®

1 Ohio Environmental

John R. Kasich, Governor
Mary Taylor, Lt. Governor
Craig W. Butler, Director

Protection Agency

June 3, 2016

Re: Arco Recycling, Irtc.
uerneral Correaporderìce
Construction Derno!ition Debris
Cuyahoga County
CDDL021638

Michael Riley
Arco Recycling, lnc.
1705 Noble Road
East Cleveland, Ohio 44112
Subject:

Facility Operationa! Review — April 2016

Dear Mr. Riley:
On April 6, 2016, Ohio EPA's Division of Materials and Waste Management, Northeast
District Office, conducted an unannounced, onsite inspection of the Arco Recycling
construction and demolition debris (C&DD) recycling facility located at 1705 Noble Road,
East Cleveland. The purpose of the site inspection was to verify that your C&DD recycling
operation complies with applicable rules found in the Ohio Administrative Code (OAC),
including:
1.
2.
3.
4.

meets the definition of recycling (OAC Rule 3745-400-01(11));
meets facility exclusion requirements (OAC Rule 3745-400-03(C));
meets the provisions of OAC Rule 3745-400-04; and
clean hard fill is stored in an appropriate manner (OAC Rule 3745-400-05).

Ohio EPA's review of Arco's operating data from June 2015 to April 2016 indicates the
facility accepted a total of 220,466 cubic yards of C&DD. During the same period, 24,551
cubic yards of material was shipped off site. That resulted in an average turnover rate of
only 11 percent.
We understand that Arco initially stockpiled a large amount of C&DD prior to beginning
actual recycling operations and has made some strides in obtaining the equipment and
personnel needed to recycle legitimate material; however, we are concerned the facility is
accepting and storing more C&DD than it is processing and sending off site. Continuing
this practice could result in C&DD residing at the facility for excessive periods of time and
potentially be considered illegal disposal, a violation of the OAC.

Northeast District Office • 2110 East Aurora Road ® Twinsburg, OH 44087-1924
epa.ohio.gov o (330) 963-1200 ® (330) 487-0769 (fax)

 ARCO RECYCLING, INC.
JUNE 3, 2016
PAGE 2 OF 2

processing. C&DD without a beneficial reuse value was being removed for futul
ul

Recommendations
1. Make substantial progress towards completing the Recycling Certification Institute
(RCI) certification process, in order to remain a listed registrant with RCI.
2. Install weight scales at the facility to accurately verify recycling rates and comply
with RCI requirements.
3. Achieve and maintain a recycling rate averaging at least 40 percent, so the facility is
eligible to dispose of recovered screened material (RSM) at Ohio's licensed C&DD
landfills (as outlined in the Ohio Addendum to the RCI certification program).
4. Keep accurate records of the weight/volume of material arriving onsite, being
recycled and leaving the site, along with receipts from the destination facility. Also
keep records of the weight/volume of non-recyclable material leaving site for
disposal, including receipts from legitimate disposal facilities.
Nothing in this letter shall be construed as waiving or compromising in any way ti

If you have any questions concerning this letter, don't hesitate to contact me at (330) 963
1245 or bill Iu@ea otiio gov Please reference the subject line of this letter in all
correspondence.
Sincerely,

Bill Lutz
Environmental Specialist
Division of Materials and Waste Management