REFERRAL FOR INJUNCTIVE RELIEF AND CIVIL PENALTIES. DEFENDANT VIOLATED CLEAN AIR ACT AND TENESSEE SIP BY BEGINNING CONSTRUCTION OF MAJOR VOC SOURCE WITHOUT PSD PERMITS. DEFENDANT CONTINUED TO VIOLATE ACT AND SIP BY CONSTRUCTING SOURCE PURSUANT TO INVALID PERMITS THAT DID NOT APPLY BACT. DEFENDANT VIOLATED AN EPA ADMINISTRATIVE ORDER BANNING CONSTRUCTION.