DoE Plutonium plans (comments sent by the public) Date: September 19th, 2000


From: Russell D. Hoffman
To: Stop Cassini/NKS subscribers, others Re: DoE Plutonium plans (comments sent by the public) Date: September 19th, 2000

To Whom it may Concern:

The attached emails were sent by Hans Karow and Author Doucette to DoE, and we thank them each for sending us a copy. If anyone else wishes to see their messages to DoE distributed to the Stop Cassini subscriber base please send them in!

Sincerely,

Russell Hoffman
concerned citizen, activist
former (?) editor, Stop Cassini newsletter (contact info follows three (3) attachments)

*** Attachment #1: Letter to DoE from Hans Karow *** Attachment #2: Letter to DoE from Author Doucette *** Attachment #3: Congressional website/legislation information

***************************************************************** *** Attachment #1: Letter to DoE from Hans Karow: *****************************************************************

VIA E - MAIL

September 18, 2000

Attention:

Mrs. Colette E. Brown

U.S. Department of Energy, NE-50,
19901 Germantown Road, Germantown, MD 20874-1290; fax (toll-free) 1-877/562-4592; 1-877/562-4593; E-mail Nuclear.Infrastructure-PEIS@hq.doe.gov

Re: DoE PLANS FOR EXPANDED PRODUCTION OF PLU-238 FOR FUTURE SPACE MISSIONS, specifically, solicited comments based on the DRAFT Programmatic Environmental Impact Statement for Accomplishing Expanded Civilian Nuclear Energy Research and Development and Isotope Production Missions in the United States, Including the Role of the Fast Flux Test Facility, DOE/EIS-0310D, July, 2000

Dear Mrs. Brown,

I refer to the letters/e-mails to you from Jonathan Mark (September 14, 2000) and Russell Hoffman (September 9 and 14, 2000) with regards of the above mentioned matter.

I fully support both letters and like to express my deepest concern.

I became aware of the nuclear issue with the Cassini deep space mission and have contacted eminent independent scientists and researchers myself . I also have regularly contacted Prof. Karl Grossman, whom we have to thank that he made the Citizens on Earth aware about the nuclear issue with his book and two videos.

I hereby ask you and the relevant U.S. Government Departments that any further production and use of nuclear fuel (including all nuclear waste products) are to be stopped for the reasons giving below in a fact sheet about Plutonium also downloadable at:

http://www.animatedsoftware.com/cassini/nltrs/nltr0139.htm

I kindly ask you to please acknowledge my letter to you, and I especially ask you to please correct my findings about the Plutonium's fact, which I was also able to gather upon contacting a few independent eminent scientists and medical doctors. Please state where I am wrong. Please note: the fact sheet I wrote before Cassini's planned Earth fly-by. The facts about Plutoniums accidental release in/on/above Earth and in space are still valid, no matter in which project involved.

In deep concern,

Hans Karow,

former Coordinator of the Cassini Redirection Coalition (CRC)

S 32 / C 6, RR # 1

OLIVER, BC, VOH 1T0, CANADA

Tel./Fax: (250) 498 3135

Fax: (250) 498 3183

E-mail: core@vip.net

xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

Facts about Cassini's Plutonium

The Cassini deep space mission to Saturn must be redirected to avoid its planned high risk Earth fly-by this year on August 18. Although a safe alternative solar technique was available instead of the use of Plutonium, NASA ignored worldwide warnings.

Here are some facts about Plutonium (Pu) that everybody should know about:

Pu was plentiful on Earth when it was first formed. Life did not appear on Earth until the Pu had decayed to Uranium.

Pu, almost entirely a man-made element, is a radioactive and highly toxic substance. Pu was first isolated in large (milligram) quantities in 1942 by Dr. John W. Gofman, who headed the Manhattan Project's Plutonium Group (Hiroshima and Nagasaki bombs).

Once it enters the body through inhalation, ingestion, or through a cut, it becomes an internal emitter that emits highly destructive radiation to the body tissue in which it concentrates. It is akin to an internal X-ray machine.

When lodged within tiny airways of the lung, Pu particles bombard surrounding tissue with alpha radiation. Smaller particles may break away from larger aggregates of the compound to be absorbed through the lung and enter the bloodstream. Because Pu has properties similar to iron, it is combined with the iron-transporting proteins in the blood and conveyed to iron-storage cells in the liver and bone marrow, inducing liver and bone cancer, and leukemia. Pu's iron-like properties also permit the element to cross the highly selective placental barrier and reach the developing fetus, possibly causing the development of abnormal structures in an embryo resulting in a severely deformed fetus and subsequent gross deformities in the newborn infant.

Pu can also migrate to the testicles and ovaries where it can cause genetic mutation to be passed on to future generations.

No quantity inhaled has been found too small to [be able to] induce lung cancer in animals. It has also been found, by any reasonable standard of scientific proof, that there is no safe dose or safe dose-rate of ionizing radiation, meaning there is no safe threshold.

It has been estimated that only one pound of Pu-238, if uniformly deposited in the lungs of the world's population, would be enough to induce lung cancer in everyone on Earth.

In the event of Cassini's accidental atmosphere re-entry during its planned Earth fly-by, or any other time due to a loss of control and subsequent random collision, its 72.3 pounds of Pu would get vaporized into invisible particles and spread as a dust all over the world. Even though over four tons of Pu-239 were released during atmospheric nuclear bomb testing, Cassini's 72.3 pounds of Pu-238 would carry more radioactivity than all the Pu-239 from the bomb tests.

The cancer rate will increase (humans and animals), induced over years by Cassini's accidentally released Pu.

If Pu is released into the environment, there is no way to stop its radioactive decay. As it decays, it produces the highly dangerous alpha radiation mentioned above.

Pu cannot be destroyed by any means. Pu does not disappear in the environment. It is not water-soluble. As a dust it easily becomes airborne. Once dispersed into the environment it can mix with organic substances forming compounds that can enable it to be taken up in bodies of all live species: plants, animals, and humans.

A Pu particle constantly produces radiation - and can harm any living thing, whether human, animal or plant, that it enters, also meaning as many times as it changes its living host. If someone were to die of lung cancer induced by Pu and were cremated, contaminated smoke might carry that Pu particle into someone else's lungs. If an animal dies or is killed, its meat may be eaten by other animals or humans. Or it rots and its poisoned dust could be scattered by the wind and inhaled by other creatures. Pu-238 will be radioactive over more than 800 years [~10X the half-life -- rdh] (14% of Cassini's Plutonium consists of Pu-239, being radioactive for over 240,000 years [~10X the half-life -- rdh], although somewhat less toxic than Pu-238). Once Pu is deposited in the lung, there is no way to remove it from the lung and there is nothing that medical science can do to reduce the risk of lung cancer.

In case all vaporized Pu particles are of the size of the invisible 1,000,000 atoms-particle, there will be about 1.63 x 10^5 particles per square meter (163,000 particles!) of Earth's surface (including water surface) awaiting all living on Earth, to be absorbed over and over again for many generations!

All the above facts have been retrieved from Professor Karl Grossman's book " The Wrong Stuff", "The Stop Cassini" web site http://www.animatedsoftware.com/cassini and the "Cassini NoFlyBy Action Site" http://www.nonviolence.org/noflyby and upon contacting eminent medical doctors and physicists.

Hans Karow

Coordinator, Cassini Redirect Coalition (CRC)

***************************************************************** *** Attachment #2: Letter to DoE from Author Doucette: *****************************************************************

FYI

-----Original Message-----
From: Arthur Doucette
Sent: Monday, September 18, 2000 12:21 PM
To: 'Nuclear.Infrastructure-PEIS@hq.doe.gov'
Subject: Re-establishing production capability for Pu-238

Re: Use of Pu-238 for space based power supplies:

I am totally against this for many reasons:

Considering what happened to the Mars Polar Lander it is obvious
that NASA's "one in a million" chance of the spacecraft impacting earth
was grossly overstated. What if the day after Cassini crashed into the
earth, impacting Manhattan, we all got to read in the papers the next day:
"OOPS, the contractor was working in Lbs. and JPL was using Kilos". Prior
to the Polar Lander, I'm sure no one would have believed such a
inconceivably silly mistake could occur.

Since NASA must agree that the odds were really not one in a million
but with just one more data point added by the ill fated Polar Lander more
like one in a thousand then one must also agree that NASA's extrapolation
of potential risk which was partly based on this estimate was also
understated and that at least some of the concerns of those opposed to the
launch/flyby turned out to be well founded.

I do not believe that anyone, including NASA or DOE, could or has
accurately simulated the forces exerted on a non-aerodynamic 6 ton
spacecraft entering the atmosphere at 42,500 MPH. I don't believe we have
the technical ability to accelerate an object even a fraction of the size
and shape of Cassini to over 62,000 feet/sec. on the earth's surface! As
far as the forces involved, to put it in perspective, Casinni's weight is
almost the same as our Apollo Command module. Apollo's re-entry speed was
only about 1/2 of Casinni's potential re-entry speed. The Apollo re-entry
had to be precisely flown to within a degree or so in order to keep the
approach angle shallow enough that the energy of re-entry was dissipated
over sufficient time to keep the shield temperatures down to a manageable
5,000 degrees F. Apollo gave up over 86,000 KiloWatts of energy during
it's controlled approach, Casinni could have easily arrived at the earth's
surface with that much energy or more still left. On a perpendicular
trajectory it would traverse the atmosphere in a little over 10 seconds
and hardly slow down at all. Does the DOE realize the destructive force of
a 6 ton object moving at this speed impacting almost anywhere? What about
in a densely populated area? To claim that the RTG's could withstand an
impact into the earth's surface at these speeds and potential temperatures
and remain intact was and is preposterous.

Given that NASA agrees that there was a risk and that the argument
is really about the level of risk, where is the justification that there
is anything we will learn from Saturn or the other outer planets that
warrants taking this risk? Is NASA just assuming it is worth the risk when
they support these deep space probes using plutonium? We have sent many
deep space probes with RTG's, can NASA name just one life which has been
saved or even extended a short while because of what we have learned?
Could NASA list just one improvement to mankind that has come from what we
have learned from ANY of our deep space probes? Can NASA point to any
potential improvement to mankind that couldn't be achieved without a RTG
powered space probe?

NASA believes that "Other than plutonium generators, there is no
practical source of electrical power for spacecraft that go to the outer
planets." Has NASA considered that maybe we shouldn't explore them until
we can develop a SAFE and practical source of electrical power for deep
space travel? Is it not possible that if we spent the same 3 Billion in
research to develop such a safe and practical source of power that the
research could also have many practical benefits to those of us back on
earth? In the article by Dick Thompson (Time) he writes on this issue:
"What will be lost if Cassini is canceled? As Galileo's spectacular images
of Jupiter and its moons showed last spring, an extended visit is really
the only way to study a distant planet. Saturn's rings are perhaps the
most mysterious and magnificent objects in the solar system. Its moon
Titan has its own atmosphere, filled with organic chemicals; scientists
suspect it's just the sort of place life could have gained a foothold.
Pulling the plug on Cassini now, when we're on the verge of exploring such
a place, would be a missed opportunity of astronomical proportions."
While this is stirring prose there is really nothing of substance alluded
to, no actual benefits to be gained. The fact is Space exploration is
direct science not applied science. Any benefit we get from this is
coincidental and with Space Science, any coincidental benefits are most
likely to be gained only after extremely long spans of time. Therefor
delaying the probes for a decade or so, until they can be made safely has
no negative impact on anyone and the chance of discovering something
coincidentally valuable while developing the required safe power systems
is equally great so in reality, nothing is lost. Any money spent on Direct
Science is a gamble and we never know the odds.


I'm particularly not in favor of using the earth for gravity assists
to the outer planets and certainly not when they are carry plutonium 238
power supplies. Several key issues are risk Vs reward and potential
terminal damage to public support for space exploration. I'm sure that if
Cassini had hit the earth or atmosphere, that future use of RTG's on space
probes would become problematic and that deep space research in general
might be significantly curtailed. I believe this would be true regardless
of the measured health impact of the plutonium on board. What was the
probability of Cassini hitting the earth? Certainly not high, but then not
as low as NASA was saying either. The final trajectory towards the earth
was planned such that in almost every failure mode of the final course
correction, the failure would result in Cassini missing the earth by a
wider margin then planned. The danger was in navigation errors prior to
the final burn which is exactly what caused MPL to impact on Mars. When
they did the final burn for the MPL it was not where they thought it was
because of previous navigation errors caused by improper calculation of
the spacecraft's weight. The other dangers include loss of communication
with the spacecraft due to mechanical damage: antenna not unfolding,
micrometer impact or the not uncommon unexplained failure. Because of the
path the spacecraft needed in order to use Earth as a gravity assist then
failures of this type could leave Cassini in a near Earth orbit, i.e. if
it didn't get all of the three specific gravity assists it needed it would
never get the energy needed to accelerate to Jupiter for it's final assist
to Saturn. If it got stuck in a near Earth orbit then given time its
likely hood of impacting the Earth go way above the likelihood of the
final course correction causing a problem. The plutonium on board would
remain a problem for thousands of years.


The second area I am in disagreement with NASA is on the toxicity of
plutonium. Specifically plutonium 238 which comprised 71% of the plutonium
on Cassini. (13% P239, 2% P240) - an important point is that plutonium
decays into americium and it has its own set of problems, in fact decayed
plutonium is considered more dangerous then the starting material. I have
included several references from respected sources, none from fringe
scientists or others with their own agendas.

The first is from the Univ. of Penn. on the health risk of Plutonium based
on its form:

On the other hand, plutonium inside the body is highly toxic. Solid
plutonium metal is neither easily dispersed nor easily inhaled or absorbed
into the body. But if plutonium metal is exposed to air to any degree, it
slowly oxidizes to plutonium oxide (PuO2), which is a powdery, much more
dispersible substance. Depending on the particle size, plutonium-239 oxide
may lodge deep in the alveoli of the lung where it has a biological
half-life of 500 days, and alpha particles from the oxide can cause
cancer. Also, fractions of the inhaled plutonium oxide can slowly
dissolve, enter the bloodstream, and end up primarily in bone or liver.

Plutonium oxide is weakly soluble in water. If it is ingested in food or
water, only a small fraction (4 parts per 10,000) is absorbed into the
gastrointestinal tract. However, it may take just a few millionths of a
gram to cause cancer over time. In animals, small doses induce cancer,
especially in lung and bone.

Plutonium's Risk to Human Health Depends On Its Form
Last Revision Date: Thursday, 26-Aug-1999 23:27:58 EDT
Copyright 1994, The Trustees of the University of Pennsylvania

The point of this article is that the most dangerous form of Pu is the
oxide which is what Cassini's fuel consisted of.

The next is from the DOE funded Amarillo Natl. Research Center (ANRC)
which basically says extremely small particles of Pu inhaled will cause
cancer:

The main danger from plutonium comes from inhalation. If inhaled,
plutonium can become stuck in the tissues of the lungs (if the particles
are smaller than one micron - .00004 inches - in diameter). Although the
radioactivity of plutonium is not high, the radiation would be
concentrated in a single place, and because the plutonium would be in
direct contact with sensitive tissue, the alpha particles could damage the
lungs, this damage would typically show up as cancer after a period of
years.
ANRC
The U.S. Department of Energy and the State of Texas formed the Amarillo
National Research Center (ANRC) to conduct scientific and technical
research, advise decision makers, and provide information on nuclear
weapons materials and related environment, safety, health and
non-proliferation issues.

The next is from the Lawrence Livermore National Laboratory in a
very well written study on the toxicity of plutonium.
This section deals with determining the risk factors, the appendix is the
supporting calculations:

The total effective dose equivalent defined in Limits for the Intake of
Radionuclides by Workers, International Commission on Radiological
Protection (ICRP) Publication 30 (Pergamon Press, Cambridge, UK, 1979), is
a weighted sum of organ dose equivalents multiplied by appropriate risk
weighting factors. [10] These values are based on effects observed at
relatively high exposures. The usual (and conservative) assumption is that
the risk of getting cancer at lower exposures is linearly related to the
exposure. This risk would be in addition to the natural incidence rate of
fatal cancer, which is approximately 20% for the United States population.
Thus, if an individual inhaled 0.0008 milligrams of plutonium, that
individual's risk of developing fatal cancer as a result of this exposure
would be increased from 20% to 21%. If each of 10 individuals inhaled
0.0008 milligrams of plutonium, the probability that one of them would get
cancer would be 10%, since each individual has a 1% risk. That is, the
probability of a cancer appearing in an exposed population depends simply
on the amount of plutonium collectively inhaled. For each 0.08 milligrams
of plutonium inhaled by the exposed population (regardless of the size of
the population), one additional fatal cancer would be expected to occur.


Appendix A. Risk and Dose Vs Plutonium Intake
The cancer risk associated with the inhalation or ingestion of a given
amount of plutonium can be determined as the product of three quantities:
(1) the activity (activity is measured in curies) of plutonium per
milligram, (2) the dose (measured in rem) delivered per unit of plutonium
activity taken in, and (3) the risk of cancer per unit dose of radiation
delivered to the body by that plutonium. The calculations below follow
that pattern.

For inhalation, we have

.08 millicurie/mg X 3.1 X 10XX5 rem/millicurie X 5 X 10XX-4 Cancer/rem =
12 cancer/mg

which corresponds to 0.08 mg/cancer.


For ingestion, we have

.08 millicurie/mg X 52 rem/millicurie X 5 X 10XX-4 Cancer/rem = .0021
cancer/mg

which corresponds to 480 mg/cancer.


References for the quantities given in the expressions above:

0.08 mCi/mg: Homann, S. G., HOTSPOT Health Physics Codes for the PC,
Lawrence Livermore National Laboratory, Livermore, CA, UCRL-MA-106315
(1994).

rem/mCi (inhalation), and 52 rem/mCi (ingestion; we have used , the value
appropriate for plutonium oxide, for the fraction of plutonium absorbed
from the GI tract into the bloodstream): Limiting Values of Radionuclide
Intake and Air Concentration and Dose Conversion Factors for Inhalation,
Submersion and Ingestion, U.S. Environmental Protection Agency,
Washington, DC, Federal Guidance Report No. 11 (1988).

cancer/rem: ICRP 60 (Ref. 25).

A Perspective on the Dangers of Plutonium W. G. Sutcliffe, R. H. Condit,
W. G. Mansfield, D. S. Myers, D. W. Layton, and P. W. Murphy. Lawrence
Livermore National Laboratory, April 14, 1995

The problem with the previous article is it dealt with P239 in it's
calculation. As it turns out P238 is far more dangerous, in fact as the
following excerpt from the ATSDR shows the radiation per gram of P238 is
260 times as great as P239:

Plutonium has been released to the environment primarily by atmospheric
testing of nuclear weapons and by accidents at weapons production and
utilization facilities. In addition, accidents involving weapons
transport, satellite reentry, and nuclear reactors have also released
smaller amounts of plutonium into the atmosphere. When plutonium was
released to the atmosphere, it returned to the earth's surface as fallout.
Average fallout levels in soils in the United States are about 2
millicuries (mCi)/square kilometer (about 0.4 square miles) for
plutonium-239 and 0.05 mCi/square kilometer for plutonium-238. A
millicurie is a unit used to measure the amount of radioactivity; 1 mCi of
plutonium-239 weighs 0.016 gm, while 1 mCi of plutonium-238 weighs 0.00006
gm.

Agency for Toxic Substances and Disease Registry
ATSDR Public Health Statement, December 1990

If you review the formulas presented in the preceding paper you will see
that there is a direct correlation of mCi/g to the toxicity. Thus where
the previous formula suggests .08mg per cancer for inhaled Pu239,
substituting the mCi rate of Pu238 yields .0003 mg/cancer. Thus making
Pu238 260 times more lethal per gram!

I would agree that even in most re-entry scenarios, the likelihood
of a catastrophe is very small, but there do exist plausible scenarios
that could result in massive deaths and illness. This is the risk Vs
reward issue. I've followed NASA since before the first Redstone took
Carpenter on his suborbital flight. Never before, even considering the
Apollo pad fire and Challenger, have I ever read or seen so many people
and groups bashing NASA consistently and with such anger as over Cassini
and launches containing RTG's. Simply from a public relations point of
view Cassini will likely remain a net loss to NASA even if it succeeds in
its planetary exploration mission. Future launches of Pu238 will continue
to result in a ever growing part of the public which opposes their
mission.

Sincerely,
Arthur Doucette


***************************************************************** *** Attachment #3: Congressional website/legislation information: *****************************************************************

To: PRC prcsandiego@igc.org
Subject: Congressional websites

Bookmark these!

Quick Routes to U.S. Congress:
http://www.senate.gov/senators/index.cfm (Senators' Websites) http://www.house.gov/house/MemberWWW.html (Representatives' Websites) http://thomas.loc.gov/ (Pending Legislation - Search)

***************************************************************** *** Contact info for Russell Hoffman and affiliation information: *****************************************************************


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