In order to ensure consistency regarding the dates of certification when a CEMS is recertified after a replacement or significant repair, EMS is providing guidance and clarification on when CEMS are officially certified and when the data become valid and enforceable.

EMS has and will continue to use the date of the successful Relative Accuracy (RA) portion of a successful Performance Specification Test (PST) as the certification date when recertifying an analyzer using Technical Manual (TM) 1005, Appendix E, Option 1, consistent with TM 1005 V. G. However, per TM 1005, Appendix E, Option 1, the data is considered valid back to the date of the successful Cylinder Gas Audit (CGA). Therefore, there would be no downtime between these two dates (unless downtime was accrued for some other reason). Since the EEMPR does not flag downtime based on the certification date and the Submitter manually enters data into the EEMPR spreadsheet for Hours of Operation, CEMS uptime and CEMS downtime, the Submitter would include the hours between the CGA and PST as uptime (again, unless there is another reason to be listed as downtime).

The Submitter shall include an attachment to the EEMPR explaining the recertification and why this period prior to the official recertification date is not downtime. The attachment shall include: the date the original CEMS was taken out of service, the date the replacement CEMS was installed, the date of the successful CGA and the date of the successful RA during the subsequent PST.