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Draft Environmental Impact Report Forward Inc. Landfill Expansion Project Page IV.E-10 Impact E.3: Spills, collisions, upsets,or other accidents at the landfill or during waste transport could cause injury to site workers,the general public, or the environment. Toxic leachate could leak or spill due to containment failures, and special wastes such as asbestos containing materials (ACM), petroleum contaminated soils, ash, etc. could end up in inappropriate uncontrolled locations due to spills, collisions, upsets or other accidents that can occur during the landfilling operations. Mitigation of such accidents after the fact—such as e sed— could be difficult. Worker health and safety could be threatened in the event such upsets occ windblown asbestos containing materials if the bags that contain ACM ripped and di p The Forward Landfill operating procedures (part of the JTD) contains the Site Emergency ur: Action Plan, Fire Prevention Plan, Health and Safety Plan and Hazardous Material Management Plan that are designed to have procedures in place to deal effectively with spills, collisions, upsets, or other accidents at the landfill. The San Joaquin County Office of Emergency Service signed off on the Forward Landfill plan. i The following procedures are proposed as part of the project: The Standard Safe Work Practices listed in the Forward, Inc. Site Health and Safety Program and Contingency Plan will be implemented by the operator. J � • The landfill operator will comply with the provisions of CCR Title 27, Section 20590, which requires that O&M personnel wear and use approved safety equipment for i personal heath and safety. • Landfill access will continue to be controlled to limit unauthorized entry by persons or vehicles. ■ The landfill operator will comply with all provisions of CCR, Title 27, Division 2, Chapter 3, Subchapter 4, Articles.1-3 that apply to landfill health and safety. i These procedures also would be included in the JTD being updated by the applicant. The off-site impact is potentially significant, therefore the following additional mitigation measure is suggested: i Miti ation Measure E.3: The San Joaquin County Public Works Department shall approve any ' new waste transport haul routes to the landfill from major arterials, SR 4, or Highway 99. Implementation of the proposed procedures and this mitigation measure would reduce the impact to a less-than-significant level. Impact EA: Additional landfill gas would be generated, thus increasing the potential for explosion hazards. Landfill gas concentrations of methane and carbon dioxide, the two indicator gases that commonly build up within landfills,have been reported as less than significant levels in the 11 monitoring points in the most recent(Q2-200$) sampling at Forward j Landfill. Higher concentrations of landfill gases are attributed to the Austin Road Landfill unit. The production of landfill gases within a landfill is of concern because the methane gas at 50 percent concentration is flammable when diluted with air(5 to 15 percent by volume) and because of the hazardous air pollutants carried with the gas (such as the documented volatile VOCs in the area of the Austin Road Landfill). Uncontrolled landfill gas emissions could cause explosive methane gas buildup that could be ignited by machinery or onsite workers. Methane is slightly denser than air (1.56 versus 1.17 g/L)but is a gas and as such will often accumulate at t I i �^ k G i