[Federal Register Volume 62, Number 91 (Monday, May 12, 1997)]
[Notices]
[Pages 25904-25908]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 97-12395]
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DEPARTMENT OF COMMERCE
International Trade Administration
[A-583-826]
Notice of Preliminary Determination of Sales at Less Than Fair
Value and Postponement of Final Determination: Collated Roofing Nails
From Taiwan
AGENCY: Import Administration, International Trade Administration,
Department of Commerce.
EFFECTIVE DATE: May 12, 1997.
FOR FURTHER INFORMATION CONTACT: Everett Kelly or Ellen Grebasch,
Import Administration, International Trade Administration, U.S.
Department of Commerce, 14th Street and Constitution Avenue, N.W.,
Washington, D.C. 20230; telephone: (202) 482-4194 or (202) 482-3773,
respectively.
The Applicable Statute
Unless otherwise indicated, all citations to the Tariff Act of
1930, as amended (the Act), are references to the provisions effective
January 1, 1995, the effective date of the amendments made to the Act
by the Uruguay Round Agreements Act (URAA). In addition, unless
otherwise indicated, all citations to the Department's regulations are
to the current regulations, as amended by the interim regulations
published in the Federal Register on May 11, 1995 (60 FR 25130).
Preliminary Determination
We preliminarily determine that collated roofing nails (``CRN'')
from Taiwan are being, or are likely to be, sold in the United States
at less than fair value (``LTFV''), as provided in section 733 of the
Act. The estimated margins of sales at LTFV are shown in the
``Suspension of Liquidation'' section of this notice.
Case History
Since the initiation of this investigation (Notice of Initiation of
Antidumping Duty Investigations: Collated Roofing Nails from the
People's Republic of China, the Republic of Korea, and Taiwan (61 FR
67306, December 20, 1996), the following events have occurred:
On January 17, 1997, the United States International Trade
Commission (``ITC'') issued an affirmative preliminary injury
determination in this case (see ITC Investigation Nos. 731-TA-757-759).
During November 1996 through January 1997, the Department obtained
information from various sources identifying producers/exporters of the
subject merchandise. (See Memorandum to the File, dated May 5, 1997,
for a detailed explanation of the Department's search for producers/
exporters of the subject merchandise.) During January and February,
based on this information, the Department issued antidumping
questionnaires to Unicatch Industrial Co. Ltd. (``Unicatch''), K. Ticho
Industries Co., Ltd. (``K. Ticho''), Hao Chun B&M Corporation (``Hao
Chun''), Lei Chu Enterprise Co., Ltd. (``Lei Chu''), Forrader Union
Company (``Forrader''), Double Dragon Ent. Co. Ltd. (``Dragon''), S&J
Wire Products Company, Ltd. (``S&J''), Certified Products Inc.
(``Certified''), Sun Jade Handicraft Ltd. (``Sun Jade''), Master United
Corporation (``United''), Trim International Incorporated (``Trim''),
and Romp Coil Nail Industries (``Romp''). The questionnaire is divided
into four sections: Section A requests general information concerning a
company's corporate structure and business practices, the merchandise
under investigation that it sells, and the sales of the merchandise in
all of its markets. Sections B and C request home market sales listings
and U.S. sales listings, respectively. Section D requests information
on the cost of production (``COP'') of the foreign like product and
constructed value (``CV'') of the subject merchandise.
The Department received responses to Section A of the questionnaire
during February and March, 1997. K. Ticho did not respond to the
Department's questionnaire. (See the ``Fair Value Comparisons'' section
below, for further discussion).
On March 13, 1997, pursuant to section 777A(c) of the Act, the
Department determined that, due to the large number of exporters/
producers of the subject merchandise, it would limit the number of
mandatory respondents in this investigation. The Department determined
that the resources available to it for this investigation and the two
companion investigations limited our ability to analyze any more than
the responses of the four largest exporters/producers of the subject
merchandise in this investigation. Based on Section A questionnaire
responses, the Department determined that the four largest companies,
and therefore the mandatory respondents in this proceeding, were:
Unicatch, Lei Chu, Romp, and S&J. (For detailed information regarding
this issue, see memorandum to Lou Apple from the CRN team, dated March
13, 1997.)
Unicatch, Lei Chu, Romp, and S&J submitted questionnaire responses
in February and March 1997. We issued supplemental requests for
information in March and April 1997, and received supplemental
responses to these requests in April 1997.
On April 14, 16, 23, and 25, 1997, the Paslode Division of Illinois
Tool Works Inc. (``Petitioner'') filed comments on the Unicatch, Lei
Chu, Romp, and S&J questionnaire responses.
Postponement of Final Determination and Extension of Provisional
Measures
On April 22, 1997, Respondents Unicatch and Lei Chu requested that,
pursuant to section 735(a)(2)(A) of the Act, in the event of an
affirmative preliminary determination in this investigation, the
Department postpone its final determination until not later than 135
days after the date of publication of the affirmative preliminary
determination in the Federal Register. In accordance with section
735(a)(2)(A) of the Act and 19 CFR 353.20(b), inasmuch as our
preliminary determination is affirmative, Unicatch and Lei Chu account
for a significant proportion of exports of the subject merchandise
under investigation, and we are not aware of the existence of any
compelling reasons for denying the request, we are granting the
respondents' request and postponing the final determination. Suspension
of liquidation will be extended
[[Page 25905]]
accordingly. See Preliminary Determination of Sales at Less Than Fair
Value: Large Newspaper Printing Presses and Components Thereof, Whether
Assembled or Unassembled, from Japan (61 FR 8029, March 1, 1996).
Scope of Investigation
The product covered by this investigation is CR nails made of
steel, having a length of \13/16\ to 1-\13/16\ inches (or 20.64 to
46.04 millimeters), a head diameter of 0.330 inch to 0.415 inch (or
8.38 to 10.54 millimeters), and a shank diameter of 0.100 inch to 0.125
inch (or 2.54 to 3.18 millimeters), whether or not galvanized, that are
collated with two wires.
CR nails within the scope of this investigation are classifiable
under the Harmonized Tariff Schedule of the United States (``HTSUS'')
subheading 7317.00.55.05. Although the HTSUS subheading is provided for
convenience and customs purposes, our written description of the scope
of this investigation is dispositive.
Period of Investigation
The period of this investigation (``POI'') comprises each
exporter's four most recent fiscal quarters prior to the filing of the
petition. In this case, the POI for all companies is October 1, 1995
through September 30, 1996.
Fair Value Comparisons
A. K. Ticho
As discussed above, K. Ticho did not respond to the Department's
questionnaire. Section 776(a)(2) of the Act provides that if an
interested party withholds information that has been requested by the
Department, fails to provide such information in a timely manner and in
the form requested, significantly impedes a proceeding, or provides
such information but the information cannot be verified, the Department
shall use the facts otherwise available in reaching the applicable
determination. Because K. Ticho failed to submit the information that
the Department specifically requested, we must base our determination
for K. Ticho on the facts available.
Section 776(b) of the Act provides that adverse inferences may be
used against a party that has failed to cooperate by not acting to the
best of its ability to comply with a request for information. K.
Ticho's decision not to participate in the Department's investigation
demonstrates that K. Ticho has failed to act to the best of its ability
in this investigation. Thus, the Department has determined that, in
selecting from among the facts otherwise available, an adverse
inference is warranted. As adverse facts available, we are assigning to
K.Ticho the higher of the petition margin or margin calculated for any
respondent in this investigation. Because the margins in the petition
(as recalculated by the Department at initiation) were higher than any
of the calculated margins, we used the highest margin stated in the
Notice of Initiation, 40.28%, as total adverse facts available for K.
Ticho.
Section 776(c) of the Act provides that where the Department
selects from among the facts otherwise available and relies on
``secondary information,'' such as the petition, the Department shall,
to the extent practicable, corroborate that information from
independent sources reasonably at the Department's disposal. The
Statement of Administrative Action accompanying the URAA, H.R. Doc. No.
316, 103d Cong., 2d Sess. (1994) (hereinafter, the ``SAA''), states
that ``corroborate'' means to determine that the information used has
probative value. See SAA at 870.
In the petition, the petitioner based its allegation of export
price on price quotes from two manufacturer/exporters of CRN in Taiwan.
These price quotations were adjusted for movement expenses using
customs data and IM-145 Import Statistics. See Notice of Initiation, 61
FR at 67307-08. As stated in Final Determination of Sales at Less Than
Fair Value: Certain Pasta From Turkey, 61 FR 30309 (June 14, 1996), we
consider price quotations as information from independent sources. The
export price calculations were based upon independent sources and
Import Statistics, both sources which we consider to require no further
corroboration by the Department. Therefore, we determined at
initiation, and continue to find, that the calculations set forth in
the petition have probative value.
The petitioner based Normal Value (``NV'') on CV. See Notice of
Initiation, 61 FR at 67308. To calculate CV, the petitioner used
manufacturing costs based on its own production experience, its 1995
audited financial statements, and publicly available industry data. Id.
The CV calculations in the petition are consistent with the CVs
reported by the respondents on the record of this investigation. As
such, we determine that the NV calculations have probative value. (See
memorandum, dated May 5, 1997.)
Based on our pre-initiation analysis and reexamination of the price
information supporting the petition, we determine that the highest
margin stated in the Notice of Initiation is corroborated within the
meaning of section 776(c) of the Act.
B. Unicatch, Lei Chu, S&J, and Romp
To determine whether sales of the subject merchandise by Unicatch,
Lei Chu, S&J, and Romp to the United States were made at less than fair
value, we compared the Export Price (``EP'') or Constructed Export
Price (``CEP'') to the NV, as described in the EP, CEP, and ``Normal
Value'' sections of this notice, below. In accordance with section
777A(d)(1)(A)(i) of the Act, we compared POI-wide weighted-average EPs
or CEPs to weighted-average NVs.
In making our comparisons, in accordance with section 771(16) of
the Act, we considered all products sold in the home market, fitting
the description specified in the ``Scope of Investigation'' section of
this notice, above, to be foreign like products for purposes of
determining appropriate product comparisons to U.S. sales. Unicatch,
Lei Chu, S&J, and Romp reported that they had no viable home market or
third country sales during the POI. We therefore made no price-to-price
comparisons. See the ``Normal Value'' section of this notice, below,
for further discussion.
Level of Trade and CEP Offset
As set forth in section 773(a)(1)(B)(i) of the Act and in the SAA
at 829-331, to the extent practicable, the Department will calculate NV
based on sales at the same level of trade as the U.S. sales. When the
Department is unable to find sales in the comparison market at the same
level of trade as the U.S. sale(s), the Department may compare sales in
the U.S. and foreign markets at different levels of trade. Section
773(a)(7)(A) provides that if we compare a U.S. sale with a home market
sale made at a different level of trade, when appropriate, we will
adjust NV to account for this difference. When NV is based on CV, the
level of trade is that of the sales from which we derive selling,
general and administrative (``SG&A'') expenses and profit.
For comparisons to CEP sales, section 773(a)(7)(B) establishes the
procedure for making a CEP offset when two conditions are met. First,
the NV is established at a level of trade which constitutes a more
advanced stage of distribution than the level of trade of the CEP, and
second, the data available do not establish an appropriate basis for
calculating a level of trade adjustment.
We have not applied a level of trade adjustment or CEP offset for
any respondent in this investigation because none of the respondents
claimed a level of trade adjustment and we are unable
[[Page 25906]]
to determine whether the NVs for each respondent are calculated at
different levels of trade than their U.S. sales. As explained below in
the ``Normal Value'' section of this notice, we calculated NV for each
respondent based entirely on CV. We derived SG&A and profit from data
contained in each respondents' financial statements. This data does not
permit an appropriate level of trade analysis because we are unable to
isolate the particular selling expenses associated with the selling
functions for each respondents' NV. Therefore, we find insufficient
evidence on the record to justify a level of trade adjustment or CEP
offset.
Export Price/Constructed Export Price
Unicatch
We used EP in accordance with section 772(a) of the Act where the
subject merchandise was sold to unaffiliated customers prior to
importation and the CEP methodology was not indicated by the facts of
record. We used CEP in accordance with section 772(b) of the Act where
the subject merchandise was sold to unaffiliated customers after
importation. We calculated EP/CEP, as appropriate, based on packed
prices, either FOB Taiwan, C&F USA, CIF USA, Free on Road (``FOR'')
Taiwan, or FOB U.S. affiliate's warehouse to the first unaffiliated
purchaser in the United States. For both EP and CEP sales we made
deductions from the starting price (gross unit price) for discounts,
inland freight from the plant/warehouse to port of exit, Taiwan
brokerage and handling, international freight, marine insurance, U.S.
inland freight from port to the warehouse, and U.S. customs duties,
where appropriate. We also adjusted the starting price and quantity for
returns. We added to both EP and CEP reported duty drawback amounts.
For Unicatch's CEP sales, we made additional deductions, in
accordance with section 772(d) (1) and (2) of the Act, for commissions,
credit expenses, indirect selling expenses, and inventory carrying
costs. Pursuant to section 772(d)(3) of the Act, the price was further
reduced by an amount for profit, to arrive at the CEP. In accordance
with section 773(f) of the Act, the CEP profit rate was calculated
using the expenses incurred by Unicatch and its affiliates on their
sales of the subject merchandise in the United States and the profit
associated with those sales. Because Unicatch had no home market sales,
we did not include any home market expenses in the CEP profit rate
calculation.
Lei Chu
We used EP in accordance with section 772(a) of the Act because the
subject merchandise was sold to unaffiliated customers before
importation and the CEP methodology was not indicated by the facts of
record. We calculated EP based on packed prices, either FOB, CNF USA,
or CIF USA to the first unaffiliated purchaser in the United States.
Where appropriate, we made deductions from the starting price (gross
unit price) for inland freight from the plant/warehouse to port of
exit, brokerage and handling in Taiwan, international freight, marine
insurance, and bank charges. We added to EP reported duty drawback
amounts.
S&J
We used EP in accordance with section 772(a) of the Act because the
subject merchandise was sold to unaffiliated customers before
importation and the CEP methodology was not indicated by the facts of
record. We calculated EP based on packed prices, either FOB, CNF, or
CIF to the first unaffiliated purchaser in the United States. Where
appropriate, we made deductions from the starting price (gross unit
price) for inland freight from the plant/warehouse to port of exit,
brokerage and handling in Taiwan, international freight, marine
insurance and direct selling expenses.
Romp
We used EP in accordance with section 772(a) of the Act because the
subject merchandise was sold to unaffiliated customers before
importation and the CEP methodology was not indicated by the facts of
record. We calculated EP based on packed prices, FOB to the first
unaffiliated purchaser in the United States. Where appropriate, we made
deductions from the starting price (gross unit price) for inland
freight from the plant/warehouse to port of exit, and brokerage and
handling in Taiwan. We added to EP reported duty drawback amounts.
Normal Value
In order to determine whether there is a sufficient volume of sales
in the home market to serve as a viable basis for calculating NV (i.e.,
the aggregate volume of home market sales of the foreign like product
is greater than five percent of the aggregate volume of U.S. sales), we
compare each respondent's volume of home market sales of the foreign
like product to the volume of U.S. sales of the subject merchandise, in
accordance with section 773(a)(1)(C) of the Act. Unicatch, Lei Chu,
S&J, and Romp reported that they had no home market sales during the
POI. Therefore, we have determined that none of the respondents have a
viable home market. Because Unicatch, Lei Chu, S&J, and Romp also
reported that they had no third country sales during the POI, we based
normal value on CV in accordance with section 773(a)(4) of the Act.
Calculation of CV
In accordance with section 773(e)(1) of the Act, we calculated CV
based on the sum of a respondent's cost of materials, fabrication,
SG&A, profit and U.S. packing costs as reported in the U.S. sales
databases. In this case, none of the respondents had home market
selling expenses or home market profit upon which to base CV.
Section 773(e)(2)(B) of the Act sets forth three alternatives for
computing profit and SG&A without establishing a hierarchy or
preference among the alternative methods. We did not have the necessary
cost data for methods one (calculating SG&A and profit incurred by the
producer on the home market sales of merchandise of the same general
category as the exports in question), or two (averaging SG&A and profit
of other investigated producers of the foreign like product). The third
alternative (section 773(e)(2)(B)(iii) of the Act) provides that profit
and SG&A may be computed by any other reasonable method, capped by the
amount of profit normally realized on sales in the home market of the
same general category of products. The SAA states that, if the
Department does not have the data to determine amounts for profit under
alternatives one and two or a profit cap under alternative three, it
may apply alternative three (without determining the cap) on the basis
of ``the facts available.'' SAA at 841. Therefore, as the facts
available, we are using each respondent's overall profit and SG&A rate
associated with its total sales as recorded in its most recent
financial statement. Because the figures recorded in the financial
statements are company-specific and contemporaneous with the POI, we
preliminarily determine this data to be a reasonable surrogate for SG&A
and profit of the subject merchandise. However, we will consider the
issue of appropriate SG&A and profit information further for the final
determination and invite comment on this issue.
Price to CV Comparisons
Because we based SG&A for CV on the financial statements of each
individual company, where we compared CV to EP, we did not make any
circumstance of sale adjustments for direct expenses and
[[Page 25907]]
commissions as we were unable to split out from total SG&A these
expenses.
Currency Conversion
We made currency conversions into U.S. dollars based on the
official exchange rates in effect on the dates of the U.S. sales as
certified by the Federal Reserve Bank.
Section 773A(a) of the Act directs the Department to convert
foreign currencies based on the dollar exchange rate in effect on the
date of sale of the subject merchandise, except if it is established
that a currency transaction on forward markets is directly linked to an
export sale. When a company demonstrates that a sale on forward markets
is directly linked to a particular export sale in order to minimize its
exposure to exchange rate losses, the Department will use the rate of
exchange in the forward currency sale agreement.
Section 773A(a) also directs the Department to use a daily exchange
rate in order to convert foreign currencies into U.S. dollars unless
the daily rate involves a fluctuation. It is the Department's practice
to find that a fluctuation exists when the daily exchange rate differs
from the benchmark rate by 2.25 percent. The benchmark is defined as
the moving average of rates for the past 40 business days. When we
determine a fluctuation to have existed, we substitute the benchmark
rate for the daily rate, in accordance with established practice.
Further, section 773A(b) directs the Department to allow a 60-day
adjustment period when a currency has undergone a sustained movement. A
sustained movement has occurred when the weekly average of actual daily
rates exceeds the weekly average of benchmark rates by more than five
percent for eight consecutive weeks. (For an explanation of this
method, Policy Bulletin 96-1: Currency Conversions (61 FR 9434, March
8, 1996)). Such an adjustment period is required only when a foreign
currency is appreciating against the U.S. dollar. The use of an
adjustment period was not warranted in this case because the New Taiwan
dollar did not undergo a sustained movement.
Critical Circumstances
The petition contained a timely allegation that there is a
reasonable basis to believe or suspect that critical circumstances
exist with respect to imports of subject merchandise. Section 733(e)(1)
of the Act provides that the Department will determine that there is a
reasonable basis to believe or suspect that critical circumstances
exist if: (A)(i) there is a history of dumping and material injury by
reason of dumped imports in the United States or elsewhere of the
subject merchandise, or (ii) the person by whom, or for whose account,
the merchandise was imported knows or should have known that the
exporter was selling the subject merchandise at less than its fair
value and that there was likely to be material injury by reason of such
sales, and (B) there have been massive imports of the subject
merchandise over a relatively short period.
To determine that there is a history of dumping of the subject
merchandise, the Department normally considers evidence of an existing
antidumping duty order on CRN in the United States or elsewhere to be
sufficient. See e.g., Preliminary Determinations of Critical
Circumstances: Brake Drums and Rotors from the People's Republic of
China, 61 FR 55269 (Oct. 25, 1996); Notice of Final Determinations of
Sales at Less Than Fair Value: Brake Drums and Rotors from the People's
Republic of China, 62 FR 9160 (Feb. 28, 1997). Currently, no countries
have outstanding antidumping duty orders on CRN from Taiwan. The
petitioner alleged a history of dumping based upon antidumping orders
on steel wire nails from Korea and the People's Republic of China, both
of which covered CRN. See Certain Steel Wire Nails From Korea; Final
Results of Changed Circumstances Administrative Review and Revocation
of Antidumping Duty Order, 50 FR 40045 (Oct. 1, 1985); Final Results of
Changed Circumstances Administrative Review and Revocation of
Antidumping Duty Order; Certain Steel Wire Nails from The People's
Republic of China, 52 FR 33463 (Sept. 3, 1987). We preliminarily
determine that these antidumping orders are not a sufficient basis to
find a history of dumping because both orders were revoked several
years ago. However, we will consider this issue further for the final
determination and we invite interested parties to comment on the issue.
In determining whether an importer knew or should have known that
the exporter was selling subject merchandise at less than fair value
and thereby causing material injury, the Department normally considers
margins over 15% for EP sales and 25% for CEP sales to impute knowledge
of dumping and of resultant material injury. Brake Drums and Rotors, 62
FR at 9164-65. In this investigation, none of the exporters/
manufacturers has a margin over 15% for EP sales or 25% for CEP sales.
Based on these facts, we determine that the first criterion for
ascertaining whether or not critical circumstances exist is not
satisfied. Therefore, we have not analyzed the shipment data for any of
these companies to examine whether imports of CRN have been massive
over a relatively short period. Thus, because neither alternative of
the first criterion has been met, we preliminarily determine that there
is no reasonable basis to believe or suspect that critical
circumstances exist with respect to exports of CRN from Taiwan by
Unicatch, Lei Chu, Romp, and S&J.
Regarding all other exporters, because we do not find that critical
circumstances exist for any of the investigated companies, we also
determine that critical circumstances do not exist for companies
covered by the ``All Others'' rate.
We will make a final determination concerning critical
circumstances when we make our final determination in this
investigation, if the final determination is affirmative.
Verification
As provided in section 782(i) of the Act, we will verify all
information determined to be acceptable for use in making our final
determination.
Suspension of Liquidation
In accordance with section 733(d) of the Act, we are directing the
Customs Service to suspend liquidation of all imports of subject
merchandise--except those exported by Unicatch or Lei Chu--that are
entered, or withdrawn from warehouse, for consumption on or after the
date of publication of this notice in the Federal Register. We will
instruct the Customs Service to require a cash deposit or the posting
of a bond equal to the weighted-average amount by which the NV exceeds
the export price, as indicated in the chart below. These suspension of
liquidation instructions will remain in effect until further notice.
The weighted-average dumping margins are as follows:
------------------------------------------------------------------------
Weighted-
average
Exporter/manufacturer margin
percentage
------------------------------------------------------------------------
Unicatch.................................................... 0
Lei Chu..................................................... 4.38
Romp........................................................ 6.09
S&J......................................................... 6.21
K. Ticho.................................................... 40.28
All Others.................................................. 5.39
------------------------------------------------------------------------
Pursuant to section 735(c)(5)(A) of the Act, the Department has
excluded zero margins and the margin determined entirely under section
776 of the Act from the calculation of the ``All Others Rate.''
[[Page 25908]]
ITC Notification
In accordance with section 733(f) of the Act, we have notified the
ITC of our determination. If our final determination is affirmative,
the ITC will determine before the later of 120 days after the date of
this preliminary determination or 45 days after our final determination
whether these imports are materially injuring, or threaten material
injury to, the U.S. industry.
Public Comment
Case briefs or other written comments in at least ten copies must
be submitted to the Assistant Secretary for Import Administration no
later than July 30, 1997, and rebuttal briefs, no later than August 6,
1997. A list of authorities used and an executive summary of issues
should accompany any briefs submitted to the Department. Such summary
should be limited to five pages total, including footnotes. In
accordance with section 774 of the Act, we will hold a public hearing,
if requested, to afford interested parties an opportunity to comment on
arguments raised in case or rebuttal briefs. Tentatively, the hearing
will be held on August 7th, at 9:00 a.m. in Room 1412 at the U.S.
Department of Commerce, 14th Street and Constitution Avenue, N.W.,
Washington, D.C. 20230. Parties should confirm by telephone the time,
date, and place of the hearing 48 hours before the scheduled time.
Interested parties who wish to request a hearing, or to participate
if one is requested, must submit a written request to the Assistant
Secretary for Import Administration, U.S. Department of Commerce, Room
1870, within ten days of the publication of this notice. Requests
should contain: (1) The party's name, address, and telephone number;
(2) the number of participants; and (3) a list of the issues to be
discussed. Oral presentations will be limited to issues raised in the
briefs. If this investigation proceeds normally, we will make our final
determination by 135 days after the publication of this notice in the
Federal Register.
This determination is published pursuant to section 733(d) of the
Act.
Dated: May 5, 1997.
Robert S. LaRussa,
Acting Assistant Secretary for Import Administration.
[FR Doc. 97-12395 Filed 5-9-97; 8:45 am]
BILLING CODE 3510-DS-P