While looking into Option 2- Air Testing, a member of our project team presented the following questions as they believe this method is not achievable at this time:
1) Are there currently any labs with the capability of collecting Ozone to meet the detection limits?
2) Are all of the contaminants listed under VOCs classified as VOCs (i.e. all the ethylene glycol contaminants listed and others are Semi-volatile organic compounds)?
3) Are these contaminants in fact detectable by the specified lab method?
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Dale Walsh
30 thumbs up
October 3, 2016 - 2:49 am
There are methods for ozone monitoring. The two described in LEED 4 are for direct reading instruments. There are numerous environmental rental equipment companies (Pine Environmental, Field Environmental, Argus Hazco, Reaco Rents, etc.) that rent ozone meters. You would want one that datalogs. There is also an industrial hygiene method – OSHA ID 214. You can go to ALS Environmental in Salt Lake City, UT for that analysis amongst other AIHA accredited labs. Ask for Paul Pope.
When it comes to what is a VOC, that is a difficult question. There is no definitive definition. Some definitions are based on vapor pressures, others on boiling points, and some on a combination. ASTM D1356 − 15b Standard Terminology Relating to Sampling and Analysis of Atmospheres defines it as —an organic compound with a saturation vapor pressure greater than 10−2 kPa at 25°C. What a Total VOC is anybody’s guess. ASTM defines it as —the summed concentration of all the individual volatile organic compounds (VOCs) quantifiable in an air sample by both a precisely specified sampling protocol and a precisely defined analytical method. I don’t see any “precisely specified sampling protocols or precisely defined analytical methods” in LEED. Each time a different protocol or method is used (there are numerous variations) a different result occurs and the relatively meaningless 500 ug/M3 TVOC may either be passed or failed. I did a case study on this about 7 years ago and found the three different methods I used (TO-15, TO-17, and TO-17 with passive sampler) varied tremendously in their results with some of them passing the LEED TVOC allowable level and some failing for the same air sampled (presented at American Industrial Hygiene Conference and Exhibition in Denver, CO 2010 – PO128).
Regarding question 3, the answer is no. Paul Pope with ALS Environmental in Salt Lake City, UT (a lab that has been around for decades and used to assist in creating methods for OSHA and NIOSH) assessed the list and grouped it into eight different methods required to assess all the compounds. Of those eight methods, only the TO-17 method in LEED 4 was applicable. The cost would be over $800 per sampling location plus markup. That is just for the “VOCs” with normal 5- to 10-day turnaround. Add another $100 to $300 for lab or rental for the others parameters for each sampling location. This is more than $1,000 lab/rental fees for each sampling location – just the lab cost. For LEED 2009 sampling I was charging less than $900 per sampling location for the whole job (lab, labor, report, 3-day turnaround, etc.). This fee per location would decrease the more locations tested (based on the size of the building). With all the extra labor for sampling plus the higher lab/rental costs it would be hard to keep the fees below $2,000 per sample location. In other words, the LEED 4 testing costs more than twice what it did before for little or no extra benefit, though the initial benefit of this whole LEED IAQ approach has little benefit in the first place.
It should be noted that the California “stuff” that was incorporated into LEED started with “The Air Toxics "Hot Spots" Information and Assessment Act of 1987 (AB 2588)” which was for regulating emissions to the atmosphere from chemical plants. See the AIR TOXICS "HOT SPOTS" (AB 2588) - PUBLIC NOTIFICATION PROCEDURES at http://www.vcapcd.org/pubs/Engineering/AirToxics/finalgl.pdf. This legislation was mostly in response to the Bhopal, India pesticide release from a Union Carbide facility in December, 1984 which reportedly killed as many as 16,000 people and injured over half a million. It has since evolved into chamber testing for chemical emissions from building products. The document that LEED references for the chemical list is titled “STANDARD METHOD FOR THE TESTING AND EVALUATION OF VOLATILE ORGANIC CHEMICAL EMISSIONS FROM INDOOR SOURCES USING ENVIRONMENTAL CHAMBERS”. Table 4.1 in that document is the source of the LEED 4 chemical list. The source of the allowable levels is from the California OEHHA list of reference exposure limits (RELs). These are supposedly allowable indoor air levels for 99 different compounds based on risk assessments (voodoo science in my opinion). What happened to the other 66 that aren’t included in Table 4.1? Isn’t this whole LEED air testing for VOCs based on a method for evaluating VOC emissions from “indoor sources” in a chamber – not in the general air? WHAT DOES ALL THIS HAVE TO DO WITH AMBIENT VOCS IN AN OCCUPIED BUILDING AND THEIR POTENTIAL IMPACT ON AIR QUALITY AND OCCUPANT HEALTH???? The stated intent of this LEED 4 IAQ credit is “To establish better quality indoor air in the building after construction and during occupancy.” It is obvious that the approach LEED has taken is wrong. The proper approach would be from the occupational exposure point of view through the regulations and guidelines of agencies and organizations such as OSHA, NIOSH, ACGIH, etc. – NOT THE EPA OR CalEPA. The occupational exposure limits simply need to be properly adjusted to accommodate a more sensitive and varied population in a non-industrial worker setting.
I am a firm believer in “Don’t Complain If You Don’t Have a Better Alternative”. I have published and presented my alternatives “20 Reasons Your Green Building May Not Have Green Indoor Air” (search the internet). In my experience, if any individual VOC that is collected or analyzed using the EPA TO-15 or TO-17 methods (most common industry methods) with tentatively identified compounds listed has a level detected that is within one one-thousandth of the ACGIH TLV or another more conservative occupational exposure limit (OEL), then it should be further investigated as to its source (except formaldehyde). Also in my experience, when an individual VOC is elevated it rarely, if ever, is associated with a new building material. It is usually occupant related (personal care products, perfumes, cleaners, fuels, etc.). When it is building related it is poor outdoor air intake locations (vehicle exhaust, sewer gas, cooking odors, cooling towers, emergency generators, dust, etc.) refrigerant leaks, roof deterioration emissions, moisture intrusion or water leaks, inadequate or improperly designed or maintained air filters and ventilation systems, negative building pressurization, etc.
I hope that the realization of the folly of the LEED 4 IAQ testing credit, as well as the worthless waste of money and time called flush out, that Helene’s posted questions engenders will eventually cause the LEED IEQ TAG to re-think its approach and actually ask for and listen to the experts in this field.
Alice Delia
Laboratory DirectoPrism Analytical Technologies
1 thumbs up
January 4, 2017 - 1:41 pm
Addressing your questions 2 and 3 -
2. As Dale stated, the exact definition of a VOC is a bit loose but all the conversions of temperature and vapor pressure pretty much coincide with a range of chemical compounds containing 6 to 16 carbon molecules (often referred to as C6-C16).
So, anything lighter or smaller than hexane (which is C6) would be termed very volatile (VVOC) instead of volatile (VOC). There are 6 chemical compounds in the Table 1 list lighter than hexane.
There are also some compounds that are VOCs in terms of their chemical makeup and size but are classified as "VOC-exempt" because they are not photochemically active; this is really an outdoor distinction so not particularly relevant to indoor environments but the definition still stands. Compounds like glycols and glycol ethers are typically VOC-exempt so it's up to interpretation whether the VOC-exempt classification applies here.
Analytically, this list of compounds is very challenging but my lab has been working on it for quite a while and are now able to supply concentrations for all VOCs in Table 1 with the exception of formaldehyde using a single sample. We use thermal desorption (TD) GC-MS; ISO 16000-6 or EPA TO-17.
Whether these compounds truly represent the worst offenders in indoor air quality is a separate question. I've looked at thousands of samples for indoor air quality and there are a few of these compounds I've never seen.
In Dale Walsh's comment on your post, he also commented on the TVOC requirement. ISO 16000-6 does actually define TVOC in section 11.3:
"Consider the entire area of the chromatogram between n-hexane and n-hexadecane. Using the toluene response factor, convert the area into mass units of toluene."
This is the same C6-C16 range commonly used to define VOCs.
Hope that helps!
Feel free to contact me directly for more info on how my lab performs this VOC testing.