National Guard Bureau 

Mid-West Regional Industrial Hygiene Office 

301-IH Old Bay Lane 

Havre de Grace, MD 21078 

ARNG-CSG-P October 7, 2014 

MEMORANDUM FOR: The Adjutant General for South Dakota 

SUBJECT: Surface Wipe Testing for Lead at the Mitchell Armory in Mitchell, South Dakota 

National Guard Bureau (NGB) Mid-West Regional Industrial Hygiene (IH) Office field personnel 

conducted a survey on June 26, 2014 at the South Dakota Army National Guard Armory, 

located in Mitchell, South Dakota. This survey included a walkthrough of the facility and surface 

wipe sampling for lead contamination. 

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. Guidance for RAC 

determination is attached to this memorandum. 

Surface Wipe Sampling: Six wipe samples were collected on representative surfaces in the 

facility and analyzed for lead. For purposes of this report, any results that exceed the guidelines 

adopted by the NGB Mid-West Regional IH Office are considered significant. 

Four of the six wipe samples had detectable levels of lead. The sample collected on a soda 

machine in the Drill room had a lead level of 166 ug/ft2. A sample collected on an electrical 

box in the Drill room had a lead level of 465 ug/ft2. A sample collected on the ice machine in 

the Kitchen had a lead level of 42 ug/ft2. Also of concern, a wipe sample from the supply air 

vent in the Rehearsal Hall had a lead level of 110 ug/ft2. 

Recommendations 

 Clean the upper level surfaces in the drill room and kitchen using high-efficiency 

particulate air (HEPA) filter vacuums or wet methods to avoid the spread lead dust to the 

floor below. (RAC 2) 

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 1 of 24

Surface Wipe Testing for Lead Armory 

Survey Date: June 26, 2014 Mitchell, SD 

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 3 of 24
Surface Sample Lead Testing Armory 

Survey Date: June 26, 2014 Mitchell, SD 

A-1

Appendix A

Lead

Surface Wipe Sampling 

Six wipe samples were collected from representative areas of the facility using Environmental 

Express GhostTM Wipes and templates IAW the OSHA wipe sampling method (OSHA Technical 

Manual, Appendix II, 2-1). The samples were analyzed for lead by OSHA Method ID-121. The 

results and photos are contained in Table A-1. 

Although OSHA does not have published exposure standards for metal surface contamination, 

29 CFR 1910 requires that all surfaces must be kept as free as practicable of accumulations of 

toxic metal dusts. In addition, DOD has instituted a 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 guidelines for metal dust published in 

NG Pam 420-15, Guidelines and Procedures for Rehabilitation and Conversion of Indoor Firing 

Ranges and the Department of Energy (DOE)/Brookhaven National Laboratory Surface Wipe 

Sampling Procedure (IH75190). Any results that exceed these guidelines shown in Table A-1 

are considered significant. 

Four of the six wipe samples had detectable levels of lead. The sample collected on a soda 

machine in the Drill room had a lead level of 166 ug/ft2. A sample collected on an electrical 

box in the Drill room had a lead level of 465 ug/ft2. A sample collected on the ice machine in 

the Kitchen had a lead level of 42 ug/ft2. Also of concern, a wipe sample on the supply air vent 

in the Rehearsal Hall had a lead level of 110 ug/ft2. 

Recommendations 

1. Clean the upper level surfaces in the drill room and kitchen using high-efficiency 

particulate air (HEPA) filter vacuums or wet methods to avoid the spread lead dust to the 

floor below. (RAC 2) 

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 4 of 24
Surface Sample Lead Testing Armory 

Survey Date: June 26, 2014 Mitchell, SD 

A-2

Table A-1 

Surface Wipe Sampling Results for Lead 

South Dakota Army National Guard

Mitchell Armory 

Sample No.

Location Photo Lead (μg/ft2)

Surface Guidelines

For areas open to the public,

Break rooms, and kitchens

40

Surface Guidelines

All other areas of the building 200

W-1

Drill Room on top of 

soda machine

166

W-2

Drill Room on white 

electrical box

465

W-3

Kitchen

On ice machine

42

W-4

Kitchen 

Serving window

<10

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 5 of 24
Surface Sample Lead Testing Armory 

Survey Date: June 26, 2014 Mitchell, SD 

A-3

Sample No.

Location Photo Lead (μg/ft2)

Surface Guidelines

For areas open to the public,

Break rooms, and kitchens

40

Surface Guidelines

All other areas of the building 200

W-5

Rehearsal Hall

On supply air vent

110

W-6

DEERS Office

On cabinet

<10

W-7

Blank ND

Notes: 1) μg / ft2 = micrograms per square foot of surface area. 2) ND = none detected. 3) “<” means 

less than the reporting limit for the analytical method. 

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 6 of 24
Surface Sample Lead Testing Armory 

Survey Date: June 26, 2014 Mitchell, SD 

A-4

Laboratory Result Reports and Chain of Custody Sheets

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 7 of 24



National Guard Bureau 

Mid-West Regional Industrial Hygiene Office 

301-IH Old Bay Lane 

Havre de Grace, MD 21078 

ARNG-CSG-P September 30, 2014 

MEMORANDUM FOR: The Adjutant General for South Dakota 

SUBJECT: Surface Wipe Testing for Lead at the Sioux Falls Armory in Sioux Falls, South 

Dakota 

National Guard Bureau (NGB) Mid-West Regional Industrial Hygiene (IH) Office field personnel 

conducted a survey on May 16, 2014 at the South Dakota Army National Guard Armory, located 

in Sioux Falls, South Dakota. This survey included a walkthrough of the facility and surface 

wipe sampling for lead contamination. 

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. Guidance for RAC 

determination is attached to this memorandum. 

Surface Wipe Sampling: Twenty wipe samples were collected on representative surfaces in 

the facility and analyzed for lead. For purposes of this report, any results that exceed the 

guidelines adopted by the NGB Mid-West Regional IH Office are considered significant. 

Nine of the twenty wipe samples had detectable levels of lead. The sample collected on a 

speaker in the Drill room had a lead level of 170 ug/ft2. Four samples collected in the Food 

Storage had a lead levels ranging from 14 to 26 ug/ft2. A sample collected on a computer desk 

in the Starbase room 154 had a lead level of 11 ug/ft2. Three samples collected in the former 

firing range had lead levels ranging from 94 to 260 ug/ft2. 

Recommendations 

1. Clean the upper level surfaces in the drill room using high-efficiency particulate air 

(HEPA) filter vacuums or wet methods to avoid the spread lead dust to the floor below. 

(RAC 2) 

2. Clean surfaces and items in the Food Storage rooms and the former firing range. 

(RAC 2) 

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 11 of 24

Surface Wipe Testing for Lead Armory 

Survey Date: May 16, 2014 Sioux Falls, SD 

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 13 of 24
Surface Sample Lead Testing Armory 

Survey Date: May 16, 2014 Sioux Falls, SD 

A-1

Appendix A

Lead

Surface Wipe Sampling 

Twenty wipe samples were collected from representative areas of the facility using 

Environmental Express GhostTM Wipes and templates IAW the OSHA wipe sampling method 

(OSHA Technical Manual, Appendix II, 2-1). The samples were analyzed for lead by OSHA 

Method ID-121. The results and photos are contained in Table A-1. 

Although OSHA does not have published exposure standards for metal surface contamination, 

29 CFR 1910 requires that all surfaces must be kept as free as practicable of accumulations of 

toxic metal dusts. In addition, DOD has instituted a 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 guidelines for metal dust published in 

NG Pam 420-15, Guidelines and Procedures for Rehabilitation and Conversion of Indoor Firing 

Ranges and the Department of Energy (DOE)/Brookhaven National Laboratory Surface Wipe 

Sampling Procedure (IH75190). Any results that exceed these guidelines shown in Table A-1 

are considered significant. 

Nine of the twenty wipe samples had detectable levels of lead. The sample collected on a 

speaker in the Drill room had a lead level of 170 ug/ft2. Four samples collected in the Food 

Storage had a lead levels ranging from 14 to 26 ug/ft2. A sample collected on a computer desk 

in the Starbase room 154 had a lead level of 11 ug/ft2. Three samples collected in the former 

firing range had lead levels ranging from 94 to 260 ug/ft2. 

Recommendations 

1. Clean the upper level surfaces in the drill room using high-efficiency particulate air 

(HEPA) filter vacuums or wet methods to avoid the spread lead dust to the floor below. 

(RAC 2) 

2. Clean surfaces and items in the Food Storage rooms and the former firing range. 

(RAC 2) 

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 14 of 24
Surface Sample Lead Testing Armory 

Survey Date: May 16, 2014 Sioux Falls, SD 

A-2

Table A-1 

Surface Wipe Sampling Results for Lead 

South Dakota Army National Guard

Sioux Falls Armory 

Sample No.

Location Photo Lead (μg/ft2)

Surface Guidelines

For areas open to the public,

Break rooms, and kitchens

40

Surface Guidelines

All other areas of the building 200

W-1

Drill Room on speaker 170

W-2

Dining Hall room 161

On soda machine <91

W-3

Kitchen on shelf <91

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 15 of 24
Surface Sample Lead Testing Armory 

Survey Date: May 16, 2014 Sioux Falls, SD 

A-3

Sample No.

Location Photo Lead (μg/ft2)

Surface Guidelines

For areas open to the public,

Break rooms, and kitchens

40

Surface Guidelines

All other areas of the building 200

W-4

Kitchen on oven <10

W-5

Kitchen on freezer <91

W-6

Food Storage

On floor 26

W-7

Food Storage

On metal shelf 24

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 16 of 24
Surface Sample Lead Testing Armory 

Survey Date: May 16, 2014 Sioux Falls, SD 

A-4

Sample No.

Location Photo Lead (μg/ft2)

Surface Guidelines

For areas open to the public,

Break rooms, and kitchens

40

Surface Guidelines

All other areas of the building 200

W-8

Food Storage BDE

On metal shelf

<10

W-9

Food Storage BDE

On floor

<10

W-10

Food Storage cage

On metal shelf

17

W-11

Food Storage cage

On floor 14

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 17 of 24
Surface Sample Lead Testing Armory 

Survey Date: May 16, 2014 Sioux Falls, SD 

A-5

Sample No.

Location Photo Lead (μg/ft2)

Surface Guidelines

For areas open to the public,

Break rooms, and kitchens

40

Surface Guidelines

All other areas of the building 200

W-12

Food Storage

On floor

<10

W-13

Starbase room 153

On desk

<10

W-14

Starbase room 153

On screen TV

<10

W-15

Starbase room 154

On projector

<91

W-16

Starbase room 154

On electrical box

<91

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 18 of 24
Surface Sample Lead Testing Armory 

Survey Date: May 16, 2014 Sioux Falls, SD 

A-6

Sample No.

Location Photo Lead (μg/ft2)

Surface Guidelines

For areas open to the public,

Break rooms, and kitchens

40

Surface Guidelines

All other areas of the building 200

W-17

Starbase room 154

On computer desk

11

W-18

Range

On black case

260

W-19

Range 

On green table

120

W-20

Range 

On red pads

94

W-21

blank - ND

Notes: 1) μg / ft2 = micrograms per square foot of surface area. 2) ND = none detected. 3) “<” means 

less than the reporting limit for the analytical method. 

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 19 of 24
Surface Sample Lead Testing Armory 

Survey Date: May 16, 2014 Sioux Falls, SD 

A-7

Laboratory Result Reports and Chain of Custody Sheets

BEST AVAILABLE COPY BEST AVAILABLE COPY FOIA Requested Record #J-15-0085 (SD) 

Released by National Guard Bureau 

Page 20 of 24