PCBs Deconstruction Program

(Applies only to projects subject to Planning Review)

1. Verify Program Applicability: Projects applying for building/structure deconstruction 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 Deconstruction Building Permit.
   
   
3.  Conduct sampling of Priority Building Materials per the Protocol: Per the PCBs Application 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 required coordination with the Environmental Protection Agency and other agencies that may take several months. It is recommended that projects conduct this step as early as possible prior to deconstruction (during the project planning process) to minimize delays.

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 Deconstruction 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 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 Deconstruction Building Permit Application: Include the completed CERTIFICATION AND SAMPLING RESULTS to confirm acknowledgement and compliance of all regulatory requirements. 

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-deconstruction 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.