Reviewer Name: Letha Dawson Applicant: Recovery School District 
DisasterlEmergencylProgramlProject Title: DR I603LA I Hurricane Katrina I Public Assistance Program / EOR 3160 Abramson Senior high School 
Building A 

Record of Environmental Consideration 


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See 44 Code of Federal Regulation Part 10. 

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Project NamelNumber: Abramson Senior High School / PW 14936 

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Project Location: 5552 Read Road, New Orleans, Louisiana, Orleans Parish, 70127 (N30.02947 
W-89.97 108) 

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Project Description: Project activities include gutting, pressure washing, and disinfecting the walls, 
ceilings, interior finishes and non-masonry partitions; removing and replacing VCT, vinyl base, ceiling, 
ACT and grid, walls, drywall, hollow metal doors, door frames, wood doors, toilet and flush valves, 
lavatory and faucets, paper towel dispensers, toilet paper dispensers, mirrors, aluminum windows, 
insulated panels, aluminum frames, metal louvers, condensing units, heat pumps, air handling units, 
equipment connections and disconnects; installing ceiling, drywall, wood paneling, vision panels, and 
dead bolts; replacing service and distribution, lighting, wiring and controls, fire alarm systems, main 
panel, sensors, pull stations, intercom system, sound system, security system, clock system, and video 
distribution system; providing new hardware sets, panic hardware, door closers, trophy cases, 
emergency lighting with battery back-up, and fire strobes; prepping and painting walls, door frames, 
and gates; cleaning and polishing floor and base; and washing the vault door. Applicable codes and 
standards will apply to building repairs. 

Documentation Requirements 

o No Documentation Required (Review Concluded) 
o (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) 


[8J (Long version) All applicable laws and executive orders were reviewed. Additional information for 
compliance is attached to this REC. 

National Environmental Policy Act (NEP A) Determination 

o Statutorily excluded from NEPA review. (Review Concluded) 
[8J Programmatic Categorical Exclusion -Category (xv) <Review Concluded) 
o Categorical Exclusion -Category
o No Extraordinary Circumstances exist. 
Are project conditions required? 0 Yes (see section V) D No <Review Concluded) 
o Extraordinary Circumstances exist (See Section IV). 


o Extraordinary Circumstances mitigated. (See Section IV comments) 
Are project conditions required? 0 Yes (see section V) 0 No <Review Concluded) 


o Environmental Assessment 
o Supplemental Environmental Assessment (Reference EA or PEA in comments) 
o Environmental Impact Statement 


Record of Environmental Consideration 12/27/06 


Reviewer Nlme: Letha Dawson AppliClnt: Recovery School District 
DislsterlEmergencylProgrlmIProjed Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR 3160 Abramson Senior high School 
Building A 

Comments: Refer to Programmatic Categorical Exclusion Restoration and/or Improvement of Internal Facility Systems and 
Components dated 0912212005. See attached. 

Reviewer and Approvals 

o Project is Non-Compliant (See attached documentation justifying selection). 
FEMA Environmental Reviewer. 

Name: Letha 
Signature..........,=..;;;;;............-=.........,;__""'"""~~,&..L-"<:-___.....:.. Date _--=.1=2 ;.::2"""7 ;.::2=°=°6=---_____...:. 


FEMA Regional Environmental Officer or delegated approving official. 
Name: Howard R. Bush, ELO 


Signature ~~ . Date _~12=/2=:.;7~/2=0=06!>!..-____~ 

I. Compliance Review for Environmental Laws (other than NEPAl 

A. National Historic Preservation Act 

[gJ Not type ofactivity with potential to affect historic properties. (Review Concluded) 

D Applicable executed Programmatic Agreement (12/03/2004) Otherwise, conduct standard Section 106 review. 

D Activity meets Programmatic Allowance # __ 

Are project conditions required? D Yes (see section V) D No (Review Concluded) 

mSTORIC BUILDINGS AND STRUCTURES 

~No historic properties that are listed or 45/50 years or older in project area. (Review Concluded) 

D Building or structure listed or 45/50 years or older in project area and activity not exempt from review. 

D Determination ofNo Historic Properties Affected (FEMA fmdingiSHPOrrHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Determination ofHistoric Properties Affected (FEMA findingiSHPO/THPO 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 
il~<L.AdverseB:'fectDetermination (FEW. findinWSHPOITIIPO eonewrence on file):~~---~~~---·-· 
-~..-.-~.-.---~ Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination (FEMA findingiSHPOrrHPO 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 

~Project affects only previously disturbed ground. (Review Concluded) 

D Project affects undisturbed ground. 

D Project area has no potential for presence ofarcheological resources 

D Determination ofno historic properties affected (FEMA findingiSHPOrrHPO concurrence or 

consultation on file). (Review Concluded) 

D Project area has potential for presence of archeological resources 

D Determination ofno historic properties affected (FEMA findingiSHPOITHPO concurrence on file) 

Are project conditions required D Yes (see section V) D No (Review Concluded) 

D Determination of historic properties affected 

D NR eligible resources not present (FEMA findingiSHPO/THPO concurrence on file). 

Are project conditions required DYes (see section V) D No (Review Concluded) 


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Reviewer Name: Letha Dawson Applicant: Recovery School District 
DisasterlEmergencylProgramIProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program I EOR 3160 Abramson Senior high School 
Building A 

o NR eligible resources present in project area. (FEMA finding! SHPOITHPO concurrence on 
file) 

o No Adverse Effect Detennination. (FEMA finding! SHPOITHPO concurrence on file) 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o Adverse Effect Detennination. (FEMA finding! SHPOITHPO concurrence on file) 


o Resolution of Adverse Effect completed. (MOA on file) 
Are project conditions required? 0 Yes (see section V) 0 No 
(Review Concluded) 

Comments: According to the Project Officer, the main building was built in 1969 (portable in 1985). 
Correspondence/Consultation/References: 

B. Endangered Species Act 

181 No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. 
eview Concluded 

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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) 


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o May affect, but not likely to adversely affect species or designated critical habitat (FEMA 

detenninationlUSFWSINMFS 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) 

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Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) i 

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Comments: None 
Correspondence/Consultation/References: 

C. Coastal Barrier Resources Act 

181 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 detenninationlUSFWS 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) 


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Comments: None 
Correspondence/Consultation/References: 


D. Clean Water Act 

181 Project would not affect any waters ofthe U.S. (Review Concluded) 

o Project would affect waters, including wetlands, ofthe U.S. 

o Project exempted as in kind replacement or other exemption. (Review Concluded) 
o Project requires Section 404/40 Ilor Section 9/10 (Rivers and Harbors Act) penni!, including qualification 
under Nationwide Pennits. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


Comments: None 
Correspondence/Consultation/References: 

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) 

181 Project is located in a coastal zone area and/or affects the coastal zone 
181 State administering agency does not require consistency review. (Review Concluded). 

Record of Environmental Consideration 3 12/27/06 


Reviewer Name: Letha Dawson Applicant: Recovery School District 
DisasterlEmergencylProgramlProjed Title: DR 1603 LA I Hurricane Katrina I Public Assistance Program I EOR 3160 Abramson Senior high School 
BuiJdingA 

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 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 1-800-267-4019. 

Correspondence/Consultation/References: 

F. Fish and Wildlife Coordination Act 

181 Project does not affect, control, or modify a waterway/body of water. (Review Concluded) 

o Project affects, controls or modifies a waterway/body of water. 

o Coordination with USFWS conducted 

o No Recommendations offered by USFWS. (Review Concluded) 
o Recommendations provided by USFWS. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


Comments: None 
Correspondence/Consultation/References: 

G. Clean Air Act 

181 Project will not result in permanent air emissions. <Review Concluded)

o Project is located in an attainment area. <Review Concluded)
o Project is located in a non-attainment area. 


o Coordination required with applicable state administering agency.. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

H. Farmland Protection Policy Act 

181 Project does not affect designated prime or unique farmland. <Review Concluded)

o Project causes unnecessary or irreversible conversion of designated prime or unique farmland. 

o Coordination with Natural Resource Conservation Commission required. 

o Farmland Conversion Impact Rating, Form AD-I006, completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

I. Migratory Bird Treaty Act 

o Project not located within a flyway zone. <Review Concluded)
181 Project located within a flyway zone. 

181 Project does not have potential to take migratory birds. <Review Concluded) 
Are project conditions required? 0 Yes (see section V) 181 No (Review Concluded) 

o Project has potential to take migratory birds. 

o Contact made with USFWS 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: See letter from Don Fairley to Mr. Russ Watson with USF&WS, dated 09/1412005. 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. 


Reviewer Name: Letha Dawson Applicant: Recovery School District 
DisasterlEmergencylProgramIProject Title: DR I603LA I Hurricane Katrina I Public Assistance Program I EOR 3160 Abramson Senior high School 
Building A 

ICorrespondence/Consultation/References: http://pacificflyway.gov/DocumentslMississippi map.pdf, 

J. Magnuson-Stevens Fishery Conservation and Management Act 

181 Project not located in or near Essential Fish Habitat. (Review Concluded) 

o Project located in or near Essential Fish Habitat. 

o Project does not adversely affect Essential Fish Habitat. (Review Concluded) 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o Project adversely affects Essential Fish Habitat (FEMA detenninationlUSFWSINMFS concurrence on file) 
o NOAA Fisheries provided no recommendation(s) (Review Concluded). 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 
o NOAA Fisheries provided recommendation(s) 






o Written reply to NOAA Fisheries recommendations completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

K. Wild and Scenic Rivers Act 

181 Project is not along and does not affect Wild or Scenic River (WSR) • <Review Concluded) 

o Project is along or affects WSR 

o Project adversely affects WSR as detennined by NPSIUSFS. FEMA cannot fund the action. 
(NPSIUSFSIUSFWSIBLM consultation on file) (Review Concluded) 
o Project does not adversely affect WSR. (NPSIUSFSIUSFWSIBLM consultation on file) 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


Comments: None 
Correspondence/Consultation/References: 

L. Other Relevant Laws and Environmental Regulations 

II. Compliance Review for Executive Orders 

A. E.O. 11988 -Floodplains 

o No Effect on FloodplainslFlood levels and project outside Floodplain -(Review Concluded) 
181 Located in Floodplain or Effects on FloodplainsIFlood levels ~_~__ 


---~---.-.~-.-~.. D N<faavetseefi'ect on flOOdplam and notadverselyiffected by the floodplain.~(RevrewConcluded), 
Are project conditions required? 0 Yes (see section V) 0 No (Review Concluded) 

o Beneficial Effect on Floodplain OccupancyNalues (Review Concluded). 
181 Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain 
environment 

181 8 Step Process Complete -documentation on file 
Are project conditions required? 181 YES (see section V) 0 NO (Review Concluded) 

Comments: 12/27/2006 -The City of New Orleans/Orleans Parish is enrolled in the National Flood Insurance Program 
(NFIP) as of08/03170. Per Flood Insurance Rate Map (FIRM) panel number 2252030 115E dated 03/01184, project is 
located within an "A4" zone, area of 1OO-yr flooding, base flood elevations and flood hazard factors as detennined. Project 
is for repair of bUilding. Applicant must coordinate and comply with Local Floodplain Ordinances, and follow current 
codes and standards. Applicant is required to coordinate with the Local Floodplain Administrator regarding floodplain 
pennit(s) prior to the start ofany activities. Applicant is responsible for obtaining and retaining all pennits and certificates 
for verification. All coordination pertaining to these pennit(s), should be documented to the local floodplain administrator 
and copies provided to LA GOHSEP and FEMA as part ofthe permanent project files. In compliance with E011988, an 8step 
process, showing considered alternatives, was completed and is attached. Per 44 CFR 9.11 (D)(9), mitigation or 
minimization standards must be applied where possible. The replacement of building contents, materials and equipment 


Reviewer Name: Letha Dawson Applicant: Recovery School District 
DisasterlEmergencylProgramIProject Title: DR 1603LA f Hurricane Katrina f Public Assistance Program f EOR 3160 Abramson Senior high School 
Building A 

should be, where possible, wet or dry-proofed, elevated, or relocated to or above the Advisory Base Flood Elevation 
(ABFE) per the ABFE maps. Per 44 CFR 9.12, applicant must publish a final public notice 15 days prior to the start of 
construction activities. Final public notice is to be forwarded to the LA GOHSEP and FEMA for inclusion in the permanent 
project files. J. Schexnayder, CFM 

Correspondence/Consultation/References: 8-Step Process 

B. E.O. 11990 -Wetlands 

[gI No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) 

o Located in Wetland or effects Wetland(s) 

o 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: None 
Correspondence/Consultation/References: 

C. E.O. 12898 -Environmental Justice For Low Income and Minority Populations 

[gI No Low income or minority popUlation in, near or affected by the project -(Review Concluded) 

o Low income or minority popUlation in or near project area 

oNo disproportionately high and adverse impact on low income or minority population-(Review Concluded) 
o Disproportionately high or adverse effects on low income or minority popUlation 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 


Comment: None 
Correspondence/Consultation/References: 

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 cbecklist for guidance). 

Comments: None 
Correspondence/Consultation/References: 

--~~.~-~-...-.~--~-.--~..-.~-.~~--..---.------=-=---=---~-~~------=:-------::-:--.-----------.--.-~.-----.----.


IV. Extraordinary Circumstances 

Based on tbe review of compliance witb other environmental laws and Executive Orders, and in 
consideration of other environmental factors, review tbe 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. lfthe circumstance can be mitigated, 
please explain in comments. If no, leave blank. 

Yes 

o (i) Greater scope or size than normally experienced for a particular category of action 
o (ii) Actions with a high level of public controversy 
o (iii) Potential for degradation, even though slight, of already existing poor environmental 
conditions; 
o (iv) Employment of unproven technology with potential adverse effects or actions involving 


unique or unknown environmental risks; 
Record of Environmental Consideration 6 

12/27/06 


Reviewer Name: Letha Dawson Applicant: Recovery School District 
DisasterlEmergencylProgramlProject Title: DR1603LA I Hurricane Katrina I Public Assistance Program I EOR 3160 Abramson Senior high School 

Building A 
o (v) Presence ofendangered or threatened species or their critical habitat, or archaeological, 
cultural, historical or other protected resources; o (vi) Presence ofhazardous or toxic substances at levels which exceed Federal, state or local 
regulations or standards requiring action or attention; o (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; o (viii) Potential for adverse effects on health or safety; and o (ix) Potential to violate a federal, state, local or tribal law or requirement imposed for the 
o protection ofthe environment. 
(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 

General comments: None 

Project Conditions: 

1. Applicant must coordinate and comply with Local Floodplain Ordinances, and follow 
current codes and standards. Applicant is required to coordinate with the Local Floodplain 
Administrator regarding Floodplain Pennit(s) prior to the start ofany activities. Applicant 
is responsible for obtaining and retaining all pennits and certificates for verification. All 
coordination pertaining to these pennit(s), should be documented to the Local Floodplain 
Administrator and copies provided to LA GOHSEP and FEMA as part ofthe pennanent 
project files. 
2. Per 44 CFR 9.11 (D)(9), mitigation or minimization standards must be applied where 
possible. The replacement of building contents, materials and equipment should be, where 
possible, wet or dry-proofed, elevated, or relocated to or above the Advisory Base Flood 
Elevation (ABFE) per the ABFE maps. Per 44 CFR 9.12, applicant must publish a final 
public notice 15 days prior to the start ofconstruction activities. Final public notice is to be 
forwarded to the LA GOHSEP and FEMA for inclusion in the pennanent project files. ____ 


-~~------r Unusable eqUlpmen~(le6ris and material shallbe diSposed of inaD. apiX'oved 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/or toxic waste in accordance to the requirements and to 
the satisfaction ofthe governing local, state and federal agencies. 

4. Removal and disposal of debris 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. 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 ofsuch operations are ineligible for federal funding. Previously 
obligated funding is subject to de-obligation ifa detennination of ineligibility is made. 

Record ofEnvironmental Consideration 7 12127/06 


Reviewer Name: Letha Dawson Applic:ant: Recovery School District 
DisasterlEmergenc:ylProgramIProje<:t Title: DR1603LA I Hurricane Katrina / Publ ic Assistance Program / EOR 3160 Abramson Senior high School 
Building A 

Applicants managing debris staging, processing, burning or disposal sites (other than 

previously pennitted landfills) that have been pennitted by Louisiana Department of 

Environmental Quality must also complete an Emergency Debris Management Site 

Certification (self certification) regarding compliance with all applicable substantive laws 

and executive orders. 

5. 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 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 ofAgriculture and Forestry or his Designee(s). 
6. 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 "Seventh Amended Declaration of 
Emergency and Administrative Order" dated August 28, 2006 or latest amended 
declaration, incorporating the provisions of EPA's National Emission Standards for 
Hazardous Air Pollutants (NESHAP) and the 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. 
7. Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise 
concentrating Lead Based Paint (LBP) shall comply with applicable provisions of 29 CFR 
Parts 1910 and 1926 (OSHA -Worker Safety), and 40 CFR 260 through 268 (EPAHazardous 
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. 
8. 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 of Emergency; Mercury-Containing Devices 
and Electronic Equipment as Universal Waste" letter dated October 3, 2005. 


Monitoring Requirements: None