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would be performed in dry periods where storm flows were not <br /> present. The testing would also have to be scheduled to avoid <br /> tidal conditions which would flood the storm drain system. <br /> • If fugitive connections to the storm drain system are discovered, <br /> solutions would include either plugging the drain in question or <br /> repiping to the sanitary sewer system. <br /> Recommended Action <br /> • It is recommended that a pilot program be undertaken to examine <br /> the feasibility of flow or dye testing of inplant drains as <br /> described above. The pilot program should focus on a limited <br /> portion of the plant in an area of high risk for entry of <br /> pollutants into drains. The program should include mapping of <br /> floor drains and drainage piping followed by either flow or dye <br /> • testing. If dye testing is employed, specific approval should be <br /> obtained from the Regional Board for the dye to be used. The <br /> pilot program should be limited to three days duration. An <br /> accounting of time required for specific tasks should be made to <br /> permit extrapolation of the program to the entire plant area. <br /> • The estimated cost for a three day pilot program as described <br /> above is $2500. <br /> WASTE AND PULPED PAPER DISCHARGE <br /> • System Description <br /> Gold Bond stores waste paper bales in the yard along the south <br /> and east sides of the plant property. A chain link fence borders <br /> the plant perimeter. Yard drains, as described above, are <br /> • located in the waste paper storage area to carry storm runoff <br /> from the area . <br /> Identified Concerns <br /> Regional Board staff has indicated a concern that waste and <br /> • pulped paper may be entering McDougald Slough from the Gold Bond <br /> yard, either through wind-blown transmission or conveyance <br /> through storm drains , and has requested that steps be taken to <br /> prevent such occurences . <br /> Discussion <br />• A field investigation of the the waste paper storage area <br /> bordering McDougald Slough was made on February 4, 1986. The <br /> investigation followed a period of rain; winds during the <br /> investigation were estimated at 15 to 20 miles per hour. The <br /> following observations were made: <br />• ( 1 ) No evidence of waste paper blowing from the <br /> storage yard to the slough was observed. The <br /> slough was not littered with waste paper. Minor <br />• 15 <br />