Management of PCBs in Gas Transmission Systems

  • Client: Natural Gas Distributors
  • Date: 2009
  • Location: Illinois


In response to the discovery of liquid containing polychlorinated-biphenyls (PCBs) within their natural gas distribution systems, Schiff Hardin's clients, two major natural gas distribution companies, decided to disclose the issues to the U.S. Environmental Protection Agency (EPA).

EPA and the Illinois Attorney General required each company to embark on an extensive investigation into PCB Mega Rule compliance. In a case of first impression in Illinois and in Region 5, Schiff Hardin's attorneys, working with leading experts, developed "best management" sampling practices and reporting strategies to identify and manage the presence of PCBs in the system. The approach our attorneys and clients took with the Illinois Attorney General and EPA resulted in a cooperative relationship with the regulators and no enforcement action has been pursued. Many of the "best management practices" developed have been embodied in and serve as a national model.