Establishing An Effective Plant Fluid Leak Management and Prevention Program

Establishing an Effective Plant Fluid Leak
Management and Prevention Program
2015 TECHNICAL REPORT
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Establishing an Effective Plant Fluid
Leak Management and Prevention
Program
3002005355
Final Report, December 2015
EPRI Project Manager

G. Boles
All or a portion of the requirements of the EPRI Nuclear

Quality Assurance Program apply to this product.
ELECTRIC POWER RESEARCH INSTITUTE

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Copyright © 2015 Electric Power Research Institute, Inc. All rights reserved.
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ACKNOWLEDGMENTS
The following organization, under contract to the Electric Power Research Institute (EPRI),
prepared this report:
AP Services, a Business Unit of Curtiss Wright
203 Armstrong Dr.
Freeport, PA 16229
Principal Author
Dave Steffen
This report describes research sponsored by EPRI.
EPRI would like to recognize the members of the utility Technical Advisory Group (TAG) who
gave their time, attention, and input to the defining the scope and content of this project and
particularly for their comments, which were invaluable in reviewing the final draft report.
Mark Barraclough, Wolf Creek Nuclear Operating Company
James Ebenroth, Exelon
Errol Lain, Exelon
Jim Love, Pacific Gas and Electric
Paul Studer, Arizona Public Service
Chris Wax, Arizona Public Service
Dwayne Williams, Duke Energy
Finally, EPRI would also like to recognize the industry Fluid Leak Management Users Group for
their many and valuable perspectives contributed during the preparation of this report.
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In addition, the following Boric Acid Program Owners who offered support and consultation
are recognized:
Jim Bennetch Dominion
Steve Jones Palo Verde
Dale Snyder NextEra Energy
Al Shams Xcel Energy
Sharon Gray Southern Nuclear
Pam Schulterman Entergy
This publication is a corporate document that should be cited in the literature in the following
manner:
Establishing an Effective Plant Fluid Leak Management and Prevention Program. EPRI,
Palo Alto, CA: 2015. 3002005355.
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REPORT SUMMARY
Establishing an Effective Plant Fluid Leak Management and Prevention Program is a

comprehensive update and revision of the EPRI Fluid Leak Management (FLM) and prevention
program guidance report entitled Nuclear Maintenance Applications Center: Establishing an
Effective Plant Fluid Sealing Technology Program (report 1018959) published in August 2009.
Background
For years, minor leakage events received low-level management attention at many plants. Leaks
were often viewed as inevitable, and corrective action consisted of making repairs at the next
convenient opportunity. In many cases, this approach led to refueling outage extensions, forced
outages, personnel contaminations, the spread of extremely radioactive particles (for example,
fuel fleas), and power reductions. As utilities came under increasing pressure in the mid-1990s to
reduce costs and improve availability, leak reduction was recognized as an area of opportunity.
Initial EPRI research results addressing gasketed joints, valve packing, threaded connections, and
other seal types were well received, culminating in the aforementioned publication of a program
document designed to assist EPRI members in developing and implementing effective FLM
programs at their operating plants.
After nearly twenty years of industry experience in the implementation of this guidance, EPRI
members have indicated a desire for EPRI to continuously reexamine the factors currently
driving or affecting the development or successful implementation of plant FLM programs. EPRI
members have directed EPRI to develop a revision of the preceding technical guidance that
reflects recognition of those factors and takes into account implementation lessons learned over
this preceding period.
The change in title represents comments from the industry that leaks still occur and the
importance of managing such leaks. However, the industry recognizes that the prevention of
leaks is the first step in managing them as the easiest leaks to manage are the ones that never
occur! As part of EPRI’s mission to conduct research, development, and demonstration relating
to the generation, delivery, and use of electricity for the benefit of the public, the identification
and demonstration of new technology to the industry to prevent, manage, and repair leaks are as
important as ever.
In general, the program will be referred to as the FLM program, although the term prevention
should be considered part of the overall program.
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Objectives
• To incorporate lessons learned during previous industry attempts at developing or
implementing a successful plant FLM and prevention program.
• To continue to focus industry technical guidance pertaining to plant FLM programs away
from leakage management and toward leakage mitigation, recognizing that great strides have
been made in mitigating many types of leakage events through improved sealing materials
and assembly techniques.
• To revisit guidance relative to how leaks are defined, categorized, and prioritized for repair to
ensure that leaks do not affect nuclear safety, industrial safety, radiological safety, and
generation risk.
• To provide a clear justification for the implementation of a plant FLM program.
• To simplify the understanding of an effective plant FLM program implementation process.
• To continue the emphasis on fluid leak prevention, while still providing guidance for utilities
to manage the leaks that they have so that they are repaired commensurate with their impact
on safe and reliable generation.
Approach
This revision was begun by conducting a careful review of the existing technical guidance
contained in its current fluid leak program report and comparing the scope and content of that
report to suggestions by EPRI members on needed additions or modifications. Subsequently, a
technical advisory group (TAG) comprising utility members and vendors was organized for the
purpose of providing initial scoping guidance and ongoing technical review during preparation of
the revised report. It should be noted that the TAG members are also active members of the non-
EPRI Fluid Leak Management Users Group (FLMUG), an industry group of nuclear utility
professionals, vendors, and other organizations that collaborate to address leakage issues
primarily with nonwelded mechanical joints (for example, packing, gaskets, mechanical seals,
threaded fittings).
Proposed topics for this revision were developed by EPRI and provided to the TAG for review
and comment including additions. Based on this initial input, a draft document scope was
established and the proposed content ordered and organized.
Presentations were made at industry topical meetings to familiarize utility representatives with
the proposed project scope and content. Industry input was collected and used to further refine
the proposed technical guidance.
As in the past, technical guidance needs to continue to correlate well with an ongoing industry
effort by the FLMUG to use and improve a plant FLM program self-assessment tool. To support
this effort, EPRI provides input to the FLMUG to assist in the improvement of their assessment
tools. This guidance continues to mesh with the technical objectives of the assessment tool. The
results are both a front-end technical document providing guidance for establishing a plant FLM
program as well as a back-end assessment tool to aid plant technical staff in evaluating the
performance of their FLM program.
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Results
Using the material contained herein, those involved in creating and managing leakage
management programs should be able to do the following:
• Justify the benefits of developing and implementing a plant fluid leak program.
• Evaluate the effectiveness of their current leakage management program.
• Establish practical goals for an improved program.
• Select a leakage management program owner with the requisite skills.
• Track the performance of the program and make improvements as warranted.
This module is different from others in the series in that the material is intended primarily for
study by managers and technical support staff rather than as material to be presented to
maintenance technicians in a hands-on training environment.
EPRI Perspective
EPRI views this report pertaining to FLM as an important and needed contribution to the state of
the art with respect to plant maintenance and operations and maintenance cost reduction. This
document is considered to be of particular importance because it establishes the process by
which an effective plant FLM program can be implemented in a cost-effective manner.
Keywords
FLM
Fluid leak management
Leakage
Leak reduction
Maintenance
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ABSTRACT
For nearly 40 years, the nuclear power industry has recognized a need to address a series of fluid
leak management (FLM)–related issues affecting plant safety, operability, and availability.
Beginning in the mid-1980s with the issue of fraudulent threaded fasteners making their way into
the industry’s supply chain, the nuclear power industry has maintained an ongoing emphasis on
addressing a variety of major FLM issues. These include materials and techniques for Valve
Packing Performance improvement, bolted gasketed joints, replacement of asbestos gaskets and
packing, the cost of making expensive and hazardous on-line repairs on high-temperature, high-
pressure systems, and the issue of borated water corrosion in pressurized water reactor (PWR)
power plants.
Beginning in the early 1990s, in response to member requests for assistance, EPRI initiated what
was to become a comprehensive series of technical programs spanning a range of general FLM
issues. These research projects and resultant technical reports covered seal types that included
gaskets, packing materials, threaded piping connections, and mechanical and static seals, as well
as related programmatic concerns including boric acid corrosion, freeze sealing (plugging) of
piping, on-line leak repairs, and foreign material exclusion. Much of EPRI’s work in this domain
culminated in 2009 with the publication of a technical report entitled Establishing an Effective
Plant Fluid Leak Management Program (1018959), providing guidance on developing and
implementing a common industry leakage management program.
Establishing an Effective Plant Fluid Leak Management and Prevention Program is a major
revision to the preceding EPRI program guidance on this topic. The document incorporates
program implementation lessons learned since the last revision. Its emphasis is on leak
prevention and repairs while recognizing that leaks still occur and provides guidance for
evaluating them quantitatively and from a nuclear and generation risk perspective. It enables
plant personnel actually responsible for implementation to draw much clearer connections
between their program responsibilities and peripheral plant and industry information.
In addition to an introduction, this report includes sections covering program benefits, industry
operating experience, objectives and goals, management involvement, program responsibilities,
required levels of effort, implementation factors, procedures, tools and materials, training,
relationships to other plant programs, program improvement opportunities, and appendices
containing examples.
The report is intended for managers and plant technical staff responsible for the development,
implementation, or management of a plant FLM program.
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ACRONYMS
APR annual program review

BACCP boric acid corrosion control program
FIN Fix It Now
FLMUG Fluid Leak Management Users Group
FLM fluid leak management
FLMPO fluid leak management program owner
FTE full-time equivalent
INPO Institute for Nuclear Power Operations
OE operating experience
O&M operations and maintenance
PWR pressurized water reactor
RIB radially inward buckling
SME subject matter expert
TAG technical advisory group
TSG technical support group
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CONTENTS
1 INTRODUCTION .................................................................................................................... 1-1

1.1 Background .................................................................................................................. 1-1
1.2 Objectives .................................................................................................................... 1-3
1.3 Target Audience .......................................................................................................... 1-3
1.4 Summary ..................................................................................................................... 1-3
2 LEAKAGE DEFINITIONS AND CLASSIFICATIONS ............................................................ 2-1

2.1 General Definition of a Leak ........................................................................................ 2-1
2.2 Defining the Program Scope ........................................................................................ 2-2
2.3 Leakage Severity Levels for Common Fluid Types ..................................................... 2-3
3 FLM PROGRAM BENEFITS .................................................................................................. 3-1

3.1 Improved Plant Safety ................................................................................................. 3-1
3.2 Improved Plant Appearance ........................................................................................ 3-2
3.3 Direct Cost Reduction .................................................................................................. 3-2
3.3.1 Cost of Direct Work to Repair Leaks ................................................................... 3-2
3.3.2 Costs Associated with Cause Analysis of Leaks................................................. 3-3
3.3.3 Costs of Replacement Power for Leaks Causing Shutdowns ............................. 3-3
3.3.4 Radwaste and Water-Processing Costs ............................................................. 3-4
3.3.5 Special Costs ...................................................................................................... 3-4
3.4 Reduced Indirect O&M Impact ..................................................................................... 3-4
3.5 Improved Industry and Regulatory Recognition ........................................................... 3-4
4 INDUSTRY EXPERIENCE ..................................................................................................... 4-1

4.1 U.S. Experience 1974–2003 ........................................................................................ 4-1
4.1.1 Significant Event Data 1974–2002 ...................................................................... 4-1
4.1.2 Special Analysis Conducted Between 2002 and 2003........................................ 4-3
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4.2 Analysis of Events Adding 2003–2014 Events to Previous Analysis of
Significant Events ........................................................................................................ 4-4
4.2.1 Significant Events: 1974–2014............................................................................ 4-4
4.2.2 2003–2014 Events Causing Forced Shutdowns Analysis................................... 4-6
4.2.2.1 2003–2014 Events for Base Metal and Welds .............................................. 4-7
4.2.2.2 2003–2014 Events for Leak Sources in the Scope of the FLM Program ...... 4-8
4.3 Conclusions ............................................................................................................... 4-10
4.4 Industry Performance Metrics .................................................................................... 4-10
4.4.1 Industry FLM Program Self-Assessment Results ............................................. 4-10
4.4.2 Sample Plant FLM Performance ....................................................................... 4-13
4.4.3 Leading Indicators ............................................................................................. 4-15
4.4.4 Industry Experience .......................................................................................... 4-16
5 OBJECTIVES AND GOALS ................................................................................................... 5-1

5.1 Current Status Assessment ......................................................................................... 5-1
5.1.1 Assessment of Plant Management’s Intolerance of Leakage Events ................. 5-1
5.1.2 Analysis of Work Management System Records ................................................ 5-2
5.1.3 Plant Walkdown Inspections ............................................................................... 5-2
5.1.4 Plant Personnel Interviews.................................................................................. 5-3
5.1.5 Recent Peer Assessments .................................................................................. 5-3
5.2 Establishing Practical Goals ........................................................................................ 5-3
5.2.1 Initial Goals for New Programs ........................................................................... 5-4
5.2.2 Performance Goals for Established Programs .................................................... 5-5
5.2.3 Stretch Goals for Mature Programs .................................................................... 5-6
6 PLANT MANAGEMENT INVOLVEMENT .............................................................................. 6-1

6.1 Program Approach ....................................................................................................... 6-1
6.1.1 Reactive .............................................................................................................. 6-1
6.1.2 Programmatic ...................................................................................................... 6-1
6.1.3 Proactive ............................................................................................................. 6-2
6.2 Support Opportunities .................................................................................................. 6-3
6.2.1 Program Staffing ................................................................................................. 6-3
6.2.2 Goals and Objectives .......................................................................................... 6-3
6.2.3 Implementation Assistance ................................................................................. 6-4
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7 PROGRAM RESPONSIBILITY .............................................................................................. 7-1
7.1 Accepting Ownership ................................................................................................... 7-1
7.2 FLMPO Management Attributes .................................................................................. 7-3
7.3 Required Level of Effort ............................................................................................... 7-4
7.3.1 FLM Program Owner........................................................................................... 7-4
7.3.2 Technical Backup ................................................................................................ 7-5
7.3.3 Technical Support Group .................................................................................... 7-5
7.3.4 External Technical Support ................................................................................. 7-5
8 LEAKAGE ASSESSMENT PRACTICES ............................................................................... 8-1

8.1 Walkdown Inspections ................................................................................................. 8-1
8.2 Work Order Review...................................................................................................... 8-2
8.3 In-Plant Personnel Interaction...................................................................................... 8-3
8.4 Cause Evaluation ......................................................................................................... 8-3
8.5 Reporting ..................................................................................................................... 8-4
8.5.1 Monitoring, Tracking, and Trending .................................................................... 8-4
8.5.2 Report Types....................................................................................................... 8-5
8.5.3 Standardized Reporting ...................................................................................... 8-5
8.5.3.1 FLMUG Standard Scoring Metric ................................................................. 8-6
9 PROCEDURES, MATERIALS, AND TRAINING ................................................................... 9-1

9.1 Practical Procedures .................................................................................................... 9-1
9.1.1 FLM Program Procedure..................................................................................... 9-2
9.1.2 Supporting Procedures ....................................................................................... 9-4
9.2 Tools and Materials ..................................................................................................... 9-5
9.2.1 Tool Selection ..................................................................................................... 9-5
9.2.2 Material Selection................................................................................................ 9-6
9.3 Training Scope and Frequency .................................................................................... 9-7
9.3.1 General Training ................................................................................................. 9-8
9.3.2 Specific Skills Training ........................................................................................ 9-8
9.3.3 Refresher Training .............................................................................................. 9-9
9.3.4 Supplemental Work Force Training..................................................................... 9-9
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10 TECHNICAL PROGRAM RELATIONSHIPS ..................................................................... 10-1
10.1 Boric Acid Corrosion Control (PWR Only) ............................................................. 10-1
10.2 Catch Containment Programs ............................................................................... 10-2
10.3 On-Line Leak Repairs ........................................................................................... 10-2
10.4 System Health Monitoring Programs .................................................................... 10-2
10.5 Service Water System Program ............................................................................ 10-2
10.6 Foreign Material Exclusion .................................................................................... 10-3
10.7 Procurement Engineering ..................................................................................... 10-3
10.8 Outage Planning ................................................................................................... 10-3
10.9 Work Management ................................................................................................ 10-4
10.10 Buried Piping ......................................................................................................... 10-4
11 PROGRAM IMPROVEMENT ............................................................................................. 11-1

11.1 Self-Assessments ................................................................................................. 11-1
11.2 Peer Reviews ........................................................................................................ 11-2
11.3 Annual Program Review ....................................................................................... 11-3
11.4 Industry OE Review .............................................................................................. 11-4
11.5 Industry Benchmarking ......................................................................................... 11-4
11.6 Industry Participation............................................................................................. 11-5
12 APPENDICES ..................................................................................................................... 12-1

12.1 FLM Program Self-Assessment with Scorecard ................................................... 12-1
12.2 On-Line Leak Sealing Decision Screening .......................................................... 12-18
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LIST OF FIGURES
Figure 1-1 EPRI FLM technical guidance ................................................................................. 1-2

Figure 4-1 Distribution of common event causes for leakage events (1974–2002) ................... 4-2
Figure 4-2 Distribution of common event causes for leakage events (2002–2003) ................... 4-3
Figure 4-3 Events classified as significant or significant by others (1974–2014) ....................... 4-5
Figure 4-4 Leak events causing shutdowns (2003–2014) ......................................................... 4-6
Figure 4-5 Weld and base metal leaks causing or complicating shutdowns by source
(2003–2014) ....................................................................................................................... 4-7
Figure 4-6 Replaceable seal leaks by high-level cause ............................................................. 4-8
Figure 4-7 Replaceable seal leaks by joint type ........................................................................ 4-9
Figure 4-8 Average plant leaks by media ................................................................................ 4-13
Figure 4-9 Average leak distribution by severity (limited sample size) .................................... 4-14
Figure 4-10 Leakage by leak source ........................................................................................ 4-15
Figure 8-1 Historical fluid leak program health report ................................................................ 8-7
Figure 9-1 Scope of leakage program: example ........................................................................ 9-3
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LIST OF TABLES
Table 2-1 Leakage classification by fluid type and leakage severity ......................................... 2-4
Table 3-1 Work order person-hours associated with a leak ....................................................... 3-2
Table 11-1 Example of a one-day FLM program peer-review agenda .................................... 11-3
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1
INTRODUCTION
Reducing the number of leaks at a plant by managing the leakage events should no longer be
the primary objective of plant programs in this topical area. Along with leak management, an
effective program incorporates all aspects of improved fluid leak management (FLM)
technologies at plant sites to prevent leaks from occurring in the first place is the best practice.
For those that do occur, proper evaluation of those leaks, both singularly and from a cumulative
perspective, should focus on preventing the leaks from jeopardizing safety (nuclear, radiological,
and industrial) and generation.
1.1 Background
Since 1981, EPRI has developed and delivered a variety of technical products related to various
aspects of FLM. These products have ranged over a variety of topics, including bolting,
fasteners, on-line leak sealing, inspection, freeze sealing, various components, and more. In
1992, EPRI began to promote the concept of managing leakage events, as opposed to the
traditional approach of responding to them in an efficient manner, in relation to ongoing work in
the area of borated water corrosion in pressurized water reactors. This led to the first specific
section addressing plant leakage reduction to be published in an EPRI document Boric Acid
Corrosion Guidebook, in 1995.
EPRI continues to work with utilities, manufacturers, and service providers to bring state-of-the-
art techniques in the installation of sealing products and maintenance of components to reduce
both the number and the severity of those leaks. EPRI does this through continuous interface
with its members on both an individual basis and collectively through participation in outside
groups such as Fluid Leak Management Users Group (FLMUG).
Figure 1-1 is a synopsis of that guidance at the time of the publication of this document. Note
that EPRI periodically updates its guides and creates new guides based on industry needs and
current best practices.
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Introduction
Figure 1-1
EPRI FLM technical guidance (Consult www.epri.com for current products.)
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Introduction
1.2 Objectives
The objectives of this document are to provide plant management and technical support staff
with the information necessary to evaluate the effectiveness of their current leakage management
programs and to improve the performance of the programs in a cost-effective manner. By
following the information in this document, those involved in creating and managing leakage
reduction programs should be able to do the following:
• Evaluate the effectiveness of their current program.
• Establish practical goals for an improved program.
• Identify the benefits of establishing an effective plant FLM program.
• Identify the required resources to establish and support an effective FLM program.
• Select an FLM program owner (FLMPO) with the requisite skills to develop and implement
the improved leakage management program.
• Establish and implement a cost-effective leakage management program.
• Track the performance of the program and make improvements as warranted.
1.3 Target Audience

The material is directed towards individuals involved in creating and managing FLM programs.
These include plant management, work management, FLMPOs, engineers, work analysts, and so
on. It is not directed toward craft personnel, although craft personnel will benefit significantly
from a clear description of the fluid leakage management program selected for implementation
at the plant.
1.4 Summary
• The objectives of this document are to assist plants in evaluating the performance of their
current leakage management programs and to provide guidance to improve the program
performance in a cost effective manner
• This document is directed toward plant management, work management, FLMPOs,
engineers, and work planners.
• Craft personnel will benefit from a clear description of the final program developed for the
plant FLM program.
Plants are provided a basis and means to manage, assess, improve performance, and provide
guidance for a sustainable FLM program based on industry best practices and proven
performance techniques. This document provides insight into and specific examples of what
industry excellence looks like in the area of FLM.
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2
LEAKAGE DEFINITIONS AND CLASSIFICATIONS
At one time, the lack of a common definition and classification of leakage severity posed a
problem when attempting to compare or communicate leakage experience between plants.
Without such a standard, the overall level of leakage at a plant became a qualitative estimate
subject to a wide range of interpretation. For example, some utilities classified a film of oil on a
lube oil system flange as a leak, whereas others consider this a normal condition easily handled
by periodic wipe downs. Based solely on different interpretations, one plant reported a leak,
whereas another did not.
A milestone achievement by utility technical advisory group members for EPRI’s FLM program
in the late 1990s was the development of an acceptable industry standard to quantify leakage
events. This has continually been reviewed and updated, and this document reflects minor
updates to that standard.
2.1 General Definition of a Leak

The program’s Technical Advisory Group (TAG) members recognized that there were two
important aspects to quantifying general leakage experience across the industry. First, the TAG
agreed that it would be necessary to develop and adopt some common definitions for what
constituted a leak. The resulting accepted EPRI general definition of a leak is a process fluid
escaped or escaping from a component in an amount that is in excess of the amount acceptable
for the component’s designed operating condition.”
Key elements of this definition necessary for an accurate understanding are as follows:
• The definition pertains to a process fluid such as oil, water, steam, air, and chemicals that is
necessary to facilitate some industrial process. This includes those fluids which are essential
to equipment reliability or habitability such that the loss of those fluids may cause damage to
equipment needed for power generation or nuclear safety. A specific example of this would
be the oil that separates from grease in MOV actuators and tends to leak through gaskets.
While the oil/grease may not be a process fluid, it is needed to operate a piece of equipment
that is necessary to facilitate an industrial process. Therefore, this kind of leak is included in
scope of this document. In the case of lubricants, leakage is evidenced by formation of a
drop, not mere discoloration. The intent is to specifically segregate process leaks from other
nuisance leaks, such as those from roofs, bathroom fixtures, and other nonprocess systems
that might otherwise be found at any plant site and have no impact on plant reliability.
• The definition contains a reference to an escaped or escaping fluid, which connotes an
unintended release that is different from other normal means such as evaporation (from an
open system). The phrase also highlights the intent that the definition is meant to encapsulate
both active and inactive leaks.
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Leakage Definitions and Classifications
• Finally, the definition quantifies the amount of escaping leak as being “in excess of that
amount for the…designed operating condition.” This was specifically intended to address
instances such as with packing/mechanical seals on rotating shafts, where some defined
amount of leakage is desirable or even required in order for the system or component to
successfully perform its function. However, no leakage is generally expected from valve
packing, mechanical bolted or threaded connections, O-rings, and so forth.
2.2 Defining the Program Scope

Much worthwhile debate has occurred over the past ten years about what types of leakage events
should be included in a plant FLM program. In general, it is the consensus industry position
accepted by EPRI that plant FLM programs should, from a leakage standpoint, limit their scope
to addressing external leaks from plant process systems or supporting systems. From a
preventability standpoint, this program focuses on leaks from a replaceable seal.
This immediately rules all types of in-leakage and through-leakage events out of scope as they
do not typically represent external leaks. This means that internal valve seat leakage, for
example, is normally out of scope of an FLM program unless it directly results in a leak to the
environment, such as a relief valve seat leaking by or uncontrolled leakage past a seat to the
atmosphere. Similarly, condenser tube leakage, heating/ventilation/air conditioning air in-
leakage, and other such in- and through-leakage events are also out of scope
The intent of the above definition is to confine the scope of the program relative to the
identification of leaks to all external leaks. The use of other programs to address specific
technical issues such as erosion/corrosion, microbiologically induced corrosion, and boric acid
corrosion is recognized as necessary. Individual program health assessments for other programs
will ensure their technical effectiveness.
Typically, seal types that are considered in scope from a preventability viewpoint of the FLM
program would include gaskets, valve packing, rotating shaft seals, threaded piping components
and joints, compression fittings, and static seals such as O-rings. Although no replaceable seal is
at fault, through-wall leaks are also considered in-scope because it is external leakage and
typically requires FLM program resources to resolve.
As indicated elsewhere in this document, a leakage event must also be related to plant process
equipment or a related component. Leaks related to structures (for example, roofs, floors, walls),
facility fixtures (for example, faucets, toilets, drinking fountains, and so on), and non-process
related systems are generally not considered to be in scope unless the leaks cause a plant
equipment reliability concern.
One exception to this rule is the plant firewater system. Although not a part of the plant process
system per se, the firewater system directly supports the capability to maintain the integrity of
plant process systems during an off-normal event (that is, a fire).
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2.3 Leakage Severity Levels for Common Fluid Types

Once the general definition for a leak was accepted, the TAG members agreed that further
clarification would be necessary in order to quantify the relative severity of a leakage event to
some common standard for the purpose of enabling comparative discussion of separate leakage
events.
The TAG began by defining as many as nine levels of severity, but after extensive discussions
over a period of time, that number was ultimately reduced to five general severity levels deemed
an adequate balance between definition and practicality.
The five levels of severity, in order of increasing magnitude, are as follows:
• Level 1 represents an inactive leak or evidence of a past leak, but no active leakage.
• Levels 2–5 represent increasing levels of active leakage.
See Table 2-1 for these severity levels based on fluid type and leakage quantity. There are some
special considerations for borated water leakage.
In thinking through the actual application of these metrics in a plant setting, the TAG also
deemed it necessary to provide more specific guidance on leakage metrics according to the four
basic fluid types found at commercial power plant environments: oil, water, steam, and air. In
addition, for pressurized water reactors (PWRs), specific guidance has been given for boric acid
leaks due to their regulatory significance.
Table 2-1 summarizes the resulting matrix of individual leakage level definitions for each basic
fluid type.
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Table 2-1
Leakage classification by fluid type and leakage severity
Leakage Severity Levels

1 2 3 4 5
Fluid
Inactive Active
Inactive Leak Detectable Leak Small Leak Medium Leak Large Leak
Inactive leak or evidence <1 drop/5 min Up to a steady stream <0.1 gpm (0.38 lpm) >0.1 gpm (0.38 lpm)
Oil/chemicals of past leakage1 of droplets (~0.02 gpm
[0.076 lpm])
Inactive leak or evidence <1 drop/5 min Up to a steady stream <0.1 gpm (0.38 lpm) >0.1 gpm (0.38 lpm)
Water of past leakage of droplets (~0.02 gpm
[~0.076 lpm])
Inactive leak or evidence Simmering with no Leakage stream 4.a. Measured <0.1 gpm 5.a. Measured
of past leakage observable stream detectable at distance (<0.38 lpm) >0.1 gpm (0.38 lpm)
<2 in (<50.8 mm)2
Steam 4.b. Stream detectable at 5.b. Stream detectable
distance <6 in (152.4 mm) at distance >6 in
(152.4 mm)
Detectable using a Leakage stream Stream detectable at distance <6 Stream detectable at
Air/gases N/A soap solution detectable at distance in (152.4 mm) distance >6 in
<2 in (<50.8 mm)3 (152.4 mm)
Inactive Active
Inactive leak or evidence Dry, nonexcessive Dry, excessive4 Wet or wetted deposits/buildup; Active dripping or
Borated of past leakage; no deposit/buildup in deposits; noticeable Intermittent leaks/evidence of streaming
water noticeable change in immediate region of change in buildup over fluid transport (for example, wet
deposit; milk ring leak location time; discoloration only while in service)
Note:
1
For oil and lubricants, evidence of a leak is the formation of a drop of fluid, not mere discoloration.
2
Leakage stream detectable by impingement on a mirrored surface or tell-tale (a wisp of air detectable only at 2 in. (50.8 mm).
3
Air leakage stream detectable by motion of a tell-tale.
4
Excessive as defined by WCAP 15988-NP.
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The classification of leaks per Table 2-1 should represent the worst case scenario condition. For
example, if a leak is identified and assigned a severity level of 1 during static conditions, but
then the component experiences a change causing an increase in severity of leakage at which
point the leak would fall in the severity level 4 classification (even if only temporary), the leak
should be assigned Class 4.
It is recommended that these general classifications by fluid type and leakage severity be adopted
and implemented as the common standard for leak evaluation and comparison. An industry
standard scoring metric will be based on each leak’s classification. This scoring metric is
discussed further in Section 8.5.3.1.
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3
FLM PROGRAM BENEFITS
Allocation of plant operations and maintenance (O&M) resources can be very competitive at
commercial power plants. Where a regulatory requirement or industry-identified area for
improvement exists, the decision to allocate plant resources in order to address the issue is
relatively certain. However, in all other cases, when plant management considers the relative
merit of allocating resources to address an issue that is not similarly driven, the relative benefits
to be derived must be evaluated.
The principal benefits for the development and implementation of a plant FLM program at a
commercial power plant generally fall into one of the following five categories:
• Improved plant safety
• Improved plant appearance
• Direct cost reduction
• Reduced indirect O&M impact
• Improved industry and regulatory recognition
The following sections summarize various attributes of each incentive category. These sections
should assist in helping plant management formulate a decision on the relative value of
implementing or maintaining an FLM program for their site.
3.1 Improved Plant Safety

With respect to safety significance, this is probably the least consequential incentive category as
leaks of any immediate safety significance are virtually always addressed immediately on
discovery by plant maintenance resources. Personnel injury accidents resulting from plant
leakage incidents, although they have occurred, are extremely rare. Nonetheless, some severe
leakage events, such as when using leak sealant injections, can cause increased and unnecessary
risk to both personnel and plant equipment. Similarly, the spread of extremely radioactive
particles (for example, fuel fleas) can also be a hazard.
Data provided by plant radiation protection departments as part of overall cost impact
assessments at a number of U.S. plant sites, pertaining to fluid leakage events, suggest the
cumulative radiation exposure for all plant personnel due to leakage can be significant. At one
plant, for example, this amount was reported as high as 60 REM in 1 year. Assuming industry-
accepted values of $10,000–$25,000 per man/REM of dose in 2005 increased to $12,500–
$31,000 in 2015, this translates to $750,000–$1,860,000 excess financial burden due to leakage
events, notwithstanding any potential immediate or longer term health effects resulting from
such exposure.
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FlM Program Benefits
3.2 Improved Plant Appearance

Although not necessarily a personnel safety or plant performance issue, improved plant
appearance resulting from reducing leaks and associated leak management paraphernalia (for
example, drip pads, funnels, catch containments, equipment tags, boundary markers) can yield
both tangible and intangible benefits. With respect to tangible benefits, there is certainly some
cost saving associated with using and maintaining less of the aforementioned paraphernalia
necessary to manage leakage events. With respect to the intangible, it is an accepted fact that a
cleaner workplace, free from obvious defects, tends to increase morale, standards, and the desire
among workers to maintain or continue to improve that condition over time.
3.3 Direct Cost Reduction
3.3.1 Cost of Direct Work to Repair Leaks

Direct cost reduction is certainly a benefit to implementing an FLM and prevention program.
Prevention of leaks reduces the cost of simply repairing the routine leak that occurs that has not
caused a plant event such as a shutdown. The simple cost of writing and processing a work order
to repair a leak is >$5000, not including parts and materials, as shown in Table 3-1.
Table 3-1
Work order person-hours associated with a leak
Work Order Person-Hours Associated with a Leak
Activity Resource Person-hours

Identification and initial cleanup Operations 1
Write incident report/condition report Operations 0.5
Operations review Shift manager 0.5

Station committee review Multidiscipline group 0.5
Roll to work order Work control 0.5
Clerk to print package Planning 0.5

Schedule cycle planner Work control 0.5
Develop out of service (develop and reviews) Operations 7
Develop radiation work permit/as low as

reasonably achievable review/attach work Radiation protection 3
order
Purchase parts (catalog identify development
Procurement 1
and purchase)
Stores to pull parts (receive, inspect, deliver,
Stores 3
and so on)
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Table 3-1 (continued)

Activity Resource Person-hours

Mechanical maintenance department to Mechanical maintenance
1
walkdown package department
Mechanical maintenance
First-line supervisor to review package 0.5
department first-line supervisor
Hang out of service Operations 2
Work execution (briefs/repairs) 8
Clear out of service Operations 2
Close out work package 1
Clerk to process package (closure and
Planning 1
scanning)
Total person-hours 33.5
Cost @ $75 per person-hour $2513
Work package preparation cost $3000
Total labor cost $5513
Parts and materials cost Unknown and varies
3.3.2 Costs Associated with Cause Analysis of Leaks

In addition, costs associated with cause analysis performed for more significant leaks from an
apparent cause analysis to a complete root cause analysis add to the cost. Utilities estimate that
apparent cause analyses cost $3520 and root cause analyses cost ~$30,000. These consume
valuable person-hours that could be spent on plant improvements rather than dwelling on past
issues, that is, drawing circles around bullet holes. This does not suggest that finding the causes
of leaks is not important and certainly does not suggest that the corrective action program is not
important. It only means that if the leaks were eliminated, the cost associated with the corrective
action program would be less.
3.3.3 Costs of Replacement Power for Leaks Causing Shutdowns

Last, but not least, is the obvious cost of replacement power, lost production during a forced or
extended outage, or down-power event. Costs of replacement power vary greatly depending on the
cost of replacement power at the time, but numbers that are frequently quoted are $1 million/day.
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Review of wholesale electricity cost data from June 2014 to June 2015 shows a cost of electricity
of >$68 per MWH. So, for a 1000-MW nuclear power plant, this would be ~$1.7 million/day (note
that the variance from high to low is $0.5 million to ~$2.9 million, depending on the electricity
demand for that time period) (source http://www.eia.gov/electricity/monthly/update/wholesale_
markets.cfm). Data for leaks causing or complicating shutdowns are discussed in Section 4.
3.3.4 Radwaste and Water-Processing Costs

Leakage of water can be a significant cost from both the cost of purifying and treating water used
in plants to the cost of processing radwaste from leaks in some instances.
3.3.5 Special Costs

Plants using Canadian deuterium/uranium technology use heavy water as the moderator. The
cost of a drum of heavy water used in a Canadian deuterium/uranium reactor has been reported
to be ~$95,000 CAD a barrel or greater than $1700 CAD a gallon! Therefore, the prevention of
leaks at heavy water plants is a special consideration.
3.4 Reduced Indirect O&M Impact

In addition to these estimated costs, even relatively inconsequential and nuisance leaks can have
an indirect effect on plant O&M resources.
As an example, many small or inactive leaks are viewed as simply a housekeeping issue at many
plants. Although it is true that they may have no direct effect on plant operations, availability, or
generating capacity, they do require the application of maintenance resources in the form of
remediation materials (for example, drains, pads) and periodic labor to install, replace, and
dispose of such materials.
In addition, they contribute to the confirmation of an overall plant culture that is accepting of
minor defects in plant condition. The obvious problem is that this starts the plant on the slippery
slope of subjective judgment as to what type of leak and level of leakage is acceptable and what
is not. This acceptance tends to inevitably expand incrementally over time, as the culture
becomes accustomed to a given level of defect.
Consequently, maintenance resources, principally administration and labor, dedicated to
addressing minor leakage events on a periodic basis invariably add up over time to a sum that
frequently surprises many in plant management when confronted with a credible aggregation of
these resources and their cost. The hidden cost here, however, lies in the untallied cost impact
resulting from those maintenance issues that have been either delayed or deferred due to the use
of plant resources to address leaks.
3.5 Improved Industry and Regulatory Recognition

In an era of more performance-based regulatory scrutiny, plant management decisions and plant
programs that appear to provide an observable improvement in plant safety, capacity, availability,
or equipment reliability can create an environment where the visible performance of a plant sets
the tone with both regulatory bodies and the industry. This visible level of performance is
frequently accompanied by an associated culture of more intense attention to detail and a
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questioning attitude that fosters a more favorable level of scrutiny by regulatory bodies and
performance-assessment organizations representative of actual plant performance. This, in turn,
allows station management and maintenance resources expended to respond to these bodies to be
reduced, thus allowing more energy to be focused on actual performance improvements because
scrutiny, on-site presence, and administrative burden (that is, bureaucracy) is often proportional
to technical stature. Also, when plant management direction or a plant program is recognized by
regulatory bodies or performance assessment organizations, there is a tendency to refer to that
plant as a model for others to follow in pursuit of that same level of technical excellence in a
given area. Similarly, there is most certainly some intangible value to being highly regarded
within the industry for a particular technical achievement.
Thus, perhaps, the most important incentive to implementing and maintaining an FLM program
may be to contribute to the exemplary performance, with its attendant built-in costs, and perhaps
gain industry recognition, which brings with it some level of value.
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4
INDUSTRY EXPERIENCE
4.1 U.S. Experience: 1974–2003

There is a tremendous amount of documented industry operating experience (OE) relating to
fluid leakage events. In addition to specific significant events resulting in increased regulatory
scrutiny, virtually every plant, regardless of nuclear steam supply system type, has experienced
at least some level of impact to plant availability and reliability attributable to fluid leakage.
The following sections summarize recent industry data on reportable significant events and
provide additional information that may be useful to plant personnel to evaluate event precursors
and identify actions to eliminate vulnerabilities to prevent similar events.
4.1.1 Significant Event Data: 1974–2002

In 2002, one industry technical analysis, Institute for Nuclear Power Operations (INPO) 02-005
Analysis of Significant Events sought to identify the 20 most significant U.S. nuclear plant
events occurring since 1974. The basic criteria were that these events were either important to
nuclear safety or were responsible for significant consequences or both.
The analysis reportedly showed that six of the 20 most significant events analyzed, or ~30% of
the time, involved degradation of the pressure boundary due to a leakage event.
The analysis concluded that operation with known equipment problems that subsequently
affected the event or complicated the operators’ responses to the event was a factor. The analysis
also noted that in three of these events, station personnel continued operation with a leak from
the reactor coolant system that later resulted in serious problems.
The analysis also found that lessons learned from industry and internal OE had not been
implemented in 25% of the cases.
In looking more closely at these events, the most common event type among the 20 events
involved the potential for an unisolatable leak due to a degraded pressure boundary. The analysis
subsequently identified the common event causes contributing to each of the 20 events. In those
events pertaining to system or component leakage, common event causes include the following:
• Operation with known equipment problems
• Lack of appreciation of risks
• Improper operator response to abnormal conditions
• Erroneous assumptions
• Pressure to continue operations
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• Required action not taken by operators

• Operator knowledge or training
• Inadequate procedure guidance
• OE not properly implemented
• Indication problems
• Senior license holder did not maintain oversight
The distribution of common event causes to leakage events is shown in Figure 4-1.
Problems with
Operating Indicators, 4%
Experience Not
Correctly
Implemented, 4% Improper
Inadequate Oversight, 4%
Procedureal
Operator Knowledge Guidance, 4%
Operation With
or Training, 4%
Known Equipment
Operators Did Not Issues, 19%
Take Required Lack of Risk
Actions, 8% Appreciation, 15%
Mistaken
Assumptions, 11%
Management
Pressure for
Continued
Operations, 12% Wrong Operator
Response to
Abnormal
Conditions, 15%
Figure 4-1
Distribution of common event causes for leakage events (1974–2002)
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4.1.2 Special Analysis Conducted Between 2002 and 2003

Subsequently, due to a reported increase in the number of significant event reports and notices
reported during the first nine months of 2003, another industry analysis, INPO 03-005, Analysis
of Recent Significant Events, was conducted to review significant events occurring during the
18-month period between January 2002 and September 2003. From this review, four of 19
significant events pertained to leakage associated with plant systems or components, resulting
in degradation of the pressure boundary.
Common event causes for these four leakage events were determined to be the following
(Figure 4-2):
• Equipment fault or material degradation/aging
• Lack of experience, knowledge, or training
• Ineffective oversight
• Nonconservative decisions
• Lack of questioning attitude or complacency
• Ineffective problem resolution or station program
• Ineffective use of station's own OE
Ineffective Use
of Station's Own
Operating Equipment Fault,
Experience, 1 Material
Degradation or
Ineffecti Aging, 2
ve
Problem Lack of Questioning Lack of Experience,
Resoluti Attitude or Knowledge or
on or Complacency, 1 Training, 1
Station
Program,
Non-Conservative Ineffective
1
Decisions, 1 Oversight, 1
Figure 4-2
Distribution of common event causes for leakage events (2002–2003)
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In some cases, it appears that specific industry leakage issues are well defined, such as radially
inward buckling (RIB) of spiral-wound gaskets causing foreign material contamination and
damage to plant systems and components. In particular, numerous plants had reported finding
foreign material attributable to the stainless steel metal windings from buckled spiral-wound
gaskets causing fretting of steam generator tubing. Such damage to steam generator tubes
currently requires tube plugging to repair and eventually accelerates the requirement for
expensive steam generator replacement. This particular problem has been addressed by the use
of spiral wound gaskets with inner rings or gaskets that are not susceptible to this phenomenon
for joints that have been disassembled with new gaskets installed. Some legacy joints may still
be susceptible, but this is decreasing with time.
4.2 Analysis of Events Adding 2003–2014 Events to Previous Analysis of

Significant Events
As part of this revision, an analysis of events occurring from 2003 until 2014 has been performed
and added to show overall historical industry trends and focus over more recent years.
4.2.1 Significant Events: 1974–2014

Since this analysis was performed, another analysis using current criteria for significance
(significant by INPO and significant by others) was performed (Figure 4-3). For the period of
1974–2002, ~7% of significant events involved external leaks. For the period of 2003–2014,
the overall number of events has decreased and, along with that, leakage events. However, it
is interesting to note that leakage events still account for nearly the same number of significant
events.
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Figure 4-3
Events classified as significant or significant by others (1974–2014)
Clearly, it appears that the industry has made progress in reducing significant events involving
leaks. However, the industry is still striving for continued improvement in this area as evidenced
by the continued support of efforts by EPRI in improving guidance for mechanical joints and the
thriving of non-EPRI groups such as the FLMUG, which seeks to share knowledge between
utilities, vendors, service providers, and other entities to improve performance in this area.
To provide more focus on what areas continue to be problematic, events from 2003 to 2014,
designated as significant by INPO involving leaks were examined. Four events were identified
that were the direct result of system leakage. One additional event was complicated by a leak in a
system important to accident mitigation, but the event was not directly caused by a leak. Of those
significant events, four were attributable to joints within the scope of this program. Of those, two
involved the reactor head flange (a metal O-ring joint), one was a more common gasket, and one
was a base metal defect.
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4.2.2 2003–2014 Events Causing Forced Shutdowns Analysis

Additionally, events in U.S. plants that caused unplanned shutdowns or significantly complicated
shutdowns (for example, a leak caused a safety system to not be available when needed because
of the shutdown) were examined. From 2003 to 2014, 182 events were identified that caused or
complicated shutdowns; 81 of those events were caused by welds or base metal defects (that is,
nonreplaceable seals), and 101 (55%) involved replaceable seals (Figure 4-4).
An analysis by year shows a favorable trend in the numbers of leaks causing forced shutdowns
by year until 2012. However, increasing numbers in 2013 and 2014 as well as trends through
June 2015 are not favorable. The economic impact of these shutdowns is considerable, as
discussed in Section 3.
Shutdowns Caused or Complicated by All External Leaks 2003-

2014
30
25
20
15
10
0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014
Replaceable Seals and Joints Welds, Base Metal, etc.
Figure 4-4
Leak events causing shutdowns (2003–2014)
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4.2.2.1 2003–2014 Events for Base Metal and Welds

Although beyond the scope of the prevention side of the FLM program, it is interesting to note
that the source of leaks outside the FLM program (primarily welds, brazes, solder joints, base
metal, and expansion joints) and the sources of those leaks are significant in number.
Leaks Causing or Complicating Shutdowns 2003-2014

Welds and Base Metal Type
Unknown, 1, 1%
Tubing, 2, 2% Design
Solder Joint, 3, 4% Valve Body, 1, 1%
, 1, 1%
Bellows, 2, 3%
Base metal, 3, 4%
Weld, 43, 52%
Expansion
Joint, 4, 5%
Brazed Joint, 7, 9%
Pipe, 15, 18%
Figure 4-5
Weld and base metal leaks causing or complicating shutdowns by source (2003–2014)
A chart of those is shown in Figure 4-5. Clearly, welds and base metal leaks continue to be an
issue. Since many of the leaks are due to age-related mechanisms such as corrosion and fatigue,
this would seem to make sense based on the age of U.S. plants. Program such as microbiologically
induced corrosion and flow accelerated corrosion as well as primary system corrosion programs
are all high-visibility programs by EPRI from a nondestructive examination and metallurgical
perspective. However, the FLM program must continue to be vigilant in identifying leaks if they
do occur and involve personnel responsible for other programs in the assessment and repairs of
those leaks. FLMPOs may often be involved in coordinating temporary repairs, depending on the
organization and responsibilities at the station. The bottom line is that identification of all external
leaks is within scope of the FLM program even though the analysis and ultimate repair methods
are outside the scope of the FLM program.
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4.2.2.2 2003–2014 Events for Leak Sources in the Scope of the FLM Program
Leaks causing shutdowns that are in the scope of the program were examined more thoroughly to
provide the industry with focus areas for improvement. The data were parsed and analyzed in
several different ways as follows:
High Level Causes for Leaks from Replaceable Seals Causing

Shutdowns (Numbers of Leaks)
2003-2014
45 42
40
35
30
25
20
19
15
15
8
10
6 6
5 2 1
0
Inadequate Inadequate Unknown Preventative Inadequate Manufacturing Fatigue Seal Control
work practices procedure Maintenance design Issue System Problem
Program
Inadequacy
Figure 4-6
Replaceable seal leaks by high-level cause
Figure 4-6 shows these events by high-level cause. Clearly, issues related to maintenance
implementation (inadequate work practices and procedures) account for almost two thirds (62%)
of the events. These issues are often hard to separate because some uses have less detail in their
procedures because they believe that their worker knowledge and/or experience require less
detail. Unknown causes are next in frequency (Figure 4-7). Preventive maintenance program
inadequacies often are cases of poor programs such as packing maintenance programs or
instances where age-related degradation of elastomers caused notable leaks. Since these data are
for the period 2003–2014, with essentially no additional plants in that time frame, it is suspected
that design issues were exposed earlier in the life of the plants. Cause unknown represents 15%
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of the events and often represents events caused by moisture intrusion to electrical or control
equipment where the leak source was unknown. Miscellaneous causes such as wrong material,
lack of preventive maintenance, manufacturing or material defects, and inadequate oversight
account for only 15% of the events.
Replaceable Joints Types Causing or Complicating Shutdowns

2003-2014
30 28
25
22
20
15
10 9
8
6
5 4 4
3 3
1 1 1 1 1 1 1 1 1 1 1 1
0
Figure 4-7
Replaceable seal leaks by joint type
Gasketed flanges and valve packing account for more than one-half of the leaks. This is expected
since there are so many of those joints. A surprising result was the number of joints involving O-
rings (flanges, fittings, and packing), which accounted 14 events. Compression fittings and
threaded pipe fittings also were significant but are numerous in plants.
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4.3 Conclusions
Based on OE analysis from 1974 to 2014, the following can be concluded:
• Significant leaks have been drastically reduced during the time period 1974–2014, indicating
progress by the industry and effectiveness by industry efforts to prevent and manage leaks.
• Leaks are still a significant contributor to shutdowns, and trends in 2013 and 2014 indicate
that focus by utilities to address leaks is needed. A look at shutdowns in the first half of 2015
indicates similar trends in 2013–2014.
4.4 Industry Performance Metrics

A common area of interest in planning or assessing plant FLM efforts is centered on how a given
plant compares with the rest of the industry in terms of leakage events and FLM programs. The
following sections provide guidance on assessing that comparison, focusing on particular types
of sealing issues and summarizing common methods for predicting emerging leakage issues at
a plant.
4.4.1 Industry FLM Program Self-Assessment Results

One of the most frequent questions asked by plant management in relation to their FLM program
is how does our program performance compare with that of other plants? Until recently, this was
a difficult question to answer because no common standard of comparison existed.
In 2008, the nuclear power industry’s FLMUG took on the challenge of creating a comprehensive
self-assessment tool based on a similar assessment tool previously developed and successfully
used by the industry’s predictive maintenance personnel. The resulting FLM Self-Assessment
Metric provides the framework by which users self-assess their plant’s performance across a
range of criteria organized under four broad categories.
The first category helps users evaluate their plant FLM program from the standpoint of its success
as a station process. Specifically, this category seeks to define whether the plant FLM program
has defined performance goals, whether the program is clearly defined and has ownership by
both plant technical staff and management, whether it has an identified technical lead with the
necessary capabilities to be successful, and to what degree the program is results oriented.
Next, the assessment tool guides the user in evaluating criteria that have a bearing on the
potential success during program implementation. These criteria include an evaluation of the
program scope and supporting plant technical procedures, whether key definitions and
performance metrics exist, whether the plant has a reliable means to track and trend leakage
events, the process by which leaks are addressed by maintenance, to what extent the plant seeks
to understand the cause of individual leakage events, how the station manages data relating to
plant FLM issues, and, finally, whether the training provided by the plant is sufficient and
effective to minimize the occurrence of leakage events.
The assessment tool then provides the users with an opportunity to evaluate their use of tools and
materials. In this section, the eventual intention of the industry user group is to develop detailed
subassessments for gaskets and seals, valve packing, and boric acid corrosion control (BACC)
programs that will then feed their results into this overall assessment matrix. At this juncture,
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only the valve packing detailed assessment tool is completed. In the interim, users are simply
inserting values for gaskets and boric acid programs, along with valve packing if the detailed tool
has not been used, in the overall assessment. Eventual metrics in this section yet to be defined
will no doubt focus on the effectiveness and specific application of tools and sealing materials,
and their relative success in minimizing leakage events.
Finally, the assessment tool provides users with a section to evaluate the success of their FLM
program as a living process at their site. Metrics include to what degree the FLM program has
been included in the program health–reporting process, the level of attention paid to leak
detection and prevention, and the extent and effectiveness to which industry operational
experience are obtained and implemented.
As an example, the following chart illustrates the results of the self-assessments recorded since
2009 using the FLM Assessment Guide. The average score for each line item in the self-
assessment categories is given in the far right column. In general, the following observations,
based on those plants participating in a full FLM self-assessment are shown below.
Average scores for each plant performing a self-assessment are provided across the bottom of the
chart and are color-coded according to the legend appearing below the chart. In general, a score
of 1 is judged to be the poorest performance, whereas a score of 10 is judged to be the best
performance.
In terms of individual plant performance, results run from weak (2) to very strong (10), with one-
third of the plants ranking their FLM programs as strong to very strong (7–9) and one-half of the
sites ranking their programs average (5–6).
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Station M
Station G
Station A
Station B
Station C
Station D
Station H
Station K
Station N
Station E
Station F
Station L
Station J
Station I
Ave
FLM
FLM as a Station Process Score

Station Goals 9 6 8 7.5 7 5 10 8 7 6 5 6 3 7 6.75
Clarity and Ownership 8 5 8 7 8 5 10 8 8 8 6 7 7 8 7.36
Staff Capabilities & Exper 10 7 6 7 5 6 10 8 7 5 5 4 3 6 6.38
Focus on Results 10 4 6 7 5 4 6 8 6 5 4 5 2 8 5.71
FLM Implimentation
Program and Procedures 10 4 6 10 4 4 9 8 6 4 6 5 4 8 6.29
FLM Leak Definition & Metrics 10 6 8 10 8 8 10 9 10 5 7 7 5 10 7.92
Leak ID and Tracking 8 6 8 6 10 8 10 9 9 8 7 6 6 8 7.77
Addressing Leaks 8 5 7 7 8 4 8 8 6 6 4 5 3 6 6.07
Leak Cause & Determination 10 6.5 3 7 4 5 6 5 7 6 4 3 4 7 5.54
FLM Data Management 6 5 8 8 6 5 8 6 7 7 6 6 3 10 6.50
Training 8 4 4 4 6 5 8 5 5 8 4 5 5 7 5.57
Living Process
Program Health Assessments 10 8 10 3 3 10 6 3 8 7 8 3 3 6.31
Leak Prevention 9 3 4 6 6 5 6 6 7 4 4 4 4 6 5.29
Use of OE and Best Practices 10 7 5 8 6 8 6 7 8 6 8 3 8 6.92
Score Overall Average 9.00 5.46 6.33 7.25 6.29 5.21 8.50 7.14 6.79 6.29 5.36 5.64 3.93 7.29 6.40
LEGEND: 1-2 RED
3-4 YELLOW
5-6 WHITE
7-8 GREEN
9-10 GOLD
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4.4.2 Sample Plant FLM Performance
In preparing this report, a leading industry software data provider was asked to develop a fact-
based response comparison of the plants with respect to leaks.
The data provider took a cumulative look at all data from the 20 available sites and used the
information to provide the charts seen below. Figures 4-8 through 4-10 summarize the results
from the data. 1
Leak Media Boric Acid

Water
Steam
3%
Oil
12%
36% Air
12%
Chemical
14%
23%
Figure 4-8
Average plant leaks by media
Boric acid leaks continue to be an issue in the industry, making up 36% of the leaks on record at
the time of the survey. The results also indicate that water and steam leaks are a large portion of
the leaks identified.
1
Data provided by SealPRO, a product of CurtissWright.
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Industry Experience
EPRI Class
5%
9%
35%
3 - Small Leak
17% 2 - Detectable Leak
1 - Inactive Leak
4 - Medium Leak
5 - Large Leak
34%
Figure 4-9
Average leak distribution by severity (limited sample size)
It is noteworthy that 49% of the dataset’s leaks are severity level 3 or higher. Typically severity
level 3, 4, and 5 leaks require repair. These data show that a large portion of the industry’s leaks
are going to require significant resources to fix. This leads to the conclusion that leak prevention
should be a focus for sites in order to keep maintenance costs down.
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Industry Experience
Leak Source
1%
0% 1%
4% 3%
Valve Packing
11%
Fitting
46% Gasket - Flange
12% Other
Gasket - Body-to-Bonnet
Mechanical Seal
Gasket - Pressure Seal
22% Seat Leak to Atm
Pipe Through-Wall
Figure 4-10
Leakage by leak source
However, for plants without such a program in place, it is entirely likely that with a strict FLM
program assessment using established guidelines for quantifying leakage events, those plants
may find that their numbers of leaks may differ, even substantially, from the average values
presented above.
4.4.3 Leading Indicators

Leading indicators can provide a valuable tool in helping plant personnel anticipate and prepare
to mitigate various types of potential plant maintenance issues. For example, increased vibration
can be a leading indicator of advancing bearing wear in plant rotating equipment. Unfortunately,
most plants appear to reside in a predominantly reactive mode when it comes to anticipating
leakage issues. Analysis of leading indicators, such as preliminary leakage events, can frequently
help to identify emerging generic leakage issues before their occurrence becomes more frequent
or widespread.
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Industry Experience
Based on the preceding survey results, most respondents indicated that they either use no leading
indicators to anticipate future leakage issues or rely on evaluating leakage events after the fact, in
some fashion, in order to identify a trend relative to a certain type of equipment or seal. Although
use of plant and industry OE has real value in assisting plant personnel in mitigating leakage events,
other more direct precursors should also be developed. Examples might include the following:
• Monitoring of air handling system performance in PWR power plants as an advance indicator
of minute boric acid leakage that is immediately airborne and eventually deposits in the
containment air filters.
• Rising radiation level as a means of identifying increasing leakage from primary systems.
• Increasing radwaste disposal processing volumes from sumps.
• Measured stem friction for air- and motor-operated valves significantly below calculated
values as a leading indicator of pending valve packing leakage.
• Lack of a formalized valve packing and gasket programs and a designated program owner(s).
• Implementation of use of live-loaded packing configurations far below the industry average
(~2% of installed configurations).
• Failure to implement industry best practices as outlined in FLMUG valve packing and gasket
assessment guides.
• Failure to incorporate new/better materials for certain applications or using materials with
known limited life spans.
Plants expecting to have an effective FLM program need to be creative in identifying and
implementing leading indicators for their plant that can provide advance warning of developing
FLM issues prior to their becoming leaks.
4.4.4 Industry Experience

Lagging metrics for assessing external leakage events, in the form of leak tracking and trending,
appear to be well implemented at most plant sites. Most plants indicate that they track leaks on
an ongoing basis and present a summary of the plant leaks to plant management at least once per
month. While it may be hard for a plant to determine what good looks like, a review of the data
shows that each site has roughly 265 active leaks. In this case, active represents those leaks
classified as severity level 2 or higher. Likewise, all plants review industry OE they obtain, and
many plants also participate in industry user groups related to improved FLM in order to obtain
additional information and data.
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5
OBJECTIVES AND GOALS
In order to begin the process of identifying worthwhile program objectives and setting
meaningful goals to define program success, a clear understanding of the current plant status as it
relates to leakage events is mandatory. To gain this understanding, it is important to first develop
an accepted definition for the scope of the program. Once the program scope is understood, steps
can be taken to develop an understanding of the current plant condition as it relates to current
leakage events. The knowledge of the current plant condition can then be used to begin the
process of establishing practical goals to reduce leakage events at the plant over time.
5.1 Current Status Assessment

There are at least five steps that personnel at every plant can take in order to develop a reasonably
accurate assessment of their plant’s current condition as it pertains to current leakage events.
These include the following:
• Assessment of plant management’s intolerance of leakage events.
• Analysis of the work management system records pertaining to leaks.
• Perform a walkdown inspection of the plant.
• Interview or survey cognizant plant personnel.
• Review recent industry peer assessments in the subject area.
5.1.1 Assessment of Plant Management’s Intolerance of Leakage Events

When assessing the current condition of a plant’s FLM program, it will be critical to determine
the station management’s mind set on leaks. Station culture is often molded by its leadership and
therefore the position management takes towards leaks will have a great effect on the overall
station culture towards the FLM program. There are several ways to determine plant
management’s stance on leaks. A few are listed below:
• Plan of the Day Meeting includes discussion of leak issues.
• Ensuring an FLMPO is assigned and active.
• Required monthly reporting.
• Allowance of participation in industry meetings.
• Training provided specifically for leak prevention/reporting.
• Outage initiatives such as fixing all temporary repairs before startup.
• Scheduling initiatives such as not pushing leak related work out of the schedule without
documented cause.
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Objectives and Goals
5.1.2 Analysis of Work Management System Records

One of the most effective means of gaining an accurate understanding of the current plant
condition, as it pertains to current and past leakage events, is to query the plant work
management data system to identify all those records that relate to leaks. While valuable and
always worth the effort, the ease with which this is accomplished is completely dependent on the
particular work management system in use and the quality of the data entered therein.
Typically, experience has shown that it is useful to query a period of at least two to three
operating cycles in duration, up to the present, so that any unusual events that would normally
skew the data interpretation for a shorter period are presented in a more complete context. Unless
the particular work management system has a special code applied to all work orders relating to
leakage events and there is a high-confidence probability that the preponderance of records in
the database are correctly coded, then it is recommended that the query used be structured to
return a list of all external leaks occurring during the period. This will necessitate a subsequent
record-by-record review, with manual deletions of out-of-scope records in order to develop an
accurate understanding of the state of plant leakage. This approach not only provides a snapshot
of the current state, but also places the current state in the context of time, so that an idea of the
general trend of leakage events can be assessed.
Once a reliable data set has been established, plant personnel can begin to analyze the results to
determine what seal types pose the greatest challenge to plant resources, what components have
the highest chronic leakage recurrence, and where resources should be prioritized.
Third-party software has recently become available to the industry to identify, track, trend, sort,
and report site leakage information using an automated updating process with the station’s work
management system. While these third-party software solutions remove a large part of the
manual labor of keeping track of the FLM program, the flagging of leak-related condition reports
and work orders remains crucial to the accuracy of the information, no matter how it is
accomplished.
5.1.3 Plant Walkdown Inspections

A simple means to develop a rapid appreciation for existing plant FLM issues is to perform a
walkdown inspection of the plant systems. A walkdown inspection can help the inspector
determine firsthand what types of leakage events appear to be most evident and to what level of
severity. In addition, the walkdown can also highlight typical maintenance approaches, such as to
what extent valves are live-loaded and whether hardened steel washers are routinely used on
flanges and under valve packing gland nuts.
In addition to walkdown inspections during normal plant operations, some utilities have found
that walkdowns performed immediately before coming down from power for an outage or plant
transient and again on coming up to power after an outage or transient are useful to ensure that
all leaks are identified.
A caveat when relying on walkdown inspection results: the results noted are only as good as the
eye of the inspector and his or her familiarity with potential leakage locations.
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5.1.4 Plant Personnel Interviews

Plant system or component engineering and maintenance personnel typically have an innately
accurate feel for the existence of leakage event issues and their severity for systems and
components for which they are responsible. Whether by in-person interviews, roundtable
discussion, or through an e-mail survey and response, soliciting the perspective of plant
engineering and maintenance personnel can provide numerous insights for uncovering a range
of FLM-related issues at a plant site.
Furthermore, this process is also valuable in identifying the relative interest and importance that
individual plant personnel attach to FLM issues within their respective areas of responsibility.
This related knowledge will prove valuable during program implementation in order to structure
cooperation with plant personnel in a manner that is most likely to succeed. This process can also
determine how aggressively plant personnel identify leaks.
5.1.5 Recent Peer Assessments

Periodically, plants may receive an evaluation in one or more technical areas conducted by the
INPO, the World Association of Nuclear Operators, the FLMUG, or other industry peer groups.
Interested plant personnel should determine whether such an assessment has been completed
within a useful recent period, and, if so, seek out the results from that assessment.
The principal value of peer assessment results are that they provide an outside view of their
plant’s condition and the corresponding FLM program. This outside viewpoint can be useful in
identifying potential technical or operational issues, as well as highlighting items that stand out
to outside observers.
Keep in mind that this does not necessarily mean that the assessment viewpoint is correct since
that is strictly based on the knowledge and impartiality of the inspection group, coupled with
their ability to have the necessary time to accurately understand the plant condition and FLM
program status. The assessment only provides a snapshot in time of those issues that appear to
stand out to outside observers who are not encumbered by overfamiliarity with the plant and its
operation.
It is strongly recommended that the FLM Self-Assessment Guide located in Appendix 12.1 of
this document be used for performing FLM self-assessments. This guide is widely used in the
industry and provides a comprehensive look at a station’s FLM program and provides objective
criteria for scoring. It is the best tool available currently that allows a plant to compare their FLM
program with that of their peers.
5.2 Establishing Practical Goals

In order to succeed, an FLM program must set and achieve goals that define the degree of
program success. As with other similar opportunities, setting unrealistic or unachievable goals
serves no purpose and, in fact, can severely damage the plant culture in such a way that
subsequent achievement of more reasonable goals becomes problematic.
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As with any goal-setting exercise, a goal should be reduced to a single objective where the
relative result can be measured or otherwise quantified against some previously established
metric. Refine each goal’s definition until a single value is in focus. Establish a corresponding
measurable metric of success and define one or more threshold values for achievement that
correspond to degrees of success. Finally, define a period of performance for each goal, as well
as a reasonable number of milestones (either calendar or event driven) during the period of
performance to review progress toward the goal with some accountability group.
As a caution, if initially developing and implementing a new plant FLM program, it is suggested
that plants initially focus on setting goals that are more easily achievable in order to build an
initial environment of success. This will assist the program and the program owners in gaining
traction for the program with management and peers and in building the confidence necessary to
successfully tackle more aggressive goals as the program develops.
Program goals can be developed by the plant FLMPO or others. However, in view of the fact
that the FLMPO will be primarily responsible for their achievement, it seems reasonable that the
FLMPO should have significant input in their definition. It is recommended that the FLMPO
establish a plant FLM technical committee, representing other related plant groups or programs,
to provide input for consideration of this and other related issues. Establishment of a committee
may, in fact, be a goal in itself.
Once developed, it is imperative that the FLMPO discuss these goals with plant management and
obtain their concurrence and support. In keeping with the above logic, a phased approach to goal
setting is recommended comprising the following:
• Initial goals designed to help new programs get off the ground successfully
• Performance goals intended to generally reduce the number of leakage events period over
period and over time
• Stretch focused on resolving specific challenges to the FLM program’s success that have not
been adequately addressed through general performance goals
5.2.1 Initial Goals for New Programs

When attempting to define and implement a new plant FLM program, initial goals should focus
on accomplishing those tasks necessary to establish a sound foundation for the program at the
plant and within the utility.
A frequent misstep made by plants attempting to implement an FLM program is to focus too
quickly on tasks and goals tied to showing an immediate reduction in the number or severity of
leakage events, without first ensuring that the necessary and important building blocks are
solidly in place that will enable the program to accomplish those types of tasks efficiently and
effectively over the longer term. This frequently results in a spike in the allocation of plant O&M
resources, which usually results in some reduction in the numbers of leaks and/or their severity;
however, long-term performance of the FLM program may suffer once station resources are
reallocated elsewhere. A quality FLM program needs to focus on ensuring that processes and
culture are established such that the program may stand on its own without brute force.
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In terms of identifying initial goals for a new program, the following are among the opportunities
to consider:
• Designate a plant organization responsible for execution of the plant FLM program, usually
either Engineering or Maintenance.
• Identify an FLMPO to be principally responsible for the day-to-day program development
and administration.
• Establish an FLM plant technical committee that meets on a regular basis to discuss and
facilitate the achievement of program goals.
• Identify and record all current active and inactive leaks in some formal leak-tracking system
that includes a plan to track each item and its disposition.
• Review all current active and inactive leaks and prioritize major areas for attention (for
example, valve packing, gaskets, threaded connections, mechanical seals).
• Review all current leakage-related work orders in the plant work control system and close out
those work orders that are no longer active.
• Define program reporting requirements and report formats.
Note that the initial goals all pertain to establishing the core building blocks that form the
foundation of any program and are not generally directly tied to some aspect of plant
performance with respect to leakage event mitigation.
5.2.2 Performance Goals for Established Programs

For established programs, goals should begin to reflect tasks that generally are intended to
further develop the general FLM program and begin achieving direct results in terms of
accomplishing the program objectives.
In terms of performance goals for an existing program, the following are among the
opportunities to consider for continuation of program improvement:
• Develop and execute a plan to review and revise related plant procedures, in a prioritized
fashion, to reflect the best technical guidance in each topical area. (Each procedure
subsequently becomes a separate performance goal.).
• Develop and execute a plan to review and revise related technical training modules provided
to plant personnel and supplemental work force personnel to reflect the best technical
guidance in each topical area. (Each module subsequently becomes a separate performance
goal.)
• Identify and conduct personnel training programs in targeted technical areas where
requirements are indicated by plant performance.
• Review and revise related procurement specifications to reflect the best available materials
and components for both general use and specific applications.
• Establish a process by which each work order is assessed before action to determine whether
it creates an opportunity to repair a related leak.
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• Establish a process to “clean and close” low-level (severity level 1) leaks rather than carrying
them on the backlog for a lengthy period of time. Leaving these leaks on the backlog and
monitoring them indefinitely may lead to an unnecessary drain on resources in the long run.
However, if the leak returns within a refueling cycle, it is obvious that some active leakage
must be present. The FLMPO should be aware if the leak returns, in which case it is no
longer considered a severity level 1 inactive leak and should be classified as a severity level 2
or higher leak and be dealt with according to station procedures. Leaks identified in
infrequently accessed areas need special consideration to ensure these leaks are monitored
such that nuclear, radiological, and industrial safety are prioritized.
In terms of performance goals for an existing program, the following are among the
opportunities to consider for directly reducing leakage events:
• Eliminate factors that have led to on-line leak repairs in the previous operating cycle in order
to reduce future events in the next cycle by some number.
• Reduce the number of leakage-related events leading to production penalties (for example,
forced outages, outage extensions, down-powering events) over the previous operating cycle.
• Reduce the total production penalty attributable to leakage-related events from that accrued
during the previous operating cycle.
• Establish a process to identify and schedule for repair leaks that have been on the books more
than a predefined period of time.
• Reducing the number of leaks by X for a given seal type (for example, gasket, packing).
• Reducing the number of leaks by X in a given classification of criticality or level of severity.
• Reducing the number of leaks by X for a given fluid type (for example, oil, water, steam).
• Reducing the number of rework events pertaining to fluid leakage.
• Reducing the number of leaks attributable to supplementary work force personnel.
• Reducing the aggregate cost impact of fluid leaks on the O&M budget by X.
• Replacing outmoded or ineffective FLM technologies (for example, gaskets, packing) with
improved materials. Stations should make an effort to investigate new sealing materials and
their applicability given the operating conditions and no longer accept the practice of only
using the same material that was removed or the material referenced in the Bill of Material.
• Introducing new tools or maintenance techniques intended to improve the performance of
fluid seals.
5.2.3 Stretch Goals for Mature Programs

For mature programs, goals should reflect a desire to focus on very specific FLM issues or
program improvement opportunities that would not have ordinarily been addressed by the goals
for the general program development.
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In terms of stretch goals for an established program, the following are among the opportunities to
consider for directly reducing chronic leakage events:
• Identify and resolve chronic leakage events that have occurred more than twice for the same
component or seal application.
• Develop and implement a solution for each chronic leaking component or seal application
(each instance represents a separate goal).
• Identify and deliver some defined technical support solutions that help others resolve or
prevent a leakage event at another plant site.
• Identify and resolve the top X FLM contributors (that is, specific components) to increased
plant O&M cost.
• Eliminating leakage events pertaining to one fluid, seal, or component type.
• Optimizing the FLM program in order to reduce the annual program cost by X.
On this last item, it is extremely important to remember that optimizing an FLM program for the
purpose of reducing the annual program cost only applies to mature programs that are well
established and have a demonstrated a history of success. The expectation is that every plant
program is initially implemented with a cost-effective plan already worked out. Only after an
already efficient program has been in operation for a period of time will those subtle
opportunities to further optimize the cost-effectiveness of the program becomes apparent.
Moving too soon with program optimization goals, from a cost reduction standpoint, runs the
real risk of ruining the program’s viability and the investment of resources to date. Hence, it is
recommended that plants proceed with program cost optimization only after the program has
been running smoothly for an extended period, and the program operation, function, and results
are well understood by plant management and the FLMPO.
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6
PLANT MANAGEMENT INVOLVEMENT
Plant management can initiate a plant FLM program, support an FLM program put forward by
plant engineering and maintenance staff, or work with that same staff to jointly create a program.
All three approaches can be successful. However, it is unlikely that a successful program can be
developed and implemented without management involvement and support. This section
discusses the scope, roles, and responsibilities pertaining to plant management’s involvement in
orchestrating an effective and successful plant FLM program.
6.1 Program Approach

There are several general management approaches to addressing leakage events in commercial
nuclear power plants: responsive, programmatic, and proactive.
6.1.1 Reactive
The most basic approach is simply responsive, in which leakage event prevention is given no
special emphasis compared with other plant maintenance objectives. In this approach, there is a
general recognition that if and when a leak is identified, it will be evaluated and a decision made
to repair it at the next appropriate opportunity. In the interim, the usual course of action is to
monitor for change, depending on its impact on personnel safety and its future severity and
criticality to plant operations.
The value of this approach is that it typically requires the lowest investment of up-front
organizational effort and O&M assets because few, if any, programmatic or preventive measures
are taken and leakage event identification typically occurs as a result of some other unrelated
plant activity.
One downside to this approach is that it signals that there is a low level of significance to general
leakage events, thus degrading any incentive on the part of plant technical staff to improve this
condition. This approach also restricts the solution of FLM issues to those resources that can be
dedicated after the fact. Because collateral impact (for example, reduced plant capacity and
availability, regulatory review) and consequential damage (increased equipment and component
repair or replacement) can occur as a result of a responsive-based approach to FLM, it is not the
most efficient or cost-effective approach to addressing plant leakage events.
6.1.2 Programmatic
A significant improvement on the responsive approach is the programmatic approach, in which
plant management makes a specific effort to ensure that the plant identifies the most up-to-date
technical guidance, uses the best tools and materials for a given application, and ensures that
technicians performing the work have the best training and skills necessary to successfully
complete a given task.
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Plant Management Involvement
The value of this approach is that it is comprehensive in its coordination and implementation of
the key technical areas that collectively contribute to an effective and successful FLM program:
procedural guidance, tools and materials, and personnel training. Using this approach, plant
management decides to put into place a program based on these solid program elements and then
ultimately relies on the program to deliver the best results possible based on this foundation. This
approach also fits neatly into the existing nuclear industry organizational paradigm.
One downside to the approach is that all the emphasis is placed on ensuring that the foundational
elements are in place and properly executed. This leads to a de facto acceptance in advance that
the plant is willing to deal with the consequences of any failures that occur as a result of gaps in
the program’s technical foundation or execution. While this approach should certainly minimize
the number and perhaps the severity of leakage events experienced by a plant compared with the
responsive approach, this approach does not tend to encourage actions that proactively seek to
identify and avoid specific sealing challenges that result from issues not addressed by the general
program guidance and execution.
6.1.3 Proactive
The ultimate goal of an FLM program would be to eventually elevate program performance
from simple programmatic execution to proactive involvement, in which not only is a solid
programmatic foundation implemented and executed, but plant personnel and resources are
dedicated to proactively identifying and analyzing potential FLM issues on an ongoing basis.
The intent of this approach is to develop and implement preventive solutions that eliminate
potential FLM issues before they become leakage events.
The value of this approach is that it does not condone the premise that it acceptable to accept the
potential for some future leakage events that will have to be dealt with on a case-by-case basis.
By striving to prevent all future leakage events through various proactive means, plant
management greatly reduces the probability of a significant leakage event occurring at their plant
in the future. It is expected that plants that rely on either the responsive or programmatic
approach will eventually experience a very costly leakage event that causes a forced outage,
significant outage extension, or other production penalty, which, in turn, frequently results in
some level of increased scrutiny by the industry regulator or other external industry body. The
plant response to this external scrutiny frequently adds additional cost, as well as an intangible
burden. The proactive approach holds the expectation of eventually eliminating leakage events as
a priority for a plant’s future.
A potential downside to this approach is the additional cost related to proactive identification and
elimination of leaks, which are not always easy to identify in a cost-benefit analysis. Recent and
current utility economic dogma tends to value most highly technical programs that produce
tangible cost savings over a relatively short and well-defined period. Programs that focus on
avoiding cost in the longer term are frequently not given equal consideration, unless the avoided
cost benefit is extremely well documented.
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6.2 Support Opportunities

A principal way that plant management needs to be involved in order to create a successful plant
FLM program is defined by the types of support that it provides to the program, not only initially,
but on an ongoing basis. This support can be divided into three main areas of involvement:
facilitating program organization, assisting with certain elements of implementation, and
providing accountability for the program owner(s).
Plant management has the opportunity to contribute to its FLM program organization success
early on, as it designates staff, helps formulate program goals and objectives, and allocates
funding to cover other program expenses.
6.2.1 Program Staffing

In terms of plant personnel resources, FLM programs are typically the responsibility of single
technical point of contact at each site, or the FLMPO. To paraphrase a quote attributed to
Admiral Hyman Rickover, the father of the U.S. Navy’s nuclear power program, “[i]f you cannot
point to the single person in charge, then no one is really in charge.” It is important that
management delegate this responsibility to a person generally meeting the qualifications set forth
for that position in the next section. Although a majority of plants appear to assign this
responsibility to someone in the plant maintenance organization, a significant number of plants,
for various reasons, have chosen to assign the responsibility within their engineering
organization. As discussed in Section 7, the qualities of the person responsible for the program
are more important than where the program resides in the organization.
In addition to the above-mentioned plant FLMPO, management should be prepared to allow
another plant person to allocate sufficient time as necessary to maintain a general level of
familiarity and awareness of the FLM program and its current status in order to act as a technical
backup in the event the FLMPO is absent or otherwise unavailable for some period.
Finally, with respect to staffing, a number of plants that have shown greater success in
implementing a plant FLM program have allowed the FLMPO to form a supporting technical
support group (TSG) comprising representatives from a number of related plant programs and
departments. The TSG then meets on a regular basis to provide feedback to the FLMPO on
planned program activities with respect to how those activities affect other plant activities and to
act as informal liaisons for the FLMPO with their respective plant organizations.
6.2.2 Goals and Objectives

Another opportunity for management to facilitate the organization of a plant FLM program rests
in its ability to help the FLMPO set practical and valuable goals and objectives for the program.
Whether the goals and objectives (1) are driven by management, (2) originate with the FLMPO,
or (3) are developed through a joint collaboration between plant management and the FLMPO is
unimportant. Experience has shown that all three approaches can be effective if certain general
guidelines are followed.
Goals and objectives are discussed further in Section 5.
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6.2.3 Implementation Assistance

Once the staffing, objectives, and goals are set, management can continue to contribute to
program success by providing implementation assistance to the FLMPO in several ways.
Principally, this includes providing the FLMPO with program development guidance from a
program advocate by communicating the importance of the FLM program and its scope, purpose,
and goals to the entire organization with both internal plant programs and external entities and in
providing a source of accountability to the FLMPO for program success.
With respect to providing program development guidance, it is important for plant management
to become and remain engaged. This is especially true during program implementation and
development, particularly early on, and as the FLMPO seeks to transition the program between
the implementation and development stages.
In addition to providing regular management oversight and funding, plant management can be
extremely useful to the FLMPO as a sounding board for implementation ideas and ideas that
pertain to making the transition to becoming an established plant program.
The goal of plant management in acting as a provider of development guidance should remain
engaged in the program process such that management is able to provide encouragement,
support, and unbiased technical wisdom to the FLMPO, as necessary.
Finally, plant management brings accountability to the FLMPO in the form of ongoing oversight
that maintains an awareness of the established goals, metrics, and performance against those
metrics. Regular discussion and enforced accountability provide an important framework within
which the FLM program must operate.
The single key point for plant management is that management needs to assign the responsibility
for developing and implementing a successful FLM program to the right person and then provide
that person with the guidance, resources, support, and accountability necessary for that person to
get the job done.
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7
PROGRAM RESPONSIBILITY
Experience has shown that those plants with the most effective FLM programs often share a
common characteristic; the person most responsible for the program is not merely the designated
program owner, but someone who is personally interested in and actively champions the
program, both internally at the plant site as well as externally within the industry. This section
summarizes information on assigning program responsibility at a plant, important attributes for
key personnel involved in the program, and presents estimates on required levels of effort based
on industry experience by a number of plant sites.
7.1 Accepting Ownership

When assigning responsibility for the plant FLM program, plant management’s first question is
frequently “should this program reside in the engineering or the maintenance organization?”
While many of the program responsibilities are oriented toward activities (for example,
procedure development, event tracking and trending, product and materials evaluation) normally
associated with the plant engineering organization, the plant maintenance organization is
primarily responsible for enacting the guidance that the FLM program represents and so also has
a legitimate claim to program ownership. Arguably, the maintenance organization may have a
greater incentive to effectively operate a plant FLM program because it has first-line
accountability for the actual results. In addition, plant maintenance has a more hands-on role in
the actual implementation of plant programs and thus may be better positioned to effect change
in implementing a plant FLM program. Ideally, as with many plant sites, there will be some type
of engineering function assigned within or joined to the plant maintenance organization.
Examples might include a component maintenance optimization group, a maintenance TSG, or a
maintenance engineering group.
The key point, regardless of where the program is situated in the organization, is who is
responsible for managing the program. It is the level of interest and initiative of the person who
accepts ownership of the program, not where the program resides in the organization that is the
single most predominant factor contributing to a successful program.
As mentioned in the section on management involvement, experience has shown that the most
effective FLM programs are not managed by a committee, but by a single determined individual.
That said, the individual program owner can enhance the effective implementation by developing
a program TSG to assist in defining and implementing the program at the plant site.
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Program Responsibility
The TSG will comprise representatives from other plant programs and organizations who have
important functional connections to the plant FLM program. These programs and organizations
might include the following:
• System or component engineering or maintenance (depending on the location of the program,
a representative from the other organization should be included)
• Training
• Work management
• Radiation protection
• Procurement engineering
• Design engineering
• Outage management
• Quality assurance
• Boric acid corrosion control (PWR only)
The objectives of the TSG are twofold: to provide feedback to the FLMPO on planned program
activities with respect to how those activities affect other plant activities and to act as informal
liaisons for the FLMPO with their respective plant organizations.
Given the frequency of other reporting recommendations made later in this document, it seems
reasonable that the FLMPO and TSG members should meet regularly. The purpose of each
meeting should include the following:
• Reviewing program progress toward established goals and identified challenges
• Discussing new challenges to goal achievement identified since the previous meeting and
collaboratively develop potential solutions
• Identifying opportunities for TSG members or others to contribute to or influence these
solutions
• Defining action items for the next intermeeting period necessary to support program goals
• Outage scope review including discussion of significant leaks being repaired in the upcoming
outage
While a formal monthly meeting of this group is suggested, the FLMPO will of course continue
to coordinate with individual members of the TSG and other plant personnel as required.
Depending on changing circumstances, the FLMPO may deem it prudent to ask the TSG to
meet more frequently during periods of high activity or when other important factors make it
appropriate.
It is important to reiterate that the purpose of the TSG is not to manage the plant FLM program
by committee, but to provide support to the designated FLMPO as well as provide liaison
opportunities to their respective plant programs and organizations.
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7.2 FLMPO Management Attributes

Among the attributes for management to consider, the ideal candidate will be a champion for
the responsibility, based on a natural interest in the technical area. As mentioned elsewhere, the
FLMPO is often the key to success in developing and implementing an effective plant FLM
program.
Ideally, the FLMPO should have the following characteristics:
• The authority, backing, and confidence of management. These three attributes are
important. Peers and other plant personnel must know and recognize that the FLMPO gets
his or her authority directly from plant management. Likewise, the FLMPO must be able to
count on management support to overcome inevitable hurdles as the program is being
developed and implemented. Finally, it is important that plant management have sufficient
confidence in the FLMPO’s judgment and capabilities that they are generally willing to
accept program development or implementation.
• The technical ability to establish and support the FLM program. This includes the ability
to determine the cause of problem leaks and factor experience back into the program to avoid
such leaks in the future. The FLMPO should be a technical position and should have the
technical knowledge to develop, implement, and fine tune the program. The FLMPO need
not necessarily be an engineer, although an engineering background can be helpful, but must
be knowledgeable regarding the technology and able to recognize when more specialized
assistance is needed.
• The recognition, respect, and acceptance by engineering and maintenance staff. The
FLMPO must have the recognition, respect, and acceptance of plant staff in order to be
effective. First and foremost, management must announce the appointment of the FLMPO,
such that the program owner is recognized among most plant technical staff. EPRI has visited
many sites where the occupant of the FLMPO position was not generally recognized. In
addition, there have been several cases in EPRI’s experience in which the person proposed
by management has had little practical knowledge of FLM issues or seal (for example,
gasket, packing) assembly techniques. It will be difficult for such an individual to gain the
respect of engineers and craft personnel sufficient to receive the level of acceptance
necessary to succeed.
• The ability to train others. Training is one of the three key building blocks of the proposed
program. The FLMPO must ensure that the training objectives, materials, and approach are
consistent with the procedures and materials developed. It is also desirable for the FLMPO to
participate in some of the training activities to obtain feedback from craft personnel
regarding special problems and potential program improvements.
• Persistence and determination. A tendency exists in human nature to accept the status quo.
An effective program owner must be out in the field working with the staff to ensure that the
procedures and materials are performing as intended and looking into the causes of the
remaining leaks from important joints. This important role cannot be accomplished sitting at
a desk. It is best if the person appointed to this role has a natural tendency to be persistent
and proactive. This will avoid the need for management to provide constant prodding.
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• Knowledge of the plant work force. The workforce has an ebb and flow of personnel and
experience. For example, there was a boon of personnel joining the work force in the 1970s
and 1980s. Those people accumulated vast experience, often learned through mistakes.
Current safety culture and economics are relatively intolerant of mistakes. Therefore, the
FLMPO must ensure that management is aware when experience levels are going to lessen
and propose actions to compensate for those issues such as proposing or conducting training.
7.3 Required Level of Effort

Level of effort is always an important consideration when planning to implement a new program.
The following estimates are based in part on the experience of some U.S. nuclear plants in
developing and implementing FLM programs at their sites at various times over the past fifteen
years.
However, experience has also shown that the level of effort assigned can vary considerably from
plant to plant. Staffing levels have been noted to range from an unallocated resource to as much
as five full-time equivalents (FTEs). Levels of effort are also subject to adjustment according to
the stage of development for the program, as well as to temporary adjustments dictated by
immediate circumstances.
The following sections attempt to provide some frame of reference for the three principal areas
of personnel effort: the FLMPO, the technical backup, and the TSG, as well as supporting
opportunities for external technical support.
7.3.1 FLM Program Owner

In the past, plants desiring to develop and implement an FLM program planned on a required
level of effort equivalent to at least one FTE for at least the first year. This level of effort was
dictated by the need to identify and define the process and program information and organization
from the ground up.
More recently, primarily as a result of technical efforts by EPRI to develop and deliver
standardized program development guidance such as this document, the required level of effort
necessary to start a new FLM program at a plant site is estimated to have been reduced to
approximately 0.5 FTE over the first year or, more accurately, over the first fuel cycle.
Thus, where a significant level of up-front effort was required simply to define and organize the
program, with that work done, the balance of the FLMPO’s effort in the first year or fuel cycle is
largely attributable to revising pertinent plant procedures, updating sealing materials used in
various applications, and supervising the dissemination of state-of-the-art FLM guidance to plant
technical staff. This latter dissemination activity includes arranging and supervising training
activities as required.
Once the program has matured, depending on plant-specific factors, not the least of which is the
level of the overall FLM challenge faced by the plant, the required level of effort may continue at
around 0.5 FTE or may drop to around 0.25 FTE over time.
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Regardless, it is important to note that the required level of effort necessary to have a successful
plant fluid sealing program is never zero. Experience has clearly shown that development and
implementation of a plant fluid sealing program can be assigned as just one more responsibility
for an individual is simply not realistic.
7.3.2 Technical Backup

The technical backup position is intended primarily to provide program continuity during those
times when the FLMPO is unavailable or in the event the FLMPO leaves the company or plant
site. As such, the required level of effort for training and to attend monthly TSG meetings with
the FLMPO and replace the FLMPO periodically during periods of travel, illness, vacation, and
so forth on the part of the FLMPO, probably does not amount to more than about 0.1 FTE. This
is based on 120 hours of vacation, twelve 1-hour TSG meetings, and 80 hours of travel-related
absence on the part of the FLMPO each year.
However, some plants may desire, or require, that the technical backup take a larger ongoing role
in supporting the FLMPO throughout the year, expanding the required level of effort
accordingly. As an example, the technical backup may provide some level of direct technical
support to the program. At some plants, the technical backup may actually be responsible for the
performance of specialty tasks of sealing activities such as freeze sealing (plugging) of piping or
on-line leak repairs. In these cases, their level of effort in supporting the program may actually
exceed that of the FLMPO.
7.3.3 Technical Support Group

The level of effort envisioned for the TSG includes participation in a monthly meeting with the
FLMPO and other TSG members. In general, it is probably also prudent to allow for at least
1 hour of preparatory time per meeting.
7.3.4 External Technical Support

It may be useful to also seek out external assistance in order to accelerate program
implementation and development and increase efficiency. This assistance is available from a
variety of sources, including vendors of sealing products and services, industry groups, and
independent subject matter experts.
Product and services vendors provide an excellent channel for technical information and
assistance. In addition to support for their particular products and services, most major vendors
also frequently provide some level of value-added services aimed at assisting customers with
analyzing emergent issues and recommending specific solutions. The FLMPO should establish
and maintain an ongoing relationship with the principal FLM product and service vendors used
by the plant.
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In addition, there are numerous industry technical groups organized to share information and
facilitate technical support through increased interaction of their members. With respect to FLM,
these groups might include the following:
• FLMUG
• Air-operated valve users group
• Motor-operated valve users group
• AP-928 (work management) working group
• Outage planners users group
• Work planners users group
Typically, these groups meet at least annually. Meetings generally focus on presentation of
relevant OE, new products, services, and techniques, as well as solutions to technical issues of
interest to the group. Meetings also provide an opportunity to network and share information.
It is highly recommended that the FLMPO identify and actively participate in those industry
technical groups that appear to offer the most value to the plant FLM program. At a minimum,
participation should include the following:
• Identification of available group information or other resources that can be used to improve
the plant FLM program
• Attendance at group meetings for the purpose of discussing major sealing challenges at the
plant, relevant OE, and identifying potential solutions
• Presenting information on specific solutions achieved by the plant FLM program that may be
of application to others
Finally, in addition to vendors and industry groups, the use of subject matter experts (SMEs) is
of significant value. The FLMPO can use SMEs in decision making to successfully jump start
the implementation of the plant FLM program, as well as to provide technical guidance to the
FLMPO, as required, in order to streamline the successful analysis and resolution of general
FLM challenges and specific issues. Unlike vendor experts and industry group participants,
SMEs typically bring a broad and unbiased technical perspective.
On this latter point, plant FLM programs can have setbacks when technical information (for
example, techniques, procedures) from one plant is simply copied and applied at another plant,
without a solid understanding of (1) to what degree that information was actually effective at the
originating plant and (2) on what basis it was effective. SMEs typically have sufficient breadth of
technical knowledge and experience in the field to be able to help the FLMPO efficiently and
effectively implement industry technical guidance without the extended, and sometimes costly,
learning curve associated with increasing the FLMPO’s own level of experience in the area.
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8
LEAKAGE ASSESSMENT PRACTICES
Of fundamental importance to the success of any plant fluid sealing program is the ability to
know the current condition of leakage events in the plant. In general, this knowledge is obtained
through plant walkdown inspections conducted by various persons, usually system engineers or
plant operators, during the course of their normal duties. However, an FLMPO can also take
additional steps to further define not only the current plant condition, but also the current trend
from past events to the potential future issues. This latter opportunity results from reviewing
historical work order data, as well as talking with maintenance craft persons, particularly Fix It
Now (FIN) maintenance team members, to take the pulse of what they see as current and
potentially emerging issues in the plant.
8.1 Walkdown Inspections

Walkdown inspections of plant systems are an effective, but time-consuming, means to identify
emerging, increasing, or unresolved FLM issues. However, if this practice is spread across a
number of different plant personnel groups, the performance burden can be significantly
decreased while significantly improving the identification of issues.
In general, there are six groups at each site that can easily contribute to the overall task of
assessing plant leakage on an ongoing basis. The groups include the following:
• Operations personnel
• Plant maintenance personnel
• Component or system engineers
• Radiation control
• Plant supervision or management personnel
• FLMPO
Operations personnel tasked with making routine daily rounds to assess various plant equipment
and plant maintenance personnel working in the plant on other issues can and should be tasked
with identifying, documenting, and reporting any observed FLM issues encountered during their
normal course of activities. It is also suggested that O&M personnel update any database that
may track or trend leak information. Both of these groups spend a considerable amount of their
time transiting through or working in the plant and should receive training or instruction on how
to effectively spot potential FLM issues, properly document the issue, and report the issue. Leak
monitoring can be easier if these FLM program support groups are actively engaged with the site
leak management database.
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Leakage Assessment Practices
Engineering personnel, whether system or component engineers, responsible for the function of
plant equipment, should routinely go into the plant to inspect those systems or components for
which they are responsible on a periodic basis. During these routine activities, the engineering
personnel should be encouraged to identify, quantify, and document leaks. They should also be
encouraged to update leakage attributes (for example, severity, leak rate, targets, photos) in the
FLM program database to ensure the most up-to-date information for each leak is reflected. In
many cases, the FLM program may use the walkdowns to document leaks of monitor only status.
All leaks should be walked down at least once a cycle unless special consideration is given, such
as inaccessible areas or areas with high radiation dose rates. Active leaks and/or boric acid leaks
should be monitored at an increased frequency based on consequence.
Radiation control personnel should inform the FLMPO of identified leaks resulting from
radiation protection surveys and the hanging of catchments.
Plant supervisory or management personnel who may be transiting through the plant should be
aware of opportunities to identify potential FLM issues as they emerge as well as to inspect the
leakage disposition tags attached to plant equipment with which they come in contact. In
particular, they should look intensely for disposition tags that appear exceedingly old or are past
their due date for resolution.
Finally, the FLMPO should make it a point to routinely be aware of identifying potential FLM
issues during transits of the plant, as well as make periodic walkdowns of components or
equipment known to be problematic from a sealing standpoint. Occasional walkdowns with
system engineers, operators, and maintenance personnel can be useful in promoting consistent
standards at the site.
8.2 Work Order Review

Another effective method to assess relative plant FLM performance is to conduct routine reviews
and analysis of work orders or work requests from the plant work management system.
First and foremost, work orders involving leaks should receive a code designation on entry into
the work management system that will automatically flag the attention of the plant FLMPO.
These codes should identify the fluid type and severity of leakage noted. This process may
require special training for work management personnel to ensure that proper coding is used. The
FLMPO should review each of these actions on a regular basis to determine whether the flag is
appropriate and sufficient detail is contained in the event description necessary to properly plan
the disposition of the item. The FLMPO should also be aware of emerging trends or root causes
that become apparent as a result of this review and address each of them accordingly.
In order to validate the effectiveness of the described flagging process, the FLMPO should also
periodically challenge the work management system by defining a query that generates a list of
all work orders and work requests pertaining to leaks. Some fine-tuning of the query will be
necessary to rule out facility leaks, integrated leak rate tests, and other undesirable hits. Once a
suitable query result is obtained, the FLMPO can then compare the rough results of the general
query with the reported work orders and work requests resulting from the flagging process. The
differential between the two, while perhaps not nil, should be small.
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To the extent that the differential between the flagged results and the challenge query are large,
the FLMPO should seek to determine what adjustments to the normal flagging process need to
be implemented in order to result in a more comprehensive identification of leakage-related
action items.
In particular, the FLMPO should also routinely review outstanding work orders and work
requests to ensure that they are being addressed in a timely fashion. General tracking should
include a means of limiting the ability of a leak-related action item to be deferred for
maintenance without the concurrence of the site FLMPO. Likewise, the process should enable
the FLMPO to keep track of any delays in planned maintenance so that the probability of
continued postponement of the maintenance action is unlikely.
8.3 In-Plant Personnel Interaction

A third effective method of assessing the leakage at a plant is to simply ask in-plant personnel
who are normally engaged in identifying or repairing leaks, such as FIN teams and others. While
these personnel may not be able to provide information on exact numbers of leaks, they will
probably be able to provide a relatively accurate picture of the extent of leakage events,
particularly with respect to specific process equipment.
Maintaining communication with these personnel is important, as some leaks that occur may be
identified and fixed immediately by the FIN team in the field, without ever being recorded in the
plant leak tracking system. The concern with this practice is that it can effectively conceal both
the number of leakage events actually occurring at a site and the type of leak and its severity. In
this latter case, as an example, retorquing of valve gland studs by the FIN team or other in-plant
personnel in order to eliminate emergent valve packing leaks can mask the fact that there may be
an underlying technical issue with the plant valve packing program, requiring a change in
procedures, materials, or personnel training.
An added benefit of including in-plant personnel interaction in formulating a leakage assessment
plan is that FIN team members can frequently shed light not only on what is leaking, but why.
Understanding the why can be particularly valuable in formulating successful resolutions to
repetitive leakage events.
8.4 Cause Evaluation

In general, an effective plant FLM program will be based on effective procedures, tools,
materials, and training. However, when a particular seal type or component continues to leak
repeatedly, a methodical approach should be followed to resolve the issue. EPRI has historically
recommended a graduated three-step process to resolve FLM issues based on increasing levels of
attention and resources.
At the first level, a leaking component is addressed by the maintenance group. Photographs taken
of the leak can be helpful in documenting the event. They carefully assess the leaking component
before and during disassembly and take special care to ensure that all applicable procedures are
followed in detail. They also ensure that the best tools and materials are used in reassembly and
that careful attention is paid to best assembly practices for the repair of the leaking component.
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If the component should leak a second time, the responsible system or component engineer
should be tasked with carefully reviewing the application, materials used, and assembly steps
from the initial and previous attempts to achieve a leak-tight condition. The engineer may also
solicit additional input from the component or sealing material vendor(s), as well as other in-
house resources, before formulating and overseeing another assembly attempt.
If after such careful attention to detail by in-house resources the component still fails to achieve a
leak-tight condition, use of an outside independent SME may prove beneficial to understanding
and resolving the particular issue. This might include a full root-cause analysis, materials testing,
or other steps necessary to arrive at a clear understanding of the underlying issue contributing to
the leakage event.
Regardless, at each level, increasing levels of detail need to be incorporated in documenting the
application parameters, the as-found condition, and the steps taken in attempting to mitigate the
condition.
8.5 Reporting
One of the keys to an effective FLM program is reporting; reporting the numbers of leaks, the
progress achieved, and continuing challenges. In order to support the reporting function, it
requires that the plant must begin by identifying current leaks, leading to some type of general
leakage identification activity. From this, maintenance planning and scheduling can take place,
and tracking and trending can occur over time, leading to documentation of relative program
success. The reporting of ongoing sealing challenges identified leads to increased attention to
resolve specific problems. In short, effective reporting helps drive the success of a plant FLM
program from start to finish.
The following subsections provide guidance on developing an effective plant FLM function.
8.5.1 Monitoring, Tracking, and Trending

In an effective plant FLM program, the plant should develop and maintain the capability to
identify and track leakage events in a manner that easily supports accurate analysis and
reporting.
To accomplish this monitoring, tracking, and trending function, the plant work management
system and corrective action process should be flexible enough to (1) incorporate the necessary
codes to identify and categorize leakage events and (2) be able to do so to with at least some
level of resolution. The objective is to enable the FLMPO to analyze and identify common root
causes and emerging trends.
As an example, the system should not only be able to identify work orders where system leakage
was a result, but should be able to provide some increased resolution such as monitoring
schedule, seal type (for example, gasket, packing), fluid (for example, oil, water, steam), failure
mode (for example, creep relaxation, aging degradation, corrosion) or special concern (for
example, boric acid in PWR plants). This ability to record some extended details concerning
leakage events is crucial in providing the capability to analyze historical events in order to
identify and understand emerging trends in program performance.
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If the plant work management system is incapable of providing the above level of detail, the
plant may wish to investigate adopting a separate commercial or custom software tool to provide
the above capabilities. For simplicity, the selected software tool should integrate directly with the
plant work management system in order to increase data quality and reduce the required
implementation effort.
8.5.2 Report Types

Reports can be subdivided into two types: informal and formal.
Informal reports are those reports developed by the FLMPO primarily for his or her own use for
the purpose of maintaining an ongoing understanding of program performance and identifying
emerging trends. Typically, informal reports will be developed on an as-needed basis and the
information contained will likely focus on a specific aspect of the overall plant FLM program.
As an example, due to one or more particular leakage events, the FLMPO might wish to develop
a report on the number of valve body-to-bonnet leaks for a specific valve type or application in
order to determine whether there might be any obvious common factors that could be causing the
events. Informal reports may not always present their data within a larger context and thus
should not be widely distributed unless that context is provided.
Formal reports are those reports developed by the FLMPO for the purpose of documenting
program performance or informing others of program results. Typically, formal reports will be
prepared on some type of regular basis, and the information contained will likely provide a
general overview of the entire program or one of its major components. As an example, the
FLMPO might be required to provide an ongoing report on active leaks by fluid type and level of
severity to plant management on a regular basis in order to facilitate their decision process in
allocating plant resources. Formal reports will always present their data within a larger context
so that the relative meaning or importance of the data presented is clear and unambiguous to its
intended audience.
8.5.3 Standardized Reporting

While the format of informal reports may vary widely according to the report objective, one
hallmark of an effective plant FLM program will be that formal reports will have a standardized
format and frequency of distribution assigned for each. While the guidance contained in this
document will not attempt to define all the various report formats that an individual plant FLM
program should require, it is suggested that at a minimum, a fundamental baseline report should
include the following data:
• Number of new leaks identified during the period (whether immediately repaired or not)
• Number of leaks repaired during the period (including those immediately repaired)
• Number of active leaks by fluid type and severity level
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It may also be useful to sort and analyze these data by fluid type (for example, air, water, steam),
seal type (for example, gasket, valve packing, mechanical seal), or level of severity (for example,
levels 1 through 5) and present the data in comparison with some number of preceding periods so
that an idea of recent trends can be established. It is suggested that, at a minimum, three
preceding periods be used in order to provide sufficient context for the current data presented.
Additional data points that might be useful to record and present in various formal reports
include the following:
• Labor hours/material cost of leakage-related work orders
• Lost generation (megawatts-electrical) attributable to forced outages, outage extensions, and
other production penalties attributable to leakage events
In terms of formal report frequency, it is suggested that plants consider the following scope and
frequency strategy:
• Weekly: Updated number of new leaks, repaired leaks, and current leaks and severity level
over preceding period.
• Monthly: Updated monthly reports with added criteria for fluid types, seal types, and levels
of severity.
• Quarterly: Updated quarterly reports with added criteria for labor hours, material costs, and
lost generation data, as well as a review of performance compared with program goals.
• Annually: Updated annual reports as well as proposed program goals and metrics for the
coming year.
8.5.3.1 FLMUG Standard Scoring Metric

The industry has struggled for years to determine a method of scoring plants fairly and
objectively. The following metric defines the method endorsed by this document and the
FLMUG for scoring a site in an objective manner. All sites are encouraged to incorporate this
metric score into their monthly reporting in order to provide a method of comparison with the
rest of the industry. This metric assumes all leaks (per the definition in this guide) are assigned
an EPRI classification for severity.
The formula for obtaining a site FLM metric score is as follows:
100-(U.M.)*{[0.05*# of Severity Level (SL)1 leaks] + [0.1*# of SL 2 leaks] +
[0.15*# of SL 3 leaks] + [0.2 *# of SL4 leaks] + [0.4* # of SL 5 leaks]}
The singular month’s score is then averaged with the score of the previous 5 months to obtain the
final metric score for the month. This ensures that a single poor month (that is, many leaks
identified during an outage) does not immediately place the site in the red status.
In the equation shown, U.M. is the unit multiplier. The unit multiplier equals 1 divided by the
number of operating units at a site. A single unit site will have a U.M. value of 1 (1/1), a dual
unit site will have a U.M. value of 0.5 (1/2), a triple unit site will have a U.M. value of 0.33
(1/3), and so on.
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This formula is the best method that the industry currently has to determine how plants compare
with each other objectively. However, it is relatively new, and stations are encouraged to refer to
the FLMUG website for the latest formula as it may change based on industry feedback.
This formula puts an emphasis on the severity of the leak, such that more severe leaks are
weighted more heavily than minor leaks and will decrease a site’s metric score more significantly.
Figure 8-1 shows an example of what a site’s industry metric score may look like.
Figure 8-1
Historical fluid leak program health report
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9
PROCEDURES, MATERIALS, AND TRAINING
In addition to a knowledgeable and dedicated FLMPO and management support, practical

procedures, proper tools and materials, and effective training are the cornerstones on which a
successful plant FLM program is built. The following subsections provide guidance related to
implementing these factors in an effective fashion.
9.1 Practical Procedures

First and foremost, it is important to ensure that plant procedures related to FLM—and perhaps
most plant procedures—are clear, concise, and practical in their organization and content. In some
cases, there is either too little guidance or too much, or there may be the right amount that does not
represent the most up-to-date guidance available.
A common means of developing or improving a particular procedure is to benchmark other plants
that appear to perform well in that procedural area, the theory being that their success is related to
the quality of their procedure. While this may be true, it may also be equally true that their success
in any given technical area may be due to other factors, independent of the procedure.
The principal challenge of developing an effective FLM procedure is to ensure that the key factors
that contribute to success in the topical area of the procedure are clearly identified and accurately
addressed, such that the procedure minimizes any room for interpretation in terms of how these
factors are to be addressed when the procedure is executed.
This is accomplished most easily by studying the predominant failure modes associated with a
particular seal type or application and identifying those factors that most directly lead to that
failure mode occurring. Once these key factors are identified, it is possible to determine what
actions can be taken, procedurally, to eliminate or mitigate those factors during the maintenance
process. It is these steps that must be included in the procedure if the procedure is to provide an
opportunity to succeed.
In addition to identifying these steps, it is equally important to describe them clearly and
unambiguously within the procedure. Important steps that are mentioned, but whose
implementation is left open to interpretation, will not ensure a successful, repeatable outcome.
Important steps in procedures should include a signature or initials block to document completion
(in addition to circle/slash if that is the method of place keeping being used). The idea here is that
all procedure steps with a required signatures are more likely to be followed verbatim and
oftentimes are reviewed for completeness before closing the work package. It is also important
to understand the procedure level of use and how it affects the quality of work. For example, if a
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Procedures, Materials, and Training
station is having issues with valve packing leaks, they may want to consider upgrading their
packing procedure from reference use to information use or continuous use to ensure that steps
are followed verbatim. Upgrading the level of use temporarily might also be helpful when the
procedure undergoes a large revision.
Finally, any procedural content that does not directly contribute to a clear understanding, and
accurate execution of steps necessary to accomplish the task and elimination or mitigation of key
failure mode factors is of questionable value. Procedures that contain too much supporting
information can frequently obscure the important content or diminish the technicians’ desire or
ability to faithfully follow the procedure as written, leading to procedural adherence issues.
Supporting information that has value, but does not directly pertain to the steps necessary to
successfully accomplish the task outlined in the procedure, may be better suited to inclusion in an
appendix or a separate procedure altogether. The procedure is a tool used by the craft to execute
work. Any additional or supporting information included in the procedure that is used during the
planning of the work but does not directly benefit the craft during the execution of the work should
be removed. An example might be the inclusion of packing material and configuration criteria
included in a valve packing procedure. This kind of information is not relevant to the valve
packing procedure as the material and configuration should already be planned before to execution
of the work.
9.1.1 FLM Program Procedure

With the above in mind, a successful plant FLM will have an overarching, higher level procedure
that describes how the program is to function and the relationships between pertinent plant
programs and specific subordinate technical procedures and processes. This general program
procedure will accomplish the following minimum objectives:
• Define the scope and objective(s) for the program.
• Identify how the program will be managed.
• Define the ways that plant management will support the program.
• Identify and define the relationship(s) between the program and other plant programs, as
appropriate.
• Define the type of metrics and the periodicity by which the program progress will be measured.
• Identify how changes to the program will be implemented.
In terms of program scope and objectives, it is the decision of most program owners to focus the
prevention efforts in this program on external pressure boundary leaks resulting from some type
of temporary seal failure. (While temporary seals may have an indefinite life span, they are not
permanent in the same sense as a weld, for example, since disassembly is easily accomplished
without damage to the sealed components.) Examples of major seal types are gasketed joints,
valve stem and rotating shaft packing, static seals (for example, O-rings) and mechanical seals,
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threaded piping connections, and compression fittings. With all that being said, leaks from base
metal or welds, solder joints and brazed joints should still be counted in the leak program.
Figure 9-1 shows this relationship, but they should be addressed and can be tracked in other
program responsibilities.
Plant Leaks
MIC
FAC/EC
Fluid Joints- Boric

Acid
Fluid Joints
Figure 9-1
Scope of leakage program: example
The principal objective for a plant FLM program should be to improve the capability of an
operating plant to successfully seal all pressure-boundary components at the onset. One by-product
of an effective program is that the number and severity of leakage events should subsequently be
reduced.
With respect to program management, the procedure should indicate whether an FLMPO will be
responsible for day-to-day program development and implementation and, if not, how the program
will be managed. The procedure should also indicate whether there will be a technical backup for
the FLMPO, as well as whether a TSG will be organized to provide technical support and liaison
responsibilities with other programs. If a TSG is to be implemented, the core departments, plant
organizations, or programs represented should be identified as well.
With respect to the programs’ relationship with other plant programs, the procedure should
identify those principal programs that have a direct relationship with the FLM program, suggest
how those programs will interface with one another, and identify any important boundaries
between the FLM program and other plant programs.
The procedure should define the metrics that will be used to evaluate the program. Metrics might
include the numbers of leaks, direct cost reduction, reduced production penalties, and so forth. The
procedure will lay out the frequency with which these metrics will be assessed and the manner in
which the assessment will be accomplished.
Finally, the procedure will define how program feedback will be incorporated into procedural
changes and program improvements.
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9.1.2 Supporting Procedures

In addition to the overarching FLM program procedure, an effective program will also incorporate
a number of specific application procedures. At a minimum, these core procedures will be similar
to the following:
• Tightening and torquing
• Assembling pressure-boundary gasketed joints
• Valve packing
• Pump packing
• Mechanical seals
• Compression fittings
• Threaded piping connections
• Procedures that are used to perform maintenance or diagnostic testing of commonly used fluid
leak materials (for example, packing, gaskets, O-rings) on components
– Air-operated valve diagnostic procedures
– Motor-operated valve diagnostic procedures
The tightening and torquing procedure will contain the fundamental guidance on tightening
pressure-boundary fasteners. The procedure will identify different assembly methods (for example,
tightening, torquing) and when one method will be used instead of another. In each case, the
procedure will focus on achieving the target fastener preload with good uniformity
of preload between all fasteners.
The gasketed joint procedure will contain guidance on the assembly of various gasketed joints. In
practice, plants may find it desirable to divide this guidance into multiple procedures, according to
specific joint type (for example, pressure seal bonnets, cover plates) and by general seal type (for
example, semimetallic gaskets, sheet gaskets). In the case of gasketed joints, the procedures will
focus on achieving and maintaining the target gasket seating stress in-service.
The valve packing procedure will contain guidance on proper techniques for packing or repacking
a valve stem stuffing box. Important considerations for valve packing selection that can influence
valve packing technique are valve configuration, operator type, general application, and frequency
of use. In the case of valve packing, the procedure will focus on achieving optimum packing
consolidation at the target packing stress.
The mechanical seal installation procedure should contain guidance on proper techniques for
component inspection and preparation before seal installation and general guidance on good
practices for seal installation.
The compression fitting procedure should contain guidance on proper tube cutting techniques and
preparation of tubing ends to receive the fitting, fitting engagement, initial tightening requirements
necessary to set the fitting, and repetitive tightening guidance to prevent eventual fitting failure due
to work hardening of the sealing surface or overtightening. The potential for mismatching of parts
from various fitting manufacturers should also be addressed.
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The threaded piping connection procedure should contain guidance on sealant selection, proper
thread cleaning and preparation requirements for the sealant type to be used, proper thread sealant
application, requirements for sealant cure times, and pipe assembly considerations related to
facilitating a seal on assembly.
For each procedure, sufficient technical guidance will be provided to enable craft persons to
successfully perform the task, ostensibly resulting in a leak-free assembly. Alternate assembly
methods may also be included, accompanied by guidance that clarifies when or under what
circumstances they will be used. Key factors contributing to success will be identified and at a
minimum will include proper tools and assembly techniques, adequate fastener lubrication, and use
of hardened steel washers under the turned element as appropriate.
In addition to these core supporting procedures, a plant may also find specific procedures addressing
other seal types (for example, compression fittings, threaded piping connections, mechanical seals)
to be of value in continuing to improve their overall plant FLM program performance.
Finally, it is crucial to include specific procedural guidance that is often considered the skill of
the craft, where that guidance represents a key success factor that must be performed in a specific
fashion.
Frequently such guidance is not defined in detail within procedures because the assumption is that
everyone knows that’s important. An example would be the topic of fastener lubrication, where
procedures involving the preload of pressure-boundary fasteners invariably mention that a
specified lubricant should be applied to the fastener at some point in the procedure. Experience has
shown that many, if not most, procedures are not sufficiently specific in terms of locations where
lubricant should be applied, or to what extent, even though extensive research has shown that
lubricant application technique, the quantity applied, and multiple locations (fastener threads and
turned element bearing surface) can have a significant influence on the degree of resultant fastener
preload for a given applied torque. Accordingly, it can be extremely important to not overlook the
provision of detailed guidance for obvious subtasks in which the risk of not doing so might lead to
a significantly different outcome.
9.2 Tools and Materials

An effective plant FLM program will incorporate the use of the proper tools and the best materials
for each specific application. The best performing plants establish a close relationship with
procurement engineering to help facilitate incorporation of industry best products for a given
application and eliminate the use of products that have a proven poor performance.
9.2.1 Tool Selection

With respect to tool selection, to include assembly techniques, a fundamental concept in achieving
leak-free sealing is assembling the seal sufficiently tight to effect a seal while not causing damage
to either the sealed components or the seal itself and in such a manner that the achieved tightness is
not significantly diminished in-service. Given that seals that are not sufficiently tight will not seal
or will not maintain a seal in-service and seals that are overly tightened can damage the seal or
related sealed components, it frequently becomes necessary to differentiate between the need to
tighten, torque, or load a sealing component.
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In general, a common maxim states that “if a subsequent leak would be relatively inconsequential,
then tightening the seal is sufficient.” For the purposes of this guidance, tightening is defined as
mechanically preloading a threaded fastener or other component using simple tools (for example,
a standard wrench, screwdriver) and relying on the mechanic’s judgment to achieve the necessary
degree of tightness. Therefore, where a subsequent leakage event is of some consequence, an
alternative method of preloading the fastener or component should be used.
In cases in which elevated target preloads are required or other assembly conditions prevail, a
hydraulic torque wrench may prove more useful and accurate than a manual torque wrench.
In other cases, accurate fastener preload using some form of torque technique may be undesirable
due to increased accuracy requirements, fastener or component size, configuration, or required
preload. In such cases, some form of direct fastener loading, such as with ultrasonically measured
bolt stretch equipment or stud heaters may be required, as is often the case in the assembly of
turbine casing bolting.
In nonfastener-related assemblies, such as compression fittings, the use of some form of
mechanical indicator to determine the correct degree of assembly may be required.
In any event, the most effective plant FLM programs will determine the need for specific types
of assembly tools necessary to achieve the best results on an application-specific basis.
9.2.2 Material Selection

With respect to material selection, an effective plant FLM program will similarly identify the best
materials for a given application and specify their use in those applications instead of continuing a
one size fits all approach. For example, in the area of gasketed joints, there is a tendency among
many operating plants to attempt to standardize a very few gasket styles. While this objective
yields obvious tangible benefits in procurement engineering, inventory and quality control,
personnel training, and engineering, experience and performance testing have shown that there is a
significant subset of applications where specific gasket styles or materials are better suited to a
particular application than the gasket style or material that would otherwise be generally used in
most applications.
Factors that can affect material selection might include the following:
• Sealing surface condition
• Joint design
• Pressure or temperature ranges
• System or component thermal-cycling potential
• Process fluid type
• System or component chemistry and/or radiation considerations
• Aging considerations
• Static vs. dynamic sealing conditions
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Where a previous leakage event has occurred, an effective FLM program will have evaluated the
event within the context of the preceding criteria to determine whether a more suitable material
selection was possible in order to mitigate the potential occurrence of a future similar event.
EPRI and others have performed extensive research on a variety of gasket styles and material
types, valve packing materials, sealants for threaded piping connections, and other related sealing
components (Figure 1-1). An effective FLM program will have consulted these sources, in addition
to seeking out vendor recommendations, in order to determine the best sealing material for a given
application to avoid repetitive failures. Personnel responsible for making the decision for
determining the material used to resolve leakage issues need to be informed of the latest
technologies available to them. Industry experience should be used to identify industry success
in sealing similar leaks.
9.3 Training Scope and Frequency

The third leg supporting an effective plant FLM program is personnel training. Technical training
modules presented must represent the most up-to-date information and guidance and be focused
toward the appropriate groups at the appropriate time. In general, there are four specific training
areas that program training should cover. These include general training for designated plant
personnel, specific skills training, refresher training, and training for supplemental work force
personnel.
The primary objective for each should be to provide the knowledge and hands-on skills necessary
to ensure that plant equipment relying on seals is assembled in a safe and efficient manner such
that there is the highest probability that the resulting seal will not leak on system startup or in-
service and that no collateral damage occurs to that or other equipment in the process.
Experience has shown that technical training for FLM-related topics must not only present the how
in accomplishing related maintenance tasks, but equally important is helping students gain an
understanding of the why as well. It has been conclusively shown during more than 60 EPRI plant
leakage reduction workshops conducted over the years that students who understand why a
particular task is to be performed in a certain way are more likely to incorporate that instruction
into their own work practices than students who are only given the how part of the presentation.
Unless student incorporate instruction to subsequently improve their individual work practice, the
value of the training instruction is negligible.
EPRI workshops have shown that classroom presentations of technical material are most widely
received when they include a combination of presentation techniques, such as lecture/discussion
and multimedia, and do not simply rely on the presentation of a canned viewgraph presentation. It
is crucial to engage the students in a process that enables the students to discuss, discover, and
articulate answers to technical questions themselves rather than simply being fed the material
through a presentation.
EPRI workshops have also conclusively demonstrated the value of hands-on skills training in
communicating technical guidance and making an impact on attendees. Where possible, FLM
training should always include some combination of classroom activities and hands-on
demonstrations by the instructor and students.
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Whenever possible, the FLMPO should be present and assist the training instructor in conducting
FLM-related courses.
9.3.1 General Training

The most basic level of instruction for FLM information is what otherwise might be termed
orientation to the subject area. It will typically be classroom-only instruction, without a need for
any specific hands-on skills training. At a minimum, this general training should address the
following topics:
• Overview of the plant FLM program, including organization, scope, personnel, goals, and
objectives
• Benefits to minimizing or eliminating leaks at the plant
• Process for identifying leaks by type and severity level and initiating leak-related work orders
• Standard references and nomenclature pertaining to leaks
General training should be mandatory for designated personnel who may be involved in the
identification, assessment, evaluation, repair, or other maintenance of leakage-related events at the
plant. Due to its general introductory nature, without specific technical task instruction, it may not
need to be repeated on a periodic basis.
9.3.2 Specific Skills Training

The next level of training should be specific skills training, addressing topics that might include
gasketed joint assembly, proper torque wrench use, visual inspection, valve packing, and so forth.
Specific skills training should be geared toward providing attendees not only with instruction on
task performance, but also toward key factors affecting performance and the related assessment
and troubleshooting skills necessary to identify when those factors arise.
In addition to classroom lecture and discussion, specific skills training should always include
hands-on time for attendees to test and demonstrate their understanding of the subject matter using
actual equipment and components or an appropriate training mockup simulating same.
Other related specific skills training might include the following:
• Assembly of compression fittings
• Cutting, threading, and assembly of threaded piping
• Rigging and lifting
• Confined space activities
• Foreign material exclusion
• Boric acid corrosion identification (PWR only)
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Due to the hands-on nature of the skills training, it may be advisable for attendees to repeat this
training on some periodic basis in order to ensure that they receive the most up-to-date technical
guidance available and to demonstrate and confirm their continued competency to successfully
perform the task(s).
9.3.3 Refresher Training

In addition to periodic specific skills training, the effective plant FLM program may find it
advisable to plan and conduct targeted refresher training for a specific skill or skills in advance
of performing maintenance on a critical piece of equipment or under critical circumstances.
Scheduling of such targeted refresher training is left to the discretion of the FLMPO, plant
supervision, and management. However, refresher training may be indicated under the following
circumstances, where:
• A review of previous maintenance performance in a similar situation suggests that some
remedial maintenance training may be in order
• Industry OE suggests that other plants have experienced a problem in successfully
accomplishing the specific maintenance task
• Any other factor arises, such as the introduction of new plant personnel, that brings into
question the probability of maintenance craft to successfully accomplish the task
9.3.4 Supplemental Work Force Training

Past industry data suggest that more than 50% of maintenance-induced errors occurring during
plant maintenance activities are the result of temporary supplemental work force personnel
employed during outages and other temporary maintenance events. The final component to
effective FLM program training is incorporating a process to, at a minimum, confirm the task
competency of temporary supplemental work force personnel.
The key to supplemental work force training is to first determine whether the focus is to achieve
the following:
• Provide the same level of training and instruction as that provided to regular plant personnel,
to include both general training and specific skills training as appropriate
• Confirm the level of technical competency of the temporary craft to successfully accomplish
the assigned FLM tasks
• A combination of both approaches
Regardless of the approach chosen, some level of supplemental work force training should be
conducted that results in the following:
• Accurately and effectively communicating the performance goals and plant expectations
of quality
• Identifying key work practices contained in relevant procedures that have been shown to be
important to repetitive task success
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• Identifying work practices and expectations for a specific skill that may be common at other
sites or in other industries but are not allowed at the site (for example, applying some type of
gasket dressing to the gasket surface in order to improve ease of installation under certain
circumstances)
• Identifying contact information and procedures for the FLMPO in the event that his or her
input is required during task planning or performance
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10
TECHNICAL PROGRAM RELATIONSHIPS
As with many plant programs, an effective plant FLM program will not exist in a vacuum, but
will need to interface with other plant programs. One measure of the FLM program’s effectiveness
is how well this interface is defined. The following subsections summarize aspects of how an
effective plant FLM program will interface with a number of program types common across the
industry. The goal of these program relationships should be to prevent and repair leaks.
10.1 Boric Acid Corrosion Control (PWR Only)

Borated water is used in PWR power plants to help control reactivity. Boric acid is added to
selected systems to achieve desired concentration levels necessary to achieve that goal. However,
industry experience has shown that significant corrosion problems can develop due to leakage of
borated water from gaskets, seals, valve packing, and other potential leakage locations where
free oxygen is available to facilitate the corrosion process.
A boric acid corrosion control program (BACCP) is intended to prevent corrosion of the plant
systems, structures, or components due to leakage of borated water as necessary to comply with
commitments to U.S. Nuclear Regulatory Commission Generic Letter 88-05, Boric Acid
Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants. PWR plants
designed by Westinghouse Commercial Atomic Power may also refer to guidance provided by
that company contained in WCAP-15988-NP, Generic Guidance for an Effective Boric Acid
Inspection Program for Pressurized Water Reactors.
All systems containing borated water and the structures and equipment surrounding these
systems that are susceptible to corrosion by boric acid are generally in the scope of a BACCP.
Other equipment, which may be affected, includes mechanical systems, structural supports, and
electrical equipment located in close proximity to borated systems. Bolted closures such as
manways and flanged connections in systems containing dissolved boric acid should also be
addressed when leakage is evident. The activities to identify the source of boric acid leakage
and to inspect subsequent corrosion degradation of associated piping, structures and components
should also be detailed in a BACCP. Included in those activities are inspections, walkdowns,
and procedures to identify, correct, or prevent borated water leakage onto plant equipment or
the reactor coolant pressure boundary.
Due to the technical specificity and regulatory components inherent in BACCPs, they are
frequently managed separately from the plant FLM program. Nonetheless, the BACCP can be
managed by the FLMPO if this approach makes sense for the individual plant and personnel
involved.
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Technical Program Relationships
Where each program is managed separately, the BACCP should be a subset of the larger FLM
program, particularly with respect to the manner and methods by which leakage is identified,
tracked, and trended. The FLMPO and the BACCP owner, if not one and the same, should
communicate closely to ensure that all boric acid leaks are accounted for in the FLM program
and not in addition to the program.
10.2 Catch Containment Programs

A catch containment program manages active leaks for housekeeping purposes. The FLMPO
should be responsible for maintaining this aspect of the FLM program. Support from plant
operations, radiation protection, or other plant organizations may be necessary to install and
maintain these containments. All catch containments should be labeled as such using either
specific FLM program tags or generic plant deficiency tags. Catch containments should be
individually tracked in the database used by the plant for the purpose of tracking leakage events.
10.3 On-Line Leak Repairs

Temporary repairs to resolve leakage events, such as on-line leak injections, should be managed
within the overall FLM program and should include a formal process to ensure that appropriate
engineering evaluations are performed and approvals obtained before performing these types of
repairs. The site’s work management process should be used to track such temporary repairs,
including leak injections, to ensure that permanent repairs are performed at the next available
opportunity. In general, the leak injection process should be an avenue of last resort, to be used
only after all other options have been exhausted. An On-line Leak Sealing Decision Screening
Form developed by Duke Energy is included in the Appendix and may be used to aid in this
decision process. The FLMPO may serve as the job sponsor for the implementation of on-line
leak repair and leak sealant injection activities.
10.4 System Health Monitoring Programs

As with BACCP, most plants monitor system health. Leaks should be considered as one of the
attributes of system condition within the scope of the plant FLM program. The FLMPO and the
system engineer should work together to identify and track leakage events affecting those
systems. However, the FLMPO should be primarily responsible for mitigating leakage from
those systems, with support from the system engineer as required (Plant Engineering: Generic
Handbook for New System Engineers. EPRI, Palo Alto, CA: 2011. 1022526).
10.5 Service Water System Program

Some plants have developed Service Water Piping Corrosion Programs to help manage the
increasing occurrence of microbiologically induced corrosion in their service water systems and,
in fact, may have license renewal commitments to track these types of leaks. While service water
system corrosion programs may be managed separately from the FLM program, the FLMPO and
the service water system engineer should work together to identify and track leakage events
affecting the system. However, the FLMPO should be primarily responsible for mitigating
leakage events, with support from the service water system engineer as required.
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10.6 Foreign Material Exclusion

While foreign material exclusion may at first seem somewhat unrelated to a plant FLM program,
there is unfortunately a direct relationship. In one example, spiral-wound gaskets, both with and
without an inner ring, have been known to buckle radially inward on compression, sometimes
resulting in the introduction of the gasket’s filler and metal winding materials into the process
system. Contrary to popular belief, RIB is not caused by overtightening gaskets because EPRI
research has demonstrated that this phenomenon can occur at bolt preloads as low as 124,106 Pa.
Where introduction of foreign material occurs, RIB events can be particularly detrimental to
downstream filters, valve seats, and strainers, as well as the potential to cause fretting of steam
generator and heat exchanger tubing. In another example, excess or improperly applied thread
sealants (for example, pastes, tapes) used to seal threaded pipe joints can also be introduced into
systems with the potential to foul downstream control valves and components. The FLM program
should provide a mechanism for the FLMPO to exchange information with the foreign material
exclusion program owner for the purposes of identifying instances of foreign material intrusion
or induced damage, such that the FLMPO can take steps to prevent similar future occurrences.
10.7 Procurement Engineering

An important, but frequently overlooked, element of an effective and successful plant FLM
program is its ability to provide the plant procurement engineering organization with sufficient
information and data to support the justification for purchasing new or different sealing products.
Frequently such products may be more expensive than the products that the plant is currently
purchasing for use on a unit cost basis. It is important for the FLMPO to be able to make an
effective cost-justification argument to show when the cost of ownership, or rather the total
accrued cost of using a particular product, is less than simply comparing cost savings based on
purchase pricing. In one example, a product may perform substantially better than other similar
products of the same type (for example, gaskets, packing materials, thread sealants), with a
corresponding quantifiable cost savings resulting from this increase in reliability. In another
example, a product may be significantly easier or faster to install, with associated cost savings
that are easily quantified when this reduction in required maintenance resources is factored into
the cost of ownership. In most cases, the product cost difference is inconsequential compared
with the overall costs associated with repairing a leak.
10.8 Outage Planning

Some repairs can only be accomplished when the plant is off-line. Accordingly, the FLMPO
should maintain a list of those leaking components that are most easily, or only, addressed off-
line and work with the plant outage planning organization to ensure that those work orders are
reviewed and included in the outage plan as appropriate. Within this context, the FLMPO has
two additional objectives: first, to ensure that those tasks that are in the planned outage scope are
not deferred and, second, for those tasks that do not make it in to the planned outage scope, the
FLMPO should work to ensure that they receive increased priority at the next available
opportunity so that their resolution is achieved.
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10.9 Work Management

A common FLM issue at many operating plants is repeated deferment of plans to resolve minor
housekeeping leaks. In the old paradigm of managing leakage events, many plants allowed a
number of minor leaks to continue indefinitely as long as no increase in severity, equipment
damage, or other consequence to operations was noted. However, the expectation was that these
small nuisance leaks would eventually be addressed over time. Since this expectation has proved
not to be the case in many instances, the industry is changing to require a more aggressive
position to resolve even minor leaks in a timely fashion. In order to accomplish this goal, the
FLMPO will need to work closely with the plant work management organization to accomplish
two objectives. First, the plant FLM program must provide both the FLMPO and the work
management organization with a periodic report on unresolved leakage events by date, so that it
is possible to easily identify leaks that have been ongoing for some time. The FLMPO must then
work to ensure that these older leaks are addressed. Second, the plant FLM program must ensure
that once corrective actions pertaining to leakage events are planned, those actions cannot be
deferred without the notification and concurrence of the FLMPO. This visibility will reduce the
tendency of other plant organizations with different priorities to sacrifice planned maintenance
actions to correct leaks in favor of other tasks.
10.10 Buried Piping

Emphasis on buried piping has been increased as plants age and are implementing life extension.
Knowledge of specific issues with buried piping should be considered and an interface established
(User’s Guide for the Repair of Buried Piping: Recommended Approach for the Selection and
Application of Repair Methods to Restore Degraded Buried Piping. EPRI, Palo Alto, CA: 2013.
3002000738).
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11
PROGRAM IMPROVEMENT
One of the hallmarks of a successful and effective plant FLM program is the degree to which it
engages in self-examination and self-improvement initiatives on an ongoing basis. With respect
to self-examination, these initiatives can take many forms, from focused self-assessments and
peer reviews to full-scale program reviews. Self-improvement initiatives can include review and
incorporation of industry OE, benchmarking of other plant sites, and participation in industry
technical meetings and conferences. The following subsections discuss these program
improvement opportunities and provide guidance related to implementing them within the
context of improving a plant FLM program.
11.1 Self-Assessments
A core aspect of any successful technical program is self-assessment, followed by corrective
action. With respect to self-assessment, there are at least two proactive means to evaluate the
efficacy of your plant FLM program.
First, the industry FLMUG has put together a relatively comprehensive approach to better
understand the relative effectiveness of a plant FLM program. This FLMUG Metric Systematic
Assessment Guide with Scorecard currently represents the industry standard approach to FLM
program assessment and is reproduced in its current version in Appendix 12.1 of this document.
Updates and additional instruction in its application can be obtained by contacting the FLMUG
online. This self-assessment tool follows the guidance contained in this document. Adherence to
this guidance in all aspects should produce a very successful self-assessment result.
A second method for assessing the effectiveness of the plant FLM program is to use one of the
commercial vendors that specialize in performing plant FLM program assessments. The chief
benefit of these independent assessments is that they generally use a different approach and
provide a different end product from the FLMUG assessment tool. Accordingly, their end
products are useful in both validating the results of the FLMUG assessment tool, as well as
providing a different perspective on various aspects of the plant FLM program achievements
and opportunities for improvement.
A third, reactive, method is to rely on formal industry organizations such as INPO or World
Association of Nuclear Operators to assess your plant FLM program, with the FLMPO analyzing
the resulting exit commentaries and summary report that follow. For obvious reasons, this
approach is not recommended as it is frequently the most costly approach in the long run due to
the need to respond to any deficiencies found in an artificial time frame.
Regardless of the method selected, a program self-assessment is recommended approximately
every two to three years. This provides sufficient time after the preceding assessment to
implement changes with some reasonable expectation of witnessing the beginnings of results.
In addition, it also ensures that at least one refueling outage will occur during the period between
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Program Improvement
assessments. This is necessary in order to implement repairs and changes that can only be
accomplished when the plant is off-line. Self-assessments should be planned and coordinated by
the FLMPO and, regardless of which of the proactive methods are chosen, should include
discussions with both plant management and supervision, as well as representatives from other
plant programs interfacing with the plant FLM program. Where an outside SME is used,
additional personnel may be involved depending on the vendor-specific approach used.
Each self-assessment should conform to the individual utilities self-assessment procedure and
result in a formal written report that summarizes the process and results, program strengths, and
provides detailed information and data on each aspect of the program assessment. This report
should result in a clear presentation of the current plant FLM program status, identify
opportunities for improvement, and include specific recommendations for achievement of those
opportunities. The report should also identify key contributors to the current level of program
success, where noted.
11.2 Peer Reviews

Peer reviews serve an important function in improving plant FLM programs by creating
opportunities to incorporate new ideas from external sources to improve existing programs.
It is recommended that the FLMPO invite one or more peers approximately once every two years
from other plants, preferably from outside the host plant’s utility, to visit the site. The purpose of
inbound peer review should be to perform a plant walkdown inspection and discuss each plant’s
FLM program. The walkdown inspection should focus on the number and location of leakage
events, as well as affected system or component applications. Use of specific sealing products or
materials in sealing applications (for example, where are hardened steel washers used? Belleville
springs?) Other specialty items should also be noted. Particular sealing challenges should also be
discussed.
Experienced industry peers will bring valuable perspectives from their site operation that the host
FLMPO will find useful in addressing challenges faced at the host site. Even inexperienced peers
or those peers representing plants with relatively new FLM programs will provide benefit to the
host site through the questions that they ask that require the host FLMPO to think through and
explain the rationale for the manner in which aspects of the host site FLM program are
organized.
Of equal importance to inbound peer reviews, when industry personnel come to visit a host site,
are outbound peer reviews where a FLMPO will travel to another plant site for the purpose of
participating in another plant’s FLM program peer review. Participation in another site’s FLM
program review provides FLMPO personnel from other sites with the opportunity to validate
their own program’s performance compared with programs at other sites, but also to learn first-
hand how other sites are dealing with technical challenges of interest at each outbound plant site.
A general peer review should be able to be accomplished in one to two days, while a more
detailed assessment might take several days to complete. Table 11-1 shows a simple agenda for
a sample one-day peer review.
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Table 11-1
Example of a one-day FLM program peer-review agenda
Time Activity
07h30 Plant access for visitors
Introductory meeting, including supervisory management, to discuss agenda and
08h00
review objectives for the activity
09h00 Plant walkdown inspection, including specific FLM program challenges
11h30 Lunch
12h30 Review and discuss pertinent plant procedures
14h00 Review and discuss pertinent training modules
15h30 Roundtable discussion of the top 3 FLM challenges at the host site
16h15 Exit summary
16h30 Adjourn
Peer reviews work best with smaller groups of participants; an optimal number is three to five
invited attendees. Too few participants may cause the review to lack sufficient technical mass
to ensure a lively discussion and debate of alternate ideas. Too many participants may result in
excessive discussion and dialogue that will make it difficult to keep the review on task and on
schedule.
It is important that the host FLMPO document the activity by preparing a summary in the form
of a simple letter report for future reference. The letter report should be provided to each of the
participants for their future reference as well.
11.3 Annual Program Review

Each year, the FLMPO should put together a formal annual program review (APR) for
presentation to plant management. The written APR should present a clear summary of the
current status of leakage events at the site and within the context of the overall performance trend
over the preceding year. The APR should also present trending information for the preceding
three years, if available. This longer view will enable users to put the current trend in better
context by looking at data covering at least two complete fuel cycles. When a significant
anomaly is identified in this intermediate term, it may be valuable to present five years, or three
fuel cycles, worth of data in order to put the identified anomaly into better perspective.
The APR should also identify all goals and objectives set during the preceding year and
summarize the current progress status for each. Where goals or objectives are changed during
the year, the change and reason should be identified in the APR.
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In addition to discussing performance against past goals, the APR should be the vehicle used to
set forth proposed goals and new objectives for the coming year. Goals should be clear, concise,
and measurable, and the basis for establishing each goal should be discussed. The APR should
identify any design initiatives that are ongoing or that need management support to address fluid
leakage issues.
Finally, the APR should identify and summarize all FLM program–related activities that took
place during the preceding year. These might include peer reviews, industry-based program
assessments, plant participation in industry topical meetings or other activities, and significant
changes to plant procedures, sealing materials used, or personnel training. The APR should also
identify any other noteworthy achievements not otherwise addressed in the report.
The goal of the APR is to provide plant management with a clear and concise understanding of
the scope of program activities during the past year, key accomplishments, performance of
planned goals, and planned program priorities for the coming year.
11.4 Industry OE Review

A key component of the FLMPO’s responsibility is to review and apply new industry OE
pertaining to industry FLM events as it becomes available. The FLMPO should develop a
process by which all new pertinent OE is routed to the FLMPO for review. The FLMPO should
maintain a reference file of topical OE, as well as an action item list to ensure that specific OE
applicable to improving the existing plant FLM program is implemented in a timely fashion.
11.5 Industry Benchmarking

Benchmarking of the manner in which other plants successfully address a long-term or emerging
issue of significance is a proven method for improving plant performance. Benchmarking should
consist of the following four distinct phases:
1. Definition. The process by which the FLMPO exactly defines the cause of the issue faced by
his or her plant FLM program, not just the outcome of the issue.
2. Awareness. The process by which the FLMPO develops an understanding of which other
plants have had experience with the specific issue and to what degree they appear to have had
success in resolving the issue at their sites.
3. Understanding. The process by which the FLMPO travels to one or more sites for the
purpose of developing a clear understanding of the solution developed by a specific plant and
the controlling factors, both general and plant specific, that contributed to the plant’s ability
to successfully resolve the issue.
4. Feedback. The process by which the FLMPO provides feedback to the benchmarked site and
others, as appropriate, on the relative level of success in applying the benchmarked solution
at his or her site. Feedback should quantify the level of success achieved as well as any
modifications to the benchmarked process necessary to make it successful.
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With respect to defining the issue, it is imperative that the FLMPO focus efforts on defining the
issue cause and not the symptom. For example, it may be more useful to know that the reason a
pipe cap is leaking is due to a leaking valve seat that enables excess pressure to build against the
cap rather than focusing on a better thread sealant for the pipe cap. Frequently, we tend to focus
on the symptom rather than the root cause.
To develop an initial sense of awareness of potential benchmarking candidate sites, the FLMPO
has a number of options that include the following:
• Nuclear network. Posting a request for information on the INPO’s Nuclear Network that
outlines the issue faced and clearly states a request for assistance desired
• Industry meetings. Attend industry topical meetings for discussion of plant issues with
industry peers
• Industry OE. Review of industry experience that highlights other plants that have faced the
same issue
• Fleet operations. Where the plant is a member of a larger utility fleet, contacting peers
across the fleet to learn whether they have had similar experience and if not, why not
• Vendor information. Where a specific component is primarily involved, the equipment
vendor may have suggestions for other industry contacts based on their field service business
Similarly, before embarking on scheduling a benchmarking trip to visit another plant, the
FLMPO should ensure that he or she adequately understands that the other plant has indeed
resolved the same root cause issue in a similar application and that any controlling factors
contributing to that plant’s success are similar to those found at the home plant.
When making the benchmarking visit, the FLMPO should have the following objectives:
• Confirm the scope of the issue and approach to the solution resolved by the host plant
• Obtain copies of supporting procedures or other documentation
• Identify controlling factors at the host plant that affect either implementation or success
• Number of specific challenges to success that had to be overcome
The acronym COIN can be used to describe these principal benchmarking process objectives.
Finally, it is important to provide feedback to the benchmarking host plant(s) on the results of
each benchmarking effort. This feedback not only provides confirmation of the capability to
successfully expand their technical approach to other sites, but also expands their understanding
of future related implementation issues that other sites may encounter.
11.6 Industry Participation

The final major area of program improvement is the area of participation in industry topical
meetings and events. This might include attending technical conferences, hands-on workshops,
or user group meetings related to FLM or even participating in technical working groups to
develop and deliver a related product or service for the industry.
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The two most common reasons cited for not participating in such industry events are (1) I don’t
have the time/budget to do so, or (2) I do not have the experience necessary to make a valuable
contribution to the activity.
With respect to the former, available time and budget, like diet and exercise, are matters of
priority. If improving the performance of your plant FLM program is a priority, then the FLMPO
will find the time and plant management will find the budget necessary to support participation.
With respect to the latter, it has been found over years of managing countless industry technical
initiatives that everyone, regardless of their level of expertise, can make valuable contributions to
their peers by their participation in various industry activities.
Plant FLM programs that do not actively participate in industry technical activities tend to
become stale and degenerative over time. Whether new ideas are identified and incorporated into
a plant program, the simple act of exposure to new ideas and the demands to explain your own
FLM program approach on a periodic basis will help to keep the program vital and effective.
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APPENDICES
12.1 FLM Program Self-Assessment with Scorecard

This self-assessment tool was developed by the nuclear power industry’s FLMUG in 2008.
Although it currently remains a work in progress, it does serve as a useful tool for providing a
common self-assessment format that will assist plants in developing a better understanding of
their own FLM program and as an aid in comparing the effectiveness of their program with that
of others.
EPRI has taken the liberty of making some minor formatting changes to improve presentation
consistency and clarity, as well as some grammatical corrections. In particular, EPRI has
changed the color-code designation for items in the 9–10 ranking from green to gold in order to
provide a better distinction between items at the existing 7–8 level that were also color-coded
green, and in keeping with the idea of representing industry best practice.
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FLMUG Metric Systematic Assessment

Guide with Scorecard
Station ____________________________________
Representative _____________________________
Date _____________________________________
FLM as a Station Process

STATION GOALS
The Station has demonstrated a strong and substantial commitment to taking control of fluid
leaks. A culture of Leak Intolerance for leakage on critical components is obvious, and the
impact of other leaks on station performance is apparent. As noted by EPRI, INPO and
Westinghouse documents regarding Boric Acid Leakage, a strong station commitment is one
of the foundations to any successful Fluid Leak Management Program.
Score
Rating Station Goals Score
(Color)
The Station demonstrates strong, obvious commitment to
control and prevention of fluid leaks, have instilled a culture of
intolerance for critical leaks. Station Performance Indicators
10 (Gold) Industry Best
(PI’s) exist, have been incorporated into the stations PI’s are
monitored and acted on when indication of declining
performance is noted.
Station has demonstrated a commitment to an FLM program.
PI’s exist and are used. A “Culture of Intolerance” to critical
Industry
8 (Green) leaks is noted and is communicated to the station. Goals are
Strength
kept challenging to foster a “continually improving, living
program”.
6 (White) High PI exist, Management attention to critical leaks is apparent.
4 (Yellow) Medium Various parts a commitment and culture are noted at the site.
Fluids Leaks are handled as normal business, no special

2 (Red) Low
priority or attention is given to them.
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CLARITY AND OWNERSHIP
1. Formal Process is Implemented

(That is, Procedures, Guidance, Desktop Leak Guide, Reference Book)
2. Program Owner or single point of contact
3. Dedicated Resources (staffing)
4. Management Support
5. Defined Roles and Responsibilities
6. Coordination between Work Groups (observation cooperation between groups)
7. Work Groups take ownership of their portion of the process/area
8. Demonstrated Craft Ownership
Score
Rating Clarity and Ownership Score
(Color)
All 8 attributes fully exist and are fully acknowledged by the
organizations.
Industry Formal process exists and 4 of 7.
8 (Green)
Strength
6 (White) High Formal process exists and 3 of 7.
4 (Yellow) Medium Formal process exists and 2 of 7.

2 (Red) Low No formal process exists.
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STAFF CAPABLITILIES AND EXPERIENCE
To effectively and efficiently implement a FLM program requires personnel who are
experienced, familiar with the station’s work process, knowledgeable in leak management and
continuously improves of the FLM program.
Score
Rating Staff Capabilities and Experience Score
(Color)
Owner roles and responsibilities are clearly defined.

Incumbent(s) (with a minimum of 2 years of program
ownership) and a backup are clearly identified and both fully
capable. Program ownership is consistent. Owner maintains a
FLM program plan of objectives and improvement initiatives for
constant improvement and development.
Industry Incumbent(s) fully capable and a backup clearly defined and

8 (Green)
Strength fully capable. Program ownership is consistent.
6 (White) High Incumbent(s) fully capable and backup has been named.
Incumbent(s) is capable of performing most roles and

4 (Yellow) Medium
responsibilities.
2 (Red) Low No incumbents have been named.
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FOCUS ON RESULTS Reduction of Leaks
The mere tracking, recording and classification of fluid leaks does nothing to eliminate their
impact. The ultimate focus remains the prevention of, elimination of reoccurring leaks/leak
sealing injections and overall number of fluid leaks. Within the parameters established by the
station performance is evaluated.
“Critical” term used below applies to the standard INPO AP-913 definition, or alternative used
by the station.
Score
Rating Focus on Results Score
(Color)
Station has no “critical” non-outage leaks and less than 3
“critical” outage leaks. Over Station leaks are less than 25.
Industry Results Equal or exceed Station Expectations.
8 (Green)
Strength
Results are below station expectations, and a
6 (White) High
Reduction/Recover Plan is in place and appears effective.
Results are below station expectations, and a
4 (Yellow) Medium Reduction/Recover Plan just being implemented, or its
effectiveness is not yet measureable.
Few or no goals or parameters for # of leaks, classification
2 (Red) Low and so on exists. If reduction plans exist they do not appear to
be effective.
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FLM Implementation
FLM PROGRAM AND PROCEDURE GUIDANCE
Procedures and process descriptions provide consistency and means to maintain and effectively
operate the FLM program. Provide a means to document continuous improvement of the FLM
process.
Score
Rating Status of PM Living Program Procedures Score
(Color)
Procedures are well defined, up to date on all FLM program
activities and support a proactive program. Guidelines for leak
classification, processing, prioritization and all FLM Living
10 (Gold) Industry Best Program features are well developed and documented in site
procedures reflect industry best practices. Procedure
compliance is overwhelmingly demonstrated throughout
the assessment.
Procedures are well defined and proactive on all FLM program
Industry
8 (Green) activities. Procedure compliance is demonstrated throughout
Strength
the assessment.
The basic FLM program and structure are defined, the
6 (White) High procedures are well defined and compliance is consistently
demonstrated. Structure may lack a more proactive attack.
The basic FLM program and structure are defined but the
4 (Yellow) Medium procedures are not well defined and thus compliance is not
consistently demonstrated. Defined program is not proactive.
2 (Red) Low No procedures or process description have been developed.
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FLM LEAK DEFINITION AND METRICS
Procedures call out program boundary, provide guidance on what is a leak and its classification.
Consideration is given to:
• Leakage Classification Rules (What is a Leak? size for action, and so on)
• Leakage Metrics − How leaks are counted
Score
Rating FLM Program Guidance Score
(Color)
Station has incorporated EPRI and WCAPP (if applicable)

guidance, demonstrates “a leak is a leak” philosophy (that is, all
leaks are counted). Establishes clear standards for when,
where, how leakage is acceptable, but are still counted.
Industry Station has built on the standard EPRI guidance and

8 (Green)
Strength addressed in more details, specific site issues/areas.
6 (White) High Standard EPRI guidance of leakage classification is used.
4 (Yellow) Medium Some form of general guidance is provided.
No guidance exists for classification of leakage or any

2 (Red) Low
structured approach to their evaluation.
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LEAKAGE IDENTIFICATION AND TRACKING
Based on criteria develop, a well-defined process not only tracks leaks which are identified, but
establishes and insures that a process for the “identification” exists.
Score
Rating Leakage Identification and Tracking Score
(Color)
“A LEAK IS A LEAK”, all leaks are identified A formal process
for scheduled leak identification walkdowns exists (that is,
startup, shutdown, pressure test). All station person have
bought in to routinely reporting leaks when found.
Leaks are identified routinely, and leak id walkdowns are
Industry performed. All station persons have bought in to routinely
8 (Green)
Strength
reporting leaks when found.
Leaks are identified routinely, no special efforts are made to

6 (White) High
insure all leaks are identified.
Only critical leaks are identified no program for specific
4 (Yellow) Medium
walkdowns.
Leaks are not specifically identified and tracked. Actions
2 (Red) Low requests are generated purely as the normal station work.
Leaks are not consistently identified.
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ADDRESSING LEAKS – WHY, HOW, WHEN
The FLM Program should include evaluation, tracking, and correction of any indications of any
leakage detected during any plant activities.
Score
Rating Addressing Leaks – Why, How, When Score
(Color)
Fluid leaks are promptly classified, as appropriate, evaluated.
Per established guidance, actions are taken to stop, contain
and monitor. Responsible groups define corrective actions and
actions are taken. Based on Leak classification, Work Control
insures leaks are addressed promptly. (That is, repairs are
scheduled and rarely rescheduled). Processes effectively,
promptly establish catchments, wipe and watch or seal
injections as called for.
Fluid leaks are classified, addressed as appropriate. Per
established guidance, actions are taken to stop, contain and
monitor. Responsible groups define corrective actions and
Industry
8 (Green) actions are taken. Based on Leak classification, Work Control
Strength
insures leaks addressed (that is, repairs are scheduled and
most are not rescheduled). Processes establish catchments,
wipe and watch or seal injections as called for.
Fluids leaks are considered by classification but evaluation and
scheduling are not rigorously followed and may not routinely
6 (White) High occur. BACC evaluations are performed. Processes for
catchment, wipe & watch and seal injections may exist but may
be general and/or no routinely implemented.
Fluid leaks are treated as any other station issues, only BACC
4 (Yellow) Medium evaluations are performed. Guidance may exist for catchment,
wipe & watch and seal injections.
Fluid leaks are treated as any other station issues, usually few
2 (Red) Low or no evaluations are performed or considered. No priority for
repair is given leaks which other would warrant attention.
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LEAK CAUSE DETERMINATION
Do you know the cause of your leaks? Are your leaks caused by rework?
Score
Rating Leak Cause Determination Score
(Color)
Significant leaks or leaks on “critical” components are
appropriately investigated to determine cause and extend of
condition. Site procedures incorporate check off list and/or
other aids in assisting Maintenance in leak cause
determination. Corrective Action Process (CAP) is triggered on
leaks of “critical” components. As appropriate full CAP
evaluations are performed. Rigorous tracking/evaluation of
leaks is done to identify trends/generic causes.
Significant leaks or leaks on “critical” components are
appropriately investigated to determine cause and extend of
Industry
8 (Green) condition. In general it is felt that leaks have a cause and efforts
Strength
are spent to determine them. General tracking and evaluation
of leaks is done to identify trends/generic causes
On some “critical” leaks consideration is given to casual factors
or prevention of reoccurrence. Generally the station appears to
6 (White) High accept that leaks to some degree are expected. Each leak is
generally viewed as a separate event, little if any effort is spent
attempting to trend leaks.
Station expectations rarely drive for determination of the cause
4 (Yellow) Medium of most leaks. Station accepts leak as a part of normal station
operation.
When leaks occur they are simply repaired. No follow up or
2 (Red) Low investigation is normally pursued except for special serious
cases.
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FLM DATA MANAGEMENT
Industry experience to date has shown that due to the quantity of leaks, the information required
to properly identify, classify, track, trend, evaluate and measure performance, good management
of FLM data is crucial. While simple databases can function adequately, their update and
accuracy must be maintained.
Score
Rating FLM Database Management Score
(Color)
Automated data management process is in place assembling
10 (Gold) Industry Best all required data required for maintaining an Industry Best FLM
program, requiring little manual upkeep.
Regardless of software application all required data is

assembled on a regular frequency, is readily available, feeds
Industry
8 (Green) into PI’s and is a crucial tool to leak cause evaluation. Process
Strength
is labor intensive and if resources are reduced effort could
easily fall down.
Simple database is maintained capturing the major critical items
6 (White) High required, but may be labor intensive to update, have limited
access to station personnel, and be infrequently updated.
Minimum information is accumulated only a specific areas such
4 (Yellow) Medium
as BACCP, or critical system leakage.
No Effect is made to consolidate leak information or provide
2 (Red) Low
data for PI’s.
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TRAINING
Individuals involved in the FLM program need a basic understanding of the FLM process, site
procedures, FLM scope, basic insights into FLM, and the interrelationships between interfacing
organizations. General Training incorporation of OE and Best Practices.
Score
Rating Status of Training Score
(Color)
All appropriate personnel (for example, FLM program owner,
engineers, and so on) have been formally trained to relevant
10
Industry Best aspects of the program within the past two (2) years, and
(Green)
station reinforces training through an ongoing communications
program.
All appropriate personnel (for example, FLM program owner,
Industry engineers, and so on) have been formally trained to relevant
8 (Green)
Strength aspects of the program, and station reinforces training through
some site/fleet communications.
All personnel are aware of their roles and responsibilities, and
6 (White) High
there is evidence of either formal or informal training.
Most personnel are aware of their roles and responsibilities,
4 (Yellow) Medium
though there is no evidence of training.
2 (Red) Low Most personnel are unaware of their roles and responsibilities.
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Technology & Materials

FLUID LEAK MANAGEMENT AND MATERIALS
INTENT IS THAT FOR EACH OF THESE AREAS A SEPARATE SPECIFIC GUIDE

WOULD BE CREATED, THE COMBINED SCORE FROM THAT MORE DETAILED
GUIDE WOULD BE PROVIDED HERE. These individual guides would also be stand alone,
so with them, you could perform an assessment of just that area (that is, gaskets, packing.)
Score
Rating Packing Program Score
(Color)
Industry
10 (Gold)
Best
Industry
8 (Green)
Strength
6 (White) High
4 (Yellow) Medium
2 (Red) Low
Score
Rating Gasket/Seals Program Score
(Color)
Industry
10 (Gold)
Best
Industry
8 (Green)
Strength
6 (White) High
4 (Yellow) Medium
2 (Red) Low
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Score
Rating BACCP Program (if applicable) Score
(Color)
Industry
10 (Gold)
Best
Industry
8 (Green)
Strength
6 (White) High
4 (Yellow) Medium
2 (Red) Low
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FLM as a “Living Process”

DOCUMENTED PROGRAM HEALTH, ASSESSMENTS AND BENCHMARKING
In order to maintain a high quality FLM program, the FLM owner should periodically assess the
process to monitor, display and communicate the health of the program, including benchmarking
the program against other sources (industry, fleet or other units).
Note: The WCAPP states a periodic program self-assessments are recommended once every
2 years following significant programmatic enhancements. For mature programs, the self-
assessments can range from 3 to 5 years.
Score Documented Program Health, Assessments

Rating Score
(Color) and Benchmarking
A comprehensive FLM Program Health report has been
demonstrated to be current and dynamic for at least 1 year.
At least one program assessment has been conducted and
documents over the past 3 years with a clear improvement
action plan. Owner has participated in at least two industry
benchmarking activities each year for the past 2 years.
A comprehensive FLM Program Health report or similar .
periodic review has been demonstrated to be current. At least
Industry one program assessment has been conducted and documents
8 (Green)
Strength over the past 3 years with a clear improvement action plan.
Owner has participated in at least one industry benchmarking
activity each year for the past 2 years.
A FLM Program Health report or
similar periodic review has been
implemented. At least one program
assessment has been conducted
and documents over the past 3-5
6 (White) High
years including as appropriate an
improvement action plan. Owner
has participated in at least one
industry benchmarking activity over
the past 2 years.
At least some type of program review/assessment has been
conducted and documents over the past 3-5 years including an
4 (Yellow) Medium
appropriate action plan, or the owner has participated in at
least one industry benchmarking activity.
No FLM Program Health report has been developed, no
2 (Red) Low assessments have been performed, and no benchmarks have
been established.
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LEAK PREVENTION PROGRAM
A Leak Prevention Program is the proactive metric looking to see if proactive steps are taken
avoids leaks. This includes inspections, walk downs, special measures for repetitive leakers,
retorquing, and repacking if necessary.
Score
Rating Leak Prevention Program Score
(Color)
Appropriate proactive actions have been identified and
implemented to prevent leaks from occurring. A robust
feedback mechanism, both corrective maintenance and
preventive exists to identify opportunities for improvements.
The Fluid Leak Manager or appropriate personnel is involved
in the process.
Appropriate proactive actions have been identified and
Industry implemented to prevent leaks from occurring. A feedback
8 (Green)
Strength mechanism , both corrective maintenance and preventive
exists to identify opportunities for improvements.
Some proactive steps have been taken to prevent leaks from
6 (White) High
reoccurring.
Minor consideration is given to addressing the cause of leaks
4 (Yellow) Medium
or the need to retighten packing or gaskets on some basis.
2 (Red) Low No formal process exists no consider is given in this area.
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INTEGRATION OF INDUSTRY DATA, EXPERIENCE AND BEST PRACTICES INTO

FLM PROGRAM
It is beneficial to use subject matter experts to incorporate industry data into FLM
process/program to substantiate a living program. Industry data may include INPO operating
experience (OE), EPIX data, EPRI guidance, FLMUG recommendations, component failure
history, and so on. Use of specialized vendors to review, assist and recommend new techniques
and/or products.
New Technologies
Score Effectiveness of Integrating Industry Data into
Rating Score
(Color) FLM Program
The most current industry data is incorporated into FLM
process/program on a regular basis, and a process exists to
periodically review and update it. Process clearly captures the
concept “a living continually improving process”.
Industry Recent industry data is incorporated into FLM
8 (Green)
Strength process/programs.
Recent industry data is incorporated into most FLM
6 (White) High
process/programs.
4 (Yellow) Medium Some data is incorporated into some FLM process/programs.
Industry data has not been incorporated into FLM

2 (Red) Low
process/programs.
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12.2 On-Line Leak Sealing Decision Screening

Directions: Answer all of the following screening questions regarding the component being
considered for on-line leak sealing. Record the appropriate points for each question answer and
calculate the total points for decision screening. On-line leak seal candidates with a point total of
≥15 are considered to be viable candidates and may be pursued through the on-line leak sealing
process. Those jobs with a point total <15 need additional justification and may not be performed
without the consent of the Superintendent of Maintenance or his or her designee.
Description of proposed on-line leak sealing activity: ___________________________________
1. Can the component be isolated on-line?

Yes No Points: ______
(0 points) (3 points)
2. Will component isolation result in lost generation or increase the potential for a Unit
transient?
Yes No N/A Points: ______
(3 points) (0 points) (0 points)
3. What is level of risk to Unit reliability if activity is not performed?

Low Medium High Points: ______
(1 point) (2 points) (3 points)
4. What is level of risk to Unit reliability incurred during performance of the activity?
(2 points) (1 point) (0 points)
5. What is level of increased operability risk associated with leakage, that is, ECCS leakage
external to containment may pose higher risk due to offsite dose limit considerations.
6. How much time remains before the next scheduled Unit outage?
≤ 3 mo. ≤6 mo. >6 mo. Points: ______
7. What is level of impact to Materiel Condition/Housekeeping of the general Area?

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8. What is level of risk for substantial component damage and repair cost if activity is not
performed?
9. What is level of risk to personnel safety if activity is not performed?

Total Points: _____________
Recommended action with consideration of screening point total: _________________________

Screening Performed By: ___________________________
Screening Approved By: ____________________________
Additional approval for activities with <15 screening point total: (attach additional justification)
Approved By: ____________________________________
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Establishing An Effective Plant Fluid Leak Management and Prevention Program

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Establishing An Effective Plant Fluid Leak Management and Prevention Program

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Establishing an Effective Plant Fluid Leak

Management and Prevention Program

2015 TECHNICAL REPORT

Final Report, December 2015

EPRI Project Manager

All or a portion of the requirements of the EPRI Nuclear

ELECTRIC POWER RESEARCH INSTITUTE

Establishing an Effective Plant Fluid Leak Management and Prevention Program is a

APR annual program review

1 INTRODUCTION .................................................................................................................... 1-1

2 LEAKAGE DEFINITIONS AND CLASSIFICATIONS ............................................................ 2-1

3 FLM PROGRAM BENEFITS .................................................................................................. 3-1

4 INDUSTRY EXPERIENCE ..................................................................................................... 4-1

5 OBJECTIVES AND GOALS ................................................................................................... 5-1

6 PLANT MANAGEMENT INVOLVEMENT .............................................................................. 6-1

8 LEAKAGE ASSESSMENT PRACTICES ............................................................................... 8-1

9 PROCEDURES, MATERIALS, AND TRAINING ................................................................... 9-1

11 PROGRAM IMPROVEMENT ............................................................................................. 11-1

12 APPENDICES ..................................................................................................................... 12-1

Figure 1-1 EPRI FLM technical guidance ................................................................................. 1-2

1.3 Target Audience

2.1 General Definition of a Leak

2.2 Defining the Program Scope

2.3 Leakage Severity Levels for Common Fluid Types

Leakage Severity Levels

3.1 Improved Plant Safety

3.2 Improved Plant Appearance

3.3 Direct Cost Reduction

3.3.1 Cost of Direct Work to Repair Leaks

Work Order Person-Hours Associated with a Leak

Activity Resource Person-hours

Operations review Shift manager 0.5

Clerk to print package Planning 0.5

Develop radiation work permit/as low as

Table 3-1 (continued)

Work Order Person-Hours Associated with a Leak

Activity Resource Person-hours

Total person-hours 33.5

Cost @ $75 per person-hour $2513

Work package preparation cost $3000

Total labor cost $5513

Parts and materials cost Unknown and varies

3.3.2 Costs Associated with Cause Analysis of Leaks

3.3.3 Costs of Replacement Power for Leaks Causing Shutdowns

3.3.4 Radwaste and Water-Processing Costs

3.3.5 Special Costs

3.4 Reduced Indirect O&M Impact

3.5 Improved Industry and Regulatory Recognition

4.1 U.S. Experience: 1974–2003

4.1.1 Significant Event Data: 1974–2002

• Required action not taken by operators

4.1.2 Special Analysis Conducted Between 2002 and 2003

4.2 Analysis of Events Adding 2003–2014 Events to Previous Analysis of

4.2.1 Significant Events: 1974–2014

4.2.2 2003–2014 Events Causing Forced Shutdowns Analysis

Shutdowns Caused or Complicated by All External Leaks 2003-

Replaceable Seals and Joints Welds, Base Metal, etc.

4.2.2.1 2003–2014 Events for Base Metal and Welds

Leaks Causing or Complicating Shutdowns 2003-2014

Pipe, 15, 18%

High Level Causes for Leaks from Replaceable Seals Causing

Replaceable Joints Types Causing or Complicating Shutdowns

4.4 Industry Performance Metrics