DRC-2025-000823

Deq submit <[e-mail]>
Fwd: Anfield Resources Holding Corp. Radioactive Materials License [RML]
UT0900480 and Groundwater Quality Discharge Permit [GWDP] UGW 170003 -
Monitor Well RM-1 Damage Report and Work Plan
1 message
Adam Wingate <[e-mail]>Thu, Mar 6, 2025 at 11:27 AM
To: Deq submit <[e-mail]>
Can you upload the attached document to Laserfiche and use the email as a cover letter? This is for Anfield (UT0900480)
Thanks!
---------- Forwarded message ---------
From: sagarling rdeinc.biz <[e-mail]>
Date: Wed, Mar 5, 2025 at 3:24 PM
Subject: Anfield Resources Holding Corp. Radioactive Materials License [RML] UT0900480 and Groundwater Quality
Discharge Permit [GWDP] UGW 170003 - Monitor Well RM-1 Damage Report and Work Plan
To: Adam Wingate <[e-mail]>, [e-mail] <[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]>, Carl W <[e-mail]>, Doug Beahm
<[e-mail]>, ragarling rdeinc.biz <[e-mail]>
The attached file contains the work plan appended to the original damage report regarding monitor
well RM-1.

All Wells Drilling contractor had a drilling project they were working on and could not provide a
definite mobilization date. As of today, they indicated they may be able to mobilize to the
Shootaring Canyon Mill site location possibly Friday, March 7th , or Monday March 10th .

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

Sheryl & Roger
Contract Radiation Safety Officers

Sheryl and Roger Garling
R and D Enterprises, Inc.
www.rdeinc.biz
PO Box 3321
Casper, WY 82602
Cell 307.277.3861
3/6/25, 4:16 PM State of Utah Mail - Fwd: Anfield Resources Holding Corp. Radioactive Materials License [RML] UT0900480 and Groundwater Qualit…
https://mail.google.com/mail/b/AEoRXRSYroS_jWomOT_fUNQIMOVeut6Gw1kG5gOeBlwHP3ZDzkrC/u/0/?ik=adf9d5e615&view=pt&search=all&perm…1/2
Land 307.237.4188
[e-mail]
[e-mail]

--
Adam Wingate
Section Manager | Uranium Recovery
He / Him
Direct Line: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Statements made in this email do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control. If you desire a statement of the Division Director's position,
please submit a written request to the Director, including copies of documents relevant to your request
2025-03-05-ARHC RESPONSE OF INCIDENT REPORT TO UTAH WITH WORK PLAN FINAL.pdf
2710K
3/6/25, 4:16 PM State of Utah Mail - Fwd: Anfield Resources Holding Corp. Radioactive Materials License [RML] UT0900480 and Groundwater Qualit…
https://mail.google.com/mail/b/AEoRXRSYroS_jWomOT_fUNQIMOVeut6Gw1kG5gOeBlwHP3ZDzkrC/u/0/?ik=adf9d5e615&view=pt&search=all&perm…2/2
Office Address:
10808 S. River Front Parkway, Suite 321
South Jordan, UT 84095

MEMO OF REPORTABLE INCIDENT with WORK PLAN
DATE OF RESPONSE TO
02/10/2025
MR. WINGATE’S LETTER:
March 3, 2025
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:
Adam Wingate, UT-DWMRC, [e-mail]
385 499-0293
Ryan Johnson, UT-DWMRC, [e-mail]
801.536.0200
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
Carl Warren, P.E., P.G., Project Engineer | BRS Engineering
[e-mail]
Office [phone] | Fax [phone] | Cell [phone]

Anfield Resources Holding Corp. - Shootaring Canyon Mill - Radioactive Materials License UT0900480March 5, 2025 - Page 1 of 10
Doug Beahm, Principal Engineer | BRS Engineering
[e-mail]
Office [phone] | Fax [phone] | [phone]
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 has obtained a cost estimate to drill a new well in the upgradient
drainage. The new well will be identified as RM23. The attached drawing
identifies the proposed location.
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.

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,
䅮晩敬搠剥獯畲捥猠䡯汤楮朠䍯牰⸠ⴠ卨潯瑡物湧⁃慮祯渠䵩汬‭⁒慤楯慣瑩癥⁍慴敲楡汳⁌楣敮獥⁕吰㤰〴㠰䵡牣栠㔬′〲㔠ⴠ偡来′映㄰
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,

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.
REPORTED EVENT RESOLUTION-INITIAL:
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.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.

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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. Discussion with Mr. Jim Goddard, Utah State Engineer’s office,
indicated that the rockslide ARHC was unable to locate the original RM-1 and RM-12 groundwater permit
applications and numbers. Discussion with Mr. Jim Goddard, Utah State Engineer’s office, indicated that
the rockslide constitutes a naturally abandoned well and will be noted as such 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 RM1.

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.

MARCH 3, 2025, PROPOSED WORK PLAN:
Anfield Resources Holding, Corp. received a letter from the DWMRC dated February 10, 2025, outlining
their request to provide a Work Plan;…Following these discussions, please provide a work plan for
replacing monitoring well RM-1 that includes, but is not limited to:

1. Placement and construction details of a replacement monitoring well;
1.1. See attached location map. Due to the distance from the original RM1 location,
the SEO required the new well to have a new well identification, RM23.
1.1.1. The location intersects the Entrada lower K sand,
1.1.2. The well will be up-gradient of the mill (triangulate between RM14 and
RM2R), and
1.1.3. The proposed location is within the fenced boundary of the Shootaring
Canyon Mill, but outside the restricted area boundary.

2. Justification for not meeting the 90-day replacement requirement found in condition I.E.c. of the
Permit if the March 31, 2025, date stated in the Incident Report cannot be met. This justification
can include:
2.1. All Wells Drilling, located in Hanksville, UT, provided Anfield Energy, Inc. with a cost estimate
and proposed schedule to drill a new well, RM23, which will replace RM1. They are currently
estimating the time of completion by the end of March 2025. All Wells Drilling will provide
services to drill and log (geophysical tool for resistivity and passive gamma) the new well, set
䅮晩敬搠剥獯畲捥猠䡯汤楮朠䍯牰⸠ⴠ卨潯瑡物湧⁃慮祯渠䵩汬‭⁒慤楯慣瑩癥⁍慴敲楡汳⁌楣敮獥⁕吰㤰〴㠰䵡牣栠㔬′〲㔠ⴠ偡来‴映㄰
casing, complete installation of downhole pipe, power cord, pump to complete the well to a
functioning monitor well. ARHC will notify DWMRC as soon as a schedule is provided by the
driller.
2.2. Due to the current driller’s schedule, and time to pump develop the well, this serves as
notification to DWMRC and DEQ Groundwater staff that ARHC may not be able to complete
the well development prior to the 2nd quarter sampling event scheduled for April 6-7, 2025.
ARHC would be in noncompliance for the 2025 2nd quarter groundwater sampling event for
RM-1 (RM23) if well development is not achieved.
2.3. BRS, Inc. will provide a professional geologist with expertise to supervise onsite activities, to
include documenting the lithology from cuttings at 5ft intervals, during drilling and completion
of the new well.
2.4. Anfield Energy Inc./ARHC will be represented by LaMiya Morrill to provide onsite access and
supervision during the drilling activities.
3. Time to get necessary permits including potential access from the U.S. Bureau of Land
Management (BLM).
3.1. ARHC has applied for and obtained the permits from the State Engineer’s office.
4. Scheduling drillers and other contractors;
4.1. Refer to above.
5. Potential weather delays;
5.1. Weather delays may affect drilling schedule and AHRC will notify DWMRC immediately upon
learning of the delays.
6. Delays from the sale and transfer of control of the Mill;
6.1. Anfield Energy Inc., owner of ARHC, has completed the publicized stock sale to UEC. This
activity will not delay the drilling of the new well RM23.
7. A proposed date of replacing RM-1; and
7.1. Refer to above.
8. Possible alternate locations to replace RM-1.
8.1. The location of the new well, RM23, is identified on attached map. The location was identified
by DWMRC staff during their onsite visit January 13, 2025.

䅮晩敬搠剥獯畲捥猠䡯汤楮朠䍯牰⸠ⴠ卨潯瑡物湧⁃慮祯渠䵩汬‭⁒慤楯慣瑩癥⁍慴敲楡汳⁌楣敮獥⁕吰㤰〴㠰䵡牣栠㔬′〲㔠ⴠ偡来‵映㄰

Location Map RM-1, RM-12 to Shootaring Canyon Uranium Mill
Anfield Resources Holding Corp. - Shootaring Canyon Mill - Radioactive Materials License UT0900480March 5, 2025 - Page 6 of 10
Rockslide on top of RM-1

Anfield Resources Holding Corp. - Shootaring Canyon Mill - Radioactive Materials License UT0900480March 5, 2025 - Page 7 of 10
Rockslide on top of RM-1
Rockslide on top of RM-1, looking east

Anfield Resources Holding Corp. - Shootaring Canyon Mill - Radioactive Materials License UT0900480March 5, 2025 - Page 8 of 10

Anfield Resources Holding Corp. - Shootaring Canyon Mill - Radioactive Materials License UT0900480March 5, 2025 - Page 9 of 10

Anfield Resources Holding Corp. - Shootaring Canyon Mill - Radioactive Materials License UT0900480March 5, 2025 - Page 10 of 10