CARGILL FAILED TO COMPLY WITH SPECIFIC REQUIREMENTS OF THE PHARMACEUTICAL MACT INCLUDING FAILURE TO PROPERLY MONITOR EQUIPMENT SUBJECT TO LEAK DETECTION AND REPAIR REQUIREMENTS AND FAILURE TO IDENTIFY WASTEWATER AT THE FACILITY SUBJECT TO THE EMISSION CONTROL REQUIREMENTS. AS PART OF THE SETTLEMENT, CARGILL WILL IMPLEMENT AN ADVANCED LEAK DETECTION PROGRAM AND CONDUCT A SEP THAT WILL REPLACE CERTAIN PUMPS AT THE FACILITY WITH SEALLESS PUMPS.