KOPPERS OWNS AND OPERATES A CHEMICAL MANUFACTURING FACILITY LOCATED AT 3900 SOUTH LARAMIE AVENUE, CICERO, ILLINOIS, WHER E IT MANUFACTURES COAL TAR PRODUCTS. CONTIGUOUS WITH THE MA NUFACTURING FACILITY IS THE KOPPERS STICKNEY TERMINAL, A BUL K LOADING AND STORAGE FACILITY OPERATED BY KOPPERS, LOCATED ADJUACENT TO THE CHICAGO SANITARY AND SHIP CANAL ( CANAL ). ON SEPTEMBER 8, 1995, KOPPERS DISCOVERED A SPILL OF APPROXIM ATELY 16,524 GALLONS OF CRUDE COAL TAR WHICH DISCHARGED INTO THE CANAL. THE SOURCE OF THE SPILL WAS A TRANSFER PIPELINE WHICH RAN PARALLEL TO THE CANAL. THE CAUSE OF THE SPILL WAS A RUPTURED WELD JOINT ON A PLATE ON A TEE IN THE TTANSFER PI PELINE. KOPPERS REPORTED THE DISCHARGE TO THE NATIONAL RESP ONSE CENTER ON SEPTEMBER 9, 1995. BOTH THE UNITED STATES EN VIRONMENTAL PROTECTION AGENCY ( U.S. EPA ) AND THE UNITED ST ATES COAST GUARD ( USCG ) RESPONDED TO THE SPILL. DUE TO IT S PHYSICAL CHARACTERISTICS, MOST OF THE CRUDE COAL TAR SETTL ED THROUGH THE WATER COLUMN AND ACCUMULATE ON THE BOTTOM OF THE CANAL. THE LIGHTER FRACTIONS OF OIL IN THE COAL TAR CAUSED A SHEEN ON THE SURFACE OF THE CANAL. U.S. EPA ISSUED A UNILATERAL ADMINISTRATIVE ORDER ( UAO ) TO KOPPERS ON OCTOBER 5, 1995, REQUIRING THE COMPANY TO CLEAN UP THE SPILLED COAL TAR. PURSUANT TO THE UAL, KOPPERS DREDG ED THE CANAL AND REMOVED COAL TAR AND CONTAMINATED SEDIMENTS FROM THE BOTTOM OF THE CANAL.