National Guard Bureau
Mid-West Regional Industrial Hygiene Office
301-IH Old Bay Lane
Havre de Grace, MD 21078
ARNG-CSG-P

Apr 15, 2014

MEMORANDUM FOR: The Adjutant General for South Dakota
SUBJECT: Industrial Hygiene Survey at Milbank Armory, South Dakota

National Guard Bureau (NGB) Mid-West Regional Industrial Hygiene (IH) Office field personnel
conducted lead surface wipe sampling at the South Dakota Army National Guard Armory
located at Milbank, South Dakota on March 28, 2014.
Occupational health risk assessment codes (RACs) are assigned to quantify health risks to
personnel IAW DOD Letter of Instruction 6055.1, DOD Safety and Occupational Health
Program. Risk assessment is an expression of health hazard severity and mishap probability,
described in terms of route of exposure, actual exposure, exposure limit standards, potential
health effects, duration of exposure, and number of exposed personnel.
Based on information on site, the armory is joined with the local high school. The old firing
range is now converted to storage space for gym equipment, and is located in the gym itself.
Wipe samples were collected on representative surfaces in the facility and analyzed for lead.
Some of the surface wipe sample results exceeded the guideline adopted by the NGB Mid-West
Regional IH Office. The following actions are required:

1. Continue to clean the horizontal surfaces to prevent the accumulation of lead
dusts. (RAC 3).
2. The remodeled area where the old firing range was located needs to be
decontaminated to surface lead levels below 40 µg/ft 2. (Due in part to children in
close proximity to contaminated area). Consult a licensed contractor to remediate
this area and provide additional abatement guidance (RAC 2).

 Industrial Hygiene Survey
Survey Date: March 28, 2014

Milbank Armory
Milbank, SD

The NGB conducted this survey in the interest of preventing employee illness and to meet legal
obligations where applicable. Results and recommendations are based on information provided
by site personnel, field measurements, and conditions observed during the survey. For any
further questions, please contact Dr. Randy Fritz at randy.fritz@us.army.mil or call at 303 2108722.
Dr. Randy C. Fritz DM, MS

Regional Industrial Hygienist

Appendix
A.
B.
C.
D.
E.
F.
G.

Title
Metals……………….
Organic Vapors…….
Noise………………..
Ventilation…………..
Lighting…………......
Other IH Issues…….
Other IH Sampling….

Status
Attached
N/A
N/A
N/A
N/A
N/A
N/A

 Industrial Hygiene Survey
Survey Date: March 28, 2014

Milbank Armory
Milbank, SD
Appendix A
Metals

Surface Wipe Samples
Armory is joined with the local high school. The old firing range is converted to storage space
for gym equipment, inside the gym itself. Wipe samples were collected from representative
areas of the facility using Environmental Express Ghost TM Wipes and templates IAW the
Occupational Safety and Health Administration (OSHA) wipe sampling method (OSHA
Technical Manual, Appendix II, 2-1). The samples were analyzed for lead by OSHA Method ID121. The results and photos are contained in Table A-1.
Although OSHA does not have published exposure standards for lead surface contamination,
the 29 CFR 1910.1025(h)(1) requires that all surfaces must be kept as free as practicable of
accumulations of lead dust. In addition, DOD has instituted a new policy to minimize surface
contamination levels of heavy metals (Control and Management of Surface Accumulations from
Lead, Hexavalent Chromium, and Cadmium Operations, DTM 12-003, 18 April 2012).
The NGB Mid-West Regional IH Office has adopted the sampling procedures and guidelines for
lead dust published in NG PAM 420-15, Guidelines and Procedures for Rehabilitation and
Conversion of Indoor Firing Ranges. For purposes of this report, any surface lead level that
exceeds 200 micrograms per square foot (µg/ft2) in the facility is considered significant.
High lead surface levels were detected in the facility.
Recommendations:
1. Continue to clean the horizontal surfaces to prevent the accumulation of lead dusts.
(RAC 3).
2. The remodeled area where the old firing range was located needs to be decontaminated
to surface lead levels below 40 µg/ft2. (Due in part to children in close proximity to
contaminated area). Consult a licensed contractor to remediate this area and provide
additional abatement guidance (RAC 2).

A-1

 Industrial Hygiene Survey
Survey Date: March 28, 2014

Milbank Armory
Milbank, SD

Table A-1
Surface Wipe Sampling Results for Lead
South Dakota Army National Guard
Milbank Armory
March 28, 2014
Sample #

Location

Photo

Surface Guideline

Lead
(μg/ft2)
200

SDMB1A

Old range backstop area on floor
left side

218

SDMB2A

Old range backstop area on floor
right side

110

SDMB3A

Gym bleachers upstairs by
backstop 12x12

<10

SDMB4A

Gym bleachers upstairs by
backstop 12x12

<10

SDMB5A

Below range by kitchen 12x12

<10

A-2

 Industrial Hygiene Survey
Survey Date: March 28, 2014
Sample #

Milbank Armory
Milbank, SD

Location

Photo

Surface Guideline

Lead
(μg/ft2)
200

SDMB6A

Loft above firing range 12x12

51

SDMB7A

Outside supply room door on floor

<91

SDMB8A

In kitchen on fridge

<91

Blank

NA

SDMB8A

2

Notes: 1) μg / ft = micrograms per square foot of surface area. 2) ND = none detected. 3) “<”
means less than the reporting limit for the analytical method.

A-3

 Industrial Hygiene Survey
Survey Date: March 28, 2014

Milbank Armory
Milbank, SD

Laboratory Result Reports and Chain of Custody Sheets

A-4

 Industrial Hygiene Survey Milbank Armory
Survey Date: March 28, 2014 Milbank, SD

  

FOH ENVIRONMENTAL LABORATORY


?b 536 S. CLARK STREET CHICAGO. IL 6060-5 PHONE: I312I FAR: I312I 

 



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Surface Wige Samgling Criteria

 

Metal Acceptable Surface Level Basis for Criteria
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Metals in Wipe Limits
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MS. Edna A. Bautieta
Technical Manager

 

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Industrial Hygiene Survey Milbank Armory
Survey Date: March 28, 2014 Milbank, SD

 

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