Research Triangle Institute                                                      August 28, 2008
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                 Test/QA Plan for Mold-Resistant Building Material Testing
                                      Prepared by:

                               Research Triangle Institute
                               Research Triangle Park, NC
Approved by:

RTI Project Manager:	signed by Karin Foarde on September 16, 2008	
Karin K. Foarde

RTI Quality Assurance Manager:    	signed by W. Gary Eaton on September 16, 2008
W. Gary Eaton

EPA Project Officer:  	signed by Timothy Dean on October 23. 2008	
Timothy Dean

EPA Quality Assurance Manager:	signed by Robert Wright on October 23, 2008
Robert Wright

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This document serves as the Test and Quality Assurance (QA) plan for mold-resistant building
material testing. The Quality Management Plan (QMP) under which this work is conducted is the
Verification Testing of Air Pollution Control Technology Quality Management Plan, Revision
2.2, February 17, 20051. This QMP was approved by EPA for the ETV program and fulfills the
requirements of the ETV program-level QMP.

                                  Acknowledgement

RTI would like to thank the stakeholders who input to this program.

                Stakeholders
Taj ah Blackburn, US EPA
Doris Betancourt, US EPA
Alison Kinn, US EPA
Laura Kolb, US EPA
Russ Jerusik, Hercules
David Marciniak, General Services Administration
Janet Macher, California Department of Health
Services
Marc Menetrez, USEPA

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                                  Table of Contents

Test/QA Plan for Mold-Resistant Building Material Testing	i
Table of Contents	iii
A3: Distribution List	v
List of Acronyms/Abbreviations/Definitions	vi
List of Acronyms/Abbreviations/Definitions	vi
SECTION A: PROJECT MANAGEMENT	1
A4: Project/Task Organization	1
  A4.1: Management Responsibilities	1
    A4.1.1: EPA Project Officer	1
    A4.1.2: RTI Project Manager	1
  A4.2: Quality Assurance Responsibilities	2
    A4.2.1: EPA Quality Assurance Manager	2
    A4.2.3: RTI Quality Assurance Manager	2
A5: Problem Definition/Background Information	2
A6: ESTE Testing - Description and Schedule	4
  A6.1: Description of Testing	5
    A6.1.1: Identification and Acquisition of Mold-Resistant Building Materials	5
    A6.1.2: Performance of Mold Resistance Testing	5
    A6.1.3: Preparation of Report	6
  A6.2: Schedule	6
A7: Data Quality Objective and Criteria for Measurement Data	6
A8: Special Training Requirements/Certification	6
A9: Documentation and Records	7
  A9.1: Laboratory Documentation	7
  A9.2: QA Reports	7
  A9.3: Reporting	7
  A9.4: Verification Reports	8
    A9.4.1 Environmental Sustainability Criteria	8
SECTIONS:    MEASUREMENT/DATA ACQUISITION	9
Bl: Test Design	9
Bl.l   Static Chambers	9
  B1.2   Test Organisms	9
  B1.3   Sample Preparation and Inoculation	10
B2: Sampling Methods Requirements	10
B3: Sample Handling and Custody Requirements	11
B4: Analytical Methods Requirements	11
B5: Quality Control Requirements	11
B6: Instrument/Equipment Testing, Inspection, and Maintenance Requirements	11
B7: Instrument Calibration and Frequency	12
B8: Inspection/Acceptance Requirements for Supplies and Consumables	12
B9: Data Acquisition Requirements (Non-direct measurements)	12
BIO:  Data Management	12
  B10.1: Data Recording	12
  BIO.2: Data Analysis	12

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  BIO.3: Data Storage and Retrieval	12
SECTION C: ASSESSMENT/OVERSIGHT	14
Cl: Assessments and Response Actions	14
  Cl.l: Audits	14
  C1.2: Corrective Actions	14
C2: Reports to Management	15
SECTION D: DATA VALIDATION AND USABILITY	16
Dl: Data Review, Validation, and Verification Requirements	16
D2: Validation and Verification Methods	16
D3: Reconciliation with Data Quality Objectives	16
References	17
RTI Operating Procedures Referenced in the Test/QA Plan	20
Appendix A Moisture Testing	21
Appendix B. Emissions Testing	23
                                     FIGURES

Figure 1. Organization Chart	1
Figure 2. Diagram illustrating the conditions required for fungal growth on a material	3

                                 LIST OF TABLES

Table 1. Data Quality Objectives	6
Table 2. RTFs ETV Assessments	14

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A3:  Distribution List

EPA
Dr. Timothy Dean
Dr. Doris Betancourt
Mr. Robert Wright

Research Triangle Institute
Ms. Karin Foarde
Dr. Jonathan Black
Dr. Keith Esch
Mr. Michael Herman
Ms. Amy Rothbard
Ms. Tricia Schwartz
Dr. W. Gary Eaton

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List of Acronyms/Abbreviations/Definitions
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       Page vi
ACH
ADQ
ASTM
&w
CPU
DNPH
DQO
EPA
ESTE
ERH
ETV
g
GC/MS
ISO
MC
ML
ML SOP
QA
QAM
QAPP
QC
QMP
RH
RTI
sec
SOP
spp
t
TOP
T/QAP
TSA
TVOC
VOC
Mg
(j,m
air changes per hour
audit of data quality
American Society for Testing and Materials
water activity
colony forming unit
2,4-dinitrophenylhydrazine
data quality objective
U.S. Environmental Protection Agency
environmental and sustainable technology evaluations
equilibrium relative humidity
environmental technology verification
gram(s)
gas chromatography/mass spectrometry
International Organization for Standardization
moisture content
microbiology laboratories
microbiology laboratory standard operating procedure
quality assurance
quality assurance manager
quality assurance project plan
quality control
quality management plan
relative humidity
Research Triangle Institute (RTI International)
second(s)
standard operating procedure
species
temperature
technical operating procedure
test/quality assurance plan
technical system audit
total volatile organic compounds
volatile organic compounds
microgram(s)
micrometer(s)

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SECTION A: PROJECT MANAGEMENT
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       Page 1
A4:  Project/Task Organization
The Environmental Technology Verification (ETV) / Environmental and Sustainable
Technology Evaluations (ESTE) Program was established by the U.S. Environmental Protection
Agency's Office of Research and Development to accelerate the development and
commercialization of improved environmental technologies through third party verification and
reporting of performance. RTI will perform the testing, evaluate the data, and prepare the
verification reports.  The various quality assurance (QA) and management responsibilities are
divided between EPA and RTI key project personnel as defined below.  The lines of authority
between key personnel for this project are shown on the project organization chart in Figure 1.



EPA Project Officer
Timothy Dean


RTI Project
Manager
Karin Foarde


RTI Technical Staff


• • • • •
• • • • •

EPA Quality
Assurance Manager
Robert Wright

RTI Quality Assurance
Manager
W. Gary Eaton


       Figure 1. Organization Chart. Dotted lines indicate organizational independence.

A4.1: Management Responsibilities
Project management responsibilities are divided between EPA and RTI personnel as listed
below.

A4.1.1:  EPA Project Officer
Dr. Timothy Dean is the EPA Project Officer for the contract. He is responsible for oversight of
this program.

A4.1.2:  RTI Project Manager
The RTI Project Manager, Ms. Karin Foarde is responsible for task implementation and technical
quality control.  The RTI Project Manager is also responsible for the following:
    •  Update and deliver revisions of the Test/Quality Assurance Project Plan (T/QAP),
    •  Define task objectives in coordination with EPA,
    •  Develop a detailed work plan schedule,

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   •   Halt testing if there is a quality or safety problem,
   •   Work with vendors and stakeholders,
   •   Review work progress to ensure that task budgets and schedules are met, and
   •   Prepare verification reports.

Ms. Foarde will also be the technical leader and will review and compare the results for
consistency based on her experience with the respective components of the tests.

A4.2: Quality Assurance Responsibilities
QA responsibilities are divided between the EPA and RTI personnel as listed below.

A4.2.1: EPA Quality Assurance Manager
The EPA Quality Assurance Manager (EPA QAM), Mr. Robert Wright, will conduct audits of
RTFs QA System1 and of specific technical activities on the project as specified by EPA. He
will be available to resolve any QA  issues relating to performance and EPA's QA requirements.
Specific functions and duties of the  EPA QAM include approving the contents of this T/QAP
and subsequent revisions, performing a ISA (technical system audit) on RTI, and reviewing QA
reports prepared by RTI, including RTFs internal QA evaluations and audits.

A4.2.3: RTI Quality Assurance Manager
The RTI Quality Assurance Manager (RTI QAM), Dr. W. Gary Eaton, is organizationally
independent of the RTI Project Manager and is responsible for ensuring that QA/quality  control
(QC) procedures described in this T/QAP are followed.  In addition, the RTI QAM will:
   •   Maintain regular communication with the EPA QAM regarding QA issues,
   •   Report on the adequacy, status, and effectiveness of the QA program to the Project
       Manager,
   •   Conduct an internal TSA after samples have been received and cut for distribution. This
       will constitute a "readiness review." An audit of data quality (ADQ) will be conducted
       after results from day zero are in hand.  Any TSA items not completed during "readiness
       review" will be completed at the time of the ADQ.
   •   Halt testing if a quality or safety problem is found in  the TSA, after consultation with
       RTI program manager,
   •   Ensure that corrective action, if necessary, is properly implemented and documented,
• Review and approve test (including QC) reports, and
• Prepare the QA section of each verification report.

A5: Problem Definition/Background Information
Fungal growth and the resulting contamination of building materials is a well-documented
problem, especially after the reports from New Orleans and the US Gulf Coast post Hurricane
Katrina. However, contaminated materials have been recognized as important indoor fungal
reservoirs for years. For example, contamination with fungi has been associated with a variety of
materials including carpet,  ceiling tile, gypsum board, wallpaper, flooring, insulation, and
heating, ventilation and air conditioning components2'3'4'5.

Exposure to fungi may result in respiratory symptoms of both the upper and lower respiratory
tract such as allergy and asthma6. Everyone is potentially susceptible.  However, of particular

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concern are children with their immature immune systems and individuals of all ages that are
immunocompromi sed7'8.

One approach to limiting exposure is to reduce the levels of fungi in the indoor space. For some
sensitive individuals, limiting exposure through avoidance is an effective control method;
however, avoidance is not always possible or practical.  The investigation, development, and
application of effective source controls and strategies are essential to prevent fungal growth in
the indoor environment. Mold resistant building material is a potentially effective method of
source control.

A building is not a sterile environment, nor should it be. However, a building may serve as a
reservoir for microorganisms. While many different types of microorganisms occupy indoor
spaces, it is well-recognized that fungi can colonize and amplify on a variety of building
materials if sufficient nutrients and moisture  are present. These contaminated materials are
known to be important indoor reservoirs. Fungal growth on natural and fabricated building
materials can be a major source of respiratory
disease in humans.  Some common environmental
fungi that have been isolated from contaminated
materials include Acremonium spp., Alternaria spp.,
Aspergillus spp., Chaetomium spp.,  Cladosporium
spp., Epicoccum spp., Fusarium spp., Penicillium
spp., Stachybotrys spp., and Trichoderma spp.

Figure 2 illustrates the combination of moisture and
nutrients required for microbial growth on a
material. Sufficient nutrients for growth may be
provided by the material itself or through the
accumulation of dust on or in the material. When
sufficient nutrients are available, the ultimate
determinate for microbial growth is availability of
water. The more hygroscopic a material is, the more
impact on the overall hygoscopicity the surface
treatments may have.
Figure 2. Diagram illustrating the
conditions required for fungal growth
on a material.
This test plan addresses three specific characteristics of mold resistant building material: 1) mold
resistance, 2) emissions of VOCs and aldehydes, and 3) moisture content. Mold resistance is the
critical measurement, so the T/QAP is focusing on mold resistance. Moisture content and
emissions of VOCs and aldehydes are ancillary tests and may or may not be performed
depending upon the relevance to the test material. Information can be found in Appendix A and
B, respectively. Other characteristics, such as fire resistance,  are important and should be
considered by users of the products, but are beyond the scope of this test plan.

A building is not a sterile environment, nor should it be. In fact, a building is frequently a
reservoir for microorganisms. While many different types of microorganisms occupy indoor
spaces, it is well-recognized that fungi can colonize and amplify on a variety of building
materials if sufficient nutrients and moisture  are present. These contaminated materials are
known to be important indoor reservoirs. Fungal growth on natural and fabricated building

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materials can be a major source of respiratory disease in humans.  Some common environmental
fungi that have been isolated from contaminated materials include Acremonium spp., Alternaria
spp., Aspergillus spp., Chaetomium spp., Cladosporium spp., Epicoccum spp., Fusarium spp.,
Penicillium spp., Stachybotrys spp., and Trichoderma spp.

Mold resistance testing will be performed following the guidelines outlined in ASTM 6329-98
(2008)9.  This method was developed as part of a more comprehensive project to apply indoor air
quality engineering to biocontamination in buildings. One of the primary goals was to provide a
scientific basis for studying indoor air biocontaminants. Available methods, including those from
ASTM, AATCC, and UL, for evaluating the resistance of a variety of materials to fungal growth
were surveyed at the initial stages of that project. Although the basic principals were similar, a
major concern was the way growth on the different materials was evaluated. Although
quantitative methods for inoculation were employed, none assessed growth as the endpoint
quantitatively. The strategy was to develop a method that would provide a quantitative endpoint
for growth in a well-controlled environment to and to improve repeatability and comparability.
The method has been successfully used to evaluate fungal resistance on a variety of materials
including ceiling tiles and HVAC duct materials 10'n'12>13.

A6:  ESTE Testing - Description and Schedule
The ESTE testing for mold-resistant building material will be performed under the US EPA's
quality system whose goal is to ensure that environmental programs and decisions are supported
by data of the type and quality needed and expected for their intended use, and that decisions
involving environmental technology are supported by appropriate quality-assured engineering
standards and practices. The implementation of the EPA Quality System is based on  a graded
approach, meaning that quality systems for different organizations and programs will vary
according to the specific objectives and needs of the organization. EPA requires that contractors
performing research or testing for EPA have both  a quality management plan1 and a quality
assurance project plan (QAPP) (or test plan) - this document.

The ETV management plan states:
       The quality system for the overall ETV program seeks to be consistent with industry
       consensus standards. Each verification organization shall implement a valid and approved
       quality system. The Agency's required quality system for cooperative agreements and
       contracts is ANSI/ASQC E4. Each verification test will be performed according to
       planned and documented, pre-approved test/QA plans. All technical statements in ETV
       verification reports shall be supported by the appropriate data14.

ETV requires that all test plans, data and results be reviewed by both the company (in this case,
RTI) and the EPA project quality managers. In addition, both RTI and EPA perform  audits of the
RTI ESTE quality system and how the testing is being performed and how ETV quality
management performs.

EPA uses the data quality objective (DQO) process as defined in Guidance on Systematic
Planning using the Data Quality Objectives Process (QA/G-4)15. The DQO process is used to
establish performance or acceptance criteria, which serve as the basis for designing a plan for
collecting data of sufficient quality and quantity to support the goal of a study15. DQOs may

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include specific values for accuracy and precision, but they will often provide one value that
incorporates both entities.

EPA and ETV strongly support the use of international consensus standards, however,
recognizes that a laboratory will need to supplement standards with their own SOPs. The
following sections indicate which standards are used in developing this QAPP/test plan. This
document is written in a format defined by EPA that includes sections not found in a standard
test method. This document will indicate sections and document information when procedures
are being used from those documents.

A6.1:  Description of Testing
The ESTE verification test includes separate tests to be performed on each building material
product submitted for testing:
   •   Mold resistance testing.
   •   VOC and aldehyde emissions testing, and
   •   Moisture content

Testing for VOC and aldehyde emissions and moisture content are ancillary tests which may or
may not be performed depending upon the relevancy to the test material. Some materials have
undergone GreenGuard testing for VOC emissions. For those products, the test report
downloaded from the website will serve as the ancillary report. The use  of this report falls under
the use of existing data clause in the ETV management plan

The testing consists of the three steps summarized below:
•  Acquiring the mold-resistant building material products for testing,
•  Performing the testing of the products, and
•  Preparing verification reports and summary statements.

Each of the three tests is discussed separately. The moisture test can be found in appendix A. The
VOC  and aldehyde emissions test can be found in appendix B. Both tests are considered optional
and will be performed as appropriate for a test material.

A6.1.1: Identification and Acquisition of Mold-Resistant Building Materials
The companies will provide their building material product to RTI for testing.   Tricia Schwartz
will be the custodian at RTI and will be responsible for storage, labeling, etc. of the products.
She is responsible for documentation showing chain of custody. Each piece of building material
product will be labeled as will the samples cut from it. The products will be stored in the
Building 11, Bay 1 storage room at RTI until used and will be retained until the verification
report for the  product is approved. All products will be logged in upon receipt and will be
checked out for testing, then the unused portion will be returned to the storage room when testing
is complete.

A6.1.2: Performance of Mold Resistance Testing
Mold resistance testing will be performed following the guidelines outlined in ASTM D6329-98
(2008)9.  The  specifics of the test and the related  SOPs are discussed in further detail in Section
B1.2.  In overview, the test organisms are inoculated by pipette directly onto the surface of each
building material piece in sufficiently high numbers to provide an adequate challenge, but at a

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level that is realistic to quantitate. The tests will run for 12 weeks.  Within the 12 weeks of the
test, four test days, Day 0, Week 1, Week 6, and Week 12 will be evaluated. Day 0 will provide
the baseline inoculum level. A sufficient number of test pieces will be inoculated simultaneously
for all four test days. All of the pieces for one material and one test organism will be put in the
same static chamber. Two test organisms, Stachybotrys chartarum and Aspergillus versicolor
will be used. The chambers will be set to 100% ERH for the tests with S. chartarum and at 85%
for A versicolor. On each test day (including day 0), five replicates of the test material pieces are
removed from the chamber, placed in sterile buffer, and extracted by shaking. The resulting
suspension of eluted organisms is plated and microbial growth on materials quantitated by
manually enumerating colony-forming units (CPU),

The numbers of CPU eluted on test days week 1, 6, and 12 and compared to the baseline at Day
0.  The numbers of CPU are expressed as logio.  The results will be reported as the log change in
CPUs between Day 0 and Week 1, Day  0 and Week 6, and Day 0 and Week 12.

A6.1.3: Preparation of Report
The final step is to complete the verification report and verification statement for each product
tested and submit them to EPA for review.

A6.2: Schedule
The verification will begin when the T/QAP is approved by EPA and will continue at least until
all three initial products are tested. Testing may continue beyond that if there are  additional
products and funding to test.

A7: Data Quality Objective and Criteria for Measurement Data
Data quality objectives (DQOs) are qualitative and quantitative statements designed to ensure
that the type, quality, and quantity of data used are appropriate for the intended application.  The
DQO for the critical measurement, quantitation  of fungal growth on an individual test date, is
found in Table 2.

                            Table 2.  Data Quality Objectives

Test
Mold
Resistance

Parameter
Quantitation of
fungal growth on an
individual test date
DQO
Precision
± 5-fold difference
Accuracy
10% of the plates
will be counted by
a second operator.
± 20% agreement
between the
operators
Completeness
100%
All RTI data will be reviewed for accuracy (correctness) and reasonableness. If the results are
deemed unreasonable (e.g., internally inconsistent), they will be discarded, the procedures
reviewed, and the test repeated if necessary.  Data points that are analyzed and determined to be
obvious outliers will be discarded without requiring the entire test to be repeated.
A8:  Special Training Requirements/Certification

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There are no specialized certification requirements specified for these tests.  The RTI Project
Manager will be responsible for overseeing all work and ensuring that RTI personnel are fully
trained in each operation for the microbial, VOC, and moisture testing. RTI personnel working
with the mold resistance testing are trained to perform all of the required procedures, including
determining microbial growth.

A9:  Documentation and Records
This section identifies the documents and reports to be generated as part of the verification
program  and the information to be included in the verification reports. A description of the data
management system established for this task is presented in Section B. 10.

Requirements for record keeping and data management for the overall program are found in the
Quality Management Plan (QMP) for the Verification Testing of Air Pollution Control
Technology, Revision 2.21,  including Table 5-1, Records Management Responsibilities for ETV.
All ML SOPs and TOPs (Technical Operating Procedures) are maintained on file at RTI. Access
to these files is permitted on-site at RTI and will be available for review during internal and
external TSAs.

A9.1: Laboratory Documentation
The culturable test organism counts or CPUs from each test piece on each test day will be
entered in the project notebook or recorded by a computer.  If recorded to a computer, the file
will be saved to the hard drive and later copied to a floppy disk or shared directory for backup.

A9.2: QA Reports
The RTI  QAM will perform an internal TSA based on the approved T/QAP during the first
month of verification; this is considered suitable because this testing program is using well-
known measurement systems  components.  A report will be prepared for the Project Manager
within 15 days of completion  of the audit.

The RTI  QAM will perform an ADQ of all RTI data. RTI will provide a report  of the ADQ to
EPA with the verification report for review.

RTI will  cooperate with audits performed by the EPA Project Officer, EPA QAM, or their
designee insofar as resources permit. EPA will perform a TSA for this project.

A9.3: Reporting
After the completion of tests, the control test data, sample inventory logs, calibration records,
and certificates of calibration will be stored in the laboratories. Copies of these will be made for
RTI and EPA QA.  Calibration records  will include such information as the instrument being
calibrated, raw calibration data, calibration equations, analyzer identifications, calibration dates,
calibration standards used and their traceabilities, identification of calibration equipment used,
and the staff conducting the calibration.  Final reports of self-assessments and independent
assessments (i.e., technical systems audits, performance evaluations, and audits of data quality
[TSAs and ADQs]) will be retained as  required by ETV and RTI. Each verification report will
contain a QA section, which will describe QA activities and the extent to which test data comply
with DQOs.

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A9.4: Verification Reports
Verification reports will be prepared by RTI personnel and reviewed by RTFs Project Manager
and QAM prior to submittal to the EPA Project Manager for review.

There shall be a general discussion of the test process giving dates and other information as
appropriate.

The microbial resistance will be reported as the log change in CPUs between the start date and
each of the four test dates. Each test organism will be reported separately.

The DQO will be reported. The results of the ancillary moisture and emissions tests will also be
included when performed.

A9.4.1 Environmental Sustainability Criteria
A section of the verification report and the verification statement will focus on environmental
sustainability, with information provided by the vendor.

The verification organization will work with the vendor to estimate impacts on solid waste
disposal from replacing building materials less frequently, using the test results for microbial
resistance. If possible this should be done quantitatively with uncertainty estimates.

The vendor will supply the following:
   •   Information regarding the chemicals or other product characteristics that engender the
       product microbial resistant.
   •   For chemical additives that are claimed to confer microbial resistance, the vendor shall
       provide the identity of the chemical and a summary of toxicity information  relative to the
       chemical.  The quantity of the chemical used in the building material product shall also be
       provided.  It is expected that this information will  come from the MSDS sheet, which can
       be included as an appendix to the report.
   •   Additional information relative to the environmental sustainability of the product such as
       recyclability/reusability of the product and disposability of the product and  use of
       renewable resources or other criteria the vendor deems relevant to the environmental
       sustainability of the product.

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SECTION B: MEASUREMENT/DATA ACQUISITION

Bl:  Test Design
Mold resistance testing will be based on ASTM D6329-98 (2008)9, "Standard Guide for
Developing Methodology for Evaluating the Ability of Indoor Materials to Support Microbial
Growth Using Static Environmental Chambers".

Bl.l   Static Chambers
Acrylic desiccators will serve  as the static environmental chambers. The desiccators are sealed so
there is no air exchange and serve as good static chambers. The chamber humidity will be
maintained through the use of saturated salt solutions (ASTM E104-0216) or sterile water.
Temperature control is externally controlled and maintained at room temperature.  Prior to use,
the chambers will be decontaminated following ML (microbiology laboratories) SOP #017
(Standard Operating Procedure for the Decontamination of Humidity Chambers). The chambers
will be characterized following ML SOP #005 (Standard Operating Procedure for the
Characterization of Relative Humidity Chamber) once prior to initiation of the testing.

The chambers will be set to 100% ERH for the tests with Stachybotrys chartarum and at 85% for
Aspergillus versicolor. The ERH in each chamber will be monitored with a hygrometer.

B1.2   Test Organisms
Selecting the "correct" test organism is critical to any test; therefore selection criteria were
developed.  The selection criteria used to choose the appropriate test organisms for this study
were:
1)     the reasonableness or likelihood of the test material being challenged by that particular
       organism when in actual use, and
2)     that they cover the range of ERHs to the needed to bracketing the ERHs where fungal
       growth can occur.

While exposure to many of the fungi can be considered problematic, none are as controversial as
exposure to Stachybotrys char tar uml7'n.  There are numerous reports demonstrating an
association between exposure  to S. chartarum and adverse respiratory heath effects; but none is
as compelling as the paper simply entitled Stachybotrys by Etzel19, which reviews what has been
learned about Stachybotrys and its association with  pediatric pulmonary disease. Pulmonary
hemosiderosis among infants was reported in Cleveland,  OH, in the early 1990s (Etzel20 et al.(a))
although the findings were not sufficient to support an association between Stachybotrys
chartarum on building materials and the disease (Montana21 et al., Etzel22 et al. (b); CDC
MMWR23). In another study,  mycotoxin produced  from S. chartarum on wetted wallboard has
been found to be water-soluble and was toxigenic in vitro (Black24 et al.).

Two fungi will be used as test organism, Aspergillus versicolor and Stachybotrys chartarum.
Both are from the RTI culture collection (CC). The CC number for S chartarum is 3075 and was
received from EPA NERL. A. versicolor is CC #3348, and it is a field isolate. Prior to initiation
of the testing, their identification will be confirmed by standard techniques.  Aspergillus
versicolor is recommended because it is a xerophilic fungus  and capable of growing at lower
relative humidities.  Stachybotrys chartarum is recommended because it requires high levels of
available water to grow and has been associated with  a number of toxigenic symptoms. A.

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versicolor is frequently reported as a causative agent of hypersensitivity pneumonitis and has
been isolated from a number of problem buildings. Both have been reported as growing on
building materials.

B1.3   Sample Preparation and Inoculation
Small (at least 4 cm x 4 cm), replicate pieces of test mold resistant building material will be
prepared and  inoculated. To minimize error and demonstrate reproducibility, five pieces of each
sample type will be  processed on each respective sampling day. Because there are four test dates,
a minimum of 20 pieces will be prepared simultaneously. Each piece is placed on a separate
labeled sterile petri dish.

Fungi media,  cultures, spore isolation, suspension, quantitation, and inoculation on the test
wallboard will follow: ML SOP #001 (Standard Operating Procedure for Media Preparation -
Dehydrated);  ML SOP #002 (Standard Operating Procedure for the Preparation of Sterile
Water); ML SOP #003 (Standard Operating Procedure for the Preparation of Sterile Buffer);  ML
SOP #009 (Standard Operating Procedure for the Quantitative Evaluation of Microorganisms);
ML SOP #012 (Standard Operating Procedure for the Quantitation of Viable Spores in
Suspension Preparation); and ML SOP #058 (Standard Operating Procedure for Direct
Inoculation of Materials with a Spore Suspension). A review of those steps follow.

The fungi challenge suspensions are prepared by inoculating the test organism onto solid agar
media, incubating the culture at room temperature until mature, wiping organisms from the
surface of the pure culture, and eluting them into sterile 18-Mohm distilled water to a known
concentration to serve as a stock solution. The organism preparation is viewed microscopically
to verify purity of spores (absence of hyphae). The suspension is diluted in sterile 18-Mohm
distilled water if needed to a concentration of approximately  105 - 106 CFU/mL. The test pieces
are inoculated (usually with 5  10|iL spots in an X  configuration) by  pipet onto the surface of the
building material test piece and allowed to dry in the biosafety cabinet. The goal is to load each
of the individual test pieces with approximately 103to 105 CPU/piece. The fungi spore
suspension is quantified on appropriate media to enumerate the inoculum.

On each test day (including day 0), the test pieces  will be removed from the static chamber,
placed in approximately 30 mL sterile buffer, and  extracted by shaking using a vortex or wrist
action shaker. The extract is diluted if needed and plated on agar media to determine CPU.

B2:  Sampling Methods Requirements
The mold resistance sampling method requirements and critical dimensions and configurations
of the test chamber are specified in Foarde25 et al.  All sampling methodology will comply where
appropriate.   Static chambers are maintained in accordance with ML SOP #005 (Standard
Operating Procedure for the Characterization  of Relative Humidity Chamber), ML SOP #009
(Standard Operating Procedure for the Quantitative Evaluation of Microorganisms), ML SOP
#017 (Standard Operating Procedure for the Decontamination of Humidity Chambers), and ML
SOP #058 (Standard Operating Procedure for Direct Inoculation of Materials with a Spore
Suspension).  Where used, all  equipment will be calibrated and operated according to the
manufacturer's specifications.

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Each SOP has its own QUALITY ASSURANCE/QUALITY CONTROL section, which
includes the QC Checks, which are available at RTI. As one example, ML SOP #001 Standard
Operating Procedure for Media Preparation - Dehydrated, the QC Checks are as follows:
   •   If balance has an internal calibration program, that may be used, or a check weight can be
       used as first and last weighing. Refer to the procedures outlined in the appropriate user's
       manual for more specific calibration instructions if needed.
   •   Balances are professionally calibrated annually.
   •   If the Manostat is used, the desired volume of media dispensed is checked with a
       graduated cylinder or tube before filling plates.
   •   Incubate plates at room temperature (on counter) for at least 3 days (no more than 5) prior
       to use so that contaminated plates may be identified (appearance of any colonies) and
       disposed of in an appropriate manner.  Media for bacteria may be used if necessary after
       1 day.
   •   Inoculate several plates (~2 out of 100) with a loop of appropriate organism to prove the
       media's ability to sustain growth (see supervisor to ascertain incubation time and
       temperature).
   •   Record the reaction in the media preparation notebook.
   •   After quality control tests have been completed, store bagged and labeled plates upside
       down in  a refrigerator (2-5°C).

B3: Sample Handling and Custody Requirements
Sampling methods and laboratory procedures are described in specific laboratory SOPs. These
SOPs address any anticipated failures and the methods that will be employed to overcome these
failures. Most of the methods are well-known sampling methods; therefore, sampling failures
are not anticipated. Any additional project-specific considerations will be addressed and
included in an updated SOP.  Supporting measurements, such as temperature, relative humidity
or atmospheric pressure, will be recorded in laboratory  data logs, run sheets or notebooks.

B4: Analytical Methods Requirements
The analytical method requirement for the mold resistance in static chamber test is described in
ASTM D6329-98 (2008)9.  The requirements for biological testing are described in the
appropriate ML  SOPs.

B5: Quality Control Requirements
The static chambers are decontaminated and cleaned in accordance with ML SOP #017
(Standard Operating Procedure for the Decontamination of Humidity Chambers). All media and
reagents are QC'd as outlined in ML  SOP #001 (Standard Operating Procedure for Media
Preparation - Dehydrated) and ML SOP #003 (Standard Operating Procedure for the Preparation
of Sterile Buffer).  All laboratory surfaces are disinfected  using ML SOP #023  (Standard
Operating Procedure for Regular Disinfection of Laboratory Surfaces). All laboratory equipment
including the autoclave sterilizer is verified using ML SOP #019 (Standard Operating Procedure
for Maintenance and Record Keeping of Laboratory Equipment).

B6: Instrument/Equipment Testing, Inspection, and Maintenance Requirements
RTI ML instrument maintenance is done in accord with the ML's SOPs.

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B7:  Instrument Calibration and Frequency
Calibration will be performed in accordance with the manufacturer's recommendations or
annually. Recommended instrument calibration frequencies are provided in the respective SOPs
and/or manufacturer's manuals.  Pipettes will be calibrated gravimetrically following ML SOP
#013 (SOP for Pipet Calibration).

B8:  Inspection/Acceptance Requirements for Supplies and Consumables
Chemicals, supplies, and other consumables will be purchased from sources that have provided
high-quality products to the laboratory in the past. Materials such as growth media will be
purchased from a single source to help ensure uniformity throughout the duration of the project.
All supplies will be inspected by the lab personnel. RTFs purchasing department will assist with
the return of any equipment or materials that do not meet project requirements. Items will be
NIST traceable when possible.

B9:  Data Acquisition Requirements (Non-direct measurements)
No types of data are needed for project implementation or decision making that would be
obtained from non-measurement sources such as computer databases, programs, literature files,
or historical databases.

Manual methods of primary data acquisition (e.g., visual CPU counting) are described in ML's
SOPs, while automated data acquisition equipment (e.g., balances and environmental controls) is
checked using procedures recommended by the manufacturer. Procedures for screening and
verifying manually entered data are used to reduce input errors to a minimum through double
checking each other.  Non-experimental data,  such as an MSDS,  will be included in the project
notebook and a copy maintained in the RTI Project Manager's project file.

BIO: Data Management
Guidelines for data management in the ML include the description, location, format, and
organization of all types of records. The RTI Project Manager will oversee all data management
activities.  This section identifies the activities and processes planned for documenting the
traceability of the data, calibrations, and information in the verification  report. Corrections to
manual entries are made on the same line (where possible), are initialed and dated.

B10.1: Data  Recording
Data for this task will be collected either by computer or by manual (handwritten) entries.
Observations  and records (e.g., sample description and collection information) will be recorded
manually in lab notebooks kept exclusively for this task.

B10.2: Data  Analysis
Analysis will  be performed as defined in ASTM D6329-98 (2008), Section 12.3.3.

B10.3: Data  Storage and Retrieval
Laboratory notebooks containing manually recorded information and data output
generated from instrumentation will be stored in the custody of the Project Leader for the
duration of the project. Access to the notebooks is controlled; any changes made are initialed and
dated, thus maintaining a good audit trail.

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Spreadsheet files including raw and calculated data will be stored on computers.  The files will
be downloaded to a network server backed up nightly on magnetic tape. Access to the files are
controlled, with file names indicating date and initials of person creating file, thus maintaining a
good audit trail.

Following ETV policy, data files will be archived for 10 years following the end of the project
and reports will be kept in perpetuity. The records will not be destroyed without written
approval from EPA.

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SECTION C: ASSESSMENT/OVERSIGHT

Cl:  Assessments and Response Actions

Cl.l: Audits
RTI will be subject to both external and internal audits as specified in the ETV QMP1, especially
Table 9-1, ETV Assessments. A subset of that table is shown below, Table 3. Audits based on
this test/QA plan include Technical System Audits (TSAs). RTI raw and summary data are
subject to Audits of Data Quality (ADQs). An external TSA will be conducted by EPA or a
designated representative. Other external audits may be performed. The auditor(s) will
document their findings and note where corrective actions are necessary.  The auditor(s) will
distribute audit reports to those listed in Section A3 as well as to the supervisor whose laboratory
was audited. RTI will provide the QA reports, including the ADQ report, to EPA with the
verification report for review.
                            Table 3. RTI's ETV Assessments
Assessment Tool

Technical
Systems Audits





Audits of Data
Quality







Assessors

Self
RTI QAM

Independent
EPA QAM


Self
RTI QAM

Independent
EPA QAM




Subject of
Assessment
Test/QA plan






Raw data and
summary data







Minimum
Frequency
Serf
Once per technology
evaluation

Independent
Once per year, as
applicable
Self
At least 10% of the
data in each
technology
evaluation
Independent
Each technology
evaluation, as
applicable
Reason for
Assessment
Assess
technical
quality of
evaluations



Assess data
calculations
and reporting






Report Reviewed by

EPA Project Officer

EPA QAM

RTI Project Manager


EPA Project Officer

EPA QAM

RTI Project Manager




C1.2: Corrective Actions
Technical personnel will have the direct responsibility for ensuring that whenever accuracy or
bias is outside the limits of the DQOs for the critical measurements that corrective actions are
taken. Corrective action will be taken If procedures are found to be faulty, corrective action will
also be taken.

Corrective actions include:
•   Problem identification;
•   Attempting to find the cause;
•   Attempting immediate steps to remedy the situation (if possible);
•   Reporting or documenting the problem;
•   Planning for corrective action (if major repairs are needed);

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•  Checking that the problem was corrected;
•  Documenting the corrective actions taken; and
•  Recommending changes to instruments, SOPs, etc. to avoid similar future occurrences.

The RTI QAM and Project Manager will be jointly responsible for proper documentation of
corrective actions.  Minor corrective actions are to be recorded in the laboratory notebooks.
Major problems will be addressed as outlined above.  All corrective actions will be noted in the
verification report.  Depending on the time and expense involved with necessary corrective
actions, it will be necessary to consult the Program Manager or the sponsor before implementing
any changes in the planned activities.

C2:  Reports to  Management
The RTI Project  Manager will notify the EPA Project Officer when testing under this project is
being conducted. The RTI Project Manager will submit verification reports, as well as data, to
the RTI QAM. The RTI QAM will submit reports of all technical assessments to the RTI Project
Manager.  The RTI Project Manager will submit verification reports to the EPA Project Officer.

TSA and ADQ reports will be sent to the EPA Project Officer and QAM.

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SECTION D:  DATA VALIDATION AND USABILITY

Dl:  Data Review, Validation, and Verification Requirements
The verification is acceptable if all the measured parameters fall within the DQO limits described
in Table 2.  The test operator and analyst are responsible for checking that all measured
parameters fall within prescribed limits before continuing testing.

D2:  Validation and Verification Methods
Both the test operator and the test analyst will verify that the test data have been correctly
entered and processed and that all manual calculations are correct. They will verify all newly
developed or modified software, including spreadsheets for correctness before using the software
to process project data.

Each verification report will be reviewed by the RTI QAM for compliance with the applicable
method and for the quality of the data reported.

The RTI QAM will check for the following:
•  Data completeness,
•  Initial and continuing calibrations, and
•  QC reference and internal standards.

D3:  Reconciliation with Data Quality  Objectives
Each ETV verification report will present the critical and relevant ancillary measurements.

The program manager will be responsible for reconciling  data sets with the DQOs. She will work
with the QAM for the mold resistance testing and with RTI technical staff for the moisture and
emissions testing. This will be done during the ADQ and will be reported in  the ADQ report.

Actual data quality will be compared with the DQO specified in Section A7; if the data quality
meets or exceeds the objectives and verification specifications have been met, the test data will
be considered  acceptable.  If exceptions are identified, the issues will be investigated for impact
on the credibility of the data, the EPA QAM will be consulted, and the verification results
disposed of on the basis of this careful consideration. If the impact is not significant, the data will
be reported with indication of the  exceptions.

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                                      References

1.  RTI (Research Triangle Institute). 2005. Quality Management Plan for Verification Testing
   of Air Pollution Control  Technology, Revision 2.2, Research Triangle Park, NC.
   http://etv.rti.org/apct/pdf/apctqmp.pdf
2.  Morey, P.R., 1988, "Microorganisms in Buildings and HVAC Systems: A Summary of 21
   Environmental Studies," Proceedings of the ASHRAE Conference on Indoor Air Quality,
   American Society of Heating, Refrigeration, and Air-Conditioning Engineers, Atlanta, GA,
   pp 10-24.
3.  Reynolds, SJ,, AJ. Steifel, and C.E. McJilton, 1990, Elevated Airborne Concentration of
   Fungi in Residential and Office Environments, American Industrial Hygiene Association
   Journal, Vol. 51, pp 601-604.
4.  Leese, K.E., E.G. Cole, and J.D. Neefus, 1992. Biocide Mitigation of a Mold Contaminated
   Building: An Initial Preventive Approach, Proceedings, American Industrial Hygiene
   Association Annual Meeting, Washington, DC.
5.  Kozak, P.P., et al, 1980.  Currently Available Methods for Home Mold Surveys. II. Examples
   of Problem Homes Surveyed, Annals of Allergy, Vol. 45, pp 167-176.
6.  Garrett, M.H., Rayment, P.R., Hooper, M.A., Abramson, M.J., and Hooper, B.M. Indoor
   airborne fungal spores, house dampness and associations with environmental factors and
   respiratory health in children, Clinical and Experimental Allergy 1998: 28: 459-467.
7.  Rylander, R. and Etzel, R. Indoor mold and children's health. Environmental Health
   Perspectives Supplements 1999:107: 465-517.
8.  Gent, J.F., Ren, P., Belanger, K., Triche, E., Bracken, M.B., Holford, T.R., and Leaderer,
   B.P. Levels of household mold associated with respiratory symptoms in the first year of life
   in a cohort at risk for asthma. Environmental Health Perspectives 2002: 110: A781-A786.
9.  ASTM D6329-98(2008), Standard Guide for Developing Methodology for Evaluating the
   Ability of Indoor Materials to Support Microbial Growth Using Static Environmental
   Chambers, American Society for Testing and Materials, West Conshohocken, PA.
10. Foarde, K.K. and M.Y. Menetrez. 2002. Evaluating the Potential Efficacy of Three
   Antifungal Sealants of Duct Liner and Galvanized Steel as Used in HVAC Systems. Journal
   of Industrial Microbiology & Biotechnology. 29:3 8-43.
11. Foarde, K.K. and J.T. Hanley. 2001. Determine the Efficacy of Antimicrobial Treatments of
   Fibrous Air Filters. ASHRAE Transactions. Volume 107, Part 1.  156-170.
12. Chang, J.C.S., K.K. Foarde, and D.W. VanOsdell. 1995.  Growth Evaluation of Fungi
   (Penicillium andAspergillus spp.) On Ceiling Tile.  Atmospheric Environment. 29:2331
   2337.
13. Foarde, K., E. Cole, D. VanOsdell, D. Bush, D. Franke and J. Chang. 1992.
   Characterization of Environmental Chambers for Evaluating Microbial Growth on Building
   Materials. In: IAQ '92 Environments for People, proceedings; 185-190.
14. U.S. EPA. 2002. Environmental Technology Verification Program Quality Management
   Plan,  EPA/600/R-03/021, U.S. EPA, Cincinnati, OH.
   http://www.epa.gov/etv/pdfs/qmp/00 qmpetv.html.
15. U.S. EPA, 2006).Guidance on Systematic Planning using the Data Quality Objectives
   Process (QA/G-4), Washington, DC. http://www.epa.gov/quality/qs-docs/g4-fmal.pdf
16. ASTM El04-02, 2002, Standard Practice for Maintaining Constant Relative  Humidity by
   Means of Aqueous Solutions. American Society for Testing and Materials, West
   Conshohocken, PA.

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17. Kuhn, D.M. and M.A.Ghannoum, 2003, Indoor mold, toxigenic fungi, and Stachybotrys
   chartarum: infectious disease perspective, ClinMicrobiolRev, 16:144-172.
18. Robbins, C.A., Swenson, L.J., Nealley, M.L., Gots, R.E. and Kelman, BJ. 2000. Health
    effects of mycotoxins in indoor air:  a critical review. Applied Occupational and
    Environmental Hygiene 15: 773-784.
19. Etzel, R.A., 2003. Stachybotrys, Curr OpinPediatr, Vol 15 (1) 103-106.
20. Etzel, R.A (a)., Montana, E.,  Sorenson, W.G., Kullman, G.J., Miller, J.D., Jarvis, B.B.,
   Dearborn, D.G., 1996. Pulmonary hemosiderosis associated with exposure to Stachybotrys
   atra, Epidemiology, 7, S3 8.
21. Montana, E., Etzel, R.A., Allan,!., Horgan, T.E., Dearborn, D.G., 1997. Environmental risk
   factors associated with pediatric idiopathic pulmonary hemorrhage/hemosiderosis in a
   Cleveland community, Pediatrics, 99, 117-124.
22. Etzel, R.A (b).,  Montana, E.,  Sorenson, W.G., Kullman, G.J., Allan, T.M., Dearborn, D.G.,
   1998. Acute pulmonary hemorrhage in infants associated with  exposure to Stachybotrys atra
   and other fungi, Arch. Pediatr. Adolesc. Med., 152, 757-762.
23. CDC MMWR, 2000. Update: Pulmonary Hemorrhage/Hemosiderosis Among Infants—
   Cleveland, Ohio, 1993-1996, JAMA 283, 1951-1953.
24. Black, J. and Y.M. Menetrez. 2006. Solvent Comparison in the Isolation, Solubilization, and
   Toxicity of Stachybotrys chartarum spore trichothocene mycotoxins in an established in
   vitro luminescence protein translation inhibition assay. Journal of Microbiological Methods,
   66:354-361.
25. Foarde, K. (b), VanOsdell, D., Chang, J., 1994. Static chamber method for evaluating the
   ability of indoor materials to  support microbial growth. In: American Society for Testing and
   Materials Symposium, Washington, D.C., pp. 25-28.
26. West, M.K. and Hansen, E.G. (1989) "Determination of material hygroscopic properties that
   affect indoor air quality", In:  Proceedings IAQ '89 - The Human Equation: Health and
   Comfort, American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc.,
   Atlanta, GA, pp. 224-231.
27. Foarde, K. (a), Dulaney, P., Cole, E., VanOsdell, D., Ensor, D. and Chang, J. (1993)
   "Assessment of fungal growth on ceiling tiles under environmentally characterized
   conditions", In: Proceedings Indoor Air '93, 4, pp. 357-362.
28. Pitt, J.I. (1981)  Food storage and biodeterioration, Biology of Conidial Fungi. Academic
   Press, pp. 111-142.
29. Corry, J. (1987) Relationships of water activity to fungal growth, Food and Beverage
   Mycology, VanNostrand Reinhold, pp. 51-99
30. RTI. 1999. Large Chamber Test Protocol for Measuring Emissions of VOCs and
   Aldehydes From Commercial Furniture. US. EPA ETV Program.
   http://www.epa.gov/etv/pdfs/vp/07_vp_furniture.pdf
31. ASTM. D5116-06, Standard Guide for Small Scale Environmental Chamber Determinations
   of Organic Emissions from Indoor Materials/Products, American Society for Testing and
   Materials, West Conshohocken, PA.
32. ASTM, D6670-01 (2001) Standard Practice for Full-Scale Chamber Determination of
   Volatile Organic Emissions from Indoor Materials/Products, American Society for Testing
   and Materials, West Conshohocken, PA.
33. ASTM, 2003. D6196-03, Standard Practice for Selection of Sorbents, Sampling,  and Thermal
   Desorption Analysis Procedures for Volatile Organic Compounds in Air, American Society
   for Testing and Materials, West Conshohocken, PA.

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34. EPA. Compendium of Methods for Determination of Toxic Organic Compounds in Ambient
   Air, EPA report 600/4-89/017.  This report is available to the public through the National
   Technical Information Service, Springfield, VA 22161; PB90-116989.  This contains EPA
   TO-1, EPA TO-11 and EPA TO-17. Two supplements to this document are available on the
   EPA Web site at http://www.epa.gov/clhtml/pubtitie.html.
35. ASTM, 2003. D5197-03 Standard Test Method for Determination of Formaldehyde and
   Other Carbonyl Compounds in Air (Active Sampler Methodology), West Conshohocken,
   PA.

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RTI Operating Procedures Referenced in the Test/QA Plan

ML SOP #001   Standard Operating Procedure for Media Preparation - Dehydrated
ML SOP #002  Standard Operating Procedure for the Preparation of Sterile Water
ML SOP #003   Standard Operating Procedure for the Preparation of Sterile Buffer
ML SOP #005   Standard Operating Procedure for the Characterization of Relative Humidity
               Chamber
ML SOP #007  Standard Operating Procedure for the Gravimetric Determination of Moisture
               Content
ML SOP #009  Standard Operating Procedure for the Quantitative Evaluation of
               Microorganisms
ML SOP #012  Standard Operating Procedure for the Quantitation of Viable Spores in
               Suspension Preparation
ML SOP #013   Standard Operating Procedure for Pipet Calibration
ML SOP #017  Standard Operating Procedure for the Decontamination of Humidity Chambers
ML SOP #019  Standard Operating Procedure for Maintenance and  Record Keeping of
               Laboratory Equipment
ML SOP #023   Standard Operating Procedure for Regular Disinfection of Laboratory Surfaces
ML SOP #058   Standard Operating Procedure for Direct Inoculation of Materials with a Spore
               Suspension

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Appendix A Moisture Testing

Impact of Moisture on Building Materials
It is well  established that molds can colonize and amplify on a variety of building materials if
sufficient nutrients and moisture are present. Commonly, sufficient nutrients are available and
water is usually the growth factor most limiting the establishment and growth of microbial
populations. Sufficient moisture for growth may become available through water incursion from
leaks and spills, condensation on cold surfaces, or ab- or adsorption directly from the indoor air.
The amount of water required is not large, and materials that appear dry to cursory inspection
may be capable of supporting microorganism growth.  Because moisture is so important,
knowing  the amount of available moisture in a material is critical to preventing and controlling
microbial growth and amplification on materials.

Performance of Moisture Testing
Moisture testing will also be performed following the guidelines outlined in ASTM 6329. Two
types of measurements are commonly used to evaluate building material moisture: most
engineers think in terms of moisture content (MC) and many microbiologists utilize water
activity (aw).  MC, defined as mass of water per unit mass of dry material, is measured
gravimetrically (West and Hansen26; Foarde27 et al.). It is a bulk measurement of the water in  a
sample of the material.  The aw, primarily used to relate the water content of foods to the ability
of microorganisms to grow on them, is defined as the equilibrium RH (ERH) above a sample of a
material,  divided by 100 (Pitt28).

In the test described in this document, the ERH is the RH in a closed chamber containing a
material sample after the material and the air in the chamber have reached water equilibrium.
Therefore, the aw of the material that has been equilibrated in a closed chamber having an RH  of
94% is 0.94. Corry29 stated that aw is the proportion of "available water for biological reactions."
It is a useful laboratory measurement when RH conditions are known to be at equilibrium.

For porous materials, MC and ERH (or aw) are related through the material's water adsorption
isotherm, and different relationships are obtained for different materials.  In this test, the MC for
each test  material will be determined at four ERHs, 100%, 94%, 85% and 62%.  There is no need
to test lower ERHs as microbial growth cannot occur below ~ 60% ERH.

For microbial growth, the aw or ERH is the important number as it indicates how much water is
available for growth. The MC will be  determined for each test material, but will be reported only
as a reference value.  This reference value will provide two pieces of information. First, the
actual MC at the time of the test. This may be useful if other sample  are tested at a later date for
comparison purposes. Additionally, while  the microbial resistance testing will be performed with
the test material at ERH, in buildings, the RH of a space and the materials in the space are not  at
equilibrium. Therefore, another measure such as MC would be important.

Test Design for Moisture Testing
In addition to ASTM D6329, ML SOP #007 (Standard Operating Procedure for the Gravimetric
Determination of Moisture Content) will be followed. The details are described  below.

Replicate small (at least 4 cm x 4 cm) pieces of the test material will be used. Pieces will be

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placed on sterile dishes on the shelves in the static chamber.  Equilibration time will depend
upon both the material to be tested and the chamber relative humidity selected for the test and
will be determined for each material prior to testing.  Equilibration will be defined as when the
bulk moisture content of the material reaches a constant value. A calibrated analytical balance
will be used.

At least 5 chambers will be used. One each will be set at 100%, 94%, 85% and 62% ERH. The
fifth chamber will contain  a desiccant for a near 0% RH baseline comparison.

Data Analysis for Moisture Testing
Analysis will be performed as defined in ASTM D6329, Section  8.3.2.

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Appendix B. Emissions Testing

Impact of Emissions of VOCs and Aldehydes from Building Materials
Volatile organic compounds (VOCs) and aldehydes are of a concern for indoor air quality
because of adverse health effects. Many items in buildings may emit VOCs and aldehydes,
including  paints and lacquers, paint strippers, cleaning supplies, pesticides, building materials
and furnishings, office equipment such as copiers and printers, correction fluids and carbonless
copy paper, graphics and craft materials including glues and adhesives, permanent markers, and
photographic solutions. Manufacturers of these items have been working since the early 1990s
(or earlier) to reduce emissions from their products. EPA has sponsored research and testing on
low emission products. Under an earlier project, RTI developed a test method for measuring
VOC and aldehyde emissions from commercial furniture30.

This test plan includes measurement of emissions of aldehydes and VOCs from building
materials under conditions designed to simulate product use.  Formaldehyde and total volatile
organic compounds (TVOC) can be measured in addition to a range of other individual
aldehydes and individual VOCs. Emissions levels are determined by placing a piece of the
building material into a small environmental test chamber under specified test conditions, then
measuring chamber air concentrations of aldehydes and VOCs at selected time intervals.
Product-specific emission factors are calculated from the chamber air measurements.  The
method provides a standard test that reproducibly and accurately measures emissions from
building material under controlled laboratory conditions.

Chemical testing of VOCs and aldehydes will be performed by RTI.

One of the provisions of the ETV program is the use of existing data. VOC and aldehyde testing
of building materials is fairly common and there are a number of programs which perform VOC
testing. If a test material has been previous tested by an organization using the ASTM method
and the test results are publically available on the internet, RTI will evaluate the appropriateness
of using the existing data rather than retesting. If after discussion with the EPA project officer, he
is in agreement, the existing data will be used.

Performance of Emissions Testing
The emissions testing and analysis will be performed following the guidance of ASTM D5116-
0631, "Standard Guide for Small  Scale Environmental Chamber Determinations of Organic
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Emissions from Indoor Materials/Products"; ASTM, D6670-01  . A sample is placed into an
environmental chamber. Measurements are taken over time for VOCs and aldehydes. Gas
chromatography/mass spectrometry (GC/MS) is used to determine the quantity of VOCs and
reverse-phase high-performance liquid chromatography (HPLC) with ultraviolet (UV) detection
is used for aldehydes.

Test Design for Emissions Testing
The testing will be performed following the guidance of ASTM D5116-0631, Emissions levels
are determined by placing the test objects into an  environmental test chamber under specified test
conditions then measuring chamber air concentrations of aldehydes and VOCs at selected time
intervals. Product-specific emission factors are calculated from the chamber air measurements.

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Research Triangle Institute                                                     August 28, 2008
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Mold-Resistant Building Material Testing                                                Page 24

Aldehydes in chamber air samples are collected on silica gel cartridges coated with
2,4-dinitrophenylhydrazine (DNPH). The DNPH-aldehyde derivatives on the cartridges are
eluted with acetonitrile, and the eluate is analyzed using high performance liquid
chromatography (HPLC) with ultraviolet (UV) detection.

VOCs in chamber air samples are collected on sorbent cartridges (tubes). VOCs trapped on the
cartridges are thermally desorbed then analyzed by gas chromatography/mass spectrometry
(GC/MS).  Results of these analyses will be reported as mg/m3 (or (j, g/m3) and may be used to
estimate concentrations in chamber air samples.

Sampling will be performed following the guidance of ASTM D5116-0631,  Each sample will be
accompanied by a chain of custody form that documents all sample handling, transfer, and
storage prior to emissions testing.

Analysis for Emissions Testing
Chemical analysis for VOCs will be performed using GC/MS. The collected sorbent tubes will
subjected to thermal desorption using a Perkin Elmer ATD Turbomatrix system  interfaced to an
Agilent 6890 Plus GC and an Agilent 5973N MS.

Total VOCs (TVOC) will be calculated as the sum of those VOCs that elute between the
retention times of n-hexane and n-hexadecane on a non-polar or equivalent  capillary GC column
and quantified based on the response factor for toluene.  For individual VOCs, the analytical
methods are based on ASTM D6196-0333, "Standard Practice for Selection  of Sorbents,
Sampling, and Thermal Desorption Analysis Procedures for Volatile Organic Compounds in
Air", EPA methods T01734, "Determination of Volatile Organic Compounds in Ambient Air
Using Active Sampling onto Sorbent Tubes" and TO-134, "Determination of Volatile Organic
Compounds in Ambient Air Using Tenax Adsorption and Gas Chromatography/Mass
Spectrometry".

The analytical methods for formaldehyde, and other low molecular weight aldehydes are based
on ASTM D5197-0335, Standard Test Method for Determination of Formaldehyde and Other
Carbonyl Compounds in Air (Active Sampler Methodology)".

Data analysis will be performed as defined in ASTM D5116-0631.

Quality Assurance and Control for Emissions Testing
QC requirements for emissions testing will be consistent with ASTM D5116-0632, and include
the following:
    1.  Air change:     LOACH+/-5.0%
   2.  Mixing:       +/-5.0%
   3.  Air Tightness: <0.03 ACH
   4.  Recovery*:    100%+/-20%
       *recovery is based on average recoveries from Toluene, Decane, and Formaldehyde.

All RTI staff are trained and knowledgeable for the work they perform; training files are
maintained for each staff member. Calibrations for chemical analysis instruments are obtained
using multi-point calibration curves prepared using pure compounds; a minimum of four points

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Research Triangle Institute                                                        August 28, 2008
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Mold-Resistant Building Material Testing                                                  Page 25

shall be used.  For those VOCs determined by GC/MS, target analytes are introduced onto
sorbent tubes as gas or liquid standards and then analyzed using methods identical to those used
for analysis of chamber samples. A calibration check standard is prepared and analyzed daily, at
a minimum, to verify that calibration for each analyte is in control.  Corrective action will be
taken as needed to ensure quantitation accuracies.

Carbonyls analyzed by HPLC will be quantified based on a multipoint calibration curve prepared
using dinotrophenyl hydrazone derivatives of the pure target analytes. Standards and unknown
are analyzed using the same analytical conditions. A QC check standard will be analyzed every
10 injections to ensure accuracy. Re-calibration will be performed as needed.

All VOC data will be reviewed for accuracy (correctness) and reasonableness.

The emissions test results will be reported as mg/m3 (or (j, g/m3) TVOC and VOCs by species,
unless all parties (EPA, RTI and vendor) have agreed that only TVOC shall be reported.

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