[Federal Register Volume 70, Number 36 (Thursday, February 24, 2005)]
[Notices]
[Pages 9037-9041]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E5-760]


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DEPARTMENT OF COMMERCE

International Trade Administration

[A-570-896]


Final Determination of Sales at Less Than Fair Value and 
Affirmative Critical Circumstances: Magnesium Metal From the People's 
Republic of China

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

Final Determination

    We determine that magnesium metal from the People's Republic of 
China (``PRC'') is being, or is likely to be, sold in the United States 
at less than fair value (``LTFV'') as provided in section 735 of Tariff 
Act of 1930, as amended (``the Act''). The estimated margins of sales 
at LTFV are shown in the ``Final Determination Margins'' section of 
this notice.

DATES: Effective Date: February 24, 2005.

FOR FURTHER INFORMATION CONTACT: Laurel LaCivita or Lilit 
Astvatsatrian, Import Administration, International Trade 
Administration, U.S. Department of Commerce, 14th Street and 
Constitution Avenue NW., Washington, DC 20230; telephone: (202) 482-
4243 and (202) 482-6412, respectively.

Case History

    The Department of Commerce (``the Department'') published its 
preliminary determination of sales at LTFV on October 4, 2004. See 
Preliminary Determination of Sales at Less Than Fair Value: Magnesium 
Metal from the People's Republic of China, 69 FR 59187, (October 4, 
2004) (``Preliminary Determination''). The Department selected two 
mandatory respondents \1\ and received a Section A response from a 
third company requesting a rate separate from the PRC-wide entity.\2\ 
Since the Preliminary Determination, the Department conducted 
verification of RSM and Tianjin in both the PRC and the United States, 
where applicable. See the Verification Section below for additional 
information. On November 22, 2004, the parties \3\ submitted surrogate-
value information. On December 2, 2004, the parties submitted rebuttals 
to those surrogate-value submissions. On December 28, 2004, the 
petitioners submitted an allegation of critical circumstances in 
accordance with section 733(e)(1) of the Act and 19 CFR 351.206(c)(1). 
On January 4, 2005, the Petitioners, RSM, and Tianjin submitted case 
briefs, and on January 10, 2005, all three parties submitted rebuttal 
briefs. On January 11, 2005, the Department invited all parties to 
comment on the petitioners' allegation of critical circumstances and 
requested RSM, Tianjin, and Guangling to report the quantity and value 
of their shipments of subject merchandise to the United States on a 
monthly basis for the period January 2003 through December 2004. On 
January 19, 2005, RSM and Tianjin provided the requested information. 
Guangling did not respond to the Department's request for information. 
On February 3, 2005, the Department published its preliminary 
determination of critical circumstances in which it found that critical 
circumstances exist with regard to imports of magnesium metal from the 
PRC for Tianjin, Guangling, and the PRC-wide entity. See Affirmative 
Preliminary Determination of Critical Circumstances: Magnesium Metal 
from the People's Republic of China, 70 FR 5606 (February 3, 2005) 
(``Critical Circumstances Determination''). On February 7, 2005, the 
petitioners submitted comments on the Department's preliminary 
determination of critical circumstances. None of the respondents 
provided comments or rebuttals on the Department's preliminary 
determination of critical circumstances.
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    \1\ Tianjin Magnesium International Co., Ltd. (``Tianjin''), and 
the RSM companies. In the preliminary determination we determined 
that the following companies were collapsed members of the RSM group 
of companies for the purposes of this investigation: Nanjing Yunhai 
Special Metals Co., Ltd. (``Yunhai Special''), Nanjing Welbow Metals 
Co., Ltd. (``Welbow''), Nanjing Yunhai Magnesium Co., Ltd. (``Yunhai 
Magnesium''), Shanxi Wenxi Yunhai Metals Co., Ltd. (``Wenxi 
Yunhai''). See Memorandum to Laurie Parkhill, Director, Office 8, 
NME/China Group, from Laurel LaCivita, Senior Case Analyst, through 
Robert Bolling, Program Manager: Antidumping Duty Investigation of 
Magnesium Metal from the People's Republic of China: Affiliation and 
Collapsing of Members of the RSM Group and its Affiliated U.S. 
Reseller, Toyota Tsusho America, Inc., dated September 24, 2004. In 
addition, we calculated a separate rate for China National 
Nonferrous Metals I/E Corp. Jiangsu Branch (``Jiangsu Metals''). See 
Memorandum to Laurie Parkhill, Director, Office 8, NME/China Group, 
from Laurel LaCivita, Senior Case Analyst and Lilit Astvatsatrian, 
Case Analyst, through Robert Bolling, Program Manager: Separate 
Rates Memorandum, dated September 24, 2004.
    \2\ Beijing Guangling Jinghua Science & Technology Co., Ltd. 
(``Guangling'').
    \3\ The parties include RSM, Tianjin, and the petitioners (U.S. 
Magnesium LLC, United Steelworkers of America, Local 8319 and Glass, 
Molders, Pottery, Plastics & Allied Workers International, Local 
374). Guangling did not submit case or rebuttal briefs.

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[[Page 9038]]

Analysis of Comments Received

    All issues raised in the case and rebuttal briefs by parties to 
this proceeding are addressed in the memorandum from Barbara E. 
Tillman, Acting Deputy Assistant Secretary for Import Administration, 
to Joseph A. Spetrini, Acting Assistant Secretary for Import 
Administration, Issues and Decision Memorandum for the Less-Than-Fair-
Value Investigation of Magnesium Metal from the People's Republic of 
China, dated February 16, 2005, which is hereby adopted by this notice 
(``Issues and Decision Memorandum''). A list of the issues which 
parties raised and to which we respond in the Issues and Decision 
Memorandum is attached to this notice as an Appendix. The Issues and 
Decision Memorandum is a public document and is on file in the Central 
Records Unit (``CRU''), Main Commerce Building, Room B-099, and is 
accessible on the Web at http://ia.ita.doc.gov. The paper copy and 
electronic version of the memorandum are identical in content.

Scope of Investigation

    The products covered by this investigation are primary and 
secondary alloy magnesium metal regardless of chemistry, raw material 
source, form, shape, or size. Magnesium is a metal or alloy containing 
by weight primarily the element magnesium. Primary magnesium is 
produced by decomposing raw materials into magnesium metal. Secondary 
magnesium is produced by recycling magnesium-based scrap into magnesium 
metal. The magnesium covered by this investigation includes blends of 
primary and secondary magnesium.
    The subject merchandise includes the following alloy magnesium 
metal products made from primary and/or secondary magnesium including, 
without limitation, magnesium cast into ingots, slabs, rounds, billets, 
and other shapes, magnesium ground, chipped, crushed, or machined into 
raspings, granules, turnings, chips, powder, briquettes, and other 
shapes: products that contain 50 percent or greater, but less than 99.8 
percent, magnesium, by weight, and that have been entered into the 
United States as conforming to an ``ASTM Specification for Magnesium 
Alloy'' \4\ and thus are outside the scope of the existing antidumping 
orders on magnesium from the PRC (generally referred to as ``alloy'' 
magnesium).
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    \4\ The meaning of this term is the same as that used by the 
American Society for Testing and Materials in its Annual Book of 
ASTM Standards: Volume 01.02 Aluminum and Magnesium Alloys.
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    The scope of this investigation excludes the following merchandise: 
(1) All forms of pure magnesium, including chemical combinations of 
magnesium and other material(s) in which the pure magnesium content is 
50 percent or greater, but less than 99.8 percent, by weight, that do 
not conform to an ``ASTM Specification for Magnesium Alloy'' \5\; (2) 
magnesium that is in liquid or molten form; and (3) mixtures containing 
90 percent or less magnesium in granular or powder form, by weight, and 
one or more of certain non-magnesium granular materials to make 
magnesium-based reagent mixtures, including lime, calcium metal, 
calcium silicon, calcium carbide, calcium carbonate, carbon, slag 
coagulants, fluorspar, nephaline syenite, feldspar, alumina (Al203), 
calcium aluminate, soda ash, hydrocarbons, graphite, coke, silicon, 
rare earth metals/mischmetal, cryolite, silica/fly ash, magnesium 
oxide, periclase, ferroalloys, dolomite lime, and colemanite.\6\
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    \5\ This material is already covered by existing antidumping 
orders. See Antidumping Duty Orders: Pure Magnesium from the 
People's Republic of China, the Russian Federation and Ukraine; 
Amended Final Determination of Sales at Less Than Fair Value: 
Antidumping Duty Investigation of Pure Magnesium from the Russian 
Federation, 60 FR 25691 (May 12, 1995), and Antidumping Duty Order: 
Pure Magnesium in Granular Form from the People's Republic of China, 
66 FR 57936 (November 19, 2001).
    \6\ This third exclusion for magnesium-based reagent mixtures is 
based on the exclusion for reagent mixtures in the 2000-2001 
investigations of magnesium from the PRC, Israel, and Russia. See 
Final Determination of Sales at Less Than Fair Value: Pure Magnesium 
in Granular Form From the People's Republic of China, 66 FR 49345 
(September 27, 2001); Final Determination of Sales at Less Than Fair 
Value: Pure Magnesium From Israel, 66 FR 49349 (September 27, 2001); 
Final Determination of Sales at Not Less Than Fair Value: Pure 
Magnesium From the Russian Federation, 66 FR 49347 (September 27, 
2001). These mixtures are not magnesium alloys because they are not 
chemically combined in liquid form and cast into the same ingot.
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    The merchandise subject to this investigation is currently 
classifiable under items 8104.19.00 and 8104.30.00 of the Harmonized 
Tariff Schedule of the United States (``HTSUS''). Although the HTSUS 
items are provided for convenience and customs purposes, the written 
description of the merchandise under investigation is dispositive.

Verification

    As provided in section 782(i) of the Act, we verified the 
information submitted by the mandatory respondents for use in our final 
determination (see the Department's verification reports on the record 
of this investigation, located in the CRU, with respect to Jiangsu 
Metals, Yunhai Special, Welbow, Bada, Tianjin, and Toyota Tsusho 
America, Inc. (``TAI'')). For all verified companies, we used standard 
verification procedures, including examination of relevant accounting 
and production records as well as original source documents provided by 
respondents.

Surrogate Country

    In the Preliminary Determination, we stated that we had selected 
India as the appropriate surrogate country to use in this investigation 
for the following reasons: (1) India is at a level of economic 
development comparable to that of the PRC; (2) Indian manufacturers 
produce comparable merchandise and are significant producers of 
aluminum; (3) India provides the best opportunity to use appropriate, 
publicly available data to value the factors of production. See 
Preliminary Determination, 69 FR at 59191. For the final determination, 
we made no changes to our findings with respect to the selection of a 
surrogate country.

Critical Circumstances

    As described below in the section concerning the application of 
adverse facts available (``AFA''), we are applying total AFA to the 
group of RSM companies which includes Jiangsu Metals and TAI. As part 
of total AFA for the RSM companies, we determine that RSM and Jiangsu 
Metals are not eligible for a separate rate and, therefore, remain a 
part of the PRC-wide entity. Therefore, we revised our critical-
circumstances analysis to include imports from RSM and Jiangsu Metals 
in the total quantity of imports from the PRC-wide entity during the 
base and comparison periods. As a result of this change, we have 
determined that critical circumstances do not exist with respect to the 
PRC-wide entity. Additionally, for this final determination we continue 
to find that critical circumstances exist for Tianjin and Guangling. 
For further details regarding the Department's critical-circumstances 
analysis see the Memorandum from Laurel LaCivita, Case Analyst, to 
Laurie Parkhill, Office Director, AD/CVD Enforcement, Antidumping Duty 
Investigation of Magnesium Metal from the People's Republic of China 
(the ``PRC'')--Affirmative Final Determination of Critical 
Circumstances, dated February 16, 2005 (``Final Critical Circumstances 
Memorandum'').

Separate Rates

    In the Preliminary Determination, the Department found that 
Guangling, which provided a response to Section A

[[Page 9039]]

of the antidumping questionnaire, was eligible for a rate separate from 
the PRC-wide rate. The margin we established in the Preliminary 
Determination for Guangling was 140.09 percent. Because the rates of 
the selected mandatory respondents have changed since the Preliminary 
Determination, we have recalculated the rate applicable to Guangling. 
The final rate is 91.36 percent.
    As discussed below, the Department has determined to apply AFA with 
respect to the RSM companies. In addition, we have determined that 
there is no reliable basis for granting the RSM companies a separate 
rate. Accordingly, the RSM companies have not overcome the presumption 
that they are part of the PRC-wide entity and, therefore, entries of 
their merchandise will be subject to the PRC-wide rate.

Adverse Facts Available

    Section 776(a)(2) of the Act provides that the Department shall 
apply ``facts otherwise available'' if, inter alia, an interested party 
or any other person (A) withholds information that has been requested, 
(B) fails to provide information within the deadlines established, or 
in the form or manner requested by the Department, subject to 
subsections (c)(1) and (e) of section 782, (C) significantly impedes a 
proceeding, or (D) provides information that cannot be verified as 
provided by section 782(i) of the Act. Section 776(b) of the Act 
provides further that the Department may use an adverse inference when 
a party has failed to cooperate by not acting to the best of its 
ability to comply with a request for information.
    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 and subject to 
section 782(e) of the Act, the Department may 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 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.
    In the Preliminary Determination, we calculated a dumping margin of 
128.11 percent for RSM based on the information it reported in its 
questionnaire responses. See Preliminary Determination. We conducted 
verification of the RSM companies in the PRC and in the United States.
    In the Preliminary Determination, we determined that the RSM group 
of companies and Jiangsu Metals were affiliated under sections 
771(33)(E) and (F) of the Act. See Preliminary Determination at 59192. 
Additionally, we determined that TAI and the RSM group of companies 
were affiliated under sections 771(33)(E) and (F) of the Act. See 
Preliminary Determination at 59192. There has been no information 
placed on the record since the Preliminary Determination that 
contradicts our affiliation determinations. Therefore, for the final 
determination, we continue to find that RSM, Jiangsu Metals, and TAI 
are affiliated under the statute.
    Based on record evidence gathered as a result of the verification 
of TAI, RSM's affiliated customer in the United States, and pursuant to 
the statutory requirements of the Act, the Department has determined 
that the RSM Group and its affiliates impeded this investigation, 
provided unverifiable information, and did not cooperate to the best of 
their ability to comply with the Department's requests for information. 
Therefore, we determine that the use of AFA is warranted with respect 
to all of TAI's sales of subject merchandise whether exported through 
RSM or Jiangsu Metals for the purposes of the final determination of 
this investigation. See our response to Comment 1 in the Decision 
Memorandum for a further discussion of this issue.
    In the Preliminary Determination, the Department granted RSM and 
Jiangsu Metals separate rates based on the information provided in 
their questionnaire responses. See memorandum to Laurie Parkhill, 
Office Director, China/NME Group, through Robert Bolling, Program 
Manager, from Laurel LaCivita, Senior Case Analyst and Lilit 
Astvatsatrian, Case Analyst, Preliminary Determination: Magnesium Metal 
from the People's Republic of China: Separate-Rates Memorandum 
(``Separate Rates Memorandum''), dated September 24, 2004, at 13. 
Because we found that RSM's affiliate TAI did not cooperate to the best 
of its ability and are applying AFA to all of TAI's sales of subject 
merchandise in the United States, we have determined that RSM and 
Jiangsu Metals, which produced and/or exported the subject merchandise, 
do not qualify for separate rates. See our response to Comment 3 in the 
Issues and Decision Memorandum for a further discussion of this issue.

Corroboration of the Adverse-Facts-Available Rate

    In the Preliminary Determination, in accordance with sections 
776(b) of the Act, we assigned an AFA rate to the PRC-wide entity based 
on a calculated margin derived from information obtained in the course 
of the investigation and placed on the record of this proceeding. At 
the Preliminary Determination, we applied a rate of 177.62 percent. 
Based on comments we received from interested parties which changed our 
calculations of the respondents margins, we have determined to change 
the AFA rate we applied in the Preliminary Determination.
    Section 776(c) of the Act provides that, when the Department relies 
on secondary information rather than on information obtained in the 
course of an investigation as facts available, it must, to the extent 
practicable, corroborate that information from independent sources 
reasonably at its disposal. Secondary information is described in the 
SAA as ``information derived from the petition that gave rise to the 
investigation or review, the final determination concerning subject 
merchandise, or any previous review under section 751 concerning the 
subject merchandise.'' See SAA at 870. The SAA provides that to 
``corroborate'' means simply that the Department will satisfy itself 
that the secondary information to be used has probative value. Ibid. 
The SAA also states that independent sources used to corroborate may 
include, for example, published price lists, official import statistics 
and customs data, and information obtained from interested parties 
during the particular investigation. Ibid. As explained in Tapered 
Roller Bearings and Parts Thereof, Finished and Unfinished, from Japan, 
and Tapered Roller Bearings, Four Inches or Less in Outside Diameter, 
and Components Thereof, from Japan; Preliminary Results of Antidumping 
Duty Administrative Reviews and Partial Termination of Administrative 
Reviews, 61 FR 57391, 57392 (November 6, 1996), to corroborate 
secondary information, the Department will examine, to the extent 
practicable, the reliability and relevance of the information used.

[[Page 9040]]

    We find that the export-price and normal-value information in the 
petition is reliable and relevant and, therefore, have determined that 
the information has probative value. See Memorandum from Lilit 
Astvatsatrian to Laurie Parkhill, dated February 16, 2005, 
Corroboration of the PRC-Wide Adverse Facts-Available Rate. 
Accordingly, we find that the highest margin based on that information, 
141.49 percent, is corroborated within the meaning of section 776(c) of 
the Act.
    Furthermore, there is no information on the record that 
demonstrates that the rate we have selected is an inappropriate total 
AFA rate for the companies in question. Therefore, we consider the 
selected rate to have probative value with respect to the firms in 
question and to reflect the appropriate adverse inference.

The PRC-Wide Rate

    Because we begin with the presumption that all companies within a 
non-market-economy (``NME'') country are subject to government control 
and because only the companies listed under the ``Final Determination 
Margins'' below have overcome that presumption, we are applying a 
single antidumping rate--the PRC-wide rate--to all other exporters of 
subject merchandise from the PRC. Such companies did not demonstrate 
entitlement to a separate rate. See Final Determination of Sales at 
Less Than Fair Value: Synthetic Indigo from the People's Republic of 
China, 65 FR 25706 (May 3, 2000). The PRC-wide rate applies to all 
entries of subject merchandise except for entries from the respondents 
listed in the ``Final Determination Margins'' section below (except as 
noted).

Changes Since the Preliminary Determination

    Based on our analysis of comments received, we have made changes in 
our margin calculations for Tianjin. We did not calculate a margin 
using the information RSM provided because we determined the margin for 
RSM based on total AFA. For discussion of the company-specific changes 
we made since the preliminary determination to our calculations of 
Tianjin's final margin, see Memorandum to the File from Lilit 
Astvatsatrian, Case Analyst, through Robert Bolling, Program Manager, 
Analysis Memorandum for the Final Determination of the Antidumping Duty 
Investigation of Magnesium Metal from the People's Republic of China: 
Tianjin Magnesium Co., Ltd. (``Tianjin'') (``Final Analysis 
Memorandum''), dated February 16, 2005. We made the following changes 
to the margin calculations:
     We determined the profit ratios for the Indian surrogate 
companies as a percentage of the cost of manufacturing, selling, 
general and administrative expenses, and interest.
     We calculated the surrogate value for the subject 
merchandise produced by Yinguang Metal based on its purchases of pure 
magnesium from affiliated and unaffiliated suppliers rather than by 
using surrogate values for inputs used to produce the raw magnesium 
produced and supplied to Yinguang by Yangyu Magnesium, an affiliated 
supplier.

Final Determination Margins

    We determine that the following percentage weighted-average margins 
exist for the Period of Investigation:

                      Magnesium Metal from the PRC
------------------------------------------------------------------------
                                                               Weighted-
                    Manufacturer/Exporter                       Average
                                                                Margin
------------------------------------------------------------------------
Tianjin.....................................................       91.31
Guangling...................................................       91.31
PRC-Wide Rate*..............................................     141.49
------------------------------------------------------------------------
\*\ Not a separate rate; also applies to the RSM companies and Jiangsu
  Metals.

Continuation of Suspension of Liquidation

    In accordance with section 735(c)(1)(B) of the Act, we are 
directing the U.S. Bureau of Customs and Border Protection (``CBP'') to 
continue to suspend liquidation of all entries of subject merchandise 
from the PRC that are entered, or withdrawn from warehouse, for 
consumption on or after October 4, 2004 for the RSM group of companies.
    With respect to Tianjin and Guangling, we will direct the U.S. 
Customs and Border Protection (``CBP'') to continue to suspend 
liquidation of all entries of magnesium metal from the PRC that are 
entered, or withdrawn from warehouse, on or after 90 days before the 
date of publication of the Preliminary Determination. CBP shall 
continue to require a cash deposit or posting of a bond equal to the 
estimated amount by which the normal value exceeds the U.S. price as 
shown below. These instructions suspending liquidation will remain in 
effect until further notice.

Disclosure

    We will disclose the calculations performed within five days of the 
date of publication of this notice to parties in this proceeding in 
accordance with 19 CFR 351.224(b).

ITC Notification

    In accordance with section 735(d) of the Act, we have notified the 
International Trade Commission (``ITC'') of our final determination of 
sales at LTFV. As our final determination is affirmative, in accordance 
with section 735(b)(2) of the Act, within 45 days the ITC will 
determine whether the domestic industry in the United States is 
materially injured, or threatened with material injury, by reason of 
imports or sales (or the likelihood of sales) for importation of the 
subject merchandise. If the ITC determines that material injury or 
threat of material injury does not exist, the proceeding will be 
terminated and all securities posted will be refunded or canceled. If 
the ITC determines that such injury does exist, the Department will 
issue an antidumping duty order directing CBP to assess antidumping 
duties on all imports of subject merchandise entered for consumption on 
or after the effective date of the suspension of liquidation.

Notification Regarding APO

    This notice also serves as a reminder to parties subject to 
administrative protective order (``APO'') of their responsibility 
concerning the disposition of proprietary information disclosed under 
APO in accordance with 19 CFR 351.305. Timely notification of return or 
destruction of APO materials or conversion to judicial protective order 
is hereby requested. Failure to comply with the regulations and the 
terms of an APO is a sanctionable violation.
    This determination is issued and published in accordance with 
sections 735(d) and 777(I)(1) of the Act.

    Dated: February 16, 2005.
Joseph A. Spetrini,
Acting Assistant Secretary for Import Administration.

Appendix

Issues in the Issues and Decision Memorandum

Issues With Respect to RSM

Comment 1: TAI Verification Failure
    Date of Sale
    TAI's Lack of Preparation
    Location of the Accounting Documents and Site Selection for 
Verification
    Sales--Trace Documentation
    Brokerage Expenses Incurred in the United States
    Warehousing and Freight Expenses Incurred in the United States
    Indirect Selling Expenses
Comment 2: Application of Adverse Facts Available
Comment 3: Separate Rate for Jiangsu Metals
Comment 4: Labor-Rate Factor at Bada Magnesium

[[Page 9041]]

General Issues

Comment 5: Critical Circumstances
Comment 6: Exporter-Producer Combination Rates

Surrogate Values

Comment 7: Time Period for the Valuation of Pure Magnesium
Comment 8: Valuation of Pure Magnesium
Comment 9: Surrogate Value for Dolomite
Comment 10: Ferrosilicon, No. 2 Flux, Fluorite Powder, Magnesium and 
Barium Chlorides, Bituminous Coal
Comment 11: Electricity and Chemicals/Gases
Comment 12: Use of Zinc Financial Statements Instead of Aluminum for 
Determination of the Overhead Ratios
Comment 13: Particle-board Pallets, Profit, and Marine Insurance

Issues with Respect to Tianjin

Comment 14: Valuation of Pure Magnesium for Yinguang
Comment 15: Yinguang's Consumption Rate for Dolomite
Comment 16: Supplier Distance for Yangyu
Comment 17: Valuation of Pure Magnesium for Guoli
 [FR Doc. E5-760 Filed 2-23-05; 8:45 am]
BILLING CODE 3510-DS-P