February 14, 2023
Michigan Department of Environment, Great Lakes, and Energy,
Drinking Water and Environmental Health Division,
Attention: David DeYoung
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,