The repeated notices of violations and permit deviations at Tesla’s Fremont factory over the last 18 months, first reported exclusively by The Drive, center on one of the plant’s most persistent trouble spots: the paint shop. Paint shops consistently the biggest air quality challenge for any car factory, but at Fremont a witches brew of technical problems, fires, poor record keeping and an apparent disregard for environmental compliance has led to a pollution problem whose magnitude we may never fully understand.

The most dramatic element of Tesla’s paint shop problems are without a doubt the repeated fires that plagued the facility throughout 2018 and beyond. According to minutes from a November 2018 meeting of the Bay Area Air Quality Management District’s board of directors, reports of conflagration prompted the regulator to step up their scrutiny of Fremont’s paint shop. “Following the fire in April 2018 and smoldering event in June 2018, at Tesla Inc., Air District staff have been conducting inspections at Tesla’s North Paint Shop, Assembly and Touch-Up Operations. Air District staff are in the process of reviewing Tesla’s permit applications and evaluating previously unpermitted coating operations, including all coatings, solvents, and adhesives used at the facility,” reported Compliance and Enforcement Division Director Jeffrey Gove.

In fact, BAAQMD staff first noticed potential fire risks much earlier. According to a Tesla semi-annual compliance report dated July 31, 2018, Senior Air Quality Inspector Huynh informed Tesla on January 9 that an inspection the month before had identified a permit condition deviation involving improper disposal of flammable solvent wipes in the plant’s North Paint Shop. Then, on April 3, an E-Scrub system used to control overspray emissions at Primer Spray Booth #1 and Clear Coat Spray Booth #3 were “de-energized due to safety concerns as possible ignition sources for fires.” Two days later, CNBC reported that a fire had broken out at a primer booth on the 3rd, the first of a series of high-profile reports of fires at the facility.

On June 1 CNBC’s Lora Kolodny followed up with a story reporting that the April 3 fire had been worse than previously understood, and that no fewer than four fires had taken place at Fremont’s paint shop since 2014. On June 5th, I reported in the Daily Beast that sparks from an E-Scrub’s electrostatic plates had sparked paint that had backed up out of a clogged hopper, sparking the fire. Though Tesla responded to both Kolodny’s and my reports by touting the steps it had taken to upgrade equipment, a BAAQMD document shows that another E-Scrub system was de-energized on the 21st “as investigative findings indicate that the electrically charged plates are a source of ignition for fires in spray booths.

But the most worrying detail in Kolodny’s story was the one that nobody seemed to pay much attention to, and which I struggled to corroborate. “Months before the April fire, the sprinkler heads were clogged and coated at least an inch thick of paint and clear-coat,” according to Kolodny’s sources. “Filters below the paint booths and exhaust systems that clean and carry air into and out of the building were also visibly coated.” Though seemingly innocuous compared to repeated conflagrations, the new documents confirm that this was actually evidence of cascading problems that had left the paint shop out of compliance.

Tesla had failed to obtain the necessary Permit To Operate for 15 emissions sources and four abatement systems installed as part of its 2015 revamp of North Paint, and had failed to perform required particulate emissions tests on three of those sources (all spray booths) and the E-Scrub systems that were supposed to abate their overspray. With the e-Scrub system shut off due to fire risk, overspray began to collect in the shop’s ductwork and damaged the thermal oxidizer, leading to an “informational” source test that showed the oxidizer was letting through Precursor Organic Compounds through the abatement device at a rate above the permitted limit. Conveniently, however, Tesla hadn’t maintained records related to the temperature at which it was operating that oxidizer, raising now-impossible-to-answer questions about its actual POC destruction rate.

Over the May 26-29 shutdown, Tesla tried to clean up its ducts, fix the thermal oxidizer and cobble together an unpermitted filter house system (which ironically can be seen in an official company video titled "Tesla 2018", see blue filters on the floor in the image at the top of this post) to replace the E-Scrub and keep overspray out of the ducts and sprinklers. This emergency fix seems to have kept this unlucky section of the paint shop out of the list of deviations and violation notices for the rest of 2018, but an unpermitted physical filter system would likely fundamentally affect the entire system’s airflow and thus its permit conditions.

By September it was the South Paint shop’s turn to feature in BAAQMD’s documents, specifically the very same thermal oxidizer that created the plant’s first real air quality compliance problem way back in 2015. This time oxidizer A-1002 had bigger issues than just emitting a little extra NOx, shutting down completely for four and a half days while Tesla continued to produce cars (and likely POC emissions) at its highest rates to date. Tesla obtained “breakdown relief” for this debacle, but then it turned out that records for A-1002 hadn’t been maintained since 2016 when its previous refurbishment was supposed to have been completed.

This combination of repeated problems at A-1002 and the lack of record maintenance for the system raises even tougher questions about its real-world emissions over the years, but the problems still weren’t over. In December, a “miscommunication” between Tesla and its source test contractor meant A-1002’s annual test wasn’t completed requiring a “make-up compliance test.”

Then, in April of 2019 Tesla went before BAAQMD’s Hearing Board to request permission to operate A-1002 at 1275 degrees Fahrenheit instead of the 1400 degrees the district wanted due to damage that the company said was likely to get worse at the higher temperature. The board sided with Tesla, figuring that further damage could cause worse emissions than the lower operating temperature. It is unclear if the damage in question was also caused by the decision to turn off the E-Scrub system, but regardless Tesla will finally replace A-1002 in June of 2019.

Like most of the tragic stories coming out of Tesla’s struggle with automotive manufacturing, the main lesson of this saga is that making cars is hard. But beyond that, there’s a theme that also resonates throughout many of Tesla’s challenges: a frantic pace may push an up-and-coming automaker through today’s crisis but in any heavy industry there will always be a cost for not planning thoroughly and moving at a deliberate pace. In its haste to conquer the industry and justify its industry-dwarfing market valuation, Tesla seems to have lost one of its most important assets: its environmental leadership.

Tesla and BAAQMD did not return requests for comment.