US EPA requests that the DOJ commence proceedings under Section 104 of CERCLA for the purpose of securing ex parte judicial orders in aid of access at the Lake Calumet Cluster site. Ex parte judicial orders in aid of access are necessary to permit access to further inspect and sample abandoned hazardous waste and to facilitate the performance of a remedial investigation and feasibility study (RI/FS) for Operable Unit Two (groundwater operable unit).