Text

CFR50.55a Request: Proposed Alternative to ASME Section XI Requirements for Replacement of Class 3 Buried Piping
	ML082470210
Person / Time
Site:	Callaway
Issue date:	07/10/2008
From:	Mills K; AmerenUE, Union Electric Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TAC MD6792, ULNRC-05517
	Download: ML082470210 (244)
	v • d • e

AmerenUE PO Box 620 CallawayPlant Fulton, MO 65251 July 10, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 ULNRC-05517 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 VIA merefn UNION ELECTRIC COMPANY UE FACILITY OPERATING LICENSE NPF-30 10CFR50.55a REQUEST: PROPOSED ALTERNATIVE TO ASME SECTION X1 REQUIREMENTS FOR REPLACEMENT OF CLASS 3 BURIED PIPING - (TAC NUMBER MD6792)

References:

1. ULNRC-05434 dated August 30, 2007

2. ULNRC-05490 dated April 17, 2008

3. NRC Request for Additional Information (RAI) letter from Mohan C. Thadani to Charles D. Naslund dated June 10, 2008 In Reference 1 cited above, and in accordance with 10CFR50.55a, Union Electric Company (AmerenUE) submitted Relief Request 13R-10 regarding paragraph IWA-4221 (b) of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI. The relief requested per 13R-10 is needed to support the planned replacement of buried steel piping in Callaway's essential service water (ESW) system with high-density polyethylene (HDPE) piping. For this repair/replacement activity, IWA-4221(b) would require the new/replacement piping to meet the original Construction Code requirements for the ESW piping. The applicable Construction Code (ASME Section III), however, does not provide rules for the design, fabrication, installation, examination and testing of HDPE piping, and therefore, AmerenUE requested relief from the noted Code requirements. [The ASME Section XI Code Edition applicable to the current 10-year Inservice Inspection interval for Callaway Plant is the- 1998 Edition (up to and including the 2000 Addenda).] AmerenUE's relief request is still under review by the NRC staff.

In Reference 2, AmerenUE responded to questions received from the NRC's Piping and NDE Branch (CPNB) and Mechanical and Civil Engineering Branch (EMCB) regarding the relief request. More recently, additional questions/requests '*.io( ?i were identified by the NRC staff and were transmitted in a request for additional Q information (RAI) identified as Reference 3 above. The questions/requests of the P C(-

a subsidiary of Ameren Corporation

ULNRC-05517 July 10, 2008 Page 2 Reference 3 RAI letter were contained within five enclosures to the letter. The questions/requests contained in Enclosures 1 and 2, in particular, were provided from the NRC's Division of Component Integrity and Division of Engineering, respectively. AmerenUE is hereby providing its responses to those questions/requests. Responses for the questions/requests contained in Enclosures 3, 4, and 5 of the Reference 3 RAI letter are being transmitted under a separate cover letter from AmerenUE, i.e., AmerenUE letter ULNRC-05520.

In response to the NRC's RAI letter, Enclosure 1 of this letter contains responses to the questions/requests from the NRC's Division of Component Integrity, and Enclosure 2 provides responses to the questions/requests from the NRC's Division of Engineering. Supporting information for the responses is provided in additional enclosures to this letter. Specifically, a letter from Dow Chemical Company (with its own attachments) is provided in Enclosure 3. Enclosure 4 contains a calculation of the minimum wall thickness for the subject underground HDPE piping, i.e., Callaway Calculation 2007-13241. (The calculation is not finalized but will be available for inspection after finalization.) Enclosure 6 provides information that supports the response to one of the RAI questions addressed in . It provides a basis for use of a 0.56 design factor in the determination of allowable stresses for the HDPE piping design. Enclosure 7 provides a summary of the commitments made within this submittal.

In addition, in developing the responses for the NRC's RAI, it was determined that the relief request document itself (as originally provided via Reference 1) must be revised. An updated and final version of the relief request, i.e., 10CFR50.55a Request Number 13R- 10, is therefore provided as Enclosure 5 to this letter. The revised relief request has its own attachment, "Requirements for HDPE Piping for Nuclear Service," which is included within Enclosure 5.

If you have any questions on this letter or its enclosures, please contact Mr.

Scott Maglio at (573) 676-8719.

Very truly yours, Keith A. Mills Manager - Plant Engineering

ULNRC-05517 July 10, 2008 Page 3 GGY/MDB/TBE/nls

Enclosures:

1 - Responses to RAI Questions/Requests from NRC Division of Component Integrity 2 - Responses to RAI Questions/Requests from NRC Division of Engineering 3 - Letter from Dow Chemical Company (with attachments) 4 - Callaway Calculation No. 2007-13241 5 - 10CFR50.55a Request Number I3R-10 (with attachment) 6 - Justification for Increase in Callaway's HDPE Design Factor 7 - Summary of Regulatory Commitments

ULNRC-05517 July 10, 2008 Page 4 cc:

U.S. Nuclear Regulatory Commission (Original and 1 copy)

Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Mr. Elmo E. Collins, Jr.

Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8G14 Washington, DC 20555-2738

ULNRC-05517 July 10, 2008 Page 5 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Responses and Reports ULNRC Distribution:

A. C. Heflin w/o F. M. Diya w/o T. E. Herrmann L. H. Graessle w/o S. M. Maglio w/o T. B. Elwood S. L. Gallagher w/o L. M. Belsky (NSRB)

R. D. Myatt w/o C. R. Kieferw/o M. D. Brandes J. E. O'Sullivan G. G. Yates w/o Mr. Ron Reynolds, Director (SEMA)

Mr. Edward Gray, Senior REP Planner (SEMA)

Mr. John Campbell, REP Planner (SEMA)

Ms. Diane M. Hooper (WCNOC) w/o Mr. Dennis Buschbaum (TXU) w/o Mr. Scott Bauer (Palo Verde) w/o Mr. Stan Ketelsen (PG&E) w/o Mr. Scott Head (STP) w/o Mr. John O'Neill (Pillsbury, Winthrop, Shaw, Pittman LLP)

Mr. Floyd Gilzow (DNR)

Enclosure I to ULNRC-05517 Enclosure 1 Responses to RAI Questions/Requests from NRC Division of Component Integrity

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELATED TO ESSENTIAL SERVICE WATER UNION ELECTRIC COMPANY CALLAWAY PLANT DOCKET NO. 50-483 The Division of Component Integrity staff has reviewed the licensee's response to the Nuclear Regulatory Commission (NRC) staff s first round of request for additional information (RAI). Based on that review, the NRC staff has a need for additional information. Accordingly, a second round of RAIs was sent to the licensee via e-mail on June 2, 2008, and is being formally documented here for response.

As stated above, the NRC staff requests a response to the following second round of RAIs.

1. Title 10 of the Code of Federal Regulations (10 CFR) Appendix B, Criterion XVII, Quality Assurance Records, states, "Records shall be identifiable and retrievable." The Standard Fusion Procedure Specification (FSP) in QF-221 implies that the supporting records exist in the Plastic Pipe Institute (PPI) report TR-33/2001. The data used in TR-33/2001 is based on limited tests and equipment manufacturer recommendations. The information supplied in Callaway's request does not provide record traceability and record retrievability that support the FSP qualification tests.

Question/Reqiuest:

Provide a discussion on the accessibility of records supporting the procedure, equipment, and personnel qualifications that will be used for installation and examination of high density polyethylene (HDPE) pipe.

Response

Background Background information needs to be provided to answer this question. First, TR-33 was written to address 49 CFR 192.283 (Federal safety standards for transportation of natural and other gas by pipeline):

Sec. 192.283 Plastic pipe:

(a) Heat fusion, solvent cement, and adhesive joints. Before any written procedure established under Sec. 192.273(b) is used for making plastic pipe joints by a heat fusion, solvent cement, or adhesive method, the procedure must be qualified by subjecting specimen joints made according to the procedure to the following tests:

(1) The burst test requirements of--

(i) In the case of thermoplastic pipe, paragraph 6.6 (Sustained Pressure Test) or paragraph 6. 7 (Minimum Hydrostatic Burst Pressure (Quick Burst)) of ASTM D 2513...

(3) For procedures intended for nonlateral pipe connections, follow the tensile test requirements of ASTM D638, except that the test may be conducted at ambient temperature and humidity. If the specimen elongates no less than 25 percent or failure initiates outside the joint area, the procedure qualifies for use.

During the initial development process of TR-33, two parameters were found to be critical: interfacial pressure (60-90 psi) and fusion temperature (Heater Plate) of 400-450' F. Pipe size or wall thickness was determined not to be a critical variable.

(Heater) Temperature The temperature is critical not only for the material but the fusion process as well.

If the temperature is higher than 4500 F, damage to additives in the base material may occur thereby reducing the material properties. Also, a high temperature could cause excessive melted material to flow out of the joint when pressure is applied creating a poor quality joint. Low temperatures could result in incomplete fusion.

Interfacial Pressure The interfacial pressure is critical to ensure the proper fusion of the melted material when the pipe ends are pressed together. If the pressure is lower than 60 psi the pipe end may not fuse correctly, resulting in "cold fusion." If the pressure is too high, excessive melted material could flow out of the joint creating a poor quality joint.

Pressure Test Per 49 CFR 192.283 a pressure test is required to verify the strength and quality of the fused joint. One of two methods, sustained pressure test (long term, ASTM D-1598) or quick burst test (short term, ASTM D-1599), can be used.

TR-33 Protocol Using the Interfacial Pressure and Heater Temperature data, a Fusion Box is created as shown in the figure below.

Test Poinla 450 W

FUSION BOX S 400 60 00 PRESSURE Any fused joints made using parameters within the "Fusion Box" will have a very high probability of being a properly fused joint. Each corner of the "Fusion Box" is tested using a combination of tests: high speed impact testing, and quick burst testing or sustained pressure testing. If there is a change in essential variables, a new procedure incorporating those variables will necessitate five test coupons (pipe fusion joints) at each of the extremes (20 total coupons)- three for high speed impact testing and two for sustained pressure testing.

Applicability to Callaway Although PE3408 was used for development ofTR-33/2001, Dow Chemical, the constituent supplier for the piping provided for the Callaway ESW project, has provided Callaway with test results for the Dow PE4710 resin confirming acceptability for use with the TR-33/2001 procedure. Information regarding this concern is included in .

This information from Dow Chemical will be retained in permanent Callaway records.

In addition, and as a performance demonstration of the fusion process and equipment beyond TR33 and PPI requirements, AmerenUE will produce and perform testing on six (6) fusion joint test coupons of 36NPS DR 9.5 material and 4NPS DR 9 material on each model of fusion machine expected to be used in production, as stated in the response to Question 2 below. All data from this performance demonstration will be retained in permanent Callaway records.

Records are produced during qualification of fusion operators on production equipment in accordance with Callaway's fusion qualification program requirements and are retained as permanent records. The instruments used on the production equipment are calibrated under an approved program and the calibration records are also retained as permanent records.

2. 10 CFR 50 Appendix B, Criterion III, Design Control, states, "Where a test program is used to verify the adequacy of a specific design feature in lieu of other verifying or checking processes, it shall include suitable qualifications testing of a prototype unit under the most adverse design conditions." The two procedure qualification methods in Code Case N-755 must demonstrate that they are capable of making acceptable fused joints. The demonstrations must cover pipe sizes and essential variable extremes for the equipment (manufacturer model) that is being used for fusing joints. The reference to PPI report TR-33/2001 does not provide sufficient test data for equipment and procedure-specific qualifications for the essential variable extremes. The performance demonstration should use representative pipe material and pipe sizes (diameter and wall thickness), and the performance demonstration should make sufficient repetitions of fused joints to statistically evaluated equipment and fusion process reliability*

Question/Req uest:

Provide a discussion describing the performance demonstrations that will be used for equipment and procedure qualifications, and describe the testing that will be used to validate internal soundness supporting equipment and procedure qualifications. Provide the same discussion for each process (butt fusion, electro-fusion. etc,) if more than one process is used for fusing joints.

Response

AmerenUE has elected to qualify all fusion operators on the standard TR33/2001 procedure using the same size (36 NPS) and thickness (approximately 4 inches) of pipe, same model machines (McElroy and Ritmo), and at the same target values (pressure and temperature) to be used during production. These qualification tests (similar to those specified in 49CFRI 92.285) simulated the actual production conditions to be employed and therefore serve as performance demonstrations for the process, as well as for the equipment and personnel. From each coupon, two specimens were cut, visually inspected, and hydraulically bend tested to exceed 20% strain at the fusion joint (one test specimen for the interior surface and another for the exterior surface). (The yield point of HDPE typically occurs at approximately 10% strain.) The surfaces of each specimen were visually examined for any evidence of voids, discontinuities, or failure in the joint area.

Sixteen (16) specimens were bend-tested (eight in the fabrication shop and eight in the field), with one test failure. The operator with the one failure in the shop underwent additional training and successfully passed on re-test. In addition, the machine was inspected and adjusted to improve uniformity of heating, and six additional test specimens (for a total of 22) were then produced on the machine - all of which successfully passed the bend-tests. These tests - each pair of which simulates the single performance demonstration required by ASME Section IX (QW-5 10 & QW-302.1) to allow a manufacturer to use a Standard Welding Procedure Specification (QW- 100.1) -

validate the internal soundness of large diameter heavy wall piping joints made by thermal butt fusion on actual production machines using the standard fusion procedure described in TR33/2001.

As a performance demonstration at the request of the Regulator, AmerenUE will produce six (6) fusion joint test coupons of 36NPS DR 9.5 and six (6) fusion joint test specimens of 4NPS DR 9 material on each model of fusion machine carriage expected to be used in production for the respective size of piping as a performance demonstration. Three (3) of these fusions on each machine will target minimum temperature and interfacial pressure using maximum heater removal times, and three (3) will target maximum temperature and interfacial pressure using minimal heater removal times - to the extent feasible considering production limits, machine capabilities and the limits of the AmerenUE Fusion Procedure Specification.

A minimum of four (4) specimens will be cut from each fusion joint coupon approximately 90 degrees apart and tensile-tested to verify that the fusion joint is stronger than the pipe. Testing will be performed by commercial plastics industry suppliers without a 10 CFR 50 Appendix B quality program, but all testing will be overseen by AmerenUE representatives, and the test records will be retained in permanent Callaway records.

High-speed impact tensile testing for the 4NPS specimens will be performed in accordance with QF-131. This testing will also be performed for the 36NPS specimens if determined feasible and conclusive considering the need - due to tensile machine capability - to test segmented specimens; otherwise, tensile testing for the 36 NPS specimens will be performed with full-section specimens consistent with ASTM Specification D638, "Standard Test Method for Tensile Properties of Plastic," in accordance with the butt fusion procedure qualification requirements of 49CFR192.283 for gas pipelines.

Only the butt thermal fusion process will be used on this project.

Question/Request:

2.(a) QF-223(a) provides one pipe diameter and wall thickness for equipment and procedure qualification testing. The use of a one-size (diameter and wall thickness) pipe to represent all pipe sizes ignores the effect that pipe diameter and wall thickness have on fused joint integrity. The PPI TR-33/2001 report does not provide information to support that a one-size pipe is representative of all pipe sizes. Discuss the demonstration data that supports the representativeness of one pipe size for all pipe size combinations or that supports the range of pipe sizes that will be used. Provide the criteria to be applied to demonstrate fused joint soundness for the range of pipe sizes that will be used.

Response

There are two options provided for a Fusion Procedure Specification (FPS): use of the Standard FPS based on TR-33, or development and qualification of a new FPS.

Standard FPS Option The Standard FPS is based on TR-33, which was developed at the request of the United States Department of Transportation to promote greater uniformity in the joining procedures utilized by gas utilities for the butt fusion of polyethylene products. TR-33 has since become the standard industry practice for butt fusion of polyethylene. The conclusion of TR-33/2001, based on the testing of 2 NPS and 8 NPS samples, was that pressure range and temperature range were the only variables essential for successful fusion of a broad range of medium and high density polyethylene piping materials.

TR-33/2006 subsequently expanded this testing to include 12 NPS, 14 NPS, 16 NPS, and 22 NPS samples and concluded that the fusion pressure range and temperature range established in TR-33/2001 are applicable to this expanded range of sizes.

AmerenUE is using this option.

New FPS Option Use of TR-33 is not mandatory, and every PE pipe producer and pipeline operator retains the option of developing different procedures for its particular products and pipelines. However, to develop a new FPS that deviates from the parameters of TR-33 would require 20 pipe coupons and 13 months of pressure testing.

Since the standard procedure developed by TR-33 applies to a broad range of sizes, there would little value added in requalifying for the AmerenUE application.

Callaway Plan AmerenUE has utilized the Standard FPS for the qualification of all fusion machine operators. As discussed above, this performance qualification

/demonstration of the fusion machines and fusion operators also served to demonstrate satisfactory performance of the Standard FPS on 36 NPS DR 9.5 piping.

Also, quick burst test data provided by Dow Chemical (included in Enclosure 3) confirms that joints produced with the TR-33/2001 procedure are stronger than the Dow PE4710 piping base material in sizes up to and including 22 NPS DR 9.

This burst test, coupled with the performance demonstration testing of six (6) fusion joint test coupons of 36NPS DR 9.5 material and 4NPS DR9 material on each model of fusion machine expected to be used in production, exceeds the requirements of 49CFR192.283(a) for butt fusion procedure qualification, and will confirm that the FPS used by AmerenUE is suitable for the sizes and thicknesses of piping that will be used.

QF-223(a) requires pipe coupons made from 8 IPS, DR 11. This size was chosen for ease of manufacturing the high speed tensile specimens and to accommodate the testing machine.

Question/Request:

2.(b) QF-104.1 (a) defines essential variables as conditions under which fusing must be performed, and QF-222(a) lists essential variables for procedure and equipment qualifications. The standard fusion procedure specification (QF-221) does not contain all of the essential variables listed in (QF-222) for procedure qualification. Discuss the application of the essential variables listed in QF-222(a) that will be used in the equipment and procedure qualification.

Response

The essential variables from QF-222 that were not included in QF-221 were (a) pipe material and (d) fusion pressure. In the attached proposed alternative, QF-221(b) has been corrected to include pipe material and QF-222 has been corrected to delete "fusion pressure" which is redundant to "butt fusion interfacial pressure range."

Question/Request:

2.(c) In the submittal, Paragraph 3041 provides criteria for minimum design temperature which may inadvertently be applied to procedure qualifications. The Code Case does not address the effects of lower temperatures on the effectiveness of the fusion process. In response to RAI question 1(b), the licensee stated that the minimum ambient temperature for joint fabrication is 50' F (degrees Fahrenheit) and will apply an environmental enclosure as necessary for temperature control. Since the fusion process is a temperature-dependent process and ambient temperature affects the heater removal to pipe fusion dwell time, the minimum ambient temperature is a variable. Provide the minimum ambient temperature that was used during the performance demonstration for equipment and procedure qualification.

Response

The 6 NPS and 36 NPS performance qualification/demonstration testing at the fitting fabrication shop was performed indoors at ambient temperatures- approximately 65-75' F. The 6 NPS and 36 NPS performance qualification! demonstration testing performed at Callaway was performed in a shelter that was open to the atmosphere - with temperatures ranging between 50 and 75' F. Fusing will not be performed in an environment below 50 'F.

Note that AmerenUE has placed this 50 'F lower limit for ambient temperature only as a conservative good practice; neither ASME nor the Plastics Pipe Industry (which often fuses HDPE using the standard procedure at temperatures below freezing) consider ambient temperature to be an important variable for the fusion process.

3. The response to RAI question 3(a) did not address the question of performance-based VT (visual examination) personnel qualifications.

Performance-based qualifications are in keeping with NUREG/BR-0303 and NRC's presentation, "NRC Perspective on NDE Performance Demonstration,"

given July 24, 2006, at the EPRI Performance Demonstration Workshop, Myrtle Beach, SC. The VT examination of HDPE-fused joints is substantially different than VT examinations of metal pipe. Therefore, criteria supplementing the current VT qualification are necessary to measure and verify personnel skill in VT examination of HDPE-fused joints.

Ouestion/Req uest:

Please supplement the response to RAI question 3(a) that includes criteria for performance-based personnel qualifications.

Response

All personnel performing Visual Examinations of HDPE pipe fusion joints must be certified VT-I examination personnel. In addition, they are required to receive the same training as required for the fusion machine operator. This involves a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of training, covering the principles of the fusion process and the operation of the fusion equipment. Included is a two-part test addressing theoretical knowledge and machine operation.

These requirements will be supplemented by additional evaluation involving examination of physical samples of visually acceptable and unacceptable HDPE pipe fusion joints. A minimum of five flaw samples will be used for the visual examination procedure demonstration, and five for the personnel demonstration using the visual examination procedure.

Ouestion/Req uest:

3.(a) In response to RAI questions 3(b) pertaining to inside-surface VT examination, 3(c) pertaining to voids at pipe ends, 3(d) pertaining to voids near the joint, and 4.0 pertaining to in-process testing, the licensee proposed using ultrasonic testing (UT) examinations to verify internal soundness of each fused joint and the adjacent pipe material with the exception of fittings. Currently, there are no UT performance-based criteria that are specific to an HDPE pipe. Provide the performance demonstration criteria for detection of flaws (internal unsoundness),

and provide an acceptance criterion statistically establishing detection reliability (an example is the ASME Code,Section XI, Appendix VIII).

Response

As there are no existing performance-based criteria specific to HDPE piping, a demonstration will be performed to verify that the Time-of-Flight Diffraction (TOFD) procedure utilized will apply available technology for this technique. The demonstration will utilize specimen(s) containing ten flaws of varying shapes, dimensions and relative locations, simulating flaws expected to occur in unacceptable joints.

As discussed in AmerenUE letter ULNRC-05490, the contractor performing the TOFD does not have a 10 CFR 50 Appendix B quality program, but the contractor's examiners will be qualified in accordance with SNT-TC-I A or equivalent, and the inspection records will be retained in permanent Callaway records.

AmerenUE is currently evaluating and refining acceptance criteria based on industry standards (e.g. ASME B31 piping codes). The current acceptance criteria require that any unbonded area in the joint, found as a result of the TOFD, is cause for rejection.

Question/Req uest:

3.(b) The response to RAI question 2(a) defined accessibility to the inside pipe surface as being within direct VT examination from an open pipe end or fitting end. The definition is ignoring industry experience with remote control VT examination equipment. Remote VT equipment is being used for diameters as small as steam generator tubes. Joints not conducive to UT examinations, such as fittings, will still have to be VT examined from both the inside and outside surfaces. Provide the criteria for VT examinations performed from the inside surfaces regardless of the distance from the pipe end, or provide another means for ensuring internal soundness for fused joints that can not be UT examined.

Response

All joints that are not visually inspected on the interior beads will be examined using Time-of-flight UT techniques.

4. The NRC staff has not found Code Case N-755 to be acceptable. The reference of Code Case N-755 in the proposed alternative can not be approved at this time. However, a proposed alternative for a site and application-specific request using the applicable parts and modifications provided in the RAI responses may be reviewable.

Question/Req uest:

Provide a revised proposed alternative that is specific to Callaway's essential service water system repair that does not reference Code Case N-755.

Response

The revised proposed alternative, i.e., revised Relief Request 13R-10 and its attachment, "Requirements for HDPE Piping for Nuclear Service," is provided in .

to ULNRC-05517 Enclosure 2 Responses to RAI Questions/Requests from NRC Division of Engineering

OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELATED TO ESSENTIAL SERVICE WATER UNION ELECTRIC COMPANY CALLAWAY PLANT DOCKET NO. 50-483 The NRC's Division of Engineering staff has reviewed the licensee's analysis provided in response to its request for additional information (RAI), and has determined that additional RAls are required based on its review. Please provide a response to the following RAls to facilitate the continuation of the review by the NRC staff.

In its application dated August 30, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072550488), Union Electric Company (AmerenUE) submitted Relief Request (RR) 13R- 10 for the replacement of Class 3 buried steel piping in the safety-related essential service water (ESW) system with polyethylene (PE) piping at the Callaway Plant, Unit I (Callaway). AmerenUE stated that the construction code of record for buried Class 3 piping is the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section III, Division 1, subsection ND, 1974 Edition through Summer 1975 Addenda. As the construction code and later editions and addenda do not provide rules for the design, fabrication, installation, examination, and testing of piping constructed using PE material, AmerenUE requests the approval of RR 13R-10 for the use of PE piping. AmerenUE proposed to use the provisions of the ASME Code Case N-755 for the ESW piping replacement effort. Since the relief request did not contain detailed technical documentation, the NRC staff requested detailed technical information that was captured in six questions in its initial RAI on February 29, 2008. AmerenUE responded to the NRC RAls by ULNRC-05490 dated April 17, 2008 (ADAMS Accession No. ML081190648), which included three enclosures (Reference 1).

Based on our review of the information in Reference 1, the following additional information is requested. Callaway is the first licensee that requested to utilize PE 4710 material piping in a safety-related ASME Class 3 application, and is the first to use temperatures higher than 100 'F (degrees Fahrenheit), pressures higher than 115 psig (pounds per square inch gauge), and diameters larger than 12.75 inches.

1. AmerenUE is requested to supplement the relief request to address specific aspects that prompted the NRC staff to not endorse ASME Code Case N-755.

NRC's review of the methodology utilized in the relief request is specific for the Callaway application only. The industry is engaged in an extensive ongoing testing program to establish the full range of properties, fatigue data, stress intensification factors, long-term creep rupture data, and slow crack-growth characteristics for the specific grade of PE material (PE 4710) to be utilized in the requested Callaway application. The current test data that support a fatigue-allowable of 1100 pounds per square inch (psi) for PE 3408 material data is very limited and does not meet the provisions in Section III of the ASME Code for establishing fatigue, curves (Electric Power Research Institute (EPRI) Report 1013549). More investigations are needed to confirm the short-duration (30 days) stress allowables, and applicable design factors. Furthermore, techniques to ensure the structural integrity of fusion joints are still evolving. Finally, there is currently no domestic performance or operating experience history regarding PE piping's use in nuclear safety-related applications.

Question/Req uest:

In light of these considerations and in conjunction with this request for alternative, AmerenUE should include whether it will formally commit to:

(a) Prior to submitting Callaway's fourth 10-year interval in-service inspection plan, Callaway will submit information obtained from the above referenced industry testing program to the NRC. If the information supports operation using PE 4710 for the remainder of plant life, this information will be submitted to the NRC for information only.

(b) If the information does not support operation using PE 4710 for the remainder of plant life, this information will be submitted to the NRC as part of a subsequent request for alternative for the fourth 10-year interval.

Response

AmerenUE will evaluate future investigations performed by the industry to confirm the short-duration (30-day) stress allowables and applicable design factors applied at Callaway for the PE4710 piping. AmerenUE will also evaluate future evolution of the fusion technique to validate structural integrity of the installed fusion joints. The results will be submitted to the NRC prior to submittal of Callaway's fourth 10-year interval in-service inspection plan, and will include, if necessary, a fourth-interval alternative request.

2. In Enclosure 1 (page 18 of 20), Attachment 2, Design Paragraph 3016, and in Enclosure 3 (page 4 of 152), Section 4.2.2 of Reference 1, AmerenUE states that the Miner's Rule in accordance with ISO 13760 will be used to account for operation for 30 days at (plant) post-accident conditions and normal operating conditions for the balance of the 40-year design life. However, there was no such evaluation included in Enclosure 3, Preliminary Stress Calculation 2007-16760.

Question/Reqiuest:

Provide the evaluation based on the Miner's Rule.

Response

The use of Miner's Rule is documented in the design minimum wall thickness calculation, i.e., Callaway calculation No. 2007-13241. This calculation is provided in Enclosure 4.

(Note: The calculation in Enclosure 4 is not finalized but will be available for inspection after finalization.)

3. In response to the staffs RAI question 6 (Enclosure 1, page 13 of 20, Reference 1), you stated that any sections with flaws exceeding 10 percent of wall thickness in 4-inch piping or flaws exceeding 7 percent of wall thickness in 36-inch piping shall be cut out and replaced. The response further stated that flaws below the above-stated limits will be left as-is or smoothly blended. Some degree of conservatism needs to be maintained in order to account for the uncertainties in the PE material properties. The ESW supply, return, and backwash lines, when replaced with PE material, will be subjected to relatively high temperatures (175

'F) and/or pressures (for a 36-inch supply line, 95 'F/l190 psig; for a 36-inch return line, 175 'F/45 psig; and for a 4-inch backwash line, 95 'F/1 80 psig). In the minimum required wall thickness (tmin) calculations, the fabricated thickness (tactual) without accounting for the reduced wall thickness due to flaws was utilized, and the margins left are practically insignificant as shown in Section 8.1.1 of Enclosure 3, page 141 of 152 of Reference 1. (For a supply line, tmin =

3.82 inches versus tactual = 3.85 inches; for a backwash line, tmin = 0.46 inches versus tactual = 0.5 inches.)

Question/Req uest:

3.(a) The NRC requests your reassessment of the minimum required wall thickness accounting for flaw depth in actual thickness. Please confirm that the remaining thickness (93 percent thickness (%t) for 36-inch pipes and 90 %t for 4-inch pipes in Section 7.1, Pressure Design of HDPE Pipes, of Enclosure 3, Reference 1) exceeds the minimum required ASME Code thickness.

Response

In response to the staffs concern, the following revised procedure for addressing damage to polyethylene piping under the scope of this project is provided:

(1) For 4-inch piping, any section with a flaw exceeding 10% of the wall thickness shall be cut out and replaced.

(2) For 36-inch piping, any section with a flaw exceeding 7% of the wall thickness shall be cut out and replaced.

(3) Wherever a flaw will result in a remaining wall thickness less than the required as-fabricated minimum wall thickness per ASTM F714, the affected section of piping shall be cut out and replaced or the stresses in the affected section shall be re-evaluated and determined to be acceptable considering the remaining wall thickness.

(4) Any section of piping with a flaw not exceeding 5% of the wall thickness and not resulting in a remaining wall thickness less than the required as-fabricated minimum wall thickness per ASTM F714 may be left as-is.

(5) All other flaws shall be removed by blending as follows:

(a) The depression after flaw elimination is blended uniformly into the surrounding surface with a maximum taper not to exceed 3:1 (ratio of width to height).

(b) After flaw elimination, the area will be examined by visual examination to ensure that the flaw has been removed.

(c) If the elimination of the flaw reduces the thickness of the section below the minimum required design thickness, the section of piping containing the flaw shall be cut out and replaced.

Question/Req uest:

3.(b) The NRC also requests you to confirm that the remaining wall thickness (93 %t for 36-inch pipes and 90 %t for 4-inch pipes) was used, rather than the fabricated wall thickness, in all of the structural integrity calculations (Reference 1, Section 7.3, Soil and Surcharge Analysis; Section 7.5, Longitudinal Stress Analysis; Section 7.6, Thermal Expansion Stress Calculations; Section 7.7, Seismic Stress Calculations; and Section 7.8, Pipe Systems Finite Element Analysis) to establish the acceptability.

Response

The final analysis will use the required as-fabricated minimum wall thickness per ASTM F714 in all structural integrity calculations. As stated in the response to RAI 3(a) above, wherever a flaw will result in a remaining wall thickness less than the required as-fabricated minimum wall thickness per ASTM F714, the affected piping section shall be cut out and replaced or the stresses in the affected section shall be reevaluated and determined to be acceptable considering the remaining wall thickness.

4. For Combined Seismic Induced Stresses [Seismic Wave Passage (equivalent thermal) and Building Seismic Anchor Motion], Enclosure 3, Reference 1: Section 7.7.2 (page 64 of 152, Return Lines); Section 7.7.3 (pages 70 of 152 and 74 of 152), the evaluations were based on a stress intensification factor, i = 1.0, for a straight pipe only. There is no sketch of the pipe layout provided to show the locations of mitered elbows, flange connections, interfaces with steel pipe, and buildings, and important joint numbers.

Question/Req uest:

4.(a) Provide a simple schematic of piping layout showing at least the major details.

Include orientation of N-S, E-W, and vertical directions along with Global X, Y, and Z coordinate axes.

Response

A simple schematic of the piping layout (i.e., drawing C-U206) is provided on page 14 of this enclosure.

Question/Req uest:

4.(b) Include a stress evaluation at a miter-bend location with a stress intensification factor, i = 2.0.

Response

Based on the results of the preliminary analysis, the locations of peak stress occurred in the straight pipe sections, even when a stress intensification factor of i = 2.0 was considered for mitered elbows. The final analysis will summarize the peak stress value in straight pipe and the peak stress in mitered elbows. A stress intensification factor of i = 2.0 will be used for mitered elbow locations.

4.(c) In the stress evaluations, the resultant moment was computed using two moment components (about vertical and transverse axes) only. Piping design rules specify the use of all three moment components including torsional moment in resultant moment computation. Please explain the rationale for your deviation.

Response

The final analysis will compute resultant moments using all three moment components.

This change is not expected to have a significant impact on the analysis results.

5. For Pipe Systems Finite Element Analyses, Enclosure 3, Reference 1, Section 7.8.1 (pages 104 of 152 and 105 of 152, SAP2000 Output, Return Lines), the evaluations were based on a stress intensification factor, i = 2.0, for a critical miter-bend location.

Question/Request:

5.(a) Secondary or Thermal expansion stress evaluation should be based on range of all thermal modes or load cases. Based on page 75 of 152:

Load Case 1: Twater - Tground = 175-70 = +105 'F; and Load Case 2:

Twater - Tground = 32-55 = -23 'F and not +60 'F as was used in the evaluation.

Since Load Case 2 has a negative temperature difference, the moment range between Load Case 1 and Load Case 2 will be higher than due to Load Case I or Load Case 2 alone. Given that your evaluation does not account for thermal expansion stress based on maximum range of moments, you are requested to explain the rationale for your thermal analysis or provide a re-evaluation consistent with maximum bounding thermal moment range. Typical piping stress analysis programs compute moment ranges for load cases, apply the appropriate stress intensification, and automatically compute intensified stresses at every node point in accordance with applicable ASME Section III Code edition. Are you doing stress computations manually using moments from SAP2000, because the SAP2000 program version V7.40 utilized for PE piping analysis does not have these features built-in?

Response

If the alternative thermal expansion and contraction evaluation is performed in the final analysis, the range of moments for the expansion and contraction cases will be evaluated instead of evaluating the expansion and contraction cases individually.

For the fully constrained thermal expansion and contraction evaluations, the calculated thermal stresses will be based on the temperature differential between the pipe operating temperature and the soil temperature. This approach is supported by EPRI document 1013549, "Nondestructive Evaluation: Seismic Design Criteria for Polyethylene Pipe Replacement Code Case," and EPRI document 1013549, "Design and Qualification of High-Density Polyethylene for ASME Safety Class 3 Piping Systems."

Stress computations are performed manually in Mathcad using the output from SAP2000 because SAP2000 does not have built-in features for PE piping analysis.

Question/Req uest:

5.(b) In the stress evaluations, the resultant moment was computed using two moment components (about vertical and transverse axes) only. NRC requests a re-evaluation using all three moment components including torsional moment in resultant moment computation (similar to item 4.(c) above of this RAI).

Response

The final analysis will compute resultant moments using all three moment components.

This change is not expected to have a significant impact on the analysis results.

6. For Pipe Systems Finite Element Analyses, Enclosure 3, Reference 1, Section 7.8.2 (pages 139 of 152 and 140 of 152, SAP2000 Output, Backwash Lines), the evaluations were based on a stress intensification factor, i = 2.0, for a miter-bend location.

Question/Request:

6.(a) Secondary or Thermal expansion stress evaluation should be based on a range of all thermal modes or load cases. Based on page 100 of 152, Load Case 1: Twater -

Tground = 95-70 = +25 'F; Load Case 2: Twater - Tground = 32-55 = -23 'F and not +20 'F as was used in the evaluation. Since Load Case 2 has a negative temperature difference, the moment range between Load Case 1 and Load Case 2 will be higher than due to Load Case I or Load Case 2 alone. An explanation for this discrepancy is requested, or a re-evaluation of thermal expansion stress based on maximum range of moments is required.

Response

As stated in the response to RAI 5.(a), if the alternative thermal expansion and contraction evaluation is performed in the final analysis, the range of moments for the expansion and contraction cases will be evaluated instead of evaluating the expansion and contraction cases individually.

For the fully constrained thermal expansion and contraction evaluations, the calculated thermal stresses will be based on the temperature differential between the pipe operating temperature and the soil temperature. This approach is supported by EPRI document 1013549, "Nondestructive Evaluation: Seismic Design Criteria for Polyethylene Pipe Replacement Code Case," and EPRI document 1013549, "Design and Qualification of High-Density Polyethylene for ASME Safety Class 3 Piping Systems."

Question/Request:

6.(b) In the stress evaluations, the resultant moment was computed using two moment components (about vertical & transverse axes) only. NRC requests a re-evaluation using all three moment components including torsional moment in resultant moment computation.

Response

The final analysis will compute resultant moments using all three moment components.

This change is not expected to have a significant impact on the analysis results.

7. For SAP2000 Input/Output, Enclosure 3, Reference 1 (page 10 of 24 of Attachment 10.4; page 10 of 19 of Attachment 10.5; page 13 of 37 of Attachment 10.6; and page 13 of 37 of Attachment 10.7), the value of 8.980E-05 kips per cubic inch used for weight per unit volume for PE material under material property data does not agree with the value of 0.959 grams per cubic centimeter (which corresponds to 3.465E-05 kips per cubic inch) given on page 7 of 152.

Question/Request:

Explain the discrepancy in the weight per unit volume for PE material and evaluate the impact, if any, on the results.

Response

The weight per unit volume value input into SAP2000 for PE pipe is a value that is representative of both the PE pipe and the water inside the pipe. The value is equivalent to the total weight of PE and water per unit length of pipe divided by the area of pipe material. As shown on page 10 of 24 of Attachment 10.4 and page 10 of 19 of 0.5, this value equates to 9.290E-05 kips per cubic inch for the 36" pipe. As shown on page 13 of 37 of Attachment 10.6 and page 13 of 37 of Attachment 10.7, this value equates to 8.980E-05 kips per cubic inch for the 4" pipe.

8. For Allowable Stress for Circumferential Compressive Stress in the sidewalls (Section 7.3, page 33 of 152 and Section 6.2.1, page 15 of 152), the NRC finds inappropriate the use of a constant allowable of 1000 psi (without any temperature dependence) for compression of sidewalls in PE piping.

Question/Request:

A re-evaluation is required using an allowable stress corresponding to the temperature to which the piping is subjected. For supply and backwash lines, it should be 695 psi at 95 'F, and for return lines it should be 340 psi at 175 'F in lieu of a constant 1000 psi.

Response

The final analysis will use temperature-dependent allowable stress values for evaluation of circumferential compressive stress in the sidewalls as requested. A review of the calculated stresses in the preliminary analysis shows that the use of temperature-dependent allowable stress values in lieu of a constant allowable stress value of 1000 psi will not change the conclusion that the calculated stresses are less than the allowable stresses.

9. For Flotation Analysis (Section 7.4, page 44 of 152), i.e., the weight of water (Ww) displaced by the pipe, the per-unit length (upward buoyant force) should be based on the outside diameter of the pipe. The calculations in Section 7.4 were based on the inside diameter of the pipe.

Question/Request:

Please re-evaluate the calculations based on outside diameter of supply, return, and backwash lines.

Response

The final analysis will perform flotation analysis based on the outside diameter of the pipe. This change is not expected to change the results of the flotation analysis.

10. For Longitudinal Stress Analysis (pages 46 of 152 through 52 of 152 in Sections 7.5.1, 7.5.2, and 7.5.3, Reference 1), the evaluations were based on primary stress indices of B1 = 0.5 and B 2 = 1.0 for a straight pipe only. For mitered elbows with a diameter ratio of DR = 9, B1 = 0.69 and B 2 = 1.64; and with a diameter ratio of DR = 9.35, B1 = 0.69 and B2 = 1.69.

Ouestion/Requ est:

10.(a) Include stress evaluation at a critical miter-bend location also with applicable primary stress indices.

Response

Based on the results of the preliminary analysis, the locations of peak longitudinal stress occurred in the straight pipe sections, even when the mitered elbow primary stress indices were considered. The final analysis will summarize the peak longitudinal stress value in straight pipe and the peak longitudinal stress in mitered elbows. The mitered elbow primary stress indices will be used for mitered elbow locations.

Question/Request:

I0.(b) In the stress evaluations, the resultant moment was computed using two moment components (about vertical and transverse axes) only. NRC requires a re-evaluation using all three moment components including torsional moment in resultant moment computation.

Response

The final analysis will compute resultant moments using all three moment components.

This change is not expected to have a significant impact on the analysis results.

11.

Ouestion/Req uest:

I L.(a) For Stress Allowable at 176 'F (Enclosure 3, Attachment 10.3, page 2 of 2, Reference 1), is 340 psi considered as the allowable with DF = 0.5 for 2.5 years of continuous operation or for 30 days of continuous operation? Please provide clarification. Also, note that DF > 0.5 which corresponds to a factor of safety of less than 2 is not acceptable to the NRC.

Response

As documented in the design minimum wall thickness calculation, which is included as , the allowable stress value for 30 days of continuous operation at 175 'F is conservatively considered to be the same as the allowable stress value for 2.5 years of continuous operation at 176 'F. Also note that as the ESW operating temperature is expected to drop significantly within the first several days post-accident, the assumption that the peak post-accident operating temperature will occur continuously for 30 days is conservative.

With regard to the design factor, Ameren intends to utilize a design factor of 0.56 in lieu of 0.5. The justification for this approach is provided in Enclosure 6.

Question/Req uest:

11.(b) Are the additional loads from the buried piping side included in the design of interface anchors at the control building, UHS Control Tower, ESW pump house, ESW Yard Vaults, and others, if any? Please provide a summary of anchor loads.

Response

The anchors attach to the metallic piping, as close as practically possible to the flanged interfaces between the HDPE piping and metallic piping. The combined anchor design loads are determined in the above ground piping analysis calculations using traditional piping stress analysis software. In order to obtain loads from the HDPE side of the anchors, the computer models used in the above ground piping analysis calculations include the metallic piping on the HDPE side of the anchors up to the interface with the HDPE piping. The models also include a lumped mass at the end of the metallic piping that bounds the total weight of the HDPE transition flange, metallic flange and metallic back-up ring. The loads acting on the HDPE side and the loads acting on the metallic side of the anchor are calculated by the piping stress analysis software. A summary of preliminary combined anchor loads is provided on pages 15 and 16 of this enclosure.

Question/Request:

I .(c) For Ring Deflection Equation (page 15 of 152, Enclosure 3, Reference 1), clarify that Q, i2max are non-dimensional ring deflections' that is, a ratio of ring deflection to diameter and not ring deflection values. Since the units for vertical soil pressure due to earth load (PE) and pressure due to surcharge load (PL) seismic anchor motion (SAM) are in psf (pounds per square foot) and the units for Epipe and E' are in psi, a 1/144 factor is required.

Response

Within the preliminary analysis, the calculated and allowable ring deflections as percentages of the diameter are multiplied by the diameter to provide deflections in terms of inches. This has no impact on the results of the ring deflection evaluation. The preliminary evaluation is performed using Mathcad software. Mathcad software automatically performs unit conversions. Therefore, the inclusion of the 1/144 factor is not required.

Question/Request:

I .(d) For Flotation (page 16 of 152, Enclosure 3, Reference 1), since the units for PE are in psf, and the units for D are in inches, a 1/12 factor for the term (PE.D) is required.

Response

The preliminary evaluation is performed using Mathcad software. Mathcad software automatically performs unit conversions. Therefore, the inclusion of the 1/12 factor is not required.

Question/Request:

1 .(e) Concerning Enclosure 2 of Reference 1, please provide clarification for the terms CRS and HBD (or HDB?).

Response

The term "HBD" in Enclosure 2 of Reference I is a typo. It should be "HDB" which stands for Hydrostatic Design Basis. As defined in ASTM D-2837, hydrostaticdesign basis (HDB) - one of a series of established stress values for a compound. It is obtained by categorizing the long-term hydrostatic strength (LTHS) in accordance with Table 1.

TAB4.E $ HydroStafti DQO31n Dadt] Cutcg0904 o-m I -Te LTHS is dete'mrcld to The neamrt 10 psi. Roundimg pmoedures in Prutice E 29 should be followed.

"age at C&tulamod LTHS Vbhuos " stc Osign Basis

- {(WA) 1 06_ (MPa 190 p -C240 ( l.$3 V.,<c1,.0)1 X0 I I.

2.10 0,<30 ( 1.65 lo2.07 250 I I.72 30 lo <c 380 2,07 to < :,2) 315 4 117) 3WG10 -C480 C2.82t6 < 3,31 400 12-7611 4,0 *1 6W (.31*to < 4,$4) 9O0 3.45)

~Goo1* 70 C4,I4 * < 5,24) WD0 4.34) 7M0 l <O' T5,24 so.2}

< 6). 5.52)

200Je150._

No -4= ~120, L&___:827 6w1OL0 1<0i55*__J250 134,M, 0 L~a.___

411.D HDB = 1600 psi Z44J0 10 4 DO (1,&5 10 40'M2 2500 1l17.24) for PE 3408 &

4320 1o 4W0D C.=82 10 ,<4C40 315 (13-M PE 4710, 3=3 ib -0480 C2&.41 %a4300'W 4wo 127-U) 4800 10 SM4 P&~09 10 <4~1AZ~ 500D (34,47)

G"040 <Solo1 (41.02 to -o4&92) a" ~ M441) 68101.0t e92 (4.9 2 ito 64;W 710D 4a As defined in ASTM D2837, hydrostatic design stress (HDS)-the estimated maximum tensile stress the material is capable of withstanding continuously with a high degree of certainty that failure of the pipe will not occur. This stress is circumferential when internal hydrostatic water pressure is applied. The HDS is the product of HDB and the design factor (DF).

HDS = HDB X DF The term "CRS" stands for Categorized Required Strength. As defined in Plastics Pipe Institute (PPI) document TR-3, CategorizedRequired Strength CRS (0, t) is the Categorized Required Strength value of Olpl determined and categorized for the selected temperature (0) and required time (t) in accordance with the ISO 9080 using 3 or 4 coefficient stress rupture/time equation.

12. Enclosure 3, page 11 of 152, Reference 1, states that preliminary finite element analyses studies indicated that lower soil spring stiffness gave higher thermal stresses in buried HDPE piping and the inverse for the combined seismic wave passage and SAM controlled by SAM.

Question/Request:

Provide a simple summary table of the study runs, including a discussion of the spacing utilized for the soil springs.

Response

As discussed in EPRI document 1013549, "Design and Qualification of High-Density Polyethylene for ASME Safety Class 3 Piping Systems," most of the movements in buried piping are absorbed with a short distance (i.e. the influence length) of changes in direction. EPRI document 1013549 recommends that springs be spaced at distance of two pipe diameters (2D) within the influence length and at a distance of IOD beyond the influence length. Within the SAP2000 analysis model, springs near mitered elbows were spaced at a distance of approximately ID. All other springs (i.e. between large spans) were spaced at a distance between approximately 3D and approximately 5D As the greater the number of modeled springs, the more accurately the results will reflect the behavior of the buried pipe under the load conditions. This spacing is conservative when compared to the EPRI recommendations.

Summary tables of the study runs are provided on pages 17 and 18 of this enclosure.

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Preliminary HDPE to Metallic Piping Interface Anchor Combined Loads ESW Pumphouse 36" HDPE to 30" Metallic Piping Anchors Anchor EFI l-A003 (Train 'A' Supply)

Fx Fy Fz Mx My Mz Service Level (ls.bs) (Ibs) (f(Ibs)

(ft--bs) My (ft-lbs)

Normal (A) 0/-601 0/-9360 0/-2893 0 / -27823 5706/0 0/-3026 Upset (B) 2022/-2809 0/-10803 1706/-5573 0/-36458 14371 /-7212 8027/-13696 Faulted (D) 3920/-4707 0/-11648 3869/-7737 0/-43279 21972/-14812 17380/-23049 Anchor EFI l-A004 (Train 'B' Supply)

Fx Fy Fz Mx My Mz Service Level (l-bs) (Ibs) (Ibs) (ft-lbs) (ft-lbs) (ft-lbs)

Normal (A) 601 /0 0/-9360 0/-2893 0/-27823 0/-5706 0/-3026 Upset (B) 2817/-2030 0/-10957 1736/-5603 0/-36790 7240/-14400 13720/-8051 Faulted (D) 4722/-3935 0/-11877 3913/-7781 0/-43730 14865/-22025 23095/-17426 Control Building 36" HDPE to 30" Metallic Piping Anchors Anchor EFO1-AOO1 (Train 'A' Supply)

Fx Fy Fz Mx My Mz Service Level ((Ibs) ((Ibs) (ft-lbs) ________ (ft-lbs)

Normal (A) 0/-5300 0/-12526 3424/0 14713/0 0/-13133 4128/-478 Upset (B) 0/-6477 0/-14659 4651 /0 18503 1 0 1255/-14857 5073/-1368 Faulted (D) 695/-7237 0/-15933 5357/-647 20564/0 2207/-15808 5426/-1722 Anchor EFOI-A002 (Train '3' Supply)

FxFy Fz Mx MyMz Service Level (7bs) (Ibs) (Ibs) (ft-lbs) (ft-lbs) (ft-lbs)

Normal (A) 1896/-2594 0/-13459 4016/0 16578/0 5939/-7261 10486/-3852 Upset (B) 4453/-5151. 0/-20592 6678/-880 30837/-1027 9987/-11310 21543/-14909 Faulted (D) 5252/-5950 0/-22506 7313/-1515 34513/-4702 11479/-12801 24251/-17617 Anchor EFOI-A003 (Train 'A' Return)

Fx Fy Fz Mx My Mz Service Level (Ibs) (lbs) (Ibs) (ft-lbs) (ft-lbs) (ft-lbs)

Normal (A) 2158/-4468 0/-13851 3651/-1749 11874/0 5101/-9220 3734/0 Upset (B) 3836/-6146 0/-17408 4836/-2934 18589/-3855 8150/-12269 6812/-1776 Faulted (D) 9558/-6691 7944/-18635 5122/-7443 21157/-13443 20487/-13377 9589/-2712 Anchor EFOI-A004 (Train 'B' Return)

Fx Fy Fz NIX My Mz Service Level (Ibs) (Ibs) (lbs) (ft-lbs) (ft-lbs) (ft-lbs)

Normal (A) 441/0 0/-7760 852/0 6179/0 2973/0 0/-1408 Upset (B) 5819/-5163 0/-9638 1423/0 9156/0 8766/-3648 29646/-31892 Faulted (D) 4586/-3804 10566/-10167 1452/-7934 10324/-20224 10805 /-4160 19569/-22463

- 15-

Preliminary HDPE to Metallic Piping Interface Anchor Combined Loads (Continued)

UHS Cooling Tower 36" HDPE to 30" Metallic Piping Anchors Anchor EF I1 -AOO 1 (Train 'A' Return)

Service Level Fx (lbs)

Fy (lbs)

Fz (lbs I (ft-lbs)

Mx j My (ft-lbs) I Mz (ft-lbs)

Normal (A) 4680/-1242 0/-10095 819/-4 492 8554/-17783 0/-3195 23770 /0 Upset (B) 6082/-2644 0/-11810 3171/-( 5844 19886/-29115 5552/- 10108 30166 /0 Faulted (D) 6539/-3100 0/-12482 4155/-27828 24388 /-33617 8453 /-13009 32396 /0 Anchor EF I1 -A002 (Train 'B' Return)

Fx Fy Fz Mx My Mz Service Level (lbs) I (lbs) I (lbs) (ft-lbs) (ft-lbs) I (ft-lbs)

Normal (A) 4680 / -1242 0/-10095 819/-4492 8554/-17783 0 /-3195 23770 /0 Upset (B) 6082 / -2644 0/-11810 3171/-6844 19886 /-29115 5552 /- 10108 30166 /0 Faulted (D) 6539/-3100 0/-12482 I 4155/-7828 24388/-33617 8453 /-13009 32396 /0 ESW Pumphouse 4" HDPE to 4" Metallic Piping Anchors Anchor EF1 I-AO05 (Train 'A' Backwash)

Fx Fy Fz Mx My Mz Service Level (lbs) (lbs) (lbs) (ft-lbs) (ft-lbs) (ft-lbs)

Normal (A) 30/-35 0/-300 104/-116 0/-598 153/-96 168/0 Upset (B) 188/-193 0/-473 478/-490 386/-1461 683/-626 379/-103 Faulted (D) 229/-234 0/-518 584/-596 606/-1682 824/-767 441/-164 Anchor EFI 1-A006 (Train 'B' Backwash)

Fx Fy Fz Mx My Mz Service Level (lbs) (lbs) (lbbs) (fs-(bs) J My[s) (ft-lbs)

Normal (A) 47/-9 0/-274 141/-58 0/-634 5/-208 0/-232 Upset (B) 181/-143 0/-461 561 /-478 647/-1699 505/-708 87/-489 Faulted (D) 238/-200 0/-537 711/-629 1040/-2091 722/-925 215/-617 ESW Yard Vault 4" HDPE to 4" Metallic Piping Anchors Anchor EFI I-A007 (Train 'A' Backwash)

Fx Fy Fz Mx My Mz Service Level (lbs) (lbs) (lbs) (ft-lbs) (ft-lbs) (ft-lbs)

Normal (A) 0/0 0/-150 53/-80 18/0 57/-85 0/-39 Upset (B) 14/-14 0/-161 61/-88 29/0 71 /-99 0/-45 Faulted (D) 23/-23 0/-168 67/-93 36/0 81/-109 0/-49 Anchor EF1 I-A008 (Train 'B' Backwash)

Fx Fy Fz Mx My Mz Service Level (lbs) (lbs) (lbs) (ft-lbs) (ft-lbs) (ft-lbs)

Normal (A) 0/0 0/-138 32/-48 5/0 44/-65 17/0 Upset (B) 19/-19 0/-147 37/-53 15/-4 60/-82 19/0 Faulted (D) 31/-31 0/-153 41/-57 22/-11 71/-93 21/0 Summary of Spring Stiffness Sensitivity Runs - Seismic Case 5

Seismic Analysis Output @ 0. Kavg Seismic Analysis Output @ 2Kavg ABS(odouble @ 2Kag) -

(Half the Average Soil Sprang Stiffness Values) (Double the Average Soil Spring Sliffness Values) ABS(othaf @ 0. 5Kavg) t FRAME LOC Fa half Fbhalf Fc.half Ma.half Mb.half Uhalf qhalf Faduble Fb~double Fc.double MUadouble Mb.double Mc80oble 3double Al (kip) (kip) (kip) (ip-in) (kip-in) (kip-in) (psi) (kip) (kip) (kip) (kip-in) (kip-in) (kip-in) (psi) 1.0 0.0 -32.17 -2.88 2.70 2.16 248.42 -159.48 187.00 -65.19 -3.21 4.84 1.87 340.21 -163.95 301.03 114.03 1.0 14.5 -32.17 -2.74 2.70 2.16 209.34 -118.75 167.74 -65.19 -3.07 4.84 1.87 269.98 -118.39 271.77 104.03 1.0 29.0 -32.17 -2.59 2.70 2.16 170.25 -80.09 149.19 -65.19 -2.93 4.84 1.87 199.75 -74.91 242.99 93.80 2.0 0.0 -32.17 -2.59 2.70 2.16 170.25 -80.09 149.19 -65.19 -2.93 4.84 1.87 199.75 -74.91 242.99 93.80 2.0 18.0 -32.17 -1.94 2.70 2.16 121.73 -39.25 127.91 -65.19 -2.28 4.84 1.87 112.57 -28.07 208.62 80.71 38.0 57.3 -11.98 -4.75 0.24 14.49 16.54 249.26 207.56 -13.51 -4.13 0.12 6.92 6.87 235.48 201.24 -6.32 39.0 0.0 -11.82 5.12 0.22 -2.00 21.94 249.26 207.16 -12.47 6.65 0.10 -0.47 9.75 235.48 198.55 -8.61 26.0 72.0 -10.61 0.51 -3.72 -4.07 234.17 19.12 193.29 -12.79 0.62 -4.01 -3.36 221.57 14.57 189.77 -3.52 27.0 0.0 -10.13 0.51 4.87 10.64 234.17 16.40 192.06 -11.88 0.62 6.21 7.93 221.57 12.68 187.42 -4.64 14.0 43.0 -9.48 -0.54 4.59 -3.09 -218.94 2.68 179.06 -11.44 -0.58 5.73 1.42 -223.10 6.17 187.09 8.03 NOTES:

1) All forces and moments are from SAP2000 output and are in local coordinates where a=axial, b=vertical and c=transverse.

2) Only ten highest stress locations are summarized.

3) Stress intensification factor of 2.0 used for mitered elbow locations and 1.0 for straight pipe locations.

Summary of Spring Stiffness Sensitivity Runs - Thermal Case Thermal Analysis Output @ 0.5K,,g Thermal Analysis Output @ 2Kn., ABS(ohalf @ 0.5Kavg) -

2 (Half the Aerage Soil Spring Stiffness Values) (Double ItheAerage Soil Spring Stiffness Values) ABS(Od-oube @ Kv,)

FRAME LOC Fa half Fb half Fe.half Matha)f Mb.Sial Me.halft h)alf Fa double Fb.double Fe.doubl Ma.double Mb.doubl¢ Me~doubl I double A (kip) (kip) (kip) (kip-in) (kip-in) (kip-n) (psi) (kip) (kip) (kip) (kip-in) (kip-in) (kip-in) (psi) 38.00 57.31 -49.86 -15.80 0.46 28.82 21.23 828.82 714.26 -51.38 -13.27 -0.16 10.48 5.04 747.91 660.53 53.73 39.00 0.00 -46.40 24.15 0.36 3.58 35.40 828.83 705.35 -45.68 27.01 -0.25 2.26 10.98 747.91 645.87 59.48 26.00 72.01 -45.94 0.58 -14.41 -3.28 797.97 19.85 682.02 -50.25 0.65 -13.74 -2.88 725.58 13.63 641.88 40.14 15.00 0.00 -43.67 -0.75 -14.54 -3.28 -803.15 -6.67 679.67 -47.48 -0.61 -14.38 -2.88 -750.49 5.54 652.28 27.39 27.00 0.00 -42.68 0.58 22.30 11.72 797.97 16.36 673.62 -45.25 0.65 25.82 7.61 725.58 11.67 629.03 44.59 14.00 42.96 -41.16 -0.75 20.60 -7.03 -803.15 -2.39 673.22 -43.74 -0.61 23.41 1.88 -750.49 5.95 642.66 30.56 47.00 0.00 -47.23 -0.05 19.84 3.31 760.15 -2.26 658.44 -50.50 -0.03 21.27 3.05 659.35 -0.64 595.65 62.79 46.00 36.07 -47.15 -0.05 -20.04 3.93 760.15 0.80 658.22 -50.45 -0.03 -21.39 2.58 659.35 1.74 595.52 62.70 37.00 0.00 -45.61 -18.27 1.10 28.90 86.65 -759.26 657.49 -50.10 -19.16 1.67 10.57 55.93 -727.53 644.34 13.15 36.00 41.03 -45.18 19.30 1.10 -40.77 81.74 -759.26 656.39 -48.99 21.85 1.67 -32.04 47.04 -727.53 641.49 14.90 NOTES:

1) All forces and moments are from SAP2000 output and are in local coordinates where a=axial, b-=vertical and c-transverse.

2) Only ten highest stress locations are summarized.

3) Stress intensification factor of 2.0 used for mitered elbow locations and 1.0 for straight pipe locations.

To ULNRC-05517 Enclosure 3 Letter from Dow Chemical Company (with attachments)

Z. Jimmy Zhou, Ph. D The Dow Chemical Company Plastics TS&D NA 2301 N. Brazosport Blvd.

Freeport, TX 77541 June 24, 2008 Mr. Matthew D. Brandes Mechanical Design Engineer Nuclear Engineering Callaway Plant Ameren UE PO Box 620, CA-460 Fulton, MO 65251

Dear Mr. Brandes,

The purpose of this letter is to share the fusion qualification data of CONTINUUM DGDA 2490 and DGDA 2492 using the fusion procedure of PPI TR-33, Generic Butt Fusion Joining Procedure for Field Joining of Polyethylene Pipe. Attached are the fusion qualification and testing reports.

The fusion temperature window in PPI TR-33 is from 400 'F to 450 'F. The interfacial stress is from 60 psi to 90 psi. Fusion tests have been done at the four comers of the fusion window: 400 'F/60 psi, 400 'F/90 psi, 450 'F/60 psi, and 450 'F/90 psi to cover all the fusion conditions. The pipe samples used range from 1" up to 22". The fusion joints were made by McElroy, the fusion machine manufacturer, the pipe and fittings manufacturers, the installation contractors, as well as Dow Chemical. The evaluation and testing of the joints were conducted by fusion machine manufacturer, independent testing firms, pipe and fitting manufacturers, contractors, and Dow Chemical as well. The joint test ranges from tensile, impact tensile, quick burst, sustained pressure testing (up to more than 1 years testing at elevated temperatures). The failures of the sustained pressure testing samples were on the pipe section, not in the joints.

PPI TR-33 fusion procedure has been used for DGDA 2490/2492 pipe since 2002 for natural gas pipe, oil and gas collection, industrial pipe, and mining applications without any issues.

Based on the fusion testing data and the field application experience, high quality fusion joints can be made for DGDA 2490/2492 pipe using PPI TR-33. The field conditions vary, which include the ambient temperatures and wind variables. The specific fusion condition may be selected based on the specific job environment. However, the PPI TR-33 fusion window shall cover all the application conditions so that high quality joints are made.

If you have any questions or comments, please do not hesitate to call me.

Yours very truly, Z. Jimmy Zhou Z. Jimmy Zhou Sr. Development Specialist (979) 238-7410 (office)

(281) 467-8659 (cell) zjzhou@dow.com

Attachment:

1. CONTINUUM DGDA 2490 Gas Pipe Qualification

2. McElroy Fusion Qualification Report

3. 8" Pipe Fusion Testing Report

4. "New Products, New Horizons: HDPE Resins for Natural Gas Piping" CC: Lonnie J. Corley, Construction Supervisor, Ameren UE

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 1 of 59 TECHNICAL REPORT ContinuumT Bimodal Polyethylene Resins fl000 0 1[0111 CONTINUUM* DGDA-2490 BK 100 For Natural Gas Pipe and Fittings Compliance with ASTM D2513-04 "Standard Specification for the Thermoplastic Gas Pressure Pipe, Tubing and Fittings" PPI TR-33 "Generic Butt Fusion Joining Procedure for Polyethylene Gas Pipe" PPI TR-41 "Generic Saddle Fusion Joining Procedure for Polyethylene Gas Pipe",

And Department of Transportation (DOT) CFR49, Part 192

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 2 of 59 TABLE OF CONTENTS

1. Scope 5

2. References 5

3. Summary 6

4. Analysis/Discussion 6 4.1 General 6 4.2 Material Requirements 6 ASTM D 2513-04 Section:

4.1 General 6 A1.3.1 Classification 6 A1.3.2 Short and Long Term Properties 6 A1.3.3 Hydrostatic Design Basis (HDB) Substantiation 7 A1.3.4 Qualification for LPG Service 7 A1.3.5 Slow Crack Growth (SCG) Resistance 7 A1.3.6 Additive Classes 7 ISO 4437 Table 1 7 Rapid Crack Propagation (RCP) Resistance 4.3 Requirements for Pipe and Fittings 7 ASTM D 2513-04 Section:

5.1 General 7 5.2 Workmanship 7 5.3 Pipe and Tubing Dimensions 7 5.4 Sustained Pressure 7 ISO 4437 Table 6 8 Hydrostatic Strength ASTM D 2513-04 Section:

5.5 Elevated Temperature Service 8 X3.5.1 Elevated Temperature Service 8 A1.5.1 Conditioning 8 A1.5.2 Minimum Hydrostatic Burst, Pressure/

Apparent Tensile Strength (Quick Burst) 8 A1.5.3 Sustained Pressure 73F (123C) 8 A1.5.4 Melt Index 8 A1.5.6 Thermal Stability 8 A1.5.7 Outdoor Storage Stability 8 A1.5.8 Dimensions and Tolerance, See 5.3 8

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 3 of 59 A1.5.9 Short Term Pressurization for Sizes above 12" 9 A1.5.10 HDB Validation of PE Pipe 9 A1.5.11 Inside Surface Ductility for Pipe 9 A1.5.11.2 Elongation at Break Test Method 9 A1.5.11.3 Thermal Stability Test Method 9 4.4 Fusion Qualification 9 4.4.1 PPI TR-33 Qualification 9 4.4.2 PPI TR-41 Qualification 10 4.5 Fitting Qualification 10 4.5.1 ASTM D3261-97 Qualification 11 4.5.2 PPI TR-33 Qualification 11

5. Conclusion 11 Appendix A: Data for Material Qualification 13 HDB Listing 14 MRS Listing 14 CRS (0, t) Listing 14 Cell Classification ASTM D 3350 15 PENT Data 15 S-4 RCP Property 15 Appendix B: Data for Pipe and Fittings 16 Dimensions and Tolerance 17 OIT 17 Sustained Pressure Test at 231C 18 Elevated Temperature Service (80C) 18 Quick Burst of Butt Fusion 22" SDR 9 made by Rinker 19 Fusion Welds by Michigan Pipe 21" SDR 11 19 HDB Validation 231C 20 HDB Validation 601C 21 Appendix C: Data for Fusion Qualification 22 Cross Fusion Qualification Cross Fusion of 1" SDR 11 with PE 2406 and PE 3408

@ 231C, 1600 psi and 80'C, 670 psi 23 Jana Laboratories Report on Fusion 24 Mc Elroy Mc Snapper TM Fusion Welds 32 Uponor Saddle Fusion (Quick Burst Test) 38 Uponor Saddle Fusion (Knock-Out Test) 39 Appendix D: Data for Fitting Qualification 40 Fitting Testing Qualification HDB A-2490/A-2490, 801C, 800 psi 41 HDB A-2490/A-2490, 901C, 725 psi 42

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 4 of 59 Perfection's Trials of Tapping Tees 42 Appendix E: Technical Reports on DGDA-2490 Pipes from Other Sources 43 Becetel Report 5179 44 Uponor Technical Lab Report 48 UAC 3700 (A-2490) 2" Pipes Sustained Pressure ASTM D 1598 (80 0 C) 49 Sustained Pressure ASTM D 1598 (231C) 49 Quick Burst ASTM 1599 49 Dimension Specifications 49 Yellow 8300 to UAC 3700 Tap Tee Saddle Fusion (D.O.T. 192.283)

Short Term Burst Test ASTM D 1599 50 Impact Resistance ASTM F 905 50 UAC 3700 Pipe to Drisco 8100 pipe Butt Fusion (D.O.T. 192.283)

Short Term Burst Test ASTM D 1599 (500°F fusion) 51 Tensile Elongation ASTM D 638 51 Short Term Burst Test ASTM D 1599 (450'F fusion) 51 Tensile Elongation ASTM D 638 51 UAC 3700 Pipe to UAC 3700 Pipe Butt Fusion (D.O. T 192.283)

Short Term Burst Test ASTM D 1599 (500°F fusion) 52 Tensile Elongation ASTM D 638 52 Short Term Burst Test ASTM D 1599 (450'F fusion) 52 Tensile Elongation ASTM D 638 52 UAC 3700 Pipe to UAC 3700 Socket Coupling (D.O.T. 192.283)

Short Term Burst Test ASTM D 1599 (500'F fusion) 53 Tensile Elongation ASTM D 638 53 UAC 3700 Pipe to UAC 3700 Tap Tee Saddle Fusion (D.O.T. 192.283)

Short Term Burst Test ASTM D 1599 54 Impact Resistance ASTM F 905 54 Drisco 8100 Pipe to UAC 3700 Socket Coupling (D.O.T. 192.283)

Short Term Burst Test ASTM D 1599 (5001F fusion) 55 Tensile Elongation ASTM D 638 55 Drisco 8100 to UAC 3700 Tap Tee Saddle Fusion (D.O.T. 192.283)

Short Term Burst Test ASTM D 1599 56 Impact Resistance ASTM F 905 56 Yellow 8300 to UAC 3700 Tap Tee Saddle Fusion (D.O.T. 192.283)

Short Term Burst Test ASTM D 1599 57 Impact Resistance ASTM F 905 57 Yellow 8300 to UAC 3700 Socket Coupling (D.O.T. 192.283)

Short Term Burst Test ASTM D 1599 58 Tensile Elongation ASTM D 638 58 UAC 3700 Pipe to Yellow 8300 Pipe Butt Fusion (D.O.T. 192.283)

Short Term Burst Test ASTM D 1599 (500'F fusion) 59 Tensile Elongation ASTM D 638 59 Short Term Burst Test ASTM D 1599 (450'F fusion) 59 Tensile Elongation ASTM D 638 59

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 5 of 59

1. Scope 1.1 The scope of this document is to provide data that the pipe manufactured from Dow CONTINUUM DGDA-2490 Bimodal Resin is in compliance with ASTM D2513-04 for natural gas distribution as a PE3408 pipe. The resin also meets the requirements in ASTM D 2513-04 Appendix X3 and ISO 4437 as a PE 100 gas pipe. In addition, the heat fusion of DGDA-2490 pipe has been qualified per the Department of Transportation (DOT) CFR 49, Part 192, §192.273(b) and

§192.283.

1.2 The butt fusion of DGDA-2490 pipe to other materials has proven to be acceptable using the same testing protocol as documented in the Plastics Pipe Institute (PPI) Technical Report (TR) 33, "Generic Butt Fusion Joining Procedure for Polyethylene Gas Pipe".

1.3 The saddle fusion of PE 2406 and PE 3408 materials to DGDA-2490 pipe has proven to be acceptable using the same testing protocol as documented in PPI TR-41, "Generic Saddle Fusion Joining Procedure for Polyethylene Gas Pipe".

1.4 This document is intended to qualify CONTINUUM DGDA-2490 Bimodal Resin for natural gas piping. The pipe samples used were from several pipe manufacturers. Dow Pipe Technology Center, independent testing firms, pipe manufacturers, and contractors generated the data.

1.5 This document is not intended to qualify any specific pipe manufacturers although pipe samples made from several pipe manufacturers were used. Qualification of pipe and fittings made by a given pipe manufacturer needs to use all samples from the same pipe manufacturer.

2. References 2.1 The following references are applicable to this report:

ASTM D 2513-04, "Standard Specification for the Thermoplastic Gas Pressure Pipe, Tubing and Fittings" ISO 4437:1997, "Buried Polyethylene (PE) Pipes for the Supply of Gaseous Fuels - Metric Series - Specifications" PPI TR-33, "Generic Butt Fusion Joining Procedure for Polyethylene Gas Pipe" PPI TR-41, "Generic Saddle Fusion Joining Procedure for Polyethylene Gas Pipe" DOT CFR 49, Part 192, §192.273, §192.283, §192.285

Attachment 1 - Dow letter to Ameren dtd 6-24-08 6 Page 6 of 59

3. Summary 3.1 The documentation of materials and the test results contained herein indicate that CONTINUUM DGDA-2490 piping products meet the requirements of ASTM D 2513-04, PPI TR-33 and PPI TR-41.

3.2 For qualification under PPI TR-33, butt fusions were made from samples using CONTINUUM DGDA-2490 pipe. The butt fusion joints included like and unlike materials under the parameters of TR-33 and proved to be successful joints.

3.3 Saddle fusions were qualified in accordance with PPI TR-41 by preparing samples of "unlike" materials and tested in accordance with DOT CFR 49, Part 192. All fusions proved to be successful joints.

3.4 Becetel in Belgium conducted the S-4 Rapid Crack Propagation (RCP) test on 10" SDR 11 pipe. The critical temperature was -1 7C at the internal pressure of 10 bar, meeting ISO 4437 requirement and the requirement in Northeast Gas Utilities End Use Specification. ASTM F 2231, the modified Charpy test for measuring RCP property, is used as a quality control method for RCP resistance.

3.5 PENT test was conducted on CONTINUUM DGDA-2490 resin materials. All samples had >6000 hour PENT, meeting the requirement of 500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months in Northeast Gas (NE) Utilities End Use Specification and ASTM D 2513-04.

Accelerated PENT at 3 MPa is used as a quality control method for SCG resistance.

4. Analysis/Discussion 4.1 General The following section numbers used correspond to the applicable section numbers as listed in ASTM D 2513-04. It includes the requirements in the main body for plastic pipe and fittings and the additional requirements as listed in Annex Al and Appendix X3 for PE gas pipe and fittings. Each requirement includes the supporting documents with a brief explanation of results. The documents are attached as Appendices to this document.

4.2 Material Requirements (see Appendix A)

ASTM D 2513-04 Section:

4.1 General DGDA-2490 pipe material is listed by PPI as PE 3408 and PE 100 pipe.

A 1.3.1 Classification DGDA-2490 material is classified in accordance with ASTM D 3350 with cell classification of 345564C and meets the requirements of Table A1.2 of D 2513-04.

A1.3.2 Short and Long Term Properties Material has shown to meet the requirements of Table 1.3 as a PE 3408.

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 7 of 59 A 1.3.3 HydrostaticDesign Basis (HDB)Substantiation Pipe product has been substantiated in accordance with ASTM D 2837.

Asterisk (*) listing is granted by PPI (See PPI TR-4) for meeting the substantiation of linearity of long term hydrostatic strength (LTHS) at 73 0F for 50 years.

A 1.3.4 Qualificationfor LPG Service Pipe product has been qualified in accordance with A1.3.3 and carries a recommended HDB at 140'F for 1000 psi in accordance to Section 5.6 of D 2513-04.

A 1.3.5 Slow Crack Growth Resistance Samples subjected to conditions in ASTM F 1473 per this specification exceed an average of 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months as shown by the attached test data. In addition, they also exceed the 500-hour requirement in the NE Utilities End Use Specification.

A 1.3.6 Additive Classes Pipe specimens meet the requirements of Class C as defined in ASTM D 3350 as shown by the attached test data.

ISO 4437 Table 1 Rapid Crack Propagation(RCP)Resistance S-4 test data from Becetel, Belgium exceed the critical pressure requirement of 4.2 bar for PE 100 pipe. They also exceed the critical temperature requirement of 20°F by the NE Gas Utility End Use Specification.

4.3 Requirements for Pipe and Fittings (see Appendix B)

ASTM D 2513-04 Section:

5.1 General Product is supplied in either coils or straight lengths.

5.2 Workmanship The pipe is homogeneous throughout and free of visible cracks, holes, foreign inclusion, blisters, dents or other injurious defects.

5.3 Pipe and Tubing Dimensions Dimensions for pipe samples are specified by wall thickness and outside diameter (see Appendix B). Quality pipe made from DGDA-2490 meets the requirements for diameters, toe-in, wall thickness, wall thickness eccentricity range, and ovality.

5.4 SustainedPressure The pipe does not fail as defined in Test Method D 1598 when tested in accordance with 6.6 of ASTM D 2513-04 (Refer to A1.5.3 above). In addition, elevated sustained pressure testing was performed at 176°F per ASTM D 1598 with specimens subjected to a hoop stress of 670 + 10 psi with no loss in pressure for a test duration of 170 hours0.00197 days 0.0472 hours 2.810847e-4 weeks 6.4685e-5 months . Test results for both sustained and elevated pressure tests are located in Appendix B.

DGDA-2490 pipe exceeds the requirements.

Attachment 1 - Dow letter to Ameren dtd 6-24-08 8 Page 8 of 59 ISO 4437 Table 6 HydrostaticStrength PE 100 pipe shall not fail before 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months at 20 0C and 1800 psi, 165 hours0.00191 days 0.0458 hours 2.728175e-4 weeks 6.27825e-5 months at 800C and 800 psi, and 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months at 80'C and 670 psi. DGDA-2490 exceeds the requirements.

ASTM D 2513-04 Section:

5.5 Elevated Temperature Service PPI Hydrostatic Design Basis (HDB) has been determined in accordance with Test Method D 2837 for use of material up to 140°F (60'C). Material has been categorized as CEC (or CEE) in accordance with Table 4 of ASTM D 2513-04.

X3.5.1 Elevated Temperature Service In addition to MRS classification using the ISO 12162 standard conditions of 20'C and 50 years, the MRS can be determined at other desired temperature or time conditions as denoted by MRS (0, t). The MRS (0, t) is the categorized MRS value for a material at a temperature of 0 'C and a time of t years. In addition to the pipe category per table 4 of ASTM D 2513-04, the pipe category using the MRS designation as noted in Table X3.2 may be used. DGDA-2490 pipe has been categorized as CJC (or CJE) in accordance with Table X3.2 of ASTM D2513-04. (Note that ISO and PPI have changed MRS (0, t) to CRS (0, t))

A1.5.1 Conditioning Samples were conditioned in accordance with 6.3 when conditioning of samples was required.

Al .5.2 Minimum HydrostaticBurst Pressure/ApparentTensile Strength (Quick Burst)

Pipe samples failed in a ductile manner when tested in accordance with ASTM D 1599 as shown by the attached test data (See Appendix B).

A1.5.3 Sustained Pressure73OF (230C)

Pipe samples did not fail in less than 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months when tested in accordance with ASTM D 1598. As shown by the attached test data, pipe specimens were subjected to stress of 1600 psi (See Appendix B).

Al.5.4 Melt Index Melt index of pipe complies with Table 4 and listing of pipe category CEC (or CEE) (See Appendix B).

A1.5.6 Thermal Stability Pipe exceeds minimum induction temperature of 428°F (220'C) when tested in accordance with ASTM D 3350 (See Appendix B).

A1.5.7 Outdoor Storage Stability Pipe specimens meet the requirements of this specification; therefore, they are suitable for storage exceeding two years from date of manufacture.

A 1.5.8 Dimensions and Tolerance See 5.3

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 9 of 59 A 1.5.9 Short Term Pressurizationfor Sizes above 12" Pipe, molded and fabricated fittings shall not fail when tested in accordance with Test Method D 1599 with the hoop stress of 2900 psi for Class 3 density materials. Pipe made from DGDA-2490 exceeds this requirement (See Appendix B).

A1.5.10 HDB Validation of PE Pipe HDB at 73°F and 140'F was validated using the pipe specimens made by several pipe manufacturers per ASTM D 2837. Validating 1000 psi HDB at 140°F per PPI TR-3 and ASTM D 2837 validated the 1600-psi HDB at 73 0 F.

A 1.5.11 Inside Surface Ductilityfor Pipe Samples were conditioned in accordance with D 618 before testing in accordance with A1.5.11.1, A1.5.11.2 and A1.5.11.3 A 1.5.11.2 Elongation-At-Break Test Method Percentage of elongation for specimens exceeds 400% for each test specimen.

A 1.5.11.3 Thermal Stability Test Methods See A1.5.6 4.4 Fusion Qualification (see Appendix C)

The following analysis/discussion lists the supporting documents with a brief explanation to support the qualification of CONTINUUM DGDA-2490 pipe according to the generic butt fusion procedure, PPI TR-33.

4.4.1. Plastics Pipe Institute TR-33 This report describes the scope, testing program for the evaluation of pipe fusion of like and unlike materials, pipe sizes, conclusion, resin types, pipe manufacturers and the generic buff fusion procedure itself.

The following butt fusion combinations were made per the guidelines of TR-33:

1" SDR 11 DGDA-2490 pipe with 1" SDR 11 CP TR 418 PE 2406 pipe 1" SDR 11 DGDA-2490 pipe with 1" SDR 11 Atofina 3344 PE 3408 pipe 1" SDR 11 DGDA-2490 pipe with 1" SDR 11 Drisco 8100 PE 3408 pipe These fusions were subjected to the testing programs of TR-33 for evaluation of the butt fusions. This included the following testing procedures:

ASTM D 1599-99 "Resistance to Short-Time Hydraulic Pressure of Plastic Pipe, Tubing and Fittings" ASTM D 1598-02 "Time-to-Failure of Plastic Pipe under Constant Internal Pressure" ASTM D 638-01 "Tensile Properties of Plastics"

Attachment 1 - Dow letter to Ameren dtd 6-24-08 59 Page 10 of ASTM D 1822-99 "Tensile-Impact Energy to Break Plastics and Electrical Insulating Materials" The results of the above references testing standards are located in Appendix C of this report.

The following analysis/discussion lists the supporting documents with a brief explanation to support the qualification of CONTINUUM DGDA-2490 pipe according to the generic saddle fusion procedure, PPI TR-41.

4.4.2 PlasticsPipeInstitute TR-41 This report describes the scope, testing program for the evaluation of pipe fusion of like and unlike materials, pipe sizes, conclusions, resin types, pipe manufacturers and the generic saddle fusion procedure itself.

The following saddle fusions were made per guidelines ofTR-41:

Quick Burst Test Saddle Fusion Tap Tee 2" SDR 11 Pipe End Cap

_._Material Fusion Type DGDA-2490 BK 100 DGDC-2480 3408 Solvay K44-08-123 Socket DGDA-2490 BK 100 DGDC-2480 3408 Solvay K44-08-123 Butt DGDA-2490 BK 100 Atofina 3344 PE 3408 Solvay K44-08-123 Socket DGDA-2490 BK 100 UAC 2000 (TR-418) TR-418 Socket Knock-Out Test Saddle Fusion Tap Tee 2" SDR 11 Pipe DGDA-2490 BK 100 DGDC-2480 BK 3408 DGDA-2490 BK 100 DGDC-2480 BK 3408 DGDA-2490 BK 100 Atofina 3344 PE 3408 CP TR-480 PE 3408 DGDC-2480 BK 3408 CP TR-480 PE 3408 DGDC-2480 BK 3408 These *fusions were subjected to the testing program of TR-41 for evaluation of the saddle fusions. This included the following testing procedures:

ASTM D 1598-02 "Time-to-Failure of Plastic Pipe under Constant Internal Pressure" The results of the above references testing standard are located in Appendix Cof this report.

4.5 Fitting Qualification (see Appendix D)

The following analysis/discussion lists the supporting documents with a brief explanation to support the qualification of CONTINUUM DGDA-2490 material according to the requirements of ASTM D 3261-97 and the generic butt fusion.

procedure, PPI TR-33.

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 11 of 59 4.5.1 ASTMD3261-97 This specification covers polyethylene (PE) butt fusion fittings for use with polyethylene pipe (IPS and ISO) and tubing (CTS). Included are the requirements for materials, workmanship, dimensions, marking, sustained pressure, and burst pressure.

4.5.2 PlasticsPipe Institute TR-33 This report describes the scope, testing program for the evaluation of pipe fusion of like and unlike materials, pipe sizes, conclusion, resin types, pipe manufacturers and the generic buff fusion procedure itself.

The following butt fusion combinations were made per the guidelines of TR-33:

1" SDR 11 DGDA-2490 fitting to 1" SDR 9 DGDA-2490 pipe 2" SDR 11 DGDA-2490 fitting to 2" SDR 9 DGDA-2490 pipe These fusions were subjected to the testing programs of TR-33 for evaluation of the butt fusions. This included the following testing procedures:

ASTM D 1599-99 "Resistance to Short-Time Hydraulic Pressure of Plastic Pipe, Tubing and Fittings" ASTM D 1598-02 "Time-to-Failure of Plastic Pipe under Constant Internal Pressure" ASTM D 638-01 "Tensile Properties of Plastics" ASTM D 1822-99 "Tensile-Impact Energy to Break Plastics and Electrical Insulating Materials" The results of the above references testing standards are located in Appendix C of this report.

5. Conclusion From the data that are presented in this reporf, CONTINUUM DGDA-2490 bimodal material exceeds the requirements of ASTM D 2513-04 as PE 3408 pipe. It also exceeds the key performance requirements in ISO 4437 for PE 100 pipe. In addition, it meets the requirements listed in the Northeast Gas Utility End Use Specification for operation pressures, operation temperatures, SCG resistance, and RCP resistance.

From the data that are presented in this report, samples of pipes extruded from a compound of 93.5% CONTINUUM DGDA-2490 and 6.5% DFNF-0092 from PolyOne or Ampacet by several pipe manufacturers have shown to meet or exceed the requirements of ASTM D 2513-04 as PE 3408 pipe. It also exceeds the key performance requirements in ISO 4437 for PE 100 pipe.

In addition, the butt fusion that were made with like and unlike materials met the requirements of TR-33, "Generic Butt Fusion Joining Procedure for Polyethylene Gas

Attachment 1 - Dow letter to Ameren dtd 6-24-08 12 Page 12 of 59 Pipe." Saddle fusions also proved to be acceptable per requirements of DOT, CFR 49, Part 192, §192.283 and met the requirement of PPI TRY41, "Generic Saddle Fusion Joining Procedure for Polyethylene Gas Pipe."

From the data that are presented in this report, samples of fittings made, by Central Plastics, Rahn Plastics and Perfection from black CONTINUUM DGDA-2490 material (93.5% DGDA-2490 NT resin and 6.5% DFNF-0092 black masterbatch) met the requirements of ASTM D 3261, "Butt Heat Fusion Polyethylene (PE) Plastic Fittings for Polyethylene (PE) Plastic Pipe and Tubing" and PPI TR-33, "Generic Butt Fusion Joining Procedure for Polyethylene Gas Pipe".

Natural gas pipe and fittings manufactured from this material shall have a PPI dependent listing supported by The Dow Chemical Company and granted by PPI. It shall be marked in accordance with ASTM D 2513-04 Section 7.1 and A1.6.1. The pipe shall be identified by a trade name of the pipe manufacturer that is listed by PPI.

Attachment 1 - Dow letter to Ameren dtd 6-24-08 13 Page 13 of 59 APPENDIX A DATA FOR MATERIAL QUALIFICATION

Attachment 1 - Dow letter to Ameren dtd 6-24-08 14 Page 14 of 59 Plastics Pipe Institute (PPI) TR-4 Pressure Rating Listing HDB Listing CONTINUUM DGDA-2490 BK 100 is listed in Plastics Pipe Institute (PPI) TR-4 as a PE 3408 pipe material with 1600 psi HDB at 73°F. As indicated by the asterisk listing

(*), it is validated for the linearity of the long term hydrostatic strength (LTHS) at 73°F for 50 years. In addition, it has 1000 psi HDB at 140'F.

Company Name Material Designation, Temp. j 111DB Grade Expiration (F)- (psi) Date Dow Chemical Co CONTINUUM DGDA 2490 BK 100 73 1600 S* 12/31/05 Dow Chemical Co CONTINUUM DGDA 2490 BK 100 140 1000 S 12/31/05 MRS Listing Company Name Material Designation Temperature HDB Grade Expiration (F) (psi) - Date Dow Chemical Co CONTINUUM DGDA 2490 BK 100 68 10 S 12/31/05 CRS (0, t) Listing For design purposes, the CRS (0, t) may be determined at other desired temperatures (0) or time (t) conditions. The CRS (0, t) is the categorized value of the ISO 9080 O7pl for a material at a temperature of 0 F (°C) and a time oft years, using the extrapolation limits of ISO 9080.

Company Name- Material Designation Temp (F) Time. CRS Grade Expiration (years) . _ Date Dow Chemical Co CONTINUUM DGDA 2490 68 100 10 S 12/31/06 BK 100 (20 C, 100 years)

Dow Chemical Co CONTINUUM DGDA 2490 105 90 8 S 12/31/06 BK 100 (40 C, 90 years) II Dow Chemical Co CONTINUUM DGDA 2490 140 11 6.3 S 12/31/06 BK 100 (60 C, Ilyears)

Attachment 1 - Dow letter to Ameren dtd 6-24-08 15 Page 15 of 59 Cell Classification in Accordance with ASTM D 3350 Property Test Method Value Cell Classification

-per ASTM.3350 Density, g/cc ASTM D 1505 0.949 3 Melt Index, 12 ASTM D1238 0.08 4 Flexural Modulus, MPa (psi) ASTM D 790, method 1, 1034 5 Procedure B (150,000)

Tensile strength at yield, MPa (psi) ASTM D 638 24.8 (3600) 5 Slow Crack Growth PENT (hours), molded plaque, 80'C, ASTM F 1473 >6000 6 2.4 MPa Hydrostatic Design Classification HDB, psi (73°F) ASTM D 2837 1600 4 MRS, MPa (20'C) ISO 9080 10 6 PENT Data Test done by Dow Year Tested Resin Blend number PENT Specimen (hours) 2.4 MPa and 80 0C DGDA-2490 9,451 DGDA-2490 8,832 on test DGDA-2490 9,042 on test DGDA-2490 9,271 on test DGDA-2490 9,049 Stopped, non-failure DGDA-2490 9,049 Stopped, non-failure DGDA-2490 9,050 Stopped, non-failure DGDA-2490 9,050 Stopped, non-failure DGDA-2490 24,900 on test S-4 RCP Property Material Designation Tc, *C Pc, bar Pc, bar ISO 13477 IS0443" ISO 13477 DGDA-2490 < -17 4.2 > 12

Attachment 1 - Dow letter to Ameren dtd 6-24-08 16 Page 16 of 59 APPENDIX B DATA FOR PIPE AND FITTINGS

Attachment 1 - Dow letter to Ameren dtd 6-24-08 17 Page 17 of 59 Dimensions and Tolerance 2" DGDA-2490 pipes made by Uponor Actual Maximum Minimum Ma xiium .Minimuuil Outof- ,

"Saiple.# 'OD, in [ OD ,in .01j,in.: Wall; in,. - in-,

. 'Round -i'Q aity: E itrify 1 2.378 2.380 2.375 0.234 0.225 0.005 0.2% 3.8%

2 2.378 2.380 2.375 0.232 0.226 0.005 0.2% 2.6%

4" DGDA-2490 pipes made by Rinker Materials Maximum Minimum Maximum Minimum 2)ActuraJ OUt-of-dSampe#

OD, in OD,. in 1OD, in Wallin Wall, in '.Round

.. Q.valit*. ,Eccienf*rly 1 4.510 4.515 4.505 0.455 0.412 0.010 0.2% 9.5%

2 4.510 4.515 4.505 0.450 0.409 0.010 0.2% 9.1%

6" DGDA-2490 pipes made by Rinker Materials

-Actural J MaXimun Mifimumim 'Miximuinm MinimUm 'Oiit~ofz . .] .

Sample . 0D1'. ODD:i

. in 'D ini.-i Wall, in : w in :Rond vOlity§ Ecnhicit3 1 6.628 6.629 6.626 0.653 0.622 0.003 0.0% 4.7%

2 6.628 6.629 6.626 0.652 0.620 0.003 0.0% 4.9%

OIT@ 210 C: 43 minutes

Attachment 1 - Dow letter to Ameren dtd 6-24-08 18 Page 18 of 59 ASTM D 2513-04, Section 5.5 Sustained Pressure Since pipes do not fail at 1600psi, ISO 4437 test condition for PE 100 is used (1800 psi @ 23 0 C for PE 100)

Pipe samples were made by Dow Chemical, Oil Creek, Performance Pipe, Rinker Materials, CO-EX and Quail Date Wall 0. D. (in) Line Pressure Hoop Stress Failure Time Type of Failure Thickness (in) (psi) (psi) (hours)

June 2000 0.130 1.315 395 1800 173 Non-Failure June 2000 0.130 1.315 395 1800 173 Non-Failure June 2000 0.130 1.315 395 1800 173 Non-Failure July 2001 0.125 1.315 378 1800 349 Ductile July 2001 0.125 1.315 378 1800 333 Ductile July 2001 0.125 1.315 378 1800 435 Ductile October 2002 0.121 1.319 364 1800 110 Non-Failure October 2002 0.121 1.319 364 1800 181 Non-Failure October 2002 0.121 1.319 364 1800 102 Non-Failure ASTM D 2513-04, Section 5.6 Elevated Temperature Service Since pipes do not fail at 670psi, ISO 4437 test condition for PE 100 is used Pipe samples were made by Dow Chemical, Oil Creek, Performance Pipe, Rinker Materials, CO-EX and Quail (800 psi @ 801C for PE 100)

Date Wall 0. D. (in) Line Pressure Hoop Stress Failure Time ':Type of Failure Thickness(in) , (psi). (psi). (hours). "

March 2000 0.125 1.305 169 800 10,852 Non-Failure March 2000 0.125 1.305 169 800 10,908 Non-Failure March 2000 0.125 1.305 169 800 10,946 Non-Failure April 2000 0.121 1.305 163 800 5,754 Ductile April 2000 0.121 1.305 163 800 5,569 Non-Failure April 2000 0.121 1.305 163 800 5,982 Non-Failure July 2000 0.130 1.315 175 800 3,012 Ductile July 2000 0.130 1.315 175 800 10,699 Non-Failure July 2000 0.130 1.315 175 800 8,200 Ductile August 2001 0.125 1.315 168 800 3,125 Non-Failure August 2001 0.125 1.315 168 800 3,174 Non-Failure August 2001 0.125 1.315 168 800 3,861 Non-Failure

Attachment 1 - Dow letter to Ameren dtd 6-24-08 19 Page 19 of 59 Quick Burst of Butt Fusion Jointed 22" SDR 9 DGDA-2490 Pipes made by Rinker Pipe Outside Diameter, inches 22.025 Minimum Wall Thickness, inches 2.496 Test Condition 23 0C Internal Pressure, psig 1090 Hoop Stress, psi 4264 Evaluation of Fusion Welds Generated at Michigan Pipe Using 21" Diameter SDR 11 Pipe Made from DGDA-2490 by Quail Piping at Kingman, Arizona Fusion Joint #1 Fusion Joint #2 Pipe Sidewall (450° F, 9 min @ (4000 F, 10 min @ (control) 75psi) 75psi) (control)

A. Dow PTL Yield Strength, psi 3491 3499 3607 (stdev) (141) (67) (74)

Break Strength, psi 3865 3934 4247 (stdev) (365) (153) (133)

Elongation at Break, % 590 610 647 (stdev) (41) (25) (20)

Tensile Impact, @ 23°C ft-lb./cu in. 483 484 489 ft-lb./sq. in. 227 228 230 B.TRI/Environmental, Inc Yield Strength, psi 3673 3561 3261 (stdev) (253) (311) (167)

Break Strength, psi 3533 3485 3801 (stdev) (858) (817) (356)

Elongation at Break, % NA NA NA (stdev)

Attachment 1 - Dow letter to Ameren dtd 6-24-08 20 Page 20 of 59 VALIDATION: HYDROSTATIC BURST TEST OF CONTINUUM DGDA-2490 Resin Manufacturer: Dow Type: A-2490 BK Black Masterbatch Producer: PolyOne Type: DFNF-0092 Pipe Producer: Quail Rework: 0%

Sample Size and Length: 1" SDR 11 x 18" Temperature: 23 C Conditioning: > 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Test Fluid: Water Date: July 2001 Tested: Dow's Laboratory Data Identification: DGDA-2490 BK Quail Pipe OD (inches): 1.315 Pipe wall thickness (inches): 0.125 SDR: 10.52 SIDR: 8.52 Date of test: 7/1/2001 Test Temperature (deg. C): 23 Number of Data points: 15 note: both "r" and "r2" use predicted failure time vs. actual failure time.

Correlation coefficient (r): 0.8938754 r2 value: 0.7990131 Ratio (LCL/LTHS) 0.9357276 Long Term Hyd. Stress (1,000 hours0 days 0 hours 0 weeks 0 months ) 1783 Long Term Hyd. Stress (10 years) 1639 Long Term Hyd. Stress (100,000 hours0 days 0 hours 0 weeks 0 months ) 1635 Long Term Hyd. Stress (50 years) 1591 Lower Confidence Limit (97.5%) 1530 Hydrostatic Design Basis 1600 LTHS data 1000 CO 0

0 100 Lim 1 10 100 1000 10000 100000 1000000 Failure time (hrs)

Attachment I - Dow letter to Ameren dtd 6-24-08 21 Page 21 of 59 VALIDATION: HYDROSTATIC BURST TEST OF CONTINUUM DGDA-2490 Resin Manufacturer: Dow Type: A-2490 BK Black Masterbatch Producer: PolyOne Type: DFNF-0092 Pipe Producer: Oil Creek Rework: 0%

Sample Size and Length: 1" SDR 11 x 18" Temperature: 60 C Conditioning: > 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Test Fluid: Water Date: November 2003 Tested: Dow's Laboratory Data Identification: DGDA-2490 BK 100 Oil Creek Pipe OD (inches): 1.196 Pipe wall thickness (inches): 0.073 SDR: 16.38 SIDR: 14.38 Date of test: 11/3/2003 Test Temperature (deg. C): 60 Number of Data points: 19 note: both "r" and "r2" use predicted failure time vs. actual failure time.

Correlation coefficient (r): 0.8768598 r2 value: 0.7688831 Ratio (LCL/LTHS) 0.985369382 Long Term Hyd. Stress (1,000 hours0 days 0 hours 0 weeks 0 months ) 1120 Long Term Hyd. Stress (10 years) 1082 Long Term Hyd. Stress (100,000 hours0 days 0 hours 0 weeks 0 months ) 1080 Long Term Hyd. Stress (50 years) 1068 Lower Confidence Limit (97.5%) 1065 Hydrostatic Design Basis 1000 10,000

! 1,000 0.

0 0

100 10 100 1,000 10,000 100,000 Failure time (hrs)

Attachment 1 - Dow letter to Ameren dtd 6-24-08 22 Page 22 of 59 APPENDIX C DATA FOR FUSION QUALIFICATION

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 23 of 59 23 Cross-Fusion of one-inch, SDR 11, CONTINUUM DGDA-2490 BK 100 With Benchmark Pressure one-inch, SDR 11 Pipes

~ W~tfei~ne,~ stii~~ai~~.

YMod oofFai fl

-t W6 rec' on Win -- V1F1 -

5544 No failure TR 418 PE 2406 ASTM D3261 23 C, 1320 psi 5544 No failure (Table 7, footnote A) 5544 No failure 5568. No failure TR 418 PE 2406 ISO 1167 (4.6 MPa) 80 C, 670 psi 5568 No failure 5568 No failure Atofina 3344 4752 No failure PE 3408 4752 No failure ASTM D3261 23C, 1600 psi Drisco 8100 (Marlex (Table 7, footnote A) 4752 No failure H516 PE 3408) 7008 No failure 7008 No failure Atofina 3344 1981 Brittle failure on Fina pipe, joint intact PE 3408 1981 Brittle failure on Fina pipe, joint intact ISO 1167 (5.5 MPa) 80 C, 800 psi 3045 Brittle failure on Fina pipe, joint intact Drisco 8100 2860 Failure at the joint (Marlex H516 PE 4716 Brittle failure on Drisco 8100, joint intact 3408) 7056 No failure ASTM D3261 23 C, 1600 psi > 10,000 Brittle failure on pipes DGDA-2490 BK (Table 7, footnote A)

_ _ ISO 1167 (5.5 MPa) 80 C, 800 psi 4300 Brittle failure on pipes

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 24 of 59 7JAoNA LABORATORIEs INc.

Executive Summary:

The purpose of this test was to validate the fusion of polyethylene (PE) pipe materials. Samples of Dow PEIOO/Enhanced PE3408 pipe fused to itself and PE3408 and PE2406 pipe materials were examined through Burst and Sustained Pressure testing. A sample of Dow PE100 PE fused to itself was examined by UTensile testing.

Visual inspection of the butt fused joints was conducted to examine for any signs of unacceptable appearance such as cold fusion, improper alignment, inadequate roll back, incomplete face off, or insufficient melt. Sustained Pressure testing was conducted in accordance with ASTM D3261-97 according to ASTM D1 598-97. Six specimens were tested at 80 nC, 115 psig for 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months . Burst testing was conducted in accordance with ASTM 01599-99, Procedure A. Tensile testing was conducted in general accordance with ISO 13953:2001(E) for 20" diameter pipe sections, at the speed of 5 mm/min with fusien beads intact.

Based on visual analysis, the samples all appear to be adequately fused. This is confirmed by the burst test and sustained pressure test results for the 2" pipe samples and the tensile test results for the 20" pipe. All the 2" pipe specimens passed the Sustained Pressure Test requirements of ASTM D3261-97, Section 10.5.2 and the Burst Pressure Test requirements of ASTM D3261-97, Section 10.5.3. All Tensile Test failures were ductile based on reference to ISO 13953:2001(E).

UBased on the testing and analysis conducted the following conclusions can be drawn:

U 1. The 2" pipe butt fusions of the PE100/Enhanced PE3408 material to itself and PE3408 and PE2406 pipe materials meet the Sustained Pressure and Burst Test requirements of ASTM D3261-97.

2. Tensile testing of the butt fused joints prepared from the 20" diameter pipe show that the butt fused area has similar or greater tensile strength compared to the solid (wall) pipe control (samples) and that all failures at the fusion interface are ductile in nature.

i Project 02-3117- Final Report Page 1/8 m 280B INDUSTRIAL PARKWAY S., AURORA,ONTARMOL4G 3Y9 905-726-8550 Fax: 905-726-8609 RL

Attachment 1 - Dow letter to Ameren dtd 6-24-08

__25 Page 25 of 59 S V71JANA L4BORA TORIES INC.

5 Report No: Project 02-3117 - Final Report s Client, Dow Date of Issue: January 17, 2003 I

Purpose of Test:

I The purpose of this test was to validate the fusion of polyethylene (PE) pipe materials. Samples of Dow PE100 PE fused to itself and PE3408 and PE2406 pipe materials were examined.

Test Item Identification and

Description:

Sample Description # of ID Specimens02-758 Black PE Pipe. Two pieces cut from large diameter pipe 2 200102016-56-1 Quail Pipe Butt Fusion Sample 02-777 Black PE Pipe. One piece cut from large diameter pipe. 1 Dimensions: 16 M"x 20" x 2". PC 160 C3. ASTM F714-2-A.

AZ 12-13-01 QUAIL HD3400 02-812 Black PE Pipe. One piece cut from large diameter pipe. 1 Dimensions : 13" x 10" x 2" With fusion in the middle 02-813 Black PE Pipe. One piece cut from large diameter pipe. 1 Dimensions : 13" x 5" x 2" With fusion in the middle 02-814 2" PE Pipe. Fusion of DGDB-2480 with DGDC-2480 9 Note: DGDB-2480 pipe has yellow print line and DGDC-2480 pipe has blue print line Blue: SDR1 1 AWWA C901-96-PC-160 02-815 2" PE Pipe. Fusion of DGDC-2480 with DGDC-2480 11 Note: DGDC-2480 pipe has blue print line SDR 11 PE 3408 2" IPS02-816 2" PE Pipe. Fusion of DGDC-2480 with PE2406 Quail pipe 11 Note: DGDC-2480 pipe has blue print line and PE 2406 is yellow pipe Yellow:. QUAIL MD 2400 GAS PIPE PE2406 2" IPS SDR 11 Black: HD 3400 PE3408 2" IPS SDR1 I 02-850 2" PE Pipe. Fusion of DGDB-2480 with DGDC-2480 3 Project 02-3117- Final Report Page 2/8 280B INDUSTRIAL PARacWAV S., AURORA, ONTARIO L4G 3T9 905-726-8550 Fax: 905-726-609

Attachment 1 - Dow letter to Ameren dtd 6-24-08

_26 Page 26 of 59 j/JANA LABORA TOMEs INC.

Test Methods:

Visual inspection of the butt fused joints was conducted to examine for any signs of unacceptable appearance such as cold fusion, improper alignment, inadequate Iroll back, incomplete face off, or insufficient melt.

Sustained Pressure testing was conducted in accordance with ASTM D3261-97 according to ASTM D1598-97. Six specimens for testing were capped with free end style closures, filled with water, and conditioned for a minimum of I hour in water at 176 +/- 3.6 OF (80 +/- 20C). Specimens were intemally pressurized with water to 115 psig (0.794 MPa) and tested for 1000 hours0.0116 days 0.278 hours 0.00165 weeks 3.805e-4 months . The applied hoop stress was calculated based on the end pipe dimensions.

I Burst testing was conducted in accordance with ASTM D 599-99, Procedure A.

Five specimens were capped with free end style closures, filled with water, and conditioned for a minimum of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in water at 73 +/- 3.6 OF (23 +/- 2 °C). Internal water pressure was ramped uniformly and continuously until the specimen failed between 60 and 70 seconds. The applied hoop stress was calculated based on the end pipe dimensions.

Tensile testing was conducted in general accordance with ISO 13953:2001 (E) for the large diameter pipe sections both with and without butt fusion joints. Type B test pieces were machined except that the length of the narrow parallel sided portion was zero due to the constraints in the number of available samples and the machining process. One solid pipe control sample had a narrower end width, however, the region being tested had the same dimensions as all other samples.

Four solid pipe control specimens were prepared from Sample 02-777. Seven specimens with butt fused joints were prepared from Samples02-812, 02-813 and 02-758. Machined samples were conditioned at 73 +/- 3.6 OF (23 + 20C) for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months prior to testing. Testing was conducted at the speed of 5 mm/min. Fusion beads were not removed. Tensile testing was conducted at an approved outsource laboratory.

II I!

N Project 02-3117 - Final Report Page 318 2M0B INDUSTMIAL PARKWAV S, AURoRA,ONTARtOLAG 3T9 905-726-8550 Fax: 905-726-8609

Attachment 1 - Dow letter to Ameren dtd 6-24-08 27 Page 27 of 59 In 7/JANA LABORATORIES INC.

II I! Results:

1. Visual Inspection NI Based on visual inspection of the butt fusion joints of the large diameter pipe and the 2" pipes, the pipes appear to be adequately fused. No indication of cold N! fusion, improper alignment, inadequate roll back, incomplete face off or insufficient melt were observed.

ii 2. Sustained Pressure Test: 2" Butt Fused Pipe Samples NI The Sustained Pressure Test results are provided in Tables 2.1, 2.2, and 2.3. All specimens tested exceeded the requirements of D3261 Section 10.5.2.

Ni Table 2.1: Fusion between DGDC-2480(PE1OO/Enhanced PE3408) and DGDC-2480(PE1OO1Enhanced PE3408), 80 °C, 115 psi_

02-815- 02-815- 02-815- Sec3281 In Specimen 02-815-1___

01 02-815-02 02-815-03 04 05 06 Sectio 10.5.2 Hoop Stress 551 548 551 545 552 553 NIA NI (psi)

Status after 1000 hrs Non-Failure Non-Failure Non-Failure Non-Failure Non-Failure Non-Failure Pass N/Ak Not-applicable NI Table 2.2: Fusion between DGDC-2480(PElOOEnhanced PE3408) and DGDB-2480(PE3408), 8000, 115 psi Ne Specimen Spcmn 02-8414-01 02-814-02 02-814-03 02-814-04 02-814-05 02814 068 D3261 eto 10.5.2 Ni Hoop Stress (psi)

Status after 550 Non-543 Non-549 Non-556 Non-553 Non-562 Non.

N/A Pass 1000 hrs Failure Failure Failure Failure Failure Failure N/A: Not-applicable.

Table 2.3: Fusion between DGDC-2480(PE100I/Enhanced PE3408) and PE2406, 80 oC, ll5 g 02-816- 02-816- 02-816- 02-816- 02-816- 02-816- D3261 Specimen 01 02 04 05 06 10 Section 10.5.2 Hoop Stress 554 551 551 546 552 549 WA (psi)

Status after Non- Non- Non- Non- Non- Non-1000 hrs Failure Failure Failure I Failure Failure Failure Pass N/A: Not-applicable Project 02-3117 - Final Report Page 4/8 280B INDUSTRIAL PARK.-WAVS., AuRoRA, Otr4rnAo LAG 3T9 905-726-8550 Fax: 905-726-8609

Attachment 1 - Dow letter to Ameren dtd 6-24-08 28 Page 28 of 59 I

I/JANA LABORAToRIES INC.

I

3. Burst Test: 2" Butt Fused Pipe Samples I The Burst Test results are provided in Tables 3.1, 3.2, and 3.3. All the failures occurred in the pipe. None of butt fused joints failed during testing. Testing was I conducted between October 18, 2002 and December 9, 2002. For sample 02-816, the PE2406 pipe section expanded significantly during testing such that the pressure reached the peak between approximately 60 and 70 seconds and then I stopped increasing. The sample then failed at a later time at a pressure close to the peak pressure. In this case, the peak pressure is recorded as the Burst Pressure. All the failures occurred above the minimum burst pressure U requirement of 500 psig in accordance with ASTM D3261-97, Section 10.5.3.

Table 3.1: Fusion between DGDC-2480(PE100/Enhanced PE3408) and DGDC-S Specimen 2480(PE10o/Enhanced PE3408), 23 TC 02-815- 02-815- 02-815- 02-815- 02-815- Mean (+/-

07 08 11 10 09 s.d.)

N Date Time to Burst (seac)

Burst Pressure (psig) 02-10-18 66 795 02-10-18 64 780 02-11-06 69 797 02-11-06 63 776 02-11-06

' 61 789 N/A N/A 787 +/- 9 Burst Stress (psi) 3807 3729 3832 3718 3759 3769 +/- 49 Failure Mode Ductile Ductile Ductile , Ductile . Ductile N/A s.d.: Standard deviation N/A: Not-applicable N Table 3.2: Fusion between DGDC-2480(PE100/Enhanced PE3408) and DGDB-2480(PE3408), 23 OC N Specimen Date 02-814-08 02-11-06 02-814-07 02-11-06 02-814-09 02-11-06 02-850-01 02-12-09 02-850-02 02-12-09 Mean (+

s.d.)

N/A Time to Burst (sc) 65 62 67 63 61 N/A Burst Pressure (psig) 800 773 877 989 789 842 1 82

- Burst Stress (psi) 3826 3769 4193 4505 3721 4003 +/- 337 Failure Mode Ductile Ductile Ductile Ductile Ductile N/A s.d.: Standard deviation N/A: Not-applicable Table 3.3: Fusion between DGDC-2480(PE100/Enhanced PE3408) and IN Specimen PE2406, 23 OC 02-816-07 02-816-11 02-816-09 02-816-03 02-816-08 Mean (t s.d.)

Date Time to Burst Cj!-ec, 02-11-06 82 02-11-06 69 .

02-11-12

..8.7 02-11-12 85 02-12-09 71 N/A NIA Burst Pressure (psig) 637 656 664 654 698 662 122 Burst Stress (psi) 3054 3111 3162 3032 3235 3119 183 0N Failure Mode s.d.: Standard deviation NIA: Not-applicable Ductile Ductile Ductile Ductile Ductile . N/A Note: All failures are located on yellow pipe (PE2406) 01 Project 02-3117 - Final Report Page SIB 280B INDUSTRIAL PARKWAY S., AURORA, ONTARto 1AG 3T9 90.5-7268550 Fax: 905-726-8609

Attachment 1 - Dow letter to Ameren dtd 6-24-08 29 Page 29 of 59 I

1/JAA LNABORATORJES INC.

U

4. Tensile Testing: 20" PE100 Pipe Butt Fusion Samples I The Tensile Test results of the 20" diameter pipe sections are provided in Table 4.1. A machined sample prior to the testing and the failed surface area of one of I the butt fused pipe specimens are shown in Figure 1 and Figure 2, respectively.

All the failures of the butt fused pipe specimens show the same type of failure as shown in Figure 2. Specimens prepared from the solid pipe control failed after I necking and elongation. In general, the Tensile Strengths of the fused pipe samples were comparable to those of the solid wall pipe. The average Tensile Strenqth of the fused samples was 27.5 +/- 0.3 N/mm 2 compared to 26.4 +/- 0.7 I N/mm for the solid wall pipe. The fused samples were tested with the fusion beads intact.

I The geometry of the specimens ensures that the stress is concentrated through the jointed region and that ultimate failure is in the vicinity of the joint. All failures occurred at the fusion interface as intended. The failures based on reference to I Figure 2 of ISO 13953:2001(E), are all ductile in nature.

Table 4.1: Tensile Test Results I Sample Tensile Strength (N/mm 2 )

Total Extension (mm) Mode of Failure Fused 1 28.0 21.4* Ductile Fused 2 27.5 30.9 Ductile Fused 3 27.4 30.5* Ductile I Fused 4 Fused 5 Fused 6 27.6 27.6 32.7 29.2 Ductile Ductile m

27.4 58.6 Ductile Fused 7 28.9 37.1 Ductile Solid Control 1 27.0 106.7 Necking and elongation N Solid Control 2 26.6 130.6 Necking and elongation Solid Control 3 26.5 98.8 Necking and N Solid Control 4** 25.4 111.3" elongation Necking and elongation I The test was stopped when the load dropped by 80% of the peak load. therefore, the total extension Is greater than the reported value End width is 45 mm with traction hole diameter of 19 mm The area around the traction holes began to elongate during the test due to the narrow U end width, therefore the total extension is less than the reported value U

I Project 02-3117 - Final Report 28°IDSRM AKA S., UOA NAI 4 T 0-2-50 Fx 0-24 Pape 6/8 905-726-8SM Fax: 905-726-8609 U 280H INDUSTRIAL PARKWAV S., AvRORA. UNTAitio L4G 3T9

- Dow letter to Ameren dtd 6-24-08 30 Page 30 of 59

Attachment 1 - Dow letter to Ameren dtd 6-24-08 31 Page 31 of 59 J/JANA LABoRA TOMEs INc.

Discussion:

Based on visual analysis, the samples all appear to be adequately fused. This is confirmed by the burst test and sustained pressure test results for the 2" pipe samples and the tensile test results for the 20" pipe. All the 2" pipe specimens passed the Sustained Pressure Test requirements of ASTM 03261-97, Section 10.5.2 and the Burst Pressure Test requirements of ASTM D3261-97, Section 10.5.3. All Tensile failures were ductile based on reference to ISO 13953:2001(E).

N

Conclusions:

Based on the testing and analysis conducted the following conclusions can be drawn:

1. The 2" pipe butt fusions of the PE1GO/Enhanced PE3408 material to Burst itself and PE3408 and PE2406 pipe materials meet the Sustained Pressure and Test requirements of ASTM D3261-97.

N 2. Tensile testing of the butt fused joints prepared from the 20" diameter pipe show that the butt fused area has similar or greater tensile strength compared to the solid (wall) pipe control (samples) and that all failures at the fusion interface are ductile in nature.

NThis report shall not be reproducedexcept in full without the written approval of JanaLaboratories.

N Issued By: J.D. Kim, Ph.D.

Signed: ' , o Reviewed By: Ken Oliphant, P P.Eng.

IE.OLIPHANT Signed: .t This report relates onlyto the speomen provnidec and there is no representation on warranty that it applies to similar substances or naltenals of the bulk of which the specirnm is a prlt Any comparisn osnl for tte test conditions swilled. This report shall not be reproduced except in its entirety without express written consent from Ja-e Laboratories. Ic. Neither Jana Laboratoriea ton any Of its etployees shal be responsible on held liabe for any daims, loss or damages arising in oonseaequnen of relanoe on this report or any dcef.lt. entro t omrission in its preparation or the tests onducted.

Project 02-3117 - Final Report Page 8/8 280B INDUSTRALPARKWAY S., AuRos., OwARo LAG 3T9 905-726-8550 Fax: 905-726-8609

Attachment 1 - Dow letter to Ameren dtd 6-24-08 32 Page 32 of 59 Evaluation and Comparison of Fusion Welds by McElroy McSnapperTM High-Speed Tensile Impact Testing Objective:

Evaluate and compare joint quality of butt-fused polyethylene pipes molded from Dow's DGDA-2490, Dow's DGDB-2480 and Uponor UAC 2000 in support of the Martin-Marietta Dow Pipeline Project.

Discussion:

In support of a proposed pipeline between Martin-Marietta and Dow facilities to deliver brine solution, a modest study was undertaken to determine the quality and compatibility of fusion and cross-fusion joints made from sections of Dow DGDA-2490 (PE100), Dow DGDB-2480 (PE3408) and Uponor UAC 2000 (PE2406) pipe. Eight-inch diameter, SDR 11 (0.73 inch wall thickness) pipe sections supplied by Quail Piping, Kingman, Arizona (HDPE) and McElroy Manufacturing, Tulsa, Oklahoma (MDPE) were butt-fusion welded by McElroy technical personnel. McElroy's expertise in the fusion of polyethylene pipes is widely recognized.. Two interfacial pressures (60 psi and 90 psi) were used to represent a typical range of conditions for butt-welding operations and pipe samples containing fusion welds made at these two different pressures were collected for this study. Four specimens from each joint configuration were fabricated using a McElroy Coupon Cutter. In addition to these samples, coupons were cut from pipe sidewall to serve as controls for this study. The diagram on the last page provides a pictorial representation of these coupons Heat fusion joining process requires the uniform melting of two opposed (and aligned) surfaces, merging these melted surfaces under pressure and solidifying this merged surface under a given pressure. Uniformity of melting and applied pressure(s) is tantamount to attaining an strong and acceptable fusion that will last the life of the pipe system. Generating a uniform melted surface is the first step in obtaining an acceptable weld. Several factors, such as starting with two smooth parallel pipe surfaces, proper heating temperature, adequate contact time, and uniform pressure on the polymer surface during this melting stage are critical to achieving a uniform melted surface. Polymer factors such as molecular weight, molecular weight distribution, and comonomer content, can effect melting point and the ability of the melt to flow under pressure and temperature. When fusing pipe samples of equivalent polyethylene, the development of a uniform melt surface and resultant interface (fusion) is straight forward and widely practiced art.

The fusing of unlike polyethylenes can be a bit more involved and can require an adjustment to the heating/melt portion of the fusion process. For this test, all materials were fused using recognized standard fusion practices.

Samples:

As indicated, examples of butt-fusion welds were collected at each pressure. The high-speed (McSnapperTM) tensile impact properties of these welds were compared to sections of wall without a weld present (controls). An important aspect of this testing is to evaluate the fusion compatibility of pipe molded from Dow's new bi-modal HDPE product to itself and with pipe extruded from other existing polyethylene products. For test short examination, two other pipe samples were selected, a PE3408 pipe extruded from Dow's DGDB-2480 and a PE2406 pipe provided by McElroy. The compatibility of Dow DGDA-2490 with other existing pipe materials, namely PE3408 and PE2406 is essential, since on occasion, it may be necessary for a

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 33 of 59 pipe installer to heat fuse pipe components of differing polyethylene materials. Sample descriptions used in this evaluation are provided it the charts that follow

- Chart 1 -

I. Eight-inch Diameter SDR 11 Pipe Sample Descriptions II. Designation Ill. Resin/Pipe IV. Pipe Source V. PE-100 VI. Dow DGDA-2490 VII. Quail Piping, Kingman, AZ VIII. PE3408 IX. Dow DGDB-2480 X. Quail Piping, Kingman, AZ XI. PE2406 XII.Uponor UAC 2000 XIII. McElroy Manufacturing, Tulsa, OK

-Chart 2-Butt-Fusion Sample Descriptions Sample Number Sample Description DW1 PE-100 to PE-100 fused at 60 psi interfacial pressure DW2 PE- 100 to PE- 100 fused at 90 psi interfacial pressure DW3 PE-100 to PE-3408 fused at 60 psi interfacial pressure DW4 PE- 100 to PE-3408 fused at 90 psi interfacial pressure DW5 PE-I100 to PE-2406 fused at 60 psi interfacial pressure DW6 PE-100 to PE-2406 fused at 90 psi interfacial pressure DW7 PE-3408 to PE-3408 fused at 60 psi interfacial pressure DW8 PE-3408 to PE-3408 fused at 90 psi interfacial pressure DW9 PE-3400 no joint (control)

DW10 PE-3408 no joint (control)

Sample Preparation:

For samples DWI through DW8, sections of pipe wall containing fusion joints at the top, bottom and both sides were removed and cut into coupons by McElroy representatives using a McElroy Coupon Cutter. The specimens containing butt-welds were carefully fabricated to ensure that the fusion joint was located at the center of the specimen. Where dissimilar materials were welded together, each side of the coupon was engraved to indicate the material present on that side of the weld. For the control samples, no fusion was present.

Testin$!:

The McSnapperTM machine is a tensile with impact testing apparatus, designed specifically for polyolefinic materials. It was developed by McElroy Manufacturing with the expressed intent to accurately test fusion joints. The McSnapperTM combines the tensile impact test ASTM D 1822 and high speed tensile test ASTM D 2289 to provide an accurate test for fused joints by being

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 34 of 59 critical to the fusion, but allowing the pipe to fail if the joint is good. Using the Impact Resistance Test ASTM F 905 as a model, the McSnapperTM is capable of testing sidewall fusions. The machine can also be used in the development of new materials, quality assurance for existing materials, or in fusion compatibility to determine lot uniformity, strength and fuseability of pipe and fittings. While the McSnapperTM test appears to have some usefulness as a quality control test for fusion joints, it only measures one set of "short term" property characteristics of the fusions. As a follow-up to this study, we recognize that testing in accordance with ASTM D-2837, "Standard Method for Obtaining Hydrostatic Design Basis for Thermoplastic Pipe Materials" should be considered for long-term pressure performance validation of fusion joints.

Results:

All tested specimens were returned along with the data from the McElroy Manufacturing. Since we had the luxury of comparing failed test specimens with the data, we are able to report that no brittle failures were observed in the returned strained coupon specimens. Additionally, all the failures occurred in the pipe sidewall and none occurred at the actual fusion joints. The data from the testing is summarized in chart 3 and chart 4 that follow. In chart 4, the averaged data along with the standard deviation for each of the four individual test specimens run from each fusion joint and control sample. Chart 4 at the end of this document provides all the data generated by McElroy on the pipe fusions and control specimens.

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 35 of 59

- Chart 3 -

Im Rijtt-Fijsi~n MnSn~nn~rTM Axi~ran~c1 R~siiIt~

SapeYield Sa pl { Energy (ft-lbs) TFai j lure(ft-lbs)

Energy Maximum Force (Ibs)

]UlJtimate(psi) Stress DWl avg 19 83 1234 4031 h std dev 1,5 12 21 l 79 DW2 avgi 18 77 T 1226 4010 std dev 1.6 3 25 64 DW3 avg 17 67 1172 3908 std dev 1.0 4 14 39 DW4 avg 17 61 1142 3775 std dev 160 11 31 93 DW5 E avg std dev 14 0.6 57 5

1056 ] 3418 25 67 DW6 -::avjg 13 57 1 1055 3459 std dev 05 19 15 43 DW7 avg 19 75 1128 3636 std dev 2.1 9 18 63 DW8 avgg 19 68 1135 3695 L std dev 1.9 8 15 35 DW9 avg 18 87 1201 3964

____ std dev 0.8 5 16 60 DW10 avg 19 85 1118 3701 std dev 1,0 5 40 110 Conclusions, Recommendations and Future Work Using McElroy's McSnapperTM test apparatus, fusions of like pipes made from Dow 's new PE-100, DGDA-2490 displayed excellent strength compared to control samples without fusions present. Additionally, acceptable fusions of DGDA-2490 with pipes made from standard PE-3408 and PE-2406 materials can be generated using standard butt-fusion techniques. None of the fusion tested displayed brittle failure. All failures were of a ductile nature occurring in the pipe sidewall rather than at the fusion. While these are positive data indicating acceptable joint quality can be achieved using standard fusion techniques with pipe fabrication from Dow PE-100, additional pressure testing will be required to affirm long term pressure validation for field service.

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 36 of 59

- Chart 4 McElroy McSnapperTM Test Results Samole JYield Energy (ft-lbs Falr nry (t-lbs)

Maximum Forte (Ibs)

Ultimate Stress (psi) Sample fYield Energy (ft-lbs)

Failure Energy (ft-lbs) 1Maximum Force (Ibs)

Ultimate Stress (psi)

DW1 1 2

18 20 72 99 1206 1256 3915 4078 r-DW6 * "--'"-"

2 12 13 58 1040 3467 58 1055 3517 21 84 1241 4082 13 56 1075 3420 18 2 78 1231 4049 2 13 56 1050 3433 avg 19 83 1234 4031 avg 13 57 1055 3459 std dev 1.5 12 21 79 _std dev 0.5 1 15 43 DW2 1 16 74 1191 3915 ] DW7 1- 17 65 1110 3542 2 20 76 1226 4030 2 21 71 1120 3665 3 18 77 1241 4054 3 21 75 1130 3670 4 18 82 1246 4039 4 18 87 1151 3667 avg 18 77 1226 4010 1 _ 19 75 1128 3636 std dev, 1.6 3 25 64 s _ "_1 2.1 9 18 63 DW3 1 17 72 1156 3924 DW8 1 18 55 1125 3654 2 16 67 1181 3857 2 20 73 1120 3683 3 18 66 1186 3948 3 16 70 1145 3737 16 62 1166 3902 4 20 72 1151 3707 avg 17 67 1172 3908 a 19 68 1135 3695 std dev 1.0 4 14 39 1 d__

dev1 1,9 8 15 35 DW4

--W-1 16 44 1105 3647 =-DW9-- 1_ 18 92 1181 3882 2 18 67 1176 3840 -2_ 18 86 1216 3997 a 16 62 1130 3764 avg 19 81 1211 4018 4 16 69 1156 3848 4 17 90 1196 3958 avd 17 61 1142 3-1_7 E5____ 18 87 1201 3964 i std dev 1.0 11 31 9-3 std dev 0.8 5 16 60 IDW5 I 13 51 1025 3328 ",IDW10 I 18 86 1125 3702 n 2 14 61 1085 3478 2 20 77 1065 3575 3 13 57 1050 3409 3 19 85 1120 3684 4 14 60 1065 3458 4 18 90 1161 3842 avg 14 57 1056 3418 avg 19 85 1118 3701 std dev 0.6 5 25 67 std dev 1.0 5 40 110

-I- I

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 37 of 59

References:

Jim Perrault, P.E., McElroy Manufacturing, Inc. Testing Report PO#63518814, Dated 4/24/2002 McElroy Manufacturing, Inc. Operator's Manual #S00106 Revised 3/99: "High Speed Tensile with Impact Testing System, McSnapperTM'"

Plastics Pipe Institute Technical Note, "General Guidelines for Butt, Saddle, and Socket Fusion of Unlike Polyethylene Pipes and Fittings TN-13/2001" Plastics Pipe Institute Technical Report, "Generic Butt Fusion Joining Procedure for Polyethylene Gas Pipe TR-33/2001"

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 38 of 59 38 Uponor Saddle Fusion Test Data with CONTINUUM DGDA-2490 BK 100 Quick Burst Test (ASTM D1599 - 5 specimens)

Quick Burst Test Results Saddle Pipe Gauge Hoop Time Failure End Cap # of Sample Fusion (2" IPS) (psi) Stress (psi) (sec) Type Location S. Fitting # Material Fusion Butt Tap Tee 1 2 3 4 5 Fusion Control None DGDC- 780 3655 70 Ductile Pipe- --- -------- ---- --- Solvay Butt 2 2480 BK K44-08-123 3408 (1)

Control None UAC2000 600 2895 60 Ductile Pipe- --- -------- ---- --- TR418 Butt 2 (TR-418) I I I A DGDA- DGDC- 770 3790 69 Ductile Pipe OK OK OK OK OK Solvay Socket 5 2490 BK 2480 BK K44-08-123 100 3408 (1)

B DGDA- DGDC- 790 3702 67 Ductile Pipe OK OK OK OK OK Solvay Butt 5 2490 BK 2480 BK K44-08-123 100 3408 (2)

C DGDA- PE 3408 740 3569 60 Ductile Pipe OK OK OK OK OK Solvay Socket 5 2490 BK (AtoFina K44-08-123 100 3344)

D DGDA- UAC2000 580 2799 64 Ductile Pipe OK OK OK OK OK TR418 Socket 5 2490 BK (TR-418) 100 Pipe:

DGDC-2480 BK 3408 (1)- lot # T01-051702, 2.373" OD, 0.224" wall, CEC DGDC-2480 BK 3408 (2) - lot # T07-040303, 2.375" 013, 0.229" wall, CEC PE 3408 pipe (Atofina 3344) - lot # T01-051602, 2.374" OD, 0.223" wall, CEC UAC 2000 (TR-418) - lot # T02-060502, 2.375" OD, 0.223" wall, CEC SF Tap Tee:

CONTINUUM DGDA-2490 BK 100 SF Tap Tee lot # 2003 16755, 2x3/4 IP, 0.500 cutter, CJE PE 3408 pipe (TR480) SF Tap Tee - lot # 2000 65882, 2xl/2CT, 0.800 cutter, CDC End Cap:

UAC 2000 (TR 418) SF Cap - lot #200294990, /4, CEC PE 3408 (Solvay K44-08-123)- lot # 351332U, 3/4IPS

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 39 of 59 39 Uponor Saddle Fusion Data with CONTINUUM DGDA-2490 BK 100 Knock-Out Test (ASTM F905 - 6 specimens) (Hammer weight - 20 1b, Drop height - 14 ft 1 inch)

S. Fitting #1 S. Fitting #2 S. Fitting #3 S. Fitting #4 S. Fitting #5 S. Fitting #6 Saddle Pipe Fusion Failure Fusion Fusion Fusion Fusion Fusion Fusion Fusion Fusion Fusion Fusion Sample Fusion (2" IPS) Joint Location Joint Location Joint Location Joint Location Joint Location Joint Location Tap Tee E DGDA- DGDC- OK Fitting OK Fitting OK Fitting OK Fitting OK Fitting OK Fitting 2490 BK 2480 BK (1) 100 F DGDA- DGDC- OK Fitting OK Fitting OK Fitting OK Fitting OK Fitting OK Fitting 2490 BK 2480 BK (2) 100 G DGDA- PE 3408 OK Pipe OK Pipe OK Pipe OK Pipe OK Pipe OK Pipe 2490 BK (AtoFina 100 3344)

H PE 3408 DGDC- OK Fitting OK Fitting OK Fitting OK Fitting OK Fitting OK Fitting (TR480) 2480 BK 3408 (1)

I PE 3408 DGDC- OK Fitting OK Fitting OK Fitting OK Fitting OK Fitting OK Fitting (TR480) 2480 BK 3408B(2) 1 1 1 1 1 1 2 0 w C Pipe:

DGDC-2480 BK 3408 (1)- lot # T01-051702, 2.373" OD, 0.224" wall, CEC DGDC-2480 BK 3408 (2) - lot # T07-040303, 2.375" OD, 0.229" wall, CEC PE 3408 pipe (Atofina 3344) - lot # T01-051602, 2.374" OD, 0.223" wall, CEC UAC 2000 (TR-418)- lot # T02-060502, 2.375" OD, 0.223" wall, CEC SF Tap Tee:

CONTINUUM DGDA-2490 BK 100 SF Tap Tee lot # 2003 16755, 2x3/4 IP, 0.500 cutter, CJE PE 3408 pipe (TR480) SF Tap Tee - lot # 2000 65882, 2xl/2CT, 0.800 cutter, CDC End Cap:

3 UAC 2000 (TR 418) SF Cap - lot #200294990, 3, CEC PE 3408 (Solvay K44-08-123) - lot # 351332U, 3/4 IPS

Attachment 1 - Dow letter to Ameren dtd 6-24-08 40 Page 40 of 59 APPENDIX D DATA FOR FITTING QUALIFICATION

Attachment 1 - Dow letter to Ameren dtd 6-24-08 41 Page 41 of 59 Hydrostatic Testing At 80 0 C and 800 psi of 1" SDR 11 fitting butt-fused to 1" SDR 9 pipe made from CONTINUUM DGDA-2490 material Injection-Molded Fittings made by Central Plastics Pipe sample was extruded by the Pipe Technology Center of Dow Butt-fusion was made by the Pipe Technology Center of Dow Hydrostatic test was done by PTC of Dow Fitting Pi e., Failure Mode A-2490 Minimum Diameter Minimum Diameter Hours Brittle/Ductile Thickness (inch). Thicknless (inch),

(inch) (inch):' -

0.120 1.328 0.144 1.312 160 Brittle (pin hole) 180 degrees from the injection molding gate, not at the joint 2 0.120 1.327 0.147 .1.315 187 Brittle (pin hole) 180 degrees from the injection molding gate, not at the joint 3 0.119 1.230 0.142 1.312 283 Brittle (pinhole) 180 degrees from the injection molding gate, not at the joint 4 0.117 1.325 0.144 1.310 206 Brittle (pin hole) 180 degrees from the injection molding gate, not at the joint 5 0.119 1.320 0.146 1.311 321 Brittle (pin hole) 180 degrees from the injection molding gate, not at the joint 6 0.111 1.314 0.134 1.310 438 Brittle (pinhole) 180 degrees from the injection molding gate, not at the joint 7 0.113 1.325 0.138 1.309 421 Brittle (pinhole) 180 degrees from the injection molding gate, not at the joint 9 0.111 1.324 0.138 1.311 330 Brittle (pinhole) 180 degrees from the injection molding gate, not at the joint

Attachment 1 - Dow letter to Ameren dtd 6-24-08 42 Page 42 of 59 Hydrostatic Testing At 90 0 C and 725 psi of 2" SDR It fitting butt-fused to 2" SDR 9 pipe made from CONTINUUM DGDA-2490 BK 100 Injection-Molded Fittings made by Central Plastics and Rahn Plastics Pipe sample was extruded by the Pipe Technology Center of Dow Butt-fusion was made by the Pipe Technology Center of Dow Hydrostatic test was done by PTC of Dow K*"....... i.... s .... Mitianiu Hoursi-r4 'Di B&tle i ile Th~ickhessý (Indi:

1 0.225 2.385 2580 No failures. All samples removed 2 0.221 2.385 2580 from testing 3 0.216 2.385 2580 4 0.229 2.375 2387 No failures. All samples removed 5 0.229 2.375 2111 from testing 6 0.228 2.375 2169 Perfection's Trials of Mechanical Tapping Tee of Various Sizes Made of CONTINUUM DGDA-2490 BK 100 Passed tests specified in ASTM 1598, 1599, F1924, F1588 Passed @ 80C and 670 psi Passed @ 23C and 1,000 psi (1,242 hours0.0028 days 0.0672 hours 4.001323e-4 weeks 9.2081e-5 months and test stopped)

Passed the Cone Test

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 43 of 59 APPENDIX E TECHNICAL REPORTS ON DGDA-2490 PIPES FROM OTHER SOURCES

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 44 of 59 B E C E T E L BELGIAN RESEARCH CENTRE FOR PIPES AND FITTINGS REPORT No. 5179 Demanded by DOW CHEMICAL Attn. Mr. J. ZHOU PO&E TS&D, Rml 10/B98 171 River Road PISCATAWAY, NJ 08854 U.S.A.

At the expense of idem Concerning Determination of the resistance to rapid crack propagation of 10" PE pipes (S4 test method), product DGDA-2490 BK 100.

Your order by e-mail dd. 26/06/2001.

Our reference BEC 3616 and SR010333.doc Our invoice no. no.20010511 Date of the report 27 September 2001 This report contains 4 pages General remark The results mentioned in this report are exclusively related to the product as defined hereinafter and this document may, in no case, be considered as an approval of this product.

To warrant that the results would be representative of the product, as it is delivered or applied, conformity of the specimens to the product should be assured.

The specimens are at your disposal during two months after the date of the report.

This report may not be reproduced, except completely, without the prior written permission of the research centre BECETEL.

SR010333.doc - 1/4 BECETEL VZW / ASeL GONTRODE HEIRWEG 130 - B-9090 MELLE TEL -+32 (0)9 272 50"70 - FAX +32 (0)9 272 50 72 BTW/TVA/VAT: BE 406 633 106 - FORTIS BANK GENT 290-0083433 KB GENT 447"0039971-29

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 45 of 59 DETERMINATION OF THE RESISTANCE TO RAPID CRACK PROPAGATION OF 10" PE PIPES (S4 TEST METHOD). PRODUCT DGDA-2490 BK 100 I Received material 10 PE pipes 10", delivered to Becetel on 20 July 2001.

Product name: DGDA-2490 BK 100 Marking: PLEXCO EHWW 10" IPS DI I PE3408 ASTM F714 C3 U-401 A002 06/25/01 Colour: black Length: 2,0 m Pipe dimensions: diameter 273 mm, wall thickness 25 mm The pipes are extruded and delivered to Becetel by Plexco Inc. (USA).

2 Test proeram The tests on the PE pipes are executed in accordance with ISO 13477 "Thermoplastics pipes for the conveyance of fluids - Determination of the resistance to Rapid Crack Propagation (RCP) - Small-Scale Steady-State Test (S4 test)"

The critical pressure at a temperature of 0 'C is determined, followed by a measurement of critcal temperature at a pressure of 10 bar.

The critical pressure is determined again, but at that temperature where crack propagation occurs at 10 bar pressure.

3 Principle The Small-Scale Steady State (S4) test is developed to determine the critical pressure of plastics pipes, i.e. the minimum internal pressure which results in a propagation of the brittle fracture over the entire length of the test piece.

The S4 test simulates a steady state propagation of the rapid crack by an artificial limitation of decompression of the pipe during the crack propagation. The decompression ahead of the propagating crack is retarded by internal baffles and by an external containment cage, which restricts flaring of the pipe at the edges of the fracture.

Hence the stress at the crack tip does not decrease and the propagation of the crack is sustained.

The fast-running axial crack is initiated by driving a knife in the pipe wall. near one end. at a considerable speed (15 +/- 5 m/s).

Tests are executed at different internal pressures in order to determine the transition from crack arrest to crack propagation over the entire length of the specimen. This transition defines the critical pressure of the pipe material, p,,.,

SRO10333+doc - 2/4 BECETEL VZ / ASBL GONTRODE HEIRWEG 130 - 8.9090 MELLE TEL, +32 (0)9 272 50"70 - FAX +32 (0)9 272 50 72 BTW/TVA/VAT: BE 406 633 106 - FORTIS BANK GENT 290-0083433 KBC GENT 447,0039971-29 E-MAIL: infoiSbecefel.be - WESSITE: www.beCete1.b8

Attachment 1 - Dow letter to Ameren dtd 6-24-08 46 Page 46 of 59 4 Test conditions External diameter of the pipes dc: 270 mm, Wall thickness e.: 25 mm; Length of the pipes: 1800 mm:

Propagation zone: 1270 mm:

Number of pressure chambers: 10; Internal diameter of the containment cage: 300 mm; The crack length is measured following the pipe axis (= projection of the crack path onto the pipe axis);

Test temperatures: see below, obtained by conditioning the test pipes in a freezer; The test pressures are reached using compressed air; Impact velocity: 12 m/s:

- Test date: 4-14 September 2001.

5 Test results The crack lengths in the following tables are measured from the center of the knife impact.

The crack lengths are also given in relation to the nominal diameter of the pipes d,.

Pipe Temperature Internal Crack length aid, Result, no. °C pressure a (mm)

(bar) 1 0 5,0 475 1,8 Crack arrest 2 0 10,0 375 1,4 Crack arrest 3 0 11,5 405 1,5 Crack arrest 4 -10 10.0 855 3.2 Crack arrest 5 -15 10,0 720 2,7 Crack arrest 6 -17 10,0 865 3,2 Crack arrest 7 -20 1,5 270 1,0 Crack arrest 8 -20 2,0 1430 5.3 Crack propagation 9 -20 3,0 1430 5,3 Crack propagation 10 -20 10,0 1430 5,3 Crack propagation Due to the lack of test pieces, no more tests at -20*C could be performed for a more precise determination of the critical pressure.

SRO 10333.doc - 3/4 BECETEL V7W/ ASBL GONTRODE HEIRWEG 130 - B-9090 MELLE TEL' +32 (0)9 272 5070 - FAX +32 (0)9 272 5072 BTW/TVA/VAT: BE 406 633 106 - FORMnS BANK GENT 290-0083433 KBC GENT 447-0039971-29 intoc@beteelbe -- WEBSITE: www.becelel.be

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 47 of 59 Q;

6 Discussion of results The S4 tests on the 10" PE pipes, product DGDA-2490 BK 100 at a temperature of 0 °C.

result in a critical pressure PC.S4 of higher than 11,5 bar.

The critical temperature T,%4 at 10 bar air pressure is determined at -17C. The critical pressure Pc.s4 at -20°C is determined at 1.5 bar.

Melle, 27 September 2001.

ir. J. VIENNE Prof. it. P(

Staff Member General ri SR010333.doc - 4/4 BECETEL vZw/ ASHL GONTRODE HEIRWEG 130 - E-9090 MELLE TEL. +32 (0)9 272 5070 - FAX +32 (0)9 272 5072 BTW/TVA/VAT: BE 406 633 106 - FORTIS BANKGENT 2900083433 KBC GENT 447"0039971"29 E.-MAIL:info@becelel.be .- WE3rrE :www.beceteV.be

Attachment I - Dow letter to Ameren dtd 6-24-08 48 Page 48 of 59 uponor TECHNICAL LAB REPORT Uponor Aldyl Company 4501 West 4 9 th Street Tulsa, OK 74107-7315 Tel. (918) 446-4471 Fax (918) 446-9369 Plant

Contact:

Larry Shelton - Phone 918-445-5643 Job Number: 090301 Lot Number: Pipe - T01081303 / Ftgs. -200316754 & 200316755.

Background:

Uponor produced UAC 3700 ULTRA-STRIPE pipe and UAC 3700 molded fittings from Dow A 2490 PE 100 resin. The pipe and fittings were joined to each other and other PE 3408 pipe products. The heat fusion joints were qualified per DOT 192.283 requirements.

Product

Description:

Uponor UAC 3700 2 X V"butt outlet tap tees, UAC 3700 couplings, and UAC 3700 pipe produced from Dow DGDA 2490 PE 100 / PE 3408 resin.

Scope: Testing was performed to qualify the extrusion process of UAC 3700 pipe from Dow DGDA 2490 PE 100/PE 3408 resin and to qualify the heat fusion joints between Uponor UAC 3700 pipe and fittings to other PE3408 pipe products.

Preparation: Test Conditions: 230 C & 800 C Test Procedures: Per ASTM F 905, ASTM D 638, ASTM D 1598, & ASTM D 1599.

ASTM D 1599: 15 specimens were tested, with ductile failure occurring in the pipe wall.

ASTM F 905 18 specimens were tested, with all failures occurring in the pipe wall.

ASTM D 638: 36 specimens were elongated > 25% with no joint failures.

ASTM D 1598 12 specimens were squeezed per D 2513, A1.5.5, then tested > 1000 hrs with no failures.

==

Conclusion:==

All specimens met or exceeded the listed procedure requirements, thereby meeting the qualification requirements per ASTM D 2513 & DOT 192.283. See attached data.

Note: "We certify that all portions of each test performed were under continuous, direct supervision of this laboratory."

Bob Creason Larry Shelton Bob Creason Larry Shelton Lab Operator Lab Supervisor

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 49 of 59 UAC 3700/Dow A 2490 Resin 2" Pipe Samples Lot Number T01081303 / 2" IPS SDR 11 UAC 3700 Pipe Resin lot # QE1755P83B, Masterbatch # 241120308 All D 1598 specimens squeezed-off per D 2513, A1.5.5 requirements Sustained Pressure Test per ASTM D 1598 Sample Test Temp Stress Time Results 1 800 C 670 psi >1000 hrs Passed 2 80' C 670 psi >1000 hrs Passed 3 80' C 670 psi >1000 hrs Passed 4 80' C 670 psi >1000 hrs Passed 5 80' C 670 psi >1000 hrs Passed 6 800 C 670 psi >1000 hrs Passed Sustained Pressure Test per ASTM D 1598 Sample Test Temp Stress Time Results 1 23' C 1600 psi >1000 hrs Passed 2 230 C 1600 psi >1000 hrs Passed 3 23° C 1600 psi >1000 hrs Passed 4 23° C 1600 psi >1000 hrs Passed 5 230 C 1600 psi >1000 hrs Passed 6 23°C 1600 psi >1000 hrs Passed Quick Burst Test per ASTM D 1599 Sample Test Temp Stress Time Mode Result 1 230 C 740 psig 68 Sec Ductile Passed ASTM D 2513 Dimension Specifications for 2" SDR 11 Pipe Wall: .216" -. 242" / OD: 2.369" - 2.381" As Measured Dimensions Sample Wall OD 1 .225- .2291 2.379 2 .221 - .2251 2.380 3 .224- .229 2.380 4 .224- .229 2.380 5 .222- .226 2.380 6 .222 - .226 2.380

Attachment 1 - Dow letter to Ameren dtd 6-24-08 50 Page 50 of 59 YELLOWSTRIPE 8300 PIPE TO UAC 3700 TAP TEE SADDLE FUSION.

PROCEDURE QUALIFICATION PER D.O.T. 192.283 SHORT-TERM BURST TEST (ASTM D1 599)

Fusion Parameters: Fused at 500°F per Uponor fusion procedures.