Attachment_1_Non-Time-Critical_Removal_Action_(Area_2_Soil_and_Sediment).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: Area 2 Soil and Sediment

Virgin Islands National Park Caneel Bay Resort

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

June 12, 2024

Caneel Bay Non-Time-Critical Action Work Plan June 12, 2024 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

1.3. Community Involvement and Regulatory Approval

2. Project Organization and Responsibilities

2.1. NPS

2.2. Project Monitor

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. Contaminated Material Disposal

5.4. NTCRA Observation, Confirmatory Sampling, and Reporting

5.4.1. Air Monitoring

5.4.2. NTCRA Observation and Record Keeping

5.5. Confirmatory Sampling and Screening

5.5.1. Sampling Methodology

5.5.2. Quality Assurance/Quality Control

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5.5.3. Area 2 Confirmatory Sampling and Screening

5.5.4. NTCRA Completion Report

6. Post-Removal Action Maintenance

8. References

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List of Tables Table 1 – RGs for Soil: Area 2 (in text, page 7)

Table 2 – Summary of NTCRA Areas (in text, page 11)

Table 3 – Summary of Area 2 Confirmation Samples (in text, page 16)

List of Figures Figure 1 – Site Layout

Figure 2 – Soil Removal Plan – Area 2

Figure 3 – Sediment Removal Plan – Area 2

Appendices Appendix 1 – NTCRA Specifications

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List of Abbreviations and Acronyms ARAR Applicable or Relevant and Appropriate Requirement BCY bank cubic yards CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 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 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 SAP Sampling and Analysis Plan SRU Soil Removal Unit TPDES Territorial Pollutant Discharge Elimination System UPPP Under-an-Acre Pollution Prevention Plan USVI U.S. Virgin Islands VIC Virgin Islands Code VIIS Virgin Islands National Park

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Caneel Bay Resort Site NTCRA National Park Service

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1. Introduction This Non-Time-Critical Removal Action (NTCRA) Work Plan will be used to plan and execute the removal of contaminants in soil and sediment 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 Monitor contracted by NPS. The Contractor’s scope of work, responsibilities, and requirements of work (the “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.

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)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 and removing sediment from the drainage channel within Area 2. 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

1This Work Plan is limited to removal actions for the locations in Area 2.

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Plan (NCP), which govern response actions at sites where hazardous substances present a potential risk to human health or ecological receptors.

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: Area 2 and Area 3. This NTCRA Work Plan is limited to Area 2. Additionally, removal of asbestos-containing debris has been completed under a separate NTCRA. This Work Plan does not include removal or abatement of asbestos-containing debris or lead-based paint.

The selected alternative for Area 2 is soil and sediment 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, Area 2 will be considered acceptable for unrestricted (i.e., residential) use.

1.2. Site Description

Area 2 of the Site 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-total2, 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

2 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 the road that services the engineering and maintenance area. These vegetated areas are flat and mostly bounded by paved roads, building foundations, or a paved/concrete-lined drainage channel. No permanent structures were observed within the decision units, although buried utilities may be present close to the ground surface. The area is 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 5.5 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, 2021.

Photograph 2: Drainage channel basin (A2-Sed2), 2021.

Drainage channel

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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 at 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).3 In October 2022, NPS issued an Action Memorandum selecting the removal action to address asbestos-containing debris and loose piping at the Site.4

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 Monitor, Contractor, and USVI Department of Planning and Natural Resources (DPNR).

3 This Work Plan is limited to Area 2.

4 Removal of asbestos-containing debris has been completed under a separate NTCRA and is not included as part of this NTCRA.

https://parkplanning.nps.gov/CaneelBayAssessment

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2.2. Project Monitor

The Project Monitor, 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 inspections; and prepare the completion report. The Project Monitor shall maintain communication with NPS and prepare daily reports during the performance of the NTCRA. The Project Monitor 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.

3. Removal Action Objectives and Cleanup Goals NPS used data collected during the EE/CA field investigation to determine that a removal action in Area 2 was necessary to address unacceptable risks to human and ecological receptors.

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:

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

• 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.

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3.2. Removal Action Goals

The numerical criteria used in decision making for the COCs established in the EE/CA are the RGs. Table 1, below, summarizes the RGs, which will be applied for soil remaining within Area 2, following soil removal.

Table 1 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

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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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 for the Area 2 NTCRA is expected to be substantially less than 1 acre. The Contractor will prepare and implement an Under-an- Acre Pollution Prevention Plan (UPPP) to control potential discharges of pollutants from the Site during removal action activities. 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, 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 “development5”, 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

5 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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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, 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 Area 2, although VIIS records show portions of Area 2 may cut through the location of a historical village. There are currently no known undisturbed archeologically sensitive areas within the identified excavation areas. However, VIIS officials will identify potential archeological 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 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 archeological 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-mobilization conference. As stated in Specifications Section 01 10 00 – Summary of Work, the Contractor must take precautions to avoid damaging heritage trees and plants.

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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 Depth6

Anticipated Volume5

Reference Figure(s)

Area 2 Surface Soil

A2-Soil1, A2-Soil2, A2-Soil3, A2-Soil4

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

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 5.5.

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 area. Location and marking of subsurface utilities.

• Installation, maintenance, and removal of erosion and sedimentation controls in accordance with an approved UPPP. 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

6 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. 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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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 Monitor and, where required, additional excavation. Refer to Section 5.5.

• Recordation of final excavated extents and elevations, performed by the Contractor.

• 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.

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.

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

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• 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. 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 shall be segregated for separate handling and disposal, based on material characteristics and/or disposal requirements.

5.4. 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 Monitor.

5.4.1. Air Monitoring

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 Contractor shall control generation of dust to greatest extent practicable during their operations.

The Project Monitor 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:

• 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.

5.4.2. 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 Monitor will observe and document Site activities associated with this

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NTCRA and will maintain communication with NPS. Site activities will be documented and reported to NPS by the Project Monitor 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, stockpiled, loaded, and transported off-Site;

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

• 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.

The Contractor will prepare and submit independent daily reports in accordance with Specifications Section 01 31 00 – Project Management and Coordination.

5.5. 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 Monitor 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 used during the EE/CA investigation activities. The Project Monitor is responsible for sample collection, preservation, transportation, and laboratory analytical costs of the confirmatory samples.

NPS cannot guarantee a specific turnaround time from date of confirmation sample collection to the receiving of analytical results; however, depending on when samples are shipped and assuming no delays are encountered, the expectation is that confirmation sampling results will be provided to the Project Monitor within three days after receipt by the lab (assuming one day for shipping and a 48-hour turn-around time by the lab). FedEx shipments are picked up on Tuesdays and Thursdays with the closest certified lab being in Puerto Rico. The realized number

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Virgin Islands National Park U.S. Department of the Interior of days will be affected by FedEx’s limited pick-up schedule and other factors beyond the control of NPS or the Project Monitor.

5.5.1. 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) 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, 2020). 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.

5.5.2. 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.

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.

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Caneel Bay Resort Site NTCRA National Park Service

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

5.5.3. 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. Prior to or at the beginning of Contractor mobilization, the Project Monitor will conduct surface soil confirmation sampling in these areas to identify whether COC concentrations in these soils meet RGs (see Table 1) 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), the Project Monitor will collect confirmatory soil samples 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 1) remains in place, additional excavation may be required to fully achieve the RAOs. In this event, the Project Monitor will propose DUs for additional confirmation sampling to NPS.

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 A2-Soil2 Soil - ISM 3 A2-Soil3 Soil - ISM 3 A2-Soil4 Soil - ISM 3

EB-yyyymmdd Field Equipment Blank 2

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Caneel Bay Resort Site NTCRA National Park Service

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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 1). If COC concentrations above the applicable RGs remain, additional material removal may be required to fully achieve the RAOs.

5.5.4. NTCRA Completion Report

Upon completion of all Work outlined in this NTCRA Work Plan, the Project Monitor will prepare and submit to NPS a NTCRA Completion Report, using the most current Removal Action Completion Report Template. 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;

• 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. 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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Caneel Bay Resort Site NTCRA National Park Service

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7. 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

Interstate Technology and Regulatory Council (ITRC). (2020). Incremental Sampling Methodology (ISM) Update.

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

Caneel Bay Resort Site NTCRA National Park Service

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

APPENDICES

Caneel Bay Resort Site NTCRA National Park Service

VIIS - 5SER3346 TABLE OF CONTENTS AND DEFINITIONS - 1

SOIL AND SEDIMENT REMOVAL

CANEEL BAY REMOVAL ACTION – AREA 2 SOIL AND SEDIMENT REMOVAL

VIRGIN ISLANDS NATIONAL PARK - 5SER3346

TABLE OF CONTENTS

Division 1

01 11 00 Summary of Work

01 26 01 Contract Modification Procedures

01 27 00 Definition of Contract Line Items

01 31 00 Project Management and Coordination

01 33 23 Submittal Procedures

01 35 13.22 Archeological Protection

01 42 00 Reference Standards

01 50 00 Temporary Facilities and Controls

01 57 19 Temporary Environmental Controls

01 77 00 Inspection Procedures

Division 2

02 51 00 Physical Decontamination

02 61 13 Excavation and Handling of Contaminated Material

02 61 29 Removal and Disposal of Contaminated Sediment and Soils

Division 3

31 11 00 Clearing and Grubbing

31 23 23 Backfill and Compaction

32 90 00 Planting

VIIS - 5SER3346 TABLE OF CONTENTS AND DEFINITIONS - 2

DEFINITIONS

DEFINITIONS

The following words, terms, and abbreviations, when used within these specifications shall have the following meanings unless the context clearly indicates otherwise.

1. Access Road: Existing and proposed roadways within the Resort used to provide equipment and personnel access to Work Area, as defined in the approved Construction Plan.

2. APHIS: USDA Animal and Plant Health Inspection Service.

3. Area 2: The former engineering, landscaping, and maintenance area of the Resort, as identified in the 2021 Engineering Evaluation/Cost Analysis (EE/CA).

4. Area 3: The former landfill area of the Resort, as identified in the 2021 EE/CA.

5. Authorized Visitor: NPS Contracting Officer (CO) and their representatives, and any representative of a regulatory or other agency having jurisdiction over the project.

6. Clean Fill: Soil for use in backfilling meeting the requirements of the NPS Clean Fill

Protocol.

7. Common Fill: Soil for use in backfilling excavations to within 6 inches of the final ground surface.

8. Construction Plan: Pre-construction planning documents prepared by the Contractor, including, but not limited to, construction schedule, construction drawings, UPPP, Decontamination Plan, and HASP.

9. Contract Documents: Documents comprising the contract between the Contractor and NPS, including, but not limited to the Contractor’s proposal, the Specifications, and the NTCRA Work Plan.

10. Contractor: The firm hired by NPS to conduct the Work.

11. Contract Time: The period of performance defined in the Contract Documents.

12. Contract Sum: The Contract price defined in the Contract Documents.

13. DPNR: US Virgin Islands Department of Planning and Natural Resources.

14. EE/CA: The 2021 NPS Engineering Evaluation/Cost Analysis: Areas 1, 2, and 3 of the

Caneel Bay Resort.

15. EPA or USEPA: United States Environmental Protection Agency.

16. HASP: Site-Specific Health and Safety Plan.

17. Haul Road: Existing and proposed roadways within the Resort used for heavy truck traffic/waste transportation, as defined in the approved Construction Plan.

18. Hazardous Waste: A waste which meets the criteria established in RCRA or specified in

40 CFR § 261.3.

19. NPS: National Park Service.

20. NTCRA: Non-Time Critical Removal Action.

21. OSHA: Occupational Safety and Health Administration.

22. Personal Protective Equipment (PPE): Appropriate protective clothing, gloves, eye protection, footwear, and head gear.

23. UPPP: Under-an-Acre Pollution Prevention Plan.

24. Plastic Sheeting: Polyethylene sheeting of a certain thickness as indicated.

25. Pre-Mobilization Conference: On-Site meeting to be conducted prior to start of on-Site

Work with Contractor, NPS, and NPS’s representatives – including the Project Monitor.

26. Project Monitor: The firm hired by the NPS to conduct third-party oversight of the Work, conduct inspections, and collect confirmation samples.

VIIS - 5SER3346 TABLE OF CONTENTS AND DEFINITIONS - 3

27. Punch List: List of construction items to be completed and/or corrected, prepared by Contractor or Project Monitor.

28. RCRA: Resource Conservation and Recovery Act.

29. Resort or Site: Caneel Bay Resort.

30. Sediment Removal Unit: Stormwater drainage channel sediment removal area, as defined in the NTCRA Work Plan and Specifications.

31. Soil Removal Unit or Surface Soil Removal Unit: Soil excavation areas, as defined in the

NTCRA Work Plan and Specifications.

32. Topsoil: Fertile soil for use in backfilling the top 6 inches of excavations in areas to be revegetated.

33. USDA: United States Department of Agriculture.

34. USVI: United States Virgin Islands.

35. VIIS or Park: Virgin Islands National Park.

36. Work: the scope of work summarized in Section 01 11 00 and detailed in other specification sections.

37. Work Area: The lateral extents of excavation areas, as defined in the NTCRA Work Plan and Specifications, plus ancillary support areas (e.g., laydown areas, stockpiles areas, access routes, etc.) to be defined in the approved Construction Plan.

38. Work Limits: The outer extents of the Work Area, as marked by the Contractor and approved by the Project Monitor and/or NPS.

VIRGIN ISLANDS NATIONAL PARK - 5SER3346 01 11 00 - 1

SUMMARY OF WORK

CANEEL BAY REMOVAL ACTION – AREA 2 SOIL AND SEDIMENT REMOVAL

VIRGIN ISLANDS NATIONAL PARK - 5SER3346

SECTION 01 11 00 - SUMMARY OF WORK

PART 1 - GENERAL

1.1 SUMMARY

A. Section consists of the scope of the Work, descriptions and figures depicting the areas of the Work, and general requirements.

1.2 WORK COVERED BY CONTRACT DOCUMENTS

A. Project Location: Caneel Bay Resort, in Virgin Islands National Park (VIIS), St. John, United States Virgin Islands (USVI).

B. Capitalized terms are defined in Section 00, Table of Contents and Definitions.

C. The Work Area includes:

1. The Soil Removal Units and Confirmation Sampling Units in Area 2, depicted on Figure 2 (A2-Soil1, A2-Soil2, A2-Soil3, A2-Soil4, A2-SU1, A2-SU2, A2-SU3, and A2-SU4).

2. The concrete/masonry drainage channel, depicted on Figure 3, between the eastern end of Area 2, near the Resort entrance, and its discharge point at the ocean near the dock near Little Caneel Beach, as shown on Figure 3 (A2-Sed1, A2-Sed2, and A2-Sed3).

3. Ancillary support areas, including laydown areas, stockpile areas, access routes, etc.

D. The Work consists of:

1. Construction Plan Preparation, as defined in Section 01 31 00, to include, but not limited to:

a. Identification of key personnel and subcontractors

b. Construction Site Drawings

c. Construction Schedule

d. Decontamination Plan

e. Transportation and Disposal Plan

f. Waste transporter documentation

g. Disposal facility documentation

h. Site-Specific Health and Safety Plan (HASP)

i. Under-an-Acre Pollution Prevention Plan (UPPP)

2. Area 2 Soil Removal:

VIRGIN ISLANDS NATIONAL PARK - 5SER3346 01 11 00 - 2

a. Install, maintain, and remove erosion and sedimentation controls in accordance with an approved UPPP. Erosion and sedimentation controls shall be installed prior to excavation work in a particular area and maintained until that area is stabilized (i.e., revegetated).

b. Establish support areas as required by the Specifications, defined in the approved UPPP, and approved by the Project Monitor and NPS (e.g., stockpile area, decontamination pads, construction exits, etc.).

c. Establish excavation limits. Stake out horizontal extents of excavations for approval by the Project Monitor and establish vertical control necessary to achieve and verify excavation depths.

d. Clear brush and trees, as required, within excavation and support areas. Chip clearing debris and stockpile in areas approved by Project Monitor and NPS.

e. Excavate, stockpile (as necessary), and load surface soil (i.e., 0 to 0.5 feet below ground surface) from Soil Removal Units A2-Soil1, A2-Soil2, A2-Soil3, and A2- Soil4 (total estimated volume of 288 bank cubic yards (BCY)).

f. Keep the excavation open and dry until vertical and horizontal excavation limits are approved by the Project Monitor based on confirmation sampling results. Additional excavation may be required, as directed by the Contracting Officer, based on the results.

g. Transport and dispose excavated soils at an approved facility.

h. Record final excavation extents using, at minimum, a sub-meter Global Positioning

System (GPS) unit.

i. Backfill excavations with Topsoil (0 to 0.5 feet below final grade) from an approved clean fill source. Consolidate with initial placement equipment; compaction equipment is not required for backfill of Topsoil. If excavation below 0.5 feet below ground surface is required, backfill and compact with Common Fill, from an approved clean fill source, to 0.5 feet below final grade.

j. Seed disturbed areas with approved seed mix(es).