Respondents Andrew B. Chase a/k/a Andy Chase, Chase Services, Inc., Chase Convenience Stores, Inc., and Chase Commercial Land Development, Inc. appeal from an initial decision imposing a $127,069 civil penalty on them for violations of section 9006 of the Solid Waste Disposal Act, 42 U.S.C. § 6991e, and associated regulations at 40 C.F.R. part 280.