Reviewer Name: Adam Borden, Env. Specialist Project Name/Env. Database #: Arabi Preschool 
FEMA-1603/1607-DR-LA PW#12876 

Parish: St. Bernard 

Record ofEnvironmental Consideration 

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


Project Name/Number: 
Arabi Preschool / PW# 12876 
FIPS#087-04449-00 


Project Location: 
100Llama Dr,Arabi, LA70032 
Latitude: 29.96484, Longitude: -89.99115 


Project Description: Heavy rains and high winds from Hurricane Katrina (DR-1603) caused significant exterior 
and interior damage to Arabi Preschool ofthe St. Bernard Parish School Board. This pw reimburses the eligible applicantfor replacement ofthe building within pre-disaster footprint. The new building will be replaced according to codes and 
standards upgrades. All work will be performed in apreviously disturbed area with no indication ofnearby waterways or 

other bodies of watex 

Documentation Requirements 

• 
(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) 

^ 
(Long version) All applicable laws and executive orders were reviewed. Additional information for compliance is 

attached tothis REC and/or included inproject files, asapplicable. 

National Environmental Policy Act (NEPA) Determination 

• 
Statutorily excluded from NEPA review. (Review Concluded) 
• 
Programmatic Categorical Exclusion -Category (Reference PCE in comments) (Review Concluded) 
• 
Categorical Exclusion -Category 
CD No Extraordinary Circumstances exist. 
Are project conditions required? • Yes (see section V) • No (Review Concluded) 
LJ Extraordinary Circumstances exist (See Section IV). 


• 
Extraordinary Circumstances mitigated. (See Section IV comments) 
Are project conditions required? • Yes (see section V) • No (Review Concluded) 
Environmental Assessment 

• Supplemental Environmental Assessment (Reference EA or PEA in comments)
^ Environmental Impact Statement 
Comments: 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 ofenvironmental 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 toobtain 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). 

Record of Environmental Consideration (Version 08/25/06) 


Reviewer Name: Adam Borden, Env. Specialist Project Name/Env. Database #: Arabi Preschool 
FEMA-1603/1607-DR-LA PW012876 


Parish: 
St. Bernard 

FEMA Environmental Reviewer: 

Name: Adam Bordeii,

rdeil, FEMA-
FEMA-FEMA-Environmental 
EnvironmentalEnvironmental Specialist
SpecialistSpecialist

,IL— /LX.^, nate g-Q&vjz,

Signature. 

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

?• 
2r.&<r

Signature /^"Z^t— /g j*-""9, Date 

I. Compliance Review for Environmental Laws (other than NEPA) 
A. National Historic Preservation Act (NHPA) 
^ Not type ofactivity with potential to affect historic properties. 
• 
Activity meets Programmatic Agreement, December 3, 2004. Appendix A: 
Are project conditions required? • Yes (see Section V) QNo 
• 
Programmatic Agreement not applicable, must conduct standard Section 106 Review. 
HISTORIC BLTLDINGS AND STRUCTURES 

UNo historic properties that are listed or45/50 years orolder 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? • Yes (see Section V) • No (Review Concluded) 
• 
Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) 
l~1 
Resolution ofAdverse Effect completed. (MOA onfile) 
Are project conditions required • Yes (see Section V) • No (Review Concluded) 

ARCHEOLOGICAL RESOURCES 

^ Project affects only previously disturbed ground. (Review Concluded) 
l~1 Project affects undisturbed ground. 
I~l Project area has no potential for presence ofarcheological resources 
O Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence or 
consultation on file). (Review Concluded) 
l~1 Project area has potential for presence ofarcheological resources 
O Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence on file) 
Are project conditions required O Yes (see Section V) • No (Review Concluded) 

• 
Determination of historic properties affected 
O NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). 
Are project conditions required QYes (see Section V) • No (Review Concluded) 
O NR eligible resources present in project area. (FEMA finding/ SHPO/THPO concurrence on 
file) 

• 
NoAdverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) 
Areproject conditions required? • Yes(seeSection V) • No(Review Concluded) 
• 
Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) 
• 
Resolution ofAdverse Effect completed. (MOA onfile) 
Are project conditions required? |_] Yes (see Section V) d No 
(Review Concluded) 

Record of Environmental Consideration (Version 08/25/06) 


Reviewer Name: Adam Borden, Env. Specialist 
Project Name/Env. Database U: Arabi Preschool 

FEMA-1603/1607-DR-LA 
PW#12876 

Parish: St. Bernard 

Comments: FEMA, inconsultation with the State Historic Preservation Officer (SHPO), has determined that none ofthe 
structures associated with the proposed demolition are listed onoreligible for the National RegisterofHistoric Places (see 
attached correspondence dated January 4,2006 ) and finds that this scope ofwork will have no effect on standing historic 
properties. Scopeofworkindicates grounddisturbingactivitiesassociatedwiththedemolitionand rebuildofthe structure 
within its pre-disaster footprint only. Upon consultation ofdata provided by SHPO, there are no known archaeological sites 
within .5 miles ofthe project area.Demolition must follow the low impact demolition stipulations &additional protocols 
which are attached. The stipulations and protocols should be explicit in the demolition contract. Failure tocomply with 
thesestipulations&additionalprotocolswilljeopardizereceiptoffederalfunding. Ifduringthecourseofwork, 
archaeological artifacts (prehistoric orhistoric) orhuman remains are discovered, the applicant shall stop work in the 
vicinityofthediscoveryandtakeallreasonablemeasurestoavoidorminimizeharmtothefinds. Theapplicantshall 
informtheirPublicAssistance(PA)contactsatFEMA,whowillinturncontactFEMAHistoric Preservationstaff.The 
applicant will not proceed with work until FEMA Historic Preservation staffhave completed consultation with the 
LouisianaStateHistoric PreservationOfficer(SHPO).Inaddition,ifunmarkedgravesarepresent,compliancewiththe 
Louisiana Unmarked Human Burial Sites Preservation Act (R.S. 8:671 etseq.) isrequired. The applicant shall notify the 
law enforcement agency ofthe jurisdiction where the remains are located within twenty-four hours ofthe discovery. The 
applicant shall also notify FEMA and the Louisiana Unmarked Burial Sites Board (call the Louisiana Division of 
Archeology at225-342-8170) within seventy-two hours ofthe discovery. Ifthis scope ofwork and/or the footprint/location 
ofthenewbuildingchanges,thisprojectwillneedtoberesubmittedforfurtherSection 106reviewpriortoground 
disturbing activities taking place outside ofthe pre-disasterfootprint ofthebuilding. 
Correspondence/Consultation/References: NHPA effect determinations made by Katherine Zeringue, Historic Preservation 
Specialist/Archaeologist 

B. Endangered Species Act 
^ No listed species and/or designated critical habitat present in areas affected directly orindirectly 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. 
• 
No effect to species or designated critical habitat (See comments forjustification) 
Are project conditions required? • Yes (see Section V) Q No (Review Concluded) 
• May affect, but not likely to adversely affect species ordesignated critical habitat (FEMA 
determination/USFWS/NMFS concurrence on file) (Review Concluded) 
Are project conditions required? • Yes (see Section V) Q No(Review Concluded) 
l~~l Likelytoadverselyaffectspeciesordesignatedcriticalhabitat 
O 
Formal consultation concluded. (Biological Assessment and Biological Opinion on file) 
Areproject conditions required? O YES (see Section V) • NO(Review Concluded) 

Comments: Projectis locatedinanurbanorpreviouslydevelopedarea. Neitherlistedspeciesnortheir habitatoccurinor 
nearthissite,thus FEMAfindstherewillbeno effecttothreatenedorendangeredspecies. 
Correspondence/Consultation/References: USFWSemergency consultation provisionsdeterminedinlettersdated 
September 15, 2005 for Katrina. 

C. Coastal Barrier Resources Act 
£3 Project isnot onor connected toCBRA Unit orOtherwise Protected Area (Review Concluded). 
• 
Project is on orconnected toCBRA Unit orOtherwise Protected Area. (FEMA determination/USFWS consultation on 
file) 
"2 Proposed action an exception under Section 3505.a.6 (Review Concluded) 
l~1 Proposed action not excepted under Section 3505.a.6. 
Are project conditions required? • YES (seeSection V) • NO(Review Concluded) 


Comments: Project is not within a CBRA zone. 
Correspondence/Consultation/References: Louisiana Coastal Barrier Resource System Maps referenced 08/25/06. 


D. Clean Water Act 
[3 Project would not affect any waters ofthe U.S. (Review Concluded) 
• 
Project would affect waters, including wetlands, ofthe U.S. 
Lj Project exempted as in kind replacement or other exemption. (Review Concluded) 
Record of Environmental Consideration (Version 08/25/06) 


Reviewer Name: Adam Borden, Env. Specialist Project Name/Env. Database #:Arabi Preschool 
FEMA-1603/1607-DR-LA PW#12876 

Parish: St. Bernard 

• 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: NojurisdictionalwatersoftheU.S., includingwetlands,occur inorneartheprojectarea. 
Correspondence/Consultation/References: USFWS National Wetlands Inventory map (http://www.fws.gov/nwi/) queried 

on 08/25/06. 

E. Coastal Zone Management Act 
• 
Project is not located in a coastal zone area and does not affect a coastal zone area (Review concluded) 
^ 
Project islocated ina coastal zone area and/or affects thecoastal zone 

[3 State administering agency does not require consistency review. (Review Concluded). 

LJ State administering agency requires consistency review. 

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

Comments: This"projectislocatedwithintheLouisianaCoastalManagementZone. LADepartmentofNaturalResources 
(DNR) has determined that receipt offederal assistance isconsistent with the Louisiana Coastal Resource Program. Projects 
withinthecoastalzonemaystillrequireacoastalusepermitorotherauthorizationfromDNR. Projectsmaybecoordinated 
by contacting LA DNR at 1-800-276-4019. 
Correspondence/Consultation/References: LDNR Louisiana Coastal Zone map 2002. 

F. Fish and Wildlife Coordination Act 
KlProjectdoes notaffect, control,ormodifyawaterway/bodyofwater. (Review Concluded) 
LJ Projectaffects controls or modifies a waterway/body of water. 
O Coordination with USFWS conducted 
J No Recommendations offered by USFWS. (Review Concluded) 
LJ" 
Recommendations provided by USFWS. 
Are project conditions required? • YES (see Section V) • NO (Review Concluded) 

Comments: Nostreams orwaterbodiesarelocated inorneartheprojectarea. 

Correspondence/Consultation/References: Louisiana Map (http://wwwlamap.doa.louisiana.gov/) queried 08/25/06. 

G. 
Clean Air Act 
J Projectwillnotresultinpermanent air emissions. (ReviewConcluded) 
^ Project islocated inan attainment area. (Review Concluded) 
LJ Project is located in a non-attainment area. 
I ICoordination required with applicable state administering agency. 
Are project conditions required? • YES (see section V) Q NO (Review Concluded) 


Comments: This project involvesthe demolitionor renovation of a publicstructure. Regardlessof the asbestoscontent, the 
applicant isresponsible forensuringthatrenovation ordemolition activities arecoordinatedwiththe Louisiana Department 
of Environmental Quality (LDEQ) in accordance with the LDEQ "Sixth Amended Declaration of Emergency and 
Administrative Order" dated March 31, 2006, and theLESHAP protocol dated March 1, 2006, incorporating the provisions 
of EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code 
(LAC)33.III.5151 andChapter27.ShouldAsbestosContainingMaterials(ACMs)bepresentattheproject site,the 
applicantisalsoresponsibleforensuringproperdisposalinaccordance withthepreviouslyreferencedadministrative 

orders. 

Correspondence/Consultation/References: EPA Region6 Non-attainmentMap. 

H. Farmland Protection Policy Act 
E<3 Project does not affect designated prime orunique farmland. (Review Concluded) 
LJ Project causes unnecessary or irreversible conversion of designated prime or unique farmland. 
I~l 
Coordination with Natural Resource Conservation Commission required. 

• 
Farmland Conversion Impact Rating, Form AD-1006, completed. 
Areprojectconditionsrequired? [J"YES(seesectionV)• NO(ReviewConcluded) 
Record of Environmental Consideration (Version 08/25/06) 


Reviewer Name: Adam Borden, Env. Specialist Project Name/Env. Database U: Arabi Preschool 
FEMA-1603/1607-DR-LA PWS12876 

Parish: St. Bernard 

Comments: The project site is in adeveloped urbanized area and Farmland Protection Policy Act (FPPA) is precluded. No 

prime or unique farmland present. 

Correspondence/Consultation/References: National Resource Conservation Service, Web Soil Survey 

(http://websoilsurvev.nrcs.usda.gov/app/ Referenced 08/25/06. 

I. Migratory Bird Treaty Act 
J Project not located within a flyway zone. (Review Concluded) 
£3 Project located within a flyway zone. 
^ Project does not have potential to take migratory birds. (Review Concluded) 
Are project conditions required? • Yes (see section V) ^ No(Review Concluded) 
LJ Projecthaspotential totakemigratory birds. 


• 
Contact made with USFWS 
Are project conditions required? • YES (see section V) • NO (Review Concluded) 
Comments: Thesiteisan existingdisturbedareawith littlevaluetomigratorybirdsandwouldnotbe includedinthe 

USFWSmigratorybird managementprogram. 

Correspondence/Consultation/References: USFWS guidance letterdatedSeptember 15,2005for Katrina 

J. Magnuson-Stevens Fishery Conservation and Management Act 
^ Projectnotlocatedinor nearEssentialFishHabitat. (Review Concluded) 
• 
Project located inor near Essential Fish Habitat. 
• 
Project does not adversely affect Essential Fish Habitat. (Review Concluded) 
Are project conditions required? • Yes (see Section V) Q No (Review Concluded) 
• 
Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) 
LJ" NOAA Fisheries provided no recommendation(s) (Review Concluded). 
Are project conditions required? • Yes (see Section V) • No (Review Concluded) 
LJ" NOAA Fisheries provided recommendation(s) 
l~~l 
Written reply to NOAA Fisheries recommendations completed. 
Are project conditions required? • YES (see Section V) • NO (Review Concluded) 

Comments: Projectisnot located inornear any surface waters withthepotential toaffect EFH species. 

Correspondence/Consultation/References: Louisiana Map(http://wwwlamap.doa.louisiana.gov/) referenced 08/25/06. 

K. Wild and Scenic Rivers Act 
KlProject isnotalonganddoesnotaffectWildorScenicRiver(WSR)-(Review Concluded) 
n Project is along oraffects WSR 

• 
Project adversely affects WSR as determined by NPS/USFS. FEMA cannot fund the action. 
(NPS/USFS/USFWS/BLMconsultationon file) (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: National Wild and Scenic Rivers http://www.nps.gov/rivers/wildriverslist.html. 

referenced 08/25/06 . 

L. 
Other Relevant Laws and Environmental Regulations 
State Hazardous Materials and Solid Waste Laws 

Comments: -In accordancewiththe FormosanTermiteInitiativeAct,(LAR.S. 3:3391.1 thru3391.13)theLouisiana 
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, 
temporaryhousingorarchitecturalcomponents(e.g. beams,doorsandotherwoodsalvaged fromastructure)maynotleave 
thequarantined parishes without written authorization from thecommissioner ofthe Louisiana Department ofAgriculture 
andforestry orhisdesignee(s). 

Record of Environmental Consideration (Version 08/25/06) 


Reviewer Name: Adam Borden, Env. Specialist 
Project Name/Env. Database #: Arabi Preschool 

FEMA-1603/1607-DR-LA 
PW#12876 

Parish: St Bernard 

-Removal and disposal ofdebris containing household hazardous waste and certain categories ofliquid 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 orregulated infectious wastes must besegregated 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 orrestoration/repair ofsites damaged as 
aresultofsuchoperationsareineligibleforfederalfunding. Previouslyobligatedfundingissubjecttode-obligationifa 
determinationof ineligibilityismade. 

-Lead-Basedpaint-thisprojectinvolvesthedemolitionofa publicstructurethatmaycontainsurfacescoated with lead-
based paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, orotherwise concentrating 
LBP shall comply with applicable provisions of29CFR parts 1910 and 1926 (OSHA -worker safety), and 40CFR 260 
through 268 (EPA -hazardous waste). The applicant isresponsible for ensuring that project activities are coordinated with 
the Louisiana Department ofEnvironmental Quality for abatement activities and isalso responsible for ensuring proper 
disposal inaccordance with thepreviously referenced regulations. 

Mercury containing devices -this project potentially involves the disposal ofmetallic mercury containing electronic 
devices. The applicant isresponsible for ensuring that these devices are recovered, recycled, reused orsequestered in 
accordance with the Louisiana Department ofEnvironmental Quality (LDEQ) "Declaration ofEmergency; Mercury-
Containing Devices and Electronic Equipment as Universal Waste" letter dated October 3, 2005. 

II. Compliance Review for Executive Orders 
A. E.0.11988 -Floodplains 
J No Effect onFloodplains/Flood levels and project outside Floodplain -(Review Concluded) 
03 Located in Floodplain orEffects on Floodplains/Flood levels 

• 
No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded). 
Areproject conditions required? • Yes (see Section V) • No (Review Concluded) 
J Beneficial Effect on Floodplain Occupancy/Values (Review Concluded). 
£3 Possible adverse effects associated with investment in floodplain, occupancy or modification offloodplain 

environment 

^ 
8Step Process Complete -documentation onfile 
Areproject conditions required? ^ YES (see Section V) • NO (ReviewConcluded) 

Comments: The site is located in Zone A3. 

http://store.msc.fema.gov/webapp/wcs/stores/servlet/FemaWelcomeView?storeId= 10001&catalog!d= 10001&langld=-1. 
TheparishofSt.Bernard enrolledintheNationalFloodInsuranceProgram(NFIP)asof 03/13/70.Buildingsarelocated 
withinan"A3"zone,areaof100-yrflooding, basefloodelevationsandflood hazardfactorsasdeterminedperFlood 
Insurance Rate Map (FIRM) panel number 2252040280 C, dated 03/04/1987. Project is replacement of buildings. 
Applicant is required to coordinate and comply with local floodplain administrator regarding floodplain permit(s) prior to 
thestartofanyactivities. Applicantisresponsibleformeetingallrequirementsofthe permit(s). Allcoordination 
pertainingtothesepermit(s), shouldbedocumentedtothe localfloodplainadministratorandcopiesprovidedtoLA 
GOHSEPandFEMAaspartofthe permanentprojectfiles. IncompliancewithE011988,acompleted8-stepprocess 
showing considered alternatives isattached. Per44CFR9.11 alternatives were reviewed. Per44CFR9.11 (d)(9), the 
replacementofbuildingcontents,materialsand equipmentshouldbe,wherepossible, wetordry-proofed, elevated,or 
relocated toor above theAdvisory BaseFlood Elevation (ABFE) perthe ABFE maps. Elevation information, signed and 
sealedbya licensedsurveyor,engineer,orarchitectmustbeobtainedandfiledforverificationof compliance. Per44CFR 
9.12,applicantmustpublishafinalpublicnotice 15dayspriortothestartofconstruction activities. Finalpublicnoticeis 
tobe forwardedtothe LAGOHSEPandFEMAforinclusioninthe permanentprojectfiles. A.C.Clark,Floodplain 

Specialist 
Correspondence/Consultation/References: FEMA Flood Insurance Rate Map, Community Panel No. # 2252040280 C, 


dated 03/04/1987 

B. E.0.11990-Wetlands 
^ No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) 
Record of Environmental Consideration (Version 08/25/06) 


Reviewer Name: Adam Borden, Env. Specialist 
Project Name/Env. Database #:Arabi Preschool 

FEMA-1603/1607-DR-LA 
PWW12876 

Parish: St. Bernard 

• 
Located in Wetland or effects Wetland(s) 
J Beneficial Effect on Wetland -(Review Concluded) 
LJ Possible adverse effectassociated with constructing inornearwetland 
J Review completed aspartof floodplain review 


• 
8 Step Process Complete -documentation on file 
Are project conditions required? • YES (see Section V) • NO (Review Concluded) 
Comments: Nowetlands were observed during sitevisit ordetermined tobe presentbycheckingtheUSFWS National 
WetlandsInventory(NWI) maps. 
Correspondence/Consultation/References: USFWS NWImapaccessed on-line 
(http://wetlandsfws.er.usgs.gov/wtlnds/launch.html) 08/24/06. 


C. E.0.12898 -Environmental Justice for Low Income and Minority Populations 
• 
No Low income or minority population in, near or affected by the project -(Review Concluded) 
^ Low income orminority population in ornear project area 
H No disproportionately high and adverse impact on low income orminority population-(Review Concluded)
O Disproportionately high oradverse effects on low income or minority population 

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

Comments Project has no Environmental Justice implications. 

Correspondence/Consultation/References: U.S. Census bureau 2000 data at http://factfinder.census.gov, referenced 

08/24/06. 

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: -Inaccordance withthe Formosan TermiteInitiative Act,(LA R.S. 3:3391.1 thru3391.13) the Louisiana 

parishesofCalcasieu,Cameron, JeffersonDavis,Orleans,Jefferson, Plaquemines, St.Bernard,St. Charles, St.Johnthe 

Baptist,St.Tammany,Tangipahoaand Washingtonareunderquarantine. The movementofwoodor cellulosematerial, 
temporaryhousingorarchitecturalcomponents(e.g. beams,doorsandotherwoodsalvagedfromastructure)maynotleave 
thequarantinedparisheswithoutwrittenauthorization fromthecommissionerofthe LouisianaDepartmentofAgriculture 
and forestry or his designee(s). 

-Removalanddisposal ofdebriscontaininghouseholdhazardous wasteandcertaincategoriesofliquidwastesmustbe 
performed inaccordance with allapplicable federal andstate laws, regulations, executive orders and guidelines. LAC title 
33partVII requiresthatspecified items,includingleadacidbatteries,usedoilfilters,usedmotoroil, scraptires,cfc's 
(refrigerants), radioactive wasteorregulated infectious wastes mustbesegregated fromandexcluded from non-hazardous 
debris collection, staging, processing and disposal sites. Failure to comply with applicable legal requirements in debris 
collection and/or disposal operations willjeopardize federal funding. Theclean-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. 

LeadBased-paint-thisproject involvesthedemolitionofa publicstructurethatmaycontainsurfacescoatedwithleadbasedpaint(
LBP). Activitiesinvolvingabrading(sanding,scraping,etc.), heating,stripping,or otherwiseconcentrating 
LBPshallcomplywithapplicableprovisionsof29 CFRparts 1910and 1926(OSHA -workersafety),and40CFR260 
through268(EPA -hazardouswaste). Theapplicantisresponsibleforensuringthatprojectactivitiesarecoordinatedwith 
the Louisiana Department of Environmental Quality for abatement activities and is also responsible for ensuring proper 
disposal in accordance with the previously referenced regulations. 
Correspondence/Consultation/Reference: 

IV. Extraordinary Circumstances 
Record of Environmental Consideration (Version 08/25/06) 

ReviewerName: AdamBorden,Env.Specialist ProjectName/Env.Database#:ArabiPreschool 
FEMA-1603/1607-DR-LA PWM2876 

Parish: 
St. Bernard 

Based on the review of compliance with other environmental laws and Executive Orders, and in 
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. If no, leave blank. 

Yes 

Q 
(i) Greater scope or size than normally experienced for aparticular category of action 

(ii)Actions withahighlevelof public 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; 

O (v) Presence ofendangered or threatened species or their critical habitat, or archaeological, 
cultural, historical or other protected resources; 
LJ (vi) PresenceofhazardousortoxicsubstancesatlevelswhichexceedFederal,stateor local 
regulations or standards requiring action or attention; 


• 
(vii) Actions with the potential to affect special status areas adversely orother critical resources 
suchas wetlands,coastalzones,wildliferefugeandwildernessareas,wildand scenicrivers, 
sole or principal drinking water aquifers; 
LJ (viii)Potentialfor adverseeffectson healthorsafety;and 
LJ (ix) Potential to violate a federal, state, local or tribal law or requirement imposed for the 
protection of the environment. 


LJ 
(x)Potentialforsignificant cumulativeimpactwhentheproposedactioniscombinedwith 
otherpast,presentandreasonably foreseeable future actions, eventhoughtheimpactsofthe 
proposed action may not be significant by themselves. 


Comments: None 

V. Environmental Review Project Conditions 
Project Conditions: 

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

• 
Thisprojectinvolvesthedemolitionorrenovationofapublicstructure.Regardlessoftheasbestoscontent,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 
EmergencyandAdministrativeOrder"datedMarch31,2006,andtheLESHAPprotocol datedMarch 1,2006, 
incorporating theprovisionsofEPA'sNationalEmissionStandardsforHazardousAirPollutants(NESHAP) and 
theLouisianaAdministrativeCode (LAC)33.111.5151 andChapter27. ShouldAsbestosContaining Materials 
(ACMs)bepresentattheprojectsite,theapplicantisalsoresponsible forensuringproperdisposalinaccordance 
with the previously referenced administrative orders. 
• 
InaccordancewiththeFormosanTermiteInitiativeAct,(LAR.S.3:3391.1thru3391.13)theLouisianaparishesof 
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). 
• 
Removalanddisposalofdebriscontaininghouseholdhazardouswasteandcertaincategoriesofliquid wastesmust 
beperformed inaccordancewithallapplicable federalandstatelaws,regulations, executiveordersandguidelines. 
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 
excludedfromnon-hazardousdebriscollection,staging,processinganddisposalsites. Failuretocomplywith 
Record of Environmental Consideration (Version 08/25/06) 


Reviewer Name: Adam Borden, Env. Specialist Project Name/Env. Database Hi Arabi Preschool 
FEMA-1603/1607-DR-LA PW#12876 

Parish: St. Bernard 

applicable legal requirements in debris collection and/or disposal operations will jeopardize federal funding. The 
clean-up or restoration/repair ofsites damaged as aresult ofsuch operations are ineligible for federal funding. 
Previouslyobligatedfunding issubjecttode-obligationifadeterminationofineligibility ismade. 

• 
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, orotherwise 
concentratingLBPshallcomplywithapplicableprovisionsof29CFRparts 1910and 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 ofEnvironmental Quality for abatement activities 
and is also responsible for ensuring proper disposal in accordance with the previously referenced regulations. 
• 
Demolition must follow the low impact demolition stipulations & additional protocols which are attached. The 
stipulations and protocols should be explicit in the demolition contract. Failure to comply with these stipulations & 
additional protocols will jeopardize receipt offederal funding. Ifduring the course ofwork, archaeological 
artifacts (prehistoric orhistoric) orhuman remains are discovered, the applicant shall stop work in the vicinity of 
the discovery and take all reasonable measures toavoid orminimize harm tothe finds. The applicant shall inform 
their Public Assistance (PA) contacts at FEMA, who will inturn contact FEMA Historic Preservationstaff.The 
applicant will not proceed with work until FEMA Historic Preservation staff have completed consultation with the 
Louisiana State Historic Preservation Officer (SHPO). In addition, ifunmarked graves are present, compliance 
with the Louisiana Unmarked Human Burial Sites Preservation Act (R.S. 8:671 etseq.) is required. The applicant 
shall notify the law enforcement agency ofthe jurisdiction where the remains are located within twenty-four hours 
ofthe discovery. The applicant shall also notify FEMA and the Louisiana Unmarked Burial Sites Board (call the 
Louisiana Division ofArcheology at225-342-8170) within seventy-two hours ofthe discovery. Ifthis scope of 
work and/or thefootprint/location ofthenewbuilding changes, thisprojectwillneedtobe resubmitted forfurther 
Section 106reviewpriortogrounddisturbingactivitiestakingplaceoutsideofthepre-disasterfootprintofthe 
building. 

• 
Mercury containing devices -this project potentially involves the disposal ofmetallic mercury containing 
electronic devices. The applicant isresponsible 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-ContainingDevicesandElectronicEquipmentasUniversal Waste"letterdatedOctober3, 
2005. 

• 
Applicant is required to coordinate and comply with local floodplain administrator regarding floodplain permit(s) 
priortothestartofanyactivities. Applicantisresponsibleformeetingallrequirementsofthepermit(s). All 
coordinationpertainingtothesepermit(s),shouldbedocumentedtothe localfloodplainadministratorandcopies 
providedtoLAGOHSEPandFEMAaspartofthepermanentprojectfiles. IncompliancewithE011988,a 
completed 8-step process showing considered alternatives is attached. Per 44 CFR 9.11 alternatives were 
reviewed. Per44 CFR9.11(d)(9),thereplacementofbuildingcontents,materialsandequipmentshouldbe,where 
possible, wet ordry-proofed, elevated, orrelocated toor above theadvisory base flood elevation (ABFE) perthe 
ABFEmaps. Elevationinformation, signedandsealedbyalicensedsurveyor,engineer,orarchitectmustbe 
obtainedandfiledforverificationofcompliance. Per44 CFR9.12,applicantmustpublishafinalpublicnotice 15 
dayspriortothestartofconstructionactivities. FinalpublicnoticeistobeforwardedtotheLA GOHSEPand 
FEMA for inclusion in the permanent project files. 
Record of Environmental Consideration (Version 08/25/06)