C&D failed to conduct performance testing of all of its sources of lead emissions subject to Subpart PPPPPP and Section 112 of the Act, 42 U.S.C. § 7412. EPA issued a Finding of Violation to C&D on April 27, 2010 and held a Section 113 conference with the company on May 27, 2010. EPA issued an Administrative Consent Order (ACO) to C&D on September 30, 2010, requiring C&D to conduct the required testing. C&D completed testing and submitted test results to EPA in accordance with the ACO. All tests demonstrate compliance with subpart PPPPPP. On March 31, 2011, EPA filed and Administrative Complaint assessing a penalty of $148,711. The CAFO requires C&D to pay a cash penalty of $26,000, in consideration of C&DÂs cooperation in this matter, expeditious return to compliance, and performance of a Supplemental Environmental Project. Specifically, C&D will replace its dust collector with a new model that has a higher removal efficiency for particulate matter. C&D's particulate matter is mostly lead, so this will achieve lead and PM emissions reductions by about 33 percent.