Electrical Cooperatives

Pole-mounted transformers are located on electrical poles within the distribution network, and pad or pole-mounted transformers are located at customers’ facilities. Some older transformers in service may contain PCB-contaminated mineral oils. These transformers can become damaged in storms or other incidents and leak or spill transformer oils, resulting in environmental impacts, including at third-party-owned locations. Third parties could file claims for cleanup and property damage.

At facility yards, electric co-ops store many replacement transformers and other electrical equipment to replace damaged equipment in use. Storage of transformers and equipment at these facilities could lead to leaks and spills of mineral oils that could cause environmental risks.

Transformers and other electrical equipment removed from service require storage at facility sites and either are refurbished or require disposal. Spills or leaks of oils could occur during storage or refurbishing activities, which can migrate into the subsurface or collect in stormwater run-off, resulting in environmental impacts.

Equipment and vehicles utilized by electric co-ops are powered by diesel fuel or other petroleum products and utilize hydraulic fluids and lubricants. The fuels and maintenance fluids may be stored in containers, aboveground, or underground storage tanks. Also, waste oils and fluids may be generated from equipment maintenance. Leaks from equipment or storage areas or spills during refueling or maintenance can contaminate soil or groundwater or be carried by stormwater into storm drainage systems and migrate directly or indirectly to surface waters. Cleaning of vehicles or equipment may generate wastewater or sludge. Spills could occur during cleaning or from waste storage areas, creating environmental risks.

Vehicles and powered equipment, such as forklifts, trucks, and cranes, may be used in electric co-op operations. These types of internal combustion vehicles are powered by diesel or propane, which can emit carbon monoxide gas.

Waste transformer and motor oils, hydraulic fluids, wastewater, and sludge may be generated at electric co-ops. Improper waste disposal could lead to environmental liability or legal consequences for violating regulatory requirements.

Releases may occur during an accident involving a truck transporting transformers or other electrical equipment. The releases may migrate from the roadway and contaminate the surrounding area. The releases may also travel to shallow groundwater or surface water, such as lakes, rivers, streams, or creeks. A release to groundwater could potentially contaminate drinking water sources.

Electric co-ops store electrical poles used in their distribution system in storage yards. They also install or decommission old poles. The poles may be coated with pentachlorophenol, chromated copper arsenate, copper naphthenate, ammoniacal copper zinc arsenate, creosote, or 4.5-di-chloro-2-N-octyl-4-isothiazolin-3-one (DCOI). Excessive release of preservative solutions can occur from the poles. Suppose poles at the yard are not stored off the ground or over a low permeability surface. In that case, they can leach chemicals into soil or groundwater, potentially impacting drinking water sources. Chemicals can also migrate in stormwater to nearby storm drains, drywells, or surface water bodies. Migration of contaminants off-site could result in third-party claims for cleanup, bodily injury, or property damage.

Excavations can be required to remove old poles or install new ones. Soil disturbance can occur, and erosion and sediment can migrate in stormwater to impact nearby surface waters. Contaminated soils could be present in the area of the poles from the leaching of wood preservatives, historical transformer leaks, or other causes. If not properly handled, contaminants could be spread. Improper waste disposal of contaminated soils could lead to environmental liability or legal consequences for violating regulatory requirements.

If not adequately marked, utility lines could be damaged during excavations, releasing sewage or natural gas into the soil, groundwater, or air and lead to third-party property damage or bodily injury claims and cleanup liability.

Pesticides or herbicides usage may control vegetation within transmission or distribution line rights-of-way. Pesticides or herbicides could be carried in winds or stormwater to impact third-party properties, natural resources, or surface water.

Illicit abandonment is the illegal dumping of pollutants on a property by a third party. It can occur at the facilities or in the right-of-way for electric lines of an electric cooperative. It can become the burden of the electric cooperative for cleanup and third-party bodily injury or property damage if law enforcement cannot locate the originator of the waste.

Fires can occur in electrical equipment. Firefighting foam used to extinguish electrical fires can contain PFAS substances. Also, mineral oils can be leaked from equipment damaged in fires. Fire water run-off that contains pollutants can cause environmental impacts on and offsite.