Editor’s Note: The EPA has created a Q&A for PCB testing and remediation that further validates the approach we are currently taking at Malibu High School and Juan Cabrillo Elementary School. Below is a statement from the SMMUSD on the issue.
The United States Environmental Protection Agency (EPA) recently published an update to a document on its website titled “PCBs in Building Materials – Questions & Answers,” dated July 28, 2015.
The document, which can be found at this website address: http://www.epa.gov/pcbsincaulk/pdf/pcb_bdg_mat_qa.pdf, is meant to help school administrators, building owners, managers and occupants better understand the types of building materials that may contain PCBs, the potential for building occupant exposure to PCBs, and how exposure to polychlorinated biphenyls (PCBs) can be assessed and reduced.
This updated EPA document further validates the approach currently taken by the Santa Monica-Malibu Unified School District at Malibu High School (MHS) and Juan Cabrillo Elementary School (JCES):
— To reduce PCB exposures, EPA recommends first removing all PCB-containing fluorescent light ballasts and conducting best management practices (BMPs) on a frequent, ongoing basis to minimize potential exposures to PCBs. Fluorescent light ballasts have been removed from both MHS and JCES and BMPs are currently ongoing.
— If after BMPs there is still concern about possible exposure to PCBs in school indoor air, EPA recommends that the school administrators consult with their EPA Regional PCB Coordinator to assess whether to consider testing indoor air for PCBs. As of May 2015, 250 air samples had been collected from MHS and JCES in consultation with EPA. Further indoor air testing is underway.
— EPA has updated their Exposure Levels for Evaluating PCBs in Indoor School Air in this document. These levels are not intended by EPA to be treated as a bright line above which health risks are presumed to occur. In other words, while the Exposure Levels are health protective and exposures below the set levels would not lead to health risks, exposures above the EPA levels are not automatically presumed to cause harm. Further, EPA notes that “EPA calculated the Exposure Levels for Evaluating PCBs in Indoor School Air so that if children and adults breathed PCBs at or below those levels for the hours per day and the days per year in which school is in session, those PCB exposures would not lead to risks of suffering adverse health effects.” All air samples collected to date from MHS and JCES have been below the EPA age-specific concentrations.
— EPA recommends further steps (which could include additional BMPs, further investigation of potential PCB sources, expanding air testing, or removal of PCB-containing building materials) only if air concentrations exceed their Exposure Levels for Evaluating PCBs in Indoor School Air, which is not the case at MHS and JCES.
— EPA recommends characterizing and removing PCB-containing caulk and other PCB-containing materials during planned building renovations and repair activities. Bulk material sampling for PCBs was conducted in connection with demolition of the Technology building at Santa Monica High School (SAMOHI) and planned modernization of four buildings at Olympic in order to properly characterize demolition debris that will be removed during planned activities for appropriate offsite disposal, as recommended by EPA.
