UNIVERSITY OWNS AND OPERATES A COGENERATION SYSTEM AT ITS BERRY HOLDING COMPANY OPERATIONS. THE FACILITY CON- SISTS OF A GAS TURBINE AND A WASTE HEAT BOILER FIRED BY DUCT BURNERS. PURSUANT TO THE NEW SOURCE PERFORMANCE STANDARDS, UNIVERSITY IS REQUIRED TO NOTIFY EPA OF CONSTRUC- TION, AND STARTUP, AND TO PERFORM CERTAIN EMISSIONS TEST. UNIVERSITY DID NOT PROVIDE SOME OF THE REQUIRED NOTIFICATION AND ALSO DID NOT PERFORM EMISSIONS TEST ON THE DUCT BURNERS.