# F INDING OF 

# N O 

# S IGNIFICANT 

# I MPACT AND


# F INAL 

# E NVIRONMENTAL 

# A SSESSMENT OF


# T HREE 

# S ITE 

# D EVELOPMENT 

# P ROJECTS AT THE


# N ATIONAL 

# R ENEWABLE 

# E NERGY 

# L ABORATORY


# S OUTH 

# T ABLE 

# M OUNTAIN 

# S ITE



## July 2007

U.S. Department of Energy Golden Field Office National Renewable Energy Laboratory 1617 Cole Boulevard Golden, Colorado 80401 DOE/EA-1573Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

i TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS ....................................................................................................i v
EXECUTIVE SUMMARY ..........................................................................................................................v

1.0 INTRODUCTION ...........................................................................................................................1

1.1 The National Environmental Policy Act and Related Procedures ...................................... 1
1.2 Background......................................................................................................................... 2
1.3 Purpose and Need ............................................................................................................... 2
1.4 Scoping ............................................................................................................................... 6
1.5 Comments on the Draft EA................................................................................................. 6

2.0 PROPOSED ACTION AN D ALTERNATIVES ............................................................................7

2.1 Renewable Fuel Heating Plant............................................................................................ 7
2.2 SolarTAC Project.............................................................................................................. 1 1
2.3 Mesa Top Photovoltaic Project......................................................................................... 12
2.4 No Action Alternative....................................................................................................... 13
2.5 Alternatives Considered But Not Analyzed...................................................................... 13

3.0 EXISTING ENVIRONMENT AND ENVIRONMENTAL IMPACTS .......................................14

3.1 Environmental Impacts of the Proposed Action ............................................................... 14
3.1.1 Land Use, Planning, Socioeconom ics, and Public Policy....................................14
3.1.1.1 Existing Environment..........................................................................14
3.1.1.2 Impacts of the Proposed Action...........................................................15
3.1.2 Traffic and Circulation.........................................................................................17
3.1.2.1 Existing Environment..........................................................................17
3.1.2.2 Impacts of the Proposed Action...........................................................18
3.1.3 Air Quality ...........................................................................................................19
3.1.3.1 Existing Environment..........................................................................19
3.1.3.2 Impacts of the Proposed Action...........................................................20
3.1.4 Visual Quality/Aesthetics ....................................................................................25
3.1.4.1 Existing Environment..........................................................................25
3.1.4.2 Impacts of the Proposed Action...........................................................26
3.1.5 Water Resources ..................................................................................................28
3.1.5.1 Existing Environment..........................................................................28
3.1.5.2 Impacts of the Proposed Action...........................................................29
3.1.6 Geology and Soils................................................................................................30
3.1.6.1 Existing Environment..........................................................................30
3.1.6.2 Impacts of the Proposed Action...........................................................30
3.1.7 Biological Resources and Wetlands.....................................................................31
3.1.7.1 Existing Environment..........................................................................31Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

ii 3.1.7.2 Impacts of the Proposed Action...........................................................34
3.1.8 Cultural Resources...............................................................................................35
3.1.8.1 Existing Environment..........................................................................35
3.1.8.2 Impacts of the Proposed Action...........................................................35
3.1.9 Noise....................................................................................................................36
3.1.9.1 Existing Environment..........................................................................36
3.1.9.2 Impacts of the Proposed Action...........................................................37
3.1.10 Waste Management..............................................................................................38
3.1.10.1 Existing Environment..........................................................................38
3.1.10.2 Impacts of the Proposed Action...........................................................39
3.1.11 Public Facilities, Services, and Utilities ..............................................................39
3.1.11.1 Existing Environment..........................................................................39
3.1.11.2 Impacts of the Proposed Action...........................................................40
3.1.12 Energy and Sustainability ....................................................................................40
3.1.13 Intentional Destructive Acts ................................................................................40
3.2 Environmental Consequences of the No Action Alternative ............................................ 41

4.0 CUMULATIVE AND SEC ONDARY IMPACTS........................................................................43

5.0 COMMITMENT OF RESOURCES AND SHORT-TERM USES...............................................45

5.1 Irreversible/Irretrievable Commitment of Resources ....................................................... 45
5.2 The Relationship between Local Short-Te rm Uses of the Human Environment and the Maintenance and Enhancemen t of Long-Term Productivity ...................................... 45

6.0 REFERENCES ..................................................................................................................... .........46

APPENDIX A SCOPING LETTERS...............................................................................................A-1

APPENDIX B SCOPING LETTER DISTR IBUTION LISTS ........................................................ B-1

APPENDIX C RESPONSES RECEIVED TO SCOPING LETTER............................................... C-1

APPENDIX D RESPONSES TO COMMENTS ON THE DRAFT EA..........................................D-1

APPENDIX E DRAFT RFHP CONSTRUCTION PERMIT .......................................................... E-1Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

iii LIST OF TABLES

Table 3-1. Estimated Annual Emissions at the STM Site, 2001 ........................................................19
Table 3-2. Predicted Emissions Compared to NAAQS .....................................................................21
Table 3-3. Comparison of Maximum Predicted Impact to Health-Based Standards .........................22
Table 3-4. Comparison of Emissions: Current Plant, Proposed Plant, and Open Burning ................23
Table 3-5. Vegetation Types at NREL, STM Site, Golden, Colorado...............................................32
Table 3-6. RFHP Equipment Noise Levels........................................................................................37
Table 3-7. Waste Generation at the STM Site, 2003-2006 ................................................................39

LIST OF FIGURES

Figure 1-1. Regional Location of the STM Site ....................................................................................3 Figure 1-2. Local Setting of the STM Site ............................................................................................4 Figure 2-1. STM and the Relative Locations of the Three Proposed Projects on the Site ....................8 Figure 2-2. Site Layout of the RFHP.....................................................................................................9 Figure 3-1. Site Development Zones and Proposed Improvements at the STM Site ..........................16 Figure 3-2. View of the Visitors Center, SERF, and Mesa-Top Facilities ..........................................25 Figure 3-3. View of Mesa-Top Facilities, FTLB, and SERF ..............................................................26 Figure 3-4. Simulated View of the Proposed RFHP, with the Proposed MTPP in the Distance ........27 Figure 3-5. Simulated View of the Proposed Sola rTAC Project and Parking Area............................27 Figure 3-6. Simulated View of the Proposed MTPP from I-70...........................................................28Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

iv ACRONYMS AND ABBREVIATIONS

ACGIH American Conference of G overnmental Industrial Hygienists APE area of potential effects BMP best management practice °C degree Celsius CCR Code of Colorado Regulations CDOW Colorado Division of Wildlife CDPHE Colorado Department of Public Health and Environment CFR Code of Federal Regulations CO carbon monoxide CO 2 carbon dioxide dBA A-weighted decibel DOE U.S. Department of Energy DWOP Denver West Office Park EA environmental assessment EERE DOE’s Office of Energy Efficiency and Renewable Energy EPA U.S. Environmental Protection Agency °F degree Fahrenheit FTLB Field Test Laboratory Building I-70 Interstate 70 IPCC Intergovernmental Panel on Climate Change LOS level of service
μ g/m 3 micrograms per cubic meter MTPP Mesa Top Photovoltaic Project MW megawatt NAAQS National Ambient Air Quality Standards NEPA National Environmental Policy Act NIOSH National Institute for Occ upational Safety and Health NO X nitrogen oxides NREL National Renewable Energy Laboratory OSHA Occupational Safety and Health Administration PM 10 particulate matter less than 10 microns PV photovoltaic REL recommended exposure limit RFHP Renewable Fuel Heating Plant S&TF Science and Technology Facility SERF Solar Energy Research Facility SO 2 sulfur dioxide SOTAC Solar Technology Advancement Consortium SolarTAC SolarTAC Project (NREL Site) SVOC semivolatile organic compound STM South Table Mountain TAP toxic air pollutant TOC total organic carbon TLV threshold limit value USFWS U.S. Fish and Wildlife Service VOC volatile organic compoundFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

v EXECUTIVE SUMMARY

Introduction

In accordance with the Department of Energy (DOE) National Environmental Policy Act (NEPA) implementing regulations, DOE is required to eval uate the potential environmental impacts of DOE facilities, operations, and related funding decisions. DOE proposes to construct and operate three site development projects at the National Renewable En ergy Laboratory’s (NREL) South Table Mountain (STM) site:

• A Renewable Fuel Heating Plant (RFHP) th at would use woodwaste as its primary fuel;

• Various solar technology advancement inst allations, collectively called SolarTAC;

• A Mesa Top Photovoltaic Project (MTPP) that woul d generate about 1.0 megawatt (MW) of solar energy for use at the STM site.

The decision to use federal funds for these three site improvement projects requires that DOE address NEPA requirements and related environmental documentation and permitting requirements. In compliance with the NEPA (42 U.S.C. 4321) and w ith DOE’s NEPA implementing regulations (10 CFR section 1021.330) and procedures, this environmen tal assessment (EA) examines the potential environmental impacts of DOE’s decision to support this Proposed Action and also examines a No Action Alternative.

In 2003, DOE issued the Final Site-Wide EA of the National Renewable Energy Laboratory’s South Table Mountain Complex (DOE/EA-1440). Each of the three proposed projects that are the topic of this EA would occur in areas that were analyzed in the site -wide EA. The site-wide EA provides the analytical structure to assess the potential environmental impacts of the specific Proposed Action that is the topic of this EA. The site-wide EA is incorporated in its entir ety into this EA by reference, and this EA tiers off the descriptions of the affected environment and the potential environmental impact assessments presented in the site-wide EA. The site-wide EA is available at http://www.eere.energy.gov/golden/NREL_STM.aspx

Purpose and Need

The proposed projects would substantially reduce NREL’s use of natural gas and grid-provided electricity, while simultaneously a dvancing and contributing to comme rcialization of renewable energy technologies.

Renewable Fuel Heating Plant . The proposed RFHP would reduce NREL’s current STM site natural gas consumption by an estimated 75 to 80 percent by using woodwaste to replace most natural gas usage in the primary site heating boiler. The project would also showcase the viability of woodwaste biomass fuels as an alternative to fossil fuel heating.

SolarTAC . SolarTAC would accelerate the introduction and recognition of pre-commercial and earlycommercial solar energy technologies in the U.S. marketplace. It would support and promote the commercial acceptance of solar energy technologies. The SolarTAC Project would provide a launch pad for commercialization of solar-generating technologi es in Colorado and elsewhere, such that solar technologies would become an increasingly important and ultimately indispensable contributor to the energy use profile in the United States and across the world.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

vi Mesa Top Photovoltaic Project . The proposed MTPP would generate about 1.0 MW of solar electric energy to offset NREL’s growing energy demand. This is consistent with DOE’s long-term site development plans and energy goals to increase on-s ite renewable energy generation at the laboratory.

Proposed Action and Alternatives

Renewable Fuel Heating Plant . The RFHP would operate as the primary winter heat source for NREL’s research and support facilities and would largely replace the site’s current use of natural gas-fired boilers for heat. The Challenger Combustion System TM proposed for the plant is designed specifically for the combustion of solid waste fuels to optimize energy r ecovery and minimize air emissions. The RFHP fuel would consist of woodwaste such as construction w aste, urban tree trimmings, pallets, and forest thinnings. Woodwaste acceptance criteria would be developed to ensure that contaminants and undesirable components were not combusted in the RFHP. At a minimum, woodwaste containing chemically treated, stained, painted, laminated, or otherwise altered wood produc ts would be prohibited. Fuel would be delivered three to five times per week at 23 metric tons (25 tons) per load during the heating season. Total annual fuel consumption is estim ated to be 2,722 metric tons (3,000 tons).

The burner would be housed in a new building appr oximately 21 meters (70 feet) long, 11 meters (35 feet) wide, and 9 meters (30 feet) high. It would be constructed at the edge of a natural drainage near the center of the STM main campus. The building would be constructed of architectural concrete block similar to the finish on the existing Field Test La boratory Building. The stack would extend 3 meters (10 feet) above the roof. Construction is projected to take 6 to 7 months.

In addition to the new building, a driveway would be installed for trucks to access the building, and a turnaround area to facilitate delivery truck traffic flow may be installed. A wing wall would be installed at the end of the culvert to prevent flooding into the building’s ground floor.

Pollution control equipment would consist of a mu lti-cyclone to control particulate matter. The combustion unit and associated equipment would be monitored and adjusted to maintain optimal efficiency of the pollution control equipment. The major RFHP components would have an estimated 10- to 30-year lifetime. At the end of its useful lifetime, the RFHP would be decommissioned, removed, and disposed of as solid waste or recycled in a ma nner consistent with NREL’ s facilities management and waste management policies applicable at that time.

SolarTAC . The SolarTAC center would showcase and test va rious solar energy generation, use, control, and communications equipment. The area would includ e residential photovoltaic (PV) systems, utility PV systems not requiring special safety precautions, stand-alone PV systems (e.g., bus-stop shelters, remote lighting), and similar systems. Solar arrays and co mmunications equipment would be installed on various rooftops at NREL and at other locations not accessible to SolarTAC visitors. Plans include a small solar demonstration house of approximately 170 to 230 sq uare meters (1,800 to 2, 500 square feet) showing efficient insulation; a working PV system with i nverter, batteries, and appliances; and information displays.

The SolarTAC center would be located primarily ou tdoors. It would be constructed on approximately 0.8 hectare (2 acres) of land east of a natural drainage that lies northeast of the NREL Visitors Center. The site would be graded, concrete pads would be poured to support solar panels, a foundation would be poured for the solar demonstration house, and gravel or road base material would be installed for a walkway and access road. Fencing would limit ac cess to potentially dange rous equipment.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

vii A 3.6-meter (12-foot) wide contractor access and service drive terminating at a 30-meter (100-foot) diameter turnaround area would be constructed immediat ely east of the proposed main SolarTAC facility arrays. A new pedestrian footbridge connecting the ma in SolarTAC displays to the NREL Visitors Center would cross the natural drainageway. Ultimately, th e proposed SolarTAC could include construction of a new 54-space parking lot in the median area located south of the existing 39-space NREL Visitors Center parking lot.

Mesa Top Photovoltaic Project . The MTPP would be a PV system located adjacent to the existing Solar Radiation Research Laboratory. It would convert appr oximately 2 hectares (5 acres) of open, undeveloped mesa-top land to a restricted access area used for the commercial generation of solar energy. It would be designed to generate approximately 1.0 MW of sola r energy to be used on-site by DOE. The maximum allowable PV panel height would be 2.4 meters (8 feet) above the ground to minimize the visual impact of the PV system. Concrete pads would be poured to support solar panels, and possibly to support utility lines if poles were used.

The MTPP would be enclosed by a 2-meter (6-foot) chai n link fence with three strands of barbed wire on top. Motion-activated lighting would provide safety for workers after dark and minimize night shine from the mesa top. Once installation was complete, the n eed for human presence would be rare (probably one visit per week for a short inspection). Interconnec tion to the STM site would likely be through an existing, spare 13.2-kilovolt/480-volt three-phase tran sformer with a 1-MW capacity, located near the middle of the proposed MTPP site.

No Action Alternative

The three proposed projects would not be implem ented and the STM would remain in its current configuration. The No Action Alternative would not preclude other development projects from being proposed at such time as NREL determined them to be ripe for NEPA action.

Scoping

On April 2, 2007, a scoping/consultation letter was di stributed to county, state, and federal agencies; organizations that may have inform ation regarding potential environmental issues in the vicinity of the project site; and 1,470 Pleasant Ridge residential addresses. The only comments received were from the Colorado Historic Preservation Officer recommending con tinued coordination, an e ffort to which DOE is committed; the U.S. Fish & Wildlife Service, wh ich expressed no concerns regarding the proposed actions and protected species; and the Colorado Depart ment of Public Health and Environment, which acknowledged receipt of the air quality determination letter for the RFHP.

Environmental Consequences

The EA identified and assessed the following environmental resource areas:

Land Use, Planning, Socioeconomics, and Public Policy Traffic and Circulation Air Quality Visual Quality/Aesthetics Water Resources Geology and Soils Biological Resources and Wetlands Cultural ResourcesFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

viii Noise Waste Management Public Facilities, Services, and Utilities Energy and Sustainability Intentional Destructive Acts

For many of the environmental resource areas assessed in the EA, the three site improvement projects that make up the Proposed Action would not result in either adverse or beneficial impacts because the project area and surrounding area lack sensitive receptors or r esource areas that would be impacted (e.g., species of concern; on-site perennial creeks, streams, ponds , or floodplains; cultural resources; wetlands; lowincome or minority populations; off-site noise r eceptors; agriculturally productive soils; or high commercial- or aesthetic-value geologic resources. ) However, implementation of the three site improvement projects would result in some environmental impacts.

The proposed RFHP would result in emissions of crite ria air pollutants and toxic air pollutants (TAPs). Based on a dispersion modeling analysis of the propos ed RFHP, emissions of criteria air pollutants would not exceed National Ambient Air Quality Standards (NAAQS), nor would they pose a health risk based on the American Conference of Governmental Indus trial Hygienists (ACGIH) Threshold Limit Values (TLVs) or the National Institute for Occupationa l Safety and Health (N IOSH) Recommended Exposure Limits (RELs). Although the proposed RFHP would substantially reduce the STM site’s use of and reliance on natural gas (a limited and increasingly expe nsive fossil fuel) and would reduce emissions of geologically sequestered carbon dioxide (CO 2 ), it would also increase the site’s net emissions of CO 2 , a greenhouse gas.

Collectively, the three proposed projects would result in the loss of approximately 3 hectares (8 acres) of grassland and shrubland habitat. The RFHP and the SolarTAC Project would be constructed in or adjacent to natural drainages, which are among the site ’s most productive wildlife habitats and corridors. The drainages also support the site’s richest vegeta tion. The MTPP would be an extension of DOE’s existing mesa-top facilities. Although construction in this area was agreed to when the adjacent conservation easement was established in 1999, the mesa top is a sensitive environmental area where development is discouraged by local government and environmental interest groups.

Construction of the three proposed facilities would result in short-term (up to 1 y ear) increases in on-site traffic, noise, fugitive dust, auto and equipment emissions, and construction debris. Operationally, the proposed RFHP and the MTPP would have little impact on either on-site or off-site traffic. However, the proposed SolarTAC Project could attract up to 500 vis itors a month. This influx could further strain already limited on-site parking and traffic flow. Until supplemental parking for the SolarTAC was constructed, there could be a need for NREL visitors to park off-site and walk to th e site, or for the site to implement shuttle bus service to accommodate visitors.

The equipment and facilities that would be added to the STM site under the Proposed Action would not be unique to the site. The appearance of these facilities would in fact be similar to other buildings and PV panels that have been a part of the STM site fo r many years. As such, the addition of the RFHP, SolarTAC, and MTPP would add to, but would not substantially alter, the visual impact and character of the site. If the proposed facilities were noticed at all, the casual observer would likely note only that the added development resembled the structures already on the site

The proposed actions would not result in untreated oper ational discharges of pollutants to surface water or groundwater. Drains would be connected to the site ’s existing stormwater and sewage lines, and allFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

ix discharges to the publicly owned tr eatment works would meet the requirements of the Metro Wastewater Reclamation District and the Pleasant View Water and Sanitation District.

The new construction would increase the impervious surface area, which could increase quantities of stormwater conveyed off-site. Management practi ces, including stormwater pollution prevention measures to minimize runoff, would be implemented to the fullest extent possible during construction to minimize degradation of surface water quality due to sediment and various chemicals associated with additional vehicles and construction equipment.

The Proposed Action would not increase the susceptibility of the STM site to intentional destructive acts.

The Proposed Action would be consistent with th e overall objectives and mission of NREL and would occur within areas evaluated and committed to for further development in the 2003 site-wide EA.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

1 1.0 INTRODUCTION

The U.S. Department of Energy (DOE) proposes to co nstruct and operate three site development projects at the National Renewable Energy Laboratory ’s (NREL) South Table Mountain (STM) site:

• A woodwaste-burning heating plant adjacent to the STM Field Test Laboratory Building (FTLB) that would use renewable fuel;

• Various solar technology advancement installations for research and demonstration at the STM complex, primarily northeast of the NREL Visitors Center;

• A solar power generation project on the STM mesa top.

In compliance with the National Environm ental Policy Act (NEPA) (42 U.S.C. §§ 4321 et seq .) and with DOE’s NEPA implementing regulati ons (Title 10 Code of Federal Re gulations [CFR] Part 1021) and procedures, this final environmental assessment (E A) examines the potential environmental impacts, both individual and cumulative, of the Proposed Action. No other action alternatives are analyzed in this EA. For purposes of comparison, this EA also evaluates th e impacts that would occur if DOE decided not to implement the Proposed Action (the No Action Alternative).

This final EA has been prepared under DOE’s regulati ons and guidelines for compliance with NEPA. It is being distributed to interested members of the public and to federal, state, and local agencies for review and comment prior to DOE’s final decision on the Proposed Action.

1.1 The National Environmental Policy Act and Related Procedures

The Council on Environmental Quality regulations for implementing the procedural provisions of NEPA (40 CFR Parts 1500-1508) and DOE’s implementing procedures for compliance with NEPA (10 CFR Part 1021) require that DOE, as a federal agency:

• Assess the environmental impacts of its proposed actions;

• Identify any adverse environmental effects that cannot be avoided should a proposed action be implemented;

• Evaluate alternatives to the proposed ac tion, including a no action alternative;

• Describe the relationship between local short-te rm uses of the environment and the maintenance and enhancement of long-term productivity; and

• Characterize any irreversible and irretrievable commitments of resources that would be involved should the proposed action be implemented.

These requirements must be met before a final decisi on is made to proceed with any proposed federal action that could cause significant impacts to human hea lth or the environment. This final EA is intended to meet DOE’s regulatory requirements under NEPA and to provide DOE, the State of Colorado, and other agency decision-makers with the information th ey need to make informed decisions in connection with this Proposed Action.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

2 1.2 Background

NREL History and Research Mission

NREL will mark its 30th anniversary in July 2007. In July 1977, DOE opened the Solar Energy Research Institute as a federal facility dedicated to harnessing solar power. In 1991, it ach ieved national laboratory status and was renamed the National Renewable Ener gy Laboratory. Today, NREL is one of 10 DOE national laboratories and is the nation’s primary labor atory for renewable energy and energy efficiency research and development. NREL’s mission is fo cused on advancing natio nal energy policy and efficiency goals, particularly in the areas of re newable, wind, and solar energy research, development, demonstration, and deployment. NREL conducts resear ch activities at the STM site in support of the following DOE research programs:

• Solar energy technologies

• Geothermal technologies

• Distributed energy, electrical infrastructure, and reliability

• Biomass

• Industrial technologies

• Freedom car and vehicle technology

• Hydrogen, fuel cells, and infrastructure technologies

• Buildings technologies

• Weatherization and intergovernmental grants

• Federal energy management

• Other DOE-sponsored programs

• Work for others supporting the DOE mission

NREL is operated for DOE through a partnership betw een Midwest Research Institute and the Battelle Memorial Institute. The laboratory comprises three main sites: STM , the adjacent Denver West Office Park (DWOP) in Golden, Colorado, and the National Wind Technology Center located just south of Boulder, Colorado. The STM and DWOP sites are coll ectively referred to as the STM complex. The three site development projects that make up the Proposed Action and are the subject of this EA would be implemented at the STM site. Figures 1-1 and 1-2 illust rate the regional location and local setting of the STM site and the Proposed Action.

1.3 Purpose and Need

The purpose of the Proposed Action is to suppor t and advance DOE’s mission in the research and development of energy efficiency and renewable en ergy technologies. DOE’s Office of Energy Efficiency and Renewable Energy (EERE) leads the national resear ch effort to develop clean, competitive, and reliable energy technologies for the 21st century. The goal of the EERE program is to improve the nation's overall economic strength and competitiveness, energy security, and environmental stewardship through the development, demonstr ation, and deployment of clean, competitive, and reliable power technologies. The three STM site development projects that make up the Proposed Action would contribute to achieving this goal.

Purpose of the EA

In 2003, DOE issued the Final Site-Wide EA of the National Renewable Energy Laboratory’s South Table Mountain Complex (DOE/EA-1440) (DOE, 2003). That EA addressed future developments,Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

5 improvements, and on-site activities at the STM complex and future changes associated with changes to the STM site boundaries. The site-wide EA acknowledged that fina l designs and locations of some proposed or conceptual projects or facilities at the complex were uncertain and that various configur ations were possible. The sitewide EA was prepared as a “bounding” analysis that would allow for future flexibility in implementing a range of potential activities. The bounding approach was used to evaluate potential environmental impacts resulting from an array of potential development options within a conceptually defined “ buildout” scenario. The assessment considered a range of future s ite use and development options through 2008. In July 2003, DOE determined that the proposed or contemplated improvements assessed in the site-wide EA did not either individually or collectivel y constitute a major federal action significantly affecting the human environment within the meaning of NEPA.

The site-wide EA analyzed impacts that would occur if site development occurred in areas that DOE believed would minimize the overall e nvironmental impacts associated with sustainable site development. Moreover, it identified areas that should be set aside and preserved in a natural or existing state. Each of the three proposed projects that are the topic of this EA would occur in areas that were analyzed in the site-wide EA. DOE concluded that development in these areas would not constitute a major federal action significantly affecting the quality of the human environment.

The site-wide EA provides the analytical structure to assess the potential environmental impacts of the specific Proposed Action that is the topic of this EA. While DOE is also considering several other site development projects at this time, based on the availa bility of funds and project-specific schedules, those projects are not ripe for NEPA review at th is time and are not evaluated in this EA.

The site-wide EA is incorporated in its entirety into this EA by reference, a nd this EA tiers off the descriptions of the affected environment and the pot ential environmental impact assessments presented in the site-wide EA. The site-wide EA is available at http://www.eere.energy.gov/golden/NREL_STM.aspx.. Within the framework of the site-wide EA, this EA assesses the impacts of implementing the following three proposed projects at the STM site:

• a Renewable Fuel Heating Plant (RFHP);

• a range of solar-generating installations a dvanced by the Solar Technology Advancement Consortium (SOTAC). SOTAC activities to be conduc ted at NREL are hereafter referred to as the SolarTAC Project. The proposed SolarTAC activities at the NREL site are the only SOTAC activities assessed in this EA; and

• a Mesa Top Photovoltaic Project (MTPP).

Purpose of the Proposed Projects

Collectively, the proposed projects would substan tially reduce NREL’s use of natural gas and gridprovided electricity, while simultane ously advancing and contributing to commercialization of renewable energy technologies. Solar Technology Advancement Consortium (SOTAC) SOTAC is a collaboration among DOE, utilities, and universities. The goal of the consortium is to provide research, education, and demonstration opportunities toaccelerate the deployment of precommercial and early commercial solar energy technologies to the marketplace.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

6 Renewable Fuel Heating Plant . The proposed RFHP would reduce NREL’s current STM site natural gas consumption by an estimated 75 to 80 percent an d also provide some measure of insulation from the volatility of natural gas prices. The project would also showcase the viability of woodwaste biomass fuels as an alternative to fossil fuel heating.

SolarTAC Project . The SolarTAC Project would accelerate the introduction and recognition of precommercial and early-commercial solar energy techno logies in the U.S. marketplace. It would support and promote the commercial acceptance of solar energy technologies. The SolarTAC Project would provide a launch pad for commercialization of sola r-generating technologies in Colorado and elsewhere, such that solar technologies would become an in creasingly important and ultimately indispensable contributor to the energy use profile in the United States and across the world.

Mesa Top Photovoltaic Project . The proposed MTPP would generate about 1.0 megawatt (MW) of solar electric energy to offset NREL’s growing energy demand. This is consistent with DOE’s long-term site development plans and energy goals to increase on-s ite renewable energy generation at the laboratory

1.4 Scoping

On November 13, 2006, DOE posted a Request for P ublic and Agency Comments on the Proposed RFHP to the DOE Golden Field Office electronic readi ng room. The announcement invited comments through January 5, 2007, and indicated that no formal pub lic scoping meeting was planned for this project.

On April 2, 2007, DOE posted a Request for Public and Agency Comments on the three projects that are the subject of this EA to the DOE Golden Fiel d Office electronic reading room. This announcement indicated that no formal public scoping meeting was planned for these projects. A copy of this scoping letter is provided in Appendix A. DOE also mailed the scoping letter to the business, agencies, and organizations shown in Appendix B and to all kn own addresses in a nearby residential area called Pleasant View; the Pleasant View residential mailing list consisted of 1,470 addresses. DOE received three comments on the scope of the EA from fede ral and state agencies, which are included in Appendix C.

1.5 Comments on the Draft EA

On June 1, 2007, DOE posted a notice stating that th e draft EA was available electronically on its website and in hard copy if requested. DOE also mailed notices of availability to the same individuals and organizations listed in Appendix B that received the scoping letter. The notice invited readers to comment on the analyses provided in the draft EA.

DOE received three comment letters on the draft EA and has considered all comments in finalizing this EA. A summary of comments and DOE’s responses is provided in Appendix D. The comment letters necessitated only a few minor clarifications in the text and the addition of a new figure (Figure 2-2) that provides detailed location information for the RFHP.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

7 2.0 PROPOSED ACTION AND ALTERNATIVES

Figure 2-1 illustrates the STM and the relative locati ons of the three proposed projects on the site, and Figure 2-2 provides a more detailed layout of the RFHP.

2.1 Renewable Fuel Heating Plant

The RFHP would be installed in a new building a pproximately 21 meters ( 70 feet) long, 11 meters (35 feet) wide, and 9 meters (30 feet) high. The fo otprint would be approxima tely 185 to 230 square meters (2,000 to 2,500 square feet) in the area be hind (north of) the FTLB. The proposed RFHP would be constructed at the edge of a natural drainage that provides habitat and corridor passage for wildlife and intermittently supports lush vegeta tion. Construction is projected to take 6 to 7 months. NREL policy stipulates that construction debris is to be recycled to the fullest extent possible in order to minimize impacts to local landfills.

The building would have two levels. The ground floo r would be at the existing service drive. A wood combustor, cyclone, hot water pumps, fuel processing equipment, fuel area, and ash hopper would be located on the ground floor. A boiler, expansion tank, truck access, and control room would be located on the mezzanine level of the buildi ng. If necessary, an enclosed walk could be installed from the FTLB mechanical room door to the new building to al low for easier access. The project would include installation of hot water distribution lines interconnec ting the new facility to the Solar Energy Research Facility (SERF) central plant and the FTLB central plant. Detailed physical descriptions, illustrations, operating parameters, and economics of the proposed plant are provided in the Final Proposal, Renewable Fuel Heating Facility, National Renewable Energy Laboratory, Colorado ( Ameresco, 2007) and in the On-site Impact Assessment of Proposed Rene wable Fuel Heating Plant, Ameresco, NREL, Golden Colorado (Trinity Consultants, 2006), both of which are incorporated into this EA by reference.

A fuel storage area would be designed to store approximately 160 cubic meters (215 cubic yards) (equivalent to 4 to 7 days’ worth) of woodwaste. A railed walkway would be inst alled on one side of the area to allow for access to the fuel st orage pit. Motors and augers would be accessible on the other side of the fuel area to minimize unnecessary entry to the pit.

Fuel would be delivered at the building’s east side , where a large overhead door would allow trucks to back into the fuel storage area. A concrete stru cture would prevent trucks from encroaching on the building footprint. The door would open via an electr onic keypad system to limit entrance to authorized site personnel. A man door would also be located on the east side of the building to allow access to the control room when necessary. This door would be locked to limit unauthorized or unnecessary access.

The building would be constructed of architectural concrete block. It would be finished with a moisture barrier and exterior insulation. The finish would be similar to the FTLB finish. The roof of the building would be a single-ply flat construction. The building would be insulated to meet American Society of Heating, Refrigerating and Air-C onditioning Engineers standards. A stack would extend 3 meters (10 feet) above the roof and would be approxima tely 56 centimeters (22 in ches) in diameter.

In addition to the new building, a driveway would be installed for trucks to access the building, requiring the extension of an existing culvert by 17 to 20 linear meters (55 to 65 linear feet) using 3.6-meter (12-foot) by 1.2-meter (4-foot) concrete block (Figur e 2-2).The proposed RFHP would be constructed at the edge of a natural drainage area that provi des habitat and corridor passage for wildlife and intermittently supports lush vegetation. DOE may decide to install a turnaround area to facilitate delivery truck traffic flow.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

10 However, the decision to install a turnaround area and th e relative size, if one were installed, has not yet been finalized. As shown on Figure 2-2, if a turnarou nd area were built, it would be a small extension of the sides of the existing road. A wing wall would be installed at the end of the culvert to prevent flooding into the building’s ground floor. Approximately 1,65 0 meters (1,800 yards) of asphalt would be poured over the culvert for the driveway and the turnaround area. The area over the culvert would be regraded with 1.5 meters (5 feet) of fill for proper site drainage.

The RFHP would operate as the primary winter heat source to NREL’s research and support facilities. Heating is currently supplied by natural-gas-fired bo ilers, and these boilers would remain available to supplement or replace RFHP demand as necessary. Fuel would consist of Rocky Mountain Front Range woodwaste such as construction waste, urban tree trimmings, pallets, and forest thinnings.

Equipment Description, Operation, and Specifications

The Challenger Combustion System TM proposed for use in the RFHP is designed specifically for the combustion of solid waste fuels to optimize energy recovery and minimize air emissions. The primary combustion zone would be lined with high-insulating cast refractory ceramics to minimize heat transfer to the unit exterior.

Woodwaste combustion would begin by directing three levels of air into the combustion zone. Primary air would be forced into the combustion zone from be neath the grates, where the fuel would be placed. Secondary air would be forced through side grates. Tertiary air would enter through the cast refractory located on the sides of the unit to prevent unburned fuel from exiting the unit.

A secondary ceramic chamber operating at 900 degrees Celsius (°C) (1,650 degrees Fahrenheit [°F]) would be included between the primary combustion zone and the boiler to allow for an extended combustion zone with a 1.3-second retention time. This design would reduce carbon monoxide (CO) and volatile carbon emissions by more than 70 percent. The appropriate combustion temperature would be maintained by adjusting fuel feed, fan speed, and air intake.

Once the fuel was combusted, the stack gas would be transitioned into a hot-water boiler. The boiler would be capable of producing up to 9 to 10 milli on British thermal units per hour of 30 pounds per square inch gauge hot water, or approximately 2,80 0 liters (750 gallons) per minute. Downstream of the boiler, exhaust gas would be directed through a mu lti-cyclone particulate separator. The exhaust gas would then pass through an insulated, single-skin flue and be vented to the atmosphere.

The combustor would be designed as a dual-fuel unit and could be operated on natural gas if woodwastes were unavailable. In the event that heating loads in excess of the RFHP output were required, or during down-time due to scheduled or unscheduled maintena nce, the existing natural gas boilers would be brought on-line as needed to meet heating load demands. Natural gas would be utilized in the RHFP combustor during start-up, during shut-down, and during periods when the heating load dropped too low for woodwaste combustion.

Pollution control equipment would consist of a multi- cyclone to control particulate matter. The multicyclone would have a design capacity of 10,376 cubi c feet per minute at 149°C (300°F). The combustion unit and associated equipment would be monitored and adjusted to maintain op timal efficiency of the pollution control equipment.

The multi-cyclone would be operated and mainta ined in accordance with the manufacturer’s recommendations and incorporated into NREL’s main tenance procedures. This would include periodicFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

11 measurement of the system pressure drop, tube cleaning, and visual inspections for plugging, holes, spinner damage, and unusual wear patterns.

Woodwaste fuel would be procured from commercial Front Range sources. Woodwaste acceptance criteria would be developed to ensure that contam inants and undesirable components were not combusted in the RFHP. At a minimum, woodwastes containing chem ically treated, stained, painted, laminated, or otherwise altered wood products w ould be prohibited. Current plans call for approximately 160 cubic meters (215 cubic yards) of on-site fuel storage (appr oximately 59 metric tons [65 tons]). Fuel would be delivered three to five times per week at approxima tely 23 metric tons (25 tons) per load during the heating season. Total annual fuel consumption is estim ated to be 2,722 metric tons (3,000 tons).

The major RFHP components would have an estimated 10- to 30-year lifetime. At the end of its useful lifetime, the RFHP would be decommissioned, removed, and disposed of as solid waste or recycled in a manner consistent with NREL’s facilities management a nd waste management policies applicable at that time. Alternatively, equipment could be refurbishe d or replaced, as necessary, to continue with RFHP operation.

2.2 SolarTAC Project

The SolarTAC center would be located primarily ou tdoors. It would be constructed on approximately 0.8 hectare (2 acres) of land east of a natural drainage that lies northeast of the NREL Visitors Center. This area lies outside the site security area and would be provided by DOE through an agreement with the SOTAC.

Although buildout plans are not final, construction at the 0.8-hectare (2-acre) is estimated to take approximately 6 months. The site w ould be graded over a several-week period, concrete pads would be poured to support solar panels, a foundation would be poured for a solar demonstration house, and gravel or road base material would be installed for a walkway and access road. Management practices such as water spraying for dust suppression and storm wate r pollution prevention measures to minimize runoff would be identified and implem ented during construction.

The SolarTAC center would showcase and test variou s solar energy generation, use, control, and communications equipment. The area would include r esidential photovoltaic (PV) systems, utility PV systems not requiring special safety precautions, stand-alone PV systems (e.g., bus-stop shelters, remote lighting), and similar systems. Solar arrays and co mmunications equipment would be installed on various rooftops at NREL and at other locations not accessible to SolarTAC visitors. DOE expects that initial system sizes would range from 1 to 50 kilowatts.

Plans include a small solar demonstration house of approximately 170 to 230 square meters (1,800 to 2,500 square feet) showing efficient insulation; a working PV system with inverter, batteries, and appliances; and information displays. A fenced-o ff area would control access to sensitive research equipment or equipment that could pose a hazard without proper training on its correct use.

A 3.6-meter (12-foot) wide contractor access and service drive terminating at a 30-meter (100-foot)- diameter turnaround area would be constructed immediat ely east of the proposed main SolarTAC facility arrays. This new driveway would cross a natural drainageway. The vehicle bridge would be strong enough to handle a fully loaded cement truck. Th e access would mainly be for the Fire Department, maintenance staff, and other service personnel. The driveway would be chained off to preclude people from using it for everyday access to the site.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

12 A new pedestrian footbridge connecting the main Sola rTAC displays to the NREL Visitors Center would also cross the natural drainageway. The footbridge would most likely be pre-engineered and constructed out of Corten steel, which gains strength as it oxidizes. The bridge would continuously gain a rusty patina as it aged, which would help the bridge ble nd more naturally with the environment.

Ultimately, the proposed SolarTAC could include co nstruction of a new 54-space parking lot in the median area located south of the existing 39-sp ace NREL Visitors Center parking lot. However, construction of this new parking area may be included in initial SolarTAC construction to alleviate the shortage of available parking.

2.3 Mesa Top Photovoltaic Project

The MTPP would be designed to generate approximately 1.0 MW of solar energy to be used on-site by DOE. The MTPP may be installed and operated by a contractor. If the project were contracted out, the anticipated length of the contract for operation of the system would be 20 years. If the equipment were still viable at the end of the 20-year period, it could continue to be used on-site.

If implemented, the system would probably be a “si ngle-axis design” and/or “fixed-tilt design”. For a single-axis design, dark-blue to black-colored panels would be installed parallel to the ground in a northsouth alignment and would rotate east (morning) to west (afternoon). The maximum allowable PV panel height would be 2.4 meters (8 feet) above the ground to minimize the visual impact of the PV system. If a fixed-tilt design were implemented, the number of pa nels would increase by about 15 percent, and the panels would be installed in rows running east-west and sloped to the south at approximately 40 degrees.

The proposed installation would be located on approxim ately 2 hectares (5 acres) of flat land north and east of the existing Solar Radiation Research Labor atory and Solar Furnace buildings. Buildout plans are not final; however, construction at the site is estimat ed to take approximately 6 months. Although the site is generally flat, grading could be necessary. Concrete pads would be poured to support solar panels, and possibly to support utility lines if poles were used. The MTPP would be enclosed by a fence similar to the existing fence, which is a 2-meter (6-foot) chain link fence with three strands of barbed wire on top.

Although there is an existing road to the site, it is likely that a new service drive would be needed within the 2-hectare (5-acre) site. The surface of the drive would be permeable material such as road base or gravel. Management practices such as water spra ying for dust suppression and storm water pollution prevention measures to minimize runoff would be id entified and implemented during construction. Once installation was complete, the need for human presence would be rare (probably one visit per week for a short inspection).

Interconnection would likely be thro ugh an existing, spare 13.2-kilovolt/480-volt three-phase transformer with a 1-MW capacity. This transformer is located in the middle of the proposed MTPP site, so minimal electrical infrastructure would be required between th e PV system and the transformer. The transformer ties into the NREL 13.2-kilovolt distribution system th at feeds all STM site loads. New interconnection cables would be installed either on the ground su rface, underground, or possibly on a limited number of new overhead utility poles and power lines.

Security lighting would be required. DOE NREL would in stall lighting similar to lights currently installed at DOE’s existing mesa-top facilities. To minimize impacts to dark skies at night, a motion sensor would be installed on each light, with the timer set at a relati vely short interval, such as the current interval of 5 minutes.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

13 Solar PV panels have useful lives of up to 30 years. Consequently, the panels currently in place at NREL and those that would be installed as part of the Prop osed Action would eventually be either removed and disposed of as waste or recycled. PV products ar e generally safe for landfills, because PV materials are usually encased in glass or plastic, and many are in soluble. Some modules, however, could be classified as hazardous waste, a situation that is prompting the PV industry to develop recycling processes for modules. Currently, most PV panels and cells collected from NREL research and testing are disposed of as hazardous waste due to arsenic, cadmium, or lead conten t (the lead is not present in the PV panel, but in the solder connecting the panel to an electrical junction box).

Because PV systems are widely dispersed, and b ecause each system has small amounts of semiconductor material per cell, recycling PV materials would be a challenging task. The PV industry’s effort to develop recycling processes is in response to this challenge. Because solar panel disposal is in its infancy, it is not possible to specify how or where the MTPP panels would ultimately be disposed of or recycled.

2.4 No Action Alternative

Under the No Action Alternative, the three proposed projects would not be implemented and the STM would remain in its current configuration. The No Action Alternative would not preclude other projects addressed or contemplated in the site-wide EA fro m being proposed at such time as NREL determined them to be ripe for NEPA action.

2.5 Alternatives Considered But Not Analyzed

DOE considered alternative locations for each of the projects that make up the Proposed Action. In general, these alternative locations were not furthe r analyzed because the proposed locations evaluated in this EA were found to be the most consistent with the overall buildout vision articulated in the site-wide EA.

The proposed location for the MTPP would be much clo ser to the road, the spar e transformer, and the existing utility lines than alternative locations, thereb y keeping the need for new support infrastructure to a minimum. An alternative location for MTPP north east of a new Science and Technology Facility (S&TF) was not further evaluated due to the smaller available area and the possibility of future shading from buildings that might be built to the south. An a lternative location for the RFHP north of the roadway was considered. However, the proposed location for the RFHP was considered better because it is closer to the FTLB and SERF. Alternative locations were al so considered for the SolarTAC Project; however, because those locations had competing proposed uses a nd because they were all behind the security fence, they were not considered further.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

14 3.0 EXISTING ENVIRONMENT AND ENVIRONMENTAL IMPACTS

General Site Description

The 132-hectare (327-acre) STM site is located on the s outheast side of STM, north of Interstate 70 (I-70) and west of the I-70 and Denver West Boulevard in terchange in unincorporat ed Jefferson County near Golden, Colorado. The DWOP is located in the city of Lakewood. The areas surrounding the STM and DWOP sites are within portions of unincorporated Jefferson County, as well as the Cities of Golden and Lakewood in Jefferson County. The Pleasant View Me tropolitan District, within unincorporated Jefferson County, overlies portions of each of these jurisdictions . These jurisdictions are described and illustrated in detail in the site-wide EA (DOE, 2003).

Of the 132 hectares (327 acres) at the STM site, 55 he ctares (136 acres) are available for development. A total of 72 hectares (177 acres) is protected by a conservation easement, and development on 5.7 hectares (14 acres) is restricted by utility easeme nts. There are currently seven laboratory facilities, a few small test facilities, and several support buildings on the site. The site includes acreage on the STM mesa top, slope, and toe and was formerly part of the Colorado National Guard facility, established between 1903 and 1924, at Camp George West. Figure 2-1 illustrates the STM site and the locations of the three proposed improvement projects that are the subject of this EA.

The following descriptions of the existing environmen t and potential environmental impacts tier off and generally follow the structure of the site-wid e EA (DOE, 2003). The descriptions of the existing environment in this EA summarize the descriptions found in the site-wide EA when they remain current; otherwise, this EA describes relevant changes sin ce the site-wide EA was issued. Many of the impacts expected from the three development projects proposed in this EA are bounded by the impacts reported in the site-wide EA. In cases where impacts from any of the three development projects are not bounded by the site-wide EA (for example, air quality impacts from RFHP emissions), more detailed discussions are provided.

3.1 Environmental Impacts of the Proposed Action

3.1.1 Land Use, Planning, Socioeconomics, and Public Policy

3.1.1.1 Existing Environment

The descriptions of land use, planning, socioeconom ics, and public policy found in the site-wide EA remain current and are summarized below.

Current land use at the site includes research and development facilities, office space, support buildings, and testing areas. The STM complex (including th e DWOP space that is leased to DOE) provides 48,000 square meters (516,000 square feet) of facilities and workspace for approximately 1,200 workers (employees, temporary personnel, and contract workers).

A 72-hectare (177-acre) conservation easement was es tablished in 1999 in ex change for 10 hectares (25 acres) of developable land that is included in th e 55 developable hectares (136 developable acres) on the southernmost portion of the site. Jefferson C ounty is designated as the “beneficiary” of this conservation easement. The goals of the conservation easement are to:

• Retain, preserve, and protect natural, scenic, ecological, and historical aspects of the conservation easement property;Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

15 • Protect the ecosystem of the STM area and the sustainable habitat for biodiverse vegetation, birds, and terrestrial animals;

• Ensure the scenic and biological integr ation with adjoining open-space land;

• Prevent further industrial, commercial, or resi dential development of the conservation easement property; and

• Preserve the conservation easement property as natural open space.

As described in the site-wide EA, DOE has establishe d seven zones on the STM site for the management of ongoing and future site land use and development. The zones are illustrated in Figure 3-1.

The RFHP would be located in Zone 4, the NREL Central Campus. This 22-hectare (55-acre) zone includes major DOE facilities such as SERF, FTLB, and the recently completed two-story, approximately 6,600-square-meter (71,000-square-f oot) S&TF. It also includes wet laboratories and space for research such as experiments with hydrogen, toxic gases, PV, biofuels, and industrial technology. This portion of the site is considered suitable for project demonstration and is considered the center of the STM complex. The proposed SolarTAC Project would be constructed pa rtly in Zone 4 and partly in Zone 5, which is designated as an area where general research, development, demonstra tion, and support facilities could be located. The MTPP would be located in Zone 1, the top of the Mesa Buildable Area. This 5.3-hectare (13-acre) zone includes land designated for specia lized research such as solar collection and solar radiation. Additional facilities, if any, would be of minimal size, low occupancy, and designed for minimal disruption to views of the mesa. There are approximately 42 hectares (105 acres) of mesa-top land within the STM site. Approximately 37 hect ares (92 acres) of mesa-top land are within the conservation easement area, leaving 5 hectares (13 acres) of mesa-top land available for development.

The mesa top is subject to various local govern ment policies and agreements intended to limit development. Previous plans to develop these are as for non-DOE activities have met substantial public criticism, have generated broad comm unity controversy, and/or have been denied by local government. As a federal agency, DOE is generally exempt from local government regulation; however, DOE is sensitive to local community and state concerns. It is DOE’s intent to minimize its developments on the mesa top, while still fulfilling its mission of research, development, and technology transfer of renewable energy and energy efficiency technologies.

3.1.1.2 Impacts of the Proposed Action

The land use, planning, socioeconomics, and public policy impacts of the three proposed site development projects are bounded by the discussion of impacts presented in the site-wide EA (DOE, 2003) and are summarized below.

Renewable Fuel Heating Plant

The proposed RFHP would be a de-facto, free-standi ng annex to the existing FTLB and SERF physical plants. It would be situated near the center of th e NREL Development Zone 4 (Central Campus), where it would be generally consistent w ith and compatible with the current land use pattern and ongoing NREL operations. Its construction would convert approximately 0.2 hectare (0.5 acre) of undeveloped hillside and drainageway land between the FTLB and the SERF to site infrastructure use. The RFHP would be built adjacent to the FTLB. The majo r land use issues at the STM (exclusive of mesa-top issues)Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

17 primarily relate to development in close proximity to residential areas located south of Zone 3 (West Campus); residential areas east and west of Zone 6; a planned park located south of Zone 6; and the Camden Denver West condominiums located east of Zone 5. The proposed RFHP would not impact land use in these areas.

SolarTAC Project

The proposed SolarTAC Project would be built in NR EL Development Zone 5 (East Campus), with some overlap into Zone 4, an area that is undeveloped ex cept for the NREL Visitors Center and east entrance. However, Zone 5 is designated as an area where general research, developm ent, demonstration, and support facilities could be located. The new inst allations would allow for increased research, development, and demonstration activities that would be consistent with exis ting and planned uses of NREL Development Zones 4 and 5. The major land use issues at the STM (exclusive of mesa-top issues) primarily relate to development in close proximity to residential areas located south of Zone 3 (West Campus); residential areas east and west of Zone 6; a planned park located south of Zone 6; and the Camden Denver West condominiums located east of Zone 5. SolarTAC would not impact land use in these sensitive areas.

Mesa Top Photovoltaic Project

The proposed MTPP would be located adjacent to the existing Solar Radiation Research Laboratory. It would convert approximately 2 hectares (5 acres) of open, undeveloped mesa-top land to a restricted access area used for the commercial generation of so lar energy. Development of mesa-top areas for nonDOE purposes is discouraged by local government policy and has been the subject of community controversy. However, controversies over previous commercial proposals to develop portions of the mesa top for activities not related to DOE operations were in part the basis for the land transfer that resulted in the formation of the approximately 72-hectare (177-acr e) Zone 2 conservation area and the decision to prevent development in Zone 7 (Non-contiguous Historic Resource Areas). For these reasons, and because the only new development proposed on the 5 hectares (13 acres) of Zone 1 is the MTPP, the land use impact on the mesa top would not be major. All of the areas that would be developed for the MTPP are areas that were agreed could be developed when the conservation easement was established in 1999.

The site-wide EA determined that development within the bounding cond itions of the EA would have no direct impacts on minority populations because no off-site human health or environmental effects of the Proposed Action were anticipated, and because no concentrations of minority populations were located in the vicinity of the site. The site-wide EA also de termined that the Proposed Action would have positive direct and indirect economic impacts because it would create jobs and involve substantial construction expenditures. The socioeconomic, environmental justice, policy, and planning impacts of the three development projects that are the subject of this EA are bounded by the impacts described in the site-wide EA.

3.1.2 Traffic and Circulation

3.1.2.1 Existing Environment

The description of existing traffic and circulation at the STM complex reported in the site-wide EA was based on consultation with local governments and th e information and findings presented in a traffic impact study prepared by Felsburg Holt & Ullevig for the STM site in November of 2002 (NREL, 2002a). Recently, Felsburg Holt & Ullevig have prepared a draft update of the 2002 traffic impact studyFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

18 (NREL, 2007a). Both the 2002 traffic impact study and the 2007 update are incorporated into this EA by reference and are summarized below.

Using methods documented in the Highway Capacity Manual (TRB, 2000), existing peak-hour traffic volumes were analyzed to determine existing operational conditions. The Highway Capacity Manual describes traffic operational conditions with a level of service (LOS), a qualitative measure based on the average delay per vehicle at a controlled intersection. LOSs are described by a letter designation of either A, B, C, D, E or F. A LOS “A” represents conditions with minimal delay, while a LOS “F” represents conditions with much longer delays . Typically, a LOS “D” or better is considered to be acceptable. The results of the analyses indicated that all of the study intersections currently operate at acceptable levels of service ranging from LOS A to LOS C during the peak hours.

3.1.2.2 Impacts of the Proposed Action

Renewable Fuel Heating Plant

During RFHP construction, there would be a temporary increase in vehicles and increased demand for limited on-site parking to accommodate the construc tion workforce, which DOE estimates would be 2 to 3 dozen workers for 6 to 7 months. Construction-relate d traffic impacts are anticipated to be similar in nature to, although less severe than, those recently ex perienced at the site during construction of the S&TF. Temporary disruptions of on-site traffic fl ows and access could occur. DOE does not anticipate that construction of the RFHP would im pact off-site traffic or parking.

Operationally, there would be no traffic impacts because no additional personnel would be hired to operate the RFHP; the existing boiler plant operators would operate the RFHP as part of their work responsibilities. Currently, about 30 trucks per week enter the site for various deliveries. Delivery of woodwaste fuel and pick-up of ash would require th ree to five new truck trips per week during the October through May operating season. This would not represent a major increase over the current on-site truck traffic. However, the 27- to 31-metric ton (30- to 35-ton) capacity trucks that would be used to deliver approximately 23 metric tons (25 tons) of biomass per trip would be large. The trucks would unload directly into an interior pit within the RFHP structure. Truck deliveries would be arranged to be made Monday through Friday. The large delivery trucks could have difficulty negotiating on-site roads, especially when accumulated snow further constricted the roads. DOE is considering a turnaround area to expedite woodwaste deliveries at the RFHP. Installa tion of a large turnaround area would minimize any traffic impact such deliveries would have on on-s ite traffic flow. If no turnaround were installed, woodwaste deliveries could temporarily impede on-site traffic flow.

SolarTAC Project

Construction of SolarTAC would result in a short-te rm increase in on-site traffic caused by commuting construction workers. In the long term, DOE estim ates that the SolarTAC Project could attract approximately 500 visitors per mont h. This could be in addition to the approximately 1,500 individual who currently visit the NREL Visitors Center each m onth. In a later phase of its implementation, the proposed SolarTAC would include construction of a new 54-space parking lot in the median area located south of the existing 39-space NREL Visitors Center parking lot. However, unless and until construction of the new parking area lot was complete, the increase d number of visitors woul d probably result in the existing parking area often being filled to capacity. Some visitors might have to park off-site, then walk up the road to reach the Visitors Center or the Sola rTAC. In areas where sidewalks are lacking, this could pose a safety risk to pedestrians. Depending on traffic and the distance to the nearest parking, the use of a shuttle bus to transport vi sitors may be required.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

19 Mesa Top Photovoltaic Project

Construction of the MTPP would result in a short-te rm increase in on-site traffic caused by commuting construction workers. In the long term, there would be a slight increase in traffic at the mesa top due to the need for weekly inspections and system maintenance.

3.1.3 Air Quality

3.1.3.1 Existing Environment

Detailed descriptions of the existing air quality at the STM are provided in the site-wide EA. These descriptions address climate (Section 3.3.1), air qualit y regulatory authorities (Section 3.3.2), emissions sources (Section 3.3.3), and STM site permit status (Section 3.3.4). They remain current and are summarized or updated below.

Air Quality

National Ambient Air Quality Standards (NAAQS) set th e absolute upper limits for specific air pollutant concentrations in order to protect human health. Th ese pollutants are called criteria pollutants and consist of CO, nitrogen oxides (NO X ), sulfur dioxide (SO 2 ), ozone, particulate matter less than 10 microns (PM 10 ), lead, and volatile organic compounds (VOCs). A geographic area that meets or exceeds the limit for a particular criteria pollutant is called a nona ttainment area. Areas where pollutants are measured below the limits are called attainment areas. The De nver metropolitan area was in attainment for all criteria pollutants as of April 2007

. An air emissions inventory dated Ju ly 2001 indicates that the STM site lists numerous stationary sources of air emissions. The sources consist of boilers, water heaters, back-up generators, building heaters, and a thermochemical process development unit (or therma l oxidizer) used for research activities. Emissions from the 2001 inventory are listed in Table 3-1. These emissions are reasonable estimates of current sitewide emissions at the STM because no major additiona l emitting sources have been added since the sitewide EA.

With respect to hazardous air pollutants, the STM s ite emits extremely small quantities of materials from laboratory hoods. Examples of the source of these ha zardous air pollutants include acetone, cyclohexane, toluene, xylene, phosphoric acid, and sulfuric acid. The emission quantities are well below notification and permit thresholds. Fugitive dust is also emitted from the STM and DWOP sites in the form of unplanned emissions that escape from a process by a r oute other than a stack, chimney, or vent. These emissions are minor. Another source of fugitive dust is windblown soil. Construction activities at the STM site have the potential to increase fugitive dust levels by disturbing soil

.

Table 3-1. Estimated Annual Emissions at the STM Site, 2001

Particulates SO 2 NOx CO TOC Type of Air Emission Tons per Year
Potential Emissions 2.86 5.18 46.41 23.21 3.63
Estimated Emissions 0.39 0.13 5.33 3.87 0.55 TOC = total organic carbon. Source: NREL, 2001.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

20 For State of Colorado permitting requirements, a major st ationary source is one that has the potential to emit, when operated at maximum load for 8,760 hour s per year, more than 100 tons per year of any criteria pollutant, or more than 5 tons per year of any hazardous air pollutant. NREL is not a major source, and the major source permitting requirements do not apply

. Operating permits may be issued for sources with thresholds under 100 tons per year; these are call ed minor sources. NREL currently is not required to obtain a minor source operating permit.

3.1.3.2 Impacts of the Proposed Action

RFHP Air Quality Impacts

The proposed RFHP would result in emissions of the following criteria air pollutants: PM 10 , NO X , sulfur oxides, CO, and VOCs.

The RFHP would also emit both organic and trace elem ent toxic air pollutants (TAPs). In addition, the two to five woodwaste delivery trucks per week a nd one ash removal truck per month during the RFHP operating season would result in a small incremental in crease in vehicle exhaust emissions at the STM site compared to existing emissions.

A dispersion modeling analysis of the proposed RFHP emissions was conducted in 2006 (Trinity Consultants, 2006). The analysis was based on av ailable emission factors provided by the U.S. Environmental Protection Agency (EPA) and vendor control data and is incorporated into this EA by reference. The screening dispersion modeling an alysis was conducted in accordance with EPA’s Guideline on Air Quality Models (40 CFR 51, Appendix W) and Screening Procedures for Estimating the Air Quality Impact of Stationary Sources, Revised. The modeling analysis used 22 receptors located at the S&TF, the SERF, and the FTLB at distances ranging from 13 to 274 meters (42 to 900 feet) from the RFHP emission source. TAP emissions were qua ntified using emission factors from AP-42 for uncontrolled wood combustion. Although the increased residence time from the secondary combustion chamber would destroy most of the organic emissions , and the multi-cyclone would capture some of the TAP emissions, no control was assumed in the anal ysis. Consequently, the analysis conservatively overestimates the TAP emissions.

DOE filed an Air Pollution Emission Notice and permit application package for the proposed RFHP with the Colorado Department of Public Health and Environment (CDPHE) on March 16, 2007 (NREL, 2007b). In response, CDPHE has issued an initial approval for construction of the proposed RFHP as a minor source at a minor facility. The initial approval, shown in Appendix E, lists all applicable air permitting requirements for construction of the pro posed RFHP and conditions that must be met for operation.

As shown in Table 3-2, the predicted RFHP crite ria air pollutant emissions would not exceed NAAQS.

The dispersion modeling analysis indicated that emissions of TAPs from the RFHP would not pose a health risk based on the American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) and the National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limits (RELs). Specifically, the analysis of emissions from the RFHP as shown in Table 3-3 demonstrates that the quantities of pollutants emitted would all be below, and most would be several orders of magnitude below, the 8-hour hea lth-based standards. Therefore, there would be no impacts to the health of either on-site workers or the off-site public from RFHP emissions

.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

21 Table 3-2. Predicted Emissions Compared to NAAQS

Pollutant Averaging Period RFHP Emissions a ( μ g/m 3 ) NAAQS b ( μ g/m 3 ) NO 2 Annual 39 100 Annual 4 80 24-hour 22 365 SO 2

3-hour 50 1300 Annual 26 50 PM 10 24-hour 129 150 8-hour 280 10,000 CO 1-hour 100 40,000 a. Source: Trinity Consultants, 2006. b. Source: CFR, Title 40, Part 50.
Note: μ g/m 3 = micrograms per cubic meter.

Odor information provided by the vendor (Ameresco , 2007) indicates that noticeable levels of odors would be present during start-up and shut-down, corr esponding to periods when the operating temperature is anticipated to be below 315oC (600oF) to 371oC (700oF). However, odors would be minimized by the planned firing of the equipment with natural gas durin g those periods in order to quickly bring the unit up to operating temperature, at which time there woul d be no discernible odor. If for any reason natural gas were not available during start-up and shut down peri ods, odors could be noticeable for 40 to 60 minutes. The woodwaste fuel supply would be contained in an enclosed building with an auger live-bottom delivery system. This design would prevent the woodwaste from sitting dormant and decomposing.

Opacity information provided by the equipment ma nufacturer indicates that exhaust gases exiting the stack would not result in a visible plume at temperatures of 371oC (700oF) and above. It is anticipated that opacity would be less than 5 percent. Data coll ected by the manufacturer on a similar but smaller combustion unit indicated opacity at less than 2 per cent. Opacity impacts would be minimized by firing the equipment with natural gas and quickly heati ng the system above 371oC (700oF). If for any reason natural gas were not available during start-up and sh ut down periods, opacity impacts could occur for 40 to 60 minutes.

Comparison of Greenhouse Gas Emissions

The current NREL heating plant uses natural gas; the RFHP would predominantly use a biomass fuel (woodwastes), with some continued use of natural gas during start-up and shut-downs and during periods of low demand. Both the existing natural-gas-fired plant and the RFHP would emit the greenhouse gas carbon dioxide (CO 2 ). The Third and Fourth Assessment Reports of the Intergovernmental Panel on Climate Change (IPCC, 2001; IPCC, 2007) provide an overview of the global effects of greenhouse gases that tend to warm the earth surface by absorbing some of the infrared radiation it emits.

“The principal anthropogenic [man-made] greenhouse gas is carbon dioxide (CO 2 ), whose concentration has increased by 31% since 1750 to a level which is likely to have not been exceeded fo r 20 million years. This increase is predominantly due to fossil fuel burning, but also to land-use change, especially deforestation. The other significant anthropogenic greenhouse gases are methane (CH 4 ) (151% increase since 1750, 1/3 of CO 2 ’s radiative forcing), halocarbons such as CFCs and their substitutes (100% anthropogenic, 1/4 of CO 2 ’s radiative forcing) and nitrous oxide (N 2 O) (17% increase since 1750, 1/10 of CO 2 ’s radiative forcing).”Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

22 Table 3-3. Comparison of Maximum Predicted Impact to Health-Based Standards

Pollutant RFHP Emission 8-Hr Average (μg/m 3 ) 8-Hr Health-Based Standard (μg/m 3 ) Would this Concentration Present a Health Hazard? (Yes/No) Carbon monoxide 280 40,000 No Sulfur dioxide 39 5,000 No Nitrogen oxide 340 30,000 No VOC 7.9 29,000 No Carbon dioxide 240,000 9,000,000 No Nitrous oxide 20 46,000 No Acetone 0.3 1,187,730 No Acetophenone 0.000005 49,141 No Acrolein 6.2 250 No Benzene 6.5 1,597 No bis(2-ethylhexyl) phthalate 0.000073 5,000 No Methyl bromide (bromomethane) 0.023 3,883 No 2-Butanone (MEK) 0.0084 589,829 No Carbon tetrachloride 0.07 31,456 No Chlorine 1.2 1,450 No Chlorobenzene 0.051 46,037 No Chloroform 0.044 48,826 No Chloromethane (methyl chloride) 0.036 103,247 No Crotonaldehyde 0.015 6,000 No 1,2-Dichloroethane 0.045 4,000 No Dichloromethane 0.45 173,681 No 1,2-Dichloropropane 0.051 350,000 No Ethylbenzene 0.048 434,233 No Formaldehyde 6.8 20 No Methane 33 656,033 No Naphthalene 0.15 52,429 No Pentachlorophenol 0.000008 500 No Phenol 0.079 19,245 No Styrene 3 85,202 No Tetrachloroethylene 0.059 169,564 No Toluene 1.4 188,446 No 1,1,1-Trichloroethane 0.048 1,900,000 No Trichloroethylene 0.047 268,689 No Vinyl Chloride 0.028 2,556 No o-Xylene 0.039 435,000 No Antimony 0.012 500 No Arsenic 0.034 10 No Barium 0.26 500 No Beryllium 0.0017 2 No Cadmium 0.0064 2 No Chromium 0.033 500 No Chromium (VI) 0.0054 50 No Cobalt 0.01 20 No Copper 0.14 200 No Lead 0.075 50 No Manganese 2.5 200 No Mercury 0.0054 25 No Molybdenum 0.0033 10,000 No Nickel 0.051 1,500 No Phosphorus 0.042 100 No Selenium 0.0044 200 No Silver 2.6 10 No Tin 0.036 2,000 No Yttrium 0.00047 1,000 No Source: Trinity Consultants, 2006.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

23 The IPCC (2007) attributes about three-quarters of the anthropogenic emissions of CO 2 to the atmosphere during the past 20 years to fossil fuel burning. The rest is attributed predominantly to land-use change, especially deforestation.

Table 3-4 shows that the proposed RFHP would emit more CO 2 , from an absolute quantity perspective, than is being currently emitted with natural gas firi ng. Therefore, a technical review of the available literature (Droppo and Yu, 2007) was prepared to ad dress (1) whether, despite an increase in absolute CO 2 emissions, the RFHP would be considered reaso nable and justifiable in terms of greenhouse gas emissions and climate change, and (2) how the pr oposed RFHP combustion process emissions would compare with other means of disposing of or using wood chips.

Table 3-4 compares emissions under the No Action Alternative (i.e., continued operation of the current natural gas heating plant), emissions from the propo sed RFHP, and emissions from open burning of an equivalent mass of wood.

While the available literature suggests that CO 2 emissions from the RFHP would be similar to those that would occur from open burning of wood, it also finds that the higher combustion temperatures and secondary combustion systems of the RFHP would not emit the greenhouse gas methane (CH 4 ). Furthermore, when compared to open burning, the pro posed plant would also be desirable in terms of the emission of other pollutants. The comparisons in Ta ble 3-4 indicate that open burning would significantly increase the emissions of CO, total particulate matter, and VOCs over the RFHP, all of which are criteria air pollutants.

In terms of net CO 2 in the atmosphere, the argument has been advanced, based on current scientific understanding on climate change processes, that burning wood chips is much more desirable than burning a fuel that contains carbon that has been sequestered underground. The CO 2 from wood chip combustion has a “net zero” emission rate based on factors in EPA’s AP-42 (EPA, 2007). The “net zero” emission

Table 3-4. Comparison of Emissions: Current Plant, Proposed Plant, and Open Burning

Proposed RFHP Emission Rate Computed for the Combustion of an Equivalent Mass of Wood

No Action (Natural

Gas) Total from Wood and Natural Gas Wood Portion Natural Gas Portion Rocky Mountain Wildfire ForestBurning AP42 Emission Factors (a) Forest WastesBurning AP42 Emission Factors (b) Sundance Fire Emission Factors from

Ward and Hardy (1991) Modeled Emissions from

Eight Major California Forest Fires (Clinton et al., 2006) Emission

Gas

Tons per Year CO 2.06 1.93 1.40 0. 53 270 176-380 590 340 - 381 SO 2 0.015 0.586 0.583 0.004 No t listed Not listed Not listed 3.3 -3.6 NO x2.45 5.75 5.13 0.63 7. 9 Not listed 27 10 - 12 PM 0.186 5.17 5.13 0.048 33 7.8 – 33 74 Not listed PM 10 0.047 4.67 4.66 0.012 Not listed Not listed Not listed 35 - 39 VOC 0.135 0.074 0.040 0.035 47 7.8 - 37 Not listed 24 - 25 CO 2 2,941 5,297 4,544 753 Not listed Not listed 6,030 4,450 – 4,910 CH 4 (c) (c) (c) (c) Not listed Not listed 2.5 - 6.4 14 - 15 a. Estimated based on Rocky Mountain wildfire forest burning emission factors (AP-42, Table 13.1-3) [EPA, 2007]. b. Estimated based on forest wastes burning emissi on factors (AP-42, Tabl e 2.5-5) [EPA, 2007]. c. No value listed; expected to be negligible.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

24 rate is based on an assumption that CO 2 from burning wood from forests represents no increase in the net amount of CO 2 in the atmosphere. A cycling of carbon between the atmosphere and forests results in no net gain or loss of airborne CO 2 . On the other hand, CO 2 from burning natural gas represents an increase in the net amount of atmospheric CO 2 from the introduction of “new” carbon that has been sequestered underground for millennia or longer. Thus, the prim ary argument supporting the proposed RFHP is to reduce the introduction of new carbon into the current atmospheric carbon cycle.

It should be noted, however, that based on a recent Supreme Court ruling, the EPA’s decision basis for not regulating CO 2 and other greenhouse gases may change [ Massachusetts v. U.S. Environmental Protection Agency , 549 U.S. __ (2007) (slip opinion dated April 2, 2007)]. According to the ruling, EPA’s action not to regulate greenhouse gas emissions was “arbitrary, capricious, or otherwise not in accordance with law”. Under the ruling, EPA must re consider its decision and ground its reasons for action or inaction in the Clean Air Act statute. The ruling states that unless EPA can show that CO 2 is not involved in the global warming seen around the world, the EPA should regulate it. Given the timing of this decision and the fact that the ruling was made in the context of regulating greenhouse gases from new motor vehicles, at this time it is too speculative to estimate what actions EPA may take, or what regulations might be promulgated, that might affect the RFHP.

From the viewpoint of minimizing impacts on global climate change, the burning of wood chips also tends to be more desirable than the common alterative use of wood chips in composting activities and landfilling. Although there is great variability and uncertainty in the published emission rates, the gaseous emission from open burning, composting, and landfilli ng tend to have much larger emissions of greenhouse gases, and specifically larger fractions of gases such as methane and ammonia, than the proposed process for burning woodwastes. The published source terms for open burning show the RFHP option to be preferable from the viewpoint of having lower emissions. Of particular importance are mixes of combustion products from these activities. For exam ple, because methane is currently thought to be many times more effective for inducing climate changes than CO 2 , the potentially higher methane levels from open burning, composting, and landfilling make th ese activities less desirable from the viewpoint of minimizing the potential impact of greenhou se gas emissions (Droppo and Yu, 2007).

SolarTAC Air Quality Impacts

Construction of the SolarTAC may involve scraping and grading up to 0.8 hectare (2 acres) of land, which would result in intermittent fugitive dust emissions for up to 6 months. NREL’s standard procedures require that construction dust be controlled by spraying or other means to minimize on-site and off-site dust. There would also be short-term or intermittent vehicle emissions from construction, visitors, and routine maintenance visits. Operations at the proposed SolarTAC would not result in emissions of regulated air pollutants.

MTPP Air Quality Impacts

Construction of the MTPP may involve scraping and gr ading up to 2 hectares (5 acres) of land, which would result in intermittent fugitive dust emissions for up to 6 months. Dust would be controlled or reduced by spraying and other techniques. There w ould also be short-term or intermittent vehicle emissions from construction, visitors, and routine maintenance visits. Operations at the proposed MTPP would not result in emissions of regulated air pollutants.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

25 3.1.4 Visual Quality/Aesthetics

3.1.4.1 Existing Environment

With the exception of the recently constructed S&TF, the narrative d escriptions and figures illustrating the visual and aesthetic environment of the STM presen ted in the site-wide EA remain current and are summarized below. Figures 3-2 and 3-3 illustrate the overall visual environment at the STM complex in 2007.

The dominant visual characteristics of the existing STM site include the prominent slope and mesa top associated with STM; the DOE f acilities located on top of STM; and the SERF, FTLB, S&TF, and Visitors Center located at the toe of the slope. The STM site buildings are prominent against the landscape of STM. Other less prominent buildings occur at the western end of the site.

The STM site facilities are designed to reflect the labora tory activities related to modern energy concepts. Three of the larger buildings—the SERF, FTLB, and S&TF—are terraced and set against the south slope of STM. In addition to the buildings at the STM centr al campus, DOE has constructed a variety of solar testing and measurement structures such as the Hi gh Flux Solar Furnace, Solar Radiation Research Laboratory, and numerous PV panels situated throughout the site.

The facilities located on top of STM cover only a sm all proportion of the overall STM mesa top. The remainder of the mesa top is almost entirely undeveloped and is part of the conservation easement delineated by Zone 2. DOE’s solar furnace and the su rrounding buildings in Zone 1 are visible from offsite locations. A Colorado State Patrol driver training tr ack is also located on top of the mesa, but it is not visible from most off-site locations. Other natural areas on the mesa top are within designated Jefferson County open space areas or NREL’s on-site conservation area (Zone 2).

View looking northwest toward STM (telephoto).

Figure 3-2. View of the Visitors Center, SERF, and Mesa-Top FacilitiesFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

26 View from the 6 th Avenue frontage road (telephoto).

Figure 3-3. View of Mesa-Top Facilities, FTLB, and SERF

3.1.4.2 Impacts of the Proposed Action

The equipment and facilities that would be added to the STM site under the Proposed Action would not be unique to the site. The appearance of these facilities would in fact be similar to other buildings and PV panels that have been a part of the STM site fo r many years. As such, the addition of the RFHP, SolarTAC, and MTPP would not alter the current visu al character of the site. If the proposed facilities were noticed at all, the casual observer would likel y note only that the added development resembled the structures already on the site. Figures 3-4 through 3-6 provide simulated views of the proposed facilities.

Renewable Fuel Heating Plant

The RFHP would be similar in height to the FTLB and, from most off-site observation points, would be partially blocked from view by the FTLB. Constructe d of the same architectural concrete block as the FTLB, its color and texture would blend into the ove rall view. Figure 3-4 is a simulation of the view looking north from the south side of the STM site with the RFHP added. From this vantage point, without artificial magnification, the RFHP would be almost indi scernible. As described in Section 3.1.3, at normal operating temperatures, no visible plume would exit the RFHP stack.

SolarTAC Project

SolarTAC would alter the near-field existing view by installing arrays of PV panels over 0.8 hectare (2 acres) of undeveloped area adjacent to and behind the current Visitors Center and converting the median in front of the Visitors Center into a pa rking area (Figure 3-5). Arranged in rows ascending the gradual slope of the SolarTAC site, the PV panels w ould be somewhat consistent in form to the terraced appearance of the SERF located nearby and would be similar in appearance to PV panels located elsewhere on the STM site. Viewed from a distance, SolarTAC would blend with the overall appearance of the STM site and would not represent a unique addition to the site’s overall visual impression.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

27

Figure 3-4. Simulated View of the Proposed RFHP, with the Proposed MTPP in the Distance

Figure 3-5. Simulated View of the Proposed SolarTAC Project and Parking AreaFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

28 Figure 3-6. Simulated View of the Proposed MTPP from I-70

Mesa Top Photovoltaic Project

The MTPP would be located atop the mesa at about 6,000 feet above sea level. Due to the steepness of the mesa’s slope, the MTPP would be almost undetectab le by anyone viewing the site from any location lower than the mesa top. The terrain within 3 kilometers (2 miles) of the STM site is less than 6,000 feet in elevation; therefore, anyone within that area would not see the MTPP.

As shown in the simulation on Figure 3-4, the MTPP, although remote, would be viewed by residents south of the STM site as a dark thin linear feature along the edge of the mesa top adjacent to the already existing solar radiation research facilities. Extending approximately 300 to 600 meters (1,000 to 2,000 feet) along the edge of the mesa top, the MTPP woul d be visually unique among the miles of undeveloped mesa edge atop STM. As viewed by drivers trave ling east on I-70 (Figure 3-6), the MTPP would be virtually indistinguishable on the horizon.

3.1.5 Water Resources

3.1.5.1 Existing Environment

The descriptions of water resources found in the site-w ide EA remain current and are summarized below.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

29 Surface Water

There are no perennial creeks, streams, ponds, or fl oodplains on the STM site. Surface water, when present, is not used by NREL. There may be seas onal seeps on the STM site after small amounts of surface water percolate through the soil or the fract ured basalt that caps STM. Intermittent storms and other seasonal precipitation events may cause water to temporarily collect in topographic lows and drainages. Surface water may briefly collect in depressi ons formed in the basalt on the top of the mesa.

Groundwater

Groundwater monitoring is not required of NREL by a regulatory agency; however, monitoring wells were installed at the STM site, and groundwater b aseline data were accumulated beginning in 1990. The monitoring wells have since been capped. The most recent groundwater monitoring data were obtained in 1997. That year, groundwater beneath the site was analyzed for VOCs, semivolatile organic compounds (SVOCs), total metals, pesticides, and herbicides. Resu lts of the analysis indicated that the groundwater beneath STM is uncontaminated for VOCs, SVOCs, pesticides, and herbicides. Although the samples indicated that concentrations of manganese and iron were elevated, the concentrations were within naturally occurring variations and no constituent concentrations exceed ed national primary drinking water standards.

3.1.5.2 Impacts of the Proposed Action

Renewable Fuel Heating Plant

The RFHP would not result in untreated operati onal discharges of pollutants to surface water or groundwater. The RFHP drains would be connected to the site’s existing stormwater and sewage lines, and all discharges to the publicly owned treatment works would meet the requirements of the Metro Wastewater Reclamation District and the Pleasant View Water and Sanitation District.

The RFHP would increase the impervious surface area, which could increase quantities of stormwater conveyed off-site, increase runoff rates, and incr ementally degrade surface water quality. Increased turbidity and quantities of various chemicals asso ciated with additional vehicles and construction equipment would occur.

Changes in the quantity of stormw ater and runoff rates could incrementally impact localized on-site flooding; however, implementation of stormwater pollution prevention measures would minimize off-site drainage impacts. During the design process, drainage structures would be designed on-site to minimize the increase in the flow rate of stormwater conveyed off-site. Stormwater impacts would be minimized by complying with the provisions of NREL’s EPA-issued National Pollutant Discharge Elimination System general construction permit. If grou ndwater were encountered during excavations for the plant, it would be pumped from the excavation to a vegetated area rath er than into drainage. The vegetated areas would act as filters to trap sediment and reduce impacts associated with groundwater disposal.

SolarTAC Project

The description of surface water resource impacts pr ovided above for the RF HP are applicable to SolarTAC. There would be no impacts to groundwater . The SolarTAC installa tion and operations would result in an increased number of visitor automob iles entering the site. Traces of petroleum products originating from leaking vehicles could be transported from the pavement off-site via stormwater. These contaminants could contribute to water quality degradation.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

30 Mesa Top Photovoltaic Project

The description of surface water resource impacts prov ided for SolarTAC are al so applicable to the MTPP. There would be no impacts to groundwater.

3.1.6 Geology and Soils

3.1.6.1 Existing Environment

The detailed descriptions of the site geology and soils found in the site-wide EA remain current and are summarized below.

The STM is located on the gently sloping terrain of the Foothills Province of the Rocky Mountain Front Range between the Southern Rocky Mountain Province to the west and Great Plains Province to the east. Denver clay loam and Denver cobbly clay loam domi nate the soils at STM site where the RFHP and SolarTAC installations would be constructed; Lavina loam dominates on the mesa top. Slopes are generally less than 9 percent. The STM site is classified as being in Seismic Zone 1, an area of low seismic risk. Structures to be built on the STM site would meet the most current Uniform Building Code standards appropriate for it s designated seismic zone.

3.1.6.2 Impacts of the Proposed Action

Renewable Fuel Heating Plant

Potential geological impacts would closely resemble the geological impacts presented in the site-wide EA, which specifically considered construction of the nearby S&TF and other comparable site developments. The RFHP would be constructed into a hillside. An area of approximately 185 to 230 square meters (2,000 to 2,500 square feet) would be disturbed. A geotechnical survey and soil sampling were performed on the proposed RFHP site during the planning phase. The report findings were used to develop structural designs and determine site preparation and construction requirements. Prior to building installation, the site would be excavated as needed for building construction. Resources such as concrete aggregate and crushed ro ck would be required during constr uction of the RFHP. These materials would be obtained from off-site commercial sources or may involve use of material from on-site excavations. Excavation may occur below the alluvi al surface. Excavation could conceivably go below the alluvium if reaching bedrock for stability were ne cessary. It is unlikely that RFHP construction would increase landslide potential at the construction site or elsewhere at the STM site in the future because there is no evidence of recent landslides on the south side of STM, and no on-site or off-site construction in the immediate vicinity of the STM site has caused slope instability. The necessary excavation into the hillside would apply the most current engineering d esign specifications to avoid slope-stability impacts

. The RFHP design would include drainage features to ensure stability of the structure, prevent flooding, and facilitate installation of an entrance drive.

SolarTAC Project

Construction activities associated with the SolarTAC installations would be primarily aboveground, surface, or shallow below-ground installations a nd would not impact existing geologic resources. Installation of new SolarTAC facilities, a driveway , and a parking area would disturb approximately 2 hectares (5 acres) of topsoil. Where installations re quired removal of topsoil, it would be stockpiled for reuse, removed, or redistributed on the site by the co ntractor. Some soils would be lost due to the physical alteration of the existing soil profile. However, the site’s soil is nonproductive from an agriculturalFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

31 standpoint; therefore, the loss of these soils would not represent a major impact. DOE would import fill and/or topsoil, if necessary.

Mesa Top Photovoltaic Project

Construction activities on the mesa top could dist urb the basalt layer that underlies the thin (approximately 13-centimeter [5-inch]) Lavina loam soil layer. Electrical interconnection would be through an existing, spare transformer. This transf ormer is located in the middle of the proposed MTPP site, so only minimal excavation, or blasting if ne w utility poles were erected, would be required. Approximately 2 hectares (5 acres) of Lavina loam on the mesa top could be di sturbed during installation of the MTPP panels. Disturbing the soil as a result of construction activities could increase the potential for soil particles to be scattered by the wind. Eros ion caused by water on mesa-top construction sites would be very minor because the mesa top is relatively flat.

3.1.7 Biological Resources and Wetlands

3.1.7.1 Existing Environment

The descriptions of biological resources and wetlands found in the site-wide EA remain current and are summarized below. These descriptions relied upon pr evious reporting and fieldwork performed by various consultants at the STM site over the past 16 years, as well as fieldwork conducted in May 2002. Additional biological resource information is available in the following reports.

• Wildlife Survey (Including Migratory Birds and Raptors) at the National Renewable Energy Laboratory South Table Mountain Site, Golden, Colorado (NREL, 2005);

• Vegetation Survey, NREL South Table Mountain Site (NREL, 2002b);

• National Renewable Energy Laboratory (NREL) Site Conservation Easem ent Baseline Inventory (NREL, 1999);

• South Table Mountain Conservation Easement Baseline Inventory (NREL, 1998).

Located at the base of the foothills to the Rocky Mountains, the STM site occurs at elevations ranging from 1,762 meters (5,780 feet) to 1,838 meters (6,030 f eet) above mean sea level. This coincides with the interface between two ecological provinces: the Great Plains-Palouse Dry Steppe Province to the east, and the Southern Rocky Mountain Steppe – Open Woodla nd – Coniferous Forest – Alpine Meadow Province to the west.

Three primary plant communities occur within the proposed project areas at the STM site: grasslands, shrublands, and one very small wetland. Table 3-4 in the site-wide EA lists the vegetation types and their areal extent; Figure 3.8 in the site-wide EA depict s the locations of these different vegetation types. Noxious weeds occur in all vegetation types. The RFHP would be built on previously disturbed and ravine shrub habitat, SolarTAC would be insta lled on mixed grass habitat, and the MTPP would be installed on disturbed mesa top land and short grass habitat. Table 3-5 shows variations of these three primary types of vegetation and their ap proximate distributions at the site.

As shown in Figure 3-9 of the site-wide EA, there ar e no wetlands in development Zone 1 (top of mesa buildable area) and none in the vicinity of the propos ed SolarTAC installations. There is one very small 14-square-meter ([150-square-foot ]) palustrine emergent wetla nd (STM-6) immediately behindFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

32 Table 3-5. Vegetation Types at NREL, STM Site, Golden, Colorado

Vegetation Type Area (Acres) Percent of Site Short grass grassland 124 37.9 Mixed grass grassland 103 31.4 Tall shrubland 19 5.8 Short shrubland 16 4.9 Ravine shrubland 5 1.5 Wetland <1 0.1 Disturbed/reclaimed 32 9.8 Developed 28 8.6 TOTAL 327 100 Source: NREL, 2002b.

Note: To convert acres to hec tares, multiply by 0.4.

(northwest of) the SERF and several hundred feet east of and on the opposite side of the ravine from the proposed RFHP site.

Wildlife habitat at the STM site is almost exclusiv ely grassland and shrubland. The Colorado Division of Wildlife (CDOW) has estimated that these habitats may support up to 14 reptile species, 36 mammal species, 82 bird species, and 4 amphibian species.

A wildlife study of the STM was conducted in 1987. The demographics of the area surrounding the STM site have changed since that study, and additional de velopment of the STM site has since occurred. At the request of NREL, Science Applications Internationa l Corporation began a four-season wildlife survey of the STM site in the spring of 2004 to update th e 1987 data. The 2005 wildlife survey (NREL, 2005) is incorporated into this EA by reference; the findi ngs are summarized below. The wildlife survey also includes recommendations for consideration during normal site operations and future construction projects to minimize adverse impacts to wildlife. These recommendations would be reviewed and implemented to the fullest extent possible before and during implementation of the Proposed Action.

Migratory Birds and Raptors

Many species of migratory birds occur on the STM site, with many of these species potentially nesting on-site. In addition, the STM site may provide important migration and winter habitat for migratory birds. Habitat for migrating birds is important, as some of these species may migrate as far south as Central and South America.

Several species of raptors were observed at the STM site, and two species were observed during both wildlife surveys (1987 and 2004-2005) nesting on-site: the red-tailed hawk and the American kestrel. Both of these species were observed hunting on-site du ring the 2004-2005 surveys, in addition to the Cooper’s hawk. The NREL STM site provides habitat a nd a prey base of small birds and small mammals for these raptor species. Species su ch as the Swainson’s hawk migrate thousands of miles each year, wintering as far south as Argentina and returning to the western United States and Canada to breed. Areas such as the STM site may provide a prey source for the Swainson’s hawk and other species during migration.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

33 Large Mammals

Mule deer at the STM site have been observed in all habitat types. Mule deer were often observed in the amphitheater drainage or in the tall shrubland on slopes.

Predators

Coyotes are one of the most widespread and adaptabl e carnivores in North America. They occur at all elevation levels and in all ecosystems in Colorado. Rabbits and rodents are an important part of the coyote’s diet, both of which are abundant on the STM site. Evidence of predation on cottontail rabbits (i.e., entrails and fur) was observed during site visits. Coyotes may breed on the STM site, as two potential dens were observed on-site in drainage areas.

Small Mammals

The deer mouse is the most common small mamma l on the NREL STM site. Deer mice can occur wherever cover occurs and were observed in the ve getation types sampled on the STM site. This species is a generalist and is known to e xploit disturbed habitats. Mexican w oodrats and prairie voles were more restricted than the deer mouse in the habitats th ey occupied on the STM site. Mexican woodrats are associated with rocky slopes and do not build dens away from rocky areas. This species is therefore limited as to where it can occur on the STM site. Prai rie voles are adapted to the grasslands, constructing burrows and runway systems throughout the grassla nd, essentially limiting this species to the short grass and mixed grass vegetation types on the STM site. A ll of these species are active throughout the year.

Reptiles/Amphibians

Several rattlesnakes were observed on the STM site, more often in rocky areas, but also in the grassland. A rattlesnake den may be present in th e rocks near the top of the mesa slope north of the Visitors Center; four rattlesnakes were observed within a few feet of each other, one in the open and three in a rock crevice. Hibernation generally occurs in rock out crops, with this species usually active from mid-April through late-September. Although only three species of reptiles and one species of amphibian were observed on the STM site, no specific survey methods we re employed to identify or count these groups of wildlife at STM.

Species of Concern

For this EA, a species of concern is defined as tho se species protected under federal statute, including the Endangered Species Act of 1973, as amended; the Bald Eagle Protection Act of 1940, as amended; and the CDOW list of endangered, threatened, and wild life species of concern. Federal agencies are also required to abide by the Migratory Bird Treaty Act of 1918, as amended.

The 2005 survey included a review of the U.S. Fish and Wildlife Service (USFWS) proposed, endangered, threatened, experimental, and candida te species and habitat list (USFWS, 2004) and the CDOW listing of endangered, threatened and wildlife species of special concern list (CDOW, 2003) for species observed on the STM site. No species observed on the STM site during the 1987 or the 2004-2005 wildlife surveys were present on either agency’s list. However, golden eagles were incidentally observed on the STM site (outside of raptor surveys) and are protected under the Bald Eagle Protection Act. Golden eagles were observed flying over the site and may use the site for hunting. No golden eagle nests or nesting activities were observed on the STM site.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

34 3.1.7.2 Impacts of the Proposed Action

Renewable Fuel Heating Plant

The RFHP would be located on previously disturbed land adjacent to a major site road and between the FTLB and the SERF. Land clearing, excavation, and c onstruction staging areas would degrade the habitat value of the adjacent drainageway. Four standing trees would be destroyed, relocated, or replaced. The disturbed area that is not permanently lost as habita t due to new construction would probably have an increased susceptibility to noxious w eed invasion (discussed further under impacts from the SolarTAC installations and MTPP below). If a truck turnaround area were added, there would be a small increase (less than an acre) of additional habitat loss. Th e small wetland area behind the SERF would not be impacted by construction or operation of the RFHP.

SolarTAC Project

The SolarTAC Project would result in direct, permanent loss of up to 0.8 hectare (2 acres) of mixed grass and shrub habitat in Zones 4 and 5. This loss woul d adversely impact wildlife that currently use the habitat. Wildlife impacts from habitat losses would not be major because (1) substantial wildlife habitat has been protected on-site and off-site in the project vicinity, and (2) no species of concern have been documented within the habitat that would be lost. Secondary impacts due to the loss of this habitat would reduce the overall size of local hunting areas of resi dent mammalian and avian predators such as coyotes, fox, red-tailed hawks, and owls. In addition, loss of habitat in Zones 4 and 5 would reduce habitat connectivity for land-based animals between the c onservation easement in Zone 2 and Lena Gulch, located just south of the site at Camp George West. Local populations of mule deer, coyotes, and other species that have relatively large foraging areas may be adversely affected by this loss.

Land clearing and the installation of SolarTAC and MTPP facilities could disturb some existing vegetation, making the areas more susceptible to noxi ous weed invasion. Noxious weeds such as Canada thistle, diffuse knapweed, musk thistle, houndstongue, field bindweed, common teasel, jointed goatgrass, and dalmatian toadflax occur on the site and are f ound on either the list of the 10 most widespread noxious weeds in the State of Colorado or on Jeffers on County’s list of noxious weeds of concern. The potential spread of these species, as well as cheatgrass and the other 12 noxious weed species found at the STM site, into disturbed areas represents secondary im pacts as a result of the Proposed Action. DOE has made efforts to combat noxious weed invasion. Th ese efforts include implementation of a noxious weed management plan which, among other strategies, calls for the use of a native grassland seed mix to be used in restoration areas after construction.

Mesa Top Photovoltaic Project

The MTPP would result in direct, permanent loss of up to 2 hectares (5 acres) of mixed grass and shrub habitat in Zone 1. This would adve rsely impact wildlife that currently uses the habitat. Wildlife impacts from habitat losses would not be major because (1) substa ntial wildlife habitat has been protected on-site and off-site in the project vicinity, and (2) no species of concern have been documented within the habitat that would be lost. Secondary impacts due to the loss of this grassland habitat would reduce the overall size of local hunting areas of resident mammalian and avian predators such as coyotes, fox, red-tailed hawks, and owls.

Land clearing and the installation of MTPP facilities c ould disturb some existing vegetation, making the areas more susceptible to noxious weed invasion. Noxious weeds such as Canada thistle, diffuse knapweed, musk thistle, houndstongue, field bindweed, common teasel, jointed goatgrass, and dalmatianFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

35 toadflax occur on the site and are found on either the list of the 10 most widespread noxious weeds in the State of Colorado or on Jefferson County’s list of noxi ous weeds of concern. The potential spread of these species, as well as cheatgrass and the other 12 noxious w eed species found at the STM site, into disturbed areas represents secondary impacts as a result of the Proposed Action. DOE has made efforts to combat noxious weed invasion. These efforts include implemen tation of a noxious weed management plan, which calls for the use of a native grassland seed mix to be used in restoration areas after construction.

3.1.8 Cultural Resources

3.1.8.1 Existing Environment

There are no known significant prehistoric archaeologi cal resources within or adjacent to the NREL STM property. There are no known significant traditional cultural resources within or adjacent to the STM site. Should any evidence of archaeological or cultural r esources be discovered at any time during any grounddisturbing activities at the STM site, all work would stop in the vicinity until a qualified archaeologist completely evaluated the significance of the find accord ing to criteria established by the National Register of Historic Places.

DOE completed a file search for the entire STM site in June 2005. As a result, eight previously recorded features were identified in the STM vicinity (Nel son, 1980). A Class III intensive survey conducted in April 2007 identified no other cultural resour ces in the Proposed Action areas (Rhodes, 2007).

There are four significant or contributing historic structures on the STM property. Two of these resources, the amphitheater and associated footbridge (5JF842) and the ammunition igloo (5JF843), are located in Zone 7 (Non-contiguous Historic Resource Areas) and are individually listed on the National Register. The remaining resources are within the Camp George West Historic District and contribute to the District’s eligibility. These resources are located in Zo ne 6 and were recorded to the Level II Historic American Building Survey/Historic American Engin eering Record standards in January 2006 (Rhodes, 2006) (see Figure 3-1).

The historic amphitheater is an ovate stone structure bu ilt into the natural slope of the hillside with a stone projection booth located at the base of the structur e. A concrete center aisle separates the theater’s concrete and stone seating areas. Some of the associated rock walls and seats have collapsed, and much of the area is overgrown with native vegetation. A small stone footbridge leads to the amphitheater. The bridge is in good condition. Outside groups have expressed an interest in restoring both of these historic structures, but no formal proposal has been submitted. The ammunition igloo dates from World War II.

3.1.8.2 Impacts of the Proposed Action

Renewable Fuel Heating Plant

The RFHP would be constructed in a drainage setting between the existing FTLB and the existing SERF. The ammunition igloo is the nearest historic propert y to this proposed development site but is well beyond the proposed area of potential effects (APE). The igloo is located approximately 60 meters (180 feet) to the northeast, on the other side of the road. The amphitheater is located up the drainage northwest of the proposed RFHP, but none of the r ecorded features associated with the amphitheater are within 100 meters (300 feet) of the proposed facility . Neither the ammunition igloo nor the amphitheater would be impacted by the Proposed Action.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

36 SolarTAC Project

The SolarTAC Center would be located just northeast of the Visitors Center. The SolarTAC is not within 100 meters (300 feet) of any historic property. One feature was identified in the vicinity by Nelson (1980). This feature, consisting of check dams, is located more than 100 meters (300 feet) from the proposed development site, in a drainage to the east. This feature would not be impacted by the Proposed Action.

Mesa Top Photovoltaic Project

The MTPP would occupy a portion of the mesa top above the amphitheater. At the closest point, the proposed project area boundary is approximately 40 me ters (130 feet) above the historic property. At the farthest point, the boundary is over 100 meters (300 feet) away. The mesa top and the amphitheater are visually separated by a significant drop in elevation of at least 12 meters (40 feet) at the closest point. The amphitheater is well beyond the APE of this Proposed Action and would not be impacted.

Based on the results of the recent literature search and Class III intensive survey, as well as previous surveys and consultations, DOE has determined that the Proposed Action would have no effect on cultural resources. A letter confirming the State Historic Preservation Officer’s (SHPO’s) concurrence with a finding of “no historic properties affected” is included in Appendix C.

3.1.9 Noise

3.1.9.1 Existing Environment

Detailed descriptions of the exis ting noise environments at the STM are provided in the site-wide EA. These descriptions address sensitive noise receptors (Secti on 3.4.1), existing noise levels (Section 3.4.2) and noise regulations and guidelines (Section 3.4.3). Th ey remain current and are summarized or updated below.

Noise receptors located in the immediate vicinity of the STM site include STM personnel, inhabitants of residences to the east and south of the site boundary, and wildlife. With respect to NREL personnel, DOE has accepted the Occupational Safety and Health Administration (OSHA) noise regulations and guidelines for worker exposure and manages compliance with them. These regulations and guidelines focus on noise from machinery, equipment, and tool s. DOE maintains compliance with all regulations related to worker health and safety.

Other sensitive receptors in the vici nity include multi-family residences located approximately 15 meters (50 feet) east of the site boundary. Two subdivisions composed of single-family residences are located south of the STM site. The nearest residence to the site’s southwestern boundary is located approximately 15 meters (50 feet) away. The nearest residence to the site’s southeastern boundary is located approximately 30 meters (100 feet) away. The nearest school, church, or day-care center is about a half mile from the site, near 20 th and Denver West Parkway. A ball field was recently completed in the open area immediately south of the STM site.

Although noise measurements were not taken for the site-wide EA and noise modeling was not performed, site observations indicate that the ac oustic environment within the boundaries of the southeastern portion of the site can be considered simila r to that of an urban location. I-70 is a significant noise source throughout the day and during sensitive la te-night and early-morning periods. Noise levels on the mesa top are typical of a rural location but can be elevated substantially when an adjacent StateFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

37 Highway Patrol driver-training track is being used. It is estimated that 24-hour day-night average sound levels on the site typically range from 40 to 60 A-we ighted decibels (dBA). Most activity and mechanical operations at the STM site are conducted within build ings. Construction activity and routine maintenance occasionally generate noise. The proposed new park will become another source of noise in the vicinity.

The State of Colorado Noise Statute (Code of Colorado Regulations [CCR] 25-12-101 through CCR 25-12-109) has established state-wide standards for noi se level limits for various time periods and areas. The standards exclude federal entities such as NREL; how ever, they can be used as guidelines in order to evaluate impacts. The most stringent permissible noi se levels apply to residential zones, where the maximum permissible daytime (7 a.m. to 7 p.m.) noise level is 55 dBA and the noise level is measured at a distance of 8 meters (25 feet) from the property line . In addition, construction projects are limited to permit conditions or 80 dBA for the period within which the construction is to be completed or a reasonable amount of time.

The City of Denver has promulgated a noise ordinance, Revised Municipal Code, City and County of Denver, Colorado, Ordinance No. 628-97, 22 Sept ember 1997, Supplement No. 55 (City and County of Denver, 1997) that can provide another basis for eval uating noise levels. The type of premises on which the noise is generated determines allowable noise le vels. In the case of the STM site, the most conservative approach is to consider it “industria l premises.” The maximum allowable sound pressure level under the Denver ordinance is 80 dBA measured at the site property line between the hours of 7 a.m. and 10 p.m.

3.1.9.2 Impacts of the Proposed Action

Renewable Fuel Heating Plant

The RFHP would be installed inside a building, so operational noise impacts to the surrounding area would be partially attenuated. Table 3-6 shows the major equipment involved in the operation of the RFHP that would be heard in the building and approxim ate decibel levels associated with the equipment.

Operation of the proposed RFHP would incremen tally increase the ambient nose at the STM site. Compliance with OSHA requirements for noise exposure is a site mandate. Noise impacts to RFHP operators would be reduced by the use of hearing protection equipment as required by OSHA standards or as requested by RFHP operators.

Levels of ambient or intrusive outdoor noise vary extensively at distances greater than about 100 meters (330 feet) from the source. This variation is caused by changes in weather and by topographical features such as ground cover, hills, trees, structures, a nd other obstacles between the noise source and the

Table 3-6. RFHP Equipment Noise Levels
RFHP Equipment Estimated Indoor Noise Level Grinder 85 dBa maximum Hot Water Pumps < 49 dBa Fans and Ventilation System < 48 dBa Augers Minimal Screener Minimal Source: Ameresco, 2007.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

38 receptor. A rule of thumb (the “Rule of 6”) is that under ideal conditions (no background sound or interference), a sound level drops 6 dBa for every doubling of the distance from the source (AEUB, 2007). The nearest off-site noise receptors to the pr oposed RFHP noise source would be homes in the northeast corner of the Whiteaker subdivision and the northwest corner of the Richards Heights subdivision. Both of these off-site receptor areas lie approximately 300 meters (1,000 feet) from the proposed location of the RFHP. There are structures between the noise source and the receptors, and the receptors are on the other side of the Denver West Pa rkway. These factors make it difficult to quantify the noise impact from the proposed RFHP at these locations . However, applying the Rule of 6 and assuming the wood grinder, the loudest source of noise at the RFHP, could generate 85 dBa at a distance of 10 meters (30 feet), the noise level at the nearest o ff-site receptors would be approximately 45 dBa. This is a conservative (probably high) estimate of off-s ite noise because the grinder would be housed in a building, which would attenuate th e noise perceived by off-site receptors. For comparison, 45 dBA is approximately the ambient noise level in quiet agricultural areas (EPA, 1978). The noise from the RFHP grinder, which would be intermittent, would probably not be noti ceable over ambient residential neighborhood, street, and highway noise.

SolarTAC and MTPP Noise Impacts

Noise impacts due to construction of the SolarTac and MTPP would be similar to those described in detail in the site-wide EA (DOE, 2003). Construction-relate d noise would be expected to occur intermittently for the approximately 6 months that the facilities woul d be under construction. Operation of the proposed SolarTAC and MTPP facilities would not result in ma jor increases to existing ambient noise at the STM.

3.1.10 Waste Management

3.1.10.1 Existing Environment

The descriptions of the existing waste management environment found in the site-wide EA remain generally current and are summarized or updated below.

The STM generates a variety of hazardous and non-hazardous wastes from laboratory and mission support activities. All waste-handling and disposal ac tivities at both sites comply with the requirements and regulations of OSHA, the Resource Conservati on and Recovery Act, DOE, and the CDPHE. All hazardous wastes are packaged and disposed of th rough contracted off-site commercial treatment, disposal, and recycling firms. Many of the hazardous wastes generated on-site are recycled in accordance with CDPHE regulations, including such items as batteries, fluorescent bulbs, and computer monitors. As a best management practice (BMP) in order to ensure maximal protection of the environment, many of the non-hazardous waste materials (non-regulated waste) generated at the sites are treated in the same manner as the hazardous wastes. These materials, although not classified as hazardous, are also recycled or disposed of at off-site commercial treatment, storage, disposal, and recycling facilities.

The STM site is a small-quantity generator, whic h means that the facility generates more than 100 kilograms (220.5 pounds) but less than 1,000 kilograms (2,205 pounds) of hazardous waste per month. The STM site does not maintain an on-site waste disposal facility. The amount of hazardous and non-regulated waste generated by the STM site in recent years is shown in Table 3-7.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

39 Table 3-7. Waste Generation at the STM Site, 2003-2006

Amount Generated (gross weight in pounds) Category of Waste
2003 2004 2005 2006 Hazardous waste 21,725 19,631 33,370 31,539 Non-regulated waste 5,469 1,645 11,345 7,492 Note: To convert pounds to kilograms, multiply by 0.45.

3.1.10.2 Impacts of the Proposed Action

Renewable Fuel Heating Plant

RFHP construction would be short- term (approximately 6 to 7 mont hs) and would not substantially increase the amounts or types of hazardous materials gene rated or maintained at the site. In the case of a spill or release of chemicals or hydrocarbons during construction activities, existing BMPs and procedures associated with spill response and mate rials handling would minimize impacts to surface water. These procedures are defined in the NREL Spill Prevention Control and Countermeasures (SPCC) Plan for the STM (NREL, 2006) (Procedure 6.2-10). Any construction debris that could not be recycled would temporarily increase the weight and volume of non-regulated waste generated at the site.

RFHP operations would not generate hazardous waste or non-regulated waste. The ash generated by theRFHP would be considered recycled waste, a separate waste category from either hazardous or nonregulated waste. Based on vendor-provided data (Ameresco, 2007), the biomass fuel would be 2 percent to 3 percent ash, and the total quantity of RFHP ash generated during an aver age heating season would be 83 to 136 metric tons (92 to 150 tons). The ash would be picked up weekly during the peak winter months and two to three times a month during non-peak opera ting months. The ash would be recycled for use in mulching mixes or shipped for use in concrete manuf acturing. If the ash could not be recycled, it would be disposed of off-site at a commercial landfill. Because the STM is located near a very large metropolitan area, this increase in landfill waste would not represent a significant impact to regional waste management (storage and disposal) operations or capacities.

SolarTAC Project

Neither the construction nor the operation of SolarT AC would result in the generation of significant quantities of hazardous or non-regulated waste. Any cons truction debris that could not be recycled would temporarily increase the weight and volume of non-regulated waste generated at the site.

Mesa Top Photovoltaic Project

Neither the construction nor the operation of the MTPP would result in the generation of significant quantities of hazardous or non-regulated waste. Any cons truction debris that could not be recycled would temporarily increase the weight and volume of non-regulated waste generated at the site.

3.1.11 Public Facilities, Services, and Utilities

3.1.11.1 Existing Environment

The detailed descriptions of public facilities, service s, and utilities found in the site-wide EA remain
current.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

40 3.1.11.2 Impacts of the Proposed Action

The following discussion addresses the impacts of the Proposed Action on the capacity of public infrastructure and service providers. Any requisite utility interconnection interruptions during construction or operation w ould be temporary and would be coordi nated in advance with the cognizant utilities.

The RFHP and MTPP would have a substantial net positive impact on electric and gas utility infrastructure because they would reduce the overall cu rrent and projected future demand the STM site places on local and regional public utility infrastruct ures for delivery of natural gas (RFHP) and gridgenerated electricity (MTPP) to the STM site. The RFHP and SolarTAC installations would result in a small overall increase in the STM site’s net electric po wer usage, but this increase would be more than offset by the overall decrease in demand for grid-generated power.

Collectively, the three proposed improvement projects would represent a very minor increase in demand for telecommunications, domestic water, or sewage service due to the very low number of additional employees and other perso nnel at the STM site.

The new facilities and additional staff associated with the Proposed Action would incrementally increase demand for police, fire, and ambulance services, but the increases would be considered minor given site use, on-site security, and anticipated needs for emergency service providers.

Because the RFHP would be a wood-burning boiler, it would slightly increase the risk of wildfire on the site. The NREL Fire Protection Program currently addresses this and other fire risks. The RFHP proposal includes a dry pipe fire suppression system and an alarm system. The potential for particulate emissions would be mitigated by a multi-cyclone system. The pl ant would automatically shut down if the induced draft fan serving the cyclone were to fail.

3.1.12 Energy and Sustainability

The discussion of energy and sustainability found in the site-wide EA remains current and is applicable to the SolarTAC and MTPP projects, which are intended to make a substantial contribution to energy efficiency and renewable (sustainable) energy tec hnology. The magnitude of these beneficial impacts could range from minor to globally significant, depending on the technology achievements resulting from the projects. These direct benefits would also result in indirect and/or secondary beneficial impacts to the environment, including, but not limited to, reduced ai r pollution as compared to emissions generated with conventional energy technologies. The RFHP would use renewable biomass in place of a fossil fuel whose availability is finite.

3.1.13 Intentional Destructive Acts

In December 2006, the DOE Office of General C ounsel (formerly the Office of NEPA Policy and Compliance) issued interim guidance stipulating that each DOE EIS and EA should explicitly consider intentional destructive acts (i.e., acts of sabotage or terrorism). DOE applied a sliding scale in considering the potential impacts of intentional destructive act s within the context of the Proposed Action.

None of the three proposed site improvement projects that are the subject of this EA would involve the transportation, storage, or use of radioactive, expl osive, or toxic materials. Consequently, it is highly unlikely that the projects making up the Proposed Action would be viewed as a potential target by saboteurs or terrorists. The wood that would fuel the proposed RFHP is necessarily combustible but it isFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

41 neither explosive nor highly flammable. The limited quantities of wood that would be stockpiled, the facility’s fire suppression and alarm system, and the limited access to the fuel storage pit would limit the attractiveness of the facility to saboteurs or terrorists.

Vandalism of the MTPP PV panels on the mesa top by so-called “eco-terrorist s” is a more credible intentionally destructive act scenario. However, su ch vandalism, while potentially disruptive of NREL operations, would not pose a risk of adverse impacts to human life, health, or safety. Moreover, the mesatop facilities would be protected by a security fence and motion-sensitive night lighting. In summary, the Proposed Action does not appear to offer any targets of opportunity for terrorists or saboteurs to inflict significant adverse impacts to human life, heath, or safety.

3.2 Environmental Consequences of the No Action Alternative

The environmental consequences of the No Action Alternative would be very similar, and in some instances identical, to the Environmental Consequen ces of the No Action Alternative presented in the site-wide EA. These are summarized or updated below.

Under the No Action Alternative:

• Existing on-site land uses, site development density, and opera tions would not change. Fewer beneficial economic impacts would result because RFHP, SolarTAC , and MTPP construction would not occur, and related job growth and NREL development would be limited.

• The minor incremental impacts to traffic and park ing from site construction and increased visitors to SolarTAC installations associated with the Pr oposed Action would be avoided. An additional three to five weekly RFHP fuel-delivery trucks and ash pick-up trucks would not traverse the site from October through April.

• Emissions of criteria air pollutants and TAPs from RFHP operations would not occur. Existing emissions from on-site operations w ould remain at current levels.

• A new ambient noise source (the RFHP) would not be added to the STM site. Off-site noise levels in the area would continue to be dominated by vehicle traffic on I-70.

• There would be no impacts to surface water, stormwater, or groundwater resources.

• The loss of approximately 3 hectares (7 acres) of grassland habitat on the mesa top and north of the NREL Visitors Center would not occur.

• The site would not generate 83 to 136 metric tons (92 to 150 tons) of non-regulated RFHP ash as a waste stream. The quantities and types of hazar dous materials and hazardous wastes associated with the site would remain c onsistent with current amounts.

• The No Action Alternative would limit demand growth for public services and utilities by retaining existing employment levels and operati onal activity at current levels. New facilities and modification and expansion of existing facilities w ould not occur. Incremental capacity impacts on existing service providers resulting from the Pr oposed Action and the impacts of associated infrastructure improvements would be avoided.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

42 • The STM site’s energy production capacity and energy consumption would remain at current levels. The site would not benefit from replacement of up to 80 percent of its natural gas with renewable biomass fuel for winter heating, no r would it augment its current electric power demand with up to 1 MW of solar power.

• There would be no improvements made to the middle drainageway.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

43 4.0 CUMULATIVE AND SECONDARY IMPACTS

Cumulative impacts result from the in cremental impact of a proposed action when added to other past, present, and reasonably foreseeable future actions. Secondary impacts are those that are caused by a proposed action, but may occur later in time or fart her removed in distance, relative to the primary impacts of the proposed action (40 CFR section 1508.7).

The 2003 site-wide EA considered cumulative and sec ondary impacts of various pending and conceptual site development projects and c oncluded that the incremental contribution to these cumulative and secondary impact areas would be insignificant. That EA also concluded that the No Action Alternative would not contribute to these impacts. The most important examples of cumulative and secondary impacts associated with the site-wid e EA Proposed Action were as follows:

• Traffic congestion at the intersections along Denver West Marriott Boulevard;

• Regional and local air pollutant emissions;

• Noise impacts on Pleasant View neighborhoods;

• Development intensification;

• Increases in Lena Gulch stormwater flows;

• Habitat losses from development of natural areas;

• Demand for energy; and

• Beneficial impacts from improved alternative energy sources.

The three proposed site improvement projects that ar e the subject of this EA were not sufficiently far along in their conceptualization to be explicitly discussed in the site-wide EA. However, with the exception of visual impacts, the preceding list of cumulative and secondary impact areas bounds those that would be associated with these three proposed projects. The following discussions describe the potential for the Proposed Action in this EA to result in cumulative and secondary impacts.

Visual impacts . Construction and operation of the three proj ects described as the Proposed Action in this EA would slightly modify the overall visual impression of the STM by adding facilities on 3 hectares (7 acres) of land that is planned for development but is not yet developed. The new development would be visually compatible with the STM site. Additi onally, commercial development continues to occur adjacent to the STM site, altering the visual landscape from open space to offices and residential buildings.

Traffic congestion at the intersections along Denver West Marriott Boulevard. The estimated constructionworkforce for the proposed projects would not be large, nor would the proposed construction be longterm. Construction of the RFHP would only require an estimated 2 to 3 dozen workers for 6 to 7 months. No new workers would be hired to operate the RF HP. The proposed SolarTAC could increase the number of visitors to the STM site by an estimated 500 pe r month, or on average about 20 visitors a day. However, some visitors to the SolarTAC would car pool, and visitors would not necessarily arrive and leave during rush hour. DOE does not expect the three proposed projects to change the current LOS at the intersections along Denver West Marriott Boulevard. Ho wever, if additional park ing were not included in Phase I of the SolarTAC Project, vistors could be requir ed to park off-site, ride shuttle buses, or walk in the street, which could pose a pedestrian hazard.

Regional and local air pollutant emissions . Air quality in the Denver metropolitan area has been poor in the past but has improved in recent years to the po int where the metropolitan area has been redesignated as an attainment area. The RFHP’s emissions would no t be expected to have any meaningful impact onFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

44 the metropolitan area’s air quality or attainment designati on. However, air pollutant concentrations in the metro area are relatively close to the standard fo r ozone and other pollutants, so every source is scrutinized. Given the potential air qua lity benefits of renewable energy and energy efficiency research to be performed at the site, the overall net impact of the three projects on cumulative air quality in the region and locally would probably be neutral. The MTPP and SolarTAC would provide a net advantage to air quality by harnessing non-polluting solar power, while the RFHP would result in an increase in some emissions of criteria air pollutants and hazardous air pollutants.

Noise impacts on Pleasant View neighborhoods . Noise generated during construction, from vehicle use on the site, and from RFHP operations is not exp ected to cause noise levels that would exceed any cumulative noise impact standard.

Development intensification . The Proposed Action includes new development and improvements on the mesa, but it does not create unplanned development or present the potential to open up new off-site areas for development. It does not create improved access to real estate, reduce development restrictions, or substantially induce new development in unanticipated areas.

Increases in Lena Gulch stormwater flows , Stormwater flooding in Lena Gu lch is created by an off-site channel constriction in Camp George West Park. The proposed projects would increase the impervious surface area on the STM site. However, DOE does not anticipate this would have any impact on stormwater flow in Lena Gulch because a new stor mwater retention pond has recently been added at Camp George West Park. Improvements to the middl e drainage stormwater management infrastructure that would be installed as part of the proposed RFHP construction would further reduce the potential for increases in Lena Gulch stormwater flows.

Habitat losses from development of natural areas . The Proposed Action would not have direct impacts on protected species or habitats (wetlands) that are the subject of regulations appr oved to address cumulative impacts on biological resources. However, the projects could impact migratory bird species.

Demand for energy and beneficial impacts fr om improved alternative energy sources . All projects requiring energy have incremental impacts related to energy, but very few offer the possibility of making a positive contribution toward renewable energy an d energy efficiency. The MTPP and the SolarTAC Project are specifically intended to advance the use and acceptance of renewable energy and to enhance energy efficiency.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

45 5.0 COMMITMENT OF RESOURCES AND SHORT-TERM USES

The discussions in Sections 5.1 and 5.2 below were presented in the site-wide EA and are directly applicable to the Proposed Action that is the subject of this EA.

5.1 Irreversible/Irretrievable Commitment of Resources

An irreversible commitment of resources is defined as the loss of future options. The term applies primarily to the effects of use of nonrenewable res ources such as minerals or cultural resources, or to those factors such as soil productivity that are renewable only over long periods. It could also apply to the loss of an experience as an indirect effect of a “perma nent” change in the nature or character of the land. An irretrievable commitment of resources is defined as the loss of production, harvest, or use of natural resources. The amount of production forgone is irretrieva ble, but the action is not irreversible. If the use changes, it is possible to resume production.

The Proposed Action would not have irreversible impacts because future options for using this site would remain possible. A future decommissioning process coul d restore the site for alternative uses, ranging from natural open space to urban development. No loss of future options would occur.

The primary irretrievable impacts of the Proposed Action would involve the use of energy, labor, materials, and funds, and the conversion of some la nds from a natural condition through the construction of buildings and facilities. Irretrievable impacts would occur as a result of construction, facility operation, and maintenance activities. Direct losses of biologi cal productivity and the use of natural resources from these impacts would be inconsequential.

5.2 The Relationship between Local Short-T erm Uses of the Human Environment and the Maintenance and Enhancement of Long-Term Productivity

This section addresses the commitment of resources asso ciated with the Proposed Action relative to the loss of long-term productivity associated with these commitments.

The Proposed Action would commit resources in the fo rm of energy, labor, materials, funds, and land over 20 years or more. The justification for these commitm ents at this time is described in Section 1.3, Purpose and Need. Long-term productivity associated with the site relates to biological value as habitat and open-space values associated with aesthetic qual ity and recreation. The Pr oposed Action would be implemented at a site where substantial portions of the land are specifically reserved and preserved for these purposes. For these reasons, the incremental loss of biological and open-space values is balanced by the protections afforded to the long-term productivity of the site. Improved efficiency and increased reliance on renewable energy resources could substantia lly reduce reliance on coal, oil, and nuclear fuels and reduce resource productivity losses in off-site r esource extraction areas. The Proposed Action would create no long-term risks to public health and safety.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

46 6.0 REFERENCES

AEUB (Alberta Energy and Utilities Board). 2007. Dir ective 038, Noise Control. Pg 41. February 2007. http://www.eub.gov.ab.ca/bbs/documents/directives/Directive038.pdf.

Ameresco (Ameresco Federal Solutions). 2007. Final Proposal, Renewable Fuel Heating Facility, National Renewable Energy Laboratory, CO

. CDOW (Colorado Division of Wildlife). 2003. Colo rado Listing of Endangered, Threatened and Wildlife Species of Special Concern. Updated April, 2003. Available at http://wildlife.state.co.us/species_cons /list.asp. Accessed April 13, 2005.

City and County of Denver. 1997. Revised Muni cipal Code, Ordinance No. 628-97, 22, Supplement No. 55, September 1997.

Clinton, NE, P. Gong, and K. Scott. 2006. “Quantif ication of pollutants emitted from very large wildland fires in Southern California, USA,” Atmos. Environ ., 40(20), pp. 3686-3695.

DOE (U.S. Department of Energy). 2003. Final Site-Wide EA of the National Renewable Energy Laboratory’s South Table Mountain Complex . DOE/EA-1440. July 2003.

Droppo, J.G., and Yu, X.Y. 2007. Evaluation of Replacing Natural Gas Heat Plant with a Biomass Heat Plant . Technical Report by Pacific Northwest National Laboratory to the Department of Energy, May 2007.

EPA (U.S. Environmental Protection Agency). 1978. “Protective Noise Levels: Condensed Version of EPA Levels Document.” EPA 550/9-79-100. Available at http://www.nonoise.org/library/levels/levels.htm

. EPA (U.S. Environmental Protection Agency). 2007. “Emissions Factors & AP 42.” Technology Transfer Network: Clearinghouse for Inventories & Emissions Factors. Available at http://www.epa.gov/ttn/chief/ap42/.

IPCC (Intergovernmental Panel on Climate Change). 2001. “Mitigation. Contribution of Working Group III to the Third Assessment Report of the In tergovernmental Panel on Climate Change.”

IPCC (Intergovernmental Panel on Climate Change). 2007. “Climate Change 2007: The Physical Science Basis: Summary for Policymakers. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change”.

Massachusetts v. U.S. Environmental Protection Agen cy, 549 U.S. __ (2007) (sli p opinion dated April 2, 2007).

Nelson, Sarah M. 1980. “Historic and Prehistoric Resources, South Table Mountain, Golden, Colorado.”

NREL (National Renewable Energy Laboratory). 1998. South Table Mountain Conservation Easement Baseline Inventory. Prepared by ERO Resources Corporation, Denver, CO.

NREL (National Renewable Energy Laboratory). 1999. National Renewable Energy Laboratory (NREL) Site Conservation Easem ent Baseline Inventory . Prepared by Dames & Moore.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

47 NREL (National Renewable Energy Laboratory). 2001. South Table Mountain Emissions Inventory . July.

NREL (National Renewable Energy Laboratory). 2002a. South Table Mountain Facility, Traffic Impact Study . Prepared by Felsburg Holt and Ullevig (F HU). FHU Reference No. 02-150. November.

NREL (National Renewable Energy Laboratory). 2002b. Vegetation Survey, NREL South Table Mountain Site . Prepared by Plantae Consulting Services, Boulder, CO. June.

NREL (National Renewable Energy Laboratory). 2005. Wildlife Survey (Including Migratory Birds and Raptors) at the National Renewable Energy Laboratory South Table Mountain Site Golden, Colorado . Prepared by Science Applications Inte rnational Corporation. June 2005.

NREL (National Renewable Energy Laboratory). 2006. Spill Prevention Control and Countermeasures for the South Table Mountain Site (Procedure No. 6-2.10). June.

NREL (National Renewable Energy Laboratory). 2007 a. “Draft Update South Table Mountain Facility, Traffic Impact Study.” Prepared by Felsburg Holt and Ullevig (FHU). FHU Reference No.

NREL (National Renewable Energy Laboratory). 20 07b. Letter of transmittal for the Air Pollution Emission Notice (APEN) and permit application pack age for the proposed RFHP with the Colorado Department of Public Health a nd Environment, March 16, 2007.

Rhodes, Lori. 2006. Camp George West Level II Historic American Building Survey/Historic American Engineering Record (HABS/HAER) Documentation

.
Rhodes, Lori. 2007. Class III Cultural Resources Inventory of the Proposed Renewable Fuel Heating Plant, Solar Technology Advancement Consortium, and Solar Electric Generation Project on the NREL STM site, Jefferson County, Colorado . Limited-Results Cultural Resources Survey Form.

TRB (Transportation Research Board). 2000. Highway Capacity Manual , third edition.

Trinity Consultants. 2006. On-Site Impact Assessment of Proposed Renewable Fuel Heating Plant Ameresco, NREL, Golden, Colorado

. U.S. Fish and Wildlife Service (USFWS). 2004. “Federally Listed and Proposed, Endangered, Threatened, Experimental, and Candidate Species and Habitat in Colorado by County.” Updated August 2004. Available at: http://mountain-prai rie.fws.gov/endspp/CountyLists/COLORADO.htm. Accessed April 13, 2005.

Ward, D.E., and C.C. Hardy. 1991. “Smoke emissions from wildland fires.” Environment International 17 (1991), pp. 117–134.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

A-1 APPENDIX A SCOPING LETTERFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

A-2Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

A-3Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

A-4Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

A-5Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

A-6Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

A-7Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

A-8Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

A-9Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

B-1 APPENDIX B SCOPING LETTER DISTRIBUTION LISTS

DOE mailed the scoping letter shown in Appendix A to the businesses, agencies, and organizations shown in the following mailing list. In addition, DOE mailed the scoping letter to all known Pleasant View residential addresses. The residentia l mailing list consisted of 1,470 addresses.

4-U Mini Mart 15750 S. Golden Rd. Golden, CO 80401 7-Eleven 16400 S. Golden Rd. Golden, CO 80401 Absolute Tatoo 15750 S. Golden Rd. Golden, CO 80401

AC Transmission 15435 W. Colfax Ave Golden, CO 80401 Ace Liquor Store 16265 S. Golden Rd. Golden, CO 80401 Adolph Coors Company 1819 Denver West Drive Golden, CO 80401

Advantage Appraisals Inc. 795 McIntyre St. Golden, CO 80401 AMS 10433 Denver West Parkway Golden, CO 80401 Anderson Services 1125 Quaker St. Golden, CO 80401

Back Talk System 14998 W. 6th Ave., 500 Golden, CO 80401 Barnes & Noble 14371 W. Colfax Ave. Golden, CO 80401 Bed Bath & Beyond 14275 W. Colfax Ave. Golden, CO 80401

Bilg's Delicatessen 16400 S. Golden Rd. Golden, CO 80401 Bldg. 3 15850 W. 6th Ave Golden, CO 80401 Bobcat of the Rockies 15680 W. 6th Ave. Golden, CO 80401

Boston Market, Inc. 14103 Denver West Parkway Golden, CO 80401 Environmental Compliance Office Bureau of Land Management 2850 Younfield Street Lakewood, CO 80215 Calvary Baptist Church 17050 S. Golden Rd. Golden, CO 80401

Howard Roitman CDPHE Office of Environmental Programs 4300 Cherry Creek Drive, South Denver, CO 80246 Margie Perkins, Division Director CDPHE Air Pollution Control Division 4300 Cherry Creek Drive, South Denver, CO 80246-1530 Steve Gunderson, Division Director CDPHE Water Quality Control Division 4300 Cherry Creek Drive, South Denver, CO 80246-1530

Centennial Equipment Co. 15760 W. 6th Ave Golden, CO 80401 Christy Sports 14371 W. Colfax Ave. Golden, CO 80401 Mr. Vince Auriemma City of Golden Golden Public Works Office 1445 10th Street Golden, CO 80401

Ms. Katie Fendel City of Golden Golden Public Works Office 911 10th Street Golden, CO 80401 Ms. Pamela Sheldon City of Lakewood Planning Department 455 S. Allison Parkway Lakewood, CO 80226 Classic Log Homes 15740 W 6th Ave. Golden, CO 80401Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

B-2

CMC Challenge-Mfg-Consult 15744 W 6th Ave Golden, CO 80401 Coleman Coporation Dept. 586 (Real Estate) PO Box 2931 Wichita, KS 67201 Colorado Business Bank 15710 W. Colfax Ave. Golden, CO 80401

Colorado Concrete & Pottery 16601 S. Golden Rd. Golden, CO 80401 Dr. Dana L. Winkelman, Director Colorado Coop Fish & Wildlife Research Unit 201 JVK Wagar Building CSU Campus Delivery 1484 Fort Collins, CO 80523-148 Mr. Jim Miller Colorado Department of Agriculture Dir. Of Policy & Communication 700 Kipling Street, Suite 4000 Lakewood, CO 80215

Ms. Linda Coulter Colorado Department of Agriculture 700 Kipling Street, Suite 4000 Lakewood, CO 80215 Mr. Curt Eckhart Colorado Department of Transportation, Region 6 Office 2000 South Holly Street Denver, CO 80222 Colorado Dept. of Natural Resources Executive Director's Office 1313 Sherman Street, Room 718 Denver, CO 80203

Colorado Dept. of Public Health & Environment Haz. Materials & Waste Mgmt Div. 4300 Cherry Creek Drive, South Denver, CO 80246-1530 Mr. Gerald Craig Colorado Division of Wildlife State Raptor Biologist 317 Prospect Road Fort Collins, CO 80526 Mr. Perry Olson Colorado Division of Wildlife 6060 Broadway Denver, CO 80216

Colorado Environmental Coalition, Inc. 1536 Wynkoop Denver, CO 80202 Mr. Lew Ladwig Colorado Geological Survey 1313 Sherman Street, Rm 715 Denver, CO 80203 Management and Conservation Colorado Office of Energy 225 E. 16th Ave, Suite 650 Denver, CO 80203

Colorado State Board of Land Communication 1313 Sherman Street, Rm 620 Denver, CO 80203 Mr. Bruce Colter Colorado State Forest Service Golden District Office 1504 Quaker Street Golden, CO 80401-2956 Colorado State Patrol 1096 McIntyre St. Golden, CO 80401

Ms. Rebecca Vickers Colorado Transporation Dept. Empire Park Environmental Services 4201 E. Arkansas Ave. Denver, CO 80222 Columbine Café 15630 S. Golden Rd. Golden, CO 80401 Communication Industries, Ind 785 McIntyre St. Golden, CO 80401

Mr. Walter S. Welton, President Consolidated Mutual Water Company 12700 W. 27th Ave. Lakewood, CO 80215 CSI Hobby Greenhouses 15850 W. Colfax Ave. Golden, CO 80401 Custer & Steinmates 622 Gardenia Ct. Golden, CO 80401

DAVCO Motors 795 McIntyre St. Golden, CO 80401 Day's Inn Motel 15059 W. Colfax Ave. Golden, CO 80401 DDRC Maintenance Terminal 16611 S. Golden Rd. Golden, CO 80401Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

B-3

Delux Towing 16305 S. Golden Rd. Golden, CO 80401 Denver Biomaterials Inc 14998 W. 6th Ave., 700 Golden, CO 80401 Mr. Greg Stevinson Denver West Ltd. 1546 Cole Blvd Golden, CO 80401

Ms. Valerie Farnham Denver West Ltd. 1546 Cole Blvd Golden, CO 80401 Mr. Terry McKee, Omaha District Dept. of Army, Corps of Engineers 9307 State Highway 121 Littleon, CO 80123 Mr. Hal Simpson Division of Water Resources 1313 Sherman St., Rm 818 Denver, CO 80203

DOC 15000 W. 6th Ave., 102 Golden, CO 80401 Dolls Anonymous 16399 S. Golden Rd., Unit C Golden, CO 80401 EAP Glass 616 Moss St. Golden, CO 80401

Eggers Lapidary 16950 S. Golden Rd. Golden, CO 80401 Einstein Bagel Company 14103 Denver West Parkway #100 Golden, CO 80401 Einstein Bros. Bagels 14401 W. Colfax Ave. Golden, CO 80401

El Amigo Restaurant 16399 S. Golden Rd., Unit D Golden, CO 80401 El Senor Sol 15900 W. Colfax Ave. Golden, CO 80401 Energy West Controls 14828 W. 6th Ave. Golden, CO 80401

Enstroms Candies 14415 W. Colfax Ave. Golden, CO 80401 Enterprise Car Rental 885 Lupine St. A Golden, CO 80401 Ms. Christine Shaver Environmental Defense Fund, Inc. Rocky Mountain Office 2334 North Broadway Boulder, CO 80304

Mr. Wes Wilson EPA Region VII NEPA Compliance, 8WMEA 999 18th Street Denver, CO 80202-2466 Evergreen Appraisals 622 Gardenia Ct. Golden, CO 80401 Northwest Mountain Office Federal Aviation Administration 1601 Lind Avenue SW Renton, WA 98055-4056

Five R Repair 15590 W. Colfax Ave. Golden, CO 80401 Foothills Chiropractic Health Center 16135 S. Golden Rd. Golden, CO 80401 Foreign Car Service 16289 W. Colfax Ave. Golden, CO 80401

Francis Veterinary 16199 S. Golden Rd. Golden, CO 80401 Ms. Doris DePenning Friends of the Foothills 9285 Blue Mountain Dr. Golden, CO 80403 Ms. Nancy Hollinger Friends of the Foothills 9184 Fern Way Golden, CO 80402

Glasscraft, Inc. 626 Moss St. Golden, CO 80401 God's Place 16399 S. Golden Rd., Unit G Golden, CO 80401 Golden Auto Parts 16948 S. Golden Rd. Golden, CO 80401Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

B-4

Mr. Allen Gallamore Golden District Forester Golden District Office 1504 Quaker Street Golden, CO 80401-2956 Golden Gate Parts 15990 S. Golden Rd. Golden, CO 80401 Mr. Steve Glueck, Director Golden Planning & Development Department 1455 10th Street Golden, CO 80401

Gram's Foods 15710 W. 6th Ave., 710 Golden, CO 80401 Holiday Inn West Village 14707 W. Colfax Ave. Golden, CO 80401 Hops 14285 W. Colfax Ave. Golden, CO 80401

Horizon Foods 16305 S. Golden Rd. Golden, CO 80401 Intermountain Marketing 15000 W. 6th Ave., 200 Golden, CO 80401 Islamic Center of Golden 16199 S. Golden Rd. Golden, CO 80401

J. F. Hurlbut Co. 622 Gardenia Ct. Golden, CO 80401 Jamba Juice 14237 W. Colfax Ave. Golden, CO 80401 Jeffco Open Space Foundation, Inc. 5855 Wadsworth Bypass Building A, Suite 100 Arvada, CO 80003

Mr. Bud Smead, Director Jefferson County Public Works Div. 1700 Arapahoe Street Golden, CO 80419 C/O John Litz Jefferson County Colorado Citzens for Planned Growth and Open Space 11010 W. 29th Avenue Lakewood, CO 80215-7120 Ms. Nanette Neelon Jefferson County Special Projects Coordinator 100 Jefferson County Pkwy Golden, CO 80419-3500

Randy B. Holman Jefferson County Assessor's Office 100 Jefferson County Parkway, Suite 3550 Golden, CO 80419 Jefferson County Highways and Transporation 100 Jefferson County Pkwy, Ste. 3500 Golden, CO 80419 Jefferson County Department of Health Environmental Health Division 260 South Kipling Street Lakewood, CO 80226

Mr. Terry Green Jefferson County Emergency Preparedness 100 Jefferson County Pkwy, Suite 4570 Golden, CO 80419 Joy Lucisano Jefferson County Open Space Acquisitions Specialist 100 Jefferson County Parkway Golden, CO 80419 Mr. Randy Frank Jefferson County Open Space 700 Jefferson County Pkwy, Ste. 100 Golden, CO 80419

Jefferson County Open Space Assistant County Attorney 100 Jefferson County Pkwy Golden, CO 80419 Mr. David Field Jefferson County Planning & Zoning Office 100 Jefferson County Parkway Ste. 3550 Golden, CO 80419 Mr. Preston Gibson, AICP Jefferson County Planning & Zoning Office Planning and Engineering Mgr 100 Jefferson County Pkwy, Suite. 3550 Golden, CO 80419

Ms. Karen Hellner Jefferson County Planning & Zoning Office 7000 Jefferson County Pkwy Suite 3550 Golden, CO 80419 Jefferson County Public Schools 1829 Denver West Drive Golden, CO 80401 Mr. Ronald Beckham Jefferson County Sheriff 17900 W. 10th Ave. Golden, CO 80401-2679Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

B-5

JGS Contractors, Inc. 855 Lupine St. Golden, CO 80401 Junction Texaco 15065 W. Colfax Ave. Golden, CO 80401 K&P Inc. 777 Nile St. Golden, CO 80401

K.E.M. Printing 16250 S. Golden Rd. Golden, CO 80401 Key Bank 14417 W. Colfax Ave. Golden, CO 80401 Mr. Eric Blank Land & Water Fund of the Rockies 2260 Baseline Road, Suite 200 Boulder, CO 80302

Lawson Pain and Body 910 McIntyre St. Golden, CO 80401 Le Peep 14401 W. Colfax Ave. Golden, CO 80401 Leep'in Lizard SAAB 605 Lupine St. Golden, CO 80401

Mac Vik Plumbing & Heating 16190 S. Golden Rd. Golden, CO 80401 Macaroni Grill 14245 W. Colfax Ave. Golden, CO 80401 Majestic Ventures 16500 S. Golden Rd. Golden, CO 80401

Mannie and Bo's Pizzeria 16399 S. Golden Rd., Unit E Golden, CO 80401 McKee Construction Co. 795 McIntyre St. Golden, CO 80401 Method Machine Tools, Inc. 14998 W. 6th Ave. Golden, CO 80401

Mr. Dale Lauer, Board of Directors Metro Sanitation District 952 Moss Street Golden, CO 80401 Rue Eich Metro Wastewater Reclamation District 6450 York Street Denver, CO Mier's Deli 15750 S. Golden Rd. Golden, CO 80401

Mile Hi Chem Dry 15970 S. Golden Rd. Golden, CO 80401 Mimi's Café 14265 W. Colfax Ave. Golden, CO 80401 MLL General Contractors 665 Moss St. Golden, CO 80401

Mobile Mechanic at the Shop 15810 W. Colfax Ave. Golden, CO 80401 Mountain View Laundromat & Dry Cleaner 15940 S Golden Rd. Golden, CO 80401 Mountain View Motel 14825 W. Colfax Ave. Golden, CO 80401

Mountain View Trailer Village 16100 S. Golden Rd. Golden, CO 80401 Mr. Handyman 622 Gardenia Ct. Golden, CO 80401 National Wildlife Federation 2260 Baseline Road Boulder, CO 80302

Nationwide Storage 16845 Mt. Vernon Rd. Golden, CO 80401 Native Nursery - Tom Gillian 17025 S. Golden Rd. Golden, CO 80401 Ronald Wopsock & Roland McCook Northern Ute Indian Tribe PO Box 190 Ft. Duchesene, UT 84026

Oasis Denver West Apt Homes 1910 Denver West Drive Golden, CO 80401 Office Max 14275 W. Colfax Ave. Golden, CO 80401 Office of Representative Bob Beauprez 4251 Kipling St., Ste. 370 Wheat Ridge, CO 80033Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

B-6

Office of Representative Mark Udall 8601 Turnpike Drive #206 Westminster, CO 80031 Office of Senator Ken Salazar 2300 15th St., Ste. 450 Denver, CO 80202 Ms. Kristine Pollard Office of Senator Wayne Allard 7340 E. Caley, Suite 215 Englewood, CO 80111

Old Golden Discount Liquors 15750 S. Golden Rd. Golden, CO 80401 Old Navy 14367 W. Colfax Ave. Golden, CO 80401 On the Border 14225 W. Colfax Ave. Golden, CO 80401

Outback Steakhouse 14295 W. Colfax Ave. Golden, CO 80401 Peregrine Communications Inc. 14818 W. 6th Ave., 15A Golden, CO 80401 Perfection Tool Repair 16200 S. Golden Rd. Golden, CO 80401

Performance Plus Auto Care 16099 S. Golden Rd. Golden, CO 80401 Planet Honda 15601 W. Colfax Ave. Golden, CO 80401 Pleasant View Beauty Salon 15940 S Golden Rd. Golden, CO 80401

Mr. Branden Baalman, Chief Pleasant View Fire Department 955 Moss Street Golden, CO 80401 Stewart McCallister, District Coordinator Pleasant View Metro District 955 Moss Street Golden, CO 80401 Mr. David Councilman Pleasant View Water & Sanitation District 955 Moss Street Golden, CO 80401

Pompoms & Whiskers Grooming 940 McIntyre St. Golden, CO 80401 Porter Design 15750 S. Golden Rd., Unit G Golden, CO 80401 Procard, Inc. 1819 Denver West Drive Golden, CO 80401

Puttin Parts 16185 S. Golden Rd. Golden, CO 80401 Quiznos 14413 W. Colfax Ave. Golden, CO 80401 Ramstetter Excavating 16599 S. Golden Rd. Golden, CO 80401

Ranniger Systems, Inc. 795 McIntyre St. Golden, CO 80401 Reasonable Auto Service 15735 S. Golden Rd. Golden, CO 80401 Regal Mortgage 795 McIntyre St. Golden, CO 80401

Richards Agency 622 Gardenia Ct. Golden, CO 80401 Rock Rest 16005 Mt. Vernon Rd. Golden, CO 80401 Mr. David Abelson Rocky Flats Coalition of Local Government 8461 Turnpike Dr. Westminster, CO 80031

Roofing Services 15985 S. Golden Rd., Unit F Golden, CO 80401 Rose Cleaners 14407 W. Colfax Ave. Golden, CO 80401 Save the Mesas/Citzens Involved in the NW Quadrant PO Box 16551 Golden, CO 80402-6009

Secor 14998 W. 6th Ave., 800 Golden, CO 80401 Sid's Auto Service 16305 S. Golden Rd. Golden, CO 80401 Ms. Maggie Fox, Southwest Office Sierra Club 2260 Baseline Road, Suite 105 Boulder, CO 80302Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

B-7

Simplex 14998 W. 6th Ave., 600 Golden, CO 80401 Sinclair Service Station 15495 W. Colfax Ave. Golden, CO 80401 Ecological Science Dept. Soil Conservation Service 655 Parfet Street, Rm E20C Lakewood, CO 80215

Clement Frost, Tribal Leader Southern Ute Tribe PO Box 737 Ingacio, CO 81137 Edna Frost, Director Southern Ute Tribe Tribal Information Services PO Box 737 Ingacio, CO 81137 Mr. & Mrs Alden Naranjo Southern Ute Tribe Ute Language & Culture Committee PO Box 737 Ingacio, CO 81137

Mr. Leonard C. Burch, Chairman Southern Ute Tribe Ute Language & Culture Committee PO Box 737 Ingacio, CO 81137 Mr. Neil Cloud Southern Ute Tribe NAGPRA Coordinator PO Box 737 Igacio, CO 81137 Sports Rack Vehicle Outfitter 15600 W. Colfax Ave. Golden, CO 80401

Mr. Jim Green State Historic Pres. Office 1300 Broadway Denver, CO 80203 Govenor Bill Owens State of Colorado 136 State Capital Denver, CO 80203 Stevinson Chevrolet 14700 W. Colfax Ave. Golden, CO 80401

Stevinson Lexus 801 Indiana Street Golden, CO 80401 Stevinson Toyota 15000 W. Colfax Ave. Golden, CO 80401 Table Mountain Conservation Fund PO Box 16201 Golden, CO 80402-6004

Telecommunications Products, Inc. 795 McIntyre St. Golden, CO 80401 Telescope Engineering 15730 W. 6th Ave. Golden, CO 80401 The Salon 14235 W. Colfax Ave. Golden, CO 80401

Tokyo Joes 14227 W. Colfax Ave. Golden, CO 80401 Dr. Kenneth R. Wilson U.S. Department Interior Fish & Wildlife Service Colorado Field Supervisor 755 Parfet St., Rm 361 Lakewood, CO 80215 Eugene H. Backhaus U.S. Department of Agriculture District Conservationist 655 Parfet Street, Room E-300 Lakewood, CO 80215-5517

Mr. Gary Finstad U.S. Department of Agriculture Natural Resource Conservation Service - Metro Office 655 Parfet Street, Rm E-300 Lakewood, CO 80215-5517 Mr. Andrew Archuleta U.S. Fish and Wildlife Service Colorado Field Office PO Box 25486-DFC Denver, CO 80225-0207 UA 14225 W. Colfax Ave. Golden, CO 80401

U-Haul 15500 W. Colfax Ave. Golden, CO 80401 Betsy Chapoose Uinta and Ouray Ute Tribal Business Council PO Box 190 Ft. Duchesene, UT 84026 Ultimate Electronics 14275 W. Colfax Ave. Golden, CO 80401Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

B-8

Mr. Randy Christiansen United Power # 5 Grouse Dam Rd. Golden, CO 80403 Universal Surface Counter Tops 15866 W. 7th Ave., C&D Golden, CO 80401 Mr. Gregory Davis US EPA Mailcode: EPR-EP 999 18th Street, Suite 500 Denver, CO 80202

Ms. Carol Campbell US EPA - Region VIII Director Ecosystem Protection 999 18th Street, Suite 500 Denver, CO 80202-2405 Mr. Grady Towns US Fish and Wildlife Service Denver Regional Office PO Box 25486 Denver, CO 80225 Mr. Terry Knight, Spiritual Coordinator Ute Mountain Life Tribe PO Box 53 Towaoc, CO 81334

Ms. Judy Knight-Frank, Chairperson Ute Mountain Ute Tribal Council General Delivery Towaoc, CO 81334 VFW Post # 4171 15625 W. 10th Ave. Golden, CO 80401 Videotronix 15000 W. 6th Ave., 102A Golden, CO 80401

Wa La Hair Studio 15750 S. Golden Rd. Golden, CO 80401 Walts Tire Store 15990 S. Golden Rd. Golden, CO 80401 West Metro Fire Protection District 447 S. Allison Parkway Lakewood, CO 80226-3128

West Side Auto Sales 676 Moss St. Golden, CO 80401 Western Roofing 15810 W. 6th Ave Golden, CO 80401 Ms. Belinda Boiko Yenter Companies 20300 W. Highway 72 Arvada, CO 80007

Carl Eiberger 14330 Fairview Lane Golden, CO 80401 Craig Cox 2900 Vance Street Denver, CO 80215 Wilbur between Lodges Oglala Sious Tribe Pine Ridge, SD 57770Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

C-1 APPENDIX C RESPONSES RECEIVED TO SCOPING LETTERFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

C-2Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

C-3Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

C-4Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

C-5Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

C-6Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

C-7Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

D-1 APPENDIX D RESPONSES TO COMMENTS ON THE DRAFT EA

Comment: I imagine this proposal will stir up a lot of controversy, as the Mesas seem to be quite protected by the residents of Golden. I believe the NREL mission is critical and will only benefit the city, the state, the nation and the planet. NREL is trying to lead by example and lower their own footprint, all while they continue to further research of renewable energies for the nation and the planet. This is much bigger, and in my opinion a worthy sacrifice, of a few hundred acres on top of one of our Mesas; especially if done in a respectful and courteous manner to the residents of Golden.

Response: DOE appreciates the support for the mission and goals of NREL expressed by the comment. Both the beneficial aspects of the propo sed actions and the visual impacts that might affect some members of the public have been id entified in this EA. While the commenter also expressed that even as much as hundreds acres of development on the mesa top would be acceptable, DOE notes that the proposed devel opment on the mesa top addressed in this EA would be limited to 5 acres, and based on the vi sual simulations, such development would not result in significant visual impacts.

Comment: I am a resident of Golden and have also spent some time walking around South Table Mountain. There are two significant prehistoric sites in the general vicinity of NREL that I don't think are on federal lands but I'm not exactly sure where th e boundaries are for the various land owners. I'm also very interested in the CCC amphitheater a nd if there are any plans for that area.

Response: Communications between DOE and the comment er have determined that the cultural resource sites are not located in or near the proposed project area and would not be impacted by the proposed actions.

Comment: It is questionable if this project suppor ts the NREL mission such as “advancing and contributing to commercialization of renewable energy technologies.”

Response: The RFHP advances and contributes to the commercialization of this renewable energy technology by demonstrating its technical viability, specifically in this geographic region and at altitude; demonstrating its financial viability, importantly through a private-sector financing mechanism, Energy Savings Performance Contracting (ESPC); and supporting a major NREL sustainability project that provides first-hand commercialization experience to NREL deployment and R&D personnel that can be transferred to DOE/NREL customers.

Comment: It appears the manufacturer will obtain opera ting data from NREL to improve its products, possibly advancing a renewable energy technology. If th at is the case, is the manufacturer entering into a cost sharing arrangement with NREL, as is typically done with research partners having technology aligned with the NREL mission? Additionally, the RF HP has been proposed as a capital project for at least the last five years, and after going through the formal evaluation process it always fell off the list of funded projects.

Response: There are no cost-sharing requirements in the DOE ESPC that would finance the proposed RFHP. The RFHP is not funded by NREL appropriations. Under an ESPC, the contractor is required to provide all capital equipment and is responsible for all maintenance, repair, replacement and operations, including long-term wood fuel supply. The contractor is paid from the energy cost savings realized from the project.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

D-2 Comment: The EA states that the RFHP will have a 10- to 30-year operating lifetime. This appears rather broad and vague, with recognition that it may be the b est data available for this technology. Of greater concern is that the EA does not state what the RFHP will cost, or what the pay-back period will be.

Response: Various components of the RFHP have 10- to 30-year life ranges; the contract term with the Energy Savings Company (ESCO) is 24 years, and the contract covers replacement (by the ESCO) of any component with less than a 24-year expected life. While the Department certainly considers life cycle costs in its deci sion-making, the National Environmental Policy Act (NEPA) requires that a federal agency iden tify in an appropriate NEPA document the environmental impacts of its proposed actions be fore determining a course of action. “For the purposes of complying with the Act, the weighing of the merits and drawbacks of the various alternatives need not be displayed in a mone tary cost-benefit analysis ...” (40 CFR 1502.23).

Comment: The EA references documents that provide more detail on the exact location, but it does not indicate if or where these documents are available for review.

Response: DOE standard practice is to maintain all reference documents in the project administrative record; references are available for review upon request.

Comment: The EA frequently states that the RFHP will be sited “at the edge of a natural drainage.” Given the size of the RFHP and related paved areas, and the size of the natural drainage, it appears that the impact will be significant. Clarification of the ex act impact on the natural drainage appears necessary.

Response: DOE has added another figure to the EA clarifying the exact location of the RFHP and associated turnaround area (Figure 2-2). The po tential impacts to the drainage area resulting from the RFHP and turnaround area are discussed in Section 3.1.7.2 of the EA.

Comment: Whether or not the natural drainage between the FTLB and the SERF qualified as a wetland or other type of protected area was always a point of concern for SERI and NREL. It was always my understanding that any wetlands were artificial, creat ed by development of the STM site, and therefore not protected. Technically it is only a drainage ditch, and the only requirement is that it be capable of draining.

Response: The designation of the arroyo as a drainage way is correct. This drainage has no areas of designated wetlands that would require special permitting for construction. As discussed in the STM Site-wide EA (DOE/EA #1440), the USACE dete rmined in 1997 that the drainage is not considered a water of the United States. NREL’ s 2002 Vegetation Survey Report – South Table Mountain (June 29, 2002) identifies four sma ll plant communities that supported wetland-type plants; these areas would not be affected by th e Proposed Action. The vegetation study classifies the plant community within the dr ainages as ravine shrubland.

Comment: As part of its environmental best-managem ent approach, as previously mentioned, NREL intentionally did not build on or across the drainage in the past. This accounts for the distance between the FTLB and SERF and the fact that separate utility spines are maintained on either side of the drainage.

Response: NREL has had a culvert and service road ove r the drainage since the SERF was built. The existing culvert may be extended and two co ttonwood trees would be destroyed, relocated, or replaced. The new utility spines would be located over the culvert. The building would not extend into the drainage.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

D-3 Comment: The location of the RFHP is contrary to site development concepts previously espoused and represents a change in NREL’s approach (if not actual policy) toward utilization of the site and voluntary protection of valued natural features. NREL site development planning looking out at least 25 years envisioned the area around the FTLB, SERF and S& TF as being a campus environment that would promote group interactions in indoor and outdoor settings. Placement of a boiler facility in the middle of this campus, along with access roads and heavy trucks delivering wood supplies, does not support such a collegial environment and have the appearance of a “wa ll,” that is, a continuous string of buildings along the base of South Table Mountain.

Response: The proposed location is a compromise between ideal environmental aspects of site development and the need for operational efficien cy and effectiveness adjacent to the central utility plant. NREL site development planning co ntinues to “envision the area around the FTLB, SERF, and S&TF as being a campus environment that would promote group interactions in indoor and outdoor settings.” The RFHP is located at the northern edge of the buildable portion of the site, where there are no current or planned am enity areas (trails, outdoor seating, etc) for staff interaction. The staff interaction areas are signifi cantly farther down the arroyo and should not be impacted by the location of the RFHP. As discu ssed in Section 3.1.4.2 of the EA, the RFHP would be blocked from view by the FTLB from most off-site observational viewpoints.

Comment: The EA states that plume modeling established that no adverse health effects will be presented to persons in other facilities by the RFHP stack emissions. This “minimum requirement” analysis addresses standards established by OSHA and ACGIH, but does not comment on possible reentrainment of odors into the SERF and S&TF ventilation systems.

Response: DOE and NREL have taken the issue of re-entrainment into consideration in preliminary design of the facility’s stack hei ght and will include design requirements in its contractual agreement with the ESCO.

Comment: The EA describes higher odor levels during star t-up and shut-down of the RFHP, but there is no mention at all about specific odor levels during steady-state operation.

Response: The RFHP will have dual combustion chambe rs – the primary combustion chamber is fired at up to 1,800 ° F, and secondary chamber is fired at 3,100 ° F – resulting in complete combustion. NREL has held discussions with four operators of similarly sized wood-fired boilers, including visiting one operation in person. In each case, the operators indicated that there were no odors during steady-state operation. Experience from other operators of similar systems has also shown that there are no noticeable odors.

Comment: The EA does not address whether the necessary fu el supply will be available for either the operating-life or the pay-back period of the RFHP. Ther e is also no mention of the embedded energy costs of transporting the waste wood, such as how far away will it be coming from, will those distances increase over time, and what will the effects of higher truck fuel costs be.

Response: The ESPC requires that the ESCO remain responsible for wood fuel supply for the entire term of the contract. The ESCO has identif ied a local provider for wood-waste fuel for the RFHP. The supplier has been in business for 32 years, is located less than 16 kilometers (10 miles) from NREL, has multiple local sources of wood-waste, and can guarantee the monthly and annual supply needed to meet the minor load of the RFHP.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

D-4 Comment: The commenter expressed concern that there would be a significant increase in CO 2 emissions that would be realized over the use of natural gas. Regardless of the “net” CO 2 argument that the EA presents around wood versus natural gas, the fact remains that an increase is an increase.

Response: There would be an increase in absolute qu antity: 2,941 tons/year (natural gas) vs. 5,297 tons/year (4,544 wood and 753 natural gas) . This increase of 2,356 tons represents an increase of less than 8 percent in the overall laboratory CO 2 footprint (30,067 tons, FY06). Further, as shown on Table 3-3, from a Maximum Predicted Impact to Health-Based Standards perspective, the RFHP emissions (8-hour average (micrograms/m 3 ) of 240,000 vs. the 9,000,000 health standard is not significant. NREL’s policy on CO 2 is to be “carbon neutral.” It is also appropriately NREL’s policy to maximize the use of on-site renewable energy. To this end, the Renewable Fuel Heating Plant (RFHP) is expected to reduce laboratory natural gas (fossil fuel) use by a significant 75 percent at the South Ta ble Mountain site. By accepted EPA national standards (EPA-AP42), the combustion of biomass (wood) waste at facilities such as the RFHP is considered to be CO 2 “net neutral.” That is, the same amount of CO 2 is released during combustion of the biomass waste as was sequestered during its relatively recent growth cycle. The combustion of natural gas is considered to release “new” carbon into the atmosphere. Even though combustion of biomass waste is considered to be CO 2 “net neutral,” NREL will purchase renewable energy credits (RECs) to offset all CO 2 produced by the RFHP.

Comment: The EA compares the RFHP CO 2 emissions with combustion of an equivalent mass of wood using a forest fire model. That comparison erroneously assumes that any wood waste not used at the RFHP will be subject to open burning with CO 2 emissions equal to or greater than the RFHP. Likewise, estimates of methane generated by landfilling or natural degradation assu me a single, all-consuming end for the waste wood. A more accurate model is needed.

Response: The comparative analyses provided in the EA were based on a technical review of the available literature. This revi ew found “open burning” and “la ndfilling/natural degradation” as the best available and quantified alte rnatives for comparison to combustion. Other alternatives such as open decomposition could not be quantifia bly compared based on the available scientific literature. The analyses were included to provide the reader and the decision-makers with additional means of comparing among alternatives but in no way assumed that these would be the only alternative pathways for wood waste not used by the RFHP.

Comment: It has come to my attention that the plan to build the RFHP was critical to a LEED [Leadership in Energy and Environmental Design] Pl atinum rating being awarded to the S&TF [Science and Technology Facility]. This commitment by the op erating contractor may make construction of the RFHP a foregone conclusion, and any EA comments submitted by myself and others become moot.

Response: The S&TF LEED Platinum rating was achiev ed in part through NREL’s commitment to a renewable heating source for the building. In the event the RFHP is not constructed and operated, NREL could retain the platinum rati ng as long as an equivalent amount of renewable energy were installed on the building. For exampl e, NREL could use PV to meet the requirement instead of heat generated through the RFHP. NR EL’s commitment to use of renewable energy through the LEED application process in no way represents a foregone commitment to the RFHP; other renewable heat sources could be considered through existing review mechanisms, including NEPA.Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

E-1 APPENDIX E DRAFT RFHP CONSTRUCTION PERMITFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

E-2Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

E-3Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

E-4Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

E-5Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

E-6Final Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

3Figure 1-1. Regional Location of the STM SiteFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

4Figure 1-2. Local Setting of the STM SiteFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

8Figure 2-1. STM and the Relative Locations of the Three Proposed Projects on the SiteFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

9Figure 2-2. Site Layout of the RFHPFinal Environmental Assessment of Three Site Development Projects at the National Renewable Energy Laboratory South Table Mountain Site

16Source: DOE, 2003, Figure 2-1Figure 3-1. Site Development Zones andProposed Improvements at the STM Site.