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Case 16-42529 Doc 53 Filed 04/13/16 Entered 04113/16 12:50:57 Main Document <br />Pg 13 of 31 <br />26. In addition to the surety bonds described above, the Debtors also maintain <br />the following letters of credit, issued under the Debtors' prepetition revolving credit agreement <br />and accounts receivable securitization facilitya, relating to their workers' compensation <br />obligations: <br />a) A letter of credit in the approximate amount of $32.0 million, <br />issued by PNC Bank, N.A. ("PNC") in favor of Ace and certain <br />Ace affiliates, to secure the Debtors' obligations under the <br />Workers' Compensation Insurance Policy; <br />b) A letter of credit in the approximate amount of $3.2 million, issued <br />by PNC in favor of Old Republic Insurance Company ("Old <br />Republic"), to secure the Debtors' obligations for workers' <br />compensation coverage that the Debtors maintain on certain <br />Residual Self -Insured Claims; <br />C) The following two letters of credit issued by Citibank, N.A. <br />("Citibank" and, with PNC and U.S. Bank, the "Letter of Credit <br />Issuers"), which the Debtors maintain to secure certain workers' <br />compensation obligations of Springfield Coal Company that the <br />Debtors previously assumed: (i) a letter of credit in the <br />approximate amount of $1.9 million in favor of Rockwood <br />Casualty Insurance Company and (ii) a letter of credit in the <br />approximate amount of $1.5 million in favor of Old Republic. <br />d) A letter of credit in the approximate amount of $9.9 million, issued <br />by Citibank in favor of Argonaut, to partially collateralize the <br />Patriot Workers' Compensation Bond. <br />27. Continuation of the Workers' Compensation Prog am. Certain Workers' <br />Compensation Claims may have been incurred or asserted prior to the Petition Date but not yet <br />resolved or paid (collectively, the "Unpaid Workers' Compensation Claims"). For the claims <br />administration process to operate in an efficient manner and to ensure that the Debtors comply <br />with their contractual obligations, the Debtors must continue to assess, determine and adjudicate <br />Unpaid Workers' Compensation Claims during these chapter 11 cases. In addition, to the extent <br />any of the Debtors' employees assert Workers' Compensation Claims, the Debtors request that <br />the Court modify the automatic stay under section 362 of the Bankruptcy Code to permit such <br />-13- <br />