National Guard Bureau 

Mid-West Regional Industrial Hygiene Office 

301-IH Old Bay Lane 

Havre de Grace, MD 21078 

ARNG-CSG-P June 17, 2015 

MEMORANDUM FOR: The Adjutant General for Minnesota 

SUBJECT: Industrial Hygiene Survey at Northfield Armory, Northfield, Minnesota 

At the request of the National Guard Bureau (NGB) Mid-West Regional Industrial Hygiene (IH) Office, 

 Certified Industrial Hygienist (CIH), conducted a survey on May 8, 2015 at the Minnesota 

Army National Guard Northfield Armory, 519 Division, Northfield, Minnesota. The site point of contact 

was 

The NGB conducted this survey in the interest of preventing employee illness and in meeting legal 

obligations where applicable. Based on information provided, every effort was made to conduct a 

comprehensive survey covering the parameters considered. Results and recommendations are based on 

information provided by site personnel, field measurements, and conditions observed during the survey. 

Changes in work practices and/or processes may change employee exposure levels. Use of different 

materials may result in exposure to a different air contaminant. 

Occupational health risk assessment codes (RACs) are assigned to quantify health risks to personnel in 

accordance with 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. RAC descriptors are as follows: 1 = Critical, 2 = Serious, 3 = Moderate, 

4 = Minor, and 5 = Negligible. 

The Northfield Armory was built in 1915, and it has about 25,000 square feet of floor space. The armory 

is the base of operations for 434th Chemical Company. During the week, most of the activities at the 

armory involve administrative work. Site personnel reported that vehicle maintenance activities are 

mostly limited to fluid checks and tire changes on drill weekends, and that no major vehicle maintenance 

is performed at the armory. No vehicle maintenance was performed on the day of the survey. The 

Northfield Armory had an indoor firing range (IFR) that was closed and converted to caged storage. 

Weapons may be cleaned in the vault, in the supply room, or on tables set up on the drill floor. 

The armory is available for rental for community activities that include: birthday parties, wedding 

receptions, and YMCA use. Site personnel reported that the building will be closed in 2015 and sold. The 

industrial hygiene survey included a walkthrough of the facility and interviews with employees. 

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. One of ten of the surface wipe sample results exceeded the guideline for lead. 

A sample collected on the floor near the entrance of the supply office, in the bullet trap area in the former 

IFR, had a lead concentration of 268 μg/ft2. Five of six samples collected in the former IFR had detectable 

levels of lead. The following actions are required:

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Industrial Hygiene Survey Northfield Armory 

Survey date: May 8, 2015 Northfield, MN 

3 

Northfield Armory

Surface Area Wipe Samples

Wipe samples were collected from representative areas of the facility using Environmental Express 

GhostTM Wipes and templates in accordance with the OSHA wipe sampling method (OSHA Technical 

Manual, Appendix II, 2-1). In addition, surface wipe samples were collected in the kitchen to assess 

migration of lead into food handling spaces. The samples were analyzed for lead by OSHA Method ID121. The results and photos are contained in Table 1. 

The Occupational Safety and Health Administration (OSHA) requires that all surfaces must be kept as 

free as practicable of accumulations of toxic metal dusts (29 CFR 1910). 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 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 (BNL) Surface Wipe Sampling 

Procedure (IH75190). Any results that exceed these guidelines, which are shown in Table 1, are 

considered significant. 

One of ten of the surface wipe sample results exceeded the guideline for lead. Sample MNNOW12, which 

was collected on the floor near the entrance of the supply office, in the bullet trap area in the former IFR, 

had a lead concentration of 268 μg/ft2

. Five of six samples collected in the former IFR had detectable 

levels of lead. 

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Industrial Hygiene Survey Northfield Armory 

Survey date: May 8, 2015 Northfield, MN 

4 

Table 1 

Surface Area Wipe Sampling Results for Lead 

Minnesota Army National Guard 

Northfield Armory 

Northfield, Minnesota 

May 8, 2015 

Sample # Location Photo Lead 

(μg/ft2)

Surface Guideline 200

MNNOW11

Supply office, former 

IFR at bullet trap, SE 

corner on floor

96

MNNOW12

Supply office, former 

IFR at bullet trap, near 

entrance on floor

268

MNNOW13

HVAC and storage 

room, former IFR at 

bullet trap, NE corner on 

floor

143

MNNOW14

HVAC and storage 

room, former IFR at 

bullet trap, inside air 

supply duct

83

MNNOW15 Decon 3 storage, former 

IFR midrange, on floor 41

MNNOW16

Common area, former 

IFR at firing line, on 

floor

<10

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Industrial Hygiene Survey Northfield Armory 

Survey date: May 8, 2015 Northfield, MN 

5 

Sample # Location Photo Lead 

(μg/ft2)

Surface Guideline 200

MNNOW17 Drill floor, center <10

MNNOW18 Cold storage, caged 

storage on floor 37

MNNOW19 Maintenance bay, on 

FLS cabinet 58

MNNOW20 Field blank N/A 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. 

Recommendations:

1. Inform potential purchasers of the building that it has lead contamination in the former IFR 

area (RAC 2). 

2. Clean the horizontal surfaces where lead may be present by using high-efficiency particulate air 

(HEPA) filter vacuums or wet methods (RAC 2). 

3. Continue to prohibit the presence of food and drink in work areas and stress the importance of 

hand washing prior to the consumption of food items (RAC 3). 

4. When weapons are cleaned, special attention should be given to cleaning up the work area to 

prevent potential lead contamination from ammunition (RAC 2). 

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National Guard Bureau 

Mid-West Regional Industrial Hygiene Office 

301-IH Old Bay Lane 

Havre de Grace, MD 21078 

ARNG-CSG-P June 16, 2015 

MEMORANDUM FOR: The Adjutant General for Minnesota 

SUBJECT: Industrial Hygiene Survey at Rochester Armory, Rochester, Minnesota 

At the request of the National Guard Bureau (NGB) Mid-West Regional Industrial Hygiene (IH) Office, 

, Certified Industrial Hygienist (CIH), conducted a survey on April 29, 2015 at the 

Minnesota Army National Guard Rochester Armory, 1715 SE Marion Road, Rochester, Minnesota. The 

site points of contact were 

The NGB conducted this survey in the interest of preventing employee illness and in meeting legal 

obligations where applicable. Based on information provided, every effort was made to conduct a 

comprehensive survey covering the parameters considered. Results and recommendations are based on 

information provided by site personnel, field measurements, and conditions observed during the survey. 

Changes in work practices and/or processes may change employee exposure levels. Use of different 

materials may result in exposure to a different air contaminant. 

Occupational health risk assessment codes (RACs) are assigned to quantify health risks to personnel in 

accordance with 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. RAC descriptors are as follows: 1 = Critical, 2 = Serious, 3 = Moderate, 

4 = Minor, and 5 = Negligible. 

The Rochester Armory was built in 1979 and has about 33,309 square feet of floor space. The armory is 

the base of operations for Bravo Company 2-135th IN and 7212th Army Reserve Medics. During the week, 

most of the activities at the armory involve administrative work. Site personnel reported that vehicle 

maintenance activities are mostly limited to fluid checks and tire changes on drill weekends, and that no 

major vehicle maintenance is performed at the armory. No vehicle maintenance was performed on the day 

of the survey. The Rochester Armory had an indoor firing range that was closed and converted to unit 

storage in 2008. Weapons may be cleaned in the vault, in the supply room, or on tables set up on the drill 

floor. 

The armory is available for rental for community activities that include: children and adult soccer practice 

and a remote control aircraft flying club that uses the drill floor to fly their model airplanes. The industrial 

hygiene survey included a walkthrough of the facility and interviews with employees. 

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. None of the surface wipe sample results exceeded the guideline for 

lead. The following actions are required:

 Clean the horizontal surfaces where lead may be present using high-efficiency particulate air 

(HEPA) filter vacuums or wet methods (RAC 2). 

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Industrial Hygiene Survey Rochester Armory 

Survey date: April 29, 2015 Rochester, MN 

3 

Rochester Armory

Surface Area Wipe Samples 

Wipe samples were collected from representative areas of the facility using Environmental Express 

GhostTM Wipes and templates in accordance with the OSHA wipe sampling method (OSHA Technical 

Manual, Appendix II, 2-1). In addition, surface wipe samples were collected in the kitchen to assess 

migration of lead into food handling spaces. The samples were analyzed for lead by OSHA Method ID121. The results and photos are contained in Table 1. 

The Occupational Safety and Health Administration (OSHA) requires that all surfaces must be kept as 

free as practicable of accumulations of toxic metal dusts (29 CFR 1910). 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 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 (BNL) Surface Wipe Sampling 

Procedure (IH75190). Any results that exceed these guidelines, which are shown in Table 1, are 

considered significant. None of the surface wipe sample results exceeded the guideline for lead. 

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

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Industrial Hygiene Survey Rochester Armory 

Survey date: April 29, 2015 Rochester, MN 

4 

Table 1 

Surface Area Wipe Sampling Results for Lead 

Minnesota Army National Guard 

Rochester Armory 

Rochester, Minnesota 

April 29, 2015 

Sample # Location Photo Lead 

(μg/ft2)

Surface Guideline 200

MNROAW21 Vault 711, on floor 39

MNROAW22

Unit storage, former IFR 

at firing line, SE by 

entrance on floor

54

MNROAW23

Unit storage, former IFR 

at firing line, center of 

room on floor

37

MNROAW24

3

rd Platoon training 

room, former IFR 

midrange, on floor

16

MNROAW25

2

nd Platoon training 

room, former IFR 

midrange, on floor

25

MNROAW26

1

st Platoon training 

room, former IFR at 

bullet trap, near entrance 

on floor

61

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5 

Sample # Location Photo Lead 

(μg/ft2)

Surface Guideline 200

MNROAW27

1

st Platoon training 

room, former IFR at 

bullet trap, center of 

room on floor

51

MNROAW28 Drill floor, center on 

floor <10

MNROAW29 Kitchen, on top of 

canopy hood above stove <10

MNROAW30 Orderly room, on 

desktop <10

MNROAW31 Field blank N/A 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. 

Recommendations:

1. Clean the horizontal surfaces where lead may be present by using high-efficiency particulate 

air (HEPA) filter vacuums or wet methods (RAC 2). 

2. Continue to prohibit the presence of food and drink in work areas and stress the importance 

of hand washing prior to the consumption of food items (RAC 3). 

3. When weapons are cleaned, special attention should be given to cleaning up the work area to 

prevent potential lead contamination from ammunition (RAC 2). 

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National Guard Bureau 

Mid-West Regional Industrial Hygiene Office 

301-IH Old Bay Lane 

Havre de Grace, MD 21078 

ARNG-CSG-P June 16, 2015 

MEMORANDUM FOR: The Adjutant General for Minnesota 

SUBJECT: Industrial Hygiene Survey at Rosemount Armory, Rosemount, Minnesota 

At the request of the National Guard Bureau (NGB) Mid-West Regional Industrial Hygiene (IH) Office, 

, Certified Industrial Hygienist (CIH), conducted a survey on April 30, 2015 at the 

Minnesota Army National Guard Rosemount Armory, 13865 Robert Trail, Rosemount, Minnesota. The 

site point of contact was . 

The NGB conducted this survey in the interest of preventing employee illness and in meeting legal 

obligations where applicable. Based on information provided, every effort was made to conduct a 

comprehensive survey covering the parameters considered. Results and recommendations are based on 

information provided by site personnel, field measurements, and conditions observed during the survey. 

Changes in work practices and/or processes may change employee exposure levels. Use of different 

materials may result in exposure to a different air contaminant. 

Occupational health risk assessment codes (RACs) are assigned to quantify health risks to personnel in 

accordance with 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. RAC descriptors are as follows: 1 = Critical, 2 = Serious, 3 = Moderate, 

4 = Minor, and 5 = Negligible. 

The Rosemount Armory was built in 1994 and has about 140,000 square feet of floor space. The 

MNARNG occupies about 96,000 square feet of the floor space, and the balance is leased by the city of 

Rosemount for use as a community center. The armory is the base of operations for Alpha and Bravo 

Company DHHB; 34th ID Band; and RSP. During the week, most of the activities at the armory involve 

administrative work. Site personnel reported that vehicle maintenance activities are mostly limited to fluid 

checks and tire changes on drill weekends, and that no major vehicle maintenance is performed at the 

armory. No vehicle maintenance was performed on the day of the survey. Site personnel reported that the 

Rosemount Armory had an indoor firing range that was closed in 2000 and converted to classrooms in 

2006. Weapons may be cleaned in the vault, in the supply room, or on tables set up on the drill floor. 

The armory is available for rental for community activities that include: teen night; weekly elementary 

and junior high school sports practice; and weekly toddler time activities for children ages 2-4. The 

industrial hygiene survey included a walkthrough of the facility and interviews with employees. 

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. None of the surface wipe sample results exceeded the guideline for 

lead. The following actions are required:

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Industrial Hygiene Survey Rosemount Armory 

Survey date: April 30, 2015 Rosemount, MN 

3 

Rosemount Armory

Surface Area Wipe Samples 

Wipe samples were collected from representative areas of the facility using Environmental Express 

GhostTM Wipes and templates in accordance with the OSHA wipe sampling method (OSHA Technical 

Manual, Appendix II, 2-1). In addition, surface wipe samples were collected in the kitchen to assess 

migration of lead into food handling spaces. The samples were analyzed for lead by OSHA Method ID121. The results and photos are contained in Table 1. 

The Occupational Safety and Health Administration (OSHA) requires that all surfaces must be kept as 

free as practicable of accumulations of toxic metal dusts (29 CFR 1910). 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 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 (BNL) Surface Wipe Sampling 

Procedure (IH75190). Any results that exceed these guidelines, which are shown in Table 1, are 

considered significant. None of the surface wipe sample results exceeded the guideline for lead. 

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

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Industrial Hygiene Survey Rosemount Armory 

Survey date: April 30, 2015 Rosemount, MN 

4 

Table 1 

Surface Area Wipe Sampling Results for Lead 

Minnesota Army National Guard 

Rosemount Armory 

Rosemount, Minnesota 

April 30, 2015 

Sample # Location Photo Lead 

(μg/ft2)

Surface Guideline 200

MNRSAW1 Room #221, 34th ID 

Band room, on table top <10

MNRSAW2 Auditorium, on stage <10

MNRSAW3 Gym/Drill floor, center 

on floor <10

MNRSAW4 Gym/Drill floor, 

northeast corner on floor <10

MNRSAW5 Kitchen, on Cres Cor 

food warmer <10

MNRSAW6

Server room, former 

IFR, at bullet trap, on 

floor

<10

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Industrial Hygiene Survey Rosemount Armory 

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5 

Sample # Location Photo Lead 

(μg/ft2)

Surface Guideline 200

MNRSAW7 Alpha company vault, on 

floor 33

MNRSAW8

Room #167, Language 

lab foyer office, former 

IFR, at firing line, on 

floor

<10

MNRSAW9

Language lab testing 

room, former IFR, at 

firing line, on desktop

<10

MNRSAW10

Language lab, former 

IFR, midrange, on 

desktop

<10

MNRSAW11 Field blank N/A 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. 

Recommendations:

1. Clean the horizontal surfaces where lead may be present by using high-efficiency particulate 

air (HEPA) filter vacuums or wet methods (RAC 2). 

2. Continue to prohibit the presence of food and drink in work areas and stress the importance 

of hand washing prior to the consumption of food items (RAC 3). 

3. When weapons are cleaned, special attention should be given to cleaning up the work area to 

prevent potential lead contamination from ammunition (RAC 2). 

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National Guard Bureau 

Mid-West Regional Industrial Hygiene Office 

301-IH Old Bay Lane 

Havre de Grace, MD 21078 

ARNG-CSG-P December 16, 2013 

MEMORANDUM FOR: The Adjutant General for Minnesota 

SUBJECT: Industrial Hygiene Survey at Stillwater Armory, Stillwater Minnesota 

At the request of the National Guard Bureau (NGB) Mid-West Regional Industrial Hygiene (IH) Office, 

, Certified Industrial Hygienist (CIH), conducted a survey on December 11, 2013 at the 

Minnesota Army National Guard Stillwater Armory in Stillwater, MN. The site point of contact was 

The NGB conducted this survey in the interest of preventing employee illness and in meeting legal 

obligations where applicable. Based on information provided, every effort was made to conduct a 

comprehensive survey covering the parameters considered. Results and recommendations are based on 

information provided by site personnel, field measurements, and conditions observed during the survey. 

Changes in work practices and/or processes may change employee exposure levels. Use of different 

materials may result in exposure to a different air contaminant. 

Occupational health risk assessment codes (RACs) are assigned to quantify health risks to personnel in 

accordance with 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. RAC descriptors are as follows: 1 = Critical, 2 = Serious, 3 = Moderate, 4 

= Minor, and 5 = Negligible. 

The Stillwater armory had an indoor firing range (IFR) that was closed and converted to a storage area. 

The IFR was located in the basement of the building. During the conversion, the IFR was redesigned to 

serve as an air plenum and mixing chamber for outside air that is supplied to the basement. Outside air is 

delivered to the IFR by a fan and sheet metal duct. The sheet metal duct blows air into the IFR, where it 

mixes with the air in the room. An overhead dehumidifier unit draws the mixed air from the room and it is 

then transported by ductwork to offices and storage areas in the basement. 

This survey was requested as a follow up to a previous survey performed on November 18, 2013 that 

identified lead dust on surfaces in the former IFR, offices and storage areas in the basement. That survey 

identified lead dust on the floor of the former IFR that ranged up to 11,214 ug/ft2. 

The armory is available for rental for community activities that include: volleyball for girls and boys aged 

12 to 14; basketball for adults; gymnasium activities for kindergarten through high school students; 

antique shows; gun shows; and craft shows. The industrial hygiene survey included a walkthrough of the 

facility, air sampling for lead and interviews with employees. 

On the day of the survey, the basement areas were designated a restricted area, and no personnel were 

working in the basement. Materials stored in the IFR had been removed and relocated to a different 

storage room in the basement. The supply sergeant who worked in the supply room in the basement had 

been relocated to an office on the first floor of the armory. 

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Industrial Hygiene Survey Stillwater Armory 

Survey Date: December 11, 2013 Stillwater, MN 

Appendix Title Status

A. Lead – Air and Bulk Sampling Attached

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Survey date: December 11, 2013 Stillwater, MN 

A-1

Appendix A

Air and Bulk Sampling for Lead 

Air Samples 

Portable air sampling pumps were used to collect area samples. SKC air sampling pumps (Universal XR 

Pump Model PCXR8) were calibrated with a primary airflow meter (BIOS Defender 510-M) before and 

after each sample was collected. SKC 37-millimeter cassettes with 0.8-micron mixed cellulose ester 

(MCE) filters were used to collect the air samples which were analyzed for lead by OSHA Method ID121. 

The Stillwater armory had an indoor firing range (IFR) that was closed and converted to a storage area. 

The IFR was located in the basement of the building (Figure 1). During the conversion, the IFR was 

redesigned to serve as an air plenum and mixing chamber for outside air that is supplied to the basement. 

Outside air is delivered to the IFR by a fan and sheet metal duct (Figures 2 and 3). The sheet metal duct 

blows air into the IFR, where it mixes with the air in the room. An overhead dehumidifier unit (Figure 4) 

draws the mixed air from the room and it is then transported by ductwork to offices and storage areas in 

the basement. 

This survey was requested as a follow up to a previous survey performed on November 18, 2013 that 

identified lead dust on surfaces in the former IFR, offices and storage areas in the basement. That survey 

identified lead dust on the floor of the former IFR that ranged up to 11,214 ug/ft2. 

On the day of the survey, the basement areas were designated a restricted area, and no personnel were 

working in the basement. Materials stored in the IFR had been removed and relocated to a different 

storage room in the basement (Figure 5). The supply sergeant who worked in the supply room in the 

basement had been relocated to an office on the first floor of the armory. 

The armory is available for rental for community activities that include: volleyball for girls and boys aged 

12 to 14 (Figure 6); basketball for adults; gymnasium activities for kindergarten through high school 

students; antique shows; gun shows; and craft shows. 

Area air samples were collected in four rooms in the basement and analyzed for lead. The samples were 

collected in the former IFR (room B14); the supply office (room B12); the kitchen storage area (room 

B11); and the QRF area (room B9). Air sampling results were compared to the applicable OSHA 

Permissible Exposure Limit (PEL). The results are contained in Table A-1. The air sample results were 

below the limit of detection for lead. 

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Industrial Hygiene Survey Stillwater Armory 

Survey date: December 11, 2013 Stillwater, MN 

A-2

Table A-1 

Area Air Sampling Results for Lead 

Minnesota Army National Guard 

Stillwater Armory 

Stillwater, MN 

December 11, 2013 

Location Work 

Activity Sample # Sample Volume(L)

Lead

(mg/m3)

OSHA PEL-TWA 0.05

Room B14, Former Indoor Firing Range, 

5 feet above floor level, door to hallway 

closed

None MSM1 1,737.2 <0.01

Room B12, Supply Office, 5 feet above 

floor level, door to hallway open

None

MSM2 1,744

<0.01

Room B11, Kitchen Storage, 5 feet above 

floor level, door to hallway open

None

MSM3 1,740

<0.01

Room B9, QRF Room, 5 feet above floor 

level, door to hallway open

None

MSM4 1,739.6

<0.01

Field Blank N/A MSM5 N/A ND

Notes: 1) L = liters. 2) mg / m3= milligrams per cubic meter. 3) ND = none detected. 4) “<” means less than the 

reporting limit for the analytical method. 

Bulk Samples 

An overhead dehumidifier unit in the former IFR draws mixed air from the room which is then 

transported by ductwork to offices and storage areas in the basement. The dehumidifier in the former IFR 

was equipped with pleated air filters which are used to filter mixed air in the IFR plenum before it is 

transported by the ductwork. The pleated air filters were dirty. Site personnel could not provide 

information regarding the last time the air filters had been changed and replaced. 

The pleated air filters were not high efficiency particulate air (HEPA) filters. Commercially available 

pleated air filters are designed to remove relatively large airborne particles. They are not designed to 

remove respirable dusts, which will penetrate them. A pleated air filter was removed and sent to the 

laboratory for bulk analysis for lead. An unused pleated air filter was also sent to the laboratory and 

analyzed as a field blank, or control bulk sample. The results are contained in Table A-2. 

The laboratory analysis for the used pleated air filter indicated that lead was present at a concentration of 

147 mg/kg. This result indicates a history of airborne lead in the former IFR. Lead on the floor surfaces in 

the IFR, designing the IFR to serve as an outdoor air mixing plenum, storing materials in the room, and 

retrieving materials from the room may cause lead to become airborne. No lead should be present in the 

air or on the pleated air filter, so the levels of lead detected are significant. 

Since the former IFR is used as a mixing plenum, it is likely that airborne lead particles that are smaller 

than the removal characteristics of the pleated filter have been transported to other areas in the basement. 

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Industrial Hygiene Survey Stillwater Armory 

Survey date: December 11, 2013 Stillwater, MN 

A-3

Removal and use of materials that were stored in the former IFR may also lead to lead contamination in 

other areas. 

Table A-2 

Bulk Sampling Results for Lead 

Minnesota Army National Guard 

Stillwater Armory 

Stillwater, MN 

December 11, 2013 

Location Sample # Lead

(mg/kg)

Used HVAC filter removed from dehumidifier in Room 

B14 MSB1 147

Unused HVAC filter stored in a box in Room B14 – field 

blank MSB2 <50

Notes: 1) mg / kg = milligrams per kilogram 2) “<” means less than the reporting limit for the analytical method.

Recommendations:

1. Decontaminate the IFR and all of the materials that were stored in the IFR in accordance with NG 

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

(RAC 2). 

2. Coordinate the cleanup of the former indoor firing range and basement areas with the National 

Guard Bureau (NGB) Mid-West Regional Industrial Hygiene (IH) Office (RAC 2). 

3. Ensure that the National Guard Bureau (NGB) Mid-West Regional Industrial Hygiene (IH) Office 

reviews the scope and manner of the lead remediation project (RAC 2). 

4. Ensure that the supply sergeant remains in offices on the first floor until the basement has been 

decontaminated (RAC 2). 

5. Provide area air sampling results to personnel who work in the armory (RAC 3). 

6. Continue to prohibit the presence of food and drink in work areas and stress the importance of hand 

washing prior to the consumption of food items (RAC 3). 

7. When weapons are cleaned, special attention should be given to cleaning up the work area to 

prevent potential lead contamination from ammunition (RAC 3). 

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Industrial Hygiene Survey Stillwater Armory 

Survey date: December 11, 2013 Stillwater, MN 

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Figure 1 – Diagram for Basement Areas in Stillwater Armory 

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Figure 2 – Fan and Sheet Metal Duct that Provide Outside Air to Former IFR 

Figure 3 – Fan and Sheet Metal Duct that Provide Outside Air to Former IFR 

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Figure 4 – Overhead Dehumidifier in Former IFR 

Figure 5 - Stored Materials that Were Recently Removed from the Former IFR 

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Figure 6 – Girls Volleyball Team Practice in Stillwater Armory 

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National Guard Bureau 

Mid-West Regional Industrial Hygiene Office 

301-IH Old Bay Lane 

Havre de Grace, MD 21078 

ARNG-CSG-P June 17, 2015 

MEMORANDUM FOR: The Adjutant General for Minnesota 

SUBJECT: Industrial Hygiene Survey at Willmar Armory, Willmar, Minnesota 

At the request of the National Guard Bureau (NGB) Mid-West Regional Industrial Hygiene (IH) Office, 

, Certified Industrial Hygienist (CIH), conducted a survey on May 6, 2015 at the Minnesota 

Army National Guard Willmar Armory, 614 North Highway 71, Willmar, Minnesota. The site point of 

contact was 

The NGB conducted this survey in the interest of preventing employee illness and in meeting legal 

obligations where applicable. Based on information provided, every effort was made to conduct a 

comprehensive survey covering the parameters considered. Results and recommendations are based on 

information provided by site personnel, field measurements, and conditions observed during the survey. 

Changes in work practices and/or processes may change employee exposure levels. Use of different 

materials may result in exposure to a different air contaminant. 

Occupational health risk assessment codes (RACs) are assigned to quantify health risks to personnel in 

accordance with 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. RAC descriptors are as follows: 1 = Critical, 2 = Serious, 3 = Moderate, 

4 = Minor, and 5 = Negligible. 

Site personnel reported that the Willmar Armory was built in the 1950s. The armory is the base of 

operations for FSC 682nd, HHC 682nd, and Battalion HQ 682nd. During the week, most of the activities at 

the armory involve administrative work. Site personnel reported that vehicle maintenance activities are 

mostly limited to fluid checks and tire changes on drill weekends, and that no major vehicle maintenance 

is performed at the armory. No vehicle maintenance was performed on the day of the survey. 

Site personnel reported that the Willmar Armory had an indoor firing range (IFR) that was closed and 

converted to storage. No overhead or original ventilation remained from the former IFR. The concrete 

floor in the former IFR had been painted, and the paint was damaged in some areas. Weapons may be 

cleaned in the vault, in the supply room, or on tables set up on the drill floor. 

The armory is available for rental for community activities that include: child and teen dance classes, teen 

boxing classes, youth and adult martial arts classes, Cub Scout meetings and sleepovers, birthday parties, 

and wedding receptions. The industrial hygiene survey included a walkthrough of the facility and 

interviews with employees. 

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. Six of the nine surface wipe sample results exceeded the guideline for lead. All 

of these samples were located in the former IFR area. 

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Willmar Armory

Surface Area Wipe Samples

Wipe samples were collected from representative areas of the facility using Environmental Express 

GhostTM Wipes and templates in accordance with the OSHA wipe sampling method (OSHA Technical 

Manual, Appendix II, 2-1). In addition, surface wipe samples were collected in the kitchen to assess 

migration of lead into food handling spaces. The samples were analyzed for lead by OSHA Method ID121. The results and photos are contained in Table 1. 

Site personnel reported that the Willmar Armory had an indoor firing range (IFR) that was closed and 

converted to storage. No overhead or original ventilation remained from the former IFR. The concrete 

floor in the former IFR had been painted, and the paint was damaged in some areas. 

The Occupational Safety and Health Administration (OSHA) requires that all surfaces must be kept as 

free as practicable of accumulations of toxic metal dusts (29 CFR 1910). 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 (BNL) Surface Wipe Sampling 

Procedure (IH75190). Any results that exceed these guidelines, which are shown in Table 1, are 

considered significant. 

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Six of the surface wipe sample results exceeded the guideline for lead. All of these samples were located 

in the former IFR area. 

Sample MNWIAW3, which was collected on the floor in the HHC caged storage #1, at the firing line in 

the former IFR, had a lead concentration of 2,475 μg/ft2. Sample MNWIAW4, which was collected on the 

floor of the corridor in the caged storage area near the entrance, at the firing line in the former IFR, had a 

lead concentration of 1,693 μg/ft2. Sample MNWIAW5, which was collected on the floor in the FSC 

caged storage area #4, midrange in the former IFR, had a lead concentration of 1,585 μg/ft2. Sample 

MNWIAW6, which was collected on the floor of the caged storage area corridor, midrange in the former 

IFR, had a lead concentration of 1,805 μg/ft2. Sample MNWIAW7, which was collected on the floor in 

the FSC caged storage area #6, at the bullet trap in the former IFR, had a lead concentration of 2,587 

μg/ft2. Sample MNWIAW8, which was collected on the floor in the HHC caged storage area #7, at the 

bullet trap in the former IFR, had a lead concentration of 8,370 μg/ft2. 

Table 1 

Surface Area Wipe Sampling Results for Lead 

Minnesota Army National Guard 

Willmar Armory 

Willmar, Minnesota 

May 6, 2015 

Sample # Location Photo Lead 

(μg/ft2)

Surface Guideline 200

MNWIAW1 Drill floor, center on 

floor <10

MNWIAW2 Kitchen, on food prep 

table counter top <10

MNWIAW3

Storage, former IFR at 

firing line, inside HHC 

caged storage area #1

2,475

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Sample # Location Photo Lead 

(μg/ft2)

Surface Guideline 200

MNWIAW4

Storage, former IFR at 

firing line, corridor by 

entrance on floor

1,693

MNWIAW5

Storage, former IFR 

midrange, inside FSC 

caged storage area #4 on 

floor

1,585

MNWIAW6

Storage, former IFR 

midrange, corridor on 

floor

1,805

MNWIAW7

Storage, former IFR at 

bullet trap, inside FSC 

caged storage area #6 on 

floor

2,587

MNWIAW8

Storage, former IFR at 

bullet trap, inside HHC 

caged storage area #7

8,370

MNWIAW9

Room #105, Supply 

room, in front of vault 

entrance on floor

48

MNWIAW10 Field blank N/A 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. 

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Recommendations:

1. The closed indoor firing range should be cleaned up as specified by the procedures contained 

in NG PAM 420-15 Guidelines and Procedures for Rehabilitation and Conversion of Indoor 

Firing Ranges. Residual lead contamination of surfaces must be less than 200 ug/ft2. (RAC 2) 

2. Clean the horizontal surfaces where lead may be present by using high-efficiency particulate 

air (HEPA) filter vacuums or wet methods (RAC 2). 

3. Continue to prohibit the presence of food and drink in work areas and stress the importance 

of hand washing prior to the consumption of food items (RAC 3). 

4. When weapons are cleaned, special attention should be given to cleaning up the work area to 

prevent potential lead contamination from ammunition (RAC 2). 

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National Guard Bureau 

Mid-West Regional Industrial Hygiene Office 

301-IH Old Bay Lane 

Havre de Grace, MD 21078 

ARNG-CSG-P October 3, 2013 

MEMORANDUM FOR: The Adjutant General for Minnesota 

SUBJECT: Industrial Hygiene Survey at Old Faribault Armory, Faribault, Minnesota 

At the request of the National Guard Bureau (NGB) Mid-West Regional Industrial Hygiene (IH) 

Office, , Certified Industrial Hygienist (CIH), conducted a survey on July 30, 2013 

at the Minnesota Army National Guard Old Faribault Armory, 2831 Park Avenue NW, Faribault, 

Minnesota. The site points of contact were . 

The NGB conducted this survey in the interest of preventing employee illness and in meeting 

legal obligations where applicable. Based on information provided, every effort was made to 

conduct a comprehensive survey covering the parameters considered. Results and 

recommendations are based on information provided by site personnel, field measurements, 

and conditions observed during the survey. Changes in work practices and/or processes may 

change employee exposure levels. Use of different materials may result in exposure to a 

different air contaminant. 

The Old Faribault Armory was built in 1979 and has been closed for about 3 to 4 years. The 

MNARNG is considering reopening the building, and requested a building survey to help to 

assess the condition of the building. The MNARNG requested an evaluation of toxic metals on 

surfaces, and a visual inspection for mold and suspect asbestos containing materials. 

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. RAC descriptors are as 

follows: 1 = Critical, 2 = Serious, 3 = Moderate, 4 = Minor, and 5 = Negligible. 

Wipe samples were collected on representative surfaces in the facility and analyzed for toxic 

metals (lead, cadmium, and chromium). Two bulk samples of damaged paint were also 

collected from a wall on the drill floor and analyzed for toxic metals. The building had an indoor 

firing range (IFR) that had been closed and converted to a storage area. Site personnel could 

not provide information regarding when the IFR had been closed. For purposes of this report, 

any results that exceed the guidelines adopted by the NGB Mid-West Regional IH Office are 

considered significant. Seven of the surface wipe sample results exceeded the guideline for 

lead and cadmium. The results indicated that lead from the IFR and vault had spread to the drill 

floor and, potentially, other parts of the building. The following actions are required:

• Perform follow up surface wipe sampling to determine all of the lead 

contamination in the building. Identify the spread and extent of lead 

contamination from the former IFR (RAC 2). 

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Survey Date: July 30, 2013 Faribault, Minnesota 

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Appendix A

Metals 

Surface Wipe Samples 

Wipe samples were collected from the former IFR and 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). In addition, a surface wipe sample was collected in 

the kitchen to assess migration of toxic metals into food handling spaces. The samples were 

analyzed for toxic metals 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, 

the 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 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 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 (BNL) Surface 

Wipe Sampling Procedure (IH75190). Any results that exceed these guidelines shown in Table 

A-1 are considered significant. Seven results exceeded these guidelines. Sample MNF1, which 

was collected in the firing line area, in former IFR, had a lead concentration of 235 μg/ft2

. 

Sample MNF2, which was collected 20 feet downrange, in the former IFR, had a lead 

concentration of 807 μg/ft2

. Sample MNF3, which was collected 40 feet downrange, in the 

former IFR, had a lead concentration of 249 μg/ft2

. Sample MNF5, which was collected at the 

bullet trap, southwest corner, in the former IFR, had a lead concentration of 7,998 μg/ft2 and a 

cadmium concentration of 29 μg/ft2

. Sample MNF6, which was collected in the northwest corner, 

in the former IFR, had a lead concentration of 6,436 μg/ft2

. Sample MNF7, which was collected 

on the drill floor, in the former IFR, had a lead concentration of 235 μg/ft2

. Sample MNF8, which 

was collected on the floor in the vault had a lead concentration of 1,479 μg/ft2 and a cadmium 

concentration of 550 μg/ft2

. The results indicated that lead from the IFR and vault had spread to 

the drill floor and, potentially, other parts of the building. 

Bulk Paint Samples 

Two bulk samples of damaged paint on the wall of the drill floor were collected and analyzed for 

toxic metals. The Department of Housing and Urban Development (HUD) guideline for lead 

containing paint is 0.5% lead by weight, or 5 milligrams per gram (5 mg/g). The results and 

photos are contained in Table A-2. Both of the samples were below the HUD guideline. 

Recommendations:

1. Perform follow up surface wipe sampling to determine the extent of lead contamination in 

the building (RAC 2). 

2. Clean the surfaces of lead contaminated areas using high-efficiency particulate air (HEPA) 

filter vacuums or wet methods (RAC 2). 

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Industrial Hygiene Survey Old Faribault Armory 

Survey Date: July 30, 2013 Faribault, Minnesota 

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Industrial Hygiene Survey Old Faribault Armory 

Survey Date: July 30, 2013 Faribault, Minnesota 

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Appendix B 

Lighting 

Illumination levels were measured with a Sper Scientific 840022 Broad Range Lux/FC Meter 

calibrated according to the manufacturer’s specifications. The results were compared with the 

recommendations in the National Guard Bureau Facility Design Guides and the American 

National Standards Institute/Illuminating Engineering Society of North America RP-1 (Offices) 

and RP-7 (Industrial Facilities) guidelines. The results and the lighting criteria are contained in 

Table B-1. Twelve spaces in the facility did not meet the minimum lighting level. 

Recommendations:

1. Increase the illumination levels in the facility areas that did not meet minimum illumination 

requirements (RAC 4). 

Table B-1 

Lighting Measurements 

Minnesota Army National Guard, Old Faribault Armory, Faribault MN 

July 30, 2013 

Locations Measured Illumination

(foot candles) 

Required Illumination 

(foot candles) 

Standard 

Met? 

Room 103, Orderly Room 48-52 50 Partial 

Room 104, Company Office 38-68 50 Partial 

Room 105, Recruiter Office 38-43 50 No 

Room 106, Training 26-38 50 No 

Male Latrine 22-36 30 Partial 

Female Latrine 36-40 30 Yes 

Storage 23-35 30 Partial 

Classroom 39-41 50 No 

Locker Room 32-36 30 Yes 

Male Shower 5-7 30 No 

Supply Room 17-23 30 No 

Vault 2-5 30 No 

Drill Floor Not Functional 30 No 

Boiler Room 9-11 30 No 

Firing Range 4-18 50 No 

Kitchen 28-48 50 No 

Pantry 6-13 30 No 

Maintenance Room 39-77 50 Partial 

Hazardous Waste Room Not Functional 30 No 

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Appendix C 

Visual Inspection of Building

The Old Faribault Armory was built in 1979 and has been closed for about 3 to 4 years. The 

MNARNG is considering reopening the building, and requested a building survey to help to 

assess the condition of the building. The MNARNG requested a visual inspection for mold, lead 

paint and suspected asbestos containing materials. The NGB requested background 

information regarding previous surveys for these materials. , Environmental 

Specialist for the MNARNG, reported that he could not locate any records of surveys for the 

presence of asbestos, lead paint or mold in the Old Faribault Armory. 

Visual Identification of Water Leaks and Mold 

A walk through of the building identified visual evidence of water leaks and mold in several 

areas. Table C-1 indicates locations of water leaks and mold. A thorough roof inspection should 

be performed and all existing roof leaks should be repaired. All water and mold damaged 

materials should be cleaned up or replaced. 

Table C-1 

Visual Inspection for Water Leaks and Mold 

Minnesota Army National Guard, Old Faribault Armory, Faribault MN 

July 30, 2013 

Location/Description Photo 

Water leaks/mold on North wall and 

ceiling tiles, in area where low rooftop 

meets higher rooftop 

Water leaks/mold on North wall and 

ceiling tiles, in area where low rooftop 

meets higher rooftop 

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Location/Description Photo 

Water leaks/mold adjacent to roll up 

door on east side of building 

Water damage on east wall of drill hall, 

bubbling and peeling paint 

Mold/water leaks on ceiling tiles in 

classroom 

Mold/water leaks on ceiling tiles in 

classroom 

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Location/Description Photo 

Black mold beneath water heater in 

kitchen pantry 

Black mold beneath water heater in 

kitchen pantry 

Water damage/mold on ceiling tiles in 

maintenance room 

Water damage/mold on ceiling tiles in 

locker room 

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Location/Description Photo 

Water damage/mold on ceiling tiles in 

supply room 

Visual Identification of Suspect Asbestos Containing Materials 

The reported construction age of the building (1979) suggests that it may have been 

constructed with asbestos containing materials. The building is equipped with an oil fired 

hot water boiler. Most of the visible hot water pipe insulation appeared to be fiberglass. A 

partial list of suspected asbestos containing materials in the building includes; the boiler 

gasket material, roofing materials, suspended ceiling tiles, and floor tiles and mastic. A 

detailed asbestos inspection of all of the building materials in the Old Faribault Armory 

should be performed by a state certified asbestos inspector. 

Underground Storage Tank 

The building is equipped with an oil fired hot water boiler. The boiler may have an 

underground storage tank (UST). The MNARNG should determine whether a UST for the 

boiler fuel is on site. If present, the UST should be evaluated to determine its contents and 

integrity to prevent potential leaks to groundwater.

Heating, Ventilation and Air Conditioning (HVAC) 

The facility engineer provided access to the rooftop HVAC unit. The rooftop air 

conditioning unit was observed to be clean and dry (Figure 1). 

Recommendations:

1. A thorough roof inspection should be performed and all existing roof leaks should be 

repaired (RAC 2). 

2. All water and mold damaged materials should be cleaned up or replaced (RAC 2). 

3. A detailed asbestos inspection of all of the building materials in the Old Faribault Armory 

should be performed by a state certified asbestos inspector. A partial list of suspected 

asbestos containing materials in the building includes; the boiler gasket material, roofing 

materials, suspended ceiling tiles, and floor tiles and mastic (RAC 2). 

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4. Determine whether a UST for the boiler fuel is on site. If present, the UST should be 

evaluated to determine its contents and integrity to prevent potential leaks to 

groundwater (RAC 2). 

Figure 1 – Rooftop HVAC Unit

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