FAQ: Asbestos and Roosevelt Elementary School

Demolition activities throughout the state are regulated by EGLE. Asbestos inspectors play a large role in ensuring these activities comply with applicable air quality rules and regulations. This is done through evaluation of notifications, inspections, complaint responses and enforcement actions when necessary. 

As the Roosevelt Elementary School demolition moves forward, EGLE will follow normal inspection and complaint response procedures, including additional sampling, if necessary.

Regulated Asbestos-Containing Material (RACM) is a specific classification of asbestos-containing materials defined by the U.S. Environmental Protection Agency (EPA) under the National Emission Standards for Hazardous Air Pollutants (NESHAP) for asbestos.

• Friable asbestos is material containing asbestos that can be crushed with hand pressure.
  • For example, pipe insulation or material that has become damaged.
• Non-friable is material that cannot be crushed with hand pressure and is firm or hard.
  • Floor tile or roofing that is in good condition are examples of non-friable materials.
  • Most nonfriable materials are not regulated under the asbestos NESHAP unless they are in poor condition or are made friable by improper work practices during demolition or renovation.

The asbestos removal contractor is a State of Michigan licensed asbestos abatement contractor. The asbestos abatement is subject to the asbestos NESHAP as well as MIOSHA Asbestos rules.

The asbestos rules are designed to protect not only the workers conducting asbestos abatement work but also the public. Asbestos abatement will be conducted under negative pressure glove-bag/negative pressure enclosure.

The enclosures require the use of air filtration devices to maintain negative pressure and filter asbestos fibers. Water usage is required to control dust inside the containment area.

Asbestos waste must be properly packaged and labeled for proper disposal. Asbestos air clearance sampling is required, which includes a visual inspection of the work areas and collection of air samples.  

The asbestos NESHAP requires a 10-day notification.

This is done through MiEnviro Portal. All notifications are available for the public to view.

• Use Notification search
• Select “Search Options"
• Enter “Roosevelt Elementary School” as the site name

A contractor can be onsite setting up equipment and containment areas before their abatement start date. 

They cannot remove any asbestos containing material before the date listed on the notification for Roosevelt Elementary School. 

September 8, 2025 is the date abatement activities may begin.

Surveys are conducted in accordance with Occupational Safety and Health administration’s asbestos standards and adhere to the Environmental Protection Agency’s (EPA’s) Asbestos Hazard Emergency Response Act (AHERA) protocol and are performed by a Michigan-accredited asbestos building inspector or a Certified Industrial Hygienist (CIH).

The number of samples collected in the survey will depend on the type and amount of asbestos.

Materials may be assumed to contain asbestos as part of an inspection. 

There is:

• An original asbestos survey dated August 2023
• A revised asbestos survey dated September 2023, and 
• Additional sampling documents dated:
  • February 2024
  • April 2024 and
  • September 2025

All asbestos surveys have been posted in MiEnviro Portal.  Look for “Site / General [DATE] Asbestos NESHAP Survey” in the Description column to find the survey you are interested in. 

An asbestos survey was conducted by Michigan accredited asbestos building inspectors on the interior and exterior of Roosevelt Elementary School building. 

All asbestos surveys have been posted in MiEnviro Portal.

Look for “Site / General [DATE] Asbestos NESHAP Survey” in the Description column to find the survey you are interested in.

Asbestos building inspectors are required to follow EPA rules and guidance documents when collecting plaster samples. These samples require a minimum number of samples based on the total area of the homogeneous material (a material like in color and texture). The asbestos building inspectors collected more than the minimum amount of samples required at the school which are:  

• < 1,000 sq ft: 3 samples
• 1,000 - 5,000 sq ft: 5 samples
• > 5,000 sq ft: 7 samples 

Plaster may look similar in color and texture; however, it is possible that the plaster in various locations may be a distinct material. This may be due to different construction dates or renovation history of the building.  It could be because asbestos was required to be added to the plaster in some building areas and not added in others.  Asbestos was often hand mixed in plaster which may cause the plaster to vary.

This is the destruction of small sections of the building to discover whether asbestos-containing material is behind concealed spaces or other hard to get to areas.

For example, pipe insulation may be behind walls and ceilings, or exterior walls may need to be accessed to check for vermiculite insulation.

Updates to the asbestos surveys are common during a project, as the owner/operator is responsible for identifying and removing all RACM prior to demolition.

For example, as additional destructive sampling occurs during abatement new materials may be identified or  areas that were previously inaccessible to an inspection can be accessed during the project.

The historical collapse of the ceiling in Room 204 is outside the authority of EGLE’s asbestos regulations. 

EGLE’s oversight of a renovation or demolition project begins when a notification of intent to renovate or demolish is submitted. 

This room was part of the asbestos survey and abatement is being done as appropriate for the findings of the survey.

The asbestos NESHAP does not include asbestos air sampling in the rule.

The MIOSHA Asbestos Program enforces rules related to air monitoring to ensure fibers concentrations are below established amounts.

Air sampling will be conducted during the project by the environmental consultant. 

Yes, additional samples will be taken as needed.

In September 2025, an additional 15 samples were taken on the first floor and 2nd floor center stairwell and analyzed. One sample tested positive for asbestos in the 2nd floor center stairwell.

These results can be seen in the "Old Roosevelt - Bulk Sample Reports Applied Redactions.pdf" starting on page 148. 

Yes, additional samples will be taken as needed.

In September 2025, an additional 29 samples were taken of the roof and analyzed. The results indicated that the roof siding caulk - grey came back as asbestos containing. No other roofing samples to date have contained asbestos.

These results can be seen in the "Old Roosevelt - Bulk Sample Reports Applied Redactions.pdf" starting on page 148. 

No.

EGLE reviews the notification submitted by the contractor or building owner during an inspection. Notifications are generally submitted by the contractor.

Although Roosevelt Elementary will be demolished, the asbestos abatement notification is submitted as a Planned Renovation to EGLE under Box 1 of the notification. 

The asbestos abatement notification may not appear to list all asbestos being abated from a building as a contractor is only required to notify for removal of RACM.

Notifications are required to be revised when there is a change to the required information previously submitted.

The end date of asbestos abatement and the start date of demolition are estimates by both contractors.

The rules don't allow for the demolition contractor to revise their start date "backward" if the abatement contractor finishes early. 

The demolition date will start no earlier than the date on the demolition notification.

Yes, abatement started on September 8, 2025

Yes, abatement is happening in an enclosure within the building. Fresh air and exhaust air must be available for the filtration process to work and to keep workers safe. All air is filtered for asbestos before exiting the enclosure. 

A visual inspection and clearance sampling of abatement areas will be conducted by the environmental consultant. EGLE will conduct a post abatement inspection of the school prior to demolition. 

No, the owner or operator determines when the building will be demolished. EGLE and MIOSHA will ensure the asbestos abatement is conducted in accordance with all applicable rules and regulations and will take enforcement actions, if necessary. 

The US Environmental Protection Agency has specific rules related to paint abatement and demolition. You can learn more on their Lead-Based Paint and Demolition website. 

The contractor will be required to submit a notification of “intent to demolish” when they are getting ready for demolition.  This will be posted as a notification in MiEnviro Portal. 

The Agency for Toxic Substances and Disease Registry (ATSDR) has robust information on how asbestos may impact you. ATSDR asbestos and your health

The Agency for Toxic Substances and Disease Registry (ATSDR) has robust information on how asbestos may impact the outdoor environment as well as sources of asbestos and how to reduce exposure. ATSDR asbestos in your environment: What you can do to limit exposure

For concerns related to water and soil, please contact the EGLE Warren District Office and ask for the Water Resources Division and/or the Remediation and Redevelopment Division at 586-753-3700.  

The State of Michigan Construction Standard: Part 20, Demolition does not require a hydrogeologic survey. Additionally, EGLE and the US EPA do not require hydrogeologic surveys before this type of demolition can occur. 

These tips can be helpful anytime there is renovation or demolition going on near you. The chance of asbestos leaving the sire is very low but is can still be prudent to take additional safety steps.

Top tips: 

• Stay away from demolition sites. 
• Keep windows and doors closed during demolition activities.
• Clean dust inside your home with water and use a Hepa filter when vacuuming.
• Wipe down pets with a damp cloth after outdoor activities.
• Keep yard dust down with water.

The demolition contractor is required to use appropriate dust control techniques during demolitions. Complaints about dust that crosses beyond property lines can be filed by anyone in the community. Complaints are investigated by EGLE staff.

File a complaint online

MIOSHA also has rules to help prevent dust exposure to workers, which can also help prevent possible exposure to the community. 

The decision to evacuate during a demolition is made by local officials.

This decision is based on an engineering study to determine the potential impacts of demolition.

Questions related to this should be directed to Keego Harbor. 

Once demolition has been concluded and any visible dust is cleaned up, residents should be able to resume normal activities.

Any questions related to exposure should be directed to health professionals.