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Memo on Commissioner's Orders for building cleaning, Oct 2002

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DEP memo dated October 2002 discusses issuing orders to buildings with asbestos residue and drafts compliance requirements.

NYC-WTC_000153573–000153575

Folder label: “WORLD TRADE CENTER - BUILDING EXTERIORS

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NYC 9/11 Public Portal Document

(£> Hoffer, Mark From; Pecunies, Russ Sent: Wednesday, October 02, 2002 12:32 PM To: Hoffer, Mark; Avaltroni, Robert; Gilsenan, Michael; Radhakrishnan, Krish; Rogak, Elizabeth Subject: Commissioner's Orders - Lower Manhattan Building Cleaning

Since we are now approaching the end of the exterior cleaning program in lower Manhattan, it may soon be necessary to issue Commissioner's Orders to those buildings which have not submitted License Agreements and where positive asbestos samples are collected. So we are prepared to do this, I am attaching a draft Order for your review. Please review and comment with regard to the wording, particularly #3, keeping in mind that the Order must satisfy the requirements of the Spill Bill while remaining consistent with past positions we have taken regarding the hazard posed by WTC residue.

Other issues:

If we have no access to the building to collect samples, do we issue an Order?

If the Order is not complied with, do we issue NOVs? —

Should we give the owner the option of submitting a License Agreement as a way of complying with the Order?

wtcorder.doc

) 1

NYC-WTC_000153573

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NYC-WTC_000153573Source: NYC Law Department, mirrored locally

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