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Berhan Keffelew <br />June 30, 2010 <br />Page 4 <br />Cement Silos (4) and Dispatch System. GCC increased the number cement silos at the <br />Facility in order to allow for additional storage needed to accommodate the varying demand <br />for cement throughout the year. <br />Rail Yard. The railyard was modified pursuant to BNSF's recommendations - to <br />accommodate the use of unit trains and to safely allow adequate space for train deliveries to <br />and from the Facility. <br />Cost Basis <br />As listed above, included with the reclamation cost analysis, is a spreadsheet describing the <br />unit cost estimates, providing RSM Code descriptions. The reclamation cost analysis <br />incorporates construction cost data based on version 2004 of RSMeans. GCC deemed this <br />cost basis most appropriate given it is a similar cost basis used in establishing GCC's <br />original financial assurance amount. In addition, GCC finds such basis accurately reflects <br />current market values for reclamation and demolition costs in the geographic <br />location where the Facility sits, the area in which GCC will be contracting for reclamation <br />services. If the Division wishes to discuss whether consideration of an alternate cost basis <br />may be worthwhile, GCC will promptly make its representatives available to participate in <br />a mutual evaluation of this issue. Also, if the Division has any question regarding the cost <br />analysis including any calculations or the basis therefor, GCC will promptly work to <br />provide any additional information or explanation. <br />Reclamation Cost Reductions <br />In addition to the information submitted herein, regarding those certain structural <br />modifications and additions which have increased reclamation costs for the Facility, GCC <br />has also identified some structural modifications causing reclamation cost reductions. <br />Given the immediate need for GCC to provide the information requested by the Division, <br />GCC did not include details or discussion regarding those modifications at this time. GCC <br />will coordinate and work with the Division to address these circumstances separately, at a <br />later date.