Respondent is a municipality in the state of Kansas, which owns and operates a Water Treatment Plant. On or about August 24, 2016, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than 2,500 pounds of Chlorine in a process at its facility. From the time Respondent first had onsite greater than 2,500 pounds of Chlorine in a process, Respondent was subject to the requirements of Section 112(r) of the CAA, 42 U .S.C. § 7412(r), and 40 C.F .R. Part 68 because it was an owner and operator of a stationary source that had more than a threshold quantity of a regulated substance in a process. From the time Respondent first had onsite greater than 2,500 pounds of Chlorine in a process, Respondent was subject to Program 2 prevention program requirements because pursuant to 40 C.F .R. § 68.10( c), the process does not meet the eligibility requirements of either Program 1 or Program 3, as described in 40 C.F.R. § 68.10(b) and (d), respectively. Complainant hereby states and alleges that Respondent has violated the CAA and federal regulations promulgated there under as follows: