A settling CAA and CWA defendant that allegedly failed to obtain a modification to its title V CAA permit before its hydrolyzed protein powder facility in Delhi, New York, became a major source of volatile organic compound (VOC) emissions; perform a reasonably available control technology (RACT) demonstration and implement RACT before commencing operation of a major source of VOC emissions; obtain a permit before constructing a new, modified, or existing air contamination source at the facility; and report and maintain annual reports of its VOC emissions must reduce harmful toluene emissions through the installation and operation of pollution controls, comply with its permits, and pay a $2,880,000 civil penalty.