1

Kelly, Shaheerah

From: Dwight Mallory <Dmallory@resoluteenergy.com>

Sent: Monday, August 31, 2015 2:43 PM

To: Kelly, Shaheerah

Cc: Patrick Flynn

Subject: RE: Dinetahdoo CRM Resolute McElmo Flare Report

Attachments: removed.txt; DCRM 2015-31 Aneth Flare RNRC 08312015.doc

Shaheerah, 

Attached is Resolute’s final edit of the NHPA assessment with EPA’s comments incorporated. It has been 

reviewed by our management, as well as by outside counsel with NHPA expertise. I know it has taken me a 

while to get this back to you, but hopefully this will get us back on track. 

I will be in the office this week and next, with the exception of the Labor Day holiday. Please let me know if 

there are any questions. 

Thanks. The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

Dwight E. Mallory

Environmental/Regulatory Manager

Resolute Energy Corporation

1700 Lincoln Street, Suite 2800

Denver, CO 80203

Direct: 303-573-4886 X 1165

From: Kelly, Shaheerah [mailto:Kelly.Shaheerah@epa.gov] 

Sent: Friday, August 07, 2015 12:23 PM 

To: Dwight Mallory 

Cc: Patrick Flynn ; Kelly, Shaheerah 

Subject: RE: Dinetahdoo CRM Resolute McElmo Flare Report 

Hi Dwight, 

Just following up on the email below on whether you have any updates. Please call me if you have any 

questions. 

Thanks. 

************************************ 

Shaheerah Kelly 

Permits Office, Air Division (AIR-3) 

U.S. Environmental Protection Agency, Region 9 

San Francisco, CA 94105 

Phone: 415-947-4156 

Fax: 415-947-3579 

Email: kelly.shaheerah@epa.gov

From: Kelly, Shaheerah 

Sent: Thursday, July 02, 2015 10:00 AM 

To: Dwight Mallory 

Cc: Maurin, Lawrence; Rios, Gerardo; Kelly, Shaheerah; Patrick Flynn; Saanii 

Subject: RE: Dinetahdoo CRM Resolute McElmo Flare Report 

Dwight, 

We received the draft historic properties report submitted by your consultant, Dinetahdoo Cultural Resources 

Management. We appreciate the opportunity to review the draft report, which provides an assessment of the 
2

historic properties within the area of potential effects (i.e., 2 km of the main flare) for the undertaking. In order 

to make the report complete, we have the following comments and suggestions provided below. 

Once you have addressed our comments, we look forward to reviewing the revised report which we expect will 

be submitted by Resolute Natural Resources Company. EPA must obtain this information to move toward 

conclusion of the NHPA consultation process. This process must be completed before the agency can issue the 

final PSD permit. If you have any questions, please contact Shaheerah Kelly at (415) 947-4156 or 

kelly.shaheerah@epa.gov, or Larry Maurin at (415) 972-3943 or maurin.lawrence@epa.gov. 

Comment #1:

The report does not describe EPA’s undertaking in the section called “Description of Undertaking” on page 1. 

We recommend that you modify this section such that it includes the following: 

“Resolute Natural Resources, LLC contracted with DCRM to identify historic properties, as defined by

the National Historic Preservation Act (NHPA) and its implementing regulations, within a 2 km Area of

Potential Effect (APE) of the main flare at the McElmo Creek Unit Oil Production Facility (MCU Facility

or Facility). 

Pursuant to Section 106 of the NHPA, and its implementing regulations at 36 CFR Part 800, prior to the 

approval of the expenditure of any funds on or prior to the issuance of any license for an undertaking, 

EPA is required to take into account the effects of its undertakings on historic properties. Consultation 

is required for all undertakings that have the potential to affect historic properties. Section 106 

consultations assess whether historic properties exist within an undertaking’s area of potential effect 

and, if so, whether the undertaking will adversely affect such properties. The term “historic properties” 

means prehistoric or historic districts, sites, buildings, structures, or objects included in, or eligible for 

inclusion in, the National Register of Historic Places maintained by the Department of the Interior. 

EPA’s undertaking triggering the application of the NHPA is the issuance of a federal Prevention of 

Significant Deterioration (PSD) air quality permit, in accordance with the Clean Air Act and PSD 

regulations (40 CFR 52.21), for the gas flare (called the “main flare”) at the MCU Facility. While the 

Facility is an existing oil and gas production operation located on the McElmo Creek Unit oilfield in 

San Juan County, Utah, our action is only for the gas flare which is used to destroy natural gas during 

any upsets of the natural gas gathering system. The United States Environmental Protection Agency 

(EPA) Region 9 is the lead federal agency for this undertaking. 

EPA is amending the PSD permit to incorporate pollution limits, terms, and conditions of a federal 

Consent Decree (United States v. Mobil Exploration and Producing U.S. Inc., Case No. 2:05-CV-319, 

filed June 8, 2005) that specifically applies to the main gas flare at the MCU Facility. These pollution 

limits, terms, and conditions include Best Available Control Technology (BACT) emission limitations for 

nitrogen oxides, carbon monoxide, sulfur dioxide, and volatile organic compounds for the main flare at 

the MCU Facility. 

Additionally, EPA is amending the PSD permit to remove and update other applicable requirements in 

the MCU Facility’s PSD permit due to equipment that has been shut down and removed from the site. 

Other than the potential replacement of a fixed speed fan with a variable speed fan to provide better 

pollution control at the already existing main flare, EPA’s action does not authorize any new 

construction or modification of existing equipment at the MCU Facility. 

EPA issued the proposed permit for public comment on October 15, 2014. A final permit decision will 

be issued following completion of the Agency’s Section 106 NHPA consultation. 

DCRM’s identification of historic properties included a literature search to identify previously recorded 

cultural resources to determine if they qualified as historic properties under the NHPA (Figure 1) as 

well as a field assessment of existing Navajo in-use sites within the APE to determine if any of the 

structures are eligible for listing as historic properties (Figure 2).”

Comment #2:

The report does not discuss potential effects of the undertaking on historic properties. The undertaking is for the 

issuance of a PSD permit. However, other than the potential replacement of a fixed speed fan with a variable 

speed fan to provide better pollution control at the already existing main flare, EPA’s action does not authorize 

any new construction or modification of existing equipment at the MCU Facility. Additionally, the EPA’s 
3

action would not result in any ground breaking activities to undisturbed areas. We recommend that you add a 

section to the report that addresses potential effects of the undertaking on historic properties within the 2 km 

APE for the flare, or if there are no effects, indicate that the undertaking will have no effect or will not likely 

effect historic properties within the 2 km APE. 

Comment #3:

In the “Abstract” section on page i and in the “Introduction” section on page 1, we recommend that you replace 

“the continued operation of the McElmo Creek Unit Main Flare” with “the undertaking”. 

Comment #4: 

In the map in Figure 1 on page 2, please clearly identify the location of the flare in the map. 

Comment #5: 

The report identifies thirteen (13) historic structures, and nine (9) in-use sites. For each of these sites, please 

identify which sites or structures are already listed in, or eligible to be listed in, the National Register of Historic 

Places. For sites or structures that are listed in the National Register of Historic Places, it would be helpful to 

provide the listing date. 

Comment #6:

In the “Recommendations” section on page 41 of the report, we find that the first recommendation stating that 

the “USEPA or their contractors should visit the homesites within the 2 km APE to see and analyze the oily 

residue that falls on their property as a result of the burning of excess gas” is not supported by the report. 

EPA’s undertaking concerns the main flare at the site, which is a gas flare. The report does not describe how the 

main flare results in “oily residue.” In fact, there is no discussion of oily residue in any other part of the report 

and how and where such oily residue (if it even exists) is produced. The report does not provide a basis for how 

the gas-fired main flare results in an “oily residue” and whether “oily residue” may be due to sources other than 

the main flare. 

Comment #7

In the “Recommendations” section on page 41 of the report, recommendation #2, calls for EPA or Resolute to

make arrangements (through a qualified contractor) to conduct a field analysis regarding the current status of

previously documented archaeological sites provided in this report, and what, if any, impacts the gas flare has

had on the previously documented archaeological sites. We are not clear about this recommendation since the 

purpose of this report is to provide Resolute with the current status of such sites, and to provide Resolute with upto-date information regarding potential effects on historic properties within the 2 km APE. If the consultant found

no such effects, or is unable to make this determination it should state so in the report. 

On page 42 of the report, recommendation #3, calls for the EPA or Resolute to make arrangements (through a 

qualified contractor) to fully document eight historic structures that were deemed eligible for protection under 

the NHPA, and assess the impacts, if any, of the main flare on these structures. Again, we are perplexed by this 

recommendation because the purpose of this report is to fully document and assess the impacts (if any) on 

historic properties (if any) by the main flare within the 2 km APE. If the consultant found no such effects, or is 

unable to make this determination it should state so in the report. 

************************************ 

Shaheerah Kelly 

Permits Office, Air Division (AIR-3) 

U.S. Environmental Protection Agency, Region 9 

San Francisco, CA 94105 

Phone: 415-947-4156 

Fax: 415-947-3579 

Email: kelly.shaheerah@epa.gov

From: Saanii [mailto:dinetahdoo@yahoo.com] 

Sent: Monday, June 29, 2015 2:42 PM 

To: Kelly, Shaheerah 

Subject: Dinetahdoo CRM Resolute McElmo Flare Report 

Good afternoon Ms. Kelly, 
4

Attached to this message is a copy of Dinetahdoo CRM's report regarding the listing of previously identified 

archaeological resources and historic Navajo structures in the vicinity of the McElmo Unit Main Flare which is 

operated by Resolute Natural Resources in Aneth, Utah. The report has been reviewed by Mr. Dwight Mallory 

of Resolute and we believe that the report is ready for submission to your office and the Navajo Nation Historic 

Preservation Department (NNHPD). The copies that will be sent to NNHPD will include a confidential 

ethnographical appendix as well as site forms for the majority of the archaeological sites described in the report. 

We would like to know if there is anything you would like from us as well? Please do not hesitate to contact us 

should there be any questions regarding the report. Thank you and have a great day. 

Jeremy Begay 

Senior Archaeologist 

Dinetahdoo Cultural Resources Management, LLC 

P.O. Box 2012, Farmington NM 87499 

10076 US Hwy 371, S of Farmington, NM 

Phone (505) 960-9478Fax (505) 960-9749 

Email dinetahdoo@yahoo.com 

Website: www.dinetahdoo.com

This e-mail message and any attachments are for the sole use of the intended recipient(s) and may contain 

confidential, privileged, and proprietary information of Resolute Energy Corporation. Any unauthorized review, 

use, disclosure or distribution may be prohibited under law. If you are not the intended recipient, please contact 

the sender by reply E-mail of any erroneous transmission, and destroy the original E-mail, any attachments, and 

all copies of the original message. Thank you. 
An NHPA Assessment of Historic Properties within a 2-Kilometer APE of the 

McElmo Creek Unit Main Flare in San Juan County, Utah, for Resolute Natural 

Resources Company, LLC.

Report prepared by

Rena Martin, Archaeologist

DCRM 2015-31

Navajo Nation Historic Preservation Department

Permit Number C14021-E

June 30, 2015

Submitted by 

Rena Martin, Anthropologist/Archaeologist

Dinétahdóó Cultural Resources Management 

P.O. Box 2012

Farmington, New Mexico 87499

Submitted to and Prepared for:

Dwight Mallory,

Resolute Natural Resources Company, LLC.

1700 Lincoln St., Suite 2800

Denver, CO 80203
i

Abstract

This report is submitted to the U.S. Environmental Protection Agency and the Navajo Nation 

Historic Preservation Department for compliance review as part of the cultural resources 

clearance process. The report details the results of the cultural resources inventory conducted in 

conjunction with the project entitled “An NHPA Assessment of Historic Properties within a 2-

Kilometer APE of the McElmo Creek Unit Main Flare in San Juan County, Utah, for Resolute 

Natural Resources Inc.” The project will identify and assess historic properties, as defined by the 

National Historic Preservation Act (NHPA) and its implementing regulations, within a 2 km area 

of potential effect (APE) of the Main Flare located at Resolute Natural Resources Company, 

LLC’s McElmo Creek Unit Central Facility. The project area is located in San Juan County, 

Utah, on Navajo Nation Tribal Trust lands. The project area is located in Section 36, Township 

40 South, Range 24 East; Sections 29, 30, 31, 32, and 33, Township 40 South, Range 25 East;

Section 1, Township 41 South, Range 24 East; and Sections 4, 5, 6, 7, and 8, Township 41 South, 

Range 25 East. The project can be found on the Navajo Canyon, Utah, Provisional Edition 1985 

and Aneth, Utah, Provisional Edition 1989 7.5-minute USGS quadrangle maps. Fifty (50) 

previously recorded archaeological sites, thirteen (13) historic structures, and nine (9) in-use sites

were identified and evaluated in conjunction with the project. Archaeological clearance is 

recommended for the undertaking described herein.
ii

Contents

Abstract i

List of Figures iv

List of Tables................................................................................................................................................................iv

Introduction ...................................................................................................................................................................1

Description of Undertaking ...........................................................................................................................................1

Location.........................................................................................................................................................................2

Existing Data Review ....................................................................................................................................................5

Field Methods................................................................................................................................................................6

Historic Structure Identification and Inventory .........................................................................................................6

Cultural Resources Findings..........................................................................................................................................7

Archaeological Sites..................................................................................................................................................7

Site: UT-C-42-22...................................................................................................................................................7

Site: UT-C-42-23...................................................................................................................................................7

Site: UT-C-42-36...................................................................................................................................................8

Site: UT-C-42-37...................................................................................................................................................8

Site: UT-C-42-40...................................................................................................................................................8

Site: UT-C-42-48...................................................................................................................................................9

Site: UT-C-42-50...................................................................................................................................................9

Site: UT-C-42-59...................................................................................................................................................9

Site: UT-C-42-104...............................................................................................................................................10

Site: UT-C-42-108...............................................................................................................................................10

Site: UT-C-42-110...............................................................................................................................................11

Site: UT-C-42-113...............................................................................................................................................11

Site: UT-C-42-114...............................................................................................................................................11

Site: UT-C-42-115...............................................................................................................................................12

Site: UT-C-42-116...............................................................................................................................................12

Site: UT-C-42-117...............................................................................................................................................12

Site: UT-C-42-118...............................................................................................................................................13

Site: UT-C-42-119...............................................................................................................................................14

Site: UT-C-42-120...............................................................................................................................................14

Site: UT-C-42-121...............................................................................................................................................14

Site: UT-C-42-122...............................................................................................................................................15

Site: UT-C-42-123...............................................................................................................................................15

Site: UT-C-42-124...............................................................................................................................................16

Site: UT-C-42-125...............................................................................................................................................16

Site: UT-C-42-126...............................................................................................................................................16

Site: UT-C-42-127...............................................................................................................................................17

Site: UT-C-42-128...............................................................................................................................................17

Site: UT-C-42-381...............................................................................................................................................17

Site: UT-C-42-382...............................................................................................................................................18
iii

Site: UT-C-42-401...............................................................................................................................................18

Site: UT-C-42-411...............................................................................................................................................18

Site: UT-C-42-412...............................................................................................................................................19

Site: UT-C-42-413...............................................................................................................................................19

Site: UT-C-42-414...............................................................................................................................................19

Site: UT-C-42-415...............................................................................................................................................20

Site: UT-C-42-416...............................................................................................................................................20

Site: UT-C-42-417...............................................................................................................................................20

Site: UT-C-42-418...............................................................................................................................................21

Site: UT-C-55-163...............................................................................................................................................21

In-Use Sites .............................................................................................................................................................22

Historic Structures...............................................................................................................................................2328

Evaluation of Significance...........................................................................................................................................28

Impact of Undertaking on Historical Properties..........................................................................................................35

References Cited..........................................................................................................................................................36
iv

List of Figures

Figure 1: Map showing project area and fifty previously documented archaeological sites (DCRM 2015-31)............3

Figure 2: Map showing project area and nine documented in-use sites (DCRM 2015-31)...........................................4

List of Tables

Table 1. UTM Coordinates, Legal Descriptions, and USGS Maps for the McElmo Creek Unit Main Flare Project....2

Table 2: List of previously documented archaeological sites in the McElmo Creek Unit Main Flare Project Area. ....5

Table 3: In-Use Site Summary Table and interview results. .......................................................................................22

Table 4: NHPA, ARPA, AIRFA, and NAGPRA Evaluation of Documented Cultural Resources in the McElmo Unit 

Main Flare Project Area...............................................................................................................................................29

Table 5: NHPA, ARPA, AIRFA, and NAGPRA Evaluation table for Historic IUS structures in the McElmo Unit 

Main Flare Project Area...............................................................................................................................................35
1

Introduction

Between May 21 and June 3, 2015, Jeremy Begay, Clifford Werito, Shane Wero, Natasha 

Ignacio, and Jeffrey Begay, archaeologists with Dinétahdóó Cultural Resources Management 

(DCRM), conducted a field assessment of nine in-use sites and thirteen historic structures within 

2 km of Resolute Natural Resources’ McElmo Creek Unit in San Juan County, Utah. DCRM 

also conducted a literature search in the Navajo Nation Historic Preservation Department’s 

records room, which identified fifty previously documented archaeological sites. This work was 

conducted to fulfill NHPA requirements as requested by the U.S. Environmental Protection 

Agency, Region 9, for the undertaking. This cultural resources inventory was completed under 

the Navajo Nation Historic Preservation Department permit number B14288.

Description of Undertaking

Resolute Natural Resources, LLC contracted with DCRM to identify historic properties, as 

defined by the National Historic Preservation Act (NHPA) and its implementing regulations, 

within a 2 km Area of Potential Effect (APE) of the main flare at the McElmo Creek Unit Oil 

Production Facility (MCU Facility or Facility). 

Pursuant to Section 106 of the NHPA, and its implementing regulations at 36 CFR Part 800, 

prior to the approval of the expenditure of any funds on or prior to the issuance of any license for 

an undertaking, EPA is required to take into account the effects of its undertakings on historic 

properties. Consultation is required for all undertakings that have the potential to affect historic 

properties. Section 106 consultations assess whether historic properties exist within an 

undertaking’s area of potential effect and, if so, whether the undertaking will adversely affect 

such properties. The term “historic properties” means prehistoric or historic districts, sites, 

buildings, structures, or objects included in, or eligible for inclusion in, the National Register of 

Historic Places maintained by the Department of the Interior.

EPA’s undertaking triggering the application of the NHPA is the issuance of a federal Prevention 

of Significant Deterioration (PSD) air quality permit, in accordance with the Clean Air Act and 

PSD regulations (40 CFR 52.21), for the gas flare (called the “main flare”) at the MCU Facility. 

While the Facility is an existing oil and gas production operation located on the McElmo Creek 

Unit oilfield in San Juan County, Utah, our action is only for the gas flare which is used to 

destroy natural gas during any upsets of the natural gas gathering system. The United States 

Environmental Protection Agency (EPA) Region 9 is the lead federal agency for this 

undertaking. 

EPA is amending the PSD permit to incorporate pollution limits, terms, and conditions of a 

federal Consent Decree (United States v. Mobil Exploration and Producing U.S. Inc., Case No. 

2:05-CV-319, filed June 8, 2005) that specifically applies to the main gas flare at the MCU 

Facility. These pollution limits, terms, and conditions include Best Available Control 

Technology (BACT) emission limitations for nitrogen oxides, carbon monoxide, sulfur dioxide, 

and volatile organic compounds for the main flare at the MCU Facility. 

Additionally, EPA is amending the PSD permit to remove and update other applicable

requirements in the MCU Facility’s PSD permit due to equipment that has been shut down and 
2

removed from the site. Other than the potential replacement of a fixed speed fan with a variable 

speed fan to provide better pollution control at the already existing main flare, EPA’s action does 

not authorize any new construction or modification of existing equipment at the MCU Facility.

EPA issued the proposed permit for public comment on October 15, 2014. A final permit 

decision will be issued following completion of the Agency’s Section 106 NHPA consultation. 

DCRM’s identification of historic properties included a literature search to identify previously 

recorded cultural resources to determine if they qualified as historic properties under the NHPA 

(Figure 1) as well as a field assessment of existing Navajo in-use sites within the APE to 

determine if any of the structures are eligible for listing as historic properties (Figure 2).

Location

The project area is in San Juan County, Utah, on Navajo Nation Trust lands in the Aneth Chapter

(Figure 1). Table 1 provides the UTM coordinates and legal descriptions of the project area.

Table 1. UTM Coordinates, Legal Descriptions, and USGS Maps for the McElmo Creek Unit Main Flare 

Project.

Designation

UTM Coordinates

Zone 12 (NAD 83)

Legal Descriptions USGS Map Name 

(7.5’ Quadrangle)

Northing Easting 1⁄4 1⁄4 1⁄4 Sec. T R

Flare 4125157 0659112 SE SE SE 31 40S 25E Navajo Canyon, 

Utah, P.E. 1985

 * Denotes Unplatted 1⁄4 and Section Data 
3

Figure 1: Map showing project area and fifty previously documented archaeological sites (DCRM 2015-31).
4

Figure 2: Map showing project area and nine documented in-use sites (DCRM 2015-31). 
5

Existing Data Review

Prior to the fieldwork, a records check was conducted at the Navajo Nation Historic Preservation 

Department (NNHPD) in Window Rock, Arizona, to determine whether cultural resources 

inventories had been performed within the project area. The review indicated that numerous

large and small projects have been conducted within the project area, with fifty previously 

identified archaeological sites being recorded. Table 2 provides the site designation, type, and 

report in which the archaeological site was documented.

Table 2: List of previously documented archaeological sites in the McElmo Creek Unit Main Flare Project 

Area.

Designation Site Type NNHPD Report Number

UT-C-42-20 No Record at NNHPD

UT-C-42-22 Undated Lithic Scatter HPD 95-174

UT-C-42-23 Navajo Sweatlodge HPD 88-021

UT-C-42-34 No Record at NNHPD

UT-C-42-36 Undated Lithic Scatter HPD 85-556

UT-C-42-37 Multi-Component Undated Lithic Scatter 

and Historic Navajo Cairns

HPD 85-556

UT-C-42-40 Undated Lithic Scatter HPD 85-556

UT-C-42-41 No Record at NNHPD

UT-C-42-42 No Record at NNHPD

UT-C-42-48 Archaic Artifact Scatter HPD 98-021

UT-C-42-50 Undated Lithic Scatter HPD 88-021

UT-C-42-54 No Record at NNHPD

UT-C-42-57 No Record at NNHPD

UT-C-42-59 Navajo Sweatlodge HPD 88-021

UT-C-42-104 Multi-Component Undated Base Camp & 

Anasazi Activity Area

HPD 95-174

UT-C-42-105 No Record at NNHPD

UT-C-42-106 No Record at NNHPD

UT-C-42-108 Historic Refuse Area HPD 95-174

UT-C-42-110 Undated Lithic Scatter HPD 95-174

UT-C-42-113 Undated Sandstone Alignment HPD 88-021

UT-C-42-114 Historic Hearth HPD 88-021

UT-C-42-115 Undated Lithic Quarry HPD 88-021

UT-C-42-116 Undated Lithic Scatter HPD 88-021

UT-C-42-117 Multi-Component Undated Lithic Quarry 

and Navajo Habitation

HPD 88-021

UT-C-42-118 Undated Lithic Scatter HPD 88-021

UT-C-42-119 Anasazi Activity Area HPD 88-021

UT-C-42-120 Historic Rock Art HPD 88-021

UT-C-42-121 Undated Water Control Feature HPD 95-174, HPD 88-021

UT-C-42-122 Navajo Stone Enclosure HPD 88-021

UT-C-42-123 Historic Improvised Spring HPD 88-021

UT-C-42-124 Undated Stone Enclosure HPD 88-021

UT-C-42-125 Undated Lithic Scatter w/ Features HPD 88-021

UT-C-42-126 Historic Hearth HPD 88-021

UT-C-42-127 Historic Rock Art HPD 88-021

UT-C-42-128 Historic Corral & Lambing Pen HPD 88-021

UT-C-42-284 No Record at NNHPD

UT-C-42-381 Undated Activity Area HPD 95-174

UT-C-42-382 Undated Activity Area HPD 95-174
6

UT-C-42-400 No Record at NNHPD

UT-C-42-401 Archaic Camp HPD 97-470

UT-C-42-411 Anasazi Artifact Scatter and Petroglyphs HPD 99-339

UT-C-42-412 Anasazi Habitation HPD 99-339

UT-C-42-413 Historic Navajo Habitation HPD 99-339

UT-C-42-414 Undated Artifact Scatter HPD 99-339

UT-C-42-415 Undated Artifact Scatter HPD 99-339

UT-C-42-416 Undated Artifact Scatter HPD 99-339

UT-C-42-417 Historic Navajo Habitation HPD 99-339

UT-C-42-418 Undated Lithic Scatter HPD 99-339

UT-C-42-SA46161 No Record at NNHPD

UT-C-55-163 Historic Navajo Corral HPD 95-174

Environmental and Cultural Setting

The San Juan River is a braided channel system that serves as the main drainage for the San Juan 

Basin. Within the San Juan Valley are Navajo communities such as Upper Fruitland, Shiprock, 

Teec Nos Pos, and Aneth. The large, flat bottomed valley is incising numerous Cenozoic era 

geologic facies. Large sedimentary and igneous clasts ranging from pebbles to boulders have 

been deposited in the San River Valley from the nearby San Juan igneous belt to the north. Eons 

of erosion have created numerous named and unnamed secondary geologic and geographic 

features such as side tributaries, escarpments, terraces, hills, and floodplains. Surface sediments 

within the area consist of fine- to coarse-grained alluvial, fluvial, colluvial, aeolian, and residual 

packages of sand, silt, clay, and multi-lithic sand. The river, which flows year-round, supports a 

wide variety of native, cultivated, and foreign plant species. Prevalent flora in the area include

cottonwood, tamarisk, Russian olive, elm, cheat, brome, and grama grass, ring muhly, Russian 

thistle, prickly pear and cholla cacti, snakeweed, rabbitbrush, and tansy mustard.

The Navajo name for Aneth is Taa’ biich’ iidii, which means “Just like the devil,” a name

applied to the community’s first Anglo trader because of his business practices. Several land 

agreements and exchanges led to the incorporation of the Utah Navajo lands into the Navajo 

Reservation. There is extensive oil industry development in the Aneth area (LSR Innovations 

2004).

Field Methods

Between May 21 and June 3, 2015, Jeremy Begay, Clifford Werito, Shane Wero, Natasha 

Ignacio, and Jeffrey Begay, archaeologists with Dinétahdóó Cultural Resources Management 

(DCRM), conducted the cultural resources assessments of the historic and in-use properties in 

the project area. As described below, the previously recorded archaeological sites were not field

reassessed.

Historic Structure Identification and Inventory

Nine currently in-use sites were visited, including interviews with the residents and/or employees

regarding the age and cultural importance of structures that are at least 50 years old and that were 

deemed potentially eligible for protection under Section 106 guidelines.

Thirteen historic structures were identified during the inventory. Interviews with the owners of 

the historic structures provided information regarding the importance and history of the structure.
7

Locations of the cultural resources identified during the inventory were recorded using a handheld Global Positioning Satellite (GPS) unit. 

Cultural Resources Findings

Thirteen historic structures and nine in-use sites were documented during the inventory and are 

described in this section. An in-field assessment of the fifty previously documented 

archaeological sites was not conducted. The information provided in this report was collected 

during the literature search at the NNHPD records room and reflects the description and 

assessments made by the earlier recording. Information on thirty-nine sites was found; the 

remaining eleven previously identified archaeological sites had no documentation.

Archaeological Sites

Site: UT-C-42-22

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: No location information per NNHPD/NDOT guidelines in 1995

UTM (NAD83): No location information per NNHPD/NDOT guidelines in 1995

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Lithic Scatter

Site Size: 410m x 480m

Site Setting: In a drainage basin below a bench south of Cajon Mesa.

Site Description: UT-C-42-22 is an undated lithic scatter with no recorded features. It has been 

recorded twice, once in 1989 and again in 1993 by Navajo Nation Archaeology Department 

(NNAD) archaeologists. UT-C-42-22 is composed of nondiagnostic flaked lithic artifacts. Also, 

two rock shelters were recorded underneath the sandstone bench. In 1993, one McElmo Blackon-white ceramic sherd was documented in the site area, although the artifact was recorded as an 

isolated occurrence. UT-C-42-22 may date to the Archaic.

Site: UT-C-42-23

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4125142, E 0659017

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Navajo Sweat Lodge

Site Size: 12m x 25m

Site Setting: On a sandstone outcrop along the crest of a ridge finger.

Site Description: UT-C-42-23 contains the remnants of a Navajo sweat lodge that was originally 

recorded in 1984 by NNAD archaeologists and revisited in 1988 by NNAD archaeologists. There 

are no visible structural remains of the sweat lodge; the site consists of charcoal, ash, firecracked rock, a wire brush, and four lithic artifacts. The single feature (Feature 1) measures 2.5m 

x 1.5m and included fragments of charcoal, ash, and fire-cracked rock. Surrounding feature 1 is a 

general scatter of fire-cracked rock measuring 20m x 10m in which a wire brush and four lithic 
8

flakes where also recorded. The presence of charcoal in Feature 1 suggested that the site was 

fairly recent in age. No other features or artifacts were recorded during the inventory.

Site: UT-C-42-36

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Sec 5, T41S, R25E

UTM (NAD83): Zone 12, N 4124502, E 0660562

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Lithic Scatter

Site Size: 150m x 90m

Site Setting: At the edge of a terrace overlooking a large drainage.

Site Description: UT-C-42-36 is an undated lithic scatter with one recorded feature. Feature 1 is 

a collapsed hearth with an artifact concentration consisting of flaked and ground stone artifacts 

with no formalized tools other than a bifacially smoothed, one-hand sandstone mano. UT-C-42-

36 may have served as a lithic reduction site with a minimal amount of food processing. It may 

date to the Archaic.

Site: UT-C-42-37

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Sec 5, T41S, R25E

UTM (NAD83): Zone 12, N 4124952, E 0660112

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Multicomponent Undated Lithic Scatter & historic Navajo cairns

Site Size: 110m x 110m

Site Setting: At the edge of a terrace overlooking a large drainage.

Site Description: UT-C-42-37 is a multicomponent undated lithic scatter and historic Navajo 

cairn site with three features. Feature 1 is a collapsed hearth and has been assigned to the 

prehistoric component. It consists of a scattering of sandstone blocks intermixed with flaked 

stone artifacts. Other artifacts attributed to the prehistoric component include flaked and ground

stone tools. Features 2 and 3 are included in the historic Navajo component. Both are in the 

eastern site area. They are stacked sandstone slab and block cairns with no other related material 

nearby. The prehistoric component may date to the Archaic.

Site: UT-C-42-40

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Sec 4, T41S, R25E

UTM (NAD83): Zone 12, N 4124300, E 0661190

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Lithic Scatter

Site Size: 20m x 10m

Site Setting: UT-C-42-40 is located on a semi-stabilized sand dune ridge. 
9

Site Description: UT-C-42-40 is an undated lithic scatter that was originally recorded in 1985 by 

Navajo Nation Archaeology Department (NNAD) archaeologists. The 1985 NNAD survey 

recorded a scattering of flaked lithic artifacts including a scraper tool. No other features or 

artificats were recorded. No diagnostic artifacts were observed, however, sites that contain this 

sort of artifact assemblage are usually attributed to Archaic groups.

Site: UT-C-42-48

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Sec 32, T40S, R25E

UTM (NAD83): Zone 12, N 4125552, E 0659587

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Archaic Artifact Scatter

Site Size: 20m x 85m

Site Setting: In a road cut in a stabilized sand dune. 

Site Description: UT-C-42-48 is an Archaic artifact scatter that was originally recorded in 1985 

by NNAD archaeologists. The site was last visited in 1997 by Complete Archaeological Service 

Associates (CASA) archaeologists in conjunction with a CO2 pipeline project. The 1985 NNAD 

survey recorded a scattering of flaked lithic artifacts and several sandstone slab piles that were 

attributed to the prehistoric Archaic occupation. In the 1997 survey, CASA archaeologists 

determined that the sandstone piles were remnants of oil field activity and that the majority of the 

artifacts recorded by the NNAD archaeologists had since been redeposited by various oil field 

activities, and that very few artifacts remained in situ. A single broken projectile point base 

contained characteristics attributable to Archaic traditions.

Site: UT-C-42-50

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4125552, E 0660037

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Lithic Scatter

Site Size: 130m x 310m

Site Setting: In a field of stabilized sand dunes surrounded by ephemeral arroyos.

Site Description: UT-C-42-50 is an undated lithic scatter that was originally recorded in 1985 by 

NNAD archaeologists and was revisited by NNAD in 1988 in conjunction with a well-pad 

survey. The artifact assemblage consisted of 165 chipped stone artifacts, including Brushy Basin 

chert flakes, cores, retouched nodules, scrapers, quartzite flakes, and siltstone flakes. No features 

were observed during the inventory. UT-C-42-50 may be Archaic.

Site: UT-C-42-59

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 41N, R25E

UTM (NAD83): Zone 12, N 4124862, E 0659267
10

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Navajo Sweat Lodge

Site Size: 27m x 24m

Site Setting: On a low-lying knoll at the edge of a terrace.

Site Description: UT-C-42-59 is a historic Navajo sweat house that was originally recorded in 

1985 by NNAD archaeologists and was revisited by NNAD in 1988 in conjunction with a wellpad survey. UT-C-42-59 consists of four features and several historic artifacts. Feature 1 appears 

to be a sweathouse with a pile of approximately 250 fire-reddened sandstone fragments that 

measures 4m in diameter. Feature 2 appears to be the remnants of a ramada with a scattering of 

artifacts (1 food can, 1 hub cap) and 55 juniper branches in an area measuring 7m x6m. Feature 3 

consists of 25 burnt sandstone fragments, ash, and a charcoal pile that measures 3m in diameter. 

Feature 4 consists of 2 shards of milk glass and approximately 200 fire-reddened sandstone 

fragments scattered in an area measuring 12.5m x 8.5m that does not appear to contain 

subsurface materials. No other features or artifacts were recorded. 

Site: UT-C-42-104

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: No location information per NNHPD/NDOT guidelines in 1995

UTM (NAD83): No location information per NNHPD/NDOT guidelines in 1995

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Multi-component Undated Base Camp & Anasazi Activity Area

Site Size: 125m x 150m

Site Setting: On the west side of an ephemeral south-oriented arroyo.

Site Description: UT-C-42-104 is a heavily damaged multicomponent undated base camp & 

Anasazi activity area with no recorded features. The undated prehistoric component is a scatter

of undiagnostic flaked and ground stone artifacts. The Anasazi activity area has several hearths 

and ceramic sherds as well as flaked and ground stone artifacts. In 1994, NNAD archaeologists 

reported that UT-C-42-104 had been heavily damaged when heavy vehicles had been used to 

remove soil in the site area for use elsewhere. These activities had severely disturbed and even 

destroyed several of the hearths. Nevertheless, the NNAD archaeologists believed that UT-C-42-

104 may contain subsurface cultural deposits in the undamaged areas.

Site: UT-C-42-108

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: No location information per NNHPD/NDOT guidelines in 1995

UTM (NAD83): No location information per NNHPD/NDOT guidelines in 1995

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Historic Refuse Area

Site Size: 9m x 13m

Site Setting: In a relatively flat area bisected by a pipeline.
11

Site Description: UT-C-42-108 is a historic refuse area with no recorded features. It was 

recorded in 1988 by NNAD archaeologists in conjunction with a pipeline survey. The site is 

composed of trash presumed to have been discarded by the employees who constructed the 

pipeline in the 1960s. The artifact assemblage consists of metal cans, broken ceramic mugs, and 

several glass soda bottles.

Site: UT-C-42-110

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: No location information per NNHPD/NDOT guidelines in 1995

UTM (NAD83): No location information per NNHPD/NDOT guidelines in 1995

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Lithic Scatter

Site Size: 100m x 60m

Site Setting: On the west slope of a ridge east of Allen Canyon.

Site Description: UT-C-42-110 was an undated lithic scatter originally recorded in 1988 by 

NNAD archaeologists. It was composed of flaked lithic artifacts, none of which were diagnostic. 

UT-C-42-110 was revisited in 1994 by NNAD archaeologists, who determined that the site had 

been destroyed by pipeline activities in the immediate area. No trace of cultural materials was

observed in the site area or nearby. At least two pipelines had been constructed in the site area 

since it was first recorded in 1988.

Site: UT-C-42-113

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4126122, E 0659067

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Sandstone Alignment

Site Size: 4m x 3m

Site Setting: On level terrain on top of a terrace.

Site Description: UT-C-42-113 is an undated sandstone alignment that was originally recorded in 

1988 by NNAD archaeologists in conjunction with a well-pad survey. The artifact assemblage 

consists of a single chert flake and a stacked sandstone wall alignment that measures 1.70m x 

0.60m. The flake may be from a lithic procurement site (UT-C-42-115) located 130m to the 

north. No other artifacts or features were recorded.

Site: UT-C-42-114

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4126142, E 0659097

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Historic Hearth
12

Site Size: 2.50m x 1.80m

Site Setting: On level terrain on top of a terrace.

Site Description: UT-C-42-114 is a historic hearth that was originally recorded in 1988 by 

NNAD archaeologists in conjunction with a well-pad survey. It consists of one feature and ashy 

soil, charcoal, burnt paper, and a piece of metal. Feature 1 appears to be the remains of a singleepisode hearth. It may be associated with herding activities. No other artifacts or features were 

recorded or observed. 

Site: UT-C-42-115

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4126302, E 0659127

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Lithic Quarry

Site Size: 70m x 57m

Site Setting: On level to gently rolling terrain on top of a terrace.

Site Description: UT-C-42-115 is an undated lithic quarry that was originally recorded in 1988 

by NNAD archaeologists in conjunction with a well-pad survey. The artifact assemblage consists 

of chipped stone artifacts and cores in an area measuring 80m in diameter. None of the artifacts 

are diagnostic. An in-use feature in the southeastern portion of the site is a small dump adjacent 

to a corral that is part of an IUS. No other artifacts or features were recorded or observed.

Site: UT-C-42-116

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4126252, E 0658947

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Lithic Scatter

Site Size: 60m x 32m

Site Setting: On level to rolling terrain on top of a terrace.

Site Description: UT-C-42-116 is an undated lithic scatter with one feature that was originally 

recorded in 1988 by NNAD archaeologists in conjunction with a well-pad survey. Feature 1 

consists of four upright sandstone slabs aligned in an “L” that measures 1.50m x 0.90m. The 

function of the feature is unknown. Southwest of Feature 1 is a lithic concentration measuring 75 

square meters. The site appears to be a specialized activity area associated with lithic reduction. 

The affiliation of the site cannot be determined, although it is almost certainly prehistoric. No 

other artifacts or features were recorded or observed.

Site: UT-C-42-117

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E
13

UTM (NAD83): Zone 12, N 4125662, E 0659897

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Multi-Component Undated Lithic Quarry and Historic Navajo Habitation

Site Size: 460m x 240m

Site Setting: On the top, west slopes, and bottom of an unnamed canyon near the canyon’s head.

Site Description: UT-C-42-117 is a multicomponent prehistoric lithic procurement area and a 

historic Navajo habitation. The prehistoric component consists of concentrations 1 through 10 

and five possible quarry areas (Features 19 through 22 and 28). The concentrations range from 

0.75 meters squared to 3,200 square meters. Feature 1 is a corral constructed of stacked 

sandstone slabs incorporated into a southeast-facing sandstone ledge with an overhang; it

measures 18m x 12m. Feature 24 appears to be the remains of a dugout incorporated into the 

lower slope of a dune; it measures 3m in diameter. Feature 25 is a shallow depression which 

measures 4.5m in diameter. At the margins of the depression are two upright sandstone slabs, six 

unmodified rectangular sandstone rocks, splinters of wood, and a short piece of wood with three 

nails; this feature may be the remains of a hogan whose materials have been salvaged. Feature 26 

is a concentration of small unshaped pieces of sandstone covering an area 8.4m in diameter. 

Feature 27 consists of three upright sandstone slabs and two unmodified sandstone blocks; the 

feature measures 4.8m in diameter. Feature 2 is a concentration of ash, charcoal, a coffee pot lid, 

a slide-on lid, 2 clear glass fragments, a shoe sole, a sheep rib bone, and several pieces of firereddened sandstone in an area measuring 1m x 2m. Feature 3 is a sandstone hogan with an 

interior diameter of 3.50m. Feature 4 is a hogan base; no dimensions are given for this mostly 

dismantled feature. Feature 5 is an ash pile measuring 3m x 4m with charcoal and burnt 

sandstone fragments. Feature 6 is a hogan ring measuring 3m in diameter. Feature 7 is a 

sandstone corral measuring 18m x 26m; associated artifacts include 2 slide-on lids and 1 

sheepherder’s shaker can with wire handle. Feature 8 is a sandstone enclosure measuring 2.90m 

x 2.20m. Feature 9 consists of an ash pile that measures1m x 1.50m. Feature 10 is an ash pile 

with historic artifacts; it measures 1.60m in diameter. Feature 10 may be associated with Feature 

11, a sandstone hogan outline that measures 2.30m in diameter. Feature 12 is a sandstone 

enclosure of unknown function; it measures 1m x 2m. Feature 13 is an ash pile that measures 

1.50m in diameter and contains a single sandstone mano fragment. Feature 32 is a sandstone 

hogan outline measuring 3.50m in diameter. Feature 14 is a cairn measuring 100cm x 75cm; this 

feature is of relatively recent in origin. Feature 15 is a cairn that measures 70cm x 35cm. Feature 

16 is also a cairn, measuring 70cm x 35cm. Feature 17 is a cairn that measures 37cm x 34cm. 

Feature 18 is a collapsed cairn; no measurements were provided. Feature 30 is a cairn measuring 

30cm x 30cm. Feature 29 is a sandstone enclosure in a natural crevice; it measures 1.50m x 

0.90m. Feature 13 is a short sandstone alignment that is 1.02m long. No other features or 

artifacts were recorded at the site.

Site: UT-C-42-118

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4125835, E 0661672

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth
14

Site Type: Undated Lithic scatter

Site Size: 45m x 25m

Site Setting: On level terrain on top of a high terrace.

Site Description: UT-C-42-118 consists of sparse lithic concentrations with no features. 

Concentration 1 measures approximately 80 square meters. Concentration 2 covers 144 square 

meters. The site may be a chipping station. No other artifacts were recorded. It may date to the 

Archaic.

Site: UT-C-42-119

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 41N, R25E

UTM (NAD83): Zone 12, N 4124452, E 0658197

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Anasazi Activity Area

Site Size: 45m x 25m

Site Setting: On top of a knoll.

Site Description: UT-C-42-119 consists of a sparse sherd and lithic scatter with 1 feature. 

Feature 1 consists of ashy soil with fewer than 10 small burnt sandstone fragments. It appears to 

be a hearth that measures approximately 50cm in diameter. The artifact assemblage includes 

Brushy Basin chert flakes, 2 Mancos Corrugated sherds, 3 Deadman’s Black-on-red sherds, and 

several unidentified grayware sherds. No other artifacts or features were recorded. It probably 

represents a single use site.

Site: UT-C-42-120

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 41N, R25E

UTM (NAD83): Zone 12, N 4124452, E 0658197

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Historic Rock Art

Site Size: 1m x 1m

Site Setting: At the base of a low sandstone ledge.

Site Description: UT-C-42-120 consists of two incised rock art panels. Panel 1 measures 3.50cm 

long and has what appears to be an “I” followed by an “E” followed by two parallel lines. Panel 

2 measures 5.30cm long and contains a single (Yei?) figure made of triangles which form the 

head, body, and hands. The site is not considered not to have any subsurface cultural deposits. 

No other petroglyphs, artifacts, or features were recorded.

Site: UT-C-42-121

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: No location information per NNHPD/NDOT guidelines in 1995

UTM (NAD83): No location information per NNHPD/NDOT guidelines in 1995
15

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Water Control Feature

Site Size: 9m x 7m

Site Setting: On top of a sandstone outcrop on the west side of an ephemeral drainage.

Site Description: UT-C-42-121 is an undated water-control feature. Feature 1 is a dry-laid 

sandstone wall constructed in a small basin on top of a sandstone bedrock outcrop. Feature 1 was 

constructed to contain water in a shallow basin in the bedrock. No diagnostic artifacts were 

observed in the immediate area so the age of the feature is unknown. No other features or 

artifacts were recorded.

Site: UT-C-42-122

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4125382, E 0659307

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Stone enclosure

Site Size: 5m x 5m

Site Setting: On a steep, south-facing talus slope that forms the side of a V-shaped tributary to 

Allen Canyon.

Site Description: UT-C-42-122 consists of a stone enclosure. Feature 1 is a sandstone wall that 

encloses a space between two large boulders; it measures 1.50m x 0.95m. The site appears to 

have functioned as a lambing pen. No other features or artifacts were recorded.

Site: UT-C-42-123

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4125092, E 0659027

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Historic Improved Spring

Site Size: 44m x 24m

Site Setting: At the head of a small southwest-trending canyon that joins an unnamed tributary of 

Allen Canyon.

Site Description: UT-C-42-123 is an improved spring site with three features: a spring house, 

pump platform, stacked rock trail, and a sparse trash scatter that was not given a feature number. 

Feature 1 is a semicircular spring house measuring 8m in diameter; in front of Feature 1 is a 

sandstone alignment measuring 5m long. Feature 2 is a concrete slab with an unattached castiron hand pump; the slab measures 1.70m x 1.50m. Feature 3 is a trail that extends from the top 

of the sandstone ledge down the side of the canyon; it is 19m long and 2m wide. The site is a 

historic improvement of a natural feature. No other features or artifacts were recorded.
16

Site: UT-C-42-124

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4125192, E 0659287

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated stone enclosure

Site Size: 19m x 14m

Site Setting: On a ridge at the head of a tributary to Allen Canyon.

Site Description: UT-C-42-124 consists of two sandstone enclosures. Feature 1 is a stacked stone 

and stick enclosure formed between a crack in a large sandstone boulder; the feature measures 

1.50m x 0.50m. Feature 2 is a sandstone wall that encloses an 0.45m x 1.50m area. The features 

are probably lambing pens or caches associated with herding activities. No other features or 

artifacts were recorded.

Site: UT-C-42-125

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 41N, R25E

UTM (NAD83): Zone 12, N 4124902, E 0659367

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Lithic Scatter with Features.

Site Size: 85m x 45m

Site Setting: In the deflation basin of a sand dune.

Site Description: UT-C-42-125 consists of two features and a lithic scatter. Feature 1 measures 

1.40m x 1m and consists of the burnt sandstone remains of a collapsed hearth. Feature 2 is a pile 

of fire-reddened sandstone measuring 1.50m x1.20m, also indicating a collapsed hearth. A lithic 

scatter north of Feature 1 represents a chipped stone reduction area of unknown size. No other 

features or artifacts were recorded.

Site: UT-C-42-126

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 41N, R25E

UTM (NAD83): Zone 12, N 4124882, E 0659037

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Historic Hearth

Site Size: 10m x 20m

Site Setting: At the base of a cliff.

Site Description: UT-C-42-126 consists of a single feature and a scatter of historic artifacts. 

Feature 1 is a scatter of charcoal that measures 4m x 1.20m. The charcoal extends downstream to 

the west. Artifacts included a coffee can, Styrofoam cups, a base from a plastic cup, and 5 ax-cut 

wood chips. No other features or artifacts were recorded. 
17

Site: UT-C-42-127

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 41N, R25E

UTM (NAD83): Zone 12, N 4124942, E 0659007

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Historic Rock Art

Site Size: 11m x 7m

Site Setting: On a pinnacle and cliff face above a tributary to Allen Canyon.

Site Description: UT-C-42-127 consists of 4 rock art panels; no features or measurements were 

provided. The rock art panels appear to be quite recent. No other features or artifacts were 

recorded.

Site: UT-C-42-128

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4125082, E 0659157

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Historic Corral and lambing pen

Site Size: 85m x 23m

Site Setting: At the head of a tributary to Allen Canyon.

Site Description: UT-C-42-128 consists of 5 features and a sparse artifact scatter. Feature 1 is a 

sandstone enclosure that measures 2m x 0.90m. Feature 2 is sandstone enclosure in a small break 

in the cliff face; it measures 2.40m in diameter. Feature 3 is a sandstone wall measuring 4.30m. 

Feature 4 is a sandstone wall measuring 2.70m. Feature 5 is sandstone wall that runs 21m to a

wall corner and then extends another 9m. Features 3, 4, and 5 are segments of a sandstone corral. 

No measurements or details on the historic artifact scatter were noted. No other features or 

artifacts were recorded.

Site: UT-C-42-381

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: No location information per NNHPD/NDOT guidelines in 1995

UTM (NAD83): No location information per NNHPD/NDOT guidelines in 1995

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Activity Area

Site Size: 10m x 55m

Site Setting: In a road cut and a deflated sand dune.

Site Description: UT-C-42-381 is an undated activity area with no recorded features. UT-C-42-

381 is composed of artifacts in a road cut and on the slope of a sand dune. The assemblage 

includes flaked stone artifacts, four pieces of tabular sandstone, and one quartz river cobble. 
18

When it was recorded in 1995, an ash lens was also observed in the road cut. UT-C-42-381 may 

date to the Archaic occupation.

Site: UT-C-42-382

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: No location information per NNHPD/NDOT guidelines in 1995

UTM (NAD83): No location information per NNHPD/NDOT guidelines in 1995

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Activity Area

Site Size: 60m x 45m

Site Setting: On a deflating sand dune.

Site Description: UT-C-42-382 is an undated activity area with no recorded features. The 

scattered artifacts consist of flaked and ground stone and two clusters of fire-cracked rock. 

Subsurface cultural deposits may occur in the western area of the site in the undisturbed sand 

dune. No diagnostic artifacts were observed, although other sites containing assemblages of this 

type have been attributed to Archaic groups.

Site: UT-C-42-401

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Sec 30, T40S, R25E

UTM (NAD83): Zone 12, N 4127220, E 0658740

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Archaic Camp

Site Size: 52m x 42m

Site Setting: On a stabilized sand dune below Cajon Mesa.

Site Description: UT-C-42-401 is an Archaic camp with no recorded features. The flaked lithic 

artifacts at the site are a rhyolite tool, a cobble chopper, ten flakes, and a scatter of fire-cracked 

sandstone fragments. UT-C-42-401 was originally recorded in 1997 by Complete Archaeological 

Service Associates (CASA) archaeologists in conjunction with a CO2 pipeline survey. CASA 

archaeologists reported that the site was impacted by the installation of a pipeline prior to 1997 

and that the construction activities likely altered the location of the materials. Additional cultural 

materials may occur in the areas furthest from the pipeline.

Site: UT-C-42-411

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 41N, R25E

UTM (NAD83): Zone 12, N 4124572, E 0660477

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Artifact Scatter and Petroglyphs

Site Size: 82m x 31m

Site Setting: On and below a south-facing rocky point.
19

Site Description: UT-C-42-411 consists of 1 feature, an artifact scatter, and petroglyphs. Feature 

1 is a rubble pile measuring 2m in diameter that represents a small room. No measurements or 

descriptions of the petroglyphs or artifact scatter are given. No other features or artifacts were 

recorded.

Site: UT-C-42-412

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 41N, R25E

UTM (NAD83): Zone 12, N 4124882, E 0659787

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Anasazi Habitation

Site Size: 76m x 40m

Site Setting: Under a sandstone ledge on a slope.

Site Description: UT-C-42-412 consists of the remains of 3 rooms and lithic scatter. Rooms 1 

and 2 each measure 2m x 2m. Room 3 is 4m x 5m. No measurement or description of the artifact 

scatter is given. The site is probably a seasonal Anasazi habitation of Pueblo II age. No other 

features or artifacts were recorded. 

Site: UT-C-42-413

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 41N, R25E

UTM (NAD83): Zone 12, N 4124782, E 0659247

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Historic Navajo Habitation

Site Size: 42m x 23m

Site Setting: On top of a small sandstone ledge at the base of a steep, boulder-strewn slope.

Site Description: UT-C-42-413 consists of 3 features. Feature 1 is a sandstone hogan ring which 

measures 3m in diameter. Feature 2 is a series of rock alignments; no measurements or estimated 

function was recorded. Feature 3 is a 40cm diameter semicircular outline of stacked sandstone 

fragments. No other features or artifacts were recorded.

Site: UT-C-42-414

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 41N, R25E

UTM (NAD83): Zone 12, N 4124782, E 0660477

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Artifact scatter

Site Size: 144m x 96m

Site Setting: On top of a small sandstone mesa.
20

Site Description: UT-C-42-414 consists of 3 artifact concentrations. No measurements are given. 

This site may be related to nearby UT-C-42-414. A 60m space with no flaked lithic artifacts and 

a vertical drop-off warranted separation of the 2 sites. The site may have intact subsurface 

deposits and/or features. No diagnostic artifacts were observed, although other sites containing 

assemblages of this type have been attributed to Archaic groups.

Site: UT-C-42-415

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4126452, E 0659337

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Artifact scatter

Site Size: 50m x 28m

Site Setting: On rolling terrain on the northwest slope of a sand dune.

Site Description: UT-C-42-415 consists of an artifact concentration with no associated features. 

The size of the artifact concentration is not recorded. The artifacts are primarily exposed in a 

two-track road. A few scattered flakes occur outside of the roadbed. The fact that the vast 

majority of the flakes are exposed in the road cut suggests intact subsurface cultural deposits 

and/or features could be present. No other features or artifacts were recorded. No diagnostic 

artifacts were observed, although other sites containing assemblages of this type have been 

attributed to Archaic groups.

Site: UT-C-42-416

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4125422, E 0660197

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Artifact scatter

Site Size: 138m x 54m

Site Setting: Between two sand dunes and along the top of the easternmost sand dune.

Site Description: UT-C-42-416 contains two discrete flake concentrations. Locus A is the 

smaller of the two. Locus B contains the vast majority of the flakes. No measurements are given. 

Several areas of low-density scattered sandstone fragments on the site are also conspicuous. 

Intact subsurface cultural deposits and/or features are likely present. UT-C-42-416 may be 

associated with the Site UT-C-42-50 located to the north. No other features or artifacts were 

recorded. No diagnostic artifacts were observed, although other sites containing assemblages of 

this type have been attributed to Archaic groups.

Site: UT-C-42-417

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4125662, E 0659897
21

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Historic Navajo habitation

Site Size: 52m x 60m

Site Setting: Near the lower end of a talus slope along a cliff face.

Site Description: UT-C-42-417 consists of a historic Navajo habitation with 4 features. Feature 1 

is a stacked sandstone hogan ring with deteriorated axe-cut log fragments; it measures 2.4m in 

diameter. Feature 2 is a 2m x 1m sandstone enclosure. Feature 3 is a rock pile south of a small 

boulder and may be a burial. Feature 4 is a stacked sandstone enclosure formed around several 

small boulders but there is no indication of its size. Ethnographic consultations were unable to 

produce any information regarding the site. UT-C-42 417 has been highly disturbed by a 

bulldozer cut right through the middle of the site. No other features or artifacts were recorded.

Site: UT-C-42-418

USGS Map Reference: Navajo Canyon, Utah, P.E. 1985

Legal Location: Platted, 40N, R25E

UTM (NAD83): Zone 12, N 4125802, E 0659137

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Undated Lithic scatter

Site Size: 82m x 64m

Site Setting: Near a small butte.

Site Description: UT-C-42-418 consists of 1 artifact concentration, 1 feature, and 1 possible 

feature. Feature 1 is a 1.5m circular outline of collapsed sandstone. No indication of the size of 

the artifact concentration is mentioned in the report. A possible feature is an incomplete oval 

outline of rocks west of Feature 1. The site has some potential for intact subsurface cultural 

deposits and/or features. No diagnostic artifacts were observed, although other sites containing 

assemblages of this type have been attributed to Archaic groups.

Site: UT-C-55-163

USGS Map Reference: Aneth, Utah, P.E. 1989

Legal Location: No location information per NNHPD/NDOT guidelines in 1995

UTM (NAD83): No location information per NNHPD/NDOT guidelines in 1995

Land Status: Navajo Tribal Trust

State: Utah County: San Juan Chapter: Aneth

Site Type: Historic Navajo Corral

Site Size: 65m x 43m

Site Setting: At the head of an ephemeral drainage on a west-facing terrace below a ridge.

Site Description: UT-C-55-163 is a historic Navajo corral and lambing pen recorded in 1993 by 

NNAD archaeologists in conjunction with a road survey. Many of the corral walls incorporated 

sandstone boulders. Two crushed metal cans were observed within the corral, which was dated to 

1909 by ethnographic interviews. The lambing pen is south of the main corral and was 
22

constructed using dry laid sandstone blocks and slabs. No other features or artifacts were 

recorded.

In-Use Sites

During the survey, nine in-use sites (IUSs) were identified and recorded. Five are Navajo 

extended family communities and four are Resolute Natural Resources facilities. Also, in 

accordance with Navajo Nation Historic Preservation Department policies, the project 

archaeologists interviewed several Navajo residents about any traditional cultural properties or 

unmarked burials in the area. The interviews were conducted in English and Navajo. A brief 

description of the identified IUSs and the interview results can be found in Table 3.

Table 3: In-Use Site Summary Table and interview results.

In-Use Site # and 

Client Name

Summary of Structures Contact Person Interview Data and 

Occupation Dates

IUS #1-Anna B. Oldman 

& Emma Benally family

-One Modern Yellow 

House (2000)

-One Modern/Stone 

House (1950s)

-One Stone House 

(1950s)

-One Hogan (1980s)

-One Pink House

(1950s)

-One House (Ruin)

(1950s)

-One Ceremonial Hogan

(1990s)

-One Modern Blue House

(1980s)

-Corral #1 (1970s)

-Corral #2 (1970s)

-Sweathouse #1

Anna B. Oldman

Emma Benally

Leslie Oldman

Ms. Oldman identified 4 

historic structures and 4

traditionally used 

structures. The family has 

been living here since the 

1940s. 

IUS #2-Dora 

Todacheenie and Harold 

Benally family

-One shed (1950s)

-One Blue House (1950s)

-One Brown House 

(1950s)

-One Garage

(1980s)

-One Gray House (1950s)

-One Modern White 

House (1980s)

-Corral #3 (1970s)

-Corral #4 (1970s)

Dora Todacheenie

Clara Todacheenie

June Benally

Harold Benally

Desirae Todacheenie

Mrs. Dora Todacheenie 

identified 4 historic 

structures. Mr. Harold 

Benally identified 2 

traditionally used 

structures. The family has 

been living here since the 

1940s. 

IUS #3-Flora 

Todacheenie Family

-One mobile home 

(1980s)

-One blue hogan (1980s)

-One modern house under 

construction.

(2014)

-Sweathouse #2

(2000s)

Florence Todacheenie No Historic properties, 

TCPs, or Burials. Family 

has been living here since 

the 1980s. 

IUS #4-Betty Ann -One mobile home Betty Ann Norton No Historic properties, 
23

Norton family (1990s)

-One Modern House 

(1980s)

-One Hogan

(1980s)

TCPs, or Burials. Family 

has been living here since 

the 1980s.

IUS#5-Emma Begay, 

Louise Tapaha, and Kee 

Tapaha Family

-One Modern House 

(1980s)

-One Modular Home 

(2000s)

Emma Begay

Crystal Tapaha

Louise Tapaha

Kee Tapaha

No Historic properties, 

TCPs, or Burials. Family 

has been living here since 

the 1980s.

IUS#6-Resolute 

Equipment Area

Resolute Equipment 

Holding Area

Resolute Personnel No Historic properties, 

TCPs, or Burials. 

IUS #7-Resolute Offices 

and McElmo Flare

Resolute Offices and 

McElmo Flare

Resolute Personnel No Historic properties, 

TCPs, or Burials. Facilities 

installed in the 1980s.

IUS #8-Resolute Oil & 

Gas Pad with Storage 

Tanks

Resolute Oil & Gas Pad 

with Storage Tanks

Resolute Personnel No Historic properties, 

TCPs, or Burials. 

IUS#9-Resolute 

Equipment Area

Resolute Equipment 

Storage Area

Resolute Personnel No Historic properties, 

TCPs, or Burials. 

Historic Structures

Thirteen structures were identified as being historic and eligible for listing as historic properties 

according to the NHPA. DCRM archaeologists, through ethnographic interviews, obtained 

information regarding the structures and their importance to the residents to whom they belong. 

Information regarding the thirteen historically significant structures can be found below.
24

Structures recorded in IUS 1

Modern/Historic House (Structure 1). This home was constructed by Big John and Curley 

John in the early 1950s. The original home was constructed from shaped sandstone that was 

quarried from a nearby sandstone source. An addition was added to the home in the 1980s. The 

home is still in-use and is occupied by the Anna B. Oldman family. 

Pink Historic House (Structure 2). The home was constructed by Big John in the late 1950s. 

Modern materials were used to construct the home. The house is L-shaped and has a cement 

porch on the north side. The home is presently unoccupied and is slowly deteriorating. 
25

Stone Historic House (Structure 3). The home was originally constructed in the late 1920s by 

Curley John and Big John. The materials for the home were quarried from a sandstone source 

nearby and transported by a wheelbarrow. The home is currently unoccupied. 

Historic House (Ruin) (Structure 4). The home was originally built in the 1930s by Big John 

and Tom Skeezie. As with the other stone structures, the materials were quarried from a nearby 

sandstone source and transported by wheelbarrow; only the north wall and half of the east wall 

are still standing. Some fruit trees are still growing on the north side. The home is unoccupied. 
26

Structures Recorded in IUS 2

Historic Shed (Structure 5). This shed was built in the late 1950s by Harry Todacheenie. The 

shed was primarily used for storing tools and equipment for the Todacheenie family. The shed is 

still in use. 

Historic Home (Desirae Todacheenie) (Structure 6). This home belongs to Desirae 

Todacheenie and was originally built in the late 1950s by Harry Todacheenie and Harold 

Benally. The original home was smaller, but recent additions have increased the size of the 

home. The home is currently occupied by Ms. Desirae Todacheenie. 
27

Historic Home (June Benally) (Structure 7). This home was originally built in the late 1950s

by Harry Todacheenie and Harold Benally. The home features a stone wall and fenced yard. 

Another addition is being planned. Currently, the home is under construction and is occupied by 

Ms. June Benally. 

Historic Home (Dora Todacheenie) (Structure 8). This home was originally constructed in the 

late 1950s by Harry Todacheenie and Harold Benally. This home features a stone wall and there 

are recent additions to the home. The home is currently occupied by Ms. Dora Todacheenie and 

Ms. Clara Todacheenie. 
28

Traditional Cultural Properties

Although the identification of Traditional Cultural Properties was not an objective of the current 

undertaking, interviews with Navajo residents occupying the in-use residential sites provided 

data about four areas of traditional and cultural concern. These four Traditional Cultural 

Properties (TCPs) are two natural springs and two offering areas. Information gathered by the 

DCRM ethnographic inquiry for the four TCPs can be found in Confidential Appendix B.

Sweathouse #1 (Structure 5). This in-use sweathouse is used by the Anna B. Oldman family. 

The Plains-style sweathouse is made from tamarisk shafts bent over to make a dome that can be 

covered by a tarp or hides. In the middle of the sweathouse is a hollow pit where the heated rocks 

are placed. Near the sweathouse is a storage shelter and a cache of volcanic rocks for heating. 

The sweathouse is located on a ledge that overlooks the western horizon. The sweathouse is still 

in use by the Oldman family. No photographs were taken.

Corral #1 and Corral #2 (Structures 6 & 7). These corrals are located at IUS #1 and belong to 

the Anna B. Oldman family and the Emma Benally family. Both corrals have been blessed and 

are currently in use. 

Corral #3 and Corral #4 (Structures 12 & 13). These in-use corrals belong to the Todacheenie 

family. These corrals were first constructed in the late 1950s. The corrals have been blessed and 

contain birth cords from Harold Benally’s two sons. The corrals are made from scrap pieces of 

lumber and iron rebar. 

Evaluation of Significance

All cultural resources identified and recorded are evaluated for significance under certain federal 

statutes for the preservation and management of these resources. This process is intended to 

ensure that cultural resources are not inadvertently destroyed, and to ensure that local 

communities are involved in the decision-making process.

The National Historic Preservation Act

Under the Section 106 process of the National Historic Preservation Act (NHPA; 36 CFR 60.4), 

cultural resources may be eligible for nomination to the National Register of Historic Places if 

they are more than 50 years old and “possess integrity of location, design, setting, material, 

workmanship, feeling, and association.” One or more of the following criteria (a-d) must be 

applicable:

a. associated with events that have made a significant contribution to the broad patterns of 

our history; or

b. associated with the lives of a person significant in our past; or 

c. embody the distinctive characteristics of a type, period, or method of construction, or that 

represent the work of a master, or that possess high artistic values, or that represent a 

significant and distinguishable entity whose components may lack individual distinction; 

or 

d. has yielded, or may be likely to yield, information important in prehistory or history.
29

As defined in 36 CFR 60.4, cemeteries, birthplaces, or graves of historical figures; properties 

owned by religious institutions or used for religious purposes; structures that have been moved

from their original locations; reconstructed historical buildings; properties primarily 

commemorative in nature; and properties that have achieved significance within the past 50 

years are not ordinarily considered eligible for the National Register. However, such properties 

may qualify if they are integral parts of districts that do meet the eligibility criteria.

Table 4: NHPA Evaluation of Documented Cultural Resources in the McElmo Unit Main Flare Project Area. 

Cultural Resource No. Description Evaluation

UT-C-42-22 

(Previously Recorded)

Lithic Scatter NRHP Not Eligible

1. 50-year guideline met

2. Does not retain integrity

3. Does not meet criteria a-d

UT-C-42-23 

(Previously Recorded)

Navajo Sweatlodge NRHP Is Eligible

1. 50-year guideline met

2. Retains integrity of location, setting, 

association, design, and feeling.

3. Meets criterion d

UT-C-42-36 

(Previously Recorded)

Lithic Scatter NRHP Not Eligible

1. 50-year guideline met

2. Does not retain integrity

3. Does not meet criteria a-d

UT-C-42-37 

(Previously Recorded)

Multi-Component 

Undated Lithic Scatter 

and Navajo Habitation

NRHP Not Eligible

1. 50-year guideline met

2. Does not retain integrity

3. Does not meet criteria a-d

UT-C-42-39 

(Previously Recorded)

Undated Lithic Scatter NRHP Not Eligible

1. 50-year guideline met

2. Does not retain integrity

3. Does not meet criteria a-d

UT-C-42-40 

(Previously Recorded)

Undated Lithic Scatter NRHP Is Eligible

1. 50-year guideline met

2. Retains integrity of location, setting, 

and materials.

3. Meets criterion d

UT-C-42-48 

(Previously Recorded)

Archaic Artifact Scatter NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of location, 

materials, and setting.

3. Meets criterion d.

UT-C-42-50 

(Previously Recorded)

Undated Lithic Scatter NRHP Is Eligible

1. 50-year guideline met

2. Retains integrity of feeling, association, 

materials, setting, and workmanship

3. Meets criterion d
30

Cultural Resource No. Description Evaluation

UT-C-42-56 

(Previously Recorded)

Lithic Scatter NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, and materials.

3. Meets criterion d.

UT-C-42-59 

(Previously Recorded)

Navajo Sweatlodge NRHP Is Eligible

1. 50-year guideline met

2. Retains integrity of location.

3. Meets criterion d

UT-C-42-104 

(Previously Recorded)

Anasazi Activity Area NRHP Not Eligible

1. 50-year guideline met

2. Does not retain integrity

3. Does not meet criteria a-d

UT-C-42-108 

(Previously Recorded)

Historic Artifact Scatter NRHP Not Eligible

1. 50-year guideline met

2. Does not retain integrity

3. Does not meet criteria a-d

UT-C-42-110 

(Previously Recorded)

Lithic Scatter NRHP Not Eligible

1. 50-year guideline met

2. Does not retain integrity

3. Does not meet criteria a-d

UT-C-42-113 

(Previously Recorded)

Sandstone Alignment 

with Lithic Scatter

NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, design, workmanship, 

feeling, and association.

3. Does not meet criteria a-d

UT-C-42-114 

(Previously Recorded)

Hearth NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, workmanship, feeling, and 

association.

3. Meets criterion d

UT-C-42-115 

(Previously Recorded)

Lithic Quarry NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, workmanship, feeling, 

and association.

3. Meets criterion d

UT-C-42-116 

(Previously Recorded)

Undated Lithic Scatter 

with Features

NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, design, workmanship, 

feeling, and association.

3. Meets criterion d
31

Cultural Resource No. Description Evaluation

UT-C-42-117 

(Previously Recorded)

Multi-Component 

Undated Lithic Scatter 

and Navajo Habitation

NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, design, workmanship, 

feeling, and association.

3. Meets criterion d

UT-C-42-118 

(Previously Recorded)

Undated Lithic Scatter NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, workmanship, feeling, 

and association.

3. Meets criterion d

UT-C-42-119 

(Previously Recorded)

Anasazi Sherd and 

Lithic Scatter with 

Hearth

NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, design, workmanship, 

feeling, and association.

3. Meets criterion d

UT-C-42-120 

(Previously Recorded)

Navajo Rock Art NRHP Is Not Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, design, workmanship, 

and feeling.

3. Does not meet criteria a-d

UT-C-42-121 

(Previously Recorded)

Undated Water Control 

Feature

NRHP Is Not Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, design, workmanship, 

association, and feeling.

3. Does not meet criteria a-d

UT-C-42-122

(Previously Recorded)

Navajo Structure NRHP Is Not Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, design, workmanship, 

association, and feeling.

3. Does not meet criteria a-d

UT-C-42-123 

(Previously Recorded)

Navajo Improvised 

Structure

NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, design, workmanship, 

association, and feeling.

3. Meets criterion d.

UT-C-42-124 

(Previously Recorded)

Navajo Structure NRHP Is Not Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, design, workmanship, 

association, and feeling.

3. Does not meet criteria a-d
32

Cultural Resource No. Description Evaluation

UT-C-42-125 

(Previously Recorded)

Undated Artifact Scatter 

with Features

NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, association, and 

feeling.

3. Meets criterion d.

UT-C-42-126 

(Previously Recorded)

Historic Hearth NRHP Is Not Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

association, and feeling.

3. Does not meet criteria a-d

UT-C-42-127 

(Previously Recorded)

Navajo Rock Art NRHP Is Not Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, design, workmanship, 

association, and feeling.

3. Does not meet criteria a-d

UT-C-42-128 

(Previously Recorded)

Navajo Corral NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, design, workmanship, 

association, and feeling.

3. Meets criterion d.

UT-C-42-381 

(Previously Recorded)

Lithic Scatter NRHP Not Eligible

1. 50-year guideline met

2. Does not retain integrity

3. Does not meet criteria a-d

UT-C-42-382 

(Previously Recorded)

Lithic Scatter NRHP Not Eligible

1. 50-year guideline met

2. Does not retain integrity

3. Does not meet criteria a-d

UT-C-42-401

(Previously Recorded)

Archaic Camp NRHP Is Eligible

1. 50-year guideline met

2. Does not retain integrity.

3. Meets criterion d.

UT-C-42-411 

(Previously Recorded)

Anasazi Artifact Scatter 

with Features

NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, and workmanship.

3. Meets criterion d.

UT-C-42-412 

(Previously Recorded)

Artifact Scatter with 

possible habitation

NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, and workmanship.

3. Meets criterion d.
33

Cultural Resource No. Description Evaluation

UT-C-42-413 

(Previously Recorded)

Navajo Habitation NRHP Is Not Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, materials, and workmanship.

3. Does not meet criteria a-d

UT-C-42-414 

(Previously Recorded)

Artifact Scatter NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, and materials.

3. Meets criterion d

UT-C-42-415 

(Previously Recorded)

Lithic Scatter NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, and materials.

3. Meets criterion d

UT-C-42-416 

(Previously Recorded)

Artifact Scatter NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, and materials.

3. Meets criterion d

UT-C-42-417 

(Previously Recorded)

Navajo Habitation NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, and materials.

3. Meets criterion d

UT-C-42-418 

(Previously Recorded)

Artifact Scatter with 

Features

NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of setting, 

location, and materials.

3. Meets criterion d

UT-C-55-163

(Previously Recorded)

Navajo Corral NRHP Is Eligible

1. 50-year guideline met

2. Does retain integrity of location.

3. Meets criterion d.

UT-C-42-20

(Previously Recorded)

Unknown (Records not 

found at NNHPD 

records repository)

NRHP Eligibility is Unknown

1. 50-year guideline unknown

2. Unknown Integrity

3. Unknown criteria eligibility

UT-C-42-34

(Previously Recorded)

Unknown (Records not 

found at NNHPD 

records repository)

NRHP Eligibility is Unknown

1. 50-year guideline unknown

2. Unknown Integrity

3. Unknown criteria eligibility

UT-C-42-41

(Previously Recorded)

Unknown (Records not 

found at NNHPD 

records repository)

NRHP Eligibility is Unknown

1. 50-year guideline unknown

2. Unknown Integrity

3. Unknown criteria eligibility
34

Cultural Resource No. Description Evaluation

UT-C-42-42

(Previously Recorded)

Unknown (Records not 

found at NNHPD 

records repository)

NRHP Eligibility is Unknown

1. 50-year guideline unknown

2. Unknown Integrity

3. Unknown criteria eligibility

UT-C-42-54

(Previously Recorded)

Unknown (Records not 

found at NNHPD 

records repository)

NRHP Eligibility is Unknown

1. 50-year guideline unknown

2. Unknown Integrity

3. Unknown criteria eligibility

UT-C-42-57

(Previously Recorded)

Unknown (Records not 

found at NNHPD 

records repository)

NRHP Eligibility is Unknown

1. 50-year guideline unknown

2. Unknown Integrity

3. Unknown criteria eligibility

UT-C-42-105

(Previously Recorded)

Unknown (Records not 

found at NNHPD 

records repository)

NRHP Eligibility is Unknown

1. 50-year guideline unknown

2. Unknown Integrity

3. Unknown criteria eligibility

UT-C-42-106

(Previously Recorded)

Unknown (Records not 

found at NNHPD 

records repository)

NRHP Eligibility is Unknown

1. 50-year guideline unknown

2. Unknown Integrity

3. Unknown criteria eligibility

UT-C-42-284

(Previously Recorded)

Unknown (Records not 

found at NNHPD 

records repository)

NRHP Eligibility is Unknown

1. 50-year guideline unknown

2. Unknown Integrity

3. Unknown criteria eligibility

UT-C-42-400

(Previously Recorded)

Unknown (Records not 

found at NNHPD 

records repository)

NRHP Eligibility is Unknown

1. 50-year guideline unknown

2. Unknown Integrity

3. Unknown criteria eligibility

UT-C-42-SA46161

(Previously Recorded)

Unknown (Records not 

found at NNHPD 

records repository)

NRHP Eligibility is Unknown

1. 50-year guideline unknown

2. Unknown Integrity

3. Unknown criteria eligibility
35

Table 5: NHPA Evaluation table for Historic IUS structures in the McElmo Unit Main Flare Project Area.

Resource Designation 

and Location

Resource 

Description

Resource 

Evaluation

Comments

IUS #1 (located SE of 

McElmo Flare)

see Table 3 NRHP: Yes IUS #1 contains 4 homes that are more than 50 years 

old; The four homes are eligible under criteria (d) 

because they may yield information regarding

historic Navajo occupation; they possess integrity of 

location, design, setting, material, workmanship, 

feeling and association

IUS #2 (located east of 

the McElmo Flare)

see Table 3 NRHP: Yes IUS #2 contains 4 homes that are more than 50 years 

old; The four homes are eligible under criteria (d) 

because they may yield information regarding

historic Navajo occupation; they possess integrity of 

location, design, setting, material, workmanship, 

feeling and association

IUS #3 (located east of 

the McElmo Flare)

see Table 3 NRHP: No IUS #3 does not contain any structures that are 50 

years old; therefore it does not meet eligibility 

requirements.

IUS #4 (located north of 

McElmo Flare)

see Table 3 NRHP: No IUS #4 does not contain any structures that are 50 

years old; therefore it does not meet eligibility 

requirements.

IUS #5 (located north of 

McElmo Flare)

see Table 3 NRHP: No IUS #5 does not contain any structures that are 50 

years old; therefore it does not meet eligibility 

requirements. 

IUS #6 (located south of 

McElmo Flare)

Resolute 

Equipment 

Holding 

Area

NRHP: No IUS #6 does not contain any structures that are 50 

years old; therefore it does not meet eligibility 

requirements. 

IUS #7 (center of 

McElmo Flare)

Resolute 

Offices and 

Plant

NRHP: No IUS #7 does not contain any structures that are 50 

years old; therefore it does not meet eligibility 

requirements. 

IUS #8 (located west of 

McElmo Flare)

Resolute Oil 

& gas Pad 

with Storage 

Tanks

NRHP: No IUS #8 does not contain any structures that are 50 

years old; therefore it does not meet eligibility 

requirements. 

IUS #9 (located 

southwest of McElmo 

Flare)

Resolute 

Equipment 

Storage 

Area

NRHP: No IUS #9 does not contain any structures that are 50 

years old; therefore it does not meet eligibility 

requirements.

Impact of the Undertaking on Historical Properties

EPA’s undertaking does not authorize any new construction or modification of existing 

equipment at the MCU Facility. The undertaking results in no new surface disturbance or 

change in operations and therefore will have no effect on eligible historic properties located 

within 2 km APE for the McElmo Creek Unit main flare.
36

References Cited

LSR Innovations Research & Planning

2004 Chapter Images: 2004 Edition. Navajo Nation Division of Community 

Development, Window Rock, Arizona.

Van Valkenburgh, Richard F.

1974 Navajo Sacred Places. In Navajo Indians III, edited by C. Kluckhohn, pp. 9-99. 

Garland, New York.