CC Metals and Alloys, LLC — Hazardous Materials Safety Interpretation

Page 1U.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 2CC1QQ,: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 3they 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 4CRS 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 5January 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 6Report 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 7Project 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 8Ferrosilicon, 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 9Test 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 10Gas 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 11CRS 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 12January 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 13Report 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 14Project 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 15Ferrosilicon, 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 16Test 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 17Gas 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 18CRS 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 19January 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 20Report 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 21Project 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 22CSF-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 23Test 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 24Gas 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 25CRS 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 26February 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 27Report 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 28Project 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 29Silicon 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 30Test 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 31Gas 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 32CRS 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 33February 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 34Report 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 35Project 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 36Graphidox 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 37Test 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 38Gas 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 39CRS 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 40January 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 41Report 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 42Project 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 43Low-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 44Enough 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 45Gas 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 46CRS 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 47February 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 48Report 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 49Project 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 50lnoculoy 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 51Test 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 52Gas 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 53CRS 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 54January 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 55Report 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 56Project 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 57Noduloy 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 58Test 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 59Gas 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 60CRS 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 61January 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 62Report 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 63Project 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 64Noduloy 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 65Test 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 66Gas 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 67CRS 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 68February 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 69Report 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 70Project 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 71SRF-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 72Test 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 73Gas 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 74CRS 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 75February 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 76Report 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 77Project 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 78SRF-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 79Test 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 80Gas 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 JJ:,,:,tt9 23.o o.o o.o 0.000 ttt\$.9: 23.o o.o o.o 0.000 iftN:$$. 23.8 o.o o.o 0.000 =t?ffS9 23.8 o.5 o.5 0.000 tt'tM~ 23.o o.o o.o 0.000 ttt:~ 23.o o.o o.o 0.000 ::rm:ttQ 23.8 o.5 o.5 0.013 :,,::t4QO: 23.8 o.5 o.5 0.000 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 81C.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#