27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN Cost -benel'it anaiysis of repeating the chronic study of the potentiai effects of PFOS on reproduction in quaii. In the previously conducted study. the experimental design and the fact that some equivocal effects were observed at the least dose in the diet (10 mgikg}, precluded accurate assignment of a No Observable Adverse Effects Concentration Results of the previously conducted study will be evaluated in conjunction with known sensitivity ranges, and uncertainty factors to determine the potential bene?ts that could be gained by repeating the study at lesser concentrations to obtain a NOAEC. Work product A short report summarizing the potential benefits, or lack thereof, for repeating the quail chronic PFOS exposure study in addition to a rough estimate of the cost range for the study. The analysis will present the likely effect on the revised risk assessments if a more accurate estimate of the threshold NOAEL were to be made available. The greatest impact would be on obtaining a lower NOAEL that is not driven by the doses in the experimental design. Assumptions information necessary to do this analysis is currently available at the ENTRIX office. Cost Name Rate Hours Subtotal Responsibilities John Giesy 275 3 2,200 Review report John Newsted 175 30 5,250 Assess benefits, estimate cost range, write report Denise Kay 5% 150 - Paul Jones 135 - Shaun Roark 120 - Melissa Shotwell 95 - Karen 75 5 375 Admin support 47'0 Communications of labor) 3,295 Total estimated cost Made Available by am for Inspection and Copying as Confidential Information: Subject to Protective Order In Palmer v. 3M, No. 02-04-6309 3MA02513T52 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN Cost-benefit analysis of frestrel chronic feeding study Based on the information available in the literature, the threshold for effects seems to be similar in a number of species. However, since the quail and mallard are not top carnivores. but eat seeds, vegetation and invertebrates, an among?species uncertainty factor is used in risk assessments. If data were available for an additional species, such as a top predator, an argument could be made to reduce or eliminate the among- species uncertainty factor. will conduct an analysis of the currently known species sensitivity range and applied uncertainty factors to determine the potential bene?ts to be gained from conducting a chronic feeding study with a top predator such as kestrel. Work product A short report summarizing the potential bene?ts, or lack thereof, for conducting a kestrel chronic PFOS exposure study in addition to a rough estimate of the cost range for the study. Assumptions Information necessary to do this analysis is currently available at the ENTRIX office. Cost Home Rate Hours Subtotal Responsibilities John Giesy 275 8 2.200 Review report John Newsted 175 20 3.500 Assess bene?ts. estimate cost range, write report Denise Kay 150 - Paul Jones 135 - Shaun Roark 120 - Melissa Shotweli 95 - Karen 75 5 375 Admin supgort 365 Communications of labor) 6,440 Total estimated cost 3 Made Available by 3M for Inspection and Copying as Confidential Information: 3MA02513T53 Subject to Protective Order In Palmer v. 3M, No. 02-04-6309 Cost -benefit analysis of egg injection study 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN Another possibility in addition to. or separate from, the chronic feeding studies discussed above, is an egg injection study with 5 or bird species. This study would include quail and mallard for comparison to existing data along with additional species such as kestrels or bald eagles: From this data we could derive a species-sensitivity distributiom which could be used to obviate the need for among-species sensitivity factors all together for birds. Work product A short report summarizing the potential benefits, or lack thereof, for conducting a PFOS egg injection study in addition to a rough estimate of the cost range for the study. Assumptions Information necessary to do this analysis is currently available at the ENTRIX of?ce. Cost Name Rate Hours Subtotal Responsibilities John Giesy 275 3 2,200 Review report John Newsted 3 175 20 3,500 Assess benefits. estimate cost range, write report Denise Kay 3 150 - Paul Jones 135 - Shaun Reark 120 Melissa Shotwell 95 - Karen T5 5 375 Admin support 385 Communications of labor) 6,440 Total estimated cost 4 Made Available by 3M for Inspection and Copying as Confidential Information: 3MA02513T54 Subject to Protective Order In Palmer v. 3M, No. 02-04-6309 Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN Chironomus tentans toxicity test The one study that is published in the literature on Chironomus tentans reports a very low threshold value that drives the values calculated for water quality criteria. Because the value is much lower than that observed for other species, it is likely that if the test is repeated under GLP. that the values will be greater. This will have a great benefit in reducing uncertainty in ecological risk assessments for aquatic invertebrates. If such a test is conducted, it must include the same endpoints measured in the previous study and also measure standard ecologically-relevant endpoints. such as survival, growth and reproduction (fertility and fecundity). In addition, it would be useful to measure PFOS concentration in both the overlying water as well as in the sediment. At your reguest. ENTRIX has initiated these toxicity tests in coniunction with ?thdlife lntemational. ENTRIX will design the experiments in coniunction with Wildlife International, arrange to have me_se studies to be conducted. oversee the studies. interpret the results, and prepare a report and manuscript based on the results. Work product Initial interpretation of the results presented verbally. Final written report based on the results and a manuscript to be submitted for publication in the peer-reviewed. open literature that will compare and contrast the results with the previously published work to either con?rm the previous conclusions or ?correct? the literature. Assumptions Wildlife International will conduct the in-life phase of the study and provide all laboratory reports, and documentation to ENTRIX. The Wildlife International portion of the study and any costs associated with chemical analysis will be provided separately as decisions are made regarding the most appropriate approach. 3M may wish to arrange for the analytical support internally or through one of their contract laboratories directly. ENTRIX can also make these arrangements and pay for the analyses with no mark-up. The cost estimate is for ENTRIX tasks only and does not include costs of analytical or for Wildlife International to conduct the test. Cost Name Rate Hours Subtotal Responsibilities John Giesy 2?5 24 5,600 Data analysis, report review John Newsted 175 45 7,875 Design. oversight, data analysis, report writing Denise Kay 11?: 150 5 - Paul Jones 135 5 Shaun Roark 120 - Melissa Shotwell 95 10 950 Table and figure prep Karen 7'5 16 1.200 Admin support 998 Communications of labor) 17,623 Total estimated cost 5 Made Available by 3M for Inspection and Copying as Confidential Information: 3MA02513T55 Subject to Protective Order In Palmer v. Bid, No. 02-04-6309 Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN White paper on ecological risk assessments of PFCs inciuding PFOS and PFOA This white paper will review currently published ecological risk assessments of PFCs. Contrasts and comparisons will be made regarding various conclusions concerning impacts of PFCs, evaluations of uncertainty, and data reporting. Work product Peer-reviewed literature publication based on currently published ecological risk assessments of PFCs including PFOS and PFDA. The document will describe the approaches and conclusions of previously conducted assessments and identify mistakes. uncertainties and data gaps. The document will give a discussion of current status and trends and provide a risk assessment based on the most current information and scienti?cally valid methods. Assumptions Published ecological risk assessments to be reviewed for this white paper have already been acquired by or are otherwise readily available. Cost Name Rate Hours Subtotal Responsibilities John Giesy 275 50 15.500 Oversee data analysis, review and input for ?nal draft John Newsted 175 200 35.000 Write primary draft Denise Kay 5 150 25 3.750 Assist with data analysis. draft review Paul Jones ?43 135 25 3.375 Assist with data analysis. dralt review Shaun Fioark 120 40 4.800 Table and ?gure prep Melissa Shotweil 95 30 2,350 Literature search Karen 75 30 2,250 Admin support 4,112 Communications of labor} Total estimated cost 6 Made Available by 3M for Inspection and Copying as Confidential Information: 3MA02513T56 Subject to Protective Order In Palmer v. 3M, No. 02-04-6309 Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN White paper on the impact of the 2000 phase out of PFOS This white paper will include a meta analysis of the existing publicly available data from peer?reviewed literature on the concentrations of PFOS in the environment to assess the historical trend pre- and post- 2000. It may be possible to include comparisons to other chemicals like DDT that have undergone similar phase-outs. This paper will rely on the PFOS analytical results database that ENTRIX has already generated for 3M. The existing data can be evaluated for use in this review and the white paper can be outlined and established in the first year of this task. ENTRIX would also like to propose that a lower level effort be put forth during the foltowing 3 to 5 years to maintain a database of PFOS analytical results with annual updates to the white paper review of trends. Work product White paper assessing the impact of the 2000 phase-out on the concentrations of PFOS in the environment based on publicly available peer-reviewed literature. Referential database of PFDS analytical results as reported in the reviewed literature. Annual update of trends of environmental concentrations of PFOS. Assumptions The published PFOS literature rarely reports concentrations and specific sampling locations of individual samples. Rather, mean values and general sampling locations are more common reporting methods. The budget presented here assumes that the data will be sufficient as it can been obtained from publicly available literature and it will not be necessary to obtain further speci?c details from investigators. Cost Year 1' budget Name Rate Hours Subtotal Responsibilities John Giesy 275 30 8,250 Oversee data analysis, review and input for ?nal draft John Newsted 175 130 3 22,?50 Identify pertinent literature, write primary draft Denise Kay 15 150 40 5,000 Data base design and maintainence Paul Jones 135 - Shaun Roark 120 40 4,500 Table and ?gure prep Melissa Shotwell 95 40 3,500 Literature search and data entry Karen 75 50 3,?50 Admin support 55 2,961 Communications of labor) 52,311 Total estimated cost illnnuall ongoing budget Name Rate Hours Subtotal . . Responsibilities John Giesy 275 24 6,600 Review annual update John Newsted 175 40 1000 Identify pertinent publications, draft annual update Denise Kay 5 150 30 4,500 Data base design and maintenance Paul Jones 135 - Shaun Roark 120 8 960 Table and figure prep Melissa Shotwell 95 45 4,275 Literature search and data entry Karen 75 15 1,125 Admin support 1,458 Communications of labor] 25,928 Total estimated cost 7, Made Available by 3M for Inspection and Copying as Confidential Information: 3MA02513T57 Subject to Protective Order In Palmer v. 3M, No. 02-04-6309 Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN Monitor and environmentai issues and initiative invoiving PFCs in the Asia- Pacifio region At your request. John Giesy has initiated this effort. Toward this end, we will continue to establish working relationships with the key laboratories and agencies in Asia. In this way, we can assure that the science that is done will be of the highest quality. Work product Oral reports as issues arrive or information becomes available and prepare quarterly written reports upon request as well as making all pertinent documents available to am. Assumptions John Giesy will attend meetings and develop joint projects with Chinese colleagues from whom he can obtain information and over whom he can exert some in?uence to maintain quality of the results. To achieve these goals JPG will need to "buy favors" in the form of supplying standards and reference materials and validation of methods by analyzing split samples at the 3M laboratories or their designated contract lab. Cost John Giesy: time and materials as usuai. Costs for travel to key meetings may be incurred, but cost estimates will be provided and approved before any travel is undertaken. Costs will be tracked quarterly aocountings and rolling estimates of costs in the next quarter provided. Costs will vary from quarter to quarter depending upon activities. Made Available by 3M for Inspection and Copying as Confidential Information: 3MA02513T58 Subject to Protective Order In Palmer v. 3M, No. 02-04-6309 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN Maintain Reference Manager data base of literature on per?uorinated compounds This is an ongoing effort to maintain a referential database of peer-reviewed publicly available literature on perfluorinated coMpounds. database. Work product reports are provided with information on the number of recently published PFC related articles. Electronic updates to the 3M database are provided quarterly. Any article included in the database can be obtained and provided to am upon request. We perform searches of available literature and continuously update this Assumptions The focus of the database continues to be limited to published articles and reports related to PFCs. Cost Name Rate Hours Subtotal Responsibilities John Giesy 275 24 6,600 Identify pertinent literature John Newsted 175 15 2,625 Identify pertinent literature Denise Kay 145 Paul Jones 95 135 Ryan Holem 120 50 6,000 Database maintenance, and quarterly updates Melissa Shotwell 95 1D 1% 950 Literature search Karen 100 1500 Enter articles in database 1.421 Communications of labor} 25,096 Total estimated cost 9 Made Available by 3M for Inspection and Copying as Confidential Information: 3M??25t3?59 Subject to Protective Order In Palmer v. 3M, No. 02-04-6309 Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN Collect and monitor PFCs in mussels from near-shore North American marine environments ENTRIX will provide oversight. and report preparation for a project (subcontract) to the University of Saskatchewan to analyze samples of mussels obtained from the NCAA Mussel Watch Program. ENTRIX has already made arrangements to obtain historical samples from NCAA and then to obtain samples annually in the future {about a two to three year delay) when NOAA has ?nished all of the analyses that they want to conduct on these samples. The results will include up to 60 analytes of various chain and functional moieties. Work product The initial work products will be a Sampling and Analysis Plan (SAP) and a Quality Assurance Project Plan (QAPP) produced by ENTRIX and cost estimate provided separately below. On an ongoing basis. ENTRIX will provide an annual report. including status and trends. When enough data has been accrued. a manuscript will be prepared for publication in the peer?reviewed. open literature. Assumptions 3M will provide technical assistance as needed. This may include purchase of standards and access to instrumentation in the ?rst year until the necessary instruments are purchased by the of S. The of will conduct the instrumental analyses and arrange for inter-laboratory spit sample analyses and other QA as appropriate. It is estimated that approximately 300 to 400 samples will be analyzed per year. depending on availability from NOAA In addition, an additional 20% of samples will be conducted as 0A samples. either as reference materials, duplicates or spike-recovery samples. 3M will provide directly or indirectly. through a designated contract lab analytical services for validation of sample splits. Cost Cost summary for first year of mussel monitoring program including initial QAPP and SAP Description Direct cost Markup Category subtotal of subcontract 142.?50 142.?50 ENTRIX labor 51.400 4% 54.484 ENTRIX expenses 11% 8.300 1.0% 9.545 TOTAL ESTIMATED COST 5 205379 Write GA PP and SAP for biomonitoring program Name Rate Hours Subtotal Responsibilities John Giesy 2T5 10 2.750 Review ?nal document John Newsted 1?5 20 3.500 Statistical sampling design Denise Kay 150 40 6.000 Write draft docUments Paul Jones 33 135 40 5.400 Write draft documents Patrick Bradley 120 10 1.200 design Melissa Shotwell 95 10 950 Table and ?gure prep. document editing 75 20 1.500 Admin support 1.2?3 Communications of labor) 22,5?8 Total estimated cost 10 Made Available by 3M for Inspection and Copying as Confidential Information: 3MA02513T60 Subject to Protective Order In Palmer v. 3M. No. 02-04-6309 27-CV-10-28862 Annual budget for oi portion of mussel monitoring program Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN Description Salary Benefits Total costs on project Subtotal of labor Graduate assistant 2,000 3.104 25,104 100% 25,104 Laboratory manager {bene?ts 34%} $44,000 35 14,960 58,950 25% 14,740 Post doctoral fellow (bene?ts 34%} $32,000 10,880 42,380 25% 10,720 Hourly labor 3.750 of Subtotal Labor 54,314 of Expenses Laboratory supplies 5 10.000 Instrument suppliestitrogen etc, 35 12,000 Instrument maintenance 55 8.000 Travel 5.600 Publication costs 2.500 Of?ce supplies, computer, telephone, copy 13 1.500 of - Subtotal Expenses 39,500 of Subtotal Labor and Expenses 55 93.914 Overhead 40.035 of 8 Total Labor Expenses $142,750 Annual budget for ENTRIX portion of mussel monitoring program Description Unit cost Un'rt Quantity Cost ENTRIX Labor John Giesy 2?5 hour 40 11,000 Paul Jones 135 hour 20 2,?00 Denise Kay 15 145 hour 40 5,300 John Newsted 1?5 hour 40 7,000 Melissa Shotwell 95 hour 20 1,900 Karen T5 hour 20 1,500 ENTRIX - Subtotal Labor 29,900 Communications of Labor) 55 1,196 ENTRIX Labor Total 31,096 ENTRIX Expenses Travel 95 2.150 trips 2 4.300 Sample shipping 4,000 4.000 ENTRIX - Subtotal Expenses 8.300 Expense markup 1,245 ENTRIX Expenses Total 9.545 ENTRIX Total Labor Expenses 41.451 1 1 Made Available by 301 for Inspection and Copying as Confidential Information: 3MA02513T61 Subject to Protective Order In Palmer y. 3M, No. 02-04-6309 Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN Consider methods to assess the nature and characteristics of the totai PFC toad in the environment and deveiop methods to determine sources This task is to look at methods to assess the nature and characteristics of the total PFC load in the environment. This will be a joint project that will involve the University of Saskatchewan but may also provide an opportunity to partner with key laboratories and institutions in Asia to maintain a working relationship that allows access to information and to influence the quality of studies in Asia. The project will investigate possible sources of PFCs in the environment from historical and or on-going sources. The project will include, among other things the development of methods to identify sources. These will include, analyses of samples of different types of samples, including abiotic and biotic samples for individual PFCs, including the isomers of each compound. Then, by use of relative ratios of the various PFC, and their isomers, and pattern recognition techniques, the relative contributions of various sources will be determined. In addition, this project will develop and provide proof of concept on the use of stable isotopes to determine potential sources of various PFCs. but will focus initially on PFOS, PFOA and their primary precursors. It is possible to determine the source of anthropogenic chemicals in the environment using or 0?5 and 016 ratios. in some case ratios of stable nitrogen isotopes may also be possible. Finally, this research project will develop and apply methods for the measurement of total. organically-bound in samples so that a mass balance can be developed for the organically-bound that can be accounted for in the currently identi?ed and quanti?ed organic compounds. Work product The products of this research project will be annual reports, including an oral discussion of the results. The results will be published in the peer-reviewed, open literature and presented at scientific meetings as appropriate. 3M employees will be extended the opportunity to co-author papers at their discretion. Assumptions This is a three year project. am will provide technology, methods, standards, materials and equipment as needed. It is assumed that 3M has the necessary expertise to do the measurements of total organically-bound F. The work will be conducted by a student, postrdoc and technician at the of S, under the direction of JP Giesy. The student and or post doc and technician will go to the 3M laboratories or their designated contractor as necessary to develop the methods and analyze samples. The of will purchase a new in early 200T and use this instrument for subsequent analyses. A more complete proposal from the of will be developed that will outline all of the speci?c experiments to be conducted and the personnel. Cost ENTRIX will manage a sub-contract to the of and provide oversight as well as QNQC and data management and report preparation. There will be no mark-up on the funds passed through to the of S. Cost summary for first year of of 5 research program on PFC load and sources in the environment Description Direct cost Markup Category subtotal of subcontract 209,113 209,113 ENTRIX labor 23,900 8% 25,334 ENTRIX expenses 8, 300 15% 9,545 TOTAL ESTIMATED COST 243,992 1 2 Made Available by 3M for Inspection and Copying as Confidential Information: 3MA02513T62 Subject to Protective Order In Palmer v. 3M, No. 02-04-6309 Filed in Fourth Judicial District Court 11/17/2017 6:53 PM Hennepin County, MN Annual budget for of research program on PFC load and sources in the environment Total on Description Salary Benefits Costs project Subtotal of labor Graduate assistant (benefits 14.11%} $22,000 33 3,104 25,104 100% 25,104 Laboratory manager {bene?ts 34%} $44,000 55 14,960 58,960 25% 14, T40 Post doctoral fellow {benefits 34%} $32,000 10,880 42,880 100% 42,880 Graduate tuition waiver 6,500 6,500 Hourly labor 3,750 of - Subtotal Labor 92,974 of Expenses Laboratory supplies 15,000 Instrument suppliesl'Nitrogen etct 12,000 Instrument maintenance 8,000 Travel 15 5,600 Publication costs 2,500 Office supplies, computer, telephone, copy 5 1,500 of - Subtotal Expenses 44,600 of 8 Subtotal Labor and Expenses $13?,5?4 Overhead 71.539 0 of 3 Total Labor Expenses $209,113 Annual budget for ENTRIX portion of of 8 research program on PFC load and sources in the environment Description Unit cost Unit Quantity Cost ENTRIX Labor Giesy, John 275 hour 30 8,250 Kay, Denise 35 150 hour 40 6,000 Newsled, John at 1'i?5 hour 40 3 1000 Shotwell, Melissa 95 hour 20 1,900 vath, Karen 75 hour 10 7'50 ENTRIX - Subtotal Labor 23,900 Communications of Labor) 5 956 ENTRIX Labor Total 24,856 ENTRIX Expenses Travel 5 2,150 trips 2 4,300 Sample shipping 5 4.000 4,000 ENTRIX - Subtotal Expenses 6,300 Expense markup 1,245 ENTRIX Expenses Total 9,545 Total Labor Expenses 15 34,401 1 3 Made Available by 3M for Inspection and Copying as Confidential Information: Subject to Protective Order In Palmer v. 3M, No. 02-04-6309 3MA02513T63