Defendant Kenneth C. Johnson is and was at all relevant times the owner and President of defendant Technical Finishes and Coatings, Inc. (TFC);

• As a routine paii of its metal-stripping and -plating operations, defendant TFC generated waste, including substances known as electroless nickel and nickel strip;

• TFC stored that waste in 55-gallon drums for eventual removal and processing by contractors specializing in the treatment and disposal of industrial waste;

• In the spring of 2017, TFC solicited bids from two companies, WasteXpress and Univar, to remove at least 88 drums of electroless nickel and nickel strip;

• WasteXpress, had provided such services to TFC since 2011; it sampled and procured a chemical analysis of the contents of the drums in May 2017 in order to prepare its bid;

• The results of that chemical analysis showed that at least some of the drums were contaminated with Chromium at a level that required the contents to be disposed of as hazardous waste; accordingly, WasteXpress tendered a bid to defendants TFC and Johnson on June 2, 2017, for the removal of the hazardous waste for $375 per drum, with a total contract amount of $39,937 for the disposal of 100 drums; WasteXpress later reduced its quote to $32,437 on June 8, 2017;

• Defendant Johnson rejected WasteXpress's characterization of the drums' contents as hazardous waste, claiming that they contained no chromium and protesting that WasteXpress's rates for disposing of hazardous waste would "bankrupt" TFC;

• On June 6, 2017, Univar tendered a bid for removal of 88 drums of waste at a total cost of $7,876. This bid was based on a US Ecology "waste/material profile form" (a document that US Ecology uses to comply with EPA's regulations on the handling of hazardous waste) that defendant Johnson had completed on June 5, 2017;

• On that document, defendant Johnson certified-contrary to the testing results he had learned of three days earlier from WasteXpress-that the drums contained only non-hazardous material, purportedly based on his own "Process/Generator Knowledge" rather than "Lab Analysis" or relevant materials safety data sheets;

• Based on the defendants ' false description of the waste, in July 2017 Univar transported 107 drums to US Ecology's Idaho facility, which accepted the waste as nonhazardous, for a total cost of $9,796.92-approximately $22,640 less than WasteXpress had quoted for only 100 drums;

• In August 2018, EPA sampled and tested a subsequent batch of putatively nonhazardous waste that TFC had shipped to US Ecology's Idaho facility and confirmed that the later waste also contained chromium in hazardous concentrations.

• Resource Conservation and Recovery Act (RCRA)