NATIONAL RENEWABLE ENERGY LABORATORY 

ENVIRONMENTAL PERFORMANCE REPORT for 2006 

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

 

Prepared by: 

Environment, Safety, Health & Quality Office 

National Renewable Energy Laboratory

NREL is a national laboratory of the 

U.S. Department of Energy and is

Operated by Midwest Research Institute and Battelle 

September 2007 

NREL Environmental Performance Report- 2006

 

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NREL Environmental Performance Report- 2006 

 

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Cover Photo contributed by NREL Employee Ruth Baranowski, 2007: NWTC early morning 

view of double rainbows over the Flatirons 
NREL Environmental Performance Report- 2006 

 

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TABLE OF CONTENTS 

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

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

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

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

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

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

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

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

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

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

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

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

2.2 DOE Order 450.1, Environmental Protection Program....................................................................24

2.3 Executive Orders................................................................................................................................24

2.4 Permit Summary.................................................................................................................................26

3 ENVIRONMENTAL OCCURRENCES....................................................................................................26

4 ENVIRONMENTAL MANAGEMENT SYSTEM...................................................................................28

4.1 Description.........................................................................................................................................28

4.2 Performance Indicators and Progress...............................................................................................30

4.3 Assessment and Improvement ............................................................................................................33

4.4 Sustainability and the Environmental Management System ..............................................................35

5 ENVIRONMENTAL PROGRAMS...........................................................................................................36

5.1 Air Quality Protection........................................................................................................................36

5.1.1 Program Management ................................................................................................................36

5.1.2 Permitting...................................................................................................................................38

5.1.3 2006 Activities...........................................................................................................................38

5.2 Drinking Water ..................................................................................................................................38

5.2.1 Program Management ................................................................................................................38

5.2.2 Permitting/ Notifications............................................................................................................40

5.3 Groundwater Protection ....................................................................................................................41

5.3.1 Program Management ................................................................................................................41

5.3.2 Permitting...................................................................................................................................43

5.3.3 2006 Activities...........................................................................................................................43

5.4 Wastewater Discharge .......................................................................................................................43

5.4.1 Program Management ................................................................................................................43

5.4.2 Permitting...................................................................................................................................43

5.4.3 2006 Activities...........................................................................................................................44

5.5 Surface Water Protection (Storm Water and Erosion Control).........................................................44

5.5.1 Program Management ................................................................................................................44

5.5.2 Permitting...................................................................................................................................45

5.5.3 2006 Activities...........................................................................................................................45

5.6 Waste Management............................................................................................................................45

5.6.1 Program Management ................................................................................................................45

5.6.2 Permitting...................................................................................................................................46

5.6.3 2006 Activities...........................................................................................................................46

5.7 Storage Tanks (Underground and Aboveground)..............................................................................46

5.7.1 Program Management ................................................................................................................46

5.7.2 Permitting...................................................................................................................................47

5.7.3 2006 Activities...........................................................................................................................47
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5.8 Hazardous Materials Management....................................................................................................47

5.8.1 Program Management ................................................................................................................47

5.8.2 Permitting...................................................................................................................................49

5.8.3 2006 Activities...........................................................................................................................49

5.9 Pollution Prevention & Sustainability ...............................................................................................50

5.9.1 Waste Minimization, Recycling, and Green Purchasing............................................................50

5.9.2 Vehicles......................................................................................................................................53

5.9.3 Renewable Energy .....................................................................................................................57

5.9.4 Water Conservation....................................................................................................................59

5.9.5 Sustainable Building Design ......................................................................................................60

5.9.6 Technical Assistance and Outreach............................................................................................62

5.10 Vegetation ..........................................................................................................................................62

5.10.1 Program Management ................................................................................................................62

5.10.2 Permitting...................................................................................................................................65

5.10.3 2006 Activities...........................................................................................................................65

5.11 Wildlife...............................................................................................................................................66

5.11.1 Program Management ................................................................................................................66

5.11.2 Permitting...................................................................................................................................67

5.11.3 2006 Activities...........................................................................................................................68

5.12 Endangered Species/Species of Concern ...........................................................................................71

5.12.1 Program Management ................................................................................................................71

Permitting...................................................................................................................................................73

5.12.2 2006 Activities...........................................................................................................................73

5.13 Wetlands/Floodplains........................................................................................................................73

5.14 Cultural Resources.............................................................................................................................74

5.14.1 Program Management ................................................................................................................74

5.14.2 Permitting...................................................................................................................................76

5.14.3 2006 Activities...........................................................................................................................76

5.15 National Environmental Policy Act (NEPA)......................................................................................77

5.15.1 Program Management ................................................................................................................77

5.15.2 Permitting...................................................................................................................................77

5.15.3 2006 Activities...........................................................................................................................78

5.16 Radiological Program........................................................................................................................78

5.16.1 Program Management ................................................................................................................78

5.16.2 Permitting...................................................................................................................................79

5.16.3 2006 Activities...........................................................................................................................79

6 CONSERVATION EASEMENT LANDS .................................................................................................80

7 REFERENCES.............................................................................................................................................83

8 APPENDICES..............................................................................................................................................85
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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 1.5 - South Table Mountain Site – West end of the site........................................ 17 

Figure 1.6 - South Table Mountain Site – East view ........................................................ 17 

Figure 1.7 - South Table Mountain Site – NW and mesa top view .................................. 18 

Figure 1.8 – South Table Mountain Site – Denver West Office Park............................... 18 

Figure 1.9 – NWTC Site – NW View............................................................................... 19 

Figure 1.10 – NWTC Site – NW View with research facilities........................................ 19 

Figure 5.1 – NREL Transportation by Mode.................................................................... 53 

Figure 5.2 – NREL Fleet Petroleum Use .......................................................................... 53 

Figure 5.3 – FY06 Energy Use Reduction Progress (Electricity/Natural Gas)................. 56 

Figure 5.4 – GHG Emissions Reductions ......................................................................... 59 

Figure 5.5 – FY06 Kg CO2 Emissions Breakdown.......................................................... 60 

Figure 5.6 – L.E.E.D. Platinum Certified S&TF at STM ................................................. 63 

Figure 5.7 – Frosted Yucca ............................................................................................... 64 

Figure 5.8 – Noxious Weed .............................................................................................. 65 

Figure 5.9 – Flower at STM.............................................................................................. 66 

Figure 5.10 – Lush vegetation growth along the NWTC north fence line ....................... 66 

Figure 5.11 – Mule Deer ................................................................................................... 70 

Figure 5.12 – Coyote eating a jackrabbit at STM ............................................................. 72 

Figure 5.13 – Rattlesnake in the leaf litter ........................................................................ 72 

Figure 5.14 – A bull snake and a rabbit ............................................................................ 72 

Figure 5.15 – STM Site Wildlife....................................................................................... 73 

Figure 5.16 – STM Site Wildlife....................................................................................... 73 

Figure 5.17 – Eurasian collared dove................................................................................ 75 

Figure 5.18 – STM Site Cultural Resource....................................................................... 76 

Figure 5.19 – STM Site Cultural Resource....................................................................... 77 

Figure 5.20 – STM Site Conservation Easement.............................................................. 82 

Figure 5.21 – STM Site Easement Lands.......................................................................... 83 

Figure 5.22 – STM Site Wildlife at Sunset....................................................................... 84 

LIST OF TABLES 

Table 4.1 – Greenhouse Gas Emissions ......................................................................... 31 

Table 4.2 – Water Use....................................................................................................... 31 

Table 4.3 – Total Energy Use ....................................................................................... 32 

Table 5.1 – Energy Consumption .................................................................................. 57 

Table 5.2 – Water Consumption ....................................................................................... 61
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1 INTRODUCTION 

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

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

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

under the oversight of the DOE Golden Field Office (GO). NREL is the nation's premier 

laboratory for renewable energy research and development and a leading laboratory for energy 

efficiency research, with programs in wind energy, solar energy, plant and waste-derived fuels 

and chemicals, energy efficiency in buildings, geothermal energy, advanced vehicle design, 

hydrogen infrastructure, and fuel cells. 

Purpose

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

activities for 2006. It is organized according to the different environmental media (e.g., 

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

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

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

reporting period in that environmental area. A description of the environmental condition 

and features of NREL’s sites is also included to provide a basis for the program 

overview. 

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

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

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

231.1 and 5400.5. 

Background

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

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

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

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

major technology area follows. 

Photovoltaics: Photovoltaics enables 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 utilization throughout the world. 

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

and biomass-derived electricity (biopower), and projects in biomass-derived chemicals 

and materials. 
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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 utilization of renewable 

energy and energy efficiency products. As a part of this initiative, NREL is involved in 

the development, design, and facilitation of the application of renewable and 

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

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

the use of renewable energy technologies in the building sector by working to develop 

new, cost-effective, and environmentally acceptable building equipment and envelope 

systems. 

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

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

development. Basic and applied research and material development using biology, 

physics, and chemistry enable and support the development of hydrogen production, 

storage, and end-use systems. 

Transportation: NREL works with industry to develop advanced vehicles and systems 

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

transportation initiatives. NREL also works with energy companies and manufacturers 

of vehicles and engines to develop advanced motor vehicle fuels for improved energy 

and environmental performance. A systems approach is used to develop optimized 

engine management, fuel, and emission control technologies. 

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

renewable energy and energy efficient technologies. 

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

Electricity Technologies: These technologies include renewable energy, hydrogen, and 

superconductivity technologies, plus utility resources. 

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

initiatives. 

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

photovoltaic cells, building technologies, and wind turbines. 

Renewable Energy Resources: Researchers develop resource information for solar, 

wind, biomass, and geothermal energy applications. 
Site and Facility Description

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

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

facilities in Jefferson County include the Denver West Office Park (DWOP), the South 

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

Technology Center (NWTC).The Renewable Fuels and Lubricants Research Laboratory

(ReFUEL) is located within the city limits of Denver. The DWOP and STM sites are

approximately 2 miles (3.2 km) east of Golden and 12 miles (19.3 km) west of central 

Denver. The NWTC is located near the intersection of Highways 93 and 128, between 

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

adjacent to the former 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) at 1900 31st Street, Denver, about 12 

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

DWOP, NWTC, and JSF sites on a regional map. The location of the ReFUEL Facility is 

shown on Figure 1.2. Figure 1.3 provides a more detailed map of the STM site, and 

Figure 1.4 provides detail for the NWTC site. 

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

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

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

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

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

complex housed within the RTD/DSOC facility. NREL performs engine-testing activities

pertaining to fuels and lubricants at the site.

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Joyce Street

Facility

Denver West Office

Park Site (Bldgs 15, 

16, 17, 7)

National Wind 

Technology Center 

Figure 1.1. Regional Map showing NREL locations in Jefferson County, CO. 

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N

 

REL Environmental Performance Report- 2006

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I25 

I70 

NREL

ReFUEL

Figure 1.2. ReFUEL Facility Location Map, located in Denver County, CO. 
Figure 1.3. STM Site Detail. 

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Figure 1.4. NWTC Site Detail. 
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Site Environmental Conditions/Features

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

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

Denver West Office Park sites, and Figures 1.9 and 1.10 provide images of the National 

Wind Technology Center site. The views on the STM site also illustrate the Conservation 

Easement property and the Camp George West property acquired in 1999. 

Climate

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

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

daily and seasonal temperature variations. 

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

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

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

decrease significantly in the fall, and reaches the minimum during winter. Winter is the 

driest season, contributing less than 10% of the annual precipitation, primarily in the 

form of snowfall. 

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

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

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

25 cm (6 to 10 in.). 

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

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

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

1.1 South Table Mountain Site 

Geology, Soils, and Hydrogeology 

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

and lower south-facing slopes of South Table Mountain. South Table Mountain is 

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

erosion. The South Table Mountain feature is a mesa that stands about 150 meters above 

the adjacent lowlands. The mesa was formed as weak sedimentary rocks surrounding the 

lava were eroded away, leaving the lava-capped mesa in relief. Below the lava caprock, 

the sedimentary rocks are part of the Denver Formation that consists of layers and lenses 

of claystone, sandstone, and conglomerate. Sedimentary rocks of the Arapahoe 

Formation underlie the Denver Formation. 

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 
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South Table Mountain, and within the materials above the Denver Formation, which are 

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

direction. 

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

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

shallow, well-drained clayey soil. Soil on the upper side slopes of South Table Mountain 

is also a loam consisting of extremely stony soils with significant amounts of clay. Much 

of the remainder of the site, including the area designated for major development, has a 

deep, well-drained soil referred to as Denver clay loam. It consists of clayey material 

containing some calcium carbonate. There are also two smaller soil areas on the 

southwestern portion of the site, both of similar character to other site soils: cobbly clay 

loam and very stony clay loam. 

Surface Water 

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

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

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

site ultimately flows into Lena Gulch. 

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

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

found in the drainage channels with seasonal springs evident along some of the mesa 

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

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

Vegetation 

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

The most common plant communities on the STM site are mixed grasslands, composing 

more than 80% of the vegetation on the site. These communities are generally 

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

occur on the STM site: mountain mahogany shrublands, found on the shallow soils of 

the mesa, and upland shrublands, occurring in drainages lacking active channels as well 

as drainages with associated wetlands. Recent field surveys have identified limited 

wetland/riparian areas along drainages. The wetland communities identified on the STM 

site are a minor component of the total vegetation cover, accounting for less than 1% of 

the vegetation over an area of less than 0.3 ha (0.75 ac). Riparian shrub communities 

also occur adjacent to the emergent wetlands. 

Wildlife 

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

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

update the existing data began in 2004 and was completed in 2005 (see section 5.11 for 

more detail). Mammals seen using the site during the surveys include mule deer, 

coyotes, gray foxes, red foxes, raccoons, long tailed weasels, striped skunks, spotted 

skunks, badgers, bobcats, mountain lions, rabbits, and yellow-bellied marmots. 

Seventeen species of birds have been observed on the STM site, along with two species 
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of raptors: American kestrels and two nesting pairs of red-tailed hawks. NREL 

personnel have reported numerous sightings of snakes as well as a golden eagle. 

Amphibian species are known to inhabit the area as well. 

Land Use 

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

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

are located immediately to the south and west of the western portions of the STM site. 

Pleasant View has constructed a recreational park immediately south of the STM site. 

Offices, shops, and a tree nursery owned by the Colorado State Forest Service are 

located at the far western edge. Undeveloped state land and a Colorado State Highway 

Patrol pursuit driver-training track are located along the northwestern boundary of the 

STM site on top of the mesa. Jefferson County open space wraps around the northern 

and the eastern edge of the site. Portions of the DWOP and apartment homes lie to the 

east. 

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

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

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

Space. Trail development is planned for implementation in phases by the County, and 

was begun in 2004 (see Section 6.0 for more detail). 

1.2 National Wind Technology Center 

Geology, Soils, and Hydrogeology 

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

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

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

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

consist primarily of claystones with some siltstones. Unconfined groundwater flow 

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

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

Rocky Flats, Inc., 1992). 

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

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

dominated by clay (USDA, 1995). 

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. 
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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: 

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 ( see 

Section 5.10). Although seldom seen, rattlesnakes, bull snakes, racers, and several other 

reptilian and amphibian species are known to occupy the area. 

Land Use 

The NWTC facility occupies a 305-acre area surrounded largely by open space and 

grazing land. The former Rocky Flats Environmental Technology Site land borders the 

NWTC to the southeast, and a sand and gravel mining and processing operation is 

located along the southern and western boundaries of the site. A blasting company also 

has a small installation along the western site boundary. 

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. 
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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 primarily as 

warehouse space only. No support activities and only occasional research 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 and 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 

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

Figure 1.6. South Table Mountain Site – East view.

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Figure 1.7. South Table Mountain Site – NW and mesa top view. The Colorado State Highway

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

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

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Figure 1.9. NWTC Site – Northwest view. 

Figure 1.10. NWTC Site – NW view with research facilities.

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2 COMPLIANCE SUMMARY 

2.1 Laws and Regulations 

Air Quality Protection 

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

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

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

Agency (EPA). NREL does not have a major source for air pollutants on site, but does 

hold two site-wide permits for particulate air emissions from construction and one air 

emissions permit for a pilot scale research project. NREL has been conducting increased 

monitoring since the fourth quarter of 2006 for disinfection byproducts. 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 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. 

In 2006, NREL had no air quality compliance issues. 

Drinking Water Quality Protection 

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

CDPHE, under authority delegated by the 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. 

Groundwater Quality Protection 

Colorado groundwater standards are established by the Colorado Department of Natural 

Resources. That department also issues permits for groundwater 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. 

In 2006, NREL had no ground water compliance issues. 
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Wastewater 

Wastewater 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 Acts implementing wastewater discharge regulations are 

administered at NREL’s STM and DWOP via Pleasant View and Metro requirements. 

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

requirements. Wastewater at the NWTC site flows into two individual sewage disposal 

systems (septic and leach fields). These are regulated by CDPHE; inspection and permit 

issuance have been delegated by CDPHE to the Jefferson County Department of Health 

and Environment. There is also one individual sewage disposal system at the Solar 

Radiation Research Laboratory on the mesa top at the STM Site. As is the case with 

NWTC septic systems, the mesa top system regulations are administered by Jefferson 

County. Additional detail about NREL’s wastewater discharge program can be found in 

Section 5.4. 

In 2006, NREL had no wastewater compliance issues. 

Surface Water Quality Protection 

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

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

(CGP) Program for the STM and NWTC sites for storm water discharge from 

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

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

characteristics. 

During 2006, two small construction projects (less than 0.25 acres each) were undertaken 

at the NWTC. Neither of these projects required permitting. As a best management 

practice and to be consistent with NREL policy, an Erosion and Sediment Control Plan 

was developed for each project to address possible stormwater issues. At the STM, a 

Notice of Intent was filed with the EPA in 2005 for the 8.5 acre construction zone of the 

S&TF. This project was managed under the EPA’s Construction General Permit 

Program. Vegetative coverage has not achieved 70% in an area adjacent to the facility 

due to foundation repair activities in spring 2007. A Notice of Termination is anticipated 

to be filed in mid-CY08. Details of NREL’s surface water protection program are 

provided in Section 5.5. 

Waste Management 

The Resource Conservation and Recovery Act (RCRA) established federal authority over 

hazardous waste. In Colorado, CDPHE administers hazardous waste regulations under 

authority delegated by the EPA. NREL holds five 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. 
NREL Environmental Performance Report- 2006 

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In 2006, NREL had no waste management compliance issues. A hazardous waste 

management inspection by CDPHE was conducted in late August 2006. The final report 

and follow-up actions are discussed in Section 5.6. 

Storage Tanks

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

only water in bermed tanks at the NWTC. Aboveground storage tanks (ASTs) 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. 

A state inspection of NREL’s regulated ASTs was conducted in 2006. A field Violation 

Report was issued for insufficient tank grounding on one tank. The issue was 

satisfactorily resolved within one week. No spills or releases from NREL’s ASTs 

occurred during 2006. 

Threatened and Endangered Species/Species of Concern 

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

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

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

plant species. State laws also designate and protect rare or unique plants and animals. No 

threatened or endangered species or species of concern have been documented on 

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

5.11. 

In 2006, NREL had no compliance issues regarding wildlife. 

EPCRA Compliance and Prevention of Toxic Releases 

Executive Order (EO) 13148 outlines requirements for SARA Title III, Emergency 

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

Inventory reductions for government facilities. NREL maintains hazardous materials 

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

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

In 2006, NREL facilities had no releases 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 MSDS and 

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

with the jurisdictional fire department. 

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

materials, and during 2006, the laboratory did not otherwise use any materials on the 

SARA Section 313 list in quantities exceeding the 4,526-kg (10,000-lb) threshold 

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

5.8. 
NREL Environmental Performance Report- 2006 

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

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

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

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

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

Cultural Resources Protection 

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

Native American Graves Protection and Repatriation Act, protect cultural resources. 

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

There are no known eligible sites at the NWTC. In 2007, the DOE Golden Field Office 

and NREL conducted cultural resource surveying associated with the Environmental 

Assessment (EA) for three site development projects on the NREL STM Site (see Section 

5.14). 

In 2006, NREL had no compliance issues regarding cultural resources. 

2.2 DOE Order 450.1, Environmental Protection Program 

DOE Order 450.1 requires sites to implement Environmental Management Systems 

(EMSs) by integrating them with the site’s Integrated Safety Management System. Sites 

were required to have an EMS in place by December 31, 2005. NREL’s implementation 

of its EMS is described in Section 4.0 of this report. 

2.3 Executive Orders 

Executive Order 13423, Strengthening Federal Environmental, Energy, and 

Transportation Management 

On January 24, 2007, the President signed Executive Order (EO) 13423. This Order 

requires all Federal agencies and departments to “conduct their environmental , 

transportation, and energy-related activities under the law in support of their respective 

missions in an environmentally, economically and fiscally sound, integrated continuously 

improving, efficient and sustainable manner” 72 FR 3919. DOE’s senior management has 

been working on a Transformational Energy Action Management (TEAM) Initiative to 

create and implement a plan designed to expedite attainment of the requirements imposed 

by the EO. Application of EO 13423’s objectives will be discussed in NREL’s 2007 

Environmental Performance Report. 

Although EO 13423 supersedes EO 13148 and EO 13201, the two superseded orders will 

be discussed here as they were in effect in 2006. 

Executive Order 13148 

In March 2000, EO 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 long-term 

planning processes. In February 2001, DOE issued a notice (DOE N 450.4) outlining 
NREL Environmental Performance Report- 2006 

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requirements for DOE contractors under EO 13148. NREL’s compliance with these 

requirements is explained below. 

Specific requirements under EO 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 Sections 4.0 and 5.0, 

respectively. Compliance with environmental regulations at NREL, including EPCRA is 

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

5.1, and sustainable landscaping is discussed in Section 5.10. 

Executive Order 13201, Greening the Government Through Waste Prevention, Recycling, 

and Federal Acquisition 

NREL enters data on its recycling and affirmative procurement (environmentally 

preferable purchasing) activities into DOE’s pollution prevention web-based database on 

an annual basis. A discussion of NREL’s pollution prevention and sustainability activities 

can be found in Section 5.9. 

Executive Order 11988, Floodplains Management 

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

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

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

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

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

withstand the equivalent of a 100-year flood). 

Actions with the potential for environmental impact that are undertaken by NREL at 

subcontractor facilities are assessed for potential impacts on floodplains and wetlands at 

those sites through the use of an environmental checklist. 

Executive Order 11990, Wetlands Protection 

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

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

and field mint. 

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). 

In 2006, NREL had no compliance issues regarding environment-related Executive 

Orders. 
NREL Environmental Performance Report- 2006 

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2.4 Permit Summary 

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

notifications. 

3 ENVIRONMENTAL OCCURRENCES 

There were three incidents with environmental implications during 2006 at the STM and 

NWTC sites reported through ORPS.. 

Offsite Wildland Fire in Proximity to the NREL NWTC 

A wildland fire started near the intersection of Colorado State Highways 72 and 93 in the 

evening of January 10, 2006. At the time, the origin of the fire was approximately 2.5 

miles southwest of NREL’s NWTC. Due to high winds (30 – 60 mph) experienced 

overnight, the fire grew to approximately 2700 acres by 06:00 (MTZ) the morning of 

January 11, 2006. By that time, more than 175 firefighters from 25 separate fire agencies 

were working to contain the fire. At 08:00 (MTZ), the NREL Facility Manager 

determined that due to existing conditions and National Weather Service predictions for 

high winds, the fire posed a potential threat to assets at the NWTC. Notifications were 

initiated per ORPS requirements. The fire was 80% contained by 10:00 (MTZ) and was 

determined to no longer pose a threat to the NWTC by fire authorities. On scene 

estimates indicate that the fire approached within 1-mile of the NWTC. Site evacuation 

was not necessary. There were no NREL injuries or property damage. 

Wildland Fire East of NREL NWTC 

A wildland fire burned an estimated 1600 acres near the former DOE RFETS site 

Sunday, April 2, 2006. The fire was discovered at approximately 13:30 (MTZ) and is 

believed to have started at a point approximately 1.2 miles east of the NREL NWTC. The 

fire was fanned by high winds gusting between 30-50 mph, according to the National 

Weather Service. Prevailing winds pushed the fire to the east/southeast, away from the 

NWTC. Approximately 100 firefighters from multiple agencies battled the fire. 

Authorities evacuated 135 homes by 16:00 hours (MTZ) and the fire was 100% contained 

by 18:00 (MTZ). Preliminary reports indicate that the fire started at an electrical utility 

pole located in a field south of Colorado State Highway 128, approximately 1.2 miles 

east of the NWTC. There were no NREL injuries or structural damage attributed to the 

fire. 

SERF Above-Ground Storage Tank Field Violation Report 

An inspector from the Colorado Department of Labor and Employment, Division of Oil 

and Public Safety arrived on the NREL STM Site on Friday, April 28, 2006 to conduct an 

unannounced inspection of state regulated above-ground storage tanks (ASTs). NREL 

has two ASTs regulated by the State of Colorado; one empty 6,000 gallon ethanol tank, 

located at the AFUF Process Development Unit, and one 800 gallon fuel tank to support 

an emergency generator for the SERF. The state inspector, accompanied by the SERF 

Building Area Engineer, indicated that, based on a visual inspection, the 800 gallon fuel 

tank may not have been sufficiently grounded, and issued a Field Violation Report. The 
NREL Environmental Performance Report- 2006 

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tank is a flat tank; the emergency generator sits on top of the tank as a single unit. State 

inspections conducted in 1997, 1998, and 1999 did not identify a grounding noncompliance with either regulated tank. They found the ASTs to be installed in accordance 

with the Colorado regulation pertaining to grounding that requires that, “All equipment 

such as tanks, machinery and piping, where an ignitable mixture may be present, shall be 

bonded or connected to a ground.” NREL has conducted previous visual inspections of 

the tank and generator system that specifically evaluated the grounding adequacy. Based 

on these inspections, it appeared to the NREL inspector that the tank was properly 

grounded by metal-to-metal contact with the generator, and was therefore in compliance 

with the Colorado State AST regulations. An additional ground was added to the tank. 

Other environmental issues and actions in CY2006 include the following: 

Voluntary Self Assessment Conducted on the SERF Storage Tanks 

As a standard operating procedure, all tanks larger thank 110 gallons are visually 

inspected at least once per month. In addition, during CY2006, the NREL inspector 

conducted self assessments on the storage tanks at the STM - SERF. 

Increased Monitoring due to Exceedance of TTHMs MCL 

On October 12, 2006, CDPHE notified NREL that the annual result for total 

trihalomethanes (TTHM) exceeded the applicable maximum contaminant level (MCL), 

and required an increase in monitoring from an annual sample to quarterly samples. The 

result for the sample collected in August 2006 was 0.082 mg/L; the MCL is 0.080 mg/L. 

CDPHE wrote that “NREL must increase monitoring from yearly to quarterly monitoring 

beginning in the fourth quarter of 2006 for both disinfection byproducts (TTHM and 

HAA5).” While the haloacetic acid (HAA5) result had been within the applicable MCL, 

the CDPHE program required increased monitoring for both sets of disinfection 

byproducts. NREL immediately directed the operator to collect quarterly samples for 

TTHMs and HAA5s. The first sample was collected in November 2006, and the results 

were below the applicable MCLs. Collection of the quarterly samples will continue in 

2007. 

State of Colorado RCRA inspection of STM Site 

In August of 2006, two representatives of the Colorado Department of Public Health and 

Environment (CDPHE) conducted an RCRA inspection of the South Table Mountain 

facilities. In addition to inspecting waste generating areas in labs, the waste handling 

facility, and the newly opened Science and Technology Facility, the inspectors also 

reviewed employee training records and the ESH&Q hazardous waste records. The items 

noted by the CDPHE inspectors were minor in nature and no enforcement actions were 

taken as a result of the visit. All identified issues have been corrected. 
4 ENVIRONMENTAL MANAGEMENT SYSTEM

4.1 Description 

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

policy:

1 NREL ENVIRONMENTAL POLICY STATEMENT 

NREL exemplifies sustainability by maximizing efficient use of resources, minimizing waste and 

pollution, and serving as a positive force in economic, environmental, and community

responsibility. To this end, NREL is committed to:

Economic Viability. Managing laboratory fiscal resources efficiently to meet applicable

regulations and effectively accomplishing the Laboratory's mission, taking sustainability into

consideration.

Environmental Stewardship. . . . NREL is committed to sound environmental management that

serves as an example to others and supports the Laboratory’s mission to protect natural resources

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

technologies. . . . To this end, NREL is committed to:

• Pollution Prevention. . . . Incorporating pollution prevention practices in research and support activities. 

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

(EMS).

• Campus. . . . Managing the impact on the environment caused by the placement and general design of NREL structures;

maintaining, protecting, and restoring natural and landscaped environments to sustain natural and native ecological systems,

both on and adjacent to NREL campuses.

• Water. . . . Reducing water consumption and managing water discharges from the site. 

• Electricity/Natural Gas. . . . Reducing energy use in building designs and operations, within available funds; using cost

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

sources. 

• Transportation. . . . Reducing the impact of local NREL travel on the environment; reducing the use of fossil-based 

gasoline/diesel fuel for NREL onsite and local operations through the use of alternative fuel vehicles or hybrids; and

increasing the use of video and teleconferencing to reduce the environmental impacts of air travel.

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

for laboratory operations; increasing the purchase and use of environmentally sensitive products and products with recycled

content. 

• Environmental Management. . . . Providing an environment that promotes efficiency, effectiveness, and sustainability, and 

encourages the creativity and personal motivation required for excellence in scientific, engineering, technology development, 

and support functions.

• Education/Communication. . . . Informing and providing outreach to workers about sustainability activities, including a 

method for interaction and feedback; educating workers about participating and contributing to sustainable activities. . . ; 

informing workers and the public about NREL’s environmental performance, including a method for interaction and 

feedback. 

• Compliance with Requirements. . . . Complying with applicable federal, state, and other environmental requirements and

exceeding those requirements, when feasible, by implementing environmental best management practices.

Public Responsibility. Working with local stakeholders to identify and implement collaborative

projects to improve sustainability of the local community; educating others about sustainability

through a variety of outreach mechanisms. 

NREL Environmental Performance Report- 2006

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NREL Environmental Performance Report- 2006 

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NREL’s EMS and ISM System

NREL’s Environmental Management System (EMS) implements NREL’s environmental 

policy, and is a framework of policies and procedures that are integrated with NREL’s 

normal management processes, combined with the environmentally sound daily work 

practices of Environment, Safety, Health & Quality (ESH&Q) Office staff and personnel 

throughout the laboratory. Environmental protection must involve everyone at the lab in 

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

and state laws and regulations, and DOE requirements. 

As a DOE-owned facility, NREL is required by DOE Order 450.1 to implement its EMS 

as part of an Integrated Safety Management (ISM) System. The Environmental 

Management Policy (6-2) and 19 supporting laboratory-level environmental programs 

that define the NREL EMS have been coordinated and linked with the ISM Policy (2-1), 

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

NREL Policy (2-7), and approximately 40 supporting lab-level safety and health 

programs. The EMS is further integrated with ISM via task specific procedures that flow 

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

Notable 2006 Activities 

In 2006, NREL continued progressing toward our NEPT/CELP environmental 

performance commitments. In early 2004, NREL was accepted into the EPA National 

Environmental Performance Track (NEPT) Program and the Colorado Environmental 

Leadership Program (CELP). The NEPT program is a national voluntary partnership 

between the EPA and participating private and public U.S. facilities that recognizes 

environmental leadership and performance; the CELP program is a similar state-level 

voluntary partnership. As a component of these programs, each year NREL sets voluntary 

performance goals in an effort to further enhance environmental performance at the 

laboratory. NREL was one of the first two DOE national laboratories to be accepted into 

NEPT. NREL decided to forego additional participation in the NEPT program beyond 

CY2006, and will reapply for continued participation and recognition in the State of 

Colorado’s CELP. CY2006 progress is discussed in detail in Section 4.2. 

In August 2007, NREL voluntarily invited a third-party auditor to assess the EMS. The 

assessment served as a gap analysis between the existing NREL EMS and the revised 

ISO 14001 – 2004 standard. Discussion of the report will occur in the CY2007 

Environmental Performance Report. 

Public Outreach 

The National Renewable Energy Laboratory (NREL) hosted several public meetings to 

report on and discuss environmental performance and other issues. In 2006, the public 

was invited to a Smart Energy Living Expo at the NREL Visitors Center on June 10. 

More than 750 people attended and were provided with information on renewable energy 

and energy efficient technologies for their homes. Fifteen vendors showcased a variety of 

energy products. The DOE-sponsored “Energy Hog” conducted shows for kids and 

parents along with other activities for families. 
NREL Environmental Performance Report- 2006 

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NREL and DOE’s Golden Field Office (GO) hosted a Community Meeting on Nov. 14, 

inviting community members to learn about the Laboratory’s 2007 outlook and site 

development plans. More than 90 community members attended and toured NREL’s 

newest building, the Science and Technology Facility (S&TF). Copies of presentations 

made by NREL Deputy Director Bill Glover and GO's Assistant Manager for Laboratory 

Operations Jeff Baker were made available online.

A February 2006 community newsletter announced construction on the S&TF had moved 

inside and construction was 85 percent completed. The May 2006 community newsletter 

announced construction was almost complete and a ribbon cutting ceremony was planned 

for July. 

A special Web site was maintained by the Public Relations Office, providing the 

community with periodic updates on S&TF construction. A phone number was also set 

up to provide construction updates and to allow members of the community to relay any 

concerns they might have about the project. 

A series of "power lunches" open to the public are held at the Visitors Center. In 2006, 

topics included advanced vehicle technologies, residential solar, and climate change. In 

all, approximately 15,488 people passed through NREL's Visitors Center. All are 

required to sign in, and space is provided on the sign-in sheet for comments. Concerns 

about the lab’s environmental performance are relayed to appropriate staff. 

In addition, the lab's public website, www.nrel.gov, features a "Sustainable NREL" link, 

where the public can find copies of NREL's Sustainability Reports. 

Visits to NREL by elected officials are common. In past years, the laboratory has hosted 

visits by President George W. Bush, congressional staffers, mayors, and many other local 

government leaders. NREL hosted two breakfasts for Jefferson County government 

leaders in FY06, and no environmental performance issues were raised. 

4.2 Performance Indicators and Progress 

2006 Environmental Objectives and Progress Toward Goals 

Each fiscal year, in collaboration with the DOE Golden Field Office (DOE-GO), NREL 

develops environmental objectives for the upcoming year as part of the lab’s One-Year 

Plan. For fiscal year 2006, the ambitious objectives were the following: 

• Complete self-certification of EMS - ISM integration in conjunction with the 

Golden Field Office to meet the December 30, 2005 deadline as required by DOE 

Order 450.1, Environmental Protection Program. 

• Conduct independent assessment of ISM implementation and develop gap 

analysis. 

• Conduct evaluation of the lab-wide chemical inventory management system and 

identify improvements. 

• Conduct validation of lab-wide chemical inventory. 
NREL Environmental Performance Report- 2006 

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• Evaluate and close-out open action items from previous Golden Office 

Surveillances. 

• Participate in GO Surveillance Program. 

• Demonstrate progress towards achieving NEPT goals. 

• Support GO in conducting the environmental reviews associated with site buildout activities. 

NREL has successfully completed each of the eight objectives listed above. Please see 

Sections 4.3, 5.0, and specifically 5.8 and 5.9 for additional information on assessments, 

environmental programs, and specifically chemical inventory, pollution prevention, and 

sustainability. The four NEPT goals for completion in CY2006 are stated below, with 

supporting progress noted in this Environmental Performance Report in Section 5.9 on 

Pollution Prevention and Sustainability. 

Sustainable NREL and EMS staff worked together to compile pollution prevention data 

on waste generation, recycling, and green purchasing. In 2006, NREL received the 

following awards: 

• Honorable Mention for the White House Closing the Circle Pollution Prevention 

Award. 

• Federal Energy Saver Showcase Award for the S&TF. 

• Jefferson County Commissioners’ Award for Design Excellence – S&TF. 

• U.S. EPA Climate Protection Award. 

National Environmental Performance Track Commitments 

NREL’s performance commitments under the NEPT program are 3-year commitments, to 

be in place throughout NREL’s 3-year participation in the program, from 2004 through 

the end of 2006. NREL’s commitments are as follows. 

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

year. 

NREL has met the Performance Track commitment of a 10% reduction in CO2 

emissions. The assumptions used for GHG emissions data are: 1) data reflects both 

NREL/DOE-owned and leased facilities, as reflected in NREL’s data submitted to the 

EPA Climate Leaders Program, 2) electric, natural gas, commuter, air travel, fleet, solid 

waste, and water emissions were considered, 3) commitment to a 10% reduction in CO2 

emissions from the baseline, 4) data includes renewable energy credit (REC) offsets, and 

5) the addition of the 71,000 sq ft S&TF required normalizing by square footage. In 

FY06, REC purchases offset the entire laboratory CO2 footprint. 

Commitment #2: Reduce water use by 20% from the 2002 baseline year. 

NREL’s original 2006 performance commitment was to reduce water use by 5%, in order 

to achieve a goal of 10,181,625 gallons. NREL extended its commitment to reduce water 

use further because NREL’s water use was so low in FY2004. As it turned out, NREL’s 

2004 water used appeared to be low due to inaccurate billing of water consumption at the 

SERF from the water utility company. The SERF is approximately 45% of the overall 
water utility bill, and the FY04 SERF water values were determined through a

combination of existing water sub-metes data and estimating the annual water

consumptions at the evaporative coolers, irrigation system, and plumbing fixtures at the 

facility. FY05 numbers represent a more accurate view of yearly water consumption at

the laboratory. In FY06, there was an 18% increase in water usage compared to the FY00 

baseline water usage. As a result, NREL did not meet either the original NEPT goal or 

the extended goal. The increase in water usage is due to the newly constructed S&TF

coming on line in April 2006. The majority of the increase can be attributed to the S&TF

cooling tower, evaporative coolers, and the irrigation system required to stabilize the site

in accordance with the EPA storm water general permit. Water data is for NREL/DOE 

owned sites only, so a different normalizing factor is used compared to commitments 

where data includes both leased and owned facilities. 

Commitment #3: Reduce emissions of carbon monoxide. 

Carbon monoxide data for 2006 remained unchanged since the composition of NREL’s 

fleet remained the same as in previous years. NREL continues to work with GSA to 

acquire more AFVs, but has so far been unable to obtain additional vehicles. 

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

While NREL did succeed in reducing our annual energy use in 2006 and we were very

close to meeting our performance commitment, we ended up just short of the 3%

reduction. The laboratory continues to actively investigate opportunities to reduce energy

use and improve energy efficiency. The major sources of energy use are building

operations and process loads associated with laboratory testing facilities. All major

laboratory buildings are metered for electric and natural gas use. In addition, major loads 

are separately metered for electric use. Also, all future construction at NREL will strive

for LEED Gold level. 

Table 4.1. Greenhouse Gas Emissions

Greenhouse Gas Emissions (CO2 equivalent)

Baseline Year 1 Year 2 Year 3 

Performance 

Commitment 

Calendar Year 2002 2004 2005 2006 2006

20,990 ٭0 ٭8,346 23,150 23,322 Year/Tons

٭Note: The goal in 2005 and 2006 was met through the purchase of Renewable Energy Certificates (RECs).

Table 4.2. Water Use 

Water Use (Gallons per Year)٭

Baseline Year 1 Year 2 Year 3 

Performance 

Commitment 

Calendar Year 2002 2004 2005 2006 2006 

Gallons/Year 10,717,500 7,160,000 10,200,000 14,951,000 8,574,000

٭Note: Meter information was incorrectly supplied by the water provider. Also note that 2006 data is higher due to onetime watering requirements of re-vegetation at the new STF site as well as other shakedown/ commissioning activities. 

NREL Environmental Performance Report- 2006

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NREL Environmental Performance Report- 2006 

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Table 4.3. Total Energy Use 

Total Energy Use (mmBTU) 

Baseline Year 1 Year 2 Year 3 

Performance 

Commitment 

Calendar Year 2002 2004 2005 2006 2006 

Actual Energy 

 101,172 ٭101,808 105,356 99,928 104,303 Use

RECs Purchased 6,760 6,760 51,488 +51,000 

Net Energy Use 97,543 93,168 53,868 <51,000 

٭ Note: The normalizing factor based on square footage changed in this year from 1.0 to 1.11 

2007 Objectives 

Environmental objectives developed by NREL in collaboration with DOE-GO to meet 

the goal of further enhancing ESH&Q as a core value of the laboratory for fiscal year 

2007 are: 

• Effective leadership and prevention 

• Effective response 

Progress toward the 2007 goals will be reported in the NREL 2007 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. Assessments and management reviews also provide for continuous 

improvement of the EMS. 

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

the EMS at NREL: EMS assessments, periodic compliance assessments, and third-party 

assessments. 

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

periodic basis. The scope of the assessments includes both the management of significant 

environmental aspects (areas where NREL activities have the potential for environmental 

effect, either positive or negative) 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 standards. 

Periodic compliance assessments are conducted of individual environmental programs to 

verify that the program, as written, meets all applicable legislative and regulatory 
NREL Environmental Performance Report- 2006 

 Page 34

requirements and that the program is implemented as intended (see Section 5.0 for 

examples). Improvements are developed and implemented as necessary, based on the 

results of each assessment. 

In addition to regular compliance assessments of individual NREL environmental 

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

and updates of the set of policies, lab-level programs, and task specific procedures, 

including EMS policies and programs. NREL reviews its ESH&Q policies as needed, but 

at least every five 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. 

2006 Assessment Activities 

In an effort to continuously improve the EMS integration with the ISM System in 2006, 

NREL conducted an independent assessment of the ISM System, including gap analysis. 

The resulting outcome has been that environmental processes are adequately integrated 

into the ISMS. Additionally, NREL continued implementation of an EMS database tool, 

allowing for electronic tracking of due dates for permits and other milestones, as well as 

proving a mechanism to consolidate elements of NREL’s environmental management 

system. 

Please recall that in December 2005, DOE conducted a follow-up surveillance to the 

2004 self-assessment. This surveillance was on action plan progress and EMS integration 

with NREL’s ISMS. There were no DOE findings as a result of the surveillance and no 

corrective actions were required. DOE found that NREL’s EMS is integrated sufficiently 

with its ISMS, and certified the EMS as such for purposes of compliance with DOE 

Order 450.1, which required integration to be complete by 12-31-05. 

Please also recall that in August 2005, representatives from the EPA Region 8 and the 

Colorado Department of Public Health and Environment (CDPHE) visited NREL to 

review the laboratory’s commitment to the NEPT and CELP programs. During the site 

visit, the EPA and CDPHE were impressed with NREL’s commitment to going beyond 

compliance in the areas of environmental performance and sustainability. The EPA found 

NREL’s sustainability practices to demonstrate leadership, its public outreach program to 

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

documented. The EPA also provided NREL with recommendations for improvement. 

As anticipated, implementation of the continuous improvements planned as a result of the 

2004 self-assessment is a multi-year effort that continued in 2006. Progress has been 

made in implementing the improvements, as discussed earlier in this section. 
NREL Environmental Performance Report- 2006 

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In August 2007, NREL voluntarily invited a third-party auditor to assess the EMS. The 

assessment was conducted as a gap analysis between the existing NREL EMS and the 

revised ISO 14001 – 2004 standard. Discussion of the report will occur in the CY2007 

Environmental Performance Report. 

4.4 Sustainability and the Environmental Management System 

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

world. Sustainability is defined as meeting the needs of the present without 

compromising the ability of future generations to meet their needs, and involves the 

simultaneous and balanced pursuit of economic viability, environmental stewardship, and 

public responsibility. 

 

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

in NREL operations. It is an interdisciplinary initiative involving staff from numerous 

NREL centers and offices with the goals of maximizing efficient use of resources; 

minimizing waste and pollution; and serving as a positive force in economic, 

environmental, and public responsibility. Elements of the environmental stewardship 

component of Sustainable NREL include: 

• Campus and Transportation 

• Water, Electricity, and Natural Gas 

• Reduce, Reuse, Recycle, and Rebuy 

• Education and Communications Environmental Management 

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

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

sensitive new buildings, reducing water consumption; decreasing greenhouse gas 

emissions, minimizing the impact of local NREL travel on the environment, using less 

fossil-based fuel for local operations, incorporating renewable energy technologies into 

its on-site STM and NWTC operations, and creating less waste by reducing, reusing, and 

recycling materials for laboratory operations. 

The Environmental Management System (EMS) supports Sustainable NREL’s goals. The 

EMS focuses on protecting the natural and cultural resources on and around NREL sites 

by: 

• Reviewing NREL’s potential for environmental impacts through emissions, 

discharges, waste generation, and land use. 

• Conducting required permitting activities. 

• Managing site natural resources so as to protect and preserve them in their natural 

character. 

• Managing site cultural resources so as to document resources of significance and 

minimize disturbance whenever possible. 
NREL Environmental Performance Report- 2006 

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• Recommending and coordinating measures to minimize any potential impacts 

NREL’s activities have on the environment. 

There is synergism between Sustainable NREL and environmental protection activities of 

the ESH&Q Office in that both address different components of NREL’s environmental 

footprint. Together, Sustainable NREL and the Environmental Management System, as 

implemented by the ESH&Q Office, form a single environmental program that is 

integrated with NREL’s other management processes. 

More detail is provided in this report about the following sustainability-related efforts at 

NREL: 

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

• Pollution Prevention activities are discussed in Section 3.9, Pollution Prevention. 

5 ENVIRONMENTAL PROGRAMS 

The overarching objective of NREL’s EMS and its component programs is responsible 

stewardship of the environment on its DOE-owned sites, leased properties, and to the extent 

practicable, on subcontractor and partner sites. NREL strives to protect the natural environment 

by minimizing or eliminating any adverse environmental impacts resulting from NREL 

activities. The laboratory’s EMS is integrated with other NREL management systems and applies 

to all research and operations activities. The EMS includes written environmental protection 

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

management levels. 

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

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

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

section is composed of three areas of discussion: a summary of the environmental management 

of the resource, a discussion of any relevant permitting, and a summary of significant activities 

that have occurred throughout the year. 

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

These permits are discussed in the following relevant sections. 

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
NREL Environmental Performance Report- 2006 

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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 noncriteria 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 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 CDPHE. 

EPA-certified technicians must service this equipment, and NREL has certified 

technicians on staff that performs this type of service. 

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

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

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

located at the Solar Energy Research Facility (SERF) on the STM Site, and one at 

the DWOP. 

Halon-based fire suppression systems previously used at NREL were eliminated 

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

“banking.” 

Street Sanding

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

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

complies with this requirement and files an annual sanding report with CDPHE. 

During the period October 2005 to May 2006, NREL used 14 tons of sand during 

7 sanding episodes. NREL maintains 12.3 lane-miles of roads. During the period 

October 2006 to May 2007, NREL used 20 tons of sand during 12 sanding 

episodes, while continuing to maintain 12.3 lane-miles of road. 
NREL Environmental Performance Report- 2006 

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5.1.2 Permitting

Most potential sources of air emissions from NREL laboratory and facility 

operations in 2006 were small scale and did not require permitting. Permitting 

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

pollutant. Projected emissions for these sources were either below thresholds for 

air permitting or the state reviewed the operation and determined emissions to be 

negligible in terms of impacts to the environment. 

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

been issued to NREL by CDPHE. NREL has held such permits for a number of 

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

held permits on which the time period of applicability had expired. One permit 

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

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

FTLB on the STM Site. The permit was issued in 2002. NREL has operated the 

thermal oxidizer emission control device for the experimental Thermochemical 

Process Demonstration Unit (TCPDU) located at the FTLB since the late 1980’s, 

under an exemption.. An Air Pollution Emission Notice (APEN) update was filed 

with the Colorado Air Pollution Control Division in 2005. 

5.1.3 2006 Activities

Two Air Pollution Emission Notices (APENs) were filed in early 2005, one for 

the STM and one for the NWTC, for overlot grading and associated construction 

activities to address fugitive particulate emissions. These APENs will expire in 

2010. Significant activities not associated with routine maintenance or small 

construction projects identified in the APEN submission were evaluated on a 

case-by-case basis in 2006. It was not necessary to submit an updated APEN. 

As required by CDPHE every five years, an APEN update was filed in May 2005 

to update the information provided in the original APEN for TCPDU activities. 

There have been no significant changes to the operating parameters or air 

emissions of the TCPDU in the last six years, including 2006. 

5.2 Drinking Water 

5.2.1 Program Management

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

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

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

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

ReFUEL Facilities is also provided by a public water supply. NREL supplies 
NREL Environmental Performance Report- 2006 

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

supply through a subcontracted water hauler. NREL stores the water on site in a 

buried 15,000-gallon storage tank and an above ground 2,000-gallon tank. The 

water hauler fills the 15,000-gallon tank, and water is pumped on demand to the 

2,000-gallon tank where it is distributed to the Industrial User Facility (IUF), 

Building 251, and the hydrogen test pad on the west end of the site. 

Disinfection boosting is performed at the NWTC using a chlorine disinfection 

system. 

Monitoring for bacteria (total coliforms), chlorine levels, haloacetic acids and 

trihalomethanes (disinfection by-products), lead and copper is performed at the 

NWTC according to the requirements of CDPHE. NREL qualifies for reduced 

lead and copper monitoring. Current state requirements for NWTC system are as 

follows: 

• Bacteria – monthly 

• Lead and copper – triennially 

• Chlorine levels – weekly, or more frequently as needed 

• Haloacetic acids (HAA5) – quarterly 

• Trihalomethanes (TTHM) –quarterly 

Samples are collected from three locations at the NWTC: Building 251, the IUF, 

and the hydrogen test pad (added in 2006).. No coliforms were detected in any of 

the samples taken during2006. Monthly reporting is provided to the state for the 

bacterial analyses. 

Monitoring for lead and copper was completed as scheduled during the summer of 

2002. All samples collected were well below the action levels. Sampling 

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

required again until the summer of 2005; however, the state requested NREL 

collect lead and copper samples in 2004 and 2005. All lead and copper levels 

were below action levels. No monitoring for lead and copper was required by 

CDPHE in 2006. 

Chlorine residual monitoring of the NWTC drinking water system began with the 

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

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

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

monitoring locations. The state requires that chlorine residual monitoring occur 

when collecting monthly bacterial samples. 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. Results are provided to the state on 

a quarterly basis. Chlorine was present at appropriate levels in all samples 

collected in 2006. The running annual average of the maximum residual 

disinfectant level (MRDL) for CY2006 was 0.38 ppm. 
NREL Environmental Performance Report- 2006 

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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/ Notifications

NREL has a registered Public Water Supply Identification Number (PWSID) 

issued by CDPHE for the drinking water it provides at the NWTC. This 

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

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

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

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

5.2.3 2006 Activities

In 2006, 176,095 gallons of potable water were delivered to the NWTC, an 

average daily consumption rate of 482 gallons per day. NREL conducted all 

required monitoring for 2006 and all reported results met drinking water 

standards. Bacteria were absent in all samples collected, and disinfectant was 

detected at all locations tested. The annual running average for chlorine residual 

was 0.38 ppm. 

In October 2006, the Wind to Hydrogen project became operational at the NWTC. 

The project uses wind generated electricity to hydrolyze water, and to store the 

hydrogen produced. Water for this project is supplied by a newly constructed 

extension of the water supply system at the NWTC. Because the hydrogen test 

pad is now the furthest point in the system from the distribution tank, it was added 

as a monitoring point. The operating contractor began collecting samples for 

bacteria and chlorine at this location in October. 

Plans to install an automated disinfection system continued in 2006. This system 

is intended to overcome problems of excess chlorine added to the system at 

week’s end in order to maintain residual levels over the weekends. Reducing 

residual chlorine levels will also reduce the potential for producing disinfectant 

byproducts, trihalomethanes, and haloacetic acids. Installation of the controller 

and probe is scheduled to occur in 2007. 

In October 2005, NREL initiated a review of the drinking water system operations 

and testing. These activities are subcontracted to qualified licensed operators. In 

August 2006, NREL replaced the operating contractor. Colorado regulations 

require that public water supply systems identify an Operator in Responsible 

Charge. Notification was provided to CDPHE identifying the new Operator in 

Responsible Charge along with his Class A certification. 
NREL Environmental Performance Report- 2006 

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On October 12, 2006, CDPHE notified NREL that the annual result for total 

trihalomethanes (TTHM) exceeded the applicable maximum contaminant level 

(MCL), and required an increase in monitoring from an annual sample to 

quarterly samples. The result for the sample collected in August 2006 was 0.082 

mg/L; the MCL is 0.080 mg/L. CDPHE wrote that “NREL must increase 

monitoring from yearly to quarterly monitoring beginning in the fourth quarter of 

2006 for both disinfection byproducts (TTHM and HAA5).” While the 

Haloacetic Acids (HAA5) result had been within the applicable MCL, the 

CDPHE program required increased monitoring for both sets of disinfection 

byproducts. NREL immediately directed the operator to collect quarterly samples 

for TTHMs and HAA5s. The first sample was collected in November 2006, and 

the results were below the applicable MCLs. Collection of the quarterly samples 

will continue in 2007. 

5.3 Groundwater 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 groundwater resource, NREL is careful to 

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

groundwater quality. If there are any materials used that could pose a potential 

ground water risk, the laboratory typically insists that safeguards to protect 

groundwater be established. Safeguards include, but are not limited to, 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. 

In 1990 groundwater characterization began on the STM site 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 groundwater quality. Quarterly 

sampling was performed for five calendar quarters, followed by annual sampling 

for 3 years. There was no evidence of contamination found. In addition, routine 

follow-up sampling was done in 1997. Three of the initial eight wells were closed 

(in accordance with state requirements) due to construction activities in 1993, and 

a fourth was found to be inaccessible during the 1997 sampling, presumably also 

due to construction activity in the area. Therefore, follow-up samples were only 

collected from four of the original monitoring wells: three upgradient wells and 

one downgradient of NREL development. No evidence of contamination was 

found in the 1997 sampling. 
NREL Environmental Performance Report- 2006 

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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 groundwater monitoring study in 1988 adjacent 

to the NREL-leased buildings. Two monitoring wells were drilled. There were no 

detections of significant levels of contaminants. 

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

supply well that provided water to Building 251 when DOE’s Rocky Flats Office 

operated the site. In 1993, NREL collected one round of water samples from this 

well and the associated water distribution and treatment system for the purpose of 

determining the most feasible alternative for water supply to the site. Based on the 

sampling results, it was determined that the maintenance and repairs required to 

make the existing well and treatment system effective were extensive, and there 

was an indication of the potential for trace organic compounds in the water. 

Therefore, when DOE's Golden Field Office assumed landlord responsibility for 

the site in 1993, the connection between the building and the well was severed. 

The water supply well was plugged and abandoned in accordance with state 

regulations by an NREL subcontractor in 1996. Potable water is currently 

transported to the site, as described in section 5.2. NREL has not done any other 

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

future activities pose a risk to the groundwater quality.

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

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

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

of routine deliveries and pick-up of inventory stored in the warehouse. No 

groundwater studies have been performed by NREL in proximity to the ReFUEL 

facility, as it is located in a heavily industrialized area and NREL has not had any 

releases to the environment that would pose a risk to groundwater. 

There is currently no ongoing routine groundwater monitoring program on any 

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

that currently or historically pose 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, or 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. 
NREL Environmental Performance Report- 2006 

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5.3.2 Permitting

All groundwater 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 2006 Activities

In 2006, the three groundwater monitoring wells that were installed due to the 

PDU emergency generator aboveground storage tank leak were closed in 

accordance with state requirements.

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 

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

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

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

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

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

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

treatment of wastewater. 

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

system, and NREL staff is trained in this policy. In addition, NREL sites have 

design criteria for waste drains in lab areas to minimize the possibility of a 

hazardous material discharge. These criteria include measures such as secondary 

containment for any chemicals used near sinks in laboratory exhaust hoods, no 

floor drains in laboratory areas unless a specific need can be shown, and caps for 

any floor drains that are installed in lab areas. New research and operations 

activities as well as ongoing activities that undergo significant modifications are 

reviewed for their potential effect on wastewater character through NREL’s risk 

assessment process. 

5.4.2 Permitting

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

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

ReFUEL, or JSF, so no National Pollutant Discharge Elimination System 
NREL Environmental Performance Report- 2006 

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(NPDES) permitting is necessary. NREL maintains three individual sewage 

disposal systems, two at the NWTC and one at the STM site. The remainder of 

NREL facility wastewater is discharged to Metro through the sanitary sewer 

system. NREL facilities are currently classified by Metro as non-industrial water 

users at these sites. As non-industrial users, NREL sites do not need a permit from 

Metro for sewer discharge, and monitoring for pollutants in wastewater is not 

required. 

NREL maintains septic permits from Jefferson County (an authority delegated to 

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

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

5.4.3 2006 Activities

In 2006, there were no new wastewater discharge activities . 

5.5 Surface Water Protection (Storm Water and Erosion Control) 

5.5.1 Program Management

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

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

Water Pollution Prevention for Construction Activities at the NWTC (6-2.15 and 

6-2.16, respectively) 

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 weedinfested areas were detected in the water samples. 

Outdoor research projects are reviewed during the planning stages, through 

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

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

design for each project. Such control measures could include secondary 

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

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

adverse weather conditions. 

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

construction activities on both the STM and NWTC (6-2.15 and 6-2.16, 
NREL Environmental Performance Report- 2006 

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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 

allow for prompt revegetation of disturbed areas. Provisions of the SPPPs are 

implemented through coordination with NREL’s construction subcontractors. 

5.5.2 Permitting

NPDES notification for storm water discharges on federal facilities in Colorado is 

under the jurisdiction of the Environmental Protection Agency (EPA). In 2006, 

NREL was covered under the EPA’s general permit for stormwater discharge 

associated with construction activities on the STM S&TF project. Both Midwest 

Research Institute, as operator, and DOE, as site owner, have filed Notices of 

Intent for appropriate construction activities on the STM and NWTC Sites. No 

permits are required for NREL’s routine operations. 

5.5.3 2006 Activities

In 2006, there were no new surface water protection activities.

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 of 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 ESH&Q Office for off-site disposal. 

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

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

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

potential hazard, are collected and disposed of as non-hazardous materials at an 

RCRA-permitted disposal facility. 

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

consists of personal protective equipment, disposable lab ware, scintillation fluids, 
NREL Environmental Performance Report- 2006 

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and water-based liquids. Radioactive waste is shipped off-site for disposal on an 

as-needed basis. 

5.6.2 Permitting

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

of hazardous materials. Each of the five sites has an RCRA waste generator 

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

location is classified as a "small quantity generator," generating less than 1000 kg 

of waste per month. The other four sites – the Joyce Street Facility, the National 

Wind Technology Center, the Denver West Office Park and the ReFUEL Facility 

– are classified as "conditionally exempt small quantity generators," generating 

less than 100 kg of waste per month. 

5.6.3 2006 Activities

In CY2006, from all five sites combined, NREL shipped 24,830 pounds (11,286 

kg) of hazardous waste, 8,093 pounds (3,679 kg) of non-RCRA regulated waste, 

and 8,095 pounds (3,680 kg) of universal waste for disposal and recycling. 

Universal waste includes batteries, fluorescent light bulbs, and electronic 

equipment. 

In 2006, no radioactive waste was generated or shipped for off-site disposal. 

Information regarding the types and quantities of radioactive materials used at 

NREL facilities is detailed in Section 5.15. 

5.7 Storage Tanks (Underground and Aboveground) 

5.7.1 Program Management

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

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

Countermeasures (6-2.10). NREL does not have any underground tanks with 

hazardous materials. 

NREL facilities store diesel for emergency generator and research use in 

aboveground storage tanks. NREL's tank management program focuses on proper 

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

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

the regulations require in many areas. 

Several important safeguards have been incorporated into NREL’s tank 

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

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

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

leaking, overfill and spill protection; and procedural safeguards, such as written 
NREL Environmental Performance Report- 2006 

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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, NWTC, and ReFUEL sites, 

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 off-site impacts related to tank activities. 

5.7.2 Permitting

Aboveground tanks larger than 660 gallons require registration with the State of 

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

the registration threshold, the SERF emergency generator diesel storage tank and 

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

Fuels User Facility (AFUF). Both are located on the STM site. 

5.7.3 2006 Activities

A state inspection of NREL’s regulated ASTs was conducted in 2006. A field 

Violation Report was issued for insufficient tank grounding on one tank. The 

issue was satisfactorily resolved within one week. No spills or releases from 

NREL’s ASTs occurred during 2006. 

5.8 Hazardous Materials Management 

5.8.1 Program Management

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

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

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

laboratory sites. Therefore, many sections of the Comprehensive Environmental 

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

facilities. 

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

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

Emergency Planning and Community Right-To-Know Act (EPCRA). Section 302 

of these regulations requires a facility to notify the State Emergency Response 

Commission (SERC) that it is subject to emergency planning and notification 

requirements if any chemicals in the facility's inventory are stored in quantities 

greater than prescribed Threshold Planning Quantities (TPQs). NREL facilities 

first became subject to planning and notification requirements in 1988. 
NREL Environmental Performance Report- 2006 

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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. 

When requested, NREL provides additional emergency response and reporting 

information to the Jefferson County LEPC, the SERC, West Metro Fire Protection 

District, and Rocky Mountain Fire Protection District. 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 the 

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. To date, NREL has 

not met the thresholds that trigger applicability of Section 112r. 

NREL has a laboratory-wide Chemical Management System (CMS) that serves as 

a centralized chemical inventory as well as a tool for managing and reporting on 

chemicals used at the laboratory. Using an electronic bar-coding system, the CMS 

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

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

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

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

• Improving research efficiency and minimizing hazardous waste generation 

by allowing staff to determine if needed chemicals are already available 

on site prior to making chemical purchases. 
NREL Environmental Performance Report- 2006 

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• Providing quick access to chemical inventories and hazard information 

during emergency responses. 

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

districts, EPC, EPA, DOE). 

 

To maintain the CMS database, a physical inventory of each lab and work area in 

which chemicals are used or stored is conducted periodically. Such an inventory 

was conducted in 2006. Seven contract employees worked from June through 

September updating the CMS with chemical hazard information and conducting a 

wall-to-wall inventory of laboratory chemicals. 

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: the Joyce Street Facility, Building 251 

at the NWTC, Building 16, the STM Site, the AFUF (only older areas of the 

building), the FTLB, and the SRRL. No asbestos was found at the Joyce Street 

Facility and the AFUF. The other facilities have limited amounts of asbestoscontaining material in areas such as floor tile, lab countertops, caulking and 

sealants, and roofing materials. Asbestos-containing materials are left undisturbed 

whenever possible. If renovation is planned that will disturb asbestos-containing 

material, then certified asbestos removal contractors are used and strict asbestos 

removal procedures are followed. An Asbestos Management Program is in effect 

for all NREL facilities. 

5.8.2 Permitting

NREL obtains annual Hazardous Material Permits from West Metro Fire 

Protection District for the STM and DWOP sites. The permits are required by the 

West Metro and are issued by building. NREL obtains permits for a total of six 

buildings where hazardous materials are stored and/or used. Prior to issuing the 

permits, a representative from West Metro conducts a walk-through inspection of 

the entire South Table Mountain Site and DWOP. 

5.8.3 2006 Activities

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

facilities in the summer of 2006. Annual Hazardous Materials Permits for the six 

buildings were issued following the inspection. 

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

West Metro when applying for Hazardous Materials Permits in 2006. The CMS 

was also used to post individual laboratory chemical inventories on the ESH&Q 

website, which were updated monthly. 

In 2006, NREL had three chemicals on-site in quantities that exceeded the TPQs: 

sulfuric acid, hydrofluoric acid, and hydrogen selenide. The proper MSDSs and 
NREL Environmental Performance Report- 2006 

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Tier II forms were submitted to state and local emergency response organizations, 

and the local fire department. 

In 2006, NREL facilities had no releases exceeding the RQ of any reportable 

material under EPCRA. 

In August of 2006, two representatives of the Colorado Department of Public 

Health and Environment (CDPHE) conducted a RCRA inspection of the South 

Table Mountain facilities. In addition to inspecting waste generating areas in labs, 

the waste handling facility, and the newly opened Science and Technology 

Facility, the inspectors also reviewed employee training records and the ESH&Q 

hazardous waste records. The items noted by the CDPHE inspectors were minor 

in nature and no enforcement actions were taken as a result of the visit. 

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

process any materials, and during 2006, the laboratory did not use any materials 

on the Section 313 list in quantities exceeding the 4536-kg (10,000-lb) TPQ. 

5.9 Pollution Prevention & Sustainability 

5.9.1 Waste Minimization, Recycling, and Green Purchasing 

(Purchasing Materials with Recovered Content) 

As a facility that focuses on the research, development, and application of 

renewable energy and energy efficiency technologies, NREL is committed to 

responsible environmental stewardship. A significant part of this effort is 

pollution prevention. NREL's Waste Management and Minimization Program 

outlines pollution prevention principles that are consistent with the EPA's 

hierarchy of preventing or reducing pollution at the source; recycling or reusing 

waste materials that cannot be prevented; and environmentally safe treatment and 

disposal of waste that cannot be prevented, recycled, or reused. 

The current pollution prevention program includes training on waste handling, 

waste minimization, and methods to eliminate releases to air, soil, or wastewater. 

In addition, the ESH&Q Office integrates pollution prevention awareness into 

NREL activities in a number of ways. The proposed use of chemicals in projects 

are evaluated prior to use during project planning reviews, Safe Operating 

Procedure reviews, and Readiness Verifications conducted according to NREL’s 

Hazard Identification and Control Program (ESH 6-6.2). During these reviews, 

NREL staff evaluates opportunities for chemical substitution as well as methods 

of reducing the volume of chemicals used and waste streams generated. 

The use of bankcards for chemical purchases has been another means of reducing 

the volume of chemicals purchased, stored and disposed at NREL. Under the 

bankcard chemical purchasing system, a small group of chemical users are given 

privileges to order chemicals directly from the vendor using their bankcards. 

Because bankcard purchasing expedites chemical purchases over conventional 
NREL Environmental Performance Report- 2006 

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purchasing processes at NREL, users order only the chemicals required for use in 

the immediate future, knowing that additional quantities can be quickly acquired 

if needed. The ESH&Q Office reviews all chemical purchases made using the 

bankcards. 

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

prevention program. A crosscutting committee composed of staff from around the 

laboratory, and led by Sustainable NREL, manages NREL’s recycling program. 

As recommended by EPA’s comprehensive recycling guidelines, items currently 

recycled or reused at NREL include the following: 

• Computer monitors • Fluorescent bulbs 

• Batteries • Styrofoam peanuts 

• 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 • Tyvek envelopes 

Fourteen central recycling locations are available for most recycling needs 

throughout NREL facilities. NREL also offers a chemical redistribution program 

where chemicals in original containers are made available to staff at NREL and 

other DOE facilities to be reissued for research activities at no cost. The NREL 

CMS is used for redistributing chemicals to new users. In addition, NREL 

implemented and maintains a materials reuse center in Building 16 in the Denver 

West facilities. This center encourages NREL employees to select reusable office 

supplies prior to placing purchase orders. 

NREL has consistently decreased solid waste disposal since FY2003. 

FY03 FY04 FY05 FY06 

Solid Waste 427,880 406,820 365,934 305,696 

Recycled Material 236,128 180,636 164,488 214,000 

Data for some of the materials recycled by NREL during 2006 follow. Quantities 

listed below are those entered into the DOE Pollution Prevention database, which 

tracks recycling on a fiscal year (October 1 through Sept. 30) basis. Data are for 

fiscal year 2006. Quantities are not tracked for all materials that are recycled; 

therefore, the list below does not include all recycled materials. 
Recycled Material Quantity 

Batteries 5,717 lbs

Fluorescent bulbs 214 lbs 

Mixed metal 11,160 lbs 

Commingled containers, cardboard, office 

and mixed paper 214,000 lbs 

Computer monitors 2,164 lbs 

NREL has implemented multiple green purchasing activities including purchasing

office supplies through an online catalog featuring environmentally preferable

(recycled content) products. Green purchasing was integral to NREL's decision to 

create an electronic purchase card system. The system tracks metrics on green 

purchases made at the laboratory and encourages staff to purchase green products 

whenever possible. In 2006, some of the products purchased containing recovered 

content included: carpeting, uncoated-printing paper, and toner cartridges. One 

hundred percent (100%) of NREL’s supply of uncoated printing and writing paper 

contains recycled content. Recycled toner cartridges are available in the NREL

stock room. 

Laboratory Purchase of Recycled Materials 

59 60

48

39 41 45 39

25

30

30 29 18

18

9

15

26

22

0

20

40

60

80

100

120

FY99 FY00 FY02 FY03 FY04 FY05 FY06

Dollars (in thousands)

Carpet

Toner Cartridges

Office Paper

* 2001 Data not available

Since 1999, 100% of all carpet, toner cartridges, and office paper purchased by

NREL have contained recycled content. 

An additional recycling accomplishment at the laboratory in 2006 involved new 

construction activity. The Science and Technology Facility (S&TF) was 

completed in 2006. During design and construction, the target was to exceed the 

requirements for the Leadership in Energy and Environmental Design (LEED) 

Gold level. In March 2007, the S&TF received Platinum level certification, 

including points for materials management. At least 5% of the total value of

materials used in the project contained recycled content, and at least 20% of the 

total value of the materials and products used were manufactured regionally

NREL Environmental Performance Report- 2006

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within a 500-mile radius of NREL. The contractor recycled about 75% of the total 

waste from the project, including the following materials:

• Office and Mixed Paper: 46,000 lbs 

• Asphalt: 38,400 lbs 

• Scrap metals: 8,100 lbs 

• Land Debris: 20,000 lbs 

• Wood: 9,900 lbs 

• Concrete: 17,300 lbs 

5.9.2 Vehicles

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

travel, and employee commuting. Figure 5.1 illustrates a percentage breakdown of 

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

on the footprint of the laboratory, a calculation was done illustrating the 

kilograms of CO2 emitted into the atmosphere. Fifteen percent (15%) of NREL’s

total CO2 footprint was due to transportation. This breakdown serves as a way to 

examine NREL’s transportation issues and proactively provide solutions to reduce 

the impact of transportation. 

Total Transportation Miles in FY06

Air

59%

Commuter

39%

Fleet

2%

Figure 5.1. NREL Transportation by Mode

Sustainable NREL’s Transportation strategy is directed by two Federal guidelines. 

The first, EPACT of 1992 states that 75% of the light duty vehicle (LDV) fleet 

shall be Alternative Fuel Vehicles (AFV). Secondly, Executive Order 13149 

(Greening the Government through Federal Fleet and Transportation Efficiency, 

superseded in 2007 by E.O. 13423) and DOE compliance strategy for this 

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

by 2005 as compared to a 1999 baseline. In order to meet these goals, NREL’s 

fleet currently has 33 AFVs in their total fleet of 47 vehicles. This decreased

NREL’s petroleum use to 6,217 gallons in FY06. The fleet used 9,868 gallons of 

NREL Environmental Performance Report- 2006

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E85 in FY06 which is more than 70% of the total fleet usage of 13,975 gallons of 

fuel. The laboratory is converting its fleet to 100% AFVs as soon as possible, 

subject to their availability for leasing through the General Services

Administration. 

 

NREL Fleet Petroleum Use

6,000

7,000

8,000

9,000

10,000

11,000

12,000

13,000

Gallons Used NREL Gallons Used 12,250 11,700 9,970 10,540 8,500 7,691 7,448 6,217

FY99 FY00 FY01 FY02 FY03 FY04 FY05 FY06

DOE FY05 Goal =

9,800

 

 

Figure 5.2. NREL Fleet Petroleum Use 

For FY06, although NREL is actively using E85-fueled vehicles, biodiesel is also 

an option being explored. Currently, the nearest available biodiesel supplier is 10 

miles away, making obtaining the fuel inefficient. Once there is a local biodiesel

supply, NREL is considering plans to fuel a Kubota tractor, a Gradall lift, and a 

Ford 555 backhoe with biodiesel B20 fuel as a pilot project. Proximity of 

biodiesel suppliers to NREL is analyzed quarterly for changes. 

Fleet vehicles are only part of the transportation 

initiative at the laboratory. Sustainable NREL also 

actively encourages alternative commuting for 

employees. In the spring of 2005, employees received 

NREL Environmental Performance Report- 2006

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an on-line survey regarding their commuting habits.132 

of the 384 respondents use alternative modes of 

commuting. Sustainable NREL anticipates updating this survey, in FY08. 

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

NREL offers free bus passes to all full-time employees and provides a free shuttle

service using alternative-fueled vehicles. NREL also works actively with the 

Denver Regional Council of Governments to provide employees with carpool and 

vanpool resources.
NREL Environmental Performance Report- 2006 

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Biking and walking are also viable commuting options for NREL employees 

living within a reasonable proximity and the laboratory wants to make these easy 

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

and bike lockers on-site. Bike vests were given to our bike commuters for an 

added measure of safety. External biking programs are also promoted such as 

Colorado’s Bike to Work Day in June 2006. NREL employees increased 

registered participation in the event by over 20% versus last year. As of 2006, 84 

NREL participants registered traveling over 1,092 miles by bicycle. 

 

Air travel is also a concern for NREL, representing 59% of the total miles 

traveled in FY06. The laboratory has two offices, one in Golden, Colorado and 

the other in Washington, DC. Employees were able to decrease air travel back and 

forth from these two offices by utilizing videoconferencing equipment. In FY06 

alone, the use of video conferencing mitigated the need for 121 domestic air 

flights, totaling 336,300 air miles. 

Energy

The federal requirement for NREL’s energy use in FY05 is a 5% energy-use 

reduction by 2005 and a 10% reduction by 2010, as compared to a 1990 baseline. 

Through energy efficiency retrofits, energy efficient new construction, 

implementation of renewable energy projects, energy education, and the purchase 

of renewable energy certificates (RECs), NREL has exceeded its goals and 

continues to actively pursue all cost-effective, energy-use reduction opportunities 

(refer to Figure 5.2). New goals have been established by the Energy Policy Act 

of 2005 (EPAct 2005) that took effect in 2006. 

The major sources of energy use are building operation (particularly the 

laboratory type buildings) and process loads associated with laboratory testing 

facilities. All major laboratory buildings are metered for electric and natural gas 

use. 

NREL manages its energy-use reduction activities through a comprehensive 

energy management plan. The primary activities include energy efficiency 

retrofits; sustainable, energy-efficient, new-building construction; use of on-site 

renewable energy; extensive use of site metering; energy-management control 

systems; peak demand management; and energy education. 
0

100,000

200,000

300,000

400,000

Btu/Sq. Ft.

1990 FY01 FY02 FY03 FY04 FY05 FY06

FY06 Energy Use Reduction Progress (Electricity/Natural Gas)

Btu/Sq. Ft. without RECs

Btu/Sq. Ft. with RECs

FY05

Goal FY10 

Goal

EPACT

2006 

Goal

Figure 5.3. FY06 Energy Use Reduction Progress (Electricity/Natural Gas)

The baseline is the average for all DOE Laboratories and Industrial Facilities in 

1990. For NREL, this baseline is 352,540 BTU/SF and has been applicable to 

NREL facilities since 2002. 

Table 5.1 includes the FY 1990 baseline and summarizes the total energy

consumption per gross square foot for NREL facilities, which includes both the

South Table Mountain and National Wind Technology Center sites.

Table 5.1. Energy Consumption 

BTU/GSF

FY1990 BASE YEAR 352,540 

FY2001 TOTAL NREL (DOE-owned) 271,247 

FY2002 TOTAL NREL (DOE-owned) 270,495 

FY2003 TOTAL NREL (DOE-owned) 257,887 

FY2003 TOTAL NREL (w/ Renewable Energy Certificates) 240,525 

FY2004 TOTAL NREL (DOE-owned) 256,650 

FY2004 TOTAL NREL (w/ Renewable Energy Certificates) 239,289 

FY2005 TOTAL NREL (DOE-owned) 325,408 

FY2005 TOTAL NREL (w/ Renewable Energy Certificates) 133,253 

FY2006 TOTAL NREL (DOE-owned) 245,498 

FY2006 TOTAL NREL (w/ Renewable Energy Certificates) 23,129 

NREL Environmental Performance Report- 2006

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NREL Environmental Performance Report- 2006 

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NREL completed an energy survey in FY2007. The report will be discussed in the 

CY2007 Environmental Performance Report. 

Energy Efficiency Specifications for Renovations/New Construction 

NREL has always emphasized significantly greater levels of energy efficiency 

than federal standards with all of its DOE-owned buildings. The goal is to reduce 

energy use by 30% compared to the federal standard reference for building 

systems at 10 CFR 434. Energy efficiency criteria have been incorporated into the 

established NREL design standards and specifications for all construction 

projects. All new buildings must meet, at a minimum, Leadership in Energy and 

Environmental Design (LEED) Silver criteria, established by the U.S. Green 

Building Council. In addition, all new laboratory buildings are designed according 

to the principles of the Laboratories for the 21st Century Program. See the 

“Sustainable Building Design” section below for more detailed information. 

Computer/Monitors Purchasing. 

NREL Information Services (IS) provides a standard hardware list of 

recommended Energy Star products for PC and MAC computers, monitors, and 

peripherals. Staff is encouraged to purchase Energy Star hardware items through 

the "Basic Ordering Agreement" (BOA) contracts. Supplier’s websites provide 

energy information for standard products. Flat panel monitors that use 

significantly less energy than standard monitors have been added to NREL’s 

standard supply list, and are the priority purchase recommendation. 

Printers and Copiers

Networked printers are configured automatically to enter a low-power mode of 

15-45 watts or less after a period of inactivity (this time period differs with 

models). Seventy-one (71) duplex modules were purchased in FY 2001 and 

installed on network printers configured to default duplexing. Users can control 

one-sided printing through the applications print feature. All copiers are Energy 

Star rated. 

5.9.3 Renewable Energy

Use of Renewable Energy

The federal requirement is that annual electric use includes renewable energy use 

at the 3% level for each year from 2007 to 2009, 5% from 2010 to 2012, and 7.5% 

from 2013 forward. 

NREL’s goal is to exceed the federal requirement and to maximize its use of 

renewable energy. For energy that is produced onsite (direct energy use), the goal 

is to produce this energy with renewables. Examples of direct energy use are 
natural gas used for building heating and the laboratory’s fleet vehicles. For

energy that is produced offsite (indirect energy), the goal is to offset the related 

GHG emissions through the purchase of renewable energy certificates (RECs). 

NREL makes use of on-site renewable energy sources for 

its direct energy use. On-site electric generation sources 

include photovoltaics and wind. The National Wind 

Technology Center (NWTC) has approximately 1,600 kW

of installed wind turbine capacity used for research 

purposes. When the turbines are running, the energy that 

they produce is used to simultaneous offset NWTC site energy use. In FY06, 

wind and PV sources generated approximately 130 MWh. 

In FY06, electricity was generated by multiple 

photovoltaic projects. These photovoltaic panels are 

located at the SERF, the Site Entrance Building, the 

Outdoor Test Facility, NWTC Site Entrance Building

and DER Test Facility, and remote applications 

including signs, walkway and parking lighting. 

On-site renewable thermal energy sources include solar hot water systems, 

ventilation air preheat systems, and extensive use of passive solar heating and day

lighting. In FY06, these sources produced some 10 MMBtu. A project to displace 

75% of the laboratory’s natural gas use by the 2007/8 heating season is currently

being developed. 

NREL exceeds the federal requirements through the use of onsite renewable

energy and REC purchases. This purchase positioned NREL as the leader among 

the national laboratories in the use of RECs for offsetting GHG emissions. In

FY06, the laboratory made REC purchases to offset its entire CO2 footprint to

meet its goal of being “carbon neutral.” 

Greenhouse Gas Emissions

Through the off-set purchase of RECs, and with regard to the total resources 

brought into, and the wastes generated and disposed of by the laboratory, the 

laboratory became “carbon neutral” in FY06 in terms of CO2 production. 

The updated figure representing NREL’s CO2 footprint is shown in Figure 5.5. 

NREL Environmental Performance Report- 2006

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Figure 5.5 FY06 Kg CO2 Emission Breakdown

5.9.4 Water Conservation

NREL made progress by systematically implementing life-cycle, cost-effective,

water-use reduction measures. Since 2003, six best management practices (BMPs) 

have been implemented. These BMPs include educating staff about water 

conservation, xeriscaping, low-flush toilets, waterless urinals, retrofitted faucets 

and showerheads, cooling-tower management and distribution audits, and leak 

detection and repairs. 

Water use data for the STM site is obtained from the water supply company,

Consolidated Mutual Water. All of the facilities that require water on the STM 

site have dedicated water meters. There are also water sub-meters on all three

cooling towers at the STM site. 

The NWTC site is a remote site that has no wells or water supply. Boulder Public 

Water Supply water is delivered weekly to the NWTC, as described in Section 

5.2. Currently, water usage at the NWTC is measured by the amount of water 

delivered to the site. 

 

The water use for all NREL sites is estimated and summarized in Table 5.2. 

NREL’s total water use was up significantly in 2006, impacted partially by the 

S&TF coming online in 2006. 

NREL Environmental Performance Report- 2006

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Table 5.2. Water Consumption 

Million Gallons per Year (MGY) 

FY2000 (BASE YEAR – TOTAL NREL) 12.6 

FY2001 – TOTAL NREL 11.1 

FY2002 – TOTAL NREL 10.7 

FY2003 – TOTAL NREL 9.6 

FY2004 – TOTAL NREL 8.4 

FY2005 – TOTAL NREL 10.2 

FY2006 – TOTAL NREL 15.7 

NREL completed a water survey in FY2007. The report will be discussed in the 

CY2007 Environmental Performance Report. 

5.9.5 Sustainable Building Design

In the second half of 2006, NREL completed construction of the Science and 

Technology Facility (S&TF), a two-story, 71,000 sq. ft. laboratory research

building to be used for collaborative renewable energy research with industry. It

houses office and laboratories for 75 people. The building is designed to 

accelerate development and commercialization of promising new alternative

energy technologies, such as solar hydrogen and energy efficiency technologies. 

Construction began on the S&TF in early 2005. The facility received Platinum 

Level LEED certification in March of 2007. Its projected energy cost reduction is 

50% better than the requirement for federal facilities (10 CFR 434). The S&TF

was a Laboratories of the 21st Century (Labs 21) Pilot Partner Project; a program 

sponsored by the EPA and DOE. The labs 21 design principles were used in the 

S&TF design. 

Figure 5.6. L.E.E.D. Platinum certified S&TF at STM

NREL Environmental Performance Report- 2006

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NREL Environmental Performance Report- 2006 

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NREL’s goals for the S&TF were to: 

• Build a state-of-the-art facility that meets research needs and is a model of 

sustainable design 

• Develop and implement aggressive energy savings 

• Achieve a LEED Gold rating 

• Minimize the building’s footprint on the land (its impact on natural flora 

and fauna) 

• Preserve views of the surrounding vistas 

The completed S&TF meets the established goals and expresses concepts of 

sustainable design such as: design and sitting, increased energy efficiency, 

reduced operating costs, environmentally preferable building materials, indoor 

environmental quality, and resource conservation, 

NREL’s S&TF received the 2006 Federal Energy Saver Showcase Award as part 

of the Federal Energy and Water Management Awards ceremony in Washington, 

D.C. The award recognizes buildings that incorporate comprehensive energy 

management and stand out as exceptional models of energy efficiency, 

innovation, and sustainable design. The S&TF is expected to use 41 % less energy 

than conventional construction, saving the laboratory $96,000 per year. An 

efficient ventilation system with variable-air-volume supply and exhaust, coupled 

with heat recovery, low-flow fume hoods, evaporative cooling, and an efficient 

central plant contribute to the savings. The building also incorporates 27% local 

or regional building materials. Over 75% of the construction water was recycled. 

In addition, the building has a storm water detention system, xeriscaping, and 

low-flow water fixtures to reduce water consumption. 

In addition to the new S&TF, several of NREL's other buildings, including the 

Thermal Test Facility (TTF) and the SERF are models of energy efficiency. The 

SERF's annual energy costs are 40% below that of a similar building designed to 

meet federal energy standards, and the TTF operates on 63% less energy than a 

building designed to meet the Federal Energy Code. The TTF building received a 

2002 Federal Energy Saver Showcase Award. 

NREL staff designed the NWTC Site Entrance Building (SEB) in-house. The 

building was designed to be a near-zero energy building; its systems are fully 

monitored. The NWTC SEB is 16’x 10’ and uses NREL technologies to reduce 

the power demand of the building. Such technologies include: daylighting, 

passive solar heating, good thermal envelope, natural ventilation through the 

windows, low-e windows, overhangs for shade control, a Trombe wall, occupancy 

and daylight sensors, high-efficiency lighting with dimming fixtures, and the use 

of energy efficient flat screen computer monitors. These technologies, along with 

a roof mounted 768 W photovoltaic array and two 1000 W wind turbines, reduce 

the amount of electricity drawn from the utility grid and feed excess electricity 

produced back to the grid. 
NREL Environmental Performance Report- 2006 

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5.9.6 Technical Assistance and Outreach

Outreach by Leadership 

NREL staff developed a Sustainable Design Guide for Los Alamos National 

Laboratory. NREL FEMP staff has assisted in developing both Energy 

Management and Water Management Plans at NREL. In addition, NREL FEMP 

staff developed the Department of Commerce agency-wide energy plan and is in 

the process of assisting several other agencies in their energy planning processes. 

NREL researchers work with DOE, EPA, the U.S. Green Building Council, and 

others on a variety of assistance and outreach programs and activities related to 

energy and water use. Examples include standards development, conferences, 

classes and workshops, tours, publications, websites, and energy and water 

analysis software. NREL’s activities in this regard can be surveyed through the 

most recent Institutional Plan or Performance Assessments, accessible on NREL’s 

website (www.nrel.gov). 

Outreach by Recognition 

As a component of its outreach efforts to disseminate information regarding 

sustainability, NREL has received a number of awards. Examples of these awards 

are: CU Wirth Chair Award in Environmental and Community Development 

Policy and the DOE Departmental Energy Management Achievement Award: 

Effective Program Implementation – Sustainable NREL. In 2005, Sustainable 

NREL received a White House Closing the Circle Honorable Mention and a DOE 

Pollution Prevention Star Award. 

Internal and External Outreach 

NREL has produced a number of publications with the goal of sharing the details 

of NREL’s Sustainability Program with staff and the public. These include the 

Sustainable NREL Pioneer and NREL NOW, internal electronic publications; and 

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

and to the public. Also, as part of Sustainable NREL’s internal outreach program, 

the laboratory has implemented a Web site with an enhanced suite of 

sustainability tools for employees. For example, some of the tools address 

alternative commuting, computer power management, and CO2 emissions 

equivalents from employee activities and laboratory operations. 

5.10 Vegetation 

5.10.1 Program Management

Management in this area is consistent with NREL’s Weed Management Programs 

for the STM and NWTC (6-2.12 and 6-2.13, respectively) and the Sustainable 

Landscape Design and Management Program (6-2.19). 
NREL’s basic philosophy regarding vegetation is to conserve the ecosystems on 

the site in their natural state as much as possible. There is some landscaping using

non-native drought-tolerant species adjacent to some of the buildings, and even a 

few areas of bluegrass at the STM site. However, the native vegetation and 

natural character of the landscape is maintained over the majority of the site. 

Revegetation of areas to be left in their natural state following disturbance from 

construction or other outdoor activities is conducted using a native seed mix of 

grasses and forbs. These mixes are site-specific and are composed predominantly

of natives that were originally present on the site before disturbance. Seed mix

and revegetation procedures are outlined in NREL’s Storm Water Pollution

Prevention Programs for the STM and NWTC Sites. The use of native species is 

required at both the STM and NWTC whenever feasible. When possible, 

replacement of high water demand species, like Kentucky bluegrass, with 

drought-tolerant species is encouraged. 

The most recent 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. 

Figure 5.7. Frosted Yucca Courtesy Stephen Wilcox 

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. 

 Figure 5.8. Noxious Weed Courtesy Stephen Wilcox

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A three-season vegetation survey of the NWTC site was performed between 

August 1999 and August 2000. The survey defined five general habitats on the 

NWTC site, comprising nine plant communities and 271 vascular plant species 

(Plantae Consulting Services, 2000). Figure 5.7 illustrates a portion of the NWTC 

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

species were found on the site. However, the survey identified a small area of 

xeric tallgrass prairie (defined as mesic mixed grassland in this study) located in 

the southwest corner of the NWTC. This natural community is listed as rare and 

imperiled by the Colorado Natural Heritage Program. This listing implies no legal 

designation or regulatory enforcement. It is so designated primarily for 

management purposes. This area of the NWTC is not impacted by research or 

construction activities on the site. 

Figure 5.9. Flower at STM

 Courtesy Stephen Wilcox Figure 5.10. Lush vegetation growth 

along the NWTC north fence line

The survey identified 11 noxious weed species on the NWTC site. Five of these 

are recognized as belonging to the top-ten prioritized weed species in Colorado:

Canada thistle, diffuse knapweed, field bindweed, musk thistle, and leafy spurge. 

Based on the survey, recommendations were made to continue using a 

comprehensive weed management program, founded on an integrated pest

management (IPM) philosophy.

The survey showed the native seed mix used for revegetation at the NWTC to be 

very successful in many areas of the site. NREL is continuing the use of this seed 

mix for revegetation at the NWTC. 

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

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

control methods. Some of these include mechanical practices (e.g. mowing), 

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

eliminating driving of vehicles off established roadways), and herbicide

treatment. The effectiveness of control methods is periodically assessed. The use 

of multiple strategies for control has been successful in significantly reducing

populations of diffuse knapweed and Canada thistle on the sites. The key aspect 

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of the weed control program is to maintain flexibility to respond to the changes in 

weed populations from year to year. 

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

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

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

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

time, infested areas of the NWTC have been treated using ground application with 

herbicide. More information regarding 2006 herbicide application is provided in 

Section 5.10.3. 

Weed infestations at the STM site are much less severe than at the NWTC. 

Limited ground application of herbicides has been conducted at the STM since 

1998. 

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

practicing environmentally sound, cost-effective landscaping practices. These 

practices reduce adverse impacts to the natural environment while providing 

essential shade and cooling for indoor and outdoor spaces, and a more 

aesthetically appealing appearance for the sites. This commitment is implemented 

by a Sustainable Landscape Design and Management Program. 

5.10.2 Permitting

There is no permitting applicable to vegetation management, although there is a 

state weed law that requires property owners to control certain species of invasive 

weeds (e.g., diffuse knapweed). For application of certain types of herbicides 

designated as “restricted use” by the EPA, a certified applicator must be used. In 

2005, one of NREL’s Site Operations staff attended training and became a 

certified applicator of restricted use pesticides. Herbicides and pesticides applied 

by NREL staff are applied by the certified applicator or under his supervision, 

according to regulatory requirements. 

5.10.3 2006 Activities

NREL routinely practices IPM using various weed control methods, as described 

in the previous section. These are implemented during the normal course of site 

operation. In addition to the reclamation, off-road driving restrictions, and other 

weed control methods, ground applications of herbicides occurred at the NWTC 

in the spring of 2006. Very limited herbicide application was conducted on the 

STM site in the spring of 2006, focusing primarily on areas adjacent to roadways 

and buildings. The spraying was performed using a four-wheel drive vehicle. 

Primary target weeds were diffuse knapweed, leafy spurge, Canada thistle, 

common teasel, and hoary cress at the NWTC. At the STM, target weeds were 

mainly diffuse knapweed and Canada thistle. 
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In 2006, the weed management plans for the NWTC and STM were consolidated 

into an Integrated Weed Management Plan. The approach used to integrate weed 

control activities will be expanded to the control of other pests at NREL facilities, 

ultimately resulting in an integrated pest management program. 

On January 19, 2006, a Pesticide Applicator- Routine Inspection was conducted 

by a representative of the Colorado Department of Agriculture. The routine 

inspections cover office records, notification and posting, storage, disposal, 

equipment, and supervision. The inspector identified a minor issue with posting 

the pesticide storage area. The Facility Maintenance Building, NREL’s designated 

pesticide storage location, was posted with proper signage shortly after the 

inspection. No other issues were noted by the inspector. 

5.11 Wildlife 

5.11.1 Program Management

Wildlife habitat at the STM site is primarily grasslands, shrublands, and wetlands. 

The STM site provides vegetation types for a variety of wildlife species including 

birds, mammals, reptiles, and amphibians. The variety of vegetation types present 

on site attracts species that may use the site as year-round habitat, for breeding 

only, during migration, or as winter habitat. 

A wildlife survey was conducted on the STM sites in 1987. Follow-up 

verification surveys were conducted in 1998 and 1999. A new site-wide wildlife 

survey was completed in 2005. 

NWTC Site

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 greathorned owl were noted on the site, they were primarily transient in nature. The 

survey indicated that the NWTC appears to be used primarily for resting and 

hunting, although one pair of kestrels nested in an old concrete pole during the 

spring. Birds of prey of concern, such as eagles, generally fly in excess of 152 m 

(500 ft) over the site. No significant impacts to the birds from NREL activities 

were found during the survey. 

A year-long monitoring project for birds and bats was initiated on the NWTC in 

early 2001. Standardized plot surveys were conducted to survey songbirds and 

raptors on the NWTC and adjacent, undeveloped areas. NREL also conducted 

systematic searches of turbines and meteorological towers on the NWTC to 

document avian mortality. The study was completed in July 2002. salient findings 

of the study were as follows (Schmidt, E., et al., 2003): 

• Abundances of individual raptor species on the NWTC site were similar to 

surrounding areas. However, the average number of species detected per 
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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 low-stature 

grasslands preferred by this species. 

• Bird abundance and variety on the undeveloped southern portion of the 

NWTC site were generally similar to the developed areas, except for the 

relative scarcity of raptors on the undeveloped site, which probably was 

due to a lack of perches. 

• The NWTC does not support a large diversity or abundance of bat species 

(possibly six species of bats use the site), but an area on the northwest side 

of the site, with trees close to a rocky outcrop, provides foraging and 

perhaps a roosting habitat. 

No raptor carcasses were found during the 12-month survey of the NWTC except 

one American kestrel that had died before the study started. Bird mortality 

associated with the site appears to be minor. Extrapolating from four passerine 

(songbird) carcasses found during the searches, estimated annual bird mortality 

attributable to the NWTC was 24 individuals, all songbirds (Passeriformes). Most 

of these deaths were probably the result of collisions with support wires for the 

meteorological towers rather than the turbines themselves. No evidence was 

found of bat fatalities at the site. 

STM Site

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

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

in light of expanded development of both the site and the surrounding area, and to 

develop best management practices for future construction projects to maximize 

protection for site wildlife. 

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

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

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

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

attached as Appendix B. A summary of the survey results follows (see section 

5.11.3).

5.11.2 Permitting
Scientific collection licenses must be obtained from the Colorado Division of 

Wildlife for the small mammal trapping portion of the wildlife surveys. NREL

has no other permitting requirements for this area of environmental management. 

5.11.3 2006 Activities

Nest surveys for ground nesting birds were conducted prior to the construction 

project that began during nesting season. 

Migratory Birds and Raptors

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

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

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

American tree sparrow was only observed on site during winter surveys and the 

northern harrier was observed hunting on site only in the fall and winter seasons. 

Several species were only observed during the fall season including downy

woodpecker, red-breasted nuthatch, blue jay, loggerhead shrike, and rock wren, 

suggesting that these species may use the STM site as a stopover during

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

migrate as far south as Central and South America. 

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

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

hawk and the American kestrel. Both of these species were observed hunting onsite during the 2004-2005 surveys, in addition to the Cooper’s hawk. The NREL

STM site provides habitat and a prey base of small birds and small mammals for

these raptor species. Species such as the Swainson’s hawk migrate thousands of 

miles each year, wintering as far south as Argentina, and returning to the western 

United States and Canada to breed. Areas such as the STM site may provide a 

prey source for the Swainson’s hawk and other species during migration. 

Large Mammals

Mule deer at the STM site have been observed in 

all habitat types. Mule deer were often observed in 

the amphitheater drainage or in the tall shrubland 

on the slope. When approached on the mesa top, 

the mule deer tended to move away from the 

disturbance and into the amphitheater drainage. 

 Figure 5.11. Mule Deer

 Courtesy Dean Levi

The tall shrubland vegetation type may provide important hiding cover for this 

species. Spring pellet group surveys resulted in nearly double the amount of pellet 

groups and plots the pellet groups were observed in than fall surveys. This may

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

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

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

data is not sufficient to draw conclusions regarding seasonal variation. 

Predators

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

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

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

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

predation on cottontail rabbits (i.e. entrails and fur) was observed during site 

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

site in two of the site drainages. 

Small Mammals

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

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

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

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

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

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

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

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

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

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

adapted to the grasslands, constructing burrows and runway systems throughout 

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

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

year. Winter surveys (2004-2005) were conducted during a warm weather trend, 

which may have contributed to the highest number of small mammals caught 

compared to the three other surveys. 

Reptiles/Amphibians

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

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

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

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

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

species usually active from mid-April through late-September (Hammerson 

1999). Although only three species of reptiles and one species of amphibian were 

observed on the STM site, no specific survey methods were employed to identify 

or count these groups of wildlife at STM. Some of the STM Site wildlife species 

are shown on the photos in Figures 5.13 through 5.16. 
To avoid or minimize disturbance to wildlife species on site, site-wide BMPs 

were developed as a result of this survey for consideration during ongoing normal 

site operations and future construction projects. The BMPs address migratory

birds and raptors, mammals, all wildlife, and general site operations. They will be

applied as appropriate to site activities and future site development. 

Figure 5.12 – Coyote eating a jackrabbit at STM. Photo courtesy of Stephen Wilcox.

Figure 5.13. Rattlesnake rests in the leaf litter Figure 5.14. A bull snake and a rabbit.

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 Figure 5.15. STM Site wildlife. “Bucky”, on STM (left), courtesy of Stephen Wilcox. In the

photo on the right, two thistle bees are captured on film - by Stephen Wilcox. 

Figure 5.16. STM Site wildlife. A long-tailed weasel peaks out from underneath the 

CNG cylinders on the STM site (left). . . In the photo on the right, a rare sighting of 

an amphibian; a tiger salamander.

5.12 Endangered Species/Species of Concern

5.12.1 Program Management

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The Endangered Species Act provides for the designation and protection of

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

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

surveys, a species of concern is defined as those species protected under Federal 

statutes, including the Endangered Species Act of 1973, as amended, the Bald 
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Eagle Protection Act of 1940, as amended, and the Colorado Division of Wildlife 

list of endangered, threatened, and wildlife species of concern. Federal agencies 

are also required to abide by the Migratory Bird Treaty Act of 1918, as amended, 

but for this report, these species are not included as species of concern. For plant 

surveys, the Colorado Natural Heritage Program designation is also considered. 

Although this listing of rare species is not regulatory in nature, NREL uses it for 

management purposes. 

No threatened or endangered species or candidate wildlife species for endangered 

designation or other sensitive species have been found on either the STM or 

NWTC sites during any site wildlife surveys. Likewise, no threatened, 

endangered, candidate, or other sensitive plant species were identified in any 

survey of the STM or NWTC sites, as there was no suitable habitat present for 

any of the sensitive species. 

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

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

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

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

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

for management planning purposes. This xeric tallgrass prairie area has been 

designated by NREL as a Conservation Management Area. Most of the 

Conservation Management Areas on the NWTC are formally designated as areas 

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

active turbine testing area, it is not reasonable to preclude all development on 

portions of the site inhabited by this plant community. Disturbance will be 

minimized on the area. 

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

imperiled plant species on the site, but areas of mixed foothills shrublands (also 

called tall upland shrubland) were identified along the top of the mesa within the 

Conservation Easement area. That natural community is listed as rare and 

imperiled by the Colorado Natural Heritage program. It is within a designated 

conservation easement area where no development will occur except planned 

trails being established by Jefferson County Open Space (see Section 6.0 for a 

discussion of trails). 

As reported in Section 5.11.3, a site-wide wildlife survey of the STM site has 

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

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

golden eagles were incidentally observed on the STM site (outside of raptor 

surveys) and are protected under the Bald Eagle Protection Act. Golden eagles 

were observed flying over the site and may use the site for hunting. No golden 

eagle nests or nesting activities were observed on the STM site. 
Permitting

NREL has no permitting requirements for this area of environmental 

management. 

5.12.2 2006 Activities

In 2006, the presence of a new avian species was recorded at STM – the Eurasian 

Collared Dove (Streptopelia decaocto). This is an invasive species that has just 

begun to inhabit the Denver area. The Colorado Division of Wildlife considers 

this species to be a threat to native avian species, and allows the unlimited take of

Eurasian collared doves during regular dove season and during a special dove 

season in the winter. NREL has not taken any birds in 2006. 

Figure 5.17. Eurasian collared dove (Streptopelia decaocto) at STM

5.13 Wetlands/Floodplains 

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

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

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

mint. 

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 floodplain maps generated by the Urban Drainage and Flood 

Control District and adopted by the Jefferson County Department of Highways

and Transportation, 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). 

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5.14 Cultural Resources

5.14.1 Program Management

Cultural resources are protected under Section 106 of the National Historic

Preservation Act (NHPA) of 1966, as amended. Significant cultural resources are 

either eligible for, or listed in, the National Register of Historic Places (National

Register).

Cultural resources are defined as any prehistoric or historic district, site, building,

structure, or object considered important to a culture, subculture, or community

for scientific, traditional, religious, or any other reason. Cultural resources can be 

divided into three major categories: 

• Prehistoric and historic archaeological resources. 

• Architectural resources. 

• Traditional cultural resources. 

Prehistoric and historic archaeological resources are locations where human

activity measurably altered the earth or left deposits of physical remains (e.g., 

arrowheads, bottles). Prehistoric resources that predate the advent of written 

records in a region range from a scatter composed of a few artifacts to village

sites and rock art. Historic resources may include campsites, roads, fences, trails, 

dumps, battlegrounds, mines, and a variety of other features. 

Architectural resources include standing buildings, dams, canals, bridges, and 

other structures of historic or aesthetic significance. Architectural resources 

generally must be more than 50 years old to be considered for protection under 

existing cultural resource laws. However, more recent structures, such as Cold 

War facilities, may warrant protection if they manifest the potential to gain 

significance in the future.

Figure 5.18. STM cultural resource. Stone and concrete ammunition 

bunker at STM. Photo courtesy of Stephen Wilcox.

A traditional cultural resource can be defined as a property that is eligible for

inclusion in the National Register because of its association with cultural practices 

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or beliefs of a living community that are rooted in the community’s history, and 

are important in maintaining the continuing cultural identify of the community. 

Traditional resources can include archaeological resources, buildings, 

neighborhoods, prominent topographic features, habitats, plants, animals, and 

minerals that Native Americans or other groups consider essential for the 

persistence of their traditional culture. 

Three formal surveys of historic and cultural resources have been performed on 

the STM site. These surveys were completed in 1980, 1987, and 2003 (see 

Section 5.14.3 for more detail about the 2003 survey). Two additional surveys of

the Camp George West district involving the STM site have also been conducted. 

As a result of these STM surveys, three historical sites were recognized as 

significant cultural resources that should be preserved. These sites include an 

open-air amphitheater, a stone bridge spanning a natural drainage channel 

adjacent to the amphitheater, and a stone and concrete ammunition bunker below 

the amphitheater site (see Figure 5.12). The three structures were constructed 

during the Works Progress Administration (WPA) era in the 1930s. Through 

NREL's efforts, these sites have been added to the National Register of Historic 

Places (National Register), with the amphitheater and stone footbridge listed 

together as a single site. NREL also participated in an interagency survey of South 

Table Mountain and Camp George West to identify historic structures and sites 

eligible for nomination to the National Register. Figure 1.7 provides an aerial 

view of the amphitheater, while Figure 5.13 captures a ground-level view. 

Figure 5.19. STM Site cultural resource. Amphitheater at STM. Photo courtesy of Stephen Wilcox

The Camp George West Historic District, also listed on the National Register, 

includes the 25-acre parcel of NREL’s site, south of the Denver West Parkway.

Two types of historic archaeological resources (firing range lines and a low rock 

wall) have been identified on that parcel. These resources have been determined 

to contribute to the National Register eligibility of the Camp George West 

Historic District. 

An archaeological survey of the NWTC site was conducted in support of the 1996 

Environmental Assessment to supplement previous surveys so there were no gaps 

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in cultural surveys on the site. No significant historical or archaeological 

resources were identified. However, the wooded ridge area on the west portion of 

the site was identified as a location with potential for cultural resources, so further 

testing or observation during excavation would be done should there be any future 

need for work in the utility corridor in the vicinity of the ridge. 

Should any evidence of cultural resources be discovered at any time during 

ground disturbing activities at the STM or NWTC sites, NREL will stop all work 

in the vicinity until a qualified archaeologist evaluates the significance of the find. 

5.14.2 Permitting

NREL has no permitting requirements for this area of environmental 

management. 

5.14.3 2006 Activities

Background Information

The Camp George West Historic District overlaps the NREL STM property by 25 

acres. Two contributing resources occur within those 25 acres. Contributing 

resources are those features within a historic district that contribute to the 

district’s overall eligibility for the National Register. 

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

Denver West Parkway on the STM Site. The survey confirmed the existence of 

the contributing features to the Camp George West Historic District occurring 

within the 25-acre parcel. The contributing resources are as follows: 

• Two firing lines located on the 25 acres. There are also firing lines located 

south of the NREL property on land owned by Jefferson County Open Space 

and proposed for development as the Camp George West Park. 

• Portions of a low rock wall are also present on the 25 acres. There is also a 

rock wall located south of the NREL property. 

DOE consulted with the State Historic Preservation Officer (SHPO) regarding the 

significant resources located on the 25 acres. DOE and the SHPO subsequently 

entered into a Memorandum of Agreement in which DOE agreed to perform 

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

development of the parcel. 

In 2005, the DOE Golden Field Office and NREL conducted documentation of 

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

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

Register of Historic Places. The documentation resulted in Level II HABS/HAER 

documentation that consisted of mapping, photographs, and detailed description 
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of the resources. The documentation was submitted using archival quality 

materials to the State Historic Preservation Officer in late 2005. 

2006 Update 

In January 2006, the Camp George West Level II HABS/HAER Documentation 

(originally dated August 2005) was revised to include field drawings of the “low 

rock wall” as requested by the Colorado SHPO. This was the final report 

submitted to the SHPO. It is on file with the Colorado SHPO and also at the DOE 

GO and NREL offices. 

Additionally in CY2006, a site survey for cultural resources was conducted in 

support of NREL / DOE’s EA for the first of three site development projects 

(RFHP, and two potential solar field sites). The RFHP EA was completed in early 

summer 2007, and will be discussed in the CY2007 Environmental Performance 

Report. 

5.15 National Environmental Policy Act (NEPA) 

5.15.1 Program Management

Management in this area is consistent with NREL’s NEPA Implementation 

Program (6-2.2). 

As a federal agency, DOE is obligated to comply with NEPA by evaluating the 

potential for environmental impacts prior to conducting its activities. The Council 

of Environmental Quality (CEQ) issues regulations for compliance with the Act. 

DOE has also issued implementing regulations at 10 CFR that complement the 

CEQ requirements. DOE has written a site wide Environmental Assessment (EA) 

for its activity at the STM Site and DWOP, and separate EAs for the NWTC and 

JSF activities. 

NREL has established procedures, with the approval of the DOE Golden Field 

Office (GO), to assist DOE in meeting their NEPA obligation. Proposed activities 

that will be conducted at NREL’s five sites are evaluated for their potential 

environmental effects using the appropriate level of NEPA review, in conjunction 

with GO. 

The NREL NEPA Handbook has been prepared to provide NREL project 

managers and procurement specialists with guidance on implementing the NEPA 

procedures, and training is provided to staff, as appropriate. 

5.15.2 Permitting

NREL has no permitting requirements under NEPA. 
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5.15.3 2006 Activities

During 2006, 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 GO NEPA Compliance Officer (GO NCO). NEPA requirements were 

also coordinated with future program planning (e.g., development of NREL’s 

2007 Grand Buildout Infrastructure Design) through interaction between NREL’s 

ESH&Q Office Director and NREL’s Technology Program and Project Managers. 

Requirements were also coordinated through participation in the NREL 

management annual planning process and other reviews of proposed projects for 

the upcoming 2006 year. 

In April 2006, NREL completed and issued an updated “NREL NEPA 

Environmental Review Handbook”. This handbook includes NEPA background 

and criteria, categorical exclusions, a NEPA worksheet, an environmental 

checklist, and instructions for the checklist. 

Additionally, in CY2006, NREL began the EA process for three projects (RFHP, 

and two potential solar field sites). The EA was completed in early summer 2007, 

and will be discussed in the CY2007 Environmental Performance Report. 

5.16 Radiological Program 

5.16.1 Program Management

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

Quality Protection (6-2.5), and Radiological Control (6-4.5). 

All radioactive material at NREL facilities is handled according to NREL’s 

Radiological Control Program. Elements of the program include a radiological 

control organization, a radiation safety policy and control manual, safe operating 

procedures, safe work permits, radiological control areas and postings, 

monitoring, training, and purchasing controls for radioactive materials. 

There are no nuclear operations at NREL sites. All of NREL’s radiation sources 

are used/stored in facilities located on the STM site. These include four x-ray 

diffraction machines at the SERF on the STM Site.. In addition, one laboratory at 

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

small quantities of radioisotopes for biological or chemical labeling. 

The four x-ray diffraction machines located at the SERF are registered with the 

State of Colorado and are inspected every 2 years by a state-licensed surveyor. 

The surveyor inspects and certifies the x-ray machines and audits NREL's 

program for radiation safety in connection with operating the machines. 
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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-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-level radioactive waste. 

5.16.2 Permitting

NREL does not have a radioactive materials license from the State of Colorado, as 

the laboratory is currently under DOE jurisdiction for radioactive materials 

handling. 

5.16.3 2006 Activities

During 2006, no work involving the use of radioisotopes occurred. In 2006, the 

potential dose to the public was calculated as though the contents of all unsealed 

containers of stored radioisotopes were exhausted to the atmosphere. P-32 and S35 waste that is stored in the Waste Handling Facility and has decayed past ten 

half-lives was not included in this calculation. 

The distance from the source in the FTLB to the nearest potential receptor is 119 

m (fence line of nearest resident). For the WHF, the distance from the source to 

the nearest potential receptor is 311 m. 

According to the COMPLY computer model, the potential dose to the nearest 

member of the public was 0.016 mrem/yr, well below the emission limit of 10 
mrem/yr, and NREL is in compliance with the NESHAP for radionuclides. 

Because the dose is calculated rather than measured, it represents a potential or

estimated rather than an actual dose.

The resulting calculated off-site whole body doses are small, but are still likely

overestimates of potential radionuclide doses. The COMPLY formula assumes 

that the entire quantity of the radionuclide in all open containers was released, and 

that the receptor raises and consumes all his/her own milk, meat, and vegetables 

at home. These assumptions are extremely conservative. 

In 2006, there were no unplanned releases of radioisotopes. 

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. 

Figure 5.20. Conservation easement

Courtesy Stephen Wilcox

 

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 diverse 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. 

NREL Environmental Performance Report- 2006

 Page 80
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.

2006 Assessment of the Property 

During 2006 there was no NREL activity on the conservation easement property having the 

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

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

other environmental issues were found. Representative areas of the easement lands are shown 

in the photo below, taken in 2006. 

Jefferson County Open Space has the responsibility to establish and maintain formal trails on 

the Conservation Easement Property. The trail plan calls for establishing trails in phases. The

first phase began in 2004, with Jefferson County Open Space installing two trails from 

Denver West Parkway (near the NREL Site Entrance) to the mesa top. Routine trail 

maintenance occurred in CY2006. . No additional trails were constructed in 2006. 

Figure 5.21. STM Site easement lands.

NREL Environmental Performance Report- 2006

 Page 81
Contacts for Feedback or More Information

We welcome your feedback and suggestions on this report and on NREL’s efforts at sustainability and environmental 

stewardship. To provide comments or to obtain additional information about NREL’s environmental and sustainability

programs, please contact: 

Maureen Jordan Frank Rukavina

Senior Environmental Scientist Director, ESH&Q 

maureen_jordan@nrel.gov frank_rukavina@nrel.gov 

303-275-3248 303-275-3220 

National Renewable Energy Laboratory

1617 Cole Boulevard, Golden, Colorado 80401-3393

303-275-3000 – www.nrel.gov

Operated for the U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

by Midwest Research Institute – Battelle

NREL- September 2006 

Figure 5.22. Site wildlife at sunset

Courtesy Stephen Wilcox

NREL Environmental Performance Report- 2006

 Page 82
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. 

Felsburg Holt & Ullevig (2007). National Renewable Energy Laboratory South Table

Mountain Facility Traffic Impact Study Update. Centennial, 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. 

NREL Environmental Performance Report- 2006

 

 Page 83
Rust Environment & Infrastructure, Inc., (1995a). Report, Wastewater Monitoring Program,

Fourth Quarter, 1994 and Annual Report. Englewood, Colorado. 

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

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

Colorado. 

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

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

Report. University of Colorado, Boulder, Colorado. 

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

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

Golden, Colorado. Lakewood, Colorado. 

U.S. Department of Energy, (1998). Environmental Assessment, Right-of-Way Easement For 

Public Service Company of Colorado at the South Table Mountain Site, Golden, Colorado. 

DOE/EA-1254. 

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

Laboratory (NREL) Site Conservation Easement Baseline Inventory. Golden, Colorado. 

U.S. Department of Energy, (1993). Site wide Environmental Assessment for the National

Renewable Energy Laboratory, Golden, Colorado. DOE/EA-0850. 

U.S. Department of Energy, (2002). Site-Wide Environmental Assessment of National

Renewable Energy Laboratory’s National Wind Technology Center. DOE/EA 1378. 

U.S. Department of Energy, (2003). Site-Wide Environmental Assessment of the National 

Renewable Energy Laboratory’s South Table Mountain Complex. DOE/EA 1440. 

U.S. Department of Energy, (2007). Final Environmental Assessment of Three Site 

Development Projects at the National Renewable Energy Laboratory South Table Mountain 

Site. DOE/EA 1573. 

NREL Environmental Performance Report- 2006

 

 Page 84
NREL Environmental Performance Report- 2006 

 

 Page 85

8 APPENDICES 

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

Appendix B – Wildlife Species Observed on the South Table Mountain Site 

APPENDIX A – SUMMARY OF NREL ENVIRONMENTAL PERMITS, REGISTRATIONS, NOTIFICA

Tracking

Number 

Permit or 

Registration

Number 

Permit or Reg. 

Holder 

Permit Type Permit Description Issuing

Agency Name

Location

Description 

Status

Permits

1 04JE1442L DOE AIR Air Emission Permit

for Land Development

(fugitive dust from

construction activities)

Colorado Dept. 

of Public

Health and

Environment

(CDPHE) 

NWTC 01/31/2

issue

2 04JE1443L DOE AIR Air Emission Permit

for Land Development

(fugitive dust from

construction activities)

CDPHE STM 01/31/2

issue

7 37232 SERI Groundwater

Monitoring Well

Permit to Construct a 

Well (MW-1) 

Colo. Div. Of

Water 

Resources 

STM Constru

permit 

until w

8 37229 SERI Groundwater

Monitoring Well

Permit to Construct a 

Well (MW-2) 

Colo. Div. Of

Water 

Resources 

STM Constru

permit 

until w

9 37228 SERI Groundwater

Monitoring Well

Permit to Construct a 

Well (MW-3) 

Colo. Div. Of

Water 

Resources 

STM Constru

permit 

until w

10 37231 SERI Groundwater

Monitoring Well

Permit to Construct a 

Well (MW-4) 

Colo. Div. Of

Water 

Resources 

STM Constru

permit 

until w

11 37230 SERI Groundwater

Monitoring Well

Permit to Construct a 

Well (MW-5) 

Colo. Div. Of

Water 

Resources 

STM Constru

permit 

until w

NREL Environmental Performance Report- 2006 
Tracking

Number 

Permit or 

Registration

Number 

Permit or Reg. 

Holder 

Permit Type Permit Description Issuing

Agency Name

Location

Description 

Status/ 

D

12 214960

Closed

NREL/DOE Groundwater

Monitoring Well

Permit to Construct a 

Well (MW-11) 

Colo. Div. Of

Water 

Resources 

STM Well clo

12, 20

number 

until w

13 214961

Closed

NREL/DOE Groundwater

Monitoring Well

Permit to Construct a 

Well (MW-10) 

Colo. Div. Of

Water 

Resources 

STM Well clo

12, 20

number 

until w

14 214962

Closed

NREL/DOE Groundwater

Monitoring Well

Permit to Construct a 

Well (MW-09) 

Colo Div. Of

Water 

Resources 

STM Well clo

12, 20

number 

until w

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

issued 

16 20070617

through 

20070623 

NREL Permit Hazardous material

storage and use permit

West Metro 

Fire Protection

District 

7 STM facilities 

(Bldg 16, WHF,

SERF, S&TF, 

FTLB, AFUF, 

S&R)

Jul

17 P15-07-00003 NREL BioSafety Permit Sugarcane Bagasse USDA - APHIS STM 02/018 PDEP-07-

00222 

NREL BioSafety Permit Wheat Streams USDA - APHIS STM 02/0

19 PDEP-06-

00178 

NREL BioSafety Permit Oryza sativa leaves

and stems 

USDA - APHIS STM 12/0

Notifications and

Registrations

20 PWSID

Number 

CO0230860 

DOE DRINKING

WATER

Non-community 

Supply of hauled 

water from a

surface water 

source 

CDPHE NWTC 

NREL Environmental Performance Report- 2006 
Tracking

Number 

Permit or 

Registration

Number 

Permit or 

Reg. Holder

Permit Type Permit 

Description 

Issuing

Agency Name

Location

Description 

Status/ 

D

21 CO4890000017 DOE HAZARDOUS

WASTE 

Notification of

Regulated Waste 

Activity

CDPHE DWOP U

recomm

3-5 year

if substan

in acti

Last up

22 CO3890090076 DOE HAZARDOUS

WASTE 

Notification of

Regulated Waste 

Activity

CDPHE STM U

recomm

3-5 year

if substan

in acti

Last up

23 COD980805162 DOE HAZARDOUS

WASTE 

Notification of

Regulated Waste 

Activity

CDPHE JSF U

recomm

3-5 year

if substan

in acti

Last up

24 COD983802448 DOE HAZARDOUS

WASTE 

Notification of

Regulated Waste 

Activity

CDPHE NWTC U

recomm

3-5 year

if substan

in acti

Last up

25 COR000207563 DOE HAZARDOUS

WASTE 

Notification of

Regulated Waste 

Activity

CDPHE ReFUEL Issued 

26 001 and 002 DOE AIR: OZONE

DEPLETING 

SUBSTANCES

Registration of

stationary

appliances (2 

SERF chillers) 

CDPHE SERF Annual 

J

27 N/A DOE AIR: OZONE

DEPLETING 

SUBSTANCES

Facility

Notification

CDPHE STM, NWTC Annual 

and 

Dec

NREL Environmental Performance Report- 2006 
Tracking

Number 

Permit or 

Registration

Number 

Permit or 

Reg. Holder

Permit Type Permit 

Description 

Issuing

Agency Name

Location

Description 

Status/ 

D

28 001 DOE AIR: OZONE

DEPLETING 

SUBSTANCES

Registration of

stationary

appliance (chiller 

in DWOP) 

CDPHE DWOP Annual 

J

29 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 

and 

Ap

30 93000378 DOE Historic Registration National Register 

of Historic Places

National Park

Service 

Colorado 

Amphitheater 

No e

31 93000379 DOE Historic Registration National Register 

of Historic Places

National Park

Service 

Ammunition

Igloo 

No e

32 AFP-CO-00255 DOE Alcohol (not an

environmental 

permit) 

Alcohol

Producer's Permit

Bureau of

Alcohol,

Tobacco, and 

Firearms

AFUF (PDU) Annual 

J

33 TF-CO-0331 DOE Alcohol (not an

environmental 

permit) 

Industrial Alcohol 

User Permit 

Bureau of

Alcohol,

Tobacco, and 

Firearms

NREL-wide Annual 

J

34 N/A NREL Transportation Hazardous

Material 

Transportation

U.S. 

Department of

Transportation

NREL-wide Annual 

35 85936 NREL Registration X-Ray Machine

Certification

Report

CDPHE SERF Novem

36 85938

NREL

Registration X-Ray Machine

Certification

Report

CDPHE SERF Novem

37 92056 NREL Registration X-Ray Machine

Certification

Report

CDPHE SERF Novem

NREL Environmental Performance Report- 2006 
REL Environmental Performance Report- 2006 

Tracking

Number 

Permit or 

Registration

Number 

Permit or 

Reg. Holder

Permit Type Permit 

Description 

Issuing

Agency Name

Location

Description 

Status/ 

D

38 85937 NREL Registration X-Ray Machine

Certification

Report

CDPHE SERF Novem

39 COR10000F DOE Notice of Intent

(NOI) 

Stormwater 

Discharges 

Associated with

Construction 

Activity Under an

NPDES General 

Permit 

EPA S&TF A

40 COR10000F NREL/MRI Notice of Intent

(NOI) 

Stormwater 

Discharges 

Associated with

Construction 

Activity Under an

NPDES General 

Permit 

EPA S&TF A

N
APPENDIX B 

Common and Scientific Names of Wildlife Species Observed During Wildlife

Surveys at the National Renewable Energy Laboratory South Table Mountain 

Site, Golden, Colorado

NREL Environmental Performance Report- 2006
Wildlife Species Observed at the National Renewable Energy Laboratory 

South Table Mountain Site, Golden, Colorado. 

COMMON NAME SCIENTIFIC NAME

Reptiles 

Bull snake1 Pituophis catenifer

Plains garter snake Thamnophis radix 

Six-lined racerunner Cnemidophorus sexlineatus 

Tiger salamander Ambystoma tigrinum

Western rattlesnake Crotalus viridus 

Birds 

American crow Corvus brachyrhynchos 

American kestrel Falco sparverius 

American robin Turdus migratorius 

American tree sparrow Spizella arborea 

Barn swallow Hirundo rustica 

Black-billed magpie Pica pica 

Black-capped chickadee Poecile atricapilla 

Black-crowned night heron Nycticorax nycticorax 

Blue jay Cyanocitta cristata

Brewer's blackbird Euphagus cyanocephalus

Brown headed cowbird Molothrus ater 

Bullock's oriole Icterus bullockii 

California gull Larus californicus 

Canada goose Branta canadensis 

Common nighthawk Chordeiles minor

Common raven Corvus corax 

Common snipe Gallinago gallinago 

Cooper’s hawk Accipiter cooperii 

Dark-eyed junco Junco hyemalis 

Downy woodpecker Picoides pubescens 

European starling Sturnus vulgaris 

Flycatcher Empidonax sp.

Golden eagle Aquila chrysaetos 

Great blue heron Ardea herodias 

Horned lark1 Eremophila alpestris 

House finch Carpodacus mexicanus 

House sparrow Passer domesticus 

Killdeer Charadrius vociferous 

Lark bunting Calamospiza melanocorys 

Loggerhead shrike Lanius ludovicianus 

MacGillivray’s warbler Oporornis tolmiei 

Mallard Anas platyrhynchos 

Mountain bluebird Sialia currucoides 

Mourning dove Zenaida macroura 

Northern flicker Colaptes auratus 

Northern harrier Circus cyaneus 

Osprey Pandion haliaetus 

NREL Environmental Performance Report- 2006

 Page 93
COMMON NAME SCIENTIFIC NAME

Prairie falcon Falco mexicanus 

Red-breasted nuthatch Sitta canadensis 

Red-tailed hawk Buteo jamaicensis 

Red-winged blackbird Agelaius phoeniceus 

Rock dove Columba livia 

Rock wren Salpinctes obsoletus 

Say's phoebe Sayornis saya 

Sharp-shinned hawk Accipiter striatus

Spotted towhee Pipilo maculates 

Swainson’s hawk Buteo swainsoni 

Tree swallow Tachycineta bicolor

Turkey vulture Cathartes aura

Unidentified sparrow 1 - 

Unidentified sparrow 2 - 

Unidentified species - 

Unidentified warbler - 

Vesper sparrow Pooecetes gramineus 

Western kingbird Tyrannus verticalis 

Western meadowlark Sturnella neglecta

Western scrub jay Aphelocoma californica 

White-crowned sparrow Zonotrichia leucophrys 

Mammals

Black-tailed jackrabbit1 Lepus californicus 

Bushy-tailed woodrat1 Neotoma cinerea 

Coyote Canis latrans 

Deer mouse Peromyscus maniculatus

Fox squirrel Sciurus niger

Long-tailed weasel Mustela frenata 

Mexican woodrat Neotoma mexicana 

Mountain cottontail Sylvilagus nuttalli 

Mule deer Odocoileus hemionus 

Prairie vole Microtus ochrogaster

Raccoon Procyon lotor

Red fox Vulpes vulpes 

Western harvest mouse Reithrodontomys megalotis 

White-tailed jackrabbit Lepus townsendii 

Yellow-bellied marmot1 Marmota flaviventris

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

NREL Environmental Performance Report- 2006

 Page 94