### 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 ma terials may ignite into large fires, posing a threat to local communities, the environment, firefight ers and other emergency responders, and personal property. Such fires often occur at sites wher e 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, tir e 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 un til their tire supplies were completely exhausted (EPA 1991, p. 22). Tire fires may cause contamination of so il, 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 polyc yclic aromatic hydrocarbons (PAHs), heavy metals, CO, SO 2 , and NO x . Materials other than tires, such as scrap wood debris and wooden pallets, are also common sources of fuel for spontaneous fires. Fires involving these material s may cause air and water pollution, but the examples identified did not cause damage as extensiv e 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 Winc hester, 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 betwee n five and nine million tires. Th e facility reportedly stored tires in haphazardly stacked piles 50 to 80 feet high (EPA 1984, p. 2; Bauer). A lthough 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 responde rs 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 brea ks down the polymeric rubber molecules in the tire rubber into shorter chain hydrocarbons, turning tire rubber into pyrolytic oil. Pyroly tic 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 str eam of pyrolized oil. The tire pile’s location uphill from Hogue Creek, a tributary of the Potomac Rive r, allowed oil residues fro m 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 wate rs near the site, as well as an aquifer that served as a source of drinking water, all contained oily r esidues, various heavy metals (e.g., cadmium, arsenic, lead, and nickel) and volatile organic compounds (VOCs) (toluene and xylene in par ticular). 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 residu es, and controlled soil erosion. A temporary water treatment facility and pond (Rhineha rt Pond) were constructed and ope rated 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 pyroli zed oil flowing from the site. Remediation teams collected a total of 800,000 gallons of pyrolized oi l from the pond and sent this material to recycling facilities. After all of the oil was collected, remedi ation 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 Rh inehart Dump from the NPL in 2005.

Chautauqua County, New York - Tire Fire (1995)

On April 23, 1995, a scrap tire pile covering nearly sev en acres of land with tires piled 15 to 30 feet high caught fire in Chautauqua County, New York. The bl aze 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 ove r which the smoke plume hovered were largely rural and agricultural, approximately 50 households and one school were ev acuated, and authorities suggested that nearby residents with respiratory problems evacuate their homes (Huber).

The New York Department of Environmental Conserva tion (NY DEC) contained the fire by constructing a firewall, or earthen berm, around the burning tires th at 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 shi pped 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, be nzene, and toluene, were detected in the plume smoke. To extinguish the fire, EPA uncovered the smoldering tires and smothe red them with soil. Because runoff from the fire could have contaminatedthe large aquifer near the site, EPA did not use water to contain or extinguish the fire. The aquife r supplies drinking water to several municipalities in the county, and its protection from pollution was of major concern (Huber).3 On May 1, 1995, the fire was officially declared ex tinguished. 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 necess itate 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 cl aimed 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 remedi ation 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 th e United States (Blumenthal, p. 9). The Filbin Tire Pile was an illegal scrap tire dump containing sev en 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 whic h point assistance from federal authorities was needed. The location in the canyon made the fire particular ly challenging to manage, as it was difficult to maneuver the large equipment necessary for extinguis hing the fire on the dangerous and unsteady slopes lining the canyon.

Ash and soot from the fire were re portedly 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 o il 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, e nvironmental 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 Ma nagement 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 cons tructed 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 th e 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).4 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 registeredby the Texas Department of Environmental Quality (TCEQ) as a recycler. When the local fire depart ment refused to assist in extinguishing the fire, the owner used his own heavy equipment to extinguish th e blaze. The owner purposefully used as little water as possible, knowing that the proximity of the scrap p ile to the recharge zone of the Edwards Aquifer could cause contamination (MySanAntonio.com).

Following complaints from area residents, state offici als 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 usi ng 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 wate r 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 a nd the elderly. Soon after, fecal coli form bacteria were found in well water. Becau se the quenching pit at the site of the blaze was also contaminated with the bacteria, environmental protec tion 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 seve ral new regulations on de bris 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 th e owner filed as a recycler and not as a disposal facility (Eckhardt, April 2008). A state investigator al so had reportedly visited th e 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 detaile d 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 larg e, consuming over 25,000 pallets, that 30 fire units and 100 firefighters had to respond and shuttle water from multiple hydr ants and from a nearby pond to extinguish the fire. The local highway was also te mporarily closed to detour traffic around the scene5 (Beardsley). The Lanier fire was thought to have b een caused by a spark from th e incinerator located at the site, though an ember blown into the facility fro m 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, Tex as 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 in to mulch in Polk County, Florida, has experienced two separate blazes since 2004. The 2004 fire was be lieved 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 th e 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 extinguis hing the blaze within a few hours.

References
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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/archiv es/1858-Fire-heavily-damages-LanierPallet.html

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. Eckhardt, Gregg. 2007 and 2008. The Edwards Aquifer We bsite. Postings cited: “B rush pile fire impacts Edwards wells near Helotes” (January 2007); “H elotes 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” (M arch 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

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.6 National Institute for Occupational Safety and Health (NIOSH). 1984. Health Hazard Evaluation Report for Rhinehart Tire Fire, Winchester, VA. U.S. De partment of Health and Human Service HETA 84-044- 1441, March 1984.
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