Recycling Residential Asphalt Shingles in Wisconsin
The DNR encourages recycling of residential asphalt shingles because they occupy a large part of roofing tear-off waste and general construction and demolition (C&D) waste and are fairly easy to identify and separate. Of the top 10 C&D wastes by weight, asphalt shingles are second after wood waste, according to a recent study. An estimated 247,000 tons of asphalt shingles were landfilled in Wisconsin in 2009.
Benefits of shingle recycling
Recycling shingles has many benefits, especially when the price of oil and virgin asphalt is high. Highway engineers have investigated use of shingles that are recycled into an additive for hot mix asphalt to build or repair roads and have found good results when ground shingles are used correctly. Recycling also saves landfill space and uses less energy than using virgin materials. Asphalt shingles contain asphalt cement "binder" and mineral aggregate, which are useful for asphalt hot mix pavement applications if proportioned following Wisconsin Department of Transportation standard specifications.
Shingle recycling process overview
Contractors, waste haulers and shingle processors play a key role in providing sorted shingle scrap to asphalt plants with minimum contamination from other materials in roofing debris, such as:
- asbestos from flashing, fabrics, rolled roofing, mastic and pre-1973 shingles; and
- wood, metal, cardboard, plastic packaging and shingle nails, which affect pavement acceptability.
Asphalt shingles must be ground to be useful to asphalt hot mix plants, and grinding asbestos-containing materials violates Clean Air Act restrictions. Other roofing wastes degrade hot mix pavement. Therefore, the DNR encourages contractors to source separate at job sites. Some of the other wastes can be recycled, such as wood, metals and cardboard, including the shingle nails, which can be removed from the ground shingles by magnets.
- Recycling Residential Asphalt Shingles: Roofing Contractors and Waste Hauler Responsibilities (WA1228 ) describes the benefits and concerns about residential asphalt shingles and the licensing requirements for residential asphalt shingles handlers
- Shinglerecycling.org, a website hosted by the U.S. Environmental Protection Agency (EPA), the Federal Highway Administration and the Construction Materials Recycling Association that covers advantages and requirements for recycling asphalt shingles into hot mix asphalt and other end uses
- California Integrated Waste Management Board introduction to shingle recycling
- California Integrated Waste Management Board information about asphalt roofing shingles in aggregate base
Wisconsin licensing and plan approval requirements
Residential asphalt shingles are a solid waste under Wisconsin solid waste management rules found in the NR 500 series of Wisconsin's administrative codes.
The tabs below provide information about the licensing and plan review requirements for typical shingle-handling activities.
Separating shingles does not require a DNR license or submitted plan
On-site source separation and containerized storage are not subject to licensing or plan approval requirements.
Roofing contractors or do-it-yourselfers are encouraged to separate asphalt shingles at the job site in separate lugger boxes (one box to collect clean asphalt shingles and other boxes to collect the rest of the project's wastes). Placing all roofing debris in a single on-site container requires further processing of those materials to extract the shingles from the other debris.
Haulers and contractors who separate roofing waste on their own property need to assure that all wastes are removed after sorting, whether for recycling or for landfill disposal. In those situations, haulers and contractors may be required to follow transfer facility rules under s. NR 502.07, Wis. Adm. Code.
The next handler of your shingles will require information from you assuring that the shingles came from residences with four or fewer units. If your project is a residence with more than four units or a commercial/institutional building, you will need to provide asbestos test data for each layer of shingles that were on that tear-off project.
Transporting shingles requires a state DNR license
If you haul source-separated residential asphalt shingles and/or mixed roofing debris from job sites, you must have a Collection and Transportation (C&T) license under s. NR 502.06, Wis. Adm. Code.
One-time, do-it yourself haulers of roofing materials may qualify for an exemption from licensing under s. NR 502.06(2)(b) if they haul less than 20 tons per year of solid waste and comply with the specified operational requirements.
All haulers, whether licensed or exempt, must deliver their materials to recycling facilities licensed or approved by the DNR, or to recycling facilities which are exempt from regulation by the DNR.
The receiving facility should be able to document its license or approval status. The facility will require information from the hauler assuring that the shingles came from a residence with four or fewer units. If they came from a residence with four or more units or a commercial/institutional building, the hauler will need to provide asbestos test data furnished to them by the generator.
Bringing material back to a box-yard to accumulate sufficient amounts of materials, consolidate loads or sort out recyclable materials requires an additional license (see Storage or Transfer tabs for details).
Storing shingles at a separate site may require a DNR license or approval
Storage means stockpiling residential asphalt shingles (sorted or mixed) at a property other than the job site, in order to accumulate sufficient quantities to economically haul the materials to the next facility. The storage facility either must be licensed and approved under s. NR 502.05, Wis. Adm. Code, or qualify for an short-term storage exemption under s. NR 502.05(3)(j) if the specified performance, location and operational requirements are met.
Operations that handle less than 50 tons per day of shingles may qualify for an exemption from the plan approval requirements under s. NR 502.05(3)(k). These operations receive a license and annually self-certify that they operate in compliance with pertinent code requirements.
Those stockpiling shingles need to keep sufficient records on the origin of the shingles delivered to your facility to provide information to the next receiving facility assuring that the shingles came from residences with four or fewer units. If the shingles came from residence with more than four units or a commercial/institutional building, test data furnished by the generator will need to be provided.
Sorting materials at a storage facility to extract recyclables is not allowed (see Transfer tab for details).
- To obtain a storage facility license, contact your regional DNR environmental program associate.
Combining loads of shingles to haul elsewhere requires a DNR license
Transfer means combining loads of residential asphalt shingles from smaller lugger boxes into larger boxes, at a property other than the job site, in order to haul the combined shingles to distant reuse operations more efficiently. The transfer facility must be licensed and approved under s. NR 502.07, Wis. Adm. Code.
Operations that handle less than 50 tons per day of shingles may qualify for an exemption from the plan approval requirements under s. NR 502.07(2r). These operations receive a license and annually self-certify that they operate in compliance with the pertinent code requirements.
Some sorting can be performed as part of the transferring operation to separate recyclable materials, provided you do not create nuisance conditions. This often includes manual sorting of shingles to produce a cleaner, sorted shingle load that is more economical to haul to the next recycler and typically receives a price similar to source-separated materials.
You need to keep sufficient records on the origin of the shingles delivered to your facility to provide information to the next receiving facility assuring that the shingles came from residences with four or fewer units. If the shingles came from residence with more than four units or a commercial/institutional building, you will need to provide asbestos test data furnished to you by the generator.
Multiple sorting activities, mechanically assisted operations or material grinding are not allowed at a transfer facility (see Processing tab).
Processing shingles written approval from the DNR
Processing residential asphalt shingles produces a ground shingle product that meets the asphalt plant specification for reuse in hot mix asphalt, which typically includes:
- sorting or separating shingles from other roofing debris to remove nails and other foreign objects; and
- grinding shingles to produce a product meeting the specifications of the reuse/recycling operation.
The processing facility is regulated under s. NR 502.08, Wis. Adm. Code.
Operations that can demonstrate contracted end markets or that are under shared ownership as the end market of asphalt shingles and the end markets are using the shingles for a structural purpose may qualify for an exemption from plan review and licensing requirements under s. NR 502.08(2)(i), Wis. Adm. Code. This exemption requires DNR approval of the facility’s asbestos screening procedures as well as material handling procedures, including pre-sorting, storage, final sorting, grinding and final product storage activities.
Shingle processing under this exemption does not allow the acceptance of other C&D materials that are not residential three-tab shingle materials (see Material Recovery tab).
To learn more about shingle processing requirements and apply, review:
Construction and demolition materials recovery facilities
Construction and demolition material recovery operations handle a larger array of recyclable C&D materials and receive mixed C&D materials from projects sites more diversified than residential roofing tearoffs. These facilities are considered to be solid waste processing facilities and must be licensed and approved under s. NR 502.08, Wis. Adm. Code.
To encourage C&D material recovery facilities, the DNR waives plan review fees and licensing fees. To maintain the fee waiver for future relicensing and plan modification review fees, the operation is typically required to document that sufficient volumes of materials accepted at the facility have actually been sent to recycling markets.