Respondent manufactures ceramic capacitors using a stacking process which includes sandwiching ceramic material with precious metals. A RCRA CEI was conducted of the facility in response to its September 2008 shipment of 27,000 lbs of non-regulated waste which was subsequently determined to exhibit toxic characteristics for cadmium (D006) and barium (D005) and therefore contained hazardous waste. The CEI determined that this waste originated from a grinding operation and, prior to shipment, had been accumulating at the facility for about two years. In addition, the CEI determined that the facility was in violation of many safe harbor provisions for large quantity generators of hazardous waste. The Complaint cited these provisions (as failing to obtain a permit), its failure to make a hazardous waste determination, and failure to comply with manifest requirements.