ENVIRONMENTAL ASSESSMENT KORE
Power − KOREPlex Facility, City of
Buckeye, Maricopa County, Arizona
Environmental Assessment and Draft Finding of No
Significant Impact
DOE/EA-2222
June 2023
KOREPlex Facility Environmental Assessment
Contents
Page i
CONTENTS
1.0 Purpose and Need ......................................................................................................... 1
1.1 Purpose and Need for Agency Action .......................................................................... 1
1.2 Background .................................................................................................................. 1
1.3 Scope of Environmental Assessment ........................................................................... 2
2.0 Description of the Proposed Action ............................................................................. 4
2.1 Construction ................................................................................................................. 6
2.1.1 Facilities .................................................................................................................... 6
2.1.2 Stormwater Management ........................................................................................... 8
2.1.3 Utilities ....................................................................................................................... 8
2.1.4 Transportation ........................................................................................................... 9
2.1.5 Schedule ................................................................................................................. 10
2.2 Operations ................................................................................................................. 10
2.2.1 Personnel ................................................................................................................ 10
2.2.2 Traffic and Transportation ........................................................................................ 11
2.2.3 Production ............................................................................................................... 11
2.2.4 Waste Management ................................................................................................. 19
3.0 Environmental Consequences ................................................................................... 20
3.1 Aesthetics and Visual Resources ............................................................................... 20
3.2 Water Resources ....................................................................................................... 21
3.2.1 Surface Water .......................................................................................................... 21
3.2.2 Groundwater ............................................................................................................ 23
3.3 Air Quality .................................................................................................................. 23
3.3.1 Setting ..................................................................................................................... 23
3.3.2 Emissions Analysis .................................................................................................. 23
3.4 Biological Resources.................................................................................................. 27
3.4.1 Vegetation ............................................................................................................... 27
3.4.2 Wildlife ..................................................................................................................... 27
3.5 Cult
ural Resources .................................................................................................... 28
3.5.1 Historic Properties ................................................................................................... 28
3.5.2 Consultation with Native American Tribes ................................................................ 29
3.6 Socioeconomic Resources and Environmental Justice .............................................. 30
3.6.1 Socioeconomics ...................................................................................................... 30
3.6.2 Environmental Justice .............................................................................................. 31
3.7 Human Environment .................................................................................................. 32
3.7.1 Transportation ......................................................................................................... 32
3.7.2 Public and Occupational Safety and Health ............................................................. 33
3.7.3 Waste Management ................................................................................................. 34
3.8 Cumulative Impacts ................................................................................................... 36
3.8.1 Air Quality ................................................................................................................ 37
3.8.2 Greenhouse Gas Emissions .................................................................................... 37
3.8.3 Transportation ......................................................................................................... 38
4.0 Draft Finding ................................................................................................................ 39
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5.0 List of Preparers .......................................................................................................... 40
5.1 U.S. Department of Energy ........................................................................................ 40
5.2 Hilgartwilson, LLC ...................................................................................................... 40
5.3 KORE Power, Inc. ...................................................................................................... 40
6.0 References ................................................................................................................... 41
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LIST OF FIGURES
Figure 1 Regional Overview .............................................................................................. 3
Figure 2 Aerial Photograph ............................................................................................... 5
Figure 3 Proposed Action Site Layout ............................................................................... 7
Figure 4 Mixing ................................................................................................................12
Figure 5 Coating ..............................................................................................................13
Figure 6 Drying ................................................................................................................13
Figure 7 Roll Pressing ......................................................................................................14
Figure 8 Notching/ Slitting ................................................................................................14
Figure 9 Die Cutting .........................................................................................................15
Figure 10 Stacking .............................................................................................................15
Figure 11 Welding ..............................................................................................................16
Figure 12 Electrolyte Filling ................................................................................................16
Figure 13 Formation ..........................................................................................................17
Figure 14 Aging .................................................................................................................18
Figure 15 Degassing and Sealing ......................................................................................18
Figure 16 Grading ..............................................................................................................19
Figure 17 FEMA Flood Zones and National Wetlands Inventory ........................................22
Figure 18 Air Quality ..........................................................................................................24
LIST OF
TABLES
Table 1 Estimated Development Areas by Phase ............................................................ 4
Table 2 Estimated Facility-Wide Emissions ....................................................................26
Table 3 Population and Ethnicity (2020 Census) ............................................................31
Table 4 Selected Variables from EPA’s EJ Screening Tool .............................................32
Table 5 Annual Projected Operational Waste Generation and Management ..................35
Table 6 Estimated GHG Emissions .................................................................................37
LIST OF APPENDICES
Appendix A List of Permits
Appendix B Battery Basics
Appendix C Screening Analysis for Threatened and Endangered Species
Appendix D Consultation with Agencies and Native American Tribes
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ACRONYMS AND ABBREVIATIONS
Acronym
Definition
Act Section 136 of the Energy Independence and Security Act of 2007, as amended
ADEQ Arizona Department of Environmental Quality
ADOT Arizona Department of Transportation
AGFD Arizona Game and Fish Department
APE area of potential effect
APS Arizona Public Service Company
ATVM Program Advanced Technology Vehicle Manufacturing Loan Program
BACT best available control technology
CFR Code of Federal Regulations
City City of Buckeye
CO carbon monoxide
CO
2
carbon dioxide
DOE U.S. Department of Energy
EA environmental assessment
EJ environmental justice
EPA U.S. Environmental Protection Agency
FEMA Federal Emergency Management Agency
FTZ Foreign Trade Zone
GHG greenhouse gas
GWh gigawatt-hours
HAP Hazardous air pollutant
HVAC heating, ventilation, and air-conditioning
IPaC Information for Planning and Consultation
KORE Power KORE Power, Inc.
LFP lithium-iron-phosphate
LPO Loan Programs Office
MC Maricopa County
MCAQD Maricopa County Air Quality Division
NAAQS National Ambient Air Quality Standards
NATA
National Air Toxics Assessment
NEPA National Environmental Policy Act
NMC nickel-manganese-cobalt
NMP n-methyl-pyrrolidone
NO
X
nitrogen oxides
OSHA the Occupational Safety and Health Administration
PM Particulate-matter
PM
10
equal to or smaller than 10 microns in diameter
PM
2.5
less than 2.5 microns in diameter
RCRA Resource Conservation and Recovery Act
SHPO State Historic Preservation Office
SO
2
sulfur dioxide
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Acronym
Definition
SR State Route
U.S.C. United States Code
USFWS U.S. Fish and Wildlife Service
VOC volatile organic compound
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Purpose and Need
Page 1
1.0 PURPOSE AND NEED
1.1 Purpose and Need for Agency Action
The purpose and need for agency action are to comply with the U.S. Department of Energy
(DOE) mandate under Section 136 of the Energy Independence and Security Act of 2007, as
amended (Act) (42 United States Code [U.S.C.] Section 17013), to select projects for financial
assistance that are consistent with the goals of the Act.
KORE Power, Inc. (KORE Power), is a developer of large-scale battery cells, which are
produced primarily to support utility-scale energy storage systems and the e-mobility industry.
KORE Power has applied for a loan pursuant to DOE’s Advanced Technology Vehicle
Manufacturing Loan Program (ATVM Program), which was established to provide loans to
automobile and automobile parts manufacturers for the cost of re-equipping, expanding, or
establishing manufacturing facilities in the U.S. that produce advanced technology vehicles or
qualified components. The primary goal of the ATVM Program is to improve fuel economy for
light-duty vehicles and thereby reduce ozone precursors, greenhouse gas (GHG) emissions,
and particulate matter emissions associated with vehicle emissions.
Construction and operation of the proposed manufacturing facility would help to ensure a
reliable and independent U.S.-based supply of large-scale battery cells. Ultimately, the KORE
Power manufacturing facility would have an estimated annual production capacity of
approximately 12 gigawatt-hours (GWh) and be powered, in part, by an on-site solar
cogeneration plant. KORE Power has applied for financial assistance under the ATVM Program
to support development of the first phase of the proposed manufacturing facility. Phase 1 would
include construction and operation of an approximately 1.15-million-square-foot building that
would house two production lines, with an annual capacity of approximately 6 GWh. The project
would also involve administrative offices, material storage and mechanical systems buildings,
parking and access roads, and stormwater retention facilities.
The batteries produced by KORE Power support zero-emission EVs and will displace vehicles
with internal combustion engines and their associated emissions, such as ozone precursors,
particulate matter, and GHGs that contribute to global warming, as is consistent with the primary
goal of the ATVM Program. Financially supporting KORE Power's proposals would help bring
battery cells and batteries to market and into greater use, while contributing to the expansion of
zero-emission propulsion, thereby reducing overall national emissions of air pollutants and
human-caused GHGs.
1.2 Background
The ATVM Program is administered by DOE’s Loan Programs Office (LPO). LPO originates,
underwrites, and services loans for eligible projects, including those involving automotive or
component manufacturers. Pursuant to 10 Code of Federal Regulations (CFR) 611.2, eligible
projects include re-equipping, expanding, or establishing a manufacturing facility in the U.S. to
produce qualifying advanced technology vehicles or qualifying components; engineering
integration performed in the U.S. for qualifying advanced technology vehicles and qualifying
components; or manufacturing, recycling, processing, reprocessing, remediating, or reusing
materials, components, or subcomponents involving critical minerals, critical minerals
production, or the supply chain for such materials, as set forth in Executive Order 13953,
Executive Order Addressing the Threat to the Domestic Supply Chain from Reliance on Critical
Minerals from Foreign Adversaries, and Executive Order 13817, A Federal Strategy to Ensure
Secure and Reliable Supplies of Critical Minerals, as amended. The primary goal of the ATVM
Program is to improve fuel economy for light-duty vehicles and thereby reduce ozone
KOREPlex Facility Environmental Assessment
Purpose and Need
Page 2
precursors, greenhouse gas (GHG) emissions, and particulate emissions associated with
vehicle fuel combustion. The ATVM Program is designed to stimulate production of the
technology required to meet program objectives.
To fund its project, KORE power applied to the DOE ATVM Program for financial assistance.
LPO determined that the application substantially complete per the rules governing the ATVM
Program in 10 Code of Federal Regulations (CFR) Part 611. KORE Power was subsequently
invited to enter into the LPO’s due diligence process.
1.3 Scope of Environmental Assessment
LPO has prepared this EA to address the planned new construction and operation of Phase 1 of
the proposed manufacturing facility (the KOREPlex) on an approximately 214-acre parcel
(project area) in Buckeye, Maricopa County, Arizona (Figure 1). Future phases of the
KOREPlex facility are outside the scope of analysis for this EA and are not considered in this
evaluation.
Section 2.0 of this EA describes the construction and operation of the KOREPlex manufacturing
facility (the project) that is subject to LPO’s financial assistance, e.g. the proposed action.
Section 3.0 provides details regarding existing conditions occurring within and around the
project area and analyzes the potential environmental consequences (impacts) associated with
construction and operation of the KOREPlex manufacturing facility. Based on LPO’s review of
the scope of the project (i.e., construction and tooling of the new facility in Buckeye, Arizona),
the existing site conditions, and permit status, the scope of the issues analyzed in this EA
includes:
Aesthetics and visual resources
Water resources, including surface water and groundwater
Air quality, including GHG emissions and climate change
Biological resources, including vegetation, wildlife, and special-status species
Cultural resources
Socioeconomics and environmental justice and
Human environment, including transportation, public health and safety, and waste
management.
These resource areas were identified as potentially being affected by the project and each was
assessed to determine the nature, extent, and significance of those impacts (see Section 3,
Environmental Consequences). The assessment combined desktop research and analysis of
existing available information with select field studies, including site assessments related to
cultural resources, biological resources, and the identification of potential jurisdictional waters of
the U.S.
Because the site for the proposed KOREPlex facility is
in a rural area, on previously disturbed
land (former agricultural production) away from sensitive noise receptors, and within an area
zoned for industrial use, impacts on soil, geology, land use, recreational resources, as well as
noise sensitive receptors are not anticipated. Additionally, the U.S. Army Corps of Engineers
has concurred that waters of the U.S., including wetlands, do not occur in the project area
(USACE 2022). As such, all of the aforementioned resources areas are not included in the
scope of this EA.
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Purpose and Need
Page 3
Figure 1 Regional Overview
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Description of the Proposed Action
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2.0 DESCRIPTION OF THE PROPOSED ACTION
KORE Power is seeking to develop a manufacturing facility for the production of battery cells to
support energy storage systems and e-mobility industries. As depicted in Figure 2, KORE
Power proposes to construct the manufacturing facility on an approximately 214-acre parcel of
land located south of the Union Pacific Railroad between Baseline Road and the Buckeye Canal
and between State Route (SR) 85 to the west and Rooks Road to the east. The project area lies
within the north half of Section 1 of Township 1 South, Range 4 West, of the Gila and Salt River
Meridian.
The proposed KOREPlex facility will be located on private land approximately 1.5 miles west of
the Buckeye city center and historic downtown. The landscape setting in the vicinity of the
KOREPlex facility is predominantly rural, consisting primarily of agricultural land. However,
residential master-planned communities exist northeast and southeast of the project area.
Commercial and industrial uses exist or are under construction immediately west of SR 85,
south of the project area along Maricopa County (MC) 85 and to the north along Baseline Road.
The current land use designation is Employment, per the Imagine Buckeye 2040 General Plan,
Future Land Use Map (Matrix Design Group, 2018, as amended 2022). The current zoning
designation is General Commerce, per the Buckeye Zoning Districts Map (City of Buckeye,
2022). The project area is also within Buckeye’s Downtown Incentive District, which establishes
certain reduced fees to encourage redevelopment and growth in the City’s center.
During construction, the entire 214-acre site will be subject to mass grading and related
activities, including, but not limited to, grading for construction offices and laydown areas. The
entire project site has been previously disturbed by agricultural activities and includes fields,
access roads, and irrigation facilities.
Table 1. Estimated Development Areas by Phase
Primary Component
Estimated Development Area (acres)
Phase 1
Phase 2
Total
Buildings and tanks 26 24 50
Access roads and parking areas 30 20 50
Electrical substation 6 -- 6
Road, utility, and trail easements 25 -- 25
Drainage & retention 50 -- 50
Total
137
44
181
Landscape area* 12 10 22
*
The City of Buckeye requires 10 percent of the site to be subject to landscaping/site enhancement. This will overlap
and include portions of the area designated for drainage and retention; therefore, it is not included in the site totals.
The timing of for landscaping is subject to change.
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Figure 2 Aerial Photograph
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2.1 Construction
2.1.1 Facilities
The proposed DOE loan will support development of the first phase of the project, which will
include construction and operation of an approximately 1.15-million-square-foot manufacturing
facility that will house two production lines with an annual capacity of approximately 6 GWh. The
facility will also include administrative offices, material storage areas, buildings for mechanical
systems, an electrical substation, employee parking and access roads, and stormwater
retention facilities. Figure 3 Proposed Action Site Layout shows the preliminary site plan for
the project.
1
The manufacturing facility will comprise three primary sections, each of which will be
approximately 600 feet by 400 feet. Including the connected raw materials warehouse and
finished goods warehouse, the overall footprint of the main building will cover more than
900,000 square feet (roughly 2,250 feet long [east–west] by 400 feet wide [north–south]. The
manufacturing facility will have a single story, with varying ceiling clearances, depending on
equipment. The maximum building height will be approximately 75 feet. The building foundation
will be constructed with cast-in-place reinforced-concrete drilled piers/caissons. The roof system
will be fabricated with steel trusses supported by steel columns. The interior building floor will be
concrete, with epoxy coating (or similar) in some areas. Metal decking/equipment platforms will
be erected in some areas to accommodate some of the process units and/or heating,
ventilation, and air-conditioning (HVAC) systems. The manufacturing facility will include space
for battery production as the process progresses from the raw materials receiving area (with
truck bays) at the east end of the building to the finished goods area at the west end of the
building, at which point the batteries will be shipped by tractor-trailer rigs (see Section 2.2.3).
Accessory rooms and facilities will generally be constructed along the center spine of the
building (e.g., restrooms, employee break rooms, employee offices, conference rooms, quality
assurance laboratories, control rooms).
Other facilities will be staged in supporting structures south of the manufacturing facility; the
placement of these facilities, including tanks for chemical storage, will generally correspond to
the requirements of a particular process step. It is anticipated that four 30,000-gallon tanks and
one 5,000-gallon tank will be needed for electrolyte storage. Additional chemical storage will be
required for n-methyl-pyrrolidone (NMP) and carbon nanotubes. The chemical storage areas will
be constructed with cast-in-place reinforced-concrete for containment purposes; these areas will
slope to a sump pump in one corner to facilitate waste removal, if needed. Containment areas
will provide chemical-resistant water stops and have an epoxy coating to decrease absorption.
A pre-engineered metal building will be constructed to store defective and at-risk cells at the
west end of the area south of the manufacturing facility.
HVAC systems will include a combination of equipment, such as dehumidification units, rooftop
units, air rotation units, air handling units, and exhaust fans, for climate control and process
service. Preliminarily, the primary climate control system is anticipated to include an estimated
38 dehumidification units and 62 rooftop units.
1
The site layout depicted in Figure 3 is a preliminary site plan and subject to refinement and change.
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Description of the Proposed Action
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Figure 3 Proposed Action Site Layout
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The project will include an administration building at the west end of the manufacturing facility;
the administration building will be a two-story structure, consisting of approximately
30,000 square feet on each level. Visitor parking and an entrance will be provided farther to the
west. Facilities east of the manufacturing facility will include a chiller yard and compressed air
plant, a nitrogen plant, and an area for a substation that will be operated and maintained by the
Arizona Public Service Company (APS) (see Section 2.1.3). One guard house and gated entry
will be provided for Foreign Trade Zone (FTZ) ingress and egress along the north access road;
the guard house will comprise prefabricated modular assemblies.
2.1.2 Stormwater Management
The stormwater retention areas to be constructed will be capable of managing the volume of
runoff generated in the project area as a result of a 100-year, 2-hour return storm event.
Stormwater runoff from the northern portion of the site and building will be directed to an
approximately 10-acre retention basin at the northwest corner of the project area. Stormwater
runoff from the southern portion of the building and remainder of the project area will be directed
to an approximately 30-acre retention area along the southern edge of the project area.
Stormwater will be managed using a combination of overland flow and open channels to direct
runoff to surface inlets; runoff will flow into an underground storm collection system or directly to
retention areas. The basins will retain stormwater and discharge through evaporation and
drywells.
The project area will also have a regional stormwater conveyance channel along the eastern
edge of the property. It is not anticipated that on-site stormwater runoff will intermingle with off-
site stormwater conveyed in the regional channel. The size and configuration of the regional
channel have not been determined.
2
2.1.3 Utilities
Wet Utilities
Potable water will be provided by the City of Buckeye (City). This water will be used for drinking;
it will also be used in restrooms and a closed-loop chiller water. The City’s water will also feed
into a reverse-osmosis
and de-ionization treatment unit, providing ultrapure process water for
the facility.
A new water main will be constructed along the Rooks Road alignment. The new main will
connect to existing water lines in Baseline Road and MC 85. Water demand at the facility is
anticipated to total approximately 500 acre-feet per year, which is roughly half the amount of
water that had been used annually for irrigation associated with agricultural use.
3
KORE Power
plans to provide up to two locations for groundwater wells to the City in the project area.
4
Fire protection services will be provided by the City of Buckeye; water for fire-flow demand will
be provided from the City’s water distribution system. This will be supplemented by a fire-
2
If the channel is constructed as an underground culvert, the corresponding easement will be roughly 20 to 30 feet
wide. Alternately, if the channel is constructed as an earthen ditch, the width will be roughly 150 to 170 feet. Other
configurations, such as those involving drainage tiles or shotcrete, may be considered; these will alter the footprint of
the drainage easement.
3
The project area is under Irrigation Grandfather Right No. 58-103039.001, with an annual allotment of 985.73 acre-
feet of water (Arizona Department of Water Resources, 2023).
4
Groundwater wells will be constructed, operated, and maintained by the City of Buckeye; the wells are not a part of
the scope of this analysis. Groundwater from wells in the project area will be conveyed through water transmission
mains to an existing water campus; following potential treatment and chlorination, potable water will be conveyed
(indirectly) to the KORE Power facility through the City’s water distribution system.
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protection pumphouse and storage tank that will be constructed on-site. The storage tank will be
sized in accordance with the requirements of the Fire Marshal, providing an available fire flow of
4,000 gallons per minute for 4 hours, or 960,000 gallons, and booster pumping capacity.
Domestic wastewater will be conveyed generally to the southeast corner of the site and
discharged from a connection to the City’s existing wastewater collection system in Rooks
Road. A small on-site lift station may be required to facilitate this connection. Currently, process
wastewater is anticipated to be collected from sumps located throughout the plant and pumped
to a wastewater treatment area south of the Phase 1 manufacturing facility. The primary
sources of process wastewater are anticipated to be water from cleaning the mixing areas and,
infrequently, tray washing.
The volume of process wastewater is estimated to be approximately 20,000 gallons per month.
Process wastewater is anticipated to be pretreated on-site and then discharged to the City’s
existing wastewater collection system. Routine sampling and monitoring will ensure compliance
with local limits established by the City of Buckeye’s industrial pretreatment program (City of
Buckeye, 2021). Alternately, process wastewater will be collected, stored in holding tanks with
secondary containment, and hauled by tanker truck to an off-site facility for treatment.
Dry Utilities
APS will be the electric utility provider. An electrical substation will be constructed on
approximately 6 to 8 acres of the site to facilitate three-phase, 69-kilovolt service to the site.
Natural gas service will be provided by Southwest Gas; it is assumed that the connection will
enter the site from the northeast and run east along the northern utility right of way.
It is anticipated that communication facilities will include fiber optic/internet. Robust internal
control systems will be designed and integrated into the facility.
2.1.4 Transportation
Access for construction on the site will be via northbound SR 85; a second point of
ingress/egress will be provided via Rooks Road northbound to Baseline Road at the northeast
corner of the site.
In anticipation of operations, KORE Power is working with the City of Buckeye and the Arizona
Department of Transportation (ADOT) to develop appropriate access routes and traffic solutions
for facility operations. As part of the project, the following improvements to transportation
infrastructure are anticipated, based on the latest draft of the traffic impact analysis (Southwest
Traffic Engineering, 2023).
Improvements to SR 85 will consist of the addition of a right-turn acceleration/ deceleration
lane along the frontage of the KOREPlex facility, in accordance with ADOT guidelines. This
driveway will be the primary route for employee and visitor ingress and egress to the site
(“west access”).
The primary truck access route to the facility will be via MC 85 and Rooks Road.
− For Phase 1, truck access to the KOREPlex facility will be via Rooks Road near the
northeast corner of the site (“north access”).
− Ultimately, a second point of connection to the KOREPlex facility will be added to Rooks
Road (“south access”).
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− The southbound and northbound turn lanes to Rooks Road from the north and south
access roads on the KOREPlex facility will provide adequate storage to facilitate traffic
movements.
KORE Power will dedicate 70 feet along the eastern frontage of the project area, providing a
right of way for half-street improvements along Rooks Road plus an 8-foot-wide public utility
easement. The half-street improvements are anticipated to include three travel lanes, along
with a curb, gutter, and sidewalk.
The City of Buckeye will extend improvements to the Rooks Road alignment south of the
KOREPlex facility; this will include adding a bridge over the Buckeye Canal.
Stop signs will regulate traffic from Rooks Road to MC 85 and from Rooks Road to Baseline
Road. These intersections will be monitored as the KOREPlex facility and other developments
progress. Traffic signals will be installed when warranted.
It is anticipated that dual right-turn lanes will be constructed at the intersection of Southern
Avenue and northbound SR 85, either as part of the second phase of the KOREPlex facility
or if warranted by other development in the area.
2.1.5 Schedule
Construction of the KORE Power facility will include site preparation and the installation of
temporary facilities, security fencing, access roads, parking lots, and construction laydown
areas.
Clearing and grubbing will be followed by mass grading of the site. Building construction will
start with forming and pouring the concrete foundations. Wet and dry utilities will be brought to
the project site. Building and process structure erection will be initiated shortly thereafter. The
installation of mechanical systems and process equipment, as well as electrical and
instrumentation infrastructure, will be the final construction step, leading to commissioning and
the start of operations.
Phase 1 construction was initiated during the fourth quarter of 2022; construction completion is
anticipated in fourth quarter of 2024.
5
Up to 1,000 new jobs are anticipated during construction.
KORE Power will be responsible for compliance with federal, state, and local laws and
regulations, including, but not limited to, the Clean Air Act, Clean Water Act, National Historic
Preservation Act, and Endangered Species Act. The City of Buckeye will issue building permits
in accordance with City and Maricopa County codes and ordinances. The general contractor will
be responsible for compliance with permits for construction, including, but not limited to, a dust
control permit from the Maricopa County Air Quality Division (MCAQD) and stormwater pollution
prevention permits issued by the Arizona Department of Environmental Quality (ADEQ). A list of
the permits that have been completed or are in process is included in Appendix A, List of
Permits.
2.2 Operations
2.2.1 Personnel
The KOREPlex facility is anticipated to require approximately 1,500 employees for operation of
Phase 1 buildout. Preliminarily, the facility will operate on two 12-hour shifts per day, 7 days per
5
DOE issued a memorandum entitled Allowable Interim Actions under NEPA Review – KORE Power (Loan #A1017)
on November 28, 2022, which contemplated the initiation of construction activities prior to completion of the NEPA
review process.
KOREPlex Facility Environmental Assessment
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week, with personnel rotating 36-hour and 48-hour work weeks. Buildout of Phase 2 will support
an estimated 3,000 employees on the same rotating schedule.
2.2.2 Traffic and Transportation
Phase 1 of the project is anticipated to generate approximately 100 truck trips per day plus
employee trips. Raw material deliveries will enter the site via the Rooks Road entrance on the
east side of the facility. After passing through a guard station, deliveries will be directed to the
truck bays at the east end of the manufacturing facility. Chemical deliveries and supplies will be
transferred to fixed tanks located within the secondary containment area along the delivery
route on the south side of the building. Shipping of the outgoing product will occur at the truck
bays on the west end of the manufacturing facility.
The primary truck access route to and from the site will be the north access driveway from
Rooks Road to MC 85 and then to SR 85 at the existing signalized intersection. The west
access driveway, with right-in/right-out traffic movements to SR 85, will be the primary route for
employee and visitor access. When SR 85 ultimately transitions to a limited access freeway, it is
anticipated that access along the western edge of the site will connect to a frontage road.
2.2.3 Production
Generally, battery cells comprise three primary components: electrodes (anodes and cathodes),
electrolytes, and separators. Battery cells can be packaged into different form factors (or
shapes) and then sold individually as battery cells or assembled into modules, battery packs, or
larger configurations (refer to Appendix B, Battery Basics).
By using various materials and chemicals for the primary components, batteries can be tailored
for different applications. KORE Power proposes to manufacture lithium-ion battery cells, using
nickel-manganese-cobalt (NMC) in pouch form and/or lithium-iron-phosphate (LFP) chemical
configurations in prismatic forms. The NMC and LFP batteries may be assembled into modules
and packs and integrated into e-mobility products and/or used for utility-scale energy storage.
Although the aforementioned chemistries and form factors are anticipated, research into battery
systems continues; the KORE Power facility may adjust or change its production lines to match
innovative technologies and developments in the future.
The battery production process is highly automated and precise. Many of the individual steps,
as well as much of the production line, include internal or external recycle functions that
eliminate and/or substantially reduce waste streams. Control equipment will be installed where
appropriate to maintain air quality standards.
6
Production will also include quality assurance and
quality control measures to meet performance requirements and ensure product stability and
safety. The process steps generally include:
Production of the electrode
Assembly of the battery cell
Battery formation
Module assembly
The production sequence and major equipment required for the battery cell manufacturing
process are outlined herein.
6
See the additional discussion of air quality control measures in Section 3.2.2
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Electrode Production
Mixing
Raw materials, such as conductive additives, solvents, and binders, are mixed in a dry form and
then combined with liquids to form the cathode slurry, anode slurry, and ceramic slurry (Figure
4).
Figure 4 Mixing
Unifor
m distribution of the components, along with monitoring parameters such as viscosity,
density, and solid content, is directly related to the quality of the battery. The process will be
fully enclosed to avoid gas inclusions and control dust and moisture. Particulate-matter (PM)
emissions generated from the mixing process will be abated with the use of dust collectors.
Coating
As depicted in Figure 5, slurries generated from the mixing step will be evenly spread onto the
current collectors (typically copper and aluminum foils) and dried (Figure 6). NMP solvent will be
used as part of this process; solvent vapors will be abated with use of an exhaust gas recovery
device. Following coating and drying, the collectors will be wound into coils before proceeding to
the roll pressing operation.
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Figure 5 Coating
Figure 6 Drying
Roll Pressing
The coated copper or aluminum foil will be compressed by a pair of rollers (Figure 7). The
electrode foil will be statically discharged and cleaned by brushes or air flow. The material will
be compacted by the top and bottom rollers.
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Figure 7 Roll Pressing
Notching/ Slitting
Typically, rolls are fed to a slitting station in which a wide electrode coil (mother roll) is divided
into several smaller electrode coils (daughter rolls). The individual daughter rolls are then
cleaned and rewound. Figure 8 depicts the general notching and slitting process for both pouch
and prismatic-/cylinder-form batteries.
Figure 8 Notching/ Slitting
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Cell Assembly
Die Cutting and Stac
king
The separated electrode sheets will be fixed with adhesive tape or glue and shear cut with a
punching tool (Figure 9) before being stacked in a repeating cycle of anode, separator, cathode,
separator, etc. (Figure 10). PM emissions generated from the cutting process will be abated by
the dust collector.
Figure 9 Die Cutting
Figure 10 Stacking
Welding, Packing, and Sealing (Pouch)
The current collectors (anodes and cathodes) will be connected to cell tabs using an ultrasonic
or laser welding process (Figure 11). The cell stack will then be positioned in a pouch and
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sealed on three sides (typically). One side of the cell will be left open to add electrolyte. PM
emissions from welding will be abated by the dust collector.
Figure 11 Welding
Baking
Cells will be placed in a large oven and dried at high temperature and under vacuum to control
moisture and oxygen.
Electrolyte Filling
As depicted in Figure 12, the electrolyte will enter the cell, which is under vacuum, with help
from a high-precision dosing needle. The liquid electrolyte consists of organic carbonates that
generate volatile organic compound (VOC) emissions. VOC emissions will be abated by carbon
beds.
Figure 12 Electrolyte Filling
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The cell will al
so get activated (wetted) by applying pressure and relying on the capillary effect.
Finally, the pouch foil will be sealed under vacuum.
Formation
Formation
The cells will be activated for the first time by charging and (possibly) discharging during the
formation step (Figure 13). Defined currents and voltages will then applied to embed lithium ions
in the anode and establish an interface layer between the electrolyte and the electrode (the solid
electrolyte interface).
Figure 13 Formation
Aging
The aging process will be used for quality assurance; cell characteristics and performance will
be monitored and measured (Figure 14).
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Figure 14 Aging
Degassing and Sealing
Off gases can be produced during the first charging of a cell; the gases will be collected in a
vacuum chamber for removal and treatment. Following degassing, the cell will be sealed under
vacuum, and the gas bag will be separated and properly disposed of. As needed, final folding
and gluing will be conducted to reduce the dimensions of the pouch cell. These steps are
depicted in Figure 15.
Figure 15 Degassing and Sealing
Grading
Grading is used to determine cell quality by analyzing data such as capacity, internal resistance,
and voltage drop over time (Figure 16). Testing of the cells may include pulse tests, internal
resistance measurements, visual inspections, voltage tests, and leakage tests.
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Figure 16 Grading
Module
Assembly
Sorting
After testing, cells will be grouped according to their performance data. Cells that do not meet
performance specifications will be sent to recycling.
Module Assembly and Pac
king
Once the tests have been completed and passed, the cells will be packed and shipped or
integrated into battery energy storage systems.
2.2.4 Waste Management
Lithium-ion battery production is inherently a closed system that produces little to zero waste
material. Waste materials within the system are recycled back into the process to maintain
efficiencies. Defective cells (with or without electrolyte) are identified at several steps in the
process; these make up the majority of the solid waste generated by the production process.
Generally, the defective cells will be recycled. Other solid wastes generated by the production
process include electrode sheet and/or separator scrap, cutoff or defective pieces, and
aluminum-plastic film cutoff from the welding and packing step. Solid waste that cannot be
recycled will be disposed of at an appropriate facility.
During operations, isolation tanks/cases for the management and control of defective cells will
be staged throughout the production line, with smaller cases located more frequently and sized
to handle individual cells. Larger isolation tanks will be established for the different steps in
production. The isolation tanks/cases will eliminate potential risks from defective cells and be
appropriate to the corresponding stage of production.
The KOREPlex facility will generate both solid and liquid hazardous and non-hazardous waste
from manufacturing processes. Solid non-hazardous waste is generally associated with routine
building operations and maintenance. The storage, transport, recycling, and disposal of waste
material will be in accordance with applicable federal, state, and local environmental
regulations. Section 3.7.3 provides additional information related to waste generation and
management.
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3.0 ENVIRONMENTAL CONSEQUENCES
In each of the following sections, a specific resource area is addressed with both qualitative
and, where applicable, quantitative information to concisely describe the nature and
characteristics of the resource that may be affected by the project, as well as the potential
impacts (direct and indirect) on that resource from the project given proposed controls. A
conclusion regarding the significance of impacts is provided for each resource area.
Section 3.8, Cumulative Impacts, provides a review of the present and reasonably foreseeable
federal and nonfederal actions that may contribute to a cumulative impact when added to the
impacts of the project. The impacts of past actions were reviewed and are included as part of
the affected environment to establish the current condition of the resource (i.e., the baseline
condition) that may be affected by the project.
3.1 Aesthetics and Visual Resources
The project area is situated in the Buckeye Valley. The White Tank Mountains lie approximately
10 miles to the north (north of Interstate 10). The Gila River is roughly 3 miles to the south.
South of the river, the terrain rises slightly in the Buckeye Hills. The historic center of the City of
Buckeye is about 1.5 miles to the east.
Historically, the predominant land use in the City of Buckeye was agricultural production, which
was interspersed with industrial uses and residential development. Agricultural fields continue to
convert to industrial and residential uses. Existing and planned warehousing and manufacturing
uses tend to align along major transportation corridors. The northbound lanes of SR 85 border
the project area on the west, the Union Pacific Railroad forms the northern boundary, and the
Buckeye Canal lies adjacent to the south. Rooks Road forms the eastern boundary of the
project area.
South of the Buckeye Canal, a gas station, tire shops, truck and transport facilities, equipment
yards, and other enterprises front MC 85. A strip of similar, as well as agricultural, uses lie north
of the railroad and south of Baseline Road. Fertizona, a concrete batch plant, and the new
(under construction) APS Western Service Center lie west of the southbound lane of SR 85. A
residential property lies east of Rooks Road on the north side of the Buckeye Canal (at the
southeast corner of the project area) (Figures 1-3).
After construction, the site would contain manufacturing facilities and buildings, an electrical
substation, a water storage facility, retention ponds, and paved parking lots. A setback of 400
feet would separate facilities from adjacent roadways and other land. Exterior building materials
would include steel, glass, and concrete panels that would be designed to offer aesthetically
pleasing breaks in color and material across the face of each building. Landscaping would
consist of a variety of native, low-water-use, and desert-adapted plants. Trees would be
strategically placed to offer shade along walkways and cool parking lots, and understory
planting would be used to soften and connect the project to the ground plane. Plantings along
adjacent perimeter streets and at the entrance would be used to enhance the aesthetic appeal.
Because the area is zoned for industrial use, existing and planned manufacturing and other
industrial facilities are adjacent to the project area, and landscaping would be incorporated,
impacts on aesthetics and visual resources as a result of the project would not be significant.
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3.2 Water Resources
3.2.1 Surface Water
The project area lies within the historic floodplain of the Gila River. The hydrology within the
study area has been altered by development, transportation structures, agriculture, and
irrigation features. The Buckeye Flood Retarding Structure system, constructed by the Flood
Control District of Maricopa County in 1975, parallels Interstate 10 and intercepts and diverts
stormwater runoff from the White Tank Mountains to the north. The Roosevelt Canal, located
approximately 2.3 miles north of the project area, prevents stormwater flows from south of
Interstate 10 from reaching the project area. The Union Pacific Railroad is located along the
northern boundary of the project area; the Buckeye Canal traverses the southern boundary. The
project area is composed entirely of agricultural fields; return flows are captured in a constructed
basin at the southwest corner. The project area receives negligible stormwater flows from
upgradient areas and does not contribute flows to downgradient areas. The drainage channel to
be constructed along the west side of the Rooks Road alignment is part of a recommended
regional solution for stormwater management (Dibble, 2009).
Floodplains
The project site is currently comprised of undeveloped agricultural land that generally slopes to
the south at a fall of approximately 0.7 percent. Under existing conditions, stormwater run-on
from off-site areas that may affect the project area are limited. Stormwater run-on tends to pond
along the north side of the Union Pacific Railroad, which parallels the northern boundary of the
site.
As depicted in Figure 17, the southern portion of the project area (along the Buckeye Canal) is
on a Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map, Panels
0413C2580L and 0413C2115L (FEMA, 2013). The majority of the property is within Special
Flood Hazard Area “Zone X” (i.e., an area with a 0.2 percent annual chance of a flood hazard or
an area with a 1 percent annual chance of a flood with average depth of less than 1 foot or with
drainage areas of less than 1 square mile). The portion of the project area lying adjacent to the
Buckeye Canal is delineated as Special Flood Hazard Area “Zone AH” (i.e., an area with a 1
percent annual chance of shallow flooding, usually in the form of a pond, with an average depth
ranging from 1 to 3 feet). The base flood elevation for this portion of the project area is 881 feet.
Stormwater management for the KORE Power facility includes collection facilities (underground
piping and open channels) to convey stormwater runoff away from structures to retention areas.
Drywells would be constructed within the retention areas to facilitate the infiltration of ponded
water. The retention areas would also account for the volume of stormwater retained in the
project area prior to development, as mapped in FEMA Special Flood Hazard Area Zone AH. A
Conditional Letter of Map Revision would be submitted to revise floodplain mapping accordingly.
Construction activities would be conducted under an Arizona Pollutant Discharge Elimination
System Construction General Permit and a notice of intent would be filed with the ADEQ. As a
result of these detailed best management practices, a Stormwater Pollution Prevention Plan and
various on-site erosion and sediment controls, impacts to surface water resources, including
floodplains, would not be significant.
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Figure 17 FEMA Flood Zones and National Wetlands Inventory
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3.2.2 Groundwater
The average depth to groundwater in the project area is approximately 35 to 50 feet below the
ground surface (ADWR, 2022). Although KORE may provide locations for groundwater wells for
the City of Buckeye, construction and development of the well sites would be conducted by the
City. Therefore, the wells are outside the scope of analysis for this EA.
Excavation activities for the KORE Power facilities would not reach the depth of groundwater;
thus, the project would have no direct or indirect impact on groundwater. The manufacturing
process is not water-intensive; water to the facility would be provided by the City of Buckeye.
The KOREPlex facility would not have a direct impact on groundwater sustainability.
Furthermore, the conversion of the project area from agricultural use to manufacturing would
reduce the groundwater demand from the project area. Impacts to groundwater resources would
not be significant.
3.3 Air Quality
3.3.1 Setting
Air quality is determined by the ambient concentrations of pollutants that are known to have
detrimental effects on public health and the environment. In accordance with Section 109 of the
Clean Air Act, the U.S. Environmental Protection Agency (EPA) has promulgated National
Ambient Air Quality Standards (NAAQS) for six criteria pollutants: carbon monoxide (CO), PM,
lead, sulfur dioxide (SO
2
), ozone, and nitrogen oxides (NO
X
) (40 CFR 50). Standards for PM
exist for two categories of particles: those equal to or smaller than 10 microns in diameter
(PM
10
) and those equal to or less than 2.5 microns in diameter (PM
2.5
). Areas that do not meet
the air quality standards are designated as “non-attainment areas.” A designation of non-
attainment submits an area to regulatory control of pollutant emissions so that attainment of the
NAAQS can be achieved within a designated time period.
The EPA regulates emissions of air pollution from mobile and stationary sources under the
authority of the Clean Air Act. The MCAQD has jurisdiction over stationary air pollution sources
in the county and administers the permitting program pursuant to Part 70 of the Clean Air Act.
Operating permits issued by MCAQD are legally enforceable documents. They are designed to
improve compliance with the Clean Air Act by specifying control measures for facilities with the
potential to emit pollutants.
The project area is within Maricopa County, which is currently designated as an attainment area
with respect to the NAAQS, except for the 8-hour ozone and PM
10
standards (EPA, 2022a).
Specifically, the project area is in attainment for the NAAQS, except for the 8-hour ozone
standard. The non-attainment area for PM
10
is adjacent to the project area and to the east
(Figure 18).
3.3.2 Emissions Analysis
Air emissions would result from construction and operation of the proposed KOREPlex facility.
Generally, impacts on air quality from construction activities are considered short-term impacts,
lasting only for the duration of construction. Operational impacts are considered long-term
impacts, occurring while the facility is in use. Required permits, air quality standards, and the
consequences of the project on air quality are discussed below.
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Figure 18 Air Quality
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Construction
Air emissions resulting from development of the proposed facility would include fugitive dust
(PM
10
and PM
2.5
) associated with construction activities (e.g., earthmoving) and emissions from
vehicles and equipment (e.g., CO, SO
2
, NO
x
, precursors to ozone) may result in temporary
impacts to the Project site. To reduce emissions of pollutants, during construction, appropriate
construction best management practices would be implemented, and vehicles and equipment
would be properly maintained. Contractors would be required to comply with the best
management practices specified in the Dust Control Permit; additional measures to minimize
soil erosion and sedimentation are mandated under the Arizona Pollutant Discharge Elimination
System Notice of Intent/Construction General Permit, which would also minimize dust
generation. Because of the relatively short duration of air emissions associated with
construction, and the best management practices that would be employed, impacts on air
quality during construction would not be significant.
Operation
In accordance with the MCAQD Part 70 permit program, industrial operations that have the
potential to emit 5.5 pounds per day or 1 ton per year of any regulated air pollutant are required
to obtain an air quality permit to operate the facility. The type of permit issued by MCAQD
requires a detailed review of facility systems, projected emissions, and the current ambient air
quality. New manufacturing facilities must demonstrate use
and implementation of best
available control technology (BACT) to reduce emissions, as practicable.
Permits
set emission limitations and define monitoring, recording, and reporting requirements
and are valid for 5 years. Although an owner may revise and/or transfer an air quality permit,
continued operation of the facility
must be in accordance with the active permit.
Because the proposed facility would be a new stationary source with the
potential to emit
regulated pollutants, an application for a permit to operate is being prepared for submittal to the
MCAOD. Expected emissions from the KOREPlex manufacting process include:
PM emissions from the mixing stage
VOC emissions during the coating and drying stage
Hazardous air pollutant (HAP) emissions from chemical usage in die cutting
PM emissions during laser cutting (permit exempt)
VOC emissions during electrolyte filling
NO
X
, CO, VOC, PM
10
, PM
2.5
, SO
2
, and HAP emissions from natural gas combustion in HVAC
units
7
VOC emissions from storage tanks
KORE Power would use an exhaust gas recovery device with an estimated 95 percent control
efficiency to abate NMP emissions during cathode application, thereby meeting the BACT
requirement. Carbon beds with an estimated 95 percent control efficiency would abate VOC
emissions during the electrolyte filling process and from storage tanks, also in accordance with
BACT requirement. Dust collectors and carbon beds would comply with MCAQD regulations to
control visible emissions, fugitive dust and PM, and VOC emissions.
7
The KOREPlex facility is evaluating the efficiency of two approaches to climate control (i.e., air-conditioning and
heating): a combination of dehumidification and rooftop units or air handling units. In either case, natural gas
combustion would power the climate control systems. For the purposes of this analysis, 38 dehumidification units and
62 rooftop units are assumed to be necessary for cooling or heating the facility. If elected, the air handling units would
be anticipated to have lower emissions.
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Based on information from the air permit application, Table 2 summarizes anticipated emissions
from continuous operation of the facility with BACT measures implemented. The anticipated
maximum emissions of all pollutants would be below the MCAQD permit threshold for a Major
Facility (Class I). As such, a Class II permit issued by the MCAQD would be applicable for long-
term operation of the facility. Compliance with permit conditions would prevent pollutant levels
from exceeding the NAAQS within non-attainment areas.
Table 2. Estimated Facility-Wide Emissions
Source
Pollutant
Controlled
Emissions
(pounds/year)
Controlled
Emissions
(tons/year)
Major Facility
Threshold
(tons/year)
Natural gas combustion NO
X
21,000 11 100
Natural gas combustion CO 5,800 2.9 100
Natural gas combustion, cathode
application, Line 1 electrolyte filling, Line
2 electrolyte filling, storage tanks
VOCs 25,000 13 100
Natural gas combustion, anode mixing
(Line 1 & 2), cathode mixing (Line 1 & 2)
PM 1,200 0.60 100
Natural gas combustion, anode mixing,
cathode mixing (Line 1 and 2)
PM
10
1,200 0.60 70
Natural gas combustion SO
2
100 5.0 x 10
-2
100
Natural gas combustion Benzene 1.3 6.6 x 10
-4
10
Natural gas combustion Formaldehyde 2.8 1.4 x 10
-3
10
Natural gas combustion Total PAHs (exc.
naphthalene)
0.02 8.2 x 10
-6
10
Natural gas combustion Naphthalene 0.05 2.5 x 10
-5
10
Natural gas combustion Acetaldehyde 0.71 3.5 x 10
-4
10
Natural gas combustion Acrolein 0.44 2.2 x 10
-4
10
Natural gas combustion Ammonia 530 0.27 10
Natural gas combustion Ethylbenzene 1.6 7.8 x 10
-4
10
Natural gas combustion Hexane 1.0 5.2 x 10
-4
10
Natural gas combustion
Toluene
6.0
3.0 x 10
-3
10
Natural gas combustion Xylene 4.5 2.2 x 10
-3
10
Cathode mixing Cobalt
compounds
0.53 2.6 x 10
-4
10
Cathode mixing Nickel
compounds
0.53 2.6 x 10
-4
10
Cathode mixing Manganese
compounds
0.53 2.6 x 10
-4
10
Die cutting
*
Acetonitrile 18,000 9 10
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Source
Pollutant
Controlled
Emissions
(pounds/year)
Controlled
Emissions
(tons/year)
Major Facility
Threshold
(tons/year)
Natural gas combustion, cathode mixing,
die cutting
Total HAPs 19,000 9.5 25
ERM, 2022. The estimated emissions assume continuous operation of the KOREPlex facility (8,760 hours/year).
*An alternate die-cutting process, using tape in lieu of acetonitrile, is under evaluation, which would eliminate this
potential emission.
PAH = polycyclic aromatic hydrocarbon
Through implementation of BACT measures and compliance with the MCAQD Class II Minor Air
Quality Permit, the impact on air quality within the analysis area would not be significant.
3.4 Biological Resources
This section describes biological resources that may be affected by implementation of the
project, including vegetation, wildlife, and special-status species.
3.4.1 Vegetation
The project area lies within the Lower Colorado River subdivision of the Sonoran desert scrub
biotic community, as defined by Brown (1994). The project area comprises fallowed fields, most
recently planted in alfalfa (Medicago sativa), and structures used for irrigation and agricultural
operations, (e.g., canals, roadways). Negligible native vegetation is present. A retention pond in
the southwest corner holds return agricultural flows; however, wetland plants are not present.
3.4.2 Wildlife
The project area provides habitat for many species of wildlife. Mammals known to exist within
the vicinity include coyote (Canis latrans), desert cottontail (Sylvilagus audubonii), black-tailed
jackrabbit (Lepus californicus), and round-tailed ground squirrel (Spermophilus tereticaudus).
Lizard species in the vicinity include tiger whiptail (Aspidoscelis tigris), side-blotched lizard (Uta
stansburiana), and Gila monster (Heloderma suspectum). Snakes in the area include western
diamondback rattlesnake (Crotalus atrox) and gophersnake (Pituophis catenifer). Several bird
species are known to occur in the project area, including western burrowing owl (Athene
cunicularia). Detailed information regarding these special-status species can be found in the
Migratory Birds section, below.
Agricultural lands, as well as the retention pond for agricultural return flows, serve as foraging
habitat for wildlife in the project area. Construction would remove land used as foraging habitat
for wildlife, including bird species; however, these individuals would most likely relocate to
adjacent fields and retention ponds. Direct mortality of a few mammals and reptiles may occur
during construction, although the grading and soil disturbance that would occur would be similar
to normal agricultural practices. Construction could temporarily disturb wildlife species that use
habitat adjacent to the project area; however, this disturbance is not expected to be substantial
because loud ground-disturbing activities are common in agricultural lands. Wildlife generally
leave an area upon initial construction. Therefore, the impacts on vegetation, wildlife, and wildlife
populations would not be significant.
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Special-Status Species
Threatened and Endangered Species
Threatened and endangered species and their critical habitat that have the potential to occur in
the project area were evaluated (Appendix C, Screening Analysis for Threatened and
Endangered Species). The evaluation concluded there would be no effect on threatened or
endangered species or their critical habitat from implementation of the project.
Migratory Birds
Migratory birds are protected under the Migratory Bird Treaty Act. Migratory birds observed in
the project area include western burrowing owl, Gambel’s quail (Callipepla gambelii), killdeer
(Charadrius vociferus), red-winged blackbird (Agelaius phoeniceus), yellow-headed blackbird
(Xanthocephalus xanthocephalus), great-tailed grackle (Quiscalus mexicanus), great blue heron
(Ardea herodias), great egret (Ardea alba), mallard (Anas platyrhynchos), and black phoebe
(Sayornis nigricans). The majority of the birds were using the retention pond in the southwest
corner of the project area. Western burrowing owls located on the banks of the irrigation ditches
used irrigation pipes in the agricultural fields for cover prior to site grading. Because of grading,
the project area is not considered suitable breeding habitat for birds. Killdeer and western
burrowing owls are the exception; both of these species nest in or on the ground in disturbed
areas.
Site-specific surveys were conducted for western burrowing owl prior to ground-disturbing
activities. A federally permitted biologist conducted the surveys in conformance with the protocol
outlined in the Arizona Game and Fish Department (AGFD) Burrowing Owl Project Clearance
Guidance for Landowners. Several pairs of burrowing owls, as well as active burrows, were
identified on or adjacent to the site during the survey. A Migratory Bird Special Purpose Permit
was obtained through the U.S. Fish and Wildlife Service (USFWS) for relocation of the owls and
destruction of the nests. Owls were trapped, and active and potential burrows were collapsed
on-site and along the berms of the irrigation canal immediately adjacent to the site, according to
USFWS guidelines.
Fliers regarding western burrowing owl were provided to construction contractors and posted at
the project site for continued management. If an owl cannot be flushed and is in the path of
construction, work should stop until the owl flushes or until a permitted biologist arrives to
evaluate and resolve the situation. A biological monitor would be provided during initial
construction and for future stages of the project if new burrowing owl activity is detected.
With implementation of preconstruction efforts by permitted biologists to remove and relocate
western burrowing owl from the subject site, impacts would be considered negligible and short
term. It is not anticipated that western burrowing owl would occupy active developed portions of
the project area. Should owls repopulate berms on existing canals or retention basins, KORE
Power operations would not be anticipated to affect these individuals. Based on these
considerations, impacts on migratory birds from the project would not be significant.
3.5 Cultural Resources
3.5.1 Historic Properties
A qualified archaeological consultant conducted a Class I site file search and literature review
covering a 1-mile radius around the area of potential effect (APE) and a Class III cultural
resources inventory of the project site (Paleowest, 2022). The archaeological APE consists of a
213.8-acre parcel of farmland, which is situated entirely on private land. The architectural APE
(i.e., site file search radius) consists of the 213.8-acre project footprint as well as a 1-mile buffer
surrounding the area to address potential indirect effects. The survey of the APE identified one
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site, one isolated occurrence, and two in-use historic structures. The identified site includes
historic building foundations and a well that was associated with historic agricultural/farming
practices in the area. The isolated occurrence is a capped well of unknown age. One in-use
historic structure is made up of lateral segments of an irrigation canal, along with roads
associated with farming in the region. The other in-use historic structure is a segment of the 69-
kilovolt transmission line from Buckeye to Gillespie that parallels the eastern edge of the project
area. None of these sites are considered eligible for listing on the National Register of Historic
Places or Arizona Register of Historic Places, and no avoidance measures are recommended
for ground-disturbing activities.
No historic architectural structures, historic areas, or archaeological sites are present within the
project area. On June 9, 2022, a consultation letter was sent to the Arizona State Historic
Preservation Office (SHPO) for Section 106 consultation, requesting concurrence with the
archaeological and architectural APEs, as well as the DOE review and finding of no historic
properties affected. On October 31, 2022, SHPO concurred with the recommendations in the
Class III survey that no archaeological resources in the APE are eligible for listing in the NRHP.
Should unexpected archaeological resources be discovered during construction, activities would
be halted in the immediate area of the discovery until the resources have been evaluated for
NRHP eligibility criteria (36 CFR 60.4) in consultation with the SHPO, Arizona State Museum,
DOE, and/or interested tribal consulting parties, as appropriate, and in accordance with 36 CFR
800.13. Appropriate mitigation would be determined during this consultation.
Due to the absence of eligible architectural and archaeological resources within the APE, the
controls that are in place in the event of an unanticipated discovery, and the SHPO’s
concurrence on the archaeological and architectural findings, impacts on cultural resources as a
result the project would not be significant.
3.5.2 Consultation with Native American Tribes
In conjunction with this EA and the National Historic Preservation Act Section 106 historic and
archeological review process, DOE sent a June 2022 NEPA notice regarding the KORE Power
project to Native American tribes in an effort to identify tribal interest in the project site and
provide an opportunity to make comments or express concerns. The following federally
recognized tribes and councils were contacted (see Appendix D, Consultation with Agencies
and Native American Tribes):
Ak-Chin
Colorado River Indian Tribes
Fort McDowell Yavapai Nation
Fort Mojave Indian Tribe
Gila River Indian Community
Hopi Tribe
Mescalero Apache Tribe
Pascua Yaqui Tribe
Pueblo of Zuni
Salt River Pima-Maricopa Indian Community
San Carlos Apache Tribe
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Tohono O'odham Nation
White Mountain Apache Tribe
Yavapai Apache Nation
Yavapai Prescott Indian Tribe
Following submission of the notice, each tribe was contacted by telephone to ensure receipt and
respond to any immediate questions or concerns. No immediate concerns were relayed by the
tribes. Next, the DOE contacted the aforementioned tribes upon completion of the cultural
resources survey for the project site. The Pascua Yaqui Tribe, Tohono O'odham Nation, Gila
River Indian Community, and White Mountain Apache Nation requested a copy of the cultural
resources survey for review. All of the aforementioned tribes that reviewed the survey concurred
with the DOE finding of no adverse effect on Native American interests within or surrounding the
project site.
Because of the absence of cultural resources or Native American interests within or surrounding
the project site, impacts on Native American interests resulting from the project would not be
significant.
3.6 Socioeconomic Resources and Environmental Justice
3.6.1 Socioeconomics
The project is in a primarily agricultural area of Buckeye, Arizona, but with light industry and
residential communities either constructed or under construction to the east. The nearest
emergency center, Abrazo Buckeye Emergency Center, at 525 South Watson Road, is
approximately 9.5 miles to the northeast, and the nearest school, Bales Elementary School, at
25400 West Maricopa Road, is approximately 2.1 driving miles to the northeast (0.9 air mile).
The nearest airport is Buckeye Municipal Airport, located 7 miles northwest of the project site
and the project site is approximately 36 miles from the city of Phoenix, a major metropolitan
area.
The City of Buckeye has a population of approximately 100,000, with a population density of
approximately 230 people per square mile (U.S. Census Bureau, 2020a). The civilian labor
force is approximately 51 percent of the total population in the City of Buckeye; the civilian labor
force in all of Arizona is approaching 57 percent. Roughly 73 percent of the labor force is
employed by private companies, and 14 percent are local, state, or federal government
employees. Construction work represents roughly 10 percent of the jobs. Manufacturing,
warehouse, and transportation work represent roughly 16 percent of the jobs (U.S. Census
Bureau, 2021a). Per the 2021 American Community Survey, the median annual household
income in the City of Buckeye is $75,417; median annual household income is $69,056 for all of
Arizona. The median annual household income by family type in the City of Buckeye is $86,985
for families, $93,882 for married couples, and $53,943 for non-family households (U.S. Census
Bureau, 2021b).
The KORE Power facility would have beneficial socioeconomic impacts on the area, from
increased employment opportunities, increased tax revenue, and direct and indirect spending in
the local economy. Notably, the facility would change land use from agricultural to
manufacturing. The change in land use would increase property taxes on the land, generate
sales tax, and result in more jobs than under current conditions.
Construction of the facility is anticipated to take roughly 2 years from the initial site survey,
grading, and layout through final certificate of operation. The design and construction phases
are anticipated to employ approximately 1,000 workers. Currently, the construction industry is
roughly 10 percent of the civilian employed population in Buckeye. Given the current working
population of roughly 50,000 people in Buckeye, there are 5,000 construction jobs in the area.
KOREPlex Facility Environmental Assessment
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The additional 1,000 construction jobs needed to build the facility would represent a 20 percent
increase in construction jobs in Buckeye over the next 2 years. This would have a positive,
temporary effect on the local economy. The impact of the project on local infrastructure and
services such as housing, schools, and healthcare would not be significant due to the availability
of local infrastructure and services within the City of Buckeye and in the nearby city of Phoenix.
The first phase of the KOREPlex facility is anticipated to begin operations in the fourth quarter of
2024. Phase 1 is anticipated to require approximately 1,500 workers to operate at full capacity.
Manufacturing, warehousing, and transportation currently represent about 16 percent of the jobs
in Buckeye (roughly 8,000 jobs). The addition of another 1,500 manufacturing, warehouse, and
transportation jobs would be a 19 percent increase in this job category compared with current
conditions. This would have a positive long-term effect on the local economy.
3.6.2 Environmental Justice
LPO’s review of environmental justice (EJ) issues is guided by Executive Order 12898, Federal
Actions to Address Environmental Justice in Minority Populations and Low-Income Populations,
the National Air Toxics Assessment (NATA) cancer risk and respiratory hazard index, as defined
in EPA’s EJ screening tool. Executive Order 12898 directs federal agencies to address
environmental and human health conditions in minority and low-income communities. The
evaluation of EJ is dependent on determining if high and adverse impacts from a project would
disproportionately affect minority or low-income populations in the affected community.
In accordance with EPA’s EJ guidelines, minority populations should be identified when either 1)
the minority population of the affected area exceeds 50 percent or 2) the minority population
percentage of the affected area is meaningfully greater than the minority population percentage in
the general population or other appropriate unit of geographic analysis.
The total 2020 population of Arizona was 7,151,502; 1.3 percent of the population, 91,502 people,
lived in Buckeye. The project area is located within Census Tract 506.17, which has a population
of 5,312. People living in poverty make up 12.8 percent of the population in Arizona, 9.1 percent
in Buckeye, and an estimated 14.3 percent in Census Tract 506.17. Table 3 summarizes the
ethnic and racial composition of the City of Buckeye, Maricopa County, and the state of Arizona
(U.S. Census Bureau, 2020a, 2020b, 2020c, and 2020d).
Table 3. Population and Ethnicity (2020 Census)
City of Buckeye Maricopa County Arizona
Total population
91,502
4,420,568
7,151,502
Race and Ethnicity
White, not Hispanic or Latino 45.1% 53.4% 53.2%
Hispanic or Latino 43.5% 32.0% 32.3%
Two or more races 8.5% 3.3% 3.1%
Black or African American 6.6% 6.7% 5.4%
Asian 2.1% 4.8% 3.8%
American Indian and Alaska Native 1.4% 2.9% 5.3%
Native Hawaiian and Pacific Islander 0.2% 0.3% 0.3%
Poverty 9.1% 11.6% 12.8%
Sources: U.S. Census Bureau, 2020a, 2020c, 2020d.
Minority populations in the City of Buckeye make up approximately 54.9 percent of the
population. The relative percentage of the minority populations is not meaningfully different from
that of the larger reference area of Maricopa County. The number of people living in poverty is
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higher in the census tract (14.3 percent) than it is in Buckeye (9.1 percent), Maricopa County
(11.6 percent), or the state of Arizona (12.8 percent). The low-income population for Buckeye is
estimated to be 25 percent, compared to 33 percent for the state of Arizona (EPA, 2022b).
Because no adverse environmental impacts are anticipated under the project, no
disproportionately high or adverse human health or environmental effects would affect minority
or low-income populations in the project area. The facility would be anticipated to have a
positive impact on poverty and low-income rates in the project area due to the added potential
opportunity for employment.
Executive Order 13045, Protection of Children from Environmental Health Risks and Safety
Risks, requires an analysis of EJ to determine whether a project would place an undue burden
on children. Because construction and operation of the project would not occur near any
schools, day-care facilities, playgrounds, or other places frequented by children, and because of
the remote location and high security for the project, trespassing children are not expected on
the site. Therefore, children would not be disproportionately affected by environmental health
and safety risks.
Table 4 lists selected variable from EPA’s EJ screening tool. The NATA cancer risk and
respiratory hazard indices are a way to see how local residents compare to everyone else in the
state as well as the entire U.S. With respect to the NATA cancer risk, the project area is in a
census tract that is in the 80
th
to 90
th
percentile in the U.S.; however, the value of the census
tract is slightly lower than the state average and slightly greater than the 50
th
percentile in the
state. The respiratory hazard index for the evaluated census tract is below the 50
th
percentile for
the state and the U.S.
Table 4. Selected Variables from EPA’s EJ Screening Tool
Census
Tract
Value
State
Average
Percentile
in State
U.S.
Average
Percentile
in U.S.
NATA* cancer risk (lifetime risk per million) 30 32 56
th
28 80-90
th
NATA* respiratory hazard index 0.3 0.37 42
nd
0.36 <50
th
People of color 60% 46% 72
nd
40% 73
rd
Low-income population
30%
33%
51
st
30%
54
th
Source: EPA, 2022b.
*More information on the NATA can be found at https://www.epa.gov/national-air-toxics-assessment.
Permitted emission levels of criteria pollutants and HAPs are considered to be protective of
human health and the environment. Also, the air quality permit from MCAQD would mandate the
installation and use of BACT during operations to minimize emissions and potential air quality
impacts (refer to Section 3.2.2). The project would comply with applicable federal, state, and
local air regulations and would not be expected to affect the NATA cancer risk and respiratory
hazard indicators; therefore, impacts from the project would not be significant.
3.7 Human Environment
3.7.1 Transportation
The existing regional roadway network includes Interstate 10, which is approximately 3.5 miles
north of the project area. Interstate 10 runs east–west through central Buckeye, connecting the
Phoenix metropolitan area to Southern California. SR 85 is adjacent to the project area on the
west, running north–south through Buckeye and connecting Interstate 10 and Interstate 8.
Interstate 8 begins in San Diego, California, runs through Gila Bend, Arizona, and connects to
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Interstate 10 in Casa Grande, Arizona. SR 85 acts as a bypass to Interstate 10, allowing freight-
related traffic to avoid the Phoenix metropolitan area. SR 85 is ultimately planned to be a part of
the Interstate 11 corridor (ADOT, 2021a).
Currently, SR 85 is a limited-access state highway, except for two existing signalized
intersections in Buckeye at MC 85 and Baseline Road. Per the City of Buckeye’s transportation
master plan, MC 85 and Baseline Road are planned as six-lane arterial roadways (Matrix
Design Group, 2019). Rooks Road, running north–south along the eastern edge of the project
area, is also planned as an arterial roadway. The Union Pacific Railroad parallels the northern
boundary of the project area; rail service is not planned as part of the KORE Power project.
The project is in a rapidly growing area of Buckeye. In coordination with the City, adjacent
roadways would be widened and improved as the area develops. According to the traffic impact
analysis, existing transportation networks would experience increases in traffic and delay both
with and without the KOREPlex facility. However, levels of service along key Buckeye arterial
roadways and associated intersections would improve as development widens and improves
the roadways. Interim measures such as widened intersections and traffic signals along SR 85
are anticipated to provide temporary relief for increasing traffic and movements associated with
the KOREPlex facility and other proximate development (Southwest Traffic Engineering, 2023).
Under existing conditions, the intersection of MC 85/SR 85 is signalized. The intersections at
Baseline Road/SR 85 and Southern Avenue/SR 85 are controlled by stop signs for east–west
traffic movements. With ongoing growth and development in the area, widened intersections
and traffic signals would be anticipated at Baseline Road/SR 85 and Southern Avenue/SR 85.
These measures would provide temporary relief for traffic congestion, but a regional solution,
driven by ADOT, Maricopa County, the Maricopa Association of Governments, and the City of
Buckeye, would be required to fund and construct the ultimate SR 85 limited-access highway.
Due to the implementation of the proposed traffic and roadway improvements being coordinated
with the City; impacts to transportation networks in and around the project site would not be
significant.
3.7.2 Public and Occupational Safety and Health
Congress passed the Occupational Safety and Health Act of 1970 to ensure worker and
workplace safety. The act also created the Occupational Safety and Health Administration
(OSHA) to set and enforce standards; provide training, outreach, and education; establish
partnerships; and encourage improvement in workplace safety and health (29 CFR Part 1910).
The Arizona Division of Occupational Safety and Health operates under an approved plan with
the U.S. Department of Labor to retain jurisdiction over occupational safety and health issues in
Arizona, excluding mining operations, Indian reservations, and federal employees.
The KOREPlex facility would be designed, constructed, and operated to ensure employee and
community health and safety, in accordance with OSHA standards. The facility would
implement corporate health and safety policies and procedures, including employee training,
emergency drills, proper personal protective equipment, engineering controls, monitoring, and
internal assessments. Additional policies and procedures would be implemented as needed as
new potential risks are identified. These measures would help to ensure compliance with
applicable health and safety regulations and minimize health and safety risks to employees and
the public.
Points of ingress and egress would be positioned such that employees would have ready
access to safe exits from the building. The emergency action plan would incorporate employee
training, including a minimum of 4 hours of site- and job-specific training during orientation.
Emergency drills would be conducted regularly, with information regarding safety stations and
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Environmental Consequences
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muster locations. Work areas and emergency exits would be well maintained and free of
obstructions.
With respect to chemical storage and handling, loading/unloading areas would be designed and
built with appropriate secondary containment, leak sensors, and engineering controls as
appropriate. Protocols would include proper practices for controlling potential emissions,
employee exposures, and/or releases to the environment. Safety data sheets for chemicals
would be maintained on-site, and appropriate practices and protocols would be implemented.
KORE Power would prepare appropriate emergency planning and response plans and file
required documents in accordance with the Community Right-to-Know Act.
The plant management system would allow integrated monitoring and system control from the
operating center. Each step in the manufacturing process would be monitored to ensure proper
product spacing and ventilation, and appropriate protocols would be implemented to ensure
safe production practices.
Because of measures such as best management practices and compliance with federal, state,
and local regulations and standards, impacts on the health and safety of workers, as well as the
public, from project construction and operation would not be significant.
3.7.3 Waste Management
The Resource Conservation and Recovery Act (RCRA) of 1976 charged the EPA with
controlling the generation, transport, treatment, storage, and disposal of hazardous waste.
RCRA also promulgated a framework for the management of non-hazardous solid wastes. The
1986 amendments to RCRA enabled the EPA to address environmental problems that could
result from underground storage tanks where petroleum and other hazardous substances are
stored.
Solid waste generated during the construction phase would be managed and transported in
accordance with applicable federal, state, and local regulations. During operations, the
KOREPlex facility would use hazardous and non-hazardous materials in controlled
environments. The use of these materials and the generation of waste materials during
operations would be conducted in accordance with applicable regulations, including regulations
regarding transport, storage, and disposal.
Table 5 provides an estimate of annual hazardous and non-hazardous waste generation at the
KOREPlex facility. The table also lists the anticipated methods for collection, transport, and
disposal. The majority of the waste material would be collected and sent for recycling (see
Section 2.2.4). Solid and hazardous waste that cannot be recycled would be disposed of at
appropriate disposal facilities in accordance with applicable state and federal laws.
With planned waste management practices, including recycling, and solid and liquid waste
disposal controls, impacts from waste management activities would not be significant.
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Table 5. Annual Projected Operational Waste Generation and Management
Waste Stream Type
Annual
Generation
(pounds)
*
Collection Transportation
Anticipated
Disposal Method
General
Oils and greases Non-hazardous 3,000 Drums By truck Recycling
Lab chemicals Hazardous 3,000 Drums
characterized
for disposal
Drums by truck Recycling
Off-spec NMP Non-hazardous 30,000 Aboveground
storage tank
By tanker truck Recovery/refining
Bag filter media Non-hazardous 35,000 Drums
characterized
for disposal
Drums by truck Recycling
NMC
Defective
positive tab
Non-hazardous 9,000 Gaylord
boxes
By truck Recycling
Defective
negative tab
Non-hazardous 8,000 Gaylord
boxes
By truck Recycling
Cathode offcut Non-hazardous 59,000 Gaylord
boxes
By truck Recycling
Anode offcut Non-hazardous 95,000 Gaylord
boxes
By truck Recycling
Cathode
electrode
Non-hazardous 385,000 Gaylord
boxes
By truck Recycling
Anode electrode Non-hazardous 329,000 Gaylord
boxes
By truck Recycling
Copper foil Non-hazardous 37,000 Gaylord
boxes
By truck Recycling
Aluminum foil Non-hazardous 91,000 Gaylord
boxes
By truck Recycling
Aluminum-plastic
film
Non-hazardous 436,000 Gaylord
boxes
By truck Recycling
Scrap battery
cells
Hazardous 1,095,000 Trays/Drums By truck Recycling
LFP
Defective
positive tab
Non-hazardous 9,000 Gaylord
boxes
By truck Recycling
Defective
negative tab
Non-hazardous 8,000 Gaylord
boxes
By truck Recycling
Cathode offcut Non-hazardous 59,000 Gaylord
boxes
By truck Recycling
Anode offcut Non-hazardous 95,000 Gaylord
boxes
By truck Recycling
Cathode
electrode
Non-hazardous 385,000 Gaylord
boxes
By truck Recycling
Anode electrode Non-hazardous 329,000 Gaylord
boxes
By truck Recycling
Copper foil Non-hazardous 37,000 Gaylord
boxes
By truck Recycling
KOREPlex Facility Environmental Assessment
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Waste Stream
Type
Annual
Generation
(pounds)
*
Collection
Transportation
Anticipated
Disposal Method
Aluminum foil Non-hazardous 91,000 Gaylord
boxes
By truck Recycling
Hard shell Non-hazardous 500,000 Gaylord
boxes
By truck Recycling
Scrap battery
cells
Hazardous 1,471,000 Trays/drums By truck Recycling
*
Preliminary estimate of waste generation; estimates are subject to change.
3.8 Cumulative Impacts
This section discusses cumulative effects, which are effects on the environment that result from
the incremental effects of a project when added to the effects of other past, present, and
reasonably foreseeable future projects, regardless of what agency (federal or non-federal) or
person undertakes such other projects (40 CFR Part 1508.1[g]). Projects were identified through
a review of active project lists and planning documents from the City of Buckeye, ADOT, the
Maricopa County Department of Transportation, and the Maricopa County Planning Office.
ADOT is widening Interstate 10 between Verrado Way and SR 85; the intersection of SR 85
and Interstate 10 is currently under construction. Reconstruction of the Watson Road
interchange will follow. Anticipated completion is summer 2023 (ADOT, 2021b).
ADOT and the Federal Highway Administration are completing an environmental impact
statement for the proposed Interstate 11 corridor from Nogales, Mexico, to Wickenburg,
Arizona. SR 85 through Buckeye comprises a portion of the preferred alignment for the
proposed interstate freeway (ADOT, 2021a).
Construction of a new Maricopa County vehicle maintenance building, fuel island, and vehicle
wash bay canopy is proposed south of the Buckeye Canal (south of the project area).
Construction would be initiated in summer 2023 (Maricopa County, 2022).
An approximately 80-acre industrial center is proposed at the southeast corner of Southern
Avenue and Apache Road, roughly 1.5 miles east of the project area; the City is reviewing
preliminary plans for this facility.
A 1.7-million-square-foot distribution center for Ross Dress for Less is under construction
roughly 2 miles east of the project area.
Multiple new distribution centers and a Fry’s grocery store are planned for construction on
Miller Road just south of Interstate 10, northeast of the project area.
Teravalis, a 37,000-acre mixed-use master planned community with an estimated 100,000
homes is undergoing planning and entitlement at the northwest corner of the Buckeye
Municipal Planning Area (more than 20 miles northwest of the project area).
Numerous other residential, commercial, and industrial development projects are in various
stages of permitting, design, and land acquisition in the City.
The geographic area was reviewed to consider area trends and other projects that, in
combination with the project, have the potential to result in incremental adverse effects. The
analysis area is defined as the reasonable area where cumulative impacts could be measured
as result of the project. The analysis area is not necessarily the same across all resources.
KOREPlex Facility Environmental Assessment
Environmental Consequences
Page 37
LPO reviewed the identified projects in the region to determine the resources that may be
subject to a cumulative impact. The review focused on resources that may be affected by the
project and other projects in the region. Based on that review, the following resources were
evaluated for cumulative impacts:
Air quality
Greenhouse gas emissions
Transportation
3.8.1 Air Quality
Construction activities would occur at the KOREPlex facility and at other project sites in the
vicini
ty. Construction impacts would be temporary and minimized through compliance with dust
control permit requirements and implementation of best management practices mandated by
Maricopa County.
Emissions associated with operation of the KOREPlex facility in combination with emissions
from other projects would have the potential to result in cumulative impacts on regional air
quality. As discussed in Section 3.2.2, the county is in attainment with respect to the NAAQS,
except for the 8-hour ozone and PM
10
standards. The State Implementation Plan identifies
measures to achieve compliance with the NAAQS. In addition, new sources of emissions,
including those from the identified projects in the region, would be subject to air quality
permitting requirements, which are under the jurisdiction of the MCAQD and EPA. These air
quality permitting requirements would ensure compliance with the NAAQS. Therefore,
cumulative impacts on air quality associated with the operation of the project and the other
projects in the region would not be significant.
3.8.2 Greenhouse Gas Emissions
Current study of Earth’s climate shows that human activity has been the primary cause of
observed global warming since the mid-twentieth century (Intergovernmental Panel on Climate
Change, 2023). Since the beginning of the industrial era, human activity has increased the
concentration of GHG in the atmosphere. The rising global temperatures have been
accompanied by changes in weather and climate (e.g., changes in rainfall that result in more
floods, droughts, or intense rain; rising sea levels; polar sea ice decline; and more frequent and
intense heat waves). The increase in atmospheric GHG concentrations is affecting the Earth’s
climate. Table 6 estimates GHG emissions from the KORE Power facility during operations;
emissions from construction activities would be short term and would not be signficant.
Table 6. Estimated GHG Emissions
Equipment
Description
Equipment
Type
Fuel
Type
Equipment
Rating
(MMBtu/
hour)
Greenhouse Gas Emissions
CO
2
(pounds/
year)
Methane
(pounds/
year)
N
2
O
(pounds/
year)
CO
2
eq.
(metric
tons/
year)
Natural gas
combustion
(HVAC units)
*
Other
combustion
equipment
Natural
gas
19.3 2.0 x 10
7
370 37 9.0 x 10
3
Source: EPA, 2009.
*
Refer to footnote 7 in Section 3.3.2 for assumptions on the number and size of HVAC units.
CO
2
= carbon dioxide; CO
2
eq. = carbon dioxide equivalent; MMBtu = 1 million British thermal units; N
2
0 = nitrous
oxide
KOREPlex Facility Environmental Assessment
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The magnitude of potential reductions in the number of gallons of petroleum consumed annually
would depend on the number of electric vehicles with manufactured battery cells. With buildout
of Phase 1 of the KOREPlex facility, the project would produce enough batteries to supply up to
60,000 vehicles annually, assuming a 100-kilowatt-hour battery pack is used in each vehicle.
The petroleum usage that would be displaced is calculated to be approximately 25 million
gallons per year (based on annual mileage of 12,000 miles and an average fuel economy of 29
miles per gallon for light-duty vehicles). Therefore, the use of battery cells produced by the
project and used in electric vehicles would reduce carbon dioxide (CO
2
) emissions by
approximately 243,000 tons of per year. The potential benefits associated with reducing CO
2
emissions would lead to a reduction in GHG concentrations and associated climate change
impacts (e.g., increases in atmospheric temperature, changes in precipitation, increases in the
frequency and intensity of extreme weather events, rising sea levels) such that a signficant
adverse impact on climate change would not occur.
3.8.3 Transportation
The project, in conjunction with the identified development in the region, would lead to an
incremental increase in overall traffic; however, ongoing regional planning, including planned
and ongoing improvements to local and regional streets, would be consistent with City of
Buckeye and ADOT transportation plans and guidelines. Therefore, no significant adverse
cumulative effects on the regional transportation network are anticipated.
KOREPlex Facility Environmental Assessment
Draft Finding
Page 39
4.0 DRAFT FINDING
Based on
this EA, DOE has determined that providing a federal loan guarantee to KORE Power
to construct a battery manufacturing facility in Buckeye Arizona, will not have a significant effect
on the human environment. The preparation of an EIS is therefore not required, and the DOE is
issuing this Finding of No Significant Impact (FONSI).
____________________________
Dat
e
_______________________________
Todd Stribley
NEPA Compliance Officer
DOE Loan Programs Office
KOREPlex Facility Environmental Assessment
List of Preparers
Page 40
5.0 LIST OF PREPARERS
The following individuals participated in preparation of this EA:
5.1 U.S. Department of Energy
Alicia Williamson, DOE − LPO Environmental Protection Specialist
Todd Stribley, DOE – LPO NEPA Compliance Officer
5.2 Hilgartwilson, LLC
Sheila A. Logan, PE, Manager – Environmental Services
Jill Hankins, Senior Project Manager
Rafael de Grenade, PhD, Senior Biologist
5.3 KORE Power, Inc.
Randy Cowder, Senior Vice President of Manufacturing
Bill Mervine, Director of Plant Engineering
John Gregory, Senior Process Engineer
KOREPlex Facility Environmental Assessment
References
Page 41
6.0 REFERENCES
Arizona Department of Transportation. 2021a. Interstate 11 Corridor Tier 1 Environmental
Impact Statement, Nogales to Wickenburg. Retrieved from Overview. Available:
http://origin.i11study.com/Arizona/.
Arizona Department of Transportation. 2021b. Central District Projects. Retrieved from
Interstate 10: SR 85 to Verrado Way Improvements. Available:
https://azdot.gov/projects/central-district-projects/i-10-sr85-verrado-way-improvements.
Arizona Department of Water Resources. 2022. ADWR GIS. Retrieved from Wells 55 Database.
Available: https://gisweb3.azwater.gov/WellReg. Accessed: June 23, 2022/
Arizona Department of Water Resources. 2023. Groundwater Rights. Retrieved from Interactive
Maps and Data. Available: https://azwatermaps.azwater.gov/igfr. Accessed: March 21,
2023.
Brown, D.E. 1994. Biotic Communities of the Southwestern United States and Northern Mexico.
Salt Lake City, UT: University of Utah Press.
City of Buckeye. 2021. Industrial Pretreatment Program. Buckeye, AZ. Available:
http://azdeq.gov/updated-public-notice-proposed-arizona-pollutant-discharge-
elimination-system-azpdes-pretreatment. Accessed: March 29, 2023.
City of Buckeye. 2022. City of Buckeye. Retrieved from Buckeye Planning Map. Available:
https://buckeyearizona.maps.arcgis.com/apps/View/index.html?appid=690f24e4daf8488
3a8d7fdf547b3303f. Accessed: November 22, 2022.
Dibble. 2009. Buckeye Area Drainage Master Plan, FCD 2004C058, Recommended Design
Report. Prepared for Flood Control District of Maricopa County.
ERM. 2022. Application for Authority to Construct and Permit to Operate for Cell Manufacturing
Facility. Buckeye, AZ.
Federal Emergency Management Agency. 2013. Flood Insurance Rate Map Panels
04013C2115L and 04013C2580L. October 16. Available: https://msc.fema.gov/portal/
search?AddressQuery=buckeye%2C%20az#searchresultsanchor. Accessed: October
20, 2022
Intergovernmental Panel on Climate Change. 2023. Sixth Assessment Report. Available:
https://www.ipcc.ch/assessment-report/ar6/. Accessed: Retrieved January 11, 2023.
Maricopa County. 2022. Maricopa County Planning Department. Retrieved from Active Permit
Viewer, Permit #B2021173. Available: https://www.maricopa.gov/797/Planning-
Development.
Matrix Design Group. 2018, as amended 2022. Imagine Buckeye 2040 General Plan. Buckeye,
AZ. Available: https://www.buckeyeaz.gov/home/showpublisheddocument/6300/
637928096311900000.
Matrix Design Group. 2019. Buckeye in Motion Transportation Master Plan. Phoenix, AZ.
Available: https://www.buckeyeaz.gov/business/engineering/transportation-master-plan.
Paleowest. 2022. Class III Survey of 213.8 Acres Prior to Converting Private Farmland to a
Manufacturing Facility in Buckeye, Maricopa County, Arizona – Revised. Phoenix, AZ.
Southwest Traffic Engineering. 2023. Draft KORE Power Baseline Road/State Route 85 Traffic
Impact Analysis. Phoenix, AZ.
KOREPlex Facility Environmental Assessment
References
Page 42
U.S. Army Corps of Engineers (USACE). 2022. Approved Jurisdictional Determination File No.
SPL-2022-00348. September 29. Phoenix, AZ.
U.S. Census Bureau. 2020a. QuickFacts. Buckeye, AZ. Available:
https://census.gov/quickfacts/buckeyecityarizona.
Accessed: December 5, 2022.
U.S. Census Bureau. 2020b. Explore Census Data. Census Tract 506.17. Arizona, AZ.
Available: https://data.census.gov/map?g=0400000US04_0500000US04021$1400000_
1600000US0407940&layer=VT_2020_140_00_PY_D1&mode=selection&loc=33.3727,-
112.6021,z13.6640. Accessed: December 5, 2022.
U.S. Census Bureau. 2020c. QuickFacts.
Maricopa County, AZ. Available:
https://www.census.gov/quickfacts/maricopacountyarizona. Accessed: December 5,
2022.
U.S. Census Bureau. 2020d. QuickFacts. Available: https://www.census.gov/quickfacts/AZ.
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