December 18, 2019
Robert D. Mullaney
Environmental Law and Justice Clinic
Golden Gate University School of Law
536 Mission Street
San Francisco, CA 94105-2968
David C. Anton
1717 Redwood Lane
Davis, CA 95616
SUBJECT: PETITION UNDER TITLE 10 OF THE CODE OF FEDERAL REGULATIONS
PART 2.206 SEEKING ENFORCEMENT ACTION AGAINST TETRA TECH EC,
INCORPORATED
Dear Mr. Mullaney and Mr. Anton:
This letter is in reference to your petition for Greenaction for Health and Environmental Justice,
dated June 28, 2017, as supplemented on January 18, 2018, February 13, 2018,
July 23, 2018, and June 21, 2019 (Agencywide Documents Access and Management System
[ADAMS] Accession Nos. ML18178A067, ML18178A087, ML18212A267, ML18212A264, and
ML19178A147, respectively). Your petition has been reviewed by the U.S. Nuclear Regulatory
Commission (NRC) Office of Nuclear Material Safety and Safeguards pursuant to Title 10 of the
Code of Federal Regulations (10 CFR) Section 2.206 of the Commission’s regulations. In your
petition, you requested that the NRC revoke Materials License No. 29-31396-01, Docket
Number 03938199, issued to Tetra Tech EC, Inc (TTEC), relating to fraudulent activities at the
Hunters Point Naval Shipyard (HPNS).
Consistent with the Memorandum of Understanding between the NRC and Department Of
Justice (DOJ) to facilitate the exchange of information between agencies
(https://www.nrc.gov/about-nrc/regulatory/enforcement/moudoj.pdf
), the NRC will defer its
decision regarding your 2.206 Petition pending the outcome of the DOJ’s ongoing civil complaint
against TTEC. As a result, the NRC will hold your 2.206 petition in abeyance until the legal
resolution of the DOJ civil complaint. At that time, the NRC staff will reassess your petition
consistent with the 10 CFR 2.206 process as outlined in Management Directive 8.11.