The asbestos NESHAP protects the public and environment by minimizing the release of asbestos fibers during renovation and demolition activities. Advanced notification is required to ensure all precautions are being taken to minimize asbestos emissions.
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 project 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 the Notification search and click on “Search Options: and enter “Roosevelt Elementary School” as the site name.
The 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 in their notification. In this case, 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.
An asbestos survey was conducted by Michigan accredited asbestos building inspectors on the interior and exterior of the school building.
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 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.
No. EGLE reviews the notification submitted by the contractor or building owner during an inspection. Notifications are generally submitted by the contractor.
Although the school 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 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.
Top tips:
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 an online complaint.
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.
