Final Site Close-Out Report 

Crown Vantage Landfill Site 

Hunterdon County, New Jersey 

Prepared by 

U.S. Envir onmental Protection Agency 

Region 2 

New York, Ne ;v York 

Date: 

be . ;2~ 2or t:_ 

; 

Walter E. Mugdan 

Director 

Emergency and Remedial Response Division 

U.S. EPA, Region 2 
i

TABLE OF CONTENTS

1.0 INTRODUCTION........................................................................................................1

2.0 SUMMARY OF SITE CONDITIONS.......................................................................1

2.1 Site Location and Description.........................................................................1

2.2 Site History and Enforcement Activities ........................................................2

2.3 Selected Remedy and Remedial Action Objectives........................................3

2.4 Remedial Design and Remedial Construction Activities................................3

 2.4.1 Monitoring Well Closure ........................................................................4

 2.4.2 Partial Fence Relocation .........................................................................4

 2.4.3 Construction Complete and Preliminary Site Close-out.........................5

2.5 Institutional Controls ......................................................................................5

3.0 SUMMARY OF OPERATION, MAINTENANCE AND MONITORING ...........5

4.0 DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE 

AND QUALITY CONTROL......................................................................................6

5.0 FIVE-YEAR REVIEW................................................................................................6

6.0 SITE COMPLETION CRITERIA.............................................................................6

7.0 BIBLIOGRAPHY........................................................................................................7

FIGURES

1 Site Location Map
1

SUPERFUND FINAL SITE CLOSE-OUT REPORT

Crown Vantage Landfill Site

Frenchtown Road

Hunterdon County, New Jersey 

1.0 INTRODUCTION

This Final Close-Out Report documents the United States Environmental Protection Agency’s 

(EPA’s) determination that all response actions for the Crown Vantage Landfill Superfund Site 

have been completed in accordance with Close-Out Procedures for National Priorities List Sites

(OSWER Directive 9320.2-22, May 2011).

All response actions specified in the 2011 Record of Decision (ROD) for the Crown Vantage 

Landfill Superfund Site have been successfully implemented. EPA approved the August 2013 

Remedial Action Completion Report and issued a Preliminary Site Close-out Report on 

September 10, 2013. The ROD also required the implementation of institutional controls (i.e., 

deed notice) to ensure that future site uses do not disturb the surface of the site, thereby 

preventing future residential or commercial/industrial development of the site. These institutional 

controls are now in place. 

No further response, other than long-term monitoring and five-year reviews, is anticipated. 

Human exposures and contaminated groundwater releases are under control. 

2.0 SUMMARY OF SITE CONDITIONS

2.1 Site Location and Description

The Crown Vantage Landfill Site, EPA CERCLIS ID number NJN000204492, is an inactive 

former landfill located at Block 17.01 Lot 1 of the Alexandria Township Tax Map, at 500 

Milford-Frenchtown Road in Alexandria Township, Hunterdon County, New Jersey (see Figure 

1).

The site is approximately 10 acres and roughly elliptical in shape. The site has approximately 

1,500 feet of frontage on the eastern bank of the Delaware River. A mix of young and mature 

hardwood trees, shrubs and grasses covers the site. Access to the landfill area is restricted by 

locked chain-link fencing.

To the west of the site, across the Delaware River, lies Bucks County, Pennsylvania. The 

Delaware and Raritan Canal foot path and a farm field bound the site to the east. Historically, 

railroad tracks bounded the Site to the east. The landfill property is bounded to the south by the 

Delaware Raritan Canal State Park and to the north by the former Curtis Specialty Papers 

Superfund Site. 
2

2.2 Site History and Enforcement Activities 

The landfill reportedly was utilized by the nearby former Curtis Specialty Papers mill, as well as 

by other nearby Riegel Paper Company facilities, for the disposal of waste beginning in the late 

1930s through the early 1970s. The landfill may also have accepted flood-damaged items from 

the local community following record flooding of the Delaware River in 1955. Types of wastes 

disposed of at the landfill include fly ash, cinders, and bottom ash; paper mill and coating-related 

wastes, including foil-backed paper, off-specification paper, 55-gallon drums containing press 

room wastes, and paper fiber sludge from wastewater treatment plant operations; steel and fiber 

barrels and pallets; and construction and demolition debris. A review of historical aerial photos 

indicated that shallow trenches in the surface of the landfill may have been used for the burial of 

drummed wastes in the early 1970s.

The site has been characterized through numerous investigations that started in 1991 and 

continued to the Remedial Investigation (RI), which was conducted in 2008 and 2009. A 

Preliminary Site Investigation, including an aerial photograph analysis, geophysical survey of the 

landfill area, soil gas sampling, ground water sampling and a wetlands assessment, was 

conducted in 1991. The Preliminary Site Investigation was followed by the removal of drums 

(empty, full, and partially full) and paper products from the surface of the landfill. In 1994, 

monitoring wells were installed and the ground water quality was characterized. 

From 2001 through 2003, the New Jersey Department of Environmental Protection (NJDEP)

fenced the site, removed additional surface debris, including drums, and collected surface soil 

samples. The EPA conducted additional sampling of surface water, sediment, surface soil and 

fly ash, and ground water in 2003 and 2004. Additional wastes were removed from the surface 

and riprap was placed in flood-impacted areas. 

The site was proposed to the National Priorities List (NPL) in September 2004 (69 FR 56970) 

and listed on the NPL in April 2005 (70 FR 21644). 

In May 2005, Fort James Operating Company, a subsidiary of Georgia-Pacific Consumer 

Products (GP), entered into an Administrative Order on Consent (AOC) with EPA for a Removal 

Action. Under the 2005 AOC, additional surficial drums were removed, additional fencing was 

provided, and an engineered slope stabilization wall was constructed to stabilize the landfill’s 

western face. In total, over 700 surficial drums, drum remnants and drum carcasses were 

removed from the surface of the site during investigations conducted between 1991 and 2007.

Investigations and removal actions at the site have been performed by GP under an AOC signed 

in September 2007 and by International Paper Company (IP) under a Unilateral Administrative 

Order issued in December 2007. GP and IP retained TRC Solutions (TRC) as their 

environmental consultant. During the RI, more than 1,750 drums, drum carcasses and drum 

remnants were removed from the site. Analytical data from surface water, pore water and 

groundwater sampling showed that these media were not impacted by the site. The RI Report 

was completed in July 2010. The RI concluded that, after removal activities were conducted, all 

human health risks were within or below EPA’s acceptable levels. An ecological risk assessment 

was also conducted and concluded that there was no need for remediation based on potential 

risks to ecological receptors. The FS Report was completed in November 2010.
3

The Proposed Plan for the site was released for public comment on June 30, 2011. A public 

comment period was held from July 1 through July 30, 2011. A public meeting was held on July 

12, 2011 at the Milford Firehouse in Milford, New Jersey to discuss the findings of the RI/FS 

and to present EPA’s Proposed Plan to the community. 

EPA issued the ROD, including the Responsiveness Summary that addresses comments received 

during the public comment period, on September 29, 2011.

A Consent Decree for IP’s and GP’s performance of the Remedial Design and Remedial Action 

was entered by the United States District Court for the District of New Jersey on April 11, 2013. 

2.3 Selected Remedy and Remedial Action Objectives

The ROD for the site was signed in September 2011. Because the baseline human health risk 

assessment and ecological risk assessments for the site did not identify the presence of 

unacceptable human health or ecological risks requiring remediation under current and 

reasonably anticipated future site use, the remedial action objectives (RAOs) were limited to the 

following:

 Prevent exposures to landfill materials.

The major components of the selected remedy of the September 2011 ROD include the 

following:

 Establishment of a deed restriction to ensure that future site uses do not result in the 

disturbance of the surface of the site, thereby preventing future residential or 

commercial/industrial development of the site;

 Continued maintenance of security measures at the site (e.g., signage and fencing);

 Continued maintenance of the slope stabilization wall;

 Sealing of remaining shallow monitoring wells; 

 Semi-annual monitoring of the site, including the slope stabilization wall; and

 Five-Year Reviews.

2.4 Remedial Design and Remedial Construction Activities

The remedy was designed and constructed in a single phase. The table below summarizes the 

chronology of the design and implementation of the remedial construction activities. Due to the 

previous construction of the slope stabilization wall and the removal of hot-spot drum disposal 

areas while the RI was ongoing, a formal remedial design was not required to implement the 

remaining components of the remedy selected in the September 2011 ROD. The scope of the 

remedial actions was described in the Work Plan - Monitoring Well Closure and Partial Fence 

Relocation, which was submitted in December 2012 and approved by EPA in January 2013. The 

work plan was implemented from February to April 2013. The monitoring well closure required 

by the ROD and the fence relocation undertaken as part of maintaining the existing security 

measures, are described separately below. 
4

Chronology of Remedial Construction Activities

Activity Date

Record of Decision September 29, 2011

Submittal of Work Plan - Monitoring Well 

Closure and Partial Fence Relocation December 12, 2012

Approval of Work Plan - Monitoring Well 

Closure and Partial Fence Relocation January 2, 2013

RA Construction Activities February 20 - April 4, 2013

Submittal of Remedial Action/O&M Plan May 10, 2013

Disposal & Demobilization Complete June 6, 2013

Approval of Remedial Action/O&M Plan June 21, 2013

Final Inspection July 16, 2013

Approval of Remedial Action Report September 10, 2013

Preliminary Site Close-out Report September 10, 2013

2.4.1 Monitoring Well Closure

Field work began in February 2013 to locate the monitoring wells and piezometers for closure. 

From February to April 2013, three flush-mounted monitoring wells (MW-1, MW-2 and MW-3) 

and two piezometers (REAC-MW-8 and REAC-MW-9) were located in the field and sealed in 

accordance with New Jersey well closure regulations. The monitoring wells were verified to be 

clear of obstructions, the depth of each well was measured, and Portland cement grout was then

pumped into the well with a tremie pipe to seal the well. For the piezometers, Portland grout was

introduced into the annulus that remained when the plastic casing was removed. Following 

grouting, a concrete cap was placed over the top of each well or piezometer to encourage 

drainage away from the location of the closed well/piezometer. 

Three monitoring wells (MW-4, MW-5 and MW-6) and four piezometers (REAC-MW-3, 

REAC-MW-4, REAC-MW-6 and REAC-MW-7) were documented to have been closed in 2007. 

Two monitoring wells (MW-7 and MW-8) could not be located visually or with the use of a 

metal detector and may have been closed in 2007 or covered by silt and other materials since 

they were last sampled in 1994. Four piezometers located beneath the slope stabilization wall 

(REAC-MW-3, REAC-MW-4, REAC-MW-8 and REAC-MW-9) also could not be located and 

are presumed to be no longer accessible.

2.4.2 Partial Fence Relocation

During routine inspection of the slope stabilization wall and perimeter fencing in October 2011, 

areas of erosion were observed near the southern corner of the perimeter fence line, adjacent to 

the Delaware River. In this area, erosion had cut the riverbank very close to the fence. As a 

preventive measure, the work plan called for relocating this portion of the fence to be closer to, 

but still outside, the limits of the landfill as defined by previous visual observations and 

geophysical testing. 
5

The partial fence relocation was conducted in March 2013. New 12-foot fence posts were driven 

to a depth of four feet. Monitoring of ambient air was conducted during fence installation, with 

no measurable concentrations of volatile organic compounds detected above background levels. 

Old posts and fencing were removed and recycled, and a new section of fencing and fabric 

installed. New coated, rust-free aluminum signs were posted along the entire fence perimeter as 

needed.

2.4.3 Construction Complete and Preliminary Site Close-out

On April 22, 2013, EPA conducted a preliminary site inspection that included a review of the 

relocated fence portion. The final inspection was conducted on July 16, 2013 with 

representatives of EPA and the NJDEP in attendance; no punch list items were identified. On 

September 10, 2013, EPA approved the August 2013 Remedial Action Completion Report and 

issued a Preliminary Site Close-out Report for the site.

2.5 Institutional Controls

As noted above, the September 2011 ROD included the establishment of a deed restriction to 

ensure that future site uses do not result in the disturbance of the surface of the site, thereby 

preventing future residential or commercial/industrial development of the site. As part of the 

bankruptcy proceedings associated with the previous site owner, Crown Paper Co., the 

bankruptcy court authorized the abandonment of the site property in 2001. Crown Paper Co. is

now a defunct entity without identifiable representatives, directors or officers. Therefore, with 

the support of the EPA and Alexandria Township, IP and GP sought court appointment of a 

receiver for Crown Paper Co. who would have the power to, among other things, execute a deed 

notice for the property. On March 25, 2011, the court issued an Interim Order providing, among 

other things, for the future appointment of a receiver to execute the deed notice for the site after 

the ROD was issued. 

Pursuant to the April 2013 RD/RA Consent Decree and the EPA-approved May 2013 Remedial 

Action/O&M Plan, IP and GP prepared a draft deed notice. EPA approved the final deed notice 

on December 3, 2013. In January 2014, IP and GP filed an application with the court and, on 

February 14, 2014, the judge signed the order appointing the receiver to execute and authorize 

the recording of the deed notice. The court-appointed receiver then duly executed the deed notice 

and authorized its recordation. The deed notice was recorded by the Hunterdon County Clerk on 

February 25, 2014. 

3.0 SUMMARY OF OPERATION, MAINTENANCE AND MONITORING

Operation, maintenance and monitoring (O&M) activities at the site are conducted in accordance 

with the EPA-approved Remedial Action/O&M Plan. O&M activities include semi-annual 

monitoring of the site, including the slope stabilization wall; continued maintenance of security 

measures at the site (e.g., signage and fencing); and continued maintenance of the slope 

stabilization wall through the elimination of plant growth and flood debris deposited on the 

stabilization wall that could compromise the integrity of the wall.
6

To date, three semi-annual site inspections have been completed (October 2013, April 2014, and 

October 2014) and three semi-annual monitoring reports have been submitted (November 2013, 

May 2014, and November 2014). Maintenance activities implemented as a result of the semiannual inspections have included the removal of fallen trees from the fence line and stabilization 

wall; the removal of woody plants sprouting on the face of the stabilization wall; the removal of 

vegetation that was blocking the view of warning signs and the clearance of vegetation growing 

on the fence line. No evidence of security breaches (i.e., on-site trespassers) and no adverse 

impacts affecting the effectiveness of the stabilization wall were observed.

4.0 DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND 

QUALITY CONTROL 

All applicable EPA and NJDEP quality assurance and quality control (QA/QC) procedures and 

protocols were incorporated into the response actions. Remedial action activities at the site (i.e., 

monitoring well closure and partial fence relocation) were undertaken in accordance with the 

ROD and EPA-approved work plans. Technical specifications and drawings were developed for 

the chain link fence installation. All subcontractor activities, including the evaluation of 

subcontractor materials and workmanship, were performed with TRC oversight. Subsequent 

EPA inspections confirmed that remedial actions were completed in accordance with the ROD 

and EPA-approved work plans. 

5.0 FIVE-YEAR REVIEW

Hazardous substances will remain at this site above levels which would allow for unlimited use 

and unrestricted exposure for more than five years. EPA will conduct statutory five-year reviews 

consistent with the 2001 Comprehensive Five-Year Review Guidance. The first Five-Year 

Review Report will be completed by February 2018, which is five years from the start of the onsite remedial action construction.

6.0 SITE COMPLETION CRITERIA

This site meets all the site completion requirements as specified in OSWER Directive 9320.2-

22, Close Out Procedures for National Priorities List Sites. The implemented remedies achieve 

the degree of cleanup and protection specified in the ROD for all exposure pathways. 

Specifically, all actions specified in the 2011 ROD have been implemented. Institutional 

controls are in place to further prevent potential exposures to the public. All selected remedial 

and removal actions and the RAO are consistent with agency policy and guidance. 

The continuing efforts at the site are the semi-annual long-term monitoring of the fence, signs 

and wall, the biennial inspections and certifications for deed-noticed properties, and conducting 

future five-year reviews. 
7

7.0 BIBLIOGRAPHY

Woodward-Clyde Consultants, 1991. Preliminary Site Investigation Report, James River 

Corporation Old Landfill Site, Milford, New Jersey. September 12, 1991.

Woodward-Clyde Consultants, 1992. Surface Remedial Action Report, Old Landfill Site, 

Milford, NJ. August 1992.

Woodward-Clyde Consultants, 1992. Wetland Delineation Report for an Application for a Letter 

of Interpretation, Block 17.01, Lot 1, Alexandria Township, Hunterdon County, New Jersey, 

James River Old Landfill Site. October 1992.

Woodward-Clyde Consultants, 1995. Preliminary Groundwater Investigation Report, James 

River Corporation, Milford, New Jersey. February 1995.

ATSDR, 2004. Health Consultation, Crown Vantage Landfill, Alexandria Township, Hunterdon 

County, New Jersey, available at 

http://www.atsdr.cdc.gov/HAC/PHA/crownvantage/cvl_pl.html, dated March 9, 2004.

NJDEP, 2003. Internal Memorandum re: Crown Vantage Landfill – Soil Sample Results Review, 

from Steven Macgregor, Technical Coordinator, BEERA/EES to Robert Gallagher, Site 

Manager, OWR, dated June 6, 2003.

EPA, 2004. Hazard Ranking System Documentation Package, Crown Vantage Landfill, 

Alexandria Township, Hunterdon County, New Jersey, CERCLIS ID No. : NJN000204492, EPA 

Region 2 Site Assessment Team, Weston Solutions, Inc., September 2004. 

EPA, 2004. Aerial Photographic Analysis of Crown Vantage Landfill Site, Alexandria 

Township, New Jersey, EPA Environmental Sciences Division, TS-PIC-20402354S, March 

2004.

Weston, 2004. Integrated Assessment Report, Crown Vantage Landfill, Alexandria Township, 

Hunterdon County, New Jersey, CERCLIS ID No. NJN000204492. Volumes I through III, 

Weston Solutions, Inc., Region 2 Site Assessment Team, September 2004.

EPA, 2005. Action Memorandum/Enforcement for the Crown Vantage Landfill, Alexandria 

Township, Hunterdon County, New Jersey, from Nick Magriples, On-Scene Coordinator, 

Removal Action Branch, to William McCabe, Acting Director, Emergency and Remedial 

Response Division, dated January 18, 2005.

ATSDR, 2006. Public Health Assessment for Crown Vantage Landfill, Alexandria Township, 

Hunterdon County, New Jersey, EPA Facility No. NJN00204492, July 5, 2006.

ENSR, 2006. Engineering Design Report, Slope Stabilization Measures, Crown Vantage 

Landfill located in Alexandria Township, New Jersey. ENSR Corporation, July 2006.
8

ENSR, 2007. Final Report of Slope Stabilization Measures, Crown Vantage Landfill Site, 

located in Alexandria Township, New Jersey. ENSR Corporation, October 2007.

TRC, 2008. Current Conditions Report, Crown Vantage Landfill, Alexandria Township, 

Hunterdon County, New Jersey. TRC, October 2007, revised January 2008.

TRC, 2008. Preliminary Conceptual Site Model, Crown Vantage Landfill, Alexandria 

Township, Hunterdon County, New Jersey. TRC, November 2007, revised May 2008.

TRC, 2008. Remedial Investigation/Feasibility Study Work Plan. TRC, May 2008, revised 

August 2008.

TRC, 2009. Memorandum on Exposure Scenarios and Assumptions, Crown Vantage Landfill, 

TRC, February 2009, revised April 2009 and May 2009. 

TRC, 2009. Site Characterization Summary Report, Crown Vantage Landfill, TRC, June 2009.

TRC, 2009. Screening Level Ecological Risk Assessment, Crown Vantage Landfill, TRC, 

Revised August 2009.

TRC, 2009. Pathways Analysis Report, Crown Vantage Landfill, TRC, June 2009, revised 

August 2009.

TRC, 2009. Screening Level Ecological Risk Assessment, Crown Vantage Landfill, TRC, July 

2009, revised August 2009.

TRC, 2010. Human Health Risk Assessment, Crown Vantage Landfill, TRC, November 2009, 

revised January 2010.

TRC, 2010. Baseline Ecological Risk Assessment, Crown Vantage Landfill, TRC, January 

2010, revised April 2010.

TRC, 2010. Reuse Assessment Report, Crown Vantage Landfill, TRC, February 2010, revised 

April 2010.

TRC, 2010. Development and Screening of Remedial Alternatives Technical Memorandum, 

TRC, June 2010.

TRC, 2010. Remedial Investigation Report, Crown Vantage Landfill, TRC, June 2010, revised 

July 2010.

TRC, 2010. Feasibility Study Report, Crown Vantage Landfill Site, TRC, September 2010, 

revised November 2010.

EPA, 2011. Record of Decision, Crown Vantage Landfill, EPA, September 29, 2011.

TRC, 2012. Remedial Action Work Plan, Crown Vantage Landfill Site, TRC, May 10, 2013. 
9

TRC, 2012. Work Plan – Monitoring Well Closure and Partial Fence Relocation, Crown 

Vantage Landfill Site, TRC, December 2012.

TRC, 2013. Remedial Action Completion Report, Crown Vantage Landfill Site, TRC, August 

2013.

EPA, 2013. Preliminary Closeout Report, Crown Vantage Landfill Site, EPA, September 2013.
10