COMMUNITY INVOLVEMENT PLAN
FORMER CUSTOM CLEANERS SITE SHELBY COUNTY, TENNESSEE
JUNE 2017
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 4
Approved by~ Date:-,f----S....-~-- vJ/2JJbr COMMUNITY INVOLVEMENT PLAN
FORMER CUSTOM CLEANERS SITE SHELBY COUNTY, TENNESSEE
JUNE 2017
U. S. ENVIRONMENTAL PROTECTION AGENCY REGION 4
Title Page
Project Title: Former Custom Cleaners Site
Document Title: Community Involvement Plan for Former Custom Cleaners Site Memphis, Shelby County, Tennessee
Prepared by: U.S. Environmental Protection Agency
Date Prepared: June 2017
Date(s) Revised:
Principal author: Kerisa Coleman, Community Involvement Coordinator
EPA RPM: Ken Mallary, Remedial Project Manager THE U. S. ENVIRONMENTAL PROTECTION AGENCY’S (EPA) SUPERFUND COMMUNITY INVOLVEMENT PROGRAM IS COMMITTED TO PROMOTING COMMUNICATION BETWEEN CITIZENS AND THE AGENCY.
ACTIVE PUBLIC INVOLVEMENT IS CRUCIAL TO THE SUCCESS OF ANY PUBLIC PROJECT.
EPA’S COMMUNITY INVOLVEMENT ACTIVITIES AT THE FORMER CUSTOM CLEANERS SITE ARE DESIGNED TO
INFORM THE PUBLIC OF THE NATURE OF THE ENVIRONMENTAL ISSUES ASSOCIATED WITH THE SITE,
INVOLVE THE PUBLIC IN THE DECISION-MAKING PROCESS THAT WILL AFFECT THEM,
INVOLVE THE PUBLIC IN THE RESPONSES UNDER CONSIDERATION TO REMEDY THESE ISSUES, AND
INFORM THE PUBLIC OF THE PROGRESS BEING MADE TO IMPLEMENT THE REMEDY.
Table of Contents
Section Page
1.0 Overview of the Community Involvement Plan ...... 5 2.0 Community Background ...... 6 3.0 Community Concerns ...... 9 4.0 Community Involvement Goals and Activities...... 13 5.0 What Is Superfund?...... 16 6.0 Environmental Justice ...... 17 7.0 Site Description ...... 18
Appendices: A EPA Regional Contacts...... 21 B Local Officials ...... 22 C State Officials ...... 23 D Federal Elected Officials ...... 24 E Environmental and Active Citizens Groups ...... 25 F Media Contacts ...... 26 G Meeting Locations ...... 27 H Repository Locations ...... 28 I Glossary ...... 29 J Acronym List ...... 32 K References ...... 33 L Attachments ...... 34
Figure 1 (front cover) The Former Custom Cleaner building being demolished during EPA’s removal action. ______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 4 Section 1.0 Overview of the Community Involvement Plan
The United States Environmental Protection Agency (EPA or the Agency) developed this Community Involvement Plan (CIP) to inform and involve the community in a two-way discussion about the Former Custom Cleaners (FCC) Site. This CIP is developed in accordance with EPA's Superfund Program. It provides information about community concerns and presents a plan that is intended to enhance communication between local residents and EPA as investigation and cleanup at the site progresses.
The objective of EPA's Superfund Community Involvement Program is to involve the public in activities and decisions related to the cleanup of Superfund sites. EPA recognizes, in its decision- making process, the importance of actively soliciting comments and information from the community. Public input can be useful in two ways:
Communities are able to provide valuable information on local history, citizen involvement, and site conditions. Communities that express concerns assist the EPA in recognizing the unique characteristics of each site community and in developing a response that more effectively addresses specific community needs.
The CIP will be revised as community concern warrants or at minimum, every three years until the Site is removed from the National Priorities List (NPL). The revision process includes conducting additional community interviews, updating the mailing lists, auditing the files at the designated information repository, and updating the contacts and resources provided in the appendices of the CIP as necessary.
This CIP consists of the following sections: • A description and brief history of the FCC Site. • An explanation of the Superfund Process. • A discussion of the Agency’s environmental justice commitment • A profile of Memphis, Shelby County, Tennessee • A discussion of community involvement objectives for the site and activities designed to implement them.
This CIP contains the following appendices: • A list of contacts and interested groups. • A list of locations for public meetings and the site information repository. • Glossaries of acronyms, technical terms, and references.
If you are interested in submitting comments or have questions or suggestions concerning the CIP, please contact: Kerisa Coleman Community Involvement Coordinator EPA Region 4 (404) 562-8831 [email protected] ______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 5 Section 2.0 Community Background
This section describes the composition of Memphis, Shelby County, Tennessee and the history of community involvement with the site.
2.1 Community Profile
Memphis is the largest city in Tennessee and is situated in the southwest corner of Tennessee and is located on the banks of the Mississippi River and borders both Arkansas and Mississippi. The City of Memphis has a mayor and council form of government which was established in 1966. The City’s government provides a full range of municipal services, including police and fire protection, comprehensive land use planning and zoning services, code enforcement and neighborhood improvement, streets and drainage construction and maintenance, traffic engineering services, refuse and recycling services, recreation and parks, cultural and nature services and necessary administrative services to support these activities. Additionally, Memphis is home to Regional One Health, the regional trauma center for Tennessee, Arkansas and Mississippi, St. Jude Children’s Research Hospital, which conducts world-class cancer research and treatment, Methodists Hospital, and LeBonheaur Children's Hospital. Home to FedEx, AutoZone, International Paper, Service Master and several other Fortune 500 companies, Memphis is consistently ranked among the best places to conduct business. Memphis is known for its BBQ, entertainment and business. Memphis is home to the University of Memphis, the University of Tennessee-Health Science Center, LeMoyne-Owen College, Rhodes College, Christian Brothers University and the Southern College of Optometry. Due to its central location in the United States and its many business interests, Memphis’ International Airport handles more cargo than any other airport in America and second in the world. Memphis is also home to the University of Memphis Tigers, Memphis Grizzlies, and Memphis Redbirds.
Memphis' first inhabitants were Native American Indians who lived along the Mississippi River for 10,000 years along the wooded river bluffs. A thousand years before foreign explorers entered the region, Chickasaw Indians controlled the bluffs. After the French and Indian War in 1763, England gained control of the bluffs although the area was Chickasaw by treaty. The Indians, French, English, Spanish and new "Americans" coexisted along the river trading and skirmishing until Tennessee became a U.S. territory in 1790, and then a state in 1796. Although this land legally belonged to the Chickasaw Indians, the new settlers would eventually take it over. In 1818 the Chickasaws relinquished their northern territory, including the land that would become the City of Memphis. The city was surveyed and designed in 1819. Thusly, Memphis was founded in 1819 and incorporated in 1826. At the time Memphis was only four blocks wide and had a population of around fifty people. Marcus Winchester, the General's son, was made the first mayor.
In 1968 Memphis became the focus for an important civil rights struggle. A labor dispute raised by the City of Memphis Sanitation Workers escalated into a full-fledged commitment to human dignity, economic equity, and an attack on poverty. The issue brought Dr. Martin Luther King to Memphis. For his commitment to non-violent change, Dr. King was killed on the balcony of the
______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 6 Lorraine Motel in Memphis on April 4, 1968. Riots ensued in cities all over the nation. Memphis' contribution to the ceaseless struggle of bettering human relations and improving life is the National Civil Rights Museum, built at the Lorraine Motel where Dr. King was assassinated. The same year the Civil Rights Museum opened, Memphis elected its first African-American Mayor, Dr. Willie W. Herenton.
The graphics above show demographics of both Memphis and Zip Code 38111. Zip Code is 38111 was used because it includes the area that encompasses the Site. The information was taken from http://www.city-data.com/. The information in the table below is based on the 2010- 2015 (estimates) U.S. Census Bureau. Please note that because the information is from two different sources, the numbers may not be equal in all categories.
People Quick Facts (U.S. Census Bureau, 2015) Memphis Tennessee Population, 2015 655,770 6,548,000 Population, percent change, 2010 to 2015 0.6% 4.0% Population, 2000 646,889 6,346,105 Persons under 5 years old, percent, 2010 7.6% 6.4% Persons under 18 years old, percent, 2010 26% 23.6% Persons 65 years old and over, percent, 2010 10.3% 15.4% Female persons, percent, 2010 52.5% 51.3% White persons, percent, 2010 29.4% 78.8% Black persons, percent, 2010 63.3% 17.1% American Indian and Alaska Native persons, percent, 2010 0.2% 0.4% Asian persons, percent, 2010 1.6% 1.8% Persons reporting two or more races, percent, 2010 1.4% 1.8% Persons of Hispanic or Latino origin, percent, 2010 6.5% 5.2% White persons not Hispanic, percent, 2010 27.5% 74.4%
______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 7 2.2 History of Community Involvement EPA Region 4 has established community involvement activities since the discovery of the Site, which include following meetings and activities:
During the week of August 29, 2016 the Community Involvement Coordinator (CIC) and the Federal On-Scene Removal Actions Coordinator (OSC) conducted outreach activities to Removal responses are provide information on EPA’s Removal Action that would common at Superfund sites occur in the late summer of 2016. when the contamination poses an immediate threat to human The local information repository was established in health and the environment. September 2016 at the Benjamin L. Hooks Central Library located at 3030 Poplar Avenue, Memphis, TN. Information Repository On October 6, 2016 EPA hosted a public meeting to A record storage area at or approximately eight citizens, local stakeholders and state near a Superfund Site that officials. The meeting’s purpose was to provide contains all correspondence, information on the Site’s proposed listing to the National Priorities List (NPL), the Superfund process, Site history reports and documents and background as well as procedures for submitting pertaining to the site, as well written comments pertinent to the September 8, 2016 as general Superfund program Proposed Rule. information.
The administrative record file was established and made available to the public as a part of the information Administrative Record repository in November 2016. The administrative record for a response action serves an The EPA Site team in conjunction with personnel from the important purpose: it contains Tennessee Department of Environment and Conservation the information that explains (TDEC) continue to engage the community by addressing why EPA conducted a concerns and sharing information in a timely manner. particular response at a site. The CIC conducted face-to-face, email and telephone interviews during the week of March 6, 2017.
Community Interviews Face-to-face and telephone community interviews were conducted during the week of March 6, 2017. The purpose of the interviews was to gather information and identify key considerations to inform the CIP and future community involvement activities at the Site. The CIC met and spoke with several stakeholders, including the City of Memphis’ Mayor’s office, small businesses surrounding the Site, community members, environmental groups and the Center for Applied Earth Science and Engineering Research (CAESAR) staff.
______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 8 Section 3.0 Community Concerns
Table 3.1, Summary of Community Concerns and EPA Responses (on the next page), presents a summary of the major concerns gathered from local stakeholders, residents, environmental groups and local officials during outreach opportunities involving the community and EPA responses to those concerns. Health issues, water quality and addressing other potential sites were the major concerns identified. The information was gathered through formal interviews, telephone calls and email correspondence since August 2016.
Local businesses also expressed concern to the EPA about the condition of the rear entrance of the Site that sits along Southern Avenue and Minor Road (see photograph below). Stakeholders expressed concerns over potential run off of contamination prior to and during the removal action. The OSC addressed these concerns during early outreach activities in 2016. During outreach activities, stakeholders expressed sincere concerns over potential threats from the Site’s contamination on their drinking water quality.
Figure 2 (Rear entrance to the Former Custom Cleaners Site)
______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 9 3.1 Summary of Community Concerns and EPA Response
Summary of Community Concerns and EPA Responses Concern EPA Response What are the effects of the contaminants on During the remedial investigation, a risk health? Stakeholders expressed concern with assessment will be completed which will regard to various health issues in the provide more information on the effects of the community. contaminants found at the Site. Once EPA collects samples at the Site and analyzes the data during the Remedial Investigation (RI), a risk assessment will be developed to provide information about the potential effects of the contaminants on human health, including the primary contaminant tetrachloroethylene (PCE). A fact sheet on PCE is included as an attachment to this CIP. In addition, the Tennessee Department of Health’s (TDH) Environmental Epidemiology Program (EPP) is funded by the Agency for Toxic Substances and Disease Registry (ATSDR). The TDH EEP will prepare a health assessment after information has been gathered from the RI to assess the potential impacts to human health associated with the Site-related contaminants. The TDH EEP point-of-contact information will be included in this CIP. Municipal Water Quality Memphis Light, Gas and Water (MLGW) periodically checks the groundwater quality in Memphis by collecting and analyzing groundwater from the individual production wells. Recent groundwater samples collected from the Sheahan Well Field located approximately one mile east of the FCC Site do not indicate the presence of Site-related contamination. How bad is the contamination? The EPA Removal Action that was completed in fall 2016 removed the former FCC building and highest levels of PCE in the soil beneath the building foundation. The upcoming RI will determine how much PCE remains in the soil, groundwater and soil gas at the Site. The risk assessment will evaluate the potential risks to human health associated with the PCE. ______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 10 Inadequate number of monitoring wells One monitoring well was installed at the Site during the Site Inspection (SI) to determine if PCE has reached the Memphis Sand Aquifer. That well, screened in the migration pathway (intermediate aquifer) to the Memphis Sand, did indicate the presence of PCE. Additional soil borings and monitoring wells will be installed at the Site during the RI to further evaluate the nature and extent of Site-related groundwater contamination. Are there any impacts to the Memphis sand As stated in the previous response, aquifer? groundwater has been sampled in the monitoring well at the Site, and indicates the presence of PCE in the intermediate aquifer. The information available to date indicates the intermediate aquifer and the Memphis Sand Aquifer are likely interconnected beneath the Site. One of the objectives of the RI is to determine the extent of the Site- related PCE groundwater contamination in the interconnected intermediate aquifer/Memphis Sand Aquifer. Are there threats to the safety of students at There has not been any data collected at the the University and pets at the veterinarian’s Site that indicates a potential threat to any office (both sit in close proximity to the Site)? University students or pets at the nearby veterinarian’s office. The EPA will collect data and develop a risk assessment during the upcoming RI to evaluate potential health threats to humans and animals living in the area around the Site due to PCE contamination at the Site. Runoff (pictured in figure 2) from the The EPA does not take any responsibility for driveway never occurred prior to the the driveway that McDonald’s built on their construction of the McDonald’s. Does the property or its maintenance. The EPA took Agency assume responsibility for this precautions during the Removal Action to driveway and its maintenance? Potential prohibit the runoff of PCE-contaminated soil runoff of contamination prior to and during from the Site. The EPA will take proper the removal. precautions during the upcoming RI to prohibit the runoff of PCE-contaminated soil from the Site. Will other potential hazardous waste sites be The funding that the EPA has been approved addressed simultaneously? to conduct the RI/FS is site-specific, and cannot be used to investigate other sites. Likewise, any funding that might be needed
______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 11 in the future to remediate the FCC site cannot be used to remediate other sites.
______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 12 Section 4.0 Community Involvement Programs and Activities
When establishing the objectives for a site-specific community involvement program, several factors are considered, including federal requirements that assess the nature and extent of known or perceived site contaminants and known community concerns and requests.
To be effective, the community involvement program must be designed to meet the community’s need to know, give information in a timely manner and accommodate the community’s interests and its willingness to participate in decision-making processes. Information must be provided in language the public can understand. Based on demographics obtained from the U.S. Census Bureau and interviews, all information will be provided in English.
To meet the needs of the community; to respond to information obtained during the community interviews conducted in August and September 2016, March and May 2017; and to meet federal requirements, the following objectives have been established for community involvement efforts:
Enlist the support and involvement of local officials and community leaders Monitor community interest in the Site and respond accordingly Keep the community well informed of ongoing and planned Site activities Provide follow-up explanations about technical Site activities and findings Provide opportunities for public input on key decisions.
The Agency has implemented, or will implement the activities described below to meaningful and actively engage the community in decisions regarding the cleanup of the Site. These activities are intended to provide opportunities for communication between the community and the Agency and address key concerns and questions raised during the community interviews conducted.
Maintain Point of Contact. The EPA and TDEC have designated points of contact for the project (See Appendices A and C). Current contact information will be updated as necessary and provided on all written and electronic information. The community will be notified of any contact information changes.
Establish a Toll-Free Number for Residents to Ask Questions and Receive Information. Residents can call 877-718-3752 as questions or concerns arise, rather than waiting for a public meeting or to receive written information. EPA will publish this general toll-free number periodically in local newspaper advertisements and will include this general toll-free number on the website, in fact sheets and other EPA communications with the public.
Maintain Communication with Local Officials, Agencies and Community Residents. The EPA interviewed community members, local officials and other stakeholders during the community interviews and will continue to maintain communication with them throughout the Superfund cleanup process.
______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 13 Update and Maintain the Site Mailing List. A mailing list of local residents, organizations, businesses and officials has been established for the Site. This list will be used for mailing fact sheets, Site updates, invitations to public meetings and events, and other Site-related information to the community. The list will be updated regularly to reflect address changes, changes in elected officials and to add new people interested in Site activities. An email list will also be established and regular updates will be provided as appropriate.
The Site mailing list is used to ensure that those that do not have access to the Internet or other information sources still have a way to receive site information and be notified about important meetings. If a community member is interested in being placed on the email or mailing list they can contact the current CIC, Kerisa Coleman (see Appendix A for contact information).
Prepare and Distribute Fact Sheets, Newsletters and Site Updates. Fact sheets, newsletters and Site updates summarizing current information about the Site and describing upcoming activities may be prepared and distributed to those on the Site mailing and email lists. These documents are written in non-technical language and are typically prepared to coincide with important Site activities.
The Agency uses these types of documents to provide the community with detailed information in a relatively quick, simple and easy-to-understand manner. In addition to being distributed to individuals on the email or mailing list, fact sheets and Site updates are also placed in the information repository.
Establish and Maintain a Site-Specific Information Repository. The EPA has set up a local information repository at the Benjamin L. Hooks Central Library, located at 3030 Poplar Avenue in Memphis. The repository is a reference collection of Site information available to the public for reading and photocopying. Documents include fact sheets, technical reports, the CIP, general Superfund information and other documents. New documents about the Site will be added as they become available. Information repositories provide residents with local access to Site information in forms that can be easily read and photocopied for future use.
Establish and Maintain the Administrative Record. A copy of the Administrative Record for the Site will be found at the Benjamin L. Hooks Central Library. The EPA will update the Administrative Record as necessary. The Administrative Record provides residents with all documents the EPA uses and considers to make decisions about the Superfund site cleanup.
Conduct Public Meetings and Information Sessions. Public meetings and information sessions are typically held to communicate information and to solicit questions and input from the community. The purpose of the meeting should dictate the forum and the frequency. The achievement of certain project milestones or discovery of new information may warrant a more formal public meeting with presentations of technical information by the EPA and others as necessary. During ongoing Site work, information sessions may be needed to keep the community informed of Site progress, answer resident questions about ongoing work and obtain information about the resident perception and concerns.
______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 14 Develop and Distribute News Releases and Public Notices. The Agency will prepare and release announcements to local newspapers such as the Commercial Appeal to provide information about events such as opportunities for public input, significant Site investigation findings, completion of major milestones, important scheduling information and other pertinent Site-related information.
News releases allow the Agency to reach large audiences quickly. News releases and public notices are typically published to announce major events such as comment periods, public meetings and major milestones such as the selection of a cleanup plan. Copies of the news releases and public notices will also be available in the Information Repository and on the website.
Solicit Community Input During Public Comment Periods. The Agency will hold public comment periods to give community members an opportunity to review and comment on key decisions. Before a final cleanup plan is selected for the Site, a public comment period will be held to allow interested residents an opportunity to review and comment on its proposed plan. The Agency will consider the community’s input before selecting a final cleanup plan. Response to public comments will be summarized in a document called a responsiveness summary, which will be placed in the Site Information Repository.
Evaluate Community Involvement and Outreach Efforts and make Adjustments as Warranted. This CIP was designed to consider Site and community specific factors as well as to comply with federal requirements. Community concerns, the objectives of the community involvement program for the Site, and specific activities to address these concerns in this CIP were based to a large extent on information obtained during interviews with local residents and officials. The Agency recognizes that changes in areas such as community perceptions, information needs and population demographics can occur over time and that such changes may necessitate a revised approach to conducting involvement activities. For this reason, as well as to determine whether the activities described in this CIP are achieving their intended objectives, periodic reviews will be done to determine whether additional activities are warranted or whether changes to current methods of implementing the activities outlined in this CIP as necessary.
Table 4.1 on the next page provides a list of community involvement activities and the status of the activities. Where appropriate, comments or other information is provided for each of the activities.
Table 4.1 Status Summary for Community Involvement Activities
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Community Involvement Status Notes Activities
Establish and Maintain Point of Contact Completed See Appendix A
Establish a Toll-Free Number for Completed; publish on written 1-877-718-3752 Residents To Ask Questions and materials Receive Information
Maintain Communication with Local Ongoing as needed Officials, Agencies, and Community Residents
Update and Maintain Site Mailing and Completed; update as needed Email Lists
Prepare and Distribute Fact Sheets, Ongoing as needed Newsletters, and Site Updates
Establish and Maintain a Site- Completed; audits of the See Appendix B for location Specific Information Repository information repository are performed, at minimum, every three to five years or as needed.
Establish and Maintain the Completed; update as needed See Appendix B for location Administrative Record
Provide Site and Superfund Completed; update as needed https://cumulis.epa.gov/s information on the Internet upercpad/cursites/csitinf o.cfm?id=0402275
Provide Technical Assistance Grant Completed EPA provided an overview during first (TAG) information public meeting October 6, 2016 NPL Meeting held October 6, 2016 Conduct Public Meetings and Ongoing as needed Availability Session(s) held August 3, Information Sessions 2017
Develop and Distribute News Ongoing as needed Releases
Proposal to the NPL NPL Comment period Solicit Community Input During When proposed cleanup plan is September 8, 2016 - November 7, 2016 Public Comment Periods completed Evaluate Community Involvement and Periodically throughout the Outreach Efforts and Make Adjustments cleanup process (at least every to the CIP as Warranted three years)
______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 16 Section 5.0 What is Superfund?
Figure 3 (Superfund Process) Superfund is an environmental cleanup program enabled by a federal law enacted in 1980 known as the Comprehensive Environmental Response, Compensation, and Liability Act or CERCLA. In 1986, another law, the Superfund Amendments and Reauthorization Act (SARA) reauthorized CERCLA to continue Superfund cleanup activities. The CERCLA law gives EPA the authority to require those parties responsible for creating hazardous waste sites to clean those sites up or to reimburse the government if EPA cleans up the site. EPA requires responsible parties to clean up hazardous waste sites through administrative orders, consent decrees and other legal settlements. EPA is authorized to enforce the Superfund laws in all 50 states and in U.S. territories. Superfund site identification, monitoring and response activities are coordinated with state, tribal, and territorial environmental protection or waste management agencies. The Superfund program encourage active dialogue between communities affected by the release of hazardous substances and all of the agencies responsible for carrying out or overseeing cleanup actions. EPA follows a step-by-step process, as depicted in Figure 1 above, to determine the best way to clean up a polluted site and protect human health and the environment. EPA considers community involvement to be an important part of the Superfund program and opportunities for community involvement occur throughout the procedure. Visit these EPA websites for more information on the Superfund process:
Superfund: www.epa.gov/superfund/index.htm Cleanup Process: www.epa.gov/superfund/cleanup/index.htm Community Involvement: www.epa.gov/superfund/community/index.htm
______Former Custom Cleaners Site June 2017 Community Involvement Plan Page 17 Section 6.0 Environmental Justice
The Environmental Justice Act of 1992 obligates federal agencies to make environmental justice part of its overall mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its program, policies, and activities on minority populations and low-income populations. Following this order, the Office of Environmental Equity within EPA became the Office of Environmental Justice. EPA’s Office of Environmental Justice ensures that all people, regardless of race, color, national origin, or income, enjoy the same degree of protection from environmental and health hazards and equal access to the decision-making process for a healthy living, learning and work environment. Ensuring environmental justice means not only protecting human health and the environment for everyone, but also ensuring that all people are treated fairly and are given the opportunity to participate meaningfully in the development, implementation, and enforcement of environmental laws, regulations, and policies.
Based on an EJ analysis conducted on May 18, 2017, there are no potential EJ concerns regarding the area surrounding the FCC Site.
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Section 7.0 Site Description
This section provides the Site location and description and summarizes the Site investigation and cleanup activities conducted to date at the Site.
7.1 Site Background/Location
The FCC Site (see Figure 4) is a commercially zoned property located at 3517 Southern Avenue in Memphis, Shelby County, Tennessee and is situated in a residential and commercial area of east Memphis. The area is undergoing significant redevelopment, including the development of the property adjoining the western boundary of the Site into the popular fast food chain, McDonald’s. The FCC Site is bordered to the north by Southern Avenue, to the east by Minor Road, to the south by Spottswood Avenue and to the West by South Highland Avenue. The FCC facility operated as a dry cleaner for about 45 years from approximately 1950 until the mid- 1990s. From the mid-1990’s to 2014, the FCC facility building housed Sharri’s Discount Arts until the building was torn down and removed in 2016. The FCC Site is 0.62 acres in size, and currently consists of one building, a parking lot, and an open area where the former FCC facility building was located. The area around the FCC Site has high pedestrian traffic due to its proximity to the University of Memphis. The nearest residential properties include apartment complexes located approximately 375 feet to the south of the Site.
Site
Figure 4 (FCC Site Location Map)
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7.2 Site Inspections and Cleanup Activities
As a result of complaints, TDEC conducted an initial assessment investigation in 2013. The investigation documented that PCE was used during Custom Cleaners operation at the Site. In 2014, TDEC conducted a Preliminary Assessment (PA) at the Site. The PA revealed the presence of PCE vapor under the building slab. In March 2015, TDEC conducted Site Inspection (SI) sampling activities at the Site. Results for subsurface soil, soil gas and groundwater samples collected during the SI revealed the presence of tetrachloroethylene, also known as perchloroethylene (PCE). Due to the elevated concentrations of PCE and the proximity of the Site to the City of Memphis drinking water supply, TDEC and the EPA’s Remedial Program referred the Site to the Emergency Response, Removal and Prevention Branch (ERRPB).
In December 2015, EPA’s Remedial Program presented the Site to the Regional Decision Team (RDT) for possible listing on the NPL. Simultaneously, the Emergency Response, Removal & Prevention Branch began taking steps to perform a removal action, which occurred in the Fall of 2016. This included removal of the building and concrete slab and the removal of the highest concentrations of PCE located beneath the building’s slab down to 18 feet below land surface (see front cover photograph).
The FCC Site was proposed for the NPL on September 8, 2016. The FCC Site has not been finalized on the NPL. Beginning in late June 2017, the EPA will initiate the RI fieldwork, and the fieldwork will be completed in August or early September 2017. The objective of the RI is to determine the nature and extent of site-related contamination in soil and groundwater at the Site, assess the potential risks associated with the contamination, conduct a Feasibility Study (FS) to develop and evaluate options to address the contamination. Once EPA and TDEC evaluate each option, the preferred option is selected to address the contamination and presented to the public for their comment.
The EPA is proceeding under the Superfund Program, which is primarily a civil statute designed to address cleanup of contaminated sites by the people responsible for that contamination. The EPA has identified one Potentially Responsible Party (PRP) at the Site and is investigating former business owners and operators.
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Appendix A EPA Regional Contacts
Ken Mallary Kerisa Coleman Remedial Project Manager Community Involvement Coordinator U.S. EPA, Region 4 U.S. EPA, Region 4 SF Restoration and SF Enforcement and Site Evaluation Branch Community Engagement Section 61 Forsyth St., SW 61 Forsyth St., SW Atlanta, GA 30303 (404) 562-8831 (404) 562-8802 [email protected] [email protected]
Steve Spurlin Federal On-Scene Coordinator U.S. EPA, Region 4 SF Emergency Response, Removal & Prevention Branch 61 Forsyth St., SW Atlanta, GA 30303 (731) 394-8996 [email protected]
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Appendix B Local Officials
City of Memphis Shelby County
Mayor Mayor Jim Strickland Mark Luttrell, Jr. City Hall 160 N. Main Street 125 N. Main Street Suite 100 Room 700 Memphis, TN 38103 Memphis, TN 38103 (901) 222-2000 (901) 636-6000 [email protected] [email protected] District 13 County Commissioner Director of Communications Steve Basar Ursula Madden Vasco A. Smith, Jr. Administration (901) 576-6011 Building 160 N. Main Street [email protected] Suite 600 Memphis, TN 38103 District 5 Commissioner (901) 222-1000 Worth Morgan 125 N. Main Street Shelby County Health Department Room 514 Tamal Chakraverty MD MPH CPH Memphis, TN 38103 Epidemiologist (901) 636-6786 814 Jefferson, Rm. 203 [email protected] Memphis, TN 38105 (901) 222-9247 Super 9 District Commissioners 125 N. Main Street Room 514 Memphis, TN 38103 (901) 63-6786
Position 1 Kemp Conrad [email protected]
Position 2 Philip Spinosa, Jr. [email protected]
Position 3 Reid Hedgepath [email protected]
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Appendix C State Officials
Governor Merrie Embry Bill Haslam TDEC Environmental Consultant State Capitol, 1st Floor Division of Remediation 600 Charlotte Avenue Memphis Environmental Field Office Nashville, TN 37243 8383 Wolf Lake Drive (615) 741-2001 Bartlett, TN 38133 (901) 371-3151 Senate District 33 [email protected] Senator Reginald Tate 301 6th Avenue North Tennessee Department of Health Suite 320, War Memorial Bldg. Joe George, PG Nashville, TN 37243 Environmental Health Assessor (615) 741-2509 Environmental Epidemiology Program Andrew Johnson Tower, 3rd Floor House District 93 710 James Robertson Parkway Rep. G.A. Hardaway Nashville, TN 37243 301 6th Avenue North (615) 741-7247 Suite 37, Legislative Plaza [email protected] Nashville, TN 37243 (615) 741-5625
Tennessee Department of Environment and Conservation RonnéAdkins, Ph.D. Regional Director of External Affairs Office of External Affairs Memphis Environmental Field Office 8383 Wolf Lake Drive Bartlett, TN 38133 (901) 371-3001 [email protected]
Jordan English Manager Division of Remediation/West Tennessee Regional Office 8383 Wolf Lake Drive Barlett, TN 38133 (901) 371-3039 [email protected]
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Appendix D Federal Elected Officials
U.S. Senate U.S. House of Representatives
Senator Bob Corker Representative District 9 Dirksen Senate Office Building Steve Cohen SD-425 2404 Rayburn HOB Washington, DC 20510 Washington, DC 20515 Phone: 202-224-3344 Phone: 202-225-3265
Memphis Office Location Memphis Office Location 100 Peabody Place, Suite 1125 Clifford Davis-Odell Horton Memphis, TN 38103 Federal Building Phone: 901-683-1910 167 North Main Street Suite 369 Senator Lamar Alexander Memphis, TN 38103 455 Dirksen Senate Office Building (901) 544-4131 Washington, DC 20510 Phone: 202-224-4944
Memphis Office Location Clifford Davis-Odell Horton Federal Building 167 North Main Street #1068 Memphis, TN 38103 Phone: 901-544-4131
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Appendix E Environmental and Active Citizens Groups
Tennessee Chapter of Sierra Club 2600 Poplar Ave. Memphis, TN 38112 Phone: 901-324-7757
Protect Our Aquifer www.protectouraquifer.org
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Appendix F Media Contacts
Television Stations:
WMC-TV Action News 5 WRVR-FM 104.5 1960 Union Avenue 1835 Moriah Woods Boulevard #1 Memphis, TN 38104 Memphis, TN 38117 (901) 726-0555 (901) 384-5900
WREG News Channel 3 WHRK-FM K97.1 803 Channel 3 Drive 2650 Thousand Oaks Boulevard #4100 Memphis, TN 38103 Memphis, TN 38118 (901) 543-2333 (901) 535-9797
Fox 13 Memphis WHBQ Newspapers: 485 South Highland Street Memphis, TN 38111 The Commercial Appeal (901) 320-1313 495 Union Avenue Memphis, TN 38103 WATN-TV Local 24 (901) 529-2345 1725 North Shelby Oaks Drive Suite 101 Memphis, TN 38133 (901) 321-7673
Radio Stations:
Hot 107.1 6080 Mount Moriah Road Memphis, TN 3815 (901) 375-9324
WEVL-FM 98.9 518 South Main Street Memphis, TN 38112 (901) 528-0560
WGKX-KIX 106 5629 Murray Avenue Memphis, TN 38119 (901) 682-1106
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Appendix G Meeting Locations
Memphis Botanic Garden 750 Cherry Road Memphis, TN 38117 (901) 636-4100
University of Memphis 3720 Alumni Avenue Memphis, TN 38152
Old Highland Branch Library 460 S. Highland Street Memphis, TN 38111
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Appendix H Repository Locations
Local Repository:
Benjamin L. Hooks Central Library 3030 Poplar Avenue Memphis, TN 38111 (901) 415-2700
Hours of Operation: Monday – Thursday 10 a.m. – 8 p.m. Friday and Saturday 10 a.m. – 5 p.m.
EPA Region 4 Repository:
U.S. Environmental Protection Agency 61 Forsyth Street, SW Sam Nunn Atlanta Federal Center, 9th Floor Atlanta, GA 30303 (404) 562-8190 [email protected]
Hours Open to Public: Monday – Friday 8 a.m. – 3:45 p.m.
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Appendix I Glossary
Administrative Record: All documents which EPA considered or relied on in selecting the response action at a Superfund site, culminating in the record of decision for remedial action or, an action memorandum for removal actions, usually placed in the information repository near the Site.
Aquifer: A body of permeable rock that can contain or transmit water.
Baseline Risk Assessment: An analysis of the potential adverse health effects (current or future) caused by hazardous substance releases from a site in the absence of any actions to control or mitigate these releases (i.e., under an assumption of no action).
Cleanup: Actions taken to correct a release or threatened release of hazardous substances that could affect public health and/or the environment.
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): Also known as Superfund, is a federal law passed in 1980 and modified in 1986 by the Superfund Amendment and Reauthorization Act (SARA); the act created a trust fund, to investigate and cleanup abandoned or uncontrolled hazardous waste sites. The law authorizes the federal government to respond directly to releases of hazardous substances that may endanger public health or the environment. EPA is responsible for managing the Superfund.
Feasibility Study: Study conducted after the Remedial Investigation to determine what alternatives or technologies could be applicable to the site-specific contamination.
Groundwater: The supply of fresh water found beneath the Earth’s surface (usually aquifers) which is often used for supplying wells and springs.
Hazard Ranking System (HRS): A numerical screening system used by EPA to evaluate the relative potential risks to public health and the environment form releases or threatened releases of hazardous substances from contaminated sites. Data from preliminary site investigations is used to develop a site score from 0 to 100 indicating the potential for substances released in ground water, air, surface water, or soil to affect people on or near the site. The HRS score is the principal factor used to determine if a site qualifies for the National Priorities List.
Information Repository: A file that contains accurate, up-to-date documents on a Superfund site. The file is usually located in a public building (school, library, or city hall) convenient for local residents.
National Contingency Plan: The Federal Regulation that guides the Superfund program. The NCP was revised in February 1990.
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National Priorities List: The list of hazardous waste sites in the United States eligible for long- term remedial action (cleanup) financed under the federal Superfund program.
Non-Time Critical Removal Action: Activities used to handle emergency oil spills or chemical releases and short-term responses that are completed in more than 120 days. Because non-time- critical sites do not present an immediate threat to public health or safety, the EPA has time to prepare an engineering evaluation and cost analysis analyzing alternatives for the site.
Proposed Plan: A Superfund public participation fact sheet which summarizes cleanup alternatives, the rationale for their selection, and presents the best method for cleanup (preferred alternative) for public comment.
Public Comment Period: The time allowed for the public to express its views and concerns regarding an action by EPA (e.g. a Federal Register Notice of proposed rule-making, a public notice of a draft permit, or a Notice of Intent to Deny).
Record of Decision (ROD): A public document describing EPA's rationale for selection of a Superfund cleanup alternative.
Remedial Action - Remedial action (RA) follows the Remedial Design phase and involves the actual construction or implementation stage of the cleanup.
Remedial Alternative: A potential approach to prevent or mitigate contamination problems, defined in terms of a remedial action technology option or combination of options.
Remedial Design: Remedial design is the phase in the Superfund site cleanup process in which the technical specifications for cleanup remedies and technologies are developed.
Remedial Investigation/ Feasibility Study (RI/FS): A two-part investigation conducted to fully assess the nature and extent of the release, or threat of release, of hazardous substances, pollutants, or contaminants, and to identify alternatives for cleanup. The Remedial Investigation gathers the necessary data to support the corresponding Feasibility Study.
Remedy: Long-term action that stops or ssubstantially reduces a release or threat of a release of hazardous substances.
Responsiveness Summary: A summary of oral and written comments received by EPA during a comment period on key EPA documents, and EPA’s responses to those comments. The responsiveness summary is a key part of the ROD, highlighting community concerns for EPA decision-makers.
Soil Gas: Gases found in the air space between soil components. The primary natural soil gases include nitrogen, carbon dioxide and oxygen. The oxygen is critical because it allows for respiration of both plant roots and soil organisms.
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Superfund: The program operated under the legislative authority of CERCLA and SARA that funds and carries out EPA long-term removal and remedial activities.
Time Critical Removal Action: Activities used to handle emergency oil spills or chemical releases and short-term responses. Emergency actions are taken and completed in 120 days to eliminate immediate risks and ensure public safety.
Technical Assistance Grant (TAG): The purpose of the TAG is to increase the level of understanding and participation in the Superfund process among community members and provide independent technical review of Site documents. As part of the Administrative Order, a grant in the amount of $50,000 is awarded to a community group (that is directly affected by the Superfund Site) that is responsible for hiring and managing a Technical Advisor, to assist the affected community. The community group is also responsible for disseminating information to additional stakeholders or other affected communities.
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Appendix J Acronym List
ACS American Community Survey ATSDR Agency for Toxic Substances Disease Registry CAESAR Center for Applied Earth Science and Engineering Research CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CIC Community Involvement Coordinator CIP Community Involvement Plant EPA United States Environmental Protection Agency EJ Environmental Justice FS Feasibility Study FCC Former Custom Cleaners HRS Hazard Ranking System MLGW Memphis Light, Gas and Water NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priority List OSC Federal On-Scene Coordinator PA Preliminary Assessment PCE Tetrachloroethylene RI Remedial Investigation RPM Remedial Project Manager RSE Removal Site Evaluation SARA Superfund Amendments and Reauthorization Act SI Site Investigation TAG Technical Assistant Grant TDEC Tennessee Department of Environment & Conservation
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Appendix K References
1. City of Memphis (2017). Retrieved from www.memphistn.gov.
2. City-data. Memphis, Tennessee. Retrieved from http://www.city-data.com.
3. United States Environmental Protection Agency, Region 4. Community Interviews, Former Custom Cleaners. August 2016 through May 2017.
4. United States Environmental Protection Agency, Office of Superfund Remediation and Technology Innovation, Community Involvement and Program Initiative Branch. Superfund Community Involvement Handbook, Washington, D.C., January 2016. EPA 540-K-02-015.
5. United States Environmental Protection Agency, Office of Environmental Justice. EJSCREEN Report (Version 2016), May 2017.
6. U.S. Census Bureau (2015). Quick Facts 2010-2015. Retrieved from http://www.census.gov/quickfacts.
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Appendix L Attachments
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ATSDR TETRACHLOROETHYLENE AGENCY FOR TOXIC SUBSTANCES ANO DISEASE REGISTRY CAS # 127-18-4
Agency for Toxic Substances and Disease Registr~ ToxF:\Qs September 1997
This fact sheet answers the most frequently asked health questions (FAQs) about tetrachloroethylene. For more information, caU the ATSDR Information Center at 1-888-422-8737. This fact sheet is one in a series of summaries about hazardous substances and their health effects. It's important you understand this information because this substance may harm you. The effects of exposure to any hazardous substance depend on the dose, the duration, bow you arc exposed, personal traits and habits, and whether other chemicals are present.
IDGHLIGHTS: Tetrachloroethylene is a manufactured chemical used for dry cleaning and metal degreasing. Exposure to very high concentrations of tetrachloroethylene can cause dizziness, headaches, sleepiness, confusion, nausea, difficulty in speaking and walking, unconsciousness, and death. Tetrachloroethylene has been found in at least 771 of the 1,430 National Priorities List sites identified by the Environmental Protection Agency (EPA).
What is tetrachloroethylene? How might I be exposed to tetrachloroetbylene? (Pronounced tet'rn-klor' o-eth':;,-len') 0 When you bring clothes from the dry cleaners, they will release small amounts of tetrachloroethylene into the air. Tetrachloroethylene is a manufactured chemical that is widely used for dry cleaning of fabrics and for metal-degreas D When you drink water containing tetrachloroethylene, you are exposed to it. ing. It is also used to make other chemicals and is used in some consumer products. Other names for tetrachloroethylene include perchloroet How can tetrachloroethylene affect my health? hylene, PCE, and tetrachloroethene. It is a nonflammable High concentrations of tetrachloroethylene (particularly liquid at room temperature. It evaporates easily into the air in closed, poorly ventilated areas) can cause dizziness, head and has a sharp, sweet odor. Most people can smell tetra ache, sleepiness, confusion, nausea, difficu lty in speaking and chloroethylene when it is present in the air at a level of I part walking, unconsciousness, and death. tetrachloroethylene per million parts of air ( I ppm) or more, although some can smell it at even lower levels. Irritation may result from repeated or extended skin con tact with it. These symptoms occur almost entirely in work (or What happens to tetrachloroethylene when it hobby) environments when people have been accidentally enters the environment? exposed to high concentrations or have intentionally used 0 Much of the tetrachloroethylene that gets into water or tetrachloroethylene to get a "high." soil evaporates into the air. In industry, most workers are exposed to levels lower than 0 Microorganisms can break down some of the tetrachloro those causing obvious nervous system effects. The health ethylene in soil or underground water. effects of breathing in air or drinking water with low levels of 0 In the air, it is broken down by sunlight into other chemi tetrachloroethylene are not known. cals or brought back to the soil and water by rain. 0 It does not appear to collect in fish or other animals that Results from some studies suggest that women who work live in water. in dry cleaning industries where exposures to tetrachloroethyl-
l'.S. DEP\RT\IE'\T OF IIE \I.TII .\'\D Ill \I.\'\ SER\'ICES, Puhlic lkalth St·nin· .\gt•nt·~ for To\ic Suhstant·t·s and Disl':ISl' Rl·gistr~ TETRACHLOROETHYLENE Page 2 CAS # 127-18-4
ToxFAQs Internet home page ,·ia WWW is http://\\W\\.atsdr.cdc.gO\-/toxfa ene can be quite high may have more menstrual problems and formed at special laboratories that have the right equipment. spontaneous abortions than women who are not exposed. Because exposure to other chemicals can produce the However, it is not known iftetrachloroethylene was respon same breakdown products in the urine and blood, the tests for sible for these problems because other possible causes were breakdown products cannot determine if you have been ex not considered. posed to tetrachloroethylene or the other chemicals. Results of animal studies, conducted with amounts much higher than those that most people are exposed to, show that Has the federal government made tetrachloroethylene can cause liver and kidney damage. Ex recommendations to protect human health? posure to very high levels of tetrachloroethylene can be toxic The EPA maximum contaminant level for the amount of to the unborn pups of pregnant rats and mice. Changes in tetrachloroethylene that can be in drinking water is 0.005 mil behavior were observed in the offspring of rats that breathed ligrams tetrachloroethylene per liter of water (0.005 mg/L). high levels of the chemical while they were pregnant. The Occupational Safety and Health Administration (OSHA) has set a limit of I 00 ppm for an 8-hour workday over How likely is tetrachloroethylene to cause a 40-hour workweek. cancer? The National institute for Occupational Safety and Health The Department of Health and Human Services (DHHS) (NIOSH) recommends that tetrachloroethylene be handled as a has determined that tetrachloroethylene may reasonably be potenti al carcinogen and recommends that levels in workplace anticipated to be a carcinogen. Tetrachloroethylene has been air should be as low as possible. shown to cause liver tumors in mice and kidney tumors in male rats. Glossary Carcinogen: A substance with the abili ty to cause cancer. Is there a medical test to show whether I've been CAS: Chemical Abstracts Service. exposed to tetrachloroetbylene? Milligram (mg): One thousandth ofa gram. One way of testing for tetrachloroethylene exposure is to Nonflammable: Will not burn. measure the amount of the chemical in the breath, much the References same way breath-alcohol measurements are used to determine This ToxFAQs infom,ation is taken from the 1997 Toxico the amount of alcohol in the blood. logical Profile for Tetrachloroethylene (update) produced by Because it is stored in the body's fat and slowly released the Agency for Toxic Substances and Disease Registry, Public into the bloodstream, tetrachloroethylene can be detected in Health Service, U.S. Department of Health and Human Ser the breath for weeks following a heavy exposure. vices, Public Health Service in Atlanta, GA. Tetrachloroethylene and trichloroacetic acid (TCA), a breakdown product of tetrachloroethylene, can be detected in the blood. These tests are relatively simple to perfonn. These tests aren't available at most doctors' offices, but can be per- Where can I get more information? For more information, contact the Agency for Toxic Substances and Disease Registry, Division of Toxicology, 1600 Clifton Road NE, Mailstop F-32, Atlanta, GA 30333. Phone:1- 888-422-8737, FAX: 770-488-4 178. ToxFAQs Internet address via WWW is http://www.atsdr.cdc.gov/toxfaq.html ATSDR can tell you where to find occupati onal and environmental health clinics. Their specialists can recognize, evaluate, and treat illnesses resulting from exposure to hazardous substances. You can also contact your community or state health or environmental quality department if you have any more questi ons or concerns. h •tkral lkc~clin:.! l'rn:.!r:tlll O Printed on Rl·c~cll'd P:tpl·r • U.S. Environmental Protection Agency Former Custom Cleaners Site Memphis, Tennessee July 2017 This information summarizes the history of the Former Custom Cleaners Public availability session to (FCC) Site, provides an overview of the Superfund program and removal discuss the Superfund actions taken at the Site. cleanup Thursday August 3, Ba ckground 2017 9:00 a.m. to 12:00 The FCC Site is a former dry cleaner which operated from about 1950 until noon and the mid-1990s. The Site is a commercially zoned property located at 3517 5 p.m. to 7 p.m. Southern Avenue in Memphis, Shelby County, Tennessee in a residential Old Highland Branch Library and commercial area of east Memphis. Past operations have impacted 460 S. Highland Street subsurface soils and groundwater with the solvent perchloroethylene Memphis, Tennessee (PCE) . While there has been no impact to date, there is potential for the PCE contaminated groundwater to impact the municipal drinking water wells within t he Memphis light, Gas and Water (MLGW) Sheahan Well Field, due to the Site's close proximity. The FCC Site is bordered to the north by Southern Avenue, to the east by Minor Road, to the south by Spottswood Avenue, and to the w est by South Highland Avenue. The area surrounding the Site is undergoing significant redevelopment, including t he development of the property adjoining the western boundary of the Site into a popular fast food restaurant. EPA's Actions Taken The U.S. Environmental Protection Agency (EPA), in conjunction with the Tennessee Department of Environment and Conservation (TDEC), have conducted several actions at the Site. • 2013 - Initial investigation conducted revealed that PCE was used during the cleaner's tenure at the Site. • 2015 -EPA supported the TDEC Site Inspection (SI) sampling activities at the Site that included the collection of subsurface soil samples, soil gas samples and groundwater samples. • 2016 - Due to the elevated PCE concentrations and the proximity of the Site to the City of Memphis drinking water supply, EPA performed an evaluation which expanded the subsurface sampling conducted during the 2015 TDEC SI sampling event . • EPA issued an Action Memorandum which provides rationale for removal action that is needed to address conta mination at the Site. • In September, EPA conducted a removal action which included removal of the building and concrete slab and t he removal of the highest concentrations of PCE located beneath the building' s slab to approximately 18 feet below land surface. • On September 9, 2016, EPA proposed the Site be placed on the National Priorities List (NPL) and is expected to be finalized in July 2017. ------l(l)a______Next Steps The EPA is proceeding with the investigation and cleanup of the FCC Site under the Superfund Program. EPA will perform the Remedial Investigation/Feasibility Study (RI/FS), while TDEC provides support during this process. In late June 2017, the EPA initiated the RI fieldwork and expects to be completed by September 2017. The objective of the RI/FS is to determine the nature and extent of site-related contamination in soil and groundwater at the Site, assess the potential risks associated with the contamination, develop and evaluate options to address the contamination and select the preferred cleanup option. At the completion of the RI/FS, there will also be a meeting for the public to ask questions and comment on the proposed cleanup plan. The cleanup plan and associated documents related to the FCC Site will be made available in the Administrative Record of the Information Repository located at the Benjamin L. Hooks Central Library, 3030 Poplar Avenue, Memphis, Tennessee. The EPA will host two availability sessions to provide information to the public on the Superfund process and progress being made during the RI on Thursday, August 3, 2017 at the Old Highland Branch Library. The first session begins at 9:00 a.m. and is expected to end at noon. The second session begins at 5:00 p.m. and is expected to end at 7:00 p.m. The public is encouraged to attend to learn more about the Site and the investigation and cleanup process. FOR M ORE INFORMATION EPA Remedial Project Manager Information Repository Ken Mallary (404) 562-8802 Benjamin L. Hooks Central Library [email protected] 3030 Poplar Avenue Memphis, TN 38111 EPA Community Involvement Coordinator Ke risa Coleman (404) 562-8831 [email protected] 2 FOR MORE INFORMATION U.S. Environmental Protection Agency EPA Remedial Project Manager John Nolen National Priorities Listing of the &EPA 404-562-8750 Nt1k11 Jtlhll !I ~.-p.1 gt I\ Former Custom Cleaners Site EPA National Priorities list Coordinator Memphis, Tennessee Cathy Amoroso 404-562-8637 ;Ulh'llhl) (';Uh} .!!.'-'P;l gt)\ Number 2 September 2016 EPA Community Involvement Coordinator Background Kerisa Coleman Public Meeting Scheduled (404) 562-8831 This fact sheet con1ains information regarding 1he proposed A public meeting to discuss the NPL listing 1o.1tll.'t1l,lll ~l'll'.'o,l}'i..'1),1 g,1, addition of1he Former Custom Cleaners si1e (FCC) 10 lhe National Priorities List (NPL) by the U.S. Environmental and remedial process for the Former Protection Agency (EPA). The FCC site is a fonner d1y cleaning Custom Cleaners site has been scheduled. lnfonnation Repository business which operated from approximately 1950 until the Thursday, October 6, 2016 at 6:00 p.m. mid-1990s. The Site is located in commercially zoned area of Benjamin L. Hooks Central Memphis Botanic Garden Library east Memphis. Tennessee. Past operations have impacted 3030 Poplar Avenue subsurface soils and groundwater "ith the solvent 750 Cherry Road, Memphis, Tennessee perchlorocthylcne (PCE). The FCC site is bordered to the nonh Memphis, Tennessee. 38 11 1 by Southern Avenue. to the east by Minor Road, to the south by The public comment period for NPL listing (901) 4 15-2700 Sponswoood Avenue, and to the west by South Highland is September 9 to November 8, 2016. Avenue. &EPA See page 2 for how to submit comments. l,;n.led Sl.a'.tt Frequently Asked Questions Regarding En• .rcnfT'~n~al Proleeton Agency NPL Listing Rt-p,c;in4 Whar ,s Ille National Pnont,es Lis/? Attn K('nU Co!tm¥\ M• Code 9125 I he Nl'L 1s a hst of serious u11co11trolleJ or abandoned ha,;udou, \\a,te site, 1Jc111111ed for 111\·cstig:uion and 1x1ss1blc 51 ro,,-)<:ti Stit'tt S\i'i lon,;•tenn cleanup under Su1>e1fund. an El'/\ program that addresses hawrdou, wa.ste sites The NPI. is mtcnded ACl•n1• GA30)0)·MISO pnmarily 10 guide EPA 111 d~temuniug \\hid, sites need runhcr i1l\c~t1µation and 10 3."\.~C$S lhc nature nnd c~tcnl orpuhlic health and en, ironmcntal risks associated \\ith a site 1·.Pi\ 1s required hy la" to update the NPI. at least once a ycnr (EPA is currc111ly npdatini; the Nl'L two times a )CM) How are sites hsted on the NPL? There nre three \\'ays a s11c is eligible for the NPI.: I. Scores at least 28.50: i\ site ma~ be mdudcd on the NPI. if it seor,:s suflic,ently high 011 the I lazmd Jfank111g System (I IRS). \\hich is a 111a1he111atical fo nnula 1ha1 scr\'Cs as a scoring de\'1cc 10 evalu.11c a sue·s threat to human health or the en, 1ron 111c111 i\s a mancr of EPi\ J>(lhcy. those sitcs th:u score 28.50 or greater on the I IRS are eligible for inclusion on the NPL. Thi s is the most conunon way a site be-comes eligible for the Nl'L I he Fonner Custom Clca,11:1> ~Ile scored a 50 on the I IRS and is be111g propos..-d to the NPL based on i1s I IRS sco,c. 2. Stale Pick: Each ,tatc and territory may designate one top-p110111y site 1c11ardless of scor,:. 3. ,\TSDR llcnlth ,\1h•isory: The Agency for To,ic S11bsta11ccs and Disease Rcg,suy CATSUR) of 1hc US Depanmen1 of I lcalth and Human Services issues a hcahh ad, 1>-0ry that recommends rc111orn1g 1>coplc m, a) from the sne. EPA de1cmunccl 1ha11hc release poses a significant threat 10 pubhc health, and a111ic1pa1cs it "ill be more eos1-cn,-c 11 vc 10 use ns rcmcd,al authonty inst National Priorities Listing of the FonnerCustom OeanersSite, Memplis, T~ National Priorities Listing of the Former Custom Cleaners Site, Memphis, Tennessee 1-Vhat happens to sties on the NPL? The N PL hs1i11g allows El' i\ 10 access additional put,1 ic funding 10 clean u1>a si1c if EPi\ cann(ll find a , iahlc rc~ponsiblc party In p:ty for the \\Ork. L1~1i11g a ..;11c on the NPL s1grmls the :,.Ian ofthe Jon;;-tcrm Supc:1 fund mvcs11!!:it1nn and cleanup pn,ecss ;ll a sue. kno,,,, as the: Rcme,J1al Proccs..; A sue rcm:llll$ on the NPL u11 11I all ckattup 1scomplctct1 :,nil clcanu1) goals h,ivc been aclnc, cd i\ s11ccan be dcktc.t frnrn 1hc Nl'I. aflcrall clc.111111>g,,:,ls arc mel How many NPL sttes are there and u:here can I find more 111fom1atton on tl1e NPL? r,, datc. FPA ha< pro1><,scd l.77~ ;11c;101hc NPI. Of 1hosc, .'91 ha,·c hccn dck1cd fr()m lhc NPI. You 1113) obt.oin a How do I 1c 1. Visit \\\\\\ 1'..'::.ul, 11·11n-. g,\,. lJndcr ··c111cr kc) """' ''1 If)" 1~J >C in EPA-HQ-OLEJ\1-20 16-0436. \\hich i, 1hc dockd number for 1hc Fonner Custom Cleaners .s11c t 111 '·!-c;m.:h" hl ~cie all d0cumcnl"- 2. Con1ac1 thr Region --1 NPI. CPN Source: SbclbyCouftt)' Rq.is1uofOccd.s 201S 3. EPA records can also be viewed at the Si1c's local reposi1ory al the Benjamin L. Hooks Central Library located at 3030 Poplar Avenue, Memphis, Tennessee during nonnal hours of operalion. How might mycommun,ty benefit from bemg on /he NPL? I.isling a site on 1hc NPI. all o\\S EPA to access :1dditit'1nal r~sourccs 10 supporl com11111111t~ 111 ,ohcment 111 the Supcrfond I-low do I subrmt comments to EPA on the proposal ofthe Former Custom Cleaners sue on tlleNPt? procc" Th,-sc include fonnalinn of a Comm1 111il) ,\dd;o" Ci1N111 (CJ\G) and prO\ldi11 i; Technical Assislancc Gra 111s All conuncms mus, bcsuhmi1t1:d in wri1 1n~. and Ml l"T lncl11 1 You may post ~ou1 conuncn1s ;uwn~1111.m:-I~ 011 1ht \~\\\\ r.. ·.::111.1111111-- g, \ \\ch~1h!. p1oduc11,I! reuse Ct,m11 11.·nb l':lll alS<, tx ~uhnu 11 t-·d , -,a cm:11l tfl. ~u1h.:rl 11ml ,h1d.,l..'t:!' t-'(M ~t'' 1M1en 1~1/1 the neAt phase, tile long-term Remedial p,oces.s. st,111 attlle s,te' Fl',\ i, al1 cad) plann ing lhc nc\l phase ,lf 111, esli[!allon \\Ork r,11 the FCC sne. /\dd11ional community 111ec1ings mlll fact l)1 mail a k llcr ,, 11h yom commc111:- addrc!-,.-.cd 10 sh..:cls tm.: ph11111'-'t.l for the near future 10 discu:,~ the Remedial procc~~ and create a 11mdrnc fot Remcdi.11 act i\'i tics. 1\ddi1io11al 111fonna1ion can als1> he ol~:uncd duntll' 1hc public 111cc.1,ng <>n Oc1ober 6, 20 16 a11h c Mc111phi~ llotan,c Garden Docke1Cvvrd 111a1,11, J lcadq11:111cr, loca1cd al 750 l'hcn-y Rmd. Memphis. ·1c1111,-,;;cc :1811 i. I , S Em ,ronmc111;tl Protc1.·11011 Agl'IIC~ CERL'I ,\ I >.c..:kc1 Office. ~305T Where can I /1/ld more mformarton about the solvent pe,chloroerhy/ene (PCE) at tile FCC srte' 1200 Pl'llO~\hm11a A,cuuc. N\V Pcrchloroctl1ylene or Te1rachlorocthylcne is a manufactured chemical used for dry cleaning and is a nonnammable Washm~lo~. DC 20~<,0 colorless liquid. More infom,a1ion on PCE can be found here: V.11at /1appens after rile public comment penod is closed? PCE: l111p \\\\\\ at,dr ,:ck c<1\ ltl\liu1, lliH:l:,.IS pdl EP1\ "111 rrnup1k all comment~ rcccl\ ....c1 anti prepare a rc:-pon:-\! to tho:-c con111u.·111s nus support docu 1111.·11 t mu:-t be co111pk1ed before 1hc ,11c "111:1,lc final on lhc Nl'L ·1h i, 11,uall, occur, the ne" lnnc 1hc NPI. is updmcJ Jnd. in tin~ case. would I><: 1hc :-:p1 111g 1.)1' 20 17 I kmc,·..:1 , it l·PA 1crci,·cs 1;;.rg11 ifi,·ant co111111c 111~ 1hc tinal11.uwn of lhl.' :.,.111.· 111a~ he delayed tn allm, l'Pi\ 11111,, 10 prepare;, rcSJ><>n~c U. S. Environmental Protection Agency National Priorities List &EPA Frequently Asked Questions Frequently Asked Q uestions Regarding NPL Listing What is the National Priorities List? The National Priorities List (N PL) is a list of serious uncontrolled or abandoned hazardous waste sites identified fo r in vestigation and possible long-term cleanup under Superfund. an EPA program that addresses hazardous waste sites. The li st serves as an information and management tool for the Superfund clean up process as required under the Superfu nd law. The NPL is intended primarily lo guide EPA in determining which sites waiTant fu1th er investigation lo assess the nature and extent of public hea lth and environmental risks associated with a site. EPA is required by law to update the NPL at least once a year (EPA is currently updating the NPL two times a year). How are sites listed on the NPL? There are three ways a site is eligible for the NPL: 1. Scores at least 28.50: A site may be included on the PL if it scores sufficiently high on the I lazard Ranking System (HRS). which is a mathematical formula that serves as a scoring device to evaluate a si1e·s threat to human health or the environment. As a matter of EPA policy. those sites that score 28.50 or greater on the HRS are el igible for inclusion on the NPL. This is the most common way a site becomes eligible for the NPL. The Former Custom Cleaners site scored a 50 on the HRS and is being proposed to the NPL based on its HRS score 2. State Pick: Each state and tcr-ritory may designate one top-priority site regardless of score. 3. ATSDR Health Advisory: The Agency for Toxic Substances and Disease Registry (ATSDR) of the U.S. Department of Health and Human Services issues a health advisory that recommends removing people away from the site. EPA determines that the release poses a significant threat to public health. and EPA anticipates it will be more cost-effective to use its remedial authority instead of its emergency removal authority to respond to the site. All of these conditions must be met and the HRS score is not taken into account. What happens to sites on the NPL? The NPL listing allows EPA to access additional public funding to clean up a site if EPA cannot find a viable responsible party to pay for the work. Listing a site on the NPL signals the start of the long-term Superfund investigati on and cleanup process at a site. known as the Remedial Process. A site remains 011 the NPL until all cleanup is completed and cleanup goals have been achieved. A site can be deleted from the NPL afte r all cleanup goals are met. How many NPL sites are there and where can I find more information on the NPL? To date. EPA has proposed 1.774 sites to the NPL. Of those, 391 have been deleted from the NPL. You may obtain additional in formation on the NPL. including a list of the sites and updated information by visiting: -.vww .epa. gov/ su pcrfund/s ites /np I/ How do I review the information that EPA used to support the NPL listing? Sta1ting on September 9. 20 16. materials com pi led by EPA to propose the former Custom Cleaners site to the N PL can be obtained in several ways: I. www.regulations.gov Under .. enter key word or ID .. type in EPA-HQ-OLEM-2016-0436. which is the docket number for the r-onner Custom Cleaners site. Hit --search .. to see all documen ts. 2. Contact the Region 4 NPL Coordinator, Cathy Amoroso. whose contact information is on the last page, to have an electronic copy mailed to you (the materials are too extensive to print). You may also call Cathy Amoroso to make an appointment to view hard copies of the EPA records at the Regional office in Atla nta (address on the last page). How do I submit comments to EPA on the proposal of the Former Custom Cleaners site on the NPL? All comments must be submitted in writing. and MUST include the docket number above. The public comment period will be from September 9, 2016 to November 8, 2016. Specific dates will be provided during the public meeting. You may post your comments anonymously on the ,,w,,·.regulations.!!ov web site. Comments can also be submitted via email to: superrund.docket'<0ega.!!Ov Or mai I a letter 'vvith your comments addressed to: U.S. Environmental Protection Agency EPA Superfund Docket Center Mai I Code :2822 IT 1200 Pennsylvania Avenue, NW Washington. DC 20460 What happens after the public comment period is closed? EPA will compile all comments received and prepare a response to those comments. This support document must be completed before the site is made final on the PL. This usually occurs the next time the NPL is updated. and in this case would be the spring of 201 7. However. if EPA receives significant comments the finalization of the site may be delayed to allow EPA time to prepare a response. How might my community benefit from being on the NPL? Listing a site on the NPL allows EPA 10 access additional resources to support community involvement in the Superfund process. These include formation or a Community Adv iso1y Group (CAG) and providing Technical Assistance Grants (TAG). which help communities hire trained professionals to explain the EPA technical documents. EPA has also introduced the Superfund Job Training Initiative (SuperJTI). which encourages the employment of trainees at local Superfund cleanups. Finally, through the Superfund Redevelopment Initiati ve. EPA partners with communities to return Superfund sites to productive reuse. When will the next phase. the long-term Remedial process. start at the site? EPA is already planning the next phase or investigation work for the Former Custom Cleaners site. Add itional community meetings and fact sheets are planned for the near future to discuss the Remedial process and outline a timeline for Remedial activities. Additional information can also be obtained during the public meeting on October 6.2016 at the Memphis Botanic Garden located al 750 Cherry Road. Memphis. Tennessee. Where can I find more information about the solvent perchloroethylene (PCE) at the Former Custom Cleaners site? Perchloroethy lene or Tetrachloroethylene is a manufactured chemical used for dry cleaning and is a nonflammable colorless liquid. More information on PCE can be found here: • PCE: http://ww,, .atsclr.cdc.!.!.O\ /toxfaqs/tfocts 18.pdr / U.S. Environmental Protection Agency Former Custom Cleaners Site Memphis, Tennessee August 2016 Introduction This information summarizes the history of the Former Custom Cleaners Site ("FCC Site") and provides an overview of proposed removal actions at the Site. The cleanup plan and associated documents related to the FCC Site's activities will be made available in the Administrative Record of the Information Repository located at the Benjamin L. Hooks Central Library, 3030 Poplar Avenue, Memphis, TN. Background The FCC Site is a former dry cleaning operation which operated from approximately 1950 until the mid-1990s. The Site is a commercially zoned property located at 3517 Southern Avenue in Memphis, Shelby County, Tennessee and is situated in a residential and commercial area of east Memphis. Past operations have impacted subsurface soils and groundwater with the solvent perchloroethylene (PCE). Due to the Site's close proximity to municipal drinking water wells within the Memphis Light, Gas and Water (MLGW) Sheahan Well Field, there exists a potential for the PCE contaminated groundwater to impact these wells. The FCC Site is bordered to the north by Southern Avenue, to the east by Minor Road, to the south by Spottswood Avenue, and to the west by South Highland Avenue. The area surrounding the Site is undergoing significant redevelopment, including the development of the property adjoining the western boundary of the Site into a popular fast food restaurant. EPA'sAdions Taken EPA, in conjunction with the Tennessee Department of Environment and Conservation (TDEC), have conducted several actions at the Site. • 2013 - Initial assessment investigation conducted revealed that PCE was used during the cleaner's period of operation at the Site. • 2015 - EPA supported the TDEC Site Inspection sampling activities at the Site that included the collection of subsurface soil samples, soil gas samples and groundwater samples. • TDEC and EPA decided more investigation was necessary due to the elevated concentrations of PCE and the proximity of the Site to the City of Memphis drinking water supply. • 2016 - EPA conducted a site eva luation to trace potential sources of subsurface contamination by expanding the subsurface sampling conducted during the 2015 TDEC sampling event. ------111111(1 ______Next Steps In August, EPA issued an Action Memorandum for the Site authorizing funding for removal of PCE contamination. The EPA expects to begin conducting removal activities during the month of September. The proposed activities are as follows: • Demolition and removal of buildings and structures, as necessary • Collection of additional surface, subsurface soil, sediment, air and waste samples, as needed • Excavation and temporary staging of contaminated soils • Transport and disposal of contaminated soils to an approved facility • Backfilling excavated areas to original grade and restoring areas impacted by the removal action Throughout the removal activities, EPA will conduct air monitoring to ensure the safety of the workers and the public. Immediate control measures will be taken to minimize vapors, if detected above the action level. If necessary, work will stop temporarily, and nearby businesses and residents will be promptly notified. The EPA activities will result in a temporary increase in truck traffic in areas near the Site. The EPA will institute safety measures, as necessary, to minimize hazards from the truck traffic. The FCC Site is likely to be placed on the National Priorities List (NPL), a list of the nation's high priority hazardous waste sites due to the potential threat to the City of Memphis well field. As an initial step towards listing the Site on the NPL, TDEC has placed the Site on the Tennessee List of Inactive Hazardous Substance Sites. FOR MORE INFORMATION EPA On-Scene Coordinator Information Repository Steve Spurlin (731) 394-8996 Benjamin L. Hooks Central Library [email protected] 3030 Poplar Avenue Memphis, TN 38111 EPA Community Involvement Coordinator Kerisa Coleman (404) 562-8831 [email protected] 2