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Freedom Industries Chemical Release

Overview

On January 9, 2014, a mixture containing Crude MCHM and PPH, stripped (Shurflot 944) leaked from aboveground storage tank 396 at Freedom Industries in Charleston, West Virginia. The release entered the Elk River and contaminated the local water supply. WVAW issued a Do Not Use order for about 300,000 residents across portions of nine counties. The CSB final report identified pitting corrosion holes in the tank floor and failed secondary containment as the physical release path. It also documented deficiencies in maintenance, inspection, containment, communication, and emergency planning.

Incident Snapshot

Field Value
Facility / Company Freedom Industries, Inc.
Location Charleston, WV
Incident Date 01/09/2014
Investigation Status The CSB's final investigation report was released on 5.11.2017.
Accident Type Chemical spill contaminates public water supply
Final Report Release Date 05/11/2017

What Happened

  • On January 9, 2014, WVDEP inspectors arrived at the Freedom Industries chemical storage and distribution facility in Charleston, West Virginia, in response to complaints from the public about a chemical odor.
  • WVDEP inspectors discovered a chemical leaking from tank 396, an aboveground storage tank (AST).
  • The chemical mixture escaped tank 396 through two small holes on the tank floor and traveled down a descending bank into the adjacent Elk River.
  • Nearly 11,000 gallons of a mixture containing Crude MCHM and PPH, stripped had already entered into the surrounding soil and Elk River.
  • That evening, WVAW issued a Do Not Use (DNU) order for 93,000 customer accounts (approximately 300,000 residents) across portions of nine counties.
  • On January 10, 2014, WVDEP issued violations to Freedom under the State of West Virginia Water Pollution Control Act, Groundwater Protection Act and Air Pollution Control Act.
  • On January 10, 2014, WVDEP issued a Consent Order to Freedom to begin removing all material from all ASTs and store the material in an offsite area that provided adequate secondary containment.
  • By January 11, 2014, Freedom had removed all of the tank contents from the ASTs and transported it offsite to Poca Blending, LLC in four large banker tanks.
  • On January 15, 2014, WVBPH, in consultation with CDC, issued a drinking water advisory cautioning pregnant women to drink bottled water until there are no longer detectable levels of MCHM in the distribution system.
  • On January 18, 2014, the DNU order was lifted for all areas.
  • On January 21, 2014, the President of Freedom announced that another chemical mixture, PPH, stripped, was also released into the Elk River during the initial spill.
  • On January 27, 2014, the revised total spill estimate was 10,000 gallons.

Facility and Process Context

  • Freedom Industries stored Crude MCHM and PPH, stripped at tank 396.
  • The site had been used for storage of a variety of chemicals in ASTs dating back to the late 1930s under multiple owners and operators.
  • Freedom had ownership of the facility for only nine days prior to the incident.
  • The Freedom facility is located approximately 1.5 miles upstream from the raw water intake of the WVAW Kanawha Valley Treatment Plant.
  • WVAW KVTP is a conventional coagulation and filtration water treatment facility that serves the Kanawha Valley System—a surface water system.
  • Freedom was subject to the West Virginia GPR and was required to have a GPP and secondary containment.
  • Freedom possessed a General WV/NPDES Water Pollution Control Permit for stormwater discharges from the WVDEP on the day of the incident.
  • All facilities covered by the permit must have an SWPPP and a GPP.
  • WVAW decided not to close the water intake and relied on its treatment process, including PAC and GAC to remove the chemicals.

Consequences

  • Fatalities:
  • Injuries: Over 300 members of the public sought medical treatment for potential exposure. 346 patients were treated at local hospitals within 6 days of the release.
  • Environmental Release: Approximately 11,000 gallons of a chemical mixture containing Crude MCHM and PPH, stripped leaked from tank 396 and entered the surrounding soil and Elk River. Freedom revised the spill estimate to 10,000 gallons.
  • Facility Damage: The tanks were demolished; the site no longer has any tanks on the facility and only the office/warehouse, garage and storage buildings remain. The containment wall was in disrepair and was not liquidtight; signs of deterioration and corrosion were visible on tank 396. pitting corrosion degraded the thickness of the tank floor from the interior; deteriorated secondary containment wall; deteriorated underground culvert.
  • Operational Impact: WVAW issued a Do Not Use (DNU) order for 93,000 customer accounts (approximately 300,000 residents) across portions of nine counties. Local businesses were closed; residents were advised to restrict tap water usage and flush pipes; drinking water service was disrupted across multiple areas.

Key Findings

Immediate Causes

  • The chemical mixture escaped tank 396 through two small holes on the tank floor.
  • The holes were caused by pitting corrosion that initiated on the internal surface of the tank floor.
  • Once the mixture escaped tank 396, it moved through the soil beneath the tank and migrated to the Elk River through two pathways: the failing secondary containment wall located between tank 396 and the Elk River, and a deteriorated underground culvert located around tank 396.
  • Once the mixture containing Crude MCHM and PPH, stripped entered the Elk River, it flowed into WVAW’s water intake, located about 1.5 miles away from the Freedom facility site.
  • The water treatment process was not capable of fully treating and removing the chemical.

Contributing Factors

  • The secondary containment or dike wall had cracks and holes from disrepair that allowed tank contents to escape the containment.
  • Freedom was aware of the deteriorated secondary containment wall but did not repair it prior to the incident.
  • Freedom and ERT did not have a program in place to ensure that the ASTs and associated equipment were properly maintained with regular inspection and testing programs.
  • CSB found no documentation of prior inspections or maintenance conducted by Freedom or the prior facility owner, Etowah River Terminal (ERT), which would have identified and addressed internal corrosion in tank 396.
  • Freedom did not have any leak prevention or leak detection system in place as recommended by best practices and industry guidelines, nor did it have an effective leak containment process.
  • The 4- to 6-inch gravel pad directly beneath the tank was highly permeable, through which the tank contents quickly traveled at the onset of the release.
  • Extremely cold weather conditions in early January 2014 may have caused a frost heaving effect in the ground surrounding the Freedom tanks.
  • Movement of the tank bottom or soil beneath the tank may have contributed to the onset of the spill.
  • Freedom did not immediately disclose all chemicals contained in tank 396.
  • Freedom’s communication to the public, state and federal agencies, WVAW and first responders regarding the chemicals and quantity of chemicals involved in the leak was deficient.
  • WVAW was mistakenly informed that Crude MCHM was a flocculant, rather than a frothing agent, and that only 1,000 gallons was released.
  • WVAW assumed its water treatment and filtration system was capable of fully treating and removing the chemicals from the water.
  • WVAW and WVBPH were unable to immediately communicate the risk of drinking water contamination to the public because there were no established sampling methods to determine the concentrations of the chemicals in the water.
  • The Public Water Emergency Annex (B12) of the Kanawha Putnam Emergency Management Plan addressed only isolated water system losses, not the complete loss of the water system.
  • The KPEPC AAR identified the lack of a response plan at the state or county level for Crude MCHM because no information was available on the known hazards of the chemical.
  • The KPEPC AAR identified the lack of a unified command for Kanawha and Putnam counties.
  • The KPEPC AAR identified the exclusion of the county health department from the command and control structure during the incident response.

Organizational and Systemic Factors

  • Freedom and ERT did not validate the integrity of the secondary containment system.
  • Freedom and ERT did not maintain the secondary containment wall that surrounded the tanks despite knowing the wall was in poor condition.
  • Freedom did not have a detailed record of its tank history, maintenance and inspection records for tank 396.
  • Freedom did not voluntarily choose to use recognized industry practices, such as API Standards, to ensure the integrity of a tank.
  • WVAW did not voluntarily request and review publicly available information, such as the Freedom site’s Tier II Emergency and Hazardous Chemical Inventory forms, to understand what chemicals were stored onsite.
  • WVAW was not familiar with the chemical characteristics, sampling methods, or the ability of its filtration system to treat potential leaks of those chemical compounds.
  • Source water protection efforts vary by state, and surface water treatment plants across the United States are subject to different requirements to protect drinking water sources.
  • American Water (AW) provides guidance and some oversight through required policies to its subsidiary water utilities across the United States.
  • AW does not formally monitor or track which plans, policies or procedures are followed by its utilities.
  • WVAW relied on e-mail to capture the decision-making processes post-incident rather than using AW standard ICS and AW Incident Management forms.
  • West Virginia’s Source Water Assessment and Protection Program language was voluntary and the SWAP protection plan was not required.
  • WVAW never finished conducting interviews with commercial entities of concern as part of its voluntarily developed SWAP protection plan.
  • CSB did not find evidence indicating that WVAW surveyed the Freedom site to assess the risk of potential spills into the Elk River.
  • The KPEPC did not have a detailed response plan for Freedom because it was neither a production facility nor a facility that stored extremely hazardous substances.
  • The KPEPC consists of 15 Board Members and about 120 members, and includes ten annex committees.
  • The KPEPC is responsible for emergency planning and processing of public information requests associated with the use and transport of chemicals in the area.
  • The KPEPC’s major activities include response planning, conducting emergency drills and functioning as an information source on chemicals for the community.

Failed Safeguards or Barrier Breakdowns

  • No documentation of prior inspections or maintenance conducted by Freedom or ERT that would have identified and addressed internal corrosion in tank 396.
  • No leak prevention system.
  • No leak detection system (LDS).
  • No effective leak containment process.
  • The secondary containment wall had cracks and holes from disrepair.
  • The dike walls were in poor condition.
  • The culvert beneath the site was deteriorated.
  • Freedom had no additional leak containment supplies onsite.
  • Freedom did not have a detailed record of its tank history, maintenance and inspection records for tank 396.
  • Freedom did not have a program in place to ensure that the ASTs and associated equipment were properly maintained with regular inspection and testing programs.
  • WVAW did not have established sampling methods to determine the concentrations of the chemicals in the water.
  • WVAW’s water treatment and filtration methods were unable to treat and remove all of the chemical mixture in its water treatment process.
  • Public Water Emergency Annex (B12) addressed only isolated water system losses, not the complete loss of the water system.
  • Lack of a response plan at the state or county level for Crude MCHM.
  • Lack of a unified command for Kanawha and Putnam counties.
  • Exclusion of the county health department from the command and control structure during the incident response.
  • Freedom did not provide reliable information during the first week of the incident.
  • Freedom did not immediately disclose all chemicals contained in tank 396.
  • Freedom would not or could not provide an accurate estimate of the quantity of chemicals that leaked.
  • WVAW was not provided any notification about the Freedom tank contents.

Recommendations

  1. 2014-01-I-WV-R1 | Recipient: The American Water Works Association | Status: Closed – Acceptable Action | Summary: Communicate the findings, lessons learned and recommendations contained within this report to all American Water Works Association members. Emphasize the importance of source water protection planning, emergency planning, and coordination with local, state and federal entities, and the public, to ensure timely notification of potential water contamination events and emergencies.
  2. 2014-01-I-WV-R2 | Recipient: American Water Works Company, Inc. | Status: Closed – Acceptable Action | Summary: Establish requirements for all American Water state utilities’ surface water treatment plants to undertake the following activities: 1. Conduct an inventory of all hazardous chemicals or classes of hazardous chemicals that are considered a potential source of significant contamination stored in the utility’s most vulnerable source water protection area (e.g., Zone of Critical Concern). Chemicals may be identified by accessing publicly available information, which may include Tier II reporting forms submitted to local emergency planning committees and electronically available information from federal, state or local databases. 2. For each inventoried chemical or class of chemicals, conduct a prioritized assessment to determine if existing analytical methods are available to detect the presence and/or concentration of the chemical or class of chemicals in the event of a release to the water supply and if the chemical or class of chemicals is capable of being treated or removed by the utility’s water treatment process. 3. For all chemicals or classes of chemicals that are not capable of being treated or removed by the treatment process, develop a contingency plan to respond to contamination events (e.g., as modeled by WVAW’s Kanawha Valley Water System June 2016 Source Water Protection Plan).
  3. 2014-01-I-WV-R3 | Recipient: Eastman Chemical Company | Status: Closed – Acceptable Action | Summary: Update appropriate sections of the Crude MCHM Safety Data Sheet to include toxicological and ecological information based on the June 1, 2016, National Toxicology Program’s toxicity evaluation of Crude MCHM. Include information about the effects of Crude MCHM on fetal and early life growth and development. Distribute the revised Crude MCHM SDS to all customers that previously received and are currently using or storing MCHM from Eastman, and ensure all new MCHM customers receive the revised SDS with shipment.

Key Engineering Lessons

  • Internal pitting corrosion in tank bottoms can create through-wall holes and an active leak path even when the tank remains in service.
  • Secondary containment that is cracked, holed, or otherwise not liquidtight can fail to prevent migration of released material to nearby surface waters.
  • Visual-only leak detection and inspection are inadequate when tank bottoms and containment areas are dirty, muddy, or otherwise not readily inspectable.
  • A tank located near a drinking water intake requires source water protection planning that accounts for hazardous chemicals stored nearby and the ability, or inability, of the treatment process to remove them.
  • If a utility cannot reliably detect or treat a contaminant, a contingency plan is needed before a release occurs.

Source Notes

  • Priority 1 final report used as the primary authority for incident facts, causes, consequences, and recommendations.
  • Recommendation status values were normalized to the final status in the recommendation status change summaries where available.
  • Supporting documents were used only to supplement or clarify facts already present in the final report, especially for metallurgical findings and recommendation closure status.
  • No external facts were added beyond the provided extracts.

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