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<br /> <br /> <br /> <br /> <br />1810 East Hazelton Avenue | Stockton, California 95205 | T 209 468 3000 | F 209 468 2999 <br />Follow us on Facebook @ PublicWorksSJC Visit our website: www.sjgov.org/pubworks <br /> <br />Department of Public Works <br /> <br />Fritz Buchman, Director <br />Alex Chetley, Deputy Director - Development <br />Kristi Rhea, Deputy Director - Administration <br />David Tolliver, Deputy Director - Operations <br /> Najee Zarif, Deputy Director - Engineering <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br />August 22, 2025 <br /> Ms. Rachel Beck P.G. <br />Engineering Geologist <br />Closure and Technical Support Section <br />Engineering Support Branch, CalRecycle <br /> <br />SUBJECT: NORTH COUNTY LANDFILL, SAN JOAQUIN COUNTY (39-AA-0022) <br />PRELIMINARY CLOSURE AND POSTCLOSURE MAINTENANCE PLAN <br />REVIEW COMMENTS DATED AUGUST 12, 2025 <br /> <br />Dear Ms. Beck: <br /> <br />Following are comments in response to your letter dated August 12, 2025. <br /> <br />1. Interim Cover Assumption. In your letter, you direct that the County is to “not assume the <br />use of any estimated in-place intermediate cover material”. So, the assumption would be <br />that for a 185 acre landfill that has been in place for 30 plus years there is no suitable or <br />acceptable cover that would be accepted as part of final cover? Really? Reducing the <br />assumed thickness from 30” to say 12” would be conservative, but zero is extreme and <br />unreasonable. Please share the basis for this interpretation as I don’t see it in Title 27. If <br />your concern is about inadequate thickness than a more realistic approach would be to <br />increase the overall depth of final cover as I have done on the attached revised table. <br />2. Cost Estimate Basis. The costs which are the basis for the estimate come from actual jobs <br />bid by the county. I would be happy to provide copies. The use of surcharge and mark-ups <br />might be appropriate for cost estimates based strictly upon hourly rates, or equipment rental <br />rates, but that is not the case here. <br />3. Mobilization/Demobilization. Mob/Demob has not been explicitly included on this nor prior <br />versions but certainly is a realistic cost for any project. I am happy to separate it out but note <br />a corresponding reduction in contingency. In the past few months, the County bid a project <br />to construct a new module at this facility. The bid awarded was for over $10m, thus of <br />similar magnitude to this project and the Mob/Demob was 4.5% which I have applied to the <br />updated attached table. <br />I look forward to your response, and subsequent approval. if you have any questions, please <br />email or call me at (209) 953-7316. <br /> <br />Sincerely, <br /> <br />Mark Houghton, PE <br />Senior Civil Engineer <br /> <br />N:\1North County\CalRecycle-LEA\JTDs\2024 5 Yr Review\Full JTD Appendices\Appendix B - Closure PCMP\Tables n <br />FIgures\2025-8-22 NC 5-Year JTD Response to Comments.docx <br />Attachment: Table 2 Preliminary Closure Cost Estimate – revised 8/22/25 <br />C by email: Bryce Howard, Integrated Waste Manager <br />Todd Del Frate, Central Valley Regional Quality Control Board <br />Natalia Subbotnikova SJ County EHD <br />Garret Backus, SJ County EHD