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Flow Chart for Lead-Based Paint and PCBs


This is an Accessible Version of the flowchart (PDF) for lead-based paint. The Adobe Acrobat Portable Document should be the preferred version for downloading.

This is a flowchart depicting the process districts are required to follow when seeking California Department of Education (CDE) final approval and Department of Toxic Substances (DTSC) determinations when lead-based paint/polychlorinated biphenyls (PCBs) are involved.

Disclaimer: This is a linear list of the decisions from the flowchart and it may not represent the actual flow of information.

Phase 1 without lead-based paint or PCB sampling data, may conclude further investigation is required for only lead/PCB. District submits to DTSC with $1,500.

DTSC approves Phase 1, determines "No Action" required.

Phase 1 without lead-based paint or PCB sampling data, may conclude further investigation is required for only lead/PCB. District submits to DTSC with $1,500.

DTSC approves Phase 1, determines further investigation is required for only lead/PCB via Phase 1 addendum. District commits in writing to do lead/PCB addendum.

District conducts sampling before grading and submits lead/PCB Phase 1 addendum to DTSC.

DTSC approves lead/PCB Phase 1 addendum and determines "No Action" is required.
or
DTSC determines Preliminary Endangerment Assessment (PEA) is required for lead/PCB only.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

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DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 without lead-based paint or PCB sampling data, may conclude further investigation is required for only lead/PCB. District submits to DTSC with $1,500.

DTSC determines Phase 1 is equivalent to a lead/PCB only PEA. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

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DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 without lead-based paint or PCB sampling data, may conclude further investigation is required for only lead/PCB. District submits to DTSC with $1,500.

DTSC determines PEA is required for lead/PCB only. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 without lead-based paint or PCB sampling data, may conclude further investigation is required for only lead/PCB. District submits to DTSC with $1,500.

DTSC concurs PEA is required for lead/PCB and other substance(s).

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

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DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with lead-based paint or PCB sampling data concludes no further investigation is required. District submits to DTSC with $1,500.

DTSC approves PHASE 1, determines "No Action" required.

Phase 1 with lead based paint or PCB sampling data concludes no further investigation is required. District submits to DTSC with $1,500.

DTSC approves Phase 1, determines further investigation is required for only lead/PCB via Phase 1 addendum. District commits in writing to do lead/PCB addendum.

District conducts sampling before grading and submits lead/PCB Phase 1 addendum to DTSC.

DTSC approves lead/PCB Phase 1 addendum and determines "No Action" is required.
or
DTSC determines Preliminary Endangerment Assessment (PEA) is required for lead/PCB only.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

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Phase 1 with lead-based paint or PCB sampling data concludes no further investigation is required. District submits to DTSC with $1,500.

DTSC determines Phase 1 is equivalent to a lead/PCB only PEA. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with lead-based paint or PCB sampling data concludes no further investigation is required. District submits to DTSC with $1,500.

DTSC determines PEA is required for lead/PCB only. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

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DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with lead-based paint or PCB sampling data concludes no further investigation is required. District submits to DTSC with $1,500.

DTSC concurs PEA is required for lead/PCB and other substance(s).

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

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DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with or without lead/PCB data concludes PEA is required for lead and/or PCBs and possibly other substance(s). With DTSC concurrence, District skips Phase 1 review.

DTSC approves Phase 1, determines further investigation is required for only lead/PCB via Phase 1 addendum. District commits in writing to do lead/PCB addendum.

District conducts sampling before grading and submits lead/PCB Phase 1 addendum to DTSC.

DTSC approves lead/PCB Phase 1 addendum and determines "No Action" is required.
or
DTSC determines Preliminary Endangerment Assessment (PEA) is required for lead/PCB only.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

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DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with or without lead/PCB data concludes PEA is required for lead and/or PCBs and possibly other substance(s). With DTSC concurrence, District skips Phase 1 review.

DTSC determines Phase 1 is equivalent to a lead/PCB only PEA. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with or without lead/PCB data concludes PEA is required for lead and/or PCBs and possibly other substance(s). With DTSC concurrence, District skips Phase 1 review.

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DTSC determines PEA is required for lead/PCB only. District commits in writing to do PEA.

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

Phase 1 with or without lead/PCB data concludes PEA is required for lead and/or PCBs and possibly other substance(s). With DTSC concurrence, District skips Phase 1 review.

DTSC concurs PEA is required for lead/PCB and other substance(s).

District signs Environmental Oversight Agreement (EOA), prepares and submits PEA to DTSC.

DTSC approves PEA determines "No Further Action" required.
or
DTSC approves PEA, requires Further Action for only lead/PCB and district commits to do Response Action.
or
DTSC approves PEA, requires Further Action for lead/PCB and other substance, district signs Voluntary Cleanup Agreement (VCA).

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

DTSC requires and District submits lead PCB Supplemental Site Investigation (SSI) to DTSC.

DTSC determines No Further Action required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB only

DTSC certifies Response Action Complete, "No Further Action" required.

DTSC approves Response Action cleanup plan under a VCA and does not object to CDE final approval.

District conducts Response Action for lead/PCB and other substance(s).

DTSC certifies Response Action Complete, "No Further Action" required.

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Questions:   School Facilities and Transportation Services Division| sftsd@cde.ca.gov | 916-322-2470
Last Reviewed: Tuesday, October 24, 2023