On a related note, however, there are some important classes of rings $R$ where \emph{countable countable prime avoidance} holds. That is, when an ideal $J$ is a subset of a \emph{countable} countable union of prime ideals in such a ring, it has to be contained in a single element of the collection. In particular, $R$ satisfies countable prime avoidance if either:
$R$ contains an uncountable field, or
$R$ is a complete Noetherian local ring.
Case 1 was mentioned in an article by Hochster and Huneke in the Michigan Math. Journal in 2000. Case 2 was proved by Lindsay Burch in 1972. Both arguments are fairly straightforward.
I learned these things from the Hochster-Huneke article some years back.

