The problem is most likely the aftermarket Cat-Converter! I used to deal with this problem alot at the dealership I worked at. It usually happens on '91-'95 YJ's, XJ's and ZJ's with 2.5l or 4.0l engines. We would install a Mopar factory replacement cat-converter and fix the problem.
The state of CA. just this year addressed the problem of improper Cat-Converters being installed on vehicles. They usually are undersized compared to the factory part!
See this link:
http://www.arb.ca.gov/msprog/aftermktcat/aftermktcat.htmAnd another one:
http://www.bar.ca.gov/80_BARResources/ftp/pdfdocs/ARSC-summer08.pdf As of the first of the year,(2009) new replacement cat-converters MUST have a CARB EO# (Exemption Order), just like any other aftermarket part than can alter the emissions. It seems they found out that the low cost "universal" replacement cats skimp out on the Rhodium element in the converter that catalyzes the NOX. If you look at the last test result, right after you replaced the converter the last time, the NOX reading is probably pretty close to the maximum spec. The new cat-converter has to pass the same tests as the factory cat and has to be warranteed for 5 years. Expect to pay between $200-$400 for the new cat-converter.
You might try to see if your old converter still has a warranty left on it, they will have to upgrade it to the new style converter as it is illegal to install the old ones, now.
Hope this helps!
P.S. I'm a California certified Smog tech, and had worked for a local Jeep dealer as a smog tech there for most of the last 19 years. (I'm now in "semi-retirement" working for a University Fleet, still doing smogs though! <img src="/forums/images/graemlins/sleeping.gif" alt="" />)