Rags and cellulosics can absorb liquids having very high or very low pH. Therefore, at the very least, rags and cellulosics should be tested with the EPA's solid corrosivity test. For example, the California test method could be used. In answer to a question from the Hearing Officer, Dr. Hirschhorn testified that wastes have to meet the RCRA requirements of the state in which the waste is located. Three federal regulatory agencies having jurisdiction over these materials define reactivity around the idea of causing severe problems when mixed with water, but do not necessarily agree on the type of material included in that definition. The OSHA considers any solid that becomes a danger when wet to be reactive.
Toxic gases are present in debris waste containers.
Benzene and vinyl chloride could be present in such containers. Under certain conditions releases of these gases could be dangerous to human health and the environment. The reactivity characteristic should be addressed by testing for reactivity if headspace sampling and analysis reveals the presence of toxic gases in a container. Such containers are one of the problems resulting from accepting waste from such an agglomeration of different waste streams. Currently, the draft Permit does not take these rigid containers into account.