Bureau of Mining Regulation and Reclamation Regulation Branch
POLICY AND PROCEDURES FOR
COMPLIANCE INSPECTIONS
The Regulation Branch of the Bureau of Mining Regulation and Reclamation (BMR&R) performs inspections of mining operations. There are several types of inspections performed:
1. Compliance Inspections - These are performed by the Compliance Inspectors, PCNs 0202 and 0553. The inspections are scheduled on a periodic basis, the frequency depending on the size of the facility and the potential to degrade waters of the State. The goal is to inspect large sites at least three times a year, medium sites twice a year, and small or inactive sites once a year. An annual inspection schedule is prepared at the beginning of each calendar year. The inspections are performed in accordance with the Compliance Inspection Guidelines (Attachment 1).
2. Permit/Construction Inspections - These inspections are performed by the Permit Writers, PCNs 0520, 0519, 0511, 0551, 0523, and 0522. They are performed on an as-needed basis, usually before a permit is issued, or corresponding with significant construction activity. The purpose of these inspections is to familiarize the permit writer with the layout of a new facility or to ensure that construction of process components is in accordance with the approved engineering design.
3. Investigative Inspections - These are performed in response to a significant release of contaminants, or a complaint requiring follow-up by the Division. They are normally performed by the Compliance Inspector and Permit Writer assigned to the site, along with the Branch Supervisor (PCN 0522) and Bureau Chief (PCN 0531) if appropriate. The purpose of these inspections is to investigate and document the severity and extent of a release in preparation for potential enforcement action, or to evaluate the validity of a complaint and recommend corrective actions.
The Bureau of Land Management and the USDA Forest Service are provided annual inspection schedules at the beginning of each calendar year, so that inspections may be performed cooperatively. The mine operator is notified in advance for most inspections, except for certain Investigative Inspections where forewarning is not desirable. Photos or video recordings are taken as necessary to document conditions at the site.
An Inspection Report is prepared to document each inspection. Noted in the report are any problems or concerns discovered during the inspection, and deadlines for corrective actions. The report is sent in letter form to the operator, with copies to the federal land manager, if applicable. The reports and associated documentation are kept in the blue project files.