Request
Action: Notice, request for comments.
Web posting date: 08/12/2008
Federal Register Notice of Finding Publication Date:
10/06/08
Effective Date of Federal Register:
10/07/08
Close of public comment period:
10/22/08
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 steel clad reinforcement bars; Quantity; 124,900 IB in the state of Rhode Island.
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
| Lloyd Welker 08/12/2008 |
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Simple comment is NO. Ohio already tested some of this material earlier and it didn't meet their specification requirements. Now we are proposing because it isn't produced here that we should make it available. If that is the alternative then remove the law period, not just for the special product you want. We can get better wire strand for prestressed and post tensioned outside this country. Lets waive that. We currently pay 2 to 3 times higher for pipe castings made in this country than if we bought from another country and the product is better quality. While I don't want to step on Rhode Island's use this is just a game. Ohio couldn't get strand for a bridge for a year and was refused the waiver. We have run into strand quality problems on another bridge that the higher control of Japanese strand would have eliminated the problem. Change the law. If products meet specs they can be used. Not by USA. FHWA refuses to allow a state to have a buy Ohio clause for federal funds. Why should FHWA be allowed a buy America clause.
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| Raymond Schnell 08/19/2008 |
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Solid stainless steel rebar products, such as 316LN and 2205, may currently have higher costs, when compared to some of the other types of corrosion resistant products available in the marketplace today, however Talley Metals manufactures a grade called EnduraMet 32 (UNS S24100 or XM-28) which has been approved by the DOT's in Virginia, as well as in New York and Pennsylvania. This grade has significantly lower Nickel and Molybdenum contents than 316LN. Manganese has been used to replace Nickel, and provides excellent corrosion resistance. Testing conducted by an independent 3rd party has confirmed it has 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 in the lengths and sizes required for use. Life cycle charts indicate that the EnduraMet 32 (UNS S24100) has a life expectancy of 100+ years. We do not believe that stainless clad is available in sizes #3 and #4, but the EnduraMet 32 is available in all sizes, from #3 to #16. Stainless clad product only provides a thin cover over its carbon steel core, whereas solid stainless steel rebar, is stainless throughout, and it is corrosion resistant, regardless of the way it is formed or handled. We feel strongly and 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 are melted and manufactured in the United States.
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| Rodney G. Powers 08/28/2008 |
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Originally posted on August 27, 2008:
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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