University of Minnesota  Administrative Policy

Environmental Protection

Policy Statement

University activities and facilities significantly impact land, air, water, other natural resources, and public health. The University is committed to the protection of these resources in all its activities and at all stages of acquisition, design, development, and operation of its campus facilities.


Faculty, staff, and students must protect the environment by:

  • Planning activities to minimize the amount of waste produced and resources used.
  • Conserving aquatic resources.
  • Reusing and recycling materials whenever possible, by using existing campus programs.
  • Using established programs for proper disposal of hazardous materials. Disposal of any laboratory or maintenance chemicals through the trash or sanitary sewer system without advance notice and written approval by the Department of Environmental Health and Safety (DEHS) is prohibited.
  • Protecting soil, surface water, and groundwater from contamination.
  • Reporting chemical spills immediately.

Anyone discovering a spill of what they believe is a hazardous material must report the spill by dialing 9-1-1. This will ensure that the appropriate authorities are notified.

Faculty, staff and students must comply with environmental laws and regulations . If a faculty, staff, or student is cited for violating a law or regulation, their unit is responsible for the resulting fines or penalties.


Acquisition and Development. Planning, Space, and Real Estate (PSRE), for acquisitions of new sites, and Capital Project Management (CPM) and U Construction, for development of existing sites, must incorporate into their transactions and projects the review of the environmental impacts from hazardous substances and the cleanup of identified pollution to levels appropriate for planned uses of the site.

Design. The design team must ensure that facility plans minimize the environmental impacts of building and equipment and meet environmental standards in time for agency permit review.

Construction. Project managers and contractors must ensure that construction and renovation of facilities is done in a manner that protects the waters of the State, minimizes waste, and mitigates discovered environmental contamination.

Maintenance and Operations. Facilities managers must operate building systems and control equipment to meet design requirements; review practices and infrastructure systems so that sewer systems are separate and dedicated to either storm water or sanitary effluent and provide information for reports to environmental agencies.

Reason for Policy

This policy and its related procedures implement the environmental commitments of Board of Regents Policy: Sustainability and Energy Efficiency (PDF), and to ensure compliance with all local, state, and federal environmental regulations. 


Primary ContactAdam Krajicek612-626-1590[email protected]
Utilities EngineeringCathy Abene612-626-3547[email protected]
Crookston (DEHS)Kimberly Jenkins612-626-6002[email protected]
Duluth (DEHS)EHSO Main Office218-726-7139[email protected]
Morris (DEHS)Amanda Hyett-Ringgenberg320-589-6106[email protected]
Rochester (Facilities)Main Office612-626-6002[email protected]
Twin Cities (DEHS)Main Office612-626-6002[email protected]
Responsible Individuals
Responsible Officer Policy Owner Primary Contact
  • Assistant Vice President for Health, Safety, and Risk Management
  • Assistant Vice President for Health, Safety, and Risk Management
  • Adam Krajicek
    Director, Environmental Health & Safety


Best Management Practices (BMPs)

BMPs prevent or reduce the pollution of the waters of the state. BMPs include schedules of activities, prohibitions of practices, water treatment, special operating procedures, and other practices that control site runoff, spillage, or drainage from outdoor materials storage.

Construction Activity

Construction activity as defined in 40 CFR § 122.26(b). It includes disturbing land to change topography or soil cover. Examples of construction activity include clearing, grading, filling, and excavating. Construction activity includes the disturbance of less than one acre of total land area that is part of a larger common plan of development if the larger common plan will ultimately disturb one acre or more.

Environmental Site Assessment (ESA)

An ESA summarizes property use history and the recognized environmental conditions. The document identifies materials that will need to be abated or further investigated prior to construction, remodeling or demolition. The report includes a Phase 1 ESA and may in addition evaluate the presence of other hazardous materials and environmental conditions. The report may recommend conducting a Phase II investigation or preparing an Environmental Contingency Plan that will contend with potential risks that are likely to be discovered during construction or demolition.

An ESA may include an evaluation of the following hazards:

  • Asbestos
  • Pesticides
  • Heavy metals such as lead and mercury
  • Storage tanks and petroleum
  • Water infiltration and mold
  • Radiation closeout surveys/decontamination
  • Hazardous chemicals
  • Biohazardous agents
  • Regulated refrigerants including chlorofluorocarbons (CFCs) are likely to be discovered during construction or demolition

Hazardous Chemical Waste

If a chemical waste fits any of the categories listed in Federal (EPA 40 CFR 261) or Minnesota (Minnesota Rules Chapter 7045) regulations, it is defined as a hazardous chemical waste by regulation. This includes chemical wastes specifically listed (P-, U-, F-, K- lists) or chemical waste that demonstrates a characteristic of ignitability, corrosivity, reactivity, toxicity, lethality, or contains polychlorinated biphenyls. There are, however, other chemical wastes which have not been defined as hazardous by regulation which should be managed as hazardous chemical waste. These include: carcinogens, reproductive toxins, or any other chemical waste which poses a threat to public health or the environment when disposed of as a non-hazardous waste.

Illegal Discharge.

Any direct or indirect non-storm water discharge to the storm drain system, except as exempted under this policy.

Illicit Connections

An illicit connection is defined as:

  • A surface or subsurface conveyance which allows an illegal discharge to enter the storm drain system. Illegal discharges include sanitary sewage, process wastewater and wash water. Discharges are illegal even if the connection had been previously permitted by a government agency; or
  • Any drain or conveyance connected to the storm drain system which has not been documented in plans, maps or equivalent records and approved by the University.

National Pollutant Discharge Elimination System (NPDES) Storm Water Discharge Permits

General, group and individual storm water discharge permits that regulate facilities defined in federal NPDES regulation pursuant to the Clean Water Act or under state adopted implementation plans as applicable.

Phase I Environmental Site Assessment (Phase I)

This study follows a commercial and customary practice in the United States for conducting an environmental site assessment of a parcel of commercial real estate with respect to the range of contaminants within the scope of Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and petroleum products. The Phase I will meet the requirements of the American Society for Testing and Materials (ASTM) Practice E 1527. These documents will typically be prepared by a QEC for a property that the University is acquiring.

Phase II Environmental Site Assessment (Phase II).

An investigation designed to evaluate the recognized environmental conditions identified in the Phase I ESA. It is intended to provide information regarding the nature and extent of contamination; to assist in making informed business decisions about the property; and satisfy legal requirements for an innocent purchaser defense. The Phase II will meet the requirements of the ASTM Practice E 1528. These documents will typically be prepared by a QEC for a property that the University is acquiring.


Pollutants may include hazardous waste such as pesticide, herbicide, dissolved and particulate metals, paint and varnish, chemical solvent, oil or other automotive fluids. Pollutants also include non-hazardous yard waste, refuse, rubbish, garbage, and litter and residues from building construction such as concrete rinse water. Pollutants include agricultural and animal waste.

Qualified Environmental Consultant (QEC).

The University maintains a list of consultants with expertise in environmental sciences and engineering. Consultants on the list have been prequalified to work on environmental projects at the University.

Recognized Environmental Conditions (REC)

ASTM E1527-13 defines this term as the "presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, ground water, or surface water of the property."

Storm Drain System

Facilities that collect and convey storm water such as roads, gutters, curbs, inlets, piped storm drains, pumping facilities, retention and detention basins, channels, reservoirs. and other drainage structures.

Storm Water

Any runoff from land including snow melt and surface drainage from precipitation.

Storm Water Pollution Prevention Plan (SWPPP)

A plan for stormwater discharge that includes all required content under Part III of the NPDES/SDS Construction Permit MN R100001 and which describes the erosion prevention BMPs, sediment control BMPs and Permanent Stormwater Management Systems that, when implemented, will decrease soil erosion on a parcel of land and decrease off-site nonpoint source pollution.

Voluntary Investigation and Cleanup (VIC)

The MPCA Voluntary Investigation and Cleanup (VIC) Program provides technical assistance and administrative or legal assurances for individuals or businesses seeking to investigate or cleanup contaminated property.


Wetlands are defined as “those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.” (40 CFR 230.3(t)) Due to their dependence on hydrology, wetlands are closely aligned with water resources. Wetlands can be located on the fringes of streams, rivers and lakes.

Wetland Delineation

A wetland delineation report determines the wetland boundary and type by describing the dominant vegetation, hydrology and landscape position. It describes the transition to adjacent upland and the basis for the wetland delineation line. The wetland delineation report must include registered survey information describing boundaries.


Vice President for University Services

Provides resources, support and funding to facilitate the University's compliance with this policy. Reports the University's performance to the Regents on a periodic basis.

Deans, Directors, Department Heads

Holds affected faculty, staff, and students accountable. Promote programs implementing this policy. Responsible for any fines or penalties resulting from their unit's actions.

Department of Environmental Health and Safety (DEHS)

Facilitates compliance with these environmental standards. Represents the University with environmental regulatory agencies. Monitors compliance and promotes a best environmental management practices. Administers a program for the management of hazardous chemical and radioactive wastes.

Facilities Management

Facilitates the University’s Municipal Separate Storm Sewer System Program (MS4) at the Twin Cities and Duluth campuses, which requires the implementation of Best Management Practices as detailed in the campus-specific SWPPP, with the goal of maximizing pollutants to the maximum extent practicable.

Faculty, staff, and students

Conduct activities in a way that protects the environment. Provide information to ensure compliance. Report observed spills.

Additional responsibilities are identified in each of the individual procedures associated with this policy.

Related Information


  • US Environmental Protection Agency (40 CFR Part 50-99)
  • Minnesota Rules, Chapters 7001,7002, 7005,7007,7008,7009,7011,7017,7019


  • US Environmental Protection Agency (40 CFR Part 261-268)
  • Minnesota Rules Chapters 7001,7045,7150,7151


  • US Environmental Protection Agency (40 CFR Part 122-135)
  • Minnesota Rules 7090


  • Clean Water Act 33 U.S.C. Sec. 1251 et seq.
  • Minnesota Statutes Chapter 103A. et seq. Wetland Conservation Act
  • Minnesota Administrative Rules 8420. Wetland Conservation
  • Minnesota Board of Water and Soil Resources:

Environmental Assessment:

  • US Environmental Protection Agency (40 CFR Part 312)
  • Minnesota Pollution Control Agency’s Voluntary Investigation and Cleanup Programs
  • Minnesota Department of Health Rules Residential Lead Abatement Chapter 4761
  • TSCA (15 U.S.C. section 2601 et seq.) Title 1 - Control of Toxic Substances
  • TSCA (15 U.S.C. section 2601 et seq.) Title 2 - Asbestos Hazard Emergency Response



February 2023 - Deleted Storm Water procedure associated with this policy and added Facilities Management definition. The requirements of the deleted procedure are covered in Energy Management's written program.


July 2020 - Comprehensive Review, Minor revisions.

  1. Title change: Environmental Management to Environmental Protection
  2. Includes a new procedure on wetland protection.
  3. Consolidates procedures/appendices.


  4. Simplifies language for the ready and reflects some changes to responsibilities in University Services.


October 2014 - Comprehensive Review, Minor Revision; Expands the definitions section to include terms used in the procedures. Incorporates changes in the procedures to reflect current practice and to better align with the permit requirements (storm water).


November 2008