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Time to Respond - before DOE expands Pu-238 Production for Civilian Space Program

1) Please respond soon to the U.S. Department of Energy (DOE's) intent to prepare a programmatic environmental impact statement (PEIS) 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. This PEIS will be referred to as the Nuclear Infrastructure PEIS.

Beginning October 13 to October 26 the DOE will be holding public scoping meetings solicit oral and written comments on the porposed scope and content of the PEIS. One of their options is a "No Action" alternative where there would be "no domestic capability to produce Plutonium-238 for future space missions would be established." Please respond by going to the public meetings, calling (877-562-4593 and by E-mail to:

The following is a sample letter. Please edit, change or rewrite, but send YOUR STATEMENT in response to the DOE PEIS to expand PU-238 for the civilian space nuclear program.

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Colette Brown,
Office of Nuclear Energy,
Science and Technology (NE-50),
U.S. Department of Energy,
19901 Germantown Road,
Germantown, Maryland 20874,


Re: U.S. Department of Energy (DOE) intent to prepare a programmatic environmental impact statement (PEIS) 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.
http://www.ne.doe.gov/


October 4, 1999



Dear Ms. Brown:

Thank you for your reply to my telephone call last week. This letter is my written statement regarding the DOE's consideration in preparing the Nuclear Infrastructure PEIS.

To be very simple and straightforward I want to be on the record for opposing any consideration of expanding the development of production of Plutonium-238. Recently the Earth flyby of the Cassini space probe threatened life on Earth with the possibility of dispersing 400,000 curies of radioactive Plutonium into our atmosphere. Fortunately the mission went by Earth without a catastrophic incident, but if we keep taking chances with isotopes that are toxic and known to cause mutations and cancers in living cells (remaining harmful for many generations), we will continue threatening life in an unprecedented way by our shortsightedness and disregard for the health of life on Earth.

Please use the information on the website from the Action Site to Stop Cassini Earth Flyby. It is posted at http://www.nonviolence.org/noflyby . You are invited to download the NoFlyby website as part of my statement and can use
http://www.bluesquirrel.com/products/grabasite/grabasite.html
to grab an entire web site to your hard drive. At the end of this letter I will list a few critical references from this website, in case you cannot review the whole site.

One of the most significant findings in the last few years about the potential harm by dangerous radioactive isotopes is by the work of Hei, et all. In a letter by Dr. John Gofman's May 11, 1999 letter, posted at
http://www.ratical.org/radiation/CNR/LetterOfConcern.html , he wrote, "..By any reasonable standard of biomedical proof, there is no safe dose, which means that just one decaying radioactive atom can produce permanent mutation in a cell's genetic molecules. My own work showed this in 1990 for xrays, gamma rays, and beta particles (Gofman 1990: Radiation-Induced Cancer from Low-Dose Exposure). For alpha particles, the logic of no safe dose was confirmed experimentally in 1997 by Tom K. Hei and co-workers at Columbia University College of Physicians and Surgeons in New York (Proceedings of the National Academy of Sciences (USA) Vol.94, pp.3765-3770, April 1997, "Mutagenic Effects of a Single and an Exact Number of Alpha Particles in Mammalian Cells").


This information and new findings by many scientist studying the disproportionate harm of low level radiation show that the currently accepted internal dosimetry models presented in the International Commission on Radiological Protection (ICRP) Publication 30 and the radiation health effects' estimator for the induction of fatal cancers as outlined in ICRP Publication 60, both of which are accepted by the national and international radiation protection communities, are inaccurate, limited and misleading. Based on the findings of Hei, et all, and other analyses, such as Dr. Ernest Sternglass' measurement with the "Baby Tooth Project" [see www.radiation.org ] I urge you to conduct new investigations on the disproportionate harm that could come from low level radiation, and until those investigations are complete, to stop the use and development of plutonium in space programs.

Plutonium radioactive isotopes are relatively new. They have only been developed in the last sixty years, initiated by the fear that Germany would produce the first atomic bomb during World War II. This is very little time compared to these substances long-term toxicity to generations of human beings and our environment. The scientific standards that you are using today in measuring the possible harm of low level plutonium radioactive isotopes are most likely inaccurate. Yet, knowing that the U.S. military has strong interests in using plutonium for space-based weaponry, knowing that NASA and DOE operates with the military on the development of nuclear space programs, it is practical to assume the close involvement with these agencies in the development of plutonium for the space program. This is why I am not only suggesting a "No Action" alternative to where no domestic capability to produce Plutonium-238 for future space missions would be established by the DOE, but I also strongly encourage the DOE support to stop all development of dangerous Plutonium isotopes.

Your support of a "No Action" alternative would be a step in the correct direction in the consideration for life and the future of life on Earth. By stopping these programs, I am confident that the DOE, NASA and the U.S. military could find other ways to explore our heavens, benefit humanity and protect life. Please contact me, if I can assist you further in such beneficial transformative directions.


Sincerely,

Jonathan Mark


For important references see:

Radiation and Public Health Project, Inc.'s status report of the Baby Teeth Project
http://www.radiation.org/whatsnew.html

"No Safe Dose "- a Letter of Concern by Dr. John W. Gofman
http://www.ratical.org/radiation/CNR/LetterOfConcern.html

Landmines at the cellular level
http://www.pgs.ca/pages/nl/lmcells.htm

Bart Jordan Commentary on ancient civilizations and development of dangerous isotopes
http://www.nonviolence.org/noflyby/ref/bart.htm

NoFlyby Newsletter No. 19
http://www.nonviolence.org/noflyby/alerts/19nl.htm


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