The prohibitions in the draft Permit are sensible. It is crucial to determine whether a specific drum contains these prohibited materials. The question is how to characterize the waste to adequately determine whether these prohibited materials are present. VE could be used to determine whether the multiple waste streams from multiple sites are chemically compatible. VE, however, could not explain the mechanism by which the corrosion formed on the inside of the drums.
More sophisticated analysis is needed to make that determination.