# CC Metals and Alloys, LLC — Hazardous Materials Safety Interpretation

**Citation:** 20-0024  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2020-06-09

20-0024 response to CC Metals and Alloys, LLC concerning 173.22.

## Document text

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
June 9, 2020
Joe Cruse
Quality / Lab Manager
CC Metals and Alloys, LLC
1542 North Main Street
PO Box 217
Calvert City, KY 42029
Reference No. 20-0024
Dear Mr. Cruse:
This letter is in response to your March 9, 2020, email requesting clarification of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of
“UN1408, Ferrosilicon, with 30 percent or more but less than 90 percent silicon.” You state that
your company has transported this material as a non-hazardous material based on third-party
testing that confirmed that the material does not meet the definition of a Division 4.3 (dangerous
when wet) material. However, you state that the U.S. Coast Guard will not accept the third-party
testing information you have previously provided them and you seek confirmation that the
product you transport does not meet the criteria of a Division 4.3 (dangerous when wet) material.
Under 49 CFR 173.22, it is the shipper’s responsibility to properly classify a hazardous material
and such determinations are not required to be verified by this Office. Furthermore, PHMSA
does not certify a shipper’s determination of whether a material is hazardous or not. However,
based on the third-party test results you provided with your email, it is the opinion of this Office
that the ferrosilicon manufactured by your company does not meet the criteria of a Division 4.3
(dangerous when wet) material. Note that exclusion from Divisions 4.3 alone does not
necessarily indicate that the material is not subject to the HMR. To satisfy the request of the U.S.
Coast Guard you may consider conducting additional tests to verify that the product does not
meet any other hazard classification criteria, (e.g., Division 6.1).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

<<<PAGE 2>>>

CC1QQ,:t
2() - CX>Q<j
Dodd, Alice (PHMSA)
From:
Sent:
To:
Subject:
Attachments:
INFOCNTR (PHMSA)
Monday, March 9, 2020 3:40 PM
Hazmat lnterps
FW: Request For Formal Letter of Interpretation On Hazmat Classification
US DOT HAZ MAT Exemption Testing Results.pdf; Cruse Letter.docx
Hello Alice and lkeya,
Below is a request for letter of interpretation with attached PDF test data.
Thanks,
Jonathon, HMIC
From: Joe Cruse [mailto:jcruse@ccmetals.com]
Sent: Monday, March 9, 2020 1:01 PM
To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>
Cc: Daniela Rost <d.rost@ftamericas.com>; David Tuten <dtuten@ccmetals.com>
Subject: Request For Formal Letter of Interpretation On Hazmat Classification
Good afternoon,
I was referred to this email address by Josh, at the USDOT Hazmat Hotline. We are requesting a formal letter of
interpretation on the results of our testing of the Ferrosilicon products {Si >30% and <90% content ) we produce and
ship at CC Metals and Alloys, LLC in Calvert City, KY. This facility performed the testing, as prescribed for materials
classification in 49 CFR Section 173, Appendix E, Division 4 {Sections 1-4), in the 1990's, when the facility was owned by
VIAG, and was named SKW Metals and Alloys, Inc.
To give some background to our situation, the company produces Ferrosilicon at its single-site production facility in
Calvert City, KY, located on the banks of the Tennessee River. We ship our product to both domestic and foreign
locations via truck, railcar, barge, and sea container. In the mid-1990's, our company (as SKW Metals and Alloys, Inc.),
along with all of our other North American and European competitors, undertook a testing regimen of our Ferrosilicon
per 49 CFR Section 173, Appendix E, Division 4 {Sections 1-4). We performed all testing in-house, and also had a third
party laboratory perform the same testing, on our entire line of Ferrosilicon products. In all cases, our testing results (in-
house lab and third party lab) all demonstrated that none of our Ferrosilicon products met the criteria for classification
as "Hazardous When Wet" materials, per the criteria contained within 49 CFR, Section 173, Appendix E, Division 4. Our
competitors testing showed the same conclusions. At that point, we determined that our entire product line of
Ferrosilicon was not subject to HMR, as did our competitors. Today, this facility, as CC Metals and Alloys, LLC, still
produces those same Ferrosilicon products, under the same production methods and environment; there has been no
change to the composition or other aspects of the products we produce and ship here.
A short time ago, our company was approached by the US Coast Guard's Marine Safety Unit, based out of Paducah, KY,
to inquire as to why we ship our Ferrosilicon products from our river dock facility without the hazmat classification.
We've shared our testing results and our formal declaration of our product not meeting hazard class and that the
products are not subject to HMR. They are not satisfied with this, and are looking for some kind of formal response from
USDOT on our determination. In my phone conversation with the Hazmat Hotline, Josh suggested I contact you via email
on this matter. We are looking for some way to meet the local US Coast Guard MSU's request. I know that it is on the
Shipper to demonstrate that our products do not meet the criteria of Division 4.3 or other hazard classes, to show that
1

<<<PAGE 3>>>

they are not subject to the HMR. We believe we have successfully done so. We are asking USDOT to review our testing
results, and issue to us a formal letter of interpretation of our testing results that we can show to the US Coast Guard
MSU, and satisfy their request. We appreciate your help in this matter, and if you have any additional questions on this
matter, please do not hesitate to call or email me, per my contact information below.
Thank you,
Joe Cruse
Quality/Lab Mgr
CC Metals and Alloys, LLC
1542 North Main Street (PO Box 217}
Calvert City, KY 42029
270.395.2103 (Office)
270.703.8833 (cell)
2

<<<PAGE 4>>>

CRS Project Number: S-6747
January 27, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Dangerous When Wet Materials (as set forth in 49 CFR Section 173,
Appendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of 50% FeSi,
Regular, Lab ID: 2124A, Bin Number: 300.
Dear Mr. Hall:
We have completed our gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The material we received from
SKW was labeled as: 50% FeSi, Regular. The results were as follows:
(1) no gas was evolved and no spontaneous ignition occurred.
(2) no gas was evolved and no spontaneous ignition occurred.
(3) no gas was evolved and no spontaneous ignition occurred.
(4) while some gas did evolve, the average rate never exceeded 1 liter per
kilogram per hour in the sample tested. The gas was not flammable nor
did it spontaneously ignite in any of the tests.
On the basis of these test results, the ferrosilicon material listed above
would not fit the definition in 49 CFR Section 173, Appendix E, Division 4,
Sections 1, 2, 3 and 4 as "Dangerous When Wet" .
Sincerely,
~V\tt'_& le.. l~-- j \~ ~ - lL_. ~· 1"" V'~
Jam~s R. Lakin . ~j'l'X"'"'' ~] ksoc.ic.1
Business Operations Manager

<<<PAGE 5>>>

January 27, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P . O. Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Number: S-6747
Dear Mr. Hall:
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The identification of the
material submitted and its chemistry specification are listed below.
50% FeSi, Regular Al Si Cr Mn Ti Ca p
Specification, % : <1.25 47-51 <0.2 <0.75 <0.1 <0.3
Lab ID: 2124A
Bin Number: 300
Chemistry: 0.19 47.30 0.12 0.37 0. 041 0 . 00 0.030
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C. No gas evolution was observed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results)
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 20°C. No gas evolution was observed, nor
did the sample spontaneously ignite.
Section 3 (Procedure & Results)
A small pile with an indentation in the center, approximately 2cm high by 3cm
in diameter, was made of the material . A few drops of water were added to the
hollow. No gas evolution was observed, nor did any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of material submitted, and
using a hammer and chisel the pieces were crushed individually. The larger pieces
and the fines were screened off from each sample. Only material of +20 mesh to -8
mesh was used in the gas evolution tests. Three reaction vessels were set-up and
filled with a deionized water. The reaction vessels were 1000 ml beakers each
containing a small flask with 25.0 grams of sample material. Above each small
flask a 50 ml buret was positioned up-side-down, which was also filled with
deionized water and placed over the end of the flask making a water seal. The
level in the buret was monitored for the next 5 days. Gas evolution data, measured
in milliliters, is attached .
Following the gas evolution tests, the burets were submerged, still up-side-
down, up to the stopcocks in water. A small flame was placed near the tip of the

<<<PAGE 6>>>

Report S-6747
buret and the stopcock was opened to allow the gas inside the burets to be pushed
out into the flame by the water pressure. Flammability observations are noted at
the bottom of the gas evolution data . The gas was not analyzed to determine its
composition.
If you have questions about the test or these results please contact me.
Thank you for doing business with us.
Sincerely,
2 of 3

<<<PAGE 7>>>

Project S-6747 (sheet 3)
Gas Evolution Measurements
(Water Volume Displacement)
50% FeSi
1 2
(mil (mil
Avg Rate
3 (I/kg/hr)
Time
(hours)
Day 1 0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8.00
17.50
Day 2 26.00
41.50
Day 3 50.00
65.50
Day 4 89.50
Day 5 98.00
Flammable (Fl
lgnitible (I) *
Not Flammable (NF)
(ml)
0.0 0.0
0.0 0.0
0.0 0.0
0.0 0.0
0.0 0.0
0.0 0.0
0.1 0.1
0.1 0.1
0.1 0.1
0.1 1 . 1
0 .2 2.0
1.2 15.8
2 .3 23.3
3.4 32.3
9.3 44.8
11 .2 47.2
0.0
0.0 0.000
0.0 0.000
0.0 0.000
0 .0 0 .000
0 .0 0 .000
0.0 0.003
0.0 0.001
0 .0 0.000
0.2 0.002
1.0 0.003
4.2 0.015
7 .4 0.019
13.4 0.014
23.5 0.016
26 .3 0 .011
X X
X
* lgnitible = the gas will ignite but will not sustain a continuous flame.
3 of 3

<<<PAGE 8>>>

Ferrosilicon, 50%, Regular Grade
Specification Chemistry, %:
Al Si Cr
<1.25 47-51 <0.20
Mn
<0.75
Ti
<0.10
Ca
<0.30
p
Sample I.D. Number: 21248
Bin Number: 300
Observed Chemistry of Tested Sample, %:
Al Si Cr Mn
0.19 47.30 0.12 0.37
Ti
0.041
Ca
0.00
p
0.030
Test 1:
A small quantity (approximately 2 mm diameter) of the above material was
placed in a trough of distilled water at 20° C and observed to see whether any
gas evolved and if it spontaneously ignited. Test 1 was performed in triplicate
on the above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 1 was performed.
Test 2:
A small quantity (approximately 2 mm diameter) of the above material was
floated on a piece of filter paper in distilled water at 20° C and observed to see
whether any gas evolved and if it spontaneously ignited. Test 2 was performed
in triplicate on the above material.
Result:
Neither evolution of gas or spontaneous ignition was observed in any of the
three times Test 2 was performed.
Test 3:
The test material was formed into three piles approximately 2 cm high by 3 cm
wide. An indentation was formed in the top of each pile and a few drops of water
were added to each hollow. Each pile was observed to see whether any gas
evolved and if it spontaneously ignited. Test 3 was performed in triplicate on the
above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 3 was performed.

<<<PAGE 9>>>

Test 4:
Enough water at 20° C to cover the sample, 10ml to 20ml, was added to a
dropping funnel. The spout of the dropping funnel was inserted into one hole of
a #14, two-hole stopper; a tube for conveying any gas produced into the
collection cylinder, a gas buret, was inserted into the other hole of the stopper;
the far end of the tube was inserted into the end of the collection cylinder.
The gas buret is glass, 50 ml capacity, marked in individual ml units with each ml
subdivided into 0.1 ml increments. The gas buret was filled with water, inverted
and stood in a water trough. The gas tube in the previous paragraph was
inserted into the bottom end of the gas buret and any gas produced was
measured by observing the displacement of the water in the top of the buret.
25 g of the above listed material was added to each of three 100 ml conical
flasks with #14 neck size. The stoppers mentioned above were inserted into the
neck of the conical flasks. The stopcocks were opened and 10 ml to 20 ml of the
20° C distilled water, enough to completely cover the sample, was allowed to
flow into the flasks. A timer was started and readings of any gas evolved were
taken every hour for five days. From this data the average rate of gas
production per hour was calculated for the five days.
Result:
The Gas Collection data for Ferrosilicon, 50%, Regular Grade is detailed on the
following page:

<<<PAGE 10>>>

Gas Test on Regular Grade 50% FeSi January 24, 1996
!!_!!_.!!_!!_ :1::tt'll 0.0 0.0 0.0 0.000 t=tfH31: 0.4 0.1 0.3 0.000 n:n=:H61 0.7 0.4 0.7 0.000 :tt:tHil 0.7 0.8 0.7 0.000
tr:t:'t:Z o.o o.o o.o 0.000 l'®'tff~Z 0.4 0.1 o.3 0.000 MJJH~ti o.7 o.4 0.7 0.000 ?Wi@IZ 0.7 0.8 o.7 0.000
ttttt, o.o o.o o.o 0.000 tt=tr:aa o.4 0.1 o.3 0.000 tt=::noo 0.1 0.4 0.1 0.000 :=tttl9a. 0.1 o.8 0.1 0.000
<ttt<J o.o o.o o.o 0.000 t,ttta4' 0.4 0.1 o.3 0.000 tttam 0.1 o.6 0.1 0.003 ttt@M 0.1 o.8 0.1 0.000
k}It/5 0.0 0.0 0.0 0.000 ttt:/35 0.4 0.1 0.3 0.000 't@U\65. 0.7 0.6 0.7 0.000 i:=Mt:ss 0.7 0.8 0.7 0.000
■ g:g g : g g:g g:ggg lljlJl!J!Jl!:!:!!:!! g:: g: ~ g : i g : ggg /!
1
:!!!!i!!!!/i!!!! g:; g : i g:i g:ggg !i!!!i!i!!i/!
1
!:i!! g:; g:: g:; g:g~g
t't:l:ttj o.o o.o o.o 0.000 rrr:n3.9 0.4 0.1 o.3 0.000 1:n:t&s 0.1 o.6 0.1 0.000 :t:trrs.~ 0.1 o.8 0.1 0.000
tttMQ o.o o.o o.o 0.000 :::n,:nr~: 0.4 0.1 o.3 0.000 tttn10 0.1 o.6 0.1 0.000 :ttM:® 0.1 o.8 0.1 0.000
)'fth'U 0.0 0.0 0.0 0.000 =t'f'}4t 0.4 0.1 0.3 0.000 ttIH1l 0.7 0.6 0.7 0.000 ttm:nn: 0.7 0.8 0.7 0.000
:n't@1:Z 0.0 0.0 0.0 0.000 ='jf'tfAZ 0.5 0.2 0.4 0.004 ''@i'f':n 0.7 0.6 0.7 0.000 Mttl~ 0.7 0.8 0.7 0.000
tttf/11 o.o o.o o.o 0.000 =ttt:=43. 0.5 0.2 0.4 0.000 tttft3 0.7 o.6 o.7 0.000 JK/10:l 0.7 0.8 0.7 0.000
::tt\'14 o.o o.o o.o 0.000 Jttt'M 0.5 0.2 0.4 0.000 =ItfF14. 0.7 0.6 o.7 0.000 ttflQ4' 0.7 0.8 o.7 0.000
tttn5 o.o o.o o.o 0.000 '==tt=t'45 o.5 0.2 o.4 0.000 tJI''fta 0.1 o.6 0.1 0.000 tt:nies 0.1 o.8 0.1 0.000
tttt:1~ o.o o.o o.o 0.000 :::rt::'4~ o.5 0.2 o.5 0.001 ::t::tr:~ 0.1 o.6 0.1 0.000 :rtr,:o.~ 0.1 o.8 0.1 0.000
itit@11 o.o o.o o.o 0.000 tti'A:4t o.5 0.2 0.5 0.000 f,,fttt o.7 0.6 0.7 0.000 t=t'iittl:t 0.7 0.8 o.7 0.000·
i'Htn'1~ o.o o.o o.o 0.000 l'\Hiffl o.5 0.2 o.5 0.000 W'\f1~ o.7 o.6 o.7 0.000 ,tfMQ&.: 0.7 o.8 o.7 0.000_
=::td9 o.o o.o o.o 0.000 ,rtt@W 0.6 o.3 o.5 0.003 ,fff~ 0.7 o.6 0.7 0.000 :ttM®.: 0.7 0.8 0.7 0.000
.
1 :::1,::t® o.o o.o o.o 0.000 :r::r,r:®.' o.6 o.3 o.5 0.000 m:tmtao. 0.1 o.6 0.1 0.000 t'tt11n 0.1 o.8 0.1 0.000_
=t:'t2.1: o.o o.o o.o 0.000 t::nt:51' o.6 o.3 o.5 0.000 ttrta1 0.1 o.6 0.1 0.000 :n:ra1:t 0.1 o.8 0.1 0.000
ritttt2:z: o.o o.o o.o 0.000 mmt@ft~ o.6 o.3 o.5 0.000 tftffijJ: 0.1 o.6 o.7 0.000 @rrrrtti 0.1 a.a 0.1 0.000·
c,tttz3 o.o o.o o.o 0.000 tr:rmsa o.6 o.3 o.5 0.000 ,:r::t:nm 0.1 o.6 0.1 0.000 n,ttft:a 0.1 o.8 0.1 0.000.
im::t=:ti4 0.0 0.0 0.0 0.000 :=t:=%tS4' 0.6 0.3 0.5 0.000 ttt::~4 0.7 0.6 0.7 0.000 =t=t\1:14 0.7 0.8 0.7 0.000_
t')H25 0.0 0.0 0.0 0.000 tt::t=,':os 0.6 0.3 0.5 0.000 l:ff'f'85. 0.7 0.6 0.7 0.000 )Fl11S. 0.7 0.8 0.7 0.000
t\Jttt?6: 0.2 o .o o.o 0.003 ;ffttf$.6\ 0.6 o.3 o.s 0.000 ff{fI~- 0.7 a.a 0.7 0.003 tttf1l1!&. o.7 o.a 0.7 0.000·
:t=ttzt 0.2 o.o o.o 0.000 tt?ts.t 0.6 o.3 o.5 0.000 l?tJ:W: 0.7 o.8 o.7 0.000 =tt:Mift o.7 0.8 o.7 0.000
.
=ItFi$ 0.3 o.o 0.2 0.004 ::tt?''~ 0.6 0.3 0.5 0.000 :::'ttdffl 0.7 0.8 0.7 0.000 t:'IM1tl 0.7 0.8 o.7 0.000_
:nt=t29 0.4 0.1 o.3 0.004 :Jt:ttS:t 0.1 0.4 0.1 0.005 :,:ntt'a9. 0.1 o.8 0.1 0.000 tJ't11\l 0.1 o.a 0.1 0.000.
::tL't® 0.4 0.1 o.3 0.000 =ltttl!lQ 0.7 0.4 o.7 0.000 Ltftm) 0.7 o.8 0.7 0.000 ft=t1w: 0.7 o.8 0.7 0.000
1. All samples 25 gram.
2.Average rate of gas production in UKg/Hr=Avg produced(ml)x40/1000ml/L OOTSOREG.XLS

<<<PAGE 11>>>

CRS Project Number: S-6747
January 27, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Dangerous When Wet Materials (as set forth in 49 CFR Section 173,
Appendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of 75% FeSi,
Regular, Lab ID: 2125A, Bin Number: 14 Fee.
Dear Mr. Hall:
We have completed our gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The material we received from
SKW was labeled as: 75% FeSi, Regular. The results were as follows:
(1) no gas was evolved and no spontaneous ignition occurred.
(2) no gas was evolved and no spontaneous ignition occurred.
(3) no gas was evolved and no spontaneous ignition occurred.
(4) while some gas did evolve, the average rate never exceeded 1 liter per
kilogram per hour in the sample tested. The gas was flammable and
ignitible (gas ignited but would not sustain a continuous flame). It
did not spontaneously ignite in any of the tests.
On the basis of these test results, the ferrosilicon material listed above
would not fit the definition in 49 CFR Section 173, Appendix E, Division 4,
Sections 1, 2, 3 and 4 as "Dangerous When Wet".
Sincerely,
~wti g_ L.-'"1J.i~ I bJ
James R. Lakin
Business Operations
~£\tLl ,c L -1'\'\ ~v. ~s:§
Ev-g-~• e;,\.~J /\¼ocJ.:,1
Manager

<<<PAGE 12>>>

January 27, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P . O. Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Number: S-6747
Dear Mr. Hall :
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173 , Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996 . The identification of the
material submitted and its chemistry specification are listed below.
75% FeSi, Regular Al Si Cr Mn Ti Ca p
Specification, %-: <1.50 74-79 <0.3 <0.4 <0.2 <0.6
Lab ID: 2125A
Bin Number: 14 Fee
Chemistry : 0.054 76.30 0.06 0.19 0.052 0.41 0.013
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C. No gas evolution was observed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results)
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 20°C. No gas evolution was observed, nor
did the sample spontaneously ignite.
Section 3 (Procedure & Results)
A small pile with an indentation in the center, approximately 2cm high b y 3cm
in diameter, was made of the material. A few drops of water were added to the
hollow. No gas evolution was observed, nor did any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of material submitted, and
using a hammer and chisel the pieces were crushed individually. The larger pieces
and the fines were screened off from each sample. Only material of +20 m esh to -8
mesh was used in the gas evolution tests. Three reaction vessels were set-up and
filled with a deionized water. The reaction vessels were 1000 ml beakers each
containing a small flask with 25.0 grams of sample material. Above each small
flask a 50 ml buret was positioned up-side-down, which was also filled with
deionized water and placed over the end of the flask making a water seal. The
level in the buret was monitored fo r the next 5 days. Gas evolution data, measured
in milliliters, is attached.
Following the gas evolution tests, the burets were submerged, still up-side-
down, up to the stopcocks in water . A small flame was placed near the tip of the

<<<PAGE 13>>>

Report S-6747
buret and the stopcock was opened to allow the gas inside the burets to be pushed
out into the flame by the water pressure. Flammability observations are noted at
the bottom of the gas evolution data. The gas was not analyzed to determine its
composition.
If you have questions about the test or these results please contact me.
Thank you for doing business with us.
Sincerely,
j (i,tr/V,_e<;. e. La.b,., I 6J ~l2lt,e- 'l' -W~o-t\,~ . .. ' . ' .
. G"'~; N cr \V-\.''l l\~soc,o., k.
Jam7s R. Lakin . 0 · · ,_J
Business Operations Manager
2 of 3

<<<PAGE 14>>>

Project S-6747 (sheet 4)
Gas Evolution Measurements
(Water Volume Displacement)
75% FeSi
2
(ml) (ml)
Avg Rate
3 (I/kg/hr)
Time
(hours)
Day 1 0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8.00
17.50
Day 2 26.00
41 .50
Day 3 50.00
65.50
Day 4 89.50
Day 5 98.00
Flammable (F)
lgnitible (I)*
Not Flammable (NF)
(ml)
0.0 0.0
0.2 0.2
0.4 0.5
0.8 0.6
1.0 1.0
1.3 0.8
1.4 0.9
1.2 1.3
2.1 1.3
4.4 3.6
6.5 5.3
9.1 11 . 1
11.4 15.8
15.4 22.7
18.0 34.0
20.1 36.1
X X
0.0
0.3 0.009
0.5 0.009
0.8 0.011
1.6 0 .019
1 . 1 -0.005
1.5 0.008
1.8 0.007
2.0 0.011
6.1 0.012
8.0 0 .009
16.2 0 .014
26.1 0.027
34.6 0.017
46.6 0.014
48.7 0.010
X
* lgnitible = the gas will ignite but will not sustain a continuous flame.
3 of 3

<<<PAGE 15>>>

Ferrosilicon, 75%, Regular Grade
Specification Chemistry, %:
Al Si Cr
<1.5 74-79 <0.30
Mn
<0.40
Ti
<0.20
Ca
<0.60
p
Sample I.D. Number: 2125A
Bin Number: 14 Fee
Observed Chemistry of Tested Sample, %:
Al Si Cr Mn
0.05 76.30 0.06 0.19
Ti
0.052
Ca
0.41
p
0.013
Test 1:
A small quantity (approximately 2 mm diameter) of the above material was
placed in a trough of distilled water at 20° C and observed to see whether any
gas evolved and if it spontaneously ignited. Test 1 was performed in triplicate
on the above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 1 was performed.
Test 2:
A small quantity (approximately 2 mm diameter) of the above material was
floated on a piece of filter paper in distilled water at 20° C and observed to see
whether any gas evolved and if it spontaneously ignited. Test 2 was performed
in triplicate on the above material.
Result:
Neither evolution of gas or spontaneous ignition was observed in any of the
three times Test 2 was performed.
Test 3:
The test material was formed into three piles approximately 2 cm high by 3 cm
wide. An indentation was formed in the top of each pile and a few drops of water
were added to each hollow. Each pile was observed to see whether any gas
evolved and if it spontaneously ignited. Test 3 was performed in triplicate on the
above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 3 was performed.

<<<PAGE 16>>>

Test 4:
Enough water at 20° C to cover the sample, 10 ml to 20 ml, was added to a
dropping funnel. The spout of the dropping funnel was inserted into one hole of
a #14, two-hole stopper; a tube for conveying any gas produced into the
collection cylinder, a gas buret, was inserted into the other hole of the stopper;
the far end of the tube was inserted into the end of the collection cylinder.
The gas buret is glass, 50 ml capacity, marked in individual ml units with each ml
subdivided into 0.1 ml increments. The gas buret was filled with water, inverted
and stood in a water trough. The gas tube in the previous paragraph was
inserted into the bottom end of the gas buret and any gas produced was
measured by observing the displacement of the water in the top of the buret.
25 g of the above listed material was added to each of three 100 ml conical
flasks with #14 neck size. The stoppers mentioned above were inserted into the
neck of the conical flasks. The stopcocks were opened and 10 ml to 20 ml of the
20° C distilled water, enough to completely cover the sample, was allowed to
flow into the flasks. A timer was started and readings of any gas evolved were
taken every hour for five days. From this data the average rate of gas
production per hour was calculated for the five days.
Result:
The Gas Collection data for Ferrosilicon, 75
%, Regular Grade is detailed on the following page:

<<<PAGE 17>>>

Gas Test on Regular Grade 75% FeSi
January 24, 1996
Avg
Avg
Avg
Avg
Rime
2
3
Rate
Jime
Rate
time
Rate
rime
Rate
Hr.
mil
(ml)
(ml)
L/Ka/Hr
(ml)
(ml)
(ml)
LIKa/Hr
(iml)
(ml
0.1
(ml).
L/Kg/Hr
Hr.
(m)
0.
0
0.0
0.
0.000
31
0.7
0.6
1.0
0.009
61
1.9
2.2
0.000
(ml)
(ml)
1.9
0.1
2.2
L/Kg/Hr
91
0.000
2
0.
0.
0.
0,000
32
0.7
0.1
1.1
-0.005
62
1.9
0.1
2.2
0,000
92
1.9
0.1
2.2
0.000
3
0
0.000
1.0
0.1
1.2
0.005
63
1.9
0.1
2.2
0.000
93
1.9
0.1
2.2
0.000
0.
000
34
1.1
0.1
1.3
0.003
64
1.9
0.1
2.2
0.000
94
1.9
0.1
2.2
0,000
GOO
35
1.2
0.1
1.5
0,004
65
1.9
0.
1
2.2
0,000
95
1.9
0.
2.2
0.000
00
36
1.4
0.1
1.7
0.005
66
1.9
0.1
2.2
0.000
-96
1.9
0.1
2.2
0.000
0
00O
37
1.6
0.1
1.8
0.004
67
1.9
0.1
2.2
0.000
97
1.9
0.1
2.2
0.000
000
38
1.7
0.1
1.9
0.003
68
1.9
0.
2.2
0,000
98
1.9
0.
1
2.2
0,000
0.0
39
1.7
0.1
2.0
0.001
69
1.9
0.1
2.2
0.000
99
1.9
0.1
2.2
0.000
10:
000
40
1.9
0.1
2.1
0.004
70
1.9
0.1
2.2
0.000
100
1.9
0.1
2.2
0.000
000
41
1.9
0.1
2.2
0.001
71
1.9
0.1
2.2
0.000
101
1.
.9
0.
1
2.2
0.000
12
.000
42
1.9
0.1
2.2
0.000
12
1.9
0.1
2.2
0.000
102
1.9
0.1
2.2
0.000
0.
000
1.9
0.1
2.2
0.000
79
1.9
0.1
2.2
0.000
104
103
1.9
0.1
2.2
0.000
0.0
0.0
0,000
1.9
0.1
2.2
0.000
1.9
0.1
0.000
0,000
0.
.0
0.0
.0
0.000
1.9
0.1
2.2
0.000
1.9
0.1
0.000
105
1
0.000
0.
.0
0.
000
0.1
2.2
0.000
1.9
0.1
2.2
0,000
.9
0.
2.
2
0,000
0.
0.
000
1.
0.1
2.2
0.000
1.9
0.1
2.2
0.000
07
1
.9
0.
2
0.000
0.
000
0.1
2.2
0.000
78
1.9
0.1
2.2
0.000
188
0
1
2.
2
000
0.
0
000
0.
1
2.2
0,000
79
1.9
0.1
2.2
0,000
0.
2
2
0.
.000
1.
9
2.2
0.000
80
1.9
0.1
2.2
0.000
0.
2
2
000
1.
9
1
2.2
0.000
100
1.
9
2.2
0.000
81
1.9
0.1
2.
2
0.000
82
1.9
0.1
2.2
1.000
0.0
0.000
1.9
0.
1
2.
2
0.000
1.9
0.1
2.2
0.
.000
0,000
0.0
0.0
988888888888
0.000
1.9
1
2.2
0.000
1.9
0.1
2.2
aLla
0.000
0.000
1.9
0.1
2.2
0.000
1.9
0.1
2.2
0.000
0.0
0.3
0.004
1.
9
0.
2.2
0.000
86
1.9
0.1
2.2
0.
.1
2.2
0.000
0.0
0.4
0.001
1.
9
0.1
2.2
0.000
67]
1.9
0.1
2.2
17
0.
1
2.2
0.2
0.5
0.004
1
9
0.1
2.2
0.000
88.
1.9
0.1
2.2
118
0
1
2.2
0.5
0.7
0.008
1
.9
0.
.1
2.2
0.000
0.6
0.9
0.004
1.
.9
1
2.2
0.000
38
1.
.9
0.1
2.2
0.000
119
0.
1
2.2
0.000
1.
0.1
2.2
0.000
120
0.
2.2
0.000
1. All samples 25 gram.
2. Average rate of gas production in L/Kg/Hr=Avg produced(ml)x40/1000m/L
DOT75REG.XLS

<<<PAGE 18>>>

CRS Project Number: S-6747
January 27, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Dangerous When Wet Materials (as set forth in 49 CFR Section 173,
Appendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of CSF 10, Lab ID:
2130A, Bin Number: 312.
Dear Mr. Hall:
We have completed our gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections I, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The material we received from
SKW was labeled as: CSF 10. The results were as follows:
(1) no gas was evolved and no spontaneous ignition occurred.
(2) no gas was evolved and no spontaneous ignition occurred.
(3) no gas was evolved and no spontaneous ignition occurred.
(4) while some gas did evolve, the average rate never exceeded 1 liter per
kilogram per hour in the sample tested. The gas was not flammable but
was ignitible (gas ignited but would not sustain a continuous flame).
It did not spontaneously ignite in any of the tests.
On the basis of these test results, the ferrosilicon material listed above
would not fit the definition in 49 CFR Section 173, Appendix E, Division 4,
Sections I, 2, 3 and 4 as "Dangerous When Wet".
Sincerely,
'i~·WWJ i. ~E,k; .. , I bj ~~-( (:- . ~ , 1M~/i~)E:
James R. Lakin ~i,¼?L-'r; ,.._)A. • '.
Business Operations Manager n~~Dc\ttl2

<<<PAGE 19>>>

January 27, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P . O. Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Number: S-6747
Dear Mr. Hall:
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The identification of the
material submitted and its chemistry specification are listed below.
CSF 10 Al Si Ce TRE
Specification, % : <1.5 50-55 9-11 10.5-15
Lab ID: 2130A
Bin Number: 312
Chemistry: 0.47 37.90 9 . 65 10.76
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C. No gas evolution was observed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results)
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 20°C. No gas evolution was observed, nor
did the sample spontaneously ignite.
Section 3 (Procedure & Results)
A small pile with an indentation in the center, approximately 2cm high by 3cm
in diameter, was made of the material. A few drops of water were added to the
hollow. No gas evolution was observed, nor did any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of material submitted, and
using a hammer and chisel the pieces were crushed individually . The larger pieces
and the fines were screened off from each sample . Only material of +20 mesh to -8
mesh was used in the gas evolution tests. Three reaction vessels were set-up and
filled with a deionized water. The reaction vessels were 1000 ml beakers each
containing a small flask with 25.0 grams of sample material. Above each small
flask a 50 ml buret was positioned up-side-down, which was also filled with
deionized water and placed over the end of the flask making a water seal. The
level in the buret was monitored for the next 5 days . Gas evolution data, measured
in milliliters, is attached .
Following the gas evolution tests, the burets were submerged, still up-side-
down, up to the stopcocks in water. A small flame was placed near the tip of the

<<<PAGE 20>>>

Report S-6747
buret and the stopcock was opened to allow the gas inside the burets to be pushed
out into the flame by the water pressure. Flammability observations are noted at
the bottom of the gas evolution data. The gas was not analyzed to determine its
composition.
If you have questions about the test or these results please contact me.
Thank you for doing business with us.
Sincerely,
2 of 3 ·

<<<PAGE 21>>>

Project S-6747 (sheet 6)
Gas Evolution Measurements
(Water Volume Displacement)
CSF 10
2 3
(ml) (ml) (ml)
Avg Rate
(I/kg/hr)
Time
(hours)
Day 1 0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8 .00
Day 2 22.25
Day 3 46.25
54.75
Day 4 70.25
Day 5 98.75
0.0 0.0 0.0
0.1 0.1 0.1
0.1 0 .1 0.3
0 .2 0.2 1 . 1
0.2 0.2 1.2
0.2 0 .3 3.1
0.2 0.4 5.8
0.3 0.9 7.3
0.3 0.9 7.5
0.8 1.2 22.2
4.0 34.8 46.3
5.4 39.2 48.2
8.1 44.3 50.0
13.8 49.8 50.0
0.004
0.003
0.013
0.001
0.027
0.037
0.033
0.015
0.015
0.034
0.012
0.008
0.005
Flammable (F)
lgnitible (I)*
Not Flammable (NF)
X
X X
* lgnitible = the gas will ignite but will not sustain a continuous flame.
3 of 3

<<<PAGE 22>>>

CSF-10
Specification Chemistry, %:
~ Si Ce
<1.50 35-40 9-11
TRE
10.5-15
Sample I.D. Number: 21308
Bin Number: 312
Observed Chemistry of Tested Sample,%:
Al Si Ce TRE
0.19 37.90 9.65 10.76
Test 1:
A small quantity (approximately 2 mm diameter) of the above material was
placed in a trough of distilled water at 20° C and observed to see whether any
gas evolved and if it spontaneously ignited. Test 1 was performed in triplicate
on the above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 1 was performed.
Test 2:
A small quantity ( approximately 2 mm diameter) of the above material was
floated on a piece of filter paper in distilled water at 20° C and observed to see
whether any gas evolved and if it spontaneously ignited. Test 2 was performed
in triplicate on the above material.
Result:
Neither evolution of gas or spontaneous ignition was observed in any of the
three times Test 2 was performed.
Test 3:
The test material was formed into three piles approximately 2 cm high by 3 cm
wide. An indentation was formed in the top of each pile and a few drops of water
were added to each hollow. Each pile was observed to see whether any gas
evolved and if it spontaneously ignited. Test 3 was performed in triplicate on the
above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 3 was performed.

<<<PAGE 23>>>

Test 4:
Enough water at 20° C to cover the sample, 10ml to 20ml, was added to a
dropping funnel. The spout of the dropping funnel was inserted into one hole of
a #14, two-hole stopper; a tube for conveying any gas produced into the
collection cylinder, a gas buret, was inserted into the other hole of the stopper;
the far end of the tube was inserted into the end of the collection cylinder.
The gas buret is glass, 50 ml capacity, marked in individual ml units with each ml
subdivided into 0.1 ml increments. The gas buret was filled with water, inverted
and stood in a water trough. The gas tube in the previous paragraph was
inserted into the bottom end of the gas buret and any gas produced was
measured by observing the displacement of the water in the top of the buret.
25 g of the above listed material was added to each of three 100 ml conical
flasks with #14 neck size. The stoppers mentioned above were inserted into the
neck of the conical flasks. The stopcocks were opened and 10ml to 20ml of the
20° C distilled water, enough to completely cover the sample, was allowed to
flow into the flasks. A timer was started and readings of any gas evolved were
taken every hour for five days. From this data the average rate of gas
production per hour was calculated for the five days.
Result:
The Gas Collection data for CSF-10 is detailed on the following page:

<<<PAGE 24>>>

Gas Test on CSF-10
January 24, 1996
Avg
Avg
Avg
Avg
Time
Rate
Jime
Rate
ime
Rate
Time
Rate
(ml)
(ml)
L/Kg/Hr
Hr.
(m)
(mi)
(ml)
L/Kg/He
Hr.
(mi)
0.0
(ml)
(ml)
Hr.
(ml)
(ml)
(ml)
L/Kg/Hr
0.
0.0
1.
.0
0.013
31
0.0
0.0
1.0
0.000
61
0.0
4.0
0.000
81
0.0
0.0
4.0
0.000
0.
0
. 0
0.000
3
12
0.0
0.0
1.0
0.000
62
0.0
0.
4.0
0,000
92
0.0
0.0
4.0
0,000
LO
0
0
.0
0,000
33
0.
0.0
1.0
0.000
63
0.0
0.
4.0
0.000
93
0.0
0.
.0
4.0
0.000
0.
0
1.
.0
0.000
34
0.
0.0
1.0
0.000
64
0.0
4.0
0.000
94
0.0
0.
4.0
0.000
1.0
0.
000
35
1.
0.000
65
4.
0,000
95
0
0.
4.0
0.000
1.0
0.000
36
2.0
0.013
66
0.000
96
0
0.
4.0
0.000
0.
.000
37
2
.0
0.000
67
0.000
97
0.
.0
0.
4.0
0.000
0.
.000
38
0,000
68
0.000
98
0.
4.0
0,000
.0
0.
000
0.000
69
0,000
99
.0
0.
4.0
0,000
1.0
0.
000
40
0,000
70
0,000
100
0.0
0.
4.0
0,000
.0
0.
000
41
0.013
0.000
101
0.0
0.
0
4.0
0.000
O.
.0
.0
0,000
42
3.
0.000
12
0
0
4.
0
0.000
102
0.0
0.
.0
4.0
0,000
0.
0
0
1.
.0
0.000
43
3.0
0.000
73
0.0
4.0
0,000
103
0.0
0.0
4.0
0.000
0.000
0.0
0.0
3.0
0.000
0.0
0.0
4.0
0.000
104
0.0
0.000
0.
0.
0.000
0.
0.000
0.0
0.
4.0
0.000
105
0.0
0.000
0.
.0
0
0
0.
000
4
.0
0.
0
.000
0.
0.
.0
.0
4.0
0
100
0.
.0
0
0.000
47
0.
.0
0
.0
3
0
0.
.000
0.
0.
4.
0
0.
10
107
.0
0
0.
.000
48
.0
0.C
3
0
0.
,000
0.
4.
000
10€
0.
.0
1.0
0.
000
49
0,000
79
0
4
00
109
4
0.
0
0.000
3
0.000
80
0
.0
4.
0
00
0
0.
000
0.0
0.013
.0
4.1
0
.00
0O
.O
0.000
0.0
0.
.000
4.
DO
0.0
0.0
1.0
0.000
4.
.000
0.
4.
0
.00
0
0.000
0.0
1.0
0.000
4.
00o
0.
0.
4.
.00
88
0.
0.000
0.0
0.
.0
0.000
4
0.
0.0
4
0.00
115
0.
0.000
0.0
.0
0,000
.0
0.
.000
0.0
.0
4.
0
0.000
116
0.
coo
0.000
0.0
0.
.0
0.000
0
4.
0.
.000
0.
0
4.0
0.000
117
888
0.
0.000
0.0
U
0.000
0.
0.0
4
0.
.000
4.
0
0.000
118
0.
.0
0.000
0.0
0.0
88
0.000
0.
1.0
0.0
4.
00°
4.
0.
0.000
0.
.0
0.
.0
0.
000
0.
.0
4.
0.000
10419
0.
. 0
4.
0.
.0
4.
• 0
0.000
4.0
0.000
120
0.000
1. All samples 25 gram.
2.Average rate of gas production in L/Kg/Hr=Avg produced(ml)x40/1000ml/L
DOTCSF10.XLS

<<<PAGE 25>>>

CRS Project Number: s-6747
February 5, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Dangerous When Wet Materials (as set forth in 49 CFR Section 173,
Appendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of FeSi Dross, Lab
ID: 2124A, Bin Number: 300.
Dear Mr. Hall:
We have completed our gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996 . The material we received from
SKW was labeled as: FeSi Dross. The results were as follows:
(1) no gas was evolved and no spontaneous ignition occurred.
(2) no gas was evolved and no spontaneous ignition occurred.
(3) no gas was evolved and no spontaneous ignition occurred.
(4) while some gas did evolve, the average rate never exceeded 1 liter per
kilogram per hour in the sample tested. The gas was not flammable, but
was ignitible (gas ignited but would not sustain a continuous flame).
It did not spontaneously ignite in any of the tests.
On the basis of these test results, the ferrosilicon material listed above
would not fit the definition in 49 CFR Section 173, Appendix E, Division 4,
Sections 1, 2, 3 and 4 as II Dangerous When Wet" .
Sincerely,
-1~{ R . ~ / bJ ~W:i \_ ,'i
_ vtou,i~ . ,
. &-~1r,ff- n •'uo"\ l\s..s.oc .a,~
James R. Lakin 'j ~
Business Operations Manager

<<<PAGE 26>>>

February 5, 1997
Mr . Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Number: S-6747
Dear Mr. Hall:
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The identification of the
material submitted and its chemistry specification are listed below.
FeSi Dross
Specification, %:
Lab ID: 2124A
Bin Number: 300
Chemistry:
Si
35-45
40. 6
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C . No gas evolution was observed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results )
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 20°C. No gas evolution was observed, nor
did the sample spontaneously ignite.
Section 3 (Procedure & Results)
A small pile with an indentation in the center, approximately 2cm high by 3cm
in diameter, was made of the material. A few drops of water were added to the
hollow . No gas evolution was observed, nor did any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of material submitted, and
using a hammer and chisel the pieces were crushed individually. The larger pieces
and the fines were screened off from each sample. Only material of +20 mesh to -8
mesh was used in the gas evolution tests. Three reaction vessels were set-up and
filled with a deionized water . The reaction vessels were 1000 ml beakers each
containing a small flask with 25.0 grams of sample material. Above each small
flask a 50 ml buret was positioned up-side-down, which was also filled with
deionized water and placed over the end of the flask making a water seal . The
level in the buret was monitored for the next 5 days. Gas evolution data, measured
in milliliters, is attached.
Following the gas evolution tests, the burets were submerged, still up-side-
down, up to the stopcocks in water. A small flame was placed near the tip of the

<<<PAGE 27>>>

Report S-6747
buret and the stopcock was opened to allow the gas inside the burets to be pushed
out into the flame by the water pressure. Flammability observations are noted at
the bottom of the gas evolution data. The gas was not analyzed to determine its
composition.
If you have questions about the test or these results please contact me.
Thank you for doing business with us.
Sincerely,
2 of 3

<<<PAGE 28>>>

Project S-674 7 (sheet 13)
Gas Evolution Measurements
(Water Volume Displacement)
FeSi Dross
1 2
(mil (ml)
Avg Rate
3 (I/kg/hr)
Time
(hours)
Day 1 0.00
1.00
2.00
3.00
4.00
5.00
6.00
Day 2 21.00
29 .50
Day 3 45.00
53.50
Day 4 69 .00
77.50
Day 5 93.00
101.50
(ml)
0.0 0.0
0.1 0.2
0.1 0 .2
0.1 0 .3
0.2 0.5
0.2 0.6
0.3 0.8
0.3 5.7
0.4 11. 7
0.4 26.6
0.4 31.8
0.9 38.7
1.6 42.6
3.0 46.8
3.5 48.3
0.0
0.2 0.007
0.2 0 .000
0.3 0.003
0.2 0.003
0 .3 0.003
0.4 0 .005
1 . 1 0 .005
2.0 0 .011
3.7 0.014
4.7 0.010
7.5 0.009
9.7 0 .011
13.6 0.008
15.2 0.006
Flammable (Fl
lgnitible (I)*
Not Flammable (NF)
X
X
X
* lgnitible = the gas will ignite but will not sustain a continuous flame . .
3 of 3

<<<PAGE 29>>>

Silicon Dross
Specification Chemistry, %:
Si
35-45
Sample I.D. Number: 21728
Stockpile Number: 1-D
Observed Chemistry of Tested Sample, %:
Si
40.60
Test 1:
A small quantity (approximately 2 mm diameter) of the above material was
placed in a trough of distilled water at 20° C and observed to see whether any
gas evolved and if it spontaneously ignited. Test 1 was performed in triplicate
on the above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 1 was performed.
Test 2:
A small quantity (approximately 2 mm diameter) of the above material was
floated on a piece of filter paper in distilled water at 20° C and observed to see
whether any gas evolved and if it spontaneously ignited. Test 2 was performed
in triplicate on the above material.
Result:
Neither evolution of gas or spontaneous ignition was observed in any of the
three times Test 2 was performed.
Test 3:
The test material was formed into three piles approximately 2 cm high by 3 cm
wide. An indentation was formed in the top of each pile and a few drops of water
were added to each hollow. Each pile was observed to see whether any gas
evolved and if it spontaneously ignited. Test 3 was performed in triplicate on the
above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 3 was performed.

<<<PAGE 30>>>

Test 4:
Enough water at 20° C to cover the sample, 10ml to 20ml, was added to a
dropping funnel. The spout of the dropping funnel was inserted into one hole of
a #14, two-hole stopper; a tube for conveying any gas produced into the
collection cylinder, a gas buret, was inserted into the other hole of the stopper;
the far end of the tube was inserted into the end of the collection cylinder.
The gas buret is glass, 50 ml capacity, marked in individual ml units with each ml
subdivided into 0.1 ml increments. The gas buret was filled with water, inverted
and stood in a water trough. The gas tube in the previous paragraph was
inserted into the bottom end of the gas buret and any gas produced was
measured by observing the displacement of the water in the top of the buret.
25 g of the above listed material was added to each of three 100 ml conical
flasks with #14 neck size. The stoppers mentioned above were inserted into the
neck of the conical flasks. The stopcocks were opened and 1 0 ml to 20 ml of the
20° C distilled water, enough to completely cover the sample, was allowed to
flow into the flasks. A timer was started and readings of any gas evolved were
taken every hour for five days. From this data the average rate of gas
production per hour was calculated for the five days.
Result:
The Gas Collection data for Silicon Dross is detailed on the following page:

<<<PAGE 31>>>

Gas Test on
Si
Dross
January 24, 1996
Avg
Avg
Ava
Avg
asme
Rate
Time
Rate
ime
Rate
R
kite
SHr.
(mi)
0.
0
(mi)
(mi
LIKa/Hr
CHr.
0.
0,000
Ami
0.
.0
(Imi
UKallr
Hra
(m))
(ml)
(mi
LKg/Hr
Ht.
(ml)
(ml)
L/Kg/Hr
31
0.
.0
0.3
0.000
61
1.7
2.3
0.000
91
2.1
0.0
2.
4
0.000
2
0.
0.
0.
0,000
2
0.
0.
0.000
6.
1.
2.3
0.001
92
2.1
0.0
2.
4
0.000
0.
0.
0
0.000
0.
0.
.3
0.000
1.
9
0.
2.3
0.001
93
2.1
0.0
2.4
0.000
0.
0.
0.000
34
0.000
64
2.
0.
2.3
0.001
94
2.1
0.0
2.4
0.000
5
0.000
3
5
0.001
65
2.0
0.
.0
2.3
0.000
95
2.1
0.0
2.4
0.000
6
0,000
36
0,000
2.
0
0.
2
3
0,000
96
2.1
2
4
0,000
0.000
37
0.
.000
67
2.0
0.
2.
.3
0.000
197
2.1
.0
2.
4
0.000
8
0,000
38
000
68
2.0
0.000
98
2.1
0
2.
.4
0.000
0,000
39
000
69
2.
0.000
99
2.1
2
0.000
0,000
40
0.
.000
70
2.
0
0
.0
2
0.000
100
2.1
0.000
0.000
41
0,000
2.
0.
2.
3
0.000
101
2.1
.0
2
4
0.000
2
0,000
42
0.
.0
0.000
2.
0
0.003
102
2.1
0.0
2.
.4
0.000
0
0.000
43
0.
.0
0
0
0,000
0.
.0
2.4
0,000
103
2.1
0.0
2.4
0.0
2.4
0.000
104
0.000
4
0
0
0.000
44
.0
0.000
74
2.1
0.0
2.4
0.000
0
0
0,000
0
.0
0.0
.5
0.001
0.0
2
.4
0,000
105
2.1
0.0
2.
.4
0.000
0.
.0
0.
.0
0.000
0.0
0.0
0
.5
0.000
0.0
2.4
0.000
106
2.1
0.0
2
1.4
0.000
00
0
0
0
0
5
0,000
2.
0.0
2
4
0.000
107
2.1
0
.0
4
0.000
0
5
0,000
2.
0.
.0
2
0,000
108
2.1
.0
2
4
0.000
19
0
7
0.003
2.
1
0
2.
0.000
109
2.1
2
0.000
20
0
0
0
7
0,000
80
2.1
0.0
2.4
0.000
110
2.1
0
4
0,000
104
0
0
.0
0
0.000
81
2.
1
0.0
2
4
0.000
2.1
NiNN
4
000
00
0.0
1
.5
0.031
82
2.1
0.0
2.4
0,000
112
2.1
0.0
0.000
2.2
0.009
0.003
83
2.1
0.000
1113
2.1
1.0
0.0
0.0
0.000
1.6
0.0
2.3
84
2.1
0.0
0.000
114
2.1
0.0
2.4
2000
0.0
0.0
0.000
1.6
0.I
0
2.3
0.000
85
2.1
0.0
2.4
0.000
115
2.1
0.0
2.4
0.000
0.0
0.0
0.000
1.6
0.0
2.3
0.000
86
2.1
0.0
2.4
0.000
116
2.1
0.0
2.4
0.000
0.0
0.0
0.000
1.6
0.0
2.3
0.000
87
2.1
0.0
2.4
0.000
117
2.1
0.0
2.4
0.000
0.0
0.0
0.000
1.7
0.
.0
2.3
0.001
88
2.1
0.0
2.4
0.000
118
2.1
0.0
2.4
0.000
0.0
0.000
59
1.7
0.
NIN
m'm
0.000
189
0.0
2.4
0.000
0.0
2.4
10 120
119
2.1
0.0
2.4
0.000
0.0
0.000
60
1
7
0.000
90
2.
0.C00
2.1]
0.0
2.4
0.000
1. All samples 25 gram.
2. Average rate of gas production in L/Kg/Hr=Avg produced(ml)x40/1000m//L
DOTDROSS.XLS

<<<PAGE 32>>>

CRS Project Number: S-6747
February 5, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O . Box 217
Calvert City, Kentucky 42029
Dangerous When Wet Materials (as set forth in 49 CFR Section 173,
Appendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of Graphidox, Lab
ID: 2129A, Bin Number: 406.
Dear Mr. Hall:
We have completed our gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections l, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The material we received from
SKW was labeled as: Graphidox. The results were as follows:
(1) no gas was evolved and no spontaneous ignition occurred.
(2) no gas was evolved and no spontaneous ignition occurred.
(3) no gas was evolved and no spontaneous ignition occurred.
(4) while some gas did evolve, the average rate never exceeded l liter per
kilogram per hour in the sample tested. The gas was not flammable, but
was ignitible (gas ignited but would not sustain a continuous flame).
It did not spontaneously ignite in any of the tests.
On the basis of these test results, the ferrosilicon material listed above
would not fit the definition in 49 CFR Section 173, Appendix E, Division 4,
Sections l, 2, 3 and 4 as "Dangerous When Wet".
Sincerely,
~~~ (. ~~~ / b'j ~Cf£ L-:~wa;
J R L k . ~ \t'Wt"-thV\ f\\SOC.U-i, {e
ames . a in u J
Business Operations Manager '

<<<PAGE 33>>>

February 5, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O . Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Number: S-6747
Dear Mr. Hall:
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The identification of the
material submitted and its chemistry specification are listed below .
Graphidox Al Si Ti Ca
Specification, %-: <1 . 50 50-55 9-11 5.0-7 . 0
Lab ID : 2129A
Bin Number: 406
Chemistry: 1.01 51.13 9 . 24 5.52
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C. No gas evolution was observed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results)
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 20°C . No gas evolution was observed, nor
did the sample spontaneously ignite.
Section 3 (Procedure & Results)
A small pile with an indentation in the center, approx imately 2cm high by 3cm
in diameter, was made of the material. A few drops of water were added to the
hollow. No gas evolution was observed, nor did any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of material submitted, and
using a hammer and chisel the pieces were crushed individually. The larger pieces
and the fines were screened off from each sample. Only material of +20 mesh to -8
mesh was used in the gas evolution tests . Three reaction vessels were set-up and
filled with a deionized water. The reaction vessels were 1000 ml beakers each
containing a small flask with 25 . 0 grams of sample material. Above each small
flask a 50 ml buret was positioned up-side-down, which was also filled with
deionized water and placed over the end of the flask making a water seal . The
level in the buret was monitored for the next 5 days . Gas evolution data, measured
in milliliters, is attached.
Following the gas evolution tests, the burets were submerged, still up-side-

<<<PAGE 34>>>

Report S-6747
down, up to the stopcocks in water. A small flame was placed near the tip of the
buret and the stopcock was opened to allow the gas inside the burets to be pushed
out into the flame by the water pressure. Flammability observations are noted at
the bottom of the gas evolution data . The gas was not analyzed to determine its
composition.
If you have questions about the test or these results please contact me .
Thank you for doing business with us.
Sincerely,
2 of 3

<<<PAGE 35>>>

Project S-6747 (sheet 12)
Gas Evolution Measurements
(Water Volume Displacement)
Graphidox
2
(ml) (ml)
Avg Rate
3 (I/kg/hr)
Time
(hours)
Day 1 0.00
1.00
2.00
3.00
4 .00
5.00
6.00
Day 2 21.00
29.50
Day 3 45.00
53.50
Day 4 69.00
77.50
Day 5 93.00
101.50
(ml)
0 .0 0.0
0.2 0.2
0.5 0.2
0.9 0.2
1.6 0.4
2.1 0.4
2.4 0.4
17.4 0.6
23.2 2.0
31.8 6.9
34.8 9.8
38.6 13.2
41.9 17 .0
45.8 23.4
46.5 25.6
0.0
0.2 0.008
0.4 0.007
0.4 0.005
0.5 0.013
0.5 0.007
0.5 0.004
0 .6 0.014
0 .8 0.012
0 .9 0 .012
0.9 0.009
1.2 0.006
1.7 0.012
2.0 0 .009
2.2 0.005
Flammable (F)
lgnitible (I)*
Not Flammable (NF)
X X
X
* lgnitible = the gas will ignite but will not sustain a continuous flame.
3 of 3

<<<PAGE 36>>>

Graphidox
Specification Chemistry, %:
Al Si Ti
<1.50 50-55 9-11
Ca
5.0-7.0
Sample I.D. Number: 21298
Bin Number: 406
Observed Chemistry of Tested Sample,%:
Al Si Ti Ca
1.01 51.13 9.24 5.52
Test 1:
A small quantity (approximately 2 mm diameter) of the above material was
placed in a trough of distilled water at 20° C and observed to see whether any
gas evolved and if it spontaneously ignited. Test 1 was performed in triplicate
on the above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 1 was performed.
Test 2:
A small quantity (approximately 2 mm diameter) of the above material was
floated on a piece of filter paper in distilled water at 20° C and observed to see
whether any gas evolved and if it spontaneously ignited. Test 2 was performed
in triplicate on the above material.
Result:
Neither evolution of gas or spontaneous ignition was observed in any of the
three times Test 2 was performed.
Test 3:
The test material was formed into three piles approximately 2 cm high by 3 cm
wide. An indentation was formed in the top of each pile and a few drops of water
were added to each hollow. Each pile was observed to see whether any gas
evolved and if it spontaneously ignited. Test 3 was performed in triplicate on the
above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 3 was performed.
I

<<<PAGE 37>>>

Test 4:
Enough water at 20° C to cover the sample, 10 ml to 20 ml, was added to a
dropping funnel. The spout of the dropping funnel was inserted into one hole of
a #14, two-hole stopper; a tube for conveying any gas produced into the
collection cylinder, a gas buret, was inserted into the other hole of the stopper;
the far end of the tube was inserted into the end of the collection cylinder.
The gas buret is glass, 50 ml capacity, marked in individual ml units with each ml
subdivided into 0.1 ml increments. The gas buret was filled with water, inverted
and stood in a water trough. The gas tube in the previous paragraph was
inserted into the bottom end of the gas buret and any gas produced was
measured by observing the displacement of the water in the top of the buret.
25 g of the above listed material was added to each of three 100 ml conical
flasks with #14 neck size. The stoppers mentioned above were inserted into the
neck of the conical flasks. The stopcocks were opened and 10 ml to 20 ml of the
20° C distilled water, enough to completely cover the sample, was allowed to
flow into the flasks. A timer was started and readings of any gas evolved were
taken every hour for five days. From this data the average rate of gas
production per hour was calculated for the five days.
Result:
The Gas Collection data for Graphidox is detailed on the following page:

<<<PAGE 38>>>

Gas Test on Graphidox
January 24, 1996
Avg
Time
Rate
Time
AVg
Avg
Avg
Rate
3sme
Rate
Rate
Hr.
(ml)
(ml)
ml)
L/Kg/Hr
Hr.
(ml)
(ml)
0.0
(ml)
L/Ka/He
Hr
(ml)
(ml)
(ml)
LIKg/Hr
(ml)
0.0
0.000
(ml)
2.7
0.0
(mi)
0.
0
L/Kg/Hr
1
0.0
0.
0
0.
0
0.000
31
0.0
0.0
0.000
61
2.6
0.0
91
0.000
0.
0
0.
0.000
32
0.
0.000
62
2.6
0.0
.0
0,000
92
2.7
0.
.0
0,000
.0
0
0
0.000
33
0.
0.
0.000
63
2.6
0
. 0
0.000
93
2.7
0
0,000
0.
.0
.0
0.
0.000
34
0.000
64
2.6
0,000
94
2.7
.0
0.000
0.
0.
0
0.000
.000
65
2.
6
0.000
95
2.7
0.
.0
88
0.
.0
0,000
6
.000
66
2.
0,000
96
2.7
.00
0.
8
8°
0.000
000
67
N
6
0,000
97
2.7
0.
0.
.0
0.00
0.000
000
68
0.001
98
2.7
0.0
0 00
0,000
00
69
2
0.000
99
2.7
0.0
00
.0
0
0,000
000
70
2.7
0.000
100
2.7
0.
0.000
11
.0
0.
0.000
OOI
71
2.
7
0,000
101
2.7
0.000
12
.0
0.
0
0.000
42
2.
0.000
102
2.7
0.0
0.000
888
0.000
000
73
2.7
0.000
103
2.7
0.0
0.0
0.000
0.0
0.0
0.000
0.000
NIN
7
0.0
0.000
104
88
0.0
0.000
0.
.0
0.
0,000
0.
0.
.0
0.000
7
0.000
0.0
0.001
0.
2
7
106
2.
8
17
00
00
IN'N
.7
2.
8
000
.7
00
8
88998
00
2.
.7
2.
8
20
2
2.
.7
110
2.
8
.5
0.0
004
2.7
111
2.
8
23
0.
0.0
0.0
00
2
0.000
.5
0.0
0
112
0
0.
7
.000
113
0.
000
0.
0.000
2.
.6
0.
.000
114
000
0.
0.000
2.
100
2.
0
0.
.000
115
2.8
0.
.0
0.0
88888
0.0
0.000
2
6
2.
7
0.000
. 000
116
2.8
0.
0
000
0.000
2
.6
0
2.
7
.0
0.000
BAIT
2.8
.0
0.0
888g
0.000
00
0
.0
0.
000
118
2.8
0
988888
.000
88
0.000
NINN
.6
0
.0
0
.000
0
0.0
0.000
0
.0
.000
0.
0.000
0.
.0
.0
0
.000
1. All samples 25 gram.
2.Average rate of gas production in L/Kg/Hr=Avg produced(ml)x40/1000ml/L
DOTGRDX XLS

<<<PAGE 39>>>

CRS Project Number: S-6747
January 27, l997
Mr . Timothy H. Hall
SKW Metals and Alloys, Inc.
P .O. Box 2l7
Calvert City, Kentucky 42029
Dangerous When Wet Materials (as set forth in 49 CFR Section 173,
Appendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of Low Ca
Graphidox, Lab ID: 2128A, Bin Number: 405.
Dear Mr. Hall:
We have completed our gas evolution measurements and the flammability tests,
per Code 49 CFR l73, Appendix E division 4, Sections l, 2, 3 and 4, on the sample
material that you submitted in late December l996. The material we received from
SKW was labeled as: Low Ca Graphidox. The results were as follows:
(l) no gas was evolved and no spontaneous ignition occurred.
(2) no gas was evolved and no spontaneous ignition occurred.
(3) no gas was evolved and no spontaneous ignition occurred.
(4) while some gas did evolve, the average rate never exceeded l liter per
kilogram per hour in the sample tested. The gas was flammable and
ignitible (gas ignited but would not sustain a continuous flame). It
did not spontaneously ignite in any of the tests.
On the basis of these test results, the ferrosilicon material listed above
would not fit the definition in 49 CFR Section l73, Appendix E, Division 4,
Sect. ions l, 2, 3 and 4 as "Dangerous When Wet" .
Sincerely,
j o.,vii, e~
James R.
Business
,.__ le,t.,b_;\ ( 6j ~~~£ it t_ .
· :r~l~\~
l:iru;1 l'\e- 0 n"'-') f'?';/:,1..'!<.,0
Lakin O i..
Operations Manager

<<<PAGE 40>>>

January 27, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Number: S-6747
Dear Mr. Hall:
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The identification of the
material submitted and its chemistry specification are listed below.
Low Ca Graphidox
Specification, %:
Lab ID: 2128A
Bin Number: 405
Chemistry:
Al
<1.5
Si
50-55
Ti
9-11
Ca
0.5-1.5
0.24
50.38
10.92
0.50
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C. No gas evolution was observed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results)
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 20°C. No gas evolution was observed, nor
did the sample spontaneously ignite.
Section 3 (Procedure & Results)
A small pile with an indentation in the center, approximately 2cm high by 3cm
in diameter, was made of the material. A few drops of water were added to the
hollow. No gas evolution was observed, nor did any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of material submitted, and
using a hammer and chisel the pieces were crushed individually. The larger pieces
and the fines were screened off from each sample. Only material of +20 mesh to -8
mesh was used in the gas evolution tests. Three reaction vessels were set-up and
filled with a deionized water. The reaction vessels were 1000 ml beakers each
containing a small flask with 25.0 grams of sample material. Above each small
flask a 50 ml buret was positioned up-side-down, which was also filled with
deionized water and placed over the end of the flask making a water seal. The
level in the buret was monitored for the next 5 days. Gas evolution data, measured
in milliliters, is attached.
Following the gas evolution tests, the burets were submerged, still up-side-
down, up to the stopcocks in water. A small flame was placed near the tip of the

<<<PAGE 41>>>

Report 8-6747
buret and the stopcock was opened to allow the gas inside the burets to be pushed
out into the flame by the water pressure. Flammability observations are noted at
the bottom of the gas evolution data . The gas was not analyzed to determine its
composition.
If you have questions about the test or these results please contact me.
Thank you for doing business with us.
2 of 3

<<<PAGE 42>>>

Project S-6747 (sheet 7)
Gas Evolution Measurements
(Water Volume Displacement)
Low Ca Graphidox
1 2
(ml) (ml)
Avg Rate
3 (I/kg/hr)
Time
(hours)
Day 1 0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8.00
Day 2 22.25
Day 3 46.25
54.75
Day 4 70.25
Day 5 98.75
(ml)
0.0 0.0
0.2 0 .1
0.3 0.2
0.6 0.7
1.0 0.8
1.2 1.0
1.5 1.2
1.8 1.7
1.9 1.8
4.4 4.6
5.2 9.9
5.4 12.4
5.6 16.0
7.4 22.4
0.0
0.1 0.005
0.2 0.004
0.7 0.017
0.7 0.007
0.9 0 .008
1.2 0.011
1.6 0.013
1.6 0.009
3.6 0.007
5.1 0.004
5.5 0.005
6.0 0.004
7.6 0.005
Flammable (F)
lgnitible (I)*
Not Flammable (NF)
X
X
X
* lgnitible = the gas will ignite but will not sustain a continuous flame.
3of 3

<<<PAGE 43>>>

Low-Calcium Graphidox
Specification Chemistry, %:
Al Si Ti
<1 .50 50-55 9-11
Ca
0.5-1 .5
Sample I.D. Number: 21288
Bin Number: 405
Observed Chemistry of Tested Sample,%:
Al Si Ti Ca
0.24 50.38 10.92 0.50
Test 1:
A small quantity (approximately 2 mm diameter) of the above material was
placed in a trough of distilled water at 20° C and observed to see whether any
gas evolved and if it spontaneously ignited. Test 1 was performed in triplicate
on the above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 1 was performed.
Test 2:
A small quantity (approximately 2 mm diameter) of the above material was
floated on a piece of filter paper in distilled water at 20° C and observed to see
whether any gas evolved and if it spontaneously ignited. Test 2 was performed
in triplicate on the above material.
Result:
Neither evolution of gas or spontaneous ignition was observed in any of the
three times Test 2 was performed.
Test 3:
The test material was formed into three piles approximately 2 cm high by 3 cm
wide. An indentation was formed in the top of each pile and a few drops of water
were added to each hollow. Each pile was observed to see whether any gas
evolved and if it spontaneously ignited. Test 3 was performed in triplicate on the
above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 3 was performed.
Test 4:

<<<PAGE 44>>>

Enough water at 20° C to cover the sample, 10ml to 20ml, was added to a
dropping funnel. The spout of the dropping funnel was inserted into one hole of
a #14, two-hole stopper; a tube for conveying any gas produced into the
collection cylinder, a gas buret, was inserted into the other hole of the stopper;
the far end of the tube was inserted into the end of the collection cylinder.
The gas buret is glass, 50 ml capacity, marked in individual ml units with each ml
subdivided into 0.1 ml increments. The gas buret was filled with water, inverted
and stood in a water trough. The gas tube in the previous paragraph was
inserted into the bottom end of the gas buret and any gas produced was
measured by observing the displacement of the water in the top of the buret.
25 g of the above listed material was added to each of three 100 r:nl conical
flasks with #14 neck size. The stoppers mentioned above were inserted into the
neck of the conical flasks. The stopcocks were opened and 10ml to 20ml of the
20° C distilled water, enough to completely cover the sample, was allowed to
flow into the flasks. A timer was started and readings of any gas evolved were
taken every hour for five days. From this data the average rate of gas
production per hour was calculated for the five days.
Result:
The Gas Collection data for Low-Calcium Graphidox is detailed on the following
page:

<<<PAGE 45>>>

Gas Test on Low Calcium Graphidox
January 16, 1996
Avg
Time
2
Time
AVg
Avg
2
2
3
Avg
Rate
Rate
sme
Rate
time
Rate
(mi).
(ml) (ml)
L/Ko/Hr
Hr.
0.0
2.0
1.0
(m))
(ml)
(mi)
LING HE
(ml)
(ml)
(ml)
Likg/Hr
Hr.
(ml)
(ml)
(ml)
L/Kg/Hr
0.040
31.
0.0
2.0
1.01
0.000
61
0.0
3.0
1.0
0.000
91
0.0
3.0
1.0
0.000
2
0.0
2.0
1.0
0.000
32
0.
.0
2.0
1.0
0,000
62
0.0
3.0
1.0
0,000
92
0.0
3.0
1,0
0,000
3
0.0
2.0
1.0
0.000
33
0.
2.0
1.0
0.000
63
0.0
3.0
1.0
0.000
93
0.0
3.0
1.0
0.000
0.0
2.0
1.0
0.000
34
0.
0
2.0
0.000
64
0.0
3.0
1.0
0,000
94
0.0
3.0
1
0
0.000
0.0
2.0
1.0
0,000
0.
0
2.0
0.000
65
0.0
3.0
1.0
0,000
95
0.0
3.
1.0
0.000
6
0.0
2.0
1.0
0,000
36
2.
0
1.0
0,000
66
0.0
3.0
1.0
0,000
96
0.0
3.0
1.0
0.000
0.
0
2.0
1.0
0.000
37
2.
1.
.0
0.000
0.0
3.0
1.0
0.000
97
0.0
3.
0
1.0
0.000
8
0.0
2.0
1.0
0.000
38
2.
1.0
0.000
68
0.0
3.0
1.0
0.000
98
0.0
3.
1.
0
0.000
9
0.0
2.0
1.0
0.000
39
2
1.
0.000
69
0.0
3.(
1.0
0.000
0.0
3.0
1.0
0,000
10
0.0
2.0
1.0
0.000
40
2.
1
.0
0.000
11
0.0
2.0
70
0.0
3.0
1.0
0,000
100
0
.0
3.
.0
1.0
0.000
1.0
0.000
41
2.
1.
0
0,000
71
0.0
3.
1.0
0.000
101
0.0
3.0
1.0
0.000
12
0.0
2.0
1.0
0.000
42
0.
2.0
1.0
0.000
12
0.0
3.0
1.0
0.000
102
0.0
3.0
1.0
0.000
13
0.0
2.0
1.0
0.000
43
0.
2.0
1.0
0.000
73
0.0
3.0
1.0
0.000
103
0.0
3.0
1.0
0.000
0.0
2.0
1.0
0.000
2.0
0.000
88
0.
3.0
0.000
0.0
0,000
0.0
2.0
1.0
0.000
3.0
0.013
3.
0.000
0.0
0.
.000
16
0.
.0
2.0
1.
0.000
0
3.
1.
0.
.000
3.
0
0
100
0
.0
3.
0
0
17
0.
.0
2.
0.000
0.000
0.
3
1
.0
0
3.
.0
18.
0.
2.
0
1.
0
0.000
0
0.000
78
0.
0
3.
1.0
0
100
108
0.
3.
19
0.
2.
0,000
0.000
0
0
• 0
1
.0
0.
3.
20
0.
.0
2.
0
0.000
0.000
3
1
0.
000
0
3.
21
0.
2
0
0
0.000
1.0
0,000
.0
0.
000
3.
00
22
2
0
0.000
0,000
.0
000
3.
00
231
0.0
2.0
1.0
0.000
0.
3.
0.000
0.
3.
1.
0.000
113
11
4
0.
3.
85
88
.0
1
0,000
0.000
24
0.0
2.0
1.0
0.000
0.
3.
.000
3
0,000
0.0
2.0
1.0
0,000
0.
3.
1.0
0.000
3.
0
1.
0.000
115
0
.0
3.
0,000
0.0
2.0
1.0
0,000
0.
3.0
1.
.0
0.000
0.
.0
0
1.
0.000
116
3.0
0.000
0.0
2.0
1.0
0.000
0.
3.
1.
0
0.000
0.
3
1
0.000
117
0
3.0
0.000
0.0
2.0
1.0
0.000
0.
3.
.0
0.000
88
0.
3
0.000
118
O
.0
3.
0.000
0.0
2.0
1.0
0.000
3.
1.0
0.000
8/8
0.
• O
3
0.000
0
.0
3.
0.0
2.0
1.0
0.000
3.
1.0
0.000
3
.0
0.000
0.0
3
.0
1
0.000
1. All samples 25 gram.
2.Average rate of gas production in L/Kg/Hr=Avg produced(ml)x40/1000ml/L
DOTLCGRD.XLSR

<<<PAGE 46>>>

CRS Project Number: S-6747
February 5, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P . O. Box 217
Calvert City, Kentucky 42029
Dangerous When Wet Materials (as set forth in 49 CFR Section 173,
Appendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of I63, Lab ID:
2131A, Bin Number: 316.
Dear Mr. Hall:
We have completed our gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The material we received from
SKW was labeled as: I63 . The results were as follows:
(1) no gas was evolved and no spontaneous ignition occurred.
(2) no gas was evolved and no spontaneous ignition occurred.
(3) no gas was evolved and no spontaneous ignition occurred.
(4) while some gas did evolve, the average rate never exceeded 1 liter per
kilogram per hour in the sample tested. The gas was flammable, but
it
did not spontaneously ignite in any of the tests .
On the basis of these test results, the ferrosilicon material listed above
would not fit the definition in 49 CFR Section 173, Appendix E, Division 4,
Sections 1, 2, 3 and 4 as "Dangerous When Wet".
Sincerely,

<<<PAGE 47>>>

February 5, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Number: S-6747
Dear Mr. Hall:
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The identification of the
material submitted and its chemistry specification are listed below.
I63 Al Si Mn Ca Ba
Specification, % : 0 . 8-1.5 60-65 7-12 1.5-3 . 0 4.0-6 . 0
Lab ID : 2131A
Bin Number: 316
Chemistry: 1.23 64.87 7.14 1. 90 4.09
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C. No gas evolution was observed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results)
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 20°C. No gas evolution was observed, nor
did the sample spontaneously ignite.
Section 3 (Procedure & Results)
A small pile with an indentation in the center, approximately 2cm high by 3cm
in diameter, was made of the material. A few drops of water were added to the
hollow. No gas evolution was observed, nor did any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of material submitted, and
using a hammer and chisel the pieces were crushed individually . The larger pieces
and the fines were screened off from each sample. Only material of +20 mesh to - 8
mesh was used in the gas evolution tests. Three reaction vessels were set-up and
filled with a deionized water. The reaction vessels were 1000 ml beakers each
containing a small flask with 25.0 grams of sample material. Above each small
flask a 50 ml buret was positioned up-side-down, which was also filled with
deionized water and placed over the end of the flask making a water seal. The
level in the buret was monitored for the next 5 days . Gas evolution data, measured
in milliliters, is attached.
Following the gas evolution tests, the burets were submerged, still up-side-
down, up to the stopcocks in water. A small flame was placed near the tip of the

<<<PAGE 48>>>

Report S-6747
buret and the stopcock was opened to allow the gas inside the burets to be pushed
out into the flame by the water pressure. Flammability observations are noted at
the bottom of the gas evolution data. The gas was not analyzed to determine its
composition.
If you have questions about the test or these results please contact me.
Thank you for doing business with us.
Sincerely,
~,;\\1.1&. t - Lu,1~ / ~'J Oleete, l. ~\,\~~ec _ _ ._
Jam~s R. Lakin , G-~V\.-v-q i\-~oc-~c4.e
Business Operations Manager · --J
2 of 3

<<<PAGE 49>>>

Project S-6747 (sheet 9)
Gas Evolution Measurements
(Water Volume Displacement)
163
2
(ml) (mil
Avg Rate
3 (I/kg/hr)
Time
(hours)
Day 1 0.00
1.00
2.00
3.00
4.00
5.00
8.25
Day 2 20.25
28.75
Day 3 44.25
52.25
Day 4 68.25
76.50
Day 5 92.25
100.75
(mil
0 .0 0 .0
0.6 0.7
2.2 2.0
5.0 4.6
5.6 5.2
8 .0 7.5
11 .8 10.6
19.8 20.2
25 .0 26.6
34.0 36.6
36.9 39.8
40.4 44.1
41.8 46.2
46.6 49.5
49.4 50.0
0.0
0.6 0.025
1. 7 0.053
3.9 0.101
4.4 0.023
6.7 0.093
10.3 0.043
18.2 0.028
23.6 0.027
32.6 0.024
35.8 0.016
40.4 0.010
42.5 0.009
47.2 0.011
50.0 0.010
Flammable (Fl
lgnitible (I) *
Not Flammable {NF)
X X
X
* lgnitible = the gas will ignite but will not sustain a continuous flame.
3 of 3

<<<PAGE 50>>>

lnoculoy 63
Specification Chemistry, %:
~ Si Mn
0. 8-1 . 5 60-65 7 -12
Ca
1.5-3.0
Ba
4.0-6.0
Sample 1.0. Number: 2131 B
Bin Number: 316
Observed Chemistry of Tested Sample,%:
~ Si Mn Ca
1.23 64.87 7.14 1.90
Ba
4.09
Test 1:
A small quantity (approximately 2 mm diameter) of the above material was
placed in a trough of distilled water at 20° C and observed to see whether any
gas evolved and if it spontaneously ignited. Test 1 was performed in triplicate
on the above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 1 was performed.
Test 2:
A small quantity (approximately 2 mm diameter) of the above material was
floated on a piece of filter paper in distilled water at 20° C and observed to see
whether any gas evolved and if it spontaneously ignited. Test 2 was performed
in triplicate on the above material.
Result:
Neither evolution of gas or spontaneous ignition was observed in any of the
three times Test 2 was performed.
Test 3:
The test material was formed into three piles approximately 2 cm high by 3 cm
wide. An indentation was formed in the top of each pile and a few drops of water
were added to each hollow. Each pile was observed to see whether any gas
evolved and if it spontaneously ignited. Test 3 was performed in triplicate on the
above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 3 was performed.

<<<PAGE 51>>>

Test 4:
Enough water at 20° C to cover the sample, 10 ml to 20 ml, was added to a
dropping funnel. The spout of the dropping funnel was inserted into one hole of
a #14, two-hole stopper; a tube for conveying any gas produced into the
collection cylinder, a gas buret, was inserted into the other hole of the stopper;
the far end of the tube was inserted into the end of the collection cylinder.
The gas buret is glass, 50 ml capacity, marked in individual ml units with each ml
subdivided into 0.1 ml increments. The gas buret was filled with water, inverted
and stood in a water trough. The gas tube in the previous paragraph was
inserted into the bottom end of the gas buret and any gas produced was
measured by observing the displacement of the water in the top of the buret.
25 g of the above listed material was added to each of three 100 ml conical
flasks with #14 neck size. The stoppers mentioned above were inserted into the
neck of the conical flasks. The stopcocks were opened and 10 ml to 20 ml of the
20° C distilled water, enough to completely cover the sample, was allowed to
flow into the flasks. A timer was started and readings of any gas evolved were
taken every hour for five days. From this data the average rate of gas
production per hour was calculated for the five days.
Result:
The Gas Collection data for lnoculoy 63 is detailed on the following page:

<<<PAGE 52>>>

Gas Test on I-63
January 24, 1996
Avg
AVg
Avg
Avg
a me
Rate
Time
Rate
Time
Rate
REme
Rate
HE.
(ml)
(ml)
(ml)
ШКа/Hr
(mi)
(mi)
0.0
(mi)
5.0
L/Kg/Ht
Hr.
0.0
0.0
1.0
0.013
131
6.0
(ml)
(ml)
0.0
"(m)
Hr.
(mi)
7.0
0.000
91
12.0
(m))
0.0
(ml)
L/Kg/Hr
0.027
61
12.0
7.0
0.000
2
0.0
1.0
0.000
132
6.0
0.
5.0
0.000
62
12.0
0.0
7.0
0.000
92
12.0
0.0
7.0
0.000
0
0.
1.0
0.000
33
6.0
0.
5.0
0.000
63
12.0
7.0
0.000
93
12.0
0.0
7.0
0.000
0
0
0
0,000
34
6.0
0
5.
0
0.000
64
12.0
0.0
7.0
0,000
94
12.0
0.0
7.0
0.000
0.000
35
6.0
5
0
0.000
65
12.0
0.0
7.0
0.000
85
12.0
0.0
7.0
0,000
0
.0
0.000
36
6.0
0
0.000
66
12.0
0.0
7.0
0.000
96
12.0
0.0
7.0
0.000
0.000
37)
6.0
0.000
12.0
0.0
7.0
0.000
97
12.0
0.0
7.0
0.000
0,000
38
6.0
0.000
68
12.0
0.0
7.0
0.000
98
13.0
0.0
7.
. 0
0.013
9:
0,000
39
7.
0.013
69
12.0
0.0
7.0
0,000
99
13.0
0.0
7.
0.000
10
0.000
40
7.0
6.
0.013
70
12.0
0.0
7.0
0,000
100
13.0
0.0
7.
. 0
0,000
11
0.000
41
8.0
6.
0.013
71
12.0
0.0
7.0
0.000
101
13.0
0.0
7.0
0.000
12
0.
0.000
42
9.0
7.
0.027
72
12.0
0.0
7.0
0.000
102
13.
0
0.0
7.0
0,000
13
0.
0.
1.0
0.000
43
9.0
7.
0.000
73
12.0
0.0
7.0
0,000
103
13.0
0.0
7.0
0.000
1.0
0.013
9.0
0.
7.0
0.000฿
12.0
0.0
7.0
0.000
0.0
7
104
13.0
0.0
7.
0.000
1.
0
0.
1.0
0.000
10.0
0.0
7.0
12.0
.0
0.000
105
13.0
0.0
0.000
1.
.0
0.
.0
1.
0
0.000
10.0
0.
7
0.000
12.0
7.
0
.0
.0
0.
1.
.0
2.
0
0.
013
11.0
7.
0.013
12.0
0.
7.0
3.
0.
1.
.0
.0
2.
0.000
11.0
7
0
0.000
78
12.0
0.
.0
7.0
3.
0.
.0
7
.0
000
2.
.0
2
0.
11.0
7
0.000
79
12.0
0.
7.0
3.
7
.0
000
0
0.
000
11.0
7
0.000
80
12.0
0.
0
7.0
3.
0.
7.
.0
2.
0
0
0.
000
12.0
0.013
81
12.0
0
.0
3.
0.
7.
.0
2.
0.
.000
12.0
0.000
82
12.0
0.
7
.0
00
3.
0.
7
.0
2.01
3.0
8888
2.0
0.000
12.0
0.0
7.
0.000
12.0
0.
.0
7.0
0.000.
113
13.0
0.0
.0
12.0
0.
.0
.0
0.000
114
0.000
3.0
0.027
12.
0.0
7.0
0.000
13.0
0.
7
.0
0.000
4.0
3.0
0.013
12
.0
0.0
7.0
0.000
85
12.0
0.
7.0
0.000
115
13.0
0.
0
0.000
5.0
4.0
0.0
4.0
0.013
12.0
0.0
7.0
0.000
86
12.0
0.
7.0
0.000
116
13.0
0.
7.0
0.000
0.0
4.0
0.013
12.0
0.0
7.0
0.000
12.0
0.0
7.0
0,000
88
87
12.0
0.
7.0
0.000
117
13.0
0.
.0
7.0
0.000
5.0
0.0
4.0
0.000
12.0
0.
.0
7.0
0,000
118
13.0
0.
7
.0
12.0
0.
.0
7
0.000
5.0
0.0
4.0
0.000
12.0
0.0
7.0
0.000
89
.0
0.000
119
13.0
7
.0
0.000
5.0
0.0
4.0
0.000
12.0
0.0
7.0
0.000
12.0
0.
.0
7.0
0.000
120
13.0
7.0
0.000
1. All samples 25 gram.
2. Average rate of gas production in L/Kg/Hr=Avg produced(ml)x40/1000ml/L
DOTI63.XLS

<<<PAGE 53>>>

CRS Project Number: S-6747
January 27, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Dangerous When Wet Materials (as set forth in 49 CFR Section 173,
Appendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of Noduloy SCl,
Lab ID: 2126A, Bin Number: 109.
Dear Mr. Hall:
We have completed our gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996 . The material we received from
SKW was labeled as: Noduloy SCl. The results were as follows:
(1) no gas was evolved and no spontaneous ignition occurred.
(2) no gas was evolved and no spontaneous ignition occurred.
(3) no gas was evolved and no spontaneous ignition occurred.
(4) while some gas did evolve, the average rate never exceeded 1 liter per
kilogram per hour in the sample tested. The gas was flammable and
ignitible (gas ignited but would not sustain flame) It did not
spontaneously ignite in any of the tests.
On the basis of these test results, the ferrosilicon material listed above
would not fit the definition in 49 CFR Section 173, Appendix E, Division 4,
Sections 1, 2, 3 and 4 as "Dangerous When Wet".
Sincerely,
d-i~~ e. ~ /1,J
James R. Lakin
Business Operations

<<<PAGE 54>>>

January 27, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P . O. Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Number: S-6747
Dear Mr . Hall:
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The identification of the
material submitted and its chemistry specification are listed below.
Noduloy SCl Al Si Ce Mg TRE Ca
Specification, %: 0.7-1.2 44 - 48 0.9-1.2 5.5 - 6.0 0.8-1. 3
Lab ID : 2126A
Bin Number : 109
Chemistry: 0.72 44.87 0. 91 5. 93 1.20
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C. No gas evolution was observ ed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results)
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 2 0°C. No gas evolution was observed, nor
did the sample spontaneously ignite.
Section 3 (Procedure & Results)
A small pile with an indentation in the center, approximately 2cm high by 3cm
in diameter, was made of the material. A few drops of water were added to the
hollow . No gas e v olution was observ ed, nor di d any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of mat erial submitted, and
using a hammer and chisel the pieces were crushed individually. Th e larger pieces
and the fines were screened off from each sample. Only material of +20 mesh to - 8
mesh was used in the gas evolution tests. Three reaction vessels were set- up and
filled with a deionized water. The reaction vessels were 1000 ml beakers each
containing a small flask with 25.0 grams of sample material . Above each small
flask a 50 ml buret was positioned up-side-down, which was also filled with
deionized water and placed over the end of the flask making a water seal. The
level in the buret was monitored for the next 5 days. Gas evolution data, measu red
in milliliters, is attached .
Following the gas evolution tests, the burets were submerged, still up-side-
down , up to the stopcocks in water . A small flame was p l aced near the tip of the

<<<PAGE 55>>>

Report S-6747
buret and the stopcock was opened to allow the gas inside the burets to be pushed
out into the flame by the water pressure. Flammability observations are noted at
the bottom of the gas evolution data. The gas was not analyzed to determine its
composition.
If you have questions about the test or these results please contact me.
Thank you for doing business with us.
Sincerely,
'J" (ii'v'Kf'-.C. e.,. W~i I bJ ~ - ltc- L ~~86-. ,l .
James R. La in k . i.:::;, ,~,1131,'.__,\ "'~OC.t'.»,c.
·1.-.n.. '{vll<!<-·lil 1J ("">
Business Operations Manager O (
2 of 3

<<<PAGE 56>>>

Project S-6747 (sheet 51
Gas Evolution Measurements
(Water Volume Displacement)
Time
(hours)
Day 1 0.00
1.00
2.00
3.00
4.00
5.00
6.00
7 .00
8.00
17.50
Day 2 26.00
41.50
Day 3 50.00
65.50
Day 4 89.50
Day 5 98.00
Flammable (Fl
lgnitible (I)*
Not Flammable (NF)
(ml)
NOD5C1 Avg Rate
2 3 (I/kg/hr)
(ml) (ml)
0.0
6.0
8.3
10.3
10.7
12.9
13.6
14.4
15 .0
19.6
22 .3
26.2
27.8
31.9
35.9
37.2
0.0 0.0
5.8 4.5 0.217
7.9 6.6 0.087
9.9 9.1 0.087
9.9 9.1 0 .005
11 .8 10.6 0.075
12.3 11 .2 0 .024
13.4 12.2 0.031
13.8 13.3 0.033
18.6 21 .0 0.024
21.3 29.5 0 .022
25.1 39.6 0.015
26.7 43.5 0.011
30.4 49.0 0.011
34.6 49.4 0.005
35.8 49 .9 0 .005
X
X
X
* lgnitible = the gas will ignite but will not sustain a continuous flame .
3 of 3

<<<PAGE 57>>>

Noduloy 5C1
Specification Chemistry, %:
~ Si Ce
0.7-1.2 44-48 0.9-1 .2
Mg
5.5-6.0
TRE
Not sp.
Ca
0.8-1 .3
Sample I.D. Number: 2126B
Bin Number: 109
Observed Chemistry of Tested Sample, %:
Al Si Ce Mg
0.72 44.87 0.91 5.93
TRE
Ca
1.20
Test 1:
A small quantity (approximately 2 mm diameter) of the above material was
placed in a trough of distilled water at 20° C and observed to see whether any
gas evolved and if it spontaneously ignited. Test 1 was performed in triplicate
on the above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 1 was performed.
Test 2:
A small quantity (approximately 2 mm diameter) of the above material was
floated on a piece of filter paper in distilled water at 20° C and observed to see
whether any gas evolved and if it spontaneously ignited. Test 2 was performed
in triplicate on the above material.
Result:
Neither evolution of gas or spontaneous ignition was observed in any of the
three times Test 2 was performed.
Test 3:
The test material was formed into three piles approximately 2 cm high by 3 cm
wirf,::, An inrli:on+~+inn VJ~c:: fnrmi:orf in thi:o tnn nf ,::,~rh nil&:> ~nr, ~ f&:>\AJ rfrnnc:: nf w::it,::,r
···--· ... .
···--·· ..
-
· ·-·· ··-- ·
-
· · · ·-- • •• 111,,1,_ ... -,.... -· ---·· ,.... , ,_
-··- -
· -··
-·-r--- -· .. _.. .. _,
were added to each hollow. Each pile was observed to see whether any gas
evolved and if it spontaneously ignited. Test 3 was performed in triplicate on the
above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 3 was performed.

<<<PAGE 58>>>

Test 4:
Enough water at 20° C to cover the sample, 10 ml to 20 ml, was added to a
dropping funnel. The spout of the dropping funnel was inserted into one hole of
a #14, two-hole stopper; a tube for conveying any gas produced into the
collection cylinder, a gas buret, was inserted into the other hole of the stopper;
the far end of the tube was inserted into the end of the collection cylinder.
The gas buret is glass, 50 ml capacity, marked in individual ml units with each ml
subdivided into 0.1 ml increments. The gas buret was filled with water, inverted
and stood in a water trough. The gas tube in the previous paragraph was
inserted into the bottom end of the gas buret and any gas produced was
measured by observing the displacement of the water in the top of the buret.
25 g of the above listed material was added to each of three 100 ml conical
flasks with #14 neck size. The stoppers mentioned above were inserted into the
neck of the conical flasks. The stopcocks were opened and 10 ml to 20 ml of the
20° C distilled water, enough to completely cover the sample, was allowed to
flow into the flasks. A timer was started and readings of any gas evolved were
taken every hour for five days. From this data the average rate of gas
production per hour was calculated for the five days.
Result:
The Gas Collection data for Noduloy 5C1 is detailed on the following page:

<<<PAGE 59>>>

Gas Test on Noduloy 5C1
January 24, 1996
AVg
Avg
Avg
AVg
Time
Rate
Time
Rate
i me
Rate
Time
Rate
HE.
(mll
(mll.
(m)
L. LIKe/Hr
Hr.
(m.))
(m))
L/Kg/Hr
Hr.
(ml)
(ml)
LiKa/Hi
Ho.
(ml)
(ml)
0.7
1.5
0.7
0.039
(mil)
L/Kg/He
31
2.1
7.5
7.7
0,000
61
2.1
7.5
7.7
0.000
91
2.1
10.5
13.1
0.004
1.3
1.9
1.2
0.020
32
2.1
7.5
7.7
0.000
62
2.1
7.5
7.8
0.001
92
2.1
10.6
13.1
0.001
2.0
2.6
2.1
0.031
2.1
7.5
7.7
0.000
63
2.1
7.5
8.0
0.003
93
2.1
10.6
13.1
0.000
2.0
2.9
2.
5
0.009
2.1
7.5
7.7
0.000
64
2.1
7.
.5
8.2
0.003
84
2.1
10.6
13.1
0.000
2.0
3.1
2.8
0.007
35
2.1
7.5
7.7
0.000
65
2.1
7.
.5
8.2
0,000
95
2.1
10.6
13.1
0,000
2.0
3.4
3.3
0.011
36
2.1
7.5
7.7
0.000
66
2.1
7.
8
0.005
96
2.1
10.6
13.1
0.000
2.0
3.6
3.7
0.008
37
2.1
7.5
7.7
0.000
67.
2.1
7.5
0.000
97
2.1
10,6
13.1
0.000
2.0
3.7
4.2
0,008
38
2.1
7.5
7.7
0.000
68
2.1
7.5
0.003
98
2.1
10.6
13.1
0.000
2.0
4.3
4.7
0.015
39
2.1
7.5
7.7
0.000
69
2.1
7.5
0.000
99
2.1
10.6
13.1
0.000
2.0
9
5.2
0.015
40
2.1
7.5
7.7
0,000
70
2.1
7.6
0.003
100
2.1
10.6
13.1
0.000
11
2.0
5.3
5.6
0.011
41
2.1
7.5
7.7
0.000
2.1
7.6
0.000
101
2.1
10.6
13.1
0.000
12
2.0
5.
.5
5.
.7
0.004
42
2.1
7.5
7.7
0.000
72
2.1
7.8
0.005
102
2.1
10.6
13.1
0.000
13
2.0
5
6
6.
.0
0.005
43
2.1
7.5
7.7
0,000
73
2.1
8.0
9
0.007
103
2.1
10.6
13.1
104
0.000
2.0
5.7
6.
1
0.003
7,5
0.000
8.4
2.0
6.3
6.4
0.012
NN
1
1000
0.007
2.1
10.6
13.1
0.000
7.
7
0,000
8.4
0.000
105
2.1
10.6
13.1
0.000
2.0
5
6.
8
0.008
2.
1
7.
7
0.000
2
1
8.7
9
6
0.005
106
2.1
10.
6
13.1
0,000
2.0
6.8
6.
9
0.005
2
1
7.5
7.
7
0.000
2.1
8.7
0.001
107
2.1
10.6
13.1
0.000
2.0
6.9
0.003
2.
1
7.5
7.
0.000
78
2.1
8.8
9
0.003
108
2.1
10.
6
13.1
0.000
2.
7.2
0.011
49
1
7.5
7.
7
0,000
79
2.
7.5
7.7
0.008
50
0.000
60
2.1
9.0
9
0.003
109
2.1
10.6
13.1
0.000
7.5
7.7
2.1
9.
8
2.
1
7.5
7.
2.
0.000
110
2.1
10.6
13.1
0.000
7
0.000
61
2.
7.5
7.7
0.000
81
2.1
9.
.3
I0.
2
0.009
111
2.1
10.6
13.1
0,000
7.5
0,000
2.
1
7.5
7.7
0.000
82
2.1
9.5
0.
4
0.005
112
2.1
10.
13.1
0.000
2.1
7.5
7.7
0.000
2.1
7.5
7.7
0.000
2.1
9.8
1
0.027
113
2.1
10.6
13.1
0.000
2.1
7.5
7.7
0.000
54
2.
1
7.5
7.7
0,000
2.1
9.8
2
0.001
114
2.1
10,6
13.1
0.000
2.1
7.5
7.7
0.000
55
2.1
7.5
7.7
0.000
85
2.1
9.8
0.001
115
2.1
10.6
13.1
0.000
2.1
7.5
7.7
0.000
56
2.1
7.5
7.7
0.000
86.
2.1
10.2
12.6
0.009
116
2.1
10.6
13.1
0.000
2.1
7.5
7.7
0.000
2.1
7.5
7.7
0.000
87.
2.1
10.2
2.1
7.5
7.7
0.000
58
2.1
7.5
7
10.3
12.6
0.000
117
2.1
10.6
13.1
0.000
.7
0.000
8.8
2.1
12.8
0.004
118
2.1
10.6
13.1
0.000
2.1
7.5
7.7
0.000
59
2.1
7.5
7
0.000
2.1
7.5
7.7
0.000
60
2.1
8/8
2.1
10.4
12.9
0.003
119
2.1
10.6
13.1
0.000
7.5
7.7
0.000
2.1
10.4
12.9
0.000
120
2.1
10.6
13.1
0.000
1. All samples 25 gram.
2.Average rate of gas production in L/Kg/Hr=Avg produced(ml)x40/1000ml/L
DOT5C1.XLS

<<<PAGE 60>>>

CRS Project Number: S-6747
January 27, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Dangerous When Wet Materials (as set forth in 49 CFR Section 173,
Appendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of Noduloy 5R2,
Lab ID: 2127A, Bin Number: 107.
Dear Mr. Hall:
We have completed our gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that y ou submitted in late December 1996. The material we received from
SKW was labeled as: Noduloy 5R2 . The results were as follows:
(1) no gas was evolved and no spontaneous ignition occurred.
(2) no gas was evolved and no spontaneous ignition occurred .
(3) no gas was evolved and no spontaneous ignition occurred.
(4) while some gas did evolve, the average rate never exceeded 1 liter per
kilogram per hour in the sample tested. The gas was flammable and
ignitible (gas ignited but would not sustain a continuous flame). It
did not spontaneously ignite in any of the tests.
On the basis of these test results , the ferrosilicon material listed above
would not fit the definition in 49 CFR Section 173, Appendix E, Division 4,
Sections 1, 2, 3 and 4 as "Dangerous When Wet".
Sincerely,
· "':f AA\i<" t . Lu,,l~ / b0 ~tee: 1f 1.., -'\fi/4r .. ~t(,~
J R L k . r:.:w:;~,.,.- 'i"-', /\s~oq,:,;, t,c
ames . a in - I i
Business Operations Manager

<<<PAGE 61>>>

January 27, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Number: S-6747
Dear Mr. Hall:
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The identification of the
material submitted and its chemistry specification are listed below.
Noduloy SR2 Al Si Ce Mg TRE Ca
Specification, %: 0.7-1.2 44-48 0.3-0.5 6.0-6.8 0.5-0.85 0.8-1.3
Lab ID: 2127A
Bin Number: 107
Chemistry: 0.97 44.26 0.60 6.56 0.84 1. 02
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C. No gas evolution was observed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results)
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 20°C. No gas evolution was observed, nor
did the sample spontaneously ignite.
Section 3 (Procedure & Results)
A small pile with an indentation in the center, approximately 2cm high by 3cm
in diameter, was made of the material. A few drops of water were added to the
hollow. No gas evolution was observed, nor did any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of material submitted, and
using a hammer and chisel the pieces were crushed individually. The larger pieces
and the fines were screened off from each sample. Only material of +20 mesh to -8
mesh was used in the gas evolution tests. Three reaction vessels were set-up and
filled with a deionized water. The reaction vessels were 1000 ml beakers each
containing a small flask with 25.0 grams of sample material. Above each small
flask a 50 ml buret was positioned up-side-down, which was also filled with
deionized water and placed over the end of the flask making a water seal. The
level in the buret was monitored for the n. ext 5 days. Gas evolution data, measured
in milliliters, is attached.
Following the gas evolution tests, the burets were submerged, still up-side-
down, up to the stopcocks in water. A small flame was placed near the tip of the

<<<PAGE 62>>>

Report S-6747
buret and the stopcock was opened to allow the gas inside the burets to be pushed
out into the flame by the water pressure. Flammability observations are noted at
the bottom of the gas evolution data. The gas was not analyzed to determine its
composition.
If you have questions about the test or these results please contact me.
Thank you for doing business with us .
2 of 3

<<<PAGE 63>>>

Project S-6747 (sheet 8)
Gas Evolution Measurements
(Water Volume Displacement)
Noduloy 5R1
1 2
(mil (ml)
Avg Rate
3 (I/kg/hr)
Time
(hours)
Day 1 0 .00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8.00
Day 2 22.25
Day 3 46.25
54.75
Day 4 70.25
Day 5 98.75
(ml)
0.0 0.0
3.5 4 .4
6.3 7 .2
8.1 9.2
9.2 10.6
9.8 11 .6
10.6 12.7
12.0 14.6
12.3 14.9
18.6 23.5
31 .9 32.2
34.2 34.2
37.5 37.2
43 .6 41 .9
0.0
6.4 0.191
11 .0 0.136
14.0 0.091
16.9 0.072
18.2 0.039
19.6 0.044
20.8 0.052
21 .7 0.040
29.6 0.021
50.0 0 .024
50.0 0 .007
50.0 0 .005
50.0 0 .005
Flammable (F)
lgniti ble (I) *
Not Flammable (NF)
X
X
X
* lgnitible = the gas will ignite but will not sustain a continuous flame.
3 of 3

<<<PAGE 64>>>

Noduloy 5R2
Specification Chemistry, %:
Al Si Ce
0.7-1.2 44-48 0.3-0.5
Mg
6.0-6.8
TRE
0.5-.85
Ca
0.8-1.3
Sample 1.0. Number: 2127B
Bin Number: 107
Observed Chemistry of Tested Sample,%:
~ Si Ce Mg
0.97 44.26 0.60 6.56
TRE
0.84
Ca
1.02
Test 1:
A small quantity (approximately 2 mm diameter) of the above material was
placed in a trough of distilled water at 20° C and observed to see whether any
gas evolved and if it spontaneously ignited. Test 1 was performed in triplicate
on the above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 1 was performed.
Test 2:
A small quantity (approximately 2 mm diameter) of the above material was
floated on a piece of filter paper in distilled water at 20° C and observed to see
whether any gas evolved and if it spontaneously ignited. Test 2 was performed
in triplicate on the above material.
Result:
Neither evolution of gas or spontaneous ignition was observed in any of the
three times Test 2 was performed.
Test 3:
The test material was formed into three piles approximately 2 cm high by 3 cm
wide. An indentation was formed in the top of each pile and a few drops of water
were added to each hollow. Each pile was observed to see whether any gas
evolved and if it spontaneously ignited. Test 3 was performed in triplicate on the
above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 3 was performed.

<<<PAGE 65>>>

Test 4:
Enough water at 20° C to cover the sample, 10ml to 20ml, was added to a
dropping funnel. The spout of the dropping funnel was inserted into one hole of
a #14, two-hole stopper; a tube for conveying any gas produced into the
collection cylinder, a gas buret, was inserted into the other hole of the stopper;
the far end of the tube was inserted into the end of the collection cylinder.
The gas buret is glass, 50 ml capacity, marked in individual ml units with each ml
subdivided into 0.1 ml increments. The gas buret was filled with water, inverted
and stood in a water trough. The gas tube in the previous paragraph was
inserted into the bottom end of the gas buret and any gas produced was
measured by observing the displacement of the water in the top of the buret.
25 g of the above listed material was added to each of three 100 ml conical
flasks with #14 neck size. The stoppers mentioned above were inserted into the
neck of the conical flasks. The stopcocks were opened and 10 ml to 20 ml of the
20° C distilled water, enough to completely cover the sample, was allowed to
flow into the flasks. A timer was started and readings of any gas evolved were
taken every hour for five days. From this data the average rate of gas
production per hour was calculated for the five days.
Result:
The Gas Collection data for Noduloy 5R2 is detailed on the following page:

<<<PAGE 66>>>

Gas Test on Noduloy, 5R2
January 16, 1996
Avg
Avg
Avg
Avg
Time
Rate
Time
Rate
time
Rate
Time
2
3
Rate
Hr.
(mil)
(ml))
(ml)
10.0
17.0
0.0
L/Kg/Hir
(m))
21.0
(m)
(mil
L/Ko/Hr
Hr.
( (ml)
21.5
((ml)
32.5
(ml)
15.2
0.000
(ml)
(ml)
0.360
31
30.6
15.0
0.000
81
21.5
32.5
(m))
15.2
UKg/Hr
0.000
2
14.8
18.5
6.8
0.175
32
21.0
30.6
15.0
0.000
62
21.5
32.5
15.2
0.000
92
21.5
32.5
15.2
0,000
17.9
21.2
8.6
0.101
33
21.0
30,6
15.0
0.000
63
21.5
32.5
15.2
0.000
93
21.5
32.5
15.2
0.000
20.8
24.6
13.1
0.144
34
21.0
30.6
15.0
0.000
64
21.5
32.5
15.2
0,000
94
21.5
32.5
15.2
0.000
20.9
27.5
13.4
0.044
35
21.0
30.6
15.0
0.000
65
21.5
32.5
15.2
0,000
95
21.5
32.5
15.2
0.000
6
20.9
27.9
14,8
0.024
36
21.0
30.6
15.0
0.000
66
21.5
32.5
15.2
0,000
96
21.5
32.5
15.2
0.000
21.0
28.0
15.0
0.005
37
21.0
30.6
15.0
0.000
21.5
32.5
15.2
0,000
97
21.5
32.5
15.2
0.000
21.0
28.0
15.0
0.000
38
21.0
30.6
15.0
0.000
21.5
32.5
15.2
0.000
98
21.5
32.5
15.2
0.000
91
21.0
28.0
15.0
0,000
39
21.0
30.6
15.0
0.000
69.
21.5
32.5
15.2
0.000
99
21.5
32.5
15.2
0,000
10
21.0
28.0
15.0
0.000
40
21.0
30.6
15.0
0.000
70
21.5
32.5
15.2
0,000
100
21.5
32.5
15.2
0.000
11.
21.0
29.0
15.0
0.013
41
21.0
30.6
15.0
0.000
71
21.5
32.5
15.2
0.000
101
21.5
32.5
15.2
0,000
121
21.0
29.0
15.0
0.000
42
21.0
30.6
15.0
0.000
12
21.5
32.5
15.2
0.000
102
21.5
32.5
15.2
0.000
13
21.0
29.0
15.0
0.000
43
21.0
30.6
15.0
0.000
73
21.5
32.5
15.2
0,000
103
21.5
32.5
15.2
0.000
14
21.0
29.0
15.0
0.000
44|
21.0
30.6
15.0
0.000
74
21.5
32.5
0.000
1104
21.5
32.5
15.2
0.000
15
21.0
29.4
15.0
0.005
21.0
31.5
15.0
0.012
75
21.5
32.5
0,000
105
21.5
32.5
15.2
0.000
16
21.0
29.4
15.0
0,000
46
21.1
31.5
15.0
0.001
76
21.5
32.5
0,000
106
21.5
32.5
15.2
0,000
17
21.0
29.4
15.0
0.000
47|
21.1
31.6
15.0
0.001
TEA
21.5
32.5
0,000
107
21.5
32.5
15.2
0.000
18
21.0
30.6
15.0
0.016
48
21.2
31.6
15.0
0.001
78
21.5
32.5
15.2
0.000
108
21.5
32.5
15.2
0.000
20
19
21.0
30,6
15.0
0,000
49
21.2
32.0
15.0
0.005
79)
21.5
32.5
15.2
0.000
109
21.5
32.5
15.2
0.000
21.0
30.6
15.0
0.000
50
21.3
32.1
15.1
0.004
80)
21.5
32.5
15.2
0.000
110
21.5
32.5
15.2
0.000
21
21.0
30,6
15.0
0.000
51
21.3
32.1
15.
0.000
21.5
32.5
15.2
0.000
111
21.5
32.5
15.2
0.000
22
21.0
30.6
15.0
0.000
52
21.4
32.2
15.2
0.004
21.5
32.5
15.2
0,000
112
21.5
32.5
15.2
0,000
23|
21.0
30.6
15.0
0.000
53
21.4
32.4
15.2
0.003:
83
21.5
32.5
84
21.5
32.5
152
0.000
- 113
21.5
32.5
15.2
0.000
24
21.0
30.6
15.0
0.000
54
21.5
32.5
15.2
0.003
0.000
7114
21.5
32.5
15.2
0.000
25
21.0
30.6
15.07
0.000
65
21.5
32.5
15.2
0.000
85
21.5
32.5
15.2
0.000
115
21.5
32.5
15.2
0.000
26
21.0
30.6
15.0
0.000
56
21.5
32.5
15.2
0.000
86
21.5
32.5
15.2
0.000
116
21.5
32.5
15.2
0.000
27)
21.01
30.6
15.0
0.000
67
21.5
32.5
15.2
0.000
67I
21.5
32.5
15.2
0.000
117
21.5
32.5
15.2
0.000
28
21.0
30.6
15.0
0.000
58
21.5
32.5
15.2
0.000
88.
21.5
32.5
15.2
0.000
118
21.5
32.5
15.2
0.000
21.0
30.6
15.0
0.000
59
21.5
32.5
15.2
0.000
89
21.5
32.5
15.2
0.000
119
21.5
32.5
15.2
0.000
21.07
30.6
15.0
0.000
60
21.5
32.5
15.2
0.000
901
21.5
32.5
15.2
0.000 M120
21.5
32.5
15.2
0.000
1. All samples 25 gram.
2. Average rate of gas production in L/Kg/Hr=Avg produced(ml)x40/1000ml/L

<<<PAGE 67>>>

CRS Project Nwnber: S-6747
February 5, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O . Box 217
Calvert City, Kentucky 42029
Dangerous When Wet Materials (as set forth in 49 CFR Section 173,
Appendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of SRF SO, Lab ID:
2133A, Bin Nwnber: 307.
Dear Mr. Hall:
We have completed our gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The material we received from
SKW was labeled as: SRF 50. The results were as follows:
(1) no gas was evolved and no spontaneous ignition occurred.
(2) no gas was evolved and no spontaneous ignition occurred.
(3) no gas was evolved and no spontaneous ignition occurred.
(4) while some gas did evolve, the average rate never exceeded 1 liter per
kilogram per hour in the sample tested . The gas was nonflammable in
all cases, and it did not spontaneously ignite in any of the tests.
On the basis of these test results, the ferrosilicon material listed above
would not fit the definition in 49 CFR Section 173, Appendix E, Division 4,
Sections 1, 2, 3 and 4 as "Dangerous When Wet".
Sincerely,
i(l,W\f( t.. w~ I ~ ~~~ l . r~bV~~ ) \ ~
,
James R. Lakin ~-Vv~'\.;U.·•'J fuH'i. . .t C
Business Operations Manager '

<<<PAGE 68>>>

February 5, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Number: S-6747
Dear Mr. Hall:
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The identification of the
material submitted and its chemistry specification are listed below.
SRF so Al Si Ca Sr
Specification, % : <0.5 44-48 <0.1 0.8-1.2
Lab ID: 2133A
Bin Number : 307
Chemistry: 0. 37 46.12 0.01 0 . 86
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C. No gas evolution was observed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results)
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 20°C. No gas evolution was observed, nor
did the sample spontaneously ignite .
section 3 (Procedure & Results)
A small pile with an indentation in the center, approximately 2cm high by 3cm
in diameter, was made of the material. A few drops of water were added to the
hollow. No gas evolution was observed, nor did any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of material submitted, and
using a hammer and chisel the pieces were crushed individually. The larger pieces
and the fines were screened off from each sample. Only material of +20 mesh to -8
mesh was used in the gas evolution tests. Three reaction vessels were set-up and
filled with a deionized water. The reaction vessels were 1000 ml beakers each
containing a small flask with 25.0 grams of sample material. Above each small
flask a 50 ml buret was positioned up-side-down, which was also filled with
deionized water and placed over the end of the flask making a water seal. The
level in the buret was monitored for the next 5 days. Gas evolution data, measured
in milliliters, is attached .
Following the gas evolution tests, the burets were submerged, still up-side-

<<<PAGE 69>>>

Report S-6747
down, up to the stopcocks in water. A small flame was placed near the tip of the
buret and the stopcock was opened to allow the gas inside the burets to be pushed
out into the flame by the water pressure. Flammability observations are noted at
the bottom of the gas evolution data. The gas was not analyzed to determine its
composition.
If you have questions about the test or these results please contact me.
Thank you for doing business with us.
Sincerely,
-~\it K-L~-~~ / ~0 ~tl{~ t . -~~
James R. Lakin L~i.ti.:V\ . ..\.,,•J
Business Operations Manager ·
2 of 3

<<<PAGE 70>>>

Project S-6747 (sheet 10)
Gas Evolution Measurements
(Water Volume Displacement)
SRF 50
1 2
(mil (mil
Avg Rate
3 (I/kg/hr)
Time
(hours)
Day 1 0.00
1.00
2.00
3.00
4.00
5.00
8.25
Day 2 20.25
28.75
Day 3 44.25
52.25
Day 4 68.25
76.50
Day 5 92.25
100.75
(ml)
0 .0 0.0
0.0 0.1
0.1 0.1
0.1 0.1
0.2 0.2
0.3 0.3
0.2 0 .2
0.1 0.2
0.4 0.2
1 .1 0.5
9 .9 0.5
36.9 0.5
40.2 0.4
46.5 1.2
48.7 1.4
0.0
0.0 0.001
0.0 0.001
0.0 0.000
0 .1 0.004
0.2 0.004
0.3 0.000
3.2 0 .003
6.8 0.006
10.6 0.004
17.4 0 .026
32.2 0.035
33.7 0.008
36.6 0.008
38.9 0.007
Flammable (F)
lgnitible (I)*
Not Flammable (NF)
X X
X
* lgnitible = the gas will ignite but will not sustain a continuous flame.
3 of 3

<<<PAGE 71>>>

SRF-50
Specification Chemistry, %:
Al Si Ca
<0.50 44-48 <0.10
Sr
0.8-1.2
Sample I.D. Number: 21338
Bin Number: 307
Observed Chemistry of Tested Sample, %:
Al Si Ca Sr
0.37 46.12 0.01 0.86
Test 1:
A small quantity (approximately 2 mm diameter) of the above material was
placed in a trough of distilled water at 20° C and observed to see whether any
gas evolved and if it spontaneously ignited. Test 1 was performed in triplicate
on the above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 1 was performed.
Test 2:
A small quantity (approximately 2 mm diameter) of the above material was
floated on a piece of filter paper in distilled water at 20° C and observed to see
whether any gas evolved and if it spontaneously ignited. Test 2 was performed
in triplicate on the above material.
Result:
Neither evolution of gas or spontaneous ignition was observed in any of the
three times Test 2 was performed.
Test 3:
The test material was formed into three piles approximately 2 cm high by 3 cm
wide. An indentation was formed in the top of each pile and a few drops of water
were added to each hollow. Each pile was observed to see whether any gas
evolved and if it spontaneously ignited. Test 3 was performed in triplicate on the
above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 3 was performed.

<<<PAGE 72>>>

Test 4:
Enough water at 20° C to cover the sample, 10ml to 20ml, was added to a
dropping funnel. The spout of the dropping funnel was inserted into one hole of
a #14, two-hole stopper; a tube for conveying any gas produced into the
collection cylinder, a gas buret, was inserted into the other hole of the stopper;
the far end of the tube was inserted into the end of the collection cylinder.
The gas buret is glass, 50 ml capacity, marked in individual ml units with each ml
subdivided into 0.1 ml increments. The gas buret was filled with water, inverted
and stood in a water trough. The gas tube in the previous paragraph was
inserted into the bottom end of the gas buret and any gas produced was
measured by observing the displacement of the water in the top of the buret.
25 g of the above listed material was added to each of three 100 ml conical
flasks with #14 neck size. The stoppers mentioned above were inserted into the
neck of the conical flasks. The stopcocks were opened and 1 0 ml to 20 ml of the
20° C distilled water, enough to completely cover the sample, was allowed to
flow into the flasks. A timer was started and readings of any gas evolved were
taken every hour for five days. From this data the average rate of gas
production per hour was calculated for the five days.
Result:
The Gas Collection data for SRF-50 is detailed on the following page:

<<<PAGE 73>>>

Gas Test on SRF-50
January 24, 1996
Avg
Time
Avg
Avg
Avg
Rate
Time
Rate
Time
Rate
Hr
Rate
(ml)
0.0
(ml)
0.0
(m))
L/Kg/Hr
Hr.
0.0
0.000
31
(mi
(m)
2.0
0.0
0.0
0.000
61
3.0
(ml)
0.0
(ml)
LIkg/Hit
0.000
HE
((m))
(ml)
(ml
L/Kg/Hr
0.0
91
3.1
0.5
0.0
0.000
0.0
0.0
0.
.0
0.000
32
2.0
0.0
0.
0
0.000
3.0
0.0
0.0
0.000
92
3.1
0.5
0.
0
0.000
1.
0.
0.
0.013
2.0
0.
0.
0
0,000
63
3.0
0.0
0,000
93
3.1
0.
.5
0.
0.000
1.0
0.
0.0
0,000
2.0
0.000
64
3.0
0.0
0.000
94
3.1
0.
0.000
5
2.0
0.
0.013
85
2.
0
0.000
65
3.0
0.
0.0
0.000
95
3.1
0
0
0,000
6
2.0
0.
0,000
36
0.000
66
3.1
0.
0.
.0
0.001
96
3.1
0
.5
0
7
2.0
0.
0,000
37
2
0.000
67
3.1
0.
0,000
97.
3.1
5
2.0
0.
0.000
38
2
0.000
68
3.1
0.0
0.000
98
3.1
0
2.0
0.0
0.000
39
2
0
.000
69
3.1
0.007
99
3.1
10:
2.0
.C
0,000
40
2.
0
000
70
3.1
0.
0.000
100
3.1
2.0
0.000
0.
0.000
41
2.
0.000
71
3.1
0.5
0.
.0
0.000
101
3.1
5
12
2.0
42
2.0
0.000
12
3.1
0.5
0.
.0
0.000
102
3.1
0
00O
13
2.0
0
0.
.0
0,000
43
2.0
0,000
73
3.1
0.5
0.0
0,000
103
3.1
0.5
0.
0,000
2.0
0.000
0.0
0.000
3.1
3
0.5
0.0
0.000
104
3.1
0.5
0.0
0.000
ada
2.0
0.0
0.000
0.
.0
0.
0,000
1
0.5
0,000
105
3.1
0.5
0.
.0
0,000
2.0
0.
0.
.000
2.
0
.0
0
.0
0,000
3
5
0
.0
100
3.
0
17
2.0
0.
0.000
0.000
3
1
0.
0.
.000
107
3.1
.5
18
2.0
.000
0
0.000
3
0.
5
0.0
108
3.
1
0
.0
000
2.
0
0.
.000
3.
1
0.
0.0
3.
1
5
2.0
.000
2.
2.
0.003
3.
0.
.5
0.0
3.
5
.C
0.
81
3.
0.
0.0
.000
11
3
2.
2.
6
0.
3.
0.0
000
12
3
0
5
2.0
0.0
0.000
2.
.9
0.
.O
0.
3.
0.
• 0
0.
00
3.
1
0.
5
0.
.0
0.000
113
0.000
114
3.1
0
1.5
0.0
0.000
2.0
0.
888
0.0
0.000
0.
.001
3.
0.
.5
0
.0
3.1
0
5
0.000
25
2.0
0.0
0.000
3.
0.
.0
0.0
0.
DOI
3
0.
5
0.0
0,000
11
3.1
0
5
.0
0.000
26
2.0
0.0
0.0
0.000
3.
.0
0.
.000
3.
1
0.
5
.0
0.000
116
3.1
.000
2.0
0.0
0.0
0.000
3.
.0
0.
0
0.000
3.
1
0.
5
0.0
0.000
117
3.1
0
5
0.000
2.0
0.0
0.0
0.000
3.
0.
0
0.000
0.
5
0.
.0
0.000
118
3.
1
5
0.
0.000
2.0
0.0
0.0
0.000
w co
0.
.O
0.
.0
0.
.000
3.
0.
5
0.
0
0.000
119
3.1
0.
5
0.0
0.000
2.0
0.0
0.0
0.000
0.
.0
0
.0
3.
.5
0.
.0
0.000
120
3.1
0.
0.000
1. All samples 25 gram.
2. Average rate of gas production in L/Kg/Hr=Avg produced(ml)x40/1000ml/L
DOTSRF50.XLS

<<<PAGE 74>>>

CRS Project Number: S-6747
February 5, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Dangerous When Wet Materials (as set forth in 49 CFR Section 173,
Appendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of SRF 75, Lab ID:
2132A, Bin Number: 506.
Dear Mr. Hall:
We have completed our gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The material we received from
SKW was labeled as: SRF 75. The results were as follows:
(1) no gas was evolved and no spontaneous ignition occurred.
(2) no gas was evolved and no spontaneous ignition occurred.
(3) no gas was evolved and no spontaneous ignition occurred.
(4) while some gas did evolve, the average rate never exceeded l liter per
kilogram per hour in the sample tested. The gas was ignitible (gas
will ignite but will not sustain a continuous flame) in all cases, but
it did not spontaneously ignite in any of the tests.
On the basis of these test results, the ferrosilicon material listed above
would not fit the definition in 49 CFR Section 173, Appendix E, Division 4,
Sections 1, 2, 3 and 4 as "Dangerous When Wet".
Sincerely,

<<<PAGE 75>>>

February 5, 1997
Mr. Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Nwnber: S-6747
Dear Mr. Hall:
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The identification of the
material submitted and its chemistry specification are listed below.
SRF 75 Al Si Ca Sr
Specification, %- : <0.5 74-79 <0.1 0.8-1.2
Lab ID: 2132A
Bin Number: 506
Chemistry: 0.41 74.20 0.01 0.91
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C. No gas evolution was observed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results)
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 20°C. No gas evolution was observed, nor
did the sample spontaneously ignite.
Section 3 (Procedure & Results)
A small pile with an indentation in the center, approximately 2cm high by 3cm
in diameter, was made of the material. A few drops of water were added to the
hollow. No gas evolution was observed, nor did any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of material submitted, and
using a hammer and chisel the pieces were crushed individually. The larger pieces
and the fines were screened off from each sample. Only material of +20 mesh to -8
mesh was used in the gas evolution tests. Three reaction vessels were set-up and
filled with a deionized water. The reaction vessels were 1000 ml beakers each
containing a small flask with 25.0 grams of sample material. Above each small
flask a 50 ml buret was positioned up-side-down, which was also filled with
deionized water and placed over the end of the flask making a water seal . The
level in the buret was monitored for the next 5 days. Gas evolution data, measured
in milliliters, is attached.
Following the gas evolution tests, the burets were submerged, still up-side-

<<<PAGE 76>>>

Report S-6747
down, up to the stopcocks in water. A small flame was placed near the tip of the
buret and the stopcock was opened to allow the gas inside the burets to be pushed
out into the flame by the water pressure. Flammability observations are noted at
the bottom of the gas evolution data. The gas was not analyzed to determine its
composition.
If you have questions about the test or these results please contact me.
Thank you for doing business with us .
Sincerely,
2 of 3

<<<PAGE 77>>>

Project S-6747 (sheet 11 I
Gas Evolution Measurements
(Water Volume Displacement)
SRF 75
2
(ml) (ml)
Avg Rate
3 (I/kg/hr)
Time
(hours)
Day 1 0.00
1.00
2.00
3.00
4.00
5.00
8.25
Day 2 20.25
28.75
Day 3 44.25
52.25
Day 4 68.25
76.50
Day 5 92.25
100.75
(ml)
0.0 0.0
0.0 0.1
0.2 0.3
0.3 0.8
0.5 1 .1
0 .8 1.4
0 .7 7.9
3.3 12.6
7.8 21.1
16.2 30.6
23.7 36.1
35.2 44.2
37.8 45.7
42.5 49.1
45.0 50.0
0.0
0.0 0.001
0.2 0.008
0 .5 0 .012
0 .6 0.008
1.6 0 .021
3.6 0.034
32.8 0.041
41.5 0.034
48.2 0.021
50.0 0.025
50.0 0.016
50.0 0.007
50.0 0 .007
50.0 0.005
Flammable (F)
lgnitible (I) *
Not Flammable (NF)
X X
X
* lgnitible = the gas will ignite but will not sustain a continuous flame.
3 of 3

<<<PAGE 78>>>

SRF-75
Specification Chemistry, %:
~ Si Ca
<0.50 74-79 <0.10
Sr
0.8-1.2
Sample I.D. Number: 21328
Bin Number: 506
Observed Chemistry of Tested Sample,%:
Al Si Ca Sr
0.41 7 4.2 0.01 0.91
Test 1:
A small quantity (approximately 2 mm diameter) of the above material was
placed in a trough of distilled water at 20° C and observed to see whether any
gas evolved and if it spontaneously ignited. Test 1 was performed in triplicate
on the above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 1 was performed.
Test 2:
A small quantity (approximately 2 mm diameter) of the above material was
floated on a piece of filter paper in distilled water at 20° C and observed to see
whether any gas evolved and if it spontaneously ignited. Test 2 was performed
in triplicate on the above material.
Result:
Neither evolution of gas or spontaneous ignition was observed in any of the
three times Test 2 was performed.
Test 3:
The test material was formed into three piles approximately 2 cm high by 3 cm
wide. An indentation was formed in the top of each pile and a few drops of water
were added to each hollow. Each pile was observed to see whether any gas
evolved and if it spontaneously ignited. Test 3 was performed in triplicate on the
above material.
Result:
Neither evolution of gas nor spontaneous ignition was observed any of the three
times Test 3 was performed.

<<<PAGE 79>>>

Test 4:
Enough water at 20° C to cover the sample, 10ml to 20ml, was added to a
dropping funnel. The spout of the dropping funnel was inserted into one hole of
a #14, two-hole stopper; a tube for conveying any gas produced into the
collection cylinder, a gas buret, was inserted into the other hole of the stopper;
the far end of the tube was inserted into the end of the collection cylinder.
The gas buret is glass, 50 ml capacity, marked in individual ml units with each ml
subdivided into 0.1 ml increments. The gas buret was filled with water, inverted
and stood in a water trough. The gas tube in the previous paragraph was
inserted into the bottom end of the gas buret and any gas produced was
measured by observing the displacement of the water in the top of the buret.
25 g of the above listed material was added to each of three 100 ml conical
flasks with #14 neck size. The stoppers mentioned above were inserted into the
neck of the conical flasks. The stopcocks were opened and 1 0 ml to 20 ml of the
20° C distilled water, enough to completely cover the sample, was allowed to
flow into the flasks. A timer was started and readings of any gas evolved were
taken every hour for five days. From this data the average rate of gas
production per hour was calculated for the five days.
Result:
The Gas Collection data for SRF-75 is detailed on the following page:

<<<PAGE 80>>>

Gas Test on SRF-75 January 16, 1996
!! ___ !!_!!_!!_
ltttt:M 10.0 o.o o.o 0.133 tt\tts.1: 23.0 o.o o.o 0.000 Jtt}M 23.8 o.o o.o 0.000 ttttlfi 23.8 0.5 o.5 0.000
,rnrr:=~ 18.0 o.o o.o 0.107 1,,:rtJZ 23.o o.o o.o 0.000 tttt]t2. 23.8 o.o o.o 0.000 :n=rt=iz 23.8 o.5 o.5 0.000
=rn:rm:r::a 23.o o.o o.o 0.067 it=::tt:aa 23.o o.o o.o 0.000 ttt,t6.3 23.8 o.o o.o 0.000 ttJt:9'.a 23.8 o.5 o.5 0.000
==tf 14 23.0 o.o o.o 0.000 tJ:J:,:a4. 23.o o.o o.o 0.000 IttIFffi1 23.8 o.o o.o 0.000 :=Httt4. 23.8 0.5 0.5 0.000
t:t:@?:$ 23.0 o.o o.o 0.000 =tttlts 23.0 o.o o.o 0.000 :t=l='t65 23.8 o.o o.o 0.000 :m=:=t@lffi 23.8 o.5 0.5 0.000
tk/t@f 23.0 o.o o.o 0.000 ltt:f~i 23.0 o.o o.o 0.000 tktt~ 23.8 o.o o.o 0.000 =t=t='f9$ 23.8 0.5 o.5 0.000
Vi?'?{'1 23.0 0.0 0.0 0.000 t}(/37: 23.0 0.0 0.0 0.000 ttt'(61 23.8 0.0 0.0 0.000 ,:ttti:9:t 23.8 0.5 0.5 0.000
tt'tt~ 23.o o.o o.o 0.000 Jtt==:a~ 23.o o.o o.o 0.000 tmtt~ 23.8 o.o o.o 0.000 :=ttl :® 23.8 o.5 o.5 0.000
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t='tfU 23.0 o.o o.o 0.000 Ittt4t 23.o o.o o.o 0.000 tttttt 23.8 0.5 0.5 0.000 =J=JA:01 23.8 o.5 o.5 0.000
ttt=AZ 23.0 o.o o.o 0.000 ?ttI4Z 23.0 o.o o.o 0.000 tltt:n 23.8 0.5 o.5 0.000 JWM QZ 23.8 o.5 o.5 0.000
:rnrt:1a 23.o o.o o.o 0.000 t/,t4.a 23.o o.o o.o 0.000 1:=r:::m,a 23.8 o.5 o.5 0.000 t:tm:oa 23.8 o.5 o.5 0.000
1 :ttt:14 23.o o.o o.o 0.000 ,::tit44. 23.0 o.o o.o 0.000 kf\IM 23.8 0.5 o.5 0.000 ll''=tQ4 23.8 o.5 o.5 0.000
,,,=:rras 23.o o.o o.o 0.000 r::::=:rn:;w 23.6 o.o o.o 0.008 ,rrrnt.s 23.8 o.5 o.5 0.000 tttios 23.8 o.5 o.5 0.000
:rr:r',,1~ 23.o o.o o.o 0.000 't':th1~ 23.6 o.o o.o 0.000 =:t@I'7t 23.8 o.5 o.5 0.000 t:mnn1~ 23.8 o.5 o.5 0.000
nt:ra1. 23.o o.o o.o 0.000 ':,,ntAt 23.6 o.o o.o 0.000 :::t:ttn 23.8 o.5 o.5 0.000 :ttaot 23.8 o.5 o.5 0.000
=tmn:=111 23.o o.o o.o 0.000 n=::tt~ 23.6 o.o o.o 0.000 =tr,,na 23.8 o.5 o.5 0.000 :=:'tttQJ 23.8 o.5 o.5 0.000
1:tt=t1s 23.o o.o o.o 0.000 ttti:49.' 23.7 o.o o.o 0.001 tt'k79 23.8 o.5 o.5 0.000 ,mtnos: 23.8 o.5 o.5 0.000
1trt:~ 23.0 0.0 0.0 0.000 tk?#iO. 23.8 0.0 0.0 0.001 tt'='t~ 23.8 0.5 0.5 0.000 @t:MJP 23.8 0.5 0.5 0.000
,t]/21: 23.0 0.0 0.0 0.000 )';:'lf51 23.8 0.0 0.0 0.000 =tttatt 23.8 0.5 0.5 0.000 :ntMO 23.8 0.5 0.5 0.000
1 '''t=::miz 23.o o.o o.o 0.000 t'tt=,.a 23.8 o.o o.o 0.000 tt/''~ 23.8 o.5 o.5 0.000 tt'=11z 23.8 o.5 o.5 0.000
ttn::z$ 23.o o.o o.o 0.000 :ttti~ 23.8 o.o o.o 0.000 '='tJt:B.a 23.8 o.5 o.5 0.000 tt':a:,:a: 23.8 o.5 o.5 0.000
r::tnii 23.o o.o o.o 0.000 t:'t<M 23.8 o.o o.o 0.000 t::n:t:M 23.8 o.5 o.5 0.000 tmtt:t4 23.8 o.5 o.5 0.000
it'1=ti2S 23.0 0.0 0.0 0.000 ::,,:,:,5::, 23.8 0.0 0.0 0.000 ttt\6$. 23.8 0.5 0.5 0.000 tit::i:it~ 23.8 0.5 0.5 0.000
::nn:ii 23_0 o.o o.o 0.000 ,rt t~ 23.8 o.o o.o 0.000 m,:,::n~ 23.8 o.5 o.5 0.000 t=tM1$. 23.8 o.5 o.5 0.000
?'ttt21 23.o o.o o.o 0.000 ttti6t 23.8 o.o o.o 0.000 tttnw 23.8 o.5 o.5 0.000 ttJnt 23.8 o.5 o.5 0.000
tn:::::i$ 23.o o.o o.o 0.000 tr====®' 23.8 o.o o.o 0.000 ,,:,=tnJm 23.8 o.5 o.5 0.000 ttMMr 23.8 o.5 o.5 0.000
ttt='Zi 23.0 o.o o.o 0.000 tJ::@$9: 23.8 o.o o.o 0.000 =tt:tJl'9. 23.8 o.5 o.5 0.000 t@M19: 23.8 o.5 0.5 0.000
t'tti® 23.0 o.o o.o 0.000 ?tt ~Q- 23.8 __ o.o o.o 0.000 it=:t: ~ 23.8 0.5 o.5 0.000 l@MiO: 23.8 o.5 o.5 0.000
1. All samples 25 gram.
2.Average rate of gas production in UKg/Hr=Avg produced(ml)x40/1000ml/L DOTSRF75.XLS

<<<PAGE 81>>>

C.C. E. Bredniak
H. Wang
DOT testing of
Stab50 and Unstab50
40x325 mesh material
11/22/2000
Test A:
Place approx 2mm of the test material in a trough of distilled water (at least 20°C) and observe for evolution of
gas. If any evolution observed, check for spontaneous combustion of evolved gases. Pass or Fail test.
Stab50 Unstab50
Trial 1 p p
Trial 2 p p
Trial 3 p p Water temp= 24°C
Test B:
Place approx 2mm of the test material on a piece of filter paper. Float the paper and material in a container with
distilled water (at least 20°C) and observe for gas evolution and spontaneous combustion of any evolved gases.
Pass or Fail test.
Stab50 Unstab50
Trial 1 p p
Trial 2 p p
Trial 3 p p Water temp= 24°C
Test C:
Make a conical pile of the test material, approx 2cm high and 3cm wide at the base. Press a small indention at
the top and fill with distilled water (at least 20°C). Observe for any gas evolution and spontaneous combustion of
any evolved gases. Pass or Fail test.
Stab50 Unstab50
Trial 1 p p
Trial 2 p p
Trial 3 p p Water temp= 24°C
Test D:
Place 25g of material in a 50ml conical flask. Add 35ml of distilled water (at least 20°C) to flask and quickly
stopper with a 1-hole 00 stopper. Stopper hole has glass tubing connected to rubber tubing that leads to the
gas collection buret (Stab50 gas test apparatus). Start timer immediately, noting the initial buret reading for
air displacement. Read gas readings on buret every hour for 7 hours. If, at the 7th hour, the evolution rate is
decreasing or not increasing at all, and if the total gas evolved is less than 40ml/25g of material, the test
material has passed. If the evolution rate is increasing after 7 hours, continue the test for a total period of 5
days.
wt t
a er em~= 23°C
Hour Stab50-1 Stab50-2 Stab50-3 Unstab50-1 Unstab50-2 Unstab50-3
Initial 2.8 2.7 2.9 4.1 3.7 3.7
1 3.4 2.8 3.7 4.9 3.8 4.1
2 3.6 2.9 3.9 5.1 4.2 4.6
3 3.9 3.6 4.2 5.2 4.3 4.7
4 3.9 3.6 4.2 5.5 4.3 4.7
5 3.9 3.6 4.2 5.5 4.6 5.0
6 3.9 3.6 4.2 5.5 4.6 5.0
7 3.9 3.6 4.2 5.5 4.6 5.0
Result p p p p p p

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/74076/200024.pdf>
- Source ID: `phmsa`
- SHA-256: `e4e389b35a8cb7f5f5e9362464d16b7289e8fd01f51dbe66307a2958d6c828d8`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-23T05:52:21.864Z
- Document slug: `phmsa-interpretation-20-0024`

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