Reviewer Name: U*M Ommm Applicant: Jefferson PArish Public School System Disaster/Emergeney/FrpgriMM'ilHJJK)|k Mlltf' 11Hurricane Katrina / Public Assistance Program/ EJE 0236 Lincoln Elementary School- Record ofEnvironmental Consideration See 44 Code of Federal Regulation Part 10. Project Name/Number; Lincoln Elementary School-Permanent Repairs / PW 11534 Project Location: 1429 Ames Blvd., Marrero, Louisiana, Jefferson Parish, 70072 Project Description: Project activities involve removing and replacing modified bitumen base sheet, roofinsulation, modified bitumengranularcapsheet, gravel stop,gutter,downspout, rooftop air conditioners, ceiling insulation, wood fiber ceiling tile, vinyl wall molding, VCT flooring, terrazzo tile, gypsumboard,woodpanel,fluorescentlights,bulletinboards,builtuproofwithrockaggregate, wood fibercementroofplanks, fascia, roofdrain,vent stack,lightweightconcrete and windows;polishing terrazzo tile; preparing and painting CMU, concrete floors, gypsum board, doors and panels; and testing fire alarm devices and intercom speakers. A hazard mitigation proposal (HMP) is included to replace the damaged roof with a metal standing seam roof. A hip roof with a low slope pitch would be constructed. New metal stud load bearing framing and purlins would be constructed to support the new roof. Documentation Requirements I I No Documentation Required (Review Concluded) I I (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) E^l (Long version) All applicable laws and executive orders were reviewed. Additional information for compliance is attached to this REC. National Environmental Policy Act (NEPA) Determination I I Statutorily excluded from NEPA review. (Review Concluded) I I Programmatic Categorical Exclusion -Category (Review Concluded) I I Categorical Exclusion -Category I I No Extraordinary Circumstances exist. Are project conditions required? Q Yes (see section V) O No (Review Concluded) I I Extraordinary Circumstances exist (See Section IV). I I Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? Q Yes (see section V) Q No (Review Concluded) I I Environmental Assessment I I SupplementalEnvironmentalAssessment(ReferenceEAorPEAincomments) D><] Environmental Impact Statement Comments: Although this project would have qualified as a CATEX (XV) and (XVI) under 44 CFR Part 10.8 (D)(2), this project meets the definition of critical infrastructure (Permanent Schools) under the Alternative Arrangements for NEPA Compliance. This project has conditions and requires mitigation under the other Environmental and Historic Preservation (EHP) Laws which are listed under the NEPA Level of Environmental Review in the Project Worksheet. Any changes to Record of Environmental Consideration 1 09/11/06 Reviewer Name: Letha Dawson Applicant: Jefferson PArish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program/ EJE 0236 Lincoln Elementary School- Permanent Repairs this approved scope ofwork will require submission to, and evaluation and approval by, the State and FEMA prior to initiation ofany work, for compliance with the National Environmental Policy Act. The applicant is required to obtain and comply with all local, state and federal permits and requirements. Non-compliance with the requirements noted above may jeopardize the receipt of federal funding. Reviewer and Approvals • Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Letha Dawson, Environmental Specialist Signature WJS&AfkX^SXi lJuOCTy— . Date 09/11/2006 FEMA Regional Environmental Officer or delegated approving official. Name: Howard R. Bush, ELO Signature 7*"""^-r* ^-^ . Date 09/11/2006 I. Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act j • Not type ofactivity with potential to affect historic properties. (Review Concluded) 1 E<] Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review. j^ Activity meets Programmatic Allowance #Appendix A, Section {II-E1, II-F2, II-A4, II-A2, II-C1, II-B1, II-H, \ II-B2, II-C2} | Are project conditions required? ^ Yes (see section V) • No (Review Concluded) f HISTORIC BUILDINGS AND STRUCTURES \ • No historic properties that are listed or 45/50 years or older in project area. (Review Concluded) j • Building or structure listed or45/50 years or older in project area and activity not exempt from review. f • Determination ofNo Historic Properties Affected (FEMA fmding/SHPO/THPO concurrence on file) I Are project conditions required? • Yes (see section V) • No (Review Concluded) I • Determination of Historic Properties Affected (FEMA fmding/SHPO/THPO concurrence on file) | • Property aNational Historic Landmark and National Park Service was provided early notification t during the consultation process. If not, explain in comments ( • No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file). J 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) I Are project conditions required Q Yes (see section V) • No (Review Concluded) j ARCHEOLOGICAL RESOURCES f |]x] Project affects only previously disturbed ground. (Review Concluded) f l"~l Project affects undisturbed ground. I l~l 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) I f~l Project area has potential for presence ofarcheological resources j • Determination of no historic properties affected (FEMA finding/SHPO/THPO concurrence on file) j Are project conditions required • Yes (see section V) • No (Review Concluded) I f~l Determination ofhistoric properties affected { • NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). I Record of Environmental Consideration 2 09/11/06 I Reviewer Name: Letha Dawson Applicant: Jefferson PArish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program/ EJE 0236 Lincoln Elementary School- Permanent Repairs Are project conditions required DYes (see section V) • 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? D 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? Q Yes (see section V) • No (Review Concluded) Comments: 09/11/2006 -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 assubmitted in this PW has been reviewed and meets the criteria outlined in Appendix A, Programmatic Allowances, Section (II-El, II-F2, II-A4, II-A2, II-C1, II-B1, II-H, II-B2, II-C2}, ofthe document. In accordance with the PA, FEMA isnot required todetermine the National Register eligibility ofproperties ortosubmit projects tothe State Historic Preservation Officer (SHPO) for review where the work performed meets these allowances. In keeping with the stipulations ofthe PA, all proposed repair activities should be done in-kind tomatch existing materials and form. Any change tothe approved scope ofwork will require resubmission for re-evaluation under Section 106 and consultation with the SHPO. Non-compliance may jeopardize thereceipt offederal funding. This concludes theSection 106 review for this project. V. Gomez, Historic Preservation Specialist Correspondence/Consultation/References: B. Endangered Species Act ^ No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. (Review Concluded) • Listed species and/or designated critical habitat present in the areas affected directly or indirectly by the Federal action. • No effect to species ordesignated 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 on file) (Review Concluded) Are project conditions required? • Yes (see section V) • No (Review Concluded) • Likely to adversely affect species ordesignated critical habitat • Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? • YES (see section V) • NO(Review Concluded) Comments: None Correspondence/Consultation/References: C. Coastal Barrier Resources Act ^ Projectisnotonor connectedtoCBRAUnitorOtherwiseProtectedArea(ReviewConcluded). • Project is on orconnected to CBRA Unit orOtherwise Protected Area. (FEMA determination/USFWS consultation on file) O Proposed action anexception under Section 3505.a.6? (Review Concluded) LZ] Proposed action not excepted under Section 3505.a.6. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: D. Clean Water Act ^ Project would not affect any waters ofthe U.S. (Review Concluded) O Project would affect waters, including wetlands, ofthe U.S. • Project exempted as inkind replacement orother 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) Record of Environmental Consideration 3 09/11/06 Reviewer Name: Letha Dawson Applicant: Jefferson PArish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program/ EJE 0236 Lincoln Elementary School- Permanent Repairs Comments: None Correspondence/Consultation/References: E. Coastal Zone Management Act O Projectisnotlocatedina coastalzoneareaanddoesnotaffectacoastalzonearea (Review concluded) 13 Projectislocated ina coastal zone area and/or affects the coastal zone E<] State administering agency does not require consistency review. (Review Concluded). Q State administering agency requires consistency review. Are project conditions required? • YES (see section V) • NO(ReviewConcluded) Comments: Thisprojectislocated within theLouisianaCoastal Management Zone.LADNRhas determined that receiptoffederalassistanceisconsistentwiththeLouisianaCoastalResourceProgram. ProjectswithintheCoastal ZonemaystillrequireaCoastalUsePermitorotherauthorizationfromDNR. Projectsmaybecoordinatedby contacting LA DNR at 1-800-267-4019. Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act E3 Project does not affect, control, ormodify awaterway/body ofwater. (Review Concluded) (~1 Projectaffects,controlsormodifiesawaterway/bodyofwater. • Coordination withUSFWS conducted • No Recommendations offered byUSFWS. (Review Concluded) O Recommendations provided byUSFWS. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: G. Clean Air Act 13 Project will not result inpermanent airemissions. (Review Concluded) O Projectislocatedinanattainmentarea. (ReviewConcluded) Q Project islocated ina non-attainment area. [~1 Coordination required with applicable state administering agency.. Are project conditions required? O YES (see section V) O NO (Review Concluded) Comments: None Correspondence/Consultation/References: H. Farmland Protection Policy Act E3 Project does not affect designated prime or unique farmland. (Review Concluded) l~1 Projectcausesunnecessaryorirreversibleconversionofdesignatedprimeoruniquefarmland. f~1 Coordination with Natural Resource Conservation Commission required. f~1 Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? Q YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: I. Migratory Bird Treaty Act f~~l Project not located within a flyway zone. (Review Concluded) [3 Project located within a flyway zone. E3Projectdoesnothavepotentialtotakemigratorybirds. (ReviewConcluded) Are project conditions required? • Yes (see section V) [3 No (Review Concluded) Record of Environmental Consideration 09/11/06 Reviewer Name: Letha Dawson Applicant: Jefferson PArish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program/ EJE 0236 Lincoln Elementary School- Permanent Repairs CD Project has potential totake migratory birds. • Contact madewithUSFWS Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/14/2005. Specifically, FEMA has determined that restoration projects funded with federal resources will nothave adverse impacts onmigratory birds orother f fish andwildlife reserves. These determinations arebased ontheunderstanding thatthe conditions outlined inthe Louisiana EndangeredSpecies Summaryare met. Correspondence/Consultation/References: http://pacificflvwav.gov/Documents/Mississippi map.pdf. J. Magnuson-Stevens Fishery Conservation and Management Act [3Projectnotlocatedinor nearEssentialFishHabitat. (ReviewConcluded) • Project located inor near Essential Fish Habitat. • 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) CD NOAA Fisheries provided no recommendation(s) (Review Concluded). Are project conditions required? CD Yes (see section V) • No(Review Concluded) • NOAA Fisheries provided recommendation(s) CD Written reply to NOAA Fisheries recommendations completed. Are project conditions required? CD YES (see section V) CD NO (Review Concluded) Comments: None Correspondence/Consultation/References: K. Wild and Scenic Rivers Act ^ Project is not along and does not affect Wild orScenic River (WSR) -(Review Concluded) • Project isalong oraffects WSR • Project adversely affects WSR as determined 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? CD YES (see section V) CD NO (Review Concluded) Comments: None Correspondence/Consultation/References: L. Other Relevant Laws and Environmental Regulations II. Compliance Review for Executive Orders A. E.0.11988 -Floodplains CD No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded) £3 Located inFloodplain orEffects onFloodplains/Flood levels £3Noadverseeffectonfloodplainandnotadverselyaffectedbythefloodplain. (ReviewConcluded). Are project conditions required? ^ Yes (see section V) CD No(Review Concluded) CD Beneficial Effect on Floodplain Occupancy/Values (Review Concluded). CD Possible adverse effects associated with investment in floodplain, occupancy ormodification offloodplain environment CD 8 Step Process Complete -documentation onfile Areproject conditions required? CD YES (see section V) CD NO (Review Concluded) Comments: 07/19/2006 -The Parish of Jefferson enrolled in the National Flood Insurance Program (NFIP) on 10/1/1971. Per Flood Insurance Rate Map (FIRM) panel number 22051C0135E, dated 03/23/1995, project is located in shaded zone "X", area protected from the 100-yr flood by levee, dike or other structure subject to failure or overtopping during larger Record of Environmental Consideration 5 09/11/06 Reviewer Name: Letha Dawson Applicant: Jefferson PArish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program/ EJE 0236 Lincoln Elementary School- Permanent Repairs floods. Project isrepair offive buildings and replacement ofelectrical components. Per flood recovery guidance, dated 04/12/2006, where possible, all equipment and contents should be elevated at least 3 ft. above the highest adjacent grade elevation. K. Roof, Floodplain Management Specialist. Correspondence/consultation/references: B. E.0.11990-Wetlands S No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located inWetland oreffects Wetland(s) • Beneficial Effect on Wetland -(ReviewConcluded) CD Possible adverse effect associated with constructing in ornear wetland CD Review completed as part offloodplain review • 8StepProcessComplete-documentationonfile Are project conditions required? CD YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: C. E.0.12898 -Environmental Justice For Low Income and Minority Populations G3 No Low income or minority population in, near oraffected by the project -(Review Concluded) CD Low income orminority population in ornear project area • No disproportionately high and adverse impact on low income orminority population-(Review Concluded) CD Disproportionately high oradverse effects on low income orminority population Are project conditions required? CD YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: III. Other Environmental Issues Identify other potential environmental concerns in the comment box not clearly falling under a law or executive order (see environmental concerns scoping checklist for guidance). Comments: None Correspondence/Consultation/References: IV. Extraordinary Circumstances Based on the review of compliance with other environmental laws and Executive Orders, and in consideration of other environmental factors, review the project for extraordinary circumstances. • A"Yes"underanycircumstancemayrequireanEnvironmentalAssessment(EA)withtheexceptionof(ii) whichshouldbeappliedinconjunctionwithcontroversyonanenvironmentalissue. Ifthecircumstancecan be mitigated, please explain in comments. If no, leave blank. Yes CD (0Greaterscopeorsizethannormallyexperiencedforaparticularcategoryofaction CD (ii)Actionswithahighlevelofpubliccontroversy CD (iii) Potential for degradation, even though slight, ofalready existing poor environmental conditions; CD (iv) Employment ofunproven technology with potential adverse effects oractions involving unique or unknown environmental risks; CD (v) Presence ofendangered orthreatened species ortheir critical habitat, orarchaeological, cultural, historical or other protected resources; Record of Environmental Consideration 6 09/11/06 Reviewer Name: Letha Dawson Applicant: Jefferson PArish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program/ EJE 0236 Lincoln Elementary School- Permanent Repairs • (vi) Presence ofhazardous or toxic substances at levels which exceed Federal, state or local regulationsor standardsrequiringactionor attention; CD (vii) Actions with the potential to affect special status areas adversely or other critical resources such as wetlands, coastal zones, wildlife refuge and wilderness areas, wild and scenic rivers, sole or principaldrinkingwateraquifers; • (viii) Potential for adverse effects on health or safety; and • (ix) Potential to violate afederal, state, local or tribal law or requirement imposed for the protection ofthe environment. CD (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 proposedactionmaynotbesignificant bythemselves. Comments: None V. Environmental Review Project Conditions General comments: None Project Conditions: 1. Perfloodrecoveryguidance,dated04/12/2006,wherepossible,allequipmentandcontents shouldbeelevatedatleast3 ft. abovethehighestadjacentgradeelevation. 2. Inkeepingwiththestipulationsofthe PA,allproposedrepairactivitiesshouldbedonein-kind tomatchexistingmaterialsandform. Anychangetotheapprovedscopeofworkwillrequire resubmission for re-evaluation under Section 106 and consultation with the SHPO. Non compliance mayjeopardizethereceiptof federal funding. 3. Unusable equipment, debris and material shall be disposed of in an approved manner and location. Inthe eventsignificantitems(orevidencethereof)arediscoveredduring implementation of the project applicant shall handle, manage, and dispose of petroleum products, hazardousmaterials and/ortoxic waste inaccordance tothe requirements andtothe satisfaction of the governing local, state and federal agencies. 4. Removal and disposal of debris containing household hazardous waste and certain categories of liquid 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 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-up or restoration/repair of sites damaged as a result of such operations are ineligible for federal funding. Previously obligated funding is subject to de-obligation if a determination of ineligibility is made. Applicants managing debris staging, processing, burning or disposal sites (other than previously permitted landfills) that have been permitted by Louisiana Department of Environmental Quality must also complete an Emergency Debris Management Site Certification (Self Certification) regarding compliance with all applicable substantive laws and executive orders. 5. 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 of wood or cellulose material, temporary housing or Record of Environmental Consideration 7 09/11/06 Reviewer Name: Letha Dawson Applicant: Jefferson PArish Public School SystemDisaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program/ EJE 0236 Lincoln Elementary School- Permanent Repairs architectural components (e.g. beams, doors and other wood salvaged from a structure) may not leave the quarantined parishes without written authorization from the commissioner of the Louisiana Department ofAgriculture and Forestry orhis Designee(s). 6. Regardless ofthe asbestos content, the applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana Department of Environmental Quality (LDEQ) in accordance with the LDEQ "Sixth Amended Declaration of Emergency and Administrative Order" dated June 30, 2006 or latest amended declaration, 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 ContainingMaterials(ACMS) bepresentattheprojectsite,theapplicantisalsoresponsiblefor ensuringproperdisposal inaccordance withthepreviouslyreferenced administrative order. 7. Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating Lead Based Paint (LBP) shall comply with applicable provisions of29CFR Parts 1910 and 1926 (OSHA -Worker Safety), and 40 CFR 260 through 268 (EPA -Hazardous Waste). The applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana Department of Environmental Quality for abatement activities and is also responsible for ensuring proper disposal in accordance with the previously referenced regulations. 8. This project potentially involves the disposal ofmetallic mercury containing electronic devices. The applicant is responsible for ensuring that these devices are recovered, recycled, reused or sequestered in accordance with the Louisiana Department of Environmental Quality (LDEQ) "Declaration of Emergency; Mercury-Containing Devices and Electronic Equipment as Universal Waste" letter dated October 3, 2005. Monitoring Requirements: None Record of Environmental Consideration 8 09/11/06