2_-_Raymond_Land_Port_of_Entry_-_Lead_Dust_Evaluation_dated_October_15_2016.pdf

October 15, 2016

Lead-Dust Evaluation

Raymond Land Port of Entry 1519 Montana 16

Raymond, Montana

Prepared For:

John Kleinschmidt United States General Services Administration

Denver Federal Center - Building 41, Room 240 Denver, Colorado 80225

Pinyon Project No.:

1/16-346-06.8001

October 15, 2016

1519 Montana 16

Prepared For:

John Kleinschmidt United States General Services Administration

Denver Federal Center - Building 41, Room 240 Denver, Colorado 80225

Pinyon Project No.:

1/16-346-06.8001

Prepared by:

Timothy R. Grenier, E.I.T.

Environmental Engineer

____________________for Cynthia Ellwood

PhD, CIH, FAIHA

Reviewed by:

Jeremy Musson Principal

Table of Contents

1. Introduction

1.1 Facility Description

1.2 Survey Intent

2. Methods

3. Results

4. Discussion and Conclusions

5. Remediation Recommendations

6. Limitations

Figures

Figure 1 – Site Layout

Figure 2 – Lead Wipe Sample Locations – Basement Building A

Figure 3 – Lead Wipe Sample Locations – First Floor Building A

Figure 4 – Lead Wipe Sample Locations – Second Floor Building A

Figure 5 – Lead Wipe Sample Locations – First Floor Building B

Figure 6 – Lead Wipe and Soil Sample Locations – First Floor Building C

Figure 7 – Lead Wipe Sample Locations – Basement Building C

Figure 8 – Exterior Soil Sample Location

Figure 9 – Remediation and Lead Wipe Sample Locations – Basement Building C

Figure 10 – Remediation Locations – Firing Range Exhaust System

Appendices

Appendix A Analytical Results Tables

Appendix B Laboratory Report, Chain-of-Custody, and Laboratory Accreditation

Appendix C Photographic Log

Appendix D Background Threshold Values for Inorganics in Montana Soils

Appendix E Indoor Firing Range Design, Operations, & Maintenance Criteria. GSA Public Buildings Service, (April 2002). http://www.gsa.gov/portal/mediaId/121750/fileName/IFR_Criteria_0412.action

Appendix F Indoor Firing Ranges Industrial Hygiene Technical Guide. Navy Environmental Health Center, Technical Manual NEHC–TM6290.99-10 Rev.1, (May 2002)

Raymond, Montana Page 1

1. Introduction

Pinyon Environmental, Inc. (Pinyon), was retained by the United States General Services Administration (GSA) to conduct an evaluation of potential lead-dust contamination at the Raymond Land Port of Entry (LPOE). Pinyon visited the Raymond LPOE on June 16, 17, and 20, 2016, to collect lead-wipe and surface soil samples. The sampling was completed due to the presence of an on-site firing range. Upon firing, lead-based ammunition releases lead dust into the atmosphere. The purpose of this lead survey was to evaluate if lead dust from the firing range is impacting other areas of the facility. Lead can be transported through the building’s heating, ventilation, and air conditioning (HVAC) system, on the person and/or clothing of an individual using the range, and released to the environment through improperly filtered exhaust systems.

1.1 Facility Description

The LPOE facility is comprised of three separate buildings, the Main Port Building (Building A), the Non- Commercial Secondary/Maintenance Garage Building (Building B), and the Commercial Secondary/Firing Range Building (Building C) (Figure 1). Building A is a two-story structure with a basement and is comprised of a mechanical room, office spaces, restrooms, gym, holding cells, and a conference room. Building B is a garage structure used for vehicle maintenance and for non-commercial secondary inspections. Building C is a single-story building with garage. The main level is used for the operations and maintenance office and storage, and the basement houses the firing range, gun cleaning area, ammo storage, and a restroom.

1.2 Survey Intent

The intent of the sampling was to assess the extent, if any, of lead-dust contamination from the indoor firing range to buildings and surrounding grounds. This report includes a complete description of the sampling plan, sample locations, sample methods, laboratory results, survey conclusions and any necessary remediation recommendations.

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2. Methods

Lead-Wipe Sampling

Samples were collected from horizontal surfaces (e.g. desks, tables, and floors), supply air diffusers, return air grilles, exhaust grilles, inside air handling ducts, and other surfaces where lead dust may accumulate. A total of 134 lead-wipe samples (including 12 blanks) were collected on June 16, 17, and 20, 2016 (Figures 2 through 7), by utilizing the following methods:

Samples were collected using laboratory-supplied individually sealed Ghost WipesTM, which are sturdy wiping materials that are moistened with deionized water.

A new, disposable paper template was used to mark off a one foot by one foot (1’ x 1’) area for each sample.

New disposable nitrile gloves were donned prior to collecting each sample. With the clean gloves on, the Ghost Wipe container was opened and the wipe removed.

The test surface area was wiped in an ‘S’ formation from top to bottom, then side to side, and finally the entire outer edge of the area was wiped to collect dust that may have accumulated on the edges of the template.

Once the wiping was completed, the Ghost Wipe was folded multiple times (with the dust surface in) and placed in a laboratory-supplied container.

Samples were submitted to Reservoirs Laboratory (Reservoirs) in Denver, Colorado, in accordance with Pinyon Standard Operating Procedure (SOP) 17, “Chain of Custody Forms/Sample Labeling”, for analyses by National Institute for Occupational Safety and Health (NIOSH) Method 9102 Inductively Coupled Plasma (ICP).

Soil Sampling

One soil sample was collected from the southwest corner of Building C on June 16, 2016 (Figure 2). The sample was collected from firing range exhaust fan discharge area. The sample was collected by placing approximately 50 milliliters (mL) of soil in a laboratory supplied plastic container. The sample was submitted to Reservoirs, in accordance with Pinyon SOP 17, for analyses by Environmental Protection Agency (EPA) method SW846 3050B/6020A.

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3. Results

Lead-Wipe Sampling

A total of 134 lead-wipe samples (including 12 blanks) were collected and submitted to the lab for analysis.

Fifteen of the lead-wipe samples exceeded the GSA limit of 200 micrograms per square foot (ug/ft2), as summarized below (Appendix A, Table 1; Figures 2 through 7):

The following samples exceeded the GSA limit in Building C:

Building C, Room C001: Samples RAY-32, -33, -34, -35, -36, -37, -38, -42, -43, -44, and -45, collected from the firing range

Building C, Room C004: Samples RAY-22, -24, -26, and -27, collected from the Locker/Storage/Work Room/Gun Cleaning area adjacent to the firing range

A low level of lead, 1.6 ug/ft2, was detected in field blank samples RAY-135. Lead was not detected in the remaining 11 field blank samples. Based on the low level detection and the concentration of the exceedances, the result of the blank sample does not appear to have contributed to potential false positive results.

Complete analytical results are presented in Table 1 in Appendix A, and the laboratory analytical reports with chain-of-custodies and laboratory accreditation are included as Appendix B. A photographic log of various sample locations is included as Appendix C.

Soil Sampling

Lead was detected in soil sample RAY-2 at 8.2 milligrams per kilogram (mg/kg) (Table 2 in Appendix A). The Montana Department of Environmental Quality (MDEQ) has conducted extensive surface soil sampling throughout the state and has set a background threshold value (BTV) for lead in soil of 29.8 mg/kg, based on the findings (Appendix D). If soil sample results exceed the BTV, there is a possibility that the lead was introduced through on-site activities. If values are blow the BTV, it is likely that the lead is naturally occurring.

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4. Discussion and Conclusions

The GSA has published a document titled, Indoor Firing Range Design, Operations, and Maintenance Criteria, (April 2012), a copy of which is included in Appendix E.

The criteria document defines two levels of cleaning for firing ranges: routine and comprehensive. Routine cleaning is defined as cleaning that is performed after every use of the firing range. The document states routine cleaning shall include emptying spent slugs from the bullet trap and cleaning all horizontal surfaces within the range.

Comprehensive cleaning is defined as cleaning that shall be performed at least once a year and shall include all surfaces both within the range and in the support areas. The document further states that wipe tests shall be collected and used to verify the effectiveness of comprehensive cleaning. The criteria document states that lead dust levels taken from behind the firing line and in support areas adjacent to the range (including training, storage and HVAC maintenance areas) shall be less than 200 ug/ft2. The GSA criteria document references a Navy Environmental Health Center (NEHC) guide titled, Indoor Firing Ranges Industrial Hygiene Technical Guide as the source of the 200 ug/ft2 surface contamination limit. A copy of the Navy technical guide is included in Appendix F.

The NEHC guidance document states the frequency of comprehensive cleaning is dependent on how heavily the firing range is used. For example, when quarterly qualifying training events involve multiple individuals, a comprehensive cleaning shall occur at the conclusion of the event. Wipe tests shall be collected and used to verify the effectiveness of comprehensive cleaning.

Firing Range, Building C Room C001

During the initial walkthrough at the facility the Operations and Maintenance contractor, Quality Control International (QCI), reported the most recent comprehensive cleaning of the firing range occurred sometime in the first quarter of 2016, and the firing range had been used, to their knowledge, for one training session since the last comprehensive cleaning. Upon inquiry by GSA personnel, Customs and Border Patrol (CBP) reported that the firing range is comprehensively cleaned twice a year. Although the Raymond CBP Port Director indicated the contractor cleaning the firing range does not clean the bullet trap. No information was provided regarding who cleans the bullet trap and at what frequency.

One of five wipe samples collected behind the firing line resulted in lead dust concentrations above the GSA limit of 200 ug/ft2. Ten of eleven wipe samples collected beyond the firing line resulted in lead dust concentrations above the GSA lead dust surface limit. Several of the sample locations beyond the firing line included horizontal surfaces that should be cleaned during routine cleaning (e.g. floor, upper surface of target track). Other sample locations are those that should have been cleaned during comprehensive cleaning (e.g.

upper surface of baffles, ceiling hung unit heater, walls).

The wipe test results taken from horizontal surfaces within the firing range indicate the routine cleaning of horizontal surfaces within the firing range was not effective. Given the high concentrations of some wipe samples beyond the firing line, it can be argued the most recent comprehensive cleaning was not effective.

Based on the results of the lead-dust sampling conducted by Pinyon, the firing range requires lead dust remediation (Figure 8).

In order to be compliant with the GSA criteria document, post ventilation system maintenance cleaning should also be performed on the exhaust system. The scope of the cleaning, according to GSA criteria, shall include all horizontal surfaces within the firing range and cleaning of all HVAC areas. To be consistent with the GSA criteria document regarding cleaning of the ventilation system after maintenance is performed, it seems reasonable to include the exhaust system in the lead remediation scope of work (Figure 9).

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Firing Range Support Spaces, Building C Room C004

Located adjacent to the firing range are support areas which, in an open floor plan, include the armory, lockers, storage, and work area. A single bathroom is also in the immediate area. The HVAC system does not supply air to this space. Heating is provided through the use of one electric powered ceiling hung heater mounted in the southeast corner, and a wall mounted electric heater in the bathroom. No cooling is provided. The bathroom has a single exhaust fan.

Wipe sample results indicate cross-contamination from the firing range to the adjacent support spaces. Lead dust contaminated surfaces include the bottom surface of the dumbwaiter, upper surface of lockers, and the floor. Since the accumulation of lead dust on the upper surface of the lockers contained lead dust at the concentration of 1,321 ug/ft2, one can argue settled dust on horizontal surfaces in the support space contains lead dust of similar concentration.

Based on the results of the lead-dust sampling conducted by Pinyon, tead dust remediation is required for the dumbwaiter, floors including at the top of the stairs and the steps, and on horizontal surfaces with visible dust, including the ceiling hung heater (Figure 8).

Soil Samples

One soil sample was collected from under the exhaust fan louver. The soil sample resulted in a lead concentration less than the MDEQ BTV for lead in soil at 29.8 mg/kg. No additional actions are warranted regarding the soil at this location.

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5. Remediation Recommendations

The locations discussed in Section 4 above, Table 1 (in bold font), and Figure 8 require lead contamination remediation in order to achieve compliance with the GSA Indoor Firing Range Design, Operations, and Maintenance Criteria. Section 3 of the GSA criteria document provides limited guidance for comprehensive and/or remediation cleaning protocols. Appendix D of the Navy Environmental Health Center (NEHC) technical guide provides detailed indoor firing range cleaning guidance. GSA requires strict adherence to the NEHC cleaning guidance during remediation activities performed at the site.

Figure 8 is not to scale. It is the remediation contractor’s responsibility to obtain scaled drawings from GSA and to quantify remediation surface areas.

Contractor will submit, in the GSA Quote Document, means and methods to demonstrate compliance of the NEHC guidance document Appendix D.

NEHC Highlights of Remediation Contractor Requirements:

Required Training – Contractors involved with the remediation shall have appropriate training and be competent in following lead-safe work practices, which include three simple procedures:

o Contain the work area o Minimize dust o Clean up thoroughly

Occupational Safety and Health Administration (OSHA) Compliance – Remediation activities shall be performed in a manner that meets applicable OSHA standards.

Equipment Needed for Cleaning – High-efficiency particulate air (HEPA) vacuums and attachments (crevice tools), detergent, waterproof gloves, rags, sponges, mops, buckets, 6-mil plastic bags, debris containers, waste water containers, shovels, rakes, water-misting sprayers, and 6-mil polyethylene plastic sheeting (or equivalent).

Waste Disposal – Regulations governing hazardous and non-hazardous waste storage, transportation, and disposal affect both the daily and final cleaning procedures. The hazard control contractor and the disposal contractor shall work together to establish formal written procedures, specifying selected containers, storage areas, and debris pickups, to ensure that relevant regulations are met. An authorized representative of either GSA or CBP will be designated prior to initiating remediation activities to sign waste manifests and profiles.

Containment – The work area should be properly contained with physical barriers, directional airflow and strict entry/exit procedures for personnel, equipment, and waste.

Basic Cleaning Methods – The typical cleaning method uses a special vacuum cleaner equipped with a HEPA filter, followed by wet washing with special cleaning agents and rinsing, followed by a final pass with the HEPA vacuum. Consideration for an explosion-proof HEPA vacuum is necessary due to the possibility of buildup of unburned powder. The vacuum shall be dedicated for the lead dust cleanup. Dry sweeping or the use of compressed air to "blow down" the range shall be prohibited.

Decontamination of Workers, Supplies, and Equipment – Decontamination is necessary to ensure that worker’s families, other workers, and subsequent properties do not become contaminated. Specific procedures for proper decontamination of equipment, tools, and materials prior to their removal from lead hazard control containment areas should be implemented.

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NEHC Highlights of Coordinated Efforts between Remediation Contractor and Independent Third Party Inspector:

Preliminary Visual Examination – After the cleaning work is completed, an independent third-party competent person shall visually evaluate the entire work area to ensure that work has been completed and visible dust and debris have been removed. If the visual examination results are unsatisfactory, affected surfaces must be retreated and/or re-cleaned.

Final Inspection – The final clearance evaluation should take place at least 1 hour after the final cleaning.

The clearance evaluation has three purposes:

o To ensure that the lead hazard control work is complete o To detect the presence of leaded dust o To make sure that treated surfaces have been repainted or otherwise sealed

Clearance Standard – Wipe sample results shall be less than 200 ug/ft2 on interior floors and remediated surfaces.

Re-cleaning After Clearance Failure – The Contractor shall complete any necessary re-cleaning of the space at no additional cost to the Government if after passing the final visual examination, the space "fails" the clearance wipe dust tests. The HEPA/wet wash/HEPA cleaning cycle shall be carefully and methodically repeated in the event of a clearance wipe dust test "failure". Failure is an indication that the cleaning has not been successful. Care should be exercised during the re-cleaning of “failed” surfaces or components thereof to avoid recontaminating “cleared” surfaces or components.

Re-inspection and Re-clearance – The Contractor shall be responsible for costs to redo tasks in the Final Inspection, Re-Cleaning After Clearance Failure, and Clearance Standard sections.

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6. Limitations

This report was prepared by Pinyon Environmental, Inc., at the request of and for the sole benefit of the United States General Services Administration, or any entity controlling, controlled by, or under common control with the United States General Services Administration. The conclusions and recommendations offered in this report are based on the data obtained from a limited number of samples. Lead-dust conditions can vary even over short distances. Thus, the nature and extent of variations outside the investigation may not become evident except through further investigation.

This report is the exclusive and present use of the United States General Services Administration, or any entity controlling, controlled by, or under common control with the United States General Services Administration. Laboratory analysis has been performed for a specific constituent during the course of this investigation, as described in the text. This study makes no attempt to assess constituents not searched for in the laboratory analysis.

Conclusions stated herein refer only to the specific site at the time of the investigation.

Figures

Raymond, Montana

Appendix A Analytical Results Tables

Table 1 Lead-Wipe Results

Table 2 Soil Sampling Results

Raymond, Montana

Table 1 Lead-Wipe Sample Results

Sample # Material Description Room # Sample Location Results (ug/ft2)

RAY-1 EF-7 Fire range exhaust louver

Outside Building C -ground level

SE side of building 43.5

RAY-3

MAU-2 Makeup air unit for firing range - intake louver obtain from exterior side of unit

Outside Building C -ground level NE side of building 2.1

RAY-4

MAU-2 Makeup air unit for firing range - discharge side of filter

Outside Building C -ground level

NE side of building 54.4

RAY-5

EF-8 Exhaust fan in bay area

- inside duct accessed at floor (right side)

Building C Bay (C100) 2'E, S Wall, 1'G 88.8

RAY-6

UH-8 Unit heater in bay area - fan guard housing

(north end) Building C Bay (C100) 20'W, 3'N, 12'G 47.0

RAY-7 Upper horizontal dusty surface

Building C Bay (C100) W Wall, 24'S, 3'G 56.6

RAY-8 Surface of foam mat Building C Bay (C100) 3'E, 20'S, 3'G 8.9

RAY-9 Exhaust grill (EF-6) Building C Bathroom

(C103) 1'E, 1'N, C 26.3

RAY-10 Supply air diffuser Building C storage (C101) 6'E, 11'S, 8'G 72.4

RAY-11 Return air grille Building C storage (C101) 6'W, 5'S, 8'G 102

RAY-12

Upper horizontal dusty surface Building C storage (C101) 2'E, 9'S, 7'G 106

RAY-13 Floor near equipment storage Building C storage (C101) 7'W, 7'N, G 68.5

RAY-14 Supply air diffuser Building C Office (C104) 7'W, 6'N, C 44.8

RAY-15 Return air grille Building C Office (C104) 3'E, 1'S, C 23.0

RAY-16

Upper horizontal dusty surface Building C Office (C104) 1'W, 5'N, 5'G 38.7

RAY-17 Floor near entrance Building C Office (C104) 3'E, 1'S, G 5.1

RAY-18 Door handle into C105 Building C Office (C105) 4'E, S Wall, 3'G BRL

RAY-19 Desk surface Building C Office/Break

(C107) 2'E, 6'N, 3'G 26.4

RAY-20 Return air grille Building C Waiting Room

(C106) 3'E, 1'S, C 45.2

RAY-21

Door handle at entrance into firing range from interior side

Building C (C004) 5'W, N Wall, 3'G 8.5

RAY-22 Floor at landing entrance into firing range

Building C (C004) 3'W, 3'N, G 308

Raymond, Montana

Sample # Material Description Room # Sample Location Results (ug/ft2)

RAY-23 Hand rail on stairs leading down to firing range

Building C (C004) 5'W, 12'N, 3'G 20.9

RAY-24

Bottom surface of dumbwaiter Building C (C004) 9'W, 4'N, 3'G 1,389

RAY-25

Wall located above gun cleaning station Building C (C004) E Wall, 20'N, 5'G 15.0

RAY-26 Floor below gun cleaning station

Building C (C004) 1'E, 22'N, G 3,186

RAY-27 Upper surface of red lockers Building C (C004) 1'E, 7'S, 7'G 1,321

RAY-28

Handle entrance into ammo gage Building C (C005) 5'E, N Fence, 5'G 27.2

RAY-29

Door handle into bathroom

(C003) Building C (C003) 3'E, S Wall, 3'G 4.9

RAY-30 Exhaust grille (bathroom) Building C (C003) 1'E, 1'S, C 62.5

RAY-31 Cabinet door handle above sink

Building C (C004) 7'E, 1'N, 5'G 11.7

RAY-32

Firing range - Discharge side of ceiling mounted unit heater

Building C (C001) 8'W, 35'N, 10'G 5,813

RAY-33

Firing range - Upper surface of target track near firing station (north end)

Building C (C001) 8'E, 12'N, 8'G 968

RAY-34

Firing range - Upper surface of target track near targets

(south end) Building C (C001) 7'W, 23'S, 8'G 1,688

RAY-35 Firing range - upper surface of baffle 1 (south end)

Building C (C001) 9'W, 30'S, 9'G 4,142

RAY-36

Firing range - upper surface of baffle 2 (middle) Building C (C001) 7'E, 58'S, 9'G 6,476

RAY-37

Firing range - upper surface of baffle (north end) Building C (C001) 4'W, 76'S, 9'G 3,376

RAY-38 Firing range Instructors desk

- computer control panel

Building C (C001) 9'E, 7'N, 4'G 525

RAY-39

Firing range handrail around instructor’s desk Building C (C001) 5'W, 5'N, 5'G 63.0

RAY-40

Firing range supply air perforate panel behind instructor’s desk Building C (C001) 2'E, N Wall, 5'G 42.6

RAY-41 Firing range east wall to the right of Lead warning sign Building C (C001) E Wall, 5'N, 4'G 31.3

RAY-42 Firing range floor - south end

Building C (C001) 6'W, 20'S, G 1,965

Raymond, Montana

Sample # Material Description Room # Sample Location Results (ug/ft2)

RAY-43 Firing range floor - middle Building C (C001) 10'W, 44'S, G 3,973

RAY-44

Firing range floor - north end Building C (C001) 2'E, 78'S, G 1,732

RAY-45 Firing range wall - north end Building C (C001) W Wall, 22'N, 5'G 230

RAY-46 Firing range wall - south end Building C (C001) E Wall, 26'S, 4'G 45.9

RAY-47

Restroom vestibule north wall B112 1'W, N Wall, 6'G BRL

RAY-48 Exhaust grille B113 2'E, 3'N, C BRL

RAY-49 Exhaust grille B114 2'E, 4'N, C 1.5

RAY-50 Floor at outside south entrance

B110 3'E, 1'S, G 2.2

RAY-51

Door handle into B117 from

B110 side B110 E Wall, 10'S, 3'G 1.5

RAY-52 Exhaust grille B107 2'E, 3'S, C BRL

RAY-53 Desk surface B105 18'E, 10'S, 3'G BRL

RAY-54

Upper surface of gray cabinets across from desks B105 13'E, 1'S, 5'G 1.5

RAY-55

MAU-1 Control panel on east wall B100 E Wall, 28'N, 4'G 1.6

RAY-56 Door handle (interior) North door

B100 4'E, N Wall, 3'G 5.2

RAY-57 Desk surface B101 2'E, 8'N, 3'G BRL

RAY-58 Return air grille B101 1'E, 8'S, C BRL

RAY-59 Floor at entrance into B101 Corridor B102 1'W, 22'N, G BRL

RAY-60 Supply air diffuser B104 8'W, 4'N, C BRL

RAY-61 Elevator call button Corridor A004 7'W, N Wall, 3'G BRL

RAY-62 Door handle into A001 (boiler room side)

A003 W Wall, 12'N, 3'G 1.4

RAY-63 Table top A006 15'E, 10'S, 2'G BRL

RAY-64 Return air grill A006 3'W, 6'S, 7'G 8.7

RAY-65 Supply air diffuser A006 10'E, 8'S, 7'G BRL

RAY-66 Upper horizontal dusty surface

A006 3'E, 6'S, 5'G BRL

RAY-67

Floor – Mid-landing in east stair A005 3'W, 4'N, G BRL

RAY-68 Handrail in east stair A005 5'W, 5'N, 3'G BRL

RAY-69 Floor - level 1 landing in east stair

A119 3'E, 3'S, G BRL

Raymond, Montana

Sample # Material Description Room # Sample Location Results (ug/ft2)

RAY-70 Door handle into A113 from corridor side

Corridor A114 3'W, N Wall, 3'G BRL

RAY-71 Supply air diffuser A113 6'W, 6'S, C BRL

RAY-72 Desk/table surface A113 3'E, 7'N, 2'G BRL

RAY-73 Return air grille - east end A112 3'E, N Wall, 15'G BRL

RAY-74

Door handle into A125 from corridor side A125 W Wall, 5'S, 3'G BRL

RAY-75 Supply air diffuser A125 2'W, 5'S, C BRL

RAY-76 Window sill A125 E Wall, 6'S, 3'G BRL

RAY-77

Light switch and area around it A125 W Wall, 6'S, 3'G BRL

RAY-78

Door handle into A112 from corridor side Corridor A114 28'E, S Wall, 3'G BRL

RAY-79 Elevator call button A114 16'W, N Wall, 3'G BRL

RAY-80 Floor - elevator A114 3'E, 1'S, G 1.3

RAY-81

Door handle into locker room from hall side A117 1'E, S Wall, 3'G BRL

RAY-82 Floor - immediately inside locker room

A124 3'E, 2'S, G BRL

RAY-83 Locker 1 - upper surface A124 5'W, 1'S, 7'G BRL

RAY-84 Locker 2 - upper surface A124 5'W, 1'N, 7'G BRL

RAY-85 Locker 3 - upper surface A124 6'E, 6'N, 7'G BRL

RAY-86 Locker 1 - handle A124 6'E, 2'S, 3'G BRL

RAY-87 Locker 2 - handle A124 3'W, 2'N, 3'G 7.1

RAY-88 Locker 3 - handle A124 6'E, 5'N, 3'G 25.7

RAY-89 Exhaust grille A120 3'E, 1'N, C BRL

RAY-90 Exhaust grille A122 1'W, 1'N, C BRL

RAY-91 Floor at finger print area A110 2'W, 3'S, G BRL

RAY-92 Cabinets at finger print area A110 5'W, 2'S, 5'G BRL

RAY-93

Desk top on officer side of desk A109 4'E, 4'S, 3'G BRL

RAY-94 Return air grille A109 2'E, 2'S, C 28.3

RAY-95 Door handle entrance into A107

A101 Vestibule E Wall, 3'S, 3'G 1.4

RAY-96 Main entrance door handle A101A door 3'E, S Wall, 3'G 13.4

Raymond, Montana

Sample # Material Description Room # Sample Location Results (ug/ft2)

RAY-97 Door handle on 1/2 door -south handle

A100 9'E, 8'S, 2'G BRL

RAY-98 Top surface of 1/2 door A100 9'E, 8'S, 3'G BRL

RAY-99

Inspector counter area -phone A102 20'E, 8'S, 4'G BRL

RAY-100 Inspector counter area -desktop

A102 18'E, 12'S, 4'G BRL

RAY-101 Inspector counter area -computer key pad

A102 2'E, 2'S, 4'G 1.7

RAY-102

Floor under Inspector counter area - East end A102 14'E, 11'S, G 2.0

RAY-103 Floor under Inspector counter area - Middle

A102 24'E, 11'S, G 2.2

RAY-104 Floor under Inspector counter area - West end

A102 5'W, 11'S, G 1.5

RAY-105

High touch surface of any chair - 1 A102 11'W, 16'S, 3'G BRL

RAY-106

High touch surface of any chair - 2 A102 4'E, 6'N, 3'G BRL

RAY-107 Refrigerator handle A106 3'E, 5'N, 3'G BRL

RAY-108 Table top A106 5'W, 3'N, 3'G BRL

RAY-109 Light switch A106 W Wall, 3'S, 3'G BRL

RAY-110 Return air grill A106 3'E, 4'S, C BRL

RAY-111 Vest 1 - Surface of any 3 bullet vests you see

B101 3'E, 11'S, 3'G BRL

RAY-112

Vest 2 - Surface of any 3 bullet vests you see C001 4'W, 1'N, 3'G 138

RAY-114 Return air grille A103 4'W, 1'S, C 2.9

RAY-115 Desk top in Primary bi-level booth - lower booth

West end of A102 4'W, 2'N, 3'G 1.8

RAY-116

Door handle west side into west stairs A205 E Wall, 3'S, 3'G BRL

RAY-117 Door handle east side from within west stairs

A215 W Wall, 3'N, 3'G BRL

RAY-118 Hand rail within west stairs A215 6'E, 4'S, 4'G 1.4

RAY-119

Floor at L2 entrance into stair A215 3'W, 6'S, G BRL

RAY-120 Return air grill A207 4'E, 1'S, C 2.3

Raymond, Montana

Sample # Material Description Room # Sample Location Results (ug/ft2)

RAY-121 Discharge side of filters -

AHU-1

A209 5'W, 10'N, 1'G 5.9

RAY-122 Exhaust fan A210 4'E, 4'S, C 1.8

RAY-123

Upper horizontal dusty surface A220 36'E, 1'N, 6'G BRL

RAY-124 Beater bar of custodial vacuum

A116 1'W, 1'S, G 1.7

RAY-125 Blank A125 Blank BRL

RAY-126 Blank A124 Blank BRL

RAY-127 Blank A110 Blank BRL

RAY-128 Blank A102 Blank BRL

RAY-129 Blank A215 Blank BRL

RAY-130 Blank B101 Blank BRL

RAY-131 Blank C004 Blank BRL

RAY-132 Blank C004 Blank BRL

RAY-133 Blank C001 Blank BRL

RAY-134 Blank C001 Blank BRL

RAY-135 Blank C100 Blank 1.6

RAY-136 Blank C104 Blank BRL

Notes:

Sample location descriptions are based on the sample distance from the listed wall. For example 1’S, 3’W, 3’G refers to a sample collected one foot from the south wall, three feet from the west wall, and three feet from the ground.

Bold – samples exceed the GSA Guidance value of 200 ug/ft2

BRL – Below Reporting Limit sf – square feet ‘ – foot

NS – Not Sampled ug/ft2 – micrograms per square foot N – North S – South E – East W – West G – ground C – Ceiling AHU – Air Handling Unit

Raymond, Montana

Table 2 Soil Sampling Results

Sample # Room # Material Description

Sample Location

Results (mg/kg)

RAY-2 Soil sample below EF-7 termination

Outside Building C

- ground level

SE side of building 8.2

Notes:

mg/kg – milligrams per kilogram SE – Southeast

Raymond, Montana

Appendix B Laboratory Report, Chain-of-Custody, and Laboratory Accreditation

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 T:\QAQC\Lab\Reservoirs Environmental QA Manual.doc

Laboratory Code: RES Subcontract Number: NA Laboratory Report: RES 353590-1 Project # / PO #: 11634606 Project Description:

RES 353590-1

Sincerely, June 23, 2016

Dear Customer, Reservoirs has analyzed the following sample(s) using Atomic Absorption Spectroscopy (AAS) / Atomic Emission Spectroscopy - Inductively Coupled Plasma (AES-ICP) per your request. Reported sample results were not blank corrected. The analysis has been completed in general accordance with the appropriate methodology as stated in the analysis table. Results have been sent to your office.

property of the customer. Reservoirs Environmental, Inc. will not discuss any part of this study with personnel other than those authorized by the client. The results described in this report only apply to the samples analyzed. This report shall not be reproduced except in full, without written approval from Reservoirs Environmental, Inc. Samples will be disposed of after sixty days unless longer storage is requested. If you should have any questions about this report, please feel free to call me at 303-964-1986.

Reservoirs Environmental, Inc. is an analytical laboratory accredited for the analysis of Industrial Hygiene and Environmental matrices by the American Industrial Hygiene Association, Lab ID 101533 - Accreditation Certificate #480.

The laboratory is currently proficient in both IHPAT & ELPAT programs respectively.

is the job number assigned to this study. This report is considered highly confidential and the sole

GSA-Raymond

Lakewood CO 80232 9100 West Jewell Ave. Suite 200 Pinyon Environmental Engineering

Jeanne Spencer

President

P: 303-964-1986 F: 303-477-4275

5801 Logan Street, Suite 100 Denver, CO 80216

1-866-RESI-ENV

www.reilab.com

Effective January 1, 2015 T:\QAQC\Lab\Reservoirs Environmental QA Manual.doc

RES Job Number:

Client:

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Samples Analyzed:

Client Lab Sample LEAD Reporting LEAD

ID Number ID Number Area (µg) Limit CONCENTRATION (sq.ft.) (µg/ft2) (µg/ft2)

RAY-1 EM 1654199 1.00 43.5 1.3 43.5

RAY-3 EM 1654201 1.00 2.1 1.3 2.1

RAY-4 EM 1654202 1.00 54.4 1.3 54.4

RAY-5 EM 1654203 1.00 88.8 1.3 88.8

RAY-6 EM 1654204 1.00 47.0 1.3 47.0

RAY-7 EM 1654205 1.00 56.6 1.3 56.6

RAY-8 EM 1654206 1.00 8.9 1.3 8.9

RAY-9 EM 1654207 1.00 26.3 1.3 26.3

RAY-10 EM 1654208 1.00 72.4 1.3 72.4

RAY-11 EM 1654209 1.00 102 1.3 102

RAY-12 EM 1654210 1.00 106 1.3 106

RAY-13 EM 1654211 1.00 68.5 1.3 68.5

RAY-14 EM 1654212 1.00 44.8 1.3 44.8

RAY-15 EM 1654213 1.00 23.0 1.3 23.0

RAY-16 EM 1654214 1.00 38.7 1.3 38.7

RAY-17 EM 1654215 1.00 5.1 1.3 5.1

RAY-18 EM 1654216 1.00 BRL 1.3 BRL

RAY-19 EM 1654217 1.00 26.4 1.3 26.4

RAY-20 EM 1654218 1.00 45.2 1.3 45.2

RAY-21 EM 1654219 1.00 8.5 1.3 8.5

RAY-22 EM 1654220 1.00 308 1.3 308

RAY-23 EM 1654221 1.00 20.9 1.3 20.9

RAY-24 EM 1654222 1.00 1,389 1.3 1,389

RAY-25 EM 1654223 1.00 15.0 1.3 15.0

RAY-26 EM 1654224 1.00 3,186 1.3 3,186

RAY-27 EM 1654225 1.00 1,321 1.3 1,321

RAY-28 EM 1654226 1.00 27.2 1.3 27.2

RAY-29 EM 1654227 1.00 4.9 1.3 4.9

RAY-30 EM 1654228 1.00 62.5 1.3 62.5

RAY-31 EM 1654229 1.00 11.7 1.3 11.7

RESERVOIRS ENVIRONMENTAL, INC.

5801 Logan St., Suite 100

Denver CO 80216

TABLE ANALYSIS: LEAD BY WIPE SAMPLING

June 22 - June 23, 2016

RES 353590-1

24 Hour

June 22, 2016

NIOSH 9102 (ICP)

Pinyon Environmental Engineering 11634606 GSA-Raymond

BRL = Below Reporting Limit

P: 303-964-1986 F: 303-477-4275

5801 Logan Street, Suite 100 Denver, CO 80216

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Samples Analyzed:

Client Lab Sample LEAD Reporting LEAD

ID Number ID Number Area (µg) Limit CONCENTRATION (sq.ft.) (µg/ft2) (µg/ft2)

RESERVOIRS ENVIRONMENTAL, INC.

5801 Logan St., Suite 100

Denver CO 80216

TABLE ANALYSIS: LEAD BY WIPE SAMPLING

June 22 - June 23, 2016

RES 353590-1

24 Hour

June 22, 2016

NIOSH 9102 (ICP)

Pinyon Environmental Engineering 11634606 GSA-Raymond

RAY-32 EM 1654230 1.00 5,813 1.3 5,813

RAY-33 EM 1654231 1.00 968 1.3 968

RAY-34 EM 1654232 1.00 1,688 1.3 1,688

RAY-35 EM 1654233 1.00 4,142 1.3 4,142

RAY-36 EM 1654234 1.00 6,476 1.3 6,476

RAY-37 EM 1654235 1.00 3,376 1.3 3,376

RAY-38 EM 1654236 1.00 525 1.3 525

RAY-39 EM 1654237 1.00 63.0 1.3 63.0

RAY-40 EM 1654238 1.00 42.6 1.3 42.6

RAY-41 EM 1654239 1.00 31.3 1.3 31.3

RAY-42 EM 1654240 1.00 1,965 1.3 1,965

RAY-43 EM 1654241 1.00 3,973 1.3 3,973

RAY-44 EM 1654242 1.00 1,732 1.3 1,732

RAY-45 EM 1654243 1.00 230 1.3 230

RAY-46 EM 1654244 1.00 45.9 1.3 45.9

RAY-47 EM 1654245 1.00 BRL 1.3 BRL

RAY-48 EM 1654246 1.00 BRL 1.3 BRL

RAY-49 EM 1654247 1.00 1.5 1.3 1.5

RAY-50 EM 1654248 1.00 2.2 1.3 2.2

RAY-51 EM 1654249 1.00 1.5 1.3 1.5

RAY-52 EM 1654250 1.00 BRL 1.3 BRL

RAY-53 EM 1654251 1.00 BRL 1.3 BRL

RAY-54 EM 1654252 1.00 1.5 1.3 1.5

RAY-55 EM 1654253 1.00 1.6 1.3 1.6

RAY-56 EM 1654254 1.00 5.2 1.3 5.2

RAY-57 EM 1654255 1.00 BRL 1.3 BRL

RAY-58 EM 1654256 1.00 BRL 1.3 BRL

RAY-59 EM 1654257 1.00 BRL 1.3 BRL

RAY-60 EM 1654258 1.00 BRL 1.3 BRL

RAY-61 EM 1654259 1.00 BRL 1.3 BRL

BRL = Below Reporting Limit

P: 303-964-1986 F: 303-477-4275

5801 Logan Street, Suite 100 Denver, CO 80216

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Samples Analyzed:

Client Lab Sample LEAD Reporting LEAD

ID Number ID Number Area (µg) Limit CONCENTRATION (sq.ft.) (µg/ft2) (µg/ft2)

RESERVOIRS ENVIRONMENTAL, INC.

5801 Logan St., Suite 100

Denver CO 80216

TABLE ANALYSIS: LEAD BY WIPE SAMPLING

June 22 - June 23, 2016

RES 353590-1

24 Hour

June 22, 2016

NIOSH 9102 (ICP)

Pinyon Environmental Engineering 11634606 GSA-Raymond

RAY-62 EM 1654260 1.00 1.4 1.3 1.4

RAY-63 EM 1654261 1.00 BRL 1.3 BRL

RAY-64 EM 1654262 1.00 8.7 1.3 8.7

RAY-65 EM 1654263 1.00 BRL 1.3 BRL

RAY-66 EM 1654264 1.00 BRL 1.3 BRL

RAY-67 EM 1654265 1.00 BRL 1.3 BRL

RAY-68 EM 1654266 1.00 BRL 1.3 BRL

RAY-69 EM 1654267 1.00 BRL 1.3 BRL

RAY-70 EM 1654268 1.00 BRL 1.3 BRL

RAY-71 EM 1654269 1.00 BRL 1.3 BRL

RAY-72 EM 1654270 1.00 BRL 1.3 BRL

RAY-73 EM 1654271 1.00 BRL 1.3 BRL

RAY-74 EM 1654272 1.00 BRL 1.3 BRL

RAY-75 EM 1654273 1.00 BRL 1.3 BRL

RAY-76 EM 1654274 1.00 BRL 1.3 BRL

RAY-77 EM 1654275 1.00 BRL 1.3 BRL

RAY-78 EM 1654276 1.00 BRL 1.3 BRL

RAY-79 EM 1654277 1.00 BRL 1.3 BRL

RAY-80 EM 1654278 1.00 1.3 1.3 1.3

RAY-81 EM 1654279 1.00 BRL 1.3 BRL

RAY-82 EM 1654280 1.00 BRL 1.3 BRL

RAY-83 EM 1654281 1.00 BRL 1.3 BRL

RAY-84 EM 1654282 1.00 BRL 1.3 BRL

RAY-85 EM 1654283 1.00 BRL 1.3 BRL

RAY-86 EM 1654284 1.00 BRL 1.3 BRL

RAY-87 EM 1654285 1.00 7.1 1.3 7.1

RAY-88 EM 1654286 1.00 25.7 1.3 25.7

RAY-89 EM 1654287 1.00 BRL 1.3 BRL

RAY-90 EM 1654288 1.00 BRL 1.3 BRL

RAY-91 EM 1654289 1.00 BRL 1.3 BRL

BRL = Below Reporting Limit

P: 303-964-1986 F: 303-477-4275

5801 Logan Street, Suite 100 Denver, CO 80216

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Samples Analyzed:

Client Lab Sample LEAD Reporting LEAD

ID Number ID Number Area (µg) Limit CONCENTRATION (sq.ft.) (µg/ft2) (µg/ft2)

RESERVOIRS ENVIRONMENTAL, INC.

5801 Logan St., Suite 100

Denver CO 80216

TABLE ANALYSIS: LEAD BY WIPE SAMPLING

June 22 - June 23, 2016

RES 353590-1

24 Hour

June 22, 2016

NIOSH 9102 (ICP)

Pinyon Environmental Engineering 11634606 GSA-Raymond

RAY-92 EM 1654290 1.00 BRL 1.3 BRL

RAY-93 EM 1654291 1.00 BRL 1.3 BRL

RAY-94 EM 1654292 1.00 28.3 1.3 28.3

RAY-95 EM 1654293 1.00 1.4 1.3 1.4

RAY-96 EM 1654294 1.00 13.4 1.3 13.4

RAY-97 EM 1654295 1.00 BRL 1.3 BRL

RAY-98 EM 1654296 1.00 BRL 1.3 BRL

RAY-99 EM 1654297 1.00 BRL 1.3 BRL

RAY-100 EM 1654298 1.00 BRL 1.3 BRL

RAY-101 EM 1654299 1.00 1.7 1.3 1.7

RAY-102 EM 1654300 1.00 2.0 1.3 2.0

RAY-103 EM 1654301 1.00 2.2 1.3 2.2

RAY-104 EM 1654302 1.00 1.5 1.3 1.5

RAY-105 EM 1654303 1.00 BRL 1.3 BRL

RAY-106 EM 1654304 1.00 BRL 1.3 BRL

RAY-107 EM 1654305 1.00 BRL 1.3 BRL

RAY-108 EM 1654306 1.00 BRL 1.3 BRL

RAY-109 EM 1654307 1.00 BRL 1.3 BRL

RAY-110 EM 1654308 1.00 BRL 1.3 BRL

RAY-111 EM 1654309 1.00 BRL 1.3 BRL

RAY-112 EM 1654310 1.00 138 1.3 138

RAY-114 EM 1654311 1.00 2.9 1.3 2.9

RAY-115 EM 1654312 1.00 1.8 1.3 1.8

RAY-116 EM 1654313 1.00 BRL 1.3 BRL

RAY-117 EM 1654314 1.00 BRL 1.3 BRL

RAY-118 EM 1654315 1.00 1.4 1.3 1.4

RAY-119 EM 1654316 1.00 BRL 1.3 BRL

RAY-120 EM 1654317 1.00 2.3 1.3 2.3

RAY-121 EM 1654318 1.00 5.9 1.3 5.9

RAY-122 EM 1654319 1.00 1.8 1.3 1.8

BRL = Below Reporting Limit

P: 303-964-1986 F: 303-477-4275

5801 Logan Street, Suite 100 Denver, CO 80216

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Samples Analyzed:

Client Lab Sample LEAD Reporting LEAD

ID Number ID Number Area (µg) Limit CONCENTRATION (sq.ft.) (µg/ft2) (µg/ft2)

RESERVOIRS ENVIRONMENTAL, INC.

5801 Logan St., Suite 100

Denver CO 80216

TABLE ANALYSIS: LEAD BY WIPE SAMPLING

June 22 - June 23, 2016

RES 353590-1

24 Hour

June 22, 2016

NIOSH 9102 (ICP)

Pinyon Environmental Engineering 11634606 GSA-Raymond

RAY-123 EM 1654320 1.00 BRL 1.3 BRL

RAY-124 EM 1654321 1.00 1.7 1.3 1.7

RAY-125 EM 1654322 1.00 BRL 1.3 BRL

RAY-126 EM 1654323 1.00 BRL 1.3 BRL

RAY-127 EM 1654324 1.00 BRL 1.3 BRL

RAY-128 EM 1654325 1.00 BRL 1.3 BRL

RAY-129 EM 1654326 1.00 BRL 1.3 BRL

RAY-130 EM 1654327 1.00 BRL 1.3 BRL

RAY-131 EM 1654328 1.00 BRL 1.3 BRL

RAY-132 EM 1654329 1.00 BRL 1.3 BRL

RAY-133 EM 1654330 1.00 BRL 1.3 BRL

RAY-134 EM 1654331 1.00 BRL 1.3 BRL

RAY-135 EM 1654332 1.00 1.6 1.3 1.6

RAY-136 EM 1654333 1.00 BRL 1.3 BRL

*Calculations Based On A 1 sq.ft. Sample Area Unless Otherwise Noted

* Unless otherwise noted all quality control samples performed within specifications established by the laboratory.

Analyst / Data QA:_________________________

BRL = Below Reporting Limit

P: 303-964-1986 F: 303-477-4275

5801 Logan Street, Suite 100 Denver, CO 80216

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Samples Analyzed:

Client Lab Reporting LEAD

ID Number ID Number Limit CONCENTRATION (mg/kg) (mg/kg)

RAY-2 EM 1654200 1.9 8.2

Analyst / Data QA:__________________________

June 22, 2016

24 Hour

USEPA SW846 3050B / 6020A

* Unless otherwise noted all quality control samples performed within specifications established by the laboratory.

June 22, 2016

GSA-Raymond

RES 353590-1

Pinyon Environmental Engineering 11634606

RESERVOIRS ENVIRONMENTAL, INC.

5801 Logan St., Suite 100

Denver CO 80216

TABLE ANALYSIS: LEAD IN SOIL

BRL = Below Reporting Limit

P: 303-964-1986 F: 303-477-4275

5801 Logan Street, Suite 100 Denver, CO 80216

AIHA Laboratory Accreditation Programs, LLC acknowledges that

5801 Logan Street, Suite 100, Denver, CO 80216

Laboratory ID: 101533 along with all premises from which key activities are performed, as listed above, has fulfilled the requirements of the AIHA Laboratory Accreditation Programs (AIHA-LAP), LLC accreditation to the ISO/IEC 17025:2005 international standard, General Requirements for the Competence of Testing and Calibration Laboratories in the following:

LABORATORY ACCREDITATION PROGRAMS

INDUSTRIAL HYGIENE Accreditation Expires: 02/01/2017 ENVIRONMENTAL LEAD Accreditation Expires: 02/01/2017 ENVIRONMENTAL MICROBIOLOGY Accreditation Expires: 02/01/2017 FOOD Accreditation Expires: 02/01/2017 UNIQUE SCOPES Accreditation Expires:

Specific Field(s) of Testing (FoT)/Method(s) within each Accreditation Program for which the above named laboratory maintains accreditation is outlined on the attached Scope of Accreditation. Continued accreditation is contingent upon successful on-going compliance with ISO/IEC 17025:2005 and AIHA-LAP, LLC requirements. This certificate is not valid without the attached Scope of Accreditation. Please review the AIHA- LAP, LLC website (www.aihaaccreditedlabs.org) for the most current Scope.

Gerald Schultz, CIH Chairperson, Analytical Accreditation Board

Cheryl O. Morton Managing Director, AIHA Laboratory Accreditation Programs, LLC

Revision 14: 03/26/2014 Date Issued: 03/31/2015 http://www.aihaaccreditedlabs.org/

Appendix C Photographic Log

Photographic Log June 16, 17, and 20, 2016

Gun cleaning area in Building C. Floor below gun cleaning area, top of lockers, bottom surface of dumbwaiter, and floor at entrance of gun cleaning area exceeded the GSA guidance document value (Samples RAY- 22, 24, 26, and 27).

Hand wash and dumbwaiter in gun cleaning area of Building C.

Floor below gun cleaning area, top of lockers, bottom surface of dumbwaiter, and floor at entrance of gun cleaning area exceeded the GSA guidance document value (Samples RAY- 22, 24, 26, and 27).

June 16, 17, and 20, 2016

Building C, firing range exhaust fan. Sample did not exceed the GSA guidance document value (Sample RAY-1).

Building C, makeup air unit for firing range.

Sample did not exceed the GSA guidance document value (Samples RAY- 4).

June 16, 17, and 20, 2016

Building C, operations and maintenance office area.

None of the samples in this area exceeded the GSA guidance document value (Samples RAY-5 through RAY- 20).

Typical supply air diffuser found throughout Building A. None of the samples collected in Building A exceeded the GSA guidance document value (multiple samples).

June 16, 17, and 20, 2016

Typical return air grille found throughout Building A. None of the samples collected in Building A exceeded the GSA guidance document value (multiple samples).

Locker room in Building A. None of the samples collected in Building A exceeded the GSA guidance document value

June 16, 17, and 20, 2016

Typical supply air diffuser found throughout Building A. None of the samples collected in Building A exceeded the GSA guidance document value (multiple samples).

Inspector counter area in Building A. None of the samples collected in Building A exceeded the GSA guidance document value

Raymond, Montana

Appendix D Background Threshold Values for Inorganics in Montana Soils

Raymond, Montana

Appendix E Indoor Firing Range Design, Operations, & Maintenance Criteria. GSA Public Buildings Service, (April 2002).

http://www.gsa.gov/portal/mediaId/121750/fileName/IF R_Criteria_0412.action

Raymond, Montana

Appendix F Indoor Firing Ranges Industrial Hygiene Technical Guide.

Navy Environmental Health Center, Technical Manual NEHC–TM6290.99-10 Rev.1, (May 2002)

Navy Environmental Health Center Technical Manual NEHC–TM6290.99-10 Rev.1 (May 2002)

INDOOR FIRING RANGES

INDUSTRIAL HYGIENE

TECHNICAL GUIDE

NAVY ENVIRONMENTAL HEALTH CENTER

BUREAU OF MEDICINE AND SURGERY

Nancy.Owens Text Box DISTRIBUTION STATEMENT A. Approved for public release; distribution is unlimited.

INDOOR FIRING RANGES

INDUSTRIAL HYGIENE

TECHNICAL GUIDE

Published By

NAVY ENVIRONMENTAL HEALTH CENTER

620 John Paul Jones Circle

Portsmouth, Virginia 23708-2197

Revision 1 May 2002

Navy Environmental Health Center Technical Manual NEHC-TM6290.99-10 Rev. 1

Contents

1.0 Introduction

1.1 Purpose

1.2 Use

1.3 Other technical assistance

2.0 Hazards

2.1 Components of ammunition

2.2 The firing/shooting process

2.3 Bullet impact

2.4 Lead

3.0 Design

3.1 Length

3.2 Firing lanes

3.3 Structure design and construction

3.4 Bullet stops (traps)

3.5 Selection and installation of bullet traps

3.6 Regular maintenance

3.7 Target retrieval systems

3.8 Shooting Booths

3.9 Rubber mats

3.10 Lighting

3.11 Alarms

4.0 Mechanical

4.1 Ventilation Systems

4.2 Air Distribution

4.3 Air flow

4.4 Intake and discharge of air

5.0 Evaluation

5.1 Physical and operational assessment

5.2 Ventilation assessment

5.3 Air sampling

5.4 Range cleaning

5.5 Hygiene

5.6 Surface contamination assessments

i

6.0 Controls

6.1 Substitution

6.2 Ventilation systems

6.3 Maintenance

6.4 Administrative

7.0 Acceptance Testing

7.1 Background

7.2 Generic industrial hygiene acceptance test

Appendices

Appendix A - Health Considerations for Routine Range Use/Cleanup: Generic Standard

Operating Procedure for Training Type Indoor Small Arms Ranges

Appendix B - Wipe Sampling for Settled Lead-Contaminated Dust

Appendix C - Lead Removal Plan/Material Containing Lead Removal Plan

Appendix D - Indoor Firing Range Cleaning Guidance

Appendix E - Sources of Information

Appendix F - Industrial Hygiene Acceptance Test

Disclaimer: Mention of the name of any company or product or the depiction of engineering designs does not constitute endorsement by Navy Environmental Health Center or the Department of the Navy.

ii

1.0 Introduction

1.1 Purpose - This reference guide is intended to provide general information regarding indoor firing ranges (small arms ranges) to assist in recognizing, evaluating and controlling safety and health hazards. The contents are drawn from Federal regulations, Navy instructions, and other technical documents.

1.2 Use - This guide should be useful to range operators, industrial hygienists, safety professionals and technicians in performing range evaluations, understanding conditions that require additional expertise and developing operation and maintenance procedures.

1.2.1 This guide provides the following:

1.2.1.1 General hazard information,

1.2.1.2 General design and operation aspects,

1.2.1.3 Systems and equipment of industrial hygiene concern,

1.2.1.4 General discussion of ventilation design and evaluation,

1.2.1.5 Work practices and recommendations for controlling exposure to hazards and safe operation,

1.2.1.6 Other sources of information.

1.3 Technical assistance

1.3.1 For questions regarding this guide, users may contact Mr. John Bishop, CIH, Navy Environmental Health Center, Industrial Hygiene Directorate, (757) 953-0752, DSN 377-0752, e-mail john.bishop@med.navy.mil.

1.3.2 For engineering support, contact the Naval Facilities Engineering Command, Technical Centers of Expertise, Mr. Randy Jackson, P.E. at (757) 322-4316.

2.0 Hazards

2.1 Components of ammunition

2.1.1 The projectile or bullet is usually made of a dense material such as lead and may be covered or jacketed with a copper-zinc alloy. Some special purpose bullets may be made from metals other than lead. The bullet may be non-jacketed (totally exposed lead bullet) or totally or partially jacketed. Even in totally jacketed bullets, the base of the bullet may have exposed lead.

2.1.2 The casing contains the propellant and the primer. The casing is usually brass and most ranges will recover them for recycling. The propellant is the main charge and provides the expanding gas that propels the bullet. It is usually a mixture of nitrocellulose and nitroglycerin. The propellant is ignited by the primer which is an explosive. Common formulations of primers contain sensitive metallic salts and metallic nitrate compounds that serve as an oxidizer (fulminates of lead, including lead styphnate, and sometimes lead peroxide).

2.2 The firing/shooting process

2.2.1 When struck by the firing pin, the primer explodes, igniting the propellant.

The burning propellant can generate pressures of 18,000 to 20,000 pounds per square inch (psi) and may reach a temperature of 2000 degrees Fahrenheit. The expanding gas propels the bullet down the barrel.

2.2.2 The bore (inside diameter of the barrel) is scored with spiral groves called rifling. These grooves cause the bullet to spin as it is traveling down the barrel. A spinning bullet is more stable and resists tumbling as it travels through the air towards the target.

2.2.3 The velocity achieved is directly related to the amount of propellant in the charge. Pistol bullets accelerate to nearly the speed of sound. High powered pistol and rifle bullets reach speeds above the speed of sound.

2.3 Bullet impact

2.3.1 In an indoor range, the projectile will eventually require its energy to be absorbed. Bullets usually impact onto or into some type of bullet trap (see Section 3). On impact, the bullet may fragment in many directions. This is known as "backsplatter." Factors in the generation of backsplatter are the angle at which the projectile impacts the trap, the smoothness of the impacted surface and the impact velocity. The greater the energy of a bullet, the more likely the fragments will continue on their original path and not bounce back. Lower energy bullets (e.g., subsonic ammunition) produce the most pronounced backsplatter.

2.3.2 Backsplatter fragments projected back towards the shooter are called a ricochet. Ricochets should be rare in a properly designed range. Ricochets may also be caused by the type of target used. Hard targets such as bowling pins and metal targets (poppers) can increase the likelihood of ricochet. Improper ammunition used on the range may dent the bullet stop, increasing the chance of ricochet. Bullet strikes on structural components (target retrieval systems, electrical fixtures, etc.) can cause ricochets.