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Request
Action: Notice, request for comments.
Web posting date: 06/22/2008
Federal Register Notice of Finding Publication Date:
08/25/08
Effective Date of Federal Register:
08/26/08
Close of public comment period:
09/10/08
Summary:
The Federal Highway Administration (FHWA) is seeking comments on whether a waiver of the Buy America requirements of 23 CFR 635.410 should be granted to permit the use of non-domestic Stainless Clad Rebars, Quantity: 359,875 lbs in the state of Virginia.
FHWA will only consider a Buy America waiver when the conditions of 23 CFR 635.410( c) have been met: (1) when the application of the provision would be inconsistent with the public interest; or (2) when steel and iron products are not produced in the United States in sufficient and reasonably available quantities, which are of a satisfactory quality.
The FHWA will consider all comments received in the initial 15-day comment period during our evaluation of the waiver request. Comments received after this period, but before notice of our finding is published in the Federal Register, will be considered to the extent practical. Follow-up coordination on the comments received may result in a delay in the publication of our waiver finding in the Federal Register. Comments received during the 15-day comment period after notice of our finding is published in the Federal Register will be reviewed, but the finding will continue to remain valid. Comments received during the comment period after the effective date of the finding will be reviewed, and may influence the FHWA's decision to terminate or modify a finding.
Comments
| Gena Peters 06/20/2008 |
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Non-domestic stainless clad rebar should not be granted a waiver for Federal-aid highway project #BR-041-3(026), BR-047-2(120), BR-340-8(012), STP-PM01-(224) in the state of Virginia. Solid stainless steel rebar is produced in sufficient and reasonably available quantities in the United States. American manufactured solid stainless steel rebar is more cost effective than foreign made stainless clad rebar, especially now with EnduraMet32 being recently included in the Virginia DOT Specification Section 223 for steel reinforcement.
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| Raymond Schnell 06/23/2008 |
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Standard solid stainless steel rebar products, such as 316LN and 2205, may have higher costs, however Talley Metals manufactures a grade called EnduraMet 32 (UNS S24100) which has been approved in Virginia, as well as in New York and Pennsylvania. This grade has significantly lower Nickel and Molybdenum contents. Manganese has been used to replace the Nickel, and provides excellent corrosion resistance. Testing conducted by an independent 3rd party has confirmed its comparable corrosion resistance and strength to 316LN and as such, it is very cost competitive, and in fact it is less expensive than the stainless clad product. The product is weldable, with no worry of cracked or spalled cladding, and no worry of flaking during fabrication. It does not require end caps, such as with the stainless clad product, and it is readily available, in significant quantities. Life cycle charts indicate that the EnduraMet 32 (UNS S24100) has a life expectancy of 100+ years. We do not believe the stainless clad is available in sizes #3 and #4, but EnduraMet 32 is available in all sizes, from #3 to #16. Clad product only covers carbon steel, whereas solid stainless steel rebar, is stainless throughout, and it is corrosion resistant, regardless of the way it is formed or handled. We believe that non-domestic material should not be used, and a waiver should not granted, when lower cost alternatives, such as EnduraMet 32, are readily available and melted and manufactured in the United States.
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| steve kahl 06/23/2008 |
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The clad product is suitable for use as reinforcing steel. Corrosion resistance is comparable to the solid products and I believe the cladding thickness is such that damage to straight segments is unlikely from handling or shipping. The cost advantage is also beneficial as compared to solid, even when considering the newer products as mentioned above. The sizing limitation can be accommodated with solid stainless in sizes of #3 and #4 as needed, and it can be bent provided the bend radius is consistent with that specified for epoxy coated reinforcement.
Support of the foreign made stainless clad could encourage domestic development of the product. Just as solid stainless can be selectively used in a structure to maximize cost efficiency, appropriate use of the clad bar would be highly beneficial in encouraging more widespread use of corrosion resistant materials to obtain the 75 to 100 year service life. Stainless clad bar should be viewed as a complement to the use of solid stainless as opposed to competitive.
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| JP Belmont 06/23/2008 |
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I dont see any interest for FHWA to buy stainless clad rebar from Europe. for 3 reasons : 1. The product is not produced in the US 2. The company in Wales cannot guaranty the production in quantity (they have delivered 40 MT within the last 2 years) and the quality in term of corrosion and chemical and mecanichal specs. 3. Also, The price of stainless clad rebar is now equal or more expensive than solid stainless steel (2304) produced in the US and much more expensive than solid stainless steel (2101)produced in the US. 2101 address corrosion for +75 years and 2304 for +150 years
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| steven kahl 06/25/2008 |
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I disagree with the statement that ss clad is much more expensive than 2101 stainless. You are certainly not selling 2101 stainless for $1.80/lb fabricated, delivered, and installed.
For the Michigan demo project, the actual bid price for 95,000 lb of stainless clad reinforcement was $1.80/lb. Actual bid price for 72,000 lb of solid stainless reinforcement (spec did not include the newer types 2101/2304) was $5.00/lb.
The estimated bid price for the newer types of stainless (considering a 40% reduction) would be $3.20 to $3.40/lb, therefore there is still a pricing advantage to the clad steel.
I do not work for the stainless clad nor the solid stainless manufacturers, suppliers, or fabricators.
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| JULIUS F. J. VOLGYI, JR. 07/29/2008 |
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Virginia DOT (VDOT) (Structure and Bridge Division) is implementing a plan in 2008 to use corrosion resistant reinforcing (CRR) steels in its structures replacing the epoxy-coated and galvanized reinforcing steels. The VDOT plan is to do a few preliminary projects in 2008 and allow all three types of CRR: ASTM 1035 (MMFX-2), stainless clad and stainless. In 2009, VDOT would like to specify the type of CRR used on individual projects. Then, in January 2010 VDOT is planning full implementation with the Contractor supplying any of the three types of CRR noted in the specifications: ASTM 1035, stainless clad or stainless. VDOT feels that by specifying the type of CRR in 2009 on individual projects, it would be in a better position to evaluate cost, delivery problems or field problems before going to full implementation in 2010.
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| Michael Bergmann 08/25/2008 |
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The limitation of SS clad bars is that they are only made (currently) in a few sizes. If the VDOT deck design accommodates those sizes, then the waiver is appropriate.
However, a waiver for a product that requires re-design of the owner's "standard" deck seems to be a waste of time. Similarly, if the SS clad material must be supplemented with solid SS in the sizes that are not available in SS clad, what's the point?
The most important reason for using the UK-produced SS clad bars is that they are "assumed" to be cheaper than solid SS bars, (depending on the alloy.) If the SS clad bars are no cheaper than the solid bars, there is no reason for a waiver. If the SS clad bars are not available in the needed sizes, and the (presumably) more expensive solid SS bars must be used anyway, there also seems to be little public interest in a waiver.
So, it seems that the use of foreign SS clad bars is in the public interest under the following circumstances:
1. The material price (FOB jobsite) is lower than domestic solid SS bars.
2. The SS clad bars are produced in the needed sizes, or the structure can reasonably be re-designed to accommodate the available sizes without major engineering cost to the owner.
Note that some "empirical" deck designs (including New York's) cannot readily be re-designed because they utilize #4 bars at 8" spacing. While #5 bars at 12" spacing provides similar flexural resistance, "empirical' designs often utilize a "membrane" model and the 8" spacing must be maintained.
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| Rodney G. Powers 08/27/2008 |
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The stainless steel clad reinforcing bar being produced today is of consistent high quality and will meet all applicable specifications. Research has consistently shown 316 clad bars to have essentially the same corrosion resistance as solid stainless steel. The cladding is of sufficient thickness to withstand the most severe of handling conditions without breech. Competing quasi-stainless steels have consistently shown only marginal improvement over that of conventional carbon steel bars.
It is reported that the manufacturer is capable of producing #4 stainless steel clad bars.
None of the users to date have reported any difficulties associated with the end caps.
Posted by: Rodney G. Powers, Retired, Florida Department of Transportation; DBA: Rodney G. Powers & Associates, LLC.
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Contact
Edwin Okonkwo
Office of Program Administration
202-366-1558
E-mail Edwin
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