Commentary

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By Jonathan K. Bennett, P.E., D.GE, M.ASCE

The use of American Petroleum Institute (API) N80 mill secondary material as micropile casing has been recognized as the industry standard in the U.S. for decades and is provided for in all industry standard

micropile design manuals and specifications. The Buy America Act (1983), Buy American Act (1933), and American Recovery and Reinvestment Act (ARRA) of 2009 require that steel used on projects receiving Federal funds be of domestic origin. As a re-sult, federal agencies and many state departments of transporta-tion have implemented requirements that mill certifications be provided for micropile casing to prove that it is in fact domestic.

Unfortunately, steel mills do not provide mill certifications for mill secondary material, primarily for legal reasons, so mill certifications are not available for these materials. In many instances, state and federal implementation of Buy America re-quirements result in micropile contractors having to purchase “prime” casing instead of “mill secondary” at a cost premium of 200-300 percent just to provide a mill certification. Some micropile casing suppliers can document that their mill secondary casing was manufactured in the U.S., but cannot provide mill certificates for the material.

The API N80 designation refers to an 80 ksi yield strength category of oilfield tubular goods. The API specifications are specific to material used as drill casing for oil drilling. In this

context, “mill secondary” material is a product that has been deemed by the producing mill, at the time of production, as not meeting the requirements of the API specification due to some physical or chemical variance. This variance prevents the product from being classified as “prime” product for the purposes of oil well drilling. However many of the requirements utilized to classify oilfield casing as either “prime” or “mill secondary” are not relevant to micropile casing applications. Of those that are relevant to micropile applications, there are none that cannot be easily verified and documented for mill secondary product through physical inspection and coupon sample testing.

The FHWA micropile manual, “Micropile Design and Con-struction Guidelines,” has recognized the use of mill secondary casing since 2000. However, state DOTs, beginning with New York, have begun enforcing regulations that do not allow the use of mill secondary material at all. Some micropile jobs have been cancelled due to significantly increased costs because of the added expense of meeting the procurement requirements of the Buy America Acts. Others are built at a higher than necessary cost to the U.S. taxpayer. In many instances, the requirement to use prime casing can result in micropiles no longer being an economical solution. In any case, using prime casing rather than mill secondary casing unnecessarily increases the cost substan-tially without any performance benefit. If these requirements are

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‘Buy America’ Act Threatens u.S. Micropile Business

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allowed to continue, they could threaten the use of micropiles altogether on projects subject to Buy America provisions.

A mill certification is an exceedingly stringent require-ment simply to prove national origin. There has been a heated debate of this issue within the U.S. micropile community. The position of the micropile design and construction community represented by the ADSC/DFI Joint Micropile Committee is:

“The use of mill secondary material as micropile casing has been recognized as the industry standard for many years and is provided for in all industry stan-dard micropile specifications. However, some project specifications (in an effort to meet Federal Buy America requirements) include requirements to provide prime casing with mill certifications as opposed to mill sec-ondary material. Prime casing offers no advantage in terms of either installation or in-service performance over properly verified mill secondary casing for micro-pile applications and costs two to three times what mill secondary casing does. The cost premium cannot be justified on the basis of performance. Therefore, there is no reasonable basis, from a performance standpoint, for specifying prime casing material as opposed to mill secondary material. It is the position of the ADSC/DFI

Joint Micropile Committee that the use of properly veri-fied mill secondary material for micropile casing is the most economically sensible approach and is preferred for general applications.”

Let’s use mill secondary material, made in the U.S., and keep our projects affordable. The ‘Buy American’ provisions allow for leeway if the resulting prices are unreasonable. This leeway needs to be applied to micropiles or only private development will be taking advantage of this very useful technology in the future. Without relief, we will have legislated ourselves out of many jobs that depend on this technology for public works.

AUTHOR

Jonathan K. Bennett, P.E., D.GE, M.ASCE is the chair of the Deep Foundations Institute (DFI) Micropile Committee. Jon is the Chief Engineer for the Mid-Atlantic Region at Brayman Construction Corporation and has over 18 years of experience in deep foundations and specialty geotechnical design and construction. He is the founder and author of the Micropile Design and Construction Blog. Jon can be reached at jonathan.bennett.pe@gmail.com