IN 1981, COORS RECEIVED A PSD PERMIT FROM EPA TO CON- STRUCT A BREWERY IN ELKTON, VIRGINIA. IN 1984, AFTER HAVING BEEN DELEGATED THE AUTHORITY TO ADMINISTER THE PSD PROGRAM, VIRGINIA ISSUED A NEW PSD PERMIT THAT SUPERSEDED THE 1981 PERMIT. COORS REQUESTED SEVERAL EXTENSION TO THIS PERMIT, ALL OF WHICH WERE GRANTED WITH THE CONDITION THAT, PRIOR TO COMMENCING CONSTRUCTION OF THE BREWERY, COORS DEMONSTRATE COMPLIANCE WITH ALL PSD REQUIREMENTS. THIS INCLUDES PER- FORMING NEW BACT AND MODELING ANALYSES. DURING A MARCH 7, 1991 EPA INSPECTION, EPA LEARNED THAT COORS HAD INSTALLED AN EMISSION SOURCE FOR THE BREWERY THAT HAD NOT BEEN INCLUD- ED IN THE PERMIT, AND THAT COORS DID NOT COMPLETE THE RE- QUIRED PSD REVIEW PRIOR TO BEGINNING THAT CONSTRUCTION.