Contractor_Monitoring_SOP_2022_(1).pdf

Contractor Monitoring

SUBJECT AREA :

Safety and Security

DISTRIBUTION:

Park Wide

EFFECTIVE DATE:

05/2022

AMENDS:

New

RESCINDS:

All Previous

NO. PAGES:

DURATION:

Permanent

PREPARED BY: Kayla Sanders __ Chief Ranger PREPARED BY: Beth Miller Cultural Resources

APPROVED BY: _Timothy Stauffer_________________ Chief of Maintenance APPROVED BY: Michelle Mihalkovitz Chief of Cultural Resources APPROVED BY: Michael Shaver Chief of Interpretation (Acting Chief)

APPROVED BY: _Thomas Ross__________________ Superintendent

I.Purpose

This procedure outlines rules and guidance for monitoring contractors at Thomas Edison NHP.

The intent is to provide safety and security for all park staff, visitors, park resources, and contractors. Every project, scheduled maintenance, and routine inspection need follow the same daily routines to ensure guidelines are met.

II.Authority

The regulations contained in 36 CFR, Parts 1-7, are the basic mechanism used by the National

Park Service (NPS) to preserve and protect the natural and cultural resources of the park and to protect visitors and property within the park. Parts I through 6 are general regulations applicable to all areas of the National Park System, and Part 7 contains special regulations specific to individual parks

The National Park Service (NPS) is granted broad statutory authority under 54 United States

Code (U.S.C.) Section 100101 et.seq. (Omnibus Public Land Management Act of 2009, SOP

2022-1

2013-05

Thomas Edison National Historical Park

Division of Visitor & Resource Protection previously Organic Act of 1916, as amended to regulate the use of the Federal areas known as national parks, monuments, and reservations. by such means and measures as conform to the fundamental purposes of the said parks: “which purpose is to conserve the scenery and the natural and historic objects and the wildlife therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment for future generations" (54 USC Section 100101(a)). In addition, the NPS Organic Act allows the NPS, through the Secretary of the Interior, to "make and publish such rules and regulations as he may deem necessary or proper for the use and management of the parks, monuments, and reservations under the jurisdiction of the National Park Service" (54 USC Section 100751)

A person who violates any provision of the regulations found in 36 CFR, Parts 1-7, or provisions of this Compendium, is subject to a fine as provided by law (18 USC 3571) up to $5000 for individuals and $10000 for organizations, or by imprisonment not exceeding six months (18

USC 3559), or both, and shall be adjudged to pay all court costs associated with any court proceedings

III. Physical Security

The National Park Service is charged with the protection of structures, landscapes, and objects in its care. The historical buildings of the Thomas Edison National Historical Park are secure facilities. As part of the park’s physical and museum security plans, the following pertains to all contractors, such as but not limited to, electricians, plumbers, PSE & G employees, alarm technicians, conservators, historic structure preservation crafts persons, their presence, and work onsite.

- Pre-work meeting(s) will identify the location and number of spaces available to access for contractors and their teams before the start of the project and change due to the course and completion of the work, maintenance, access, safety, or security issues.

- Backpacks, bags, boxes, tool cases, and other conveyances are subject to inspection at any time.

- A roster of all contractor staff is required.

- Contractors and their team may be required to wear identification badges while on-site, logging in and out by name and time, and provide names of all parties working for them or with them. Additional requests must be made in advance for subcontractors and/or suppliers slated to make on-site deliveries.

- Contractors and their teams shall be physically escorted by NPS staff from the entrance of park property to the project location. Access to additional areas will be directly communicated with assigned NPS staff to arrange further escort. An NPS staff member will be assigned to monitor contractors at all times. Assigned NPS staff are responsible for the security of the structure, artifacts, and furnishings within the workspace. Assigned NPS staff also serve as point of contact (POC) for the duration of their assignment, coordinating directly with contractors and the project manager for additional needs (ie.

relief, breaks, supply/equipment deliveries etc.). There should be no anticipation or expectation of privacy in secure facilities. Contractors shall not work independently in any park buildings. An NPS staff member will continually be present, in the immediate vicinity, during all phases of the contractor’s on-site work.

IV. Guidelines for Contractors

1. Contractors are expected to adhere to the designated working hours/days as depicted in the contractual agreement. NPS monitoring staff cannot authorize extra hours or deviate from the contractual agreement without an official amendment by the COR. Please review daily work plans with monitoring NPS staff members.

2. Food, beverages, and gum chewing are not permitted in historic buildings; Debris and staining left behind can permanently damage museum objects. Smoking is not permitted.

3. Museum objects are extremely delicate and fragile. Contractors are not permitted to touch, shift, move, or utilize for functional use any object(s). Contractors shall notify NPS staff to coordinate relocating park owned equipment, objects, historical artifacts, personnel items etc. for the purpose of contractual work. Do not use historic sinks, bathrooms, ladders, chairs, or tables. Do not set up equipment near fragile objects.

4. Any alteration to a historic structure such as a hole, insertion of a nail or bracket, an alteration of a trim or surface, etc. must first be approved by the NPS and COR to ensure compliance with the National Historic Preservation Act.

5. Protective barriers must be used between contractor equipment and museum surfaces.

Clean blankets, covers, and/or plastic must protect the historic artifacts and/or interiors from damage such as but not limited to scratching, dents, liquid spills etc. Surfaces of museum objects shall not be used for storing or staging tools, equipment, or personal items. Protective barriers in doorways or on floor surfaces must be utilized to protect plaster or when work is known to produce dust to prevent particles from intruding into non-work areas.

6. Do not block doorways or emergency exits with equipment or supplies. Contractors may be requested to use designated access/egress points to enter or exit an area or building to accommodate daily staff access and/or public tour access.

7. No open flames. Any equipment emitting heat or creating a spark including but not limited to heat guns, stripping guns, electrical drying tools, heaters, tack irons, welding torches etc. requires ADVANCED PERMISSION from the NPS. Procedures for hot work are strictly enforced. Any hot work requires documentation (provided by NPS) submitted to NPS Visitor and Resource Protection (VRP) for approval and signature. Additionally, hot work occurring near a fire detector or sprinkler pipe that generates heat, dust and/or debris requires advanced NPS VRP notice to prevent accidental activation. (SEE attachment II. “Hot Work-Fire Watch”)

8. Chemicals and other flammable materials, such as but not limited to, those containing butane or alcohol, shall not be left overnight in historic buildings and must be stored in a designated safety zone during work hours. MSDS sheets are required for all on-site chemicals and require review by NPS staff. A physical copy of all MSDS sheets must remain with onsite chemicals at all times. Rags must be stored in regulation non-combustible fire canisters. Unless advanced arrangements are made, trash must be removed at the end of each workday.

9. Electrical service is limited in historic buildings. Arrangements must be made in advance to use electrical equipment. Electrical equipment must be in satisfactory shape; do not use frayed or damaged extension cords. Do not leave construction lights or equipment on or plugged in while unattended.

10. Contractors and their teams shall immediately alert their direct supervisor and NPS staff of any injuries or safety issues that arise during the workday.

11. NPS monitors shall not physically assist nor perform errands for contractors. Other than the COR, NPS monitors shall not direct contractual work. Contractors are responsible for providing and maintaining their own supplies and equipment. NPS staff are not permitted to assist contactors with loading or unloading of supplies/equipment, clean-up, or provide NPS equipment for the contractor’s use.

12. Contractors should be aware of fire extinguisher locations in the working area and know evacuation routes to include emergency exits. In the case of an emergency or alarm, evacuate the area, call 911, and follow further directions from NPS staff.

13. On-site parking is limited. Consult the NPS for guidelines. Overnight parking may be requested and must be approved by VRP Rangers.

14. Contractors should be easily identifiable by NPS staff with company logo attire, visible ID badges etc. Contractors with or without visible IDS may be issued NPS EDIS Contractor badges.

15. For security and safety, Contractors are not permitted to invite friends or family to the worksite. Animals are not permitted on the worksite. Service animals are permitted at the park. Subcontracting is not permitted unless otherwise specified in the contractual agreement or by the COR.

16. Contractors must coordinate any deliveries of equipment or supplies to the worksite with NPS staff and the COR. Contractors must be present during all deliveries for inspection and transport. NPS staff are not responsible for deliveries and are not permitted to sign for any supplies or equipment unless depicted in the contractual agreement or directed by the COR.

17. Contractors are required to adhere to any implemented health and safety guidelines by the CDC or by the state of New Jersey.

V. Roles and Responsibilities of Park Staff

Daily Start-up Procedures

1. Prior to work beginning, coordinate with VRP to place fire alarms in “test” when necessary, especially if there is any work that might produce dust. When systems are in test, the fire suppression system will engage in the event of a fire, but the fire department will not dispatch. Be sure to call 911 if there is an emergency.

2. Smoke detectors should be covered if there is any work which may produce large amounts of dust, as this could cause the detectors to malfunction. Covering the detectors requires NPS monitors to be on site at all times for fire watch. VRP Rangers need to be notified when detectors are covered. Knowing when to cover detectors is determined in the project planning phase and should also be noted in morning briefings with the contractor, prior to any work taking place. Maintenance Rangers should be consulted to assist with covering the detectors unless otherwise noted in the contractual agreement.

3. Similarly, to smoke detectors if contractors are working near sprinkler heads, the sprinkler should be covered to protect the unit from damage. Maintenance should be consulted to assist with covering sprinklers unless otherwise noted in the contractual agreement.

4. All hot work must be documented, submitted to VRP for review, and all procedures followed. Hot Work forms vary depending on the type of work. Please consult your supervisor or VRP if you have any questions. (SEE attachment II. “Hot work-Fire Watch”)

5. NPS Monitors should communicate daily contractor plans with their supervisor. Plans should be discussed with contractors at the beginning and end of each working day to keep all parties informed. Daily check-list sheets should be completed to assist in this task and submitted to the project manager for review. Be sure to note any safety issues that may have occurred.

6. Coordinate with the contractor prior to work beginning to determine if artifacts need to be moved, covered, or protected in advance. Coordinate with Cultural Resource Rangers.

7. If contractors are not easily identifiable (ie. No ID, company logo, uniform attire), they must be issued an EDIS Contractor Badge, which is to be visible at all times on their person. Conservators may remove the badge to avoid damage to artifacts but must have the badge visible in their immediate working area. Badges are located in the Visitor Center Desk and must be signed out by the contractor and the NPS assigned monitor.

During the Workday

1. IF THE FIRE SYSTEM IS IN TEST, YOU MUST CALL 911 IN CASE OF FIRE. If the system is in test, fire alarms will still go off, but the fire department will not be dispatched. If there is an alarm, also inform on-duty VRP Rangers. In case of fire, lead evacuation procedures. (SEE attachment I. Exert from Park OEP “Evacuation Procedures”)

2. Contractors must follow “Guidelines for Contractors” (noted under section IV). Any issues or conflicts should be reported to VRP and the project manager.

3. Contractors and their teams shall be escorted, accompanied, and monitored by NPS staff at all times to ensure and maintain the security of the structure, artifacts, and furnishings within the workspace. Assigned NPS staff shall remain in direct vicinity and will maintain line of sight with the contractors. Contractors shall not work independently in any park buildings or be separated from monitors by protective barriers (ie. affixed plastic sheets, tarps, painting dropcloths, tents etc.). If you need a break, coordinate with your direct supervisor.

4. Assigned monitors serve as direct POC for contractors to coordinate additional needs or tasks. Confirm and clarify any additional requests with the project manager. Actively communicate contractor needs (lunch break, relief, etc.) Contractors shall be physically escorted on/off site. Always predesignate a time and place to meet contractors.

5. If contractors need to work/have access to multiple locations, additional staff may be required. Coordinate with your supervisor and the project manager. If a project is ongoing beyond a week’s time, a schedule may be developed to clearly indicate who is monitoring and when.

6. Monitor for dust, dirt, or other debris intruding on areas outside of the worksite.

Additional measures may be necessary to protect all areas. Consult with the contractor, project manager, and maintenance rangers to correct the problem.

7. Monitor for safety issues, for example- ladder safety, use of extension cords, tripping hazards, unsafe or misuse of equipment. Report all safety hazards to on-duty VRP

Rangers and the project manager. NPS owned supplies, tools, or equipment is never permitted to be loaned to a contractor for use unless otherwise noted in the contractual agreement or directed by the COR.

8. It is inappropriate for NPS monitors to: assist the contractor with tasks, help carry tools or supplies, or provide feedback such as offering technical advice or answer technical questions. NPS owned supplies, tools, or equipment are never permitted to be loaned to a contractor for use unless otherwise noted in the contractual agreement or directed by the COR. All questions should be directed to the project manager and/or COR.

9. If anyone is injured, contact 911 and on-duty Rangers for EMS response. Contractors should also contact their direct supervisor about the incident.

10. Contact VRP Rangers for any alarms, trouble alerts, or power outages.

11. On-site Security: exterior doors shall remain locked at all times. When contractors are on break, arrange a time and place to meet to provide access to the worksite.

12. Dependent on work site location, know where the closest fire extinguisher is located. Be aware of evacuation routes and emergency exits. In case of a circuit breaker trip, contact Maintenance Rangers and advise on-duty VRP Rangers.

13. If you see something, say something. If something does not seem correct, contact your supervisor or the project manager.

End-of-Day Closing Procedures

1. Remind contractor 30 minutes before the end of the day to begin clean up. If hot work is being performed, be mindful of fire watch time periods.

2. All tools and supplies should be neatly put away. Do a walk through to make sure there are no safety hazards. All walkways should be clear. All protective barriers and coverings should be removed to eliminate fire and egress hazards.

3. Chemicals and other flammable materials cannot be left overnight in historic buildings.

They must be either taken by the contractor off-site or arrangements should be made in advance with maintenance to store them in a flammable storage cabinet. During working hours and when stored on-site, a physical copy of all chemical SDS sheets are required.

4. Dirty rags with flammable solvents must be stored in a fireproof container or removed from the site.

5. All electric tools and extension cords must be turned off and unplugged from outlets.

Cords should be neatly stored to avoid tripping hazards. Any heat generating equipment must be removed from the site.

6. Trash must be removed at the end of each workday and taken off-site unless other arrangements are stated in the contractual agreement.

Appendix I.

Thomas Edison NHP Emergency Occupant Plan

Exert- Evacuation Plan

1. Introduction

This Occupant Emergency Plan provides procedures to be followed during emergency situations.

The National Park Service believes that the safety of its employees and visitors is of the utmost importance. Please take the time to read this Occupant Emergency Plan carefully. An emergency or hazardous condition can occur at any time and without warning. Your knowledge of these procedures will ensure you can act quickly and calmly and thus prevent a serious injury or loss of life.

2. Emergency Telephone

Numbers and Contacts

Service

Location Phone

West Orange PD 60 Main St West Orange, NJ

07052

(973) 325-4000

NJ State Police 686 Nye Ave Irvington, NJ

07111

(973) 351-1063

Medical Emergency-

Ambulance

25 Mt. Pleasant Place West

Orange, NJ 07052

(973) 325-4170

Medical Emergency- Hospital Saint Barnabas Health

95 Old Short Hills Rd West

Orange, NJ 07052

(973) 322-5000

West Orange Fire

Department

415 Valley Rd West Orange, NJ 07052

(973) 325-4175

Facility Maintenance 211 Main St West Orange, NJ

07052

(973) 666-1580

Park Dispatch

Delaware Water Gap NRA

1978 River Rd Bushkill, PA

18324

(570) 426-2457

Chief Ranger (EDIS) 211 Main St West Orange NJ

07052

(201) 341-6203

Poison Control 140 Bergen St Newark, NJ

07101

(973) 972-9280

3. Occupant Emergency Actions

A. Emergency Alerts

Evacuation Signals

Fire alarm bells and strobe lights are used in the Laboratory Complex and Glenmont Estate buildings to alert personnel to immediately evacuate the building. Manual alarm pull stations will also activate a general alarm. A general alarm can also be activated automatically, if a sprinkler head is activated.

Not all emergency situations require occupants to evacuate. In some instances, such as severe weather, terrorist acts, or civil disturbance, occupants may be required to Shelter-in-

Place.

Emergency Notifications

EDIS Employee Information Line (973) 736-0550 Ext. 95

B. Evacuation Procedures

Upon activation of the alarm, occupants must;

▪ Stop work immediately

▪ If you are not in the immediate vicinity of your office when the alarm sounds, do not return to your office to retrieve your belongings; instead, proceed to the nearest emergency exit.

▪ Close all corridor doors but do not lock.

▪ Promptly and in an orderly manner, follow the evacuation route designated for your area.

▪ The evacuation of occupants who require assistance will be coordinated by their pre- assigned person.

▪ Walk to the nearest emergency exit. DO NOT RUN OR PUSH. Remain calm.

▪ Use handrails in the stairways.

▪ Proceed to the designated rally point and remain there until you receive further instructions.

▪ Use caution if crossing streets.

▪ Elevators must not be used during an evacuation. If you happen to be on an elevator when the alarm bells sound, exit the elevator at the first opportunity and proceed to the nearest emergency exit.

▪ Alternative evacuation routes may be designated by emergency response personnel under certain circumstances (e.g., bomb threats).

C. Rally Points

Identify Rally Points

Occupants in the Laboratory Complex should proceed to the staff parking lot

Occupants on the Glenmont Estate Grounds should proceed to the visitor parking lot

D. Individuals Who Require Assistance during a Building Evacuation

Self-Identification

Individuals who require assistance in an evacuation should self-identify their needs prior to an incident by notifying their supervisor.

Individuals who have self-identified have the option of using an assigned Buddy to aid and assist them in safely exiting the building. “Buddy Systems” are used in many high-rise buildings to safely and expeditiously assist persons with mobility, sensory, and hidden disabilities in the event of an emergency. A Buddy should become familiar with the specific needs of the individual. This may require training with special equipment, such as evacuation chairs;

knowing how to provide guiding assistance and how to assist when a service animal is used.

Supervisors are responsible for assigning at least two buddies. If the buddy is not physically present (e.g., teleworking) during the emergency, when notified of the emergency, the supervisor should contact the individual who requires assistance and ensure they are getting the necessary assistance.

Visitors and Individuals not previously Self-identified

If you have a visitor with a disability with you when the signal to evacuate the building is given, include them in the evacuation. If a visitor is visually impaired, people assisting them should offer their elbow to the individual and guide him/her through the evacuation route. If a guide dog is being used, ask the visitor how you can help their dog do its job of caring for them.

If you need assistance to evacuate but have not previously identified your need, go to a predesignated “Area of Refuge” in your building

Additional Notification for Hearing Impaired Individuals

The alarm system is supplemented with strobe lights which flash when the alarm is activated.

If the strobe lights are flashing, evacuate the building immediately.

Visually Impaired Individuals

Individuals who are blind or visually impaired need to know an evacuation route in case of an emergency and should know at least one alternate route. Twice a year, it is good to practice leaving the building by at least one of the emergency evacuation routes. This improves familiarity of the evacuation procedures and routes for the employee, their service animal, and their buddies.

Service animals: If the alarm is sounded, employees with a service animal should always leave the building - if they don't, their service animal will learn to disregard the alarms. Additionally, never let go of your service animal.

Buddies should be someone familiar with the visually impaired individual, specifically knowing how to provide guiding assistance, and they should be familiar with the individual’s service animal.

Individuals Who Are Unable to Evacuate via Stairwells

Make contact with your designated Buddy who will assist you in relocating to the

“Area of Refuge” if unable to exit the building.

If the emergency situation makes the “Area of Refuge” unsafe, call 911 to alert emergency response personnel of your location.

E. Accounting for Personnel

During a building emergency, all employees should go to the rally point. Once safely at the

Rally Point, check in with your supervisor.

F. Re-entry into the Building

Employees will be recalled into the building by an “All Clear” message from local emergency response officers or Visitor and Resource Protection Staff, when it is safe.

G. Occupant Emergencies

Medical Emergency

For serious accidents or illness requiring emergency medical assistance, call

911 Portable automated external defibrillators (AED) are located in each building.

Smoke/ Fire

If smoke or fire is present, pull the nearest fire-alarm manual pull and follow the evacuation procedures. The fire department is notified automatically. If the fire alarm is activated, evacuating through the nearest exit.

Appendix II.

Thomas Edison NHP

Hot Work/Fire Watch Procedures

Hot Work - The use of an open flame, welding torch, or significant heat producing equipment anywhere in or near a building for repair or conservation projects

Fire Watch:

Welding equipment - The 2 hour time frame after the welding process has concluded.

Open Flame- The 1 hour time frame after the flame has been extinguished.

Heat producing equipment- The 20 minute time frame after the heat-producing device has been turned off and unplugged

Prior to any flame, welding torch, or heat producing equipment being turned on/used, be certain:

o A hot work/open flame permit form is completed and signed by NPS and contractor.

o NPS will temporarily disable the fire alarm/sprinkler system as needed for the area.

o Contractor will provide at least 2 fully charged portable fire extinguishers.

o Contractor will protect surrounding area with fire blankets or other non-flammable material as needed.

o Both NPS and Contractor will provide at least one person each as a designated Fire

Watch Person.

During Hot Work:

o Confirm that all permit conditions have been met.

o NPS staff should have a park radio.

o Advise VRP division Hot Work has commenced o Know where the next available fire extinguisher is located.

o Confirm that the Contractor designated Fire Watch individual is in place.

o If pipes/metal are being soldered or welded, be aware of any smoke/heat or sparks that may come out at the opposite end of the pipe or below the flame. Is the area protected?

o Find a location where you can observe the hot work/open flame safely o If welding, do not look directly at the flame. Wear welding glasses.

o Observe where heat or flames are directed at all times. Be aware of any sparks or drips from soldering material.

o Note the time that the flame or heat equipment is turned off/unplugged. Report time to

VRP division.

o The NPS and Contractor designated Fire Watch individuals must remain in place for the required time as defined by the type of equipment used (ie. 2 hours for welding, 1 hour for open flame, 20 minutes for heat producing equipment). Designated individuals cannot conduct any other work while assigned to Fire Watch.

Fire Watch:

o The NPS and Contractor designated Fire Watch individuals shall remain in place until the entire designated time has elapsed. No other work can be conducted during this time.

o Check the area and make sure there are no visible signs of smoke. Do not touch hot metal such as pipes!

o Every few minutes, check the area and adjacent areas for any signs of smoke.

o At the end of the fire watch, check the area thoroughly. Make sure the surrounding floor, walls, ceiling, etc. are cool to the touch.

o Report time to the VRP division.

At the end of the day, make sure that the fire alarm panel is re-connected and put back in service before the contractor leaves.

Glossary

Hot Work - The use of an open flame or heat producing device anywhere in or near a building.

Welding – A fabrication process to join materials, usually metal, by using high heat to melt parts together and then allowing them to cool, causing fusion.

Open Flame – Fabrication utilizing a device that temporarily emits a flame directly exposed to outside elements.

Heat Producing Equipment – Electrically heated, often thermostatically adjustable, highly controllable equipment used to repair and conserve with precision and accuracy, such as but not limited to, tack irons, heat guns, soldering tools etc.

Hot Work Area - A 4' to 6' area around the open flame. This includes ceiling, floor and walls.

Each hot work area may differ based on location and type/size of flame or proximity of combustibles.

Fire Watch - The time frame after the open flame has been extinguished or the utilized heat producing equipment is switched off and unplugged. During the fire watch, both the contractor designated Fire Watch individual as well as the NPS Fire Watch individual, shall remain in the room and/or area where the hot work/open flame took place. Each are responsible for monitoring and extinguishing any possible lingering sparks or smoldering wood. Designated individuals cannot conduct any other work while assigned to Fire Watch.

Contractor Designated Fire Watch – A contractor assigned to monitor hot work. Must be familiar with the operation of a fire extinguisher and shall remain in close proximity to the hot work/open flame for the duration of the fire watch.

NPS Designated Fire Watch - An NPS employee assigned to monitor the hot work.

Thomas Edison National Historical Park

Hot Work

Request and Approval Form

Date: __________________ Time Of Work: ____________________________

Location and work to be done: ____________________________________________

Welding requiring 2 Hour Fire Watch:……………………………………..

Open Flame requiring 1 Hour Fire Watch:…………………………………

Heat producing equipment requiring 20 Min Fire Watch:………………….

Please supply the following:

Name of Conservator(s) or Welder (s) Signature

Name of Fire Watch Person (s) Signature o Fire watch must remain within 6’ – 8’ of the hot work at all times o Fire watch to continue after flame is extinguished and until the area is cool to the touch

The following items have been completed:

_____ Pre-hot work/open flame assessment meeting completed

_____ Smoke producing operations identified and ventilation provided

_____ Fire retardant blankets and/or other agreed upon fire protection is in place

_____ At least two appropriate fire extinguishers are within six feet of hot work

_____ NPS has temporarily disabled fire suppression/detection system for requested area

Signatures:

National Park Service:

Contractor:

VRP Division:

Approved: Denied: