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Mr. Houghton <br />August 12, 2025 <br />Page 2 of 3 <br /> <br />The preliminary closure cost estimate must be revised to include the cost for the <br />entire final cover design and not assume the use of any estimated in-place <br />intermediate cover material. <br /> <br />2. Table 2, Preliminary Closure Cost Estimate, per 27 CCR Section 21815, cost <br />estimates shall include both a surcharge and mark-up for labor costs. The surcharge <br />and mark-up factors are 9% for labor surcharge and 35% for labor mark-up, and <br />15% mark-up for both material and equipment. It is unclear if these surcharge and <br />mark-up factors were incorporated into the labor, material, and equipment costs. <br /> <br />The operator needs to submit cost estimates that are detailed and justified pursuant <br />to 27 CCR Sections 21815, 21820, and 21840. Please specify and provide <br />additional back-up information regarding bid costs to ensure that appropriate <br />prevailing wages and markups are used. <br /> <br />3. Table 2, Preliminary Closure Cost Estimate, the cost estimate does not specify a <br />cost for mobilization and demobilization for final cover construction. Based on cost <br />estimate review experience, CalRecycle staff have seen the actual cost for <br />mobilization and demobilization in California has ranged from 4 to 18% of total <br />closure costs. <br /> <br />The operator needs to include a cost estimate for mobilization and demobilization <br />that is detailed and justified to demonstrate an estimate representative of State costs <br />pursuant to 27 CCR Sections 21815, 21820, and 21840. <br /> <br />Pursuant to 27 CCR 21860(f), the operator is required to respond to the above <br />comments and submit required revisions within 60 days of receipt of the comments <br />unless an alternative schedule is approved. Please submit the response by <br />October 13, 2025. <br /> <br />Should you have any questions or comments concerning the above matter, please <br />contact me at (916) 341-6229 or by email at Rachel.Beck@calrecycle.ca.gov. <br /> <br />Sincerely, <br /> <br /> <br /> <br />Rachel Beck, P.G. <br />Engineering Geologist <br />Closure and Technical Support Section <br />Engineering Support Branch <br /> <br /> <br /> <br />