MESSAGE NO: 5032112 DATE: 02 01 1995
CATEGORY: ADA TYPE: PRE
REFERENCE: REFERENCE DATE:
CASES: A - 357 - 809 A - 351 - 826
A - 428 - 820 A - 475 - 814
- - - -

PERIOD COVERED: 01 27 1995 TO

LIQ SUSPENSION DATE:

TO: REGIONAL DIRECTORS, COMMERCIAL OPERATIONS
DISTRICT DIRECTORS, AREA AND PORT DIRECTORS

FROM: DIRECTOR, TRADE COMPLIANCE DIVISION

RE: PRELIMINARY - SEAMLESS CARBON AND ALLOY STEEL
(A-357-809, A-351-826, A-428-820, AND A-475-814)


1. THE DEPARTMENT OF COMMERCE PUBLISHED IN THE FEDERAL REGISTER
ON JANUARY 27, 1995 ITS NOTICES OF THE PRELIMINARY DETERMINATIONS
OF SALES AT LESS THAN FAIR VALUE IN THE ANTIDUMPING DUTY
INVESTIGATIONS OF SMALL DIAMETER CIRCULAR SEAMLESS CARBON AND
ALLOY STEEL STANDARD, LINE AND PRESSURE PIPE (SEAMLESS PIPES)
FROM ARGENTINA, BRAZIL, AND GERMANY. ON THE SAME DATE, THE
DEPARTMENT ALSO PUBLISHED ITS NOTICE OF THE PRELIMINARY
DETERMINATION OF SALES AT NOT LESS THAN FAIR VALUE IN THE
ANTIDUMPING DUTY INVESTIGATION OF SMALL DIAMETER CIRCULAR
SEAMLESS CARBON AND ALLOY STEEL STANDARD, LINE, AND PRESSURE PIPE
(SEAMLESS PIPE) FROM ITALY.

2. FOR PURPOSES OF THESE INVESTIGATIONS, SEAMLESS PIPES ARE
SEAMLESS CARBON AND ALLOY (OTHER THAN STAINLESS) STEEL PIPES, OF
CIRCULAR CROSS-SECTION, NOT MORE THAN 114.3MM (4.5 INCHES) IN
OUTSIDE DIAMETER, REGARDLESS OF WALL THICKNESS, MANUFACTURING
PROCESS (HOT-FINISHED OR COLD-DRAWN), END FINISH (PLAIN END,
BEVELLED END, UPSET END, THREADED, OR THREADED AND COUPLED), OR
SURFACE FINISH. THESE PIPES ARE COMMONLY KNOWN AS STANDARD PIPE,
LINE PIPE OR PRESSURE PIPE, DEPENDING UPON THE APPLICATION. THEY
MAY ALSO BE USED IN STRUCTURAL APPLICATIONS.

THE SEAMLESS PIPES SUBJECT TO THESE INVESTIGATIONS ARE
CURRENTLY CLASSIFIABLE UNDER SUBHEADINGS 7304.10.10.20,
7304.10.50.20, 7304.31.60.50, 7304.39.00.16, 7304.39.00.20,
7304.39.00.24, 7304.39.00.28, 7304.39.00.32, 7304.51.50.05,
7304.51.50.60, 7304.59.60.00, 7304.59.80.10, 7304.59.80.15,
7304.59.80.20, AND 7304.59.80.25 OF THE HARMONIZED TARIFF
SCHEDULE OF THE UNITED STATES (HTSUS).

THE FOLLOWING INFORMATION FURTHER DEFINES THE SCOPE OF THESE
INVESTIGATIONS WHICH COVERS PIPE MEETING THE PHYSICAL PARAMETERS
DESCRIBED ABOVE:

SPECIFICATIONS, CHARACTERISTICS AND USES: SEAMLESS PRESSURE
PIPES ARE INTENDED FOR THE CONVEYANCE OF WATER, STEAM,
PETROCHEMICALS, CHEMICALS, OIL PRODUCTS, NATURAL GAS AND OTHER
LIQUIDS AND GASSES IN INDUSTRIAL PIPING SYSTEMS. THEY MAY CARRY
THESE SUBSTANCES AT ELEVATED PRESSURES AND TEMPERATURES AND MAY
BE SUBJECT TO THE APPLICATION OF EXTERNAL HEAT. SEAMLESS CARBON
STEEL PRESSURE PIPE MEETING THE AMERICAN SOCIETY FOR TESTING AND
MATERIALS (ASTM) STANDARD A-106 MAY BE USED IN TEMPERATURES OF UP
TO 1000 DEGREES FAHRENHEIT, AT VARIOUS AMERICAN SOCIETY OF
MECHANICAL ENGINEERS (ASME) CODE STRESS LEVELS. ALLOY PIPES MADE
TO ASTM STANDARD A-335 MUST BE USED IF TEMPERATURES AND STRESS
LEVELS EXCEED THOSE ALLOWED FOR A-106 AND THE ASME CODES.
SEAMLESS PRESSURE PIPES SOLD IN THE UNITED STATES ARE COMMONLY
PRODUCED TO THE ASTM A-106 STANDARD.

SEAMLESS STANDARD PIPES ARE MOST COMMONLY PRODUCED TO THE
ASTM A-53 SPECIFICATION AND GENERALLY ARE NOT INTENDED FOR HIGH
TEMPERATURE SERVICE. THEY ARE INTENDED FOR THE LOW TEMPERATURE
AND PRESSURE CONVEYANCE OF WATER, STEAM, NATURAL GAS, AIR AND
OTHER LIQUIDS AND GASSES IN PLUMBING AND HEATING SYSTEMS, AIR
CONDITIONING UNITS, AUTOMATIC SPRINKLER SYSTEMS, AND OTHER
RELATED USES. STANDARD PIPES (DEPENDING ON TYPE AND CODE) MAY
CARRY LIQUIDS AT ELEVATED TEMPERATURES BUT MUST NOT EXCEED
RELEVANT ASME CODE REQUIREMENTS.

SEAMLESS LINE PIPES ARE INTENDED FOR THE CONVEYANCE OF OIL AND
NATURAL GAS OR OTHER FLUIDS IN PIPE LINES. SEAMLESS LINE PIPES
ARE PRODUCED TO THE API 5L SPECIFICATION.
SEAMLESS PIPES ARE COMMONLY PRODUCED AND CERTIFIED TO MEET
ASTM A-106, ASTM A-53 AND API 5L SPECIFICATIONS. SUCH TRIPLE
CERTIFICATION OF PIPES IS COMMON BECAUSE ALL PIPES MEETING THE
STRINGENT A-106 SPECIFICATION NECESSARILY MEET THE API 5L AND
ASTM A-53 SPECIFICATIONS. PIPES MEETING THE API 5L SPECIFICATION
NECESSARILY MEET THE ASTM A-53 SPECIFICATION. HOWEVER, PIPES
MEETING THE A-53 OR API 5L SPECIFICATIONS DO NOT NECESSARILY
MEET THE A-106 SPECIFICATION. TO AVOID MAINTAINING SEPARATE
PRODUCTION RUNS AND SEPARATE INVENTORIES MANUFACTURERS TRIPLE
CERTIFY THE PIPES. SINCE DISTRIBUTORS SELL THE VAST MAJORITY OF
THIS PRODUCT, THEY CAN THEREBY MAINTAIN A SINGLE INVENTORY TO
SERVICE ALL CUSTOMERS.
THE PRIMARY APPLICATION OF ASTM A-106 PRESSURE PIPES AND
TRIPLE CERTIFIED PIPES IS IN PRESSURE PIPING SYSTEMS BY
REFINERIES, PETROCHEMICAL PLANTS AND CHEMCIAL PLANTS. OTHER
APPLICATIONS ARE IN POWER GENERATION PLANTS (ELECTRICAL-FOSSIL
FUEL OR NUCLEAR), AND IN SOME OIL FIELD USES (ON SHORE AND OFF
SHORE) SUCH AS FOR SEPARATOR LINES, GATHERING LINES AND METERING
RUNS. A MINOR APPLICATION OF THIS PRODUCT IS FOR USE AS OIL AND
GAS DISTRIBUTION LINES FOR COMMERCIAL APPLICATIONS. THESE
APPLICATIONS CONSTITUTE THE MAJORITY OF THE MARKET FOR THE
SUBJECT SEAMLESS PIPES. HOWEVER, A-106 PIPES MAY BE USED IN SOME
BOILER APPLICATIONS.

THE SCOPE OF THESE INVESTIGATIONS INCLUDES ALL MULTIPLE
STENCILED SEAMLESS PIPE MEETING THE PHYSICAL PARAMETERS DESCRIBED
ABOVE AND PRODUCED TO ONE OF THE SPECIFICATIONS LISTED ABOVE,
WHETHER OR NOT ALSO CERTIFIED TO A NON-COVERED SPECIFICATION.
STANDARD, LINE AND PRESSURE APPLICATIONS ARE DEFINING
CHARACTERISTICS OF THE SCOPE OF THESE INVESTIGATIONS. THEREFORE,
SEAMLESS PIPES MEETING THE PHYSICAL DESCRIPTION ABOVE, BUT NOT
PRODUCED TO THE A-106, A-53, OR API 5L STANDARD SHALL BE COVERED
IF USED IN AN A-106, A-335, A-53 OR API 5L APPLICATION.
FOR EXAMPLE, THERE ARE CERTAIN OTHER ASTM SPECIFICATIONS OF
PIPE WHICH, BECAUSE OF OVERLAPPING CHARACTERISTICS, COULD
POTENTIALLY BE USED IN A-106 APPLICATIONS. THESE SPECIFICATIONS
INCLUDE A-162, A-192, A-210, A-333, AND A-524. WHEN SUCH PIPES
ARE USED IN A STANDARD, LINE OR PRESSURE PIPE APPLICATION, SUCH
PRODUCTS ARE COVERED BY THE SCOPE OF THESE INVESTIGATIONS.
SPECIFICALLY EXCLUDED FROM THESE INVESTIATIONS ARE BOILER
TUBING, MECHANICAL TUBING AND OIL COUNTRY TUBULAR GOODS EXCEPT
WHEN USED IN A STANDARD, LINE OR PRESSURE PIPE APPLICATION. ALSO
EXCLUDED FROM THESE INVESTIGATIONS ARE REDRAW HOLLOWS FOR
COLD-DRAWING WHEN USED IN THE PRODUCTION OF COLD-DRAWN PIPE OR
TUBE.

ALTHOUGH THE HTS SUBHEADINGS ARE PROVIDED FOR CONVENIENCE AND
CUSTOMS PURPOSES, OUR WRITTEN DESCRIPTION OF THE SCOPE OF THESE
INVESTIGATIONS IS DISPOSITIVE.

3. FOR FURTHER REPORTING PURPOSES, THESE CASES HAVE BEEN
ASSIGNED INVESTIGATION NUMBERS:
GERMANY A-428-820 BRAZIL A-351-826
ARGENTINA A-357-809 ITALY A-475-814.

4. FOR IMPORTS OF SEAMLESS PIPE FROM ARGENTINA, BRAZIL AND
GERMANY, THE CUSTOMS SERVICE SHALL SUSPEND LIQUIDATION OF SUCH
SHIPMENTS THAT ARE ENTERED OR WITHDRAWN FROM WAREHOUSE FOR
CONSUMPTION ON OR AFTER JANUARY 27, 1995. EFFECTIVE
JANUARY 27, 1995, CUSTOMS SHALL REQUIRE A CASH DEPOSIT OR
POSTING OF A BOND EQUAL TO THE MARGINS SHOWN BELOW.

THE DEPARTMENT OF COMMERCE DETERMINED THAT IMPORTS OF SEAMLESS
PIPE FROM ITALY ARE NOT BEING SOLD AT LESS THAN FAIR VALUE DUE TO
A DE MINIMIS MARGIN OF .28 PER CENT. THEREFORE, DO NOT SUSPEND
LIQUIDATION OF SUCH SHIPMENTS. NO CASH DEPOSIT OR POSTING OF A
BOND IS NECESSARY.

MANUFACTURER/PRODUCER IDENTIFICATION WEIGHTED-AVERAGE
EXPORTER NUMBER MARGIN PERCENTAGE

ARGENTINA
SIDERCA S.A.I.C. A-357-809-001 108.13%
ALL OTHERS A-357-809-000 108.13%

BRAZIL
MANNESMANN S.A. A-351-826-001 12.83%
ALL OTHERS A-351-826-000 12.83%

GERMANY
MANNESMANNROHREN WERKE AG A-428-820-001 2.68%
ALL OTHERS A-428-820-000 2.68%

DALMINE, S.p.A. A-475-814-001 0.00
ALL OTHERS A-475-814-000 0.00

5. IF THERE ARE ANY QUESTIONS REGARDING THIS MATTER BY CUSTOMS
OFFICERS, PLEASE CONTACT, VIA E-MAIL, THROUGH THE REGIONAL
ANTIDUMPING/COUNTERVAILING DUTY COORDINATOR, TRADE COMPLIANCE
DIVISION, ANTIDUMPING/COUNTERVAILING DUTY BRANCH, USING
ATTRIBUTE "HQ OAB." THE IMPORTING PUBLIC AND OTHER INTERESTED
PARTIES SHOULD CONTACT IRENE DARZENTA OR FABIAN RIVELIS, OF THE
OFFICE OF ANTIDUMPING INVESTIGATIONS, IMPORT ADMINISTRATION,
INTERNATIONAL TRADE ADMINISTRATION, U.S. DEPARTMENT OF COMMERCE
AT (202) 482-6320 OR (202) 482-3853, RESPECTIVELY.

6. THERE ARE NO RESTRICTIONS ON THE RELEASE OF THIS INFORMATION.


NANCY MCTIERNAN