[Federal Register Volume 67, Number 87 (Monday, May 6, 2002)]
[Notices]
[Pages 30358-30362]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 02-11075]


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DEPARTMENT OF COMMERCE

International Trade Administration

[A-437-804]


Notice of Preliminary Determination of Sales at Less Than Fair 
Value: Sulfanilic Acid From Hungary

AGENCY: Import Administration, International Trade Administration, 
Department of Commerce.

ACTION: Notice of preliminary determination of sales at less than fair 
value.

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SUMMARY: We preliminarily determine that sulfanilic acid from Hungary 
is being, or is likely to be, sold in the United States at less than 
fair value, as provided in section 733(b) of the Tariff Act of 1930, as 
amended.
    Interested parties are invited to comment on this preliminary 
determination (see the ``Public Comment'' section of this notice).

EFFECTIVE DATE: May 6, 2002.

FOR FURTHER INFORMATION CONTACT: Jarrod Goldfeder, Import 
Administration, International Trade Administration, U.S. Department of 
Commerce, 14th Street and Constitution Avenue, NW., Washington, DC 
20230; telephone: (202) 482-0189.

SUPPLEMENTARY INFORMATION:

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 of Commerce 
(``Department'') regulations are to 19 CFR Part 351 (April 2001).

Background

    Since the initiation of this investigation (Notice of Initiation of 
Antidumping Investigations: Sulfanilic Acid from Hungary and Portugal, 
66 FR 54214, 54218 (October 26, 2001) (``Initiation Notice'')), the 
following events have occurred:
    On October 25, 2001, we solicited comments from interested parties 
regarding the criteria to be used for model-matching purposes. We 
received comments from the petitioner on October 30, 2001.
    On November 20, 2001, the United States International Trade 
Commission (``ITC'') preliminarily determined that there is a 
reasonable indication that imports of sulfanilic acid from Hungary are 
materially injuring the United States industry (see ITC Investigation 
No. 731-TA-984-985 (Publication No. 3472)).
    We issued an antidumping questionnaire to Nitrokemia 2000 Rt. 
(``Nitrokemia''), a pro se respondent, on November 19, 2001. We 
received responses to the questionnaire from Nitrokemia on December 8, 
2001, and January 14, 2002. We issued supplemental questionnaires to 
Nitrokemia on January 25, February 12, March 11, and April 8, 2002, to 
which we received responses on February 6, February 28, March 27, and 
April 17, 2002, respectively. On January 29 and February 1, 2002, we 
received comments from the petitioner on the respondent's questionnaire 
responses. Subsequently, on February 10, 2002, we received comments 
from Nitrokemia on the petitioner's comments concerning the 
respondent's questionnaire responses.
    On February 14, 2002, the petitioner made a timely request to 
postpone the preliminary determination pursuant to 19 CFR 351.205(e). 
On February 15, 2002, we postponed the preliminary determination until 
no later than April 8, 2002. See Notice of Postponement of Preliminary 
Determinations of Antidumping Investigations: Sulfanilic Acid from 
Hungary and Portugal, 67 FR 8525 (February 25, 2002).
    On April 4, 2002, the Department again postponed the preliminary 
determination until no later than April 26, 2002. For the reasons for 
the postponement, see Notice of Postponement of Preliminary Antidumping 
Duty Determinations of Antidumping Duty Investigations: Sulfanilic Acid 
from Hungary and Portugal, 67 FR 17968 (April 12, 2002).
    On April 19, 2002, the petitioner submitted comments with respect 
to the upcoming preliminary determination.

Scope of Investigation

    Imports covered by this investigation are all grades of sulfanilic 
acid, which include technical (or crude) sulfanilic acid, refined (or 
purified) sulfanilic acid and sodium salt of sulfanilic acid.
    Sulfanilic acid is a synthetic organic chemical produced from the 
direct sulfonation of aniline and sulfuric acid. Sulfanilic acid is 
used as a raw material in the production of optical brighteners, food 
colors, specialty dyes and concrete additives. The principal 
differences between the grades are the undesirable quantities of 
residual aniline and alkali insoluble materials present in the 
sulfanilic acid. All grades are available as dry, free-flowing powders.
    Technical sulfanilic acid, currently classifiable under subheading

[[Page 30359]]

2921.42.22 of the Harmonized Tariff Schedule (``HTS''), contains 96 
percent minimum sulfanilic acid, 1.0 percent maximum aniline, and 1.0 
percent maximum alkali insoluble materials. Refined sulfanilic acid, 
also currently classifiable under 2921.42.22 of the HTS, contains 98 
percent minimum sulfanilic acid, 0.5 percent maximum aniline and 0.25 
percent maximum alkali insoluble materials.
    Sodium salt (sodium sulfanilate), currently classifiable under HTS 
subheading 2921.42.90, is a powder, granular or crystalline material 
which contains 75 percent minimum equivalent sulfanilic acid, 0.5 
percent maximum aniline based on the equivalent sulfanilic acid 
content, and 0.25 percent maximum alkali insoluble materials based on 
the equivalent sulfanilic acid content.
    Although the HTS subheadings are provided for convenience and 
customs purposes, the written description of the scope of this 
investigation is dispositive.
    In accordance with the preamble to the Department's regulations 
(see Antidumping Duties; Countervailing Duties; Final Rule, 62 FR 
27296, 27323 (May 19, 1997)), we set aside a period of time for parties 
to raise issues regarding product coverage and encouraged all parties 
to submit comments within 20 calendar days of publication of the 
Initiation Notice. We did not receive any such comments.

Period of Investigation

    The period of investigation (``POI'') is July 1, 2000, through June 
30, 2001.

Fair Value Comparisons

    To determine whether sales of sulfanilic acid from Hungary to the 
United States were made at less than fair value, we compared the export 
price (``EP'') to the normal value (``NV''), as described in the 
``Export Price'' and ``Normal Value'' sections of this notice, below. 
In accordance with section 777A(d)(1)(A)(i) of the Act, we compared POI 
weighted-average EPs to POI weighted-average NVs. Any company-specific 
changes to the EP and NV calculations are discussed in Nitrokemia's 
calculation memorandum, which is on file in the Import Administration's 
Central Records Unit, Room B-099 of the main Department of Commerce 
building.

Product Comparisons

    In accordance with section 771(16) of the Act, we considered all 
products produced and sold by Nitrokemia in the foreign market during 
the POI that fit the description in the ``Scope of Investigation'' 
section of this notice to be foreign like products for purposes of 
determining appropriate product comparisons to U.S. sales. We compared 
U.S. sales to sales of identical products in the third market (see 
``Normal Value'' section, below), where appropriate. Where there were 
no sales of identical merchandise in the foreign market made in the 
ordinary course of trade to compare to U.S. sales, we compared U.S. 
sales to sales of the most similar foreign like product made in the 
ordinary course of trade. In making the product comparisons, we matched 
foreign like products based on the physical characteristics reported by 
the respondent in the following order of importance: form; product 
type; aniline impurity content; alkali insoluble impurity content; and 
sulfanilic content.

Export Price

    We calculated EP, in accordance with section 772(a) of the Act, for 
those sales where the merchandise was sold to the first unaffiliated 
purchaser in the United States prior to importation by the exporter or 
producer outside the United States, or to an unaffiliated purchaser for 
exportation to the United States, based on the facts of record. We 
based EP on the packed CIF price to unaffiliated purchasers in the 
United States. We made deductions for movement expenses in accordance 
with section 772(c)(2)(A) of the Act. These included foreign inland 
freight, inland insurance, and ocean freight. We increased EP, where 
appropriate, for duty drawback in accordance with section 772(c)(1)(B) 
of the Act. We relied on the U.S. sales data submitted by Nitrokemia, 
with the following exceptions.
    Based on our review of Nitrokemia's questionnaire responses, we 
find that Nitrokemia did not answer many of the Department's numerous 
and repeated questions relating to the completeness and accuracy of its 
reporting of U.S. sales and related charges and adjustments. Section 
776(a)(2) of the Act provides that if an interested party or any other 
person (A) withholds information that has been requested by the 
administering authority; (B) fails to provide such information by the 
deadlines for the submission of the information or in the form and 
manner requested, subject to subsections (c)(1) and (e) of section 782 
of the Act; (C) significantly impedes a proceeding under this title; or 
(D) provides such information but the information cannot be verified as 
provided in section 782(i) of the Act, the administering authority 
shall, subject to section 782(d) of the Act, use the facts otherwise 
available in reaching the applicable determination under this title.\1\ 
Section 776(b) of the Act further provides that adverse inferences may 
be used when a party has failed to cooperate by not acting to the best 
of its ability to comply with a request for information.
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    \1\ Where the Department determines that a response to a request 
for information does not comply with the request, section 782(d) of 
the Act provides that the Department will so inform the party 
submitting the response and will, to the extent practicable, provide 
that party the opportunity to remedy or explain the deficiency. If 
the party fails to remedy the deficiency within the applicable time 
limits, the Department may, subject to section 782(e) of the Act, 
disregard all or part of the original and subsequent responses, as 
appropriate. Section 782(e) of the Act provides that the Department 
``shall not decline to consider information that is submitted by an 
interested party and is necessary to the determination but does not 
meet all the applicable requirements established by the 
administering authority'' if the information is timely, can be 
verified, and is not so incomplete that it cannot be used, and if 
the interested party acted to the best of its ability in providing 
the information. Where all of these conditions are met, the statute 
requires the Department to use the information, if it can do so 
without undue difficulties.
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    In this case, we find that Nitrokemia has withheld information 
requested by the Department concerning the completeness and accuracy of 
Nitrokemia's U.S. sales response. Specifically, we noted in 
Nitrokemia's original questionnaire response that it reported credit 
expenses, inventory carrying costs, direct selling expenses, and 
packing costs on some, but not all, U.S. sales. In several supplemental 
questionnaires, we requested that Nitrokemia report these expenses for 
all U.S. sales, or explain why it was not appropriate to do so. Despite 
our repeated notifications to Nitrokemia of these deficiencies in its 
data and the several opportunities we provided the company to remedy 
its reporting of these fields (pursuant to section 782(d) of the Act), 
Nitrokemia continued to provide incomplete responses. Since Nitrokemia 
did not provide the information requested or provided information that 
was so incomplete that it could not be used (within the meaning of 
section 782(e) of the Act), we are resorting to facts otherwise 
available pursuant to section 776(a)(2)(A) of the Act. Further, the 
data that Nitrokemia did not provide on some U.S. transactions was 
provided for other U.S. transactions. Nitrokemia did not sufficiently 
explain why it was not possible to provide this information for all 
U.S. transactions. Therefore, we conclude that Nitrokemia could have 
provided the necessary data but chose not to, thereby failing to 
cooperate to the best of its ability within the meaning of section 
776(b) of the Act. Accordingly,

[[Page 30360]]

we find that the use of an adverse inference is warranted.
    As explained in the Memorandum from Team to the File, ``Preliminary 
Determination Calculation Memorandum for Nitrokemia 2000 Rt.,'' dated 
April 26, 2002 (``Calculation Memorandum''), as adverse facts 
available, we adjusted EP or NV, as appropriate, by the highest 
adjustment amount that Nitrokemia actually reported in its U.S. sales 
response for direct selling expenses and packing costs. Furthermore, we 
recalculated Nitrokemia's credit expenses and inventory carrying costs 
using information contained in Nitrokemia's questionnaire responses and 
a published dollar-denominated short-term interest rate. No other 
adjustments were made to Nitrokemia's submitted U.S. sales response. We 
intend to review Nitrokemia's questionnaire responses extensively at 
verification in order to ascertain whether this application of facts 
available is adequately adverse.

Normal Value

A. Home Market Viability

    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., 
whether the aggregate volume of home market sales of the foreign like 
product is equal to or greater than five percent of the aggregate 
volume of U.S. sales), the Department compares the 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. We determined that Nitrokemia's volume of home 
market sales was less than five percent of its volume of U.S. sales. 
Therefore, we have based NV for Nitrokemia on third country sales in 
the usual commercial quantities and in the ordinary course of trade. 
For the reasons described in the Memorandum to Richard Moreland, 
``Selection of Third Country Comparison Market,'' dated April 26, 2002, 
we used sales to Germany as third-country comparison sales. Germany was 
Nitrokemia's largest third-country market for sulfanilic acid in terms 
of both value and quantity.

B. Cost of Production Analysis

    Based on our analysis of an allegation contained in the petition, 
we found that there were reasonable grounds to believe or suspect that 
sales of sulfanilic acid in the third market were made at prices below 
their cost of production (``COP''). Reasonable grounds exist when an 
interested party provides specific factual information on costs and 
prices, observed or constructed, indicating that sales in the 
comparison market in question are at below-cost prices. See Antidumping 
Duty Petition, September 26, 2001. Accordingly, pursuant to section 
773(b) of the Act, we initiated a country-wide sales-below-cost 
investigation to determine whether sales were made at prices below 
their respective COP (see Initiation Notice, 66 FR at 54215).
1. Calculation of COP
    In accordance with section 773(b)(3) of the Act, we calculated COP 
based on the sum of the cost of materials and fabrication for the 
foreign like product, plus an amount for selling, general, and 
administrative expenses (``SG&A''), interest expenses, and foreign 
market packing costs (see ``Test of Foreign Market Sales Prices'' 
section below for treatment of foreign market selling expenses). We 
relied on the COP data submitted by Nitrokemia, with the following 
exceptions. Despite our repeated requests in the original and 
supplemental questionnaires, Nitrokemia did not report overhead, SG&A, 
and financial expense in accordance with the Department's instructions. 
Moreover, the actual cost data supplied by Nitrokemia are not 
sufficient for purposes of deriving SG&A and financial expense ratios. 
Because Nitrokemia failed to provide this cost information in the form 
and manner requested by the Department, pursuant to section 
776(a)(2)(B) of the Act we find that facts available is warranted. As 
facts available, we derived SG&A and interest expense ratios based on 
Nitrokemia's 2000 financial statements, as included in the petition and 
submitted by Nitrokemia in its questionnaire responses. Furthermore, we 
derived an overhead ratio based on total overhead costs reported by 
Nitrokemia and information from Nitrokemia's 2000 financial statements. 
As we noted above, we intend to review Nitrokemia's questionnaire 
responses extensively at verification in order to ascertain whether 
this application of facts available is adequately adverse.
2. Test of Foreign Market Sales Prices
    We compared COP to foreign market sale prices of the foreign like 
product, as required under section 773(b) of the Act, in order to 
determine whether these sales had been made at prices below the COP. In 
determining whether to disregard foreign market sales made at prices 
below the COP, we examined whether such sales were made (1) within an 
extended period of time in substantial quantities, and (2) at prices 
which permitted the recovery of all costs within a reasonable period of 
time, in accordance with sections 773(b)(1)(A) and (B) of the Act. On a 
product-specific basis, we compared the COP to foreign market prices, 
less any applicable movement charges, discounts and rebates, and 
selling expenses.
3. Results of the COP Test
    Pursuant to section 773(b)(2)(C), where less than 20 percent of the 
respondent's sales of a given product are at prices less than the COP, 
we do not disregard any below-cost sales of that product, because we 
determine that in such instances the below-cost sales were not made in 
``substantial quantities.'' Where 20 percent or more of a respondent's 
sales of a given product are at prices less than the COP over a period 
of at least six months, we determine that the below-cost sales 
represent ``substantial quantities'' within an extended period of time, 
in accordance with section 773(b)(1)(A) of the Act. In such cases, we 
also determine whether such sales were made at prices which would not 
permit recovery of all costs within a reasonable period of time, in 
accordance with section 773(b)(1)(B) of the Act and, if so, we 
disregard the below-cost sales.
    We found that, for certain products, more than 20 percent of 
Nitrokemia's foreign market sales were at prices less than the COP and 
did not provide for the recovery of costs. Therefore, we excluded these 
sales and used the remaining above-cost sales, if any, as the basis for 
determining NV, in accordance with section 773(b)(1) of the Act.

C. Level of Trade

    Section 773(a)(1)(B)(i) of the Act states that, to the extent 
practicable, the Department will calculate NV based on sales at the 
same level of trade (``LOT'') as the EP or constructed export price. 
Sales are made at different LOTs if they are made at different 
marketing stages (or their equivalent) according to 19 CFR 
351.412(c)(2). Substantial differences in selling activities are a 
necessary, but not sufficient, condition for determining that there is 
a difference in the stages of marketing. Id; see also Notice of Final 
Determination of Sales at Less Than Fair Value: Certain Cut-to-Length 
Carbon Steel Plate From South Africa, 62 FR 61731, 61732 (November 19, 
1997). In order to determine whether the comparison sales were at 
different stages in the marketing process than the U.S. sales, we 
reviewed the distribution system in each market (i.e., the ``chain of 
distribution''),\2\ including selling

[[Page 30361]]

functions,\3\ class of customer (``customer category''), and the level 
of selling expenses for each type of sale.
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    \2\ The marketing process in the United States and comparison 
markets begins with the producer and extends to the sale to the 
final user or consumer. The chain of distribution between the two 
may have many or few links, and the respondent's sales occur 
somewhere along this chain. In performing this evaluation, we 
considered the narrative responses of the respondent to properly 
determine where in the chain of distribution the sale occurs.
    \3\ Selling functions associated with a particular chain of 
distribution help us to evaluate the level(s) of trade in a 
particular market. For purposes of this preliminary determination, 
we have organized the common sulfanilic acid selling functions into 
four major categories: Sales process and marketing support, freight 
and delivery, inventory and warehousing, and quality assurance/
warranty services.
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    Pursuant to section 773(a)(1)(B)(i) of the Act, in identifying 
levels of trade for EP and comparison market sales (i.e., NV based on 
either home market or third country prices), we consider the starting 
prices before any adjustments.
    When the Department is unable to match U.S. sales to sales of the 
foreign like product in the comparison market at the same LOT as the EP 
LOT, the Department may compare the U.S. sale to sales at a different 
LOT in the comparison market. If the comparison market sales are at a 
different LOT, and the difference affects price comparability, as 
manifested in a pattern of consistent price differences between sales 
at different LOTs in the country in which NV is determined, we make a 
level of trade adjustment under section 773(a)(7)(A) of the Act. See 
Notice of Final Determination of Sales at Less Than Fair Value: Certain 
Cut-to-Length Carbon Steel Plate from South Africa, 62 FR 61731 
(November 19, 1997).
    We obtained information from Nitrokemia regarding the marketing 
stages involved in making the reported third market and U.S. sales, 
including a description of the selling activities performed by the 
respondent for each channel of distribution. In the comparison market, 
all sales reported by Nitrokemia were direct sales to end users. Sales 
through this single channel of distribution to the sole customer 
category were similar with respect to all selling activities and, 
therefore, Nitrokemia's foreign market sales constituted a single level 
of trade.
    In the U.S. market, Nitrokemia had only EP sales. Nitrokemia 
reported direct EP sales to end users through only one channel of 
distribution and one customer category, and therefore had only one 
level of trade for its EP sales. This EP level of trade was similar to 
the foreign market level of trade with respect to selling activities, 
except for marginal differences in sales process and marketing support. 
Consequently, we matched the EP level of trade to sales at the same 
level of trade in the foreign market.

D. Calculation of Normal Value Based on Foreign Market Prices

    We calculated NV based on free carrier, carriage paid, or delivered 
duties unpaid prices to unaffiliated customers. We made adjustments for 
inland freight, international freight, and duty drawback, in accordance 
with section 773(a)(6)(B)(iii) of the Act. We made adjustments, where 
appropriate, for differences in costs attributable to differences in 
the physical characteristics of the merchandise in accordance with 
section 773(a)(6)(C)(ii) of the Act and 19 CFR 351.411. In addition, 
where appropriate, we made adjustments under section 773(a)(6)(C)(iii) 
of the Act for differences in circumstances of sale for commissions, 
imputed credit expenses, and other direct selling expenses. We also 
made adjustments, in accordance with 19 CFR 351.410(e), for indirect 
selling expenses incurred in the foreign market on U.S. sales where 
commissions were granted on sales in one market but not in the other 
(the commission offset). We deducted foreign market packing costs and 
added U.S. packing costs in accordance with section 773(a)(6)(A) and 
(B) of the Act. We adjusted Nitrokemia's reported inventory carrying 
costs and packing costs, where appropriate, as explained in the 
Calculation Memorandum.

Currency Conversion

    We made currency conversions into U.S. dollars in accordance with 
section 773A(a) of the Act based on the exchange rates in effect on the 
dates of the U.S. sales, either as certified by the Federal Reserve 
Bank or, in the case of Hungarian forints, as reported by the Dow 
Jones.\4\
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    \4\ We normally make currency conversions into U.S. dollars in 
accordance with section 773A(a) of the Act based on the exchange 
rates in effect on the dates of the U.S. sales as certified by the 
Federal Reserve Bank. In this case, where foreign market prices, 
costs and expenses were reported in Hungarian forints, we made 
currency conversions based on the exchange rates in effect on the 
dates of the U.S. sales as reported by the Dow Jones because the 
Federal Reserve Bank does not track the forint-to-dollar exchange 
rate.
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Verification

    As provided in section 782(i) of the Act, we will verify all 
information relied upon in making our final determination.

Suspension of Liquidation

    In accordance with section 733(d)(2) of the Act, we are directing 
the Customs Service to suspend liquidation of all imports of subject 
merchandise 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 EP, 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
------------------------------------------------------------------------
Nitrokemia.................................................         7.40
All Others.................................................         7.40
------------------------------------------------------------------------

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.

Disclosure

    We will disclose the calculations used in our analysis to parties 
to this proceeding in accordance with 19 CFR 351.224(b).

Public Comment

    Case briefs for this investigation must be submitted to the 
Department not later than June 4, 2002. Rebuttal briefs must be filed 
by June 10, 2002. See 19 CFR 309(c)(1)(i). A list of authorities used, 
a table of contents, and an executive summary of issues should 
accompany any briefs submitted to the Department. Executive summaries 
should be limited to five pages total, including footnotes. Section 774 
of the Act provides that the Department will hold a public hearing to 
afford interested parties an opportunity to comment on arguments raised 
in case or rebuttal briefs, provided that such a hearing is requested 
by an interested party. If a request for a hearing is made in this 
investigation, the hearing will tentatively be held on June 13, 2002, 
at the U.S. Department of Commerce, 14th Street and Constitution 
Avenue, NW., Washington, DC 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

[[Page 30362]]

requested, must submit a written request to the Assistant Secretary for 
Import Administration, U.S. Department of Commerce, Room 1870, within 
30 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 not later than 75 days after the date of the 
Department's preliminary determination.
    This determination is published pursuant to sections 733(f) and 
777(i) of the Act.

    Dated: April 26, 2002.
Faryar Shirzad,
Assistant Secretary for Import Administration.
[FR Doc. 02-11075 Filed 5-3-02; 8:45 am]
BILLING CODE 3510-DS-P