Respondent produces steel tubing using bending, stamping, cutting, laser etching, welding, assembly, and powder coating operations, and is located on Seneca Nation of Indians land. A RCRA CEI was conducted in response to the facility's off-site shipment to a solid waste landfil of six drums of waste that was subsequently determined to be hazardous waste for the toxicity characteristic of chromium. In the landfill's process of staging these containers, hazardous waste was accidently released into the environment. The CEI determined that the chromium waste was generated from a laser etching operation, and the facility was in violation of most safe harbor provisions for small quantity generators. The Complaint cites these provisions (as failing to obtain a permit), Respondent's failure to make hazardous waste determinations, and to use manifests to ship these hazardous waste. Respondent admitted to these violations and agreed to a settlement.