Occupational Dose Evaluation in Support of the Development of the
October, 2012
Rare Element Resources, Inc. Bear Lodge Project
15
“unrefined or unprocessed ore” exemption. If determined appropriate by the NRC, this material
could require specific licensing and the radiation protection standards in 10 CFR 20 would
apply. The occupational radiation dose limits in 10 CFR 20 are:
An annual limit, which is the more limiting of a Total Effective Dose Equivalent of 5 rem
or the sum of the deep-dose equivalent and the committed dose equivalent to any organ
or tissue other than the lens of the eye being equal to 50 rem,
An annual limit of 15 rem to the lens of the eye,
An annual limit of 50 rem to the skin, and
A 10 mg per week limit of soluble uranium
The NRC also requires, to the extent practical, implementation of procedures and engineering
controls based on sound radiation protection principle to achieve occupational doses that are as
low as is reasonably achievable (ALARA). ALARA is the optimization component of radiation
protection principles. If an NRC license is issued, the occupational dose limits and ALARA
requirement are applicable to all radionuclides, not just uranium and thorium.
3.2
Occupational Safety and Health Administration
OSHA regulates all aspects of occupational health and safety in the U.S. with the exception of
the mining industry and the radiation protection component for NRC licensees. In the absence of
a radioactive materials license issued by the NRC or Agreement State, OSHA has authority to
regulate and limit occupational doses from radiation resulting from NORM sources for non-
mining industries. These regulations are contained in 29 CFR 1910.1096 and are not consistent
with the radiation protection regulations adopted by the NRC. The occupational radiation dose
limits contained in 29 CFR 1910.1096 are:
1.25 rem per calendar quarter to the whole body.
18.75 rem per calendar quarter to the hands (including forearms), feet and ankles.
7.5 rem per calendar quarter to the skin of whole body.
Worker exposure to airborne radioactive material are to be kept below concentrations in
Table 1 of Appendix B to 10 CFR 20 (1971 publication) based on a 40-hour average.
There are no requirements in the OSHA regulations to maintain occupational doses to levels that
are ALARA.
3.3
Mine Safety and Health Administration
MSHA is responsible for implementation and enforcement of the Federal Mine Safety and
Health Act of 1977 (Mine Act). This act and MSHA’s implementation and enforcement
regulations are applicable to all mineral processing operations in the U.S. The occupational
health and safety requirements for surface metal and non-metal mines are in 30 CFR 56. There
