Respondent is a municipality doing business in the Commonwealth of Kentucky. On November 13, 2014, the EPA issued to Respondent a notice of potential violation (“NOPV”), providing notice that the EPA found that Respondent had potentially committed the alleged violations described in Section E of this Agreement and providing Respondent an opportunity to confer with the EPA. On July 14, 2015, and October 14, 2015, representatives of Respondent and the EPA discussed the November 13, 2014, NOPV. Respondent operates a “stationary source” as that term is defined by Section 302(z) of the Act, 42 U.S.C. § 7602(z). Respondent has submitted and registered an RMPlan to the EPA for its stationary source and has developed an RMProgram accidental release prevention program for the stationary source: