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(3)
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JP
1
1st
paragraph
ge
The term “space systems” has been changed Modify
to ”spacecraft and launch vehicle orbital
stages” in the rest parts of this standard, but
such modification has not been applies in this
clause.
JP
3.4
te
“Definition of casualty risk” is defined as a kind
of “probability”, but “risk” is not “reliability”.
In general, “risk” is a product of “probability”
and “magnitude of hazard”.
JP
3.1
ge
“Space systems” is to be changed to ”spacecraft Modify
and launch vehicle orbital stages”
te
“Break-up” is general term. Definition against
common sense will only invite confusion.
(If it would be a proper definition, what shall
we call when we destroy natural object?)
We had better to see the defnition in IADC
Guidelines.
3.8
Change to “a parameter, to assess the
safety of human on the ground, defined
by a product of the effect of impact to
human and the probability of impact to
human” or something similar
3.16
JP
3.3
Delete
Otherwise, change to “phenomena that
generate fragments including explosion
caused by chemical reaction, rupture by
inner pressure, fragmentation by
impact or destruction, etc. (NOTE: This
standard would limit on-orbital breakup, but not add the phenomena caused
by aerodynamic and thermal effect
during re-entry, planned separation, or
release of parts due to degradation.) ”
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JP
3.5
JP
3.11
te
ge
JP
3.12
ge
JP
3.13
te
JP
3.15
ge
“Disposal” is very common word. If we would
like to include “passivation” in “disposal”, we
may say “safe disposal”.
In current planning, “Disposal of satellite
operating in LEO STD” and “Passivation STD”
are defined independently. Otherwise this
STD and “Disposal of satellite operating in
LEO” shall be combined.
It may be better to define “passivation” and
“disposal manuever” independently. Then it
will allow to say as “passivasion after disposal
menuever”.
Change “disposal” to “safe disposal”.
Avoid unnecessary terms.
It can be solved to explain in each paragraph.
Delete.
Otherwise, change the sentence of
requirement so as readers can
understand.
Change the sentence of requirement so
as readers can understand without
referring definition of terms.
Spacecraft might be better to change to Delete
payload.
Rather delete such basic definition of term. It
will only to invite discussion and confusion.
We expect more simple and easy definition for Change to “Any stages of launch
“launch vehicle orbital stages”.
vehicles that will not decay directory
after the separation”.
It is very risky to define LEO in such way that Delete
apogee is less than 2000km.
We should have more concern with “Low Earth
Orbit Region (lower than 2000km)”. Namely we
must monitor and control every orbit whose
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5
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(e.g. 3.1)
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perigee is less than 2000km.
We should be satisfied by sub-clause 5.2 that
defines LEO protected region.
Check how this term is actually used in this
draft carefully. Perhaps it can be deleted.
“Re-entry” cannot be defined as a point. And Change it to “entering to atmosphere of
the explanation for physical phenomena could objects which has once ascended up to
be deleted from definition.
higher layer than mesosphere, as
example” or something similar.
JP
3.20
te
JP
3.23
te
JP
3.24
ge
JP
6.1.5
te
It is not feasible to comply with the
Delete
requirement for solid motor. Unfeasible
restriction shall be transferred to a Technical
Report as Collision Avoidance or other subjects.
[See detail in Attachment-A]
JP
6.2.2.1
te
“Probability of break-up is limited to 0.001”
Show the effective and available
in this draft.
methods, and assess its possibility. If it
In our routine work in design phase the is impossible the quantitative
failure rate and prospected reliability are requirements shall be deleted.
calculated, but it is impose additional difficult
Otherwise define the requirement by
work to calculate the possibility to cause break“reliability” not the “break-up
Generally “object” is not limited to man-made Delete
object. (Example: When we say “Near Earth
Object” the object is natural object.)
Also this term is not essential to this standard.
“Space object” can be changed to “spacecraft
and launch vehicle orbital stages” concerning to
this draft. (See clause 1)
“Space systems” is to be changed to ”spacecraft Modify
and launch vehicle orbital stages”
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JP
6.3.1.3
te
JP
6.3.2.2
te
JP
6.3.4.1
te
up. (Usually failure rate would not be
distributed for each failure mode. As example,
failure rate for propellant valve may be defined
but failure rate only to cause break-up cannot
be identified.)
Failure rates are calculated according to MILHDBK-217, NPRD, and other latest methods.
(Otherwise it can be calculated with using
specific failure rate corresponding to each
component.) But these failure rates cannot be
distributed to each failure modes.
If there are any countries that can do it, the
method shall be presented.
The requirement in 6.3.1.3 says “the
evaluation of the probability of successful
disposal shall quantitatively consider failure
modes of all functional element that are used
in disposal”, but 6.3.1.2 also defines the
conditional probability that allow to use
mission reliability and assess just as a function
of time. There is contradiction.
Also as shown in the previous comments, to
calculate probability for each failure mode is
not easy. There is no such data.
“Solar reflection index” shall be changed to
“solar radiation pressure coefficient”.
“Space objects” is not adequate. In this
standard, spacecraft and orbital stages shall be
controlled. See the scope of this STD.
probability”. (in such case, 0.001 is too
high for every nation.)
Or show the method that is practical
in Appendix.
Delete 6.3.1.3
Modefy
“Space objects” shall be changed to
“spacecraft and launch vehicle orbital
stages”. Other objects are out of scope
of this standard.
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24113―5.3
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(3)
4
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(6)
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(e.g. 3.1)
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JP
7.1
ge
The Space Debris Mitigation Plan shall be
prepared not only by supplier, but also by
developer (like JAXA, CNES), manufactures
(Alcatel, MELCO), space service provider
(Space Communication Corporation), operators
(,JAXA for government satellites), launch
providers(MHI, Arianespace).
“Space system provider” should be
changed to “developer, manufactures,
space service provider, operators,
launch providers.”
(Clause 6.3 is applied for the space operator
and the launch providers.)
JP
7.2
ge
The content of SDMP is not clear for reader.
Sub-clause 7.2 seems to define it as same level
as System Engineering Plan.
While sub-clause 7.3 requires very detail
including management activities. (If it requires
all the detail of debris mitigation work, the
plan will become very tick.)
Generally, such plan would show how to
guarantee the compliance between
requirements in the STD and activities.
JP
7.3
ge
Intention is not clear fro readers.
(1) Does it require the acquiring organization
to conduct systematic activities? This STD
must support the acquiring organization to
require the plan to suppliers. Such
activities must be required to supplier.
Clear the contents of the plan in
Appendix.
As example, organization, schedule,
planning & review system, tailoring
and its rationale, compliance matrix
between requirements and design &
operation plan, practices and methods
to comply with this standard, etc.
Reconfirm the concept f SDMP, and rewrite.
(2) The acquiring organization would not
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include its management requirement in the
SDMP. The SDMP would produce the
SDMP, not the acquiring organization
Re-write so as reader can understand the
meaning.
JP
7.4
ge
It says, “measures to manage and mitigate
space debris generation shall be tracked,
documented and validated in accordance with
the SDMP”.
However several companies involve through
life cycle, they are developers, manufactures,
space service providers, operators, launch
service providers.
The requirements shall be written considering
such relations.
Add---“The developers, designer,
manufactures, space service providers,
operators, launch service providers
shall develop the SDMP for their
associated work according to their
responsibilities. Every mitigation
measure taken in planning and design
phase shall be documented and
transferred to the operating phase.”
JP
7.5
ge
It says “the SDMP shall be maintained and
updated through all phase of a space system’s
life cycle”.
As just example,
However under the circumstance that several
companies involve through life cycle
(developers, manufactures, space service
providers, operators, launch service providers),
it is difficult to maintain one SDMP through
the life.
Clear the concept of SDMP.
“The SDMP shall be maintained and
updated by developers, designer,
manufactures, space service providers,
operators, launch service providers for
their associated work. Basic mitigation
plan, technical value, operation concept
shall be documented, transferred to the
following entity, and reflected on
operation procedure (Spacecraft
Operating Procedure, etc).”
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(*1) ： Mark Mulrooney, GB Tech, Inc., An assessment of the role of Solid Rocket Motors in the Generation of orbital Debris, TP-2007-213738,
2/1/2007, pp. 105, Location unavailable.
Abstract: Through an intensive collection and assimilation effort of SRM related data and resources, the author offers a resolution to the uncertainties
surrounding SRM particulate generation, sufficiently so to enable a first-order incorporation of SRMs as a source term in space debris environment
definition. The following five key conclusions are derived: 1) The emission of particles in the size regime of greatest concern from an orbital debris
hazard perspective (D >100 µm), and in significant quantities, occurs only during the Tail-off phase of SRM burn activity. 2) The velocity of these
emissions is correspondingly small - between 0 and 100 m/s. 3) The total Tail-off emitted mass is between approximately 0.04 and 0.65% of the initial
propellant mass. 4) The majority of Tail-off emissions occur during the 30 second period that begins as the chamber pressure declines below
approximately 34.5 kPa (5 psia). 5) The size distribution for the emitted particles ranges from 100 µm
Comments and Proposal on draft ISO24113
(The issue of solid motors)
1. Disagreement in Baselines
It was agreed that this standard ISO24113 “Space Debris Mitigation” should be developed under the worldwide consensus such as IADC Guidelines, UN
Guidelines and ITU Recommendation. In the discussion in IADC, restriction to the solid motor was rejected because of immature in technical
background, so there is no address in UN Guideline also. The current requirement “Solid rocket motors shall be designed to avoid the release into
Earth orbit of products larger than 1 mm in their largest dimension (subsection 6.1.5)” came from local standard in Europe; European Code of
Conducts for Debris Mitigation (COC), which Japan have not agreed. ISO shall pay more careful consideration to import requirements from COC
because of its flexible concept toward the “what is a requirement”. The European STD is so flexible for each requirement to be easily tailored, while
ISO STD is imposed to be respected to have compliance more strictly. Every requirement in ISO STD shall be reviewed for its feasibility to keep dignity
of ISO STD (unfeasible requirements shall be rejected otherwise ISO STD will lose its dignity and honor). It is obvious that no solid motor in the world
would comply with this requirement (prohibit to generate slag larger than 1 mm), and cannot be verified to comply with the requirement in the actual
orbital situations.
Also importing requirement from COC to this standard is against the initial agreement written in “introduction”.
2. Disagreement in Rational
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A document “TP-2007-213738: An Assessment of the Role of Solid Rocket Motors in the Generation of Orbital Debris, (February 2007, by NASA/JSC)”
is refereed in the ISO24113 to show “the methods available to verify the distribution of solid rocket motor slag and to satisfy the 1 mm size threshold”.
But clearly the document was not produced with intention to be a part of international standard by author (also by Space Debris Program Office in JSC,
and Thiokol), and have not agreed by any countries, perhaps JSC/NASA/USA will not agree to use it for this ISO 24113. However excellent this article
may be, it is an academic article, not an internationally agreed consensus.
Also this article would not provide effective method to verify the size and quantify the slag in orbital conditions, and even not provide any measures to
satisfy the 1mm rule (except spinning), although the ISO24113 says so in NOTE for 6.1.5. In many countries, the test facility (such that is introduced by
TP-2007-213738 which can keep vacuum condition in tail-off phase would not be available in the rest of world, at least not available in Japan, which
means this standard intends to prohibit many countries to develop solid motors. But even by such facilities, it is impossible to simulate orbital condition
perfectly. In addition to the vacuum condition, other factors (which effect on accumulation of solidified Al2O3 slag in interior portion of the nozzle, such
as acceleration, vibration, attitude and orbital maneuver, thrust vector control, spinning, etc) cannot be simulated on the ground static test. Also test
method shall be defined more specifically, at least the set-up attitude (setting horizontally or vertically) and direction of exhausting (vertical setting and
exhausting upward may limit the slag accumulation less than actual orbit operation) must be defined.
3. Responsibility of proposing countries
The European COC prohibits solid motor to generate larger slag than 10 micro-meter. Japan delegation requests to European courtiers to show how
the new European launch vehicle VEGA (with solid motors called P80, Zefiro-23 and Zefiro-9) could comply with the requirement, with information of
method for verification, in order to show the feasibility of this requirement.
It is a responsibility of the country, which proposes requirement, to show its feasibility and prove compliance.
If it is impossible to show it, which means it is too early to address in the current standard. Currently it seems to be more adequate to present the risk
of solid motor in a Technical Report of ISO and announce to the world to refrain from using it particularly for Apogee Kick Motor in GEO mission. We
will share the idea that we should eliminate slag or prohibit solid motor in near future but currently the world situation (social demand and national
tactics toward launch service) would not allow it, and technical level has not been matured.
4. Reconfirmation of facts
Followings are fact that we can agree now,
(1) It is unavoidable to generate slag from solid motor under the current technology.
(2) There is no reliable debris model to agree actual situation, because observation of tiny slag from the ground is generally difficult.
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(3) The characteristics of generation of debris are difficult to prospect. It is impossible to verify it on the ground because both to keep vacuum condition
in tail-off phase and to simulate the operational condition which effect on accumulation of Al2O3 (gravity, acceleration, vibration, spinning, attitude &
orbit control, etc.) are impossible. The set-up for firing test (set in vertically or horizontally) is also effect on the test result.
(4) Adaptation of solid motor to the booster or very low altitude may be allowed because of its scare effect on the environment. It is out of range of this
standard.
(5) Adaptation of solid motor to upper stage for LEO mission would not pose large effect on environment up to about 800 km in altitude just for smaller
slag than 1 cm, which complies with the 25-year-rule. Technical ground of 1 mm-rule is not clear.
(6) It is not desirable to use solid motor for apogee kick motor for GEO (and 12-hour-orbit like GPS) mission, because slag will stay permanently (or
extremely very long).
5. World situation
Followings are examples of usage of solid motors in ISO member countries.
Without strong will to abandon these solid L/Vs, they should not agree this restriction. Otherwise, this standard establishes another double standard
in the world, where some countries can keep business using solid motor, and the rest of world will be prohibited to do so.
(1) ESA have almost completed the development of VEGA (three stages of it are solid motors; P80, Zefiro 23、Zefiro 9). VEGA is a key tactic in
the European commercial strategy to occupy the launch providing service in the small size L/V business area.
(2) In the USA, several types of solid motors are used for Minotaur、Pegasus-XL、Taurus-XL. DoD may go out from solid motors after launching
GPS-2, solid launch vehicles are kept developing and used by NASA and commercial entities. In US Government standard for debris mitigation
does not address the solid motor so far.
(3) Brazil is operating VLS-1, and Russia is operating START, etc.
6. Recommendations
It is obviously true that a solid motor generates slag and release into orbit although the detail is not been agreed yet. And this issue shall be studied,
and R&D for new propellant shall be encouraged. However, every mitigation measures shall be determined by trade-off study for the balance between
the contribution on the space activities and the drawback to the orbital environment. The study has not finished for solid motor issue.
If the ISO insists to educate world space fairing nations, an adequate type of document shall be selected. It must not be a Standard but a Technical
Report.
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7. Conclusion
Japanese delegation would like to propose;
(1) Delete subsection 6.1.5.
(2) Technical Report should be produced to inform the risk of solid motors, detail recommendation to apply solid motor to booster, LEO, MEO and
GEO mission, test methods, technical measures to limit the generation of slag.
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