Description of Non-Hazardous Secondary Material Events that Resulted in Adverse 

Environmental Impacts 

September 11, 2009 

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Background Summary 

The stockpiling of non-hazardous secondary materials may lead to adverse events that cause damage to 

the environment. In particular, stockpiled secondary materials may ignite into large fires, posing a threat 

to local communities, the environment, firefighters and other emergency responders, and personal 

property. Such fires often occur at sites where materials have been improperly managed or overaccumulated. Local residents often bring these practices to the attention of environmental protection 

authorities prior to the occurrence of an incident, but, in some cases, inspectors do not issue citations for 

these practices (Bauer, Harris). 

While the damage from any fire may be significant, tire fires are particularly destructive because of the 

difficulty in extinguishing them. The duration of tire fires may range from a few days to more than a 

year. In addition, several stockpiles have burned until their tire supplies were completely exhausted (EPA 

1991, p. 22). Tire fires may cause contamination of soil, ground and surface water, and air, and may also 

produce thousands of gallons of oil from the pyrolysis of tire rubber.1

 Air pollutants from tire fires 

include black smoke containing toxins such as polycyclic aromatic hydrocarbons (PAHs), heavy metals, 

CO, SO2, and NOx. 

Materials other than tires, such as scrap wood debris and wooden pallets, are also common sources of fuel 

for spontaneous fires. Fires involving these materials may cause air and water pollution, but the examples 

identified did not cause damage as extensive as that associated with tire fires. 

This document summarizes the following examples of secondary materials fires: three examples of tire 

fires, one of a debris fire, and a collection of examples of pallet fires. Because the available information 

on individual pallet fires is limited, the collection of pallet fire events summarized in this document 

constitutes a broad representation of these particular fires. 

Winchester, Virginia – Rhinehart Tire Fire (Oct. 1983 – July 1984) 

The tire fire at the “Old Tire Home”, a tire dump in an agricultural area in Winchester, Virginia, was one 

of the largest tire fires in U.S. history (Schneider, p. 2; Blumenthal, p. 9). The privately-owned facility, 

also known as the Rhinehart Dump, served as a tire dump from 1972 through 1983 before the fire broke 

out on October 31, 1983, igniting between five and nine million tires. The facility reportedly stored tires 

in haphazardly stacked piles 50 to 80 feet high (EPA 1984, p. 2; Bauer). Although an EPA emergency 

team was able to control the fire within a few days, the tire pile continued to smolder for six months. 

Limited water supply reportedly prevented responders from dousing the fire (NIOSH, p. 2). 

 

1

 Pyrolysis is the thermal decomposition of a substance in the absence of oxygen. For tires, it is the process by 

which the intense heat in a tire fire breaks down the polymeric rubber molecules in the tire rubber into shorter chain 

hydrocarbons, turning tire rubber into pyrolytic oil. Pyrolytic oil needs to be further processed to be used as a 

valuable product (P2Pays.org). 
2 

The burning tires at the Rhinehart Dump produced a stream of pyrolized oil. The tire pile’s location 

uphill from Hogue Creek, a tributary of the Potomac River, allowed oil residues from the fire to enter the 

Creek, posing a threat to drinking water downstream in Washington, D.C. (EPA 1984b, p. 8). The fire 

also released a plume of black smoke that spanned 50 miles across four states (VA DEQ, p. 1). Human 

health risk testing of the plume revealed CO, PAHs, lead, iron, and zinc; the Centers for Disease Control 

determined that the plume posed an immediate human health threat (EPA 1984b, p. 8). 

Due to continued water and soil contamination caused by the fire, EPA added the Rhinehart Dump to the 

National Priorities List (NPL) in June of 1986. EPA designated a total of 22 acres as the Rhinehart Tire 

Fire Dump Superfund Site, including the 4.5-acre Dump itself plus much of the surrounding area (EPA 

2009). As a result of the fire, sediment and surface waters near the site, as well as an aquifer that served 

as a source of drinking water, all contained oily residues, various heavy metals (e.g., cadmium, arsenic, 

lead, and nickel) and volatile organic compounds (VOCs) (toluene and xylene in particular). Soil near the 

site also contained low levels of PAHs (VA DEQ, p. 2). 

Remediation of the site began in 1988 and continued until August 2002, and cost $1.74 million in 

CERCLA emergency funds (EPA 2008; EPA 1986). During the clean-up period, remediation teams 

treated ground and surface waters, collected oil residues, and controlled soil erosion. A temporary water 

treatment facility and pond (Rhinehart Pond) were constructed and operated until the treatment plant’s 

effluent met discharge requirements. During the incident, responders dug an emergency pond 

(Dutchman’s Pond) to collect the stream of pyrolized oil flowing from the site. Remediation teams 

collected a total of 800,000 gallons of pyrolized oil from the pond and sent this material to recycling 

facilities. After all of the oil was collected, remediation teams removed the pond and stabilized the area. 

In addition, to minimize the risk of further water contamination, soil was removed from the site and the 

area was re-seeded. EPA removed the Rhinehart Dump from the NPL in 2005. 

Chautauqua County, New York - Tire Fire (1995) 

On April 23, 1995, a scrap tire pile covering nearly seven acres of land with tires piled 15 to 30 feet high 

caught fire in Chautauqua County, New York. The blaze consumed approximately two million of the five 

to six million tires in the stockpile. The burning tires emitted black smoke into the air that was visible for 

several miles. Though the areas over which the smoke plume hovered were largely rural and agricultural, 

approximately 50 households and one school were evacuated, and authorities suggested that nearby 

residents with respiratory problems evacuate their homes (Huber). 

The New York Department of Environmental Conservation (NY DEC) contained the fire by constructing 

a firewall, or earthen berm, around the burning tires that prevented the flames from spreading to the 

remaining tires. To contain oily run-off from the fire, the NY DEC constructed a network of ponds and 

pipelines that funneled water out of the earthen berm and into the containment ponds, which were lined to 

prevent toxic substances from seeping into the ground. The oil and contaminated water collected in these 

ponds were removed by tankers and shipped from the area for recycling (Huber). 

Two days after the blaze (on April 25, 1995), the U.S. Environmental Protection Agency (EPA) 

monitored and sampled air quality in the area surrounding the fire. The Agency found no significant toxic 

readings upwind; however, VOCs, including PAHs, benzene, and toluene, were detected in the plume 

smoke. To extinguish the fire, EPA uncovered the smoldering tires and smothered them with soil. 

Because runoff from the fire could have contaminated the large aquifer near the site, EPA did not use 

water to contain or extinguish the fire. The aquifer supplies drinking water to several municipalities in 

the county, and its protection from pollution was of major concern (Huber). 
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On May 1, 1995, the fire was officially declared extinguished. Although the fire subsequently reignited 

numerous times in the following months, the re-ignitions were not so extensive as to require further action 

from environmental protection officials. Soil samples collected four months after the initial blaze showed 

insignificant levels of contaminants, and did not necessitate further remediation. In addition, EPA found 

no contamination to the local aquifer. 

Legal battles concerning both the cleanup of the burnt tires and of the remaining four million tires in the 

stockpile were lengthy (Huber). The property owners claimed that state and federal officials did not assist 

them in their attempts to remove the tire stockpile prior to the fire, and therefore the owners refused to 

pay for removal of the remaining tires. However, on June 30, 1995 the State of New York placed the 

responsibility for restoration and remediation on the owners of the property. 

Westley, California – Filbin Tire Pile Fire (1999) 

The Filbin Tire Fire in Westley, California, similar in size to the Rhinehart Dump Tire Fire, is also 

regarded as one of the largest tire fires to occur in the United States (Blumenthal, p. 9). The Filbin Tire 

Pile was an illegal scrap tire dump containing seven million tires located in a canyon above the San 

Joaquin Valley. The pile ignited during a lightening storm in 1999, and the blaze quickly became so large 

that it overwhelmed local fire departments, at which point assistance from federal authorities was needed. 

The location in the canyon made the fire particularly challenging to manage, as it was difficult to 

maneuver the large equipment necessary for extinguishing the fire on the dangerous and unsteady slopes 

lining the canyon. 

Ash and soot from the fire were reportedly transported as far as 60 miles from the blaze. In addition, the 

fire spread to nearby grasslands and eventually charred 1,200 acres of land (Shane, p. 380). Firefighters 

and environmental protection authorities used foam, water, and large excavators to extinguish the fire. 

Foam was needed to extinguish an oil fire that started when the stream of pyrolized oil flowing from the 

fire ignited. Four million gallons of water were used during the incident, and more would have been 

necessary had there not already been a containment structure downstream from the site (Shane, p. 382). 

The containment structure was used in conjunction with a recirculation system, installed during the 

incident, to recycle and reuse water and prevent overflow of the containment pond. 

The fire produced 250,000 gallons of pyrolized oil, which were contained behind an existing earthen dam, 

previously dug as a watering pond. Due to the high benzene content of the pyrolized oil and other 

toxicity ratings, the oil was classified as hazardous waste, and the California EPA would not grant a onetime permit to allow it to be recycled as a non-hazardous material at a local refinery. The oil was 

eventually shipped to Kansas as “RQ Waste Flammable Liquid N.O.S. (RQ Benzene)” at a cost of 

$271,000 (Shane, p. 381). In addition to the oil, environmental protection officials also had to contain 

and manage the four million gallons of water contaminated from contact with the toxic oil and other fire 

residues (Shane, p. 382). 

Following the fire, the California Integrated Waste Management Board (CIWMB), feared that heavy rain 

and resulting runoff during an El Niño winter could cause the water containment ponds to overflow and 

contaminate areas downstream (Shane, p. 381). To avoid this, CIWMB constructed impoundments and 

pipelines to divert water from tributary canyons to areas downstream from the contaminated area. 

The cost of extinguishing the fire and disposing of the pyrolized oil totaled $3.7 million, not including the 

costs of investigation or remediation of the site. Cost estimates for remediation following the fire ranged 

from $10 to $30 million (Shane, p. 382). 
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Bexar County, Texas – Helotes Debris Fire (Dec. 2006 – March 2007) 

On December 26, 2006, an unknown source ignited a pile of wood waste 70 feet high and 800 feet long 

near Helotes, Texas. The facility was registered by the Texas Department of Environmental Quality 

(TCEQ) as a recycler. When the local fire department refused to assist in extinguishing the fire, the 

owner used his own heavy equipment to extinguish the blaze. The owner purposefully used as little water 

as possible, knowing that the proximity of the scrap pile to the recharge zone of the Edwards Aquifer 

could cause contamination (MySanAntonio.com). 

Following complaints from area residents, state officials ceased control of the property on January 9 and 

hired a contractor to extinguish the fire. Despite warnings from the Edwards Aquifer Authority (EAA) 

and the San Antonio Water System (SAWS) that using water could contaminate the nearby aquifer, the 

contractor doused the fire with water. Days later, residents complained of cloudy water that smelled like 

smoke, and seven wells were found to be contaminated. The TCEQ subsequently changed strategy and 

built a quenching pit to sequester and extinguish small portions of the debris at a time; however, EAA and 

SAWS would not provide the 300,000 gallons/day of water requested, stating that they did not want to 

turn a short-term air problem into a longer-term water problem (Eckhardt, Feb. 2007). Eventually, EAA 

and SAWS agreed to provide the water if the TCEQ closely monitored nearby wells. 

By March 10, air quality conditions near the site were unfit for children and the elderly. Soon after, fecal 

coli form bacteria were found in well water. Because the quenching pit at the site of the blaze was also 

contaminated with the bacteria, environmental protection officials believed it may have been the source. 

Unable to control the blaze with the limited amount of water provided by EAA and SAWS, the TCEQ 

informed SAWS that it was revoking its agreement not to use water directly on the fire and ordered 

SAWS to provide more water. On March 27, the fire was officially extinguished. 

Following the Helotes fire, the TCEQ considered several new regulations on debris pile management. 

The new requirements included that piles not exceed 25 feet in height, that 90 percent of acquired 

material must leave the property each year, and that facilities near the Edwards Aquifer must have water 

pollution abatement plans. Witnesses reported that in the ten years the facility was in operation, they had 

never seen material leave the property, even though the owner filed as a recycler and not as a disposal 

facility (Eckhardt, April 2008). A state investigator also had reportedly visited the site a month before the 

fire following a complaint but issued no violations (MySanAntonio.com). 

In June, the Texas Attorney General filed suit against the owner of the recycling facility for violations of 

both air pollution and outdoor burning regulations. The Attorney General cited costs of $5.8 million for 

extinguishing the fire and sued for additional fees for civil penalties: $50 - $25,000 for each of the 92 

days the fire burned (MySanAntonio.com). 

Pallet Fires – Various 

Although a number of pallet fires have occurred in the U.S. in recent years, little information is available 

on each individual fire. In the absence of this detailed information, we provide brief summaries of pallet 

fires at three facilities. 

A pallet fire at Lanier Pallet Recycling facility in Commerce, Georgia began in a pallet storage shed 

located at the facility. The fire grew to be so large, consuming over 25,000 pallets, that 30 fire units and 

100 firefighters had to respond and shuttle water from multiple hydrants and from a nearby pond to 

extinguish the fire. The local highway was also temporarily closed to detour traffic around the scene 
5 

(Beardsley). The Lanier fire was thought to have been caused by a spark from the incinerator located at 

the site, though an ember blown into the facility from the road could have also caused the blaze. 

Similar to the Lanier fire, an onsite wood-burning furnace was cited as a possible cause of a large pallet 

fire at the Red Express Pallet Company in Hewitt, Texas in June 2009 (Pere). Local firefighters were able 

to contain the blaze within a few hours, and the business re-opened the following day. 

Pallet Recycle, a facility that recycles wood pallets into mulch in Polk County, Florida, has experienced 

two separate blazes since 2004. The 2004 fire was believed to have been caused by a spark from the 

facility’s wood chipper. The fire engulfed ten acres of land and spread to a nearby sheet metal 

manufacturer (Ready). In 2008, an unknown source sparked a similar fire at the same site. The fire 

ignited the facility’s scrap pallet piles, in which pallets were stacked 40 feet high. The fire spread to a 

nearby tractor-trailer filled with tires, which also ignited, making the fire even more difficult to 

extinguish. Despite this, the local fire department was successful in extinguishing the blaze within a few 

hours. 

References 

Adams, Jason. 2009. Sham recycling case study results presented at the National Environmental 

Enforcement Conference on April 15, 2009. 

Bauer, Clarissa Kay. 2009. “Civil Prosecution of Sham Recyclers.” Presented at the National 

Environmental Enforcement Conference on April 15, 2009. 

Beardsley, Mark. 2009. “Fire heavily damages Lanier Pallet.” CommerceNewsToday.com. Accessed on 

July 22, 2009 at http://www.commercenewstoday.com/archives/1858-Fire-heavily-damages-LanierPallet.html. 

Blumenthal, Michael. “A Brief History of Scrap Tire Stockpiles & Open-Air Tire Fires.” Rubber 

Manufacturers Association Presentation at EPA Scrap Tire Cleanup Forum, accessed on August 14, 2009 

at http://www.epa.gov/reg5rcra/wptdiv/solidwaste/tires/paforum/blumenthal%20-%20history.pdf. 

Eckhardt, Gregg. 2007 and 2008. The Edwards Aquifer Website. Postings cited: “Brush pile fire impacts 

Edwards wells near Helotes” (January 2007); “Helotes fire rekindles debate about water quality 

protection” (February 2007); “Helotes fire finally out, cleanup to begin” (March 2007); “Helotes fire 

continues to burn; more wells contaminated” (March 2007); and “New rules for Bexar county brush 

management proposed in wake of ‘Mulchie’” (April 2008). Accessed on July 16, 2009 at 

http://www.edwardsaquifer.net/news.html. 

Harris, Pat. 2009. “Sham Recycling: Case Study.” Presented at the National Environmental Enforcement 

Conference on April 15, 2009. 

Huber, Dee et al. “Chautauqua County Fire.” Available from the North Carolina Department of 

Environment and Natural Resources (NC DENR), Division of Pollution Prevention and Environmental 

Assistance, at: http://www.p2pays.org/ref/11/10504/html/biblio/htmls2/prh7.html

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http://www.mysanantonio.com/news/MYSA_061408_MAINmulchfirelawsuit_EN_3898b88_html5163.ht

ml. 
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National Institute for Occupational Safety and Health (NIOSH). 1984. Health Hazard Evaluation Report 

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1441, March 1984. 

P2Pays.org. “Pyrolysis.” Accessed on August 17, 2009 at 

http://www.p2pays.org/ref/11/10504/html/usa/pyro.htm. 

Pere, Anita. 2009. “POLICE NEWS: Three fire departments battle pallet blaze near Hewitt.” 

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http://www.wacotrib.com/news/content/news/stories/2009/06/24/06240209waccops.html?cxtype=rss&cx

svc=7&cxcat=11. 

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and_Recycling_Facility. 

Schneider, Keith. 1990. “Worst Tire Inferno Has Put Focus on Disposal Problem.” NYTimes.com. 

Accessed on 16 July 2009 at: http://www.nytimes.com/1990/03/02/us/worst-tire-inferno-has-put-focuson-disposal-problem.html. 

Shane, Daniel M. 2001. “Westley Tire Fire, Stanislaus County, California.” Inland Issues: 2001 

International Oil Spill Conference. pp. 379-381. 

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for Rhinehart Tire Fire. 

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http://www.epa.gov/reg3hwmd/npl/VAD980831796.htm. 

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