NATIONAL RENEWABLE ENERGY LABORATORY 

ENVIRONMENTAL PERFORMANCE REPORT for 2002 

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

Prepared by: 

Environment, Safety & Security Office 

National Renewable Energy Laboratory 

NREL is a national laboratory of the 

U.S. Department of Energy and is 

Operated by Midwest Research Institute, Battelle, and 

Bechtel 

September 2003 
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NREL Environmental Performance Report- 2002 

 

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TABLE OF CONTENTS 

1 INTRODUCTION ............................................................................................................................................. 5

PURPOSE ................................................................................................................................................................... 5

BACKGROUND .......................................................................................................................................................... 5

SITE AND FACILITY DESCRIPTION............................................................................................................................ 7

SITE ENVIRONMENTAL CONDITIONS/FEATURES ................................................................................................... 12

1.1 South Table Mountain Site .................................................................................................................... 12

1.2 National Wind Technology Center ....................................................................................................... 14

1.3 Denver West Office Park ...................................................................................................................... 16

1.4 Joyce Street Facility .............................................................................................................................. 16

1.5 Renewable Fuels and Lubricants Research Laboratory ...................................................................... 16

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

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

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

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

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

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

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

4.2 Performance Indicators and Progress ................................................................................................. 26

4.3 Assessment and Improvement ............................................................................................................... 27

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

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

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

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

5.3 Ground Water Protection ..................................................................................................................... 36

5.4 Wastewater Discharge .......................................................................................................................... 38

5.5 Surface Water Protection (Storm Water) ............................................................................................. 39

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

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

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

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

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

5.11 Endangered Species/Species of Concern ............................................................................................. 55

5.12 Wetlands/Floodplains ........................................................................................................................... 57

5.13 Cultural Resources ................................................................................................................................ 57

5.14 National Environmental Policy Act (NEPA) ........................................................................................ 58

5.15 Radiological Program .......................................................................................................................... 59

6 CONSERVATION EASEMENT LANDS ................................................................................................... 62

7 REFERENCES ................................................................................................................................................ 63

8 APPENDICES ................................................................................................................................................. 65
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LIST OF FIGURES 

Figure 1.1 – Regional Map ................................................................................................ 8 

Figure 1.2 – ReFUEL Facility Location Map .................................................................... 9 

Figure 1.3 – STM Site Detail ........................................................................................... 10 

Figure 1.4 – NWTC Site Detail ....................................................................................... 11 

Figure 2.11.5 - South Table Mountain Site – N ViewWest end of the site ...................... 17 

Figure 1.62.2 - South Table Mountain Site – NW ViewWest view ................................. 17 

Figure 1.72.3 - South Table Mountain Site – E ViewNW and mesa top view ................. 18 

Figure 1.82.4 – South Table Mountain Site – SE ViewDenver West Office Park ........... 18 

Figure 1.92.5 – NWTC Site – NW View ........................................................................ 19 

Figure 1.102.6 – NWTC Site – NW View with Turbineresearch facilities ...................... 19 

 
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1.1 INTRODUCTION 

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

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

and Renewable Energy (EERE). The Midwest Research Institute, Battelle, and Bechtel 

operate NREL under the oversight of the DOE Golden Field Office (GO). NREL is the 

nation's premier laboratory for renewable energy research and development and a leading 

laboratory for energy efficiency research, with programs in wind energy, solar energy, plant 

and waste-derived fuels and chemicals, energy efficiency in buildings, geothermal energy, 

advanced vehicle design, and hydrogen infrastructure and fuel cells. 

Purpose 

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

activities for 2002. It is organized according to the different environmental media 

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

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

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

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

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

basis for the program overview. 

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

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

DOE guidelines for the 2002 Annual Site Environmental Report, as required by DOE 

Orders 231.1 and 5400.5. 

Background 

NREL’s mission: NREL develops renewable energy and energy efficiency 

technologies and practices, advances related science and engineering, and transfers 

knowledge and innovations to address the nation’s energy and environmental goals. 

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

major technology area follows. 

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

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

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

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

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

generation and facilitates its deployment throughout the world 

Formatted: Bullets and Numbering
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Bioenergy: NREL currently has major programs in both biomass-derived fuels 

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

Renewable Thermal Technologies: These technologies generate power from heat or 

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

water heating, and geothermal heat and power. 

Distributed Power: Distributed power is modular electric generation or storage 

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

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

efficiency technologies in distributed power systems, maximizing the deployment of 

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

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

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

Building Energy: NREL increases the use of energy efficiency technologies and 

expands the use of renewable energy technologies in the building sector by working 

to develop new, cost-effective, and environmentally acceptable building equipment 

and envelope systems. 

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

as well as in advanced storage and sensor development. Basic and applied research 

and material development using biology, physics, and chemistry enable and support 

the development of hydrogen production, storage, and end-use systems. 

Transportation: NREL works with industry to develop advanced vehicles and 

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

DOE transportation initiatives. NREL also works with energy companies and 

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

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

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

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

NREL’s renewable energy and energy efficient technologies. 

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

Electricity Technologies: These technologies include renewable energy, hydrogen, 

and superconductivity technologies, plus utility resources. 

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

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

photovoltaic cells, building technologies, and wind turbines. 

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

biomass, and geothermal energy applications. 

Site and Facility Description 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

the STM site, and Figure 1.4 is a more detailed map of the NWTC site. 

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

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

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

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

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

small shop complex housed within the RTD/DSOC facility. NREL performs engine 

testingengine-testing activities pertaining to fuels and lubricants at the site. 
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Figure 1.1 – Regional Map 

National Wind 

Technology Center 

Joyce Street 

Facility 
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Figure 1.2 – ReFUEL Facility Location Map 

RTD and 

ReFUEL 

LOCATION 

I-25 

I-70 
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Figure 1.3 – STM Site Map 
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Figure 1.4 – NWTC Site Map 

P
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Site Environmental Conditions/Features 

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

during 2002, are included at the end of this section. Figures 2.1, 2.2, 2.31.5, 1.6, 1.7

and 2.41.8 illustrate the South Table Mountain and Denver West Office Park sites, and 

Figures 2.5 and 2.61.9 and 1.10 illustrate the National Wind Technology Center site. 

The views on the STM site also illustrate the Conservation Easement property and the 

Camp George West property acquired in 1999. 

Climate 

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

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

daily and seasonal temperature variations. 

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

50 cm (20 in). Almost half of the annual precipitation occurs from March to June. 

Summer showers contribute 33% of the annual precipitation total. Precipitation 

begins to decrease significantly in the fall, and reaches the minimum during winter. 

Winter is the driest season, contributing less than 10% of the annual precipitation, 

primarily in the form of snowfall. 

Spring is a season of unstable air masses with strong winds along the foothills and the 

Front Range. The highest average snowfall occurs in March, and the STM site can 

generally expect to experience at least one heavy snowstorm with totals exceeding 15 

to 25 cm (6 to 10 in.). 

The solar radiation (sunlight energy) of the region is excellent for outdoor research 

and testing of solar energy conversion devices and systems. Sunshine is abundant 

throughout the year and remarkably consistent from month to month and season to 

season. 

1.1 South Table Mountain Site 

Geology, Soils, and Hydrogeology 

The STM site is a roughly triangular parcel of land occupying portions of the top, 

sides, and lower south-facing slopes of South Table Mountain. South Table 

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

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

150 meters above the adjacent lowlands. It was formed by the erosion of weak 

sedimentary rocks surrounding the mesa's erosion resistant lava capThe erosion of 

weak sedimentary rocks surrounding the mesa’s erosion resistant lava cap formed it. 

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

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

rocks of the Arapahoe Formation underlie the Denver Formation. 
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Both the Arapahoe and Denver Formations are considered to be aquifers in portions 

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

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

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

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

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

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

southeasterly direction. 

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

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

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

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

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

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

consists of clayey material containing some calcium carbonate. There are also two 

smaller soil areas on the southwestern portion of the site, both of similar character to 

other site soils: cobbly clay loam and very stony clay loam. 

Surface Water 

About 90% of the surface drainage off the site, both the mesa top and across the 

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

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

the site ultimately flows into Lena Gulch. 

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

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

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

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

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

Vegetation 

Two primary vegetation types are present on the STM site: grasslands and 

shrublands. The most common plant communities on the STM site are mixed 

grasslands, comprising over 80% of the vegetation on the site. These communities 

are generally dominated by short- and mid-grass species. Two primary upland shrub 

communities occur on the STM site: mountain mahogany shrublands, found on the 

shallow soils of the mesa, and, and upland shrublands, occurring in drainages lacking 

active channels as well as drainages with associated wetlands. Recent field surveys 

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

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

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

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

emergent wetlands. 
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Wildlife 

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

surveys were done in 1999 over the Conservation easement property. Mammals seen 

using the site during the surveys were the mule deer, coyote, greygray fox, red fox, 

raccoon, longtailedlong tailed weasel, striped skunk, spotted skunk, badger, bobcat, 

mountain lion, rabbits, and yellow-bellied marmots. Seventeen species of birds were 

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

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

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

inhabit the area. 

Land Use 

The STM site is a 325-acre area predominantly bordered by open grassland zoned for 

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

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

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

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

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

Colorado State Highway Patrol pursuit driver trainingdriver-training track are located 

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

County open space wraps around the northern and the eastern edge of the site. 

Portions of the DWOP and apartment homes lie to the east. 

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

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

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

Open Space. 

1.2 National Wind Technology Center 

Geology, Soils, and Hydrogeology 

The NWTC site is located on a plain formed by stream deposits. The uppermost 

geological layer beneath the site is known as the Rocky Flats Alluvium (RFA). It is 

composed of cobbles, coarse gravel, sand, and gravelly clay. Below the RFA are the 

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

consist primarily of claystones with some siltstones. Unconfined groundwater flow 

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

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

Rocky Flats, Inc., 1992). 

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

soil is characterized by a large amount of cobble and gravel in the soil volume, and a 

subsoil dominated by clay (USDA, 1995). 
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Surface Water 

The area surrounding the NWTC site is drained by five streams: Rock Creek, North 

Walnut Creek, South Walnut Creek, Woman Creek, and Coal Creek. Rock Creek 

flows eastward and is located southeast of the NWTC. North Walnut Creek and 

South Walnut Creek flow eastward into the Great Western Reservoir. Woman Creek 

drains eastward into Standley Lake. Coal Creek flows in a northeasterly direction 

across the City of Boulder open space north of the NWTC. 

The majority of the NWTC drains into a tributary to Rock Creek. Some of the 

northern portions of the site drain into Coal Creek or its tributaries. 

Vegetation 

The NWTC is located in the transition area between the Great Plains and the Rocky 

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

contains elements from both mountain and prairie ecosystems and associations that 

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

foothill ravine flora (Plantae Consulting Service, 2000). 

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

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

including the following: seasonal wetlands/or ephemeral hydric soils, woodlands, 

shrublands, mixed grasslands, and disturbed areas. 

Along the Northwestern ridge is a Ponderosa pine woodland area. Vegetation found 

in this area includes woody species with an understory of grasses, forbs, and shrubs. 

Wildlife 

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

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

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

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

mule deer, coyotes, desert cottontail rabbits, white-tailed jackrabbits, black-tailed 

jackrabbits, deer mice, prairie voles, and thirteen-lined ground squirrels. 

Approximately 20 different species of birds were sighted at or near the site. Raptor 

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

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

also conducted in 2001 to 2002; it is described further in Section 5.10. Although 

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

amphibian species are known to occupy the area. 

Land Use 

The NWTC facility occupies a 305-acre area surrounded by open grazing land, with 

the exception of operations at the Rocky Flats Environmental Technology Site, which 

borders the NWTC to the southeast, and a sand and gravel mining operation along the 

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

installation along the western site boundary. 
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A piece of land of about 25 acres, located at the southeast corner of the NWTC, was 

recently designated for inclusion within the NWTC by the National Defense 

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

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

in 2003.

1.3 Denver West Office Park 

The DWOP is a relatively flat, landscaped office complex occupied by a number of 

four-story buildings, parking lots, and common areas. NREL-leased facilities at 

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

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

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

site. DWOP is within the City of Lakewood. 

1.4 Joyce Street Facility 

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

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

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

and there are no staff offices at JSF. 

1.5 Renewable Fuels and Lubricants Research Laboratory 

The ReFUEL facility is used for research, testing, and support activities related to 

advanced fuels, engines, and vehicles to objectively evaluate performance, emissions, 

and energy efficiency impacts. The laboratory will also be used to evaluate and 

develop heavy hybrid electric vehicles. 

 

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

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

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

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

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

general area is highly developed with concentrated industrial and commercial 

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

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

south, east and northeast. 
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Figure 1.5 – STM Site – Aerial view looking northwest, showing facilities and 

Conservation Easement lands.at the western end of the site.

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

acquired in 1999, and portions of the Pleasant View neighborhooda portion of the Pleasant View neighborhood, 

and the Conservation Easement lands. 
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Figure 1.7 – STM Site – View looking eastnorthwest at the historic amphitheater and the mesa top facilities. 

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

Figure 1.8 – STM Site – View looking southeast, showing portions of 

Pleasant View and northwest, over Interstate 70 at the NREL/DOE buildings in the Denver West Office Park. 
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Figure 1.9 – NWTC – View looking northwest 

Figure 1.10 – NWTC – NW View withView to the northwest with research facilities shown. Turbine
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2 COMPLIANCE SUMMARY 

2.1 Laws and Regulations 

Air Quality Protection 

Clean Air Act implementing regulations are administered for all point sources 

(facilities or other types of operations) in Colorado by the Colorado Department of 

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

and Environment (CDPHE) administers Clean Air Act implementing regulations for 

all point sources (facilities or other types of operations) in Colorado, under authority 

delegated by the U.S. Environmental Protection Agency (EPA). NREL holds two sitewide permits for particulate air emissions from construction and one air emissions 

permit for a pilot scale research project. Detailed information about NREL’s air 

quality protection program is provided in Section 5.1. 

National Emissions Standards for Hazardous Air Pollutants (NESHAPs) requirements 

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

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

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

Drinking Water Quality Protection 

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

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

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

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

efforts is provided in Section 5.2. 

Ground Water Quality Protection 

Colorado ground water standards are established by the Colorado Department of 

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

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

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

is provided in Section 5.3. 

Waste Water 

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

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

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

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

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

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

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

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

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

Jefferson County Department of Health and Environment. There is also one 
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individual sewage disposal system at the Solar Radiation Research Laboratory on the 

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

system regulations are administered by Jefferson County. Additional detail about 

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

Surface Water Quality Protection 

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

Colorado rests with EPA. NREL holds two site-wide permits for the STM and NWTC 

sites for storm water discharge from construction areas; no permits for NREL 

operations are required. Details of NREL’s surface water protection program are 

provided in Section 5.5. 

Waste Management

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

hazardous waste. In Colorado, CDPHE implements hazardous waste regulations 

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

each of its sites. NREL’s waste management program is outlined in Section 5.6. 

Pollution Prevention efforts at NREL are described in Section 5.9. 

Storage Tanks

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

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

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

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

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

NREL’s tank program are provided in Section 5.7. 

Threatened and Endangered Species/Species of Concern 

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

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

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

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

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

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

Section 5.11. 

EPCRA Compliance and Prevention of Toxic Releases: 

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

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

Release Inventory reductions for government facilities. NREL maintains hazardous 

materials permits with West Metro Fire Protection District and provides chemical 

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

In 2002, NREL facilities had no release exceeding the reportable quantity (RQ) of any 

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

site that exceeded the EPCRA threshold planning quantity for each chemical, so 
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MSDSs and Tier II reports were filed with the state and local emergency planning 

organizations and with the fire department. 

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

any materials, and during 2002, the Laboratory did not otherwise use any materials on 

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

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

Section 5.8. 

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

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

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

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

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

Cultural Resources Protection 

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

National Historic Preservation Act and the Native American Graves Protection and 

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

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

Cultural Resources program is described in Section 5.13. 

2.2 Executive Orders 

Executive Order 13148 

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

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

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

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

compliance with these requirements is explained below. 

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

implement environmental management systems, comply with environmental 

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

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

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

sustainable landscaping practices to reduce adverse impacts on the environment. 

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

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

respectively. Compliance with environmental regulations at NREL, including EPCRA 

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

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

Executive Order 11988, Floodplains Management: 
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According to maps generated by the Jefferson County Department of Highways and 

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

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

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

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

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

Actions undertaken by NREL at subcontractor facilities are assessed for potential 

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

checklist. 

Executive Order 11990, Wetlands Protection: 

Limited wetland areas totaling less than 0.2 ha (0.50 ac) occur on the STM site in the 

drainage bottom located north of the Visitor’s Center. These are narrow, linear 

wetlands supporting spikerush, baltic rush, sedges, bluegrass, hemlock, and field mint. 

These wetlands will be protected from adverse impacts as site development continues. 

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

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

protected from adverse impacts. 

2.3 Permit Summary 

A table summarizing NREL’s permits, registrations, and notifications isnotifications 

are provided in Appendix A. 
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3.3 ENVIRONMENTAL OCCURRENCES 

There were two incidents with environmental implications during 2002 at the STM 

site, and two at the NWTC. 

At the STM site on April 11, 2002, approximately 3 gallons of dilute ammonia 

hydroxide leaked from an Ammonia Test Loop at the FTLB. A portion of the leak 

escaped containment and leaked into the adjoining area. The NREL Emergency 

Response Team was activated. The spilled material was cleaned up without any 

releases to the floor drains or the environment. 

Also at the STM site on December 27, 2002, there was a fire in a laboratory exhaust 

ventilation hood at the SERF. It was caused by residue of a pyrophoric material in a 

pipette in the hood. The contents of the hood were consumed, but the fire was 

contained to the hood.

At the NWTC site, on January 18, 2002, the transmission filter on a construction-type 

forklift burst, spilling two to three quarts of oil onto the ground. Spilled oil and 

contaminated soil were cleaned up. The investigation determined that the filter was 

clogged. The service interval frequency will be increased. There was no long-term 

environmental damage to the site and no reportable releases as a result of this incident. 

On July 2, 2002, at the NWTC, a semi-truck delivering a 1.5 MW nacelle for testing 

was not properly disconnected from its trailer. The hydraulic lines separated, spilling 

about 8 to 10 gallons of hydraulic oil onto the gravel driveway. Oil saturated soil was 

collected for disposal. There was no long-term environmental damage to the site and 

no reportable releases as a result of this incident. 

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4 ENVIRONMENTAL MANAGEMENT SYSTEM 

4.1 Description 

Environmental protection is a priority at NREL. NREL is committed to sound 

environmental management that embodies its mission to protect the Earth’s natural 

resources through research, development, and deployment of renewable energy and 

energy efficiency technologies. 

The EMS is in place to implement NREL’s environmental policy, and is comprised of 

a framework of policies and procedures that are integrated with NREL’s normal 

management processes, combined with the environmentally sound daily work 

practices of Environment, Safety & Security (ES&S) Office staff and staff throughout 

the Laboratory. Environmental protection must involve everyone at the Lab in order 

for it to be effective. All activities conducted at NREL must comply with federal and 

state laws and regulations, and DOE requirements. 

NREL’s EMS focuses on applying sustainability concepts to the design and operation 

of its campuses and facilities; protecting natural and cultural resources; and 

incorporating pollution prevention practices in research and support activities. NREL 

strives to provide leadership within the community in sustainability and environmental 

excellence through consistently high performance and open, responsive 

communications. Another vital component of NREL’s EMS is compliance with all 

applicable federal, state, and local environmental requirements, exceeding those 

requirements whenever feasible by implementing environmental best management 

practices. 

As a DOE-owned facility, NREL implements an EMS (EMS) as part of a Integrated 

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

Management Policy (6-2) and 18 supporting Lab-level environmental programs that 

define the NREL EMS have been carefully coordinated and linked with the ISM 

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

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

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

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

4.2 Performance Indicators and Progress 

2002 Environmental Objectives and Progress Toward Goals 

Each fiscal year, NREL in collaboration with the DOE Golden Field Office (DOEGO) develop environmental objectives for the upcoming year. For fiscal year 2002, 

the objectives were: 

 Complete NWTC Environmental Assessment (EA)

 Prepare STM Site-Wide EA

 Increase environmental support staff

 Continue support for geothermal program activities
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The NWTC Site-wide EA was completed in May 2002. It is an excellent planning 

tool for activities at the NWTC in that it describes the potential environmental impacts 

of proposed research and site development projects, and outlines any measures that 

must be taken to minimize the potential for adverse impacts. 

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

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

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

coordinated with the NREL General Development Planning process that began in June 

2002. 

An additional environmental staff member was hired to share the workload, primarily 

in the areas of environmental permitting and compliance as well as National 

Environmental Policy Act (NEPA) support. 

An Environmental Assessment (EA) of a potential site for a small-scale geothermal 

power plant in Animas, New Mexico was completed in 2002. An EA for a geothermal 

district heating project in Canby, California was initiated in August 2002; the EA was 

completed in February 2003, and project construction began in the spring of 2003. 

4.2.12003 Objectives 

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

fiscal year 2003 are: 

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

 Complete the STM Site-Wide Environmental Assessment 

 Coordinate Sustainable NREL with NREL’s EMS 

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

 Implement improvements identified through assessments and reviews. 

Progress toward the 2003 goals will be reported in the NREL 2003 Environmental 

Performance Report. 

4.3 Assessment and Improvement 

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

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

maintain compliance with regulatory and legal requirements, meet the established 

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

environmental goals. Assessment and management review also provide for 

continuous improvement of the EMS. 

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

of the EMS at NREL: annual EMS assessments, periodic compliance assessments, 

and third-party audits. 

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

NREL staff. The team generally includes NREL Environment, Safety & Security staff 

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

includes both the management of significant environmental aspects and policy 

implementation. The team evaluates the EMS based on an appropriate set of criteria, 

such as ISO 14000 standards, EPA National Environmental Performance Track 

standards, or other applicable environmental management standard. The assessment 

team selects the most appropriate set of criteria for each assessment. 

Periodic compliance assessments are conducted of individual environmental programs 

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

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

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

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

assessments. These are conducted in coordination with the DOE Golden Field Office 

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

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

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

environmental programs that are part of the EMS. The Waste Management and 

Minimization Program was originally scheduled to be evaluated in 2002, but was 

actually completed in 2003. 

In addition to regular compliance assessments of individual NREL environmental 

programs, NREL has EMS auditing processes in place for regular reviews and updates 

of the set of policies, Lab-level programs, and task specific procedures. NREL 

reviews its ES&H policies as needed, but at least every 4 years, and makes revisions 

as necessary. All SOPs are reviewed on an annual basis and are revised as necessary 

to help ensure the required controls are appropriate for the hazards present. 

Environmental hazards and controls are specifically called out in each SOP. 

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

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

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

regulatory agencies may periodically conduct assessments for compliance with 

environmental programs, at the discretion of the agency. 

2002 Assessment Activities 

In August 2002, a third party assessment of NREL’s EMS was conducted. This also 

served as the annual EMS assessment for 2002 and provided the opportunity for 

management review. The assessment was performed using criteria from ISO 14001, 

EMAS, and EPA National Environmental Performance Track standards. A summary 

of the assessment results follows. 

The assessors felt it was clear that NREL management and staff are committed to 

proactive environmental management. It was also apparent that the overall 

environmental goal of the organization is to move to a position ‘beyond compliance’ 
NREL Environmental Performance Report- 2002 

 

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with a focus on environmental performance, which is particularly evident through the 

strong senior management support for programs such as Sustainable NREL. The 

assessors believed that NREL is taking the right steps in being proactive to anticipate 

change and to strive for environmental leadership, with Sustainable NREL being a 

good example of this. 

The EMS is in a mature phase of implementation, however, in comparison with 

industry accepted best practices, such as ISO 14001, there are system elements that are 

missing. In order to more closely meet industry best practice the areas that require 

particular attention are: 

 Environmental Policy – Develop and implement a distinct Environmental 

Policy statement that describes the environmental statement of intent or 

principles of actions of NREL, with commitment from the senior management 

to uphold. There are currently several policies that reference environmental 

management, and the assessors felt this could cause confusion. 

 Environmental Aspects – To ensure and demonstrate that the most significant 

environmental impacts are being effectively and efficiently managed NREL 

needs to formalize a process to identify and evaluate the environmental 

aspects, both direct and indirect. 

 Objectives and Targets – There needs to be a clear link of NREL’s 

environmental objectives and targets to the environmental policy and 

significant environmental aspects. Performance improvement related 

objectives and targets should also be established. 

 EMS Auditing and Management Review – The internal audit process needs to 

be formalized, and should include internal audits / assessments of the EMS. 

The assessment concluded that the EMS in place has enormous potential to assist in 

achieving the goals of sustainability, and supporting the Sustainable NREL program. 

However, there needs to be more effort focused on ensuring that the Sustainable 

NREL and EMS are complementary and mutually supportive, and that duplication of 

work is avoided. This may be achieved through ensuring that key staff in both the 

ES&S office and the Sustainable NREL program have a clear understanding of the 

purpose, goals and operation of each program, to assist in identifying areas that are 

mutually beneficial. For example, the Sustainable NREL Environmental Stewardship 

Goals may be achieved through establishing them as EMS performance objectives and 

targets. It is very common for such goals to be set as objectives and or targets as part 

of the organizational environmental management systems, and to use the EMS to 

provide a systematic approach to the implementation and achievement of such goals 

(e.g. through, as appropriate: establishing management programs or action plans, 

assigning responsibility, providing training, establishing or revising operational 

controls, monitoring and recording measurements, auditing or assessing progress over 

time, and periodically reviewing and revising goals). 

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4.4 Sustainability and the Environmental Management System 

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

the world. Sustainability at NREL, in the sense of an organization and its operations, 

is the simultaneous and balanced pursuit of economic viability, environmental 

stewardship and public responsibility over the long-term through appropriate 

investment decisions and operating practices. 

 

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

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

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

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

economic, environmental, and community responsibility. Sustainability is defined as 

the simultaneous and balanced pursuit of economic viability, public responsibility, and 

environmental stewardship. Elements of the environmental stewardship component 

include: 

 Campus and Transportation 

 Water, Electricity, and Natural Gas 

 Reduce, Reuse, Recycle, Rebuy 

 Education and CommunicationsEnvironmental Management 

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

operations, designing energy efficient and environmentally sensitive new buildings, 

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

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

operations, and creating less waste by reducing, reusing and recycling materials for 

Laboratory operations. 

The environmental management component of Sustainable NREL is implemented 

through the EMS, with the EMS focus on exceeding requirements in order to protect 

the natural and cultural resources on and around NREL sites and to minimize any 

potential impacts NREL’s activities could have on the environment. There is also 

overlap between the EMS and some of the other components of Sustainable NREL. 

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

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

 Pollution Prevention activities are discussed in Section 3.9, Pollution 

Prevention. 

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5 ENVIRONMENTAL PROGRAMS 

The objective of NREL’s Environmental Management System and its implementing programs 

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

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

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

integrated throughout all research and operations Centers and Offices. The EMS includes 

written environmental protection policy and program implementation documents. These are 

put into practice at all staff and management levels. 

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

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

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

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

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

activities that have occurred throughout the year. 

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

Appendix A. These permits are discussed in the relevant sections below. 

5.1 Air Quality Protection 

5.1.1 Program Management 

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

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

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

Emissions Control for Construction (6-2.14). 

Criteria, Hazardous, and Non-Criteria Pollutants 

The Clean Air Act and State of Colorado laws and regulations delineate 

several main categories for air pollutants: 

 Criteria air pollutants (e.g. carbon monoxide, nitrogen oxides, sulfur 

dioxide, particulate matter, ozone, and lead) 

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

compounds, metallic compounds, and corrosives) 

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

corrosives, asbestos, radionuclides, and pesticides) 

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

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

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

NREL include boilers, emergency generators, experimental laboratory hoods, 

pilot scale research projects, and small pieces of equipment with gasoline or 
NREL Environmental Performance Report- 2002 

 

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

emissions and identify whether notification and permitting could be required 

for a particular facility or activity. Fugitive particulate emissions from 

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

Ozone Depleting Substances 

Facilities that service refrigeration equipment containing ozone-depleting 

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

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

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

certified technicians on staff that perform this type of service. 

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

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

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

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

one at the DWOP. 

Halon-based fire suppression systems previously used at NREL were 

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

facilities for “banking”. 

Street Sanding 

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

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

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

CDPHE. During the period of December 2001 to April 2002 NREL used 17 

tons of sand during 9 sanding episodes. During the period of October 2002 to 

March 2003, NREL used 31 tons of sand during 13 sanding episodes. NREL 

maintains 4 lane-miles of roads. 

5.1.2 Permitting 

Most potential sources of air emissions from NREL laboratory and facility 

operations in 2002 were small scale and did not require permitting. Permitting 

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

pollutant. Projected emissions for these sources were either below thresholds 

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

to be negligible in terms of impacts to the environment. 

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

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

other is in effect for the NWTC. NREL also holds one air emissions permit for 

an experimental pilot process (See Section 5.1.3). 
NREL Environmental Performance Report- 2002 

 

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5.1.3 2002 Activities 

No APENS were filed in 2002. 

Final permitting approval was obtained in April 2002 for the proposed scale-up 

of the experimental pilot scale Thermochemical Process Development Unit 

(TCPDU), located at the Field Test Laboratory Building on the STM Site. 

5.2 Drinking Water 

5.2.1 Program Management 

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

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

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

water supply, Consolidated Mutual Water Company. Water to the JSF is also 

provided by a public water supply. NREL supplies drinking water to its 

NWTC by trucking in water from the Boulder public water supply through a 

subcontracted water hauler. NREL stores the water on site in an underground 

15,000 gallon,000-gallon storage tank and an above ground 2000 gallon2000-

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

and water is pumped on demand to the 2000 gallon2000-gallon tank, where it 

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

Disinfection boosting is performed at the NWTC using a chlorine disinfection 

system, which was installed in June of 2000. An ultraviolet lamp system 

previously used for disinfection boosting was removed in November 2000. 

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

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

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

 Bacteria – monthly 

 Lead and copper – triennially 

 Chlorine residual – monthly, or more frequently as needed 

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

coliform was detected in any of the samples taken during 2002. 

Monitoring for lead and copper was completed as scheduled during the 

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

sampling is not required again until the summer of 2005. 

Chlorine residual monitoring of the NWTC drinking water system began with 

the installation of the chlorine disinfection system in 2000. Monitoring is 
NREL Environmental Performance Report- 2002 

 

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

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

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

that chlorine residual monitoring occur when collecting bacterial samples 

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

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

the NWTC. Monitoring results have shown the concentration of residual 

chlorine to be detectable since the chlorine disinfection system became 

operational. 

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

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

filtered on site using a 1 micron1-micron filter. This would filter out any 

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

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

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

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

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

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

filtration operations and to perform the necessary sampling. 

5.2.2 Permitting 

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

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

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

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

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

PWSID, Consolidated Mutual Water Company, and NREL does not alter or 

treat the water in any way. 

5.2.3 2002 Activities 

An updated Operator in Responsible Charge report was filed with the State in 

2002, as required. This report identifies NREL’s licensed operator. It will be 

kept current in the event NREL’s operator changes. 

In November of 2001 drinking water monitoring was performed in the FTLB, 

on the STM site, in response to building occupant concerns regarding the poor 

taste of the water. The monitoring results did not point to a source of the poor 

water taste, but revealed elevated levels of lead at a number of taps. Low 

levels of chlorine and elevated levels of turbidity were also detected at one of 

the drinking fountains. Extensive follow-up drinking water monitoring was 

performed for lead throughout the FTLB, which revealed that lead 

contamination was isolated to a few water outlets within the building. Filters 
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that remove lead were placed on the outlets that are used for drinking water 

and tested positive for lead. The remaining outlets testing positive for lead 

have restricted access and are not intended for drinking water purposes (i.e. 

custodial sinks); they were posted with signs prohibiting their use for drinking 

water purposes. 

Follow-up sampling was conducted in 2002 for lead, and to follow up on the 

chlorine and turbidity results. 

A filter was installed at the drinking fountain where turbidity levels were 

elevated in the original sampling; the filter seemed to eliminate this problem. 

Total chlorine and turbidity analyses were completed again on January 29, 

2002, and results were within the normal, acceptable limits. The initial 2001 

chlorine values were on the lower range of what was expected, and this may be 

because this parameter was measured as free chlorine rather than total 

chlorine. No further testing of these two parameters has been completed to 

date. 

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

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

pervasive problem throughout the FTLB domestic plumbing system. Lead was 

not detected in the samples representing water coming into the building 

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

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

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

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

to the lateral piping. 

As a result of these findings, filters approved for lead removal were installed at 

nine outlets where lead contamination was considered to be a risk for potable 

water. 

In addition to the filter, sink hardware in FTLB Room 167 was replaced. 

Filters were not installed at outlets with lead levels above the action level 

where use of the water for consumption is unlikely. However, as a Best 

Management Practice, these locations were posted with “do not drink” signs. 

Subsequent monitoring has been conducted in 2003 to evaluate the 

effectiveness of these mitigation strategies. The 2003 monitoring will be 

reported in the 2003 Environmental Performance Report. 
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5.3 Ground Water Protection 

5.3.1 Program Management 

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

Program (6-2.4). 

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

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

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

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

protect ground water be established, such as secondary containment for 

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

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

and bermed areas to contain experimental materials. 

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

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

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

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

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

downgradient direction to verify that NREL activities had not adversely 

affected ground water quality. Quarterly sampling was performed for five 

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

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

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

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

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

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

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

downgradient of NREL development. No evidence of contamination was 

found in the 1997 sampling. 

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

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

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

be addressed with Denver West Management. DWOP management contracted 

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

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

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

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

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

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

water samples from this well and the associated water distribution and 
NREL Environmental Performance Report- 2002 

 

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treatment system for the purpose of determining the most feasible alternative 

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

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

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

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

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

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

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

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

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

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

activities pose a risk to the groundwater quality.

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

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

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

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

warehouse. 

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

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

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

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

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

emergency generator above ground storage tank at the Alternative Fuels User 

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

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

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

downgradient. No hydrocarbon contamination was detected in the ground 

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

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

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

5.3.2 Permitting 

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

been permitted with the Colorado Department of Natural Resources. 

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

three wells that were plugged in 1993. 

5.3.3 2002 Activities 

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

September 1998. 
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5.4 Wastewater Discharge 

5.4.1 Program Management 

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

Minimization Program (6-2.8). 

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

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

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

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

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

sewer line to the mesa top. Wastewater from the JSF flows into the City of 

Arvada’s collection system where it is also routed to Metro’s treatment plant. 

The NWTC is not connected to a sewer system, but has two septic systems that 

include tanks and absorption fields for the treatment of wastewater. 

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

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

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

possibility of a hazardous material discharge. These criteria include measures 

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

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

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

research and operations activities as well as ongoing activities that undergo 

significant modifications are reviewed for their potential effect on wastewater 

character through NREL’s risk assessment process. 

Quarterly wastewater monitoring at the DWOP leased facilities and at the STM 

site was initiated in mid-1992 and continued throughout 1994 to demonstrate 

that NREL facilities' wastewater effluent met local publicly owned treatment 

works, state, and EPA standards. Both 24-hour composite and grab samples 

were collected and demonstrated that discharges from Building 16 in the 

DWOP and the FTLB met all applicable regulatory standards. 

Manual grab sampling was also performed at the Building 15 photography 

laboratory wastewater sump with the same frequency as the other sampling 

during 1992 and 1993. The sump was decommissioned in 1994, and direct 

sampling of photo lab wastewater streams was conducted throughout 1994 to 

verify that standards were met. 

5.4.2 Permitting 

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

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

JSF, so no National Permit Discharge Elimination System (NPDES) permitting 
NREL Environmental Performance Report- 2002 

 

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

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

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

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

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

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

NREL maintains septic permits from Jefferson County (an authority delegated 

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

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

5.4.3 2002 Activities 

There were no new significant activities during 2002 in this area. 

5.5 Surface Water Protection (Storm Water) 

5.5.1 Program Management 

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

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

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

2.15 and 6-2.16, respectively) 

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

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

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

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

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

water runoff. 

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

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

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

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

Outdoor research projects are reviewed during the planning stages, through 

NREL’s risk assessment program, for potential impacts to surface water. 

Measures to prevent such impacts are incorporated, as appropriate, into the 

design for each project. Such control measures could include secondary 

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

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

adverse weather conditions. 

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

construction activities on both the STM and NWTC (6-2.15 and 6-2.16, 
NREL Environmental Performance Report- 2002 

 

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

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

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

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

corrective actions assigned to responsible staff when necessary. The SPPPs 

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

SPPPs are implemented through coordination with NREL’s construction 

subcontractors. 

5.5.2 Permitting 

NPDES permitting for storm water discharges on federal facilities in Colorado 

is under the jurisdiction of the Environmental Protection Agency (EPA). 

NREL is currently covered under EPA’s general permit for storm water 

discharge associated with construction activities on the STM and NWTC sites. 

Both Midwest Research Institute, as operator, and DOE, as site owner, have 

been issued permits. EPA has issued separate permit numbers for each owner 

and operator at each site for a total of four permit numbers. No permits are 

required for NREL’s routine operations. 

5.5.3 2002 Activities 

In 2002 there were a few research-related and paving construction projects for 

which erosion and sediment control programs were developed. These were 

minor in terms of the extent of soil disturbance. There were no major 

construction projects in 2002. 

5.6 Waste Management 

5.6.1 Program Management 

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

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

and Notification (6-2.1). 

Hazardous wastes are handled and disposed according to the Resource 

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

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

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

experimental site. These wastes are periodically collected from the 

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

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

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

waste disposal policy in which materials that are not regulated by RCRA, yet 
NREL Environmental Performance Report- 2002 

 

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

material at a RCRA-permitted disposal facility. 

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

waste normally consists of personal protective equipment, disposable labware, 

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

5.6.2 Permitting 

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

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

Conservation and Recovery Act (RCRA) waste generator identification 

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

Denver West Office Park locations are classified as "small quantity 

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

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

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

than 100 kg of waste per month. 

5.6.3 2002 Activities 

In 2002 NREL generated 6,362 pounds (2,892 kg) of hazardous waste, and 

12,810 pounds (5,823 kg) of non-RCRA regulated waste. These quantities are 

approximations only. The materials are normally not weighed when picked up 

by disposal or recycling vendors. Typically, a vendor will provide its good 

faith estimate of quantity based on practical experience. 

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

2002 was 455 pounds (207 kg), which included 62.88 MBq (1.699 mCi) of 

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

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

In 2002, NREL participated in the DOE Materials Exchange program by 

sharing the list of chemicals available for redistribution with other DOE 

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

organization. 

5.7 Storage Tanks (Underground and Above Ground) 

5.7.1 Program Management 

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

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

and Countermeasures (6-2.10) 
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NREL facilities store diesel for emergency generator and research use in 

aboveground storage tanks. The NREL tank inventory is presented in 

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

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

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

than the regulations require in many areas. 

Several important safeguards have been incorporated into NREL’s tank 

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

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

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

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

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

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

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

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

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

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

had any offsite impacts related to tank activities. 

5.7.2 Permitting 

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

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

meet the registration threshold, the SERF emergency generator diesel storage 

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

Alternative Fuels User Facility (AFUF), both located on the STM site. In 1999 

the State inspected each of NREL's registered tanks and found no deficiencies 

in the management or operation of the tanks. 

5.7.3 2002 Activities 

There were no spills or leaks from NREL tanks during 2002. There was no 

state inspection in 2002..

5.8 Hazardous Materials Management 

5.8.1 Program Management 

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

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

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

Therefore, many sections of the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) do not apply to NREL facilities. 
NREL Environmental Performance Report- 2002 

 

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

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

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

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

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

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

inventory are stored in quantities greater than prescribed threshold planning 

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

notification requirements in 1988. 

EPCRA Section 304 requires facilities to immediately notify the Local 

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

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

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

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

than TPQs, and provides inventory reporting for these same chemicals in the 

form of Tier I or Tier II reports to emergency planning and response groups. 

NREL provides emergency response and reporting information to the Jefferson 

County Emergency LEPC, the SERC, and West Metro Fire Protection District 

when requested. The Jefferson County LEPC uses Uniform Fire Code hazard 

categories and threshold reporting quantities rather than those specified in 

SARA Title III, resulting in a larger number of individual hazard categories 

and lower reporting thresholds. NREL has an active involvement in the 

emergency planning concepts of SARA Title III, in that the Laboratory 

currently has two acting members on the Jefferson County LEPC, and has been 

represented since the LEPC’s inception. 

The Laboratory is also subject to reporting requirements in the event of a 

release of an RQ of any hazardous substance listed by EPCRA. EPCRA 

Section 313 requires that a toxic chemical release inventory report (Form R) be 

filed with EPA for any chemical that is manufactured, processed, or otherwise 

used in quantities exceeding TPQs. Although NREL is not a manufacturing 

facility and does not fall within any of the Standard Industrial Classification 

(SIC) codes for which Section 313 reporting is required, Executive Order 

12856 requires all federal facilities to file a report, if applicable, regardless of 

SIC code. 

Section 112r of the Clean Air Act regulates numerous toxic and flammable 

substances, and threshold quantities are established under Section 112r of the 

Clean Air Act. All thresholds are 500, 100, 2500, 500, 10,000, 15,000, or 

20,000 pounds, depending on the material. The threshold quantity applies to 

the quantity of substance in a single process, not at the facility as a whole. 
NREL Environmental Performance Report- 2002 

 

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NREL has a Laboratory-wide chemical management system that serves as a 

centralized chemical inventory as well as a tool for managing and reporting on 

chemicals used at the Laboratory. Using an electronic barcoding system, the 

CMS tracks chemicals from the point of receipt through disposal. Key 

functions of the system include: 

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

 Improving research efficiency and minimizing hazardous waste 

generation by allowing staff to determine if needed chemicals are 

already available on site prior to making chemical purchases 

 Providing quick access to chemical inventories and hazard information 

during emergency responses 

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

fire districts, EPC, EPA, DOE) 

 

To populate the CMS database, a physical inventory of each lab and work area 

in which chemicals are used or stored was conducted between June 1999 and 

the first quarter of 2000. In 2000, technical data and reporting information was 

entered into the system for many of the chemicals in the CMS database. 

NREL has not identified any areas within its facilities that contain residual 

contamination requiring special decommissioning. Asbestos surveys have 

been conducted in a number of NREL facilities: Joyce Street Facility; 

Building 251 at the NWTC; Building 16, and at the STM Site the AFUF (only 

older areas of the building), FTLB and SRRL. No asbestos was found at the 

Joyce Street Facility and the AFUF. The other facilities have limited amounts 

of asbestos-containing material in areas such as floor tile, lab countertops, 

caulking and sealants, and roofing material. Asbestos-containing materials are 

left undisturbed whenever possible. If renovation is planned that will disturb 

asbestos-containing material, then certified asbestos removal contractors are 

used and strict asbestos removal procedures are followed. An Asbestos 

Management Program is in effect for all NREL facilities. 

5.8.2 Permitting 

NREL obtains annual Hazardous Material Permits from West Metro Fire 

Protection District for the STM and DWOP sites. The permits are required by 

the West Metro Fire Protection District (West Metro) and are issued by 

building. NREL obtains permits for a total of seven buildings where hazardous 

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

from West Metro conducts a walk-through inspection of the entire South Table 

Mountain Site and DWOP. 
NREL Environmental Performance Report- 2002 

 

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5.8.3 2002 Activities 

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

facilities in the spring of 2002. Annual hazardous materials permits for the 

seven buildings were issued following the inspection. West Metro provided a 

few recommendations as a result of that inspection. Recommendations 

included: labeling natural gas lines in four labs at the AFUF, installing hazard 

placards on doors in four labs at the FTLB, installing a hazard placard on the 

south side of the Waste Handling Facility, replacing warning signs at the SERF 

loading dock area that had faded, and placing 55-gallon drums in secondary 

containment. All recommendations have been implemented with the exception 

of the last, which is still being discussed with West Metro. 

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

to West Metro when applying for Hazardous Materials Permits in 2002. The 

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

ES&H website, which were updated monthly. 

In 2002, NREL had three chemicals on-site in quantities that exceeded the 

TPQs, sulfuric acid, hydrofluoric acid, and hydrogen selenide. The proper 

MSDSs and Tier II forms were submitted to state and local emergency 

response organizations and the local fire department. 

In 2002, NREL facilities had no release exceeding the RQ of any reportable 

material under EPCRA. 

As a research and development Laboratory, NREL does not manufacture or 

process any materials, and during 2002, the Laboratory did not use any 

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

lb) threshold planning quantity. 

5.9 Pollution Prevention & Sustainability 

5.9.1 Waste Minimization, Recycling, and Green Purchasing (Purchasing 

Materials With Recovered Content) 

As a facility that focuses on renewable technologies, NREL is committed to 

responsible environmental stewardship. A significant part of this effort is 

pollution prevention. NREL's Waste Management and Minimization Program 

outlines pollution prevention principles that are consistent with the EPA's 

hierarchy of preventing or reducing pollution at the source; recycling or 

reusing waste materials that cannot be prevented; and environmentally safe 

treatment and disposal of waste that cannot be prevented, recycled, or reused. 

The current pollution prevention program includes training on waste handling, 

waste minimization, and methods to eliminate releases to air, soil, or 
NREL Environmental Performance Report- 2002 

 

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wastewater. In addition, the ES&S Office integrates pollution prevention 

awareness into NREL activities in a number of ways. The proposed use of 

chemicals in projects are evaluated prior to use during project planning 

reviews, Safe Operating Procedure reviews, and Readiness Verifications 

conducted according to NREL’s Hazard Identification and Control Program 

(ESH 6-6.2). During these reviews, NREL staff evaluatestaff evaluates

opportunities for chemical substitution as well as methods of reducing the 

volume of chemicals used and waste streams generated. 

The use of bankcards for chemical purchases has been another means of 

reducing the volume of chemicals purchased, stored and disposed at NREL. 

Under the bankcard chemical purchasing system, a small group of chemical 

users are given privileges to order chemicals directly from the vendor using 

their bankcards. Because bankcard purchasing expedites chemical purchases 

over conventional purchasing processes at NREL, users order only the 

chemicals they foresee they’ll need in the immediate future, knowing that they 

can quickly obtain more if needed. The ES&S Office reviews all chemical 

purchases made using the bankcards. 

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

prevention program. NREL’s recycling program is managed by a crosscuttingcrosscutting committee comprised of staff from around the Laboratory. 

Items currently recycled or reused at NREL include the following: 

 fluorescent bulbs 

 batteries 

 styrofoam peanuts and other packing materials 

 freon from refrigerator units 

 scrap metal 

 wooden pallets 

 laser printer cartridges 

 aluminum and tin cans 

 glass 

 plastics (1 & 2 only) 

 newspaper 

 white and mixed paper 

 corrugated cardboard 

 boxboard 

 books and magazines 

 transparencies, and 

 tyvek envelopes 

Several central recycling locations are available for most recycling needs 

throughout NREL facilities. NREL also offers a chemical redistribution 

program where chemicals in original containers are made available to staff at 
NREL Environmental Performance Report- 2002 

 

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NREL and other DOE facilities to be reissued for research activities at no cost. 

The NREL CMS is used for redistributing chemicals to new users. 

In 2002, NREL generated 218 metric tons of solid waste and diverted 72 

metric tons to recycling, or 33% of the total. Data for some of the materials 

recycled by NREL during 2002 follow. Quantities are not tracked for all 

materials that are recycled, so the list below does not include all recycled 

materials. 

 Batteries 2405 lb 

 Fluorescent bulbs 537 lb 

 Mixed metal 59,200 lb 

 Commingled containers 17,370 lb 

 Cardboard 6080 lb 

 Misc. paper 127,437 lb 

 Computer monitors 38 units 

When possible, NREL purchases products with recovered content. In 2002, 

some of the products purchased containing recovered content included 

carpeting, plastic fencing, uncoated-printing paper, toner cartridges, file folders 

and notepads. One hundred percent (100%) of NREL’s supply of uncoated 

printing and writing paper, plastic fencing, and toner cartridges purchased in 

2002 contained recovered content. 

5.9.2 Vehicles 

NREL leases 47 vehicles from the General Services Administration. These 

vehicles are used for a variety of transportation and special purpose activities, 

such as equipment moving and servicing, grounds maintenance, and travel 

between the NREL sites. Of those vehicles, 28 are alternative fueled vehicles 

or hybrid vehicles. It is NREL policy to replace standard vehicles with 

alternative fuel vehicles whenever a suitable vehicle is available from GSA, 

with an ultimate NREL goal of 100% AFVs and hybrids. In fiscal year 2002, 

NREL was able to reduce its petroleum usage by 14% over the base year, 

1999. The goal set by E.O. 13149 for all federal agencies is to reach a 20% 

petroleum use reduction by 2005. 

5.9.3 Energy 

NREL is on target to meet the fiscal year 2005 requirement of a 20 percent 

reduction in energy use per square foot in laboratory and industrial facilities 

using a DOE 1990 baseline. The baseline is the average for all DOE 

Laboratory and Industrial Facilities in 1990. For NREL, this baseline is 

352,540 BTU/SF and will be applicable to NREL facilities from 2002 forward. 
NREL Environmental Performance Report- 2002 

 

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Table 1 includes the FY1990 baseline and summarizes the energy consumption 

per gross square foot for Total NREL facilities, which includes both the South 

Table Mountain and National Wind Technology Center sites. 

Table 1. Energy Consumption 

 BTU/GSF 

FY1990 BASE YEAR 352,540 

FY2001 TOTAL NREL (DOE-owned) 271,247 

FY2002 TOTAL NREL (DOE-owned) 270,495 

Comparing total NREL energy consumption in FY2002 to the baseline, the 

energy consumption is 23% lower than the FY1990 baseline. In addition, there 

is a 0.21% reduction of energy consumption from FY2001 to FY2002. 

Individual Building Metering. NREL previously received gas and electrical 

utility billing from the utility company, Xcel, on a monthly basis for NREL’s 

two sites. The electrical utility billing was not broken down into individual 

buildings within each site; Xcel only provided the total electrical power 

consumption and billing data for the entire site. In 2002, NREL completed 

installation of individual power meters at each major facility on the STM and 

NWTC sites. Individual metering will allow better understanding of energy 

use and identify further opportunities for reductions. 

Individual Energy Saving Program. NREL completed site metering of its 

DOE-owned facilities in FY2002. Beginning with FY2003, this building-bybuilding energy use will be made available to management, building managers 

and building occupants as a method of providing feedback on building energy 

use. A program to educate building occupants on energy saving opportunities 

will also be implemented. The objective of providing feedback and education 

on energy saving opportunities is to reduce energy use at the individual level. 

Building energy managers dealing with building operation issues, and 

management who are tracking progress and identifying opportunities will also 

use building energy use information. 

Computer/Monitors Purchasing. NREL Information Services (IS) provides a 

standard hardware list of recommended Energy Star products for PC and MAC 

computers, monitors and peripherals. Staff is encouraged to purchase Energy 

Star hardware items through the "Buyers Ordering Agreement" (BOA) 

contracts. Suppliers websites provide energy information for standard 

products. Flat panel monitors, that use significantly less energy than standard 

monitors, have been added to NREL’s standard supply list. 

Computer Power Management. Whenever possible, computers are configured 

to a low power or sleep mode, and monitors are switched off when not in use. 

Due to the diversity of NREL's hardware, NREL does not recommend use of 

the system standby or hibernation modes on a routine basis. A review of the 
NREL Environmental Performance Report- 2002 

 

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desktop energy configurations areReviews of the desktop energy 

configurations are discussed with each client during a standard service call. 

Printers. Networked printers are configured automatically to enter a lowpower mode of 15-45 watts or less after a period of inactivity (this time period 

differs with models). Seventy-one duplex modules were purchased in FY 2001 

and installed on network printers configured to default duplexing. Users can 

control one-sided printing through the applications print feature. 

 

Copiers. All copiers are Energy Star rated.

Vending Misers. “Vending Miser” units, designed to turn off advertising 

lights, were piloted on two vending machines. A data logger was installed to 

track energy consumption reductions due to these changes, which have proven 

to be about 50%. Additional Vending Misers will be installed on most of the 

remaining vending machines throughout the complex. 

Water Coolers. NREL is exploring options to reduce energy consumption in 

existing water coolers, possibly through use of timers. 

Energy Efficiency Specifications for Renovations/New Construction. Energy 

efficiency criteria have been incorporated into the established NREL design 

standards and specifications for all construction projects. These requirements 

include T8 lights, electronic ballasts, and LED exit signs. Prior to 2001, all 

existing exit signs were retrofitted with LED’s and direct digital controls. See 

“Sustainable Building Design” section below for more detailed information. 

5.9.4 Renewable Energy 

Self-generated electricity. NREL generates about 50,000 kWh of electricity 

from grid-connected PV panels each year. These panels are located on the 

Solar Energy Research Facility, the Site Entrance Building, the Outdoor Test 

Facility, and remote applications including signs and walkway lighting. NREL 

purchased an additional 720 watts of PV panels in FY2002 that were installed 

at the Site Entrance Building to help offset that building’s electrical usage. 

The NREL NWTC has approximately 1600 kW of installed wind turbine 

capacity used for research purposes. When the turbines are running, the 

energy that they produce is used to offset simultaneous NWTC site energy use. 

NREL and DOE Golden Office are currently negotiating a Purchase Power 

Agreement (PPA) with Xcel Energy for any excess energy produced at the 

NWTC. 

Purchased renewable energy. In FY2002, NREL purchased 1,981,200 kWh of 

wind-generated electricity from the local utility company, Xcel Energy. This 

purchase represents 10% of NREL’s annual electrical usage. NREL has 
NREL Environmental Performance Report- 2002 

 

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committed to purchase another 1,981,200 kWh of wind-generated electricity 

for FY2003 and will be negotiating agreements for FY2004 and beyond. 

5.9.5 Water Conservation 

NREL performed a preliminary water management study of all the facilities on 

the STM site to determine expected water savings per year if all water closets, 

urinals, and shower heads were replaced with low flush water closets, 

waterless urinals and low flow showerheads, respectively. In 2002, NREL 

completed a Water Efficiency Plan that also identifies several other water 

savings best management practices. In fiscal year 2002, NREL installed lowflow toilets, waterless urinals, and low-flow showerheads in existing facilities 

(the DOE-owned buildings on the South Table Mountain site). This is 

expected to save more than 300,000 gallons of water per year. 

In spring and summer of 2002, the communities in the Rocky Mountain 

Region were faced with drought conditions and mandatory water restrictions 

were implemented. NREL actively participated by reducing irrigation by 43% 

on both sites and worked with Denver Water to perform a water audit on the 

two facilities (the FTLB and SERF) that account for 89% of NREL’s total 

water consumption. The water audit helped identify recommendations for the 

Water Efficiency Plan. 

Water use data use for the STM site is obtained from the water supply 

company, Consolidated Mutual Water. All of the facilities that require water 

on the STM site have dedicated water meters. There are also water sub-meters 

on all three cooling towers at the STM site. 

The NWTC site is a remote site that has no wells or water supply. Boulder 

Public Water Supply water is delivered weekly to the NWTC, as described in 

Section 5.2. Currently water usage at the NWTC is measured by the amount of 

water delivered to the site. 

 

The water use for all NREL sites is summarized in Table 2. Water 

consumption was 16% lower in FY2002 as compared to FY2000 base year. 

Table 2. Water Consumption 

 Million Gallons per Year (MGY) 

FY2000 (BASE YEAR – TOTAL NREL) 12.9 

FY2002 – TOTAL NREL 10.9 

5.9.6 Sustainable Building Design 

NREL has always emphasized significantly greater levels of energy efficiency 

than federal standards with all of its DOE-owned buildings, with a goal to 

reduce energy use by 30% compared to the federal standard reference for 

building systems. Several of NREL's buildings, including the Thermal Test 
NREL Environmental Performance Report- 2002 

 

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Facility (TTF) and Solar Energy Research Facility (SERF) are models of 

energy efficiency. The SERF's annual energy costs are 40 percent below that 

of a similar building designed to meet federal energy standards, and the TTF 

operates on 63 percent less energy than a building designed to meet the Federal 

Energy Code. The TTF building received a 2002 Federal Energy Saver 

Showcase Award. 

The NWTC Site Entrance Building (SEB) was designed in-house by NREL 

staff during fiscal year 2002. Construction was completed in early 2003. The 

building was designed to be a near zero energy building; its systems are fully 

monitored. The NWTC SEB is 16’x 10’, and uses NREL technologies to 

reduce the power demand of the building. Such technologies include 

daylighting, passive solar heating, good thermal envelope, natural ventilation 

through the windows, low-e windows, overhangs for shade control, a Trombe 

wall, occupancy and daylight sensors, high-efficiency lighting with dimming 

fixtures, and the use of energy efficient flat screen computer monitors. These 

technologies, along with a roof mounted 768 W photovoltaic array, and two 

1000 W wind turbines, reduce the amount of electricity drawn from the utility 

grid and feed excess electricity produced back to the grid. 

5.9.7 Technical Assistance and Outreach 

NREL’s mission since its inception has been related to the development of 

energy efficiency and renewable energy technologies. An important part of 

that mission is technical assistance and outreach on all energy-related aspects 

of building design, vehicles and fuels, and electricity from renewable energy 

and hybrid energy sources. NREL scientists and engineers regularly assist 

other DOE laboratories, other federal agencies, state and local governments, 

commercial businesses, consumers, and energy users in developing countries 

to understand and implement energy efficiency and renewable energy options. 

NREL FEMP staff has assisted in both developing Energy Management and 

Water Management Plans at NREL. In addition, NREL FEMP staff developed 

the Department of Commerce agency-wide energy plan and is in the process of 

assisting several other agencies in their energy planning processes. NREL 

researchers work with DOE, EPA, the US Green Building Council, and others 

on a variety of assistance and outreach programs and activities related to 

energy and water use. Examples include standards development, conferences, 

classes and workshops, tours, publications, websites, and energy and water 

analysis software. NREL’s activities in this regard can be surveyed through 

the most recent Institutional Plan or Performance Assessments, accessible on 

NREL’s website (www.nrel.gov). 
NREL Environmental Performance Report- 2002 

 

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5.10 Vegetation 

5.10.1 Program Management 

Management in this area is consistent with NREL’s Weed Management 

Programs for the STM and NWTC (6-2.12 and 6-2.13, respectively) and the 

Sustainable Landscape Design and Management Program (6-2.19). 

NREL’s basic philosophy regarding vegetation is to preserve and protect the 

ecosystems on the site in their natural state as much as possible. There is some 

landscaping using non-native drought-tolerant species adjacent to some of the 

buildings, and even a few areas at the STM site of sodded bluegrass. However 

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

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

following disturbance from construction or other outdoor activities is 

conducted using a native seed mix of grasses and forbs. This mix is comprised 

predominantly of natives that were originally present on the site before 

disturbance. That seed mix and revegetation procedures are outlined in 

NREL’s Storm Water Pollution Prevention Programs for the STM and NWTC 

Sites. The use of native species is required at both the STM and NWTC 

whenever feasible. 

A vegetation survey of the STM site was conducted in support of the 1993 site 

wide Environmental Assessment, and a site reconnaissance was performed by 

Dames & Moore biologists in November 1997 (U.S. DOE, 1998, page 3-1). 

In 1999, a verification survey of STM site vegetation was performed on the 

Conservation easement property to identify any changes to habitat character or 

species types that may have occurred since the 1993 and 1997 surveys. An 

effort was made to determine whether any sensitive species or habitats that 

could potentially support such species were present on the site. No sensitive 

species or potential habitats were identified on the STM site. 

A vegetation survey of the STM was conducted between June 2001 and May 

2002. Details of the survey results are included in Section 5.10.3 below. 

A three-season vegetation survey of the NWTC site was performed between 

August 1999 and August 2000. The survey defined five general habitats on 

the NWTC site, comprising nine plant communities and 271 vascular plant 

species (Plantae Consulting Services, 2000). No rare or imperiled plant 

species were found on the site. However, the survey identified a small area of 

xeric tallgrass prairie (defined as mesic mixed grassland in this study) located 

in the southwest corner of the NWTC. This natural community is listed as rare 

and imperiled by the Colorado Natural Heritage Program. This listing implies 

no legal designation or regulatory enforcement. It is made primarily for 
NREL Environmental Performance Report- 2002 

 

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management purposes. This area of the NWTC is not impacted by research or 

construction activities on the site. 

The survey identified eleven noxious weed species on the NWTC site. Five of 

these are recognized as belonging to the top ten prioritized weed species in 

Colorado. Based on the survey, recommendations were made to continue 

using a comprehensive weed management program, based on integrated pest 

management (IPM) philosophy. 

The survey showed the native seed mix used for revegetation at the NWTC to 

be very successful in many areas of the site. NREL is continuing the use of 

this seed mix for revegetation at the NWTC. 

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

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

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

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

eliminating driving of vehicles off established roadways), and herbicide 

treatment. The effectiveness of control methods is periodically assessed. The 

use of multiple strategies for control has been successful in significantly 

reducing populations of diffuse knapweed and Canada thistle on the sites. The 

key aspect of the weed control program is to maintain flexibility to respond to 

the changes in weed populations from year to year. 

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

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

knapweed. It has been very effective in controlling the weed, and healthy 

stands of native grasses have proliferated with the decrease in weed 

competition. Also at the NWTC in 1998, sensitive areas adjacent to drainage 

areas and trees were treated using ground application with the herbicide, 

Transline, to control diffuse knapweed, and small areas of Canada thistle were 

treated with Telar. Limited herbicide application occurred from 2000 to 2002, 

which included spot spraying using tractor and backpack applicators to target 

remaining pockets of diffuse knapweed and Canada thistle. More regarding 

2002 herbicide application are provided in Section 3.9.3. 

Weed infestations at the STM site are much less severe than at the NWTC. 

Limited ground application of herbicides has been conducted at the STM from 

1999-2002, applying Transline and Tordon to diffuse knapweed and Telar to 

Canada thistle infested areas. 

5.10.2 Permitting 

There is no permitting applicable to vegetation management, although there is 

a State weed law that requires property owners to control certain species of 

invasive weeds (e.g. diffuse knapweed). For application of certain types of 
NREL Environmental Performance Report- 2002 

 

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herbicides designated as “restricted use” by EPA, a certified applicator must be 

used. Herbicide applications at NREL are always performed by a certified 

applicator. The exceptions are herbicides used for control of undesirable 

vegetation along walkways, roadways, and adjacent to facilities. These are 

typically Round-Up and Weed-B-Gon and are applied by NREL Site 

Operations staff according to an NREL Safe Operating Procedure (SOP). 

5.10.3 2002 Activities 

While NREL applies a variety of IPM practices, limited ground applications of 

herbicides occurred at the NWTC and STM in 2002. At the NWTC, spot 

spraying using tractor and backpack applicators was performed to target 

remaining pockets of diffuse knapweed and Canada thistle. Tordon and 

Transline were used to target diffuse knapweed. Tordon was applied in dry 

upland areas, while Transline was used near drainage areas. Tordon was also 

applied to small patches of leafy spurge. Telar was used to target Canada 

thistle. Escort was used in limited applications for common teasel, hoary cress, 

and sulfur cinquefoil. At the STM, Transline was applied to diffuse knapweed 

near drainage areas and near neighbor’s fence lines, while Tordon was used for 

diffuse knapweed in dry upland areas. Telar was applied to Canada thistle at 

the STM. 

A vegetation survey of the STM was conducted between June 2001 and May 

2002. Five general habitats were described on the STM site, comprising seven 

plant communities (Plantae Consulting Services, 2002). No rare or imperiled 

plant species were found on the site. Areas of mixed foothills shrublands (also 

called tall upland shrubland) were identified on top of the mesa within the 

Conservation Easement area. This natural community is listed as rare and 

imperiled by the Colorado Natural Heritage program. No development will 

occur in the Conservation Easement area. 

Eleven noxious weed species were located on the STM site. Four of these 

belong to Colorado’s top ten prioritized-for-control weed species. These four 

include Canada thistle, diffuse knapweed, field bindweed, and musk thistle. 

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

implementing environmentally sound, cost-effective landscaping practices that 

reduce adverse impacts to the natural environment while providing essential 

shade and cooling for indoor and outdoor spaces and a more aesthetically 

appealing appearance for the sites. In order to formalize this commitment, 

NREL has just completed a new Sustainable Landscape Design and 

Management Program. 
NREL Environmental Performance Report- 2002 

 

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5.11 Endangered Species/Species of Concern 

5.11.1 Program Management 

The Endangered Species Act provides for the designation and protection of 

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

the ecosystems on which these species depend. A wildlife survey was 

completed on the STM site in 1987 (The FORUM Associates, Inc., 1987a), at 

which time no threatened or endangered species or candidate wildlife species 

for endangered designation were found. A vegetation survey of the STM site 

was completed in 1999 for the National Renewable Energy Laboratory 

(NREL) Site Conservation Easement Baseline Inventory (U.S. DOE 1999). No 

threatened, endangered, or candidate plant species were identified in the 

survey. 

Additional surveys of wildlife on the Conservation Easement property were 

conducted in 1999, also for the Baseline Inventory. The U.S. Fish and Wildlife 

Service lists five threatened and endangered animal species that may 

potentially occur in the property area, including American peregrine falcon, 

bald eagle, Eskimo curlew, Mexican spotted owl, and Preble's meadow 

jumping mouse. The Colorado Natural Heritage Program database lists three 

animal species of interest that may potentially occur in the property area, 

including common shiner, arogos skipper, and ottoe skipper. No suitable 

habitat is present for any of these species on the Conservation easement 

property. 

No threatened, endangered, or candidate species of either plants or animals 

have been identified to date on the NWTC site. A vegetation survey conducted 

between August 1999 and August 2000 identified a small area of xeric 

tallgrass (defined in the survey as mesic mixed grassland) prairie located in the 

southwest corner of the NWTC site. This natural community is listed as rare 

and imperiled by the Colorado Natural Heritage Program. This listing implies 

no legal designation, but is made primarily for management planning purposes. 

This area is not impacted by current research and construction activities. 

Field research into avian use of the NWTC was conducted during 1994 and 

1995 in an effort to identify potential impacts on birds from wind-turbine 

research. While several species of raptors, including red-tailed hawks, 

kestrels, and a great-horned owl were noted on the site, they were primarily 

transient in nature. The NWTC appears to be used primarily for resting and 

hunting, although one pair of kestrels nested in an old concrete pole during the 

spring. Birds of prey of concern, such as eagles, generally fly in excess of 152 

m (500 ft) over the site. No significant impacts to the birds from NREL 

activities were found. 
NREL Environmental Performance Report- 2002 

 

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The most recent research conducted for avian and bat use of the NWTC was 

conducted between May 2001 and July 2002. Final study results are included 

in Section 5.11.3. 

5.11.2 Permitting 

NREL has no permitting requirements for this area of environmental 

management. 

5.11.3 2002 Activities 

A year-longyear-long monitoring project for birds and bats was initiated on the 

NWTC in early 2001. Starting on May 30, 2001, standardized plot surveys 

were conducted to survey songbirds and raptors on the NWTC and adjacent, 

undeveloped areas. Starting on May 29, 2001, NREL began conducting 

systematic searches of turbines and meteorological towers on the NWTC to 

document avian mortality. The study was completed in July 2002. Salient 

findings of the study were as follows (Schmidt, E., et al., 2003): 

 Abundances of individual raptor species on the NWTC site were 

similar to surrounding areas. However, the average number of species 

detected per count at the NWTC was nearly double that of surrounding 

areas in winter, the season when raptors are most abundant in the 

region. This difference is likely attributable to increased availability of 

perches at the site. Raptors flew and perched higher at the NWTC than 

in adjacent areas, again probably related to the wind turbines and other 

structures at the site. 

 Only 1 of 46 bird species counted on grassland plots during this study 

differed in abundance between the NWTC and adjacent areas – the 

horned lark, which was about 16 times more common off site. This 

difference is attributable to cattle on Boulder Open Space creating lowstature grasslands preferred by this species. 

 Bird abundance and variety on the...[newly acquired 25-acre parcel, 

south of the previous NWTC boundary] slated for future use were 

generally similar to the developed areas, except for the relative scarcity 

of raptors on the undeveloped site, which probably was due to a lack of 

perches. 

 The NWTC does not support a large diversity or abundance of bat 

species (possibly six species of bats use the site), but an are on the 

northwest side of the site, with trees close to a rocky outcrop, provides 

foraging and perhaps roosting habitat. 

 No raptor carcasses [were found] during the 12-month survey of the 

NWTC, except one American kestrel that had died before the study 

started. Bird mortality associated with the site appears to be minor. 

Extrapolating from four passerine (songbird) carcasses found during 

the searches, estimated annual bird mortality attributable to the NWTC 
NREL Environmental Performance Report- 2002 

 

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was 24 individuals, all songbirds (Passeriformes). Most of these deaths 

were probably the result of collisions with support wires for the 

meteorological towers rather than the turbines themselves. No 

evidence [was found] of bat fatalities at the site. 

A 3-season vegetation survey was completed on the STM site in May 2002. 

Details of the survey are presented in Section 5.10.3. The survey found no 

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

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

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

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

within a designated conservation easement area where no development will 

occur. 

5.12 Wetlands/Floodplains 

Limited wetland areas totaling less than 0.2 ha (0.50 ac) occur on the STM site 

in the drainage bottom located north of the Visitor’s Center. These are narrow, 

linear wetlands supporting spikerush, baltic rush, sedges, bluegrass, hemlock, 

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

development continues. 

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

areas, along the site’s eastern boundary, total less than 0.4 ha (1 ac). 

According to maps generated by the Jefferson County Department of 

Highways and Transportation as part of its urban drainage studies, NREL's 

STM site does not contain any floodplains, and no floodplains have been 

identified at the NWTC. As a best-management practice, however, all 

construction activities that may cross a drainage channel are designed to meet 

the 100-year flood control standards (designed to withstand the equivalent of a 

100-year flood). 

5.13 Cultural Resources 

Two formal surveys of historic and cultural resources have been performed on 

the STM site. These surveys were completed in 1980 and 1987. As a result of 

these surveys, three historical sites were recognized as significant cultural 

resources that should be preserved. These sites include an open-air 

amphitheater, a stone bridge spanning a natural drainage channel adjacent to 

the amphitheater, and a stone and concrete ammunition bunker below the 

amphitheater site. The three structures were constructed during the Works 

Progress Administration (WPA) era in the 1930s. Through NREL's efforts, 

these sites have been added to the National Register of Historic Places 

(National Register), with the amphitheater and stone footbridge listed together 

as a single site. NREL also participated in an interagency survey of South 
NREL Environmental Performance Report- 2002 

 

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Table Mountain and Camp George West to identify historic structures and sites 

eligible for nomination to the National Register. 

An archaeological survey of the NWTC site was conducted in support of the 

1996 Environmental Assessment to supplement previous surveys so there were 

no gaps in cultural surveys on the site. No significant historical or 

archaeological resources were identified. However, the wooded ridge area on 

the west portion of the site was identified as a location with potential for 

cultural resources, so further testing or observation during excavation would be 

done should there be any future need for work in the utility corridor in the 

vicinity of the ridge. 

5.14 National Environmental Policy Act (NEPA) 

5.14.1 Program Management 

Management in this area is consistent with NREL’s NEPA Implementation 

Program (6-2.2). 

As a federal agency, DOE is obligated to comply with NEPA by evaluating the 

potential for environmental impacts prior to conducting its activities. 

Regulations for compliance with the Act are issued by the Council of 

Environmental Quality (CEQ). DOE has also issued implementing regulations 

at 10 CFR that complement the CEQ requirements. DOE has written a site 

wide Environmental Assessment (EA) for its activity at the STM Site and 

DWOP, and separate EAs for the NWTC and JSF activities. 

NREL has established procedures, with the approval of the DOE GO, to assist 

DOE in meeting their NEPA obligation. Proposed activities that will be 

conducted off of NREL’s four sites are evaluated for their potential 

environmental effects using the appropriate level of NEPA review, in 

conjunction with GO. 

The NREL NEPA Handbook has been prepared to provide NREL project 

managers and procurement specialists with guidance on implementing the 

NEPA procedures. 

5.14.2 Permitting 

NREL has no permitting requirements under NEPA. 

5.14.3 2002 Activities 

During 2002, activity continued on developing EAs for one potential site for 

small-scale geothermal power plant construction in Animas, New Mexico, and 

one potential site for a geothermal direct use project (district heating system), 
NREL Environmental Performance Report- 2002 

 

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in Canby, California. The EA for the Animas, New Mexico site that was 

initiated in 2001 was completed; a FONSI was signed in 2002. The EA 

process was initiated in 2002 for the Canby, California site, and the EA was 

completed in early 2003. 

In 2001 a subcontractor was hired and began writing the new Site wide EA for 

the NWTC, and the EA was completed in May 2002. 

Internal scoping began in 2001 for the new Site wide EA for the STM site. In 

2002 the contractor was hired and began writing the EA. The EA for the STM 

site was completed in 2003. 

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

offsite activities occurred through completion of NREL Environmental 

Checklists. As outlined in NREL’s NEPA implementation procedures, these 

reviews were coordinated with NREL project managers, subcontracting staff, 

the NREL NEPA Coordinator, and the DOE Golden Field Office NEPA 

Compliance Officer. NEPA requirements were also coordinated with future 

program planning through interaction between NREL’s NEPA Coordinator 

and NREL’s Technology Program and Project Managers. 

5.15 Radiological Program 

5.15.1 Program Management 

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

Quality Protection (6-2.5), and Radiological Control (6-4.5). 

All radioactive material at NREL facilities areis handled according to NREL’s 

Radiological Control Program. Elements of the program include a radiological 

control organization, a radiation safety policy and control manual, safe 

operating procedures, safe work permits, radiological control areas and 

postings, monitoring, training, and purchasing controls for radioactive 

materials. 

There are no nuclear operations at NREL sites. The majority of radiation 

sources are used/stored in facilities located on the STM site. These include 

three x-ray diffraction machines at the SERF and two sealed source level 

gauges at the AFUF used on pilot scale processes to measure the level of 

material inside process tanks. In addition, two laboratories at the Field Test 

Laboratory Building (FTLB), on the STM site, occasionally use small 

quantities of radioisotopes for biological or chemical labeling. 

The three X-ray diffraction machines are registered with the State of Colorado 

and are inspected every two years by a state-licensed surveyor. The surveyor 
NREL Environmental Performance Report- 2002 

 

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inspects and certifies the X-ray machines and audits NREL's program for 

radiation safety in connection with operating the machines. 

Monitoring of equipment and facilities for removable contamination is 

performed in the laboratories where radioisotopes are used. Wipe tests are 

performed on any laboratory surfaces that could have become contaminated by 

the radioisotope work at least monthly and more frequently if needed. These 

wipes are analyzed using a scintillation counter. 

U.S. Department of Energy (DOE) Order 5400.5, “Radiation Protection of the 

Public and the Environment,” established radiation emission limits for DOE 

facilities. Such emissions are also regulated by Section 112 of the Clean Air 

Act as implemented by 40 CFR 61, Subpart H, established by the U.S. 

Environmental Protection Agency (EPA). According to 40 CFR 61, Subpart 

H, all DOE facilities, including NREL, must annually demonstrate compliance 

with the radionuclide emission limit to the ambient air not exceeding an 

amount that would result in any member of the public receiving an effective 

dose of 10 mrem/yr or greater. No radioactive air-emission monitoring is 

conducted at NREL because of the extremely low usage of radioactive 

material. Therefore, NREL demonstrates compliance with the National 

Emission Standards for Hazardous Air Pollutants (NESHAP) in 40 CFR 61, 

Subpart H, by utilizing the EPA’s COMPLY computer model to determine the 

effective dose equivalent to the public. 

All radioactive waste generated during NREL activities is classified as low 

levellow-level waste. Waste from the STM site is temporarily stored at the 

Waste Handling Facility (WHF) until disposal is arranged at an offsite facility 

permitted to accept low levellow-level radioactive waste. 

5.15.2 Permitting 

NREL does not have a radioactive materials license from the State of 

Colorado, as the Laboratory is currently under DOE jurisdiction for radioactive 

materials handling. 

5.15.3 2002 Activities 

During 2002, the total quantity of radioisotopes used was 10.699 mCi used in 

one laboratory at NREL’s FTLB and one laboratory at the SERF. Any 

emissions generated by this work were emitted by a laboratory hood exhaust. 

In addition, much of NREL’s radioisotope inventory (including waste 

quantities) is in containers on which the manufacturer’s original seal was 

broken. In 2002 the potential dose to the public was calculated as though the 

contents of all unsealed containers was exhausted to the atmosphere, including 

the amount actually used in 2002. P-32 and S-35 waste that is stored in the 
NREL Environmental Performance Report- 2002 

 

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Waste Handling Facility and has decayed past ten half-lives was not included 

in this calculation. 

The distance from the source in the FTLB to the nearest potential receptor is 

119 m (fence line of nearest resident). For the SERF, the distance from source 

to the nearest potential receptor is 256 meters. For the WHF, the distance from 

the source to the nearest potential receptor is 311 m. 

According to the COMPLY computer model, the potential dose to the nearest 

member of the public is 0.045 mrem/yr, below the emission limit of 10 

mrem/yr, and NREL is in compliance with the NESHAP for radionuclides. 

Because the dose is calculated rather than measured, it represents a potential or 

estimated rather than an actual dose. 

The resulting calculated off-site whole body doses are small, but are still likely 

overestimates of potential radionuclide doses. The COMPLY formula assumes 

that the entire quantity of the radionuclide in all open containers was released, 

and that the receptor raises and consumes all his/her own milk, meat, and 

vegetables at home. These assumptions are extremely conservative. 

The total amount of low levellow-level radioactive waste shipped off-site for 

disposal in 2002 was 62.88 MBq (1.699 mCi) of Carbon-14 and tritium (H-3) 

waste material. 

In 2002 there was no construction or modifications to the labs where 

radioisotopes are used. 

There were no unplanned releases of radioisotopes in 2002. 
NREL Environmental Performance Report- 2002 

 

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6 CONSERVATION EASEMENT LANDS 

During 1999, DOE placed 177 acres of the STM site in a Conservation Easement. The 

purpose of the Conservation Easement is to preserve the natural character of the property, 

including its visual, biological, and recreational resources, especially in relation to the 

changing land uses adjacent to the NREL site and within the region. 

The goals of the easement are to: 

 Retain, preserve and protect natural, scenic, ecological, and historical aspects of the 

conservation easement property; 

 Protect the ecosystem of the South Table Mountain area and the sustainable habitat 

for biodiverse vegetation, birds, and terrestrial animals; 

 Ensure the scenic and biological integration with adjoining open-space land; 

 Prevent further industrial, commercial, or residential development of the 

conservation easement property; and 

 Preserve the conservation easement property as natural open space. 

A baseline inventory of the property was prepared in June 1999 to document the current 

condition of the easement property and to assess the conservation value of the property 

(Department of Energy, Golden Field Office, 1999). The baseline inventory includes a 

description of the geographical setting and adjacent property owners, access and use of the 

property by the public, and a description of the existing environmental conditions of the 

property (geology, hydrology, vegetation, wildlife, cultural resources). There are also photos 

incorporated into the report that document the condition of the property. 

2002 Assessment of the Property 

During 2002 there was no NREL activity on the conservation easement property having the 

potential to degrade the environmental condition of the property. A site inspection was 

conducted by Jefferson County Open Space, NREL, and DOE during the summer of 2002. 

No degraded conditions or other environmental issues were found. Photos taken in 2003 

showing the representative areas of the easement lands are included in Section 2 of this report. 
NREL Environmental Performance Report- 2002 

 

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7 REFERENCES 

Armstrong, D.,C. Bock, T. Piaggio, and E. Schmidt (2001). NWTC Site wide Bat and Avian 

Impact Study Plan: May 1, 2001-July 31, 2002. 

EG&G Rocky Flats, Inc., (1992). Rocky Flats Plant Site Environmental Report, January 

Through December 1992. Golden, Colorado. 

Handex of Colorado, Inc. (1997). Groundwater Monitoring Report, South Table Mountain 

Site. Golden, Colorado 

National Renewable Energy Laboratory, (Draft). ES&H Program Number 6-2.12, 

Weed Management Program, STM Site. Golden, Colorado. 

National Renewable Energy Laboratory, (1997). National Renewable Energy Laboratory 

Environmental Report for 1995 and 1996. Golden, Colorado. 

National Renewable Energy Laboratory, (1999a). National Renewable Energy 

Laboratory Five-Year Plan, 2000-2004. Golden, Colorado.

National Renewable Energy Laboratory, (1999b). NREL Policy Number 6-2, Environmental 

Management. Golden, Colorado. 

National Renewable Energy Laboratory, (1999c). NREL Policy Number 6-6, Risk Assessment. 

Golden, Colorado. 

Piaggio, T., Doctoral Candidate, Environmental, Population, and Organismic Biology, 

University of Colorado, Boulder, telephone, communication. July 18, 2001. 

Plantae Consulting Services, (2000). Vegetation Survey, NREL National Wind Technology 

Center. Boulder, Colorado. 

Plantae Consulting Services, (2002). Vegetation Survey, NREL South Table Mountain Site. 

Boulder, Colorado 

Rust Environment & Infrastructure, Inc., (1993). Water Quality Monitoring, National Wind 

Technology Center. Englewood, Colorado. 

Rust Environment & Infrastructure, Inc., (1994a). Final Report, Baseline Surface Water 

Monitoring Program: 1993. Englewood, Colorado. 

Rust Environment & Infrastructure, Inc., (1995a). Report, Wastewater Monitoring Program, 

Fourth Quarter, 1994 and Annual Report. Englewood, Colorado. 
NREL Environmental Performance Report- 2002 

 

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

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

Colorado. 

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

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

Report. University of Colorado, Boulder, Colorado. 

U.S. Department of Energy, (1998). Environmental Assessment, Right-of-Way Easement For 

Public Service Company of Colorado at the South Table Mountain Site, Golden, Colorado. 

DOE/EA-1254. 

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

Laboratory (NREL) Site Conservation Easement Baseline Inventory. Golden, Colorado. 

U.S. Department of Energy, (1993). Site wide Environmental Assessment for the National 

Renewable Energy Laboratory, Golden, Colorado. DOE/EA-0850. 

U.S. Department of Energy, (2002). Site-Wide Environmental Assessment of National 

Renewable Energy Laboratory’s National Wind Technology Center. DOE/EA 1378. 

U.S. Department of Energy, (2003). Site-Wide Environmental Assessment of the National 

Renewable Energy Laboratory’s South Table Mountain Complex. DOE/EA 1440. 
NREL Environmental Performance Report- 2002 

 

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8 APPENDICES 

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

Appendix B – Above Ground Storage Tank Inventory 

NREL Environmental Performance Report- 2002 Page 67

APPENDIX A – SUMMARY OF NREL ENVIRONMENTAL PERMITS, REGISTRATIONS, NOTIFICATIONS 

Tracking 

Number 

Permit or 

Registration 

Number 

Permit or 

Reg. Holder 

Permit Type Permit Description Issuing 

Agency Name

Location 

Description 

Status/ Expiration 

Date 

Reporting Required

Permits 

1 00JE0010L DOE AIR Air Emission Permit 

for Land Development (fugitive dust from construction activities)

Colorado Dept. of Public Health and Environment (CDPHE) 

NWTC site 1/31/05 (issued 

3/1/00) 

N/A 

2 00JE0009L DOE AIR Air Emission Permit 

for Land Development (fugitive dust from construction activities)

CDPHE STM site 1/31/05 (issued 

3/1/00) 

N/A 

3 COR10A59F DOE STORM WATER Storm Water 

(sitewide) -- discharge associated with construction activities

U.S. Environmental Protection Agency (EPA) 

NWTC site 2/17/03 (permit 

issued by EPA 2/17/98) 

Internal updates to SPPP; internal weekly site inspections 

4 COR10A60F MRI STORM WATER Storm Water 

(sitewide) - discharge associated with construction activities

EPA NWTC site 2/17/03 (permit 

issued by EPA 2/17/98) 

Internal updates to SPPP; internal weekly site inspections 

5 COR10A57F DOE STORM WATER Storm Water 

(sitewide) - discharge associated with construction activities

EPA STM site 2/17/03 (permit 

issued by EPA 2/17/98) 

Internal updates to SPPP; internal weekly site inspections 

6 COR10A58F MRI STORM WATER Storm Water 

(sitewide) - discharge associated with construction activities

EPA STM site 2/17/03 (permit 

issued by EPA 2/17/98) 

Internal updates to SPPP; internal weekly site inspections 

7 37232 SERI Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-1) 

Colo. Div. Of Water Resources 

STM construction 

complete, permit number active until well is closed 

none 
NREL Environmental Performance Report- 2002 Page 68

Tracking 

Number

Permit or 

Registration 

Number

Permit or 

Reg. Holder

Permit Type Permit 

Description

Issuing 

Agency Name

Location 

Description

Status/ Expiration 

Date

Reporting Required

8 37229 SERI Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-2) 

Colo. Div. Of Water Resources 

STM construction 

complete, permit number active until well is closed 

none 

9 37228 SERI Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-3) 

Colo. Div. Of Water Resources 

STM construction 

complete, permit number active until well is closed 

none 

10 37231 SERI Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-4) 

Colo. Div. Of Water Resources 

STM construction 

complete, permit number active until well is closed 

none 

11 37230 SERI Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-5) 

Colo. Div. Of Water Resources 

STM construction 

complete, permit number active until well is closed 

None 

12 214960 NREL/DOE Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-11) 

Colo. Div. Of Water Resources 

STM construction 

complete, permit number active until well is closed 

none 

13 214961 NREL/DOE Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-10) 

Colo. Div. Of Water Resources 

STM construction 

complete, permit number active until well is closed 

none 

14 214962 NREL/DOE Groundwater 

Monitoring Well 

Permit to Construct a Well (MW-09) 

Colo Div. Of Water Resources 

STM construction 

complete, permit number active until well is closed 

none 

15 99JE0400 NREL/DOE Air TCPDU air 

emissions 

CDPHE STM initial approval 

issued 7/20/2000 

None 

16 20030373 NREL Hazardous 

Materials 

Hazardous Material Storage and Use Permit for Building 

West Metro Fire Protection District 

Building 16 2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually 
NREL Environmental Performance Report- 2002 Page 69

Tracking 

Number

Permit or 

Registration 

Number

Permit or 

Reg. Holder

Permit Type Permit 

Description

Issuing 

Agency Name

Location 

Description

Status/ Expiration 

Date

Reporting Required

17 20030374 NREL Hazardous Materials Hazardous 

Material Storage and Use Permit for Building 

West Metro Fire Protection District 

Waste Handling 

Facility (WHF)

2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually 

18 20030375 NREL Hazardous Materials Hazardous 

Material Storage and Use Permit for Building 

West Metro Fire Protection District 

SERF 2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually 

19 20030376 NREL Hazardous Materials Hazardous 

Material Storage and Use Permit for Building 

West Metro Fire Protection District 

FTLB 2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually 

20 20030377 NREL Hazardous Materials Hazardous 

Material Storage and Use Permit for Building 

West Metro Fire Protection District 

AFUF 2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually 

21 20030378 NREL Hazardous Materials Hazardous 

Material Storage and Use Permit for Building 

West Metro Fire Protection District 

Shipping & 

Receiving 

Facility 

2003 Annual fee, fire dept. 

inspection; new chemical inventory provided annually 

Notifications and Registrations 

22 PWSID Number 

230860 

DOE DRINKING 

WATER 

Non-community supply of hauled water from a surface water source 

CDPHE NWTC site N/A Periodic chlorine 

residual testing; monthly bacteriological testing; periodic lead and copper monitoring 

23 CO4890000017 DOE HAZARDOUS 

WASTE 

Notification of Regulated Waste Activity 

CDPHE DWOP update recommended 

every 3-5 years, or sooner if substantial changes in activity occur. Last update: 7/97 

annual fee to Colorado Hazardous Waste Commission 
NREL Environmental Performance Report- 2002 Page 70

Tracking 

Number

Permit or 

Registration 

Number

Permit or 

Reg. Holder

Permit Type Permit 

Description

Issuing 

Agency Name

Location 

Description

Status/ Expiration 

Date

Reporting Required

24 CO3890090076 DOE HAZARDOUS 

WASTE 

Notification of Regulated Waste Activity 

CDPHE STM update recommended 

every 3-5 years, or sooner if substantial changes in activity occur. Last update: 7/97 

annual fee to Colorado Hazardous Waste Commission 

25 COD980805162 DOE HAZARDOUS 

WASTE 

Notification of Regulated Waste Activity 

CDPHE JSF update recommended 

every 3-5 years, or sooner if substantial changes in activity occur. Last update: 7/97 

none 

26 COD983802448 DOE HAZARDOUS 

WASTE 

Notification of Regulated Waste Activity 

CDPHE NWTC update recommended 

every 3-5 years, or sooner if substantial changes in activity occur. Last update: 7/97 

none 

27 00407-001 and 

00407-002 

DOE AIR: OZONE 

DEPLETING SUBSTANCES 

Registration of stationary appliances (2 SERF chillers) 

CDPHE SERF annual renewal due 

July 1 

none 

28 N/A DOE AIR: OZONE 

DEPLETING SUBSTANCES 

Facility Notification 

CDPHE STM, NWTC annual notification 

and fee due December 1 

29 N/A DOE AIR: OZONE 

DEPLETING SUBSTANCES 

Registration of stationary appliance (chiller in DWOP)

CDPHE DWOP annual renewal due 

July 1 

2930 2873-001 and 

2873-002 

DOE ABOVE GROUND 

STORAGE TANK 

Registration of aboveground storage tanks 

Colorado Dept. of Labor 

STM--PDU 

Ethanol Storage 

Tank, SERF 

Emergency 

Generator Tank

annual registration and fee, due April/May 

none 
NREL Environmental Performance Report- 2002 Page 71

Tracking 

Number

Permit or 

Registration 

Number

Permit or 

Reg. Holder

Permit Type Permit 

Description

Issuing Agency Name

Location 

Description

Status/ Expiration Date

Reporting Required

31 93000378 DOE Historic Registration National Register 

of Historic Places

National Park Service 

Colorado 

Amphitheater 

no expiration none 

32 93000379 DOE Historic Registration National Register 

of Historic Places

National Park Service 

Ammunition 

Igloo 

no expiration none 

3233 AFP-CO-00255 DOE Alcohol (not an 

environmental permit) 

Alcohol Producer's Permit

Bureau of Alcohol, Tobacco, and Firearms 

AFUF (PDU) annual renewal due 

July 1 

annual report due Jan 30 

3334 TF-CO-0331 DOE Alcohol (not an 

environmental permit) 

Industrial Alcohol User Permit 

Bureau of Alcohol, Tobacco, and Firearms 

NREL-wide annual renewal due 

July 1 

none 

3435 N/A NREL Transportation Hazardous 

Material Transportation 

U.S. Department of Transportation 

NREL-wide annual renewal and 

fee 

none 
NREL Environmental Performance Report- 2002 Page 72

APPENDIX B - ABOVEGROUND STORAGE TANK INVENTORY 

Tank 

ID 

Size Contents Class Use Date On-Line Service 

Status 

Date Last 

Change in 

Status 

No. 1 1010 gallons Diesel II FTLB Emergency Generator 

(UST) 

1983 Closed 

(6/96) 

6/96 

No. 2 800 gallons Diesel II SERF Emergency Generator 10/93 In-Service 

 Double-walled, interstitial monitor, no secondary containment 

No. 3 6000 gallons Ethanol, 50% IC PDU Ethanol Storage 12/95 In-Service 

 Single-walled, remote monitoring, 7500 gal concrete containment 

No. 4 564 gallons Diesel II PDU Emergency Generator 8/95 In- Service 6/15/98 OS 

9/11/98 IS 

 Double-walled, interstitial monitor, no secondary containment 

No. 5 560 gallons Diesel II FTLB Emergency Generator 6/96 In-Service 

 Double-walled, interstitial monitor, concrete secondary containment 

No. 6 400 gallons Diesel II IUF Emergency Generator 3/97 In-Service 

 Double-walled, no secondary containment 

No. 7 80 gallons Diesel II 251 Emergency Generator 1980 PC No. 8 500 gallons Diesel II NWTC Hybrid Power Test 

Bed (HBTB) Convault, popup interstitial monitor 

 6/97 In-Service 

No. 9 500 gallons Diesel II Bldg 16 Emergency Generator 

Single-walled, no interstitial 

monitor, 537-gal secondary 

containment 

1990 In-Service 

No. 10 100 gallons Diesel II NWTC NPS Daytank 

Double-walled, no interstitial monitor 

6/96 In-Service 
NREL Environmental Performance Report- 2002 Page 73

Tank 

ID 

Size Contents Class Use Date On-Line Service 

Status 

Date Last 

Change in 

Status 

No. 11 100 gallons Diesel II NWTC HPTB North Daytank 

(SIM#1) Single-walled, no interstitial monitor 

6/97 In-Service 

Tank 

ID

 Size Contents Class Use Date On-Line Service 

Status

Date Last 

Change in 

Status 

No. 12 100 gallons Diesel II NWTC HPTB South Daytank 

(SIM#2) Single-walled, no interstitial monitor 

6/97 In-Service 

 No. 13 50 gallons Diesel II SunWize (West of HPTB) 

Single-walled, 36-gal steel catch basin 

5/98 NC 

No. 14 200 gallons Diesel II 251 Stand-by Generator 

Double-walled, no interstitial monitor 

9/98 In-Service 

No. 15 100 gallons Diesel II AFUF Emergency Generator 

Double-walled, no interstitial monitor 

6/94 TC 10/2000 TC 

No. 16 50 gallons Diesel II Bergey Hybrid System 

(Site 1.8)  Double-walled, no interstitial monitor 

1/00 NC 

No. 17 173 gallons Diesel II NWTC Hybrid 80 (Sim #4) 

Double-walled, no interstitial monitor 

3/01 In-Service 

No. 18 336 gallons Diesel II NWTC Hybrid 125 (Sim #3) 

Double-walled, no interstitial monitor 

3/01 In-Service 
NREL Environmental Performance Report- 2002 Page 74

No. 19 500 gallons Propane - NWTC East Met Tower - NC No. 20 500 gallons Propane - NWTC West Met Tower - NC No. 21 500 gallons Propane - Capstone Micoturbine - NC 

Service Status  In-Service (IS)  Out-of-Service (OS)  Temporary Closure (TC)  Permanent Closure (PC)  Change-In-Service (CIS)  NC—not covered by this Program