STORAGE TANK CORROSION FAILURE — DRINKING WATER CONTAMINATION
Freedom Industries Chemical Release
Freedom Industries, Inc.
📍 Charleston, WV
Incident: January 9, 2014  •  CSB Report: May 11, 2017
0
Fatalities
Crude MCHM (4-Methylcyclohexane Methanol) -- Coal Processing Chemical
Chemical Involved
3
CSB Recommendations
📋 Incident Summary

On January 9, 2014, a corroded storage tank at Freedom Industries in Charleston, West Virginia, leaked crude MCHM (4-methylcyclohexane methanol) -- a coal processing chemical -- into the Elk River, just 1.5 miles upstream from the intake for the West Virginia American Water treatment plant. The contamination left approximately 300,000 residents without clean drinking water for days, with a characteristic licorice odor detected across the affected area.

The CSB investigation found that the leaking tank had never been inspected under API 653 (the storage tank inspection standard). Water was entering the tank through holes in the tank roof and accelerating corrosion of the tank bottom -- a failure that was preventable with basic inspection and maintenance. Freedom Industries had no record of any inspection on the tank.

The May 2017 final report issued 3 recommendations to the American Water Works Association, American Water Works Company, and Eastman Chemical -- focusing on source water protection planning, utility contingency plans for untreatable chemical contamination, and updated toxicological data on crude MCHM. All 3 recommendations were closed.

🔎 Key Findings
Finding 01
Corroded Tank Leaked MCHM Into Drinking Water Supply
A Freedom Industries storage tank corroded through at the bottom, releasing crude MCHM that flowed through secondary containment and reached the Elk River, contaminating the drinking water supply for 300,000 residents.
Finding 02
Tank Had No Record of Any Formal Inspection
No records existed of any formal inspection of the Freedom Industries storage tank -- it had never been inspected under API 653, leaving progressive corrosion undetected until a catastrophic leak occurred.
Finding 03
Tank Roof Holes Allowed Water Infiltration Accelerating Corrosion
Water entered the tank through holes in the tank roof, pooling on the bottom beneath the stored chemical and accelerating corrosion of the tank floor -- a known mechanism that regular inspection would have detected.
Finding 04
Water Utility Had No Contingency for Untreatable Contamination
West Virginia American Water had no contingency plan to respond to contamination by a chemical that its treatment process could not remove -- MCHM could not be treated by conventional water treatment methods.
Finding 05
Toxicological Data on Crude MCHM Was Inadequate
At the time of the incident, safety data sheets for crude MCHM contained inadequate toxicological and ecological information, limiting public health guidance that could be provided to affected residents.
🔍 Root Causes
1
No Tank Inspection or Maintenance Program at Freedom Industries
Freedom Industries had no formal program to inspect, maintain, or assess the integrity of its chemical storage tanks -- the complete absence of any inspection program allowed corrosion to proceed unchecked until tank failure occurred.
2
Source Water Protection Plans Did Not Account for Upstream Chemical Facilities
Regional and utility source water protection planning had not adequately inventoried hazardous chemical facilities within the Zone of Critical Concern upstream of the water treatment plant intake.
3
Water Utilities Lacked Contingency Plans for Non-Treatable Contamination
American Water's treatment system was not equipped to treat MCHM-contaminated source water; no contingency plan existed for responding to contamination by a chemical the treatment process cannot remove.
☑ CSB Recommendations
→ American Water Works Association
Communicate Freedom Industries findings, lessons learned, and recommendations to all AWWA members, emphasizing source water protection planning, emergency planning, and coordination with local entities for timely notification of water contamination events.
→ American Water Works Company, Inc.
Establish requirements for all state utility surface water treatment plants to: inventory hazardous chemicals stored in the most vulnerable source water protection areas; assess whether those chemicals can be detected and treated; and develop contingency plans for chemicals that cannot be treated.
→ Eastman Chemical Company
Update the crude MCHM Safety Data Sheet to include toxicological and ecological information based on current toxicity evaluations, including effects on fetal and early life development; distribute updated SDS to all customers.
💡 Lessons Learned
Storage tanks holding chemicals near water supplies must be formally inspected. API 653 provides a well-established standard for above-ground storage tank inspection that would have detected the corrosion causing the Freedom Industries leak -- failure to apply any inspection program represents a fundamental mechanical integrity gap.
Corroded tank roofs allowing water infiltration is a known mechanism for accelerating tank floor corrosion. Regular visual inspection of tank roofs and floors -- a basic component of any tank integrity program -- can detect this progressive damage mechanism before it causes a catastrophic failure.
Water utilities downstream from chemical facilities must know what chemicals are stored upstream and whether those chemicals can be removed by the treatment process. Source water protection planning that does not inventory upstream chemical hazards is incomplete and leaves utilities unprepared for contamination events.
Emergency notification to the public following a water supply contamination event must be rapid and specific. Clear communication protocols established before an incident -- defining channels, timing, and responsible parties -- are essential for effective public protection.
The toxicological data gap on crude MCHM illustrates a broader problem: chemical substances used in industrial processes may lack publicly available toxicological data adequate to support health guidance in a contamination emergency. Safety data sheets must be kept current with the best available toxicological information.
MI: Mechanical IntegrityPSI: Process Safety InformationEAP: Emergency Planning & Response
🔨 Safety Meeting Toolbox Talk
►When was the last formal inspection of each above-ground storage tank at our facility? Are our tanks inspected under API 653 or an equivalent standard on a documented schedule?
►Do we inspect tank roofs, vents, and structural integrity in addition to the tank bottom and shell? Water infiltration through a damaged roof can silently accelerate floor corrosion without any visible external sign.
►What happens if one of our storage tanks fails and releases chemical to a nearby drainage way, waterway, or storm drain? Is there a specific emergency response plan for that scenario?
►Are our chemical storage facilities located where a release could reach a water supply, well, or other sensitive receptor? Have we assessed that risk and implemented adequate containment?
►Does our facility maintain an up-to-date inventory of hazardous chemicals we store -- including their treatability and toxicity data -- so we can inform emergency responders and affected utilities if a release occurs?
Immediate Action Items
✓Pull inspection records for all above-ground chemical storage tanks at your facility and verify they have been inspected on a documented schedule consistent with API 653 or an applicable tank inspection standard.
✓Include tank roof integrity in the scope of upcoming tank inspections -- water infiltration through roof defects can silently accelerate tank floor corrosion and cause failure at the bottom.
✓Review your facility's emergency response plan and confirm it specifically addresses tank failure scenarios, including the release pathway to nearby drains, waterways, or groundwater.
✓Coordinate with your local LEPC to ensure chemical storage inventory data is available to emergency responders and downstream water utilities who may need it in a release emergency.
✓Verify that Safety Data Sheets for all chemicals stored in above-ground tanks are current and include adequate toxicological data for emergency health guidance.
🔗 PSM Failures Behind This Incident

This incident traced to breakdowns across 3 PSM elements (MI · PSI · EAP). Each represents a documented gap that process safety documentation and consulting can close before a similar event occurs at your facility.

Mechanical Integrity (MI)
Equipment must be designed, inspected, and maintained to operate safely in its intended service. Mechanical integrity failures — degraded equipment, missed inspections, deferred repairs — contributed to loss of containment here.
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Process Safety Information (PSI)
Accurate, complete Process Safety Information is the foundation every other PSM element depends on. When PSI is missing or wrong — chemistry data, equipment specs, P&IDs — the entire hazard analysis is built on a flawed base.
Supporting documents in our library →
Emergency Planning & Response
When process safety barriers fail, emergency response capability determines whether the outcome is controlled or catastrophic. Gaps in emergency preparedness amplified the consequences here.
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