THIS REFERRAL IS PART OF A MULTI-REGIONAL REFERRAL BEING LEAD BY REGION 7. EARTHGRAIN'S IS A LARGE BAKERY OPERATION WITH 66 FACILITIES NATIONWIDE AND 18 FACILITIES LOCATED IN REGION 4. AS PART OF A MULTI- REGIONAL REFERRAL, REGION 4 STAFF IDENTIFIED 1,687 VIOLATIONS AT 17 OF THE 18 FACILITIES LOCATED IN REGION 4. IN ITS BAKING PROCESS, EARTHGRAIN FACILITIES USE LARGE INDUSTRIAL CHILLERS OR LARGE COMPRESSORS THAT CONTAIN OVER 50 POUNDS OF CLASS I OR CLASS II REFRIGERANT. THE USE OF THESE REFRIGERANTS IS REGULATED UNDER SECTION 608 OF THE CAA AND 40 CFR PART 82, SUBPART F. THE PENALTY CALCULATION FROM THE PENALTY POLICIES FOR THE FACILITIES IN REGION 4 IS $20,282,419 -- AN AVERAGE OF OVER $1 MILLION PER FACILITY. THE STATUTORY MAXIMUM PENALTY FOR ALL VIOLATIONS IN REGION 4 IS $47,302,500. THE REFERRAL, HOWEVER, DOES NOT INDICATE A PARTICULAR SUGGESTED SETTLEMENT AMOUNT. SINCE OTHER REGIONS ARE ALSO GENERATING LARG PENALTY CALCULATIONS, THE LITIGATION TEAM HAS ELECTED TO DEFER THE SELECTION OF A BOTTOM-LINE SETTLEMENT UNTIL AFTER ALL OF THE REFERRALS ARE SUBMITTED AND EACH REGION HAS A CHANCE TO PROVIDE INPUT INTO HOW A POSSIBLE SETTLEMENT CAN BE STRUCTURED. NOT ALL OF THE REGIONS HAVE FURNISHED THEIR REVIEWS SO WE DO NOT YET KNOW HOW MANY FACILITIES NATIONWIDE (OUT OF 66) ARE IN VIOLATION, NOR DO WE KNOW HOW THE