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.

Environmental Performance Report 2013

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

NREL prints on paper that contains recycled content.

Cover Photo: Feather reed grass used in landscaping in front of the ESIF at NREL’s STM campus in Golden, CO.

Photo by Dennis Schroeder, NREL 27750
ENVIRONMENTAL PERFORMANCE REPORT 2013 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.

The National Renewable Energy Laboratory’s 

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

Office staff provided their subject matter expertise 

by authoring content, providing data, and 

conducting technical reviews:

Brenda Beatty

Genny Braus

Larry Durbin

John Eickhoff

Bob Fiehweg

Maureen Ray

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.

Theresa von Kuegelgen and Bruce Green with 

NREL’s Communications and Public Affairs Office 

provided editing and project support.

Lori Gray, Robert Smith, Robin Sweeney, and 

Amy Van Dercook with the U.S. Department of 

Energy Golden Field Office, worked closely with 

staff of the Alliance for Sustainable Energy, LLC, to 

continuously improve the report and conducted 

the review and approval process. 

Acknowledgements Contact Us

We welcome your feedback and suggestions on this 

report and on NREL’s efforts toward sustainability and 

environmental stewardship. To provide comments, 

to request a printed copy of this report, or to obtain 

additional information about NREL’s environmental 

programs, please contact:

Maureen Ray

Director, EHS Office

maureen.ray@nrel.gov

303-275-3248

John Eickhoff 

Environmental Manager 

john.eickhoff@nrel.gov 

303-275-3217 

Thomas Stites

Director, Communications & Public Affairs Office

tom.stites@nrel.gov

303-275-3650

This report is available online at:

www.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 2013

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

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

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

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......................14

2 Significant Activities in 2013....................................................15

2.1 Major and Minor Construction Projects........................15

2.2 Integrated Environmental Stewardship in 

Construction Management................................................16

3 Environmental Management System and

Pollution Prevention ...................................................................17

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

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

3.3 Performance Indicators and Progress............................20

3.4 Assessment and Improvement ........................................20

3.5 2013 Awards and Recognition .........................................23

4 Sustainability .................................................................................25

4.1 Site Sustainability Planning...............................................26

4.2 2013 SSPP Goal Performance............................................27

5 Compliance Summary................................................................29

6 Air Quality Protection .................................................................36

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

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

7.2 Groundwater...........................................................................41

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

TABLE OF CONTENTS

NREL Environmental Performance Report 2013
ENVIRONMENTAL PERFORMANCE REPORT 2013 3

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 Management...................49

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

8.5 Radiological Materials and Waste Management........51

9 National Environmental Policy Act........................................52

10 Natural and Cultural Resources Protection.........................55

10.1 Wildlife Management........................................................55

10.2 Endangered Species and Species of Concern..........58

10.3 Vegetation Management.................................................59

10.4 Wetlands and Floodplains...............................................63

10.5 Cultural Resources..............................................................64

11 Conservation Easement Lands ..............................................67

12 Traffic Management....................................................................69

Appendix A: Plant Communities at the 

STM and the NWTC............................................................................72

Appendix B: Wildlife Species Observed at the

STM and the NWTC............................................................................79

Appendix C: Environmental Permits, Registrations,

and Notifications Applicable to NREL During 2013...............85
4 ENVIRONMENTAL PERFORMANCE REPORT 2013

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

CO2e—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 GO—Department of Energy Golden Field Office

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

DWR—Colorado Division of Water Resources

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

FAA—Federal Aviation Administration

FDA— Food and Drug Administration

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

HAA5—Haloacetic Acids

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

LOS—Level of Service

LQG—Large Quantity Generator 

MAP—Mitigation Action Plan

MBTA—Migratory Bird Treaty Act

MCL—Maximum Contaminant Level

MOA— Memorandum of Agreement

MOU—Memorandum of Understanding

mrem—Millirem

MSDS—Material Safety Data Sheet (replaced by SDS)

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

NESHAPs—National Emission Standards for Hazardous Air Pollutants

NOI—Notice of Intent

NPS—National Park Service

ODS—Ozone Depleting Substance

OHSAS—Occupational Health & Safety Advisory Services

OTF—Outdoor Test Facility

PM—Particulate Matter

PUE—Power Usage Effectiveness

PV—Photovoltaic 

RCRA—Resource Conservation and Recovery Act

ReFUEL—Renewable Fuel and Lubricants Research Laboratory

REC—Renewable Energy Credit 

RFA—Rocky Flats Alluvium

RFHP—Renewable Fuel Heat Plant

RFID—Radio Frequency Identification 

RFP—Request for Proposal

RSF—Research Support Facility

RTD—Regional Transportation District

SARA—Superfund Amendments and Reauthorization Act

SDWA—Safe Drinking Water Act

SDS—Safety Data Sheet

SERF—Solar Energy Research Facility

SERI—Solar Energy Research Institute

SHPO—State Historic Preservation Officer

SITES—Sustainable Sites Initiative

SO2—Sulfur Dioxide

SolarTAC—Solar Technology Acceleration Center

SPCC—Spill Prevention Control and Countermeasures

SPO—Sustainability Performance Office

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

WMFR—West Metro Fire Rescue

WQCD—Water Quality Control Division of CDPHE
ENVIRONMENTAL PERFORMANCE REPORT 2013 5

PURPOSE

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

Environmental Performance Report provides a description of 

the laboratory’s environmental management activities for 

2013, 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 U.S. Department of Energy (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 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 plan-do-checkfeedback continual improvement framework depicted in 

Figure E-1, and is implemented as part of an Integrated 

Safety Management System (ISMS).

Each year, the laboratory sets measurable objectives and 

targets for environmental improvement through the NREL 

environmental management system planning process. 

Goals are established through the Performance Evaluation 

Measurement Plan, Site Sustainability Plan (SSP), and 

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 (STM) 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 clean-energy alternatives for 

powering our homes and businesses, and the 

nation’s transportation infrastructure. NREL’s science 

and technology teams span the full spectrum of 

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

and validation. 

Photo: Researchers demonstrate the automated transfer 

chamber system to move samples between tools while 

maintaining vacuum using a mobile chamber. Photo by 

Dennis Schroeder, NREL 24997

EXECUTIVE SUMMARY
6 ENVIRONMENTAL PERFORMANCE REPORT 2013

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 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 NREL 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 to 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.

During 2013, NREL continued its excellent record of 

environmental leadership and sustainability 

performance. The following are some of the laboratory’s 

key accomplishments:

■ Achieved key short-term internal environmental and 

sustainability goals, and made progress toward longterm goals (see sections 3 and 4 for details).

■ Received several awards and recognitions for 

environmental and sustainability accomplishments 

(see sidebar at the top of next column).

■ Maintained International Organization for Standardization (ISO) 14001:2004 environmental management 

system certification.

■ Maintained Colorado Environmental Leadership 

Program Gold-level Leader status, the highest level 

awarded by the state-sponsored program. 

■ Received LEED Platinum (Leadership in Energy and 

Environmental Design) certification from the U.S. Green 

Building Council for two new high-performance sustainable buildings, the Energy Systems Integration Facility 

(ESIF) and the NREL Café.

■ Received SITES (Sustainable Sites Initiative) certification 

for sustainable landscape design and management.

■ Enhanced campus “green infrastructure” by installing 

porous pavers to replace 800 feet (244 meters) of asphalt 

roadway at the STM campus, increasing stormwater 

infiltration. 

■ Initiated a radio frequency identification (RFID) 

chemical-inventory pilot project to improve hazardous 

materials management.

■ Reduced overall hazardous and nonhazardous waste 

volumes significantly from the prior year.

■ Prevented migratory bird collisions with glass bus shelters by adding a film visible to birds; shared the laboratory’s experience in reducing impacts to migratory birds 

within DOE and among other federal agencies.

■ Installed a public historical information display just 

south of the STM campus with information about the 

Define Scope

Analyze

Hazards,

Perform Work

Develop Controls

Feedback &

Improvement

Environment

Quality Safety

Impacts & Issues

Figure E-1. NREL’s continual improvement cycle.

Prestigious Environmental 

Sustainability Awards Received

NREL received several important recognitions 

in 2013 for its environmental and sustainability 

accomplishments including:

■ A DOE Green Buy Program Gold Award for 

purchasing 16 products in five different 

categories, achieving DOE’s Green Buy 

leadership goal.

■ A Best Workplace for Commuters recognition 

by the National Center for Urban 

Transportation Research.

■ Environmental Protection Agency (EPA) 

Federal Green Challenge recognition 

both nationally and in Region 8 for green 

purchasing.

■ A Platinum-level Federal Electronics 

Challenge (FEC) Award, issued by the the 

Office of the Federal Environmental Executive 

and the EPA, recognized the laboratory’s 

leadership in green electronics purchasing, 

management, and recycling.
ENVIRONMENTAL PERFORMANCE REPORT 2013 7

former Camp George West site used by the Colorado 

National Guard throughout the first half of the 1900s.

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

alternative commuting options such as access to mass 

transit, vanpool discounts, preferred parking for carpool/

vanpool vehicles, ride-share coordination, and bicycle 

and pedestrian infrastructure.

■ Reduced the laboratory’s peak traffic impacts by 

constructing an additional right-turn lane in the eastbound direction at the intersection of Denver West 

Parkway and Denver West Marriott Boulevard near the 

STM campus. 

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 does not 

conduct continuous radiation or radiological 

contamination monitoring.

The laboratory continued its excellent record of 

environmental compliance in 2013. 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. Actions were taken in two instances to 

correct circumstances that could lead to a violation.

A Compliance Advisory was received from the state when 

a required quarterly sample for haloacetic acids, a class 

of disinfection byproducts (DBPs), was not collected for 

the NWTC drinking water system. Although there was 

no impact to users, the laboratory posted a notification 

regarding the missed sampling event. Samples for the 

remainder of the year were collected according to schedule 

as required, and the results showed DBP levels well below 

the maximum allowed. 

NREL is committed to protecting wildlife on campus 

and workers are encouraged to notify staff biologists of 

situations that could impact wildlife. Over several months, 

workers at the recently constructed ESIF reported several 

instances of birds colliding with the building’s windows. An 

immediate interim solution was implemented by installing 

bird-visible decals on select windows. A long-term solution 

has been developed and is planned for implementation in 

early 2014.

Environmental Management Programs

The laboratory continues to meet or exceed compliance 

requirements and strives to make continual improvements 

in environmental management. Major environmental 

program areas include:

■ Air quality protection, including air permitting, ozone 

depleting substance (ODS) management, and greenhouse gas (GHG) emissions monitoring

■ Water quality protection, including construction 

stormwater management, drinking water monitoring, and preventing unallowable sanitary sewer 

system discharges

■ Hazardous materials and waste management, including 

pollution prevention, spill response, proper storage, use, 

and disposal of hazardous chemicals and materials, as 

well as planning, permitting, and reporting regarding 

use and emissions of such materials

■ National Environmental Policy Act (NEPA) reviews

■ Natural and cultural resources protection, including 

wildlife, vegetation, protected species, wetlands, and 

cultural resources management. 

The laboratory continued to improve its environmental 

management and performance in 2013. A track record 

of excellent compliance with regulatory requirements 

and demonstrated leadership in environmental and 

sustainability management continued.

NREL’s Continued ISO 14001 

Certification Demonstrates 

Commitment to Environmental 

Leadership

In 2013, the laboratory maintained ISO 

14001:2004 certification of its environmental 

management system. A team of external 

auditors conducted an independent assessment 

of the policies, procedures, tools, and roles 

and responsibilities used in environmental 

management. The assessment verified that the 

laboratory continues to meet the requirements 

of the ISO 14001 standard and demonstrates our 

commitment to environmental stewardship.
8 ENVIRONMENTAL PERFORMANCE REPORT 2013

1.1 PURPOSE 

This report presents a summary of the National Renewable Energy Laboratory’s (NREL’s) 2013 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 

Admin. Chg. 1, 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 

The Insight Center at NREL combines state-of-theart visualization and collaboration tools to promote 

knowledge discovery in energy systems integration. 

Photo by Denny Gruchalla, NREL 25944

1 INTRODUCTION
ENVIRONMENTAL PERFORMANCE REPORT 2013 9

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 end-use 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. 

■ 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)

■ Renewable Fuel and Lubricants Research Laboratory 

(ReFUEL), located in Denver.

Sustainable landscaping at the RSF. Photo by Robb Williamson, 

NREL 29509
10 ENVIRONMENTAL PERFORMANCE REPORT 2013

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 single high bay and 

small office area 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 Site 

The STM site is the main research center for NREL—

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

laboratories there. The STM site is approximately two 

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

(19.3 km) west of central Denver.

Land Use

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

slopes of South Table Mountain, a mesa that stands 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 (132 hectares) area predominantly bordered by open grassland zoned for recreation 

and light-commercial activity. Portions of the community 

of Pleasant View are located immediately to the south and 

west. Pleasant View has constructed a recreational park 

immediately south of the STM site. Offices, shops, and a 

tree nursery owned by the Colorado State Forest Service 

are located at the far western edge. Undeveloped state 

land and a Colorado State Highway Patrol pursuit drivertraining track are located along the northwestern boundary of the STM site on top of the mesa. Jefferson County 

open space wraps around the northern and the eastern 

Visitor Center

FTLB

SERF TTF

SEB

NREL campus yesterday...

South Gate / SSEB

TTF

OTF

IBRF

West Gate

Parking Garage

Central Arroyo Detention Pond

East Gate/SEB

S&TF

SERF

VTIF

RSF

FTLB

Cafeteria

Visitor Parking

Visitor Center

SSRL PV Arrays

ESIF

NREL’s STM campus today. Inset photo the STM campus yesterday. Photo by Dennis Schroeder, NREL 23326.

Inset photo by Warren Gretz, NREL 12568 
ENVIRONMENTAL PERFORMANCE REPORT 2013 11

edge of the site. Portions of DWOP and apartment homes 

lie to the east. 

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

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

existing utility easements and recreational trails to be 

established by Jefferson County Open Space (for more 

detail, see section 11 Conservation Easement Lands).

Geology, Soils, and Hydrogeology 

The mesa was formed as weak sedimentary rocks 

surrounding the lava were eroded away, leaving the 

lava-capped mesa in relief. Below the lava caprock, the 

sedimentary rocks are part of the Denver Formation that 

consists of layers and lenses of claystone, sandstone, 

and conglomerate. Sedimentary rocks of the Arapahoe 

Formation underlie the Denver Formation. 

Both the Arapahoe and Denver Formations are considered 

to be aquifers in portions of the Denver Basin. The Denver 

Formation underlies the areas on which most NREL 

construction has taken place. Groundwater on the STM 

site occurs primarily in the weathered and fractured silts 

and sands of the Denver Formation. There may also be 

some groundwater in the form of perched aquifers below 

the basaltic lava cap on South Table Mountain, and within 

the materials above the Denver Formation, which are 

largely the result of stream deposits. Groundwater flow on 

the site is in a southeasterly direction. 

The soil covering the top of South Table Mountain is 

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

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

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

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

clay. Much of the remainder of the site, including the area 

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

of clayey material containing some calcium carbonate. 

There are also two smaller soil areas on the southwestern 

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

soils—cobbly clay loam and very stony clay loam.

Surface Water 

About 90% of the surface drainage 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 mid-grass species. Two primary upland shrub 

communities occur on the STM site: mountain mahogany 

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

upland shrublands, occurring in drainages lacking active 

channels as well as drainages with associated wetlands. 

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

identified on the STM site are a minor component of the 

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

vegetation over an area of less than 0.3 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. 
12 ENVIRONMENTAL PERFORMANCE REPORT 2013

National Wind Technology Center

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

border just east of the foothills of the Rocky Mountains, 

the NWTC has abundant wind resources that are critical 

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

is located near the intersection of Highways 93 and 128, 

between Boulder and Golden, and is approximately 15 

miles (24.2 km) north of the STM site. 

Land Use 

The NWTC facility occupies a 305-acre (124-hectares) 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. 

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. 

2, 3 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, Colorado.

National Wind Technology Center. Photo by Dennis Schroeder,

 NREL 25869

1

 EG&G Rocky Flats, Inc. (1992). Rocky Flats Plant Site Environmental Report, January Through December 1992. Golden, Colorado. 
ENVIRONMENTAL PERFORMANCE REPORT 2013 13

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, white-tailed jackrabbits, black-tailed jackrabbits, deer mice, prairie voles, and thirteen-lined ground 

squirrels. Approximately 20 different species of birds were 

sighted at or near the site. Raptor 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 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 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 Fuel and Lubricants 

Research Laboratory 

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 consists of a single high bay and small office area 

housed within the RTD DSOC at 1900 31st Street, Denver, 

about 12 miles (20 km) east of the STM and DWOP sites. 

The RTD DSOC facility occupies approximately 22 acres (9 

hectares) 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 on-site or in the 

immediate vicinity. There are trees and shrubs lining the 

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

and northeastern borders. 

Additional Locations 

■ Laboratory staff 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 

NREL engineer blends fuel to be used for biofuels testing at 

ReFUEL. Photo by Dennis Schroeder, NREL 22735
14 ENVIRONMENTAL PERFORMANCE REPORT 2013

that want to make use of a real-world outdoor site to 

develop, test, validate, or showcase solar products. 

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

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

readily accessible land and all the necessary infrastructure and resources needed to rapidly and economically 

install their technologies. NREL 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. 

■ Regional Test Center—This project is testing PV technologies through partnerships with manufacturers.

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 20 inches [50 centimeters (cm)]. Almost half of the annual precipitation occurs 

from March to June. Summer showers contribute 33% 

of the annual precipitation total. Precipitation begins to 

decrease significantly in the fall, reaching the minimum 

during winter. Winter is the driest season, contributing 

less than 10% of the annual precipitation, primarily in the 

form of snowfall. 

Spring is a season of unstable air masses with strong winds 

along the foothills and the Front Range. The highest average 

snowfall occurs in March, and the STM site can generally 

expect to experience at least one heavy snowstorm with 

totals exceeding 6 to 10 inches (15 to 25 cm). 

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.

 CPV array at SolarTAC in Aurora, Colorado. Photo by 

Dennis Schroeder, NREL 25538
ENVIRONMENTAL PERFORMANCE REPORT 2013 15

In 2013, there was less construction activity on the STM 

and NWTC campuses than in the previous couple of 

years, though numerous minor construction projects 

were underway. 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 CONSTRUCTION PROJECTS

Projects underway in 2013 included: 

■ Improvements to the onsite portion of Denver West 

Parkway, including installation of permeable pavers, 

were completed.

■ Improvements to fire suppression systems were 

completed to enhance fire water supply to the 

western end of the STM campus.

■ The dynamometer expansion project was completed 

at the NWTC.

■ Work on the Regional Test Center at SolarTAC 

was completed.

■ An additional right-turn lane was completed at the 

intersection of Denver West Parkway and Denver West 

Marriott Boulevard. Landscaping improvements were 

initiated at the Solar Energy Research Facility (SERF) 

and Science and Technology Facility (S&TF).

■ An upgrade to the STM site-wide electrical system 

was begun.

2 SIGNIFICANT ACTIVITIES 

IN 2013

DOE and NREL dedicate the new Dynamometer Test 

Facility at the NWTC. One of the largest dynamometers 

in the world, the new facility will test wind turbine 

drivetrains with capacity ratings up to 5 megawatts. 

Photo by Dennis Schroeder, NREL 28244
16 ENVIRONMENTAL PERFORMANCE REPORT 2013

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 

on-site to support net-zero energy use on campus; using 

passive solar design; using radiant heating and cooling; 

using underfloor ventilation; letting occupants open 

and close windows; using no- and low-volatile organice 

compound (VOC) materials and products selected from 

reputable, certified product label systems such as Green 

Seal, EcoLogo, and the EPA’s WaterSense program; using 

daylighting and lighting controls; designing with wildlife 

in mind; and incorporating low-impact design elements 

to retain stormwater on-site through infiltration.

Environmentally Responsible 

Construction Practices

During construction, DOE and NREL staff participate in 

weekly construction team meetings, monitor performance criteria, and provide ongoing feedback to the 

project team regarding environmental management. 

Some examples of environmentally responsible construction practices include pre-construction review of project 

plans, using a “plan of the day” to coordinate and control 

activities, implementation of stormwater controls prior to 

starting excavations, keeping wildlife safe, tracking 

waste diversion, minimizing and cleaning up spills, and 

controlling dust.
ENVIRONMENTAL PERFORMANCE REPORT 2013 17

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. 

The EMS is implemented as part of a DOE-required Integrated Safety Management System (ISMS) and involves 

all workers at the laboratory. The ISMS systematically 

integrates safety and environmental protection into 

3

ENVIRONMENTAL

MANAGEMENT SYSTEM 

AND POLLUTION 

PREVENTION

Composting and recycling reduce the laboratory’s 

environmental footprint. Photo by Dennis Schroeder, 

NREL 27221

NREL’s Environmental Aspects

NREL conducts an annual review of its 

activities that could potentially affect the 

environment. The laboratory’s significant 

environmental aspects for 2013 were:

■ Air emissions

■ Surface water and 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 EMS.
18 ENVIRONMENTAL PERFORMANCE REPORT 2013

management and work practices at all levels to protect 

the public, the worker, and the environment.

The laboratory is continually working to reduce waste and 

prevent pollution, reducing its environmental footprint. 

Pollution prevention is implemented through the laboratory’s EMS, the Hazard Identification and Control program, 

and the Sustainable NREL program.

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 Figure 1. 

Planning

■ Environmental policy—NREL states its commitments to 

the environment through this overarching policy. The 

policy commits specifically to:

● Environmental stewardship

● Pollution prevention 

● Compliance with legal requirements and 

voluntary commitments

● Continual improvement of environmental and 

sustainability performance.

■ Environmental aspects—NREL’s environmental aspects 

are those activities, products, or services that have 

the potential to interact with the environment. The 

significance of an identified aspect is determined by 

assigning a frequency of occurrence and a severity. Using this method, NREL’s Environment, Health, 

& Safety (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 (EOs), and DOE orders.

■ 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 

3.3, 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 

Define Scope

Analyze

H

azards,

Perform Work

Develop Controls

Feedback &

Improvement

Environment

Quality Safety

Impacts & Issues

ISO 14001:2004 Certified

NREL’s EMS is certified to the International 

Organization for Standardization (ISO) 

14001:2004 standard for environmental 

management systems. ISO 14001 is a 

globally recognized standard that defines the 

structure of an organization’s EMS to improve 

its environmental performance. ISO 14001 

requires an organization to identify potential 

environmental impacts and establish controls 

needed to minimize impacts, to monitor and 

communicate environmental performance, and 

to establish a formal process for continually 

improving the system. Figure 1. NREL’s continual improvement cycle.
ENVIRONMENTAL PERFORMANCE REPORT 2013 19

and the community, such as community meetings, 

lunch-and-learn 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 3.4, 

Assessment and Improvement).

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 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. 

DOE O 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, both of 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 also requires that DOE facilities 

comply with the Pollution Prevention Act of 1990 and 

support pollution prevention. 

NREL has made a formal commitment to pollution 

prevention through its laboratory-wide environmental 

policy. NREL fulfills this commitment by implementing a 

variety of controls to reduce the potential environmental 

impacts of laboratory operations. 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. NREL’s hazard 

Workers reduce pollution by substituting less hazardous 

chemicals whenever feasible. Photo by David Parsons, NREL 04860

Facilities at NREL are designed to reduce waste and prevent 

pollution. The library in the RSF is designed with energy saving 

appliances and recycled materials. Photo by Dennis Schroeder, 

NREL 23241
20 ENVIRONMENTAL PERFORMANCE REPORT 2013

identification and control process helps staff regularly 

identify opportunities to prevent pollution, and formal 

pollution prevention assessments are conducted periodically to identify opportunities to reduce pollution and 

improve program effectiveness. In addition, resources are 

dedicated for sustainable operations and pollution 

prevention through the Sustainable NREL program.

3.3 PERFORMANCE INDICATORS 

AND PROGRESS

■ Each year measurable goals for environmental 

improvement are set. Goals are set through the 

following:

■ Performance Evaluation Measurement Plan—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)—Sustainable NREL 

develops an SSP each year to establish sustainability 

performance commitments for the year and document activities in support of EO 13514 requirements. 

Results of the plan are presented in the next chapter of 

this report. 

■ Goals are owned by individuals and groups throughout the laboratory. Progress on each of these goals is 

tracked throughout the year and results are reported 

annually. Some examples of performance for the year 

are described in Table 1.

3.4 ASSESSMENT AND 

IMPROVEMENT

Assessments support the continual improvement of 

environmental management. Periodic assessment of 

the EMS and its components provides assurance that 

the EMS continues to be an effective tool to achieve and 

maintain compliance with regulatory and legal requirements, meet the established environmental goals of the 

laboratory, and demonstrate to ourselves and others that 

NREL is “walking the talk.” 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.

■ 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. 

■ 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. 

2013 Assessments

In 2013, 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.

Reducing Pollution

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 greenhouse gas emissions and use of Colorado’s 

limited water supplies.
ENVIRONMENTAL PERFORMANCE REPORT 2013 21

TABLE 1. 2013 ENVIRONMENTAL GOALS AND ACHIEVEMENTS

2013 Goals 2013 Examples Goal 

Met?

Integrate environmental planning 

with NREL program and project 

planning

Identified lessons learned from the NWTC Environmental Assessment (EA) internal process and 

transferred these concepts to the STM EA. 

Modified the capital projects process to include an EHS review prior to funding determination by 

senior/executive management. Additionally, environmental risks are included as a risk category in 

a project template for use in assessing technical partnership project risks.

Implemented “environment” as a standing item at the monthly construction project 

management group meetings.

Yes

Actively identify potential EHS risks 

and modify practices accordingly

Improved stormwater protection program performance across campus by including stormwater 

management requirements in construction specifications and requiring construction contractors 

to have proper stormwater protections in place prior to granting an excavation permit.

Reduced the risk of migratory bird collisions and resulting deaths by retrofitting all existing glass 

bus shelters on campus by adding “CollidEscape” film.

Shared the laboratory’s expertise in reducing impacts to migratory birds by 1) nominating NREL’s 

work on bird-friendly bus shelters and parking garage for the 2013 Presidential Migratory Bird 

Federal Stewardship Award, and 2) responding to numerous requests for information on birdsafe design from the public and stakeholders, including the Food and Drug Administration (FDA) 

and Federal Aviation Administration (FAA).

Yes

Maintain ISO 14001 and OHSAS 

18001 certifications 

Completed an annual third-party audit which verified the laboratory’s continued conformance 

with the ISO 14001 and Occupational Health & Safety Advisory Services (OHSAS) 18001 

management system standards.

Completed corrective actions and opportunities for improvement from the prior year ISO/OHSAS 

surveillance audit.

Improved procedures regarding assessments, corrective action management, and 

document control.

Completed an internal audit of the Particulate Emission Control for Construction Program.

Maintained EHS performance data on the NREL dashboard; senior managers across the lab use 

the dashboard as a tool for communicating EHS performance issues with their staff.

Yes

Reduce impacts of employee 

commuting by reducing individual 

vehicle miles travelled and to 

implement a traffic mitigation plan 

for the STM campus—including 

alternative work schedules and 

telecommuting

Throughout 2013, traffic monitoring and intersection analysis indicated that NREL-generated 

traffic volumes and levels of service remained within acceptable levels.

NREL continues to offer incentives for employees to participate in alternative commuting options 

such as access to mass transit, vanpool discounts, preferred parking for carpool/vanpool vehicles, 

ride-share coordination, and bicycle and pedestrian infrastructure (i.e., bicycle maintenance 

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

Yes

To support NREL’s long-term goal 

of achieving a net-zero energy 

campus, seek to reduce electricity 

use per square foot by 3% per year, 

starting with a 2008 baseline

NREL exceeded its goal of 3% per year reduction in energy use per square foot (from a 2008 

baseline), reducing energy use from 277 to 183 kBtu/sq. ft. The reduction was due to the 

implementation of energy efficiency measures and construction of several highly energy 

efficient facilities.

Yes

Seek certification in the SITES—

Pilot Program on Landscaping 

Green Certification for 

Sustainable Landscaping

NREL received the Sustainable Sites Initiative (SITES) Green Certification, with a score of three out 

of four possible stars. The laboratory expanded its initial goal to certify the Research Support 

Facility (RSF) and included two newly constructed projects, a stormwater detention area, as well 

as a parking garage and new site entrance building. Sustainable landscaping features include 

plants and trees that are Colorado native or adapted and non-invasive species, landscaping 

walls built from stone excavated on-site, pavers designed to allow stormwater to infiltrate and 

enhance water quality, and drip irrigation.

Yes
22 ENVIRONMENTAL PERFORMANCE REPORT 2013

The following assessment activities took place in 2013:

■ Internal assessments—An internal assessment was 

conducted of the laboratory’s Particulate Emission 

Control for Construction Program. Scheduled interviews 

were conducted, and reviews of relevant procedures 

and records were completed. Three opportunities for 

improvement were identified and have been addressed. 

■ Evaluations of compliance—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 the prior year. 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:

● Emergency Planning and Community Right-toKnow Act (EPCRA) reporting

● Ozone depleting substances management

● EMS

● Environmental and sustainability management

● EHS inspections

● National Environmental Policy Act (NEPA).

Two areas of potential non-compliance with regulatory 

requirements were identified and have been addressed, 

including incomplete records of service for equipment 

containing 50 or more pounds of ozone-depleting 

substances (ODS), and disinfectant byproducts present 

in the NWTC drinking water supply above the 

applicable standard. 

■ External assessments—in 2013, NREL maintained its 

certification under ISO 14001. 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 three findings and 

several opportunities for improvement. Corrective 

actions are underway to address deficiencies in training, document control, and risk control. 

2013 Accomplishments and Highlights

■ In 2013, NREL maintained its ISO 14001:2004 

certification. 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.

■ In 2013, the laboratory worked to enhance 

the integration of environmental and safety 

considerations into laboratory planning 

processes (see Table 1). 

■ The laboratory’s multiple policies related to 

environment, health, and safety management 

were combined and streamlined to eliminate 

redundancy and improve the clarity of 

NREL’s commitments. Related laboratory 

procedures were reorganized to match the 

new policy structure.

■ NREL developed improved metrics for 

monitoring performance on environmental 

objectives and targets, training, and 

inspection completion.

■ The laboratory improved laboratory 

procedures for assessments, corrective 

action management, and document control.

■ NREL conducted several internal assessments 

of environmental management programs and 

identified areas for continual improvement 

(for details, see section 3.4, Assessment 

and Improvement). 

■ The laboratory completed two pollution 

prevention assessments regarding the 

potential to recycle used or broken PV 

panels and the potential to use biodiesel as 

a viable fuel in backup generators. In each 

assessment, it was determined that there was 

currently no feasible alternative.
ENVIRONMENTAL PERFORMANCE REPORT 2013 23

3.5 2013 AWARDS AND 

RECOGNITION

In 2013, NREL received several awards and recognition 

of its environmental and sustainability achievements 

including:

■ DOE Green Buy Program Gold Award

■ Federal Electronics Challenge (FEC) Platinum Award

■ Best Workplace for Commuters Award

■ Federal Green Challenge Award

■ CELP Gold-Level Leader.

DOE Green Buy Program Gold Award

NREL received a DOE Green Buy Program Gold Award for 

purchasing 16 priority product types, achieving excellence in sustainable acquisition.

FEC Platinum Award

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

■ Manage obsolete electronics in an environmentally 

safe way. 

The FEC award program ended in August 2013. Going 

forward, the laboratory will seek recognition for its leadership in electronic stewardship through the EPA’s Federal 

Green Challenge.

Best Workplace for Commuters

The laboratory was recognized as a Best Workplace 

for Commuters by the National Center for Urban 

Transportation Research.

Federal Green Challenge

NREL was recognized in the U.S. Environmental Protection 

Agency (EPA) Federal Green Challenge both nationally 

and in Region 8 for green purchasing. 

Colorado Environmental Leadership 

Program Gold-Level Leader

NREL maintained its status as a CELP Gold-level Leader, 

the highest level awarded by the program. 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 focuses on incorporating 

environmental considerations into normal management processes and improving internal environmental 

management effectiveness)

■ Work closely with their communities

■ Establish three-year goals focusing on 

measurable results.

Learn more about this voluntary program at the 

CDPHE CELP website: www.colorado.gov/cs/Satellite/

CDPHE-DEHS/CBON/1251583700741. 
24 ENVIRONMENTAL PERFORMANCE REPORT 2013

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.
ENVIRONMENTAL PERFORMANCE REPORT 2013 25

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 EOs, 

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

■ Measurement and tracking of environmental 

objectives, targets, and actions

■ Pollution prevention assessments and improvements

■ Awareness and engagement of staff and 

community members.

4 SUSTAINABILITY

The ESIF received LEED Platinum certification. 

Photo by Dennis Schroeder, NREL 25300
26 ENVIRONMENTAL PERFORMANCE REPORT 2013

4.1 SITE SUSTAINABILITY PLANNING

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 EO 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) 2014. 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 execution of the mission. 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 FY 2013, staff (i.e., employees and subcontractors) increased 4% from FY 2012, and the laboratory’s 

building square footage increased by 23%. While experiencing growth, in the current economic climate, it is 

uncertain if this trend will continue. While there are no new 

Congressional Line Item projects identified at this time, 

the laboratory is conducting planning activities so that 

it is positioned to accommodate future growth through 

the construction of new high-performance buildings, 

energy efficiency retrofits, and renewable energy systems 

2013 Accomplishments and Highlights 

Two new, high-performance sustainable buildings, the ESIF and the Café, achieved LEED 

(Leadership in Energy and Environmental Design) 

Platinum certification from the U.S. Green 

Building Council.

■ NREL was recognized with several prestigious 

awards that acknowledged the laboratory’s 

exemplary performance in sustainability 

(see section 3, Environmental Management 

System and Pollution Prevention)

■ Laboratory staff developed an internal 

dashboard to present sustainability 

goal performance

■ NREL initiated a site-specific climate change 

adaptation planning pilot project

■ Laboratory staff developed a Best Practices 

Guide and template materials for the Sustainability Performance Office’s (SPO) website for 

sustainability campaign development and 

communication for DOE sites and laboratories.

NREL’s Cafeteria offers a precedent model for creating a high 

performing, low-energy consuming, and “state-of-the-art” 

example of efficient food service. The facility received LEED 

Platinum certification. Photo by Dennis Schroeder, NREL 21698

Worker plugs his electric vehicle into one of 36 charging stations 

in the STM parking garage, designed to LEED Platinum standards 

to maximize energy savings and environmental stewardship.

Photo by Dennis Schroeder, NREL 26671
ENVIRONMENTAL PERFORMANCE REPORT 2013 27

TABLE 2. NREL’S PERFORMANCE STATUS TOWARD DOE SUSTAINABILITY GOALS

SPP 

Goal # DOE SSPP Goal NREL Performance Status in FY 2013 Status

1.1 28% GHG reduction from sources such as heating, 

cooling, and electricity use by FY 2020 from a FY 

2008 baseline (2013 target: 17%).

Emissions from energy use reduced 10% from the 2008 

baseline (without RECs) and 31% from the 2008 baseline 

(including RECs).

On Track

1.2 13% GHG reduction from sources such as air 

travel and commuting by FY 2020 from a FY 2008 

baseline (2013 target: 4%).

Emissions from sources such as transportation increased 

11% from the 2008 baseline. The reduction on a per 

employee basis will be met, however meeting the absolute 

reduction from the 2008 baseline will be challenging due 

to increased staffing.

Not On 

Track

2.1 30% building energy use per square foot reduction 

by FY 2015 from a FY 2003 baseline.

Decreased over 50% since 2003. On Track

2.2 Perform energy and water audits. Performed energy and water audits on buildings 

representing 7% of total site energy use in FY 2013. 

On Track

2.3 Individual buildings or processes metered for 90% 

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

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

Replaced 13 NWTC electric submeters to increase data 

quality and added 27 new meters in the ESIF.

On Track

2.4 Energy efficient cool roofs, unless uneconomical, 

for roof replacements.

Cool roofs make up 69% of NREL’s roof areas, a 43% increase 

from FY 2012.

On Track

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

(465 gross square meters) are compliant with the 

federal green building standards by FY 2015.

NREL currently has four buildings (17%) compliant with 

federal green building standards. NREL performed 

assessments on five additional buildings this year.

On Track

2.6 All new construction, major renovations, and 

alterations of buildings greater than 5,000 GSF 

GSF (465 gross square meters) must comply with 

federal green building standards and where the 

work exceeds $5 million, each are LEED – New 

Construction Gold certification or equivalent.

The new OTF expansion project will incorporate federal 

green building requirements and achieve at least LEED 

Gold certification.

On Track

3.1 10% annual increase in fleet alternative fuel 

consumption by FY 2015 relative to a FY 

2005 baseline.

Alternative fuel use has grown 145% since 2005. On Track

3.2 2% annual reduction in fleet petroleum 

consumption by FY 2020 relative to a FY 

2005 baseline.

Petroleum fuel usage has grown 73% since 2005. Not On 

Track

that take advantage of alternative financing mechanisms, 

including power purchase agreements, energy savings 

performance contracts, partnerships with energy service 

companies , and cooperative research and development 

agreements (CRADAs). NREL continues to review the use of 

overhead funds, cost savings reinvestment, and leveraged 

alternative financing to support new projects or retrofits 

on campus.

4.2 2013 SSPP GOAL PERFORMANCE

Table 2 summarizes each of DOE’s Strategic Sustainability 

Performance Plan (SSPP) goals and NREL’s performance 

status. For more specific information, please refer to the 

full SSP referenced.

Table 2 continued on page 28
28 ENVIRONMENTAL PERFORMANCE REPORT 2013

TABLE 2. NREL’S PERFORMANCE STATUS TOWARD DOE

SPP 

Goal # DOE SSPP Goal NREL Performance Status in FY 2013 Status

3.3 100% of light duty vehicle purchases must 

consist of alternative fuel vehicles by FY 2015 and 

thereafter (2000-2015).

No light-duty vehicles purchased in FY 2013. Not 

Applicable

3.4 Reduce fleet inventory of non-mission critical 

vehicles by 35% by 2013 relative to a FY 

2005 baseline.

Vehicle reduction is complete. To date NREL has reduced 

its fleet by eight vehicles; 100% of remaining fleet vehicles 

are mission critical.

On Track

4.1 26% potable water intensity (gallons per GSF) 

reduction by FY 2020 from a FY 2007 baseline. 

Water intensity is 16% less than the reduction goal. On Track

4.2 20% water consumption reduction of industrial, 

landscaping, and agricultural water by FY 2020 

from a FY 2010 baseline.

NREL does not use industrial, landscaping, and 

agricultural water. 

Not 

Applicable

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

excluding construction and demolition debris, by

FY 2015.

Diverted 77% of campus waste from the landfill in 

FY 2013.

On Track

5.2 Divert at least 50% of construction and demolition 

materials and debris by FY 2015.

Diverted 90% of construction waste from the landfill in

FY 2013.

On Track

6.1 Procurements meet sustainability requirements 

and include sustainable acquisition clause (95% 

each year).

All construction and custodial contracts met sustainable 

acquisitions requirements.

On Track

7.1 All data centers are metered to measure energy 

efficiency by FY 2015.

The RSF and ESIF data centers measure monthly 

energy efficiency.

On Track

7.2 Maximum annual weighted average energy 

efficiency rating (i.e., Power Usage Effectiveness) of 

1.4 by FY 2015.

The average energy efficiency rating for the RSF Data 

Center was 1.18.

On Track

7.3 Electronic Stewardship – 100% of eligible PCs, 

laptops, and monitors with power management 

actively implemented and in use by FY 2012.

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

8.1 20% of annual electricity consumption from 

renewable sources by FY 2020 (2013 target: 7.5%).

30% of NREL’s electricity was generated on-site in FY 2013. On Track
ENVIRONMENTAL PERFORMANCE REPORT 2013 29

NREL is subject to many federal, state, and local environmental laws and regulations, as well as EOs and DOE 

orders, and memoranda of understanding with government agencies. NREL continues its excellent record of 

environmental compliance. 

In 2013, 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. 

Actions were taken in two instances to correct circumstances that could lead to a violation. 

A Compliance Advisory was received from the state when 

a required quarterly sample for haloacetic acids (HAA5), a 

class of disinfection byproducts (DBPs), was not collected 

for the NWTC drinking water system. The laboratory 

posted a notification regarding the missed sample and 

the potential effects on users as required by the Compliance Advisory. DBP samples required for the remainder 

of the year were collected as required and the results 

showed DBP levels well below the maximum contaminant levels (MCLs).

Seventeen bird deaths occurred from collisions with 

windows from August to November at the recently 

constructed ESIF. The collisions involved 8 species, including 6 mourning doves, 6 songbirds, 2 pigeons, 1 magpie, 

and 2 unknown. An immediate interim solution was 

implemented by installing UV light-reflecting decals on 

select windows. A long-term solution is being developed 

and is planned for implementation prior to the 2014 

migration season.

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

year. More detailed information for each area of compliance is found in the referenced sections of this report. 

For information on required permits, registrations, and 

notifications, see Appendix C.

5 COMPLIANCE SUMMARY

Photo by Dennis Schroeder, NREL 18573
30 ENVIRONMENTAL PERFORMANCE REPORT 2013

TABLE 3. 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 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 EPA. Several main 

categories for air pollutants are 

regulated: criteria air pollutants, 

non-criteria pollutants, hazardous 

air pollutants (HAPs), and ODSs.

EPA regulation 40 CFR 82, 

Protection Of Stratospheric Ozone, 

requires that servicing records 

must be kept for appliances 

containing more than 50 pounds 

(23 kilograms/kg) 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.

The laboratory filed Air Pollution Emission Notices (APENs) 

and air permits for eleven new or previously exempt air 

emissions sources. APENs were filed with the state for six 

previously exempt standby generators for which APENs are 

now required due to Air Pollution Control Division 

(APCD) rule change. These standby generators remain 

permit exempt.

NREL reported air emissions to the state for five sources 

which are air permit exempt but exceed the emission 

reporting threshold; APENs are maintained with the state for 

these sources and are renewed every five years. 

An evaluation of HAP emissions indicated that emissions 

were well below reporting and permitting thresholds.

All required ODS equipment registrations were completed. 

NREL facilities servicing refrigeration equipment were 

registered and all refrigeration service personnel maintain 

the federal and state required training and certification.

The laboratory evaluated CO2e and GHG emissions and 

emissions were below the threshold for federal reporting 

and permitting rules.

The required annual street sanding report was provided to 

the state and Jefferson County.

An assessment of selected generators was performed to 

confirm compliance with state air permit requirements 

regarding run time. No deficiencies were identified.

NAAQS

40 CFR 50

ODS

40 CFR 82 and CDPHE 

CCR 1001-19, Reg. 15

New Source 

Performance 

Standards 

40 CFR 60

New Source 

Review, Prevention 

of Significant 

Deterioration

40 CFR 51

Title V

40 CFR 70 and 71

NESHAPs, HAP

40 CFR 63 and CDPHE 

5 CCR 1001-5, Reg. 3

Permitting

CDPHE 5 CCR 

1001-5, Reg. 3 

GHG

40 CFR 98 and 40 CFR 

51, 52, 70, 71 

Street Sanding 

CDPHE 5 CCR 

1001-18, Reg. 16

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. 

A Compliance Advisory was received from the state when 

a required quarterly sample for haloacetic acids (HAA5), a 

class of DBPs, was not collected. The laboratory posted a 

notification regarding the missed sample and the potential 

effects on users as required by the Compliance Advisory. 

DBP samples for the remainder of the year were collected as 

required and the results showed DBP levels well below 

the MCLs.

All other monitored parameters in 2013 met 

applicable requirements.

501,269 gallons (1,897,509 liters) of drinking water was 

provided to NWTC users.

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).

Submitted the Geothermal Well Construction and Test 

Report (Form GX-01) to the Colorado Division of Water 

Resources for the South SEB closed loop geothermal system. 

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 402-2
ENVIRONMENTAL PERFORMANCE REPORT 2013 31

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

APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Surface 

Water 

Quality

Construction-related stormwater 

discharge regulations are 

administered by the EPA at federal 

facilities in Colorado. 

Non-federal facility constructionrelated stormwater discharges in 

Colorado are regulated by the Water 

Quality Control Division of CDPHE.

All program activities were in compliance with requirements. 

Permit coverage was obtained under the EPA Construction 

General Permit (CGP) for one new construction project at the STM 

site. Five permits for completed projects were terminated in 2013. 

Monthly stormwater inspections were performed for construction 

sites where federal permit coverage continues during the 

restoration phase of these projects. Weekly inspections occurred 

for construction sites with an active federal stormwater permit. 

State stormwater permits were maintained by subcontractors at 

two experimental research projects at the SolarTAC site. 

Successful revegetation, defined in the federal stormwater permit 

as vegetative cover equivalent to 70% of pre-disturbance cover, 

was achieved at four major construction sites. Carefully selected 

seed mixes and mulches together with weed management 

and temporary irrigation were instrumental in achieving the 

EPA criteria.

EPA:

40 CFR 122.26

CDPHE:

5 CCR 

1002-61

Regs. 38, 61, 

65, and 93

Wastewater 

Management

The federal Clean Water Act (CWA) 

and Colorado Water Quality Control 

Act regulations apply to wastewater 

management at NREL’s STM and 

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. EPA:

40 CFR 

122-136

CDPHE:

5 CCR 

1002-62 & 63

Hazardous 

Materials 

Management

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 Department. Hazardous 

Materials Information System 

requirements, including permitting, 

inventory, and annual inspection. 

All program activities were in compliance with requirements. 

In 2013, NREL submitted a Tier II report to the state and the Local 

Emergency Planning Committee (LEPC) for reporting year 2012, 

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 2012.

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.

In order to meet OSHA’s new hazard communication 

requirements (29 CFR 1910.1200), NREL provided detailed training 

on the components of the newly adopted Global Harmonization 

System (GHS). Employers were required to train all employees 

who might be exposed to chemical hazards in the workplace 

on these requirements by December 1, 2013. NREL met that goal 

by providing classroom training for employees working in a lab. 

In addition to classroom training, more information on the GHS 

components were provided to workers on NREL’s intranet site.

EPA:

40 CFR 

355, 370, 372

Table 3 continued on page 32
32 ENVIRONMENTAL PERFORMANCE REPORT 2013

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

APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Regulated 

Waste Management

The Resource Conservation 

and Recovery Act established 

requirements for the management of 

regulated waste. In Colorado, CDPHE 

administers waste regulations under 

authority delegated by the EPA. 

All program activities were in compliance with 

requirements. 

All regulatory notifications were updated and applicable 

waste generator fees were paid for five NREL facilities. 

An assessment was conducted of the universal waste 

program, identifying no concerns, two findings, six 

opportunities for improvement and six noteworthy 

practices. Corrective actions have been implemented to 

close the findings and opportunities for improvement are 

being addressed.

EPA:

40 CFR 

260— 280

CDPHE:

6 CCR 1007-3

Above-ground 

Storage Tank 

(AST) Management

ASTs are regulated in Colorado by 

the Colorado Department of Labor 

and Employment (CDLE) Division 

of Oil and Public Safety under the 

Colorado AST regulation 7 CCR 

1101-14. Colorado requires that ASTs 

660 gallons (2,498 liters)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. 

A state inspection of registered ASTs was completed with 

no violations noted.

One installation permit was obtained for a planned 1,000 

gallon (3,785 liters) E-85 fleet vehicle fuel tank at the 

STM facility.

One 2,500 gallon (9,463 liters) AST at the SolarTAC 

facility received a state installation inspection and 

was registered.

CDLE:

Division of Oil 

and Public 

Safety (DOPS) 

Storage Tank 

Regulations,

7 CCR 1101-14

Spill Prevention 

and Response

Spill prevention, control, and 

countermeasures (SPCC) plans 

are required by EPA and Colorado 

regulations for facilities that meet 

certain oil storage criteria. In general, a 

facility must have an SPCC plan if the 

facility stores more than 1,320 gallons 

(4,997 liters) of oil or where a spill has 

the potential to enter waters of the 

United States.

All program activities were in compliance with 

requirements.

An SPCC plan was developed and implemented for the 

SolarTAC facility.

Workers who manage and/or operate oil-containing 

equipment received annual SPCC training. 

There were no reportable spills. Nine minor spills of diesel, 

lubricant, coolant, 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 (0.38 liters to 57 liters). 

The majority of these spills were the result of construction 

activities. Each spill received immediate remedial action 

and did not result in any significant impact to 

the environment.

EPA:

Oil Pollution 

Prevention 

40 CFR 112

CDLE:

DOPS

Storage Tank 

Regulations,

7 CCR 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 

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 0.036 mllirem (mrem) per year, far below the 

10 mrem per year limit.

EPA:

40 CFR 61, 

Subpart H

DOE:

DOE O 458.1
ENVIRONMENTAL PERFORMANCE REPORT 2013 33

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

APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

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 seventy six NEPA reviews were 

conducted for project activities on- and off-site 

during CY 2013. 

Updated the NEPA program to reflect the revised 

DOE NEPA implementing regulations and new 

classes of Categorical Exclusions. 

Progress continued on the site-wide Environmental 

Assessments (EAs) for the NWTC and STM sites, 

including completion of several activities such 

as internal scoping, public/agency scoping, and 

request for public comment.

Council for

Environmental 

Quality:

40 CFR

1500–1508

DOE:

10 CFR 1021

Wildlife 

Management

The Migratory Bird Treaty Act (MBTA) of 1918 is 

the main driver for protection of migratory birds 

in the United States. The MBTA and amendments 

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 U.S. Fish and Wildlife 

Service (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.

Seventeen bird deaths occurred from collisions 

with windows from August to November at the 

recently constructed ESIF. The collisions involved 8 

species, including 6 mourning doves, 6 songbirds, 2 

pigeons, 1 magpie, and 2 unknown. An immediate 

interim solution was implemented by installing UV 

light reflecting decals on select windows. A longterm solution is being developed and is planned for 

implementation prior to the 2014 migration season.

One bird death, an American Crow, was reported 

at the NWTC during the year. Workers at the site are 

requested to report incidental observations of bird 

mortalities to environmental program staff who 

track this information. 

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.

U.S. Fish 

and Wildlife 

Service:

50 CFR 17

Table 3 continued on page 34
34 ENVIRONMENTAL PERFORMANCE REPORT 2013

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

APPLICABLE TO NREL

Report 

Sections Regulatory Program Description Compliance Status and Highlights Regulator &Requirement

Vegetation 

Management

EO 13112, Invasive Species requires the control of 

invasive species at federal facilities. In Colorado, 

the Department of Agriculture Commissioner 

develops and implements state noxious weed 

management plans for three categories of 

weed species. Class A plants are targeted for 

eradication. Class B species are subject to 

management plans designed to stop their 

continued spread. Class C species are subject to 

plans designed to support the efforts of local 

governing bodies to facilitate more effective 

integrated weed management on private and 

public lands.

The Federal Insecticide, Fungicide, and 

Rodenticide Act regulates the use, storage, 

and disposal of herbicides and pesticides. 

For application of certain types of herbicides 

designated as “restricted use” by the EPA, a 

certified applicator must be used. 

All program activities were in compliance 

with requirements.

Aggressive weed management continued. Knapweed 

is nearly under control at the NWTC and Canada thistle, 

hounds tongue, and myrtle spurge are under control 

at the STM site. In support of the goal to eliminate the 

A-listed noxious weed myrtle spurge from the STM site, 

the species was treated for the third consecutive year 

and the affected areas have been much reduced. At 

the NWTC, herbicides were applied to approximately 

88 acres (35.6 hectares) in April, 42 acres (17 hectares) 

in June, and 88 acres (35.6 hectares) in September. At 

the STM site, approximately 16 acres (6.5 hectares) were 

treated in May-June, 2 acres (0.8 hectares) in July, and 9 

acres 3.6 hectares) in September. The application of 

restricted-use herbicides was conducted using 

certified applicators. 

EO 13112

EPA:

40 CFR 

162—171(f)

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 U.S. Army Corp of 

Engineers (USACE).

Jefferson County requires approval of 

development proposed in floodplains within 

its jurisdiction.

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. 

EO 11990

USACE:

CWA Section 

404

DOE: 

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 

requires that Federal agencies consult with the 

State Historic Preservation Office (Colorado 

Office of Archaeology & Historic Preservation) 

and other consulting parties for undertakings 

that may impact historic properties.

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.

In June 2013, DOE and NREL completed an 

informational display as mitigation for impacts to the 

former Camp George West 500- and 600-yard small 

arms firing lines during the construction of the south 

access road to the STM campus in accordance with a 

2011 MOA with the Colorado Office of Archaeology & 

Historic Preservation. The firing lines are considered 

contributing features of the Camp George West 

Historic District. The informational display is located 

off of Research Road in Pleasant View Community Park 

and is accessible to the public. 

Advisory 

Council 

on Historic 

Preservation:

36 CFR 60

36 CFR 63

36 CFR 79

36 CFR 800

16 U.S.C. 470
ENVIRONMENTAL PERFORMANCE REPORT 2013 35

TABLE 3. 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

DOE O 436.1, Departmental Sustainability 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.

EO 13423

EO 13514

DOE:

DOE O 436.1

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 intersection of Denver West Parkway and Denver West 

Marriott Boulevard operates at a Level of Service (LOS) of D 

or better 

• The intersection of Quaker St. and South Golden Road 

operates at a Level of Service 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 alternative 

work schedules (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.

Transportation Demand Management 

measures required by the MAP were 

continued in 2013. 

Average PM peak hour traffic volume 

at the intersection of Denver West 

Parkway and Denver West Marriott 

Boulevard was 307 vehicle trips. The 

monitoring periods were April 2013, 

August 2013, and November 2013. The 

MAP threshold of Level of Service 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.

DOE/EA1440-S-I 

(May 2008) 

Traffic MAP
36 ENVIRONMENTAL PERFORMANCE REPORT 2013

6 AIR QUALITY PROTECTION

NREL strives to minimize air emissions, tracks air emissions 

from the larger on-site sources, confirms that on-site sources 

have air permits as required, and meets federal and state air 

emissions and permitting requirements.

Minimizing air emissions creates direct health benefits for 

immediate neighbors to the laboratory and for those in the 

Denver metropolitan area. Reducing emissions also 

reduces the complexity of the facility’s air permits and 

reduces associated emission controls, tests, and 

reporting requirements.

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 

Solar Energy Research Facility. Photo by Dennis Schroeder, 

NREL 21754

2013 Accomplishments and Highlights

■ Updated the air emissions inventory, 

including new sources and the use of 

equipment-specific emission factors where 

available. This has resulted in a more 

accurate emission inventory and estimated 

nitrogen oxide (NOx) emissions decreased 

due to this effort.

■ Provided hazardous air pollutant (HAP) 

emissions estimates and compliance 

guidance to NREL research staff related to 

several small-scale research projects.

■ Completed an evaluation of compliance 

with federal and state facility-wide permitting and emissions control requirements. 

All facilities and individual permitted 

equipment items remain classified as 

minor sources. 
ENVIRONMENTAL PERFORMANCE REPORT 2013 37

emissions and maintain a current and accurate air 

emission inventory.

Program Management

The 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 (91 metric tons) per 

year for a criteria pollutant such as: 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 (9.1 metric tons) per year, or the total 

emissions of all HAP pollutants at one facility exceeds 25 

tons (22.7 metric 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 (22.7 kg to 2,268 kg) per year.

Air emission reporting in Colorado is required for an item 

of equipment that emits 1 ton (0.9 metric tons) per year or 

more of any criteria air pollutant. A state air permit may be 

required if a piece of equipment emits as little as 1 ton (0.9 

metric tons) per year of any criteria pollutant. The trigger 

level varies from 1 to 10 tons (0.9 to 9.1 metric tons) per year 

depending on requirements for the 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.

■ 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 EPAspecified NAAQS.

■ HAPs which include a specific list of organic compounds, 

metals, corrosives, asbestos, radionuclides, and pesticides 

established by the EPA.

■ ODSs such as chlorofluorocarbons or “Freon” and hydrochlorofluorocarbons that are being phased out of use in 

comfort heating and cooling systems and equipment.

■ GHG compounds such as carbon dioxide, methane, 

nitrous oxide, and many man-made refrigerant gases 

that contribute to global warming.

There are various federal and state 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, bench- and pilot-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. The laboratory maintains several 

air permits issued by the state for “minor” sources, including 

standby electrical generators and pollution control systems 

at the STM, NWTC, and SolarTAC sites. All of these individual 

emission sources and each NREL facility are considered by 

the EPA and state 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 (10.1 hectares), or 

occurring for longer than six months, are subject to state 

fugitive particulate emissions permits. A fugitive emission 

permit is in effect for construction activity at the STM site.

Permitting 

Most sources of air emissions from NREL laboratory and 

facility operations are small scale and do not require permitting. While permitting thresholds may vary, depending on 

the pollutant, the state 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 are 

evaluated and air emission reporting and permitting are 

performed as required. 

HAP 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 

(23 kg) per year to more than 2,000 pounds (907 kg) per year.

Ozone-Depleting Substances

EPA regulation 40 CFR 82, Protection of Stratospheric Ozone, 

requires that appliances and stationary appliances containing more than 50 pounds (23 kg) of Class I or II ODS refrigerant must meet specific EPA record keeping, ODS recovery, 

and leak monitoring and repair requirements.
38 ENVIRONMENTAL PERFORMANCE REPORT 2013

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

Emission of Ozone Depleting Compounds):

1. Facilities where maintenance activities are performed on 

refrigeration equipment containing ODS are required to 

file an annual notification with CDPHE.

2. 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.

3. Refrigeration equipment larger than 100 horsepower 

(hp) containing ODS must be registered annually with 

the state. 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 the state—two located at the 

SERF on the STM site, and one at the DWOP. NREL performs 

the necessary annual notification that maintenance activities occurred, renews the registration for the three chillers, 

and confirms 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 (23 kg) 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 particulate pollution in the Denver area. As these 

particulates contribute to breathing and health problems for 

susceptible individuals, the EPA and state have issued regulations to minimize this source of air pollution.

NREL complies with the sanding requirements and files an 

annual sanding report with the state. The laboratory uses 

only deicer to maintain roadways. 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.

Greenhouse Gas 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 carbon dioxide equivalent 

(CO2e) emissions are greater than 100,000 U.S. tons (90,718 

metric tons) per year. The Mandatory Reporting Rule requires 

annual GHG reporting to EPA if CO2e emissions are greater 

than 25,000 metric tons (27,557 U.S. tons) per year. Reporting and permitting of GHGs are not currently required for 

NREL facilities as emissions are below EPA reporting and 

permitting thresholds.

GHGs include CO2, methane, nitric oxide, and refrigerants 

including ODS chlorofluorinated hydrocarbons such as 

hydrofluorocarbons, perfluorocarbons, and other fluorinated 

gases. For more information on how NREL is reducing its 

emission of GHGs, please see section 4, Sustainability. 

2013 Compliance Summary and Activities

■ Program activities were in compliance with requirements. 

The laboratory did not exceed any air permit standard or 

other air regulatory requirement at any facility.

■ The laboratory filed APENs and air permits for eleven new 

or previously exempt air emissions sources. APENs were 

filed with the state for six previously exempt standby 

generators for which APENs are now required due to 

APCD rule change. These standby generators remain 

permit-exempt.

■ NREL reported air emissions to the state for five sources 

which are air permit exempt but exceed the emission 

reporting threshold; APENs are maintained with the state 

for these sources and are renewed every five years. 

■ An evaluation of HAP emissions at NREL indicated 

that emissions were well below reporting and 

permitting thresholds. 

■ All required ODS equipment registrations were completed. NREL facilities servicing refrigeration equipment were 

registered and all refrigeration service personnel maintain 

the federal and state required training and certification.

■ The laboratory evaluated and concluded that CO2e

 and 

GHG emissions were below the threshold for federal 

reporting and permitting rules. 

■ NREL provided the required annual street sanding report 

to the state and Jefferson County.

■ DOE performed an assessment for selected NREL generators 

to confirm compliance with state air permit requirements 

regarding run time. No deficiencies were identified.
ENVIRONMENTAL PERFORMANCE REPORT 2013 39

7 WATER QUALITY PROTECTION

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 NWTC does not have 

access to a public drinking water supply. For this reason, 

NREL operates a drinking water distribution system at 

the NWTC, serving about 150 employees. Drinking water 

is purchased from local municipalities and transported 

by truck to the site, where it is transferred to a large 

holding tank with a capacity of 15,000 gallons (56,781 

liters). Water is pumped from the holding tank to a day 

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

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

boost disinfectant levels. The system is permitted by 

the State of Colorado, which requires monitoring for a 

number of parameters on a monthly and 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. 

NREL’s management of the drinking water system is 

subject to assessments by DOE and compliance

inspections by 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 EPA has 

established allowable levels for drinking water 

Extraordinarily heavy rains filled the stormwater 

detention basin at the STM site in September 2013. 

Photo by Dennis Schroeder, NREL 27735
40 ENVIRONMENTAL PERFORMANCE REPORT 2013

constituents known as 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. Figures 2 and 3 show 

the results of the chlorine and DBPs monitoring for 2013.

2013 Compliance Summary and Activities

■ A Compliance Advisory was received from the state 

when a required quarterly sample for haloacetic acids 

(HAA5), a class of DBPs, was not collected. The laboratory posted a notification regarding the missed sample 

and the potential effects on users as required by the 

Compliance Advisory. DBP samples for the remainder 

of the year were collected as required and the results 

showed DBP levels well below the MCLs.

■ All other monitored parameters in 2013 met 

applicable requirements.

■ 501,269 gallons (1,897,509 liters) of drinking water was 

provided to NWTC users. 

Average Monthly Chlorine Residual 2013

5.00

4.00

3.00

2.00

1.00

0.00

1 3 5 7 9 11 

Chlorine

Residual,

mg/L

Month

Maximum

Allowed

Average Monthly

Chlorine Residual

Figure 2. Results of 2013 chlorine monitoring.

Figure 3. Results of 2013 DBP monitoring.

Disinfectant Byproducts

80

70

60

50

40

30

20

10

0

2009 2010 2011 2012 2013

Amount

Present,

ppb

TTHM MCL

TTHM

HAA5

HAA5 
ENVIRONMENTAL PERFORMANCE REPORT 2013 41

7.2 GROUNDWATER

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

increasing numbers of residents for water supplies. NREL’s 

groundwater protection program is based on the 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 on by the groundwater users in the basin. 

The northern extent of the Dawson aquifer is located 

approximately 20 miles (33 km) to the south and east of 

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

site or the NWTC would not intersect the Dawson aquifer, 

nor would a source of contamination affect the groundwater quality in this aquifer. 

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 on establishing safeguards 

such as 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 ongoing 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 are two closed-loop geothermal systems in operation at the STM Solar Radiation Research Laboratory 

and at the STM South Site Entrance Building. 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 would be 

implemented and additional groundwater monitoring 

wells would be installed as needed.

2013 Compliance Activities

■ Submitted the Geothermal Well Construction and 

Test Report (Form GX-01) to the Colorado Division 

of Water Resources for the South SEB closed loop 

geothermal system.

7.3 SURFACE WATER

NREL’s Surface Water Protection program seeks to protect 

the quality of nearby receiving waters to which the 

STM and NWTC campuses drain. 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 that 

flows across active construction sites, inclusion of project 

design elements that promote infiltration and detention, 

and management of campus grounds to minimize erosion 

and support infiltration.

Due to the continuing construction activity at both 

campuses, the focus of NREL’s water quality protection 

program 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 NEPA 

reviews and approvals, and the assessment of design 

documents for potential impacts to stormwater and 

2013 Accomplishments and Highlights 

There were no spills or releases that impacted 

groundwater at any NREL site in 2013.
42 ENVIRONMENTAL PERFORMANCE REPORT 2013

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 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 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, Colorado Discharge 

Permit System stormwater permits may be required. For 

construction sites on sites 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. 

While construction sites less than 1 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 basic elements of the stormwater pollution 

prevention program are followed, including the development of 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 Best Management Practices 

(BMPs) may also be required. 

2013 Accomplishments and Highlights 

■ NREL’s STM campus stormwater-detention basin, 

which was completed in 2012, successfully 

detained and then slowly released the historic 

rainfall and runoff received in September 2013 

without causing erosion or sedimentation to 

the adjacent and downstream neighborhood or 

park facility. The slow release rate also allowed 

for settling of sediment within the basin, thus 

removing urban pollutants typically bound to 

sediment, prior to its discharge to Lena Gulch.

■ The laboratory developed final design documents 

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 2014. 

■ NREL improved stormwater protection by 

enhancing stormwater program elements and 

construction specifications to better communicate 

requirements and responsibilities. 

■ The laboratory specified and installed porous 

pavers to replace 800 feet (244 meters)of asphalt 

roadway at the STM campus, increasing infiltration 

and decreasing runoff delivered to the STM 

stormwater detention basin. This low-impact 

design element will reduce maintenance and costs 

due to reduced stormwater infrastructure and 

maintenance needs.
ENVIRONMENTAL PERFORMANCE REPORT 2013 43

The 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, EO 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. 

2013 Compliance Summary and Activities

■ Program activities were in compliance 

with requirements.

■ Permit coverage was obtained under the EPA CGP 

for one new construction project at the STM site. 

Five permits for completed projects were terminated 

in 2013. 

■ Monthly stormwater inspections were performed for 

construction sites where EPA CGP permit coverage 

continues during the restoration phase of these projects. Weekly inspections occurred for construction 

sites with an active federal stormwater permit. State 

stormwater permits were maintained by subcontractors at two experimental research projects at the 

SolarTAC site. 

■ Successful revegetation, defined in the federal stormwater permit as vegetative cover equivalent to 70% 

of pre-disturbance cover, was achieved at four major 

construction sites. Carefully selected seed mixes 

and mulches together with weed management and 

temporary irrigation were instrumental in achieving 

the EPA criteria.

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 site 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 the STM site, serving the 

Solar Radiation Research Laboratory, 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. 

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 federal regulations have targeted, 

nor does the laboratory discharge a volume of water that 

would trigger requirement of 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. 

Successful revegetation following construction disturbance. 

Photo by Dennis Schroeder, NREL 27798 Resurfacing of Denver West Parkway with concrete pavers 

during the historic rainfall event of September 2013. Photo by

Dennis Schroeder, NREL 27635
44 ENVIRONMENTAL PERFORMANCE REPORT 2013

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. 

At the IBRF, a neutralization pit containing limestone is 

installed in the facility’s discharge line that helps neutralize wastewater that may be somewhat acidic. This passive 

system is installed just upstream of the final discharge of 

the IBRF.

2013 Compliance Summary and Activities

Program activities were in compliance with requirements.
ENVIRONMENTAL PERFORMANCE REPORT 2013 45

8

HAZARDOUS MATERIALS 

 AND WASTE 

MANAGEMENT

At NREL, responsible acquisition, use, and disposal of 

materials and wastes are critical to meeting our commitments to compliance, preventing pollution, and environmental stewardship. NREL seeks to purchase materials that 

are sourced responsibly and contain recycled content and 

lower impact materials. Use of 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 

NREL biochemists discuss results of vials containing an 

enzymatic digestion assay of cellulose. Photo by 

Dennis Schroeder, NREL 28876
46 ENVIRONMENTAL PERFORMANCE REPORT 2013

system, the CMS tracks chemicals from the point of receipt 

through end-use and disposal. The system also contains 

technical data and reporting information for many of 

the chemicals in the CMS database. Key functions of the 

system include: 

■ Providing current inventories by room, building, 

and/or site 

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

needed chemicals are already available on-site prior to 

making chemical purchases

■ 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 management system that tracks chemical 

amounts, locations, and hazards. Each week, safety 

personnel receive a list of the chemicals and their hazards 

that were shipped to NREL during the previous week. 

Researchers and safety personnel ensure that chemicals 

are properly stored in locations suitable for any hazards, 

such as storing flammable materials in designated 

flammables cabinets. 

Program Management

NREL facilities are subject to the emergency reporting 

provision of the 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 Safety 

Data Sheets or SDS (per OSHA’s new hazard communication requirements, the term SDS replaces MSDS or Material 

Safety Data Sheets) for chemicals that are stored on-site 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, 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 Section 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 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 walkthrough 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 

2013 Accomplishments and Highlights 

■ The laboratory initiated a radio frequency identification (RFID) chemical-inventory pilot project 

with an initial focus on time-sensitive chemicals such as peroxide formers. This technology 

streamlines data collection by remotely detecting inventory data without physically scanning 

each item and reduces inventory errors. 

■ There were no releases of hazardous materials 

requiring reporting.
ENVIRONMENTAL PERFORMANCE REPORT 2013 47

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.

2013 Compliance Summary and Activities

■ All laboratory program activities were in compliance 

with requirements. 

■ In 2013, NREL submitted a Tier II report to state and the 

LEPC for reporting year 2012, identifying diesel fuel, 

petroleum oil, and sulfuric acid in lead-acid batteries; see 

Table 4 for details.

■ 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.

■ In order to meet OSHA’s new hazard communication requirements (29 CFR 1910.1200), NREL provided 

detailed training on the components of the newly 

adopted Global Harmonization System (GHS). Employers were required to train all employees who might be 

exposed to chemical hazards in the workplace on these 

requirements by December 1, 2013. NREL met that goal 

by providing classroom training for employees working 

in a lab. In addition to classroom training, more information on the GHS components were provided to workers 

on NREL’s intranet site. 

8.2 REGULATED WASTE 

MANAGEMENT

Research and development activities and general facility operations create a variety of waste streams, including 

those containing toxic chemicals or metals. The laboratory 

is committed to the appropriate management of regulated 

waste generated through its daily operations. 

These wastes are handled, stored, and disposed of responsibly to minimize the potential for health and environmental 

impacts that could result from a release or improper disposal.

Waste management and minimization efforts begin in the 

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

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

activity begins and 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. On-site waste management activities are 

conducted in a manner that will minimize potential effects 

on human health and the environment. 

NREL researchers reduce waste in the laboratory by substiting 

less hazardous chemicals whenever possible and ordering only 

what they need. Photo by Dennis Schroeder, NREL 19438

TABLE 4. 2013 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

Reported 

EPCRA Section 313 TRI Reporting Not 

required

 “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).

2013 Accomplishments and Highlights 

■ Overall hazardous and non-hazardous waste 

volumes decreased significantly at NREL from 

the prior year (see Table 5), largely due to a 

reduction in pilot scale testing in the Thermochemical Process Development and at ReFUEL. 

Universal waste generation increased due to a 

site-wide energy efficient lighting retrofit.

■ 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 

those for personnel training, contingency 

planning, and container management. 
48 ENVIRONMENTAL PERFORMANCE REPORT 2013

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. Additional applicable regulatory requirements fall under the U.S. 

Department of Transportation Hazardous Material regulations in Title 49 of the Code of Federal Regulations. 

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, diesel fuel, or select pretreatment 

liquors from biomass processing; does not include 

municipal solid waste, such as regular trash

■ Universal waste such as mercury-containing light bulbs, 

lead-acid batteries, aerosol cans, and electronic waste 

such as computers, monitors, and research instrumentation containing electronic circuitry.

A comparison of waste generated is summarized in Table 5.

NREL maintains unique EPA identification numbers for each 

of its five facilities: STM, DWOP, NWTC, JSF, and ReFUEL. 

Pursuant with state and federal regulations, annual generator notifications are made and applicable fees are paid to 

the state based on monthly volumes of hazardous waste 

that are generated at each facility. The three waste generator classifications are:

■ LQG: generates ≥ 1,000 kg (220 lbs) of hazardous waste 

in a calendar month (or > 1 kg/2.2 lbs of acutely toxic 

hazardous waste)

■ Small Quantity Generator (SQG): generates > 100 kg 

(22 lbs) but < 1,000 kg (220 lbs) of hazardous waste in a 

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

■ Conditionally Exempt Small Quantity Generator 

(CESQG): generates < 100 kg (22 lbs) of hazardous waste 

in a calendar month (and < 1 kg/2.2 lbs) of acutely 

hazardous waste).

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, yet pose a potential 

hazard, are collected and disposed of as non-hazardous 

materials at federally permitted disposal facilities. For 

example, non-hazardous, nanomaterial-bearing wastes are 

not federally 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, hazardous waste items are 

shipped off-site for final disposal via incineration, treatment, 

and landfill. Universal wastes are recycled or reclaimed.

2013 Compliance Summary and Activities

■ Program activities were in compliance with 

requirements. 

■ All regulatory notifications were updated and applicable 

waste generator fees were paid for five NREL facilities. 

■ An assessment was conducted of the universal waste 

program, identifying no concerns, two findings, six 

opportunities for improvement, and six noteworthy 

practices. Corrective actions have been implemented to 

close the findings and opportunities for improvement 

are being addressed.

TABLE 5. COMPARISON OF FOUR WASTE 

CATEGORIES GENERATED AT NREL FACILITIES 

[LBS. (KGS) NET WEIGHT]

Hazardous 

Waste

Non-Hazardous 

Waste

Universal 

Electronic

Waste

Other 

Universal 

Waste

2011 20,557

(9,324) 

6,156

(2,792)

29,549 

(13,403) 3,539 (1,605)

2012 33,386 

(15,144)

8,805

(3,994)

41,355 

(18,758) 4,803 (2,179)

2013 14,974

(6,792)

4,477

(2,031)

38,096 

(17,280)

19,063 

(8,647)
ENVIRONMENTAL PERFORMANCE REPORT 2013 49

8.3 ABOVEGROUND STORAGE 

 TANK MANAGEMENT

Proper tank management prevents or minimizes the size of 

spills and leaks of fuels or oils, avoiding contamination of 

soils, surface water, groundwater, and drinking water. 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

■ Ensure compliance with tank design, operation, training, 

and inspection requirements.

NREL minimizes the risk of underground soil and water 

contamination from storage tanks by using 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 Division of 

Oil and Public Safety under the Colorado AST regulation 

7 CCR 1101-14. Colorado requires that ASTs 660 gallons 

(2,498 liters) or larger be permitted prior to installation, be 

inspected by the state following installation, and be registered within 30 days following commencement of use. 

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 quantities employ a Spill 

Prevention, Control, And Countermeasures (SPCC) plan 

to manage oil sources 55 gallons (208 liters) or larger (see 

section 8.4, Spill Prevention and Response, for

more information).

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 equipped with sensors 

that result in an alarm if the inner tank wall is leaking, and 

secondary containment for single-wall tanks. Procedural 

safeguards include written operating and tank-filling procedures, monthly and annual inspections, and record keeping 

of inspection results. ASTs larger than 110 gallons (416 liters) 

are visually inspected monthly and all double-walled 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, tank inspections 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 and documentation of annual training activities.

Personnel who operate and manage ASTs are trained 

annually on AST program requirements including inspection and response requirements, spill history of each site 

and lessons learned, and recent changes in rules 

and regulations.

NREL maintains 15 ASTs at the STM site with a total capacity of 12,839 gallons (48,600 liters); one AST at DWOP with 

a capacity of 500 gallons (1,893 liters); five ASTs at the 

NWTC with a total capacity of 1,061 gallons (4,016 liters); 

and one 2,500-gallon (9,464-liter) AST at the SolarTAC 

Consolidated Utility Base Energy System is an integrated power 

electronic platform for a 60-kW PV-Battery-Diesel hybrid power 

system developed for the U.S. Army to provide power to 

Forward Operating Bases. Photo by Dennis Schroeder, NREL 28837

2013 Accomplishments and Highlights 

■ Annual AST training was provided to all laboratory personnel identified as having responsibility for operating and fueling ASTs.

■ All tanks were reviewed to confirm continued 

adherence to recently revised regulations. 
50 ENVIRONMENTAL PERFORMANCE REPORT 2013

facility. Four ASTs at the STM and the SolarTAC AST are 

registered with the state. There are no ASTs at the NWTC 

that need to be permitted or registered. 

2013 Compliance Summary and Activities

■ All program activities were in compliance 

with requirements.

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

activities occurred. 

■ A state inspection of registered ASTs was completed with 

no violations noted.

■ One installation permit was obtained for a planned 

1,000-gallon (3,785-liter) E-85 fleet vehicle fuel tank at 

the STM facility.

■ One 2,500-gallon (9, 464-liter) AST at the SolarTAC 

facility received a state installation inspection and 

was registered.

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.

The laboratory prepares for and continually improves spill 

response. Formal SPCC plans have been developed for four 

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 CCR 1101-14. In general, facilities 

that store more than 1,320 gallons (5,000 liters) of oil and 

have the potential for a spill to enter a 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 (208 liters) or more of oil be included in the plan. 

The plan must address such items as:

■ Topography and location of waterways

■ Location and quantity of oil sources

■ Possible spill pathways

■ Spill scenarios and potential spill volumes

■ Spill prevention and response training

■ Spill notification procedures and contact information

■ Emergency response plans.

Due to the quantity of oils stored at the STM, NWTC, ReFUEL, 

and SolarTAC sites, an SPCC plan is required for each of these 

locations. NREL’s SPCC plans are updated every 3 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 5 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 

equipment is maintained at multiple locations, allowing 

response and clean-up activities to occur quickly. 

■ SPCC training occurs annually for individuals who are 

responsible for oil-containing equipment and AST operation and maintenance. SPCC training is combined with 

AST training and educates staff on oil-containing equipment at each site, inspection and response requirements, 

the oil spill history of each site and lessons learned, and 

recent changes to rules and regulations.

■ The laboratory typically does not experience spills that 

require notification to federal and state agencies. Small, 

incidental hydraulic system leaks, lubricant leaks, and fuel 

transfer spills may occur on occasion. Lessons learned 

from spill incidents and clean-up activities are used to 

improve management and spill response planning.

2013 Compliance Summary and Activities

■ Program activities were in compliance with 

requirements.

■ An SPCC plan was developed and implemented for the 

SolarTAC facility.

2013 Accomplishments and Highlights 

The laboratory SPCC training course was updated 

to include new NREL facilities and revised 

SPCC plans. 
ENVIRONMENTAL PERFORMANCE REPORT 2013 51

■ Workers who manage and/or operate oil-containing 

equipment received annual SPCC training. 

■ There were no reportable spills. Nine minor spills of 

diesel, lubricant, coolant, 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 (0.39 to 

57 liters). The majority of these spills were the result of 

construction activities. Each spill received immediate 

remedial action and did not result in any significant 

impact to the environment. 

8.5 RADIOLOGICAL MATERIALS AND 

WASTE MANAGEMENT

NREL conducts a wide range of research and operational 

activities that incorporate the use of radiological materials. 

The laboratory occasionally uses small quantities of radioisotopes for biological labeling and electron microscopy staining. All of the radioisotopes have very low activity levels and 

are used in extremely small amounts. A number of sealed 

sources are present in analytical and process equipment, 

check sources, and emergency exit signs. Unlike many DOE 

facilities, NREL does not 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 radiation generating devices, 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 small number of 

specific laboratories

■ Monitoring equipment and facilities for removable 

contamination or sealed source leakage

■ Assuring that future users are not at risk for receiving 

contaminated materials—no equipment used on-site is 

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 O 458.1, Radiation Protection of the Public and the 

Environment establishes radiation emission limits for DOE 

facilities. These facilities, including NREL, must annually 

demonstrate compliance with Rad NESHAPs, 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 Rad NESHAPs standards by using an EPA computer 

model (COMPLY Version 1.6) to determine the effective dose 

equivalent to the public. 

All radioactive waste generated 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. 

2013 Compliance Summary and Activities

■ Program activities were in compliance with 

requirements.

■ Small quantities of low-level radioactive waste were 

generated and are currently in storage awaiting 

off-site disposal.

■ The effective dose equivalent to the public was 0.036 

mrem per year, far below the 10 mrem per year limit.

What Is “Effective Dose Equivalent?”

To understand effective dose equivalent, you 

must first define dose and dose equivalent:

■ Dose – a generic term to describe the 

amount of radiation a person receives.

■ Dose Equivalent – a measure of the 

biological risk of the energy that the radiation 

deposited in tissue, which depends on the 

type of radiation and the tissues exposed. The 

units of dose equivalent are called rems, and 

a thousandth of a rem is called a millirem, 

abbreviated as mrem.

■ Effective Dose Equivalent – the total of 

the dose equivalent to the organ or tissue 

multiplied by weighting factors applicable to 

each of the body organs or tissues that are 

exposed to radiation.

An average person in the United States receives 

about 310 mrem each year from natural 

sources and an additional 310 mrem from 

medical procedures and consumer products.
52 ENVIRONMENTAL PERFORMANCE REPORT 2013

9

NATIONAL

ENVIRONMENTAL 

POLICY ACT

NREL’s 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, staff 

conduct reviews of a wide range of activities prior to 

spending funds or commencing work. 

Examples of activities requiring a NEPA review include 

new or revised laboratory research, construction activities, 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, DOE established 

Maintenance work on a turbine at the NWTC. Photo by 

Dennis Schroeder, NREL 26641

2013 Accomplishments and Highlights 

■ Provided training for workers participating in 

the laboratory’s NEPA process. The training 

included information regarding the purpose 

of NEPA and implementing procedures.

■ Continued to provide NEPA support in 

the preparation of proposals for DOE 

Funding Opportunity Announcements that 

support DOE’s mission and the nation’s 

energy objectives. 
ENVIRONMENTAL PERFORMANCE REPORT 2013 53

NEPA Implementing Procedures (10 CFR 1021) which DOE 

(and NREL) use to comply with Section 102(2) of the NEPA 

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

procedures supplement, and are to be used in conjunction with, CEQ regulations.

Under NEPA, federal agencies consider and document 

environmental factors in decision-making processes using 

one of the following methods:

■ Categorical Exclusion (CX) 

■ Environmental Assessment (EA)

■ Environmental Impact Statement (EIS).

Categorical Exclusion

Proposed activities may fall under a DOE 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.

Environmental Assessment

If the proposed action does not fit into a CX established 

by DOE, or there are extraordinary circumstances 

present (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. For DOE facilities, a 

site-wide EA can be developed which considers the 

potential environmental impact of site operations and 

future proposed development. An EA provides sufficient 

evidence and analysis for determining whether to prepare 

an EIS or not. 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. 

Environmental Impact Statement

An EIS provides a detailed analysis of projects that have 

significant prospective environmental impacts. The 

EIS provides a discussion of significant environmental 

impacts and reasonable alternatives (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.

NREL Implementation of the NEPA Process

The laboratory initiates NEPA reviews and supports the 

DOE Golden Field Office (DOE GO ) in making NEPA determinations before work begins. In accordance with DOE 

NEPA Implementing Procedures (10 CFR 1021), all NREL 

activities must undergo a NEPA environmental review. The 

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

Scrub Jay at the South Table Mountain (STM) campus. Photo by 

Bob Fiehweg, NREL 19582

Aerial photo of the NWTC. Photo by Dennis Schroeder, NREL 25929
54 ENVIRONMENTAL PERFORMANCE REPORT 2013

before a contract award can be made, and before project 

activities begin. 

If proposed activities have not already been evaluated 

in an existing NREL site-wide EA or supplemental NEPA 

document, then further environmental review must be 

conducted. Potential environmental impacts of an activity 

are evaluated and measures are taken as needed to avoid 

or minimize those impacts. The level of review conducted 

is appropriate to the potential impacts of the proposed 

activity. A planned construction project, for example, 

receives a more rigorous review than routine office work.

2013 Compliance Summary and Activities

■ Program activities were in compliance with 

requirements.

■ Four hundred seventy six NEPA reviews were conducted for project activities on- and off-site during CY 2013. 

■ Updated the NEPA program to reflect the revised DOE 

NEPA implementing regulations and new classes of 

Categorical Exclusions.

■ Progress continued on the site-wide EAs for the NWTC 

and STM sites, including several activities such as internal scoping, public/agency scoping, and request for 

public comment. 
ENVIRONMENTAL PERFORMANCE REPORT 2013 55

NREL is committed to responsible stewardship of its 

natural ecosystems, native wildlife and vegetation, and 

important cultural resources. Natural resources at the 

STM and NWTC facilities are managed appropriately to 

ensure its 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 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 on-site. NREL is committed to 

responsible land stewardship that supports wildlife. Many 

surrounding landowners, including residential neighbors 

and Jefferson County Open Space, value the benefits 

of maintaining wildlife habitat and opportunities to 

observe wildlife. Proper wildlife management provides an 

important benefit to our community. 

NREL biologists work with project managers and 

decision-makers 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. 

10

NATURAL

AND CULTURAL 

RESOURCES

PROTECTION

Aerial photo of the NWTC. Photo by Dennis Schroeder, 

NREL 25908 
56 ENVIRONMENTAL PERFORMANCE REPORT 2013

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 

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 that 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) 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 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 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 

The glass at the parking garage is bird-friendly with vertical frits 

to prevent collisions. Photo by Dennis Schroeder, NREL 24898

2013 Accomplishments and Highlights 

■ Informal monitoring of previously constructed 

facilities with bird-friendly design features has 

indicated these efforts have been successful. 

No bird fatalities have been observed. 

■ Continued retrofit of STM campus bus shelters with laminate to reduce the potential for 

bird collisions. 

■ Numerous rattlesnakes that posed a hazard to 

workers were relocated to nearby habitat on 

NREL sites. 

■ Monitoring of mammalian predators at the STM 

and NWTC sites continued in 2013. Data was 

collected from two motion detection cameras 

at each site. STM motion detection cameras 

confirmed continued use of the site by several 

species, including red fox (Vulpes vulpes), 

coyote, and striped skunk (Mephitis mephitis). 

NWTC motion detection cameras, once again, 

recorded two mammalian predators, coyote 

and bobcat (Felis rufus), and one avian predator 

species, the great-horned owl. 

■ Acoustic bat monitoring at the NWTC documented four species of bats over a 5-month 

period (May to September) including the Big 

brown bat (Eptesicus fuscus), the Silver-haired 

bat (Lasionycteris noctivagans), the Hoary bat 

(Lasiurus cinereus), and the Brazilian free-tailed 

bat (Tadarida brasiliensis).
ENVIRONMENTAL PERFORMANCE REPORT 2013 57

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 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 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 CRS 33-6-128: Damage or Destruction of Dens 

or Nests—Harassment of Wildlife, no wildlife dens or nests, 

young, or eggs may be damaged or destroyed unless 

permitted by the Colorado Division of Parks and Wildlife. It 

is unlawful for any person to willfully harass wildlife. 

The “Memorandum of Understanding (MOU) between the 

United States Department of Energy and United States 

Fish and Wildlife Service Regarding Implementation of 

EO 13186, Responsibilities of Federal Agencies to Protect 

Migratory Birds” (9/2013) formalizes DOE’s commitments 

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 nesting bird surveys are conducted. 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. 

Project Reviews – Biologists conduct project reviews to 

assess and reduce potential impacts to wildlife.

Coordination – Biologists coordinate with local, state, 

and federal agencies to improve wildlife management.

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. 

2013 Compliance Summary and Activities

■ Seventeen bird deaths occurred from collisions with 

windows from August to November at the recently 

constructed ESIF. The collisions involved 8 species, 

When rattlesnakes are reported near pedestrian areas of the 

STM site they are relocated to safer areas. Photo by Steve Wilcox, 

NREL 23924

Bobcat at NWTC. Photo by Jason Cotrell, NREL 24480
58 ENVIRONMENTAL PERFORMANCE REPORT 2013

including 6 mourning doves, 6 songbirds, 2 pigeons, 

1 magpie, and 2 unknown. An immediate interim solution was implemented by installing UV light reflecting decals on select windows. A long-term solution is 

being developed and is planned for implementation 

prior to the 2014 migration season. 

■ One bird death, an American Crow, was reported 

at the NWTC during the year. Workers at the site are 

requested to report incidental observations of bird 

mortalities to environmental program staff who track 

this information. 

10.2 ENDANGERED SPECIES AND 

SPECIES OF CONCERN

NREL manages its research and operational 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, and 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 on-site, 

the USFWS designated critical Preble’s habitat within the 

upper reaches of Rock Creek, including a small area at 

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

impacted 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 surveys are conducted for species that may 

occur at NREL sites, typically, every 5 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. 

The USFWS lists five other species occurring in the Platte 

River watershed in Nebraska in accordance with the ESA 

as species that must be considered for projects in Colorado and Wyoming that may deplete water supplies to the 

Platte River system. These include three birds, the piping 

plover (Charadrius melodus), the whooping crane (Grus 

americana), and the least tern (Sternula antillarum), a fish, 

the pallid sturgeon (Scaphirhynchus albus), and a plant, 

the Western prairie fringed orchid (Platanthera praeclara). 

For any NREL activities that may deplete water in the 

Platte River system, a consultation with the USFWS would 

be completed to determine potential impacts.

2013 Compliance Summary and Activities

Program activities were in compliance with requirements.
ENVIRONMENTAL PERFORMANCE REPORT 2013 59

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, out competing native plants 

for nutrients and water, while also sometimes depriving 

wildlife of nutrients and shelter. Plants such as kochia 

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

olive (Elaeagnus angustifolia), diffuse knapweed 

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

and myrtle spurge (Euphorbia myrsinites) are examples of 

non-native plants that can have destructive effects on 

natural habitats.

For these reasons, the focus of NREL’s approach to 

vegetation management is to:

■ Conserve existing ecosystems in their natural state as 

much as possible

■ Strive to replace disturbed vegetation with native 

species, or with adapted, but non-invasive species 

when necessary

■ Implement a program of weed management to 

prevent the spread of noxious weeds and implement 

measures to control these species

■ Implement a sustainable landscape design and 

maintenance program. 

Approximately 60 acres of land within the NWTC 

site boundaries are managed as conservation areas. 

The laboratory limits development in and manages these 

areas to conserve specific features there including seeps, 

ephemeral drainages, ponds, native grassland habitat, 

areas supporting ancient soils (a soil structure in association with plant species forming a stable ecological 

community that is resistant to weed invasion), a small 

area designated as critical habitat for the Preble’s meadow 

jumping mouse, an area of remnant tallgrass prairie, 

and a rocky outcropping supporting Ponderosa pine 

and shrublands. 

On the STM campus, 177 acres are under a conservation 

easement with Jefferson County. The easement preserves 

the natural character of the property, including its visual, 

biological, and recreational resources.

Where removal of native vegetation cannot be avoided, 

reseeding is done using grass and forb seed mixes native 

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

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

STM 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: 

■ Provide supplemental water during seedling growth 

and establishment and minimize water use thereafter

■ 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 RSF, NREL participated in the 

SITES 2-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 

(i.e., LEED certification) for new and existing buildings 

currently exists, there is no similar rating system for

Feather reed grass used in landscaping in front of the ESIF at landscaped environments. 

NREL’s STM site. Photo by Dennis Schroeder, NREL 27750
60 ENVIRONMENTAL PERFORMANCE REPORT 2013

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 to landscape plants, and to recharge groundwater in the area. 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

Vegetation management consists of a number of 

programs and plans that meet the requirements of 

EO 13112, Invasive Species, and the Colorado Noxious 

Weed Act and support the laboratory’s vegetation 

management approach. 

In Colorado, the Department of Agriculture Commissioner 

—in consultation with the Colorado 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. 

■ 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 STM stormwater detention pond serves as an important 

local habitat that provides wildlife with food, water, shelter 

and safe areas to raise their young. Photo by Michelle Slovensky, 

NREL 23403

2013 Accomplishments and Highlights 

■ NREL received SITES Program certification, 

achieving a three-star rating out of four, for the 

sustainable landscape design and management of the RSF and STM stormwater detention basin. In support of the certification, a 

Landscape Maintenance Plan was developed 

to coordinate and plan landscape maintenance 

responsibilities and activities across multiple 

groups at the lab. The plan establishes a 

campus landscape vision and directs landscaping maintenance and materials use supporting:

● Plant stewardship

● Invasive species management

● Organic materials management

● Soil stewardship

● Water conservation

● Stormwater management

● Materials recycling and composting

● Landscape maintenance equipment

● Snow and ice management. 

■ A laboratory-wide “snow push map” was used 

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 on campus. 
ENVIRONMENTAL PERFORMANCE REPORT 2013 61

Figure 3. Weed survey results at the STM.
62 ENVIRONMENTAL PERFORMANCE REPORT 2013

Figure 4. Weed survey results at the NWTC.
ENVIRONMENTAL PERFORMANCE REPORT 2013 63

The laboratory continues to address the control of 

these species using the integrated weed management 

approach described above. The weed maps in Figures 

3 and 4 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 5 years) to identify 

weed outbreaks. 

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.

2013 Compliance Summary and Activities

■ Program activities were in compliance 

with requirements.

■ Aggressive weed management continued. Knapweed 

is nearly under control at the NWTC and Canada thistle, 

hounds tongue, and myrtle spurge are under control 

at the STM site. In support of the goal to eliminate the 

A-listed noxious weed myrtle spurge from the STM 

site, the species was treated for the third consecutive 

year, and the affected areas have been much reduced. 

At the NWTC, herbicides were applied to approximately 88 acres in April, 42 acres in June, and 88 acres 

in September. At the STM site, approximately 16 acres 

were treated in May-June, 2 acres in July, and 9 acres 

in September.

10.4 WETLANDS AND 

FLOODPLAINS 

Floodplains are land areas adjacent to rivers and streams 

that are subject to recurring inundation. Wetlands are 

lands that are inundated or saturated by surface or 

groundwater at a frequency and duration sufficient 

to support distinct soil types and plant communities. 

Wetland areas typically take the form of swamps, marshes, 

bogs and groundwater seeps and are frequently located 

within or adjacent to a floodplain. 

Both wetlands and floodplains play a key role in providing 

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

promote the growth of wetland and riparian vegetation 

that provide habitat for a rich diversity of terrestrial and 

aquatic plants and animals. NREL preserves the important 

natural functions of its wetlands and floodplains, thereby 

protecting the physical, biological and chemical integrity 

of receiving waters and riparian areas on and adjacent to 

the STM 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

The STM stormwater detention pond regulates the flow of 

stormwater from the STM campus to neighboring Lena Gulch, 

mimicking pre-development hydrology. Photo by Dennis Schroeder, 

NREL 23189

TABLE 6. 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
64 ENVIRONMENTAL PERFORMANCE REPORT 2013

■ 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 that 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 are considered wetlands but do not fall 

within the jurisdiction of the USACE 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.

At the STM campus, the USACE issued a jurisdictional 

determination stating that all drainages examined are 

considered upland swales and consequently are not 

regulated by the USACE. The jurisdictional determination, 

which is valid for a period of 5 years through April 27, 

2014, allows NREL to perform work in the upland swales 

without a USACE permit. At the NWTC, a preliminary 

wetland assessment and delineation was jointly conducted with the USACE. A formal delineation will be submitted to the USACE to obtain a jurisdictional determination 

for the site. Non-jurisdictional functional wetlands are 

considered valuable features, and the laboratory seeks to 

preserve these.

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 

boundaries that affect the NWTC or STM sites. 

2013 Compliance Summary and Activities

Program activities were in compliance with requirements.

10.5 CULTURAL RESOURCES

Cultural resources are defined as any prehistoric or 

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

scientific, traditional, religious, or other reasons. 

Cultural resources can be divided into three 

major categories: 

■ Prehistoric and historic archaeological resources 

■ Architectural resources 

■ Traditional cultural resources. 

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

or left deposits of physical remains (e.g., arrowheads, 

pottery, and tools). Prehistoric resources that predate the 

advent of written records in a region range from a scatter 

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

Historic resources may include campsites, roads, fences, 

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

other features. 

Architectural resources include standing buildings, 

dams, canals, bridges, and other structures of historic 

or 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 

2013 Accomplishments and Highlights 

Qualified laboratory staff reviewed wetland 

vegetation and wetland mapping (see Appendix 

A) for both the STM and NWTC campuses.

157th Infantry on Parade at Camp George West, 1934. Used with 

permission from Denver Public Library.
ENVIRONMENTAL PERFORMANCE REPORT 2013 65

practices or beliefs of a living community that are rooted 

in the community’s history, and is 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. 

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 3 miles (4.8 km) 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 (303 hectares) and 

many buildings were added throughout the 1930s and 

1940s. During World War II, much of Camp George West 

was leased to the federal government for military training 

purposes. From the 1930s to the 1970s, several state entities took up residence at Camp George West, including the 

Colorado State Highway Patrol, the Colorado Law Enforcement Training Academy, and the Colorado Correctional 

Center. In 1981, more than 300 acres (121 hectares) were 

transferred to the federal government for solar energy 

research purposes. An additional 25 acres (10.1 hectares) 

were transferred to DOE in 2003. Today, the STM site totals 

327 acres (132 hectares).

Program Management

Cultural resources are protected under Sections 106 and 

110 of the National Historic Preservation Act of 1966. 

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. 

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 and features.

■ Implementing procedures to manage historic features 

and to protect undiscovered cultural resources 

and artifacts.

■ Periodically conducting surveys to document presence 

or absence of cultural or historic resources while considering project impacts to the human environment. When 

surveys reveal artifacts, staff work with the Colorado 

Office of Archaeology and Historic Preservation to 

determine if the artifacts are eligible for consideration 

as cultural or historic resources.

■ Requiring construction contractors to provide workers 

with site orientation training that includes guidance on 

what to do in the event they discover any evidence of 

cultural resources during ground-disturbing activities. 

Workers are to stop all work in the vicinity until a qualified archaeologist evaluates the significance of the find. 

Several formal surveys of historic and cultural resources 

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

three historical sites were recognized as significant 

Informational display at the former Camp George West small 

arms firing-line near the south entrance to the STM campus.

Photo by Tom Ryon, NREL 29508

2013 Accomplishments and Highlights 

In June 2013, DOE and NREL completed an 

informational display as mitigation for impacts to 

the former Camp George West 500- and 600-yard 

small arms firing lines during the construction 

of the south access road to the STM campus in 

accordance with a 2011 MOA with the Colorado 

Office of Archaeology & Historic Preservation. 

The firing lines are considered contributing 

features of the Camp George West Historic 

District. The informational display is located off of 

Research Road in Pleasant View Community Park 

and is accessible to the public. 
66 ENVIRONMENTAL PERFORMANCE REPORT 2013

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, lies south of the 

STM site.

2013 Compliance Summary and Activities

Program activities were in compliance with requirements.

Historic amphitheater at the STM site. Photo by David Parsons,

NREL 06921
ENVIRONMENTAL PERFORMANCE REPORT 2013 67

I In 1999, DOE granted a conservation easement for 177 

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

The purpose of the easement is to preserve the natural 

character of the property, including its visual, biological, 

and recreational resources.

The goals of the easement are to: 

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

ecological, and historical aspects of the conservation 

easement property 

■ Protect the ecosystem of the STM area and the 

sustainable habitat for diverse vegetation and wildlife

■ Ensure the scenic and biological integration with 

adjoining open-space land 

■ Prevent further industrial, commercial, or residential 

development of the conservation easement property 

■ Preserve the conservation easement property as 

natural open space. 

Local policies established by Jefferson County, Golden, 

and Lakewood reflect community sensitivity with 

respect to the visual qualities provided by natural 

resources in the 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 

11 CONSERVATION EASEMENT LANDS

Conservation easement on South Table Mountain. 

Photo by Christina Chase, NREL 22071 
68 ENVIRONMENTAL PERFORMANCE REPORT 2013

value of the property.3 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 east site entrance) to the trails on the mesa top. 

NREL staff and the public use these trails daily.

2013 Property Assessment 

During 2013, there was no NREL activity on the conservation easement property having the potential to degrade 

the environmental condition of the property. 

3

 U.S. Department of Energy, Golden Field Office (1999). National Renewable Energy Laboratory (NREL) Site Conservation Easement Baseline Inventory. Golden, Colorado. 
ENVIRONMENTAL PERFORMANCE REPORT 2013 69

The STM site draws hundreds of commuter vehicles 

daily, as well as visitor and delivery traffic entering 

and leaving the site. Traffic management for the site is 

important for minimizing negative impacts to traffic flow 

on Denver West Parkway and in nearby neighborhoods 

and business areas. Reducing traffic also reduces noise 

and light pollution, vehicle emissions, fuel use, parking 

requirements, and road maintenance costs.

The laboratory works to reduce traffic by encouraging:

■ Alternative modes of commuting, such as mass transit, 

ride-sharing (e.g., 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 peakhour 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 Denver 

West Parkway and Denver West Marriott Boulevard, 

as well as and Quaker St. and 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. Level of service is a qualitative 

measure of traffic flow based on the average delay per 

vehicle at an intersection. Typically, a LOS of “D” or better 

indicates acceptable operational conditions. Monitoring 

will continue to be conducted as additional staff are 

relocated to STM.

12 TRAFFICMANAGEMENT

NREL work rides his recumbent bicycle after stopping for 

some food and drink on Bike-2-Work Day. Hundreds of 

NREL employees opted for two wheels instead of four. 

Photo by Dennis Schroeder, NREL 26310
70 ENVIRONMENTAL PERFORMANCE REPORT 2013

Program Management

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 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 intersection of Denver West Parkway and Denver 

West Marriott Boulevard operates at a LOS of D 

or better. 

■ The intersection of Quaker St. and South Golden Road 

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 this annual Environmental Performance 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 (AWSs), 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 below. 

 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 RTD transit stations in 

Lakewood and Wheat Ridge. 

■ Incentive parking is provided for vanpools and 

carpools at the STM and Denver West sites. 

■ Vanpool incentives are available for participants who 

commute in formal organized vanpools.

■ Bike racks, bike lockers, and bicycle maintenance 

stations are in key locations on the STM site. Bike racks 

on shuttle vehicles permit staff to take their bikes 

with them when they commute or move between 

buildings.

■ RideShare Connections, an intranet site, allows staff 

to post and search listings for potential carpool and 

vanpool partners within NREL.

Incentive parking is provided for vanpools, carpools, and green 

vehicles, such as no- and low-emission vehicles. Photo by 

Dennis Schroeder, NREL 27807

A light rail train runs near the STM site. NREL shuttles provide 

a link for commuters from the train station to campus. Photo by 

Dennis Schroeder, NREL 25928

2013 Accomplishments and Highlights 

The completion of an additional right-turn lane 

in the eastbound direction at the intersection of 

Denver West Parkway and Denver West Marriott 

Boulevard in July 2013 further improved capacity at the intersection, allowing for increased 

acceptable NREL-generated peak-hour traffic 

volume thresholds. Throughout 2013, traffic 

monitoring indicated that NREL-generated 

traffic volumes and LOS remained within 

acceptable levels.
ENVIRONMENTAL PERFORMANCE REPORT 2013 71

■ Literature kiosks in key building locations provide 

shuttle and RTD schedules, bicycle maps, and 

telecommuting information.

■ Information sharing events promote safe bicycling, 

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

Flexible Workplace Practices

Conferencing by video, telephone, and the internet as 

well as AWSs provide flexibility in how people work, 

saving staff time, energy, and money. An AWS policy 

allows employees to work varying schedules and reduces 

the miles driven by employees to and from the laboratory. 

Telecommuting

Telecommuting allows staff (i.e., 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. 

2013 Compliance Summary and Activities

■ Program activities were in compliance with 

MAP requirements.

■ TDM measures required by the MAP were continued 

in 2013. 

■ Average PM peak hour traffic volume at the intersection of Denver West Parkway and Denver West Marriott Boulevard was 307 vehicle trips. The monitoring 

periods were April 2013, August 2013, and November 2013. 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.

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 PM and 5:30 PM This hour 

has been designated the PM peak hour. Video traffic 

surveillance was conducted during three weeks at three 

different times of the year. 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 intersection of Denver West 

Parkway and Denver West Marriott Boulevard.

Table 7 shows the results of the traffic counts at the east, 

west and south entrances to the STM site in April, August 

and November 2013. 

The applicable traffic volume threshold identified in the 

MAP is 387 vehicle trips in the PM peak hour (from 4:30 

PM to 5:30 PM) at the intersection of Denver West Parkway and Denver West Marriott Boulevard. This threshold 

identifies the acceptable number of vehicle trips NREL can 

contribute to the intersection without causing significant 

degradation to flow. In 2013, PM peak hour traffic volume 

averages remained below the MAP threshold even with 

the permanent relocation of approximately 250 DOE staff 

members to the STM campus from off-site leased 

office space. 

In 2013, PM peak hour traffic volume averages remained 

below the MAP threshold at 307 vehicle trips even with 

the permanent relocation of approximately 250 DOE staff 

members to the STM campus from off-site leased 

office space. 

TABLE 7. 2013 TRAFFIC COUNTS

Gate

PM Peak Hour Vehicles 

 (in- and out-bound)

April August Nov Average

East Entrance (Denver 

West Parkway/Denver 

West Marriott Blvd.)

285 294 343 307

West Entrance (Quaker St./

South Golden Road)

0 18 13 10

South Entrance (South 

Golden Road/Research Rd.)

183 213 282 226
72 ENVIRONMENTAL PERFORMANCE REPORT 2013

Vegetation surveys are periodically completed for the 

STM and NWTC sites with the most recent survey occur-

ring in 2011. Plant communities and species were identi-

fied 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 the STM site 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 the STM site include ravine shrubland, 

tall shrubland, short shrubland, and wetlands. The plant 

communities are described below and mapped as illus-

trated in Figure 5.

Short-grass Grassland

Short-grass grassland is found on the flat top of the mesa. 

The dominant grass species are blue grama (Chondro-

sum gracile), a native prairie species, and cheatgrass 

(Anisantha tectorum), a noxious weed. Populations of 

diffuse knapweed (Acosta diffusa) and Dalmatian toad-

flax (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 hen-and-chicks (Echinocereus viridiflorus)

and pincushion cacti (Coryphantha missouriensis and C. 

vivipara var. vivpara). Well-draining hillocks often support 

thick stands of needle-and-thread grass (Hesperostipa 

comata) and yucca (Yucca glauca). Some short shrubs 

such as rubber rabbitbrush (Chrysothamnus nauseosus 

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

(Rhus aromatica subsp. trilobata) occur infrequently

APPENDIX A: 

PLANT COMMUNITIES AT 

THE STM AND THE NWTC
ENVIRONMENTAL PERFORMANCE REPORT 2013 73

Figure 5. STM land cover types surveyed in 2011. Note: Map updated in 2012 to reflect site building changes. 
74 ENVIRONMENTAL PERFORMANCE REPORT 2013

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 mixed-grass 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 short-grass areas, a large number of forbs also 

occur in the mixed-grass 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 mixed-grass community.

Upland Shrublands

Shrubland habitat occurs along the upper sides of ravines 

and on the steeper mesa slopes, becoming more prominent as elevation increases up to the top of the mesa. The 

upland shrubland habitat, which excludes the shrublands 

in the ravine bottoms, comprises tall shrubland and short 

shrubland communities very similar in overall composition but distinguished by the dominant species. 

Tall Shrubland

The tall shrubland areas are defined by stands of mountain-mahogany (Cercocarpus montanus) that occur along 

the rim of the mesa, usually where volcanic cap rock is 

exposed, and on the upper mesa slopes below rimrock 

areas. The understory is notably sparse throughout this 

community, with a large amount of bare soil. Cheatgrass 

is the most common herbaceous species in these areas, 

intermixed with needle-and-thread grass, yucca, and 

many cacti.

Short Shrubland

The short shrublands occur on elevated flat areas amidst 

the surrounding grasslands, some of which appear to 

have experienced surficial disturbance in the past. These 

areas are distinctive because of 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 
ENVIRONMENTAL PERFORMANCE REPORT 2013 75

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 

Plantae4 no longer appears to support wetland vegetation. 

In 2002, cattail species near an old stock tank in the 

eastern-most drainage appeared to have been supported 

by a pipe coming out of the hillside. Although the stock 

tank was observed in the 2011 survey, it appears the 

cattails have not persisted in the intervening years. 

Disturbed/Reclaimed

This habitat type comprises all of the areas at the site 

that have experienced surface disturbance to vegetation 

caused by human activities. These mostly occur on the 

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

dumping areas. Most of these areas appear to have been 

re-vegetated and support a combination of native grassland plants, planted ornamental re-vegetation species, and 

native and introduced weeds.

NWTC Plant Communities

The majority of the vegetation at the NWTC site belongs 

to the mixed-grass prairie association of the grassland 

formation. Mixed-grass prairie is defined by the presence 

of grass species typical of the 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 19985, Plantae 

20006) is discussed below by specific plant community. 

The plant communities are described below and mapped 

as illustrated in Figure 6.

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 mixedgrass prairie. Species flowering in late spring include little 

bluestem, cheatgrass, sand lily (Leucocrinum montanum), 

wild iris (Iris missouriensis), Lambert locoweed (Oxytropis 

lambertii), mouse-ear (Cerastium strictum), western wallflower (Erysimum capitatum), and prairie golden pea

(Thermopsis rhombifolia). 

4, 6 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, Colorado.

5 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.
76 ENVIRONMENTAL PERFORMANCE REPORT 2013

Figure 6. NWTC land cover types surveyed in 2012.
ENVIRONMENTAL PERFORMANCE REPORT 2013 77

Wet Meadow

Three locations support wet meadows7 at the NWTC. 

One is south of the SunEdison solar array, the second is at 

the upper end of the Rock Creek tributary along Row 4, 

and the third is adjacent to the Building 251 east parking 

lot. A wet meadow is a type of grassland that transitions 

between mesic and hydric conditions (i.e., 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. 

An isolated group of hawthorn (Crataegus erthyropoda)

shrubs occurs along the western site boundary, within the 

NWTC site boundary. These trees are at the top of the slope 

and occur directly east of an active area of construction 

disturbance, which is outside the NWTC site boundary. 

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 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.

7

 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.
78 ENVIRONMENTAL PERFORMANCE REPORT 2013

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 years.8

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.

8 Plantae Consulting Services (2000). Vegetation Survey, NREL National Wind Technology Center. Boulder, Colorado. 
ENVIRONMENTAL PERFORMANCE REPORT 2013 79

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 AND THE NWTC

TABLE 8. 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

Table 8 continued on page 80
80 ENVIRONMENTAL PERFORMANCE REPORT 2013

TABLE 8. WILDLIFE SPECIES AT THE STM*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

BIRDS

Common grackle Quiscalus quiscula X

Common nighthawk Chordeiles minor X X X

Common raven Corvus corax X X

Common snipe Gallinago delicata X

Cooper's hawk Accipiter cooperii X X

Dark-eyed junco Junco hyemalis X X

Double-crested cormorant Phalacrocorax auritus X

Eastern kingbird Tyrannus tyrannus X

Eurasian collared dove** Streptopelia decaocto

European starling Sturnus vulgaris X X X

Golden eagle Aquila chrysaetos X

Grasshopper sparrow Ammodramus savannarum X

Great blue heron Ardea herodias X X

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
ENVIRONMENTAL PERFORMANCE REPORT 2013 81

TABLE 8. WILDLIFE SPECIES AT THE STM*

SPECIES COMMON NAME SCIENTIFIC NAME 1987 Survey 2005 Survey 2011 Survey

BIRDS

Sharp-shinned hawk Accipiter striatus X

Spotted towhee Pipilo maculates X

Swainson's hawk Buteo swainsoni X

Tree swallow Tachycineta bicolor X X

Turkey vulture Cathartes aura X

Vesper sparrow Pooecetes gramineus X

Virginia’s warbler Oreothlypis virginiae X 

Violet-green swallow Tachycineta thalassina X

Western kingbird Tyrannus verticalis X X

Western meadowlark Sturnella neglecta X X

Western scrub-jay Aphelocoma californica X

White-crowned sparrow Zonotrichia leucophrys X

White-faced ibis Plegadis chihi X

White-throated swift Aeronautes saxatalis X

Yellow-breasted chat Icteria virens X

Yellow-rumped warbler Dendroica coronata X

MAMMALS 

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.

Table 8 continued on page 82
82 ENVIRONMENTAL PERFORMANCE REPORT 2013

TABLE 8. WILDLIFE SPECIES AT THE NWTC*

SPECIES COMMON NAME SCIENTIFIC NAME 1996 Survey 2003 Survey 2011 Survey

BIRDS

American crow Corvus brachyrhynchos X

American goldfinch Spinus tristis X X

American kestrel Falco sparverius X X X

American pipit Anthus rubescens X

American robin Turdus migratorius X X

American tree sparrow Spizella arborea X

Bald eagle Haliaeetus leucocephalus X

Barn swallow Hirundo rustica X X

Black-billed magpie Pica hudsonia X X

Black-capped chickadee Poecile atricapillus X X

Blue-gray gnatcatcher Polioptila caerulea X

Blue jay Cyanocitta cristata X

Brewer's blackbird Euphagus cyanocephalus X X

Brewer's sparrow Spizella breweri X

Broad-tailed hummingbird Selasphorus platycercus X X

Broad-winged hawk Buteo platypterus X

Brown-headed cowbird Molothrus ater X X

Bullock's oriole Icterus bullockii X

Canada goose Branta canadensis X

Cedar waxwing Bombycilla cedrorum X

Chipping sparrow Spizella passerina X X

Cliff swallow Petrochelidon pyrrhonota X

Common grackle Quiscalus quiscula X X

Common nighthawk Chordeiles minor X

Common raven Corvus corax X X

Common snipe Gallinago delicata X

Cooper’s hawk Accipiter cooperii X

Dark-eyed junco Junco hyemalis X

Double-crested cormorant Phalacrocorax auritus X

Downy woodpecker Picoides pubescens X

Eurasian collared-dove Streptopelia decaocto X

European starling Sturnus vulgaris X X

Ferruginous hawk Buteo regalis X X

Franklin's gull Larus pipixcan X

Golden eagle Aquila chrysaetos X X X

Grasshopper sparrow Ammodramus savannarum X X

Gray catbird Dumetella carolinensis X

Great blue heron Ardea herodias X X

Great horned owl Bubo virginianus X

Green-tailed towhee Pipilo chlorurus X

Hairy woodpecker Picoides villosus X

Horned lark Eremophila alpestris X X

House finch Carpodacus mexicanus X X

Killdeer Charadrius vociferus X
ENVIRONMENTAL PERFORMANCE REPORT 2013 83

TABLE 8. WILDLIFE SPECIES AT THE NWTC*

SPECIES COMMON NAME SCIENTIFIC NAME 1996 Survey 2003 Survey 2011 Survey

BIRDS

Lark bunting Calamospiza melanocorys X

Lark sparrow Chondestes grammacus X

Loggerhead shrike Lanius ludovicianus X

Long-billed curlew Numenius americanus X

Mallard Anas platyrhynchos X X

Merlin Falco columbarius X

Mountain bluebird Sialia currucoides X X

Mountain chickadee Poecile gambeli X

Mourning dove Zenaida macroura X X

Northern flicker Colaptes auratus X X

Northern goshawk Accipiter gentilis X

Northern harrier Circus cyaneus X X X

Osprey Pandion haliaetus X

Peregrine falcon Falco peregrinus X X

Prairie falcon Falco mexicanus X X

Red-headed woodpecker Melanerpes erythrocephalus X

Red-tailed hawk Buteo jamaicensis X X X

Red-winged blackbird Agelaius phoeniceus X X

Rough-legged hawk Buteo lagopus X X X

Ruby-crowned kinglet Regulus calendula X

Sandhill crane Grus canadensis X

Savannah sparrow Passerculus sandwichensis X

Say's phoebe Sayornis saya X X

Sharp-shinned hawk Accipiter striatus X

Song sparrow Melospiza melodia X

Spotted towhee Pipilo maculatus X

Swainson's hawk Buteo swainsoni X X

Tree swallow Tachycineta bicolor X

Turkey vulture Cathartes aura X X X

Vesper sparrow Pooecetes gramineus X X

Western kingbird Tyrannus verticalis X X

Western meadowlark Sturnella neglecta X X

Wilson’s warbler Wilsonia pusilla X

Yellow-rumped warbler Dendroica coronata X

Table 8 continued on page 84
84 ENVIRONMENTAL PERFORMANCE REPORT 2013

TABLE 8. 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

*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.
ENVIRONMENTAL PERFORMANCE REPORT 2013 85

TABLE 9. NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2013

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

AST for petroleum 

storage STM ESIF AST Registration DOPS 19275-1 Completed

AST for petroleum 

storage STM PDU AST Registration DOPS 2873-2 Completed

AST for petroleum 

storage STM RSF2 AST Registration DOPS 2873-3 Completed

AST for petroleum 

storage STM SERF AST Registration DOPS 2873-1 Completed

AST for petroleum 

storage SolarTAC AST Registration DOPS 19325-1 Completed

Air Laboratory-wide servicing of CFC-containing 

equipment Notification APCD 647 Active

Air DWOP CFC-containing stationary source Registration APCD 647 Active

Air STM SERF, 2 CFC-containing stationary sources Registration APCD 647 Active

Air STM FTLB waste gas combustor Permit APCD 99JE0400 Active

Air STM RFHP wood waste boiler Permit APCD 07JE0277 Active

Air STM fugitive dust from construction activities Permit APCD 08JE0889L Active

Air STM RSF 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

APPENDIX C: 

ENVIRONMENTAL PERMITS, 

REGISTRATIONS, AND 

NOTIFICATIONS APPLICABLE 

TO NREL DURING 2013

Table 9 continued on page 86
86 ENVIRONMENTAL PERFORMANCE REPORT 2013

TABLE 9. NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2013

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

Earth disturbance STM stormwater detention basin grading 

permit Permit Jefferson County 10-126950GP Active

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

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 COR12A43F Terminated

Stormwater STM stormwater detention basin construction 

project Permit EPA COR12A36F Terminated

Stormwater STM ESIF construction project Permit EPA COR12A60F Active

Stormwater STM parking garage and south entrance 

construction project Permit EPA COR12A61F Terminated
ENVIRONMENTAL PERFORMANCE REPORT 2013 87

TABLE 9. NREL’S ENVIRONMENTAL PERMITS, REGISTRATIONS, AND NOTIFICATIONS IN 2013

Type Location/ Description Category Issuing 

Agency ID #

Permit or 

Registration 

Status

Stormwater NWTC dynamometer expansion construction 

project Permit EPA COR12A41F Active

Stormwater STM RSF II Construction Project Permit EPA COR12A62F Active

Stormwater STM IBRF construction project Permit EPA COR12A64F Terminated

Stormwater STM vehicle test pad construction project Permit EPA COR12A63F Terminated

Stormwater

STM SERF & STF Landscape Improvements/

Denver West Parkway Safety Enhancements 

(FTLB)

Permit EPA COR12AW4F Active


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