Attachment_2__NTCRAWP_for_ACM_at_Caneel_Bay_Resort_USVI.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: Asbestos Abatement by

Removal and Disposal Virgin Islands National Park

Caneel Bay Resort St. John, U.S. Virgin Islands

EDL Number 5SER3346

Prepared by

March 20, 2023

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

Table of Contents List of Tables .................................................................................................................................. ii

List of Appendices ......................................................................................................................... ii

List of Abbreviations and Acronyms .......................................................................................... iii

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. Asbestos Contractor

3. Removal Action Objectives and Removal Goals

3.1. RAOs

3.2. Removal Goals

4. Attainment of ARARs

4.1. NPS Organic Act

4.2. Clean Air Act National Emissions Standards for Asbestos

4.3. Asbestos Model Accreditation Plan

4.4. National Historic Preservation Act

4.5. Endangered Species Act

4.6. Coastal Zone Management Act

5. Abatement Observation, Sampling, and Reporting

6. References

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List of Tables List of Tables in Text

Table 1 Summary of Asbestos-Containing Waste

List of Appendices Appendix 1 – Asbestos Abatement and Disposal Specifications

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List of Abbreviations and Acronyms ACM asbestos-containing material ARAR applicable or relevant and appropriate requirements CBIA CBI Acquisitions, LLC CERCLA Comprehensive Environmental Response, Compensation, and Liability Act EHI EHI Acquisitions, LLC NCP National Oil and Hazardous Substances Pollution Contingency Plan NPS National Park Service NTCRA non time-critical removal action NTCRAWP non time-critical removal action work plan RAO removal action objective RG removal goal RUE Retained Use Estate USVI U.S. Virgin Islands VIC Virgin Islands Code VICZMA Virgin Islands Coastal Zone Management Act VIIS Virgin Islands National Park

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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 work plan (NTCRAWP) will be used to plan and execute the removal of asbestos-containing materials from the Caneel Bay Resort Site (Site). The main body of this plan guides the National Park Service (NPS) manager and Asbestos Project Monitor contracted by NPS. The specifications in Appendix 1 detail the asbestos abatement contractor’s responsibilities.

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 NPS. The Resort closed to overnight visitors in 2017 after Hurricanes Irma and Maria severely damaged many of its buildings. EHI Acquisitions, LLC (EHI) 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, 2022), NPS determined that asbestos-containing debris, from structures damaged by hurricanes Irma and Maria, is present on or above ground at Areas 1 and 2, Caneel Beach, Scott Beach, Hawksnest Beach, and Turtle Bay. Debris may have been displaced by weather or human activities since then, and all locations must be field-verified. Some detached sections of aboveground asbestos-containing pipes are no longer serving their intended purpose and are also considered waste.

NPS concluded that a removal action is needed to meet removal action objectives (RAOs) related to risks to human health and the environment, future constraints on VIIS resources, and compliance with cleanup standards and regulations. This part of the non-time critical removal action (NTCRA) will consist of removing and disposing of Asbestos-Containing Waste, as defined Section 01 10 00 of the Specifications in Appendix 1. This NTCRA will be performed by an asbestos abatement contractor. The Work to be performed by the Contractor is defined in the Specifications in Appendix 1. The Project Monitor, contracted separately by NPS, will provide asbestos inspection, perimeter air sampling, design, and observation services, and conduct a final visual inspection for compliance. The Project Monitor’s responsibilities are defined in Section 02 82 13 “Asbestos Abatement and Disposal” in Appendix 1. Upon completion of the NTCRA, Asbestos-Containing Waste will have been removed from the ground and disposed of at a landfill.

Other parts of the NTCRA, including removal of pesticide-contaminated soil and a former landfill will be completed under separate contracts.

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

NPS is conducting the NTCRA at 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.

This NTCRAWP was prepared by VHB under contract number 140P2121A0026, order number 140P5422F0029.

1.1. Purpose

Hurricane debris has been abandoned on the ground since 2017. Building materials with asbestos mineral concentrations greater than one percent (>1%) by weight are considered asbestos-containing materials (ACM). During the EE/CA Addendum Investigation in November 2021, NPS identified debris and piping containing non-friable asbestos, meaning that it could not be crushed by hand and did not present an immediate risk to human health or the environment. However, the Asbestos-Containing Waste is exposed to wind, rain, and sunlight, which are likely to weather or deteriorate the materials with time, increasing the potential for asbestos fibers to be released to the environment and present an exposure risk. Additionally, destruction, disturbance, or improper handling of the structures or debris piles by untrained or unknowing personnel, visitors, or trespassers may cause a release of asbestos fibers to the air and expose those personnel and others.

The selected removal alternative for Asbestos-Containing Waste, as recommended in the EE/CA, is abatement by removal and disposal. The RAO 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.

Once the RAOs and cleanup goals are met, the ground surface where ACM debris has come to be located will be available for unrestricted use. This scope does not address the ACM currently attached to buildings, some of which is exposed to the environment, or buried below ground.

1.2. Site Description

The Resort has been continuously operated by private businesses since at least 1956. Although the majority of the Resort did not reopen after the 2017 hurricanes, EHI and CBIA continued to operate restaurant and beach tourism services at the Resort pursuant to the RUE, which will expire on September 30, 2023 (National Park Service, 2013).

ACM roof debris resulting from the hurricanes is present mainly in the northern portion of the Resort, at Scott Beach, Hawksnest Beach, and Turtle Bay, as described in Table 1 and labeled on

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

Figure 1 in Section 01 10 00 “Summary of Work” in Appendix 1. The roofing debris has not been secured and may have moved since NPS identified the debris piles in November 2021; locations must be field-verified. ACM pipes that are not attached to buildings are typically partially buried in the ground, and some appear to have been used as protective bollards. To aid in identifying Asbestos-Containing Wastes, representative photographs are included in Table 2.

Table 3 Summary of Asbestos-Containing Waste

Area Material Description & Approximate Quantity

Turtle Bay (Estate Restaurant, Units, Estate House) and Scott Beach Buildings (Units), and

Hawksnest (Units) – See representative photographs below

Roof Material Type II (i.e., asphaltic roofing felt + maximum of 1 inch of soil beneath ACM, if needed. 150 cubic yards

Photograph 1 Scott Beach (sample R03)

Photograph 2 Turtle Bay (sample R05)

Photograph 3 Hawksnest Units roofing (at Scott

Beach) (sample R09)

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

Area Material Description & Approximate Quantity

West of Resort Front Entrance, Wastewater Treatment Area (Area 1), and Area 2 – see representative photographs below

Partially buried or loose sections of Asbestos-cement pipe + maximum of 1 inch of soil beneath ACM, if needed. Multiple ~5 foot sections (10 cubic yards).

Photograph 4 Exposed pipe at Wastewater Treatment Area (sample BP3)

Photograph 5 Exposed pipe at Maintenance/Pottery Area (sample BP5)

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 https://go.nps.gov/CaneelBay. 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.

The U.S. Environmental Protection Agency and USVI Department of Planning and Natural Resources (DPNR) must be notified at least 10 days in advance of asbestos abatement work.

USVI DPNR issues hazardous waste generator permits and approves hazardous waste transportation applications.

https://go.nps.gov/CaneelBay

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

2. Project Organization and Responsibilities

2.1. NPS

NPS is the lead CERCLA response agency and will conduct 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, Asbestos Contractor, Resort Operator, and USVI DPNR.

2.2. Project Monitor

The Project Monitor, contracted by NPS, shall provide asbestos inspection, perimeter air sampling, design, and observation services; conduct a final visual inspection for compliance; and prepare the completion report. The Project Monitor shall maintain communication with NPS. The Project Monitor must be present during asbestos disturbing work. Responsibilities are detailed in Section 02 82 13 “Asbestos Abatement and Disposal” in Appendix 1.

2.3. Asbestos Contractor

The Asbestos Contractor, contracted by NPS, shall conduct the asbestos abatement by removal and disposal detailed in Appendix 1.

3. Removal Action Objectives and Removal Goals NPS used the data collected during the EE/CA field investigation to decide if removal actions were needed to address unacceptable risks and, if warranted, identify and evaluate RAOs. NPS chose to remove ACM debris that could pose future risks to receptors.

The RAOs describe what is to be achieved to protect human health and the environment under current and reasonably anticipated future land use scenarios. Correspondingly, cleanup goals are the numerical concentrations, expressed as removal goals (RGs) required to achieve the RAO for each contaminant of concern (COC). For this removal action, asbestos is the only COC.

3.1. RAOs

The RAOs for this project are:

• Eliminate unacceptable risks to human health and the environment (represented by exceedance of the RG concentrations), specifically through removal and off-site disposal of Asbestos-Containing Waste

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

• 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 4.1, below.

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

3.2. Removal Goals

The RG for ACM debris is 1% asbestos by weight in building materials.

4. Attainment of ARARs 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 a permit for hazardous waste generation because asbestos is a hazardous waste under USVI regulations. Territorial regulations and substantive requirements that would be contained in a permit will be addressed and adhered to during NTCRA activities as detailed in this Work Plan and the specifications attached as Appendix 1.

4.1. 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 nonimpairment mandate because it will remove an uncontrolled source of asbestos fibers that is currently impairing the use and enjoyment of VIIS. Moreover, as described in specifications attached in Appendix 1, steps will be taken to prevent damage to natural and cultural resources during implementation of the Work. See, e.g., Section 01 10 00 “Summary of Work.”

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

4.2. Clean Air Act National Emissions Standards for Asbestos

The National Emissions Standards for Hazardous Air Pollutants (NESHAP) and implementing regulations, set forth at 42 U.S.C. §§ 7401, 7412, 7414, 7416, 7601 and 40 C.F.R. Part 61, Subpart M, respectively, specify “work practices for asbestos to be followed during demolitions and renovations of all structures, installations, and buildings (excluding residential buildings that have four or fewer dwelling units). The regulations require the owner of the building or the operator to notify the appropriate state agency before any demolition, or before any renovations of buildings that could contain a certain threshold amount of asbestos or asbestos-containing material.” (U.S. Environmental Protection Agency, 2021b). These regulations also require the owner or operator to take certain steps to minimize emissions of asbestos fibers to outside air during demolition or renovation activities including packaging or transporting of any asbestos-containing waste. The asbestos NESHAP requirements are relevant and appropriate for response activities that involve contact with asbestos-containing material but do not constitute demolition or renovation. The asbestos NESHAP requirements are incorporated by reference in Section 01 42 00 of the specifications attached in Appendix 1.

4.3. Asbestos Model Accreditation Plan

The Asbestos Model Accreditation Plan, Appendix C to 40 CFR Part 763, Subpart E, provides training requirements for asbestos professionals (including any worker, contractor, supervisor, inspector, management planner or project designer) working with asbestos-containing building materials in a school, public, or commercial building. The Asbestos Model Accreditation Plan is relevant and appropriate for response activities that involve contact with asbestos-containing material not found in public or commercial buildings. The Asbestos Model Accreditation Plan is incorporated by reference in Section 01 42 00 of the specifications attached in Appendix 1.

4.4. 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. Soil disturbance will be limited to the surface soil less than 1 inch deep. Therefore, the project is unlikely to have adverse effects on historic structures, cultural landscapes, or archaeological sites.

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 Section 01 10 00 “Summary of Work”, the Contractor must take precautions to avoid damaging heritage trees and plants.

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

4.5. Endangered Species Act

For National Priorities List (NPL) scoring purposes, all National Parks, including VIIS, are considered “sensitive environments.”

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

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 within the Site. The Work is not anticipated to adversely impact endangered species or habitats located within the Site.

There is no evidence that an asbestos release is impacting sensitive environments other than, potentially, VIIS.

4.6. Coastal Zone Management Act

The USVI 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), Title 12 Chapter 21 of the Virgin Islands Code (VIC). The Resort is mapped within the Tier One Coastal Zone (CZM@STT_PM, 2021). Some of the activities to be performed may be included in the definition of “development1”, including removal or demolition of any structure. Primary coastal zone concerns for this work are to prevent ACM from migrating to the ocean in nearby Salomon Bay and Caneel Bay. Dust and asbestos air monitoring will be conducted to evaluate the potential for asbestos fibers to be released, and mitigation measures

1 § 902 subsection I of the VICZMA states: “‘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, including mineral resources; subdivision of land pursuant to Title 29, chapter 3 of this Code;

construction, reconstruction, removal, demolition or alteration of the size of any structure; or removal or harvesting of vegetation, including coral. Development shall not be defined or interpreted to include activities related to or undertaken in conjunction with the cultivation, use or subdivision of land for agricultural purposes which do not disturb the coastal waters or sea, or any improvement made in the interior of any structure.”

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Caneel Bay Resort Site NTCRA National Park Service Virgin Islands National Park U.S. Department of the Interior will be employed if necessary. Because the work is being performed is a CERCLA action, a CZM permit will not be required. However, the substantiative requirements detailed in 12 VIC sections 903, 906, and 910 will be satisfied.

5. Abatement Observation, Sampling, and Reporting The specifications in Appendix 1 detail the preparation, abatement, access, air sampling, decontamination, reporting and other requirements of the Work.

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6. 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. (2022). Draft 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. Environmental Protection Agency. (2021b). Information for Owners and Managers of Buildings that Contain Asbestos. Retrieved from U.S. Environmental Protection Agency:

https://www.epa.gov/asbestos/information-owners-and-managers-buildings-contain-asbestos#renovations

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.

Virgin Islands Rules and Regulations. 2014 (May 6). Title 12, Chapter 16, Underground Storage Tanks. (n.d.).

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

Appendix 1 – Asbestos Abatement Specifications

VIIS - 5SER3346 TOC AND DEFINITIONS - 1

ASBESTOS

CANEEL BAY REMOVAL ACTION – ASBESTOS

VIRGIN ISLANDS NATIONAL PARK - 5SER3346

TABLE OF CONTENTS (TOC)

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

Division 2

02 82 13 Asbestos Abatement and Disposal

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. Abatement: Procedures physically taken to control or eliminate fiber release from Asbestos-containing materials (ACM). This includes removal, encapsulation, enclosure, and repair.

2. AIHA: American Industrial Hygiene Association.

3. Airlock: System for permitting entrance and exit while restricting air movement between a contaminated area and an uncontaminated area. It consists of two Curtained Doorways separated by a distance of at least three feet such that one passes through one (1) doorway into the Airlock, allowing the doorway sheeting to overlap and close off the opening before proceeding through the second doorway, thereby preventing flow-through contamination.

4. Air Sampling: Process of measuring the fiber content of a known volume of air collected during a specific period. The procedure utilized for Asbestos follows the NIOSH Standard Analytical Method 7400, or the provisional transmission electron microscopy methods

VIIS - 5SER3346 TOC AND DEFINITIONS - 2

developed by the US EPA, which are utilized for lower detection levels and specific fiber identification.

5. Air Sample: An Asbestos air sample collected by Air Sampling.

6. Amended Water: Water to which a chemical wetting agent that improves penetration (i.e., a surfactant) has been added.

7. ANSI: American National Standards Institute.

8. Asbestos: Any hydrated mineral silicate separable into commercially usable fibers, including but not limited to chrysotile (serpentine), amosite (cummingtonite-grunerite), crocidolite (riebeckite), tremolite, anthophyllite and actinolite.

9. Asbestos-Containing Material (ACM): Asbestos or any material containing more than one-percent Asbestos.

10. Asbestos-Containing Waste: Designated ACM Debris and disconnected ACM piping, and a maximum lift of 1 inch of surface soil if it contains ACM pieces too small to remove by hand.

11. Authorized Visitor: NPS Contracting Officer (CO) and his/her representatives, and any representative of a regulatory or other agency having jurisdiction over the project. An Authorized Visitor must have appropriate asbestos training and certification to enter a Work Area, and must enter and exit through the Decontamination Unit if Asbestos- Containing Waste is present.

12. Clean Room: An uncontaminated area or room that is part of a worker Decontamination Unit with provisions for storage of workers’ street clothes and protective equipment.

13. Contractor: The hazardous material removal contractor licensed to remove Asbestos.

14. Curtained Doorway: Device that consists of at least three overlapping sheets of polyethylene over an existing or temporarily framed doorway. One (1) sheet shall be secured at the top and left side, the second sheet at the top and right side, and the third sheet at the top and left side. All sheets shall have weights attached to the bottom to ensure that the sheets hang straight and maintain a seal over the doorway when not in use.

15. Debris: Detached building materials present on the ground.

16. Decontamination Unit: Series of connected rooms, separated from the Work Area and from each other by Air Locks, for the decontamination of workers, materials, waste containers, and equipment.

17. DPNR: Department of Planning and Natural Resources.

18. Employee: An Asbestos Abatement worker who disturbs, removes, repairs, or encloses

Asbestos-Containing Waste. This individual shall have completed approved training course(s) and be in possession of applicable local license(s).

19. Employee Exposure Air Sampling: Method used to determine Employees’ exposure to airborne fibers. The sample is collected outside the respirator in the worker’s breathing zone.

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

21. Equipment Room: Contaminated area or room that is part of the worker Decontamination

Unit with provisions for the storage of contaminated clothing and equipment.

22. Friable Asbestos Material: Asbestos or any ACM that can be crumbled, pulverized, or reduced to powder when dry, by hand or other mechanical pressure.

23. HEPA-Filter: High efficiency particulate air filter capable of trapping and retaining 99.97 percent of particles (Asbestos fibers) greater than 0.3 micrometers mass median aerodynamic equivalent diameter.

24. HEPA Vacuum: A vacuum cleaner equipped with a HEPA-Filter.

25. Licensed Asbestos Supervisor: Individual who supervises the Employees during Asbestos-

Containing Waste disturbing activities and ensures that proper Asbestos abatement procedures as well as individual safety procedures are being adhered to. This individual shall have completed approved training course(s) and be in possession of applicable local

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license(s).

26. NESHAPS: National Emission Standards for Hazardous Air Pollutants.

27. NIOSH: National Institute for Occupational Safety and Health.

28. NPS: National Park Service.

29. OSHA: Occupational Safety and Health Administration.

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

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

32. Project Monitor: The firm, hired by the NPS, to provide Asbestos inspection, perimeter Air

Sampling, design, and oversight services, and to conduct final visual inspection for compliance.

33. Resort: Caneel Bay Resort

34. Separation Barrier: A constructed wall with no door that separates the clean area of the

Work Site from the contaminated Work Area and does not interfere with the means of egress. Polyethylene sheeting (minimum two (2) layers, 6-mil thick) shall be placed on the Work Area side of the barrier so that it completely seals off the Work Area to prevent the distribution of fibers to the surrounding area. Danger signs and barrier tape shall be used to block other entrances to the Work Area.

35. Shower Room: Room between the Clean Room and the Equipment Room in the worker Decontamination Unit with hot and cold running water controllable at the tap and arranged for complete showering during decontamination.

36. USVI: United States Virgin Islands.

37. VIIS: Virgin Islands National Park.

38. Wet Cleaning: Removal of Asbestos fibers from surfaces and objects by using cloths, mops, or other cleaning tools which have been dampened with amended water.

39. Work:

a. The Abatement by removal and disposal of Asbestos-Containing Waste from Caneel Bay Resort.

b. Employee Exposure Air Sampling during Abatement by removal activities.

c. Controlling dust and asbestos fibers during Asbestos-Containing Waste handling and loading activities.

d. Transportation and disposal of Asbestos-Containing Waste at a landfill approved to accept Asbestos waste.

40. Work Area: Designated spaces or areas of the site where Asbestos abatement activities take(s) place.

41. Work Site: Premises where abatement activity is being performed. May be composed of one (1) or more Work Areas.

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SUMMARY OF WORK

CANEEL BAY REMOVAL ACTION – ASBESTOS

VIRGIN ISLANDS NATIONAL PARK - 5SER3346

SECTION 01 11 00 - SUMMARY OF WORK

PART 1 - GENERAL

1.1 SUMMARY

A. Section includes the following:

1. Work Covered by Contract Documents

2. Work Phases

3. Work Under Other Contracts

4. Government-Furnished Materials

5. Contractor Use of Site

6. Public Use of Site

7. Conduct of Operations

8. Work Restrictions

9. Engineering Evaluation/Cost Analysis Report

10. Figure 1 Asbestos-Containing Waste Locations

1.2 WORK COVERED BY CONTRACT DOCUMENTS

A. Project Location: Caneel Bay Resort, in the 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 consists of:

1. The Abatement by removal and disposal of Asbestos-Containing Waste from Caneel Bay

Resort. The Asbestos-Containing Waste identified by the National Park Service (NPS) is summarized in Table 1 below. The total quantity of Asbestos-Containing Waste is ap-proximately 160 cubic yards. The Asbestos-Containing Waste identified at the Resort was classified as non-friable as of the date of the Engineering Evaluation/Cost Analysis Addendum investigation (November 2021). Approximate locations of Asbestos-Contain-ing Waste as identified in November 2021 are shown on Figure 1, at the end of this Sec-tion.

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

TABLE 1 - ASBESTOS CONTAINING WASTE

Location(s) Material Description Estimated Quantity

Turtle Bay (Estate Restaurant, Units, Estate House) and Scott Beach Buildings (Units), and Hawksnest Beach Buildings

(Units)

Roof Material Type II (i.e., asphaltic roofing felt + maximum of 1 inch of soil beneath the Asbestos-Containing

Waste, if needed

150 cubic yards

West of Resort Front Entrance, Wastewater Treatment Area

(Area 1), and Area 2

Partially buried or loose pipe sections of Asbestos-cement pipe

Multiple ~5-foot sec-tions (10 cubic yards)

2. Employee Exposure Air Sampling during Abatement by removal activities.

3. Controlling dust and Asbestos fibers during Asbestos-Containing Waste handling and loading activities. (Perimeter air monitoring will be conducted separately by the Project Monitor contracted directly by NPS.)

4. Transportation and disposal of Asbestos-Containing Waste at a landfill approved to ac-cept Asbestos waste.

D. Project will be conducted under a single prime contract.

1.3 WORK UNDER OTHER CONTRACTS

A. General: Other contractors may be present at the Resort for construction or operations. Cooperate with separate contractors so work on contracts may be carried out smoothly, without interfering with or delaying work under this Contract. Coordinate Work performed under this Contract with work performed under separate contracts.

B. Concurrent work: Government will award separate contract(s) for the following operations at the Work Site. Those operations will be conducted simultaneously with work under this Contract.

1. Project Monitor: A separate contract will be awarded to a third-party for initial and final inspections, Abatement operations observation, and perimeter air monitoring for Asbestos and dust during Contractor Asbestos Abatement by removal.

1.4 CONTRACTOR USE OF SITE

A. General: Contractor shall have limited use of the Resort for Work operations. Limit use of premises to the areas listed in Table 1. Do not disturb portions of Resort beyond areas in which the Work is indicated.

1. Limits: Confine Asbestos Abatement and decontamination operations to a 50-foot radius of the perimeter of the Work Area.

2. Access: There will be no unauthorized persons allowed in the Work Areas during this project. Access to the Work Areas shall be restricted to the Contractor, Project Monitor, and authorized visitors. Provide danger signs and barrier tape at all approaches to Asbestos Work Areas.

3. Resort Operations: The Contractor shall not interfere with daily activities within the remainder of the Resort or otherwise affect daily operations. Issues concerning Work

VIRGIN ISLANDS NATIONAL PARK - 5SER3346 01 11 00 - 3

Area access shall be communicated to NPS, who will coordinate with the Caneel Bay Resort operator.

4. Decontamination Unit: The Contractor shall construct a remote Decontamination Unit that will be used as the entry and exit for each Work Area, as detailed in Section 02 82 13 “Asbestos Abatement and Disposal”.

B. Storage of Materials: Confine storage of materials to areas designated by NPS during the pre-construction conference.

C. Parking: Confine parking to areas designated by NPS during the pre-construction conference. Do not block Resort roads.

D. Asbestos-Containing Waste storage: The Asbestos-Containing Waste from the Work Area shall be collected, packed, and sealed into labeled 6-mil plastic bags prior to starting the next section to prevent the material from drying. Removed material shall not be left out of bags overnight or for more than four hours. Bags and drums of Asbestos-Containing Waste shall be staged within the Work Area or loaded directly into a shipping container. Shipping containers shall be closed to prevent entry.

E. Preservation of Natural Features and Cultural Resources:

1. Prevent damage to natural surroundings. Restore damaged areas, repairing or replacing damaged trees and plants outside Work Areas, at no additional expense to the Government.

2. Provide temporary barriers to protect existing trees, plants, and root zones and cultural resources identified by NPS inside and outside Work Areas. NPS will identify heritage trees and plants during the initial walk through and on a map.

3. Do not remove, injure, or destroy trees or other plants without prior approval. Consult with Contracting Officer (CO) and remove agreed on roots and branches that interfere with the Work.

4. Do not fasten ropes, cables, or guys to existing trees outside Work Areas or to heritage trees and plants inside Work Areas.

5. Carefully supervise trucking, equipment moving, and other construction operations near trees and cultural resources identified by NPS outside Work Areas to prevent damage.

F. Driveways and Entrances: Keep driveways, Resort roads, and entrances serving the Resort clear and available to Resort and Government employees and emergency vehicles at all times. Do not use for parking or storage of materials.

1. Schedule trucks and/or shipments to minimize use of driveways and entrances.

2. Schedule deliveries to minimize space and time requirements for storage of materials and equipment on-site.

G. Construction Camp: Establishment of a camp within park and Resort will not be permitted.

H. Hauling Restrictions: Comply with legal load restrictions in hauling of materials. Load restrictions on park roads are identical to Territory and State load restrictions with such additional regulations as may be imposed by the Park Superintendent. Information regarding rules and regulations for vehicular traffic on park roads may be obtained from the Office of the Park Superintendent. A special permit will not relieve Contractor of liability for damage which may result from moving of equipment.

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1.5 PUBLIC USE OF SITE

A. Contractor shall conduct operations to ensure the least inconvenience to public. Resort road closures may be permitted, when required, if there is no other way to prevent public access to the Work Area during the Work.

B. No unauthorized visitors are allowed in a Work Area while Abatement activities are occurring.

1.6 OCCUPANCY REQUIREMENTS FOR BUILDINGS

A. Existing Buildings

1. Partial Resort Occupancy: A Resort operator or the Government may occupy premises at the Resort during entire construction period, with exception of Work Areas. Cooperate with Resort operators and Government during the Work to minimize conflicts and facilitate usage. Perform Work so as not to interfere with Resort or other contractor operations. Maintain existing exits from buildings, unless they permit uncontrolled access to the Work Area.

a. Maintain access to existing walkways, corridors, and other adjacent occupied or used facilities outside the Work Area. Do not close or obstruct walkways, corridors, or other occupied or used facilities without written permission from Contracting Officer.

1.7 CONDUCT OF OPERATIONS

A. Contractor shall conduct operations in conformance with rules and regulations promulgated by the Secretary of the Interior for the National Park Service, and applicable Virgin Islands National Park (VIIS) rules and regulations prescribed by Park Superintendent. The current compendium is here (Compendium - Virgin Islands National Park (U.S. National Park Service) (nps.gov) https://www.nps.gov/viis/learn/management/compendium.htm).

B. Work may not be performed on Federal holidays or at night.

C. No signs or advertisements (except those specified herein) shall be displayed at the Resort or within VIIS unless approved by the Contracting Officer.

1.8 WORK RESTRICTIONS

A. On-Site Work Hours: Work shall be generally performed during the hours of 7:00 a.m. to 5:00 p.m.

B. Existing Utilities

1. Existing Utilities: Excavation of soil is not to exceed 1 inch below existing ground surface without prior approval of the Contracting Officer. If utilities are observed within 1 inch of ground surface, notify the Contracting Officer before proceeding with excavation.

2. Contractor shall be responsible for locating and preventing damage to known utilities. If damage occurs, repair utility at no additional expense to the Government.

https://www.nps.gov/viis/learn/management/compendium.htm https://www.nps.gov/viis/learn/management/compendium.htm

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

3. If damage occurs to an unknown utility, notify the Contracting Office, who may direct repair of the utility.

1.9 ENGINEERING EVALUATION/COST ANALYSIS REPORT

A. The Engineering Evaluation/Cost Analysis Addendum Report, prepared by VHB, details the Asbestos investigation results and is available for download at https://parkplanning.nps.gov/documentsList.cfm?parkID=412&projectID=100132.

B. In case of conflict between the text of the Engineering Evaluation/Cost Analysis Addendum Report and drawings or specifications herein, the drawings and specifications govern.

PART 2 - PRODUCTS (Not Used)

PART 3 - EXECUTION (Not Used) https://parkplanning.nps.gov/documentsList.cfm?parkID=412&projectID=100132

VIRGIN ISLANDS NATIONAL PARK - 5SER3346 01 11 00 - 6

Figure 1 Asbestos-Containing Waste Locations

VIRGIN ISLANDS NATIONAL PARK - 5SER3346 01 11 00 - 7

END OF SECTION 01 11 00

VIIS - 5SER3346 01 26 01 - 1

CONTRACT MODIFICATION PROCEDURES

CANEEL BAY REMOVAL ACTION – ASBESTOS

VIRGIN ISLANDS NATIONAL PARK - 5SER3346

SECTION 01 26 01 – CONTRACT MODIFICATION PROCEDURES

PART 1 - GENERAL

1.1 SUMMARY

A. Section consists of administrative and procedural requirements for contract modifications.

1.2 DEFINITIONS AND ALLOWANCES

A. Home Office Overhead: Costs incurred in support of all of a contractor’s projects and not attributable to a specific job. The cost for home office overhead is only allowed as a percentage of all direct work excluding profit. The following items represent allowable home office overhead costs identified in Part 31 of the Federal Acquisition Regulation (FAR):

1. Rent

2. Utilities

3. Furnishings

4. Office equipment

5. Executive and management staff not exclusively assigned to the project

6. Support, accounting, and administrative staff

7. Preparation of cost proposals, estimating, and schedule analyses connected with

Modifications

8. Estimating and pre-Work services

9. Mortgage costs

10. Real estate and corporate taxes

11. Automobile maintenance and travel costs for home office personnel

12. Home office insurances i.e. structure, automotive, umbrella, flood, etc.

13. Depreciation of equipment and other assets

14. Home office supplies (paper, staples, etc.)

15. Legal services

16. Accounting and data processing

17. Professional fees/registration

B. General Conditions (Field Office Overhead): Management and administrative costs incurred on site for the designated project. Costs associated with preparation of modifications will not be allowed. Costs for these items are to be included only in the general conditions of the modification estimate. Only in the case of a contract time extension are additional general conditions included in modifications. The following items, if applicable, are considered allowable costs for calculating General Conditions:

1. Project Manager (PM), Assistant Project Manager

VIIS - 5SER3346 01 26 01 - 2

2. Superintendent, Assistant Superintendent

3. Licensed Asbestos Supervisor

4. Quality Control, Safety Officer, Environmental Manager, etc.

5. Asbestos Employees

6. Travel, lodging, and per diem (as established by Federal Travel Regulations)

7. Scheduling

8. Field Office Trailers and associated temporary utilities

9. Field office supplies

a. Mailing and couriers

b. Reproduction costs

c. Storage

d. Phones

e. Computers

f. Copiers

10. Personal vehicles i.e. Superintendent Pickup trucks

C. General Requirements: Costs directly associated with the project and necessary to perform the actual work of the modification. These costs shall be shown as direct costs in the estimate. The following items, if applicable, are considered allowable costs for calculating General Requirements:

1. Material handling

2. Temporary fencing

3. Port-a-lets

4. Trash removal, dumpsters

5. Barricades

6. Small tools

7. Safety supplies

8. Daily cleaning

9. Traffic control

10. Temporary signage

11. Temporary heating and power

12. Decontamination facilities

D. Personnel Costs: Costs included in the modification must only be for General Conditions staff and workers actually present and working on project site. Modification costs for salaried workers are only allowed within the structure of a 40-hour week and no overtime or holiday pay will be allowed.

1. Worker Hourly Rates are costs directly associated with the individual worker and consist of the following:

a. Base Rate: The hourly rate paid directly to the worker

b. Labor Burden: Employer payments of all applicable burdens; includes insurance and taxes the business must pay on behalf of the worker to government entities and educational forums, such as:

1) Social Security

2) Medicare

3) Workers Compensation – Policy and company calculation to be made available.

VIIS - 5SER3346 01 26 01 - 3

4) Federal Unemployment Tax Act (FUTA) - Cap Rate and percentage to be proportionally allocated over one year.

5) State Unemployment Tax Act (SUTA) - Cap Rate and percentage to be proportionally allocated over one year.

6) Union agreement costs - Other costs required under an enforceable collective bargaining agreement.

c. Fringe Benefits: Various non-wage compensations provided to employees such as:

1) Health Care Insurance Premiums

2) Cell Phone

3) Clothing

4) 401K and Pensions

5) Vehicle allowances

6) Gas allowance

7) Life insurance premiums

8) Disability insurance

9) Other Fringe Benefits required under an enforceable collective bargaining agreement

E. Bonuses or Deferred Compensation: No Bonus or Deferred Compensation will be allowed within any components of pricing including Home Office Overhead, General Conditions, General Requirements, Hourly Worker Rates, or the direct costs of work.

F. General Liability Insurance: An insurance policy that protects Contractor from claims resulting from bodily injury or property damage to a third party. Include as a separate line item within all modification proposals and provide a current insurance quote upon request.

G. Performance and Payment Bonds: A performance bond is a surety bond issued by an insurance company or bank to guarantee satisfactory completion of a project. The Payment Bond guarantees the Contractor will pay the labor and material costs incurred. Banks and Insurance companies charge a premium for individual project based on a sliding scale related to the size of the project.

Include as a separate line item in modification proposals and provide current company bonding rates upon request.

H. Builder’s Risk Insurance: Covers the contractor’s loss due to fire, high winds, or other natural forces. Not reimbursed by the National Park Service (NPS) and shall not be included in modification proposals.

1.3 MODIFICATION PROPOSAL PRICING REQUIREMENTS

A. General:

1. Proposal shall be received in the format and within the time frame specified in the Request for Proposal (RFP) letter. Costs or delays resulting from failure of contractor to submit within the time frame specified will not be compensable.

2. Proposal shall be detailed with itemized lists of equipment, materials, labor, production rates, overhead, profit, and bond markup for each item. Labor costs must be itemized by craft and hourly rate, including Fringe Benefits and Labor Burden. If the costs of Fringe Benefits and Labor Burden are not itemized, it is assumed they are included in http://en.wikipedia.org/wiki/Employee http://en.wikipedia.org/wiki/Surety_bond http://en.wikipedia.org/wiki/Insurance http://en.wikipedia.org/wiki/Bank

VIIS - 5SER3346 01 26 01 - 4

the hourly rate shown, or contractor is not requesting reimbursement. Contractor may utilize the government provided Contractor Estimate Form, or their own form, provided that it contains the same information and level of detail as the Government’s form.

3. Requests for extensions of contract time as a result of change must be justified with a Time Impact Analysis (TIA). TIA and associated costs shall be received with the proposal by the date shown within the Request for Proposal letter. Contractor’s failure to submit within the specified time frame will be construed as the Contractor waiving right for additional time and no time extension will be allowed.

4. All supporting documentation used to justify the proposed modification will be made available to the Contracting Officer (CO) upon request.

5. Contractor shall review and approve all subcontractor/supplier pricing in detail for proper format, scope, production rates, and pricing prior to submission to NPS. All delay costs associated with not reviewing and approving subcontractor/supplier pricing will be borne by the Contractor.

6. All pricing and production rates within the estimate must be based on fair and reasonable pricing and cannot include built-in contingency.

B. Labor:

1. Contractor…