May 31, 2020

PCBs Building Demolition Program

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

Requirements Effective July 1, 2019

Purpose of 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 make the fish safer to eat, protect human health, and improve the health of our Bay and aquatic life, sources of PCBs need to be identified and controlled. One common pathway for PCBs to enter the Bay is through urban stormwater runoff. Sources of PCBs are found in certain building materials (e.g., caulks, sealants, insulation, window seals/gaskets and adhesives), specifically from buildings that were built or redeveloped between 1950 and 1980. The Regional Water Quality Control Board requires that local agencies, including Suisun City, develop a screening program to keep PCBs from building materials out of the storm drain systems during the whole building demolition process.

The San Francisco Bay (Bay) Municipal Stormwater Regional Permit (MRP) requires local agencies to:

  1. Develop methods to identify applicable structures and priority materials before demolition;
  2. Develop protocols to ensure that PCBs are not discharged to the storm drain during the demolition of these structures; and
  3. Establish the legal authority for the protocol.

PCBs Screening Protocol
To meet these requirements, on May 21, 2019, the City Council adopted Ordinance No, 759: Amending Chapter 10 of Title 13 (Stormwater Management and Discharge Control) of the Suisun City Municipal Code to implement the Municipal Regional Stormwater Permit mandate to manage Polychlorinated Biphenyls (PCBs)-containing materials during building demolition.

This new screening process is a Bay Area region-wide requirement and will help protect the San Francisco Bay from PCBs pollutants that may be present in building demolition materials. All Bay Area cities are subject to this new requirement as part of the San Francisco Bay (Bay) Municipal Stormwater Regional Permit (MRP).

Starting July 1, 2019, all applicants proposing to demolish a building must complete a PCBs Screening Assessment Form (Download 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.

Notice to Applicants
This Program does not address other environmental programs or regulations (e.g., PCB regulations under the Toxic Substances Control Act; federal, state or local regulations for hazardous material handling and hazardous waste disposal; health and safety practices to mitigate human exposure to PCBs or other hazardous materials; recycling mandates; or abatement at sites with PCBs or other contaminants). The applicant is responsible for knowing and complying with all relevant laws and regulations.

Consultant and Contractor Assistance
Below is a list of Bay Area associations of consultants and contractors who may be able to assist with screening for PCBs:
Association of Environmental Contractors
Association of Northern California Environmental Consultants

Disclaimer: The City of Suisun City provides this list as a courtesy, for informational purposes and for the applicant to conduct its own research. This is not a complete list of associations, contractors or consultants and may not represent current availability of their products and services. It is the applicant’s responsibility to verify the qualifications of any contractor(s) and/or consultant(s). The City is not responsible for any expenses that may be associated with using this resource, nor does the City endorse any contractor or consultant.

Questions about the PCBs Screening Assessment Form
If you have any questions, please contact the Suisun City Building Department staff at (707) 421-7317 or aconner@suisun.com.

Forms and Additional Resources


PCBs Screening Assessment Form 
PCBs in Building Materials Fact Sheet for Municipal Staff 
Fact sheet for Industry Stakeholders 
Bay Area Stormwater Management Agencies Association(BASMAA)-Managing PCBs-Containing Building Materials during Demolition:Guidance,Tools,Outreach and Training(dated November 2019)