Reviewer Name: Adam Borden Project Name/Env Database No: Mandeville Elementary School/PW9168 FEMA-1603/1607-DR-LA Parish: St Tammany Record of Environmental Consideration REVISED FOR FEMA ENVIRONMENTAL -LOUISIANA -2006 See 44 Code of Federal Regulation Part 10 Project Name/Number: Mandeville Elementary School/PW#9168/FIPS#103-UH9IO-00 Project Location; 519MassenaSt.,Mandeville, Louisiana,St.TammanyParish70448 Latitude: 30.36757, Longitude: -90.08088 Project Description: Heavy rains and high winds from Hurricane Katrina (DR.-1603) caused significant exterior and interior damage to Mandeville Elementary School. Cumulative repair work to the buildings include the removal/replacement of insulation, ceiling tile, ceiling plywood, ceiling lights, floor tile, roofing components, vinyl wall base, wood fascia, plywood soffit, wood framing, and wood paneling. One (1) play structure and one (1) wood picket fence trash enclosure were also removed and replaced. Hazard mitigation has been proposed for six (6) portable classrooms (nos. 3,4,5,6,7 & 8a), located on the south side ofthe school grounds, which had extensive wind damage to the asphalt shingle roofs due to hurricane Katrina. Over halfofthe shingles were repaired by attaching a new pre-formed metal panel roofover top ofthe existing sloped shingled roof. The useful life of a property installed metal roof is estimated to be about 30 years versus 20 years for an asphalt shingle roof. All work will be performed in a previously disturbed area with no indication of nearby waterways or other bodies of water. Documentation Requirements I I (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) 1^1 (Long version) All applicable laws and executive orders were reviewed. Additional information for compliance is attached to this REC and/or included in project files, as applicable. National Environmental Policy Act (NEPA) Determination I I Statutorily excluded from NEPA review. (Review Concluded) O Programmatic Categorical Exclusion -Category (Reference PCE in comments) (Review Concluded) CD Categorical Exclusion -Category l~l NoExtraordinary Circumstances exist. Are project conditions required? \Z\ Yes (see section V) Q No (Review Concluded) O Extraordinary Circumstances exist (See Section IV). r~l Extraordinary Circumstances mitigated. (See Section IVcomments) Are project conditions required? Q Yes (see section V) \Z\ No (Review Concluded) f~l Environmental Assessment l~1 SupplementalEnvironmentalAssessment(ReferenceEAor PEAincomments) 153 Environmental Impact Statement Comments: This project meets the criteria for the alternative arrangement, permanent school, type of project. This project hasconditions andrequires mitigation undertheotherEHP laws. Reviewer and Approvals I I ProjectisNon-Compliant(Seeattacheddocumentationjustifyingselection). Record ofEnvironmental Consideration (Version 6/20/06) Reviewer Name: Adam Borden Project Name/Env Database No: Mandeville Elementary School/PW9168 FEMA-1603/1607-DR-LA Parish: St.Tammany FEMA Environmental Reviewer: Name: Adam Bo/den, FEMAJEnvironmental 1bo/den, bbMAJEnvironmental Specialist SpecialistSpecialist, Signature FEMA Regional Environmental Officer or Delegated Approving Official: Name: Michael GriclhamJDeputy Environmental Liason Officer Signature s^***^/ yJ£^> Date fc-3.)-06 . | I. Compliance Review for Environmental Laws (other than NEPA) j A. National Historic Preservation Act (NHPA) ^ Not type ofactivity with potential to affect historic properties. | • Activity meets Programmatic Agreement, December 3,2004. Appendix A: Allowance No. I Are project conditions required? • Yes (see Section V) • No I • Programmatic Agreement not applicable, must conduct standard Section 106 Review. I HISTORIC BUILDINGS AND STRUCTURES I ^ No historic properties that are listed or 45/50 years or older in project area. (Review Concluded) f • Buildingorstructurelistedor45/50yearsorolderinprojectareaandactivitynotexemptfromreview. I • Determination ofNo Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) f Are project conditions required? • Yes (see Section V) • No (Review Concluded) I • Determination of Historic Properties Affected (FEMA finding/SHPO/THPO concurrence on file) [ CI Property aNational Historic Landmark and National Park Service was provided early notification | during the consultation process. If not, explain in comments I • No Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file). [ Are project conditions required? • Yes (see Section V) • No (Review Concluded) I • Adverse Effect Determination (FEMA finding/SHPO/THPO concurrence on file) I [U Resolution ofAdverse Effect completed. (MOA on file) { Are project conditions required • Yes (see Section V) • No (ReviewConcluded) I I t ARCHEOLOGICAL RESOURCES J E3 Project affects only previously disturbed ground. (Review Concluded) f • Project affects undisturbed ground. | d Project area has no potential for presence ofarcheological resources | • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence or j consultationon file). (Review Concluded) f l~l Project area has potential for presence ofarcheological resources | • Determination ofno historic properties affected (FEMA finding/SHPO/THPO concurrence on file) f Are project conditions required • Yes (see Section V) • No (Review Concluded) J [H Determination ofhistoric properties affected j • NR eligible resources not present (FEMA finding/SHPO/THPO concurrence on file). jAre project conditions required [HYes (see Section V) • No (Review Concluded) f • NR eligible resources present inproject area. (FEMA finding/ SHPO/THPO concurrence on I file) • No Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) Are project conditions required? • Yes (seeSection V) • No (Review Concluded) • Adverse Effect Determination. (FEMA finding/ SHPO/THPO concurrence on file) O Resolution ofAdverse Effect completed. (MOA onfile) Are project conditions required? • Yes (see Section V) • No (Review Concluded) Comments: None Record of Environmental Consideration (Version 6/20/06) Reviewer Name: Adam Borden Project Name/Env Database No: Mandeville Elementary School/PW9168 FEMA-1603/1607-DR-LA Parish: St Tammany Correspondence/Consultation/References: B. Endangered Species Act E3 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. • No effect to species ordesignated critical habitat (See comments for justification) Are project conditions required? • Yes (see Section V) • 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) • No(Review Concluded) • Likely toadversely affect species ordesignated critical habitat D Formal consultation concluded. (Biological Assessment and Biological Opinion on file) Are project conditions required? Q YES (see Section V) • NO(Review Concluded) Comments: Projectislocatedinanurbanorpreviouslydevelopedarea. Neitherlistedspeciesortheirhabitatoccurinor nearthissite,thusFEMAfinds therewillbeno effecttothreatenedorendangeredspecies. Correspondence/Consultation/References'. USFWS emergency consultation provisions determined in letters dated September 15,2005. C. Coastal Barrier Resources Act ^ Projectisnotonor connectedtoCBRAUnitorOtherwiseProtectedArea (Review Concluded). • Project ison orconnected toCERA Unit orOtherwise Protected Area. (FEMA determination/USFWS consultation on file) • Proposed action anexception under Section 3505.a.6 (Review Concluded) O Proposed action not excepted under Section 3505.a.6. Are project conditions required? • YES (see Section V) Q NO(Review Concluded) Comments: Project is not within a CBRA zone. Correspondence/Consultation/References: Louisiana Coastal BarrierResource System Maps referenced 06/20/06. D. Clean Water Act KlProjectwould not affect anywaters ofthe U.S. (Review Concluded) O Project would affect waters, including wetlands, ofthe U.S. CIProjectexempted as inkindreplacementorotherexemption. (Review Concluded) • 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) Q NO(Review Concluded) Comments: Nojurisdictional watersofthe U.S., includingwetlands,occurinorneartheprojectarea. Correspondence/Consultation/References: USFWS National Wetlands Inventory map (http://www.fws.gov/nwi/) queried on 06/20/06. E. Coastal Zone Management Act O Projectisnotlocatedina coastalzoneareaanddoesnotaffectacoastalzonearea(Review concluded) E3Projectislocatedina coastal zone areaand/or affectsthecoastal zone ^ State administering agency does not require consistency review. (Review Concluded). I~l State administering agency requires consistency review. Are project conditions required? • YES (see Section V) • NO(Review Concluded) Comments: Thisprojectis locatedwithin theLouisianaCoastal ManagementZone. LADNRhas determinedthatreceiptof federal assistance isconsistentwith theLouisianaCoastal Resource Program. Projects within thecoastal zonemaystill requireacoastalusepermitorotherauthorizationfromDNR. ProjectsmaybecoordinatedbycontactingLADNRat1 800-276-4019. Correspondence/Consultation/References: LDNR Louisiana Coastal Zone map 2002. Record of EnvironmentalConsideration(Version 6/20/06) Reviewer Name: Adam Borden Project Name/Env Database No: Mandeville Elementary School/PW9168 FEMA-1603/1607-DR-LA Parish: St. Tammany F. Fish and Wildlife Coordination Act ^ Project does not affect, control, ormodify awaterway/body ofwater. (Review Concluded) d Projectaffects controlsormodifiesawaterway/bodyofwater. • Coordination withUSFWS conducted • No Recommendations offered by USFWS. (Review Concluded) • Recommendations provided byUSFWS. Are project conditions required? • YES (see Section V) • NO(ReviewConcluded) Comments: Nostreamsor waterbodiesarelocatedinorneartheprojectarea. Correspondence/Consultation/References: Louisiana Map(http://wwwlamap.doa.louisiana.gov/) queried 06/20/06. G. Clean Air Act • Project will not result inpermanent airemissions. (Review Concluded) £3 Project islocated inanattainment area. (Review Concluded) • Projectislocatedina non-attainmentarea. d Coordination required with applicable state administering agency. Are project conditions required? • YES (see section V) • NO (Review Concluded) Comments: Thisprojectinvolvesthe demolitionorrenovationofapublicstructure. Regardlessoftheasbestoscontent,the applicant isresponsible forensuringthatrenovation ordemolition activities arecoordinated with theLouisianaDepartment ofEnvironmentalQuality(LDEQ) inaccordancewiththe LDEQ"FifthAmendedDeclarationof Emergencyand Administrative Order" datedMarch 31,2006,andthe LESHAP protocol datedMarch1,2006,incorporatingthe provisions ofEPA'sNationalEmissionStandardsforHazardousAirPollutants(NESHAP)andtheLouisianaAdministrative Code (LAC)33.111.5151 andChapter27. ShouldAsbestosContainingMaterials (ACMs)bepresentattheprojectsite,the applicantisalsoresponsibleforensuringproperdisposal inaccordancewiththepreviouslyreferencedadministrative orders. Correspondence/Consultation/References: EPA Region 6 Non-attainment Map. H. Farmland Protection Policy Act S Project does not affect designated prime orunique farmland. (Review Concluded) CD Project causes unnecessary orirreversible conversion ofdesignated prime orunique farmland. f~l Coordination with Natural Resource Conservation Commission required. O Farmland Conversion Impact Rating, Form AD-1006, completed. Are project conditions required? • YES (see section V) • NO (ReviewConcluded) Comments: Theprojectsiteisina developed urbanizedareaand FPPA isprecluded. Noprime orunique farmland present. Correspondence/Consultation/References: National Resource Conservation Service, Web Soil Survey (http://websoilsurvev.nrcs.usda.gov/app/ Referenced 06/20/06. I. Migratory Bird Treaty Act O Project not located within a flyway zone. (Review Concluded) Kl Project located within a flyway zone. I~~l Project does not have potential totake migratory birds. (Review Concluded) Areproject conditionsrequired? • Yes(see sectionV) • No (Review Concluded) O Project has potential totake migratory birds. • Contact made with USFWS Are project conditions required? • YES (see section V) • NO (ReviewConcluded) 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/Consultation/References: USFWS guidance letter dated September 15, 2005 for Katrina J. Magnuson-Stevens Fishery Conservation and Management Act Record of Environmental Consideration (Version 6/20/06) Reviewer Name: AdamBorden Project Name/Env Database No: Mandeville Elementary School/PW9168 FEMA-1603/1607-DR-LA Parish: St Tammany EU Project not located inornear Essential Fish Habitat. (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) • No (Review Concluded) • Project adversely affects Essential Fish Habitat (FEMA determination/USFWS/NMFS concurrence on file) Q NOAA Fisheries provided no recommendation(s) (Review Concluded). Are project conditions required? • Yes (see Section V) • No(Review Concluded) O NOAA Fisheries provided recommendation(s) d Written reply toNOAA Fisheries recommendations completed. Are project conditions required? Q YES (see Section V) • NO (Review Concluded) Comments: Project isnot located inornearanysurface waters withthe potentialtoaffect EFHspecies. Correspondence/Consultation/References: Louisiana Map(http://wwwlamap.doa.louisiana.gov/) referenced 06/20/06. K. Wild and Scenic Rivers Act ^ ProjectisnotalonganddoesnotaffectWildorScenicRiver(WSR)-(ReviewConcluded) • Project isalong oraffects WSR • Project adversely affects WSR asdetermined by NPS/USFS. FEMA cannot fund theaction. (NPS/USFS/USFWS/BLM consultation on 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: NationalWildandScenicRivers http://www.nps.gov/rivers/wildriverslist.html. referenced 06/20/06. L. Other Relevant Laws and Environmental Regulations State Hazardous Materials and Solid Waste Laws Comments: Unusable equipment, debris and material shall be disposed of in an approved manner and location. Intheeventsignificantitems(orevidencethereof)arediscovered duringimplementation oftheproject applicant shall handle, manage, and dispose of petroleum products, hazardous materials and/or toxic waste in accordanceto the requirementsandto the satisfaction ofthe governinglocal,state and federalagencies. Correspondence/Consultation/Reference: II. Compliance Review for Executive Orders A. E.0.11988 -Floodplains SI No Effect on Floodplains/Flood levels and project outside Floodplain -(Review Concluded) O Located inFloodplain orEffects on Floodplains/Flood levels • No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded). Are project conditions required? • Yes (see Section V) Q No(Review Concluded) IZI Beneficial Effect onFloodplain Occupancy/Values (Review Concluded). CD Possible adverse effects associated with investment in floodplain, occupancy ormodification offloodplain environment O 8 Step Process Complete -documentation onfile Are project conditions required? • YES (seeSection V) • NO (Review Concluded) Comments: The site is located in Zone C. http://store.msc.fema.gov/webapp/wcs/stores/servlet/FemaWelcomeView?storeId=l 0001 &catalog!d=10001&langld=-1. click on Map search and enter lat/long for the site. Correspondence/Consultation/References: FEMAFloodInsuranceRateMap,Community PanelNo.2202020002C, revised 4/4/83. B. E.0.11990 -Wetlands Record ofEnvironmental Consideration (Version 6/20/06) Reviewer Name: Adam Borden Project Name/Env Database No: Mandeville Elementary School/PW9168 FEMA-1603/1607-DR-LA Parish: St Tammany E] No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) • Located in Wetland oreffects Wetland(s) • Beneficial Effect on Wetland -(Review Concluded) O Possible adverse effect associated with constructing inornear wetland Q Review completed aspart offloodplain review l~1 8Step Process Complete-documentation onfile Are project conditions required? • YES (see Section V) • NO (Review Concluded) Comments: No wetlandsweredetermined to be presentby checkingthe USFWSNational WetlandsInventory(NWI) maps. Correspondence/Consultation/References: USFWS NWI map accessed on-line (http://wetlandsfws.er.usgs.gov/wtlnds/launch.html) 06/20/06. C. E.0.12898 -Environmental Justice for Low Income and Minority Populations d No Low income orminority population in, near oraffected by the project -(Review Concluded) E] Low income orminority population inornear project area f~l No disproportionately high and adverse impact on low income orminority population-(Review Concluded) d Disproportionately high oradverse effects onlow income orminority population Are project conditions required? O YES (see Section V) • NO (ReviewConcluded) Comments: Thepercentpopulationsof70448are:92.8% white,4.7% blackand2.4%hispanic. Themedianhousehold income in 1999 was $ 64,482 and 4.1 % of families are below poverty level. Correspondence/Consultation/References: U.S.Censusbureau2000 dataathttp://factfinder.census.gov.referenced 06/20/06. 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: Unusable equipment, debris and material shall be disposed of in an approved manner and location. In the event significantitems(or evidencethereof) are discoveredduring implementationof the project applicantshall handle, manage,and dispose ofpetroleumproducts, hazardousmaterials and/or toxic waste in accordance to the requirements and to the satisfaction of the governing local, state and federal agencies. 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"underanycircumstance mayrequireanEnvironmental Assessment(EA)withtheexceptionof(ii)which shouldbeappliedinconjunctionwithcontroversyonanenvironmentalissue. Ifthecircumstancecanbemitigated, please explain in comments. If no, leave blank. Yes • (i) Greater scope or size than normally experienced for a particular category of action • (ii) Actions with a high level of public controversy • (iii) Potential for degradation, even though slight, of already existing poor environmental conditions; • (iv) Employment of unproventechnologywith potential adverse effects or actions involving unique or unknown environmental risks; Record of Environmental Consideration (Version 6/20/06) Reviewer Name: Adam Borden ProjectName/Env DatabaseNo: Mandeville Elementary School/PW9168 FEMA-1603/1607-DR-LA Parish:St Tammany C] (v) Presence ofendangered orthreatened species ortheir critical habitat, orarchaeological, cultural, historical or other protected resources; O (vi) PresenceofhazardousortoxicsubstancesatlevelswhichexceedFederal,stateorlocal regulations or standards requiring action or attention; C3 (vii) Actions with the potential toaffect special status areas adversely orother critical resources such as wetlands, coastal zones, wildlife refuge and wilderness areas, wild and scenic rivers, sole or principal drinking water aquifers; • (viii) Potential for adverse effects onhealth orsafety; and CI (ix) Potential to violate a federal, state, local ortribal law orrequirement imposed for the protection of the environment. O (x) Potential for significant cumulative impact when the proposed action iscombined with otherpast,presentandreasonablyforeseeablefutureactions,eventhoughthe impacts ofthe proposed action may not be significant by themselves. Comments: None V. Environmental Review Project Conditions Project Conditions: This project must comply with all conditions ofthe attached Programmatic Categorical Exclusion. In addition, the following conditions apply as a condition of FEMA funding reimbursement: • This project involves the demolition or renovation ofa public structure. Regardless ofthe asbestos content, the applicant is responsible for ensuring that renovation or demolition activities are coordinated with the Louisiana Department of Environmental Quality (LDEQ) in accordance with the LDEQ "Fifth Amended Declaration of Emergency and Administrative Order" dated March 31, 2006, and the LESHAP 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 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. • Unusable equipment, debris and material shall be disposed of in an approved manner and location. In the event significant items (or evidence thereof) are discovered during implementation of the project applicant shall handle, manage, and dispose of petroleum products, hazardous materials and/or toxic waste in accordance to the requirements and to the satisfaction ofthe governing local, state and federal agencies. Record of Environmental Consideration (Version 6/20/06)