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The undersigned organizations are pleased to submit comments on the application of Range Resources Appalachia LLC, General Permit Number WMGR097R025, for research and development (R&D) activities involving the use of drill cuttings from natural gas wells as an aggregate in a stabilized soil pavement.

Oil and gas operators face a growing challenge in handling and disposing of the increasing volumes of solid and liquid waste they produce. However, this concern should not be a reason to allow dangerous substances that threaten health and the environment to be used in ways that can have unknown consequences for the public. With this in mind, we offer comments in three parts: objections related to the potential designation of “beneficial reuse” in the context of natural gas operations; ongoing concerns about the likelihood that gas field wastes such as drill cuttings are hazardous and radioactive; and specific concerns about the permit application itself.

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