# F inal S ite Close-Out Report C ro w n Vantage Landfill Site

Hunterdon County, New Jersey

Prepared by

U.S. Env i r o nmental Protection Agency Region 2 New York, Ne ;v York

Date : 

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; Walter E. Mug dan Direc t or Emergency a nd Rem ed ial Respons e Division U.S

. EPA

, Re g i o n 2i 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 Desig n 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 CO MPLETION CRITERIA

................................ ................................ ............. 6

7 .0 BIBLIOGRA PHY

................................ ................................ ................................ ........ 7

FIGURES

1 Site Location Map1 SUPERFUND FINAL SITE CLOSE

- OUT REPORT

Crown Vantage Landfill Site Frenchtown Road Hunterdon County, New Jersey

1.0 INTRODUCTIO N

This Final Close

- Out Report documents the United State s 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 Clos e

- 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/industria l 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 S ITE 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 acr es 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 t rees, 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 p ath and a farm fi eld bound the s ite 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 S ite

.2

2.2 S ite History and Enforcement Activities

The landfill reportedly was utilized by the nearby former Curtis Specialty Paper s mill, as well as by other n earby Riegel Paper Company facilities, for the disposal of waste beginning in the late 1930s through the e arly 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 coa ting

- related
wastes , i ncluding 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 const ruction 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 s ite has been characterized through numerous investigations that start ed in 1 991 and continued to the Remedial Investigation (RI), which w as conducted in 2008 and 2009. A Prel iminary 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 P reliminary Site Investigation was followed by the removal of drums (empty, full, and partially full) and paper products fro m the surface of the landfill. In 1994, monitoring wells were installed and the ground water quality was characterized.

From 2001 thro ugh 2003, the N ew Jersey De partment of Environmental Protection (NJDEP) fenced the s ite, 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 s ite was proposed to the National Prioritie s List (NPL) i n 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 dru ms, drum remnants and drum carcasses were

r emoved from the surface of the s ite during investigations conducted between 1991 and 2007.

I nvestigati ons and removal actions at the s ite have been performed by GP under an AOC signed in September 2007 and by Int ernational 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 fr om the s ite. 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 s ite was released for public comment on June 30, 2011. A public comment pe riod 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 t he ROD , including the Responsiveness Summary that addresses comments received during the public comment per iod, 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 s ite was signed in Septem ber 2011

. Because the baseline human health risk assessment and ecological risk assessment s for the s ite did not identify the presence of unacceptable human health or ecological risks requiring remediation under current and reasonably anticipated future s i te 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 res triction to en sure that future s ite uses do not result in the dis turbance of the surface of the s ite, thereby preventing future residential or commercial /industrial development of the s ite;

 Continued maintenan ce of security measures at the s ite (e.g., signage and fencin g);

 Continued maintenance of the slope stabilization wall;

 Sealing of remaining shallow monitoring wells;

 Semi

- annual monitor ing of the s ite, including the slope stabilization wall; and

 Five

- Year Reviews.

2.4 Remedial Design and Remedial Construction Activit ies

The remedy was d esigned 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 re moval 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 Pl an

- Monitoring Well Closure and Partial Fence Relocation, which was submitted in December 2012 and approved by EPA in January 2013. The work plan was implemente d 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 Activit i es

Activity Date
Record of Decision September 29, 2011 Submittal of Work Plan

- Monitoring Well C losure 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 & Demob ilization 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 C losure 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 w as mea sured, 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 th e location of the closed well/piezometer.

Three moni toring wells (MW

- 4, MW

- 5 and MW

- 6) and four piezometers (R EAC

- 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 loc ated visually or with the use of a metal detector and may have been closed in 2007 or covered by silt and other materials since th ey were last sampled in 1994. Four piezometers located beneath the slope stabilization wall (R EAC

- MW

- 3, REAC

- MW

- 4, REAC

- MW

- 8 a nd REAC

- MW

- 9) also could not be located and are presumed to be no longer accessible

.

2.4.2 Partial Fence R elocation During routine inspection of t he slope stabilization wall and perimeter fencing in October 2011

, areas o f erosion were observed near the souther n 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, t he work plan called for relocating this portion of the fence to be closer to, but still ou tsi de, 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 p osted 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 re view of the relocated fence portion

. T he final i n spection 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 include d the establishment of a deed res triction to ensure that future s ite uses do not result in the dis turbance of the surface of the s ite, thereby preventing future residential or commercial/ind ustrial development of the s ite. As part of the bankruptcy proceedings associated with the previous site owner, Crown Paper Co., the bankruptcy court aut horized the abandonment of the s ite property in 2001. Crown Paper Co. i s

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 oth er 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 e xecute the deed notice for the s ite after the ROD was issu ed

.

P ursuant t o the April 2013 RD/RA Consent Decree and the EPA

- approved May 2013 Remedial Action/O&M Pl an, 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 , o n 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 record ed by the Hunterdon County Clerk on February 25, 2014.

3.0 SUMMARY OF OPERATION , MAINTENANCE AND MO NITORING

O peration, maintenance and monitoring (O&M) activities at the s ite are conducted in accordance with the EPA

- approved Remedial Action/O&M Plan. O&M activities include semi

- annual monitoring of the s ite, including the slope stabilization wall; continued maintenan ce of security measures at the s ite (e.g., signage and fencing); and continued maintenance of the slope stabilization wall through the elimina tion 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 s ite inspections have been completed (October 2013, April 2014, and October 2014) and three semi

- annual m onitoring reports have been submitted (November 2013, May 2014, and November 2014). Maintenance activities implemented as a result of the semi

annual inspections have include d the removal of fallen trees from the fence line and stabilization wall; the remo val 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 trespasse rs) and no adverse impacts affecting the effectiveness of the stabilization wall were observed.

4.0 DEMONSTRATION OF CLE ANUP ACTIVITY QUALIT Y ASSURANCE AND QUALITY CONTROL

All applicable EPA and NJDEP quality assurance and quality control (QA/QC) procedure s and protoc ols were incorporated into the response actions . Remedia l action activities at the s ite (i.e., monitoring well closure and partial fence relocation) were undertaken in accordance with the ROD and EPA

- approved work plans

. Technical specificatio ns 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 a ctions were completed in acco rdance with the ROD and EPA

- approved work plan s

.

5.0 FIVE

- YEAR REVIEW

Hazardous substances will remain at this s ite 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 Re port will be completed by February 201 8 , which is five years from the start of the on

site remedial action construction

.

6.0 S ITE COMPLETION CRITE RIA

This s ite 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 specifie d 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 R AO are consistent with agency policy and guidance.

The continuing efforts at the s ite 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 f ive

- year reviews.7

7.0 BIB LIOGRAPHY

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 Re port, 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 Lan dfill 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, Hunt erdon 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, Hunter don 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. Eng ineering 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 Alexa ndria 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 Si te 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 Exp osure 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 Assessmen t, 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, revise d 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 W ork 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 Landfil l Site , TRC, August 2013.

EPA, 2013. Preliminary Closeout Report, Crown Vantage Landfill Site , EPA, September 2013.10