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Recertification and Diagnostic Testing Policy (12/1/01)

On October 24, 2001, EPA issued "Recertification and Diagnostic Testing Policy" which is intended to provide guidance concerning CEMS maintenance activities that trigger recertification and diagnostic test events. This policy document has been issued in a question/answer format and EPA intends to formally incorporate this policy into the Acid Rain Program Policy Manual in the near future. In at least one instance, this policy contradicts existing policy statements in the Policy Manual. For example, the "Recertification and Diagnostic Testing Policy" states that replacing an umbilical with a "like-kind" umbilical triggers a complete recertification event rather than a diagnostic event as specified in Question 13.19. EPA has stated that the newly released policy takes precedence and that conflicting questions in the Policy Manual will be revised or retired.

Curiously, this policy states that "EPA recognizes that this guidance cannot possibly address every situation that may arise and is not binding for situations that it does address." Unfortunately, a failure to adhere to this policy may leave a source vulnerable to enforcement actions. This policy increases the importance of clear lines of communication between the CEMS technicians, personnel responsible for generating EDRs, and personnel responsible for providing regulatory expertise. Additionally, these diagnostic test provisions may require modifications to current CEMS maintenance strategies (from reactive to preventive) to avoid excessive quality assurance tests during a quarter. For additional information concerning EPA’s latest policy decisions or for assistance in developing preventive CEMS maintenance strategies, please contact RMB. A copy of the "Recertification and Diagnostic Testing Policy" is available in our FTP Library.

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RMB Consulting & Research, Inc.
Last Revised: December 03, 2001