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University of Minnisota  Administrative Policy

Environmental Management

Responsible University Officer(s):
  • Vice President, University Services
Policy Owner(s):
  • Associate Director - Environmental Health and Safety
Policy contact(s):
  • Adam Krajicek
Date Revised:
Oct 28, 2014
Effective Date:
Nov 1, 2008

Policy Statement

University activities and facilities significantly impact land, air, water, 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 will carry out their responsibilities in a manner protective of the environment by:

  • Planning activities to minimize the amount of waste produced and resources used.
  • Reusing and recycling materials (such as paper, bottles and cans) whenever possible, taking advantage of existing campus programs.
  • Using established programs for proper disposal of hazardous materials. Employees and students are prohibited from disposing 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).
  • Protecting our campus and downstream waters by using storm drains for storm water and clean water only.
  • Protecting the soil and groundwater from chemical releases.

Any faculty, staff or student discovering a spill or other release of what they believe is a hazardous material must report such a release to DEHS. DEHS will promptly manage the release and make the proper notifications to external agencies.

Faculty, staff and students must comply with environmental laws and regulations by using programs established to meet these legal requirements. If a faculty, staff or student  causes a regulatory violation, their unit is responsible for the resulting fines or penalties.


Acquisition and Development. Real Estate, for acquisitions of new sites, and Capital Planning and Project Management (CPPM) 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 to the planned use of the site.

Design. Capital project managers and contractors must ensure that the design process for facilities identifies and addresses the environmental impacts of building and equipment, incorporates controls protective of environment, meets established environmental standards, and provides timely information for review and incorporation into University permits.

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 demolition and construction wastes, fulfills regulatory requirements, and addresses environmental discoveries.

Operations. Facilities managers must operate building systems and control equipment to meet design and regulatory requirements; review practices and infrastructure systems so that sewer systems are separate and dedicated to storm water and sanitary effluent, as appropriate; and provide requisite information to DEHS 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. The policy and the Storm Water Compliance procedure fulfill the Federal and State requirement for the equivalent of a municipal storm water ordinance for compliance with the University’s Municipal Separate Storm Sewer System permit.




Frequently Asked Questions


Policy Contacts
Subject Contact Phone Email
Primary Contact Adam Krajicek 612-626-1590
Crookston (DEHS) Tom Feiro 218-281-8300
Duluth (DEHS) Main Office 218-726-7139
Morris (DEHS) Dean Olsen 320-589-6106
Rochester (Facilities) Jennifer Eirikson 507-258-8423
Twin Cities (DEHS) Main Office 612-626-6002


Best Management Practices (BMPs)
BMPs mean practices to prevent or reduce the pollution of the waters of the state, including schedules of activities, prohibitions of practices, and other management practices including treatment, requirements, operating procedures, and practices to control site runoff, spillage or leaks, sludge, or water disposal or drainage from raw materials storage.
Construction Activity
Construction activity as defined in 40 CFR § 122.26(b)(14)(x) and small construction activity as defined in 40 CFR § 122.26(b)(15). This includes a disturbance to the land that results in a change in topography, existing soil cover (both vegetative and non-vegetative), or existing soil topography that may result in accelerated stormwater runoff, leading to soil erosion and movement of sediment into surface waters or drainage systems. Examples of construction activity may 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 Report
This report provides a summary of previous investigation, property 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 may recommend conducting a Phase II investigation or preparing an Environmental Contingency Plan that will identify the unknowns and the potential risks that may present and will need to be abated during construction or demolition if discovered.
Facilities Condition Assessment (FCA) Database.
Facilities Management maintains a database on a wide range of facility related equipment and systems. For some locations this includes summaries of asbestos and lead assessments in University buildings. This may include an estimated cost for abatement.
Hazardous Waste
Waste that has certain hazard characteristics such as being radioactive, infectious, pathogenic, ignitable, toxic, corrosive, reactive, carcinogenic, mutagenic, etc.
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 procedure.
Illicit Connections
An illicit connection is defined as ether of the following:
  • Any drain or conveyance, whether on the surface or subsurface, which allows an illegal discharge to enter the storm drain system including but not limited to any conveyances which allow any non-storm water discharge including sewage, process wastewater and wash water to enter the storm drain system and any connections to the storm drain system from indoor drains and sinks, regardless of whether said drain or connection had been previously allowed, permitted or approved 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.
Minnesota Pollution Control Agency (MPCA)
The MPCA has regulatory authority to ensure compliance with Federal Clean Water Act requirements.
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.
Non-Storm Water Discharge
Any discharge to the storm drain system that is not composed entirely of storm water.
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 to provide sufficient information regarding the nature and extent of contamination; to assist in making informed business decisions about the property; and where applicable, provide the level of knowledge necessary to satisfy the innocent purchaser defense under CERCLA. 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.
Anything that causes or contributes to pollution. Pollutants may include, but are not limited to, paints, varnishes and solvents; oil and other automotive fluids; non-hazardous liquid and solid wastes and yard wastes; refuse, rubbish, garbage, litter or other discarded or abandoned objects, articles and accumulations, so that same may cause or contribute to pollution; floatables; pesticides, herbicides and fertilizers; hazardous substances and wastes; sewage, fecal coliform and pathogens; dissolved and particulate metals; animal wastes; wastes and residues that result from constructing a building or structure (including but not limited to sediments, slurries and concrete rinsates); and noxious or offensive matter of any kind.
Post-Development Conditions
Conditions after site improvements are completed.
Pre-Demolition Assessment
During project planning a brief summary of the known history and a list of potential risks based on past building uses will be prepared. These risks may include the following:
  • Asbestos
  • Pesticides
  • Heavy Metals, including but not limited to lead and mercury
  • Storage tanks and petroleum
  • Water infiltration and mold
  • Radiation closeout surveys/decontamination
  • Hazardous chemicals
  • Biohazardous agents
  • Regulated refrigerants including chlorofluorocarbons (CFCs)
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
University Owned facilities by which storm water is collected and/or conveyed, including but not limited to any roads with drainage systems, municipal streets, gutters, curbs, inlets, piped storm drains, pumping facilities, retention and detention basins, natural and human-made or altered drainage channels, reservoirs and other drainage structures which are within the University and are not part of a publicly owned treatment works as defined at 40 CFR Section 122.2.
Storm Water
Any stormwater runoff, snow melt runoff, and surface runoff and drainage.
Storm Water Committee
Committee charged by University Administration with reviewing internal policies and standards, individual projects and Master Planning efforts for consistency with external regulations and best practice and representing academic interests in storm water BMPs at the University.
Storm Water Pollution Prevention Plan
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.


Vice President for University Services
Provides resources, support and funding to facilitate the University's compliance with this policy and reports the University's performance to the Regents on a periodic basis.
Deans, Directors, Department Heads
Communicate this policy and procedure to affected staff and students, support programs implementing this policy, provide resources for unit to comply with policy, and pay any fines or penalties resulting from their unit's actions.
Department of Environmental Health and Safety (DEHS)
Facilitates compliance with these environmental standards by
  • Coordinating environmental programs and activities.
  • Maintaining expertise in environmental regulations and standards.
  • Representing the University with environmental regulatory agencies.
  • Assisting and guiding projects, operations and departments in ensuring compliance by:
    • recommending programs, procedures and options to maintain compliance.
    • providing resources and services that support compliance.
    • monitoring compliance and addressing noncompliance.
    • promoting and advancing best environmental management practices.
    • engaging and partnering with the units and people served.
  • Administering central collection, packaging, shipment and disposal of all hazardous chemical and radioactive wastes, including management of waste storage facilities and disposal contracts.
  • Providing or arranging for emergency response and clean-up of hazardous material spills.
Staff, faculty, and students
Are responsible for carrying out their roles in a manner protective of the environment and in compliance with this policy. Any student, staff or faculty member discovering a spill or release of what they believe to be a hazardous material will report such a release to DEHS.

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

Environmental Assessment:

  • US Environmental Protection Agency (40 CFR Part 312)
  • Minnesota Pollution Control Agency’s Voluntary Investigation and Cleanup Program Guidance Documents
  • 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


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

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