 Computational sciences – This area includes basic and 

applied research using high-performance computing 

and applied mathematics. 

■■	 Distributed power – Distributed power draws upon 

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

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

enhancement of the traditional electric power grid. 

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

incorporation of renewable and energy efficiency 

technologies in distributed power systems. 

■■	 Electricity technologies – Research is conducted to 

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

■■	 Energy analysis – Energy analysis at NREL is performed 

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

advance from concept to commercial application 

to market penetration. 

■■	 Hydrogen – NREL is a leader in renewable hydrogen 

production technologies and the development of 

codes, standards, and advanced storage and sensors. 

Hybrid electric vehicles charging at the Vehicle Testing and 

Integration Facility solar canopy. Photo by Dennis Schroeder, 

NREL 31895 

Basic and applied research and material development 

using biology, physics, and chemistry enable and 

support the development of hydrogen production, 

storage, and end-use systems. 

■■	 Measurements and testing – NREL laboratories and 

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

cells, building technologies, and wind turbines. 

■■	 Photovoltaics – Photovoltaic cells enable the direct 

conversion of sunlight to electricity using solid-state 

materials. The National Center for Photovoltaics 

develops and deploys photovoltaic technology for the 

generation of electric power. 

■■	 Renewable energy resources – Researchers develop 

resource information for solar, wind, biomass, and 

geothermal energy applications. 

■■	 Renewable thermal technologies – Research 

is conducted in thermal technologies including 

concentrating solar power, solar water heating, and 

geothermal heat and power, which generate power 

from heat or utilize heat from renewable resources. 

■■	 Transportation – NREL works with industry experts 

to develop advanced vehicles and transportation 

systems. NREL also works with energy companies and 

manufacturers of vehicles and engines to develop 

advanced motor vehicle fuels for improved energy and 

environmental performance. 

■■	 Wind energy – Through the National Wind 

Technology Center, NREL develops, improves, and 

demonstrates the viability of wind technology for 

electricity generation and facilitates its utilization 

throughout the world. 

10 
ENVIRONMENTAL PERFORMANCE REPORT 2015

 

NREL senior engineers view velocity (blue) and turbulence (yellow) 

at a simulated wind farm in the Energy Systems Integration Facility’s 

Visualization Laboratory. Photo by Dennis Schroeder, NREL 31408 

1.3 SITE AND FACILITY DESCRIPTION 

NREL’s five facilities occupy four separate locations in
 

Jefferson County, Colorado, and one location in the City
 

and County of Denver. These include:
 

■■ National Wind Technology Center (NWTC)
 

■■ South Table Mountain (STM)
 

■■ Denver West Office Park
 

■■ Joyce Street Facility
 

■■ Renewable Fuels and Lubricants Research Laboratory.
 

The STM site and the NWTC are the primary locations
 

where NREL research operations are conducted. The
 

Denver West Office Park is leased space used primarily for
 

administrative functions and limited research activities.
 

The leased Joyce Street Facility space is primarily used for 

storage. The Renewable Fuels and Lubricants Research 

Laboratory facility is a leased research space that consists 

of a single vehicle high bay and small office area housed 

within the Regional Transportation District’s District Shops 

and Operations Center facility in Denver. 

Laboratory staff also conduct work at additional locations 

as needed; for example, at the Solar Technology Acceleration Center described on page 16. 

Climate 

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

precipitation, low relative humidity, abundant sunshine, 

and large daily and seasonal temperature variations. 

The area experiences moderate precipitation, with an 

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

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

begins to decrease significantly in the fall, reaching the 

minimum during winter. Winter is the driest season, 

contributing less than 10% of the annual precipitation, 

primarily in the form of snowfall. 

Spring is a season of unstable air masses with strong 

winds along the foothills and the Front Range. The 

highest average snowfall typically occurs in March, 

during which time at least one heavy snowstorm of 

between 6 to 10 inches (15 to 25 cm) may occur. 

South Entrance 

Employee 

Parking 

Café 

RSF 

STM Stormwater 

Detention Basin 

West Entrance 

East Entrance 

Education Center 

Visitor Parking 

ESIF 

RFHP SERF

S&TF 

IBRF 

TTF 

OTF 

FTLB 

VTIF 

HighFlux 

Solar Furnace 

Photovoltaic 

Arrays SRRL 

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

11 
ENVIRONMENTAL PERFORMANCE REPORT 2015

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. 

South Table Mountain Site 

The STM site is the main research center for NREL— 

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

laboratories there. The STM site is approximately two 

miles (3.2 kilometers [km]) east of Golden and 12 miles 

(19.3 km) west of central Denver. 

Land Use 

The STM site is a roughly triangular parcel of land occupying portions of the top, sides, and lower south-facing 

slopes of South Table Mountain, a mesa that stands 

approximately 492 feet (150 meters) above the adjacent 

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

to erosion. 

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

and light commercial activity. Portions of the community 

of Pleasant View are located immediately to the south and 

west. Pleasant View has constructed a recreational park 

immediately south of the STM 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 drivertraining 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 eastern edges 

of the site. Portions of the Denver West Office Park and 

apartment homes lie to the east. 

More than half of the STM site (177 acres / 72 hectares) 

has been set aside in a conservation easement. No development is allowed on that land, with the exception of 

some existing utility easements and recreational trails to 

be established by Jefferson County Open Space. (For more 

details, see section 11, Conservation Easement Lands.) 

Geology, Soils, and Hydrogeology 

The mesa was formed as weak sedimentary rocks 

surrounding lava were eroded away, leaving the lavacapped mesa in relief. Below the lava caprock, the 

sedimentary rocks are part of the Denver Formation that 

consists of layers and lenses of claystone, sandstone, 

and conglomerate. Sedimentary rocks of the Arapahoe 

Formation underlie the Denver Formation. 

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

Denver Formation underlies the areas on which most 

NREL construction has taken place. Groundwater on the 

STM site occurs primarily in the weathered and fractured 

silts and sands of the Denver Formation. There may also 

be some groundwater in the form of perched aquifers 

Melting snow from the roof of the Research Support Facility is captured in a landscaped catch basin. These same basins receive stormwater 

runoff from the roof later in the year, providing water to trees and grasses planted within them. Photo by Dennis Schroeder, NREL 18643 

12 
ENVIRONMENTAL PERFORMANCE REPORT 2015

Flowering prickly pear at the STM site. Photo by Brent Nelson, NREL 23871 

below the basaltic lava cap on South Table Mountain, and 

within the materials above the Denver Formation, which 

are largely the result of stream deposits. Groundwater 

flow on the site is in a southeasterly direction. 

The soil covering the top of South Table Mountain is 

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

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

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

slopes of South Table Mountain is also a loam consisting 

of extremely stony soils with significant amounts of clay. 

Much of the remainder of the site, including the area 

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

of clayey material containing some calcium carbonate. 

There are also two smaller soil areas on the southwestern 

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

soils—cobbly clay loam and very stony clay loam. 

Surface Water 

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

from the mesa top and across the lower portions of 

the site, flows in a southeasterly direction toward Lena 

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

permanent stream flow on the STM site, occasional flow 

from extended periods of precipitation, usually during 

the late winter and early spring, is found in the drainage 

channels, with seasonal springs evident along some of 

the mesa slopes. The mesa top features one seep 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 more than 80% of the vegetation on the 

site. These communities are generally dominated by 

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

communities occur on the STM site: mountain mahogany 

shrublands, found on the shallow soils of the mesa, and 

upland shrublands, occurring in drainages lacking active 

channels as well as drainages with associated wetlands. 

Field surveys have identified limited wetland and riparian areas along drainages. The wetland communities 

identified on the STM site are a minor component of the 

total vegetation cover, accounting for less than 1% of the 

vegetation over an area of less than 0.75 acres (0.3 hectares). Riparian shrub communities also occur adjacent to 

the emergent wetlands. A vegetation survey of the STM 

site was conducted in 2010. (For more details, see section 

10.3, Vegetation Management.) 

Wildlife 

Several comprehensive wildlife surveys have been 

conducted on the site, starting with the original study 

in 1987. Additional surveys were done in 1999 of the 

conservation easement property. Surveys to update existing data were completed in 2005 and in 2011. (For more 

details, see section 10.1, Wildlife Management.) 

Mammals identified during the surveys included mule 

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

weasels, striped and spotted skunks, badgers, bobcats, 

mountain lions, rabbits, yellow-bellied marmots, and 

various smaller mammals. More than 50 species of birds 

have been recorded on the STM site by the formal wildlife surveys and supplemental employee observations. A 

number of raptor species have been recorded at or above 

the STM site, especially during spring migration. Two 

raptor species are resident at the site: American kestrel 

and red-tailed hawk. Reptiles and amphibians inhabit 

the area as well. Most notably, the western rattlesnake is 

routinely encountered around the site area. 

13 
ENVIRONMENTAL PERFORMANCE REPORT 2015

 

Building 251 Switch Gear 

Building 

Grid Storage 

Pads 

Test Prep 

Building 

CGI 

5 MW 

Dynamometer 

2.5 MW 

Dynamometer STL 

Modal 

Lab DERTF A-60 

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

National Wind Technology Center 

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

border just east of the foothills of the Rocky Mountains, 

the NWTC has abundant wind resources that are critical 

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

is located near the intersection of Highways 93 and 128, 

between Boulder and Golden, and is approximately 

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

Land Use 

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

surrounded by open space, grazing, and industrial land 

uses. The Rocky Flats National Wildlife Refuge (RFNWR) 

borders the NWTC to the south and east. A sand and 

gravel mine currently being restored is located due south 

(on RFNWR property), and an expanded shale and clay 

lightweight aggregate production operation is located 

along the southern portion of the western boundary of 

the site. A propellant fracturing company also has a small 

installation along the northern portion of the western site 

boundary. The City of Boulder owns open space bordering 

the NWTC to the north; State Highway 128 lies to the 

north of that open space. 

Geology, Soils, and Hydrogeology 

The NWTC is located on a plain formed by stream deposits. The uppermost geological layer beneath the site is 

known as the Rocky Flats Alluvium. It is composed of 

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

Rocky Flats Alluvium are the Laramie Formation, Fox Hills 

Sandstone, and Pierre Shale. These rock formations consist 

primarily of claystones with some siltstones. Unconfined 

groundwater flow occurs in the Rocky Flats Alluvium 

toward the east/southeast, and small perched zones are 

common. Groundwater occurs as confined aquifers in the 

deeper bedrock formations.1 

The NWTC has a strongly developed soil defined as a very 

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

amount of cobble and gravel in the soil volume, and 

subsoil dominated by clay. 

Surface Water 

The area surrounding the NWTC is drained by five streams: 

Rock Creek, North Walnut Creek, South Walnut Creek, 

Woman Creek, and Coal Creek. Rock Creek flows eastward 

and is located southeast of the NWTC. North Walnut Creek 

and South Walnut Creek flow eastward into the Great 

Western Reservoir. Woman Creek drains eastward into 

Standley Lake. Coal Creek flows in a northeasterly 

direction across the City of Boulder Open Space north of 

the NWTC. 

The majority of the NWTC drains into a tributary to Rock 

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

Coal Creek or its tributaries. 

Vegetation 

The NWTC is located in the transition area between the 

Great Plains and the Rocky Mountains.2

 This location 

results in a flora that contains elements from both 

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

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

14 
ENVIRONMENTAL PERFORMANCE REPORT 2015

Mule deer at the NWTC. Photo by Mark McDade, NREL 29825 

mountain and prairie ecosystems, and associations that 

represent residual tallgrass prairie, shortgrass plains, 

ponderosa pine woodland, and foothill ravine flora.3 

Vegetation surveys conducted at the NWTC have identified 271 vascular plant species and defined five major 

habitat types including xeric mixed grasslands, pine 

woodlands, shrublands, wetlands, and disturbed areas. 

Along the northwestern ridge is a ponderosa pine 

woodland area. Vegetation found in this area includes 

woody species with an understory of grasses, forbs, 

and shrubs. The most recent vegetation survey was 

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

Vegetation Management.) 

Wildlife 

Prior to 1975, livestock heavily grazed the NWTC, 

damaging a majority of the native vegetation. DOE 

prepared a biological characterization inventory in 1992 

for the entire Rocky Flats Plant, including the NWTC, 

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

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

mountain lions were identified. Other mammals known 

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

rabbits, white-tailed jackrabbits, black-tailed jackrabbits, 

deer mice, prairie voles, and thirteen-lined ground squirrels. Approximately 20 species of birds were sighted at or 

near the site. Raptor surveys were conducted at the NWTC 

in 1994 and 1995, and identified seven raptor species 

on or in the vicinity of the site. An avian survey was 

also completed in 2002 and updated in 2011. (For more 

details, see section 10.1, Wildlife Management.) Although 

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

other reptilian and amphibian species are known to 

occupy the area. 

NREL researcher uses a small quantity of biofuel to evaluate the 

combustion kinetics in an Ignition Quality Tester at an NREL Denver 

West laboratory. Photo by Dennis Schroeder, NREL 32870 

Denver West Office Park 

The Denver West Office Park, located within the City of 

Lakewood approximately 2 miles (3.2 km) east of Golden 

and 12 miles (19.3 km) west of central Denver, is a relatively flat, landscaped office complex occupied by a 

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

areas. NREL-leased facilities at this location are situated 

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

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

west by the Pleasant View residential area, Camp George 

West facility, and the STM site. In addition to office spaces, 

activities at the Denver West Office Park include low-risk 

research related to fuel and battery characterization, 

thermal analyses of vehicle cooling loops, vehicle 

electrical systems analysis, and photo-electrochemical 

hydrogen production. 

Joyce Street Facility 

The Joyce Street Facility is located in a commercial area 

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

primarily as warehouse space; there are no staff offices at 

this location. The Joyce Street Facility is located at 6800 

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

West Office Park and the STM site. 

Renewable Fuel and Lubricants 

Research Laboratory 

The Renewable Fuels and Lubricants Research Laboratory is 

used for research, testing, and support activities related to 

advanced fuels, engines, and vehicles to objectively evaluate performance, emissions, and energy efficiency impacts, 

including the evaluation and development of heavy-duty 

3 Ibid. 

15 
16 ENVIRONMENTAL PERFORMANCE REPORT 2015

hybrid vehicles. The laboratory consists of a single vehicle 

high bay and small office area housed within the Regional 

Transportation District’s District Shops and Operations 

Center located at 1900 31st Street, Denver, approximately 

12 miles (20 km) east of the STM site. The District’s Shops 

and Operations Center facility occupies approximately 22 

acres (9 hectares) of land and serves as the primary maintenance facility for the Regional Transportation System’s 

bus and light rail train systems. The area around the facility 

consists of commercial and light industrial development.

The site lies on relatively flat terrain with a slight gradient 

to the northwest. The general area is highly developed 

with concentrated industrial and commercial activities. 

Very little natural vegetated habitat exists on site or in the 

immediate vicinity. There are trees and shrubs lining the 

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

and northeastern borders.

Additional Locations 

Laboratory staff work at additional locations as needed. 

One such location is the Solar Technology Acceleration 

Center, operated by MRIGlobal, located near Denver 

International Airport, northeast of the intersection of East 

26th Avenue and North Hudson Road in Aurora, Colorado. 

The Solar Technology Acceleration Center is a partnership 

of solar equipment manufacturers, research organizations, 

and electric utilities that utilize a real-world outdoor site 

to develop, test, validate, and showcase solar products. 

Approximately 33 miles (54 km) east of the STM site, the 

74-acre (30-hectare) facility provides users with readily 

accessible land and all the necessary infrastructure and 

resources needed to rapidly and economically install their 

technologies. NREL leases several acres at the site. The 

primary project currently being conducted by NREL is the 

testing of photovoltaic technologies through partnerships 

with various equipment manufacturers. 
ENVIRONMENTAL PERFORMANCE REPORT 2015 17

In 2015, numerous minor construction projects were 

commenced, continued, or completed. From concept to 

design to completion, environmental and sustainable 

stewardship practices are integrated into the management of infrastructure and building projects.

2.1 CONSTRUCTION PROJECTS

A brief description of the significant projects that 

occurred on NREL sites during 2015 is as follows:

STM Site

■■ Site preparations including gravel access roads, 

communications/data connectivity, and a 480V 

3-phase electrical service panel were completed on a 

0.7-acre (0.3 hectares) portion of the STM site where 

photovoltaic arrays will be installed for large scale 

reliability testing. 

■■ Improvements to the electrical infrastructure at the 

Thermal Test Facility were completed. The increase 

in electrical service from 800 amps to 1,600 amps 

will better accommodate existing testing and enable 

additional future testing. 

■■ Building maintenance occurred including the 

construction of a new roof at the Shipping and 

Receiving building, and exterior painting at the Shipping and Receiving building, Solar Energy Research 

Facility, and Integrated Biorefinery Facility. 

■■ Infrastructure was erected at the STM site to communicate emergency announcements to staff walking/

working out-of-doors. This infrastructure, which 

includes an omnidirectional speaker mounted atop a 

50-foot steel pole, will complement the public address 

systems already installed in all site buildings. 

2 SIGNIFICANT SITE

ACTIVITIES IN 2015

NREL technician working on a lubrication manifold of a 

next-generation drive train for a wind turbine gearbox. 

Photo by Dennis Schroeder, NREL 32786
18 ENVIRONMENTAL PERFORMANCE REPORT 2015

NWTC

■■ Asphalt roads and parking lots that had degraded over 

the years were repaired and overtopped. In addition, 

several dirt roads that service large megawatt turbines 

as well as other site access roads that require annual 

grading and graveling were asphalt paved. 

2.2 INTEGRATED ENVIRONMENTAL 

STEWARDSHIP IN CONSTRUCTION 

MANAGEMENT

NREL designs and builds new facilities using an approach 

that integrates planning, design, and construction. An 

interdisciplinary team collaborates on each project 

beginning with planning and selection of design, 

continuing through construction. This integrated 

approach allows the laboratory to achieve mission needs 

while addressing environmental, health, safety, and 

community considerations.

Project Planning and Design

Environmental staff participate in an interdisciplinary 

project management team from a project’s initiation 

through construction. This includes developing and 

reviewing scopes of work, facilitating the inclusion of 

environmental requirements and best management 

practices (such as bird-friendly windows) into project 

designs, and monitoring proposed changes throughout 

the project to confirm that potential environmental 

impacts are considered and addressed. Some of the 

2015 projects that demonstrate the integration of 

environmental considerations in planning and design 

include the following: 

■■ An outdoor gravel pad for placement of containerized 

equipment was designed and constructed to provide 

much needed storage space while also promoting 

stormwater infiltration, thus reducing runoff leaving 

NREL property.

■■ An electrical substation, one component of an electrical upgrade project at the NWTC, was designed 

to minimize the area of construction and restore 

surrounding native grasses and habitat in an area that 

has been degraded by offsite sediment deposition.

Environmentally Responsible 

Construction Practices

During construction, DOE and NREL environmental 

staff participate in weekly construction team meetings, 

monitors performance criteria, and provides ongoing 

feedback to the project team regarding environmental 

management. Environmentally responsible construction 

practices include pre-construction review of project 

plans, performing nesting-bird surveys prior to 

commencing earth-disturbing activities, using a 

"plan of the day" to coordinate and control activities, 

implementing stormwater controls prior to starting 

excavations, minimizing impacts to wildlife, tracking 

waste diversion, properly storing hazardous materials, 

and controlling dust.
ENVIRONMENTAL PERFORMANCE REPORT 2015 19

NREL’s Environmental Management System (EMS) 

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

procedures, and programs that integrates environmental 

protection into daily work practices. The laboratory’s 

EMS efforts include:

■■ Protection and enhancement of vegetation, wildlife, 

and natural resources of the laboratory sites

■■ Pollution prevention

■■ Compliance with environmental requirements

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

The laboratory strives to continually minimize waste and 

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

laboratory’s EMS, the Hazard Identification and Control 

program, and the Sustainable NREL program.

Requirements

A new federal Executive Order, EO 13693, Planning for 

Federal Sustainability in the Next Decade, was released, 

cancelling EO 13423, Strengthening Federal Environmental, Energy, and Transportation Management; and EO 

13514, Federal Leadership in Environmental, Energy, and 

Economic Performance. EO 13693 establishes updated 

goals for environmental sustainability in the federal 

government. To meet these goals, federal facilities must 

conserve natural resources, reduce energy use and 

greenhouse gas emissions, develop renewable energy, 

manage buildings and transportation in a sustainable 

manner, and support pollution prevention.

EO 13693, together with DOE Order 436.1, Departmental 

Sustainability, requires that the laboratory implement an 

EMS that conforms to the ISO 14001 structure. The EMS 

is implemented as part of a DOE-required Integrated 

3 ENVIRONMENTAL

MANAGEMENT SYSTEM 

AND POLLUTION 

PREVENTION

An NREL technician installs internal strain gages along a 

turbine blade, connecting the wires to a data acquisition 

system for testing. Photo by Sara Fairchild, NREL 34719
20 ENVIRONMENTAL PERFORMANCE REPORT 2015

Safety Management System, which systematically 

integrates safety and environmental protection into 

management and work practices at all levels to protect 

the public, the worker, and the environment. 

3.1 ENVIRONMENTAL MANAGEMENT 

SYSTEM STRUCTURE

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

continual improvement framework described below and 

depicted in Figure 1. 

Planning

■■ Environmental policy – NREL states its commitments 

to the environment through this overarching policy. 

The policy commits specifically to:

● Environmental stewardship

● Pollution prevention 

● Compliance with legal requirements and 

voluntary commitments

● Continual improvement of environmental and 

sustainability performance.

■■ Environmental aspects – NREL’s environmental 

aspects are those activities, products, or services that 

have the potential to interact with the environment. 

The significance of an identified aspect is determined 

by assigning a frequency of occurrence and a severity. 

Using this method, NREL’s EHS staff review potential 

impacts to the environment annually, and activities 

in the EMS are prioritized by the identified significant 

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

Management System to manage environmental risks.

■■ Legal and other requirements – NREL maintains a 

formal process to identify regulations and standards 

that are necessary and sufficient to address specific 

environmental hazards including federal laws and 

regulations, state and local requirements, executive 

orders (EOs), and DOE orders.

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

Define Scope

Analyze

H

a

zards,

Perform Work

Develop Controls

Feedback &

Improvement

Environment

Quality Safety

Impacts

& Issues

ISO 14001:2004 Certified

NREL’s EMS is certified to the International 

Organization for Standardization (ISO) 

14001:2004 standard for environmental 

management systems. ISO 14001 is a 

globally recognized standard that defines the 

structure of an organization’s EMS to improve 

its environmental performance. ISO 14001 

requires an organization to identify potential 

environmental impacts and establish controls 

needed to minimize impacts, monitor and 

communicate environmental performance, 

and establish a formal process for continually 

improving the system.

Figure 1. NREL’s continual improvement cycle

NREL’s Environmental Aspects

NREL conducts an annual review of its activities 

that could potentially affect the environment. 

The laboratory’s significant environmental 

aspects for 2015 were:

■■ Air emissions

■■ Surface water and groundwater discharges

■■ Wastewater releases

■■ Waste generation and management

■■ Resource use or conservation (energy, water, 

land, biological, cultural)

■■ Community. 

Each of these aspects is addressed by the EMS.
ENVIRONMENTAL PERFORMANCE REPORT 2015 21

environmental goals. The EHS Office and Sustainable 

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

continual improvement. (For more details, see section 

3.2, Performance Indicators and Progress.) 

Implementing

■■ Structure and responsibility – NREL policies and 

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

■■ Competence, training, and awareness – NREL verifies 

that workers are competent on the basis of education, 

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

■■ Communication – NREL provides a number of avenues 

for communication between the laboratory and the 

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

newsletters, and community mailings. NREL tracks 

and responds to all environmentally related concerns 

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

intranet sites, newsletters, emails, meetings, posters, 

trainings, and personal interaction with EHS staff.

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

and objectives. Staff continually identify and review 

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

minimize or avoid impacts to the environment.

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

documents are available for use and that records are 

maintained to meet requirements.

Checking and Corrective Action

■■ Monitoring, measuring, and evaluating compliance – 

NREL monitors key activities, tracks performance 

and progress toward environmental objectives, and 

conducts periodic assessments of compliance with 

legal requirements.

■■ Internal assessment – NREL periodically conducts 

assessments to verify that its EMS is operating as 

intended. A formal system for tracking corrective and 

preventive actions supports continual improvement of 

the management system. (For more details, see section 

3.3, Assessment and Improvement.)

Management Review

■■ Management Review – NREL management conducts 

regular reviews of the EMS to provide feedback 

and direction for environmental performance of 

the organization.

3.2 POLLUTION PREVENTION

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

NREL fulfills this commitment by implementing a variety 

of controls to reduce the potential environmental impacts 

of laboratory operations. These operations include NREL’s 

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

and energy and water use. NREL’s hazard identification 

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

opportunities to reduce pollution and improve program 

effectiveness. In addition, resources are dedicated for 

sustainable operations and pollution prevention through 

the Sustainable NREL program. While the majority of 

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

programs go beyond compliance requirements, continually improving environmental performance. 

Management and Reduction of 

Regulated Refrigerants 

Certain refrigerants and other chemicals are more highly 

regulated than others due to their ability to damage the 

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

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

as well as the substitution and reduction of regulated 

refrigerants when possible. (For more details, see 

Earth Week kicks off with former NREL director and organizer of the 

first Earth Day, Denis Hayes, speaking to staff at the STM site. Photo 

by Dennis Schroeder, NREL 33271
22 ENVIRONMENTAL PERFORMANCE REPORT 2015

section 6, Air Quality Protection.) The policies used 

to reduce regulated refrigerant use and limit their 

releases include: 

■■ Monitoring of the availability of acceptable substitutes 

for regulated refrigerants on a regular basis 

■■ Prohibiting the purchase of any new refrigeration 

equipment using an ODS refrigerant

■■ Evaluating proposed research activities to determine if 

any refrigerants used are ODS and, if so, investigating 

the use of an EPA-approved alternative

■■ Adhering strictly to requirements for ODS equipment 

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

■■ Removing, where feasible, ODS refrigeration equipment 

and recycling of the refrigerant.

Performance Indicators and Progress

Each year measurable goals for environmental 

improvement are developed. Goals are identified in 

the following documents:

■■ Performance Evaluation Measurement Plan – 

DOE requires every national laboratory to develop 

performance goals through a Performance Evaluation 

Measurement Plan. Each fiscal year, in collaboration 

with the DOE Golden Field Office, NREL’s performance 

objectives are developed to enhance the function and 

compliance of laboratory activities.

■■ Site Sustainability Plan – Sustainable NREL develops 

a Site Sustainability Plan each year to establish 

sustainability performance commitments for the year 

and document activities that support the requirements 

of EO 13693, Planning for Sustainability in the Next 

Decade. Results of the plan are presented in section 

4, Sustainability.

Goals are owned by individuals and groups throughout 

the laboratory. Progress on each of these goals is tracked 

throughout the year and results are reported annually. 

Some examples of performance for the year are described 

in Table 1.

Reducing Pollution

Examples of positive impacts of reducing 

pollution from NREL’s activities include:

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

exposure to employees, the public, and 

local ecosystems

■■ Choosing bio-based and recycled-content 

products to reduce impacts on natural 

systems

■■ Encouraging employees to telecommute, take alternative transportation, and 

supporting Web-based meetings to reduce 

traffic, air pollution, and health effects on 

surrounding communities

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

greenhouse gas emissions and use of Colorado’s limited water supplies

■■ Performing waste audits in facilities for 

improving diversion of materials from the 

waste stream to recycling/reuse streams.

Sustainable NREL’s Shred-It event collected and shredded more than 

4,950 lbs. of paper from NREL staff households. Rather than being 

disposed of in a landfill, the shredded paper was taken to an offsite 

composting facility. Photo by Dennis Schroeder, NREL 29896
ENVIRONMENTAL PERFORMANCE REPORT 2015 23

 3.3 ASSESSMENT AND IMPROVEMENT

Assessments support the continual improvement of 

environmental management. Periodic assessment of the 

EMS and its components provides assurance that the EMS 

continues to be an effective tool to achieve and maintain 

compliance with regulatory and legal requirements, meet 

the established environmental goals of the laboratory, 

and demonstrate to ourselves and others that NREL is 

"walking the talk." Internal and external assessments are 

performed to evaluate the functionality of NREL’s EMS.

■■ Internal assessment – Staff performs regular internal 

assessments to evaluate consistency of the EMS with 

the ISO 14001 standard, legal, and other requirements.

■■ External assessment – Periodically, external thirdparty assessments may be conducted by technical 

experts for specific components of environmental 

TABLE 1. 2015 ENVIRONMENTAL GOALS AND ACHIEVEMENTS

2015 Goals 2015 Examples Goal Met?

Demonstrate continuous 

improvement in the 

integration of 

environmental planning 

into NREL programs, 

laboratory, and site 

operation processes

Fully deployed the revised General Plant Improvement process tool for integrating 

environmental considerations into planning processes

Conducted an environmental planning review of the Ten-Year Site Plan and Five-Year Plan

Established an Exterior Design Review committee to review projects and prioritize 

issues to minimize environmental impacts (e.g., construction activities, laydown areas, 

erosion, revegetation) 

Yes

Actively identify potential 

EHS risks and modify 

practices accordingly

Enhanced monitoring of sensitive areas (drainages, riparian areas, quality habitat), the 

STM Conservation Easement, and the NWTC Conservation Management Areas was 

completed. Developed recommendations for improved management. 

Stormwater training was attended by maintenance workers to better understand 

stormwater regulations and their role as it relates to best management practices. 

Provided spill management training to all NREL shuttle drivers to aid in spill recognition, 

reporting, and proper response actions in the event of a vehicle fluid release. 

Yes

Ensure procedures and 

controls are in place and 

implemented to comply 

with environmental 

regulatory requirements

Provided an increased level of oversight to the new NWTC drinking water system 

Operator in Responsible Charge, including familiarizing the subcontractor to the system 

configuration and requirements, and participating in weekly sampling events. The most 

common issues for small systems such as the NWTC system were identified in order to 

reduce the risk of regulatory noncompliance.

Provided nesting bird survey training to workers, enabling them to conduct surveys for 

compliance with the federal Migratory Bird Treaty Act. 

Yes

Maintain and demonstrate 

continuous improvement of 

International Organization 

for Standardization 14001 

management system

Verified ISO standard compliance of management systems as documented in the 

surveillance performed by a third party auditor

Improved the process EHS uses for identification of legal and other requirements, as the 

DOE Necessary and Sufficient Standards is no longer a recognized DOE process

Updated 20 laboratory-level procedures to flow down new or changed regulatory 

requirements, address findings from assessments, and make improvements identified 

during regular procedure reviews

Hosted a Battelle Community of Practice group that conducted a Peer Review of the 

laboratory’s EMS, allowing NREL to benchmark its EMS processes with other Battelle 

laboratories and share best practices

Yes

Implement an enhanced 

National Environmental 

Policy Act (NEPA) program

Continued development of program modifications to improve efficiency and operational 

flexibility, including development of new evaluation criteria

Developed master milestone schedule identifying further enhancement activities that will 

continue throughout FY16. 

Yes
24 ENVIRONMENTAL PERFORMANCE REPORT 2015

programs as part of continual improvement efforts. 

Annual surveillance assessments and triennial recertification assessments are conducted for the EMS as a 

whole to maintain ISO certification. 

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

2015 Assessments

The following assessment activities took place in 

2015, and have allowed NREL to enhance program 

effectiveness and make substantial environmental 

performance improvements:

■■ Internal assessments – Internal assessments of the 

laboratory’s Drinking Water and Hazardous Waste 

Management programs were conducted, which 

involved interviews with staff and reviews of relevant 

procedures and records. The outcomes of these 

assessments are included in section 7, Water Quality 

Protection, and section 8, Hazardous Materials and 

Waste Management.

■■ External assessments – NREL underwent an annual 

assessment to verify conformance to the ISO 

14001:2004 standard. The assessment was conducted 

by a team of external auditors and included visits to a 

number of the laboratory’s facilities, interviews with 

staff at all levels of the organization, observations of 

processes in place, and reviews of documents and 

records. The assessment resulted in five findings and 

six opportunities for improvement. Corrective actions 

are underway to address deficiencies regarding 

records and data management, flowdown of 

requirements to construction subcontractors, and 

spill prevention planning. 

3.4 2015 AWARDS AND RECOGNITION

In 2015, NREL received several awards and recognition 

of its environmental and sustainability achievements 

including:

■■ DOE Green Buy Program Gold Award

■■ Green Electronics Council Electronic Product Environmental Assessment Tool (EPEAT) Purchaser Award 

■■ Colorado Environmental Leadership Program GoldLevel Leader.

DOE Green Buy Program Gold Award

NREL received the gold-level DOE Green Buy Award for 

achieving excellence in sustainable acquisition. This is the 

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

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

13 product types in six different categories.

Green Electronics Council Award

In FY 2015, the Green Electronics Council awarded NREL 

with a Three-Star EPEAT Purchaser Award, recognizing 

NREL’s excellence in the green procurement of electronics. 

The combined efforts of all of the 2015 EPEAT Purchaser 

Award winners resulted in enough energy savings 

to power more than 6,500 U.S. households for one 

year, the reduction of more than 771,618 pounds 

2015 Accomplishments and Highlights

■■ NREL was successfully recertified to the ISO 

14001:2004 standard. A team of external 

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

roles and responsibilities used in environmental management. The assessment verified 

that the laboratory continues to meet the 

requirements of the ISO 14001 standard 

and demonstrates our commitment to 

environmental stewardship.

■■ The laboratory continued to enhance the 

integration of environmental considerations 

into planning processes.

■■ Internal assessments of the Drinking Water 

and the Hazardous Waste Management 

programs identified several areas 

for improvement. 

The Research Support Facility, located on the STM site, is a 

Leadership in Energy and Environmental Design (LEED®) Platinum 

office building occupied by approximately 1,300 employees. 

As illustrated in this photo, the building makes use of natural 

daylighting in lieu of electric lighting, and beetle-kill wood rather 

than virgin timber. Photo by Dennis Schroeder, NREL 17614
ENVIRONMENTAL PERFORMANCE REPORT 2015 25

Reduced risk to facility/organizational mission

NREL’s Hazard Identification and Control Program 

incorporates environmental risk assessment. System 

improvements also reduce risk of non-compliance with 

requirements and potential enforcement actions.

Improved fiscal efficiency and/or cost avoidance

Cost savings are realized through energy efficiency projects, 

new renewable energy installations, waste reduction and 

recycling, and reduced environmental incidents such 

as spills.

Greater understanding and recognition 

of environmental issues at all levels of the 

organization

Staff are made aware of the potential environmental 

impacts from their work activities through the NREL Now

internal newsletter; postings on the NREL intranet; new 

employee orientation and activity-specific trainings; 

policies and procedures; management communications; 

Sustainable NREL communications; and special events such 

as Staff Awards (an annual employee recognition event), 

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

environmental issues supports environmental performance 

throughout the laboratory.

Empowerment of individuals to contribute 

to the reduction of the organization’s 

environmental footprint

Staff are encouraged to reduce the laboratory’s 

environmental footprint by participating in programs and 

events for recycling single-stream materials, batteries, 

electronic equipment, and shredded paper. A composting 

program is also in place. Furthermore, the Be The Change 

Program empowers individuals to develop and suggest 

changes to improve environmental/sustainability.

Integration of environment into organizational 

culture and operations

NREL strives to maintain a high level of awareness in the 

laboratory around safety, health, and environmental 

responsibilities. This is supported through regular 

communications from executive management, trainings, 

inspections, and risk assessments.

Integration of environment into real property 

asset management

NREL includes environmental considerations into long-term 

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

plans consider wildlife movement across the site, surface 

water management, and climate change impacts.

Improved community relations

The laboratory works to improve community relations 

by responding to and tracking all community input 

through phone calls, email, community meetings, and 

soliciting feedback from stakeholders through the National 

Environmental Policy Act process. NREL takes proactive 

measures to engage the community with public tours, 

newsletters, and mailings to neighborhoods surrounding 

its facilities.

Improved effectiveness in overall mission

NREL’s EMS supports the organization’s overall mission 

and improves effectiveness by systematically addressing 

environmental opportunities and risks, ensuring 

compliance with regulations, and implementing voluntary 

commitments to achieve superior performance.

Improved collaborative conversation with 

other groups

The laboratory actively collaborates with stakeholders on 

environmental issues, such as sustainability, renewable 

energy, and resource conservation and management. This 

includes cooperating with other agencies in controlling 

noxious weeds and the management of conservation areas. 

Additionally, NREL is a member of the West Environmental 

Sustainability Team, a partnership that provides outreach 

and resources to help the community save energy, conserve 

resources, use environmentally friendly products, and 

practice sustainability. More information is available at: 

http://www.lakewood.org/getgreen/.

Benefits of the EMS to NREL

(350,000 kilograms) of hazardous waste, the elimination of 

enough mercury to fill more than 5,000 mercury thermometers, and carbon reductions equal to removing more than 

11,000 passenger cars from the road for one year.

Colorado Environmental Leadership 

Program Gold-Level Leader 

NREL maintained its status as a Colorado Environmental 

Leadership Program Gold-Level Leader, the highest level 

awarded by the program. The Colorado Environmental 

Leadership Program is a voluntary partnership between 

the Colorado Department of Public Health and Environment and participating private and public Colorado facilities, and is intended to recognize environmental leadership and performance.

In early 2004, NREL was the first laboratory accepted into 

the program as a Gold-Level Leader and has maintained 
26 ENVIRONMENTAL PERFORMANCE REPORT 2015

Improved overall compliance management

NREL maintains a formal process to identify regulations 

and standards applicable to NREL, including federal laws 

and regulations, state and local requirements, executive 

orders, and DOE orders. In addition, compliance with 

these requirements is regularly reviewed through a 

variety of mechanisms, including internal assessments, 

inspections, and monitoring.

Personnel health and safety

Continually improving environmental, safety, and 

quality management helps make NREL a safer, more 

environmentally responsible workplace and enhances 

the quality of our work processes.

Pollution prevention

Staff regularly identify opportunities to prevent pollution 

through NREL’s hazard identification and control process. 

Resources are dedicated for sustainable operations 

and pollution prevention through the laboratory’s 

sustainability program.

Improved air and water quality

The EMS goals relating to the use of alternative 

energy sources, the use of clean burning fuels, and 

the minimization of the quantity of chemicals used 

onsite contribute toward improved air quality. Through 

refinement and implementation of requirements related 

to the management of runoff, operations, and outdoor 

storage/use of materials at both temporary construction 

sites and throughout facility grounds, NREL continually 

strives to protect water quality onsite and offsite. 

Improved hazardous material, hazardous waste, 

and solid waste management

Hazardous material tracking through the NREL chemical 

inventory reduces the purchase of new supplies by 

allowing staff to determine if a needed chemical already 

exists onsite, which in turn minimizes the generation of 

hazardous waste. The laboratory has averaged above 

a 75% landfill diversion rate for solid waste for several 

years, greatly exceeding DOE goals for waste diversion.

Improved conservation of water, natural 

resources, energy in facilities, fuel in vehicles

The laboratory sets goals for water, energy, and fuel 

usage annually and monitors progress toward each 

throughout the year. 

Reduced number of permits needed to operate

Implementation of the EMS provides a mechanism to 

identify, evaluate, and implement pollution prevention 

opportunities including waste minimization, product 

substitution, and process modification. These efforts can 

reduce the number of regulatory requirements that the 

laboratory must meet.

Benefits of the EMS to the Environment 

this leadership level ever since. As a component of the 

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

enhance operations and performance at the laboratory. 

Colorado Environmental Leadership Program recognizes 

facilities that voluntarily:

■■ Exceed regulatory requirements

■■ Implement EMS (which focuses on incorporating 

environmental considerations into normal management processes and improving internal environmental 

management effectiveness)

■■ Work closely with their communities

■■ Establish three-year goals focusing on measurable 

results.

Learn more about this voluntary program at the state 

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

environmental-leadership-program.

Figure 2. NREL maintained its Colorado Environmental Leadership 

Program Gold Leader status.
ENVIRONMENTAL PERFORMANCE REPORT 2015 27

NREL pursues sustainability in all laboratory operations 

and strives to minimize the environmental, economic, 

and social impacts of doing business. As one of the 

nation's foremost scientific institutions, the laboratory 

embraces the best in energy and ecological conservation 

practices, setting the standard for the wise use of 

natural resources. As a leader in sustainability, NREL's 

goal is to minimize the use of energy, materials, and 

water while carrying out the mission of clean energy 

research. NREL’s sites are living laboratories that 

showcase new technologies, design practices, and best 

practices in operating behaviors. In all site development, 

opportunities to integrate energy efficiency and 

renewable energy, high-performance buildings, and 

sustainable transportation options are sought. On-site 

deployment of technologies developed by NREL 

researchers is also emphasized. 

NREL integrates sustainability into its Environmental 

Management System. Staff work together regularly to 

improve operations and implement programs including:

■■ Site sustainability and pollution prevention data 

tracking and reporting to DOE

■■ Sustainability and environmental management 

planning

■■ Measurement and tracking of environmental 

objectives, targets, and actions

■■ Awareness and engagement of staff and community 

members.

Requirements

The new federal order, EO 13693, Planning for Federal 

Sustainability in the Next Decade, specifies environmental 

sustainability performance goals for federal agencies. In 

addition, DOE Order 436.1, Departmental Sustainability, 

requires DOE facilities to prepare and implement an 

annual Site Sustainability Plan. Each site’s plan reports 

4 SUSTAINABILITY

Members of the U.S. Department of Homeland Security 

sustainability team tour the photovoltaic array on the roof 

of the Research Support Facility. Photo by Dennis Schroeder, 

NREL 34562
28 ENVIRONMENTAL PERFORMANCE REPORT 2015

on the performance status of DOE facilities in addressing 

the sustainability goals and objectives of the executive and 

DOE order and also outlines plans to continue to address 

these objectives and goals in the upcoming year.

EO 13653, Preparing the United States for the Impacts of 

Climate Change, issued in 2013, requires each agency to 

continue ongoing efforts to develop, implement, and 

update comprehensive plans that integrate consideration 

of climate change into agency operations and overall 

mission objectives. 

Program Management

The sustainability program addresses multiple areas of 

sustainability including greenhouse gas management and 

reduction, high-performance sustainable buildings, energy 

efficiency, renewable energy, water management, fleet 

management, waste management and reduction, sustainable procurement processes, climate change resiliency 

planning, engaging with the community, and employee 

behavior change. The program addresses sustainability 

using an integrated and holistic approach. For example, 

NREL is committed to the design, operation, and maintenance of high-performance sustainable buildings by 

employing building design and operation strategies that 

promote optimal performance and maximize life-cycle 

asset value. These operational strategies can also support 

NREL’s mission, which includes the development of renewable energy projects, overall laboratory reductions in 

energy and water usage, and improving sustainable work 

habits of employees. The sustainability program is able to 

leverage a variety of expertise and experiences to integrate sustainable operations throughout the laboratory to 

improve performance and resilience. 

In addition, the sustainability program works closely with 

researchers throughout the laboratory to continually 

develop partnerships that support NREL’s mission while 

improving upon facility operations. NREL serves as both a 

living model of sustainability and a place to develop new 

clean energy ideas, technologies, and practices. 

4.1 SUSTAINABILITY GOALS 

PERFORMANCE

Table 2 summarizes DOE’s performance in meeting its 

sustainability goals at NREL. For more specific information 

related to each goal, please refer to the DOE’s Site Sustainability Plan, which can be found at: http://www.nrel.gov/

docs/gen/fy16/65390.pdf.

NREL employee test rides an electric bike during NREL’s Earth Week 

celebration. Photo by Dennis Schroeder, NREL 33297

2015 Accomplishments and Highlights 

In addition to meeting or exceeding nearly all 

DOE sustainability goals as indicated in the 

Sustainability Goals Performance Summary, 

below are some additional accomplishments: 

■■ NREL launched the Energy Intelligent 

Campus tool that integrates data from 

building energy sensors and meters. 

Energy data collected may be from lighting, 

heating, cooling, and renewable energy 

systems and other building/site operations. 

This tool provides an integrated view of 

energy management with an emphasis on 

operational, financial, and environmental 

accountability. 

■■ NREL staff replaced several pieces of lessefficient legacy IT equipment within the 

Research Support Facility Data Center, which 

reduced the energy consumption of the 

data center by 19 kW. The Research Support 

Facility data center supports staff business 

operations for NREL’s sites.

■■ The installation of 11 solar photovoltaic 

panels completed the roof top array of the 

South Site Entrance Building, which now 

operates at net zero operational energy 

performance. Through the operation of 

the South Site Entrance Building and the 

Research Support Facility (also operated at 

net zero energy), NREL has gained critical 

insight into the importance of measurement 

and verification of facility design. 
ENVIRONMENTAL PERFORMANCE REPORT 2015 29

TABLE 2. SUSTAINABILITY GOALS PERFORMANCE SUMMARY

Goal # DOE Sustainability Goal NREL Performance Status Through FY 2015 Status

1.1 50% greenhouse gas reduction from sources such 

as heating, cooling, and electricity use by FY 2025 

from a FY 2008 baseline

Emissions decreased 85% from the baseline On Track

1.2 25% greenhouse gas reduction from sources such 

as air travel and commuting by FY 2025 from a FY 

2008 baseline 

Emissions decreased 19% from the baseline On Track

2.1 25% building energy use per square foot 

(energy intensity) reduction by FY 2025 from a 

FY 2015 baseline 

Energy intensity reduced 48% from the FY 2003 

baseline. New goal will be based on FY 2015 

energy use as the baseline

Not On Track1

2.2 Perform energy and water audits Conducted energy and water audits on 

three facilities

Evaluations are 81% complete, comprehensive 

evaluation due 6/30/2016

On Track

2.3 Meter all individual buildings for electricity, 

natural gas, steam, and water, where cost-effective 

and appropriate

100% of NREL’s buildings have energy meters 

(including electricity, natural gas, and renewables 

where appropriate)

100% of NREL’s buildings have chilled water meters

100% of NREL’s buildings have hot water meters 

(NREL does not use steam)

95% of NREL’s buildings have potable water meters

On Track

2.4 At least 15% of existing buildings greater than 5,000 

gross square feet in size must comply with the 

Guiding Principles of High Performance Sustainable 

Buildings (HPSB) by FY 2025, with progress to 

100% thereafter

Six buildings (33%) of eligible buildings are 

compliant with the Guiding Principles for HPSB 

On Track

2.5 Efforts to increase regional and local planning 

coordination and involvement 

Continued to work with local governments to 

promote and encourage alternative transportation

Worked with the Regional Transport District to 

develop a new shuttle route for NREL employees 

to encourage commuting by alternative 

transportation

Met with staff from the City of Golden and the 

Colorado School of Mines to discuss potential carshare and bike-share opportunities

Worked with DOE and Jefferson County Open 

Space to improve the Cretaceous Trailhead 

accessing South Table Mountain Park

Coordinated efforts with the U.S. Fish and Wildlife 

Rocky Flats National Wildlife Refuge officials to treat 

102 acres for knapweed at the NWTC

On Track

1 This goal will likely not be met due to energy consumption increases that will 

occur as a result of expansion of the high performance data center. Table 2 continued on page 30
30 ENVIRONMENTAL PERFORMANCE REPORT 2015

TABLE 2. SUSTAINABILITY GOALS PERFORMANCE SUMMARY

Goal # DOE Sustainability Goal NREL Performance Status Through FY 2015 Status

2.6a Net Zero Buildings: Percentage of the site’s existing 

buildings above 5,000 gross square footage 

intended to be net zero energy and waste or water 

buildings by FY 2025.

New goal in FY 2016 N/A

(Percentage of 

net zero buildings 

to which goal 

applies has not 

yet been defined 

by DOE)

2.6b Net Zero Buildings: Percentage of new buildings 

(>5,000 GSF) entering the planning process 

designed to achieve energy net zero beginning in 

FY 2020 

New goal in FY 2016 N/A

(Percentage of 

net zero buildings 

to which goal 

applies has not 

yet been defined 

by DOE)

2.7 Data Center Efficiency: Establish a Power Usage 

Effectiveness (PUE) target in the range of 1.2-1.4 for 

new data centers and less than 1.5 for existing data 

centers (PUE is generally equal to the ratio of power 

used by a data center for computing functions only 

to the extra power needed for data center cooling 

and lighting.)

The Research Support Facility data center PUE of 1.19 

and Energy Systems Integration Facility PUE of 1.06 

are well below the goal of 1.5 PUE for existing 

data centers

On Track

3.1 “Clean Energy” requires that the percentage of 

an agency’s total electric and thermal energy 

accounted for by renewable and alternative energy 

shall be not less than: 10% in FY 2016- 2017, working 

towards 25% by FY 2025 

New goal for FY 2016 On Track

3.2 “Renewable Electric Energy” requires that 

renewable electric energy account for not less than 

10% of a total electric consumption in FY 2016-

2017, working towards 30% of total agency electric 

consumption by FY 2025

Onsite renewable electric energy consumed at NREL 

accounted for 19% of total electric consumption

On Track

4.1 36% potable water intensity (gallons per gross 

square foot) reduction by FY 2025 from a 

FY 2007 baseline

Reduced potable water intensity 42% from the FY 

2007 baseline

On Track

4.2 30% water consumption reduction of Industrial, 

Landscaping, and Agricultural (ILA) water by FY 

2025 from a FY 2010 baseline. (ILA water is defined) 

NREL only uses potable water; therefore this goal 

does not apply.

N/A

5.1 20% reduction in annual petroleum consumption 

by FY 2015 relative to a FY 2005 baseline; maintain 

20% reduction thereafter (FY 2015 target: 20%)

Petroleum consumption increased 17% from 

the baseline

Not On Track2

5.2 10% increase in annual alternative fuel 

consumption by FY 2015 relative to a FY 2005 

baseline; maintain 10% increase thereafter

(FY 2015 target: 10%) 

Alternative fuel use increased a cumulative 127% 

from the baseline. This is a 53% increase from 

FY 2014 

On Track

2 Annual petroleum consumption increased as a result of the increased site demand for diesel buses 

and the lack of funding available to replace the diesel buses with alternative fuel vehicles.
ENVIRONMENTAL PERFORMANCE REPORT 2015 31

TABLE 2. SUSTAINABILITY GOALS PERFORMANCE SUMMARY

Goal # DOE Sustainability Goal NREL Performance Status Through FY 2015 Status

5.3 30% reduction in fleet-wide per-mile greenhouse 

gas emissions reduction by FY 2025 from a 

FY 2014 baseline 

(FY 2015 target: N/A; FY 2017 target: 4%) 

New goal for FY 2016 On Track

5.4 75% of light duty vehicle acquisitions must consist 

of alternative fuel vehicles 

(FY 2015 target: 75%) 

100% of light duty vehicle acquisitions consisted of 

alternative fuel vehicles 

On Track

5.5 50% of passenger vehicle acquisitions consist of 

zero emission or plug-in hybrid electric vehicles by 

FY 2025 

(FY 2015 target: N/A) 

New goal in FY 2016 Not On Track3

6.1 Promote sustainable acquisition and procurement 

to the maximum extent practicable, ensuring that 

BioPreferred and bio-based provisions and clauses 

are included in 95% of applicable contracts 

100% of construction contracts meet sustainable 

acquisitions requirements 

100% of custodial contracts meet sustainable 

acquisitions requirements

Goal Met

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

excluding construction and demolition debris 

Diverted 81% of nonhazardous solid waste from 

the landfill

Goal Met

7.2 Divert at least 50% of construction and demolition 

materials and debris 

Diverted 75% of construction and demolition 

materials and debris from the landfill

Goal Met

8.1 Annual targets for performance contracting to be 

implemented in FY 2017 and annually thereafter as 

part of the planning of section 14 of EO 13693

Planned target of $2 million to be used for 

performance contracting

On Track

9.1 Purchases: 95% of eligible acquisitions each 

year are registered with the Electronics Product 

Environmental Assessment Tool (EPEAT), which 

ranks selected desktop computers, notebooks, and 

monitors based on their environmental attributes. 

98% of eligible electronic acquisitions met 

EPEAT standards

Goal Met

9.2 Power management—100% of eligible PCs, 

laptops, and monitors have power 

management enabled

Power management is enabled on 100% of eligible 

PCs, laptops, and monitors

Goal Met

9.3 Automatic duplexing—100% of eligible computers 

and imaging equipment have automatic 

duplexing enabled

100% of computers and imaging equipment 

have automatic duplexing enabled. 100% of 

eligible personal printers have automatic 

duplexing enabled 

Goal Met

9.4 End of Life—100% of used electronics are reused or 

recycled using environmentally sound disposition 

options each year

100% of electronics at their end of life were 

donated, resold, or recycled using environmentally 

sound disposition practices. 33,441 pounds of 

electronics were recycled in FY 2015

Goal met

3 NREL procures its fleet vehicles from the General Services Administration (GSA). For the current type of passenger 

vehicles NREL utilizes in its fleet, the GSA has no available zero emission or plug-in hybrid electric options. Attainment of 

this goal will also require charging stations and other infrastructure at the NWTC for which funding may not be available. Table 2 continued on page 32
32 ENVIRONMENTAL PERFORMANCE REPORT 2015

TABLE 2. SUSTAINABILITY GOALS PERFORMANCE SUMMARY

Goal # DOE Sustainability Goal NREL Performance Status Through FY 2015 Status

10.1 Update policies to incentivize planning for and 

addressing the impacts of climate change

NREL’s recent A Climate Change Vulnerability 

Assessment Report for the National Renewable Energy 

Laboratory and A Resiliency Action Plan for the National 

Renewable Energy Laboratory identified goals 10.1–10.4 

as areas to be pursued beginning in FY 2016.

On Track

10.2 Update emergency response procedures and 

protocols to account for projected climate change, 

including extreme weather events

NREL’s recent A Climate Change Vulnerability 

Assessment Report for the National Renewable Energy 

Laboratory and A Resiliency Action Plan for the National 

Renewable Energy Laboratory identified goals 10.1–10.4 

as areas to be pursued beginning in FY 2016. 

On Track

10.3 Ensure workforce protocols and policies reflect 

projected human health and safety impacts of 

climate change

NREL’s recent A Climate Change Vulnerability 

Assessment Report for the National Renewable Energy 

Laboratory and A Resiliency Action Plan for the National 

Renewable Energy Laboratory identified goals 10.1–10.4 

as areas to be pursued beginning in FY 2016. 

On Track

10.4 Ensure site/laboratory management demonstrates 

commitment to adaptation efforts through internal 

communications and policies

NREL’s recent A Climate Change Vulnerability 

Assessment Report for the National Renewable Energy 

Laboratory and A Resiliency Action Plan for the National 

Renewable Energy Laboratory identified goals 10.1–10.4 

as areas to be pursued beginning in FY 2016.

On Track

10.5 Ensure that site/laboratory climate adaptation 

and resilience policies and programs reflect best 

available current climate change science, updated 

as necessary

NREL’s recent climate change vulnerability 

assessment and resilience action plan used current 

climate science information provided by the Western 

Water Assessment (who serves as the Regional 

Integrated Science and Assessment [RISA] climate 

science research team organized by NOAA)

On Track

4.2 CLIMATE CHANGE ADAPTATION 

MANAGEMENT 

As climate change becomes more apparent worldwide, 

NREL is proactively engaged in mitigation and adaptation strategies to manage site-specific climate risks, and 

improve resiliency of operations to ensure continuity of 

achieving the laboratory’s mission. 

Requirements 

NREL complies with the requirements of EO 13693, 

Planning for Federal Sustainability in the Next Decade, and 

DOE Order 436.1, Departmental Sustainability, by reporting 

on sustainability performance in its Site Sustainability Plan, 

which is submitted to DOE each year. Also included in the 

Site Sustainability Plan is the progress made in achieving 

climate change resilience goals developed by DOE for 

their facilities needed to meet the requirements of 

EO 13653, Preparing the United States for the Impacts of 

Climate Change. These goals include the following: 

■■ Update policies to incentivize planning for, and addressing the impacts of, climate change

■■ Update emergency response procedures and protocols to 

account for projected climate change including extreme 

weather events 

■■ Ensure that workforce protocols and policies reflect 

projected human health and safety impacts of 

climate change 

■■ Ensure that site/laboratory management demonstrates 

commitment to adaptation efforts through internal 

communications and policies 

■■ Ensure that site/laboratory climate adaptation and resilience policies and programs reflect best available current 

climate change science, updated as necessary.
ENVIRONMENTAL PERFORMANCE REPORT 2015 33

Program Management 

In 2014 and 2015, NREL took steps to prepare for climate 

change and build organizational resilience. DOE’s Sustainability Performance Office funded NREL to develop a 

model process for climate change resilience planning 

that could also assist other DOE sites in preparing for the 

impacts of climate change. NREL worked with an outside 

research consultant, diverse stakeholders from across the 

laboratory, and key external stakeholders to conduct a 

vulnerability assessment and a resilience planning process. 

A steering committee composed of 22 staff members and 

smaller work groups with subject matter experts helped 

to identify climate-related sensitivities that could impact 

NREL’s ability to meet its mission. These sensitivities were 

then scored using the most up-to-date climate science 

available for the region, and adaptation options for the 

highest risk vulnerabilities were identified. From this 

assessment process, NREL has developed a list of actions 

to manage near- and longer-term climate change risks.

2015 Compliance Summary and Activities 

■■ Program activities were in compliance with requirements.

■■ NREL completed and published the following documents in support of its climate change management 

efforts and in compliance with EO 13653, EO 13963, and 

DOE Order 436.1: 

● A Climate Change Vulnerability Assessment Report for 

the National Renewable Energy Laboratory, May 23, 

2014–June 5, 2015 5

● A Resiliency Action Plan for the National Renewable 

Energy Laboratory, May 23, 2014–June 5, 2015.

6

2015 Accomplishments and Highlights 

■■ NREL staff outlined the process of developing 

NREL’s climate vulnerability assessment 

and resilience action plan to DOE national 

laboratory representatives at DOE’s Annual Site 

Environmental Report workshop.

■■ The laboratory supported the DOE 

Sustainability Performance Office in evaluating 

four DOE pilot vulnerability assessments, which 

included the assessment performed by NREL. 

The resulting publication, Practical Strategies 

Guide for Vulnerability Assessments,

4

 detailed 

the commonalities, differences, and best 

practices of the approaches taken and 

identified lessons learned to be used by 

laboratories going forward. 

4 Practical Strategies for Climate Change Vulnerability Assessments. Department of Energy, Sustainability Performance Office. December 2015.

5 A Climate Change Vulnerability Assessment Report for the National Renewable Energy Laboratory, May 23, 2014—June 5, 2015. J. Vogel, M. O’Grady, and 

S. Renfrow, Abt Environmental Research, Inc., Boulder, Colorado.

6 A Resiliency Action Plan for the National Renewable Energy Laboratory, May 23, 2014—June 5, 2015. J. Vogel, C. Wagner, and S. Renfrow, Abt 

Environmental Research, Inc., Boulder, Colorado.

Wind turbine at dusk near the Outdoor Test Facility at the STM site. 

Photo by Steve Wilcox, NREL 15260
34 ENVIRONMENTAL PERFORMANCE REPORT 2015

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

(EOs) and DOE orders and memoranda of understanding 

with government agencies. NREL continues its excellent 

record of environmental compliance.

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

More detailed information for each area of compliance is 

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

see Appendix C.

5 COMPLIANCE SUMMARY

In partnership with the United Parcel Service (UPS) and 

the Clean Cities initiative, NREL’s fleet evaluation team 

is conducting dynamometer testing of medium- and 

heavy-duty UPS fleet vehicles running on conventional and 

synthetic diesel. This side-by-side evaluation is designed to 

determine the fuel economy and emissions impact 

of conventional versus synthetic diesel. Photo by 

Dennis Schroeder, NREL34436
ENVIRONMENTAL PERFORMANCE REPORT 2015 35

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

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Report DOE Order 231.1B, Chg 1, Environment, Safety 

and Health Reporting, was implemented to 

ensure that DOE receives timely, accurate 

information about events that have affected 

or could adversely affect the health and safety 

of the public or workers, the environment, 

or the operations of DOE facilities. The order 

requires that DOE facilities report specific site 

environmental information annually including 

environmental management performance, 

environmental occurrences and response, 

compliance with environmental standards and 

requirements, significant programs and efforts, 

and property clearance activities for property 

contaminated with radiological materials.

NREL reports annually via this Environmental 

Performance Report.

DOE:

DOE Order 231.1B, 

Chg 1

EMS and 

Sustainability

A new federal Executive Order, EO 13693, 

Planning for Federal Sustainability in the 

Next Decade, establishes updated goals for 

environmental sustainability in the federal 

government. These goals require federal 

facilities to conserve natural resources, reduce 

energy use and greenhouse gas emissions, 

develop renewable energy, manage buildings 

and transportation in a sustainable manner, 

and support pollution prevention.

EO 13693, together with DOE Order 436.1, 

Departmental Sustainability, requires that 

the laboratory implement an EMS that 

conforms to the ISO 14001 structure. The EMS 

is implemented as part of a DOE-required 

Integrated Safety Management System, 

which systematically integrates safety and 

environmental protection into management 

and work practices at all levels to protect the 

public, the worker, and the environment.

Each year, a Site Sustainability Plan is developed 

to report on past performance and set goals 

for the coming year. These performance goals 

are integrated with the laboratory’s EMS, and 

progress is tracked throughout the year. 

NREL’s EMS has been certified to the ISO 

14001:2004 international standard for 

environmental management systems since 2011. 

Annual assessments verify that NREL meets 

the ISO standard and is continually 

improving performance.

Executive Order:

EO 13693

DOE:

DOE Order 436.1

Climate 

Change 

Adaptation 

Management

 EO 13693, Planning for Federal Sustainability in 

the Next Decade, requires every federal agency 

to report on sustainability performance 

each year. DOE Order 436.1 requires NREL to 

submit a Site Sustainability Plan to the DOE’s 

Sustainability Performance Office each year. 

EO 13653, Preparing the United States for the 

Impacts of Climate Change, requires NREL 

to include in its Site Sustainability Plan the 

progress the laboratory has made in meeting 

the climate change resilience goals specified 

in EO 13693. 

All program activities were in compliance with 

requirements.

NREL completed and published the following 

documents in support of its climate change 

management efforts and in compliance with EO 

13653, EO 13963 and DOE Order 436.1: 

■■ A Climate Change Vulnerability Assessment 

Report for the National Renewable Energy 

Laboratory, May 23, 2014-June 5, 20157

, and, 

■■ A Resiliency Action Plan for the National 

Renewable Energy Laboratory, May 23, 

2014-June 5, 20158

Executive Orders:

EO 13653 

EO 13693 

DOE:

DOE Order 436.1

7 A Climate Change Vulnerability Assessment Report for the National Renewable Energy Laboratory, May 23, 2014—June 5, 2015. 

J. Vogel, M. O’Grady, and S. Renfrow, Abt Environmental Research, Inc., Boulder, Colorado.

8 A Resiliency Action Plan for the National Renewable Energy Laboratory, May 23, 2014—June 5, 2015. J. Vogel, C. Wagner, and 

S. Renfrow, Abt Environmental Research, Inc., Boulder, Colorado.

Table 3 continued on page 36
36 ENVIRONMENTAL PERFORMANCE REPORT 2015

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

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Air Quality The Colorado Department of Public Health 

and Environment (CDPHE) administers the 

Clean Air Act implementing regulations for 

all point sources (facilities or other types of 

operations) in Colorado, under authority 

delegated by the U.S. Environmental 

Protection Agency (EPA). Categories of 

regulated air pollutants include: criteria 

air pollutants, hazardous air pollutants 

(HAPs), ozone-depleting substances, and 

greenhouse gases.

EPA’s Protection Of Stratospheric Ozone (40 

CFR 82) requires that servicing records must 

be kept for appliances containing more than 

50 pounds of Class 1 or 2 Ozone Depleting 

Substances refrigerant.

EPA regulations require that certain facilities 

that emit greenhouse gases track and report 

the amount of those emissions. Reporting 

and permitting of greenhouse gases may 

be required under the EPA Prevention of 

Significant Deterioration regulation, Title V 

Tailoring Rule, and is required under the EPA 

Greenhouse Gas Mandatory Reporting Rule.

CDPHE regulations require federal, state, 

and local government facilities to track 

street sanding in the wintertime, and to 

minimize sand use with the goal of reducing 

particulate pollution in the Denver area.

All program activities were in compliance 

with requirements. NREL did not exceed any 

air permit standard or other air regulatory 

requirement at any facility.

A compliance inspection was conducted by the 

Jefferson County Public Health, on behalf of the 

state, of permitted emission sources. Inspections 

included six standby generators, Field Test 

Laboratory Building waste gas combustor, 

and the Renewable Fuel Heating Plant. No 

deficiencies were identified.

Completed the annual evaluation of compliance 

with federal and state facility-wide air permitting 

and emissions control requirements. All facilities 

and individual permitted equipment items 

remain classified as minor sources.

The laboratory evaluated carbon dioxide 

equivalent and greenhouse gas emissions and 

concluded they were below the threshold for 

federal reporting and permitting rules.

All state-required Ozone Depleting Substances 

equipment registrations and annual registration 

renewals were completed. In addition, all 

refrigerant recovery equipment has been 

registered with the EPA, and all service 

personnel maintain federal and state required 

training and certification.

Four air permits for three standby generators 

and a waste gas combustor were renewed.

Completed the annual street sanding report 

required by the state confirming that no sand 

was used at the STM site and NWTC.

National Ambient 

Air Quality 

Standards:

40 CFR 50

ODS:

40 CFR 82 

and CDPHE 

Colorado Code of 

Regulations (CCR) 

1001-19, Reg. 15

New Source 

Performance 

Standards:

40 CFR 60

New Source 

Review, Prevention 

of Significant 

Deterioration:

40 CFR 51

Title V:

40 CFR 70 and 71

National Emission 

Standards for 

Hazardous 

Air Pollutants, 

Hazardous Air 

Pollutant:

40 CFR 63 and 

CDPHE 5 CCR 

1001-5, Reg. 3

Permitting:

CDPHE 5 CCR 

1001-5, Reg. 3

Greenhouse Gas:

40 CFR 98 and 40 

CFR 51, 52, 70, 71

Street Sanding:

CDPHE 5 CCR 

1001-18, Reg. 16
ENVIRONMENTAL PERFORMANCE REPORT 2015 37

Table 3 continued on page 38

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

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Drinking 

Water Quality

The Safe Drinking Water Act 

establishes minimum drinking 

water standards and monitoring 

requirements for drinking water 

supplies. Drinking water quality 

is regulated for all public water 

suppliers in Colorado by CDPHE, 

under authority delegated by 

the EPA.

All program activities were in compliance with 

requirements. 

All monitored parameters met applicable requirements. 

Jefferson County Public Health, on behalf of the state 

of Colorado, conducted an inspection of the NWTC 

drinking water system. In addition to the absence of 

deficiencies and violations, NREL and its subcontractor 

were commended for their detailed and comprehensive 

management of the system and for the extent of 

protection of drinking water quality from delivery 

to consumption.

Modifications to the backflow prevention and cross 

contamination plan were completed in advance of 

the January 1, 2016 compliance deadline, as required 

by revisions to the state’s drinking water regulations in 

2015. Implementation of the plan, including an annual 

inventory and assessment of all possible drinking water 

system contamination sources, is ongoing. 493,175 gallons 

(1,866,869 liters) of drinking water were provided to 

NWTC users. 

EPA:

40 CFR 141-149

CDPHE:

5 CCR 1002-11 

Reg. 11

Groundwater 

Quality

Colorado groundwater quality 

standards are established by CDPHE. 

Permits for groundwater wells are 

issued by the Colorado Department 

of Natural Resources.

All program activities were in compliance with 

requirements.

Five groundwater monitoring wells that were no longer 

being monitored at the STM site were abandoned in 

conformance with state regulations. 

Three groundwater monitoring and observation holes 

were installed in conformance with state regulations.

CDPHE:

5 CCR 1002-41

2 CCR 402-2

2 CCR 402-10

Surface Water 

Quality

Surface water quality is controlled 

through the federal Clean Water Act, 

Energy Independence and Security 

Act of 2007, EO 13693, Planning 

for Federal Sustainability in the Next 

Decade, and the Colorado Water 

Quality Control Act. Constructionrelated stormwater discharge 

regulations are administered by the 

EPA at federal facilities in Colorado. 

Non-federal facility constructionrelated stormwater discharges in 

Colorado are regulated by the Water 

Quality Control Division of CDPHE. 

All program activities were in compliance with requirements. 

Permit coverage under the EPA Construction General Permit 

continues for two STM site construction projects; there are 

no active construction stormwater permits at the NWTC.

A Low Erosivity Waiver was prepared and submitted to 

the EPA for a road improvement project at the NWTC. The 

waiver allowed for construction to proceed without EPA 

Construction General Permit coverage because the required 

erosivity computations indicated a low potential for negative 

impacts on stormwater runoff from construction activity. 

Although the waiver was granted, NREL implemented 

stormwater controls to protect stormwater quality and 

prevent erosion and sedimentation.

EPA Construction General Permit coverage for one 

completed project was terminated.

Weekly stormwater inspections were performed on active 

construction sites per EPA regulations. Additionally, monthly 

stormwater inspections were performed for restorationphase construction sites still under EPA Construction General 

Permit coverage.

EPA:

40 CFR 122.26

CDPHE:

5 CCR 1002-61

Regs. 38, 61, 65, 

and 93

Executive Order:

EO 13693
38 ENVIRONMENTAL PERFORMANCE REPORT 2015

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

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Wastewater The federal Clean Water Act and Colorado Water 

Quality Control Act regulations apply to wastewater 

management at NREL’s STM site and Denver West Office 

Park. The Metro Wastewater and Reclamation District 

manages wastewater for much of the Denver metro 

area, receiving wastewater from the Pleasant View 

Water and Sanitation District, which services the STM 

site and Denver West Office Park.

The NTWC utilizes an onsite septic system. Inspection 

and permitting of individual sewage disposal systems 

have been delegated to Jefferson County by CDPHE.

All program activities were in 

compliance with requirements. 

EPA:

40 CFR 

122-136

CDPHE:

5 CCR 

1002-62, 63

Hazardous 

Materials 

Management

EO 13693, Planning for Federal Sustainability in the Next 

Decade, outlines requirements for increasing waste and 

pollution prevention by reporting in accordance with 

requirements of Sections 301-313 of the Emergency 

Planning and Community Right-to-Know Act of 1986, 

and by minimizing the quantities of toxic chemicals and 

materials at federal facilities.

NREL facilities are subject to various parts of EPCRA. 

Section 302 of EPCRA requires a facility to notify the 

state and local emergency response and planning 

agencies if any extremely hazardous substances in the 

facility's inventory are stored in quantities greater than 

regulatory thresholds. 

EPCRA Section 304 requires facilities to immediately 

notify the state and local emergency response and 

planning agencies if there is an accidental spill or release 

of more than the predetermined reportable quantity. 

In accordance with Sections 311 and 312 of EPCRA, NREL 

provides Safety Data Sheets (SDSs) for chemicals that 

are stored on-site in quantities greater than regulatory 

thresholds, and provides inventory reporting for these 

chemicals in an annual hazardous materials report to 

state and local emergency response agencies and local 

fire departments, called a Tier II report.

In the event of a release, EPCRA Section 313 requires 

that a toxic chemical release inventory report be filed 

with the EPA for any chemical that is manufactured, 

processed, or otherwise used in quantities exceeding 

regulatory thresholds. 

Annual hazardous material permits are required by 

West Metro Fire Rescue for the STM site and Denver 

West Office Park sites. Renewable Fuels and Lubricants 

Research Laboratory, located within the City and County 

of Denver, is subject to the Denver Fire Department 

Hazardous Materials Information System requirements, 

including permitting, inventory, and annual inspection. 

Hazardous materials permits are currently not required 

at the NWTC or the Joyce Street Facility.

All program activities were in 

compliance with requirements. 

There were no releases of hazardous 

materials above reporting requirements.

In accordance with DOE Order 151.1c, 

Comprehensive Emergency Management 

System, NREL conducted a hazardous 

materials screening of select chemicals 

to confirm that inventories are below 

threshold planning quantities.

EPCRA Tier II hazardous materials reports 

were submitted to the appropriate 

state and local emergency response 

and planning agencies, as well as local 

fire departments, for three facilities 

for reporting year 2014. Diesel fuel, 

petroleum oil, and sulfuric acid in leadacid batteries were included in 

the report.

West Metro Fire Rescue conducted an 

annual hazardous material inspection 

and issued hazardous materials 

management permits for seven facilities.

The inventory of hazardous materials 

at the Renewable Fuels and Lubricants 

Research Laboratory was provided to 

the Denver Fire Department.

EPA:

40 CFR 355, 370, 

372

Executive Order:

EO 13693

DOE:

DOE Order 

151.1c
ENVIRONMENTAL PERFORMANCE REPORT 2015 39

Table 3 continued on page 40

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

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Regulated 

Waste 

Management

The Resource Conservation and Recovery 

Act established requirements for the 

management of regulated waste, 

including hazardous waste. In Colorado, 

CDPHE administers regulated waste 

requirements under authority delegated 

by the EPA.

All program activities were in compliance with 

requirements. 

All regulatory notifications were updated and 

applicable waste generator fees were paid for five 

NREL sites.

Nineteen hazardous and five universal waste 

shipments for offsite disposal were made across NREL’s 

five sites.

Twelve cubic yards of imported sugarcane bagasse 

used in biofuels research were transported and 

disposed of in accordance with guidelines set forth by 

the United States Department of Agriculture’s Animal 

and Plant Health Inspection Service. Disposal involved 

placement and subsequent burial at a municipal solid 

waste landfill.

EPA:

40 CFR 260- 280

CDPHE:

6 CCR 1007-3

Aboveground 

Storage Tank 

Management

Aboveground Storage Tanks (ASTs) are 

regulated in Colorado by the Colorado 

Department of Labor and Employment 

(CDLE) Division of Oil and Public Safety 

under the Colorado Aboveground 

Storage Tank (AST) regulation. Colorado 

requires that ASTs 660 gallons or larger 

be permitted prior to installation, and 

registration renewals are submitted 

annually thereafter.

All program activities were in compliance with 

requirements.

No reportable spills or releases from NREL’s ASTs or 

related fueling activities occurred. 

No new tanks were permitted.

CDLE:

Division of Oil 

and Public 

Safety (DOPS) 

Storage Tank 

Regulations,

7 C.C.R. 1101-14

Spill 

Prevention 

and Response

Spill Prevention, Control, and Countermeasures (SPCC) plans are required by 

EPA and Colorado regulations for facilities 

that meet certain oil storage criteria. In 

general, a facility must have an SPCC plan 

if the facility stores more than 1,320 gallons of oil or where a spill has the potential to enter waters of the United States.

All program activities were in compliance with 

requirements.

Staff who manage and/or operate oil-containing 

equipment received annual SPCC training. 

All regulated tanks were inspected on a regular basis.

No reportable spills occurred. Sixteen minor spills of 

diesel, lubricant, coolant, or hydraulic fluids occurred 

at the STM site, and two spills occurred at the NWTC. 

The size of spills ranged from less than 0.1 gallon to 4 

gallons (0.38 to 15 liters). The majority of these spills 

resulted from vehicle and construction equipment 

leaks. Each spill received immediate remedial action 

and did not result in any significant impact to

the environment.

UEPA:

Oil Pollution 

Prevention 

40 CFR 112

CWA Section 

319

CDLE:

DOPS 

Storage Tank 

Regulations,

7 C.C.R. 1101-14

CWCC:

25-8-205 C.R.S.

Radiological 

Materials 

and Waste 

Management

Air emissions are regulated by Section 

112 of the Clean Air Act and implemented 

by the EPA. 40 CFR Part 61 established 

National Emission Standards for 

Hazardous Air Pollutants and, more 

specifically, Subpart H, sets such 

standards for radiological materials.

DOE Order 458.1, Radiation Protection of 

the Public and the Environment, establishes 

radiation emission limits for DOE facilities. 

All program activities were in compliance with 

requirements. 

No planned or unplanned radiological releases 

occurred.

Only small quantities of low-level radioactive waste 

were generated and are currently in storage awaiting 

off-site disposal.

The effective dose equivalent to the public from NREL 

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

the 10 mrem per year limit.

EPA:

40 CFR 61, 

Subpart H

DOE:

DOE Order 

458.1
40 ENVIRONMENTAL PERFORMANCE REPORT 2015

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

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

National 

Environmental 

Policy Act 

National Environmental Policy Act (NEPA) 

requires that federal agencies determine 

environmental impacts of proposed federal 

actions and alternatives. DOE implementing 

NEPA regulations are found in 10 CFR 1021.

All program activities were in compliance with 

requirements.

A total of 614 NEPA reviews were conducted for 

project activities on- and off-site.

A NEPA program assessment conducted in 

2014 identified findings related to document 

control, training, and adherence to internal NEPA 

processes. A NEPA enhancement project plan, 

designed to address the findings, is in place and 

progress has been made to implement it; full 

implementation will be completed in 2016.

Council for

Environmental 

Quality:

40 CFR 1500-1508

DOE:

10 CFR 1021

Wildlife 

Management

The Migratory Bird Treaty Act (MBTA) of 1918 

is the main driver for protection of migratory 

birds in the United States. The MBTA and 

amendments implement several treaties 

between the U.S., Great Britain, Mexico, Japan, 

and the former Soviet Union. The MBTA 

prohibits the taking, killing, or possession of 

migratory birds, nests, and eggs.

Under Colorado Revised Statute (CRS) 33-6-

128, Damage or Destruction of Dens or Nests—

Harassment of Wildlife, no wildlife dens or nests, 

young, or eggs may be damaged or destroyed 

unless permitted by the Colorado Division of 

Parks and Wildlife. It is unlawful for any person 

to willfully harass wildlife, including birds.

Under the “Memorandum of Understanding 

between DOE and the U.S. Fish and Wildlife 

Service Regarding Implementation of EO 

13186, Responsibilities of Federal Agencies to 

Protect Migratory Birds”, DOE agrees to integrate 

migratory bird conservation principles, 

measures, and practices into agency activities, 

and avoid or minimize adverse impacts on 

migratory bird resources and their habitats.

Visible markers were applied to a total of 6,700 

square feet of glass windows of the Energy 

Systems Integration Facility in August of 2014 

with the intent of reducing the potential for bird 

strikes. Post-retrofit bird survey results found that 

no bird strikes occurred on any of the treated 

windows. Based on pre-retrofit surveys and 

the post-retrofit surveys, the project will likely 

prevent 15 to 20 bird deaths due to window 

strikes each fall migration season.

Cavity nesters, such as flickers and woodpeckers, 

commonly build nests in the exterior surfaces of 

buildings, causing significant damage. Building 

repair activities are delayed until nestlings have 

fledged and the adults have abandoned the 

nests, in compliance with the Migratory Bird 

Treaty Act. This situation occurred in 2015 

with a nesting pair of flickers at the Outdoor 

Test Facility.

NREL incorporates necessary components of 

the Avian Power Line Interaction Committee 

guidelines into project planning and design, 

in accordance with the Memorandum of 

Understanding between DOE and U. S. Fish and 

Wildlife Service.

U.S. Fish and 

Wildlife Service:

MBTA 16

U.S.C. 703-712

Colorado Division 

of Parks and 

Wildlife: CRS 

33-6-128

Memorandum of 

Understanding 

between DOE 

and the U.S. 

Fish and Wildlife 

Service 

Executive Order:

EO 13186

Endangered 

Species and 

Species of 

Concern

The Endangered Species Act (ESA) is intended 

to protect threatened and endangered 

wildlife and plant species and associated 

critical habitat. 

All program activities were in compliance with 

requirements.

As part of its NEPA evaluation, NREL conducted 

natural resource surveys for a potential project 

at the NWTC. These surveys included presence/

absence and habitat surveys for threatened and 

endangered species and Colorado state listed 

species. A rare plant survey was also conducted 

for the Ute ladies’ tresses orchid and the 

Colorado butterfly plant. No federally protected 

or state listed species or habitats were found. 

U.S. Fish and 

Wildlife Service:

50 CFR 17
ENVIRONMENTAL PERFORMANCE REPORT 2015 41

Table 3 continued on page 42

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

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Vegetation 

Management

EO 13112, Invasive Species, requires the 

control of invasive species at federal 

facilities. In Colorado, the Department 

of Agriculture Commissioner develops 

and implements state noxious weed 

management plans for three categories of 

weed species. Class A plants are targeted 

for eradication. Class B species are subject 

to management plans designed to stop 

their continued spread. Class C species 

are subject to plans designed to support 

the efforts of local governing bodies to 

facilitate more effective integrated weed 

management on private and public lands.

The Federal Insecticide, Fungicide, and 

Rodenticide Act regulates the use, storage, 

and disposal of herbicides and pesticides. 

For application of certain types of 

herbicides designated as “restricted use” by 

the EPA, a certified applicator must be used. 

All program activities were in compliance with 

requirements.

At the NWTC, herbicides were applied to control A-, 

B- and C-listed weeds on approximately 135 acres (55 

hectares) in April and May, 41 acres (17 hectares) in July, 

and 21 acres (8 hectares) in October.

At the STM site, herbicides were applied to control Band C-listed weeds to approximately 15 acres (6 hectares) 

in May and June, 6 acres (2 hectares) in August, and 13 

acres (5 hectares) in October.

Across the STM site and within the STM Conservation 

Easement, 15 Russian olive trees were girdled and treated 

with herbicide to kill the trees and prevent the spread of 

this invasive species.

A rust fungus (Puccinia punctiformis) was introduced 

at two locations, one on the STM site and the other 

on the NWTC, to combat Canada thistle. The locations 

are seep areas where Canada thistle is known to 

occur. Introduction of this biological control agent, 

done in cooperation with the Colorado Department 

of Agriculture, provides an integrated approach to 

combatting noxious weeds. The Colorado Department 

of Agriculture will monitor the rust fungus in subsequent 

years to document its establishment and effectiveness.

Knapweed weevils were introduced along the Pine 

Ridge at the NWTC in August. Two species were released; 

one that attacks the seed heads and another that attacks 

the roots of knapweed. This effort further diversifies 

noxious weed control methods.

Executive 

Orders:

EO 13112

EPA:

40 CFR 

162-171(f)

CRS 35-5.5

Department 

of Agriculture:

Federal 

Noxious 

Weed Act of 

1974 (Public 

Law 93-629, 

88 Statute 

2148)

Plant 

Protection 

Act (Public 

Law 106-224)

Wetlands and 

Floodplains

EO 11988, Floodplain Management, requires 

federal agencies to provide leadership and 

take action to reduce the risk of flood loss; 

minimize the impact of floods on human 

safety, health, and welfare; and restore and 

preserve the natural and beneficial values 

served by floodplains in carrying out 

its responsibilities.

Under EO 11990, Wetlands Protection, federal 

agencies must provide leadership and take 

action to minimize the destruction, loss, or 

degradation of wetlands, and to preserve 

and enhance the natural and beneficial 

values of wetlands. Wetlands that meet 

certain soils, vegetation, and hydrologic 

criteria are protected under the CWA 

Section 404, which is administered by the 

U.S. Army Corps of Engineers (USACE).

Jefferson County requires approval of 

development proposed in floodplains 

within its jurisdiction.

All program activities were in compliance with 

requirements; no actions occurred that affected 

wetlands or floodplains.

No NREL projects or activities that could impact 

wetlands or floodplains occurred.

The STM site and the NWTC do not contain any 

regulatory floodplains. 

Executive 

Orders:

EO 11988

EO 11990

USACE:

CWA Section 

404

DOE:

10 CFR 1022
42 ENVIRONMENTAL PERFORMANCE REPORT 2015

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

APPLICABLE TO NREL AND COMPLIANCE STATUS

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Cultural 

Resources

Cultural resources are protected under 

Sections 106 and 110 of the National 

Historic Preservation Act. Federal agencies 

must establish preservation programs—

commensurate with their mission and 

the effects of their activities on historic 

properties—that provide for the careful 

consideration of historic properties. Significant 

cultural resources are either eligible for, or 

listed in, the National Register of Historic 

Places. Cultural resources are defined as any 

prehistoric or historic district, site, building, 

structure, or object considered important 

to a culture, subculture, or community for 

scientific, traditional, religious, or other reason. 

The National Historic Preservation Act is 

administered in Colorado by the Colorado 

Office of Archaeology & Historic Preservation 

(State Historic Preservation Officer).

All program activities were in compliance with 

requirements.

DOE initiated a consultation with the Colorado 

State Historic Preservation Office under Section 

106 of the National Historic Preservation Act of 

1966 for the Central Array Test Site installation 

and operation at the STM site. As part of the 

process, DOE provided a letter to the Colorado 

State Historic Preservation Office indicating 

that no historic properties would be directly 

or indirectly affected by the project. The State 

Historic Preservation Office concurred with 

DOE’s determination. 

Advisory Council 

on Historic 

Preservation:

36 CFR 60

36 CFR 63

36 CFR 79

36 CFR 800

16 U.S.C. 470

Traffic

Management 

There are no traffic regulations that pertain to 

the NREL sites. Traffic demand management 

strategies are implemented to minimize traffic 

impacts in the local area. 

Active transportation demand management 

activities were continued in 2015.

The average afternoon (4:30 p.m. to 5:30 p.m.) 

peak-hour traffic volume, measured at the 

intersection of Denver West Parkway and 

Denver West Marriott Boulevard, was 277 vehicle 

trips per hour. This traffic volume remained 

below the threshold established as part of the 

traffic Mitigation Action Plan (522 vehicle trips 

per hour) intended to ensure acceptable traffic 

volumes at the intersection. 

DOE/EA1440-S-I

(May 2008)

Traffic Mitigation 

Action Plan
ENVIRONMENTAL PERFORMANCE REPORT 2015 43

Water quality is critical to human health and the health 

of our natural ecosystems. At NREL, the focus of water 

quality protection is on four main areas: 

■■ Drinking water

■■ Groundwater

■■ Surface water

■■ Wastewater

7.1 DRINKING WATER

Drinking water at the STM campus is provided by the 

public water provider Consolidated Mutual Water 

Company. The water is treated at the Maple Grove Water 

Treatment Plant through an advanced membrane water 

treatment method.

The NWTC does not have access to a public drinking 

water supply. For this reason, NREL operates a drinking water distribution system at the NWTC, serving 

about 150 employees. Drinking water is purchased 

from local municipalities and transported by truck to 

the site, where it is transferred to a large holding tank 

with a capacity of 15,000 gallons (56,781 liters). Water is 

pumped from the holding tank to a day tank where it is 

circulated around the site for use. There is no treatment 

of the water, but chlorine is added to boost disinfectant 

levels. The system is permitted by the state of Colorado. 

The water is tested monthly and annually in the same 

ways municipal water systems are tested for residual 

chlorine levels, bacteria, disinfection byproducts, lead, 

and copper. 

Requirements

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

sources, and meeting federal and state air emissions 

and permitting requirements. Minimizing air emissions 

creates direct health benefits for neighbors immediately 

adjacent to the laboratory and for those in the Denver 

metropolitan area. Staff actively participate in project 

planning, safety evaluations, readiness verifications, and 

operations activities. This participation results in awareness of projects and planned air emissions while 

allowing staff to obtain the necessary regulatory approval 

for those emissions and maintain a current and accurate 

air emission inventory.

Requirements

The Clean Air Act, which is administered by both the 

EPA and the state, regulates several main categories of 

air pollutants:

■■ Criteria air pollutants – including carbon monoxide, 

nitrogen oxides, sulfur dioxide, particulate matter, 

respirable particulates, ozone, and lead

■■ Non-criteria pollutants – these include any air 

pollutant that is not defined as a criteria air pollutant. 

Regulated categories of these include the following:

6 AIR QUALITY PROTECTION

The Renewable Fuel Heating Plant burns beetle-kill and 

forest thinning wood to produce hot water to heat many of 

the STM site buildings. Photo by Larry Durbin, NREL 37584

2015 Accomplishments and Highlights 

■■ The laboratory air emissions inventory was 

updated, using equipment-specific emission 

factors where available. This resulted in a more 

accurate emission inventory.

■■ An evaluation of Hazardous Air Pollutant 

emissions indicated that emissions were well 

below reporting and permitting thresholds at 

all NREL sites.
44 ENVIRONMENTAL PERFORMANCE REPORT 2015

● Hazardous Air Pollutants – including specific 

organic and metallic compounds, certain metals, 

corrosive compounds, asbestos, radionuclides, and 

pesticides established by the EPA

● Greenhouse gas compounds – including carbon 

dioxide, methane, nitrous oxide, and many 

man-made refrigerant gases that contribute to 

climate change

● Ozone-Depleting Substances (ODS) – 

including chlorofluorocarbons or “Freon” and 

hydrochlorofluorocarbons that are being phased 

out of use in comfort heating and cooling systems 

and equipment.

For facilities and stationary sources that emit criteria air 

pollutants and hazardous air pollutants, there are various 

federal and state requirements for permitting, reporting, 

emission controls, and operations, depending upon the 

type and amount of air pollutants emitted. Generally, 

these requirements become stricter as the quantity of air 

pollutants emitted increases, or the air pollutants have a 

higher potential for harm or adverse effect.

Greenhouse gases emitted by certain facilities are 

required by federal regulations to be tracked and reported 

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

metric tons) of carbon dioxide equivalent per year. The 

purpose of this reporting is to better identify actual emissions of such gases across the United States and provide 

the EPA with data upon which to base future greenhouse 

gas regulations. Additionally, permits for major emission 

sources (greater than 100 U.S. tons [9 metric tons] per 

year of a criteria pollutant) may be required to include 

greenhouse gases in the permit if carbon dioxide 

equivalent emissions are greater than 100,000 U.S. tons 

(90,718 metric tons) per year. 

Certain refrigerants and similar chemicals are more highly 

regulated than others due to their ability to damage the 

Earth’s protective ozone layer. Federal and state regulations for these ODS, depending upon the quantity of ODS 

and the size of the comfort heating and cooling equipment, require registration, recordkeeping, refrigerant 

recovery, and leak monitoring and repair. These regulations also prohibit the intentional venting of both ODS 

and non-ODS refrigerants into the atmosphere.

There are several state air regulations for sources of 

particulate pollution, including large construction sites 

and street sanding operations in the winter. Particulate 

emissions, such as dust from construction sites larger than 

25 acres (10.1 hectares), or occurring for longer than six 

months, are subject to state fugitive particulate emissions 

permits. Winter road sanding in Colorado can also result in 

particulate emissions when vehicle activity turns roadapplied sand into finer particulates that then become 

airborne. These particulates may contribute to breathing 

and health problems for susceptible individuals. State 

regulations require federal, state, and local government 

facilities to track street sanding in the winter and to 

minimize sand use. Sand is not applied to NREL roadways 

in an effort to minimize particulate emissions from 

laboratory sites.

The primary sources of regulated pollutants at NREL are a 

result of burning fuel, laboratory chemical use, and facility 

operations. Sources include process heat boilers, process 

cooling systems, comfort heating and cooling systems, 

standby electrical generators, construction and maintenance equipment with gasoline or diesel engines, benchand pilot-scale research activities using chemicals, and 

facility operations maintenance activities. 

Program Management 

Criteria Pollutants and Hazardous 

Air Pollutants Permitting

The laboratory maintains an air emission inventory to 

track potential emissions and identify whether future 

Baghouse filter at the Integrated Biorefinery Research Facility. The 

baghouse filter collects dust and particulates generated during 

the biomass milling process of biofuel production. Photo by 

Dennis Schroeder, NREL 17679
ENVIRONMENTAL PERFORMANCE REPORT 2015 45

notification and permitting could be required for a 

particular facility or activity. Projected emissions for new 

sources are evaluated and air emission reporting and 

permitting are performed as required.

The laboratory maintains several air permits issued by 

the state for “minor” sources (such as standby electrical 

generators and pollution control systems) that are 

subject to minimal permit and compliance requirements. 

Currently, Title V “major” permitting is not required 

because all pollutant emissions are well below that 

permitting threshold. 

The laboratory has a fugitive particulate emission permit 

in place for the STM site due to construction activity that 

has occurred over the last several years. To further minimize the generation of airborne particulates, NREL uses 

a non-sand deicer to maintain roadways. This minimizes 

potential fugitive particulate emissions from snow 

removal operations, contributing to improved air quality 

for neighbors and the Denver metro region.

Greenhouse Gas Emissions Tracking 

and Permitting

Permitting and reporting of greenhouse gases are not 

currently required for NREL facilities as emissions are 

below EPA permitting and reporting thresholds. 

Ozone-Depleting Substances Permitting

The majority of refrigeration equipment at NREL either 

contains non-ODS refrigerants or uses very small 

amounts of regulated refrigerants. The only equipment 

containing more than 50 pounds (23 kilograms) of 

regulated refrigerant are two chillers located in the 

Solar Energy Research Facility at the STM site. Operators 

of the chillers must maintain records of service for 

this equipment.

NREL annually registers with the state those facilities 

where ODS maintenance activities occur, maintains 

EPA-approved training certification for all technicians 

servicing ODS-containing equipment, and renews registrations for ODS-containing equipment as necessary. The 

two previously mentioned Solar Energy Research Facility 

chillers each have more than 100 horsepower (74.6 kW) 

of compression, contain an ODS refrigerant, and must be 

registered with the state. 

2015 Compliance Summary and Activities 

■■ Program activities were in compliance with requirements. The laboratory emission sources did not exceed 

any air permit standard.

■■ A summary of NREL facility estimated annual air pollutant emissions is included in Table 4.

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

ANNUAL AIR POLLUTANT EMISSIONS (IN U.S. TONS [METRIC TONS] PER YEAR)*

CRITERIA POLLUTANTS GREENHOUSE GASES HAPs

Year CO NOx VOC PM10 SO2 CO2 CH4 N2

O Total

2011 5.82 (5.28) 8.03 (7.28) 0.44 (0.39) 0.97 (0.88) 0.15 (0.13) 8,310 (7,539) 0.24 (0.21) 0.17 (0.15) 0.19 (0.17)

2012 6.35 (5.76) 16.28 (14.77) 1.09 (0.98) 2.37 (2.15) 0.22 (0.19) 7,175 (6,509) 0.41 (0.37) 0.17 (0.15) 0.31 (0.28)

2013 6.02 (5.46) 13.83 (12.55) 0.47 (0.42) 3.16 (2.86) 0.360 (0.326) 8,584 (7,787) 0.51 (0.46) 0.25 (0.22) 0.51 (0.46)

2014 5.82 (5.28) 14.06 (12.76) 0.99 (0.89) 1.39 (1.26) 0.10 (0.09) 6,263 (5,682) 0.30 (0.27) 0.11 (0.09) 0.16 (0.15)

2015 6.42 (5.82) 15.49 (14.05) 0.54 (0.48) 3.95 (3.58) 0.45 (0.40) 9,329 (8.463) 0.56 (0.50) 0.30 (0.27) 0.63 (0.57)

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

PM10 – respirable particulate matter less than 10 microns in aerodynamic diameter, SO2

 – sulfur dioxide, CO2 – carbon dioxide, 

CH4

 – methane, N2O – nitrous oxide.
46 ENVIRONMENTAL PERFORMANCE REPORT 2015

■■ On behalf of the state, Jefferson County Public Health 

conducted a compliance inspection of permitted 

sources including six standby generators, the Field 

Test Laboratory Building waste gas combustor, and the 

Renewable Fuel Heating Plant. No deficiencies 

were identified.

■■ The annual evaluation of compliance with federal and 

state facility-wide permitting and emissions control 

requirements was completed. All facilities and individually permitted equipment items remain classified 

as minor sources.

■■ The required annual street sanding report was provided to the state and Jefferson County confirming that 

no sand was used at the STM site and NWTC.

■■ The laboratory evaluated carbon dioxide equivalent 

and greenhouse gas emissions and concluded they 

were below the threshold for federal reporting and 

permitting rules.

■■ All state-required ODS equipment registrations, as well 

as annual registration renewals, were completed at the 

STM site and NWTC. Per federal requirements, 

refrigerant recovery equipment has been registered 

with the EPA. 

■■ Four air permits for three standby generators and a 

waste gas combustor were renewed.
ENVIRONMENTAL PERFORMANCE REPORT 2015 47

Water quality is critical to human health and the health 

of our natural ecosystems. The focus of water quality 

protection is on four main areas:

■■ Drinking water

■■ Groundwater

■■ Surface water

■■ Wastewater.

7.1 DRINKING WATER

The public water provider, Consolidated Mutual Water 

Company, provides drinking water at the STM site. 

The Maple Grove Water Treatment Plant treats the 

water through an advanced membrane water 

treatment method.

The NWTC does not have access to a public drinking 

water supply. For this reason, NREL operates a drinking 

water distribution system there, serving approximately 

150 employees. Drinking water is purchased from local 

municipalities and transported by truck to the site, where 

it is transferred to a large holding tank with a capacity 

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

the holding tank to a 2,000 gallon (7,580 liters) day tank, 

where it is circulated around the site for use. There is 

no treatment of the water, but chlorine is added to boost 

disinfectant levels. The state of Colorado permits

the system. 

7 WATER QUALITY

PROTECTION

An NREL staff member analyzes the chlorine concentration 

of potable water being delivered to the NWTC. Photo by

Genevieve Braus, NREL 36266

2015 Accomplishments and Highlights 

An internal assessment of the drinking water 

program identified a number of potential 

improvements, including clarification of procedures, forms, and recordkeeping. Implementation of these improvements is underway.
48 ENVIRONMENTAL PERFORMANCE REPORT 2015

Requirements

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

Drinking Water Act and federal and state regulations. The 

EPA has established allowable levels for drinking water 

contaminants known as Maximum Contaminant Levels. 

Colorado has adopted these Maximum Contaminant 

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

regulate drinking water providers to assure safe, reliable 

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

Program Management

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

testing as required by the monitoring plan issued by 

the state each year. The plan identifies which tests are to 

be performed and at what frequency. Monthly tests are 

required for bacteria and disinfectant levels, while disinfection byproducts (haloacetic acids [HAA5] and trihalomethanes [TTHM]) are sampled once per year and testing 

of lead and copper are completed on a three-year rotating 

basis. Figures 3 and 4 show the results of the chlorine and 

disinfection byproducts monitoring for 2015.

Average Monthly Chlorine Residual, 2015

5.00

4.00

3.00

2.00

1.00

0

4.50

3.50

2.50

1.50

0.50

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

Chlorine

Residual

mg/L

Month

Maximum Allowed

Average Monthly

Chlorine Residual

Figure 4. Comparison of disinfection byproducts monitoring, 2011 – 2015

Figure 3. Results of 2015 average monthly chlorine residual monitoring

Disinfectant Byproducts

80

70

60

50

40

30

20

10

0

2011 2012 2013 2014 2015

Amount

Present,

ppb

TTHM MCL*

TTHM

HAA5

HAA5 MCL* 

*MCL – Maximum Contaminant Level 
ENVIRONMENTAL PERFORMANCE REPORT 2015 49

2015 Compliance Summary and Activities

■■ Program activities were in compliance with 

requirements.

■■ All monitored parameters met applicable 

requirements.

■■ Jefferson County Public Health, on behalf of the state 

of Colorado, inspected the NWTC drinking water 

system. In addition to the absence of deficiencies and 

violations, NREL and its subcontractor were commended for their detailed and comprehensive management 

of the system and for the extent of protection of water 

quality from delivery to consumption.

■■ Modifications to the backflow prevention and cross 

contamination plan were completed in advance of 

the January 1, 2016, compliance deadline, as required 

by 2015 revisions to the state’s drinking water regulations. Implementation of the plan, including an annual 

inventory and assessment of all possible drinking 

water system contamination sources, is ongoing.

■■ A total of 493,175 gallons (1,866,869 liters) of drinking 

water were provided to NWTC users. 

7.2 GROUNDWATER

The Denver Basin aquifer system underlies an area of 

approximately 7,000 square miles (2,833 hectares) that 

extends from Greeley south to near Colorado Springs 

and from the Front Range east to near Limon. The aquifer 

provides groundwater supplies to urban, rural, and agricultural users. The aquifers within the Denver Basin aquifer system, which include the Dawson, Denver, Arapahoe, 

and Laramie-Fox Hills aquifers, form a layered sequence 

of rock in an elongated, bowl-shaped structural depression. Both the STM site and the NWTC are located at the 

western edge of the Denver Basin aquifer system.

The STM site overlies the shallowest portions of the 

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

NWTC overlies the shallowest portions of the Arapahoe 

and Laramie-Fox Hills aquifers. The Dawson formation is 

the shallowest of the Denver Basin aquifers and is the one 

most relied on by the groundwater users in the basin. The 

northern extent of the Dawson aquifer is located approximately 20 miles (33 km) to the south and east of the STM 

site; consequently, wells drilled at either the STM site or 

the NWTC would not intersect the Dawson aquifer, nor 

would a source of contamination affect the groundwater 

quality in this aquifer. 

Despite the limited ability of reaching the Dawson aquifer, 

NREL’s groundwater management program is focused on 

the control of potential pollutant sources that could affect 

this important source.

Requirements

The state of Colorado regulates the installation of 

groundwater wells, requiring a permit for drinking water, 

geothermal, irrigation, livestock watering, dewatering, 

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

Program Management

Periodically, NREL monitors site groundwater quality 

using one or more monitoring wells. When the laboratory conducts activities that could impact groundwater, 

NREL implements a monitoring program and groundwater monitoring wells are installed as needed. There are 

currently three permitted monitoring wells at the STM site 

Installation of a groundwater monitoring well near the Field Testing 

Laboratory Building at the STM site. Photo by Genevieve Braus, 

NREL 36268

2015 Accomplishments and Highlights 

■■ There were no spills or releases that 

impacted groundwater.

■■ Three groundwater monitoring wells were 

installed at the STM site on the north side 

of the Field Testing Laboratory Building to 

determine if groundwater or surface water 

is the source of water seepage observed 

within the building. Groundwater level 

measurements and limited groundwater 

quality data collected from the wells are 

being used to assist with this effort. 
50 ENVIRONMENTAL PERFORMANCE REPORT 2015

from which data is being collected to assist in understanding whether groundwater may be contributing to water 

seepage observed in one of the site buildings. There are 

no groundwater monitoring wells at the NWTC.

There are two permitted closed-loop geothermal systems 

in operation at the STM site; one is located at the Solar 

Radiation Research Laboratory and the second is located 

near the South Site Entrance Building. 

To protect groundwater quality, NREL carefully evaluates 

all outdoor projects to eliminate, substitute, or control 

potential sources of pollution. If any materials are used 

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

disposal of concrete wash water. 

2015 Compliance Activities

■■ Program activities were in compliance with 

requirements.

■■ Five groundwater monitoring wells that were no 

longer being sampled or monitored at the STM 

site were abandoned in conformance with 

state regulations. 

■■ Three groundwater monitoring wells were installed in 

conformance with state regulations.

7.3 SURFACE WATER

Through its surface water program, NREL seeks to protect 

the quality of nearby receiving waters into which the STM 

site and the NWTC drain. These receiving waters include 

Lena Gulch at the STM site and Coal Creek and Rock Creek 

at the NWTC. Sediment, debris, and chemicals transported 

to these water bodies via stormwater runoff can harm 

or kill fish and other wildlife either directly or by destroying aquatic and riparian habitat. High volumes of 

sediment can result in stream bank erosion and clogging 

of waterways.

Water quality protection is accomplished through compliance with federal and state stormwater permitting 

requirements, management of stormwater runoff flowing across active construction sites, inclusion of project 

design elements that promote infiltration and detention 

of stormwater, and management of NREL grounds to 

minimize erosion and support infiltration.

Successful restoration of native grasses in an area disturbed during 

construction of the Energy Systems Integration Facility. Photo by 

Dennis Schroeder, NREL 34003

2015 Accomplishments and Highlights 

■■ Revegetation was achieved in areas 

disturbed as a result of construction of the 

Energy Systems Integration Facility, thus 

allowing termination of EPA stormwater 

permit coverage. Successful revegetation 

occurs, as defined by the EPA, when vegetative cover equals 70% of pre-disturbance 

cover. Carefully selected seed mixes and 

mulches, together with weed management and temporary irrigation, were 

instrumental in achieving a native grass 

cover sufficient to meet the EPA criteria.

■■ Repeated reseeding and mulching applications as well as weed management 

activities were conducted on a portion of 

the STM site disturbed during an electrical upgrade project that was completed 

in 2014. These activities will continue until 

native grass cover meeting federal stormwater permit revegetation requirements 

is achieved. 

■■ Backfilling, seeding, and mulching activities were performed in an area adjacent to 

the Field Test Laboratory Building where a 

steep slope had become eroded as a result 

of runoff associated with the 2013 flood 

event and a leaking buried domestic 

water line. 

■■ Periodic stormwater inspections were 

performed at locations where active 

construction recently occurred to protect 

stormwater quality and prevent sedimentation and erosion. 
ENVIRONMENTAL PERFORMANCE REPORT 2015 51

Requirements

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

construction activities that disturb greater than one acre. 

The EPA is the regulating authority for stormwater at NREL, 

which is a federally owned facility. For onsite construction 

projects that disturb greater than one acre, a Notice of 

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

Construction General Permit, and a site-specific Stormwater Pollution Prevention Plan must be prepared. The 

Stormwater Pollution Prevention Plan implements both 

the requirements of the EPA’s Construction General Permit 

and NREL-specific requirements. For NREL construction 

projects that occur off federal property, Colorado 

Discharge Permit System stormwater permits may 

be required.

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

comply by using low-impact design elements such as 

porous pavers, cisterns, and bioswales, or retain 

stormwater runoff and release at predevelopment levels. 

In addition, EO 13693, Planning for Federal Sustainability 

in the Next Decade, directs federal agencies to install 

appropriate green infrastructure features to improve 

stormwater management.

Program Management

The surface water program focuses on managing construction site runoff, which has the potential to impact receiving waters into which NREL sites drain. 

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

approvals for compliance with the National Environmental 

Policy Act, and the assessment of design documents for 

potential impacts to stormwater and receiving waters. 

Design teams are encouraged to incorporate low-impact 

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

documents and construction implementation to look for 

additional opportunities to reduce runoff quantity and 

enhance runoff quality.

Erosion and sediment controls, proper chemical storage, 

fueling procedures, and good housekeeping practices 

are implemented during construction according to the 

stormwater management plans developed by contractors 

and reviewed by project staff for EPA-permitted sites as 

well as those construction sites for which an EPA permit is 

not required. While construction projects that disturb less 

than one acre are not regulated by the EPA and typically 

involve minimal disturbance within a short timeframe, 

such projects still have the potential to contribute pollutants to stormwater runoff. Elements of the NREL stormwater pollution prevention program are therefore followed, 

including the development of an abbreviated Stormwater 

Pollution Prevention Plan documenting basic contact, 

project, and best management practice information. An 

illustration showing the area of disturbance and locations 

of key site characteristics and best management practices 

is also required.

Regular inspections by contractors and staff are conducted 

throughout construction to verify that required controls 

are functioning properly. Any repairs or modifications 

to the plans are documented on an inspection report; 

prompt actions are required to correct any 

noncompliant conditions.

Management of areas outside active construction sites 

minimizes erosion, supports infiltration of rain water and 

snowmelt, and prevents contamination of stormwater 

with hazardous materials. Vegetation and landscaping are 

maintained to prevent erosion. Infiltration of precipitation 

is achieved through detention basins and grassy swales, 

as well as design elements including porous pavement 

and diversion of roof and perimeter drains to landscaped 

areas. In addition, hazardous wastes are stored indoors or 

in covered areas, and site roads and sidewalks are swept 

to reduce sediment and other potential pollutants from 

entering the stormwater conveyance system. 

2015 Compliance Summary and Activities

■■ Program activities were in compliance with 

requirements.

■■ Permit coverage under the EPA Construction General 

Permit continues for two STM site construction projects; 

Porous pavers surrounding a manhole cover in a STM site roadway. 

Porous pavers promote stormwater infiltration, improve stormwater 

runoff quality and reduce runoff volume leaving NREL sites. 

Photo by Genevieve Braus, NREL 36264
52 ENVIRONMENTAL PERFORMANCE REPORT 2015

there are no active construction stormwater permits at 

the NWTC.

■■ A Low Erosivity Waiver was prepared and submitted to 

the EPA for a road improvement project at the NWTC. 

The waiver allowed for construction to proceed without 

EPA Construction General Permit coverage, given that 

required computations indicated a low potential for 

negative impacts to stormwater quality from construction activity. Although the waiver was granted, NREL 

implemented stormwater controls to protect stormwater 

quality and prevent erosion and sedimentation. 

■■ EPA Construction General Permit coverage for one 

completed project was terminated.

■■ Weekly stormwater inspections were performed per 

EPA stormwater regulations where active construction 

occurs; monthly stormwater inspections were performed 

for construction sites where EPA Construction General 

Permit coverage continues during the restoration phase 

of these projects. 

7.4 WASTEWATER

Untreated or poorly treated wastewater has the potential 

to contaminate surface and groundwater used for drinking 

water, irrigation, industrial, commercial, and recreational 

purposes. The majority of wastewater from the STM site and 

Denver West Office Park facilities flows into the Pleasant 

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

and ultimately to the Metropolitan Wastewater Reclamation 

District’s (Metro District) central treatment plant. Wastewater from the Joyce Street Facility and the Renewable Fuels 

and Lubricants Research Laboratory also flows to the Metro 

District’s treatment plant. 

Research activities at the STM site's Integrated Biorefinery 

Research Facility develop, test, evaluate, and demonstrate 

processes for the production of bio-based products and 

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

converting cellulosic biomass into a variety of fuels and 

chemicals. The pH of the effluent from this process is adjusted to fall within an allowable pH range prior to discharge 

into the sanitary sewer system. The Metro District and Pleasant View system managers periodically tour the facility and 

review the operational controls.

For those facilities that lack sanitary service, there are three 

small septic systems in place, each consisting of a tank and 

a leach field. One is located at the STM site's mesa top Solar 

Radiation Research Laboratory and two are at the NWTC. 

A preventative maintenance and inspection program is in 

place to confirm proper system function.

Requirements

Non-domestic wastewater discharges to the Metro 

District must comply with the Metro District’s rules and 

regulations, which incorporate requirements of the 

Clean Water Act, such as the Pretreatment Program. The 

Pretreatment Program is the set of regulations applied 

to industries and commercial operations that generate 

non-domestic wastewaters with potentially high levels of 

pollutants that could have an impact on wastewater treatment facilities and the environment. 

The program includes specific regulations for certain 

types of industries, for dischargers of large quantities of 

industrial wastewater, and for all non-domestic wastewater discharges. NREL’s operations are not among those 

identified as requiring specific discharge regulations, nor 

does the laboratory discharge a volume of water that 

would trigger requirement of a formal discharge permit 

from the Metro District for large industrial wastewater 

users. The laboratory does comply with all applicable 

requirements including the general prohibitions for all 

non-domestic wastewater discharges that protect Metro 

District’s collection and treatment systems. These prohibitions include the discharge of hazardous materials, highly 

viscous substances, radioactive material, excessive oil 

and grease, or other substances that could cause 

material harm to the wastewater treatment system and 

the environment. 

Program Management

NREL’s wastewater management program is multi-faceted 

and encompasses activities across the site, from green 

cleaning supplies to minimization of harmful chemicals 

in laboratory operations, and is intended to adhere to 

requirements and minimize potential impacts to the 

treatment processes.

NREL staff are trained in the requirements of the Metro 

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

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

criteria include measures such as secondary containment for 

any chemicals used near sinks in laboratory exhaust hoods, 

no floor drains in laboratory areas unless a specific need 

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

laboratory areas. New research and operations activities as 

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

for their potential effect on wastewater character. 

2015 Compliance Summary and Activities

■■ Program activities were in compliance with 

requirements. 
ENVIRONMENTAL PERFORMANCE REPORT 2015 53

Responsible acquisition, use, and disposal of materials 

and wastes are critical to meeting our commitments to 

compliance, preventing pollution, and environmental 

stewardship. NREL seeks to purchase materials that 

are sourced responsibly and contain recycled content 

and lower-impact materials. Use of hazardous materials is thoughtfully controlled with internal procedures 

designed to limit health and environmental risks. Wastes 

are carefully managed and disposed of through select 

contractors. Areas of focus include:

■■ Hazardous materials management

■■ Regulated waste management

■■ Aboveground storage tank management

■■ Spill prevention and response 

■■ Radiological materials and waste management.

8.1 HAZARDOUS MATERIALS 

MANAGEMENT

A variety of chemicals and materials, some of which are 

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

protective of laboratory personnel, the general public, and 

the environment. 

Requirements

Hazardous material management is regulated at the 

federal level through the Superfund Amendments and 

Reauthorization Act Title III, which is also known as the 

Emergency Planning and Community Right-to-Know Act 

of 1986 (EPCRA). EPCRA was created to help communities 

and federal, state, and local governments plan for 

emergencies involving hazardous substances. It also 

requires industry to report on the storage, use, and 

accidental releases of hazardous chemicals to federal, state, 

and local governments. 

8

 HAZARDOUS MATERIALS 

 AND WASTE MANAGEMENT

Barcode scanner being used to inventory chemicals in a 

laboratory. This tool is one component of a laboratory-wide 

chemical management program that ensures the proper 

handling of NREL’s chemicals throughout their lifecycle. 

Photo by Dennis Schroeder, NREL 33676
54 ENVIRONMENTAL PERFORMANCE REPORT 2015

NREL facilities are subject to Sections 302, 304, 311, 312, 

and 313 of EPCRA. Please refer to Table 5 for NREL’s EPCRA 

reporting status.

NREL is also subject to permitting requirements through 

local jurisdictions and obtains annual hazardous material 

permits from West Metro Fire Rescue for the STM site and 

Denver West Office Park facilities. These permits are issued 

for a total of seven buildings where hazardous materials 

are stored and/or used. Prior to issuing the permits, a 

representative from West Metro Fire Rescue conducts a 

walk-through inspection of the entire STM site and Denver 

West Office Park. 

The Renewable Fuels and Lubricants Research Laboratory is 

within the jurisdiction of the City and County of Denver and 

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

of listed materials, including various fuels such as biodiesel, 

must be reported to the Denver Fire Department annually. 

The Denver Fire Department inspects the facility and issues 

a hazardous materials permit.

Hazardous materials permits are currently not required at 

the NWTC or the Joyce Street Facility.

Program Management

In addition to the EPCRA reporting obligations described 

above, a cornerstone of NREL’s hazardous material 

management program is its laboratory-wide chemical 

management system, which serves as a centralized 

chemical inventory and as a tool for managing and 

reporting on chemicals used at the laboratory. Using an 

electronic barcoding system, the chemical management 

system tracks chemicals from the point of receipt through 

end-use and disposal. The system also contains technical 

data and reporting information for many of the chemicals 

in the chemical management system database. Key 

functions of the system include: 

■■ Providing current inventories by room, building, and/

or site 

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

needed chemicals are already available on-site prior to 

making chemical purchases

NREL researcher works with cyanobacteria in the Photobiology 

Laboratory. Researchers attempt to reduce the amount of hazardous 

chemicals used and the amount of hazardous wastes generated in 

their experiments. Photo by Dennis Schroeder, NREL 25032

TABLE 5. 2015 EPCRA REPORTING

EPCRA 

Section Description of Reporting Status

EPCRA Section 302 Planning Notification Not 

required

EPCRA Section 304 Extremely Hazardous 

Substance Release Notification

Not 

required

EPCRA Section 

311-312

Safety Data Sheet/

Chemical Inventory Reported 

EPCRA Section 313 Toxics Release 

Inventory Reporting

Not 

required

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

report under the provision cited because it did not meet 

the threshold or did not have an extremely hazardous 

substance release. 

2015 Accomplishments and Highlights

■■ Laboratory safety training, required 

annually for all laboratory workers and 

NREL emergency response team members, 

was updated to reflect current regulations and 

enhanced to raise awareness of the various 

classes of hazardous materials stored in 

NREL laboratories.

■■ The laboratory’s chemical inventory was 

reviewed, and unneeded or expired materials 

were collected for reuse or proper disposal. 

■■ An internal assessment was conducted of the 

laboratory’s hazardous waste management 

program. Five minor non-conformities, five 

opportunities for improvement, and one 

positive practice were identified. Corrective 

actions to address non-conformities have 

been developed.
ENVIRONMENTAL PERFORMANCE REPORT 2015 55

■■ Providing quick access to chemical inventories and 

hazard information during emergency responses

■■ Facilitating accurate and efficient reporting to external 

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

response agencies, EPA, and DOE). 

Hazardous materials are rigorously managed, starting 

with the chemical management system that tracks 

chemical amounts, locations, and hazards. Each week, 

safety personnel receive a list of the chemicals and their 

hazards that were shipped to NREL during the previous 

week. Researchers and safety personnel ensure that 

chemicals are properly stored in locations suitable for 

their hazards such as storing flammable materials in 

designated flammables cabinets. 

When requested by the state and local emergency 

response agencies or local fire departments, additional 

emergency response and reporting information is 

provided. NREL has been represented in the Jefferson 

County Local Emergency Planning Committee since 

its inception and is actively involved in the emergency 

planning concepts of EPCRA, with two active members on 

the committee.

Emergency response plans are also in place in the event of 

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

coordinated with state and local emergency planning and 

response agencies and first responders, such as the West 

Metro Fire Rescue, Rocky Mountain Fire Rescue, and the 

Jefferson County Local Emergency Planning Committee. 

2015 Compliance Summary and Activities

■■ Program activities were in compliance with 

requirements. 

■■ There were no releases of hazardous materials requiring reporting. In accordance with DOE Order 151.1c, 

Comprehensive Emergency Management System, NREL 

conducted a hazardous materials screening of select 

chemicals to confirm that inventories are below threshold planning quantities.

■■ EPCRA Tier II hazardous materials reports were submitted to the required state and local emergency response 

and planning agencies as well as local fire departments 

for three facilities for reporting year 2014. Chemicals 

reported included diesel fuel, petroleum oil, and sulfuric 

acid in lead-acid batteries. 

■■ West Metro Fire Rescue conducted an annual hazardous 

material inspection and issued permits for seven 

facilities. 

■■ The inventory of hazardous materials at the Renewable 

Fuels and Lubricants Research Laboratory was provided 

to the Denver Fire Department.

8.2 REGULATED WASTE MANAGEMENT

Research and development activities and general facility 

operations create a variety of waste streams including 

those containing toxic chemicals or metals. 

NREL typically disposes or recycles the following categories 

of waste:

■■ Hazardous waste (as defined by environmental 

regulations)

■■ Non-hazardous waste such as propylene glycol from 

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

such as regular trash)

■■ Universal waste such as mercury-containing light 

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

waste such as computers, monitors, and research 

instrumentation containing electronic circuitry.

Requirements

Regulated wastes are handled and disposed of according 

to the federal Resource Conservation and Recovery Act 

and the state of Colorado hazardous waste regulations. 

Additional applicable requirements for hazardous material transportation are regulated by the U.S. Department 

of Transportation.

NREL maintains unique EPA identification numbers for each 

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

Joyce Street Facility, and Renewable Fuels and Lubricants 

Research Laboratory. Per state and federal regulations, 

annual generator notifications are made and applicable 

fees are paid to the state based on monthly volumes of 

2015 Accomplishments and Highlights

■■ As a best management practice, all NREL 

facilities are managed to the stringent Large 

Quantity Generator status hazardous waste 

regulatory requirements, which require 

personnel training, contingency planning, and 

container management.

■■ Twenty cubic yards (15 cubic meters) of 

non-hazardous, nanomaterial-bearing High 

Efficiency Particulate Air filters from NREL 

facility ventilation systems were shipped 

to a hazardous waste landfill as a best 

management practice.
56 ENVIRONMENTAL PERFORMANCE REPORT 2015

hazardous waste that are generated at each facility. The 

three waste generator classifications are:

■■ Large Quantity Generator

■■ Small Quantity Generator 

■■ Conditionally Exempt Small Quantity Generator.

Four out of five of NREL’s sites fall under the waste generator 

category of Conditionally Exempt Small Quantity Generator because they generate minimal amounts of hazardous 

waste per calendar month. The STM site typically produces 

quantities of hazardous waste well within the category 

of Small Quantity Generator; however, due to pilot-scale 

research experiments, the STM site can episodically elevate 

to that of Large Quantity Generator category in one or more 

months during the year. 

Program Management

Waste management and minimization efforts begin in the 

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

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

activity begins and continues until material use is complete 

and it is ready for disposal. Hazardous materials proposed 

for use are also assessed for the potential substitution of 

less hazardous products, resulting in less hazardous 

waste streams. 

The laboratory is committed to the appropriate management of regulated waste generated through its daily operations. These wastes are handled, stored, and disposed of 

responsibly and per regulatory requirements to minimize 

the potential for health and environmental impacts that 

could result from a release or improper disposal.

Implementation of regulatory requirements includes:

■■ Documented waste management and minimization 

program

■■ Annual training for all staff who generate and/or handle 

regulated waste

■■ Regular inspection and tracking of all waste containers

■■ Storage, packaging, shipment, and tracking until final 

disposition at a properly permitted waste disposal or 

recycling facility

■■ Active monitoring of waste volumes to determine 

generator status

■■ Maintaining records that are generated through “cradle 

to grave” waste management activities.

For select unregulated materials that still pose a potential 

hazard, NREL follows a conservative waste management 

policy wherein the material is collected and disposed as 

non-hazardous materials at properly permitted disposal 

facilities. For example, non-hazardous, nanomaterial-bearing wastes are not federally regulated, but because they 

pose a potential health risk, are managed and disposed of 

via the same management methods used for hazardous 

waste. Waste streams are accumulated on site for timeframes well within regulatory limits prior to being shipped 

for final disposal. In a general order of management 

preference, hazardous waste items are shipped off-site 

for final disposal via incineration, treatment, and landfill. 

Universal wastes are recycled or reclaimed. 

Table 6 provides a summary of quantities and types of waste 

generated at NREL for the past five years.

TABLE 6. COMPARISON OF FOUR WASTE 

CATEGORIES GENERATED AT NREL 

FACILITIES (IN LBS. [KGS] NET WEIGHT)

Hazardous 

Waste

Non-Hazardous 

Waste

Universal 

Waste 

Electronics

Other 

Universal 

Waste

2011 20,557

(9,324) 

6,156

(2,792)

29,549 

(13,403)

3,539

(1,605)

2012 33,386 

(15,144)

8,805

(3,994)

41,355 

(18,758)

4,803

(2,179)

2013 14,974

(6,792)

4,477

(2,031)

38,096 

(17,280)

19,063

(8,647)

2014 14,683

(6,659)

15,198

(6893)

28,551

(12,949)

6,738

(3,056)

2015 17,040

(7,729)

47,407

21,503

31,964

(14,499)

15,600

(7,076) Regulated wastes generated across the STM site are consolidated at 

the Waste Handling Facility for packaging prior to offsite disposal or 

recycling. Photo by Sheila Hayter, NREL 14003
ENVIRONMENTAL PERFORMANCE REPORT 2015 57

2015 Compliance Summary and Activities

■■ Program activities were in compliance with 

requirements.

■■ Nineteen hazardous and five universal waste shipments for offsite disposal were made across NREL’s 

five sites. 

■■ Mandatory employee hazardous and universal waste 

management training was completed in compliance 

with state and federal requirements. 

■■ All regulatory notifications were updated and applicable waste generator fees were paid.

■■ Twelve cubic yards of imported sugarcane bagasse 

used in biofuels research were transported and 

disposed of in accordance with guidelines set forth by 

the U. S. Department of Agriculture’s Animal and Plant 

Health Inspection Service. Disposal involved placement and subsequent burial at a municipal solid 

waste landfill.

8.3 ABOVEGROUND STORAGE TANK 

MANAGEMENT

Proper tank management prevents or minimizes the size of 

spills and leaks of fuels or oils, avoiding contamination of 

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

supports the laboratory’s commitments to environmental 

stewardship and pollution prevention.

The aboveground storage tank (AST) management program 

applies to petroleum fuel tanks and is intended to:

■■ Minimize releases from tanks

■■ Confirm that safety features are present and functional

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

The risk of underground soil and water contamination from 

storage tanks is minimized by using only aboveground 

tanks. Unlike underground tanks, aboveground installations 

provide access for regular visual leak inspections and 

allow for less costly repair and cleanup.

NREL operates several ASTs, which are maintained 

using best management practices and according to

applicable regulations.

Requirements

ASTs in Colorado are regulated by the state, which requires 

that ASTs with capacities of 660 gallons (2,498 liters) or 

larger be permitted prior to installation, inspected by the 

state following installation, and registered with the state 

within 30 days following commencement of use. 

Regulations require that ASTs be constructed and installed 

according to specific standards, be regularly inspected 

with all inspections documented, and that facilities meeting certain oil storage quantities employ a Spill Prevention, 

Control, and Countermeasures plan to manage oil sources 

55 gallons (208 liters) or larger. (For more details, see section 

8.4, Spill Prevention and Response.)

Eighteen ASTs are maintained at the STM site with a 

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

at Denver West Office Park with a capacity of 500 gallons 

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

capacity of 1,006 gallons (3,808 liters). Five ASTs at the 

STM site are registered with the state. There are no ASTs at 

the NWTC, Renewable Fuels and Lubricants Laboratory, or 

Joyce Street facility that need to be registered. 

Program Management

NREL’s AST management program consists of permit 

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

Staff actively participate in the program through:

■■ Participating in project planning, safety evaluations, 

and readiness verifications

2015 Accomplishments and Highlights 

■■ All tanks were inspected to confirm 

continued adherence to recently 

revised regulations.

■■ Annual AST training was provided to 27 staff 

members identified as having responsibility 

for operating and fueling ASTs or that 

perform oversight for tank safety and 

environmental compliance. Emergency generator near the employee parking garage at the 

STM site. Photo by Genevieve Braus, NREL 36262
58 ENVIRONMENTAL PERFORMANCE REPORT 2015

■■ Conducting regular tank inspections and maintenance 

activities 

■■ Achieving timely, necessary regulatory approval 

■■ Maintaining a current and accurate AST inventory

■■ Placing spill response supplies in key locations 

■■ Planning and documenting of annual training activities.

Personnel who operate and manage ASTs are trained annually on program requirements including inspection and 

response requirements, spill history of each site, lessons 

learned, and recent changes in rules and regulations.

Several important mechanical and procedural safeguards 

have been incorporated into NREL’s AST management 

program to prevent an accidental release of diesel or 

E-85 fuel from the storage tanks. Mechanical safeguards 

include overfill and spill protection, double-wall tanks 

equipped with sensors that result in an alarm if the inner 

tank wall is leaking, and secondary containment for 

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

annual inspections, and recordkeeping of inspection 

results. ASTs larger than 60 gallons (227 liters) are visually inspected monthly and all double-walled ASTs are 

inspected annually to confirm that there is no liquid in the 

interstitial space.

2015 Compliance Summary and Activities

■■ Program activities were in compliance with EPA and 

state AST requirements.

■■ No reportable spills occurred associated with tank 

equipment failures or tank filling operations.

■■ No new tanks were permitted or installed. 

8.4 SPILL PREVENTION AND 

RESPONSE

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

causing damage to ecosystems, wildlife habitat, and human 

health. Comprehensive planning using spill prevention, 

control, and countermeasures plans (SPCC) can reduce spills 

and limit impacts to the environment when spills do occur. 

Requirements

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

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

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

waters of the United States or state of Colorado waters 

must have a SPCC plan. SPCC regulations require that any 

equipment or containers with the capacity to store 55 

gallons (208 liters) or more of oil be included in the plan.

The plan must address such items as: 

■■ Topography and location of waterways

■■ Location and quantity of oil sources

■■ Possible spill pathways

■■ Spill scenarios and potential spill volumes

■■ Spill prevention and response training

■■ Spill notification procedures and contact information

■■ Emergency response activities.

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

NWTC, and the Renewable Fuels and Lubricants Research 

Laboratory, a SPCC plan is required for those locations.

2015 Accomplishments and Highlights 

■■ The laboratory SPCC training course was 

updated to include new facilities and 

revised SPCC plans. Two additional large 

portable spill control kits were placed at 

key STM site locations to improve rapid 

response capability.

■■ The STM site SPCC Plan was revised to include 

additional oil-containing items including 

transformers, hydraulic equipment and 

storage drums.

Spill kit near the E-85 tank at the STM site. Photo by Larry Durbin, 

NREL 36265
ENVIRONMENTAL PERFORMANCE REPORT 2015 59

Program Management

The laboratory prepares for and continually improves spill 

response. Formal SPCC plans have been developed and 

are periodically updated for three facilities. The plans are 

designed to minimize the number and size of spills, and 

speed the control and cleanup of spilled materials. SPCC 

plans are updated every three years, or whenever there is 

a significant change in regulations, operations, or equipment. This aggressive approach to spill prevention and 

control exceeds the EPA’s requirement that SPCC plans be 

updated at least every five years.

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

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

spill response protects water and ecological resources.

SPCC training occurs annually for individuals who are 

responsible for oil-containing equipment and AST 

operation and maintenance. SPCC training is combined 

with AST training and educates staff on oil-containing 

equipment at each site. Training also includes inspection 

and response requirements, location and use of 

spill response equipment, and notification and spill 

reporting protocols.

The laboratory typically does not experience spills that 

require notification to federal and state agencies. Small, 

incidental hydraulic system leaks, lubricant leaks, and fuel 

transfer spills may occur on occasion. Lessons learned 

from spill incidents and clean-up activities are used to 

improve management and spill response planning.

2015 Compliance Summary and Activities

■■ Program activities were in compliance with 

requirements.

■■ Forty-nine staff who manage and/or operate oilcontaining equipment received annual SPCC training. 

■■ No reportable spills occurred. Sixteen minor spills of 

diesel, lubricant, coolant, and hydraulic fluids occurred 

at the STM site, and two spills occurred at the NWTC. 

The size of spills ranged from less than 0.1 gallon to 4 

gallons (0.38 to 15 liters). The majority of these spills 

were the result of leaks from vehicles and construction 

equipment. Each spill received immediate remedial 

action and did not result in any significant impact to 

the environment.

8.5 RADIOLOGICAL MATERIALS AND 

WASTE MANAGEMENT

NREL conducts a wide range of research and operational 

activities that incorporate the use of radiological materials. The laboratory occasionally uses small quantities of 

radioisotopes for biological labeling and electron microscopy staining. All of the radioisotopes have very low 

activity levels and are used in extremely small amounts. 

A number of sealed sources are present in analytical and 

process equipment, check sources, and emergency exit 

signs. Unlike many DOE facilities, NREL does not have 

legacy radiological contamination issues associated with 

past nuclear weapons production and research.

Requirements

Radiological air emissions are regulated by the EPA. DOE 

Order 458.1, Radiation Protection of the Public and the 

Environment, establishes radiation emission limits for DOE 

facilities. These facilities, including NREL, must annually 

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

To understand effective dose equivalent, you must first 

define dose and dose equivalent:

■■ Dose – a generic term to describe the amount of 

radiation a person receives.

■■ Dose Equivalent – a measure of the biological 

risk of the energy that the radiation deposited in 

tissue, which depends on the type of radiation 

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

called a millirem, abbreviated as mrem.

■■ Effective Dose Equivalent – the total of the dose 

equivalent to the organ or tissue multiplied by 

weighting factors applicable to each of the body 

organs or tissues that are exposed to radiation.

An average person in the United States receives 

about 310 mrem each year from natural sources and 

an additional 310 mrem from medical procedures 

and consumer products.

What Is “Effective Dose Equivalent?”
60 ENVIRONMENTAL PERFORMANCE REPORT 2015

any member of the public from receiving an effective 

dose equivalent of 10 mrem per year or greater.

Program Management

NREL has established strict protocols for radiationgenerating devices, equipment containing sources of 

radiation or for the use of radioisotopes in laboratory 

experiments through its radiation safety program. Some of 

these controls include:

■■ Confining work with radioisotopes to a small number 

of specific laboratories

■■ Limiting the types and quantities of radioisotopes 

onsite

■■ Monitoring equipment and facilities for removable 

contamination or sealed-source leakage.

No radioactive air emission monitoring is conducted 

at the laboratory because of the extremely low usage 

of radioactive material. Therefore, NREL demonstrates 

compliance with radiological air emission standards by 

using an EPA computer model (COMPLY Version 1.6) to 

determine the effective dose equivalent to the public. 

Current laboratory procedures prohibit any activity that 

may result in a radioactive waste that is also federally 

regulated under the Resource Conservation and Recovery 

Act and thus categorized as “mixed waste.” Therefore, all 

radioactive waste generated is classified solely as low-level 

radioactive waste. Waste is temporarily stored on-site 

until disposal is arranged at an off-site facility permitted 

to accept low-level radioactive waste. Internal procedures 

prohibit the disposition of property unless it has been 

decontaminated to background levels.

2015 Compliance Summary and Activities

■■ Program activities were in compliance with 

requirements. 

■■ Only small quantities of low-level radioactive waste 

were generated and are currently in storage awaiting 

off-site disposal.

■■ The effective dose equivalent of radiation to the public 

was 0.036 millirem (mrem) per year, far below the 10 

mrem per year limit.
ENVIRONMENTAL PERFORMANCE REPORT 2015 61

9 NATIONAL ENVIRONMENTAL

POLICY ACT

NREL’s National Environmental Policy Act (NEPA) 

program provides a mechanism to consider the potential 

for environmental impacts in decision-making processes 

and to promote sustainable and environmentally 

responsible operations. Under this program, staff analyze 

the potential impacts for a wide range of activities prior 

to spending funds or commencing work. 

Requirements

NEPA is a federal law that requires potential environmental impacts to be considered for activities having 

a federal connection, such as those using federal 

funds, property, facilities, employees, and equipment. 

NEPA represents the federal government’s mandate to 

consider the environment equally to other factors when 

making decisions. It directs federal agencies to take into 

account, and publicly disclose, the environmental consequences of proposed actions. 

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

president’s Council on Environmental Quality enacted 

regulations that provided direction to federal agencies on 

how NEPA should be implemented. Subsequently, DOE 

established NEPA Implementing Procedures which are 

“Bio-oils” produced at the Field Testing Laboratory Building. 

By subjecting feedstocks such as corn stover or beetle-kill 

wood to high temperatures in the absence of oxygen, oils 

generated in this way have the potential of being used as 

a renewable transportation fuel. Photo by Dennis Schroeder, 

NREL 33054

2015 Accomplishments and Highlights 

■■ The environmental review process was evaluated to identify ways to enhance the laboratory’s ability to meet the spirit and intent of 

NEPA requirements. 

■■ NREL staff members continued to provide 

NEPA support in identifying potential environmental impacts related to DOE Funding 

Opportunity Announcements that support 

DOE’s mission.
62 ENVIRONMENTAL PERFORMANCE REPORT 2015

used by both DOE and NREL to comply with NEPA and the 

Council on Environmental Quality regulations.

Under NEPA, DOE considers and documents environmental factors used in deciding what level of evaluation is 

required for a proposed action. These are:

■■ Categorical Exclusion 

■■ Environmental Assessment 

■■ Environmental Impact Statement.

Categorical Exclusion (CX)

A CX determination is the lowest level of NEPA review and 

can be applied to activities that are known not to have a 

significant individual or cumulative effect on the quality 

of the human and natural environment. Each agency has 

a unique set of CXs based on their own routine activities. 

Examples of DOE’s CXs include:

■■ Routine administrative and business activities

■■ Specific types of site and facility maintenance and 

improvements

■■ Information gathering and data analysis

■■ Technical assistance activities

■■ Research activities conducted at existing offsite nonNREL laboratories

■■ Small-scale renewable energy research and development projects

■■ Research and operations activities at NREL’s ReFuel and 

Joyce Street facilities.

Environmental Assessment (EA)

If the proposed action has extraordinary circumstances 

present (such as potential effects to environmentally 

sensitive resources that must be addressed, public controversy, or new construction not addressed in a site-wide 

EA), or the proposed action fits within a category of 

actions that DOE has determined to typically require an 

EA, then an EA must be prepared. The purpose of an EA is 

to determine the significance of the environmental effects 

and to look at alternative means to achieve the agency’s 

objectives. The EA also provides sufficient evidence and 

analysis for determining whether or not to prepare an EIS. 

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

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

biomass, and solar energy projects and operations. The EA 

allows for public review and comment, and demonstrates 

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

analysis and interagency reviews conducted during the 

EA process conclude that no significant impacts will occur 

related to the quality of the environment, a Finding of 

No Significant Impact is issued. If the EA indicates significant environmental impacts will occur, an Environmental 

Impact Statement is required.

Environmental Impact Statement (EIS)

An EIS provides a detailed analysis of projects that have 

significant prospective environmental impacts. The 

EIS provides a discussion of significant environmental 

impacts and reasonable alternatives that would avoid 

or minimize adverse impacts or enhance the quality 

of the human and natural environment (including the 

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

made available for public review and comment. As a 

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

the decision, the alternatives considered, including the 

environmentally preferred alternative, and discusses 

mitigation plans, including any enforcement and 

monitoring commitments. It should be noted that NREL, 

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

Program Management

NREL employees initiate the NEPA process and provide 

support to the DOE Golden Field Office in conducting a 

NEPA analysis before a project or activity begins. In accordance with regulations, all NREL activities (both on- and 

off-site) must undergo a NEPA environmental review. The 

outcome of this review is considered the NEPA determination. A final determination must be completed before Honey bees take up temporary residence in a tree outside of the 

Solar Energy Research Facility. Photo by John De La Rosa, NREL 33551
ENVIRONMENTAL PERFORMANCE REPORT 2015 63

federal funds are expended, before a contract award can 

be made, and before project activities begin.

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

environmental review process. These programmatic NEPA 

documents, known as Site-Wide EAs, are comprehensive 

site-wide analyses of potential environmental impacts 

associated with NREL’s current and future actions over a 

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

that aid ongoing and future operational and development 

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

STM site and NWTC provide a baseline environmental 

analysis that streamlines future environmental reviews, 

improves and coordinates site and agency planning, and 

maximizes cost savings. 

If proposed activities have not already been evaluated 

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

conducted. Potential environmental impacts of an activity 

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

or minimize those impacts. The level of review conducted 

is appropriate to the potential impacts of the proposed 

activity. A planned construction project, for example, 

receives a more rigorous review than routine office or 

laboratory work.

2015 Compliance Summary and Activities

■■ Program activities were in compliance with 

requirements.

■■ A total of 614 NEPA reviews were conducted for project 

activities on- and off-site.

■■ A NEPA program assessment (conducted in 2014) 

identified findings related to document control, training, and adherence to internal NEPA processes. A NEPA 

enhancement project plan is in place and progress 

has been made to address the findings, which will be 

completed in 2016. 

1.1MW solar photovoltaic array at the NWTC. Photo by

Dennis Schroeder, NREL 31432
64 ENVIRONMENTAL PERFORMANCE REPORT 2015

10 NATURAL AND 

CULTURAL RESOURCES 

PROTECTION

NREL is committed to responsible stewardship of its 

natural ecosystems, native wildlife, vegetation, and 

important cultural resources. Natural resources at the 

STM site and the NWTC are managed appropriately to 

ensure NREL’s research needs are met while protecting 

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

NREL employees and the surrounding community, and 

demonstrates the laboratory’s leadership in the DOE and 

federal government as a whole. Management focuses on 

these key areas:

■■ Wildlife management

■■ Endangered species and species of concern

■■ Vegetation management

■■ Wetlands and floodplains

■■ Cultural resources.

Western kingbird (Tyrannus verticalis) in a tree outside of 

the Research Support Facility at the STM site. Despite NREL 

biologists’ efforts to discourage nesting during an adjacent 

paving project (note the bird-deterrent tape tied on a tree 

branch), these birds nested and several young successfully 

fledged the nest. Photo by Suzanne Belmont, NREL 35301

Yellow-bellied racer (Coluber constrictor) observed near the STM site 

Maintenance Shed. This common non-venomous, diurnal snake 

is fast moving and very docile. The underbelly color can vary from 

white, to a light tan, to yellow. This individual exhibits the namesake colors. Photo by Tom Ryon, NREL 35302
ENVIRONMENTAL PERFORMANCE REPORT 2015 65

10.1 WILDLIFE MANAGEMENT

The wildlife management program promotes responsible 

wildlife and habitat management, and gathers information to better consider impacts to wildlife when 

implementing projects onsite. 

Many surrounding landowners, including residential 

neighbors and Jefferson County Open Space, value the 

benefits of maintaining wildlife habitat and opportunities 

to observe wildlife. Proper wildlife management at 

NREL therefore provides an important benefit to 

our community.

2015 Accomplishments and Highlights

■■ Acoustic bat monitoring at the NWTC continued. 

In cooperation with biologists from the Rocky Flats 

National Wildlife Refuge, an additional acoustic 

monitoring station was established on the refuge 

within the Rock Creek drainage area. Monitoring 

at the NWTC occurred from April through October, 

and at Rock Creek from June to July. 

■■ Mammalian predator monitoring continued at 

the NWTC. Coyote (Canis latrans) and bobcat 

(Felis rufus) were again observed; no new species 

were documented. 

■■ Nest boxes have been installed in areas around 

the STM site including the mesa slope and the 

stormwater detention basin. This year, tree 

swallows nested in two of the boxes along the 

eastern edge of the detention basin. Along the 

mesa slope, some of the older/weathered boxes 

were replaced and American kestrels and common 

flickers showed interest but did not nest. 

■■ Bee boxes installed in previous years were found 

to have Mason bees; cocoons were found to be 

over-wintering.

■■ A honey bee swarm was found near the southwest 

corner of the Solar Energy Research Facility at the 

STM site. Rather than destroying the swarm, a local 

beekeeper was called to remove the swarm from 

the site. The bees were then used to create a new 

colony at the beekeepers’ apiary. 

■■ A community open-house was held in 

coordination with the DOE Golden Field Office 

during which environmental stewardship at 

NREL was presented. Topics discussed included 

the research related to wildlife impacts from 

renewable energy and efforts to reduce those 

impacts, past STM site and NWTC wildlife and 

cultural resource studies, and how NREL assesses 

environmental impacts of all types. 

■■ Provided information at The Wildlife Society – 

North American Conference about how energy 

efficient building design can also minimize bird 

collisions with windows. 

■■ An avian workshop sponsored by the DOE Golden 

Field Office and led by the U.S. Fish and Wildlife 

Service was held at NREL. The topics covered 

included a thorough review of the Migratory 

Bird Treaty Act and associated case law, related 

regulations, and how these regulations specifically 

apply to DOE sites. NREL provided highlights of 

activities implemented at the STM site and the 

NWTC that comply with these regulations. 

■■ Tularemia, also known as “Rabbit Fever”, was 

on the rise in Jefferson County in 2015. Many 

rabbits were found dead or dying on the STM site, 

especially within the Conservation Easement. It 

is assumed these rabbits had succumbed to the 

disease, which, together with predation, is a part 

of the normal process of population suppression. 

No lasting effects to local populations are realized 

until 90 to 95% of the population dies9

 (ARCC 

1993). Rabbits have a high annual turnover 

rate (typically upwards of 80%), which occurs 

due to weather, disease, parasites, predators, or 

starvation.10 Local rabbit populations have the 

ability to rebound after severe reduction within a 

year or two. 

■■ NREL was alerted by the Colorado Parks and 

Wildlife Division of a buck mule deer that was 

extremely thin and weak near the STM site; it 

was found dead at the site after a week. Testing 

proved the buck was infected with chronic 

wasting disease, which is endemic to northeastern 

Colorado, including Jefferson County.11

9 Australian Rabbit Control Conference, Adelaide, April 1993, pp. 26-34. Editor B.D. Cooke.

10 Yarrow, G. 2009. Cottontail Rabbit Biology and Management. Clemson University Extension Service. http://www.clemson.edu/extension/natural_resources/

wildlife/publications/fs8_cottontail%20rabbit.html.

11 Belay, E.D., R. A. Maddox, E.S. Williams, M.W. Miller, P. Gambetti, and L.B. Schonberger. 2004. Chronic Wasting Disease and Potential Transmission to Humans. 

Emerging Infectious Diseases, Vol 10 (6). June. www.cdc.gov/eid.
66 ENVIRONMENTAL PERFORMANCE REPORT 2015

Requirements

A Colorado statute, several federal laws, and an executive 

order comprise the regulatory framework for NREL’s 

wildlife management program. (Please refer to section 

10.2, Endangered Species and Species of Concern, 

for discussion of other federal laws relating to 

wildlife management.) 

Wildlife is considered a state resource under Colorado 

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

damaged or destroyed unless permitted by the Colorado 

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

to willfully harass wildlife.

The Migratory Bird Treaty Act is the main driver for 

protecting migratory birds in the United States. In the 

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

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

States, except those non-migratory species such as quail 

and turkey that are managed by individual states as game 

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

The Migratory Bird Treaty Act makes it a federal crime to 

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

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

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

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

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

protected migratory bird or to attempt those activities. 

The U.S. Fish and Wildlife Service has developed a system 

of permits for activities that involve the “take” of migratory 

birds, including those governing scientific collection and 

bird banding, and lethal and non-lethal measures taken to 

prevent depredation of agricultural crops and to protect 

public health and safety. 

In 2001, EO 13186, Responsibilities of Federal Agencies 

to Protect Migratory Birds, set requirements for federal 

agencies to minimize their impacts to migratory birds, to 

work cooperatively with the U.S. Fish & Wildlife Service, 

and to establish an interagency migratory bird committee 

for collaboration and information sharing. Additionally, 

the U.S. Fish & Wildlife Service issued guidance identifying goals for federal program activities based upon this 

executive order. This guidance highlighted measures to 

avoid and/or minimize potential impacts to migratory 

birds, eggs, and active nests including but not limited to:

■■ Project modification

■■ Time-of-year restrictions on vegetation clearing

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

active nests

■■ Avoidance of nests of species of concern.

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

environmental analyses of federal activities under NEPA or 

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

birds, particularly on species of concern.

The 2013 Memorandum of Understanding between 

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

regarding the protection of migratory birds. Under the 

Memorandum of Understanding, DOE agrees to integrate 

migratory bird conservation principles, measures, and 

practices into agency activities, and avoid or minimize, to 

the extent practicable, adverse impacts on migratory bird 

resources and their habitats.

Program Management

NREL’s wildlife management program was developed to 

implement measures to allow the laboratory to meet or 

exceed the regulatory requirements discussed above and 

to minimize or avoid impacts to wildlife species and their 

habitats while achieving NREL’s mission. 

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

habitat by avoiding sensitive areas and reclaiming lands 

once disturbance is complete.

A long-term objective is to maintain wildlife movement 

through the STM site by retaining linkages between the 

Northern leopard frog, a Colorado species of concern, in wet 

meadow located at the southwest corner of the NWTC. Proper 

vegetation practices applied to this area, which was formerly infested 

with noxious weeds, along with plentiful spring and summer 

precipitation have contributed to the abundance of frogs at this 

location. Photo by Tom Ryon, NREL 35466
ENVIRONMENTAL PERFORMANCE REPORT 2015 67

open space areas north of the site, and Pleasant View 

Community Park and Lena Gulch to the south. At the 

NWTC, ecologically sensitive areas are preserved within 

the site and linkages with surrounding open space areas 

are maintained. At both sites, periodic monitoring using 

wildlife surveys informs responsible management.

When control of pest wildlife species is necessary, a graded 

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

and administrative controls are the first line of defense 

against pests. When these are not fully effective, additional 

controls are used. Pests are relocated whenever possible. 

When pests must be destroyed, mechanical methods are 

preferred over poisoning. When necessary, pesticides 

are selected that pose the least harmful effects to nontarget wildlife. 

Several activities occur periodically to achieve the 

program’s intent including the following:

Monitoring – The laboratory conducts nesting bird 

surveys prior to any ground- or vegetation-disturbing 

activities conducted between March 15 and September 

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

a proper buffer area until nestlings fledge. Staff conduct 

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

■■ Acoustic bat monitoring at a NWTC location continued in 2015. In cooperation with biologists from the 

Rocky Flats National Wildlife Refuge, an additional 

acoustic monitoring station was established on the 

refuge within the Rock Creek drainage area. Using 

microphones, bat calls are recorded and compared 

to standard calls of a particular species. Monitoring at 

the NWTC occurred from April through November and 

at Rock Creek from June to July. Results for acoustic 

bat monitoring at the NWTC included the presence of 

three species: Little Brown Bat (Myotis lucifugus); Hoary 

Bat (Lasiurus cinereus); and Silver-hair Bat (Lasionycteris noctivagans). At the Rocky Flats National Wildlife 

Refuge, four species of bats were recorded including 

the Little Brown Bat, Hoary Bat, Silver-hair Bat and Big 

Brown Bat (Eptesicus fuscus). All four of these species 

have been recorded at the NWTC in recent years.

Project Reviews – Biologists conduct project reviews to 

assess and reduce potential impacts to wildlife.

Coordination – Biologists coordinate with local, state, 

and federal agencies to improve wildlife management. 

They conduct these activities in concert with surveys for 

threatened and endangered species and habitats. (For 

more details, see section 10.2, Endangered Species and 

Species of Concern.) Because habitat is as much a concern 

as the wildlife species themselves, program activities often 

overlap with vegetation management.

Mule deer (left) and white-tailed deer (right) at the NWTC. Smaller ears and lighter color fur around the eyes and nose distinguish the 

white-tailed deer from the mule deer. Photo by Tom Ryon, NREL 35364

A bobcat walks through the pine ridge at the NWTC and is captured 

on the game camera mounted nearby. Photo by Tom Ryon, 

NREL 35362
68 ENVIRONMENTAL PERFORMANCE REPORT 2015

2015 Compliance Summary and Activities

■■ Visible markers were applied to a total of 6,700 square 

feet of glass windows of the Energy Systems Integration Facility in August of 2014 to reduce the potential 

for bird strikes. Post-retrofit bird surveys consisting 

of 45-researcher-hours over two 10-week periods 

during two fall migration seasons were concluded in 

November 2015, with the results showing that no bird 

strikes occurred on any of the treated windows. Based 

on pre-retrofit surveys conducted from August 2013 

through November 2013 and the post-retrofit surveys, 

the project will likely prevent 15 to 20 bird deaths due 

to window strikes each fall migration season.

■■ Building repair activities were delayed at the Outdoor 

Test Facility until nestlings produced by a pair of flickers had fledged and the adults abandoned the nests, 

to ensure compliance with the Migratory Bird Treaty 

Act. Cavity nesters, such as flickers and woodpeckers, 

commonly build nests in the exterior surfaces of buildings causing significant damage.

■■ Requirements of the Avian Power Line Interaction 

Committee guidelines12 to minimize migratory bird 

hazards were incorporated into project planning and 

design. Incorporation of these guidelines ensures 

compliance with the DOE and U.S. Fish and Wildlife 

Service Memorandum of Understanding Regarding 

Implementation of EO 13186, Responsibilities of Federal 

Agencies to Protect Migratory Birds. This Memorandum 

of Understanding requires that "...whenever appropriate and feasible, DOE sites utilize avian-friendly 

transmission lines and power poles that are designed 

to minimize bird collisions and electrocutions...”. 

10.2 ENDANGERED SPECIES AND 

 SPECIES OF CONCERN

NREL manages research and operational activities to 

preserve and protect environmental quality. The 

laboratory is committed to the protection of imperiled 

species, and monitors for these species at the STM site 

and the NWTC.

Periodically, surveys are conducted for declining wildlife 

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

or declining. Biologists also survey for potential habitat 

for these species. Should potential habitat be found, more 

targeted surveys may be conducted. These surveys 

identify the presence or absence of rare species or their 

habitats and aid in siting and planning new projects. 

While no protected or declining species have been 

detected at an NREL facility, appropriate steps would be 

taken should such a species be found.

Requirements

The federal Endangered Species Act provides for the 

designation and protection of wildlife, fish, and plant 

species that are in danger of extinction, and preserves the 

habitats on which these species depend. Federal agencies 

are required to abide by the Endangered Species Act and 

ensure that their actions do not adversely affect species 

that are federally listed under the Endangered Species Act 

as threatened, endangered, or candidate species.

The U.S. Fish and Wildlife Service, which administers the 

Endangered Species Act, lists nine species as threatened, 

endangered, or a candidate for listing that could potentially occur in Jefferson and Boulder Counties combined. 

Of these species, three have the potential to occur at the 

STM site or the NWTC, including the Preble’s meadow 

jumping mouse, the Ute ladies’ tresses orchid, and the 

Colorado butterfly plant.

Additional federal and state laws and regulations protect 

wildlife, such as the Bald and Golden Eagle Protection 

Act. The Colorado Division of Parks and Wildlife identifies 

a list of endangered, threatened, and wildlife species of 

concern for Colorado. Furthermore, the Colorado Natural 

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

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

rare plants. The list of threatened, endangered, and candidate species, and species of concern (i.e., bald and golden 

eagles, state-listed species, and Colorado Natural Heritage 

Program species) are all considered imperiled species 

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

Endangered, or Species of Concern” species.

Program Management

NREL conducts periodic surveys for the three listed 

species that have the potential to occur at the STM site 

and the NWTC in order to document their presence or 

absence. While the Preble’s meadow jumping mouse does 

not occur on-site, the U.S. Fish and Wildlife Service designated critical Preble’s habitat within the upper reaches of 

Rock Creek, including a small area at the southeast corner 

of the NWTC. This area may not be disturbed without 

coordination with the U.S. Fish and Wildlife Service.

12 Avian Power Line Interaction Committee. Reducing Avian Collisions with Power Lines: The State of the Art in 2012. October 2012.
ENVIRONMENTAL PERFORMANCE REPORT 2015 69

NREL also considers other plant and animal species 

that may be state listed or generally in decline. Current 

information is obtained from both the Colorado Division 

of Parks and Wildlife and the Colorado Natural Heritage 

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

not required by federal regulation, periodic surveys are 

conducted for species that may occur at the STM site and 

the NWTC, typically every five years when baseline vegetation and wildlife studies are conducted. These baseline 

surveys are a vital part of NREL’s National Environmental 

Policy Act program through which impacts to natural 

resources from mission activities are assessed.

The U.S. Fish and Wildlife Service lists five other species 

occurring in the Platte River watershed in Nebraska in 

accordance with the Endangered Species Act as species 

that must be considered for projects in Colorado and 

Wyoming that may deplete water supplies to the Platte 

River system. These include three birds, the Piping 

plover (Charadrius melodus), the Whooping crane (Grus 

americana), and the Least tern (Sternula antillarum); a 

fish, the Pallid sturgeon (Scaphirhynchus albus); and a 

plant, the Western prairie fringed orchid (Platanthera 

praeclara). For any NREL activities that may deplete water 

in the Platte River system, a consultation with the U.S. 

Fish and Wildlife Service must be completed to determine 

potential impacts. 

2015 Compliance Summary and Activities

■■ Program activities were in compliance with 

requirements.

■■ As part of its NEPA evaluation, NREL conducted natural 

resource surveys for a potential research project at 

the NWTC. These surveys included presence/absence 

and habitat surveys for threatened and endangered 

species and Colorado state-listed species. A rare plant 

survey was also conducted for the Ute ladies’ tresses 

orchid and the Colorado butterfly plant. No federally 

protected species or habitats were found and no statelisted species or habitats were found. 

10.3 VEGETATION MANAGEMENT

Native plants have evolved over long periods of time in 

harmony with the local climate and surrounding soil, 

growing in association with microorganisms and resident wildlife to create diverse ecosystems. Through this 

evolution, native plants have developed natural defenses 

against pests and diseases specific to their locale. When 

non-native plants are introduced into an environment, 

they often overcome indigenous plants, attracting new 

types of pests and diseases and out-competing native 

plants for nutrients and water, while also sometimes 

depriving wildlife of nutrients and shelter. Plants such as 

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

Russian olive (Elaeagnus angustifolia), diffuse knapweed 

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

and myrtle spurge (Euphorbia myrsinites) are examples 

of non-native plants that can have destructive effects on 

natural habitats.

Landscaped areas near buildings and common areas at 

the STM site and the NWTC are designed and installed 

with sustainability in mind, and include features such 

as native plantings, xeriscape principles appropriate for 

arid climates, and infiltration of stormwater to provide 

water and nutrients to landscape plants and to recharge 

groundwater in the area. 

Requirements

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

Weed Act, and the Federal Insecticide, Fungicide and 

Rodenticide Act. 

The Federal Insecticide, Fungicide, and Rodenticide Act 

regulates the use, storage, and disposal of herbicides and 

pesticides. For application of certain types of herbicides 

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

2015 Accomplishments and Highlights 

■■ Monthly review and coordination meetings 

were conducted to assess the success 

of seasonal herbicide applications and 

revegetation efforts.

■■ Herbicide was applied in an area at the 

STM site where reseeding occurred in 2014 

following land disturbance from a utilities 

infrastructure upgrade project. Removal of 

weedy species results in less competition for 

nutrients and water that are needed by the 

native grasses in order for them to succeed. 

■■ Annual herbicide spraying was performed 

to continue the control knapweed at the 

NWTC, and Canada thistle, houndstongue 

(Cynoglossum officinale) and myrtle spurge 

at the STM site.
70 ENVIRONMENTAL PERFORMANCE REPORT 2015

certified applicator license must be used. Application of 

restricted-use herbicides is conducted in accordance with 

the regulation. NREL currently uses contractors for this 

type of application.

At the STM site, vegetation management of 177 acres is 

under a conservation easement agreement with Jefferson 

County, which requires that the unique landscapes within 

the easement are left undisturbed. (For more details, see 

section 11, Conservation Easement Lands.) 

NREL voluntarily complies with the Colorado Noxious 

Weed Act. 

Program Management

The focus of NREL’s vegetation management program 

is to:

■■ Conserve existing ecosystems in their natural state as 

much as possible 

■■ Strive to replace disturbed vegetation with native 

species, or with adapted but non-invasive species 

when necessary

■■ Implement a program of weed management to 

prevent the spread of noxious weeds and implement 

measures to control these species

■■ Implement a sustainable landscape design and maintenance program.

Approximately 60 acres (24 hectares) of land within the 

NWTC boundaries are managed as conservation areas. As 

within the STM site's 177-acre (71 hectares) conservation 

easement, the laboratory limits development in these 

areas at the NWTC and manages them to conserve 

specific features including seeps, ephemeral drainages, 

ponds, native grassland habitat, areas supporting ancient 

soils (a soil structure in association with plant species 

forming a stable ecological community that is resistant 

to weed invasion), a small area designated as critical 

habitat for the Preble’s meadow jumping mouse, an area 

of remnant tallgrass prairie, and a rocky outcropping 

supporting ponderosa pine and shrublands. 

To maintain the existing native vegetation and to ensure 

the success of revegetated areas, the laboratory has 

developed sustainable landscape management 

practices that:

■■ Provide supplemental water during seedling growth 

and establishment, and minimize water use thereafter

■■ Reduce the need for and use of pesticides and 

fertilizers

■■ Reduce maintenance costs

■■ Maximize ground cover to reduce soil erosion

■■ Establish a variety of habitats to support diverse 

wildlife

■■ Create an aesthetically pleasing landscape 

environment.

Where removal of native vegetation cannot be avoided, 

reseeding is done using grass and forb seed mixes native 

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

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

STM site and the NWTC to enhance ecosystem diversity 

and integrity. NREL staff continually evaluate and modify 

revegetation techniques as needed to promote healthy 

plant establishment.

NREL participated in the Sustainable Sites Initiative 

two-year pilot program (2010-2012) established by the 

American Society of Landscape Architects, the 

Lady Bird Johnson Wildflower Center at the University of 

Texas at Austin, the United States Botanic Garden, and a 

diverse group of other stakeholders. The purpose of the 

pilot program was to develop the first national rating 

system for sustainable landscapes. Certification under 

the program demonstrates that the stewardship activities 

necessary for regeneration of the natural benefits 

and services for sustaining healthy ecosystems are 

being implemented.

NREL developed and submitted a plan for implementing 

sustainable landscape practices and received a rating of 

three out of four stars. The plan is now integrated into 

NREL’s landscape maintenance plan and other site-wide 

procedures. Integrated components of the plan include 

Common mullein, sometimes referred to as wooly mullein, is a 

noxious weed. The first sign of this weed is a rosette (pictured) 

that grows during its first year. In the second year, a stalk will grow 

from the center of the rosette to produce many yellow flowers. By 

the second year, control of this plant is generally not possible, so 

identification and control of the first year stage is important for this 

weed. Photo by Tom Ryon, NREL 36263
ENVIRONMENTAL PERFORMANCE REPORT 2015 71

plant stewardship, invasive species management, 

organic materials management, soil stewardship, 

irrigation and water use, stormwater management, 

materials management, snow and ice management, and 

monitoring. The Sustainable Sites Initiative program is 

also a critical foundation that supports NREL’s objective in 

creating adaptive and resilient sites to meet the challenge 

of dynamic climate changes.

NREL uses an integrated weed management approach 

that incorporates various types of weed control methods 

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

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

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

off established roadways), and herbicide treatment. The 

effectiveness of control methods is periodically assessed. 

The use of multiple strategies for control has been 

successful in significantly reducing populations of 

diffuse knapweed (Centaurea diffusa) and Canada thistle 

(Cirsium arvense). The weed control program maintains 

the flexibility needed to respond to changes in weed 

populations from year to year. Periodic mapping of weed 

infestation areas assists in targeting weed control efforts.

The laboratory continues to address the control of 

these species using the integrated weed management 

approach described above. Comprehensive site-wide 

weed surveys and mapping are performed approximately every five years; smaller areas are assessed annually. 

A list of noxious weed species identified at the STM site 

and the NWTC is found in Table 7.

For information on rare and imperiled plant species, see 

section 10.2, Endangered Species and Species 

of Concern.

2015 Compliance Summary and Activities

■■ Program activities were in compliance with 

requirements.

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

C-listed weeds to approximately 135 acres (55 hectares) in April and May, 41 acres (17 hectares) in July, 

and 21 acres (8 hectares) in October. 

■■ At the STM site, herbicides were applied to control 

A-, B- and C-listed weeds to approximately 15 acres 

(6 hectares) in May and June, 6 acres (2 hectares) in 

August, and 13 acres (5 hectares) in October. Across the 

STM site and within the STM Conservation Easement 

15 Russian olive trees were girdled and treated with 

herbicide in September to kill the trees and prevent 

the spread of this invasive species.

■■ Two locations, one on the STM site and the other on 

the NWTC, were selected to introduce a rust fungus 

(Puccinia punctiformis) to combat Canada thistle. The 

locations are seep areas where Canada thistle is known 

to occur. Introduction of this biological control agent, 

done in cooperation with the Colorado Department 

of Agriculture, provides an integrated approach to 

combatting noxious weeds. The Colorado Department of Agriculture will monitor the rust fungus in 

Dalmation toadflax, a native of western Asia and southeastern 

Europe, is an invasive weed in North America and has been 

identified at NREL. Photo by Tom Ryon, NREL 36362

TABLE 7. NOXIOUS WEED SPECIES IDENTIFIED 

AT THE STM SITE AND THE NWTC

Noxious Weed 

Class

Species Present at 

STM Site

Species Present at 

NWTC

Class A Myrtle spurge None

Class B

Canada thistle

Common teasel

Dalmation toadflax

Diffuse knapweed

Hoary cress 

(whitetop) 

Hound’s tongue

Musk thistle

Russian olive 

Scotch thistle

Canada thistle

Chicory

Dalmation toadflax

Diffuse knapweed

Hoary cress 

(whitetop)

Musk thistle

Class C 

Field bindweed

Cheatgrass 

Field bindweed

Cheatgrass
72 ENVIRONMENTAL PERFORMANCE REPORT 2015

subsequent years to document its establishment and 

effectiveness.

■■ Knapweed weevils were introduced along the Pine 

Ridge at the NWTC in August. Two species were 

released; one that attacks the seed heads and another 

that attacks the roots of knapweed. This effort further 

diversifies noxious weed control methods.

10.4 WETLANDS AND FLOODPLAINS 

Floodplains are land areas adjacent to rivers and streams 

that are subject to recurring inundation. Wetlands are 

lands that are inundated or saturated by surface or 

groundwater at a frequency and duration sufficient 

to support distinct soil types and plant communities. 

Wetland areas typically take the form of swamps, marshes, 

bogs, and groundwater seeps and are frequently located 

within or adjacent to a floodplain.

Both wetlands and floodplains play a key role in providing 

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

promote the growth of wetland and riparian vegetation 

that provide habitat for a rich diversity of terrestrial and 

aquatic plants and animals. NREL preserves the important 

natural functions of its wetlands and floodplains, thereby 

protecting the physical, biological, and chemical integrity 

of receiving waters and riparian areas on and adjacent to 

the STM site and NWTC.

Requirements

■■ Wetlands became regulated in 1972 when, under the 

Clean Water Act, the definition of waters of the United 

States was expanded to include tributaries to navigable waters, interstate wetlands, wetlands that could 

affect interstate or foreign commerce, and wetlands 

adjacent to other waters of the United States. Wetlands 

that fit within the definition and that meet certain 

soils, vegetation, and hydrologic criteria are federally protected under programs administered by the 

U.S. Army Corps of Engineers, with program oversight 

provided by the EPA. These regulated wetlands are 

known as jurisdictional wetlands. Areas that do not 

meet the criteria above are not protected or regulated 

but still perform wetland functions and act as valuable 

ecologic components. 

■■ Wetland areas identified at the STM site and NWTC 

are managed as a valuable natural resource and in a 

manner consistent with the Clean Water Act as well 

as EO 11990, Protection of Wetlands, which requires 

that federal agencies minimize the destruction, loss, 

Seasonal Pond in June, 2015. Open water supports amphibians, 

insects, and waterbirds. Photo by Don Young, NREL 35300

Seasonal Pond in August, 2015. Wetland plants have emerged along 

the edges of the receding water. Photo by Don Young, NREL 35299

2015 Accomplishments and Highlights 

According to the National Weather Service 

Forecast Office for the Denver-Boulder Area, the 

highest precipitation within the last 15 years 

occurred in 2014 and 2015. With this abundance 

of precipitation in two consecutive years, wetland 

vegetation has been in full expression. Lowlying areas that normally do not exhibit wetland 

vegetation have supported cattails and rushes or 

have held standing water. These wetland areas 

contain flood waters, reduce erosion, and support 

many forms of native wildlife. As an illustration of 

dramatic change over just a few months, below 

are photos of a seasonal pond at the NWTC. Most 

years, the pond is dry except for a few weeks after 

snow runoff season (April to May, annually). In 

2015, this seasonal pond was filled for the entire 

growing season and supported wetland and 

aquatic plant communities that sprouted forth 

from the soil seed bank. 
ENVIRONMENTAL PERFORMANCE REPORT 2015 73

or degradation of wetlands; follow DOE policy to carry 

out the requirements of EO 11990; and preserve and 

enhance the natural and beneficial values of wetlands 

in carrying out the agency's responsibilities.

Counties regulate floodplains by mapping the 100-year 

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

and then develop regulations that control the type and 

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

per the requirements identified in EO 11988, Floodplain 

Management. This executive order requires federal agencies to minimize the impact of floods on human safety, 

health, and welfare, and restore and preserve the natural 

and beneficial values served by floodplains. 

The STM site and NWTC do not contain any regulatory 

100-year floodplains.

Program Management

NREL protects its wetlands and floodplains through 

several means:

■■ Periodic vegetation surveys and wetland delineations

■■ Mapping of wetland areas potentially affected by 

proposed construction

■■ Identification of potential impacts

■■ Coordination with other jurisdictions on the control of 

floodwaters leaving NREL’s STM site and NWTC.

The U.S. Army Corps of Engineers has examined the 

STM site drainages and determined that they do not fit 

wetland criteria and are therefore not currently regulated. The U.S. Army Corp of Engineers has not evaluated 

the NWTC drainages to date. The new Clean Water Rule, 

promulgated in May 2015, would more precisely define 

implementation of the Clean Water Act and what constitutes a wetland, which could change which drainages at 

NREL are regulated. Currently, however, the Clean Water 

Rule is being contested within the court system, and 

prior regulations remain in effect nationwide. Functional 

wetlands, whether regulated or not, are considered valuable features, and the laboratory seeks to preserve these. 

Table 8 presents the types and acreage of wetlands at 

the STM site and NWTC that have been identified to date. 

Please refer to Appendix A for locations of these wetlands.

2015 Compliance Summary and Activities

■■ Program activities were in compliance with regulations.

■■ No NREL projects or activities that could impact 

wetlands or floodplains occurred.

10.5 CULTURAL RESOURCES

Cultural resources are defined as any prehistoric or 

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

scientific, traditional, religious, or other reasons.

Cultural resources can be divided into three major 

categories:

■■ Prehistoric and historic archaeological resources

■■ Architectural resources

■■ Traditional cultural resources.

Prehistoric and historic archaeological resources are locations where human activity measurably altered the earth 

or left deposits of physical remains, such as arrowheads, 

pottery, and tools. Prehistoric resources that predate the 

advent of written records in a region range from a scatter 

composed of a few artifacts to village sites and rock art. 

Historic resources may include campsites, roads, fences, 

trails, dumps, battlegrounds, mines, and a variety of 

other features.

Architectural resources include standing buildings, 

dams, canals, bridges, and other structures of historic or 

TABLE 8. WETLAND TYPES AND ACREAGES AT 

THE STM SITE AND THE NWTC

Wetland Type STM Site

Acres (hectares)

NWTC

Acres (hectares)

Groundwater Seep 0.2

(0.08)

C0.2*

(0.08)

Headwater Wetland 0

(0) 

1.7*

(0.68)

Palustrine Emergent 1.2

(0.48)

0.8

(0.32)

Seasonal Pond 0.6

(0.24)

0.4*

(0.16)

Wet Meadow 0.3

(0.12)

4.9

(1.9)

Total 2.3

(0.93)

8.0

(3.2)

* Wetlands that have been surveyed and meet all federal 

wetland criteria. Other wetlands listed were identified by 

vegetation type only. 
74 ENVIRONMENTAL PERFORMANCE REPORT 2015

aesthetic significance. Architectural resources generally must be more than 50 years old to be considered for 

protection under existing cultural resource laws. However, 

more recent structures, such as Cold War facilities, may 

warrant protection if they manifest the potential to gain 

significance in the future.

A traditional cultural resource can be defined as a property that is eligible for inclusion in the National Register 

of Historic Places because of its association with cultural 

practices or beliefs of a living community that are rooted 

in the community’s history, and its importance in maintaining the continuing cultural identity of the community. 

Traditional resources may include archaeological resources, buildings, neighborhoods, prominent topographic 

features, habitats, plants, animals, and traditional culture.

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

variety of human uses. In 1903, the Colorado National 

Guard established the State Rifle Range at a location 3 

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

veteran and Golden business man, George West, became 

an integral part of Colorado National Guard activities 

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

camp totaled 750 acres (303 hectares) and many buildings 

were added throughout the 1930s and 1940s. 

During World War II, much of Camp George West was 

leased to the federal government for military training 

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

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

Enforcement Training Academy, and the Colorado Correctional Center. In 1977, the Solar Energy Research Institute 

(SERI) began operations, and in 1981, more than 300 acres 

(121 hectares) were transferred to the federal government 

for solar energy research purposes, which would become 

SERI’s South Table Mountain site. SERI was elevated to 

national laboratory status in 1991 and became NREL. 

An additional 25 acres (10.1 hectares) were transferred 

to DOE in 2003. Today, the STM site totals 327 acres 

(132 hectares).

SERI began the testing of small wind turbines at a 

305-acre site 13 miles north of Golden on a northern 

portion of the previous Rocky Flats Plant. The testing area 

became a national center in 1994 and was designated the 

National Wind Technology Center. Because research activities did not begin until the late 1970s, all current NWTC 

structures and buildings have been constructed since 

then. Consequently, none of the current structures or 

buildings has reached the 50-year threshold required for 

listing consideration by the National Register of Historic 

Places, nor have they been determined to be of exceptional importance for earlier consideration.

Requirements

Cultural resources are protected under the National 

Historic Preservation Act of 1966 and the Archaeological 

and Historic Preservation Act of 1974. Federal agencies 

must establish preservation programs commensurate 

with their mission and the effects of their activities on 

historic properties. DOE is charged to uphold these laws 

by preserving, protecting, and perpetuating cultural 

resources for future generations in a spirit of stewardship to the extent feasible given the agency’s mission 

and mandates. To do this, DOE implements management 

accountability for compliance with federal statutes, executive orders, treaties, DOE orders, and implementation 

guidance. The department also ensures that DOE contractors are obligated to implement DOE programs and 

projects in a manner that is consistent with these requirements. Significant cultural resources are either eligible for, 

or listed in, the National Register of Historic Places.

Program Management

Cultural resources are protected at NREL in several ways:

■■ Integrating cultural resource management into site 

activities and minimizing and/or mitigating impacts to 

historic properties and features

■■ Implementing procedures to manage historic features 

and to protect undiscovered cultural resources 

and artifacts

■■ Periodically conducting surveys to document presence 

or absence of cultural or historic resources and, when 

surveys reveal artifacts, working with the Colorado 

Office of Archaeology and Historic Preservation to 

determine if the artifacts are eligible for consideration 

as architectural, historic or cultural resources

■■ Requiring construction contractors to provide workers 

with site orientation training that includes guidance 

2015 Accomplishments and Highlights 

A cultural resource survey was completed for a 

proposed project that would support research 

conducted at the NWTC. Although the survey 

found two previously documented historic properties nearby, the proposed project would not 

have an adverse effect on these properties. 
ENVIRONMENTAL PERFORMANCE REPORT 2015 75

on what to do in the event they discover any evidence 

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

qualified archaeologist evaluates the significance of 

the find.

Several formal surveys of historic and cultural resources 

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

three historical sites were recognized as significant 

cultural resources that should be preserved. These 

resources include:

■■ An open-air amphitheater

■■ A stone bridge spanning a natural drainage channel 

adjacent to the amphitheater

■■ A stone and concrete ammunition bunker below 

the amphitheater.

The three structures were constructed in the 1930s and 

early 1940s during the Works Progress Administration era. 

Through NREL’s efforts, these structures have been added 

to the National Register, with the amphitheater and stone 

footbridge listed together as a single resource. Additionally, a portion of the STM site south of Denver West Parkway 

lies within the 98-acre Camp George West Historic District. 

An archeological survey of the NWTC was conducted 

in support of the 1996 environmental assessment to 

supplement previous surveys so that no gaps in cultural 

surveys occurred. No significant historical or archeological 

resources were identified.

2015 Compliance Summary and Activities

■■ Program activities were in compliance with 

requirements.

■■ DOE initiated a consultation with the Colorado State 

Historic Preservation Office under Section 106 of the 

National Historic Preservation Act of 1966 for the 

Central Array Test Site installation and operation at 

the STM site. As part of the process, DOE provided a 

letter to the Colorado State Historic Preservation Office 

indicating that no historic properties would 

be directly or indirectly affected by the project. The 

State Historic Preservation Office concurred with 

DOE’s determination.

The 157th Infantry passing in review during Governor’s Day at Camp 

George West, June 16, 1934. The training grounds encompassed all 

of the South Table Mountain site as well as acreage to the south in 

the Pleasant View community. Photo from the Denver Public Library
76 ENVIRONMENTAL PERFORMANCE REPORT 2015

In 1999, DOE granted a conservation easement for 177 

acres (72 hectares) of the STM site to Jefferson County. 

The purpose of the easement is to preserve the natural 

character of the property, including its visual, biological, 

and recreational resources.

The goals of the easement are to:

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

ecological, and historical aspects of the conservation 

easement property

■■ Protect the ecosystem and sustainable habitat for 

diverse vegetation and wildlife

■■ Ensure the scenic and biological integration with 

adjoining open-space land

■■ Prevent further industrial, commercial, or residential 

development of the conservation easement property

■■ Preserve the conservation easement property as 

natural open space.

Local policies established by Jefferson County, Golden, 

and Lakewood reflect community sensitivity with respect 

to the visual qualities provided by natural resources in 

the area around the STM site. Specifically, the Jefferson 

County General Land Use Plan characterizes North and 

South Table Mountains as “unique landscapes,” and 

states that “maintaining landscapes that have a unique 

visual quality” is key to maintaining the quality of life in 

Jefferson County.

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.13 The baseline inventory includes 

a description of the geographical setting and adjacent 

11 CONSERVATION

EASEMENT LANDS

Spring flowers in the STM Site Conservation Easement. 

Photo by Kurt Schlomberg, NREL 33337

13 U.S. Department of Energy, Golden Field Office (1999). National Renewable 

Energy Laboratory (NREL) Site Conservation Easement Baseline Inventory. 

Golden, Colorado.
ENVIRONMENTAL PERFORMANCE REPORT 2015 77

Figure 5. Conservation Easement at the STM Site.
78 ENVIRONMENTAL PERFORMANCE REPORT 2015

property owners, access and use of the property by the 

public, and a description of the existing environmental 

conditions of the property (including geology, hydrology, 

vegetation, wildlife, and cultural resources). Vegetation 

within the easement area includes grasslands interspersed 

with shrubland communities, primarily in the drainages. 

Several seeps also occur throughout the area. Each year, at 

least one visual inspection of the conservation easement 

property is conducted to identify management activities 

needed to address erosion, weed management, trail conditions, or other issues that may exist.

Jefferson County Open Space maintains formal trails on 

the conservation easement property. Two trails cross the 

easement, connecting Denver West Parkway (near the STM 

site east entrance) to the trails on the mesa top. NREL staff 

and the public use these trails frequently.

2015 Compliance Summary and Activities

■■ NREL conducted a visual inspection of the conservation 

easement. Potential improvements to the management 

of the easement were noted, including addressing 

social trails, erosion, and weed control. Following the 

inspection, 15 Russian olive trees were girdled to kill the 

trees and prevent the spread of this invasive species. 

NREL coordinated with Jefferson County citizens and 

Jefferson County Open Space to address erosion, 

drainage, and access at the south end of the trail 

located along the eastern boundary of the STM site.

■■ Jefferson County Open Space conducted the annual 

assessment of the conservation easement. The 

resulting Conservation Easement Monitoring Report14

highlighted the significant natural features of the 

parcel, including wildlife habitat and unique landforms, 

as well as the passive recreational amenities provided 

by the public trails that cross the area. No significant 

changes to the land use and condition were observed 

from baseline observations. 

14 Jefferson County Open Space. Conservation Easement Monitoring Report. August 18, 2015.
ENVIRONMENTAL PERFORMANCE REPORT 2015 79

The STM site is the destination of hundreds of commuter 

vehicles daily, as well as visitor and delivery traffic entering and leaving the site. Traffic management for the site 

is important for minimizing negative impacts to traffic 

flow on Denver West Parkway and in nearby neighborhoods and business areas. Reducing traffic also reduces 

noise and light pollution, vehicle emissions, fuel use, 

parking requirements, and road maintenance costs. 

Requirements

In 2008, as part of a National Environmental Policy Act 

assessment for the construction of additional buildings 

on the STM site and the moving of additional employees 

to the STM site from off-site leased locations, a traffic 

Mitigation Action Plan was prepared. This plan established periodic monitoring at nearby intersections affected by NREL traffic, the development of traffic thresholds 

at those intersections, and actions to be taken to reduce 

the traffic generated by NREL employees. 

In February 2015, with the completion and full occupancy of the Research Support Facility and Energy Systems 

12TRAFFIC

MANAGEMENT

The RTD’s new West Light Rail line has increased public 

transportation ridership from NREL staff living in Denver and 

the western suburbs. Photo by Dennis Schroeder, NREL 25931

2015 Accomplishments and Highlights

■■ Implementation of the traffic Mitigation 

Action Plan for the STM site was completed.

■■ Traffic monitoring in 2015 indicated that 

NREL-generated traffic volumes at intersections near the STM site remained within 

acceptable levels.

■■ NREL implemented a new shuttle route to 

improve last-mile connections between 

NREL and a nearby light rail station 

(Oak Street) in Lakewood, increasing shuttle 

and transit ridership. 
80 ENVIRONMENTAL PERFORMANCE REPORT 2015

Integration Facility, and with offsite traffic impacts maintained below threshold levels as identified in the Mitigation Action Plan, DOE issued the Mitigation Action Plan 

Completion Report.

15

The report signifies the completion of the traffic Mitigation Action Plan but notes that DOE and NREL will continue to conduct informal traffic monitoring and continue 

implementation of traffic control measures (such as the 

Regional Transportation District’s transit passes, shuttle 

services, and telecommuting) as part of standard operations and sustainability initiatives. 

Program Management

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

the surrounding community and to reduce petroleum 

fuel use and greenhouse gas emissions by promoting 

alternative modes of transportation. Program activities 

include encouraging and supporting alternative modes of 

commuting, flexible workplace practices, telecommuting, 

teleconferencing, and periodic traffic monitoring. These 

activities are described below. 

Alternative Modes of Commuting

■■ EcoPasses provided to employees encourage use of 

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

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

■■ Shuttle routes provide connections between NREL 

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

■■ Incentive parking is provided for vanpools and 

carpools at the STM site and at the Denver West 

Office Park.

■■ Vanpool incentives are available for participants who 

commute in formal organized vanpools.

■■ Bike racks, bike lockers, and bicycle maintenance 

stations are in key locations on the STM site. Bike 

racks on shuttle vehicles permit staff members to take 

their bikes with them when they commute or move 

between buildings.

■■ RideShare Connections, an intranet site, allows staff 

to post and search listings for potential carpool and 

vanpool partners within NREL. 

■■ Literature kiosks in key building locations provide 

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

■■ Information-sharing events promote safe bicycling, 

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

Flexible Workplace Practices

Conferencing by video, telephone, and the internet as 

well as alternating work schedules provide flexibility in 

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

An alternating work schedule policy allows employees to 

work varying schedules, with management approval, 

and reduces the miles driven by employees to and from 

the laboratory.

Telecommuting

NREL’s telecommuting policy allows employees, with 

management approval, to work from home at an agreedupon frequency based on job duties, reducing the days 

they commute to the laboratory.

Laboratory-wide employee surveys have confirmed that 

adoption of this program has been very strong.

Teleconferencing

The laboratory promotes and encourages the use of 

teleconferencing and videoconferencing for meetings to 

decrease local vehicle trips and air travel.

2015 Compliance Summary and Activities

■■ Active transportation demand management activities 

were continued.

■■ The average afternoon (4:30–5:30 p.m.) peak-hour 

traffic volume measured at the intersection of Denver 

West Parkway and Denver West Marriott Boulevard was 

277 vehicle trips per hour. This traffic volume remained 

below the threshold established as part of the traffic 

Mitigation Action Plan (522 vehicle trips per hour) 

intended to ensure acceptable traffic volumes at 

the intersection. 

An employee badges in at the STM site east entrance. Hundreds of 

NREL staff opted out of their cars, cycling to work instead to take part 

in Bike To Work Day. Photo by Dennis Schroeder, NREL 34020

15 Mitigation Action Plan Completion Report: The Supplement to Final Site-Wide Environmental Assessment for the National Renewable Energy Laboratory’s 

South Table Mountain Complex (prepared to accompany the Final Supplement to the Site-Wide Environmental Assessment of the National Renewable 

Energy Laboratory's South Table Mountain Complex, May 2008 [DOE/EA-1440-S-I]).
ENVIRONMENTAL PERFORMANCE REPORT 2015 81

Detailed Traffic Metrics and Results

Previous traffic studies indicated that the greatest impact 

to traffic in the local area from the STM site occurs 

between 4:30 p.m. and 5:30 p.m. This hour has been 

designated the PM peak hour. 

PM peak-hour video traffic counts were conducted in 

2015 over three one- week periods during April, August, 

and December at the STM site east, west, and south 

entrances, to evaluate the impact of traffic at the intersections of Denver West Parkway and Denver West Marriott 

Boulevard, Quaker Street and South Golden Road, and 

South Golden Road and Research Road. Table 9 shows the 

traffic count results at these three locations. 

Traffic counts were evaluated at the east and west 

entrances. At the east entrance, traffic counts were 

compared against the threshold, which identifies the 

acceptable number of vehicle trips NREL can contribute 

to the intersection of Denver West Parkway and Denver 

West Marriott Boulevard without causing significant 

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

peak hour (from 4:30 to 5:30 p.m.). In 2015, the PM-peakhour traffic volume averaged 277 vehicle trips, thus 

remaining below the NREL-established threshold. At the 

west entrance, NREL has identified a traffic threshold of 36 

vehicle trips in the PM peak hour. In 2015, the PM-peakhour traffic volume average remained below the threshold at 11 vehicle trips. 

As the south entrance was not constructed at the time 

of the original traffic analysis conducted for the traffic 

Mitigation Action Plan, the 2015 average PM-peak-hour 

traffic volume of 235 vehicle trips cannot be compared to 

a vehicle trip threshold number.

TABLE 9. 2015 TRAFFIC COUNTS AND COMPARISON WITH THRESHOLD VALUES

Gate 

(Affected Intersection)

PM Peak-Hour Vehicles 

 (in- and out-bound)

Apr-15 Aug-15 Dec-15 Average MAP

Threshold

East Entrance (Denver West Parkway/Denver West Marriott Blvd.) 292 235 304 277 387

West Entrance (Quaker Street/South Golden Road) 11 10 13 11 36

South Entrance (South Golden Road/Research Road) 273 144 290 235 N/A

A new shuttle route connects the STM site to the Oak Street Station on RTD's West Light Rail Line during morning and evening commuting 

hours. Photo by Suzanne Belmont, NREL 35142
82 ENVIRONMENTAL PERFORMANCE REPORT 2015

APPENDIX A:

PLANT COMMUNITIES AT 

THE STM SITE AND THE NWTC

Vegetation surveys are periodically completed for the 

STM site and the NWTC, with the most recent survey 

occurring in 2011. Plant communities and species were 

identified for each site at that time, and changes from 

similar surveys completed in 2000 are noted below.

STM Site Plant Communities

The majority of vegetation at the STM site belongs to the 

grassland community type. Within that association, there 

are two distinct community types: short grassland on the 

mesa top and mixed grassland located on the slopes and 

toe area. Other mapped vegetation communities at the 

STM site include ravine shrubland, tall shrubland, short 

shrubland, and wetlands. The plant communities are 

described below and mapped as illustrated. 

Short Grassland

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

dominant grass species are blue grama (Chondrosum 

gracile), a native prairie species, and cheatgrass (Anisan-

tha tectorum), a noxious weed. Populations of diffuse 

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

comprise approximately 1% of the short grassland.

Alyssum (Alyssum parviflorum), an introduced species, is 

the dominant forb. Several species of prickly pear cactus (Opuntia fragilis, O. macrorhiza, O. phaeacantha, and O. 

polyacantha) occur throughout the short grassland on 

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

viridiflorus) and pincushion cacti (Coryphantha missou-

riensis and C. vivipara var. vivpara). Well-draining hillocks 

often support thick stands of needle-and-thread grass (Hesperostipa comata) and yucca (Yucca glauca). Some 

short shrubs such as rubber rabbitbrush (Chrysotham-

nus nauseosus subsp.), chokecherry (Padus virginiana), 

and skunkbrush (Rhus aromatica subsp. trilobata) occur 

infrequently in the short grassland area and concentrate 
ENVIRONMENTAL PERFORMANCE REPORT 2015 83

Figure 6. STM Site land cover types surveyed in 2011. Note: map was updated in 2012 to reflect building changes.
84 ENVIRONMENTAL PERFORMANCE REPORT 2015

along the rimrock areas. Several large hackberry trees 

(Celtis reticulata) are clustered at the very edge of the 

mesa top.

Historically, this short grassland was probably dominated 

by blue grama grass and other short-grass species such 

as buffalo grass (Buchloë dactyloides), intermixed with the 

other species associations described above. However, the 

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

the appearance and general species composition of the 

area by apparently out-competing native plants.

Mixed Grassland

The mesa slopes and toe areas on the STM site also 

support blue grama and cheatgrass, but are dominated by 

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

grass and western wheatgrass (Pascopyrum smithii), with 

smaller amounts of big bluestem (Andropogon gerardii), 

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

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

also occur in the mixed grasslands.

A few patches of anomalous vegetation occur within the 

mixed grasslands where subsurface water appears to be 

close to the surface. These areas support wide swaths of 

mat muhly (Muhlenbergia richardsonis). One is located on 

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

of the ravine north of the NREL Education Center, formerly 

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

large population of poison ivy (Toxicodendron rydbergii), 

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

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

number of plains cottonwood (Populus deltoides) saplings, 

skunkbrush, chokecherry, and snowberry occurs in this 

patch as well.

The mixed-grass areas grade into both the upland and 

ravine shrublands and contribute the majority of the 

understory in these areas. Some mixed-grass areas also 

blend into disturbed areas, where reclamation species 

such as crested wheatgrass (Agropyron cristatum) and 

smooth brome have been planted and have subsequently 

spread into the mixed-grass community.

Upland Shrublands

Shrubland habitat occurs along the upper sides of ravines 

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

upland shrubland habitat, which excludes the shrublands 

in the ravine bottoms, comprises tall shrubland and short 

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

Tall Shrubland

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

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

exposed, and on the upper mesa slopes below rimrock 

areas. The understory is notably sparse throughout this 

community, with a large amount of bare soil. Cheatgrass 

is the most common herbaceous species in these areas, 

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

many cacti.

Short Shrubland

The short shrublands occur on elevated flat areas amidst 

the surrounding grasslands, some of which appear to 

have experienced surficial disturbance in the past. These 

areas are distinctive because of the dominance of rubber 

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

defines these and other short shrublands along the 

upper portions of the steepest slopes of the mesa. These 

communities usually grade into the ravine shrublands 

along the drainage bottoms and the tall shrublands near 

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

forbs as the tall-shrub community.

Ravine Shrublands

Ravine shrublands are limited to the lower sides and 

bottoms of the drainages that cut down through the mesa 

slopes. These communities support a variety of shrubs 

such as skunkbrush, chokecherry, and wild plum (Prunus 

americana), often growing in dense, impassible thickets. A 

few plains cottonwoods and peachleaf willow (Salix amygdaloides) trees occur at the top of the ravine channels and 

in other portions of the channel where the subsurface 

water table appears to be relatively high. A diverse herbaceous component is found in these drainages. In one 

instance near the southeast boundary, a ravine shrubland 

grades into an ephemeral drainage at the toe of the mesa. 

This drainage is vegetated with grassland species and 

conducts only occasional surface water runoff.

Wetlands

Five very small communities on the STM site were found 

to support wetland vegetation. These communities were 

not examined for the soils and hydrology that would classify them as functioning wetlands; rather, they are noted 

only for their dominance of wetland vegetation. These 

are limited to very small areas (less than half an acre in 
ENVIRONMENTAL PERFORMANCE REPORT 2015 85

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

at the southwestern corner of the site boundary where 

surface water and/or subsurface drainage have created 

a pocket of saturated soil. Species here include sedges 

(Carex spp.), rushes (Juncus spp.), bulrush (Schoenoplectus 

spp.), and peachleaf willow. The second wetland could 

have formed as a result of past construction activities. This 

linear depression supports wetland vegetation along the 

central portion of the western site boundary, northeast of 

the photovoltaic array. Perhaps situated where equipment 

was once staged, this area appears to hold seasonal water 

for enough consecutive growing seasons to support some 

wetland vegetation including Arctic rush (Juncus arcticus), 

American speedwell (Veronica americana), and broadleaf 

cattail (Typha latifolia).

The wetland at the mouth of the ravine may no longer 

experience the hydrology that originally allowed these 

plants to establish there. In 2002, this plant community 

supported populations of cattails that were not observed 

in the 2011 survey.

Three small seeps are located on the hill slope between 

the NREL Education Center and the public trail on the far 

eastern boundary of the site. These seeps are dominated 

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

A seventh wetland community that was observed by 

Plantae16 no longer appears to support wetland vegetation. In 2002, cattail species near an old stock tank in the 

eastern-most drainage appeared to have been supported 

by a pipe coming out of the hillside. Although the stock 

tank was observed in the 2011 survey, it appears the 

cattails have not persisted in the intervening years.

Disturbed/Reclaimed

This habitat type comprises all of the areas at the site 

that have experienced surface disturbance to vegetation 

caused by human activities. These mostly occur on the 

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

dumping areas. Most of these areas appear to have been 

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

and native and introduced weeds.

NWTC Plant Communities

The majority of the vegetation at the NWTC belongs 

to the mixed-grass prairie association of the grassland 

formation. Mixed-grass prairie is defined by the presence 

of grass species typical of the tallgrass or true prairie 

such as big bluestem (Andropogon gerardii), little 

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

the short-grass prairie such as blue grama (Chondrosum 

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

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

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

mixed-grass prairie. 

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

primarily on available soils and soil moisture, reflected in 

xeric mixed-grassland plant species assemblages.

A number of changes in vegetation patterns noted since 

the NWTC was previously mapped17 is discussed below by 

specific plant community.

The plant communities are described below and mapped 

as illustrated.

Xeric Mixed Grassland 

Xeric mixed grassland is by far the largest and most widespread community type at the NWTC. These areas do not 

have access to regular soil moisture (xeric conditions) and 

are dominated by typical short- and mixed-grass prairie 

species. This plant community includes a large variety of 

native grass species as well as a diverse forb component, 

typical of mixed grasslands. Dominant species noted 

include big bluestem, little bluestem, prairie dropseed, 

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

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

bluestem, cheatgrass, sand lily (Leucocrinum montanum), 

wild iris (Iris missouriensis), Lambert locoweed (Oxytropis lambertii), mouse-ear (Cerastium strictum), western 

wallflower (Erysimum capitatum), and prairie golden pea 

(Thermopsis rhombifolia).

Wet Meadow

Three locations support wet meadows18 at the NWTC. 

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

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

and the third is adjacent to the Building 251 east parking 

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

between mesic and hydric conditions (i.e., a transition 

area between upland grasslands and wetlands). These 

areas support Arctic rush, Canada bluegrass (Poa compressa), redtop bentgrass (Agrostis stolonifera), Canada thistle, 

16,17 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, Colorado.

18 In the 2000 and 2011 surveys, wet meadows were identified as mesic mixed grassland. These areas were reclassified in 2012 as wet meadows 

due to an apparent change in vegetation and hydric conditions.
86 ENVIRONMENTAL PERFORMANCE REPORT 2015

Figure 7. NWTC land cover types surveyed in 2012.
ENVIRONMENTAL PERFORMANCE REPORT 2015 87

western wheatgrass, common three-square (Schoenoplectus pungens), showy milkweed (Asclepias speciosa), and 

wild iris (Iris missouriensis).

Ponderosa Pine Woodland

One woodland habitat, defined by a single community of 

the ponderosa pine (Pinus ponderosa) woodland, occurs 

in the northwestern corner of the site along a granite 

outcrop. This small area supports a very diverse native 

plant community including common grassland and 

foothills species, as well as a number of introduced and 

noxious weeds. Dominant species include ponderosa pine 

(Pinus ponderosa), smooth bromegrass, crested wheatgrass, and green needlegrass (Nassella viridula). Species 

flowering in late spring include sand lily, western snowberry (Symphoricarpus occidentalis), groundsel (Senecio sp.), 

and wax current (Ribes cereum).

Upland Shrubland

A small upland shrub community is located to the southeast of the ponderosa pine woodland, where the same 

ridge rises to a lesser degree from the surrounding grassland community. This rocky ridge supports shrub species 

interspersed with grasses and forbs representative of the 

surrounding grasslands. Dominant species noted include 

western snowberry, Canada wild rye (Elymus canadensis), 

Canada bluegrass, Kentucky bluegrass (Poa pratense), and 

little bluestem. Species flowering in late spring include 

prairie golden pea.

An isolated group of hawthorn (Crataegus erthyropoda) 

shrubs occurs along the western site boundary, within the 

NWTC boundary. These trees are at the top of the slope 

and occur directly east of an active area of construction 

disturbance, which is outside the NWTC boundary.

Palustrine Emergent Wetland

Two wetlands at the site fall into the palustrine emergent 

category. The first is a linear depression on the southern side of the south road. This area appears to have 

developed as the result of soil excavation intercepting 

sufficient surface water runoff from the adjacent road to 

support sedge species (Carex spp.). A second wetland is 

located on the southern boundary in an area previously 

disturbed from the neighboring industrial activities. This 

wetland comprises a center of cattails (Typha angustifolia) 

surrounded by a stand of coyote willow (Salix exigua).

Two palustrine emergent wetlands were mapped in the 

mesic mixed grassland in the 2000 growing season. 

These areas appear to have dried considerably in the 

intervening 10 years. The small wetland pockets of cattails 

(Typha spp.) that occurred in the southern portions of this 

area are no longer present, apparently replaced by large 

stands of Canada thistle. Dead remnants of Baltic rush 

(Juncus balticus) can be found in the area litter (prior years’ 

herbaceous vegetation). The dominant species noted was 

smooth bromegrass.

Headwater Wetland

Areas of headwater wetland occur along the two ephemeral drainages on the NWTC. Both drainages occur in the 

northeastern portion of the site, one flowing east and one 

flowing north. Both show evidence of intermittent 

surface flow. The northern-most drainage is a tributary 

of Coal Creek, and the second drainage is a tributary of 

Rock Creek.

Surface flow in the drainage to the northeast appears to 

be augmented by outflow from the groundwater seep 

wetland on the western bank. The second and larger 

drainage conducts surface flows through the center of 

the site off to the eastern fence line. The upper reaches 

of this drainage are a shallow grassland swale. This channel deepens as it flows east across the site. At its eastern 

reaches, this drainage clearly intercepts subsurface water, 

although not in sufficient quantities to produce consistent 

surface flow. At the point where this drainage leaves the 

NWTC, there is a human-constructed rock wall. Dominant 

species noted include Canada thistle, Baltic rush, curly 

dock (Rumex crispus), common evening primrose 

(Oenothera villosa), smooth bromegrass, and western 

wheatgrass (Pascopyrum smithii).

Groundwater Seep Wetland

Two areas of groundwater seep wetland are located on the 

NWTC. The first occurs west of the ponderosa pine woodland, in the northwestern portion of the site along the 

northern fence line. This area now includes more upland 

species than noted in 2000.

The second occurs over a very small area on the banks 

of the northern drainage. This community is a clearly 

demarcated area of primarily wetland plants amidst the 

surrounding grassland. Fifty plant species were identified 

in this community in 2000, many of which also occur in the 

headwater wetland to the south. Dominant species noted 

include sedges (Carex sp.) and rushes (Juncus sp.). Common 

teasel (Dipsacus fullonum) has invaded the northern drainage area. Species flowering in late spring include common 

teasel, showy milkweed (Asclepias speciosa), wild iris, fieldmint (Mentha arvensis), and Canada thistle.
88 ENVIRONMENTAL PERFORMANCE REPORT 2015

Seasonal Pond 

A seasonal pond and pond margin occur at the 

northwestern corner of the site, west of the southern 

terminus of the ponderosa pine woodland. This area 

appears to depend on an elevated spring and early 

summer water table for the hydric soil moisture conditions 

that support this community. Observers have noted that 

the pond depression often contains standing water in the 

spring and early summer in some years.19 However, no 

standing water was observed in this area during the most 

recent survey. These drier soil conditions are reflected in a 

shift of dominant plant species in this community between 

the 2000 and 2011 surveys. Dominant species noted 

include curly dock, Canada bluegrass, smooth bromegrass, 

and Canada thistle.

Disturbed 

These plant associations reflect surface disturbance due to 

human activities on the site. These areas include roadsides, 

pad sites, parking lot perimeters, construction sites, and 

storage areas. Some of these areas have been revegetated 

and now include a combination of species from surrounding natural plant communities, reclamation species, and 

adventive (non-native) or ruderal (native or adventive, 

disturbance colonizer) species. Dominant species noted 

include smooth bromegrass and cheatgrass.

Ornamental Trees/Shrubs 

Disturbed areas around buildings have been planted with 

a combination of native and ornamental trees and shrubs. 

The trees include multiple species of junipers (Sabina 

spp.) and pines (Pinus spp.), interspersed with ornamental 

deciduous trees. Shrubs in these areas are mainly 

chokecherry (Padus virginiana) and rose (Rosa spp.) bushes.

19 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center, Boulder, Colorado.
ENVIRONMENTAL PERFORMANCE REPORT 2015 89

APPENDIX B:

WILDLIFE SPECIES OBSERVED 

AT THE STM SITE AND THE NWTC

The following are lists of common and scientific names of 

wildlife species observed at the STM site and the NWTC. 

The species for the NWTC were identified during surveys 

completed in 2011. The species listed for STM site were 

observed by staff and/or observed in surveys completed in 

1987, 2005, and 2011.

TABLE 10. WILDLIFE SPECIES AT THE STM SITE*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

BIRDS

American crow Corvus brachyrhynchos X X

American goldfinch Carduelis tristis X

American kestrel Falco sparverius X X X

American pipit Anthus rubescens X

American redstart Setophaga ruticilla X

American robin Turdus migratorius X X X

American tree sparrow Spizella arborea X X

American white pelican Pelecanus erythrorhynchos X

Bald eagle** Haleatus leucocephalus

Barn swallow Hirundo rustica X

Black-billed magpie Pica hudsonia X X X

Black-capped chickadee Poecile atricapilla X

Black-crowned night heron Nycticorax nycticorax X

Black-headed grosbeak Pheucticus melanocephalus X

Blue-gray gnatcatcher Polioptila caerulea X

Blue jay Cyanocitta cristata X X

Brewer’s blackbird Euphagus cyanocephalus X X

Brewer’s sparrow Spizella breweri X

Broad-tailed hummingbird Selasphorus platycercus X

Broad-winged hawk Buteo platypterus X

Brown-headed cowbird Molothrus ater X X X

Bullock's oriole Icterus bullockii X X

Bushtit Psaltriparus minimus X

California gull Larus californicus X

Canada goose Branta canadensis X X

Cedar waxwing Bombycilla cedrorum X

Cassin’s kingbird Tyrannus vociferans X

Chestnut-collared longspur Calcarius ornatus X

Chipping sparrow Spizella passerina X

Cliff swallow Petrochelidon pyrrhonota X

Table 10 continued on page 90
90 ENVIRONMENTAL PERFORMANCE REPORT 2015

TABLE 10. WILDLIFE SPECIES AT THE STM SITE*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

BIRDS

Common grackle Quiscalus quiscula X

Common nighthawk Chordeiles minor X X X

Common raven Corvus corax X X

Common snipe Gallinago delicata X

Cooper's hawk Accipiter cooperii X X

Dark-eyed junco Junco hyemalis X X

Double-crested cormorant Phalacrocorax auritus X

Eastern kingbird Tyrannus tyrannus X

Eurasian collared dove** Streptopelia decaocto

European starling Sturnus vulgaris X X X

Golden eagle Aquila chrysaetos X

Grasshopper sparrow Ammodramus savannarum X

Great blue heron Ardea herodias X X

Great horned owl** Bubo virginianus

Green-tailed towhee Pipilo chlorurus X

Hepatic tanager Piranga flava X

Hermit thrush Catharus guttatus X

Horned lark Eremophila alpestris X X

House finch Carpodacus mexicanus X X

House sparrow Passer domesticus X X

House wren Troglodytes aedon X

Killdeer Charadrius vociferous X X X

Lark bunting Calamospiza melanocorys X X

Lark sparrow Chondestes grammacus X

Lazuli bunting Passerina amoena X

Lesser goldfinch Carduelis psaltria X

Loggerhead shrike Lanius ludovicianus X

MacGillivray's warbler Oporornis tolmiei X

Mallard Anas platyrhynchos X

Mountain bluebird Sialia currucoides X X

Mountain chickadee Poecile gambeli X

Mourning dove Zenaida macroura X X

Northern flicker Colaptes auratus X X

Northern goshawk Accipiter gentilis X

Northern harrier Circus cyaneus X

Northern saw-whet owl** Aegolius acadicus

Orange-crowned warbler** Oreothlypis celata

Osprey Pandion haliaetus X

Peregrine falcon Falco peregrinus X

Pine siskin Carduelis pinus X

Prairie falcon Falco mexicanus X

Red-breasted nuthatch Sitta canadensis X

Red-tailed hawk Buteo jamaicensis X X

Red-winged blackbird Agelaius phoeniceus X

Rock dove Columba livia X
ENVIRONMENTAL PERFORMANCE REPORT 2015 91

Table 10 continued on page 92

TABLE 10. WILDLIFE SPECIES AT THE STM SITE*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

BIRDS

Rock wren Salpinctes obsoletus X

Ruby-crowned kinglet Regulus calendula X

Sage thrasher Oreoscoptes montanus X

Say's phoebe Sayornis saya X

Sharp-shinned hawk Accipiter striatus X

Spotted towhee Pipilo maculates X

Swainson's hawk Buteo swainsoni X

Tree swallow Tachycineta bicolor X X

Turkey vulture Cathartes aura X

Vesper sparrow Pooecetes gramineus X

Virginia’s warbler Oreothlypis virginiae X 

Violet-green swallow Tachycineta thalassina X

Western kingbird Tyrannus verticalis X X

Western meadowlark Sturnella neglecta X X

Western scrub-jay Aphelocoma californica X

White-crowned sparrow Zonotrichia leucophrys X

White-faced ibis Plegadis chihi X

White-throated swift Aeronautes saxatalis X

Yellow-breasted chat Icteria virens X

Yellow-rumped warbler Dendroica coronata X

MAMMALS 

Big brown bat** Eptesicus fuscus

Black bear** Ursus americanus

Black-tailed jackrabbit Lepus californicus X X

Bushy-tailed woodrat Neotoma cinerea X

Coyote Canis latrans X X X

Deer mouse Peromyscus maniculatus X X

Elk** Cervus canadensis

Fox squirrel Sciurus niger X

Hoary bat** Lasiurus cinereus

Long-tailed weasel Mustela frenata X 

Mexican woodrat Neotoma mexicana X X

Mountain cottontail Sylvilagus nuttalli X X X

Mule deer Odocoileus hemionus X X X

Prairie vole Microtus ochrogaster X X

Raccoon Procyon lotor X X X

Red fox Vulpes vulpes X X

Striped skunk Mephitis X

Western harvest mouse Reithrodontomys megalotis X X X

Western spotted skunk Spilogale gracilis X

White-tailed jackrabbit Lepus townsendii X

Yellow-bellied marmot Marmota flaviventris X
92 ENVIRONMENTAL PERFORMANCE REPORT 2015

*No terrestrial arthropod genera of specific concern were detected during surveys in 2010.

**Species observed at a time other than in a survey.

TABLE 10. WILDLIFE SPECIES AT THE STM SITE*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

REPTILES AND AMPHIBIANS

Bull snake Pituophis catenifer X X

Plains garter snake Thamnophis radix X X

Prairie lizard Sceloporus undulatus X

Racer Coluber constrictor X

Six-lined racerunner Cnemidophorus sexlineatus X

Tiger salamander Ambystoma tigrinum X X

Western chorus frog** Pseudacris triseriata

Western (Prairie) rattlesnake Crotalus viridus X X X

Woodhouse’s toad Bufo woodhousii X
ENVIRONMENTAL PERFORMANCE REPORT 2015 93

TABLE 11. WILDLIFE SPECIES AT THE NWTC*

SPECIES COMMON NAME SCIENTIFIC NAME 1996 Survey 2003 Survey 2011 Survey

BIRDS

American crow Corvus brachyrhynchos X

American goldfinch Spinus tristis X X

American kestrel Falco sparverius X X X

American pipit Anthus rubescens X

American robin Turdus migratorius X X

American tree sparrow Spizella arborea X

Bald eagle Haliaeetus leucocephalus X

Barn swallow Hirundo rustica X X

Black-billed magpie Pica hudsonia X X

Black-capped chickadee Poecile atricapillus X X

Blue-gray gnatcatcher Polioptila caerulea X

Blue jay Cyanocitta cristata X

Brewer's blackbird Euphagus cyanocephalus X X

Brewer's sparrow Spizella breweri X

Broad-tailed hummingbird Selasphorus platycercus X X

Broad-winged hawk Buteo platypterus X

Brown-headed cowbird Molothrus ater X X

Bullock's oriole Icterus bullockii X

Canada goose Branta canadensis X

Cedar waxwing Bombycilla cedrorum X

Chipping sparrow Spizella passerina X X

Cliff swallow Petrochelidon pyrrhonota X

Common grackle Quiscalus quiscula X X

Common nighthawk Chordeiles minor X

Common raven Corvus corax X X

Common snipe Gallinago delicata X

Cooper’s hawk Accipiter cooperii X

Dark-eyed junco Junco hyemalis X

Double-crested cormorant Phalacrocorax auritus X

Downy woodpecker Picoides pubescens X

Eurasian collared-dove Streptopelia decaocto X

European starling Sturnus vulgaris X X

Ferruginous hawk Buteo regalis X X

Franklin's gull Larus pipixcan X

Golden eagle Aquila chrysaetos X X X

Grasshopper sparrow Ammodramus savannarum X X

Gray catbird Dumetella carolinensis X

Great blue heron Ardea herodias X X

Great horned owl Bubo virginianus X

Green-tailed towhee Pipilo chlorurus X

Hairy woodpecker Picoides villosus X

Horned lark Eremophila alpestris X X

House finch Carpodacus mexicanus X X

Killdeer Charadrius vociferus X

Table 11 continued on page 94
94 ENVIRONMENTAL PERFORMANCE REPORT 2015

TABLE 11. WILDLIFE SPECIES AT THE NWTC*

SPECIES COMMON NAME SCIENTIFIC NAME 1996 Survey 2003 Survey 2011 Survey

BIRDS

Lark bunting Calamospiza melanocorys X

Lark sparrow Chondestes grammacus X

Loggerhead shrike Lanius ludovicianus X

Long-billed curlew Numenius americanus X

Mallard Anas platyrhynchos X X

Merlin Falco columbarius X

Mountain bluebird Sialia currucoides X X

Mountain chickadee Poecile gambeli X

Mourning dove Zenaida macroura X X

Northern flicker Colaptes auratus X X

Northern goshawk Accipiter gentilis X

Northern harrier Circus cyaneus X X X

Osprey Pandion haliaetus X

Peregrine falcon Falco peregrinus X X

Prairie falcon Falco mexicanus X X

Red-headed woodpecker Melanerpes erythrocephalus X

Red-tailed hawk Buteo jamaicensis X X X

Red-winged blackbird Agelaius phoeniceus X X

Rough-legged hawk Buteo lagopus X X X

Ruby-crowned kinglet Regulus calendula X

Sandhill crane Grus canadensis X

Savannah sparrow Passerculus sandwichensis X

Say's phoebe Sayornis saya X X

Sharp-shinned hawk Accipiter striatus X

Song sparrow Melospiza melodia X

Spotted towhee Pipilo maculatus X

Swainson's hawk Buteo swainsoni X X

Tree swallow Tachycineta bicolor X

Turkey vulture Cathartes aura X X X

Vesper sparrow Pooecetes gramineus X X

Western kingbird Tyrannus verticalis X X

Western meadowlark Sturnella neglecta X X

Wilson’s warbler Wilsonia pusilla X

Yellow-rumped warbler Dendroica coronata X
ENVIRONMENTAL PERFORMANCE REPORT 2015 95

TABLE 11. WILDLIFE SPECIES AT THE NWTC*

SPECIES COMMON NAME SCIENTIFIC NAME 1996 Survey 2003 Survey 2011 Survey

MAMMALS

Big brown bat Eptesicus fuscus X

Black-tailed prairie dog** Cynomys ludovicianus

Bobcat** Felis rufus

Coyote Canis latrans X

Deer mouse Peromyscus maniculatus X

Desert cottontail Sylvilagus audubonii X

Eastern red bat Lasiurus borealis X

Elk Cervus canadensis X

Fringed myotis Myotis thysanodes X

Hoary bat Lasiurus cinereus X

Masked shrew Sorex cinereus X

Meadow vole Microtus pennsylvanicus X

Mexican woodrat Neotoma mexicana X

Mule deer Odocoileus hemionus X

Myotis bats Myotis sp. X

Prairie vole Microtus ochrogaster X

Silver-haired bat Lasionycteris noctivagans X

Thirteen-lined ground squirrel Spermophilus tridecemlineatus X

Western harvest mouse Reithrodontomys megalotis X

REPTILES AND AMPHIBIANS

Boreal chorus frog Pseudacris maculata X

Bull snake Pituophis catenifer X

Western (Prairie) rattlesnake Crotalus viridus X X X

Woodhouse’s toad Bufo woodhousii X

TERRESTRIAL ARTHROPODS

Aphrodite fritillary Speyeria aphrodite X

Cabbage white Pieris rapae X

Checkered white Pontia protodice X

Common wood nymph Cercyonis pegala X

Dainty sulphur Nathalis iole X

Gray hairstreak Strymon melinus X

Orange sulphur Colias eurytheme X

Western white Pontia occidentalis X

*The 1996 study addressed only raptors. Mammals, reptiles, amphibians, or terrestrial arthropods were not the subject of a survey at the 

NWTC until the 2011 baseline survey.

**Species observed at a time other than in a survey.
96 ENVIRONMENTAL PERFORMANCE REPORT 2015

TABLE 12. NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2015

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

AST for petroleum 

storage

STM ESIF AST Registration DOPS 19275-1 Completed

AST for petroleum 

storage

STM PDU AST Registration DOPS 2873-2 Completed

AST for petroleum 

storage

STM RSF2 AST Registration DOPS 19211-1 Completed

AST for petroleum 

storage

STM SERF AST Registration DOPS 2873-1 Completed

AST for petroleum 

storage

E85 AST Registration DOPS 2873-4 Completed

Air Laboratory-wide servicing of CFC-containing 

equipment Notification APCD 647 Active

Air STM SERF, 2 CFC-containing stationary sources Registration APCD 647 Active

Air STM FTLB waste gas combustor Permit APCD 99JE0400 Active

Air STM RFHP wood waste boiler Permit APCD 07JE0277 Active

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

Air STM RSF 1 diesel-fired standby electrical 

generator

Permit APCD 10JE1400 Active

Air STM RSF 2 diesel-fired standby electrical 

generator

Permit APCD 11JE1303 Active

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

Air NWTC Site 4.0 diesel-fired standby electrical 

generator

Permit APCD 10JE1712 Active

Air STM parking garage diesel-fired standby electrical 

generator

Permit APCD 11JE1997 Active

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

Air STM ESIF research electrical generator #3 Permit APCD 13JE2829 Active

Air STM IBRF scrubber and baghouse Permit APCD 11JE1798 Active

Air STM ESIF research electrical generator #1 APEN APCD 12JE1734 XP Active

Air STM ESIF research electrical generator #2 APEN APCD 12JE1735 XP Active

APPENDIX C:

ENVIRONMENTAL PERMITS, 

REGISTRATIONS, AND 

NOTIFICATIONS APPLICABLE 

TO NREL DURING 2015
ENVIRONMENTAL PERFORMANCE REPORT 2015 97

Table 12 continued on page 98

TABLE 12. NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2015

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

Air STM IBRF standby electrical generator APEN APCD 13JE2276 XP Active

Air NWTC STL standby electrical generator APEN APCD 13JE2271 XP Active

Air NWTC Building 251 standby electrical generator APEN APCD 13JE2272 XP Active

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

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

Drinking water 

system NWTC drinking water system ID number Registration WQCD CO0230860 In Effect; Does 

Not Expire

Groundwater well STM groundwater monitoring well MW-1 Permit DWR 37229 Abandoned 

per regulations

Groundwater well STM groundwater monitoring well MW-2 Permit DWR 37228 Abandoned 

per regulations

Groundwater well STM groundwater monitoring well MW-3 Permit DWR 37231 Abandoned 

per regulations

Groundwater well STM groundwater monitoring well MW-4 Permit DWR 37230 Abandoned 

per regulations

Groundwater well STM groundwater monitoring well MW-5 Permit DWR 37233 Abandoned 

per regulations

Groundwater well STM FTLB groundwater monitoring well MW-FTLB-1 Permit DWR 53674-MH Active

Groundwater well STM FTLB groundwater monitoring well MW-FTLB-2 Permit DWR 53674-MH Active

Groundwater well STM FTLB groundwater monitoring well MW-FTLB-3 Permit DWR 53675-MH Active

Hazardous materials STM WHF hazardous material storage and use permit Permit WMFR 9243 Active

Hazardous materials STM SERF hazardous material storage and use permit Permit WMFR 9248 Active

Hazardous materials STM S&TF hazardous material storage and use permit Permit WMFR 9249 Active

Hazardous materials STM FTLB hazardous material storage and use permit Permit WMFR 9244 Active

Hazardous materials STM IBRF hazardous material storage and use permit Permit WMFR 9245 Active

Hazardous materials STM Shipping and Receiving hazardous material 

storage and use permit Permit WMFR 9246 Active

Hazardous materials DWOP building 16 hazardous material storage and 

use permit Permit WMFR 9242 Active

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

Department 154229 Active

Hazardous waste DWOP RCRA hazardous waste generator status 

EPA ID Notification HMWMD CO4890000017 Completed

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

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

Hazardous waste NWTC RCRA hazardous waste generator status 

EPA ID Notification HMWMD COD983802448 Completed

Hazardous waste ReFUEL RCRA hazardous waste generator status 

EPA ID Notification HMWMD COR000207563 Completed

Historic registration STM amphitheater Registration NPS 93000378 In effect; does 

not expire

Historic registration STM stone bunker Registration NPS 93000379 In effect; does 

not expire
98 ENVIRONMENTAL PERFORMANCE REPORT 2015

TABLE 12. NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2015

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

Stormwater STM ESIF construction project Permit EPA COR12A60F Terminated

Stormwater STM electrical upgrade project Permit EPA COR12B06F Active

Stormwater STM SERF & STF Landscape Improvements/DWP 

Safety Enhancements (FTLB) Permit EPA COR12AW4F Active

Acronyms used in the table

APCD – Air Pollution Control Division of Colorado Department of Public Health and the Environment (CDPHE)

APEN – Air Pollutant Emission Notice

AST – Aboveground Storage Tank

CFC – Chlorofluorocarbon

DFD – Denver Fire Department

DOPS – Division of Oil and Public Safety of the Colorado Department of Labor and Employment

DWOP – Denver West Office Park

DWR – Division of Water Resources

EPA – Environmental Protection Agency

ESIF – Energy Systems Integration Facility

FTLB – Field Test Laboratory Building 

HMWMD – Hazardous Materials and Waste Management Division of CDPHE

IBRF – Integrated Biorefinery Research Facility

NPS – National Park Service of the U.S. Department of the Interior

NWTC – National Wind Technology Center

PDU – Process Development Unit

RCRA – Resource Conservation and Recovery Act

ReFUEL – Renewable Fuels and Lubricants Research Laboratory 

RFHP – Renewable Fuel Heat Plant 

RSF – Research Support Facility

S&TF – Science and Technology Facility

SERF – Solar Energy Research Facility

STM – South Table Mountain

TTB – Alcohol and Tobacco Tax and Trade Bureau of the U.S. Department of the Treasury

WHF – Waste Handling Facility

WMFR – West Metro Fire Rescue

WQCD – Water Quality Control Division of CDPHE

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