THE MOST ENVIRONMENTALLY SIGNIFICANT RCRA COUNTS ARE BASED ON FITCHBURG STATE COLLEGE'S STORAGE OF CONTAINERS OF REACTIVE HAZARDOUS WASTES IN A REFRIGERATOR IN ROOM 236 OF THE CONDIKE BUILDING. THIS ROOM IS LOCATED BETWEEN TWO FUNCTIONING CLASSROOMS. STUDENTS ARE OBSERVED IN ONE OF THESE CLASSROOMS AT THE TIME OF THE INSPECTION. A SIGN ON THE DOOR OF THE REFRIGERATOR READ, OPEN (easy) Door SLOWLY (valuable thermometer) . THE INSPECTION TEAM WAS UNABLE TO DOCUMENT THE CONTENTS OF EACH CONTAINER BECAUSE OF POTENTIALLY DANGEROUS CONDITIONS (REACTIVE HAZARDOUS WASTES MAY EXPLODE AND/OR RELEASE TOXIC VAPORS). HOWEVER, INSPECTORS WERE ABLE TO VERIFY THAT METHYL TERT ETHER AND ISOPROPYL ETHER WERE TWO OF THE REACTIVE COMPOUNDS PRESENT. FURTHER, IN THE ANTHONY AND CONDIKE BUILDINGS, FITCHBURG STATE COLLEGE WAS STORING CHEMICALS OF UNKNOWN CONTENT, CHEMICALS THAT WERE UNUSUABLE DUE TO DETERIORATION, AND CHEMICALS NO LONGER USED BY STUDENTS OR FACULTY. IN ALL CASES, FITCHBURG STATE COLLEGE FAILED TO MAKE DETERMINATIONS AS TO WHETHER MORE THAN 30 WASTE STREAMS WERE WASTE, AND IF THEY WERE WASTE, WHETHER THEY WERE HAZARDOUS WASTE. APPROXIMATELY 6500 POUNDS OF HAZARDOUS WASTE WERE SHIPPED OFF-SITE. SOME OF THE PARTICULARLY DANGEROUS MATERIALS WERE REMOVED BY A CONTRACTOR USING REMOTE ROBOTIC EQUIPMENT.
THE SERIOUSNESS OF THESE VIOLATIONS AND SIZE OF THE PENALTY WERE EXACERBATED BY THE RESPONDENT'S APPARENT KNOWLEDGE OF THE ABOVE-DESCRIBED CONDITIONS. RESPONDENT'S MISMANAGEMENT OF HA