A general description of limitations that exist in pressure vessel neutron fluence determinations for commercial light water reactors is presented. Complexity factors that arise in light water reactor pressure vessel neutron fluence calculations are identified and used to analyze calculational limitations. Two broad categories of calculational limitations are introduced, namely benchmark field limitations and deep penetration limitations. Explicit examples of limitations that can arise in each of these two broad categories are presented. These limitations are used to show that the recent draft regulatory guide for the determination of pressure vessel neutron fluence, developed by the Nuclear Regulatory Commission, is based upon procedures and assumptions that are not valid. To eliminate the complexity and limitations of calculational methods, it is recommended that the determination of light water reactor pressure vessel neutron fluence be based upon experiment. Recommendations for improved methods of pressure vessel surveillance neutron dosimetry are advanced.
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