Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Booker T. Wasbinglon Higb School, Bldg. A FEMA·t603/1607·DR·LA PWi#13315 Parisb: Orleans Record of Environmental Consideration REVISED FOR FEMA ENVIRONMENTAL -LOUISIANA -2006 See 44 Code of Federal Regulation Part 10 Project NamelNumber: Booker T. Washington High School, Bldg. A I PW# 13315 FIPS#033-UA9M2-00 Project Location: 120 I S Roman St, New Orleans, LA 70125 Latitude: 29.95035, Longitude: -90.0882 Project Description: Heavy rains and high winds from Hurricane Katrina (DR-1603) caused significant exterior and interior damage to Booker T. Washington High School, Bldg. A of the Recovery School District. This pw reimburses the eligible applicant for replacement of wallboard, ceiling tiles, windows, flooring, doors, roofing/components, and alarmllighting systems. Cleaning/disinfecting work will also be associated with this pw. The new building material will be replaced according to codes and standards upgrades. All work will be performed in a previously disturbed area with no indication ofnearby waterways or other bodies of water. Documentation Requirements 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) 1:8:1 (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 (NEPAl Determination D Statutorily excluded from NEPA review. (Review Concluded) D Programmatic Categorical Exclusion -Category (Reference PCE in comments) !Review Concluded) D Categorical Exclusion -Category D No Extraordinary Circumstances exist. Are project conditions required? D Yes (see section V) D No !Review Concluded) D Extraordinary Circumstances exist (See Section IV). D Extraordinary Circumstances mitigated. (See Section IV comments) Are project conditions required? D Yes (see section V) D No . o Project is on or connected to CBRA Unit or Otherwise Protected Area. (FEMA determinationlUSFWS consultation on file) o Proposed action an exception under Section 3505.a.6 (Review Concluded) o Proposed action not excepted under Section 3505.a.6. Are project conditions required? 0 YES (see Section V) 0 NO (Review Concluded) Comments: Project is not within a CBRA zone. Co"espondenceiConsultationiRe/erences: Louisiana Coastal Barrier Resource System Maps referenced 0911106. D. Clean Water Act 181 Project would not affect any waters of the 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 404/40Ilor 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: No jurisdictional waters ofthe U.S., including wetlands, occur in or near the project area. Co"espondenceiConsultationiRe/erences: USFWS National Wetlands Inventory map (http://www.fws.gov/nwi/)queried on 0911106. 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) Record ofEnvironmental Consideration (Version 091l106) Reviewer Name: Adam Borden. Env. Specialist Project NamelEnv. Database No: Booker T. Washington High School. Bldg. A FEMA-I603/1607-DR-LA PW#13315 Parish: OrieaDS 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). D State administering agency requires consistency review. Are project conditions required? D YES (see Section V) D NO (Review Concluded) Comments: This project is located within the Louisiana Coastal Management Zone. LA Department ofNatural Resources (DNR) has determined that receipt of federal assistance is consistent with the Louisiana Coastal Resource Program. Projects within the coastal zone may still require a coastal use permit or other authorization from DNR. Projects may be coordinated by contacting LA DNR at 1-800-276-4019. Correspondence/Consultation!Re/erences: LDNR Louisiana Coastal Zone map 2002. F. Fish and Wildlife Coordination Act 181 Project does not affect, control, or modifY a waterwaylbody of water. (Review Concluded) D Project affects controls or modifies a waterwaylbody ofwater. D Coordination with USFWS conducted D No Recommendations offered by USFWS. (Review Concluded) D Recommendations provided by USFWS. Are project conditions required? D YES (see Section V) D NO (Review Concluded) Comments: No streams or water bodies are located in or near the project area. Correspondence/Consultation!Re/erences: Louisiana Map (http://wwwlamap.doa.louisiana.govD queried 0911106. G. Clean Air Act D Project will not result in permanent air emissions. (Review Concluded) 181 Project is located in an attainment area. (Review Concluded) D Project is located in a non-attainment area. D Coordination required with applicable state administering agency. Are project conditions required? D YES (see section V) D NO (Review Concluded) Comments: This project involves the demolition or renovation ofa public structure. Regardless 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 "Sixth Amended Declaration ofEmergency and Administrative Order" dated March 31,2006, and the LESHAP protocol dated March 1,2006, incorporating the provisions ofEPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code (LAC) 33.m.51S1 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. Correspondence/Consultation!Re/erences: EPA Region 6 Non-attainment Map. H. Farmland Protection Policy Act 181 Project does not affect designated prime or unique farmland. (Review Concluded) D Project causes unnecessary or irreversible conversion of designated prime or unique farmland. D Coordination with Natural Resource Conservation Commission required. D Farmland Conversion Impact Rating, Form AD-l 006, completed. Are project conditions required? D YES (see section V) D NO (Review Concluded) Comments: The project site is in a developed urbanized area and Farmland Protection Policy Act (FPPA) is precluded. No prime or unique farmland present. Correspondence/Consultation!Re/erences: National Resource Conservation Service, Web Soil Survey I(httu:llwebsoilsurvev.nrcs.usda.llov/aool )referenced 09/1106. I. Migratory Bird Treaty Act D 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) Record of Environmental Consideration (Version 09/1/06) Are project conditions required? 0 Yes (see section V) 181 No (Review Concluded) Reviewer Name: Adam Borden, Env. Specialist Project Name/Env. Database No: Booker T. Wuhington High School, Bldg. A FEMA·I60;J/1607·DR.LA. PWIII»I! Parish: Orleans 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: 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. CorresfJondencelConsultation!Rejerences: USFWS guidance letter dated September 15,2005 for Katrina 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 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: Project is not located in or near any surface waters with the potential to affect EFH species. CorrespondenceiConsultation!Rejerences: Louisiana Map (bttp://wwwlamDP.doa.louisiana.govD referenced 0911106. 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 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 CorrespondencelConsultation!Rejerences: National Wild and Scenic Rivers http://www.nps.gov/riverslwildriverslist.html. referenced 0911/06. L. Other Relevant Laws and Environmental Regulations State Hazardous Materials and Solid Waste Laws Comments: -In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana parishes 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). -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 ofsites damaged as a result ofsuch operations are ineligible for federal funding. Previously obligated funding is subject to de-obligation ifa determination of ineligibility is made. Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Database No: Booker T. Washington High School, Bldg. A FEMA-1603/1607-DR-LA PWI#13315 Parish: Orleans -Lead-Based paint this project involves the demolition ofa public structure that may contain surfaces coated with leadbased paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating LBP shall comply with appJicable provisions of29 CFRparts 1910 and 1926 (OSHA-worker safety), and 40 CFR260 through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that project activities are coordinated with the Louisiana Department of Environmental Quality for abatement activities and is also responsible for ensuring proper disposal in accordance with the previously referenced regulations. II. Compliance Review for Executive Orders A. E.O. 11988 -Floodplains D No Effect on FloodplainsIFlood levels and project outside Floodplain -(Review Concluded) IZJ Located in Floodplain or Effects on FloodplainsIFlood levels IZJ No adverse effect on floodplain and not adversely affected by the floodplain. (Review Concluded), Are project conditions required? D Yes (see Section V) IZJ No (Review Concluded) D Beneficial Effect on Floodplain OccupancyNalues (Review Concluded). D Possible adverse effects associated with investment in floodplain, occupancy or modification of floodplain environment D 8 Step Process Complete -documentation on file Are project conditions required? D YES (see Section V) D NO (Review Concluded) Comments: The site is located in Zone B. http://store.msc.fema.gov/webapp/wcs/stores/servletlFemaWelcomeView?storeld= 1 000 1 &catalogId=1000 l&langId=-l, The city ofNew Orleans 1Orleans Parish enrolled in the National Flood Insurance Program (NFIP) on 08/0311970. Per Flood Insurance Rate Map (FIRM) panel number 2252030160 E, dated 03/0111984, project is located in zone "B", area protected from 1OO-yr flood by levee, dike, or other structure subject to failure or overtopping during larger floods. Project is to repair building to pre-disaster footprmt which is not likely to affect any floodplain. Without mitigation. A. C. Clark, Floodplain Specialist CorrespondenceiConsultationIRe/erences: FEMA Flood Insurance Rate Map, Community Panel No. # 2252030160 E, dated 03/0111984, B. E.O. 11990 -Wetlands 181 No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) D Located in Wetland or effects Wetland(s) D Beneficial Effect on Wetland -(Review Concluded) D Possible adverse effect associated with constructing in or near wetland D Review completed as part offloodplain review D 8 Step Process Complete -documentation on file Are project conditions required? D YES (see Section V) D NO (Review Concluded) Comments: No wetlands were observed during site visit or determined to be present by checking the USFWS National Wetlands Inventory (NWI) maps. CorrespondenceiConsultationIRe/erences: USFWS NWI map accessed on-line (bttp:l/wetlandsfws.er.usgs.gov/wtlndsllaunch.html) 0911/06. c. E.O. 12898 -Environmental Justice for Low Income and Minority Populations D No Low income or minority popUlation in, near or affected by the project -(Review Concluded) IZJ Low income or minority population in or near project area 181 No disproportionately high and adverse impact on low income or minority population-(Review Concluded) D Disproportionately high or adverse effects on low income or minority population Are project conditions required? D YES (see Section V) D NO (Review Concluded) Comments The percent populations of70125 are: 71.3% Black, 25.6% White, and 2.6% Hispanic. The median household income in 1999 was $ 20,089 and 37.3% of families are below poverty level. CorrespondenceiConsullationIRe/erences: U.S. Census bureau 2000 data at http://factfmder.census.gov, referenced 09/1/06. Reviewer Name: Adam Borden, Env. Specialist Project NamelEnv. Databalle No: Booker T. Wasbington Higb Scbool, Bldg. A FEMA-1603/1607·DR·LA PW1I13315 Parish: OrIeaDs III. Other Environmental Issues Identify other potential environmental concerns in the comment box not clearly falling under a law or executive order (see environmental concerns scoping checklist for guidance). State Hazardous Materials and Solid Waste Laws Comments: -In accordance with the Fonnosan Tennite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana parishes ofCalcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, S1. Bernard, S1. 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). -Removal and disposal ofdebris 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, efc's (refrigerants), radioactive waste or regulated infectious wastes must be segregated from and excluded from non-hazardous debris collection, staging, processing and disposal sites. Failure to comply with applicable legal requirements in debris collection and/or disposal operations will jeopardize federal funding. The clean-up or restoration/repair of sites damaged as a result of such operations are ineligible for federal funding. Previously obligated funding is subject to de-obligation if a detennination of ineligibility is made. -Lead-Based paint this project involves the demolition of a public structure that may contain surfaces coated with leadbased paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating LBP shall comply with applicable provisions of29 CFR parts 1910 and 1926 (OSHA-worker safety), and 40 CFR 260 through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that project activities are coordinated with the Louisiana Department of Environmental Quality for abatement activities and is also responsible for ensuring proper disposal in accordance with the previoUsly referenced regulations. Correspondence/Consultation/Reference: IV. Extraordinary Circumstances Based on the review of compliance with other environmental laws and Executive Orders, and in consideration of other environmental factors, review the project for extraordinary circumstances. '" A "Yes" under any circumstance may require an Environmental Assessment (EA) with the exception of(ii) which should be applied in conjunction with controversy on an environmental issue. Ifthe circumstance can be mitigated, please explain in comments. Ifno, leave blank. Yes o (i) Greater scope or size than nonnany experienced for a particular category of action o (ii) Actions with a high level ofpublic controversy o (iii) Potential for degradation, even though slight, ofalready existing poor environmental conditions; o (iv) Employment of unproven technology with potential adverse effects or actions involving unique or unknown environmental risks; o (v) Presence of endangered 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; Reviewer Name: Adam Borden, [nv. Spedalist Project NamelEnv. Database No: Booker T. Washington Higb School, Bldg. A FEMA-1603/1607-DR-LA PWII13315 Parish: Orleans D (viii) Potential for adverse effects on health or safety; and D (ix) Potential to viorate a federal, state, local or tribal law or requirement imposed for the protection of the environment. D (x) Potential for significant cumulative impact when the proposed action is combined with other past, present and reasonably foreseeable future actions, even though the impacts ofthe proposed action may not be significant by themselves. IComments: None V. Environmental Review Project Conditions Project Conditions: The following conditions apply as a condition ofFEMA 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 I, 2006, incorporating the provisions ofEPA'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 orders. • In accordance with the Formosan Termite Initiative Act, (LA R.S. 3:3391.1 thru 3391.13) the Louisiana parishes of Calcasieu, Cameron, Jefferson Davis, Orleans, Jefferson, Plaquemines, St. Bernard, St. Charles, St. John the Baptist, St. Tammany, Tangipahoa and Washington are under quarantine. The movement of wood or cellulose material, temporary housing or architectural components (e.g. beams, doors and other wood salvaged from a structure) may not leave the quarantined parishes without written authorization from the commissioner of the Louisiana Department of Agriculture and forestry or his designee(s). • Removal and disposal 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, efc's (refrigerants), radioactive waste or regulated infectious wastes must be segregated from and excluded from non-hazardous debris collection, staging, processing and disposal sites. Failure to comply with applicable legal requirements in debris collection and/or disposal operations will jeopardize federal funding. The clean-up or restoration/repair ofsites damaged as a result ofsuch operations are ineligible for federal funding. Previously obligated funding is subject to de-obligation ifa determination of ineligibility is made. • Lead-based paint -this project involves the demolition of a public structure that may contain surfaces coated with lead-based paint (LBP). Activities involving abrading (sanding, scraping, etc.), heating, stripping, or otherwise concentrating LBP shall comply with applicable provisions of 29 CFR parts 1910 and 1926 (OSHA-worker safety), and 40 CFR 260 through 268 (EPA -hazardous waste). The applicant is responsible for ensuring that project activities are coordinated with the Louisiana Department of Environmental Quality for abatement activities and is also responsible for ensuring proper disposal in accordance with the previously referenced regulations. • In keeping with the stipulations of the PA, all proposed repair activities should be done in-kind to match existing materials and form. Any change to the approved scope of work will require resubmission for re-evaluation under Section 106 and consultation with the SHPO. Non-compliance may jeopardize the receipt offederal funding. This concludes the Section 106 review for this project.