Polychlorinated Biphenyls Building Demolition Ordinance

Polychlorinated Biphenyls (PCBs) Building Demolition Program

Polychlorinated biphenyls (PCBs) are pollutants that have been found at elevated levels in certain species of fish in the San Francisco Bay (Bay). When PCBs enter the ocean, aquatic organisms take them up, including species that humans might consume. According to the US Environmental Protection Agency (EPA), PCBs have been found to cause a variety of adverse health effects to animals, including humans, if ingested.

In order to improve the health of the Bay and protect human health, sources of PCBs need to be identified and controlled. One common pathway for PCBs to enter the Bay is through urban stormwater runoff.  Common materials used in buildings constructed or remodeled between 1950 through 1980 are sources of PCBs (e.g., caulks/sealants, thermal/fiberglass insulation, adhesive/mastic, rubber window seals/gaskets).

The San Francisco Bay Regional Water Quality Control Board requires that local agencies, including Dublin, develop a screening program to keep PCBs from building materials out of the storm drain system during the building demolition process. The Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit requires:

• Developing methods to identify applicable structures and priority materials before demolition;
• Developing protocols to ensure that PCBs are not discharged to the storm drain during demolition of these structures; and
• Establishing the necessary authority for requiring implementation of the protocol via municipal ordinance or other mechanism.

PCBs Screening Protocol

To meet these requirements, on June 4, 2019, Dublin City Council approved an addition to the Dublin Municipal Code, adding Chapter 7.29 to Manage Polychlorinated Biphenyls (PCBs) during the building demolition process.   Starting July 1, 2019, all applicants proposing to demolish a building must complete a PCBs Screening Assessment Form and submit it with the Building Demolition permit application.  City Staff will review the form for completeness and accuracy.  The form will help you determine:

   1. Whether the building proposed for demolition is likely to have PCBs-containing             building materials.
   2. How to conduct representative sampling of priority building materials (if needed).
   3. Whether PCBs are present at a concentration equal to or greater than 50 parts             per million (ppm) in building materials.

When the PCBs in Priority Building Materials Screening Assessment identifies one or more Priority Building Materials containing PCBs, the Applicant must comply with all related applicable federal and state laws, including potential notification of the appropriate regulatory agencies. 

Affected Structures: The requirements apply to whole building demolition of commercial, multi-family residential, public, institutional, and industrial structures constructed or remodeled between 1950 and 1980 in the MRP area: Counties of Alameda, Contra Costa, San Mateo, and Santa Clara, and the Cities of Fairfield-Suisun and Vallejo. Single-family homes and wood-frame structures are exempt.

For questions on the program, please contact the Environmental Services Division at 925-833-6630 or at es@dublin.ca.gov.