NI43-101Pre-Feasibility Study Report - page 517

Rare Element Resources
Bear Lodge Project
Canadian NI 43-101 Technical Report
October 9
, 2014
10135-200-46 - Rev. 0
Rare Element has prepared an Aquatic Resources Inventory for both the Bull Hill
mine site and the Upton Hydrometallurgical plant site and requested a jurisdictional
determination from the USACE. In December 2013, the USACE determined that
Coyote Creek near Upton Hydrometallurgical plant location does not meet the
standard and therefore will not require a permit. The USACE is still evaluating the
Bull Hill mine site and a jurisdictional decision is expected in the second half of 2014.
20.5 United States Nuclear Regulatory Commission
The Nuclear Regulatory Commission (NRC) regulates radioactive materials subject to
the Atomic Energy Act (AEA) as amended. This includes source, by-product, and
special nuclear material. Of these three types of radioactive material, only source
material could potentially apply to the Bear Lodge Project. The NRC defines source
material in 10 Code of Federal Regulations (CFR) 40 as follows:
Source Material means: (1) uranium or thorium, or any combination thereof, in any
physical or chemical form or (2) ores which contain by weight one-twentieth of one
percent (0.05%) or more of: (i) uranium, (ii) thorium or (iii) any combination thereof.
Source material does not include special nuclear material.
The NRC excludes from regulation source material in “unrefined or unprocessed ore”
and “in any chemical mixture, compound, solution, or alloys in which the source
material is by weight less than 0.05 percent of the mixture, compound, solution or
alloy”. Based on this definition and exclusion, the Bull Hill unprocessed ore is not
subject to NRC regulation. Pre-concentrates produced at the PUG and some waste
streams from the Hydromet will meet the NRC’s definition of source material and
therefore, will require a radioactive materials possession license.
Rare Element intends to submit a radioactive materials license application to the NRC
consistent with the guidelines contained in NUREG-1556 Volume 12 “Program-
Specific Guidance About Possession Licenses for Manufacturing and Distribution”
and the requirements in 10 CFR 40. Accompanying this application will be an
environmental report consistent with the guidelines contained in NUREG-1748,
Environmental Review Guidance for Licensing Actions Associated with NMSS
Programs” and the requirements in US Code of Regulations, 10 CFR 51.
The license application and environmental report will be submitted to the NRC in the
second half of 2014. The environmental report will be used to evaluate impacts
following NRC’s environmental review NEPA process.
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