U.S. Department 1200 New Jersey Ave .. SE 

of Transportation Washington, D.C. 20590 

Federal Highway 

Administration September 27, 20 17 In Reply Refer To: 

HSST-1 /B-288 

Mr. Mark G. Fellows 

Nucor Steel Marion, Inc. 

912 Cheney A venue 

Marion, OH. 43302 

Dear Mr. Mark Fellows: 

This letter is in response to your June 30, 2017 request for the Federal Highway Administration 

(FHWA) to review a roadside safety device, hardware, or system for eligibility for 

reimbursement under the Federal-aid highway program. This FHW A letter of eligibility is 

assigned FHW A control number B-288 and is valid until a subsequent letter is issued by FHW A 

that expressly references this device. 

Decision 

The following devices are eligible, with details provided in the form which is attached as an 

integral part of this letter: 

• Nu-Guard® 3 I 

Scope of this Letter 

To be found eligible for Federal-aid funding, new roadside safety devices should meet the crash 

test and evaluation criteria contained in the American Association of State Highway and 

Transportation Officials'(AASHTO) Manual for Assessing Safety Hardware (MASH). 

However, the FHW A, the Department of Transportation, and the United States Government do 

not regulate the manufacture of roadside safety devices. Eligibility for reimbursement under the 

Federal-aid highway program does not establish approval, certification or endorsement of the 

device for any particular purpose or use. 

This letter is not a determination by the FHWA, the Department of Transportation, or the United 

States Government that a vehicle crash involving the device will result in any particular 

outcome, nor is it a guarantee of the in-service performance of this device. Proper 

manufacturing, installation, and maintenance are required in order for this device to function as 

tested. 

This finding of eligibility is limited to the crashworthiness of the system and does not cover other 

structural features, nor conformity with the Manual on Uniform Traffic Control Devices. 
2 

Eligibility for Reimbursement 

Based solely on a review of crash test results and certifications submitted by the manufacturer, 

and the crash test laboratory, FHWA agrees that the device described herein meets the crash test 

and evaluation criteria of the AASHTO's MASH. Therefore, the device is eligible for 

reimbursement under the Federal-aid highway program if installed under the range of tested 

conditions. 

Name of system: Nu-Guard® 31 


Type of system: Longitudinal Barrier 


Test Level: MASH Test Level 3 (TL3) 


Testing conducted by: Texas A&M Transportation Institute 


Date ofrequest: July 1, 2017 


Date initially acknowledged: July 11 , 2017 


FHWA concurs with the recommendation of the accredited crash testing laboratory as stated 

within the attached form. 

Full Description of the Eligible Device 

The device and supporting documentation, including reports of the crash tests or other testing 

done, videos of any crash testing, and/or drawings of the device, are described in the attached 

form. 

Notice 

This eligibility letter is issued for the subject device as tested. Modifications made to the device 

are not covered by this letter and will need to be tested in accordance with all recommended tests 

in AASHTO's MASH as part of a new and separate submittal. 

You are expected to supply potential users with sufficient information on design, installation and 

maintenance requirements to ensure proper performance. 

You are expected to certify to potential users that the hardware furnished has the same chemistry, 

mechanical properties, and geometry as that submitted for review, and that it will meet the test 

and evaluation criteria of AASHTO's MASH. 

Issuance of this letter does not convey property rights of any sort or any exclusive privilege. This 

letter is based on the premise that information and reports submitted by you are accurate and 

correct. We reserve the right to modify or revoke this letter if: (1) there are any inaccuracies in 

the information submitted in support of your request for this letter, (2) the qualification testing 

was flawed, (3) in-service performance or other information reveals safety problems, ( 4) the 

system is significantly different from the version that was crash tested, or (5) any other 

information indicates that the letter was issued in error or otherwise does not reflect full and 

complete information about the crashworthiness of the system. 
3 

Standard Provisions 

• 	 To prevent misunderstanding by others, this letter of eligibility designated as FHW A 

control number B-288 shall not be reproduced except in full. This letter and the test 

documentation upon which it is based are public information. All such letters and 

documentation may be reviewed upon request. 

• 	 This letter shall not be construed as authorization or consent by the FHW A to use, 

manufacture, or sell any patented system for which the applicant is not the patent holder. 

• 	 Ifthe subject device is a patented product it may be considered to be proprietary. If 

proprietary systems are specified by a highway agency for use on Federal-aid projects: 

(a) they must be supplied through competitive bidding with equally suitable unpatented 

items; (b) the highway agency must certify that they are essential for synchronization 

with the existing highway facilities or that no equally suitable alternative exists; or (c) 

they must be used for research or for a distinctive type of construction on relatively short 

sections of road for experimental purposes. Our regulations concerning proprietary 

products are contained in Title 23 , Code of Federal Regulations, Section 635.411. 

Sincerely, 

Robert Ritter 

Acting Director, Office of Safety 

Technologies 

Office of Safety 

Enclosures 
Version 10.0 (05/16) 

Page 1 of 4 

Request for Federal Aid Reimbursement Eligibility 

of Highway Safety Hardware 

Date of Request: June 30, 2017 I r. New C Resubmission 

Name: Mark G. Fellows 

.... 

QJ 

..... 

..... ·e 

Company: 

Address: 

Nucor Steel Marion, Inc. 

912 Cheney Avenue, Marion OH 43302 

..c 

:I 

Vl Country: U.S. 

To: Michael S. Griffith, Director 

FHWA, Office of Safety Technologies 

I request the following devices be considered eligible for reimbursement under the Federal-aid 

highway program. 

Device & Testing Criterion - Enter from right to left starting with Test Level Fl 

System Type Submission Type Device Name I Variant Testing Criterion Test 

Level 

'B': Rigid/Semi-Rigid Barriers 

(Roadside, Median, Bridge 

Railinas) 

(9 Physical Crash Testing 

(' Engineering Analysis 

Nu-Guard 31 Guardrail 

System 

AASHTO MASH TL3 

By submitting this request for review and evaluation by the Federal Highway Administration, I certify 

that the product(s) was (were) tested in conformity with the AASHTO Manual for Assessing Safety 

Hardware and that the evaluation results meet the appropriate evaluation criteria in the MASH. 

Individual or Organization responsible for the product: 

Contact Name: Steven J. Conway Same as Submitter D 

Company Name: Nucor Steel Marion, Inc. Same as Submitter ~ 

Address: 912 Cheney Avenue, Marion OH 43302 Same as Submitter ~ 

Country: U.S. Same as Submitter ~ 

Enter below all disclosures of financial interests as required by the FHWA 'Federal-Aid Reimbursement 

Eligibility Process for Safety Hardware Devices' document. 

There are no shared financial interests in the Nu-Guard 31 System between Nucor Steel Marion, Inc., and Texas 

A&M Transportation Institute, other than the costs involved in the actual crash tests and reports for this 

submission to FHWA. 
Version 10.0 (05/16) 

Page 2 of 4 

PRODUCT DESCRIPTION 

(i' New Hardware or 

• Significant Modification 

(' Modification to 

Existing Hardware 

The test installation was comprised of a 31-inch tall W-beam guardrail system utilizing 78-inch long, 4 lb/ft NuGuard"' guardrail posts (posts 3-28) with a 9 ft-4Vi inches long TxDOT Downstream Anchor Terminal (DAT-14) 

on each end, for a total installation length of 181 ft-3 inches. Posts 3 to 28 were equally spaced at 6 ft-3 inches. 

Standard 12-gauge W-beam guardrail (type RWM04a) was used in the system, and guardrail splices were 

located mid-span between every other post. Recessed guardrail nuts on the posts were tightened to 96 ft-lb of 

torque. The posts were installed in 18-inch diameter drilled shafts to the embedment depth of 47 inches and 

backfilled with AASHTO Ml 47-65(2004) grade B crushed limestone base, compacted to MASH standard. 

In Test 3-10 the height of the guardrail system was raised to 32 inches and the embedment depth of the posts 

was 46 inches. This was done to allow a range of rail height construction. Further explanation is provided in 

the test descriptions. No other elements of the system were changed for Test 3-10. 

CRASH TESTING 

By signature below, the Engineer affiliated with the testing laboratory, agrees in support of this submission that 

all of the critical and relevant crash tests for this device listed above were conducted to meet the MASH test 

criteria. The Engineer has determined that no other crash tests are necessary to determine the device meets 

the MASH criteria. 

Engineer Name: Nathaniel D. Schulz 

Engineer Signature: Nathaniel D Schulz Digitally signed by Nathaniel D. Schulz • Date: 2017.06.27 14:10:29 -05'00' 

Address: 3135 TAMU, College Station, Texas 77843-3135 Same as Submitter D 

Country: United States Same as Submitter D 

A brref description of each crash test and its result : 
Version 10.0 (05/16) 

Page 3 of 4 

Required Test 

Number 

Narrative 

Description 

Evaluation 

Results 

3-10 (11 OOC) 

For this test the guardrail system was raised 

to a height of 32 inches. This was done to 

provide a range for rail mounting height. As 

stated in MASH section 2.2.1 .1, small car 

tests should be conducted with barrier rail 

elements at the the maximum acceptable 

height and light truck tests should be 

conducted with rail elements at the 

minimum acceptable height. No other 

changes were made to the guardrail system. 

The results of the test conducted on 

February 7, 2017 are found in TII Test 

Report No. 690900-NSM 16. The Nu-Guard® 

31 contained and redirected the 11 OOC 

vehicle. The vehicle did not penetrate, 

underride, or override the installation. 

Maximum dynamic deflection during the 

test was 4.0 ft. The tops of several posts 

fractured and the rail element released from 

several posts. These detached elements 

and fragments did not penetrate or show 

potential for penetrating the occupant 

compartment, or present undue hazard to 

others in the area. Maximum occupant 

compartment deformation was 1.75 inches 

in the right front instrument panel area. 

The 11 OOC vehicle remained upright during 

and after the collision event. Maximum roll 

and pitch angles were 9 degrees and 6 

degrees, respectively. Occupant risk factors 

were within the preferred limits specified in 

MASH. 

PASS 

3-11 (2270P) 

The results of the test conducted on April 

25, 2017 are found in TII Test Report No. 

690900-NSM17. The Nu-Guard® 31 

contained and redirected the 2270P vehicle. 

The vehicle did not penetrate, underride, or 

override the installation. Maximum 

dynamic deflection was 87.6 inches. Small 

fragments from the test article were present 

but did not penetrate or show potential for 

penetrating the occupant compartment, 

nor present hazard to others in the area. No 

occupant compartment deformation or 

intrusion occurred. The 2270P vehicle 

remained upright during and after the 

collision event. Maximum roll and pitch 

angles were 18 degrees and 6 degrees, 

respectively. Occupant risk factors were 

within the preferred limits specified in 

MASH. 

PASS 

3-20 (11 OOC) Test 3-20 is not applicable for this type of 

system. Non-Relevant Test, not conducted 
Version 10.0 (05/16) 

Page 4 of 4 

Required Test 

Number 

Narrative 

Description 

Evaluation 

Results 

3-21 (2270P) Test 3-21 is not applicable for this type of 

system. Non-Relevant Test, not conducted 

Full Scale Crash Testing was done in compliance with MASH by the following accredited crash test 

laboratory (cite the laboratory's accreditation status as noted in the crash test reports .): 

Laboratory Name: Texas AM Transportation Institute 

Laboratory Signature: Darrell L. Kuhn Darrell L. Kuhn 

2017.06.29 18:58:20 -05'00' 

Address: 

Roadside Safety & Physical Security 

Texas A&M University System 

3135 TAMU, College Station, TX 77843 Same as Submitter 0 

Country: USA Same as Submitter 0 

Accreditation Certificate 

Number and Dates of current 

Accreditation period : 

ISO 17025 Laboratory, A2LA Testing Certificate #2821.01 

Expires April 30, 2019 

OigitaHys19"1edbyMarkfeMows 

Submitter Signature*: Mark Fellows Z"..:.:::::::.::~;o;;~::':.:~::... .. ema~=mafk.fellow§@outOJ tom, c=US 

O.ite·20l7.07.0111·42:23-04'00' 

Submit Form 

ATTACHMENTS 

Attach to this form: 

1) Additional disclosures of related financial interest as indicated above. 

2) A copy of the full test report, video, and a Test Data Summary Sheet for each test conducted in 

support of this request. 

3) A drawing or drawings ofthe device(s) that conform to the Task Force-I 3 Drawing Specifications 

[Hardware Guide Drawing Standards]. For proprietary products, a single isometric line drawing is 

usually acceptable to illustrate the product, with detailed specifications, intended use, and contact 

information provided on the reverse. Additional drawings (not in TF-13 format) showing details that 

are relevant to understanding the dimensions and performance of the device should also be submitted 

to facilitate our review. 

FHWA Official Business Only: 

Eligibility Letter 

Number Date Key Words 
Test Installation 

181 3" 

Lengt11 of Need 

162'-6' .- TxDOT DAT Term1na 

'>4'-0. 9 4 1 2 Typ each end 21'-0' 

Plan View 

Impact Patti See 1b A-. ,

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2A ?b ,4 22 20 18 16 14 12 10 8 4 

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H H H H H H H H H H H S 

A-. 

Elevation View 

Spacer Washer 

Recessed Guard'a11 Nut 

1T1ghtef' to 96 't1lbs 

See Exploded View at right 


4-space W-bean' G 

11' 

fl1e Bolt rests 1n the bottom of the slot 


' J 1/2" Button-head Guardrail Bolt 

Ground Line 

N 

0 Section A-A -.I 

I Scale 1 : 20 

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Nu-Guard 41b Guardrail Post 

1a. Backfill Post holes with AASHTO M147-65(2004 ). grade B 

crushed limestone road base. compacted to MASH standard. 

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Roadside Safety and 
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Physical Security Division 

Proving Ground 
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Project 690900-NSM-17 Nucor W-beam Rail I MASH 3-11 2017-03-24 e 

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Drawn By GES Scale1 :250 Sheet 1 of 1 Test Installation !­

Figure 2.1. Details of the Nu-Guard® 31. 

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General Information Impact Conditions Post-Impact Trajectory 

Test Agency ..... ... Texas A&M Transportation Institute (TTI) Speed ...... ...... . ....... 63.5 mi/h Stopping Distance ....... . ... 210 ft downstream 

Test Standard Test No ....... MASH Test 3-10 Angle . . . ... . . . .. . . . . . . . . . . ........ 24.6 degrees 8 ft twd field side 

TTI Test No. 690900-NSM16 Location/Orientation ........... 16 ft 2 inches Vehicle Stability 

Test Date ... 2017-02-07 upstream of post 13 Maximum Yaw Angle .... . 360 degrees 

Test Article Impact Severity ........ 57 kip-ft Maximum Pitch Ang le ... .. . 6 degrees 

Type Guardrail Exit Conditions Maximum Roll Angle . . ..... 9 degrees 

Name ......... ....... ......... Nu-Guard® 31 Speed .... 44.6 mi/h 
 Vehicle Snagging .. ... Yes 

Installation Length .... . .... 181ft 3 inches Angle ..... . .. 16.0 degrees 
 Vehicle Pocketing .. ... . ...... No 

Material or Key Elements ... 32-inch tall W-beam guardrail system with Occupant Risk Values Test Article Deflections 

4 lb/ft Nu-Guard® guardrail posts and Longitudinal OIV ... . ..... 16.4 ft/s Dynamic ..... . .... 4.0 ft 

TxDOT DAT-14 terminal Lateral OIV ........................ 14.8 ft/s Permanent ..... . ....... .. 2.4 ft 

Soil Type and Condition ..... AASHTO M147-65(2004), grade B Soil Longitudinal Ridedown ....... 5.5 g Working Width ... . .. .4.6 ft 

(crushed limestone), Damp Lateral Ridedown .. . . . ...8.2 g Vehicle Damage 

Test Vehicle 
 THIV ...23.2 km/h VOS ......... . ..................... 01RFQ4 

Type/Designation ... 11 OOC 
 PHO . . .... 8.5 g CDC .. . . ....... 01RFEW3 

Make and Model ...... 2011 Kia Rio 
 ASI.. . ............. 0.74 Max. Ex1erior Deformation .......... 7.5 inches 

Curb ................ 2474 lb 
 Max. 0.050-s Average OCDI . . . ..... .. .... . . .... RFOOOOOOO N Test Inertial 2444 lb Longitudinal ................... . -4.3 g 
 Max. Occupant Compartment 0 

Dummy ........ .. ... .......... 165 lb 
 Lateral .. .. -6.5 g 
 Deformation ...... 1.75 inches -.....) 

I Gross Static ...................... 2609 lb 
 Vertical. ..... . ....... - 2.3 g 


0 

Vo 

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N Figure 5.9. Summa ry of Results for MASH Test 3-10 on Nu-Guard® 31. w 
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$'. 0.000 s 0.250 s 0.500 s 0.875 s 

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....... ? 4 " 


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General Information Impact Conditions Post-Impact Trajectory 

Test Agency .... ... .... .. .. ........ Texas A&M Transportation Institute (TTI) Speed ................................. 64.4 mi/h Stopping Distance .... . . .......... 300 ft dwnstrm 

Test Standard Test No .... .. . MASH Test 3-11 Angle ... . . ........ ..... . ...... 25.4 degrees 1 ft twd field side 

TTI Test No. .. 690900-NSM1 7 Location/Orientation ... 24 inches upstream Vehicle Stability 

Test Date ....... 2017-04-25 of post 10 Maximum Yaw Angle .. . 49 degrees 

Test Article Impact Severity .... 128 kip-ft Maximum Pitch Angle ..... ........... 6 degrees 

Type ... .. . . ...... Guardrail Exit Conditions Maximum Roll Angle ......... ........ 18 degrees 

Name ... ...... ... ......... . . ... Nu-Guard® 31 Speed .......... . .41 .1 mi/h 
 Vehicle Snagging ........... ... No 

Installation Length ........... .... 181 ft 3 inches Angle .... ...9.8 degrees 
 Vehicle Pocketing ..................... No 

Material or Key Elements ... 31-inch tall W-beam guardrail system with Occupant Risk Values Test Article Deflections 

4-lb/ft Nu-Guard® guardrail posts and Longitudinal OIV ... .. ......... ... 12.8 ft/s 
 Dynamic .......................... ........... 87.6 inches 

TxDOT DAT-14 terminal Lateral OIV ............. .... ... .. .... 12.5 ft/s 
 Permanent ...... . 45.0 inches 

Soil Type and Condition ... .. AASHTO M147-65(2004), grade B Soil Longitudinal Ridedown ... .. .. .4.3 g 
 Working Width .. . . ....... 96.8 inches 

(crushed limestone). Damp Lateral Ridedown ...... 6.3 g 
 Vehicle Damage 

Test Vehicle THIV . . ...................... 18.6 km/h 
 VOS 01RFQ5 

Type/Designation ..... 2270P PHO .......... 7.4 g 
 CDC ............... .. .... . ... 01FREW4 

Make and Model ... 2011 Dodge RAM 1500 ASI ........... 0.52 
 Max. Exterior Deformation .... .... 12.0 inches 

Curb .............. . ... 4885 lb Max. 0.050-s Average OCDI ... . ............... FSOOOOOOO N 

0 Test Inertial .... . ....... 5038 lb Longitudinal ............... -3.8 g Max. Occupant Compartment 

Dummy .. No dummy Lateral ... ..... -4.4 g Deformation ............. None -.J 

I Gross Static ... .. . .... 5038 lb Vertical .. . .... -2.3 g 0 

0\ 

I 

0 Figure 5.10. Summary of Results for MASH Test 3-11 on Nu-Guard® 31. 00