Executive Council

Authorizes Release:

Vice President for Administration and Finance

Responsible Area:

Facilities Services

Review Cycle:

Annually or as required

Last Review:

March 2021

Related Policies and Additional References:



St. Mary’s University generates solid and liquid waste as part of normal daily facility operations and academic operations. A determination is conducted on all waste to identify the proper disposal routes for the protection of the environment and compliance to Federal, State, and local regulation. All regulated waste is disposed of by an authorized service provider. St. Mary’s is currently operating as a Conditionally Exempt Small Quantity Generator (CESQG) of hazardous waste. St. Mary’s manages some of its hazardous waste such as used lamps, used batteries, mercury-containing equipment, and paint and paint-related material as Universal Waste as allowed for by law. St. Mary’s operates as a Small Quantity Handler of Universal Waste (SQHUW) as defined as generating universal wastes, not treating or recycling on site, in amounts less than 5,000 kilograms at any given time. St. Mary’s also has implemented a waste minimization program to reduce source generation and divert as much solid waste away from landfill disposal and into the recycle stream as possible.


This Waste Disposal Management Plan (WDMP) addresses the disposal of regulated and non-regulated waste generated and disposed by St. Mary’s University. Within this plan is guidance on the process to determine the storage and disposal requirements of all waste generated on campus. The plan provides procedures and practices for hazardous waste, universal waste, used oil, medical waste, polychlorinated biphenyl (PCB) waste, aerosol cans, empty containers, asbestos containing materials, e-waste, special waste, and unknown wastes. The plans also outlines the waste minimization and recycle program, training employees on managing hazardous waste, establishing contingency plans, and regulatory report requirements. The WDMP applies to all academic and non-academic departments of St. Mary’s University and is intended to serve as general guidance on the minimum requirements for waste disposal. Elements of this plan can be superseded by a more stringent departmental or process specific procedure that at a minimum includes the requirements outlined.


This plan is not intended to address the safe handling of chemicals in laboratories as required under OSHA regulation 29 CFR 1910.1450 nor is this plan intended to define the requirements for employees exposed to Asbestos Containing Materials as required under OSHA regulations 29 CFR 1910.1001, 29 CFR 1926.1101, or 40 CFR 763.92. St. Mary’s has a Chemical Hygiene Plan and Asbestos Management Plan under a separate cover which addresses the safe handling of laboratory chemical and building asbestos material, respectively.


Copies of the Waste Disposal Management Plan are located in the Office of Facilities Services.


It is the responsibility of all employees, students, and contractors working on behalf of St. Mary’s to handle, store, and dispose of hazard waste, universal waste, bio-hazardous waste, and regulated non-hazardous waste in a manner that is in compliance with all applicable state and federal regulations. The department or person that purchased or otherwise brought the material to the University campus should contact the Facilities Services to create a work order when the material is ready for disposal.

The department should provide the following minimum information on the work order request: type of hazardous material, quantity, source of generation, and the building and room that the waste is stored. The user should enter this information into the TMA Work Order request system in Gateway or provide it by email or phone to the Facilities Service Front Office if user does not have access to Gateway. Once the information is received:

  • Facilities Services shall create a work order and enter it into the system for processing by appropriate division (Housekeeping).
  • Housekeeping will process work order and schedule pickup up waste materials from department.

General Waste Streams

Hazardous Waste (40 CFR part 261) – Hazardous materials that are no longer useful, needed or wanted are to be considered hazardous waste. Hazardous wastes are either EPA listed or characteristically hazardous and must be handled and disposed of by a certified HW contractor.

Universal Waste (40 CFR part 273) – A special form of hazardous waste subject to less strict regulations based on environmentally sound collection and proper recycling or treatment processes. Examples are hazardous material batteries (i.e. lead-acid batteries, rechargeable batteries (NiCad, Lithium), pesticides, mercury containing equipment, and green pin florescent lamps (Hg content).

Other Regulated Waste – Other special materials such as e-waste, ballasts, used oil, tires, and medical wastes must be processed through a regulated vendor. Contact housekeeping for special containers and disposal requirements.

Non-regulated Waste

Liquid waste – San Antonio Water System (SAWS)is the Publicly Owned Treatment Works (POTW) for San Antonio and has restrictions for what can and what cannot go down the drain (refer to City of San Antonio Ordinance Ch. 34, Article V). Disposal of products down sinks and toilets must be in compliance to the guidelines set forth in the SAWS ordinance. Chemical waste must be determined to be non-hazardous and pH controlled. Normal biological waste from bathrooms, non-toxic laundry detergents from the laundry, and food preparation wastewater can go down the drain (sanitary sewer). Any solids are to be removed from waste streams such as water-based paint equipment rinse water, inks, glazes, and clays before being poured down the sink.

Solid trash – Non-hazardous solid waste such as food scraps, contaminated or waxed cardboard, cellophane or plastic wrap or plastic bags, glass, lumber, incandescent lamps, plastics, and dried (hardened) water-based paint materials can be discarded as regular solid waste for disposal in landfill. Containers with small amounts (<3% by volume) of residual oil-based paint can also be hardened and discarded as regular solid waste for disposal in landfill.

NOTE: Use the trash receptacles (not marked recycle) on campus or the Waste Management dumpsters located on campus for this type of non-regulated solid waste. Locations of the solid waste dumpsters on campus can be found in the Facilities Standard Operating Procedure, Dumpsters Trash and Recycle Management Procedure.


Single-stream recycling –Ink jet cartridges, printer and copier cartridges, alkaline batteries, aerosol spray cans, e-waste, scrap metal, lamps, ballasts, and kitchen grease should be stored in their dedicated recycle containers or storage areas pending off-site disposal.

Co-mingled recycling – Paper, newspaper, magazines, books without hard covers, cardboard, plastic bottles, glass, and cans should be disposed in the blue containers or other containers labeled as “Recycle”. Segregation of the different recycle material is not necessary since all recycle material is co-mingled in the 40 YD. compactor before off-site disposal.

Hazardous Waste Generator Status

St. Mary’s is currently identified and operating as a Conditionally Exempt Small Quantity Generator (CESQG) of hazardous waste since it generates less than 220 pounds of hazardous waste per month. Even though not required for a CESQG, St. Mary’s is registered with the Environmental Protection Agency (EPA and the Texas Commission on Environmental Quality (TCEQ): EPA ID Number TXD 078 500 725.

Regardless of status, St. Mary’s has made the decision to comply with the majority of requirements (i.e. container management, personnel training) of a Small Quantity Generator (SQG) of hazardous waste as a Best Management Practice. Close monitoring of campus status must be ensured when wastes are generated and when conducting periodic laboratory clean-outs to maintain CESQG status. As a CESQG of hazardous waste, St. Mary’s will implement the following practices as required by a CESQG.

  • Not store in excess of greater than 1,000 kilograms (2,200 pounds) of hazardous waste or greater than 1.0 kilogram (2.2 pounds) of acute hazardous waste at any given time
  • Not generate greater than 220 pounds of hazardous waste, or greater than 2.2 pounds of acute hazardous waste, in any one (1) calendar month.
  • Perform and maintain waste determinations.
  • Comply with Department of Transportation (DOT) regulations.
  • Comply with Universal Waste rules or manage the waste as hazardous.
  • Comply with Used Oil requirements.

By utilizing several of the practices required by a Small Quantity Generator of hazardous waste, St. Mary’s will also:

  • Use a manifest for all off-site shipments of hazardous waste
  • (Mark (label) each container of hazardous waste with appropriate labels including the words “hazardous waste” and “other words that identify the contents of the containers such as the “chemical name”.
  • Place the waste in appropriate containers.
  • Establish and document emergency preparedness procedures and contingency plans
  • Conduct annual training
  • Perform inspections of the CAA and SAA’s

Additionally, St. Mary’s is operating as a Small Quantity Handler of Universal Waste (SQHUW), and as such shall:

  • Store universal waste (lamps, damaged or leaking batteries, damaged or leaking mercury-containing equipment) in containers or packages that are structurally sound and adequate to prevent breakage;
  • Select containers compatible with the universal waste;
  • Ensure containers are closed except when adding or removing waste
  • Label containers with the words “Universal Waste” and other descriptive words such as “Universal waste – lamps,” “Universal Waste – batteries,” or “Universal Waste – mercury containing devices;”
  • Store waste for no more than one year from the date waste for first placed in the container.

HW Generation Reports are reviewed monthly by the Office of Administration and Finance to verify that the University is performing hazardous waste determinations and are not exceeding the maximum monthly waste generation and storage limits as a CESQG. If it is identified that St. Mary’s is generating above the CESQG Limits and Requirements, the University will ensure additional requirements are met to comply with the SQG or LQG Limits and Requirements as described below:

SQG Limits and Requirements: if St. Mary’s exceeds the CESQG limits and generates between 220 and 2,200 pounds or approximately 26 to 260 gallons (100 and 1,000 kg) of hazardous waste or less than 2.2 lbs. (1 kg) of acute hazardous waste per calendar month the following SQG requirements apply:

  • You can only store waste on-site for less than 180 days.
  • You can only accumulate less than 2,200 lbs. (1,000) kg of waste on-site at any one time.
  • Waste can be accumulated in containers or tanks.
    • You must comply with preparedness and prevention procedures.
    • Emergency response procedures must be in place.
    • You must post emergency contact information next to the telephone.
    • You must develop and maintain a written inspection program.
    • You must obtain an EPA Identification Number.
    • You must train your personnel.
    • You must manifest your waste using the uniform hazardous waste manifest.
    • You must comply with Department of Transportation rules.
    • You must “close” your hazardous waste storage area in accordance with the regulations if you discontinue its use.
    • You must certify on manifests that a good faith effort has been made to minimize hazardous waste generation.
    • You must either comply with Universal Waste rules or manage the waste as hazardous.
    • You must comply with Used Oil requirements.

LQG Limits and Requirements: if St. Mary’s exceeds the SQG limits and generates more than 2,200 pounds or approximately 260 gallons (1,000 kg) or more of hazardous waste per calendar month, or more than 2.2 lbs. (1 kg) of acute hazardous waste, the following SQG requirements apply:

  • You must perform and maintain waste determinations.
  • You can only store waste on-site for less than 90 days.
  • There is no quantity limit to on-site accumulation.
  • Waste can accumulate in containers, tanks, or containment buildings.
  • You must comply with preparedness and prevention procedures.
  • You must develop and maintain a written contingency plan.
  • You must develop and maintain a written inspection program.
  • You must maintain an annual personnel training program and written job descriptions.
  • You must obtain an EPA Identification Number.
  • You must manifest your waste using the uniform hazardous waste manifest.
  • You must comply with Department of Transportation rules.
  • You must “close” your hazardous waste storage area in accordance with the regulations if you discontinue its use.
  • You must prepare a written waste minimization program.
  • You must comply with applicable air emission standards.
  • You must comply with Universal Waste rules or manage the waste as hazardous.
  • You must comply with Used Oil requirements.

HW Disposal Requirements

At the end of each semester, after all labs are completed, the Lab Supervisors for each department that generates chemical waste (i.e. Biology, Chemistry, and Photo Lab) will accumulate the lab waste in their respective satellite accumulation area and notify the Office of EHS &RM. The HW will be packaged in non-spill able containers and labeled with contents, and the words “Hazardous Waste”, date of generation, and the department of origination before transport. A preliminary assessment of the hazardous waste will be conducted by a third-party authorized service provider to ascertain cost and confirm the lab pack and pickup date.

Facilities Services will transport all HW to the HW Primary Accumulation Storage designated as the Central Accumulation Area (CAA) located in the Facilities Services compound before the pickup date. The Office of EHS & RM will supervise the lab packing and disposal and is responsible for approving and maintaining the HW disposal manifests and other supporting associated with the disposal.

  • HW Satellite Accumulation Area (SAA) – Hazardous waste generated from labs shall be accumulated in a predetermined waste accumulation area within the department. This satellite accumulation area cannot exceed a total waste volume of 55 gals. Liquid waste determined to be non-hazardous waste can be diluted and poured down the sink. Chemicals poured down sink, toilets, or other floor drains must be compliant to the wastewater restrictions identified in the City of San Antonio Ordinance Ch. 34, Article V – Sewage Transportation, Treatment, and Disposal.
  • Solids Trap Waste Determination – Sink Trap waste from CF 230, 234, 235; Garni 213; and Interceptor Trap waste from vehicle wash rack will be determined as either hazardous or non-hazardous based on user knowledge of the chemicals disposed. If determined hazardous, the solid waste from the sink traps or wash rack interceptor will be added to the HW Tracking System and stored in the SAA or CAA as applicable pending disposal.
  • Legacy/Abandoned Chemicals – Accumulation of unlabeled containers or containers with unknown substances shall be avoided. All waste containers shall be labeled with type of waste and hazards (i.e. flammable, corrosive, reactive, etc.).  If the material is identified as a Hazardous Waste it shall be labeled, dated, and stored in a HW accumulation area pending disposal.

HW Manifest Requirements

Prior to any off-site shipment of hazardous waste from St. Mary’s University, a hazardous waste manifest is completed and accompanies all off-site shipments. The hazardous waste manifest is presented on 8½” x 11” paper and contains six (6) copies. Once the waste is loaded on the truck for shipment, the designated appointee from St. Mary’s prints and signs his/her name and dates the manifest. Prior to the waste leaving the campus, the truck driver transporting the waste must print and sign his/her name and date the manifest. St. Mary’s is to maintain one copy of the manifest at this time. The six (6) copies of the manifest are distributed as follows:

Copy 1: When the manifest is completed by the Treatment, Storage and Disposal Facility (TSDF), a copy is mailed to the State where the TSDF located.

Copy 2: When the TSDF has completed this section of the manifest, a copy is mailed to the State where the waste was generated.

Copy 3: When the TSDF has completed this section of the manifest, a copy is mailed back to St. Mary’s for their records. This copy is used to document the delivery of the waste to the designated facility.

Copy 4: When the TSDF has completed this section of the manifest, he keeps this copy for his records.

Copy 5: When the Transporter has completed his section and transfers the waste to the TSDF, he keeps this copy for his records.

Copy 6: When St. Mary’s and the Transporter have completed their sections of the manifest (including signatures) and the hazardous waste has been transferred to the vehicle, St. Mary’s keeps this copy of the manifest for their records. Note: this is the first copy of the manifest the campus receives.

When Copy 3 of the manifest is returned to St. Mary’s, it is attached to Copy 6 and any other records associated with the shipment (i.e. LDR, emergency response information, lab pack inventories, etc.) and must be retained on-site for a minimum of three (3) years. The original manifest must be retained by the EHS officer.

If Copy 3 is not returned to St. Mary’s within 45 days, the TSDF will be contacted to determine the status of the waste shipment. If the manifest copy has not been returned within 60 days, St. Mary’s should notify legal counsel. As a CESQG, it is not necessary for St. Mary’s to submit an Exception Report to TCEQ, as this is only a requirement of SQGs and LQGs in TX. Instead, the campus should make every effort to identify the fate of the waste and ensure that the waste was delivered to, and received by, the TSDF.

Note: Those signing HW Disposal Manifests on behalf of St. Mary’s shall be trained in Department of Transportation (DOT) / Resource Conservation and Recovery Act (RCRA) procedures and requirements at least every three (3) years.

Manifests are not required for the off-site disposal of used oil, regulated non-hazardous waste, or bio-hazardous waste. However, it is a Best Management Practice by both St. Mary’s and its service providers to utilize a manifest or Bill of Lading where appropriate to document all off-site shipments of waste materials and recycled, reclaimed, or donated materials. St. Mary’s should maintain copies of all waste disposal documents for at least three (3) years. Whereas three (3) years is the required record keeping time period, due to the liability involved with waste disposal, permanent record keeping of waste disposal documents is recommended.

If a hazardous waste is restricted from land disposal (see 40 CFR Part 268.7(a)(4)), records of the LDR must be retained with the copy of the waste manifest (i.e. staple the original copy of the waste manifest to the LDR statement and the returned copy of the manifest indicating successful shipment to the final disposal facility.) Typically, the hazardous waste vendor used by St. Mary’s generates the LDR. However, the University is ultimately responsible to ensure that the LDR is completed and maintained with the manifest in University’s files.

Waste Determination

Hazardous Waste (HW) – All lab waste (whether hazardous or non-hazardous) shall be documented in the HW Tracking System weekly (each Friday) by both the Chemistry and Biology departments. Generated waste chemicals shall be quantified and identified as hazardous or non-hazardous along with the method of disposal (HW Container, Sink).   Refer to the HW Tracking System End-User Instructions (Mar 2012) for the information required to be entered. Faculty and staff’s knowledge of the process generating the waste, any associated material safety data sheets (MSDS), and lab analyses are tools that can be used in this determination.

Universal Waste (UW) – According to 40 CFR 273 Subpart A, the following hazardous waste streams may be managed as Universal Waste:

  • Hazardous waste batteries (40 CFR 273.2)
  • Waste or recalled pesticides (40 CFR 273.3)
  • Mercury containing equipment (40 CFR 273.4)
  • Universal waste lamps (i.e. fluorescent lamps, exit sign lights, street lights, and those meeting the characteristics of a hazardous waste) (40 CFR 273.5)

In Texas, Paint and Paint-Related Material (PPRM) is also included as universal waste. Under 30 TAC 335.262, PPRW is defined as:

  • Used or unused paint and paint-related material which is “hazardous waste”
  • Any mixture of pigment and a suitable liquid that forms a closely adherent coating when spread on a surface or any material that results from painting activities.

All generated universal waste on the University campus is shipped off-site to a regulated facility. Universal waste manifests, or other documents associated with universal waste disposal/recycling are retained by the Office Administration and Finance.

Unknown Wastes – Unknown wastes may occur when a waste is generated from a new process and the waste has not yet been evaluated as to its hazards or during inventory clean-outs when the original product label is no longer legible. Unknown waste presents a particularly dangerous threat since the hazards are not known. Unknown waste should be treated as hazardous waste until the waste can be characterized. Professor or student knowledge of the process generating the waste, as well as laboratory analytical procedures, can be used to identify the waste.

Empty Containers – Empty containers that formerly contained hazardous materials may be considered hazardous waste if not managed properly. For containers that have been utilized for the storage of acute hazardous waste (P-listed waste) the container must be triple rinsed to be considered empty and no longer hazardous waste. The rinsate from this process must be collected and waste determinations performed to determine if the rinsate is hazardous. Or, the college may collect the container without triple rinsing, and thus dispose of the container itself as hazardous waste.

For non-acute hazardous waste (U-listed, some F-listed, K-listed and characteristic waste) the container is considered empty if:

  • All waste has been removed that can be removed
  • Less than 1 inch of residue remains in the container
  • No more than 3% by weight of the total capacity of the container remains in a container sized less or equal to 110 gallons
  • No more than 0.3% by weight of the total capacity of the container remains in a container sized more than 110 gallons.

If containers are not “empty” per the requirements listed above, it must be treated as hazardous waste. If the containers meet the regulatory definition of empty, then the containers should be identified as “empty” to ensure proper disposal. Empty containers of raw materials or virgin chemicals become wastes when materials are emptied from such containers as reasonably attainable. When this is achieved, the waste rule as noted above applies. Empty containers containing non-hazardous waste materials may be disposed of in the general refuse provided no visible materials remain within the container.

Aerosol Cans – An aerosol can typically become waste when 1) the can has lost its spray nozzle before the contents have been completely used; 2) the can runs out of propellant before the contents have been completely used; 3) the generator no longer has a use for that product; or 4) the product has been completely used and the empty, pressurized can remains.

An aerosol can, even one in which its contents have been completely used, by itself is usually considered hazardous waste because it exhibits the characteristic of reactivity (D003) or ignitability (D001). That is, it is capable of detonation or explosive reaction if it is subjected to a strong initiating source or it is heated under confinement.

Each department at St. Mary’s will establish a waste bin for waste aerosol cans. When the waste bin is full, or at the end of each semester, a request is made with the Facilities Services Department to collect the accumulated waste aerosol cans, and transport them to Facilities Services compound where the cans are collected.  Aerosol cans are punctured to completely empty aerosol cans and make them non-reactive.  Punctured and drained aerosol cans meet the definition of an empty container and are exempt from management as hazardous waste and are treated as scrap metal. The contents of all aerosol cans are collected in a 33 gal drum located in the CAA and is treated as hazardous waste.

Waste Minimization Program

Regardless of generator status, St. Mary’s will make every effort to reduce the amount of non-hazardous, universal, medical, used oil, E-waste and hazardous waste generated on campus. This will include, but is not limited to, maintaining an inventory control system to avoid the unnecessary accumulation of chemicals. The EPA has established guidance recommending six key elements that should be incorporated into a waste minimization program. These key elements are:

  • Top management support
  • Characterization of waste generation and waste management costs
  • Periodic waste minimization assessments
  • Cost allocation system
  • Encourage Technology transfer
  • Program implementation and evaluation


As a CESQG, St. Mary’s shall ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies. As a Best Management Practice, RCRA hazardous waste training will be conducted annually for those employees who manage and/or handle hazardous waste. All University personnel (faculty, staff, and students) responsible for or participating in accumulation, tracking, storage, relocation or disposal of HW shall be trained on this Waste Disposal Management Plan. The Office of Facilities Services will notify all relevant personnel if any substantive changes are made to the Plan between training cycles.

The Office of Facilities Services is required to maintain current training for Department of Transportation (DOT) and Resource Conservation and Recovery Act (RCRA) to sign hazardous waste manifests.

  • Training on this plan and the Resource Conservation and Recovery Act (RCRA) will be offered annually for all Facilities Services personnel. Monthly Department Meeting attendance shall serve as Training Record.
  • Faculty and staff of academic departments that generate HW shall review this Plan on an annual basis and provide feedback to update the Plan if needed.   Departmental Meeting attendance shall serve as Training Record.
  • Students engaged in HW activities shall receive appropriate training of HW handling, storage and disposal requirements as part of the lab safety orientation. Student class/lab enrollment may serve as Training Record.

Emergency Contingency Planning

The operations at St. Mary’s are conducted in a manner to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste. A Chemical Compatibility Chart is located in each area storing hazardous waste and is used to ensure the proper storage of both raw materials as well as waste to ensure that the risk of fire, explosion, or release is minimized. Hazardous waste is centrally stored in the HW Primary Accumulation Storage Building in the Facilities Services compound and is designated as the Central Accumulation Area for the University.

The University Vice President of Administration and Finance is the Emergency Coordinator for the University Campus. The University Police Department (UPD) is notified of all emergencies on campus and serves as the liaison to the local (San Antonio and Bexar County) police, fire department, and hazardous materials emergency units.   The clean-up of large chemical releases is out-sourced to an authorized waste service provider and overseen by the Office of Administration and Finance in collaboration with the UPD. Any fire, explosion, chemical release that meets reportability requirements is reported to the National Response Center (NRC) and TCEQ immediately.

The Incident Management Plan outlines processes for responding to incidents that impact the safety and welfare of the University community and/or the continuity of operations. The plan identifies a Critical Incident Response Team (CIRT), establishes an emergency meeting location and promotes return to normal operations as soon as possible. A component of the IMP is emergency notification.

The Emergency Notification Plan identifies the key individuals of the CIRT who are responsible for implementation of an electronic “Emergency Notification System” to support emergency notification to all current students, faculty, and staff. Message alerts are sent to all students, faculty, and staff via text messaging, email, and voicemail in cases of personal safety, inclement weather, and power outages. This is an “opt out” system in which the individual is automatically enrolled unless they consciously make the decision to exclude themselves from the notification system.

The Emergency Action Plan complies with OSHA 20 CFR 1910.38, and includes procedures for medical emergencies, chemical spills, explosions, severe weather, and power outages. All emergency situations are reported to the University Police Department.

Safety Equipment Locations Available in the Office of Facilities Services.

Other Wastes

Used Oil is defined as any oil that has been refined from crude, or any synthetic oil, that has been used and as a result of such use is contaminated by physical or chemical impurities. Used oil that is recycled is regulated under 40 CFR Part 279. Used oil under this regulation does not include antifreeze, kerosene, vegetable oil, animal oil, kitchen grease, and petroleum distillates.

Used oil may be considered hazardous waste and must be managed in accordance with the previous sections of this plan if:

  • The used oil has been mixed with a listed hazardous waste
  • The used oil has been mixed with a characteristic hazardous waste and still meets the characteristics of the hazard
  • Contains greater than 1,000 ppm (0.1%) of total halogens
  • Contains greater than 50 ppm of total polychlorinated biphenyls (PCBs)

Used oil is to be stored in solid containers less than 55 gals in capacity and is to be covered at all times unless filling or emptying its contents. The container must have a label with the words, “USED OIL”. Oil spills are managed per the University Spill Prevention Control and Countermeasures (SPCC) Plan.

Used oil generated at St. Mary’s includes lubricating oil, hydraulic fluid, compressor oil, mineral oil, coolants, cutting oils and metal working fluid resulting from maintenance activities associated with boilers, compressors, and elevators as well as vehicles. St. Mary’s follows all the requirements listed above and consolidates all used oil in appropriate containers in the Facilities Services compound. The University uses an authorized used oil vendor for the disposal/recycling of its used oil.

Parts Washer

Facilities Services has discontinued use of the automotive parts washer.

Medical Waste

The TCEQ defines medical waste as being one of the following: Animal waste from animals intentionally exposed to pathogens; Bulk human blood and blood products; Pathological waste; Microbiological waste; or Sharps.

Certain categories of medical waste may not be disposed of in sanitary landfills or may be disposed of only after the waste has been treated or packaged in certain ways:

  • Sharps must be securely packaged in puncture-proof containers prior to landfilling;
  • Cultures and stocks of infectious agents and associated biologicals must not be landfilled unless and until they have been treated (e.g. autoclaved, incinerated) to render them non-infectious;
  • Human blood and blood products and other body fluids may not be landfilled. This restriction applies to bulk liquids or wastes containing substantive amounts of free liquids, but does not apply simply blood – contaminated materials such as emptied blood bags, bandages, or “dirty” linens
  • Recognizable human organs and body parts may not be landfilled. to simply blood – contaminated materials such as emptied blood bags, bandages, or “dirty” linens; a Recognizable human organs and body parts may not be landfilled

St. Mary’s generates medical waste (sharps, bagged medical waste) from three sources on campus: Student Health Center, Biology Department, and the Athletics Department. St. Mary’s ships all generated medical waste offsite for treatment on a quarterly schedule using an authorize service provider.   Medical or other bio-hazardous waste can be autoclaved for odor control. But this autoclaved waste will still be packaged and labeled per 30 TAC 330.1207 (c) and shipped off-site for disposal. Refer to the Medical Waste Disposal and Chain of Custody procedure for safe handling and disposal requirements. Disposal records are retained in the EHS Office.

Asbestos Containing Material

St. Mary’s personnel are not licensed to conduct asbestos surveys, nor are St. Mary’s personnel licensed or certified to remove asbestos containing materials (ACM). As required under the National Emission Standards for Hazardous Air Pollution (NESHAP) Standards, in the event demolition or renovation activities are performed on campus, St. Mary’s contracts with an authorized service provider to conduct asbestos surveys to identify any ACM in the work area prior to any work being performed.

In the event ACM is identified in a proposed work area by a licensed or accredited Asbestos Inspector, St. Mary’s complies with all appropriate removal and notification requirements. St. Mary’s retains copies of all contractors’ licenses as well as a copy of the final report to include a waste manifest documenting the proper disposal of the ACM to an approved disposal facility. Pertinent copies are permanently retained within the campus Environmental Files. Under no circumstances should St. Mary’s store waste materials associated with the abatement or removal of ACM.

Polychlorinated Biphenyl (PCB) Waste

St. Mary’s has retro-filled all campus transformers with non-PCB mineral oil or dielectric fluid. All transformers are labeled as such.   However, the University does have florescent light ballasts throughout the facility. These ballasts when ready for disposal are evaluated for the potential PCB content based on the guidance given in 40 CFR 761.2. If the ballast is marked “non-PCB” it may be either recycled or disposed in the general trash. If the ballast is not marked “non-PCB it is assumed to be PCB containing. Once the PCB content has been determined, St. Mary’s follows the proper labeling and storage requirements listed above. All generated PCB waste on the St. Mary’s campus is shipped off-site to a regulated facility. Waste manifests are retained by the Office of EHS & RM.


E-waste is a general category for electronic products facing displacement or replacement that are hazardous due to the toxic metals present within their internal materials, coatings and glass. E-waste may include personal computers, monitors, televisions, keyboards printers, telephones, typewriters, calculators, copiers, fax machines and audio equipment. There are commodities worth capturing in E-waste plus there are traditionally toxic materials in electronics that should be kept out of the environment and properly managed.

E-waste generated at St. Mary’s includes but is not limited to personal computers, monitors, televisions, keyboards printers, telephones, and other office equipment. St. Mary’s uses an authorized recycling service provider to pick-up all e-waste on a quarterly schedule. Disposal documentation including Certificate of Destruction and Recycling is retained in the Office of EHS & RM.

Special Waste

St. Mary’s generates a classification of waste referred to as “Special Waste”. This waste is any waste that does not fall under any of the previous categories but requires special handling and disposal because of its quantity, concentration, physical or chemical characteristics, or biological properties. Contact the Office EHS for additional information on the disposal method for the special wastes listed below:

Grease-traps (UC and Subway)

  • St. Mary’s utilizes two grease traps for its food services areas that are serviced on a quarterly basis (no longer than 90 days between services). The grease traps are also checked for solid content each month to ensure they are less than 25% solids. If either grease trap has a solid content ≥25% a pump out of both grease traps will be scheduled within 48 hrs. regardless of the time since last pump out.

Grit-trap (wash rack) wastes

  • St. Mary’s utilizes a wash rack interceptor to trap oil and solids sourcing from the automotive wash rack bay. The interceptor is serviced on a quarterly basis and tested every two years for presence of hazardous material per San Antonio Municipal Code.

Kitchen Grease Tank

  • St. Mary’s utilizes a 275 gal grease tank to store kitchen grease. The tank is double-walled with an appropriate interstitial area to serve as secondary containment. The tank is serviced as needed when reaching capacity by an authorized service provider.

Animal carcasses, specimens, and organs

  • Dead animal carcasses are double-bagged, labeled and disposed in a dedicated solid trash dumpster at the end of each semester. A waste hauler will provide this dedicated dumpster upon request. A special waste profile describing the waste type and quantity shall be on file with the authorized waste hauler and disposal facility. This special waste will be disposed of at the end of each semester

Empty pesticide (insecticide, herbicide, fungicide, or rodenticide) containers

  • All chemical remaining in container should be used up before disposing of the container. If labeling indicates non-hazardous, dispose of container in solid waste dumpsters. Depending on the type of chemical the container may have to be triple- rinsed before disposal. Contact Office of EHS & RM if unsure of proper disposal procedure.

Asbestos Containing Material

  • Certain discarded materials containing asbestos per 30 TAC 330.171(c)(3) and (4) or regulated asbestos-containing material may be accepted for disposal at a Type I or Type IAE landfill. Non-regulated   asbestos-containing materials (non-RAM) may be accepted for disposal at a Type I, Type IAE, Type IV, or Type IVAR landfill.
  • All potential ACM is disposition by a certified asbestos abatement contractor before disposal

Scrap Metal / Other Recycle

Ferrous and non-ferrous metals that are no longer in use are disposed of as scrap metal. A 20 CY roll off container (bin) located in the Facilities Services compound is used to store all scrap metal pending disposal.   Any equipment (i.e. microwaves, appliances) that includes electrical devices such as capacitors or motors that may contain hazardous material shall have the device removed before placing the item in the scrap metal bin. All equipment containing hazardous liquid (i.e. oil, refrigerant) will be completely emptied before placing in scrap metal bin. The bin will be serviced on a quarterly basis or when full (whichever comes first).

For other materials eligible for recycle refer to the following Standard Operating Procedures:

  • Batteries Collection and Disposal
  • Dumpsters Trash and Recycle Management
  • Lamp Ballast Battery Capacitor Recycle Program
  • Safety and Operation of Aerosol Can Puncture System
  • Used Oil Collection and Disposal

Available in the Office of Facilities Services:
Appendix A: Examples of Regulated Waste Generated on Campus

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