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  
Charles “Buddy” Sebastian,