ARCH COAL IS THE PARENT COMPANY OF ICG, INC., ARCH COAL, AND ICG, INC., FILED FOR BANKRUPTCY JANUARY 11, 2016. THE CWA CD WITH ARCH COAL AND OCG WAS ENTERED ON 2/23/16. THE $2 MILLION PENALTY IN THE CD HAD NOT BEEN PAID WHEN ARCH FILED FOR BANKRUPTCY. THE CD WAS PART OF A MULTI-REGION ENFORCEMENT INITIATIVE WITH REGION 3 AS THE LEADER BECAUSE MOST OF THE PERMIT VIOLATIONS WERE AT FACILITIES LOCATED IN REGION 3. A BANKRUPTCY REFERRAL TRANSMITTED BY EPA REGION 3 AND THIS BANKRUPTCY REFERRAL BY REGION 4 DESCRIBE EPA'S CLAIMS TO SUPPORT FILING A BANKRUPTCY PROOF OF CLAIM.