Robert P. Grefe, P.E. Bureau of Waste & Materials Mgt Wis. Dept. of Natural Resources 608-266-2178

1. Wisconsin Regulatory Experience with Asphalt Shingle Recycling3rd Asphalt Shingle Recycling ForumChicago, EPA Region 5November 1-2, 2007 Robert P. Grefe, P.E. Bureau of Waste & Materials Mgt Wis. Dept. of Natural Resources 608-266-2178 robert.grefe@wisconsin.gov

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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.

8. Bruce Co – load as received from contractors

9. Bruce Co – picking line for shingles

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

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

12. Bruce Co – shingle shreds used for dust control on soil or aggregate

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

14. 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

15. 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

16. 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

17. 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?

18. 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

19. 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