THIS IS AN ADMINISTRATIVE SETTLMENT FOR ALLEGED CAA TITLE v PERMIT VIOLATIONS. THE SETTLEMENT PENALTY WAS SUBSTANTIALLY REDUCED BECAUSE OF VICTORY'S DOCUMENTED INABILITY TO PAY. AS AUTHORIZED BY EPA's HEARING RULES, THIS CAFO WAS ISSUED WITHOUT AN ACCOMPANYING ADMINISTRATIVE COMPLAINT, SO THERE WAS NO INITIAL PROPOSED PENALTY IN THIS CASE. YVICTORY FAILED TO MONITOR OPERATIONS, KEEP RECORDS, AND SUBMIT REPORTS. IN ADDITION, IT USED COATINGS AND PAINTS WITH VOC CONTENT ABOVE THE ALLOWABLE LEVEL.