MESSAGE NO: 5333111 DATE: 11 29 1994
CATEGORY: CVD TYPE: PRE
REFERENCE: REFERENCE DATE:
CASES: C - 475 - 815 - -
- - - -
- - - -

PERIOD COVERED: 11 28 1994 TO

LIQ SUSPENSION DATE:

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

FROM: DIRECTOR, TRADE COMPLIANCE DIVISION

RE: PRELIMINARY AFFIRMATIVE CVD DETERMINATION: SMALL DIAMETER
CIRCULAR SEAMLESS CARBON & ALLOY STEEL STANDARD, LINE &
PRESSURE ("SEAMLESS PIPE") FM ITALY (C-475-815)

1. THE DEPARTMENT OF COMMERCE PUBLISHED ON NOVEMBER 28, 1994 ITS
PRELIMINARY DETERMINATION OF COUNTERVAILING DUTY INVESTIGATION
REGARDING SMALL DIAMETER CIRCULAR SEAMLESS CARBON AND ALLOY STEEL
STANDARD, LINE AND PRESSURE PIPE FROM ITALY.

2. THE PRODUCTS COVERED BY THIS INVESTIGATION ARE SEAMLESS
PIPES, WHICH ARE SEAMLESS CARBON AND ALLOY (OTHER THAN STAINLESS)
STEEL PIPES, OF CIRCULAR CROSS-SECTION, NOT MORE THAN 114.3 MM
(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 THIS INVESTIGATION ARE CURRENTLY
CLASSIFIABLE UNDER SUBHEADINGS 7304.10.1020, 7304.10.5020,
7304.31.6050, 7304.39.0016, 7304.39.0020, 7304.39.0024,
7304.39.0028, 7304.39.0032, 7304.51.5005, 7304.51.5060,
7304.59.6000, 7304.59.8010, 7304.59.8015, 7304.59.8020, AND
7304.59.8025 OF THE HARMONIZED TARIFF SCHEDULE OF THE UNITED
STATES ("HTSUS").

THE FOLLOWING INFORMATION FURTHER DEFINES THE SCOPE OF THIS
INVESTIGATION, 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 SYSTMS. THEY MAY
CARRY THESE SUBSTANCES AT ELEVATED PRESSURES AND TEMPERATURES AND
MAY BE SUBJECT TO THE APPLICATION OF EXTERNAL HEAT. SEAMLESS
CARBON STEEL RESSURE PIPE MEETING THE AMERICAN SOCIETY FOR
TESTING AND MATERIALS (ASTM) STANDARD A-106 MAYBE USED IN
TEMPERATURES OF UP TO 1000 DEGREES FAHRENHEIT, AT VARIOUS
AMERICAN SOCIELY OF ENGINEERS (ASME) CODE STRESS LEVELS. ALLOY
PIPES MADE TO ASTM STANTARD 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-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
CERTIFICATIONS OF PIPES IS COMMON BECAUSE ALL PIPES MEETING THE
STRINGENT A-106 SPECIFICATION NECESSARILY MEET THE API 5L
SPECIFICATION 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 PRODUCTIONS 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 CHEMICAL PLANTS. OTHER APPLICATIONS
ARE IN POWER GENERATION PLANTS (ELECTRICAL-FOSSIL FUEL OR
NUCLEAR), AND IN SOME OIL FIEL USES (ON SHORE AND OFF SHORE) SUCH
AS FOR SEPERATOR LINES, GATHERING LINES, AND METERING RUNS. A
MINOR APPLICATION OF THIS PRODUCT IS FOR USE AS OIL AND GAS
DISTRIBUTION LINE 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 THIS INVESTIGATION 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 TH
SCOPE OF THIS INVESTIGATION. THEREFORE, SEAMLESS PIPES MEETING
THE PHYSICAL DESCRIPTION ABOVE, BUT NOT PRODUCED TO THE A-106,
A-53, OR API 5L STANDARDS 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 CHARACTERISTCS, 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 THIS INVESTIGATION.

SPECIFICALLY EXCLUDED FROM THIS INVESTIGATION ARE BOILER TUBING,
MECHANICAL TUBING, AND OIL COUNTRY TUBULAR GOODS EXCEPT WHEN USED
IN A STANDARD, LINE OR PRESSURE PIPE.APPLICATION. ALSO EXCLUDED
FROM THIS INVESTIGATION ARE REDRAW HOLLOWS FOR COLD-DRAWING WHEN
USED IN THE PRODUCTION OF COLD-DRAWN PIPE OR TUBE.

ALTHOUGH THE HTSUS SUBHEADINGS ARE PROVIDED FOR CONVENIENCE AND
CUSTOMS PURPOSES, OUR WRITTEN DESCRIPTION OF THE SCOPE OF THIS
INVESTIGATION IS DISPOSITIVE.

3. FOR FURTHER REPORTING PURPOSES, THIS CASE HAS BEEN ASSIGNED
THE FOLLOWING CASE NUMBER C475-815.

4. THE U.S. CUSTOMS SERVICE SHALL SUSPEND LIQUIDATION OF ALL
ENTRY SUMMARIES OF SMALL DIAMETER CIRCULAR SEAMLESS CARBON AND
ALLOY STEEL STANDARD, LINE AND PRESSURE PIPE ("SEAMLESS PIPE")
FROM ITALY WHICH ARE ENTERED OR WITHDRAWN FROM WAREHOUSE, FOR
CONSUMPTION ON OR AFTER NOVEMBER 28, 1994. EFFECTIVE NOVEMBER
28, 1994, CUSTOMS SHALL REQUIRE A CASH DEPOSIT OR BOND FOR SUCH
ENTRY SUMMARIES OF THE MERCHANDISE AS FOLLOWS:




MANUFACTURERS/PRODUCERS/ CUSTOMS ID MARGIN/
EXPORTERS NUMBER PERCENT

COUNTRY WIDE C-475-815-000 1.42%


5. IF THERE ARE ANY QUESTIONS REGARDING THIS MATTER BY CUSTOMS
OFFICERS, PLEASE CONTACT VIA E-MAIL, THROUGH THE REGIONAL AD/CVD
COORDINATOR, TRADE COMPLIANCE DIVISION, AD/CVD BRANCH USING
ATTRIBUTE "HQ OAB". THE IMPORTING PUBLIC AND OTHER INTERESTED
PARTIES SHOULD CONTACT THOMAS MCGINTY OR PETER WILKNISS, OFFICE
OF COUNTERVAILING INVESTIGATIONS, IMPORT ADMINISTRATION,
INTERNATIONAL TRADE ADMINISTRATION, U.S. DEPARTMENT OF COMMERCE,
TELEPHONE (202) 482-5055 AND (202) 482-0588 RESPECTIVELY.

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





NANCY MCTIERNAN