ML003680254
| ML003680254 | |
| Person / Time | |
|---|---|
| Issue date: | 02/03/2000 |
| From: | Charemagne Grimes NRC/NRR/DRIP/RLSB |
| To: | Walters D Nuclear Energy Institute |
| Lee S | |
| References | |
| Download: ML003680254 (18) | |
Text
February 3, 2000Mr. Douglas J. WaltersNuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708
SUBJECT:
GENERIC AGING LESSONS LEARNED (GALL) REPORT AND STANDARDREVIEW PLAN FOR LICENSE RENEWAL (SRP-LR)
Dear Mr. Walters:
We held a public workshop on December 6, 1999, to discuss the development of the GenericAging Lessons Learned (GALL) report and the Standard Review Plan for License Renewal (SRP-LR). As described in SECY 99-148, "Credit for Existing Programs for License Renewal,"
the staff plans on referencing the GALL report in the SRP-LR as a basis for determining the adequacy of existing programs.The staff intends to treat the GALL report as a topical report with generic applicability to allplants. We have drafted guidance on the treatment of the GALL report, including an example on a license renewal application and the corresponding staff safety evaluation report. (See ) We have also drafted the corresponding SRP-LR section as an example. (See ) We plan on using Enclosure 2 as a "guide" to develop the aging management review sections of the SRP-LR. Please note that Enclosure 2 references a Branch Technical Position (BTP) on aging management review. This BTP is intended to be the staff guidance for program acceptance using the "10 program elements" contained in Section 3.0 of the draft SRP-LR, dated September 1997.As discussed in the public workshop on December 6, 1999, the staff is releasing early drafts oflicense renewal implementation guidance documents to invite stakeholders participation.
Accordingly, we are providing these enclosures for your information and comment. We also would be willing to meet with industry representatives to discuss any comments you may have.
If you have any questions regarding this matter, please contact Sam Lee at (301)415-3109.Sincerely,/RA/Christopher I. Grimes, ChiefLicense Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor RegulationProject No. 690
Enclosures:
As stated cc w/encl: See next page Mr. Douglas J. WaltersNuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708
SUBJECT:
GENERIC AGING LESSONS LEARNED (GALL) REPORT AND STANDARDREVIEW PLAN FOR LICENSE RENEWAL (SRP-LR)
Dear Mr. Walters:
We held a public workshop on December 6, 1999, to discuss the development of the GenericAging Lessons Learned (GALL) report and the Standard Review Plan for License Renewal (SRP-LR). As described in SECY 99-148, "Credit for Existing Programs for License Renewal,"
the staff plans on referencing the GALL report in the SRP-LR as a basis for determining the adequacy of existing programs.The staff intends to treat the GALL report as a topical report with generic applicability to allplants. We have drafted guidance on the treatment of the GALL report, including an example on a license renewal application and the corresponding staff safety evaluation report. (See ) We have also drafted the corresponding SRP-LR section as an example. (See ) We plan on using Enclosure 2 as a "guide" to develop the aging management review sections of the SRP-LR. Please note that Enclosure 2 references a Branch Technical Position (BTP) on aging management review. This BTP is intended to be the staff guidance for program acceptance using the "10 program elements" contained in Section 3.0 of the draft SRP-LR, dated September 1997.As discussed in the public workshop on December 6, 1999, the staff is releasing early drafts oflicense renewal implementation guidance documents to invite stakeholders participation.
Accordingly, we are providing these enclosures for your information and comment. We also would be willing to meet with industry representatives to discuss any comments you may have.
If you have any questions regarding this matter, please contact Sam Lee at (301)415-3109.Sincerely,/RA/Christopher I. Grimes, ChiefLicense Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor RegulationProject No. 690
Enclosures:
As stated cc w/encl: See next page Document Name: C:\GALL_SRP.wpdOFFICELARLSBRLSB:SCRLSB:BCNAMEEHyltonSLeePTKuoCGrimes DATE 02/02/00 02/02/00 02/02/00 02/03/00OFFICIAL RECORD COPY 2/3/00TREATMENT OF THE "GALL" REPORTAPPROACHThe Generic Aging Lessons Learned (GALL) report should be treated in the same manner asan approved topical report. The staff should not repeat its review of the matters described in the GALL report and should find it acceptable when the GALL report is referenced in a license renewal application. However, the staff should ensure that the material presented in the GALL report is applicable to the specific plant involved. The staff should also verify that the applicant has identified specific programs as described and evaluated in the GALL report.Information in the License Renewal ApplicationIn Chapter 2 of the application, the applicant would identify structures and components subjectto aging management review for license renewal. Scoping is not affected by the presence of the GALL report. (Note: Chapter 1 of the application contains administrative information.)In Chapter 3 of the application, the applicant would provide the aging management review ofthe structures and components identified in Chapter 2. The applicant would reference the GALL report as appropriate. The applicant would briefly describe the system, components, materials, and environment, and state that they are bounded by the GALL report. The applicant would also state that the applicable aging effects and industry and plant-specific operating experience have been reviewed, and are bounded by the GALL report. Any outliers would be discussed in the application. Then, the applicant would state that certain aging management programs and the staff evaluation, as described in the GALL report, are applicable to their plant. The applicant would list those components, applicable aging effects, and aging management programs in a table. If the GALL report indicates that some of these aging management programs should be further evaluated, the applicant would provide the plant-specific proposal to augment these programs. For aging management programs and/or staff evaluation in the GALL report that do not apply or are otherwise different for their plant, the applicant would provide a plant-specific aging management review. Also, for components and/or applicable aging effects that are not addressed in the GALL report, the applicant would provide the plant-specific aging management review.In Chapter 4 of the application, the applicant would provide the time-limited aging analysis(TLAA) evaluation. Similar to aging management review in Chapter 3, the applicant would reference the GALL report as appropriate. For TLAAs that have been evaluated in the GALL report, the applicant would state that certain TLAAs and staff evaluation, as described in the GALL report, are applicable to their plant. If the GALL report indicates that further evaluation should be performed, the applicant would provide that additional information in the application.
For TLAAs that have not been evaluated in the GALL report or if the TLAA evaluation in the GALL report does not apply to the plant, the applicant would provide the plant-specific evaluation.Enclosure 1 22/3/00A summary description of all aging management programs and TLAA evaluations would beprovided in the final safety analysis report (FSAR) supplement.Staff Review GuidanceThe staff should not repeat its review of the matters described in the GALL report. The staffshould ensure that the material presented in the GALL report is applicable to the specific plant involved. For a particular system, the standard review plan for license renewal (SRP) should contain a summary table listing all the components, aging effects, and aging management programs, indicating whether the program is acceptable without change or should be further evaluated, as described in the GALL report. The staff would verify that the applicant has identified the appropriate programs as described and evaluated in the GALL report. The focus of the staff review would be on augmented programs for license renewal. The staff would also review information that is not addressed in the GALL report or is otherwise different from that in the GALL report. In addition, the staff would review the FSAR supplement based on the SRP.
32/3/00EXAMPLEContainment Spray System (part of the Engineered Safety Features). Note: This example is forillustration only.This example shows information in the license renewal application and the corresponding staffsafety evaluation report.
42/3/00Example: License Renewal Application3.3 Engineered Safety FeaturesThe Engineered Safety Features at Plant X evaluated in this application consist of: ....,Containment Spray System,....
....
The Containment Spray System provides borated water to reduce the temperature insidecontainment in accident conditions, as described in FSAR Section Y. The system consists of stainless steel and carbon steel components, such as piping, valves, pumps, and bolting, orifice, spray heads (see Table 2.Z in this application). The internal environment is borated water and the external environment is containment air. A review of the industry experience shows that stagnant portions of the containment spray stainless steel piping have experience cracking. However, this aging effect has not been observed at Plant X.
....
Based on a review of the system, components, materials, environment, applicable agingeffects, and operating experience, the information in the GALL report (Chapter V of Reference
- 1) regarding the Engineered Safety Features bounds Plant X. However, carbon steel piping and isolation valve in the Containment Spray System are not addressed in the GALL report and are evaluated in Sections 3.3.4.1 and 3.3.4.2 of this application.3.3.1 Aging Management Programs Evaluated in the GALL Report that Are Relied on forLicense RenewalThe following aging management programs and the staff evaluation for the Engineered SafetyFeatures, as described in the GALL report, are applicable to Plant X:GALL Item No.Aging Effect orMechanismAging ManagementProgramGALLRecommendationV.A.1.1 thru 1.3, ....Pitting and crevice corrosionInservice inspectionand water chemistry Further evaluation isrecommended (see Section 3.3.2.1 of this application)V.A.1.4, ....Corrosion/ boric acidwastage of external surfacesNRC Generic Letter88-05 and inservice inspectionNo further evaluationis recommended
....3.3.2 Further Evaluation of Aging Management as Recommended by the GALL Report3.3.2.1 Detection of Pitting and Crevice Corrosion 52/3/00The GALL report indicates that a one-time inspection of representative sample of the systempopulation and most susceptible locations in the Containment Spray System should be conducted to ensure that significant degradation is not occurring and the component intended function will be maintained during the extended periods.... For license renewal, Plant X is proposing ....3.3.3 Aging Management Programs or Evaluations that Are Different from those Described inthe GALL Report3.3.3.1 Aging Management Review of Stress Corrosion Cracking of Stainless Steel Piping andFittingsThe aging management program for stress corrosion cracking of stainless steel piping andfittings up to the isolation valve of the Containment Spray System (Item No. V.A.1.1 of the GALL report) at Plant X is different from that evaluated in the GALL report. Plant X....3.3.4 Components or Aging Effects that Are Not Addressed in the GALL Report3.3.4.1 Aging Management Review of Carbon Steel PipingPlant X....
3.3.4.2 Aging Management Review of Isolation Valve BodyPlant X....
3.3.5 FSAR SupplementThe proposed FSAR Supplement for the Engineered Safety Features is as follows:ProgramDescription of ProgramImplementation ScheduleWater chemistryprogramTo mitigate aging effects on internal surfacesthat are exposed to borated water as process fluid, chemistry programs are used to control primary water chemistry for impurities (chloride, fluoride, and sulfate) that accelerate
corrosion.Existing programOne-time inspectionof Containment Spray SystemTo verify the effectiveness of the chemistryprogram and to supplement the limited scope of leakage monitoring program, one-time inspection of internal surfaces of components (using visual inspection) at the most susceptible locations is performed to ensure that degradation is not occurring as a result of corrosion.... Program will beimplemented by ....
62/3/00Implementation ofNRC Generic Letter 88-05The program consists of: (1) visual inspectionof external surfaces that are potentially exposed to borated water for leaks, (2) timely discovery of leak path and removal of the boric acid residues, (3) assessment of the damage, and (4) follow up inspection for adequacy.Existing programInservice inspectionin accordance with ASME Section XI, as required in 10 CFR 50.55(a)The program consists of periodic visualinspection of external surfaces for signs of significant degradation and assessment of the damage and corrective actions. Existing program
....
72/3/00Example: Staff Safety Evaluation Report3.3 Engineered Safety Features
....3.3.3 Staff EvaluationIn Section 3.3 of the application, the applicant provided an aging management review of theEngineered Safety Features at Plant X. The applicant referenced the GALL report in its aging management review. The staff has previously evaluated the adequacy of aging management for license renewal as documented in the GALL report. Thus, the staff did not repeat its review of the matters described in the GALL report, except to ensure that the material presented is applicable to the specific plant involved and to verify that the applicant has identified the appropriate programs as described and evaluated in the GALL report. The staff further evaluated certain aging management programs as recommended in the GALL report. The staff also reviewed aging management information provided by the applicant that is different from that in the GALL report or not addressed in the GALL report.3.3.3.1 Aging Management Programs Evaluated in the GALL Report that Are Relied on forLicense RenewalThe staff has reviewed the application and determined that the applicant has provided theinformation necessary to adopt the finding of program acceptability as described and evaluated in the GALL report. The applicant has identified those aging effects for the Engineered Safety Features components that are contained in the GALL report as applicable to its plant. The applicant has identified the programs in the GALL report for the aging management of these components, and they are:GALL Item No.Aging Effect orMechanismAging ManagementProgramGALLRecommendationV.A.1.1 thru 1.3, ....Pitting and crevice corrosionInservice inspectionand water chemistry Further evaluation isrecommended (see Section 3.3.3.2.1 of this safety evaluation)V.A.1.4, ....Corrosion/ boric acidwastage of external surfacesNRC Generic Letter88-05 and inservice inspectionNo further evaluationis recommended
....The staff has verified that the applicant has identified the appropriate programs as describedand evaluated in the GALL report. Thus, it is acceptable for the applicant to reference the information in the GALL report and no further staff evaluation is necessary if so recommended in the GALL report.
82/3/003.3.3.2 Further Evaluation of Aging Management as Recommended by the GALL Report
....3.3.3.3 Aging Management Programs or Evaluations that Are Different from those Described inthe GALL Report
....
3.3.3.4 Components or Aging Effects that Are Not Addressed in the GALL Report
....
3.3.3.5 FSAR SupplementThe staff reviewed the proposed FSAR supplement for the Engineered Safety Features....
3.3.4 ConclusionsThe staff has reviewed the information in Section 3.3, "Engineered Safety Features," of thelicense renewal application. The staff evaluation concludes that the applicant has demonstrated that the aging effects associated with the Engineered Safety Features will be adequately managed so that there is reasonable assurance that these systems will perform their intended functions in accordance with the current licensing basis during the period of extended operation. The staff also concludes that the FSAR supplement contains an appropriate summary description of the programs and activities for managing the effects of aging for the Engineered Safety Features.
2/3/003.3Aging Management of Engineered Safety FeaturesREVIEW RESPONSIBILITIESPRIMARY-Branch responsible for materials and chemical engineeringSECONDARY-Branch responsible for mechanical engineeringI.AREAS OF REVIEWThis review plan section addresses the aging management review of the EngineeredSafety Features for license renewal. For a recent vintage plant, the information related to the Engineered Safety Features is contained in Chapter 6, "Engineered Safety Features," of the plant's Final Safety Analysis Report (FSAR) consistent with the Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (NUREG-0800). Engineered Safety Features consist of systems, such as Emergency Core Cooling System, Containment Heat Removal Systems, Containment Spray, and Control Room Habitability Systems.The staff has issued a Generic Aging Lessons Learned (GALL) report addressing agingmanagement for license renewal (Reference 1). The GALL report documents generically the staff's basis for determining when existing programs are adequate to manage aging without change and when existing programs should be augmented for license renewal. The GALL report may be referenced in a license renewal application and should be treated in the same manner as an approved topical report.Because a license renewal applicant may or may not be able to reference the GALLreport, the following areas are reviewed:A.Aging Management Programs Evaluated in the GALL Report that Are Relied onfor License RenewalThe staff should not repeat its review of the matters described in the GALLreport and should find it acceptable when the GALL report is referenced in a license renewal application. However, the staff should ensure that the material presented in the GALL report is applicable to the specific plant involved. The staff should also verify that the applicant has identified specific programs as described and evaluated in the GALL report.B.Further Evaluation of Aging Management as Recommended by the GALL ReportThe GALL report provides the basis for identifying those programs that warrantfurther evaluation during the staff review of a license renewal application. The staff review focus should be on augmented programs for license renewal.Enclosure 2 22/3/00C.Aging Management Programs or Evaluations that Are Different from thoseDescribed in the GALL ReportThe GALL report provides a generic staff evaluation of certain agingmanagement programs. If an applicant does not rely on a particular program for license renewal, or if the applicant indicates that the generic staff evaluation of the elements of a particular program does not apply to its plant, the staff should review the applicant's aging management programs.D.Components or Aging Effects that Are Not Addressed in the GALL ReportThe GALL report provides a generic staff evaluation of certain components andaging effects. If an applicant has identified particular components subject to aging management review for its plant, or if the applicant has identified particular aging effects for a component, that are not addressed in the GALL report, the staff should review the applicant's aging management programs.E.FSAR SupplementThe FSAR supplement summarizing the programs and activities for managingthe effects of aging for the period of extended operation is reviewed.II.ACCEPTANCE CRITERIAThe acceptance criteria for the areas of review define methods for meeting therequirements of the Commission's regulations in 10 CFR 54.21.A.Aging Management Programs Evaluated in the GALL Report that Are Relied onfor License RenewalAcceptable methods for managing aging of the Engineered Safety Features aredescribed and evaluated in Chapter V of the GALL report (Reference 1). In referencing the GALL report, an applicant should indicate that the material presented in the GALL report is applicable to the specific plant involved and provide the information necessary to adopt the finding of program acceptability as described and evaluated in the GALL report. An applicant may reference appropriate programs as described and evaluated in the GALL report.B.Further Evaluation of Aging Management as Recommended by the GALL ReportThe GALL report indicates that further evaluation should be performed for:
1.Detection of Pitting and Crevice CorrosionThe management of corrosion of pressure boundary components in theContainment Spray System. A one-time inspection is an acceptable method to verify the effectiveness of the mitigation and monitoring programs.
32/3/002.....C.Aging Management Programs or Evaluations that Are Different from thoseDescribed in the GALL ReportAcceptance criteria are described in Branch Technical Position 3.0-1.D.Components or Aging Effects that Are Not Addressed in the GALL ReportAcceptance criteria are described in Branch Technical Position 3.0-1.E.FSAR SupplementThe summary description of the programs and activities for managing the effectsof aging for the period of extended operation in the FSAR supplement should provide appropriate description such that later changes can be controlled by 10 CFR 50.59. The description should contain information associated with the integrated plant assessment regarding the bases for determining that aging effects are managed in the period of extended operation.III.REVIEW PROCEDURESFor each area of review, the following review procedures are to be followed:
A.Aging Management Programs Evaluated in the GALL Report that Are Relied onfor License RenewalAn applicant may reference the GALL report in its license renewal application, asappropriate. The staff should not repeat its review of the matters described in the GALL report. The staff should find it acceptable when the GALL report is referenced in a license renewal application, if the applicant has provided the information necessary to adopt the finding of program acceptability as described and evaluated in the GALL report. The reviewer verifies that the applicant has provided a brief description of the system, components, materials, and environment, and has stated that the particular plant is bounded by the GALL report. The reviewer also verifies that the applicant has stated that the applicable aging effects and industry and plant-specific operating experience had been reviewed by the applicant and are bounded by the GALL report. The reviewer verifies that the applicant has identified those aging effects for the Engineered Safety Features components that are contained in the GALL report as applicable to its plant. The reviewer reviews any outliers identified by the applicant.The applicant may state that certain aging management programs and the staffevaluation, as described in the GALL report, are applicable to its plant. The reviewer verifies that the applicant has identified the appropriate programs as described and evaluated in the GALL report. Programs evaluated in the GALL report regarding the Engineered Safety Features are tabulated in Table 3.3-1 of this review plan section. No further staff evaluation is necessary if so recommended in the GALL report.
42/3/00B.Further Evaluation of Aging Management as Recommended by the GALL Report1.Detection of Pitting and Crevice CorrosionThe reviewer reviews the applicant's augmented program to managecorrosion of pressure boundary components in the Containment Spray System. Aging management programs for the Containment Spray System include the chemistry program and the leakage monitoring program. However, the GALL report recommends further evaluation to verify the effectiveness of the chemistry program and to supplement the limited scope of the leakage monitoring program. An acceptable method is a one-time inspection as recommended in the GALL report. The reviewer reviews the applicant's proposed program. The program should consist of a one-time inspection of internal surfaces of components (using visual inspection) at the most susceptible locations is performed to ensure that degradation is not occurring as a result of corrosion.... 2.....C.Aging Management Programs or Evaluations that Are Different from thoseDescribed in the GALL ReportReview procedures are described in Branch Technical Position RLSB 3.0-1.D.Components or Aging Effects that Are Not Addressed in the GALL ReportReview procedures are described in Branch Technical Position RLSB 3.0-1.E.FSAR SupplementThe reviewer verifies that the applicant's FSAR supplement for agingmanagement of the Engineered Safety Features for license renewal is consistent with Table 3.3-2 of this review plan section. The reviewer also verifies that the applicant has provided FSAR supplement for Subsection III.C, "Aging Management Programs or Evaluations that are Different from those Described in the GALL Report," and Subsection III.D, "Components or Aging Effects that are Not Addressed in the GALL Report," of this review plan section using a format similar to that in Table 3.3-2.
52/3/00IV.EVALUATION FINDINGSThe reviewer verifies that sufficient and adequate information has been provided tosatisfy the provisions of this review plan section and the staff's evaluation supports conclusions of the following type, to be included in the staff's safety evaluation report:The staff evaluation concludes that the applicant has demonstrated that theaging effects associated with the Engineered Safety Features will be adequately managed so that there is reasonable assurance that these systems will perform their intended functions in accordance with the current licensing basis during the period of extended operation. The staff also concludes that the FSAR supplement contains an appropriate summary description of the programs and activities for managing the effects of aging for the Engineered Safety Features.V.IMPLEMENTATIONExcept in those cases in which the applicant proposes an acceptable alternative methodfor complying with specified portions of the Commission's regulations, the method described herein will be used by the staff in its evaluation of conformance with Commission regulations.VI.REFERENCES1.NUREG-??, "Generic Aging Lessons Learned (GALL) Report," ....
62/3/00TABLE 3.3-1: Aging Management Programs Evaluated in the GALL Reportfor Engineered Safety FeaturesGALL Item No.Aging Effect orMechanismAging ManagementProgramGALLRecommendationV.A.1.1 thru 1.3, ....Pitting and crevice corrosionInservice inspectionand water chemistry Further evaluation isrecommended (see III.B.1 of this review plan section)V.A.1.4, ....Corrosion/ boric acidwastage of external surfacesNRC Generic Letter88-05 and inservice inspectionNo further evaluationis recommended
....
TABLE 3.3-2: FSAR Supplement for Aging Management of Engineered Safety FeaturesProgramDescription of ProgramImplementation ScheduleWater chemistryprogramTo mitigate aging effects on internal surfacesthat are exposed to borated water as process fluid, chemistry programs are used to control primary water chemistry for impurities (chloride, fluoride, and sulfate) that accelerate
corrosion.Existing programOne-time inspectionof Containment Spray SystemTo verify the effectiveness of the chemistryprogram and to supplement the limited scope of leakage monitoring program, one-time inspection of internal surfaces of components (using visual inspection) at the most susceptible locations is performed to ensure that degradation is not occurring as a result of corrosion.... Program will beimplemented by ....Implementation ofNRC Generic Letter 88-05The program consists of: (1) visual inspectionof external surfaces that are potentially exposed to borated water for leaks, (2) timely discovery of leak path and removal of the boric acid residues, (3) assessment of the damage, and (4) follow up inspection for adequacy.Existing programInservice inspectionin accordance with ASME Section XI, as required in 10 CFR 50.55(a)The program consists of periodic visualinspection of external surfaces for signs of significant degradation and assessment of the damage and corrective actions. Existing program
....
NUCLEAR ENERGY INSTITUTE (License Renewal Steering Committee)Project No. 690
cc:Mr. Dennis HarrisonU.S. Department of Energy NE-42 Washington, D.C. 20585Mr. Ricard P. Sedano, CommissionerState Liaison Officer Department of Public Service 112 State Street Drawer 20 Montipelier, Vermont 05620-2601Mr. Douglas J. WaltersNuclear Energy Institute 1776 I Street, N.W.
Washington, DC 20006 DJW@NEI.ORGNational Whistleblower Center3233 P Street, N.W.
Washington, DC 20007Mr. Garry YoungEntergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 GSB-2E Russellville, Arkansas 72802Mr. James P. RiccioPublic Citizen's Critical Mass Energy Project 211 Pennsylvania Avenue, SE Washington, DC 20003Mr. Robert GillDuke Energy Corporation Mail Stop EC-12R P.O. Box 1006 Charlotte, NC 28201-1006Mr. Charles R. PierceSouthern Nuclear Operating Co.
40 Inverness Center Parkway BIN B064 Birmingham, AL 35242Carl J. YoderBaltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway NEF 1st Floor Lusby, Maryland 20657Chattooga River Watershed CoalitionP. O. Box 2006 Clayton, GA 30525Mr. David LochbaumUnion of Concerned Scientists 1616 P. St., NW Suite 310 Washington, DC 20036-1495Mr. Paul GunterDirector of the Reactor Watchdog Project Nuclear Information & Resource Service
1424 16 th Street, NW, Suite 404Washington, DC 20036