Reviewer Name: Adam Borden. Env. Specialist Project NamelEnv. Database No: Valena Jones Elementary School. Main Building 
FEMA-160J/1607-DR-LA PWIIlJS80 
Parish: Orlelns 

Record of Environmental Consideration 


REVISED FOR FEMA ENVIRONMENTAL -LOUISIANA -2006 
See 44 Code of Federal Regulation Part 10 

Project NamelNumber: Valena Jones Elementary School, Main Building 1PW# 13580 
FIPS#033-UA9M2-00 
Project Location: 1901 N. Galvez Street, New Orleans LA 70119 
Latitude: 29.97847, Longitude: -90.06341 
Proiect Description: Heavy rains and high winds from Hurricane Katrina (DR-1603) caused significant exterior 

and interior damage to Valena Jones Elementary School, Main Building of the Recovery School District. This pw 
reimburses the eligible applicant for replacement of interior components, lighting, windowlframes, wallboard, doors, ceiling 
tiles, flooring, mechanical/electrical systems, insulation, and countertops/cabinetry. The new building material will be 
replaced according to codes and standards upgrades. All work will be performed in a previously disturbed area with no 
indication ofnearby waterways or other bodies ofwater. 

Documentation Reguirements 

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) 

IZI (Long version) All applicable laws and executive orders were reviewed. Additional information for compliance is 
attached to this REC andlor included in project files, as applicable. 

National Environmental Policy Act (NEP A) Determination 

D Statutorily excluded from NEPA review. (Review Concluded) 
D Programmatic Categorical Exclusion -Category (Reference PCE in comments) (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) 
IZI Environmental Impact Statement 

Comments: This project meets the criteria for an Alternative Arrangement (permanent Schools) type of project. 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. 

Reviewer and Approvals 

D Project is Non-Compliant (See attached documentation justifying selection). 

FEMA Environmental Reviewer: 
Name: Adam Borden, FEMA-Environmental Specialist 
Record of Environmental Consideration (Version 08/29/06) 



Reviewer Name: Adam Borden, Env. Specialist Project NamtlEnv. Database No: Valena JODes Elementary School, Main Building 
FEMAOI603/16070 DROLA PWNl3580


LL 

Parish: Orleans 

Signature __~L--__--'--=""'--',""",-,C:::OO::==-__ Date g-d4' < 0jJ

lL

FEMA Regional Environmental Officer or Delegated Approving Official: 
Name: Howard R. Bush, Environmental Liason Officer 

Signature ~r;??-----/....,...---Date __~_;)_f._._0_''_---'


I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act (NHPA) 
D Not type ofactivity with potential to affect historic properties. 

[8] Activity meets Programmatic Agreement, December 3, 2004. Appendix A: Section ILA-I ,II.A-2,U.A-4,II.B-1 ,ILCI 
,ILC-2,II.D-I,II.D-6,II.E-I, and II.F-I 

Are project conditions required? [8] Yes (see Section V) D No 
D Programmatic Agreement not applicable, must conduct standard Section 106 Review. 

mSTORIC BUILDINGS AND STRUCTURES 

[8] 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. 

o Determination ofNo Historic Properties Affected (FEMA findingiSHPOffHPO concurrence on file) 

Are project conditions required? 0 Yes (see Section V) 0 No <Review Concluded) 
D Determination of Historic Properties Affected (FEMA findingiSHPOffHPO concurrence on file)

o Property a National Historic Landmark and National Park Service was provided early notification 
during the consultation process. Ifnot, explain in comments 
o No Adverse Effect Determination (FEMA fmdingiSHPOffHPO concurrence on file). 
Are project conditions required? D Yes (see Section V) 0 No <Review Concluded)
o Adverse Effect Determination (FEMA findingiSHPOffHPO 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 

[8] Project affects only previously disturbed ground. <Review Concluded) 
D Project affects undisturbed ground.

o Project area has no potential for presence ofarcheological resources 
o Determination of no historic properties affected (FEMA findingiSHPOffHPO concurrence or 
consultation on file). (Review Concluded) 


o Project area has potential for presence of archeological resources 


D Determination of no historic properties affected (FEMA fmdingiSHPOffHPO concurrence on file) 
Are project conditions required 0 Yes (see Section V) D No (Review Concluded) 

o Determination of historic properties affected 

D NR eligible resources not present (FEMA fmdingiSHPOrrHPO concurrence on file). 
Are project conditions required DYes (see Section V) 0 No <Review Concluded)

o NR eligible resources present in project area. (FEMA fmdingl SHPOffHPO concurrence on 
file) 
D No Adverse Effect Determination. (FEMA findingl SHPOffHPO concurrence on file) 

Are project conditions required? D Yes (see Section V) 0 No <Review Concluded) 
D Adverse Effect Determination. (FEMA findingl SHPOffHPO concurrence on file)

o Resolution ofAdverse Effect completed. (MOA on file) 
Are project conditions required? 0 Yes (see Section V) D No 
(Review Concluded) 

Record ofEnvironmental Consideration (Version 08/29/06) 


Reviewer Name: Adam Borden, Env. Specialist Project NamflEnv. Database No: Valena Jones Elementary &:hool, Main Building 
FEMA·I60JII607·DR·LA PWI#I3580 
Parish: Orleans 

Comments: FEMA'S Programmatic Agreement (PA), dated December 3, 2004, provides for expedited project review under 
Section 106 of the National Historic Preservation Act (NHPA). The scope of work as submitted in this pw has been 
reviewed and meets the criteria outlined in appendix A, programmatic allowances, Section Il.A·l ,1I.A-2,I1.A-4,Il.B-1 ,1l.C


J,II.C-2,1l.O-J,1I.D.fi,II.E-1, and I1.F-lofthe document. In accordance with the PA, FEMA is not required to determine the 
national register eligibility of properties or to submit projects to the 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 to match existing materials and form. Any change to the approved scope ofwork will require 
resubmission for re-evaluation under Section 106 and consultation with the SHPO. Non-compliance may jeopardize the 
receipt of federal funding. This concludes the Section 106 review for this project. 
Correspondence/ConsultatlonlReferences: NHPA determinations made by E.S.Thibodeaux, HP Specialist 

B. Endangered Species Act 
IZI 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. 

o No effect to species or designated critical habitat. (See comments for justification) 
Are project conditions required? 0 Yes (see Section V) 0 No <Review Concluded)
o May affect, but not likely to adversely affect species or designated critical habitat (FEMA 


determinationlUSFWSINMFS concurrence on file) <Review Concluded) 
Are project conditions required? 0 Yes (see Section V) 0 No <Review Concluded)


o Likely to adversely affect species or designated critical habitat 

o Formal consultation concluded. (Biological Assessment and Biological Opinion on file) 
Are project conditions required? 0 YES (see Section V) 0 NO <Review Concluded) 

Comments: Project is located in an urban or previously developed area. Neither listed species nor their habitat occur in or 
near this site, thus FEMA finds there will be no effect to threatened or endangered species. 
Correspondence/Consultation/References: USFWS emergency consultation provisions determined in letters dated 
September 15,2005 for Katrina. 

C. Coastal Barrier Resources Act 
IZI Project is not on or connected to CBRA Unit or Otherwise Protected Area <Review Concluded). 


o Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determinationlUSFWS consultation on 
file) 

o Proposed action an exception under Section 3505.a.6 {Review Concluded) 
o Proposed action not excepted under Section 3505.a.6. 
Are project conditions required? 0 YES (see Section V) 0 NO {Review Concluded) 


Comments: Project is not within a CBRA zone. 
Correspondence/ConsultationIRqerences: Louisiana Coastal Barrier Resource System Maps referenced 08129/06. 


D. Clean Water Act 
IZI Project would not affect any waters of the U.S. (Review Concluded) 


o Project would affect waters, including wetlands, of the U.S. 

o Project exempted as in kind replacement or other exemption. {Review Concluded)
o Project requires Section 404/40 Ilor Section 9110 (Rivers and Harbors Act) permit, including qualification 
under Nationwide Permits. 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 


Comments: No jurisdictional waters ofthe U.S., including wetlands, occur in or near the project area. 
Correspondence/Consultation/References: USFWS National Wetlands Inventory map (http://www.fws.gov/nwil) queried 
on 08129/06. 

E. Coastal Zone Management Act 

o Project is not located in a coastal zone area and does not affect a coastal zone area (Review concluded) 
IZI Project is located in a coastal zone area and/or affects the coastal zone 

IZI State administering agency does not require consistency review. {Review Concluded). 
Record of Environmental Consideration (Version 08/29/06) 


Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Valena Jones Elementary School, Main Building 
FEMA-I603/1607-DR-LA PWII13580 
Parish: Orleans 

o State administering agency requires consistency review. 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 


Comments: This project is located within the Louisiana Coastal Management Zone. LA Department ofNatural Resources 
(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 1-800-276-4019. 
CorrespondenceiConsultationIRe/erences: LDNR Louisiana Coastal Zone map 2002. 

F. Fish and Wildlife Coordination Act 
[8J Project does not affect, control, or modify a waterwaylbody of water. (Review Concluded) 


o Project affects controls or modifies a waterwaylbody ofwater. 

o Coordination with USFWS conducted 

o No Recommendations offered by USFWS. (Review Concluded) 
o Recommendations provided by USFWS. 
Are project conditions required? D YES (see Section V) D NO (Review Concluded) 


Comments: No streams or water bodies are located in or near the project area. 
CorrespondenceiConsultationIRe/erences: Louisiana Map (http://wwwlamap.doa.louisiana.govD queried 08129/06. 

G. Clean Air Act 

o Project will not result in permanent air emissions. (Review Concluded) 
[8J Project is located in an attainment area. <Review Concluded)
D Project is located in a non-attainment area. 

D Coordination required with applicable state administering agency. 
Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: This project involves the demolition or renovation ofa 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 "Sixth Amended Declaration of Emergency and 
Administrative Order" dated March 31, 2006, and the LESHAP protocol dated March 1, 2006, incorporating the provisions 
ofEPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code 
(LAC) 33.m.SlSI 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 
orders. 
CorrespondenceiConsultationIRe/erences: EPA Region 6 Non-attainment Map. 

H. Farmland Protection Policy Act 
[8J Project does not affect designated prime or unique farmland. (Review Concluded) 
D Project causes unnecessary or irreversible conversion of designated prime or unique farmland. 


o Coordination with Natural Resource Conservation Commission required.

D Farmland Conversion Impact Rating, Form AD-I 006, completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: The project site is in a developed urbanized area and Farmland Protection Policy Act (FPPA) is precluded. No 
prime or unique farmland present. 
CorrespondenceiConsultationIRe/erences: National Resource Conservation Service, Web Soil Survey 

I(htto:llwebsoilsurvev.nrcs.usda.!!:ov/aool )referenced 08/29/06. 

I. Migratory Bird Treaty Act 
D Project not located within a flyway zone. (Review Concluded) 
(8j Project located within a flyway zone. 


(8j Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? 0 Yes (see section V) (8j No (Review Concluded) 
D Project has potential to take migratory birds. 
Record of Environmental Consideration (Version 08/29/06) 


Reviewer Name: Adam Borden, Eav. Specialist Project NamelEav. Database No: Valena Joaes Elementary School, Main Bulldillg 
FEMA-t603IUi07-DR-LA PWllt3580 


Parish: Orleans 

D Contact made with USFWS 

Are project conditions required? D YES (see section V) D NO (Review Concluded) 

Comments: The site is an existing disturbed area with little value to migratory birds and would not be included in the 
USFWS migratory bird management program. 
Correspondence!ConsultlltioniRe/erences: USFWS guidance letter dated September 15,2005 for Katrina 

J. Magnuson-Stevens Fishery Conservation and Management Act 

[8J Project not located in or near Essential Fish Habitat. (Review Concluded) 
D Project located in or near Essential Fish Habitat. 
D Project does not adversely affect Essential Fish Habitat. (Review Concluded) 
Are project conditions required? D Yes (see Section V) D No (Review Concluded) 
D Project adversely affects Essential Fish Habitat (FEMA determinationlUSFWSINMFS concurrence on file)
DNOAA Fisheries provided no recommendation(s) (Review Concluded). 
Are project conditions required? D Yes (see Section V) D No (Review Concluded) 
D NOAA Fisheries provided recommendation(s) 
D Written reply to NOAA Fisheries recommendations completed. 
Are project conditions required? D YES (see Section V) D NO (Review Concluded) 

Comments: Project is not located in or near any surface waters with the potential to affect EFH species. 
Correspondence/ConsultlltioniRe/erences: Louisiana Map (http://wwwlamap.doa.louisiana.govD referenced 08/29/06. 

K. Wild and Scenic Rivers Act 

t8l Project is not along and does not affect Wild or Scenic River (WSR) -(Review Concluded) 
D Project is along or affects WSR 

o Project adversely affects WSR as determined by NPSIUSFS. FEMA cannot fund the action. 
(NPSIUSFSIUSFWSIBLM consultation on file) <Review Concluded)

D Project does not adversely affect WSR. (NPSIUSFSlUSFWSIBLM consultation on file) 
Are project conditions required? D YES (see Section V) D NO (Review Concluded) 

Comments: None 
Correspondence/ConsultlltioniRe/erences: National Wild and Scenic Rivers htl;p://www.nps.gov/riverslwildriverslist.html. 
referenced 08129/06 . 


L. Other Relevant Laws and Environmental Re ulations 


State Hazardous Materials and Solid Waste Laws 
Comments: -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 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 of Agriculture 
and forestry or his designee(s). 

-Removal and disposal ofdebris 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, efc'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 ofsites damaged as 
a result of such operations are ineligible for federal funding. Previously obligated funding is subject to de-obligation ifa 
determination of ineligibility is made. 

-Lead-Based paint -this project involves the demolition of a public structure that may contain surfaces coated with leadbased 
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 

Record ofEnvironmental Consideration (Version 08/29/06) 


disposal in accordance with the previously referenced regulations. 

Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Valena Jones Elementary School, Main Building 
FEMA-160311607-DR-LA PWIl13580 
Parish: Orleans 
through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that project activities are coordinated with 
the Louisiana Department of Environmental Quality for abatement activities and is also responsible for ensuring proper 



-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; MercuryContainin 
Devices and Electronic ui ment as Universal Waste" letter dated October 3, 2005. 

II. Compliance Review for Executive Orders 
A. E.O. 11988 -Floodplains 


oNo Effect on FloodplainslFlood levels and project outside Floodplain -(Review Concluded) 
[8j Located in Floodplain or Effects on FloodplainslFlood levels 

oNo adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 

Are project conditions required? 0 Yes (see Section V) 0 No (Review Concluded) 
D Beneficial Effect on Floodplain OccupancyN alues (Review Concluded). 
[8j Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain 

environment 
[8j 8 Step Process Complete -documentation on file 
Are project conditions required? [8j YES (see Section V) 0 NO (Review Concluded) 

Comments: The site is located in Zone A3. 

http://store.msc.fema.gov/webawlwcs/stores/servletlFemaWelcomeView?storeld= 1 000 I &catalogId= I 000 1&langId=-1, 
The city ofNew Orleans 1Orleans Parish enrolled in the National Flood Insurance Program (NFIP) as of08/03/1970. 
Facility is located within an "A3" zone, area of I OO-yr flooding, base flood elevations and flood hazard factors as 
determined per Flood Insurance Rate Map (FIRM) panel number 2252030095 E, dated 03/0111984. Project is repair of 
building and replacement ofequipment and components. In compliance with EO 11988, an 8-step process was completed 
and is attached. As per 44 CFR 9.11, mitgation or minimization standards must be applied. Where possible, building 
contents, materials, components and equipment (mechanical or electrical) must be elevated to or above advisory base flood 
elevations. Per 44 CFR 9.12, a final public notice is to be published IS days prior to the start of any construction activities. 
Documentation ofcompleted public notice is to be forwarded to FEMA and LA GOHSEP for inclusion in the permanent 
project files. A. C. Clark, Floodplain Specialist 
Correspondence/Consultation/References: FEMA Flood Insurance Rate Map, Community Panel No. # 2252030095 E, 
dated 03/0Ill984 

B. E.O.11990 -Wetlands 
[8j No Effects on Wetiand(s) and project located outside Wetland(s) -(Review Concluded) 
D Located in Wetland or effects Wetiand(s) 


D Beneficial Effect on Wetland -(Review Concluded) 

o Possible adverse effect associated with constructing in or near wetland 

o Review completed as part of floodplain review 
o 8 Step Process Complete -documentation on file 
Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) 


Comments: No wetlands were observed during site visit or determined to be present by checking the USFWS National 
Wetlands Inventory (NWI) maps. 
Correspondence/ConsultationIReferences: USFWS NWI map accessed on-line 
(http://wetlandsfws.er.usgs.gov/wtlndsllaunch.html) 08129/06. 


c. E.O.12898 -Environmental Justice for Low Income and Minority Populations 

oNo Low income or minority population in, near or affected by the project -(Review Concluded) 
[8j Low income or minority population in or near project area 
[8j No disproportionately high and adverse impact on low income or minority population-(Review Concluded) 


oDisproportionately high or adverse effects on low income or minority population 
Record of Environmental Consideration (Version 08/29/06) 



Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Valena Jones Elementary School, Main Building 
FEMA-1603/1607-DR-LA PW#13580 
Parish: Orleans 

Are project conditions required? D YES (see Section V) D NO (Review Concluded) 

Comments The percent populations of70119 are: 72.1% Black, 23.3% White, and 5.6% Hispanic. The median household 
income in 1999 was $ 21,297 and 29.2% offamilies are below poverty level. 
Correspondence/Consultation/References: U.S. Census bureau 2000 data at http://factfinder.census.gov, referenced 
08/21106. 


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). 

State Hazardous Materials and Solid Waste Laws 
Comments: -In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana 
parishes of CaIcasieu, 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 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 of Agriculture 
and forestry or his designee(s). 

-Removal and disposal ofdebris 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. 

-Lead Based-paint -this project involves the demolition ofa public structure that may contain surfaces coated with leadbased 
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 CFR260 
through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that project 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. 

-Mercury containing devices -this project potentially involves the disposal ofmetalIic 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; MercuryContaining 
Devices and Electronic Equipment as Universal Waste" letter dated October 3, 2005. 

Correspondence/Consultation/Reference: 

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. Ifno, 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 ofpublic controversy 


Record ofEnvironmental Consideration (Version 08/29/06) 


Reviewer Name: Adam Borden. Env. Spedalist Project NamelEnv. Database No: Valena Jones Elementary School. Main Building 
FEMA-1603/1607-DR-LA PWIIJ3580 
Parish: Orleans 

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 ofendangered 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 of the environment. 

o (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 
proposed action may not be significant by themselves. 

IComments: None 

v. Environmental Review Project Conditions 


Project Conditions: 

The following conditions apply as a condition of FEMA funding reimbursement: 

• This project involves the demolition or renovation ofa public structure. Regardless of the asbestos content, the 
applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana 
Department ofEnvironmental Quality (LDEQ) in accordance with the LDEQ "Fifth Amended Declaration of 
Emergency and Administrative Order" dated March 31, 2006, and the LESHAP protocol dated March 1, 2006, 
incorporating the provisions ofEPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and 
the Louisiana Administrative Code (LAC) 33.m.515t 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 orders. 
• In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 339l.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 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 of Agriculture and forestry or his designee(s). 
• Removal and disposal ofdebris 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, efc'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 ofsites damaged as a result ofsuch operations are ineligible for federal funding. 
Previously obligated funding is subject to de-obligation if a determination of ineligibility is made. 
• Lead-based paint -this project involves the demolition 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 
project 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. 
• 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 ofEnvironmental Quality (LDEQ) "Declaration of 


Record of Environmental Consideration (Version 08/29/06) 


Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Valena Jones Elementary School, Main Building 
FEMA-I603/1607-DR-LA PW#13580 
Parish: Orleans 

Emergency; Mercury·Containing Devices and Electronic Equipment as Universal Waste" letter dated October 3, 

2005. 

• In accordance with the PA, FEMA is not required to determine the National Register eligibility ofproperties or to 
submit projects to the 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 
to match existing materials and form. Any change to the approved scope of work will require resubmission for reo 
evaluation under Section 106 and consultation with the SHPO. Non-compliance may jeopardize the receipt of 
federal funding. This concludes the Section 106 review for this project. 
• As per 44 CFR 9.11, mitgation or minimization standards must be applied. Where possible, building contents, 
materials, components and equipment (mechanical or electrical) must be elevated to or above advisory base flood 
elevations. Per 44 CFR 9.12, a final public notice is to be published IS days prior to the start of any construction 
activities. Documentation ofcompleted public notice is to be forwarded to FEMA and LA GOHSEP for inclusion 
in the permanent project files. 


Record ofEnvironmental Consideration (Version 08/29/06)