EPA REQUESTS THAT DOJ SEEK ALL APPROPRIATE RELIEF AND FILE A PROOF OF CLAIM RELATED TO EPA'S RCRA AND CERCLA CLAIMS IN THE WALTER ENERGY BANKRUPTCY AND IF NEEDED, OBJECT TO ANY ATTEMPT BY THE DEBTOR TO ABANDON THE WALTER COKE FACILITY OF AN ACCEPTABLE SETTLEMENT TO CONTINUE OPERATIONS AT THE WALTER COKE FACILITY CANNOT BE REACHED DURING THE BANKRUPTCY PROCEEDING. SHOULD THIS HAPPEN, EPA REQUESTS THAT DOJ SEEK ALL APPROPRIATE RELIEF TO SECURE MAXIMUM FUNDING TO ADDRESS THE ENVIRONMENTAL CONCERNS AT THE FACILITY. EPA ALSO REQUESTS THAT DOJ SEEK REIMBURSEMENT FOR THE EPA'S CERCLA CLAIMS.