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

- **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:** Not available
- **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>>>

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

<<<PAGE 2>>>

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

<<<PAGE 3>>>

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

<<<PAGE 4>>>

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

<<<PAGE 5>>>

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

<<<PAGE 6>>>

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

<<<PAGE 7>>>

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

<<<PAGE 8>>>

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

<<<PAGE 9>>>

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

<<<PAGE 10>>>

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

<<<PAGE 11>>>

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

<<<PAGE 12>>>

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

<<<PAGE 13>>>

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

<<<PAGE 14>>>

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

<<<PAGE 15>>>

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

<<<PAGE 16>>>

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

<<<PAGE 17>>>

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

<<<PAGE 18>>>

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

<<<PAGE 19>>>

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

<<<PAGE 20>>>

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

<<<PAGE 21>>>

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

<<<PAGE 22>>>

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

<<<PAGE 23>>>

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

<<<PAGE 24>>>

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

<<<PAGE 25>>>

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

<<<PAGE 26>>>

February 5, 1997
Mr . Timothy H. Hall
SKW Metals and Alloys, Inc.
P.O. Box 217
Calvert City, Kentucky 42029
Re: Gas Evolution Measurements and Flammability Tests.
CRS Project Number: S-6747
Dear Mr. Hall:
We have completed the gas evolution measurements and the flammability tests,
per Code 49 CFR 173, Appendix E division 4, Sections 1, 2, 3 and 4, on the sample
material that you submitted in late December 1996. The identification of the
material submitted and its chemistry specification are listed below.
FeSi Dross
Specification, %:
Lab ID: 2124A
Bin Number: 300
Chemistry:
Si
35-45
40. 6
Section 1 (Procedure & Results)
A small piece of the aforementioned material, approximately 2 mm in diameter,
was placed in a trough of distilled water at 20°C . No gas evolution was observed,
nor did the sample spontaneously ignite.
Section 2 (Procedure & Results )
A small piece of the material was placed in the center of a filter paper,
which was floating in distilled water at 20°C. No gas evolution was observed, nor
did the sample spontaneously ignite.
Section 3 (Procedure & Results)
A small pile with an indentation in the center, approximately 2cm high by 3cm
in diameter, was made of the material. A few drops of water were added to the
hollow . No gas evolution was observed, nor did any of the sample spontaneously
ignite.
Section 4 (Procedure & Results)
Representative samples were taken from the lot of material submitted, and
using a hammer and chisel the pieces were crushed individually. The larger pieces
and the fines were
- **truncated:** true
- **body characters:** 120774