Wisconsin Regulatory Experience with Asphalt Shingle Recycling

3rd Asphalt Shingle Recycling ForumChicago, EPA Region 5

November 1-2, 2007

Robert P. Grefe, P.E.Bureau of Waste & Materials MgtWis. Dept. of Natural Resources

608-266-2178robert.grefe@wisconsin.gov

Shingle Recycling Projects in Wis.

• Several small projects proposed over past decade or more– Usually one-time

– Little to no documentation

– Not sure that many were implemented, and no reporting of results

– Usually involved shredding of residential shingles for asphalt mix, road bed, mixing with subbase gravel, etc., for low volume roads or demonstration projects

– Informal approval process, or assumed to fit into code exemptions

• More significant proposals in recent years– Reduced numbers of C&D landfills

– Increased tipping fees at C&D and MSW landfills

– Emphasis on recycling more waste types

– Cost of oil, asphalt, diesel fuel

More Recent Projects

• La Crosse County – late 1990’s to 2007– County operation at its MSW landfill

– Shingles ground by contractor & used in hot mix asphalt

• Bruce Co, Verona, Dane County – 2007 – Landscaping and construction materials

– Processes loads from roofing contractors

– Shingles ground at own facility, used for cold mix asphalt, etc

• Waveland Recycling, Inc. Franklin Park, IL - 2007– Processed shingles approved to be use in Wis. project

– Subbase fill for paved roads & parking lots

• B.R. Amon & Sons, Elkhorn, Walworth County – 2007– Hot mix asphalt & quarry operations

– Shingles ground at hot mix plant & used in asphalt concrete mixes

La Crosse County

• County MSW landfill uses differential fee structure to encourage contractors to supply separated shingles to processing area

• Contracted landfill operator uses a tub grinder to shred shingles

• Asphalt plant operator uses shingle grind in mixes

• Asbestos testing – one sample per roof, contractor pays for part of cost

• Waste reduction & recycling grant – field test in 2006

• Experience – Several 100’s of asbestos tests, only a few detected >1% asbestos– Use of tub grinder resulted in acceptable grind, but may need multiple

passes and resulted in some agglomeration of shreds– Better removal of nails, metal, wood, etc would help final asphalt quality– Wood contamination caused odors & smoke in hot mix operation– Still need to work out methods to meet WDOT highway mix specs

Waveland Recycling

• Existing C&D recycling operation in IL proposed to haul shredded shingles to job sites in Wis.

• Approval process – low hazard waste grant of exemption – Statutory exemption process from solid waste rules (s. 298.43(8), Stats)

– Issued for use of shingles in Wis.

– Recycling operation segregates shingles from other C&D waste and from other potentially asbestos-containing roofing materials

– Asbestos testing conducted by recycling operation

• Approved uses limited to mix in subbase fill– 15% or less by weight

– Contractors follow best management practice guide

• Annual reports required – tonnages uses, test results, locations• Too recent to report any experience

Bruce Company

• Landscaping supply company – shredded wood, compost, soils, plants, etc., in Dane Co Area

• Proposed to process waste from roofing contractors, by use of a picking line– Primarily to recover residential shingles for grinding for reuse– Also recovers cardboard, wood, some metals, and unused roofing

materials– Shreds shingles to about ¼ in size for use in dust control & cold mix

asphalt pavement uses

• Low hazard waste grant of exemption issued in 2007

• Uses approved – surface course in roads, parking lots, access lanes– Hot mix asphalt concrete & cold patch– Geotechnical fill for base or subbase below roads or structures if less

than 15% by weight after mixing with aggregate

Bruce Co - continued

• Company intends to submit plan for processing facility for C&D waste stream

• Current shingle processing line is temporary & will be replaced• Current uses for ground shingles are dust control & cold mix asphalt

– Dust control use by sprinkling shreds over aggregate or soil & compacting by roller or traffic

– Cold mix use by physical mixing shredded shingles with aggregate, without use of hot mix plant, laydown & compaction similar to hot mix asphalt mixes

• Company is experienced with grinding wood, yard waste, trees, etc., and moving/processing materials as part of current operations– Some additional investment in labor, machinery for picking line, etc.

Bruce Co – load as received from contractors

Bruce Co – picking line for shingles

Bruce Co – unused roofing mat’ls recovered from contractor deliveries

Bruce Co – shingles after sorting & dumpsters for rejects to go to landfill

Bruce Co – shingle shreds used fordust control on soil or aggregate

Bruce Co – cold mix asphalt used as pavement on company facilities

B.R. Amon & Sons

• Operates fixed & mobile hot mix asphalt plants & aggregate quarries– Produces DOT & specialty asphalt concrete mixes, as well as aggregates

– Proposed use of shingles at it’s Elkhorn plant, as additive to hot mix asphalt to replace part of asphalt & fine aggregate

• Approval by use of rule exemption for processing facilities that use asphalt or concrete as raw material into structural material– Also has to obtain approval for use of the material as proposed

– Approval is means for requiring reporting, testing, etc.

– Restricted to residential asphalt shingles

– Emphasizes asbestos testing of ground product rather than of shingles• Sampling every 50 tons of product & testing by PLM • Increase to every 25 tons on detect of >1% asbestos until 3 rounds are <1%

– Five year sunset limit on approval – renewal to be based on experience gained and test results

B.R. Amon & Sons - continued

• No sorting at the hot mix plant – Sorting conducted by haulers/roofers – best mgt practices guide

– Loads inspected at plant, rejected loads sent to landfill

– No personnel have to physically handle shingles/roofing waste

– All material movement by end loaders, conveyers, etc.

• Dumping on paved pad to minimize dirt in shingles• Equipment & labor needed is mostly available as part of quarry or

hot mix plant– End loaders, generators, pumps, etc.

– Mobile conveyers with magnets

– Location within quarry takes advantage of runoff controls, fencing, access controls, already in use

– Add’l equipment includes rented shredder, paved pad, windblown controls

B.R. Amon & Sons - continued

• Major windblown material – cellophane scrap– Messy, but doesn’t seem to affect hot mix process

• Shingles ground to about ¼ in– Oversize separated by screens & periodically loaded into shredder

• Dust control by water sprays at shredder• Magnetic separation of nails at conveyor discharge• Product used so far for driveways & parking lots

– Testing to determine mix ratios for meeting DOT specs

– 5-10% shingle admixture by weight

– Need to balance asphalt & aggregate in shingles, use of recycled asphalt concrete, use of virgin aggregate & asphalt, fuel usage

Problems/hangups with recycled shingles

• Major uncertainty about asbestos & impact of air regs– Testing so far (La Crosse, B.R. Amon) indicates very infrequent

asbestos content of >1%

– Who pays for testing & disposal of reject loads

– How often to test, what material (shingle or ground product), where sampled

• Shingle processing – who does it – QC between haulers/roofers and processor/end user– How much inspection is needed

– Should haulers/roofers be required to have processing facility plans & approvals?

• Economic haul distance – Effects of landfill tipping fees on recovering shingles for reuse

– Regulatory changes – needed for C&D Lfs? Lf bans?

QA/QC & Recordkeeping

• DNR has a couple of mechanisms for regulation– Processing facility approval or low hazard waste grant of exemption

– Different authorities, but can require the same items

• Primary emphasis on sorting & visual examination to achieve clean shingles– Sampling for asbestos – post-grind product vs shingles?

– PLM testing is available from commercial testing labs

• Processors need best mgt practices guide for haulers/roofers• Annual reporting – for basic statistics & info

– Total tonnages of shingles used

– Results of asbestos testing program

– Locations where asphalt containing shingles was used

– Problems & solutions

Influences on shingle recycling

• Governor’s Task Force rpt dated Dec. 2006 – regarding C&D waste– More recycling of C&D, market research, use of shingles in DOT specs

– Assess impacts of C&D Lfs on groundwater & upgrade rules

• OFR rule revisions – to start later this fall– Implementation of Gov’s Task Force recommendation of OFR for small

C&D Lfs

– May lead to more extensive changes in C&D Lf rules

• Recent State budget – Increases in Recycling fee by $1 & other Lf tipping fees

• Staff review of impacts around C&D Lfs– Some effects seen in indicator parameters around unlined C&D Lfs

– Observations of diversity of waste disposed of in C&D Lfs

– Odors from certain C&D Lfs due to wallboard & water