Printed on: 05/23/2018. Please go to http://policy.umn.edu for the most current version of the Policy or related document.

ADMINISTRATIVE PROCEDURE

Environmental Assessments and Remediation

Purpose

The intent of Environmental Assessments and Remediation is to manage recognized environmental conditions associated with building materials, indoor air quality, soil, and groundwater, and to mitigate their potential effects on human health and the environment. Data collected, as part of the assessment, will be used to develop project plans that minimize risk and comply with the law.

The University will assess soil and groundwater quality on University properties prior to purchase and development. Prior to demolition or renovation of existing facilities, interior spaces will be tested for the presence of hazardous substances when indicated by historical and current uses.  All environmental assessments will be performed in accordance with nationally recognized standards. The following principles will be employed in the assessment and remediation process:

  • Assessment of buildings, soil, and groundwater will be based on year of construction, building practices, potential water damage, and previous uses.
  • Building materials, soil, and groundwater that have potential contamination will be tested to determine the extent of contaminated materials that will need to be managed, abated, or remediated.
  • Remediation plans that appropriately balance public health, environmental impacts, and cost effectiveness will be developed and implemented.
  • Where removal of contaminants is not feasible and not required by a regulatory agency, a management plan will be developed and compliance will be monitored.

Scope

This program applies to properties that the University plans to purchase and University properties system-wide.  Assessments will include investigation of the following media and building materials:

  • Soil, surface water, and groundwater quality
  • Vapor intrusion into buildings from subsurface volatile organics
  • Groundwater at elevations that may rise above the building footings
  • Asbestos containing materials
  • Regulated refrigerants
  • Electrical and hydraulic equipment containing polychlorinated biphenyls (PCBs)
  • Heavy metal contaminants in air or on surfaces. For example mercury from lab activities, building plumbing or other devices; or lead from building finishes or materials
  • Caulk that contains PCBs
  • Mold infestation from building moisture intrusion
  • Hazardous chemical contamination in laboratories, laboratory ventilation systems, or sanitary sewers
  • Pesticides
  • Tanks used for storage of hazardous materials or petroleum
  • Radioactive substances

Procedures

Property Acquisitions

A Phase I Environmental Site Assessment (ESA) and a Phase II ESA that meet the standards of the Environmental Protection Agency's All Appropriate Inquiry rules will be completed prior to transfer of real property to the University. These documents will be prepared by a Qualified Environmental Consultant (QEC), and reviewed by DEHS staff.

Buildings may also be evaluated for hazardous materials, including lead paint, PCBs, mercury, mold, and asbestos containing materials.  Note that non-destructive assessment for hazardous materials is not the same as a more thorough destructive assessment that is required prior to demolition.

University-Owned Properties: Soil and Groundwater Assessment

An ESA will be completed for construction projects that will require excavation and removal from the site.  The ESA will include a review of historical land uses and will be similar to, but may not meet all of the standards of ASTM E 1527 Practice for Environmental Site Assessments: Phase I Environmental Site Assessment.  The Assessment will focus on the additional data needed for the proposed land use.

Soil quality samples will be collected and analyzed following completion of the ESA or as soon as the excavation equipment arrives on site.  Soil will not leave the site until the soil is inspected for contamination, and laboratory analysis is completed if needed. Based on soil analytical data, DEHS will determine if fill and soil meets the MPCA standard for reuse as unregulated fill or if it needs to be disposed at a permitted landfill. Groundwater quality samples will be collected if evidence suggests that the groundwater in the area may have elevated concentrations of organic or inorganic contaminants.  If the analytical data indicate that the groundwater has elevated concentrations of volatile organic compounds, then a remediation plan will be developed.

Pre-Demolition Assessment of Building Materials

When buildings or interior spaces are scheduled for demolition or remodeling, the building construction plans and history will be reviewed, and the building will be inspected.  Information from this process will be used to develop a plan for testing building materials for hazardous materials.

Demolition may not proceed until all hazardous materials have been identified and removed, or a plan for removal during demolition has been prepared.

Response Action Plans

When feasible, assessment and remediation work may be performed by qualified University staff.  QECs may be hired to work on projects Use of a QECs will be noted in the assessment and remediation work plans.

A work plan will be prepared with a scope of work and a cost estimate for response actions for abatement or management of hazardous substances in buildings, soil or groundwater. The Capital Planning and Project Management (CPPM) staff will work with environmental assessment staff to develop cost estimates and budgets for response actions.

All assessment work will be completed in compliance with federal and state regulations or in a manner consistent with the care and skill ordinarily exercised by members of the environmental profession.  University staff will work with the MPCA staff to protect the University's interests as required.

Roles and Responsibilities

Department of Environmental Health and Safety
  • Provides the Real Estate Office with technical assistance associated with preparation of Phase I and Phase II ESAs provided by QECs during property acquisitions or sale and assists with the environmental liabilities and responsibility sections of access agreements.
  • Supports the Office of the General Counsel with preparation of contracts and agreements regarding environmental issues and provides environmental technical support for litigation when needed.
  • Prepares an ESA for all University properties that are selected for redevelopment.  The first priority is to complete ESAs for properties on the CPPM 6 year plan and other future projects that will require soil excavation.  If the property has received liability protection through the MPCA's VIC program or the Petroleum Brownfields program, a Phase I update will be prepared and submitted to the MPCA.
  • Prepares a contingency plan for projects where no contamination has been identified, but the property has the potential for contamination.
  • Participates in the selection of the qualified environmental consultant (QEC), including assisting with preparation of the RFP and participating in the evaluation of the responses.
  • Consults with the QEC or FMHMP when the initial environmental site assessment indicates hazardous substances or other environmental risks may be present. The environmental project team will provide recommendations to the CPPM project manager for conducting additional assessments.
  • Coordinate with CPPM's QEC by providing professional assistance with Phase II investigations and reviews the adequacy of the work prior to final payment
  • Supports Facilities Management Hazardous Materials Program (FMHMP) with evaluating interior spaces and assists with monitoring as appropriate. DEHS also arranges for radiation screenings when a room has a history of using an instrument that may have emitted radioactive ions.
  • Supports FMHMP staff with solving abatement problems that involves chemicals or radiation.
  • Periodically audits Facilities Management's work in asbestos and lead assessments and remediation.
Facilities Management Hazardous Materials Program (FMHMP)
  • Updates, conducts, or oversees preparation of Pre-Demolition Checklist consistent with standard procedures for evaluating building materials on University properties, and provides the reports to CPPM for their evaluation and review.
  • Conducts surveys of asbestos, mercury, perchlorate and lead in University buildings and provides survey information to project teams for capital projects.
  • Develops feasibility-level cost estimates for abatement of asbestos, mercury and lead containing materials and paint.
  • Updates the Facilities Condition Assessment Database with results from surveys and cost estimates for abatement.
  • Develops plans for mitigation and abatement of asbestos, mercury and lead when performed by University staff or external contractors. Reviews all work performed by asbestos, mercury and lead consultants and contractors for compliance with University's procedures.
  • Provide project team with closeout documents for asbestos, lead, and mercury.
Real Estate
  • Contracts with a QEC to complete a Phase I Environmental Site Assessment Report and building materials survey for all real properties prior to transfer of the property to the University.
  • Contracts with a QEC to conduct a Phase II Environmental Site Investigation when a REC is identified in Phase I.
  • Provides information and documents for properties where Phase I environmental site assessments and Phase II environmental investigations have been completed following acquisition of the property.
CPPM
  • Provides DEHS and FM Hazardous Material Group with the 6-year plan and the Client Project Request for all capital projects.
  • Oversees process, scope, schedule and budget for the additional environmental assessment and remediation. This role includes managing the RFP and QEC selection, if needed.
  • Manages QEC and receives reports and preliminary cost estimates from QEC.
  • Firms up remedial options, scope of work, and cost estimates for remediation, and implements the decisions of the project team.
  • Maintains records of environmental decisions and responses as part of the file.

Applicable University Policies, Standards and Regulations

The following University policies, industry standards and government regulations will apply to implementation of the environmental assessments and remedial actions described in this document.

  • ASTM E 1527 Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process
  • ASTM E 1528 Practice for Environmental Site Assessments: Transaction Screen Process
  • ASTM E 1903 Guide for Environmental Site Assessments: Phase II Environmental Site Assessment Process
  • University of Minnesota Administrative Policy: Environmental Management
  • Environmental Procedures Plan
  • DEHS – CPPM Roles and Responsibilities Document.
  • US Environmental Protection Agency (40 CFR Part 312) All Appropriate Inquiry (effective date is November 1, 2006)
  • Minnesota Pollution Control Agency's Voluntary Investigation and Cleanup Program Guidance Documents
  • Minnesota Department of Health Rules, Clean Indoor Air Chapter 4620, Parts 3000 to 3724,
  • Minnesota Department of Health Rules Residential Lead Abatement Chapter 4761
  • TSCA (15 U.S.C. § 2601 et seq.) Title 1 - Control of Toxic Substances
  • TSCA (15 U.S.C. § 2601 et seq.) Title 2 - Asbestos Hazard Emergency Response
  • US Environmental Protection Agency (40 CFR Part 312) All Appropriate Inquiry (effective date is November 1, 2006)

Document Feedback