Capitol Power Plant Utility Tunnels (16-NOV-06, GAO-07-227R).	 
                                                                 
The Architect of the Capitol (AOC), through the Capitol Power	 
Plant (CPP), operates five walkable utility tunnels containing	 
steam and chilled water pipes associated with serving the heating
and cooling requirements of the U.S. Capitol and 23 surrounding  
facilities. The tunnels also carry other utilities, such as fiber
optic and telephone lines. The Office of Compliance (OOC), which 
is responsible for advancing safety, health, and workplace rights
in the legislative branch, and the tunnel workers have raised	 
concerns about health and safety issues in the tunnels. 	 
Specifically, in March 2006, the utility tunnel workers sent a	 
letter to Congress complaining of unsafe working conditions in	 
the tunnels, including falling concrete, asbestos, and extreme	 
heat. In February 2006, OOC filed a complaint against AOC	 
concerning hazards in the tunnels, including falling concrete, an
inadequate communication system for these confined spaces, and	 
inadequate escape exits. According to OOC officials, these	 
conditions had been previously brought to the attention of AOC by
OOC inspectors as early as 1999. Following a reinspection in	 
mid-2005, OOC determined that AOC had not made sufficient	 
progress in addressing them and that conditions in the tunnels	 
had deteriorated further. In addition, in January 2006, OOC	 
issued citations for and asked AOC to address a potential	 
asbestos hazard and heat stress conditions. In light of these	 
concerns, Congress asked us to review the condition of the	 
tunnels. Accordingly, we examined (1) the current condition of	 
the tunnels, (2) AOC's plan for making repairs and improvements  
to the tunnels, and (3) the responsiveness of AOC's plan to the  
issues raised by OOC and the tunnel workers.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-227R					        
    ACCNO:   A63510						        
  TITLE:     Capitol Power Plant Utility Tunnels		      
     DATE:   11/16/2006 
  SUBJECT:   Inspection 					 
	     Protective equipment				 
	     Public utilities					 
	     Repairs						 
	     Safety regulation					 
	     Safety standards					 
	     Strategic planning 				 
	     Occupational safety				 
	     Capitol Power Plant (DC)				 
	     AOC Utility Tunnel Improvement Plan		 

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GAO-07-227R

November 16, 2006

The Honorable Wayne Allard

Chairman

The Honorable Richard Durbin

Ranking Minority Member

Subcommittee on the Legislative Branch

Committee on Appropriations

United States Senate

The Honorable Jerry Lewis

Chairman

The Honorable David Obey

Ranking Minority Member

Committee on Appropriations

House of Representatives

Subject: Capitol Power Plant Utility Tunnels

The Architect of the Capitol (AOC), through the Capitol Power Plant (CPP),
operates five walkable utility tunnels1 containing steam and chilled water
pipes associated with serving the heating and cooling requirements of the
U.S. Capitol and 23 surrounding facilities. The tunnels also carry other
utilities, such as fiber optic and telephone lines. The Office of
Compliance (OOC), which is responsible for advancing safety, health, and
workplace rights in the legislative branch, and the tunnel workers have
raised concerns about health and safety issues in the tunnels.
Specifically, in March 2006, the utility tunnel workers sent a letter to
Congress complaining of unsafe working conditions in the tunnels,
including falling concrete, asbestos, and extreme heat. 2 In February
2006, OOC filed a complaint against AOC concerning hazards in the tunnels,
including falling concrete, an inadequate communication system for these
confined spaces, and inadequate escape exits. According to OOC officials,
these conditions had been previously brought to the attention of AOC by
OOC inspectors as early as 1999. Following a reinspection in mid-2005, OOC
determined that AOC had not made sufficient progress in addressing them
and that conditions in the tunnels had deteriorated further. In addition,
in January 2006, OOC issued citations for and asked AOC to address a
potential asbestos hazard and heat stress conditions. In light of these
concerns, you asked us to review the condition of the tunnels.
Accordingly, we examined (1) the current condition of the tunnels, (2)
AOC's plan for making repairs and improvements to the tunnels, and (3) the
responsiveness of AOC's plan to the issues raised by OOC and the tunnel
workers.

1The tunnels are not identified by name in this report for security
reasons.

2On October 18, 2006, the utility tunnel workers filed a whistleblower
complaint against AOC alleging that they were retaliated against after
they informed Members of Congress about the conditions in the tunnels.

To report on the condition of the tunnels, we reviewed various reports on
the condition of the tunnels from 2000 to the present, viewed videotapes
of the tunnels, hired a mechanical engineer to tour the tunnels, and
interviewed tunnel workers and other AOC staff. To assess AOC's plans for
making repairs and improvements, we reviewed the August 31, 2006, Utility
Tunnel Improvement Plan that AOC submitted to Congress and various
projects that AOC initiated to implement this plan; interviewed AOC
officials; and attended weekly AOC meetings at CPP on the repair efforts
in the tunnels. Generally, it is our policy not to address issues in
litigation. Thus, given the ongoing complaint and negotiations between OOC
and AOC regarding the concerns identified in the tunnels, we did not
address whether issues identified in the complaint or the actions taken by
AOC complied with legal standards. To understand the concerns that had
been raised and the status of the concerns, we interviewed the tunnel
workers and officials from both AOC and OOC. We also compared the plan
with the concerns that had been raised. Furthermore, in accordance with
our policy, we did not address concerns the tunnel workers have raised in
its recent whistleblower complaint.

This report is based on information gathered through October 2006, and AOC
is continuing to work on solving the problems in the utility tunnels. We
did not conduct an audit: We performed our work to assist Congress in
considering the future needs of the Capitol Power Plant Utility Tunnel
System. We requested comments on the draft of this letter from AOC and
OOC.

Results in Brief

AOC has started to address problems in the tunnels, but their condition
remains substantially unchanged--that is, the conditions OOC cited as
hazardous remain. For example, AOC has installed supports in some areas of
one tunnel to minimize the potential for falling concrete and has required
individuals entering the tunnels to wear protective equipment and clothing
to shield them from potential asbestos exposure. In addition, AOC is
working toward removing the delaminated concrete and cleaning the tunnels,
so that the exhaust fans can be turned on to reduce the temperature in the
tunnels.3 An AOC contractor has completed assessments of three of the
tunnels and determined that they are not in danger of collapse. The
contractor is still assessing the two remaining tunnels and expects to
complete these assessments by December 31, 2006. Most other AOC efforts
are in the study, planning, or procurement stage. As a result, the
potential for falling concrete, asbestos exposure, excessive heat, poor
communications, and inadequate escape procedures continue to pose
problems.4 Progress in resolving the problems in the tunnels has been
hindered because the tunnel conditions that AOC and its contractors are
trying to address make it difficult to work in the tunnels.

3Delaminating concrete is concrete that is separated from the steel
reinforcing and is in danger of falling from the wall or ceiling.

4The hot working conditions in the tunnels throughout the year are a
result of the heat given off by the steam pipes in an enclosed area. The
heat is not related to seasonal changes in temperature.

AOC issued its Utility Tunnel Improvement Plan on August 31, 2006, as
directed by the House Committee on Appropriations, but the plan is
incomplete, in part because AOC has not completed its assessment of the
tunnels. In a June 1, 2006, House report,5 the House Committee on
Appropriations directed AOC to provide to the committee "a plan and budget
that strategically addresses long term repairs to the steam tunnels."
Combining the information it currently has on the condition of the
tunnels, AOC categorized the tunnel projects into immediate and short-term
repairs that it estimates will cost about $119 million over the next 6
years. AOC identified another $14.4 million in longer-range initiatives to
mitigate the known problems in the tunnels. Such initiatives include
conducting quarterly structural inspections and making necessary annual
repairs. The plan does not contain an analysis or discussion of options
for addressing the immediate and short-term needs of the tunnels, as
called for in the House report. AOC does indicate in the plan that it will
conduct an alternatives study to evaluate the long-term use of the
existing tunnels and options for meeting the Capitol Hill Complex's future
utility distribution needs. AOC recognizes that the current plan does not
fully respond to the questions raised in the committee's report. According
to AOC officials, AOC could not complete the work necessary to respond to
all of the requested information in the time allotted. But without
information on options and recommendations for addressing tunnel problems
and future utility distribution needs, Congress does not get a full
picture of the potential solutions to the tunnel problems and their costs.

AOC and OOC are working cooperatively to resolve the health and safety
concerns in the utility tunnels, but the slow progress of the work has
left the tunnel workers frustrated. To settle OOC's January 2006 citations
and February 2006 complaint, AOC and OOC are exchanging proposals and
discussing ongoing technical issues. OOC has been reviewing AOC's utility
improvement plan. While AOC's plan covers the issues raised by the OOC and
the tunnel workers, limited work has been completed to date and the
workers have no clear picture of when the work will be done. To improve
communication, AOC began holding weekly meetings with the tunnel shop
workers in April 2006 to discuss tunnel issues and the actions being
taken.

Background

CPP, which is managed by AOC, is located in Washington, D.C., at New
Jersey and E Streets, Southeast. It is the central heating and cooling
plant that provides steam, chilled water, or both, year-round for about 16
million square feet of space in 24 facilities.6 Steam is used for comfort
heating, heating domestic hot water, cooking, and humidification. Chilled
water is used for comfort and equipment cooling.

CPP consists of four main facilities: the steam plant, the East
Refrigeration Plant, the West Refrigeration Plant, and administration
buildings. The plant also includes a coal yard south of the power plant.
CPP's distribution infrastructure consists of approximately 2-1/2 miles of
walkable utility tunnels containing steam pipes, chilled water pipes, and
other utility services, such as fiber optic and telephone lines for CPP
customers. Access to the utility tunnels is provided through various
manholes and tunnel entrances in buildings. In addition, some steam and
chilled water pipes are buried in more than a half mile of covered
trenches. Access to the buried utilities is through manholes. The walkable
tunnels were built at various times--one in 1908, two in the 1930s, and
two in the 1950s.

5H.R. Rep. No. 109-485, at 21-22 (2006).

6CPP provides chilled water to 19 of the 24 facilities and steam to 24
facilities. Five of the buildings are not part of the Capitol Hill
Complex; however, they are served by CPP and are billed for services
provided.

In 2000, an AOC contractor reported that its study of the walkable utility
tunnels indicated deterioration of the tunnel structure due to, among
other things, aging and failure of the waterproofing system. According to
the contractor, the deterioration was rapidly advancing in some sections
and required immediate attention, and the tunnels posed a danger to worker
safety, especially from delaminating concrete in the tunnel roofs that
could fall without warning. On December 7, 2000, OOC's General Counsel
issued a citation for unabated hazards in the tunnels--falling concrete,
an inadequate communication system, and inadequate escape exits from these
confined spaces. In 2005, OOC inspected the tunnels and determined that
AOC had not made sufficient progress in addressing the previously
identified hazards; OOC also identified additional concerns. As a result,
in January 2006, OOC's General Counsel issued two more citations--one for
an asbestos hazard and one for a heat stress hazard--and asked AOC to
address them. In addition, on February 28, 2006, OOC's General Counsel
issued a complaint stating that AOC had not taken sufficient action to
address the problems identified in the December 2000 citation.

Since OOC's initial citation in December 2000, AOC has reported taking
some actions to address some of the problems in the tunnels, including the
following:

           o In 2001, AOC contracted with the Federal Occupational Health
           (FOH) to assess the condition of asbestos in the entire CPP,
           including the tunnels.7 FOH found that the asbestos in the tunnels
           was generally in good condition--that is it was not damaged or
           exposed.8 
           o In 2004, AOC replaced 600 feet of the roof in one tunnel in
           response to the 2000 contractor's report on tunnel conditions.
           o In 2004, AOC began another project to upgrade 15 tunnel entry
           and exit points.
           o In 2005, AOC removed asbestos from one of the tunnels.9

In addition, since 1999, AOC's Construction Management Division has been
working to identify and remove developing spalls10 and has recently
increased its efforts to identify and remove any spalling concrete.

7FOH is a component of the United States Public Health Service within the
Department of Health and Human Services.

8According to OOC officials, FOH's finding is inconsistent with OOC's
observations in the tunnels.

9According to an AOC official, AOC has determined that there is still some
asbestos in the far end of this tunnel.

10A spall indicates an area of concrete delamination that may expose the
existing reinforcing steel in the tunnel structure.

Condition of the Utility Tunnels Remains Substantially Unchanged

AOC has taken some steps to mitigate problems in the tunnels and has
initiated some actions to resolve them, but little change has taken place
thus far. To mitigate problems, AOC has installed supports to parts of the
ceiling of one tunnel to minimize the potential of falling concrete;
required individuals entering the tunnels to wear protective equipment and
clothing; contracted with FOH for air sampling and asbestos condition
assessments; purchased a portable air-conditioning system; begun upgrades
to the tunnels' communication system; and improved several tunnel
emergency escape exits. In addition, an AOC contractor has completed
structural assessments of three of the five tunnels and determined that
they are not in danger of collapse. AOC has received a draft assessment
report on the fourth tunnel, and the assessment of the fifth tunnel is
still in progress. AOC is scheduled to receive the final reports for these
two tunnels by December 31, 2006. Most of the actions AOC has initiated to
resolve the tunnel problems are still in the study, planning, or
procurement stage. (For specific information about the tunnel projects,
see enc. I.)

While AOC has taken a number of actions to begin addressing the problems
identified in the tunnels, few of the problems have been resolved thus far
and the condition of the tunnels remains substantially unchanged. Problems
persist, including the potential for falling concrete, loose asbestos, and
high heat; communication systems that do not provide consistent coverage
throughout the tunnels; a lack of adequate emergency egress; inadequate
lighting; and a lack of emergency lighting. Progress in addressing the
tunnel problems has been hindered because the conditions that AOC and its
contractors are trying to address make it difficult for them to work,
according to AOC officials.

In a preliminary report in July 2006, FOH identified asbestos in the
material used to insulate pipe and pipe fittings in three of the four
walkable tunnels.11 According to FOH, in two of the tunnels inspected, the
condition of the insulation on both steam pipes and condensate lines was
good overall. FOH has not completed its inspection of the third tunnel
because the tunnel had been closed.12 FOH does not believe that dust in
the tunnels contains asbestos except where the asbestos insulation has
been damaged. According to OOC officials, OOC does not concur with this
assessment because it found asbestos in dust samples taken off pipe
coverings in areas where damage to the insulation material was not
apparent. FOH recommends the complete abatement of all asbestos in the
tunnels. However, if complete abatement is not practicable, then FOH
recommends that damaged insulation be removed or repaired. Specifically,
according to FOH, insulation on either side of the stanchions that hold
utility pipes has been damaged by pipe movement and should be removed;
other damaged insulation should be repaired; and periodic inspections
should be done. FOH has provided limited data analysis indicating that for
some activities in the tunnels, protective equipment may not be necessary.
However, AOC has stated that it will continue to require protective
equipment until further analysis is completed.

11According to the FOH study, in the fourth tunnel, asbestos was found in
the insulation at one entrance area to the tunnel. FOH did not inspect the
fifth tunnel because the asbestos was in the process of being abated.

12AOC closed access to one of the tunnels until supports could be
installed to reduce the chance of concrete falling.

AOC's Utility Tunnel Improvement Plan Provides Some Required Information,
but Does Not Address Options for Improvement

AOC issued its Utility Tunnel Improvement Plan on August 31, 2006, as
directed by the House Committee on Appropriations, but the plan includes
only some of the required information and discusses future efforts to
provide all of the requested information. House Report 109-485, dated June
1, 2006, directed the Architect of the Capitol to "provide a plan and
budget to the committee that strategically address long term repairs to
the steam tunnels over the next 5 years." According to the report, the
plan should include, at a minimum, "an assessment of the tunnel problems
that need to be corrected, the priorities from safety and operational
standpoints, options for addressing the problems along with the costs and
benefits and advantages and disadvantages of each option, the recommended
options and schedule for implementation, and the identification of
officials who will be accountable."

As noted, because AOC's contractor has not finished assessing two of the
five tunnels, AOC's plan does not fully identify the tunnel problems. The
contractor expects to complete its assessment of the two tunnels in
December 2006. Combining the information it currently has on the condition
of the tunnels, AOC prioritized the tunnel projects into immediate,
short-term, and longer-range initiatives and established accountability
for these projects. AOC plans to initiate its immediate
improvements--designed to mitigate health, life safety, structural, and
heat stress concerns--by September 2007. AOC plans to initiate its
short-term improvements--designed to correct mechanical, electrical, and
structural defects--in fiscal years 2008 through 2012. AOC estimates the
cost for the improvements in the plan to be $119 million over the next 6
years. AOC also reported $14.4 million in longer-range initiatives
intended to mitigate the known problems in the tunnels through 2015. AOC's
longer-range initiatives include conducting quarterly structural
inspections, making necessary annual repairs, and modifying procedures to
reflect changing tunnel conditions. According to AOC, its plans were based
on information known at the time the report was being developed and are
preliminary. As the condition assessments and alternatives study are
completed, AOC expects to adjust its work plans, cost estimates, and
schedules as appropriate.

Without information on the condition of the two tunnels that remain to be
assessed, AOC's plan lacks a full picture of tunnel conditions, the work
that needs to be done, and the cost and time it will take to complete the
necessary work. In addition, the plan does not include a discussion of
options for addressing the immediate and short-term needs of the tunnels.
From the plan, it is not clear whether AOC considered various options for
addressing the tunnel problems or explored the cost, benefits, advantages,
and disadvantages of different options before determining what work to
include in the plan. AOC does indicate in the plan that it will conduct an
alternatives study to evaluate the long-term use of the existing tunnels
and options for meeting the Capitol Hill Complex's future utility
distribution needs. AOC officials said they wanted to addressed the total
utility distribution system's needs in their alternative studies to ensure
that Congress has a complete understanding of the system's requirements
and associated costs. While the immediate improvements might need to be
done before an alternatives study can be completed, AOC has reported
needing more than $100 million to address problems in the tunnels before
it identifies and considers the different options for resolving the
problems.13 Thus, Congress does not have assurance that the proposed
improvements and costs provide the best solutions for solving the problems
in the tunnels. In addition, the plan focuses only on needs in the
walkable tunnels and, as AOC points out, does not address the buried steam
lines or utility vaults, where, according to AOC officials, other problems
are known to exist.

AOC recognizes that the current plan does not fully respond to the
questions raised in the committee's report. According to AOC officials,
they are continuing to develop the requested information and will provide
it to the committee when available. They stated that the plan does not
include all of the requested information because they could not complete
the work in the time allotted. AOC officials said they wanted to be sure
they addressed the total utility distribution system's needs in their
alternatives study to ensure that Congress has a complete understanding of
the systems requirements and associated costs.

Efforts to Address OOC and Workers' Concerns Are Moving Forward, but
Progress on Worker Safety Issues Has Been Limited

AOC and OOC are moving toward resolving OOC's February 28, 2006, complaint
on the deteriorating condition of the tunnels, the tunnel communication
system, and emergency exits and the two January 2006 citations for
asbestos and heat stress problems. Both AOC and OOC are discussing
proposals to satisfy the applicable legal requirements and enable AOC to
resolve the issues in the complaint and the two citations. However,
according to OOC officials, some essential provisions that are critical to
reaching any settlement, including what hazards will be covered under the
agreement, have not to date been accepted by AOC. Furthermore, OOC
officials said they have not been fully successful in obtaining necessary
tunnel-related information from AOC on a timely basis. Part of this effort
is to understand the extent to which OOC's Office of General Counsel will
be involved in implementing activities to resolve the issues. AOC
regularly keeps the General Counsel's office up to date on the status of
tunnel operations and planned repair activities. OOC also says that it has
been working amicably with AOC to resolve the complaint and citations. AOC
and OOC are also continuing to meet to discuss and resolve new health and
safety issues in the tunnels as they arise.

The tunnel workers have expressed concern about the safety of the tunnels
due to the presence of asbestos, falling concrete, excessive heat,
inadequate emergency exits, and a poor communication system. AOC's Utility
Tunnel Improvement Plan covers these issues for the walkable tunnels, but,
as noted, progress in resolving these issues has been limited. The tunnel
workers told us they are discouraged and have no clear idea of when the
problems will be solved. To improve communication, AOC began holding
weekly meetings with the tunnel shop workers in April 2006 to discuss
tunnel issues and the actions being taken. However, the tunnel workers
have expressed frustration about the lack of progress in addressing their
safety and health concerns.

13Since the plan was issued, an AOC contractor has estimated that it will
cost between $61.5 million and $102.2 million to repair the structure of
four of the five tunnels. These costs were not available when the Utility
Tunnel Improvement Plan was issued.

AOC officials noted it has taken several actions to address the safety
concerns cited by OOC and the tunnel workers. These actions include the
establishment of safety and access control procedures for the tunnels, the
requirement that protective equipment and clothing be worn, the upgrade of
15 tunnel entry and exit points, the shoring of delaminated concrete, and
improvements to the reliability of the communication system in the
tunnels. OOC officials noted that additional concerns in the tunnels, such
as mold in one of the steam stations, continue to be identified.

Agency Comments

We provided a draft of this report to the Architect of the Capitol and the
General Counsel of the Office of Compliance for their review and comment.
The Architect of the Capitol provided us with written comments that are
reproduced in enclosure II. AOC generally agreed with the information as
presented in the report and provided technical comments that were
incorporated, as appropriate. We received oral comments from the General
Counsel at the Office of Compliance. He generally agreed with the
information as presented in the report and provided technical comments
that were incorporated, as appropriate.

We are sending copies of this report to the Architect of the Capitol, the
General Counsel of the Office of Compliance, and others interested
parties. We will also make copies available to others on request. In
addition, the report will be available at no charge on GAO's Web site at
http://www.gao.gov .

If you or your staff have any questions about this report, please contact
me at (202) 512-6923 or [email protected] . Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made major contributions to this report
are Maria Edelstein and Tom Keightley.

Terrell G. Dorn

Director, Physical Infrastructure Issues

Enclosures

Enclosure I: Tunnel Projects

Company                   Award date Work to be performed                  
                                        Prepare scoping and inspection plan   
Entech Engineering, Inc.  9/29/2005  for the utility tunnel system         
Lord & Co., Inc.          11/2/2005  Maintain radio                        
                                        Provide management consulting         
GRA, Inc.                 1/9/2006   services                              
                                        Develop heat stress programs and      
The Safety Company, Inc.  1/13/2006  policies                              
                                        Provide tunnel evaluation for one     
The Safety Company, Inc.  3/3/2006   tunnel                                
                                        Perform minor insulation and minor    
                                        abatement throughout                  
                                                                              
WACO, Inc.                4/14/2006  one tunnel                            
                                        Capitol Power Plant (CPP) emergency   
B&W Fabricating           4/20/2006  egress                                
Lord & Co., Inc.          5/4/2006   Provide radios for tunnels            
                                        Provide exposure and hazard           
                                        assessment, air sampling, asbestos    
                                                                              
                                        condition inspection, and lead paint  
US Public Health / FOH    5/5/2006   inspection                            
                                        Provide engineering services for      
                                        tunnel design documents for one       
James Posey Assoc.        5/12/2006  tunnel                                
                                        Provide construction manager services 
Jacobs Engineering        6/12/2006  for CPP tunnel program                
                                        Perform facility conditions           
Entech Engineering, Inc.  7/21/2006  assessment of the utility tunnels     
Topp Portable Air         7/21/2006  Rental of portable air units          
                                        Provide structural, environmental,    
                                        safety, and health consulting         
URS Greiner Woodard Clyde 7/25/2006  services                              
Ameri-can Engineering     7/25/2006  Purchase decontamination trailer      
US Public Health / FOH    7/28/2006  Tunnel entry procedures               
IDS Blast Finishing       8/1/2006   Rental of Decontamination trailer     
                                        Provide miscellaneous general         
CESI                      8/2/2006   housekeeping                          
                                        Develop emergency evacuation plan for 
The Safety Company, Inc.  8/15/2006  CPP utility distribution system       
                                        Provide surveying services for one    
A. Morton Thomas & Assoc. 8/16/2006  tunnel, lot 12                        
                                        Excavation and asbestos abatement for 
Centennial Contractors    9/8/2006   the egress point, lot 12              
Topp Portable Air          9/30/2006 Purchase portable air units           
Construction Management              Begin removing delamination in one    
Division, AOC             11/2006a   tunnel                                
To be determined          11/2006 a  Clean debris and dust from one tunnel 
To be determined          12/2006 a  Clean mold and abate asbestos from    
                                        one tunnel                            
To be determined          12/2006 a  Study alternative communication       
                                        system                                
To be determined          12/2006 a  Design and initial construction of    
                                        two new egress points for one tunnel  

Source: AOC.

aThese contracts have not yet been awarded. The date provided is when AOC
expects to award the contract.

Enclosure II: Comments from the Architect of the Capitol

(543175)

*** End of document. ***