Laugh, Cry, Be Angry, Do Something...

Draft Supplemental Environmental Impact Statement for the Cassini Mission

Analysis of NASA Procedures (Final Version)

by Russell D. Hoffman Copyright (c) 1997

First published online Saturday, April 12th, 1997


These two NASA documents are not good science. They are not even science. They are nothing more than a biased review of selected data, and very little real data is actually presented.

I found my name on the back pages of the DSEIS, along with about 80 other individuals, 30 environmental, peace, and other groups, and about 30 Federal, state, and local government organizations. A quick look where my name appears might lead you to think (as it did some of my friends) that I endorse this DSEIS, or that I have at least been consulted. I have not been consulted and I do not endorse these documents!

A US EPA Notice of Availability (NOA) regarding the DSEIS was published in the Federal Register on April 11, 1997.

On May 17th, 1997 I received a letter from Mr. Earle K. Huckins III, NASA Deputy Associate Administrator for Space Science, stating that this 36-point commentary "will be addressed in the Cassini Final Supplemental Environmental Impact Statement and made available to the public". Fat lot of good that's going to do! NASA should be THROWING OUT the EIS and redoing it with good science based on the work of people such as Dr. Sternglass, Dr. Gofman, Dr. Morgan, Dr. Gould, Dr. Caldicott, and many many others. Merely answering my questions can only go so far...

After receiving the documents, I called a former director of the Health Physics Division of Oak Ridge National Laboratories, Dr. Karl Z. Morgan. Dr. Morgan is referred to as "the father of Health Physics" and stands in staunch opposition to NASA's nuclear space policies.

I started to ask him about some of the claims NASA makes in the document, but he stopped me and said it all doesn't really matter, because "it's a serious mistake to carry out such 'research'" and that all such calculations "are a bit absurd".

What plutonium particles can do:

Dr. Morgan explained to me that the way plutonium works is basically like this: when a particle of plutonium lodges in the body, the localized radiation dose to the nearby living cells from one of the "fine particles" can be 1000's of REM per year if the plutonium stays fixed in one place. If it moves around in the body, the dose will be spread out among the cells it is in close proximity to.

At that high level of radiation, nearby cells will die, but ones a little further away will survive -- and be irradiated, and possibly mutate into a cancerous form.

Dr. Morgan also explained that the incineration of an RTG would produce "a spectrum of sizes" and he added "any one of them -- they could all be inhaled. I hope our government will be more cautious in using plutonium."

This is one of the many learned scientists whom NASA is ignoring. This is someone with the facts that NASA would rather pretend not to know.

Next, I read the DSEIS documents.

These documents supplement the original "FINAL" ENVIRONMENTAL IMPACT STATEMENT FOR THE CASSINI MISSION. In that original document, some of the items in these two documents are more thoroughly discussed, but generally it is still a shallow review of the overall mission risks.

These documents are missing a lot of important information. I came up with a list of items that I think should be considered, included, or fixed. Some are major, and I suppose some are minor. But all of them should be considered, every single one, and none should be left unconsidered. I think many of the reasons can stand alone as a reason not to use nuclear power in space and not to fly the Cassini mission. Taken together, I believe NASA's position is utterly indefensible.

Cassini can be stopped any time before the FINAL MOMENT when President Clinton signs off and takes final, full, moral responsibility for this dangerous and ill-conceived mission and someone pushes the button. I would not push the button...

It is interesting to note that in every instance where I found the science appearing to be compromised, the effect allowed NASA to fudge the figures in their favor. Every single instance. That's a pattern.

On with the list:


The solar option, which has been disavowed by NASA, would allow us to do the most interesting and important experiments which NASA is now incapable of doing with the current launch configuration. The rings of Saturn are the most interesting reason to go to Saturn, and only a long-term visit, so we can observe how they change over time, will really reveal anything useful. Yet NASA's Cassini mission will end in 2004 just four years after it arrives in Saturn's vicinity! On the other hand, use of a solar option would have meant that the spacecraft, once it got to Saturn, would be operable there for decades and decades. Then a proper study of the rings would be possible. Failure to use the solar option has meant that the science is not as good or as useful as it could be.


The solar option which NASA discounts as unmaneuverable requires either four long arms, 140 feet by 11.5 feet each or two long arms, 105 feet by 30 feet. Why isn't NASA considering a circular array mounted on an articulated gimbal instead? The same area as NASA's solar array (6,430 square feet) can be obtained in a 45-foot radius circle, which would be much easier to maneuver than NASA's solar example. And lighter to build. NASA's solar option uses an archaic solar array seemingly designed for failure!


The report gives health guesses for a 50-year period. Because the half-life of Pu 238 is 87.7 years, a 500-year period or even a 1000-year period would be much more appropriate. Additionally I do not believe NASA has accounted for a doubling, or even a 10-fold or 20-fold increase in population during that time. These two factors alone can mean NASA's numbers are off by a factor of 100 or more.


Plutonium in the food chain is covered by just one sentence in these documents and by only a few paragraphs in the original "final" Environmental Impact Statement. They don't project past 50 years, yet over the next few centuries this will become (after the stuff has largely settled back to earth) the most common way that plutonium from an accident will be introduced to living beings -- especially meat-eating humans -- again and again, as part of the food chain. Considering the projection only goes out 50 years, it is clearly a topic that needs more proper analysis.


There are few descriptions of how NASA came about the many numbers they present. Are human factors such as reliability included when considering the chances of a failure? And the degree of accuracy in each number NASA supplies adds a false sense of confidence. Many of them are "accurate" to three decimal places. That is highly, highly, doubtful. Normally, scientists round these sorts of things to no more than 2 digits and a multiplier, not three digits.

An appendix containing a complete example of how they did their math would at least offer some small proof of NASA's confidence in their guesswork. A table showing the factors considered, and their weights, might go a long way towards earning the public's confidence in NASA's numbers.


Of all the reasons NASA offers for launching Cassini in the first place, probably 99% of them would still have been accomplished if the ultimate goal was something like MAG LEV TRAIN SYSTEMS or INTERCONNECTING SCHOOLS THROUGH FIBER-OPTIC TECHNOLOGY. But no. Every thing that NASA has ever accomplished or might accomplish is lobbed into "science at it's best" and the need for RTGs and a 'safe' nuclear space policy.

But in reality not only would 99% of the technology still appear, but most of what wouldn't appear, isn't wanted or needed anyway! Civilians will never need to use RTGs on earth, for example (and no one else should). So if the mission's science benefits are largely independent of the use of the RTGs, then the actual reasons for using the RTGs must be that much better if you are trying to use those reasons to justify taking a risk, as NASA is required to do. And the reasons NASA has given -- the reasons that could not be transferred to virtually any other project -- simply aren't that good.


I wonder how come the maximum worst case scenario NASA describes in the DSEIS is only about 120 latent cancer deaths? 72 pounds of plutonium is just much more deadly than that! What has happened is that before calculating what the effect of the poison will be, they have first eliminated as much as 99% or more of the poison from the calculation. They did this several ways. First, they average the releases from different accident scenarios. On the flyby, their worst-case averaged to a little more than 1/15th of the total fuel pack. This averaging is an inappropriate calculation! Then, they ignore any area that will be damaged below an EPA threshold of .2 micro Curies per square meter. This is also totally inappropriate (more on that later). Then, they further eliminate possible "health effects" by using De Minimis (more on that later too).


NASA claims that most of the RTGs will not be incinerated even in the worst of scenarios. But they are dealing with an object flying, burning through the air, that is already at about 1,100 degrees Celsius (and melts at about 2,300 degrees Celsius) AND which is in a cylindrical container with COOLING FINS which will catch the wind and burn off quickly, leaving numerous holes and cavities to rip open the RTG. Furthermore the RTGs are some of the most dense objects man puts into space (put up by some of the most dense... oh, never mind).

You can expect them to continue to travel at HIGH SPEED (=hotter) for a long, long time -- all the way to Earth impact, if they don't incinerate COMPLETELY first. They'll come in "hot", they'll come in heavy, and they can come in anywhere on Earth during the flyby. An RTG returning to Earth after a collision with a random piece of space debris or for any other reason is a disaster whether it is entirely incinerated in the upper atmosphere or not, but it is much more of a disaster if it is incinerated.

Even NASA's own estimates are that a very significant portion of the Pu 238 fuel will be released in the upper atmosphere: From 32% to 34% for all the reentry cases studied (see NASA's FEIS, June 1995, page 4-51). Of this, from 20% to 66% will be in the form of respirable particles. This is from 5 to 15 pounds of Pu 238 released at high altitude, and does not include any low-altitude and ground-level releases. That's for a "normal" reentry scenario. Any number of events can result in an "abnormal" reentry where more -- or even all -- of the fuel is incinerated.


NASA groups flyby accidental re-entries into three broad categories, shallow, steep, and skip (leave the atmosphere again). But in reality each angle presents a uniquely different scenario. The shallowest angles (that don't skip) are the most dangerous from the point of view of atmospheric incineration, while the steepest angles are most dangerous for impacts and subsequent fuel release near Earth's surface.

At the very least, each degree should be calculated separately and the result from each calculation should be graphed. It's thousands of numbers, and the resulting graphic should be presented, NOT just analyzed with only NASA's theoretical interpretation of the data presented, and no data!


NASA's "skip" scenario (mentioned above, in item 9) enters Earth's atmosphere but subsequently leaves earth's gravitational pull completely. In reality, many "skip" scenarios will have the spacecraft slowed enough to fall back to Earth in weeks, months, years -- even centuries later. Some "skip" scenarios actually have the probe skimming through Earth's atmosphere dozens of times--sort of like skipping a stone on the water, but it happens at the innermost portion of a huge elliptical orbital path. NASA's "skip" scenarios appear to never fall back to Earth under any circumstances, a fallacy.

If Cassini stays in orbit around the Earth after a flyby mishap of any sort, it will continuously be subject to the possibility of a collision with some of the existing SPACE DEBRIS and any new space debris we add while Cassini is in orbit. Therefore, "skip" scenarios where the probe eventually falls to Earth are actually the most dangerous. If the probe stays up for centuries, which it absolutely can do (NASA admits this) the chances are actually good (better than 50/50) that it will collide with existing space debris, at incredible speed and kinetic force. This would break apart the RTGs prior to upper atmosphere incineration -- making the final incineration much more thorough and much more damaging. This is a situation where 100% of the RTG fuel can be burned.


It seems that NASA has made the assumption that all "skip" trajectories would leave a clean (non-nuclear) vapor trail as they slice through the atmosphere. If NASA thinks this, they are wrong because some damage will occur to the spacecraft including possibly igniting the liquid fuel component; this damage could in turn hurt the RTGs. (But I must stress that few of NASA's actual methods are clearly described in the DSEIS.)


De Minimis is ridiculous. Since plutonium in any quantity bombards local cells with enormous amounts of radiation, and since recent cloning experiments have shown that any cell with DNA (all but red blood cells, essentially) is capable of producing an entire animal from embryo to adult, it should not be considered a great leap to conclude that all cells are also capable of becoming cancerous when mutated by radiation.

Here's the sequence: Cancer is a consequence of cell DNA mutation. Plutonium's radioactivity mutates cell DNA. Inhaling plutonium is absolutely the most dangerous way to introduce it to lifeforms, 100's or even 1,000's of times more dangerous than ingesting it. Cassini's Pu 238 is about 280 times more radioactive -- yes, that means much more deadly -- than the so-called "weapons grade plutonium" which NASA assures us isn't being used. Incinerating plutonium at high temperature and at high altitude is absolutely the "best" way to distribute it around the planet for subsequent inhalation. And finally, incinerating something that starts at over 1,000 degrees Celsius and hangs out like three sore thumbs from the space probe is just too easy.

What is a good phrase for it? You might call it a chain reaction! And when your chain runs out, you get to be a "health effect". If Cassini fails, a lot of people's chains will run out.

And if Cassini fails, the steps to cancer are not an unlikely sequence of events -- it is what will actually happen for thousands, possibly millions of people if Cassini fails. Possibly many millions. Vaporized plutonium is just incredibly, unbelievably deadly. Cassini carries enough plutonium that if just 1% of it were vaporized and then inhaled in a clinical lab situation, it would be enough to kill the entire world over without question. All 5.8 billion of us without even using any of the plutonium twice. In any actual accident scenario, much of the plutonium would be re-ingested many times. Make no mistake about it -- this is deadly stuff.

If Cassini fails, NASA has just three assurances for us against this threat: First: That only a little will vaporize. This is argued throughout this document. Second: That the world's ecosystem is so vast, that only a little of that which is vaporized will subsequently be breathed in by billions of people. But they won't even present the number they think is valid (see item 13, below). Third: That of those who do breath in some plutonium, only a very few will get cancer. But NASA will not use any of the dozens of studies of the effects of minute exposure to calculate how many might actually get cancer that way. Instead they extrapolate from a high exposure level (and relatively few cases) but the effect is not linear. Chopping in half the dosage and doubling the exposed population, then calculating that the same number of people will die, is not what actually happens. The more you divide it out, the more people will die.

And that's just what NASA's doing. Dividing it out. Here's some for you, and here's some for you. You probably didn't even know NASA was carrying plutonium on board any spacecraft before you heard about this web site, and now you think the "science" NASA will be getting will benefit you somehow? Is "worth the risk"? Face it, my fellow couch potatoes: You'll never benefit from NASA's possible knowledge gain, never, and hardly anyone else will either! And to gain all this "knowledge" NASA must use lies and deceptions, because so many Americans do know the truth, and my, they are raising a stink! But the effect is, the knowledge gain from the nuclear option for society is counterbalanced by the knowledge lost to secrecy, lies, and confusions. NASA bad science outweighs NASA good science. And the whole nuclear option -- we loose freedoms to not just nuclear terrorism, but to Government worries about nuclear terrorism. We loose honesty in Government because of the cover-ups and the lies. These we loose even if Cassini succeeds!

It's not that science isn't worth dying for, sometimes. Lots of things are worth dying for -- life, liberty, the pursuit of happiness. But this? Is it humanly possible that we cannot draw the line? That we cannot say "Ah ha! At last we have it! A science experiment so dangerous, of so little value, and so expensive, that we will not do it!" Ladies and Gentlemen, this is that science experiment. This draws the line. This is nuts.

NASA assurances are hollow. The truth is, a Cassini accident can rank as one of the biggest single manmade ecological disasters in history. Not only that, but pure chance, not fancy engineering, stands between a successful mission and a disaster. Random pieces of space debris in near earth orbit (put there by mankind, mostly) can impact Cassini and cause a catastrophic failure. Man's own potential failures just add to the risk, from loose nuts in the control room to misprogrammed software programs. We've all seen those, and anyone who writes software (including myself) knows that all software can crash and no program is perfect. NASA is not perfect. NASA is human (I think).

Is this how we want to challenge God, or the gods, or fate, or nature, or just -- the odds? THIS ISN'T SCIENCE IN THE PUBLIC INTEREST. This is roulette. The public should not fund this stuff.

Let's say something unknown to mankind's sphere of knowledge killed off, over a period of a couple of decades, one out of every 5,800 people on the planet by an ailment that manifests itself as cancer. You cannot tell where the cancer came from. You cannot tell, but you die from it just the same. One in 5,800 is very hard to study. No one would notice that an unknown thing was happening. But 1,000,000 people would die around the world from this thing. You would die, but you wouldn't know why. And even if you do suspect why, you can't do anything about it, and besides, you'll be dead and can't do anything anymore. This thing is Cassini, and it can go on killing and killing for centuries.

Cassini can do this, and you still may not be able to prove, statistically, that it happened! So if statistics are so hard to use, and NASA has used them so badly on the health side -- do you really want to trust them on the engineering side, especially considering all the engineering in the world won't stop a piece of space debris from destroying the mission anyway, during the flyby (or any time, really)? How many times do you think Fate can be tested before it gets sick of us?

There is lots of other evidence that there is NO minimum lethal dose of plutonium. Yet NASA uses something they call De Minimis. NASA's uses this De Minimis thing as a way of adjusting the data by eliminating "negligible" amounts of plutonium from the count. And who defines "negligible"? Why, NASA does, of course! .001 rem. NASA doesn't care if 5 billion people get .001 rem, to them, it doesn't count. THAT's what De Minimis and NASA's other averaging techniques does. But that's not what really happens.

De Minimis as used by NASA is NOT a standard statistical gimmick. It is a statistical gimmick they made up for themselves! De Minimis says (according to the way NASA uses it) that below a threshold of .001 rem per year there will be "no discernible health effects to an individual". Facts prove otherwise, so De Minimis is ridiculous. Besides, by first limiting the area to that contaminated above 0.2 micro Curies per square meter, NASA is taking it's ridiculous De Minimis at least twice!


One of the most important numbers is missing from the report. That number is the MAXIMUM INDIVIDUAL DOS, REM for an accident involving the RTG's during the Earth flyby. This number would show the amount of plutonium that would be expected to be absorbed by each individual on the planet in the event of an upper-atmosphere incineration of the RTGs.

Whenever this value should appear, instead there is a notation indicating the item is "Not available in the current analysis." What that means is that the study was done without one of the most crucial pieces of data! And that piece is missing from about 10 different tables (about 1/3 of the total number of tables in the two documents). A notation in the DSEIS indicated the value will be available in the final report -- but by then it's too late to argue about it! We need it NOW! (So we can argue about it, of course!)


Where are the graphs? NASA claims they are using sophisticated computer modeling to produce their report. The subcontractor company that did the Nuclear Safety Analysis used for the report, Halliburton NUS, claims (on their web page) to be "an information age veteran... in the business of finding, storing, and communicating vital information... since 1973."

All modern statistical packages generate beautiful three-dimensional graphics, and have for decades. Instead NASA gives us 19th-century tables of exponential numbers! Perhaps NASA is afraid to give us a graphic showing the plume and it's potential consequences!

By giving us good graphical depictions NASA could present us with some of the RAW DATA that they supposedly have analyzed. Then, perhaps THE PUBLIC could make their own informed decisions. But no. NASA gives us one or two numbers which actually represent complex functions, and where the very act of averaging does not do any justice to the extremes. It's a way of "punching down" the data. It is commonly used by people who want to sell you a pig in a poke. It is being used now to sell us a pig in a poke.


Why are NASA estimates of land area that might be contaminated so small? It is preposterous that only 8 or 15 square kilometers will be contaminated in a "worst case scenario" but that is what NASA's averaging techniques and their other techniques have left us. They are going about it all wrong. A more reasonable approach would be to figure out how BIG an area CAN be contaminated (for example, to a 50% lethal dose) with 72.3 pounds of Pu 238 particles in millions of pieces and millions of sizes, from all altitudes and directions, and then figure out what the chances really are of that actually happening. These are separate calculations, which should not be lumped together in a report. Nowhere is the stark reality expressed of what 72.3 pounds of incinerated plutonium can do, least of all, in an informative computer-generated graphic.


If Cassini is as safe as NASA predicts, then why won't NASA and the United States Government insure it properly? Instead they use the archaic and inappropriate Price-Anderson act, which limits our international liability to just $100,000,000.00 in direct violation of an international Outer Space Treaty we co-wrote and signed. Domestically, Price-Anderson limits liability to about $7.3 billion, also hopelessly inadequate. If Cassini is safe, why do they limit the insurance payout at all?


Even accepting (more or less) NASA's numbers is NOT a sustainable policy for safe space research (or for plutonium disposal). Some people right now want to put 820 satellites in orbit, for example, for just one communications project. If nukes are OKAY, then all of those might be nuclear powered. Nukes aren't okay for one mission, and they aren't OKAY for all of them. What we really need are fiber-optic cable systems throughout the world, not expensive, failure-prone, corporate-controlled and dangerous satellites.


SPACE DEBRIS impacts can completely destroy the RTGs prior to (and causing) an Earth re-entry. Where is this specific scenario analyzed?


You can't just say "each person will get this" or "that" amount -- Some will get larger particles, or more of them, and some will get less. It's a distribution. With BILLIONS of exposures, many people will receive 10 times the "average" dose -- a few unlucky individuals -- thousands, maybe even millions of individuals -- may even receive a hundred times the "average" dose. That's what happens when you irradiate the world through upper-atmosphere incineration of plutonium. So the numbers need to be "crunched" to reflect the varying sizes of the particles and the distribution of them. Any incinerating nuclear payload from outer space -- not just Cassini but any nuclear payload -- is a fierce fireball of filthy death.

I believe what NASA has done in averaging the doses is wrong. They have taken the amount of plutonium they think might be released, and theoretically spread it evenly among the exposed population. But first, they eliminate all who live where they will be exposed to a dose lower than the EPA standard measurement value per meter (using this value at all is inappropriate, but they use it). Then they further eliminate all those who would get less than .001 rem per year (equally inappropriate). Then they eliminate potentially 1/2 the world population -- or more -- for no good reason, by simply using a baseline of the expected population at the time of the flyby. But the damage will continue to occur for centuries after, or may not even start to impact Earth for decades or centuries, and the population will continue to grow in a world crowded today with 5.8 billion people.

Each step eliminates health effects from view.


The inappropriateness of using the EPA limit mentioned above is clear when you consider study after study has shown that there is no minimum lethal dose of plutonium. At least three different ways to study it lead overwhelmingly to the same conclusion. First: You can study it by giving extremely small doses to extremely large populations of laboratory animals, large enough to be able to pass standard scientific tests of statistical significance. This is very hard to do, because you need tens of thousands, or even hundreds of thousands (or even millions) of animals to do the study, but to as much an extent as possible, it has been done. Second: You can study it by looking at publicly available data from health officials and radiation monitoring officials and compare the two sets of values. Dr. Sternglass, Dr. Gofman, Dr. Gould and many others have published numerous papers and books doing just this. Third: You can study the possible mechanisms within the body which would allow plutonium to "do its thing" at extremely low levels. And studies of mechanism after mechanism consistently point to the conclusion that there is no minimum lethal dose of plutonium. Any size particle can kill you. Maybe it will, maybe it won't, but it can and studies show that it does. Studies NASA won't use in their analysis.


NASA's use of the EPA guideline is actually even more inappropriate than described above (in item 20). If the EPA guideline says that a cleanup need not be attempted below a certain threshold (for whatever reason) that doesn't mean that it's just fine thank you to pollute beneath that level. But that is the logic NASA has taken. They have taken a good thing -- an EPA standard (which may be way too high, but at least it's something) -- and turned it into a excuse to pollute! 72 pounds of plutonium is 72 pounds of plutonium no matter how you dress it up or spread it out.


Out of 400,000+ Ci (Curies) total amount of radioactivity in the RTGs, NASA's worst case accident scenarios will "only" release about 26,000 Ci. Thus, NASA will not present any study on the effect of greater than about 1/15th of the total plutonium fuel being incinerated. This is preposterous. Space debris, as mentioned above, below, and all around the globe, can easily and randomly destroy an RTG. Even if we accept the assumption that it is relatively unlikely that all three RTGs would be hit by space debris (although space debris actually often does come in clusters), still, at the very least, since there are three RTGs, NASA should show health effects for at least 133,000 Ci released in an upper-atmosphere incineration. And at least a partial burn of the other 2 RTGs. If any of the other fuel onboard Cassini is hit, that could then incinerate one or more RTGs. The liquid fuel being carried onboard Cassini weighs more than entire previous probes like Galileo and Voyager (combined)! So that is perhaps 260,000 Ci -- 10 times more than NASA's "average". NASA needs to show the health effects, the geopolitical consequences, and the financial burdens of these scenarios!

We can leave it to Hollywood to show the effect of it coming down on New York City, say, on December 31st, 1999. (It can orbit for a while before crashing, so it really can come down anywhere, anytime.)

If Cassini is as safe as NASA claims, why can't they show a computer model of it landing on a city and tell us how many would die! A shallow reentry, burning 1/2 the RTGs, the wind to its back so the fallout collects and lands on Manhattan... and it lands on Time's Square, New York, December 31st, 1999... (If I'm around, I'll probably be there, and I'll probably be passing out leaflets.) What would happen? (From my leaflets?)

If Cassini crashed the world's biggest party: Not one building would get destroyed. But within a few weeks: 50 million people doomed. That's what would happen. (From the initial event. Decade after decade, people would continue to die.) Oh, and: Maybe a couple of buildings would be destroyed, too. The RTGs will ignite anything they land on, since their "resting" temperature is about 1,100 degrees Celsius, and they would have just flown in from outer space using air friction against blunt surfaces as their only braking force. Okay but what are the chances of that actually happening? Zero if we don't launch!

Why is NASA afraid to show the effect Cassini can have on any teaming metropolis on the planet? Just so we all know what we're talking about: NASA certainly admits it can happen. Why won't they tell us what the effect would be? Their little space probe can do all that, and it doesn't take a long chain of events, either. One pea-sized piece of space debris alone can make this an inevitability. One single Random Event. Cassini has a "one hit" capability on a concentrated population center that is so devastating, it should be prevented by being prohibited.

When did we decide we should permit underpaid and overeducated scientists (or vice-versa, or anyone else) to risk random destruction on so vast a scale? They know they can't stop it from happening... It's just chance. They just claim they can reduce the chance. We don't really mind letting scientists blow up their own science labs -- fine. Have fun. Knock yourself out. But the proper way to reduce the risk to the planet on something like this is to eliminate the possibility of it happening. The money can go towards even higher-tech activities elsewhere.


I just want to make sure that when NASA says that the RTGs will not break apart if they hit water, only land, that they include ICE as "land". The plutonium RTGs and their subassemblies will smash into fine particles and chunks if they impact on ice. Some would vaporize. Larger chunks and particles would melt through the ice to solid ground, making it almost impossible to retrieve the pieces quickly in places that are snow- and ice-covered at the time of the accident.


Plutonium in the food chain is bad for people that eat food, but it should not go unnoticed (as it does in all NASA documents) that it is also bad for the food--bad for plants, bad for animals... Mankind will not be the only animal to get cancer and other illnesses should Cassini fail. In fact, for every human injury there will probably be tens of thousands of animal injuries. Do we want to inflict this pain, this suffering, on our fellow creatures, whom we have been charged with protecting, by nature of our being here at the top of the food chain, and (supposedly) being smarter as well? Do we want to inflict this insult on our fellow creatures, while relying on them for our sustenance, for work, for companionship? What are the radiological consequences for cats, dogs, cows, horses, pandas, or our close friend the pig? What are the effects on mice, rabbits, and other science experiment fodder? Then what are the effects on future science experiments? None of this is discussed in any NASA document, and it is devastating.


RTGs are NOT aerodynamic by any stretch of the imagination, and they are heavy and have a series of pipes, valves, and other hardware. They WILL incinerate, and NASA predictions of just how much should be taken with a healthy dose of salt (with iodine, I presume).


Speaking of iodine, in the event of an accident at launch, exactly what preparations, such as storing millions of iodine pills, has NASA taken to mitigate the effects? Since proper steps can reduce the danger, one would think that NASA and DOE have calculated the health effects numbers on the assumption that there will be adequate assistance from NASA after an accident.

But will NASA provide this assistance, worldwide, in a timely manner, 500 years from now when the probe might still be capable of falling back to earth? Or will NASA provide this assistance in some war-torn part of Africa in October, 1997, if something goes wrong during early lift-off?


Since NASA is doing a SUPPLEMENTAL analysis, I think it makes sense that NASA should study the effects of the nuclear-payload-equipped Russian Mars '96 probe which recently incinerated, probably over Chili and Bolivia. This will take, as NASA knows, about 500 years to study properly. But the most crucial time to begin any study is now. And, NASA could test its cleanup procedures, starting with seeing if NASA can even FIND a nuclear payload that's been at least partially incinerated in the upper atmosphere, let alone seeing if NASA can actually clean up the mess. If nothing else, NASA has already shown that they are incapable of responding quickly to a changing situation.

One would think they would want to try to find that plutonium powerpack to see how well it actually survived re-entry. Since Russia sells us the plutonium and works with us on numerous nuclear space projects now, the similarities are probably significant.

Yet NASA is hardly studying it at all! Nothing in the DSEIS indicates they even noticed it. As usual, NASA is making no effort to find out the truth.


There is no discussion of safe disposal of the radioactive byproducts (there are many) from isolating Pu 238. The stuff not destined for Saturn is still capable of poisoning Earth and has half-lives of around 25,000 years, and is highly radioactive. It will be NASA's responsibility for the next 500,000 years or so. The risk entailed in that isn't described in this report, and the cost isn't in any accounting reports I've seen, either... 10,000 years from now, even 100,000 years from now, NASA will be demanding money from your descendants for the upkeep on its nuclear waste facility used to store the byproducts being created today for "your" Cassini mission. That cost is not reflected in any NASA documents.


Global implications (1): What if every country started to use the nuclear option? Sooner or later a firey accident would occur which might start a war, if for example an Iranian nuclear satellite plummeted onto Israel (or vice-versa). Nukes have no place in space! If Cassini fails, it could topple governments. If Cassini fails, Mr. Clinton, it will certainly ruin your party!


Global implications (2): Political catastrophes accompanying a failure of Cassini -- these are not discussed in any NASA document I have seen anywhere! What is the appropriate document for these very important considerations?


Global implications (3): Although NASA describes several clean-up scenarios (costing up to $1,000,000,000.00) it doesn't describe who will pay for this. And the costs given do not include loss-of-property and loss-of-life costs, just clean up costs. And where does NASA think it can put all that poisoned dirt, anyway? Earth is a closed-loop system.


Global implications (4): "No effect" is the way NASA describes the "no launch" alternative and it is the way they have always described it. But is that correct? NOT AT ALL! $3.4 billion dollars to clean up underfunded "Superfund" toxic waste sites, to interconnect the classrooms of America, to lay fiber-optic cable... That's not "no effect", that's progress. And that's just the "counter-balance" to a successful Cassini mission! If anything goes wrong, even with no release of plutonium, we're still out the money! If we had invested in kid's education, on the other hand, we would reap the benefits for decades -- including, perhaps, even more important discoveries than anything Cassini will bring if it succeeds completely!


The DSEIS says that President Clinton has his own separate Cassini impact analysis. But it also says that the President's document is derived from substantially the same databases as the DSEIS and its results should be similar. Are geopolitical implications discussed in the Presidential statement? Can the public see it? Who wrote it for the President? The same company that wrote the Nuclear Safety Analyses for Cassini Mission Environmental Impact Statement Process? Will they give President Clinton another, unbiased view?


What NASA has presented is not DATA to support their claims -- it is just the claims. They have distilled the information into a small set of numbers which is totally inappropriate for the complexity of the problem. They have clipped at every angle, from who should be counted to how much plutonium they might receive. They have held back vital information. They have used inappropriate studies of high-rem damage to extrapolate low-level damage, and they have ignored perfectly well-researched, easy-to-obtain reports in respected and refereed journals, reports which have shown that low-level radiation is 100's to 1,000's of times more dangerous than the large "shock treatments" of 10 to 50 rem which they choose to study.

This draft, as written, assures us of nothing.


The global model that NASA uses to do their modeling divides the world into 720 "grid boxes" of equal size. This is not nearly enough for an accurate model since the incinerated plutonium in millions and millions of tiny particles will be carried by the wind, which exhibits a much-too-complex behavior pattern to determine in just 720 grid boxes. If someone were to try to prove global warming, for instance, with so few grid boxes, they would probably be laughed out of the science halls!


NASA's contractor on the DSEIS is Halliburton NUS Corporation, a part of NUS Information Services, Inc. They did the basic study under contract to our government. This company describes itself (at it's web site, at the time of this writing (4/9/97)) as doing the following for a living: "Information Services' staff members use a total of more than 50 internal and external data bases and 70 million pages of text to find solutions for more than 660 electric generating units worldwide."

Another thing they do is run a Licensing Information Service, described by them at their web site as "Serving the nuclear industry since 1973 with a variety of regulatory information."

But perhaps the most interesting thing they do is sell a Computer-Aided Regulatory Library. It is described by them at their web site (at the time this was written) as: "[A] CD-ROM library full of Nuclear Regulatory Commission documents that can be searched and manipulated in numerous ways by the powerful [software]." Manipulated. I couldn't have said it better myself.

Clearly they are part and parcel a pro-nuclear organization masquerading as an information service. The fox is guarding the henhouse, except here, the henhouse is mother earth. If Halliburton NUS have 70 million pages of text available to them, why oh why don't they know about the hazards of extremely low levels of radiation to woman's breasts, to infants, and to fetuses? Why doesn't NASA know of Dr. Sternglass's work, if this wonderful information company is so thorough at providing information? There is not one word in the DSEIS on breast cancer, not one word on damage to fetuses, and not one word on any specific cancers at all! All the studies were done as if the effects were universal -- the same for all people. They aren't. Specifically, woman, fetuses and infants will suffer the greatest insult if Cassini fails. Nowhere -- absolutely nowhere -- is this discussed in any NASA document that I can find. Certainly not in this important one. This document only covers death, and it doesn't even do that very well. Instead it covers-up death. It's all a shell game -- but they're using live shells!

In reality NASA's "research" just proves one thing: that NASA does not dare to present -- or even consider -- the true possibilities of the situation.

By Russell D. Hoffman

NASA's draft document will remain open for review until 4:30 pm, (Eastern Daylight Time) May 27th, 1997. So this important next step -- demanding more answers -- is coming to a close soon.


You can order a copy of the Draft and accompanying Nuclear Safety Analyses, and the original "Final" EIS and other NASA documents directly from NASA. Or -- since it's getting late (Cassini launches in October, 1997) -- you can cut right to the chase and start contacting our elected officials right away. For example, print this document, and circle the points you think are most important, and tell NASA you will personally want to see them properly answered in NASA's upcoming SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT. Send the document, with your notes, directly to NASA before May 27th, 1997. Send a copy to your local press. Send a copy to the White House, too! And tell President Clinton that his "private" Cassini report needs to answers these charges as well. Or save trees and time (and we're almost out of time -- and trees): Email him the same message.

Mark R. Dahl, Program Executive,
Cassini Mission & Payload Development Division
Office of Space Science, Code SD
NASA Headquarters
Washington DC 20546-0001
Comments to NASA had to be submitted in writing and received at that office no later than 4:30 pm Eastern Daylight Time, May 27, 1997. This is my answer.


Things you can do today:

Related pages at this web site:
Stop Cassini Home Page
No Nukes In Space! Not now, not ever.
Space Debris Home Page
A series of articles on this shameful problem.

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Written April 9th, 1997.
Last modified May 27th, 1997.
Webwiz: Russell D. Hoffman
Copyright (c) Russell D. Hoffman