ASQ - Energy and Environmental Division



At its July 2001 meeting in Kuala Lumpur, Malaysia, ISO Technical Committee 207 (TC 207) passed a resolution to form a future vision task force (FVTF) for the purpose of developing a draft strategic plan for TC 207. This resolution (34/2001) was prompted by a report from an ad hoc group of the TC leadership formed in Kuala Lumpur to consider how such a plan might be developed. It was suggested in the report that the task force could

  • review the current situation and achievements of TC 207;
  • identify external developments and influences;
  • assess how these external developments and influences may impact on the current and potential future activities of TC 207;
  • develop a policy and identify mechanisms for TC 207 and ISO to be competent and responsive to these external developments and to serve real societal needs in an adequate and expeditious manner; and
  • develop an internal and external communications strategy to report on the competence and readiness of TC 207 to address societal needs.

The task force met in Amsterdam, Netherlands on April 7–8 and will present its draft plan at TC 207's upcoming June meeting in Johannesburg, South Africa.

To date, the only exchanges among the task force have been through e-mail. In these, members have speculated on the need for a strategic plan; but more than anything else, they have unearthed a spate of questions that will need to be answered before any plan can be formed. Among the questions raised are these:

  • Is the current scope of work for TC 207 in fact too narrow?
  • Have there been glaring failures in TC 207 to address pressing needs for standardization in its field of competence?
  • Can we continue to rely on the ISO process for introducing new work items to sustain the relevance and efficacy of TC 207?
  • What is the primary mission of ISO—to standardize existing practices or to advance international public policy needs?
  • Is speculative discussion within this task force of outlying and controversial candidates for standardization dangerous? Are we "priming the pump" for a flood of submittals with inadequate justification of need?
  • Is there some danger that this exercise will be seen as self-serving for TC 207's own interest in perpetuating its standards-making activities?

These questions are definitely arguable and will hopefully be argued by the FVTF, as well as by the full membership of TC 207. But more importantly, I believe these questions should be debated inside each member body of ISO (i.e., American National Standards Institute, et al). The ramifications of any TC 207 decision on this matter go way beyond the narrow and naturally conflicted interest of the delegates to TC 207. To leave the determination of these questions solely in the hands of those delegates without input from broader national interests and viewpoints is nothing short of the proverbial equivalent of leaving the fox to guard the chicken coop.

Since last November, the newspapers and television seem to have reported daily stories about the collapse of Enron Corporation and the apparent misbehavior of Enron's auditor, the Arthur Andersen company. Clearly, the failure of one of the U.S.'s biggest and most influential companies (if you believe the now famous Dick Cheney diaries) is a headline item. Countless investors and Enron employees have lost millions of dollars in the aftermath of the Enron collapse. For many, the losses represented life savings and retirement investments. That in itself reflects a great tragedy.

The secondary story has been the role of Arthur Andersen, one of the world's leading audit firms, in the Enron debacle. Stories have emerged that suggest that Andersen's auditors were deeply involved in covering up Enron's financial problems even to the extent of shredding potential criminal evidence in a cover-up attempt. These allegations are yet to be proven in a court of law, but they have had a draconian effect on Andersen and its audit business as increasing Numbers of companies have dropped Andersen as a consultant and auditor. Whether or not Arthur Andersen survives as a company remains to be seen; but, even if exonerated of the current allegations, the company's reputation and credibility may have already been irreparably damaged. In recent weeks, the federal government has debarred both Andersen and Enron from all federal contracts, further compounding their woes.

The Enron-Andersen scandal has cast a shadow across financial audit processes everywhere. At the heart of the matter is the issue of "consulting" versus "auditing." One of the fundamental principles of auditing is that an auditor must be independent of the work being audited. This separation is true for quality management systems (QMS), environmental management systems (EMS), and others, as well as financial management systems. Stories emerging from the Enron-Andersen relationship suggest that Andersen may have mixed its consulting role with its auditing role such that the line of separation became blurred at best or even erased entirely.

As a result, many organizations that offer both consulting and auditing services are re-examining their policies and operations to ensure that an adequate "firewall" exists between the two functions. This "wake-up" call was also heard in the federal government as the General Services Administration (GSA) has announced that federal financial auditing guidelines are being reviewed to ensure that the independence and integrity of the audit processes are maintained. This same principle applies to QMS and EMS audits as well and affects federal organizations in those areas as well.

Experience has shown that audit and auditor independence in federal programs has not always been fully implemented. More often than not, the difficulty has been in defining exactly what is meant by independence within an organization. There have been successes and notable failures. Perhaps most memorable is the space shuttle Challenger disaster in 1987. If the auditors had been fully independent, would the o-ring seal problem have been pushed aside so easily?

The U.S. Department of Energy frequently utilizes QA personnel from one site or facility to audit another facility or program, which is a positive step in assuring audit independence. Internal audits may also be performed by personnel from the same site but from other parts of the organization at the site. Are they fully independent if they will have an up-line manager who is also responsible for the work being performed? This may depend on one's perspective. Moreover, QA personnel often provide technical advice on quality control and quality assurance practices. Is this "consulting?" If so, then can the consulting and auditing be kept separated if the same people giving the advice also perform the audits? Are recommendations in an audit report the same as consulting? The answers may vary depending on one's perspective.

In the case of the U.S. Environmental Protection Agency, audits are usually performed by QA officers and other QA personnel at a site or facility. These same personnel may also advise their colleagues on QA and QC practices. Limited personnel resources may make it impossible to maintain separate groups, one for technical assistance and one for audits. How can this situation be resolved? It has been agency policy since the mid-1980s that quality assurance officers not report to managers having direct responsibility for environmental measurement activities; however, situations still exist today in which the QA personnel report to such managers, and the QA personnel are not fully independent when they conduct audits. The QA personnel do not audit their own work, but they can be compromised by having to report administratively to someone who could be adversely impacted by an audit conclusion. This raises a question about such personnel being truly independent. Unlike the private sector, government organizations are not always able to obtain third-party auditing services from outside parties. Again, where does providing technical assistance cross over the line and compromise audit independence? The answer is not always simple or obvious.

The Enron-Andersen situation has certainly made federal managers more aware of the need for auditor independence, and there is growing evidence that steps are being taken to ensure that independence is maintained. Clearly, more work is needed to establish an effective "firewall" between consulting and auditing, but the initiative has begun, led by GSA. Issues should be identified and discussed, and procedures developed to ensure audit independence. Like the private sector, government must also ensure the integrity of the quality systems that support its day-to-day operations. The appearance of impropriety is just as troublesome as the impropriety itself. Thankfully, positive steps are being taken.

As a consequence, it is ironic, perhaps, but the Enron-Andersen problem may have actually had a positive influence on the federal government. The message has been sent and received. Now it must be sustained.

In the December issue of the Energy and Environmental Division (EED) QEHS Zine, some of the current topics in the nuclear power generation industry were illustrated. In particular, a major barrier to building new plants and keeping existing U.S. nuclear plants running is the failure of the federal government to meet its obligation to build a repository for storing used nuclear fuel. Each nuclear plant is acting as a temporary storage site until this central facility is built. While some nuclear plants have been able to accommodate supplemental on-site storage, some could be prematurely shut down due to lack of space, in spite of their significance to our energy supply.

This article provides more information on used nuclear fuel from two perspectives: an update on the process of establishing a repository at Yucca Mountain, and an explanation of the used fuel that will be placed there. More comprehensive information on this and other aspects of the nuclear industry can be found at the Nuclear Energy Institute Web site at www.nei.org.

Yucca Mountain will take not only used fuel from commercial nuclear power generating stations, but also U.S. Navy reactor fuel, weapons production wastes, and foreign research reactor fuel.

Yucca Mountain Update
U.S. policies governing the permanent disposal of high-level radioactive waste (i.e., used fuel) are defined by the Nuclear Waste Policy Act of 1982 as amended. This act specifies that high-level radioactive waste will be disposed of underground in a deep geologic repository and that Yucca Mountain, Nevada, will be the single candidate site for characterization as a potential geologic repository.

To pay for a permanent repository, an interim storage facility, and the transportation of used fuel, the Act established the Nuclear Waste Fund. Since 1982, electricity consumers have paid into the fund a fee of one-tenth of a cent for every nuclear-generated kilowatt-hour of electricity consumed. To date, about $18 billion has been collected, with about $7 billion of that spent.

The United States has reached a major milestone in the long process of getting to the actual construction of the storage facility. Recently, the Secretary of Energy formally recommended Yucca Mountain as the repository site to President Bush, and on February 15, 2002, President Bush recommended the site to Congress. The Secretary concluded that "the Yucca Mountain site is scientifically sound and suitable for development as the nation's long-tem geological repository for nuclear waste, which will help ensure America's national security and secure disposal of nuclear waste, provide for a cleaner environment, and support energy security."

There is still a long process of license application and review, first for construction, then again for operation. This will involve extensive hearings and public comment. The state of Nevada has already voiced disapproval. On April 9, 2002, Nevada Governor Kenny Guinn vetoed the use of Yucca Mountain as the nation's repository for high-level radioactive waste. To move the project forward, the U.S. Congress must pass a joint resolution approving the site. A repository will not be built at Yucca Mountain without this approval.

What will be stored at Yucca Mountain?
Used nuclear fuel assemblies from nuclear power plants will make up most of the material placed in the Yucca Mountain repository, along with other material mentioned at the start of this article.

A new fuel assembly can generate power for about five years before the uranium-235 becomes so depleted that the assembly is no longer economically usable in a typical U.S. reactor. That does not mean that all energy is depleted. Other nations have decided to recycle their fuel and reuse it in other types of reactors, using other materials in the fuel for power generation. In fact, when most U.S. nuclear plants were built, the industry—with federal government encouragement—planned to recycle used nuclear fuel. However, in 1979, President Carter, completing a process begun by President Ford, banned commercial used nuclear fuel reprocessing in order to address concerns raised about the possible proliferation of nuclear weapons. This decision mandated a once-through, single-use fuel cycle. Although President Reagan lifted the reprocessing ban in 1981, nonproliferation concerns continue to guide U.S. policy. And while reprocessing and recycling are not currently cost-effective in the U.S., other countries continue to reprocess and recycle used nuclear fuel.

U.S. policy requires the storage of used fuel (if fuel is not recycled, it needs to be stored somewhere). Some of our early U.S. nuclear power stations were designed with only limited on-site used fuel storage under the assumption that fuel would be shipped to a reprocessing facility in accordance with our energy policy at the time. These plants are now building supplemental on-site storage, while waiting for the U.S. government to meet its obligation to build a central repository per current policy.

What does the fuel look like?
Nuclear fuel, new or used, is in the form of hard ceramic pellets, each about the size of the tip of your little finger. One new uranium nuclear fuel pellet provides the energy equivalent to that provided by 1,780 pounds of coal, 149 gallons of oil, or 17,000 cubic feet of natural gas. The pellets are inserted into metal tubes called "fuel rods" when they are manufactured. The rods are each about twelve-feet-long. About 100 rods are grouped into a bundle, called a "fuel assembly." These assemblies are then loaded into the reactor for power generation. After use, the fuel remains in these same assemblies. The primary difference of interest between used and new fuel is that the used fuel is highly radioactive.

The high-energy content of the new fuel means that the used fuel represents an extremely small volume compared to the waste and emissions from other generation sources that provide much of our electricity.

Will this repository be safe?
The overwhelming body of study and research data indicate the site will be safe, reflected by the Secretary of Energy's recommendation to proceed with the siting process. Nature also provides compelling evidence that such waste can be contained geologically for hundreds of thousands, even millions, of years. One of the best examples of nature's ability to safely isolate radioactive elements over millions of years is provided by the natural nuclear reactors discovered in 1972 at the Oklo uranium mine in the West African republic of Gabon.

This deposit of ore, which contained from 10 percent to 60 percent uranium, constituted a natural nuclear reactor. Millions of years ago, it began a self-sustaining chain reaction. Like all reactors, this one created its own radioactive byproducts of plutonium and other material.

The Oklo chain reaction occurred intermittently for more than 500,000 years. Despite its location in a wet, tropical climate, Oklo's uranium deposit and high-level waste have remained securely locked in this natural repository for the past 200 million years. Many of the waste products stayed where they were created or moved only a few inches before radioactively decaying into harmless products.

Given our society's capacity to engineer a facility and provide continuous monitoring of its operation, I believe there is no question that the Yucca Mountain site will be safe.

How will the fuel get to Yucca Mountain from the generating plants?
The used fuel will be shipped by truck and rail. This is not new. Since 1953, there have been more than 900 rail shipments of used nuclear fuel in the U.S.—without injury or environmental consequences as a result of the radioactive nature of the cargo. There has never been a release of nuclear material from a rail transport vehicle.

Since 1964, the U.S. nuclear energy industry has safely transported more than 10,000 used nuclear fuel assemblies by truck in more than 3,000 shipments covering 1.7 million miles. Accidents can and do happen, so scientists and engineers designed used nuclear fuel shipping containers to be among the safest on the road to protect the public against even the most severe accidents. The containers can withstand high-speed crashes, fires, and submersion in water—all without breaking open.

Eight accidents involving used fuel containers have occurred, four on highways and four during rail transport. None of these accidents caused any injuries, fatalities, or environmental damage stemming from the radioactive nature of the cargo. In 1971, for example, a tractor-trailer carrying a 25-ton shipping container holding used nuclear fuel swerved on a Tennessee road to avoid a head-on collision, went out of control, and overturned. The trailer, with the container still attached, separated from the tractor, and skidded into a rain-filled ditch. The container suffered minor damage but—as it was designed to do—prevented the release of radioactive material. This accident was the most severe of the eight involving used fuel transportation containers.

The containers used to transport and store used nuclear fuel must be approved by the Nuclear Regulatory Commission (NRC), an independent federal regulatory agency charged with protecting public health and safety and the environment. Before NRC certifies container designs, the designs must meet rigorous engineering and safety criteria. In addition, the container designs must be able to pass a sequence of hypothetical accident tests involving forces greater than the containers would experience in actual accidents.

Information on the NRC's safety oversight of the radioactive material shipping and the agency's involvement in the Yucca Mountain Project can be found at www.nrc.gov. Further information on shipping container testing, including pictures and video, can be found at www.nei.org. Detailed information on Yucca Mountain can be found at www.ymp.gov.

Why is a used fuel repository so important?
A used fuel repository at Yucca Mountain needs to be built so that nuclear power can remain a viable option in our nation's portfolio of energy sources, as well as to provide secure and centralized storage of this fuel. From a national security perspective, it is imperative that Yucca Mountain be licensed if we are to maintain our fleet of nuclear submarines and aircraft carriers.

The Nuclear Waste Policy Act obligated our government to build this facility, and it is over 10 years behind schedule. To continue progress, it is imperative that Congress approve Yucca Mountain this year so the siting process can continue. If you feel, as I do, that this is important, you should contact your congressional representatives if this issue comes up for a vote, so your voice can be heard on this issue. Following congressional approval, the licensing process can begin. This process will review the information already available, beginning with the $7 billion spent on study and research that shows Yucca Mountain is a sound choice for a geologic repository. Any new information will also be assessed as part of this process.

The momentum for quality continues to grow in higher education. Universities such as Stanford, Syracuse, and Kent State recently announced the launch of quality improvement initiatives.

The University of Alabama, a finalist in the 2001 Alabama Quality Award Process.

The University of Miami helped to further this trend by hosting a quality workshop in January 2002. Bob King, CEO of Goal/QPC, led a workshop on creative thinking. Dr. Donna Shalala, president of the University of Miami, spoke at a luncheon with representatives from about 25 universities that have active quality initiatives. Dr. Shalala recounted how and why she launched the quality initiative when she was president of the University of Wisconsin–Madison in the late 1980s.

Regional universities are also buzzing over the 2001 Baldrige Award that went to the University of Wisconsin–Stout. Having had the opportunity to facilitate strategic planning for UW–Stout's largest academic program a few weeks ago, I can report that UW–Stout does indeed have a remarkable management system that truly drives continuous improvement all across its campus. UW–Stout has developed approaches to governance, planning, budgeting, and academic program management that are rather unique and ahead of the curve in higher education.

Now is the time for quality professionals who are interested in the improvement of higher education to act! Please write the president of the college you attended and the current dean of your academic program at your alma mater, and insist that they benchmark UW–Stout. Your gifts to colleges that do not get on board with quality improvement simply perpetuate the irresponsible administrators that remain unresponsive to the concerns of the students, the parents, and the employers who depend on these institutions to prepare young people to take on vital roles of responsibility.


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