Pharmacia & Upjohn is primarily engaged in manufacturing, fabricating, or processing drugs in pharmaceutical preparations for human or veterinary use. The manufacturing of these pharmaceuticals requires the use of multiple hazardous air pollutants (HAPs), which makes the processing equipment subject to the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for the Pharmaceutical Productions. Section 63.1255 of the regulations requires that monitoring comply with EPA reference Method 21. On November 1, 2004, EPA issued Findings of Violation to Pharmacia & Upjohn Company for alleging violations of the Pharmaceutical Productions NESHAP requirements. EPA found that Pharmacia & Upjohn failed to monitor its process components subject to LDAR requirements in accordance with EPA Reference Method 21. As part of the settlemet documented in the CAFO, an enhanced leak detection and repair program will be taken on by Pharmacia & Upjohn for a one-year period. Also, Pharmacia will replace 8 pumps and 3 agitators with sealess technology to decrease fugitive emissions. These projects are estimated to reduce HAPs emissions by at least 23.44 tons.