Jackson Electric Cooperative stored hundreds of kilograms of PCB-contaminated transformers — one of the most notorious toxic chemicals ever manufactured — and never once checked them for leaks across a span of at least three years.

They Stored Poison and Kept No Records

Polychlorinated biphenyls — PCBs — were banned in the United States in 1979 because they cause cancer, destroy the immune system, and persist in the environment for decades. Jackson Electric Cooperative, a utility serving rural Wisconsin, sat on a registered stockpile of PCB-contaminated electrical equipment and treated federal safety rules like optional suggestions.

Federal inspectors found four separate categories of violations when they arrived at the cooperative’s facility on County Road F in Black River Falls. The violations were not about paperwork for its own sake. Every missing record, every absent inspection log, every wrong manifest form represented a moment where a leak could have gone undetected, where toxic material could have entered the ground, the water, or the air, and no one would have known.

Jackson Electric paid $8,230 (roughly what a working family spends on groceries for a year) to make all of it go away.

The Non-Financial Ledger

What Was Actually Sitting in That Storage Area

PCBs are not an abstract regulatory concept. The EPA banned them over 45 years ago because the science was unambiguous: these synthetic chemicals accumulate in fat tissue, travel up the food chain, and cause cancer, liver damage, immune suppression, hormonal disruption, and developmental harm in children. Jackson Electric’s facility in Black River Falls was a registered PCB storage site, meaning the federal government knew the toxins were there, and established a strict protocol specifically to prevent them from leaking into the surrounding environment.

That protocol required someone at the facility to physically inspect the PCB storage area every 30 days without exception. The point of those checks was to catch leaking containers before the contents made it into the soil or groundwater serving the surrounding community. Jackson Electric conducted zero documented inspections between 2020 and 2023. When EPA inspectors asked for the records, the cooperative stated no such records existed. The community around Black River Falls had no way of knowing this was happening.

In 2021, Jackson Electric removed two PCB-contaminated transformers from service, together weighing 304 kg (that is roughly the weight of a full-grown grizzly bear in toxic industrial waste), stored them on site, and then shipped them off without using a proper federal hazardous waste manifest. In 2022, the cooperative removed three more transformers, one of which tested above the critical 500 ppm PCB threshold — the concentration level at which regulators classify equipment as a full PCB transformer, the most dangerous category. That 2022 batch weighed 413 kg, the equivalent of shipping half a grand piano’s worth of some of America’s most banned industrial chemicals with essentially no paper trail.

The original 2022 annual document log that Jackson Electric handed to federal inspectors stated that zero PCB waste was disposed of that year. Zero. The cooperative corrected this only after inspectors pushed back and requested follow-up documentation. The revised figure was 412.31 kilograms. The gap between “zero” and 412 kilograms is the gap between what a company reports when no one is watching and what actually happened. That gap, sitting in a storage area with no leak records and no verified containment checks, is the real story here.

A Community Left in the Dark

Black River Falls, Wisconsin sits in Jackson County, a rural community built around timber, agriculture, and the Ho-Chunk Nation’s homeland. The people who live and farm near County Road F had no independent access to Jackson Electric’s inspection records. They could not have known whether the containers in that storage area were leaking. They had to trust that their electric cooperative was following the rules designed to protect them. That trust was misplaced.

The EPA’s settlement agreement notes that Jackson Electric “neither admits nor denies” the factual allegations. The cooperative waived its right to any hearing or appeal and paid the fine. There is no record in the source material of any community notification, any environmental sampling of soil or groundwater near the facility, or any remediation effort. The transaction was entirely between the corporation and the federal government. The people living down the road from that PCB storage area were not part of the conversation.

Legal Receipts

The Documents Don’t Lie. They Aren’t Even Trying To.

“At the time of the Inspection, Respondent did not provide records of inspection of the storage area for the years 2020-2023, and stated that no such records existed.” — EPA Region 5 Consent Agreement, Paragraph 39; Count 1 (Inspection of Storage for Disposal)

“At the time of the Inspection, the Facility’s annual document log for calendar year 2022 stated that no PCB waste was disposed of in 2022. Respondent subsequently provided a corrected annual document log for the calendar year 2022 stating that 412.31 kg of PCB waste was disposed in 2022, including 104.31 kilograms of PCBs over 500 ppm.” — EPA Region 5 Consent Agreement, Paragraph 53; Count 3 (Annual Document Logs)

“Respondent stated that it did not test or analyze the concentration of electrical equipment sent off site for disposal. The Respondent stated it relied on the disposal facility to test the concentration of PCBs in the electric equipment prior to disposal.” — EPA Region 5 Consent Agreement, Paragraph 61; Count 4 (Manifest — General Requirements)

“Respondent failed to use a U.S. EPA Form 8700-22 manifest to ship PCB-contaminated and PCB Transformers off site on April 7, 2021 and April 6, 2022 thereby violating 40 C.F.R. §§ 761.207(a) and 761.210(a) and (b).” — EPA Region 5 Consent Agreement, Paragraph 64; Count 4 (Manifest — General Requirements)

“Respondent’s failure to perform inspections of the storage area and maintain records of inspections constitute a violation of 40 C.F.R §§ 761.65(c)(5) and 761.180(a)(1)(iii).” — EPA Region 5 Consent Agreement, Paragraph 40; Count 1 Finding

Societal Impact Mapping

Public Health: The Biology of PCB Exposure

PCBs are classified as probable human carcinogens by the EPA and as known carcinogens by the International Agency for Research on Cancer. Exposure routes include contaminated water, soil contact, and inhalation of vapors from leaking equipment. The transformers Jackson Electric stored and shipped contained PCB concentrations ranging from over 50 ppm up to over 500 ppm, with the highest-concentration material sitting in a storage area that was never inspected for leaks.

The 30-day inspection requirement that Jackson Electric ignored exists precisely because PCB-containing equipment degrades, seals crack, and fluid migrates. A single undetected leak in an outdoor or partially enclosed storage area can introduce PCBs into storm runoff, soil, and ultimately groundwater. Rural communities that rely on private wells are disproportionately at risk because their water supply lacks the filtration infrastructure of municipal systems. Black River Falls is a rural community. That is not a coincidence; it is a pattern.

Children face compounded risk. PCBs are endocrine disruptors, meaning they interfere with hormone development. The documented effects in children include reduced IQ, impaired motor function, and disrupted immune development. When a utility company stores PCB equipment without conducting mandatory monthly leak checks and without producing proper disposal paperwork, those are the stakes being gambled with. The settlement did not include any requirement to test soil, water, or air near the facility.

Environmental Degradation: No Chain of Custody, No Accountability

The federal hazardous waste manifest system, specifically EPA Form 8700-22, exists to create an unbroken chain of custody from the moment a generator removes toxic material from service to the moment a licensed facility destroys it. Jackson Electric bypassed that system twice: once in April 2021 using a straight bill of lading, and again in April 2022 using a non-hazardous waste manifest. The 2022 shipment was initially manifested as 25 items but adjusted to 22 items after the destination facility performed its own testing, because Jackson Electric never tested the PCB concentrations of the equipment it sent out.

When a generator does not test its own waste and does not use the correct federal manifest, regulators lose the ability to verify that every kilogram of toxic material was actually accounted for at the receiving end. The source documents confirm that the destination facility, A-Line EDS, performed the testing instead. That arrangement means the generator, the entity with the most direct knowledge of what was in their own storage area, was the only party in the chain that was not doing its required job. 717 kg of PCB waste moved through Wisconsin’s roads and highways under documentation that federal law explicitly prohibits.

Economic Inequality: Rural Communities Pay the Hidden Tax

Jackson Electric Cooperative serves a rural area of Wisconsin. Electric cooperatives operate as membership utilities, theoretically accountable to their residential and agricultural members. But the accountability gap exposed here runs in one direction: the members bore the environmental risk while the cooperative deferred the administrative burden of compliance. A failure to inspect for leaks is not a paperwork violation; it is a decision that the cost of someone’s time is more valuable than the safety of the surrounding land and water.

The $8,230 fine ($8,230 — less than the median American worker earns in two months) was set by the EPA after considering the cooperative’s “ability to pay” and “effect on ability to continue to do business.” The penalty calculation was designed, by law, to avoid inconveniencing the company. There is no equivalent protection written into the settlement for the people who live near County Road F. The asymmetry is structural, and it runs across every case like this one: fines calibrated to corporate comfort, risks allocated to communities with no seat at the negotiating table.

The Cost of a Life Metric

What Now?

The People Responsible and The People Who Should Be Watching

The consent agreement was signed by Jackson Electric Cooperative’s General Manager / Chief Executive Officer (name not published in the source document). That individual certified that the cooperative is now in compliance with TSCA. Whether that certification is meaningful depends entirely on whether regulators follow up.

• U.S. EPA Region 5 (Chicago): The agency that brought this action and accepted the settlement. Demand that Region 5 conduct a follow-up inspection verifying current compliance, and that any soil or groundwater sampling near the Black River Falls facility be made public.
• Wisconsin Department of Natural Resources (WDNR): State environmental enforcement has independent authority to investigate PCB contamination. Contact WDNR’s Environmental Enforcement section and ask whether they were notified of these federal violations.
• EPA Office of Inspector General: The OIG monitors whether EPA penalty calculations adequately deter violations. A fine calibrated to avoid inconveniencing a company is a policy choice, not an inevitability. Document and submit formal comments on enforcement adequacy.
• Jackson Electric Cooperative Board of Directors: As a member-owned cooperative, residents in the service area have standing to attend board meetings, request inspection records and compliance certifications, and vote on leadership accountability.
• Ho-Chunk Nation Environmental Department: The Ho-Chunk Nation maintains sovereign environmental jurisdiction in this region of Wisconsin and has a direct interest in PCB contamination monitoring near their homeland.

The communities nearest to industrial storage sites like this one rarely have the legal resources or institutional access of the corporations that operate them. Local mutual aid networks, tribal environmental coalitions, and rural water-quality watchdog groups are the most effective pressure points when federal enforcement settles for a fine and closes the file. Connect with neighbors, share public records, and make noise at cooperative board meetings. The settlement agreement is public. You are holding the receipts right now.