ReviewerName: AdamBorden,EnvironmentalSpecialist ProjectName/Env.DatabaseNo:Building#2ClassroomandAssembly FEMA-1603/I607-DR-LA PW#11170 Parish: Jefferson Record of Environmental Consideration REVISED FOR FEMA ENVIRONMENTAL -LOUISIANA -2006 See44CodeofFederalRegulationPart 10 Project Name/Number: Building#2 Classroomand Assembly / PW#11170 FIPS#051-UI84J-00 Project Location: 2001 Airline Dr, Metairie LA 70001, Jefferson Parish Latitude: 29.9747, Longitude: -90.14626 Project Description: Heavy rains and high winds from Hurricane Katrina (DR-1603) caused significant exterior and interior damage to Building #2 Classroom and Assembly ofthe Celebration Christian School and Daycare. This pw reimburses the eligible applicant for repair and/orremoval/replacementofpre-hungdoors includinghardware, 4double door entrances including hardware, 515 1/fofcove base, 3377 s/fofvet flooring, 3924 s/fofinsulation, 3924 s/fofdrywall, 3377s/fofceilingtileandgrid,4entranceframes steel,3377s/fofelectricalwiring.Hazardmitigationwillbeachieved through codes and standards upgrades for replacement material. All work will be performed ina previously disturbed area withnoindicationofnearbywaterways orotherbodiesof water. Documentation Requirements • (Short version) All consultation and agreements implemented to comply with the National Historic Preservation Act, Endangered Species Act, and Executive Orders 11988, 11990 and 12898 are completed and no other laws apply. (Review Concluded) K (Long version) All applicable laws and executive orders were reviewed. Additional information for compliance is attachedtothisRECand/orincludedinprojectfiles, asapplicable. National Environmental Policy Act (NEPA) Determination • Statutorily excluded from NEPA review. (Review Concluded) • Programmatic Categorical Exclusion -Category (Reference PCE in comments) (Review Concluded) d Categorical Exclusion -Category • No Extraordinary Circumstances exist. Are project conditions required? • Yes (see section V) • No (Review Concluded) • Extraordinary Circumstances exist (See Section IV). • Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? • Yes (see section V)• No (Review Concluded) O Environmental Assessment • Supplemental Environmental Assessment (Reference EA or PEA in comments) £3 Environmental Impact Statement Comments: This project meets the criteria for the alternative arrangement, permanent school, type ofproject. This project has conditions and requires mitigation under the other EHP laws. Reviewer and Approvals • Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer: Name:AdamBo/dfn, FEIvfl\.-Environmental Specialist n Bordan, FEMA-Environ Signature. Date 1'IS'Ot, RecordofEnvironmental Consideration(Version07/13/06) re^603/^W7ADR-LAOrde,,, Ettyir°nntttM SpecUlist ProJect N.me/Env. Database No: Building #2 Classroom and Assembly r ff ttrii /u Parish: Jefferson FEMA Regional Environmental Officer orDelegated Approving Official: Name: DonFairley, Environmental Liason Officer Signature /<=*-*-/^ f^ Date -?. /"3-Ot* !• Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act (NHPA) D Not type ofactivity with potential to affect historic properties. S Activity meets Programmatic Agreement, December 3,2004. Appendix A: II-A,B,C, &F Are project conditions required? 03 Yes (see Section V) [JNo U Programmatic Agreement not applicable, must conduct standard Section 106 Review. HISTORIC BUILDINGS AND STRUCTURES D No historic properties that are listed or 45/50 years or older in project area. (Review Concluded) • Building or structure listed or 45/50 years or older in project area and activity not exempt from review. • Determination ofNo Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required? • Yes (see Section V) QNo (Review Concluded) • Determination ofHistoric Properties Affected (FEMA finding/SHPO/THPO concurrence on file) • Property aNational Historic Landmark and National Park Service was provided early notification during the consultation process. Ifnot, explain incomments • No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required? • Yes (see Section V) • No (Review Concluded) • Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) • Resolution ofAdverse Effect completed. (MOA on file) Are project conditions required D Yes (see Section V) • No (Review Concluded) ARCHEOLOGICAL RESOURCES ^ Project affects only previously disturbed ground. (Review Concluded) O Project affects undisturbed ground. • Project area has no potential for presence ofarcheological resources • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence or consultation on file). (Review Concluded) • Project area has potential for presence ofarcheological resources • Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required • Yes (see Section V) • No (Review Concluded) • Determination ofhistoric properties affected • NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required DYes (see Section V) Q No (Review Concluded) • NR eligible resources present in project area. (FEMA finding/ SHPO/THPO concurrence on file) • No Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) Are project conditions required? Q Yes (see Section V) Q No (Review Concluded) • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) • Resolution ofAdverse Effect completed. (MOA on file) Are project conditions required? • Yes (see Section V) • No (Review Concluded) Comments: FEMA's Programmatic Agreement (PA), dated December 3, 2004, provides for expedited project review under Section 106 ofthe National Historic Preservation Act (NHPA). The scope ofwork as submitted in this PW has been reviewed and meets the criteria outlined in Appendix A, programmatic allowances, section (II) (A-1,2,4) (B-l) (C-l) (F-2), of the document. In accordance with the PA, FEMA is not required to determine the national register eligibility of properties or to submit projects to the State Historic Preservation Officer (SHPO) for review where the work performed Record ofEnvironmental Consideration (Version 07/13/06) Reviewer Name: Adam Borden, Environmental Specialist Project Name/Env. Database No: Building #2 Classroom and Assembly FEMA-1603/1607-DR-LA PW#11170 Parish: Jefferson meets these allowances. In keeping with the stipulations ofthe PA, all proposed repair activities should be done in-kind to match existing materials and form. Any change to the approved scope ofwork will require resubmission for re-evaluation underSection106andconsultationwiththeSHPO. Non-compliancemayjeopardizethereceiptoffederalfunding. This concludes the Section 106 review for this project. Correspondence/Consultation/References: NHPA effect determinations made by Richard E. Kuss, FEMA Historic Preservation Specialist. B. Endangered Species Act [3 No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action (Review Concluded) 0 Listedspecies and/or designated critical habitat present in the areas affected directly or indirectly by the Federal action. • No effect to species or designated critical habitat (See comments for justification) Are project conditions required? • Yes (see Section V) • No (Review Concluded) • May affect, but not likely to adversely affect species or designated critical habitat (FEMA determination/USFWS/NMFS concurrence onfile) (Review Concluded) Are project conditions required? • Yes (see Section V) D No (Review Concluded) • Likely to adversely affect species or designated critical habitat • Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? • YES (see Section V) |~| NO (Review Concluded) Comments: Project is located in an urban orpreviously developed area. Neither listed species nor their habitat occur mor near this site, thus FEMA finds there will be no effect to threatened orendangered species. Correspondence/Consultation/References: USFWS emergency consultation provisions determined in letters dated September 15,2005 for Katrina. C. Coastal Barrier Resources Act E Project is not on or connected to CBRA Unit or Otherwise Protected Area (Review Concluded). • Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determination/USFWS consultation on file) • Proposed action an exception under Section 3505.a.6 (Review Concluded) • Proposed action not excepted under Section 3505.a.6. Are project conditions required? • YES (see Section V) • NO (Review Concluded) Comments: Project is not within a CBRA zone. Correspondence/Consultation/References: Louisiana Coastal Barrier Resource System Maps referenced 07/13/06. D. Clean Water Act E] Project would not affect any waters ofthe U.S. (Review Concluded) • Project would affect waters, including wetlands, ofthe U.S. • Project exempted as in kind replacement or other exemption. (Review Concluded) • Project requires Section 404/401/or Section 9/10 (Rivers and Harbors Act) permit, including qualification under Nationwide Permits. Are project conditions required? • YES (see Section V) • NO (Review Concluded) Comments: No jurisdictional waters ofthe U.S., including wetlands, occur in ornear the project area. Correspondence/Consultation/References: USFWS National Wetlands Inventory map (http://www fws eov/nwi/) Queried on 07/13/06. • n E. Coastal Zone Management Act • Project is not located in acoastal zone area and does not affect acoastal zone area (Review concluded) E3 Projectislocatedina coastalzoneareaand/oraffectsthecoastalzone 13State administering agency does not require consistency review. (Review Concluded). LJ State administering agency requires consistency review. Are project conditions required? • YES (see Section V) • NO (Review Concluded) Record ofEnvironmental Consideration (Version 07/13/06) Reviewer Name: AdamBorden, Environmental Specialist Project Name/Env. Database No: Building Ul Classroom and Assembly FEMA-1603/1607-DR-LA PW#11170 Parish: Jefferson Comments: This project is located within the Louisiana Coastal Management Zone. LA Department ofNatural Resources (DNR) has determined that receipt of federal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the coastal zone may still require acoastal use permit or other authorization from DNR. Projects may be coordinated by contactingLA DNR at 1-800-276-4019. Correspondence/Consultation/References: LDNR Louisiana Coastal Zone map 2002. F. Fish and Wildlife Coordination Act ISProjectdoes notaffect, control, ormodifyawaterway/bodyofwater. (Review Concluded) • Project affects controls or modifies awaterway/body ofwater. • Coordination withUSFWS conducted • No Recommendations offered by USFWS. (Review Concluded) O Recommendations provided by USFWS. Are project conditions required? • YES (see Section V) • NO (Review Concluded) Comments'. No streams orwater bodies are located inornear the project area. Correspondence/Consultation/References: Louisiana Map (http://wwwlamap.doa.louisiana.govA queried 07/13/06. G. Clean Air Act • Project will not result in permanent air emissions. (Review Concluded) E3Projectislocatedinanattainmentarea. (Review Concluded) d Project islocated ina non-attainment area. • Coordination required with applicable state administering agency. Are project conditions required? • YES (see section V) D NO (Review Concluded) Comments: This project involves the demolition or renovation ofapublic structure. Regardless ofthe asbestos content, the applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana DepartmentofEnvironmental Quality (LDEQ) in accordance with the LDEQ "Sixth Amended Declaration ofEmergency and Administrative Order" dated March 31,2006, and the LESHAP protocol dated March 1, 2006, incorporating the provisions ofEPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code (LAC) 33.111.5151 and Chapter 27. Should Asbestos Containing Materials (ACMs) be present at the project site, the applicant isalso responsible for ensuring proper disposal in accordance with the previously referenced administrative orders. Correspondence/Consultation/References: EPA Region 6Non-attainment Map. H. Farmland Protection Policy Act G3 Project does not affect designated prime or unique farmland. (Review Concluded) • Project causes unnecessary or irreversible conversion of designated prime or unique farmland. O Coordination with Natural Resource Conservation Commission required. • Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? D YES (see section V) • NO (Review Concluded) Comments: The project site is in adeveloped urbanized area and Farmland Protection Policy Act (FPPA) is precluded. No prime or unique farmland present. Correspondence/Consultation/References: National Resource Conservation Service, Web Soil Survey (http://websoilsurvev.nrcs.usda.^ov/app/ Referenced 07/13/06. I. Migratory Bird Treaty Act • Project not located within a flyway zone. (Review Concluded) ^ Project located within a flyway zone. ^ Project does not have potential to take migratory birds. (Review Concluded) Are project conditions required? • Yes (see section V) ^| No(Review Concluded) • Project has potential to take migratory birds. • Contact made withUSFWS Are project conditions required? • YES (see section V) • NO (Review Concluded) Record of Environmental Consideration (Version 07/13/06) Reviewer Name: Adam Borden, Environmental Specialist ProjectName/Env. Database No: Building#2 Classroom and Assembly FEMA-1603/1607-DR-LA PWM1170 Parish: Jefferson Comments: The site is anexisting disturbed area with little value to migratory birds andwouldnotbe included in the USFWS migratory bird management program. Correspondence/Consultation/References: USFWS guidance letterdatedSeptember15,2005 for Katrina J. Magnuson-Stevens Fishery Conservation and Management Act £>3 Project not located inor near Essential Fish Habitat. (Review Concluded) • Projectlocatedinor nearEssentialFishHabitat. • Project does not adversely affect Essential Fish Habitat. (Review Concluded) Are project conditions required? • Yes (see Section V) • No(Review Concluded) • Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) • NOAA Fisheries provided no recommendation(s) (Review Concluded). Are project conditions required? • Yes (see Section V) • No(Review Concluded) n NOAA Fisheries provided recommendation(s) O Written reply toNOAA Fisheries recommendations completed. Are project conditions required? Q YES (see Section V) • NO (Review Concluded) Comments: Projectisnotlocatedinornearanysurface waters withthepotential toaffectEFHspecies. Correspondence/Consultation/References: Louisiana Map (http://wwwlamap.doa.louisiana:govA referenced 07/13/06. K. Wild and Scenic Rivers Act [3 Project is not along and does not affect Wild orScenic River (WSR) -(Review Concluded) • Project isalong oraffects WSR • Project adversely affects WSR asdetermined by NPS/USFS. FEMA cannot fund theaction. (NPS/USFS/USFWS/BLM consultation on file) (Review Concluded) • Project does not adversely affect WSR. (NPS/USFS/USFWS/BLM consultation on file) Are project conditions required? • YES (see Section V) • NO (ReviewConcluded) Comments: None Correspondence/Consultation/References: National Wild and Scenic Rivers http://www.nps.gov/rivers/wildriverslist.html. referenced 07/13/06. L. Other Relevant Laws and Environmental Regulations State Hazardous Materials and Solid Waste Laws Comments: This project involvesthe demolitionor renovationof a publicstructurethat may containsurfacescoatedwith lead-basedpaint(LBP). Activitiesinvolvingabrading(sanding,scraping,etc.),heating,stripping,orotherwise concentrating LBPshallcomplywithapplicableprovisionsof29CFRparts1910and 1926(OSHA -workersafety),and40 CFR260through268(EPA-hazardouswaste). Theapplicantisresponsibleforensuringthatprojectactivitiesare coordinatedwiththeLouisianaDepartmentofEnvironmental Qualityforabatementactivitiesandisalsoresponsible for ensuring proper disposal in accordance with the previously referenced regulations. -InaccordancewiththeFormosanTermiteInitiativeAct,(LAR.S.3:3391.1 thru3391.13)theLouisianaparishesof Calcasieu, Cameron, Jefferson Davis,Orleans, Jefferson, Plaquemines, St.Bernard, St.Charles, St.JohntheBaptist, St. Tammany,TangipahoaandWashingtonareunderquarantine. Themovementofwoodorcellulosematerial,temporary housing or architectural components (e.g. beams, doors and other wood salvaged from a structure) may not leave the quarantinedparisheswithoutwrittenauthorizationfromthecommissioner oftheLouisianaDepartmentofAgriculture and forestry or his designee(s). -Removalanddisposal ofdebriscontaininghouseholdhazardouswasteandcertaincategoriesofliquidwastesmustbe performedinaccordancewithallapplicablefederalandstatelaws,regulations,executiveordersandguidelines. LACtitle 33partVII requiresthatspecifieditems,includingleadacidbatteries,usedoilfilters,usedmotoroil,scraptires,cfc's (refrigerants), radioactive waste or regulated infectious wastes must be segregated from and excluded from non-hazardous debris collection, staging, processing and disposal sites. Failure to comply with applicable legal requirements in debris collectionand/ordisposaloperationswilljeopardizefederal funding. Theclean-uporrestoration/repairofsitesdamagedas a result of such operations are ineligible for federal funding. Previously obligated funding is subject to de-obligation if a determinationofineligibility ismade. Record of Environmental Consideration (Version 07/13/06) Reviewer Name: AdamBorden, Environmental Specialist Project Name/Env. Database No: Building #2Classroom and Assembly FEMA-1603/1607-DR-LA PW#11170 Parish: Jefferson II. Compliance Review for Executive Orders A. E.0.11988 -Floodplains • No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded) ^ Located in Floodplain orEffects on Floodplains/Flood levels • No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded). Are project conditions required? Q Yes (see Section V) Q No (Review Concluded) • Beneficial Effect on Floodplain Occupancy/Values (Review Concluded). • Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment ^ 8Step Process Complete -documentation on file Are project conditions required? ^ YES (see Section V) • NO (Review Concluded) Comments: The site is located in Zone A99. http://store.msc.fema.gov/webapp/wcs/stores/servlet/FemaWelcomeView?storeld=1OOP1&catalog!d=1OOP1&langld=-1. The Jefferson Parish enrolled in the National Flood Insurance Program (NFIP) as of010/01/1971. Facility is located within an "AE" zone, area of100-yr flooding, base flood elevations and flood hazard factors as determined per Flood Insurance Rate Map (FIRM) panel number 22051C0040 E, dated 03/23/1995. Project is repair ofbuilding and components. In compliance with EO 11988, an 8-step process was completed and is attached. As per 44 CFR 9.11, mitgation or minimization standards must be applied. Where possible, building contents, materials, components and equipment (mechanical orelectrical) must be elevated to or above advisory base flood elevations. Per 44CFR 9.12, afinal public notice is to be published 15 days prior to the start ofany construction activities. Documentation ofcompleted public notice is to be forwarded to FEMA and LA GOHSEP for inclusion in the permanent project files. A. C. Clark, Floodplain Spec. Correspondence/Consultation/References: FEMA Flood Insurance Rate Map, Community Panel No. # 22051C0040 E dated 03/23/1995 B. E.0.11990-Wetlands ^ No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located in Wetland oreffects Wetland(s) • Beneficial Effect on Wetland -(Review Concluded) [U Possible adverse effect associated with constructing in ornear wetland • Review completed as part offloodplain review Q 8Step Process Complete -documentation on file Are project conditions required? • YES (see Section V) • NO (Review Concluded) Comments: No wetlands were observed during site visit ordetermined tobe present by checking the USFWS National Wetlands Inventory(NWI) maps. Correspondence/Consultation/References: USFWS NWI map accessed on-line (http://wetlandsfws.er.usgs.gov/wtlnds/launch.htmn 07/13/06. C. E.0.12898 -Environmental Justice for Low Income and Minority Populations • No Low income or minority population in, near or affected by the project -(Review Concluded) [3 Low income or minority population in or near project area [3 No disproportionately high and adverse impact on low income or minority population-(Review Concluded) • Disproportionately high or adverse effects on low income or minority population Are project conditions required? • YES (see Section V) • NO (Review Concluded) Comments: The percent populations of70001 are: 86.5% White, 7.8% Black and 6.7% Hispanic. The median household income in 1999 was $ 37,094 and 6.1 % of families are below poverty level. Correspondence/Consultation/References: U.S. Census bureau 2000 data at http://factfinder.census.gov. referenced 07/13/06. III. Other Environmental Issues Recordof Environmental Consideration (Version 07/13/06) Reviewer Name: Adam Borden, Environmental Specialist Project Name/Env. Database No: Building #2 Classroom and Assembly FEMA-1603/1607-DR-LA PWM1170 Parish: Jefferson Identify other potential environmental concerns in the comment box not clearly falling under alaw or executive order (see environmental concerns scoping checklist for guidance). StateHazardous Materials andSolidWasteLaws ~ " Comments: Removal and disposalofdebris containinghousehold hazardous waste and certaincategoriesofliquid wastes must be performed in accordance with all applicable federal and state laws, regulations, executive orders and guidelines. LAC title 33 part VII requires that specified items, including lead acid batteries, used oil filters, used motor oil, scrap tires cfc's (refrigerants), radioactive waste or regulated infectious wastes must be segregated from and excluded from nonhazardous debris collection, staging, processing and disposal sites. Failure to comply with applicable legal requirements in debris collection and/or disposal operations will jeopardize federal funding. The clean-up or restoration/repair of sites damaged as aresult ofsuch operations are ineligible for federal funding. Previously obligated funding is subject to de- obligation ifa determinationofineligibility ismade. This project involves the demolition or renovation ofapublic structure that may contain surfaces coated with lead-based paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating LBP shallcomplywithapplicableprovisionsof29CFRparts 1910and 1926(OSHA-workersafety),and40CFR260through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that project activities are coordinated with the Louisiana Department ofEnvironmental Quality for abatement activities and is also responsible for ensuring proper disposal inaccordance with the previously referenced regulations. -In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana parishes of Calcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, St. Charles, St. John the Baptist, St. Tammany, Tangipahoa and Washington are under quarantine. The movement ofwood or cellulose material, temporary housing or architectural components (e.g. beams, doors and other wood salvaged from astructure) may not leave the quarantined parishes without written authorization from the commissioner ofthe Louisiana Department ofAgriculture and forestry or his designee(s). Correspondence/Consultation/Reference: IV. Extraordinary Circumstances Based on the review ofcompliance with other environmental laws and Executive Orders, and in consideration ofother environmental factors, review the project for extraordinary circumstances. *A"Yes" under any circumstance may require an Environmental Assessment (EA) with the exception of (ii) which should be applied in conjunction with controversy on an environmental issue. Ifthe circumstance can be mitigated, please explain in comments. If no, leave blank. Yes • (i) Greater scope orsize than normally experienced for aparticular category ofaction • (ii) Actions with ahigh level ofpublic controversy • (iii) Potential for degradation, even though slight, ofalready existing poor environmental conditions; • (iv) Employment ofunproven technology with potential adverse effects or actions involving uniqueorunknownenvironmental risks; • (v) Presence ofendangered or threatened species or their critical habitat, or archaeological, cultural, historical or otherprotectedresources; • (vi) PresenceofhazardousortoxicsubstancesatlevelswhichexceedFederal,stateorlocal regulations or standards requiring action or attention; • (vii) Actions with the potential toaffect special status areas adversely orother critical resources such as wetlands, coastal zones, wildlife refuge and wilderness areas, wild and scenic rivers, soleorprincipal drinking wateraquifers; • (viii) Potential for adverse effects onhealth orsafety; and • (ix) Potential to violate afederal, state, local or tribal law or requirement imposed for the protection of the environment. Record ofEnvironmental Consideration (Version 07/13/06) ^wTV,-,",?/; Ad,m B°rden' Enviro'"n«n*«l Specialist Project Name/Env. Database No: Building #2 Classroom and Assembly FEMA-1603/1607-DR-LA PW#1U70 . . Parish: Jefferson U (x) Potential for significant cumulative impact when the proposed action is combined with other past, present and reasonably foreseeable future actions, even though the impacts ofthe proposed action may notbesignificant bythemselves. Comments: None V. Environmental Review Project Conditions Project Conditions: The followingconditionsapplyasaconditionofFEMA fundingreimbursement: • This project involves the demolition or renovation ofapublic structure. Regardless ofthe asbestos content, the applicant isresponsible for ensuring that renovation ordemolition activities are coordinated with the Louisiana Department ofEnvironmental Quality (LDEQ) in accordance with the LDEQ "Fifth Amended Declaration of Emergency and Administrative Order" dated March 31,2006, and the LESHAP protocol dated March 1,2006, incorporating the provisions ofEPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code (LAC) 33.III.5151 and Chapter 27. Should Asbestos Containing Materials (ACMs) be present at the project site, the applicant is also responsible for ensuring proper disposal in accordance with the previouslyreferenced administrative orders. • This project involves the demolition orrenovation ofapublic structure that may contain surfaces coated with lead- based paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating LBP shall comply with applicable provisions of29 CFR parts 1910 and 1926 (OSHA -worker safety), and 40 CFR 260 through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that project activities are coordinated with the Louisiana Department ofEnvironmental Quality for abatement activities and is also responsible for ensuring proper disposal in accordance with the previously referenced regulations. • In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana parishes of Calcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, St. Charles, St. John the Baptist, St. Tammany, Tangipahoa and Washington are under quarantine. The movement ofwood orcellulose material, temporary housing or architectural components (e.g. beams, doors and other wood salvaged from a structure) may notleave thequarantined parishes without written authorization from thecommissioner ofthe Louisiana Department ofAgriculture and forestry orhis designee(s). • Removal and disposal ofdebris containing household hazardous waste and certain categories ofliquid wastes must be performed in accordance with all applicable federal and state laws, regulations, executive orders and guidelines. LAC title 33 part VII requires that specified items, including lead acid batteries, used oil filters, used motor oil, scrap tires, cfc's (refrigerants), radioactive waste orregulated infectious wastes must be segregated from and excluded from non-hazardous debris collection, staging, processing and disposal sites. Failure to comply with applicable legal requirements in debris collection and/or disposal operations will jeopardize federal funding. The clean-uporrestoration/repairofsitesdamagedasaresultofsuchoperationsareineligibleforfederal funding. Previously obligated funding is subject to de-obligation ifadetermination ofineligibility is made. • Project is repair ofbuilding and components. In compliance with EO 11988, an 8-step process was completed and is attached. As per 44 CFR 9.11, mitgation or minimization standards must be applied. Where possible, building contents, materials, components and equipment (mechanical or electrical) must be elevated to or above advisorybase flood elevations. Per 44cfr 9.12, afinal public notice is to be published 15 days prior to the start ofany constructionactivities. Documentationofcompletedpublicnoticeistobe forwardedtoFEMAandLAGOHSEP for inclusion in the permanent project files. Record of Environmental Consideration (Version 07/13/06)