December 2016
2016 summer break PCB sampling report for Malibu High School and Juan Cabrillo Elementary School, including the appendices.

November 3, 2016
Second update on post-renovation summer 2016 air and surface wipe sampling for PCBs at Juan Cabrillo Elementary School.

October 27, 2016
Update on post-renovation summer 2016 air and surface wipe sampling for PCBs at Juan Cabrillo Elementary School.

September 9, 2016
Interim PCB sampling report from Ramboll Environ on summer 2016 testing at Malibu High School and Juan Cabrillo Elementary School.

September 1, 2016
Federal Judge approves Malibu Modernization Plan

March 29, 2016
United States District Court result of Santa Monica-Malibu Unified School District’s motion for summary judgment on March 28, 2016.

March 22, 2016
The Malibu Times requested information in the form of four questions on March 21, 2016, and SMMUSD responded.

March 7, 2016
Memo - Repair of Damaged Encapsulation

February 10, 2016
Environmental consultant Ramboll Environ provides PCB Health Fact Sheet.

February 1, 2016
EPA letter stating, “…these PCB exposure pathways are currently being addressed by the District in a manner that protects public health.”

November 4, 2015
Superintendent Sandra Lyon addresses vandalism at Malibu High School and Juan Cabrillo Elementary School in a letter to parents and staff

November 4, 2015
USEPA Finds District PCB Related Work Meets EPA Guidelines to Protect Public Health at Malibu High School and Juan Cabrillo Elementary School.

October 2015
PCB Sampling Report - Tables and Figures

September 2, 2015
Summer update on PCBs exposure sampling at Malibu High School and Juan Cabrillo Elementary School.

August 17, 2015
EPA Update Validates SMMUSD’s PCB Testing and Remediation Approach.

August 11, 2015
Update on caulk removal activities at Malibu High School and Juan Cabrillo Elementary School, summarizing caulk removal activities that occurred during the summer 2015 break.

May 1, 2015
SMMUSD continues to inform parents, staff and the community about the important environmental work in progress at Malibu High School and Juan Cabrillo Elementary School.

April 6, 2015
Final Removal Action Completion Report Building G Area

April 2, 2015
SMMUSD environmental consultant, Environ, provided an update on environmental activities at Malibu High School and Juan Cabrillo Elementary School, to the Board of Education at the March 19, 2015 board meeting, held at Malibu City Hall. The board was given an overview of the work done to date, the plan for both schools between now and the end of the school year, and the plan developed for the district as a whole.

March 26, 2015
Approval of Removal Report, Building G Area, March 26, 2015

March 20, 2015
PCB Sampling Notification

February 13, 2015
SMMUSD RELEASES TESTING RESULTS FOR MALIBU SCHOOLS
The Santa Monica-Malibu Unified School District has released an update on recent winter indoor sampling activities related to Polychlorinated Biphenyls (PCBs) at Malibu High School and Juan Cabrillo Elementary School.
The report, authored by the district's environmental consutlat Environ, concludes that the district’s best management cleaning practices have led to indoor air and dust wipe sample test results that are below the USEPA (Environmental Protection Agency) Region IX’s exposure thresholds indicating that classrooms continue to be safe for students and staff. In most cases no PCBs were detected in the samples.

The Board of Education will hold a study session on the environmental issues at both schools at the regularly scheduled board meeting on March 19, 2015, at 5:30 pm at Malibu City Hall. The board will hear a report from Environ detailing the status of the investigations, summary of the cost of the indoor and outdoor investigations relative to the government overseen testing and results; status with the DTSC and EPA, including the approved remediation of the Toxic Substance Control Act (TSCA) regulated caulk, and future environmental activities.

The board will discuss the district’s plans for moving forward with the EPA agreement outlining additional remediation efforts.

Upcoming plans include removal and replacement of all caulk in four classrooms and the woodshop at Malibu High School by June 30, 2014 and the plans for the voluntary removal of light fixtures at Malibu High School prior to school reopening after summer break in August 2015. The woodshop continues to be closed.

Questions about the health of our schools continues to be posed. State, local and federal agencies with expertise and oversight in the areas of public and environmental health have all reviewed the relevant data and concluded that the schools are safe to occupy.

We agreed with the community that questions raised about the health of our buildings needed to be answered, so we engaged those with expertise in this area and invested significant funds in the thorough investigation of the school environment – both in the classrooms and throughout the campus. After reviewing this most recent test data, the experts at EPA confirmed our facilities continue to meet established health standards.

We have reached out to America Unites (formerly Malibu Unites) regarding their independent testing so we may verify the information provided to us. Assuming the sample locations and results can be verified, any caulk in exceedance of TSCA standards will be removed under EPA oversight and subject to EPA approval. The Board of Education is elected to establish policy regarding education, including academic goals, instruction, services and resources; it is not elected to set highly technical, and sometimes subjective, environmental policy. The Board of Education’s actions are based on existing law and state and federal policy – the board does not act on speculative future standards.

We understand the concerns of America Unites. However, it is clear that they are not satisfied with the district meeting current federal and state health standards. Instead they want to change existing environmental health standards and laws. We encourage America Unites and other concerned parents and community members to take their concerns and evidence supporting those concerns to legislators, who in turn will have the ability to consider the evidence and potentially change the current laws. But until that change occurs, the district is bound to follow the statutes and policies currently endorsed by responsible state and federal regulators.

It is every Americans’ right to advocate for change, but this case, that change must be made by a body with expertise and oversight in the areas of public and environmental health. If America Unites’ goal is to change health standards and move environmental regulation down a new path, they should focus their advocacy efforts at the state and federal levels where these topics rightfully belong.

SMMUSD continues to hold the health of our students and staff as our first priority. The district’s investment with its engineering experts, expansive investigation, and interactions with local, state and federal environmental authorities establish this point. As the district continues to meet state and federal laws while modernizing and updating our schools and classrooms, we are able to focus on our area of expertise, that of educating children.

Previous Openings

December 19, 2014

District Publishes Indoor Environmental Testing Summary

SMMUSD has released a report summarizing this year’s indoor environmental work conducted at Malibu High School and Juan Cabrillo Elementary School in response to concerns about PCB contamination. In addition to outlining the scientific process undertaken and once again publicly reporting results that determined the schools were safe based on federally recognized benchmarks, the report also summarizes “Future Monitoring Plans” to address questions by community members about next steps in promoting clean, safe classrooms.

The technical report was developed by ENVIRON International Corporation (ENVIRON), the environmental consultant that conducted the scientific testing program. Inspection and sampling activities were conducted in all nine pre-1981 buildings at MHS and all six pre-1981 buildings at JCES. To evaluate potential exposures to PCBs and the effectiveness of PCB Best Management Practices (BMP) cleaning, the District voluntarily collected 163 air and 504 surface wipe samples. The sampling was compared with health-based screening levels established by the United States Environmental Protection Agency (USEPA), before and after the implementation of BMPs.

“We asked ENVIRON to develop this report to ensure our parents and staff have a solid understanding of the magnitude of the testing program and the results that led the EPA to validate that our schools are safe for students and staff,” said SMMUSD Superintendent Sandra Lyon. “We also want our parents to have a very clear understanding of the future monitoring that will be conducted to ensure our schools are environmentally safe and clean for our students.”

Next Steps
The following cleaning and monitoring steps were part of the plan EPA approved on October 31, 2014 for the four specific areas at MHS (the library and Rooms 1, 5, and 8 in Building E) under EPA’s oversight. The District is voluntarily implementing the plan for all the pre-1981 buildings at MHS and JCES.

Cleaning: While the appropriate frequency of the plan’s specified annual BMP cleaning will continue to be assessed with additional sampling in the future, the results from the June through August 2014 sampling program indicate that a frequency of one annual BMP cleaning is more than sufficient to generally reduce or maintain PCB levels on indoor surfaces and in the indoor air below EPA’s health based benchmarks.

Monitoring: The four areas under specific EPA oversight and a representative subset of randomly chosen, regularly occupied rooms will be re-sampled during the 2014/2015 winter break. These will be air andsurface wipe samples on and around surfaces with high skin exposure potential, such as desks and tables. A similar approach, based on the collective results of the summer 2014 and winter 2014/2015 sampling programs, will be used to select rooms for a June 2015 sampling investigation.

For a year, the Santa Monica-Malibu Unified School District has been addressing environmental issues regarding PCBs. The District has been coordinating with local, state and federal agencies in both the health and education areas to ensure it is providing the most appropriate environmental review in order to address concerns regarding the health and safety of students and staff.

“When these concerns were brought to our attention, we created a task force, began testing and ultimately hired an international environmental engineering firm to help us with all aspects of this issue,” Lyon said. “Our desire from the outset was to make sure our students and staff were safe and that we were taking the appropriate steps as we learned about the situation. The expense has been substantial; however, we have wanted to ensure throughout this process that we are thorough and have the best experts to guide us in decision making.”

As a result of the District’s efforts, District administration has said with confidence that Malibu High School and Juan Cabrillo Elementary are environmentally safe, with tests that have consistently reported PCB levels that were either non-detectable or well below EPA health protective standards. In fact, the EPA has generated three different letters (July 31, 2014; Aug. 14, 2014; and Oct. 31, 2014) supporting the District’s efforts to ensure our schools are safe and clearly stating that SMMUSD is following state and federal laws.

The August 14, 2014 letter was very clear: “The District is meeting EPA national guidelines to protect public health from PCBs in schools by addressing the human exposure pathways of greatest concern, namely air, dust and soil.” The letter also addressed questions from District officials and parents about the need for additional testing, stating that “EPA does not recommend additional testing of caulk unless dust or air samples persistently fail to meet EPA’s health-based guidelines.” The letter also noted, “The Toxic Substances Control Act (TSCA) does not require schools or building owners to test caulk for PCBs.”

Based on continuous implementation of the BMP program, in conjunction with the District’s planned removal of PCB-containing caulk per its EPA-approved plan, EPA has determined that conditions at the schools will continue to protect public health and meet the “no unreasonable risk” TSCA standard until building components are removed during school renovation or demolition. The ongoing efficacy of the BMPs and other approved measures will be verified through periodic evaluations, per the SMMUSD plan.

• DTSC Approval of RAW Plan – MHS, Bldg. G - 12/15/14
• Removal Action Work (RAW) Plan – MHS, Bldg G - 12/17/14

EPA Approves District Plan
MALIBU, Calif. – The Santa Monica-Malibu Unified School District received a letter from the Environmental Protection Agency today, once again validating the District’s plan to address questions surrounding the PCB issue in Malibu High School and Juan Cabrillo Elementary.

In the letter received October 31, 2014 EPA approved the District’s cleanup plan for removal of materials found to contain PCBs at four locations, verification sampling and implementation of best management practices at both schools.

The letter signed by Jared Blumenfeld, Regional Administrator for EPA Region IX, also noted that this approval “requires EPA to make a finding that PCB remediation wastes remaining in place at the two schools will not pose an unreasonable risk of injury to health or the environment. EPA is hereby making a finding that the District meets this TSCA standard for MHS and JCES.”

EPA reemphasized that MHS and JCES are safe environments for students. Both federal and state agencies have been working in collaboration with the District to ensure all laws and regulations are being followed.

Even in the three classrooms and library, where PCBs were identified in caulk at levels regulated by EPA, air and surface wipe test results have been well within EPA’s acceptable standards, indicating no inappropriate health risk of exposure.

The District plan, which was characterized as an aggressive response, proposed on August 15, 2014 includes removal of PCB-containing caulk in the four window area at MHS no later than June 30, 2015. The District also committed to remove impacted light ballasts at both schools by August 15, 2015.

While the testing program conducted over the summer ensured our MHS and JCES buildings are safe, SMMUSD is focused on ensuring our classrooms remain environmentally clean to protect the health and safety of our students and staff. To that end, the District has also committed to do the following:

• Additional indoor air and surface wipe data will be collected around the school’s winter break in the 2014-15 school year, and at the end of the 2015 school year, prior to the next annual summer cleaning. These data, along with data from this summer, will aid in determining future monitoring recommendations for PCBs.
• Continue to conduct Best Management Practices cleaning approved in today's EPA Letter.
• The District has committed to remove caulk identified and verified above regulatory thresholds and light fixtures previously found to contain PCBs, even though dust and air samples have not indicated a health risk. The District submitted to EPA a voluntary proposal that will remove the caulk from four locations at MHS by June 30, 2015. These locations previously tested above 50ppm. The District also included the woodshop in the plan approved today after consultation with EPA. Further, the District will take out light fixtures associated with previously removed PCBcontaining ballasts at MHS and JCES, within a year. This work will ensure the District remains in compliance with TSCA.

September 26, 2014 -- Supplemental Removal Information for Malibu High School, located at 30215 Morning View Drive, Malibu, California pursuant to U.S. Environmental Protection Agency (USEPA) Region IX’s jurisdiction under the Toxic Substances Control Act (TSCA), 40 CFR 761.

August 15, 2014 -- EPA Supports SMMUSD Environmental Test Program, and Does Not Recommend More Testing, As All Building Are Re-Opened for Start of School
MALIBU, Calif. – As the first day of school approaches, EPA officials issued a letter dated August 14th formally validating the District’s environmental testing program, noting that, “The District is meeting EPA national guidelines to protect public health from PCBs in schools by addressing the human exposure pathways of greatest concern, namely air, dust and soil.”

The letter also addressed questions from District officials about the need for additional testing, especially in light of recent offers by celebrity parents to pay for the testing. “EPA does not recommend additional testing of caulk unless dust or air samples persistently fail to meet EPA’s health-based guidelines.” The letter also noted, “The Toxic Substances Control Act (TSCA) does not require schools or building owners to test caulk for PCBs.”

To date, results for the District's intensive environmental testing program conducted over the summer have found that Malibu High and Juan Cabrillo Elementary buildings are safe for students and staff. That determination is based on EPA benchmarks. Air and dust samples have consistently shown PCB levels that are either not detected or well below EPA health benchmarks. The District has not re-opened two rooms, a woodshop room and the psychologist's office, where PCB levels in dust samples exceeded EPA benchmarks. SMMUSD is working, in coordination with the EPA, to clean and re-test those two rooms.

EPA officials also formally concurred with, and agreed to provide oversight of, the District’s plan to remove caulk identified above regulatory thresholds and light fixtures previously found to contain PCBs, even though dust and air samples have not indicated a health risk. The District submitted to EPA a voluntary proposal that will remove the caulk from four locations at MHS by June 30, 2015. These locations previously tested above 50 ppm. The District will also take out light fixtures associated with previously removed PCB-containing ballasts at MHS and Juan Cabrillo Elementary (JCES), within a year. This work will ensure the District remains in compliance with TSCA.

To make certain the buildings continue to be safe, additional data will be collected around the school’s winter break in the 2014/2015 school year, and at the end of the 2015 school year, prior to the next annual summer cleaning. These data, along with data from this summer, will aid in determining future monitoring recommendations. As a result of the scientific process, the District has re-opened all buildings on both campuses, with the exception of the two rooms previously noted, allowing teachers to prepare their classrooms for the start of school. Testing results for each building can be found by clicking the appropriate link/building name.

SMMUSD email to the EPA regarding environmental issues at two Malibu campuses, and the EPA’s response letter regarding the assessment of the work performed during the summer to address the PCB issues at the two Malibu schools.

August 14, 2014: All Buildings Cleared and Re-Opened at Juan Cabrillo Elementary and Malibu High School
As the first day of school quickly approaches, the District re-opened the remaining three buildings at Juan Cabrillo: two classroom buildings (Buildings D & E) and the School Library (Building F). All buildings at JCES have been sampled and cleared with the exception of one administration room that is scheduled to be completed by the end of the week. Another classroom building (Building D) as well as the Woodshop Building (Building G) was cleared on the MHS campus, certifying all nine buildings tested are safe to be re-opened for students and staff. Results for room 303 of the Music Building, where orchestra raisers were removed delaying the sampling process, as well as results for room 506 of Building G, will be announced tomorrow or Monday. In the interim, these rooms remain closed.

August 11, 2014: JCES Classroom Building and MHS Media & Graphic Arts Building are Re-Opened; Soil Tests Come Up Safe
The District recently re-opened Malibu High School's Media & Graphic Arts Building (Building I) – the seventh building to re-open on the MHS campus where nine buildings have been tested. The District has also re-opened another classroom building (Building C) at Juan Cabrillo Elementary – the third building of six. The District also announced results for soil tests at Malibu High and the results of soil tests at Juan Cabrillo, indicating PCB levels are either non-detectible or within the health-based EPA threshold – safe for students and employees.

August 8, 2014: Music Building at MHS Re-Opened, Marks 8th Building Open in Malibu
The Music Building at Malibu High marks the sixth building to re-open on the MHS campus after PCB exposure levels in air and surface wipes tests are below EPA-established benchmarks. In total, the District has re-opened eight buildings, which includes an administration and classroom building at Juan Cabrillo Elementary. The District continues ensure the safety of all teachers, staff and students at the school sites.

August 7, 2014: SMMUSD environmental consultant, Environ, provided an update on environmental activities at Malibu High School and Juan Cabrillo Elementary School, to the Board of Education at the March 19, 2015 board meeting, held at Malibu City Hall. The board was given an overview of the work done to date, the plan for both schools between now and the end of the school year, and the plan developed for the district as a whole. District Maintains Safety as Top Priority, Addresses Dissemination of Misinformation
The District received a letter from PEER, a Washington D.C.-based environmental advocacy group, asserting that the District has threatened that teachers will be terminated if they refuse to occupy classrooms containing toxic compounds. In response, the District maintains that this is a distortion of the truth, has addressed this misinformation and has reiterated that no one will be allowed to go into any classrooms deemed unsafe by environmental experts -- as the health and safety of students and employees remains the District's top priority.

August 6, 2014: Two Buildings at Juan Cabrillo Elementary School are Re-Opened
The District re-opened two buildings at Juan Cabrillo Elementary School -- Administration (Building A) and a classroom building (Building B) – the first buildings to re-open at the elementary school after air and surface wipe testing showed PCB levels that were either non-detectable or below the EPA benchmarks.

August 5, 2014: District Re-Opens Malibu Middle School Building on MHS Campus
The re-opening of the Blue Shark Building at the Malibu Middle School, which is the first classroom building located on the MHS campus to be re-opened, comes days after the District circulated a letter from the EPA to Sen. Barbara Boxer, validating the District’s environmental testing program.

August 4, 2014: Cafeteria/Auditorium Building Reopens at Malibu High School
The District re-opened MHS’ Cafeteria/Auditorium Building – the fourth building to re-open on the campus where nine buildings have been identified by the District for air, surface wipe, and soil testing, after parents raised concerns about PCB exposure.

August 3, 2014: Malibu High School Building E (Blue Shark Building) reopened
Results show that PCB concentrations in all air and final post-cleaning wipe samples are below USEPA criteria, therefore the Best Management Practices (BMPs) cleaning was successful and no additional BMP cleaning in the high-occupancy rooms of Building E is needed.

August 1, 2014: US EPA Stands Behind SMMUSD Environmental Testing Program
In a letter to Senator Barbara Boxer, the US Environmental Protection Agency (EPA) validated the School District’s testing program, noting, “The District has been responsive to [EPA] protocol by taking extensive air and dust samples in classrooms at Malibu High School in preparation for classes to begin in fall, based on EPA-approved procedures.”

July 31, 2014: Malibu High School – Building H (Cafeteria/Auditorium) re-opened
Results show that PCB concentrations in all air and final post-cleaning wipe samples afre below USEPA criteria, therefore the Best Management Practices (BMPs) cleaning was successful and no additional BMP cleaning in the high-occupancy rooms of Building H is needed.

July 28, 2014: Administration (Building B/C) and Library (Building A) Re-open at Malibu High
Results show that PCB concentrations in all air and surface wipe samples within these buildings are below EPA health-based thresholds. As such, the District has re-opened the building, a month ahead of first day of school.

July 18, 2014: Old Gym (Building J) at MHS Re-Opens after Samples Reveal No PCB Exposure Issues
Based on standards established by the EPA, the District's environmental consultant has found that air and surface wipe testing results indicate that PCB levels within the Old Gym at Malibu High are below EPA benchmarks. The District has re-opened the building.
Building A -- Library

As results are reviewed, it is also important to note that the thresholds requested by USEPA for MHS and JCES, for both air and surface wipe samples, are among of the most conservative (health protective) ever mandated by the EPA.

The health and safety of our staff and students is our top priority. In order to ensure students are learning in safe instructional environments, the district’s consultant, Ramboll, is utilizing proven testing and cleaning tactics, according to EPA and DTSC standards and reviewed by those agencies. The testing and cleaning methods used by Ramboll have also been successfully used in other districts with similar concerns. The SMMUSD does not set these standards, nor are we experts in this field. For this reason, we are relying on highly qualified environmental experts and government oversight agencies to move this testing and cleaning program forward.

The district is open to questions, comments, and suggestions regarding the environmental concerns in Malibu. You can send these comments and questions to:
Carey Upton
Chief Operations Officer
cupton@smmusd.org

ENVIRON Response to Malibu Unites - 06/16/14