Chippewa Hazardous Waste, Inc. (Chippewa) appeals an Initial Decision of Administrative Law Judge (ALJ) William B. Moran assessing a civil penalty of $45,040 for violations of section 112 of the Clean Air Act (CAA), 42 U.S.C. §7412, and certain regulations appearing at subpart M (National Emission Standard for Asbestos) of the National Emission Standards for Hazardous Air Pollutants (NESHAP), 40 C.F.R. part 61, arising from Chippewa's removal of asbestos-containing roofing shingles from a church building.