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Cement manufacturing pendent of any relationship or "extraction" which are lion' definition. facilities appear to to the definitions activities basic to be entirely inde- of "development" the "mining opera- A collector is utilized to capture a fine material carried from a cement plant l:iln with the products of combustion. Some of this material is normally wasted due to problems that current- ly prevent return of 100%~ to the kiln. This o:aste material is in no coay connected coit':Z the cleaning and preparation of substances mined by the Wining operation and will not classify as "refuse" according to the definition given in the Colorado P?ined Land Reclama- tion Act. This is further proof that the Act did not intend to in- clude processes such as a cement manufacturing Plant in "affected land" or "t"_ining Operation." This is the reason Ideal's applica- tion for a mining permit asked for specific approval to include, as affected land, a location where this plant waste is deposited in a worked-out portion of a limestone quarry. 2. Use of_ several raw materials in the manufacture of Portland Cement. Paterials used by Ideal in the manufacture of Portland Cement include limestone, marl, oyster shell, shale, clay, sandstone, iron ore, alumina by-products, fuel (primarily coal) gypsum and special purpose chemicals. l:any of these materials are mined at remote locations by Ideal or purchased from others. Limestone or the calcareous constituent is a major raw material from a weight standpoint, but often is less costly than the other materials. Average coal usage is 530 pounds per ton of cement produced. Power consumption to manufacture cement is normally purchased and requires about 120 kilowatt hours of electrical energy per ton of cement. 3. Off-site status of cement production facilities as referenced in the last line of the "Mining Operation" definition. The following information is presented to further establish cement production facilities as other off-site operations not con- ducted on affected land as given in the last sentence of the defini- tion of "Mining Operation." All Ideal plants operate separate mining operations or purchase other materials listed under item 2 above. Economical access to major raw materials is only one of the considerations in the location of a cement plant. Ideal's Seattle, Washington plant is 200 barge miles distant from the limestone source on Texada Island, B. C. Oyster shell, limestone and clay for the Plobile, Alabama and Houston, Texas plants are all transported appreciable distances. At Portland, Colorado, limestone and shale moves -3-