Technical Manual 1005 (TM1005) requires quarterly quality assurance for CEMS: either a Cylinder Gas Audit (CGA) or a Relative Accuracy Test Audit (RATA) in accordance with Part 60, Appendix F.  Under Section 5.1.4 of Appendix F, a CGA is not required in a quarter when the source does not operate.  Similarly, if a RATA is due in a quarter when the source does not operate, a RATA is not required (a RATA requires source operation in order to be completed), but the RATA must be done in the quarter when the source recommences operation.  However, these exemptions were not intended for continued periods of non-operation.  To provide clarity, the following will be required in instances of multiple successive quarters of non-operation when there was a break in quarterly quality assurance:

1.            If a CGA (or RATA) is required in the first quarter of non-operation, the facility may opt to skip the CGA (or RATA) per Section 5.1.4 of Appendix F.  However, if non-operation continues into a second consecutive quarter, a CGA will be required regardless of whether the unit operates or not.  For extended periods of non-operation, the facility may opt to discontinue quarterly quality assurance, but two or more consecutive quarters without performing any quarterly quality assurance will trigger a recertification event for when operation resumes, using the procedures specified in Number 5 below. 2.            If a RATA is due in the second or subsequent full quarter of non-operation, a CGA is required consistent with Number 1 above.  For extended periods of non-operation, the facility may opt to discontinue quarterly quality assurance, but two or more consecutive quarters without performing any quarterly quality assurance will trigger a recertification event for when operation resumes, using the procedures specified in Number 5 below.
 
3.            In the quarter when the source resumes operation and a CGA is due, a CGA is required upon startup, since any operation in that quarter prior to the successful CGA will be considered as downtime, consistent with Section VI.J. of TM1005. 

4.            If a RATA is due in the quarter when the source resumes operation, follow the procedures of TM1005, Appendix E, Option 1, except substitute RATA for Performance Specification Test (PST), and exclude references to 7-day drift assessments.  Any operation in that quarter prior to the successful CGA will be considered as downtime, consistent with Section VI.J. of TM1005.  Alternatively, a full PST can be conducted following TM1005, Appendix E, Option 2.

5.            Five or more consecutive quarters of non-operation which included a quarter without quality assurance (Number 1 above) will be considered a recertification event and a PST will be required following the procedures of TM1005, Appendix E in the quarter when the source resumes operation. 

6.            Alternatively, the facility can continue to perform quality assurance in all quarters without any break in quarterly quality assurance, regardless of non-operation in a quarter(s), by performing a CGA in the quarter when a RATA was due.  However, six or more consecutive quarters without performing a RATA will be considered a recertification event and a PST will be required following the procedures of TM1005, Appendix E in the quarter when the source resumes operation.

Note that valid data reporting is required upon re-start unless the facility has a Start-up Operating Scenario that allows for something different.  Any operation in that quarter prior to the successful CGA (TM1005, Appendix E, Option 1) or prior to Day 1 of the 7-day Calibration Drift Period (TM1005, Appendix E, Option2) will be considered downtime, consistent with Section VI.J. of TM1005.  Both Options assume a successful relative accuracy (RA) demonstration.