EPA/600/R-13/217 | October 2013 | www.epa.gov/ord
United States
Environmental Protection
Agency
             Determination of the Efficacy
             of Spore Removal from Carpets
             using Commercially-available
             Wet/Vacuum Carpet Cleaning
             Systems

             Assessment and Evaluation
             Report
Office of Research and Development
National Homeland Security Research Center

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                                           EPA600-R-13-217
                                           October 2013
Determination of the Efficacy of Spore Removal
  from Carpets using Commercially-available
     Wet/Vacuum Carpet Cleaning Systems
        Assessment and Evaluation Report
         National Homeland Security Research Center
            Office of Research and Development
            U.S. Environmental Protection Agency
             Research Triangle Park, NC 27711

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Disclaimer
The United States Environmental Protection Agency, through its Office of Research and Development's
National Homeland Security Research Center, funded  and managed this investigation through EP-C-04-
023 with ARCADIS U.S., Inc. This report has been peer and administratively reviewed and has been
approved for publication as an Environmental Protection Agency document. It does not necessarily reflect
the views of the Environmental Protection Agency. No  official endorsement should be inferred. This report
includes photographs of commercially available products.  The photographs are included for purposes of
illustration only and are not intended to imply that EPA approves or endorses the product or its
manufacturer. Environmental Protection Agency does not  endorse the purchase or sale of any
commercial products or services.
Questions concerning this document or its application should be addressed to:

Shawn P. Ryan, Ph.D.
National Homeland Security Research Center
Office of Research and Development (E-343-06)
U.S. Environmental Protection Agency
109 T.W.Alexander Dr.
Research Triangle Park, NC 27711
(919)541-0699
ryan.shawn@epa.gov

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Acknowledgments

The authors would like to acknowledge the support of Alion Science and Technology, funded under
contract with EPA (EP-D-10-070) concerning statistical analysis of the core samples.

The contributions of the EPA peer reviewers listed below are also acknowledged:

M. Worth Calfee
Robert Vanderpool
Jason Weinstein
                                            IV

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Table of Contents
Disclaimer	iii
Acknowledgments	iv
Table of Contents	v
List of Figures	vii
List of Tables	vii
List of Appendices	viii
List of Acronyms and Abbreviations	ix
List of Units	x
Executive Summary	xi
1   Project Description and Objectives	1
  1.1    Purpose 	1
  1.2    Process	1
  1.3    Project Objectives	2
2   Experimental Approach	3
  2.1    General Approach	3
    2.1.1    Control Chamber (COMMANDER)	5
    2.1.2    Material Surfaces	5
    2.1.3    Chamber Setups	7
    2.1.4    Material Sterilization	9
    2.1.5    Spore Preparation	9
    2.1.6    Controlled Contamination Procedure	10
    2.1.7    Contamination  Characterization	11
    2.1.8    Decontamination Procedure	11
    2.1.9    Final Sterilization	13
  2.2    Test Matrix	13
  2.3    Sampling Strategy	15
  2.4    Sampling/Monitoring Points	16
  2.5    Frequency of Sampling/Monitoring Events	18
  2.6    Decontamination Event Sequence	18
3   Testing and Measurement Protocols	19
  3.1    Methods	19
                                             v

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    3.1.1    Surface Sampling	19
      3.1.1.1     Wipe Sampling	19
      3.1.1.2     HEPA Vacuum Sampling	21
    3.1.2    Core Sampling	24
    3.1.3    Swab Sampling	25
    3.1.4    Rinsate Collection and Sampling Procedures	26
  3.2   Prevention of Cross-contamination of Sampling/Monitoring Equipment	26
    3.2.1    Preventing Cross-Contamination during Execution of the Decontamination Process	27
    3.2.2    Preventing Cross-Contamination during Sampling	28
    3.2.3    Preventing Cross-Contamination during Analysis	29
  3.3   Representativeness	29
  3.4   Sample Quantities	29
  3.5   Sample Containers for Collection, Transport, and Storage	29
  3.6   Sample Identification	30
  3.7   Sample Preservation	30
  3.8   Sample Holding Times	31
  3.9   Sample Handling and Custody	31
  3.10        Sample Archiving	32
4   Testing and Measurement Protocols	33
  4.1 Sample Analyses	33
    4.1.1    Recovery from HEPA Vacuum Sample	33
    4.1.2    Filter Plating	34
    4.1.3    Recovery of Core Samples	35
  4.2   Analysis Equipment Calibration	35
5   Quality Assurance	36
  5.1    Data Quality	36
  5.2   Quality Assurance/Quality Control Checks	36
  5.3   Data Quality Objectives	37
  5.4   Audits	37
6   Results and Discussion	38
  6.1    Data Reduction and Validation	38
  6.2   Test Results	39
                                             VI

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    6.2.1    Length of Decontamination Event	46
    6.2.2    Physical  Impact on Materials and Crew	46
    6.2.3    Fate of Spores	46
    6.2.4    Health and Safety Effects of Decontamination	46
References	47


List of Figures
Figure 2-1.   Conceptual Flowchart for a Test	4
Figure 2-2.   Carpet Coupon	6
Figure 2-3.   Template for Creating 1' x 1' Carpet Areas	7
Figure 2-4.   Carpet Setup in COMMANDER during Inoculation	8
Figure 2-5.   Carpet Setup in COMMANDER during Decontamination	9
Figure 2-6.   Diffusion Shield	10
Figure 2-7.   Century 400 Ninja Carpet Cleaner	11
Figure 2-8.   Judson Labs O2 Pre-Spray and Rinse System	12
Figure 2-9.   Decontaminating Carpet B with Spor-Klenz Using the Carpet Extractor	13
Figure 2-10.  Carpet Section Template and Sample Grid	17
Figure 3-1.   HEPA Sock Sampling a Coupon Section for Viable Spores	22
Figure 6-1.   Wipe Sampling Results for Test A	39
Figure 6-2.   HEPA Sock Sampling Results for Test B	40
Figure 6-3.   HEPA Sampling Results after Decontamination Attempts	41
Figure 6-4.   Core Sampling Results after Decontamination Attempts	42
Figure 6-5.   Spor-Klenz Applied to a New Carpet with a Backpack Ssprayer	43
Figure 6-6.   Spor-Klenz Applied to a New Carpet with an Unheated Vacuum Cleaner	43

List of Tables
Table 2-1.   Test Matrix	14
Table 3-1.  Cleaning Methods and Frequency for Common Test Materials/Equipment	27
Table 3-2. Sample Quantities for Each Test Setup	30
Table 4-1. Instrument Calibration Frequency	35
                                             VII

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Table 5-1.  Quality Control Checks	36
Table 5-2.  DQIs for Critical Measurements	37
Table 5-3.  Acceptance Criteria for Critical Measurements	37
Table 6-1.  Spor-Klenz Applied with a Carpet Cleaner*	44
Table 6-2.  Spor-Klenz Applied with a Backpack Sprayer*	44
Table 6-3. Log reduction	45
List of Appendices
Appendix A    Piping and Instrumentation Diagram of COMMANDER
Appendix B    MSDS for Decontamination Solutions
Appendix C    Miscellaneous Operating Procedure (MOP) 6535a
                                            VIM

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List of Acronyms and Abbreviations
APPCD
ATCC
B.
CPU
CM
COC
COMMANDER
CT
DCMD
DQI(s)
DQO(s)
EPA
HEPA
H202
IDLH
INL
ISO
LOD
MOP
NOT
NHSRC
NIST
ORLS
OPP
ORD
OSWER
PBST
PPE
PVC
QA
QC
Air Pollution Prevention and Control Division
American Type Culture Collection
Bacillus
Colony Forming Unit(s)
Critical measurement(s)
Chain of Custody
Consequence ManageMent ANd Decontamination Evaluation Room
Concentration * time
Decontamination and Consequence Management Division
Data Quality Indicator(s)
Data Quality Objective(s)
U.S. Environmental Protection Agency
High Efficiency Particulate Air
Hydrogen peroxide
Immediately Dangerous to Life and Health
Idaho National Laboratory
International Organization for Standardization
Limit(s) of detection
Miscellaneous Operating  Procedure
National Decontamination Team
National Homeland Security Research Center
National Institute for Standards and Technology
On-site Research Laboratory Support
Office of Pesticide Programs
Office of Research and Development
Office of Solid Waste and Emergency Response
Phosphate buffered saline with 0.05% TWEEN®-20
Personal protective equipment
Polyvinyl chloride
Quality Assurance
Quality Control
                                            IX

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QAPP
RSD
RTP
TRIO
ISA
VHP®
VOC
Quality Assurance Project Plan
Relative Standard Deviation
Research Triangle Park
Task Force on Research to Inform and Optimize
Tryptic Soy Agar
Vaporous hydrogen peroxide
Volatile Organic Compound
List of Units
in
ft
ft2
mg/L
ml
ppm
rpm
Inch/Inches
Foot/Feet
Square feet
Milligrams per Liter
Milliliter
Part(s) per Million
Revolutions per Minute

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Executive Summary

This project supports the U.S. Environmental Protection Agency's (EPA) Homeland Security Research
Program (HSRP) to improve the capability to respond to terrorist attacks affecting buildings and the
outdoor environments. Given the impact that a few letters containing anthrax spores had on the U.S.
Postal Service system in 2001, critical public facilities contaminated following a wide area release could
quickly consume the Nation's entire remediation capacity, requiring years to clean up and resulting in
enormous economic impacts. Additional quick, effective and economical decontamination methods
having the capacity to be employed over wide areas (outdoor and indoor) are required to increase
preparedness.

Although some of the facilities in which these letters were processed or received in 2001 were heavily
contaminated, they were successfully remediated with approaches such as fumigation with chlorine
dioxide or vaporous hydrogen peroxide. In addition, other cleaning methods were used in secondarily
contaminated areas or primarily contaminated facilities  showing a minimal presence of anthrax spores.
These methods included combinations of  disposal of contaminated  items, vacuuming, and the use of
liquid sporicides such as a pH-adjusted bleach solution. Additionally, a combined set of mechanical and
chemical procedures (vacuum, scrub/wash and bleach) was used successfully in the decontamination of
a small shed contaminated with anthrax spores originating from animal hides during a drum-making
process.1 If proven effective, any approach involving washing and cleaning with readily available
equipment would significantly increase EPA's readiness to respond to a wide area release.

This project investigated the decontamination of carpet surfaces contaminated with Bacillus spores  (i.e.,
surrogates of 8. anthracis). Two types of wet/vacuum carpet cleaning  systems - unheated (cold) and
steam/heated (hot) - were tested for efficacy. In addition, the sporicide Spor-Klenz® Ready to use (Spor-
Klenz) (STERIS, Mentor, OH) was  used in a carpet cleaner instead of the typical surfactant. This
apparatus was compared to application of Spor-Klenz with a backpack sprayer. The goal was to provide
information to support the development, use, and/or statement of limitations of these lower-tech
decontamination procedures for surfaces.

This work measured the reduction in viable spores on and within the carpet surfaces (effectiveness) as a
function of the cleaning technique and duration  applied to both new and used carpet. The size of the
carpet sections, roughly 4' x 4', was chosen as feasible yet representative of what will likely be
encountered in the field (e.g., walkways).  Operational parameters such as time, physical impacts on
materials or the remediation crew, and the fate of the viable spores (e.g.,  contamination of equipment
carpet cleaner parts, rinsate) were  also determined.

The major finding of this research is that spores are very difficult to recover from carpet once the carpet
has been wetted. The study suggests that carpet cleaners alone are not effective in completely removing
spores (to a non-detectable amount). Carpet cleaners may be effective if used in  concert with sporicides
to decontaminate a carpet. Neither the High-Efficiency Particulate Air (HEPA) sock sampling nor wipe
sampling seemed capable of recovering spores from a wetted carpet,  even after the carpet had dried.
This problem  may have been compounded for used carpet, possibly due to the higher amounts of surface
area from dirt, debris, and worn fibers. Extractive techniques were deemed more  reliable, but the
methods developed for this study need refinement to improve detection limit and recovery.
                                              XI

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Test A - Wipe Samples

The first test was conducted with both the hot and cold vacuum cleaners on new carpet, using the
manufacturer-recommended pre-spray and extraction solutions, and four sequential decontaminations.
Wipe samples taken after the first decontamination seemed to suggest that both vacuum cleaners had
removed 99.99% of the spores.

Use of the wet carpet cleaners was not expected to kill the spores but to decontaminate by removing the
spores. In this way, the spores could  be considered a material, rather than an organism, and a
rudimentary type of mass balance could be applied to them. Insufficient spray was used, however, to
actually effect such a dramatic log reduction for such a porous material and led to the consideration that
the spores had been pushed down within the carpet pile and inaccessible to the wipe sampling.

Test B - HEPA Samples

For Test B, conducted on old carpet,  HEPA sock sampling was used  instead of wipe sampling. The
HEPA sock results suggested that a significant log reduction could be obtained using either the heated or
unheated carpet cleaners. However,  based on the ineffectiveness of the wipe samples, the data could
also suggest that the HEPA socks were no more effective than the wipe sample had been at recovering
spores from a wetted carpet.

Test C - HEPA and Core (Extractive) Samples

Results from Tests A and B left questions regarding the effectiveness of the decontamination process
based upon uncertainty in the sampling methods. Test C was designed  to answer this question by
altering the carpet construction  method to allow for the collection of the core (extractive) samples in
addition to the HEPA sock samples. This test was conducted on new carpet.

Each sample area was first sampled  using HEPA socks, and extractive  analysis was performed on a
small 18 mm diameter core taken from the center of the same sample area. These data show that while
HEPA sock sampling suggested that the decontamination methods were removing some amount of
spores, subsequent extractive samples showed no or minimal removal.  The HEPA sock samples of
control areas (not decontaminated) showed minimal downward drift.

The act of decontaminating with the wet/dry vacuums seems to push  the spores away from the surface
and into the carpet pile, where the HEPA socks are unable to sample effectively. Even though the
samples were allowed to dry overnight, residual moisture or detergent may have helped spores adhere to
carpet fibers. The apparent log reduction from the HEPA sock samples from Test B showed a greater log
reduction than the HEPA sock samples from Test C. The tamped down  nature of the older, used carpet,
as well as the debris in the fibers, may further reduce recovery by binding to the spores or merely
retaining moisture.

Although the results from Tests A and B were inconclusive as to the efficiency of the carpet cleaners,  all
three tests suggested that there was  no statistical difference between the hot (heated) and cold
(unheated) cleaners. Test C indicated that the efficacy of the carpet cleaners per the manufacturer's
recommendations was poor. Extractive sampling for carpet using core samples appears to be the only
reliable sampling method following any dampening of the surface.

                                             xii

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Test D - Spor-Klenz in Cold Vacuum versus Backpack Sprayer

A final test (Test D), using new carpet, was conducted to provide information about the benefits of using a
carpet cleaner with Spor-Klenz in place of the recommended cleaner versus the application of the
sporicide without any vacuuming.

Test D showed a very good log  reduction from the use of Spor-Klenz, applied either from the carpet
cleaner or the backpack sprayer. The first decontamination showed a 6 log reduction using the HEPA
socks (no detection on the core samples, which have a higher detection limit than the HEPA sock
samples).  Following the second application of Spor-Klenz, no spores were detected using either
sampling method,  showing at least a 7 log reduction in the HEPA sock results.

Due to the quantity of spores in  the small size of the core samples, the core samples could only show a
greater than 3 log  reduction. The core samples taken for the controlled contamination had lower recovery
than expected, possibly due to the rigorous method that was used to extract the core samples causing re-
aerosolization of many spores and the high detection limit induced  by the small size of the core samples.

The length of the decontamination event was very short using the carpet cleaners (approximately 5
seconds per square foot). Test D with Spor-Klenz suggested that performing the decontamination twice
may yield no recoverable spores.  If these decontaminations are performed immediately (back-to-back),
then there is minimum impact on the remediation crew. If, on the other hand, the carpet is allowed to dry
between successive applications,  then an extra day is involved. Though it was not a consideration for this
test, the ultimate disposal of the carpet cleaners after use in an event may contribute to the cleanup time
and expense.

The backpack sprayer method as  performed does require an  extended duration, allowing for treatment of
an extrapolated 192 square feet in 30 minutes, or 6.4 square feet per minute, significantly longer per
square foot than when a carpet  cleaner is used.

No physical impact on the carpet was noted for any of the decontamination methods. While neither was
physically strenuous, any activity inside Level C suits (even with cooling vests) leads to heat stress.
Moreover, the use of Spor-Klenz in an area without very  high  air exchanges could lead to levels of
hydrogen peroxide or acetic acid above IDLH (Immediately Dangerous to  Life and Health) conditions.

Determining the ultimate fate of spores has proven very complicated due to sampling difficulties. The
rinsate recovered from the carpet  cleaners used in Tests A, B, and  C was very contaminated with
organisms of unknown origin, obscuring enumeration of the spores of interest, suggesting that the
likelihood our target organism was in the rinsate was very high. The data suggest that only a fraction of
the  spores were removed from the carpet during Tests A, B, and C, so any spores not removed may be
viable,  and viable spores may be present in carpet, carpet cleaner parts, and rinsate. The spores in  Test
D may all be inactivated due to the presence of Spor-Klenz in all locations, but some doubt lingers due to
difficulties of sampling the rinsate.
                                              XIII

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1      Project Description and Objectives

This project supports the mission of U.S. Environmental Protection Agency's (EPA) Homeland Security
Research Program (HSRP) by providing relevant information pertinent to the decontamination of
contaminated areas resulting from an act of terrorism.

A significant gap in preparedness is in the ability to effectively respond to a wide area release of a
biological agent such as 8. anthracis spores (the causative agent of anthrax and often referred to as
such, or anthrax spores). Such a release could potentially result in the contamination of a vast number of
personal residences, businesses, public facilities (e.g., hospitals), and outdoor areas. In 2001, the
introduction of a few letters containing anthrax spores into the U.S. Postal Service system resulted in the
contamination of several facilities. Although some of the facilities in which these letters were processed or
received in 2001 were  heavily contaminated, they were successfully remediated with approaches such as
fumigation with chlorine dioxide or vaporous hydrogen peroxide. However, it is believed that critical public
facilities contaminated  following a wide  area release would quickly consume the Nation's entire
remediation capacity, requiring years to clean up and resulting in enormous economic impacts.
Additional quick, effective and economical decontamination methods having the capacity to be employed
over wide areas (outdoor and indoor) are required to increase preparedness for such a release.

Fumigation has primarily been used in heavily contaminated facilities, while other cleaning methods have
been used in secondarily contaminated areas or primarily contaminated facilities showing a minimal
presence of anthrax spores. These methods included combinations of disposal of contaminated items,
vacuuming, and the use of liquid sporicides such as a pH-adjusted bleach solution. Additionally, a
combined set of mechanical and chemical procedures (vacuum, scrub/wash and bleach) was used
successfully in the decontamination of a small shed contaminated with anthrax spores originating from
animal hides during a drum-making  process.1 If proven effective, any  approach involving washing and
cleaning with  readily available equipment would significantly increase EPA's readiness to respond to  a
wide area release. Data to quantify the  effectiveness of such decontamination techniques are not
available.

1.1   Process
The general process being investigated in this project is the decontamination of carpet surfaces
contaminated with Bacillus spores (i.e.,  surrogates of 8. anthracis). Decontamination can be defined as
the process of inactivating or reducing a contaminant in or on  humans, animals, plants, food, water, soil,
air, areas, or items through physical, chemical, or other methods to meet a cleanup goal. In terms of the
surface of a material, decontamination can be accomplished by physical removal of the contamination or
via inactivation of the contaminant with  antimicrobial chemicals, heat,  UV light, etc. Physical removal
could be accomplished via in situ removal of the contamination from the material or physical removal of
the material itself (i.e.,  disposal). Similarly,  inactivation of the contaminant can  be conducted in situ or
after removal  of the material for ultimate disposal.

During the decontamination activities following the results of the 2001 anthrax incidents, a combination of
removal and in situ decontamination was used. The balance between the two was facility-dependent  and
factored in many issues (e.g., physical state of the facility). One factor was that such remediation was
unprecedented for the  United States Government,  and no technologies had been proven for such use at
the time. The  cost of disposal proved to be very significant and was complicated by the nature of the

                                               1

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waste (e.g., finding an ultimate disposal site). Since 2001, a primary focus for facility remediation has
been on improving the effectiveness and practical application of in situ decontamination methods and
evaluating waste treatment options to be able to provide information necessary to optimize the
decontamination/disposal paradigm. This optimization has a very significant impact on reducing the cost
of and time for the remediation effort.

In this research, the basis for the specific decontamination procedure is the use of wet/vacuum carpet
cleaning systems. Two types of carpet cleaning systems - unheated (cold) and steam/heated (hot) -
were tested for efficacy.  Completion of the test matrix was expected to provide information to support the
development, use, and/or statement of limitations of this lower-tech decontamination procedure for
surfaces that can achieve a target cleanup goal while minimizing hazardous waste and the spread of
contamination.

1.2   Project Objectives
This work measured the reduction in viable spores on and within the carpet surfaces (effectiveness)  as a
function of the cleaning technique and duration of application to various carpet types. The size of the
carpet sections, roughly 4' x 4', was chosen as feasible yet representative of what will  likely be
encountered in the field (e.g., walkways). Operational parameters such as time, physical impacts on
materials or the remediation crew, and fate of the viable spores (e.g., contamination of equipment, wash
water, filters) were also determined.

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2    Experimental Approach

This section documents the general approach, test conditions, test equipment, and the methods that were
used to evaluate the data related to the project objectives.

2.1   General Approach

The general approaches to meet the objectives of this project were:

    1.  Use of controlled chambers, standardized sections and spore inoculums;

    2.  Contamination of large sections of materials via aerosol deposition of bacterial spores;

    3.  Quantitative assessment of spore contamination by sampling representative sections of carpet
       sections before decontamination;

    4.  Application of a prescribed decontamination procedure to the test sections;

    5.  Quantitative assessment of residual contamination by sampling test sections;

    6.  Quantitative and qualitative analysis of decontamination procedure residues (e.g., waste water,);

    7.  Determination of decontamination effectiveness (comparison of results from positive control
       samples and test sections); and

    8.  Documentation of operational considerations (e.g., cross-contamination, procedural time, impacts
       on materials and personnel).

Testing was conducted in the consequence ManageMent ANd Decontamination Evaluation Room
(COMMANDER) located in H130-A of EPA's Research Triangle Park, NC, facility. For the purposes of
this project, effectiveness of a procedure was measured by generating a quantitative estimate of log
reduction of viable spores  on a surface - a 6 log reduction would be considered very successful.
However, factors such  as spread of viable spores  due to the decontamination procedure itself and
recovery were factored into the overall measure of effectiveness. Additionally,  procedures showing less
than a 6 log reduction may be deemed effective depending upon the circumstantial need (e.g., treatment
of scant contamination or repeated treatment of hot spots). Thus, while a log reduction value was
reported and may be termed effective, the effectiveness related to use of this procedure is less tangible
without the context of the need.

The general test approach is depicted graphically  in the flow chart shown in Figure 2-1. The following
sections provide details on the approach used to complete the testing.

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                 Material
                 Sample
               Fabrication
               and Set-up
           Decon
         Equipment
         Sterilization
  Material Sample
   and Chamber
    Sterilization
                                                           Blank
                                                        Sampling to
                                                          Confirm
                                                        Sterilization
                              Decontamination
                              Procedure (wet
                               vacuuming or
                              backpack spray
                                application)
                           Controlled
                         Contamination
                            (control)
                           Sampling
Sampling to
  Confirm
Sterilization
Test Area
Sampling


                                              Decontamination Procedure
                                              (wet vacuuming or backpack
                                                  spray application)
                                                                           Chamber Purge
                                                                           and clean up (2
                                                                               days)
         Controlled
       Contamination
          (2 hours)
                                    Decon
                                  Equipment
                                 Sterilization
Sampling to
  Confirm
Sterilization
    Have
enough Decon
attempts been
   made?
                                                                            Chamber and
                                                                               Sample
                                                                           Sterilization and
                                                                             Disassembly
Figure 2-1.   Conceptual Flowchart for a Test

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2.1.1  Control Chamber (COMMANDER)
All testing was done in the COMMANDER, an enclosed single-access-point chamber (henceforth, may
also be referred to as the chamber). COMMANDER meets the following criteria:

    1.  Supports repeated fabrication of an environment (e.g., furnished office room; outdoor setting)
       contained within the chamber;

   2.  Allows for release of biological organisms or chemicals into the chamber;

   3.  Allows for application of a decontamination technology (including fumigation with toxic corrosive
       gases);

   4.  Supports entry into the chamber during all of the above mentioned activities (in appropriate
       personal protective equipment or PPE);

   5.  External dimensions of 9 ft. x 12 ft. x 10 ft. high;

   6.  Contains one air-tight entry/exit port with a window;

   7.  Contains a 6 ft. x 6 ft. x 8 ft. high airlock with single entry/exit port with a window;

   8.  Contains entry/exit ports in  line with the enclosure double door to allow for large materials to be
       brought into or out of the chamber; and

   9.  Complies with all relevant local and national codes.

A piping and instrumentation diagram of COMMANDER is attached in Appendix A.

2.12  Material Surfaces
Carpet sections for both the new and "old" carpets were prepared using Sherwood carpet tiles with a
Shaw Contract Group Ecoworx® Backing System. These carpet sections were made of 100% nylon
woven on a 100% polyvinyl chloride (PVC)-free recyclable backing system with recycled content (made
from thermoplastic polyolefin compound with a reinforcing layer). The tiles were manufactured using a
multilevel loop construction.

Four individual 2 ft.  by 2 ft. carpet tiles were glued directly on a 4 ft. x 4 ft piece of 15/32 in. four-ply
plywood, mounted atop a 4 ft. by 4 ft. frame of commercial grade 2 ft. x 3 ft. lumber. A 1 in. x 4 in.  border
was then attached to the edge of the frame, creating a slight lip to the coupons. A photo of a carpet
coupon is shown in Figure 2-2.

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Figure 2-2.   Carpet Coupon
The used carpet tile came from EPA's Research Triangle Park facility, and was taken from the south
corridor adjacent to the elevator lobby of Building C, 6th Floor. The carpet had been in place for
approximately eight years.

The 4 ft. x 4 ft. carpet sections were then sectioned into sixteen 1 ft. x 1 ft. sample areas by using the
template shown in Figure 2-3. The template was positioned starting at a corner marked on the frame of
the carpet section. The resulting 1 ft. x 1 ft. areas were numbered 1 through 16. The only deviation from
this sample grid was for the first test, where an 8 x 8 grid of 6 in. squares was used. The change in
design for subsequent tests was made both to simplify the sampling process and to provide more
information about the homogeneity of the deposition.

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Figure 2-3.  Template for Creating 1' x 1' Carpet Areas
2.1.3  Chamber Setups
Each test consisted of two carpet sections of the same carpet type. During the inoculation phase, the
carpet coupons were centered as shown in Figure 2-4 to allow for a more uniform deposition of
aerosolized spores during the spore release.

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                             COMMANDER
                             chamber
                                   JtL
      Airlock
Figure 2-4.   Carpet Setup in COMMANDER during Inoculation
The carpet sections were shifted during the decontamination phase to allow a more natural range of
motion using the long vacuum cleaner hoses in the relatively small space within COMMANDER. The
setup during decontamination is shown in Figure 2-5.

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              COMMANDER
              chamber
      Airlock
Figure 2-5.   Carpet Setup in COMMANDER during Decontamination
2.1.4  Material Sterilization
After the sections were assembled inside COMMANDER, the carpets were sterilized using STERIS
vaporous hydrogen peroxide (VHP®). Hydrogen peroxide (H2O2) vapor concentration within the chamber
was monitored using an Analytical Technology Corp. (Collegeville, PA) H2O2 electrochemical sensor
(Model B12-34-6-1000-1) to provide  real-time concentration readings and control through a feedback
loop. A minimum concentration* time (CT) of 1000 parts per million (ppm)*hours was required for the
materials to be considered sterile. One test area of each carpet section was sampled (as described in
Section 3.1.1.1.2) to test sterility.  All  sterility checks were negative for growth.

2.1.5  Spore Preparation
The test organism for this work was a powdered spore preparation of 8. atrophaeus (American Type
Culture Collection [ATCC] 9732) and silicon dioxide particles. This bacterial species was formerly known
as 8. subtilis var niger and subsequently 8. globigii. The preparation was obtained from the U.S. Army
Dugway Proving Ground Life Science Division. The preparation procedure is reported in Brown et al.2
Briefly, after 80 - 90 percent sporulation, the suspension was centrifuged to generate a preparation of
approximately 20 percent solids. A preparation resulting in a  powdered matrix containing approximately

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1x10  viable spores per gram was prepared by dry blending and jet milling the dried spores with fumed
silica particles (Deguss, Frankfurt am Main, Germany). The nominal particulate size was 1 micron. The
estimated quantity of spores to be dispersed was approximately 2x1010 per event.

2.1.6  Controlled Contamination Procedure
The controlled contamination procedure was required to deliver a contamination of 1x106to 1x107
recoverable viable spores per square foot to the material samples. This was done by releasing 0.2 g of
the spore preparation using a TSI (Shoreview, MN) Model 3400A Fluidized Bed Aerosol Generator. The
Model 3400A Fluidized Bed Aerosol Generator was placed in the center of the COMMANDER exposure
chamber at a height of 4 feet. A perforated diffusion shield, as shown in Figure 2-6, was placed over the
fluidized bed. The shield was made of type 304 stainless steel with 0.25 in. holes and an open area of 58
percent.

Fans inside COMMANDER during the spore release created significant turbulence, forcing spores onto all
the surfaces. The real-time concentration of aerosols was monitored using a Dekati ELPI® (Tampere,
Finland)  Once the aerosol concentration began to subside (indicating that most spores had been
released), the fans were turned  off (to prevent the turbulence from beginning to remove the spores). The
chamber was aerated until no aerosol was detected inside the chamber (typically approximately two
hours).Spores were then cleaned from all surfaces except the carpet coupons.

For the first three tests, the walls, floors, and ceiling of COMMANDER were  decontaminated using pH-
amended bleach to reduce chances of cross-contamination. For the fourth test, this method was  not
available to use, so the walls, floors, and ceiling were decontaminated with Dispatch® (Caltech Industries,
Inc., Midland, Ml) wipes.
    2ft.
              _"_"_" _" J _"_"_"_"_"
              J J J J w _"_"_"_"_"
              J J J If J J J J J
              J J J JV JJJJJJJJJ
              j j j j* j^j j j j j j j
             j j j j jj^j-fs-3-j j j
             «j j j j j j j*i~3Ts * * w
                    •2 ft. diameter
Figure 2-6.   Diffusion Shield
                                              10

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2.1.7  Contamination Characterization
The "control" areas (described in Section 2.4 and shown in Figure 2-5 in that section) were sampled (as
described in Section 3.1.1.1.2). These "control" areas were the basis for any log reduction as a result of
decontamination procedures. This characterization sampling took place on the same day as the
decontamination procedure was carried out.

2.1.8  Decontamination Procedure
For Tests A, B and C, two different Century 400 (Chandler, AZ) Ninja Carpet Extractors (Figure 2-7) were
used for the decontamination procedure, the notable difference being that one carpet cleaner used a
heated surfactant (Century 400 Ninja 150 PSI, 411-22AHMO) while the other did not include a heater
(Century 400 Ninja 150 PSI, 411-22AMO). The same pre-treatment and surfactant (Judson Labs
[Greenville, S.C.] O2 Pre-Spray and Rinse System) were used for both carpet cleaners (Figure 2-8). Both
cleaners include a 12 in. dual jet head wand. The pretreatment was applied for a target time of 20
seconds at  approximately 660 mL/minute before use of the carpet cleaner. The surfactant was placed in
the carpet cleaner reservoir and allowed to heat up (if the heater was present). The surfactant is sprayed
from the wand when the operator opens a trigger valve on the wand. During the decontamination
procedure, the wand was placed in the left corner closest to the operator and the surfactant was applied
along the full length of the carpet. The surfactant was then extracted by pulling the wand back in a
straight line using a single stroke left to right across the entire coupon.  This pattern was repeated at a 90
degree angle to the first pass. Completion of the second pass was considered the end of a procedure.
Figure 2-7.   Century 400 Ninja Carpet Cleaner

For Test D, Coupon A was saturated with Spor-Klenz from a backpack sprayer, back and forth across the
carpet with 50 percent overlap on each pass. Spor-Klenz was reapplied in this manner at 20 and 40
minutes from initial application.
                                              11

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The carpet extractor was used to decontaminate Coupon B (see Figure 2-7). During the first
decontamination, the wand was placed in the center of the coupon on one side. The operator sprayed the
Spor-Klenz RTU solution (Steris Corporation, St. Louis, MO) while moving the wand toward the opposite
end of the coupon. The wand was then pulled back toward the operator, extracting the Spor-Klenz from
the carpet left to right across the top half of the coupon. The procedure was then repeated across the
bottom half of the coupon, with an overlap on the top half of approximately 10 percent.
                      Figure 2-8.  Judson Labs O2 Pre-Spray and Rinse System

For Test D, Coupon A was saturated with Spor-Klenz from the backpack sprayer (ShurFlo 4 ProPack
Rechargable Electric Backpack Sprayer, SHURFLO, LLC., Elkhart, Indiana) back and forth across the
carpet with 50 percent overlap on each pass. Spor-Klenz was reapplied in this manner at 20 and 40
minutes from initial application.

The carpet extractor was used to decontaminate Coupon B (see Figure 2-9). During the first
decontamination, the wand was  placed in the center of the coupon on one side. The operator sprayed the
Spor-Klenz RTU solution while moving the wand toward the opposite end of the coupon. The wand was
then pulled back toward the operator, extracting the Spor-Klenz from the carpet left to right across the top
half of the coupon. The procedure was then repeated across the bottom half of the coupon, with an
overlap on the top half of approximately 10 percent.
                                              12

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Figure 2-9.   Decontaminating Carpet B with Spor-Klenz using the Carpet Extractor

The second decontamination with the carpet extractor was slightly different.  Due to the awkward nature
of the first decontamination (the COMMANDER was too narrow to pull the wand to the edge of the carpet
hence decontamination was performed in halves), the carpet was placed against the wall opposite the
operator to allow for more room. The wand was placed in the  left corner closest to the operator and Spor-
Klenz was applied along the full length of the carpet. The Spor-Klenz was extracted by pulling the wand
back in a straight line using a single stroke left to right across  the entire coupon.

2.1.9  Final Sterilization
Once all decontamination procedures had been completed (up to four repeat cleanings or until the
decontamination procedure was deemed successful), the material sections and COMMANDER were
sterilized again with VHP®. After this final sterilization, the material sections were discarded.

2.2   Test Matrix
To fulfill the project purpose (Section 1.1) and meet the objectives  (Section 1.3), the test matrix shown in
Table 2-1 was developed. In the presentation of results (Section 6), the reasoning behind the change in
surface sampling methods is discussed.
                                              13

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Table 2-1.  Test Matrix
Test
A
B
C
D
Carpet Type
New
Old
New
New
Protocol
Hot vs. cold carpet cleaners
Hot vs. cold carpet cleaners
Hot vs. cold carpet cleaners
Backpack sprayer vs. cold
carpet cleaner
Carpet Cleaner Liquid
Judson Laboratories
Oxygen 2 Pre-Spray and
Extraction
Judson Laboratories
Oxygen 2 Pre-Spray and
Extraction
Judson Laboratories
Oxygen 2 Pre-Spray and
Extraction
Spor-Klenz
Sampling Techniques
Wipe Samples
HEPA sock samples
HEPA sock samples and
core samples
HEPA sock samples and
core samples
The decontamination procedure was repeated (up to four times) on materials to determine the number of
cleanings necessary to remove the spores as completely as possible. These tests were performed
according to the following parameters:

    1.  Each test was run independently.

    2.  A single test included the completion of all carpet cleaner types within that setup.

    3.  A material section blank was taken from each carpet section.

    4.  Following controlled contamination and decontamination, samples were collected for the test
       sections of each material type.

    5.  Cleaning of COMMANDER and all equipment used during testing was performed as described in
       Section 2.1.9 after the completion of each test.

    6.  Each 4 ft. x 4 ft. carpet section required three positive control samples and three test samples of
       each carpet section for each of the consecutive decontamination procedures (up to four), as well
       as vacuum liquid samples from the decontamination step for each carpet section. Hence, if four
       consecutive decontamination procedures were conducted, a total of 16 vacuum samples was
       generated for each carpet section (one vacuum sample for each 1 ft. x 1 ft. area). The exception
       to this procedure was Test 1, using wipe sampling, which had six samples instead of three at
       each sampling time.

    7.  The general testing sequence was shown in Figure 2-1. The following steps describe the testing
       sequence:

           a.  All material sections needed for this project were prefabricated before any testing was
              begun.

           b.  All spores for the study were prepared,  per the method discussed in Section 2.1.5, prior
              to the initiation of any testing.
                                              14

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           c.   The material sections were installed in COMMANDER and sterilized using VHP®.

           d.   All material sections for a given test were contaminated in accordance with Section 2.1.6.

           e.   After air purging, personnel wearing appropriate PPE entered the COMMANDER. Initial
               cleaning of the walls to reduce chances of cross-contamination was conducted.

           f.   All materials and equipment necessary for the decontamination procedure were gathered
               and prepared as documented in Section 2.1.8.

           g.   Sampling of each test area was done  according to Section 3.1.1.

           h.   Decontamination according to Section 2.1.8 was completed on one material section. All
               decontamination steps were completed before moving on to the next material.

           i.   After all decontamination was complete, samples were recovered from the wet/dry
               vacuums in  accordance with  Sections 3.1.2.

           j.   After a minimum of 18 hours  and when all coupon surfaces were visibly dry, surface
               sampling was done in accordance with Section 3.1.1.

           k.   Decontamination procedures were repeated up to four times, followed each time by
               sampling.

           I.   Sample analysis was performed as described in Section 4.1. Data reduction and
               validation were conducted as described in Section 6.1.
2.3   Sampling Strategy
The objective of the study was to assess the effectiveness of a decontamination procedure to
decontaminate the surfaces. The effectiveness was measured by the determination of the log reduction
calculated per Section 6.1. Hence, surface sampling of the test areas before and after decontamination
was required to determine the log reduction after application of the procedure. Because current surface
sampling techniques are intrusive, they will also remove viable spores from the surface of the section.
Sampling of positive control areas was required to compare to post-decontamination sampling of test
sections for this study. Positive controls and test areas are subsections of the carpet section. Positive
control areas were sampled in accordance with Section 4, before the decontamination procedure. The
entire carpet section, including test areas, is carried through the decontamination procedure, allowed to
dry, and subsequently sampled in accordance with Section 4.

The effectiveness of removing contamination from the surface of the sections provides critical information
regarding the potential of the  procedure; however, field applicability is also dependent upon several other
factors including the ultimate disposition (or fate) of the spores. This latter information is required to
provide information pertinent to the development of a comprehensive site-specific remediation strategy.
For example,  if viable spores  are washed off materials, remediation field strategies might require rinsate
                                              15

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collection and treatment. Hence, it is important to understand the fate of the spores resulting from the
application of the decontamination procedure on the section surface.

To obtain the additional critical information on the fate of the spores, several samples in addition to the
surface sampling of the sections was collected. To assess the potential for viable spores to be washed off
the surfaces, all liquids used in the decontamination process were collected and quantitatively analyzed
as a composite sample for the entire decontamination procedure on a particular carpet section.
Quantitative analysis was done on these rinsate samples to provide for an order of magnitude
determination of the disposition of viable spores in this media.

There are currently no  validated methods for sampling biological agents from porous materials. Hence,
results from past field practices1 and recent studies2"5were used to define the surface sampling strategy.
For rough and/or porous surfaces, HEPA vacuum sampling is the preferred method.36 Limits of detection
(LOD) and sensitivities determined from the comparison of wipes on nonporous surfaces and the HEPA
vacuum on nonporous  and porous surfaces indicate that HEPA vacuuming has a comparable LOD (400-
600 colony forming units [CPU] per sample area) to wipe sampling and an order of magnitude greater
sensitivity.2 Of the literature reviewed, however, only one reference provided a direct comparison between
HEPA vacuuming and wipe sampling for a porous surface (carpet).5 While wipe sampling had a higher
collection efficiency, the level of detection was  lower for the HEPA vacuuming.
2.4   Sampling/Monitoring Points
The front face of each carpet section was the only surface of the sections that was sampled in this study.
Two 4 ft. x 4 ft. sampling templates of welded stainless steel wire were made for each carpet section, one
for before decontamination and one for post-decontamination sampling. The template, with 16 areas of 1
square foot, is shown in Figure 2-10. This template was placed against the material during the sampling
events. The only deviation from this sample grid was for the first test, where an 8 x 8 grid of 6 in. squares
was used. Six areas were sampled, rather than the three replicates described here. The change in
design simplified the sampling process and provided more information about the homogeneity of the
deposition.
                                              16

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Figure 2-10.  Carpet Section Template and Sample Grid
One area was sampled as a blank after sterilization. This area was "randomly" selected based on the last
digit of the date the blank sample was taken. A small indelible mark was placed on the sample area to
mark it as the starting point for the subsequent samples. As an example, blank sample testing on April
28th would indicate a blank sample taken from area 8. This area has been highlighted yellow in Figure
2-10.

After the controlled contamination, three areas were sampled as controls, i.e., indicative of spore counts
before decontamination. Starting from the blank sample area, every fifth area was designated as one of
these controls. In our example, this would mean that areas 13,  2, and 7 would be control sample areas
(highlighted red in Figure 2-10). A small mark in indelible  ink was made on each area of the material
surface after sampling.

After decontamination, three more areas were sampled. The decontaminated samples were taken from
areas with preceding numbers to the control areas. In our example, these would be Areas 12, 1, and 6
(highlighted green in Figure 2-10). A small mark in indelible ink was made on each of these areas of the
material surface after sampling.

The decontamination procedure was repeated  up to three more times, with successive rounds of
sampling being conducted on  the sampling areas with preceding numbers to the first post-
decontamination sampling areas. In our scenario  of blank testing starting on June 28th, areas 11, 16 and 5
would be sampled following the second round of decontamination; areas 10, 15, and 4 after the third
round  of decontamination; and areas 9, 14, and 3 after the fourth and final round  of decontamination. No
area was sampled twice.

                                             17

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The liquid in each carpet cleaner recovery tank was analyzed independently. The COMMANDER
chamber was cleaned as detailed in Section 2.1.9 after the final sampling round.

2.5   Frequency of Sampling/Monitoring Events
Three surface samples of each carpet section were collected before decontamination (control samples)
and three samples after each of the following decontaminations (up to four) and the appropriate drying
time post-decontamination. The liquid collected by the cleaners from the carpet surfaces was filtered and
labeled appropriately (see Section 3.6) after the conclusion of decontamination of each carpet section.

2.6   Decontamination Event Sequence
For Tests A, B and C, the pre-spray and the solution used in the hot and cold vacuums were those
recommended by the manufacturer (Judson Laboratories Oxygen 2/Pre-Spray and Oxygen 2/Extraction,
respectively). The STERIS Spor-Klenz used in Test D was  ready-to-use as provided by the manufacturer.
Material Safety Data Sheets (MSDS) for each decontamination solution are included in Appendix B.
                                            18

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3   Testing and Measurement Protocols

Several types of samples were included in this project. Surface sampling procedures were used to collect
samples from the coupon materials. These samples included wipe samples as well as HEPA socks. Core
(punch or hole saw) samples were taken for spore enumeration via extractive analysis. In addition, swab
sampling was done for each sterilization batch for all equipment used during decontamination (vacuum
nozzles, etc), as well as to identify spores captured in the any filter associated with the wet vacuum
cleaners used during the decontamination. The rinsate generated during the decontamination procedure
was collected for each material type. Details of the sampling procedures are provided below. A laboratory
notebook was used to document the details of each sampling event (or test).

3.1   Methods
3.1.1  Surface Sampling
Prior to the sampling event, all materials needed for sampling were prepared. The materials specific to
each protocol are included in the relevant sections below. In addition, general sampling supplies were
also needed.  A sampling material bin was stocked for each sampling event, using the information
included in Section 3.4 (Table 3-2). The bin contained enough sampling kits to accommodate all required
samples for the specific test. Additional kits of each type were also included for back-up. Sufficient
prepared packages of gloves and bleach wipes were also included in the bin. A sample collection bin was
used to transport samples back to the Microbiology Laboratory. The exterior of the transport  container
was decontaminated by wiping all surfaces with a bleach wipe ortowelette moistened with a  solution of
pH-adjusted  bleach prior to transport from the sampling location to the Microbiology Laboratory.

 3.1.1.1  Wipe Sampling
Wipe sampling is typically used for small sample areas and is effective on nonporous smooth surfaces
such as ceramics, vinyl, metals, painted surfaces, and plastics.7 The general approach is that a
moistened sterile non-cotton pad is used to wipe a specified area to recover bacteria, viruses, and
biological toxins.7 The protocol that was used  in this project is described below and has been adapted
from that provided by Busher et al.7 and Brown et al.8, and documented  in the INL 2008 Evaluation
Protocols.9 None of these references provides a validated wipe procedure for Bacillus spores, as a
validated sampling  procedure does not currently exist.

The following procedure was used in this study for wipe sampling of each coupon surface:

1.  A two-person team was used, employing aseptic technique throughout. The team consisted of a
   sampler and a support person.

2.  All materials needed for collection of each sample were prepared in advance using aseptic technique.
   A sample kit for a single wipe sample was prepared as follows:

       a.   Two sterile sampling bags 10 in. x 15 in. (Fisherband Twirl'Em Sterile Sampling  Bags, item
           14-955-196, Pittsburg, PA) 5.5 in. x9 in. (Fisherbrand Sterile Sampling Bags, item 14-955-
           185, Pittsburgh, PA) and a 50 mL conical tube (Becton Dickson Labware, item 352098,
           Franklin Lakes, NJ), capped, were labeled. These bags and conical tube had the same label.
           The 5.5 in. x 9 in. labeled sterile sampling bag was referred to as the sample collection  sterile
           sampling bag.

                                             19

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       b.  A dry sterile wipe was placed in an unlabeled sterile 50 ml conical tube using sterile forceps
           and aseptic technique. The wipe was moistened by adding 5 ml of sterile phosphate buffered
           saline with 0.05% TWEEN®-20 (item P-3563, SIGMA, St. Louis, M.O., USA). The tube was
           then sealed.

       c.  The labeled 50 ml conical tube, capped, the unlabeled conical tube containing the pre-
           moistened wipe, and the 5.5 in. x9 in. labeled sampling bag were placed into the 10 in. x 15
           in. labeled sterile sampling bag. Hence, each labeled sterile sampling bag contained a
           labeled 50 ml conical tube (capped), an unlabeled capped conical tube containing a pre-
           moistened wipe, and an empty labeled sterile sampling bag.

       d.  Each prepared bag was one sampling kit.

3.   The sampler and support person placed the template onto the coupon surface.

4.   Each member of the sampling team donned a pair of sampling gloves (a new pair per sample); the
    sampler's gloves were sterile sampling gloves. All members wore N95 dust masks to further minimize
    potential contamination of the samples.

5.   The support person removed a sample kit from the sampling bin and confirmed sample ID to sampler.

6.   The support person:

       a.  Opened the outer sterile sampling bag touching the outside of the bag.

       b.  Touching  only the outside of the outer bag, maneuvered the unlabelled conical tube  until it
           was at the opening of the bag. The sampler then grabbed the tube, removed it from the bag,
           opened the tube, and poured the pre-moistened wipe into the glove of the sampler.

       c.  Discarded the unlabelled conical tube.

       d.  Maneuvered the labeled 50 ml conical tube to the end of the outer sterile sampling bag and
           loosen the cap.

       e.  Removed the cap from 50 ml conical tube immediately preceding the introduction of the
           sample into the tube.

7.   The sampler:

       a.  Squeezed out excess moisture from the wipe before approaching sample area.

       b.  Confirmed the area ID of the carpet to sample.

       c.  Wiped the surface of the sample horizontally using S-strokes to cover the entire sample area
           of the coupon  using a consistent amount of pressure.

       d.  Folded the wipe  concealing the exposed side and then wiped the same surface vertically
           using the  same technique.

                                             20

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       e.  Folded the wipe over again and rolled the folded wipe to fit into the conical tube.

       f.   Carefully placed the wipe into the 50 ml conical tube that the support person was holding
           being careful not to touch the surface of the 50 ml conical tube or plastic sterile sampling
           bag.

8.   The support person immediately closed and tightened the cap to the 50 ml conical tube and slid the
    tube back into the sample collection sterile sampling bag.

9.   The support person then put the 50 ml conical tube into the empty labeled 5.5 in.  x 9 in. sampling
    bag and sealed the bag.

10. The support person then sealed the outer sample collection bag containing the capped 50 ml conical
    tube (containing the sample wipe) inside a sealed 5.5 in. x 9 in. sample collection bag.

11. The support person then decontaminated the outer sample bag  by wiping it with a Dispatch® bleach
    wipe.

12. The support person then placed the triple-contained sample into the sample collection bin.

13. All members of the sampling team removed and discarded their gloves.

14. Steps 3-13 were repeated for each sample collected.

 3.1.1.2  HEPA Vacuum Sampling
HEPA vacuum sampling is typically used for large porous areas. The general approach is that a collection
sock is used to trap dust material. The protocol that was used in this project is depicted below and has
been adapted from that provided by Busher et al.2 and Brown et al.3 and documented in the  INL 2008
Evaluation Protocols9. None of these references provides a validated HEPA vacuuming procedure for
Bacillus spores, as a validated sampling procedure does not currently exist.

The following procedure, shown in Figure 3-1, was used in this study  for HEPA vacuum sampling the
surfaces of each area of carpet section or blank coupon:

1.   A two person team was used. The team  consisted of a sampler and a support person.

2.   All materials needed for each sample to be collected were prepared in advance. A sample kit for a
    single HEPA vacuum sample was prepared as follows:

    a.  Two sterile sampling bags were labeled in accordance with Section 3.6. These bags had  the
       same label. An additional unlabeled bag was utilized.
                                             21

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Figure 3-1.   HEPASock Sampling a Coupon Section for Viable Spores

    b.  A HEPA sock assembly was placed into one of the unlabeled sterile sampling bags.

    c.  The bag containing the HEPA sock assembly was placed into a labeled sterile sampling bag; the
       second unlabeled bag was also placed into the labeled bag. The label was clearly distinguishable
       through the unlabeled bag.

    d.  Each prepared bag was one sampling kit.

3.   The sampler and support person placed the template onto the coupon surface.

4.   Each  member of the sampling team donned a pair of sampling gloves (a new pair per sample).

5.   The sampler plugged in the HEPA vacuum power cord and then donned his/her gloves.

6.   The sampler placed the HEPA vacuum onto a convenient surface and held the vacuum nozzle for the
    support person to place the HEPA vacuum sock assembly onto the nozzle.

7.   The support person opened the sampling supply bin and removed one HEPA vacuum sock sample kit
    from the bin.

8.   The support person recorded the sample collection bag number on the sampling log sheet or
    laboratory notebook.

9.   The support person recorded the coupon code on the  sampling log sheet or laboratory notebook next
    to the corresponding sample collection bag number that was just recorded.

                                            22

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10. The support person:

       a.   Opened the outer sampling bag containing the HEPA vacuum sock assembly.

       b.   Opened the bag within the outer sterile sampling bag and pushed the HEPA vacuum sock
           assembly from the bottom to expose the cardboard applicator tube opening.

       c.   Placed the  HEPA vacuum sock assembly onto the nozzle of the vacuum tube, using the inner
           sampling bag to handle the HEPA sock assembly, while the sampler held the vacuum nozzle.

11. The sampler:

       a.   Turned on the vacuum.

       b.   Vacuumed  "horizontally" using S-strokes to cover the 1.0 sq. ft. sample area of the template,
           while keeping the vacuum nozzle perpendicular to the sample surface.

       c.   Vacuumed  the same area "vertically" using the same technique.

       d.   Turned off the vacuum when sampling was completed.

12. The support person opened the labeled sterile sampling bag and removed the HEPA sock assembly
    from the nozzle by sliding the sampling bag over the HEPA sock assembly and gripping the sock from
    the outside of the bag.

13. The support person then  sealed the inner sterile sampling bag and  placed it into the outer sterile
    sampling bag.

14. The support person then  sealed the outer sterile sampling bag and  wiped the  outer bag with a bleach
    wipe.

15. The support person then  placed the outer sample bag into the remaining labeled sterile sampling bag
    and disposed of the bleach wipe.

16. The sampler wiped the nozzle (inside and out) and ends of the tubing with bleach wipe, then
    disposed of the bleach wipe.

17. The support person then  placed the triple-contained sample into the sample collection bin.

18. If sampling from the carpet section was completed, the sample handler marked the tested areas as
    having been sampled and moved the template to the  appropriate location for decontamination.

19. All members of the  sampling team removed and discarded their gloves.

20. Steps 3-19 were repeated for each sample to be collected.

A sterilized stainless steel nozzle was used between the HEPA sock and the vacuum hose. A separate
nozzle was  used for each carpet cleaning technique.
                                             23

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3.1.2  Core Sampling
The following procedure was used in this study for core sampling of each coupon surface. This procedure
involved a two-person team, referred to below as the sampler and the assistant. Punch sampling (utilizing
a punch and hammer) was employed for Tests C and D. Because of the difficulty in obtaining core
samples with this procedure, it was modified to use a hole saw.  The resulting minor modifications to this
procedure are shown in italics.

1.   Kit Assembly

       a.  PPE for non-HazMat situations was donned.

       b.  Sample IDs were determined.

       c.  A sterile 50 ml vortex tube (or 120 mL sample cup) was labeled with each sample ID.

       d.  An over pack bag was labeled with each sample ID.

       e.  The kits were assembled ahead of time. Each kit included a clean, sterile 50 ml tube (or
           cup), a small bag, and a pair of sterile tweezers, all packed into the larger bag.

2.   Sample Collection

This procedure followed HEPA Sock sampling.

    a.  The assistant donned clean gloves.

    b.  The assistant opened the over pack bag and maneuvered the tweezers from the outside of the
       over pack until the assistant could  grab the package.

    c.  The sampler recorded the time and the sample ID (and the size of the hole saw and the pilot bit).

    d.  The sampler donned sterile gloves.

    e.  The assistant opened the tweezers package so that the sampler could grab the sterile tweezers.

    f.   The assistant opened the bag holding the sterilized punch (or the bag holding the sterilized hole
       saw and attaches it to the drill using the outside of the autoclave bag to maintain sterility).

    g.  The assistant identified the sample or sample area as indicated by the sample ID on the over
       pack bag.

    h.  The assistant used the punch and  the hammer (or drill) to collect the extractive sample from the
       center of the carpet sampling area identified in the previous Step g. This often required repeated
       blows.

    i.   Once the carpet had been cut, the core sample typically was lodged inside the punch (or hole
       saw). The assistant held the punch such that the sampler could use the tweezers to grab the
       carpet piece (or the assistant used the Allen wrench to loosen the pilot bit. The sampler removed

                                              24

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       the bit. The sampler then used the tweezers to grab the carpet piece). If the carpet core did not
       lodge inside the punch (or hole saw), but remained on the carpet surface, the sampler used the
       tweezers to collect as much of the core as possible. While the sampler was holding the circle of
       carpet, the assistant maneuvered the 50 ml vial (or 120 mL sterile cup) from the outside of the
       over pack.

   j.    The assistant opened the vial (or cup), touching only the cap.

   k.  The sampler put the carpet into the vial (or cup).

   I.   The assistant aseptically returned the cap to the vial (or cup) and closed the vial (or cup).

   m. The assistant placed the vial (or cup) in the small inner bag and wiped the outside of the bag with
       a Dispatch® wipe.

   n.  The inner bag was placed inside the over pack bag, and was wiped with a Dispatch® wipe. (The
       assistant then removed the used hole saw from the drill and placed in a bag for eventual re-
       sterilization.)

3.1.3  Swab Sampling
Two types of swab samples were collected, though a similar procedure was used  for each. Swab
sampling was done for three items of each sterilization batch for all equipment used during
decontamination (vacuum nozzles, etc). The process for this sampling is described below.

 1. The sampler donned a P95 respirator, bouffant cap, gloves, disposable lab coat, and safety glasses

 2. The sampler:

   a.  Opened the package and removed the BactiSwab™ (Remel, item 12100/12110, Lenexa, KS).

   b.  Labeled the plastic tube appropriately using the scheme detailed in Section 3.6.

   c.  Removed the cap-swab from the plastic tube.

   d.  Swabbed the surface while spinning the cap-swab between the thumb and index fingers.

   e.  Returned cap-swab to tube.

   f.   Through the sleeve, crushed the BactiSwab™ Transport System ampoule at midpoint.

   g.  Held BactiSwab™ tip end to  allow the medium to wet the swab.

   h.  The sampler dated and initialed each sample tube.

3.  All BactiSwab™ Transport Systems were placed in a 5 in. x 9 in. sterile  sampling bag.
                                             25

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4.  A chain of custody form was completed and the samples relinquished to the Microbiology Laboratory.

This procedure was modified slightly for the final Test D.  Disposable booties were added to the PPE to
help prevent re-contamination of the COMMANDER during subsequent decontamination and sampling
events. Second, the BactiSwab™ ampoule was broken prior to taking the swab sample, as it was
determined that a moistened swab increased the collection efficiency. The process for this sampling is
described below.

1.  The sampler donned a P95 respirator, bouffant cap, gloves, disposable lab coat, disposable booties,
   and safety glasses

2.  The sampler:

    a.  Through the sleeve, crushed the BactiSwab™ Transport System ampoule at midpoint.

    b.  Held BactiSwab™ tip end up for at least five seconds to allow the medium to wet the swab.

    c.  Opened the package and removed the BactiSwab™.

    d.  Labeled the plastic tube appropriately  using the scheme detailed in Section 3.6.

    e.  Removed the cap-swab from the plastic tube.

    f.   Swabbed the surface while spinning the cap-swab between the thumb and index fingers.

    g.  Returned cap-swab to tube.

3.  All BactiSwab™ Transport Systems were placed in a 5 in. x 9 in. sterile sampling bag.

4.  A chain of custody form was completed and the samples relinquished to the Microbiology Laboratory.
3.1.4  Rinsate Collection and Sampling Procedures
The liquid collected by the carpet cleaners during the decontamination procedure was collected fora
given carpet section. After all steps of the decontamination process had been completed, aliquots of the
collected liquid in the cleaner were filtered immediately to remove the spores from the liquid according to
the protocol described in Section 4.1.2 below. The filtered spores were then rinsed with Dl water to
remove any residual surfactant.

3.2   Prevention  of Cross-contamination of Sampling/Monitoring  Equipment
Several management controls were put in place to prevent cross-contamination.  This project was labor
intensive and required that many activities be performed on carpet sections or coupons that were
intentionally contaminated (test coupons and positive controls).  The treatment of these two groups of test
areas (positive control and test) varied for each group.  Hence, specific procedures were put in place in
the effort to prevent cross-contamination among the groups. Adequate cleaning of all common materials
                                             26

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and equipment was critical in preventing cross-contamination. Cleaning methods for this purpose are
listed in Table 3-1.

There were four primary activities for each test in the experimental matrix.  These activities were
preparation of the coupons, execution of the decontamination process (including sample recovery),
sampling, and analysis. Coupons were fumigated with VHP® prior to the contamination process. Specific
management controls for each of the three following activities are described below.

3.2.1  Preventing Cross-Contamination during Execution of the Decontamination
       Process

The decontamination process was labor intensive; it required that a multistep procedure be executed
repeatedly for each coupon. Additionally, the process occurred using a single test chamber.  Hence,
controlling the order of processing and actions taken to minimize cross-contamination were essential.
The following management controls were followed in an effort to minimize the potential for cross-
contamination:
Table 3-1.   Cleaning Methods and Frequency for Common Test Materials/Equipment
Material/Equipment
COMMANDER
Wet vacuums
Heads of wet vacuums
Other Bulk equipment (fans,
templates, etc)
Use
Contain carpet sections during the
application of the decontamination
procedure being tested
Part of the decontamination
procedure
Part of the decontamination
procedure
Various
Cleaning Method
Fumigation with VHP® or washing
with pH-adjusted bleach solution in
accordance with the wet/dry vacuum
cleaning procedure.*
pH-adjusted bleach solution
pH-adjusted bleach solution
Fumigation with VHP or washing
with pH-adjusted bleach solution in
accordance with the wet/dry vacuum
cleaning procedure.*
   Following use in a test, the wet/dry vacuum (including head assembly) was cleaned by being fumigated with a
   STERIS VHP® sterilization cycle. This cycle entailed the use of a STERIS VHP® ARD H2O2 generator and
   exposure of all components of the wet/dry vacuum for a minimum concentration * time (CT) of 1000 ppm*hours.
                                              27

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•   COMMANDER was cleaned prior to the start of each test in Table 2-2 via fumigation with VHP .

•   COMMANDER was cleaned with a pH-adjusted bleach solution as described above following the
    controlled contamination procedure and before decontamination of the carpet sections began.

•   COMMANDER was cleaned after completion of each test in Table 2-2 via fumigation with VHP®.

•   All cleaner wands were decontaminated after use by soaking in a pH-adjusted bleach solution for at
    least one hour. Wands were put in the solution immediately after use to eliminate any accumulation
    of contaminated equipment in the test area. The bucket of pH-adjusted bleach solution for test
    equipment clean-up was clearly identified and maintained separate from the cleaning solutions being
    used for the test coupon decontamination process.

•   Testing was done using a "clean team/dirty team" technique. One dirty team was responsible for
    chamber wipe-down and moving the carpet sections into the decontamination shower. A clean team
    (with clean and dirty members) was used for control sampling. A dirty team performed the
    decontamination procedure. A clean team (with clean and dirty members) was used for test
    sampling. Only dirty members handled contaminated items and only clean members handled
    samples.

3.2.2  Preventing Cross-Contamination during Sampling
Sampling poses an additional significant opportunity for cross-contamination of samples. In an effort to
minimize the potential for cross-contamination, several management controls were implemented.

•   In accordance with aseptic technique, a sampling team made up of a "sampler" and a "support
    person" was utilized.

•   The sampler handled only the sampling media and the support person handled all other supplies.
    The sampler sampled the surface according to the appropriate procedure described in Section 3.1.1.

•   The collection medium  (e.g., HEPA filter) was then placed into a sample container that was opened,
    held and closed by the support person.

•   The sealed sample was handled only by the support person.

•   All of the following actions were performed only by the support person, using aseptic technique:

.1.1    The sealed bag with the sample was placed into another sterile plastic bag that was then sealed;
       that bag was then decontaminated using a bleach wipe.

.1.2    The double-bagged sample was then placed into a third sterile bag that was sealed and then
       placed into a sterile  sample container for transport.

.1.3    The exterior of the transport container was decontaminated by wiping all surfaces with a bleach
       wipe ortowelette moistened with a solution of pH-adjusted bleach prior to transport from the
       sampling location to the  Microbiology Laboratory.
                                             28

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•   The sampling crew then changed their gloves in preparation for working with the next sample.

3.2.3  Preventing Cross-Contamination during Analysis

Aseptic laboratory technique was followed per the standard operating procedures (SOPs) and
miscellaneous operating procedures (MOPs) of the Microbiology Laboratory. The SOPs and MOPs
document the aseptic technique employed to prevent cross-contamination. Additionally, the order of
analysis (consistent with the above) was as follows: (1) all blank coupons; and (2) all positive control or
decontaminated coupons.

3.3   Representativeness

The representativeness of the test material, decontamination procedure, and equipment used were
critical attributes to assure reliable test results. Representativeness of the test materials means that the
materials used are typical of such materials used in buildings in terms of quality, surface characteristics,
structural integrity, etc. The materials chosen for this study (carpet) are representative of surfaces that are
likely to contribute significantly to the overall decontamination challenge in the event of a wide area
release of 8. anthracis spores. The particular carpet chosen for this study is representative of modern low
Volatile Organic Compound  (VOC) carpets used in large government institutions; this carpet is being
used by US EPA in the RTP, NC facility. Representativeness was assured by selection of test materials
that met government procurement specifications and by obtaining those materials from appropriate
suppliers. The material coupons were fabricated to be representative of the bulk surfaces.  The size of
the carpet sections was chosen to be representative of a large surface area yet manageable within the
confines of COMMANDER. The sampling strategy for the 1  ft. x 1 ft. sample areas analyzed 18% of the
carpet section both before and after each decontamination. The equipment used in the decontamination
procedures was also representative of the equipment actually used in the field. The only minor exception
is that the equipment was chosen with a preference to allow for as much quality assurance as possible.
During analysis, samples were homogenized to ensure that any aliquots taken were representative of the
bulk titer (e.g., viable spores per ml).

3.4   Sample Quantities
For each carpet section, and assuming that four decontaminations were performed, a total of 29 samples
were generated.  The total numbers of samples of each type for each test are listed in Table 3-2. As
discussed in Section 3.3, the samples from each test were analyzed in six batches, represented by "Test
Day" in Table 3-2.

3.5   Sample Containers for Collection, Transport,  and Storage
For each wipe, the primary containment was an individual sterile 50 ml conical tube.  Secondary and
tertiary containment were sterile sampling bags.  The primary, secondary, and tertiary containment of
each HEPA vacuum  sock consisted of separate sterile sampling bags. All samples from a single test
were then placed in a sterilized plastic bin. Sterilization of all containers prior to their use for the test
samples was via autoclaving on a gravity cycle or via use of pH-adjusted bleach solution. After samples
were placed  in the container for storage and transport to the Microbiology Laboratory, the container was
wiped with a towelette saturated with a pH-adjusted bleach solution. A single plastic bin was used for
storage in the decontamination laboratory during sampling and for transport to the Microbiology
Laboratory.

                                              29

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Table 3-2. Sample Quantities for Each Test Setup
Test
Day
1
2
3
5
7
9
Description
Carpet Sterility
Sampling
Post-Controlled
Contamination
Control Sampling
Decontamination 1
Sampling
Decontamination 2
Sampling
Decontamination 3
Sampling
Decontamination 4
Sampling
Sterility
Blank
2





Control Samples

3 Samples x 2
Decontamination Types
(Test A- 6 samples)




Test Samples


3 Samples x 2
Decontamination Types
3 Samples x 2
Decontamination Types
3 Samples x 2
Decontamination Types
3 Samples x 2
Decontamination Types
Liquid Filter
samples


2
2
2
2
3.6   Sample Identification
Each carpet section was identified by a description of the material and a unique sample number. The
sampling team maintained an explicit laboratory log which included  records of each unique sample
number and its associated test number, contamination application, any preconditioning and treatment
specifics, and the date treated. Each carpet section test area sample was marked with only the material
descriptor and unique code number. The wet/dry vacuum samples  from each test were identified with an
associated test number and carpet section type. The sample codes eased written identification. Once
the coupons were transferred to the Microbiology Laboratory for plate counts, each sample was
additionally identified by replicate number and dilution.  The Microbiology Laboratory also included on
each plate the date it was placed in the incubator.
3.7   Sample Preservation
After sample collection, sample integrity was maintained by storage of samples in quadruple containers
(1 - sample collection container, 2 - sterile bag, 3 - sterile bag with exterior sterilized during sample
packaging process, 4 - sterile container holding all samples from a test). All individual sample containers
remained sealed while in the decontamination laboratory or in transport after the introduction of the
sample. The locking lid on the container holding all samples remained closed except for the brief period it
was opened for sample introduction by the support person of the sampling team. The sampling person
did not handle any samples after they were relinquished to the support person during placement into the
primary sample container.

In the Microbiology Laboratory, all samples were stored in the refrigerator at approx. 4 °C±2°C until they
were analyzed. All samples were allowed to stabilize at room temperature for 1  hour prior to analysis.
                                              30

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3.8   Sample Holding Times
After sample collection for a single test was complete, all samples were transported to the Microbiology
Laboratory immediately, with appropriate chain of custody form(s). The samples were stored in
accordance with Section 3.7 and no longer than ten days before they were analyzed. A typical holding
time for most samples was a maximum of two days.

3.9   Sample Handling and Custody
Careful coordination with the Microbiology Laboratory is required to arrange for successful transfer of
uncompromised samples in a timely manner for analysis.  Test schedules were confirmed with the
Microbiology Laboratory prior to the start of each test. To ensure the integrity of samples and to maintain
a timely and traceable transfer of samples, an established and proven chain of custody or possession is
mandatory. It is imperative that accurate records be maintained whenever samples are created,
transferred, stored, analyzed, or destroyed. The primary objective of these procedures is to create an
accurate written record that can be used to trace the possession of the sample from the moment of its
creation through the reporting of the results.  A sample is in custody if it is in any one of the following
states:

•   In actual physical possession.

•   In view, after being in physical possession.

•   In physical possession and locked up so that no one can tamper with it.

•   In a secured area, restricted except to authorized personnel.

•   In transit.

Laboratory test team members received copies of the test plans prior to each test.  Pre-study briefings
were held to apprise all participants of the objectives, test protocols, and chain of custody procedures to
be followed. These protocols were required to mesh with any protocols established by EPA.

In the transfer of custody, each custodian signed, recorded, and dated the transfer on the Chain  of
Custody (COC). Sample transfer could be on a sample-by-sample basis or on a bulk basis. The following
protocol was followed for all samples as they were collected and prepared for distribution:

•   A chain of custody record accompanied the samples. When turning over possession of samples, the
    transferor and recipient signed, dated, and  noted the time on the record sheet. This record sheet
    allowed transfer of custody of a group of samples from H130-A to the Microbiology Laboratory.

•   If the  custodian had not been assigned, the laboratory technician had the responsibility of packaging
    the samples for transport.

•   Samples were carefully packed and hand-carried between on-site laboratories.

•   The chain of custody  record showing the identity of the contents accompanied all packages.
                                              31

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3.10 Sample Archiving
All samples and diluted samples were archived for two weeks following completion of analysis. This time
allowed for all data to be processed according to quality control requirements and allowed for the data to
be reviewed. Samples were archived by maintaining the primary extract at 4 °C+/-2°C in a sealed
extraction tube. Two weeks post-analysis, all samples were discarded.
                                             32

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4   Testing and Measurement Protocols

The primary results from this study were from the analysis of samples in the Microbiology Laboratory,
resulting in recovered CPUs per sample expressed on a log-10 scale. This analysis for each sample type
is detailed in Section 4.1.

Additional measurements prior to or during the decontamination procedure application were also required
to ensure quality control in the testing.

The time for application of each procedural step and time between procedural steps on each coupon was
measured using a stopwatch (Table 3-1) and recorded in the laboratory notebook.

4.1 Sample Analyses

The Microbiology Laboratory analyzed all samples for presence (swab samples) or to quantify the number
of CPU per sample (wipe, vacuum, or core samples), which were used as per Section  6.1. For all sample
types, phosphate buffered saline with 0.05% TWEEN®-20 (PBST) were used as the extraction buffer.
After the appropriate extraction procedure (as described in the sections to follow), the buffer was
subjected to a four stage serial dilution (10° to 10~4) in accordance with MOP 6535a (a revision of MOP
6535 specifically for bacterial spores; attached as Appendix C). The resulting samples were plated in
triplicate and incubated overnight.  CPU were counted as detailed in MOP 6535a.

The PBST was prepared according to an internal MOP. The extraction procedure used to recover spores
will be varied depending upon  the different matrices (HEPA filter socks, wipe samples, core samples).
The procedures are described in the following subsections.

4.1.1   Recovery from HEPA  Vacuum Sample

The recovery of the spores from the HEPA socks was done as follows, as adopted from the Idaho
National Laboratory (INL) 2008 Evaluation Protocols:9

1.  The analyst donned a fresh pair of gloves. Gloves were changed periodically (at least between
   batches) or after direct contact with a sample to reduce contamination.

2.  Sterile 3 oz. specimen cups were pre-labeled as per the sample log corresponding to the batch of
   samples being processed.

3.  The 3 oz. specimen cup sample containers were loaded with 20 mL of PBST.

4.  Both sterile sample bags were opened without removing the inner bag from outer bag. The HEPA
   sock assembly was moved to the opening of the bag using the bag.

5.  The HEPA sock was removed from the assembly using sterile forceps while holding the cardboard
   applicator from the outside of the bag. The HEPA sock was placed into the corresponding pre-
   labeled specimen cup containing 20 mL PBST.  The plastic bag with cardboard applicator was
   discarded.  A new pair of sterile forceps was used for each sample.
                                             33

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6.   After use, forceps were placed in a container of pH-adjusted bleach solution. The forceps were
    soaked for at least one hour before being autoclaved using a gravity cycle in preparation for use with
    the next sample batch.

7.   The HEPA sock was wetted by holding the upper blue portion of the HEPA sock and dipping the
    lower 1 inch of the HEPA sock into the PBST. The HEPA sock was allowed to soak up the PBST for
    a few seconds.

8.   After the soaking, the HEPA sock was lifted up just above the opening of the specimen bottle. A 1-
    inch vertical slit was cut up the center from the bottom of the sock using sterile scissors. A new pair
    of scissors was used for each sample.

9.   The HEPA sock was cut horizontally from side to side about 1 inch from the bottom, allowing the two
    pieces to fall into the specimen bottle. The HEPA sock was only cut where the sock had been wetted
    (dip, wet, look, cut).

10. Steps 7-9 were repeated until the entire white portion of the  HEPA sock was cut.

11. The upper top blue portion of the HEPA sock was then discarded.

12. After use, scissors were placed in a container of pH-adjusted bleach solution. The scissors were
    soaked for at least one hour before being autoclaved using a gravity cycle in preparation for use with
    the next sample batch.

13. Gloves were changed  between samples.

14. Steps 4-12 were repeated for each sample in the batch.

15. Twelve samples at a time were loaded into the well plate of the incubator shaker (Lab-Line, Melrose
    Park, IL).

16. The samples were agitated in the shaker incubator at 300 revolutions per minute (rpm) for 30  minutes
    with the heat off.

17. The samples were then removed from the shaker incubator and brought to the BioSafety Cabinet
    (NuAire, Inc., Plymouth, MN) for dilution plating as described in Section 4.1.

4.1.2  Filter Plating

Filter plating was done by the Microbiology Laboratory for the Spor-Klenz tests as well as for the rinsate
samples. Three 100 mL aliquots of Spor-Klenz or rinsate were delivered to the Microbiology Laboratory.
One of the 100 mL aliquots was filtered by pouring through a 0.2 micron Nalgene filter unit (Thermo-
Scientific, Waltham, MA).  The filter was then rinsed  by pouring 10 mL of sterile deionized water over the
filter. The filter was removed from the filtration unit aseptically with disposable thumb forceps and placed
onto a Tryptic Soy Agar (TSA) plate, filter side up. The plate was then placed in a 35 °C+/-2°C incubator
(Thermo-Scientific, Waltham, MA), for at least 18 hours.  Filter plating was also done for any samples for
which there were fewer than 30 CFU in the primary dilution sample.
                                              34

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4.1.3  Recovery of Core Samples
The smaller core punches used in Test C were processed in 20 ml PBST tubes. They were sonicated for
10 minutes, vortexed for two continuous minutes, and then vortexed immediately prior to dilution plating
as described in Section 4.1. The larger hole saw cores used in Test D were processed in 40 ml PBST
specimen cups. The cups were placed in the orbital shaker incubator for 30 minutes at ambient
temperatures and were vortexed immediately prior to dilution plating as described in Section 4.1.

4.2   Analysis Equipment Calibration

Standard laboratory equipment such as biological safety cabinets and incubators were routinely
monitored for proper performance. All equipment was verified as being certified calibrated or having the
calibration validated by the Metrology Laboratory at the time of use. Calibration of instruments was done
at the frequency shown in Table 4-1. Any deficiencies were noted. The instrument was adjusted to meet
calibration tolerances and recalibrated within 24 hrs. If tolerances were not met after recalibration,
additional corrective action was taken, possibly including the replacement of the equipment.

Table 4-1. Instrument Calibration Frequency
Equipment
Thermometer
Micropipettes
Clock
Biological
Cabinet
Calibration/Certification
Compared to independent National Institute for Standards and Technology
(NIST) thermometer (this is a thermometer that is recertified annually by either
NIST or an International Organization for Standardization (ISO)-17025 facility)
value once per quarter.
All micropipettes were verified to be within the calibration date at time of use.
Pipettes were recalibrated by gravimetric evaluation of pipette performance to
manufacturer's specifications every year by supplier (Rainin Instruments,
Oakland, C.A., Ovation, VistaLabs, Brewster, NY).
Compared to office U.S. Time @ www.NIST.time.gov every 30 days.
The biological cabinets were verified to be within certification dates at the time of
use. Biological Cabinets are adjusted yearly to be within flow tolerances
established by the manufacturer.
Expected
Tolerance
±rc
±5%
±1 min/30
days

                                              35

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5   Quality Assurance
5.1   Data Quality
The objective of this study was to investigate the reduction in viable spores on and within the carpet
surfaces (effectiveness) as a function of the cleaning technique and duration of application to various
carpet types. This section discusses the Quality Assurance/Quality Control (QA/QC) checks (Section 6.2)
and Data Quality Objectives (DQOs; Section 6.3) considered critical to accomplishing the  project
objectives.

The QAPP10 in place for this testing was followed with several deviations, many of which were
documented in the text above. Deviations included incorporating  HEPA sock samples in place of the
inefficient wipe samples,  and the addition of the core (extractive)  samples and the use of Spor-Klenz.
These deviations did not  substantially affect data quality and were necessitated by the test results
themselves.

5.2   Quality Assurance/Quality Control  Checks
Quantitative standards do not exist for biological agents. Quantitative determinations of organisms in this
investigation did not involve the use of analytical measurement devices. Rather, the CPU were
enumerated manually and recorded. Critical QC checks are shown in Table 5-1, with acceptance criteria
set at the most stringent level that could routinely be achieved  and that were consistent with the DQOs.

Table 5-1. Quality Control Checks
QC Sample
Positive Control
(sample from carpet
section area contaminated
with biological agent but
not subjected to the test
conditions)
Blank ISA, Sterility Control
(plate incubated, but not
inoculated)
Stability Control
Information Provided
Initial contamination level
on the coupons; allows for
determination of log
reduction (see Section
5-1); controls for
confounds arising from
history impacting
bioactivity; controls for
special causes.
Controls for sterility of
plates.
Verifies that the spores are
stable for the length of time
required for multiple
decontamination cycles
Acceptance Criteria
Target loading of 1E7 CPU
per sample with a standard
deviation of
<0.5. (5E6-5E7
CPU/sample);
No observed growth
following incubation.
No downward trend over
time
Corrective Action
Outside target range:
discuss potential impact on
results with EPAWAM;
correct loading procedure
for next test and repeat
depending on decided
impact.
Incubate additional ten
plates. If any additional
growth is observed, reject
results from the lot.
Re-evaluate efficacy
results based on natural
decay.
The positive control samples did not meet acceptance criteria for Tests A and B, but were deemed high
enough to continue with the testing. Extractive samples did not meet the criteria because of their smaller
size.

All sterility control samples met the acceptance criteria.
                                              36

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The stability control samples did show a downward trend overtime, on the order of 0.5 log reduction. This
downward trend has not been factored  into the log reduction values.

5.3   Data Quality Objectives
The DQOs define the critical measurements (CMs) needed to address the stated objectives and specify
tolerable levels of potential error associated with simulating the prescribed decontamination
environments.  The following measurements were deemed to be critical to accomplish part or all of the
project objectives:
    •   time
    •   CPU counts.
The Data Quality Indicators (DQIs) listed in Table 5-2 are specific criteria used to quantify how well the
collected data meet the DQOs. Detection limits were defined by the QAPP as 50% of the minimum
number of detectable spores, or 0.5 CPU.

Table 5-2. DQIs for Critical Measurements
Measurement
Parameter
Counts of CPU
Streak Plate
Analysis Method
Visual counting,
See Section 4.1
Visual detection
of growth
Accuracy
±10% of
CPU count
N/A*
Detection
0.5 CPU
0.5 CPU
Completeness Goals
100%
100%
Actual Completeness
100%
100%
*N/A= not applicable

The quantitative acceptance criteria in terms of precision (%Relative Standard Deviation, %RSD) for each
critical measurement are shown in Table 5-3. Tests with conditions falling outside these criteria were
rejected and repeated. Decisions to accept or reject tests were based upon engineering judgment used
to assess the likely impact of the parameter on the conclusions drawn from the data.

Table 5-3. Acceptance Criteria for Critical Measurements
Measurement Parameter
Target Value
Precision RSD
Test coupon replicates
Negative control CPUs
30 - 300 CPU per
quantifiable plate
0-1 CPU per
sample area
40%
±0.5 CPU
5.4    Audits
This project was assigned QA Category III and did not require technical systems or performance
evaluation audits.
                                             37

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6   Results and Discussion

This work measured the reduction in viable spores on and within the carpet surfaces (effectiveness) as a
function of the cleaning technique (hot versus cold vacuum) and duration of application to various carpet
types (up to four subsequent decontaminations). The size of the carpet sections, roughly 4' x 4', was
chosen as feasible yet representative of what will likely be encountered in the field (e.g., walkways).
Operational parameters such as time, physical impact on materials or the remediation crew, and fate of
the viable spores (e.g., contamination of equipment, carpet cleaner parts, and rinsate) were also
determined. The data reduction and validation procedures used are presented in Section 6.1, followed in
Section 6.2 by the results for each of the tests from the test matrix (Table 2-2).

6.1   Data Reduction and Validation

Data reduction was performed to tabulate all results from each test.  The data reduction included the total
CPU recovered from each replicate sample area, the average recovered  CPU and standard deviation for
each group of sample areas, log reductions, and total recovered CPU for each wet vacuum liquid sample.
The coupons included the following, for each combination of material type and decontamination type:
    •   Positive control areas (three replicates, average, standard deviation)
    •   Test areas (three replicates, average, standard deviation)
CPU counts per coupon were calculated according to the equation shown in MOP 6535a (Appendix C).
Efficacy is defined as the extent (by log reduction) to which the agent extracted from the coupons after
the treatment with the decontamination procedure is reduced below that extracted from positive control
areas (not exposed to the decontamination procedure). Efficacy was calculated for each test coupon
within each combination of decontamination procedure (i) and test material as:

        //, = I>L°8(CFUc)/Nc-I,Lo8(CFUs)'Nt
             j                      k

where :

        ~  = the spore log reduction efficacy of decontamination technique i
                                    the mean log CPU recovered from the control areas (C= control,
                                    j = coupon number, and Nc is the number of coupons (1 , j))

                                    the mean log CPU recovered from the surface of a
                        )/7V(  =    decontaminated coupon (S= sample from decontaminated
                                    carpet, k = coupon number, and Nt is the number of coupons
                                    tested (1 , k))
When no viable spores were detected, then a value of 0.5 CPU was assigned as the detection limit, and
the efficacy was reported as greater than or equal to the value calculated by Eqn. 6-1.

For the recovered liquid samples, the results were reported as CPU per area cleaned.

                                             38

-------
At least 10% of the data generated during sample analysis from each test was reviewed. This review
occurred within one week after the analysis was completed. The review included an independent
verification of CPU per plate and the calculation of CPU per sample (per Equation 6-1).

6.2   Test Results

The first test (Test A) was conducted on new carpet using wipe samples. Use of the wet carpet cleaners
was not expected to kill the spores but to decontaminate  by removing the spores. In this way, the spores
could  be considered a material, rather than an organism, and a rudimentary type of mass balance could
be applied to them.

Figure 6-1  shows the wipe sampling recovery following spore inoculation (loading) and after each of the
four subsequent decontaminations. When wipe sampling was used to determine spore concentration for
Test A, the results failed to satisfy the mass balance.
   o
    S5
o-
4-
3-
2-
1-
n

4-
3-
2-
1-
n-






T
1




1 1 Heated Cleaner



T , 	 I 	 , T
1 1
i
i • i • i • i






	 1




I 	 | Unhetaed Cleaner



I
i T i
1 X 1
                    Carpet Decontamination Steps
Figure 6-1.   Wipe Sampling Results for Test A

The wipe results seemed to suggest that a single use of a carpet cleaner (whether heated or unheated)
removed 99.99% of the spores after the first decontamination. This observation would further suggest that
the recovery of the surfactant was also 99.99%, if the spores were carried away by the surfactant. This
value was beyond the anticipated (or believable) efficacy of the vacuum cleaner itself. For example, the
flow rate of the surfactant was 26.6 (±3%) mL/sec for the heated carpet cleaner and 39.8 (±0.5%) mL/sec
for the unheated carpet cleaner. The surfactant was applied for approximately 45 seconds. For the
unheated carpet cleaner, only 560 ml of the approximately 1200 ml was recovered, much below the
99.99% recovery suggested  by the spore results. This observation led to the consideration that the
spores were not inactivated or removed at all, but had been pushed down within the carpet pile and made
inaccessible to the wipes.
                                              39

-------
For Test B, conducted on old carpet, HEPA sock sampling was used instead of wipe sampling, and core
samples were also intended to be collected for extraction. Because core samples were a late addition to
the test plan, the carpet construction method (gluing the carpet down) was not designed to allow for the
collection of these samples. The core samples could not be collected for Test B.

Figure 6-2 shows the results after loading and three subsequent decontaminations. The HEPA sock
results suggested that a significant log reduction could be obtained with repetition of the decontamination
process using either the heated or unheated carpet cleaners. However, based on the ineffectiveness of
the wipe samples (and without the core samples for verification), the data would suggest that the HEPA
socks were no more effective than the wipe sample had been.
   o
K-
5-
4-
3-
2-
1-
Q
7-
6-
5-
4-
3-
2-
1-






	 Ł 	




1 1 Heated Cleaner





T
1







I
J_





I
1

1 ' 1 ' 1 ' 1





I






	 1 Unheated Cleaner |





I
1














T
                    Carpet Decontamination Steps
Figure 6-2.   HEPA Sock Sampling Results for Test B
Results from Tests A and B suggested that neither of the surface sampling methods - wipe sampling or
HEPA sock sampling - was sufficiently efficient at collecting spores once the wet/dry vacuuming
operation had been performed. Test C was designed to answer the question of spore recovery by altering
the carpet construction method to allow for the collection of the core (extractive) samples in addition to
the HEPA sock samples. This test was conducted on new carpet. Figure 6-3 shows the logarithm of the
CFU recovered per square foot following multiple decontamination attempts using the HEPA sock
samples.
                                              40

-------
   o
    D)
   3
7-
6-
5-
4-
3-
2-
1-
n '

7-
6-
5-
4-
3-
2-
1-
n '







|_[ 1 Heated vani n im
i
1



i • i • i • i






1 1 1 Unheated Vacuum
T T



1


                    Carpet Decontamination Steps
Figure 6-3.   HEPA Sampling Results after Decontamination Attempts

Each sample area was first sampled using HEPA socks, then extractive analysis was performed on a
small 18 mm diameter core taken from the center of the same sample area. These data show that while
HEPA sock sampling suggested that the decontamination methods were removing some spores,
subsequent extractive samples showed no or minimal removal (less than 1 log reduction, see Figure 6-4).
The HEPA sock samples of control areas  (not decontaminated) showed minimal downward drift.
                                            41

-------
7-
6-
5-
4-
3-
2-
^ 1~
3 0-
± 8
5 ^
-1 6-
5-
4-
3-
2-
1-
n.!









|_[ 1 Heated vacuum
T
1

I
1
i • i • i • i

T



J

:

1 1 i Unheated Vacuum
T
1

T
1
                     Carpet Decontamination Steps
Figure 6-4.   Core Sampling Results after Decontamination Attempts

The act of decontaminating with the wet/dry vacuums seems to push the spores away from the surface
and into the carpet pile where the HEPA socks were unable to sample effectively. Even though the
samples were allowed to dry overnight, residual moisture or detergent may have helped spores adhere to
carpet fibers. Because the apparent log reduction from the HEPA sock samples from Test B (Figure 6-2)
showed a greater log reduction that the HEPA sock samples from Test C (Figure 6-3), the tamped down
nature of the older used carpet as well as the debris in the fibers may further reduce recovery by binding
to the spores or merely retaining moisture.

Although the results from Tests A and B were inconclusive regarding the efficiency of the  carpet cleaners,
all three tests suggested that there  was no statistical difference between the hot (heated)  and cold
(unheated) cleaners. Test C indicated that the efficacy of the carpet cleaners per the manufacturer's
recommendations was poor. For carpet, extractive sampling appears to be the most reliable method
following any dampening of the surface, especially for used carpet.

One final test (Test D), using new carpet, was conducted to provide information about the benefits of
using  a carpet cleaner with a sporicide (Spor-Klenz) in place of the recommended cleaner versus the
simple application of the sporicide without any vacuuming. These results are shown in Figure 6-5 and
Figure 6-6 using a back pack sprayer and an unheated vacuum cleaner, respectively.
                                              42

-------
       7-
       6-
       5-
       4-
       3-
2 7-
0 6-
5-
4-
3-
2-
0-
-1-
-21





1
Positive control dec
1 1 Hepa Socks Samples |

Detecti9n Limits

1 T
>n 1 Decon 2
                    Carpet Decontamination Steps
Figure 6-5.  Spor-Klenz Applied to a New Carpet with a Backpack Sprayer


6-
4-
3-
2-
"c i J
,9 o-
o UH
LL 7:
O ' -
6-
5-
4-
3-
2-
1-
0-
-1-















}
1


i
^




Positive control
1 1 I Core samples |

Detection Limits
T ^_^ \

1

1 1 1 Hepa Socks Samples

Detection Limits
1
T
decon 1 Decon 2
                    Carpet Decontamination Steps


Figure 6-6.  Spor-Klenz Applied to a New Carpet with an Unheated Vacuum Cleaner

Test D showed a very good log reduction  from the use of Spor-Klenz, applied either from the carpet
cleaner (Table 6-1) or the backpack sprayer (Table 6-2). The first decontamination showed a 6 log
reduction from the HEPA socks (no detection on the core samples, which have a higher detection limit
than the HEPA sock samples). Following the second application of Spor-Klenz, no spores were detected
using either sampling  method, a 7 log reduction in the HEPA sock results.
                                             43

-------
The core samples could show only a 3 log reduction, in part because of the higher detection limit. The
core samples taken for the controlled contamination had lower recovery than expected, possibly due to
the rigorous method that was used to extract the core samples causing re-aerosolization of many spores.
The summary of the results for the spore counts log reductions for Test B through Test D are presented in
Table 6-3.
Table 6-1. Spor-Klenz Applied with a Carpet Cleaner*
Carpet Status
Controlled
Contamination
After 1st
Decontamination
After 2nd
Decontamination
Date
8/25/2010
8/30/2010
9/1/2010
HEPA socks
Mean of log
CFU/ft2
7.2
1.5
-0.03
Error (95%
Confidence Interval)
0.11
1.82
0.10
Core Samples
Mean of
log CFU/ft2
5.29
2.5
1.8
Error (95%
Confidence
Interval)
1.09
0.30
0.04
  Detection Limit values are in red.
Table 6-2. Spor-Klenz Applied with a Backpack Sprayer*
Carpet Status
Controlled
Contamination
After 1st
Decontamination
After 2nd
Decontamination
Date
8/25/2010
8/30/2010
9/1/2010
HEPA socks
Mean of log
CFU/ft2
7.07
0.95
-0.13
Error (95%
Confidence Interval)
0.20
2.07
0.10
Core Samples
Mean of
log CFU/ft2
6.12
2.49
1.81
Error (95%
Confidence
Interval)
0.41
0.3
0
  Detection Limit values are in red.
                                              44

-------
Table 6-3. CPU Log Reduction with Spor-Klenz Application
Decontamination procedure

Spor-Klenz from backpack
sprayer
Spor-Klenz application with
carpet cleaner
HEPA Sock Sampling
Decon 1
1.7
-------
6.2.1  Length of Decontamination Event
The decontamination procedure using the carpet cleaners is very short, if only performed once,
approximately five seconds per square foot. Test D with Spor-Klenz suggested that performing the
decontamination twice would yield no recoverable spores. If the decontaminations are performed
immediately (back-to-back), then there is minimum  impact on the remediation crew. If, on the other hand,
the carpet is allowed to dry between successive applications, then an extra day is involved. Though it was
not a consideration for this test, the ultimate disposal of the carpet cleaners after use in an event may
contribute to the cleanup time and expense.

The backpack sprayer method as performed does require an  extended duration, allowing for treatment of
an extrapolated 192 square feet in 30 minutes, or 6.4 square  feet per minute, significantly higher than
when a carpet cleaner is being used.

6.2.2  Physical impact on Materials and Crew
No physical impact on the carpet was noted for any of the decontamination methods. While neither
decontamination procedure was physically strenuous, any activity inside Level C suits (even with cooling
vests) leads to heat stress.  Moreover, the use of Spor-Klenz  in an area without very high  air exchanges
could lead to levels of hydrogen peroxide or acetic acid above IDLH conditions.

6.2.3  Fate of Spores
Determining the ultimate fate of spores has proven  very complicated due to sampling difficulties. The
rinsate recovered from the carpet cleaners used in Tests A, B, and C was very contaminated, obscuring
enumeration of the spores of interest. This level of contamination does suggest that conditions are such
that the likelihood our target organism was in the rinsate was  very high. No data suggest that all spores
were removed from the carpet during Tests A,  B, and C, so the ultimate fate of those spores is probably
viable and present in carpet, carpet cleaner parts, and  rinsate. The fate of spores in Test D is probably
deactivated due to the presence of Spor-Klenz in all locations, but some doubt lingers due to difficulties
sampling the rinsate.

6.2.4  Health and Safety Effects of Decontamination
There were no noxious fumes or gases detected from the use of the carpet cleaner solutions (Judson
Laboratories Oxygen 2 Pre-Spray and Extraction) or the Spor-Klenz.
                                              46

-------
References

1  After Action Report - Danbury Anthrax Incident, U.S. EPA Region 1, September 19, 2008. (Available
  upon request from Mike Nalipinski, Nalipinski.Mike@epa.gov, Region 1 On-Scene Coordinator)

2  Brown, G.S.; Betty, R.G.; Brockmann, J.E.; Lucero, D.A.; Souza, C.A.; Walsh, K.S.;  Boucher, R.M.;
  Tezak, M.S.; Wilson, M.C. Evaluation of Surface Sample Collection Methods for Bacillus Spores on
  Porous and Non-porous Surfaces. In 2006 Workshop on Decontamination, Cleanup and Associated
  Issues for Sites Contaminated With Chemical, Biological, or Radiological Materials, Proceedings of the
  2006 NHSRC Decontamination Workshop, Washington, DC, April 26 - 28, 2006.

3  Busher, A.;Noble-Wang; J.; Rose, L. Surface Sampling. In Sampling for Biological Agents in the
  Environment; Emanual, P., Roos, J.W., Niyogi, K., Eds.; ASM Press: Washington, DC, 2008; pp 95 -
  131

4  Brown, G.S.; Betty, R.G.; Brockmann, J.E.; Lucero, D.A.; Souza, C.A.; Walsh, K.S.;  Boucher, R.M.;
  Tezak, M.; Wilson, M.C.; Rudolph, T. Evaluation of a Wipe Surface Sample Method for Collection of
  Bacillus Spores from Nonporous Surfaces. Appl Environ Microbiol 2007, 73 (3), 706 - 710

5  [FOUO] Estill, C.F.; Baron, P.A.; Beard, J.K.; Hein, M.J.; Larsen, L.D.; Rose, L.; Schaefer III, F.W.;
  Noble-Wang, J.; Hodges, L.; Lindquist, A.; Deye, G.J.; Arduino, M.J. Recovery Efficiency and Limit of
  Detection of Aerosolized B. anthracis Sterne from Environmental Surface Samples. Submitted to Appl
  Environ Microbiol.

6  Mattorano, D. U.S. EPA/OSWER/OEM/National Decontamination Team, Erlanger, KY. Personal
  communication (regarding the current sampling strategies under development by the Interagency
  Workgroup for the Validated Sampling  Plan for B. anthracis), December 12, 2008.

7  Busher, A.;Noble-Wang; J.; Rose, L. Surface Sampling. In Sampling for Biological Agents in the
  Environment; Emanual, P., Roos, J.W., Niyogi, K., Eds.; ASM Press: Washington, DC, 2008; pp 95 -
  131.

8  Brown, G.S.; Betty, R.G.; Brockmann, J.E.; Lucero, D.A.; Souza, C.A.; Walsh, K.S.;  Boucher, R.M.;
  Tezak, M.; Wilson, M.C.; Rudolph, T. Evaluation of a Wipe Surface Sample Method  for Collection of
  Bacillus Spores from Nonporous Surfaces. Appl Environ Microbiol 2007, 73 (3), 706 - 710.

9  [FOUO] INL 2008 Evaluation Protocols.

10ARCADIS  G&M, Inc. Quality Assurance Project Plan for the Determination of the Efficacy of Spore
  Removal from Carpets using Commercially-available Wet/Vacuum Carpet Cleaning Systems. Prepared
  under Contract No. EP-C-04-023, Work Assignment No. 4-35. U.S. Environmental Protection Agency,
  National Homeland Security Research  Center, Research Triangle Park, NC. May 2009. (Available upon
  request from Shawn Ryan, Ryan.Shawn@epa.gov, DCMD Division Director)

11 ARCADIS  U.S., Inc. Compatibility of Material and Electronic Equipment with Chlorine Dioxide
  Fumigation, Assessment and Evaluation Report. Prepared under Contract  No. EP-C-04-023, Work
  Assignment No. 4-50 for U.S. Environmental Protection Agency, National Homeland Security Research
                                             47

-------
Center, Office of Research and Development, Research Triangle Park, NC. July 2009. (Available upon
request from Shawn Ryan, Ryan.Shawn@epa.gov, DCMD Division Director)
                                          48

-------
Appendix A: COMMANDER Piping and Instrumentation Diagram
                                       49

-------
Appendix B: MSDS for Decontamination Solutions




   •   Judson Laboratories Oxygen 2 / Pre-Spray




   •   Judson Laboratories Oxygen 2 / Extraction




   •   Steris Spor-Klenz® Ready To Use
                                          50

-------
                           JUDSON LABORATORIES
                                  P.O. BOX 4388
                            GREENVILLE, SC 29608
                                  (864) 233-6442
MATERIAL SAFETY DATA SHEET
                                 I. IDENTIFICATION
PRODUCT NAME: OXYGEN 2 / PRE-SPRAY
CHEMICAL NAME: ALKALINE DEGREASER
CHEMICAL FAMILY: ALKALI BLENDED/OXYGEN BRIGHTENER/D-LLV1QNENE SOLVENT/PH-93 to 9.9
FORMULA: TRADE SECRET
SYNONYM'S: NONE
CAS # AND NAME: TRADE SECRET
                                 II. PHYSICAL DATA
BOILING POINT: 220 F
FREEZING POINT: 32 F
PH:  10.8
SPECIFIC GRAVITY (H2O=1): 1.0002
VAPOR DENSITY (AIR=1): NA
VAPOR PRESSURE AT 20'C:  NA
SOLUBILITY IN WATER BY WT: NA
EVAPORATION RATE 
-------
O2PRE-SPRAY /PG. 2


                        IV. FIRE AND EXPOSURE HAZARD DATA

FLASH POINT: COMPLETELY NON COMBUSTIBLE, NOT A FIRE HAZARD

FLAMMABLE LIMITS IN AIR, % BY VOLUME: LOWER: NA / UPPER  NA

EXTINGUISHING MEDIA: THIS MATERIAL IS NOT COMBUSTIBLE

SPECIAL FIRE FIGHTING PROCEDURES: N/A

UNUSUAL FIRE AND EXPLOSION HAZARDS: NONE


                              V. HEALTH HAZARD DATA


EXPOSURE LIMITS: NONE

EFFECTS OF ACCUTE OVER EXPOSURE:
SWALLOWING: INGESTION OF THE PRODUCT CAN CAUSE GASTRIC WALL IRRITATION AND POSSIBLE RED
BLOOD CELL IIEMOTOSIS

SKIN ABSORFIION: MODERATE SKIN PENETRATION

INHALATION: INHALATION OF AIR CONTAMINATED WITH LARGE AMOUNTS OF MIST SPRAY OR ATOMIZED
PRODUCTS WILL IRRITATE MUCUS MEMBRANE

SKIN CONTACT: LONG TERM CONTAMINATION OF SKIN MAY CREATE EXCESSIVE SKIN DRYNESS AND MILD
SKIN DERMATITIS BECAUSE OF THE BREAKDOWN OK NATURAL OILS

EYE CONTACT: FLUSH WITH COPIUS AMOUNTS OF WATER

EFFECTS OF REPEATED OVEREXPOSURE: WILL CAUSE THE BREAD DOWN OF NATURAL SKIN OILS CAUSING
CONTACT DERMATITIS

MEDICAL CONDITIONS AGGRAVATED BY OVEREXPOSURE: SKIN DISEASES AND CONTACT DERMATITIS AS
WELL AS PERSONS HAVING CHRONIC RESPIRATORY DISEASES

EMERGENCY AND FIRST AID PROCEDURES:
SWALmWING: WASH OUT MOUTH, DRINK LARGE QUANTITIES OF CITRUS JUTCE,(EXAMPLE: GRAPEFRUIT
JUICE) AND THEN INDUCE VOMITING

SKIN: WASH CONTAMINATED AREA WITH DILUTED VINEGAR AND WATER RINSE

INHALATION: THIS PRODUCT HAS NO HARMFUL VAPOR CHARACTERISTICS BUT DROPLETS FROM SPRAY
APPLICATION CAN CAUSE RESPIRATORY IRRITATION. EVACUATE AREA TO FRESH AIR

EYES: FLUSH WITH COPIUS AMOUNTS OF WATER FOR 15 .MINUTES, WASH EYES WITH 5% BORIC ACID SOLUTION
THEN, CONSULT A PHYSICIAN IMMEDIATELY

NOTES TO PHYSICIAN: TREAT ALL CONTACT PROBLEMS BY NEUTRALIZATION WITH MILD ACIDIC WASH THEN
TREAT FOR CHEMICAL BURNS
                                         52

-------
O2 PRE-SPRAY / PG, 3


                                 VI. REACTIVITY DATA

STABILITY: STABLE

CONDITIONS TO AVOID: CONTACT WITH STRONG ACIDS

HAZARDOUS COMBUSTION OK DECOMPOSITION PRODUCTS: THIS PRODUCT SHOULD NEVER I3L; STORED IN
ALUMINUM CONTAINERS

HAZARDOUS POLYMERIZATION: NONE

CONDITIONS TO AVOID: FURNITURE, WALLS ECT.


                           VII. SPILL OR LEAK PROCEDURES


STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED: SMALL SPILLS: ABSORB WITH ABSORBENT
MATERIAL AND DISCARD IN TRASH RECEPTACLE. LARGE SPILLS: PUMP INTO DRUMS FOR RECOVERY

WASTE DISPOSAL METHOD: SPILL, THEN NEl TTRALI7.E WASTE WITH HYDROCHLORIC ACID SOLUTION.
DILUTE WITH WATER BEFORE DISCHARGING TO SEWER SYSTEM


                       MIL SPECIAL PROTECTIVE INFORMATION


RESPIRATORY PROTECTION:  THE APPROVED RESPIRATORY MASK SHOULD BE USED IN HIGH PRESSURE
SPRAY MIST ENVIRONMENTS, IF SPRAYED INTO THE AIR.

VENTILATION: CLOSE AREAS SHOULD BE PROVIDED WITH FRESH AIR

PROTECTIVE GIXWES: IT IS SUGGESTED RUBBER NEOPRENE GLOVES TO BE WORN

EYE PROTECTION: GOGGLES OR MASK SHOULD BE WORN IF PRODUCT BECOMES IRRITATING

OTHER PROTECTIVE EQUIPMENT: IT IS SUGGESTED ALL SKIN AREAS TO BE COVERED WHEN USING THIS
PRODUCT


                              IX. SPECIAL PRECAUTIONS


STATUS ON SUBSTANCE: THE CONCENTRATIONS SHOWN ARE MAXIUM OR CEILING LEVELS (WEIGHT %) TO BE
USED FOR CALCULATIONS FOR REGULATIONS. TRADE SECRETS ARE INDICATED BY "TS"

FEDERAL EPA: COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT OF 1980
(CERCLA) REQUIRES NOTIFICATION OF THE NATIONAL RESPONSE CENTER OF RELEASE OF QUANTITIES OF
HAZARDOUS SUBSTANCES EQUAL TO OR GREATER THAN THE REPORT ABLE QNANTIT1ES (RQ'S) IN 40 CFR 302.4
THE OPINIONS ARE THOSE OF QUALIFIED SCIENTIST WITHIN JUDSON LABORATORIES. WE BELIEVE THE
INFORMATION CONTAINED IS CURRENT AND VALID. SINCE USE OF THIS INFORMATION, OPINIONS AND THE
CONDITIONS OF USE OF THE PRODUCT ARE NOT WITHIN THE CONTROL OF JUDSON LABORATORIES, IT IS THE
USERS OBLIGATION TO DETERMINE THE CONDITIONS OF SAFE USE OF THE PRODUCT.
                                          53

-------
                           JUDSON LABORATORIES
                                  P.O. BOX 4388
                            GREENVILLE, SC 29608
                                  (864) 233-6442
MATERIAL SAFETY DATA SHEET
                                 I. DENTIFICATION
PRODUCT NAME: OXYGEN 2 / EXTRACTION
CHEMICAL NAME: CLEANER / OXYGEN BRIGHTNER / NEUTRAL AGENT / IPA DRYING AGENT
CHEMICAL FAMILY: NEUTRALIZING AGENT
FORMULA: TRADE SECRET
PH: 7.0
SYNONYMS: NONE
CAS # AND NAME: TRADE SECRET WITH NO CAS NUMBERS ASSIGNED
                                 II. PHYSICAL DATA
BOILING POING: 220 F
FREEZING POINT: 32' F
SPECIFIC GRAVITY (H2O=1): 1.0002
VAPOR DENSITY (AIR=1): NA
SOLUBILITY IN WATER BY WT: COMPLETE
EVAPORATION RATE: 1
APPEARANCE & ODOR: AQUA-BLUE LIQUID WITH CLEAN ODOR
EMERGENCY PHONE NUMBERS:
MONDAY - FRIDAY: 9:OOAM - 6:OOPM (864) 233-6442 / OTHER TIMES (864) 787-3038

****HAZARD RATING SCALE****
0=MINIMAL         3=HIGH
1=SLIGHT          4=SERIOUS
2=MODERATE       5=SEVERE
                                  III. INGREDIENTS
MATERIAL % EXPOSURE LIMITS HAZARD - 1
SODIUM BORATE 3-8% 25ppm
SOppm (SKIN) OSHA
ORAL 1.48gm/kg (RAT)
INHALATION LD 50-700ppm / 7 HOURS (RAT)
                                    54

-------
O2 EXTRACTION /PG. 2


                        IV. FIRE AND EXPOSURE HAZARD DATA

FLASH POINT: COMPLETELY NON COMBUSTIBLE, NOT A FIRE HAZARD

FLAMMABLE LIMITS IN AIR, % BY VOLUME: LOWER: NA UPPER:  NA

EXTINGUISHING MEDIA:  NONE REQUIRED

SPECIAL FIRE FIGHTING PROCEDURES: N/A

UNUSUAL FIRE AND EXPLOSION HAZARDS: NONE


                               V. HEALTH HAZARD DATA

EXPOSURE LIMITS: MODERATE

EFFECTS OF ACCUTE OVER EXPOSURE:
SWALLOWING: INGESTION OF THE PRODUCT CAN CAUSE GASTRIC WALL IRRITATION

SKIN ABSORPTION: MODERATE SKTN PENETRATION

INHALATION: INHALATION OF AIR CONTAMINATED BY THE HIGH PRESSURE SPRAY MIST OF THIS PRODUCT
MAY CAUSE RESPIRATORY IRRITATION

SKIN CONTACT: LONG TERM CONTAMINATION OF SKIN MAY CREATE EXCESSIVE SKIN DRYNESS AND MILD
SKIN DERMATITIS BECAUSE OF THE BREAKDOWN OF NATURAL OILS

EYE CONTACT: FLUSH WITH COPIUS AMOUNTS OF WATER

EFFECTS OF REPEATED OVEREXPOSURE: MAY CAUSE DRY IRRITATED SKIN DUE TO REMOVAL OF OILS

MEDICAL CONDITIONS AGGRAVATED BY OVEREXPOSURE: CHRONIC SKIN DISEASE PERSONS WITH ALLERGY
PROBLEMS AND CHRONIC RESPIRATORY DISEASES MAY EXPERIENCE COMPLICATIONS

EMERGENCY AND FIRST AID PROCEDURES:
SWALLOWING: WASH OUT MOUTH. DRINK LARGE QUANTITIES OF CITRUS JUICE. GRAPEFRUIT AND THEN
INDUCE VOMITING

SKIN: WASH CONTAMINATED AREA WITH DILUTED VINEGAR AND WATER

INHALATION: THIS PRODUCT HAS NO HARMFUL VAPOR CHARACTERISTICS BUT MIST FROM HIGH PRESSURE
SPRAY MAY BE IRRITAING TO RESPIRATORY SYSTEM SEEK FRESH AIR

EYES:  FLUSH WITH COPIUS AMOUNTS OF WATER FOR 15 MINUTES

NOTES TO PHYSICIAN: NONE
                                          55

-------
O2 EXTRACTION /PG. 3


                                VI. REACTIVITY DATA


STABILITY: STABLE

CONDITIONS TO AVOID: STRONG OXIDIZING AGENTS

HAZARDOUS COMBUSTION OR DECOMPOSITION PRODUCTS: NONE

HAZARDOUS POLYMERIZATION: NONE

CONDITIONS TO AVOID: NONE


                           VII. SPILL OR LEAK PROCEDURES


STEPS TO BE TAKEN IF MATERIAL IS RELEASED OR SPILLED: CONTAIN SPILL VACUUM OR BLOT UP WITH
MOP OR ABSORB WITH WATER ABSORBING MATERIAL CONTAMINATED SURFACES MAY BE WASHED WITHOUT
ADVERSE ENVIRONMENTAL IMPACT

WASTE DISPOSAL METHOD: SPILLED MATERIAL MAY BE RECLAIMED DEPENDENT UPON OTHER
CONTAMINATS. WASTE DISPOSAL (INSURE CONFORMITY WITH ALL APPLICABLE DISPOSAL REGULATIONS)
INCINERATE OF OTHERWISE MANAGE IN A RCRA PERMITTED WASTE MANAGEMENT FACILITY


                      VIII. SPECIAL PROTECTIVE INFORMATION


RESPIRATORY PROTECTION: GENERALLY NOT REQUIRED

VENTILATION: USE ADEQUATE VENTILATION

PROTECTIVE GLOVES: SUGGESTED USE OF RUBBER GLOVES IS A GOOD PRACTICE

EYE PROTECTION:  FOR SPLASH PROTECTION USE PROTECTIVE GOGGLES OR FACE SHIELD

OTHER PROTECTIVE EQUIPMENT: NO SPECIAL GARMENTS REQUIRED AVOID UNNECCARY SKIN
CONTAMINATION WITH MATERIAL


                              IX. SPECIAL PRECAUTIONS
STATUS ON SUBSTANCE: THE CONCENTRATIONS SHOWN ARE MAXIUM OR CEILING LEVELS (WEIGHT %) TO BE
(CERCLA) REQUIRES NOTIFICATION OF THE NATIONAL RESPONSE CENTER OF RELEASE OF QUANTITIES OF
HAZARDOUS SUBSTANCES EQUAL TO OR GREATER THAN THE REPORTABLE QUANTITIES (RQS) IN 40 CFR 302,4
THE OPINIONS ARE THOSE OF QUALIFIED SCIENTIST WITHIN JUDSON LABORATORIES. WE BELIEVE THE
INFORMATION CONTAINED IS CURRENT AND VALID.  SINCE USE OF THIS INFORMATION. OPINIONS AND THE
CONDITIONS OF USE OF THE PRODUCT ARE NOT WITHIN THE CONTROL OF JUDSON LABORATORIES, IT IS THE
USERS OBLIGATION TO DETERMINE THE CONDITIONS OF SAFE USE OF THE PRODUCT.
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Material Safety Data Sheet
May be used to comply with OSHA's
Hazard Communication Standard,
29 CFR 1910.1200. Standard must be
consulted for specific requirements.
product Name
 SPOR-KLENZ
READY TO USE
                               Kroouct uescnption
COLD STERILANT

ALIPHATIC CARBOXYLIC ACID,
INORGANIC PEROXIDE.
ORGANIC PEROXIDE
(STRONG OXIPIZERj
                                                           product ID
                             6525
                                        STERIS'

Manufacturers Name
STERIS Corporation
Address
P.O. Box 147
St. Louis, Missouri 63166
tmergency leiepnone Numoer
1-314-535-1395 (STERIS); 1-800-424-9300 (CHEMTREC)
Telephone Number for Information
1-800-444-9009 (Customer Service - Scientific Products)
Date Prepared: July 1,1999
Prepared by: M. Ebers
Health
Fire
Reactivity
2
0
0
Least Sfcght Mtoersie H^h Ex:fe-ra
0 2 34

SECTION II - HAZARDOUS INGREDIENTS/IDENTITY INFORMATION
Hazardous Components (Specific Chemical
Identity; Common Name(s))

Hydrogen Peroxide (7722-84-1)

Peracetic Acid (79-2 1 -0)
Acetic Acid (64-19-7)

% by Wt,

0.80

0.06
Proprietary

ACGIH
TLV

1ppm

N/E
10ppm

OSHA PEL

1ppm

N/E
10ppm

Other Limits
Recommended






SECTION III - PHYSICAL/CHEMICAL CHARACTERISTICS

Solubility in
Water
Freezing Point F
pH @ Solution
Appearance
Complete
N/A
N/A
Clear, colorless liquid
Specific Gravity (HZ0=1 @
25C)
% Volatile by wt @ 105C/1 hr
pH as Distributed
Odor
1.01
N/A
~ 1.87
Mild vinegar odor
SECTION IV - FIRE AND EXPLOSION HAZARD DATA

 Flash Point (Method Used)   N/A
                                            Flammable Limits  N/A   LEL
                                                                                 UEL
 Extinguishing Media
  Use water, foam, C02, dry chemicals.
 Special Fire Fighting Procedures
 As with any chemical fire, the use of a self-contained breathing apparatus and full protective equipment is
 recommended. Dilute with large volumes of water.	
 Unusual Fire and Explosion
 Hazards
                                N/A
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SECTION V - REACTIVITY DATA
Stability
Unstable
Stable
Incompatibility (Materials to Avoid)
Hazardous Decomposition or
Byproducts
Hazardous
Polymerization

May Occur
Will Not
Occur

X
Conditions to Avoid
Avoid temperatures above 75F. Avoid contact with combustible
materials.
Heavy metals including iron, copper, copper alloys, brass and aluminum,
salts, alkalis, caustics, and formaldehyde.
Oxygen and heat Do not mix with chlorinated products as this could
liberate toxic corrosive chlorine gas.

X
Conditions to Avoid
None known.
                                SPOR-KLENZ READY TO USE
SECTION VI - HEALTH HAZARD DATA
 A. ACUTE (Primary Route of Exposure)

 EYES: Contact with eyes may cause burns.

 SKIN; May cause moderate skin irritation, including oxidation (i.e., whitening of the skin). LD--0 Rat; > 20 g/kg.

 INHALATION: May cause irritation to mucous membranes. LDS2 Rat: >13,439 mg/m3.




 B. SUBCHRONIC, CHRONIC, OTHER: None known
SECTION VII - EMERGENCY AND FIRST AID PROCEDURES
 EYES: In case of contact, immediately flush with water for 15 minutes and get medical attention.

 SKIN: For skin contact, wash with soap and water Get medical attention if irritation persists. Remove and launder
 contaminated clothes before reuse.

 INHALATION: Remove to fresh air.

 INGESTION: Do not induce vomiting. Drink large quantities of water.  Get immediate medical attention.
SECTION VIII - PRECAUTIONS FOR SAFE HANDLING & USE
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Spill Management:

Waste Disposal Methods:
Precautions to be taken in handling
and storage:
Shipping information:
Flush with large quantities of water; mop thoroughly. Do not use absorbent


Dispose of in accordance with all local, state and federal regulations.
Store in a cool, dry place below 75F. Do not expose to sunlight Read
observe all labeled use instructions.
and
Not restricted
SECTION IX - PROTECTION INFORMATION/CONTROL MEASURES

Respiratory:
Eyes:
Use only in well-ventilated area
Safety glasses/goggles/full face
shield
Other Clothing and Equipment:
Ventilation;
Use local exhaust
Gloves:
Rubber or plastic
Rubber apron

U.S. FEDERAL REGULATIONS:
  All components are listed in the Toxic Substance Control Act (TSCA) Chemical Substance Inventory. OSHA
  Hazardous Communication Standard (29 CFR 1910.1200) Hazardous Class: Corrosive.
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Appendix C: Miscellaneous Operating Procedure (MOP) 6535a
BL MOP NO. 6535a                                                              M. Worth Calfee
                                                                               4-8-2009, rev. 2.0
Title:           SERIAL DILUTION: SPREAD PLATE PROCEDURE TO QUANTIFY VIABLE
               BACTERIAL SPORES

Scope:         Determine the abundance of bacterial spores in a liquid extract

Purpose:       Determine quantitatively the number of viable bacterial spores in a liquid suspension
               using the spread plate procedure to count colony-forming units (CPU)
Materials:

    •   Liquid suspension of bacterial spores

    •   Sterile microcentrifuge tubes

    •   Diluent (sterile deionized water, buffered peptone water or phosphate buffered saline)

    •   Trypticase Soy Agar plates

    •   Microliter pipettes with sterile tips

    •   Sterile beads placed inside a test tube (will be used for spreading samples on the agar surface)

    •   Vortex mixer



Procedure: (This protocol is designed for 10-fold dilutions.)

    1.  For each bacterial spore suspension to be tested, label the microcentrifuge tubes as follows: 10~1,
       10"2, 10"3, 10"4, 10"5, 10"6... (The number of dilution tubes will vary depending on the  concentration
       of spores in the suspension).  Aseptically, add 900 uL of sterile diluent to each of the tubes.

    2.  Label three Trypticase Soy Agar (TSA) plates for each dilution that will be plated. These dilutions
       will be plated in triplicate.

    3.  Mix original spore suspension by vortexing thoroughly for 30 seconds. Immediately after the
       cessation of vortexing, transfer 100 uL of the stock suspension to the 10"1 tube.  Mix the 10"1 tube
       by vortexing for 10 seconds, and immediately pipette 100 uL to the 10"2 tube. Repeat this
       process until the final dilution is made.  It is imperative that used pipette  tips be exchanged for a
       sterile tip each time a new dilution is started.
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    4.  To plate the dilutions, vortex the dilution to be plated for 10 seconds, immediately pipette 100 uL
       of the dilution onto the surface of a ISA plate, taking care to dispense all of the liquid from the
       pipette tip.  If less than 10 seconds elapses between inoculation of all replicate plates, then the
       initial vortex mixing before the first replicate is sufficient for all replicates of the sample.  Use a
       new pipette tip for each set of replicate dilutions.

    5.  Carefully pour the sterile glass beads onto the surface of the ISA plate with the sample and
       shake until the entire sample is distributed on the surface of the agar plate. Aseptically remove
       the glass beads. Repeat for all plates.

    6.  Incubate the plates overnight at 32 °C  - 37 °C (incubation conditions will vary depending on the
       organism's optimum growth temperature and generation time.)

    7.  Enumerate the colony forming units (CPU) on the agar plates by manually counting with the aid of
       a plate counting lamp, and with a marker (place a mark on the surface of the Petri dish over each
       CPU when counting, so that no CPU is counted twice).

Since each dilution was tested in triplicate, determine the average of the triplicate plate abundances.
Plates suitable for counting must contain between 30 - 300 colonies.

Calculations

Total abundance of spores (CPU) within extract:

(Avg CPU / volume (ml_) plated) x (1/tube dilution factor) X extract volume
For example:
Tube Dilution          Volume plated                 Replicate      CPU

10'3                  100 uL (0.1 ml)                  1           150

10'3                  100uL (0.1 ml)                  2           250

10-3                  100uL (0.1 ml)                  3           200
Extract total volume = 20 ml
(200 CPU/0.1 ml) x  (1/10'3) X  20 ml = (2000) x (1000)  x 20  =   4.0X107CFU


Note: The volume plated (ml) and tube dilution can be multiplied to yield a 'decimal factor' (DP).  DP can
be used in the following manner to simplify the abundance calculation.

Spore Abundance per ml_   =  (Avg CPU)  X   (1 / DP)  X   extract volume
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United States
Environmental Protection
Agency
PRESORTED STANDARD
 POSTAGE & FEES PAID
         EPA
   PERMIT NO. G-35
Office of Research and Development (8101R)
Washington, DC 20460

Official Business
Penalty for Private Use
$300

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