American Iron and Steel Requirement - Withdrawn or Denied Waivers

Response to Request for Waiver of the AIS Requirements for Clean Water and Drinking Water SRF Assistance Recipients Serving 10,000 or Fewer Persons (October 30, 2015)
This decision memorandum documents the U.S. Environmental Protection Agency's response to a request from several states to waive the American Iron and Steel requirements for Drinking Water and Clean Water State Revolving Fund assistance recipients serving 10,000 or fewer persons. The EPA reviewed all comments and provides the following decision, including rationale for that decision, in the memorandum. The EPA does not approve the requests for a waiver of the AIS requirements for assistance recipients serving 10,000 or fewer persons.
Pressure Sustaining Valves for Fairview Water District, Idaho
The State withdrew Fairview Water District's waiver request for pressure sustaining valves after the assistance recipient was able to find a domestic supplier who could provide the valves in time to meet the project schedule.
Stainless Steel Pipes and Fittings for Culberston, Montana
After conducting market research, EPA identified several manufacturers that indicated they could produce the specific items in question domestically and in a reasonable timeframe. EPA provided this information to the assistance recipient and they were able to find a domestic supplier who could provide the valves in time to meet the project schedule. Therefore, EPA is not approving this waiver request.
Butterfly Valves for City of Mosinee, Wisconsin
The State withdrew the City of Mosinee's waiver request for butterfly valves after determining that the project was exempt from the AIS requirements based on the plans and specifications being approved prior to December 16, 2014.
Viton Seated Air Valves for Oldham County, Kentucky
Oldham County, Kentucky withdrew this project waiver application, as the valves in question were determined to be appurtenances to non-covered items in an assembly, and thus not required to comply with AIS. This waiver determination only applies to this project and circumstance. The product in question may not be exempt in other applications or projects. Any project using similar products and seeking a similar determination should contact EPA.

Large Diameter Butterfly Valve Request for City of Roswell, New Mexico
EPA conducted market research regarding lead time and delivery of this product, and identified one manufacturer that indicated it could domestically produce large butterfly valves that meet the City's technical specifications and could deliver the product within 6-10 weeks. The information regarding the manufacturer was provided to staff in New Mexico and the City of Roswell. Therefore, EPA is not approving this waiver request.

Public Interest Waiver Request for DWSRF Emergency Generator Projects in Connecticut
While EPA understands the urgency to complete these critical projects and at the same time not unduly burden communities for these low cost projects, the major iron and steel products needed for these projects are readily available in the U.S. Therefore, EPA is not approving this waiver request.

Butte-Silver Bow County, Montana Waiver Request for Spring-Assisted Swing Check Valves
After conducting market research, EPA identified one manufacturer that indicated they could produce the specific valve in question in a reasonable timeframe. EPA provided this information to the assistance recipient and received confirmation that the product would be suitable for the project. Therefore, EPA is not approving this waiver request.
Stainless Steel Flanges and Fittings Waiver for Williston, North Dakota
After conducting market research, EPA identified several manufacturers that indicated they could produce the specific items in question domestically and in a reasonable timeframe. EPA provided this information to the assistance recipient. Therefore, EPA is not approving this waiver request.
Precast Concrete Segment Steel Fiber Reinforcement for Dugway Storage Tunnel
EPA is not approving this waiver request because it lacks sufficient justification to grant a waiver of the AIS requirements based on availability. Decision Memorandum for Availability Waiver Request
42-Inch Butterfly Valve for Gastonia, North Carolina
Even though the City of Gastonia’s claim that no domestic manufacturers could provide 42-inch diameter butterfly valves that met the project specification within a reasonable timeframe may have been supported, the request was submitted to the EPA after the product had already been installed. Therefore, EPA is not approving this waiver request.
Ductile Iron Flanges for Mobile, Alabama
On May 12, 2016, Alabama submitted a product waiver request on behalf of Mobile Area Water and Sewer System (MAWSS) for the use of a non-domestic 54-inch ductile iron flange and a 54-inch tapped ductile iron flange as part of its CC Williams Wastewater Treatment Plant Headworks and Primary Clarifier projects. The applicant was unable to locate domestically sourced products that met the project specifications. EPA conducted market research on the supply and availability of the flanges and found two manufacturers that could supply the AIS-compliant products that met the project specifications and could be delivered on time to avoid significant delays in the project schedule. The applicant confirmed the domestic products were suitable for the project. Therefore, the waiver request was denied.
2-Inch Swing Check Valves for Hidden Lake Float Home Association Coeur d'Alene, Idaho
On May 10, 2016, Idaho submitted a product waiver request on behalf of the Hidden Lake Float Home Association for 22, two-inch, swing check valves with external levers and springs. The applicant 's contractor was not able to find AIS-compliant check valves that could meet the project's technical specifications within a short enough timeframe to meet their targeted installation date. EPA conducted market research on the supply and availability and found domestic two-inch check valves that met the project specifications and that were available within a reasonable amount of time. EPA provided information about the alternate products to the state of Idaho and the Hidden Lake Float Home Association. The state confirmed through the project engineer that alternative domestic check valves were used. Therefore, the waiver request was denied.
Large Diameter Butterfly Valves for Kingsport, Tennessee
EPA is hereby denying the State of Tennessee’s request for a timing availability waiver of the American Iron and Steel requirement for large diameter butterfly valves for the City of Kingsport’s Raw Water Intake and Transmission Improvements Project. EPA identified at least two manufacturers that indicated they could produce domestic valves that meet the project specifications and schedule.
Flexible Stainless Steel Couplings for Leonardtown, Maryland
After conducting market research, EPA identified several manufacturers that indicated they could produce the specific items in question domestically and in a reasonable timeframe. EPA provided this information to the assistance recipient and they were able to find a domestic supplier who could provide the valves in time to meet the project schedule. Therefore, EPA is not approving this waiver request.
Adapt-a-Bells for Sioux Falls, South Dakota
EPA is not approving this waiver request because it was not submitted within reasonable timeframe of the recipient learning that AIS compliant products might not be available and the products had already been installed.
Pressure and Vacuum Release Valves for Vista, California
After conducting market research, EPA identified manufacturers that indicated they could produce the specific valves in question in a reasonable timeframe. EPA provided this information to the assistance recipient and received confirmation that the alternative would be suitable for the project. Therefore, EPA is not approving this waiver request.