This opinion is subject to motions for reargument under V.R.A.P. 40 as well as formal revision before publication in the Vermont Reports.
Defendant also appeals the criminal fines as excessive.
Defendant, a Massachusetts corporation, operated a manufacturing facility in Bennington, Vermont which made Christmas wrapping paper. During the inspections, ANR collected and tested samples of ink wash and alkaline stripping solution used to clean defendant's printing equipment. ANR determined the water-based ink wash to be a hazardous waste because of its ignitability. ANR identified the by-product of the alkaline solution as a highly corrosive sludge, also a hazardous waste by definition. Because defendant did not obtain the required certification, ANR concluded that defendant had improperly generated and stored hazardous waste.