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Mr. Brendan Kenny October 7, 2020 Page 4 UV Building using a diesel-powered sump pump.' The Baker tanks served as a temporary emergency containment system. Water in the Baker tanks was then hauled off-site and, out of an abundance of caution, disposed of at a location approved for the disposal of hazardous waste. In August 2020, the SFPUC received a service bulletin issued by Calgon to the SFPUC as well as 6 other agencies stating that the company was recalling the existing model of UV lamps due to "occasional reports of premature failures." The service bulletin further stated: "Following many months of troubleshooting, data collection, and analysis, it is believed that a fluctuation in the lamp manufacturing process may lead to cases of lamp deformations and premature failures in certain limited instances. The investigation further shows that this appears to be exacerbated at installations that operate the lamps in the 12- 16kW lamp power range." Calgon has offered SFPUC and the other agencies new lamps that have a modified manufacturing process, which they believe will not result in premature lamp failures. The Facility is in the process of replacing all UV lamps following Calgon's recall process. Approximately half of the UV lamps at the Facility have been replaced with the new UV lamps. Facility staff are working closely with Calgon to prioritize shipment of the new lamps to Tesla and complete replacement of the remaining lamps. On August 24, 2020, Tesla experienced a UV lamp and sleeve break in one of its existing model lamps. Water in the trench drain was routed to the Baker tanks per the temporary emergency interception plan. Regulatory and Technical Analysis In September 2019, SFPUC retained Stephen McCord of McCord Environmental to evaluate the potential environmental impacts from the lamp break releases and other regulatory concerns expressed by the Regional Board. Stephen McCord, President of McCord Environmental, Inc., is a registered Professional Engineer in California whose area of focus in the last 20 years has been on monitoring, modeling, and remediating mercury. Releases Do Not Affect Waters of the State The NOV and Order alleged that the lamp break releases constitute a violation of CWC section 13260 and ordered the SFPUC to submit a Report of Waste Discharge. Water Code section 13260(a) states, in relevant part (emphasis added), "Each of the following persons shall file with the appropriate regional board a report of waste discharge, containing the information that may be required by the regional board: (1) A person discharging waste, or 3 More detail about the Baker tanks is included in the memorandum prepared by McCord Environmental,dated June 2020, on pages 8-9.