Annual Site Environmental Report per the U.S. Department of Energy Order 231.1-1B

Environmental Performance Report 2012

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

and Renewable Energy, operated by the Alliance for Sustainable Energy, LLC.
This report was prepared as an account of work sponsored by an agency of the United States government. Neither the United States 

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

responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that 

its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, 

trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United 

States government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of 

the United States government or any agency thereof.

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

Cover Photo: Aerial view of technicians working on a turbine at NREL’s National Wind Technology Center.

Photo by Dennis Schroeder, NREL 21869
ENVIRONMENTAL PERFORMANCE REPORT 2012 1

This report requires a tremendous amount of data, 

collaboration, and review to be made possible. Thank 

you to all who contributed their time and effort to this 

publication.

NREL’s Environment, Health, and Safety Office staff 

provided their subject matter expertise by authoring 

content, providing data, and conducting technical 

reviews:

Brenda Beatty

Genny Braus

Larry Durbin

John Eickhoff

Bob Fiehweg

Maureen Jordan

Tom Ryon

Kurt Schlomberg

Eric Schmitz.

Frank Rukavina and the Sustainable NREL team provided 

the report’s sustainability content. Lissa Myers provided 

content for the Traffic Management section of 

the report.

Jennifer Josey with NREL’s Communications Office 

provided editing and project support.

Lori Gray, Robert Smith, and Amy Van Dercook, with 

the DOE Golden Service Center, worked closely 

with Alliance for Sustainable Energy, LLC, staff to 

continuously improve the report and conducted the 

review and approval process. 

Acknowledgements Contact Us

We welcome your feedback and suggestions on 

this report and on NREL’s efforts at sustainability and environmental stewardship. To provide 

comments, to request a printed copy of this 

report, or to obtain additional information about 

NREL’s environmental programs, please contact:

Maureen Jordan, Director, EHS

maureen.jordan@nrel.gov

303-275-3248 

John Eickhoff, Environmental Manager

 john.eickhoff@nrel.gov

303-275-3217

Kerry Masson, Director, Public Affairs Office

kerry.masson@nrel.gov

303-275-4083

This report and reports from prior years are 

available online at:

nrel.gov/ehsq/environmental_protection.html 

National Renewable Energy Laboratory

15013 Denver West Parkway, Golden, CO 80401

303-275-3000

www.nrel.gov
2 ENVIRONMENTAL PERFORMANCE REPORT 2012

Nomenclature

APCD—Air Pollution Control Division of CDPHE

APEN—Air Pollutant Emission Notice

AST—Aboveground Storage Tank

AWS—Alternative Work Schedule

BMP—Best Management Practice

CCR—Colorado Code of Regulations

CDLE—Colorado Department of Labor and Employment 

CDPHE—Colorado Department of Public Health and Environment

CELP—Colorado Environmental Leadership Program

CEQ—Council on Environmental Quality

CESQG—Conditionally Exempt Small Quantity Generator 

CFR—Code of Federal Regulations 

CGP—Construction General Permit

CMS—Chemical Management System

CNHP—Colorado Natural Heritage Program

CO2

—Carbon Dioxide

CO2

e—Carbon Dioxide Equivalent

CRADA—Cooperative Research and Development Agreement

CRS—Colorado Revised Statute

CSP—Concentrating Solar Power

CWA—Clean Water Act

CX—Categorical Exclusion

DBP—Disinfection Byproduct

DFD—Denver Fire Department

DNR—Colorado Department of Natural Resources

DSOC—District Shops and Operations Center

DOE—U.S. Department of Energy

DOE GSC—Department of Energy Golden Service Center 

DOE O—Department of Energy Order

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

of Labor and Employment

DWOP—Denver West Office Park

DWP/DWMB—Denver West Parkway/Denver West Marriott Boulevard

EA—Environmental Assessment

EERE—DOE Office of Energy Efficiency and Renewable Energy

EHS—Environment, Health, and Safety 

EIS—Environmental Impact Statement

EMS—Environmental Management System

EPA—U.S. Environmental Protection Agency

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

ESA—Endangered Species Act

ESIF—Energy Systems Integration Facility

EO—Executive Order

FEC—Federal Electronics Challenge

FONSI—Finding of No Significant Impact

FTLB—Field Test Laboratory Building 

FY—Fiscal Year

GHG—Greenhouse Gas

GHS—Globally Harmonized System of Classification and Labeling of Chemicals

GSF—Gross Square Feet

GWP—Global Warming Potential

HAP—Hazardous Air Pollutant

HMWMD—Hazardous Materials and Waste Management Division of CDPHE

hp—Horsepower

HPSB—High Performance Sustainable Buildings

IBRF—Integrated Biorefinery Research Facility

ISM—Integrated Safety Management

ISMS—Integrated Safety Management System 

ISO—International Organization for Standardization

JSF—Joyce Street Facility

kg—kilogram

kW—Kilowatt 

LEED—Leadership in Energy and Environmental Design

LEPC—Local Emergency Planning Committee

LOMR—Letter of Map Revision

LOS—Level of Service

LQG—Large Quantity Generator 

MAP—Mitigation Action Plan

MBTA—Migratory Bird Treaty Act

MCL—Maximum Contaminant Level

MOU—Memorandum of Understanding

mrem—Millirem

MSDS—Material Safety Data Sheet

MW—Megawatt 

NAAQS—National Ambient Air Quality Standards

NEPA—National Environmental Policy Act

NHPA—National Historic Preservation Act 

NREL—National Renewable Energy Laboratory

NWTC—National Wind Technology Center

NESHAP—National Emission Standards for Hazardous Air Pollutants

NOI—Notice of Intent

ODS—Ozone Depleting Substance

PEMP—Performance Evaluation Measurement Plan

PM—Particulate Matter

PPA—Power Purchase Agreement

PUE—Power Usage Effectiveness

PV—Photovoltaic 

RCRA—Resource Conservation and Recovery Act

ReFUEL—Renewable Fuel and Lubricants Research Laboratory 

RFA—Rocky Flats Alluvium

RFHP—Renewable Fuel Heat Plant 

RFP—Request for Proposal

RSF—Research Support Facility

RTD—Regional Transportation District

SARA—Superfund Amendments and Reauthorization Act

SDWA—Safe Drinking Water Act

SERF—Solar Energy Research Facility

SHPO—State Historic Preservation Officer

SITES—Sustainable Sites Initiative

SO2

—Sulfur Dioxide

SolarTAC—Solar Technology Acceleration Center

SPCC—Spill Prevention Control and Countermeasures

SQG—Small Quantity Generator

SSP—Site Sustainability Plan

SSPP—Strategic Sustainability Performance Plan

S&TF—Science and Technology Facility

STM—South Table Mountain

SWPPP—Stormwater Pollution Prevention Plan

TDM—Transportation Demand Management

TES—Thermal Energy Storage

TPQ—Threshold Planning Quantity

TTB—Alcohol and Tobacco Tax and Trade Bureau of the 

U.S. Department of the Treasury

USACE—U.S. Army Corps of Engineers 

USFWS—U.S. Fish and Wildlife Service

VOC—Volatile Organic Compound

WHF—Waste Handling Facility
ENVIRONMENTAL PERFORMANCE REPORT 2012 3

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

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

Nomenclature........................................................................................2

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

1 Introduction........................................................................................8

1.1 Purpose.......................................................................................8

1.2 Our Mission ...............................................................................8

1.3 Site and Facility Description................................................9

1.4 Site Environmental Conditions/Features......................13

2 Significant Activities in 2012.......................................................14

2.1 Major and Minor Construction Projects........................14

2.2 Integrated Environmental Stewardship in 

Construction Management......................................................15

3 Environmental Management System......................................18

3.1 Environmental Management System Structure.........18

3.2 Performance Indicators and Progress............................20

3.3 Assessment and Improvement ........................................20

3.4 2012 Awards and Recognition .........................................22

4 Sustainability....................................................................................24

4.1 Site Sustainability Planning...............................................25

4.2 2012 SSPP Goal Performance............................................25

5 Compliance Summary...................................................................28

6 Air Quality Protection....................................................................35

7 Water Quality Protection..............................................................39

7.1 Drinking Water.......................................................................39

7.2 Groundwater...........................................................................40

7.3 Surface Water..........................................................................41

7.4 Wastewater..............................................................................43

8 Hazardous Materials and Waste Management ....................45

8.1 Hazardous Materials Management.................................45

8.2 Regulated Waste Management........................................47

8.3 Aboveground Storage Tank (AST) Management.......49

8.4 Spill Prevention and Response.........................................50

8.5 Pollution Prevention ............................................................52

8.6 Radiological Materials and Waste Management........53

9 National Environmental Policy Act...........................................55

10 Natural and Cultural Resources Protection.........................58

10.1 Wildlife Management........................................................58

10.2 Endangered Species and Species of Concern..........62

10.3 Vegetation Management.................................................63

10.4 Wetlands and Floodplains...............................................68

10.5 Cultural Resources..............................................................70

11 Conservation Easement Lands ...............................................73

12 Traffic Management ....................................................................74

Appendix A: Plant Communities at the 

STM and the NWTC............................................................................77

Appendix B: Wildlife Species Observed at the

STM and the NWTC............................................................................83

Appendix C: Environmental Permits, Registrations,

and Notifications Applicable to NREL During 2012...............89

Table of Contents

NREL Environmental Performance Report 2012

ENVIRONMENTAL PERFORMANCE REPORT 2012 5

Purpose

The National Renewable Energy Laboratory’s (NREL) Environmental Performance Report provides a description of 

the laboratory’s environmental management activities for 

2012, including information on environmental and sustainability performance, environmental compliance activities 

and status, and environmental protection programs, highlights, and successes. 

The purpose of this report is to ensure that DOE and the 

public receive timely, accurate information about events 

that have affected or could adversely affect the health, 

safety, and security of the public or workers, the environment, or the operations of DOE facilities. This report meets 

the requirements of the Annual Site Environmental Report 

and is prepared in accordance with the U.S. Department 

of Energy (DOE) Order 231.1B, Environment, Safety and 

Health Reporting. 

Environmental and Sustainability 

Performance

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

requirements, and continual improvement in environmental 

protection and sustainability performance. 

NREL’s Environmental 

Management System 

(EMS) implements a 

framework of policies, procedures, and 

programs that integrates environmental 

protection into daily 

work practices. The 

EMS is structured 

based on a plando-check-feedback 

continual improvement framework 

depicted in the graphic, and is implemented as part of an 

Integrated Safety Management System. 

Executive Summary

About NREL

NREL is the principal research laboratory for DOE’s 

Office of Energy Efficiency and Renewable Energy 

(EERE). The laboratory also conducts research for the 

Office of Science and the Office of Electricity Delivery 

and Energy Reliability. The laboratory is managed 

for EERE by the Alliance for Sustainable Energy, LLC, 

a partnership between MRIGlobal and the Battelle 

Memorial Institute.

NREL is the only national laboratory solely dedicated 

to advancing renewable energy and energy efficiency 

technologies from concept to commercial application. 

The laboratory’s innovations, analysis, and expertise 

have enabled the emergence of a U.S. clean energy 

industry and led to numerous success stories from 

across the laboratory. The laboratory’s 327-acre South 

Table Mountain main campus in Golden, Colorado, is 

a living model of sustainable energy. The laboratory 

also operates the National Wind Technology Center 

(NWTC).

NREL develops renewable energy and energy efficiency technologies and practices, advances related 

science and engineering, and transfers knowledge 

and innovations to address the nation’s energy and 

environmental goals. The laboratory’s research and 

development achievements have helped shape cleanenergy alternatives for powering our homes and 

businesses, and the nation’s transportation infrastructure. NREL’s science and technology teams span the 

full spectrum of innovation, from fundamental science 

and market-relevant research to systems integration, 

and testing and validation. 

NREL researchers are studying microalgae as a potential 

source of biofuels. Photo by Pat Corkery, NREL 16312

Define Scope

Analyze Hazards,

Perform Work

Develop Controls

Feedback &

Improvement

Environment

Quality Safety

Impacts & Issues
6 ENVIRONMENTAL PERFORMANCE REPORT 2012

Each year, the laboratory sets measurable objectives and 

targets for environmental improvement through the NREL 

environmental management system planning process. 

Goals are established in the Performance Evaluation 

Measurement Plan, Site Sustainability Plan, and Colorado 

Environmental Leadership Program. 

Progress through the course of the year on each of these 

goals is tracked using an online software tracking system 

and results are reported annually.

Sustainability

Sustainability is integral to both our research and operations 

and we are committed to demonstrating federal leadership 

in sustainability and continuously improving performance. 

Sustainable NREL, an interdisciplinary initiative involving 

staff from across the organization, fosters environmental and 

social responsibility, working to establish the laboratory as a 

global model for sustainability.

Each year, Sustainable NREL develops a Site Sustainability 

Plan to report on steps taken to meet the national and DOE 

sustainability objectives and outline plans for the upcoming 

year. The laboratory has currently identified 20 objectives 

to enhance sustainability and continues to make significant 

progress toward these objectives. 

Environmental Compliance and 

Monitoring

NREL is subject to many federal, state, and local environmental laws and regulations, as well as executive orders, 

DOE orders, and memoranda of understanding with government agencies. Unlike many DOE facilities, NREL does not 

conduct work involving nuclear materials and does not have 

legacy radiological or other contamination issues associated 

with past nuclear weapons production or research activities; 

therefore, NREL facilities do not conduct regular radiation or 

other monitoring.

The laboratory continued its excellent record of environmental compliance in 2012. No violation notices were 

received from any regulatory agency and all required 

permits were received or renewed, required registrations 

were completed, and required notifications and reports 

were submitted. 

There was one spill at the NWTC which required reporting 

to the state during 2012. An open valve located within the 

elevated nacelle of a wind turbine leaked approximately 

90 gallons of synthetic lubricant oil. No contamination of a 

waterway occurred and the spill was remediated. 

In August 2012, a sample collected from the NWTC drinking 

water system indicated the Maximum Contaminant Level 

(MCL) was exceeded for haloacetic acids, a class of disinfection byproducts. Increased monitoring has indicated that 

haloacetic acids levels have been consistently below the MCL 

since this single exceedance. 

ENVIRONMENTAL MANAGEMENT PROGRAMS

The laboratory continues to meet or exceed compliance 

requirements and strives to make continual improvements 

in environmental management. Major environmental 

program areas include:

■ Air quality protection, including air permitting, ozonedepleting substance management, and greenhouse gas 

emissions monitoring

■ Water quality protection, including construction 

stormwater management, drinking water monitoring, 

and preventing unallowable sanitary sewer system 

discharges

Continued ISO 14001 Certification 

Demonstrates Commitment to 

Environmental Leadership

In 2012, the laboratory maintained International 

Organization for Standardization (ISO) 14001:2004 

certification of its environmental management system. In July, a team of external auditors 

conducted an independent assessment of the 

policies, procedures, tools, and roles and responsibilities used in environmental management. The 

assessment verified that the laboratory continues to meet the requirements of the ISO 14001 

standard and demonstrates our commitment to 

environmental stewardship.
ENVIRONMENTAL PERFORMANCE REPORT 2012 7

■ Hazardous materials and waste management, including 

pollution prevention, spill response, proper storage, use, 

and disposal of hazardous chemicals and materials, as 

well as planning, permitting, and reporting regarding use 

and emissions of such materials 

■ National Environmental Policy Act reviews

■ Natural and cultural resources protection, including wildlife, vegetation, protected species, wetlands, and cultural 

resources management.

Prestigious Environmental 

Sustainability Awards Received

The laboratory received several important 

recognitions in 2012 for its environmental and 

sustainability accomplishments. NREL received a 

DOE Sustainability Award for its “Comprehensive 

Energy Management Plan.” DOE Sustainability 

Awards highlight environmental sustainability 

projects and programs within the DOE complex 

that reduce environmental impacts, enhance 

site operations, reduce costs, and demonstrate 

excellence in pollution prevention and sustainable 

environmental stewardship. 

The laboratory received a DOE Green Buy Program 

Gold Award for purchasing 17 products in five 

different categories, achieving DOE’s Green Buy 

leadership goal.

NREL also achieved the Platinum-level Federal 

Electronics Challenge (FEC) Award. FEC is a 

partnership program between the Office of the 

Federal Environmental Executive and the U.S. 

Environmental Protection Agency (EPA). The FEC 

recognizes federal facilities that voluntarily lead in 

the area of green electronics purchasing, management, and recycling.
8 ENVIRONMENTAL PERFORMANCE REPORT 2012

1.1 PURPOSE 

This report presents a summary of NREL’s 2012 environmental management activities, including: 

■ Environmental protection programs

■ Environmental and sustainability performance

■ Environmental compliance activities and status 

■ Environmental management highlights and successes. 

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

(DOE) most recent guidelines for the Annual Site Environmental Report, as required by DOE Order (DOE O) 231.1B, 

Environment, Safety, and Health Reporting. 

1.2 OUR MISSION 

NREL’s mission is focused on advancing the energy goals of 

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

statement: 

NREL develops renewable energy and energy efficiency 

technologies and practices, advances related science and 

engineering, and transfers knowledge and innovations to 

address the nation’s energy and environmental goals.

NREL fulfills its mission through technology portfolios. A 

brief description of each major technology area follows. 

■ Basic science. Fundamental research is conducted in 

the sciences that underlie NREL’s renewable energy and 

energy efficient technologies. 

■ Bioenergy. NREL currently has major programs in 

biomass-derived fuels (biofuels) and biomass-derived 

electricity (biopower), and projects in biomass-derived 

chemicals and materials. 

■ 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, environmentally acceptable 

building equipment and envelope systems. 

■ Computational sciences. This area includes basic and 

applied research using high-performance computing 

and applied mathematics.

■ 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 renewable and energy efficiency 

technologies in distributed power systems, thus maximizing the utilization of renewable energy and energy 

efficient products. 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.

■ Electricity technologies. Research is conducted to 

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

■ Energy analysis. Research at NREL includes energy 

analysis for various programs and initiatives. 

■ Hydrogen. NREL is a leader in renewable hydrogen 

production technologies and the development of codes, 

standards, and advanced storage and sensors. Basic 

and applied research and material development using 

biology, physics, and chemistry enable and support the 

development of hydrogen production, storage, and enduse systems. 

■ Measurements and testing. NREL laboratories and 

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

(PV) cells, building technologies, and wind turbines. 

■ PV. PV enables the direct conversion of sunlight to electricity using solid-state materials. The National Center for 

Photovoltaics develops and deploys PV technology for 

the generation of electric power. 

1 Introduction

NREL researchers developed the Solar Position Algorithm now 

used by solar trackers, orchard growers and movie-camera 

makers, among others. Photo by Dennis Schroeder, NREL 18600
ENVIRONMENTAL PERFORMANCE REPORT 2012 9

■ Renewable energy resources. Researchers develop 

resource information for solar, wind, biomass, and 

geothermal energy applications. 

■ Renewable thermal technologies. These technologies—including concentrating solar power (CSP), solar 

water heating, and geothermal heat and power—

generate power from heat or utilize heat from renewable resources. 

■ Transportation. NREL works with industry experts to 

develop advanced vehicles and transportation systems. 

NREL also works with energy companies and manufacturers of vehicles and engines to develop advanced 

motor vehicle fuels for improved energy and environmental performance. 

■ Wind energy. Through the National Wind Technology 

Center (NWTC), NREL develops, improves, and demonstrates the viability of wind technology for electricity 

generation and facilitates its utilization throughout 

the world.

1.3 SITE AND FACILITY DESCRIPTION 

NREL facilities occupy four separate locations in Jefferson 

County, Colorado, near Denver, and one location in the City 

and County of Denver. These include:

■ National Wind Technology Center (NWTC)

■ South Table Mountain (STM) site

■ Denver West Office Park (DWOP)

■ Joyce Street Facility (JSF)

■ ReFUEL (located in Denver).

The STM and NWTC sites are the two main sites where 

research operations are conducted; these will be addressed 

separately in the discussion of environmental features. 

DWOP is leased space used primarily for administrative 

functions and limited research activities. The leased JSF 

space is primarily used for storage. The ReFUEL facility is a 

leased space that consists of a small shop complex housed 

within the Regional Transportation District (RTD) District 

Shops and Operations Center (DSOC) facility in Denver. 

Laboratory staff also conduct work at additional locations as 

needed, for example at the Solar Technology Acceleration 

Center (SolarTAC) described below.

SOUTH TABLE MOUNTAIN (STM) SITE 

The STM site is the main research center for NREL—nearly 

80% of the laboratory’s staff have their offices and laboratories there. The STM site is approximately two miles 

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

central Denver.

Land Use

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

of South Table Mountain, a mesa that stands about 492 

feet (150 meters) above the adjacent lowlands. South Table 

Mountain is composed of sedimentary rocks below a basalt 

lava cap, which is quite resistant to erosion.

The STM site is a 327-acre area predominantly bordered by 

open grassland zoned for recreation and light-commercial 

activity. Portions of the community of Pleasant View are 

located immediately to the south and west. Pleasant View 

has constructed a recreational park immediately south 

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

by the Colorado State Forest Service are located at the far 

western edge. Undeveloped state land and a Colorado 

State Highway Patrol pursuit driver-training track are located 

along the northwestern boundary of the STM site on top of 

the mesa. Jefferson County open space wraps around the 

northern and the eastern edge of the site. Portions of DWOP 

and apartment homes lie to the east. 

NREL’s STM campus. Photo by Dennis Schroeder, NREL 21788

A red-tailed hawk in front of the Education Center at NREL’s STM 

campus. Photo by Dennis Schroeder, NREL 22325
10 ENVIRONMENTAL PERFORMANCE REPORT 2012

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 (for more detail, see section 11 Conservation Easement Lands).

Geology, Soils, and Hydrogeology 

The mesa was formed as weak sedimentary rocks surrouning 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 South Table Mountain, and within the 

materials above the Denver Formation, which are largely the 

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

a southeasterly direction. 

The soil covering the top of South Table Mountain is lavina 

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

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

well-drained clayey soil. Soil on the upper side slopes of 

South Table Mountain is also a loam consisting of extremely 

stony soils with significant amounts of clay. Much of the 

remainder of the site, including the area designated for 

major development, has a deep, well-drained soil referred to 

as Denver clay loam. It consists of clayey material containing some calcium carbonate. There are also two smaller 

soil areas on the southwestern portion of the site, both of 

similar character to other site soils—cobbly clay loam and 

very stony clay loam.

Surface Water 

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

the mesa top and across the lower portions of the site, is in 

the southerly direction toward Lena Gulch (a tributary 

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

the easternmost portion of the site ultimately flows into 

Lena Gulch. 

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

occasional flow derived from extended periods of precipitation, usually during the late winter and early spring, is found 

in the drainage channels, with seasonal springs evident 

along some of the mesa slopes. There is one seep on the 

mesa top that is often active throughout much of the year, 

but the water infiltrates and evaporates quickly during the 

dry season. 

Vegetation 

Two primary vegetation types are present on the STM 

site: grasslands and shrublands. The most common plant 

communities on the STM site are mixed grasslands, comprising more than 80% of the vegetation on the site. These 

communities are generally dominated by short- and midgrass 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 drainA new stormwater detention pond controls the flow of runoff 

from much of the STM site and serves as an important local 

habitat. Photo by Dennis Schroeder, NREL 23195

A variety of wildlife can be seen around campus, including 

mule deer. This group still has velvet on their antlers. Photo by 

Brent Nelson, NREL 23904
ENVIRONMENTAL PERFORMANCE REPORT 2012 11

ages with associated wetlands. Field surveys have identified 

limited wetland and riparian areas along drainages. The 

wetland communities identified on the STM site are a minor 

component of the total vegetation cover, accounting for 

less than 1% of the vegetation over an area of less than 0.3 

hectares (0.75 acres). Riparian shrub communities also occur 

adjacent to the emergent wetlands. A vegetation survey of 

the STM site was conducted in 2010 (for more information, 

see section 10.3 Vegetation Management).

Wildlife 

Several comprehensive wildlife surveys have been conducted on the site, starting with the original study in 1987. 

Additional surveys were done in 1999 for the conservation 

easement property. Surveys to update existing data were 

completed in 2005 and in 2011 (see section 10.1 Wildlife 

Management for more information). 

Mammals identified during the surveys included mule 

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

weasels, striped and spotted skunks, badgers, bobcats, 

mountain lions, rabbits, yellow-bellied marmots, and various 

smaller mammals. More than 50 species of birds have been 

recorded on the STM site by the formal wildlife surveys 

and supplemental employee observations. A number of 

raptor species have been recorded at or above the STM site, 

especially during spring migration. Two raptor species are 

resident at the site: American kestrel (Falco sparverius) and 

red-tailed hawks (Buteo jamaicensis). Reptiles and amphibians inhabit the area as well. Most notably, the western 

diamond-backed rattlesnake is routinely encountered 

around the campus area. 

NATIONAL WIND TECHNOLOGY CENTER (NWTC) 

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

border just east of the foothills of the Rocky Mountains, 

the NWTC has abundant wind resources that are critical 

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

is located near the intersection of Highways 93 and 128, 

between Boulder and Golden, and is approximately 15 miles 

(24.2 km) north of the STM site. 

Land Use 

The NWTC facility occupies a 305-acre area surrounded 

largely by open space and grazing land. The Rocky Flats 

National Wildlife Refuge 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. State Highway 128 borders the 

NWTC to the north; Boulder County open space lies to the 

north of the highway.

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.1

The NWTC has a strongly developed soil defined as a very 

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

amount of cobble and gravel in the soil volume, and subsoil 

dominated by clay. 

Surface Water 

The area surrounding the NWTC site is drained by five 

streams: Rock Creek, North Walnut Creek, South Walnut 

Creek, Woman Creek, and Coal Creek. Rock Creek flows eastward and is located southeast of the NWTC. North Walnut 

Creek and South Walnut Creek flow eastward into the Great 

Western Reservoir. Woman Creek drains eastward into 

Standley Lake. Coal Creek flows in a northeasterly direction 

across the City of Boulder Open Space north of the NWTC. 

The majority of the NWTC drains into a tributary to Rock 

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

Coal Creek or its tributaries. 

Aerial view of NREL’s NWTC. Photo by Lee Jay Fingersh, NREL 22073

1

 EG&G Rocky Flats, Inc. (1992). Rocky Flats Plant Site Environmental Report, January Through December 1992. Golden, Colorado.
12 ENVIRONMENTAL PERFORMANCE REPORT 2012

Vegetation 

The NWTC is located in the transition area between the 

Great Plains and the Rocky Mountains2

. 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 flora3

. 

Vegetation surveys conducted at the site have identified 

271 vascular plant species and defined five major habitat 

types on the NWTC site, including: xeric mixed grasslands, 

pine woodlands, shrublands, wetlands, and disturbed areas.

Along the northwestern ridge is a ponderosa pine woodland area. Vegetation found in this area includes woody 

species with an understory of grasses, forbs, and shrubs. The 

most recent vegetation survey was completed in 2011 (for 

more detail, see section 10.3 Vegetation Management).

Wildlife 

Prior to 1975, livestock heavily grazed the NWTC site, 

damaging a majority of the native vegetation. DOE 

prepared a biological characterization inventory in 1992 for 

the entire Rocky Flats plant, including the NWTC site which 

was part of the no-activity buffer zone of the Rocky Flats 

plant at the time. Signs or tracks of bears and mountain 

lions were identified. Other mammals known to feed at the 

site are mule deer, coyotes, desert cottontail rabbits, whitetailed 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 surveys were conducted at the NWTC in 1994 and 

1995, and identified seven raptor species on or in the vicinity of the site. An avian survey was also completed in 2002 

and updated in 2011 (for more information, see section 10.1 

Wildlife Management). Although seldom seen, rattlesnakes, 

bull snakes, racers, and several other reptilian and amphibian species are known to occupy the area. 

DENVER WEST OFFICE PARK (DWOP)

DWOP is approximately two miles (3.2 km) east of Golden 

and 12 miles (19.3 km) west of central Denver. 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 in approximately the geographic center of the development. DWOP 

is bordered on the south by commercial areas (West Colfax 

strip), and on the west by the Pleasant View residential area, 

Camp George West facility, and the STM site. DWOP is within 

the City of Lakewood.

JOYCE STREET FACILITY (JSF) 

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; 

there are no staff offices at JSF. Support activities and limited 

dry laboratory research activities are currently conducted at 

the facility. The JSF is located at 6800 Joyce Street, about 5.5 

miles (8.9 km) north of DWOP and STM sites.

RENEWABLE FUELS AND LUBRICANTS

LABORATORY (ReFUEL) 

ReFUEL 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 is also used to evaluate and develop 

heavy hybrid electric vehicles. 

ReFUEL is a small shop complex housed within the RTD 

DSOC at 1900 31st Street, Denver, about 12 miles east of the 

STM and DWOP sites. 

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 southern, eastern, and northeastern borders. 

Hybrid vehicle fuel economy and emission tests are conducted 

at NREL’s ReFUEL facility. Photo by Jack Dempsey, NREL 17222

2,3 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, Colorado.
ENVIRONMENTAL PERFORMANCE REPORT 2012 13

ADDITIONAL LOCATIONS 

Laboratory staff also conduct work at additional locations as needed. One such location is SolarTAC, operated 

by MRIGlobal, located near Denver International Airport 

northeast of the intersection of East 26th Avenue and North 

Hudson Road in Aurora, Colorado. SolarTAC is a partnership 

of solar equipment manufacturers, research organizations 

and electric utilities that want to make use of a real-world 

outdoor site to develop, test, validate or showcase solar 

products. Approximately 33 miles east of the STM site, the 

74-acre facility provides users with readily accessible land 

and all the necessary infrastructure and resources needed 

to rapidly and economically install their technologies. NREL 

currently leases several acres at the site. The primary projects currently being developed by NREL include:

■ Concentrator PV (CPV) Demonstration. This system will 

demonstrate and quantitatively compare performance of 

CPV systems installed in Japan and the Unites States.

■ Thermal Energy Storage (TES) Test Facility. This facility will 

provide a pilot-scale TES demonstration project. 

1.4 SITE ENVIRONMENTAL CONDITIONS/

FEATURES

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 inches). Almost 

half of the annual precipitation occurs from March to June. 

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

the fall, reaching the minimum during winter. Winter is the 

driest season, contributing less than 10% of the annual 

precipitation, primarily in the form of snowfall. 

Spring is a season of unstable air masses with strong winds 

along the foothills and the Front Range. The highest average 

snowfall 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 to10 inches). 

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.

The SolarTAC test facility in Aurora, Colorado. Photo by Dennis 

Schroeder, NREL 19110
14 ENVIRONMENTAL PERFORMANCE REPORT 2012

In 2012, there was significant construction activity on 

the STM and NWTC campuses. Several major and minor 

construction projects were underway throughout the year. 

From concept to design to occupancy, environmental stewardship is integrated into construction project management 

to deliver world-class energy performance and environmentally sensitive and sustainable buildings.

2.1 MAJOR AND MINOR CONSTRUCTION

PROJECTS

■ Construction of a new 1,800-space parking garage was 

completed in early 2012. The garage meets the parking 

needs of the increased number of staff located at the 

STM site that were recently relocated from leased space 

at the Denver West Office Park (DWOP).

■ A new south entrance to the STM site was completed, 

including a site entrance building designed to achieve 

LEED Platinum certification. The design of the south 

entrance improves traffic flow by redirecting much of the 

traffic from the east entrance, alleviating traffic pressure 

on Denver West Parkway. 

■ Construction of the Energy Systems Integration Facility (ESIF) was completed in late 2012. The 183,000-ft2

building houses about 200 researchers and has been 

submitted for LEED Platinum certification. The building 

will support: 

● High-performance computing at the one-half 

petaflop scale

● State-of-the-art electric systems simulation and 

visualization

● Component and systems testing at megawatt-scale 

power

● Integration of functioning systems with utility system 

simulations for real-time, real-power evaluation. 

■ Construction of a stormwater detention basin was 

completed to improve stormwater management from 

STM site development.

■ Additional smaller 

projects completed or 

underway included: 

■ Construction of a cafeteria at the STM site was 

completed. 

■ Improvements to 

Denver West Parkway 

were initiated.

■ Improvements to fire 

suppression systems 

were initiated at the 

Integrated Biorefinery 

Research Facility and 

west end of the STM 

campus.

2 Significant Activities in 2012

NREL’s Energy Systems Integration Facility during construction.

Photo by Dennis Schroeder, NREL 22119

Map of STM main facilities.
ENVIRONMENTAL PERFORMANCE REPORT 2012 15

■ At SolarTAC, construction of the Thermal Energy Test Site 

was completed and work on the Regional Test Center 

was started.

2.2 INTEGRATED ENVIRONMENTAL STEWARDSHIP IN CONSTRUCTION MANAGEMENT

NREL designs and builds new facilities using an approach 

that integrates planning, design, and construction. An interdisciplinary team collaborates on each project beginning 

with planning and selection of design, continuing through 

construction. This integrated approach allows the laboratory 

to achieve mission needs while addressing environmental, 

health, safety, and community considerations. 

PROJECT PLANNING AND DESIGN

Environmental management staff participate in an interdisciplinary team from a project’s initiation and continuing 

through construction. These staff assist with the development and review of Requests for Qualifications and 

Requests for Proposals (RFPs), facilitate the inclusion of environmental requirements into project designs, and monitor proposed changes throughout the project to confirm 

potential environmental impacts are considered. Some 

examples of sustainable design features used in recent 

projects include:

■ Producing energy onsite. New construction is designed 

to take advantage of the sun’s rays by using angled roofs 

and awnings that can support photovoltaic (PV) panels 

in optimal conditions. The RSF was designed to be a 

net-zero energy building, using only energy produced 

onsite. To help the RSF achieve the goal to produce as 

much energy onsite as used by the building, a 1.6 megawatt (MW) PV system was installed on the building and 

adjacent covered parking areas using a power purchase 

agreement (PPA) with Sun Edison and Xcel Energy. 

■ Heating and cooling strategies. Passive design allows 

buildings to stay cool in summer and warm in winter. 

Radiant heating and cooling use water as the cooling 

and heating medium instead of forced air. For example, 

42 miles of piping course through the RSF carrying water 

for radiant heating and cooling. Waste energy from the 

data center is reused to maximize building heating. Evaporative cooling systems supplement passive cooling. 

■ Underfloor ventilation. Demand-controlled, dedicated 

outside air systems in the RSF provide fresh air supplied 

via a raised floor distribution system. 

The new South Site Entrance Building on NREL’s STM campus is 

energy efficient, constructed mostly with recycled materials and 

features a passive cooling tower. Photo by Dennis Schroeder, NREL 

23232

The new cafeteria at the STM campus. Photo by Paul Schwabe, NREL 

23714

Construction of the new Energy Systems Integration Facility. 

Photo by Dennis Schroeder, NREL 22670
16 ENVIRONMENTAL PERFORMANCE REPORT 2012

■ Occupant-controlled windows. Operable windows in 

the RSF help reduce the use of air conditioning and give 

employees considerable control over their own comfort. 

When outdoor air conditions are temperate, employees 

are notified by automated systems on their computers 

that it’s okay to open windows. Building control systems 

automatically operate remaining windows when optimum conditions are met.

■ No- and low-volatile organic compound (VOC) materials. Only products that produce no or low amounts of 

VOCs are used in building interiors to maintain excellent 

air quality for inhabitants. Because employees spend 

most of their working hours indoors, the quality of 

indoor air is important for employee health and wellbeing. To ensure that no- and low-VOC products are used, 

products are selected from reputable, certified product 

label systems such as Green Seal, EcoLogo, and the EPA’s 

WaterSense program.

■ Daylighting and lighting management. NREL strives 

to design buildings that utilize natural lighting to the 

extreme, resulting in tremendous energy savings, as well 

as health and wellness benefits for occupants. External 

lighting using timers, motion-sensors, and downwardfacing, covered lights also minimize light pollution 

impacts on neighbors.

■ Wildlife-friendly design. Selection of wildlife-sensitive 

features helps minimize the impacts of buildings to birds 

and other animals. For example, the parking garage 

atrium, stair towers, and bus shelters have glass with 

specialized glazing designed to prevent bird collisions. 

NREL also carefully considers wildlife movement patterns 

and works to preserve existing travel zones. Wildlifefriendly perimeter fencing, for instance, allows wildlife to 

travel freely across property boundaries. 

■ Site sensitive drainage and vegetation. Design teams 

incorporate low-impact design elements to retain stormwater onsite through infiltration. Features such as bioswales, vegetated filters, and porous pavers and asphalt 

encourage stormwater and snowmelt to seep into the 

soil instead of running off. Native and drought-resistant 

vegetation and a smart irrigation system automatically 

adjust landscape watering based on plant needs and 

daily local weather conditions. Native plants are used 

because they are adapted to the local climate, can thrive 

without additional watering once established, and are 

beneficial to other native species.

ENVIRONMENTALLY RESPONSIBLE 

CONSTRUCTION PRACTICES

During construction, involved staff participate in weekly 

construction team meetings, monitor performance criteria, 

and provide ongoing feedback to the project team regarding environmental management. Some examples of environmentally responsible construction practices include: 

■ Pre-construction review of project plans. Staff conduct 

a pre-construction orientation with the project team to 

review the environmental elements of the project plan. 

■ Plan of the day. On a daily basis, subcontractors submit a 

“plan of the day” to the prime contractor the day before 

any work is performed. The prime contractor evaluates 

all plans for potential environmental and safety hazards 

and communicates these plans with all subcontractors 

on the job site. 

■ Stormwater controls. Erosion and sediment controls, 

proper chemical storage and fueling procedures, and 

good housekeeping practices are implemented during 

construction. Regular inspections by contractors and 

periodic site inspections by NREL staff are conducted 

to verify that the implemented controls are functioning 

properly. Any repairs are documented on an inspection report; prompt actions are required to correct any 

noncompliant conditions. 

■ Keeping wildlife safe. Prior to commencing construction, 

biologists conduct surveys for nesting birds and have 

the authority to delay construction or instruct workers to 

avoid sensitive areas if necessary until young birds fledge 

the nest. Areas with planned construction are mowed in 

the weeks prior to construction to discourage birds from 

nesting. When snakes are encountered they are safely 

relocated away from active construction areas.

The new stormwater detention pond regulates the flow of 

runoff from the STM campus and improves water quality. Photo 

by Dennis Schroeder, NREL 23189
ENVIRONMENTAL PERFORMANCE REPORT 2012 17

■ Waste reduction, reuse, and recycling. Construction 

contractors at NREL regularly divert close to 90% of their 

waste by recycling and reusing materials. Contractors are 

encouraged to retain materials onsite whenever possible 

to reduce transportation costs, fuel use, greenhouse 

gasses, and other air emissions. For example, excess excavated dirt is often used as fill onsite and may be shared 

between projects on campus. Instead of transporting 

excavated rock off-site, it’s used in gabion retaining walls 

as an attractive landscaping feature. 

■ Minimizing and cleaning up spills. NREL specifies that 

new or like-new equipment must be used during 

construction onsite to minimize the potential for drips, 

leaks, and spills of fuel, oil, and hydraulic fluids. When 

spills do occur, contractors are instructed to quickly stop 

the source, control spilled material, and contact NREL to 

monitor cleanup activities.

■ Dust control. Contractors must control dust to minimize impacts to neighbors and adjacent habitats. Water 

trucks are used to spray down dust prone areas, driving 

speeds are limited, and excavation during high winds 

is restricted. 

The parking structure on NREL’s STM campus includes 3,632 

photovoltaic panels installed on the roof and the south façade. 

The panels produce up to 1.15 megawatts of power. Photo by 

Dennis Schroeder, NREL 21635
18 ENVIRONMENTAL PERFORMANCE REPORT 2012

NREL’s Environmental Management System (EMS) provides 

effective environmental stewardship and minimizes the 

environmental impacts of laboratory activities and operations. The EMS is a framework of policies, procedures, and 

programs that integrates environmental protection into 

daily work practices. The laboratory’s EMS efforts:

■ Protect and enhance the vegetation, wildlife, and natural 

resources of the laboratory sites

■ Prevent pollution

■ Comply with environmental requirements

■ Encourage continual improvement in environmental 

protection and sustainability performance. 

While the EMS is managed by the Environment, Health, 

and Safety (EHS) Office, environmental protection must 

involve everyone at the laboratory to be effective. The EMS 

is implemented as part of a DOE-required Integrated Safety 

Management System (ISMS). The ISMS systematically integrates safety and environmental protection into management and work practices at all levels to protect the public, 

the worker, and the environment.

3.1 ENVIRONMENTAL MANAGEMENT SYSTEM 

STRUCTURE

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

continual improvement framework described below and 

depicted in the graphic. 

NREL conducts an annual review of its activities 

that could potentially affect the environment. The 

laboratory’s significant environmental aspects for 

2012 were:

■ Air emissions

■ Surface water or groundwater emissions

■ Wastewater releases

■ Waste generation and management

■ Resource use or conservation (energy, water, 

land, biological, cultural)

■ Community. 

Each of these aspects is addressed by the environmental management system.

Define Scope

Analyze

H

a

zards,

Perform Work

Develop Controls

Feedback &

Improvement

Environment

Quality Safety

Impacts

& Issues

NREL’s EMS is certified to the ISO 14001:2004 

standard for environmental management systems. 

ISO 14001 is a globally recognized standard that 

defines the structure of an organization’s EMS 

to improve its environmental performance. ISO 

14001 requires an organization to identify potential environmental impacts and establish controls 

needed to minimize impacts, to monitor and 

communicate environmental performance, and to 

establish a formal process for continually improving the system.

ISO 14001:2004 Certified

3 Environmental Management 

 System
ENVIRONMENTAL PERFORMANCE REPORT 2012 19

PLANNING

■ Environmental policy. NREL states its commitments to 

the environment through this overarching policy. The 

policy commits specifically to:

■ Environmental stewardship

■ Pollution prevention 

■ Compliance with legal requirements and voluntary 

commitments

■ Continual improvement of environmental and 

sustainability performance.

■ Environmental aspects. NREL’s environmental aspects 

are those activities, products, or services that have the 

potential to interact with the environment. The significance of an identified aspect is determined by assigning a frequency of occurrence and a severity. Using this 

method, EHS staff review potential impacts to the environment annually and activities in the EMS are prioritized 

by the identified significant aspects. NREL also utilizes a 

robust hazard identification and control process as part 

of its ISMS to manage environmental risks. 

■ Legal and other requirements. NREL maintains a formal 

process to identify regulations and standards that are 

necessary and sufficient to address specific environmental hazards, including federal laws and regulations, 

state and local requirements, executive orders, and 

DOE requirements.

■ Objectives and targets. Regular planning of activities and 

programs are necessary to achieve NREL’s environmental 

goals. The EHS Office and Sustainable NREL plan, implement, monitor, and report on environmental stewardship 

goals and actions to generate continual improvement 

(for more details, see section 3.2 Performance Indicators 

and Progress).

IMPLEMENTATION

■ Structure and responsibility. NREL policies and procedures establish roles and responsibilities for environmental management within the organization.

■ Competence, training, and awareness. NREL verifies 

that workers are competent on the basis of education, 

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

■ Communication. NREL provides a number of avenues 

for communication between the laboratory and the 

community, such as community meetings, lunch-andlearn events, public-facing websites, periodic newsletters, and mailings. NREL tracks and responds to all environmentally related concerns through the Public Affairs 

Office. Internal communication regarding environmental 

issues is provided via intranet sites, newsletters, emails, 

meetings, posters, trainings, and personal interaction 

with EHS workers.

■ Operational control. NREL plans and manages operations 

and activities in line with its environmental policy and 

objectives. Staff continually identify and review activities 

that could impact the environment, and engineering 

and administrative controls are put in place to minimize 

or avoid impacts to the environment. 

■ Document and record control. Policies and procedures 

ensure that the current, correct versions of documents 

are available for use and that records are maintained to 

meet requirements. 

CHECKING AND CORRECTIVE ACTION

■ Monitoring, measuring, and evaluating compliance. NREL 

monitors key activities, tracks performance and progress 

toward environmental objectives, and conducts periodic 

assessments of compliance with legal requirements.

■ Internal assessment. NREL periodically conducts assessments to verify that its EMS is operating as intended. 

A formal system for tracking corrective and preventive actions supports continual improvement of the 

management system (for details, see section 3.3 Assessment and Improvement).

An Earth Week nature walk along Lena Gulch. Photo by Dennis 

Schroeder, NREL 20508
20 ENVIRONMENTAL PERFORMANCE REPORT 2012

MANAGEMENT REVIEW

■ Management Review. NREL conducts regular management reviews of the EMS so that executive management 

can provide feedback and direction to the environmental 

management of the organization.

3.2 PERFORMANCE INDICATORS AND 

PROGRESS

Each year, measurable objectives and targets for environmental improvement are set. Goals are set through several 

mechanisms including:

■ Performance Evaluation Measurement Plan (PEMP). Each 

fiscal year, in collaboration with the DOE Golden Service 

Center, performance objectives are developed for the 

upcoming year.

■ Colorado Environmental Leadership Program (CELP). As 

a member of CELP, NREL voluntarily sets three-year goals 

for environmental improvement. Each year, progress 

toward these goals is reported to the state. 

■ Site Sustainability Plan (SSP). For 2012, Sustainable NREL 

developed an SSP to establish sustainability performance commitments for 2012 and document activities 

in support of Executive Order (EO) 13514 requirements. 

Results of the 2012 plan are presented in the next chapter of this report. 

Goals are owned by individuals and groups throughout the 

laboratory, including the EHS Office and Sustainable NREL. 

Progress through the course of the year on each of these 

goals is tracked using an online software tracking system 

and results are reported annually. Some examples of performance for 2012 are described in the 2012 Environmental 

Objectives and Achievements table.

For Fiscal Year 2013, NREL’s environmental and sustainability 

objectives under the PEMP are: 

■ Maintain a safe and healthful workplace based on identified and managed risks

■ Further ISM through development of improved management systems

■ Further leadership in sustainable science and laboratory 

operations.

3.3 ASSESSMENT AND IMPROVEMENT

Assessments are key to supporting the continual improvement of environmental management. Periodic assessment 

of the EMS and its components provide assurance that the 

EMS continues to be an effective tool to achieve and maintain compliance with regulatory and legal requirements, 

meet the established environmental goals of the laboratory, 

and demonstrate to ourselves and others that we are “walking the talk.” 

There are three different types of assessments performed to 

evaluate the functionality of NREL’s EMS: 

■ Internal assessment. Staff perform regular internal 

assessments of the EMS against the ISO 14001 standard. 

The scope of internal assessments includes both the 

management of significant environmental aspects (areas 

where NREL’s activities have the potential for environmental effects, either positive or negative) and policy 

implementation. 

■ External assessment. Periodically, external third-party 

assessments may be conducted by technical experts for 

specific components of environmental programs or for 

the EMS as a whole. These assessments are conducted as 

a part of continual improvement efforts and to maintain 

ISO certification. 

2012 Highlights and Achievements

■ In 2012, NREL maintained its ISO 14001:2004 

certification. In July, a team of external auditors conducted an independent assessment of 

the policies, procedures, tools, and roles and 

responsibilities used in environmental management. The assessment verified that the laboratory continues to meet the requirements of 

the ISO 14001 standard and demonstrates our 

commitment to environmental stewardship.

■ Several internal assessments of environmental 

management programs were conducted and 

identified areas for continual improvement 

(for details, see section 3.3 Assessment and 

Improvement). 

■ The laboratory’s policies and procedures for 

managing its EMS and its ISMS were combined 

to eliminate redundancy, reduce unnecessary 

procedures, and better coordinate management of the systems.

■ The 2011 version of this report was redesigned 

to improve communication with external 

stakeholders and the general public regarding 

environmental compliance and leadership in 

environmental management. 
ENVIRONMENTAL PERFORMANCE REPORT 2012 21

2012 ENVIRONMENTAL OBJECTIVES AND ACHIEVEMENTS

Goal 

Type 2012 Objectives 2012 Achievements Objective Met?

PEMP Maintain a safe and healthful workplace 

based on identified and managed risks.

•	 EHS procedures enhanced as part of continual improvement.

•	 Coordinated activities with Jefferson County to improve off-site

stormwater discharge.

•	 Inspections conducted for registered/ permitted equipment to verify

items are installed as ordered.

•	 Weekly environmental walks and construction project team

participation drove strong environmental performance (stormwater, 

spill control, wildlife protection, etc.).

Yes

PEMP Further Integrated Safety Management 

(ISM), which includes environmental 

stewardship, through development of 

improved management systems.

•	 Completed internal EMS assessments of two environmental

programs: EPCRA Reporting and Ozone-Depleting Substances (ODS) 

Management.

•	 Completed all corrective actions and 12 opportunities for improvement

from 2011 ISO/OHSAS certification assessment.

•	 Maintained ISO 14001 and OHSAS 18001 certifications.

Yes

CELP To reduce the impacts of employee 

commuting by reducing individual 

vehicle miles travelled and to implement 

a traffic mitigation plan for the STM site—

including Alternative Work Schedules 

(AWS) and telecommuting.

•	 Throughout 2012, traffic monitoring and intersection analysis indicated

that NREL-generated traffic volumes and levels of service remained 

within acceptable levels.

•	 The completion of the new south entrance and roadway from South

Golden Road to the STM site in May 2012 decreased traffic volumes 

accessing the east and west entrances and reduced NREL’s traffic 

impacts at nearby off-campus intersections. 

•	 NREL offers incentives for employees to participate in alternative

commuting options such as access to mass transit, vanpool discounts, 

preferred parking for carpool/vanpool vehicles, rideshare coordination, 

and bicycle and pedestrian infrastructure (bicycle maintenance 

stations, bicycle parking, extension of sidewalks, etc.).

Yes

CELP To support NREL’s long-term goal of 

achieving a net-zero energy campus 

by seeking to reduce electricity use per 

square foot by 3% per year, starting with a 

2008 baseline.

•	 In 2012, NREL exceeded its goal of 3% per year reduction in energy use

per square foot. The reduction was largely due to the addition of a new 

wing to the Research Support Facility (RSF) which increased square 

footage with only a small increase in site energy consumption.

Yes

CELP To implement measures at the RSF to 

seek certification in the Sustainable 

Sites Initiative (SITES) Pilot Program on 

Landscaping Green Certification for 

Sustainable Landscaping.

•	 Based on lessons learned from previous re-vegetation efforts,

landscaping plans for current construction projects were adjusted 

to optimize plant establishment, withstand difficult shading and 

snow conditions, and deter animal browsing while providing wildlife 

habitat (i.e., spaces for nesting birds, plants for pollinators such as 

hummingbirds, and protective cover for other species).

•	 A “snow push map” was developed to ensure that snow and deicer

materials would be pushed to areas where on-site vegetation would 

not be adversely impacted.

•	 A weed identification handbook was prepared to assist maintenance

personnel in identifying weeds to be hand-pulled from newly 

landscaped areas. 

Yes
22 ENVIRONMENTAL PERFORMANCE REPORT 2012

■ Evaluation of compliance. Periodic internal environmental compliance evaluations are conducted to verify that 

activities meet all applicable legal and other requirements. Improvements are developed and implemented 

as necessary based on the results of each evaluation. 

2012 ASSESSMENTS

In 2012, a number of assessments were conducted, allowing 

NREL to focus on finding areas of continual improvement, 

improve program effectiveness, and make substantial environmental performance improvements.

The following assessment activities took place in 2012:

■ Internal assessments. In January 2012, an internal assessment was conducted of the laboratory’s Emergency 

Planning and Community Right-to-Know Act (EPCRA) 

reporting. Scheduled interviews were conducted 

and reviews of relevant procedures and records were 

completed. One opportunity for improvement was identified and has been addressed.

In February 2012, an internal assessment was conducted 

of the laboratory’s Ozone-Depleting Substances (ODS) 

Program. Scheduled interviews were conducted and 

reviews of relevant procedures and records were 

completed. Four non-conformities with program 

requirements and five opportunities for improvement 

were identified. Corrective actions in the areas of record 

control and operational control were implemented to 

address each non-conformity. 

■ Evaluations of compliance. In May 2012, an internal evaluation of compliance was conducted to verify compliance 

with environmental legal and other requirements applicable to the laboratory across a sampling of activities and 

programs for 2011. 

The review included compliance with federal, state, and 

local regulatory deliverables and DOE requirements 

including permits, equipment registrations and certifications, reports, and notifications. The review also evaluated NREL’s completion of requirements by environmental program area, including requirements for inspection, 

monitoring, training, certifications, etc. Environmental 

areas reviewed included:

● Construction Stormwater Management

● EPCRA Reporting

● ODS Management

● EMS

● Environmental and Sustainability Management

● Regulated Waste

● NEPA.

Three areas of potential non-compliance with regulatory 

requirements were identified and have been addressed, 

including late payment of hazardous waste fees for 

the STM, incomplete records of service for equipment 

containing 50 or more pounds of ODSs, and failure to 

complete several hazardous waste satellite accumulation 

area inspections.

■ External assessments. In 2012, NREL maintained its certification under ISO 14001. In July, the laboratory received a 

third-party surveillance assessment to confirm continued 

conformance with the standard. The assessment was 

conducted by a team of auditors and included visits to 

a sampling of the lab’s facilities, interviews with staff at 

all levels of the organization, observations of processes 

in place, and reviews of documents and records. The 

assessment resulted in two findings and several opportunities for improvement. Corrective actions have been 

completed to address deficiencies in document control 

and record control. 

3.4 2012 AWARDS AND RECOGNITION

In 2012, NREL received several awards and recognition of its 

environmental and sustainability achievements including:

■ DOE Sustainability Award

■ DOE Green Buy Program Gold Award

■ Federal Electronics Challenge (FEC) Platinum Award

■ CELP Gold-level Leader.

DOE SUSTAINABILITY AWARD

In 2012, the laboratory received a DOE Sustainability Award 

for its nomination “Comprehensive Energy Management 

Plan.” DOE Sustainability Awards highlight environmental sustainability projects and programs within the DOE 

complex that reduce environmental impacts, enhance site 

operations, reduce costs, and demonstrate excellence

in pollution prevention and sustainable environmental 

stewardship. 

DOE GREEN BUY PROGRAM GOLD AWARD

In 2012, NREL received a DOE Green Buy Program Gold 

Award for purchasing 17 products in five different categories, achieving DOE’s Green Buy leadership goal.

FEC PLATINUM AWARD

In 2012, the laboratory achieved the platinum-level FEC 

Award. FEC is a partnership program between the Office of 

the Federal Environmental Executive and the EPA. The FEC 

recognizes federal facilities that voluntarily:

■ Purchase greener electronic products

■ Reduce impacts of electronic products during use
ENVIRONMENTAL PERFORMANCE REPORT 2012 23

■ Manage obsolete electronics in an environmentally 

safe way. 

Learn more about this voluntary program at the FEC website 

at http://www.epa.gov/fec/.

CELP GOLD-LEVEL LEADER

In 2012, NREL maintained its status as a CELP Gold-level 

Leader. CELP is a voluntary partnership between the Colorado Department of Public Health and Environment (CDPHE) 

and participating private and public Colorado facilities, and 

is intended to recognize environmental leadership and 

performance. 

In early 2004, NREL was the first laboratory accepted into 

CELP as a Gold-level Leader and has maintained this leadership level ever since. As a component of CELP membership, 

the laboratory’s voluntary environmental performance 

goals, described above, further enhance operations and 

performance at the laboratory. CELP recognizes facilities that 

voluntarily:

■ Exceed regulatory requirements

■ Implement EMS (which focus on incorporating environmental considerations into normal management processes and improving internal environmental management 

effectiveness)

■ Work closely with their communities

■ Establish three-year goals focusing on measurable results.

Learn more about this voluntary program at the CDPHE 

CELP website: http://www.colorado.gov/cs/Satellite/CDPHEDEHS/CBON/1251583700741. 

Benefits of NREL’s EMS

Mission. NREL’s EMS supports the organization’s overall 

mission and improves effectiveness by systematically 

addressing environmental opportunities and risks, ensuring 

compliance with regulations, and implementing voluntary 

commitments to achieve superior performance.

Environmental and sustainability performance. While 

the laboratory benefits as an organization from each of the 

efforts highlighted here, the larger benefit is in reduced 

impacts to the quality of the air, water, land, and to the flora 

and fauna that share the campus and community. 

Reduced risk. NREL’s Hazard Identification and Control 

Program incorporates environmental risk assessment.

Cost savings. Cost savings are realized through energy 

efficiency projects, new renewable energy installations, 

and waste reduction and recycling. Any avoided impact 

represents cost savings, specifically in the event of spills 

and accidents.

Environmental awareness. Staff are made aware of the 

potential environmental impacts from their work activities 

through the NREL Now internal newsletter, postings on 

the NREL intranet, new employee orientation and activity 

specific trainings, policies and procedures, management 

communications, Sustainable NREL communications, and 

special events such as Staff Awards (an annual employee 

recognition event), Earth Day, and Bike 2 Work Day.

Empowered individuals. Staff are empowered to reduce 

the lab’s environmental footprint by participating in 

programs and events for recycling single-stream materials, batteries, electronic equipment, and shredded paper, 

as well as a composting program. For example, staff at the 

RSF support the energy efficiency goal for the building by 

reducing their energy use in the office. 

Organizational culture and operations. NREL strives 

to maintain a high level of awareness in the laboratory 

around safety, health, and environmental responsibilities. 

This is accomplished through a variety of means, including 

regular communications from executive management. In 

addition, daily EHS interaction with lab and operations staff 

at the ground level in trainings, inspections, and risk assessments drives awareness.

Community relations. The laboratory works to improve 

community relations by responding to and tracking all 

community input through phone calls, email, community meetings, and soliciting feedback from stakeholders 

through the NEPA process. NREL takes proactive measures 

to engage the community with public tours, newsletters, 

and mailings to neighborhoods surrounding its facilities.

Cooperative conservation. NREL regularly works with 

stakeholders to improve the community. For example, with 

the growth of the STM site, NREL monitors traffic to minimize impacts to the surrounding community.
24 ENVIRONMENTAL PERFORMANCE REPORT 2012

Sustainable NREL is a long-standing laboratory program 

that fosters environmental and social responsibility, working to establish the lab as a global model for sustainability. 

Sustainable NREL advocates for all executive orders, federal 

regulations, DOE orders, and goals related to sustainable 

facility operations. The program also executes specific goals 

to reduce impacts on the community and environment, 

and provides technical expertise to organizations within the 

lab. Sustainable NREL provides leadership within the federal 

government and the community by actively mentoring and 

collaborating with other organizations to move sustainability 

into a new paradigm. NREL’s campus is a living laboratory 

that showcases new technologies, design practices, and 

operating behaviors. In all campus development, opportunities to integrate energy efficiency and renewable energy, 

high-performance buildings, and sustainable transportation 

options are sought. On-site deployment of technologies 

developed by NREL researchers is also emphasized.

NREL integrates sustainability into its EMS. Technical experts 

from Sustainable NREL and the EHS Office work together 

regularly to improve operations and implement programs, 

including:

■ Site sustainability and pollution prevention data tracking 

and reporting to DOE

■ Sustainability and environmental management planning

NREL offers secure electronics recycling and document 

shredding/recycling for NREL employees during Earth Week.

Photo by Dennis Schroeder, NREL 18885

Composting food waste at the cafeteria. Photo by John De La Rosa, 

NREL 24352

4 Sustainability

2012 Highlights and Achievements

■ NREL completed construction of four new high 

performance sustainable buildings and three 

on-site renewable systems in FY 2012. 

■ Achieved LEED (Leadership in Energy and Environmental Design) Platinum certification from the U.S. 

Green Building Council for the new wing of the 

net-zero energy Research Support Facility (RSF)

■ Completed the net-zero energy parking garage 

designed to the LEED Platinum rating

■ Completed the net-zero energy Southern Site 

Entrance Building (SSEB); LEED Platinum certification anticipated

■ Completed the cafeteria; LEED Gold certification 

anticipated

■ Deployed new on-site renewable energy systems 

including:

● 15.28 kW PV array on rooftop of the SSEB

● 408 kW PV array on rooftop of the new wing of 

the RSF

● 1130 kW PV array on rooftop and southern 

façade of the parking garage.
ENVIRONMENTAL PERFORMANCE REPORT 2012 25

■ Measurement and tracking of environmental objectives, 

targets, and actions

■ Pollution prevention assessments and improvements

■ Awareness and engagement of staff and community 

members.

4.1 SITE SUSTAINABILITY PLANNING

Executive Order (EO) 13514, Federal Leadership in Environmental, Energy, and Economic Performance, specifies environmental sustainability performance goals for federal agencies. DOE O 436.1, Departmental Sustainability, implements 

the requirements of the executive order for DOE. Each year 

DOE prepares a Strategic Sustainability Performance Plan 

(SSPP) that describes how the department will meet the 

requirements of EO 13514 and DOE O 436.1. Each DOE 

facility must then develop an annual SSP. Each site’s plan 

is used to report on steps taken to meet the national and 

DOE sustainability objectives and also outlines plans for the 

upcoming year. 

The following content has been extracted from NREL’s SSP 

for Fiscal Year (FY) 2013. The full report is located online at 

www.nrel.gov/sustainable_nrel/.

SITE MANAGEMENT VISION

NREL is a state-of-the-art laboratory that supports innovative 

research, development, and commercialization of renewable energy and energy efficiency technologies that address 

the nation’s energy and environmental needs. Fundamental 

to the laboratory’s mission is a commitment to sustainability—operating in a manner that balances environmental, 

economic, and social values in the delivery of the mission. 

At NREL, sustainability is integral to both research and 

operations. The laboratory is committed to demonstrating 

federal leadership in sustainability, working to continuously 

improve performance, and leading by example.

MAJOR PLANNING ASSUMPTIONS, ISSUES, 

FUNDING STRATEGIES

In recent years, NREL has experienced robust growth. In FY 

2003, the lab’s population was 1,132 and building square 

footage was 405,367. In FY 2012, the lab’s population was 

2,447 and building square footage was 946,625, as reported 

in the Consolidated Energy Data Report. The percentage 

increase was 116% for population and 134% for building 

square footage. Although NREL is experiencing growth, 

in the current economic climate it is unclear if this trend 

will continue. While there is no new construction line item 

funding identified at this time, planning activities are being 

conducted so that the laboratory is positioned to accommodate future growth through the construction of new 

high-performance buildings, energy efficiency retrofits, and 

renewable energy systems that take advantage of alternative 

financing mechanisms, including power purchase agreements, energy savings performance contracts, partnerships 

with energy service companies, and cooperative research 

agreements. NREL continues to review the use of overhead 

funds, cost savings reinvestment, and leveraging of alternative financing methods for retrofits or new projects. 

4.2 2012 SSPP GOAL PERFORMANCE

The following table summarizes each of DOE’s SSPP goals 

and NREL’s performance status. For more specific information, please refer to the full SSP referenced.

Aerial view of the RSF. Photo by Dennis Schroeder, NREL 21794
26 ENVIRONMENTAL PERFORMANCE REPORT 2012

NREL’S PERFORMANCE STATUS TOWARD DOE SSPP GOALS

SSPP 

Goal # DOE SSPP Goal NREL Performance Status in FY 2012

1.1 28% greenhouse gas (GHG) reduction from sources 

such as heating, cooling, and electricity use by FY 

2020 from a FY 2008 baseline.

On Track: Reduced emissions 84% from the 2008 baseline (including 

renewable energy certificates).

1.2 13% GHG reduction from sources such as air travel 

and commuting by FY 2020 from a FY 2008 baseline.

Challenge: Emissions from these sources increased 12% from the 2008 

baseline. To support NREL’s mission, air travel is necessary. While on a per 

capita basis, NREL will meet the reduction goal; the absolute reduction 

from the 2008 baseline will be challenging due to population growth.

2.1 30% building energy use per square foot reduction 

by FY 2015 from a FY 2003 baseline.

On Track: Decreased 29% since 2003.

2.2 Energy and water audits. Goal Met: Performed energy and water audits on three buildings that 

represent 50% of total site energy use in FY 2012.

2.3 Individual buildings or processes metering for 90% 

of electricity (by October 1, 2012); for 90% of steam, 

natural gas, and chilled water (by October 1, 2015).

On Track: 100% of NREL’s electricity, hot and chilled water was metered in 

FY 2012. In addition, 95% of natural gas was metered in FY 2012.

2.4 Energy efficient cool roofs, unless uneconomical, for 

roof replacements.

Goal Met: 59% of NREL campus has cool roofs, an 11% increase from 

FY 2011.

2.5 15% of existing buildings greater than 5,000 gross 

square feet (GSF) are compliant with the federal 

green building standards by FY 2015.

On Track: 18% of buildings meet federal green building standards.

2.6 All new construction, major renovations, and 

alterations of buildings greater than 5,000 GSF must 

comply with federal green building standards and 

where the work exceeds $5 million, each are LEED – 

New Construction Gold certification or equivalent.

Goal Met: Received LEED Platinum certification for the new wing of the RSF.

2.7 7.5% of annual electricity consumption from 

renewable sources by FY 2013 and thereafter (5% FY 

2010 – FY 2012).

Goal Met: 18.8% of NREL’s total power comes from on-site sources.

3.1 10% annual increase in fleet alternative fuel 

consumption by FY 2015 relative to a FY 2005 

baseline.

On Track: Alternative fuel use has grown 135% since 2005.

3.2 2% annual reduction in fleet petroleum 

consumption by FY 2020 relative to a FY 2005 

baseline.

Challenge: Overall petroleum fuel usage has grown 55.9% since 2005 

with a slight decline in FY 2012. Disposition of low-mileage, alternative 

fuel vehicles to meet the Secretary’s vehicle reduction goal increased 

petroleum use. Lack of E85 fueling stations in proximity to the NWTC 

makes using alternative fuels a challenge at that site.

3.3 100% of light duty vehicle purchases must consist 

of alternative fuel vehicles by FY 2015 and thereafter 

(2000-2015).

Not Applicable: No light-duty vehicles purchased in FY 2012.
ENVIRONMENTAL PERFORMANCE REPORT 2012 27

NREL’S PERFORMANCE STATUS TOWARD DOE SSPP GOALS

SSPP 

Goal # DOE SSPP Goal NREL Performance Status in FY 2012

3.4 Reduce fleet inventory of non-mission critical 

vehicles by 35% by 2013 relative to a FY 2005 

baseline.

Goal Met: To date, NREL has reduced fleet inventory by 8 vehicles.

This reduction represents 100% of the planned fleet reduction of 

non-mission critical vehicles.

4.1 26% potable water intensity (gallons per gross 

square foot) reduction by FY 2020 from a FY 2007 

baseline 

Challenge: Reduced water intensity by 30% from FY 2007 baseline. To make 

ESIF the world’s most energy efficient data center, a large amount of water 

will be needed for cooling, offsetting electricity use.

4.2 20% water consumption reduction of industrial, 

landscaping, and agricultural water by FY 2020 from 

a FY 2010 baseline.

Not Applicable: NREL does not use industrial, landscaping, and agricultural 

water.

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

excluding construction and demolition debris, by

FY 2015.

On Track: Diverted 81% of campus waste from landfill.

5.2 Divert at least 50% of construction and demolition 

materials and debris by FY 2015.

On Track: Diverted 88 % of construction waste from landfill.

6.1 Procurements meet sustainability requirements 

and include sustainable acquisition clause (95% 

each year).

On Track: Finalized and implemented a general procurement policy, as well 

as small purchase and purchase request procedures.

Hosted a series of meetings to increase the visibility of green officesupply product selection with staff and provided education on preferred 

purchasing procedures.

Collaborated with NREL’s preferred office supply company to host a green 

office supply fair featuring new product vendors and technologies for staff.

Implemented the green cleaning janitorial contract campus wide and 

conducted audits.

7.1 All data centers are metered to measure energy 

efficiency by FY 2015.

On Track: The RSF data center measures monthly energy efficiency.

7.2 Maximum annual weighted average energy 

efficiency rating (Power Usage Effectiveness) of 1.4 

by FY 2015.

On Track: Energy efficiency rating for the RSF data center is 1.13.

7.3 Electronic Stewardship – 100% of eligible PCs, 

laptops, and monitors with power management 

actively implemented and in use by FY 2012.

Goal Met: Power management is enabled on 100% of devices.

8.0 Innovation and Government-wide support – 

site-specific objectives.

Goal Met: Enhanced the RSF “behavior agent” software program which 

collects information on employee comfort.

Entered into discussions to establish a power purchase agreement to 

obtain power from a 30 MW off-site wind farm.

Continued outreach to encourage knowledge sharing with federal 

agencies and local governments (NASA, DOE, GSA, and City of Lakewood).

Hosted more than 40,000 visitors to the RSF, showcasing energy efficiency 

in design and management; provided workshops to commercial industry 

and other government agencies.
28 ENVIRONMENTAL PERFORMANCE REPORT 2012

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & 

Requirement

Air Quality The Colorado Department of Public 

Health and Environment (CDPHE) 

administers the Clean Air Act 

implementing regulations for all point 

sources (facilities or other types of 

operations) in Colorado, under authority 

delegated by the U.S. Environmental 

Protection Agency (EPA). Several main 

categories for air pollutants are regulated: 

criteria air pollutants, non-criteria 

pollutants, hazardous air pollutants (HAPs), 

and ozone-depleting substances.

EPA regulation 40 CFR 82, Protection 

Of Stratospheric Ozone, requires that 

servicing records must be kept for 

appliances containing more than 50 

pounds of Class 1 or 2 ODS refrigerant.

CDPHE regulations require federal, state, 

and local government facilities to track 

street sanding in the wintertime, and 

to minimize sand use with the goal of 

reducing particulate pollution in the 

Denver area.

EPA regulations require that certain 

facilities which emit GHG emissions track 

and report the amount of those emissions. 

Reporting and permitting of GHGs is 

required under the EPA Prevention of 

Significant Deterioration regulation, 

Title V Tailoring Rule, and the EPA GHG 

Mandatory Reporting Rule.

All program activities were in compliance with requirements.

NREL did not exceed any air permit standard or other air regulatory 

requirement at any facility.

Completed an evaluation of NREL’s compliance with the EPA and the Air 

Pollution Control Division (APCD) of CDPHE permitting and emissions 

control requirements. It was confirmed that NREL is in compliance with 

all Colorado and EPA permit requirements and that all facilities and 

individual permitted equipment items are classified as minor sources.

Obtained an air permit for a standby electrical generator necessary 

for the newly constructed Energy Systems Integration Facility (ESIF). 

Performed emission testing and submitted necessary forms to the 

APCD to convert construction permits to final air permits for two 

emergency generators and an ammonia scrubber and particulate 

baghouse. Five Air Pollutant Emission Notices were filed with the 

APCD for the planned installation of permit exempt sources at ESIF, 

Solar Technology Acceleration Center (SolarTAC), and National Wind 

Technology Center (NWTC) Building 258. Annual emission fees for all 

existing permits were submitted to the APCD.

All required registrations were completed for equipment containing 

ozone-depleting substances. NREL facilities servicing refrigeration 

equipment were registered. Confirmed that all NREL refrigeration 

service personnel have obtained the EPA and Colorado required 

training and certification.

The required annual street sanding report was provided to the APCD 

and Jefferson County.

Evaluated NREL’s 2012 Carbon Dioxide Equivalent (CO2e) and 

greenhouse gas (GHG) emissions. The GHG inventory shows that GHG 

emissions are below the threshold for EPA reporting and permitting 

rules. The laboratory’s CO2e inventory for EPA reporting purposes is 

6,962 U.S. tons (6,316 metric tons) for the South Table Mountain (STM) 

site and 167 U.S. tons (151 metric tons) for the NWTC site. GHG emissions 

for the STM were 6,904 U.S. tons (6263 metric tons) and 166 U.S tons (151 

metric tons) for the NWTC.

EPA:

40 Code 

of Federal 

egulations

 (CFR) 82 

CDPHE:

5 Colorado 

Code of 

egulations 

(CCR) 1001-18, 

Reg. 16

5 Compliance Summary

NREL is subject to many federal, state, and local environmental laws and regulations, as well as executive orders and 

U.S. Department of Energy (DOE) orders, and memoranda of 

understanding with government agencies. NREL continues 

its excellent record of environmental compliance. 

In 2012, NREL received no violation notices from any regulatory agency. All required permits were received or renewed, 

required registrations were completed, and required notifications and reporting were submitted. 

There was one spill at the National Wind Technology Center 

(NWTC) which required reporting to the state during 2012. 

An open valve located within the elevated nacelle of a wind 

turbine leaked approximately 90 gallons of synthetic lubricant 

oil. No contamination of a waterway occurred and the spill 

was remediated.

In August 2012, a sample collected from the NWTC drinking 

water system indicated the Maximum Contaminant Level 

(MCL) was exceeded for haloacetic acids, a class of disinfection 

byproducts. Increased monitoring has indicated that haloacetic acids levels have been consistently below the MCL since 

this single exceedance. 

The table titled Federal, State, and Local Environmental 

Laws and Regulations Applicable to NREL includes a brief 

description of the statute or regulation and how compliance 

requirements were met this year. More detailed information for each area of compliance is found in the referenced 

sections of this report. For information on required permits, 

registrations, and notifications, see Appendix C.
ENVIRONMENTAL PERFORMANCE REPORT 2012 29

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & 

Requirement

Drinking 

Water 

Quality

The Safe Drinking Water Act (SDWA) establishes minimum 

drinking water standards and monitoring requirements for 

drinking water supplies. Drinking water quality is regulated 

for all public water suppliers in Colorado by CDPHE, under 

authority delegated by

the EPA..

The NWTC drinking water system is subject to the 

regulatory requirement. In 2012, the Maximum 

Contaminant Level (MCL) was exceeded for haloacetic 

acids, a class of disinfection byproducts (DBPs). The 

annual sample collected in August measured 69.4 

ppb, which exceeded the maximum of 60 ppb. In 

such circumstances, the state requires increased 

monitoring; sample frequency was increased to 

quarterly, starting in October and continuing into 

2013. Monitoring has since indicated that haloacetic 

acids levels have been consistently below the MCL 

since this single exceedance. Prior to this single 

exceedance, the NWTC had not exceeded any of the 

SDWA’s MCLs in the past five years.

All other monitored parameters in 2012 met 

applicable SDWA requirements.

The state conducted a sanitary survey of the drinking 

water system in 2012 and found no non-conformities 

with program or regulatory requirements. Several 

recommendations for program improvements were 

made, each of which is being addressed.

EPA:

40 CFR 

141–149

CDPHE:

5 CCR 1003-1

Groundwater 

Quality

Colorado groundwater quality standards are established 

by CDPHE. Permits for groundwater wells are issued by the 

Colorado Department of Natural Resources (DNR).

There are no compliance activities associated with the 

NREL Groundwater Program. There is one closedloop geothermal system at the STM Solar Radiation 

Research Laboratory installed in 2009 and another at 

the South Site Entrance Building installed in 2012. The 

installations were completed in accordance with state 

requirements. 

NREL currently has five permitted monitoring wells at 

the STM site. The wells are not currently used for 

monitoring activities.

CDPHE:

5 CCR 1002-41

2 CCR 402-7

Surface 

Water 

Quality

Construction-related stormwater discharge regulations are 

administered by the EPA at federal facilities in Colorado. 

Non-federal facility construction-related stormwater 

discharges in Colorado are regulated by the Water Quality 

Control Division of CDPHE. 

All program activities were in compliance with 

requirements. 

Permit coverage was obtained under the new 2012 

EPA CGP for six construction projects at STM, and 

two at the NWTC. In addition, one EPA Low Erosivity 

Waiver was obtained at the STM site for a project 

constructed during low precipitation months. Two 

permits were terminated in 2012.

State stormwater permits were obtained for 

construction of two new experimental research 

projects at the SolarTAC site. Because these projects 

exist off federal property, rather than EPA permits, 

Colorado Discharge Permit System construction 

stormwater permits were required. 

Construction sites received periodic monitoring 

from local regulatory officials; no non-compliances 

were noted.

EPA:

40 CFR 122.26

CDPHE:

5 CCR 1002-61

Reg. 61
30 ENVIRONMENTAL PERFORMANCE REPORT 2012

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & Requirement

Wastewater 

Management

The federal Clean Water Act (CWA) and Colorado Water 

Quality Control Act regulations apply to wastewater 

management at NREL’s STM and Denver West Office Park 

(DWOP). The Metro Wastewater and Reclamation District 

manages wastewater for much of the Denver metro area, 

receiving wastewater from a number of smaller wastewater 

districts, including the Pleasant View Water and Sanitation 

District.

Inspection and permitting of individual sewage disposal 

systems have been delegated to Jefferson County by 

CDPHE.

All program activities were in compliance with 

requirements.

The laboratory worked with the Pleasant View 

District on several large-volume discharges related 

to construction activities. Water lines included in 

new construction must be sanitized prior to use and 

these lines were disinfected and the water used in 

that process was discharged with Pleasant View’s 

approval. Large flows over small time periods can 

be problematic to sanitary collection systems, so 

the laboratory worked with the district to minimize 

potential impacts to their system.

EPA:

40 CFR 122-136

CDPHE:

5 CCR 1002-31

Hazardous 

Materials 

Management

Executive Order (EO) 13423 outlines requirements for 

Superfund Amendments and Reauthorization Act (SARA) 

Title III, EPCRA compliance, and Toxic Release Inventory 

reductions for DOE facilities. 

Annual hazardous material permits are required by West 

Metro Fire Rescue for the STM and DWOP sites. ReFUEL, 

located within the City and County of Denver, is subject 

to the Denver Fire Dept. Hazardous Materials Information 

System requirements, including permitting, inventory, and 

annual inspection. 

All program activities were in compliance with 

requirements. There were no releases of hazardous 

materials requiring reporting.

In early 2012, NREL submitted a Tier II report to 

CDPHE for reporting year 2011, identifying diesel fuel, 

petroleum oil and sulfuric acid in lead-acid batteries. 

Toxic Release Inventory reporting under EPCRA was 

not required by NREL for reporting year 2011.

West Metro Fire Rescue conducted an annual 

hazardous material inspection and issued permits 

for all major research facilities on the STM site. The 

inventory of materials at the ReFUEL facility was 

provided to the Denver Fire Department.

EPA:

40 CFR 355,

370, 372

Regulated 

Waste

 Management

The Resource Conservation and Recovery Act established 

requirements for the management of regulated waste. 

In Colorado, CDPHE administers waste regulations under 

authority delegated by the EPA.

All program activities were in compliance with 

requirements.

NREL holds five EPA hazardous waste generator 

identification numbers, one for each of its sites. All 

regulatory notifications were updated and applicable 

waste generator fees were paid for five NREL facilities 

in calendar year 2012. 

Despite three calendar months of hazardous waste 

generation at volumes totaling more than 1,000 

kilograms per month between July and September 

2012, the STM facility downgraded its waste generator 

status from a Large Quantity Generator to that of a 

Small Quantity Generator in October 2012. Four NREL 

facilities are categorized as conditionally exempt small 

quantity generators.

The laboratory submitted the required Resource 

Conservation and Recovery Act Biannual Hazardous 

Waste Report to CDPHE HMWMD in March 2012.

40 CFR 260— 

280

CDPHE:

6 CCR 1007-3

Aboveground

storage Tank

Management

ASTs are regulated in Colorado by the Colorado Department 

of Labor and Employment (CDLE) Oil Inspection Section 

under the Colorado AST regulation 7 C.C.R. 1101-14. Colorado 

requires that ASTs 660 gallons or larger be permitted prior to 

installation and registrations submitted annually.

All program activities were in compliance with 

requirements.

No spills or releases from NREL’s ASTs or related fueling 

activities occurred. 

Two AST installation permits were obtained.

CDLE:

Division of Oil 

and Public 

Safety (DOPS) 

Storage Tank 

Regulations,

7 C.C.R. 1101-

14
ENVIRONMENTAL PERFORMANCE REPORT 2012 31

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & Requirement

Spill 

Prevention 

and 

Response

Spill prevention, control, and countermeasures (SPCC) 

plans are required by EPA and Colorado regulations for 

facilities that meet certain oil storage criteria. In general, a 

facility must have an SPCC plan if the facility stores more 

than 1,320 gallons of oil or where a spill has the potential 

to enter waters of the United States. 

All program activities were in compliance with 

requirements.

SPCC plans for the STM and NWTC sites were revised to 

address changes to equipment and oil inventories.

One spill at the NWTC required reporting. An open valve 

located within the elevated nacelle of a wind turbine 

leaked approximately 90 gallons of synthetic lubricant 

oil in February 2012. No contamination of a waterway 

occurred and the spill was remediated.

In addition, thirty minor spills of diesel, lubricant and 

hydraulic fluids at STM and one at the NWTC occurred. 

The size of spills ranged from less than 0.1 gallon to 15 

gallons. These spills totaled approximately 50 gallons 

at STM and 1 gallon at the NWTC. Each spill received 

immediate remedial action and did not result in any 

significant impact to the environment. The majority of 

these spills were construction related.

EPA:

Oil Pollution 

Prevention 

40 CFR 112

CDLE:

DOPS 

Storage Tank 

Regulations,

7 C.C.R. 1101-

14

Radiological 

Materials 

and Waste 

Management

Emissions are also regulated by Section 112 of the Clean 

Air Act and implemented by the EPA. 40 CFR Part 61 

established National Emission Standards for Hazardous 

Air Pollutants (NESHAPs), and, more specifically, Subpart 

H, sets such standards for radiological materials.

DOE O 458.1, Radiation Protection of the Public and 

the Environment cancelled DOE O 5400.5. This order 

establishes radiation emission limits for DOE facilities. 

All program activities were in compliance with 

requirements. No planned or unplanned radiological 

releases occurred.

The effective dose equivalent to the public from NREL 

activities was 0.035 mllirem (mrem) per year, far below the 

10 mrem per year limit.

Small quantities of low-level radioactive waste were 

generated and are currently in storage awaiting off-site 

disposal.

EPA:

40 CFR 61,

Subpart H

DOE:

DOE O 5400.5 

DOE O 458.1

NEPA NEPA requires that federal agencies determine 

environmental impacts of proposed federal actions and 

alternatives. DOE implements NEPA in 10 CFR 1021.

All program activities were in compliance with 

requirements.

Four hundred and twenty-five NEPA reviews were 

conducted for project activities on and off site during CY 

2012. Of these, 15 NEPA checklists were completed for 

projects or activities with a potential for environmental 

impacts. For each of these, project funding and initiation 

of work was allowed to commence only after DOE 

reviewed the submittals and provided a signed NEPA 

determination which specified any needed mitigation 

actions required to avoid impacts. The remaining NEPA 

reviews in 2012 were completed using NEPA worksheets 

addressing 285 subcontracting activities, 26 cooperative 

research and development agreement partnerships, 27 

interagency agreements with other federal agencies, and 

72 on-site projects. 

DOE revised its NEPA Implementing Procedures in 

2011, including a modification of its list of categorical 

exclusions. To comply with these changes, NREL updated 

its NEPA procedures to include an updated list of 

categorical exclusions (CX) and to include additional CXs 

that can be selected on the NEPA worksheet. 

A site-wide Environmental Assessment was initiated for 

proposed continued and enhanced operations at the 

NWTC. A supplemental EA for the RFHP was finalized in 

April 2012.

Council for

Environmental 

Quality:

40 CFR 

1500–1508

DOE:

10 CFR 1021
32 ENVIRONMENTAL PERFORMANCE REPORT 2012

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights

Regulator 

& Requirement

Wildlife 

Management

The Migratory Bird Treaty Act (MBTA) of 1918 is the main 

driver for protection of migratory birds in the United States. 

The MBTA and amendments implements several treaties 

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

former Soviet Union. The MBTA prohibits the taking, killing, 

or possession of migratory birds, nests, and eggs.

Under Colorado Revised Statute (CRS) 33-6-128: Damage 

or Destruction of Dens or Nests—Harassment of Wildlife, 

no wildlife dens or nests, young or eggs may be damaged 

or destroyed unless permitted by the Colorado Division 

of Parks and Wildlife and it is unlawful for any person to 

willfully harass wildlife including birds.

Under the “Memorandum of Understanding (MOU) 

between DOE and the USFWS Regarding Implementation 

of EO 13186, Responsibilities of Federal Agencies to Protect 

Migratory Birds” DOE agrees to integrate migratory bird 

conservation principles, measures, and practices into 

agency activities, and avoid or minimize adverse impacts 

on migratory bird resources and their habitats.

All program activities were in compliance with requirements.

No migratory birds were taken intentionally during the 

conduct of any of the laboratory’s activities.

Bird-friendly glass windows were installed on the 

laboratory’s new STM parking garage which opened in 

2012. The glass in this structure is patterned with a 50% frit 

that appears etched but still allows for visibility. This special 

glass was installed on critical areas of glass breeze-ways and 

stairwells. This design should reduce the potential for bird 

collisions, lessening impacts on migratory birds. 

Monitoring of mammalian predators at the STM and NTWC 

and bat monitoring at the NWTC began in 2012. Two motion 

detection cameras were installed at each campus and bat 

call monitoring equipment was installed at the NWTC.

U.S. Fish 

and Wildlife 

Service:

MBTA 16 

U.S.C. 703-

712

Colorado 

Division of 

Parks and 

Wildlife: CRS 

33-6-128

MOU 

between 

DOE and 

the U.S. Fish 

and Wildlife 

Service 

(USFWS) 

EO 13186

Endangered 

Species and 

Species of 

Concern

The Endangered Species Act (ESA) is intended to protect 

threatened and endangered wildlife and plant species and 

associated critical habitat.

All program activities were in compliance with requirements.

The USFWS lists nine species in accordance with the ESA as 

threatened, endangered, or a candidate for listing that could 

potentially occur in Jefferson County or Boulder County. 

Of these, several have the potential to occur on the STM or 

NWTC sites including the Preble’s meadow jumping mouse, 

the Ute ladies’ tresses orchid, and the Colorado butterfly 

plant. While the Preble’s meadow jumping mouse does not 

occur on site, the USFWS mapped critical Preble’s habitat 

within the upper reaches of Rock Creek, including a small 

area at the southeast corner of the NWTC. This area may not 

be disturbed without coordination with the USFWS.

NREL periodically conducts surveys for declining wildlife 

species and rare plants focusing on species that are federally 

protected, state protected, or otherwise considered 

imperiled or declining. In 2010 at STM and 2011 at the NWTC, 

surveys were conducted and no protected species were 

found at the STM or NWTC sites. 

U.S. Fish and 

Wildlife 

Service:

50 CFR 17

Vegetation 

Management

The Federal Insecticide, Fungicide, and Rodenticide Act 

regulates the use, storage, and disposal of herbicides and 

pesticides. For application of certain types of herbicides 

designated as “restricted use” by the EPA, a certified 

applicator must be used.

EO 13112, Invasive Species requires the control of invasive 

species at federal facilities. In Colorado, the Department of 

Agriculture Commissioner develops and implements state 

noxious weed management plans for three categories of 

weed species. Class A plants are targeted for eradication. 

Class B species are subject to management plans designed 

to stop their continued spread. Class C species are subject 

to plans designed to support the efforts of local governing 

bodies to facilitate more effective integrated weed 

management on private and public lands..

All program activities were in compliance with requirements.

The application of restricted-use herbicides was conducted 

using certified applicators. This included treatment at the 

NWTC of approximately 200 acres in May and 82 acres in 

September, and at STM of approximately 23 acres in June 

and 6 acres in September. After several years of aggressive 

management, knapweed is nearly under control at the 

NWTC and Canada thistle, hounds tongue, and myrtle 

spurge are under control at STM. 

Contractors and NREL workers doing landscape 

maintenance were required to compost landscaping waste, 

including weeds, to reduce the waste stream and to reduce 

the propagation of listed weeds.

EPA:

40 CFR 

162—171(f)

EO 13112
ENVIRONMENTAL PERFORMANCE REPORT 2012 33

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & 

Requirement

Wetlands 

and 

Floodplains

Under EO 11990, Wetlands Protection, federal agencies 

must provide leadership and take action to minimize 

the destruction, loss, or degradation of wetlands, and to 

preserve and enhance the natural and beneficial values of 

wetlands. Wetlands that meet certain soils, vegetation, and 

hydrologic criteria, are protected under the CWA Section 

404, which is administered by the USACE.

Jefferson County requires approval of development 

proposed in floodplains within its jurisdiction.

Under 10 CFR 1022, Compliance with Floodplain and 

Wetlands Environmental Review Requirements, for projects 

that occur in floodplains or could affect wetlands, DOE 

must determine the potential impacts, document this in a 

floodplain and wetland assessment, and complete notices 

of availability to appropriate government agencies and 

interested parties, as well as make a public notification in the 

local area.

All program activities were in compliance with 

requirements.

None of the wetlands present at NREL facilities 

have been designated “jurisdictional” by the USACE. 

The STM and NWTC sites do not contain any 

floodplains. However, several actions were taken to 

maintain compliance with wetlands and floodplains 

requirements for the south entrance project, located 

off of DOE property.

Project completion notification was provided to 

the USACE by DOE to close out the Clean Water Act 

Section 404 permitting related to the permanent 

loss of 0.25 acres along Lena Gulch as a result of the 

STM southern access road construction. This loss was 

mitigated through acquisition of wetland banking 

credits through the South Platte Wetlands Bank in 

Brighton, Colorado. 

With the completion of the STM southern access road, 

a final Letter of Map Revision was recorded officially 

changing county floodplain maps.

EO 11990

USACE:

CWA Section 

404

10 CFR 1022

Cultural 

Resources

Cultural resources are protected under Sections 106 

and 110 of the National Historic Preservation Act (NHPA). 

Federal agencies must establish preservation programs—

commensurate with their mission and the effects of their 

activities on historic properties—that provide for the 

careful consideration of historic properties. Significant 

cultural resources are either eligible for, or listed in, the 

National Register of Historic Places. Cultural resources 

are defined as any prehistoric or historic district, site, 

building, structure, or object considered important to a 

culture, subculture, or community for scientific, traditional, 

religious, or other reason. NHPA is administered in 

Colorado by the Colorado SHPO.

All program activities were in compliance with 

requirements.

Two structures at the STM site are listed on the 

National Register of Historic Places. There are no 

known eligible structures at the NWTC.

Construction activities were completed on the 

parking structure, the café and the Energy Systems 

Integration Facility. During excavation of these 

projects, several items were unearthed and reviewed 

for cultural significance, though none were found to 

be of unique value.

In 2010, a Class III Cultural Resource Inventory was 

completed on the final configuration of the new 

south entrance to STM, which lies within the Camp 

George West Historic District. SHPO concurred that 

construction would impact a 500-yard firing line and 

a 600-yard firing line, both of which are contributing 

features of the Camp George West Historic District, 

and that impacts should be mitigated. In 2011, DOE 

established a memorandum of agreement with 

the SHPO to mitigate impacts to these features by 

installing an interpretive feature. In 2012, this feature 

was designed and approval was received from the 

Pleasant View Metropolitan District. The interpretive 

feature will be installed in Pleasant View Community 

Park in 2013.

Advisory 

Council 

on Historic 

Preservation:

36 CFR 60

36 CFR 63

36 CFR 79

36 CFR 800

16 U.S.C. 470
34 ENVIRONMENTAL PERFORMANCE REPORT 2012

FEDERAL, STATE, AND LOCAL ENVIRONMENTAL LAWS AND REGULATIONS APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator & 

Requirement

EMS and 

Sustainability

Under EO 11990, Wetlands Protection, federal agencies 

must DOE O 436.1, Departmental Sustainability cancelled 

DOE O 450.1A, Environmental Protection Program and DOE 

O 430.2B, Departmental Energy, Renewable Energy and 

Transportation Management. The Order implements the 

objectives of EO 13423, Strengthening Federal Environmental, 

Energy, and Transportation Management, and EO 13514, 

Federal Leadership in Environmental, Energy, and Economic 

Performance, which direct federal agencies to conserve 

natural resources, reduce energy use, develop renewable 

energy, reduce GHG emissions, and manage buildings and 

transportation in a sustainable manner.

DOE O 436.1 requires that DOE develop a SSPP to ensure that 

the sustainability goals established in EO 13423 and 13514 

are met. Individual DOE facilities must develop site specific 

SSPs designed to set goals for the coming year and discuss 

performance for the prior year. 

DOE O 436.1 also requires that DOE facilities implement EMSs 

that are independently verified to meet the requirements of 

ISO 14001. 

Each year, a SSP is developed to report on past 

performance and set goals for the coming year. 

These performance goals are integrated with 

the laboratory’s EMS and progress is tracked 

throughout the year. 

NREL’s EMS has been registered to the 

ISO 14001:2004 international standard for 

environmental management systems since 2011. 

Annual assessments by the registrar verify that 

NREL meets the ISO standard and is continually 

improving performance.

EEO 13423

EO 13514

DOE:

DOE O 436.1

DOE O 450.1A

DOE O 430.2B

N/A DOE O 231.1B, Environment, Safety and Health Reporting was 

implemented to assure that DOE receives timely, accurate 

information about events that have affected or could 

adversely affect the health, safety and security of the public or 

workers, the environment, or the operations of DOE facilities. 

The order requires that DOE facilities report specific site 

environmental information annually including environmental 

management performance, environmental occurrences 

and response, compliance with environmental standards 

and requirements, significant programs and efforts, and 

property clearance activities for property contaminated with 

radiological materials.

NREL reports annually via this Environmental 

Performance Report.

DOE:

DOE O 231.1B

Traffic A Mitigation Action Plan (MAP), finalized in May 2008, was 

developed to address potential environmental impacts from 

changes in traffic at STM and to support an EA Finding of No 

Significant Impact (FONSI) for several projects at the laboratory. 

The MAP specifies the methods for implementing mitigation 

measures to ensure that the impacts of continued and 

expanded laboratory operations are not significant. The MAP 

requires that: 

■ The Denver West Parkway/Denver West Marriott Boulevard (DWP/DWMB) intersection operates at a Level of 

Service (LOS) of D or better 

■ The Quaker St. /South Golden Road intersection operates 

at a LOS of D or better

■ Traffic flow to and from the STM east entrance will be 

monitored semi-annually

■ Specific Transportation Demand Management (TDM) 

strategies be implemented as needed to ensure the traffic 

thresholds are not exceeded. Strategies include AWSs, 

expanded shuttle services, expanded carpools, encouraging walking and bicycling, increased use of the Quaker St. 

entrance, infrastructure improvements, and traffic flow 

control measures.

All program activities were in compliance with 

requirements.

TDM measures required by the MAP were 

continued in 2012. 

Average PM peak hour traffic volume at the DWP/

DWMB intersection was 335 vehicle trips. The 

monitoring periods were April 2012, August 2012, 

and December 2012. The MAP threshold of LOS 

D or better is equivalent to a maximum of 387 

vehicle trips per hour entering or leaving the site 

at the east entrance at the afternoon rush hour.

PM peak hour LOS at the DWP/DWMB 

intersection was at LOS B, which does not exceed 

the MAP threshold of LOS D or better.

Average PM peak hour traffic volume at the 

Quaker St./South Golden Road intersection was 

30 vehicle trips. The monitoring periods were 

April 2012, August 2012, and 

December 2012.

PM peak hour LOS at the Quaker St./South Golden 

Road intersection was at LOS B, which does not 

exceed the MAP threshold of LOS D or better.

DOE/EA-1440-

S-I (May 2008) 

Traffic MAP
ENVIRONMENTAL PERFORMANCE REPORT 2012 35

6 Air Quality Protection

The Air Quality Protection program is intended to achieve a 

number of goals including minimization of all types of 

air emissions, tracking of air emissions from the larger 

on-site sources, confirmation that on-site sources have air 

permits as required, and meeting the U.S. Environmental 

Protection Agency (EPA) and Colorado air emissions and 

permitting requirements.

NREL’s goal is to maintain its air emissions at a low level, 

maximizing air quality and minimizing permitting and 

compliance requirements. Minimizing air emissions creates 

direct health benefits to both surrounding neighbors and the 

Denver metropolitan area. In general terms, the more emissions a facility puts into the air, the more complex a facility’s 

air permit must be. Such permits also require more extensive 

emission controls, tests, and reporting of emissions.

NREL environmental staff actively participate in project 

planning, safety evaluations, readiness verifications, and 

operations activities. This participation results in awareness 

of projects and planned air emissions while allowing staff to 

obtain the necessary regulatory approval for those emissions 

and maintain a current and accurate air emission inventory.

PROGRAM MANAGEMENT

The EPA Clean Air Act requires specific permitting and 

emission controls when specific facility emission levels are 

exceeded or individual equipment sizes are reached. For 

example, a Title V air permit would be required if an NREL 

facility emission level were to exceed 100 tons per year for 

a criteria pollutant such as: nitrogen oxides (NOx), volatile 

organic compounds (VOCs), particulate matter (PM10), 

carbon monoxide (CO), or sulfur dioxide (SO2). Under that 

same regulation, a Title V permit would be required if a single 

HAP level exceeds 10 tons per year, or the total emissions of 

all HAP pollutants at one facility exceeds 25 tons per year.

The Colorado Air Pollution Control Division (APCD) requires 

reporting of HAP emissions at much more stringent limitations. The limitations vary for different HAPs based on their 

toxicity and the distance of the release from a facility property boundary. The reporting levels can vary from 50 to 5,000 

pounds per year.

Air emission reporting in Colorado is required for an item of 

equipment that emits 1 ton per year or more of any criteria 

air pollutant. A Colorado air permit may be required if a piece 

of equipment emits as little as 1 ton per year of any criteria pollutant. The trigger level varies from 1 to 10 tons per 

year depending on the pollutant and whether the source 

is located in an attainment or non-attainment area for that 

specific pollutant.

Criteria, Hazardous, Non-Criteria Pollutants, 

and ODS

The Clean Air Act and State of Colorado laws and regulations 

delineate several main categories for air pollutants: 

■ Criteria air pollutants—like carbon monoxide, nitrogen 

oxides, sulfur dioxide, particulate matter, respirable particulates (PM10 and PM2.5), ozone, and lead—have been 

issued National Ambient Air Quality Standards (NAAQS) 

by the EPA.

Standby electrical generator at the NWTC. Photo by Larry Durbin, 

NREL 24490

2012 Highlights and Achievements

■ Updated the air emissions inventory, including 

new sources and the use of equipment specific 

emission factors where possible. This has 

resulted in a more accurate emission inventory. 

■ The procedure for managing ozone-depleting 

substances was updated. 

■ Provided hazardous air pollutant (HAP) emissions calculations and compliance guidance 

to researchers related to several small-scale 

photovoltaic laboratory research activities.
36 ENVIRONMENTAL PERFORMANCE REPORT 2012

■ Non-criteria pollutants—like ammonia, hydrogen 

sulfide, pesticides, certain VOCs classified as ozone 

precursors, metallic compounds, greenhouse gases 

(GHGs), and corrosives—are not associated with an 

EPA-specified NAAQS.

■ HAPs which include a specific list of organic compounds, 

metals, corrosives, asbestos, radionuclides, and pesticides 

established by the EPA.

■ Ozone-depleting substances (ODS) such as chlorofluorocarbons or “Freon” and hydro-chlorofluorocarbons 

that are being phased out of use in comfort heating and 

cooling systems and equipment.

■ GHG compounds that contribute to global warming.

There are various Colorado and EPA notification, permitting 

and reporting thresholds for criteria, non-criteria, hazardous, and GHG pollutants. The primary potential sources 

of these pollutants at NREL include process heat boilers, 

process cooling systems, comfort heating and cooling 

systems, standby electrical generators, experimental laboratory hoods and ventilation systems, pilot- and large-scale 

research projects, and small equipment with gasoline or 

diesel engines. The laboratory maintains an air emission 

inventory to track potential air emissions and identify 

whether notification and permitting could be required 

for a particular facility or activity. Certain equipment and 

emissions are exempt from reporting and permitting by 

the Colorado Department of Public Health and Environment (CDPHE) APCD. The laboratory maintains several air 

permits issued by the CDPHE for “minor” sources, including standby electrical generators and pollution control 

systems at the South Table Mountain (STM) and National 

Wind Technology (NWTC) sites. All of these individual 

emission sources and each NREL facility are considered 

by the EPA and APCD to be minor sources with minimal 

permit and compliance requirements.

Fugitive particulate emissions from construction activities 

occur at the STM and NWTC sites. Particulate emissions 

from construction sites larger than 25 acres, or occurring 

for longer than six months, are subject to APCD fugitive 

particulate emissions permits. A fugitive emission permit is 

in effect for construction activity at the STM site; a fugitive 

particulate emissions permit is not currently needed for 

the NWTC.

Permitting

Most sources of air emissions from NREL laboratory and 

facility operations in 2012 were of small scale and did not 

require permitting. While permitting thresholds may vary, 

depending on the pollutant, the APCD must be notified if 

more than 1 ton per year of one or more criteria pollutants 

is emitted from an individual item of equipment. Standby 

generators generally require permitting even if criteria emissions are less than 1 ton per year. Projected emissions for 

new sources were evaluated and air emission reporting and 

permitting was performed as required. 

During 2012, NREL maintained 10 Colorado air permits. Six 

of these are for standby electrical generators, one is for 

the Renewable Fuels Heat Plant, two are for specific 

research activities, and one is for fugitive emissions from

construction activities.

During 2012, NREL reported air emissions to the CDPHE 

APCD for five new sources which are air permit exempt 

but exceed the emission reporting threshold; Air Pollution 

Emission Notices (APENs) must be submitted to Colorado 

for these sources. These APENs must be maintained for 

the life of the equipment and must be renewed every five 

years. The sources include two research electrical generators 

moved from the NWTC to the Energy Systems Integration 

Facility (ESIF) at the STM site, a steam generator and steam 

super heater at the Solar Technology Acceleration Center 

(SolarTAC), and a small standby electrical generator for 

NWTC Building 258.

An evaluation of HAP emissions for NREL activities indicated 

that those emissions were well below all reporting and 

permitting threshold values. HAP emissions reporting and 

permitting trigger levels vary with the HAP compound, the 

height of the emission point, and distance of that point 

from the nearest property boundary. Those trigger levels 

can vary from approximately 50 pounds per year to more 

than 2,000 pounds per year. The ammonia emissions from 

Standby electrical generator at the STM campus. Photo by Larry 

Durbin, NREL 24488
ENVIRONMENTAL PERFORMANCE REPORT 2012 37

the Integrated Biorefinery Research Facility project are 

expected to meet the state threshold permitting requirement. Therefore, an air permit to install and operate an 

ammonia scrubber was obtained from CDPHE APCD 

in 2012. 

Ozone-Depleting Substances

EPA regulation 40 CFR 82, Protection of Stratospheric Ozone, 

requires that appliances and stationary appliances containing more than 50 pounds of Class I or II ozone-depleting 

substances (ODS) refrigerant must meet specific EPA record 

keeping, ODS recovery, and leak monitoring and repair 

requirements.

There are three categories of ODS registration and certification in Colorado (5 CCR 1001-19, Regulation 15, Control of 

Emission of Ozone Depleting Compounds):

■ Facilities where maintenance activities are performed on 

refrigeration equipment containing ODS are required to 

file an annual notification with CDPHE.

■ Technicians that service ODS-containing equipment 

must be trained to properly conduct that work through 

an EPA-certified training program. Workers completing 

that training are issued a training registration card.

■ Refrigeration equipment larger than 100 horsepower 

(hp) containing ODS must be registered annually with 

CDPHE. Refrigeration equipment that uses non-ODS 

compounds are not required to be registered.

The laboratory has a total of three chillers that use more 

than 100 hp of compression, contain ODS compounds, and 

are thus registered with CDPHE—two located at the Solar 

Energy Research Facility on the STM site, and one at the 

Denver West Office Park. During 2012, NREL performed the 

necessary annual notification that maintenance activities 

occurred, renewed the registration for the three chillers, and 

confirmed that all technicians servicing ODS-containing 

equipment are EPA-certified.

The majority of refrigeration appliances at the laboratory either contain non-ODS refrigerants or use very small 

amounts of ODS refrigerants. The only appliances containing more than 50 pounds of ODS material are the three 

chillers previously mentioned. Operators of these chillers 

must maintain records of service for this equipment.

Street Sanding 

CDPHE regulations (5 CCR 1001-18, Regulation 16, Street 

Sanding Emissions) require federal, state, and local government facilities to track street sanding in the winter, and to 

minimize sand use. Sanding of roads followed by vehicle 

activity turns sand and gravel into finer particulates (PM10 

or smaller) which can become airborne, significantly 

contributing to pollution in the Denver area. As these 

particulates contribute to breathing and health problems 

for susceptible individuals, the EPA and Colorado have 

issued regulations to minimize this source of air pollution.

NREL complies with the Colorado sanding requirements 

and files an annual sanding report with the CDPHE. During 

the 2010 – 2011 season, the laboratory stopped using sand 

and switched to deicer to maintain roadways. This practice 

was continued during the 2011 – 2012 season. The deicer 

used does not contain sand and minimizes fugitive particulate emissions from snow removal operations, contributing 

to improved air quality for neighbors and in the Denver 

metro region.

GHG Emissions Tracking and Permitting

EPA regulations require that certain facilities emitting 

GHGs track and report the amount of those emissions. The 

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

EPA with data upon which to base future GHG regulations. 

The reporting and permitting of these emissions is required 

under the EPA Prevention of Significant Deterioration 

regulation, Title V Tailoring Rule (Tailoring Rule), and the EPA 

GHG Mandatory Reporting Rule. The Tailoring Rule requires 

air emission permitting of GHG emissions if CO2e emissions 

are greater than 100,000 U.S. tons per year. The Mandatory 

Reporting Rule requires annual GHG reporting to EPA if 

CO2e emissions are greater than 25,000 metric tons per year. 

Reporting and permitting of GHGs is not currently required 

for NREL facilities.

GHGs include CO2

, methane, nitric oxide, and many refrigerants including ODS chlorofluorinated hydrocarbons such 

as hydrofluorocarbons, perfluorocarbons, and certain other 

fluorinated gases including sulfur hexafluoride. For more 

information on how NREL is reducing its emission of GHGs, 

please see section 4 Sustainability. 

2012 COMPLIANCE SUMMARY AND ACTIVITIES

Compliance with the wide variety of air permit and emission limitation requirements is an on-going and significant 

activity at NREL that is both necessary and challenging. The 

nature of experimental research may require significant 

changes in technical direction and equipment based on the 

results obtained during those experiments. Such changes 

may alter air emissions.
38 ENVIRONMENTAL PERFORMANCE REPORT 2012

The following compliance activities were performed 

during 2012, assuring compliance with air regulations and 

improved implementation of the Air Quality Protection 

program:

■ All program activities were in compliance with 

requirements.

■ NREL did not exceed any air permit standard or other air 

regulatory requirement at any facility.

■ Completed an evaluation of NREL’s compliance with 

EPA and APCD permitting and emissions control 

requirements. NREL is in compliance with all Colorado 

and EPA permit requirements, and all facilities and 

individual permitted equipment items are classified as 

minor sources.

■ Obtained an air permit for a standby electrical generator necessary for the newly constructed ESIF. Performed 

emission testing and submitted necessary forms to the 

APCD to convert construction permits to final air permits 

for two emergency generators and an ammonia scrubber and particulate baghouse. Five APENs were filed with 

the APCD for the planned installation of permit exempt 

sources at ESIF, SolarTAC, and NWTC Building 258. Annual 

emission fees for all existing permits were submitted to 

the APCD.

■ All required registrations were completed for equipment 

containing ODS. NREL facilities servicing refrigeration 

equipment were registered and all refrigeration service 

personnel have obtained the EPA and Colorado required 

training and certification.

■ Evaluated NREL’s 2012 CO2e and GHG emissions. The 

GHG inventory shows that GHG emissions are below the 

threshold for EPA reporting and permitting rules. The 

laboratory’s CO2e inventory for EPA reporting purposes 

is 6,962 U.S. tons (6,316 metric tons) for the STM site and 

167 U.S. tons (151 metric tons) for the NWTC site. GHG 

emissions for the STM were 6,904 U.S. tons (6263 metric 

tons) and 166 U.S tons (151 metric tons) for the NWTC.

■ The required annual street sanding report was provided 

to the APCD and Jefferson County.
ENVIRONMENTAL PERFORMANCE REPORT 2012 39

Water quality is critical to human health and the health of 

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

protection is on four main areas: 

■ Drinking water

■ Wastewater

■ Groundwater

■ Surface water. 

7.1 DRINKING WATER

Due to its remote location, the National Wind Technology 

Center (NWTC) does not have access to a public drinking water supply. For this reason, NREL operates a drinking water distribution system at the NWTC, serving about 

150 employees. Drinking water is purchased from local 

municipalities and transported by truck to the site, where 

it is transferred to a large holding tank with a capacity of 

15,000 gallons. Water is pumped from the holding tank 

to a day tank where it is circulated around the site for use. 

There is no treatment of the water, but chlorine is added 

to boost disinfectant levels. The system is permitted by the 

State of Colorado, which requires monitoring for a number 

of parameters on an annual basis. The water is tested in the 

same ways municipal water systems are tested for residual 

chlorine levels, bacteria, disinfection byproducts, lead, 

and copper. 

There are a number of organizations that can take credit 

for the success of the NWTC water system. NREL’s Site 

Operations Office provides primary oversight for the 

7 Water Quality Protection

2012 Highlights and Achievements

In 2012, 503,962 gallons of drinking water was 

safely provided to NWTC users. 

Low-flow faucets. Photo by Christina Chase, NREL 20076

Results of 2012 chlorine monitoring.

Average Monthly Chlorine Residual 2012

5.00

4.50

4.00

3.50

3.00

2.50

2.00

1.50

1.00

0.50

0

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

Cl2 Residual,

mg/L

Month

Maximum

Allowed

Average Monthly

Chlorine Residual
40 ENVIRONMENTAL PERFORMANCE REPORT 2012

day-to-day operation of the system, aided by a statelicensed contract operator who visits the site weekly to 

check the details of the system operation and performance. 

The NREL Environment, Health, and Safety (EHS) Office 

assists Site Operations in tracking state requirements and 

completing required reports and managing contacts with 

regulators. NREL’s management of the drinking water 

system is subject to assessments by the U.S. Department of 

Energy (DOE) and compliance inspections by the Colorado 

Department of Public Health and Environment (CDPHE). 

PROGRAM MANAGEMENT

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

Drinking Water Act (SDWA) and federal and state regulations based on the SDWA authority. The U.S. Environmental 

Protection Agency (EPA) has established allowable levels for 

drinking water constituents known as Maximum Contaminant Levels (MCLs), which can be found at Part 40 of the 

CFR Part 141. Colorado has adopted these MCLs into the 

Colorado Primary Drinking Water Regulations at 5 CCR 

1003-1. These regulations establish the state’s authority to 

regulate drinking water providers to assure safe, reliable 

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

The primary requirement is to test the water quality following a monitoring plan issued by the state each year. The 

plan identifies which tests are to be performed and at 

what frequency. Monthly tests are required for bacteria and 

disinfectant levels, while disinfection byproducts (DBPs) are 

sampled for once a year, and lead and copper are tested on 

a three-year rotating basis. The previous two figures show 

the results of the chlorine and DBPs monitoring for 2012.

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ In 2012, the MCL was exceeded for haloacetic acids, a 

class of DBPs. The annual sample collected in August 

measured 69.4 ppb, exceeding the maximum of 60 

ppb. In such circumstances, the state requires increased 

monitoring; sample frequency was increased to quarterly, starting in October and continuing into 2013. 

Monitoring has since indicated that haloacetic acids 

levels have been consistently below the MCL since this 

single exceedance. Prior to this single exceedance, the 

NWTC had not exceeded any of the SDWA’s MCLs in the 

past five years.

■ All other monitored parameters in 2012 met applicable 

SDWA requirements.

■ The state conducted a sanitary survey of the drinking 

water system in 2012 and found no non-conformities 

with program or regulatory requirements. Several recommendations for program improvements were made and 

are being addressed.

7.2 GROUNDWATER

Groundwater protection in the West is particularly important because these resources are limited yet relied upon by 

increasing numbers of residents for water supplies. NREL’s 

groundwater protection program is based on the

Results of 2012 DBP monitoring.

Disinfection Byproducts

Trihalomethanes (TTHM) and 

Haloacetic Acid (HAA5)

80

70

60

50

40

30

20

10

0

2008 2009 2010 2011 2012

Amount

Present,

ppb

TTHM

MCL

TTHM

HAA5

HAA5

MCL
ENVIRONMENTAL PERFORMANCE REPORT 2012 41

philosophy that the prevention of groundwater contamination is far better than remediation. 

Both the STM and the NWTC sites are located at the western 

edge of the Denver Basin aquifer system that supplies water 

to urban, rural, and agricultural users along the Front Range 

of the Rocky Mountains in northeastern Colorado. The aquifers within the Denver Basin, which include the Dawson, 

Denver, Arapahoe, and Laramie-Fox Hills aquifers, form a 

layered sequence of rock in an elongated bowl-shaped 

structural depression. 

The STM site overlies the shallowest portions of the Denver, 

Arapahoe and Laramie-Fox Hills aquifers. The NWTC site 

overlies the shallowest portions of the Arapahoe and Laramie-Fox Hills aquifers. The Dawson formation is the shallowest of the Denver Basin aquifers and is the one most relied 

upon by the groundwater users in the basin. The northern 

extent of the Dawson aquifer is located approximately 20 

miles to the south and east of the STM site; consequently, 

wells drilled at either the STM site or the NWTC would 

not intersect the Dawson aquifer, nor would a source of 

contamination affect the groundwater quality in this aquifer. 

Because of the sensitive nature of the groundwater 

resource, NREL carefully evaluates all outdoor projects 

to eliminate potential impacts to groundwater quality. If 

any materials are used that pose a risk to groundwater, 

the laboratory typically insists that safeguards to protect 

groundwater be established. Safeguards include, but are not 

limited to, secondary containment for equipment with the 

potential to leak oil, double-walled tanks with leak detection 

for diesel fuel storage of NREL facilities’ emergency generators, and bermed areas, either temporary or permanent, to 

contain materials associated with construction activities or 

on-going research.

PROGRAM MANAGEMENT

The State of Colorado regulates the installation of groundwater wells through the state engineer’s office, requiring 

a permit for drinking water, groundwater monitoring, or 

geothermal installations. 

There is one closed-loop geothermal system at the STM for 

the Solar Radiation Research Laboratory installed in 2009 

and another at the South Site Entrance Building installed in 

2012. The installations were completed in accordance with 

state requirements. There are currently five permitted monitoring wells at the STM site and none at the NWTC. There 

are currently no ongoing groundwater monitoring activities 

being conducted; however, these wells remain open for 

possible future use. Should the laboratory conduct activities 

that could impact groundwater, a monitoring program will 

be implemented and additional groundwater monitoring 

wells will be installed as needed.

2012 COMPLIANCE ACTIVITIES

There are no compliance activities associated with the 

Groundwater Program.

7.3 SURFACE WATER

NREL’s Surface Water Protection program seeks to preserve 

the quality of receiving waters to which the STM and NWTC 

campuses discharge. These receiving waters include Lena 

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

the NWTC site. Water quality protection is accomplished 

through management of runoff emanating from active 

construction sites, inclusion of project design elements that 

promote infiltration and detention, and management of 

campus areas not under construction to minimize erosion 

and support infiltration.

Due to the continuing construction activity at both 

campuses, the focus of NREL’s water quality protection 

2012 Highlights and Achievements

■ There were no spills or releases that impacted 

groundwater at any NREL site in 2012.

■ Two monitoring wells, installed in the 1990s 

and closed in 2006, were removed to about 12 

feet below surface level, making way for new 

water lines that were installed along the north 

side of the Integrated Biorefinery Research 

Facility (IBRF). In accordance with state requirements, the top of the remaining well casings 

were covered with pipe caps glued in place.

Stormwater best management practices in action at the STM 

site. Photo by Genny Braus, NREL 24483
42 ENVIRONMENTAL PERFORMANCE REPORT 2012

program during 2012 has been managing construction 

site runoff which has the potential to impact rivers, lakes, 

ditches, and other waters of the United States. Sediment, 

debris, and chemicals transported to these water bodies via 

stormwater runoff can harm or kill fish and other wildlife 

either directly or by destroying aquatic and riparian habitat. 

High volumes of sediment can result in stream bank erosion 

and clogging of waterways.

Prior to construction, NREL implements an interdisciplinary 

planning and design process that involves National Environmental Policy Act reviews and approvals, and the assessment of design documents for potential impacts to stormwater and receiving waters. Design teams are encouraged 

to incorporate low impact design elements that promote 

infiltration and evapotranspiration. NREL continues to monitor final design documents and construction implementation to look for additional opportunities to reduce runoff 

quantity and enhance runoff quality. 

Erosion and sediment controls, proper chemical storage, 

fueling procedures, and good housekeeping practices 

are implemented during construction according to the 

stormwater plans developed by contractors and reviewed 

by NREL EHS staff. Regular inspections by contractors and 

staff are conducted to verify that controls are functioning properly. Any repairs or modifications to the plans are 

documented on an inspection report; prompt actions are 

required to correct any noncompliant conditions. 

Management of campus areas outside active construction 

sites minimizes erosion, supports infiltration of rain water 

and snowmelt, and prevents contamination of stormwater 

with hazardous materials. Vegetation and landscaping are 

maintained to prevent erosion. Infiltration of precipitation 

is achieved through detention basins and grassy swales, as 

well as design elements including porous pavement and 

2012 Highlights and Achievements

■ Completed construction of the STM stormwater detention basin. The detention basin receives, detains, and 

passively improves the quality of stormwater runoff 

from a majority of the STM site. The basin also provides 

flood protection to an adjacent neighborhood and 

park facility by controlling the 100-year storm event 

peak flow leaving the STM site. The basin outlet structure is designed to control the release of stormwater to 

pre-development discharge levels.

■ Developed a conceptual design for improvements to a 

large drainage swale that discharges to the STM stormwater detention basin. The improvements will include 

energy dissipation structures, reseeding, and addition 

of irrigation to enhance re-vegetation success and soil 

stability. As the swale is partly located off campus, design 

approval and permitting is required from the neighboring jurisdiction. The project is expected to be complete 

in late 2013. 

■ Modified NREL’s stormwater program. In response to 

the EPA’s new 2012 Construction General Permit, the 

laboratory modified its stormwater program by changing requirements for the frequency of post rain/snowmelt event inspections, deadlines for completion of best 

management practice (BMP) repair/replacement, and 

including planning documentation within the stormwater pollution prevention plan. These changes support 

compliance with the EPA stormwater regulation and 

improve the effectiveness of the stormwater program.

■ Completed review of snow management procedures. 

A literature review was conducted on new deicing 

chemicals and possible modifications in the application 

of those previously used on the site. This information, 

together with a map indicating preferred snow piling 

locations to maximize infiltration, was incorporated into 

NREL’s snow management practices for 2012. 

■ Incorporated low-impact design elements. All construction projects continue to incorporate low-impact 

design elements such as porous pavement, vegetated 

bioswales, and native vegetation.

■ Completed NWTC drainage system improvements. 

Improvements to the drainage system were made at the 

NWTC as part of the 5-megawatt Dynamometer Expansion project, including the addition of riprap at two 

storm drain outfalls and placement of erosion control 

matting and seeding in a roadside drainage swale.

Stormwater erosion control matting at the cafeteria at the STM 

site. Photo by Dennis Schroeder, NREL 22488
ENVIRONMENTAL PERFORMANCE REPORT 2012 43

diversion of roof and perimeter drains to landscaped areas. 

In addition, dumpsters are kept covered, hazardous wastes 

are stored indoors or in covered areas, and seasonally 

campus roads and sidewalks are swept to reduce sediment 

and deicing materials.

PROGRAM MANAGEMENT

The federal Clean Water Act (CWA), amendments, and 

implementing regulations in 40 CFR Part 122, apply to 

stormwater discharges from construction activities that 

disturb greater than one acre. As a federally owned facility, 

the EPA is the regulating authority for stormwater at NREL’s 

campuses. For construction projects off federal property, 

such as at the SolarTAC facility, CDPHE National Pollutant 

Discharge Elimination System Program stormwater permits 

may be required. For construction sites on NREL property that disturb greater than one acre, a Notice of Intent 

(NOI) must be filed with the EPA to be covered under the 

Construction General Permit (CGP) and a site-specific Stormwater Pollution Prevention Plan (SWPPP) must be prepared.

The SWPPP implements both the requirements of the EPA’s 

CGP and NREL-specific requirements at the laboratory. The 

SWPPP is developed by the subcontractor using an NRELdeveloped template that includes all required elements. The 

SWPPP must be signed and certified per EPA CGP signatory 

requirements and must be accepted by the EHS Office prior 

to filing NOIs. 

While construction sites less than one acre are not regulated by the EPA and typically involve minimal disturbance 

within a short timeframe, these sites still have the potential 

to contribute pollutants to stormwater runoff. For these 

sites, NREL requires subcontractors to comply with basic 

elements of stormwater pollution prevention. Depending on the nature of the construction, contractors may be 

required to develop an abbreviated SWPPP documenting 

basic contact, project, and BMP information. A site-specific 

erosion and sediment control plan showing the locations of 

key site characteristics and BMPs may also be required. 

Energy Independence and Security Act Section 438 requires 

agencies to reduce stormwater runoff from federal development projects to protect water resources. Agencies can 

comply using low-impact design elements such as porous 

pavers, cisterns, and bioswales, or retain stormwater runoff 

and release at predevelopment levels. In addition, Executive 

Order 13514, Federal Leadership in Environmental, Energy, 

and Economic Performance, sets requirements for efficient 

water use, reuse, and stormwater management. The laboratory’s efforts to conserve water and preserve water quality 

through low-impact design are described above, with additional information provided in section 4, Sustainability.

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with 

requirements.

■ Permit coverage was obtained under the new 2012 EPA 

CGP for six construction projects at the STM site, and two 

at the NWTC. In addition, one EPA Low Erosivity Waiver 

was obtained at the STM site for a project constructed 

during low precipitation months. Two permits were 

terminated in 2012. For a list of all stormwater permits, 

see Appendix C. 

■ State stormwater permits were obtained for construction 

of two new experimental research projects at the SolarTAC 

site. Because these projects exist off federal property, Colorado Discharge Permit System construction stormwater 

permits, rather than EPA permits, were required. 

■ Construction sites received periodic monitoring from local 

regulatory officials; no non-compliances were noted.

7.4 WASTEWATER

The majority of wastewater from the STM and DWOP 

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

Metropolitan Wastewater Reclamation District’s (Metro) 

central treatment plant. Wastewaters from the JSF and the 

ReFUEL facility also flow to Metro’s treatment plant. There is 

a small septic system consisting of a tank and leach field on 

the mesa top at STM, serving the Solar Radiation Research 

Laboratory (SRRL), because there is no sanitary service to 

that area. The NWTC also lacks sanitary service, so the site 

has two septic systems that include tanks and leach fields 

for the treatment of wastewater. 

Reseeding and mulching following construction activity at 

NWTC. Photo by Genny Braus, NREL 24489
44 ENVIRONMENTAL PERFORMANCE REPORT 2012

PROGRAM MANAGEMENT

Non-domestic wastewater discharges to the Metro District 

must comply with the district’s rules and regulations, 

which incorporate a number of requirements of the CWA, 

specifically the provision of the Pretreatment Program. 

Pretreatment is the set of regulations applied to industries 

and commercial operations that generate non-domestic 

wastewaters with potentially high levels of pollutants that 

could have an impact on treatment facilities and the environment. NREL does not have any of the types of operations 

that CWA regulations have targeted, nor does the laboratory discharge a volume of water that would make NREL 

a Significant Industrial User, which would require a formal 

discharge permit from the Metro District. The discharge 

agreement in place for NREL gives the laboratory direction 

for using the system, and provides assurance to the Metro 

District that the laboratory-generated wastewaters are 

compatible with their requirements. 

It is NREL policy to comply with all requirements of Metro’s 

Pretreatment Program, including the list of general prohibitions that protect the collection and treatment systems. 

The list of prohibitions includes hazardous materials, highly 

viscous substances, radioactive material, excessive oil and 

grease, and similar substances that could cause material harm to the sanitary system. NREL staff are trained in 

this policy. In addition, NREL sites have design criteria for 

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

measures such as secondary containment for any chemicals 

used near sinks in laboratory exhaust hoods, no floor drains 

in laboratory areas unless a specific need can be shown, and 

caps for any floor drains that are installed in laboratory 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. 

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with requirements.

■ The laboratory worked with the Pleasant View District on 

several large-volume discharges related to construction 

activities. Water lines included in new construction must 

be sanitized prior to use and these lines were disinfected 

and the water used in that process was discharged 

with Pleasant View’s approval. Large flows over small 

time periods can be problematic to sanitary collection 

systems, so the laboratory worked with the district to 

minimize potential impacts to their system.

2012 Highlights and Achievements

While most of the wastewater discharged from 

NREL facilities is domestic, one facility occasionally 

discharges wastewater under an agreement with 

the Metro District. NREL minimizes non-domestic 

wastewater discharges, but when the sanitary 

system is the best option for waste management, NREL works with the districts to ensure that 

there are no adverse impacts to their facilities or 

the environment. The IBRF has pilot-scale operations that take cellulosic materials such as switch 

grass or corn stover and convert the cellulose to 

fermentable sugars that lead to ethanol production. These operations generate wastewater, 

which is discharged to the sanitary collection 

system. Several projects in 2012 generated such 

discharges, all of which met requirements for 

wastewater release. 
ENVIRONMENTAL PERFORMANCE REPORT 2012 45

At NREL, responsible acquisition, use, and disposal of materials and wastes is critical to meeting our commitments 

to compliance, preventing pollution, and environmental 

stewardship. The laboratory seeks to purchase materials 

that are sourced responsibly and contain recycled content 

and lower-impact materials. Use of materials is thoughtfully 

controlled with internal procedures designed to limit health 

and environmental risks. Wastes are carefully managed and 

disposed of through select contractors. These elements, if 

mismanaged, have the potential to increase disposal costs, 

generate cleanup costs, and increase potential for spills and 

contamination. Areas of focus include:

■ Hazardous materials management

■ Regulated waste management

■ Storage tank management

■ Pollution prevention

■ Radiological materials and waste management.

8.1 HAZARDOUS MATERIALS MANAGEMENT

As a major national laboratory, NREL has a variety of chemicals and materials, some of which are hazardous, for use 

in research activities. Hazardous materials are stored, used, 

and managed in a manner that is protective of laboratory personnel, the general public, and the environment. 

NREL has also taken steps to plan emergency responses in 

the event there is a spill or release of a hazardous material; these plans are coordinated with local emergency 

responders, such as the West Metro Fire Protection District 

and the Jefferson County Local Emergency Planning 

Committee (LEPC). 

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 barcoding 

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 onsite prior to 

making chemical purchases

■ Providing quick access to chemical inventories and 

hazard information during emergency responses

■ Facilitating accurate and efficient reporting to external 

agencies (e.g., fire districts, LEPC, EPA, and DOE). 

Hazardous materials are rigorously managed, starting 

with the chemical inventory system that tracks chemical 

2012 Highlights and Achievements

■ In 2012, the Occupational Safety and Health 

Administration published new hazard 

communication requirements at 29 CFR 

1910.1200, implementing the United Nations 

program called the Globally Harmonized 

System of Classification and Labeling of 

Chemicals (GHS). Employers are required to 

train all employees who work with chemicals 

on the components of the new GHS program. 

Training must be complete by December 

2013. NREL introduced GHS during monthly 

chemical safety refresher courses throughout 

2012, and in December, expanded the training 

to cover details of new label requirements, 

safety warnings, and revised safety data 

sheets. All lab employees will be trained by 

the deadline in 2013.

8 Hazardous Materials and Waste 

 Management

Diesel storage tank at the STM site. Photo by Larry Durbin, NREL 24478
46 ENVIRONMENTAL PERFORMANCE REPORT 2012

amounts, locations, and hazards. Each week, safety personnel receive a list of all chemicals and their hazards shipped 

to the laboratory for the previous week. Researchers and 

safety personnel ensure that chemicals are properly stored 

in locations suitable for any hazards, such as storing flammable materials in designated flammables cabinets. In 

addition to the measures taken to safely transport, transfer, 

and store these materials without releases to the environment, there are reporting requirements triggered by certain 

quantity levels.

PROGRAM MANAGEMENT

NREL facilities are subject to the emergency reporting 

provision of the Emergency Planning and Community 

Right-to-Know Act (EPCRA), Section 302, which requires a 

facility to notify the State Emergency Response Commission (the Colorado Emergency Response Commission) if any 

extremely hazardous substances in the facility’s inventory 

are stored in quantities greater than prescribed threshold planning quantities (TPQ). NREL facilities first became 

subject to planning and notification requirements 

in 1988.

EPCRA Section 304 requires facilities to immediately notify 

the LEPC if there is an accidental spill or release of more 

than the predetermined reportable quantity. In accordance 

with Section 311 and 312 of EPCRA, NREL provides MSDS 

for chemicals that are stored onsite in quantities greater 

than TPQs, and provides inventory reporting for these same 

chemicals in the form of a Tier II report to emergency planning and response groups. 

When requested, NREL provides additional emergency 

response and reporting information to the Jefferson County 

LEPC, the Colorado Emergency Response Commission, the 

West Metro Fire Protection District, the Denver Fire Department (DFD) and the Rocky Mountain Fire Protection District. 

The Jefferson County LEPC uses hazard categories and 

threshold reporting quantities as defined by the Uniform 

Fire Code rather than those specified in SARA Title III. This 

results in a larger number of individual hazard categories 

and lower reporting thresholds. NREL has been represented 

in the LEPC since its inception and is actively involved in the 

emergency planning concepts of SARA Title III, with two 

active members on the Jefferson County LEPC.

The laboratory is also subject to reporting requirements in 

the event of a release of a reportable quantity 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 codes 

for which Section 313 reporting is required, Executive Order 

(EO) 12856, Federal Compliance With Right-To-Know Laws and 

Pollution Prevention Requirements, requires that all federal 

facilities file a report, if applicable, regardless of the standard 

industrial classification code. NREL has never manufactured, 

processed, or otherwise used chemicals on the 313 list in 

quantities exceeding TPQs, so has never had to report under 

Section 313. 

NREL is also subject to permitting requirements through 

local jurisdictions. NREL obtains annual hazardous material permits from West Metro Fire Rescue for the STM and 

Denver West Office Park (DWOP) sites as required by West 

Metro Fire Rescue. 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 Fire Rescue conducts a walk-through inspection of 

the entire STM site and DWOP. 

The ReFUEL facility is within the jurisdiction of the City and 

County of Denver and is subject to the DFD Hazardous 

Materials Information System requirements. The ReFUEL 

facility’s inventory of listed materials, including various fuels 

such as biodiesel, must be reported to the DFD annually. 

The DFD inspects the facility and issues a hazardous materials permit.

2012 COMPLIANCE SUMMARY AND ACTIVITIES

In early 2012, NREL submitted a Tier II report to CDPHE for 

reporting year 2011, identifying diesel fuel, petroleum oil, 

2012 EPCRA REPORTING

EPCRA 

Section Description of Reporting Status

EPCRA Section 

302-303

Planning Notification Not required

EPCRA Section 

304

Extremely Hazardous 

Substance Release Notification

Not required

EPCRA Section 

311-312

Material Safety Data Sheet/

Chemical Inventory

Yes

EPCRA Section 

313

TRI Reporting Not required

“Yes" indicates that the laboratory reported under the provision.

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

report under the provision (e.g., did not meet the threshold or did 

not have an extremely hazardous substance release).
ENVIRONMENTAL PERFORMANCE REPORT 2012 47

and sulfuric acid in lead-acid batteries; see the following 

table for details.

■ All program activities were in compliance with requirements. There were no releases of hazardous materials 

requiring reporting.

■ West Metro Fire Rescue conducted an annual hazardous material inspection and issued permits for all major 

research facilities on the STM site. 

■ The inventory of materials at the ReFUEL facility was 

provided to the DFD.

8.2 REGULATED WASTE MANAGEMENT

NREL is committed to the appropriate management of 

regulated waste generated through its daily operations. 

Research and development activities and general facility 

operations create a variety of waste streams, including those 

containing toxic chemicals or metals. These wastes are 

handled, stored, and disposed of responsibly and within the 

parameters of state and federal regulations to minimize the 

potential for health and environmental impacts that could 

result from a release or improper disposal.

Research in such areas as photovoltaics, bioenergy, wind, 

transportation technologies, and energy storage use a vast 

range of chemical products that, in turn, generate hazardous and non-hazardous waste in the form of solids, liquids, 

and gases. Proper planning ensures that the resulting waste 

streams are reduced in volume and managed in an environmentally friendly manner. 

Waste management and minimization efforts begin in the 

planning stages of all experimental and operational activities. 

Processes are evaluated based on the quantities and toxicities of products that will be brought onsite before an activity 

begins and lasting until material use is complete and it is 

ready for disposal. Hazardous materials proposed for use are 

also assessed for the potential substitution of less hazardous 

products, resulting in less hazardous waste streams. 

The handling of waste items always incorporates a high 

level of safety and environmental stewardship for NREL 

and its surrounding neighbors. Likewise, on-site waste 

management activities are conducted in a manner that 

will minimize potential effects on human health and 

the environment. 

PROGRAM MANAGEMENT

Regulated wastes are handled and disposed of according to 

the Resource Conservation and Recovery Act (RCRA) in Title 

40 of the Code of Federal Regulations and implemented in 

the State of Colorado by CDPHE’s Hazardous Materials and 

Waste Management Division (HMWMD) through the Colorado Hazardous Waste Act under 6 CCR 1007-3. Pursuant 

2012 Highlights and Achievements

As a best management practice, NREL continued 

to manage all of its facilities to the more 

stringent Large Quantity Generator (LQG) status 

regulatory requirements, including personnel 

training, contingency planning, and container 

management. 

Consolidation of select waste streams facilitates cost-effective 

disposal. Photo by Bob Fiehweg, NREL 24482

Electronics waste collection. Photo by Eric Schmitz, NREL 24484
48 ENVIRONMENTAL PERFORMANCE REPORT 2012

with 6 CCR 1007-3, Section 262.41, hazardous waste generators that met the criteria for a large quantity generator at 

any time during the year must have a Biennial Hazardous 

Waste Report completed on even-numbered years for the 

previous year’s activities. Additional applicable regulatory 

requirements fall under the realm of Title 49 of the Code of 

Federal Regulations, Transportation. 

NREL implementation of regulatory requirements with 

regard to waste management includes:

■ Documented waste management and minimization 

program

■ Annual training for all staff who generate waste

■ Regular inspection and tracking of all waste containers

■ Storage, packaging, shipment, and tracking until final 

disposition via a fully-permitted waste disposal or 

recycling facility

■ Active monitoring of waste volumes to determine 

generator status

■ Maintaining records that are generated through “cradle 

to grave” waste management activities per applicable 

federal and DOE records management protocols.

■ NREL typically disposes of the following categories 

of waste:

■ Hazardous waste (as defined by environmental 

regulations)

■ Non-hazardous waste such as propylene glycol from 

building chillers or select pretreatment liquors from 

biomass processing, etc.; does not include municipal 

solid waste

■ Universal waste such as mercury-containing light bulbs, 

lead-acid batteries, aerosol cans, and electronic waste 

such as circuitry, solder, display monitors, etc.

■ Low-level radioactive waste. NREL generates this in small 

quantities in one designated laboratory and normally 

consists of personal protective equipment, disposable 

lab ware, scintillation fluids, and water-based liquids 

containing small amounts of low-level isotopes. Radioactive waste is shipped off-site for disposal as needed (for 

more information, see section 8.6 Radiological Materials 

and Waste Management).

A comparison of waste volumes generated in CY 2010, CY 

2011, and CY 2012 is summarized above.

NREL maintains unique EPA identification numbers for each 

of its five facilities: STM, DWOP, NWTC, the Joyce Street 

Facility (JSF), and ReFUEL. Pursuant with state and federal 

regulations, annual generator notifications are made and 

applicable fees are paid to the HMWMD based on monthly 

volumes of hazardous waste that are generated at each 

facility. The three waste generator classifications are:

■ LQG: generates ≥ 1,000 kilograms (kg) of hazardous 

waste in a calendar month (or > 1 kg of acutely toxic 

hazardous waste)

■ SQG: generates > 100 kg but < 1,000 kg of hazardous 

waste in a calendar month (and < 1 kg of acutely hazardous waste)

■ CESQG: generates < 100 kg of hazardous waste in a 

calendar month (and < 1 kg of acutely hazardous waste)

The 2012 Generator Status for NREL Facilities table provides 

data for each NREL facility. Four out of five NREL facilities fall 

under the waste generator category of CESQG, generating 

minimal amounts of hazardous waste per calendar month. 

The STM site typically produces quantities of hazardous 

waste well within the category of SQG; however, due to 

pilot-scale research experiments, the STM site can episodically elevate to that of LQG in one or more months during 

the year. 

NREL has a conservative waste management policy where 

select materials that are not regulated by RCRA, yet pose 

a potential hazard, are collected and disposed of as nonhazardous materials at EPA-permitted disposal facilities. 

COMPARISON OF FOUR WASTE CATEGORIES 

GENERATED AT NREL FACILITIES IN 2010, 2011, 

AND 2012 (LBS. NET WEIGHT)

Hazardous 

Waste

Non-Hazardous 

Waste

Electronic

Waste

Other 

Universal 

Waste

2010 18,322 12,129 11,676 5,791

2011 20,557 6,156 29,549 3,539

2012 33,386 8,805 41,355 4,803

2012 GENERATOR STATUS FOR NREL FACILITIES

Facility Name 2012 Generator Status

STM SQG/LQG

DWOP—Bldg. 16 CESQG

NWTC CESQG

JSF CESQG

ReFUEL CESQG
ENVIRONMENTAL PERFORMANCE REPORT 2012 49

For example, non-hazardous, nanomaterial-bearing wastes 

are not RCRA-regulated, but due to the potential for health 

risk, these wastes are managed and disposed of via the 

same management methods used for hazardous waste. 

In a general order of preference, waste items are shipped 

offsite for final disposal via recycling, reclamation, treatment, 

incineration, and landfill. 

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with 

requirements. 

■ All regulatory notifications were updated and applicable 

waste generator fees were paid for five NREL facilities in 

CY 2012. 

■ The laboratory submitted the required RCRA Biannual Biennial Hazardous Waste Report for the STM 

site for reporting year 2011 to the CDPHE HMWMD in 

March 2012.

■ Despite three calendar months of hazardous waste 

generation at volumes totaling more than 1,000 kg per 

month between July and September 2012, the STM site 

downgraded its waste generator status from LQG to SQG 

in October 2012. 

8.3 ABOVEGROUND STORAGE TANK (AST) 

MANAGEMENT

Proper tank management prevents or minimizes the size of 

spills and leaks of fuels or oils, avoiding contamination of 

soils, surface water, groundwater, and drinking water. Spill 

avoidance saves money and time, and prevents impacts 

to the environment. Proper management of storage tanks 

supports the laboratory’s commitments to environmental 

stewardship and pollution prevention.

The Aboveground Storage Tank (AST) Management 

Program applies to petroleum fuel tanks and is intended to:

■ Minimize releases from tanks

■ Confirm that safety features are present and functional

■ Confirm that compliance requirements are met.

NREL minimizes the risk of underground soil and water 

contamination from storage tanks by utilizing only aboveground tanks where storage is required. Unlike underground 

tanks, aboveground installations provide access for regular 

visual leak inspections and allow for less costly repair and 

cleanup, should that be necessary. 

PROGRAM MANAGEMENT

ASTs are regulated in Colorado by the CDLE’s Oil Inspection Section under the Colorado AST regulation 7 C.C.R. 

1101-14. Colorado requires that ASTs 660 gallons or larger 

be permitted prior to installation, be inspected by the CDLE 

following installation, and be registered within 30 days 

following commencement of use. EPA regulations require 

that ASTs be constructed and installed according to specific 

standards, be regularly inspected, that those inspections are 

documented, and that facilities meeting certain oil storage limits employ a Spill Prevention, Control, And Countermeasures (SPCC) plan to manage oil sources 55 gallons 

or larger. Those plans must include specific information, 

training requirements, and response and cleanup guidance 

New standby electrical generator and AST at the STM parking 

garage. Photo by Larry Durbin, NREL 24487

2012 Highlights and Achievements

■ Governing procedures for AST management 

were updated to reflect revised regulations.

■ AST and spill prevention and response training was provided by the EHS Office to all NREL 

personnel identified as having responsibility 

for operating and fueling ASTs, and those 

providing initial spill response. More than 30 

NREL personnel attended these trainings.

■ The NREL AST inventory was revised to reflect 

new, moved, and removed ASTs at all facilities.

■ All tanks were reviewed to confirm adherence 

to recently revised regulations.
50 ENVIRONMENTAL PERFORMANCE REPORT 2012

designed to minimize the number and size of spills while 

speeding the control and cleanup of spilled materials.

NREL facilities store diesel fuel for emergency generators and ethanol from research activities in ASTs. The AST 

Management Program focuses on proper tank design, 

operation, training, and inspection to protect against spills 

and leaks. The program is designed to meet, at a minimum, 

EPA and Colorado regulatory requirements.

Several important mechanical and procedural safeguards 

have been incorporated into the AST Management Program 

to prevent an accidental release of diesel fuel from the 

storage tanks. Mechanical safeguards include overfill and 

spill protection, double-wall tanks for diesel fuel equipped 

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

is leaking, and exterior concrete containment structures 

for an ethanol storage tank and one single-wall diesel fuel 

tank. Procedural safeguards include written operating and 

tank filling procedures, monthly and annual inspections, 

and record keeping of inspection results. ASTs larger than 

110 gallons are visually inspected monthly and all doublewalled ASTs are inspected annually to confirm that there is 

no liquid in the interstitial space.

Staff participate in project planning, project safety evaluations, readiness verifications, and training activities. This 

participation supports:

■ Awareness of planned ASTs and their contents

■ Timely achievement of necessary regulatory approval 

for ASTs

■ Maintenance of a current and accurate AST inventory 

■ Placement of spill cleanup supplies to assist timely 

response to spill events

■ Planning of annual training activities

■ Regular updates of facility SPCC plans.

Personnel who operate and manage ASTs are trained 

annually. This training is combined with SPCC training for 

individuals who are responsible for AST operation and maintenance, fuel or other liquid transfer activities, and emergency response to AST spills. This combined training informs 

NREL staff of the inventory of oil-containing equipment at 

each site, discusses inspection and response requirements, 

reviews the oil spill history of each site and discusses lessons 

learned, and covers recent changes in rules and regulations.

NREL maintains 13 ASTs at the STM site with a total capacity 

of 11,399 gallons; one AST at DWOP with a capacity of 500 

gallons; and five ASTs at the NWTC with a total capacity of 

1,056 gallons. Four ASTs at the STM are required to be registered with the DOPS, including a 6,000-gallon ethanol tank 

at the Integrated Biorefinery Research Facility, an 800-gallon 

diesel tank for a standby electrical generator at the Solar 

Energy Research Facility, a 660-gallon diesel tank for a standby 

electrical generator at the Research Support Facility, and an 

883-gallon diesel tank for a standby electrical generator at 

the Energy Systems Integration Facility. These ASTs comply 

with Colorado and EPA requirements. There are no ASTs at the 

NWTC that need to be permitted or registered. 

2012 COMPLIANCE SUMMARY AND ACTIVITIES

NREL maintained two ASTs at the STM facility during 2011 

which were required to be registered, including a 6000g 

ethanol tank at the IBRF and an 800g diesel tank for an 

emergency generator at the SERF. Both of these ASTs have 

been in use at NREL for a number of years and comply with 

Colorado and EPA requirements. There are no ASTs at the 

NWTC which are required to be permitted or registered. It 

is anticipated that one or more additional ASTs requiring 

permitting and registration will be installed in 2012.

■ All program activities were in compliance with 

requirements.

■ No spills or releases from NREL’s ASTs or related fueling 

activities occurred. 

■ Two AST installation permits were obtained.

8.4 SPILL PREVENTION AND RESPONSE

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

causing damage to ecosystems, wildlife habitat, and human 

health. Comprehensive planning using spill prevention, 

control, and countermeasures plans can reduce spills and 

limit impacts when spills do occur.

A 6,000-gallon ethanol tank at the IBRF on the STM campus. 

Photo by Larry Durbin, NREL 24477
ENVIRONMENTAL PERFORMANCE REPORT 2012 51

The laboratory prepares for and continually improves spill 

response. Formal SPCC plans have been developed for three 

facilities. The plans are designed to minimize the number 

and size of spills, and speed the control and cleanup of 

spilled materials. Formal emergency notification and hazardous materials procedures are in place to provide additional 

support for spill response. Proper preventive planning and 

training minimizes the potential for spills, and advance 

preparation for spill response enhances the protection of 

our local water and ecological resources. 

PROGRAM MANAGEMENT

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

Federal regulations 40 CFR 110, regarding Discharge of 

Oil, and 40 CFR 112, regarding Oil Pollution Prevention, are 

implemented by the EPA. The CDLE implements the DOPS 

Storage Tank Regulations 7 C.C.R. 1101-14. In general, facilities that store more than 1,320 gallons of oil and have the 

potential for a spill to enter a water of the United States 

must have an SPCC plan. SPCC regulations require that 

any equipment or containers with the capacity to store 55 

gallons or more of oil be included in the plan. The plan must 

address such items as:

■ Topography and location of waterways

■ Location and quantity of oil sources

■ Possible transport mechanisms and pathway

■ Spill scenarios and potential spill volumes

■ Spill prevention and response training

■ Spill notification procedures and contact information

■ Emergency response plans.

Due to the quantity of fuels stored on the STM, NWTC, and 

ReFUEL sites, an SPCC plan is required for each of these 

locations. NREL’s SPCC plans are updated every three years, 

or whenever there is a significant change in regulations, 

operations, or equipment that renders the plan incomplete 

or inaccurate. This aggressive approach to spill prevention 

and control exceeds the EPA’s requirement that SPCC plans 

be updated at least every five years. 

NREL maintains an effective notification and spill reporting program and follows the procedures in the respective 

SPCC plans for spills that might occur at any facility. Spill 

response carts and caches are maintained at multiple locations, allowing response and cleanup activities to occur 

quickly. Given the potential for spill of hydraulic fluids and 

fuels at construction sites, construction contractors are also 

required to implement controls through Stormwater Pollution Prevention Plans for each major construction site on 

campus (see section 7.3 Surface Water).

SPCC training occurs annually for individuals who are 

responsible for AST operation and maintenance, fuel, or 

other liquid transfer activities, and emergency response 

to AST spills. This training is combined with training for 

AST operation and maintenance. This combined training 

educates staff on the inventory of oil-containing equipment at each site, discusses inspection and response 

requirements, reviews the oil spill history of each site and 

discusses lessons learned, and covers recent changes to 

rules and regulations.

While in a given year the laboratory typically does not 

experience spills that require notification to the state, small 

incidental spills do occur on occasion. These are small, 

Initial response to a vehicle fuel spill at the east entrance of the 

STM site. Photo by Kurt Schlomberg, NREL 24485

2012 Highlights and Achievements

■ Updated the SPCC plans for the STM and 

NWTC sites, including changes to equipment 

and oil volume inventory.

■ More than 30 employees who manage and 

operate oil-containing equipment received an 

annual SPCC refresher training.

■ Emergency notification and hazardous materials event notification procedures were updated 

to include a “short form” contact list in print and 

on flash drive to improve the portability of and 

access to spill response resources and contacts.
52 ENVIRONMENTAL PERFORMANCE REPORT 2012

incidental hydraulic system leaks, lubricant leaks, and fuel 

transfer spills during normal construction and maintenance activities and vehicle use. To assess the frequency of 

spill occurrences, a log of spills and clean-up responses is 

maintained. This record demonstrates that spills are generally small and infrequent, and the responses are adequate 

to prevent the spread of contamination. Lessons learned 

from the clean-up activities help improve future contingency planning. 

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with 

requirements.

■ SPCC plans for the STM and NWTC sites were revised to 

address changes to equipment and oil inventories.

■ One spill at the NWTC required reporting. An open valve 

located within the elevated nacelle of a wind turbine 

leaked approximately 90 gallons of synthetic lubricant oil 

in February 2012. No waterway contamination occurred 

and the spill was remediated.

■ In addition, 30 minor spills of diesel, lubricant, and 

hydraulic fluids at the STM site, and one at the NWTC, 

occurred. The size of spills ranged from less than 0.1 

gallon to 15 gallons. These spills totaled approximately 

50 gallons at the STM and 1 gallon at the NWTC. Each 

spill received immediate remedial action and did not 

result in any significant impact to the environment. The 

majority of these spills were construction related.

8.5 POLLUTION PREVENTION

NREL actively seeks opportunities to prevent pollution, 

going above and beyond compliance requirements to 

reduce potential impacts to our environment. Pollution 

prevention can come in many forms and can reduce 

impacts from activities such as: using and storing fuel, 

petroleum products, and chemicals; laboratory chemical 

use; purchasing, recycling, and composting; employee 

commuting and travel; energy and water use; and building 

design and construction. 

Examples of positive impacts of reducing pollution from 

NREL’s activities include: 

■ Replacing toxic chemicals with safer alternatives where 

possible, reducing potential exposure to employees, the 

public, and local ecosystems

■ Choosing bio-based and recycled-content products, 

reducing upstream impacts on natural systems

■ Encouraging employees to telecommute, take alternative transportation, and supporting Web-based meetings, reducing traffic, air pollution, and health effects on 

surrounding communities

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

designs for buildings, reducing GHG emissions and use 

of Colorado’s limited water supplies.

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

policy (see section 3 Environmental Management System). 

NREL fulfills this commitment by implementing a variety of 

controls to reduce the potential environmental impacts of 

laboratory operations. 

While the majority of NREL’s environmental management 

programs were established to meet compliance requirements, many of these programs go beyond compliance 

requirements, continually improving environmental 

performance. 

A researcher using some solvents in a chemical fume hood in 

one of the S&TF labs on the STM campus. Photo by Pat Corkery, 

NREL 15436
ENVIRONMENTAL PERFORMANCE REPORT 2012 53

PROGRAM MANAGEMENT

DOE Order 436.1, Departmental Sustainability, implements 

the objectives of EOs 13423, Strengthening Federal Environmental, Energy, and Transportation Management, and 13514, 

Federal Leadership in Environmental, Energy, and Economic 

Performance, which direct federal agencies to conserve 

natural resources, reduce energy use, develop renewable 

energy, reduce GHG emissions, and manage buildings and 

transportation in a sustainable manner. DOE Order 436.1 

also requires that DOE facilities comply with the Pollution 

Prevention Act of 1990 and support pollution prevention.

NREL’s hazard identification and control process helps staff 

regularly identify opportunities to prevent pollution, and 

formal pollution prevention assessments are conducted 

to identify opportunities to reduce pollution and improve 

program effectiveness. In addition, resources are dedicated 

for sustainable operations and pollution prevention through 

the Sustainable NREL program. The Pollution Prevention 

Initiative Program provides staff with an opportunity to 

identify and implement new pollution prevention practices 

at the laboratory. Staff also provide suggestions and assistance to reduce environmental impacts and prevent spills

2012 COMPLIANCE SUMMARY AND ACTIVITIES

While there is no requirement to conduct pollution prevention assessments, the laboratory periodically conducts these 

assessments to identify opportunities to reduce pollution, 

reduce costs, and improve internal processes.

8.6 RADIOLOGICAL MATERIALS AND WASTE 

MANAGEMENT

NREL is involved in a wide range of research activities, some 

of which occasionally include investigations using radioactive materials. NREL uses several x-ray diffraction analytical techniques and occasionally uses small quantities of 

radioisotopes for biological labeling in research. All of the 

materials used at the laboratory have very low activity levels 

and are used in extremely small amounts. Unlike many DOE 

facilities, NREL does not conduct work involving nuclear 

materials and does not have legacy radiological contamination issues associated with past nuclear weapons production and research.

NREL has established strict protocols for equipment 

containing sources or for the use of radioisotopes in laboratory experiments through its Radiation Safety program. 

Some of these controls include:

■ Confining work with radioisotopes to a single laboratory

■ Monitoring equipment and facilities for removable 

contamination where radioisotopes are used 

Electronic equipment dropped off by NREL employees is recycled 

as part of a regular recycling event. Photo by Dennis Schroeder, NREL 

20541

2012 Highlights and Achievements

■ NREL achieved an estimated reduction of 

337,580 pounds of equivalent carbon dioxide 

(CO2) emissions annually by switching from 

sulfur hexafluoride (SF6) to nitrous oxide (N2O) 

for all fume hood testing.

Sulfur hexafluoride is the most potent of the 

six commonly accepted GHGs, with a global 

warming potential (GWP) 23,900 times that of 

CO2 when compared over a 100-year period. 

Sulfur hexafluoride is also extremely longlived, is inert in the troposphere and stratosphere, and has an estimated atmospheric 

lifetime of 800 to 3,200 years.

Nitrous oxide has been proven as a successful 

alternative tracer gas for testing fume hoods. 

With a GWP of 310, N2O produces far fewer 

GHG emissions than SF6. Conducting a fume 

hood test using N2O results in roughly 33,758 

pounds less of CO2 equivalent emissions per 

test due to its significantly lower GWP, and 77 

times less CO2 emissions than if SF6 is used.

■ Sustainable NREL continued the Pollution 

Prevention Initiative Program, providing staff 

with the opportunity to submit their ideas on 

the reduction of waste, materials, water, air 

emissions, and energy use. The project ideas 

submitted by staff are being evaluated for 

feasibility and further consideration.
54 ENVIRONMENTAL PERFORMANCE REPORT 2012

■ Inspecting x-ray equipment regularly

■ Assuring that future users are not at risk for receiving 

contaminated materials—no equipment used onsite will 

be surplused until background levels of radiation present 

are achieved. 

PROGRAM MANAGEMENT

Radiation emissions are regulated under Section 112 of 

the Clean Air Act as implemented by 40 CFR 61, Subpart H, 

promulgated by the EPA. 40 CFR 61 established NESHAPs, 

and, more specifically, Subpart H, sets such standards for 

radiological materials, known as Rad NESHAPs. 

DOE Order 458.1, Radiation Protection of the Public and 

the Environment, cancelled DOE Order 5400.5. This order 

establishes radiation emission limits for DOE facilities. 

These facilities, including NREL, must annually demonstrate 

compliance with the Rad NESHAP, which limits emissions 

to amounts that would prevent any member of the public 

from receiving an effective dose equivalent of 10 millirem 

(mrem) per year or greater. 

No radioactive air emission monitoring is conducted at the 

laboratory because of the extremely low usage of radioactive material. Therefore, NREL demonstrates compliance 

with the Rad NESHAPs in 40 CFR 61, Subpart H, by using the 

EPA’s COMPLY computer model (version 1.6) 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 until 

disposal is arranged at an off-site facility permitted to accept 

low-level radioactive waste. Internal procedures prohibit the 

clearance of property unless it has been decontaminated to 

background levels. 

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with 

requirements.

■ The effective dose equivalent to the public from NREL 

activities was 0.035 mrem per year, far below the 10 

mrem per year limit.

■ Small quantities of low-level radioactive waste were 

generated and are currently in storage awaiting off-site 

disposal.

■ No planned or unplanned radiological releases occurred.

2012 Highlights and Achievements

■ Limited experiments were conducted involving carbon-14, a low-level radioactive isotope. 

The majority of the waste generated was 

comprised of scintillation fluids and minimal 

solid laboratory debris. Sealed sources are also 

used in tritium exit signs, gauging devices, and 

monitoring equipment check sources.

■ In accordance with DOE Order 458.1, Radiation 

Protection of the Public and the Environment, an 

environmental radiation protection program 

was developed to document procedures that 

demonstrate compliance with applicable 

requirements.
ENVIRONMENTAL PERFORMANCE REPORT 2012 55

NREL’s National Environmental Policy Act (NEPA) program 

provides a mechanism to consider potential environmental impacts in decision-making processes and promotes 

sustainable and environmentally responsible operations. 

Under the NEPA process (described below), staff conduct 

reviews of a wide range of activities prior to spending funds 

or commencing work. 

Examples of activities receiving a NEPA review include new 

or revised laboratory research, construction activities, 

cooperative research and development agreements 

(CRADAs) and other partnering arrangements, and 

feasibility studies or data analyses performed for other 

government agencies. 

PROGRAM MANAGEMENT

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

connection, such as those using federal funds, property, 

facilities, equipment, and staff paid using federal funds. 

The Act requires that federal agencies integrate the NEPA 

process into their activities at the earliest possible time. 

Soon after NEPA was passed, the president’s Council on 

Environmental Quality (CEQ) promulgated regulations (40 

CFR Parts 1500-1508) implementing NEPA which are binding on all federal agencies. Subsequently, the U.S. Department of Energy (DOE) established NEPA Implementing 

Procedures (10 CFR 1021) which DOE (and NREL) use to 

comply with section 102(2) of the National Environmental 

Policy Act of 1969 [42 U.S.C. 4332(2)] and CEQ regulations 

for implementing the procedural provisions of NEPA (40 CFR 

parts 1500-1508). The DOE procedures supplement, and are 

to be used in conjunction with, CEQ regulations.

NREL has developed a NEPA procedure handbook to 

provide a mechanism to consider environmental factors 

in decision-making processes at the laboratory and to 

promote environmentally responsible decisions during 

project planning activities. The handbook provides NREL 

project managers and procurement specialists with guidance on implementing the NEPA procedures, and training is 

provided to staff, as appropriate. 

9 National Environmental Policy Act

A fawn rests beneath a solar panel at the NWTC. Photo by Brenda 

Beatty, NREL 18234

2012 Highlights and Achievements

■ Provided extensive NEPA support in the preparation of proposals for DOE Funding Opportunity Announcements that support DOE’s 

mission and the nation’s energy objectives. 

■ Participated in outreach activities by discussing NEPA requirements and potential 

environmental impacts for participants in 

DOE’s Wind for Schools program. Participants included representatives from several 

colleges and universities across the country 

who will in turn communicate environmental requirements and potential impacts to 

participating schools. 

NREL staff provided a presentation to participants in NREL’s 

national Wind for Schools program.
56 ENVIRONMENTAL PERFORMANCE REPORT 2012

The laboratory initiates NEPA reviews and supports the DOE 

Golden Service Center (DOE GSC) in making NEPA determinations before work begins. In accordance with DOE NEPA 

Implementing Procedures (10 CFR 1021), all NREL activities, 

other than routine office, laboratory, or research activities, 

must undergo a NEPA environmental review. The outcome of 

this review is considered the NEPA determination—a requirement before federal funds are expended, before a contract 

award can be made, and before project activities begin. 

In most cases, proposed activities have either been evaluated in an existing site-wide Environmental Assessment (EA) 

or supplement or fall under a Categorical Exclusion (CX). A 

CX applies to activities that, based on agency experience, 

normally have no significant individual or cumulative effect 

on the quality of the human environment. Examples of DOE 

CXs include information gathering, data analysis, feasibility studies, bench-scale research and development, and 

minor interior modifications. The NEPA review is initiated by 

preparing either a NEPA worksheet or checklist. 

Worksheets

For activities where the potential for environmental impact 

does not exist, or for types of activities that have been 

previously analyzed in existing NREL site-wide NEPA documents, a NEPA worksheet is completed. The NEPA worksheet 

is a simple one-page form that lists the proposed project 

and documents the appropriate CX, NREL EA, or supplement that addresses the proposed work. Allowable types of 

projects include office work such as computer modeling or 

programming, data analysis, or preparation of educational 

materials; routine maintenance activities; minor interior 

modification of existing facilities; and bench-scale research 

and testing in an existing facility. For projects recorded on 

NEPA worksheets, the work can go forward upon receipt 

and review of the project information by NREL’s Environment, Health, and Safety Office.

Checklists

For proposed projects where there is a potential for environmental impacts, a NEPA checklist is completed. The information included on the checklist helps the NEPA reviewer 

evaluate the potential environmental impacts of the project 

(e.g., use of hazardous materials; generation of hazardous waste or air emissions; ground disturbing activities; 

presence of floodplains, wetlands, endangered species, or 

critical habitats; potential for noise and visual impacts; etc.), 

and documents measures taken to avoid or minimize those 

impacts. Projects such as on-site construction, pilot-scale 

research and testing, installation of meteorological towers 

for wind resource assessments, and prototype deployment 

of renewable energy technologies are examples of projects 

that are typically reviewed using the NEPA checklist. 

For a project recorded on a NEPA checklist, work may not 

commence until the DOE GSC has reviewed the submittal 

and provided a signed NEPA determination by a DOE NEPA 

Compliance Officer. The DOE GSC may include provisional 

language in the NEPA determination, which may limit the 

type of work that can be done until additional information 

is received, or which may specify the kind of mitigation 

actions that must be taken to avoid impacts. 

Environmental Assessment

If the proposed action is not included in the description provided in the CXs established by DOE, or there are 

extraordinary circumstances (such as potential effects to 

environmentally sensitive areas or resources and public 

controversy), or the proposed action fits within a category 

of actions that DOE has determined to typically require an 

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

determine the significance of the environmental effects and 

to look at alternative means to achieve the agency’s objectives. An EA is prepared for classes of activities such as siting, 

construction, and operation of energy system demonstration actions including wind resource, hydropower, geothermal, biomass, and solar energy projects and operations. An 

EA provides sufficient evidence and analysis for determining 

whether to prepare an environmental impact statement 

(EIS). The EA provides an opportunity for public review and 

comment, and demonstrates compliance with NEPA when 

no EIS is necessary (i.e., it helps to identify better alternatives 

and mitigation measures). The EA also facilitates preparation 

of an EIS when one is necessary. 

Lindsay Ranch with the National Wind Technology Center in the 

background. Photo by Tom Ryon, NREL 24474
ENVIRONMENTAL PERFORMANCE REPORT 2012 57

An EA provides a brief discussion of the need for the 

proposal, alternatives to the proposal, the proposed action, 

the environmental impacts of the proposed action and 

alternatives, and a list of agencies and persons consulted. 

The EA process concludes with either a Finding of No 

Significant Impact (FONSI) or a determination to proceed 

to preparation of an EIS. The FONSI documents the reasons 

why it has been concluded that there are no significant 

environmental impacts that would occur if the project 

or activities were implemented. The EA and FONSI can 

include mitigation measures or alternatives that would be 

desirable to consider and adopt even though the impacts 

of the proposal will not be “significant.” Preparation of an 

EA requires a public review and comment period after the 

draft EA is prepared; DOE must consider all comments in 

the Final EA and document in the EA how each comment 

was addressed. 

Environmental Impact Statement

An EIS provides a detailed analysis of projects that the 

proposing agency views as having significant prospective 

environmental impacts. The EIS provides a discussion of 

significant environmental impacts and reasonable alternatives (including a No Action alternative) which would avoid 

or minimize adverse impacts or enhance the quality of the 

human environment. An EIS is also made available for public 

review and comment. As a final step, a Record of Decision is 

prepared which states the decision, the alternatives considered, including the environmentally preferred alternative, 

and discusses mitigation plans, including any enforcement 

and monitoring commitments. It should be noted that no 

NREL activities have required an EIS to date.

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with 

requirements.

■ Four hundred and twenty-five NEPA reviews were 

conducted for project activities on- and off-site during 

CY 2012. Of these, 15 NEPA checklists were completed 

for projects or activities with a potential for environmental impacts. For each of the 15, project funding and initiation of work was allowed to commence only after DOE 

reviewed the submittals and provided a signed NEPA 

determination which specified any needed mitigation 

actions required to avoid impacts. The remaining NEPA 

reviews in 2012 were completed using NEPA worksheets 

addressing 285 subcontracting activities, 26 CRADA partnerships, 27 interagency agreements (IGAs) with other 

federal agencies, and 72 on-site projects. 

■ DOE revised its NEPA Implementing Procedures in 2011, 

including a modification of its list of categorical exclusions. To comply with these changes, NREL updated its 

NEPA procedures to include an updated list of CXs and 

to include additional CXs that can be selected on the 

NEPA worksheet. 

■ A site-wide EA was initiated for proposed continued and 

enhanced operations at the National Wind Technology 

Center and a supplemental EA for the RFHP was finalized 

in April 2012.

Summary of NEPA reviews conducted during CY 2012, 

by category.

NEPA

Worksheets -

Onsite Projects

72 (17%)

NEPA

Worksheets -

IAGs

27 (6%)

NEPA

Worksheets -

CRADAs

26 (6%)

Environmental

Checklists

15 (4%)

NEPA

Worksheets -

Subcontracts

285 (67%)
58 ENVIRONMENTAL PERFORMANCE REPORT 2012

NREL is committed to responsible stewardship of our 

natural ecosystems, native wildlife and vegetation, and 

important cultural resources. Natural resources at the South 

Table Mountain (STM) and National Wind Technology Center 

(NWTC) facilities are managed appropriately to ensure the 

laboratory’s research needs are met while protecting native 

wildlife and vegetation. Responsible management not only 

benefits our environment, but also NREL employees and the 

surrounding community, and demonstrates the laboratory’s 

leadership in the U.S. Department of Energy (DOE) and 

federal government as a whole. Management focuses on 

these key areas:

■ Wildlife management 

■ Endangered species and species of concern 

■ Vegetation management

■ Wetlands and floodplains

■ Cultural resources

■ Conservation easement lands.

10.1 WILDLIFE MANAGEMENT

The Wildlife Management Program promotes responsible 

wildlife and habitat management, and gathers information 

to better consider impacts to wildlife when implementing 

projects onsite. NREL is committed to responsible land stewardship and the proper management of wildlife populations 

into the future. Many surrounding landowners, including 

residential neighborhoods and Jefferson County Open 

Space, value the benefits of maintaining wildlife habitat and 

opportunities to observe wildlife. Proper wildlife management provides an important benefit to our community. 

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

habitat by avoiding sensitive areas and reclaiming lands 

once disturbance is complete. 

A long-term objective is to maintain wildlife movement 

through the STM site by retaining linkages between the 

open space areas north of the site and Pleasant View 

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

2012 Highlights and Achievements

■ NREL biologists partnered with the U.S. 

Department of Agriculture and the Colorado 

Division of Parks and Wildlife to trap and collar 

an adult male coyote (Canis latrans) in May 

2012. This effort was part of a larger study to 

observe the behaviors of urban coyotes and 

develop management strategies to avoid or 

reduce harmful human-coyote interactions 

in the Denver metropolitan area. The collar 

was recovered in January 2013 and provided 

regular GPS points for the previous six months. 

A map of the GPS points is presented here. 

The collared coyote primarily stayed on top 

of South Table Mountain and used adjacent 

ravines. The coyote frequented the ravine adjacent to the mesa top access road just west of 

the STM site and infrequently visited the STM 

site via the middle drainage, crossing south 

through the site to Lena Gulch. 

■ Several bee swarms were found on campus. 

Two swarms naturally moved offsite, but a 

third, which settled into a building cavity to 

construct a new hive, was safely relocated by a 

professional beekeeper. 

■ Numerous rattlesnakes that posed a hazard to 

workers were relocated to nearby habitat on 

NREL sites. Elk just west of the STM campus on South Table Mountain. Photo 

by Steve Wilcox, NREL 23860

10 Natural and Cultural Resources 

Protection
ENVIRONMENTAL PERFORMANCE REPORT 2012 59

NWTC, ecologically sensitive areas are preserved within the 

site and linkages with surrounding open space areas are 

maintained. At both sites, periodic monitoring using wildlife 

surveys informs responsible management. 

When control of pest wildlife species is necessary, a graded 

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

administrative controls are the first line of defense against 

pests. When these are not fully effective, additional controls 

are used. Pests are relocated whenever possible. When pests 

must be destroyed, mechanical methods are preferred over 

poisoning. When necessary, pesticides are selected to minimize secondary impacts. 

PROGRAM MANAGEMENT

Several federal laws, an executive order, and a Colorado statute comprise the regulatory framework for NREL’s Wildlife 

Management Program.

The Migratory Bird Treaty Act (MBTA) of 1918 (16 U.S.C. 

703-712; Ch. 128; July 13, 1918; 40 Stat. 755) is the main 

driver for protecting migratory birds in the United States. 

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

seasonal and somewhat predictable pattern of movement. 

Generally, this includes all native birds in the United States, 

except those non-migratory species such as quail and 

turkey that are managed by individual states as 

game species.

Under the MBTA, it is unlawful “by any means or manner 

to pursue, hunt, take, capture [or] kill” any migratory birds 

except as permitted by regulations issued by the U. S. Fish 

and Wildlife Service (USFWS). The term “take” is not defined 

in the MBTA, but the USFWS has defined it by regulation to 

mean to “pursue, hunt, shoot, wound, kill, trap, capture, or 

collect” any migratory bird or any part, nest or egg of any 

migratory bird covered by the conventions, or to attempt 

those activities.

The USFWS has developed a system of permits for activities that involve the take of migratory birds, including those 

governing scientific collection and bird banding, and lethal 

and non-lethal measures taken to prevent depredation of 

Black-capped chickadee. Photo by Bob Fiehweg, NREL 24479

Tracking of a collared coyote shows areas visited at South Table Mountain, including the NREL STM campus, over a six month period.
60 ENVIRONMENTAL PERFORMANCE REPORT 2012

agricultural crops and to protect public health and safety. 

Existing migratory bird permit regulations authorize take 

for specific types of activities, such as collecting birds for 

scientific or educational purposes, or lethal control of birds 

damaging agricultural crops or other personal property. 

The USFWS does not authorize take resulting from activities such as forestry or agricultural operations, construction, 

or operation of power lines, and other activities where an 

otherwise legal action might reasonably be expected to 

take migratory birds, but is not the intended purpose of 

the action. Therefore, NREL property managers do not have 

a permitting option for their activities unless for scientific, 

educational, or property damage. Construction activities do 

not have permitting options. 

In response to Executive Order (EO) 13186, Responsibilities of 

Federal Agencies to Protect Migratory Birds, the USFWS issued 

guidance identifying goals for federal program activities. 

The USFWS highlighted the need to identify means and 

measures to avoid and/or minimize potential for take of 

migratory birds, eggs, and active nests, including but not 

limited to: 

■ Project modification

■ Time-of-year restrictions on vegetation clearing

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

active nests

■ Avoidance of nests of species of concern. 

The USFWS also works to ensure that environmental analyses of federal activities under the NEPA or other established 

environmental review processes evaluate the effects of 

actions and agency plans on migratory birds, particularly on 

species of concern.

Wildlife is considered a state resource under Colorado 

law. Under Colorado Revised Statute 33-6-128: Damage or 

Destruction of Dens or Nests—Harassment of Wildlife, no 

wildlife dens or nests, young, or eggs may be damaged or 

destroyed unless permitted by the Colorado Division of 

Parks and Wildlife. It is unlawful for any person to willfully 

harass wildlife. This statute gives district wildlife managers 

the power to ticket offenders and enforce a similar provision 

to the MBTA and to protect mammalian wildlife species.

On August 1, 2006, a Memorandum of Understanding 

(MOU) was finalized between the USFWS and DOE regarding the protection of migratory birds. Under the MOU, DOE 

agrees to integrate migratory bird conservation principles, 

measures, and practices into agency activities, and avoid 

or minimize, to the extent practicable, adverse impacts on 

migratory bird resources and their habitats.

NREL’s Wildlife Management Program was developed to 

implement measures to allow the laboratory to meet or 

exceed the regulatory requirements discussed and to minimize or avoid impacts to wildlife species and their habitats 

while achieving NREL’s mission. Several activities occur 

periodically to achieve the program’s intent:

■ Monitoring 

● Prior to ground or vegetation disturbing activities 

conducted between March 15 and September 15, 

NREL biologists conduct a nesting bird survey. If nests 

are found, the area is closed with a proper buffer area 

until nestlings fledge.

● Periodic surveys are conducted on a site-wide basis 

to document biological conditions at NREL facilities. 

■ Research Studies

● Periodically, research studies are conducted to better 

understand the potential impacts of projects or site 

management. 

■ Vegetation Management

● Areas that may be impacted by outdoor activities 

are surveyed and then mowed to reduce vegetative 

cover, discouraging bird nesting in that area.

■ Project Reviews

● Biologists conduct project reviews to assess potential 

impacts to avian species including consideration of 

window glazings to reduce bird collisions and timing 

construction activities to start before or after the 

nesting season. A doe with her days-old fawn at the STM site. Photo by Dennis 

Schroeder, NREL 21043
ENVIRONMENTAL PERFORMANCE REPORT 2012 61

■ Coordination

● Biologists coordinate with local, state, and federal 

agencies to improve wildlife management where 

possible.

These activities are conducted in concert with surveys 

for threatened and endangered species and habitats (see 

section 10.2 Endangered Species and Species of Concern). 

Because habitat is as much of a concern as the wildlife 

species themselves, program activities often overlap with 

vegetation management. 

Avian Use and Avian and Bat Mortality Surveys at 

the NWTC

To identify species or species groups that may be at risk 

from NWTC operations and development, NREL completed 

a year-long survey in 2011 to document avian use and 

to document bird and bat mortalities. Avian-use surveys 

included breeding bird surveys during the spring and 

summer, raptor migration surveys during the spring, and 

weekly avian site-use surveys (including raptors and nonraptors) over the entire year. Avian and bat mortality surveys 

were also conducted weekly over the entire year. In addition, wildlife surveys, including bat surveys were conducted 

during 2010 and 2011. Results from these surveys were 

discussed in the 2011 Environmental Performance Report: 

http://www.nrel.gov/docs/fy12osti/54980.pdf.

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with requirements.

■ Bird-friendly glass windows were installed on the laboratory’s new STM parking garage which opened in 2012. 

The glass in this structure is patterned with a 50% frit that 

appears etched but still allows for visibility. This special 

glass was installed on critical areas of glass breeze-ways 

and stairwells. This design reduces the potential for bird 

collisions, lessening impacts on migratory birds. 

■ Monitoring of mammalian predators at the STM and 

NTWC and bat monitoring at the NWTC began in 2012. 

Two motion detection cameras were installed at each 

campus and bat call monitoring equipment was installed 

at the NWTC. 

STM motion detection cameras confirmed track identifications during 2010-2011 baseline surveys: red fox (Vulpes 

vulpes), coyote, and striped skunk (Mephitis mephitis). 

Laboratory staff at the STM site reported several species in 

2012 that hadn’t been recorded in the last baseline survey 

including: great-horned owl (Bubo virginianus), blackcapped chickadee (Poecile atricapillus), raccoon (Procyon 

lotor), western chorus frogs (Pseudacris triseriata), and elk 

(Cervus canadensis). 

NWTC motion detection cameras recorded two mammalian 

predators, coyote and bobcat (Felis rufus), and one avian 

predator species, the great-horned owl. 

Bat acoustic monitoring documented five species of bats 

over a 4-month period (March to April and September 

to October):

Bobcat at the NWTC caught with a motion-detection sensor and 

camera. Photo by Tom Ryon, NREL 24504

Windows at the parking garage use fritted glass to prevent bird 

collisions. Photo by Dennis Schroeder, NREL 22479
62 ENVIRONMENTAL PERFORMANCE REPORT 2012

■ Big brown bat (Eptesicus fuscus)

■ Silver-haired bat (Lasionycteris noctivagans)

■ Hoary bat (Lasiurus cinereus)

■ Eastern red bat (Lasiurus borealis)

■ Brazilian free-tailed bat (Tadarida brasiliensis).

10.2 ENDANGERED SPECIES AND SPECIES OF 

CONCERN

NREL manages its research- and facility-related activities to 

preserve and protect environmental quality and strives to 

practice good land stewardship at its facilities. The laboratory 

is committed to the protection of imperiled wildlife species 

and monitors for these species at its two main research sites: 

the STM and the NWTC. 

Periodically, surveys are conducted for declining wildlife 

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

or declining. Biologists also survey for potential habitat for 

these species. Should potential habitat be found, more 

targeted surveys may be conducted. These surveys identify 

the presence or absence of rare species or their habitats 

and aid in siting and planning new projects. While no 

protected or declining species have been detected at an 

NREL facility, appropriate steps would be taken should such 

a species be found. 

PROGRAM MANAGEMENT

The Endangered Species Act (ESA; 16 U.S.C. §1531-1544 as 

amended) provides for the designation and protection of 

wildlife, fish, and plant species that are in danger of extinction, and preserves the habitats on which these species 

depend. Federal agencies are required to abide by the ESA 

and ensure that their actions do not adversely affect species 

that are federally listed under the ESA as threatened, endangered, or candidate species. 

Additional federal and state laws and regulations protect 

wildlife, such as the Bald and Golden Eagle Protection Act. 

The Colorado Division of Parks and Wildlife identifies a list 

of endangered, threatened, and wildlife species of concern 

for Colorado. Furthermore, the Colorado Natural Heritage 

Program (CNHP) has a list of rare species that, while not 

regulatory in nature, is useful as it is the only designation besides the ESA that considers rare plants. The list of 

threatened, endangered, candidate species and species of 

concern (i.e., bald and golden eagles, state listed species, 

CNHP species) are all considered imperiled species and can 

be referred to as a group known as “Threatened, Endangered, or Species of Concern” species. 

The USFWS lists nine species in accordance with the ESA 

as threatened, endangered, or a candidate for listing that 

could potentially occur in Jefferson and Boulder Counties 

combined. Of these species, several have the potential to 

occur on the STM or the NWTC sites, including the Preble’s 

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

the Colorado butterfly plant. Periodic surveys are conducted 

for these three species to document their presence or 

absence on the STM or NWTC sites. While the Preble’s 

meadow jumping mouse does not occur onsite, the USFWS 

mapped critical Preble’s habitat within the upper reaches of 

Rock Creek, including a small area at the southeast corner of 

the NWTC. This area may not be disturbed without coordination with the USFWS.

NREL also considers other plant and animal species that 

may be state listed or generally in decline. Current information is obtained from both the Colorado Division of Parks 

and Wildlife and the CNHP. These two entities work together 

to track declining species and habitats throughout Colorado. Although not required by federal regulation, periodic 

Bald eagles nest along Coal Creek and at Standley Lake north 

of the STM and are occasionally seen on lands adjacent to the 

NWTC. Sightings of eagles on the STM site or at the NWTC are 

very infrequent. Photo by Tom Ryon, NREL 24481

2012 Highlights and Achievements

NREL monitored the USFWS listing of species as 

threatened, endangered, and candidates for listing. In 2012, the USFWS added the wolverine as a 

candidate for listing. While it is unlikely that NREL 

would have impacts affecting this sub-alpine 

animal, if the wolverine is listed as threatened, the 

laboratory may need to assess potential impacts 

of its activities on the species.
ENVIRONMENTAL PERFORMANCE REPORT 2012 63

surveys are conducted for species that may occur at NREL 

sites, typically, every five years when baseline vegetation 

and wildlife studies are conducted. These baseline surveys 

are a vital part of NREL’s NEPA program where impacts to 

natural resources from mission activities are assessed.

2012 COMPLIANCE SUMMARY AND ACTIVITIES

All program activities were in compliance with 

requirements.

10.3 VEGETATION MANAGEMENT

Native plants have evolved over long periods of time in 

harmony with the local climate and surrounding soil, growing in association with microorganisms and resident wildlife 

to create bio-diverse ecosystems. Through this evolution, 

native plants have developed defenses against pests and 

diseases specific to their locale. When non-native plants 

are introduced into an environment, they often overcome 

indigenous plants, attracting new types of pests and diseases, outcompeting native plants for nutrients and water, 

while also sometimes depriving wildlife of nutrients and 

shelter. Plants such as kochia (Bassia scoparia), Canada thistle 

(Cirsium arvense), Russian olive (Elaeagnus angustifolia), 

diffuse knapweed (Centaurea diffusa), dalmation toadflax 

(Linaria vulgaris), and myrtle spurge (Euphorbia myrsinites) 

are examples of non-native plants that can have destructive 

effects on natural habitats.

For these reasons, the focus of NREL’s approach to vegetation management is:

■ Conserve existing ecosystems in their natural state as 

much as possible

■ Strive to replace disturbed vegetation with native 

species, or with adapted, but non-invasive species when 

necessary

■ Implement a program of weed management to prevent 

the spread of noxious weeds and implement measures 

to control these species

■ Implement a sustainable landscape design and maintenance program. 

Approximately 60 acres of land within the NWTC site 

boundaries are managed as a conservation area. This 

includes on-site seeps and ephemeral drainages and ponds, 

native grassland habitat, and remnant tallgrass prairie. The 

purpose of conserving these areas is to avoid development 

to protect the site’s natural resources. 

Where removal of native vegetation cannot be avoided, 

reseeding is done using grass and forb seed mixes native 

2012 Highlights and Achievements

■ Based on lessons learned from previous 

re-vegetation efforts, landscaping plans for 

current construction projects were adjusted 

to optimize plant establishment, withstand 

difficult shading and snow conditions, and 

deter animal browsing while providing wildlife 

habitat (i.e., spaces for nesting birds, plants for 

pollinators such as hummingbirds, and protective cover for other species).

■ A “snow push map” was developed to ensure 

that snow and deicer materials would be 

pushed to areas where on-site vegetation 

would not be adversely impacted.

■ A weed identification handbook was prepared 

to assist maintenance personnel in identifying 

weeds to be hand-pulled from newly landscaped areas. 

■ To assist vegetation management activities 

at STM, a site-wide map was created showing current vegetation management status 

including recently seeded or landscaped areas, 

areas still under warranty with contractors for 

restoration, areas of weed infestation requiring control, and areas with established native 

vegetation. 

■ Identified areas where vegetation should be 

regularly mowed to reduce the risk of wildfire 

near buildings. 

Mariposa lily (Calochortus gunnisonii) in the xeric mixed grassland 

at the NWTC. Photo by Brenda Beatty, NREL 24475
64 ENVIRONMENTAL PERFORMANCE REPORT 2012

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

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

STM and NWTC campuses to enhance ecosystem diversity 

and integrity. NREL staff continually evaluate and modify 

re-vegetation techniques as needed to promote healthy 

plant establishment. 

To maintain the existing native vegetation and to ensure the 

success of re-vegetated areas, the laboratory has developed 

sustainable landscape management practices to: 

■ Minimize water use

■ Reduce the need for pesticides and fertilizers

■ Reduce maintenance costs

■ Maximize ground cover to reduce soil erosion

■ Establish a variety of habitats to support diverse wildlife

■ Create an aesthetically pleasing landscape environment.

During construction of the Research Support Facility (RSF), 

NREL participated in the Sustainable Sites Initiative (SITES) 

two-year pilot program, a partnership of the American Society of Landscape Architects, the Lady Bird Johnson Wildflower Center at the University of Texas at Austin, and the 

United States Botanic Garden, along with a diverse group 

of other stakeholders. The purpose of this program is to 

develop the first national rating system for sustainable landscapes. While a green building rating system (LEED certification) for new and existing buildings currently exists, there is 

no similar rating system for landscaped environments. 

RSF landscaping was designed and installed with sustainability in mind, and includes features such as native plantings, xeriscape principles appropriate for arid climates, and 

infiltration of stormwater to provide water and nutrients. 

The landscaping was designed so that the RSF would give 

the impression of “rising out of the prairie” instead of being a 

structure on the landscape. 

NREL uses an integrated weed management approach that 

incorporates various types of weed control methods including mechanical practices (e.g., mowing or hand pulling), 

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

(e.g., limiting or eliminating driving of vehicles off established roadways), and herbicide treatment. The effectiveness 

of control methods is periodically assessed. The use of multiple strategies for control has been successful in significantly 

reducing populations of diffuse knapweed and Canada 

thistle. The weed control program maintains the flexibility 

needed to respond to changes in weed populations from 

year to year. Periodic mapping of weed infestation areas 

assists in targeting weed control efforts.

NREL continues to refine and optimize this program with 

interdisciplinary participation, bringing together the expertise of biologists, landscape architects, water quality specialists, and maintenance staff.

PROGRAM MANAGEMENT

The Vegetation Management Program meets the requirements of EO 13112, Invasive Species, and the Colorado Noxious 

Weed Act, which require the control of invasive weeds. 

In Colorado, the Department of Agriculture Commissioner, 

in consultation with the state noxious weed advisory 

committee, local governments, and other interested parties, 

develops and implements noxious weed management 

plans for three categories of weed species: 

■ Class A species are targeted for eradication

■ Class B species are subject to management plans 

designed to stop the continued spread of these species 

NWTC “flower show.” Photo by Bob iehweg, NREL 24473

Bee balm (Monarda fistulosa) at the NWTC. Photo by Brenda Beatty, 

NREL 24476
ENVIRONMENTAL PERFORMANCE REPORT 2012 65

■ Class C-listed species are managed by local governments, at their discretion. If they do choose to manage 

them, the state provides funding for certain programs. 

The laboratory continues to address the control of these 

species using the integrated weed management approach 

described above. The weed maps below show the results 

of recent weed surveys at the STM and NWTC sites. These 

surveys are used to inform management and control of 

weeds at the sites and are conducted periodically (about 

every five years) to identify weed outbreaks. 

The laboratory continues to address the control of these 

species using the integrated weed management approach 

described above. The weed maps below show the results of 

recent weed surveys at STM and the NWTC. These surveys 

are used to inform management and control of weeds at 

the sites. The table below lists noxious weed species at the 

STM and NWTC. 
66 ENVIRONMENTAL PERFORMANCE REPORT 2012

Weed survey results at the STM.
ENVIRONMENTAL PERFORMANCE REPORT 2012 67

Weed survey results at the NWTC.
68 ENVIRONMENTAL PERFORMANCE REPORT 2012

STM 

No rare or imperiled plant species have been found at the 

STM site in recent surveys. Areas of mixed foothills shrublands (also called tall upland shrubland) have been identified at the STM site on top of the mesa within NREL’s conservation easement area. This natural community is listed as 

rare and imperiled by the CNHP. No development will occur 

in the conservation easement area. 

NWTC

No rare or imperiled plant species were found on the NWTC 

site. However, the survey identified a small area of remnant 

tallgrass prairie (lumped in with xeric mixed grassland in 

the survey) located northeast of the SunEdison solar array. 

This natural community is listed as rare and imperiled by the 

CNHP. 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, and was specifically 

protected during construction activities associated with the 

installation of an eight-acre photovoltaic array. 

For information on rare and imperiled plant species, see 

section 10.2 Endangered Species and Species of Concern.

The Federal Insecticide, Fungicide, and Rodenticide Act 

regulates the use, storage, and disposal of herbicides and 

pesticides. For application of certain types of herbicides 

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

certified applicator license must be used. Application of 

restricted-use herbicides is conducted in accordance with 

the regulation. NREL currently uses contractors for this type 

of application.

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with 

requirements.

■ The application of restricted-use herbicides was 

conducted using certified applicators. This included 

treatment at the NWTC of approximately 200 acres in 

May and 82 acres in September, and at the STM site of 

approximately 23 acres in June and six acres in September. After several years of aggressive management, knapweed is nearly under control at the NWTC and Canada 

thistle, hounds tongue, and myrtle spurge are under 

control at the STM site. 

■ Contractors and NREL workers doing landscape maintenance are required to compost landscaping waste, 

including weeds, to reduce the waste stream and to 

reduce the propagation of listed weeds.

10.4 WETLANDS AND FLOODPLAINS 

Floodplains are land areas adjacent to rivers and streams 

that are subject to recurring inundation. Wetlands are lands 

that are inundated or saturated by surface or groundwater 

at a frequency and duration sufficient to support distinct soil 

types and plant communities. Wetland areas typically take the 

form of swamps, marshes, bogs and groundwater seeps and 

are frequently located within or adjacent to a floodplain. 

Both wetlands and floodplains play a key role in providing 

floodwater storage, reducing flood flow rate, and filtering 

floodwater. The resulting enriched floodplain soils promote 

the growth of wetland and riparian vegetation that provide 

Lena Gulch just south of the STM campus. Photo by Tom Ryon, NREL 

24486

NOXIOUS WEED SPECIES IDENTIFIED AT THE

STM AND THE NWTC

Noxious Weed 

Class

Species Present at 

STM

Species Present at 

NWTC

Class A: Myrtle spurge None

Class B: Canada thistle

Common teasel

Dalmation toadflax

Diffuse knapweed

Hoary cress 

(whitetop) 

Hound’s tongue

Musk thistle

Russian olive 

Scotch thistle

Canada thistle

Chicory

Dalmation toadflax

Diffuse knapweed

Hoary cress 

(whitetop)

Leafy spurge

Musk thistle

Sulfur cinquefoil

Class C: Field bindweed

Cheatgrass 

Field bindweed

Cheatgrass
ENVIRONMENTAL PERFORMANCE REPORT 2012 69

habitat for a rich diversity of terrestrial and aquatic plants 

and animals. NREL preserves the important natural functions of its wetlands and floodplains, thereby protecting 

the physical, biological and chemical integrity of receiving 

waters and riparian areas on and adjacent to the STM and 

NWTC sites.

NREL protects its wetlands and floodplains through several 

means:

■ Periodic vegetation surveys and wetland delineations

■ Mapping of wetland areas potentially affected by 

proposed construction

■ Identification of potential impacts

■ Coordination with other jurisdictions on the control of 

floodwaters leaving NREL sites.

PROGRAM MANAGEMENT

Wetlands became regulated in 1972 when, under the CWA, 

the definition of Waters of the United States was expanded 

from only those waters capable of supporting interstate 

or foreign commerce (as defined under the Rivers and 

Harbors Act of 1899) to waters that also include tributaries 

to navigable waters, interstate wetlands, wetlands which 

could affect interstate or foreign commerce, and wetlands 

adjacent to other waters of the United States. Wetlands that 

meet certain soils, vegetation, and hydrologic criteria, are 

protected under the CWA Section 404, which is administered by the USACE, with program oversight provided by 

the EPA. Areas that do not meet the criteria above and do 

not fall within the jurisdiction of the Corps are not protected 

or regulated under Section 404. However, such areas may 

still perform wetland functions as described above and act 

as valuable ecologic components.

In 2009, the USACE visited the STM campus, after which 

they issued a jurisdictional determination stating that all 

drainages examined were considered upland swales and 

consequently are not regulated by the USACE. The jurisdictional determination—which is valid for a period of five 

years (through April 27, 2014)—allows NREL to perform 

work in the upland swales without a USACE permit. As 

stated above, a preliminary wetland assessment and delineation was jointly conducted with the USACE of the NWTC 

site. A formal delineation will be submitted to the USACE in 

2013 to obtain a jurisdictional determination for the NWTC.

Counties typically map the 100-year floodplain boundaries 

within their jurisdiction and then develop regulations that 

control the type and amount of development within 

those areas. Jefferson County has no 100-year floodplain 

2012 Highlights and Achievements

In support of ongoing wetland management, 

several wetland areas at the NWTC were delineated and the site vegetation map was updated 

to include the identified wetland areas and associated vegetation (see Appendix A).

Lena Gulch floodplain just south of the STM site.
70 ENVIRONMENTAL PERFORMANCE REPORT 2012

boundaries that affect the NWTC or STM sites. However, 

the new south entrance to the STM site, which was 

constructed on county and private property adjacent to 

the STM site, is located in the Lena Gulch 100-year floodplain. A Floodplain Development permit was required 

from Jefferson County and Urban Drainage and Flood 

Control District. NREL complied with floodplain development requirements, determined that the project would 

alter the floodplain, and submitted a Conditional Letter 

of Map Revision. When the project was completed, a final 

Letter of Map Revision (LOMR) was recorded officially 

changing county floodplain maps.

Federal regulation 10 CFR 1022, Compliance with Floodplain and Wetlands Environmental Review Requirements, 

establishes policy and procedures for discharging DOE’s 

responsibilities under EO 11988, Floodplain Management, 

and EO 11990. For projects that occur in floodplains or have 

the potential to affect wetlands, DOE must determine the 

potential impacts to the floodplain or wetlands, document 

this in a floodplain and wetland assessment, and complete 

notices of availability to appropriate government agencies 

(e.g., federal emergency management organizations and 

state and local governments) and to persons or groups 

known to be interested in or potentially affected by the 

proposed floodplain or wetland action. For such actions, 

DOE must also distribute the notification in the area where 

the proposed action is to be located (e.g., by publication 

in local newspapers). After the consideration of public and 

agency comments, the process concludes with the preparation of a Floodplain and Wetland Statement of Findings.

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with requirements.

■ Project completion notification was provided to the 

USACE by DOE to close out the Clean Water Act Section 

404 permitting related to the permanent loss of 0.25 

acres along Lena Gulch as a result of the STM southern access road construction. This loss was mitigated 

through acquisition of wetland banking credits through 

the South Platte Wetlands Bank in Brighton, Colorado. 

■ With the completion of the STM southern access road, 

a final LOMR was recorded, officially changing county 

floodplain maps.

10.5 CULTURAL RESOURCES

Cultural resources are defined as any prehistoric or historic 

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

traditional, religious, or other reasons. NREL identifies and 

protects cultural resources in several ways:

■ Integrating cultural resource management into site 

activities and minimizing and/or mitigating impacts to 

historic properties.

■ Implementing procedures to manage historic properties and to protect undiscovered cultural resources 

and artifacts.

■ Periodically conducting surveys to document presence or absence of cultural or historic resources while 

considering project impacts to the human environment. 

When surveys reveal artifacts, staff work with the State 

Historic Preservation Officer (SHPO) to determine if 

the artifacts are eligible for consideration as cultural or 

historic resources. 

■ Construction contractor site orientation training informs 

workers that in the event they discover any evidence of 

cultural resources during ground-disturbing activities at 

the STM or the NWTC sites, workers are to stop all work 

in the vicinity until a qualified archaeologist evaluates 

the significance of the find. 

Battalion officers at Camp George West. Photo from the Jefferson 

County Historical Society

The purpose of the stormwater detention basin is explained to 

NREL employees during a nature walk of Lena Gulch. Photo by 

Dennis Schroeder, NREL 20505
ENVIRONMENTAL PERFORMANCE REPORT 2012 71

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

variety of human uses over the decades. In 1903, the Colorado National Guard established the State Rifle Range at a 

location three miles east of Golden, Colorado. The site was 

designated as “Camp George West” in 1934, honoring civil 

war veteran and Golden business man, George West. This 

site became an integral part of Colorado National Guard 

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

the camp totaled 750 acres and many buildings were added 

throughout the 1930s and 1940s. During World War II, much 

of Camp George West was leased to the federal government for military training purposes. From the 1930s to the 

1970s, several state entities took up residence at Camp 

George West, including the Colorado State Highway Patrol, 

the Colorado Law Enforcement Training Academy, and the 

Colorado Correctional Center. In 1981, more than 300 acres 

were transferred to the federal government for solar energy 

research purposes. An additional 25 acres were transferred 

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

PROGRAM MANAGEMENT

Cultural resources are protected under Sections 106 and 

110 of the National Historic Preservation Act of 1966, as 

amended. Federal agencies must establish preservation 

programs—commensurate with their mission and the 

effects of their activities on historic properties—that provide 

for the careful consideration of historic properties. Significant cultural resources are either eligible for, or listed in, the 

National Register of Historic Places. 

Cultural resources 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, pottery, 

tools). Prehistoric resources that predate the advent of written records in a region range from a scatter composed of a 

few artifacts to village sites and rock art. Historic resources 

may include campsites, roads, fences, trails, dumps, battlegrounds, mines, and a variety of other features. 

Architectural resources include standing buildings, dams, 

canals, bridges, and other structures of historic or aesthetic 

significance. Architectural resources generally must be 

more than 50 years old to be considered for protection 

under existing cultural resource laws. However, more recent 

structures, such as Cold War facilities, may warrant protection if they manifest the potential to gain significance in

the future. 

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

Historic Places because of its association with cultural practices or beliefs of a living community that are rooted in the 

2012 Highlights and Achievements

In 2012, DOE and NREL sponsored an open house 

at the STM, inviting the public to learn about 

research at the laboratory and its management. 

At the event, DOE and NREL answered questions 

and presented information on the laboratory’s 

commitment to historical preservation and 

cultural resource management.

Ammo bunker constructed in 1940 at Camp George West.

Photo by David Parsons, NREL 06928

Firing line from Camp George West, relocated as part of the 

parking garage and south entrance project. Photo from Robert 

Smith, NREL 25492
72 ENVIRONMENTAL PERFORMANCE REPORT 2012

community’s history, and are important in maintaining the 

continuing cultural identity of the community. Traditional 

resources may include archaeological resources, buildings, 

neighborhoods, prominent topographic features, habitats, 

plants, animals, and traditional culture. 

Three formal surveys of historic and cultural resources 

have been performed on the STM site. These surveys were 

completed in 1980, 1987, and 2003. Two additional limited 

surveys of the Camp George West District involving the STM 

site have also been conducted. 

Three historical sites were recognized as significant cultural 

resources that should be preserved. These resources 

include:

■ An open-air amphitheater

■ A stone bridge spanning a natural drainage channel 

adjacent to the amphitheater

■ A stone and concrete ammunition bunker below 

the amphitheater. 

The three structures were constructed during the Works 

Progress Administration era in the 1930s. Through NREL’s 

efforts, these structures have been added to the National 

Register, with the amphitheater and stone footbridge listed 

together as a single resource. 

The Camp George West Historic District, also listed on the 

National Register of Historic Places, includes the 25-acre 

parcel of the STM site south of Denver West Parkway. Prior 

to NREL developing this parcel, a cultural resource survey 

identified two types of features associated with the historic 

district on the property: two firing lines (200-yard and 

300-yard) and a low rock wall. These features were formally 

recorded in 2006 per an agreement with the SHPO, and the 

200-yard firing line and low rock wall were then removed. 

The 300-yard firing line was salvaged and relocated in 2011 

to an interpretative trail around the STM stormwater detention basin.

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with 

requirements.

■ Construction activities were completed on the parking 

structure, the café and the Energy Systems Integration 

Facility. During excavation of these projects, several items 

were unearthed and reviewed for cultural significance, 

though none were found to be of unique value.

■ In 2010, a Class III Cultural Resource Inventory was 

completed on the final configuration of the new south 

entrance to STM, which lies within the Camp George 

West Historic District. SHPO concurred that construction 

would impact a 500-yard firing line and a 600-yard firing 

line, both of which are contributing features of the Camp 

George West Historic District, and that impacts should be 

mitigated. In 2011, DOE established a memorandum of 

agreement with the SHPO to mitigate impacts to these 

features by installing an interpretive feature. In 2012, 

this feature was designed and review and approval was 

provided by the Pleasant View Metropolitan District. 

The interpretive feature will be installed in Pleasant View 

Community Park in 2013. 
ENVIRONMENTAL PERFORMANCE REPORT 2012 73

In 1999, the U.S. Department of Energy (DOE) granted a 

conservation easement for 177 acres of the South Table 

Mountain (STM) site to Jefferson County. The purpose of the 

easement is to preserve the natural character of the property, including its visual, biological, and recreational resources, 

especially in relation to the changing land uses adjacent to 

the NREL site and within the region. 

The goals of the easement are to: 

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

and historical aspects of the conservation easement 

property

■ Protect the ecosystem of the STM 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 

■ Preserve the conservation easement property as natural 

open space. 

Local policies established by Jefferson County, Golden, and 

Lakewood reflect community sensitivity with respect to the 

visual qualities provided by natural resources in the STM 

area. Specifically, the Jefferson County General Land Use 

Plan (Land Use Plan) characterizes North and South Table 

Mountain as “unique landscapes,” and states that “maintaining landscapes that have a unique visual quality” is a key to 

maintaining the quality of life in Jefferson County. 

The conservation easement land is located on the mesa 

top, slope, and toe of STM. Vegetation includes grassland 

interspersed with shrubland communities, primarily in the 

drainages. Several seeps also occur throughout the area.

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 property4

. 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 

(including geology, hydrology, vegetation, wildlife, and 

cultural resources). 

Jefferson County Open Space maintains formal trails on the 

conservation easement property. Two trails cross the easement, connecting Denver West Parkway (near the NREL site 

entrance) to the trails on the mesa top. NREL staff and the 

public use these trails daily.

2012 PROPERTY ASSESSMENT 

During 2012, there was no NREL activity on the conservation easement property having the potential to degrade the 

environmental condition of the property. 

The conservation easement lands are northeast of the new ESIF 

on the mesa slopes and top. Photo by Dennis Schroeder, NREL 21829

Conservation easement area atop STM mesa. Photo by Christina 

Chase, NREL 22071

11 Conservation Easement Lands

4 U.S. Department of Energy, Golden Field Office (1999). National Renewable Energy Laboratory (NREL) Site Conservation Easement Baseline Inventory. 

Golden, Colorado. 
74 ENVIRONMENTAL PERFORMANCE REPORT 2012

The South Table Mountain (STM) site draws hundreds of 

commuter vehicles daily, as well as visitor and delivery traffic 

coming to and leaving the site. Traffic management for the 

site is important for minimizing negative impacts to traffic 

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

noise and light pollution, vehicle emissions, fuel use, parking 

requirements, and road maintenance costs.

The laboratory works to reduce traffic by encouraging:

■ Alternative modes of commuting, such as mass transit, 

ridesharing (carpool and vanpool), and bicycling 

■ Telecommuting one or more days per week

■ Flexible shifts and alternate work schedules

■ Teleconferencing, videoconferencing, and web-based 

tools for conducting meetings and trainings remotely.

Periodic traffic monitoring at the STM site provides information regarding total traffic volumes and peak hour vehicle 

trips. Baseline traffic levels were established in 2008 prior to 

moving increased numbers of staff into newly constructed 

buildings at the STM site. Since 2008, traffic has been 

monitored to measure changes in traffic volumes to better 

inform traffic management. 

Intersection traffic analysis, referred to as Level of Service 

(LOS) analysis, has also periodically been performed to 

measure the impacts of NREL-generated traffic volumes 

on traffic flow at the nearby intersections of DWP/Marriott 

Boulevard (DWMB) and Quaker St./South Golden Road. The 

analysis is conducted to confirm that traffic flow at the intersections adjacent to NREL has not degraded to an unacceptable level. Monitoring will continue to be conducted as 

additional staff are relocated to STM.

PROGRAM MANAGEMENT

A Mitigation Action Plan (MAP), finalized in May 2008, was 

developed to address potential environmental impacts from 

2012 Highlights and Achievements

■ The completion of the new south entrance 

and roadway from South Golden Road to the 

STM campus in May 2012 decreased traffic 

volumes accessing the east and west entrances. NREL’s traffic impacts at the DWP/DWMB 

and South Golden Road/Quaker St. intersections were also reduced. Throughout 2012, 

traffic monitoring and intersection analysis 

indicated that NREL-generated traffic volumes 

and LOS remained within acceptable levels 

and continued to be insignificant.

■ Construction of an additional right-turn lane 

at the DWP/DWMB intersection is slated to 

begin in early 2013. The turn lane will further 

improve capacity at the intersection, allowing for increased acceptable NREL-generated 

peak-hour traffic volume thresholds. Bike-2-Work Day participants enjoy breakfast at the NREL Visitors 

Center. Photo by Dennis Schroeder, NREL 19262

12 Traffic Management

Aerial view of the new south entrance to the STM campus. Photo 

by Dennis Schroeder, NREL 21814
ENVIRONMENTAL PERFORMANCE REPORT 2012 75

changes in traffic at STM and to support an Environmental 

Assessment Finding of No Significant Impact for several 

projects at the laboratory. The MAP specifies the methods 

for implementing mitigation measures to ensure that the 

impacts of continued and expanded laboratory operations 

are not significant. The MAP requires that: 

■ The DWP/DWMB intersection operates at a LOS of D 

or better. 

■ The Quaker St./South Golden Road intersection operates 

at a LOS of D or better.

■ Traffic flow to and from the STM east entrance will be 

monitored semi-annually. 

■ A report on the implementation and effectiveness of the 

STM traffic mitigation measures will be published in the 

NREL Annual Site Environmental Report.

The MAP also identified specific mitigation strategies to be 

implemented as needed to ensure that the traffic thresholds are not exceeded. These actions include transportation 

demand management (TDM) strategies such as alternative 

work schedules (AWS), expanded shuttle services, expanded 

carpools, encouraging walking and bicycling, increased use 

of the Quaker St. entrance, infrastructure improvements, 

and traffic flow control measures. The TDM measures implemented are described here. 

Alternative Modes of Commuting

■ Eco Passes provided to employees encourage use of 

the RTD public transportation system. This includes 

unlimited RTD regional, express, local, light rail, and 

call-n-Ride services. 

■ Shuttle routes provide connections between NREL facilities in Golden and three regional RTD transit stations in 

Lakewood, Wheat Ridge, and Boulder. 

■ Incentive parking is provided for vanpools and carpools 

at the STM and Denver West sites. 

■ Vanpool subsidies are available for participants who 

commute in formal organized vanpools.

■ Bike racks, bike lockers, and bicycle maintenance stations 

are in key locations on the STM site. Bike racks on shuttle 

vehicles permit staff to take their bikes with them when 

they commute or move between buildings.

■ RideShare Connections intranet site allows staff to post 

and search listings for potential carpool and vanpool 

partners within NREL.

■ Literature kiosks in key building locations provide 

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

■ Information sharing events promote safe bicycling, rideshare (carpool and vanpool) and RTD services.

Flexible Workplace Practices

Conferencing by video, telephone, and the internet as well 

as AWSs provide flexibility in how people work, saving staff 

time, energy, and money. An AWS policy allows employees 

to work varying schedules (with management approval), 

including four-day workweeks, reduces the miles driven by 

employees to and from the laboratory. 

Telecommuting

Telecommuting allows staff (with management approval) 

to work from home at least one day per week or occasionally as needed, reducing the days they commute to the lab. 

Laboratory-wide employee surveys have confirmed that 

adoption of this program has been very strong.

Teleconferencing

The laboratory promotes and encourages use of teleconferencing and videoconferencing for meetings to decrease 

local vehicle trips and air travel. 

2012 COMPLIANCE SUMMARY AND ACTIVITIES

■ All program activities were in compliance with 

requirements.

■ TDM measures required by the MAP were continued 

in 2012. 

■ Average PM peak hour traffic volume at the DWP/DWMB 

intersection was 335 vehicle trips. The monitoring periods 

were April 2012, August 2012, and December 2012. The 

MAP threshold of LOS D or better is equivalent to a maximum of 387 vehicle trips per hour entering or leaving the 

site at the east entrance at the afternoon rush hour.

■ PM peak hour LOS at the DWP/DWMB intersection was 

at LOS B, which does not exceed the MAP threshold of 

LOS D or better.

■ Average PM peak hour traffic volume at the Quaker St./

South Golden Road intersection was 30 vehicle trips. The 

monitoring periods were April 2012, August 2012, and 

December 2012.

■ PM peak hour LOS at the Quaker St./South Golden Road 

intersection was at LOS B, which does not exceed the 

MAP threshold of LOS D or better.
76 ENVIRONMENTAL PERFORMANCE REPORT 2012

Detailed Traffic Metrics and Results 

Previously conducted traffic studies indicated that the 

greatest impact to traffic in the local area from NREL activities occurs between 4:30 p.m. and 5:30 p.m. This hour has 

been designated the PM peak hour. Video traffic surveillance was conducted during three weeks at three different 

times of the year (April, August, and December 2012). Traffic 

counts for the PM peak hour were compared against the 

MAP threshold. The MAP threshold indicates the amount of 

traffic that would cause degradation to the LOS at the DWP/

DWMB intersection.

The table below shows the results of the traffic counts at 

the east, west and south entrances to the STM site in April, 

August and December 2012. 

The applicable traffic volume threshold identified in the 

MAP is 387 vehicle trips in the PM peak hour (from 4:30 p.m. 

to 5:30 p.m.) at the DWP/DWMB intersection. This threshold 

identifies the acceptable number of vehicle trips NREL can 

contribute to the intersection without causing significant 

degradation to flow. In 2012, PM peak hour traffic volume 

averages remained below the MAP threshold. 

PM Peak Hour Average = 335 vehicle trips 

In December 2011, LOS analyses were conducted at the 

DWP/DWMB and Quaker St./South Golden Road intersections indicating that both intersections were at LOS B and 

within the MAP allowed service levels (LOS D or better). 

Since these analyses were conducted, traffic volumes at 

both the east and west entrances to the STM site have 

decreased as a result of the opening of the south entrance 

and roadway. Further, results from the 2011 LOS analyses 

suggest that the NREL-generated PM peak hour traffic 

volume thresholds identified in the MAP could be adjusted 

upward to better reflect current area traffic conditions. The 

analyses indicate that PM peak hour traffic thresholds could 

be increased from 387 vehicle trips per hour to 747 trips per 

hour while still maintaining an acceptable LOS. 

2012 TRAFFIC COUNTS

Gate

PM Peak Hour Vehicles 

 (in- and out-bound)

Apr-12 Aug-12 Aug-12 Average

East Entrance (Denver 

West Parkway/Denver 

West Marriott Blvd.)

441 278 285 335

West Entrance (Quaker St./

South Golden Road)

61 19 10 30

South Entrance (South 

Golden Road/Research Rd.)

N/A 170 167 169
ENVIRONMENTAL PERFORMANCE REPORT 2012 77

Appendix A: Plant Communities at 

the STM and the NWTC

Vegetation surveys were not completed for the South Table 

Mountain (STM) and National Wind Technology Center 

(NWTC) sites in 2012; however, surveys were completed in 

2011. Plant communities and species were identified for each 

of the sites at that time, and changes from similar surveys 

completed in 2000 are noted below.

STM PLANT COMMUNITIES

The majority of vegetation at STM belongs to the grassland 

community type. Within that association, there are two 

distinct community types: short-grass grassland on the mesa 

top and mixed-grass grassland located on the slopes and 

toe area. Other mapped vegetation communities at STM 

include ravine shrubland, tall shrubland, short shrubland, and 

wetlands. The plant communities are described below and 

mapped as illustrated in the figure.

SHORT-GRASS GRASSLAND

Short-grass grassland is found on the flat top of the mesa. 

The dominant grass species are blue grama (Chondrosum 

gracile), a native prairie species, and cheatgrass (Anisantha 

tectorum), a noxious weed. Populations of diffuse knapweed 

(Acosta diffusa) and Dalmatian toadflax (Linaria genistifolia subsp. dalmatica) are scattered throughout the whole 

community. These two noxious weeds comprise approximately 1% of the short-grass. 

Alyssum (Alyssum parviflorum), an introduced species, is the 

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

occur throughout the short-grass mesa top, as well as henand-chicks (Echinocereus viridiflorus) and pincushion cacti 

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

Some short shrubs such as rubber rabbitbrush (Chrysothamnus nauseosus subsp.), chokecherry (Padus virginiana), and 

skunkbrush (Rhus aromatica subsp. trilobata) occur infrequently in the short-grass area and concentrate along the 

rimrock areas. Several large hackberry trees (Celtis reticulata) 

are clustered at the very edge of the mesa top.

Historically, this short-grass grassland was probably dominated by blue grama grass and other short-grass species 

such as buffalo grass (Buchloë dactyloides), intermixed with 

the other species associations described above. However, 

this entire mesa-top area has become dominated by cheatgrass, an aggressive noxious weed. This weed is changing the 

appearance and general species composition of the area by 

apparently out-competing native plants.

MIXED-GRASS GRASSLAND

The mesa slopes and toe areas on the STM site also support 

blue grama and cheatgrass, but are dominated by a mixedgrass species association of needle-and-thread grass and 

western wheatgrass (Pascopyrum smithii), with smaller 

amounts of big bluestem (Andropogon gerardii), side-oats 

grama (Bouteloua curtipendula), three-awn (Aristida purpurea), 

and green needle grass (Nassella viridula). As in the shortgrass areas, a large number of forbs also occur in the mixedgrass grassland.

A few patches of anomalous vegetation occur within the 

mixed-grassland where subsurface water appears to be 

close to the surface. These areas support wide swaths of 

mat muhly (Muhlenbergia richardsonis). One is located on a 

southern-facing slope, near the eastern property boundary. 

The other is located on a southwestern-facing slope of the 

ravine north of the NREL Education Center, formerly known 

as the Visitors Center. This area is notable for a large population of poison ivy (Toxicodendron rydbergii), which grows 

in thickets of tall (one meter and larger) plants that have a 

woody, shrub-like growth form. A small number of plains 

cottonwood (Populus deltoides) saplings, skunkbrush, chokecherry, and snowberry occur in this patch as well.

The mixed-grass areas grade into both the upland and ravine 

shrublands and contribute the majority of the understory 

in these areas. Some mixed-grass areas also blend into 

disturbed areas, where reclamation species such as crested 

wheatgrass (Agropyron cristatum) and smooth brome have 

been planted and have subsequently spread into the mixedgrass community.

UPLAND SHRUBLANDS

Shrubland habitat occurs along the upper sides of ravines 

and on the steeper mesa slopes, becoming more prominent 

as elevation increases up to the top of the mesa. The upland 

shrubland habitat, which excludes the shrublands in the 

ravine bottoms, comprises tall shrubland and short shrubland communities very similar in overall composition but 

distinguished by the dominant species. 

TALL SHRUBLAND

The tall shrubland areas are defined by stands of mountainmahogany (Cercocarpus montanus) that occur along the rim 
78 ENVIRONMENTAL PERFORMANCE REPORT 2012

STM land cover types surveyed in 2011. Note: Map updated in 2012 to reflect site building changes. 
ENVIRONMENTAL PERFORMANCE REPORT 2012 79

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

6

 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.

7

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

of the mesa, usually where volcanic cap rock is exposed, and 

on the upper mesa slopes below rimrock areas. The understory is notably sparse throughout this community, with a 

large amount of bare soil. Cheatgrass is the most common 

herbaceous species in these areas, intermixed with needleand-thread grass, yucca, and many cacti.

SHORT SHRUBLAND

The short shrublands occur on elevated flat areas amidst 

the surrounding grasslands, some of which appear to have 

experienced surficial disturbance in the past. These areas are 

distinctive because of their dominance by rubber rabbitbrush. The other common location for short shrublands is 

on the outer slopes of the ravines. Skunkbrush defines these 

and other short shrublands along the upper portions of the 

steepest slopes of the mesa.

 These communities usually grade into the ravine shrublands 

along the drainage bottoms and the tall shrublands near the 

top of the mesa slopes. The short shrubland community also 

has a sparse understory of the same grasses and forbs as the tall 

shrub community.

RAVINE SHRUBLANDS

Ravine shrublands are limited to the lower sides and 

bottoms of the drainages that cut down through the mesa 

slopes. These communities support a variety of shrubs such 

as skunkbrush, chokecherry, and wild plum (Prunus americana), often growing in dense, impassible thickets. A few 

plains cottonwoods and peach-leaf willow (Salix amygdaloides) trees occur at the top of the ravine channels and in 

other portions of the channel where the subsurface water 

table appears to be relatively high. A diverse herbaceous 

component is found in these drainages. In one instance near 

the southeast site boundary, a ravine shrubland grades into 

an ephemeral drainage at the toe of the mesa. This drainage is vegetated with grassland species and conducts only 

occasional surface water runoff. 

WETLANDS

Five very small communities on the STM site were found to 

support wetland vegetation. These communities were not 

examined for the soils and hydrology that would classify 

them as functioning wetlands; rather, they are noted only for 

their domination by wetland vegetation. These are limited 

to very small areas (less than half an acre in total). One is in a 

shallow swale at the mouth of the ravine at the southwestern corner of the project boundary where surface water and/

or subsurface drainage have created a pocket of saturated 

soil. Species here include sedges (Carex spp.), rushes (Juncus 

spp.), bulrush (Schoenoplectus sp.), and peach-leaf willow. 

The second wetland could have formed as a result of past 

construction activities. This linear depression supports 

wetland vegetation along the central portion of the western 

site boundary, northeast of the photovoltaic array. Perhaps 

where equipment was once staged, this area appears to hold 

seasonal water for enough consecutive growing seasons 

to support some wetland vegetation including Arctic rush 

(Juncus arcticus), American speedwell (Veronica americana), 

and broadleaf cattail (Typha latifolia). 

The wetland at the mouth of the ravine may no longer 

experience the hydrology that originally allowed these 

plants to establish there. In 2002, this plant community 

supported populations of cattails that were not observed in 

the 2011 survey. 

Three small seeps are located on the hill slope between 

the Education Center and the public trail on the far eastern boundary of the site. These seeps are dominated with 

sedges, rushes, and Canada thistle (Cirsium arvensis).

A seventh wetland community that was observed by 

Plantae5 no longer appears to support wetland vegetation. 

In 2002, cattail species near an old stock tank in the easternmost drainage appeared to have been supported by a pipe 

coming out of the hillside. Although the stock tank was 

observed in the 2011 survey, it appears the cattails have not 

persisted in the intervening years. 

DISTURBED/RECLAIMED

This habitat type comprises all of the areas at the site that 

have experienced surface disturbance to vegetation caused 

by human activities. These mostly occur on the perimeter 

of the buildings, roads, parking lots, and soil dumping areas. 

Most of these areas appear to have been re-vegetated and 

support a combination of native grassland plants, planted 

ornamental re-vegetation species, and native and introduced weeds.

NWTC PLANT COMMUNITIES

The majority of the vegetation at the NWTC site belongs to 

the mixed-grass prairie association of the grassland formation. Mixed-grass prairie is defined by the presence of grass 
80 ENVIRONMENTAL PERFORMANCE REPORT 2012

NWTC land cover types surveyed in 2011.
ENVIRONMENTAL PERFORMANCE REPORT 2012 81

species typical of the tall-grass or true prairie such as big 

bluestem (Andropogon gerardii), little bluestem (Schizachyrium scoparium), and prairie dropseed (Sporobolus heterolepis), 

with species more typical of the short-grass prairie such as 

blue grama (Chondrosum gracile) and buffalo grass (Buchlöe 

dactyloides). Intermediate grasses (mid-grasses) such as 

the needle grasses (Hesperostipa and Nassella spp.), wheat 

grasses (Pascopyron, Agropyron, Elytrigia, Elymus, and Thinopyrum spp.), and blue grasses (Poa spp.) are also important 

constituents of mixed-grass prairie. 

The grasslands at the NWTC fall into the xeric mixed grassland community type identified and classified primarily on 

available soils and soil moisture, reflected in xeric mixed 

grassland plant species assemblages. 

A number of changes in vegetation patterns noted since 

the NWTC site was previously mapped (DOE 19986

, Plantae 

20007

) are discussed by specific plant community below. 

The plant communities are described below and mapped as 

illustrated in the figure. 

XERIC MIXED GRASSLAND 

Xeric mixed grassland is by far the largest and most widespread community type at the NWTC site. These areas do 

not have access to regular soil moisture (xeric conditions) 

and are dominated by typical short- and mixed-grass prairie 

species. This plant community includes a large variety of 

native grass species as well as a diverse forb component, 

typical of mixed grasslands. Dominant species noted include 

big bluestem, little bluestem, prairie dropseed, blue grama, 

and buffalo grass. Intermediate grasses (mid-grasses) such 

as the needle grasses, wheat grasses, and blue grasses are 

also important constituents of mixed-grass prairie. Species 

flowering in late spring include little bluestem, cheatgrass, 

sand lily (Leucocrinum montanum), wild iris (Iris missouriensis), 

Lambert locoweed (Oxytropis lambertii), mouse-ear (Cerastium strictum), western wallflower (Erysimum capitatum), and 

prairie golden pea (Thermopsis rhombifolia). 

WET MEADOW

Three locations support wet meadows8 at the NWTC. One 

is south of the SunEdison solar array, the second is at the 

upper end of the Rock Creek tributary along Row 4, and the 

third is adjacent to the Building 251 east parking lot. A wet 

meadow is a type of grassland which transitions between 

mesic and hydric conditions (i.e., an ecotone between 

upland grasslands and wetlands). These areas support Arctic 

rush, Canada bluegrass (Poa compressa), red-top bent grass 

(Agrostis stolonifera), Canada thistle, western wheatgrass, 

common three-square (Schoenoplectus pungens), showy 

milkweed (Asclepias speciosa), and wild iris (Iris missouriensis). 

PONDEROSA PINE WOODLAND

One woodland habitat, defined by a single community of 

the ponderosa pine (Pinus ponderosa) woodland, occurs in 

the northwestern corner of the site along a granite outcrop. 

This small area supports a very diverse native plant community including common grassland and foothills species, 

as well as a number of introduced and noxious weeds. 

Dominant species include ponderosa pine (Pinus ponderosa), smooth bromegrass, crested wheatgrass, and green 

needlegrass (Nassella viridula). Species flowering in late 

spring include sand lily, western snowberry (Symphoricarpus 

occidentalis), groundsel (Senecio sp.), and wax current 

(Ribes cereum). 

UPLAND SHRUBLAND

A small upland shrub community is located to the southeast of the ponderosa pine woodland, where the same 

ridge arises to a lesser degree from the surrounding grassland community. This rocky ridge supports shrub species 

interspersed with grasses and forbs representative of the 

surrounding grasslands. Dominant species noted include 

western snowberry, Canada wild rye (Elymus canadensis), 

Canada bluegrass, Kentucky bluegrass (Poa pratense), and 

little bluestem. Species flowering in late spring include 

prairie goldenpea. 

PALUSTRINE EMERGENT WETLAND

Two wetlands on the site fall into the palustrine emergent 

category. The first is a linear depression on the southern side 

of the south road. This area appears to have developed as 

the result of soil excavation intercepting sufficient surface 

water runoff from the adjacent road to support sedge 

species (Carex spp.). A second wetland is located on the 

southern boundary in an area previously disturbed from the 

neighboring industrial activities. This wetland comprises a 

center of cattails (Typha angustifolia) surrounded by a stand 

of coyote willow (Salix exigua). 

Two palustrine emergent wetlands were mapped in the 

mesic mixed grassland in the 2000 growing season. These 

areas appear to have dried considerably in the intervening 10 years. The small wetland pockets of cattails (Typha 

spp.) that occurred in the southern portions of this area are 

8 In the 2000 and 2011 surveys, wet meadows were identified as mesic mixed grassland. These areas were reclassified in 2012 as wet meadows due to an 

apparent change in vegetation and hydric conditions. 
82 ENVIRONMENTAL PERFORMANCE REPORT 2012

no longer present, apparently replaced by large stands of 

Canada thistle. Dead remnants of Baltic rush (Juncus balticus) can be found in the area litter (prior years’ herbaceous 

vegetation). The dominant species noted was 

smooth bromegrass. 

HEADWATER WETLAND

Areas of headwater wetland occur along the two ephemeral 

drainages on the NWTC site. Both drainages occur in the 

northeastern portion of the site, one flowing east and one 

flowing north. Both show evidence of intermittent surface 

flow. The northern-most drainage is a tributary of Coal Creek 

and the second drainage is a tributary to Rock Creek. 

Surface flow in the drainage to the northeast appears to be 

augmented by outflow from the groundwater seep wetland 

on the western bank. The second and larger drainage 

conducts surface flows through the center of the site off 

to the eastern fence line. The upper reaches of this drainage are a shallow grassland swale (also shown in the NWTC 

weed map). This channel deepens as it flows east across the 

site. At its eastern reaches, this drainage clearly intercepts 

subsurface water, although not in sufficient quantities to 

produce consistent surface flow. At the point where this 

drainage leaves the NWTC site, there is a human-constructed rock wall. Dominant species noted include Canada 

thistle, Baltic rush, curly dock (Rumex crispus), common 

evening-primrose (Oenothera villosa), smooth bromegrass, 

and western wheatgrass (Pascopyrum smithii). 

GROUNDWATER SEEP WETLAND

Two areas of groundwater seep wetland are located on 

the NWTC site. The first occurs west of the ponderosa pine 

woodland, in the northwestern portion of the site along the 

northern fence line. This area now includes more upland 

species than noted in 2000.

The second occurs over a very small area on the banks 

of the northern drainage. This community is a clearly 

demarcated area of primarily wetland plants amidst the 

surrounding grassland. Fifty plant species were identified 

in this community in 2000, many of which also occur in the 

headwater wetland to the south. Dominant species noted 

include sedges (Carex sp.) and rushes (Juncus sp.). Common 

teasel (Dipsacus fullonum) has invaded the northern drainage area. Species flowering in late spring include common 

teasel, showy milkweed (Asclepias speciosa), wild iris, fieldmint (Mentha arvensis), and Canada thistle. 

SEASONAL POND 

A seasonal pond and pond margin occur at the northwestern corner of the site, west of the southern terminus of the 

ponderosa pine woodland. This area appears to depend on 

an elevated spring and early summer water table for the 

hydric soil moisture conditions that support this community. Observers have noted that the pond depression often 

contains standing water in the spring and early summer 

in some years9

. However, no standing water was observed 

in this area during the most recent survey. These drier soil 

conditions are reflected in a shift of dominant plant species 

in this community between the 2000 and 2011 surveys. 

Dominant species noted include curly dock, Canada bluegrass, smooth bromegrass, and Canada thistle. 

Disturbed 

These plant associations reflect surface disturbance due to 

human activities on the site. These areas include roadsides, 

pad sites, parking lot perimeters, construction sites, and 

storage areas. Some of these areas have been revegetated 

and now include a combination of species from surrounding natural plant communities, reclamation species, and 

adventive (non-native) or ruderal (native or adventive, 

disturbance colonizer) species. Dominant species noted 

include smooth bromegrass and cheatgrass. 

Ornamental Trees/Shrubs 

Disturbed areas around buildings have been planted with a 

combination of native and ornamental trees and shrubs. The 

trees include multiple species of junipers (Sabina spp.) and 

pines (Pinus spp.) interspersed with ornamental deciduous 

trees. Shrubs in these areas are mainly chokecherry (Padus 

virginiana) and rose (Rosa spp.) bushes.

9 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, Colorado.
ENVIRONMENTAL PERFORMANCE REPORT 2012 83

The following are lists of common and scientific names 

of wildlife species observed at the STM and NWTC sites. 

The species for the NWTC were identified during surveys 

completed in 2011. The species listed for STM were 

observed by staff and/or observed in surveys completed in 

1987, 2005, and 2011.

Appendix B: Wildlife Species 

Observed at the STM

WILDLIFE SPECIES AT THE STM*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

BIRDS

American crow Corvus brachyrhynchos X X

American goldfinch Carduelis tristis X

American kestrel Falco sparverius X X X

American pipit Anthus rubescens X

American redstart Setophaga ruticilla X

American robin Turdus migratorius X X X

American tree sparrow Spizella arborea X X

American white pelican Pelecanus erythrorhynchos X

Bald eagle** Haleatus leucocephalus

Barn swallow Hirundo rustica X

Black-billed magpie Pica hudsonia X X X

Black-capped chickadee Poecile atricapilla X

Black-crowned night heron Nycticorax nycticorax X

Black-headed grosbeak Pheucticus melanocephalus X

Blue-gray gnatcatcher Polioptila caerulea X

Blue jay Cyanocitta cristata X X

Brewer’s blackbird Euphagus cyanocephalus X X

Brewer’s sparrow Spizella breweri X

Broad-tailed hummingbird Selasphorus platycercus X

Broad-winged hawk Buteo platypterus X

Brown-headed cowbird Molothrus ater X X X

Bullock's oriole Icterus bullockii X X

Bushtit Psaltriparus minimus X

California gull Larus californicus X

Canada goose Branta canadensis X X

Cedar waxwing Bombycilla cedrorum X

Cassin’s kingbird Tyrannus vociferans X

Chestnut-collared longspur Calcarius ornatus X

Chipping sparrow Spizella passerina X

Cliff swallow Petrochelidon pyrrhonota X

Common grackle Quiscalus quiscula X

Common nighthawk Chordeiles minor X X X

Common raven Corvus corax X X

Common snipe Gallinago delicata X

Cooper's hawk Accipiter cooperii X X

Dark-eyed junco Junco hyemalis X X

Double-crested cormorant Phalacrocorax auritus X
84 ENVIRONMENTAL PERFORMANCE REPORT 2012

WILDLIFE SPECIES AT THE STM*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

BIRDS

Eastern kingbird Tyrannus tyrannus X

Eurasian collared dove** Streptopelia decaocto

European starling Sturnus vulgaris X X X

Golden eagle Aquila chrysaetos X

Grasshopper sparrow Ammodramus savannarum X

Great blue heron Ardea herodias X X

Green-tailed towhee Pipilo chlorurus X

Hepatic tanager Piranga flava X

Hermit thrush Catharus guttatus X

Horned lark Eremophila alpestris X X

House finch Carpodacus mexicanus X X

House sparrow Passer domesticus X X

House wren Troglodytes aedon X

Killdeer Charadrius vociferous X X X

Lark bunting Calamospiza melanocorys X X

Lark sparrow Chondestes grammacus X

Lazuli bunting Passerina amoena X

Lesser goldfinch Carduelis psaltria X

Loggerhead shrike Lanius ludovicianus X

MacGillivray's warbler Oporornis tolmiei X

Mallard Anas platyrhynchos X

Mountain bluebird Sialia currucoides X X

Mountain chickadee Poecile gambeli X

Mourning dove Zenaida macroura X X

Northern flicker Colaptes auratus X X

Northern goshawk Accipiter gentilis X

Northern harrier Circus cyaneus X

Osprey Pandion haliaetus X

Peregrine falcon Falco peregrinus X

Pine siskin Carduelis pinus X

Prairie falcon Falco mexicanus X

Red-breasted nuthatch Sitta canadensis X

Red-tailed hawk Buteo jamaicensis X X

Red-winged blackbird Agelaius phoeniceus X

Rock dove Columba livia X

Rock wren Salpinctes obsoletus X

Ruby-crowned kinglet Regulus calendula X

Sage thrasher Oreoscoptes montanus X

Say's phoebe Sayornis saya X

Sharp-shinned hawk Accipiter striatus X

Spotted towhee Pipilo maculates X

Swainson's hawk Buteo swainsoni X

Tree swallow Tachycineta bicolor X X
ENVIRONMENTAL PERFORMANCE REPORT 2012 85

WILDLIFE SPECIES AT THE STM*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

BIRDS

Turkey vulture Cathartes aura X

Vesper sparrow Pooecetes gramineus X

Virginia’s warbler Oreothlypis virginiae X 

Violet-green swallow Tachycineta thalassina X

Western kingbird Tyrannus verticalis X X

Western meadowlark Sturnella neglecta X X

Western scrub-jay Aphelocoma californica X

White-crowned sparrow Zonotrichia leucophrys X

White-faced ibis Plegadis chihi X

White-throated swift Aeronautes saxatalis X

Yellow-breasted chat Icteria virens X

Yellow-rumped warbler Dendroica coronata X

MAMMALS 

Black-tailed jackrabbit Lepus californicus X X

Bushy-tailed woodrat Neotoma cinerea X

Coyote Canis latrans X X X

Deer mouse Peromyscus maniculatus X X

Elk** Cervus canadensis

Fox squirrel Sciurus niger X

Long-tailed weasel Mustela frenata X 

Mexican woodrat Neotoma mexicana X X

Mountain cottontail Sylvilagus nuttalli X X X

Mule deer Odocoileus hemionus X X X

Prairie vole Microtus ochrogaster X X

Raccoon Procyon lotor X X X

Red fox Vulpes vulpes X X

Striped skunk Mephitis X

Western harvest mouse Reithrodontomys megalotis X X X

Western spotted skunk Spilogale gracilis X

White-tailed jackrabbit Lepus townsendii X

Yellow-bellied marmot Marmota flaviventris X

REPTILES AND AMPHIBIANS

Bull snake Pituophis catenifer X X

Plains garter snake Thamnophis radix X X

Prairie lizard Sceloporus undulatus X

Racer Coluber constrictor X

Six-lined racerunner Cnemidophorus sexlineatus X

Tiger salamander Ambystoma tigrinum X X

Western rattlesnake Crotalus viridus X X X

Woodhouse’s toad Bufo woodhousii X

*No terrestrial arthropod genera of specific concern were detected during surveys in 2010.

**Species observed at a time other than in a survey.
86 ENVIRONMENTAL PERFORMANCE REPORT 2012

Appendix B: Wildlife Species

Observed at the NWTC

WILDLIFE SPECIES AT THE NWTC*

SPECIES COMMON NAME SCIENTIFIC NAME 1996 Survey 2003 Survey 2011 Survey

BIRDS

American crow Corvus brachyrhynchos X

American goldfinch Spinus tristis X X

American kestrel Falco sparverius X X X

American pipit Anthus rubescens X

American robin Turdus migratorius X X

American tree sparrow Spizella arborea X

Bald eagle Haliaeetus leucocephalus X

Barn swallow Hirundo rustica X X

Black-billed magpie Pica hudsonia X X

Black-capped chickadee Poecile atricapillus X X

Blue-gray gnatcatcher Polioptila caerulea X

Blue jay Cyanocitta cristata X

Brewer's blackbird Euphagus cyanocephalus X X

Brewer's sparrow Spizella breweri X

Broad-tailed hummingbird Selasphorus platycercus X X

Broad-winged hawk Buteo platypterus X

Brown-headed cowbird Molothrus ater X X

Bullock's oriole Icterus bullockii X

Canada goose Branta canadensis X

Cedar waxwing Bombycilla cedrorum X

Chipping sparrow Spizella passerina X X

Cliff swallow Petrochelidon pyrrhonota X

Common grackle Quiscalus quiscula X X

Common nighthawk Chordeiles minor X

Common raven Corvus corax X X

Common snipe Gallinago delicata X

Cooper’s hawk Accipiter cooperii X

Dark-eyed junco Junco hyemalis X

Double-crested cormorant Phalacrocorax auritus X

Downy woodpecker Picoides pubescens X

Eurasian collared-dove Streptopelia decaocto X

European starling Sturnus vulgaris X X

Ferruginous hawk Buteo regalis X X

Franklin's gull Larus pipixcan X

Golden eagle Aquila chrysaetos X X X

Grasshopper sparrow Ammodramus savannarum X X
ENVIRONMENTAL PERFORMANCE REPORT 2012 87

WILDLIFE SPECIES AT THE NWTC*

SPECIES COMMON NAME SCIENTIFIC NAME 1996 Survey 2003 Survey 2011 Survey

BIRDS

Gray catbird Dumetella carolinensis X

Great blue heron Ardea herodias X X

Great horned owl Bubo virginianus X

Green-tailed towhee Pipilo chlorurus X

Hairy woodpecker Picoides villosus X

Horned lark Eremophila alpestris X X

House finch Carpodacus mexicanus X X

Killdeer Charadrius vociferus X

Lark bunting Calamospiza melanocorys X

Lark sparrow Chondestes grammacus X

Loggerhead shrike Lanius ludovicianus X

Long-billed curlew Numenius americanus X

Mallard Anas platyrhynchos X X

Merlin Falco columbarius X

Mountain bluebird Sialia currucoides X X

Mountain chickadee Poecile gambeli X

Mourning dove Zenaida macroura X X

Northern flicker Colaptes auratus X X

Northern goshawk Accipiter gentilis X

Northern harrier Circus cyaneus X X X

Osprey Pandion haliaetus X

Peregrine falcon Falco peregrinus X X

Prairie falcon Falco mexicanus X X

Red-headed woodpecker Melanerpes erythrocephalus X

Red-tailed hawk Buteo jamaicensis X X X

Red-winged blackbird Agelaius phoeniceus X X

Rough-legged hawk Buteo lagopus X X X

Ruby-crowned kinglet Regulus calendula X

Sandhill crane Grus canadensis X

Savannah sparrow Passerculus sandwichensis X

Say's phoebe Sayornis saya X X

Sharp-shinned hawk Accipiter striatus X

Song sparrow Melospiza melodia X

Spotted towhee Pipilo maculatus X

Swainson's hawk Buteo swainsoni X X

Tree swallow Tachycineta bicolor X

Turkey vulture Cathartes aura X X X

Vesper sparrow Pooecetes gramineus X X

Western kingbird Tyrannus verticalis X X

Western meadowlark Sturnella neglecta X X

Wilson’s warbler Wilsonia pusilla X

Yellow-rumped warbler Dendroica coronata X
88 ENVIRONMENTAL PERFORMANCE REPORT 2012

*The 1996 study addressed only raptors. Mammals, reptiles, amphibians, or terrestrial arthropods were not the subject of a survey at the NWTC until the 

2011 baseline survey.

**Species observed at a time other than in a survey.

WILDLIFE SPECIES AT THE NWTC*

SPECIES COMMON NAME SCIENTIFIC NAME 1996 Survey 2003 Survey 2011 Survey

MAMMALS

Big brown bat Eptesicus fuscus X

Black-tailed prairie dog** Cynomys ludovicianus

Bobcat** Felis rufus

Coyote Canis latrans X

Deer mouse Peromyscus maniculatus X

Desert cottontail Sylvilagus audubonii X

Eastern red bat Lasiurus borealis X

Elk Cervus canadensis X

Fringed myotis Myotis thysanodes X

Hoary bat Lasiurus cinereus X

Masked shrew Sorex cinereus X

Meadow vole Microtus pennsylvanicus X

Mexican woodrat Neotoma mexicana X

Mule deer Odocoileus hemionus X

Myotis bats Myotis sp. X

Prairie vole Microtus ochrogaster X

Silver-haired bat Lasionycteris noctivagans X

Thirteen-lined ground squirrel Spermophilus tridecemlineatus X

Western harvest mouse Reithrodontomys megalotis X

REPTILES AND AMPHIBIANS

Boreal chorus frog Pseudacris maculata X

Bull snake Pituophis catenifer X

Woodhouse’s toad Bufo woodhousii X

TERRESTRIAL ARTHROPODS

Aphrodite fritillary Speyeria aphrodite X

Cabbage white Pieris rapae X

Checkered white Pontia protodice X

Common wood nymph Cercyonis pegala X

Dainty sulphur Nathalis iole X

Gray hairstreak Strymon melinus X

Orange sulphur Colias eurytheme X

Western white Pontia occidentalis X
ENVIRONMENTAL PERFORMANCE REPORT 2012 89

Appendix C: Environmental Permits, 

Registrations, and Notifications 

Applicable to NREL During 2012

NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2012

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

AST for petroleum 

storage STM ESIF AST Registration DOPS OFL6097 Completed

AST for petroleum 

storage STM PDU AST Registration DOPS 2873-2 Completed

AST for petroleum 

storage STM RSF2 AST Registration DOPS OFL6023 Completed

AST for petroleum 

storage STM SERF AST Registration DOPS 2873-1 Completed

Air Laboratory-wide servicing of CFC-containing 

equipment Notification APCD 647 Completed

Air DWOP CFC-containing stationary source Registration APCD 647 Completed

Air STM SERF CFC-containing stationary source Registration APCD 647 Completed

Air STM FTLB waste gas combustor Permit APCD 99JE0400 Active

Air STM RFHP wood waste boiler Permit APCD 07JE0277 Active

Air STM fugitive dust from construction activities Permit APCD 08JE0889L Active

Air STM RSF diesel-fired standby electrical 

generator #1 Permit APCD 10JE1400 Active

Air STM RSF diesel-fired standby electrical 

generator #2 Permit APCD 11JE1303 Active

Air STM FTLB diesel-fired standby electrical 

generator Permit APCD 10JE1630 Active

Air NWTC Site 4.0 diesel-fired standby electrical 

generator Permit APCD 10JE1712 Active

Air STM parking garage diesel-fired standby 

electrical generator Permit APCD 11JE1997 Active

Air STM ESIF diesel-fired standby electrical 

generator Permit APCD 11JE3542 Active

Air STM IBRF scrubber and baghouse Permit APCD 11JE1798 Active

Alcohol STM IBRF alcohol fuel production Permit TTB AFP-CO-00255 Active

Alcohol STM tax-free alcohol use Permit TTB TF-CO-0331 Active

Drinking water 

system NWTC drinking water system ID number Registration WQCD CO0230860 In Effect; Does Not Expire

Earth disturbance STM stormwater detention basin grading 

permit Permit Jefferson County 10-126950GP Active

Earth disturbance STM stormwater detention basin grading 

permit (berm) Permit Jefferson 

County 10-106216GB Closed

Earth disturbance STM parking lot grading permit Permit Jefferson 

County 10-127351GP Active

Groundwater well STM groundwater monitoring well MW-1 Permit DWR 37232 Active

Groundwater well STM groundwater monitoring well MW-2 Permit DWR 37229 Active
90 ENVIRONMENTAL PERFORMANCE REPORT 2012

NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2012

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

Groundwater well STM groundwater monitoring well MW-3 Permit DWR 37228 Active

Groundwater well STM groundwater monitoring well MW-4 Permit DWR 37231 Active

Groundwater well STM groundwater monitoring well MW-5 Permit DWR 37230 Active

Hazardous materials STM WHF hazardous material storage and use 

permit Permit WMFR 4976 Active

Hazardous materials STM SERF hazardous material storage and use 

permit Permit WMFR 4982 Active

Hazardous materials STM S&TF hazardous material storage and use 

permit Permit WMFR 4979 Active

Hazardous materials STM FTLB hazardous material storage and use 

permit Permit WMFR 4977 Active

Hazardous materials STM IBRF hazardous material storage and use 

permit Permit WMFR 4978 Active

Hazardous materials STM Shipping and Receiving hazardous 

material storage and use permit Permit WMFR 4980 Active

Hazardous materials DWOP building 16 hazardous material storage 

and use permit Permit WMFR 4981 Active

Hazardous materials ReFUEL hazardous material storage and use 

permit Permit Denver Fire 

Department 32178 Active

Hazardous waste DWOP RCRA hazardous waste generator status 

EPA ID Notification HMWMD CO4890000017 Completed

Hazardous waste STM RCRA hazardous waste generator status 

EPA ID Notification HMWMD CO3890090076 Completed

Hazardous waste JSF RCRA hazardous waste generator status 

EPA ID Notification HMWMD COD980805162 Completed

Hazardous waste NWTC RCRA hazardous waste generator status 

EPA ID Notification HMWMD COD983802448 Completed

Hazardous waste ReFUEL RCRA hazardous waste generator status 

EPA ID Notification HMWMD COR000207563 Completed

Historic registration STM amphitheater Registration NPS 93000378

In effect; 

does not 

expire

Historic registration STM stone bunker Registration NPS 93000379

In effect; 

does not 

expire

Stormwater NWTC pedestrian safety construction project Permit EPA COR10ES2F Terminated

Stormwater NWTC pedestrian safety construction project Permit EPA COR12A43F Active

Stormwater STM stormwater detention basin construction 

project Permit EPA COR10EL5F Terminated

Stormwater STM stormwater detention basin construction 

project Permit EPA COR12A36F Active

Stormwater STM ESIF construction project Permit EPA COR10EH4F Terminated

Stormwater STM ESIF construction project Permit EPA COR12A60F Active

Stormwater STM parking garage and south entrance 

construction project Permit EPA COR10EE0F Terminated

Stormwater STM parking garage and south entrance 

construction project Permit EPA COR12A61F Active
ENVIRONMENTAL PERFORMANCE REPORT 2012 91

APCD - Air Pollution Control Division

AST – Aboveground Storage Tank

CFC - Chlorofluorocarbon

DFD - Denver Fire Department

DOPS - Division of Oil and Public Safety of the Colorado 

Department of Labor and Employment

DWOP - Denver West Office Park

DWR - Division of Water Resources

EPA - Environmental Protection Agency

ESIF - Energy Systems Integration Facility

FTLB - Field Test Laboratory Building 

HMWMD - Hazardous Materials and Waste Management 

Division of CDPHE

IBRF - Integrated Biorefinery Research Facility

NPS - National Park Service

NWTC - National Wind Technology Center

PDU - Process Development Unit

RCRA - Resource Conservation and Recovery Act

ReFUEL - Renewable Fuel and Lubricants Research 

Laboratory 

RFHP - Renewable Fuel Heat Plant 

RSF - Research Support Facility

S&TF - Science and Technology Facility

SERF - Solar Energy Research Facility

STM - South Table Mountain

TTB - Alcohol and Tobacco Tax and Trade Bureau of the U.S. 

Department of the Treasury

WHF - Waste Handling Facility

WMFR - West Metro Fire Rescue

WQCD - Water Quality Control Division of Colorado 

Department of Public Health and Environment

NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2012

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

Stormwater NWTC dynamometer expansion construction 

project Permit EPA COR10EP6F Terminated

Stormwater NWTC dynamometer expansion construction 

project Permit EPA COR12A41F Active

Stormwater STM RSF II Construction Project Permit EPA COR10E21F Terminated

Stormwater STM RSF II Construction Project Permit EPA COR12A62F Active

Stormwater STM IBRF construction project Permit EPA COR10DA6F Terminated

Stormwater STM IBRF construction project Permit EPA COR12A64F Active

Stormwater STM west gate improvements construction 

project Permit EPA COR10E08F Terminated

Stormwater STM vehicle test pad construction project Permit EPA COR10E12F Terminated

Stormwater STM vehicle test pad construction project Permit EPA COR12A63F Active

Stormwater NWTC site entrance construction project Permit EPA COR10E06F Terminated


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