A number of technical challenges have been identified in applying current methods to evaluate the effects of reactor water environment in fatigue evaluations of reactor components in license renewal applications. One challenge in using more conservative approaches is the large environmental penalty factor that may be calculated for stainless steels. The use of more sophisticated methods leads to more complex challenges, like the determination and application of transient strain rates required by the current proposed equations. For example, the definition of transients for component evaluations must consider competing effects of strain rate and stress range to assure a conservative design. As discussions extend to the possibility of addressing environmental effects in fatigue design requirements of the ASME Code, it is important to consider the implications of the challenges met in application of the current methods. This paper describes a plant-specific application of environmental fatigue penalty factors, the aspects of the challenges encountered in the application, and the ramifications of the various considerations on incorporation of fatigue environmental evaluations in future design requirements.

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