PCBs Demolition Program

Image of building demolition
(Source: WASTECOSMART)


Welcome to the NEW Polychlorinated Biphenyls (PCBs) in Priority Building Materials Demolition Program 

Requirements Effective July 1st, 2019

 

The City of Palo Alto’s Polychlorinated Biphenyls (PCBs) in Priority Building Materials Demolition Program (Program), as required by the San Francisco Bay (Bay) Municipal Stormwater Regional Permit (MRP), ensures that PCBs from particular building materials do not enter the storm drain system during whole building demolitions. This page outlines the Program’s compliance requirements for applicable projects applying for building demolitions.
Managing PCBs During Whole Building Demolitions

PURPOSE OF PROGRAM

PCBs have been detected in elevated levels in certain sport fish in the San Francisco Bay (Bay). To make the fish safer to eat and protect human health, PCB sources to the Bay need to be identified and controlled. Urban stormwater runoff is considered a significant pathway for PCBs to enter the Bay. The Regional Water Quality Control Board  requires that Bay Area municipalities address potential sources to urban runoff, including building materials (e.g., caulks, sealants, and insulation) that may contain PCBs from whole building demolitions. 

For more information and resources on PCBs, visit the Regional Water Board’s webpage.

PCBs sources to the Bay
(Source: State of California San Francisco Bay Regional Water Quality Control Board)

COMPLIANCE REQUIREMENTS

For this Program, "Applicable" or "Covered Structures" are defined as buildings constructed or remodeled between January 1, 1950 and December 31, 1980. Buildings that are either wood-framed, single-family residential, or two-family residential (duplex) are exempt and not considered applicable structures regardless of the age of the building.

The following describes general Program requirements. Applicants should review all documents per instructions below for details.

Planning Phase  (Applies only to projects subject to Planning Review)

  1. Verify Program Applicability: Projects applying for building/structure demolitions shall complete and certify the PCBs Applicability section of the Planning Development Review Application.

  2. If Step 1 determines the project to be an applicable building or structure, begin the PCBs Screening Assessment as described in the PCBs Applicant Package: Immediately review the PCBs Applicant Package to determine the Program requirements that must be met in order to receive a Demolition Building Permit.

  3.  Conduct sampling of Priority Building Materials per the Protocol: Per the PCBs Applicant Package, sampling of PCBs concentrations shall be conducted in accordance with the Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition. If sampling indicates PCBs concentrations ≥50 ppm in one or more Priority Building Materials, then the project must contact the appropriate state and federal agencies for notification and advanced approval. Program requirements are considerable, and the required coordination with the Environmental Protection Agency and other agencies may take several months. It is recommended that projects conduct this step as early as possible prior to demolition (during the project planning process) to minimize delays.

Building Permit Phase
NOTE
: If steps during Planning Phase were carried out, skip to Step 3.

  1. Verify Program Applicability: If this step was not completed during the Planning Phase, fill out the Parts 1 and 2 of the PCBs Applicant Package to determine if the project is an applicable building or structure.
    -  If not applicable, also fill out Part 3 to certify and submit with Demolition Building Permit application.
    -  If applicable, go to step 2.


  2. Conduct sampling of Priority Building Materials per the Protocol: Per the PCBs Applicant Package, sampling of PCBs concentrations shall be conducted in accordance with the Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition. If sampling indicates PCBs concentrations ≥50 ppm in one or more Priority Building Materials, then the project must contact the appropriate state and federal agencies for notification and advanced approval. Program requirements are considerable, and the required coordination with the Environmental Protection Agency and other agencies may take several months. It is recommended that projects conduct this step as soon as project is found to trigger Program requirements in order to minimize delays.

  3. Submit the PCBs Screening Assessment Applicant Package with Demolition Building Permit Application: Include the completed CERTIFICATION AND SAMPLING RESULTS to confirm acknowledgement and compliance of all regulatory requirements. 

Sampling Protocol

NOTE: Currently there is no certification program for firms conducting PCBs surveys or abatement. A list of Consultants and Contractors self-determined to be qualified to conduct a pre-demolition PCBs building survey and PCBs abatement is provided by local professional organizations. The City of Palo Alto does not recommend or certify these firms. Click here for more info.

Follow Applicable federal and state laws if PCBs are determined to exist in Priority Building Materials: This may include reporting to U.S. Environmental Protection Agency (EPA), the San Francisco Bay Regional Water Quality Control Board, and the California Department of Toxic Substances Control (DTSC). These agencies may require additional sampling and abatement of PCBs.  

RESOURCES
Background Information
PCBs Ordinance
PCBs Stakeholder Factsheet
National Pollutant Discharge Elimination System (NPDES) permit, Order No. R2-2015-0049
Santa Clara Valley Urban Runoff Pollution Prevention Program Website for PCBs

Applicant Materials
Planning Development Review Application (which includes the PCBs Applicability Section)
Palo Alto’s Online Parcel Reports
PCBs Screening Assessment Applicant Package
Bay Area Stormwater Management Agencies Association’s (BASMAA) Protocol for Evaluating Priority PCBs-Containing Materials before Building Demolition (dated August 2018)