    [From the U.S. Government Printing Office, www.gpo.gov]

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                       Ocean Thermal Energy Conversion
                       Report to Congress: Fiscal Year 1981

                               U.S. DEPARTMENT OF COMMERCE
                               National Oceanic and Atmospheric Administration
                               Office of Ocean Minerals and Energy
                               February 1982

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                                         V       UNITED STATES DEPARTMENT OF COMMERCE
                                                 National Oceanic and Atmospheric Administration
                                         Nrl of  Washington, D.C. 20230
                                                 THE ADMINISTRATOR
                                                 FEB 1 d 1982

                     Honorable George H. Bush
                     President of the Senate
                     Washington, D.C. 20510

                     Dear Mr. President:

                       It is my honor to transmit the Ocean Thermal Energy Conversion
                     Report of the National Oceanic and Atmospheric Administration (NOAA)
                     to the Congress pursuant to Section 405 of the Ocean Thermal Energy
                     Conversion Act of 1980 (P.L. 96-320).

                       This report describes NOAA's progress in implementing the Act,
                     and our continued development of the OTEC program in a legally
                     sound and environmentally sensitive manner. Also discussed are
                     NOAA's involvement in developwent of OTEC technology, and our
                     outlook for the future of OTEC.

                                                    Sincerely,

                                                    John   Byj&e

                     Enclosure

                                   U   DEPARTMENT OF COMMERCE NOAA
                                   COASTAL SERVICES CENTER
                                   2234 SOUTH H(j6SON AVENUE
                                   CHARLESTON SC 29405-2413

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                                   Property Of C
                                                    61ncerely

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                                                   @John

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                                                V
                                                       UNITED STATES DEPARTMENT OF COMMERCE
                                                       National Oceanic and Atmospheric Administration
                                                       Washington, D.C. 20230
                                              @479S of
                                                       THE ADMINISTRATOR

                       Honorable Thomas P. O'Neill, Jr.
                       Speaker of the House of Representatives
                       Washington, D.C. 20515

                       Dear Mr. Speaker:

                          It is my honor to transmit the Ocean Thermal Energy Conversion
                       Report of the National Oceanic and Atmospheric Administration (NOAA)
                       to the Congress pursuant to Section 405 of the Ocean Thermal Energy
                       Conversion Act of 1980 (P.L. 96-320).

                          This report describes NOAA's progress in implementing the Act,
                       and our continued development of the OTEC program in a legally
                       sound and environmentally sensitive manner. Also discussed are
                       NOAA's involvement in development of OTEC technology, and our
                       outlook for the future of OTEC.

                                                          Sincerely,

                                                           o n V. B   e

                       Enclosure
                                                            1 n re'Ly

                                                               V.
                                                       @ohn       B@ re

                                 'Vil OF CO
                                          "@4,          Ocean Thermal Energy
                                                        Conversion Report to
                              S   7, E's- 0             Congress: Fiscal Year 1981
                                                        Public Law 96-320

                                                        Prepared by:
                                                        Office of Ocean Minerals and Energy
                                                        2001 Wisconsin Avenue, N.W.
                                                        Washington, D.C. 20235

                                                        February 1982

                                                        U. S. DEPARTMENT OF COMMERCE
                                                        Malcolm Baldrige, Secretary
                                                        National Oceanic and Atmospheric Administration
                                                        John V. Byrne, Administrator
                                                        Office of Minerals and Energy
                                                        James P. Lawless, Acting Director

                                                    TABLE OF CONTENTS

                       Chapter I       Background ................  I................

                             The Resource
                             The National Interest
                             Nature of the Industry

                       Chapter 11 - OTEC Technologyo..*..**.**.*.oo.ooo.oo.oo.oooo.so. 7

                             How OTEC Works
                             Technology Development
                             Ocean Engineering Research and Development Program

                       Chapter III - The Legal Regime.ooo.o .... o   ...... o..o ......... o ... 16

                             The Ocean Thermal Energy Conversion Act of 1980
                             OTEC Licensing Regulations
                             The Licensing Process

                       Chapter IV - Environmental Considerationso..o..ooooo..ooooo.o.- 26

                             OTEC Environmental Issues Discussion Paper
                             Environmental Impact Statement (E'IS)
                             Technical Guidance Document
                             Environmental Research Plan

                       Chapter V    - International Impact and Future of OTECo..oo .... o. 32

                             International Trade
                             International Law
                             Recommendations for Amending the OTEC Act

                                                   Chapter I

                                                   Background

                 The Resource

                     In 1881, the French physicist Arsene d'Arsonval published a theoretical article

                 describing a method by which electricity could be generated from the temperature

                 differences between warm and cold water. D'Arsonval suggested that his process

                 could use the temperature differences between water from hot springs and a cold

                 river, or- between the warm surface waters and cold deep waters of the ocean.

                     The efficiency of d'Arsonval's process, now called ocean thermal energy

                 conversion (OTEC), increases greatly with even a small increase in the available

                 temperature difference. Although the process can work at temperature differences

                 of less than 20*C (36*F), that temperature difference is usually used as a

                 minimum standard for the OTEC resource. Deep waters are almost uniformly

                 cold throughout the world's oceans   Thus, the best ocean temperature differences

                 for OTEC are found near the Equator where the surface waters receive the

                 greatest amount of heat from the sun.

                     Temperature differences of at least 20*C at depths of 1000 meters or less

                 are found in large areas of the ocean between latitudes 30* north and 250

                 south (Figures 1 and 2). Estimates of the total ocean thermal energy base

                 range from 100 million to 10 billion megawatts. Current electric consumption

                 in the U.S. is about 230 thousand megawatts.

                     An excellent OTEC resource exists in the Western Pacific Ocean, the

                 Caribbean, the tropical west and southeastern coasts of the Americas, the

                 Indian Ocean, and near both coasts of Africa. This resource lies within 200

                 miles of the coasts of more than 90 nations and territories.

                                                                              15*
                                                                     --@l 7 Z--
                                                                            '-18-     16'

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                                                                                    21'
                                                                                   22-

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                                                  21'-

                                                 19
                                           20'                                                           2

                                                18'                                                      21
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                                                                                                         20'19'
                                                                                                                 17'

                                                   16

                                           17'

                                                 15,

                                            100*00, W      80*00,        60*00'        40*00'        20*00'        0100,

                                                  1000 m deep
                                       *Contours indicate temperature differential (*C) between surface and 1000 m depth

                                                           Figure 1. The OTEC Thermal Resource Area (Atlantic)

                                                                     16'
                                                                                                            is*
                                                                              17'
                                                                       18 . .............
                                                                          -191
                                                                       20' -
                            .... .........

                                                                                                            21'
                                                      2V                                                                        22L
                                                                                     23*

                                                                                                                                         oe@

                                                                                                             22*

                                 . . . . . . . . . . .

                                                                                                                    21*

                                                                                       9o
                                                                              18'
                                                                                                                                    17
                                                                             16'
                                                                     ........        15o                                 ------

                                                                     al-  X@.

                         120*00'E       140'00'         160'00'        180'00'        160'00'         140*00'        120*00'        100 *00,

                                   < 1000 m deep

                           *Contours indicate temperature differential M) between surface and 1000 m depth

                                                                Figure 2. The OTEC Thermal Resource Area (Pacific)

                   Potential OTEC areas for the United States include Guam, the Northern

                Marianas, other Western Pacific islands,, Hawaii, Puerto Rico, the U.S. Virgin

                Islands, and the Gulf of Mexico. The total ocean thermal resource within

                200 miles of the United States has been estimated as about equal to total

                present U.S. energy usage.

                The National Interest

                   Development of a commercial OTEC industry by the U.S. private sector would

                provide the United States with: (a) increased energy self-sufficiency,

                (b) major new international trade opportunities, (c) reduced annual balance

                of payments deficits, (d) increased investment in manufacturing, construction,

                and energy-intensive industries, (e) increased regional employment, and

                (f) continued leadership in new ocean technologies.

                   The potential power generation market in which U.S.-built OTEC plants

                could compete has been estimated for approximately seventy of the ninety

                countries and territories with access to the OTEC resource. The added electric

                power generation needs of these countries, many of which are lesser developed

                countries now dependent on imported oil, is large enough to accommodate on

                the order of 100 1OMW OTEC plants, 500 40MW plants, 1100 lOOMW plants, and

                1100 40OMW plants (a total of more than 570 thousand MW) between the years

                1990 and 2010. Even if U.S. companies are able to supply only ten percent

                of this potential market, a conservative projection, U.S. exports of OTEC

                plants would increase U.S. export trade by about $171 billion in 1980

                dollars. This would result in major benefits to U.S. employment, industrial

                activity, and balance of payments.

                   Meeting a goal of 10,000 megawatts of U.S. OTEC capacity in place by

                1999 would free Hawaii, Puerto Rico, and other U.S. islands from dependence

                                                     -4-

                  on imported oil for their baseload electricity generation, and would reduce U.S.

                  needs for imported oil by approximately 360,000 barrels a day. The cumulative

                  displacement of imported oil by 1999 would amount to a savings of $18 billion.

                  The combination of savings from imported oil and payments for U.S. OTEC plants

                  sold to other countries could result in an improvement in U.S. balance of

                  payments by $5 billion to $7 billion a year during the 1990s.

                      Because OTEC plants use components and skills from a wide variety of

                  industries, industrial investment and activity would be increased in diverse

                  areas of the U.S. economy, including shipyards, heavy construction, and the

                  manufacturing of concrete, aluminum, turbines, pumps, heat exchangers, and

                  offshore services. It has been estimated that domestic use of OTEC (without

                  counting the additional effects of international trade) by 1997 will increase

                  annual employment by 144,000 workers., personal income by $3.9 billion, retail

                  sales by $1.2 billion, and will generate tax revenues of dn additional $600

                  million to the federal government and $180 million to states and localities.

                     Commercial OTEC operations will involve extensions and new applications

                  of existing technology. If the OTEC industry emerges strongly in the United

                  States, it will help extend the nation's ability to develop ocean resources

                  in general and will help assure a continuing U.S. role as a leader in ocean

                  engineering and a supplier of high technologies.

                  Nature of the Industry

                     A large number of U.S. corporations, varying in size, are involved in

                  development of OTEC technology as potential owners, operators, builders,
                  designers, or pa r;s suppliers. Approxim ately eight consortia comprising these

                  corporations were formed to bid on a Department of Energy procurement for cost-

                  shared OTEC pilot plants. Another consortium of corporations based in Maryland

                                                       -5-

                is exploring the Potential for constructing commercial OTEC plants in

                Maryland for deployment in the Caribbean. In addition, the U.S. Territory

                of Guam signed a contract in 1980 for construction of a land-based commercial

                OTEC plant, although work has not yet started. Companies in other countries,

                principally Japan, France, and Sweden, are also engaged in OTEC development

                with varying degrees of assistance from their governments.

                                                      -6-

                                                  Chapter 11

                                               OTEC Technology

                   How OTEC Works

                      Ocean thermal energy conversion is a process for using solar energy

                   stored in the warm surface waters of the tropical and subtropical oceans

                   to perform useful work, either generating electricity for domestic and

                   industrial consumption or providing energy for industrial refining and

                   manufacturing. Several different techniques have been considered as the

                   basis for OTEC power generation. Most experts agree that two of these,

                   closed cycle and open cycle, are the most economically sound and technically

                   feasible in the foreseeable future.

                      The closed cycle technique (Figure 3) employs a working fluid (most

                   likely ammonia or Freon") enclosed in a system of piping. This fluid is

                   pumped through a heat exhanger where it is heated by oceanic surface

                   waters that have been warmed by the sun. This vaporizes the working

                   fluid causing it to pass through and drive a gas turbine. The turbine

                   is used to run an electric generator and produce electricity for distri-

                   bution to industrial and residential users on land or for use directly on

                   site for energy-intensive processing or manufacturing. After passing

                   through the turbine, the working fluid, at this point still a gas, is

                   condensed to a liquid by exposure in another heat exchanger to cold water

                   drawn from the deep ocean. The working fluid is then revaporized by being

                   pumped back through the warm water heat exchanger and the cycle is repeated.

                   This means of power generation does not use any fuel. The system is

                   based on the repeated vaporization and condensation of the working fluid

                   made possible by taking advantage of the temperature difference between the

                                                      -7-

                                                                                        Electric Power
                                    Warm                                                Output
                                    Water
                                    Intake

                                                 High Pressure                                      Low Pressure
                                                 NH3 Vapor                                          NH3 Vapor
                               25*C
                                                                    Turbine
                                                                    Generator

                                                        20*C                                 20T                                7*C

               60                      Evaporator                                                                Condenser

                                                        1O*c                                  10T
                                                                   Liquid
                                                                   Pressurizer                                                ST
                                23*C              High Pressure                              Low Pressure
                                                  NH3 Liquid                                 NH3 Liquid

                                    Warm                                                                                Cold         Cold
                                    Water                                                                                Water       Water
                                    Exhaust                                                                              Intake      Exhaust
                                                                                                                            L/
                                                                                                                            V
                                                                                                                            V

                                                                 :@irq u i d
                                                                   P   su
                                                                     e:srize]r#

                                                Figure 3. Schematic Diagram of a Closed-Cycle Power System

                    sun-heated surface waters and the perpetually cold deep waters of the

                    tropical oceans. Even the pumps used to draw in the warm and cold water

                    do not need conventional fuel. They are powered by a part of the energy

                    produced by the process itself.

                        The open cycle system is, in most ways, quite similar to the closed

                    cycle system. However, in the open cycle system seawater itself is the

                    working fluid. Warm surface water is pumped into an evaporator in which

                    the pressure is reduced to the point where the seawater boils. This produces

                    steam that passes through and drives a low-pressure turbine to generate

                    electricity, like the closed system. After leaving the turbine,

                    the steam is cooled and condensed by exposure to cold, deep water in a

                    heat exchanger. The open cycle technique has the advantage that the

                    dissolved salts do not accompany the surface water when it forms steam.

                    Thus, a valuable byproduct, fresh water, results when this steam condenses.

                        The earliest commercial applications of the OTEC principle are expected

                    to use the closed cycle process. There is also, however, considerable

                    interest in open cycle applications because of the additional benefit of

                    its fresh water production.

                        Generation of electricity is expected to be the first commercial

                    application of the OTEC process, with early commercial plants beginning

                    operation by the mid-1980s. The facilities will probably be moored to

                    or mounted directly on the ocean floor, or located partly on land with

                    their intake and discharge pipes extending out into the ocean. The

                    electricity from moored or bottom-mounted facilities will be brought to

                    shore by submarine electrical transmission cables. Land-based OTEC

                    facilities would be in areas where deep water is found very close to

                                                       -9-

                  shore. Such sites exist in Hawaii, Guam, and other U.S. islands. OTEC

                  facilities are expected to vary in size from about 10 megawatts (a size

                  suitable for small islands) to about 400 megawatts (about the size of a

                  conventional plant serving approximately 60,000 households).

                     Another possibility for implementation of the OTEC process is to use

                  the electricity directly on the site for production of energy-intensive

                  products such as hydrogen, ammonia or methanol.. or for energy-intensive

                  activities, such as aluminum smelting.

                     Such onsite manufacturing or processing could take place on facilities

                  situated on or close to shore, or on roving plantships. For the facilities

                  near shore, the product would be moved ashore by a product pipeline or by

                  vessels. Self-contained plantships that would use OTEC techniques to

                  obtain the energy needed to run onboard manufacturing or processing

                  activities could float unmoored or move slowly under their own power as

                  they sought out optimum thermal gradient conditions. Vessels would be

                  used to transport OTEC plantship products to their destinations.

                  Such plantships are expected to employ closed cycle systems.

                  Technology Development

                     The first experimental application of d'Arsonvalls OTEC theory was by

                  one of his students, Georges Claude, who in 1930 built a plant at Matanzas

                  Bay, Cuba. The facility, destroyed by a storm shortly after its completion,

                  actually consumed more electricity than it produced. Because other

                  sources of energy were still viewed as unlimited and inexpensive, Claude's

                  accomplishment was regarded at the time as more of a scientific curiosity

                  than the early development of a major source of renewable energy.

                                                     _10-

                     Renewed interest in OTEC as an energy source came about in the 1970's as

                 a result of fossil fuel shortages and the increasing uncertainty associated

                 with foreign sources of supply. In 1972 the National Science Foundation

                 began work on OTEC technology. As this work continued, it was transferred

                 to the Energy Research and Development Administration (ERDA) and then to

                 the Department of Energy. In the United States, particular interest in

                 OTEC developed in Hawaii, Puerto Rico and Guam due to their almost total

                 dependence on imported oil for electrical power.

                     While Department of Energy efforts to develop large-scale commercial

                 technology continued, private industry and the State of Hawaii undertook

                 a small-scale demonstration of the at-sea feasibility of the OTEC principle.

                 This effort was initiated independently of the federal technology develop-

                 ment program and was financed largely by Hawaii, Lockheed Missiles and

                 Space Company, and the Dillingham Corporation. Their activities resulted

                 in deployment and successful operation of Mini-OTEC, a 50-kilowatt gross

                 output plant, off the Kona Coast of the island of Hawaii in 1979. Mini-

                 OTEC produced a net power output of more than 10 kilowatts, exceeding

                 design expectations. The Mini-OTEC project was the world's first actual

                 demonstration that OTEC technology could produce net electrical energy.

                     Since late 1976 NOAA has been providing ocean engineering and technical

                 management assistance to the Department of Energy's OTEC research and de-

                 velopment program. This work has been conducted by NOAA?s Office of Ocean

                 Technology and Engineering Services (OTES). The program's major accomplish-

                 ments during FY 1981 are described in the next section.

                    Ocean Engineering Research and Development Program

                        NOAA's OTES office has supported the Department of Energy in developing

                    a number of concepts and components for OTEC plants including systems

                    relating to platforms, cold water pipes, sea water, anchoring, mooring,

                    and foundations. Most of the effort before 1981 emphasized floating OTEC

                    systems. However, in the past year interest in shelf-mounted systems has

                    accelerated. Some of the significant factors associated with shelf-mounted

                    systems are:

                             �   Installation and protection of bottom-mounted pipes;

                             �   Greater loading forces due  to the structuret cold water pipe, and
                                 power plant components;

                             o   Slope stability and associated foundation design and installation;
                                 and

                             �   Influence of near-shore circulation on discharge pipe design and
                                 installation.

                       .The FY   1981 ocean engineering program managed by NOAA was redirected in

                    mid-year to  emphasize technology related to the pilot plant or "proof of

                    concept experiment" conceptual designs while maintaining a well balanced

                    approach toward satisfying  the technical problems of floating systems and

                    the newly introduced-shelf-mounted systems.

                        Plantship Vessels and Offshore Platform Systems

                         Prior to FY 1981 OTEC engineering was concentrated on floating vessel

                    concepts--either moored barges or spars with   an electrical cable leading

                    to shore, or mobile, "grazing" vessels producing energy-intensive products

                    such as ammonia. Studies of alternative concepts using fixed-tower

                    technol-ogy-.developed by the offshore oil industry were begun in late FY

                    1980 and are.continuing..

                                                         -12-

                         NOAA ocean engineering findings in. 1981 concerned with plantship

                    and offshore platform technology are described below:

                         6 Model basin tests and other studies have shown that seakeeping

                            characteristics of OTEC barge-type vessels can be significantly

                            improved using standard naval architecture techniques.

                         o Marine concrete is a practical material for plantships.

                         o Attachment of the cold water pipe directly to a plantship compli-

                            cates the vessel's motion in a seaway and makes survival      difficult

                            during severe  weather. A moored pipe that decouples the motion

                            of the vessel  and the cold water pipe and also permits detachment

                            of the plantship.from the pipe during.severe storms was found to

                            be feasible.

                         0  Design, installation, deployment, inspection, maintenance, and

                            repair of  shelf-mounted platforms   and cold water pipes have    been

                            analyzed. Conceptual designs are     being developed to identify

                            tower and  platform arrangements for   model basin  tests.

                         o  Preliminary classification-and technical r.eq.uirements-   for the

                            inspection, maintenance, and repair of plantships, cold water

                            pipes, and mooring systems were developed. These studies showed
      4
                            that it is possible to optimize both initial and     long-term costs,

                            and thus minimize lost   income  from operational downtime, without

                            compromising safetyO

                         o Baseline designs for a    40 MW OTEC-pilot  plant were found,to be

                            feasible and in general   agreement with ship class:ification society

                            regulations.

                                                           13-

                     Cold Water Pipe and Seawater Systems

                     The cold water pipe draws cold water from a depth of about 1,000 meters

                 (3,300 feet) to the power plant condenser. A suspended cold water pipe

                 for a 40 MW floating plantship would be about 1000 meters long and 9

                 meters (30 feet) in diameter. The cold water pipe for a shelf-mounted

                 platform would lie on the.sloped ocean bottom. During FY 1981,

                 several important tests on cold water pipes were conducted. They included:

                     � A 1/50 scale test to collect valuable design data on the stress

                        associated with towing and deploying cold water pipes during

                        installation. Results indicate that a system in which the pipe

                        is towed. to the plant location and then "flipped" into its vertical

                        position is feasible.

                     �  A 1/110 scale mooring test of a platform and cold water pipe

                        showed that the pipe was sufficiently strong during severe weather.

                        Fiberglass reinforced plastic, cable-reinforced elastomer, and

                        articulated steel cold water pipes were tested.

                     �  Two analytic models of the dynamic and structural behavior of the

                        cold water pipe, platform, and moorings were developed. These

                        computer programs will be used in subsequent design and development

                        efforts.

                     �  A 1/3 scale cold water pipe test program was started in FY 1981. This

                        program will produce information on the performance of fiberglass-

                        reinforced plastic pipes; establish design and construction procedures;

                        quantify dynamic response during deployment and exposure to environ-

                                                    -14-

                          mental loads in both normal and severe sea conditions; and help

                          validate the analytic models.

                       0  An analytical computer program that integrates dynamic and thermal-

                          hydraulic responses of the flow of water in piping systems was

                          developed and evaluated.

                       Mooring and Foundation Systems

                       The mooring system comprises the wires, chains, lines, anchors,

                   hardware, and deck handling equipment. Foundations are the footings for

                   tower structures,, slope-mounted pipes, and anchor pilings for mooring

                   systems.

                       A study to evaluate the performance of various anchoring systems on a

                   sloping sea floor showed that gravity and embedment anchors are ineffective

                   on slopes over 15 degrees. The study also showed that at a Hawaiian site

                   the best anchoring systems would use drilled and grouted anchor piles. At

                   a Puerto Rico site, gravity embedment anchors could be used in deep water

                   where heavy sediment exists. However, drilling and grouting of anchor

                   piles would be required near shore where the bottom is mostly rock.

                                                        -15-

                                                 Chapter III

                                               The Legal.Regime

                The Ocean Thermal Energy Conversion Act of 1980

                    The successful, Mini-OTEC demonstration'off Hawaii in 1979 captured the

                imagination of executives at industrial concerns and of lawmakers, thus setting

                the stage for legislation to encourage development of a commercial OTEC industry.

                Private industry and utility companies believed some kind of federal law was

                necessary to remove legal and regulatory barriers that would otherwise prevent

                U.S. companies from building and operating commercial OTEC plants. These barriers

                consisted largely of legal and regulatory uncertainties, which, if left

                unresolved, could have deterred potential investors. These uncertainties

                consisted primarily of:

                        o Lack of any clear statement that OTEC activities  are legal under

                           national or international law;

                        o., Lack of any law or regulation assuring continued access to the

                           ocean thermal resource being used by a particular OTEC plant;

                        �  Lack of clarity as to whether admiralty, land-based, or some other

                           body of residual and common law would apply to activities on OTEC

                           platforms located on the high seas beyond the normal coverage of

                           national laws;

                        o Uncertainty about whether OTEC operat-ions.might be declared illegal

                           or partially restricted in the future; and

                        � Lack of clarity as to which federal agency regulations might apply to

                                                      -16-

                             OTEC operations in U.S. waters, and how those existing regulations

                             would be interpreted when applied to OTEC operations.

                  The overall effect of those uncertainties, if not dealt with by clear

                  legislation, would have been to make finanacing and insuring of commercial

                  OTEC operations essentially impossible.

                     The first formal response to these uncertainties was the introduction of

                  H.R. 6154, the Ocean Thermal Energy Conversion Act of 1980, on December 14,

                  1979. A similar Senate bill, S. 2492, was introduced on March 27, 1980.

                  Committee action on this legislation began early in the second session of

                  the 96th Congress. Extensive hearings on both bills were held, with thirty-six

                  witnesses appearing during three days of hearings on H.R. 6154 during January

                  and February 1980 before the Oceanography Subcommittee of the House Committee

                  on Merchant Marine and Fisheries. Hearings on S. 2492 were held in Honolulu

                  and Washington, D.C., in April and May 1980 by the Senate Committee on

                  Commerce, Science and Transportation. During these hearings, witnesses

                  representing private industry, utility companies, state governments, and

                  private citizens reiterated the need for federal legislation to clear the

                  way for commercial OTEC development.

                     S. 2492 was reported by the Senate Commerce Committee an May 15 and

                  passed the Senate on July 2, 1980. The Merchant Marine and Fisheries

                  Committee reported H. R. 6154 on May 16. There were only minor technical

                  differences between the two bills. As a result, after passing H.R. 6154 on

                  July 21, the House of Representatives vacated passage of that bill and passed

                  S. 2492. On August 3, 1980, the Ocean Thermal Energy Conversion Act of 1980

                  (Public Law 96-320) was signed into law.

                                                       -17-

                   The principal provisions of the Act were:

                        � Establishment of United States jurisdiction over (a) OTEC

                           facilities located in the U.S. territorial sea or connected to

                           the United States by pipeline,or cable, (b) OTEC plantships

                           owned or operated by U.S. citizens, and (c) OTEC facilities or

                           plantships documented under U.S. law;

                        � Specification of which federal and state laws are to apply to

                           OTEC facilities and plantships under U.S. jurisdiction; and

                        � Creation of a fair and expeditious licensing system to assure

                           compliance by U.S. OTEC facilities and plantships with both U.S.

                           and international law.

                  The license processing system in the Act is designed to yield a single

               federal decision representing all involved departments and agencies without

               the protracted delays that can occur in other governmental licensing processes.

               The overall licensing system is administered by the National Oceanic and

               Atmospheric Administration. The Act required promulgation of final licensing

               regulations by August 3, 1981. The Act also contains several provisions related

               to financing of OTEC plants, to be implemented by. the Transportation Department's

               Maritime Administration.

               OTEC Licensing Regulations

                  NOAA immediately took action to respond to the Act's mandate for OTEC

               licensing regulations. Proposed regulations were issued on March 30, 1981,

               just six months after the Act became law. Final regulations governing the

               licensing process were published in the Federal Register on July 31, 1981.

               These regulations carry out the purposes of the statute by eliminating legal

                                                    -18-

                  uncertainties and providing for a coordinated, efficient licensing process.

                  They are flexible enough to allow the experimentation and.innovation required

                  for OTEC to advance from the developmental stages into a commercial reality.

                      The regulations are designed to be readily usable by those seeking a

                  federal OTEC l'icense and include a voluntary review process to ensure more

                  rapid processing of an application than is required by the Act. The regulations

                  described:

                      1. Who is required to apply for an OTEC license and the procedures for

                          submitting an application.

                      2. Procedures for conducting  optional pre-application consultations with NOAA

                          prior to actual submission of an application.

                      3.  The financial, technical and environmental information that must be

                          submitted with an application to enable NOAA and other federal

                          agencies to make licensing decisions.

                      4.  An explanation of the Act's requirements for processing an OTEC

                          license application and of special processing procedures available

                          at the applicant's request.

                      5.  The criteria for approval or denial of an application, and the terms

                          and conditions that may be included in a license.

                      6.  Procedures for formal hearings on a license application, should they.

                          become necessary.

                      7.  The post-licensing enforcement procedures.

                      There was general agreement during development of the regulations

                  that site evaluation and preconstruction testing regulations were unnecessary

                  at present.   Thus, the final regulations did not address these matters. At

                  was also apparent that current'scientific understanding and projected develop-

                                                       _19-

                ment schedules did not justify immediate establishment of upper limits on the

                number or total capacity of OTEC facilities and plantships to be licensed.

                Accordingly, that issue was reserved for future rulemaking, should establish-

                ment of such limits become necessary.

                    As part of the process of developing the licensing regulations, NOAA

                prepared a regulatory impact analysis. The possible approaches to a licensing

                regime fell into three categories: detailed, moderate, and minimum regulation

                of OTEC activities.

                    In considering which of these alternatives would be most appropriate,

                NOAA was guided by the principle that maximum flexibility should be allowed

                for development of a domestic OTEC industry while providing a degree of certainty

                sufficient to encourage private financing of commercial OTEC projects. The

                choices involved the following considerations:

                1. Detailed regulation of OTEC activities

                    This general approach would involve regulations containing detailed

                provisions specifying the design of OTEC plant components and requiring use

                of specific operating procedures. The information required to make application

                for a license would of necessity be voluminous, and detailed design of the

                plant would have to be completed prior to making application.

                    Because adoption of this alternative would yield a low probability of

                obtaining the benefits to society that would accrue from OTEC development

                and would impose high costs on both potential OTEC owners and on the government,

                it was not seriously considered.

                2. Moderate regulation of OTEC activities

                    Under the moderate approach, regulations would not contain detailed provisions

                                                   -20-

                 specifying design of OTEC plant components or plant operating procedures.

                 The regulations would, however, contain detailed guidelines and performance

                 standards applicable to all OTEC facilities and plantships in order to ensure

                 adherence to overall regulatory goals. A license applicant would be required

                 to prove that the intended plant design and approach met each of the detailed

                 guidelines and performance standards included in the regulations.

                     The use of specific guidelines and performance standards is a common

                 approach to regulation of relatively mature and.stable industries where many

                 facilities al,ready exist and the nature of the technology used and its impacts

                 are well known'. However, when applied to a nascent industry such as OTEC,

                 this approach would limit the design and technical flexibility needed to

                 evolve systems that best meet the combined goals of sound engineering and

                 economics and of protection of societal values. For this reason, this

                 alternative was not selected for the licensing regime.

                 3. Minimum regulation of OTEC activities

                     Under the minimum regulation alternative, NOAA would include in the

                 licensing regulations only the general guidelines and performance standards

                 specified in the Acto Detailed guidelines and specifications would not

                 be provided in advance in the regulations. They would be introduced if

                 deemed necessary on a site-specific, case-by-case basis to prevent significant

                 adverse effects on the environment or to prevent other results contrary to

                 law. The information submitted to NOAA with an application would include

                 details of the proposed site, descriptions of the operating features of the

                 plant, and assessments of the potential impacts of construction and operation.

                 Thus, application for a license could be made before detailed design of the

                                                      -21-

                OTEC plant was completed. NOAA would examine the applicant's assessments of

                the nature and potential magnitude of the impacts from construction and operation

                of the proposed project, and analyze in detail only those impacts that appeared

                to pose significant problems.

                    Under this approach, the incremental administrative costs to NOAA

                to process each application would be relatively modest, on the order of

                two to three person-years and $250,000. Maximum design flexibility would be

                afforded OTEC project sponsors, consistent with reasonable protection of

                societal values.

                    Most persons who commented on the proposed OTEC licensing regulations

                favored the minimum regulation alternative. NOAA's detailed analysis of

                potential regulatory impacts of various licensing regimes, prepared as part

                of the regulation development process, confirmed that the minimum regulation

                approach was the most cost-effective one that would satisfy the stated goals

                of the Act. Accordingly, it was adopted as the basis for the final licensing

                regulations issued by NOAA.

                The Licensing Process

                    NOAA?s regulations establish the procedures for applying for and processing

                OTEC licenses. In addition,, they make specific provision for consultations

                between NOAA and potential applicants in advance of actual submission. This

                arrangement fosters early and productive dialogue between NOAA and potential

                OTEC license applicants and can save potential applicants from wasting effort

                gathering information that NOAA will not need.

                    Reflecting requirements of the OTEC Act itself, NOAA's licensing

                regulations provide that the application to NOAA constitutes application for

                all necessary federal agency actions, other than Coast Guard inspections and

                                                     -22-

                  approvals. Provisions are made in the regulations for insuring that all

                  involved federal and state agencies receive copies of an application in

                  timely fashion. Provision is also made for NOAA to prepare an environmental

                  impact statement on the application, to cover all federal agency actions

                  relating to OTEC project. Extensive provisions are made in the regulations

                  for public involvement in the application review process.

                      The regulations impose rigid time constraints on the OTEC license

                  application review process, as required by the Act itself. An initial

                  determination as to the completeness of the application must be made within

                  21 days after its receipt. Review of the application for anti-trust impli-

                  cations must be completed by the Attorney General within 90'days after

                  receipt of a copy of the application by the Justice Department. NOAA must

                  issue a draft environmental impact statement not later than 180 days after

                  giving notice of receipt of a complete application. Public hearings on the

                  application must be completed not later than 240 days after notice of its

                  receipt in complete form.

                      Other involved federal agencies must complete reviews within their areas

                  of responsibilities and make their recommendations to NOAA regarding approval

                  or denial not later than 45 days after completion of public hearings.

                      Finally, NOAA must make a final decision on approval or denial of the

                  license application not later than 90 days after completion of public hearings.

                  Thus, under the deadlines imposed by the Act and NOAA's implementing regulations,

                  the entire license application review process will be completed in slightly

                  less than one year after receipt of an application.

                      Early in the process of developing regulations to govern OTEC licensing,

                  NOAA recognized the need to provide applicants with the option of a more

                                                       -23-

                coordinated, efficient review process than the minimum required by the Act.

                A model exists for such a coordinated approach to multiple agency licensing

                and permitting decisions on a single project in the form of the Joint Review

                Process developed by the Colorado's Department of Natural, Resources for use

                in federal and state permitting of major energy and natural resource develop-

                ment projects. Drawing heavily on the concepts used in the Colorado process,

                NOAA developed the Consolidated Application Review (CAR) process provided

                for in the licensing regulations. The process involves early designation

                of federal, state, and local government members to,serve,,wi-th the applicant,

                on a CAR team for the application.,- NOAA will chair the CAR team, and its

                primary responsibility will*be to coordinate the scheduli.ng of each government

                agency's review process for the application, including necessary hearings

                and decision points, so that a prompt and unified decision can be reached on,

                the application.

                   The CAR process is intended to assure early and continuous coordination

                among all involved federal, state and local agencies and to provide a focal

                point for applicants in their dealings with all involved agencies. Parti-

                cipation in the CAR process is voluntary on the part of an applicant and the

                agencies other than NOAA, because the Act does not explicitly require use of

                this degree of integration in th-e review process.

                    In developing the CAR process, NOAA has had extensive discussions with

                the other pertinent federal agencies, and all have made a commitment in

                principle to use the CAR process if requested to by an applicant. NOAA is

                now identifying information requirements and decision schedules related to

                811 other government authorizations and permits necessary for location,

                construction, and operation of OTEC facilities and plantships. If an applicant

                                                     -24-

                chooses not to use the CAR process, NOAA will still provide the information

                on other agency procedures and information requirements to assist the applicant

                An direct interact-ions with those agencies. In any case, the extensive

                ongoing consultations that NOAA is conducting with the U.S. Army Corps of

                Engineers, Coast Guard, Department,of the Interior, Environmental Protection

                Agency, and Department of Justice, among others, will create a sensitivity

                and commitment among the involved agencies that*will benefit an OTEC license

                applicant whether or not the CAR process is used.

                    The licensing process developed by NOAA and specified in the final

                regulations is intended to provide the orderly, timely, and efficient review

                of OTEC proposals envisioned by the drafters of the Act. As the licensing

                process  is implemented, NOAA will monitor it carefully, and make adjustments

                where necessary to assure that it in fact contributes to early development

                of a U.S. commercial OTEC industry.

                                                       -25-

                                                  Chapter IV

                                         Environmental Considerations

                  OTEC Environmental Issues Discussion Paper

                      To provide for an early and open process to determine the scope of the

                  environmental issues associated with development of OTEC licensing regulations,

                  NOAA published a paper addressing environmental issues within a month of the

                  signing of the OTEC Act. The discussion paper described the Act and OTEC

                  in general, gave several OTEC commercial development scenarios, and highlighted

                  environmental issues associated with OTEC development.

                      The discussion paper was not a draft environmental impact statement, but

                  rather a brief introduction to OTEC so that interested parties could better

                  work with NOAA in identifying the environmental issues and the more significant

                  questions to be answered in the process of formulating regulations to implement

                  the OTEC Act.

                  Environmental Impact Statement (EIS)

                      NOAA prepared an Environmental Impact Statement analyzing the environ-

                  mental consequences of OTEC development up to the year 2000 under the

                  legal regime established by the OTEC Act. The EIS also evaluated regulatory

                  alternatives for mitigating adverse environmental impacts associated with

                  construction, deployment, and operation of commercial OTEC plants.

                      The EIS concluded that although commercial OTEC development might have

                  some affect on the atmosphere, the terrestrial environmental, the marine

                  ecosystem, and various human activities in the vicinity of deployment and

                  operation sites, the net environmental impact from OTEC development would

                  be minimal compared to the impacts from fossil fuel and nuclear power

                  production. However, the uncertainties associated with the redistribution

                                                     -26-

                   of intake waters must be better assessed. The EIS also concluded that

                   minimal regulation of OTEC activities, an approach that depends primarily

                   upon existing regulatory provisions, is the preferred strategy for licensing

                   OTEC plants.

                       Potential effects from commercial OTEC plants, although less than those

                   from equivalent fossil fuel plants, include climatic disturbances resulting

                   from releasing carbon dioxide and cooling the sea surface. Significant

                   atmospheric effects are not expected as a result of single-plant deployments.

                   However, large scale deployment could result in carbon dioxide releases

                   and sea-surface cooling of a magnitude that may affect climate. Local

                   air quality is not expected to be significantly affected by emissions

                   from industrial OTEC plants producing energy-intensive products such as

                   aluminum or ammonia. Building land-based OTEC plants, like any heavy

                   industrial construction, may destroy terrestrial habitats and increase

                   noise levels and air pollution locally.

                       The majority of environmental effects caused by OTEC development center

                   on the marine ecosystem, since it is the source of evaporating and condensing

                   waters and the receiver of effluent waters used by the plant. The effects

                   can be put in three categories: (1) major (those that might cause significant

                   environmental impacts), (2) minor (those causing insignificant environmental

                   disturbances), and (3) potential (those occurring only during accidents).

                                                      -27-

                Source                                           Potential Major Effect

                   � Platform presence                           o Biota attraction

                   � Withdrawal of surface                       o   Organism entrainment and
                      and deep ocean waters                          impingement

                   � Discharge of waters                         o   Nutrient redistributi.on
                                                                     resulting in increased
                                                                     productivity

                   � Release of biocide                          o   Toxic to marine life

                Source                                           Potential Minor Effect

                   �  Release of protective                      o   Toxicity and bloaccumulation
                      hull-coating                                   of hull-coating constituents

                   �  Power cycle erosion and                    o   Toxicity and bioaccumulation
                      corrosion                                      of released metals

                   �  Installation of cold water                 o   Habitat destruction and
                      pipe and transmission cable                    turbidity during dredging

                   �  Production of low-frequency                0   Interference with marine life
                      sound

                   �  Discharge of surfactants                   o   Toxic to marine life

                   �  Operation of open-cycle plant              o   Alteration of oxygen and
                                                                     salt concentrations in
                                                                     downstream waters

                Source                                           Potential effects from Accidents

                   � Release of working fluid                    o Toxic to marine life
                      from spills and leaks

                   � Releases of oil                             o Toxic to marine life

                    Nekton populations (i.e., free-swimming organisms) will increase near the

                plant because they are attracted to the structure itself and its lights.

                Populations may decrease in downstream areas, as a result of entrainment of

                eggs and larvae and impingement of juveniles and adults. Plankton populations

                                                      -28-

                   (i.e., floating organisms) may also be reduced immediately downstream of

                   OTEC plants, because of entrainment and release of biocides. However,

                   these effects may be offset by the redistribution of nutrient-rich deep

                   water into the photic zone., stimulating plankton productivity and ultimately

                   increasing plankton populations and the numbers of fish that feed on the

                   plankton.  Benthic community effects will center primarily on their planktonic

                   larval stages, possibly reducing recruitment stocks and adult benthic

                   populations downstream of the plant. The cumulative effect of OTEC development

                   near islands may significantly affect threatened and endangered species at

                   some sites   However, this effect is not expected to be a problem for

                   commercial OTEC plant.operation in open ocean regions.

                      Thp magnitude of potentially adverse impacts can be reduced by changing

                   the plant's location'or its equipment. Siting OTEC plants away from commercially

                   important, ecologically sensitive, and biologically productive areas will reduce

                   the effects of biota attraction, organism impingement and entrainment, and

                   biocide release. Organism attraction to OTEC plants can be minimized by

                   reducing lights and noise on the platform. Organism impingement and

                   entrainment may be reduced by locating intake structures where the least

                   number of organisms are'found or by inducing horizontal intake flows which

                   fish tend to avoid.  Adverse environmental effects resulting from biocide

                   release, sea-surface temperature alterations, and nutrient redistribution

                   may be reduced by discharging the effluent waters below about 250  feet.

                   Employing alternate biocide concentrations,- alternate biofbuling control

                   measures,,and.release sch(E@dules will minimize the effects of biocide

                   release.,.

                                                      -29-

                  Technical Guidance Document

                       NOAA published a Technical Guidance Document in September 1981 to

                  help industry meet the environmental requirements of the regulations for

                  licensing commercial OTEC plants. To a large degree,. these environmental

                  requirements are based on those developed by the Department of Energy

                  (DOE) for OTEC pilot plant proposals. In spite Pf the similarities,

                  however, NOAA believed that there may be other valid approaches to meeting

                  the requirements. Accordingly, NOAA recommended that potential applicants

                  avail themselves of the pre-application consultations provided for in

                  the regulations so that the specifics of the environmental assessment

                  needs can be discussed and resolved for site-specific situations.

                       As NOAA gains experience with OTEC operations, and as information

                  is developed through environmental research, NOAA will provide additional

                  guidance to license applicants.

                  Environmental Research Plan

                       Section 107 of the OTEC Act requires NOAA to initiate a program to

                  assess:

                       (1) any short-term and long-term effects on the environment which may
                       occur as a result of the operation of ocean thermal energy conversion
                       facilities and plantships;

                       (2) the nature and magnitude of any oceanographic, atmospheric, weather,
                       climatic, or biological changes in the environment which may occur as
                       a result of deployment and operation of large numbers of ocean thermal
                       energy conversion facilities and plantships;

                       (3) the nature and magnitude of any oceanographic, biological or other
                       changes in the environment which may occur as a result of the oper-
                       ation of electric transmission cables and equipment in the water
                       column or on or in the seabed, including the hazards of accidentally
                       severed transmission cables; and

                                                     -30-

                        (4) whether the magnitude of one or more of the cumulative environ-
                        mental effects of deployment and operation of large numbers of ocean
                        thermal energy conversion facilities and plantships requires that an
                        upper limit be placed on the number or total capacity of such facilit-
                        ies or plantships to be licensed under this Act for simultaneous oper-
                        ation, either overall or within specific geographic areas.

                   Furthermore, a plan must be prepared and submitted to Congress for carrying

                   out this program.

                        NOAA and DOE both have mandates to assure the environmental compati-

                   bility of OTEC technologies. However, NOAA's responsibilities focus on

                   licensing and facilitating commercial development of OTEC, whereas DOE's

                   responsibilities focus on development of the technology. Although these

                   responsibilities are clearly distinguishable from each other, the environ-

                   mental research that is required under each is not so clearly differentiated.

                   Thus the plan by NOAA for OTEC-related environmental research is designed

                   to complement ongoing and planned DOE studies so that the two programs

                   together will meet their respective needs most cost-effectively. The

                   plan stresses the following research areas critical to NOAA's licensing

                   decisions:

                        o Interference of one OTEC plant with another,

                        o Effects of entrainment and impingement,

                        o Long-term cumulative and interactive effects (including biocide effects),
                          and

                        0 Monitoring environmental effects.

                                                       -31-

                                                   Chapter V

                                    International Impact and Future of OTEC

                   International Trade

                      While OTEC can play a major role in the generation of electricity

                   and the manufacture of energy-intensive products in the United States,

                   OTEC's potential for generating new international trade is even greater.

                      Over 90 countries and territories are located within the OTEC resource

                   area, that is, within 200 miles of waters with a 20*C. temperature difference.

                   Many of them have little or no domestic oil, coal, or hydropower for

                   baseload electricity generation, and as a result depend on imported oil. The

                   total electricity need of a large number of these countries and territories

                   is too small for use of commercial-sized nuclear plants. For those countries,

                   OTEC is the technology most likely to be chosen for generating baseload

                   electricity to meet future increases in electrical demand and, in some cases,

                   to replace existing, costly plants.

                      Development of an active OTEC plant export business by U.S. private

                   industry would serve to open up substantial international trade relation-

                   ships with countries that are not now major U.S. trading partners.

                   Initiation of trade relationships through OTEC could broaden accessability

                   of foreign markets for U.S. manufactured and consumer goods, and strengthen

                   economic and political relationships with countries that are sources of

                   strategic and non-strategic raw materials.

                      Unlike the United States, foreign countries have concentrated their

                   efforts in the export market because they have relatively few domestic

                   sites for OTEC plants. However, U.S. industry still has a technological

                   lead on the foreign competition. Once U.S. companies have built initial

                   commercial OTEC plants, they are expected to begin more aggressive pursuit

                                                      -32-

                  of exp ort markets.

                      The major competition for OTEC export markets is from Japan, Sweden,

                  and France. In 1979 the Pacific island republic of Nauru signed a contract

                  with Japanese interests for OTEC development. A demonstration test of

                  a 100 kilowatt net land-based OTEC plant on Nauru began in October 1981. The

                  pilot plant was built by the Tokyo Electric Power Company. Most of the

                  equipment was supplied by Toshiba. The plan is to operate the pilot

                  plant in a testing mode for one year to gain information on technical

                  problems, and then to build a small commercial plant to supply baseload

                  power for the island. The pilot plant is subsidized by the Japanese

                  government.

                      A Swedish OTEC group, which consists, of several Swedish companies with

                  government support, is performing site evaluations in Jamaica prior to

                  construction of an OTEC pilot plant. The reported plans are for a pilot

                  plant approximately 1 megawatt in size, followed by a commercial plant.

                      France was involved in the post-World War 11 period in OTEC work

                  in the Ivory Coast and Guadeloupe, although both projects were apparently

                  dropped before they produced commercial power. More recently, a French

                  engineering company is performing OTEC studies for the Government of the

                  Ivory Coast. The Centre National pour I'Exploitation des Oceans (CNEXO),

                  which is owned by the French government, is performing site studies in

                  Tahiti that are expected to lead to construction of a small, land-based

                  commercial OTEC plant.

                  International Law

                      The Ocean Thermal Energy Conversion Act of 1980 is firmly grounded on

                                                     -33-

                  concepts of national jurisdiction that are widely recognized in international

                  law, and the Act requires U.S. OTEC licensees to abide by the provisions of

                  international treaties to which the United States is a party. The draft

                  treaty currently under consideration at the Third United Nations Conference

                  on the Law of the Sea is not expected to raise any new barriers to OTEC

                  development by U.S. corporations. In fact, the draft text confirms each

                  coastal nation's jurisdiction over OTEC activities within 200 miles of

                  its coastline. Consequently, the domestic and international legal regimes

                  under which OTEC development can take place in a secure investment climate

                  already exist, and international law does not pose a barrier to the OTEC

                  industry.

                      The only gap in international legal arrangements that might cause

                  difficulty for OTEC development is the lack of stated rules to prevent

                  one moving OTEC plantship from interfering with the thermal resource

                  being used by another moving plantship. The U.S. law contains provisions

                  for handling this situation between plantships licensed by the United

                  States, so the potential conflict could arise only between an OTEC plantship

                  licensed by the United States and a plantshi.p licensed by another country.

                  At the present time, the United States is the only nation considering

                  development of OTEC plantships. Therefore, this problem is not likely

                  to arise in practice in the next ten to fifteen years. If another country

                  does begin development of OTEC plantships, bilateral arrangements to

                  prevent this problem could be initiated at that time.

                  Recommendations for Amending the OTEC Act

                      At the current time no amendments to the Act are recommended. NOAA is

                                                      -34-

                  analyzing several areas in which technical amendments would clarify the

                  original intent of the Act. The most significant of these relates to the

                  specific requirements for issuance of OTEC licenses for facilities that

                  are located partly on land and partly in ocean waters. This type of

                  facility is often called a "land-based" OTEC facility.

                      NOAA believes it is clear that the OTEC Act requires a license from

                  NOAA for ownership, construction, or operation of a land-based OTEC

                  facility whose input or discharge pipes are located in the territorial

                  sea of the United States. Section 101(c)(7) of the Act prevents NOAA

                  from issuing an OTEC license if the OTEC facility or plantship will not

                  be documented under the laws of the United States. This provides protection

                  against operation of OTEC facilities and plantships under foreign flags

                  of convenience. However, the specific wording of section 101(c)(7)

                  causes a problem that may, if not corrected, prevent issuance of licenses

                  for land-based OTEC facilities because of the difficulty of documenting

                  these facilities under existing U.S. vessel documentation laws administered

                  by the Coast Guard. This problem was discussed in the preamble to NOAA1.s

                  publication of final rules for Licensing Ocean Thermal Energy Conversion

                  Facilities and Plantships (46 Federal Register 39388, July 31, 1981).

                                                     -35-                 U.S. GOVERNMENT PRINTING OFFICE: 1982 360-997/2038

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