County of Santa Clara

Department of Environmental Health

Hazardous Materials Compliance Division (HMCD)
1555 Berger Drive, Suite 300, San Jose, CA 95112-2716
Phone (408) 918-3400 Fax (408) 280-6479 www.EHinfo.org/hazmat

OFFICIAL NOTICE OF INSPECTION By Mickey.Pierce at 9:36 pm, Apr 09, 2019

Facility ID: FA0274667 Inspection Date: 03/27/2019

Facility Name: TARGET MASTERS WEST
Site Address: 122 MINNIS CL, MILPITAS, CA 95035
HW Generator Type: <1000 KG/MO. ¨ RCRA LQG
Consent to Inspect Granted By: WILLIAM HESKETT, OWNER þ Pictures Taken
¨ Samples Taken

Summary of Violations & Notice to Comply

Program: PR0415251 - HAZARDOUS WASTE GENERATOR - 2205
Inspection Type: ROUTINE INSPECTION
VC Class Violation Corrective Actions Taken

G041 M MANIFEST PROPERLY COMPLETED [3010008]

Facility failed to properly complete a Uniform Hazardous Waste Manifest in
accordance with manifest instructions.
All manifests in past 3 years (18+) document hazardous waste lead
(D008) amounts to range from 600 lbs to 2078 lbs each pickup; however,
the manifest fails to include the reportable quantity (RQ). The RQ for
hazardous waste lead (D008) is 10 lbs. Ensure the RQ is noted.

Additionally, observed manifest # 15349764JJK that failed to include the

accurate number of containers on the original manifest. The receiving
TSDF or transporter appeared to make a correction upon receipt,
indicating 4 instead of 5. Any change to the manifest after it has been
signed by the generator should be identified in the discrepancies area
(box 18) or be accompanied by a notification and acknowledgment by the
generator such as an email.
Submit a manifest correction letter to: DTSC, Generator Information Services
Section, P.O. Box 806, Sacramento, CA 95812-0806, Attn: Manifest
Corrections. Instructions on how to submit a manifest correction letter are
available upon request. [CCR 66262.23]
G110 II MAINTENANCE AND OPERATION OF FACILITY [3030030]
Facility is not maintained or operated in a manner to minimize the possibility of
a fire, explosion, or any unplanned release of hazardous waste to air, soil, or
surface water that could threaten human health or the environment.
Facility is not maintained or operated in a manner to minimize the
possibility of a release of lead to the air, soil or surface water.

Facility has a passive exhaust ventilation system that uses swamp

coolers to create a positive pressure to push the air over the shooter,
towards the back of the range and out the turbine vent on the roof.
The ventilation on the roof has obvious signs of lead dust accumulation
in and around the turbine vents evidenced by gray matter and staining
and supported by lead readings taken in these areas. At time of
inspection, DTSC investigator, Charles Stone, performed a separate
complaint inspection that including testing for lead using a XRF testing
gun. Results of the test indicated lead levels immediately outside the
exhaust on the floor of the roof ranged from 7,000 to 25,000 ppm lead.
Additional measurements were taken approximately 10 feet and 20 feet
from the immediate vent area and ranged from 2,000 to 10,500 ppm lead
(at 10 feet) and from 1,500 ppm to 6,900 ppm lead (at 20 feet). Rain
impacts the roof and directs lead contaminated water to a downspout
and into the parking lot that flows to a nearby storm drain. Additionally,
dry lead fines can be readily blown away if allowed to accumulate.
Maintain and operate the facility in a manner that minimizes potential

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 OFFICIAL NOTICE OF INSPECTION
Facility ID: FA0274667 Inspection Date: 03/27/2019
Facility Name: TARGET MASTERS WEST
Site Address: 122 MINNIS CL, MILPITAS, CA 95035

Summary of Violations & Notice to Comply

VC Class Violation Corrective Actions Taken
emergencies and unplanned releases. [CCR 66265.31, CFR 265.31]
Comments: Facility is a shooting range and generates lead contaminated hazardous waste. Annual generation ranges from
3-6.5 tons per year. Charles Stone, DTSC investigator was also on-site at time of inspection and performed a separate
complaint driven response/investigation.

EPA ID # CAR000242578.

Hazardous waste generated on-site includes:

Lead contaminated HEPA Air filters from vacuums
Lead fines/contaminated paper
Patches/Wipes from cleaning guns
Sweepings containing rubber and lead
Employee PPE (eg tyvec, respirator cartridges)

Range is cleaned with a HEPA filtered vacuum and is emptied into the waste container 3 times a week.
Dry sweeping is performed in the cleaning room behind the range and is used to clear a path of rubber trap pieces prior to
using a HEPA dustless vacuum.
Rubber trap media is placed in a shaker to help sort the sizes of the rubber pieces.
No smelting of spent bullets/casing occurs on-site.
Dud/off-spec bullets are transferred to an individual for originally intended use.
Any rags used in wet cleaning are commercially laundered by Cintas. Moist rags are set out to passively evaporate water
prior to bagging them.
Lead scrap is removed and managed by Arrow Weights.

All manifests reviewed on-site.

Generator copies are sent to DTSC within 30 days.
Reviewed weekly inspections log.

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 OFFICIAL NOTICE OF INSPECTION
Facility ID: FA0274667 Inspection Date: 03/27/2019
Facility Name: TARGET MASTERS WEST
Site Address: 122 MINNIS CL, MILPITAS, CA 95035

Summary of Violations & Notice to Comply

Program: PR0433981 - HAZARDOUS MATERIALS BUSINESS PLAN - BP01
Inspection Type: ROUTINE INSPECTION
VC Class Violation Corrective Actions Taken

B100 II HMBP NOT SUBMITTED [1010002]

Facility operator failed to complete and submit a Hazardous Materials Business
Plan (HMBP) when storing or handling hazardous materials at or above HMBP
reporting thresholds.
Facility is subject to the hazardous materials business plan (HMBP) but
has not submitted a plan.
Within 30 days, electronically submit a HMBP through either the Santa Clara
County CUPA electronic reporting portal (http://FrontCounter.sccgov.org) or
the California Environmental Reporting System (http://cers.calepa.ca.gov). Be
sure to submit all of the elements that comprise a complete HMBP (i.e., Facility
Information, Hazardous Materials Inventory, and Emergency Response and
Training Plans). See
www.sccgov.org/sites/hazmat/programs/Pages/ereporting.aspx for more details
on electronic reporting. [HSC 6.95 25505, 25508 (a)(1)]
B125 M HMBP FACILITY PROPERTY OWNER NOTIFICATION [1010012]
Operator of a facility located on leased or rented real property failed to notify
the property owner in writing that the facility is subject to and in compliance
with Hazardous Materials Business Plan (HMBP) requirements.
Facility operator does not own the property and has not notified property
owner in writing.
Comply with all other HMBP violations noted in this inspection report and then
provide written notification of compliance to your property owner. Submit a
copy of the notification to HMCD and keep a copy for your records. A sample
notification letter (Form UN-053) is available at www.EHinfo.org/hazmat. [HSC
6.95 25505.1]
B130 II HMBP EMERGENCY RESPONSE TRAINING DOCUMENTATION
[1020002]
Facility operator failed to provide initial and annual training to all employees in
emergency response and safety procedures or failed to document and maintain
training records for a minimum of three years.
Facility does not have documented training demonstrating employees
are trained to the hazardous materials business plan and how to respond
to a release or threatened release of a hazardous material.
Provide initial training for new employees and annual refresher training for all
employees. The training shall cover emergency and safety procedures in the
event of a release or threatened release of a hazardous material, as described
in the facility's Hazardous Materials Business Plan. Training must be
documented electronically or by hard copy. Make training records available for
inspection by HMCD for a minimum of three years. [HSC 6.95 25505(a)(4)]
Comments: Facility handles the following reportable hazardous materials:
Lead Debris (up to 5x55 gal drums or 2,078 lbs)
Immediately correct any violation designated as a Class I or Class II violation. Correct all other violations no later than
04/26/2019, unless otherwise noted by the inspector.

Using the space provided, write a brief description of the actions taken by the facility to correct each violation. Attach additional pages if more
space is needed. Within 5 days of achieving compliance or within 35 days of the inspection date, whichever comes first, sign the certification
statement below and return a copy of this report to HMCD. Time granted for correction of violations does not preclude any enforcement
action by HMCD or other agencies. This facility may be subject to reinspection at any time. [Authority: HSC 25185(c), 25187.8, 25404.1.2(c)]

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 OFFICIAL NOTICE OF INSPECTION
Facility ID: FA0274667 Inspection Date: 03/27/2019
Facility Name: TARGET MASTERS WEST
Site Address: 122 MINNIS CL, MILPITAS, CA 95035

Summary of Violations & Notice to Comply

Received By: Bill Heskett Inspected EE0010344 - JONATHAN BLAZO

Owner By: CA UST Inspector #8215479, Exp. 08/02/2019

Certification of Compliance
I certify under penalty of perjury that this facility has complied with directives specified in this Notice to Comply.

Signature of Owner/Operator Date

Printed Name of Owner/Operator Title

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 OFFICIAL NOTICE OF INSPECTION - SUPPLEMENTAL INFORMATION
This Official Notice of Inspection (NOI) documents the results of an inspection by HMCD, including a list of alleged violations, evidence in support of the alleged violations, corrective
actions that must be taken by the facility, and general observations.

What am I supposed to do upon receiving a NOI?

• Correct the violations within 30 days of the inspection date, unless otherwise noted.
• In the “Corrective Actions Taken” column, write a brief description of the actions taken by the facility to correct each violation. Attach additional pages if more space is needed.
• Certify that the facility has returned to compliance by signing and dating the certification statement at the end of the report.
• Make a photocopy of the NOI and any attachments for your records.
• Within 5 days of achieving compliance or 35 days of the inspection date, whichever comes first, return the original copy of the report and any attachments to HMCD at 1555
Berger Drive, Suite 300, San Jose, CA 95112-2716 or via e-mail to the inspector noted on the "Inspected By" line of the report.

What if there are violations that cannot be corrected within 30 days?

For each violation that cannot be corrected within 30 days, submit a written Compliance Plan describing the corrective actions you propose to take and the date by which the
actions will be completed. State law grants up to 30 days to correct minor violations without penalty. Minor violations that are uncorrected after 30 days, and class I and II
violations may be subject to enforcement action. To lessen the possibility of enforcement action, correct all violations as soon as possible.

What if I disagree with a violation on the NOI?

If you disagree with any violation listed in this NOI, you must submit a written Notice of Disagreement to HMCD within 30 days of the inspection date. Address such notices to the
attention of the inspector who cited the violation. In your Notice of Disagreement, explain in detail why you believe the alleged violation was incorrectly cited.

What about photographs or samples taken during the inspection?

A co-located sample will be given to you upon request if adequate sample volume is available. Photographs and sample analytical results will not generally be available until after
the inspection has been concluded. A copy of photographs and /or analytical results will be provided to you upon written request. Photographs and sample analytical results may be
withheld in the event of a criminal investigation or other ongoing investigation.

Key to Acronyms and Regulatory Terms

XX CCR California Code of Regulations, Title XX
XX CFR Code of Federal Regulations, Title XX
Class Violation classification: I = Class I violation, II = Class II violation, M = Minor violation, C = Corrected minor violation
[HSC §25110.8.5, HSC §25117.6, CCR §66260.10]
CERS California Environmental Reporting System (cers.calepa.ca.gov)
DTSC California Department of Toxic Substances Control
EPA U.S. Environmental Protection Agency
HMCD County of Santa Clara, Department of Environmental Health, Hazardous Materials Compliance Division
HSC California Health and Safety Code
RCRA Resource Conservation and Recovery Act
SCCO Santa Clara County Ordinance Code
TSDF Hazardous waste treatment, storage or disposal facility
UST Underground storage tank
VC HMCD violation code

Warning:
• It is a violation of State law to make a false statement that a facility has returned to compliance [HSC §25404.1.2(c)(2)].
• Making a false statement regarding a hazardous waste violation is punishable by a fine of not less than $2,000 or more than
$50,000 and/or imprisonment in the county jail for up to one year [HSC §25191(b)].
• Making a false statement regarding an underground storage tank violation is punishable by a fine of not less than $500 or more than $5,000
[HSC §§25299(a)(8), 25299(b)(7)].
• HMCD has the right to require the submittal of reasonable and necessary documentation in support of any claim of compliance made
by your facility [HSC §25187.8(i), 25289(b)].
HMCD-014A www.EHinfo.org/hazmat Rev. 01/02/18

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