Earth Sciences Division (ESD) Department of Energy (DOE) Lawrence Berkeley National Laboratory (LBNL)

Satellite Hazardous Waste Accumulation Area (SAA) Guidelines

All waste that is ignitable, toxic, corrosive and/or reactive is deemed chemically hazardous and shall be kept in a Satellite Accumulation Area (SAA).

There are special requirements for waste that is radioactive or a mixture of chemically hazardous and radioactive waste, called mixed waste (pdf), biohazard waste, and e-waste (pdf). Leaky batteries or ones that contain a liquid should be put in baggies or other leak-proof containers before disposed of as hazardous waste. Otherwise, batteries are regulated as “Universal Waste”, do not go into the SAA and should be disposed of in the designated green buckets located around every building. There is one located outside the 90-2125 copy room and one in the 70-108 mailroom. Ask your building manager for other locations. EH&S technicians pick up batteries from the green buckets every couple of months.

Questions?  Contact our EH&S Hazardous Waste Generator Specialist Howard Hansen x5867, or Vivi Fissekidou (x5610).

Setting Up an SAA

  1. ESD tracks all SAAs. Notify ESD's Safety Coordinator BEFORE you setup an SAA and when you dismantleone.
  2. You must take EH&S 604: Hazardous Waste Generator Training before setting up an SAA, putting waste into an SAA and requesting waste pickup
  3. Post the SAA label with current contact information and the SAA reminder sheet (pdf) above the SAA.

Storing Waste in an SAA

  1. Only hazardous waste may be placed in an SAA. Clearly delineate waste area with tape and/or signage and keep any useful product OUTSIDE the Satellite Accumulation Area.
  2. All waste must be labeled with name, date, waste composition, and other required information. Waste composition must include the relative amounts of all constituents. Use the Red and White Hazardous Waste label.
  3. Up to 55 gallons of hazardous waste, and one quart of extremely hazardous waste may be placed in an SAA.
  4. All wastes must be stored in containers compatible with the waste.
  5. All liquid containers must have tight-fitting (screw-type) lids. Tapered glass fittings and squeeze bottles are not acceptable. Tops must be kept securely closed at all times except during filling.
  6. All liquid wastes and all wastes in glass containers must be within secondary containment .
  7. Up to one quart of flammable waste may be accumulated in glass containers (exception: up to one pint of Class 1A flammable such as ethyl ether). Greater quantities of flammable and non-flammable (halogenated) solvents must be placed in red plastic safety cans. These are available free of charge from EH&S Waste Management. Contact Howard Hansen at x5867.
  8. Incompatible wastes (e.g. acids and alkalis, oxidizers and flammables) must be separated in different secondary containment.
  9. Native rocks and soils may contain toxic metals (such as lead) above the regulated threshold concentrations. The regulatory thresholds for toxic contaminants in wastes may be found in Pub 3092 Guidelines for Generators. All hazardous constituents and characteristics must be described for each waste generated. Analytical determinations for regulated toxic metals should be performed when the metals content of the soil is not known.

Hazardous Waste Pickup

Hazardous Waste must be removed within SIX MONTHS of the accumulation state date.

SAA and MWAA Inspections

ESD inspects our SAAs quarterly, and OAA conducts unannounced inspections. Follow these guidelines and tips for a violator-free inspection:

Pointers for a Violation-free SAA Inspection:

  • Review the SAA guidelines
  • Have all your waste picked-up before the inspection. An empty SAA is a compliant SAA!
  • SAA placards and waste labels need to be completely filled out.
  • Your entire workspace, especially fume hoods, is subject to inspection.
  • If you reuse solvents, label the container as "used solvent (name of solvent)", and don't label it as waste.
  • Containers with visible crust or deposits and/or those that look like they're no longer usable, will be considered wastes. If they are outside the SAA and not labeled, that's a violation.

Waste Minimization

Berkeley Lab maintains an aggressive waste minimization program with many successes over the years. The following list highlights a few of the things you can do to minimize your waste.

Separation and Segregation

  • Avoid cross contamination by storing radioactive waste separately from hazardous and nonhazardous wastes and other nonradioactive materials.
  • Segregate your liquid radioactive waste based on isotopic half life.
  • Scintillation vials showing no activity above background should be accumulated separately and managed as nonradioactive waste.
  • Segregate non hazardous materials from hazardous materials or wastes.

Good Housekeeping

  • Keep accumulation of wastes in your SAA to a minimum by requesting frequent waste pickups.  This can reduce the potential for generation of spill clean-up wastes in the event of an upset condition (such as an earthquake).
  • Label all point of use containers such as beakers, flasks or tubes, whether hazardous or not, to reduce the potential for generation of unknown waste mixtures.

Material Recycle and Reuse

  • Reuse gel staining or destaining solutions.
  • Reuse spent solvents for initial rinses or general cleaning.

Material Substitution

  • Search for and use nonhazardous chemicals whenever possible.
  • Substitute red liquid (alcohol) thermometers or digital thermometers for mercury thermometers where practicable. 
  • Substitute biodegradable nontoxic detergents for cleaning solvents.
  • To the extent possible use isotopes with half-lives shorter than 90 days.
  • Search for and use nonradioactive substitutes (e.g. immunoassay reagents, materials labeled with stable isotopes or other nonradioactive tracers), particularly when the use of long-lived isotopes is desired.

Process Modification

  • Design your experiments to use the minimum amount of hazardous or radioactive material (i.e. microscale chemistry).
  • Implement benchtop treatment (contact your Generator Assistant for details)
  • Keep 3H and 14C activities in animal tissues and scintillation fluids below 0.05 microcuries/gram whenever possible.

Inventory and Purchasing Controls

  • Order only the amount of radioactive materials and chemicals you will use in a reasonable period of time.  Centralize purchasing in your laboratory if possible to minimize duplicate orders.

For more details on any of these suggestions, or for assistance in waste minimization, please contact your Howard Hansen at X5867. Additional information is available at the EH&S Waste Services web site at and in Pub 3092.