MESSAGE NO: 5171112 DATE: 06 20 1995
CATEGORY: ADA TYPE: FIN
REFERENCE: REFERENCE DATE:
CASES: A - 357 - 809 A - 351 - 826
A - 428 - 820 A - 475 - 814
- - - -

PERIOD COVERED: 06 19 1995 TO

LIQ SUSPENSION DATE:

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

FROM: DIRECTOR, TECHNICAL PROGRAMS

RE: NOTICE OF FINAL DETERMINATIONS OF SMALL DIAMETER SEAMLESS
CARBON AND ALLOY STEEL STANDARD LINE & PRESSURE PIPE
(A-357-809, A-351-826, A-428-820, A-475-814)

1. ON JUNE 19, 1995, THE DEPARTMENT OF COMMERCE PUBLISHED IN
THE FEDERAL REGISTER ITS FINAL AFFIRMATIVE DETERMINATIONS OF
SALES AT LESS THAN FAIR VALUE IN THE ANTIDUMPING DUTY
INVESTIGATIONS OF SMALL DIAMETER SEAMLESS CARBON AND ALLOY STEEL
STANDARD, LINE AND PRESSURE PIPE (SEAMLESS PIPE) FROM ARGENTINA,
BRAZIL, GERMANY AND ITALY.

2. THE FOLLOWING SCOPE LANGUAGE REFLECTS CERTAIN MODIFICATIONS
MADE FOR PURPOSES OF THE FINAL DETERMINATION.

THE SCOPE OF THESE INVESTIGATIONS 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 THESE
INVESTIGATIONS ALSO INCLUDES ALL PRODUCTS USED IN STANDARD, LINE,
OR PRESSURE PIPE APPLICATIONS AND MEETING THE PHYSICAL PARAMETERS
BELOW, REGARDLESS OF SPECIFICATION.

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. 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 APPLICATIONOF 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 PIPE (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 CHEMICAL 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 INVESTIGATIONS 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 THESE
INVESTIGATIONS, 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 THE 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 HTSUS SUBHEADINGS ARE PROVIDED FOR CONVENIENCE AND
CUSTOMS PURPOSES, OUR WRITTEN DESCRIPTION OF THE SCOPE OF THESE
INVESTIGATION IS DISPOSITIVE.

3. THE DEPARTMENT 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 FINAL
DETERMINATION OF THESE INVESTIGATIONS.

4. FOR FURTHER REPORTING PURPOSES THESE CASES HAVE BEEN ASSINGED
INVESTIGATION NUMBERS:

ARGENTINA A-357-809 BRAZIL A-351-826
GERMANY A-428-820 ITALY A-475-814

5. FOR IMPORTS OF SEAMLESS PIPE FROM ARGENTINA, BRAZIL AND
GERMANY, THE CUSTOMS SERVICE SHALL CONTINUE TO SUSPEND
LIQUIDATION OF SUCH SHIPMENTS THAT ARE ENTERED OR WITHDRAWN FROM
WAREHOUSE, FOR CONSUMPTION ON OR AFTER JUNE 19,1995. FOR IMPORTS
OF SEAMLESS PIPE FROM ITALY, THE CUSTOMS SERVICE SHALL SUSPEND
LIQUIDATION OF SUCH SHIPMENTS THAT ARE ENTERED OR WITHDRAWN FROM
WAREHOUSE, FOR CONSUMPTION ON OR AFTER JUNE 19, 1995. EFFECTIVE
JUNE 19, 1995 CUSTOMS, SHALL REQUIRE FOR ENTRY SUMMARIES A CASH
DEPOSIT OR THE POSTING OF A BOND EQUAL TO THE MARGINS SHOWN
BELOW:

MANUFACTURER/PRODUCER CUSTOMS ID MARGIN PERCENTAGE
EXPORTER NUMBER

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-351-826-001 125.00%
ALL OTHERS A-351-826-000 125.00%

GERMANY
MANNESMANNROHREN-
WERKE AG A-428-820-001 58.23%
ALL OTHERS A-428-820-000 58.23%

ITALY
DALMINE S.P.A. A-475-814-001 1.84%
ALL OTHERS A-475-814-000 1.84%

6. IF THERE ARE ANY QUESTIONS REGARDING THIS MATTER BY CUSTOMS
OFFICERS, PLEASE CONTACT VIA E-MAIL THROUGH THE APPROPRIATE
SUPERVISORY CHANNELS, TECHNICAL PROGRAMS,
ANTIDUMPING/COUNTERVAILING DUTY, USING ATTRIBUTE "HQ OAB". THE
IMPORTING PUBLIC AND OTHER INTERESTED PARTIES SHOULD CONTACT
JAMES TERPSTRA OR IRENE DARZENTA, OFFICE OF ANTIDUMPING DUTY
INVESTIGATIONS, IMPORT ADMINISTRATION, INTERNATIONAL TRADE
ADMINISTRATION, U.S. DEPARTMENT OF COMMERCE, AT (202) 482-3965 OR
482-6320.

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

NANCY MCTIERNAN