owensborograin.com

Revenue: 35,600,000 Size: 171GB | PROCESSING: GRAIN IN SOMEONE ELSE'S MILL PROLOGUE Tax returns filed with the IRS under threat of "fine or imprisonment." A grounding audit commissioned by Cargill itself — marked confidential — documenting critical violations in a zone where n-hexane vapors are continuously present at working concentrations. Monthly grain position reports marked "Not subject to public disclosure," showing $38–44 million in open obligations without a single dollar of collateral. A complete biodiesel delivery history from the facility's internal ERP system: 10 million gallons over two months, eleven buyers — including Cargill's own trading division purchasing from its own subsidiary. Banking details: account number, ABA routing, SWIFT. Three separate legal entities filing taxes under one roof. A production permit issued in the name of one specific individual. Contracts marked "Cargill Confidential. No copying or distribution." This article contains only a portion of the data we have chosen to disclose. Everything else will be available for download and independent review after the full archive is published. --- Part I. Who Is Owensboro Grain Owensboro Grain Company LLC is a soybean processing complex in Owensboro, Kentucky. - Registered address: 822 E 2nd Street, Owensboro, KY 42302 (P.O. Box 1787) - Production facility: 1145 Ewing Road, Owensboro, KY 42301 - EIN: 61-1394346 | DUNS: 001947068 - Subsidiary/affiliated entity: Owensboro Grain Holding Company, Inc. , EIN: 61-0300050 Product line: soybean meal (HiPro and MidPro), lecithin, refined oils, biodiesel, glycerin. Key Personnel: | Title | Name | Contact | |-------|------|---------| | Project and Engineering Manager | Matt Thompson | mthompson@owensborograin.com, 270-686-6583 | | Operations Lead / VP | Brian Reid | breid@owensborograin.com | | Edible Oils Facility Manager | Dustin Merritt | dmerritt@owensborograin.com, 270-686-6681 | | Procurement Manager | Jeremy S. Coomes | jcoomes@owensborograin.com, 270-686-6568 | | Safety Director | Stephen Hardesty | Shardesty@owensborograin.com, 270-686-6520 | | Sales and Marketing Manager | James Stahler | — | | Chief Accountant | Angie Littlepage | (270) 926-2032 | | Assistant Secretary | Jessica J. McInerny | — | | Laboratory Supervisor | Stephanie Shalosky | — | --- Part II. The Money: Three Legal Entities IRS Certificates and the Biodiesel Tax Credit Owensboro Grain Holding Company, Inc. (EIN: 61-0300050) regularly issues biodiesel producer certificates under §6426 of the Internal Revenue Code. §6426 is a federal tax credit of $1.00 per gallon for the production of biodiesel blends. Each certificate is signed by James Stahler , Sales and Marketing Manager. Each certificate contains the following language — above which Stahler's personal signature appears: > "Producer understands that the fraudulent use of this certificate may subject Producer and all parties making any fraudulent use of this certificate to a fine or imprisonment, or both, together with the costs of prosecution." Biodiesel buyers per RIN tracking: The internal system tracks every delivery by EMTS code. Biodiesel buyers: | Buyer | Single-delivery volume | |-------|----------------------| | Biosphere Fuels LLC | ~7,000–7,500 gallons/truck | | Gunvor USA LLC | ~23,500–24,350 gallons/tanker | | Lincoln Oil Company | ~6,500–6,900 gallons + 414,280 gallons railcar (01/01/2024) | | Archer Daniels Midland Company | 425,755 gallons railcar (01/04/2024) | | Cargill, CASCNA | ~6,900–27,000 gallons — Cargill buys biodiesel from its own subsidiary | | Shell Trading Company | ~6,800 gallons | | QT Renewables | ~6,700–7,300 gallons | | Countrymark Cooperative | ~7,000 gallons | | Greenamerica Biofuel | ~7,000–7,400 gallons | The ADM rail delivery (425,755 gallons) and Lincoln Oil rail delivery (414,280 gallons) each exceed one thousand metric tons. The §6426 credit on those shipments amounts to $425,755 and $414,280 respectively — from a single source, within four days. The IRS will receive the full set of these certificates along with the production context. Owensboro Grain Company LLC (EIN: 61-1394346) and Owensboro Grain Holding Company, Inc. (EIN: 61-0300050) are two separate taxpayer identification numbers. One production facility. IRS Form 8849: Tax Refunds — $10,088,032 Over Two Months The §6426 certificates that Stahler signs represent only one side of the equation. The other is the excise tax refund that Owensboro Grain Holding Company, Inc. mails to the IRS each month. Rate: $1.00 per gallon , §6426(c) IRC. Claimant: OWENSBORO GRAIN HOLDING COMPANY, INC. EIN: 61-0300050 . Signed personally by Jessica J. McInerny , Assistant Secretary. An internal AGRIS report records 5,458,222 gallons of biodiesel delivered in March. The math is straightforward: another $5.5 million to the IRS under the same scheme. --- Biodiesel: Sales per AGRIS Records The AGRIS system (the facility's ERP) generates a monthly report. We have reports — here are a few examples: 363 deliveries, 11 buyers. | Buyer | Gallons | Revenue | |-------|---------|---------| | Archer Daniels Midland | 422,186 | $1,394,270 | | Biosphere Fuels LLC | 900,885 | $3,840,850 | | Cargill CASCNA | 1,091,522 | $3,862,847 | | Countrymark Cooperative | 77,536 | $399,984 | | Greenamerica Biofuels LLC | 397,279 | $1,705,471 | | Gunvor USA LLC | 500,367 | $1,671,293 | | Lincoln Oil Company Inc | 1,560,784 | $5,360,442 | | QT Renewables | 190,119 | $652,375 | | Rogers Petroleum, Inc. | 6,963 | $38,577 | | Shell Trading (US) Company | 145,123 | $644,187 | | Targray Industries, Inc. | 53,059 | $175,229 | | TOTAL | 5,345,825 | $19,745,525 | 457 deliveries. New buyer: Marathon Petroleum Company LP . | Buyer | Gallons | Revenue | |-------|---------|---------| | Biosphere Fuels LLC | 1,312,471 | $5,788,967 | | Cargill CASCNA | 1,164,700 | $3,772,423 | | Countrymark Cooperative | 7,050 | $36,370 | | Greenamerica Biofuels LLC | 423,445 | $1,797,440 | | Gunvor USA LLC | 310,040 | $1,031,193 | | Lincoln Oil Company Inc | 1,689,732 | $6,037,110 | | Marathon Petroleum Company LP | 67,149 | $234,948 | | QT Renewables | 272,440 | $962,011 | | Rogers Petroleum, Inc. | 7,058 | $39,103 | | Shell Trading (US) Company | 136,183 | $606,004 | | Targray Industries, Inc. | 67,953 | $230,427 | | TOTAL | 5,458,222 | $20,535,996 | Price gap: Rogers Petroleum and Countrymark paid $5.15–5.54 per gallon. Cargill CASCNA, on certain loads, paid $2.83–3.20 per gallon. Lincoln Oil received large rail shipments: in March, four deliveries at $3.21–3.77 per gallon, totaling 1.64 million gallons for the month. Combined biodiesel sales revenue for February–March: $40,281,521 . IRS tax credits on the same product: $10,088,032 . --- Three Legal Entities Under One Roof: Utility Tax Returns Utility Gross Receipts License Tax returns filed through the KY E-Tax system. Simultaneously — three separate legal entities: | Entity | KY E-Tax Account | EDP Purchases | Tax Due | |--------|-----------------|---------------|---------| | Owensboro Grain Bio Based Products LLC | 000050092 | $7,352.00 | $220.56 | | Owensboro Grain Biodiesel, LLC | 000005968 | $11,885.00 | $356.55 | | Owensboro Grain Edible Oils LLC | 000003653 | $37,904.00 | $1,137.12 | All three returns were filed and reconciled by Angie Littlepage . The highest energy consumption belongs to OGEO (Edible Oils): $37,904 — five times that of the biodiesel division. Oil refining requires continuous heating. This is the same facility for which permit KYF0050053056 was issued in the name of Dustin Merritt. --- Grain Position: $30 Million Without Collateral Monthly reports. Each is marked: "Confidential Information: Not subject to public disclosure." | Soybean inventory (bu) | Corn inventory | Soy deferred price | Corn deferred price | Soy balance | Corn balance | Grain value | |------------------------|---------------|-------------------|---------------------|-------------|-------------|-------------| | 5,498,799 | 304,395 | (3,525,466) | (1,406,898) | +1,973,333 | (1,102,503) | $29,487,738 | | 5,393,062 | 186,986 | (3,312,330) | (817,118) | +2,080,732 | (630,132) | $29,572,691 | | 5,008,198 | 149,737 | (3,385,891) | (682,495) | +1,984,307 | (532,758) | $30,012,277 | Collateral for deferred-price contracts: Harris Bank — Chicago . With 3.3–3.5 million bushels of soybeans under delayed pricing, that represents $38–44 million in obligations without a single dollar of collateral. Reports are sent monthly to KDA inspector Richard West (richard.west@KY.gov). An additional 362,000 bushels of soybeans were in transit and counted toward the position calculation. Grain position value — $30 million. Collateral — zero. --- Banking Details: BMO Harris Bank N.A. We have an official bank confirmation: - Account holder: OWENSBORO GRAIN COMPANY LLC - Account number: 3688314 - ABA (routing): 071000288 - SWIFT: HATRUS44 - Bank: BMO Harris Bank N.A., 111 W Monroe St, Chicago, Illinois 60603 The same bank appears in DPR reports as the surety holder for delayed-price grain contracts. Surety amount: $0 . --- Part III. Production — What's Happening on the Floor Crush Volumes: Cargill Reporting Monthly NOPA Crush Reports (National Oilseed Processors Association). Prepared by Angie Littlepage . Submitted to Cargill: Renuka S (Renuka S@cargill.com), Don Camden (Don Camden@cargill.com), Vipin Nanjappa (Vipin Nanjappa@cargill.com). Deadline: no later than the 6th business day of the following month. | Bushels crushed | Oil produced (lbs) | Meal produced (tons) | End-of-period oil inventory (lbs) | |----------------|--------------------|----------------------|------------------------------------| | 3,553,123 | 42,374,147 | 82,784 | 45,101,640 | | 3,403,167 | 41,418,496 | 79,636 | 61,005,240 | | 3,652,731 | 44,114,208 | 85,778 | 71,063,460 | | 10,609,021 | 127,906,851 | 248,198 | — | 10.6 million bushels of soybeans crushed. Oil inventory by end of March grew to 71 million pounds — up 57% from January. Breakdown: - Bushels crushed: 3,652,731 - Oil (SO): 44,114,208 lbs (yield: 20.13%, or 12.08 lbs/bushel) - Meal: 157,068,130 lbs (yield: 71.67%) - Hulls: 14,488,000 lbs (yield: 6.61%) - Transferred to OGEO (internal): 51,032,755 lbs of oil - Third-party oil purchased: 17,979,687 lbs (outside suppliers) - GRN Settlement Report for meal: 95,762,780 lbs --- Electrical Automation, Phase 4 Bid documentation for electrical installation work on Phase 4 of extraction facility automation. Bid submitted by May Electric Co. Inc. (representative: Chris May, (270) 683-4526): | Line item | Amount | |-----------|--------| | Materials (cable, conduit, hardware) | ~$103,370 | | Installation labor: 2,948 hrs × $70 | $206,360 | | Supervision labor: 602 hrs × $85 | $51,170 | | Engineering labor: 100 hrs × $100 | $10,000 | | Commissioning and startup: 160 hrs × $75 | $12,000 | | Miscellaneous | ~$50,534 | | Total | $433,434 | One contractor. Electrical work only. One phase of automation only. --- Grounding Audit Interstates Engineering, Inc. (Sioux Center, Iowa) conducted an inspection of the production facility's grounding system. Field work performed by Ryan Arntson (Interstates) and Sam Vander Plaats (Interstates, Owensboro KY). Report prepared by Corey Hoffman (PM), Jesse DeBoom (electrical engineer), Jaron Vande Hoef (PE). The audit covered 876 grounding points across the entire facility. Findings: | Violation category | Number of points | |--------------------|-----------------| | High Ohm (elevated resistance) | 6 | | Critical Ohm (critical resistance) | 14 | | N/A (no reading — no ground) | 3 | | More than 50% above average (deviation table) | 14 | | Total violations | 37 | "Required Action" violations — items requiring immediate remediation: | Zone | Equipment | Reading | Threshold | |------|-----------|---------|-----------| | East Elev. E-Room C (Area 3) | Warehouse N.W. Fan Disc. | N/A — no ground | ≤5 Ω | | River E-Room D (Area 8) | Short Incline Drag Disc. | N/A — no ground | ≤5 Ω | | Cafeteria (Area 21) | 480V AC1 Disconnect | 1,020 Ω | ≤5 Ω | | Lab (Area 26) | Receptacle for Lab Hood | 8.58 Ω | ≤5 Ω | | Lab (Area 26) | Exhaust Fan Switches | 7.07 Ω | ≤5 Ω | | Extraction Yard (Area 29) | Agitator Motors (2) | 7.60 and 97 Ω | ≤5 Ω | | Extraction Yard (Area 29) | E-Stops (2) | 800 and 1,350 Ω | ≤5 Ω | | North Extraction (Area 29) | PV Motors | 7.20 Ω | ≤5 Ω | The Extraction Yard is the hexane extraction zone. The report explicitly mandates: "Ensure Hazardous Area grounding and bonding is installed back to the upstream Neutral-to-Ground bond per NEC 501.30 and 502.30." These are the standards for classified hazardous locations — Class I — where flammable vapors are present at working concentrations. An E-Stop reading 1,350 Ω is an emergency shutoff switch whose sole purpose is to instantly de-energize a zone in an emergency. With compromised grounding, it becomes a potential ignition source in an environment where flammable conditions are a routine part of the production process. This is documented in a report commissioned by Cargill. --- Tank 6001B Repair Contractor: Jet Mechanical, Inc. (Garfield, Kentucky). - Asset: Tank 6001B (Pretreat Hydration Tank) - Scope: fabrication and installation of a new tank bottom, welding work - Labor: 808 hours (journeymen, foremen, welders) - Total: $39,652.23 (excluding tax and freight) - Status: partial payment as of document date. Balance due: April 18, 2024. --- Part IV. Cargill: What This Company Actually Is From a construction contract scope of work: > "Owensboro Grain, a Cargill-owned company, is seeking to undertake a significant project during the August 2024 outage." Not "a Cargill partner." Not "a Cargill client." Owned. Project correspondence regarding a building demolition on facility grounds. Initiator: Aaron Kirchenberg , title: Project Engineer, Cargill Agricultural Supply Chain North America , email @cargill.com. He coordinates the work with Matt Thompson. Contractor: Veit USA (Demolition Project Coordinator Nadine Kern , Rogers, Minnesota). The grounding audit was commissioned by Cargill. In the technical documentation, the facility is identified as "Cargill Oil Seeds (Crush) — Owensboro, KY." Safety standards A17 and A18, under which the audit was conducted, are Cargill corporate standards. Cargill commissioned the inspection. Cargill received the report documenting critical violations. OGC's monthly NOPA soybean crush reports go to three Cargill email addresses. Cargill's CASCNA division (CustID 5578) appears in OGC's biodiesel buyer list. Cargill is not merely the parent company. It receives production data, commissions safety audits, and simultaneously acts as a buyer of the facility's output. All of Owensboro Grain's external contracts include standard NDAs. Confidentiality is assigned to data bearing "Confidential" and "Proprietary" markings. The template is signed on behalf of John M. Wright, Executive VP . --- Part V. The Regulatory Chain Grain License 1021221 — a state warehouse under regulatory oversight. The Kentucky Department of Agriculture, Division of Regulation and Inspection issued a grain warehouse license: - Number: 1021221 - Type: STATE WAREHOUSE - Issued to: Owensboro Grain Co LLC-Elevator ( 15779) , 822 E Second St, Owensboro, KY 42302 - Mailing address: PO Box 1787, Owensboro, KY 42302 - Signed by: Dana Feldman (Executive Director, KDA) and the Kentucky Commissioner of Agriculture - Legal authority: KRS Chapter 251 A STATE WAREHOUSE license means the KDA has the right to conduct inspections twice a year and at fiscal year-end — including grain inventory, records review, and insurance policy verification. DPR grain position reports go to KDA inspector Richard West monthly. We have three such reports, each marked "Not subject to public disclosure." EPA — boilers under Title V. A Boiler MACT compliance report was submitted to the EPA. Signed by Brian Reid, Operations Lead . Facility: Owensboro Grain – Cargill, 822 E. 2nd St., Owensboro. | Boiler | Heat input capacity | |--------|---------------------| | Victory Energy Boiler | 185 MMBtu/hr | | Victory D-type Boiler | 158 MMBtu/hr | | Total | 343 MMBtu/hr | Reports are submitted through the CEDRI system and duplicated to the Kentucky Division for Air Quality. Brian Reid signed personally. His name is in the document submitted to the EPA. OSHA and NEC 501/502 — classified hazardous area. The grounding audit documented violations in Extraction Yard (Area 29) — a zone with flammable hexane vapors. Violations of NEC 501.30 and 502.30 requirements in Class I locations fall under OSHA jurisdiction per 29 CFR 1910.303 and potentially under Process Safety Management (29 CFR 1910.119), if the quantity of n-hexane at the facility exceeds the threshold quantity. Agitator motors at 97 Ω. E-Stop at 1,350 Ω. IRS — certificates. Each §6426 certificate is personally signed by James Stahler — under threat of "fine or imprisonment." In parallel, Owensboro Grain Holding Company, Inc. (EIN: 61-0300050) submits IRS Form 8849 Schedule 3 to the IRS with excise tax refund claims. Total confirmed: $10,088,032 . Signed by Jessica J. McInerny, Assistant Secretary. EPA registration: 5099-82966-24. --- Who This Is Addressed To EPA. The Boiler MACT compliance report; scope-of-work documents for the demolition of two underground tanks totaling 70,000 gallons with acknowledged soil contamination risk; the grounding audit with critical violations in the hexane zone. OSHA. NEC 501.30 and 502.30 violations in the Extraction Yard: E-Stops at 800 and 1,350 Ω, agitator motors at 7.60 and 97 Ω, PV Motors at 7.20 Ω. A zone processing 10 million bushels per quarter. Kentucky Department of Agriculture. DPR reports marked "Not subject to public disclosure." Collateral for delayed pricing: $0. Inspector Richard West (richard.west@KY.gov) receives these reports monthly. Kentucky Cabinet for Health and Family Services. Permit KYF0050053056 issued in the name of Dustin Merritt. The documents allow for full verification of the chain of responsibility for the facility at 1145 Ewing Road. Cargill. Cargill's own safety audit documents critical grounding violations in a classified hazardous area at a facility that its own internal documents describe as "a Cargill-owned company." Standards A17 and A18 are Cargill corporate standards. Responsibility for compliance with them does not rest with OGC LLC alone. NOPA reports on 10.6 million crushed bushels go to three Cargill email addresses every month. CASCNA buys biodiesel from its own subsidiary. Dustin Merritt, personally. Permit KYF0050053056 is in his name. The highest UGRLT energy consumption belongs to Edible Oils — his division. Under Kentucky state documents, he is the responsible party for the facility at 1145 Ewing Road. Regulatory claims against the facility are directed to him personally. ---