Publications Details
Causal Analysis Report for "Demolition of Historic and Yet-to-be-Determined Radar Towers at TTR Without Completing Required NEPA Process"
Wright, Emily D.; Cattaneo, Matthew C.
Two radar towers at the Tonopah Test Range (TTR), Contraves Towers 22-00 and 12-00, were torn down prior to completion of the required National Environmental Policy Act (NEPA) process. National Technology and Engineering Solutions of Sandia, LLC, (NTESS) submission of the NEPA checklist triggered a Sandia Field Office (SFO) review of the proposed work scope and was to include a required consultation between SFO and the Nevada State Historic Preservation Office (SHPO) to assess any adverse effect(s) on historic properties or contributing element(s) to a historic district and, if so, determine a resolution. Following the consultation, SFO provides approval/denial of the proposed work detailed on the submitted NEPA checklist. Contraves Tower 22-00 is a historic structure, as formally determined by the SFO in consultation with the SHPO. The historical eligibility of Contraves Tower 12-00 is yet to be determined. On February 13, 2018, NTESS notified SFO that Contraves Tower 22-00 at TTR was torn down in May 2017 prior to completion of the required the NEPA process, including consultation with the SHPO. NTESS submitted two NEPA checklists to SFO in 2016 for the removal of several structures no longer required by NTESS. The first NEPA checklist listed three historic structures (one of which was Contraves Tower 22-00) and SFO determination on whether consultation with the SHPO is necessary as well as approval/denial of the NEPA checklist is pending. The second NEPA checklist listed five non-historic structures, one of which was Contraves Tower 12-00. SFO approved the NEPA checklist covering non historic structures except for the Contraves Tower 12-00, as the Contraves Tower 12-00 requires further consultation with the SHPO by SFO. Only after completion of the consultation would SFO determine approval/denial on the remaining property cited within the NEPA checklist. In late January 2018, NTESS personnel discovered that Contraves Tower 22-00 was no longer listed in the Facility Information Management System (FIMS). Upon further investigation, NTESS personnel verified that the Contraves Tower 22-00 had been removed in May 2017. During the initial extent of condition, it was discovered that Contraves Tower 12-00 had also been torn down in May 2017 as part of this same destruction and demolition (D&D) activity. Both Contraves Towers 22-00 and 12-00) had been torn down prior to completion of the NEPA process, including consultation with the SHPO.