Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramIProjrct Tide: DRI603LA I Hurricane Katrina I Public Assistance Program! EOR 2096 Kennedy High School· Modular 
#3 (Facility) 

Record of Environmental Consideration 

See 44 Code ofFederal Regulation Part 10. 

Project NamefNumber: Kennedy High School -Modular #3 (Facility) / PW 13226 

Project Location: 5700 Wisner Blvd., New Orleans, Louisiana, Orleans Parish, 70124 (N 30.01912, 
W -90.08562) 

Project Description: Project activities include removing and disposing of the building including 
foundation piers. The modular classroom will be replaced with equivalent area modular structure. 
Current codes and standards will apply to new construction. 

Documentation Requirements 

D No Documentation Required (Review Concluded) 

D (Short version) All consultation and agreements implemented to comply with the National Historic 
Preservation Act, Endangered Species Act, and Executive Orders 11988, 11990 and 12898 are 
completed and no other laws apply_ (Review Concluded) 

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

National Environmental Policy Act (NEPA) Determination 

D Statutorily excluded from NEP A review. (Review Concluded) 
D Programmatic Categorical Exclusion -Category (Review Concluded) 
D Categorical Exclusion -Category


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

Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Environmental Assessment 
D Supplemental Environmental Assessment (Reference EA or PEA in comments) 

[8] 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 

i 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 Name: Letha Dawson Applicant: Recovery School district 
DiSlster/EmergencylProgramIProjeet Title: DR I603LA f Hurricane Katrina f Public Assistance Program! EOR 2096 Kennedy High School-Modular 
f#3 (Facility) 

Reviewer and Approvals 

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

FEMA Environmental Reviewer. 
Name: Letha Dawson, Environmental Specialist 


Signature ~&.t..\~ . Date_~09::..:../0=1~/2=0=0=6_____--,


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

Signature ~'/? >' ~ . Date 09/0112006

..........~~~~~.....----------~


I 

I. Compliance Review for Environmental Laws (other than NEP A) 

A. National Historic Preservation Act 

C8l Not type of activity with potential to affect historic properties. <Review Concluded) 

D Applicable executed Programmatic Agreement (12/0312004) 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 
C8l No historic properties that are listed or 45150 years or older in project area. <Review Concluded) 
D Building or structure listed or 45150 years or older in project area and activity not exempt from review. 

D Determination ofNo Historic Properties Affected (FEMA findinglSHPOITHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No <Review Concluded) 
D Determination of Historic Properties Affected (FEMA fmdinglSHPOITHPO concurrence on file) 
D Property a National Historic Landmark and National Park Service was provided early notification 
during the consultation process. Ifnot, explain in comments 
D No Adverse Effect Determination (FEMA fmdinglSHPOITHPO concurrence on file). 
Are project conditions required? D Yes (see section V) D No <Review Concluded) 
D Adverse Effect Determination (FEMA fmdinglSHPOITHPO 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 
C8l 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 fmdinglSHPOITHPO concurrence or 
consultation on file). (Review Concluded) 
D Project area has potential for presence of archeological resources 
D Determination ofno historic properties affected (FEMA fmdinglSHPOITHPO 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 findinglSHPOITHPO concurrence on file). 

Are project conditions required DYes (see section V) D No (Review Concluded) 
D NR eligible resources present in project area. (FEMA fmdingl SHPOITHPO concurrence on 
file) 

D No Adverse Effect Determination. (FEMA findingl SHPOITHPO concurrence on file) 
Are project conditions required? D Yes (see section V) D No (Review Concluded) 
D Adverse Effect Determination. (FEMA findingl SHPOITHPO concurrence on file) 


Reviewer Name: Letha Dawson ApplicaDt: Recovery School district 
DisasterlEmergencylProgramlProjecl Title: DR 1603LA I Hurricane Katrina I Public Assistance Program! EOR 2096 Kennedy High School -Modular 
#3 (Facility) 

D Resolution of Adverse Effect completed. (MOA on file) 

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

(Review Concluded) 

Comments: 8/3112006 -The structure does not meet the SO-year-criterion, nor does it possess the level ofexceptional 

importance required by Criteria Consideration G of the National Register guidelines to be considered eligible for the 
National Register of Historic Places. Therefore, the proposed work will have no effect on standing historic properties. 

Scope of work indicates minor ground disturbing activities associated with the demolition and replacement of the 

modular/non-permanent structure within its original location. Upon consultation of data provided by the State Historic 

Preservation Officer (SHPO), there is a known archaeological site within .S miles of the 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 to comply with these stipulations & additional protocols will 
jeopardize receipt offederal funding. If during the course of work, archaeological artifacts (prehistoric or historic) or 
human remains are discovered, the applicant shall stop work in the vicinity ofthe discovery and take all reasonable 
measures to avoid or minimize harm to the fmds. The applicant shall inform their Public Assistance (PA) contacts at 

FEMA, who will in turn contact FEMA Historic Preservation staff. 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, if unmarked graves are present, compliance with the Louisiana Unmarked Human Burial Sites Preservation Act 

(R.S. 8:671 ET SEQ.) is required. The applicant shaH notify the law enforcement agency ofthe jurisdiction where the 
remains are located within twenty-four hours ofthe discovery. The applicant shaH also notify FEMA and the Louisiana 
Unmarked Burial Sites Board (caH the Louisiana Division of Archeology at 22S-342-8170) within seventy-two hours ofthe 
discovery. If this scope of work and/or the location ofthe new building changes, this project will need to be resubmitted for 
further Section 106 review prior to ground disturbing activities taking place outside of the pre-disaster footprint of the 
building. -Katherine Zeringue, Historic Preservation Specialist/Archaeologist 
Correspondence/Consultation/References: Low Impact Demolition StipUlations & Additional Protocols 
B. Endangered Species Act 


1:8:1 No listed species and/or designated critical habitat present in areas affected directly or indirectly by the Federal action. 
<Review Concluded)
D Listed species and/or designated critical habitat present in the areas affected directly or indirectly by the Federal action. 


D No effect to species or designated critical habitat (See comments for justification) 

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

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

determinationlUSFWSINMFS concurrence on file) <Review Concluded) 

Are project conditions required? D Yes (see section V) D No <Review Concluded)
D Likely to adversely affect species or designated critical habitat 
D Formal consultation concluded. (Biological Assessment and Biological Opinion on file) 
Are project conditions required? D YES (see section V) D NO <Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

C. Coastal Barrier Resources Act 

1:8:1 Project is not on or connected to CBRA Unit or Otherwise Protected Area (Review Concluded). 
D Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determinationlUSFWS consultation on 


file) 
D Proposed action an exception under Section 3S0S.a.6? (Review Concluded) 
D Proposed action not excepted under Section 3S0S.a.6. 


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

Comments: None 
Correspondence/Consultation/References: 

D. Clean Water Act 

1:8:1 Project would not affect any waters of the U.S. <Review Concluded) 
D Project would affect waters, including wetlands, of the U.S. 

Record of Environmental Consideration 3 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramlProject Title: DRI603LA I Hurricane Katrina I Public Assistance Program! EOR 2096 Kennedy High School -Modular 
#3 (Facility) 

oProject exempted as in kind replacement or other exemption. (Review Concluded) 
oProject requires Section 404/401l0r Section 9/10 (Rivers and Harbors Act) permit, including qualification 
under Nationwide Permits. 
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). 

oState 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 waterwaylbody of water. (Review Concluded) 

oProject affects, controls or modifies a waterwaylbody of water. 

oCoordination with USFWS conducted 

oNo 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) 

oProject is located in an attainment area. (Review Concluded) 
oProject is located in a non-attainment area. 


oCoordination 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 

r:::?'In.. _~_~4 .l ___ ,._4 _C'"r __ .l .l._;_. __ ... _.l._._~_. ________.; ____ l"_" ____ I_"_--' I'n __ .! ____ ,...~ ___ I~_.I_~l'\ 

Ii::::.! rl\JJC"~ uvc;:, IlVL aUC"l uC;:'lblla~cu Vllille VI UlllljUC 1d.l11I1<l.IIU. \1:'1."'1'1""' \...uuuuu,"u/

o Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. 

o Coordination with Natural Resource Conservation Commission required. 

o Farmland Conversion Impact Rating, Form AD-1 006, completed. 
Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) 

Comments: None 
Correspondence/Consultation/References: 

I. Migratory Bird Treaty Act 


Reviewer Name: Letha Dawson Applic:ant: Recovery School district 
DisasterlEmergenc:ylProgramIProjec:t Title: DR 1603LA I Hurricane Katrina I Public Assistance Program! EOR 2096 Kennedy High School -Modular 
113 (Facility) 

o 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) 


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 09114/2005. 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 Sununary are met. 
Correspondence/Consultation/References: http://pacificflyway.gov/Documents/Mississippi map.pdf, 

J. Magnuson-Stevens Fishery Conservation and Management Act 

[8J 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 determinationlUSFWSINMFS 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 

[8J 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 determined 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 Floodplains/Flood levels and project outside Floodplain -(Review Concluded) 
[8J Located in Floodplain or Effects on FloodplainslFlood levels 

[8J No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), 
Are project conditions required? [8J Yes (see section V) 0 No (Review Concluded) 

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


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

Record of Environmental Consideration 5 09/01106 


Reviewer Name: Letha Dawson Applicant: Recovery School district 
DisasterlEmergencylProgramIProject Title: DR I603LA I Hurricane Katrina I Public Assistance Program! EOR 2096 Kennedy High School -Modular 
#3 (Facility) 

Comments 08/08/2006 • The City ofNew OrleanslOrleans Parish is enrolled in the National Flood Insurance Program 
(NFIP) as of8/3/1970. Per Flood Insurance Rate Map (FIRM) panel number 2252030095 E, dated 03/0111984, project is 
located within an "A6" zone, area of 100-yr flooding, base flood elevations and flood hazard factors as determined. Project 
is replacement of building and replacement of components. Applicant is required to coordinate with local Floodplain 
Administrator regarding floodplain permit(s) prior to the start of any activities. Applicant is responsible for meeting all 
requirements ofthe permit(s). All coordination pertaining to these permit(s), should be documented to the local Floodplain 
Administrator and copies provided to LA GOHSEP and FEMA as part ofthe permanent project files. Per 44 CFR 9.11(0) 
(9), the replacement of building contents, materials and equipment, where possible, disaster proofing ofthe building and/or 
elimination ofsuch future losses by relocation ofthose building contents, materials and equipment to or above the advisory 
base floodplain. A. C. Clark, Floodplain Specialist 

Correspondence/consultation/references: 

B. E.O. 11990 -Wetlands 
181 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 

08 Step Process Complete -documentation on file 
Are project conditions required? D 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 
181 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 

o No 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) 


Comments: 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 checklist for guidance). 

Comments: None 
Correspondence/Consultation/References: 


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. If the circumstance can 
be mitigated, please explain in comments. lfno, leave blank. 

09/01106Record of Environmental Consideration 6 


Reviewer Name: Letha Dawson Applic:aot: Recovery School district 
DisasterlEmergeoc:ylProgramIProjec:t Title: DRI603LA I Hurricane Katrina I Public Assistance Program! EOR 2096 Kennedy High School -Modular 
#3 (Facility) 

Yes 

o (i) Greater scope or size than nonnally experienced for a particular category of action 
o (ii) Actions with a high level ofpubJic controversy 
o (iii) Potential for degradation, even though slight, of already existing poor environmental 
conditions; 
o (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; 
o (vi) Presence of hazardous 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 
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 

General comments: None 

Project Conditions: 

1. Applicant is required to coordinate with local Floodplain Administrator regarding floodplain 
permit(s) prior to the start of any activities. Applicant is responsible for meeting all 
requirements of the permit(s). All coordination pertaining to these permit(s), should be 
documented to the local Floodplain Administrator and copies provided to LA GOHSEP and 
FEMA as part of the permanent project files. Per 44 CFR 9.11(0) (9), the replacement of 
building contents, materials and equipment, where possible, disaster proofing ofthe building 
and/or elimination ofsuch future losses by relocation ofthose building contents, materials and 
equipment to or above the advisory base floodplain. 
2. 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 of 
federal funding. If during the course ofwork, archaeological artifacts (prehistoric or historic) or 
human remains are discovered, the applicant shall stop work in the vicinity of the discovery and 
take all reasonable measures to avoid or minimize harm to the finds. The applicant shall inform 
their Public Assistance (P A) contacts at FEMA, who will in turn contact FEMA Historic 
Preservation staff. 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, if unmarked graves are present, compliance with the Louisiana Unmarked 
Human Burial Sites Preservation Act (R.S. 8:671 ET SEQ.) is required. The applicant shall 
notify the law enforcement agency of the jurisdiction where the remains are located within 
twenty-four hours of the discovery. The applicant shall also notify FEMA and the Louisiana 



Reviewer Name: Letha Dawson Applicant: Recovery School district 
DlsasterlEmel'1eneylProgramIProject Title: DR 1603 LA I Hurricane Katrina I Public Assistance Program! EOR 2096 Kennedy High School· Modular 
#3 (Facility) 

Unmarked Burial Sites Board (call the Louisiana Division of Archeology at 225-342-8170) 
within seventy-two hours ofthe discovery. If this scope of work and/or the location ofthe new 
building changes, this project will need to be resubmitted for further Section 106 review prior 
to ground disturbing activities taking place outside ofthe pre-disaster footprint of the building. 

3. Unusable equipment, debris and material shall be disposed of in an approved manner and 
location. In the event significant items (or evidence thereot) 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. 
4. Removal and disposal of debris 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. Applicants managing debris staging, 
processing, burning or disposal sites (other than previously permitted landfills) that have been 
permitted 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 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). 
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 "Sixth Amended Declaration of Emergency and 
Administrative Order" dated June 30, 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.III.5151 and Chapter 27. Should Asbestos 
Containing Materials (ACMS) be present at the project site, the applicant is also responsible for 
ensuring proper disposal in accordance with the previously referenced administrative order. 
7. Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise 
concentrating Lead Based Paint (LBP) shall comply \vith applicable provisions of 29 CFR Pa..rts 
1910 and 1926 (OSHA -Worker Safety), and 40 CFR 260 through 268 (EPA -Hazardous 
Waste). The applicant is responsible for ensuring that renovation or demolition activities are 
coordinated with the Louisiana Department of Environmental Quality for abatement activities 
and is also responsible for ensuring proper disposal in accordance with the previously 
referenced regulations. 
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) 



Reviewer Name: ldha Dawson Applicant: Recovery School district 
DisastnlEmergencylProgramIProject Title: DR 1603LA I Hurricane Katrina I Public Assistance Program! EOR 2096 Kennedy High School -Modular 
#3 (Facility) 

"Declaration of Emergency; Mercury-Containing Devices and Electronic Equipment as 
Universal Waste" letter dated October 3, 2005. 

9. The scope of work to replace a structure to pre-disaster condition with upgrades and 
improvements, in order to meet current codes and standards, is not expected to change the 
original footprint. In the event these upgrades and improvements result in a change to the 
overall footprint, a subsequent change to this scope of work will be required. Any change to the 
project scope of work will require re-submission through the State to FEMA and consequently 
requires re-evaluation for compliance with National Environmental Policies. Non-compliance 
with this requirement may jeopardize receipt of federal funds. 

Monitoring Requirements: None