AQ_F_1300078_20190509_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Americhem, Inc.
NC Facility ID 1300078
Inspection Report County/FIPS: Cabarrus/025
Date: 05/09/2019
Facility Data Permit Data
Americhem,Inc. Permit 06330/R13
723 Commerce Drive Issued 12/31/2014
Concord,NC 28025 Expires 4/30/2022
Lat: 35d 22.6840m Long: 80d 35.1090m Class/Status Small
SIC: 3087/Custom Compound Purchased Resins Permit Status Active
NAICS: 325991 /Custom Compounding of Purchased Resins Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Roxanne Hiott Jim Cook Roxanne Hiott
Quality Testing Plant Manager Quality Testing
Department Leader [phone] Department Leader
[phone] [phone]
Compliance Data
Comments:
7 Inspection Date 05/09/2019
/ Inspector's Name Donna Cook
Inspector's Signature: a Coo Operating Status Operating
Compliance Code Compliance'-inspection
Action Code FCE
Date of Signature: On-Site Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
TSP S02 NOX VOC CO PM10 *HAP
2013 0.0900 --- 0.3200 0.3500 0.2800 0.0900 11.78
2008 0.2200 0.3500 1.46 0.1500 1.22 0.2200 67.97
*Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

Americhem, Inc.
May 9, 2019
Page 2
X Full Compliance Partial Compliance _Complaint Other:
Type Action: Evaluation Evaluation/Reinspection Investigation
Data Tracking: X Date submitted for initial review 05/20/2019 _IBEAM WARNING/OB,NOD,NOV,NRE
./ X IBEAM Document
X IBEAM Inspection,list date inspected / X IBEAM LAT/LONG,Facility Locked ✓/
/
X IBEAM Inspection,list date draft is submitted) X IBEAM LAT/LONG,Coordinates checked V
X IBEAM Inspection,pollutants/programs checked/ _IBEAM Complaint
X IBEAM Planning,Next Inspection Date 05/01/2021
Directions: From Mooresville Regional Office to Concord,travel via Highway 3 South;turn right on
Odell School Road;turn right at the stop light onto Poplar Tent Road due to the no left turn;'make a U
turn at the next stop light;turn right on Highway 601/29 (referred to as the Concord Parkway); turn left
on Highway 601 Bypass(Warren C. Coleman Boulevard)toward Monroe for approximately 2 miles;
turn right at the stop light onto Wilshire Avenue; 0.2 miles turn left on Webb Road; and 0.1 miles turn
right on Commerce Drive. Americhem,Inc. is located on the left at the end of the road. The street
address of this company is 723 Commerce Drive.
Safety Equipment: This company requires that steel toe shoes, safety glasses,hearing protection,and a
safety vest be worn by the inspector at this facility.
Safety Issues: Inspector should be cautious of forklift operations.
Lat/Long Coordinates: The facility's coordinates on "Maps of DAQ Regulated Facilities" are not
accessible on the DAQ web site. The latitude and longitude coordinates of this facility are accurate and
locked in IBEAM.
Email Contacts: The emails for the facility, authorized,technical, and invoice contacts were,verified by
Mr. Roxanne Hiott, quality testing department leader. No changes to the email contacts are needed in
IBEAM.
I. The purpose of this site visit was to conduct a routine air quality inspection. Americhem, Inc.
manufactures color and additive dispersions for thermoplastics. Most of the products are
mixtures of colorants and plastic resins known as color concentrates. The color concentrates are
used by customers in the manufacturing of plastic articles such as building products, consumer
goods, automotive interior parts, carpet fibers, and packaging. This company operates this
facility 24 hours per day, 7 days per week, 51 weeks per year. Ms. Alejandra Cruz of the DAQ
MRO coinspected the facility with me. Ms. Roxanne Hiott, quality testing department leader,
and Mr.Mike King, maintenance leader, accompanied us during this inspection.
2. Facility Contact Information:
During the inspection, I verified the facility contact information in IBEAM with Ms. Hiott. No
changes to the facility contact information are needed in IBEAM.

Americhem, Inc.
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Page 3
3. Compliance history file review:
No problems have been noted in the last five years by DAQ prior to this inspection. The current
compliance status is discussed in the following sections.
4. Observations of permitted air emission sources and control devices:
Emission Emission Source Control Control System
Source ID Description System ID Description
MI ABM Line#1 (1,000 pounds DC-1 fabric filter(9,120 square
per hour maximum process feet of filter area
rate)
The ABM Lime#I consists of various sources that melt pigment and resin. The particulate matter
emissions from ABM Line#1 are controlled by a cartridge filter(ID No. DC-1 or company ID No.
40447). The cartridge filter exhausts through a vertical and uncapped stack to the outdoor
atmosphere. The heat to this line is provided by an exempt boiler(ID No. I-40135). This cartridge
filter(ID No. DC-1 or company ID No. 40447; 9,120 square feet of filter area) also controls
emissions from the exempt AME line(ID No. 1-40134).
The description of the fabric filter(ID No.DC-1 or company ID No. 40447; 9,120 square feet
of filter area)should be changed to a cartridge filter during the next permit revision.
Observed. The ABM Line#1 was not in operation. The cartridge filter(manufacturer,Torit
Donaldson; ID No. DC-1 or company ID No. 40447)was in operation. I observed no visible
emissions from the ABM Line#1 or from the vertical and uncapped stack of the cartridge filter.
ABM 2 'ABM Line#2 (1,000 pounds DC-2 fabric filter(9,120 square
per hour maximum process :feet of filter area)
rate)
The ABM Line 42 consists of various sources that melt pigment and resin. The particulate matter `
emissions from ABM Line#2 are controlled by a cartridge filter(ID No. DC-2 or company ID No.
40448). The cartridge filter exhausts through a vertical and uncapped stack to the outdoor
atmosphere. The heat to this line is provided by an exempt boiler(ID No. I-40135).
The description of the fabric filter(ID No.DC-2 or company ID No. 40448; 9,120 square feet
of filter area) should be changed to a cartridge filter during the next permit revision.
Observed. The ABM Line#2 and the cartridge filter(manufacturer,Torit Donaldson; ID No. DC-
2 or company ID No. 40448)were in operation. I observed no visible emissions from the ABM
Line#2 or from the vertical and uncapped stack of the cartridge filter.
40069,40117 compounding blender(ID No. 'DC-3 ]fabric filter(9,120 square
40069, 2,000 pounds per hour feet of filter area)
maximum process rate)
compounding blender(ID No.
40117, 3,000 pounds per hour
maximum process rate)'
This company uses a large platform above ground level to place the resin and pigment in the top of

Americhem, Inc.
May 9,2019
Page 4
the two compounding blenders(ID Nos. 40069 and 40117). The resin and pigment are mixed in
'the two compounding blenders. A liquid,unamine o, is added to disperse the resin and pigment as
needed. The resin and pigment mixture removed from the two compounding blenders into plastic
bags for further processing. Then the resin and pigment mixtures are processed in either ABM#1
Line or ABM#2 Line. The compounding blender(ID No. 40069) is used for darker colors. The
compounding blender(ID No. 40117)is used for lighter colors. The particulate matter emissions
from two compounding blenders(ID Nos. 40069 and 40117)are controlled by a cartridge filter(ID
No. CD-03 or company ID No. 40449). The cartridge filter exhausts through a vertical and
uncapped stack to the outdoor atmosphere.
The description of the fabric filter(ID No.DC-3 or company ID No. 40449; 9,120 square feet
of filter area) should be changed to a cartridge filter during the next permit revision.
Observed. The loading of two compounding blenders(ID No. 40069 and 40117)were being
conducted at the time of the inspection. The cartridge filter(manufacturer,Torit Donaldson; ID
'No. DC-3 or company ID No. 40449)was in operation. I observed no visible emissions from the
two compounding blenders or from the vertical and uncapped stack of the cartridge filter.
5. Observations of insignificant air emission sources and control devices listed on the current permit:
SourceA Exemption,rource
Source of Title V
Regulationsq Pollutants?
1-40009 -plastic extruder(600 pounds per hour F(�X�0)
02maximum process rate) exhausting to a fabric filter 02 1[ No Yes
(ID No.DC-4, 1,835 square feet of filter area)
The resin pellets are pneumatically conveyed from the three pellet resin storage silos(ID Nos. I-
40132,I-40420 and IES11)to the extrusion line. The ground resin pellets from the micro storage
silos(not listed in exempt sources;25,000 pounds capacity) are emptied into drums and totes for
processing on the extrusion line. The extrusion line is electrically heated. The pellets are melted
and extruded through molds on the extrusion line. The plastic is cooled in water before further
processing. The plastic extruder(ID No. 1-40009)has two ventilation points, one on the feed side
for the particulate matter emissions and second on the die and vent end for the polymer fumes.
Any emissions from the feed side for the particulate matter emissions vent to fabric filter(ID No.
DC-4 or company ID No. 40215). Any emissions from the polymer fumes vent to through a
vertical stack with a rain cap.
The fabric filter exhausts through a vertical and uncapped stack to the outdoor atmosphere or the
air flow can be diverted by a bypass damper to a HEPA filter. The exhaust of the HEPA filter is
horizontal and uncapped. The bypass damper was closed so there was no air flow to the HEPA
filter at the time of this inspection. Ms. Hiott stated that the HEPA filter has never been used by
this company.
The description of the fabric filter should be changed to exhausting to a fabric filter(ID No.
CD-4, 1,835 square feet of filter area)in series with a HEPA filter during the next permit
revision.
Observed. The plastic extruder(ID No. I-40009) and the fabric filter(ID No.DC-4 or company

Americhem, Inc.
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Page 5
ID No. 40215)were in operation. I observed no visible emissions from the plastic.extruder exhaust
of the vertical stack with a rain cap or the fabric filter exhaust of the vertical and uncapped stack.
The HEPA filter was not in operation since the bypass damper was closed.
F-4 -plastic extruder�(600 pounds per hourQ .0102m process rate) exhausting to a fabric filter 2 ( No Yes
DC-4, 1,835 square feet of filter area)
The resin pellets are pneumatically conveyed from the three pellet resin storage silos (ID Nos.I-
40132,I-40420 and IES 11)to the extrusion line. The ground resin pellets from the micro storage
silos (not listed in exempt sources; 25,000 pounds capacity)are emptied into drums and totes for
processing on the extrusion line. The extrusion line is electrically heated. The pellets are melted
and extruded through molds on the extrusion line. The plastic is cooled in water before further
processing. The plastic extruder(ID No. I-40101)has two ventilation points, one on the feed side
for the particulate matter emissions and second on the die and vent end for the polymer fumes.
Any emissions from the feed side for the particulate matter emissions vent to fabric filter(ID No.
DC-4 or company ID No. 40215). Any emissions from the polymer fumes vent to through a
vertical stack with a rain cap.
The fabric filter exhausts through a vertical and uncapped stack to the outdoor atmosphere or the
air flow can be diverted by a bypass damper to a HEPA filter. The exhaust of the HEPA filter is
horizontal and uncapped. The bypass damper was closed so there was no air flow to the HEPA
filter at the time of this inspection. Ms. Hiott stated that the HEPA filter has never been used by
this company.
The description of the fabric filter should be changed to exhausting to,a fabric filter(ID No.
CD-4, 1,835 square feet of filter area) in series with a HEPA filter during the next permit
revision.
Observed. The plastic extruder(ID No. I-40101) and fabric filter(ID No. DC-4 or company ID
No. 40215)were in operation. I observed no visible emissions from the plastic extruder exhaust of
the vertical stack with a rain cap or the fabric filter exhaust of the vertical and uncapped stack. The. .
HEPA filter was not in operation since the bypass damper was closed.
I-40102-plastic extruder(400 pounds per hour 2Q .0102 T
maximum process rate) exhausting to a fabric filter (c)(2)(E)(i) ' No Yes
(ID No. DC-4, 1,835 square feet of filter area)
The plastic extruder(ID No. I-40102)has been removed from thisfacility. The plastic extruder
(ID No.I-40102) should be removed from the insignificant/exempt activities during the next
permit review.
Observed. The plastic extruder(ID No. I-40102) is no longer at this facility.
[(ID
-40214 -plastic extruder(600 pounds per hour 2Q .0102
maximum process rate)exhausting to a fabric filter (c)(2)(E)(i) No Yes
No. DC-4, 1,835 square feet of filter area)
The resin pellets are pneumatically conveyed from the three pellet resin storage silos(ID Nos. I-
40132,I-40420 and IES11)to the extrusion line. The ground resin pellets from the micro storage
silos(not listed in exempt sources;25,000 pounds capacity) are emptied into drums and totes for
processing on the extrusion line. The extrusion line is electrically heated. The pellets are melted
and extruded through molds on the extrusion line. The plastic is cooled in water before further

Americhem,Inc.
May 9, 2019
Page 6
processing. The plastic extruder(ID No. I-40214)has two ventilation points, one on the feed side
for the particulate matter emissions and second on the die and vent end for the polymer fumes.
Any emissions from the feed side for the particulate matter emissions vent to fabric filter(ID No.
DC-4 or company ID No. 40215). Any emissions from the polymer fumes vent to through a
vertical stack with a rain cap.
The fabric filter exhausts through a vertical and uncapped stack to the outdoor atmosphere or the
air flow can be diverted by a bypass damper to a HEPA filter. The exhaust of the HEPA filter is
horizontal and uncapped. The bypass damper was closed so there was no air flow to the HEPA
filter at the time of this inspection. Ms. Hiott stated that the HEPA filter has never been used by
this company.
The description of the fabric filter should be changed to exhausting to a fabric filter(ID No.
CD-4, 1,835 square feet of filter area)in series with a HEPA filter during the next permit
revision.
Observed. The plastic extruder(ID No. I-40214) and fabric filter(ID No. DC-4 or company ID
No. 40215)were in operation. I observed no visible emissions from the plastic extruder exhaust of
'the vertical stack with a rain cap or the fabric filter exhaust of the vertical and uncapped stack. The
HEPA filter was not in operation since the bypass damper was closed.
I-40328 -plastic extruder(1200 pounds per hour 2Q .0102
maximum process rate) exhausting to a fabric filter (c)(2)(E)(i) NoF Yes
(ID No. DC-4, 1,835 square feet of filter area)
The resin pellets are pneumatically conveyed from the three pellet resin storage silos(ID Nos. I-
40132,I-40420 and IES11)to the extrusion line. The ground resin pellets from the micro storage
silos (not listed in exempt sources;25,000 pounds capacity)are emptied into drums and totes for
processing on the extrusion line. The extrusion line is electrically heated. The pellets are melted
and extruded through molds on the extrusion line. The plastic is cooled in water before further
a processing. The plastic extruder(ID No. I-40328) has two ventilation points, one on the feed side
for the particulate matter emissions and second on the die and vent end for the polymer fumes.
'Any emissions from the feed side for the particulate matter emissions vent to fabric filter(ID No.
DC-4 or company ID No. 40215). Any emissions from the polymer fumes vent to through a
vertical stack with a rain cap.
The fabric filter exhausts through a vertical and uncapped stack to the outdoor atmosphere or the
air flow can be diverted by a bypass damper to a HEPA filter. The exhaust of the HEPA filter is
horizontal and uncapped. The bypass damper was closed so there was no air flow to the HEPA
filter at the time of this inspection. Ms. Hiott stated that the HEPA filter has never been used by
'this company.
'The description of the fabric filter should be changed to exhausting to a fabric filter(ID No.
'CD-4, 1,835 square feet of filter area) in series with a HEPA filter during the next permit
revision.
Observed. The plastic extruder(ID No. I-40328)was not in operation.-The fabric filter(ID No.
DC-4 or company ID No. 40215)was in operation. I observed no visible emissions from the
plastic extruder exhaust of the vertical stack with a rain cap or the fabric filter exhaust of the
vertical and uncapped stack. The HEPA filter was not in operation since the bypass damper was

. 1
Americhem, Inc.
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Page 7
;closed.
F
-plastic extruder(1350 pounds per hour 2Q 0102
m process rate) exhausting to,a fabric filter No Yes
DC-4, 1,835 square feet of filter area) (c)(2)(E)(i)
The resin pellets are pneumatically conveyed from the three pellet resin storage silos (ID Nos. I-
40132,I-40420 and IES11)to the extrusion line. The ground resin pellets from the micro storage
silos (not listed in exempt sources; 25,000 pounds capacity)are emptied into drums and totes for
processing on the extrusion line. The extrusion line is electrically heated. The pellets are melted
and extruded through molds on the extrusion line. The plastic is cooled in water before further
processing. The plastic extruder(ID.No. I-40350)has two ventilation points, one on the feed side 's
for the particulate matter emissions and second on the die and vent end for the polymer fumes.
Any emissions from the feed side for the particulate matter emissions vent to fabric filter(ID No.
DC-4 or company ID No. 40215). Any emissions from the polymer fumes vent to through a
vertical stack with a rain cap.
The fabric filter exhausts through a vertical and uncapped stack to the outdoor atmosphere or the
air flow can be diverted by a bypass damper to a HEPA filter. The exhaust of the HEPA filter is
horizontal and uncapped. The bypass damper was closed so there was no air flow to the HEPA
filter at the time of this inspection. Ms. Hiott stated that the HEPA filter has never been used by
this company.
The description of the fabric filter should be changed to exhausting to a fabric filter(ID No.
CD-4, 1,835 square feet of filter area) in series with a HEPA filter during the next permit
revision. -
Observed. The plastic extruder,(ID No. 1-40350)was not in operation. The fabric filter(ID No.
DC-4 or company ID No. 40215)was in operation. I observed no visible emissions from the
plastic extruder exhaust of the vertical stack with a rain cap and the fabric filter exhaust of the
vertical and uncapped stack. The HEPA filter was not in operation since the bypass damper was
closed.
IES 14 -plastic extruder(100 pounds per hour
maximum process rate)exhausting to fabric filter 2Q .0102 No Yes
(ID No.DC-4, 1,835 square feet of filter area) in (c)(2)(E)(i)
series with a HEPA filter
The resin pellets are pneumatically conveyed from the three pellet resin storage silos (ID Nos. I-
40132,I-40420 and IES11)to the extrusion line. The ground resin pellets from the micro storage
silos (not listed in exempt sources; 25,000 pounds capacity)are emptied into drums and totes for
processing on the extrusion line. The extrusion line is electrically heated. The pellets are melted
and extruded through molds on the extrusion line. The plastic is cooled in water before further
processing. The plastic extruder(ID No. IES 14.)has two ventilation points, one on the feed side for
the particulate matter emissions and second on the die and vent end for the polymer fumes. Any
emissions from the feed side for the particulate matter emissions vent to fabric filter(ID No.DC-4
or company ID No. 40215). Any emissions from the polymer fumes vent to through a vertical
stack with a rain cap.
The fabric filter exhausts through a vertical and uncapped stack to the outdoor atmosphere or the
air flow can be diverted by a bypass damper to a HEPA filter. The exhaust of the HEPA filter is
horizontal and uncapped. The bypass damper was closed so there was no.air flow to the HEPA

Americhem, Inc.
May 9, 2019
Page 8
filter at the time of this inspection. Ms. Hiott stated that the HEPA filter has never been used by
this company.
The description of the fabric filter should be changed to exhausting to a fabric filter(ID No.
CD-4, 1,835 square feet of filter area)in series with a HEPA filter during the next permit
revision.
Observed. The plastic extruder(ID No. IES 14)and fabric filter(ID No. DC-4 or company ID No,
'40215)were in operation. I observed no visible emissions from the plastic extruder exhaust of the
vertical stack with a rain cap or the fabric filter exhaust of the vertical and uncapped stack. The
`HEPA filter was not in operation since the bypass damper was closed.
1-40054 -dual chamber,natural gas-fired screw F(�X�0)
02oven(0.35 million Btu per hour maximum heat E)(i) Yes Yes
input)
The dual chamber,natural gas-fired screw oven is used to clean the screws/augers that extrude the
product(color concentrate)on the six plastic extruders(ID Nos. I-40009, I-40101,I-40214, 1-
40328,140350 and IES14). The location of the screw oven is in the plastic extrusion area. Ms.
Hiott stated there is no liquids used in the cleaning process. This oven does exhaust to the outdoor
atmosphere through a vertical stack with a rain cap.
Observed. The dual chamber,natural gas-fired screw oven was not in operation.
I-40068 -diatomaceous earth loading platform 2Q .0102
exhausting to a fabric filter(ID No.DC-4, 1,835 (c)(2)(E)(i) No Yes
square feet of filter area)
The diatomaceous earth(sea shells) aids in the filtration process of the wastewater treatment unit at
this facility. The diatomaceous earth is added to a 55 gallon tank of-water and then whipped into a
slurry to make the filter cake. The wastewater from two ABM Lines (ID Nos. ABM 1 and ABM 2)
are pumped to a tank and the water is filtered through the diatomaceous earth. After the filtration
process,the diatomaceous earth is collected on a roller drum and empties into a waste bin that is
shipped off site. A hood above the water tank is used to capture any particulate matter emissions
from the loading of powdery diatomaceous earth into the water tank. The hood is vented to fabric
filter(ID No.DC-4 or company ID No.40215).
The fabric filter exhausts through a vertical and uncapped stack to the outdoor atmosphere or the
air flow can be diverted by a bypass damper to a HEPA filter. The exhaust of the HEPA filter is
horizontal and uncapped. The bypass damper was closed so there was no air flow to the HEPA
filter at the time of this inspection. Ms. Hiott stated that the HEPA filter has never been used by
this company.
The description of the fabric filter should be changed to exhausting to a fabric filter(ID No.
CD-4, 1,835 square feet of filter area)in series with a HEPA filter during the next permit
revision.
Observed. No diatomaceous earth was being loaded into the treatment tank at the time of the
inspection. The fabric filter(ID No. DC-4 or company ID No. 40215)was in operation. I observed'
no visible emissions from the fabric filter exhaust of the vertical and uncapped stack. The HEPA
filter was not in operation since the bypass damper was closed.

Americhem,Inc.
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Page 9
I-40074-tote compounding platform exhausting to 2Q 0102
a fabric filter(ID No. DC-4, 1,835 square feet of No Yes
filter area)
The tote compounding platform is used to combine resins and pigments from various totes into"a
collection drum. Any fugitive particulate matter emissions had been captured by ductwork and
controlled by the fabric filter(ID No.DC-4 or company ID No. 40215). However,the tote
compounding platform is currently not connected to the fabric filter. Ms. Hiott stated that the
compounding platform maybe reconnected to the fabric filter in the future.
The fabric filter exhausts through a vertical and uncapped stack to the outdoor atmosphere or the
air flow can be diverted by a bypass damper to a HEPA filter. The exhaust of the HEPA filter is
horizontal and uncapped. The bypass damper was closed so there was no air flow to the HEPA
filter at the time of this inspection. Ms.Hiott stated that the HEPA filter has never been used by
this company.
The description of the fabric filter should be changed to exhausting to a fabric filter(ID No.
CD-4, 1,835 square feet of filter area)in series with a HEPA filter during the next permit
revision.
Observed. The tote compounding platform was not operational and not connected to the fabric
filter(ID No. DC-4 or Company ID No. 40215)at the time of the inspection.
I-40077 -compounding mixer(50 pounds per hour 2Q 0102
in process rate) exhausting to a fabric filter'(c)(2)(E)(i) No Yes
(ID No.DC-3, 9,120 square feet of filter area)
The compounding mixer(ID No. I-40077; 50 pounds per hour maximum process rate) is also
known as the Hobart mixer. The Hobart mixer is located near the two permitted compounding
blenders(ID Nos. 40069 and 40117). The permitted cartridge filter(ID No. DC-3 or company ID
No. 40449)is used to control,particulate matter emissions from this compounding mixer(ID No. I-
40077)and two permitted compounding blenders(II)Nos. 40069 and 40117)and the new
container mixer resin and pigment compounding processes (three areas: dump station; dedusting
and mixing; permit determination letter dated December 12,2018 from this company and email
response dated January 14, 2019).
The description of the fabric filter(ID No. CD-3 or company ID No. 40449)should be
changed to a cartridge filter during the next permit revision.
Observed. The compounding mixer(Hobart)was not in operation. The cartridge filter `
(manufacturer,Torit Donaldson; ID No. DC-3 or company ID No. 40449)was in operation. I
observed no visible emissions from the cartridge filter exhaust of the vertical and uncapped stack.
I-40132 -nylon resin storage silo(100,000 pound 2Q 0102
No Yes
capacity) E)�1)
The silo stores nylon resin pellets. The silo is loaded pneumatically by tanker truck. The nylon
resin pellets are pneumatically fed from the storage silo to the six plastic extruders(ID Nos. I-
40009, I-40101, I-40214, I-40328, I-40350 and IES 14).
]Observed. The silo was in use at the time of the inspection. No truck unloading of nylon resin
into the storage silo was being conducted at the time of the inspection. I observed no visible

Americhem, Inc.
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Page 10
emissions from the storage silo.
I-40134-AME exhausting to a fabric filter(ID No. 2Q .0102 7NF Yes
DC-1, 9,120 square feet of filter area) �(c)(2)(E)(i)
The AME line is similar to the two ABM Lines(ID Nos. ABM 1 and ABM 2)except the AME line`
uses electricity to heat the powders. The heated material is extruded to'form the desired product
(color concentrate). The cartridge filter(ID No.DC-1 or company ID No. 40447) is used to control':
particulate matter emissions from AME line and ABM Line#1 (ID No. ABM 1). The stack of the
cartridge filter is vertical and uncapped. Ms. Hiott stated that the two blenders at the end of the
AME line are not connected to the cartridge filter(ID No. DC-1 or company ID No. 40447).
'The description of the fabric filter(ID No.DC-1; 9,120 square feet of filter area) should be
changed to a cartridge filter during the next permit revision.
Observed. The AME line and the cartridge filter(manufacturer,Torit Donaldson; ID No.DC-1 or ,
company ID No. 40448)were in operation. I observed no visible emissions from the AME line or
the cartridge filter exhaust of the vertical and uncapped stack.
rI-40r'35 -natural gas-fired boiler(2 million Btu per 2Q .0102NoF Yes
ou maximum heat input) (c)(2)(B)(ii)
The natural gas-fired boiler is used to provide steam to the ABM Line#1 (ID No.ABM 1),ABM
Line#2(ID No. ABM 2) and roll mill in laboratory. On the plate of the boiler, I observed the
following information: manufacturer: MIURA Boiler Co. Ltd.; model#LX-50; serial#
44S421419; national board#4456; 2 million input rating; steam 1840 lb/hr and date: 9/2002. The .
stack of the boiler is vertical with a rain cap.
Observed. The natural gas-fired boiler was in operation. I observed no visible emissions from the
exhaust of the boiler stack.
1-40420 -plastic pellet resin storage silo(147,000 :2Q 0102
FNo Yes
pounds capacity) (c)(2)(E)(i)
The silo stores plastic polyester resin pellets and labeled PET. The silo is loaded pneumatically by
tanker truck. The plastic polyester resin pellets are pneumatically fed from the storage silo to the
six plastic extruders(ID Nos. 1-40009, 1-40101,I-40214, 140328,1-40350 and IES14).
Observed. The silo was in use at the time of the inspection. No truck unloading of plastic
Ipolyester resin pellets into the storage silo was being conducted at the time of the inspection. I
observed no visible emissions from the storage silo.
IES2 -laboratory equipment,which includes four
(4)fiber lines,two(2)muffle furnaces, one(1) 2Q .0102
microwave furnace,two (2)fume hoods, five(5) (c)(1)(C)(i) Yes Yes
two roll mills,two(2) split bowl mixers,two(2)
drying ovens, and three(3) lab extruders
This facility conducts product testing of color concentrates in various rooms or labs. These sources
consist of three fiber lines,three muffle furnaces, one microwave furnace,two fume hoods,four
two roll mills(three hot oil heated and one steam heated),!two split bowl mixers;three drying
ovens,three lab extruders and one false twister(fiber spinning process and used to texturize spun
fiber). The cartridge filter(244 square feet of filter area and 1,200 acfm)is located in the
production area of this facility and used to control particulate matter emissions from the steam

I
Americhem, Inc.
May 9, 2019
Page 11
heated two roll mill. The cartridge filter exhausts inside of this facility and exempt per 2Q .0102
(g)(14)(J). Ms. Hiott stated that all the material produced in the lab is for research or samples.
None of the material is sold.
The description of the laboratory equipment should be changed to three fiber lines, three
muffle furnaces, one microwave furnace,two fume hoods, four two roll mills,two split bowl
mixers, three drying ovens,three lab extruders and one false twister(permit determination
letter dated October 21,2014).
The lab extruders and the mill room exhaust to the outdoor atmosphere as indicated by the roof
diagram. The stack of the fiber mill and mill room is vertical with a rain cap. The stack of the
extrusion lab is horizontal and uncapped.
Observed. The laboratory equipment was operational at the time of the inspection. I observed no
visible emissions from these sources.
FFIES24-two(2)natural gas-fired pressure washers 2Q 0102
Yes Yes
,000 Btu per hour maximum heat input, each) ,(c)(2)(E)(i)
The two natural gas-fired pressure washers (model Hotsy)are used to clean various pieces of
equipment and the floor at this facility. The two pressure washers are stationary. A water line
carries water to a few locations in the facility. The operator can attach a hose at the various
locations to access the two pressure washers. Ms.Hiott stated that the two pressure washers only
use water. No detergents or cleaning solution are added. The two pressure washers exhaust to the
outside atmosphere through a vertical stack with a rain cap.
Observed. The two natural gas-fired pressure washers were not in operation.
FIES10 - liquid color process exhausting to a fabric 2Q .0102NoYes
r(ID No. DC-3, 9,120 square feet of filter area) (c)(2)(E)(i)
This company submitted a letter dated December 12,2018, stating that the liquid color and
mixing process had been removed and replaced with a new and more efficient container mixer
system consisting of a discharge stand and fill station in addition to the mixer(refer to letter dated
December 12,2108 for the permit determination in email dated January 14, 2019). The-new
mixing process is connected to the cartridge filter(ID No. CD-3 or company ID No. 40449; 9,120
square feet of filter area). Ms. Hiott stated that the clumped or beaded resin and pigment is
compounded and mixed(three areas: dump station; dedusting and mixing) in this process. The
process was exempted from permitting per 15A NCAC 2Q .0102 (h)(5).
t
bserved. The liquid color process has been removed and should be deleted during the next
ermit revision.
IES 11 -polyester resin storage silo(178,000 pound'2Q .0102 y No Yes
capacity)
The silo stores plastic polyester resin pellets and labeled PET. The silo is loaded pneumatically by.4
tanker truck. The resin is pneumatically fed from the silo to the six plastic extruders (ID Nos.I-
40009, 1-40101, I-40214,1-40328, I-40350 and IES14).
Observed. The silo was in use at the time of the inspection. No truck unloading of plastic
polyester resin pellets into the storage silo was being conducted at the time of the inspection. I
observed no visible emissions from the storage silo.

Americhem, Inc.
May 9, 2019
Page 12
IES 12 -natural gas-fired air make up unit(4.0 2Q .0102
million Btu per hour maximum heat input) c 2 E i Yes Yes
The natural gas-fired air make up unit is used to help with the dust collection efficiency and prevent
cross drafts inside of this facility. The natural gas-fired air unit is located outside near the three
resin silos(ID Nos.I-40132,I-40420 and IES11) or the extrusion area.
Observed. The natural gas-fired air make up unit was not in operation at the time of the
inspection.
2 0102
IES 13 -parts washer Q ' No Yes
The parts washer(sink/drum type, 30 gallon capacity) is used to clean various machinery parts.
The parts washer is in the maintenance area of this facility. The parts washer contained Crystal
Clean 106 mineral spirits (ingredients: 95%-100% petroleum hydrocarbon naphtha and 1,2, 4
trimethylbenzene; SDS in file of facility)at the time of the inspection.
Observed. The parts washer was not in use at the time of the inspection.
IES15 -natural gas-fired crystallizer(0.35 million r2l� .6102 yes Yes
Btu per hour maximum heat input rate) )(2)(E)(i)
The natural gas-fired crystallizer is used to heat the final product(color concentrates)to
recrystallize(re-align)the polymers,which will prevent the pellets from sticking to each other.
The crystallizer exhaust to the outdoor atmosphere through a vertical and capped stack.
Observed. The natural gas-fired crystallizer was not in operation at the time of the inspection.
6. Observations of air emission sources and control devices not listed on the current permit:
a. The natural gas-fired air make up unit(5.31 million Btu per hour maximum heat
input) is used to help with the dust collection efficiency and prevent cross drafts inside of
this facility. The natural gas-fired air unit is located outside near the dispersion shop.
This unit was not in operation during the inspection. This office sent a letter dated April
8, 2015 exempting this natural gas-fired air unit from permitting per 2Q .0102 (c)(1)(B)
now 2Q .0102 (g)(2) due to a rule change. This source should be added to the
exempt/insignificant activities during the next permit revision.
b. This company operates a cryogenic process by using a cryogenic grinding equipment
(hammermill to pulverize resin pellets with no exhaust and grinder exhaust to two fabric
socks with no exhaust)and nitrogen tank(6,022 gallons)to process the resin pellets.
There are no emissions that are vented to the outdoor atmosphere from the process. After
the cryogenic grinder,the ground resin pellets are pneumatically fed through the vacuum
hoppers into the two micro storage silos(25,000 pounds capacity, each). The ground
resin pellets are pneumatically fed to a surge bin. The surge bin is located inside of this
facility and does not exhaust outside. From the surge bin,the ground pellets are placed into
drums or half tote containers for further processing through the six plastic extruders(ID
Nos. I-40009, I-40101,1-40214,I-40328,I-40350 and IES14). These sources were in
operation with no visible emissions observed at the time of the inspection.

Americhem,Inc.
May 9, 2019
Page 13
C. The cartridge filter(244 square feet of filter area and 1,200 acfm) is located in the
production area of this facility and used to control particulate matter emissions from the
steam heated two roll mill. The cartridge filter exhausts inside of this facility and exempt
per 2Q .0102 (g)(14)(J).
d. This company has one propane tank(1,000 gallon capacity)that is used to fuel the
forklifts at this facility. The propane tank is exempt per 2Q .0102(g)(4).
e. This company has two electric Hotsy brand pressure washers that were installed at this
facility in 2017. The two electric pressure washers are exempt from permitting.
f. This company has three natural gas-fired space heaters. One heater is located in the
maintenance area and the other two heaters are located in the warehouse area. The three
heaters are exempt from permitting.
g. This company has a filter cleaner that is used to clean the cartridge filters from the
permitted control devices(ID Nos. DC-1, DC-2 and DC-3). The filter cleaner exhausts
to the cartridge filter(ID No.DC-3 or company ID No. 40449; 9,120 square feet of filter
area). The filter cleaner was not in operation. The cartridge filter was in operation. I
observed no visible emissions from the cartridge filter exhaust of the vertical and
uncapped stack.
h. This company submitted a letter dated December 12, 2018, stating that the liquid color
and mixing process was being removed and replaced with a new and more efficient
container mixer system consisting of a discharge stand and fill station in addition to the
mixer(refer to letter dated December 12,2108 for the permit determination in email
dated January 14, 2019). The new mixing process is connected to the cartridge filter
(ID No. CD-3 or company ID No. 40449; 9,120 square feet of filter area). Ms. Hiott
stated that the clumped or beaded resin and pigment is compounded and mixed(three
areas: dump station; dedusting and mixing) in this process. This process is exempt per
15A NCAC 2Q .0102 (h)(5). The new container mixer system should be added to the
insignificant/exempt activities during the next permit revision.
7. Compliance with specific permit conditions and limitations:
a. Condition A. 2. Permit Renewal and Emission Inventory Requirement-The permittee at
least 90 days prior to the expiration date of this permit shall request permit renewal by
letter with an application form and submit the air pollution emission inventory report
with certification sheet for 2020 calendar year to MRO DAQ.
Observed. I informed Ms.Hiott that the current air permit will expire on April 30,
2022. Compliance with this stipulation is indicated.
b. Condition A. 3. Particulate Control Requirement-As required by 15A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Processes," particulate matter emissions
from the emission sources shall not exceed allowable emission rates.
Observed. The ABM Line#1 (ID No.AMB 1) is controlled by cartridge filter(ID No.
DC-1). The ABM Line#2 (ID No.ABM 2) is controlled by cartridge filter(ID No.DC-
2). The two compounding blenders(ID Nos. 40069 and 40117) are controlled by a

Americhem, Inc.
May 9,2019
Page 14
cartridge filter(ID No. DC-3). The particulate matter emissions from these sources are
not exceeding the allowable emission rates as indicated in the permit review.
Compliance with this stipulation was indicated during the permit application process.
C. Condition A. 4. Visible Emissions Control Requirement - As required by 15A NCAC
2D .0521 "Control of Visible Emissions," visible emissions from the emission sources,
manufactured after July 1, 1971, are limited to 20 percent opacity when averaged over a
six-minute period.
Observed. No visible emissions were observed by me at the facility. Compliance with
this stipulation is indicated.
d. Condition A. 5.Notification Requirement-As required by 15A NCAC 2D .0535,the
permittee of a source of excess emissions that last for more than four hours and that
results from a malfunction, a breakdown of process or control equipment or any other
abnormal conditions, shall notify the Director or his designee of any such occurrence by
9:00 a.m.Eastern time of the Division's next business day of becoming aware of the
occurrence.
Observed. Based on a records review and conversation with Ms.Hiott,no excess
emissions have occurred at the facility. Compliance with this stipulation is indicated.
e. Condition A. 6. Fugitive Dust Control Requirement-As required by 15A NCAC 2D
.0540 "Particulates from Fugitive Dust Emissions Sources" states that the permittee shall
not cause or allow fugitive dust emissions to cause or contribute to substantive
complaints or excess visible emissions beyond the property boundary. If substantive
complaints or excessive fugitive dust emissions from the facility are observed beyond
the property boundaries for six minutes in any one hour(using Reference Method 22 in
40 CFR,Appendix A),the owner or operator may be required to submit a fugitive dust
plan as described in 2D .0540(f).
Observed. MRO DAQ has not received any fugitive dust emissions complaints
regarding this facility. This company has paved roads at this facility. During the
inspection,I observed no fugitive dust or visible emissions from this facility.
Compliance with this stipulation is indicated.
f. Condition A. 7. Fabric Filter Requirements includingcge filters,baghouses,and
other dry filter particulate collection devices states as required by 15A NCAC 2D .0611,
the particulate matter emissions shall be controlled as described in the permitted
equipment list.
a. Inspection and Maintenance Requirements-The inspection, maintenance and
recordkeeping requirements shall become effective January 30,2015 for
cartridge filters (ID Nos.DC-1,DC-2 and DC-3). To comply with the
provisions of this permit and ensure that emissions do not exceed the regulatory
limits,the permittee shall perform, at a minimum, an annual(for each 12 month
period following the initial inspection) internal inspection of each bagfilter
system. In addition,the Permittee shall perform periodic inspections and
maintenance as recommended by the equipment manufacturer.

Americhem,Inc.
May 9,2019
Page 15
b. Recordkeeping Requirements-The results of all inspections and any variance
form manufacturer's recommendations or from those given in this permit(when
applicable) shall be investigated with corrections made and dates'ofactions
recorded in a logbook. Records of all maintenance activities shall be recorded
in the logbook. The logbook(in written or electronic format) shall be kept on-
site and made available to DAQ personnel upon request.
Observed. This company'is tracking the inspection and maintenance of the three
cartridge filters(ID Nos. DC-1 or company ID No. 40447; DC-2 or company ID No.
40448; and DC-3 or company ID No. 40449)by a computer generated preventative
maintenance program. The inspection, maintenance and recordkeeping requirements for
the three cartridge filters became effective January 30,2015. The cartridge filter(ID
No. DC-1 or company ID No. 40447)was installed on January 27, 2015. The cartridge
filter(ID No. DC-2 or company ID No. 40448)was installed on February 10,2015. The
cartridge filter(ID No.DC-3 or company ID No. 40449)was installed on April 20,
2015.
The internal inspections were conducted as follows:
Cartridge filter(ID No. DC-1 or company ID No. 40447) on 3/26/19; 3/26/18 and
3/26/17;
Cartridge filter(ID No. DC-2 or company ID,No. 40448) on 4/8/19;4/8/18 and 4/8/17;
and
Cartridge filter(ID No. DC-3 or company ID No. 40449) on 4/22/19; 4/22/18 and
4/22/17.
Copies of these records are in the file of this facility. The internal inspections of the
three cartridge filters are within the 12 month period time frame as indicated by this
condition. This facility is required by General Condition and Limitation B. 2.to keep
records on site for a minimum of two years. The records of the inspection and
maintenance activities for the three cartridge filters are being kept by this company more
than two years. Compliance with this stipulation is indicated.
g. Condition A. 8.Toxic Air Pollutant Emissions Limitation Requirement-Pursuant to
15A NCAC 2Q .0711 "Emission Rates Requiring a Permit" for each of the below listed
toxic air pollutants (TAPs),the permittee has made a demonstration that facility-wide
actual emissions, where all emission release points are unobstructed or verticallX
oriented, do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A NCAC
2Q .0711(b). The facility shall be operated and maintained in such a manner that
emissions of any listed TAPs from the facility, including fugitive emissions,will not
exceed TPERs listed in 15A NCAC 2Q .0711(b).

Americhem,Inc.
May 9, 2019
Page 16
Chronic Acute Acute
Pollutant Carcinogens Toxicants . Systemic Irritants
(lb/yr) (lb/day) Toxicants (Ib/hr)
(lb/hr)
Cadmium Metal, elemental, _F
unreacted (Component of 0.507
CDC)(7440-43-9) f
Manganese&compounds 1.3
(MNC)
Observed. The TPER limits of 2Q .0711(b) are applicable since the exhaust stacks of
the permitted emission sources from this facility are vertical and unobstructed. The
cadmium metal along with manganese and compounds are contained in various
pigments processed. According to 2013 emissions inventory, no pigments processed at
this facility contained cadmium metal. The total actual emissions of manganese and
compounds were 0.00231 pounds per year during calendar year 2013.
During a permit modification for current Air Permit No. 06330R13,the uncontrolled
emissions of manganese and compounds from the two ABM Lines(ID Nos. ABM I and
ABM 2)were reported as 0.00004 pounds per year and 0.00 as controlled by this
company. The permit review indicated that the HAP emissions were from the blending
of various pigments from the compounding blenders.
The compounding products had a throughput of 1543 pounds per year at 5.0%HAP
weight and the emission factor was 0.0236 lb/1000 lb for a total of 0.00018 pounds per
year; and a throughput of 661 pounds per year at 3.16%HAP weight and the emission
factor was 0.0236 lb/1000 lb for a total of 0.000049 pounds per year. This facility
operates 8760 hours. The throughput of blending products has decreased since 2013.
Therefore, the TPER limits for manganese and compounds are not being exceeded.
Compliance with this stipulation is indicated.
8. NSPS/NESHAP Review:
This facility is not subject to any NSPS requirements.
This company has no emergency/peak shaving generators;fire pump engines or gasoline storage
tanks at this facility.
The exempt boiler (ID No. 1-40135) at this facility is not subject to the National Emission
Standards for Hazardous Air Pollutants (NESHAP) for Industrial, Commercial, and Institutional
Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ or 6J), since this rule does not apply to a
boiler that is gas-fired.
This facility is not subject to the following NESHAPS based on the permit review for Air Permit
06330R13 by Bob Caudle in permitting:
Subpart VVVVVV-"National Emission Standards for Hazardous Air Pollutants for Chemical
Manufacturing Area Sources" because it is exempt by 63.11494(c)(2)(iii), and

Americhem, Inc.
May 9, 2019
Page 17
Subpart BBBBBBB-"National Emission Standards for Hazardous Air Pollutants for Area
Sources: Chemical Preparations Industry" because the facility's NAICS code is not 325998.
9. Summary of changes needed to the current permit:
a. The descriptions should be changed from fabric filter to cartridge filter in the permitted
control system descriptions:
Cartridge filter(ID No. DC-1; 9,120 square feet of filter area)
Cartridge filter(ID No. DC-2; 9,120 square feet of filter area)
Cartridge filter(ID No. DC-3; 9,120 square feet of filter area).
b. The descriptions should be changed from fabric filter to cartridge filter in series with a
HEPA filter in the insignificant/exempt activities descriptions:
Plastic extruder (1-40009; 600 pounds per hour maximum process rate) exhausting to a
cartridge filter (ID No. DC-4, 1,835 square feet of filter area) in series with a HEPA
filter;
Plastic extruder (1-40101; 600 pounds per hour maximum process rate) exhausting to a
cartridge filter (ID No. DC-4, 1,835 square feet of filter area) in series with a HEPA
filter;
Plastic extruder (1-40214; 600 pounds per hour maximum process rate) exhausting to a
cartridge filter (ID No. DC-4, 1,835 square feet of filter area) in series with a HEPA
filter;
Plastic extruder(1-40328; 1200 pounds per hour maximum process rate) exhausting to a
cartridge filter (ID No. DC-4, 1,835 square feet of filter area) in series with a HEPA
filter;
Plastic,extruder(1-40350; 1350 pounds per hour maximum process rate) exhausting to a
cartridge filter (ID No. DC-4, 1,835 square feet of filter area) in series with a HEPA
filter; and
Plastic extruder (IES 14; 100 pounds per hour;maximum process rate) exhausting to a
cartridge filter (ID No. DC-4, 1,835 square feet of filter area) in series with a HEPA
filter;
Diatomaceous earth loading platform (ID No. 1-40068) exhausting to a cartridge filter
(ID No. DC-4, 1,835 square feet of filter area)in series with a HEPA filter; and
Tote compounding platform (1-40074) exhausting to a cartridge filter (ID No. DC-4,
1,835 square feet of filter area)in series with a HEPA filter.
C. The descriptions should be changed from fabric filter to cartridge filter in the
insignificant/exempt activities descriptions:

Americhem, Inc.
May 9,2019
Page 18
Compounding mixer (ID No. I-40077; 50 pounds per hour maximum process rate)
exhausting to a cartridge filter(ID No. DC-3, 9,120 square feet of filter area); and
AME(ID No. I-40134) exhausting to a cartridge filter(ID No. DC-1; 9,120 square feet
of filter area)
d. The plastic extruder (ID No. I-40102; 400 pounds per hour maximum process rate)
exhausting to a fabric filter (ID No. DC-4; 1,835 square feet of filter area) should be
deleted from insignificant/exempt activities since it is no longer at this facility.
e. The laboratory equipment(ID No. IES2) in the exempt/insignificant activities should be
which includes three fiber lines, three muffle furnaces, one microwave furnace, two
fume hoods, four two roll mills, two split bowl-mixers, three drying ovens, three lab
extruders and one false twister(permit determination letter dated October 21,2014).
f. The natural gas-fired air make-up unit (5.31 million Btu per hour maximum heat input)
should be listed in the insignificant/exempt activities of the permit attachment during the
next permit revision. This office sent a letter dated April 8, 2015 exempting this source
from air permitting per 2Q .0102(c)(1)(B) now 2Q .0102 (g)(2)due to a rule change.
g. The two micro storage silos (25,000 pounds capacity, each) associated with the
cryogenic process should be evaluated to determine if these silos should be listed in the
exempt/insignificant activities.
h. This company has a filter cleaner that is used to clean the cartridge filters from the
permitted control devices(ID Nos.DC-1,DC-2 and DC-3). The filter cleaner exhausts
to the cartridge filter(ID No. DC-3 or company ID No. 40449; 9,120 square feet of filter
area). This source should be added to the insignificant/exempt activities during the next
permit revision.
i. This company submitted a letter dated December 12,2018, stating that the liquid color
and mixing process were being removed and replaced with a new and more efficient
container mixer system consisting of a discharge stand and fill station in addition to the
mixer(refer to letter dated December 12, 2108 for the permit determination in email
dated January 14, 2019). The new mixing process is connected to the cartridge filter
(ID No. CD-3 or company ID No. 40449;`9,120 square feet of filter area). Ms.Hiott
stated that the clumped or beaded resin and pigment is compounded and mixed(three
areas: dump station; dedusting and mixing) in this process. ,This process is exempt per
15A NCAC 2Q .0102 (h)(5). The new container mixer system should be added to the
insignificant/exempt activities during the next permit revision.
j. The electronic yellowsheet for permit changes needed has been completed and placed in
the facility's electronic file.
10. Compliance assistance offered during the inspection:
None.

Americhem,Inc.
May 9,2019
Page 19
11. Section 112(r) applicability:
This facility does not appear to be subject to the requirements of the Chemical Accident Release
Prevention Program, Section 112(r) of the Clean Air Act.
12. Compliance determination:
Based on my observations, this facility appeared to be in compliance with the applicable air
quality regulations at the time of the inspection.
DLC:Ihe
c: MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/CABARRUS/00078/1NSPECT 20190509.docx.
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