Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0322 Grace King High School Record of Environmental Consideration See44Codeof Federal RegulationPart10. Project Name/Number: EJE0322 Grace King High School/ PW 13345 Project Location: 4301 Grace King Place Metairie, Louisiana Jefferson Parish 70002 (N30.01347 W-90.16519) Project Description: Project activities include replacing six window screens, 12,780 SF vinyl asbestos floor tile, 13,230 SF ceiling tiles, 400 SF wallboard, 600 SF ofplaster walls, 1,501 LF ofvinyl cove wall base, 350 SF gypsum board partitions, 34 fluorescent light fixtures, 26,500 SF of modified bituminous roofing, 26,500 SFofinsulatedroofdecking, four roofmountedexhaustfans &curbs, two intake loTrversr4^0G1SFveloiir stage ciutato,i^^irta^emoTmle^irgfit^^ fixtufe^;iwo exfenofwall mounted floodlights, 120 SF ceiling insulation blankets, 160 LF roof edge cap, 160 LF metal drip edge &gutter, 242 LF metal downspout and 30 LF ofmetal rake trim. Hazard mitigation will be achieved by compliance with codes and standards. Documentation Requirements O No Documentation Required (Review Concluded) [j (Short version) All consultation and agreements implemented to comply with the National Historic PreservationAct,EndangeredSpeciesAct,andExecutive Orders 11988, 11990and12898are completed and no other laws apply. (Review Concluded) £0 (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 [H Statutorily excluded from NEPA review. (Review Concluded) • Programmatic Categorical Exclusion -Category (Review Concluded) Q Categorical Exclusion -Category O No Extraordinary Circumstances exist. Are project conditions required? • Yes (see section V) • No (Review Concluded) O Extraordinary Circumstances exist (See Section IV). • Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? • Yes (see section V) • No (Review Concluded) f~l Environmental Assessment • Supplemental Environmental Assessment (Reference EA or PEA in comments) 1^3 Environmental Impact Statement Comments: This project meets the criteria for an alternative arrangement (Permanent Schools) type ofproject. This project hasconditionsandrequiresmitigationundertheotherEHPlaws whicharelistedunderthe NEPA levelofenvironmental review inthe project worksheet. Any changes tothis 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-compliancewith the requirements noted above may jeopardize the receipt offederal funding. Recordof Environmental Consideration 1 08/22/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA /Hurricane Katrina /Public Assistance Program /EJE 0322 Grace King High School Reviewer and Approvals • Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Catherine Jones, Environmental Specialist Signature ^•^W/eAMJ bKrf t Date 8/22/2006 FEMA Regional Environmental Officer or delegated approving official. Name: Howard R. Bush, ELO Signature /"^— ^^ .Date --8/22/2006 I- Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act ^ Not type ofactivity with potential to affect historic properties. (Review Concluded) • Applicable executed Programmatic Agreement Otherwise, conduct standard Section 106 review. •.Activity meets Programmatic Allowance # Are project conditions required? • Yes (see section V) • No (Review Concluded) HISTORIC BUILDINGS AND STRUCTURES ^ 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) • PropertyaNationalHistoricLandmarkandNationalParkServicewasprovidedearlynotification duringtheconsultationprocess. Ifnot,explainin comments • 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 • Yes (see section V) • No (Review Concluded) ARCHEOLOGICAL RESOURCES E<] Project affects only previously disturbed ground. (Review Concluded) • Project affects undisturbed ground. O 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 ofno historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required • Yes (see section V) • No (Review Concluded) Q Determination ofhistoric properties affected • NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required QYes (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? • Yes (see section V) • No (Review Concluded) • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) Recordof Environmental Consideration 2 08/22/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School SystemDisaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0322 Grace King High School • Resolution ofAdverse Effect completed. (MOA on file) Are project conditions required? • Yes (seesection V) • No (Review Concluded) Comments: 08/22/2006 -According tothe Project Officer, the school was built in 1968. Catherine Jones, Environmental Specialist. Correspondence/Consultation/References: B. Endangered Species Act 13 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 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) (ReviewConcluded) -Areproject conditions re^trired?-tZ] Yertsee section V) |~| No (Review Concluded) • Likely toadversely 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 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: None Correspondence/Consultation/References: D. Clean Water Act 03ProjectwouldnotaffectanywatersoftheU.S. (ReviewConcluded) • 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: Project is not in or adjacent to any waterways of the US. Correspondence/Consultation/References: E. Coastal Zone Management Act • Projectisnotlocatedina coastalzoneareaanddoesnotaffectacoastalzonearea(Reviewconcluded) £3 Project islocatedina coastal zone area and/oraffects thecoastal zone ^ State administering agency does not require consistency review. (Review Concluded). O State administering agency requires consistency review. Are project conditions required? • YES (see section V) • NO(Review Concluded Record of Environmental Consideration 3 08/22/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Pnarter/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina /Public Assistance Program / EJE 0322 Grace King High School Comments: This project is located within the Louisiana Coastal Management Zone. La DNR has determined that receipt of federal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the coastal zone may still require a coastal use permit orother authorization from DNR. Projects may be coordinated by contacting LA DNR at I800- 267-4019.). Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act ^ Projectdoesnotaffect,control,ormodifyawaterway/bodyofwater. (ReviewConcluded) O Projectaffectscontrolsormodifiesawaterway/bodyofwater. • Coordination with USFWS conducted • No Recommendations offered by USFWS. (Review Concluded) • Recommendations provided by USFWS. Are project conditions required? • YES (see section V) Q NO (Review Concluded) Comments: Projectisnotinor adjacenttoany waterwaysoftheUS. G. Clean Air Act S Project will not result in permanent air emissions. (Review Concluded) • Project islocated inanattainment area. (Review Concluded) O Projectislocatedina non-attainmentarea. • Coordination required with applicable state administering agency.. Are project conditions required? • YES (see section V) Q NO (Review Concluded) Comments: None Correspondence/Consultation/References: H. Farmland Protection Policy Act ^ Project does not affect designated prime or unique farmland. (Review Concluded) • Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. • Coordination with Natural Resource Conservation Commission required. • 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 • Project not located within a flyway zone. (Review Concluded) 13 Project located within aflyway 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 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 not have adverse impacts on migratory birds or other fish and wildlife reserves. These determinations are based onthe understanding that the conditions outlined inthe Louisiana EndangeredSpecies Summaryare met. Correspondence/Consultation/References: http://pacificflywav.gov/Documents/Mississippi map.pdf, Record of Environmental Consideration 08/22/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0322 Grace King High School J. Magnuson-Stevens Fishery Conservation and Management Act 03 Project not located in ornear Essential Fish Habitat. (Review Concluded) • Project located inornear 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) • NOAA Fisheries provided no recommendation(s) (Review Concluded). Are project conditions required? • Yes (see section V) • No(Review Concluded) • NOAA Fisheries provided recommendation(s) • Written reply to NOAA Fisheries recommendations completed. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: K. Wild and Scenic Rivers Act 13Project is not along and does not affect Wild or Scenic River (WSR) -(Review Concluded) • Project isalong oraffects WSR • Project adversely affects WSR as determined by NPS/USFS. FEMA cannot fund the action. (NPS/USFS/USFWS/BLMconsultation onfile)(ReviewConcluded) • Project does not adversely affect WSR. (NPS/USFS/USFWS/BLM consultation on file) Are project conditions required? • YES (see section V) • 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 • No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded) E3 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? • Yes (see section V) • 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 ^ 8 Step Process Complete -documentation on file Are project conditions required? ^ YES (see section V) • NO (Review Concluded) Comments: 08/09/06-The Jefferson Parish isenrolled inthe National Flood Insurance Program (NFIP) asof 10-01-71, as determined per Flood Insurance Rate Map (FIRM) panel number 2205lc0445e, dated 03-23-95. Facility islocated within an"AE"zone,areaof100-yrflooding, basefloodelevationdetermined, theprojectistherepairofbuildingandthe replacement ofequipment and components, asper 44CFR 9.11, mitigation orminimization standards must be applied. Where possible, building contents, materials, and equipment(mechanicalorelectrical) mustbeelevatedtoorabove advisory base flood elevations. Incompliance with EO 11988, an8-step process was completed and isattached. Per 44 CFR 9.12, applicant must publish a final public notice 15 days prior to the start ofconstruction activities. Final public notice is tobe forwarded to the LAGOHS/OEP and FEMA for inclusion in the permanent project files. ACramer, FPM Specialist. Correspondence/Consultation/References: B. E.0.11990-Wetlands [3 No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located in Wetland oreffects Wetland(s) Record of Environmental Consideration 5 08/22/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA /Hurricane Katrina /Public Assistance Program /EJE 0322 Grace King High School D Beneficial Effect on Wetland -(Review Concluded) • Possible adverse effect associated with constructing in ornear wetland • Review completed as part offloodplain review • 8 Step Process Complete -documentation on file Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: None Correspondence/Consultation/References: 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) ED Low income or minority population in or near project area Q No disproportionately high and adverse impact on low income or minority population-(Review Concluded) U Disproportionately high oradverse effects on low income orminority population Are project conditions required? • YES (see section V) D NO (Review Concluded) Comments: None Correspondence/Consultation/References: III. Other Environmental Issues Identify other potential environmental concerns inthe comment box not clearly falling under alaw or executive order(see environmental concerns scoping checklist for guidance). Comments: None Correspondence/Consultation/References: IV. Extraordinary Circumstances Based onthe reviewofcompliancewithotherenvironmental laws and ExecutiveOrders, and in consideration of other 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. • (i)Greaterscopeorsizethannormallyexperiencedforaparticularcategoryofaction • (ii) Actions with ahigh level ofpublic controversy • (iii) Potential for degradation, even though slight, ofalready existing poor environmental conditions; • (iv)Employmentofunproventechnologywithpotentialadverseeffectsoractionsinvolving unique or unknown environmental risks; • (v) Presence ofendangered or threatened species or their critical habitat, or archaeological, cultural, historical or other protected resources; • (vi) Presence ofhazardous or toxic substances at levels which exceed Federal, state or local regulationsor standardsrequiringactionor attention; • (vii) Actions with the potential to affect special status areas adversely or other critical resources such aswetlands, coastal zones, wildlife refuge and wilderness areas, wild and scenic rivers, soleorprincipal drinkingwateraquifers; • (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. Record of Environmental Consideration 6 08/22/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE 0322 Grace King High School • (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 Project Conditions: 1. Where possible, building contents, materials, and equipment (mechanical orelectrical) must beelevatedtoor aboveadvisorybasefloodelevations.IncompliancewithEO 11988,an8stepprocesswascompleted and isattached. Per44 CFR9.12, applicantmustpublishafinal publicnotice 15dayspriortothestartofconstructionactivities. Finalpublicnoticeistobe forwardedtothe LAGOHS/OEPand FEMA for inclusioninthe permanentprojectfiles. 2. Unusable^quipment^-debris-andjnaterial^iall-be-di^osed of ia-aa approved manner and location. Inthe event significant items (orevidence thereof) are discovered during implementationoftheprojectapplicantshall handle, manage, anddisposeofpetroleum products, hazardous materials and/or toxic waste in accordance to the requirements and to the satisfaction of the governing local, state and federal agencies. 3. Inaccordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana Parishes ofCalcasieu, 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 not leave the quarantined parishes without written authorization from the commissioner of theLouisianaDepartmentofAgriculture andForestryorhis designee(s). 4. This project potentially involves thedisposal ofMetallic Mercury Containing Electronic Devices. The applicant is responsible for ensuring that these devices are recovered, recycled, reusedorsequesteredinaccordance withthe LouisianaDepartmentof Environmental Quality (LDEQ) "Declaration of Emergency; Mercury-Containing Devices andElectronic Equipment as Universal Waste" letter dated October 3, 2005. 5. Thisprojectinvolvesthedemolitionorrenovationofa publicstructure. Regardlessofthe asbestos content, the applicant is responsible for ensuring that renovation or demolition activities are coordinatedwiththeLouisianaDepartmentofEnvironmental Quality(LDEQ) inaccordance withtheLDEQ "ThirdAmendedDeclarationofEmergencyand Administrative Order" dated June 30,2006, incorporating the provisions of EPA's National Emission StandardsforHazardous AirPollutants (NESHAP) andthe Louisiana Administrative Code (LAC) 33.111.5151 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 previously referenced administrative order. 6. This project involves the demolition or renovation of a public 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 applicableprovisionsof29 CFRparts 1910and 1926(OSHA-WorkerSafety),and40CFR 260 through 268 (EPA-Hazardous Waste). The applicant is responsible for ensuring that renovationordemolitionactivities arecoordinated withtheLouisiana Departmentof Environmental Quality for Abatement Activities and is also responsible for ensuring proper disposal in accordance with the previously referenced regulations. Record of Environmental Consideration 7 08/22/06 Reviewer Name: Catherine Jones Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/ProjectTitle: DR1603LA/Hurricane Katrina/Public Assistance Program/EJE 0322 Grace King High School 7. 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 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 orrestoration/repair ofsites damaged as aresult ofsuch operations are ineligible for federal funding. Previously -obligatedfundingTy^ubjecttode-obligatirjrrtfa deterrmnation ofirieligtbffltyisTnade. Monitoring Requirements: None Record of Environmental Consideration 8 08/22/06