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Operator Certification Compliance Guidance during COVID-19 Pandemic


The United States Environmental Protection Agency issued a memorandum dated March 26, 2020, titled "COVID-19 Implications for EPA’s Enforcement and Compliance Assurance Program." This guidance document addresses the need for enforcement discretion resulting from the COVID-19 pandemic.


The Department of Environmental Conservation recognizes that COVID-19 may create potential shortages of properly certified operators to staff water and wastewater systems. These shortages may be due to operators becoming ill or unable to staff their water and/or wastewater systems due to travel restrictions and/or social distancing requirements.

If a system is unable to meet the staffing requirements for a water or wastewater system, as established in 18 AAC 74, the system owner must take the following steps:

  • Contact the Operator Certification Program within 24 hours of identifying that the properly certified operator will no longer be available to staff the system. Contact information is provided at the end of this document.
  • Protect public health by operating water and/or wastewater systems responsibly and ensuring the following:
    • Routine samples are being taken
      • Contact the Drinking Water Program if you are unable to collect or ship routine total coliform samples for any reason
    • Routine maintenance is being performed
    • Precautions are taken to prevent the spread of COVID-19
    • If the system chlorinates, ensure that disinfection continues to function correctly
    • If the water system is adding fluoride and no properly certified operator is available, fluoride addition MUST cease until the water system is staffed by a properly certified operator
    • If the properly certified operator is off-site and SCADA is available, the off-site operator must be in regular daily contact with the on-site operators to ensure the system is being operated properly
  • Submit to the Operator Certification Program a proposal via email for staffing the systems which includes, at a minimum, the following information:
    • The specific reason why the system is out of compliance with the Operator Certification Regulations
    • The dates of non-compliance
    • How COVID-19 impacted the ability of the system to be compliant
    • Response actions including:
      • How the system is being staffed, and
      • Experience, training, or certifications of the operators
    • Steps being taken to return to compliance with the Operator Certification Regulations
    • Document an emergency response plan including a list of all alarms, automatic responses, e.g. automatic plant shutdown on high turbidity, how the on-site and remote operators are notified, response times, and duties of all individuals involved
    The Operator Certification Program will review the system owner’s proposal. If revisions are necessary, the Operator Certification Program will provide guidance to the system owner and request resubmittal of the proposal. The Operator Certification Program will provide approval of satisfactory plans.
  • The system owner will check in via email with the Operator Certification Program by the 15th of each month with the following information:
    • The status of the operators
    • Status of required sampling and submission of required reports, e.g. monthly operator reports, Discharge Monitoring Reports (DMRs)
  • Return to compliance as soon as possible.
  • Notify the Operator Certification Program when normal operations have resumed.

Contact Information

Operator Certification Program
For matters concerning system staffing requirements
Phone: 907-465-1139
Drinking Water Program
For matters concerning drinking water sampling
Cindy Christian, Environmental Program Manager III
Phone: 907-451-2138
Wastewater Compliance and Enforcement Program
For matters concerning wastewater
Phone: 907-269-4114

Additional Guidance

This document addresses only compliance with the Operator Certification Regulations, 18 AAC 74. For guidance regarding compliance with the Drinking Water Regulations or the Alaska Pollution Discharge Elimination System Regulations, please reach out to the contacts listed above. Additional guidance documents may be found online at:

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