Reviewer Name: Brandon M. Clark Applicant: Recovery School District DisasterlEmergeneylProgramIProj«t Title: DR1603LA I Hurricane Katrina I Public ASsistance Program I E0R2982 Florence J. Chester Elementary School Cafeteria Record of Environmental Consideration See 44 Code ofFederal Regulation Part 10. Project NamelNumber: E0R2982 Florence J. Chester Elementary School Cafeteria/ PW 14783 Project Location: 3929 Erato Street, New Orleans, Louisiana, Orleans Parish 70125 (N29.57201, W90.05787) Project Description: Project scope ofwork includes restoring the facility to its pre-disaster condition and upgrading to current codes and standards. Project activities include, but not limited to, repairing and replacing damaged components such as vinyl asbestos tile and adhesive, plywood ceiling, interior doors and hardware, metal doors with push bar and window, acoustical ceiling tiles and insulation, drinking fountains, chalkboard, HV AC units, water heaters, fluorescent lights, and various cleaning. Documentation Requirements D No Documentation Required . 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: None CorrespondenCe/Consultation/References: D. Clean Water Act IZI Project would not affect any waters ofthe U.S. (Review Concluded) o Project would affect waters, including wetlands, of the U.S. o Project exempted as in kind replacement or other exemption. (Review Concluded) o Project requires Section 404/401/or Section 9110 (Rivers and Harbors Act) permit, including qualification under Nationwide Permits. Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Record of Environmental Consideration 3 Reviewer Name: Brandon M. Clark Applicant: Recovery School District DisasterlEmergencylProgramlProject Title: DR1603LA / Hurricane Katrina / Public Assistance Program / E0R2982 Florence J. Chester Elementary School Cafeteria Comments: Project is unlikely to affect waters ofthe United States. Correspondence/Consultation/References: E. Coastal Zone Management Act D Project is not located in a coastal zone area and does not affect a coastal zone area (Review concluded) ~Project is located in a coastal zone area and/or affects the coastal zone ~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: 12/0712006 -This project is located within the Louisiana Coastal Management Zone. LA DNR has determined that receipt offederal 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. Brandon M. Clark, Environmental Specialist Correspondence/Consultation/References: F. Fish and Wildlife Coordination Act ~Project does not affect, control, or modify a waterwayfbody ofwater. (Review Concluded) D Project affects, controls or modifies a waterwayfbody of water. 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: Project is unlikely to affect waters ofthe United States. Correspondence/Consultation/References: G. Clean Air Act ~Project will not result in permanent air emissions. (Review Concluded) D 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: Project will not result in permanent air emissions. Correspondence/Consultation/References: H. Farmland Protection Policy Act ~Project does not affect designated prime or unique farmland. (Review Concluded) D Project causes unnecessary or irreversible conversion ofdesignated prime or unique farmland. D Coordination with Natural Resource Conservation Commission required. D Farmland Conversion Impact Rating, Form AD-1006, completed. Are ro'ect conditions re uired? D YES (see section V D NO eview Concluded Comments: None Correspondence/Consultation/References: I. Migratory Bird Treaty Act D Project not located within a flyway zone. (Review Concluded) ~Project located within a flyway zone. ~Project does not have potential to take migratory birds. (Review Concluded) Are project conditions required? D Yes (see section V) ~No (Review Concluded) D Project has potential to take migratory birds. D Contact made with USFWS Are project conditions required? D YES (see section V) D NO Comments: 12/06/2006-The City ofNew OrleanslOrleans Parish is enrolled in the National Flood Insurance Program (NFlP) as of08/03/1970. Facility is located within an "A4" zone, area of 100-yr flooding, base flood elevations and flood hazard factors as determined per Flood Insurance Rate Map (FIRM) panel number 225203 0160e, dated 03/0111984. Project is for repair ofthe building and replacement of equipment and components. Per 44 CFR 9.11 (DX9), the replacement of building contents, materials and equipment, where possible, disaster proofmg ofthe building and/or elimination ofsuch future losses by relocation ofthose building contents. materials and equipment outside or above the advisory base flood elevation. Kara Knott, CFM Correspondence/Consultation/References: Reviewer Name: Brandon M. Clark Applicant: Recovery School District DiwterlEmergcncylProgramIProjeet Title: DRI603LA I Hurricane Katrina I Public Assistance Program I E0R2982 Florence J. Chester Elementary School Cafeteria B. E.O. 11990 -Wetlands 1:8:1 No Effects on Wetland(s) and project located outside Wetland(s) -(Review Concluded) o Located in Wetland or effects Wetland(s) o Beneficial Effect on Wetland -(Review Concluded) o Possible adverse effect associated with constructing in or near wetland o Review completed as part of floodplain review o 8 Step Process Complete -documentation on file Are project conditions required? 0 YES (see section V) 0 NO (Review Concluded) Comments: None Correspondence/Consultation/References: C. E.O. 12898 -Environmental Justice For Low Income and Minority Populations 1:8:1 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 otber potential environmental concerns in tbe comment box not clearly falling under a law or executive order (see environmental concerns scoping cbecklist for guidance). Comments: None Correspondence/Consultation/References: IV. Extraordinary Circumstances Based on tbe review of compliance witb otber environmental laws and Executive Orders, and in consideration of otber environmental factors, review tbe project for extraordinary circumstances. *A "Yes" under any circumstance may require an Environmental Assessment (EA) with the exception of (ii) which should be applied in conjunction with controversy on an environmental issue. If the circumstance can be mitigated, please explain in comments. lfno, leave blank. Yes o (i) Greater scope or size than normally experienced for a particular category of action o (ii) Actions with a high level of public controversy o (iii) Potential for degradation, even though slight, of already existing poor environmental conditions; o (iv) Employment 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 ofhazardous or toxic substances at levels which exceed Federal, state or local regulations or standards requiring action or attention; o (vii) Actions with the potential to affect special status areas adversely or other critical resources such as wetlands, coastal zones, wildlife refuge and wilderness areas, wild and scenic rivers, sole or principal drinking water aquifers; o (viii) Potential for adverse effects on health or safety; and o (ix) Potential to violate a federal, state, local or tribal law or requirement imposed for the protection of the environment. Reviewer Nlme: Brandon M. Clark Appliclnt: Recovery School District DislsterlEmergencylProgrlmIProjecf Title: DR1603LA I Hurricane Katrina I Public Assistance Program I E0R2982 Flonmce J. Chester Elementary School Cafeteria 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. Comments: None Correspondence/Consultation/References: v. Environmental Review Project Conditions Project Conditions: 1. This project must comply with all conditions ofthe attached Programmatic Categorical Exclusion. 2. In keeping with the stipulations ofthe P A, all proposed repair activities should be done in-kind to match existing materials and form. Any change to the approved scope ofwork will require resubmission for re-evaluation under Section 106 and consultation with the SHPO. Noncompliance may jeopardize the receipt offederal funding. This concludes the Section 106 review for this project. 3. Cleaning ofhistoric building materials, systems and finishes must be executed in accord with the guidance contained in the U.S. Department ofthe Interior, NPS, Preservation Brief No. 6, dangers ofabrasive cleaning to historic buildings, (see http://www.cr.nps.gov/hps/tps/briefslbriefU6.htm). Requirements include: identification of materials to be cleaned, protection ofmaterials not to be cleaned, identification ofgentlest means ofcleaning possible and testing ofcleaning means and methods. Work is to be executed by qualified workers, with documented successful experience working with historic building materials. Abrasive methods ofcleaning are prohibited including: power washing, pressure washing and blasting, unless under the supervision of a qualified building conservator or historical architect. Washing with potable water, non-ionic detergent, scrubbing with natural bristle brushes and rinsing with potable water is acceptable for most historic building materials. Other methods may be acceptable when specified by a qualified historical architect (36 CFR Part 61). Failure to comply with these stipulations may jeopardize receipt ofFEMA funding. 4. Per 44 CFR 9.1 1 (D)(9), the replacement ofbuilding contents, materials and equipment, where possible, disaster proofing ofthe building and/or elimination ofsuch future losses by relocation ofthose building contents, materials and equipment outside or above the advisory base flood elevation. 5. 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 ofpetroleum products, hazardous materials and/or toxic waste in accordance to the requirements and to the satisfaction ofthe governing local, state and federal agencies. 6. Removal and disposal ofdebris 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. 7. 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 ofthe Louisiana Department ofAgriculture and Forestry or his designee(s). 8. This project involves the demolition or renovation ofa public structure that may contain surfaces coated with lead-based paint (LBP). Activities involving abrading (sanding, scraping, etc.), Record ofEnvironmental Consideration 7 12/07/06 Reviewer Name: Brandon M. Clark Applicant: Recovery School District DisasterlEmergencylProgramIProject Title: DRl603LA I Hurricane Katrina I Public Assistance Program I E0R2982 Florence J. Chester Elementary School Cafeteria 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 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. 9. This project involves the demolition or renovation ofa public structure. 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., incorporating the provisions of EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Louisiana Administrative Code (LAC) 33.1II.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. 10. This project potentially involves the disposal of metallic mercury containing electronic devices. The applicant is responsible for ensuring that these devices are recovered, recycled, reused or sequestered in accordance with the Louisiana Department of Environmental Quality (LDEQ) "Declaration of Emergency; Mercury-Containing Devices and Electronic Equipment as Universal Waste" letter dated October 3, 2005. Monitoring Requirements: None