DRC-2025-000018

From: sagarling rdeinc.biz <[e-mail]>
Date: Tue, Dec 24, 2024 at 11:34 AM
Subject: Anfield Resources Holding Corp. Radioactive Materials License [RML] UT0900480 and Groundwater Quality Discharge Permit [GWDP] UGW
170003 - Monitor Well RM-1 Damage Report
To: [e-mail] <[e-mail]>, Adam Wingate <[e-mail]>, Christopher Leahy <[e-mail]>
Cc: [e-mail] <[e-mail]>, [e-mail] <[e-mail]>, [e-mail] <[e-mail]>,
John Howard Eckersley
<[e-mail]>, [e-mail] <[e-mail]>, [e-mail] <[e-mail]>,
ragarling rdeinc.biz <[e-mail]>
The attached file contains the damage report regarding monitor well RM-1.

Please advise if the report needs to be sent as a hard copy to the agencies involved.

If additional information is required, please don’t hesitate to contact LaMiya Morrill or the contract RSOs.

Sheryl

Sheryl and Roger Garling
R and D Enterprises, Inc.
www.rdeinc.biz
PO Box 3321
Casper, WY 82602
Cell 307.277.3861
Land 307.237.4188
[e-mail]
[e-mail]

12/31/24, 3:48 PM Fwd: Anfield Resources Holding Corp. Radioactive Materials License [RML] UT0900480 and Groundwater Quality Discharge Per…
https://mail.google.com/mail/u/0/d/AEoRXRQKy42ACbe2IcMrKFlgNnfWZQfj9khQykhbLfWEV5NbcxrT/#inbox/WhctKLbNHVjlQXVCwRPrhcRRDnMvg…1/1

Page 1 of 7

Office Address:
10808 S. River Front Parkway, Suite 321
South Jordan, UT 84095

MEMO OF REPORTABLE INCIDENT
DATE OF INITIAL
DAMAGE REPORTED: December 13, 2024 @ 11:01 AM MST
DATE OF WRITTEN
REPORT: December 21, 2024
TO: State of Utah
Department of Environmental Quality [DEQ]
Division of Waste Management and Radiation Control [DWMRC]
And
Ground Water Protection Section
Salt Lake City Utah 84114-4810
PHONE NUMBERS: DEQ: 801.536.41123
DWMRC: 801.536.0200
CONTACT NAMES AND
EMAIL ADDRESS:
Ryan Johnson, UT-DWMRC, [e-mail]
801.536.0200
Adam Wingate, UT-DWMRC, [e-mail]
385 499-0293
Chris Leahy, UT-DWMRC, [e-mail]
385.602.5505
FROM: Anfield Resources Holding, Corp. [ARHC]
10808 South River Front Parkway, Suite 321
South Jordan, UT 84095
480.577.5039
Anfield Resources Holding Corp. Contract Radiation Safety Officers
Sheryl Garling, R and D Enterprises, Inc., [e-mail]
Roger Garling, R and D Enterprises, Inc. [e-mail]
307.277.3861
CC: LaMiya Morrill, Contract Site Supervisor, [e-mail]
435 633 3035
Joshua Bleak, President, [e-mail]
480.577.5039
Corey Dias, [e-mail]
416.364.5928
John Howard Eckersley, [e-mail]
480.809.5982
Laara Shaffer, [e-mail]
604.618.4515
Bureau of Land Management-Richfield, UT Office
Devin Macklemore, [e-mail]
435.616.3622 cell; 435.253.4169 land:
Page 2 of 7

FACILITY: Shootaring Canyon Uranium Facility
SITE ADDRESS: The Shootaring Canyon Mill facility is in Garfield County in
southeastern Utah, approximately two miles north of Ticaboo, Utah;
latitude 37° 42’ 30” North, longitude 110° 41’ 30” West.
P.O. Box 2101
Lake Powell, UT 84533
PERMIT NUMBERS: Radioactive Materials License [RML] UT0900480
Groundwater Quality Discharge Permit [GWDP] UGW 170003
REPORTABLE DAMAGE
EVENT:
An upgradient groundwater monitoring well, RM-1, located outside the
restricted area, was damaged due to a rockslide on or around
December 5-9, 2024. The damage was discovered during routine
facility security and maintenance check on December 13, 2024. The
rockslide is a result of the reported 7.0 magnitude seismic activity and
aftershocks that occurred off the US’s west coast around December
5, 2024. Approximately 60 tons of rock buried the well head, leaving
the groundwater well damaged beyond repair and unusable.

No radioactive materials were released from the licensed facility
resulting from this event.
PROPOSED REMEDY: ARHC will need to drill an offset well for RM-1. The offset well will be
in the vicinity of RM-12, if approved by UT-DWMRC and the UT State
Division of Water Quality of the Department of Environmental Quality.
PROJECT HISTORY: The mill and tailings disposal cell were constructed between 1978
and 1981 and began operations in 1982 for the purpose of
extracting uranium. The Nuclear Regulatory Commission issued a
source materials license on September 21, 1979.
In 1984, Utah became an NRC agreement state and issued a Utah
Radioactive Materials License UT0900480.

REPORTABLE EVENT:
On December 17, 2024, Mr. Johnson, and Mr. Wingate, UT-DWMRC, responded to the ARHC’s contract
RSOs email RM-1 damage report. They directed ARHC’s contract RSOs to treat the rockslide, located
outside the restricted area, as a reportable incident as per R313-19-50(2)(b). Because radioactive
material is not involved it does not need to be reported to the NRC. A report from ARHC will be required
within 30 days as per R313-19-50(3)(c). In addition to the regulatory requirements for the RML, Mr. Leahy,
identified that the UT-GWDP requires reporting as per section Part I. E.1.c., Compliance Monitoring,
Protection of the Monitoring Well Network, and Part II.I., Twenty-Four Hour Notice of Noncompliance
Reporting.

Page 3 of 7

RADIOACTIVE MATERIALS LICENSE [RML] UT0900480
Rule R313-19 - Requirements of General Applicability to Licensing of Radioactive Material
Section R313-19-50 - Reporting Requirements

Section R313-19-50 - Reporting Requirements (1) Licensees shall notify the Director as soon as possible
but not later than four hours after the discovery of an event that prevents immediate protective actions
necessary to avoid exposures to radiation or radioactive materials that could exceed regulatory limits or
releases of licensed material that could exceed regulatory limits. Events may include fires, explosions,
toxic gas releases, etc….(2) The following events involving licensed material require notification of the
Director by the licensee within 24 hours:…or (b) an event in which equipment is disabled or fails to
function as designed when;…(ii) the equipment is required by rule or license condition to be available
and operable;

GROUNDWATER QUALITY DISCHARGE PERMIT UGW 170003
PART I. Specification Conditions, E. Compliance Monitoring Requirements, 1. Ground Water
Monitoring Requirements.

c) Protection of Monitor Well Network. All compliance monitoring wells shall be protected
from damage due to surface vehicular traffic or contamination due to surface spills. The
wells shall be maintained in full operational condition for the life of this Permit. Any well
that becomes damaged beyond repair or is rendered unusable for any reason shall be
replaced by the permittee within 90 days or as directed by the Director.

PART II Monitoring, Recording and Reporting Requirements, I. Twenty-Four Hour Notice of
Noncompliance Reporting, 2. A written submission…

I. Twenty-four Hour Notice of Noncompliance Reporting.
1. The permittee shall verbally report any noncompliance with permit conditions or limits as soon as
possible, but no later than twenty-four (24) hours from the time the permittee first became aware
of the circumstances. The report shall be made to the Utah Department of Environmental Quality
24-hour number, [phone], or to the Division of Waste Management and Radiation
Control at [phone], during normal business hours from 8:00 AM - 5:00 PM Mountain
Time.

2. A written submission of any noncompliance with permit conditions or limits shall be provided to
the Director within five days of the time that the permittee becomes aware of the
circumstances. The written submission shall contain:
a. A description of the noncompliance and its cause;
b. The period of noncompliance, including exact dates and times;
c. The estimated time noncompliance is expected to continue if it has not been
corrected;
d. Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
e. When applicable, either an estimation of the quantity of material discharged or an
estimation of the quantity of material released outside containment structures.

3. Written reports shall be submitted to the addresses in Condition II.D, Reporting of
Monitoring Results.

Page 4 of 7

REPORTED EVENT RESOLUTION:
ARHC has started the process to determine what necessary permits, applications, and approval are
required to proceed with drilling an offset well. Correspondence with a local area driller was made to
obtain a quote to drill an offset groundwater well to replace RM-1. The quote will include the purchase
and setting of a pump to include electric wire, drop pipe, sounder tube, and other supplies required for
the new offset well RM-1R completion.

ARHC will attempt to complete the project by the end of March 31, 2025, which would comply with the
90-day replacement time identified in the GWDP Part I.E.1.c. Routine updates will be provided to all
regarding the RM-1 offset project progress.

RM-1 and RM-12 are upgradient, site background groundwater wells, completed in the Entrada aquifer,
located on BLM land, outside the restricted area and mill site fence.

Well
Name
North
Coord.
East
Coord.
Casing
DIA
Total
Depth
MP
Elevation
RM-1 53606.43 61826.64 3” 487’ 4449.2’
RM-12 59477.15 61790.93 5” 157’ 4415.95’

RM-1 and RM-12 were drilled before reporting to the Utah Division of water rights required their
notification. They were submitted as non-production wells to the BLM in a report documenting the drilling
of test wells being drilled at the time.

Based on the evidence provided, Mr. Jim Goddard, State Engineer’s Office (SEO), confirmed that the
rockslide constituted a naturally abandoned well and should be noted on the offset of RM-1R,
replacement, groundwater well permit application.

The map identifies the location of RM-1 relative to RM-12 and the Shootaring Canyon Uranium Mill. RM-
1 and RM-12 are in the NE ¼ of the SE ¼ of Section 33, Township 35 South, Range 11 East, Salt Lake
Principal Meridian.

REPORTED NONCOMPLIANCE ACTIVITY
On December 18, 2024, an email was sent to DWMRC and DEQ Groundwater staff indicating that ARHC
would be in a noncompliance circumstance for the 2025 1st quarter groundwater sampling event for RM-
1.

ARHC is requesting approval to report the RM-1 damaged well as abandoned in place, as indicated by
the State Engineer’s office, and no other groundwater well abandonment activity will be required, other
than filing the appropriate documentation with the Utah State Engineer’s office.

Due to the rockslide damage, rendering RM-1 unusable, ARHC is reporting that they will be in a
noncompliance event for the 2025 first quarter groundwater sampling event that is scheduled for January
3rd and 4th, 2025. ARHC will provide the Director and staff periodic updates as to the progress that is
being made on the completion of the RM-1R offset project.
Page 5 of 7

Location Map RM-1, RM-12 to Shootaring Canyon Uranium Mill
Page 6 of 7

Rockslide on top of RM-1

Page 7 of 7

Rockslide on top of RM-1, looking east