CASE INCLUDES NUMEROUS WORK PRACTICE, TESTING AND RECORDKEEPING VIOLATIONS OF PHARMAMACT LEAK DETECTION AND REPAIR (LDAR) PROVISIONS. VIOLATIONS PERTAIN TO PRESSURE TESTING CARRIED OUT TO DEMONSTRATE LDAR PROGRAM COMPLIANCE, SPECIFICALLY, FAILURE TO SEAL OPEN-ENDED LINES, TO REPAIR LEAKS AND RETEST LEAKING PROCESS EQUIPMENT, TO CONDUCT PROPER GAS-BSED AND LIQUID-BASED TESTS, AND TO KEEP ADEQUATE RECORDS.