Rtviewtr Nalllt: Brandon M. Clark Applicant: Orleans Parish School Board DisuttrJElIltl'ltllcy/ProgramIProJtd Tidt: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 2120 Mildred C. Osborne Elementary School-Auxiliary Classroom Building Record of Environmental Consideration See 44 Code ofFederal Regulation Part 10. Project NamelNumber: EOR 2120 Mildred C. Osborne Elementary School-Auxiliary Classroom Building I PW 13324 Project Location: 6701 Curran Road, New Orleans, Louisiana, Orleans Parish 70126 (N30.03346, W -90.01605) Project Description: Project activities include removing and replacing components ofthe facility to restore it to pre-disaster condition, and upgrading the facility to current codes and standards. Cumulative project activities include removing and replacing interior light fixtures, vinyl composition tile, drywall ceiling and walls, insulation between walls, wireless network system, fire alarm systems, electrical components, bulletin boards, chalkboards, and tack boards, wood and metal doors, countertops, sinks, drinking fountains, clock systems, HV AC systems, and moisture and flood damaged school supplies and furniture, asphalt shingle roof, gutters, and downspouts. Documentation Requirements D No Documentation Required (Review Concluded) D (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) [gj (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 D Statutorily excluded from NEPA review. (Review Concluded) D Programmatic Categorical Exclusion -Category (Review Concluded) D Categorical Exclusion -Category D No Extraordinary Circumstances exist. Are project conditions required? D Yes (see section V) D No (Review Concluded) D Extraordinary Circumstances exist (See Section IV). D Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? D Yes (see section V) D No (Review Concluded) D Environmental Assessment D Supplemental Environmental Assessment (Reference EA or PEA in comments) [gj Environmental Impact Statement Comments: 8/3112006 -This project meets the criteria for an Alternative Arrangement (Permanent Schools) type ofproject. 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 this approved scope of work 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. Brandon M. Clark, Environmental Specialist Reviewer Name: Brandon M. Clark Applicant: Orleans Parish School Board DlwterlEmergeneylProgramIProjeet Title: DRI603LA I Hwricane Katrina I Public Assistance Program I EOR 2120 Mildred C. Osborne Elementary School-Auxiliary Classroom Building Reviewer and Approvals o Project is Non-Compliant (See attached documentation justifying selection). FEMA Environmental Reviewer. Name: Brandon M. Clark, Environmental Specialist Signature 131"\~ VV\ CJl..eJ.c . Date _08/31/06_---= L FEMA Regional Environmental Officer or delegated approving official. Name: Howard R. Bush, ELO Signature ~~ . Date __08/31/06_----" I. Compliance Review for Environmental Laws (other than NEPAl A. National Historic Preservation Act 181 Not type ofactivity with potential to affect historic properties. (Review Concluded) D Applicable executed Programmatic Agreement Otherwise, conduct standard Section 106 review. D Activity meets Programmatic Allowance # _____--=.---____ Are project conditions required? D Yes (see section V) D No (Review Concluded) HISTORIC BUILDINGS AND STRUCTURES 181 No historic properties that are listed or 45150 years or older in project area. (Review Concluded) D Building or structure listed or 45150 years or older in project area and activity not exempt from review. D Determination ofNo Historic Properties Affected (FEMA fmdinglSHPOffHPO concurrence on file) Are project conditions required? D Yes (see section V) D No (Review Concluded) D Determination of Historic Properties Affected (FEMA findinglSHPOffHPO concurrence on file) D Property a National Historic Landmark and National Park Service was provided early notification during the consultation process. Ifnot, explain in comments D No Adverse Effect Determination (FEMA fmdinglSHPOffHPO concurrence on file). Are project conditions required? D Yes (see section V) D No (Review Concluded) D Adverse Effect Determination (FEMA fmdinglSHPO/THPO concurrence on file) D Resolution of Adverse Effect completed. (MOA on file) Are project conditions required D Yes (see section V) D No (Review Concluded) ARCHEOLOGICAL RESOURCES 181 Project affects only previously disturbed ground. (Review Concluded) D Project affects undisturbed ground. D Project area has no potential for presence of archeological resources D Determination of no historic properties affected (FEMA findinglSHPOffHPO concurrence or consultation on file). (Review Concluded) D Project area has potential for presence ofarcheological resources D Determination of no historic properties affected (FEMA findinglSHPO/THPO concurrence on file) Are project conditions required D Yes (see section V) D No Comments: 08/08/06-The City ofNew Orleans/ Orleans Parish is enrolled in the National Flood Insurance Program (NFIP) as of08-03-70. As per Flood Insurance Rate Map (FIRM) panel number 2252030 115E dated 03-01-84. Project is located within a V 16 zone, area of IOO-yr coastal flooding with velocity (wave action), base flood elevations and flood hazard factors determined. The project is the repair ofbuilding and the replacement ofequipment and components. As per 44 CFR 9.11, mitigation or minimization standards must be applied. Where possible, building contents, materials, and equipment (mechanical or electrical) must be elevated to or above advisory base flood elevations. In compliance with EO 11988, an 8step process was completed and is attached. Per 44 CFR 9.12, applicant must publish a fmal public notice 15 days prior to the start ofconstruction activities. Final public notice is to be forwarded to the LA GOHS/OEP and FEMA for inclusion in the permanent project files. A. Cramer FPM Specialist. Correspondence/Consultation/References: B. E.O. 11990 -Wetlands 181 No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) D Located in Wetland or effects Wetland(s) D Beneficial Effect on Wetland - o Disproportionately high or adverse effects on low income or minority population Are project conditions required? D YES (see section V) D NO (Review Concluded) Comments: None Co"espondence/Consu/tationiReferences: 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 Co"espondence/ConsultationiReferences: 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" 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. lfno, leave blank. Yes D (i) Greater scope or size than normally experienced for a particular category of action D (ii) Actions with a high level of public controversy D (iii) Potential for degradation, even though slight, ofalready existing poor environmental conditions; D (iv) Employment of unproven technology with potential adverse effects or actions involving unique or unknown environmental risks; D (v) Presence of endangered or threatened species or their critical habitat, or archaeological, CUltural, historical or other protected resources; D (vi) Presence of hazardous or toxic substances at levels which exceed Federal, state or local regulations or standards requiring action or attention; D (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; D (viii) Potential for adverse effects on health or safety; and D (ix) Potential to violate a federal, state, local or tribal law or requirement imposed for the protection ofthe environment. D (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 ro osed action ma not be si 'ficant b themselves. Comments: None Correspondence/ConsultationiReferences: V. Environmental Review Project Conditions Project Conditions: 1. As per 44 CFR 9.11, mitigation or minimization standards must be applied. Where possible, building contents, materials, and equipment (mechanical or electrical) must be elevated to or above advisory base flood elevations. In compJiance with EO 11988, an 8-step process was completed and is attached. Per 44 CFR 9.12, applicant must publish a final public notice 15 days Record of Environmental Consideration 6 08/31106 R.eviewer Name: Brandon M. Clark Applicant: Orleans Parish School Board DisuterlEmergencylProgram/Projeet Title: DRI603LA I Hurricane Katrina I Public Assistance Program I EOR 2120 Mildred C. Osborne Elementary School-Auxiliary Classroom Building prior to the start ofconstruction activities. Final public notice is to be forwarded to the LA GOHS/OEP and FEMA for inclusion in the pennanent project files. 2. 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 project applicant shall handle, manage, and dispose of petroleum products, hazardous materials and/or toxic waste in accordance to the requirements and to the satisfaction ofthe governing local, state and federal agencies. 3. Removal and disposal ofdebris containing household hazardous waste and certain categories of liquid wastes must be perfonned 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. 4. In accordance with the Fonnosan Tennite 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 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). 5. This project involves the demolition or renovation ofa 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 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 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. 6. This project involves the demolition or renovation ofa public structure. 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 ofemergency and administrative order" dated June 30, 2006., incorporating the provisions of EPA'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 previously referenced administrative order. 7. Mercury containing devices -This project potentially involves the disposal of metallic 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 ofEmergency; Mercury-Containing Devices and Electronic Equipment as Universal Waste" letter dated October 3, 2005. Monitoring Requirements: None Record ofEnvironmental Consideration 7 08/31106