MESSAGE NO: 5216111 DATE: 08 03 1995
CATEGORY: ADA TYPE: ORD
REFERENCE: REFERENCE DATE:
CASES: A - 357 - 809 A - 351 - 826
A - 428 - 820 A - 475 - 814
- - - -

PERIOD COVERED: 08 03 1995 TO

LIQ SUSPENSION DATE:

TO: DIRECTORS OF FIELD OPERATIONS
PORT DIRECTORS

FROM: DIRECTOR, SPECIAL ENFORCEMENT

RE: ANTIDUMPING DUTY ORDER & AMENED FINAL DETERMINATION ON
CERTAIN SMALL DIAMETER SEAMLESS CARBON & ALLOY STEEL,
STANDARD, LINE & PRESSURE PIPE

1. ON AUGUST 3, 1995, THE DEPARTMENT OF COMMERCE WILL PUBLISH
IN THE FEDERAL REGISTER ITS ANTIDUMPING DUTY ORDERS AND AMENDED
FINAL DETERMINATIONS, IN THE INVESTIGATIONS OF SMALL DIAMETER
CIRCULAR SEAMLESS CARBON AND ALLOY STEEL STANDARD, LINE AND
PRESSURE PIPE (SEAMLESS PIPE) FROM ARGENTINA, BRAZIL, GERMANY,
AND ITALY.

2. THE SCOPE OF THIS INVESTIGATION INCLUDES SEAMLESS PIPES
PRODUCED TO THE ASTM A-335, ASTM A-106, ASTM A-53 AND API 5L
SPECIFICATIONS AND MEETING THE PHYSICAL PARAMETERS DESCRIBED
BELOW, REGARDLESS OF APPLICATION. THE SCOPE OF THIS
INVESTIGATION ALSO INCLUDES ALL PRODUCTS USED IN STANDARD,
LINE,OR PRESSURE PIPE APPLICATIONS AND MEETING THE PHYSICAL
PARAMETERS BELOW, REGARDLESS OF SPECIFICATION.

FOR PURPOSES OF THIS INVESTIGATION, 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.
PIPES PRODUCED IN NON-STANDARD WALL THICKNESSES ARE COMMONLY
REFERRED TO AS TUBES.

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 PIPES 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 SEAMLESS PIPE
MEETING THE PHYSICAL PARAMETERS DESCRIBED ABOVE AND PRODUCED TO
ONE OF THE SPECIFICATIONS LISTED ABOVE, REGARDLESS OF
APPLICATION, AND WHETHER OR NOT ALSO CERTIFIED TO A NON-COVERED
SPECIFICATION. STANDARD, LINE AND PRESSURE APPLICATIONS AND
THE ABOVE-LISTED SPECIFICATIONS ARE DEFINING CHARACTERISTICS OF
THE SCOPE OF THESE INVESTIGATIONS. THEREFORE, SEAMLESS PIPES
MEETING THE PHYSICAL DESCRIPTION ABOVE, BUT NOT PRODUCED TO THE
A-335, A-106, A-53, OR API 5L STANDARDS SHALL BE COVERED IF
USED IN A STANDARD, LINE OR PRESSURE 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 GENERALLY 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 AND MECHANICAL TUBING, IF SUCH PRODUCTS ARE NOT PRODUCED
TO A-335, A-106, A-53 OR API 5L SPECIFICATIONS AND ARE NOT USED
IN STANDARD, LINE OR PRESSURE APPLICATIONS. IN ADDITION,
FINISHED AND UNFINISHED OCTG ARE EXCLUDED FROM THE SCOPE OF
THIS INVESTIGATION, IF COVERED BY THE SCOPE OF ANOTHER
ANTIDUMPING DUTY ORDER FROM THE SAME COUNTRY. IF NOT COVERED
BY SUCH AN OCTG ORDER, FINISHED AND UNFINISHED OCTG ARE
INCLUDED IN THIS SCOPE WHEN USED IN STANDARD, LINE OR PRESSURE
APPLICATIONS. FINALLY, 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. THE DEPARTMENT OF COMMERCE INCLUDES END-USE AS A CRITERION
IN THE SCOPE OF THESE INVESTIGATIONS. AT THIS TIME, THE
DEPARTMENT HAS NO EVIDENCE INDICATING THAT BOILER TUBING,
MECHANICAL TUBING OR OIL COUNTRY TUBULAR GOODS, NOT ALSO
CERTIFIED TO ASTM-A-53, ASTM-A-106, ASTM-A-335, OR API-5L
SPECIFICATIONS, ARE BEING IMPORTED FOR USE IN STANDARD, LINE OR
PRESSURE PIPE APPLICATIONS. THEREFORE, UNTIL FURTHER NOTICE,
THE CUSTOMS SERVICE SHALL NOT SUSPEND LIQUIDATION ON THESE
PRODUCTS PURSUANT TO THE ANTIDUMPING ORDERS OF THESE
INVESTIGATIONS.

4. 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.

5. FOR IMPORTS OF SEAMLESS PIPE FROM ARGENTINA, BRAZIL,
GERMANY, AND ITALY, THE CUSTOMS SERVICE SHALL CONTINUE TO
SUSPEND LIQUIDATION OF SUCH SHIPMENTS THAT ARE ENTERED OR
WITHDRAWN FROM WAREHOUSE FOR CONSUMPTION ON OR AFTER JANUARY
27, 1995. EFFECTIVE AUGUST 3, 1995, CUSTOMS SHALL REQUIRE A
CASH DEPOSIT EQUAL TO THE MARGINS SHOWN BELOW.

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-351-826-001 124.94
ALL OTHERS A-351-826-000 124.94


GERMANY MANNESMANNROHREN-WERKE AG A-428-820-001 57.72
ALL OTHERS A-428-820-000 57.72


ITALY DALMINE, S.p.A. A-475-814-001 1.84
ALL OTHERS A-475-814-000 1.84


5. IF THERE ARE ANY QUESTIONS REGARDING THIS MATTER BY CUSTOMS
OFFICERS, PLEASE CONTACT, VIA E-MAIL, THROUGH THE APPROPRIAATE
SUPERVISORY CHANNELS, TECHNICAL PROGRAMS, ANTIDUMPING/

COUNTERVAILING DUTY, USING TO ATTRIBUTE "HQ OAB."
THE IMPORTING PUBLIC AND OTHER INTERESTED PARTIES SHOULD
CONTACT IRENE DARZENTA OR JAMES TERPSTRA, OF THE OFFICE OF
ANTIDUMPING INVESTIGATIONS, IMPORT ADMINISTRATION,
INTERNATIONAL TRADE ADMINISTRATION, U.S. DEPARTMENT OF COMMERCE
AT (202) 482-6320 OR (202) 482-3965, RESPECTIVELY.

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


NANCY MCTIERNAN


NOTE: THIS MESSAGE WAS INADVERTENTLY REMOVED FROM ADIL SO HAS
BEEN REPOSTED TO ADIL ON NOVEMBER 23, 2009. THE ORIGINAL
MESSAGE WAS SENT TO REGIONAL DIRECTORS, COMMERCIAL OPERATIONS,
DISTRICT DIRECTORS, AREA AND PORT DIRECTORS, NOT DIRECTORS,
FIELD OPERATIONS AND PORT DIRECTORS. DIRECTOR, TECHNICAL
PROGRAMS IS NOW SHOWN AS DIRECTOR, SPECIAL ENFORCEMENT. THE
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MATCHES THE MESSAGE THAT STILL APPEARS ON THE ADD/CVD SEARCH
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