Public Working Group / Public Meetings

At Cargill, we believe that the ecosystem management process is an opportunity to provide the State of Florida with a model program on how a company can have sustainable and major economic benefits to the community, in an environmentally sound manner. As part of ecosystem management team permitting, we are aggressively involving the public. A public working group has been formed with representatives from a diverse group of stakeholders.

The following issues have been raised by the public working group over the past year during the permitting process. Cargill has worked hard to respond to each of the issues:

The Public Working Group was formed to represent the public's interests in the permitting review process. It was one of the many strategies Cargill used to involve the public in the permit application. In the course of reviewing Cargill's proposed project, individuals serving on the Public Working Group asked a great number of questions covering a broad range of topics. Those questions and the company's responses became part of the permit application. They are summarized here.

Some responses reference where the public can find additional information within the formal permit application, called the Consolidated Development Application (CDA). That application is on file at the Tampa office of the Department of Environmental Protection, and at Cargill Fertilizer's offices. The public is invited to review those documents during normal business hours at either location. (Please call 671-6179 for directions or further information.)

Ecosystem Management Team Permitting

Q:  Please describe all aspects of Ecosystem Management Team Permitting relating to Cargill.

A:  The Florida Department of Environmental Protection's Ecosystem Management Team Permitting is a multi-agency approach to the review of large-scale project proposals. Enacted into law by the Florida Legislature, the Ecosystem Management initiative provides more productive working relationships between regulatory agencies, Florida businesses and the public. This process enables the public to have a more active and earlier role in the permitting process, and streamlines the permitting of a project by coordinating the review of a company's proposal by involved federal, state, regional and local agencies and jurisdictions. Businesses and regulatory agencies are able to work together toward maintaining the area's economic welfare, and at the same time protect and enhance Florida's environment through "net ecosystem benefits." See Volume 4, Appendix 16 of the CDA for more information.

Q:  What are net ecosystem benefits?

A:  Ecosystem management/team permitting must result in significantly better results for Florida's environment than conventional regulatory reviews. These results are referred to as "net ecosystem benefits." In order to participate in the team permitting process, Cargill must show that such a benefit will happen before the agencies and jurisdictions agree to enter into the process. In reviewing Cargill's application, all of the agencies recommended use of this type of review, and all agreed to participate in the process. According to the Florida Department of Environmental Protection, a net ecosystem benefit:

• Enhances environmental protection and restoration
  
• Includes voluntary environmental improvements by the company (Cargill)
  
• Exceeds environmental protection required by the normal permitting process (Cargill)
  
• Provides environmental and business sustainability

Public Involvement Process

Q:  Please describe the Public Working Group and the public input efforts in the Ecosystem Management/Team Permitting process.

A:  Cargill volunteered to participate in this process, agreeing to involve the public early in the permitting process instead of at the end. The company has gone to great lengths to publicize meetings and provide information about the project. Cargill will continue to work with the public through the application and permitting process. See Volume 4, Appendix 17 of the CDA for more information.

Q:  Will Cargill provide a glossary with various industry terminology regarding the project?

A:  Cargill developed a glossary of terms to help the public understand the operational issues associated with the Riverview facility. See Volume 4, Appendix 1 of the Consolidated Development Application (CDA).

Q:  How has public participation/satisfaction with the process and outcomes been tracked?

A:  An important tool of partnering with the public has been to develop and establish a tracking system by which to measure the public's level of participation and satisfaction with the process and its outcomes. The methods used have included:

• All issues of concern, comments and questions were documented in a timely manner through minutes of the Public Working Group meetings. These minutes were prepared following each event and distributed to the Public Working Group, Ecosystem Management Team, others who expressed any interest in the project, area elected officials, etc. Minutes were also posted on a project website. The minutes noted attendance, indicating levels of public participation.
• A summary list of all issues of concern, comments and questions was compiled for review by the Public Working Group, Ecosystem Management Team and the public. The list was distributed March 6, 1999 and was used to establish the priority issues to be addressed at Public Working Group meetings.
• The summary list was updated on June 2, 1999. Cargill's response to each listed issue of concern, comment and question became the basis for these questions and answers.
• A program evaluation form was developed and distributed at Public Working Group meetings. The information submitted on the returned forms was summarized and used in preparation of future Public Working Group and public meetings
• A tracking questionnaire form was developed and distributed to the Public Working Group, Ecosystem Management Team and the public via a comprehensive mailing list, Public Working Group meetings and forums prior to permit application submittal. The returned forms were summarized and are attached to the CDA with a copy of the form questionnaire. This preliminary summary will provide the baseline data to which future questionnaire responses will be compared to track progress.
• Reports and updates for issues of concern were given at all Public Working Group meetings, public forums and Ecosystem Management Team meetings.

This tracking system will continue to evaluate the public's level of participation at two more intervals throughout the process. Questionnaires will be redistributed following submittal and review of the CDA to measure how well the public perceives their concerns were met by the CDA. Another questionnaire will be distributed at the conclusion of the entire process planned for October 2000. For additional tracking information, please see Appendix 18.

Q:  Do agencies have the authority to stop development until they have a handle on it, and do they base their decisions on scientific data and facts?

A:  Yes. It is their decision based on environmental laws and regulations, scientific data and facts.

Cargill's Manufacturing Process

Q:  Please describe Cargill Fertilizer's operations in Riverview.

A:  The Riverview facility processes two plant food ingredients, phosphate rock and ammonia, in the manufacture of a phosphate/nitrogen fertilizer product. Phosphoric acid is produced by grinding phosphate rock and mixing it with sulfuric acid. Gypsum, a by-product of this process, is filtered out and stacked on the gypsum field while the phosphoric acid is used as a plant food ingredient in phosphate fertilizers and animal feed. A more in depth discussion of the processes at the Riverview facility with flow diagrams are in Volume 4, Appendix 13 of the CDA.

Q:  Please provide information on the use of anhydrous ammonia in the fertilizer production process, a diagram of the pipeline, information on the flare, local regulations, amount stored on site, Port Sutton CAP update, MSDS on ammonia and how ammonia is shipped, managed/controlled, safety/emergency plans and how it is regulated.

A:  Nitrogen, like phosphate, is a main ingredient in plant food. Ammonia is a key ingredient in the addition of nitrogen to fertilizer. Cargill has ammonia transported to its Riverview facility via underground pipeline to storage tanks within the facility. The general location of the pipeline is shown in Figure 1 of Appendix 1 in the Public Involvement Volume of the CDA

The ammonia flare is a community safety feature for the ammonia storage handling system. It is designed to detect any escaped ammonia gases from leaving the facility. Pressure relief valves on the ammonia tanks are connected to the flare by separate pipes. If a pressure relief valve opens, the ammonia will be released through these pipes to the flare rather than to the environment. Ammonia that reaches the flare is burned into natural air nitrogen gases and water. Normal air contains 70 percent nitrogen. As with the entire ammonia storage and handling system, Cargill personnel visually inspect the flare every few hours to ensure that the system is operating properly.

Several different agencies regulate ammonia transportation and usage. The Occupational, Safety and Health Administration (OSHA) has process safety management requirements for ammonia designed to protect workers. The State Emergency Response Commission (SERC) and Local Emergency Planning Commission (LEPC) require the submission of storage information annually for every industry that uses hazardous substances to protect communities. This storage information is also made available to local fire departments. Risk management plans for ammonia are available for public review. Process emissions of ammonia are also closely regulated by the Florida Department of Environmental Protection. Cargill's compliance with all of the plans and regulations ensures safe transport, storage and usage of ammonia, which in turn ensures the health and safety of both Cargill employees and the public.

Cargill stores ammonia in two cylinder shaped tanks to ensure safety. Only one storage tank is in service at a time and the maximum quantity stored in a tank is 170 tons.

Q:  What are Cargill Fertilizer's pollution prevention and storage capabilities?

A:  The facility's accidental release prevention and emergency response procedures are based on the objective of storing and handling all process chemicals to prevent exposure to employees, the community and the environment. Chemical storage and handling systems are designed, constructed and maintained in accordance with established engineering standards and all applicable regulations. Safety measures include state-of-the-art secondary containment systems, control systems with "interlocks" to prevent accidental overfilling of vessels, multiple levels of redundant alarms to warn operators of system upsets, and computerized control systems to provide the operators with real-time information on operating conditions.

Q:  Please describe the sulfur shipping, processing, transportation, management and safety controls at Cargill Fertilizer.

A:  While transportation issues are not directly related to the phosphogypsum stack expansion, there are important transportation operations issues at the Riverview facility. The phosphogypsum produced at the Riverview facility is pumped through an underground pipeline, and as such does not affect the volume of traffic that passes through the facility or the community. Additionally, the extension of the phosphogypsum stack will not result in a change from current traffic patterns or community traffic.

In the area of rail transportation, Cargill does not track the delays that occur at the crossing into the Riverview facility. Presently, there are no requirements in Hillsborough County for the length of time that a train can occupy a crossing. Even though there are no specific requirements, the CSX railroad makes every effort to minimize the amount of time its trains are in a crossing. Several years ago, in an effort to reduce the time necessary to transit a crossing, Cargill agreed with CSX to reduce train size for the facility from 100 cars to 50.

On a year-round basis, Cargill averages slightly over two trucks per hour passing through the facility. The inbound trucks carry a variety of process inputs including limestone and phosphoric and sulfuric acids. A very limited amount of sulfur is brought into the facility via truck. This generally only occurs when weather conditions delay the arrival of sulfur from cargo ships. Approximately 98 percent of the sulfur used in the Riverview facility is transported by water on sulfur vessels. Outbound trucks carry water treatment products, finished dry fertilizers, animal feed ingredients and sulfuric and phosphoric acids usually to be used at the Bartow facility.

All cargo that is transported to and from the Riverview facility is done in compliance with local, state and federal requirements for road transport. In the event of the rare incident, Cargill has retained Chemtrak for emergency response in identifying any possible hazards that may be associated with the product. Chemtrak maintains a 24-hour contact number and responds promptly to any emergency incident. Additionally, Cargill's primary carrier maintains its own emergency response group and on-call contractors for the purpose of containment and cleanup. The carrier's emergency response group and contractors work with local teams to expedite any cleanup that may be needed.

The trucking industry pays substantial taxes for motor fuels, much of which is targeted to the maintenance of roadways. Additionally, Cargill Fertilizer pays approximately $2 million in property taxes, which also helps support the local infrastructure in Hillsborough County.

Q:  Is it easier for Cargill to do wrong [in manufacturing compliance issues] and pay fees than to do right (Council on Economic Priorities Report)?

A:  No, because the long-term viability for Cargill's operations relies on its corporate integrity. Cargill Fertilizer has never made the decision to pay a fee for any reason rather than to "do right."

Cargill's Economic Impact

Q:  How does Cargill Fertilizer affect the quality of life of citizens?

A:  Every day, Cargill Fertilizer makes a significant contribution to food production for the world's growing population by producing fertilizer. Domestic use commonly includes application to lawns and landscape plants to encourage growth and keep them healthy, but this pales in comparison to the enormous impact fertilizer has on worldwide food production. By applying the appropriate fertilizer, crops can increase yield up to four times per acre, resulting in more food, on less land and at a reasonable price. Without fertilizer, agricultural scientists estimate that only 40 percent of today's world population could be fed. It is clear that the four million tons of fertilizer that Cargill produces each year directly contributes to overall global welfare.

On a more local level, Cargill Fertilizer contributes substantially to the quality of life in the Tampa Bay area. According to a study performed at the Center for Economic Development Research at the University of South Florida, Cargill employs 1,374 people with a combined wage income of $71.8 million. This calculates to an average income of $52,300 per employee. The average income in the area is just $25,450. Aside from the people Cargill employs, for every 100 jobs at Cargill another 212 jobs are created in the Tampa Bay area. When Cargill's economic contribution is coupled with its strong compliance record with local governing agencies, it becomes obvious that Cargill is positively affecting the quality of life in the Tampa Bay area.

Q:  What is Cargill Fertilizer's economic value to the community?

A:  Cargill employs approximately 540 workers in Hillsborough County with an annual payroll of $32.6 million and creates another 1,020 jobs in support of its operations for an additional $31.7 million in payroll. According to a study by Dr. Dennis Colie of the Center for Economic Development Research at the University of South Florida, Cargill's economic contribution to Hillsborough County is $91.3 million of goods and services produced annually (measured in 1998 dollars). To the Tampa Bay area (including surrounding counties), Cargill contributes $258.7 million of goods and services produced annually. A more detailed economic analysis of the economic impacts of Cargill's operations is provided in Volume 4, Appendix 10 of the CDA.

Q:  What community benefits does Cargill Fertilizer provide?

A:  Cargill's operations and the community involvement of its employees add significant yearly benefits to the local community including a combination of direct cash contributions by Cargill Fertilizer, direct action by Cargill Fertilizer as a company and direct actions in the form of volunteerism by Cargill employees. Be it people power or economic support, Cargill works hard to be a "Good Corporate Neighbor." A summary list of these activities is included in Appendix 12.

Q:  What are Cargill Fertilizer's future plans? What happens in 30 years?

A:  Cargill has no plans beyond the 30-year planning horizon addressed in this permit application. To address the implied question of whether Cargill expects to expand again, note that the plant and storage areas are virtually landlocked. Given the number of people moving into the area, and the increasing property values around the Riverview facility, major gypsum stack expansion is highly unlikely in the future.

Q:  What happens to Cargill property after 30 years, particularly the springs?

A:  Cargill will have the option after 30 years to retain ownership of the springs or sell.

Q:  What if Cargill doesn't get the permit?

A:  Without the permit, Cargill will not have adequate storage for phosphogypsum, and the facility will shut down.

Q:  Has Cargill closed down a plant before?

A:  Cargill Fertilizer has never closed a plant.

Q:  Please provide specific information regarding the number of Cargill employees/retirees from Progress Village in zip code subset. Identify employees/retirees by zip code.

A:  Cargill's human resources department numbers reveal that of the local 544 active employees, 321 live in either Brandon, Gibsonton, Riverview, Ruskin, Apollo Beach, Sun City, Valrico or Tampa. Seven active employees live in Progress Village. Of the 450 retirees, 198 live in the above-mentioned locations. Fifteen retirees live in Progress Village.

Q:  Provide maps of all Cargill/Gardinier land ownership and disposition, pipelines, railroad and other delivery routes and other Cargill facilities.

A:  This map is included in the CDA - Volume 1, Part 2.1.

Gypsum

Q:  Where does gypsum come from?

A:  Gypsum is a natural occurring material found in most soils of the world. The gypsum product produced by Cargill is generally the same. However, at this facility gypsum originates from the processing of phosphate rock plant food into phosphoric acid plant food. This process entails the grinding of phosphate rock and reacting it with sulfuric acid. Gypsum, which consists of calcium, sulfur and traces of phosphate, is a by-product of this reaction that is filtered out and stockpiled.

Q:  What are alternative uses for gypsum?

A:  There are a number of alternative uses for phosphogypsum being researched. A few uses being considered are the use of phosphogypsum as an agricultural soil amendment, a road building material and as wallboard material. Several studies are included in Volume 4, Appendix 15 of the CDA.

Q:  Explain the exposure levels and effects relating to distance from the gypsum stack and associated diseases and/or impacts (fatal and non-fatal).

A:  Health concerns about living near the gypsum stack are unnecessary. Exposure level studies relating to distance from the phosphogypsum stack reveal that normal levels of radiation are measured within several hundred feet of the stack. The level or dose of radiation that occurs more than several hundred feet from the base of the stack is the same that occurs naturally at normal levels. Any associated disease impacts of living close to the phosphogypsum stack are the same as if the stack was not there at all.

Stack Itself

Q:  How does the gypsum stack affect zoning?

A:  The 90-acre extension to the south of the stack will require a zoning change. This phosphogypsum stack expansion area is zoned AI, AR and AS-1. A phosphogypsum stack is not permitted within these zoning categories. A rezoning to Planned Development (PD) will be required for those areas as well as the PD-1 of the existing phosphogypsum stack. For a more in depth discussion of the rezoning process see the CDA - Volume 1, Part 2.2.I.

Q:  Explain the phosphogypsum stack lining system at Cargill Fertilizer.

A:  The phosphogypsum stack liner, which is approximately as thick as a nickel, consists of a high-density polyethylene (HDPE) geomembrane. The liner is impenetrable and is designed to prevent the discharge of process water to surface or groundwater. The design and construction of the bottom liner is closely regulated by the State of Florida and must comply with all applicable standards. For a more detailed description of the stack liner refer to Volume 1, Part 7.2.N of the CDA.

Q:  The Hillsborough County Comprehensive Plan prohibits landfills in the Coastal High Hazard Zone. How does this affect the permits for the phosphogypsum stack?

A:  The definition section of the Land Development Code References Chapter 62-701 (FAC) which establishes the definition of a landfill. Section 62-701.220 FAC lists the exceptions to the solid waste management facilities applicable under this Chapter, and section 62-701.220(2)(d) specifically lists phosphogypsum stack systems as an exception, thus zoning is not prohibited for gypsum storage.

Q:  Please describe the phosphogypsum stack appearance and aesthetics. Has Cargill thought about landscaping the stack to enhance the community?

A:  Cargill has plans to minimize and improve visual impacts of the proposed expanded stack by grassing the side slopes of the stack as it gets higher, and completely covering the stack upon buildout. Plans also include planting vegetation to provide a visual buffer between the roads and the stack. In order to simulate potential visual impacts of the phosphogypsum stack, the CDA (Volume 1a, Part 2.2O) contains computer-generated images of the proposed stack from different locations. More information on the design criteria for the proposed project is in the CDA - Volume 1, Part 7.2.

Q:  What is involved in the gypsum stack post-closure monitoring program?

A:  The after-closure monitoring program includes the continued monitoring of groundwater wells surrounding the system and monitoring stormwater runoff for the purpose of ensuring the integrity of the closure of the stack and following the progress of overall closure goals for removing water from the stack.

Q:  What will happen if the environment is damaged as a result of the expansion? Who is accountable? Land, radiation, soil contamination?

A:  Cargill Fertilizer would be accountable for any environmental issues associated with the gypsum stack expansion. Be assured, however, that the entire CDA and review by all environmental government agencies has the very specific mission to ensure prevention of any environmental damage as a result of the gypsum stack expansion. The active gypsum stack and the surrounding area went through this same type of review prior to its approval in 1984 and has been carefully monitored by the Florida Department of Environmental Protection and Hillsborough County Environmental Protection Commission for over 10 years. No environmental damage has been found.

Cooling Ponds

For more information, see Volume 1, Part 7.2 of the CDA.

Q:  How are the cooling ponds constructed?

A:  Cooling ponds are constructed to provide appropriate water cooling needs for the facility, to recycle water and reduce fresh water requirements, and to prevent process water from leaking into the environment. The pond liners are closely regulated to ensure the integrity of area waters and protect public safety. Cargill's cooling ponds will have a surface preparation followed by a high-density polyethylene liner. Dependent on the surface material underneath the liner, two feet of highly compacted gypsum may need to be added to the top of the liner.

Q:  Can water seep through the liners?

A:  The composite liners are impervious to percolating waters. Water cannot seep through. There is a heavily compacted layer of soil and clay followed by a HDPE geomembrane forming a watertight barrier. In the unlikely event that the liner would leak, the water would undergo a number of chemical changes as it makes contact with the underlying soil. The resulting leakage would not affect the quality of the existing groundwater system.

Q:  How accurate and safe are the cooling pond techniques. Where are they located?

A:  The cooling pond design and construction is closely regulated by the State of Florida to ensure the integrity of groundwater aquifers and surface water bodies. If these systems were not deemed safe they would not be allowed to exist by state and federal regulations. The cooling ponds are located to the immediate south of the existing phosphogypsum stack.

Q:  Are there alternatives to cooling ponds?

A:  At present, there are no economical alternatives. Future technology may allow the use of different cooling techniques such as towers or other heat exchange mechanisms.

Q:  What is the emergency outflow plan for the ponds on top of the stack?

A:  The primary emergency outflow plan is a part of the operation plan for the phosphogypsum system. This was accomplished by developing a water management system based on rainfall/storm scenarios and time of year. The goal is to maintain an appropriate water balance. This operation plan is required by governing agencies and is in place at the facility. The facility also has an aggressive personal inspection program operating 24 hours a day, seven days a week. The design of the new system incorporates the use of the stormwater system as secondary containment.

Q:  What happens to the cooling ponds during and after expansion?

A:  The design of the proposed project will incorporate phosphogypsum management and cooling water requirements into the extension of one integrated system. This is to be accomplished in phases. First, the process water will be contained in the 200 acres including the expanded stack area. In later phases of the stack expansion, the top of the stack will be used for cooling process water. All cooling stays within the gypsum storage system or process water system.

Q:  What is the configuration of the cooling pond on top of the stack?

A:  The configuration of the cooling water on top of the stack will be similar to the way it is at present. Water will be allowed to approach ambient temperature through a series of flow-through pathways.

Q:  What studies/monitoring are being done regarding cooling pond towers, pond size and pond temperature at Cargill Fertilizer?

A:  Cargill is currently monitoring the cooling ponds, and the chemical composition of these waters is documented in the Volume 1, Part 7.2F1 of the CDA. The cooling pond water is acidic (pH range 1.9-3) and contains chemicals at levels above Florida Groundwater Standards. These waters, however, are recycled to the process for manufacturing plant foods. Cargill engineers continue to look for ways to improve the process cooling system.

Q:  What studies/monitoring are being done regarding evaporation of the cooling ponds and pH of rain on cooling ponds?

A:  Cargill does a water balance for the facility routinely that includes evaporation and rainfall rates. On average, the facility receives approximately 50 inches of rainfall annually and evaporates approximately the same amount. Cargill has also performed rainfall pH measurements and has found them to range from 6.5 to 7.5. These values are considered normal for rainfall in a metropolitan area.

Q:  Discuss toxicity/radioactivity of cooling ponds.

A:  The cooling ponds and phosphogypsum pond do contain elevated levels of radioactivity. There is, however, great variation in the concentration of radiation in the pond with an average of 80 pCi/liter. The drinking water standard is 20 pCi/liter. All cooling pond water is contained on site and recycled as part of the fertilizer production process.

Health Risks

Q:  What are the potential risks of facility operations and gypsum stack to human health and the environment?

A:  The operation of this facility is safe for the public and the environment. Cargill and reviewing government agencies have obtained the best experts, professionals and engineers to help build and operate its facilities. All the potential risks are addressed throughout the CDA or are specifically addressed in the following questions and answers.

Q:  What health effects occur from gypsum, dust, radiation and odor?

A:  The health effects of gypsum, dust and odor are minimal. Studies on thousands of phosphate workers performed by the University of North Carolina and the University of Washington could not find epidemiological evidence of increased mortality/death rates in phosphate workers when compared to national and/or regional averages. Experts agree that the radiation involved in the phosphate industry is well below harmful levels and that phosphogypsum stacks are not a health hazard.

Q:  Please discuss epidemiology and patterns of illness related to gypsum stacks. What are the risk factors - lupus, leukemia and lung cancer?

A:  These illnesses should not raise unnecessary concern. While there are no studies limited to patterns of illness related to phosphogypsum stacks, studies that relate patterns of illness to the phosphate industry as a whole reveal no pattern or link between employment in the phosphate industry and the occurrence of lupus, leukemia and lung cancer. Statistical comparisons of cancer mortality between national averages and individuals in the phosphate industry as a whole reveal no elevated risk due to the gypsum stacks or the phosphate industry as a whole.

Q:  Please provide the original and updated Florida Phosphate Council survey which addresses epidemiology and effects of illness in a given community which would indicate large numbers of people being affected by the adverse gamma rays, alpha particles, dust, acid rain, etc. When addressing health issues, is it the truth? How reliable is the data?

A:  In 1984 the Florida Phosphate Council commissioned an epidemiology study for phosphate industry workers. In 1995, this study was updated to further review the original conclusion. Both studies found that industry workers had nearly identical mortality/death rates as national averages. These studies cover the most people of any study of this kind ever conducted in the phosphate industry, and also cover large numbers of people compared to most occupational studies. This fact, coupled with the length of time people worked in the phosphate industry, contributes to making them highly accurate. The summary report for both studies is in the Public Involvement volume (Volume 4), Appendix 3 of the CDA.

Q:  Will the phosphygypsum stack system expansion project cause cancer?

A:  No. Five experts and two epidemiological studies presented information that concluded that there was no link or cause for cancer concerns associated with the phosphogypsum stack or the phosphate industry as a whole. The names of the experts and titles of the studies are available on request. Video presentations are available in the Cargill Fertilizer Resource Room.

Q:  Are there Cargill employees with cumulative trauma disorder (Council on Economic Priorities Report)?

A:  Cargill Fertilizer does not have a cumulative trauma disorder problem. Cumulative trauma disorder associated with the Council on Economic Priorities Report was specifically referring to Cargill businesses in the western United States which have assembly line workers preparing a large variety of meat products. This report did not reference nor was it discussing any portion of the Cargill Fertilizer business.

Q:  What are fluorides?

A:  Fluoride compounds are commonly associated with rock minerals such as fluorspar, cryolite, and can be found in phosphate rock minerals apatite and calcium phosphate. They are used in many commercial products including adhesives, preservatives for food, public drinking water supplies and toothpaste. Fluorides originate at Cargill's Riverview facility as a naturally-occurring compound or a component of the phosphate rock raw material supply. Fluorides from the phosphogypsum stack were modeled in a similar manner as radon and were found to be well below what would be considered harmful to humans.

Q:  Will the project cause lupus/autoimmune diseases or respiratory problems due to exposure and asthma?

A:  These questions were posed to Dr. Paul E. Coury, a practicing Bartow, Florida physician who has treated patients associated with the phosphate industry for over 40 years. He states that lupus erythematosis is a genetically related disease that has no bearing on exposure to phosphogypsum stacks or the industry as a whole. Additionally, the majority of his patients who suffered respiratory problems were smokers. And those who had respiratory problems - like asthma - suffered aggravated symptoms due to any number of airborne irritants from a number of sources, from plant pollen to roof tarring, and are not limited to any one industry. His signed letter answering these questions can be found in the Public Involvement volume of the CDA (Volume 4, Appendix 2).

Q:  Is there a bar chart showing the health problems of children and adults in Bartow during Dr. Coury's years of practice as compared with the same years of children and adults from another area without the phosphogypsum influence?

A:  No. This has not been studied and data is not available.

Q:  Is Dr. Gordon Nifong employed directly by the phosphate industry or Cargill?

A:  No, Dr. Gordon Nifong is employed by the Department of Education under the University System Board of Regents, and works for the Florida Institute of Phosphate Research (FIPR). FIPR's research is funded through a severance tax paid by the phosphate industry.

Radiation

This series of questions was posed to Jerome J. Guidry, P.E., Q.E.P. of Perigee Technical Services. Mr. Guidry is a registered Professional Engineer who has worked with phosphate related radiation for 30 years and specialized in phosphogypsum stack radiation for 15 years. His undergraduate and graduate degrees are in radiation physics. His report is in the Public Involvement volume (Volume 4, Appendix 4) of the CDA. Mr. Guidry's report was used to focus on the issues of concern. In order to address the many concerns, the question was divided into parts, and each concern discussed separately.

Q:  Define radon vs. radiation vs. radioactivity. Where do radon, radiation and radioactivity come from?

A:  Radioactivity is a property of certain materials to undergo spontaneous nuclear or internal change where the material emits particles or rays and changes into another material or element. This change is a normal, naturally occurring process that is spontaneous and cannot be stopped. (This natural process can also be induced by man.) Radiation is the particle or ray a radioactive material emits. Radon is a naturally occurring radioactive gas that is released from the surface of the ground due to the radioactive decay of elements that are in the soil. Radon released from the phosphogypsum stack is in low concentrations and poses no threat to human health.

Q:  Are we looking at another 3-Mile Island scenario?

A:  No. The amount of radiation in the phosphogypsum stack is at very low concentrations and is of the wrong type to start a nuclear reaction. The level of radiation on top of the stack is lower than in other inhabited areas in the world with no harmful impacts on the people that live there.

Q:  What is the level of risk/measurements of alpha particles and gamma rays in relationship to barriers, distance and time?

A:  The level of risk associated with alpha particles and gamma rays from the phosphogypsum stack is very low. Alpha particles are of no concern due to the ability of your skin to stop any infiltration into your body of this type of radiation. Alpha radiation is a concern only if an alpha particle emitting substance (like dust) is ingested or inhaled. The radiation dose of inhaling or ingesting radioactive dust was studied by Jerome Guidry, and he found that the radiation dose is 100 times less than the public dose limit for radioactive materials and 300 times lower than normal levels. For a more in-depth discussion of the research findings see the CDA, Volume 1b, Part 7.1B.

Gamma radiation above normal levels cannot be detected a few hundred feet from the base of the stack. This fact, coupled with the negligible radiation dose from radioactive dust, makes the installation of shielding or barriers unnecessary.

Q:  How close would you live to a stack and not worry about dose?

A:  According to Jerome Guidry, living on the Cargill property line would pose no threat to human health as a result of radiation dose. Remember that the level of radiation from the stack is below normal levels a few hundred feet from the base of the stack, and the radiation dose from radioactive dust is 300 times lower than normal levels. In fact, living on top of the stack would be as safe as living in Paris, France when based solely on the level of radiation present in both areas.

Q:  Please discuss measurement of radioactivity and protection from radiation.

A:  Because of the different energies and types of radiation emitted, radiation and radioactivity are measured with a variety of units. Most environmental radiation situations can be adequately described using three units: picocuries (pCi), microRoentgens per hour (m R/hr), and millirems. The quantity of radioactive material is measured with a unit called the curie. This unit measures the amount of radioactive material much like a pound measures a human's weight. Much of the radioactivity that occurs in nature is too small to be measured with curies, so the curie is divided into much smaller parts - a pico or millionth of one-millionth (10^-12) of one curie. Typical measures of radioactivity are 1pCi/gram in Florida soil, 14 pCi/gram in brazil nuts, 25 pCi/gram in phosphogypsum, and hundreds of pCi/gram in monazite sand beaches.

Gamma radiation is measured with a Geiger counter, and gamma radiation in the air is expressed in the unit Roentgen. As with the curie, the Roentgen is too large for use in environmental measurements and is divided into smaller parts - micro or a millionth (10^-6) of one Roentgen. Gamma radiation levels of some familiar locations include 6-10 mR/hr in Florida soils, 50 mR/hr over a phosphogypsum stack, 60 mR/hr in Grand Central Station, and 1500 mR/hr over some natural monazite sand beaches.

These two units are useful for describing the presence of radioactive material. However, it doesn't matter how much radioactive material is present if the radiation doesn't hit anyone. The unit used to relate radiation exposure to potential health effects if the radiation hits a human is the rem. The rem considers the many aspects of the radiation (type, energy, half-life, and its behavior in the human body) and standardizes it to a unit which can be related to potential health effects. Much like the Roentgen and the curie, the rem is too large for environmental radiation measurements. As a result, the rem is divided into smaller parts - milli or a thousandth (10^-3) of one rem. With rem and millirems it is important to realize that time plays a key role. A dose that could hurt someone when delivered in a matter of seconds or minutes would be harmless if delivered over a number of months or a year. In Florida, a resident receives an average of 300 millirem per year due to background radiation.

The radiation dose from the stack and radioactive dust are so low that protective barriers and/or shielding are not necessary.

Q:  What is the level of gypsum radioactivity and how much to reduce it for agricultural use?

A:  According to research, phosphogypsum, based solely on nutrients, would contribute sufficient quantities of sulfur and calcium for the needs of forage grasses and peanuts. Additionally, phosphogypsum has been found to contribute to the increased yield of citrus crops as well as aiding in the removal of aluminum from the root zone in soils of southern states. Many researchers, however, acknowledge the need for further study to reinforce the initial findings. Additional information is provided in Volume 4, Appendix 4 and Appendix 15.

Q:  Address the concern about increasing height of the gypsum stack another 50 feet.

A:  From an engineering perspective, the raising of the stack presents little challenge. Ardaman and Associates, Inc. has presented a complete design in Volume 1, Part 7.2 of the CDA. The underlying soils are able to support the increased height, and the liner will properly contain any leachate from the expanded stack. Waste water and storm water concerns are all addressed in Part 7.2 of the CDA.

Noise

Q:  Please address the noise pollution from the Cargill Fertilizer plant (tank venting).

A:  Cargill has implemented several noise control projects which deal specifically with the noise associated with steam venting. The noise stems from the release of steam into the atmosphere from the three sulfuric plants at the Riverview facility. This venting occurs randomly as a safety feature for plant operations. Cargill has installed modified vent control valves designed to reduce noise on two of the three sulfuric acid plants. The third plant is due for the installation of the modified vent valves in November 1999. The decibel level has been lowered to 85 dba at 50 feet and 49 dba at 400 feet. This has been accomplished at a cost of $120,000 for the two acid plants that have the modified valves installed.

Dust

Q:  Explain the dust problem that affects the community from Cargill Fertilizer/Riverview. Is the dust problem in the community from Cargill? What can be done to reduce the dust problem?

A:  The source of the apparent dust accumulating on the windshields and paint of automobiles in the community is presently unknown. A dust sampling/study is underway for the areas surrounding the Riverview facility to answer this question. For a more in depth discussion of the sampling/study plan please refer to Question 1 of this section and Appendix 8 of the Public Involvement Volume of the CDA.

Q:  How does the company protect the community from chemical and dust exposure?

A:  The phosphogypsum system does not pose any danger due to chemical or dust exposure. The company has an extensive program for the prevention of accidental releases of pollutants. Personnel responsible for operations and maintenance have been trained and tested competent in potential hazards, how to avoid or correct unsafe conditions and in the written operation, inspection and maintenance procedures. The safety training programs address employee safety as well as protection of the surrounding community and the environment from accidental releases of hazardous materials. More information can be found in the CDA - Volume 1, Part 7.1 and Volume 4, Appendix 8,

Water Quality

Q:  What water quality and quantity issues are associated with the phosphogypsum stack expansion?

A:  Water quality and quantity issues range from the condition of current surface water and groundwater to the measures being employed to protect ground and surface water quality. The major issues regarding water are discussed below.

Water measurements taken before the active gypsum stack was activated provide baseline information about the condition of the waters in the area. This information showed that the surficial and Floridan aquifers contained groundwater unfit for human consumption, and most surface waters were brackish due to the tidal influence of Hillsborough Bay. Comparisons of recent groundwater samples show that there has been no degradation in water quality in either the surficial or Floridan aquifers as a result of the gypsum stack.

In order to protect the groundwater from any leakage from the phosphogypsum system, the entire system is contained within an impenetrable bottom liner. This liner is engineered in accordance with all state and federal regulations. Any rainwater that lands on the grassed slopes of the stack will be sampled and tested before it enters surface waters. When the stack is closed, it will be capped, top-dressed with 12 inches of topsoil, and grassed in order to prevent storm water intrusion and erosion.

According to design criteria, the proposed expansion project will create only one additional surface water outfall. This outfall will be closely monitored and regulated in accordance with state and federal regulations similarly to the existing outfalls. Any additional water quality and quantity issues can be found in Volume 1, Parts 3.3 and 7.2 of the CDA.

Q:  Will there be any change to nitrogen loading in Tampa Bay water near the Cargill Fertilizer plant in Riverview?

A:  Since the side slopes of the gypsum stack will be covered with grass, stormwater runoff is expected to be similar to that of fields of grass so nitrogen "loading" (or additions of nitrogen to the Bay) will be minimal. Based on data collected from the existing stormwater management system, nutrient loads to the Alafia River and Hillsborough Bay are expected to be less than 12 pounds of phosphorous and 10 pounds of nitrogen per day. Process water is not released into surface water bodies and is not a contributor to any nitrogen loading to Tampa Bay.

Q:  Explain the water quality sampling which Cargill Fertilizer is conducting near the Alafia River.

A:  This water quality sampling was undertaken at the request of a local resident. The concerned resident has been contacted, and a sampling well is planned for installation in the fall of 1999. The well will be used to evaluate groundwater quality and elevation. Cargill has contracted with Schreuder, Inc. Water-Resources & Environmental Consultants to evaluate groundwater monitoring information. The information will be used to construct a generalized water-table map of the surficial aquifer system in the study area.

Water Supply

Q:  What is the history of Cargill's use of spring and well water and will the Cargill facility require additional quantities of fresh water for this project or in the future? Does the current permitted quantity represent significant impacts to the river or bay?

A:  The Riverview facility has operated on some portion of spring water for more than 25 years. During the time that deep wells were used, that water was circulated through cooling towers and the spring water was used for the boilers. Deep wells are no longer used, so only spring water is used now. Cargill will be submitting a Water Use Permit application to the Southwest Florida Water Management District in the next few months. This renewal application will be for the same quantity currently permitted for the term of 20 years. It is also expected that Cargill will seek an additional 10-year extension of the permit. The permit application will include all of the facility water balance calculations and any required evaluation of impacts to the river or bay at these permitted pumping rates.

Q:  What are the plans for Cargill to operate its Riverview facility on an alternative water supply in order to reduce the amount of spring water currently used?

A:  Cargill is committed to developing an alternative spring water supply for the Riverview facility and has already evaluated the use of reclaimed water from area waste water treatment facilities in Hillsborough County. Portions of the facility's water requirements could be met by lower quality reclaimed water, and Cargill is working with Hillsborough County to develop a supply system for the facility to receive this alternative supply. Cargill will also evaluate any other potential sources of alternative supplies for the facility. A desalination unit at the facility would be cost prohibitive at this time, and the handling of discard brine could be a major environmental concern. Any use of an alternative water supply will directly reduce spring withdrawals by equivalent quantities.

Q:  Is Tampa Bay Water looking at this area's springs to make up for the water levels at the north springs, and what are the impacts to wetlands from the reduced flow of the Alafia River withdrawal project?

A:  These questions are best answered by Tampa Bay Water as part of their requirements under the Master Water Plan.

Q:  In the settlement agreement with Tampa Bay Water, are there tax dollars required for compliance with the agreement? Where does the money come from for the Cooperative Funding Grant and where are the monitoring stations for the continuous springs monitors?

A:  Tampa Bay Water will provide their funding share from revenues received from the sale of water. If a Cooperative Funding Grant is approved by the Alafia River Basin Board, the funds originate from the Water Management District portion of the Ad Valorem taxes. Continuous spring monitors will be located at the discharge of the spring pool prior to entering the receiving water body, which for Lithia Major and Minor is the Alafia River and for Buckhorn Main is Buckhorn Creek.

Air Quality

Q:  What will Cargill do to assure air quality? Will there be a plan for water, air, noise, and odor with a commitment from Cargill? Please explain what Cargill will do about odor/smell, dust film on car, bland sound/noise, dust, yellow dust, acid rain, radiation, radon, air pollution, and emissions.

A:  Cargill is aware of the odor issue and in response to initial comments in the public process has embarked on an odor abatement project. The abatement project includes a thorough investigation of the source of the odor and possible methods of reducing or eliminating the nuisance odor. A group of volunteers is working with Cargill employees and consultants in an effort to find methods to reduce odors. One method presently being experimented with includes the addition of hydrogen peroxide to re-circulating process water. A more detailed discussion of abatement response is outlined in the Public Involvement Volume 4, Appendix 7 and Volume 1, Part 7.1G of the CDA.

Cargill has also initiated a plan aimed at reducing the noise due to the venting of steam from their sulfuric plants. Two of the plants have modified vent valves installed that are designed to reduce noise while the third sulfuric plant is due for the upgrade in November 1999.

Additionally, plans are currently being developed to improve air quality by investigating dust and air emissions. A dust emission plan will determine if the dust deposits within the community are a result of Cargill's facility and/or the active phosphogypsum storage system. A sampling protocol has been developed which includes the collection of samples during distinct weather conditions. First, when winds blow from the phosphogypsum stack towards the sampling locations, and then when the winds blow in the opposite direction. Cargill has immediately proceeded with the dust emission program and is not waiting to receive its development approvals and permits for the Phosphogypsum Stack Expansion Project.

Cargill is also currently completing a feasibility study aimed at assessing the possible reduction of permitted air emissions.

Further information relating to these air quality issues and how the proposed project will protect air quality can be found in the CDA - Volume 1, Part 7.1 and Part 8.

Q:  What are dispersion models?

A:  Dispersion models, developed by the United States Environmental Protection Agency, provide a way of estimating the concentration of gases and particulate matter (dust)in the air surrounding an emission source based on a number of factors. The factors included in the model are the weather characteristics of the area, the type of gas or particulate (dust) and the source of the emission. These factors are used in the model as worst-case conditions, and provide an overestimate of the level of the gas or particulate at sites around a source. The results in Cargill's case show that for the neighborhoods surrounding the phosphogypsum stack, even using multiple worst-case assumptions, the level of radon, particulate matter (dust), and fluorides would be well below harmful levels. The actual data from the dispersion models are in the CDA - Volume 1, Part 7.1B and C.

Q:  What is the increased risk of additional air pollution/degradation of air quality (odor, dust, etc.) expected with an increase in the size of the stack (over time and distance from the stack)?

A:  As stated in a study performed by Scott McCann of Golder and Associates, the raising of the phosphogypsum stack will have no effect on air pollution quality. The air toxics were modeled using local and nationally accepted standards. The results of these models revealed that the proposed height increase of the phosphogypsum stack would have no affect on dispersion of fluorides, sulfur dioxide and particulate matter emissions from Cargill's Riverview facility. For further explanation of the methodologies used and results found from the models see Volume 1, Part 7.1 of the CDA.

Q:  How will being positioned between two 220-foot stacks affect the speed and direction of the wind in severe weather conditions with coastal flooding?

A:  Air dispersion modeling performed by Golder and Associates found there would be no change in the dispersion characteristics of wind blown sources due to the expanding of the phosphogypsum stack. Models performed with and without stack expansion yielded identical results, meaning the expanded stack would have no effect on dispersion patterns or weather events. For a more in depth discussion of the air modeling see Volume 1, Part 7.1C of the CDA.

Q:  Discuss weather effects/hurricane modeling.

A:  Regarding weather effects, the dispersion modeling used for this project was based in part on weather data from Tampa International Airport during a time when there were no hurricanes in the area. As a result, the dispersion of radioactivity or particulates was not modeled under hurricane conditions. Based on many years of experience, however, it was concluded that the rainfall during a hurricane would suppress radioactivity emissions, and any emissions would be effectively dispersed due to the high winds.

Q:  Does the project cause acid rain - corrosion/paint/finish damage? Has acid in the air gotten worse in the last two years as the stack has gotten higher, and does it affect breathing?

A:  The height of the gypsum stack has no relation to acid rain or acid in the air and has no affect on breathing. In general, there has been no increase in acid mist or acid rain associated with the fertilizer plant operations within the last two years. When fertilizer plants begin operation after being shut down, or during shut down, there can be a momentary increase in emissions. In some cases, car paint damage may occur. The company has addressed this issue through physical modifications and changes in operating procedures at the fertilizer chemical plants. In all cases, the company is not allowed to exceed permitted emission levels established through the Hillsborough County Environmental Protection Commission, the Florida Department of Environmental Protection and the U.S. Environmental Protection Agency.

Dredging

Q:  Please provide an overview of the Alafia River Channel Dredging project

A:  The existing port facility is 34' deep, 200' wide, with a 3.6 mile long channel from the main Tampa Bay Shipping channel and a 700' by 1,200' ship turning basin. Cargill loads 150-180 vessels per year with cargo exceeding 3 million metric tons of finished fertilizer products serving the United States and worldwide ports.

The U.S. Army Corps of Engineers is currently studying and permitting a project to deepen the Alafia River Channel of the federal Tampa harbor project from 32' to 40' and increase the width from 200' to 250'. Cargill proposes to use Panamax vessels, which are 750' long and 105' wide, to use the port, which will require an increase in the turning radius of the basin from 700' to 1150'.

Federal Project History -

  1889 - Five-foot project to the town of Peru, Florida (Riverview today) - approved but never built.

  1929 - U.S. Phosphoric Products begins development and in 1930 a 23' depth channel was completed.

  1940 - Channel from Alafia to Kissimmee to St. John's River studied but not built.

  1945 - Channel deepened to 25' and 150' wide. Turning basin authorized to go to 1025' but was not built.

  1950 - Channel extended to 30' depth and 200' wide with turning basin remaining the same.

  1998 - Channel depth extended to 32' and turning basin remained the same.

Q:  What is the current status of the Alafia River Channel Dredging project?

A:  The U.S. Army Corps of Engineers should complete its final study for the deepening project in June, 2000. The Corps of Engineers studies every aspect of the project including economic, environmental, community, international trade and Tampa Port development. They are looking 50 years into the future. Following the final study report, the project must be approved in the U. S. Congress as part of the federal port improvement projects for the year 2000. The Florida Department of Environmental Protection along with other local environmental agencies will review the project. Following congressional and local approval, construction could begin in the calendar year 2001.

Land Reclamation

Q:  Discuss land deterioration/reclamation.

A:  Land reclamation is not performed at the Riverview facility but is performed at Cargill's mines in Polk and Hardee Counties.

Q:  Explain the restoration project/wetlands project referring specifically to Archie Creek. Will it overflow Riverview Drive? How will it impact saturated groundwater flow to river? What is the stormwater management plan for the rerouted creek?

A:  The Archie Creek restoration project will result in less flooding on Riverview Drive and an improved wetland for nesting birds and other wetland species. It includes the rerouting of the water system further south than the current flow course. The project will include the creation of a larger wetland system than what presently exists. Inclusive in the improved wetland will be enhanced natural water filtration as well as improved flood prevention during storm events and water retention during short-term drought conditions. The complete Archie Creek restoration project is described in Volume 2, Appendix C of the CDA, and wetland impacts are described in Appendix D of the same volume.

Q:  What is mitigation and how does it relate to the phosphogypsum stack extension project?

A:  Mitigation is compensation for environmental impacts to the project site. As an example, Cargill must offset any impacts to existing wetlands in the project area by enhancing existing wetlands or even creating new wetlands near the Archie Creek restoration. Cargill is required by law to perform mitigation as part of their proposed permit. Cargill is committed to the successful completion and monitoring of all mitigation areas.

Q:  Explain exotic vegetation eradication.

A:  Exotic plant species are plants that are not naturally found in the region but were introduced either mistakenly or purposely by humans. There are many invasive plant species in the area of the Riverview facility. Cargill would remove exotic vegetative species and replant native species as part of the phosphogypsum stack buffer management plan. For more information regarding the eradication of exotic plant species please refer to Volume 1, Part 8 of the CDA.

Property Values

Q:  Has property value in the vicinity of the facility gone down in recent years, and is it expected to go down as a result of this project?

A:  Due to the increased demand for residential development in Hillsborough County and the conversion of industrial/commercial property to residential, the property values in the vicinity of the Cargill facility have increased in recent years. The market prices that Cargill has paid for land suitable for residential or commercial has remained very strong. This trend is predicted to continue, as noted by the changes in the Oak Creek development east of 78th Street.

Q:  Has Cargill considered the buyout of Hickory Lane homes or other land purchase opportunities?

A:  Cargill doesn't have any plans to purchase residential properties that are not directly associated with the phosphogypsum stack project or facility operations. Cargill has had a history of acquiring property adjacent to or near its operating facilities for many years and has continued that practice in the areas along Riverview Drive and 78th Street.