Action: Notice, request for comments.
Web posting date: 09/30/2008
Federal Register Notice of Finding Publication Date:
Effective Date of Federal Register:
Close of public comment period:
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 1. Stainless steel bridge suspender cable assemblies (34 ea); 2. Stainless steel glass panel attachment hardware (Spider fittings) (1,250 ea); 3. Stainless steel mesh at railings and elevator (2,070 sq ft.); 4. Stainless steel grade 2205 (91,999 lbs) for experimental purposes in construction of Park Boulevard at Harbor Drive Pedestrian Bridge for the City of San Diego, CA in the state of City of San Diego, CA.
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.
|Lloyd Welker 09/05/2008|
Again I cannot support this total waiver. First the designer during design should have recognized any requirements added were either available in the US or not. Second some of these items appear aesthetic and not criteria that couldn't be provided by someone in the US.Third, the last item of #92000 has no definition of use. |
|Raymond Schnell 09/08/2008|
We believe that this waiver should not be granted. (1) It is our understanding, that Insteel, a domestic supplier of wire and cable, is capable of producing these bridge suspender cable assemblies. (2) There are several domestic manufacturers of stainless steel products, that could produce the spider fittings required. (3) Salit Specialty Rebar, also a domestic supplier, has an inventory of stainless wire mesh. Is it possible to get more detailed information on the grid size required? (4) Finally, the last item, indicates 91,999 pounds of 2205 stainless steel, but does not indicate which form it may be. If it is rebar for example, then we here at Talley Metals, can provide sizes from #3 to #16 in this grade, and we are a domestic supplier of solid stainless steel rebar, and we do produce 2205, as well as other solid stainless steel grades. |
|Wade Durant, T.Y.Lin International 10/14/2008|
In response to the comment from Raymond Schnell on 9/08/08, we have looked into the companies that were recommended by Raymond Schnell to determine if they could produce any of the products that would meet the project’s needs. |
1) The first item recommends Insteel to produce stainless steel suspenders. When we contacted their sales department, we were redirected to the department responsible for high strength tendons. The representative of that department said that they primarily produce post-tensioning strand and he was not aware of any stainless steel products that they made. He recommended Bridon for stainless steel bridge suspenders.
2) Regarding the domestic suppliers of spider fittings for the glass, it is our understanding that that the fittings could be supplied domestically and the glass could be supplied domestically, but there was not a domestic company that would supply both or one that would guarantee the performance of their stainless steel fittings being used with another company’s glass products.
Following is a response to this issue from Roger Watson at SAINT-GOBAIN GLASS:
"The Litewall Mono point-fixed glazing system has been developed over many years with thorough research, development and testing of component parts. For a system of this nature to perform in its structural capacity and indeed be warranted for 10 years, it is critical that each of the component parts are procured and assembled in accordance with the testing an certification program which has been mandated by the DIBT (German Institute for Building Technology)." "The glass and integral countersunk fittings MUST be used together to ensure that the stresses induced by live loads are effectively and safely transferred through the glass to the fittings and thereon back to the supporting structure." "In order for these loads to be correctly and safely distributed back to the structure it is critical that tried and tested connections fitting e.g. "spiders" are used. Since the warranty for design and manufacture of the glass and associated components is part of the scope, it is necessary to use the Litewall system components." "It is true that many components can be sourced individually but then a "system" warranty will not apply. Should failure ever occur (for whatever reason) the end user will need to contact a source for the warranty. It is not possible to obtain a glazing system or structural warranty from a material source company such as CR Laurence." "Eckelt's Litewal spiders have been developed in-house and their performance characteristics are known. Independent suppliers might provide information but will rarely support design development procedures." "For example, the CR Laurence "Heavy Duty" spider works on glass only up to 20mm thick. There is glass on this project which is 25mm thick - what solution is there here to use the spider material supplier ?" "I would also be careful as to "manufacturers" of spiders in the US. They might have locations here but it is highly likely that the spiders are procured overseas anyway."
3) We contacted Salit Specialty Rebar and inquired about the stainless steel wire mesh for the railings. The representative told us that they do not produce any decorative railing type mesh suitable for our application. The mesh they produce is used for reinforcing steel and cannot be used for the application on our bridge.
Following is a response to this issue from John Palkoner at Carl Stahl DecorCable Innovations:
"Even though the mesh is produced in Germany, we are an American company, and have been in business in Chicago for the last 12 years. Our parent company is Sava Industries, and they are also based in New Jersey. You are buying from an American company, the mesh just isn't mfg. here. There is no other company in this hemisphere that makes this type of mesh. We only have one competitor and their headquarters is in Europe. There are other so called "mesh" suppliers here but they are not the same. Our mesh is made of cable. Most of the suppliers here, what they call "mesh" isn't cable, it is solid, and looks and acts like chain link fence, completely different. If you find anyone here that does the cable, it is all hand woven, and is not used for guard rails, and wont pass codes, they open up the cables to pass the other cable thru, not very strong. Our cable mesh is put together w/ the ferrules, and the integrity of the cables is not compromised. If you want, you can either buy all the support cables for the mesh locally, or I can have the support cables made in New Jersey. Let me know if you need anything else or have any questions."
4) The grade 2205 stainless steel plate and pipes are for use in the railings and cable guide pipes. The railings and guide pipes are primary structural members of the bridge and as such have very specific strength and durability requirements. We contacted Talley Metals and they do not produce duplex stainless steel plate or pipe. They are a rebar specialist and we do not have any stainless steel rebar on the project.
|Wade Durant, T.Y.Lin International 10/14/2008|
In Response to Lloyd Welker’s comments: We feel that our response to Mr. Schnell addresses the aesthetic elements in some detail already. As this project has evolved through a myriad of public meetings and input from various civic and project stakeholders, a desire for a world class landmark structure has been a goal of all parties. Unlike many of the great roadway bridges of the past, successful pedestrian bridges are viewed from both the macro and micro scale. This structure will not only be viewed from several vantage points from downtown San Diego in automobiles, but will also be experienced by the public at a more intimate and tactile close-up level. The project strives to seamlessly blend the rigors of engineering principals with forms and materials that are tailored to be experienced at a refined, human, tactile level. It is in these two scales that we have approached the selection of materials and finishes for this structure. |
Regarding the Structural Stainless Steel: The use of the Grade 2205 stainless steel is for the structural railings and external prestressing guide pipes. The need for higher grade materials is due to the structural nature of the railing and guide pipes that require a higher strength material and the need for those items to be highly corrosion resistant. Both of these characteristics are inherent in the Grade 2205 stainless steel, but are not found in the grades of stainless steel available in America.
Regarding Suspender Cable Fittings: American companies do produce fittings large enough for our bridge but nothing that is stainless steel and no galvanized or painted fittings that meet the aesthetic requirements of this bridge. Bridon is a UK company that produces an aesthetic product in painted or "Metal Coat" finish. American companies do produce stainless fittings for aircraft wire or marine applications, but nothing large enough for our bridge. Pfeifer is a company which produces a stainless steel fitting that is large enough for this bridge and meets the aesthetic requirements.
We have done extensive research, during the design, into the US steel industry to find domestic suppliers of both of these items. The result was that we felt a waiver of the Buy America requirement was needed. We have many pages of documentation backing up this research that is unfortunately too extensive to post here, but has been submitted to FHWA for their review.
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