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 Elements of this plan can be superseded by a more stringent departmental or process specific procedure that at a minimum includes the requirements outlined.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:
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.
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 labelled 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.
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.
By utilizing several of the practices required by a Small Quantity Generator of hazardous waste, St. Mary’s will also:
Additionally, St. Mary’s is operating as a Small Quantity Handler of Universal Waste (SQHUW), and as such shall:
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:
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:
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.
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.
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:
In Texas, Paint and Paint-Related Material (PPRM) is also included as universal waste. Under 30 TAC 335.262, PPRW is defined as:
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:
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.
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:
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.
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.
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:
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.
Facilities Services has discontinued use of the automotive parts washer.
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:
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.
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.
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.
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)
Grit-trap (wash rack) wastes
Kitchen Grease Tank
Animal carcasses, specimens, and organs
Empty pesticide (insecticide, herbicide, fungicide, or rodenticide) containers
Asbestos Containing Material
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:
Available in the Office of Facilities Services:
Appendix A: Examples of Regulated Waste Generated on Campus