Alternate Method of System Supervision (AMOSS)
Occasionally, utilities are left without an operator certified to the level of their system as a result of an unexpected departure of an operator, a modification in the treatment process that results in a change in the system classification, or difficulty in recruiting qualified operators. In situations such as these, the Department has the authority to approve an Alternate Method of System Supervision (AMOSS).
A utility can seek approval of an AMOSS by submitting a plan to the Department, describing the current circumstances, how the utility proposes to operate without an operator certified to the level of the system, and the process they will follow to come into compliance with the regulations. Before the Department approves the plan, the Governor’s Water/Wastewater Works Advisory Board (Board) must first review it and provide recommendations. Because systems and circumstances vary greatly, every AMOSS plan is unique. However, in all cases, both the Board and the Department are working to ensure that the proposed plan for system operation is sufficiently protective of public health, the environment and the system’s infrastructure.
Operator Certification Program staff are available to assist any utility that wishes to seek approval of an AMOSS plan. All plans should contain, at minimum, the following items:
- A statement of what is being proposed, including why the plan is necessary, what specific aspects of the regulations cannot be complied with, and what steps have been taken in an attempt to correct the situation.
- A description of the system, or systems, being operated including the system’s classification information, population served, treatment processes and chemical additions, as well as items such as remote sensors, SCADA systems, alarms, etc. that are not reflected in the classification calculation.
- A detailed description of how the system should be operated under normal circumstances, including staffing schedules and those activities that happen only occasionally or periodically.
- A detailed description of how the system will be operated under the proposed AMOSS plan including clearly defined lines of supervision and communication, responsibilities and qualifications of all parties involved in the plan including certifications held, and standard operating procedures. If off-site operators will remotely supervise or monitor onsite operations, detailed information regarding method and frequency of communication and frequency of onsite visits should be included.
- An emergency response plan including a description of all system alarms, automated responses, notification of responsible parties, response times, and duties and expected response for all parties involved.
- A specific plan for achieving compliance, including applicable milestones such as exams, continuing education and a date by which the plan will end.
- If the plan includes contracts or agreements with other entities or operators outside the utility, written copies of the agreements should be included.
It is important to note that the AMOSS plan approval process can take several months. To expedite the process, you should first consult with Operator Certification Program staff who can provide input on your utility’s specific situation. Then, develop a detailed and thorough plan. Program staff will review the plan and provide interim approval, if deemed adequate. Proposed AMOSS plans with interim approval will be presented to the Board at the next meeting for their recommendation and final approval by the Department.
Alaska Department of Environmental Conservation
Attn: Operator Training and Certification Program
P.O. Box 111800
Juneau, AK 99811-1800