{"operation":"document","citation":"20-0024","title":"CC Metals and Alloys, LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2020-06-09","effective_on":null,"summary":"20-0024 response to CC Metals and Alloys, LLC concerning 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0024.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0024.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0024","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/74076/200024.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nJune 9, 2020\nJoe Cruse\nQuality / Lab Manager\nCC Metals and Alloys, LLC\n1542 North Main Street\nPO Box 217\nCalvert City, KY 42029\nReference No. 20-0024\nDear Mr. Cruse:\nThis letter is in response to your March 9, 2020, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of\n“UN1408, Ferrosilicon, with 30 percent or more but less than 90 percent silicon.” You state that\nyour company has transported this material as a non-hazardous material based on third-party\ntesting that confirmed that the material does not meet the definition of a Division 4.3 (dangerous\nwhen wet) material. However, you state that the U.S. Coast Guard will not accept the third-party\ntesting information you have previously provided them and you seek confirmation that the\nproduct you transport does not meet the criteria of a Division 4.3 (dangerous when wet) material.\nUnder 49 CFR 173.22, it is the shipper’s responsibility to properly classify a hazardous material\nand such determinations are not required to be verified by this Office. Furthermore, PHMSA\ndoes not certify a shipper’s determination of whether a material is hazardous or not. However,\nbased on the third-party test results you provided with your email, it is the opinion of this Office\nthat the ferrosilicon manufactured by your company does not meet the criteria of a Division 4.3\n(dangerous when wet) material. Note that exclusion from Divisions 4.3 alone does not\nnecessarily indicate that the material is not subject to the HMR. To satisfy the request of the U.S.\nCoast Guard you may consider conducting additional tests to verify that the product does not\nmeet any other hazard classification criteria, (e.g., Division 6.1).\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nCC1QQ,:t\n2() - CX>Q<j\nDodd, Alice (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nAttachments:\nINFOCNTR (PHMSA)\nMonday, March 9, 2020 3:40 PM\nHazmat lnterps\nFW: Request For Formal Letter of Interpretation On Hazmat Classification\nUS DOT HAZ MAT Exemption Testing Results.pdf; Cruse Letter.docx\nHello Alice and lkeya,\nBelow is a request for letter of interpretation with attached PDF test data.\nThanks,\nJonathon, HMIC\nFrom: Joe Cruse [mailto:jcruse@ccmetals.com]\nSent: Monday, March 9, 2020 1:01 PM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nCc: Daniela Rost <d.rost@ftamericas.com>; David Tuten <dtuten@ccmetals.com>\nSubject: Request For Formal Letter of Interpretation On Hazmat Classification\nGood afternoon,\nI was referred to this email address by Josh, at the USDOT Hazmat Hotline. We are requesting a formal letter of\ninterpretation on the results of our testing of the Ferrosilicon products {Si >30% and <90% content ) we produce and\nship at CC Metals and Alloys, LLC in Calvert City, KY. This facility performed the testing, as prescribed for materials\nclassification in 49 CFR Section 173, Appendix E, Division 4 {Sections 1-4), in the 1990's, when the facility was owned by\nVIAG, and was named SKW Metals and Alloys, Inc.\nTo give some background to our situation, the company produces Ferrosilicon at its single-site production facility in\nCalvert City, KY, located on the banks of the Tennessee River. We ship our product to both domestic and foreign\nlocations via truck, railcar, barge, and sea container. In the mid-1990's, our company (as SKW Metals and Alloys, Inc.),\nalong with all of our other North American and European competitors, undertook a testing regimen of our Ferrosilicon\nper 49 CFR Section 173, Appendix E, Division 4 {Sections 1-4). We performed all testing in-house, and also had a third\nparty laboratory perform the same testing, on our entire line of Ferrosilicon products. In all cases, our testing results (in-\nhouse lab and third party lab) all demonstrated that none of our Ferrosilicon products met the criteria for classification\nas \"Hazardous When Wet\" materials, per the criteria contained within 49 CFR, Section 173, Appendix E, Division 4. Our\ncompetitors testing showed the same conclusions. At that point, we determined that our entire product line of\nFerrosilicon was not subject to HMR, as did our competitors. Today, this facility, as CC Metals and Alloys, LLC, still\nproduces those same Ferrosilicon products, under the same production methods and environment; there has been no\nchange to the composition or other aspects of the products we produce and ship here.\nA short time ago, our company was approached by the US Coast Guard's Marine Safety Unit, based out of Paducah, KY,\nto inquire as to why we ship our Ferrosilicon products from our river dock facility without the hazmat classification.\nWe've shared our testing results and our formal declaration of our product not meeting hazard class and that the\nproducts are not subject to HMR. They are not satisfied with this, and are looking for some kind of formal response from\nUSDOT on our determination. In my phone conversation with the Hazmat Hotline, Josh suggested I contact you via email\non 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\nShipper to demonstrate that our products do not meet the criteria of Division 4.3 or other hazard classes, to show that\n1\n\n<<<PAGE 3>>>\n\nthey are not subject to the HMR. We believe we have successfully done so. We are asking USDOT to review our testing\nresults, and issue to us a formal letter of interpretation of our testing results that we can show to the US Coast Guard\nMSU, and satisfy their request. We appreciate your help in this matter, and if you have any additional questions on this\nmatter, please do not hesitate to call or email me, per my contact information below.\nThank you,\nJoe Cruse\nQuality/Lab Mgr\nCC Metals and Alloys, LLC\n1542 North Main Street (PO Box 217}\nCalvert City, KY 42029\n270.395.2103 (Office)\n270.703.8833 (cell)\n2\n\n<<<PAGE 4>>>\n\nCRS Project Number: S-6747\nJanuary 27, 1997\nMr. Timothy H. Hall\nSKW Metals and Alloys, Inc.\nP.O. Box 217\nCalvert City, Kentucky 42029\nDangerous When Wet Materials (as set forth in 49 CFR Section 173,\nAppendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of 50% FeSi,\nRegular, Lab ID: 2124A, Bin Number: 300.\nDear Mr. Hall:\nWe have completed our gas evolution measurements and the flammability tests,\nper Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample\nmaterial that you submitted in late December 1996. The material we received from\nSKW was labeled as: 50% FeSi, Regular. The results were as follows:\n(1) no gas was evolved and no spontaneous ignition occurred.\n(2) no gas was evolved and no spontaneous ignition occurred.\n(3) no gas was evolved and no spontaneous ignition occurred.\n(4) while some gas did evolve, the average rate never exceeded 1 liter per\nkilogram per hour in the sample tested. The gas was not flammable nor\ndid it spontaneously ignite in any of the tests.\nOn the basis of these test results, the ferrosilicon material listed above\nwould not fit the definition in 49 CFR Section 173, Appendix E, Division 4,\nSections 1, 2, 3 and 4 as \"Dangerous When Wet\" .\nSincerely,\n~V\\tt'_& le.. l~-- j \\~ ~ - lL_. ~· 1\"\" V'~\nJam~s R. Lakin . ~j'l'X\"'\"'' ~] ksoc.ic.1\nBusiness Operations Manager\n\n<<<PAGE 5>>>\n\nJanuary 27, 1997\nMr. Timothy H. Hall\nSKW Metals and Alloys, Inc.\nP . O. Box 217\nCalvert City, Kentucky 42029\nRe: Gas Evolution Measurements and Flammability Tests.\nCRS Project Number: S-6747\nDear Mr. Hall:\nWe have completed the gas evolution measurements and the flammability tests,\nper Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample\nmaterial that you submitted in late December 1996. The identification of the\nmaterial submitted and its chemistry specification are listed below.\n50% FeSi, Regular Al Si Cr Mn Ti Ca p\nSpecification, % : <1.25 47-51 <0.2 <0.75 <0.1 <0.3\nLab ID: 2124A\nBin Number: 300\nChemistry: 0.19 47.30 0.12 0.37 0. 041 0 . 00 0.030\nSection 1 (Procedure & Results)\nA small piece of the aforementioned material, approximately 2 mm in diameter,\nwas placed in a trough of distilled water at 20°C. No gas evolution was observed,\nnor did the sample spontaneously ignite.\nSection 2 (Procedure & Results)\nA small piece of the material was placed in the center of a filter paper,\nwhich was floating in distilled water at 20°C. No gas evolution was observed, nor\ndid the sample spontaneously ignite.\nSection 3 (Procedure & Results)\nA small pile with an indentation in the center, approximately 2cm high by 3cm\nin diameter, was made of the material . A few drops of water were added to the\nhollow. No gas evolution was observed, nor did any of the sample spontaneously\nignite.\nSection 4 (Procedure & Results)\nRepresentative samples were taken from the lot of material submitted, and\nusing a hammer and chisel the pieces were crushed individually. The larger pieces\nand the fines were screened off from each sample. Only material of +20 mesh to -8\nmesh was used in the gas evolution tests. Three reaction vessels were set-up and\nfilled with a deionized water. The reaction vessels were 1000 ml beakers each\ncontaining a small flask with 25.0 grams of sample material. Above each small\nflask a 50 ml buret was positioned up-side-down, which was also filled with\ndeionized water and placed over the end of the flask making a water seal. The\nlevel in the buret was monitored for the next 5 days. Gas evolution data, measured\nin milliliters, is attached .\nFollowing the gas evolution tests, the burets were submerged, still up-side-\ndown, up to the stopcocks in water. A small flame was placed near the tip of the\n\n<<<PAGE 6>>>\n\nReport S-6747\nburet and the stopcock was opened to allow the gas inside the burets to be pushed\nout into the flame by the water pressure. Flammability observations are noted at\nthe bottom of the gas evolution data . The gas was not analyzed to determine its\ncomposition.\nIf you have questions about the test or these results please contact me.\nThank you for doing business with us.\nSincerely,\n2 of 3\n\n<<<PAGE 7>>>\n\nProject S-6747 (sheet 3)\nGas Evolution Measurements\n(Water Volume Displacement)\n50% FeSi\n1 2\n(mil (mil\nAvg Rate\n3 (I/kg/hr)\nTime\n(hours)\nDay 1 0.00\n1.00\n2.00\n3.00\n4.00\n5.00\n6.00\n7.00\n8.00\n17.50\nDay 2 26.00\n41.50\nDay 3 50.00\n65.50\nDay 4 89.50\nDay 5 98.00\nFlammable (Fl\nlgnitible (I) *\nNot Flammable (NF)\n(ml)\n0.0 0.0\n0.0 0.0\n0.0 0.0\n0.0 0.0\n0.0 0.0\n0.0 0.0\n0.1 0.1\n0.1 0.1\n0.1 0.1\n0.1 1 . 1\n0 .2 2.0\n1.2 15.8\n2 .3 23.3\n3.4 32.3\n9.3 44.8\n11 .2 47.2\n0.0\n0.0 0.000\n0.0 0.000\n0.0 0.000\n0 .0 0 .000\n0 .0 0 .000\n0.0 0.003\n0.0 0.001\n0 .0 0.000\n0.2 0.002\n1.0 0.003\n4.2 0.015\n7 .4 0.019\n13.4 0.014\n23.5 0.016\n26 .3 0 .011\nX X\nX\n* lgnitible = the gas will ignite but will not sustain a continuous flame.\n3 of 3\n\n<<<PAGE 8>>>\n\nFerrosilicon, 50%, Regular Grade\nSpecification Chemistry, %:\nAl Si Cr\n<1.25 47-51 <0.20\nMn\n<0.75\nTi\n<0.10\nCa\n<0.30\np\nSample I.D. Number: 21248\nBin Number: 300\nObserved Chemistry of Tested Sample, %:\nAl Si Cr Mn\n0.19 47.30 0.12 0.37\nTi\n0.041\nCa\n0.00\np\n0.030\nTest 1:\nA small quantity (approximately 2 mm diameter) of the above material was\nplaced in a trough of distilled water at 20° C and observed to see whether any\ngas evolved and if it spontaneously ignited. Test 1 was performed in triplicate\non the above material.\nResult:\nNeither evolution of gas nor spontaneous ignition was observed any of the three\ntimes Test 1 was performed.\nTest 2:\nA small quantity (approximately 2 mm diameter) of the above material was\nfloated on a piece of filter paper in distilled water at 20° C and observed to see\nwhether any gas evolved and if it spontaneously ignited. Test 2 was performed\nin triplicate on the above material.\nResult:\nNeither evolution of gas or spontaneous ignition was observed in any of the\nthree times Test 2 was performed.\nTest 3:\nThe test material was formed into three piles approximately 2 cm high by 3 cm\nwide. An indentation was formed in the top of each pile and a few drops of water\nwere added to each hollow. Each pile was observed to see whether any gas\nevolved and if it spontaneously ignited. Test 3 was performed in triplicate on the\nabove material.\nResult:\nNeither evolution of gas nor spontaneous ignition was observed any of the three\ntimes Test 3 was performed.\n\n<<<PAGE 9>>>\n\nTest 4:\nEnough water at 20° C to cover the sample, 10ml to 20ml, was added to a\ndropping funnel. The spout of the dropping funnel was inserted into one hole of\na #14, two-hole stopper; a tube for conveying any gas produced into the\ncollection cylinder, a gas buret, was inserted into the other hole of the stopper;\nthe far end of the tube was inserted into the end of the collection cylinder.\nThe gas buret is glass, 50 ml capacity, marked in individual ml units with each ml\nsubdivided into 0.1 ml increments. The gas buret was filled with water, inverted\nand stood in a water trough. The gas tube in the previous paragraph was\ninserted into the bottom end of the gas buret and any gas produced was\nmeasured by observing the displacement of the water in the top of the buret.\n25 g of the above listed material was added to each of three 100 ml conical\nflasks with #14 neck size. The stoppers mentioned above were inserted into the\nneck of the conical flasks. The stopcocks were opened and 10 ml to 20 ml of the\n20° C distilled water, enough to completely cover the sample, was allowed to\nflow into the flasks. A timer was started and readings of any gas evolved were\ntaken every hour for five days. From this data the average rate of gas\nproduction per hour was calculated for the five days.\nResult:\nThe Gas Collection data for Ferrosilicon, 50%, Regular Grade is detailed on the\nfollowing page:\n\n<<<PAGE 10>>>\n\nGas Test on Regular Grade 50% FeSi January 24, 1996\n!!_!!_.!!_!!_ :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\ntr: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\nttttt, 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\n<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\nk}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\n■ g:g g : g g:g g:ggg lljlJl!J!Jl!:!:!!:!! g:: g: ~ g : i g : ggg /!\n1\n:!!!!i!!!!/i!!!! g:; g : i g:i g:ggg !i!!!i!i!!i/!\n1\n!:i!! g:; g:: g:; g:g~g\nt'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\ntttMQ 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\n)'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: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\ntttf/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\n::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\ntttn5 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\ntttt: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\nitit@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·\ni'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_\n=::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\n.\n1 :::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_\n=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\nritttt2: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·\nc,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.\nim::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_\nt')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\nt\\Jttt?6: 0.2 o .o o.o 0.003 ;ffttf$.6\\ 0.6 o.3 o.s 0.000 ff{fI~- 0.7 a.a 0.7 0.003 tttf1l1!&. o.7 o.a 0.7 0.000·\n:t=ttzt 0.2 o.o o.o 0.000 tt?ts.t 0.6 o.3 o.5 0.000 l?tJ:W: 0.7 o.8 o.7 0.000 =tt:Mift o.7 0.8 o.7 0.000\n.\n=ItFi$ 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_\n: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.\n::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\n1. All samples 25 gram.\n2.Average rate of gas production in UKg/Hr=Avg produced(ml)x40/1000ml/L OOTSOREG.XLS\n\n<<<PAGE 11>>>\n\nCRS Project Number: S-6747\nJanuary 27, 1997\nMr. Timothy H. Hall\nSKW Metals and Alloys, Inc.\nP.O. Box 217\nCalvert City, Kentucky 42029\nDangerous When Wet Materials (as set forth in 49 CFR Section 173,\nAppendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of 75% FeSi,\nRegular, Lab ID: 2125A, Bin Number: 14 Fee.\nDear Mr. Hall:\nWe have completed our gas evolution measurements and the flammability tests,\nper Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample\nmaterial that you submitted in late December 1996. The material we received from\nSKW was labeled as: 75% FeSi, Regular. The results were as follows:\n(1) no gas was evolved and no spontaneous ignition occurred.\n(2) no gas was evolved and no spontaneous ignition occurred.\n(3) no gas was evolved and no spontaneous ignition occurred.\n(4) while some gas did evolve, the average rate never exceeded 1 liter per\nkilogram per hour in the sample tested. The gas was flammable and\nignitible (gas ignited but would not sustain a continuous flame). It\ndid not spontaneously ignite in any of the tests.\nOn the basis of these test results, the ferrosilicon material listed above\nwould not fit the definition in 49 CFR Section 173, Appendix E, Division 4,\nSections 1, 2, 3 and 4 as \"Dangerous When Wet\".\nSincerely,\n~wti g_ L.-'\"1J.i~ I bJ\nJames R. Lakin\nBusiness Operations\n~£\\tLl ,c L -1'\\'\\ ~v. ~s:§\nEv-g-~• e;,\\.~J /\\¼ocJ.:,1\nManager\n\n<<<PAGE 12>>>\n\nJanuary 27, 1997\nMr. Timothy H. Hall\nSKW Metals and Alloys, Inc.\nP . O. Box 217\nCalvert City, Kentucky 42029\nRe: Gas Evolution Measurements and Flammability Tests.\nCRS Project Number: S-6747\nDear Mr. Hall :\nWe have completed the gas evolution measurements and the flammability tests,\nper Code 49 CFR 173 , Appendix E division 4, Sections 1, 2, 3 and 4, on the sample\nmaterial that you submitted in late December 1996 . The identification of the\nmaterial submitted and its chemistry specification are listed below.\n75% FeSi, Regular Al Si Cr Mn Ti Ca p\nSpecification, %-: <1.50 74-79 <0.3 <0.4 <0.2 <0.6\nLab ID: 2125A\nBin Number: 14 Fee\nChemistry : 0.054 76.30 0.06 0.19 0.052 0.41 0.013\nSection 1 (Procedure & Results)\nA small piece of the aforementioned material, approximately 2 mm in diameter,\nwas placed in a trough of distilled water at 20°C. No gas evolution was observed,\nnor did the sample spontaneously ignite.\nSection 2 (Procedure & Results)\nA small piece of the material was placed in the center of a filter paper,\nwhich was floating in distilled water at 20°C. No gas evolution was observed, nor\ndid the sample spontaneously ignite.\nSection 3 (Procedure & Results)\nA small pile with an indentation in the center, approximately 2cm high b y 3cm\nin diameter, was made of the material. A few drops of water were added to the\nhollow. No gas evolution was observed, nor did any of the sample spontaneously\nignite.\nSection 4 (Procedure & Results)\nRepresentative samples were taken from the lot of material submitted, and\nusing a hammer and chisel the pieces were crushed individually. The larger pieces\nand the fines were screened off from each sample. Only material of +20 m esh to -8\nmesh was used in the gas evolution tests. Three reaction vessels were set-up and\nfilled with a deionized water. The reaction vessels were 1000 ml beakers each\ncontaining a small flask with 25.0 grams of sample material. Above each small\nflask a 50 ml buret was positioned up-side-down, which was also filled with\ndeionized water and placed over the end of the flask making a water seal. The\nlevel in the buret was monitored fo r the next 5 days. Gas evolution data, measured\nin milliliters, is attached.\nFollowing the gas evolution tests, the burets were submerged, still up-side-\ndown, up to the stopcocks in water . A small flame was placed near the tip of the\n\n<<<PAGE 13>>>\n\nReport S-6747\nburet and the stopcock was opened to allow the gas inside the burets to be pushed\nout into the flame by the water pressure. Flammability observations are noted at\nthe bottom of the gas evolution data. The gas was not analyzed to determine its\ncomposition.\nIf you have questions about the test or these results please contact me.\nThank you for doing business with us.\nSincerely,\nj (i,tr/V,_e<;. e. La.b,., I 6J ~l2lt,e- 'l' -W~o-t\\,~ . .. ' . ' .\n. G\"'~; N cr \\V-\\.''l l\\~soc,o., k.\nJam7s R. Lakin . 0 · · ,_J\nBusiness Operations Manager\n2 of 3\n\n<<<PAGE 14>>>\n\nProject S-6747 (sheet 4)\nGas Evolution Measurements\n(Water Volume Displacement)\n75% FeSi\n2\n(ml) (ml)\nAvg Rate\n3 (I/kg/hr)\nTime\n(hours)\nDay 1 0.00\n1.00\n2.00\n3.00\n4.00\n5.00\n6.00\n7.00\n8.00\n17.50\nDay 2 26.00\n41 .50\nDay 3 50.00\n65.50\nDay 4 89.50\nDay 5 98.00\nFlammable (F)\nlgnitible (I)*\nNot Flammable (NF)\n(ml)\n0.0 0.0\n0.2 0.2\n0.4 0.5\n0.8 0.6\n1.0 1.0\n1.3 0.8\n1.4 0.9\n1.2 1.3\n2.1 1.3\n4.4 3.6\n6.5 5.3\n9.1 11 . 1\n11.4 15.8\n15.4 22.7\n18.0 34.0\n20.1 36.1\nX X\n0.0\n0.3 0.009\n0.5 0.009\n0.8 0.011\n1.6 0 .019\n1 . 1 -0.005\n1.5 0.008\n1.8 0.007\n2.0 0.011\n6.1 0.012\n8.0 0 .009\n16.2 0 .014\n26.1 0.027\n34.6 0.017\n46.6 0.014\n48.7 0.010\nX\n* lgnitible = the gas will ignite but will not sustain a continuous flame.\n3 of 3\n\n<<<PAGE 15>>>\n\nFerrosilicon, 75%, Regular Grade\nSpecification Chemistry, %:\nAl Si Cr\n<1.5 74-79 <0.30\nMn\n<0.40\nTi\n<0.20\nCa\n<0.60\np\nSample I.D. Number: 2125A\nBin Number: 14 Fee\nObserved Chemistry of Tested Sample, %:\nAl Si Cr Mn\n0.05 76.30 0.06 0.19\nTi\n0.052\nCa\n0.41\np\n0.013\nTest 1:\nA small quantity (approximately 2 mm diameter) of the above material was\nplaced in a trough of distilled water at 20° C and observed to see whether any\ngas evolved and if it spontaneously ignited. Test 1 was performed in triplicate\non the above material.\nResult:\nNeither evolution of gas nor spontaneous ignition was observed any of the three\ntimes Test 1 was performed.\nTest 2:\nA small quantity (approximately 2 mm diameter) of the above material was\nfloated on a piece of filter paper in distilled water at 20° C and observed to see\nwhether any gas evolved and if it spontaneously ignited. Test 2 was performed\nin triplicate on the above material.\nResult:\nNeither evolution of gas or spontaneous ignition was observed in any of the\nthree times Test 2 was performed.\nTest 3:\nThe test material was formed into three piles approximately 2 cm high by 3 cm\nwide. An indentation was formed in the top of each pile and a few drops of water\nwere added to each hollow. Each pile was observed to see whether any gas\nevolved and if it spontaneously ignited. Test 3 was performed in triplicate on the\nabove material.\nResult:\nNeither evolution of gas nor spontaneous ignition was observed any of the three\ntimes Test 3 was performed.\n\n<<<PAGE 16>>>\n\nTest 4:\nEnough water at 20° C to cover the sample, 10 ml to 20 ml, was added to a\ndropping funnel. The spout of the dropping funnel was inserted into one hole of\na #14, two-hole stopper; a tube for conveying any gas produced into the\ncollection cylinder, a gas buret, was inserted into the other hole of the stopper;\nthe far end of the tube was inserted into the end of the collection cylinder.\nThe gas buret is glass, 50 ml capacity, marked in individual ml units with each ml\nsubdivided into 0.1 ml increments. The gas buret was filled with water, inverted\nand stood in a water trough. The gas tube in the previous paragraph was\ninserted into the bottom end of the gas buret and any gas produced was\nmeasured by observing the displacement of the water in the top of the buret.\n25 g of the above listed material was added to each of three 100 ml conical\nflasks with #14 neck size. The stoppers mentioned above were inserted into the\nneck of the conical flasks. The stopcocks were opened and 10 ml to 20 ml of the\n20° C distilled water, enough to completely cover the sample, was allowed to\nflow into the flasks. A timer was started and readings of any gas evolved were\ntaken every hour for five days. From this data the average rate of gas\nproduction per hour was calculated for the five days.\nResult:\nThe Gas Collection data for Ferrosilicon, 75\n%, Regular Grade is detailed on the following page:\n\n<<<PAGE 17>>>\n\nGas Test on Regular Grade 75% FeSi\nJanuary 24, 1996\nAvg\nAvg\nAvg\nAvg\nRime\n2\n3\nRate\nJime\nRate\ntime\nRate\nrime\nRate\nHr.\nmil\n(ml)\n(ml)\nL/Ka/Hr\n(ml)\n(ml)\n(ml)\nLIKa/Hr\n(iml)\n(ml\n0.1\n(ml).\nL/Kg/Hr\nHr.\n(m)\n0.\n0\n0.0\n0.\n0.000\n31\n0.7\n0.6\n1.0\n0.009\n61\n1.9\n2.2\n0.000\n(ml)\n(ml)\n1.9\n0.1\n2.2\nL/Kg/Hr\n91\n0.000\n2\n0.\n0.\n0.\n0,000\n32\n0.7\n0.1\n1.1\n-0.005\n62\n1.9\n0.1\n2.2\n0,000\n92\n1.9\n0.1\n2.2\n0.000\n3\n0\n0.000\n1.0\n0.1\n1.2\n0.005\n63\n1.9\n0.1\n2.2\n0.000\n93\n1.9\n0.1\n2.2\n0.000\n0.\n000\n34\n1.1\n0.1\n1.3\n0.003\n64\n1.9\n0.1\n2.2\n0.000\n94\n1.9\n0.1\n2.2\n0,000\nGOO\n35\n1.2\n0.1\n1.5\n0,004\n65\n1.9\n0.\n1\n2.2\n0,000\n95\n1.9\n0.\n2.2\n0.000\n00\n36\n1.4\n0.1\n1.7\n0.005\n66\n1.9\n0.1\n2.2\n0.000\n-96\n1.9\n0.1\n2.2\n0.000\n0\n00O\n37\n1.6\n0.1\n1.8\n0.004\n67\n1.9\n0.1\n2.2\n0.000\n97\n1.9\n0.1\n2.2\n0.000\n000\n38\n1.7\n0.1\n1.9\n0.003\n68\n1.9\n0.\n2.2\n0,000\n98\n1.9\n0.\n1\n2.2\n0,000\n0.0\n39\n1.7\n0.1\n2.0\n0.001\n69\n1.9\n0.1\n2.2\n0.000\n99\n1.9\n0.1\n2.2\n0.000\n10:\n000\n40\n1.9\n0.1\n2.1\n0.004\n70\n1.9\n0.1\n2.2\n0.000\n100\n1.9\n0.1\n2.2\n0.000\n000\n41\n1.9\n0.1\n2.2\n0.001\n71\n1.9\n0.1\n2.2\n0.000\n101\n1.\n.9\n0.\n1\n2.2\n0.000\n12\n.000\n42\n1.9\n0.1\n2.2\n0.000\n12\n1.9\n0.1\n2.2\n0.000\n102\n1.9\n0.1\n2.2\n0.000\n0.\n000\n1.9\n0.1\n2.2\n0.000\n79\n1.9\n0.1\n2.2\n0.000\n104\n103\n1.9\n0.1\n2.2\n0.000\n0.0\n0.0\n0,000\n1.9\n0.1\n2.2\n0.000\n1.9\n0.1\n0.000\n0,000\n0.\n.0\n0.0\n.0\n0.000\n1.9\n0.1\n2.2\n0.000\n1.9\n0.1\n0.000\n105\n1\n0.000\n0.\n.0\n0.\n000\n0.1\n2.2\n0.000\n1.9\n0.1\n2.2\n0,000\n.9\n0.\n2.\n2\n0,000\n0.\n0.\n000\n1.\n0.1\n2.2\n0.000\n1.9\n0.1\n2.2\n0.000\n07\n1\n.9\n0.\n2\n0.000\n0.\n000\n0.1\n2.2\n0.000\n78\n1.9\n0.1\n2.2\n0.000\n188\n0\n1\n2.\n2\n000\n0.\n0\n000\n0.\n1\n2.2\n0,000\n79\n1.9\n0.1\n2.2\n0,000\n0.\n2\n2\n0.\n.000\n1.\n9\n2.2\n0.000\n80\n1.9\n0.1\n2.2\n0.000\n0.\n2\n2\n000\n1.\n9\n1\n2.2\n0.000\n100\n1.\n9\n2.2\n0.000\n81\n1.9\n0.1\n2.\n2\n0.000\n82\n1.9\n0.1\n2.2\n1.000\n0.0\n0.000\n1.9\n0.\n1\n2.\n2\n0.000\n1.9\n0.1\n2.2\n0.\n.000\n0,000\n0.0\n0.0\n988888888888\n0.000\n1.9\n1\n2.2\n0.000\n1.9\n0.1\n2.2\naLla\n0.000\n0.000\n1.9\n0.1\n2.2\n0.000\n1.9\n0.1\n2.2\n0.000\n0.0\n0.3\n0.004\n1.\n9\n0.\n2.2\n0.000\n86\n1.9\n0.1\n2.2\n0.\n.1\n2.2\n0.000\n0.0\n0.4\n0.001\n1.\n9\n0.1\n2.2\n0.000\n67]\n1.9\n0.1\n2.2\n17\n0.\n1\n2.2\n0.2\n0.5\n0.004\n1\n9\n0.1\n2.2\n0.000\n88.\n1.9\n0.1\n2.2\n118\n0\n1\n2.2\n0.5\n0.7\n0.008\n1\n.9\n0.\n.1\n2.2\n0.000\n0.6\n0.9\n0.004\n1.\n.9\n1\n2.2\n0.000\n38\n1.\n.9\n0.1\n2.2\n0.000\n119\n0.\n1\n2.2\n0.000\n1.\n0.1\n2.2\n0.000\n120\n0.\n2.2\n0.000\n1. All samples 25 gram.\n2. Average rate of gas production in L/Kg/Hr=Avg produced(ml)x40/1000m/L\nDOT75REG.XLS\n\n<<<PAGE 18>>>\n\nCRS Project Number: S-6747\nJanuary 27, 1997\nMr. Timothy H. Hall\nSKW Metals and Alloys, Inc.\nP.O. Box 217\nCalvert City, Kentucky 42029\nDangerous When Wet Materials (as set forth in 49 CFR Section 173,\nAppendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of CSF 10, Lab ID:\n2130A, Bin Number: 312.\nDear Mr. Hall:\nWe have completed our gas evolution measurements and the flammability tests,\nper Code 49 CFR 173, Appendix E division 4, Sections I, 2, 3 and 4, on the sample\nmaterial that you submitted in late December 1996. The material we received from\nSKW was labeled as: CSF 10. The results were as follows:\n(1) no gas was evolved and no spontaneous ignition occurred.\n(2) no gas was evolved and no spontaneous ignition occurred.\n(3) no gas was evolved and no spontaneous ignition occurred.\n(4) while some gas did evolve, the average rate never exceeded 1 liter per\nkilogram per hour in the sample tested. The gas was not flammable but\nwas ignitible (gas ignited but would not sustain a continuous flame).\nIt did not spontaneously ignite in any of the tests.\nOn the basis of these test results, the ferrosilicon material listed above\nwould not fit the definition in 49 CFR Section 173, Appendix E, Division 4,\nSections I, 2, 3 and 4 as \"Dangerous When Wet\".\nSincerely,\n'i~·WWJ i. ~E,k; .. , I bj ~~-( (:- . ~ , 1M~/i~)E:\nJames R. Lakin ~i,¼?L-'r; ,.._)A. • '.\nBusiness Operations Manager n~~Dc\\ttl2\n\n<<<PAGE 19>>>\n\nJanuary 27, 1997\nMr. Timothy H. Hall\nSKW Metals and Alloys, Inc.\nP . O. Box 217\nCalvert City, Kentucky 42029\nRe: Gas Evolution Measurements and Flammability Tests.\nCRS Project Number: S-6747\nDear Mr. Hall:\nWe have completed the gas evolution measurements and the flammability tests,\nper Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample\nmaterial that you submitted in late December 1996. The identification of the\nmaterial submitted and its chemistry specification are listed below.\nCSF 10 Al Si Ce TRE\nSpecification, % : <1.5 50-55 9-11 10.5-15\nLab ID: 2130A\nBin Number: 312\nChemistry: 0.47 37.90 9 . 65 10.76\nSection 1 (Procedure & Results)\nA small piece of the aforementioned material, approximately 2 mm in diameter,\nwas placed in a trough of distilled water at 20°C. No gas evolution was observed,\nnor did the sample spontaneously ignite.\nSection 2 (Procedure & Results)\nA small piece of the material was placed in the center of a filter paper,\nwhich was floating in distilled water at 20°C. No gas evolution was observed, nor\ndid the sample spontaneously ignite.\nSection 3 (Procedure & Results)\nA small pile with an indentation in the center, approximately 2cm high by 3cm\nin diameter, was made of the material. A few drops of water were added to the\nhollow. No gas evolution was observed, nor did any of the sample spontaneously\nignite.\nSection 4 (Procedure & Results)\nRepresentative samples were taken from the lot of material submitted, and\nusing a hammer and chisel the pieces were crushed individually . The larger pieces\nand the fines were screened off from each sample . Only material of +20 mesh to -8\nmesh was used in the gas evolution tests. Three reaction vessels were set-up and\nfilled with a deionized water. The reaction vessels were 1000 ml beakers each\ncontaining a small flask with 25.0 grams of sample material. Above each small\nflask a 50 ml buret was positioned up-side-down, which was also filled with\ndeionized water and placed over the end of the flask making a water seal. The\nlevel in the buret was monitored for the next 5 days . Gas evolution data, measured\nin milliliters, is attached .\nFollowing the gas evolution tests, the burets were submerged, still up-side-\ndown, up to the stopcocks in water. A small flame was placed near the tip of the\n\n<<<PAGE 20>>>\n\nReport S-6747\nburet and the stopcock was opened to allow the gas inside the burets to be pushed\nout into the flame by the water pressure. Flammability observations are noted at\nthe bottom of the gas evolution data. The gas was not analyzed to determine its\ncomposition.\nIf you have questions about the test or these results please contact me.\nThank you for doing business with us.\nSincerely,\n2 of 3 ·\n\n<<<PAGE 21>>>\n\nProject S-6747 (sheet 6)\nGas Evolution Measurements\n(Water Volume Displacement)\nCSF 10\n2 3\n(ml) (ml) (ml)\nAvg Rate\n(I/kg/hr)\nTime\n(hours)\nDay 1 0.00\n1.00\n2.00\n3.00\n4.00\n5.00\n6.00\n7.00\n8 .00\nDay 2 22.25\nDay 3 46.25\n54.75\nDay 4 70.25\nDay 5 98.75\n0.0 0.0 0.0\n0.1 0.1 0.1\n0.1 0 .1 0.3\n0 .2 0.2 1 . 1\n0.2 0.2 1.2\n0.2 0 .3 3.1\n0.2 0.4 5.8\n0.3 0.9 7.3\n0.3 0.9 7.5\n0.8 1.2 22.2\n4.0 34.8 46.3\n5.4 39.2 48.2\n8.1 44.3 50.0\n13.8 49.8 50.0\n0.004\n0.003\n0.013\n0.001\n0.027\n0.037\n0.033\n0.015\n0.015\n0.034\n0.012\n0.008\n0.005\nFlammable (F)\nlgnitible (I)*\nNot Flammable (NF)\nX\nX X\n* lgnitible = the gas will ignite but will not sustain a continuous flame.\n3 of 3\n\n<<<PAGE 22>>>\n\nCSF-10\nSpecification Chemistry, %:\n~ Si Ce\n<1.50 35-40 9-11\nTRE\n10.5-15\nSample I.D. Number: 21308\nBin Number: 312\nObserved Chemistry of Tested Sample,%:\nAl Si Ce TRE\n0.19 37.90 9.65 10.76\nTest 1:\nA small quantity (approximately 2 mm diameter) of the above material was\nplaced in a trough of distilled water at 20° C and observed to see whether any\ngas evolved and if it spontaneously ignited. Test 1 was performed in triplicate\non the above material.\nResult:\nNeither evolution of gas nor spontaneous ignition was observed any of the three\ntimes Test 1 was performed.\nTest 2:\nA small quantity ( approximately 2 mm diameter) of the above material was\nfloated on a piece of filter paper in distilled water at 20° C and observed to see\nwhether any gas evolved and if it spontaneously ignited. Test 2 was performed\nin triplicate on the above material.\nResult:\nNeither evolution of gas or spontaneous ignition was observed in any of the\nthree times Test 2 was performed.\nTest 3:\nThe test material was formed into three piles approximately 2 cm high by 3 cm\nwide. An indentation was formed in the top of each pile and a few drops of water\nwere added to each hollow. Each pile was observed to see whether any gas\nevolved and if it spontaneously ignited. Test 3 was performed in triplicate on the\nabove material.\nResult:\nNeither evolution of gas nor spontaneous ignition was observed any of the three\ntimes Test 3 was performed.\n\n<<<PAGE 23>>>\n\nTest 4:\nEnough water at 20° C to cover the sample, 10ml to 20ml, was added to a\ndropping funnel. The spout of the dropping funnel was inserted into one hole of\na #14, two-hole stopper; a tube for conveying any gas produced into the\ncollection cylinder, a gas buret, was inserted into the other hole of the stopper;\nthe far end of the tube was inserted into the end of the collection cylinder.\nThe gas buret is glass, 50 ml capacity, marked in individual ml units with each ml\nsubdivided into 0.1 ml increments. The gas buret was filled with water, inverted\nand stood in a water trough. The gas tube in the previous paragraph was\ninserted into the bottom end of the gas buret and any gas produced was\nmeasured by observing the displacement of the water in the top of the buret.\n25 g of the above listed material was added to each of three 100 ml conical\nflasks with #14 neck size. The stoppers mentioned above were inserted into the\nneck of the conical flasks. The stopcocks were opened and 10ml to 20ml of the\n20° C distilled water, enough to completely cover the sample, was allowed to\nflow into the flasks. A timer was started and readings of any gas evolved were\ntaken every hour for five days. From this data the average rate of gas\nproduction per hour was calculated for the five days.\nResult:\nThe Gas Collection data for CSF-10 is detailed on the following page:\n\n<<<PAGE 24>>>\n\nGas Test on CSF-10\nJanuary 24, 1996\nAvg\nAvg\nAvg\nAvg\nTime\nRate\nJime\nRate\nime\nRate\nTime\nRate\n(ml)\n(ml)\nL/Kg/Hr\nHr.\n(m)\n(mi)\n(ml)\nL/Kg/He\nHr.\n(mi)\n0.0\n(ml)\n(ml)\nHr.\n(ml)\n(ml)\n(ml)\nL/Kg/Hr\n0.\n0.0\n1.\n.0\n0.013\n31\n0.0\n0.0\n1.0\n0.000\n61\n0.0\n4.0\n0.000\n81\n0.0\n0.0\n4.0\n0.000\n0.\n0\n. 0\n0.000\n3\n12\n0.0\n0.0\n1.0\n0.000\n62\n0.0\n0.\n4.0\n0,000\n92\n0.0\n0.0\n4.0\n0,000\nLO\n0\n0\n.0\n0,000\n33\n0.\n0.0\n1.0\n0.000\n63\n0.0\n0.\n4.0\n0.000\n93\n0.0\n0.\n.0\n4.0\n0.000\n0.\n0\n1.\n.0\n0.000\n34\n0.\n0.0\n1.0\n0.000\n64\n0.0\n4.0\n0.000\n94\n0.0\n0.\n4.0\n0.000\n1.0\n0.\n000\n35\n1.\n0.000\n65\n4.\n0,000\n95\n0\n0.\n4.0\n0.000\n1.0\n0.000\n36\n2.0\n0.013\n66\n0.000\n96\n0\n0.\n4.0\n0.000\n0.\n.000\n37\n2\n.0\n0.000\n67\n0.000\n97\n0.\n.0\n0.\n4.0\n0.000\n0.\n.000\n38\n0,000\n68\n0.000\n98\n0.\n4.0\n0,000\n.0\n0.\n000\n0.000\n69\n0,000\n99\n.0\n0.\n4.0\n0,000\n1.0\n0.\n000\n40\n0,000\n70\n0,000\n100\n0.0\n0.\n4.0\n0,000\n.0\n0.\n000\n41\n0.013\n0.000\n101\n0.0\n0.\n0\n4.0\n0.000\nO.\n.0\n.0\n0,000\n42\n3.\n0.000\n12\n0\n0\n4.\n0\n0.000\n102\n0.0\n0.\n.0\n4.0\n0,000\n0.\n0\n0\n1.\n.0\n0.000\n43\n3.0\n0.000\n73\n0.0\n4.0\n0,000\n103\n0.0\n0.0\n4.0\n0.000\n0.000\n0.0\n0.0\n3.0\n0.000\n0.0\n0.0\n4.0\n0.000\n104\n0.0\n0.000\n0.\n0.\n0.000\n0.\n0.000\n0.0\n0.\n4.0\n0.000\n105\n0.0\n0.000\n0.\n.0\n0\n0\n0.\n000\n4\n.0\n0.\n0\n.000\n0.\n0.\n.0\n.0\n4.0\n0\n100\n0.\n.0\n0\n0.000\n47\n0.\n.0\n0\n.0\n3\n0\n0.\n.000\n0.\n0.\n4.\n0\n0.\n10\n107\n.0\n0\n0.\n.000\n48\n.0\n0.C\n3\n0\n0.\n,000\n0.\n4.\n000\n10€\n0.\n.0\n1.0\n0.\n000\n49\n0,000\n79\n0\n4\n00\n109\n4\n0.\n0\n0.000\n3\n0.000\n80\n0\n.0\n4.\n0\n00\n0\n0.\n000\n0.0\n0.013\n.0\n4.1\n0\n.00\n0O\n.O\n0.000\n0.0\n0.\n.000\n4.\nDO\n0.0\n0.0\n1.0\n0.000\n4.\n.000\n0.\n4.\n0\n.00\n0\n0.000\n0.0\n1.0\n0.000\n4.\n00o\n0.\n0.\n4.\n.00\n88\n0.\n0.000\n0.0\n0.\n.0\n0.000\n4\n0.\n0.0\n4\n0.00\n115\n0.\n0.000\n0.0\n.0\n0,000\n.0\n0.\n.000\n0.0\n.0\n4.\n0\n0.000\n116\n0.\ncoo\n0.000\n0.0\n0.\n.0\n0.000\n0\n4.\n0.\n.000\n0.\n0\n4.0\n0.000\n117\n888\n0.\n0.000\n0.0\nU\n0.000\n0.\n0.0\n4\n0.\n.000\n4.\n0\n0.000\n118\n0.\n.0\n0.000\n0.0\n0.0\n88\n0.000\n0.\n1.0\n0.0\n4.\n00°\n4.\n0.\n0.000\n0.\n.0\n0.\n.0\n0.\n000\n0.\n.0\n4.\n0.000\n10419\n0.\n. 0\n4.\n0.\n.0\n4.\n• 0\n0.000\n4.0\n0.000\n120\n0.000\n1. All samples 25 gram.\n2.Average rate of gas production in L/Kg/Hr=Avg produced(ml)x40/1000ml/L\nDOTCSF10.XLS\n\n<<<PAGE 25>>>\n\nCRS Project Number: s-6747\nFebruary 5, 1997\nMr. Timothy H. Hall\nSKW Metals and Alloys, Inc.\nP.O. Box 217\nCalvert City, Kentucky 42029\nDangerous When Wet Materials (as set forth in 49 CFR Section 173,\nAppendix E, Division 4, Sections 1, 2, 3 and 4) Evaluation of FeSi Dross, Lab\nID: 2124A, Bin Number: 300.\nDear Mr. Hall:\nWe have completed our gas evolution measurements and the flammability tests,\nper Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample\nmaterial that you submitted in late December 1996 . The material we received from\nSKW was labeled as: FeSi Dross. The results were as follows:\n(1) no gas was evolved and no spontaneous ignition occurred.\n(2) no gas was evolved and no spontaneous ignition occurred.\n(3) no gas was evolved and no spontaneous ignition occurred.\n(4) while some gas did evolve, the average rate never exceeded 1 liter per\nkilogram per hour in the sample tested. The gas was not flammable, but\nwas ignitible (gas ignited but would not sustain a continuous flame).\nIt did not spontaneously ignite in any of the tests.\nOn the basis of these test results, the ferrosilicon material listed above\nwould not fit the definition in 49 CFR Section 173, Appendix E, Division 4,\nSections 1, 2, 3 and 4 as II Dangerous When Wet\" .\nSincerely,\n-1~{ R . ~ / bJ ~W:i \\_ ,'i\n_ vtou,i~ . ,\n. &-~1r,ff- n •'uo\"\\ l\\s..s.oc .a,~\nJames R. Lakin 'j ~\nBusiness Operations Manager\n\n<<<PAGE 26>>>\n\nFebruary 5, 1997\nMr . Timothy H. Hall\nSKW Metals and Alloys, Inc.\nP.O. Box 217\nCalvert City, Kentucky 42029\nRe: Gas Evolution Measurements and Flammability Tests.\nCRS Project Number: S-6747\nDear Mr. Hall:\nWe have completed the gas evolution measurements and the flammability tests,\nper Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample\nmaterial that you submitted in late December 1996. The identification of the\nmaterial submitted and its chemistry specification are listed below.\nFeSi Dross\nSpecification, %:\nLab ID: 2124A\nBin Number: 300\nChemistry:\nSi\n35-45\n40. 6\nSection 1 (Procedure & Results)\nA small piece of the aforementioned material, approximately 2 mm in diameter,\nwas placed in a trough of distilled water at 20°C . No gas evolution was observed,\nnor did the sample spontaneously ignite.\nSection 2 (Procedure & Results )\nA small piece of the material was placed in the center of a filter paper,\nwhich was floating in distilled water at 20°C. No gas evolution was observed, nor\ndid the sample spontaneously ignite.\nSection 3 (Procedure & Results)\nA small pile with an indentation in the center, approximately 2cm high by 3cm\nin diameter, was made of the material. A few drops of water were added to the\nhollow . No gas evolution was observed, nor did any of the sample spontaneously\nignite.\nSection 4 (Procedure & Results)\nRepresentative samples were taken from the lot of material submitted, and\nusing a hammer and chisel the pieces were crushed individually. The larger pieces\nand the fines were","truncated":true,"body_characters":120774}