MESSAGE NO: 4201111 DATE: 07 20 1994
CATEGORY: ADA TYPE: INI
REFERENCE: REFERENCE DATE:
CASES: A - 475 - 814 A - 428 - 820
A - 351 - 826 A - 357 - 809
- - - -

PERIOD COVERED: 07 20 1994 TO

LIQ SUSPENSION DATE:

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

FROM: DIRECTOR, TRADE COMPLIANCE DIVISION

RE: INITIATION ON SMALL DIAMETER CIRCULAR SEAMLESS CARBON &
ALLOY STEEL STANDARD LINE & PRESSURE PIPE FM
ARGENTIA, BRAZIL, GERMANY, AND ITALY

1. THE DEPARTMENT OF COMMERCE WILL PUBLISH IN THE FEDERAL
REGISTER ON JULY 20, 1994 IT'S INITIATION OF ANTIDUMPING DUTY
INVESTIGATIONS OF SMALL DIAMETER CIRCULAR SEAMLESS CARBON AND
ALLOY STEEL STANDARD, LINE AND PRESSURE PIPE (SEAMLESS PIPES)
FROM ARGENTINA, BRAZIL, GERMANY AND 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 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 ON 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 CUSTOMS.
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. TO THE EXTENT
THAT 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 IF 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: ITALY (A-475-814, GERMANY
A-428-820, BRAZIL A-351-826, AND ARGENTINA A-357-809.

4. 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 KIMBERLY HARDIN, OFFICE OF ANTIDUMPING
INVESTIGATIONS, IMPORT ADMINISTRATION, INTERNATIONAL TRADE
ADMINISTRATION, U.S. DEPARTMENT OF COMMERCE AT (202) 482-0371.

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


NANCY MCTIERNAN