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STATE OF CALIFORNIA. Department of Toxic Substances Control Report of Investigative Assistance Case Number: 914942-48 Date of Complaint: 4/23/2019 EPA Number: CAR000212578 Hauler Reg. Number: N/A Date of Report: April 4, 2019 Subject: William Heskett (d.b.a)(a.k..)(c/o): Target Masters West Address: 122 Minnis Circle, Milpitas California 95036 Allegation: Illegal disposal of Hazardous Waste Agency Requesting Assistance: Santa Clara County Environmental Health Agency Contact: Jonathon Blazo Telephone Number: (408) 918-1983 Nature of Request: Sampling assistance Action Taken: On January 23, 2019, |, Investigator Charles Stone received complaint number 1047409 from a member of the public concerning Target Masters West, a firing range in Milpitas located at 122 Minnis Circle, Milpitas California 95035. The complaint states, Target Masters West has allowed lead to escape their property from roof vents to a neighboring gymnastics training facility. The complainant is worried that children may be exposed to high lead levels at this facility. (Exhibit 1) Attached to Exhibit 1, is a Google Earth overview of the relationships between Sweets Gymnastics and Target Master West. According to the California Environmental Reporting System, (CERS) Target Masters West is in an industrial facility next to several automotive repair facilities. Additionally, a plating shop, named CBR Circuits, was abandoned at this site. Reviewing the records available in CERS, | was unable to find any documents showing how CBR was remediated. (Exhibit 2) CERS also reports the facility has one March 6, 2016 inspection, which shows no violations. (Exhibit 3) Because of the unknown history of the businesses, and whether these nearby businesses have deposited lead on site, | conducted a site visit to attempt to determine the presence of lead and it's origin, Prior to my site visit, | coordinated with Santa Clara County Environmental Health, the local Certified Unified Program Agency (CUPA). | contacted Hazardous Materials Specialist Jonathan Blazo and Senior Hazardous Materials Specialist Mickey Pierce. | informed Blazo and Pierce of the complaint and that ! would be bringing the X-ray fluorescence (XRF) for onsite readings. XRF is a non-destructive analytical technique used to determine the elemental composition of materials. XRF analyzers determine the chemistry of a sample by measuring the fluorescent (or secondary) X-ray emitted from a sample when it is excited by a primary X-ray source, Based on available schedules we planned on an unannounced site visit for March 27, 2019. , Report of Investigative Assistance Target Masters West Page 2 ‘On March 27, 2019, | met with Blazo in front of Target Masters West and explained | was using the XRF for screening for lead on the ground and hopefully on the roof of the facllity to determine if there is a direct correlation between lead found at Target Masters West and Sweets Gymnastics. Before we started our inspection, | conducted a self-test of the XRF. | explained the benefit of this is the XRF provides an in-situ screening measurement and can identify the presence of a material and identify areas in which authoritative sampling may be necessary. Screening results of greater that 1,000 ppm of lead is indication of areas that sampling may indicate hazardous levels. NOTE: This does not mean there is a violation under the Health and Safety Code, just the presence of a concentrated material. Because, all the sampling would have been destructive sampling, such as tearing up the roof or the concrete, | was not prepared to take authoritative samples. Additionally, the day of the inspection it was raining and, where possible, | took dry XRF measurements. The first XRF measurement was taken at the front door of Sweets Gymnastics and indicated 1340 ppm of lead. The second sample was in front of Sweet Gymnastics roll up door at 2676 ppm of lead. | then took measurements to the east of Target Masters West. The first was in front of See Clear Cameras (PGE. Access door) with approximately 480 ppm of lead, and under See Clear Camera's front door with 910 ppm of lead At 1008 hours, Blazo and | entered Target Masters West and met with the owner William Heskett. We introduced ourselves and I handed him my business card, Heskett was busy with a customer, but we asked to see him briefly, so we could explain why we were there. Heskett escorted us to backroom where Blazo and | explained the purpose of the visit. | explained that | received a complaint that Target Masters West was allowing lead to be deposited onto the neighboring gymnastics facility and the complaining party was concerned for the safety of the kids at the site. | explained | wanted to use the XRF to take measurements from the roof and surrounding buildings to determine if there is any validity to this allegation. Heskett stated there were older forced air systems that are no longer used but does have an air ventilation and all the air was naturally drawn out of the facility. I then asked Heskett if we could get access to the roof to take measurements with the XRF. Heskett provided us verbal consent and got us the keys to the access the roof. Blazo and | accessed the roof and took samples of the air ducts that were exiting the facility. The roof appeared to be a new, poly lined roof that is either sonically or heat sealed. Target Masters West's roof and ventilation is separated by a short approximately 3-foot wall from Sweets Gymnastics. The ventilation is in groups of three passive air systems. | took readings from the middle of each one of these groups. Using the XRF at the base of Target Masters West's ventilation to approximately 20 feet away, the XRF had readings from as high as 25,000 ppm to just under 7,000 ppm of lead. Note: Lead was found at over 52,000 ppm at the base of the unused ventilation at the rear of the facility. (Exhibit 4) | also took photographs of the area showing how the roof was laid out. (Exhibit 5) Report of Investigative Assistance Target Masters West Page 3 Figure 1 - Roof looking East on TMW roof. Notice the discoloration directly under the vents.