VIOLATIONS - 1) FAILURE TO GET A CONSTRUCTION PERMIT PRIOR TO CONSTRUCTION OF THE TWO NEW GENERATORS. ARD ENGINEER IS LOREN DENTON. THIS CASE INVOLVES THE VILLAGE OF FREEBURG (FREEBURG) THAT OWNS AND OPERATES A POWER (ELECTRICITY) PEAKING PLANT IN FREEBURG IL WHICH IS IN A MODERATE NON-ATTAINMENT AREA FOR OZONE. THE FACILITY HAS A TOTAL OF EIGHT GENERATORS. SIX GENERATORS WERE CONSTUCTED DURING THE 1950'S OR 1960'S AND ARE NOT DIRECTLY AT ISSUE IN THIS CASE. THE LAST TWO GERNERATORS WERE CONSTRUCTED WITHOUT A CONSTRUCTION PERMIT IN MARCH 1997 AND ARE THE SUBJECT OF THE CONTROVERSY AT HAND. PLEASE NOTE THAT, ALTHOUGH FREEBURG NEVER HAD A CONST RUCTION PERMIT, IT APPLIED FOR A CONSTUCTION PERMIT SHORTLY AFTER IT BEGAN CONSTURCTION OF THE TWO GENERATORS. FREEBURG HAD PREVIOUSLY FILED AN APPLICATION FOR A TITLE V PERMIT, (ALTHOUGH IT IS QUESTIONABLE WHETHER FREEBURG EVEN NEEDED SUCH A PERMIT). THE STATE OF IL ISSUED THE TILE V PERMIT BUT NOT THE CONSTRUCTION PERMIT. CURRENTLY, FREEBURG HAS A FEDERALLY ENFORCEABLE STATE OPERATING PERMIT (FESOP) APPLICATION PENDING. THE FESOP, IF GRANTED, WILL GIVE FREEBURG A SYNTHETIC MINOR EMISSION LIMITS FOR THE TWO NEW GENERATORS. THIS CASE WAS INITIATED BY DINA DALIANIS (AND PROGRAM) IN 1998, AND THE NOV WAS ISSUED ON SEPTEMBER 28, 1998. AT THE TIME OF THE ISSUANCE OF THE NOV, EPA