Attachment_1_Caneel_Bay_Soil_Removal_Action_Work_Plan.pdf

Caneel Bay Resort Site NTCRA National Park Service Virgin Islands National Park U.S. Department of the Interior

Non-Time-Critical Removal Action Work Plan: Soil and Sediment

Virgin Islands National Park Caneel Bay Resort

St. John, U.S. Virgin Islands EDL Number 5SER3346

Prepared by

October 6, 2023

Caneel Bay Non-Time-Critical Action Work Plan October 6, 2023 Page | i

Table of Contents List of Tables ................................................................................................................................. iii

List of Figures ............................................................................................................................... iii

Appendices.................................................................................................................................... iii

List of Abbreviations and Acronyms .......................................................................................... iv

1. Introduction

1.1. Purpose

1.2. Site Description

1.2.1. Area 2

1.2.2. Area 3

1.3. Community Involvement and Regulatory Approval

2. Project Organization and Responsibilities

2.1. NPS

2.2. Project Engineer

2.3. Contractor

3. Removal Action Objectives and Cleanup Goals

3.1. RAOs

3.2. Removal Action Goals

4. Attainment of ARARs and Substantive Permit Requirements

4.1. Erosion and Sediment Control

4.2. Environmental Protection

4.3. Coastal Zone Management Act

4.4. NPS Organic Act

4.5. National Historic Preservation Act

4.6. Endangered Species Act

5. NTCRA Summary

5.1. Area 2 Soil Removal

5.2. Area 2 Sediment Removal

5.3. Area 3 Soil Removal

5.4. Contaminated Material Disposal

5.5. NTCRA Observation, Confirmatory Sampling, and Reporting

5.5.1. Air Monitoring

5.5.2. NTCRA Observation and Record Keeping

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Caneel Bay Resort Site NTCRA National Park Service

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5.6. Confirmatory Sampling and Screening

5.6.1. Sampling Methodology

5.6.2. Quality Assurance/Quality Control

5.6.3. Area 2 Confirmatory Sampling and Screening

5.6.4. Area 3 Confirmatory Sampling and Screening

5.6.5. NTCRA Completion Report

6. Post-Removal Action Maintenance

8. References

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Caneel Bay Resort Site NTCRA National Park Service

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List of Tables Table 1a – RGs for Soil: Area 2 (in text, page 8)

Table 1b – RGs for Soil: Area 3 (in text, page 8)

Table 2 – Summary of NTCRA Areas (in text, page 12)

Table 3 – Summary of Area 2 Confirmation Samples (in text, page 18)

Table 4 – Summary of Area 3 Confirmation Samples (in text, page 19)

List of Figures Figure 1 – Site Layout

Figure 2 – Soil Removal Plan – Area 2

Figure 3 – Sediment Removal Plan – Area 2

Figure 4a – Soil Removal Plan – Area 3, Topographic Contours

Figure 4b – Soil Removal Plan – Area 3, Anticipated Removal Depths

Figure 4c – Soil Removal Plan – Area 3, Anticipated Removal Elevations

Appendices Appendix 1 – NTCRA Specifications

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Caneel Bay Resort Site NTCRA National Park Service

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List of Abbreviations and Acronyms ARAR Applicable or Relevant and Appropriate Requirement BCY bank cubic yards CBIA CBI Acquisitions, LLC CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COC contaminant of concern DDD dichlorodiphenyldichloroethane DDE dichlorodiphenyldichloroethylene DDT dichlorodiphenyltrichloroethane DDT-total* DDT plus its metabolites DDD and DDE DPNR USVI Department of Planning and Natural Resources DU decision unit EE/CA Engineering Evaluation/Cost Analysis EHI EHI Acquisitions, LLC ft bgs feet below ground surface LCY loose cubic yards mg/kg milligrams per kilogram NCP National Oil and Hazardous Substances Pollution Contingency Plan NPS National Park Service NTCRA non-time-critical removal action RAO removal action objective RG Removal Goal RUE Retained Use Estate SAP Sampling and Analysis Plan SRU Soil Removal Unit SWPPP Stormwater Pollution Prevention Plan TPDES Territorial Pollutant Discharge Elimination System USEPA U.S. Environmental Protection Agency USVI U.S. Virgin Islands VIC Virgin Islands Code VIIS Virgin Islands National Park XRF x-ray fluorescence

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Caneel Bay Resort Site NTCRA National Park Service

Virgin Islands National Park U.S. Department of the Interior

1. Introduction This Non-Time-Critical Removal Action (NTCRA) Work Plan will be used to plan and execute the removal of contaminants in soil from the Caneel Bay Resort Site (Site; see Figure 1). The main body of this plan guides the National Park Service (NPS) Project manager and Project Engineer contracted by NPS. The Contractor’s scope of work, responsibilities, and requirements of work are detailed in the specifications package provided as Appendix 1 (hereinafter “the Specifications”).

The Caneel Bay Resort (Resort) is located within the Virgin Islands National Park (VIIS) on St.

John, U.S. Virgin Islands (USVI). VIIS is owned by the United States and is under the jurisdiction of the National Park Service (NPS). The Resort closed to overnight visitors in 2017 after Hurricanes Irma and Maria severely damaged many of its buildings. EHI Acquisitions, LLC and CBI Acquisitions, LLC (EHI/CBIA) currently operate the Resort pursuant to the Retained Use Estate (RUE), which will expire on September 30, 2023 (National Park Service, 2013).

Through an Engineering Evaluation/Cost Analysis (EE/CA) (National Park Service, 2021a) and addendum (National Park Service, 2023), NPS determined that pesticides and metals were released through historical waste disposal practices at the Caneel Bay Resort (Resort) at the following locations:

• surface soil in portions of the engineering, landscaping, and maintenance area (referred to as Area 2 in the EE/CA and identified on Figure 1)

• accumulated sediment within a paved/concrete lined channel located within Area 2

• a former landfill (referred to as Area 3 in the EE/CA and identified on Figure 1)

NPS concluded that a removal action is needed to meet removal action objectives (RAOs) related to risks to human health and the environment, eliminate future constraints on park resources, and comply with cleanup standards and regulations. The NTCRA will consist of excavating and disposing of surface soil in Area 2; removing sediment from the drainage channel within Area 2; and excavating and disposing of solid waste and contaminated material in Area 3. The work to be performed by the Contractor is summarized in Section 5 and further defined in the Specifications.

NPS is conducting the NTCRA at the Caneel Bay Resort using its authority under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), and its implementing regulations, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), which govern response actions at sites where hazardous substances present a potential risk to human health or ecological receptors.

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This NTCRA Work Plan was prepared by VHB under contract number 140P2121A0026, order number 140P5422F0029.

1.1. Purpose

During an EE/CA investigation in 2020, NPS identified two areas with contaminants of concern (COCs) in soil that may pose an unacceptable risk to human health or the environment. The selected alternative for Areas 2 and 3 is soil removal. The RAOs and established cleanup goals for the Site are presented in Section 3. In summary, the RAOs address risk to human health and the environment, constraints on park resources, and federal and territorial regulations and guidance. Upon completion of the NTCRA, Areas 2 and 3 will be considered acceptable for unrestricted (i.e., residential) use.

1.2. Site Description

1.2.1. Area 2

Area 2 was the maintenance, landscaping, and vehicle-fueling area of the Resort. A risk assessment conducted for the EE/CA indicated that elevated levels of certain metals and pesticides present within surface soil in a portion of Area 2 may pose an unacceptable ecological risk and human health risk, specifically to a future resident or worker. Metals that exceed the Site Removal Goals (RGs) are barium, copper, and zinc, and the pesticides are DDT-total1, aldrin, dieldrin, and chlordane. As shown on Figure 2, the affected surface soil is located within four Surface Soil Removal Units (“Surface SRUs”; A2-Soil1, A2-Soil2, A2-Soil3, and A2-Soil4) that make up a portion of previously sampled decision units (DUs). These Surface SRUs generally consist of grassy and vegetated areas to the north and northeast of the buildings at the end of the road that services the engineering and maintenance area. These vegetated areas are flat and generally bounded by paved roads, building foundations, or a paved/concrete-lined drainage channel. No permanent structures were observed within the decision units, although buried

1 The pesticide dichlorodiphenyltrichloroethane (DDT) degrades into metabolites dichlorodiphenyldichloroethane (DDD) and dichlorodiphenyldichloroethylene (DDE). The RG is specified for DDT-Total*, which is the sum of the concentrations of DDT, DDD, and DDE.

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Virgin Islands National Park U.S. Department of the Interior utilities may be present close to the ground surface. The area is generally accessible by paved roadways to the north and south, as shown on Figure 2.

The previously sampled DUs, as described in the EE/CA, extended across the paved drainage channel that bisects a portion of Area 2. The current conceptual site model (CSM) suggests that contamination in Area 2 is the result of surface releases near the maintenance, landscaping, and vehicle-fueling area of the Resort and that releases would be limited by the presence of the drainage channel. Therefore, the proposed Surface SRUs (A2-Soil1, A2-Soil2, A2-Soil3, A2-Soil4) were defined to abut the drainage channel. To evaluate whether surface soils on the opposite side of the drainage channel meet RGs and therefore do not warrant removal under this NTCRA, additional confirmatory sampling in this area is proposed as outlined in Section 5.6 and shown on Figure 2.

The paved/concrete-lined drainage channel in Area 2 and along the boundary of SRUs A2-Soil3 and A2-Soil4 increases the potential for impacted soil to be carried towards the ocean during rainstorms. As shown on Figure 3, the channel begins near the Resort entrance at the eastern edge of Area 2, is aligned along the northeastern portion of Area 2, and discharges to the ocean near the dock at Little Caneel Beach. A tributary channel, beginning to the southwest near the desalination plant, joins the main channel approximately midway between Area 2 and the discharge to the ocean. Based on field observations, the main channel above the confluence is typically dry. However, the tributary channel receives a baseflow which may be related to desalination plant operations. The channel is approximately 1,500 feet long; the eastern portions are trapezoidal, measuring approximately 4 feet across at the top, 1 foot across at the bottom, and 2 feet deep. Although much of the surface of these portions are bare, there are deposits of sediment in several locations. Approximately 1,000 feet west of Area 2, the channel widens into a 130-foot masonry-walled basin (identified as A2-Sed2 on Figure 2) where more substantial deposits of sediment have accumulated. Photographs of the tributary channel (representative of A2-Sed1) and the basin (A2-Sed2) are provided below.

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Photograph 1: Tributary channel (representative of A2-Sed1) receiving baseflow.

Photograph 2: Drainage channel basin (A2-Sed2).

Drainage channel

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Caneel Bay Resort Site NTCRA National Park Service

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1.2.2. Area 3

Area 3 is the location of a former quarry and landfill in the northern portion of a small coastal valley to the east of Honeymoon Beach. The landfill extends south from a bedrock ridge into the valley, where it rises as much as 20 feet above the surrounding valley. Based on field observations and analytical results, the approximately 1.5-acre landfill includes a mixture of organic matter (wood and other vegetative waste), soil, debris (including concrete, plastics, and metals), and CERCLA hazardous substances, including the pesticide DDT. An intermittent stream or channel2, leading towards Honeymoon Beach, exists along the southern slope of the landfill.

Surface soil sampling of the dry stream bed confirmed the presence of the metals.

NPS concluded that the ecological risks from pesticides and metals in Area 3 are above acceptable levels. Additionally, based on visible evidence of erosion and exposed waste material, NPS concluded that the slopes of the landfill are unstable and that the potential migration of landfill materials towards Honeymoon Beach via erosion and/or slope failure, poses an unacceptable risk. This risk will increase with the anticipated increased frequency and intensity of storms due to climate change. NPS concluded that a removal action from the SRU (A3-Soil1) and Surface SRUs (A3-Soil2, A3-Soil3, and A3-Soil4), identified on Figures 4a-4c, is required to address the conditions in Area 3. The estimated volume of landfilled material between the ground surface and the maximum observed solid waste depth is approximately 12,500 bank cubic yards (BCY). The surface SRUs represent an additional 31 BCY.

Along with solid waste and CERCLA hazardous substances, the landfill is expected to contain benign fill materials, including vegetative matter, uncontaminated soil, and/or quarry materials.

The composition and distribution of this material will not be fully understood until it is excavated. The material will be excavated to the maximum observed depth of solid waste.

Additional excavation will be conducted if evidence of solid waste is observed at the excavation bottom or if confirmatory sampling indicates COC concentrations above the RGs.

2 The channel was dry during EE/CA field investigation activities; however, evidence of intermittent flow was observed.

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1.3. Community Involvement and Regulatory Approval

Community engagement is an NPS priority. VIIS maintains a Caneel Bay website with current information about the NPS investigation and response to environmental contamination and the redevelopment of Caneel Bay at https://parkplanning.nps.gov/CaneelBayAssessment. Two draft final investigation and response reports have been issued for public comment, including the EE/CA Report (June 2021) and the EE/CA Report Addendum (September 2022). Two public meetings, a Community Learning Session, and an NPS Listening Session, were held during the public comment period for each report. NPS considered and responded to all public comments while finalizing the reports.

In October 2021, NPS issued an Action Memorandum selecting a removal action to address hazardous substances detected in the landscaping, engineering, and maintenance area (Area 2) and resort landfill (Area 3). In October 2022, NPS issued an Action Memorandum selecting the removal action to address asbestos-containing debris and loose piping at the Site.

2. Project Organization and Responsibilities

2.1. NPS

NPS is the lead CERCLA response agency and will oversee the cleanup. NPS will appoint a Contracting Officer and Contracting Officer’s Representative. The Contracting Officer will define compliance with the contract terms and safeguard the interests of the United States in the contractual relationship. The Contracting Officer’s Representative will administer the contract and monitor the Contractor’s performance. NPS may appoint a separate Project Manager as the primary point of contact. The Project Manager or Contracting Officer’s Representative will communicate with the Project Engineer, Contractor, and USVI Department of Planning and Natural Resources (DPNR).

2.2. Project Engineer

The Project Engineer, contracted by NPS, shall provide observation services during soil and sediment removal to confirm conformance with the NTCRA Work Plan and Specifications;

conduct confirmatory sampling; conduct preliminary and final closeout inspections; and prepare the completion report. The Project Engineer shall maintain communication with NPS and prepare daily reports during the performance of the NTCRA. The Project Engineer must be present during soil and sediment disturbing work.

2.3. Contractor

The Contractor, contracted by NPS, shall conduct the soil and sediment removal and disposal as outlined herein and detailed in the Specifications.

https://parkplanning.nps.gov/CaneelBayAssessment

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Caneel Bay Resort Site NTCRA National Park Service

Virgin Islands National Park U.S. Department of the Interior

3. Removal Action Objectives and Cleanup Goals NPS used data collected during the EE/CA field investigation to determine that removal actions in Areas 2 and 3 were necessary to address unacceptable risks to human and ecological receptors. NPS also determined that a removal action was necessary to address asbestos containing debris at the Site; asbestos abatement by removal and disposal is being performed under a separate NTCRA.

The removal action objectives (RAOs) describe what is necessary to protect human health and the environment under current and reasonably anticipated future land use scenarios.

Correspondingly, the RGs are the numerical concentrations required to achieve the RAO for each

COC.

3.1. RAOs

The RAOs for this NTCRA are:

• Eliminate unacceptable risks to human health and the environment (represented by the RG concentrations), specifically:

Soil: Reduce risks to all ecological receptors that are potentially posed by pesticides and metals in Area 2 and Area 3.

Soil: Reduce the potential for future releases of COC-containing sediment to surface water at Honeymoon Beach in the event of an extreme rainfall event and/or sea level rise.

• Eliminate or minimize contaminant-related constraints to the full enjoyment and utilization of park resources for operational, scientific, and interpretive purposes consistent with NPS mandates, including the non-impairment mandate discussed in Section 4, below.

• Satisfy federal and territorial Applicable or Relevant and Appropriate Requirements (ARARs) and associated cleanup standards.

3.2. Removal Action Goals

The numerical criteria used in decision making for the COCs established in the EE/CA are the RGs. Tables 1a and 1b, below, summarize the RGs, which will be applied for soil remaining within Area 2 and Area 3, respectively, following soil removal. An additional specific removal action criteria for Area 3, as discussed further in Section 5.3, specifies that no solid waste will be present following excavation within the former landfill area.

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Caneel Bay Resort Site NTCRA National Park Service

Virgin Islands National Park U.S. Department of the Interior

Table 1a RGs for Soil: Area 2

Contaminant of Concern RG (milligrams per kilogram, mg/kg)

Barium 185

Copper 99

Zinc 147

DDT-Total* 0.17

Aldrin 0.018

Chlordane 1.20

Dieldrin 0.034

Table 1b RGs for Soil: Area 3

Contaminant of Concern RG (milligrams per kilogram, mg/kg)

Copper 99

DDT-Total* 0.17

4. Attainment of ARARs and Substantive Permit Requirements CERCLA provides that no Federal, Territorial, or local permit is required for the portion of any response action conducted on-site but requires that the substantive requirements that would be contained in a permit must be satisfied. This section outlines the specific statutes or regulations, compliance with which would be required but for the CERCLA permit exemption and describes how the substantive requirements of those statutes or regulations, will be satisfied as the NTCRA is designed and implemented.

Without the CERCLA permit exemption, a project involving the activities required to implement the NTCRA would typically be required to obtain permits for development and sediment and erosion control. Territorial regulations and substantive requirements that would be contained in the permits will be addressed and adhered to during NTCRA activities as detailed in this NTCRA Work Plan and the Specifications.

Additionally, this Section summarizes other ARARs which will potentially impact the NTCRA and identifies how these ARARs will be attained during implementation. A full identification and analysis of ARARs is provided in the EE/CA.

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Caneel Bay Resort Site NTCRA National Park Service

Virgin Islands National Park U.S. Department of the Interior

4.1. Erosion and Sediment Control

In accordance with the DPNR Territorial Pollutant Discharge Elimination System (TPDES) General Permit Number VIGSA0000 and Virgin Islands Code (VIC) Title 12, Chapter 7 – Water Pollution Control, construction activities with a disturbance area of 1 or more acres require an application for coverage under the General Permit. The disturbance area of the NTCRA will exceed 1 acre.

However, because the work is being conducted under a CERCLA action, application for coverage under the General Permit will not be required. The substantive requirements will be met though the preparation and implementation of a Stormwater Pollution Prevention Plan (SWPPP) in conformance with VIGSA0000; refer to Specifications Section 01 57 19 – Temporary Environmental Controls.

4.2. Environmental Protection

VIC Title 12, Chapter 13 – Conservation establishes environmental protection requirements for redevelopment of land. Redevelopment activities, including clearing, grading, and filling, require the approval by DPNR of an Earth Change Plan. Because the work is being conducted under a CERCLA action, approval of an Earth Change Plan by DPNR will not be required. However, the substantive requirements of the regulation will be met. The NTCRA will restore pre-existing conditions (pre-landfilling conditions in Area 3), thereby preventing potential adverse impacts due to change of Site-use. Additionally, controls will be implemented to prevent environmental degradation during the NTCRA; refer to Specifications Section 01 57 19 – Temporary Environmental Controls.

4.3. Coastal Zone Management Act

The DPNR established the Virgin Islands Coastal Zone Management Program (CZM) under the Federal Coastal Zone Management Act of 1972 to protect and preserve coastal resources in the USVI. Program regulations are detailed in the Virgin Islands Coastal Zone Management Act of 1978 (VICZMA), VIC Title 12, Chapter 21. The Resort is mapped within the Tier One Coastal Zone (CZM@STT_PM, 2021). The activities to be performed may be included in the definition of

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Caneel Bay Resort Site NTCRA National Park Service

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“development3”, including removal of fill or solid material on land. Primary coastal zone concerns for this work are the prevention of adverse impacts on marine habitats through erosion, sediment transport, and/or contaminant transport to Salomon Bay and Caneel Bay.

Because the work is being performed under a CERCLA action, a Coastal Zone Management permit will not be required. However, the substantive requirements of the regulation will be met.

The NTCRA will restore pre-existing conditions (pre-landfilling conditions in Area 3), thereby preventing potential adverse impacts due to change of Site-use. Additionally, controls (including for erosion and sedimentation) will be implemented to prevent environmental degradation during the NTCRA; refer to Specifications Section 01 57 19 – Temporary Environmental Controls.

4.4. NPS Organic Act

The non-impairment mandate, which is found in the NPS Organic Act, 54 U.S.C. §§ 100101, et seq. requires NPS to “conserve the scenery, natural and historic objects, and wild life in [National Park] System units and to provide for the enjoyment of the scenery, natural and historic objects, and wild life in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” The work is consistent with the non-impairment mandate because it will remove contaminated soils that are currently impairing the use and enjoyment of VIIS. As described in Division 1 of the Specifications, steps will be taken to prevent damage to natural and cultural resources during implementation of the work.

4.5. National Historic Preservation Act

The Resort is not currently listed on the National Register of Historic Places, but plantation ruins have been preserved in the central portion of the Resort (National Park Service, 2013) and 109 buildings at the Resort are potentially eligible for listing. There are no apparent aboveground plantation ruins at Areas 2 and 3, although VIIS records show portions of Area 2 may cut through the location of a historical village. VIIS officials will identify potential archaeological and cultural resources during the pre-Work conference and be available for consultation during the Work in Area 2. Work to be conducted in “Archeologically Sensitive Areas” will be conducted in

3 VIC Title 12, Chapter 21 §902 indicates: “‘Development‘ means the placement, erection, or removal of any fill, solid material or structure on land, in or under the water; discharge or disposal of any dredged material or of any liquid or solid waste; grading, removing, dredging, mining, or extraction of any materials...”

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Caneel Bay Resort Site NTCRA National Park Service

Virgin Islands National Park U.S. Department of the Interior accordance with Section 01 35 13.22 – Archeological Protection. VIIS staff will be alerted if artifacts that appear to be more than 50 years old are encountered during the NTCRA. No formal documentation that the project is unlikely to have adverse effects on historic structures, cultural landscapes, or archaeological sites is required.

NPS has designated some plants and trees with heritage status. NPS will identify heritage trees and plants on a map and during the pre-work conference. As stated in Specifications Section 01 10 00 – Summary of Work, the Contractor must take precautions to avoid damaging heritage trees and plants.

4.6. Endangered Species Act

Two federally listed endangered species of plants, the St. Thomas prickly-ash (Zanthoxylum thomasianum) and Thomas’ lidflower (Calyptranthes thomasiana), occur within VIIS.

Zanthoxylum thomasianum typically grows on east-facing, rocky slopes above sea salt spray (Ray & Stanford, 2005); this habitat is not present at the Resort. Calyptranthes thomasiana is only present at Bordeaux Mountain (Silander, 1997), which is not in the Resort. The Virgin Islands tree boa (Chilabothrus granti) is also a listed rare species typically present in dense growths of trees where the canopy is formed by interlocking tree branches. The work is not anticipated to adversely impact land-based endangered species or habitats located within the Site.

Numerous federally listed threatened or endangered species are present in waters off St. John.

According to a National Marine Fisheries Service letter to NPS dated October 10, 2012, “listed sea turtle and coral species may occur” near Caneel Bay Resort (National Park Service, 2013).

Federally listed species include the West Indian manatee (Trichechus manatus), the hawksbill sea turtle (Eretmochelys imbricata), and the leatherback sea turtle (Dermochelys coriacea).

Environmental controls, including erosion and sediment controls, will be implemented during the NTCRA to prevent the potential migration of sediments and contaminants to surface water;

refer to Specifications Section 01 57 19 – Temporary Environmental Controls.

5. NTCRA Summary This section summarizes the scope of the soil and sediment NTCRA. The Contractor scope of work, responsibilities, and requirements for the work (including, but not limited to decontamination, Site controls, environmental controls, worker health and safety, fill materials, etc.) are detailed in the Specifications.

A summary of the removal areas and estimated removal volumes is provided in Table 2, below.

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Table 2 Summary of NTCRA Areas

Area Removal Units Anticipated Depth4

Anticipated Volume3

Reference Figure(s)

Area 2 Surface Soil

A2-Soil1, A2-Soil2, A2-Soil3, A2-Soil3

0 to 0.5 feet below ground surface (ft bgs)

288 BCY Figure 2

Area 2 Sediment A2-Sed1, A2- Sed2, A2-Sed3

0 to 0.5 ft bgs within the basin

(A2-Sed2)

40 loose cubic yards (LCY) Figure 3

Area 3 Landfill A2-Soil1 Variable; 0 to 22+ ft bgs (Figure 4b) 12,500 BCY Figures 4a, 4b, 4c

Area 3 Surface Soil

A3-Soil2, A3-Soil3, A3-Soil4 0 to 0.5 ft bgs 31 BCY Figure 4a

5.1. Area 2 Soil Removal

The Area 2 Soil Removal generally consists of excavation and off-Site disposal of surface soil (i.e., 0 to 0.5 feet below ground surface) from SRUs A2-Soil1, A2-Soil2, A2-Soil3, and A2-Soil4 (total estimated volume of 288 BCY), as depicted on Figure 2. Additional excavation may be required, depending on the results of confirmatory sampling – see Section 5.6.

4 Excavation may extend beyond removal unit boundaries and/or anticipated removal depths if RGs or RAOs are not met. Additionally, actual excavation volumes and depths may change based on actual Site conditions and/or field observations (e.g., evidence of solid waste in Area 3). Volume and depth estimates were refined during development of the NTCRA Work Plan and may differ from the estimates provided in the EE/CA.

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Caneel Bay Resort Site NTCRA National Park Service

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Area 2 Soil Removal steps generally include:

• Location and marking of potential cultural resources, heritage trees, and endangered plants within and surrounding the proposed work areas. Location and marking of subsurface utilities.

• Installation, maintenance, and removal of erosion and sedimentation controls in accordance with an approved SWPPP. Refer to Specifications Section 01 57 19 – Temporary Environmental Controls.

• Locating and marking support areas (e.g., staging area(s), stockpile area(s), decontamination pad(s), construction exit(s), etc.) and excavation limits. Refer to Specifications Section 02 61 13 – Excavation and Handling of Contaminated Material and Section 31 11 00 – Clearing and Grubbing.

• Clearing of vegetation within the marked support and excavation areas and management of vegetative debris. Refer to Specifications Section 31 11 00 – Clearing and Grubbing.

• Excavation, loading, transportation, and disposal of soil from SRUs A2-Soil1, A2-Soil2, A2-Soil3, and A2-Soil4 at an approved facility. Refer to Specifications Section 02 61 13 – Excavation and Handling of Contaminated Material and Section 02 51 29 – Removal and Disposal of Contaminated Soils.

• Collection of confirmatory samples by the Project Engineer and, where required, additional excavation. Refer to Section 5.6.

• Backfilling and compaction of excavation areas. Refer to Specifications Section 31 23 23 Backfill and Compaction and the NPS Clean Fill Protocol.

• Revegetation of excavation areas and surrounding disturbed areas. Removal of erosion and sediment controls following stabilization of the Site.

5.2. Area 2 Sediment Removal

The Area 2 Sediment Removal generally consists of removal and off-Site disposal of sediment from the drainage channel adjacent to and downstream from the Area 2 SRUs, identified as A2- Sed1, A2-Sed2, and A2-Sed3 (total estimated volume of 40 LCY on Figure 3).

Area 2 Sediment Removal steps generally include:

• Location and marking of potential cultural resources, heritage trees, and endangered plants within and surrounding the proposed work areas.

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• Installation, maintenance, and removal of erosion and sedimentation controls in accordance with an approved SWPPP. Refer to Specifications Section 01 57 19 – Temporary Environmental Controls.

• Locating and marking support areas (e.g., staging area(s), stockpile area(s), decontamination pad(s), construction exit(s), etc.) and removal limits. Refer to Specifications Section 02 61 13 – Excavation and Handling of Contaminated Material and Section 31 11 00 – Clearing and Grubbing.

• Clearing of vegetation within the marked support and sediment removal areas and management of vegetative debris. Refer to Specifications Section 31 11 00 – Clearing and Grubbing.

• Installation of stormwater diversion features in accordance with an approved SWPPP.

Refer to Specifications Section 01 57 19 – Temporary Environmental Controls.

• Removal, loading, transportation, and disposal of sediment from Sediment Removal Units A2-Sed1, A2-Sed2, and A2-Sed3 at an approved facility. Refer to Specifications Section 02 61 13 – Excavation and Handling of Contaminated Material and Section 02 51 29 – Removal and Disposal of Contaminated Soils.

5.3. Area 3 Soil Removal

The Area 3 Soil Removal generally consists of excavation and off-Site disposal of soil from SRU A3-Soil1 (estimated volume of 12,500 BCY) and surface soil (i.e., 0 to 0.5 feet below ground surface) from SRUs A3-SU-1, A3-SU-2, and A3-SU-3 (total estimated volume of 31 BCY), as depicted on Figures 4a, 4b, and 4c. Soil in A3-Soil1 will be excavated to the elevations identified on Figure 4c (the deepest observed waste in soil borings advanced during the EE/CA investigation). Additional excavation may be required, depending on visual observations and confirmatory sampling results – see Section 5.6 and Specifications Section 02 61 13 Excavation and Handling of Contaminated Material.

Area 3 Soil Removal steps generally include:

• Abandon monitoring well MW-3-01 in accordance with USVI regulations5.

5 Virgin Islands Code (VIC) Title 12, Chapter 5, Water Resources Conservation, § 157, 158, 161 (2019)

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• Location and marking of potential cultural resources, heritage trees, and endangered plants within and surrounding the proposed work areas. Location and marking of subsurface utilities.

• Installation, maintenance, and removal of erosion and sedimentation controls in accordance with an approved SWPPP. Refer to Specifications Section 01 57 19 – Temporary Environmental Controls.

• Locating and marking support areas (e.g., staging area(s), stockpile area(s), decontamination pad(s), construction exit(s), etc.) and excavation limits. Refer to Specifications Section 02 61 13 – Excavation and Handling of Contaminated Material and Section 31 11 00 – Clearing and Grubbing.

• Clearing of vegetation within the marked support and excavation areas and management of vegetative debris. Refer to Specifications Section 31 11 00 – Clearing and Grubbing.

• Excavation to the elevations indicated on Figure 4c from SRU A3-Soil1, followed by loading, transportation and disposal at an approved facility. If evidence of solid waste is identified at the bottom of the excavation, excavation will continue until solid waste is no longer observed. Refer to Specifications Section 02 61 13 – Excavation and Handling of Contaminated Material and Section 02 51 29 – Removal and Disposal of Contaminated Soils.

• Excavation, loading, transportation, and disposal of soil from SRUs A3-SU1, A3-SU2, A3-

SU3.

• Collection of confirmatory samples by the Project Engineer and additional excavation and/or disposal, if required. Refer to Section 5.6.

• Grading and compaction of excavation areas. Refer to Specifications Section 31 23 23 Backfill and Compaction.

• Revegetation of excavation areas and surrounding disturbed areas. Removal of erosion and sediment controls following stabilization of the Site.

5.4. Contaminated Material Disposal

Excavated contaminated material and solid waste will be transported and disposed off-Site in accordance with an approved Transport and Disposal Plan (refer to Specifications Section 02 61 29 Removal and Disposal of Contaminated Materials) and local, state/territorial, and federal rules and regulations. The Contractor will characterize waste materials in accordance with the requirements of each disposal facility. Waste materials may be segregated for separate handling and disposal, based on material characteristics and/or disposal requirements.

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5.5. NTCRA Observation, Confirmatory Sampling, and Reporting

This section outlines a general summary of field procedures that will take place during this NTCRA and select responsibilities of the Contractor and Project Engineer.

5.5.1. Air Monitoring

Due to historical landfilling of organic matter in Area 3, landfill gas (primarily methane) may be generated/accumulated in the subsurface due to anerobic biodegradation. The potential uncontrolled release of landfill gas during excavation of the former landfill may present health and safety risks to Site workers and visitors. Additionally, the generation of dust during all excavation and associated soil-handling activities may present health risks to Site workers and visitors and/or nuisance conditions in surrounding areas.

The Project Engineer will be responsible for conducting and documenting air monitoring during the NTCRA and communicating monitoring results, action level exceedances, and the need for response action to the Contractor, as detailed in Specifications Section 01 57 19 – Temporary Environmental Controls. Monitoring will include:

• Landfill gas (including methane, hydrogen sulfide, and lower explosive limit (LEL)) in the work zone during excavation work at A3-Soil1.

• Dust monitoring in the worker breathing zone and periodic monitoring along the perimeters of the active work areas during excavation, stockpiling, loading, hauling, and other dust-generating activities.

5.5.2. NTCRA Observation and Record Keeping

Excavation, loading, transport, and disposal activities will be conducted by the Contractor as detailed in the Specifications, while also minimizing contaminated soil handling to the extent practical. The Project Engineer will observe and document Site activities associated with this NTCRA and will maintain communication with NPS. Site activities will be documented and reported to NPS by the Project Engineer in daily reports that shall include, at a minimum:

• The areas where work occurred on the specified reporting day;

• Work completed, including a listing of equipment and personnel on site and hours worked;

• Projected next steps;

• Delays and impacts to schedule;

• Quantities of contaminated material handled, loaded, and transported off-Site;

• Quantities of materials (e.g., common fill) imported to the Site;

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• Weather conditions and plans for severe weather;

• Documentation of health and safety meetings, monitoring activities, near misses, and incidents;

• Site access or visitation concerns and resolution; and

• Photographs representative of work performed that day.

5.6. Confirmatory Sampling and Screening

Following the excavation of SRUs, soil confirmation samples will be collected and analyzed for COCs applicable to each area and compared against the RGs to confirm that remaining soil meets the RGs. The Project Engineer will collect confirmation samples and submit them to a commercial laboratory holding National Environmental Laboratory Accreditation Program (NELAP) certifications for metals and pesticides analyses. Sampling methodologies and analytical methods will be consistent with those using during the EE/CA investigation activities.

5.6.1. Sampling Methodology

Confirmation samples will be collected and analyzed using incremental sampling methodology (ISM) techniques. Decision unit (DU) boundaries (equivalent to the soil removal units and confirmation sampling units depicted on Figure 2 and Figure 4a; removal unit A3-Soil1 will be divided into two approximately equal DUs) will be located in the field using a global positioning system (GPS) and marked with flagging, pin flags, or similar.

Consistent with the EE/CA investigation methodology, three ISM replicate samples will be collected from each DU. Each replicate sample will be composed of 40 increments using a systematic random approach (ITRC, 2012). Increments will be collected with a cordless drill fitted with a small-diameter (approximately 0.75-inch) ship auger bit to a depth of 0.5 ft. Samples will be placed directly into the sampling container for each replicate. All non-dedicated sampling equipment will be decontaminated using distilled water and a laboratory-grade detergent prior to first use and between sample collection from each DU.

ISM samples will be submitted to the laboratory for further processing, which will include drying, disaggregating, sieving, and subsampling using the two-dimensional slabcake method.

5.6.2. Quality Assurance/Quality Control

Quality assurance/quality control (QA/QC) measures will be implemented during the investigation to limit variability, mitigate the potential for false positive and/or false negative error, and increase the accuracy and defensibility of the collected data.

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The following QC samples will be collected:

• Replicate samples. Three replicate ISM samples will be collected for each DU.

• Matrix spike/matrix spike duplicate (MS/MSD) samples. MS/MSD samples will be collected and analyzed at a minimum frequency of 1 per 20 primary samples.

• Equipment field blank samples. Equipment blank samples will be collected from non-dedicated sampling equipment at a minimum frequency of 1 per 20 primary samples.

• Method blanks and laboratory control samples. Method blanks and laboratory control samples will be analyzed by the laboratory in accordance with applicable analytical methods.

5.6.3. Area 2 Confirmatory Sampling and Screening

Surface Soil Removal Units As shown on Figure 2 and discussed in Section 1.2.1, four confirmation surface soil sampling units (SUs; A2-SU1, A2-SU2, A2-SU3, and A2-SU4) are proposed that represent surface soils adjacent to the Surface SRUs and the drainage channel. Surface soil confirmation sampling will occur in these areas to identify whether COC concentrations in these soils meet RGs (see Table 1a) and therefore do not warrant removal under this NTCRA.

Following the excavation of Surface SRUs where COCs are present at concentrations exceeding RGs (A2-Soil1, A2-Soil2, A2-Soil3, and A2-Soil4), confirmatory soil samples will be collected from the base of excavation and analyzed for COCs to confirm that remaining soil meets the applicable RGs. A summary of confirmation samples and analyses is provided as Table 3, below.

If confirmatory samples indicate that soil with COC concentrations above the applicable RGs (see Table 1a) remains in place, additional excavation may be required to fully achieve the RAOs.

In this event, the Project Engineer will propose DUs for additional confirmation sampling.

Table 3 Summary of Area 2 Confirmation Samples

Sample ID Sample Type Analytical Methods

Analytes Number of Containers

A2-SU1 Soil - ISM

Organochlorine Pesticides by

8081B, Metals by 6020A

4,4’-DDD, 4-4’-

DDE, 4-4’-DDT,

Aldrin, Chlordane, Dieldrin, Barium, Copper, Zinc

3 (Mark for MS/MSD)

A2-SU2 Soil - ISM 3

A2-SU3 Soil - ISM 3

A2-SU4 Soil - ISM 3

A2-Soil1 Soil - ISM 3

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Sample ID Sample Type Analytical Methods

Analytes Number of Containers

A2-Soil2 Soil - ISM 3

A2-Soil3 Soil - ISM 3

A2-Soil4 Soil - ISM 3

EB-yyyymmdd Field Equipment Blank 2

Drainage Channel Sediment The drainage channel is understood to be paved/concrete-lined and therefore it is anticipated that confirmatory sampling will not be needed as all material will be removed from the channel.

However, the bottom of the drainage channel basin (A2-Sed2) has not been confirmed. If the bottom of the basin is earthen, or if sediment remains, confirmatory soil samples will be collected following sediment removal and compared to the Area 2 RGs (see Table 1a). If COC concentrations above the applicable RGs remain, additional material removal may be required to fully achieve the RAOs.

5.6.4. Area 3 Confirmatory Sampling and Screening

Former Landfill Removal Unit Following the excavation of landfill contents within the former landfill removal unit (A3-Soil1), the Project Engineer will collect confirmatory soil samples within the vertical and horizontal extents of excavation (in areas where soil is present above bedrock). The collected samples will be analyzed for COCs to assure that soil above the applicable RGs (see Table 1b) has been removed. If confirmatory samples indicate that soil with contaminant concentrations above the applicable RGs remains in place, additional soil excavation may be required to fully achieve the RAOs.

Surface Soil Removal Units As shown on Figure 4a, four confirmation surface sampling units (SUs: A3-SU1, A3-SU2, A3-SU3, and A3-SU4) are proposed to delineate surface soil exceedances identified during the EECA investigations and define the excavation boundary. If COC concentrations in these soils exceed RGs (see Table 1b), excavation areas will be redefined and additional confirmation sampling will be conducted.

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Following the excavation of Surface SRUs where COCs are present at concentrations exceeding RGs (A3-SU1, A3-SU2, A3-SU3), confirmatory soil samples will be collected from the base of excavation and analyzed for COCs to assure that soil above the applicable RGs has been removed. If the base of excavation sample results indicate that COC concentrations above the applicable RGs (see Table 1b) remain following the removal of surface soil (0-0.5 ft bgs), additional excavation may be required to fully achieve the RAOs.

Table 4 Summary of Area 3 Confirmation Samples

Sample ID Sample Type Analytical Methods

Analytes Number of Containers

A3-SU1 Soil - ISM

Organochlorine Pesticides by

8081B, Metals by 6020A

4,4’-DDD, 4-4’-

DDE, 4-4’-DDT,

Copper

A3-SU2 Soil - ISM 3

A3-SU3 Soil - ISM 3

A3-SU4 Soil - ISM 3

A3-Soil1-1 Soil - ISM 3

A3-Soil1-2 Soil - ISM 3

A3-Soil2 Soil - ISM 3

A3-Soil3 Soil - ISM 3

A3-Soil4 Soil - ISM 3

5.6.5. NTCRA Completion Report

Upon completion of all work outlined in this NTCRA Work Plan, the Project Engineer will prepare and submit to NPS a NTCRA Completion Report. This Completion Report will include, at a minimum:

• A summary of completed work;

• A letter from the Contractor certifying that the contracted work has been completed;

• A summary of deviations from the NTCRA Work Plan and Specifications on the part of the Contractor, and any unsatisfactory test results reported during the work;

• A map showing final removal unit extents and depths;

• Disposal quantities and destinations for excavated materials;

• Confirmatory sampling results;

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• Daily logs and laboratory analytical reports; and

• Waste manifests, weigh tickets, bills of lading, and other waste disposal documentation.

6. Post-Removal Action Maintenance Long-term maintenance is not required because the NTCRA will not leave contaminants of concern in-place. NPS will inspect slopes in Area 3 for evidence of failure and/or erosion for five years following completion of the NTCRA to confirm that the action has not resulted in increased sedimentation and erosion that may impair water quality or public use areas. Eroded areas will be regraded or repaired by NPS, as necessary. Vegetation will be monitored and selectively managed by NPS to control undesired species until performance objectives are met.

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8. References CZM@STT_PM. (2021, January 7). USVI Tier One. Retrieved from ArcGIS:

https://www.arcgis.com/home/webmap/viewer.html?webmap=1ba84a056a7940fbb63c2 22e26900896&extent=-64.9438,18.3293,-64.9161,18.3456

National Park Service. (2013). Environmental Assessment for the Caneel Bay Resort Lease.

National Park Service. (2021a). Engineering Evaluation/Cost Analysis: Areas 1, 2, and 3 of the Caneel Bay Resort. Caneel Bay Resort Site, Virgin Islands National Park. VHB.

National Park Service. (2023). Final Engineering Evaluation/Cost Analysis Report Addendum 1, Caneel Bay Resort. VHB.

Ray, G., & Stanford, A. (2005). Zanthoxylum thomasianum Survey, Mapping and Population Status Update for the Virgin Islands National Park, St. John, US Virgin Islands. Retrieved from https://academic.uprm.edu/~jchinea/proyectos/FWS/especies/Zanthoxylum/ZanTho_Fin al%20Report%201-06.pdf

Silander, S. (1997). Calyptranthes thomasiana Recovery Plan. U.S. Fish and Wildlife Service.

Retrieved from https://ecos.fws.gov/docs/recovery_plan/970930a.pdf

U.S. Fish and Wildlife Service. (2021). Critical Habitat for Threatened and Endangered Species (Mapper). Retrieved from U.S. Fish and Wildlife Service:

https://fws.maps.arcgis.com/home/webmap/viewer.html?webmap=9d8de5e265ad4fe098 93cf75b8dbfb77.

FIGURES

A3-Soil4

A3-Soil3

A3-Soil2

A3-Soil1

A3-SU-5

A3-SU-4

A3-SU-2

A3-SU-1

30'

40'

40'

30'

30'

20'

208212

MW-3-01

Source: US Virgin Islands GIS Division, Esri, HERE, Garmin, Foursquare, SafeGraph, FAO, METI/NASA, USGS, NPS, Maxar

Soil Removal Unit

Surface Soil Removal Unit

Confirmation Sampling Unit

Confirmation…