UNION GAS ( BRODHEAD CREEK SITE, STROUDSBURG, PA.). UNION GAS COMPANY (UNION GAS) IS A NATURAL GAS DISTRIBUTOR IN STROUDSBURG, PA. UNION GAS IS A SUCCESSOR TO A SERIES OF CORPORATIONS, WHICH OPERATED A COAL GASIFICATION PLANT UNTIL 1945 ON PROPERTIES PRESENTLY OWNED BY UNION GAS & PA. POWER & LIGHT CO. CITIZENS GAS CO., ONE OF UNION GAS'S CORP. PREDECESSORS, DISPOSED OF COAL TAR WASTES FROM THE COAL GASIFICATION PROCESS BY INJECTING WASTES INTO A GRAVEL LAYER BENEATH THE SURFACE OF ITS PROPERTY, NOW THE PROPERTY OF UNION GAS & PA. POWER & LIGHT CO. THE COAL TAR MIGRATED WITH THE GROUNDWATER TOWARD BRODHEAD CREEK, WHERE IT WAS OBSERVED SEEPING ONTO THE CREEK BANK IN OCT., 1980. AT THAT TIME, A TRENCH DUG BY THE PA. DEP . OF GEN. SERVICES FILLED UP WITH COAL TAR. EPA HAS SINCE OBSERVED COAL TAR SEEPING INTO BRODHEAD CREEK ITSELF. COAL TAR CONTAINS CHEMICALS SUCH AS NAPTHALENE, BENZENE, ANTHRACENE, & PHENANTHRENE, WHICH ARE HAZD SUBSTANCES UNDER THE COMPREHENSIVE ENV. RESPONSE, COMPENSATION, & LIABILITY ACT OF 1980 (CERCLA), 42 U.S.C. SS9601-9657. AFTER GIVING AN ORAL DEMAND TO UNION GAS AND 3 OTHER LANDOWNERS WHOSE PROPERTIES LIE OVER THE COAL TAR BED, EPA SPENT $464,500 IN AN EMERGENCY RESPONSE ACTION TO BLOCK THE CONT. SEEPING OF COAL TAR INTO BRODHEAD CREEK. INVEST. ARE UNDERWAY TO DETERMINE WHETHER REMEDIAL RESPONSE ACTION IS NEEDED. EPA'S EXP