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t, <br />The mud truck analysis is compared with background concentrations of elements in <br />soils and to draft soil remediation objectives from the Colorado Department of Public <br />Health and Environment (CDPHE). The TCLP regulatory limits from the Resource <br />Conservation and Recovery Act (RCRA) are also included with the notes that they can be <br />compared by dividing the sample result by 20. The TCLP is the Toxicity Characteristic <br />Leaching Procedure and it has an inherent dilution factor included with the method. <br />The analysis done on the mud trucks was for total metals and not the TCLP. EPA states <br />that the total analysis can be divided by 20 to account for the dilution that would occur <br />doing the TCLP. Therefore, the results shown on Table 1 would need to be divided by 20 <br />to compare to the TCLP limits. The results show that the mud is not a characteristic <br />hazardous waste. It should not be expected that the mud truck analytical results come <br />anywhere close to hazardous material concentrations because the mud were generated <br />by excavating the native soils with water. <br />The one analytical result that identifies volatile organic compounds was sampled near <br />the exhaust of the truck. The two VOC's were detected just slightly above the detection <br />limits and are believed to be from the truck exhaust and not the soils. The two VOC's are <br />commonly found in petroleum fuels, gasoline and diesel, and at these concentrations <br />could easily have been from the exhaust. The soils from the same truck were analyzed <br />and there were no VOC's detected. <br />Mud trucks routinely unload at various sites around the Denver Metropolitan area. <br />Broda has identified many locations where the mud trucks unload that are not <br />permitted for any activities related to inert filling or solid waste disposal. Once again, <br />the material in the mud trucks is native soils and water which should be acceptable as an <br />inert fill material and should be acceptable at inert fill sites. <br />Please contact me if you have any questions or concerns. <br />Yours truly, <br />Mark Molen <br />cc Patrick Broda, Broda's Inert Fill