FINDING OF NO SIGNIFICANT IMPACT Carbon Capture and Storage System (CCS) Richardton North Dakota Rural Development U.

Carbon Capture and Storage System (CCS) Richardton North Dakota
Rural Development
U.S. Department of Agriculture

Proposed By:
Red Trail Energy, LLC

Prepared By:
Scott Davis, USDA Rural Development

April 2021


Red Trail Energy (RTE) plans to submit a financing request to the U.S. Department of Agriculture, Rural Development (RD) to construct a carbon capture and storage system (CCS) at the existing ethanal plant in Richardton within Stark County North Dakota. RD is considering this financing request. Prior to taking a federal action (i.e., providing financial assistance), RD is required to complete an environmental impact analysis in accordance with the National Environmental Policy Act of 1969 (NEPA) (U.S.C. 4231 et seq.), the Council on Environmental Quality's (CEQ) regulations for implementing NEPA (40 CFR Parts 1500-1508), and RD's NEPA implementing regulations, Environmental Policies and Procedures (7 CFR Part 1970). After completing an independent analysis of an environmental report prepared by RTE and its consultant, RD concurred with its scope and content. In accordance with 7 CFR § 1970.102, RD adopted the report and issued it as the Agency's Environmental Assessment (EA) for the proposed Project. RD finds that the EA is consistent with federal regulations and meets the standards for an adequate assessment. RTE published a newspaper notice, announcing the availability of the EA for public review, in accordance with 7 CFR § 1970.102. In addition, RD considers the proposed Project an undertaking subject to review under Section 106 of the National Historic Preservation Act (NHPA), 16 USC 470(f), and its implementing regulation, "Protection of Historic Properties" (36 CFR Part 800).


The proposed carbon capture system would capture the carbon dioxide prior to emission from the existing corn-based ethanol production process, liquefy it and transport it about a mile in a pipeline. The carbon dioxide would then be injected deep underground, for permanent secure storage. In this case, the carbon dioxide is injected more than 6,000 feet below the surface.
Over the period of 20-years the CCS could store approximately 3.6 million tonnes of carbon dioxide. This would allow for the sale of carbon credits that could be sold to producers, or those emitting the carbon dioxide, in state like California where such regulatory systems exist.

Short Elliott Hendrickson, Inc., an environmental consultant, prepared an environmental assessment (EA) for the project assessing the proposed project's environmental impacts, and summarized as applicable any mitigation measures that would be used to minimize environmental effects. Based on the information in the EA, the proposed project will not impact farmland, floodplains, wetlands, cultural resources, biological resources, water resources, noise, transportation, or pose a risk to human health and safety. With this project, air-quality from the ethanol production process will be improved. USDA-RD has conducted an independent evaluation of the environmental assessment and believes that it accurately assesses the impacts of the proposed project. No significant impacts are expected as a result of the construction of the project.


1.No Action

Under the No Action Alternative, RD would not provide financial assistance to RTE, and/or the proposed Project would not be constructed. This alternative would not allow for the capture of carbon dioxide that is emitted from the ethanal production process.

2.Three different facility design alternatives were considered that would produce different levels of CO2.
•Food and Beverage Quality CO2: Could be sold to food and beverage industry. Would be loaded onto trucks for sale to third parties. Would have highest commercial value but would require the most capital investment. RTE did not select this alternative.
•Injection Quality CO2:High-pressure CO2 would be produced for injection and water would be only impurity removed from the CO2. The resulting product would have the lowest commercial value. RTE did not select this alternative.
•Enhanced Oil Recovery CO2:High pressure liquid CO2 produced for injection, or a medium pressure liquid CO2 product for sale to companies needing CO2 for industrial or enhanced oil recovery operations. Has capital cost higher than that of Injection Quality only, but less than Food and Beverage Quality. This alternative was selected that allows for multiple markets for the CO2 product if injection for CCS becomes unfeasible economically or logistically.

3. Different alternative injection well locations were considered. The injection wells will be drilled approximately 6400 feet below the surface into the Broom Creek Foundation which was identified from 3D seismic surveys, test wells, and other geologic testing as the target formation for CO2 storage. Site characterization of the surface and subsurface environment was assessed in the vicinity of the RTE ethanal facility to develop CO2 storage designs, site potential injection well locations, and to develop a monitoring program. Reasons for alternative well location not being selected include being too close to the Schnell Recreation Area, RTE does not currently own the land, and geotechnical boring and seismic results at some locations were less desirable than the preferred location.


RD finds that the Environmental Assessment, dated January 2021, is consistent with federal regulations and has met the standards for adequate assessment and is thereby adopting the Final EA without revision for use in supporting our NEPA decision. The analyses in the EA documented that the proposed Project would have no adverse effects to important farmland, floodplains, wetlands, water resources, coastal resources, biological resources including endangered species or migratory birds, aesthetics, air quality, or any historic properties. A summary of anticipated impacts on the human environment is provided below, including any mitigation measures deemed necessary to avoid or minimize impacts. Red Trail Energy is responsible for implementing these measures.
•Air and Soil Mitigation Measures Will Include:Water or chemical soil binders to control dust along roads and access points during construction. Minimization of discharge of smoke, dust, or other contaminants to the atmosphere. Post construction maintenance and monitoring of the CCS system to minimize leakage of the system. A Storm Water Pollution Prevention Plan (SWPPP) will be obtained prior to construction activities. Post construction site will be put back in as-is condition and affected areas will be re-seeded.
•Geologic and Mineral Mitigation Measures Will Include:Monitoring of injection pressures, and surface and subsurface conditions to ensure no sudden release of CO2, and to ensure pressures are not high enough to fracture the rock.
•Water Resources Mitigation Measures Will Include:No/minimal disturbance to wetlands, and revegetation of any disturbed areas upon construction completion. Equipment will be kept in good repair to avoid leakage of harmful substance to groundwater and wetlands. A Spill Response Plan will be developed along with a Rapid Response Plan for spill containment. Areas of disturbance will be limited.


A local newspaper advertisement announcing the availability of the EA and participation under Section 106 of the National Historic Preservation Act, was published on 10th and 17th of March, in the Dickinson Press. Hardcopies and electronic copies of the EA were available for public review at RD's office in Bismarck as well as on their website. Copies were also available at RTE's offices. The 20-day comment period ended on 3/29/2021. RD received no comments regarding the proposed project.


Based on its EA, RD has concluded that the proposed Project would have no significant effects to the environmental resources listed above. The proposed project will have no effects on historic properties listed or eligible for listing on the National Register of Historic Places and no effects to federally listed species or designated critical habitat. Further, the proposed project would not disproportionately affect minority or low-income populations.

In accordance with the National Environmental Policy Act, as amended (42 U.S.C. 4321 et seq.), the Council on Environmental Quality Regulations (40 CFR 1500-1508), and RD's Environmental Policies and Procedures (7 CFR Part 1970), RD has determined that the environmental impacts of the proposed Project have been adequately addressed and that no significant impacts to the quality of the human environment would result from construction and operation of the proposed Project. Any final action by RD related to the proposed Project will be subject to, and contingent upon, compliance with all relevant federal and state environmental laws and regulations. Because RD's action will not result in significant impacts to the quality of the human environment, RD will not prepare an Environmental Impact Statement for its potential federal action associated with the proposed Project.


This FONSI is not a decision on a loan application and therefore not an approval of the expenditure of federal funds. Issuance of the FONSI and its notices concludes RD's environmental review process. The ultimate decision on loan approval depends upon conclusion of this environmental review process in addition to financial and engineering reviews. Issuance of the FONSI and publication of notices will allow for these reviews to proceed. The decision to provide financial assistance also is subject to the availability of loan funds for the designated purpose in RD's budget. There are no provisions to appeal this decision (i.e., issuance of a FONSI). Legal challenges to the FONSI may be filed in Federal District Court under the Administrative Procedures Act.


This Finding of No Significant Impact is effective upon signature.

/s/ Denise Sundeen
USDA RD Business Programs Director
Date: 2021.04.01
(April 7, 2021) 2882601