ENVIRONMENTAL PERFORMANCE 

REPORT 2017 Annual Site Environmental Report per the

U.S. Department of Energy Order 231.1B Chg 1
Cover Photo: In late June, a doe found a shady spot just outside the Science and Technology Facility to deliver twin fawns, an event witnessed 

from a distance by several staff members. A short time later, one of the fawns was already standing. Photo by Bryan Bechtold, NREL 50156

This work was authored by the National Renewable Energy Laboratory, operated by Alliance for Sustainable Energy, LLC, for the U.S. 

Department of Energy (DOE) under Contract No. DE-AC36-08GO28308. Funding provided by U.S. Department of Energy Office of Energy 

Efficiency and Renewable Energy. The views expressed in the article do not necessarily represent the views of the DOE or the U.S. Government.
Acknowledgements | Co ntact Us 1

ACKNOWLEDGEMENTS

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, Safety, Health, and Quality (ESH&Q) 

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 

Tom Ryon

Kurt Schlomberg

Eric Schmitz

Suzanne Belmont and Lissa Myers of NREL’s Intelligent 

Campus group provided content for the Climate 

Change Adaptation Management and Sustainability 

Goals Performance sections of the report. 

Leigh Ramsey, Stacy Buchanan, Liz Craig, and Kathryn 

Ruckman with NREL’s Communications and Public 

Affairs Office provided project support, design,

and editing.

Lori Gray and Nicole Serio, with the U.S. Department 

of Energy Golden Field Office, worked closely with 

staff of the Alliance for Sustainable Energy, LLC, to 

continuously improve the report, and they conducted 

the review and approval process.

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:

Henry Higaki

Director, Environment, Safety,

Health, and Quality Office 

henry.higaki@nrel.gov

303-275-4212

John Eickhoff 

Environmental Manager 

john.eickhoff@nrel.gov

303-275-3217

Leigh Ramsey

Communications & Public Affairs Office

leigh.ramsey@nrel.gov

303-275-3668

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
2 table of Contents

TABLE OF CONTENTS

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

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

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

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

Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Environmental and Sustainability Performance . . . . . . . . . . . . . . . . . . . 5

Environmental Compliance and Monitoring . . . . . . . . . . . . . . . . . . . . . . 8

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

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

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

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

2 Environmental Management System

and Pollution Prevention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2.1 Environmental Management

System Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

2.2 Pollution Prevention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

2.3 Performance Indicators and Progress . . . . . . . . . . . . . . . . . . . . . . . . 18

2.4 Assessment and Improvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.5 2017 Awards and Recognition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

2.6 Integrated Environmental Stewardship

in Construction Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

3 Sustainability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

3.1 Sustainability Goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

3.2 Climate Change Adaptation Management . . . . . . . . . . . . . . . . . 29

4 Compliance Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .30

5 Air Quality Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

6 Water Quality Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

6.1 Drinking Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

6.2 Groundwater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

6.3 Surface Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

6.4 Wastewater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

7 Hazardous Materials and Hazardous

Waste Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

7.1 Hazardous Materials Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

7.2 Hazardous Waste Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

7.3 Aboveground Storage Tank Management . . . . . . . . . . . . . . . . . . 50

7.4 Spill Prevention and Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

7.5 Radiological Materials and Waste Management . . . . . . . . . . . 51

8 National Environmental Policy Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

9 Natural and Cultural Resources Protection . . . . . . . . . . . . . . . . .53

9.1 Wildlife Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

9.2 Endangered Species and Species of Concern . . . . . . . . . . . . . . 55

9.3 Vegetation Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

9.4 Wetlands and Floodplains . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

9.5 Cultural Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

10 Conservation Lands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

Appendix A. Program Management Descriptions . . . . . . . . . . . . 64

Appendix B. Environmental Permits,

Registrations, and Notifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

Appendix C. Wildlife Species Observed

at the STM Site and the NWTC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77

Appendix D. Plant Communities at the

STM Site and the NWTC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86

NREL

Environmental 

Performance 

Report 2017
table of Contents 3

List of Figures 

Figure 1. NREL’s continual improvement cycle . . . . . . . . . . . . . . . . . . . . . . 17

Figure 2. NREL’s environmental aspects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Figure 3. Results of 2017 average monthly chlorine

residual monitoring at the NWTC . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Figure 4. Comparison of disinfection byproducts 

monitoring at the NWTC, 2013–2017 . . . . . . . . . . . . . . . . . . . . . 45

Figure 5. Conservation easement at the STM site . . . . . . . . . . . . . . . . . . 63

Figure 6. STM site land cover types surveyed in 2017 . . . . . . . . . . . . . 88

Figure 7. NWTC land cover types surveyed in 2016 . . . . . . . . . . . . . . . . 92

List of Tables

Table 1. 2017 Environmental Goals and Achievements . . . . . . . . . 19

Table 2. Sustainability Goals and Performance Summary . . . . . . . 26

Table 3. Federal, State, and Local Environmental

Laws and Regulations and Compliance

Status Applicable to NREL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Table 4. STM Site, NWTC, and Denver West Office Park 

Estimated Annual Air Pollutant Emissions . . . . . . . . . . . . . . . . 43

Table 5. 2017 Emergency Planning and Community 

Right-to-Know Act Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Table 6. Comparison of Four Waste Categories

Generated at NREL Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Table 7. Noxious Weed Species Identified at the

STM Site and the NWTC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

Table 8. Wetland Types and Acreages at the

STM Site and the NWTC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

Table 9. NREL’S Environmental Permits, Registrations,

and Notifications in 2017 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

Table 10. Wildlife Species at the STM Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77

Table 11. Wildlife Species at the NWTC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82

National Wind Technology Center. Photo by Dennis Schroeder, NREL 44821
4 Nomenclature

NOMENCLATURE

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

CGI Controllable Grid Interface

CO2 Carbon Dioxide

CoMET Composites Manufacturing Education

and Technology

CRS Colorado Revised Statute 

CWA Clean Water Act

DERTF Distributed Energy Resources Test Facility

DOE U.S. Department of Energy

DOE Department of Energy Order

Order

DOPS Division of Oil and Public Safety of the Colorado 

Department of Labor and Employment

DWOP Denver West Office Park

EA Environmental Assessment

EMS Environmental Management System

EPA U.S. Environmental Protection Agency

EPCRA Emergency Planning and Community

Right-to-Know Act 

EPEAT Electronic Product Environmental

Assessment Tool 

ESA Endangered Species Act

EO Executive Order

ESIF Energy Systems Integration Facility

FTLB Field Test Laboratory Building

FY Fiscal Year

GHG Greenhouse Gas

IBRF Integrated Biorefinery Facility

ISO International Organization for Standardization

JSF Joyce Street Facility

MBTA Migratory Bird Treaty Act

mrem Millirem

MT Metric tons

NEPA National Environmental Policy Act 

NREL National Renewable Energy Laboratory

NWTC National Wind Technology Center

ODS Ozone Depleting Substances

OTF Outdoor Test Facility

RFHP Renewable Fuel Heating Plant

RSF Research Support Facility

S&TF Science & Technology Facility

SERF Solar Energy Research Facility

SPCC Spill Prevention Control and Countermeasures 

SRRL Solar Radiation Research Laboratory

STL Structural Testing Laboratory

STM South Table Mountain

TTF Thermal Test Facility

USACE U.S. Army Corps of Engineers

VTIF Vehicle Testing and Integration Facility
Executive Summary 5

Blue flax (Linum lewisii) growing in the South Table 

Mountain site main detention basin is one of many 

wildflower species that can be observed in the basin and 

throughout the site. Photo by Dennis Schroeder, NREL 45386

EXECUTIVE SUMMARY

Purpose

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

Environmental Performance Report provides a description of 

the laboratory’s environmental management activities in 2017, 

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 positively 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 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.

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 and 

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 
6 Nomenclature

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 

helped enable 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 main 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 market-relevant research, to systems integration and 

testing and validation.

Deer grazing near a test photovoltaic array at the South Table Mountain site. Photo by Dennis Schroeder, NREL 45449
Executive Summary 7

the DOE Golden Field Office on Performance Evaluation and 

Measurement Plan results and for DOE Headquarters on Site 

Sustainability Plan results. The laboratory identified several 

goals in 2017 to enhance sustainability and environmental 

performance and made—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. NREL operates as a living laboratory 

by implementing strategies and technologies in its facilities 

and then studying the adoption and effectiveness through 

participation by staff. 

The following are some of the laboratory’s key

accomplishments:

• Achieved short-term internal environmental and

sustainability goals, and made progress toward longterm goals (for more details, see section 2, Environmental

Management System and Pollution Prevention, and

section 3, Sustainability)

• Received several awards and recognitions for environmental

and sustainability accomplishments (see sidebar on page 8)

• Recertified to International Organization for Standardization

14001:2015 for environmental management systems, as

verified by a team of external auditors

• Continued to make progress on identifying and

implementing solutions to operational vulnerabilities that

could result from climate change

• Installed a thermosyphon on the high performance

computing data center in the Energy Systems Integration

Facility at the South Table Mountain site, which significantly

reduced water consumption while maintaining a worldclass power usage effectiveness rating of 1.03. Power Usage

Effectiveness (PUE) is the ratio of total amount of energy

used by a computer data center to the energy delivered to

computing equipment. An ideal PUE is 1.0.

• Decontaminated and properly disposed of equipment, such

as test chambers, exhaust hoods, and glove boxes, from

several individual laboratory spaces that were undergoing

renovation

• Enhanced spill control preparedness training through

mapping of key spill control points based on proximity to

site drainage features, ease of access, and ease with which

sorbents and containment structures can be deployed

• Continued to provide support to DOE in identifying potential

environmental impacts related to renewable energy efforts

that support DOE’s mission

• Continued acoustical bat monitoring at the National Wind

Technology Center

An especially large number of Painted Lady butterflies (Vanessa cardui) were seen in September 2017 across the STM site, most commonly on 

flowering Rabbitbrush (Ericameria nauseosa). Photo by Werner Slocum, NREL 50278
8 Executive Summary

• Conducted wildlife surveys at the South Table Mountain site;

highlights included documentation of the Northern Pygmy

Owl (Glaucidium californicum), which had not previously

been recorded

• Installed four nest structures for Barn Swallows (Hirundo 

rustica) at the National Wind Technology Center

• Delayed removal of a metal shed so that an active bee hive

within the shed could be removed and relocated at a time of

year that would not impact the viability of the colony

• Successfully used raptor predator call recordings and

visible decoys to deter roosting pigeons at the South Table

Mountain site parking garage structure

• Hosted and participated in a symposium at the Northern

Wildlife Society on renewable energy and impacts to wildlife

• Hosted a local Audubon group at the South Table Mountain

site to tour the facility and provide information regarding

bird-friendly building design and retrofits.

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.

The laboratory continued its excellent record of environmental 

compliance in 2017. 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 continued to improve its environmental 

management and performance in 2017, as demonstrated 

by a track record of excellent compliance with regulatory 

requirements and established leadership in environmental and 

sustainability management. Major environmental programs 

include:

• Air quality protection including air permitting, ozonedepleting 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; planning;

permitting; and reporting regarding use and emissions

of materials

• National Environmental Policy Act reviews

• Natural and cultural resources protection including wildlife,

vegetation, protected species, wetlands, and cultural

resources management.

Prestigious Environmental

Sustainability Awards Received

NREL received the following important recognitions 

in 2017 for its environmental and sustainability 

accomplishments, including:

• Three Star Electronic Product Environmental

Assessment Tool Purchases Award from the

Green Electronics Council for excellence in the

procurement of high-performance sustainable

electronics

• Colorado Environmental Leadership Program

Gold-Level Leader Award for exceeding regulatory

requirements and for continued partnership with

the Colorado Department of Public Health and

Environment since 2004

• DOE Honorable Mention for NREL’s nomination

for the 2017 Presidential Migratory Bird Federal

Stewardship Award, which recognizes migratory

bird conservation efforts at federal facilities and

projects involving a federal partnership.

NREL’s Continued International 

Organization for Standardization (ISO) 

14001 Certification Demonstrates 

Commitment to Environmental Leadership 

The laboratory’s environmental management 

system has been ISO 14001 certified since 2011. The 

initial certification was for the 2004 version of the 

standard, and during 2017 the management system 

was recertified to the current 2015 version. 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 ISO 

14001, demonstrating the laboratory’s commitment 

to environmental stewardship.
Introduction 9

The rotor from the U.S. Department of Energy’s

1.5 megawatt wind turbine at the National Wind 

Technology Center is removed to allow installation

of a new gearbox to undergo reliability testing.

Photo by Brad King, NREL 49520

1 INTRODUCTION

1.1 Purpose

This report presents a summary of the National Renewable 

Energy Laboratory’s (NREL’s) environmental management 

activities in 2017, 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 

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 following 

mission statement:

NREL advances the science and engineering of energy 

efficiency, sustainable transportation, and renewable 

power technologies, and provides the knowledge to 

integrate and optimize energy systems.

NREL fulfills its mission through technology portfolios.

A brief description of each major technology area follows.

• Advanced Manufacturing – Scientific and engineering

research at NREL focuses on reducing energy requirements

associated with the most energy-intensive manufacturing

industries and accelerating those innovations to

commercialization of next-generation technologies and

processes.

• Bioenergy – NREL bioenergy investigations advance

technologies to produce bio-based fuels, products, and

energy. Research ranges from discovery science to pilotscale processing related to biochemical conversion,

thermochemical conversion, and life-cycle analyses.
10 Introduction

• Building Efficiency – NREL supports the research and

development of technologies and practices for building

energy efficiency, working closely with industry and

manufacturers. NREL also promotes energy- and moneysaving opportunities to builders and consumers, and works

with state and local regulatory groups to improve building

codes and appliance standards.

• Chemistry and Nanoscience – NREL investigates materials

and processes for converting renewable and clean energy

resources into chemical and electrical energy. Resources

such as sunlight, heat, and renewable materials are

converted to fuels and other chemical and electrical energystorage modes. Staff conducts research across the entire

spectrum—from foundational science to working closely

with industry to commercialize new technologies.

• Computational sciences – The laboratory works to solve

energy challenges using high-performance computing,

computational science, applied mathematics, scientific data

management, visualization, and informatics. NREL is also home

to the world’s largest high performance and most energyefficient data center dedicated to advancing renewable

energy and energy efficiency technologies.

• Concentrating Solar Power – NREL staff provide scientific,

engineering, and analytical expertise to help advance

innovation in concentrated solar power technologies.

Concentrated solar power is unique in its ability to store

thermal energy in inexpensive and efficient thermal energy

storage systems.

• Energy analysis – NREL’s energy analysis informs policy and

investment decisions that lead to more resilient, reliable, and

efficient energy systems. With objective, technology-neutral

analysis, NREL aims to increase understanding of energy

policies, markets, resources, technologies, and infrastructure

to address economic, security, and environmental priorities.

• Energy Systems Integration and Grid Modernization –

NREL staff at the South Table Mountain site’s Energy Systems

Integration Facility and at the National Wind Technology

Center collaborates with industry and academic partners to

test the ability of the electric grid to incorporate sources of

renewable energy and investigate ways to modernize the

electric grid infrastructure to improve its reliability, resiliency,

and security.

• Geothermal Energy – Geothermal energy research at

NREL includes developing new techniques to increase the

production of geothermal energy, exploring the benefits

of combining geothermal and other renewable energy

systems, and collaborating with industry, government

agencies, and other partnering entities to advance the use of

geothermal energy worldwide.

• Hydrogen and Fuel Cells – The laboratory’s hydrogen

and fuel cell research and development program focuses

on developing, integrating, and demonstrating hydrogen

production and delivery, hydrogen storage, and fuel cell

technologies for transportation, stationary, and portable

applications.

• Integrated Energy Solutions – NREL supports the transition

to renewable energy portfolios at the city, state, national, and

international levels by performing technical and economic

evaluations of renewable energy opportunities that address

technology, policy, social, and market systems.

• Materials Science – NREL provides fundamental and

applied materials science discovery and problem-solving for

current and next-generation renewable energy and energyefficient technologies. Focus areas include materials physics,

electronic structure theory, analytical microscopy and

imaging science, interfacial and surface science, materials

discovery, and thin-film material science and processing for

photovoltaics and other energy applications.

NREL staff prepares samples for research in improving enzyme 

performance for breaking down plant matter into renewable fuels 

and products. Photo by Dennis Schroeder, NREL 49146

An NREL researcher works with a differential scanning calorimeter to 

characterize thermal fluids at high temperatures for corrosion-resistant 

metal coatings used in concentrating solar power equipment. Photo by 

Dennis Schroeder, NREL 45088
Introduction 11

• Photovoltaics and Solar Power – Photovoltaic cells enable

the direct conversion of sunlight into electricity using solidstate materials. NREL’s capabilities in photovoltaics include

both fundamental and applied research and development,

such as theory and modeling, materials deposition, device

design, measurements and characterization, and reliability

testing and engineering.

• Transportation – NREL collaborates 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.

• Water Power – NREL’s water power program focuses on

advancing the use of hydropower through data validation,

development of innovative water power technologies, and

toolkits to assist water power sector businesses in navigating

hydropower regulations.

• Wind energy – From conceptualizing taller turbines capable

of greater energy capture to assessing the United States’ 

offshore wind energy needs and potential, the National

Wind Technology Center drives wind industry acceleration.

Facilities at the National Wind Technology Center also

enable testing of turbine-drivetrain components; designing,

researching and validating advanced wind power plant

control systems; and manufacturing and testing turbine

blades of various new composite materials.

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 for NREL 

research operations. 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 a small office area 

housed within the Regional Transportation District’s District 

Shops and Operations Center facility in Denver.

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 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 of the Rocky Mountains 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.

Crews work to install the first power-to-gas system in the U.S. at 

the STM site. Southern California Gas partnered with NREL on the 

project, which takes excess electricity and converts it to hydrogen, 

which can be used, stored or combined with carbon dioxide to 

produce renewable natural gas. Photo by Werner Slocum, NREL 47256

NREL sponsored and hosted the “Workshop on the Present and Future 

of Energy Storage” at which NREL researchers collaborated with 

attendees on strategies, developments, breakthroughs, and challenges 

associated with energy storage. Photo by Dennis Schroeder, NREL 49377
12 Introduction

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 has 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 [m]) 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 driver-training track are located along the 

northwestern boundary of the STM site on top of the mesa. 

Jefferson County open space wraps around the northern and 

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) is 

preserved 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 10, 

Conservation Lands.)

Geology, Soils, and Hydrogeology

South Table Mountain 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.

The Arapahoe, Laramie-Fox Hills, and Denver Formations are 

considered to be aquifers in portions of the Denver Basin. 

The Denver Formation underlies the areas on which most 

NREL construction has taken place. Groundwater on the STM 

site occurs primarily in the weathered and fractured silts and 

sands of the Denver Formation. There may also be some 

groundwater in the form of perched aquifers below the basaltic 

lava cap on 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.

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

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
Introduction 13

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, welldrained clayey soil. Soil on the upper side slopes of South Table 

Mountain is also a loam and consists of extremely stony soils 

with significant amounts of clay. Much of the remainder of the 

site, including the area designated for major development, 

has a deep, well-drained soil referred to as Denver clay loam. It 

consists of clayey material containing some calcium carbonate. 

There are also two smaller soil areas on the southwestern 

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

cobbly clay loam and very stony clay loam.

Surface Water

About 90% of the surface drainage 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. 

(For more details, see Appendix D, Plant Communities at the 

STM site and the NWTC.)

Wildlife

Several comprehensive wildlife surveys have been conducted 

on the site, starting with the original study in 1987. Numerous 

mammals, and several types of amphibians and reptiles, have 

been identified during the surveys. More than 75 species of 

birds and a number of raptor species have also been recorded 

at or above the STM site by formal wildlife surveys and 

through employee observations. (For more details, see section 

9.1, Wildlife Management, and Appendix C, Wildlife Species 

Observed at the STM site and the NWTC).

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

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 borders the NWTC to the south 

and east. A restored sand and gravel mine is located due south 

(on the refuge’s 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

A Common Loon (Gavia immer) made an unexpected landing at the 

NWTC on a foggy morning in November. A wildlife rehabilitation 

organization took the bird to a nearby pond to resume its journey 

south for the winter. Photo by Garth Johnson, NREL 50078
14 Introduction

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 mountain and prairie 

ecosystems, and associations that represent residual tallgrass 

prairie, shortgrass plains, ponderosa pine woodland, and 

foothill ravine flora.3

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

3. ERO. (2016). 2016 Wildlife and Vegetation Monitoring Report, National Wind Technology Center. Jefferson County, Colorado. 

Vegetation surveys conducted at the site have identified more 

than 270 vascular plant species and defined five major habitat 

types on the NWTC, 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. (For more 

details, see Appendix D, Plant Communities at the STM site 

and the NWTC.)

Wildlife

Although the site was heavily grazed by cattle prior to 1975, 

surveys conducted since that time identified several species 

of mammals that utilize vegetation and other habitat that 

exists at the NWTC. Included among these are mule deer, 

coyotes, white-tailed jackrabbits, and thirteen-lined ground 

squirrels. Amphibians and reptiles (including the prairie 

rattlesnake) and numerous species of birds and raptors have 

been documented in surveys conducted since 1992. (For more 

details, see Appendix C, Wildlife Species Observed at the STM 

site and the NWTC.)

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

Building 251 Switch Gear 

Building

Grid Storage

Pads

CoMET

CGI

5 MW

Dynamometer

2.5 MW 

DynaSTL mometer

Modal 

DERTF A-60 Lab
Introduction 15

Denver West Office Park

The Denver West Office Park, located within the City of 

Lakewood approximately two 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. NRELleased 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 

hybrid vehicles. The laboratory consists of a single vehicle 

high bay and a small office area housed within the Regional 

Transportation District’s District Shops and Operations Center 

located at 1900 31st Street in 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.

Denver West Office Park, Building 16. Photo by Dennis Schroeder, NREL 44872

Joyce Street Facility (leased area indicated in blue). Photo courtesy of 

Google Earth.

A bus prepares to undergo testing at the Renewable Fuel and 

Lubricants Laboratory. Photo by John Ireland, NREL 17948
16 Environmental Management System and Pollution Prevention

Aerial view of the Research Support Facility, including 

rooftop solar panels. Photo by Dennis Schroeder, NREL 21794

2 ENVIRONMENTAL 

MANAGEMENT 

SYSTEM AND 

POLLUTION 

PREVENTION

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 

sustainability practices.

ISO 14001: 2015 Certification

NREL’s EMS is certified to the International 

Organization for Standardization (ISO) 14001:2015 

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.
Environmental Management System and Pollution Prevention 17

2.1 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 commitment

– Continual improvement of environmental and 

sustainability performance.

• Environmental aspects – NREL’s environmental aspects 

(see Figure 2) are those activities, products, or services that 

are identified annually and 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 Environment, Safety, Health, 

and Quality (ESH&Q) 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 is necessary to achieve NREL’s environmental goals. 

The laboratory plans, implements, monitors, and reports on 

environmental stewardship goals and actions to generate 

continual improvement. (For more details, see section 2.3.)

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 including community meetings, lunch-and-learn 

events, publicly 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 ESH&Q 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.

ASPECTS

Community

Air

emissions

Surface water

and groundwater

discharges

Wastewater

releases

Waste generation

and management

Resource use 

or conservation

(energy, water, land,

biological, cultural)

Figure 2. NREL’s environmental aspects

Define Scope

Analyze

H

a

zards,

Perform Work

Develop Controls

Feedback &

Improvement

Environment

Quality Safety

Impacts

& Issues

Figure 1. NREL’s continual improvement cycle
18 Environmental Management System and Pollution Prevention

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 2.4.)

Management Review

• Management Review – NREL’s management review

the EMS regularly to provide feedback and direction to 

continually improve the environmental performance

of the organization.

2.2 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. 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. 

2.3 Performance Indicators 

and Progress 

Each year measurable goals for environmental improvement 

are developed. Goals are identified in the following documents:

• Performance Evaluation and Measurement Plan – The 

Performance Evaluation and Measurement Plan establishes 

key priorities and provides specific objectives, expected 

outcomes, and measures of performance for managing and 

operating NREL. Each fiscal year, the laboratory and the DOE 

Golden Field Office collaborate to develop the performance 

objectives.

• Site Sustainability Plan – NREL develops a Site Sustainability 

Plan each year to establish sustainability performance 

commitments 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 3.1, 

Sustainability Goals.

Goals are owned by individuals and groups throughout the 

laboratory. Progress on each goal is tracked throughout the year 

and results are reported annually. Some examples of performance 

related to these goals in 2017 are described in Table 1.

NREL encourages its employees to use alternative transportation 

methods by providing public transportation passes, shuttle 

bus connections to local transit stations, vanpools, ride-sharing 

information, and numerous bike racks. Such practices contribute 

toward management of NREL’s environmental aspects, in this case, 

reducing air emissions. Photo by Dennis Schroeder, NREL 30466

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 or take 

alternative transportation, and supporting webbased meetings to reduce traffic, air pollution, and 

health effects on surrounding communities

• Using sustainable, low-energy, and low-water use 

designs for buildings to reduce greenhouse gas 

emissions and use of Colorado’s limited water 

supplies

• Performing waste audits in facilities to improve 

diversion of materials from the waste stream to 

recycling/reuse streams.
Environmental Management System and Pollution Prevention 19

Table 1. 2017 Environmental Goals and Achievements

2017 Goals 2017 Examples Goal Met?

Develop a final plan for Section 106 

Programmatic Agreement with

the Colorado State Historic 

Preservation Office

Completed a project plan identifying the general process, requirements, 

and milestones to develop the Programmatic Agreement 

Yes

Deliver an Efficient and

Effective Environmental 

Management Program

Identified risks and modified practices including:

• Infrastructure and research equipment replacement process 

enhancements

• Site Operations backflow prevention recordkeeping improvements

• Continued spill response training for shuttle drivers

• Assisted Site Operations with mentoring contractors to address 

stormwater deficiencies

Monitored proposed and final regulations and adherence to requirements 

including:

• Hazardous Waste Generator Improvement Rule

• Protection of Stratospheric Ozone

• EPA air quality operating standards for small boilers

• 2017 EPA Construction Stormwater General Permit

Completed inspections and assessments including:

• Air inspection by Jefferson County

• Aboveground storage tank inspection by Department of

Public Safety

• Internal assessment, Cultural Resources

• Internal assessment, Pest Management

• Independent assessment, Air Quality

• Conservation area early summer and fall inspections

• Wildlife and vegetation surveys

Took actions to protect and enhance habitat and the natural

environment including:

• Installed six new nest boxes for woodpeckers and Barn Swallows

• Revised the site seed mixes to include pollinator plant species

• Delayed activities at the High Flux Solar Furnace facility to protect

a resident bee hive 

• Provided snake handling and safety training to Security staff

• Restricted access to areas to protect fledgling birds

Collaborated to integrate environmental considerations in project 

planning including:

• S&TF clean room and waste neutralization

• NWTC electrical upgrades

• IBRF spill planning

Yes
20 Environmental Management System and Pollution Prevention

2.4 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 – Internal assessments are performed 

regularly to evaluate consistency of the EMS with the ISO 

14001 standard, legal, and other requirements.

• External assessment – Periodically, external third-party 

assessments may be conducted by technical experts for 

specific components of environmental 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.

The following assessment activities took place in 2017 and 

have allowed NREL to enhance program effectiveness and 

make substantial environmental performance improvements:

• Internal assessments – Three internal assessments of 

processes were completed for the following topics: air quality 

management, cultural resources management, and pesticide 

Seats of a historical amphitheater at the STM site. An internal 

assessment of the laboratory’s management of cultural resources 

identified three opportunities for improvement. Photo by David Parsons, 

NREL 06922

2017 Goals 2017 Examples Goal Met?

Ensure procedures and controls 

are in place and implemented 

to comply with environmental 

regulatory requirements

Staff attended trainings and webinars to continue to sharpen skills and 

maintain awareness of emerging requirements and best practices

Actively managed noxious weeds

Tracked criteria air pollutants and greenhouse gases to evaluate 

permitting requirements (annual air emission inventory report and 

Mandatory Reporting Rule report)

Completed inspections of all STM site and NWTC petroleum drums and 

storage areas to verify conformance to spill prevention, control, and 

countermeasure requirements 

Provided annual Spill Response and Awareness training to NREL and 

contracted shuttle drivers 

Yes

Maintain and implement 

continuous improvement of

ISO 14001 management system

Successfully achieved ISO14001:2015 upgrade certification as evidence 

of management system compliance to international standards. 

Implemented all corrective actions from the prior year’s ISO audit.

Yes
Environmental Management System and Pollution Prevention 21

management. Each assessment involved interviews with staff 

and reviews of relevant procedures and records. The air quality 

management assessment resulted in no non-conformities 

or opportunities for improvement. Three opportunities for 

improvement, which were identified in the cultural resources 

management assessment regarding operational planning and 

control and documented information, have been addressed. 

The pesticide management assessment resulted in four nonconformities regarding document control and operational 

planning and control; actions to address the non-conformities 

are underway.

• External assessments – NREL underwent a recertification 

assessment to verify conformance to the ISO 14001:2015 

standard. The assessment was conducted by a team of 

external auditors and included visits to a number of the 

Benefits of the EMS to NREL

Reduced risk to facility/organizational mission

NREL’s Hazard Identification and Control Program 

incorporates environmental risk assessment. System 

improvements also support the use of requirements 

to reduce the risk of non-compliance 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; 

sustainability 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 betterment of the organization’s 

environmental footprint

Staff members are empowered to reduce the laboratory’s 

environmental footprint by participating in programs and 

events for recycling single-stream materials, batteries, 

electronic equipment, and shredded paper, as well as 

a composting program. The Be the Change program 

encourages individuals to suggest changes to improve the 

environment and sustainability of the laboratory.

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, training, 

inspections, and risk assessments.

Integration of environment into real

property asset management

NREL includes environmental considerations into longterm 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, and 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. 
22 Environmental Management System and Pollution Prevention

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 11 system strengths, three non-conformities, and four 

opportunities for improvement. Corrective actions addressing 

each of the non-conformities have been completed.

2.5 2017 Awards and Recognition

In 2017, NREL received several awards and recognition of its 

environmental and sustainability achievements including: 

• Green Electronics Council Electronic Product Environmental 

Assessment Tool (EPEAT) Purchaser Award

• Colorado Environmental Leadership Program

Gold-Level Leader

• 2017 Presidential Migratory Bird Federal Stewardship

Award – DOE Nomination Honorable Mention.

Green Electronics Council Award

In 2017, NREL received the Three-Star EPEAT Purchaser Award 

from the Green Electronics Council for 2016 EPEAT purchases. 

NREL is committed to the purchase of products designated 

by EPEAT, ENERGY STAR, and the Federal Energy Management 

Program, wherever feasible, to continue to positively impact 

the environment through these purchases.

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 

(CDPHE) and participating private and public Colorado

facilities, and is intended to recognize environmental

leadership and performance.

In early 2004, NREL was the first laboratory accepted into 

the program as a Gold-Level Leader and it has maintained 

this leadership level ever since. As a component of program 

membership, NREL’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 the 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/environmentalleadership-program.

2017 Presidential Migratory Bird 

Federal Stewardship Award –

DOE Nomination Honorable Mention

In 2017, NREL and the Golden Field Office received an 

honorable mention from DOE for the 2017 Presidential 

Migratory Bird Federal Stewardship Award. This award program 

annually recognizes a single project or action conducted by 

or in partnership with a federal agency that meets the intent 

and spirit of Executive Order 13186, Responsibilities of Federal 

Agencies to Protect Migratory Birds, by focusing on migratory 

bird conservation. The laboratory’s nomination, entitled NREL 

Migratory Bird Conservation Planning and Building Retrofits, 

described its comprehensive program for the conservation of 

migratory birds on its 327-acre STM site and the 305-acre NWTC 

using a four-pronged approach which included:

1. Development of a Migratory Bird Conservation Plan

2. Requiring nesting bird surveys for projects with potential 

impacts to birds

3. Incorporating bird friendly design for new facilities, and

4. Retrofitting buildings having impacts to birds from

window collisions.

2017 Colorado Environmental Leadership Program event. 

Photo courtesy of CELP, NREL 50128
Environmental Management System and Pollution Prevention 23

2.6 Integrated Environmental 

Stewardship in Construction 

Management

NREL designs, builds, and refurbishes facilities using an 

integrated approach that allows the laboratory to achieve 

mission needs while addressing environmental, safety, health, 

and community considerations. 

Project Planning and Design 

An interdisciplinary team, composed of members of the 

laboratory’s research, facilities and operations, and DOE Golden 

Field Office staff, collaborates on projects beginning with 

conceptual planning and selection of design, and continuing 

through construction. Project staff facilitates the identification 

and inclusion of environmental and sustainable requirements, 

and best management practices into the project design.

In 2017, a new structure was designed at the NWTC for 

roadway deicing material storage. The structure, which will 

be completed in 2018, will include an adjacent stormwater 

detention basin seeded with salt-tolerant and salt-absorbing 

grasses to filter snowmelt runoff and consequently protect 

groundwater quality.

Environmentally Responsible 

Construction Practices

During construction, DOE and NREL staff participate in weekly 

construction team meetings, monitor performance criteria, 

and provide ongoing feedback to the project team regarding 

environmental management. Environmentally responsible 

construction practices include reviewing pre-construction 

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, tracking waste diversion, 

properly storing hazardous materials, and controlling dust.

Minimizing impacts to wildlife is a consideration for all 

construction projects. During 2017 this was demonstrated by 

providing numerous ramps to facilitate egress of mammals 

that may have entered trenches constructed as part of a large 

electrical upgrade project at the NWTC. 

Benefits of the EMS to the Environment

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 environment, safety, health, and 

quality management helps make NREL a safer, more 

environmentally responsible workplace and enhances the 

quality of our work processes.

Pollution prevention

Staff regularly identifies opportunities to prevent 

pollution through NREL’s hazard identification and 

control process. Resources are dedicated to 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 on site 

contribute toward improved air quality. NREL continually 

strives to protect water quality onsite and offsite 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. 

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 on site. This in turn minimizes the generation of 

hazardous waste. The laboratory has averaged higher than 

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 and fuel

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.
24 Environmental Management System and Pollution Prevention

An integrated project team consisting of representatives from 

various departments within NREL, together with construction 

contractors, attend a weekly meeting to discuss an electrical 

upgrade project at the NWTC. Photo by Genevieve Braus, NREL 50127

2017 Accomplishments And Highlights

• NREL successfully transitioned to the new 2015 

version of the ISO 14001 standard. An external 

third-party assessment verified that the laboratory 

meets the requirements of the standard and 

demonstrates our commitment to environmental 

stewardship.

• Three internal assessments were completed, 

covering the following programs: air quality 

management, cultural resources management, 

and pesticide management. The air quality 

management assessment resulted in no nonconformities or opportunities for improvement. 

Three opportunities for improvement that were 

identified in the cultural resources management 

assessment regarding operational planning and 

control and documented information have been 

addressed. The pesticide management assessment 

resulted in four non-conformities regarding 

document control and operational planning and 

control; actions to address the non-conformities 

are underway.
Sustainability 25

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. In all site development, opportunities to 

integrate energy efficiency and renewable energy, highperformance buildings, and sustainable transportation options 

are sought. NREL’s commitment to sustainability supports 

the laboratory’s success by applying what is learned through 

research and development to site facilities and infrastructure 

systems.

3.1 Sustainability Goals

In accordance with DOE Order 436.1, Departmental 

Sustainability, a Site Sustainability Plan is developed each 

year 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.

To meet DOE sustainability performance goals, sustainability 

considerations are incorporated into operations including: 

• Energy, water, and waste management

• Building design, construction, and ongoing maintenance

• Environmental management planning

• Climate change resilience planning

• Measurement and tracking of environmental objectives,

targets, and actions

• Awareness and engagement of staff and

community members.

Table 2 summarizes DOE’s 2017 performance in meeting its 

sustainability goals at NREL.

3 SUSTAINABILITY

NREL staff participate in the annual Bike to Work Day 

event, whose goal is to encourage people to try their 

bikes as an alternative means of transportation on a 

consistent basis thereby reducing traffic congestion and 

improving air quality. Photo by Dennis Schroeder, NREL 45460
26 Sustainability

Table 2. Sustainability Goals and Performance Summary

DOE Goal Current Performance Status

Multiple Categories

50% Scope 1 & 2 greenhouse gas (GHG) emissionsa

reduction by FY 2025 from a FY 2008 baseline.

95.8% reduction On Track to

Meet Goal

25% Scope 3 GHG emissionsb reduction by FY 2025 

from a FY 2008 baseline.

20.5% reduction On Track to

Meet Goal

Energy Management

25% energy intensity (British thermal unit per gross 

square foot) reduction in goal-subject buildings by FY 

2025 from a FY 2015 baseline

7.9% reduction On Track to

Meet Goal

Energy Independence and Security Act, Section 

432 continuous (4-year cycle) energy and water 

evaluations

Conducted energy and water audits at the Education 

Center, East Site Entrance building, Science and 

Technology Facility, and Shipping and Receiving building

On Track to

Meet Goal

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 to

Meet Goal

Water Management

36% potable water intensity (gallon per gross square 

foot) reduction by FY 2025 from a FY 2007 baseline

28.9% reduction On Track to

Meet Goal

30% water consumption reduction of industrial, 

landscaping and agricultural (ILA) water by FY 2025 

from a FY 2010 baseline

NREL does not use ILA water N/A

Waste Management

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

excluding construction and demolition debris

63.9% diversion Target Met

Divert at least 50% of construction and demolition 

materials and debris

88.7% diversion Target Met

a

 Scope 1 and 2 emissions are defined as follows:

Scope 1 emissions (Direct GHG) – emissions from sources that are owned or controlled by an organization. Examples of sources at NREL include fuel used for 

comfort heating equipment, fleet vehicle gasoline or other fuels, and some cryogenic materials used in laboratory experimental processes. 

Scope 2 emissions (Energy Indirect GHG) – emissions from the consumption of purchased electricity, steam or other sources of energy generated upstream 

from an organization. Examples of sources at NREL include grid electricity used to power buildings and laboratory experiments.

b

 Scope 3 emissions (Other Indirect GHG) – emissions that are a consequence of the operations of an organization but are not directly owned or controlled by 

the organization. Examples of sources at NREL include fuel use associated with employee commuting and business travel, and waste sent to the landfill.
Sustainability 27

DOE Goal Current Performance Status

Fleet Management

30% reduction in fleet-wide per-mile GHG emissions 

reduction by FY 2025 from a FY 2014 baseline

27.5% reduction On Track to

Meet Target

20% reduction in annual petroleum consumption by 

FY 2015 relative to a FY 2005 baseline; maintain 20% 

reduction thereafter

19% reduction Did not meet

20% reduction

for current year

10% increase in annual alternative fuel consumption 

by FY 2015 relative to a FY 2005 baseline; maintain 

10% increase thereafter

33.1% increase Target Met

75% of light-duty vehicle acquisitions must consist of 

alternative fuel vehicles (AFV)

No light-duty vehicles were acquired N/A

50% of passenger vehicle acquisitions consist of zero 

emission or plug-in hybrid electric vehicles by FY 2025

No passenger vehicles were acquired; NREL does not 

currently have or plan to procure any vehicles classified

as passenger vehicles

N/A

Clean & Renewable Energy

“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 25% by FY 2025 and each year thereafter

104% renewable and alternate energy use On Track to

Meet Target

“Renewable Electric Energy” is required to account 

for not less than 30% of a total agency electric 

consumption by FY 2025 and each year thereafter

133.2% renewable electric energy consumption On Track to

Meet Target

Green Buildings

At least 17% (by building count) of existing buildings 

greater than 5,000 gross square feet to be compliant 

with the revised Guiding Principles for HighPerformance and Sustainable Buildings (HPSB) by FY 

2025, with progress to 100% thereafter

33.3% meet HPSB guidelines On Track to

Meet Target

Net Zero Buildings: 1% of the site’s existing buildings 

above 5,000 gross square feet intended to be energy, 

waste, or water net-zero buildings by FY 2025

Two buildings (11%) of eligible buildings are net

zero energy

On Track to

Meet Target

Net Zero Buildings: All new buildings (>5,000 gross 

square feet) entering the planning process designed 

to achieve energy net-zero beginning in FY 2020

All new NREL buildings entering the planning process will 

be designed to achieve energy net-zero where feasible

On Track to

Meet Target
28 Sustainability

DOE Goal Current Performance Status

Green Buildings

Increase regional and local planning coordination 

and involvement

Participated in regional events to promote alternative 

commuting including Bike to Work Day and GoTober

Hosted an electric autonomous shuttle demonstration 

and invited local businesses and municipalities to attend

Contributed to the Colorado governor’s Climate Resilience 

Working Group

Target Met

Acquisition & Procurement

Promote sustainable acquisition and procurement 

to the maximum extent practicable, ensuring 

BioPreferred and biobased provisions and clauses are 

included in 95% of applicable contracts

100% sustainable acquisition and procurement Target Met

Measures, Funding, & Training

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

Continued to utilize other funding options such as 

renewable energy credit sales and utility rebates

Target Met

Electronic Stewardship

Purchases – 95% of eligible acquisitions each year are 

EPEAT-registered products

99.1% EPEAT-registered products Target Met

Power management – 100% of eligible PCs, laptops, 

and monitors have power management enabled

100% power management enabled Target Met

Automatic duplexing – 100% of eligible computers 

and imaging equipment have automatic duplexing 

enabled

100% automatic duplexing enabled Target Met

End of Life – 100% of used electronics are reused or 

recycled using environmentally sound disposition 

options each year

100% electronics reused or recycled Target Met

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

The RSF data center had an average PUE of 1.15

The high performance computing data center had an 

average PUE of 1.03

Target Met

Organizational Resilience

Discuss overall integration of climate resilience in 

emergency response, workforce, and operations 

procedures and protocols.

Added language to the telecommute policy to encourage 

staff to telecommute during adverse weather conditions

Installed a long range acoustical device to notify 

employees of hazards on the STM site

Investigated the installation of innovative sensors to 

monitor environmental conditions

Developed a power systems model to determine 

“islanding” requirements for the RSF data center

Target Met
Sustainability 29

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

3.2 Climate Change Adaptation 

Management

As the effects of climate change become 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.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements

• The laboratory continued to encourage staff to telecommute

during adverse weather conditions and updated the

telecommute policy to reflect this change

• The laboratory continued to support DOE’s Sustainability

Performance Office in developing guidance tools for climate

change resilience planning. Specifically, an instructional

tutorial was created to explain how DOE sites and offices can

conduct their own climate change resilience screenings.

• The laboratory continued to identify and implement

strategies, which stem from the findings of NREL’s Climate

Change Resilience study (2014), to increase climate

resilience. In FY2017 NREL:

– Installed a long-range acoustical device on the STM site

to notify employees and visitors of hazards, including 

inclement weather announcements

– Continued NREL’s Chief Operating Officer regular 

communications via email about seasonal weather events 

that could impact staff working schedules and ability to 

reach the sites

– Investigated the installation of innovative sensors that 

would deliver data to monitor air quality, weather 

conditions, water quality, and transportation patterns 

and issues to enhance the laboratory’s response plans to 

impactful conditions

– Developed a power systems model to determine 

requirements to isolate the RSF data center during 

extended power outages.

NREL employees can participate in ongoing research and charge 

their electric vehicles in the main parking garage. Researchers are 

developing methods to match electric vehicle charging requirements 

with solar PV generation. Photo by Matthew Staver, NREL 39225

2017 Accomplishments and Highlights

• As indicated in Table 2, NREL met all sustainability

goals set by DOE except the petroleum reduction

goal. Attainment of this goal will require replacing

some/all of NREL’s diesel shuttle buses with zeroemissions vehicles, for which funding and vehicle

options may not be available.

• The laboratory achieved third-party certification to

ISO 50001:2011 Energy Management.

• The laboratory continued development of the

intelligent campus platform, which delivers reliable

data metrics for building analytics to increase

energy efficiency across the laboratory. This

included the continued roll out of a fault detection

diagnostics software program.

• Through the retirement of legacy equipment

and upgrades to current IT equipment, NREL’s

already extremely energy efficient RSF data center

achieved a PUE of 1.15. PUE is the ratio of total

amount of energy used by a computer data center

to the energy delivered to computing equipment.

An ideal PUE is 1.0.

• In the Energy Systems Integration Facility, NREL

installed a thermosyphon on the high performance

computing data center, which significantly reduced

water consumption while maintaining a worldclass PUE rating of 1.03.
30 Compliance Summary

NREL is subject to many federal and state laws and 

regulations, as well as Executive and DOE Orders and 

memoranda of understanding with government agencies. 

By observing these rules and regulations, 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 more details, 

see Appendix B, Environmental Permits, Registrations, and 

Notifications)

4 COMPLIANCE 

SUMMARY

NREL researchers work to enhance the efficiency of 

quantum dot solar cells in converting sunlight to 

electricity. Photo by Werner Slocum, NREL 46864
Compliance Summary 31

Table 3. Federal, State, and Local Environmental Laws and Regulations and Compliance Status Applicable to NREL

Report 

Sections

Regulatory Program Description Compliance Status 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, 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

Executive Order 13693, Planning for 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 is certified to the ISO 14001:2015 

international standard for environmental 

management systems and has been certified 

to ISO 14001 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 13653, Preparing the United States for the 

Impacts of Climate Change, and DOE Order 436.1, 

Departmental Sustainability, 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. 

However, EO 13653 was rescinded on March 28, 

2017.

Program activities were in compliance

with requirements.

The laboratory continued to encourage staff 

to telecommute during adverse weather 

conditions and updated the telecommute

policy to reflect this change.

The laboratory continued to support DOE’s 

Sustainability Performance Office in developing 

guidance tools on climate change resilience 

planning. Specifically, created an instructional 

tutorial explaining how DOE sites and offices 

can conduct their own climate change resilience 

screenings.

The laboratory continued to identify and 

implement strategies, which stem from the 

findings of NREL’s Climate Change Resilience 

study (2014), to increase climate resilience.

Executive Orders:

EO 13653 

(rescinded)

EO 13693 

DOE:

DOE Order 436.1
32 Compliance Summary

Report 

Sections

Regulatory Program Description Compliance Status Regulator & 

Requirement

Air Quality The Air Pollution Control Division of Colorado 

Department of Public Health and Environment 

(CDPHE) administers the federal 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), ozonedepleting substances, and greenhouse gases.

For facilities and stationary sources that emit 

criteria air pollutants and hazardous air pollutants, 

there are both 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 EPA regulations to be tracked 

and reported if the emissions are greater than 

27,557 U.S. tons (25,000 metric tons [MT]) of 

carbon dioxide equivalent per year. The purpose 

of this reporting is to better identify the actual 

emissions of such gases across the United States 

and provide the EPA with data upon which to 

base future greenhouse gas regulations. 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.

Additionally, permits for major emissions sources 

(greater than 100 U.S. tons [90.7 MT] 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 MT) per year.

EPA’s Protection of Stratospheric Ozone (40 Code 

of Federal Regulations [CFR 82]) requires that 

servicing records must be kept for appliances 

containing more than 50 pounds (23 kilograms) 

of Class 1 or 2 Ozone Depleting Substances 

refrigerant.

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. State regulations require federal, state, and 

local government facilities to track street sanding in 

the winter and to minimize sand use.

Program activities were in compliance with 

requirements. NREL did not exceed any 

air permit standard or other air regulatory 

requirement at any facility.

An evaluation of hazardous air pollutant (HAP) 

emissions indicated that emissions for each 

individual facility were well below the reporting 

and permitting thresholds of 10 tons (9.1 MT) 

per year for each individual HAP or 25 tons (22.7 

MT) per year for all HAPs combined.

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 or the NWTC.

The laboratory evaluated carbon-dioxide 

equivalent (CO2e) and greenhouse gas 

emissions and concluded that they were below 

the federal reporting and permitting threshold 

of 27,500 tons (25,000 MT).

All equipment registrations, including annual 

registration renewals, for state-required 

ozone-depleting substances were completed 

for the STM site and the NWTC. Per federal 

requirements, refrigerant recovery equipment 

has also been registered with the EPA.

Two Air Pollutant Emission Notices for research 

power generators were renewed.

National 

Ambient 

Air Quality 

Standards:

40 CFR 50

Ozone Depleting 

Substances 

(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
Compliance Summary 33

Report 

Sections

Regulatory Program Description Compliance Status Regulator & 

Requirement

Drinking Water 

Quality

The federal Safe Drinking Water Act establishes 

minimum drinking water standards and monitoring 

requirements for drinking water supplies. Under 

this act, the EPA has established allowable levels 

for contaminants in drinking water known as 

maximum contaminant levels. 

The Water Quality Control Division of CDPHE 

implements the federal Safe Drinking Water Act in 

Colorado under authority delegated by the EPA.

Program activities were in compliance

with requirements.

All monitored parameters met applicable 

requirements.

Certified divers were contracted to perform 

inspections of the 2,000-gallon (7,580-liter) 

and 15,000-gallon (56,781-liter) fiberglass 

water storage tanks at the NWTC. Both tanks 

were found to be free of cracks and in overall 

good condition. These results were reported 

to the Water Quality Control Division of CDPHE 

in compliance with state drinking water 

requirements.

Water samples were collected at five drinking 

water taps at the NWTC and analyzed for lead 

and copper concentration. All lead sample 

results were below both the maximum 

allowable concentration in drinking water and 

below the limit at which the chemical analysis 

method can detect lead. Copper levels ranged 

from 0.060 mg/L to 0.338 mg/L, far below the 

maximum allowable concentration in drinking 

water of 1.3mg/L. These results were reported

to the Water Quality Control Division of CDPHE, 

as required.

The drinking water supply at the NWTC was 

interrupted on November 6, 2017, when a pipe 

within the distribution system burst. Repairs 

were made and water service was restored the 

same day. Water quality standards remained in 

compliance prior to and after the disruption

in service.

A total of 439,448 gallons (1,663,491 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. Permits are required for drinking 

water, geothermal, irrigation, livestock watering, 

dewatering, monitoring, and geothermal well 

installations.

Program activities were in compliance

with requirements.

Three groundwater wells installed immediately 

north of the Field Testing Laboratory Building in 

2015 continued to be monitored to determine 

if groundwater or surface water was responsible 

for seepage into the building that occurred 

under the north foundation wall.

CDPHE:

5 CCR 1002-41

2 CCR 402-2

2 CCR 402-10
34 Compliance Summary

Report 

Sections

Regulatory Program Description Compliance Status Regulator & 

Requirement

Surface Water 

Quality

Surface water quality is controlled through 

the federal Clean Water Act (CWA), Energy 

Independence and Security Act of 2007, EO 13693, 

Planning for Federal Sustainability in the Next Decade, 

and the Colorado Water Quality Control Act.

Stormwater discharges resulting from construction 

activities at federal facilities that disturb greater 

than one acre are administered in Colorado 

by the EPA. To obtain coverage under the EPA 

Construction General Permit for stormwater 

discharges, a site-specific Stormwater Pollution 

Prevention Plan must be prepared and a Notice of 

Intent must be filed with the EPA. 

The Water Quality Control Division within CDPHE 

regulates stormwater discharges at non-federal 

facilities within Colorado. For NREL construction 

projects that occur off federal property, a Colorado 

Discharge Permit System stormwater permit may 

be required.

The Energy Independence and Security Act 

requires federal agencies to reduce stormwater 

runoff from federal development projects to the 

maximum extent technically feasible. Stormwater 

runoff levels should reflect predevelopment 

hydrology, specifically with regard to runoff rate, 

volume, duration and water temperature. 

Agencies can comply by using low-impact design 

elements such as porous pavers, cisterns, and 

bioswales, or by retaining stormwater runoff and 

releasing it at predevelopment rates.

EO 13693, Planning for Federal Sustainability in the 

Next Decade, directs federal agencies to install 

appropriate green infrastructure features to 

improve stormwater management.

Program activities were in compliance

with requirements.

Permit coverage for an ongoing project at the 

STM site was transferred from the 2012 EPA 

Construction Permit to the EPA’s new 2017 

Construction General Permit, and later amended 

to reflect modified project scope and schedule.

Periodic stormwater inspections were 

performed at locations where earth-disturbing 

activities occurred. The inspections and any 

resulting maintenance of structural stormwater 

erosion and sediment controls took place on 

construction sites operating under the EPA 

Construction General Permit, as well as smaller 

areas where permit coverage is not required but 

where stormwater best management practices 

are followed.

EPA Region 8 representatives visited the STM 

site at NREL’s request to provide clarification 

on stormwater Construction General Permit 

requirements. The EPA expressed approval 

of NREL’s stormwater management and their 

confidence in NREL’s protection of downstream 

surface water quality.

EPA:

40 CFR 122.26

CDPHE:

5 CCR 1002-61

Regs. 38, 61, 65, 

and 93

Executive Order:

EO 13693

Wastewater Wastewater is regulated at the federal level under 

the Clean Water Act and at the state level under the 

Colorado Water Quality Control Act by the Water 

Quality Control Division of CDPHE.

The Metro Wastewater and Reclamation District 

(Metro District) manages wastewater at its 

treatment plant per federal and state requirements. 

Domestic and non-domestic wastewater flows 

are delivered to the Metro District’s plant via 

conveyance systems owned, operated, and 

regulated by numerous sanitation districts.

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.

Onsite septic systems are regulated by the CDPHE 

Water Quality Control Division. Inspection and 

permitting of individual sewage disposal systems 

have been delegated to Jefferson County by 

CDPHE.

Program activities were in compliance

with requirements.

The Metro Wastewater Reclamation District 

and Pleasant View Water and Sanitation District 

visited the STM site to tour current research 

operations that discharge to the sanitary sewer 

and to discuss reporting requirements.

EPA:

40 CFR 122-136

CDPHE:

5 CCR 1002-62, 

63
Compliance Summary 35

Report 

Sections

Regulatory Program Description Compliance Status Regulator & 

Requirement

Hazardous 

Materials 

Management

Hazardous material management is regulated 

at the federal level through the Superfund 

Amendments and Reauthorization Act Title 

III, which is also known as the EPCRA of 1986. 

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 release of hazardous chemicals to 

federal, state, and local governments. NREL facilities 

are subject to Sections 302, 304, 311, 312, and 313 

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 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 for chemicals 

that are stored on site in quantities greater than 

regulatory thresholds. In addition, NREL provides 

inventory reporting for these chemicals in an 

annual hazardous materials report, called a Tier 

II report, to state and local emergency response 

agencies and local fire departments.

EPCRA Section 313 requires that a toxic chemical 

release inventory report be filed with the EPA 

in the event of a release for any chemical that is 

manufactured, processed, or otherwise used in 

quantities exceeding regulatory thresholds.

Annual hazardous materials permits are required 

by West Metro Fire Rescue for the STM site and 

Denver West Office Park. 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, located within the City and County of 

Denver, is subject to the Denver Fire Department’s 

Hazardous Materials Information System 

requirements including permitting, inventory, and 

annual inspection. This facility’s inventory of listed 

materials, including various fuels such as biodiesel, 

must be reported to the Denver Fire Department 

annually.

Hazardous materials permits are currently not 

required at the NWTC or the Joyce Street Facility.

Program activities were in compliance

with requirements.

There were no releases of hazardous materials 

that required reporting. In accordance with DOE 

requirements, NREL screened selected chemicals 

to confirm that quantities fell below those 

requiring elevated operational protocols.

EPCRA Tier II hazardous materials reports 

were submitted for two facilities for reporting 

year 2017. The reports help state and local 

emergency response and planning agencies 

and local fire departments plan for chemical 

emergencies. Chemicals reported include diesel 

fuel, petroleum oil, and sulfuric acid contained in 

sealed lead-acid batteries.

The Denver Fire Department issued a hazardous 

materials permit for the Renewable Fuels and 

Lubricants Research Laboratory.

EPA:

40 CFR 355, 370, 

372

Executive Order:

EO 13693

DOE:

DOE Order 

151.1D
36 Compliance Summary

Report 

Sections

Regulatory Program Description Compliance Status Regulator & 

Requirement

Hazardous 

Waste 

Management

The Resource Conservation and Recovery Act 

established requirements for the management 

of regulated waste, including hazardous waste. 

In Colorado, the Hazardous Materials and Waste 

Management Division of CDPHE administers 

requirements under authority delegated by 

the EPA. Additional 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 

the 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 hazardous waste 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 

Conditionally Exempt Small Quantity Generator 

category because they generate minimal amounts 

of hazardous waste per calendar month. The STM 

site typically produces quantities of hazardous 

waste well within the Small Quantity Generator 

category; however, due to pilot-scale research 

experiments, the STM site can episodically elevate 

to the Large Quantity Generator category in one or 

more months during the year.

Program activities were in compliance

with requirements.

Nineteen hazardous and 12 universal waste 

shipments for offsite disposal and recycling were 

made across NREL’s five sites.

Mandatory employee training on hazardous and 

universal waste management was completed in 

compliance with state and federal regulations.

All regulatory notifications were submitted and 

applicable waste generator fees were paid.

EPA:

40 CFR 260- 280

CDPHE:

6 CCR 1007-3

Aboveground 

Storage Tank 

Management

Aboveground storage tanks (AST) are regulated in 

Colorado by the Colorado Department of Labor 

and Employment’s (CDLE) Division of Oil and Public 

Safety (DOPS) under the Colorado Aboveground 

Storage Tank regulation. 

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

or larger must be permitted prior to installation, 

inspected by the state following installation, 

registered with the state within 30 days following 

commencement of use, and registration renewals 

submitted annually thereafter.

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.

Program activities were in compliance

with requirements.

All tanks were inspected to confirm continued 

adherence to state of Colorado regulations.

Annual AST training was provided to 26 staff 

members identified as having responsibility 

for operating and fueling ASTs or performing 

oversight for tank safety and environmental 

compliance.

Eight ASTs were painted as part of a tank 

maintenance effort.

CDLE:

DOPS Storage 

Tank Regulations

7 CCR 1101-14

Rocky Mountain 

Fire Protection 

District, West 

Metro Fire 

Protection 

District: 

International Fire 

Code, Sections 

5003.5 and 

5704.2.3.2; 

National Fire 

Protection 

Association 704 

(2012 Ed.)
Compliance Summary 37

Report 

Sections

Regulatory Program Description Compliance Status Regulator & 

Requirement

Spill 

Prevention 

and Response

Oil spill prevention and response is managed at 

the federal level under the Oil Pollution Prevention 

Act and Clean Water Act, and at the state level 

under Colorado Storage Tank Regulations as 

implemented by DOPS.

Spill Prevention, Control, and Countermeasures 

(SPCC) plans are required by EPA and Colorado 

regulations 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 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 purpose of the SPCC plan is to prevent the 

discharge of oil and hazardous substances, and 

minimize the impact of such spills to adjacent 

waterways.

Program activities were in compliance

with requirements.

No reportable spills occurred. Nine minor spills 

of diesel, lubricant, coolant, and hydraulic fluids 

occurred at the STM site, and no spills occurred 

at the NWTC. The size of spills ranged from less 

than 0.1 gallon to 4 gallons (0.38 to 16 liters), 

with a total quantity of 7.6 gallons (28 liters). 

Eighty percent of these spills were from vehicles 

and mobile equipment and occurred on paved 

surfaces. Each spill received immediate remedial 

action and there was no significant impact to 

the environment.

The SPCC training required annually of all 

workers who manage fuel storage tanks was 

revised to include an updated spill history.

EPA:

Oil Pollution 

Prevention 

40 CFR 112

CWA Section 319

CDLE:

DOPS Storage 

Tank Regulations,

7 CCR 1101-14

CWCC:

25-8-205 CRS.

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. These facilities, including 

NREL, must annually demonstrate compliance with 

EPA radiological air standards that limit emissions 

to amounts that would prevent any member of the 

public from receiving an effective dose equivalent 

of 10 mrem per year or greater.

Program activities were in compliance

with requirements.

Only small quantities (less than 1 cubic yard [0.76 

cubic meter]) of low-level radioactive waste are 

currently in storage awaiting off-site disposal.

A ventilation exhaust hood was removed during 

decommissioning of the laboratory’s only 

low-level radioactive work area. Radiological 

sampling indicated the hood was within limits 

for release and would not pose a hazard to 

workers, the public, or the environment.

However, the hood was placed in the metal 

recycle bin without following established 

internal procedures. An event investigation 

was completed and the following corrective 

actions identified: (1) modify the work control 

process to eliminate multiple-copy work orders 

and prominently identify special instructions, 

and (2) mark as-built facility drawings to 

communicate prior radiological use and identify 

the need for special instructions for future facility 

modifications.

In accordance with a federal regulation and DOE 

Order, NREL submitted its annual Radionuclide Air 

Emissions Annual Report to the EPA confirming 

that the laboratory is in compliance with air 

emissions standards. For calendar year 2017, 

the effective dose equivalent of radiation to the 

public was 0.045 millirem (mrem) per year, far 

below the 10 mrem per year limit.

EPA:

40 CFR 61, 

Subpart H

DOE:

DOE Order 458.1
38 Compliance Summary

Report 

Sections

Regulatory Program Description Compliance Status Regulator & 

Requirement

National 

Environmental 

Policy Act 

The National Environmental Policy Act (NEPA) 

requires that federal agencies analyze and disclose 

the potential environmental impacts of proposed 

federal actions and alternatives as part of its 

decision-making process. 

DOE regulations and orders establish how NEPA 

is implemented for DOE, and the Council on 

Environmental Quality reviews and approves 

federal agency NEPA procedures. 

Under NEPA, DOE considers the potential impacts 

to the environment, including natural, social, and 

economic factors to determine the appropriate 

level of review for a proposed action. These include 

categorical exclusions, environmental assessments 

and environmental impact statements.

Program activities were in compliance

with requirements.

A total of 159 documented environmental 

evaluations were completed; 132 actions

were covered by a Programmatic NEPA 

Determination; and 27 actions were submitted 

to DOE for review.

Quarterly monitoring of the NEPA program was 

conducted to confirm that the appropriate 

level of NEPA evaluation (either application of 

a Programmatic NEPA Determination or review 

by DOE) was completed for maintenance, 

contracting, and purchasing activities. Results 

indicate that established procedures are 

effective, and proposed activities received the 

appropriate level of review.

Council on

Environmental 

Quality:

40 CFR

1500-1508

DOE:

10 CFR 1021

Wildlife 

Management

The Migratory Bird Treaty Act (MBTA) of 1918, as 

implemented by the U.S. Fish and Wildlife Service, 

and the Damage or Destruction of Dens or Nests–

Harassment of Wildlife statute as administered by 

the Colorado Division of Parks and Wildlife, manage 

the protection of migratory birds. 

The MBTA and its amendments implement several 

treaties between the United States, Great Britain, 

Mexico, Japan, and the former Soviet Union. The 

MBTA prohibits the taking, killing, or possession of 

migratory birds, nests, and eggs. 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.

Within the state of Colorado, 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.

Under the Presidential Memorandum, “Creating a 

Federal Strategy to Promote the Health of Honey 

Bees and Other Pollinators,” a Pollinator Health Task 

Force was created to develop a National Pollinator 

Health Strategy to enhance pollinator habitat 

on federally managed lands and facilities, and 

incorporate pollinator health as a component of all 

future restoration and reclamation projects. 

Program activities were in compliance

with requirements.

Ground-nesting-bird surveys were conducted 

prior to annual mowing and weed control 

operations at the NWTC in conformance with 

the Migratory Bird Treaty Act. A Vesper Sparrow 

(Pooecetes gramineus) nest was found and 

cordoned off; mowing was delayed in that area 

until it was clear that the eggs had hatched and 

the young had permanently left the nest.

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

Presidential 

Memorandum 

– Creating a 

Federal Strategy 

to Promote the 

Health of Honey 

Bees and Other 

Pollinators
Compliance Summary 39

Report 

Sections

Regulatory Program Description Compliance Status Regulator & 

Requirement

Endangered 

Species and 

Species of 

Concern

The Endangered Species Act (ESA), jointly 

administered by the U.S. Fish and Wildlife Service 

and the National Marine Fisheries Service, protects 

threatened and endangered wildlife and plant 

species and associated critical habitat.

Federal agencies are required to abide by the 

Endangered Species Act to ensure that their 

actions do not adversely affect species that are 

federally listed under the Act as threatened, 

endangered, or candidate species.

Additional federal and state laws and regulations 

protect wildlife, such as the Bald and Golden Eagle 

Protection Act.

DOE’s formal consultation with the U.S. Fish 

and Wildlife Service for the 2014 site-wide 

environmental assessments for the STM site and 

NWTC resulted in an agreed-upon threshold for 

water usage to limit impacts to the Platte River 

system.

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 is not 

regulatory in nature but is unique in that it is the 

only designation besides the Endangered Species 

Act that considers rare plants.

Program activities were in compliance

with requirements.

No activities were conducted in designated 

critical habitat for the federally threatened 

Preble’s meadow jumping mouse (Zapus 

hudsonius preblei).

The 23.9 million gallons (90.6 million liters) of 

water used at the STM site and the NWTC were 

reported to the U.S. Fish and Wildlife Service and 

fell below the agreed-upon limit of 39.5 million 

gallons (149.7 million liters) per year.

U.S. Fish and 

Wildlife Service:

50 CFR 17

Colorado 

Division of Parks 

and Wildlife:

2 CCR 406-10, 

Article 2 and 3 
40 Compliance Summary

Report 

Sections

Regulatory Program Description Compliance Status Regulator & 

Requirement

Vegetation 

Management

The Federal Insecticide, Fungicide, and Rodenticide 

Act, as implemented by the EPA, 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.

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.

EO 13112, Invasive Species, requires the control of 

invasive species at federal facilities.

Program activities were in compliance

with requirements.

At the NWTC, herbicides were applied to 

approximately 345 acres (140 hectares) to 

control B- and C-listed weeds in May and June, 

as well as 10 acres (4 hectares) in September.

At the STM site, herbicides were applied 

to control A-, B-, and C-listed weeds to 

approximately 40 acres (16 hectares) in April and 

May, including applications on the mesa top 

conservation easement; 12 acres (5 hectares) in 

June; and 5 acres (2 hectares) in August.

NREL biologists introduced bindweed mites to 

combat bindweed on the STM site. Biological 

control specimens were provided by the 

Colorado Department of Agriculture State 

Insectary in Palisade, Colorado.

The north and west sides of the RSF building 

were sprayed with a half-strength solution 

of Roundup®. This mixture selectively targets 

cheatgrass, a List-C noxious weed, that is first to 

emerge from dormancy in the late winter. Over 

the past three years this technique has increased 

the productivity of native grasses around the 

building.

Herbicides were applied in April and May to a 

large tract (32 acres [13 hectares]) of grassland 

within the STM site conservation easement. 

The application targeted cheatgrass, dalmatian 

toadflax, and thistle.

Russian olive trees were identified and mapped 

on the STM site during a natural resource 

inspection. The trees were treated with Roundup 

after girdling live branches, but a few tenacious 

trees are under consideration for “chainsaw 

treatment.”

Through consistent monitoring and working 

with the Colorado Department of Agriculture, 

two additional noxious weed species were 

identified at the NWTC: sulfur cinquefoil and 

moth mullein (Verbascum blattaria). The invasive 

sulfur cinquefoil was treated in 2017 and 

treatments will continue in 2018. The slowgrowing moth mullein will be incorporated in 

continuous plans to combat common mullein 

(Verbascum thapsus) as management practices 

for both species are similar.

One new APHIS permit for the import of Linum 

usitatissimum (otherwise known as flax or 

linseed) stems from Canada was obtained. Two 

permits expired for napier grass (Pennisetum 

purpureum), sugarcane (Saccharum officinarum) 

bagasse, and sugarcane leaves and plant tops.

Executive Order:

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)

Federal 

Insecticide, 

Fungicide, and 

Rodenticide Act 

7 USC 136 et seq.
Compliance Summary 41

Report 

Sections

Regulatory Program Description Compliance Status Regulator & 

Requirement

Wetlands and 

Floodplains

Wetlands became regulated under the 1972 

amendments to the Clean Water Act. Wetlands 

that meet certain soil, vegetation, and hydrologic 

criteria are protected under Section 404 of the 

CWA, which is administered by the U.S. Army Corps 

of Engineers (USACE) and the EPA.

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. 

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.

Counties protect floodplains by mapping the 100-

year floodplain boundaries within their jurisdiction 

in coordination with the Federal Emergency 

Management Agency. They then formulate 

regulations to control the type and amount of 

development within the designated boundary.

Jefferson County requires approval of development 

proposed in floodplains within its jurisdiction.

Program activities were in compliance

with requirements.

New wetlands were observed in stormwater 

detention basins and drainageways on the 

STM site during vegetation surveys. These new 

wetlands contribute to the overall acreage in 

Table 8.

USACE:

CWA Section 404

Executive Orders:

EO 11988

EO 11990

DOE:

10 CFR 1022

Cultural 

Resources

Cultural resources are protected under Sections 

106 and 110 of the National Historic Preservation 

Act, which is administered in Colorado by the 

Colorado Office of Archaeology & Historic 

Preservation (State Historic Preservation Officer).

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.

Program activities were in compliance

with requirements.

ESH&Q staff took baseline measurements of a 

crack in the STM ammunition igloo. The crack 

will be measured periodically to determine if the 

crack is expanding.

A cultural resource review was conducted for a 

portion of the NWTC along the northwestern 

corner of the site where future utility line 

projects will occur. No cultural resources were 

found.

Advisory Council 

on Historic 

Preservation:

36 CFR 60

36 CFR 63

36 CFR 79

36 CFR 800

16 U.S.C. 470

SHPO:

8 CCR 1504-7
42 Air Quality Protection

Good air quality is fundamental to the overall well-being 

of individuals and the environment. Each person inhales 

approximately 3,700 gallons (14,000 liters) of air per day, and 

contaminants that may be present can affect the individuals’ 

health. Air pollutants in the environment also can affect the 

vegetation, aquatic life, and wildlife that may be exposed to 

those pollutants.

NREL strives to protect air quality and the environment 

by minimizing air emissions from research and operations 

activities and employee commuting, tracking air emissions 

from the larger on site sources, and meeting federal and 

state air emissions and permitting requirements. Emitted 

air pollutants include criteria pollutants (carbon monoxide, 

nitrogen oxides, volatile organic compounds, particulate 

matter, and sulfur dioxide) and non-criteria pollutants 

(hazardous air pollutants, greenhouse gas compounds, 

and ozone-depleting substances). Minimizing air emissions 

generated by the laboratory contributes to the improvement 

of regional air quality, benefiting both neighbors immediately 

adjacent to the laboratory and those in the Denver 

metropolitan area. ESH&Q staff members participate in project 

planning, safety evaluations, start-up reviews, and operations 

activities to assure permit and regulatory compliance and 

address air quality considerations.

The primary sources of regulated pollutants at NREL are a result 

of fuel use, laboratory chemical use, and facility operations. 

Sources include process heat boilers, process cooling systems, 

comfort heating and cooling systems, standby generators, 

construction and maintenance equipment with gasoline or 

diesel engines, bench- and pilot-scale research activities using 

chemicals, and facility operations maintenance activities.

A summary of NREL facility estimated annual air pollutant 

emissions is included in Table 4.

Additional information regarding management of NREL’s air 

quality protection program can be found in Appendix A.

5 AIR QUALITY 

PROTECTION

Typical Renewable Fuel Heat Plant exhaust plume. 

The visible plume is moisture condensation and has a 

very low opacity level due to clean combustion and an 

efficient particulate removal system. Photo by Larry Durbin, 

NREL 50126
Air Quality Protection 43

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• An evaluation of hazardous air pollutant (HAP) emissions

indicated that emissions for each individual facility were well

below the reporting and permitting thresholds of 10 tons

(9.1 MT) per year for each individual HAP or 25 tons (22.7 MT)

per year for all HAPs combined.

• 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 or the NWTC.

• The laboratory evaluated carbon-dioxide equivalent (CO2e)

and greenhouse gas emissions and concluded that they

were below the federal reporting and permitting threshold

of 27,500 tons (25,000 MT).

• All equipment registrations, including annual registration

renewals, for state-required ozone-depleting substances

were completed for the STM site and the NWTC. Per federal

requirements, refrigerant recovery equipment has also been

registered with the EPA.

• Two Air Pollutant Emission Notices for research power

generators were renewed.

Table 4. STM Site, NWTC, and Denver West Office Park Estimated Annual Air Pollutant Emissions (in U.S. Tons [MT] Per Year)*

Year

CRITERIA POLLUTANTS GREENHOUSE GASES HAPs

CO NOx VOC PM10 SO2 CO2 CH4 N2O Total

2013 6.02 (5.46) 13.83 (12.55) 0.47 (0.42) 3.16 (2.87) 0.36 (0.32) 8,584 (7,787) 0.51 (0.46) 0.25 (0.23) 0.51 (0.46)

2014 6.25 (5.67) 14.68 (13.32) 0.48 (0.43) 3.90 (3.53) 0.45 (0.41) 9,299 (8,436) 0.55 (0.50) 0.30 (0.27) 0.62 (0.56)

2015 6.42 (5.82) 15.49 (14.05) 0.54 (0.49) 3.95 (3.58) 0.45 (0.41) 9,329 (8,463) 0.56 (0.51) 0.30 (0.27) 0.63 (0.57)

2016 5.73 (5.19) 12.94 (11.74) 2.05 (1.86) 1.61 (1.46) 0.16 (0.15) 7,066 (6,410) 0.31 (0.28) 0.15 (0.14) 0.28 (0.26)

2017 5.92 (5.37) 13.63 (12.37) 2.06 (1.87) 2.30 (2.09) 0.24 (0.22) 7,685 (6,972) 0.38 (0.34) 0.19 (0.17) 0.38 (0.35)

*Abbreviations: HAPs – hazardous air pollutants, CO – carbon monoxide, NOx – nitrogen oxides, VOC – volatile organic compounds, PM10 – respirable particulate 

matter less than 10 microns in diameter, SO2 – sulfur dioxide, CO2 – carbon dioxide, CH4 – methane, N2O – nitrous oxide

2017 Accomplishments and Highlights

• Fleet vehicle emissions were quantified as part of the 

ongoing effort to track laboratory air emissions and 

operational environmental impact. In the most recent 

period for which emissions have been quantified—

calendar year 2016—NREL operated 45 motor vehicles 

using a total of 43,266 gallons (163,799 liters) of E85 and 

diesel fuels and traveled a total of 260,870 miles (419,830 

km). This vehicle use resulted in the emission of 1.26 tons 

(1.14 MT) of CO, 0.18 tons (0.16 MT) of NOx and 0.04 tons 

(0.036 MT) of volatile organic compound.

• Cooling tower particulate emissions were quantified

and added to the 2017 air emission inventory. These

particulate emissions result from the evaporation of

cooling water mist allowing dissolved solids in the water

to enter the air. Fine particulate, which can cause health

impacts, is measured as PM10 and consists of particulates 

smaller than 10 microns in diameter. Total cooling tower 

emissions were calculated to be approximately 0.05 tons 

(0.045 MT) per year of PM10.

• An inventory of laboratory refrigerants used for both

research and operational activities was updated for use

in long-term compliance tracking.

• A Class II ozone-depleting substance in the amount of

140 pounds (64 kilograms) was recovered and recycled

during a chiller upgrade project. The replacement system

uses a non-ozone-depleting substance refrigerant.

• An internal assessment was completed; no nonconformities or opportunities for improvement

were identified.
44 Water Quality Protection

Water quality is critical to human health and the health of 

our natural ecosystems. Water quality protection at NREL falls 

within four main areas:

• Drinking water

• Groundwater

• Surface water

• Wastewater.

Additional information regarding program management for 

each of these four areas can be found in Appendix A.

6.1 Drinking Water

The STM site and the NWTC are provided with potable drinking 

water by two different means. The 2,200 staff members at the 

STM site are serviced by a municipal public water supplier, 

Consolidated Mutual Water Company, whose source water is 

primarily stormwater runoff and snowmelt from within the Clear 

Creek watershed. Because the NWTC is not located within the 

bounds of a municipal public water supply distribution system, 

treated water, which originates in large part from the Boulder 

Creek watershed and, to a lesser degree, some watersheds on the 

western slope of Colorado, is purchased from the City of Boulder 

and transported by truck to the site for the 150 employees 

located there. Upon delivery to the NWTC, the trucked water 

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-liter) day tank, where chlorine is added to 

boost disinfectant levels prior to distribution to site buildings. 

The state of Colorado permits the NWTC drinking water system. 

Weekly monitoring and periodic required sampling is conducted 

by a subcontractor to NREL, designated as the Operator in 

Responsible Charge (ORC). Sample analysis is performed by an 

analytical laboratory contracted to the ORC. Monitoring and 

sample collection methods as well as sample handling and 

laboratory quality control methods prescribed by the state of 

Colorado and the EPA are included in the ORC subcontract with 

NREL and in the ORC’s contract with the analytical laboratory.

6 WATER QUALITY 

PROTECTION

Stormwater outfall that directs runoff to the STM site 

detention basin. Grouted riprap prevents erosion of soil 

on steep slopes while wetland vegetation slows the 

flow of stormwater and encourages nutrient and urban 

pollutant uptake. Photo by Dennis Schroeder, NREL 45400
Water Quality Protection 45

Figure 3 and Figure 4 show the results of chlorine and 

disinfection byproducts monitoring at the NWTC during 2017. 2017 Accomplishments and Highlights

• The monthly disinfectant byproduct sampling

program that began in December 2016 was

completed in December 2017. Disinfectant

byproduct results were collected by the City

of Boulder, the NWTC’s water provider, within

their distribution system. The data that correlate

with NREL collection periods will be obtained

and analyzed in 2018 to help identify additional

operational practices that will minimize disinfectant

byproduct formation and provide water that meets

all regulatory requirements.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• All monitored parameters met applicable requirements.

• Certified divers were contracted to perform inspections of

the 2,000-gallon (7,580-liter) and 15,000-gallon (56,781-liter)

fiberglass water storage tanks at the NWTC. Both tanks were

found to be free of cracks and in overall good condition.

These results were reported to the Water Quality Control

Division of the CDPHE in compliance with state drinking

water requirements.

• Water samples were collected at five drinking water taps at

the NWTC and analyzed for lead and copper concentration.

All lead sample results were below both the maximum

allowable concentration in drinking water and below the

limit at which the chemical analysis method can detect lead.

Copper levels ranged from 0.060 mg/L to 0.338 mg/L, far

below the maximum allowable concentration in drinking

water of 1.3mg/L. These results were reported to the Water

Quality Control division of CDPHE, as required.

• The drinking water supply at the NWTC was interrupted

on November 6, 2017, when a pipe within the distribution

system burst. Repairs were made and water service was

restored the same day. Water quality standards remained in

compliance prior to and after the disruption in service.

• A total of 439,448 gallons (1,663,491 liters) of drinking water

were provided to NWTC users.

6.2 Groundwater

The Denver Basin aquifer system underlies an area of 

approximately 7,000 square miles (1,812,992 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, 

Figure 3. Results of 2017 average monthly chlorine residual 

monitoring at the NWTC

Figure 4. Comparison of disinfection byproducts monitoring at the 

NWTC, 2013–2017

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

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

Chlorine Residual, mg/L

Month

Average Monthly Chlorine Residual, 2017 

Max Allowed 4.0 mg/L

Chlorine Residual mg/L

Min Allowed 0.2 mg/L

2013 2014 2015 2016

Disinfectant Byproducts

80

70

60

50

40

30

20

10

0

Amount Present, ppb

TTHM MCLa

HAA5 MCLb

a

 TTHM MCL = total trihalomethanes maximum contaminant level

b HAA5 MCL = total haloacetic acids maximum contaminant level

c TTHM = total trihalomethanes

d

 HAA5 = total haloacetic acids

2017

TTHMc

HAA5d
46 Water Quality Protection

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 low likelihood of reaching the Dawson aquifer, 

NREL’s groundwater management program is focused on 

the control of potential pollutant sources that could affect 

this important resource. This includes careful evaluation of all 

outdoor projects to eliminate, substitute, or control potential 

sources of pollution.

There are currently three permitted monitoring wells at the 

STM site and no 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. Both geothermal well systems were installed 

as part of research activities.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• Three groundwater wells installed immediately north of the

Field Testing Laboratory Building in 2015 continued to be

monitored to determine if groundwater or surface water

was responsible for seepage into the building that occurred

under the north foundation wall.

6.3 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 

A subcontractor measures water levels and takes groundwater 

samples north of the Field Testing Laboratory Building.

Photo by Dennis Schroeder, NREL 49675

Erosion control blanket and underlying native seed surrounding 

electric car charging stations; the stations were installed as part of

a research project to test equipment function and durability.

Photo by Genevieve Braus, NREL 49958

2017 Accomplishments and Highlights

• There were no spills or releases that impacted

groundwater.
Water Quality Protection 47

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.

2017 Accomplishments and Highlights

• Initial work began on a project at the STM site to

stabilize the hillside adjacent to the Field Testing

Laboratory Building. The building was damaged

initially by a water line break and then further

impaired by the erosive impacts of the September

2013 flood event. Completion of the project, which

will install both retaining walls and stabilizing

vegetation, is expected to be completed in 2018.

• Erosion and sediment control plans implemented

on several small construction projects contributed

to the preservation of topsoil and prevention of

sediment deposition to nearby surface drainages.

• NREL staff attended a stormwater compliance

training class at the Rocky Mountain Education

Center. For some staff members, the training served

to refresh their current knowledge and update

them on new regulations and best management

practices. For other staff members, the training

provided a basis upon which to understand

stormwater requirements, especially in their

oversight role of construction subcontractors.

• NREL staff attended a stormwater workshop for

federal facilities sponsored by EPA Region VIII.

The workshop included in-depth discussions of

implementation methods for current requirements

and notice of upcoming regulatory changes.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• Permit coverage for an ongoing project at the STM site

was transferred from the 2012 EPA Construction Permit to

the EPA’s new 2017 Construction General Permit, and later

amended to reflect modified project scope and schedule.

• Periodic stormwater inspections were performed at locations

where earth-disturbing activities occurred. The inspections

and any resulting maintenance of structural stormwater

erosion and sediment controls took place on construction sites

operating under the EPA Construction General Permit, as well

as smaller areas where permit coverage was not required but

where stormwater best management practices are followed.

• EPA Region 8 representatives visited the STM site at NREL’s

request to provide clarification on stormwater Construction

General Permit requirements. The EPA expressed approval

of NREL’s stormwater management and their confidence in

NREL’s protection of downstream surface water quality.

6.4 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.

NREL’s primary non-domestic wastewater discharge is 

generated at the STM site’s Integrated Biorefinery Research 

Facility where research related to the production of bio-based 

products and fuels is conducted. 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 the targeted pH range of 5 to 

11 prior to discharge into the sanitary sewer system. The Metro 

District and Pleasant View system managers periodically tour 

the facility and review 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 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.

2017 Accomplishments and Highlights

• The pH probe in the acid waste neutralization tank 

at the Integrated Biorefinery Research Facility was 

replaced with a new, more accessible meter to 

facilitate frequent and direct validation of the probe’s 

accuracy; this helps to ensure that the discharge 

from the tank meets regulatory requirements. 

• Commissioning was performed on equipment to

support a new thin-film solar cell research tool.

This included flow and pH monitoring to establish

operating procedures for assuring the discharge

falls within regulatory limits.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• The Metro District and Pleasant View staff visited the STM

site to tour current research operations that discharge to the

sanitary sewer and to discuss reporting requirements.
48 Hazardous Materials and Hazardous Was te Management

Responsible acquisition, use, and disposal of materials 

and waste are critical to meeting regulatory compliance, 

preventing pollution, and caring for the environment. NREL 

seeks to purchase materials that are sourced responsibly, 

contain recycled content, and have low toxicity in order 

to reduce the environmental impact of its waste streams. 

Hazardous materials used on site are thoughtfully controlled 

with internal procedures designed to limit health and 

environmental risks. Waste is carefully managed and disposed 

of through fully permitted facilities. Areas of focus include:

• Hazardous materials management

• Hazardous waste management

• Aboveground storage tank management

• Spill prevention and response

• Radiological materials and waste management.

Additional information regarding program management for 

each of these five areas of focus can be found in Appendix A.

7.1 Hazardous Materials Management

A variety of chemicals and materials, some of which are 

hazardous, are used in research and maintenance activities 

at NREL facilities. Hazardous materials are stored, used, 

and managed in a manner that is protective of laboratory 

personnel, the public, and the environment.

2017 Accomplishments and Highlights

• A coordinated excess chemical and research sample

disposal effort was performed throughout two

bioenergy research facilities.

• Fifty-two chemical storage cabinets were obtained

to replace aging and deficient storage cabinets.

7 HAZARDOUS 

MATERIALS AND 

HAZARDOUS WASTE 

MANAGEMENT

Excess chemicals that were collected and disposed of per 

state and federal regulations. Photo by Eric Schmitz, NREL 49539 
Hazardous Materials and Hazardous Was te Management 49

2017 Compliance Summary

• Program activities were in compliance with requirements.

• There were no releases of hazardous materials that required

reporting. In accordance with DOE requirements, NREL

screened selected chemicals to confirm that quantities fell

below those requiring elevated operational protocols.

• Emergency Planning and Community Right-to-Know Act

(EPCRA) Tier II hazardous materials reports were submitted

for two facilities for reporting year 2017. The reports help

state and local emergency response and planning agencies

and local fire departments plan for chemical emergencies.

Chemicals reported include diesel fuel, petroleum oil, and

sulfuric acid contained in sealed lead-acid batteries.

• The Denver Fire Department issued a hazardous-materials

permit for the Renewable Fuels and Lubricants Research

Laboratory.

Table 5. 2017 EPCRA Reporting

EPCRA 

Section

Description

of Reporting

Status

302 Planning Notification Not requireda

304 Extremely Hazardous 

Substance Release Notification

Not requireda

311–312 Safety Data Sheet/

Chemical Inventory

Reported

313 Toxics Release Inventory 

Reporting

Not requireda

a “Not required” indicates that NREL was not required to report because it did not 

meet the threshold or did not have an extremely hazardous substance release.

The specific reporting requirements for each EPCRA section 

outlined in Table 5 is defined in Section 4, Compliance Summary.

7.2 Hazardous Waste Management

Research and development activities and general facility 

operations create a variety of waste streams, some of which 

contain toxic chemicals or metals. NREL typically disposes of or 

recycles the following categories of waste:

• Hazardous waste (as defined by environmental regulations)

• Non-hazardous waste such as low-toxicity chemicals, and

containers and utensils contaminated with chemicals (does

not include municipal solid waste such as regular office trash)

• Universal waste such as mercury-manufactured articles and

lamps, batteries, aerosol cans, and electronic waste including

computers, monitors, and research instrumentation

containing electronic circuitry.

Table 6 provides a summary of the waste generated at NREL

for the past 5 years.

Table 6. Comparison of Four Waste Categories Generated 

at NREL Facilities, in lbs. (kgs) Net Weight

Hazardous 

Waste

NonHazardous 

Waste

Universal 

Waste 

Electronics

Other 

Universal 

Waste

2013 14,974 

(6,792)

4,477 

(2,031)

38,096 

(17,280)

19,063 

(8,647)

2014 14,683 

(6,659)

15,198 

(6,893)

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)

2016 14,234 

(6,456)

17,340 

(7,865)

14,028 

(6,376)

8,686 

(3,948)

2017 20,733 

(9,404)

29,599 

(13,425)

25,924 

(11,759)

8,430 

(3,824)

2017 Accomplishments and Highlights

• As a best management practice, NREL facilities are

managed to the more stringent Large Quantity

Generator hazardous waste regulations category,

which specifies requirements for personnel training,

contingency planning, and container labeling and

management.

• Waste management storage and collection

areas were established in the NWTC’s Composite

Materials Education and Technology Facility in

advance of start-up of operations.

• Numerous individual laboratory spaces were

renovated, requiring advanced characterization and

planning for the disposal of chemical gloveboxes,

fume hoods, and exhaust ducting. While most

equipment was manually decontaminated and

recycled, two chemical gloveboxes were managed

as hazardous waste.

• Authorizations and approvals were obtained to

transport and dispose of one mobile data trailer

containing non-friable asbestos in its interior

from the NWTC in accordance with EPA, State of

Colorado, and OSHA regulations.
50 Hazardous Materials and Hazardous Was te Management

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• Nineteen hazardous and 12 universal waste shipments for

offsite disposal and recycling were made from NREL’s five sites.

• Mandatory training on employee hazardous and universal

waste management was completed in compliance with

state and federal regulations.

• All regulatory notifications were submitted and applicable

waste generator fees were paid.

7.3 Aboveground Storage 

Tank Management

Appropriate tank management prevents or minimizes spills 

and leaks of fuels or oils which can contaminate soils, surface 

water, groundwater, and drinking water. Inspections such 

as monthly and annual visual, interstitial, and ullage log 

determination support the laboratory’s commitments to 

environmental stewardship and pollution prevention.

Risk of underground soil and water contamination from 

storage tanks is reduced by using only aboveground storage 

tanks (ASTs). Unlike underground tanks, aboveground 

installations provide access for regular visual leak inspections 

and allow for less costly repair and cleanup.

NREL operates several petroleum-based ASTs. Five are located 

at the NWTC with a total capacity of 1,289 gallons (4,879 

liters), one is located at the NREL-occupied laboratory at the 

Denver West Office Park with a capacity of 500 gallons (1,893 

liters), and 20 are located at the STM site with a total capacity 

of 13,164 gallons (49,831 liters). All ASTs are maintained using 

best management practices and according to applicable 

regulations. Five ASTs at the STM site are registered with the 

state. There are no ASTs that require registration at the NWTC, 

Denver West Office Park, Renewable Fuels and Lubricants 

Laboratory, or Joyce Street Facility.

2017 Accomplishments and Highlights

• Two new, small research-generator ASTs provided by 

the U.S. Navy, which contain a combined 90 gallons 

(340 liters), were placed at the Energy Systems 

Integration Facility. These ASTs are below the state’s 

660-gallon installation permitting and registration 

threshold.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• All tanks were inspected to confirm continued adherence

to state of Colorado regulations.

• Annual AST training was provided to 26 staff members

identified as having responsibility for operating and

fueling ASTs or performing oversight for tank safety and

environmental compliance.

• Eight ASTs were painted as part of a tank maintenance effort.

7.4 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 (SPCCs), can reduce spills and limit 

impacts to the environment when spills do occur.

SPCC plans have been developed and are in place for the 

NWTC, the STM site, and the Renewable Fuels and Lubricants 

Research Laboratory. As the total amount of oil stored at NREL’s 

Joyce Street and Denver West Office Park facilities is less than 

1,320 gallons (4,997 liters), SPCC plans are not required at

those locations.

A double-wall 200-gallon (757-liter) standby generator diesel fuel 

tank located at the NWTC. Photo by Theodore DeVito NREL 50079
Hazardous Materials and Hazardous Was te Management 51

2017 Accomplishments and Highlights

• In addition to its routine training program, 35 NREL

Chemical Emergency Response Team members

participated in a 24-Hour Emergency Response 

Technician Level III training course to further enhance 

contingency planning and emergency preparedness.

• All spill kits were inventoried, inspected, and restocked.

• Spill-control planning continued to be refined and

enhanced. Additional STM site maps were developed

to identify recommended spill control points, and

included the consideration of drainage width, ease

of access, and ability to place sorbents or temporary

containment structures.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• No reportable spills occurred. Nine minor spills of diesel,

lubricant, coolant, and hydraulic fluids occurred at the STM

site, and no spills occurred at the NWTC. The size of spills

ranged from less than 0.1 gallon to 4 gallons (0.38 to 16

liters), with a total quantity of 7.6 gallons (28 liters). Eighty

percent of these spills were from vehicles and mobile

equipment and occurred on paved surfaces. Each spill

received immediate remedial action and there was no

significant impact to the environment.

• The SPCC training required annually of all workers who

manage fuel storage tanks was revised to include an

updated spill history.

7.5 Radiological Materials 

and Waste Management

The laboratory currently uses radiological materials in electron 

microscopy staining. A number of sealed sources are also 

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.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• Only small quantities (less than 1 cubic yard [0.76 cubic

meter]) of low-level radioactive waste are currently in storage

awaiting off-site disposal.

• A ventilation exhaust hood was removed during

decommissioning of the laboratory’s only low-level

radioactive work area. Radiological sampling indicated

the hood was within limits for release and would not 

pose a hazard to workers, the public, or the environment. 

However, the hood was placed in the metal recycle bin 

without following established internal procedures. An event 

investigation was completed and the following corrective 

actions identified: (1) modify the work control process to 

eliminate multiple-copy work orders and prominently identify 

special instructions, and (2) mark as-built facility drawings to 

communicate prior radiological use and identify the need for 

special instructions for future facility modifications.

• In accordance with a federal regulation and DOE Order, NREL

submitted its annual Radionuclide Air Emissions Annual Report

to the EPA confirming that the laboratory is in compliance

with air emissions standards. For calendar year 2017, the

effective dose equivalent of radiation to the public was 0.045

millirem (mrem) per year, far below the 10 mrem per year limit.

What is “Effective Dose Equivalent”?

To understand effective dose equivalent, dose and 

dose equivalent must first be defined:

• 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.
52 National Environmental Policy Act

The National Environmental Policy Act of 1969 (NEPA) is a 

federal law that serves as the national charter for protection 

of the environment, including natural, social, and economic 

impacts. NEPA requires the federal government to evaluate and 

understand the potential environmental impacts of a proposed 

action before resources are committed, such as federal 

funds, properties, facilities, employees, and equipment. NEPA 

mandates that the federal agencies weigh the potential for 

environmental impacts equally among all factors when making 

decisions about a proposed action.

In compliance with NEPA, potential environmental impacts 

from a wide range of activities conducted by NREL staff at both 

onsite and off-site facilities are evaluated prior to authorizing 

funds or commencing work. The NEPA process represents 

an effective means for project managers, scientists, and 

engineers to understand the potential environmental impacts 

of proposed activities and identify actions to minimize impacts. 

Additional information regarding NREL’s management of the 

NEPA program can be found in Appendix A.

2017 Accomplishments and Highlights 

• Two NEPA overview sessions were provided to project

managers and scientists to communicate NEPA’s

purpose, requirements, and key considerations for

effective project planning.

• NREL and DOE Golden Field Office NEPA specialists 

identified continual improvement opportunities to 

enhance the quality and consistency of NEPA evaluations.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• A total of 159 documented environmental evaluations were

completed; 132 actions were covered by a Programmatic NEPA

Determination; and 27 actions were submitted to DOE for review.

• Quarterly monitoring of the NEPA program was conducted

to confirm that the appropriate level of NEPA evaluation

(either application of a Programmatic NEPA Determination or

review by DOE) was completed for maintenance, contracting,

and purchasing activities. Results indicate that established

procedures are effective, and proposed activities received the

appropriate level of review.

8 NATIONAL 

ENVIRONMENTAL 

POLICY ACT

NREL biologists completed a study that evaluated how 

seeding with different types of native grasses—along 

with different seed bed preparations, seed protective 

covers, and shade effects—would perform under an 

8-acre, 1-MW photovoltaic array at the NWTC. This

photo documents vegetation growth in one seed bed

after 3 years. This study showed that short-growing,

warm-season grasses, with or without cool-season,

shade-tolerant species or legumes, could produce an

extensive plant cover within a 3-year period. Photo by 

David Buckner, NREL 49957
Natural and Cultural Resources Protection 53

Natural resources at the STM site and the NWTC are managed 

responsibly to ensure NREL’s research needs are met while 

protecting native wildlife, vegetation, and cultural resources. 

Responsible management benefits not only the environment, 

but also NREL employees and the surrounding community. 

Management focuses on these key areas:

• Wildlife management

• Endangered species and species of concern

• Vegetation management

• Wetlands and floodplains

• Cultural resources.

Additional information regarding program management for 

these five areas can be found in Appendix A.

9.1 Wildlife Management

Due to their location just east of the foothills of the Rocky 

Mountains, wildlife is plentiful at both the STM site and the 

NWTC. NREL promotes responsible management of wildlife 

and habitat through periodic formal surveys and review of 

impacts to wildlife when designing and implementing projects.

At the STM site, the original wildlife survey of the property was 

completed in 1987 and an additional study of the conservation 

easement property was performed in 1999. Subsequent 

surveys were completed in 2005 and in 2011. In 2017, the STM 

site was surveyed once again. 

Mammals identified during the surveys at the STM site included 

mule deer, elk, coyotes, bobcat, striped skunks, rabbits, and 

various smaller mammals. More than 80 species of birds have 

been recorded by the formal wildlife surveys and supplemental 

employee observations. Over seven raptor species have 

been recorded at or above the STM site, especially during 

spring migration. Two raptor species are residents at the site: 

American Kestrel (Falco sparverius) and Red-tailed Hawk (Buteo 

jamaicensis). Owls also occupy the STM site, including the 

Great Horned Owl (Bubo virginianus). Recently, a Northern 

9 NATURAL AND 

CULTURAL 

RESOURCES 

PROTECTION

A Common Nighthawk (Chordeiles minor) uses 

camouflage to blend in at the NWTC. Photo by Jeroen Van 

Dam, NREL 49613.
54 Natural and Cultural Resources Protection

Pygmy-Owl (Glaucidium gnoma) was heard during owl surveys.4

Reptiles and amphibians also inhabit the STM site. Most 

notably, the Woodhouse’s toad (Anaxyrus woodhousii) breeds in 

ephemeral ponds on the STM conservation easement.5

DOE prepared a biological characterization inventory in 1992 

for the entire Rocky Flats Plant area, a former production site 

for nuclear weapons. The area includes 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. Approximately 20 species of birds were sighted at or 

near the site. Raptor surveys were conducted at the NWTC in 

4. Two Dot Consulting, LLC. (2017). 2017 Vegetation and Wildlife Surveys at the National Renewable Energy Laboratory, South Table Mountain. Jefferson County, Colorado.

5. Tetra Tech EC, Inc. (2011). Avian Monitoring and Mortality Report, National Wind Technology Center. Jefferson County, Colorado.

2017 Accomplishments and Highlights

• Acoustic bat monitoring at the NWTC was conducted by 

installing an acoustic recorder in the nacelle of a utilityscale turbine on the northeast portion of the site. Contrary 

to previous monitoring, the results identified only larger 

bat species in proximity to the nacelle at approximately 

295 feet (90 meters) from ground level. Hoary bats (Lasiurus 

cinereus) and silver-haired bats (Lasionycteris noctivagans),

both tree-roosting species, and the big brown bat 

(Eptesicus fuscus), a cave-roosting species, were the only 

species recorded. These recordings reflect the results of

on-site mortality studies where these species were 

primarily found during mortality surveys.5

• Wildlife surveys were conducted at the STM wherein two

amphibian species, two reptiles, 71 avian species, and

4 mammal species were recorded. Highlights include

species not recorded previously, such as the Northern

Pygmy-Owl (Glaucidium californicum).

• Tree Swallows (Tachycineta bicolor) returned to nest in

two of the boxes along the eastern edge of a STM site

detention basin.

• A pair of American Kestrels fledged a nestling at the

STM site in a nest box provided by facilities maintenance

(see photo p. 56).

• NREL staff installed four nest structures for Barn Swallows

at the NWTC.

• NREL was featured on the DOE headquarters’ Earth Day

banner, along with the Pantex Plant and Hanford Site, for

migratory bird protection efforts.

• The removal of a metal shed was delayed so that a

resident bee hive could be removed and relocated at a

time of year likely to protect the viability of the colony.

• NREL biologists hosted two nature walks for Earth Day.

• The Woodhouse’s toad was seen during daytime surveys

on the mesa top adjacent to ephemeral ponds in spring.

Spring precipitation events determine the extent to which

these ponds provide important aquatic habitat in the 

semi-arid climate of the STM site.

• NREL biology staff hosted and participated in a

symposium panel discussion at the North American

Wildlife Society on renewable energy and impacts to

wildlife. This symposium was held at the Annual Wildlife

Society Conference in Albuquerque, New Mexico.

• NREL biology staff hosted a local Audubon group and

provided a tour of the NREL STM site to learn about

bird-friendly building design and retrofits.

• NREL staff closed entry to the southeast stairwell of

the STM site parking garage to protect fledgling birds

(American Robin [Turdus migratorius] and Common

Grackle [Quiscalus quiscula]).

• A Common Loon (Gavia immer) was found at the NWTC

in November. Thought to be injured and unable to take

flight, the loon was captured and taken to Greenwood

Wildlife Rehabilitation Center. After examination, the

loon did not appear injured and was taken that day to a

reservoir and released.

• A roll-on grape extract was successfully used to repel

Northern Flickers (Colaptes auratus) and prevent them

from nesting in the façade of the Outdoor Test Facility. The

repellent, which was applied monthly from March through

May, was successful in reducing the overall number of

holes initiated by the flickers.

• Raptor predator calls and decoys were used in the STM site 

parking garage stairwells to deter roosting pigeons; efforts 

appeared to be effective. Additionally, the stairwells were

cleaned quarterly to further discourage pigeon roosting.

• An internal assessment of pest management practices 

was completed that resulted in non-conformities and 

opportunities for improvement regarding document control, 

maintaining an approved pesticide list, ensuring application 

records are consistently completed, and enhancing 

procedures for pesticide selection and application.

A Vesper Sparrow (Pooecetes gramineus) nest found during nesting 

bird surveys at the NWTC. Photo by Kurt Schlomberg, NREL 45450
Natural and Cultural Resources Protection 55

1994 and 1995 that identified seven raptor species on or in the 

vicinity of the site. An avian survey was again completed in 2003 

and updated in 2011. A 2016 survey included mammals, reptiles, 

amphibians, and terrestrial arthropods with results duplicating 

the 2011 survey that showed that various mammals, including 

elk, mule deer, coyotes, desert cottontail rabbits, bobcats, bats, 

deer mice, prairie voles, and shrews, continue to feed at and 

occupy the site. Although seldom seen, rattlesnakes, bull snakes, 

racers, and several other reptiles are also known to occupy 

the site. Amphibians, including boreal chorus frogs (Pseudacris 

maculata), Woodhouse’s toad, and Northern leopard frog 

(Lithobates pipiens), occupy ephemeral wetlands at the NWTC.

A complete list of all wildlife species identified at both the

STM site and the NWTC is found in Appendix C.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• Ground-nesting-bird surveys were conducted prior to

annual mowing and weed control operations at the NWTC

in conformance with the Migratory Bird Treaty Act. A Vesper

Sparrow nest was found and cordoned off; mowing was

delayed in that area until it was clear that the eggs had

hatched and the young had permanently left the nest.

9.2 Endangered Species and 

Species of Concern

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. As a federal facility, NREL is 

required to abide by the Endangered Species Act. Compliance 

ensures that the laboratory’s actions do not adversely affect 

threatened, endangered, or candidate species that are listed 

under the Act. NREL also complies with the Colorado Division 

of Parks and Wildlife restrictions related to endangered, 

threatened, and species of concern for Colorado, as well as

the rare plant species listed under the Colorado Natural 

Heritage Program.

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 

be found in Jefferson and Boulder Counties. Of these species, 

three have the potential to occur at the STM site or the 

NWTC, including the Preble’s meadow jumping mouse (Zapus 

hudsonius preblei), the Ute ladies’ tresses orchid (Spiranthes 

diluvialis), and the Colorado butterfly plant (Gaura neomexicana 

var. coloradensis). According to the U. S. Fish and Wildlife Service 

iPac database, an additional 14 bird species listed as species of 

special concern, along with several other species on the state 

of Colorado’s list of Species of Greatest Conservation Concern 

(CPW 2015), could also exist in Jefferson and Boulder Counties. 

In 2017, a survey of the STM site did not detect any threatened, 

endangered, or species of concern. The 2016 NWTC survey 

revealed three state of Colorado Species of Greatest 

Conservation Concern to be present: the fringed myotis 

(Myotis thysanodes), little brown myotis (Myotis lucifugus), and 

Northern leopard frog. Note that in order for a bird species to 

be counted as occupying the STM site or the NWTC, the bird 

could not simply be flying over the site but had to be stopping 

over or otherwise utilizing habitat at the site, such as by 

nesting or foraging.

A European Starling (Sturnis vulgaris) surveys the view from a meteorological tower at the NWTC. Photo by Lee Fingersh, NREL 50124
56 Natural and Cultural Resources Protection

The U.S. Fish and Wildlife Service has designated critical habitat 

associated with the federally endangered Preble’s meadow 

jumping mouse 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 prior coordination with 

the U.S. Fish and Wildlife Service.

Five other species, which occur in the Platte River watershed 

in Nebraska, are listed by the U.S. Fish and Wildlife Service as 

species that must be considered for Colorado and Wyoming 

projects 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]). As part of the STM site and the 

NWTC NEPA environmental assessments conducted in 2014, 

DOE consulted with the U.S. Fish and Wildlife Service for future 

activities that have the potential to deplete water in the Platte 

River system. In accordance with requirements agreed upon 

during the consultation, NREL monitors water use to ensure 

the established amounts are not exceeded. NREL’s water use is 

reported to the U.S. Fish and Wildlife Service annually.

2017 Accomplishments and Highlights

• Wildlife biologists completed a survey at the STM

site; no federally listed threatened, endangered, or

species of conservation concern were found.

• NREL and DOE Golden Field Office staff supported

three off-site ocean deployment projects where

threatened and endangered species were present.

Consultations with the National Marine Fisheries

Service resulted in concurrence with a “Not Likely

to Adversely Affect” determination. Project actions

were identified and completed in such way to

minimize impacts to the affected species.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• No activities were conducted in designated critical

habitat for the federally threatened Preble’s meadow

jumping mouse.

• The 23.9 million gallons (90.6 million liters) of water used at

the STM site and the NWTC were reported to the U.S. Fish

and Wildlife Service and fell below the agreed-upon limit of

39.5 million gallons (149.7 million liters) per year.

An American Kestrel (Falco sparverius) juvenile peeks from a nest box 

while the female looks on. Photo by Tom Ryon, NREL 49607 

Whooping Cranes (Grus Americana) are endangered in the Central 

Flyway, including the Platte River Central Valley. Photo by Karin Sinclair, 

NREL 27963
Natural and Cultural Resources Protection 57

9.3 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, 

attract new types of pests and diseases, and out-compete 

native plants for nutrients and water. They can also deprive 

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.

Native Landscaping – Landscaped areas near NREL buildings 

and common areas are designed to include features such as 

native plantings, xeriscape principles suited to arid climates, 

and infiltration of stormwater to provide water and nutrients 

to landscape plants and to recharge groundwater in the area. 

Adhering to such designs helps promote wildlife-friendly 

vegetation and reduces the introduction of non-native species 

and the pests and diseases that can accompany them.  NREL 

actively manages the vegetation on its sites to maintain the 

native plant communities and manage wildfire risk. 

Weed Management – Where non-native species exist, 

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 

practices (e.g., reclamation of disturbed areas), prevention 

(e.g., limiting or eliminating driving off established roadways), 

biological practices (e.g., introducing state approved insects 

and fungus that feed on specific weed species), and herbicide 

treatment. The effectiveness of control methods is periodically 

assessed. The use of multiple control strategies has been 

successful in significantly reducing populations of diffuse 

knapweed and Canada thistle. The weed control program 

maintains the flexibility needed to respond to changes in weed 

populations from year to year.

Comprehensive site-wide weed surveys and mapping are 

performed approximately every five years. Smaller areas of 

NREL’s main sites are assessed annually. A list of noxious weed 

species, as defined on the state’s noxious weed list, identified at 

the STM site and the NWTC is found in Table 7.

Table 7. Noxious Weed Species Identified at the STM Site 

and the NWTCa

Noxious 

Weed 

Class

Species Present

at STM

Species Present

at NWTC

Class Ab Myrtle spurge None

Class Bc Canada thistle

Common teasel 

Dalmation toadflax 

Diffuse knapweed

Hoary cress 

(whitetop)

Hound’s tongue

Musk thistle

Russian olive

Scotch thistle

Bull thistle 

Canada thistle

Chicory

Common teasel

Dalmation toadflax 

Diffuse knapweed

Hoary cress 

(whitetop)

Moth mullein

Musk thistle

Sulfur cinquefoil

Class Cd Field bindweed

Cheatgrass

Common mullein

Field bindweed

Cheatgrass

Chicory

Common mullein

Common St. John’s 

wort

a Species identified reflect findings of site-wide weed surveys performed in 

2011 at the STM site and in 2016 at the NWTC. 

b

 Identified by the state for eradication.

c

 Identified by the state to stop the spread.

d

 Identified by the state to more effectively manage on private and public lands 

through education, research, and biological control resources.

Aromatic sumac (Rhus trilobata) are found in upland shrublands on 

the STM site. Photo by Brent Nelson, NREL 23908
58 Natural and Cultural Resources Protection

Wildfire Risk Management – Part of managing native 

vegetation at NREL is finding a balance between preserving 

and manipulating the landscape to reduce wildfire risk. 

NREL has a fire management program administered by the 

ESH&Q Office. This program includes wildfire assessments, 

fire risk management, and identifying areas of wildlandurban interface. These areas are currently being managed 

to achieve and maintain defensible space around buildings 

and other infrastructure against wildland fire. Most of the fire 

management activities of fire management can be done in 

conjunction with other vegetation management activities, 

such as weed control. Annual assessments of defensible space 

are conducted for the STM site and the NWTC.

Imported Plant and Organism Permits – An additional 

component of NREL’s vegetation management program 

relates to the use of certain animal and plant materials that 

are periodically used in research at the laboratory. Certain 

organisms and plants that are obtained from other states 

or from outside the United States are controlled by the 

U.S. Department of Agriculture Animal and Plant Health 

Inspection Service (APHIS). These might include the use of 

certain pathogenic organisms used in biomaterials research 

or plants such as sugarcane bagasse and other scrap 

agricultural products that are tested for their value in biofuels 

and biomaterial production. In 2017, NREL held three APHIS 

permits; two permits expired in the fall. Please see Appendix B 

for a listing of these permits.

2017 Accomplishments and Highlights 

• Monthly review and coordination meetings were

conducted to assess the success of seasonal

herbicide applications and revegetation efforts.

• A vegetation survey was conducted at the STM site.

No significant changes from previous surveys were

identified.

• A vegetation and noxious weed survey report

concluded that upland shrublands, composed

primarily of mountain mahogany, experiences very

limited regeneration due to cheatgrass (Bromus 

tectorum) competition.

• Annual herbicide spraying was performed to

control of diffuse knapweed and sulfur cinquefoil

(Potentilla recta) at the NWTC, and Canada thistle,

houndstongue (Cynoglossum officinale), and myrtle

spurge at the STM site.

• Weed mapping was performed at the STM site;

the map will be used to plan future management

actions.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• At the NWTC, herbicides were applied to approximately

345 acres (140 hectares) to control B- and C-listed weeds in

May and June, as well as 10 acres (4 hectares) in September.

• At the STM site, herbicides were applied to control A-, B-,

and C-listed weeds to approximately 40 acres (16 hectares)

in April and May, including applications on the mesa top

conservation easement; 12 acres (5 hectares) in June; and 5

acres (2 hectares) in August.

• NREL biologists introduced bindweed mites to combat

bindweed on the STM site. Biological control specimens

were provided by the Colorado Department of Agriculture

State Insectary in Palisade, Colorado.

• The north and west sides of the RSF building were sprayed

with a half-strength solution of Roundup®. This mixture

selectively targets cheatgrass, a List-C noxious weed, that

is first to emerge from dormancy in the late winter. Over

the past three years this technique has increased the

productivity of native grasses around the building.

• Herbicides were applied in April and May to a large tract

(32 acres [13 hectares]) of grassland within the STM site

conservation easement. The application targeted cheatgrass,

dalmatian toadflax, and thistle.

• Russian olive trees were identified and mapped on the STM

site during a natural resource inspection. The trees were

treated with Roundup after girdling live branches, but a

few tenacious trees are under consideration for “chainsaw

treatment.”

• Through consistent monitoring and working with the

Colorado Department of Agriculture, two additional

noxious weed species were identified at the NWTC: sulfur

cinquefoil and moth mullein (Verbascum blattaria). The 

invasive sulfur cinquefoil was treated in 2017 and treatments

will continue in 2018. The slow-growing moth mullein will

be incorporated in continuous plans to combat common

mullein (Verbascum thapsus) as management practices for

both species are similar.

• One new APHIS permit for the import of Linum usitatissimum

(otherwise known as flax or linseed) stems from Canada was

obtained. Two permits expired for napier grass (Pennisetum 

purpureum), sugarcane (Saccharum officinarum) bagasse, and

sugarcane leaves and plant tops.
Natural and Cultural Resources Protection 59

9.4 Wetlands and Floodplains

Wetlands are lands that are inundated or saturated by surface 

or groundwater at a frequency and duration sufficient to 

support, and under normal circumstances do support, 

a prevalence of vegetation typically adapted for life in 

saturated soil conditions. Wetland areas typically take the 

form of swamps, marshes, bogs, and groundwater seeps 

and are frequently located within or adjacent to a floodplain. 

Floodplains are land areas adjacent to rivers and streams that 

are subject to recurring inundation.

Both wetlands and floodplains play a key role in providing 

floodwater storage, reducing flood flow rate, filtering 

floodwater, and groundwater recharge. The resulting enriched 

floodplain soils promote the growth of wetland and riparian 

vegetation that provides habitat for a rich diversity of terrestrial 

and aquatic plants and animals.

Floodplains vary in extent from those that contain the more 

frequent low-volume rain event flows to widths that have the 

capacity to contain a 100-year flood event and greater. Stream 

channels at NREL sites generally are more characterized by the 

former description. There are no 100-year floodplains defined 

by Jefferson County or the Federal Emergency Management 

Agency on NREL sites.

Table 8 lists the types and acreage of wetlands at the STM site 

and the NWTC that have been identified to date. Please refer to 

Appendix D for the locations of these wetlands.

NREL preserves the important natural functions of its wetlands 

and floodplains, regardless of size or extent, to protect the 

physical, biological, and chemical integrity of receiving waters 

and riparian areas on and adjacent to the STM site and the NWTC.

Table 8. Wetland Types and Acreages at the STM Site and the NWTC

Wetland

Type

STM Site

(acres/

hectares)

NWTC

(acres/

hectares)

Headwater 0.0 (0.0) 2.0 (0.9)

Palustrine 

Emergenta 1.3 (0.6) 3.6 (1.4)

Seasonal Pond 0.6 (0.2) 0.6 (0.2)

Wet Meadow 0.3 (0.1) 0.0 (0.0)

TOTAL 2.2 (0.9) 6.2 (2.5)

a

 Palustrine emergent wetland areas have been surveyed and meet all federal 

wetland criteria. Other wetlands listed were identified by vegetation type only.

2017 Compliance Summary and Activities

• Program activities were in compliance with regulations.

• New wetlands were observed in stormwater detention

basins and drainageways on the STM site during vegetation

surveys. These new wetlands contribute to the overall

acreage in Table 8.

9.5 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.

Much of the land currently occupied by the STM site was 

once part of Camp George West, a military facility operated 

by the Colorado National Guard from 1903 through the early 

1930s. It was later leased to the federal government for military 

training purposes. Therefore, several formal surveys of historic 

and cultural resources have been performed on the STM site. 

Three historical resources were identified as significant cultural 

resources that should be preserved under the Archeological 

and Historic Preservation Act of 1974. These three resources, 

constructed in the 1930s and early 1940s during the Works

The “ammunition igloo” was constructed in 1940 as part of a Works 

Progress Administration project; the building is significant for its 

design. Photo by David Parsons, NREL 06928
60 Natural and Cultural Resources Protection

Progress Administration era, are located both at the STM site 

and at the remaining vestiges of Camp George West facilities 

and include:

• An open-air amphitheater

• A stone bridge spanning a natural drainage channel adjacent

to the amphitheater

• A stone and concrete ammunition igloo below the

amphitheater.

Through NREL’s efforts, these structures have been added to 

the National Register of Historic Places, 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.

A formal survey of the NWTC was conducted in 19956 and 

identified no significant historical or archeological resources.

2017 Accomplishments and Highlights 

• An internal assessment was completed that resulted

in three opportunities for improvement regarding

management of collected items and associated

records, clarification of procedures for Section

106 consultation, and enhancement of document

control.

2017 Compliance Summary and Activities

• Program activities were in compliance with requirements.

• ESH&Q staff took baseline measurements of a crack in

the STM ammunition igloo. The crack will be measured

periodically to determine if the crack is expanding.

• A cultural resource review was conducted for a portion of the

NWTC along the northwestern corner of the site where

future utility line projects will occur. No cultural resources

were found.

6. Labat-Anderson, Inc. (1995). Archaeological Assessment of the National Wind Technology Center. January 1995.
Conservation Lands 61

In 1999, DOE granted a conservation easement of 177 acres

(72 hectares) at the STM site to Jefferson County (see Figure 5).

A baseline inventory of the property was prepared in June 1999 

to document the condition of the easement property and to 

assess its conservation value.7

 The baseline inventory includes 

descriptions of the geographical setting and adjacent property 

owners, access and use of the property by the public, and 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 and trees, primarily 

in the drainages. Several seeps also occur throughout the area.

The easement helps 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 natural, scenic, ecological,

and historic resources

• Protect the ecosystem and provide 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

• 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.

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

Energy Laboratory (NREL) Site Conservation Easement Baseline Inventory.

Golden, Colorado.

10 CONSERVATION 

LANDS

View to the west from the conservation easement at the 

STM site. Photo by Kurt Schlomberg, NREL 50038
62 Conservation Lands

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, DOE 

staff, and the public use these trails frequently.

8. Jefferson County Open Space Department, Jerry Bader. (2017). Conservation Easement Monitoring Report. August 2, 2016. Golden, Colorado.

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.8

2017 Accomplishments and Highlights

• Conservation easement inspections were conducted in 

the summer and fall, and no new concerns were identified.

In the prior year’s inspection, it was noted that sections 

of fencing may have been limiting wildlife movement. 

Specific areas of fencing were identified and several 

sections were cut and rolled back to allow for wildlife to 

pass through. These areas were revisited and were found 

to support the movement of wildlife through the area.

• Since the August 2, 2016, 29-acre (11.8 hectares) wildfire,

native grasses show moderate growth, especially in the

northern half of the burn area. Areas of thin top soil,

mostly in the southern portion, show strong regrowth of

cheatgrass (Bromus tectorum), a Class-C noxious weed;

no erosion has been observed as a result of the burn,

likely due to its low intensity.

• Herbicides were applied in April and May to a large tract

(32 acres [13 hectares]) of grassland within the STM

site conservation easement. The herbicides targeted

cheatgrass, dalmatian toadflax (Linaria dalmatica), and

thistle (Asteraceae spp.).

• Russian olive trees (Elaeagnus angustifolia), an invasive

species, were girdled to prevent their spread.

• Jefferson County Open Space conducted their annual 

assessment of the conservation easement. The resulting 

conservation easement Monitoring Report6 highlighted 

the significant natural features of the land 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.
Conservation Lands 63

Figure 5. Conservation easement at the STM site
64 Appendix A. Program Management Descriptions

NREL celebrated its 40th anniversary in 2017.

Photo by Dennis Schroeder, NREL 45685

Environmental Management Systems/

Pollution Prevention

NREL’s EMS is implemented via the following:

• Establishment of environmental policies and programs

that guide site operations (including research and site

development) and maintenance at the laboratory; these

policies and programs undergo regular reviews and updates

• Annual identification of federal laws and regulations, state

and local requirements, executive and DOE orders, and

standards to address environmental hazards

• Annual identification of environmental stewardship goals

and actions and regular planning to achieve them

• Verification of worker competence with regard

to environmental requirements through various

training programs

• Communication with surrounding communities and

regional agencies to collaborate on environmental goals

• Maintaining accurate document records and controls

• Monitoring and performing corrective actions

• Conducting internal and external program assessments

• Maintaining adherence to the ISO 14001 standard.

The laboratory prevents pollution through the implementation 

of environmental and sustainability programs. This includes 

waste management and minimization, hazard identification 

and control, energy conservation, sustainable purchasing, 

sustainable transportation, water conservation, and sustainable 

building operation and maintenance.

Sustainability

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 

APPENDIX A.

PROGRAM MANAGEMENT 

DESCRIPTIONS
Appendix A. Program Management Descriptions 65

procurement processes, climate change resiliency planning, 

engaging with the community, and employee culture 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 

experience 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.

Climate Change Management

In 2014, NREL received funding from DOE’s Sustainability 

Performance Office to develop a model process for climate 

change resilience planning, beginning its climate change 

management program. 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 climaterelated 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. This assessment process, which was also made 

available to other DOE sites, enabled NREL to develop a list 

of actions to manage near- and longer-term climate change 

risks. Each year the laboratory works to make progress on these 

action items.

Air Quality Protection

The objectives of NREL’s air quality management program 

consist of minimizing air emissions related both to research 

and employee commuting activities, monitoring emissions 

from larger on-site sources, and meeting all required emission 

standards and permitting requirements. Specific management 

practices relative to the types of air pollutants emitted are 

described below.

Criteria Pollutants and Hazardous

Air Pollutants Permitting

The laboratory maintains an air-emission inventory to track 

potential emissions and identify whether future 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. An EPA Title V permit 

is required when one or more criteria emissions for a facility 

equals 100 or more tons per year (90.7 MT), or when the 

aggregate of all HAP emissions from any individual facility is 

more than 25 tons per year (22.7 MT).

The laboratory has a fugitive particulate emissions 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 nonsand 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. EPA requires that CO2

equivalent (CO2e) greenhouse gas emissions from any source 

which are larger than 27,500 U.S. tons per year (25,000 MT) be 

reported to EPA annually. EPA also requires a major source of 

criteria pollutants also include CO2e emissions in the major 

source permit if CO2e emissions exceed 75,000 tons per year 

(68,000 MT). NREL facilities are not major sources of criteria 

pollutants and CO2e emissions for all facilities are less than 

either of the above-mentioned limits.

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 refrigerants 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.
66 Appendix A. Program Management Descriptions

Annually, NREL registers 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 with the 

state as necessary. Both of the Solar Energy Research Facility 

chillers mentioned previously have more than 100 horsepower 

(74.6 kW) of compression, contain an ODS refrigerant, and 

must be registered with the state.

Drinking Water

Treated drinking water is provided to the STM site by 

Consolidated Mutual Water Company, a municipal water 

provider. Because of this, NREL does not have direct control 

over drinking water quality. However, NREL does maintain 

the integrity of the on-site distribution system and notifies 

Consolidated Mutual Water Company of any drinking water 

complaints.

When treated municipal water is hauled to the NWTC, chlorine 

is added to achieve proper disinfectant levels at the points 

of use. Drinking water quality is maintained and protected 

through water quality testing as specified by the monitoring 

plan issued each year by the Colorado Department of Public 

Health and Environment. The plan identifies which tests 

are to be performed and at what frequency. Monthly tests 

are required for bacteria and disinfectant levels. Testing 

for disinfection byproducts (haloacetic acids [HAA5] and 

trihalomethanes [TTHM]) and lead and copper is completed 

annually. 

Groundwater

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, double-walled tanks, leak detection, 

and collection and offsite disposal of concrete wash water.

When the laboratory conducts activities that could impact 

groundwater, NREL implements a monitoring program 

and groundwater monitoring wells are installed as needed. 

Occasionally groundwater wells may be installed and 

monitored to obtain water level data needed for construction 

or building maintenance purposes.

Surface Water

Surface water bodies to which NREL sites drain are protected 

by a management program that focuses on construction site 

runoff and outdoor research and maintenance activities. 

For all construction projects, NREL implements an 

interdisciplinary planning and design process that includes 

NEPA review and 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 during 

construction for additional opportunities to reduce runoff 

volume 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 NREL staff. These documents are developed 

and reviewed for EPA-permitted sites as well as construction 

sites that do not require an EPA permit. 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. These projects 

follow elements of the NREL stormwater pollution prevention 

program, including the development of a site-specific erosion 

and sediment control plan. 

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.

NREL manages areas outside active construction sites to 

minimize erosion, promote infiltration of rain water and 

snowmelt, and prevent possible contamination of stormwater 

from exposure to materials stored outdoors. These objectives 

are accomplished through landscaping with native 

materials, revegetating site areas that have experienced a 

loss of vegetative cover, incorporating Low Impact Design 

elements in NREL design guidelines for new construction and 

redevelopment, and storing materials with the potential to 

contaminate stormwater either indoors or under cover.

Wastewater

NREL’s wastewater management program is multi-faceted 

and encompasses activities across the site, from the use 

of green cleaning supplies to minimization of harmful 

chemicals in laboratory operations. The program addresses 

the requirements of the Metro Wastewater Reclamation 

District, which receives and treats waste from the STM site, and 

protects the groundwater aquifer to which the leach fields at 

the NWTC drain. 

NREL has design guidelines for new building construction and 

refurbishment of existing buildings to minimize the possibility of 

a hazardous material discharge. Examples of these requirements 

include measures to preclude inadvertent spills to sink drains, 

prohibiting floor drains in laboratory areas unless a specific 

need can be shown, and mandatory caps for floor drains that 

are installed in laboratory areas. New research and operations 
Appendix A. Program Management Descriptions 67

activities, as well as ongoing activities that undergo significant 

modifications, are reviewed through NREL’s risk assessment 

process for their potential effect on wastewater. Regular training 

on appropriate rinsing and disposal practices when dealing with 

hazardous chemicals is provided to laboratory staff.

Hazardous Materials Management

In addition to EPCRA reporting obligations, a cornerstone 

of NREL’s hazardous material management program is its 

laboratory-wide chemical management system. The system 

serves as a centralized chemical inventory and is a valuable 

tool for managing and reporting 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’s database.

Key functions of the system include:

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

• Improving research efficiency and minimizing hazardous

waste generation by allowing staff to determine if needed

chemicals are already available on-site prior to making

chemical purchases

• Providing quick access to chemical inventories and hazard

information during emergency responses

• Facilitating accurate and efficient reporting to external

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

response agencies, EPA, and DOE).

The chemical management system tracks chemical amounts, 

locations, and hazards which help NREL to rigorously manage 

hazardous materials. 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 on 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 West Metro Fire 

Rescue, Rocky Mountain Fire Rescue, and the Jefferson County 

Local Emergency Planning Committee.

Hazardous Waste 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 in accordance with 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 members 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 non-hazardous materials are collected and disposed 

of 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 using 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.
68 Appendix A. Program Management Descriptions

Aboveground Storage

Tank Management

NREL’s 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 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

• 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, the 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.

Spill Prevention and Response

The laboratory prepares for and continually improves spill 

response procedures. Formal SPCC plans have been developed 

and are periodically updated for the NWTC, the STM site, and 

the Renewable Fuels and Lubricants Research Laboratory. The 

plans are designed to minimize the number and size of spills, 

as well as facilitate the efficient 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 5 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.

Radiological Materials

Through its radiation safety program, NREL has established 

strict protocols for radiation-generating devices, equipment 

containing sources of radiation, and for the use of 

radioisotopes in laboratory experiments. Some of these 

controls include:

• Confining work with radioisotopes to a small number

of specific laboratories

• Limiting the types and quantities of radioisotopes on site

• 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 use of radioactive 

materials. In lieu of monitoring, 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 

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.
Appendix A. Program Management Descriptions 69

NEPA

Once a project is proposed, the NEPA process is initiated and 

must be completed before the proposed project or activity 

begins. In accordance with regulations, all NREL activities (both 

on- and off-site) must undergo a NEPA review to evaluate and 

understand the potential environmental impacts of a project. 

The outcome of this review is the NEPA determination. A final 

NEPA determination must be signed before federal funds are 

expended, before a contract award can be made, and before 

project activities begin.

NREL and DOE Golden Field Office use Site-Wide Environmental 

Assessments (EAs) to streamline the environmental review 

process. These documents are comprehensive analyses of 

potential environmental impacts associated with NREL’s current 

and future actions over 5–10 years at both the STM site and 

the NWTC. The EAs 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 the NWTC 

provide a baseline environmental analysis that streamlines 

future environmental reviews, improves and coordinates site 

and agency planning, and maximizes cost savings.

NREL and the DOE Golden Field Office have developed several 

Programmatic NEPA Determinations to further streamline the 

environmental review process for recurring activities that have 

minimal environmental impacts. These activities generally 

involve business and administrative actions, information 

gathering and technical advice, and bench-scale research 

and development. The Programmatic NEPA Determinations 

are based on the existing Site-Wide EAs or DOE Categorical 

Exclusions and are reviewed annually for applicability and 

appropriateness.

Using the Site-Wide EAs and Programmatic NEPA 

Determinations, DOE and NREL analyze administrative, 

operational, and research activities and place each in one 

of three categories to streamline the environmental review 

process. Each category is briefly described below:

• Require No Further NEPA Review: Actions under this

category have been assessed by DOE and NREL and have

been determined to have negligible environmental impacts.

• Require a NEPA Sufficiency Review: These actions may have

minimal potential for environmental impacts but require a

sufficiency review by the NREL NEPA Coordinator.

• Require Further NEPA Review and Documentation by

DOE: Actions in this category have a greater potential for

environmental impacts, involve actions with a federal agency

or foreign government, or require the application of a

Categorical Exclusion. DOE must complete the NEPA review.

If proposed activities have not already been evaluated in an 

existing Site-Wide EA or Programmatic NEPA Determination, 

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. For example, a 

proposed construction project would receive a more rigorous 

review than routine office or laboratory work.

Wildlife Management

NREL’s wildlife management program was developed 

to implement measures to meet or exceed regulatory 

requirements and minimize or avoid impacts to wildlife species 

and their habitats while pursuing NREL’s mission. Regulatory 

requirements include the Migratory Bird Treaty Act, a state 

statute prohibiting the harassment of wildlife (including 

damaging/destroying dens or nests), a Memorandum of 

Understanding between DOE and the U.S. Fish and Wildlife 

Service to promote the conservation of migratory bird 

populations, and a presidential memorandum to promote the 

health of honey bees and other pollinators.

Several activities occur 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 mid-March and mid-September every 

year. If nests are found, the area is closed and a buffer area 

established until nestlings fledge. Staff also conduct site-wide 

surveys on a periodic basis to document biological conditions 

at NREL facilities. 

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 in concert 

with surveys for threatened and endangered species and 

habitats. Because habitat is as much a concern as the wildlife 

species themselves, program activities often overlap with 

vegetation management.

Other program goals include maintaining wildlife movement 

through the STM site by retaining access to the adjacent 

conservation easement north of the site and Pleasant View 

Community Park and Lena Gulch to the south. At the NWTC, 

ecologically sensitive areas and linkages with surrounding 

open space areas are preserved. 

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 
70 Appendix A. Program Management Descriptions

must be destroyed, mechanical methods are preferred over 

poisoning. When necessary, pesticides are selected that pose 

the least harmful effects to non-target wildlife

Endangered Species and 

Species of Concern

Periodic surveys are conducted at the NWTC and STM site to 

determine the presence/absence of species that are listed 

under the federal Endangered Species Act as threatened or 

endangered. These include the Preble’s meadow jumping 

mouse (Zapus hudsonius preblei), the Ute ladies’ tresses 

orchid (Spiranthes diluvialis), and the Colorado butterfly plant 

(Oenothera coloradensis). To date, none of these species have 

been identified at either of NREL’s main sites. Species listed 

by the U.S. Fish and Wildlife Service on the iPac site as species 

of special concern, as well as species listed by the state of 

Colorado as rare plants, species of concern, or species of 

greatest conservation concern are surveyed along with the 

federally listed species. These baseline surveys, which are 

typically conducted every five years, are a vital part of NREL’s 

NEPA program through which impacts to natural resources 

from mission activities are assessed.

The U.S. Fish and Wildlife Service designated critical habitat 

associated with the Preble’s meadow jumping mouse 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.

In accordance with the Endangered Species Act, the U.S. Fish 

and Wildlife Service lists five other species occurring in the 

Platte River watershed in Nebraska 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, consultation with the U.S. Fish and Wildlife Service 

must be completed to determine potential impacts.

Vegetation 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.

To maintain 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 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 relevant sitewide procedures. Integrated components of the plan include 

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 
Appendix A. Program Management Descriptions 71

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 of NREL’s main sites are assessed annually. 

Wildfire Risk Management

Because wildfires have the potential to affect DOE property 

and impact operational activities, NREL has developed a 

fire protection program that addresses wildfire. To protect 

buildings, infrastructure, and outdoor research from wildfire, 

NREL evaluates the wildland – urban interface on DOE 

properties. Areas within the interface are actively managed to 

reduce fuel sources. Management activities include mowing 

vegetation, herbicide application in graveled areas, and 

shrub and tree removal where applicable. At both the STM 

site and the NWTC, vegetation management is balanced 

with maintaining native vegetation and wildlife habitat. At 

the NWTC, water tanks are inspected regularly to ensure that 

firefighting resources are available should a wildfire occur.

Imported Plants and Organisms

NREL’s vegetation management program also addresses 

the use of certain animal and plant species brought to the 

laboratory for research purposes, primarily associated with 

biofuels and biomaterials investigations. Some of these 

animals (pathogens) and plant species obtained from other 

states or from outside the United State are controlled by the 

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

Inspections Service (APHIS) and require permitting to protect 

against their release into both the immediate work area 

and to the outside environment. In addition to the required 

management practices identified in APHIS-issued permits, 

management of these materials are also controlled through 

NREL’s Biosafety program. This program provides guidance 

to researchers on various aspects of working with biological 

materials, such as the identification of materials that can and 

cannot be used at NREL, when approvals are required by NREL’s 

Institutional Biosafety Panel, and good laboratory practices. 

Wetlands and Floodplains

NREL protects its wetlands and floodplains through

several means:

• Periodically surveying vegetation and wetland delineations

• Mapping of wetland areas potentially affected by

proposed construction

• Identifying potential impacts

• Coordinating with other jurisdictions on the control of

floodwaters leaving NREL’s STM site and the NWTC.

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

drainages and determined that they do not fit jurisdictional 

wetland criteria and are not currently regulated. The U.S. Army 

Corp of Engineers has not evaluated the NWTC site drainages 

to date. Functional wetlands, whether regulated or not, are 

considered valuable features that serve many ecological 

functions, and the laboratory seeks to preserve these to the 

maximum extent practicable from site development structures.

Cultural Resources

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 the presence

or absence of cultural or historic resources and working

with the Colorado Office of Archaeology and Historic

Preservation to determine how to proceed in the event any

evidence of cultural resources is discovered during surveys

or ground-disturbing activities. Workers are to stop all work

in the vicinity until a qualified archaeologist evaluates the

significance of the find.

Conservation Lands

Approximately 177 acres (72 hectares) at the STM site have 

been granted by DOE to Jefferson County as a conservation 

easement. This area is maintained by NREL as a natural 

landscape. 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.

At the NWTC, approximately 60 acres (24 hectares) of land are 

managed as a conservation area. Development is limited in this 

area, and it is managed 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.
72 Appendix B. Environmental Permits, Registrations, and Notifications

NREL obtains numerous permits and registrations to ensure 

environmental compliance. Photo by Alexis Powers, NREL 23815

APPENDIX B. 

ENVIRONMENTAL PERMITS, 

REGISTRATIONS, 

AND NOTIFICATIONS

Table 9. NREL’S Environmental Permits, Registrations, and Notifications in 2017

NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2017

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 Completed

Air STM SERF, 2 CFC-containing

stationary sources

Registration APCD 647 Completed

Air STM FTLB waste gas combustor Permit APCD 99JE0400 Active
Appendix B. Environmental Permits, Registrations, and Notifications 73

NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2017

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

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

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

Air NWTC Composites Manufacturing 

Education and Technology facility 

composite demonstration facility

APEN APCD 16JE0934 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
74 Appendix B. Environmental Permits, Registrations, and Notifications

NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2017

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

Animals, 

Plants

CIP to import flax (Linum usitatissimum) 

from Canada

Permit APHIS PCIP-17-00534 Active

Animals, 

Plants

CIP to import Agrobacterium tumefaciens

from within the U.S.

Permit APHIS P526P-16-03695 Active

Animals, 

Plants

CIP to import Goronia, Aquitalea, 

Cupriavidus, Gulbenkiania, 

Novosphingobium, Pseudogulbenkiania, 

Roseatles from Puerto Rico or

U.S. Virgin Islands

Permit APHIS P526-16-00476 Active

Animals, 

Plants

CIP to import Napier grass (Pennisetum 

spp.), Sugarcane (Saccharum officinarum) 

bagasse from Japan, Columbia and

other countries

Permit APHIS PCIP-15-01301 Expired

Animals, 

Plants

CIP to import Sugarcane leaves and plant 

tops from Brazil and other countries

Permit APHIS PCIP-16-00369 Expired

Drinking 

water system

NWTC drinking water system ID number Registration WQCD CO0230860 In Effect; Does 

Not Expire

Groundwater 

well

STM FTLB groundwater monitoring 

well MW-FTLB-1

Permit DWR 301322 Active

Groundwater 

well

STM FTLB groundwater monitoring 

well MW-FTLB-2

Permit DWR 301323 Active

Groundwater 

well

STM FTLB groundwater monitoring 

well MW-FTLB-3

Permit DWR 301324 Active

Hazardous 

materials

STM WHF hazardous material storage 

and use permit

Permit WMFR 11408 Active

Hazardous 

materials

STM SERF hazardous material storage 

and use permit

Permit WMFR 11412 Active

Hazardous 

materials

STM S&TF hazardous material storage 

and use permit

Permit WMFR 11413 Active

Hazardous 

materials

STM FTLB hazardous material storage 

and use permit

Permit WMFR 11409 Active

Hazardous 

materials

STM IBRF hazardous material storage 

and use permit

Permit WMFR 11410 Active
Appendix B. Environmental Permits, Registrations, and Notifications 75

NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2017

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

Hazardous 

materials

STM Shipping and Receiving hazardous 

material storage and use permit

Permit WMFR 11411 Active

Hazardous 

materials

DWOP building 16 hazardous material 

storage and use permit

Permit WMFR 11407 Active

Hazardous 

materials

ReFUEL hazardous material storage and 

use permit

Permit Denver Fire 

Department

165636 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 COD983902448 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

Stormwater STM electrical upgrade project Permit EPA COR12B06F Terminated

Stormwater STM SERF & S&TF Landscape 

Improvements/Site Improvements

Permit EPA COR10F00K Active

Stormwater NWTC Site Improvements,

Power Generation Upgrade, and 

Secondary Feeder

Permit EPA COR10F028 Active
76 Appendix B. Environmental Permits, Registrations, and Notifications

Acronyms used in the table:

APCD Air Pollution Control Division of CDPHE

APEN Air Pollutant Emission Notice

APHIS Animal and Plant Health Inspection Service

of the U.S. Department of Agriculture

AST Aboveground Storage Tank

CDPHE Colorado Department of Public Health

and Environment

CFC Chlorofluorocarbon

CIP Controlled Import Permit

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 Colorado 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

JSF Joyce Street 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
Appendix C. Wildlife Species Observed at the STM Site and the NWTC 77

The following are lists of common and scientific names of 

wildlife species observed at the STM site and the NWTC. The 

species listed for the STM site were observed by staff and/

or observed in surveys completed in 1987, 2005, 2011, and 

2017. For 1987 survey results, please refer to NREL’s 2016 

Environmental Performance Report at: https://www.nrel.

gov/docs/fy17osti/68671.pdf. The species for the NWTC 

were identified during surveys completed in 1996, 2003, 2011, 

and 2016. For 1996 survey results, please refer to NREL’s 2015 

Environmental Performance Report at: https://www.nrel.gov/

docs/fy16osti/65807.pdf.

APPENDIX C.

WILDLIFE SPECIES 

OBSERVED AT THE STM SITE 

AND THE NWTC

A female Red-winged Blackbird (Agelaius phoeniceus) 

utilizing the wetland habitat in the STM site’s main 

detention basin. Photo by Dennis Schroeder, NREL 45399

Table 10. Wildlife Species at the STM Site

Species Common Name Scientific Name 2005 Survey 2011 Survey 2017 Survey

BIRDS

American Coot Fulica americana X

American Crow Corvus brachyrhynchos X X X

American Goldfinch Carduelis tristis X X

American Kestrel Falco sparverius X X X

American Pipit Anthus rubescens X X

American Redstart Setophaga ruticilla X X

American Robin Turdus migratorius X X X

American Tree Sparrow Spizella arborea X X

American White Pelican Pelecanus erythrorhynchos X

Bald Eaglea Haliaeetus leucocephalus

Barn Swallow Hirundo rustica X X

Black-billed Magpie Pica hudsonia X X X

Black-capped Chickadee Poecile atricapilla X X

Black-crowned Night Heron Nycticorax nycticorax X
78 Appendix C. Wildlife Species Observed at the STM Site and the NWTC

Species Common Name Scientific Name 2005 Survey 2011 Survey 2017 Survey

Black-headed Grosbeak Pheucticus melanocephalus X

Black Swift Cypseloides niger X

Blue-gray Gnatcatcher Polioptila caerulea X

Blue Jay Cyanocitta cristata X X

Brewer’s Blackbird Euphagus cyanocephalus X

Brewer’s Sparrow Spizella breweri X X

Broad-tailed Hummingbird Selasphorus platycercus X X

Broad-winged Hawk Buteo platypterus X

Brown-headed Cowbird Molothrus ater X X X

Bullock’s Oriole Icterus bullockii X 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 X

Chestnut-collared Longspur Calcarius ornatus X

Chipping Sparrow Spizella passerina X X

Clay-colored Sparrow Spiella pallida X

Cliff Swallow Petrochelidon pyrrhonota X X

Common Grackle Quiscalus quiscula X X

Common Nighthawk Chordeiles minor X X X

Common Raven Corvus corax X X X

Common Yellowthroat Geothlypis trichas X

Cooper’s Hawk Accipiter cooperii X X

Dark-eyed Junco Junco hyemalis X X X

Double-crested Cormorant Phalacrocorax auritus X X

Eastern Kingbird Tyrannus tyrannus X

Eurasian Collared-Dove Streptopelia decaocto X

European Starling Sturnus vulgaris X X X

Golden Eagle Aquila chrysaetos X

Grasshopper Sparrow Ammodramus savannarum X
Appendix C. Wildlife Species Observed at the STM Site and the NWTC 79

Species Common Name Scientific Name 2005 Survey 2011 Survey 2017 Survey

Gray Catbird Dumetella carolinensis X

Great Blue Heron Ardea herodias X X

Great Horned Owl Bubo virginianus X

Green-tailed Towhee Pipilo chlorurus X

Hammond’s Flycatcher Empidonax hammondii X

Hepatic Tanager Piranga flava X

Hermit Thrush Catharus guttatus X

Horned Lark Eremophila alpestris X

House Finch Carpodacus mexicanus X X X

House Sparrow Passer domesticus X X X

House Wren Troglodytes aedon X X

Killdeer Charadrius vociferous X X

Lark Bunting Calamospiza melanocorys X

Lark Sparrow Chondestes grammacus X X

Lazuli Bunting Passerina amoena X

Lesser Goldfinch Carduelis psaltria X X

Lincoln’s Sparrow Melospiza lincolnii 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 X

Northern Mockingbird Mimus polyglottos X

Northern Pygmy-Owl Glaucidium californicum X

Northern Rough-winged 

Swallow

Stelgidopteryx serripennis X

Northern Saw-whet Owla Aegolius acadicus

Orange-crowned Warblera Oreothlypis celata
80 Appendix C. Wildlife Species Observed at the STM Site and the NWTC

Species Common Name Scientific Name 2005 Survey 2011 Survey 2017 Survey

Osprey Pandion haliaetus X X

Peregrine Falcon Falco peregrinus X

Pine Siskin Carduelis pinus X

Prairie Falcon Falco mexicanus X X

Red-breasted Nuthatch Sitta canadensis X X

Red-tailed Hawk Buteo jamaicensis X X

Red-winged Blackbird Agelaius phoeniceus X

Rock Dove Columba livia X X

Rock Wren Salpinctes obsoletus X

Ruby-crowned Kinglet Regulus calendula X

Sage Thrasher Oreoscoptes montanus X X

Say’s Phoebe Sayornis saya X X

Sharp-shinned Hawk Accipiter striatus X X

Spotted Towhee Pipilo maculates X X

Swainson’s Hawk Buteo swainsoni X

Tree Swallow Tachycineta bicolor X X X

Turkey Vulture Cathartes aura X X

Vesper Sparrow Pooecetes gramineus X X

Virginia’s Warbler Oreothlypis virginiae X

Violet-green Swallow Tachycineta thalassina X X

Western Kingbird Tyrannus verticalis X X

Western Meadowlark Sturnella neglecta X X

Western Sandpiper Calidris mauri X

Woodhouse’s (Western)

Scrub-Jay

Aphelocoma californica X X

White-crowned Sparrow Zonotrichia leucophrys X X

White-faced Ibis Plegadis chihi X

White-throated Swift Aeronautes saxatalis X

Wilson’s Snipe Gallinago delicata X

Yellow Warbler Setophaga petechia X

Yellow-breasted Chat Icteria virens X X

Yellow-rumped Warbler Dendroica coronata X
Appendix C. Wildlife Species Observed at the STM Site and the NWTC 81

Species Common Name Scientific Name 2005 Survey 2011 Survey 2017 Survey

MAMMALS

Big brown bata Eptesicus fuscus

Black beara Ursus americanus

Black-tailed jackrabbit Lepus californicus X

Bushy-tailed woodrat Neotoma cinerea

Coyote Canis latrans X X

Deer mouse Peromyscus maniculatus X

Elka Cervus canadensis

Fox squirrel Sciurus niger X

Hoary bat Lasiurus cinereus X

Long-tailed weasel Mustela frenata X

Mexican woodrat Neotoma mexicana X X

Mountain cottontail Sylvilagus nuttalli X X

Mule deer Odocoileus hemionus X X

Prairie vole Microtus ochrogaster X

Raccoon Procyon lotor X X

Red fox Vulpes vulpes X

Striped skunk Mephitis X

Western harvest mouse Reithrodontomys megalotis X X

Western spotted skunk Spilogale gracilis X

White-tailed jackrabbit Lepus townsendii X

Yellow-bellied marmot Marmota flaviventris

REPTILES AND AMPHIBIANS

Bull snake Pituophis catenifer X

Plains garter snake Thamnophis radix X

Prairie lizard Sceloporus undulatus X

Racer Coluber constrictor X

Six-lined racerunner Cnemidophorus sexlineatus X

Tiger salamander Ambystoma tigrinum X X X

Western chorus frog Pseudacris triseriata X

Western (Prairie) rattlesnake Crotalus viridus X X

Woodhouse’s toad Bufo woodhousii X

a Species observed at a time other than during a survey
82 Appendix C. Wildlife Species Observed at the STM Site and the NWTC

Table 11. Wildlife Species at the NWTC

Species Common Name Scientific Name 2003 Survey 2011 Survey 2016 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 X

American Tree Sparrow Spizella arborea X

Bald Eagle Haliaeetus leucocephalus X

Barn Swallow Hirundo rustica X X X

Black-billed Magpie Pica hudsonia X X X

Black-capped Chickadee Poecile atricapillus X X

Blue-gray Gnatcatcher Polioptila caerulea X X

Blue Jay Cyanocitta cristata X

Brewer’s Blackbird Euphagus cyanocephalus X X X

Brewer’s Sparrow Spizella breweri X

Broad-tailed Hummingbird Selasphorus platycercus X X X

Broad-winged Hawk Buteo platypterus

Brown-headed Cowbird Molothrus ater X X

Bullock’s Oriole Icterus bullockii X X

Canada Goose Branta canadensis X 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 X

Common Raven Corvus corax X X X

Common Snipe Gallinago delicata X

Cooper’s Hawk Accipiter cooperii

Dark-eyed Junco Junco hyemalis X

Double-crested Cormorant Phalacrocorax auritus X X

Downy Woodpecker Picoides pubescens X
Appendix C. Wildlife Species Observed at the STM Site and the NWTC 83

Species Common Name Scientific Name 2003 Survey 2011 Survey 2016 Survey

Eurasian Collared-Dove Streptopelia decaocto X

European Starling Sturnus vulgaris X X X

Ferruginous Hawk Buteo regalis X X

Franklin’s Gull Larus pipixcan X

Golden Eagle Aquila chrysaetos X X

Grasshopper Sparrow Ammodramus savannarum X X X

Gray Catbird Dumetella carolinensis X X

Great Blue Heron Ardea herodias X X X

Great Horned Owl Bubo virginianus X X

Greater Roadrunnera Geococcyx californianus

Green-tailed Towhee Pipilo chlorurus X X

Hairy Woodpecker Picoides villosus X

Horned Lark Eremophila alpestris X X

House Finch Carpodacus mexicanus X X X

House Wren Troglodytes aedon X

Killdeer Charadrius vociferus X X

Lark Bunting Calamospiza melanocorys X

Lark Sparrow Chondestes grammacus X X

Loggerhead Shrike Lanius ludovicianus X

Long-billed Curlew Numenius americanus X

Mallard Anas platyrhynchos X X

Merlin Falco columbarius

Mountain Bluebird Sialia currucoides X X

Mountain Chickadee Poecile gambeli X

Mourning Dove Zenaida macroura X X X

Northern Flicker Colaptes auratus X X

Northern Goshawk Accipiter gentilis

Northern Harrier Circus cyaneus X X

Osprey Pandion haliaetus

Peregrine Falcon Falco peregrinus X X

Prairie Falcon Falco mexicanus X

Red-headed Woodpecker Melanerpes erythrocephalus X
84 Appendix C. Wildlife Species Observed at the STM Site and the NWTC

Species Common Name Scientific Name 2003 Survey 2011 Survey 2016 Survey

Red-tailed Hawk Buteo jamaicensis X X X

Red-winged Blackbird Agelaius phoeniceus X X X

Rough-legged Hawk Buteo lagopus 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 X

Sharp-shinned Hawk Accipiter striatus

Song Sparrow Melospiza melodia X X

Spotted Towhee Pipilo maculatus X X

Swainson’s Hawk Buteo swainsoni X

Townsend’s Solitaire Myadestes townsendi X

Tree Swallow Tachycineta bicolor X

Turkey Vulture Cathartes aura X X

Vesper Sparrow Pooecetes gramineus X X X

Western Kingbird Tyrannus verticalis X X X

Western Meadowlark Sturnella neglecta X X X

Western Wood Peewee Contopus sordidulus X

Wilson’s Snipe Gallinago delicata X

Wilson’s Warbler Wilsonia pusilla X

Yellow-rumped Warbler Dendroica coronata X

MAMMALS

Big brown bat Eptesicus fuscus X X

Black-tailed prairie doga Cynomys ludovicianus X

Bobcat Felis rufus X

Coyote Canis latrans X X

Deer mouse Peromyscus maniculatus X X

Desert cottontail Sylvilagus audubonii X X

Eastern red bat Lasiurus borealis X X

Elk Cervus canadensis X X

Fringed myotisb Myotis thysanodes X X

Hoary bat Lasiurus cinereus X X

Little brown myotisb Myotis lucifuaus X X
Appendix C. Wildlife Species Observed at the STM Site and the NWTC 85

Species Common Name Scientific Name 2003 Survey 2011 Survey 2016 Survey

Masked shrew Sorex cinereus X X

Meadow vole Microtus pennsylvanicus X X

Mexican woodrat Neotoma mexicana X X

Mountain lion Puma concolor X

Mule deer Odocoileus hemionus X X

Myotis bat Myotis sp. X X

Prairie vole Microtus ochrogaster X X

Silver-haired bat Lasionycteris noctivagans X X

Thirteen-lined ground squirrel Spermophilus tridecemlineatus X

Western harvest mouse Reithrodontomys megalotis X X

White-tailed deer Odocoileus virginiana X

REPTILES AND AMPHIBIANS

Boreal chorus frog Pseudacris maculata X X

Bull snake Pituophis catenifer X X

Northern leopard frogb Lithobates pipiens X

Tiger salamander Ambystoma tigrinum X

Western (Prairie) rattlesnake Crotalus viridus X X X

Woodhouse’s toad Bufo woodhousii X X

TERRESTRIAL ARTHROPODSc

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

a Species observed at a time other than during a survey

b

 Colorado State Species of Highest Conservation Need, Tier 1

c Terrestrial arthropod genera of specific concern were only surveyed in 2011 at the NWTC.
86 Appendix D. 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 surveys occurring at the 

STM site in 2017 and at the NWTC in 2016. Plant communities 

and species were identified for each site at that time, and 

changes from previous surveys are noted below.

STM 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 mesa slopes and toe 

areas. 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 in Figure 6.

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 (Anisantha tectorum), a 

noxious weed. Populations of diffuse knapweed (Acosta diffusa) 

and Dalmatian toadflax (Linaria genistifolia subsp. dalmatica) 

are scattered throughout the whole community. These two 

noxious weeds comprise approximately 1% of the short 

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 does 

hen and chicks (Echinocereus viridiflorus) and pincushion cacti 

(Coryphantha missouriensis and C. vivipara var. vivpara). Welldraining hillocks often support thick stands of needle-andthread grass (Hesperostipa comata) and yucca (Yucca glauca). 

Some short shrubs such as rubber rabbitbrush (Chrysothamnus 

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

skunkbrush (Rhus aromatica subsp. trilobata) occur infrequently 

in the short grassland area and concentrate along the rimrock 

areas. Several large hackberry trees (Celtis reticulata) are 

clustered at the very edge of the mesa top.

APPENDIX D.

PLANT COMMUNITIES AT THE 

STM SITE AND THE NWTC

An American vetch (Vicia americana) at the STM site. 

Photo by Brent Nelson, NREL 23877
Appendix D. Plant Communities at the STM Site and the NWTC 87

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 outcompeting 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 mixedgrass 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 such area 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 Visitors 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, 

with a large amount of bare soil, is notably sparse throughout 

this community. 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 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 
88 Appendix D. Plant Communities at the STM Site and the NWTC

Figure 6. STM site land cover types surveyed in 2017.
Appendix D. Plant Communities at the STM Site and the NWTC 89

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 observed9 no longer 

appears to support wetland vegetation. In 2002, cattail 

species near an old stock tank in the eastern-most drainage 

area 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 the areas at the site that 

have experienced surface disturbance to vegetation caused 

by human activities. These activities mostly occur on the 

perimeter of the buildings, roads, parking lots, and soil 

stockpile 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.

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

The grasslands at the NWTC fall into the xeric mixed-grassland 

community type identified and classified primarily on available 

soils and soil moisture, reflected in xeric mixed-grassland plant 

species assemblages.

A number of changes in vegetation patterns noted since the 

NWTC was previously mapped is discussed below by specific 

plant community. In addition, the plant communities are 

described and mapped as illustrated in Figure 7.

Mixed Grassland

This community is distinguished from the non-native grassland 

community by the higher cover of native grasses and forbs. 

Native species typically make up 50%–60% of the vegetative 

cover. Common grasses in this community include smooth 

brome, Kentucky bluegrass, Canada bluegrass, big bluestem, 

little bluestem, switchgrass, and purple three-awn. Common 

forbs in this community include scurfpea, fringed sage, prairie 

sage, and hairy golden aster.

Non-Native Grassland

The non-native grassland community is the most common 

community type at the NWTC and is dominated by introduced 

pasture grasses including smooth brome, Kentucky bluegrass, 

and Canada bluegrass. Non-native species make up 65%–90% 

of the vegetative cover in this community. Commonly 

observed forb species include alyssum (Alyssum simplex), 

Canada horseweed (Conyza canadensis), fringed sage 

(Artemisia frigida), prairie sage (Artemisia ludoviciana), scurfpea 

(Psoralidium tenuiflorum), and hairy golden aster (Heterotheca 

villosa). Native grasses within this community, particularly 

big bluestem and switchgrass, occur most frequently along 

roadside depressions, possibly due to higher soil moisture from 

captured precipitation runoff.

Disturbed Native Grassland

This community occurs along the northern fence line of NWTC. 

Total vegetative cover in this community ranges from 30%–

70%, and exposed soil in this community consists of coarse 

gravel. The proximity of this community to machinery and 

buildings, the abundance of exposed ground, and the gravelly 

soil texture indicate that this area has been significantly 

disturbed by human activity. However, this community had 

the highest vegetative cover of native grasses within NWTC. 

This community is dominated by purple three-awn, big 

bluestem, and switchgrass. Other commonly observed species 

in this community include non-native grasses such as smooth 

brome, and ruderal weed species including annual sunflower 

(Helianthus annuus), prickly lettuce (Lactuca serriola), common 

mullein (Verbascum thapsus), and bigbract verbena (Verbena 

bracteata).
90 Appendix D. Plant Communities at the STM Site and the NWTC

Non-Native Yucca Grassland 

This community is very similar in composition to the nonnative grassland community; however, it is distinguished by 

the presence of stands of yucca (Yucca glauca) shrubs. Yucca 

typically occurs as scattered individuals throughout the 

grassland communities at the NWTC. In the areas identified 

as non-native yucca grassland, yucca occurs at a higher 

density than in the surrounding grassland, and the structural 

change from the surrounding grasslands warrants its inclusion 

as a separate community. Dominant grass species in this 

community include downy brome (Bromus tectorum), smooth 

brome, Kentucky bluegrass, and intermediate wheatgrass 

(Thinopyrum intermedium).

Degraded Grassland

The degraded grassland community has been heavily 

influenced by human disturbance and is dominated by 

non-native and noxious grass species with minimal native 

vegetation (typically less than 10%). The dominant species 

in this community are downy brome and intermediate 

wheatgrass. Downy brome is a List-C Noxious Weed in 

Colorado. Near the southwest corner of the NWTC is an area 

containing significant bare soil that is dominated by annual 

and biennial weed species including kochia (Bassia scoparia), 

downy brome, and common sunflower. The soil in this area has 

a distinctive red color that is visible on recent aerial imagery. 

The degraded grassland community along the western 

boundary of the NWTC is possibly influenced by historic and 

ongoing disturbance that may originate from off-site activities.

Ponderosa Pine Woodland

This community occurs along a granite outcrop located in 

the northwestern corner of the project area. Dominant tree 

and shrub species include ponderosa pine (Pinus ponderosa), 

skunkbrush sumac (Rhus trilobata), wax currant (Ribes cereum), 

and wild plum (Prunus americana). Understory vegetation 

consists of native and non-native grass and forb species. 

Common species include smooth brome, crested wheatgrass 

(Agropyron cristatum), junegrass (Koeleria macrantha), sulphur 

cinquefoil (Potentilla recta), golden banner (Thermopsis 

rhombifolia), harebell (Campanula rotundifolia), and James’ 

nailwort (Paronychia jamesii).

Mixed Shrubland

The mixed shrubland community occurs on the southeast end 

of the same granite outcrop that supports the ponderosa pine 

woodland. The southeast end of this outcrop is lower and less 

exposed than where the ponderosa pine woodland occurs. 

10. Cowardin, Lewis M., Virginia Carter, Edward T. LaRoe, and Francis C. Golet. (1979). Classification of Wetlands and Deepwater Habitats of the United States. Washington, D.C.

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

12. Walsh Environmental Scientists and Engineers. (2011a). 2010-2011 Vegetation and Wildlife Surveys at the National Renewable Energy Laboratory National Wind Technology 

Center, Jefferson County, CO. Prepared for the National Renewable Energy Laboratory. Golden, CO.

Dominant shrub species include wax currant, skunkbrush 

sumac, chokecherry (Prunus virginiana), and western 

serviceberry (Amelanchier alnifolia). This community supports 

higher cover and diversity of native grasses and forbs than 

the surrounding non-native grassland community. Common 

grasses in this community include smooth brome, Kentucky 

bluegrass, big bluestem, junegrass, and sideoats grama 

(Bouteloua curtipendula). Common forbs include scurfpea, 

prairie sage, golden banner, hairy golden aster, and sulphur 

flower (Eriogonum umbellatum). An isolated group of hawthorn 

(Crataegus erthyropoda) shrubs occurs along the western site 

boundary within the NWTC site boundary. These trees are at 

the top of the slope and occur directly east of an active area of 

construction disturbance, which is outside the NWTC boundary.

Palustrine Emergent Wetland

Six wetlands were identified at the NWTC that fall into the 

palustrine emergent category.10 Dominant species in this 

community type include broadleaf cattail (Typha latifolia), 

Arctic rush (Juncus arcticus), common spikerush (Eleocharis 

palustris), and Nebraska sedge (Carex nebrascensis). Other 

commonly observed species include foxtail barley (Hordeum 

jubatum), Torrey’s rush (Juncus torreyi), cloaked bulrush (Scirpus 

pallidus), and willowherb (Epilobium) species. Patches of 

smooth brome, Kentucky bluegrass, big bluestem, and western 

wheatgrass (Pasocpyrum smithii) occur on the fringes of these 

wetland communities.

A large palustrine emergent wetland (PEM) occurs south of 

the solar array in Row 1. The southernmost road separates this 

large wetland from a second smaller wetland located along the 

southern fence line of the NWTC. These wetlands appear to be 

hydrologically connected and supported by seepage from a 

reservoir located south of the property boundary. Capture of 

surface water runoff may provide additional hydrology to these 

wetlands. The large wetland north of the road was previously 

identified by one consultant11; however, another consultant12

mapped this area as “mixed mesic grassland” dominated by big 

bluestem. Hydrological support has evidently increased since 

2011 as this area was dominated by obligate wetland species 

and surface water was present throughout the area during the 

2016 field surveys.

A second large PEM occurs in a seasonal pond located 

southwest of the ponderosa pine woodland community.

A consulting firm12 indicated that wetlands at this location 

depend on an elevated spring and early summer water table to 

support the wetland community. Standing water was observed 

in the pond during both of the 2016 field surveys. Dominant 
Appendix D. Plant Communities at the STM Site and the NWTC 91

species in this wetland are common spikerush and broadleaf 

cattail. In the uplands adjacent to this wetland community 

Canada bluegrass is the dominant grass species. Canada thistle 

(Cirsium arvense) and common mullein, both noxious weeds, 

were abundant on the west-facing slope above the pond.

A third large PEM occurs south of the solar array in Row 3.

This wetland consists of a large stand of cattails (Typha spp.) 

and foxtail barley surrounded by sandbar willow (Salix exigua) 

and plains cottonwood (Populus deltoides) trees.

Two small PEMs occur on slopes along the northern boundary 

of the project area. The first PEM is located in the northwest 

corner of NWTC, and the second occurs along the northern 

fence line adjacent to the parking lot of the administration and 

engineering building. Dominant species in the westernmost 

wetland are Nebraska sedge and Arctic rush. Prairie cordgrass 

and Arctic rush are dominant in the easternmost wetland. 

These wetlands occur on gentle slopes and appear to be 

supported by ground water seeps. Both of these wetlands 

were previously identified and mapped.

Headwater – Riparian Emergent Wetland

Headwater or riparian emergent wetland communities occur 

within the two prominent drainages located in the eastern 

half of NWTC (Figure 7). Both drainages show evidence of 

intermittent flow. The northernmost drainage is tributary 

to Coal Creek, and the southern drainage is a tributary 

to Rock Creek. Dominant species within these wetlands 

include Arctic rush, foxtail barley, Nebraska sedge, and 

prairie cordgrass (Spartina pectinata). Significant patches of 

Canada thistle, bull thistle (Cirsium vulgare), and common 

teasel (Dipsacus fullonum), all List-B noxious weeds, occur 

within the northernmost drainage. Other observed species 

include shortbeak sedge (Carex brevior), swordleaf rush 

(Juncus ensifolius), longstyle rush (Juncus longistylis), Torrey’s 

rush, common spikerush, and switchgrass. Occasional plains 

cottonwood trees and sandbar willow shrubs occur along 

these drainages.

Disturbed – Non-Habitat

These cover types 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. (These areas are not specifically called out in

Figure 7.)

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. (These areas are not 

specifically called out in Figure 7.)
92 Appendix D. Plant Communities at the STM Site and the NWTC

Figure 7. NWTC land cover types surveyed in 2016

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