PUBLIC COMMENT RELEASE : COMMENT PERIOD ENDS: FEBRUARY 18, 2020

This document summarizes an environmental public health investigation performed by the State of Tennessee Department of Health’s Environmental Epidemiology Program. Our work is conducted under a cooperative agreement with the federal Agency for Toxic Substances and Disease Registry.

This information is distributed by the Agency for Toxic Substances and Disease Registry for public comment under applicable information quality guidelines. It does not represent and should not be construed to represent final agency conclusions or recommendations.

The Former Custom Cleaners (FCC) in Memphis used dry-cleaner solvents that contaminated the site. The FCC was added to the National Priorities List (NPL) (Superfund) because of the chemical contamination. The Tennessee Department of Health’s (TDH) Environmental Epidemiology Program (EEP) has evaluated the contamination. TDH EEP has a cooperative agreement with the Agency for Toxic Substances and Disease Registry (ATSDR) to evaluate health implications of potential exposure to chemicals at hazardous waste sites in Tennessee.

On September 9, 2016, the U.S. Environmental Protection Agency (EPA) proposed adding the FCC property to the NPL. The FCC site was officially listed on the NPL on August 3, 2017. The NPL is part of EPA’s Superfund cleanup process intended to identify the nation’s most highly impacted hazardous waste sites. EEP became involved with the FCC site because Congress mandates that ATSDR conduct public health activities at Superfund sites that EPA proposes adding to its NPL.

Past releases of metals, semi-volatile organic compounds, and volatile organic compounds, primarily the dry-cleaning chemical tetrachloroethylene (PCE), traveled into soil and groundwater. PCE vapors from soil and groundwater might also migrate into indoor air should the FCC property be redeveloped.

TDH EEP and ATSDR’s top priority at this site is to ensure that authorities and affected groups have the best information possible to safeguard the health of Memphis’ citizens. Those authorities and groups include the Shelby County Health Department; Memphis Light, Gas, and Water; the Tennessee Department of Environment and Conservation; and the local community.

TDH EEP evaluated potential exposure from onsite indoor air for a former tenant of the FCC site in 2014. The tenant was living upstairs, above the former art supply store housed in the building. EEP concluded at that time that the tenant should not be living in the building unless steps were taken to reduce levels of PCE and trichloroethylene (TCE) in the indoor air [TDH EEP 2014]. EEP also concluded that PCE and TCE source removal and additional air sampling should be done before the building was occupied again. Instead, the building was demolished and source area soils were removed.

This health consultation evaluates the soil, soil gas, and off-site indoor air exposure pathways based on recent data collected onsite and off-site by EPA. Current fast food workers in the restaurant adjacent to the site and people who live in the area may walk across the site. Past exposures were not evaluated as part of this assessment. Rather, this assessment focused on current exposures at the site. In the future, additional data might become available from EPA or the Tennessee Department of Environment and Conservation (TDEC). We would use that data to evaluate the groundwater exposure pathway and other potential off-site exposure pathways. We did not evaluate subsurface soil for this health consultation because the public would not have access to these soils and would not be exposed to chemicals in those soils.

Former_Custom_Cleaners_HC_PC-508.pdf