“Volatile organic compounds or VOCs” are defined (310 CMR 40.0006) in the MCP.
Volatile Organic Compounds and VOCs each mean an organic compound with a boiling point equal to or less than 2180C that are targeted analytes in EPA Method 8260B and other purgeable organic methods specified in the Department’s Compendium of Analytical Methods.
So, what are the “targeted analytes” under: 1) 8260B; and 2) CAM?
8260B says: It is the intent of EPA that all target analytes for a particular analysis be included in the initial calibration and calibration verification standard(s). These target analytes may not include the entire list of analytes (Sec. 1.1) for which the method has been demonstrated.
Section 1.1 lists 108 individual compounds which would appear to be the universe of 8260B targets. Labs typically target a subset (37) of these, including the common aromatic and aliphatic VOCs, as well as the long list of chlorinated VOCs.
2) CAM – The current purgeable CAM methods are limited to VPH (volatile petroleum hydrocarbon). EPH (extractable petroleum hydrocarbons) is a CAM method, but is NOT a purgeable method. Therefore, EPH target analytes should fall outside the VOC definition (more on this later). Focusing on the VPH Method, “Target VPH Analytes” are narrowly defined in CAM as BTEX plus MTBE and naphthalene.
VPH hydrocarbon fractions are not target VPH analytes, and are therefore not VOCs? A literal read of the VOC guidance could go further and conclude that only the BTEX plus compounds are VOCs, since they alone are targeted in both 8260 and VPH. Such a literal read is contrary to clear guidance in the Q&A (Question 7) and the Vapor Intrusion Guidance Document. These sources make absolutely clear that DEP considers VPH fractions to be VOCs.
So What? Definition flexibility can be stretched further as illustrated below.
A Not So Hypothetical Case
C9 to C18 aliphatics slightly exceeded GW-2 standards within 30 feet of a residence. The LSP recommended reporting within 72 hours under 310 CMF 40.0313(4)(2), because “volatile organic compounds” exceeded GW-2 Standards. Client requested a second opinion from me (LSP2). With about 8 hours left on the reporting clock. I looked at the definition, talked to another LSP in the office, looked at Guidance Q&A question 7 and the Vapor Intrusion Guidance Document, and felt confident it was not a 72 – hour condition. I based my opinion on:
- EPH is not a CAM “purgeable CAM Method” and thus falls out of the definition. Further the only target PAH from EPH with a boiling point below 218oC is naphthalene, which was not detected above GW-2 standards.
- DEP guidance on the question of hydrocarbon fractions being VOCs was specific only to VPH fractions, DEP did not extend the definition in its guidance to EPH fractions.
With two LSP contrary opinions, and the clock running down, Client asked LSP1 to call DEP with the hypothetical to hopefully resolve the conflicting LSP opinions.
A few hours later (and in time), LSP1 reported back that MassDEP considers a portion of the C9-C18 aliphatics to be a VOC with reporting applicability under 310 CMR 40.0313, with the definition applying due to the overlapping VPH Fraction (C9-C12 aliphatics).
Fortunately for my client, DEP concluded the hypothetical was not a 72 – hour condition because the concentrations were relatively low, the suspect source is fuel oil and the presumed age of the release, MassDEP acknowledged that lines of evidence in our hypothetical do not require the presumption that more than 5,000 ug/L of the C9-C18 aliphatics result is in the C9-C12 range, and therefore 72-hour reporting was not required at this time.
Bottom Line and finally getting back to my opening question:
- Q. What are Volatile Organic Compounds in Massachusetts?
- 8260B targets, VPH Fractions, and sometimes C9-C18 aliphatics depending on concentrations and source.