NYC 9/11 Public Portal Document
Avaltroni, Robert
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, 1 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?
wtcoraer.aoc
NYC-WTC_000161463
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