Respondent is a municipality doing business in the Commonwealth of Kentucky. On October 27, 2015, the EPA issued to Respondent a notice of potential violation ("NOPV"), providing notice that the EPA found that Respondent had potentially committed alleged violations and providing Respondent an opportunity to confer with the EPA. On April 5, 2016, and May 26, 2016, representatives of Respondent and the EPA discussed the October 27, 2015, NOPV. For the purpose of this Agreement:

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