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1001 I Street, Sacramento, CA 95814  P.O. Box 4025, Sacramento, CA 95812 <br />www.CalRecycle.ca.gov  (916) 322-4027 <br />California Environmental Protection Agency <br /> Department of <br />Resources Recycling and Recovery <br />Gavin Newsom <br />California Governor <br />Yana Garcia <br />Secretary for Environmental Protection <br />Zoe Heller <br />CalRecycle Director <br />August 12, 2025 Via Email: mhoughton@sjgov.org <br /> <br /> <br /> <br />Mark Houghton, Senior Engineer <br />County of San Joaquin <br />Public Works Department – Solid Waste Division <br />1810 East Hazelton Avenue <br />Stockton, California 95205 <br /> <br />NORTH COUNTY LANDFILL, SAN JOAQUIN COUNTY (39-AA-0022) <br />PRELIMINARY CLOSURE AND POSTCLOSURE MAINTENANCE PLAN <br />REVIEW COMMENTS <br /> <br />Dear Mr. Houghton: <br /> <br />The California Department of Resources Recycling and Recovery (CalRecycle) Closure <br />and Technical Support Section staff reviewed the following updated document: <br /> <br />Preliminary Closure and Postclosure Maintenance Plan; dated October <br />30, 2024; prepared by San Joaquin County Department of Public Works <br />Solid Waste Division. <br /> <br />CalRecycle staff finds that the Preliminary Closure and Postclosure Maintenance Plan <br />(Plan) is not technically adequate with applicable requirements of Title 27 of the <br />California Code of Regulations (27 CCR). The following comments need to be <br />addressed: <br /> <br />1. Table 2, Preliminary Closure Cost Estimate, assumes that an interim/foundation <br />(intermediate cover) layer is anticipated to be in place at the time of final cover <br />construction. The closure cost estimate excludes this layer in the foundation layer <br />cover cost. Estimated closure costs are to include all activities yet to be completed at <br />the time of preparation of the estimate. Although CalRecycle understands that it is <br />possible that some intermediate cover may be available and usable as a portion of <br />the final cover design, nevertheless, since it is unknown (1) the quantity of <br />intermediate cover that may be present at final closure (thickness initially placed, <br />erosion, etc.) and (2) the quality of the material (not placed under final cover quality <br />control conditions, wear over time, etc.), it is premature to presume that there will be <br />sufficient quality and quantity of the material suitable for final cover. At the time of <br />partial or final closure design and implementation, the suitability of any existing <br />intermediate cover could be investigated at that time. <br />