Reviewer Name: Brandon M. Clark Applicant: Jefferson Parish Public School System DiMster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE0357 West Jefferson High School Record of Environmental Consideration See44 Code ofFederalRegulationPart 10. Project Name/Number: EJE0357WestJeffersonHighSchool/ PW 13723 Project Location: 2200 8th Street, Harvey, Louisiana, Jefferson Parish 70058 (N29.90382, W90.07318) Project Description: Projectactivities include removing andreplacing componentsofthe facility to restoreittopre-disastercondition, andupgradingthefacilitytocurrentcodesandstandards. Cumulativeprojectactivities include removingandreplacingtemporaryroofwithamodified bitumen roofmembrane, asphalt-felt underlayment, rigid insulation, stainless steel perimeter roofflashing and gutter,ceilingtile,carpet,vinylwall base,fluorescentlightfixtures, smokedetectors,antennapole, VCTflooring, sandblastingandcleaningconcretewallsandceilingsinthestairwell,and cleaningfloor tile. Documentation Requirements I I No Documentation Required (Review Concluded) [H (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) 1X1 (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 l~1 Statutorily excluded from NEPA review. (Review Concluded) (Zl Programmatic Categorical Exclusion -Category (Review Concluded) I I Categorical Exclusion -Category I I No Extraordinary Circumstances exist. Are project conditions required? O 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? O Yes (see section V) Q No (Review Concluded) I I Environmental Assessment CD Supplemental Environmental Assessment (Reference EA or PEA in comments) 1X1 Environmental Impact Statement Comments: 8/29/2006-This project meetsthecriteria for anAlternative Arrangement(Permanent Schools) type ofproject. Thisprojecthas conditions andrequires mitigation undertheotherEnvironmental andHistoric Preservation (EHP) Laws whicharelistedundertheNEPAlevelof environmentalreviewintheproject worksheet. Anychangestothis approved scope ofwork willrequire submissionto,andevaluationandapproval by,the state andFEMA priorto initiation ofany work,forcompliancewiththenationalenvironmentalpolicyact. Theapplicantisrequiredtoobtainandcomplywithall local, state and federal permits and requirements. Non-compliance withdierequirements noted above mayjeopardizethe receipt of federal funding. Brandon M. Clark, Environmental Specialist Record of Environmental Consideration 08/29/06 Reviewer Name: Brandon M. Clark Applicant: Jefferson Parish Public School SystemDisaster/Emergency/ProgranVProjectTitle: DR1603LA/HurricaneKatrina/PublicAssistanceProgram/EJE0357WestJeffersonHighSchool Reviewer and Approvals • Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Brandon M. Clark, Environmental Specialist Signature jS^^^sW t/Vl -CjUJtL Date 08/29/06 . FEMA Regional Environmental Officer ordelegated approving official. Name: Howard R. Bush, ELO Signature /==~^-/> ^^ . Date 08/29/06 . I-Compliance Review for Environmental Laws (other than NEPA) A. National Historic Preservation Act [3 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) • No (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. If not, explain in comments • No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file). Are project conditions required? Q Yes (see section V) • No (Review Concluded) • Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) • Resolution ofAdverse Effect completed. (MOAon file) Are project conditions required Q Yes (see section V) • No (Review Concluded) ARCHEOLOGICAL RESOURCES £3 Project affects only previously disturbed ground. (Review Concluded) d 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 ofno historic properties affected (FEMA finding/SHPO/THPO concurrence on file) Are project conditions required • Yes (see section V) • No (Review Concluded) [Zl 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? 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) Record of Environmental Consideration 2 08/29/06 Reviewer Name: Brandon M. Clark Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/ProjectTitle: DR1603LA/HurricaneKatrina/PublicAssistanceProgram/EJE0357WestJeffersonHighSchool Are project conditions required? • Yes (see section V) • No (Review Concluded) Comments: 8/29/2006 -According to the project officer, this facility was built in 1972. Brandon M. Clark, Environmental Specialist Correspondence/Consultation/References: B. Endangered Species Act MNo listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. (Review Concluded) • 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) • 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: None Correspondence/Consultation/References: C. Coastal Barrier Resources Act [El 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: None Correspondence/Consultation/References: D. Clean Water Act G3 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: Projectisnotinoradjacenttoany waterways ofthe United States. Correspondence/Consultation/References: E. Coastal Zone Management Act Lj Project is not located in acoastal zone area and does not affect acoastal zone area (Review concluded) £3 Project islocated in a coastal zone area and/or affects the coastal zone 03 State administering agency does not require consistency review. (Review Concluded). Ll State administering agency requires consistency review. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: 08/29/2006 -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 acoastal use permit or other authorization from DNR. Projects may be coordinated by contacting LA DNR at 1-800-267-4019. Brandon M. Clark, Environmental Specialist Record ofEnvironmental Consideration 3 08/29/06 Reviewer Name: Brandon M. Clark Applicant: Jefferson Parish Public School System Disagter/Emergency/PrograpVProjectTitle: DR1603LA/HurricaneKatrina/PublicAssistanceProgram/EJE03S7WestJeffersonHighSchool Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act S Project does not affect, control, or modify awaterway/body of water. (Review Concluded) • Projectaffects,controlsormodifiesawaterway/bodyofwater. • Coordination with USFWS conducted • No Recommendations offered by USFWS. (Review Concluded) • Recommendations provided by USFWS. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: Project isnot inoradjacent toany waterways ofthe United States. Correspondence/Consultation/References: G. Clean Air Act £3 Project will not result in permanent air emissions. (Review Concluded) • Project islocated in an attainment area. (Review Concluded) LJ Project is located in a non-attainment area. • Coordination required with applicable state administering agency.. Are project conditions required? • YES (see section V) Q NO (Review Concluded) Comments: Projectwillnotresult inpermanentairemissions. Correspondence/Consultation/References: H. Farmland Protection Policy Act MProject 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) Q NO (Review Concluded) Comments: None Correspondence/Consultation/References: I. Migratory Bird Treaty Act • Project not located within aflyway zone. (Review Concluded) ^ Project located within aflyway zone. S 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 on the understanding that the conditions outlined in the Louisiana Endangered Species Summary are met. CorresponderKdCowultation/References:h\to\llyM\ftcf\w^ map.ndf J. Magnuson-Stevens Fishery Conservation and Management Act [3 Project not located in or near 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) D 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) Record ofEnvironmental Consideration 4 08/29/06 Reviewer Name: Brandon M. Clark Applicant: Jefferson Parish Public School System Disaster/Emergency/Program/Project Title: DR1603LA /Hurricane Katrina /Public Assistance Program /EJE0357 West Jefferson High School C] NOAA Fisheries provided recommendation(s) LJ Written reply to NOAA Fisheries recommendations completed. Are project conditions required? • YES (see section V) D NO (Review Concluded) Comments: None Correspondence/Consultation/References: K. Wild and Scenic Rivers Act G3 Project 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/BLM consultation onfile) (Review Concluded) • 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 or Effects on Floodplains/Flood levels [>3 No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded). Are project conditions required? • Yes (see section V) E3 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: 08/23/06 -Jefferson Parish is enrolled in the National Flood Insurance Program (NFIP) as of10-01-71. Per Flood Insurance Rate Map (FIRM) Panel Number 22051C0135E dated 03-23-95, site is located within aShaded "X" Zone, areas of500-year flood; areas of 100-year flood with average depths of less than one foot or with drainage areas protected ' by levees from 100-year flood. Wind and wind driven rain caused the damage in this PW. Project is repair ofbuildings to pre-disaster condition which is not likely to affect the floodplain. A. Cramer FPM Specialist Correspondence/Consultation/References: B. E.0.11990-Wetlands E<] No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located in Wetland or effects Wetland(s) • Beneficial Effect on Wetland -(Review Concluded) • Possible adverse effect associated with constructing in or near 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 E3 No Low income or minority population in, near or affected by the project -(Review Concluded) • Low income or minority population in or near project area • No disproportionately high and adverse impact on low income or minority population-(Review Concluded) Record ofEnvironmental Consideration 5 08/29/06 Reviewer Name: Brandon M. Clark Applicant: Jefferson Parish Public School SystemDisaster/Emergency/Program/Project Title: DR1603LA / Hurricane Katrina / Public Assistance Program / EJE0357 West Jefferson High School • Disproportionately high or adverse effects on low income or minority population Are project conditions required? • YES (see section V) [~|NQ (Review Concluded) Comments: None Correspondence/Consultation/References: III. Other Environmental Issues Identifyother potentialenvironmentalconcernsinthecommentboxnotclearly falling underalawor executive order(see environmental concerns scoping checklist for guidance). Comments: None Correspondence/Consultation/References: IV. Extraordinary Circumstances Based onthe review ofcompliancewithotherenvironmental laws andExecutive Orders,andin consideration of otherenvironmental 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. Ifno, leave blank. Yes • (i)Greaterscopeorsizethannormallyexperiencedforaparticularcategoryofaction • (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 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 regulations or standards requiring action or attention; • (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 principal drinking water aquifers; • (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. LJ (x) Potential for significant cumulative impact when the proposed action iscombined with other past, present and reasonably foreseeable future actions, even though the impacts ofthe proposedactionmaynotbesignificant bythemselves. Comments: None Correspondence/Consultation/References: V. Environmental Review Project Conditions Project Conditions: 1. Unusable equipment, debris and material shall bedisposed ofinanapproved manner and location. In the event significant items (or evidence thereof) are discovered during implementation ofthe project applicant shall handle, manage, and dispose ofpetroleum products, hazardous materials and/ortoxic waste inaccordance totherequirements andtothe satisfaction ofthegoverning local, stateand federal agencies. Record of Environmental Consideration 6 08/29/06 Reviewer Name: Brandon M. Clark Applicant: Jefferson Parish Public School System Dwaster/Emergency/ProgranvProject Title: DR1603LA/HurricaneKatrina/PublicAssistanceProgram/EJE0357WestJeffersonHighSchool 2. 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 shall comply with applicable provisions'of 29 CFR 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 referencedregulations. 3. This project involves the demolition or renovation ofapublic structure. Regardless ofthe asbestos content, the applicant is responsible for ensuring that renovation ordemolition activities are coordinated with the Louisiana Department ofEnvironmental Quality (LDEQ) in accordance with the LDEQ "Sixth Amended Declaration ofemergency and administrative order" dated June 30, 2006., incorporating the provisions ofEPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code (LAC) 33.m.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. 4. Mercury containing devices -This project potentially involves the disposal ofmetallic mercurycontaining 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 ofEmergency; Mercury-Containing Devices and Electronic Equipment as Universal Waste" letter dated October 3,2005. Monitoring Requirements: None Record ofEnvironmental Consideration 7 08/29/06