Piegan_-_Lead_Sampling_Report_-_Final.pdf

October 15, 2016

Lead-Dust Evaluation

Piegan Land Port of Entry 5023 Highway 89 North

Babb, 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

5023 Highway 89 North

Babb, 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

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 – Firing Range Building

Figure 3 – Lead Wipe Sample Locations – Vehicle Garage

Figure 4 – Lead Wipe Sample Locations – Secondary Inspection Building

Figure 5 – Lead Wipe Sample Locations – Main Port Building

Figure 6 – Remediation and Lead Wipe Sample Locations – Firing Range

Figure 7 – Remediation and Lead Wipe Sample Locations – Firing Range Building

Figure 8 – Remediation and Lead Wipe Sample Locations – Main Port Building

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)

Piegan, 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 Piegan Land Port of Entry (LPOE).

Pinyon visited the Piegan LPOE on July 6 and 7, 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 four separate buildings (Figure 1). The Main Port Building is a one-story building comprised of office spaces, lobby area, restrooms, interrogations rooms, cafeteria, mechanical room, gym, locker room, and conference room. The Firing Range Building houses a firing range (which was reported to be no longer in use due to mechanical and design issues), the GSA office and garage area, restrooms, mechanical room, and armory. The Vehicle Garage Building is used for vehicle parking and a storage area. The Secondary Inspection Building is used to inspect vehicles crossing the border and is an open garage space.

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.

Piegan, Montana Page 2

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 179 lead-wipe samples (including 16 blanks) were collected on July 6 and 7, 2016 (Figures 2 through 5), 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

Two soil samples were collected from around the main building on July 7, 2016. One was collected near the western door of the firing range and one was collected from the northern door of the firing range (Figure 2).

The samples were collected by placing approximately 50 milliliters (mL) of soil in a laboratory supplied plastic container. The samples were submitted to Reservoirs, in accordance with Pinyon SOP 17, for analyses by Environmental Protection Agency (EPA) method SW846 3050B/6020A.

Piegan, Montana Page 3

3. Results

Lead-Wipe Sampling

A total of 179 lead-wipe samples (including 16 blanks) were collected and submitted to the lab for analysis.

The results were compared to the GSA limit of 200 micrograms per square foot (ug/ft2). Fifteen of the lead-wipe samples exceeded the GSA limit of 200 µg/ft2 (Appendix A, Table 1; Figures 2 and 5).

The following samples exceeded the GSA limit in the Firing Range Building:

Room 302, Firing Range: Samples PIE-25, -26, -31, -33, and -34

Exhaust Fan Mechanical Room: Samples PIE-36, -37, -39, -40, and -41

Room 310, Floor to the entrance of the firing range exhaust fan mechanical room: Sample PIE-48

Room 304, Discharge side of the furnace air filter: Sample PIE-43

Room 307, Supply air diffuser in restroom: Sample PIE-44

Room 306, Supply air diffuser in office: Sample PIE-46

The following samples exceeded the GSA limit in the Main Port Building:

Room BP1, Floor return air grill in meeting area: Sample PIE-165

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 the two soil samples, PIE-1 and PIE-2, at 10.8 and 10.1 milligrams per kilogram (mg/kg) respectively (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. Neither of the samples exceed the threshold value.

Piegan, Montana Page 4

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

During the initial walkthrough at the facility, the Operations and Maintenance contractor, ProSource Consulting, reported the most recent cleaning of the firing range occurred in March or April 2016, and the firing range had not been used, to their knowledge, since March 2016. It was also reported to Pinyon that Customs and Border Patrol (CBP) agents had not used the range for at least nine years, but Border Patrol personnel had used the firing range within the year (2016).

Evidence of improper cleaning and maintenance was observed during the walkthrough visit. Debris was observed within the firing range near the bullet trap at the ceiling void where spot lights were located, as well as in the exhaust system mechanical room. The exhaust system is in a mechanical room located behind the bullet trap. The exhaust system was heavily damaged with slug impacts, as was the bullet trap, and both pre-filter and final filter frames and filters. Slugs and other debris littered the exhaust system mechanical room floor.

If the firing range had been used since the quarterly comprehensive cleaning in March or April 2016, 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. If the firing range had not been used since the most recent comprehensive cleaning, the wipe sample results demonstrate the comprehensive cleaning was not effective.

The same conclusion can be applied to the exhaust system mechanical room, which should have been included in the comprehensive cleaning.

Given the extensive damage to the bullet trap and exhaust system filters, it is not surprising that lead dust was found on the discharge side of the high efficiency particulate air (HEPA) filters. Damage to the filter media permitted lead-contaminated air to pass through the filters and contaminate surfaces within the exhaust system downstream of the filter bank.

Based on the results of the lead-dust sampling conducted by Pinyon, the firing range and the exhaust system mechanical room and the entire exhaust system require lead dust remediation (Figure 6).

Piegan, Montana Page 5

Pinyon was not contracted to evaluate the performance of the firing range exhaust system, but did observe obvious damage to the pre- and final filter frames. At the completion of remediation, GSA should consider a comprehensive performance evaluation of the exhaust system prior to system start-up.

GSA Garage

The GSA garage space serves as offices and support space for ProSource, the GSA Operations and Maintenance contractor. The GSA garage space is located in the same building and floor level as the firing range. The entrance into the garage space is separate from the entrance into the firing range. The firing range exhaust mechanical room is accessed through the south GSA garage bay room 310.

The HVAC system components serving the GSA garage space consists of a furnace, supply air ducts and diffusers, and return air ducts and grilles. The same furnace also provides conditioned air to the firing range bathroom (room 303), hallway/lobby access (room 301) to the firing range and the armory (room 305). The furnace is located in room 304. Also located in room 304 is the make-up air unit for the firing range exhaust fan.

Separate exhaust fans (EFs) remove air from the GSA bathroom and the firing range bathroom. EF 10 exhausts air from the GSA bathroom 307, and EF 9 exhausts air from the firing range bathroom 303.

Wipe sample results indicate cross-contamination from the firing range to the GSA garage space. Lead contaminated surfaces include the discharge side of the furnace filter; the supply air diffuser located in the bathroom – room 307; the supply air diffuser located in office room 306; and on the garage floor (room 310) outside of the entrance into the firing range exhaust fan mechanical room.

Based on the results of the lead-dust sampling conducted by Pinyon, lead dust remediation is required for the entire furnace HVAC system, EF 9, EF 10, and hard surfaces in rooms 301, 303, 304, 305, 306, 307, and 308.

Remove and properly dispose of ceiling tiles surrounding supply air diffusers and replace with new tiles (Figure 7).

Lead dust remediation is required for the garage floor at the entrance into the firing range exhaust system mechanical room (Figure 7), Main Port Building – Border Patrol Offices

The Border Patrol Offices are located on the northeast side of the Main Port Building. These offices have conditioned air supplied through furnaces located in the crawlspace under the offices. Floor registers provide supply air to the office space and return air back to the furnace. Eleven wipe samples were collected in the space from various horizontal surfaces including chairs, phones, tops of cabinets, and four samples from return air registers and one sample from a supply air register. Ten samples had lead levels ranging from none detected (below reportable analytical detection limits) to 46.1 ug/ft2. One wipe sample collected from the supply air register in the Border Patrol main office had a lead concentration of 208 ug/ft2.

Given that the Border Patrol officers use the firing range, it is possible the elevated lead level is due to foot traffic from the firing into the Border Patrol offices. The single elevated result does not indicate wide spread cross contamination.

Lead dust remediation is required for the floor surrounding the supply air register in Room BP1 (Figure 8)

Soil Samples

The soil samples were collected at the southwest corner of the firing range and GSA garage. This location was selected because rain and snow melt from the roof surface closest to the firing range exhaust fan

Piegan, Montana Page 6 discharge would fall onto this soil. Although the HEPA filters were damaged and lead dust likely passed through the filters and onto the roof, the soil samples had lead concentrations less than the MDEQ BTV for lead in soil of 29.8 mg/kg. No additional actions are warranted regarding the soil at this location.

Piegan, Montana Page 7

5. Remediation Recommendations

The locations discussed in Section 4 above, Table 1 (in bold font), and Figures 6, 7, and 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.

Figures 6, 7, and 8 are 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 – 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.

Piegan, Montana Page 8

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 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.

Piegan, Montana Page 9

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.

Piegan, Montana

Figures

Appendices

Piegan, Montana

Appendix A Analytical Results Tables

Table 1 Lead-Wipe Results

Table 2 Soil Sampling Results

Piegan, Montana

Table 1 Lead-Wipe Sample Results

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

PIE-3 Exterior door handle into lobby Firing range 301 2'E, N Wall, 3'G 2.6

PIE-4 Interior door handle into lobby Firing range 301 2'E, N Wall, 3'G 4.6

PIE-5

Floor under carpet "Be drug free" at lobby Firing range 301 3'E, 5'N, G 36.1

PIE-6

Carpet sample "Be drug free carpet" at lobby Firing range 301 3'E, 4'N, G 22.6

PIE-7 Floor sample to the north of "Be drug free" carpet in lobby

Firing range 301 3'E, 2'N, G 20.1

PIE-8

Exterior door handle into firing range Firing range 302 W Wall, 7'N, 3'G 7.7

PIE-9

Interior door handle into firing range Firing range 302 W Wall, 7'N, 3'G 2.6

PIE-10 Door handle into bathroom Firing range 303 3'W, S Wall, 3'G 3.6

PIE-11 Bathroom exhaust fan Firing range 303 2'W, 2'S, C 29.3

PIE-12

Bathroom light switch/adjacent wall Firing range 303 2'W, N Wall, 3'G 6.1

PIE-13 Armory door handle lobby side Firing range 305 E Wall, 1'S, 3'G 16.3

PIE-14 Armory door handle armory side

Firing range 305 W Wall, 3'N, 3'G 14.3

PIE-15 Wall near light switch armory Firing range 305 W Wall, 4'N, 3'G 16.0

PIE-16

Under control panel on instructors desk Firing range 302 2'W, 3'N, 2'G 13.5

PIE-17 Floor at instructors desk Firing range 302 2'W, 3'N, 2'G 25.9

PIE-18 Instructors chair Firing range 302 4'W, 3'N, 3'G 51.2

PIE-19

Track gear box interior surface at lane 2 (Black box w/ #2 above shooting station)

Firing range 302 3'W, 9'N, 8'G 36.3

PIE-20

Upper surface of canned light panel located above shooting stations Firing range 302 5'E, 5'N, C 5.2

PIE-21

Supply air perforated diffuser bottom 1 ft (entire north wall is the diffuser)

Firing range 302 5'E, N Wall, 1'G 88.2

PIE-22

Supply air perforated diffuser top near ceiling 1 ft from ceiling

(entire north wall is the diffuser)

Firing range 302 4'E, N Wall, 1'C 18.4

PIE-23 Firing station panel wall-staion 1 Firing range 302 W Wall, 8'N, 4'G 11.1

Piegan, Montana

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

PIE-24 Firing station panel wall-station

Firing range 302 5'E, 8'N, 4'G 34.6

PIE-25

Bottom surface of glass light diffuser-1 Firing range 302 5'E, 24'N, C 252

PIE-26

Upper surface of glass light diffuser-1 Firing range 302 5'W, 24'N, C 974

PIE-27 Floor 1 Firing range 302 6'E, 32'N, G 22.4

PIE-28 Floor 2 Firing range 302 4'E, 72'N, G 22.9

PIE-29 Wall 1 Firing range 302 W Wall, 24'N, 3'G 38.3

PIE-30 Wall 2 Firing range 302 E Wall, 54'N, 4'G 66.0

PIE-31 Upper surface of baffle Firing range 302 3'E, 52'N, C 438

PIE-32 Lower surface of baffle Firing range 302 4'W, 52'N, C 69.5

PIE-33 Track 1 Firing range 302 3'W, 38'N, 7'G 536

PIE-34 Track 2 Firing range 302 3'E, 38'N, 7'G 762

PIE-35

Deflector panel above bullet trap Firing range 302 5'W, 4'S, 8'G 178

PIE-36 Floor front of fan Firing Range Exhaust fan mech room 4'W, 2'N, G 10,295

PIE-37 Floor left side of fan Firing Range Exhaust fan mech room

1'W, 2'S, G 3,906

PIE-38 Ceiling Firing Range Exhaust fan mech room 4'W, 3'S, C 23.8

PIE-39

Discharge side of HEPA filters -floor (remove HEPA filter from filter bank)

Firing Range Exhaust fan mech room

3'E, 4'S, G 183,180

PIE-40

Discharge side of HEPA filters - East side of unit (remove HEPA filter from filter bank)

Firing Range Exhaust fan mech room

1'E, 4'S, 4'G 488

PIE-41

Exterior surface of ceiling fan coil unit Firing Range Exhaust fan mech room 4'W, 3'S, 5'G 4,357

PIE-42 Inlet side of furnace air filter Mechanical 304 3'E, 1'S, 6'G 36.6

PIE-43

Discharge side of furnace air filter Mechanical 304 6'E, 1'S, 6'G 202

PIE-44 Supply air diffuser Garage bathroom 307 3'W, 4'S, C 397

PIE-45 Exhaust grill Garage bathroom 307 2'W, 1'N, C 9.1

PIE-46 Supply air diffuser Garage office 306 2'W, 2'N, C 703

PIE-47 Return air grill Garage office 306 2'E, 2'N, C 75.2

PIE-48 Floor GSA Garage entrance into firing range exhaust fan -

2'W, 6'S, G 2,745

PIE-49 Tactical equipment Vehicle garage south bay

5'E, 1'S, 2'G 5.0

Piegan, Montana

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

PIE-50 Entrance key pad Vehicle garage middle bay

403, 404,405 E Wall, 10'S, 5'G 5.7

PIE-51 Top of fammable cabinet Vehicle garage middle bay

403, 404,405 1'W, 30'S, 7'G 9.7

PIE-52 South wall light switch Vehicle garage middle bay 403, 404,405

1'E, S Wall, 4'G 1.8

PIE-53 Tactical equipment Vehicle garage north bay

406, 407 11'W, 1'N, 5'G 2.6

PIE-54 Desk Vehicle garage north bay

406, 407 8'W, 2'N, 3'G 92.2

PIE-55 Door handle north door interior

Vehicle garage north bay 406, 407

2'E, N Wall, 4'G BRL

PIE-56 Floor near tactical equipment Vehicle garage north bay

406, 407 5'W, 2'N, G 26.7

PIE-57 Wall above tactical equipment Vehicle garage north bay

406, 407 5'W, N Wall, 6'G BRL

PIE-58 Tactical training mats 1 Secondary Inspection 202 16'E, 13'S, 7'G 1.7

PIE-59 Tactical training mats 2 Secondary Inspection 202 16'E, 11'S, 7'G 3.3

PIE-60 Tactical training mats 3 Secondary Inspection 202 16'E, 13'S, 5'G 2.5

PIE-61 Underside of reflector at radiant heater (ceiling)

Secondary Inspection 202 18'E, 13'S, 12'G 3.6

PIE-62 Top of blue weapon safe Secondary Inspection 201 1'E, 10'S, 5'G 10.0

PIE-63 Front of blue weapon safe Secondary Inspection 201 1'E, 9'S, 4'G 3.6

PIE-64 Top of stainless steel table Secondary Inspection 201 17'E, 20'S, 4'G 1.3

PIE-65 West wall above light switch Secondary Inspection 201 W Wall, 13'S, 6'G 1.5

PIE-66 Officer counter MPB Lobby 103 36'E, 16'S, 5'G BRL

PIE-67 Officer phone MPB Lobby 103 16'E, 16'S, 3'G BRL

PIE-68 Floor 1 MPB OFO Pit Desks 5'E, 12'S, G BRL

PIE-69 Floor 2 MPB OFO Pit Desks 24'E, 26'S, G BRL

PIE-70 Desk 1 MPB OFO Pit Desks 18'E, 20'S, 3'G BRL

PIE-71 Desk 2 MPB OFO Pit Desks 22'E, 30'S, 3'G BRL

PIE-72 Phone 1 MPB OFO Pit Desks 14'W, 14'S, 3'G 1.6

PIE-73 Phone 2 MPB OFO Pit Desks 18'E, 27'S, 3'G 1.3

PIE-74 Chair 1 MPB OFO Pit Desks 18'E, 21'S, 2'G BRL

PIE-75 Chair 2 MPB OFO Pit Desks 12'W, 8'N, 2'G BRL

PIE-76

Back of door (room side) coat hook MPB 108 2'W, N Wall, 5'G BRL

PIE-77 Window shelf MPB west inspection W Wall, 2'S, 4'G 1.3

PIE-78 Floor under window (carpet) MPB west inspection 3'W, 2'S, G BRL

PIE-79 Return grill MPB 110 6'E, 1'S, C BRL

Piegan, Montana

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

PIE-80

Dust on top of thermostat cover (1/4 sf) MPB 110 4'E, N Wall, 5'G BRL

PIE-81 Top of cabinet above desk MPB 110 7'W, 1'S, 6'G 1.8

PIE-82 Exhaust grill MPB 111 8'E, 1'N, C 1.5

PIE-83 Light switch (1/4 sf) MPB 111 E Wall, 5'S, 3'G BRL

PIE-84 Wall MPB 111 5'E, S Wall, 3'G BRL

PIE-85 Floor MPB 113 5'E, 3'N, G 1.4

PIE-86 Vacuum beater bar MPB 113 7'W, 2'N, G 3.5

PIE-87 Return grill MPB 105 7'E, 3'S, C 37.3

PIE-88 Phone MPB 105 1'E, 6'N, 3'G BRL

PIE-89 Wall near light switch MPB 105 E Wall, 4'S, 4'G BRL

PIE-90 Return grill MPB 116 2'E, 2'S, C 3.7

PIE-91 Supply air diffuser MPB 116 3'W, 2'S, C 1.9

PIE-92 Wall near light switch MPB 116 1'W, N Wall, 4'G BRL

PIE-93 Floor MPB 116 6'W, 4'S, G 2.9

PIE-94 Return grill MPB 112 5'W, 5'N, C 6.2

PIE-95 Supply diffuser MPB 112 7'W, 5'N, C 7.0

PIE-96 Floor MPB 112 4'W, 6'S, G 2.8

PIE-97 Wall near light switch MPB 117 4'W, S Wall, 4'G 2.8

PIE-98 Floor MPB 117 4'W, 5'S, G 2.0

PIE-99 Shelf MPB 117 1'E, 6'S, 7'G 1.5

PIE-100 Wall near light switch MPB 118 4'W, S Wall, 5'G BRL

PIE-101 Floor MPB 118 5'W, 3'S, G BRL

PIE-102 Shelf MPB 118 1'E, 6'N, 3'G BRL

PIE-103 Wall near light switch MPB 119 5'W, S Wall, 5'G BRL

PIE-104 Floor MPB 119 5'W, 8'S, G BRL

PIE-105 Shelf MPB 119 1'W, 6'N, 3'G 1.7

PIE-106 Wall near light switch MPB 120 4'E, S Wall, 4'G 2.1

PIE-107 Floor MPB 120 4'E, 3'S, G BRL

PIE-108 Shelf MPB 120 1'W, 3'S, 5'G 5.2

PIE-109 Floor North stairs 3'E, 3'S, G 1.5

PIE-110 Handrail North stairs W Wall, 9'S, 3'G 2.6

PIE-111 Return grill MPB 123 7'W, 6'S, C 97.3

PIE-112 Light switch (1/4 sf) MPB 123 W Wall, 4'S, 5'G BRL

PIE-113 Desk 1 MPB 123 1'E, 3'S, 3'G 5.1

PIE-114 Desk 2 MPB 123 4'W, 3'N, 3'G 39.8

PIE-115 Phone 1 MPB 123 1'W, 1'N, 3'G 1.7

PIE-116 Phone 2 MPB 123 1'E, 1'S, 3'G 1.9

PIE-117 Floor MPB 123 9'E, 7'S, G BRL

Piegan, Montana

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

PIE-118 Chair MPB 123 2'E, 3'N, 2'G 4.2

PIE-119 Return grill MPB 124 5'W, 1'N, C 18.2

PIE-120 Wall at light swtich MPB 124 W Wall, 3'N, 5'G BRL

PIE-121 Floor MPB 124 6'W, 4'N, G BRL

PIE-122 File cabinet MPB 124 2'E, 2'N, 4'G BRL

PIE-123 Interior door handle MPB 125 W Wall, 3'S, 3'G BRL

PIE-124 Floor MPB 125 5'E, 3'S, G BRL

PIE-125 Light switch MPB 125 W Wall, 5'S, 4'G 1.6

PIE-126 Return grill MPB 147 3'W, 1'N, C BRL

PIE-127 Wall at light swtich MPB 147 3'E, N Wall, 3'G 1.5

PIE-128 Floor MPB 147 4'W, 6'N, G BRL

PIE-129 Return grill MPB 146 3'W, 1'N, C BRL

PIE-130 Wall at light swtich MPB 146 3'W, N Wall, 2'G 2.3

PIE-131 Floor MPB 146 4'E, 5'N, G BRL

PIE-132 Exhaust grill MPB 145 1'E, 6'N, C BRL

PIE-133 Wall at light swtich MPB 145 W Wall, 5'N, 3'G 131

PIE-134 Return grill MPB 131 2'W, 3'S, G 3.5

PIE-135 Floor at entrance MPB 131 4'W, 4'S, G BRL

PIE-136 Blue weapon cabinet MPB 131 3'E, 2'N, 4'G 2.0

PIE-137 Exterior of orange bullet trap MPB 131 3'E, 6'S, 4'G 2.0

PIE-138 Phone MPB 131 E Wall, 7'S, 5'G BRL

PIE-139 Dusty top of upper cabinets MPB 131 1'E, 5'N, 8'G 3.4

PIE-140 Exhaust grill MPB 135 7'E, 10'N, C BRL

PIE-141 Locker handle #23 MPB 135 2'W, 7'N, 3'G BRL

PIE-142 Locker handle #28 MPB 135 6'W, 2'N, 3'G BRL

PIE-143 Upper surface of locker #24 MPB 135 1'W, 4'N, 7'G 19.8

PIE-144 Upper surface of locker #27 MPB 135 4'W, 11'N, 7'G 15.6

PIE-145 Exhaust grill MPB 137 8'E, 5'N, C 8.0

PIE-146 Locker handle #18 MPB 137 2'W, 7'N, 3'G 5.8

PIE-147 Locker handle #6 MPB 137 3'E, 2'N, 3'G BRL

PIE-148 Upper surface of locker #11 MPB 137 7'W, 7'N, 7'G BRL

PIE-149 Upper surface of locker #15 MPB 137 7'W, 1'N, 7'G 10.1

PIE-150 Return grill MPB 138 3'E, 5'S, C BRL

PIE-151 Window sill MPB 138 1'E, 4'S, 3'G 1.3

PIE-152 Wall at light switch MPB 138 W Wall, 1'S, 5'G 23.4

PIE-153 Floor return air grill BP 1 1'W, 12'N, G BRL

PIE-154 Chair BP 1 6'W, 12'N, 2'G 1.8

PIE-155 Phone BP 1 7'E, 3'S, 3'G BRL

PIE-156 Top of cabinet BP 1 1'E, 7'S, 5'G 6.9

Piegan, Montana

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

PIE-157 Floor return air grill BP 2 1'W, 3'N, G 41.5

PIE-158

Wall below shelf to left of coyote pelt BP 2 W Wall, 9'N, 3'G 30.7

PIE-159 Floor return air grill BP 3 1'E, 16'N, G 46.1

PIE-160 Wall BP 3 W Wall, 6'S, 4'G BRL

PIE-161 Floor return air grill (1/2 sf) BP 4 4'E, 1'S, G 2.4

PIE-162 Wall BP 4 E Wall, 4'S, 4'G BRL

PIE-163 AHU 1 - Discharge side of pre-filter

Mech room 10'E, 12'S, 1'G 14.6

PIE-164

AHU 2 - Discharge side of pre-filter Mech room 18'E, 7'N, 1'G 8.9

PIE-165

Crawlspace AHU for BP -

Discharge side of filter Crawlspace In crawlspace 208

PIE-166 Blank Secondary Inspection 202 Blank BRL

PIE-167 Blank MPB Lobby 103 Blank BRL

PIE-168 Blank MPB 118 Blank BRL

PIE-169 Blank MPB 119 Blank BRL

PIE-170 Blank MPB 123 Blank BRL

PIE-171 Blank MPB 131 Blank BRL

PIE-172 Blank BP 1 Blank BRL

PIE-173 Blank MPB 138 Blank BRL

PIE-174 Blank MPB 146 Blank BRL

PIE-175 Blank MPB 125 Blank BRL

PIE-176 Blank Bay 402 Blank BRL

PIE-177 Blank Bay 407 Blank BRL

PIE-178 Blank Firing Range 301 Blank BRL

PIE-179 Blank Firing Range 302 Blank BRL

PIE-180 Blank Firing Range 307 Blank BRL

PIE-181 Blank Firing Range 310 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.

ug/ft2 – micrograms per square foot N – North S – South E – East W – West AHU – Air Handling Unit

G – ground C – Ceiling Bldg -- Building BRL – Below Reporting Limit sf – square feet ‘ – foot rm – room NS – Not Sampled Bold – samples exceed the GSA Guidance value of 200 ug/ft2

Piegan, Montana

Table 2 Soil Sampling Results

Sample # Room # Material Description

Sample Location

Results (mg/kg)

PIE-1

Soil sample west of firing range

Outside east of GSA garage/firing range 8'W of SW door 10.8

PIE-2 Soil sample north of firing range

Soil sample at north outside entrance into firing range

8'N of N door 10.1

Notes:

mg/kg – milligrams per kilogram W – West SW – Southwest N – North

Piegan, 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 355278-1 Project # / PO #: 11634606.8000 Project Description:

RES 355278-1

Sincerely, July 19, 2016

Dear Customer, Reservoirs has analyzed the following sample(s) using Atomic Absorption Spectroscopy (AAS) / Atomic Emission Spectroscopy - Mass Spectrometry (ICP-MS) 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-Piegan

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 Reporting LEAD

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

PIE-1 EM 1667116 1.6 10.8

PIE-2 EM 1667117 1.4 10.1

Analyst / Data QA:__________________________

July 12, 2016

24 Hour

USEPA SW846 3050B / 6020A

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

July 15, 2016

GSA-Piegan

RES 355278-1

Pinyon Environmental Engineering 11634606.8000

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

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)

PIE-3 EM 1667118 1.00 2.6 1.3 2.6

PIE-4 EM 1667119 1.00 4.6 1.3 4.6

PIE-5 EM 1667120 1.00 36.1 1.3 36.1

PIE-6 EM 1667121 1.00 22.6 1.3 22.6

PIE-7 EM 1667122 1.00 20.1 1.3 20.1

PIE-8 EM 1667123 1.00 7.7 1.3 7.7

PIE-9 EM 1667124 1.00 2.6 1.3 2.6

PIE-10 EM 1667125 1.00 3.6 1.3 3.6

PIE-11 EM 1667126 1.00 29.3 1.3 29.3

PIE-12 EM 1667127 1.00 6.1 1.3 6.1

PIE-13 EM 1667128 1.00 16.3 1.3 16.3

PIE-14 EM 1667129 1.00 14.3 1.3 14.3

PIE-15 EM 1667130 1.00 16.0 1.3 16.0

PIE-16 EM 1667131 1.00 13.5 1.3 13.5

PIE-17 EM 1667132 1.00 25.9 1.3 25.9

PIE-18 EM 1667133 1.00 51.2 1.3 51.2

PIE-19 EM 1667134 1.00 36.3 1.3 36.3

PIE-20 EM 1667135 1.00 5.2 1.3 5.2

PIE-21 EM 1667136 1.00 88.2 1.3 88.2

PIE-22 EM 1667137 1.00 18.4 1.3 18.4

PIE-23 EM 1667138 1.00 11.1 1.3 11.1

PIE-24 EM 1667139 1.00 34.6 1.3 34.6

PIE-25 EM 1667140 1.00 252 1.3 252

PIE-26 EM 1667141 1.00 974 1.3 974

PIE-27 EM 1667142 1.00 22.4 1.3 22.4

PIE-28 EM 1667143 1.00 22.9 1.3 22.9

PIE-29 EM 1667144 1.00 38.3 1.3 38.3

PIE-30 EM 1667145 1.00 66.0 1.3 66.0

PIE-31 EM 1667146 1.00 468 1.3 468

PIE-32 EM 1667147 1.00 69.5 1.3 69.5

PIE-33 EM 1667148 1.00 536 1.3 536

PIE-34 EM 1667149 1.00 762 1.3 762

PIE-35 EM 1667150 1.00 178 1.3 178

PIE-36 EM 1667151 1.00 10,295 1.3 10,295

PIE-37 EM 1667152 1.00 3,906 1.3 3,906

PIE-38 EM 1667153 1.00 23.8 1.3 23.8

PIE-39 EM 1667154 1.00 183,180 1.3 183,180

RESERVOIRS ENVIRONMENTAL, INC.

5801 Logan St., Suite 100

Denver CO 80216

TABLE ANALYSIS: LEAD BY WIPE SAMPLING

July 15 - July 18, 2016

RES 355278-1

24 Hour

July 12, 2016

USEPA SW846 3050B / 6020A

Pinyon Environmental Engineering 11634606.8000 GSA-Piegan

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

July 15 - July 18, 2016

RES 355278-1

24 Hour

July 12, 2016

USEPA SW846 3050B / 6020A

Pinyon Environmental Engineering 11634606.8000 GSA-Piegan

PIE-40 EM 1667155 1.00 488 1.3 488

PIE-41 EM 1667156 1.00 4,357 1.3 4,357

PIE-42 EM 1667157 1.00 36.6 1.3 36.6

PIE-43 EM 1667158 1.00 202 1.3 202

PIE-44 EM 1667159 1.00 397 1.3 397

PIE-45 EM 1667160 1.00 9.1 1.3 9.1

PIE-46 EM 1667161 1.00 703 1.3 703

PIE-47 EM 1667162 1.00 75.2 1.3 75.2

PIE-48 EM 1667163 1.00 2,745 1.3 2,745

PIE-49 EM 1667164 1.00 5.0 1.3 5.0

PIE-50 EM 1667165 1.00 5.7 1.3 5.7

PIE-51 EM 1667166 1.00 9.7 1.3 9.7

PIE-52 EM 1667167 1.00 1.8 1.3 1.8

PIE-53 EM 1667168 1.00 2.6 1.3 2.6

PIE-54 EM 1667169 1.00 92.2 1.3 92.2

PIE-55 EM 1667170 1.00 BRL 1.3 BRL

PIE-56 EM 1667171 1.00 26.7 1.3 26.7

PIE-57 EM 1667172 1.00 BRL 1.3 BRL

PIE-58 EM 1667173 1.00 1.7 1.3 1.7

PIE-59 EM 1667174 1.00 3.3 1.3 3.3

PIE-60 EM 1667175 1.00 2.5 1.3 2.5

PIE-61 EM 1667176 1.00 3.6 1.3 3.6

PIE-62 EM 1667177 1.00 10.0 1.3 10.0

PIE-63 EM 1667178 1.00 3.6 1.3 3.6

PIE-64 EM 1667179 1.00 1.3 1.3 1.3

PIE-65 EM 1667180 1.00 1.5 1.3 1.5

PIE-66 EM 1667181 1.00 BRL 1.3 BRL

PIE-67 EM 1667182 1.00 BRL 1.3 BRL

PIE-68 EM 1667183 1.00 BRL 1.3 BRL

PIE-69 EM 1667184 1.00 BRL 1.3 BRL

PIE-70 EM 1667185 1.00 BRL 1.3 BRL

PIE-71 EM 1667186 1.00 BRL 1.3 BRL

PIE-72 EM 1667187 1.00 1.6 1.3 1.6

PIE-73 EM 1667188 1.00 1.3 1.3 1.3

PIE-74 EM 1667189 1.00 BRL 1.3 BRL

PIE-75 EM 1667190 1.00 BRL 1.3 BRL

PIE-76 EM 1667191 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

July 15 - July 18, 2016

RES 355278-1

24 Hour

July 12, 2016

USEPA SW846 3050B / 6020A

Pinyon Environmental Engineering 11634606.8000 GSA-Piegan

PIE-77 EM 1667192 1.00 1.3 1.3 1.3

PIE-78 EM 1667193 1.00 BRL 1.3 BRL

PIE-79 EM 1667194 1.00 BRL 1.3 BRL

PIE-80 EM 1667195 1.00 BRL 1.3 BRL

PIE-81 EM 1667196 1.00 1.8 1.3 1.8

PIE-82 EM 1667197 1.00 1.5 1.3 1.5

PIE-83 EM 1667198 1.00 BRL 1.3 BRL

PIE-84 EM 1667199 1.00 BRL 1.3 BRL

PIE-85 EM 1667200 1.00 1.4 1.3 1.4

PIE-86 EM 1667201 1.00 3.5 1.3 3.5

PIE-87 EM 1667202 1.00 37.3 1.3 37.3

PIE-88 EM 1667203 1.00 BRL 1.3 BRL

PIE-89 EM 1667204 1.00 BRL 1.3 BRL

PIE-90 EM 1667205 1.00 3.7 1.3 3.7

PIE-91 EM 1667206 1.00 1.9 1.3 1.9

PIE-92 EM 1667207 1.00 BRL 1.3 BRL

PIE-93 EM 1667208 1.00 2.9 1.3 2.9

PIE-94 EM 1667209 1.00 6.2 1.3 6.2

PIE-95 EM 1667210 1.00 7.0 1.3 7.0

PIE-96 EM 1667211 1.00 2.8 1.3 2.8

PIE-97 EM 1667212 1.00 2.8 1.3 2.8

PIE-98 EM 1667213 1.00 2.0 1.3 2.0

PIE-99 EM 1667214 1.00 1.5 1.3 1.5

PIE-100 EM 1667215 1.00 BRL 1.3 BRL

PIE-101 EM 1667216 1.00 BRL 1.3 BRL

PIE-102 EM 1667217 1.00 BRL 1.3 BRL

PIE-103 EM 1667218 1.00 BRL 1.3 BRL

PIE-104 EM 1667219 1.00 BRL 1.3 BRL

PIE-105 EM 1667220 1.00 1.7 1.3 1.7

PIE-106 EM 1667221 1.00 2.1 1.3 2.1

PIE-107 EM 1667222 1.00 BRL 1.3 BRL

PIE-108 EM 1667223 1.00 5.2 1.3 5.2

PIE-109 EM 1667224 1.00 1.5 1.3 1.5

PIE-110 EM 1667225 1.00 2.6 1.3 2.6

PIE-111 EM 1667226 1.00 97.3 1.3 97.3

PIE-112 EM 1667227 1.00 BRL 1.3 BRL

PIE-113 EM 1667228 1.00 5.1 1.3 5.1

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

July 15 - July 18, 2016

RES 355278-1

24 Hour

July 12, 2016

USEPA SW846 3050B / 6020A

Pinyon Environmental Engineering 11634606.8000 GSA-Piegan

PIE-114 EM 1667229 1.00 39.8 1.3 39.8

PIE-115 EM 1667230 1.00 1.7 1.3 1.7

PIE-116 EM 1667231 1.00 1.9 1.3 1.9

PIE-117 EM 1667232 1.00 BRL 1.3 BRL

PIE-118 EM 1667233 1.00 4.2 1.3 4.2

PIE-119 EM 1667234 1.00 18.2 1.3 18.2

PIE-120 EM 1667235 1.00 BRL 1.3 BRL

PIE-121 EM 1667236 1.00 BRL 1.3 BRL

PIE-122 EM 1667237 1.00 BRL 1.3 BRL

PIE-123 EM 1667238 1.00 BRL 1.3 BRL

PIE-124 EM 1667239 1.00 BRL 1.3 BRL

PIE-125 EM 1667240 1.00 1.6 1.3 1.6

PIE-126 EM 1667241 1.00 BRL 1.3 BRL

PIE-127 EM 1667242 1.00 1.5 1.3 1.5

PIE-128 EM 1667243 1.00 BRL 1.3 BRL

PIE-129 EM 1667244 1.00 BRL 1.3 BRL

PIE-130 EM 1667245 1.00 2.3 1.3 2.3

PIE-131 EM 1667246 1.00 BRL 1.3 BRL

PIE-132 EM 1667247 1.00 BRL 1.3 BRL

PIE-133 EM 1667248 1.00 131 1.3 131

PIE-134 EM 1667249 1.00 3.5 1.3 3.5

PIE-135 EM 1667250 1.00 BRL 1.3 BRL

PIE-136 EM 1667251 1.00 2.0 1.3 2.0

PIE-137 EM 1667252 1.00 2.0 1.3 2.0

PIE-138 EM 1667253 1.00 BRL 1.3 BRL

PIE-139 EM 1667254 1.00 3.4 1.3 3.4

PIE-140 EM 1667255 1.00 BRL 1.3 BRL

PIE-141 EM 1667256 1.00 BRL 1.3 BRL

PIE-142 EM 1667257 1.00 BRL 1.3 BRL

PIE-143 EM 1667258 1.00 19.8 1.3 19.8

PIE-144 EM 1667259 1.00 15.6 1.3 15.6

PIE-145 EM 1667260 1.00 8.0 1.3 8.0

PIE-146 EM 1667261 1.00 5.8 1.3 5.8

PIE-147 EM 1667262 1.00 BRL 1.3 BRL

PIE-148 EM 1667263 1.00 BRL 1.3 BRL

PIE-149 EM 1667264 1.00 10.1 1.3 10.1

PIE-150 EM 1667265 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

July 15 - July 18, 2016

RES 355278-1

24 Hour

July 12, 2016

USEPA SW846 3050B / 6020A

Pinyon Environmental Engineering 11634606.8000 GSA-Piegan

PIE-151 EM 1667266 1.00 1.3 1.3 1.3

PIE-152 EM 1667267 1.00 23.4 1.3 23.4

PIE-153 EM 1667268 1.00 BRL 1.3 BRL

PIE-154 EM 1667269 1.00 1.8 1.3 1.8

PIE-155 EM 1667270 1.00 BRL 1.3 BRL

PIE-156 EM 1667271 1.00 6.9 1.3 6.9

PIE-157 EM 1667272 1.00 41.5 1.3 41.5

PIE-158 EM 1667273 1.00 30.7 1.3 30.7

PIE-159 EM 1667274 1.00 46.1 1.3 46.1

PIE-160 EM 1667275 1.00 BRL 1.3 BRL

PIE-161 EM 1667276 1.00 2.4 1.3 2.4

PIE-162 EM 1667277 1.00 BRL 1.3 BRL

PIE-163 EM 1667278 1.00 14.6 1.3 14.6

PIE-164 EM 1667279 1.00 8.9 1.3 8.9

PIE-165 EM 1667280 1.00 208 1.3 208

PIE-166 EM 1667281 1.00 BRL 1.3 BRL

PIE-167 EM 1667282 1.00 BRL 1.3 BRL

PIE-168 EM 1667283 1.00 BRL 1.3 BRL

PIE-169 EM 1667284 1.00 BRL 1.3 BRL

PIE-170 EM 1667285 1.00 BRL 1.3 BRL

PIE-171 EM 1667286 1.00 BRL 1.3 BRL

PIE-172 EM 1667287 1.00 BRL 1.3 BRL

PIE-173 EM 1667288 1.00 BRL 1.3 BRL

PIE-174 EM 1667289 1.00 BRL 1.3 BRL

PIE-175 EM 1667290 1.00 BRL 1.3 BRL

PIE-176 EM 1667291 1.00 BRL 1.3 BRL

PIE-177 EM 1667292 1.00 BRL 1.3 BRL

PIE-178 EM 1667293 1.00 BRL 1.3 BRL

PIE-179 EM 1667294 1.00 BRL 1.3 BRL

PIE-180 EM 1667295 1.00 BRL 1.3 BRL

PIE-181 EM 1667296 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

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 July 6 and 7, 2016

Inside air handling unit located in the mechanical room of the Main Port Building. None of the air handling unit samples from the Main Port Building exceeded the GSA limit (Samples PIE-163 and 164).

Inside of the Secondary Inspection Building. None of the samples collected in this building exceeded the GSA limit value (multiple samples).

July 6 and 7, 2016

Blue weapon safe found inside of the Secondary Inspection Building (Samples PIE-62 and 63).

Neither of the samples exceeded the GSA limit.

Radiant heater found in the Secondary Inspection Building (Sample PIE-61). Sample did not exceed the GSA limit.

July 6 and 7, 2016

Main staff area of the Main Port Building. None of the samples collected in this area of the building exceeded the GSA limit

Main staff area of the Main Port Building. None of the samples collected in this area of the building exceeded the GSA limit

July 6 and 7, 2016

Typical flooring material found throughout the Main Port Building. None of the flooring samples in the Main Port Building exceeded the GSA limit

Typical supply air diffuser found throughout the Main Port Building. None of the supply air diffuser samples in the Main Port Building exceeded the GSA limit

July 6 and 7, 2016

View of the firing range. The firing range mechanical room is located on the far side of the range. Five samples from the range and five samples from the mechanical room exceeded the GSA guidance document value (Samples PIE-25, 26, 31, 33, 34, 36, 37, 39, 40, and 41).

View of the hallway leading into the firing range. None of the samples collected in the hallway exceeded the GSA limit (PIE-3, 4, 5, 6, and 7).

July 6 and 7, 2016

View of duct for the Firing Range Building.

Discharge side of furnace air filter sample exceeded the GSA limit (Sample PIE-43)

View of within the Vehicle Garage Building.

None of the samples collected in the building exceeded the GSA limit

Piegan, Montana

Appendix D Background Threshold Values for Inorganics in Montana Soils

Piegan, 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

Piegan, 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…