Norwest Corporation and Subsidiaries - Page 13

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          building (other than the parking garage) in coordination with the           
          overall remodeling project. Indeed, the remodeling could not have           
          been undertaken without disturbing the asbestos-containing                  
          fireproofing. Thus, because petitioner and Norwest Nebraska chose           
          to remodel, it became a matter of necessity to remove the asbestos-         
          containing materials.    Petitioner  essentially  decided  that             
          "managing the asbestos in place" was not a viable option, given the         
          extent of remodeling that would disturb the asbestos.                       
               Removing the asbestos-containing materials from the Douglas            
          Street building at the same time as, and in connection with, the            
          remodeling was more cost efficient than conducting the removal and          
          renovations as two separate projects at different times.  It also           
          minimized the amount of inconvenience to building employees and             
          customers.                                                                  
               As late as May 1988 (approximately 6 months after asbestos             
          removal began) petitioner and Norwest Nebraska did not intend to            
          remove the parking garage asbestos-containing materials. No                 
          remodeling was planned for the garage, and the materials were in            
          sound condition. However, petitioner and Norwest Nebraska                   
          subsequently decided to remove the garage asbestos-containing               
          materials as well, on the basis of their expectation that the               
          garage tiles would eventually deteriorate, as well as the fact that         
          it was financially advantageous to conduct this removal in                  
          connection with the ongoing abatement activity.                             






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