February 14, 2023

Michigan Department of Environment, Great Lakes, and Energy,

Drinking Water and Environmental Health Division,

Attention: David DeYoung

Constitution Hall,

525 W Allegan Street, 4th Floor-South,

P.O. Box 30817, Lansing, MI 48909-8311

Dear Mr. DeYoung,

I write concerning the proposed changes to administrative rules 325.1601 – 325.1781 concerning the

ASTM International specification C 150-89 “standard Specification for Portland Cement.” The

Michigan Ground Water Association supports the Pending Rule Set 2022-39 EQ.

MGWA supports the rule changes because Type I cement has been discontinued by the

manufacturers of Portland Cement. Due to Type I cement no longer being available, wells which are

grouted with cement, shallow bedrock wells, and abandonment of wells cannot be legally done; this

endangers the public health.

Type IL cement is the reasonable alternative being offered by manufacturers of Portland Cement.

Even though it has the same cementitious qualities as Type I, it is not an approved alternative at this

time; the Pending Rule Set would fix this problem and allow the use of Type IL.

Approving the proposed rule changes under Pending Rule Set 2022-39 EQ will further public health

and safety by allowing the proper grouting of wells, shallow bedrock wells, and the abandonment of

wells. MGWA fully supports these changes under Pending Rule Set 2022-39 EQ.

Thank you for the opportunity to provide written comments in support of Pending Rule Set 2022-39

EQ.

Respectfully,

Charles “Buddy” Sebastian,

President