PROOF OF CLAIM IN CHAPTER 11 PROCEEDING ARISING FROM THE FAILURE TO MAKE PAYMENT AS REQUIRED BY A CIVIL CONSENT DECREE WITH JOHNS INSULATION. DEFENDANT AGREED TO PAY FOR ITS PAST VIOLATIONS OF THE CAA, SECTIONS 110 AND 113, AGREEING THAT IN ANY ACTION WHERE THE U.S. WAS FORCED TO COLLECT ANY DELINQUENT MONIES. THE VALIDITY, AMOUNT AND APPROPIATENESS OF THE PENALTY AND OF THE CONSENT DECREE WAS NOT SUBJECT TO REVIEW. EPA RECOMMENDS THAT A PROOF OF CLAIM BE FILED FOR THE UNCOLLECTED PENALTY. ALL ENVIRONMENTAL VIOLATIONS OCCURRED PRE PETITION.