View source for ULNRC-05517, CFR50.55a Request: Proposed Alternative to ASME Section XI Requirements for Replacement of Class 3 Buried Piping

{{Adams
| number = ML082470210
| issue date = 07/10/2008
| title = CFR50.55a Request: Proposed Alternative to ASME Section XI Requirements for Replacement of Class 3 Buried Piping
| author name = Mills K
| author affiliation = AmerenUE, Union Electric Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000483
| license number = NPF-030
| contact person = 
| case reference number = TAC MD6792, ULNRC-05517
| document type = Letter type:ULNRC, Report, Technical
| page count = 244
| project = TAC:MD6792
| stage = Request
}}

=Text=
{{#Wiki_filter: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 hours 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&#xa2;      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&deg;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&deg;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, &sect;192.273(b) and
     &sect;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, &sect;192.273, &sect;192.283, &sect;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 hours 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 hours 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&deg;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&deg;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 hours. 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 hours at 20 0C and 1800 psi, 165 hours at 800C and 800 psi, and 1000 hours 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&deg;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 hours 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&deg;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&deg;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&deg;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, &sect;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&deg;F. As indicated by the asterisk listing
(*), it is validated for the linearity of the long term hydrostatic strength (LTHS) at 73&deg;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 (&deg;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&deg;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&sect; 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&deg; 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&deg;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 hours                                     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 hours)                     1783 Long Term Hyd. Stress (10 years)                        1639 Long Term Hyd. Stress (100,000 hours)                   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 hours                                        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 hours)                    1120 Long Term Hyd. Stress (10 years)                       1082 Long Term Hyd. Stress (100,000 hours)                  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 hours. 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                                                                         Specimens 02-758        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" IPS 02-816        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 hours. 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 hour in water at 73 +/- 3.6 OF (23 +/- 2 &deg;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 Samples 02-812, 02-813 and 02-758. Machined samples were conditioned at 73 +/- 3.6 OF (23 + 20C) for a minimum of 24 hours 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 &deg;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&deg;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~ickhess&#xfd; (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 hours 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.              &deg;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 &deg;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&deg;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&deg; C     1600 psi >1000 hrs    Passed 4          23&deg; C     1600 psi >1000 hrs    Passed 5          230 C     1600 psi >1000 hrs    Passed 6          23&deg;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&deg;F per Uponor fusion procedures.
Test Specimen       Failure Mode       Time to Failure        Failure Pressure (seconds)                 (PSIG)
Sample #1        In Pipe, Ductile          63                      740 Sample #2       In Pipe,  Ductile          63                      740 Sample #3       In Pipe,  Ductile          63                      740 Sample #4       In Pipe,  Ductile          64                      750 Sample #5       In Pipe,  Ductile          64                      750 Sample #6       In Pipe, Ductile           64                      750 IMPACT RESISTANCE PER (ASTM F905)
Test Specimen           Result Sample #1   Pipe  wall torn out/pass Sample #2   Pipe  wall torn out/pass Sample #3   Pipe  wall torn out/pass Sample #4   Pipe  wall torn out/pass Sample #5   Pipe  wall torn out/pass Sample #6   Pipe wall torn out/pass

Attachment 1 - Dow letter to Ameren dtd 6-24-08 51       Page 51 of 59 UAC 3700 PIPE TO DRISCOPIPE 8100 PIPE BUTT FUSION PROCEDURE QUALIFICATION PER D.O.T. 192.283 SHORT-TERM BURST TEST (ASTM D1599)
Fusion Parameters: Fused at 500&deg;F per Uponor fusion procedures.
Test Specimen    Failure Mode    Time to Failure         Failure Pressure (seconds)                  (PSIG)
Sample A     In Pipe, Ductile       64                       740 Sample B     In Pipe, Ductile       64                       740 Sample C      In Pipe, Ductile       64                       740 TENSILE ELONGATION (ASTM D638)
Test Specimen    %Elongation         Result Sample #1          >50%        No Joint Failure Sample #2          >50%        No Joint Failure Sample #3          >50%        No Joint Failure SHORT-TERM BURST TEST (ASTM D1599)
Fusion Parameters: Fused at 400&deg;F - 450&deg;F per PPI Generic fusion procedures.
Test Specimen    Failure Mode    Time to Failure         Failure Pressure (seconds)                  (PSIG)
Sample D      In Pipe, Ductile       65                       730 Sample E      In Pipe, Ductile       65                       730 Sample F      In Pipe, Ductile       65                       730 TENSILE ELONGATION (ASTM D638)
Test Specimen    %Elongation         Result Sample #4          >50%        No Joint Failure Sample #5          >50%        No Joint Failure Sample #6          >50%        No Joint Failure

Attachment I - Dow letter to Ameren dtd 6-24-08 52       Page 52 of 59 UAC 3700 PIPE TO UAC 3700 PIPE BUTT FUSION PROCEDURE QUALIFICATION PER D.O.T. 192.283 SHORT-TERM BURST TEST (ASTM D1599)
Fusion Parameters: Fused at 500&deg;F per Uponor fusion procedures.
Test Specimen     Failure Mode    Time to Failure         Failure Pressure (seconds)                  (PSIG)
Sample A       In Pipe, Ductile       64                       740 Sample B       In Pipe, Ductile       64                       740 Sample C       In Pipe, Ductile       64                       740 TENSILE ELONGATION (ASTM D638)
Test Specimen     %Elongation         Result Sample #1           >50%        No Joint Failure Sample #2           >50%        No Joint Failure Sample #3           >50%        No Joint Failure SHORT-TERM BURST TEST (ASTM D1599)
Fusion Parameters: Fused at 400&deg;F - 450&deg;F per PPI Generic fusion procedures.
Test Specimen     Failure Mode    Time to Failure         Failure Pressure (seconds)                  (PSIG)
Sample D       In Pipe, Ductile       65                        730 Sample E       In Pipe, Ductile       65                       730 Sample F       In Pipe, Ductile       65                       730 TENSILE ELONGATION (ASTM D638)
Test Specimen     %Elongation         Result Sample #4           >50%        No Joint Failure Sample #5           >50%        No Joint Failure Sample #6           >50%        No Joint Failure

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 53 of 59 UAC 3700 PIPE TO UAC 3700 SOCKET COUPLING PROCEDURE QUALIFICATION PER D.O.T. 192.283 SHORT-TERM BURST TEST (ASTM D1599)
Fusion Parameters: Fused at 500&deg;F per Uponor fusion procedures.
Test Specimen     Failure Mode    Time to Failure          Failure Pressure (seconds)                  (PSIG)
Sample #1     In Pipe, Ductile         66                       760 Sample  #2    In Pipe,  Ductile        66                       760 Sample  #3     In Pipe, Ductile        66                       760 Sample  #4     In Pipe, Ductile        66                       760 Sample  #5     In Pipe, Ductile        66                       760 Sample  #6    In Pipe,  Ductile        66                       760 TENSILE ELONGATION (ASTM D638)
Test Specimen     %Elongation          Result Sample  #1          >50%        No  Joint Failure Sample  #2          >50%        No  Joint Failure Sample  #3          >50%        No  Joint Failure Sample  #4          >50%        No  Joint Failure Sample  #5          >50%        No  Joint Failure Sample  #6          >50%        No  Joint Failure

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 54 of 59 UAC 3700 PIPE TO UAC 3700 TAP TEE SADDLE FUSION PROCEDURE QUALIFICATION PER D.O.T. 192.283 SHORT-TERM BURST TEST (ASTM D1599)
Fusion Parameters: Fused at 500&deg;F per Uponor fusion procedures.
Test Specimen      Failure Mode       Time to Failure        Failure Pressure (seconds)                 (PSIG)
Sample  #1      In Pipe, Ductile          68                      740 Sample  #2      In Pipe, Ductile          68                      740 Sample  #3      In Pipe, Ductile          68                      740 Sample  #4      In-Pipe, Ductile          68                      740 Sample  #5      In Pipe, Ductile          68                      740 Sample  #6      In Pipe, Ductile          68                      740 IMPACT RESISTANCE PER (ASTM F905)
Test Specimen         Result Sample #1   Pipe wall torn out/pass Sample #2   Pipe wall torn out/pass Sample #3   Pipe wall torn out/pass Sample #4   Pipe wall torn out/pass Sample #5   Pipe wall torn out/pass Sample #6. Pipe wall torn out/pass

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 55 of 59 DRISCOPIPE 8100 PIPE to UAC 3700 SOCKET COUPLING PROCEDURE QUALIFICATION PER D.O.T. 192.283 SHORT-TERM BURST TEST (ASTM D1599)
Fusion Parameters: Fused at 500&deg;F per Uponor fusion procedures.
Test Specimen   Failure Mode     Time to Failure          Failure Pressure (seconds)                  (PSIG)
Sample  #1    In Pipe, Ductile        66                       760 Sample  #2    In Pipe, Ductile        66                       760 Sample  #3    In Pipe, Ductile        66                       760 Sample  #4    In Pipe, Ductile        66                       760 Sample #5     In Pipe, Ductile        66                       760 Sample #6     In Pipe, Ductile        66                       760 TENSILE ELONGATION (ASTM D638)
Test Specimen   %Elongation           Result Sample  #1         >50%        No  Joint Failure Sample  #2         >50%        No  Joint Failure Sample  #3         >50%        No  Joint Failure Sample  #4         >50%        No  Joint Failure Sample  #5         >50%        No  Joint Failure Sample  #6         >50%        No  Joint Failure

Attachment 1 - Dow letter to Ameren dtd 6-24-08 56       Page 56 of 59 DRISCOPIPE 8100 PIPE TO UAC 3700 TAP TEE SADDLE FUSION PROCEDURE QUALIFICATION PER D.O.T. 192.283 SHORT-TERM BURST TEST (ASTM DI 599)
Fusion Parameters: Fused at 500&deg;F per Uponor fusion procedures.
Test Specimen      Failure Mode       Time to Failure        Failure Pressure (seconds)                 (PSIG)
Sample #1       In Pipe, Ductile          63                      800 Sample #2       In Pipe, Ductile          63                      800 Sample #3       In Pipe, Ductile          63                      800 Sample #4       In Pipe, Ductile          64                      810 Sample #5       In Pipe, Ductile          64                      810 Sample #6       In Pipe, Ductile          64                      810 IMPACT RESISTANCE PER (ASTM F905)
Test Specimen          Result Sample #1   Pipe wall torn out/pass Sample #2   Pipe wall torn out/pass Sample #3   Pipe wall torn out/pass Sample #4   Pipe wall torn out/pass Sample #5   Pipe wall torn out/pass Sample #6   Pipe wall torn out/pass

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 57 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 D1599)
Fusion Parameters: Fused at 500&deg;F per Uponor fusion procedures.
Test Specimen      Failure Mode        Time to Failure        Failure Pressure (seconds)                 (PSIG)
Sample #1       In Pipe, Ductile           63                      740 Sample  #2      In Pipe, Ductile           63                      740 Sample  #3      In Pipe, Ductile           63                      740 Sample  #4      In Pipe, Ductile           64                      750 Sample  #5      In Pipe, Ductile           64                      750 Sample  #6      In Pipe, Ductile           64                      750 IMPACT RESISTANCE PER (ASTM F905)
Test Specimen          Result Sample  #1  Pipe wall torn  out/pass Sample  #2  Pipe wall torn  out/pass Sample  #3  Pipe  wall torn out/pass Sample  #4  Pipe  wall torn out/pass Sample  #5  Pipe  wall torn out/pass Sample  #6  Pipe  wall torn out/pass

Attachment 1 - Dow letter to Ameren dtd 6-24-08 Page 58 of 59 YELLOWSTRIPE 8300 PIPE to UAC 3700 SOCKET COUPLING PROCEDURE QUALIFICATION PER D.O.T. 192.283 SHORT-TERM BURST TEST (ASTM D1599)
Fusion Parameters: Fused at 500 0 F per Uponor fusion procedures.
Test Specimen    Failure Mode    Time to Failure          Failure Pressure (seconds)                   (PSIG)
Sample #1     In Pipe, Ductile        66                        750 Sample #2     In Pipe, Ductile        66                        750 Sample #3     In Pipe, Ductile        66                        750 Sample #4     In Pipe, Ductile        66                        750 Sample #5     In Pipe, Ductile        66                        750 Sample #6     In Pipe, Ductile        66                        750 TENSILE ELONGATION (ASTM D638)
Test Specimen    %Elongation          Result Sample #1          >50%        No  Joint Failure Sample #2          >50%        No  Joint Failure Sample #3          >50%        No  Joint Failure Sample #4          >50%        No  Joint Failure Sample #5          >50%        No  Joint Failure Sample #6          >50%        No  Joint Failure

Attachment 1 - Dow letter to Ameren dtd 6-24-08 59       Page 59 of 59 UAC 3700 PIPE TO YELLOWSTRIPE 8300 PIPE BUTT FUSION PROCEDURE QUALIFICATION PER D.O.T. 192.283 SHORT-TERM BURST TEST (ASTM DI 599)
Fusion Parameters: Fused at 500&deg;F per Uponor fusion procedures.
Test Specimen    Failure Mode    Time to Failure         Failure Pressure (seconds)                  (PSIG)
Sample A      In Pipe, Ductile       64                       740 Sample B      In Pipe, Ductile        64                      740 Sample C      In Pipe, Ductile       64                       740 TENSILE ELONGATION (ASTM D638)
Test Specimen    %Elongation         Result Sample #1          >50%        No Joint Failure Sample #2          >50%        No Joint Failure Sample #3          >50%        No Joint Failure SHORT-TERM BURST TEST (ASTM D1599)
Fusion Parameters: Fused at 400&deg;F - 450'F per PPI Generic fusion procedures.
Test Specimen    Failure Mode    Time to Failure         Failure Pressure (seconds)                  (PSIG)
Sample D      In Pipe, Ductile       65                       750 Sample E      In Pipe, Ductile       65                       750 Sample F      In Pipe, Ductile       65                       750 TENSILE ELONGATION (ASTM D638)
Test Specimen    %Elongation         Result Sample #4          >50%        No Joint Failure Sample #5          >50%        No Joint Failure Sample #6          >50%        No Joint Failure

Attachment 2 - Dow letter to Ameren dtd 6-24-08 Page 1 of 6 Evaluation and Comparison of Fusion Welds by McElroy McSnapperT 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 (PEI00), 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 (McSnapper T               M)    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 N :\ESW Buried Pipe\Relief RequestRAIs3rd round of RA [s\RAI attachments\Dow letter\U LN RC-05517 Dow Chemical 6 08 letter Attachment 2 - NRC 6-10-08 RAt Enclosure I Questions I and 2(a) - Mcelroy Mcsnapper Testing 8-13-02.doc David W. Kababik / April 24, 2002

Attachment 2 - Dow letter to Ameren dtd 6-24-08 Page 2 of6 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 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 -
Eight-inch Diameter SDR 11 Pipe Sample Descriptions Designati   Resin/Pipe         Pipe Source on PE-100      Dow DGDA-2490      Quail Piping, Kingman,      AZ PE3408      Dow DGDB-2480      Quail Piping, Kingman,      AZ PE2406      Uponor UAC         McElroy Manufacturing,      Tulsa, OK 2000
                             - chart    2  -
Butt-Fusion Sample Descriptions Sample Number      Sample Description DWI            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-100 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-100 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.

Attachment 2 - Dow letter to Ameren dtd 6-24-08 Page 3 of 6 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.
Testing:
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 McSnapper TM 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 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 McSnapper TM 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 McSnapper TM 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 2 - Dow letter to Ameren dtd 6-24-08 Page 4 of 6
                                              -   chart 3 -
Butt-Fusion McSnapper MT Averaged Results Ultimate Stress Sample
_______ __  ___   [  Yield Energy (ft-lbs)    j   Failure Energy (ft-Ibs)   j Maximum Force (Ibs)              (psi)______
DW       {         avg          19                  83            1234                4031 std dev           1.5                 12               21                 79 DW2                avg         18                   77            1226                4010 I    std dev           11.6                 3               25                 64 DW3                avg           17                 67             1172               3908 std devI           1.0                 4            __14                  39 DW4                avg           17                 61             1142                 3 std devI           1.0                11               31                 93 DW5                avg         14                   57            1056                3418 std dev          0.6                   5               25                 67 DW6                avg         13                   57            1055        -F      3459 std dev    [L    0.5                   1               15                 43 DW7                avg         19                   75             1128               3636 std dev_         2.1_1                 9      1        18                 63 DW                 avg         19                   68      E      1135        [      3695 std dev            1.9                 8               15                 35_m DW9                avg         18                   87            1201                3964 std dev          0.8                   5               16                 60 DWio               avg         19                   85            1118                3701 std dev            1.0                 5               40                110 Conclusions        Reconmmendations             and Future Work:
Using McElroy's McSnapper TM 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 2 - Dow letter to Ameren dtd 6-24-08 Page 5 of 6
                                                                                        -   chart 4 Mclroy McSnapper TM Test Results Sape(ft-Ibs Sam ole          Yield Energy  Falure   Energy (ft-lbs)     Maimum(Ibs) Force         (psi)Sress Ultimate                   Sam Sape(ft-lbs)        Yield Energy Failure   Energy (ft-lbs              (Ibs) Force Maximum                  (psi) Sres Ultimate owl                 1        18             72              1206               3915           IDW6                   1         12            58                 1040               3467 2       20              99              1256               4078         -                       2          13             58                1055               3517
        '3                   21              84              1241               4082                                 3          13            56                 1075               3420 4        18             78              1231               4049                                 4          13            56                 1050               3433 avg       19             83              1234               4031                                avg         13             57                1055               3459 td dev       1.5             12               21         1        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 18             82_246403                                                                4_81                       7_1            151 366 18           77               1241               4054                                 3         21             75                 1130               3670 4        18             82              1246               4039                                 4          18            87                 1151               3667 avg       18             77              1226               4010                                avg         19             75                1128               3636 std dev       1.6             3                25                  64           A               std dev,        2.1             9                  18                 63 DW3                 1 2
17 16 72 67 4      1156 1181 3924 3857
                                                                                               -DW8                  1 2
18 20 55 73 1125 1120 3654 3683 3        18            66               1186               3948                                 3          16            70                 1145              3737 4        16            62               1166               3902                                 4         20             72                 1151              3707 avg       17             67              1172               3908                                avg         19             68       _        1135               3695 std dev       1.0             4                14                  39                           std dev         1.9             8                  15                 35 DW4                 1        16            44               1105               3647             DW9                 1          18            92                 1181              3882 2       18             67               1176               3840                                 2          18            86                 1216              3997 3       16             62               1130               3764L                                3          19            81                 1211              4018 4       16             69               1156               3848                                 4          17            90                 1196              3958 avg       17             61              1142               3775                                avg         18             87                1201               3964 st dev,       1.0            11                31                  93                          std dev,         0.8             5                  16                 60 IDWS                 1       13             51               1025               3328             DW10                1         18             86                 1125              3702 2       14             61               1085               3478                                 2         20             77                 1065 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
N:\ESW Buried Pipe\Relief Request\RAIs\3rd round of RAIs\RAI attachments\Dow letter\ULNRC-05517 Dow Chemical 6-24-08 letter Attachment 2 - NRC 6-I 0-08 RAI Enclosure I Questions I and 2(a) - Mcelroy Mcsnapper Testing 8-13-02.doc David W. Kababik / April 24, 2002

Attachment 2 - Dow letter to Ameren dtd 6-24-08 Page 6 of 6

==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, McSnapper&#xfd;"
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" N:\ESW Buried Pipe\Relief Request\RAIs\3rd round of RAIs\RA1 attachments\Dow letter\ULNRC-05517 Dow Chemical 6-24-08 letter Attachment 2 - NRC 6-10-08 RAI Enclosure I Questions I and 2(a) - Mcelroy Mcsnapper Testing 8-13-02.doc David W. Kababik / April 24, 2002

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 1 of 17 New Products, New Horizons: High Density Polyethylene (HDPE) Resins for Natural Gas Piping Z. Jimmy Zhou, David W. Kababik, Guylaine St. Jean and Quentin D. Eberhart Pipe Technology Center, The Dow Chemical Company Somerset, NJ ABSTRACT                                                      Pipeline operation pressure is important for gas utilities to ensure the efficient transportation Three polyethylene (PE) gas pipe materials           and distribution of natural gases. Therefore it is used in the United States are analyzed. They             desirable to use materials with high pressure include two        unimodal     medium    density        ratings. In service, the ambient temperatures of polyethylene (MDPE) PE2406 with 1000 psi                 a natural gas pipeline can significantly vary from and 800 psi hydrostatic design basis (HDB) at            place to place and/or from daytime to nighttime.
60'C respectively, and one unimodal high                 Because of this, pressure ratings of pipe density polyethylene (HDPE) PE3408 with 800              materials at elevated temperatures that cover the psi HDB at 60'C. Recent progress in PE                   maximum ambient temperatures are necessary to bimodal technology have led to three new HDPE            properly design and safely operate the pipeline pipe materials: enhanced PE3408 having 1000              system. ASTM D2837 (1) and ISO 9080 (2) can psi HDB at 60'C; conventional PE100 having a             be used to extrapolate the long-term hydrostatic minimum required strength (MRS) listing at               strength (LTHS) to 11 and 50 years, 20'C; and enhanced PE100 having MRS listings             respectively, for pressure rating purposes. Plastic at both 20'C and elevated temperatures. This             Pipe Institute (PPI) lists both HDB and MRS in paper will compare the key properties of these           TR-4 (3). If operated properly and below the materials that determine          the long-term          pressure rating, a pipeline will not fail in the performances of a gas pipe system. It will focus         ductile failure mode.
on pressure capability at room and elevated temperatures, resistance to slow crack growth                Pipelines can fail in other modes other than (SCG), resistance to rapid crack propagation             ductile failures after long time service. Steel (RCP), and quality of butt-fusion joints of same         pipe, for instance, can leak due to corrosion. PE pipe and hybrid welds of different pipes.                pipe is virtually corrosion-free, offering a major advantage over metal pipe. Pipe can also fail For HDB-rated materials, the enhanced               long-term in a brittle manner through slow crack PE3408 bimodal HDPE pipe provides higher-                growth (SCG) failure mode. SCG is the main pressure capability at a broad temperature range,        failure mode of a PE gas pipeline. It is believed improved SCG and RCP resistance, and                     that the resistance to SCG, as measured by enhanced joining quality. The PE100 pipe                 PENT test (4), ASTM F1473, is related to the materials deliver the same, or better, properties        failure rate of a pipeline in the field. The longer than PE3408 bimodal HDPE material and                    the PENT lifetime, the lower the failure rate and performs better than the unimodal pipe                   the safer the pipeline is against leakage. SCG materials. In addition, PEIOO materials offer            failures usually cause a small leak on a local higher-pressure     capability    around    room         basis for an individual pipe within the pipeline temperatures. In particular, the enhanced PE100          system.
material offers higher-pressure capability in the temperature range up to 60'C than both PE2406               In gas pressure pipe, a large amount of energy and PE3408.                                              is stored in the pipeline infrastructure because of internal operating pressure. Rapid crack INTRODUCTION                                             propagation (RCP) can occur under the driving force of this stored energy. RCP failure is rare but catastrophic. It can destroy hundreds of

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 2 of 17 meters of pipelines within seconds. Unlike local          PE100 and compare the new bimodal HDPE and individual SCG failures, RCP failures can             materials with conventional medium and high result in an explosion, destroying an entire              density unimodal PE pipe materials currently pipeline system on a very large scale.                    used in North America.
Resin producers have made significant               PIPE MATERIALS INVESTIGATED progress in the past several years, developing a new generation of HDPE resins, via bimodal                  Three groups of gas pipe samples are shown in technology, for natural gas application that              the comparison study in Table 1. PE2406 and delivers safer and higher performing PE pipe              PE3408 meet the requirements of ASTM material. This new bimodal technology is an               D2513( 51 for gas pipe application. PE100 pipe improvement over the conventional unimodal                meets ISO 4437 (6) for gas pipe applications.
technology. These new materials have higher-              They all have more than 100 h PENT for SCG.
pressure ratings for a broader temperature range          In addition, they have either a CDC or CEC and resistance to SCG and RCP is significantly            rating (5)in accordance to D25 13 for the gas pipe improved.                                                 category. In naming the different samples below, the letter C represents conventional products, This paper will investigate three groups of gas        letter S represents standard products, and letter E pipe grade materials of PE2406, PE3408 and                is for the enhanced pipe products.
Table 1. Material Designation of the PE Pipe Materials Samples                                    Material Designation ASTM D3350( 71,        ASTM D2513             ISO 9080            ASTM D3350 PPI TR-4                                ISO12162(8)
Pipe Grade          Pipe Category         Pipe Grade         Cell Classification PE2406C              PE2406                 CDC                                       234363A PE2406S              PE2406                 CEC                                       234363A PE3408S              PE3408                 CDC                                        345464C PE3408E              PE3408                 CEC                                       346564C PE1OOS              PE3408                 CEC                 PE1O0                 345566C PE1OOE              PE3408                 CEC                 PE100                 346566C Table 2 General Characterization of the PE Pipe Materials Property                PE2406                      PE3408                               PE1O0 C              S             S             E                  S                   E Technology        Gas Phase       Slurry     Gas Phase      Gas Phase             Slurry           Gas Phase Molecular        Unimodal Unimodal          Unimodal         Bimodal           Bimodal             Bimodal Structure Melt Index, 12        0.2           0.2           0.1            0.08               0.1                0.08 Flow Index, 121        18            20           8.3              9                6.8                   9 Resin Density        0.939         0.940         0.944          0.949              0.951               0.949 Flexural         100,000       100,000      126,000         165,000            140,000             165,000 Modulus, psi Tensile Strength      2,800         2,800         3,200          3,600              3,700               3,600 at Yield, psi

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 3 of 17 The general characterization of the pipe      where A, B and C are constants, S is the stress in materials is illustrated in Table 2. PE3408E,       psi, T is the temperature in 'K, and t is the PE100S and PE100E are bimodal HDPE                  failure time in hours. The LTHS is then materials. MDPE PE2406C and S and HDPE              categorized into HDB and listed in PPI TR-4.
PE3408S are unimodal materials. The short-term properties of the two PE2406 resin materials are       PE2406 and PE3408 can be used for gas pipe very close. Bimodal HDPEs have a higher             in accordance to ASTM D2513. However, not density and display higher flexural modulus and     all PE2406 and PE3408 rated materials are tensile strengths over conventional HDPE.           qualified for gas pipe applications. D2513 has additional requirements that include: a minimum PRESSURE CAPABILITY                                 630 psi HDB at 60'C; and HDB at 23&deg;C is substantiated by showing that the extrapolation When designing a natural gas pipeline, utility   of the stress regression curve is linear to the companies expect them to operate safely for 50      438,000 h intercept (LTHS at 50 years).
years. It is well known that the strength of plastics is dependent on time and temperature. It      Table 3 lists the HDB of six pipe materials at is not realistic to test the pipe materials for 50  23&deg;C and 60'C. They meet the pressure rating years in the real world. A good scientific method   requirements for natural gas distribution in is needed to extrapolate the 50-year performance    North America in accordance to ASTM D2513.
based on relatively short term testing data.        Note that PE2406S has 1250 psi HDB at 23&deg;C ASTM D2837 and ISO 9080 have been used for          but 1000 psi HDB at 60'C. PE3408S is listed for many years to pressure-rate the plastic materials 1600 psi HDB at 23&deg;C but 800 psi HDB at based on hydrostatic test data with a minimum 60'C. PE2406S offers a higher pressure rating testing time of 10,000 and 9,000 hours, respectively.                                       than PE3408S at 60'C.
HDB-rated      and MRS-rated materials have been successfully used in the However, bimodal technology has improved field for several decades in North America and long-term performance in new HDPE resins. It the rest of the world (mainly in Europe),
is important to note that PE3408E outperforms respectively.
PE2406S at all temperature range up to 60'C.
HDB-Rated Materials                                 Thus, the bimodal PE3408E delivers a better long-term performance than PE2406S at a ASTM D2837 first extrapolates LTHS to          higher operation pressure and for a broader 100,000 h (11 years) using 18 hydrostatic data      temperature range, based on HDB listing.
points generated at 23 &deg;C. It assumes the linearity of the regression curve using the equation of a     MRS-rated Materials straight line.
ISO 9080 extrapolates LTHS to 50 years (438,000 h) based on multi-temperature data.
logt =a+bhlogS                  (1)       The regression curves can be non-linear using the four-parameter equations.
where a and b are constants, S is the failure stress in psi and t is the failure time in hours.
The extrapolation is validated by elevated           logt = C 1 + -
2
                                                                       +C 3 logc+          4 (3) temperature data using the rate-process method,                     T                        T the three-parameter equation, where Ci is a parameter, cy is stress in MPa, T is logt = A + B      clogs                   temperature in 'K, and t is failure time in h. The (2)       extrapolation and validation is completed by T       T using the same four-parameter equation (3). It requires data at minimum of two temperatures

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 4 of 17 and at least 30 data points at each temperature.             four-parameter equation (3) was used for the All data points are taken into consideration for             extrapolation. No ductile-brittle transition knee both extrapolation and validation. The 50-year               was detected up to 80'C and 2.5 years for the LTHS at 97.5% of lower confidence limit (LCL)                real data points. The extrapolation time factor, is then categorized into MRS in accordance to                K,, was used to determine that the ductile-brittle ISO 12162 (8. PPI lists MRS in TR-4.                         transition would not occur within 250 years at 20 0 C, 100 years at 40'C and 15 years at 60'C, Table 4 illustrates the ISO 9080 extrapolation            based on the test data.
results of a black pipe made from PEIOOE. The Table 3. HDB and MRS of the Pipe Materials Listed in PPI TR-4 Samples           Material           HDB, psi                       MRS, MPa Designation      23oC(I)     60 0C         20oC         40 0C           60 0 C PE2406C            PE2406         1250*        800 PE2406S            PE2406         1250*       1000 PE3408S           PE3408         1600*        800 PE3408E            PE3408         1600*       1000 PEIOOS             PE100         1600*       1000           10.0 PE100E(2)           PE1O0         1600*       1000           10.0          8.0            6.3 (1) In PPI TR-4,    an asterisk is used to show the compliance of HDB substantiation to 50 years at 23&deg;C.
(2) MRS (0,t) is cited from PPI TR-4. Above listings are MRS 10.0 (20'C, 100 years), MRS 8.0 (40 0 C, 50 years) and.MRS 6.3 (60'C, 11 years).
Table 4. ISO 9080 Analysis Results for the Black Pipe Made from PE100E Resin Number of Data Points*                                           93 23 0C Data                   30 points>500 h, 4 points>7000 h and 4 points>9000 h 60'C Data                     30 points>10 h, 7 points>7000 h and 3 points>9000 h 80 0C Data                  33 points>10 h, 11 points>7000 h and 10 points>9000 h Number of Parameters of the                                        4 Regression Equation Knee Position                                   No knee is detected tmax of Average of Longest Five                           21,746 h (2.5 years)
Points at 80'C Ductile Extrapolation Limit at 20'C                               250 years Ductile Extrapolation Limit at 40'C                               125 years Ductile Extrapolation Limit at 60'C                                15 years MRS at 20'C forlOO years                                     10.0 MPa MRS at 23&deg;C for 50 years                                    10.0 MPa MRS at 40'C for 50 years                                     8. 0 MPa MRS at 60'C for 11 years                                      6.3 MPa Including some non-failure points.

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 5 of 17 Table 5. Maximum Operation Pressure (MOP) of the Pipe Materials Samples       Material                           MOP, psig Designation      20 0C          23oC             40 0C               60 0C PE2406C        PE 2406                        80                                    51 PE2406S         PE2406                        80                                    64 PE3408S         PE3408                        102                                   51 PE3408E         PE3408                        102                                   64 PE1OOS         PE 100          145 PE100E(l)        PE 100          145           145              116                  91 (1) MOP is for 20'C/100 years, 23'C/50 years, 400 C/50 years and 60'C/11 years.
To date, ASTM D2513 has not recognized            the temperatures of 23&deg;C and 60'C. Because the MRS-rated materials. A parallel standard, ISO          HDB at 23&deg;C is substantiated to 50 years, the 4437, may be used provided a DOT waiver is             MOP at 23'C is based on 50-year extrapolation.
obtained. ISO 4437 requires MRS at 20 0C. ISO          At the room temperature of 23&deg;C, PE3408 TC 138 has been working on a draft standard that       outperforms PE2406. However, at 60'C, the recognizes the MRS (0, t), where E is the              enhanced PE2406S and PE3408E are better than temperature in 'C and t is the time in years.          the conventional PE2406C and PE3408S MRS (20'C, 50y) must be listed for pipe                materials.
classification. The end-use engineers shall use MRS (0, t) for design consideration. The                  Let us compare the pressure capability of four maximum application temperature should be              HDB-rated materials in the temperature range below or equal to 0.                                   from 23&deg;C to 60'C. The following equation, as given in PPI TN-18 (9), is used to calculate the To address the important application            pressure rating at a given temperature, T.
temperature issue, PPI has listed MRS (0, t) in TR-4. As shown in Table 3, PEI OOE has three new MRS listings in addition to the standard                        (SL  -SH)X        1        1 listing of MRS (20'C, 50y). The new listings are        ST = SL               1               T         (5)
MRS 10.0 (20&deg;C, 100 y), MRS 8.0 (40'C, 50 y) and MRS 6.3 (60'C, 11 y).                                                    TL    T, Maximum Operation Pressure (MOP)                       Where ST is LTHS at interpolation temperature (psi), SL is LTHS at the lower temperature (psi),
For HDB-rated materials, the MOP is              SH is LTHS at the higher temperature (psi), TT is calculated by Equation (4)                             the interpolation temperature (&deg;K), TL is the lower temperature (&deg;K) and TH is the higher temperature (&deg;K). Using HDB at 23&deg;C and 60 0 C, MOP = 2xHDBxF                  (4)
DR-1                              the pressure ratings at a temperature between 23&deg;C and 60'C can be calculated by Equation where HDB is in psi, MOP is in psig, F is a            (4). The corresponding MOP is calculated by design factor and the dimension ratio DR equals        using Equation (4).
the average outside diameter divided by the minimum wall thickness. For natural gas pipe, F        Figure 1 provides the curves of MOP versus equals 0.32. For a standard SDR 11 pipe, Table         temperatures for a standard SDR 11 pipe. Note 5 calculates MOP of the HDB-rated materials at         that: (1) PE2406S and PE3408E offer an MOP

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 6 of 17 160 140 120 100 80 0
60 40 20 0
0                20                  40           60                     80 Temperature, oC Figure 1. MOP versus Application Temperatures Table 6. SCG Requirement and PENT hours of the Pipe Materials Product         Material         SCG Cell Class      PENT, hrs"         Typical PENT, hrs Designation            D3350             D2513                   F1473 PE2406C           PE2406                  6               >100                     2500 PE2406S          PE2406                  6               >100                     3000 PE3408S          PE3408                  6               >100                      200 PE3408E           PE3408                  6               >100                     4000 PEIOOS           PE 100                  6               >100                     2000 PEIOOE           PE 100                  6               >100                     6000 higher than 60 psig up to 60'C (60 psig                   From Figure 1, PE3408E offers the best operating pressure is widely used in the U.S); (2)    pressure capability at all temperatures. On one PE3408E has a higher MOP than PE2406S for             hand, for operating pressures above 70 psig and the whole temperature range (at 23&deg;C, the MOP         maximum temperatures below 45&deg;C, PE3408S of PE3408E is 28% higher); (3) Below 45&deg;C,            may be better than PE2406S. On the other hand, PE3408S has higher MOP than PE2406S.                  for operating pressures below 70 psig and However, above 45&deg;C, PE2406S has higher               maximum temperatures above 45&deg;C, PE2406S MOP than PE3408S. It is intercepted at 70 psig        might be better than PE3408S. PE2406C is not and 45&deg;C; (4) PE2406C is ranked the last in the       competitive and should be obsolete. The current group.                                                market shares of these materials correlate well with the MOP data. PE2406S and PE3408S split

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 7 of 17 the market. PE2406S dominates the market for         1.        Ductile, the Stage I failure with large-70 psig and below. PE3408S is preferred for                    scale deformation; above 70 psig. PE2406C almost has no sales. It       2.        Slow crack growth, the Stage II brittle is worth noting that PE3408E should outperform                 failure with a very small leaking hole; both PE2406S and PE3408S.                                      and
: 3.        Rapid crack propagation, the fast failure For MRS-rated materials, the MOP is                      mode with the crack running at a speed calculated by Equation (6)                                     up to hundreds of meters per second.*
Pipe systems rarely fail in the ductile mode MOP=20 x MRS                      (6)       since the hoop stress of a pressurized gas pipe is Cx(DR-1) far below the yield point after considering the safety factor. For example, the hoop stress of a where MRS is in MPa, MOP is in bar, C is a PE3408 pipe is about 14% to 32% of the yield design coefficient and the dimension ratio DR strength within 50 years.
equals the average outside diameter divided by the minimum wall thickness. For gas pipe, C A pipe resin's resistance to SCG is the most equals 2. For a standard SDR 11 pipe, Table 5 important factor in determining the lifetime of a listed the calculated MOP value of the MRS-gas pipe system. All long time failures are rated materials at the temperatures of 20'C for caused by SCG. When the failure rate becomes 50 years. For PEIOOE, the MOP is 145 psig for        excessive in any part of the system, it must be 20'C/100years, 145psig for 23&deg;C/50years, 116         replaced. The six factors that determine failure psig for 40&deg;C/50years and 91 psig for                rates are:
60&deg;C/1 lyears. As illustrated in Figure 1, at room temperatures, PE100 has 42% and 81% pressure         1.        Quality of the resin; advantage over PE3408 S and E and PE2406 C           2.        Quality of the fusion joints; and E, respectively. In addition, at 60'C,                     Operation pressures; PE100E also offers 42% pressure advantage            4.        Temperatures; over both PE2406S and PE3408E, and 78%               5.        Installation/earth movement; and advantage over both PE2406C and PE3408S.             6.       Third party damages.
In the United States, the Department of               RCP failure is also extremely rare but Transportation      (DOT)        regulates      the  catastrophic. Five factors related to RCP transportation and distribution of natural gases. include:
The DOT has approved an American Gas Association (AGA) petition to increase the           1.       Resin quality; maximum allowable operation pressure (MAOP)         2.         Operating pressures; of PE pipe from 100 to 125 psig. However, to                  Temperatures; date, this MAOP increase has not been               4.        Pipe diameters; and published. Besides, the DOT and ASTM D2513           5.       Third party impact.
do not recognize          MRS-rated materials.
Currently, only HDB can be used to calculate               Regardless of the quality of the initial MOP in the U.S. A waiver is required from the        installation, many uncontrollable events can DOT if using MRS-rated materials.                    occur when the ground around the pipe settles naturally or is disturbed by third party WHAT CAUSES A PIPING SYSTEM TO                       excavations. The third party impact is the most FAIL                                                 common initiator of RCP failures.
A gas pipe may fail in the following three          Many long-term failures occur at the fusion modes.                                              joints. The fusion joints are a source of stress concentration that, together with the stress,

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 8 of 17 determines the rate of SCG. Its quality primarily  lifetime. For example, a joint with a defect of depends on the ability of the welder to             10% of the wall thickness, which is introduced consistently produce a good weld. The resistance   either from fusion joining or from other to SCG of the material itself plays an important    damages, can fail earlier in SCG mode. If role to determine the failure rate.                 everything is the same the joint from a resin with 4000 h PENT is expected to last 40 times longer The quality of the resin is the most important  than that from a resin with 100 h PENT.
factor in determining the lifetime of a gas pipe system. The resin property that determines the         The PENT test has been used worldwide as an lifetime is its resistance to SCG. Whatever abuse   accelerated method to mimic SCG in the field. A a gas pipe system experiences as a result of        SCG is initiated at the tip of a defect or crack.
excessive ground stresses, scratches during        Defects or cracks can be introduced into the pipe installation, or poorly fusion joints, gas pipe    wall:
infrastructure consisting of a resin with a high resistance to SCG will have a longer lifetime       1.         During the pipe extrusion process; than one with a lower resistance.                   2.         When joining parts of the pipe together;
: 3.         By scratching the pipe surfaces during Brown and Lu (12) collected the failure data              installation; from six gas utility companies. The PENT            4.         During ground movement or third party lifetimes of the resins were measured and they                 excavations; were from less than 1 hour up to 50 hours. The      5.         By rock impingement from the "hard" service lifetimes ranged from 8 to 25 years. If                objects in the soil beds; and the failure rate is defined as the number of        6.         Through an uncontrollable event in the failures per mile pipeline per year, the field                 field; failure rate can be correlated to the PENT hours.
It was found that as the PENT hours increased,         It is difficult to estimate the size and sharpness the failure rate dramatically decreased.            of the defects or cracks in the pipe wall and its consequential effect on the service lifetime. The RESISTANCE TO SLOW CRACK                            PENT test measures the resistance to SCG by GROWTH (RSCG)                                       introducing the worst defects.
The key to obtaining a long service lifetime is     Assume no defects or cracks are sharper than to install pipes and fittings made of a resin with  the tip of a razor blade and larger than 35% of a better RSCG. Higher RSCG resin has the            the pipe wall in size. PENT test uses a specimen following advantages.                               with a 35% initial notch made by a fresh razor blade. This represents the worst case that can
: 1.       Better resistance to stresses;            happen in a pipe wall. The RSCG as measured
: 2.        Better resistance to temperatures;        by PENT is related to the pure resistance of the
: 3.        Better resistance to scratches and other  resin material to SCG.
third party damages; and
: 4.        Stronger fusion joints due to higher          ASTM D2513 requires a minimum of 100 h tolerances of defects.                    PENT for gas pipe. The PENT test is conducted at 80'C and 2.4 MPa on compression-molded For the same operation conditions, a pipe      and slow-cooled specimens with 35% of notch system with better RSCG will last longer by         depth. Table 6 lists the minimum SCG slowing crack growth or penetration. Also, the      requirement and the typical values of the pipe impact of scratches or third party damages is       materials investigated.
less severe due to the greater resistance to crack growth. A poorly fusion joint may cause                MD PE2406S has the PENT hours at 15 times premature failures but fusion joints using better   higher than that of unimodal PE3408S. This is RSCG resin may still have a very long residual      another reason why PE2406S is preferred for

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 9 of 17 natural gas distribution in addition to a higher   the temperature at 0&deg;C. This critical internal HDB at 60 'C than PE3408S.                          pressure is called critical pressure, Pc. When the internal pressure is a constant, usually 10 bar, The new bimodal PE3408E has PENT hours at         the transition temperature can be measured. This 20 times higher than PE3408S. It is also better     transition temperature is                called critical than PE2406S. In fact, the PENT of PE3408E is       temperature, Tc.
at least 30% higher than that of PE2406S, indicating increased RSCG.                             ISO 4437 requires a minimum Pc for gas pipe.
One design goal of bimodal HDPE pipe resin                                  MOP 24(
is to achieve a combinatioIn of the strength                   Pc(S - 4) >_ 2.4                       (7) offered by HDPE and the toughness offered by MDPE. As a matter of fact, it has been seen that               MOP(RCP) = 2.4 x Pc(S - 4) (8) the bimodal materials have higher-pressure ratings than unimodal HDPE. Table 6 shows that         For PE100, the minimum Pc is 4.2 bar. Taking the three bimodal HDPE resins (PE3408E,             into consideration of both long-term pressure PE1OOS, and PE1O0E) have similar or better          rating of MRS and RCP, the final MOP will be RSCG compared to MDPE. In particular,               the smaller of the values calculated from PEIOOE doubles the PENT of PE2406S.                 Equation (6) and (8).
RAPID CRACK PROPAGATION (RCP)                           It is important to point out the effect of pipe diameters when measuring RCP property. For a RCP failures have been observed in the field    given SDR, the S-4 Pc decreases as the pipe for both steel and PE pipes. A crack may be         diameter increases. To date, ISO 4437 requires a initiated by a third party impact for a gas-        minimum of 160 mm diameter (6 inches) SDR pressurized pipe. The crack can propagate at a       11 pipe for S-4 test. The European standard speed up to 300 meters per second, under the        requires 250 mm diameter (10 inches) SDR 11 driving force of the internal gas pressure. This    pipe. Since S-4 Pc increases as decreasing pipe phenomenon is called RCP failure.                   diameters, a pipe material with less RCP resistance can be restricted to the applications of We have discussed the factors that determine     low operating pressures and/or for small RCP failures in the previous part of this paper. diameter pipes.
There is little doubt that the resin materials make a big difference in preventing RCP failures. As         The S-4 Pc is measured at 0&deg;C. It does not pipe diameters (for a given SDR) and/or internal    give information regarding the RCP resistance at pressures increase, more energy is stored in the    below 0&deg;C. The gas pipe industry, especially in pipe. The driving force for crack propagation       Europe, begins using S-4 Tc to evaluate the RCP becomes greater. It is more likely to have a RCP    resistance,      realizing     that       the     ambient failure. When the ambient temperature is lower,     temperatures might be below zero. ISO 4437 the pipe materials are more brittle. Here, most     requires 4.2 bar S-4 Pc for PE100. When RCP failures are initiated by a third party         measuring S-4 Tc, the internal pressure is fixed impact.                                             to 10 bar, about 2.4 times higher than the PE100 requirement. It means that at S-4 Tc, the RCP Pc ISO 13477 (S-4 test) (13) and ISO 13478 (Full    is 10 bar. This will assure that RCP failures will Scale) are used to measure the RCP property.        not occur if the application temperatures are These standard methods measure the transitions      above Tc.
the crack runs to the end of the pipe specimen and where the crack is stopped shortly after it is       A Gas Research Institute (GRI) report (11) initiated. For a given pipe specimen, the critical  measured the S-4 Tc of ten PE gas pipe. The internal pressure can be measured when fixing

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 10 of 17 Table 7. S-4 RCP Property of the Pipe Materials Samples     Material Designation              Tc, 'C                Pc, bar                    Pc, bar ISO 13477              IS04437                    ISO 13477 PE2406C             PE2406                   18-33 (11)
PE2406S             PE2406                   18--33 (l)
PE3408S             PE3408                   9-19(11)
PE3408E             PE3408                     < -17                                             >12 PE1OOS              PE100                                             4.2                       >10 PE100E              PEOO                      < -17                   4.2                       >12 Table 8. Butt Fusion Jointed Pipe Specimens and the Hydrostatic Test Matrix Hydrostatic                      Failure Times of Butt Fusion Jointed Samples, hours Test      PE3408E      PElOOE PE3408S PE2406C PE3408E PE100E PE100E PE3408E PE3408E      PElOOE PE3408S PE2406C PE3408S PE3408S PE2406C PE2406C 23 0C, Burst     X            X           X           X         X             X             X             X 23&deg;C, 1800      254          254         67           X         61            61            X             X psi 23-C,1600        X            X           X           X         X             X             X             X psi 23&deg;C, 1320       X            X           X           X         X             X             X             X psi 80&deg;C,800        X            X           X           X         X             X             X             X psi 80&deg;C,725        X            X           X           X         X              X            X             X psi 80&deg;C, 580                                X           X psi 80&deg;C, 841                    X psi 90&deg;C, 700                    X psi 90&deg;C, 483                                X           X psi Table 9. Quick Burst of Butt Fusion Jointed 22" SDR 9 PE100E pipe Pipe Sample                                  PE1OOE Pipe Outside Diameter, inches                           22.025 Minimum Wall Thickness, inches                            2.496 Test Condition                                  23 0 C Internal Pressure, psig                             1090 Hoop Stress, psi                                 4264

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 11 of 17 resins and pipes were manufactured in North         procedure TR-33 (10). The fusion jointed pipe America. The test specimens were a piece of 8"      samples were sent back to Dow Pipe SDR 11 pipe with a length of greater than 56".      Technology Center for evaluation and testing.
The S-4 Tc of five MDPE and five HDPE unimodal pipes are listed in Table 7,                     Four pipe materials were used for this respectively. The S-4 Tc of the 10 unimodal PE      research: two existing unimodal materials of gas pipes was above 9&deg;C. PE3408S had                PE2406C and PE3408S; two new bimodal relatively better RCP resistance than PE2406S       materials of PE3408E and PE1OOE. It resulted in and PE2406C.                                        eight butt-fusion jointed samples:                     four homogeneous welds made from the same pipe of The S-4 Tc of PE3408E and PEOOE was             these four materials, respectively; two cross measured on 10" SDR 11 pipe. Becetel in             fusion joints of PE3408E with PE2406C and Belgium conducted the S-4 test. The results are     PE3408S, respectively; and two cross fusion listed in Table 7. They are much better than the    joints of PElO0E with PE2406C and PE3408S, unimodal gas pipe materials. For PE3408E and        respectively. Table 8 lists these eight butt-fusion PE100E, the RCP failures will not happen if the     jointed samples.
application temperatures are above -17C, at an internal pressure of 24 bar (360 psig) for a SDR       The objectives of the hydrostatic test on the 11 pipe. On contrary, at an application below       butt-fused pipe specimens are:
9&deg;C, the best unimodal gas pipe in today's market may fail in RCP.                              1. To prove that the pipe with joints exceeds the requirements of ASTM D2513 or/and ASTM D25 13 does not require RCP property.            ISO 4437; AGA PMC has sent a letter to ASTM F17 to request a RCP requirement in D2513. An AGA          2. To provide information to support the white paper to gas utilities suggests utility            hypothesis that the cross fusion joint of a companies take ISO 4437 as a reference for RCP           better material and a conventional material property before a RCP requirement is                     would be better than the conventional pipe incorporated in D25 13.                                  itself and the joint between the conventional pipe; and BUTT-FUSION JOINTS
: 3. To experimentally show that a PEIOOE pipe Fusion joints represent the weakest point in a        will outperform a PE3408 pipe in a long run pipeline system. Because the' field failures             even if it is subject an internal pressure of typically occur within the pipe joints, the quality      45% higher than PE3408S.
of butt-fusion joints is important.
At least three specimens were tested for each The compatibility of a pipe made of the new      test condition. The partial results were listed in bimodal resins with an existing pipeline, made      Table 8. This program is still on going.
from unimodal PE, is important for the integrity of the infrastructure. It is necessary to generate      Figure 2 showed the butt-fusion jointed 1" data for the cross fusion joints between the new    SDR 11 pipe samples. Sample a and b were butt-bimodal HDPEs and the existing unimodal gas         fusion jointed from same pipe of PE1OOE and pipe materials.                                     PE3408E, respectively. Samples c and e were for the cross fusion of PE3408E with PE2606C An extensive program has been initiated by      and PE3408S, respectively. Samples f and g Dow to investigate the quality of butt-fusion       were for the cross fusion of PE1OOE with joints. 1" SDR 11 pipe was made in a Dow pilot      PE2406C and PE3408, respectively. By visually plant. The pipe samples were shipped to             examining the beads, all welds were in good McElroy. They were butt-fusion jointed together     quality.
by McElroy using the PPI generic fusion joining

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 12 of 17 0

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 13 of 17 III   ION, I                            IOX I III        ,,                     III j()1) I N  I PIS I                           III   " 108 Figure 2. Butt Fusion Jointed 1" SDR 11 Pipe

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 14 of 17 Figure 3, Quick Burst Test of 22" SDR 9 Pipe Made from PE100E.

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 15 of 17 Table 10. The McSnapper TM Test Data by McElroy for 8" SDR 11 Pipe Samples      Interfacial               Yield Energy  Failure Energy          Maximum                Ultimate Pressure,                    (ft-lbs)                         Force (lbs)           Stress (psi) psi                                      (ft-lbs PElOOE-           60           avg             19             83                  1234                 4031 PEIOOE                      std dev           1.5            12                   21                    79 90           avg             18             77                  1226                 4010 std dev           1.6             3                   25                    64 PE1OOE-           60           avg             17             67                  1172                 3908 PE3408S                      std dev           1.0             4                   14                    39 90           avg             17             61                  1142                 3775 std dev           1.0            11                   31                    93 PE1OOE-           60           avg             14             57                  1056                 3418 PE2406S                      std dev          0.6              5                   25                    67 90           avg             13             57                  1055                 3459 std dev          0.5              1                   15                    43 PE3408S-           60           avg             19             75                  1128                 3636 PE3408S                      std dev          2.1              9                   18                    63 90           avg             19             68                  1135                 3695 std dev           1.9             8                   15                    35 PE100E         No joint        avg             18             87                  1201                 3964 std dev          0.8              5                   16                    60 PE3408S        No joint        avg             19             85                  1118                 3701 std dev           1.0             5                   40                   110 Figure 2 also showed the locations where the                 The fusion joining of large diameter PE1OOE failures occurred. First, there was no failure that     pipe was no significant difference from took place at the joints, indicating an excellent        PE3408S. It produced a very uniform bead. The quality of the welds that include the cross fusion      butt-fusion jointed pipe failed at outside the samples. Second, the failures were always on the        joint, indicating the joint was stronger than the PE3408S side for the cross fusion samples,               bulk pipe for short-term. The hoop stress was indicating that both PEIOOE and PE3408E                 4264 psi, 69% higher than the requirement of performed better. At the condition of 23&deg;C and           2520"psi.
1800 psi, both PE3408E and PE1OOE performed about 4 times better than PE3408S, see Table 8.                McElroy developed the McSnapper TM machine specifically for polyolefinic materials Larger diameter pipe was also tested for fusion       to accurately test fusion joints. The McSnapper TM combines the tensile impact joining and burst pressure. A pipe manufacturer                                                       test ASTM extruded a 22" SDR 9 pipe from PE100E. The              D1822 and high-speed tensile test of ASTM pipe was butt-fusion jointed using PPI generic          2289 to provide an accurate test for fused joints.
fusion joining procedure of TR-33 by the same           PEIOOE, PE3408S and PE2406S were chosen pipe manufacturer. The quick burst test was               for the study. The extruded 8" SDR1 1 pipe was conducted at 2' C. The test result was listed in        butt-fused by McElroy using PPI TR-33 Table 9. The failed specimen was shown in                procedure (10). Two interfacial pressure (60 psi Figure 3.                                                and 90 psi) were used. They are the minimum and maximum interfacial pressure in PPI TR-33.
Four specimens from each joint configuration

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 16 of 17 were fabricated using a McElroy Coupon Cutter.        the pipe itself made from PE3408S. Based In addition to these samples, coupons were cut        on these data, the bimodal PE3408E will from pipe wall of PEIOOE and PE3408S to serve         perform better than both PE2406S and as controls for this study. Table 10 lists the        PE3408S. It can be used for new pipeline samples and the test results for the McSnapper        installations        and        replacement          or TM test.
improvement of an existing pipeline.
All the failures occurred in the pipe sidewall 3. PE100 bimodal resin opens opportunities for and none occurred at the actual fusion joints.        natural gas piping with improved pressure Additionally, no brittle failures were observed.       capability and resistance to SCG and RCP. It The data showed that joints of like pipes made         offers 42% higher-pressure capability over from PE100E displayed excellent strength               PE3408 around room temperatures. The compared to control samples without fusion             PENT lifetime is at least 10 times longer joints. The cross fusion of PE1OOE with                than the minimum requirement of 100 h.
PE3408S was stronger than joints of PE3408S with PE3408S, and even stronger than the           4. Enhanced PE100E has additional advantages PE3408S pipe itself. It appeared that PElOOE           over other PE100. It has 100-year MRS 10.0 could be butt-fused for good quality joints not        listing at 20&deg;C, 50-year MRS 8.0 at 40'C only with itself but also with PE3408S and             and 11-year MRS 6.3 at 60'C. It can be PE2406S.                                               used for application temperatures up to 60'C. It offers higher-pressure capability

==SUMMARY==
over PE3408 and PE2406 at the temperature range from the room temperature up to
: 1. Among the PE gas pipe materials currently          60 0 C.
used in North America, MDPE PE2406S is the preferred choice for small diameter pipe  5. There is no barrier to use the bimodal and low operation pressures below 70 psig.        PE3408E in the United States. PE 100 can Two key properties are attributed to the          be used outside of North America.
outstanding long-term performance. One is the 1000 psi HDB at 60'C. The other one is    6. MRS-rated materials have been listed in PPI TR-4. ASTM D3350 has recognized MRS-the resistance to SCG that is about 10 times rated PE materials. However, D2513 does higher than that of unimodal PE3408S not recognize MRS-rated materials. DOT material. For operation pressures above 70 psig, PE3408S is widely used. PE2406C is          regulations require HDB for calculating the less competitive.                                 MOP. A DOT waiver may be required for using PE100 materials in the United States.
: 2. Bimodal      PE3408E       HDPE      material     AGA is preparing a petition to DOT for outperforms all unimodal PE pipe materials        recognizing MRS-rated materials in CFR including both MDPE PE2406S and HDPE              title 49 part 192.
PE3408S. It has a higher-pressure capability than PE2406S at 23&deg;C and higher-pressure      ACKNOWLEDGMENTS capability at 60'C than PE3408S. Its resistance to SCG is better than MDPE            McElroy butt-fused all 1" SDR 11 and 8" SDR PE2406S and PE3408S. Its resistance to        11 pipe. They also tested the 8" SDR 11 joints RCP has a step improvement over PE2406S       using the McSnapper TM machine. Alan Jedic and PE3408S. It can be butt-fusion jointed    and Norman Chin of the Dow Pipe Technology with itself or PE2406C or PE3408S with        Center conducted the PENT and hydrostatic test.
high quality. Preliminary data indicated that the butt-fusion joints between this bimodal HDPE and other PE3408 were stronger than

Attachment 3 - Dow letter to Ameren dtd 6-24-08 Page 17 of 17 REFERENCES                                       12. N. Brown and X. Lu, "Controlling the Quality of PE Gas Piping Systems by
: 1. ASTM D2837-01 "Standard Test Method              Controlling the Quality of the Resin", 13th for Obtaining Hydrostatic Design Basis for       International Plastic Fuel Gas Pipe Thermoplastic Pipe Materials"                    Symposium, San Antonio, TX, 1993, p3 2 7
: 13. ISO 13477 "Thermoplastics Pipes for the
: 2. ISO/FDIS 9080-02 "Plastic Piping and Ducting Systems - Determination of Long-         Conveyance of fluids - Determination of term Hydrostatic Strength of Thermoplastics      resistance to rapid crack propagation (RCP)
Materials in Pipe Form by Extrapolation"         - Small-Scale Steady-State (S-4 Test) "
: 3. PPI TR-4 "PPI Listing of Hydrostatic Design Basis (HDB), Strength Design Basis (SDB), Pressure Design Basis (PDB) and Minimum Required Strength (MRS) Ratings for Thermoplastic Piping Materials or Pipe"
: 4. ASTM F1473-01 "Standard Test Method for Notch Tensile Test to Measure the Resistance to Slow Crack Growth of Polyethylene Pipes and Resins"
: 5. ASTM D2513-01 "Standard Specification for Thermoplastic Gas Pressure Pipe, Tubing, and Fittings"
: 6. ISO 4437-97 "Buried Polyethylene (PE)
Pipes for the Supply of Gaseous Fuels -
Metric Series - Specifications"
: 7. ASTM D3350-02 "Standard Specification for Polyethylene Plastics Pipe and Fittings Materials"
: 8. ISO 12162-95 "Thermoplastic Materials for Pipes and Fittings for Pressure Applications
    - Classification and Designation - Overall Service (Design) Coefficient"
: 9. PPI TN-18-98 "Policy for Determining long-term Strength (LTHS) by Temperature Interpolation"
: 10. PPI TR-33/2001 "Generic Butt Fusion Joining Procedure for Polyethylene Gas Pipe"
: 11. GRI Report "Impact Test that Predicts the Critical Temperature (CT) for Rapid Crack Propagation (RCP) in PE Gas Pipes',
Contract #5092-260-2356, 1998

Attachment 4- Dow letter to Ameren dtd 6-2408 Page of 27 L
I New Products, New Horizons: High Density Polyethylene (HDPE) Resins for Natural Gas Piping Z. Jimmy Zhou, David W. Kababik, Guylaine St. Jean and Quentin D. Eberhart Pipe Technology Center, The Dow Chemical Company 17th International Plastic Fuel Gas Pipe Symposium October 22, 2002, San Francisco

Attachment 4 - Dow letter to Ameren dtd 6-24-08 Page 2 of 27 Outline
* Introduction
         # Key Properties
             - Pressure capability (HDB/MRS)
             - Slow crack growth (SCG)
             - Rapid crack propagation (RCP)
* Fusion joints
* Summary 10/22/02 ZJZ             17th International Plastic Fuel Gas Pipe Symposium                                            Pg. 2

Attachment 4 - Dow letter toAmeren dtd 6-24-08 3 2
                                                                                                 . ,ofPage I
I What if Your Pipeline was Human?
* Human Being
                                                    -     Death
                                                    -     Lifetime
                                                    -    Time dependent strength
                                                    -     Health
                                                    -    Sudden death
                                                    -    Joints 10/22/02 ZJZ     17th International Plastic Fuel Gas Pipe Symposium                                           Pg. 3

Attachment 4- Dow letter to Ameren dtd 6&#xfd;24-08 Page    4of 27 I
L How Pipelines Can Fail in Service SLar,,,ge scale.J Rapid I*M Brittle: RCP Yield Local                    Log-er                                                            'L&#xfd;e. fects DeI Local ocal 10/22/02 ZJZ     17th International Plastic Fuel Gas Pipe Symposium                                           Pg. 4

Pipeline Design/Operation Considerations IMIMMR&#xfd; 9&#xfd;cg
[Durability                            RUP                    M* :Effiiciency::
J@U01M p.
10/22/02 ZJZ      17th International Plastic Fuel Gas Pipe Symposium         Pg. 5

PE Pipe Materials In North America Bimodal a) a.
0~
Unimc )dal                                 I L.
MIE MS                                 L PE3408 ii.&#xfd; 0-E 240.&deg; x
Mmwmmb&#xfd; Slow Crack Growth 10/22/02 ZJZ              17th International Plastic Fuel Gas Pipe Symposium         Pg. 6

Dow Material Designation Samples                                      Material Designation ASTM D3350,               ASTM D2513                 ISO 9080   ASTM D3350 PPI TR-4                                          IS012162 Pipe Grade               Pipe Category             Pipe Grade Cell Classification PE2406C         PE2406                        CDC                                234363A PE2406S         PE2406                        CEC                                234363A PE3408S         PE3408                        CDC                                345464C PE3408E        PE3408                         CEC            1*
346564C PE1OOS                                                             PE100        345566C 1*
PE100E                                                             PE100         346566C
                       -s        atn fo0     E30 10/22/02 ZJZ                   17th International Plastic Fuel Gas Pipe Symposium                            Pg. 7

Material Characterization Property             PE2406                           PE3408                     PE100 C               S               S                E         S             E Technology    Gas Phase       Slurry        Gas Phase         Gas Phase    Slurry      Gas Phase Molecular    Unimodal      Unimodal        Unimodal           Bimodal    Bimodal       Bimodal Structure Melt Index, 12     0.2            0.2              0.1              0.08      0.1           0.08 Flow Index, 121     18             20              8.3                9       6.8             9 Resin Density     0.939         0.940             0.944            0.949     0.951         0.949 Flexural      100,000       100,000          126,000          165,000    140,000       165,000 Modulus, psi Tensile Strength   2,800         2,800             3,200            3,600     3,700         3,600 at Yield, psi rowofer 10/22/02 ZJZ                           17th Intemational Plastic Fuel Gas Pipe Symposium                        Pg. 8

MAttachment 4- Dow lefterltoAmeren dtd 6-24-08 "1 Page9Wf27 "I*
Pressure Capability 7            Longer                                                               Elevated extrapolation?                                                       temperatures ?
I                                              .1 E5IrdsM 10/22/02 ZJZ             17th International Plastic Fuel Gas Pipe Symposium                                           Pg. 9

Longer Extrapolation by IS09080 Extrapolation Method                                 ISO 9080 23&deg;C Data              30 points>500 h, 4 points>7000 h and 4 points>9000 h 60 0 C Data             30 points>10 h, 7 points>7000 h and 3 points>9000 h 800 C Data            33 points>10 h, 11 points>7000 h and 10 points>9000 h Number of Parameters of the                                   4 Regression Equation Knee Position                              No knee is detected t,,. of Average of Longest Five                      21,746 h (2.5 years)
Points at 80*C Ductile Extrapolation Limit at 20*C                           250 years Ductile Extrapolation Limit at 40'C                           125 years Ductile Extrapolation Limit at 60'C                            15 years MRS at 20'C forl100 years                               10.0 MPa MRS at 231C for 50 years                                10.0 MPa MRS at 401C for 50 years                                8.0 MPa MRS at 601C for 11 years                                 6.3 MPa
                                           /
10/22/02 ZJZ                              17th Intemational Plastic Fuel Gas Pipe Symposium  Pg. 10

HDB/MRS Listing in PPI TR-4 Samples  Material                HDB, psi                          MRS, MPa Designation         230 C            600 C          200 C    400 C    60 0 C PE2406C   PE2406            1250*              800 PE2406S   PE2406            1250*             1000 PE3408S   PE3408            1600*              800 PE3408E   PE3408            1600*             1000 PElOOS    PE100             19
_  _          1000           10.0   1        1 1000           10.0   1  8.0   1  6.3 V
20'C for 1 00-y, 40'C for 50-y and 60'C for 11 -yI Also a PE100 at 230C 10/22/02 ZJZ                  17th International Plastic Fuel Gas Pipe Symposium                   Pg. 11

Maximum Operation Pressure, SDR 11 Pipe 170                                                  -     P E2406C
                                                          -A-   P E2406S 150                                                  PE3408S
                                                          ,---PE3408E
                                                          -- *. P ElOOS PE3408 E 130                                                                   outperforms 110                                                                    other HDB-C)
: 0.                                                                            rated 02     90                                                                    materials 70 50 30 -4 0 10 20   30          40            50           60          70 Temperature, oC 10/22/02 ZJZ         17th International Plastic Fuel Gas Pipe Symposium               Pg. 12

L                                                                      r, Attachment 4 =DBw Ietterto Ameren dtd '&24-08 Slow Crack Growth (SCG) 7SCG"resistance                                                                            PENT HoUrs controls field                                                                         The Longer, failure rates                                                                           The Be"tter                    A' SCG PENT hours Major failure mode                     PENT                                   >100 h PENT in field              Correlates with                                  ASTM D2513 field failure rates                                 Requirement 10/22/02 ZJZ             17th International Plastic Fuel Gas Pipe Symposium                                           Pg. 13

Slow Crack Growth (SCG)
Product             Material           SCG Cell Class                   PENT, hrs     Typical PENT, hrs Designation               D3350                         D2513            F1473 PE2406C              PE2406                       6                         >100             2500 PE2406S              PE2406                       6                         >100             3000 PE3408S              PE3408                       6                         >100               200 PE3408E              PE3408                       6                         >100             4000 DU IAA40            DU 1AA                                                 >,AA                AA 1- Jl_* Jl. VU 0    i.ILJ. IVVJ1                 V3                         - I VJ           *V)'J I                                I                 4 PE100E                                                                                      6000 10/22/02 ZJZ                            17th International Plastic Fuel Gas Pipe Symposium                     Pg. 14

Attachment 4 - Dow letter to Ameren dtd 6-24-08 Page 15 of27 Rapid Crack Propagation (RCP)
       ~PC Internal                                                                                          ITc Temperature pressure                                                                                 at 145 psig at 0&deg;C                              RCP                                        (232psig MOP)
S-4, Pc or Tc I
I                           - --- I-Rare but                  Temp > Tc                                 If Tc > OC Catastrophic         RCP impossible                              Restrict MOP Pipeline                                                        Pc>MOP/2.4 Failures                                                            ISO 4437 10/22/02 ZJZ                17th International Plastic Fuel Gas Pipe Symposium                                            Pg. 15

Rapid Crack Propagation (RCP)
Samples Material Designation                Tc, 0C                       Pc, bar   Pc, bar ISO 13477                    ISO 4437  ISO 13477 PE2406C        PE2406                        18-33 PE2406S        PE2406                        18-33 PE3408S        PE3408                         9-19 PE3408E         PE3408                         < -17                                  >12 4.2      >10 S
4.2      >12 10/22/02 ZJZ                    17th Intemational Plastic Fuel Gas Pipe Symposium                 Pg. 16

I                      7 Attachment 4 - Dow letter to.Ameren dtd 6-24-08 Page 17 of 27* -
Joint Integrity                         w Ho                  oste 7Hwde              ehne HDI       fue       it fsionjone itef     ote        DS
       -ndID.s Joints                     f A
Fusion I
I                               I                                              I. .   . . . .. . . .
Potential weak           PE much better                                        Integrity link in pipelines                than other                                of pipelines materials 10/22/02 ZJZ                   17th International Plastic Fuel Gas Pipe Symposium                                              Pg. 17

Attachment 4 - Dow letter to Ameren dtd 6-24 08 Page 18 of 27 Fusion Joints "I
Quality                                                                     Long term field of joints ?                                                                      performance ?
I                           I                                   I 10/22/02 ZJZ      17th International Plastic Fuel Gas Pipe Symposium                                            Pg. 18

PEI00 E Quick Burst Test 22" SDR 9 Butt-fusion Joined Pipe Pipe Sample                        PE1OOE 69% higher than Pipe Outside Diameter, inches                22.025 Minimum Wall Thickness, inches                  2.496                           the requirement, Test Condition                        230C                          2520 psi, for PE3408 Internal Pressure, psig                    1090                                            --.4A Hoop Stress, psi                       4264 10/22/02 ZJZ                           17th International Plastic Fuel Gas Pipe Symposium                    Pg. 19

                                                                                                                     *Z
                                                                       ;Att chment 4 Dowetter to Ameren dtd 6-24-08
                                                                                                     .Page 20of 27__
62OW I
                                                                                                                        !2za PE3408E Quick Burst Test 20" SDR 11 Butt-fusion Joined Pipe Pipe Sample                                            PE3408E Pipe Outside Diameter, inches                                         20.0 Minimum Wall Thickness, inches                                         1.81 Test Condition                                               23 0 C Internal Pressure, psig                                            900 Hoop Stress, psi                                              4522 W_
79% higher than the requirement, 2520 psi, for PE34 8 L
10/22/02 ZJZ             17th International Plastic Fuel Gas Pipe Symposium                                              Pg. 20

Attachment 4.- Dow letter to Ameren dtd 6-24-08 Hydrostatic Test: HDPE ett, 7   B etter uct Joint DDuctile:         4 times      s      and all failures in PE3408S Brittle: >5 times; failed in joints ross fusion: 28%
C Hydrostatic Test                   Failure Times, hours PE3408E- PE3408S-                     PE3408E-PE3408E PE3408S                      PE3408S 7CC,6',eackek   23 0 C, 1800 psi        254/D              67/D                61/D                                     Th"(00)=
Ou''Ictillb'i,  80 0 C psi 379 1000/NF Reference 204/B.              261/B
                                                                                                                  ~I0      @&R 3)C
                                                                                                                          )h
                        %                >491           Reference               128 10/22/02 ZJZ               17th International Plastic Fuel Gas Pipe Symposium                                                Pg. 21

L                                                                             }Afahet4 -Dow lette-rto Atnereh dtd 6-124MO ttchen          -         Pagek?2o 27 Hydrostatic Test: MDPE Hydrostatic Test                   Failure Time, hrs PE3408E- PE2406C- PE3408E-PE3408E PE2406C PE2406C                                                       Check 23C, 1600 psi           140/NF               69/D             63/D l rit,,tle C,hielc h k&#xfd; k-        %                   >203           reference Dructil'e--',     80C, 800 psi          1100/NF             0.58/D             1.3/D
                        %                  >1900           reference, 10/22/02 ZJZ              17th International Plastic Fuel Gas Pipe Symposium                                            Pg. 22

11l-Attachment.4 - Dow letter to Ameren dtd 6-24-08 J                  Page 23 of 2  -  ...
McSnapperTM                                                    U U      PEIOOE and PE3408S 8" SDR 11 Butt-fusion Joined Pipe 4500 4000-U,     3500  -
U)     3000  -
0.
U)
()     2500  -
C,)     2000  -
1500  -
E      1000  -
500 0        LI. __________ LZ _____ ~J ___________ LZ ______ LI. __________ U: ______ L.L.........................LJ    _____
PE100E            PE1O0E-                  PE1O0E-                 PE3408S-                            PE3408S PE100E                 PE3408S                  PE3408S Pipe 10/22/02 ZJZ                                        17th International Plastic Fuel Gas Pipe Symposium                                                                               Pg. 23

McSnap                                U]
U]     PE3408E and PE2406S 2" SDR 11 Butt-fusion Joined Pipe 4000 3500-U)      3000 2500 E) 2000
: 5)      1500 1000 500 0  .4. j~                  _______________     -~           __________ _______
PE3408E  PE3408E-                 PE3408E-         PE2406S PE3408E                   PE2406S Pipe 10/22/02 ZJZ                    17th International Plastic Fuel Gas Pipe Symposium           Pg. 24

____              Attachment 4- Dow letter to Ameren dtd 6-24-08
______________Page                                                   25 of 27 Summary: HDB-rated M-aterials PE3408E
             - Improved safety, durability and efficiency;
             - Higher MOP from 230C to 60'C;
             - Much better SCG resistance;
             - Much better RCP resistance;
             - High quality improved butt-fusion joints with itself, other PE3408 and PE2406;
             - DOW DGDC-2480 BK 3408 is the enhanced PE3408 10/22/02 ZJZ                17th International Plastic Fuel Gas Pipe Symposium                                            Pg. 25

Attachment 4 - Dow letter to Ameren dtd 6-24-08 Page 26 of 27 Summary: MRS-rated Materials
* PE100E
             - Improved safety, durability and efficiency;
             - MRS listing for 100 years at 20&deg;C and at elevated temperature;
             - Higher MOP than all HDB-rated materials;
             - Better SCG and RCP resistance than HDB-rated materials;
             - High quality improved butt-fusion joints with itself, other PE3408 and PE2406
             - DOW DGDA-2490 BK 100 is the enhanced PEI00 10/22/02 ZJZ               17th International Plastic Fuel Gas Pipe Symposium                                            Pg. 26

Attachment 4 - Dow letter to Ameren dtd 6-24-08 Page     of 27 Thank You for Your Attention i Questions?
10/22/02 ZJZ        17th International Plastic Fuel Gas Pipe Symposium                                             Pg. 27 to ULNRC-05517 Enclosure 4 Callaway Calculation No. 2007-13241

ISSUE 

==SUMMARY==
PN       14  1+
Form SOP-0402-07, Revision 7B                                               TU 11,7los DESIGN CONTROL 

==SUMMARY==

CLIENT:                AmerenUE                                            UNIT NO.:   1         Page No.: 1 (4  i*)
PROJECT NAME:          Callaway Nuclear Plant PROJECT NO.:           11504-021                                                 [   NUCLEAR SAFETY- RELATED CALC. NO.:             2007-13241                                                El  NOT NUCLEAR SAFETY-RELATED TITLE:                 Minimum Wall Thickness for ESW Buried HDPE Piping EQUIPMENT NO.:
IDENTIFICATION OF PAGES ADDED/REVISED/SUPERSEDEDNOIDED & REVIEW METHOD INITIAL ISSUE See Limitations in Section 6.3                                                                INPUTS/ ASSUMPTIONS
[] VERIFIED El UNVERIFIED REVIEW METHOD:          Detailed Review                                                    REV. 0 STATUS:                                                                         DATE FOR REV.:
PREPARER        M. Tam           *     ..         -                                      DATE: X              OL PREPARER        T. Musto (Section 6.4)    t    ,,                                        DATE:
REVIEWER        J. Saltarelli   d, a'4A.*.-                                              DATE:7 APPROVER                        V                                                        DATE:
IDENTIFICATION OF PAGES ADDED/REVISED/SUPERSEDEDNOIDED & REVIEW METHOD INPUTS/ ASSUMPTIONS El VERIFIED El UNVERIFIED REVIEW METHOD:                                                                             REV.
STATUS:                                                                         DATE FOR REV.:
PREPARER                                                                                  DATE:
REVIEWER                                                                                  DATE:
APPROVER                                                                                  DATE:
IDENTIFICATION OF PAGES ADDED/REVISED/SUPERSEDEDNOIDED & REVIEW METHOD INPUTS/ ASSUMPTIONS EDVERIFIED El UNVERIFIED REVIEW METHOD:                                                                            REV.
STATUS:                                                                        DATE FOR REV.:
PREPARER                                                                                 DATE:
REVIEWER                                                                                 DATE:
APPROVER                                                                                  DATE:
NOTE: PRINT AND SIGN IN THE SIGNATURE AREAS SOP040207.DOC                                                    ft'.4ofi,-      Qlv. 811$/08 Rev. Date: 11-12-2007

Calculation 2007-13241 Revision 0 Page 2 of 14 TABLE OF CONTENTS 1.0  PURPOSE AND SCOPE .................................................................................                          3 2.0  DESIGN INPUTS ..............................................................................................                4 3.0  ASSUM PTIO NS ................................................................................................              6 4.0  M ETHODOLOGY AND ACCEPTANCE CRITERIA ...........................................                                             7 5.0  CALCULATIONS ............................................................................................                  10 6 .0 R E S U LT S ..................................................................... ....................................... 1 2

==7.0  REFERENCES==
 .................................................................................................               14 8.0  ATTACHM ENTS ..............................................................................................                14

Calculation 2007-13241 Revision 0 Page 3 of 14 1.0 PURPOSE AND SCOPE The purpose of this calculation is to determine the minimum required wall thickness for the Callaway Nuclear Plant ESW buried High Density Polyethylene (HDPE) supply, return, and strainer backwash straight piping that is to replace the currently existing buried carbon steel piping under modification number MP 07-0066 [Ref. 7.2.1]. This calculation does not apply to fittings and components.
Specifically, this calculation applies to the following line numbers:
EF-002-HBC-4" - ESW Train 'A' Strainer       Backwash Line EF-003-HBC-30" - ESW Train 'A' Supply        from ESW Pumphouse EF-006-HBC-4" - ESW Train 'B' Strainer       Backwash Line EF-007-HBC-30" - ESW Train 'B' Supply        from ESW Pumphouse EF-083-HBC-30" - ESW Train 'A' Return        to UHS Cooling Tower EF-140-HBC-30" - ESW Train 'B' Return        to UHS Cooling Tower Note: As a result of the replacements performed under modification number MP 07-0066 [Ref. 7.2.1], the material designation code (HBC) as defined by MS-02 [Ref. 7.2.7]
will change for the replaced sections of the above lines.

Calculation 2007-13241 Revision 0 Page 4 of 14 2.0 DESIGN INPUTS 2.1 ESW HDPE Supply Lines Internal design pressure   (PD) = 165 psig [Ref. 7.2.1]
Design temperature (TD) = 95&deg;F [Ref. 7.2.1]
Outside diameter of pipe (D) = 36" [Ref. 7.2.1]
Piping Material: PE 4710 with material properties not less than those for cell classification 445574C as defined by ASTM D3350 [Ref. 7.2.1]
2.2 ESW HDPE Return Lines Internal design pressure (Po) = 45 psig [Ref. 7.2.1]
Design temperature (Tc)     = 175&deg;F [Ref. 7.2.1]
Normal Operating Temperature (T,) = 105'F [Ref. 7.2.8]
Outside diameter of pipe (D) = 36" [Ref. 7.2.1]
Piping Material: PE 4710 with material properties not less than those for cell classification 445574C as defined by ASTM D3350 [Ref. 7.2.1]
2.3 ESW HDPE Backwash Lines Internal design pressure (PD)   = 160 psig [Ref. 7.2.1]
Design temperature (TD) = 95&deg;F [Ref. 7.2.1]
Outside diameter of pipe (D) = 4.5" [Ref. 7.2.1]
Piping Material: PE 4710 with material properties not less than those for cell classification 445574C as defined by ASTM D3350 [Ref. 7.2.1]
2.4 Design Code The design code for the HDPE piping is ASME Code Case N-755 '.'Use of Polyethylene (PE) Plastic Pipe for Section III, Division I, Construction and Section Xl Repair/Replacement Activities" [Ref. 7.1.1] per modification number MP 07-0066 [Ref.
7.2.1].
2.5 Mechanical and Erosion Allowance No mechanical or erosion allowance (C) is considered in the minimum wall thickness calculation (See Assumption 3.1) [Ref. 7.2.4, p. 8].

Calculation 2007-13241 Revision 0 Page 5 of 14 2.6 Normal Service Life The replacement buried piping shall be designed for a service life of 40 years under normal system operating conditions as stated in Reference 7.2.2, Section 6.1.1.
2.7 Post-Accident Service Life The replacement buried piping shall be designed for a service life of 30 days at peak post-accident system operating conditions. The design shall assume that the peak post-accident conditions occur continuously for the entire 30 day period and that the accident occurs at the end of the 40 year normal service life as stated in Reference 7.2.2, Section 6.1.2.
2.8 Allowable Stress Allowable stress values for HDPE must be based on values determined through testing at conditions that bound the design conditions of the replacement buried piping and formally accepted for use at Callaway Nuclear Plant by the Nuclear Regulatory Commission as stated in Reference 7.2.2, Section 6.9. The following values are used within this calculation based on direction provided in Reference 7.2.5. The use of these values for Callaway Nuclear Plant still requires formal acceptance by the NRC (Limitation 6.3.1).
Table 2.8 Allowable Stress Service Temp. (OF)     Load Duration (yrs) Allowable Stress (psi) 95&deg;F                      -50                      695 104 0 F                  <50                       653 113 0 F                   _50                      613 176 0 F                   2.5                      340 Note: While Reference 7.2.5 only provides values for a load duration of 50 years, these values can conservatively be used for load durations of less than 50 years.

Calculation 2007-13241 Revision 0 Page 6 of 14 3.0 ASSUMPTIONS

===3.1 Assumption===
No mechanical or erosion allowance (C) is considered in the minimum wall thickness calculation.
Justification:
HDPE pipe will not rust, rot, pit, corrode, tuberculate or support biological growth. It has superb chemical resistance and is the material of choice for many harsh chemical environments [Ref. 7.2.4, p. 8]. Therefore, no mechanical or erosion allowance is required. This is consistent with Reference 7.2.2, Section 6.2.

===3.2 Assumption===
The allowable stress value for the HDPE Return Lines for a post-accident condition service life of 30 days is 340 psi at 175&deg;F.
Justification:
The only allowable stress value data available near 175 0 F is 340 psi at 176&deg;F for a load duration of 2.5 years in Reference 7.2.5 [Design Input 2.8]. The allowable stress for 2.5 years is lower than the allowable stress for 30 days and the allowable stress at 176&deg;F is lower than the allowable stress at 175 0 F. This will result in a larger minimum wall thickness for the 30 day post-accident condition service life case at 175 0 F for the HDPE Return Lines. Therefore, it is conservative to use 340 psi.

Calculation 2007-13241 Revision 0 Page 7 of 14 4.0   METHODOLOGY AND ACCEPTANCE CRITERIA 4.1   Methodology 4.2   Allowable Stress for HDPE Return Lines Since the allowable stress value at a design temperature of 175&deg;F for the HDPE Return Lines has only been provided for a maximum load duration of 2.5 years in Reference 7.2.5, an allowable stress value is calculated for the Normal Operating Condition case as defined by Miner's Rule using the methodology in Sections 4.2.1 and 4.2.2 and 340 psi for the 30 day Post-Accident Condition case (See Assumption 3.2). A minimum wall thickness will be calculated for both the Normal Operating Condition and the 30 day Post-Accident Condition and the larger of the two shall be conservatively used for the HDPE Return Lines.
4.2.1 Miner's Rule to Calculate Load Duration Miner's Rule takes into consideration the damages done to the pipe under different operating conditions to calculate the cumulative maximum permissible time of use under all varying conditions of the pipe. For the HDPE return lines, Normal Operating Conditions and Post-Accident Operating Conditions are considered. The cumulative maximum permissible time of use is the design service life of 40 years.
To calculate the allowable stress value for Normal Operating Conditions, Miner's Rule for plastic pipe [Ref. 7.2.6] is used to find the load duration for the pipe under normal operating conditions that will ensure a cumulative maximum permissible time of use of 40 years when considering the 30 day load duration at Post-Accident Operating Conditions. This load duration can then be used to interpolate a corresponding allowable stress value using the values in Reference 7.2.5 at the normal operating temperature of 105&deg;F. The allowable stress value for a load duration of < 50 years at 105&deg;F is provided in Reference 7.2.5 [Design Input 2.8]. The following variables are used by Miner's Rule:
T,       = normal operating temperature (OF)
Tmax     = maximum operating temperature (post-accident temperature) (&deg;F)
Ai       = percent of total service life of pipe under condition "i" (i=1, 2, 3, etc.) (%)
tI       = lifetime of pipe if placed under condition "i" (yrs) tmax     = lifetime of pipe if placed under maximum operating temperature Tmax (yrs) to       = lifetime of pipe if placed under normal operating temperature T. (yrs) tx       = maximum permissible time of use under all varying conditions (yrs)
TYD      = total yearly damage (%)
The percent of total service life of the pipe under each condition "i" is calculated for i=1, 2, 3, etc.
(yrs)
Ai = Time Under Condition "i" Total Service Life of Pipe (yrs)

Calculation 2007-13241 Revision 0 Page 8 of 14 Each condition which the pipe is exposed to generates a yearly damage percentage on the pipe.
Yearly Damage = Ai                Time Under Condition "i" (yrs) tj     Lifetime of Pipe Under Condition "i" (yrs)
The summation of these yearly damages is the total yearly damage.
TYD = YAi    ti The total yearly damage (TYD) is used to find the maximum permissible time of use under all varying conditions.
                                                  = 100 TYD To find the load duration for the pipe under normal operation, Miner's Rule is rearranged to solve for to, the lifetime of pipe if placed under only the normal operating temperature To = 105 0 F. This duration will be longer than tx, the maximum permissible time of use under all varying conditions, and will provide a lower allowable stress value. Therefore, the minimum wall thickness calculated using this value for allowable stress for Normal Operating Conditions will result in a larger minimum wall thickness which is conservative.
First, solve for the percent of the total service life of the pipe that is exposed to the normal operating temperature and the post-accident temperature to obtain Ao and Amax respectively. Then calculate the yearly damage percentages on the pipe from the Normal Operating and Post-Accident Condition where to is the unknown variable to solve for and tmax is 2.5 years as stated in Assumption 3.2.
yearly damage from post - accident condition     =  Amax t max yearly damage from normal operating condition       =  A.
to Summate the yearly damages to obtain the total yearly damage as a function of to.
TYD= YAi          A. + Amax tj    to     tmax With the maximum permissible time of use under all varying conditions set.as 40 years, tx = 40 years, substitute the TYD and solve for to.
tx_-100  -*40=-       100 TYD            A. Amax to +
tmax

Calculation 2007-13241 Revision 0 Page 9 of 14 4.2.2  Interpolation for Allowable Stress Values for Normal Operating Condition Case of the HDPE Return Lines Using the Calculated Load Duration (to)
To determine the allowable stress values for the Normal Operating Condition case, interpolate between the load durations of 50 years and the calculated to load duration.
4.3    Minimum Wall Thickness The required minimum wall thickness is determined for the pipe lines identified in Section 1.0 of this calculation. The required minimum wall thickness (tdesign) is calculated in accordance with ASME Code Case N-755 [Ref. 7.1.1, Section 3021.1] as follows:
tdesign -2S +    CD tmin where:
tdesign  = minimum required wall thickness (in) tmin     = pressure design thickness (in)
C        = the sum of mechanical allowances and erosion allowance (in)
PD      = piping system internal Design Pressure (gage) at the corresponding Design Temperature TD. This pressure does not include the consideration of pressure spikes due to transients (psig)
D       = pipe outside diameter at the pipe section where the evaluation is conducted (in)
S        = allowable stress (psi) 4.4   Acceptance Criteria None

Calculation 2007-13241 Revision 0 Page 10 of 14 5.0   CALCULATIONS 5.1   Calculation of Normal and Post-Accident Condition Allowable Stresses Values for HDPE Return Lines 5.1.1 Percent of total service life of the pipe under each condition.
Ao = 40years - 30days(post-accident) = 39.92years x1 00% = 99.8%
40years A  max =   30days(post-accident) = 0.08years x1 00% = 0.2%
40years 5.1.2 Summate the yearly damages to obtain the total yearly damage as a function of to.
TYD=       A       99.8% +      0.2%
tj       to      2.5years 5.1.3 Substitute the TYD and solve for to.
100                              100_______
tx     TYD -> 40years       =           100 0%         to = 41.2years TY                9.8%         0.2%       0 to        2.5years 5.1.4 Interpolate between temperatures of 113&deg;F and 104 0 F to find the allowable stress value S105oFat 105 0 F and 50 years from Design Input 2.8.
(613 psi-653 psi)           0   0                s68 1050F      (113 0F-   104F-p 5.1.5 Interpolate between the load durations of 50 and 40 years to find the correlating to load duration allowable stress at 105 0 F [Design Input 2.8].
St. 0  &deg;     (648.6 psi -648.6 Psi) (4 1. 2yrs - 40yrs) + 648.6 psi = 648.6 psi Table 5.1.5 HDPE Return Line Normal Operation Allowable Stress Load Duration 40 yrs               to = 41.2 yrs;           50 yrs Allowable             S            = 648.6      S5        = 648.6      S1OF = 648.6 Stress (S) (psi)          tx'1&deg;5&deg;F                 t&deg;,105&deg;F                1 Table 5.1.5 HDPE Return Line Post-Accident Allowable Stress (See Assumption 3.2)                Load Duration 30 days Allowable Stress (S) (psi)              S175&deg;F   = 340

Calculation 2007-13241 Revision 0 Page 11 of 14 5.2     Minimum Calculated Wall Thicknesses 5.2.1   Supply Lines Under an internal design pressure of 165 psig (Design Input 2.1), design temperature of 95 0 F (Design Input 2.1), mechanical and erosion allowance of 0" (Design Input 2.5), and allowable stress of 695 psi (Table 2.8-1) for both supply lines, the PE 4710 36" diameter ESW HDPE supply line piping minimum required wall thickness is:
tdesign, supply            (165psigX36")        + 0  = 3.82" 2(695psi) + 165psig 5.2.2   Return Lines 5.2.2.1 For the Normal Operating Conditions case, an internal design pressure of 45 psig (Design Input 2.2), design temperature of 105&deg;F (Design Input 2.2), mechanical and erosion allowance of 0" (Design Input 2.5), and allowable stress of 648.6 psi (Table 5.1.5-1) for both return lines, the PE 4710 36" diameter ESW HDPE return line piping minimum required wall thickness is:
tdesign, r     n n(45psig)36")                            +0 =  1.21"
                  ,return, normal op.       2(648.6psi) + 45psig 5.2.2.2 For the Post-Accident Conditions case, an internal design pressure of 45 psig (Design Input 2.2), design temperature of 175 0 F (Design Input 2.2), mechanical and erosion allowance of 0" (Design Input 2.5), and allowable stress of 340 psi (Table 5.1.5-2) for both return lines, the PE 4710 36" diameter ESW HDPE return line piping minimum required wall thickness is:
t     (45psig)(36")     + 0 = 2.235"= bounding minimum wall value tdesign, return, post-accident -    2(340psi) + 45psig 5.2.3   Backwash Lines Under an internal design pressure of 160 psig (Design Input 2.3) and design temperature of 95&deg;F (Design Input 2.3), mechanical and erosion allowance of 0" (Design Input 2.5), and allowable stress of 695 psi (Table 2.8-1) for both backwash lines, the PE 4710 4.5" diameter ESW HDPE backwash line piping minimum required wall thickness is:
tdesign backwash backwash        2(695psi)     + 160psig + 0 = 0.465" (1 60psig)(4.5")

Calculation 2007-13241 Revision 0 Page 12 of 14 6.0   RESULTS 6.1   Results The required minimum wall thicknesses for the ESW buried HDPE pipes are shown below in Table 6.1-1:
Table 6.1 Summary of Results Line No.                      Min. Wall Thickness (in)
EF-003-HBC-30" - ESW Train 'A'                 3.82" Supply from ESW Pumphouse EF-007-HBC-30" - ESW Train 'B'                3.82" Supply from ESW Pumphouse EF-083-HBC-30" - ESW Train 'A'               2.235" Return to UHS Cooling Tower EF-140-HBC-30" - ESW Train 'B'               2.235" Return to UHS Cooling Tower EF-002-HBC-4" - ESW Train 'A'                0.465" Strainer Backwash Line EF-006-HBC-4" - ESW Train 'B'                0.465" Strainer Backwash Line Note: As a result of the replacements performed under modification number MP 07-0066 [Ref. 7.2.1], the material designation code (HBC) as defined by MS-02 [Ref. 7.2.7]
will change for the replaced sections of the above lines.
6.2   Conclusions The required minimum calculated wall thickness values provided in Section 6.1 of this calculation apply to straight pipe only and include 0.0" mechanical and erosion allowance. Nominal wall thickness values for the applicable lines must account for manufacturing tolerances such that the as-manufactured minimum wallthickness values for the piping are greater than or equal to the required values.
6.3   Limitations 6.3.1 The allowable stress values used within this calculation are based on values provided in Reference 7.2.5. The use of these values for Callaway Nuclear Plant still requires formal acceptance by the NRC.
6.3.2 This calculation uses Miner's Rule methodology as defined in Reference 7.2.6. The use of this methodology for.Callaway Nuclear Plant still requires formal acceptance by the NRC.

Calculation 2007-13241 Revision 0 Page 13 of 14 6.4   Impact Assessment The following sections identify the documents reviewed for impact by this calculation and summarize the results of the impact assessments. Impacts as a result of the piping replacement being performed under MP 07-0066 are identified and evaluated as part of MP 07-0066.
6.4.1 FSAR / Site Addendum The following sections of the standard plant FSAR and site addendum were reviewed for impact by this calculation:
3.9(B) (SP): Minimum wall thickness is not discussed in the FSAR for the design of non-NSSS piping. (NOT IMPACTED) 9.2 (SP and SA): This calculation does not change the design basis functions of the ESW system, design conditions of the ESW piping or design heat loads acting on the ESW system. (NOT IMPACTED) 6.4.2 Technical Specifications / Technical Specification Bases The following sections of the technical specifications and technical specification bases were reviewed for impact by this calculation:
3.7.8 / B 3.7.8: This calculation does not change any surveillance requirements for the ESW system. None of the bases for the surveillance requirements are impacted. (NOT IMPACTED) 6.4.3 Other Documents MS-02: A new material designation must be added to MS-02 for HDPE. This material designation must ensure that the nominal wall thickness values of installed HDPE piping will provide actual minimum wall thickness values greater than or equal to the required minimum wall thickness values determined in this calculation. (IMPACTED) 6.4.4 Design and Operating Margins This calculation determines required minimum wall thickness for the subject replacement ESW piping. The nominal wall thickness of the installed piping, and hence the margin between the as-manufactured minimum wall thickness and the required minimum wall thickness, will be identified by MP 07-0066.

Calculation 2007-13241 Revision 0 Page 14 of 14

==7.0   REFERENCES==

7.1   Codes 7.1.1 ASME Code Case N-755, "Use of Polyethylene (PE) Plastic Pipe for Section III, Division 1, Construction and Section XI Repair/Replacement Activities", as approved by the Board on Nuclear Codes and Standards on 03/22/2007 (Prior to incorporation of ASME Editor changes made in PDF Release) 7.2   Miscellaneous 7.2.1 Callaway Nuclear Plant Modification No. MP 07-0066, "Replace Buried ESW Piping with HDPE Material" 7.2.2 Callaway Nuclear Plant Design Specification No. M-2017, Rev.0, "Design Specification for Replacement ASME Section III Buried Essential Service Water System Piping" 7.2.3 S&L Calculation 2007-11380, Rev. 1, "Determination of Peak ESW Buried Piping Operating Conditions" 7.2.4 The Plastics Pipe Institute, Inc. "Handbook of Polyethylene Pipe", First Edition 7.2.5 Letter NEMM 07-0038 from Matt Brandes (AmerenUE) to Mr. Musto (Sargent & Lundy, LLC) dated 11/30/2007, "Design Inputs for Development of MP 07-0066, ESW Buried Piping Replacement" (See Limitation 6.3.1) 7.2.6 The International Organization for Standardization, ISO 13760:1998(E), "Plastics Pipes for the Conveyance of Fluids Under Pressure - Miner's Rule - Calculation Method for Cumulative Damage" (See Limitation 6.3.2) 7.2.7 Callaway Nuclear Plant Drawing MS-02, Rev. 83,-"Piping Class Sheets" 7.2.8 Callaway Nuclear Plant Document MS-01, Rev. 96, "Piping Class Summary" 8.0   ATTACHMENTS
: 1. Letter NEMM 07-0038 from Matt Brandes (AmerenUE) to Mr. Musto (Sargent & Lundy, LLC) dated 11/30/2007, "Design Inputs for Development of MP 07-0066, ESW Buried Piping Replacement"                                                    3 Pages
: 2. AmerenUE Owner's Review Comments                                                    Later

Calculation 2007-13241 Revision 0 Attachment 1 Page 1 of 3 Attachment 1 Letter NEMM 07-0038 from Matt Brandes (AmerenUE) to Mr. Musto (Sargent & Lundy, LLC) dated 11/30/2007, "Design Inputs for Development of MP 07-0066, ESW Buried Piping Replacement"

Calculation 2007-13241 Revision 0 Attachment 1 Page 2 of 3 AmerenUE                                                                                   PO Box 620 Callaway Plant                                                                             Fulton, MO 65251 NEMM 07-0038 November 30, 2007 Mr. Thomas M. Musto Senior Associate Sargent & Lundy, LLC 55 East Monroe St.
Chicago, IL 60603

==Subject:==
Design Inputs for Development of MP 07-0066, ESW Buried Piping Replacement

==Reference:==
: 1. MP 07-0066, "Replace Buried ESW Piping with HDPE Material"
, i~ereg    Dear Mr. Musto" IEi   Sargent and Lundy (S&L) have requested that Ameren UE provide the following information as design UFE   inputs for development of Reference 1. The design inputs that are requested are:
: 1. Stress allowables for the high density polyethylene (HDPE) piping at temperatures above those currently provided in ASME Code Case N-755.
: 2. Elastic modulus values for the HDPE piping at temperatures above those currently provided in ASME Code Case N-755.
The information requested is being transmitted in the attachments to this letter.
For item 1, the stress allowables for HDPE provided by this transmittal are equivalent to the tables currently being added to the planned revision of Code Case N-755 (i.e. Revision 1), which is under review of ASME. During the ASME code committee meeting in November 2007, the issue of design factor was discussed. Although the ASME may yet approve a design factor greater than 0.5, for the scope of MP 07-0066, a design factor of 0.5 should be used.
For item 2, the elastic modulus to be used is table 3031-3 in ASME Code Case N-755, "Use of Polyethylene (PE) Plastic Pipe for Section III, Division 1, Construction and Section XI Repair/Replacement Activities", as approved by BPV Standards Committee 02/02/2007". This table is equivalent to Table 3210-3 in the current Code Case N-755 Rev. 0. Based on discussion with Frank Schaaf and Bill Adams (WL Plastics), the use of the elastic modulus values at 140&deg;F for temperatures higher than those currently provided in ASME Code Case N-755 (i.e. >140&deg;F) is conservative for thermal expansion and contraction stress calculations. For ring deflection and buckling due to external pressure, a minimum elastic modulus of 2 ksi for temperatures less than or equal to 176&deg;F can be used for the PE 4710 material. Industry testing is currently being performed to determine actual values.
However, based on linear extrapolation of the data in Code Case N-755, the actual value is expected to be higher. Therefore, the use of a value of 2 ksi is expected to be conservative.
Sincerely, Matt Brandes Attachment cc: S. L. Abel J. E. O'Sullivan A160.2001 a subsidiaryof Amoren Corporation

Calculation 2007-13241 Revision 0 Attachment 1 Page 3 of 3 NEMM070038 Attachment 1 Table 3021-1 Allowable Design Stress, S, for PE4710 (Dow DGDA-2490/2492)* (psi)
Service                                             Load Duration Temperature                        2.5 Years                                  50 Years**
OF (0C)         0.50 DF 1 0.56 DF              0.63 DF       0.50 DF        0.56 DF        0.63 DF 73( 23)                      Not Applicable                     800            889           1000 86 (30)                      Not Applicable                     738            826            929 95 (35)                      Not Applicable                     695            778            875 104 (40)                      Not Applicable                     653            732            823 113 (45)                      Not Applicable                     613            687            773 122(50)                       Not Applicable                     574            643            724 131 (55)                      Not Applicable                     537            601            676 140 (60)                      Not Applicable                     500            560           630 176 (80)           340       T      382           430                   Not Applicable
* Values not applicable to all materials.
** For service temperature 140'F ( 60'C), use 50-year allowable design stress for service life 50-years.
Page 1 of 1

Calculation 2007-13241 Revision 0 Attachment 2 Page 1 Attachment 2 AmerenUE Owner's Review Comments To ULNRC-05517 Enclosure 5 AmerenUE Callaway Nuclear Plant 10 CFR 50.55a Request Number I3R-10 Proposed Alternative to ASME Section XI Requirements for Replacement of Class 3 Buried Piping in Accordance with 10 CFR 50.55a(a)(3)(i)
(Includes attachment, "Requirements for HDPE Piping for Nuclear Service," dated July 10, 2008)

AmerenUE 10 CFR 50.55a Request Number 13R-10 Page 1 of 3 10 CFR 50.55a Request Number 13R-10 1.ASME Code Component(s) Affected ASME Class 3 buried Essential Service Water (ESW) System piping.

===2. Applicable Code Edition and Addenda===
ASME Boiler and Pressure Vessel Code, Section XI, Division 1, 1998 Edition through 2000 Addenda.

===3. Applicable Code Requirement===
ASME Section XI, IWA-4221 (b) requires that "an item to be used for repair / replacement activities shall meet the Construction Code specified in accordance with (1), (2), or (3) [of IWA-4221 (b)]", and ASME Section XI, IWA-4221 (b)(1) requires that "when replacing an existing item, the new item shall meet the Construction Code to which the original item was constructed."

===4. Reason for Request===
A modification has been proposed for Callaway in which the underground steel piping of the ESW system would be replaced with piping made from high-density polyethylene (HDPE).
The Construction Code of record for buried ASME Class 3 ESW piping is ASME Boiler and Pressure Vessel Code, Section III, Division 1, Subsection ND, 1974 Edition, through Summer 1975 Addenda. This Construction Code and later editions and addenda of this Construction Code do not provide rules for the materials, design, fabrication, installation, examination and testing of piping constructed with polyethylene material.
Therefore, this request is being submitted to allow the replacement of buried steel piping in the Callaway ESW system with polyethylene piping. The replacement will be in accordance with the attached document, "Requirements for HDPE Piping for Nuclear Service," dated July 10, 2008.
: 5. Proposed Alternative and Basis for Use The attached document, "Requirements for HDPE Piping for Nuclear Service," dated July 10, 2008 provides the requirements for material, design, fabrication, installation, examination and testing of high density polyethylene piping, and reflects an acceptable level of quality and safety for repair / replacement activities for ASME Section III, Division 1 Class 3 buried piping.
1

AmerenUE 10 CFR 50.55a Request Number 13R-10 Page 2 of 3 The Callaway ESW system was originally designed with unlined carbon steel piping. Plant specific and industry operating experience has shown that carbon steel piping is susceptible to fouling, corrosion, and microbiologically induced corrosion (MIC) for raw water applications.
The use of corrosion resistant steel piping provides added resistance to these problems, but does not eliminate susceptibility. Alternatively, the use of internal linings or coatings in carbon steel piping provides resistance to these problems. However, degradation of and/or damage to the linings and coatings can cause exposure of the carbon steel piping to the raw water, resulting in piping degradation. Additionally, the linings and coatings can pose a potential foreign material concern if they are released from the piping wall as a result of the degradation or damage.
Polyethylene piping pipe will not rust, rot, pit, corrode, tuberculate, or support biological growth.
The use of polyethylene piping in raw water applications will thus ensure long term reliability from a structural integrity and flow standpoint. Callaway has recently installed approximately 600 linear feet of 36-inch diameter buried polyethylene piping in a non-safety related blowdown application and has not experienced any significant problems. On a larger scale, Duke Power Company has installed 20,000 linear feet of polyethylene piping at Catawba Nuclear Station in non-safety related raw water applications. Since the installations began in 1998, Duke Power Company has reported that the material has had an excellent service history and has not experienced fouling or corrosion.
The use of polyethylene piping in accordance with this Relief Request will result in improved system performance and enhanced system reliability, and will provide an acceptable level of quality and safety.
: 6. Duration of Proposed Alternative The use of the proposed alternative is requested for the third ten-year inservice inspection interval for Callaway.
The Callaway third ten-year inservice inspection interval is currently scheduled to end on December 18, 2014.
2

AmerenUE 10 CFR 50.55a Request Number 13R-10 Page 3 of 3
: 7. References "Requirements for HDPE Piping for Nuclear Service," dated July 10, 2008 (attached)
TR33/2001, "Generic Butt Fusion Joining Procedure for Polyethylene Gas Pipe" The Plastics Pipe Institute, Inc. "Handbook of Polyethylene Pipe" 3

Requirements for HDPE Piping for Nuclear Service AmerenUE Callaway Plant July 10, 2008
-1000 GENERAL REQUIREMENTS
-1100 SCOPE (a) This document contains rules for the construction of Class 3 high density polyethylene (HDPE) pressure piping and fittings. Use of these materials is permitted only for buried Emergency Service Water Systems that are classified as ASME Section III Class 3. The design pressures and temperatures of the various lines to be replaced will be 161 psig at 95'F, 160 psig at 95 'F, or 45 psig at 175 'F, as applicable to the specific line.
(b) Terms relating to polyethylene as used in this document are defined in Supplement 1.
-1200 QUALIFICATION OF SUPPLIERS Qualification (a) The PE material shall be procured from a qualified supplier as follows; (1) AmerenUE shall be responsible for surveying, qualification, and auditing of the Nonmetallic Material Manufacturer and the Nonmetallic Material Constituent Supplier based on the survey and audit results of the Nonmetallic Material Manufacturer.
Alternately, AmerenUE shall audit and qualify the Nonmetallic Material Manufacturer for surveying/auditing the Nonmetallic Material Constituent Supplier as permitted by ASME Section III NCA-3125 and NCA-3820.
(a) The survey and audit of the Nonmetallic Material Manufacturer will establish the following;
: 1. verification process of constituent material chemistry, and
: 2. Quality System Program conforms to NCA- 3900.
(b) When survey and audit of the Nonmetallic Material Constituent Supplier is required, the survey and audit shall evaluate the Quality System Program and the implementation of ASTM D-3350, Standard Specification for Polyethylene Plastics Pipe and Fittings Materials.
(c) Satisfactory completion of the survey and audit will allow the Nonmetallic Material Manufacturer to supply material to AmerenUE for a period of three years. After the three year period an audit shall be performed to assure continued program maintenance.
1

(b) AmerenUE shall perform any of the functions required by their respective Quality Assurance Program which are not performed by the Nonmetallic Material Manufacturer.
AmerenUE may elect to perform any other Quality Program functions, which would normally be the responsibility of the Nonmetallic Material Manufacturer. These functions shall be clearly defined in the AmerenUE Quality Assurance Program.
c) AmerenUE shall make all necessary provisions so that the Authorized Inspection Agency can make the inspections necessary to comply with this document.
-1210 PE Procurement Chain (a) When the Quality System surveys/audits required by -1200 have been completed, AmerenUE shall establish a qualified HDPE supply chain.
(1) The Nonmetallic Material Constituent Supplier is the organization which manufactures and certifies the base HDPE material pellets.
(2) The Nonmetallic Material Manufacturer is the organization which manufactures, and certifies HDPE material in compliance with requirements of this document. He shall perform or shall supervise and directly control one or more of the operations which affect the HDPE material properties capable to meet the requirements of the basic material specification, and shall verify the satisfactory completion of all other requirements performed by other organizations prior to his certification.
(3) The Nonmetallic Material Supplier is an organization which supplies products of the Nonmetallic Material Manufacturer but does not perform any operations which affect the HDPE materials properties required by the basic material specification.
(4) Certification to the requirements of ASME Code Case N-755 will be considered equivalent to certification to this document.
(b) All pressure retaining HDPE material used in construction of components shall be supplied with a certified certificate of analyses for batch (CCAB) or product quality certification (PQC).
These documents shall include all the results of analysis and production tests performed on the HDPE material.
(1) Nonmetallic Material Constituent Supplier - Certified Certificate of Analysis for Batch or Product Quality Certification shall include HDPE material identification, physical property test results, and melt index temperature when required by AmerenUE when the approved Nonmetallic Material Manufacturer program relies on audits and certification.
(2) Nonmetallic Material Manufacturer - Certified Analysis for Batch or Product Quality Certification shall include HDPE material identification, physical property test results 2

(includes all in-situ and final tests), melt index temperature, mechanical property test results, and shall certify that the product was made from virgin pellets (no scrap or regrind material). The product form shall be permanently marked.
-2000 MATERIALS
-2100 GENERAL REQUIREMENTS FOR MATERIALS
-2110 Scope (a) All HDPE material and components shall be procured using the requirements of this document and the following additional requirements.
(1) HDPE material shall be selected from approved ASTM standards listed in Supplement 2, and shall have material properties not less than those for cell classification 445574C per ASTM D 3350-05 (PE 4710). The material may contain a color stripe with cell classification 445574E. (There is no physical difference between C and E other than color.)
(2) Only HDPE pipe, mitered elbows, and flanges of nominal size 4 NPS (DR9) and 36 NPS (DR9.5) using Carbon Black pigment shall be used.
(3) All HDPE product forms (pipe, mitered elbows, and flanges) shall conform to the ASTM Standards identified in Supplement 2, as applicable.
(b) HDPE material shall be marked in accordance with the marking requirements of the ASTM specified for the material, as applicable. If required the HDPE material shall be marked for identification purposes using a metallic paint marker or stenciling marker.
(c) All metallic materials and components shall be procured using the requirements of ASME Section III, Subsection ND.
-2200 ADDITIONAL PRODUCT FORM REQUIREMENTS
-2210 Mitered Elbows The elbow fabricator shall be covered under the AmerenUE Quality Assurance Program.
AmerenUE shall provide the services of an Authorized Nuclear Inspector. AmerenUE shall ensure the following requirements are met.
(a) All HDPE pipe material used shall comply with -2110(a)
(b) The configuration of the mitered elbow shall meet the requirements of -3022.4 (c) All fabrication processes used in the fabrication of the mitered elbow shall meet the requirements of -4000 and Supplement 9.
3

(d) Mitered elbows shall have the fused joints inspected and accepted in accordance with -
5000.
(e) A code data report shall be used for this product form (Supplement 4). Multiple assemblies may be included on a single form.
-2220 Transition Flange (a) The pressure rating of the transition flange shall be equal to or greater than the attached straight pipe.
(b) The material cell classification shall be not less than 445574C per ASTM D 3350-05 (PE 4710)
-2300 EXAMINATION AND REPAIR OF MATERIAL
-2310 Receipt Examination (a) All HDPE material external surfaces shall be. given a visual examination prior to installation. Any indentation or flaw more than 10% of the minimum wall thickness for 4 NPS piping, and more than 7% for 36 NPS piping, regardless of wall thickness, shall be unacceptable. Additionally, for any flaw that will result in a remaining wall thickness less than the required as-fabricated minimum wall thickness per ASTM F714 shall be unacceptable unless evaluated and determined to be acceptable considering the remaining wall thickness.
Lesser flaws shall be evaluated in accordance with -2320.
(b) Personnel performing the examination shall be qualified in accordance with -5000 of this document.
-2320 Repair of Material (a) For all piping, any section 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.
(b) For all other flaws, the damaged section of pipe shall either be physically removed, or shall be repaired as follows:
(1) The depression after flaw elimination is blended uniformly into the surrounding surface with a maximum taper not to exceed 3:1 (width to height).
(2) After flaw elimination the area will be inspected by visual examination to ensure that the flaw has been removed.
(3) If 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.
(c) For flanges the following requirements shall be met; 4

(1) if the damaged area is in the flange section the entire flange shall be replaced, and (2) if the damaged area is in the pipe section the section shall be removed or repaired as required by (a) and (b), above.
-3000 DESIGN
-3001 Scope The design rules of this Section are limited to buried, high density polyethylene piping systems constructed of straight pipe, one, three and five-joint mitered elbows not exceeding 22-1/2 degrees per miter, fusion joints, and flanged connections.
-3010 Nomenclature 2
A = cross-section area of pipe at the pipe section where the evaluation is.conducted, in Bd = trench width, ft B' = burial factor c = the sum of mechanical allowances and erosion allowance, in D = pipe outside diameter at the pipe section where the evaluation is conducted, in Davg = average pipe diameter in accordance with ASTM F-714 DR = dimension ratio of pipe = mean diameter divided by the minimum fabricated wall thickness    =  Davg / t fab min Epipe = modulus of elasticity of pipe, psi, Table 3031-3 E' = modulus of soil reaction, psi (Data is site specific)
E'N = modulus of soil reaction of native soil around trench, psi (Data is site specific)
Fa = axial force due to the specified Design, Service Level A, B, C, or D applied mechanical loads, lb Fac = axial force range due thermal expansion and/or the restraint of free end displacement, lb FaD = axial force due to the non repeated anchor motion, lb FaE = axial force range due to the combined effects of seismic wave passage, seismic soil movement, and building seismic anchor motion effects, lb Fb = upward force per unit length, lb/ft Fs = soil support factor, Table 3031-2 fo = ovality correction factor, Table 3033.2-1 H = height of ground cover, ft Hgw = height of water table above pipe, ft K = bedding factor = 0.1 L = deflection lag factor, 1.25 to 1.50, or 1.0 if using the soil prism pressure i = stress intensification factor, Table 3042-1 M = resultant moment due to the specified Design, Service Level A, B, C, or D applied mechanical loads, in-lb Mc = resultant moment range due thermal expansion and/or the restraint of free end displacement, in-lb MD = resultant moment due to the non repeated anchor motion, in-lb ME = resultant moment range due to the combined effects of seismic wave passage, seismic soil movement, and building seismic anchor motion effects, in-lb 5

P = internal gage pressure coincident with given service level or loading, psi PD= internal design gage pressure at the specified design temperature.
2    psi PE = vertical soil pressure loads due to weight cover of earth, lb/ft Phydro = external hydrostatic pressure, equal to earth plus groundwater pressure plus surcharge load, psi                                                2 PL = vertical soil pressure due to surcharge loads, lb/ft R = buoyancy reduction factor S = allowable stress, psi, Table 3021-1 TD= Design Temperature, deg F t = nominal pipe wall thickness, in tdesign =  minimum required wall thickness, in t fab min =  minimum thickness in accordance with ASTM F-714 tmin = pressure design thickness, in Wc = weight of contents (equals 0 when empty), lb/ft Wp = weight of pipe per unit length, lb/ft (exclude weight of contained liquid to represent the worst case of an empty pipe)
Ww = weight of water displaced by pipe, per unit length, lb/ft
    = coefficient of thermal expansion, 1f/F w= circumferential compressive stress in the sidewalls, psi AP = differential pressure due to negative internal pressure, psi ATeq = equivalent temperature rise, deg.F Esoi1 = maximum soil strain due to seismic wave passage n = ring deflection 92,ma = maximum allowable change in diameter as a per cent of the original diameter, commonly called the change in ring diameter, Table    3 3031-1 Psaturated = density of saturated soil, lb/ft lb/ft3 Pdry = density of dry soil, v = Poisson ratio (0.35 for short duration loads (5 min. or less) to 0.45 for long duration loads(greater than 5 min.))
-3012 Design Life (a) The Design Specification shall specify the design life of the system, not to exceed 50 years.
(b) The duration of load shall be specified for each load case, and the HDPE pipe physical and mechanical properties shall be based on the duration of load.
-3016 Design and Service Loading Design loads shall be as defined in ASME Section III, ND-3112.1 through ND-3112.3, except the design factor shall be 0.56 or lower. Miner's Rule in accordance with ISO 13760 shall be used to account for operation for 30 days at post-accident conditions and normal operating conditions for the balance of the 40 year design life. Loads applied to buried HDPE pipe shall be defined in the Design Specification, and shall include, as a minimum, the following:
6

(a) Maximum and minimum internal design gage pressure PD, for pressure design in accordance with paragraphs -3021 and -3022.
(b) Maximum and minimum temperature T, for the selection of allowable stress (Tables 3021-1 and 3035-3) and design for temperature effects in accordance paragraph -3040. The maximum Service Level A temperature shall be the Design Temperature, TD.
(c) The stress limits for the loads resulting from the maximum flow velocity, v, shall be as provided in paragraph -3021.2 (d) Vertical soil pressure PE, including saturated soil, surcharge, buoyancy and flotation, for the designs in accordance with paragraph 3030.
(e) Vertical pressure due to weight of soil, PE, and surcharge loads PL for the design in accordance with paragraph 3030 (f) Permanent ground movement, soil settlement, for design as non-repeated anchor movements in accordance with paragraph -3030.
(g) Seismic wave passage and, seismic soil movement and building anchor motions, for seismic design in accordance with paragraph -3050.
-3021 Pressure Design of Pipe
-3021.1 Minimum Required Wall Thickness. The minimum required wall thickness of straight sections of pipe for pressure design shall be determined by tdesign = tmin+ C tdesign = minimum required wall thickness, in tmin =  pressure design thickness, in c = the sum of mechanical allowances and erosion allowance, in tmin  =-- P__D-(2S + PD) tmin =  pressure design thickness, in PD = Piping system internal Design Pressure (gage) at the specified Design Temperature TD, both being specified in the Piping Design Specification. This pressure does not include the consideration of pressure spikes due to transients, psi D = pipe outside diameter at the pipe section where the evaluation is conducted, in S = allowable stress, psi, per Table 3021-1 7

Table 3021-1 Allowable Design Stress, S, for PE4710 (Dow DGDA-2490/2492)*(psi)
Service                                                 Load Duration Temperature                           2 Years                                         50 Years**
OF            0.50 DF           0.56 DF         0.63 DF         0.50 DF            0.56 DF         0.63 DF 73                          Not Applicable                         800                889            1000 86                          Not Applicable                         738                826            929 95                          Not Applicable                         695                778            875 104                          Not Applicable                         653                732            823 113                          Not Applicable                         613                687            773 122                          Not Applicable                         574                643            724 131                          Not Applicable                         537                601            676 140                          Not Applicable                         500                560            630 176              340                 382           430                          Not Applicable
* Values not applicable to all materials.
 ** For service temperature 140 TF (60&deg;C), use 50-year allowable design stress for service life 50-years.
 -3021.2 Allowable Service Level Spikes due to Transients Pressures. The sum of the maximum anticipated operating pressure plus the maximum anticipated Level B pressure spikes due to transients shall be no greater than 1.5 times the piping system. Design Pressure (see paragraph -
3021.1). The sum of the maximum anticipated operating pressure plus the maximum anticipated Level C and D pressure spikes due to transients shall be no greater than 2 times the piping system Design Pressure (see paragraph -3021.1).
 -3022 Pressure Design of Joints and Fittings
 -3022.1 High density polyethylene pipe shall be joined using the butt fusion process. All connections to metallic piping shall be flanged joints.
 -3022.2 Sustained pressure and pressure rating of high density polyethylene pipe fittings shall comply with the specifications listed in Supplement 2. The pressure rating of fittings shall be equal to or greater than the attached straight pipe.
 -3022.3 Flanged connections shall include a metallic back-up ring and shall provide a leak tight joint up to and including the piping hydrostatic test pressure. In addition, the maximum surge pressure per -3021.2 shall not cause permanent deformation of the pipe.
 -3022.4 Mitered elbows shall comply with the requirements of ASME Section III, ND-3644. In place of ND-3644 (e) butt fusion joints shall be' used in accordance with this document. In addition, the mitered elbow segments shall be a minimum of one dimension ratio (DR) lower than that of the attached straight pipe. Heavier wall segments with larger outside diameter (i.e.
 "inverted" elbows) will be used for elbow fabrication to minimize flow restriction. 90 degree, 45 degree and 22-1/2 degree elbows are permitted. Elbows less than 90 degrees may have fewer than three miter joints.
8

-3030 Soil and Surcharge Loads
-3031 Ring Deflection. The soil and surcharge loads on a buried HDPE pipe shall not cause the pipe diameter to deflect (ring deflection, n) beyond a limit K*max where 1              KxLxPE +KxPL 144     2Epipe x          3 +0.061xFs xE' 3     *.DR-l where PE = Psaturated X HW + Pdry x (H- Hw)
K = bedding factor = 0.1 L = deflection lag factor, 1.25 to 1.50, or 1.0 if using 2 the soil prism pressure PE = vertical soil pressure due to earth loads, lb/ft          2 PL = vertical soil pressure due to surcharge loads, lb/ft Epipe = apparent modulus of elasticity of pipe at design life, psi DR = dimension ratio of pipe D = pipe outside diameter, in t = nominal pipe wall thickness at the pipe section where the evaluation is conducted, in Fs = soil support factor, Table 3031-2 E' = modulus of soil reaction, psi E'N = modulus of soil reaction of native soil around trench, psi Bd = trench width, ft 3
soil, lb/ft P saturated = density of saturated 3 Pdry = density of dry soil, lb/ft H = height of ground cover, ft Hw = height of water table above pipe, ft Table 3031-1 Maximum Allowable Ring Deflection HDPE DR                                                2 max  (%)
13.5                                                 6.0 11                                                  5.0 9                                                  4.0 7.3                                                 3.0 9

Table 3031-2 Soil Support Factor Fs E'N/E'                                  BdID 1.5        2.0        2.5        3.0        4.0    5.0 0.1        0.15       0.30      0.60        0.80       0.90    1.00 0.2        0.30       0.45      0.70        0.85       0.92    1.00 0.4        0.50       0.60      0.80        0.90       0.95    1.00 0.6        0.70       0.80      0.90        0.95       1.00    1.00 0.8        0.85       0.90      0.95        0.98       1.00    1.00 1.0       1.00       1.00       1.00       1.00       1.00    1.00 1.5       1.30       1.15       1.10       1.05       1.00    1.00 2.0        1.50       1.30       1.15       1.10       1.05    1.00 3.0       1.75       1.45       1.30       1.20       1.08    1.00 5.0        2.00       1.60       1.40       1.25       1.10    1.00 Table 3031-3 Modulus of Elasticity of HDPE Pipe (ksi)
Load                     Temperature (&deg;F)
Duration       <73 OF        100 OF      120 &deg;F       140 OF    175 OF
  < 10 h          110         100          65           50        na 10h            58           47          31           24        na 100 h           51           42          27           21        na 1000 h          44           36          23           18        na I y           38           31          20           16        na 10y            32           26          17           13        na 50 y           28           23          15           12        12
-3032 Compression of Sidewalls. The circumferential compressive stress in the sidewalls osw due to soil and surcharge loads shall not exceed (PE+PL)XDR < S 2x144 a~w = circumferential compressive stress in the sidewalls 2 of pipe and miters, psi PE =   vertical soil pressure due to earth loads, lb/ft       2 PL = vertical soil pressure due to surcharge loads, lb/ft DR = dimension ratio of pipe S = allowable stress, psi, Table 3021-1
-3033 External Pressure.
-3033.1 Buckling Due to External Pressure. External pressure from ground water, earth loads, and surcharge loads on a buried HDPE pipe shall not cause the pipe to buckle.
10

[ Phydro = (PE + PL + Pgw) ] / 144*< 2.8 [R x B' x E' x Epipe / 12 (DR - 1)311/2 PE  = vertical soil pressure due to earth loads, lb/ft2 PL =  vertical soil pressure due to surcharge     loads, lb/ft2 2
Pgw = pressure due to ground water, lb/ft R = buoyancy reduction factor Epipe = modulus of elasticity of pipe, psi E' = soil modulus, psi DR = dimension ratio of pipe B' = burial factor and the buoyancy and burial factors are Hg gw R = 1-0.33x H
1 1 + 4xexp(-0.065x H)
Hgw = height of ground water above pipe, ft H = depth of cover, ft Table 3033.2-1 Ovality Correction Factor Per Cent-Ovality                 1%              2%           3%             5%             6%
Ovality Correction Factor            0.91            0.84         0.76           0.64           0.59
-3034 Flotation. Buried HDPE pipe shall have sufficient cover or be anchored to the ground to prevent flotation by groundwater. The upward resultant force due to buoyancy on a buried pipe in saturated soil is WW < Wp + PE x D/12 Ww = weight of water displaced by pipe, per unit length, lb/ft Wp = weight of empty pipe per unit length, lb/ft 2 PE = vertical soil pressure due to earth loads, lb/ft D = pipe outside diameter, in
-3035 Longitudinal Stress Design
-3035.1 Longitudinal Applied Mechanical Loads, Longitudinal stresses due to axial forces and bending moments resulting from applied mechanical loads shall not exceed k x S where 11

Bx PaxD
                                   ,     +2xB1 x Fa     3B2  M x--___kxS 2xt             A          Z B, = stress index, Table 3035-1 B 2 = stress index, Table 3035-1 Pa = Design or Service Level A, B, C, or D pressure, psi D = outside pipe diameter at the pipe section where the evaluation is conducted, in t = nominal pipe wall thickness at the pipe section where the evaluation is conducted, in Fa = axial force due to the specified Design, Level A, B, C, or D applied mechanical loads, lb A = cross section area of pipe wall at the pipe section where the force is calculated, in 2 M = resultant bending moment due to the specified Design, Level A, B, C, or D applied mechanical loads, in-lb Z = section modulus of pipe cross section at the pipe section where the moment is calculated, in3 k= factor from Table 3035-2 S = allowable stress, psi, Table 3021-1 Table 3035-1 Stress Indices DR 7                DR 9            DR 11             DR 13.5 B, Straight and           0.5                 0.5              0.5                 0.5 Butt Fused Joint B 2 Straight and          1.0                 1.0              1.0                 1.0 Butt Fused Joint B 1 Miter (a)          0.69                0.69             0.69                0.69 B 2 Miter (a)          1.38                1.64             1.91                2.21 (a) Mitered elbows shall not exceed 22.5 deg. per segment Table 3035-2 Design and Service Level Longitudinal Stress Factors Service Level        Design              A               B                C                 D Factor k            1.0               1.0            1.1              1.33              1.33
-3035.2 Short Duration Longitudinal Applied Mechanical Loads. Alternatively, for the assessment of short duration loads (less than five minutes), the allowable stress S may be replaced by 40% of the tensile strength at material yield. The method for determination of the tensile strength at material yield are given in ASTM D 638 Standard Test Method for Tensile Properties of Plastics. For cell classification 445474C, short duration allowable stress values have been determined and are provided in Table 3035-3.
12

Table 3035-3 Short-Duration Allowable Stress Values Temp <70         100    120     140     175 (OF)
S     1200 940      770    630 400 (psi)
-3040 Temperature Design
-3041 Minimum Temperature. The high density polyethylene material shall not be used at a temperature below the manufacturer limit, but in no case shall the temperature be less than minus 50 0F.
-3042 Design for Expansion and Contraction
-3042.1 Fully Constrained Thermal Contraction. The tensile stress resulting from the assumption of fully constrained thermal contraction of the buried pipe when Twater < Tground, increased by the tensile stress due to axial contraction from Poisson effect, shall not exceed the allowable stress S OyT- hpipexa xAT-v             x1 5S S = allowable stress, psi (x= coefficient of ,thermal expansion, 1f/F AT = Twater - Tground < 0 v = Poisson ratio (0.35 for short duration loads to 0.45 for long duration loads)
Epipe = modulus of elasticity of pipe, psi, Table 3031-3 P = internal design gage pressure, psi, including pressure spikes due to transients from anticipated waterhammer events D = pipe outside diameter, in t = nominal wall thickness, in 3042.2 Fully Constrained Thermal Expansion. The tensile stress resulting from the assumption of fully constrained thermal expansion of the buried pipe when Twater > Tground, shall not exceed the allowable stress S orz = Ep xaxAT*<S S = allowable stress, psi q = coefficient of thermal expansion, 1/F AT  = Twater - Tground > 0 Epipe = modulus of elasticity of pipe, psi, Table 3031-3
-3042.3 Alternative Thermal Expansion or Contraction Evaluation. As an alternative to -3042.1 and -3042.2, the soil stiffness may be accounted for to calculate pipe expansion and contraction 13

stresses. The stresses shall satisfy the following equation using the same differential temperatures as used in the fully constrained evaluations iMc         Fac Z       +A A      <- 1lOOpsi i = stress intensification factor, Table 3042.2-1 Fac = axial force range due thermal expansion or contraction and/or the restraint of free end displacement, lb                                                                     2 A = cross-section area of pipe at the pipe section where the force is calculated, in Mc = resultant moment range due thermal expansion or contraction and/or the restraint of free end displacement, in-lb                                                                          3 Z = section modulus of pipe cross section at the pipe section where the moment is calculated, in Table 3042.2-1 Stress Intensification Factor i Fitting or Joint                 i Straight Pipe                       1.0 Butt Fusion                         1.0 Mitered Elbows                      2.0
-3043 Non-Repeated Anchor Movements The effects of any single non-repeated anchor movements shall meet the requirements of.the following equation iMD        FOD
                                                 +   -<
2S Z        A i = stress intensification factor, Table 3042.2-1 FaD = axial force due to the non repeated anchor motion, lb A = cross-section area of pipe at the pipe section where the force is calculated, in2 MD = resultant moment due to the non repeated anchor motion, in-lb 3
Z = section modulus of pipe cross section at the pipe section where the moment is calculated, in S = allowable stress, psi, Table 3021-1
-3050 Seismic Design
-3051 Seismic Induced Stresses The stresses in the buried PE piping system due to soil strains caused by seismic wave passage, seismic soil movement, and building seismic anchor motion effects, where applicable, shall be evaluated. The stresses shall satisfy the following equation iME         FaE
                                             +    -    <    l00 psi Z          A      -
1 = stress intensification factor, Table 3042.2-1 14

FaE  = axial force range due to the combined effects of seismic wave passage, seismic soil movement, and building seismic anchor motion effects, lb                             2 A = cross-section area of pipe at the pipe section where the force is calculated, in ME = resultant moment range due to the combined effects of seismic wave passage, seismic soil movement, and building seismic anchor motion effects, in-lb                                      3 Z = section modulus of pipe cross section at the pipe section where the moment is calculated, in S = allowable stress, psi, Table 3021-1 Seismic wave passage, seismic soil movement, and building seismic anchor motions shall be combined by square root sum of the squares or by algebraic sum.
Supplement 3 provides a non-mandatory method for the analysis of seismic wave passage, seismic soil movement, and building seismic anchor motion effects,
-3060 Design for Future Internal Access Removable spools will be installed that would provide future access to the ID surfaces in each replacement line should suitable remote examination equipment be developed.
-4000 FABRICATION AND INSTALLATION
-4100 GENERAL REQUIREMENTS
-4110 Scope This Article provides the requirements for the installation of PE piping and fittings. Methods of installation shall be by thermal fusion and flanged fittings. Use of threaded or adhesive joints with HDPE material is not permitted. All metallic interface components will be installed following the requirements of ASME Section III, Subsection ND.
-4120 Examinations Examination activities that are not referenced for examination by specific Code paragraphs, and are performed solely to verify compliance with requirements of -4000, may be performed by the persons who perform or supervise the work. These visual examinations are not required to be performed by personnel and procedures qualified to -5100 and -5500, respectively, unless so specified.
-4130 REPAIR OF MATERIAL HDPE material originally accepted on delivery in which defects exceeding the limits of -2300 are known or discovered during the process of fabrication or installation is unacceptable. The HDPE material may be used provided the defective area can be physically removed from the material or repaired in accordance with -2300.
15

-4200 CUTTING, FORMING, AND BENDING
-4210 Cutting Materials may be cut to shape and size by mechanical means such as machining or cutting.
-4220 Forming and Bending Processes The HDPE material shall not be cold or hot formed or bent. A pipe bending radius greater than or equal to 30 times the pipe outside diameter is acceptable for piping with a DR 9 through 13.5 and is considered to be straight pipe.
-4300 FUSING QUALIFICATIONS
-4310 General Requirements (a) Fusing procedure and machine operator performance qualification shall comply with the requirements of Supplement 9.
(b) The Thermal Fusion Butt Joint is the only thermal fusion joint allowed, see Figure -4310-1.
PWIWJ  -431 -1 Tmmi Fusion Buttf Join
  -4320 Qualifications
  -4321 Required Qualifications AmerenUE shall be responsible for all fusing performed for this project and shall establish the procedures, and conduct the tests required by Supplement 9 to qualify fusion machine operators who apply these procedures.
      -4322 Maintenance and Certification of Records 16

AmerenUE shall maintain records of qualified fusing procedures and the fusion machine operators qualified by them, showing the date and results of tests and the identification mark assigned to each fusing operator. These records shall be reviewed, verified, and signed by an authorized individual and they shall be accessible to the Authorized Nuclear Inspector.
-4323 Fusing Prior to Qualification Fusing Procedure Specification (FPS) shall be qualified as required by Supplement 9 prior to their use. Only fusing operators who are qualified in accordance with -4320 and Supplement 9 shall be used.
-4324 Transferring Qualifications The FPS qualifications and performance qualification tests for fusion machine operators shall not be transferred to another organization.
-4330 Requirements for Fusing Procedure Qualification Tests
-433 1Conformance to Supplement 9 Requirements All fusing procedure qualification tests shall be in accordance with the requirements of Supplement 9 as supplemented or modified by the requirements of this document.
-4332 Preparations of Test Coupons and Specimens Removal of test coupons from the fusion test coupons and the dimensions of specimens made from them shall conform to the requirements of Supplement 9.
-4340 Performance Demonstration
-4341 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.
-4342 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.
17

    -4343 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."
    -4400 RULES GOVERNING MAKING FUSED JOINTS
    -4410     General requirements
    -4411 Identification, Storage, and Handling of HDPE Materials AmerenUE is responsible for control of the HDPE materials that are used in the fabrication and installation of components (-4120). Suitable identification, storage, and handling of HDPE material shall be maintained.
    -4412 Cleanliness and Protection of Surfaces to Be Fused The surfaces of the heater used for fusing shall be free of scale, rust, oil, grease, and other deleterious material. The work shall be protected from deleterious contamination and from rain, snow, and wind during fusing operations. Fusing shall not be performed on wet surfaces. Fusing will not be performed below 50 deg F. Any fusing performed below ambient temperature of 50'F will require an environmental enclosure to be placed over the work area to control temperature.
    -4420 Rules For Making Fused Joints
    -4421 Fused Joint Fit-up Requirements (a) Components of different outside diameters shall not be fused.together.
(b) The alignment of components for open butt fusion joints will be held in position by the fusing machine, allowable surface mismatch shall be less than 10% of the minimum wall thickness of the components being fused, and the remaining joint thickness shall not be less
   *than the required as-fabricated minimum wall thickness per ASTM F714 - unless evaluated and determined to be acceptable considering the remaining wall thickness c) To fuse components with differing DR' s, the component with the smaller DR shall be countered-bored and tapered to meet the wall thickness of the component with the larger DR and shall comply with Figure -4421.3-1 18

                             ~~I--                   I      I                   a Component of            Component of lower DR                higher DR t, =nominal wall thickness of thinner component C.*
tc,,m      .t
                                                                       =0.55     Edge
                                                ---, --- b ---         = .55      ri'M- Radius
                                                                                        = .0%1 r2.i. = .05t.
Transition Counter-bore FIGURE 4421.3-1
-4422 Identification of Joints by Fusing Operator Each fusing operator shall apply the identification mark assigned to him adjacent to all permanent fused joints or series of joints on which he fuses. The marking shall be 1 ft (.3 m) or less from the fusion bead and shall be done with permanent metallic paint marker or stenciling marker.
   -4423 Repairs Repair of a fused joint is not allowed. All unacceptable joints shall be cut out and replaced.
   -4430 Fusing Data Acquisition Recorder The fusion machine shall have an automatic acquisition data recorder attached to it. The recorder shall record essential variables of the fusion process.
(a) Failure to run the recorder during the fusion process shall be cause to fail the fusion joint.
(b) The butt fusion joint record should be compared to the FPS to ensure that the proper butt fusion parameters and procedures were followed. If any parameter is out of the approved range, the fused joint shall be cut out and remade using the correct FPS.
19

-4500 ASSEMBLY AND ERECTION
-4510 General Any distortion of piping to bring it into alignment for joint assembly which introduces a permanent strain in the piping or associated piping components is prohibited.
-4520 Flanged Joints using HDPE material (a) Flanged connections are only permitted for the joining of high density polyethylene pipe to metallic pipe or piping components. The flange connection shall be constructed using a high density polyethylene flange adapter having a DR ratio equal to or less than that of the attached HDPE pipe and shall be joined by fusion to the attached high density polyethylene piping.
(b) The high density polyethylene flange adapter shall be connected to the metal flange using a metallic backing ring, The backing ring shall have a pressure rating equal to or greater than the metal flange.
(c) Following acceptable visual examination, the external fusion beads may be removed in order to accommodate installation of the metallic backing ring.
(d) Before bolting up, flange faces shall be aligned to the design plane within 1/16 in./ft measured across any diameter; flange bolt holes shall be aligned within 1/8 in. maximum offset. Damage to a gasket, if used, or seating surface on the HDPE flange which would prevent proper sealing shall be replaced per -2320(c).
(e) The flange shall be joined using bolts of a size and strength that conforms to the requirements of ASME B 16.5 or B16.47 as applicable. Bolts or studs should extend completely through their nuts. Any which fail to do so are considered acceptably engaged if the lack of complete engagement is not more than one thread. Flat washers shall be used under bolt heads and nuts (f) In assembling flanged joints, the gasket, or high density polyethylene flange face if a gasket is not used, shall be uniformly compressed to the proper design loading. Special care shall be used in assembling flanged joints in which the flanges have widely differing mechanical properties. The required HDPE flange joint seating stress and bolt torque will be determined in accordance with the guidance provided in PPI document Technical Note TN-38, "Bolt Torque for Polyethylene Flanged Joints." If used, gasket material shall be selected to be consistent and compatible with the service requirements of the piping system. No more than one gasket shall be used between contact faces in assembling a flanged joint. See Figure -4520-1 for a typical flange configuration 20

Washers            Metallic Backing Ring Metallic Flange                                 B PE Flange Adapter Metallic Pipe                                                        Fso      on Gasket (Optional)  -C-                                      L Pipe Metallic Piping              PE Piping Transition Flange Arrangement FIGURE -4520-1
-4530 Pipe Supports All installed HDPE pipe supports shall meet the requirements of Subsection NF and the following:
(a) Piping shall be supported, guided, and anchored in such a manner as to prevent damage to the piping. Point loads and narrow areas of contact between piping and supports shall be avoided. Suitable padding shall be placed between piping and supports where damage to piping may occur.
(b) Valves and equipment which would transmit excessive loads to the piping shall be independently supported to prevent such loads.
-5000 EXAMINATION
-5100 GENERAL REQUIREMENTS (a) Visual examinations shall be conducted in accordance with the examination method of Section V, Article 9.
(b) All personnel qualified to perform Visual Examinations on HDPE pipe (VT-I examinations), excluding the hydrostatic pressure test (VT-2 examinations), shall receive the same training as required for the fusion machine operator in Supplement 9.
This training shall include the use of a fusion machine to make a fused joint; however this joint is not required to be tested for qualification. This training shall be documented on a training record.
(c) In addition, personnel performing VT-1 inspections shall undergo evaluation involving examination of physical samples of visually acceptable and unacceptable HDPE pipe 21

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
-5110 Procedures Examination Procedures. All examinations shall be executed in accordance with detailed written procedures which have been proven by actual demonstration, to the satisfaction of the Authorized Nuclear Inspector. Written procedures, records of demonstration of procedure capability, and personnel qualification shall be made available to the Authorized Nuclear Inspector on request.
-5120 Time of Examination of Completed Fused Joints Visual examination of all fused joints shall be conducted; (a) upon the completion of cooling period; (b) after the review required by paragraph -4430 has been reviewed and accepted; and (c) shall be completed before piping becomes inaccessible for inspection.
-5200 REQUIRED EXAMINATIONS
-5210 Visual Examinations are required on the following material and components.
(a) During receipt inspection of the external surface for indentations.
(b) Fusion joints after the fusion process includes, review and verification of fusion data for the joint, and external surfaces. Joints that are not examined in accordance with -
5220 shall be visually inspected on the interior of the joint, including the interior beads of mitered joints.
(c) All pipe fusion joints during the hydrostatic test.
 -5220 Time-of-Flight Diffraction (TOFD) Examination To provide added assurance of joint integrity, AmerenUE will perform ultrasonic Time-of-Flight Diffraction (TOFD) examination of all completed fusion joints, with the exception of portions of joints where the geometry prohibits effective examination (i.e.
intrados and extrados areas of mitered fitting joints).
(a) This is a non-standard non-Code examination, and the contractor providing the service will not have a 10CFR50 Appendix B program. AmerenUE personnel will oversee the examinations.
(b) 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, 22

dimensions and relative locations, simulating flaws expected to occur in unacceptable joints.
(c) Personnel performing TOFD examinations will be qualified in accordance with SNT-TC-lA or equivalent.
(d) Acceptance criteria will be evaluated and refined by AmerenUE, and will be based on industry standards (e.g. 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.
(e) All TOFD joint examination records shall be retained as permanent records.
    -5300 ACCEPTANCE STANDARDS
    -5310 General Requirements Unacceptable joints shall be removed. Repair of unacceptable joints is not permitted.
    -5320 Visual Examination Acceptance Criteria of external surfaces
    -5321 Thermal fusion butt joints shall meet the following:
(a) Joints shall exhibit proper fusion bead configuration, see Supplement 5.
(b) There shall be no evidence of cracks or incomplete fusion.
Except for mitered joints, joints shall not be visually angled or off-set. The ovality offset shall be less than 10% of the minimum wall thickness of the fused components provided the remaining joint thickness is not be less than the required as-fabricated minimum wall thickness per ASTM F714 - unless evaluated and determined to be acceptable considering the remaining wall thickness.
(c) The cleavage between fusion beads shall not extend to or below the outside diameter pipe surface (see Figure -5321-1).
(d) For mitered joints, the beads may flare out instead of roll back to the pipe surface, and/or may exhibit multiple beads or heavy beads with no cleavage. In either case, there must be evidence of melt flow around the complete interior and exterior circumference of the joint. Refer to Supplement 5.
23

(a)                                                (b)
IOPE Pipe (Cross Section Wow)                      HOPE Pipe (Cross Section Wow)
Visually Acceptable -Uniform Bead around pipe    Visually Acceptable - Nco-un"Worm Bead around pipe (c)           *(d)Cleavage                                                                 tUpShall not meet or extend Woow p~iposurface HDPE Pipe (Cross Section Wow)                      HDPE Pipe (Cross Section Wow)
Visually Acceptable - Non-en[fonm Bead around pipe  Visually Unacceptable - Noo-uniform/Uniform Bead Localize diameter mismatch less than 10%of the wall   around pipe - V-0roove too deep at pipe-tangent FIGURE -5321-1 (e) Review the data acquisition record for the joint and compare it to the Fusion Procedure Specification (FPS) to ensure the proper parameters and procedures were followed in making the fused joint, see paragraph -5330.
 -5330 Process Verification The data acquisition record for each joint shall be reviewed and compared to the Fusion Procedure Specification (FPS) to ensure the proper parameters and procedures were followed in making the fused joint.
-5500 QUALIFICATION OF NONDESTRUCTIVE EXAMINATION PERSONNEL
-5510 General Requirements Code required nondestructive examinations shall utilize personnel qualified in accordance with ND-5520, as applicable. All Code required nondestructive examinations shall be performed by and the results evaluated by qualified nondestructive examination personnel.
-5520 Personnel Qualification Requirements (a) Personnel performing visual examinations required by -5200 (a) and (b) shall be qualified and certified as a VT- 1 in accordance with IWA-2000 and shall receive the required training and evaluation in paragraph -5100(b) & (c).
24

(b) Personnel performing visual examinations required by -5200(c) shall be qualified and certified as a VT-2 in accordance with IWA-2000 and receive four hours of training in PE piping and joining practices. This training shall be documented on a training record.
-6000 TESTING
-6100 GENERAL REQUIREMENTS (a) Prior to initial operation, the installed system shall be hydrostatically tested in the presence of the Authorized Nuclear Inspector.
(b) All joints, including fused joints shall be left exposed for examination during the test.
For long sections of piping the hydrostatic testing may be accomplished by testing in small sub-sections of the longer section. Upon a satisfactory test of each small section the piping may be buried. This process shall be documented in the AmerenUE Quality Assurance Program or Repair/Replacement Program and found acceptable to the Authorized Nuclear Inspector.
(c) The pressure in the test section shall be gradually (minimum rate of 5 psig/min not to exceed a maximum rate of 20 psig/min) increased to the specified test pressure and held for 4 hours. Make up water may be added to maintain test pressure during this time to allow for initial expansion. Following the 4 hour initial pressurization period, the test pressure shall be reduced by 10 psig and the system monitored for anther 1 hour. Make up water may no longer be added to maintain pressure. Each joint shall be examined. If no visual leakage is observed and the pressure remains within 5% of the test pressure for the 1 hour, the pipe section under test is considered acceptable.
(d) The temperature of the piping under test will be maintained within the temperature limits of the system design.
(e) The total test time including initial pressurization, initial expansion, and time at test pressure, must not exceed 8 hours. If the pressure test is not completed the test section shall be de-pressurized. The test section shall not be, re-pressurized for at least 8 hours.
(f) A pneumatic test is not permitted.
-6200 Hydrostatic Test Requirements (a) Instrumentation for the hydrostatic test shall be in accordance with IWA-5260.
(b) The minimum test pressure shall be 1.5 times the Design Pressure of the HDPE piping system plus 10 psi.
(c) Personnel qualified in accordance -5520(b) shall conduct the examination.
25

-8000 NAMEPLATES, STAMPING AND REPORTS
-8100 GENERAL REQUIREMENTS
-8110 Scope The requirements for nameplates, stamping and reports shall be in accordance with AmerenUE's ASME Section XI Repair/Replacement Program with the following exception:
(a) Other than thermal indentation line printing during manufacture, no indentation stamping is allowed on the high density polyethylene pipe surface, all marking shall be performed with a metallic paint marker or stenciling marker.
(b) Form NM(PE)-2 (Supplement 2) shall be used for batch produced products produced by fusion (i.e. shop fabricated fittings). Multiple fittings may be included on oneData Report Form.
26

SUPPLEMENT 1 GLOSSARY
: 1. Butt Fusion Cycle - Pressure/Time diagram for a defined fusion temperature, representing the butt fusion operation.
: 2. Certified Certificate of Analysis for Batch (CCAB) - a document attesting that material is in accordance with specified requirements, including batch analysis of all chemical analysis, test, and examinations.
: 3. control specimen - The specimen from the base material tested to determine the tensile strength for the purpose of determining an acceptable tensile strength.
: 4. Cool time under Pressure - In the fusion process, the theoretical fusion pressure plus drag pressure is applied between the pipe ends. This pressure must be maintained until the fusion joint is cool to the touch.
: 5. coupon - a fusion assembly for procedure or performance qualification testing. The coupon may be any product from sheet plate, pipe, or tube material.
: 6. Data Acquisition Record - A detailed record of the times and pressures used in the fusion process along with the heater surface temperature , employee information, fusion machine information, pipe information, date and time for a permanent record of each joint made.
: 7. Drag Pressure - The pressure required by the fusion machine to overcome the drag resistance and frictional resistance and keep the carriage moving at its slowest speed.
: 8. Drag Resistance - Frictional resistance due to the weight of the length of pipe fixed in the movable clamp at the point at which movement of the moveable clamp is initiated (peak drag) or the friction occurring during movement (dynamic drag)
: 9. Frictional Resistance in the Butt Fusion Machine - Force necessary to overcome friction in the whole mechanism of the butt fusion machine.
: 10. Fusion Machine Operator - Person trained to carry out fusion joining between polyethylene (PE) pipes and/or fittings based on the Fusion Procedure Specification (FPS).
: 11. Fusion Operator Certificate - Approval certificate issued by the examiner/assessor stating the knowledge and the skill of the fusion operator to produce fusion joints following a given fusion procedure.
: 12. Fusion Procedure - A document providing in detail the required variables for the butt fusion process to assure repeatability in the butt fusion procedure (FPS).
27
: 13. Heater Bead-up Size - In the heating cycle, the pipe is brought against the heater and the force is dropped to the soak cycle. During this cycle, a bead of polyethylene is formed between the pipe end and the heater surface on both sides. When the bead-up size reaches the size established in the FPS, it is time to open the carriage and remove the heater.
: 14. Heater Surface Temperature - The temperature, in degrees F, of the surface of the coated heater is critical to the butt fusion process. It is usually expressed as a range (example: 400 - 4500 F) and the common practice is to set the average surface temperature at the mid-range (example:
4250 F).
: 15. hydrostatic design basis (HDB) - one of a series of established stress values for a compound.
: 16. 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.
: 17. Interfacial Pressure - The amount of force in pounds (lbs) per square inch of pipe area required to calculate the fusion machine gauge pressure. The interfacial pressure is multiplied by the pipe area in square inches to determine the amount of fusion force (lbs) required to fuse the pipe. This force is divided by the total effective piston area of the hydraulic fusion machine to determine the theoretical gauge pressure to set on the fusion machine. The Drag pressure must be added to this pressure to determine the actual gauge pressure required for fusion. The interfacial pressure usually has a range (example: 60-90 psi) and the common practice is to use the mid-range (example: 75 psi) when making these calculations.
: 18. long-term hydrostatic pressure - strength (LTHS) - the estimated tensile stress in the wall of the pipe in the circumferential orientation that when applied continuously will cause failure of the pipe at 100,000 hours.
: 19. Modulus of Soil Reaction, E' - The soil reaction modulus is a proportionality constant that represents the embedment soil's resistance to ring deflection of pipe due to earth pressure. E' has been determined empirically from field deflection measurements by substituting site parameters (i.e. depth of cover, soil weight) into Spangler's evaluation and "back calculating" F'.
: 20. HDPE - (high density polyethylene) A polyolefin composed of polymers of ethylene. It is normally a translucent, tough, waxy solid which is unaffected by water and by a large range of chemicals. This is one of three general classifications based on material density; low-density, medium-density, and high-density.
: 21. product quality certification (PQC) - a document attesting that material is in accordance with specified requirements, including batch analysis of all chemical analysis, test, and examinations.
: 22. stiffness factor - the measurement of a pipe's ability to resist deflection as determined in accordance with ASTM D 2412.
28
: 23. test joint - work pieces joined by fusing to qualify fusing procedures, or fusing operators
: 24. thermoplastic resin - a resin material which does not react or polymerize and which flows with the application of heat and solidifies when cooled. A material which can be reformed.
29

SUPPLEMENT 2 ASTM PE MATERIAL STANDARDS The following PE materials standards are acceptable for use,
: 1.      D-3035, Standard Specification for Polyethylene (PE) Plastic Pipe (DR-PR) Based on Controlled Outside Diameter
: 2.      D-3261, Standard Specification for Butt Heat Fusion Polyethylene (PE) Plastic Fittings for Polyethylene (PE) Plastic Pipe and Tubing
: 3.      D-3350, Standard Specification for Polyethylene Plastics Pipe and Fittings Materials
: 4.      F-714, Standard Specification for Polyethylene (PE) Plastic Pipe (SDR-PR) Based on Outside Diameter
: 5.      F-1055, Standard Specification for Electro fusion Type Polyethylene Fittings for Outside Diameter Controlled Polyethylene Pipe and Tubing
: 6.      F-2206, Standard Specification for Fabricated Fittings of Butt-Fused Polyethylene (PE) Plastic Pipe, Fittings, Sheet Stock, Plate Stock, or Block Stock 30

SUPPLEMENT 3 Non-Mandatory Method The buried pipe may be qualified by analysis for the effects of seismic wave passage, following the method provided in this Appendix.
Step-1. The strains from seismic wave passage, and seismically-induced permanent or temporary movements if any, shall be obtained by a plant-specific geotechnical-civil investigation.
Step-2. The soil strains (Section 3051) shall be converted into an equivalent temperature rise of the buried pipe, as follows ATq    E soil ATeq = equivalent temperature rise, deg.F esoil = maximum soil strain due to seismic wave passage a     = coefficient of thermal expansion of the pipe, 1fF Step-3. The pipe-soil system shall be modeled as a piping system constrained by soil springs.
(a) The pipe model shall consider two cases: short-term modulus (< 10 hours, Table 303 1-
: 3) for wave passage and long-term modulus for permanent soil movement (permanent seismic anchor motion).
(b) The soil model shall have at-least a bi-linear stiffness, and shall consider two cases:
upper and lower bound of soil stiffness.
For guidance on modeling soil-pipe interaction, refer to ASCE, Guidelines for the Seismic Design of Oil and Gas Pipeline Systems, 1984, ASCE 4 Seismic Analysis of Safety-Related Nuclear Structures and Commentary, or American Lifelines Alliance, Guidelines for the Design of Buried Steel Pipes, July 2001, with February 2005 addendum Step-4. The equivalent change of temperature ATeq shall be applied to the pipe-soil model, to obtain forces and moments throughout the system.
Step-5. The anticipated building seismic anchor movements, if any, shall be applied to the pipe-soil model to obtain forces and moments throughout the system.
Step-6. The anticipated seismic movements, if any, shall be applied to the pipe-soil model to obtain forces and moments throughout the system.
31

Step-7. The results of Steps 4, 5, and 6 shall be combined by SRSS or algebraic sum, at each point along the piping system to obtain resultant forces and moments.
Step-8. The resultant forces and moments shall be evaluated as follows:
(a) The axial stresses in pipe, fittings and fused joints shall comply with the requirements of 3051.
(b) Alternatively, the seismic induced strain shall be determined as follows:
(Fa)Earthquake    G[E    + Iv (PD / 2t)I ]/E Where:
(Fa)Earthquake- = Strain in the pipe from earthquake wave computer analysis This strain, (Sa)Earthquake shall be limited to the values listed in Table A-i, where k is defined in Table 3035-2 Table A-1 Seismic Strain Limits DR                     Allowable Strain DR _*13.5                       0.025 x k 13.5 < DR _*21                     0.020 x k DR > 21                        0.017 xk 32

SUPPLEMENT 4 FORMS
: 1. Form NM(PE) -2 Data Report for Non-Metallic Batch Produced Products
: 2. Form QF-200 Fusion Procedure Specification (FPS)
: 3. Form QF-300 Fusion Machine Operator Qualification (FPQ) 33

FORM NM(PE)-2 DATA REPORT FOR NON METALLIC BATCH PRODUCED PRODUCTS REQUIRING FUSING As required by the Provisions of the AmerenUE 10CFR50.55a Request Number 13R-10
: 1. Manufactured by (Name and address of Manufacturer of Non Metallic products)
: 2. Manufactured for (Name and address of purchaser)
: 3. a) Identification- Certificate Holder's Serial No.
(Lot No., Batch No., etc.) (Print string)
(Nat'l Board No.)                  (yr. mfg.)
b) Owner
: 4. Manufactured according to Mat'l Spec.                               Purchase Order No.
(ASTM)
: 5. Remarks:
(Brief Description of F CERTIFICATE OF COMPLIANCE We certify the statements made in this report are correct and the products defined in this report conform to the requirements of the ASME Material specification listed above on line 4. The Certified Material Batch Reports provided for the material covered by this report.
Date                              , 20      Signed                                     By ASME Certificate of Authorization (NA if Owner) No.                                   to use the                    Symbol expires (Date)
CERTIFICATE OF INSPECTION I, the undersigned, holding a valid commission issued by the National Board of Boiler and Pressure Vessel Inspectors and the State or Province of __and                                                   employed by of                                                     have inspected the products described in this Partial Data Report product in accordance with the ASME Section III, Division 1, AmerenUE I OCFR50.55a Request Number 13R-10.
By signing this certificate, neither the Inspector nor his employer makes any warranty, expressed or implied, concerning the product described in this Partial Data Report. Furthermore, neither the Inspector nor his employer shall be liable in any manner for any personal injury or property damage or a loss of any kind arising from or connected with this inspection.
Date                    20
_________________________________________vU1l11a1la________________________________________________
(Inspector's Signature)                                               National Board, State, Province and No.
*Supplemental sheets in form of lists, sketches or drawings may be used provided (l/ize is 8 1/2 in. x 11 in.
(2) information on items 1-4 on this Data Report is included on each sheet, and (3) each sheet is numbered and number of sheets is recorded at the top of this form.
34

FORM QF-200 ASME          FUSION PROCEDURE SPECIFICATION CC N-755I Ppftpmd by:                      Dam:         ARp1Oed bY FUSION DRAG PRESSURE:
FJSION I**IJK.,I, R:
FUSION MACHINE INFO:
DATAACQ. MFGR:
LJATA ACQ. A`flACHlpf):
FUSION INTERFACIAL PRESSURE:
[COOL TIME &, FUSION PRESSURE-HEATER SURFACE TEMPERATURE:
TECHNIQUE:
35

FORM QF-300 FUSION MACHINE OPERATOR PERFORMANCE QUALIFICATION (FPQ)
TEST FORM Operator's Name                                                         Payroll No.                             Stamp I.D.
Lab Test No.                                      Test: Qualific, ition                               Requalification Fusion Machine Manufacturer Fusion Machine Pipe Size Range Test Position Material Specification                            to Fusion Specification Procedure Pipe Size                            Pipe DR NDE Requirements: Visual                                                 Visual Results Free Bend Test                                      Bend Tests Results Data Acquisition Record Review Results Test Conducted By We certify that the statements in this record are correct and that the fused joints are prepared, fused and tested in accordance with the requirements of Supplement 9, of AmerenUE 10CFR50.55a Request Number 13R-10.
Date                                         Signed By Title 36

SUPPLEMENT 5 FUSION BEAD CONFIGURATION The following page contain pictures of critical attributes of the completed thermal fusion butt joints. These pictures may be used by personnel performing a visual examination on fusion beads.
Miter Joint Fusion:
Acceptable bead configuration for thin wall (e.g. DR 11) miter joint.
Complete evidence of melt flow around circumference Miter Joint Fusion:
Acceptable bead configuration for heavy wall (e.g. DR 8.5) miter joint.
f -
fr~
Complete evidence of mert flow around circumference 37

SsfltFuson of Pip*
Ur "1,111"1        pmeImca-of SuUtslon    be" =Yw,       Mok SuU Fusion of PI"e I Pr0p o wM                  win            ppinOfcS
       &#xfd;"Prwcwm10.
5uFbim iof",:,
lt~k Met944Co&#xfd;d ykVc9.O (      S O&#xfd;AmelnJcikt      Of CtA SWp 38

SUPPLEMENT 9 HIGH DENSITY POLYETHYLENE PIPE FUSING
: 1. Article I  -- Fusion General Requirements
: 1. Article II -- Fusion Procedure Qualifications
: 2. Article III -- Fusion Performance Qualification
: 3. Appendixes Non-mandatory Appendix A -- Fusion Machine Operator Qualification Training 39

ARTICLE I FUSION GENERAL REQUIREMENTS QF- 100 GENERAL This Supplement relates to the qualification of fusion machine operators and the procedures that they employ in fusing high density polyethylene (HDPE) piping. Due to the major differences between metallic welding and plastic fusing, the Fusion Procedure Specification (FPS) and the Procedure Qualification Record (PQR) have been combined for this supplement.
QF-10i Scope The requirements in this supplement apply to the preparation of the Fusion Procedure Specification (FPS), and the qualification of fusion machine operators for thermal butt fusion joining.
QF- 102 Terms and Definitions Some of the more common terms relating to fusion are defined in Supplement 1, and ASTM F412 Standard Terminology Relating to Plastic Piping Systems, QF-103 Responsibility QF-103.1 Fusion. AmerenUE is responsible for all fusing done for the project and shall conduct the tests required in this Supplement to qualify procedures (Article II), and the performance of fusion machine operators who use these procedures (Article III).
QF-103.2 Records. Records of the results obtained in the fusing procedure and fusion machine operator performance qualifications shall be maintained. These records shall be certified by AmerenUE and shall be accessible to the Authorized Nuclear Inspector.
QF-104 Documents QF-104.1 A FPS is a written document that provides direction to the fusion machine operator for making fused joints in accordance with the requirements of this Supplement.
(a) The FPS specifies the conditions under which the fusing must be performed. These conditions include the HDPE materials that are permitted. Such conditions are referred to in this Supplement as fusing "essential variables." The FPS shall address these essential variables.
(b) When required, qualification of a FPS is intended to determine that the fused joint proposed for construction is capable of providing the required properties for its intended 40

application. FPS qualification establishes the properties of the fused joint, not the skill of the fusion machine operator.
QF-104.2 In performance qualification, the basic criterion established for fusion machine operator qualification is to determine the operator's ability to operate the fusing equipment to produce a sound fused joint.
QF-105 Joint Orientation The orientation of all fused butt joints produced for tests or production shall be made with the horizontal axis position illustrated in Figure QF-105.
0 Horizontal Axis Position Figure QF - 105 QF- 106 Training (a) Thermal Butt Joint - Each fusion machine operator will receive a minimum of 24 hours of training, covering the principles of the fusion process and the operation of the fusion equipment. There will be a two part test at the end of this training; Part 1 Theoretical Knowledge and Part 2 Performance Qualification.
(1)     The theoretical test shall cover as a minimum; safety, fundamentals of the fusing process, and recognition of typical joint imperfections.
(2)     Performance Qualification test using an approved FPS.
(b) Appendix A to this supplement provides guidance for a training program.
QF- 120 EXAMINATIONS QF-121 Visual Examination. All fused joints shall receive a visual examination. The examination shall include all accessible surfaces of the fused joint and shall meet the following criteria; (a) Joints shall exhibit proper fusion bead configuration, see Supplement 5.
(b) There shall be no evidence of cracks or incomplete fusion.
41,

(c) Except for mitered joints, joints shall not be visually mitered (angled, off-set). The ovality offset shall be less than 10% of the minimum wall thickness of the fused components.
(d) The cleavage between fusion beads shall not extend to or below the outside diameter pipe surface (see Figure QF-121-1).
(e) For mitered joints, the beads may flare out instead of roll back to the pipe surface, and/or may exhibit multiple beads or. heavy beads with no cleavage. In either case, there must be evidence of melt flow around the complete interior and exterior circumference of the joint.
Refer to Supplement 5.
(a)                                                (b)
PE Pipe (Cross Section View)                       PE Pipe (Cross Section View)
Visually Acceptable. Uniform Bead around pipe   Visually Acceptable. Non-unIform Bead around pipe
()                                                 (d)                            Cleavage tip shall not (C                                            (                                  meet or extend below pipe surface PEPipe  (Cross Section View)                     PE Pipe (Cross Section View)
Visually Acceptable
* Non-unlform Bead around pipe  Visually Unacceptable - Non-uniform/Uniform Bead Localize diameter mismatch lese than 10%ofthe wall    around pipe - V4-rove too deep at plpe4angent FIGURE QF-121-1 (f) Review the data acquisition record for the joint and compare it to the Fusion Procedure Specification (FPS) to ensure the proper parameters and procedures were followed in making the fused joint, see paragraph QF-122.
QF-122 Data Acquisition Record Evaluation.
QF-122.1 Data Acquisition Device (a) The data recording device must be capable of recording the following butt fusion essential variables on each joint:
: 1) Heater Surface temperature
: 2)  Interfacial Pressure
: 3)  Gauge Pressure during the heat cycle
: 4)  Gauge Pressure during the fusion/cool cycle
: 5)  Time during the heat cycle
: 6)  Time during the fusion/cool cycle
: 7)  Heater removal time 42

(b) All job information related to the joints such as job number, joint number, employee number, time, date, fusion machine identification, pipe manufacturer and pipe material (c) The data recording device must be capable of storing at least (1) day of butt fusion joint information and capable of downloading this information as a permanent record.
QF-122.2 Data Acquisition Log Evaluation The butt fusion joint record should be compared to the FPS to ensure that the proper butt fusion parameters and procedures were followed. If they were not, the joint should be cut and re-fused using the correct parameters and procedures per the FPS.
(a) Verify that all job related data was entered in the record.
(b) Verify that the recorded "Fuse" interfacial pressure was within the range of qualification.
(c) Verify that the heater surface temperature recorded was within the range of qualification.
(d) Verify that the Drag Pressure was recorded.
(e) The examiner must calculate the fusion pressure for the fusion machine and add the drag pressure to confirm the machine's hydraulic fusion gauge pressure. This fusion gauge pressure must be shown in the recorded pressure/time diagram at the initial heater contact and during the fusion/cool cycle.
(f) Verify that the fusion gauge pressure dropped quickly to a value less than or equal to the drag pressure at the beginning of the heat soak cycle.
(g) At the end of the heat soak cycle, review that the machine was opened, the heater removed and the pipe ends brought together at the fusion gauge pressure as quickly as possible (not to exceed allowance in procedure).
(h) Verify that the machine fusion gauge pressure was within the range of qualification for the pipe diameter being fused. Observe that the data recording device stopped logging at the end of the fusion / cool cycle.
QF-130 Tests QF- 131 High Speed Tensile Impact Test.
QF- 131.1 Significance and Use This test method is designed to impart tensile impact energy to a butt fused plastic pipe specimen. The failure mode (brittle or ductile) are used as criteria in the evaluation of the butt fusion joint.
43

QF-131.2     Test Specimens (a) The test specimen shall conform to the dimensions shown in Figure QF-131.2. Test specimens of butt fused pipe shall have the bead remain on the outside and inside. Test specimens of butt fused pipe shall use the full wall thickness.
(b) Preparation-Test specimens shall be prepared by machining operations on butt fused sections of pipe and on the pipe itself. The machining operations shall result in a smooth surface on both sides of the reduced area with no notches or gouges.
(c) All surfaces of the specimen shall be free of visible flaws, scratches, or imperfections.
Marks left by coarse machining operations shall be carefully removed with a fine file or abrasive, and the filed surfaces shall then be smoothed with abrasive paper (600 grit or finer). The finishing sanding strokes shall be made in a direction parallel to the longitudinal axis of the test specimen. In machining a specimen, undercuts that would exceed the dimensional tolerances shall be avoided.
(d) When marking the specimens, use a permanent marker of a color that will be easily read or etch the specimen number in the area outside the hole.
62 RI
                                                                        - OF FUSION 15/16"             \ __
L           600 TYP.
NOTES:
: 1. ALL MACHINED SURFACES 125 RMS OR BETTER Tensile Full Thickness Impact Test Coupon Configuration Figure QF-131.2 44

QF- 131.3 Number of Test Specimens Test at least four specimens from butt fused pipe sections 900 apart for pipe sizes 4" and larger. Test two specimens from butt fused pipe sections 180' apart for pipe sizes 2" to 4".
QF-131.4 Speed of Testing The speed of testing shall be in accordance with Table QF-131.4 Wall Thickness                                   Testing Speed
                               <1.25 in. (32mm)                                     6 in./s    (152 mm/s)
                                >1.25 in. (32 mm)                                  4 in./S     (102 mnn/s)
Testing Speed Tolerance: +5 in,/s to -1 in./s (+12.7 mm/s to -25.4 mrnds)
TABLE QF-131.4 QF- 131.5 Conditioning (a) Conditioning-Condition the test specimens at 73.4 +/- 4&deg;F [23 +/- 2&deg;C] for not less than 1 hour prior to test.
(b) Test Conditions-Conduct the tests at 73.4 +/- 4&deg;F [23 +/- 2'C] unless otherwise specified by contract or the relevant ASTM material specification.
QF-131.6 Test Procedure (a) Set up the machine and set the speed of testing to the proper rate as required in QF-131.4 (b) Pin each specimen in the clevis tooling of the testing machine. This will align the long axis of the specimen and the tooling with the direction of pull of the machine.
(c) Determine the mode of failure and note in the report.
QF-131.7 Acceptance Criteria Failure mode shall be ductile. Reference Figure QF-130.7.
45

RDMteA                         Fiwre S                                no"r C Brims P61umr                  Due"is Pollute                         Dudle Foiurs OUtsde Fusion Intore                     A4s         to Fuson I -I I NOTE:   o         Denotes Fusion Used FIGURE GF-130.7 Tensft Tedt Slmple Evalkutlo Sample QF-132 Elevated Temperature Sustained Pressure Tests.
QF-132.1 Specimens Butt fuse (2) pieces of 8" IPS DR 11 PE 3408/PE 4710 pipe x 40" long using the FPS outlined in this Supplement and perform the elevated temperature sustained pressure tests specified in ASTM D-3055-03a.
QF-133 FREE BEND TESTS QF-133.1 Specimens Two bend specimens as shown in Figure 133.1 shall be removed from the joint approximately 1800 apart. For qualification coupons greater than 1" thick, alternative means of bend testing may be used provided similar cross-sectional stress is obtained at the joint.
15t, t                  6iGin.
Sin.                                         1-1t2 t, 1 in. min I ---- - - - - - -
BMt Fusojn Joint FIGURE OF-1S3.1 46

QF-133.2 Testing Procedure One test specimen shall be bent so that the inside surface of the joint is in tension and the other shall be bent so that the outside surface of the joint is in tension. The ends of each specimen shall be brought together until the ends of the specimens touch.
QF-133.3 Acceptance Criteria The specimens shall not crack or fracture.
47

ARTICLE II FUSION PROCEDURE QUALIFICATIONS QF-200 GENERAL QF-201 Written Fusion Procedure Specifications shall be prepared as follows:
(a) Fusion Procedure Specification (FPS). A FPS is a written qualified fusing procedure prepared to provide direction for making production fused. The FPS shall be used to provide direction to the fusion machine.
(b) Contents of the FPS. The completed FPS shall describe all of the essential variables for each fusion process used in the FPS. These essential variables are listed and defined in QF-220. Any other information may be included in the FPS that may be helpful in making a fused joint.
(c) Changes in essential variables require requalification of the FPS (d) Format of the FPS. The information required to be in the FPS may be in any format, written or tabular, as long as every essential variables outlined in QF-220 is included or referenced. Form QF-200 has been provided as a guide for the FPS.
This Form includes the required data for the fusing, it is only a guide and is located in Supplement 4.
(e) Availability of the FPS. A FPS used for production fusing shall be available for reference and review by the Authorized Nuclear Inspector at the fabrication or installation site.
QF-210 Responsibility (a) The parameters applicable to fusing that are performed in construction of fusion joints shall be listed in a document known as a Fusion Procedure Specification (FPS).
(b) The FPS shall be qualified by the fusing of test coupons, testing of specimens cut from the test coupons; and recording fusing data and test results in the FPS. The fusion machine operators used to produce the fused joints to be tested for qualification of procedures shall be under the full supervision and control of 48

AmerenUE during the production of these test fused joints. .The fused joints to be tested for qualification of procedures shall be fused either by direct employees or by individuals engaged by contract for their services as fusion machine operators under the full supervision and control of AmerenUE. It is not permissible to have the supervision and control of fusing of the test fused joints performed by another organization. It is permissible, however to subcontract any or all of the work of preparation of test material for fusing and subsequent work on preparation of test specimens from the completed fused joint, performance of nondestructive examination, and mechanical tests, provided AmerenUE accepts the responsibility' for any such work.
(c) AmerenUE has responsible operational control of the production of all fusion joints to be made for this project.
(d) AmerenUE shall certify each Fusion Procedure Specification.
QF-220 FUSION PROCEDURE SPECIFICATION (FPS)
QF-221 STANDARD FUSION PROCEDURE SPECIFICATION (a) The Standard Fusion Procedure Specification is based on standard industry practice and testing as reported in the Plastics Pipe Institute (PPI), report TR-33/2001, (a) (b) When the FPS is limited to the following parameters, qualification testing is not required. If there are to be deviation from the conditions listed below, procedure qualification testing in paragraph QF-223 shall be performed.
(1) The pipe material is PE3408 or PE4710 (2) Position is limited to horizontal, +/-45'.
(3) The pipe ends shall be faced to establish clean, parallel mating surfaces that for non-mitered joints are perpendicular to the pipe centerline on each pipe end. When the ends are brought together, there shall be no visible gap.
(4) The external surfaces of the pipe are aligned to within 10% of the pipe wall thickness.
(5) The drag pressure shall be measured and recorded. The fusion pressure shall be calculated so that an interfacial pressure of 60 to 90 psi is applied to the pipe ends.
(6) The heater plate surface temperature shall be 400 to 450'F measured at 4 locations approximately 900 apart on both sides of the heater plate.
49

(7) The heater plate shall be inserted into the gap between the pipe ends and fusion pressure shall be applied and maintained until an indication of melt is observed around the circumference of the pipe. The pressure shall be reduced to drag pressure and the fixture shall be locked in position so that no outside force is applied to the joint during the soak time.
(8) The ends shall be held in place until the following bead size is formed between the heater faces and the pipe ends, shown in Table QF-221(a)-1.
Approximate Melt Pipe Size (Dia)            Bead Size inches                   Inches
                         -c 1 1/4             1/32 to 1/16
                     > 1 114 to< 3                  1/16
* 3 to < 8              liBto 3/16
* 8 to <_12             3116 to 1/4 1112 to < 24             1/4 to 7/16"
                      > 24 to <36             7/16 to 9f16 S>36 to < 54          9/16 minimum TABLE QF-221(a)-I (9) After the proper bead size is formed, machine shall be opened and the heater removed. The pipe ends shall be brought together and the fusion pressure reapplied.
(10) The maximum time from removal of the heating plate until the pipe ends are pushed together shall not exceed the time given in Table QF-221(a)-2.
50

Pipe Wall Thickness      Max. Heater Plate (inches)           Removal Time
                               .20 to .36               8 sec.
                            > .36 to .55               10 sec.
                            > .55 to 1.18              15 sec.
                              >1.18to 2.0             25 sec.
                              > 2.0 to 4.0            45 sec.
                              > 4.0 to 6.0             60 sec.
Shop Application
                               >3.0 to 4.0            60 sec.
                               >4.0 to 6.0             75 sec.
TABLE QF-221(a)-2 (11) The pressure is maintained until the joint has cooled to the touch, after which the pipe may be removed from the joining machine. Handling of the pipe shall be minimized for an additional 30 minutes.
QF-222 Essential variables for Fusion Procedure Specifications (FPS).
Any change in the essential variables listed below and QF -221, requires requalification of the FPS per QF -223.
(a) Essential Variables (1) The pipe material, (2) Heater surface temperature range, (3) Butt fusion interfacial pressure range, (4) Deleted (redundant to 3)
(5) Heater bead up size, (6) Heater removal time, (7) Cool-down time under fusion pressure QF-223 Testing Procedure to Qualify the FPS (a) Use 8" IPS HDPE DR 11 pipe sizes in qualification test joints.
51

(b) Make the following butt fusion joints using the following combinations of heater temperature ranges and interfacial pressure ranges and the FPS:
(1) High heater surface temperature and high interfacial pressure, (5) joints (2) High heater surface temperature and low interfacial pressure, (5) joints (3) Low heater surface temperature and high interfacial pressure, (5) joints (4) Low heater surface temperature and low interfacial pressure, (5) joints (c) Evaluate (3) joints of each combination using the High Speed Tensile Impact Tests per QF-131. All joints must fail in a ductile mode.
(d) Evaluate (2) joints of each combination using the Sustained Pressure Testing per QF-132. All joints must pass this test.
QF-230 Mechanical Tests.
QF-231 General Requirements (a) The type and number of test specimens that shall be tested to qualify a butt FPS are given in QF-223, and shall be removed in a manner similar to that shown in QF-130. If any test specimen required by QF-223 fails to meet the applicable acceptance criteria, the test coupon shall be considered as failed.
(b) When it can be determined that the cause of failure is not related to fusing parameters, another test couponmay be fused using identical fusing parameters.
(c) Alternatively, if adequate material of the original test coupon exists, additional test specimens may be. removed as close as practicable to the original specimen location to replace the failed test specimens.
(d) When it has been determined that the test failure was caused by an essential variable, a new test coupon may be fused with appropriate changes to the variable(s) that was determined to cause the test failure.
(e) When it is determined that the test failure was caused by one or more fusing conditions other than essential variables, a new set of test coupons may be fused with the appropriate changes to the fusing conditions that were determined to cause the test failure. If the new test passes, the fusing conditions that were determined to cause the previous test failure shall be addressed by the manufacturer to ensure that the required properties are achieved in the production fused joint.
QF-232 Preparation of Test Coupon The base materials shall consist of pipe. The dimensions of the test coupon shall be sufficient to provide the required test specimens.
52

ARTICLE III FUSION PERFORMANCE QUALIFICATION QF-300 GENERAL QF-300.1 This Article lists the essential variables that apply to fusion machine operator performance qualifications.
The fusion machine operator qualification is limited by the essential variables.
QF-300.2 (a) The basic premises of responsibility in regard to fusion are contained within QF-103 and QF-301.2. AmerenUE shall be responsible for conducting tests to qualify the performance of fusion machine operators in accordance with qualified Fusion Procedure Specifications, which are employed in the construction of fused joints built in accordance with this Supplement. This responsibility cannot be delegated to another organization.
(b) The fusion machine operators used to produce such fused joints shall be tested under the full supervision and control of AmerenUE during the production of these test fused joints. It is not permissible to have the fusing performed by another organization. It is permissible, however, to subcontract any or all of the work of preparation of test materials for fusing and subsequent work on the preparation of test specimens from the completed fused joints, performance of nondestructive examination and mechanical tests, provided AmerenUE accepts full responsibility for any such work.
(c) AmerenUE is the organization which has responsible operational control of the production of the fused joints to be made in accordance with this Supplement.
QF-301 Tests QF-301.1 Intent of Tests. The performance qualification tests are intended to determine the ability of fusion machine operators to make sound fused joints.
QF-301.2 Qualification Tests. AmerenUE shall qualify each fusion machine operator for the fusing process to be used in production. The performance qualification test shall be fused in accordance with a qualified Fusion Procedure Specifications (FPS).
Changes beyond which requalification is required are given in QF-322. Allowable 53

visual and mechanical examination requirements are described in QF-303. Retests and renewal of qualification are given in QF-320.
The fusion machine operator who prepares the FPS qualification test coupons meeting the requirements of QF-200 is also qualified within the limits of the performance qualifications, listed in QF-303 for fusion machine operators.
The performance test may be terminated at any stage of the testing procedure, whenever it becomes apparent to the supervisor conducting the tests that the fusion machine operator does not have the required skill to produce satisfactory results.
QF-301.3 Identification of Fusion machine operators. Each qualified fusion machine operator shall be assigned an identifying number, letter, or symbol which shall be used to identify the work of that fusion machine operator.
QF-301.4 Record of Tests. The record of Fusion machine operator Performance Qualification (FPQ) tests shall include the essential variables, the type of test and test results, and the ranges qualified in accordance with Form QF-300 for each fusion machine operator.
QF-302 Type of Test Required QF-302.1 Mechanical Tests. All mechanical tests shall meet the requirements prescribed in QF- 133.
QF-302.2 Test Coupons in Pipe. For test coupons made on pipe in the horizontal axis position of Figure QF- 105. The coupons shall be removed from the test piece in accordance with Figure QF-133.1.
QF-302.3 Visual Examination. For pipe coupons all surfaces shall be examined visually per QF-121 before cutting of bend specimens. Pipe coupons shall be visually examined per QF-121 over the entire circumference, inside and outside.
QF-303 Fusion machine operators Each fusion machine operator who fuses under the rules of this Supplement shall have passed the mechanical and visual examinations prescribed in QF-302.1 and QF-302.3 respectively.
QF-303.1 Examination. Fused joints made in test coupons for performance qualification shall be examined by mechanical and visual examinations (QF-302. 1, QF-302.3).
54

QF-310 QUALIFICATION TEST COUPONS QF-3 10.1 Test Coupons. The test coupons shall be pipe. Qualifications for pipe are accomplished by fusing one pipe assembly in the horizontal axis position (figure QF-105). The minimum pipe size shall be IPS 6.
QF-320 RETESTS AND RENEWAL OF QUALIFICATION QF-321 Retests A fusion machine operator who fails one or more of the tests prescribed in QF-303, as applicable, may be retested under the following conditions.
QF-321.1 Immediate Retest Using Visual Examination. When the qualification coupon has failed the visual examination of QF-302.3, retesting shall be by visual examination before conducting the mechanical testing.
When an immediate retest is made, the fusion machine operator shall make two consecutive test coupons all of which shall pass the visual examination requirements.
The examiner may select one of the successful test coupons from each set of retest coupons which pass the visual examination for conducting the mechanical testing.
QF-321.2 Immediate Retest Using Mechanical Testing.
When the qualification coupon has failed the mechanical testing of QF-302.1, the retesting shall be mechanical testing.
When an immediate retest is made, the fusion machine operator shall make two consecutive test coupons which shall pass the test requirements.
QF-321.4 Further Training. When the fusion machine operator has had further training or practice, a new test shall be made.
QF-322 Expiration and Renewal of Qualification QF-322.1 Expiration of Qualification. The performance qualification of a fusion machine operator shall be affected when one of the following conditions occurs:
(a) When he has not performed thermal butt fusion during a period of 6 months or more, his qualification shall expire.
(b) When there is a specific reason to question his ability to make fused joints that meet the specification, the qualifications that support the fusing he is doing shall be revoked.
55

QF-322.2 Renewal of Qualification (a) Renewal of qualification expired under QF-322.1 (a) may be made by fusing a single test coupon and by testing of that coupon as required by QF-301. A successful test renews the fusion machine operator previous qualifications for the process for which he was previously qualified.
(b) Fusion machine operators whose qualifications have been revoked under QF-322.1 (b) above shall requalify. Qualification shall utilize a test coupon appropriate to the planned production work. The coupon shall be fused and tested as required by QF-301 and QF-302. Successful test restores the qualification.
QF-330 FUSION ESSENTIAL VARIABLES FOR FUSION MACHINE OPERATORS QF-331 General A fusion machine operator shall be requalified whenever a change is made, in one or more of the essential variables listed.
(a) A change in pipe diameter from one range to another; (1) Less than IPS 8, (2) IPS 8 to IPS 24. and (3) IPS over 24 (b) A change in name of the manufacturer of equipment (c) The axis of the pipe is limited beyond the horizontal position +/-450.
Qualification in any position other than horizontal qualifies the orientation tested +/- 20'.
QF-340 Testing (a) Test joints shall be 6" IPS minimum. A data acquisition device shall be attached to the fusion machine and the data concerning the joint entered. The data acquisition device shall be used to record data required by QF-122.
(b) The supervisor conducting the test shall observe making of the butt fusion joint and note if the fusion procedure (FPS) was followed.
(c) The completed joint shall be visually examined and meet the acceptance criteria of QF-121.
(d) After the joint is complete, the data acquisition record shall be reviewed by the assessor and compared to the FPS to ensure the proper procedures were followed.
56

(e) Bend test specimens shall be removed, tested and meet the acceptance criteria in accordance with QF- 133.
57

Non-Mandatory Appendix A To Supplement 9 Fusion Machine Operator Qualification Training A-1000 SCOPE (a) The major portion of the quality of HDPE piping systems is determined by the skills of the fusion machine operators. When installing polyethylene (PE) piping, the quality of the fusion joints is essential for the piping system.
(b) It is important that the fusion machine operators are trained and competent in the fusion technology employed in constructing HDPE piping systems. Continued competence of the fusion operator is covered by periodic re-training and re-assessment.
(c) This document gives guidance for the training, assessment and approval of fusion operators in order to establish and maintain competency in construction of high density polyethylene piping systems for pressure applications. The fusion joining technique covered by this Appendix is butt fusion. This article covers both the theoretical and practical knowledge necessary to ensure high quality fusion joints.
A- 1100 REFERENCES (a) Plastics Pipe Institute (PPI) Technical Report TR-33/2001 "Generic Butt Fusion Joining Procedure for Field Joining of Polyethylene Pipe (b) American Society of Testing and Materials (ASTM) D 2657-03 "Standard Practice for Heat Fusion Joining of Polyolefin Pipe and Fittings" (c) ISO TR 19480/2005 "Thermoplastics pipes and fittings for the supply of gaseous fuels or water - Guidance for training and assessment of fusion operators" A-2000 TRAINING A-2100 Training Course (a) A trainee fusion operator for HDPE systems should follow a training course in order to obtain a fusion operator certificate for HDPE pipes. The course should cover all aspects of the butt fusion process including safety, machine evaluation and 58

maintenance, machine operation, FPS guidelines, pressure and temperature setting, data log device operation and set-up, in-ditch fusion techniques, visual examination guidance, and data log record evaluation. The minimum course duration is 24 hours.
(b) The course will be delivered by a competent qualified trainer with a minimum of 3 years of experience in the butt fusion processes and who has mastered the techniques involved.
(c) The trainer should have a range of fusion machines representative of the equipment encountered on worksites for installing pipes, in order for the trainee fusion operator to become acquainted with the fusion equipment commonly used.
The trainee fusion operator may be trained on one of these fusion machines or on a machine from his own company if accepted by the training center. The fusion equipment must comply with the fusion machine manufacturer's specifications and/or ISO 12176-1 "Plastics pipes and fittings - Equipment for fusion jointing polyethylene systems -    Part 1: Butt fusion  "
A-2200 Operator Assessment The trainee fusion operator who has followed a training course as described above should then pass a theoretical and practical assessment in order to be qualified as a fusion operator for PE systems. The assessor should not be the trainer but should have the same assessment qualifications as the trainer shown above.
A-2300 Training Curriculum (a) The training course should comprise of any combination of fusion packages based on the requirements of utility or pipeline operators. These packages may be given as individual modules or combined to suit requirements. The course shall include safety training related to the fusion process and equipment.
(b) All consumables and tools necessary for the training package should be available during the training session. The pipes and fittings to be used shall conform to the ASTM product forms permitted by this Supplement.
(c) The lessons should be designed so that the trainee fusion operator learns to master the fusion technique and attains a good working knowledge of the piping system materials and practical problems encountered when fusing pipe in the field.
The fusion operator should receive a written manual covering all the elements dealt with in the training.
(d) The theoretical course should deal with general information in connection with raw materials, pipes and fittings, and also with theoretical knowledge about preparation, tools, and devices, joining components, different materials, different diameter ratios and correct and incorrect parameters. The safety course should include information concerning the fusion process, such as protective clothing, 59

general safety, regulations for electrical equipment, handling heater plates, etc. Areas of study should include but not be limited to the following:
(1) Butt fusion joining
* Principles of fusion
* Straight/coiled pipes, service lines, main lines, etc.
* Components: pipes, flange adapters saddle fittings, other fittings
* Butt fusion equipment: manual, semi-automatic and automatic machines.
* Joint preparation: Cleaning, rounding, alignment, facing, etc
* Butt fusion cycle: pressure, time and temperature relationships, diagram.
* Failure modes: understanding and avoiding possible errors
* Test methods: visual examination, high speed tensile-impact test, bending test, hydrostatic test, data log recording / evaluation, etc.
(2) The trainee fusion operator should be familiar with the butt fusion joining technique and procedure (FPS) by making a sufficient number of butt fusion joints. In some cases, the fusion technique may vary slightly according to diameter, material or other factors. In such cases, the trainee fusion operator should also be made familiar with the various techniques.
(3) The trainee should start by making a butt joint between two pipes, and should then learn to make butt fusion joints with pipes and fittings such as tees, reducers, etc.
(4) The trainee should learn how to detect and avoid typical fusion defects.
(5) The trainee should learn how to assess the quality of a butt fusion joint by doing a visual examination of the butt fusion joint and comparing it to the visual guidelines published in the pipe manufacturer's heat fusion joining procedure booklet. The trainee should also compare the data log record to the FPS to ensure the proper parameters and procedures were followed in the butt fusion process.
A-3000 ASSESSMENT AND TESTING (a) Training program should end with a theoretical and practical examination (test piece).
(b) The content of the theoretical examination shall consist of not less than (20) multiple choice questions about the butt fusion process, fusion machine operation, pipe, quality examination, safety, etc. within a set period of time. A score of 80% or better is considered passing on this examination. Questions to be included but not limited to are:
60

How do you calculate the fusion machine gauge pressure?
What is the proper heater surface temperature range from the FPS?
What is the proper butt fusion interfacial pressure range from the FPS?
How do you calculate the drag pressure?
How do you know when to remove the heater in the heating cycle?
How long do you leave the pipe ends together under pressure in the cooling cycle?
What is the difference between IPS pipe and DIPS pipe?
How do I determine the hydraulic fusion machines total effective piston area?
How is the total effective piston area of the fusion machine used to determine the fusion machines gauge pressure for a specific pipe?
How do you adjust the machine to improve the alignment of the pipe after facing?
How much material should be removed from the pipe ends in the facing operation?
How do you determine if the fusion machine conforms to the equipment manufacturer's specifications?
How do you align the pipe in the butt fusion machine?
Can you butt fuse pipe in a ditch?
What is interfacial pressure?
(c) The practical examination will require the trainee fusion operator tomake a fusion joint with a hydraulic butt fusion machine with a minimum pipe size of 6" IPS DRI 1. A data acquisition device must be attached to the fusion machine and the data concerning the joint entered. The data log device shall be used to record the joint made by the trainee. The assessor shall observe the butt fusion joint and note if the proper procedure (FPS) was followed. After thejoint is complete, the data log record shall be reviewed by the assessor and compared to the FPS to ensure the proper procedures was followed. The assessor will then conduct a visual examination of the joint to make sure it satisfies the pipe manufacturers recommend visual guidance criteria per QF- 121 of this Supplement.
(d) If a data log device is not available, the assessor will manually record the butt fusion parameters used in the butt fusion process. This should be compared with the FPS to ensure they agree.
(e) Trainee fusion operators who pass the theoretical and practical examination would receive a fusion operator certificate bearing the logo of the assessment center awarding the approval. The fusion operator certificate should state the technique or techniques and fusion machines for which the operator is qualified.
A-4000 REASSESSMENT 61

If the trainee fails one of the examinations, he should retake it after a period not shorter than one week. If the trainee fails the examination for the second time, the trainee should repeat the training course before taking the test again.
62 To ULNRC-05517 Enclosure 6 Justification for Increase in Callaway's HDPE Design Factor

Justification for Increase in Callaway's HDPE Design Factor A Design Factor (DF) of 0.5 has historically been used in the determination of allowable stress for pipe design utilizing PE 3408 piping material. For the PE 4710 High Density Polyethylene (HDPE) piping material to be installed in Callaway's Essential Service Water (ESW) system, AmerenUE intends to use a Plastics Pipe Institute (PPI) DF of 0.56 (i.e. a safety factor of 1.8) to provide sufficient design margin.
The bases for increasing the DF from 0.5 to 0.56 in the replacement Callaway ESW HDPE piping are as follows:
: 1) The PPI DF is not determined using the same method as the ASME DF. The allowable stress determined using a PPI DF of 0.56 will actually result in a DF greater than 3.5 (the ASME DF for ASME Section III, Class 3 piping) using the ASME method.
: 2) PE 4710 material will be used in the replacement Callaway ESW HDPE piping rather than PE 3408. It has been accepted by PPI that PE 4710 has superior properties when compared to other PE materials and that it is therefore appropriate to use a higher PPI DF in the design of PE 4710 piping systems.
Additionally, as discussed below, the primary failure mechanism for HDPE piping is slow crack growth. The PE 4710 material selected for use at Callaway significantly exceeds the requirements for slow crack growth resistance with a PENT (Pennsylvania Notch Test - ASTM F 1473) of greater than 10,000 hours as compared to the requirement to exceed 500 hours.
: 3) The replacement Callaway ESW HDPE piping and fittings are all being manufactured from the same PE 4710 material. The purpose of the design factor in the ASME Code is to account for the unknowns in the design and construction process. One such unknown is variation in materials. By manufacturing all of the HDPE piping and fitting from the same material and at the same facilities, the material variability is reduced.
These bases are discussed below in further detail.

Basis 1 - Comparison of PPI DF and ASME DF The PPI DF is based on a ratio of the recommended allowable stress (Hydrostatic Design Stress or HDS) to the nominal long term stress rating (Hydrostatic Design Basis or HDB). The HDB for the Dow PE 4710 material selected for use in the Callaway ESW replacement piping is 1600 psi at 73'F. (

==Reference:==
Enclosure 1 of Reference 2, ULNRC-05490.) Values of the resulting Hydrostatic Design Stress (HDS) for the Dow PE 4710 material for various DF values are presented below.
Hydrostatic Design Basis        PPI Design       Hydrostatic Design Stress (HDB) at 73-F               Factor               (HDS) at 73-F (psi)                                            (psi) 1600                      0.5                     800 1600                     0.56                     896 1600                     0.63                    1000 The ASME DF is based on the tensile strength of the material. The following illustrates the ASME DF that would exist for the HDPE material using the ASME method for determining the DF.
The tensile strength of the Dow PE 4710 material is 3600 psi. (

==Reference:==

Enclosure I of Reference 2, ULNRC-05490, and Enclosure 3.)
A calculation for the ASME allowable stress using an ASME DF of 3.5 would be:
3600 psi / 3.5 = 1030 psi However, if a Hydrostatic Design Stress (HDS) of 896 psi is used (based on the PPI DF of 0.56), the ASME DF would be:
3600 psi / 896 psi = 4.0

Basis 2 - Superior Properties of PE 4710 Material Approximately four decades ago, PPI developed the standard 0.50 design factor for thermoplastic pressure water pipe service that is used throughout North America. This 0.50 DF is the inverse of a 2.00 safety factor. This factor was developed by determining safety factors for application components with regards to uncertainty in material, pipe manufacture, handling, installation, application operating characteristics, and unknown factors. The following is a breakdown of these factors:
1.00        Starting basis 0.25        Materials variability from lot to lot, and for variability in testing and test methods 0.05        Extrusion quality variation 0.10        Extension of the HDB from 11.4 years to 50 years 0.20        Pressure surge variations (based on PVC water hammer capacity at 2 fps water velocity) 0.20        Handling and installation 0.20        Unknown factors 2.00        TOTAL SAFETY FACTOR Over the years, the plastic pipe industry has determined that the 0.50 DF has proved to be conservative for pressure-rated thermoplastic materials, i.e., PVC, CPVC, ABS, PP, and conventional PE (including PE 3408 material). However, as discussed below, PE 4710 materials demonstrate a higher level of performance without the risk of service life reduction. As a result, PPI recommends a higher design factor of 0.63 (or a safety factor of 1.6) for PE 4710 materials for water service based on a reduction or elimination of several of the individual factors as follows:

1.00       Starting basis 0.25       Materials variability from lot to lot, and for variability in testing and test methods 0.05       Extrusion quality variation 0.00       Extension of the HDB from 11.4 years to 50 years 0.00       Pressure surge variations (based on PVC water hammer capacity. at 2 fps water velocity) 0.30       Handling and installation and Unknown factors 1.60       TOTAL SAFETY FACTOR For the application at Callaway, a DF of 0.56 (or a safety factor of 1.8) will be used based on the exclusion of the 0.20 factor for pressure surge variations only. This factor is excluded since the 0.20 surge allowance is based on limiting PVC material to surge pressure from a 2 foot-per-second (fps) velocity change to prevent bursting. In contrast, and as noted in the PPI Handbook of PE pipe, PE 4710 material tolerates far higher surge pressures.
Excerpts below are taken from PPI TN-41, "High Performance PE Materials for Water Piping Applications," and provide additional justification on the use of the lower DF of 0.56 for the PE 4710 material.

===Background===
Polyethylene (PE) has been used for water piping applications both domestically and internationally since the 1960's. In 1988, high performance PE materials were introduced in Europe. Recognizing the advantages afforded by higher-performing PE materials, PPI and ASTM worked to characterize higher-performing PE materials that culminated in PE 4710 designations that are now manufactured in the U.S. by a number of resin companies. Pipe made from these PE 4710 materials have a unique combination of having the highest PE pressure

rating (PR), outstanding resistance to slow crack growth (SCG), and increased resistance to rapid crack propagation (RCP). These are the three key engineering properties for evaluating a plastic piping material, and these high performance PE materials exhibit outstanding performance in all three areas.
Although these high performance PE materials may be relatively new in North America, they have over 20 years of very successful history worldwide for water piping applications.
The Plastics Pipe Institute (PPI) identified that the best way to take advantage of these high performance PE materials in North America was to incorporate them into the ASTM and AWWA standards by applying higher material specifications that result in an increased hydrostatic design stress compared to conventional PE materials. Changes to support a higher HDS for water piping have been accomplished through revising PPI TR-3 and existing ASTM PE resin and pipe standards. The higher HDS for pressure rating can be a deciding factor whether a water company uses PE pipe or metal pipe. The premise for this increased HDS is that higher performing PE materials must demonstrate superior performance characteristics such that PE pipe would provide a safer, cost effective alternative piping system.
III. ASTM Pressure Rating Method The ASTM pressure rating method utilizes pipe samples tested at a constant temperature with the log stress vs. log time regression line extrapolated to 100,000 hours. This extrapolated value is the long-term hydrostatic strength (LTHS) of the material, and the categorized value of the LTHS is called the Hydrostatic Design Basis (HDB) in accordance with ASTM standard test method D 2837. This HDB is reduced to a maximum working stress by a design factor (DF) to establish the Hydrostatic Design Stress (HDS). The HDS is the product of the HDB and the design factor for water:
HDS     HDB x DF (for water)
HDB and HDS values for various thermoplastic materials used for piping applications are published in PPI TR-4 which is available on the PPI website

www.plasticpipe.org. These PPI listings of HDB and HDS values are classified in accordance with the material's standard pipe material designation code. In this designation system, the plastic pipe material is identified by its standard abbreviated terminology in accordance with ASTM D 1600, "Standard Terminology Relating to Abbreviations, Acronyms, and Codes for Terms Relating to Plastics," followed by a four or five digit number. The first two or three digits, as the case may be, code the material's ASTM classification (short-term properties) in accordance with the appropriate ASTM standard specification for that material. The last two digits of this number represent the PPI recommended HDS for water at 73YF (23&deg;C) divided by 100. Examples of pipe material designation codes for PE materials are as follows:
* PE 3408 is a polyethylene (the PE abbreviation is in accordance with ASTM D 1600) with a density cell class of 3 and a slow crack growth (SCG) cell class of 4 (in accordance with ASTM D 3350). It has an 800 psi maximum recommended HDS (based on a design factor of 0.5) for water at 730 F (23&deg;C).
* PE 4710 is a polyethylene (the PE abbreviation is in accordance with ASTM D 1600) with a density cell class of 4 and a slow, crack growth (SCG) cell class of 7 (in accordance with ASTM D 3350). It has a 1000-psi maximum recommended HDS (based on a design factor of 0.63) for water at 73&deg;F (23&deg;C).
IV. PPI Program A coordinated industry effort was undertaken to revise PPI documents and ASTMIAWWA/CSA standards to recognize the improved performance properties of these high-performance PE materials. These newly defined performance properties enabled expanded classification of PE materials, and justified the use of a higher hydrostatic design stress for water piping applications. Several changes to PPI documents and ASTM standards were required to accomplish this. These included changes in the pipe material designation code:
* Base resin density - 1st digit in the code
* Slow crack growth (SCG) - 2nd digit in the code
" Hydrostatic design stress (HDS) - 3rd and 4th digits in the code

a) Base Resin Density PE 3408 materials used for water pipe applications have a base resin density about 0.944 g/cc, which is a D 3350 density cell class 3 - this is the first digit in the pipe material designation code PE 3408. Most high-performance PE 4710 materials have a base resin density around 0.950 g/cc. In order to differentiate the high performance HDPE materials from traditional HDPE materials, the density cell class of ASTM D 3350 was split to create a new density class 4 for the new high performance PE materials:
* Previous cell class 3 > 0.941 - 0.955 g/cc
" New cell class 3 > 0.941 - 0.947 g/cc
" New cell class 4 > 0.947 - 0.955 g/cc Most high-performance HDPE materials will have a density cell class 4 based on their base resin density around 0.950 g/cc.
b) Slow Crack Growth (SCG)
Slow crack growth is the dominant field failure mode for PE pipes. Simply put, it is a crack that can develop in PE pipe and grows slowly through the pipe wall.
Poor backfill, excessive surface damage, rock impingement, excessively tight bend radiuses, improper backfill and other field conditions could cause localized stress concentrations resulting in slow crack growth in polyethylene pipes. The resistance to slow crack growth is a valuable property for PE pipes.
The PENT (Pennsylvania Notch Test - ASTM F 1473) measures relative resistance to slow crack growth using a laboratory test method. A specimen is cut from a compression molded plaque. It is precisely notched and then exposed to a constant tensile stress at a temperature of 176&deg;F (80'C). The time to failure is recorded and this failure time is related to actual service life in the field. The PENT test has proven to be a very good indicator of SCG in PE pipes.
A published paper in the Plastic Pipe VIII conference provided data which correlated laboratory PENT values to field pipe performance. Based upon this

data, a laboratory PENT value of 10 to 20 hours, should correlate to a field life of at least 100 years with very few failures. PPI determined that a requirement of at least 500 hours PENT slow crack growth resistance would provide assurance that high performance PE pipes will be highly unlikely to fail in the field in the slow crack growth mode.
The current PE 3408 requirement for PENT (ASTM F 1473) performance in ASTM water pipe standards is 10 hours, which is a D 3350 SCG (slow crack growth) cell class 4 - this is the second digit in the pipe material designation code PE 3408. ASTM D 3350 was revised to add a new SCG cell class 7 for 500 hours to recognize the elevated SCG resistance of the high-performance PE materials.
* Current cell class 4 at least 10 hours
* Current cell class 6 at least 100 hours
* New cell class 7 at least 500 hours With this change, the traditional HDPE materials will have a SCG cell class 4 or 6, where high performance PE materials will qualify for the new SCG cell class 7.
c) Hydrostatic Design Stress The hydrostatic design stress (HDS) for PE 3408 materials is 800 psi for water at 73&deg;F (23 0C), which are the third and fourth digits in the pipe material designation code PE 3408.         High-performance PE materials that meet the increased performance requirements indicated below qualify to be listed in PPI document TR-4 with a 1000 psi HDS for water at 73&deg;F (23&deg;C) if the PE material meets high-performance criteria as published in PPI TR-3.           (

==Reference:==
Section F.7 of "Requirements For Polyethylene (PE) Materials To Qualify For A Higher Design Factor.")
: 1) PENT value over 500 hours
: 2) 23&deg;C stress regression line substantiated to 50 years
: 3) LCLiLTHS ratio over 90%
High-performance PE 4710 materials that meet the additional high performance have a 1000 psi HDS (based on a design factor of 0.63), where the "10" is derived

by dividing the 1000 psi HDS by 100.
As discussed above, PPI document TR-3 section F.7, "Requirements For Polyethylene (PE) Materials To Qualify For A Higher Design Factor," states that in order for a material to qualify for a recommended PPI design factor of 0.63, the HDPE material must meet three requirements. The Dow PE 4710 selected for use in the Callaway ESW replacement piping meets all three of these requirements as demonstrated below:
: 1) Minimum slow crack growth performance by ASTM F 1473 of 500 hours as required by ASTM D 3350 (i.e. PENT of at least 500 hours).
The Dow PE 4710 material significantly exceeds this requirement for resistance to slow crack growth (i.e., PENT greater than 10,000 hours) as shown in Enclosure 1 in ULNRC-05490 (Ref. 2).
: 2) 50 year substantiation according to Part F.5 of TR-3.
* The Dow PE 4710 material met this requirement as shown in Enclosure 3.
: 3) LCL/LTHS ratio of at least 90% as per ASTM D 2837               -Where LCL is Lower Confidence Limit - The lowest value of the LTHS, based on a statistical analysis of the regression data that can be expected at 100,000 hours.
* The Dow PE 4710 material met this requirement (i.e. LCL/LTHS greater than 93%) as shown on Enclosure 3.
Basis 3 - Reduction in Material Variability The purpose of the design factor in ASME Code is to account for the unknowns in the design and construction process. If the number and/or extent of the unknowns can be reduced, the design factor can be reduced without a reduction in safety.
In the typical design and construction of a piping system, the design is performed assuming minimum material performance requirements as defined by the Code.
Furthermore, there is no limit to the number of different suppliers that can supply piping

or fittings to be used in the same system. This results in an inherent amount of variability in the material properties. The design factor accounts for such variations.
The replacement Callaway ESW HDPE pipe and fitting are all being manufactured from Dow PE 4710 material. Furthermore, all piping is being manufactured in one facility from the same batch lot of resin material, and all fittings are being manufactured in one facility from the same batch lot of resin material. These facilities, and processes were assessed and witnessed by Ameren to assure all identified critical characteristics for the products being supplied were acceptably controlled.
These actions implemented by AmerenUE for this project significantly reduce the extent of the unknowns associated with material variability. Although the accounting for the material variability is not removed from the design factor for PPI or Callaway, the reduction in material variability at Callaway provides additional confidence that an increase in the design factor would not constitute a reduction in safety.

Enclosure 7 to ULNRC-05517

==SUMMARY==
OF REGULATORY COMMITMENTS The following table identifies those actions committed to by AmerenUE in this document. Any other statements in this submittal are provided for information purposes and are not considered to be commitments. Please direct questions regarding these commitments to Mr. Scott Maglio, Assistant Manager - Regulatory Affairs, (573) 676-8719.
COMMITMENT                           I            Due Date/Event AmerenUE will evaluate future investigations             Prior to submittal of Callaway's performed by the industry to confirm the short-          inservice inspection plan for the duration (30-day) stress allowables and applicable       fourth 10-year interval.
design factors for 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 inservice inspection plan, and will include, if necessary, a fourth-interval alternative request.}}