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r <br />9. The NOI states that "concrete" will be used for plugging core holes. Referring to <br />COGCC requirements for plugging of coalbed methane wells, the NOI should specify <br />a type and quantity of cement (not concrete) that will be used, and how it will be <br />pumped. As a courtesy, Pioneer suggests that the Division consult with COGCC on <br />the proper plugging of these de facto gas wells to ensure that gas seeps are minimized <br />and public health and safety are protected. <br />10. Similarly, when Pioneer plugs a CBM well it must follow a protocol approved by <br />COGCC and verify the integrity of the plugging. Pioneer suggests that NECC <br />develop a similar, specific protocol, using COGCC requirements as a guideline. <br />11. COGCC requires that gas seep surveys be conducted on any plugged and abandoned <br />wells located near a proposed CBM well. Pioneer has already spent over a hundred <br />thousand dollars conducting gas seep surveys in the vicinity of coal mines and <br />abandoned wells. Pioneer suggests the NECC be required to do a follow-up gas seep <br />survey to verify that coal exploration core holes have been properly plugged and <br />abandoned. <br />12. Similar to COGCC requirements for CBM wells, Pioneer suggests the NECC be <br />required to conduct baseline gas seep surveys prior to mining of new areas as a way <br />of assessing whether subsidence or mining operations are increasing gas seep activity <br />and creating a new risk to public health and safety. <br />13. The NOI notes that drilling of core holes will require construction of an unlined pit. <br />Reclamation of drilling pits for CBM operations, including CBM core hole <br />operations, requires that specific soil standards be met during pit closure. Similar <br />standards, as a condition of approval, would ensure that the proposed pit associated <br />with core hole drilling does not create an environmental or public safety risk. <br />Specific standards that might be applied to the closure of drilling pits can be found in <br />COGCC rules (Table 910-1). <br />14. The NOI should address measures that will be taken to ensure that drilling pits will <br />not be used for waste disposal; whether the pit will be lined; and how it will be <br />constructed to avoid wildlife from becoming trapped in the pit. These are all issues <br />addressed in current State regulations, which can provide guidance. <br />15. One of the more common citizen complaints in the Raton Basin concerns noise. <br />Pioneer requests that the NOI address how noise impacts will be minimized and what <br />measures will be taken to reduce noise impacts on nearby residents. <br />16. The NOI should discuss what steps will be taken to document chemicals that will be <br />stored on site and used down hole, and the availability of Material Safety Data Sheets <br />(MSDS) for those chemicals. Local citizens have been increasingly vocal about <br />wanting to know what chemicals are being used in drilling. Documentation, MSDS <br />on site, and maintenance of a chemical inventory are common practices when drilling <br />wells for CBM production. Pioneer believes it would prudent to implement these