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Identified Concerns Regional Board staff has indicated concern that "fugitive" connections to the storm drain system may exist which could • potentially result in the discharge of pollutants to McDougald Slough. The Regional Board has requested a schematic diagram of the storm drain system and all known connections to that system and has suggested that a smoke test be performed to identify unknown connections. • Discussion It should be noted that no evidence exists to suggest that pollution of McDougald Slough has resulted from "fugitive" connections within the Gold Bond plant. The episode of dye in the slough was a result of discharge to an exterior drain inlet • rather than a fugitive inplant connection. The investigation of fugitive connections is therefore one of precaution rather than of observed effect. For this reason, it seems reasonable that this investigation should be aimed primarily at high risk areas where spills or inadvertent disposal practices could result in discharge of pollutants to the slough. • As mentioned above, no schematics of the inplant drainage system are available. Investigation of fugitive connections will therefore require some form of physical evaluation of the existing system. The Regional Board has suggested smoke testing as a means of locating such connections to the storm drain • system. The following problems exist with this approach: ( 1 ) Access to the storm drain system is limited to two manholes in West Church Street. Smoke testing from these two points would provide only limited coverage within the Gold Bond plant. Smoke will • follow the path of least resistance and exit at the first connections to atmosphere. ( 2) Many inplant drains have P-traps which will prevent the passage of smoke. Connection of such drains to the storm drain system would not be observed in a • smoke test. Smoke testing is therefore not recommended for the evaluation of fugitive connections within the Gold Bond plant. • One possible alternative to smoke testing would be to either flow or dye test individual drains within the Gold Bond plant. This effort would require an initial inventory of drain locations throughout the plant, a visual tracing of pipe connections and flow routing , and finally either flow or dye testing of individual drains. As mentioned above, the testing should focus • primarily on drains in high risk areas for spillage, etc. The flow or dye testing would be performed by adding either slugs of flow or flow with dye tracer to inplant drains and monitoring downstream storm drain manholes in Church Street. This testing • 14