ML20033B824
| ML20033B824 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/16/1981 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML16340C113 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8112020304 | |
| Download: ML20033B824 (21) | |
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1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
3 DISCUSSION OF MAY 18, 1967 NEMO AND 4
SEISHIC REVERIFICATION PLAN FOR DIABLO CANYON 5
6 PUBLIC NEETING
^
7 Nuclear Regulatory Commission Room 1130 8
1717 H Street, N.W.
Washington, D.C.
9 Tuesday, November 10, 1981 10 The Commission me t, pursuant to notice at 11 1.44 p.m.
12 BEFORE:
13 NUNZIO PALLADINO, Chairman of the Commission VICTOR GILIHSKY, Commissioner 14 PETER BRADFORD, Commissioner JOHN AHEARNE, Commissioner 15 IHOM AS ROBERTS, Commissioner 18 STAFF PRESENT:
17
- 5. CHILK, Secretary L. BICKWIT, General Counsel 18 W.
DIRKS H. DENTON 19 R. FALKENBERRY R. DE YOUNG 20 F. REMICK R. JACKSON 21 J. DEVINE R. TADESCO 22 23 24 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
2 1
EE9CEEDLEGH 2
(1:44 p.m.)
3 CHAIRMAN PALLADINO The meeting will please come 4 to order.
5 The subject of today's meeting is discussion of 8the May 18th, 1967 memo and seismic reverification plan for 7 Diablo Canyon.
The discussion of the May 18th, 1967 meno 8 will be an open meeting, and the rest of the meeting then 9 will be closed for Commission discussion.
to Now, at this time I understand the staff is 11 prepared to discuss the May 18th, 1967 memo, and I suggest 12 we proceed.
13 MR. DIRKS:
We ha ve several staff people here, Mr..
14 Chairman.
We have Dr. Jackson from NOOR who is prepared to 15 talk about the subject.
We have Mr. James Devine from the 18U.S. Geological Survey who.is sitting in the area there who 171s also prepared to review the seismic followup on the 18 sit e.
And we have from the NRR staff Mr. Bob Tadesco who 19could discuss some of the historical aspects of this memo.
20 Would ycc like to proceed first with the 21 substantive part of the issue with Dr. Jackson, and then we 1
22 can follow up with Mr. Iadesco?
23 CHAIRMAN PALLADINO:
Is the historical background 24 necessary to understand the substance?
25 MR. DIRKS:
I think it would be important to get ALDERSON REPORTING COMPANY. INC.
400 vtRGINIA AVE., S.W., WASHINGTON. D.C. 20024 e 202) 554-2345
3 l into the substance of the issue first, and then we could 2 follow it up with questions.
3 DR. JACKSON:
Since being made aware of the need 4 to discuss this meno a short time ago, we have gone back and 5 primarily talked to the U.S. Geological Survey as to their 6 recollection of wha t transpired at the time just before the 7 meno was written and shortly thereaf ter.
And basically Mr.
8 Devine can discuss that.
9 From the staff's point of view and geoscientists' to point of view we have looked back, and there were a number 11 of episodes of mapping, geologic mappings.
It boils down to 12 about three phases of geologic mapping:
those that were 13 done on the seacliff exposures prior to the site being 141oca ted there; extensive trenching across the plant area:
15 and the actual mapping of the excavation for the plant 16 structures.
17 And our perception is and understanding of the 18 menos is basically the way a geologist would approach the 19 problem:
as you look at all of the available information 20 that you have that you make a deter =ination on that, and you 21 would then pursue or not pursue depending on your best 22 judgment the need for f urther trenching and further 2
23 excavations.
24 It is our best understanding in looking back at 25 this and from what we know of the site since that time that ALDEP5cN REPORTING COMPANY,INC.
400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
4 1 basically there was confidence by the geologists, the review 2 geologists at the U.S.G.S.,and geologists who have reviewed 3 that plan since then that these faults were old in terms of 4 the criteria that were being proposed at the time, and there 5 was no further need for specific additional trenching of 6that feature in particular.
7 It turns out that during the excavation of the 8 plant structures the f ault that is in question was 9 apparent'.y intersected in the plant. structure and mapping 10 program.
After mspping Unit 1 excavation, two minor faults 111n the northern part of the excavation wero interpreted to 12 be part of this fault zone, and therefore, the f ault was 13 interpreted to die out as it approached the site f rom the 14 seac11ff exposure.
15 Our best understanding is that the faulting 16 occurred somewhere between 15 million years ago and 80 to 17 120,000 years ago, and the best estima te is tha t the actual 18 movement on these faults took place in what is called the 19 Pliocene or Lower Pleistocene time, which is more than a 23million years ago.
21 And basically that is a summary of what I have.
22 MR. DEVINE4 My comments are more on the attitude 23 of the people involved and the specifics.
I personally have 24 been involved in the site since July of
'67, shortly after 25 the meeting that these notes came from; so I have known Mr.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554 2345
5 1 Murphy and Dr. CGiter, who are both mentioned in the meno, 2 personally and directly on this case since that time.
I 3 talked with Dr. Colter la st week about this circumstance.
I 4 So my comments come from both of those sources:
my own 5 personal experience and my recent conversation with Dr.
6 Cciter.
7 And his comments were and my belief is that the 8 excavations, the trenching that was done as a result of 9 earlier questions did indeed reflect minor faulting in the 10 trenching, but no evidence of displacement in the upper 111ayer which is the 80 to 120,000 layer.
12 That question was looked at extensively by Dr.
13 Colter and Dr. Yerkes of the Geological Survey, and they 14 both recalled the field trip vividly, and indicated to me 15 that their opinions today are as they were at that times 16 that there was minor f aulting.
It was not capable faulting 17 as there was no evidence of the upper layer being displaceds 18 and they know nothing in the intervening years that would 19 cause them to change tha t position.
20 As for any attitudes about what additional work 21 should be done, there was a strong feeling on the part of ZZthe Survey at that time after having been through a few 23 other cases where capable faulting was a major issue, they 24 were highly sensitized to the q uestion.
And it was after 25 considerable thought on their part that they agreed with Dr.
ALDERSoN REPORTING COMPANY,'NC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.",, 20024 (202) 554 2345
6 1 Johns that additional trenching was not necessary, as indeed 2 it would raflect more of the same that they had already seen.
3 Hy own personal involvement came as a seismologist 4 as a result of the o values that were discussed in the same 5 meno.
But I do know over tue years of talking with Dr.
6 Colter there was no hint that something more should have 7 been done.
8 COMMISSIONER AHEARNE:
Jim, it mentions in the 9 meno "significant f ault exposed at the seawall," and goes cn 10 to say, "In Dr. Johns' opinion this larger fault does not 11 run through the site but probably passes to the northwest."
12 Is there any possibility that tha t f ault line 13 connects up with the Hosgri f ault?
14 NB. DEVINE:
I guess the possibility would not be 15 zero, but the probe.bility was certain to be quite low.
As 16 you know, there was extensive seismic profiling immediately 17 off shore to try to hook up f a ulting with the Hosgri, and it 18 would be my judgment that that would most likely have been 19 found if it indeed really hooks up with the Hosgri; and 20 there is no evidence that it has been found.
So my guess is 21 the probability would be very low that that could happen.
22 CHAIRMAN PALLADINO:
Was there any documentation 23 around that time that reflects the opinions you are giving 24 now ?
Are you aware of any, Jim?
25 MR. DEVINE:
Yes, sir.
There was a letter written ALDERSoN REPORTING CCMPrNY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554-2345
7 1 by the Geological Survey that was enclosed in the SER at the 2 time which states in writing our position on that.
3 CHAIRMAN PALLADINO What gives a number of us 4 problems is that af ter, well, reading a couple of sentences 5 here from the memo, it says, "It was estnblished that if the 6 containment were relocated te mo'.e it of f the small f aults, 71t would probably lie on similar faults in the new 81ocation.
Thus, Dr. Johns concludes that the present 9 proposed location is adequate.
They do not intend to do 10 further trenching at the risk of uncovering geologic 11 structures which could lead to additional speculation and 12 possibly delay the project."
13 That is reason to raise a little bit a concern 14 saying they just didn't want to find out what they were 15 af raid they might find out.
16 HR. DENTON:
Mr. Chairman, after the memo came to 17 my attention we did look back at all of the infornation, and 18 we contacted the people that were involved.
For whatever 19 the reasons that the company adranced that logic, I can find 20no indication that that influenced the decision of the staff 21 and the Survey.
22 The decision is well-documented based on geologic 23 inf orma tion.
It's been followed up two or three times.
24 !t's even been covered in one hearing.
And it was a choice 25 of words that must have reflected what was said at the ALDERSoN REPORTING COMPANY, ;NC.
400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345
8 1 tim e.
But as you well know, the Survey has long had a 2 reputation for independence about that, and about that same 3 time frame rejected one site in California where they were 4 concerned.
So I don't find any bcsis for thinking that 5 staff 's influence was influenced at all other than on the 6 geologic difference.
7 CHAIRMAN PALLADINO:
Do we have at hand -- you say 8 the letter that you issued about that time is in the FSAR, 9 or where did you say it was?
10 MR. DENTON:
Mr. Bob Tadesco.
11 ER. TADESCOs Mr. Chairman, Bob Tadesco of the 12 staff.
13 Appended to our SEB which issued in 1968 was a 14 report f rom the Department of the Interior Geological 15 Survey.
That did indicate the report from the Geological 16 Survey, acknowledging their evaluation of the exploratory 17 tranches that they had examined in 1966.
l 18 CHAIRMAN PALLADINO:
Are you saying then, and we 19 would include in the record the fact that this statement did 20not influence the staff decisions on this plant, and that 21 you relied on the USGS assessment as included in the SER as 22 a basis for proceeding with this plant at this site?
23 Did I put words in your mouth?
24 MR. DENTON:
Well, at that time I'm not sure the 25 staff had any geoloqists on the staf f, and we relied almost ALCERSoN REPORTING COMPANY,INC, 400 WGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
9 1 completely on the Survey, and the Survey had had a lot of 2 experience with the siting of power plants in California.
3 And I have read the reports that were produced by the Surv*1 4 both before and af ter that report, and I am confident that 5Dr. Colter was not influenced by whatever review was 6 advocated at that meeting.
7 HR. DEVINE:
I would like to put on the record 8 that I asked Dr. Colter that directly, and he indicated that 9 there was no way in influence as described in that 10 sen tence.
The reason for asking f or additional f aulting was 11 the strong belief that indeed similar structures as already 12 discovered would be found, but no hint that you could find 13 structures more severe than was already uncovered.
14 CHAIREAN PALLADINO:
This was a concern with 15 regard to that site.
16 COMMISSIONER BRADFORD:
That statement is directly 17 contrary to what.the memo itself says.
I can understand 18 that anybody 's memory would be f uzzy back to
'67.
Mine l
l 19 certainly is.
But I would be pretty hesitant to take 20 someone 's memory today over a record that was made at the 21 tim e.
1 22 MR. DENTON:
I don't think it's just that.
It's t
23 also looking at the geological basis here.
The area is 24 f aulted.
There are a lot of faults in that area, and they j
25 are all old.
It has been looked at when Unit 2 was dug, and I
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W., WASHINGTON. 0.C. 20024 (202) 554-2345
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10 l it is not as though -- as Bob Jackson said originally, there 2 are the seawall exposures.
There's the trenching that was 3 done.
Th'at was the best trench reactor site at the time.
I 4 think there was over half a mile of trenching done.
And 5 then as they dug the foundations for the plant, they exposed 8other faults that were available, and all of those showed 7 the same geologic structure and dates.
8 COMMISSIONER BRADFORD:
The memo says, "It was 9 suggested that the exposed fault of the seawall be traced by to further trenching."
Does anyone recall suggested by whom?
11 Was that an AEC suggestion, a USGS suggestion?
12 MR. DENTONs Since we didn 't have any expertise at 13 the time, I don't know who would have brought that one out.
14 CHAIREAN PALLADINO What page are you reading 15 from ?
18 COMMISSIONER BRADFORD:
It's the sentence right 17 after the one you were reading from.
Somebody at that 18 meeting suggested that further trenching might be desirable.
19 CHA~RMAN PALLADINO It's not clear from this.
20 DR. JACKSONs I would add a comment that from many 21 meetings I have been involved in as a geologist I think 22 trenching in this type of environment would always be asked 23 f o r; in f ac t, as much as you can get, as often as you can 24 get it.
And this had an extensive amount of trenching for 25 tha t time f rame.
In fact, I think there's been little more ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
11 1fone.
2 What a geologist does when he's looking at this 3 kind of information is try to make a value decision as to 4what return you may get on that additional trenching.
5 COMMISSIONER BRADFORD:
Okay.
The part that 6 troubles me, I think it's the part that troubled the 7 Chairman as well when he came across the two sentences 8 bef ore, is the next sentence cars, "The applicants said ther 9 did not believe that this was riecessary."
to Okay.
Fair enough.
That's the point that you're 11 aaking.
"And that further information of this type would 12 only complicate a contested hea ring. "
i 13 Now, if you are so sure that all of the additional,,,_
14 inf ormation would be f avorable and would confirm that there-15 was no f aulting of concern, why would the public hearing be 16 complicated?
Why wouldn't the public hearing be simplified?
17 HR. DENTON4 Bear in mind the applicant was saying 18 tha t supposedly, not the staff; and I don't know why he said 19 t h a t.
Our people wrote it down.
20 COMMISSIONER BRADFORDs The inference it invites 211s one that was suggested before which was that they didn't 22 have reason to be a hundred percent confident that the 23 result of further trenching would confirm what they have.
24 MR. DENTON:
I quess I come back, I know of no 25 more independent ;eological advice in the Survey in th a t ALDERSoN REPORTING COMPANY. INC.
400 VIRGINIA AVE, S.W WASHINGTON. D.C. 20024 (202) 554-2345
12 1 time f rame.
~
2 COMMISSIONER AHEARNE:
Was any further trenching 3 done?
4 ER. DENTON:
Yes.
Well, let me qualify that.
5 Now, trenching is only one of several ways to understand the 6 area, so every time they ext.avated for another plant -- ther 7 did Unit 1, they did Unit 2; I think they even trenched some 8 more bef ore Unit 2 was allowed -- so there was a lot of 9 geologic work, all of which confirms the kind of 10 understanding that Dr. Jackson and I said exists for that 11 site.
12 COMMISSIONER AHEARNE:
But as far as you know, was 13 there any work done that flowed from these concerns Isised?
14 5R. DENTON:
Let me go back to the only historical 15 memory, Bob Tadesco.
16 MR. TADESCO:
It's hard to recollect back to that 17 tim e, but they had a review of the memo in the report, so we 18 had to file it.
And it talked about the adeqaacy of the 19 trenching plus the additional trenching done at Unit 2 in 20 the report of the Survey.
That is what we relied on.
21 COMMISSIONER AHEARNE:
As far as the Survey knows,
22 there was no additional work done.
23 HR. DEVINE:
Not to my knowledge.
24 COMMISSIONER BRADFORD:
Has there been a complete 25 file search on our part or on the Survey's part with regard ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345 i
13 1 to this?
2 MR. DENTvN:
I wouldn't say complete, but we have 3 searched our files.
Are you fishing for problems or do you 4 think that there are some there?
We have looked, we have 5 talked to everyone involved, and we can't find any basis for 8 thinking these faults are anything but old faults.
I 7
COMMISSIONER AHEARNE:
But the difficulty is we 8 have a meno.
The memo reports a meeting, and obviously it 9 is a mee ting that occurred over 14 years ago; and so 10 unf ortunately, memories are coing to be probably very poor 11 sources of information.
So you have to rely as best you can 12 on whatever written information is available, and the 13 written information indicates a concern about doing f urther.
14 exploration because it could delay the project and 15 complicate a contested area.
18 Now, I have no way of knowing who raised those 17 objections or concerns, but at least at the moment it sounds
)
1811ke whoever raised them was successful in the argument.
19 MR. DENTON:
Well, I don't want to be defensive 20 about this.
When we got the memo called to our attention we 21 relooked, and I think we have told you all that we can tell 22 rou toda y about this, other than going back and retrenching 23 f rom start.
We have sought out th e people, and have them 24 here, who have the best corporate and geologic memory of i
I 25 that site.
i r
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE S.W WASHINGTON D.C. 20024 (202) 554-2345 l
1
q 14 005.1ISSIOtlER BRADFORD:
But as f ar as you know, in 1
2 fact the fault from the seawall never was trenched in the 3 way suggested here; that is, followed to its end to see how
- close it came to the plant in what form?
5 DR. JACKSONa What I tried to indicate is our best 6 understanding, that it was a feature picked up on the 7 mapping of Unit 1 which was interpreted to be part of that 6 fault extending toward the site.
9 I might add from a geologic point of view the 10 seac11ff is the best trench you could ever have as a natural 11 exposure which has natural weathering and weathering 12 properties that you don't have in a trench which is 13 excavated.
It is the best exposure you can have.
14 So being a geologist, you put a lot of faith in 15 that particular trench.
And I think one of the things I 16 tried to mention bef ore was that as you proceed, if this 17 trench offset or in the seacliff you noticed geologic 18 conditions which would leave you suspicious, you would have 19 no choice but to trench and to follow it up further.
20 In this case it is my judgment that what was done 21 they evaluated all of the evidence, and they would look, for Zzinstance, at air photographs of the so-called terrace units 23 and see if there were any indications or possibilities that 24 tha t f ault could project in that direction and offset the 25 other ma terial and decide to trench or not to trench.
ALDERSON REPORTING COMPANY, INC, 400 VIRGINTA AVE, S.W WASHINGTON, D.C. 20024 (202) 554-2345
15 1
COMMISSIONER BRADFORD:
I appreciate what you say, 2 and I don't have any basis for doubting it other than this 311nguage in here about the extent to which further work 4 might cause further problems.
5 Given the situation as you have described it, it 6 sounds as though f urther work would only have increased the 7 certainty for people.
What is troubling me is that people 8 seem to say if we learn more, it is going to weaken our 9 case.
That is the opposite of the situation you described.
10 DR. JACKSON:
I understand.
I've been interested 111n trenching for many years.
Trenching was not really done 12 routinely; in fact, it has evolved as a result of the 13 nuclear power plant siting, the use of trenching to identify 14 active f aulting.
15 And I think what has happened, there was an
- 16. evolution th rough time of the dependency on this 17 methodology, and tha t stemmed f rom the U.S.
Geological 18 Survey and the support that the NRC or AEC at that time gave 19 to that aspect of the study.
20 So I think it was -- my judgment would be tha t it 21 was an evolving approach.
There was an extensive amount 22 done here and a judgment made by the geologists at that time 23 that said that there's a certain amount beyond which you get 24 dimir t shing re tu rn s.
25 I might make one comment from the complication ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554-2345 i
16 1 point of view.
There's no doubt complication could mean 2 many things.
It may mean to me as a geologist that what you 3 have is more trench logs, more arguments about age dates of 4 the particular material, and complicated.
It may be more 5 certain in the end that it adds another element to the 6 review; so complicated may not mean complicating the 7 hearings in terms of the difficulty issue, but complicated Sin terms of the geologic aspect.
9 MH. DENTON:
I would suggest that for a more 10 further look you would have to go back and interview more 11 parties than we have been able to since this came to our 12 attention.
We vill try to figure out what was behind these
.n 13 statements and recreate that.
14 We tended to work internally.
We have not gone 15 back to the company.
And we talked to the people who either 16 worked for the AEC at the time or worked for the Survey at 17 the time.
18 CHAIRMAN PALLADINO:
Ba.ced on the SER or the l
191etter contained f rom the USGS in the SEH, do you believe 20 that you proceeded in a proper and effective way with regard j
21 to these particular f aults, and you were not influenced by l
22 the concern that further trenching should be avoided because Z31t might give unanticipated problems?
24 MR. DENTON I've never known the Survey to be 25 influenced by any potential problems it might raise.
They ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
17 I
1 give us their best scientific advice, and that has been my 2 experience in working with them.
3 COMMISSIONER AHEARNE:
Jim, do you have anything?
4 MR. DEVINEs Yes.
If I could make one more 5 comment, if I.could, on that very point.
6 Ihis site particularly I think the record shows 7 that we have not in the Survey at any time been hesitant to 8 reopen the case.
As you know, the last five years has been 91ar gely, as a result of our involvement in the increase of to the earthquake sites and so forth, I think it is important 11 to recognize that we have never felt an obligation to do 12 other than provide the best geologic advice and let the 13 chips f all where they may.
And I think our record is quite 14 strong in this case for just that.
15 COMMISSIONER AHEARNE:
So, Jim, I gather your 18 conclusion is that this memo has not led you to be uneasy 17 about the Geologic Survey's position.
18 HR. DEVINE:
My feeling is the memo is a 19 misstatement of our position as f ar as it implying that more 20 data would cause more trouble.
I think that is a 21 misstatement from our attitude.
22 CHAIRMAN PALLADINO:
Any other questions?
23 Well, that comple tes the first pa rt of the meeting.
24 COMMISSIONER BRADFORD:
Joe, excuse me for one 25 thing.
Perhaps I had just not been reading the memo closely ALDERSoN REPORTING COMPANY,INC, 400 vlRGINIA AVE., S.W., WASHINGTON. 0.C. 20024 (202) 554 2345
18 1 enough.
I had not taken it to state a USGS position at alla 2 that is, the part that the Chairman and I both quoted is 3 steributed to -- I don 't know if it's attributed to anybody 4 -- to a Dr. Johns who is a consultant to the applicant.
5 What did you have in mind with regard to the USGS 6 position ?
7 MR. DEVINE:
The last sentence of the letter says, 8 "Dr. Colter agrees with the statement and findings made by 9 Dr. Johns."
10 COMMISSIONER BRADFORD:
I see.
I took that to be 11 with regard to the geology itself, not a policy issue.
12 MR. DEVINE:
It is ambiguous, what it does mean.
13 COMMISSIONER BRADFORD:
Your point is you would 14 not have been endorsing the statement with regard to 15 hearings.
16 MR. DEVINE:
That's true.
17 CHAIRMAN PALLADINO:
Any other comments or 18 questions on this subject?
19 2e will now proceed to further discussion of the 23 seismic reverification plan for Diablo Canyon, and as the 21 committee voted, this will be a closed meeting.
So at this Z2 time we will take a recess while members of the public --
23 MR. DIRKS:
Do you want to go into the proposed 241ette r?
25 MR. BICKWIT:
The Commission decided it wanted to ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON. 0.C. 20024 (202) 554 2345
19 1 close the remaining portion of this discussion.
2 CHAIRMAN PALLADINO:
Because there were a number 3 of items that certainly related to frustration of purpose, 4 and we want to be free to discuss it.
5 He will recess for a few minutes while visitors 6are allowed to leave.
7 (Whereupon, at 2:10 p.m.,
the open session of the 8 meeting was adjourned.)
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) 554-2345
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