State of Tennessee June 29, 2015 Deborah Shults, Director Division of Radiological Health Tennessee Department of Environment and Conservation William R. Snodgrass Tennessee Tower 312 Rosa Parks Avenue, 15" Floor Nashville, TN 37243 Ms. Shults: We have recently been made aware that the Division of Radiological Health has received a request from EnergySolutions, Inc. in Memphis to amend its Tennessee Radioactive Material License Number R-79171-L16 to authorize a new Bulk Waste Assay Program (BWAP) allowing the release of waste to the North and South Shelby County landfills. We believe it is in the best interests of the citizens of Shelby County that the Division denies this request. We are also asking for a public hearing in the Memphis area if the Division is considering granting the amendment. Along with our constituents, we are concemed that the Shelby County landfills are unsuitable to receive materials from radioactive waste processing. ‘These landfills are close to our major metropolitan area with a county population of over 930,000, Shelby County’s high annual rainfall is a complicating factor. The similar Bulk Survey for Release Program (BSER) operated by the now idle Studsvik Memphis radioactive waste processor was responsible for the dumping of almost 26 million pounds of material into our North and South Shelby landfills between 2004 and 2015. Under these programs the waste processor is allowed to determine which materials they have received from radioactive waste generators meet the state guidelines, We are concemed there is no physical verification by the State of that determination or even occasional random Divisionmonitoring. External radiation detectors at the gates of the landfill provide very limited assurance of compliance. It troubles us that leachates collected from the Jandfill are not monitored for radiation. ‘There are no other programs like BSFR and BWAP in any other state in the United States. Because of this many states send their radioactive waste to Tennessee, much of it to Memphis. In Tennessee there are now only four landfills that accept these materials. Citizen concems about the safety of the BSFR program at the Middle Point Landfill in Murfreesboro led to stopping the practice there. EnergySolutions’. Memphis location receives many highly radioactive materials which are contaminated with uranium, plutonium, transuranics, and many other radioactive elements. EnergySolutions has not been authorized to send materials to our landfills for at least nine years, When the decommissioning of the former Studsvik site is complete there will be no more threat of radioactive contamination of the North and South Shelby landfills unless you approve this amendment request. As you are well aware when it comes to radiation exposure an abundance of caution is appropriate. It is with a deep concem for the health of the residents of Memphis and Shelby County and the workers that handle and transport the radioactive materials that we respectfully ask you to deny EnergySolutions request for authorization of their Bulk Waste Assay Program. Sincerely, Paurreah (0. Chars CE ] ? Representative Raumesh Akbari Representative Joe Towns ¥ Ol AK Senator Lee Harris Senator Sara Kyl