U.S. Department of Homeland Security Federal Emergency Management Agency FEMA-1603/1607-DR-LA 415 N 15111 Street Baton Rouge, LA 70802 FEMA August 28, 2006 Johnny Gonzales GOHSEPPAO FEMA-1603 -DR-LA 415 N. 15th Street Baton Rouge, Louisiana 70802 RE: Alternative Arrangements, Reconstruction of Critical Infrastructure in the New Orleans Metropolitan Area, Ochsner Clinic Foundation, HR-Whitney Building, PW#: 12193, DR-1603-LA, PA 10: 000-U050N-00. Dear Mr. Gonzales: The purpose of this letter is to notifY you that the Public Assistance project for HR-Whitney Building, 400 Labarre Road, Jefferson, Jefferson Parish, Louisiana 70121, (29.5743N, 90.0909W) qualifies for the National Environmental Policy Act (NEPA) Alternative Arrangements for the Reconstruction ofCritical Infrastructure in the New Orleans Metropolitan Area. Under the regular Federal Emergency Management Agency (FEMA) NEPA review this project would have qualified for a Categorical Exclusion Level II documentation. However, due to the unprecedented number of grants requested that need to be processed in a short time, the potential cumulative effects, and potential environmentally-related socio-economic effects ofFEMA's funding in the New Orleans Metropolitan Area, FEMA has determined that this type ofaction may have significant impacts that cannot be reviewed under the normal EIS process. FEMA, the Department of Homeland Security (DHS), and the Council on Environmental Quality (CEQ) have adopted the Alternative Arrangements to address the basic elements ofNEPA under these circumstances. For more information visit www.fema.gov/plan/ehp/nomaJindex.shtm. While the use ofAlternative Arrangements meets NEPA compliance requirements, there are requirements of other Environmental and Historic Preservation (EHP) laws and executive orders that must be individually complied with. For the work described in this PW the following conditions relating to those requirements apply: • Applicant should handle, manage, and dispose of potentially hazardous waste, biomedical waste, radioactive waste, universal waste, and hazardous materials in accordance with the requirements of local, state, and federal regulations. These materials may include but are not limited to asbestos, leadbased paint, laboratory reagents, propane cylinders, paints and solvents, coolants containing chlorofluorocarbons (CFCs), used oil, polychlorinated biphenyls (PCBs), other petroleum products, used oil filters, fuel filters, cleaning chemicals, pesticides, batteries, and unlabeled tanks and containers. Equipment that may include these materials are ice machines, refrigerators, generators, computers, televisions, mercury switches, fluorescent lights, fluorescent light ballasts, sandblast units, paint sprayers, etc. • This project is located within the Louisiana Coastal Management Zone. Louisiana Department of Natural Resources (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 or other authorization from DNR. Projects may be coordinated by contacting LA DNR at 1-800267- 4019. • Unusable equipment, debris, and material shall be disposed of in an approved manner and location. In the event significant items (or evidence thereof) are discovered during implementation ofthe projects applicant shall handle manage and dispose of petroleum products, hazardous materials and/or toxic Johnny Gonzales August 28, 2006 Page 2 waste in accordance to the requirements and to the satisfaction ofthe governing local, state and federal agencies. • This project involves the demolition or renovation of a public structure. Regardless of the 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 "Fifth amended Declaration of Emergency and Administrative Order" dated March 31 2005., incorporating the provisions of EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code (LAC) 33.IIl,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. • 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, S1. Tammany, Tangipahoa and Washington are under quarantine. The movement of wood or cellulose 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 ofthe Louisiana Department ofAgriculture and Forestry or his designee( s). • The applicant shall ensure that Best Management Practices are implemented to prevent erosion and sedimentation to surrounding, nearby or adjacent wetlands. This includes equipment storage and staging of construction to prevent erosion and sedimentation to ensure that wetlands are not adversely affected per the Clean Water Act and Executive Order 11990. Please note that this transmittal is a notification that this project has been cleared under NEPA only. This is not a notice of tinal approval or eligibility. Any change beyond the approved scope of work for this project will require additional environmental review by FEMA. ~' 7~M.MC4/'"*/2 : Donald R. Fairley, REM Environmental Liaison Officer FEMA-160311607-DR-LA Enclosures: P.W. 12193 Cc: Oliver Mack, FEMA DPAO for Grants