Document 8VbKMggd4YQN9wgn12q3GZDyK

Electronically Served 9/22/2017 10:26 PM Hennepin County, MN 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN STATE OF MINNESOTA DISTRICT COURT FOR THE COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT CIVIL ACTION NO. 27-CV-10-28862 STATE OF MINNESOTA, et al. v. 3M COMPANY EXPERT REPORT OF KIRK W. BROWN PREPARED ON BEHALF OF PLAINTIFF STATE OF MINNESOTA September 22, 2017 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN TABLE OF CONTENTS 1. Introduction....................................................................................................................... 1 1.1 S cope o f R e p o rt...................................................................................................... 1 1.2 P erso n a l B ackg ro u n d a n d Q ualifications............................................................ 2 1.3 P rior E xpert Testim ony..........................................................................................5 1.4 C om pensation........................................................................................................ 5 1.5 E xh ibits a n d R eservation s o f R ig h ts .................................................................... 5 1.6 D ocu m en ts a n d O ther In form ation C on sidered....................................................5 2. 3M's Fluorochemical Production and Disposal.............................................................. 6 2.1 P roperties o f P F C s.................................................................................................6 2.2 3 M 's P rodu ction o f PF O S, P F O A , PF B A , a n d R e la ted C om pounds................. 9 2.3 C om position o f 3 M 's P F C -C on tain in g W aste S trea m s..................................... 11 2.4 3 M 's D isp o sa l o f P F C -C on tain in g W astes........................................................ 15 2.5 B ioaccum ulation o f P F C s .................................................................................. 1 7 2.6 Toxicity a n d E cotoxicity o f P F C s........................................................................ 19 2 .7 3 M 's U nique A w a ren ess o f th e E n viro n m en ta l a n d H e a lth R isks o f P F C s..................................................................................................................... 23 3. Opinions and Basis for Opinions................................................................................... 26 3.1 3 M 's D isp o sa l o f P F C -C o n ta in in g W aste C on ta m in a ted th e G roundw ater......................................................................................................... 26 3.2 3 M 's F a ilu re to E x ercise R ea so n a b le C are W hen D isp o sin g o f Its P F C - C ontaining W astes............................................................................................... 32 Documents Cited........................................................................................................................ 40 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 1. INTRODUCTION 1.1 Scope of Report I have been asked by counsel to review the site information and associated documents concerning the disposal of liquid and residual solid wastes containing perfluorocarbon compounds ("PFCs") generated by 3M Company at their Cottage Grove facility. These wastes were disposed of at the Cottage Grove facility, the Oakdale disposal site, the Woodbury disposal site, and the Washington County Landfill located in Washington County, Minnesota. Specifically, I was asked to address the following topics: What 3M knew or should have known regarding the contamination of groundwater by 3M's PFC-containing wastes at its four waste disposal sites and when 3M knew or should have known it; and Whether 3M exercised reasonable care when disposing of its PFC-containing wastes at its four disposal sites and allowing releases from those disposal sites to continue. I have reviewed the reports, documents, deposition transcripts, and various other materials provided by counsel and gathered independently and offer my professional opinions in this report. A list of the materials I have reviewed is contained in Attachment 1 to this report. The types of documents that I have reviewed, including patents, scientific publications, 3M's reports and internal communications, 3M's communications with regulatory agencies and the public, are those that would reasonably be relied upon in the preparation of an expert report. As more fully detailed in the body of this report, I offer the following professional opinions to a reasonable degree of scientific certainty: 1. By the early 1950s, 3M knew or should have known that pollutants from landfilled industrial wastes would reach the groundwater beneath its disposal sites and would pose a potential threat of harm to human health and the environment and harm the State's natural resources. By the early 1960s, 3M knew that groundwater beneath at least two of its disposal sites was contaminated with industrial organic chemicals, which were components of its waste. 2. 3M failed to exercise reasonable care in connection with its disposal of PFCs and PFC-containing wastes because it disposed of them without regard for harm to human health and the environment. Further, 3M failed to exercise reasonable care by failing to prevent the continued release of PFCs into the groundwater and the Mississippi River after they were disposed of at 3M's Minnesota sites. -1 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 1.2 Personal Background and Qualifications From 1970 through 2001, I was employed as a Professor of Soil and Crop Sciences in the Soil and Crop Sciences Department, Texas A&M University, College Station, Texas. I currently serve as Professor Emeritus in the Soil and Crop Sciences Department, Texas A&M University, College Station, Texas. In 1990, I received a joint appointment to the faculty in Toxicology at Texas A&M University, where I supervised the research of masters degree and doctoral candidates in the field of toxicology. My educational background includes a Bachelor of Science degree in Agronomy from Delaware Valley College (1962), Masters of Science degree in Agronomy/Plant Physiology from Cornell University (1964), and Doctor of Philosophy degree from University of Nebraska (1969). My resume is presented as Attachment 2, and includes a complete list of my publications. While a member of the faculty at Texas A&M University, I conducted extensive research including numerous research projects for the U.S. Environmental Protection Agency ("USEPA") and the National Institute of Health ("NIH") on the fate and transport of contaminants, including pathways of exposure and toxicity of hazardous substances to receptors in the environment. As a result of these research efforts, I have authored or co-authored over 190 peer-reviewed, scientific publications, including numerous articles dealing with the disposal and treatment of waste materials, including Resource Conservation and Recovery Act ("RCRA") hazardous wastes and Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA") hazardous substances contained therein and the problems arising therefrom. Additionally, I have authored or co-authored over 35 publications which deal with risk assessment or toxicity of hazardous substances in the environment. I have conducted research in a national center funded by the USEPA to study the fate of hazardous substances in the environment. The research I conducted on the mobility of organic liquids through clay landfill liners was instrumental in the incorporation of the prohibition of land disposal of liquid wastes in the Hazardous and Solid Waste Amendments in 1984 (P.L. 98-616, 1984). Extensive research that I conducted on landfill liners was instrumental in the development and implementation of regulations which now require that both hazardous and municipal landfills must be lined and all leachate must be collected and removed for treatment. I authored the USEPA guidance document on the land treatment of hazardous wastes, and portions of the USEPA guidance document on the design of landfill liners. I authored a publication for USEPA where I surveyed the characteristics of the hazardous wastes generated by industry based on the SIC code of the industry. During my tenure at Texas A&M University, I taught courses in Soil Physics which included topics on the movement of air, water, and other fluids in the soil, and a graduate course on the land disposal of wastes, which included consideration of the principles and practices applicable to the fate, mobility, and clean-up of contaminated sites. Students in these classes included engineers, soil scientists, chemists, and geologists. I have served on hundreds of advanced degree committees in these and related disciplines. I have served on technical advisory panels to the USEPA, committees of the Office of Technical Assessment, and the National Academy of Science. Significant reports resulting from these committee assignments include, Groundwater and Soil Cleanup, Improving Management of Persistent Contaminants (1999); Ranking Hazardous Waste Sites (1994); Coming Clean, -2 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Superfund Problems Can be Solved (1989); and Superfund Strategy (1985). I was the primary author of a 1983 publication for the USEPA entitled Hazardous Waste Land Treatment. This publication specifically addressed the treatment of hazardous wastes from industrial waste streams to mitigate risk during treatment and eliminate risk to potential receptors. In 1981, I was appointed to the USEPA Land Treatment Task Force where I served from 1981 through 1985. As part of my assignment with the Task Force, I evaluated the alternatives for land disposal of wastes and the risk associated with the disposal alternatives. While a member of this Task Force, I testified before the U.S. House of Representatives - Science and Technology Committee in November 1982 on the adequacy of USEPA's liquid management system to protect groundwater at hazardous waste landfills, which lead to the passage of the Hazardous and Solid Wastes Amendments of 1984 under the Resource Conservation and Recovery Act. In 1983 and 1984, I was a member of the Advisory Panel to U.S. Congressional Office of Technology Assessment. This panel was tasked with determining the effectiveness of current USEPA programs to clean up uncontrolled hazardous waste sites. As part of my assignment with this committee, I reviewed and evaluated the toxicity and imposed risk to receptors due to hazardous substances and provided recommendations for improving the efficiency of USEPA programs to mitigate risk at uncontrolled hazardous waste sites. In 1984, I was a member of the Office of Water Regulations and Standards Committee on Municipal Sludge Landfilling, which was formed to advise USEPA on the pollutants which should be regulated for disposal and the methods or procedures to be used for regulating such pollutants. As part of my work for this committee, I assessed the hazards and risk associated with the hazardous substances contained in municipal sewage sludge and provided recommendations for regulation of metals in sewage sludge based on the degree of risk presented by exposure to these metals. From 1987 through 1995, I was a member of the Advisory Panel to U.S. Congressional Office of Technology Assessment, which was tasked with assessing the effectiveness of the USEPA in identifying, prioritizing and cleaning up hazardous waste sites. As part of my work for this committee, I evaluated the impacts of exposure from different media and the effectiveness of available technologies to mitigate exposure and risk from hazardous waste sites. From 1991 through 1994, I served on the National Academy of Sciences Committee on Remedial Action Priorities for Hazardous Waste Sites, where I evaluated the role of risk assessment and mitigation of risk in the decision process for remedial action. From 1995 through 1998, I served on the National Academy of Sciences, National Research Council Committee on Environmental Technologies Subcommittee on Landfills. As part of my assignment to this committee, I evaluated the risk due to contaminants in soil and groundwater and recommended strategies for the management and control of recalcitrant wastes for the reduction of risk due to these persistent contaminants. In addition, I have served on numerous USEPA review panels addressing toxicity and risk including the following, among others: -3 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN USEPA Panel to Review the Acceptability of Landfill Disposal of Sewage Sludge (1984); USEPA Panel to Write a Protocol for Mutagenicity Sample Preparation (1984); USEPA Hazardous Waste Center Review Panel (1988); and USEPA Review for Risk Assessment for Petroleum Industry Hazardous Waste Listing Determination (1995). I am personally familiar with the definition of "hazardous substance" as defined in 101(14) of the Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA") and under the statutes and regulations incorporated by reference into that section. A hazardous substance under CERCLA is defined in 42 U.S.C. 9601 (14), invoking the EPA designations under 42 U.S.C. 3001 and 9602, among other statutes. Included in the definition of a CERCLA hazardous substance are certain hazardous wastes which are either listed in 40 C.F.R 261, Subpart D or have certain identified characteristics as described in 40 C.F.R. 261, Subpart C. Further, I have studied and am familiar with industrial, commercial, and residential wastes, and the landfills that eventually contain such waste. I have researched the risks associated with leachate from landfills containing these wastes. I have also investigated the partitioning, biodegradation, mobility, volatilization, solubility and reactivity of organic compounds found in leachate from landfills and the resulting fate and transport in both surface water and groundwater. I have reviewed numerous remedial plans and proposed remedies pertaining to landfills containing industrial, commercial, and residential wastes. I have also served as a reviewer of toxicological profiles of hazardous substances for the Agency for Toxic Substances and Disease Registry ("ATSDR"). I have been a consultant in the field of environmental science and engineering for the past 37 years. I founded K. W. Brown and Associates, Inc., and served as President from 1980 until 1991. I was employed as a Principal Consultant with K. W. Brown Environmental Services from 1991 until 1999 and with SI Group, LP from 2000 to 2008. From January 2009 through March 2011, I was employed as a Principal Consultant with TTI Environmental Consultants. I have been employed as an independent consultant since April 2011. Through these years of consulting, numerous private and public clients have employed me. My expertise has been utilized for site assessments, data review and interpretation, waste management activities, the study of fate and transport of contaminants in the environment, the movement of contaminants in groundwater, the design and implementation of remedial actions for recalcitrant organic compounds, and other related environmental matters. I have also reviewed and interpreted a large quantity of analytical data for soils and groundwater, as well as borings logs, field logs, technical reports, and other information related to the environmental conditions of a site. As a consultant, I have evaluated or analyzed numerous waste disposal and landfill sites including the following: Laurel Park Landfill, Beacon Heights Landfill, Lone Pine Landfill, Ft. -4 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Bend County Landfill, Oak Grove Landfill, East Bethel Landfill, Dickson County Landfill, and Sinton Landfill, among others. In addition, I have also worked on the following Superfund sites: Hardage Criner, Love Canal Landfill, Lowrey Landfill, Montana Pole, National Gypsum, Riley Tar, Sharon Steel, Helen Kramer Landfill, Sikes' Pits, Metal Bank of America, Tar Creek, Babylon Landfill, and the West Dallas Lead Site. 1.3 Prior Expert Testimony I have qualified and given testimony as an expert witness in civil cases in federal and state courts, regulatory hearings, and enforcement actions pertaining to hazardous wastes, organic chemical contamination, and the fate and transport of organic chemicals and other contaminants in environmental media, as well as exposure and risk, among other issues. I have offered opinions related to these topics at several Superfund sites. A list of cases in which I have testified as an expert at trial or by deposition since January 1, 2013 is presented in Attachment 3. 1.4 Compensation I am being compensated at customary rates for work on this case. My hourly rate of compensation is $300 per hour for non-testimony time and $350 per hour for testimony time. My compensation in no way depends on the outcome of this litigation or the substance of my opinions. 1.5 Exhibits and Reservations of Rights I may use as exhibits any document contained or referred to in this report, or supplements to this report, including but not limited to the appendices; any document needed as foundation for or illustration of my testimony; any document listed as an exhibit or provided in discovery by the Defendant or any other party; any document considered by any the Defendant's or any other party's experts; or any document needed to respond to or to rebut testimony on behalf of the Defendants or any other party. I reserve the right to provide lists of exhibits as permitted by the Minnesota Rules of Civil Procedure and the Scheduling Orders in this case. I further reserve the right to supplement or modify opinions expressed herein upon which I expect to testify, to add to or modify the bases and reasons for my opinions and supplement the exhibits that I may use at trial for any of the following reasons: (1) to respond to expert reports, including but not limited to rebuttal reports, submitted by the Defendant or any other party; (2) to respond to new information; (3) to respond to information obtained in discovery, including but not limited to depositions and interviews; and (4) as permitted by Minnesota Rules of Civil Procedure. 1.6 Documents and Other Information Considered This report was developed as a result of discovery of information to which I have been provided access or which I have discovered independently. The opinions I have formed in this case are based on my education and experience described in Section 1.2, as well as documents and other materials listed in Attachment 1. -5- CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 2. 3M'S FLUOROCHEMICAL PRODUCTION AND DISPOSAL 2.1 Properties of PFCs Perfluorocarbon compounds, or PFCs, are any chemical in a family of synthetic chemicals that contains a perfluorinated (fully fluorinated) carbon chain consisting of 1 to 16 carbon atoms with a functional end group consisting of at least one double bond. PFCs do not occur in nature and were developed as a part of the research associated with the Manhattan Project during World War II. PFCs have similar molecular structure as their corresponding hydrocarbon compounds, except with complete replacement of all hydrogen atoms in the hydrocarbon molecule with fluorine. The principal compounds at issue in this suit, perfluorooctane sulfonate (PFOS), perfluorooctanoic acid (PFOA), and perfluorobutanoic acid (PFBA), are PFCs. From my review of the scientific literature, it is my understanding that many important properties of PFCs were known as a result of the early work by Dr. Joseph Simons, a research fellow at Pennsylvania State University, and numerous 3M researchers. Shortly after the public disclosure of the electrochemical fluorination process during the 114th annual meeting of the American Chemical Society on September 15, 1948, 3M purchased patents from Dr. Simons related to the manufacture of perfluorochemicals (Simons, 1950a). 3M also employed several former graduate students of Dr. Simons to prepare new compounds and develop new markets for these perfluorochemicals (Simons, 1948; Simons, 1949; Brice, 1950; Guenthner and Vietor, 1962; Bryce, 1964; Pearlson, 1968).1 R eactivity. Early patent applications and the scientific literature document that the chemical stability of PFCs was well understood before commercial production of PFCs began at the 3M Cottage Grove facility. Dr. Simons' 1948 patent application, for example, noted that PFCs were "non-corrosive, and of little chemical reactivity." PFCs "do not react with any of the metals at ordinary temperatures and react only with the more chemically reactive metals such as sodium, at elevated temperatures" (Simons, 1948). Another patent application filed the following year explained that PFCs do not react with other compounds or reagents due to the sheath of fluorine atoms surrounding the carbon skeleton of the molecule (Simons, 1949). These highly stable PFCs were developed to provide non-reactive solid and liquid chemicals with low surface tensions that could withstand high temperatures and would not react with highly reactive materials such as oxygen (Simons, 1949; Bryce, 1964). It is the stability of the carbon-tofluorine bonds in the PFCs and the lack of attraction for other chemical species that prevent the PFCs from undergoing further chemical reactions or degrading under natural processes in the environment (Simons, 1950b). As Bryce recognized, "[t]his chemical stability also extends itself to all types of biological processes; there are no known biological organisms that are able to attack the carbon-fluorine bond in a fluorocarbon" (Bryce, 1964). 3M was well aware of these chemical properties of PFCs because T.J. B rice and H.G. B ryce were 3M employees as well as former graduate students under Joseph Simons, and 3M 1 All names given in italics are either current or former 3M employees. The discoveries and information developed by these individuals was thus known to 3M. -6- CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN acquired many of Simons' patents related to fluorochemicals (3M, 2007 [3MA02527087]). 3M's knowledge of this and other basic properties was demonstrated by, among many other things, a 1949 3M sales brochure, which described the chemical and physical properties of PFBA, and a 1963 3M sales brochure on its fluorochemical surfactants, which touted their chemical and thermal stability (3M, 1949 [3M_MN03109500]; 3M, 1963 [3MA01201629]). T herm al Stability. The thermal stability of PFCs was understood prior to the start of commercial production of PFCs by 3M. In 1947, two researchers from Columbia reported that fluorocarbon compounds did not degrade at temperatures as high as 500 C (932F), even in the presence of catalytic materials (Grosse and Cady, 1947). Simons' patent application posited that PFCs were thermally stable at temperatures up to 750 C (1382 F) (Simons, 1948; Simons et al., 1949) . These PFCs were non-reactive and thermally stable due to the strength and stability of the carbon-to-fluorine bonds (Simons, 1949; Brice, 1950). Additional research by 3M expanded the understanding of the thermal stability of these perfluorocarbon compounds. As Bryce explained in his 1964 work, fracture of the carbon-to-carbon bonds in the PFCs may take place at temperatures from 600 to 1000 C (1112 to 1832 F) depending on the carbon chain length; the carbon-to-fluorine bond is much stronger and can require temperatures of 1200 C (2192 F) to break (Bryce, 1964). Solubility. As discussed further below, 3M was capable of producing a variety of PFCs at its Cottage Grove facility. From my review of 3M documents, it is my understanding that many of the PFCs produced by 3M, including PFOS, PFOA, and PFBA, in addition to the salts of PFOS, PFOA, and PFBA, would readily dissolve in water. In 3M's 1949 sales brochure, they advertised that PFBA was miscible in water at 20 C. The same brochure indicated that the salts of PFBA are highly soluble, ranging from 42.2 grams to 493 grams per 100 grams of water (3M, 1949 [3M_MN03109500]). In 1962, testing of PFOS-based surfactants indicated that these compounds were very soluble (Guenthner and Vietor, 1962). A 1963 brochure on 3M's fluorochemical surfactants confirmed that 3M was aware that many of its fluorochemical surfactants, including PFOS, were soluble in water. That brochure, for example, indicated that the solubility of FC-95 (the potassium salt of PFOS) in water was 2 grams of FC-95 per liter of water (3M, 1963 [3MA01201629]). More broadly, numerous PFCs manufactured by 3M, including fluorocarbon carboxylic acids and fluorocarbon sulfonic acids such as PFOA and PFOS, dissolved when mixed with water (Bryce, 1964). 3M knew by 1964 that when dissolved, fluorocarbon carboxylic acids and fluorocarbon sulfonic acids dissociated2 to form highly stable perfluorocarboxylate and perfluorosulfonate ions (Bryce, 1964). Later studies by 3M on the adsorption and mobility of FC-95 and FC-143 (the ammonium salt of PFOA) in soils indicated very high solubilities and very high mobilities in soils for both compounds (3M, 1978 [3MA10036129]). R esistan ce to D egradation. Because of their very limited reactivity and the high thermal stability of the perfluorinated carbon chain, PFCs do not degrade in the environment (Brice, 1950) . The breaking of a carbon-to-fluorine bond required the input of large amounts of energy 2 By dissolving in water, the chemical compounds will dissociate by separating into their component ions (charged particles) in the solution. For acids like PFOA, the ions will include perfluorooctanoate and the hydrogen ion. The released hydrogen ion will increase the acidity and decrease the pH of the solution. -7- CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN to overcome the attraction of carbon for fluorine. Chemical and physical processes occurring in nature lack sufficient energy to break carbon-to-fluorine bonds and without this input of energy, the carbon-to-fluorine bonds remain intact. "This chemical stability also extends itself to all types of biological processes; there are no known biological organisms that are able to attack the carbon-fluorine bond in a fluorocarbon" (Bryce, 1964). From the chemical stability of the carbon-to-fluorine bond, 3M knew that the PFCs were immune to chemical and biological degradation in soils and groundwater. A 1971 internal memo by H.G. B ryce stated that "the thesis that there is `no natural sink' for fluorocarbons obviously demands some attention," meaning that PFCs released to the environment will never degrade (3M, 1971 [3MA02496587]). In natural environments, PFCs do not undergo degradation of the carbon-to-fluorine bonds of the perfluorinated carbon chain. However, the non-fluorinated, functional group of the PFCs will partially degrade, yielding recalcitrant PFCs such as PFOS, PFOA, and PFBA, which resist further degradation. Basic weathering and degradation reactions, such as hydrolysis,3 occur at the non-fluorinated, functional group end of the molecule, producing the original fluorocarbon compound (Pearlson, 1950)--such as PFOS, PFOA, or PFBA--from which other PFCs were made (3M, 1979 [3M_MN00000151]). In this manner, derivative compounds containing the C7F15- group were converted to PFOA and derivative compounds containing the C8F17SO2- group reverted to PFOS (Bryce, 1964). In sum, 3M knew that the perfluorinated components of PFCs released to the environment would not degrade the perfluorinated carbon structure, but would remain intact (Brice, 1950). Later 3M research on the biodegradation of its fluorochemical compounds confirmed these results (Bacon, 2017 (pp. 40-48)). A 1976 study, for example, observed no biodegradation of FC-95, the potassium salt of PFOS. 3M judged the result of the study "unsurprising" in light of the fact that "[b]iodegradation of FC 95 is improbable because it is completely fluorinated" (3M, 1976 [3MA01252037]). A 3M report from 1978 likewise summarized a "quite extensive" set of studies of the biodegradability of FM-3422, a compound manufactured from PFOS, and concluded that "FM 3422 is likely to persist in the environment for extended periods unaltered by metabolic attack" (3M, 1978 3MA00717615]). Studies of FC-95 and FC-143 (the ammonium salt of PFOA) conducted in 1978 likewise concluded that those compounds were "likely to persist in the environment for extended periods unaltered by microbial catabolism" (3M, 1978 [3MA10054929]). 3 Typically, hydrolysis is a chemical process where a molecule of water is substituted or added at the functional group of the PFC derivative. The addition of water cleaves the nonfluorinated portion of the molecule from the fluorinated carbon tail. -8- CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 2.2 3M's Production of PFOS, PFOA, PFBA, and Related Compounds The E lectro ch em ica l F lu orin ation Process. 3M used the Simons electrochemical fluorination (ECF) process to produce PFCs (Simons, 1950a; 3M, 2007 [3MA02527087]). It is my understanding based on my independent review of the available documents that the ECF process consisted of a combination of an electrochemical cell with condensers, a sodium hydroxide reactor and driers for the removal of excess hydrogen fluoride and outlets from the cell for the collection of the liquid, fluorinated carbon-containing product mixtures (Simons, 1950a; Simons, 1950b). The ECF process created mixtures of a number of fluorinated carbon compounds. This mixture of product compounds required further separation by a process called fractional distillation,4which separated the mixture into distinct "fractions," each with a distinct boiling point range (Simons et al., 1949). The segregated fractions of fluorochemical products were collected for direct use in 3M product mixtures, used as building blocks for the production of other fluorinated compounds, or discarded as waste (Dworak, 2012 (p. 190); 3M, 2000 [3MA00001260]). P rodu ction o f Various PFCs. By upscaling the electrochemical fluorination process developed by Dr. Simons, the production of fluorocarbon compounds became commercially feasible. Simons and Brice wrote that "[t]he first commercial plant for the production of fluorocarbons and their derivatives by the electrochemical process was put into operation near Hastings, Minnesota, in October 1951" (Simons and Brice, 1954). From this point, 3M began its commercial production of fluorocarbons at its Cottage Grove facility near Hastings, Minnesota. In its early years, it operated on a relatively modest scale, producing some 250 pounds of fluorocarbon product per day in 1954 (Simons and Brice, 1954). 3M quickly expanded its production to include an entire facility devoted to the production of PFCs within its Chemolite plant. The electrochemical fluorination process for the manufacture of PFOA remained essentially the same at 3M's Cottage Grove plant from the first initial batch produced in the early 1950s through the phase out of production in 2002 (Dworak, 2012 (p. 35)). 3M used the ECF process to develop a wide variety of PFCs. Different hydrocarbon compounds containing elements other than carbon or hydrogen were sometimes used as the "feed stock," or starting materials, to develop PFCs (3M, 2000 [3MA00001260]). Some of these additional hydrocarbon starting materials retained the reactive properties of the original hydrocarbon feed stock after fluorination (Simons, 1949; Simons et al., 1949).5 This work was 4 Fractional distillation is a chemical separation process where a mixture of different compounds are separated based on the boiling points of the individual compounds in the mixture. This is achieved by repeatedly heating and boiling the mixture of compounds; because the various compounds in the mixture have different boiling points, they physically separate during this heating process. 5 In hydrocarbon compounds, an atom other than carbon attached in the skeletal structure is called a heteroatom. Functional groups are groups of two or more, non-carbon containing atoms. -9- CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN based in part on the research of Dr. Simons at Penn State, demonstrating that organic acids and sulfonyl halides, when used as the starting materials for the fluorination process, produced perfluorinated compounds while retaining their organic functional groups (Simons et al., 1949; Pearlson, 1950; Simons and Brice, 1954).6 This technique was used by 3M to manufacture PFOS, PFOA, PFBA, and related compounds (Simons, 1949; Simons, 1950a; Scholberg and B ryce, 1955; B rice and Trott, 1956). The presence of a heteroatom or a functional group within the hydrocarbon molecule imparts different properties to the substance. 6 Organic acids and sulfonyl halides are examples of functional groups that remain unchanged in the chemical structure upon fluorination of the starting materials. - 10 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 2.3 Composition of 3M's PFC-Containing Waste Streams From the beginning of the manufacture of PFCs, anyone with a knowledge of the chemistry and the manufacturing processes would have known that the wastes produced from the production of PFCs contained residual perfluorochemicals (3M, 1983 [3M_MN02571703]). 3M employed chemists and engineers who specialized in the production and product development of PFCs including T.J. Brice, H.G. Bryce, P. W. Trott, R.A. Guenthner, M.L. Vietor, H.M. Scholberg, R.I. Coon, D.G. Weiblen and W.H. Pearlson, among others. These chemists and engineers were highly trained, specializing in the manufacturing and production steps needed to separate and isolate the individual products. Therefore, 3M knew that the production wastes contained PFCs. These wastes included processing wastes, such as acid tars and resinous materials, fractionation wastes, waste solvents, solid materials, and off-specification products containing PFCs (3M, 1983 [3M_MN02571703]; 3M, 2000 [3MA00001260]; 3M, 1993 [3MA00206150]). Varieties of PFC-Containing Wastes During most of the period considered by this report, 3M did not classify its wastes in terms of their perfluorochemical content. In the 1950s and 1960s, 3M classified its wastes using rudimentary categories such as acid tars; dry scrap, such as paper, pallets, production scrap, and cardboard; wet scrap, such as liquid and semi-solid mixtures and materials contaminated with solvents, resins, waste solvents, and nonpumpable residue (3M, 1963 [3MA00456368]; 3M, 1980 [3MA01248573]). As 3M itself has explained: "The manufacturing process for sulfonated perfluorochemicals is complicated. There are more than 600 intermediate manufacturing steps associated with the production of POSF and POSF-based products. This translates into hundreds of process steps that require venting or that generate wastewater or solid waste" (3M, 2000 [3MA00045043]). POSF is the raw intermediate used to make PFOS (3M, 2000 [3MA00001260]). By the late 1960's, 3M wastes were separated into three broad categories, namely dry scrap wastes, wet scrap wastes, and extra hazardous wastes (Lewis et al., 1976). Hazardous wastes originating from 3M operations would have included dirty solvents from coating operations, mother liquors from chemical reactions, spent cleaning solutions, reject products, and nonmarketable items, as well as other wastes ( Van Noordwyk and Santoro, 1978). It is my understanding from my review of 3M documents that wastes containing PFCs from the perfluorochemical manufacturing processes included the following, among others. Furthermore, I concur with the waste streams identified in Dr. Andrews report. hydrofluoric acid tars, sometimes known as HF tars or acid tars, that resulted from the operation of the electrochemical cell; fractionation bottoms, or unwanted perfluorochemical by-products or residuals separated from the desired product during the fractionation step of the manufacturing process; - 11 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN cleaning and process wastes resulting from the cleaning of equipment used in the manufacturing process and from numerous other steps of the manufacturing process; laboratory and pilot-scale testing wastes including waste chemicals, spent solvents and other solid wastes contaminated with fluorocarbons; fluorochemical inerts, low boiling point by-products that were removed during the fluorination and distillation processes. Fluorochemical inerts are composed of short perfluorinated or partially-fluorinated carbons chains, either with or without a functional group, and other related by-products; wastewater treatment plant sludge, including solid waste materials, which settled to the bottom of the wastewater treatment pond (until 1962) or wastewater treatment plant settlement ponds (after 1962); and incinerator ash and incinerator wastewater sludge produced once the incinerator built at the Cottage Grove facility began operation in 1971. 3M's Knowledge When assembling its research and production team, 3M hired Ph.D.-level scientists and engineers with hands-on knowledge in the manufacture of fluorochemical compounds. This team worked regularly to optimize the ECF process and improve the efficiency of the stabilization and/or separation of the finished products, as well as designing and synthesizing new materials for additional markets. Because 3M understood the chemistry and engineering underlying electrochemical fluorination and other elements of its manufacturing processes, 3M knew or should have known that the wastes described in this section contained PFCs. A c id tars. The early patent documents, prepared by Dr. Joseph Simons, disclosed that the formation of acidic tars, resinous residuals containing fluorochemicals, were produced by the ECF process (Simons, 1948; Simons, 1950b). 3M was aware that these tars--often called "acid tars" or "HF tars"--contained PFCs even before it began producing PFCs on a commercial scale (3M, 1983 [3M_MN02571703]; 3M, 2000 [3MA00001260]). Testing conducted in 1963 attempted to increase the recovery of hydrofluoric acid and the recovery of PFC product intermediates by dissolving the residual tars in fuming sulfuric acid, but proved unsuccessful (3M, 1974 [3MA01201775]). The very fact that 3M was trying to recover PFCs from the acid tars clearly demonstrated that they knew that the tars contained PFCs. F ractionation bottom s. Research results by Dr. Joseph Simons on the ECF process also disclosed that the fluorination process produced a mixture of fluorinated products, which must be separated rather than one specific product (Simons, 1949b; Simons, 1950b). The mixture of products from the electrochemical fluorination process occurred as fluorocarbon compounds of differing carbon chain lengths including fully saturated fluorocarbons and other compounds with incomplete replacement of hydrogen by fluorine (Simons and Brice, 1954). Wastes from these processing steps contained residual PFCs. (3M, 1983 [3M_MN 02571703]; 3M, 2000 [3MA00001260]). A 1981 3M memo indicates that 3M sought to recover additional - 12 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN fluorocarbons from these wastes, confirming that 3M knew that they contained PFCs (3M, 1981 [3MA00082742]; Dworak, 2012 (p. 172)). C leanin g w astes a n d p ro cess w astew aters. 3M knew or should have known that cleaning wastes and process wastewaters contained PFCs. Due to the need to fractionate the raw products from the electrochemical fluorination steps and the stabilization/workup needed for the production of specialized perfluorochemicals, water and organic solvents were often used to clean vessels used in the production steps. In his deposition, Mr. Dworak stated, "any solution used to boil out the cell bodies went down the sewer to wastewater treatment and the water used from the pressure blasting went down the sewer to wastewater treatment" as well (Dworak, 2012 (p. 104)). The washwater and these solvents, containing PFCs, were typically drained to the chemical sewer. Likewise, laboratory and pilot-scale testing wastes would have included PFCs as components of their waste streams. These cleaning and processing wastes also contained PFCs (3M, 1983 [3M_MN02571703]; Dworak, 2012 (pp. 104-07, 123-24, 167, 184-85). Given 3M's knowledge of the production processes used to manufacture PFCs, 3M knew or should have known that the cleaning wastes and process wastewaters resulting from the PFC manufacturing process would contain PFCs. F lu oroch em ical inerts. 3M knew or should have known that fluorochemical inerts contained PFCs. Incompletely fluorinated byproducts were typically collected by 3M from the ECF process for further use as solvents and carriers in subsequent batch processes or as starting materials in the ECF process (3M, 2000 [3MA00001260]). 3M knew or should have known that small amounts of fluorochemical inerts would have been present in the acid tars and distillation bottoms as wastes or would have been partially degraded in the stabilization processes and discharged to the chemical sewer (3M, 2000 [3MA00001260]). W astew ater treatm en t p la n t sludge. PFC-containing wastes were discharged into the chemical sewer from Building 15 at Cottage Grove, where most of the PFCs were manufactured. (Dworak, 2012 (pp. 104-107, 123-124)). From 1971 to 1979, the wastewater treatment plant sludge included solids settled from the incinerator wastewater as well (3M, 1979 [3MA00722981]). Certain PFCs, such as FM-3422 (a PFC made from PFOS) were determined to have relatively large octanol/water partition coefficients and would have preferentially absorbed to the organic solids (3M, 1979 [3M_MN00000151]). Perfluorooctane sulfonyl fluoride (POSF), the precursor to PFOS and its salts, would be "adsorbed by waste treatment sludge and eventually land applied with this sludge" (3M, 1983 [3M_MN02571703, -706]). PFCs with strong affinity for the solid materials would have collected in the sludge of the wastewater pond prior to 1962. Even PFCs with relatively low octanol/water partition coefficients would adsorb to the solids in the wastewater treatment plant system to some degree. After completion of the wastewater treatment system, these partitioning PFCs would have collected in the aeration basins of the wastewater treatment system as wastewater treatment plant sludge (3M, 1966 [3MA00456431]; 3M, 1979 [3M_MN00000151, -160]). In the cases of FC-95 and FC-143, 3M had sufficient information regarding the fate and mobility for each PFC to prepare a schematic diagram showing the partitioning of the compound into the different segments of the environment, namely air, water, and the soil, including partitioning into the solid phase as sludge (3M, 1979 [3M_MN00000745, -748-749]; 3M, 1979 [3MA01410327, -331 334]). - 13 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN In cin erator ash a n d sludge. 3M knew from the early work of Dr. Joseph Simons that PFCs were thermally stable and resistant to degradation at high temperatures. Simons, 1950a. In his review of perfluorinated compounds, H.G. B ryce presented that the fluorine-to-carbon bond is very stable and can only be broken by heating the PFCs to very high temperatures (Bryce, 1964). For example, the compound CF4 was found to be completely stable at temperatures in excess of 1200 C (2192 F) (Bryce, 1964). Dr. B ryce was a former graduate student of Joseph Simons and a 3M employee, therefore 3M knew that PFCs would not be completely decomposed at temperatures below that level. With these benchmarks in mind, 3M incinerated PFC-containing wastes at kiln temperatures as low as 649 C (1100 F) (Van N oordw yk and Santoro, 1978; Santoro, 2017 (pp. 36-37); Weum, 2017 (p. 111)). 3M thus knew or should have known that PFCs would not have been completely decomposed in the incinerator and products of incomplete combustion would have remained in the incinerator ash and the incinerator wastewater sludge (3M, 1999 [3MA01412204]). Indeed, analysis from E ric Reiner in 2000 indicated that fluorochemicals "are more likely to be incompletely burned than most other organic compounds," and "[degradation of the organofluorine compound could be incomplete if the incinerator doesn't have a high enough temperature (e.g. perhaps > 1700 F [925 C]" (3M, 1996 [3M_MN04747296, -297]). A 1999 3M white paper on the same subject concluded that "[i]n order to ensure complete destruction, incineration experts at 3M suggest residence times in the combustion chamber greater than 1 second and at a temperature 1700 F (926 C) or greater. If combustion chamber temperatures and retention times drop below certain levels, destruction efficiency can drop off rapidly." 3M's own experience with incineration confirmed these conclusions. In March 1984, 3M conducted a trial test burn of the contaminated materials from the Oakdale disposal site. The waste materials consisting of contaminated soils and debris, were fed into the Chemolite incinerator at 3M's Cottage Grove facility to determine if the incinerator was able to effectively burn the residual waste (3M, 1984 [3MA00382051]). In a June 27, 1984 internal correspondence regarding the Oakdale incinerator ash oil and grease extracts, Jim Gagnon stated that one sample of the incinerator ash extracts "had strong absorptions indicative of a fluorochemical. Insufficient material was available for identification of the fluorochemical" (3M, 1984 [3MA00300324]). Analysis of these ash extract samples provided reasonable suspicion for the presence of PFCs in the incinerator ash. Based on this suspicion, 3M should have conducted a more thorough investigation of the incinerator ash, but the 3M documents I have reviewed do not indicate that this was ever done (Weum, 2017 (p. 114)). - 14 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 2.4 3M's Disposal of PFC-Containing Wastes The wastes produced by PFC-manufacturing processes were disposed of in numerous locations over the years. I understand from my review of 3M documents that waste was disposed of at Cottage Grove, Oakdale, Woodbury, and the Washington County Landfill, as described below, and I concur with the disposal history relating to each site as set forth in the report of Dr. Andrews. C ottage Grove. 3M disposed of PFC-containing wastes at its Cottage Grove facility beginning no later than 1951, according to remedial investigation reports by a 3M contractor and other 3M documents: Various unspecified fluorochemical wastes were burned or landfilled at the site until 1956 (3M, 1981 [3MA00364080]). Skimmings from the former wastewater treatment pond were disposed of in area D-5 for at least part of the period from 1948 to 1962 (3M, 1986 [3MA00364082, -096 98]). Wastewater from the PFC-manufacturing process flowed via the chemical sewers into the former 3M wastewater treatment pond from at least 1951 to 1962 and afterwards to the 3M wastewater treatment plant (3M, 1986 [3MA00364082, -099]; 3M, 1958 [3MA00456234, -239]; 3M, 2004 [3MA00722658, -689]). From 1963 to approximately 1973, acid tars from the electrochemical fluorination process were disposed of in area D-1 (3M, 1986 [3MA00364082, -096]; 3M [3MA01201775]; 3M, 2004 [3MA00722658, -684]; Santoro, 2017 (pp. 31-32)). Sludges from 3M's wastewater treatment plant were disposed of in areas D-2 and D-9 from at least 1964 to 1973 and in area D-6 from 1978 to 1980 (3M, 1986[3MA00364082, -096-97]; 3M, 2007 [3M_MN01483002, -016]; 3M, 1986 [3MA00294816, -818]). Incinerator ash was disposed of in area D-6 from 1978 to 1979 (3M. 1978 [3M_MN00052172]; 3M [3MA00276845, -848]). With the exception of area D-1, which was believed to have been concrete-lined, and area D-6, which was partially bentonite-lined, these disposal areas were not lined or otherwise designed to prevent the infiltration of pollutants into the soil (3M, 1986 [3MA00364082, -096]; 3M [3MA00281033, -035]; 3M, 2004 [3MA00722658, -684]). Even though these two waste disposal areas were supposedly lined, the concrete and bentonite liners were porous materials. The liners had limited conductivity, but the conductivity of liquids through the liners was not zero. Small volumes of water with these dissolved materials would have penetrated the liner materials into the underlying soils. Elevated levels of PFOS. PFOA, and PFBA were detected at a number of locations at Cottage Grove, including areas D-1, D-2, D-5, D-8, D-9, the area once occupied by the former - 15 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN wastewater treatment pond, and the East Cove area, where effluent from the former wastewater treatment pond (1955-62) and the current wastewater treatment plant (1962-present) discharged into the Mississippi River (Weston, 2007 [3M_MN01483002] (pp. 4-5 to 4-10, 5-3 to 5-6)). Oakdale. 3M disposed of acid tars and probably a number of other PFC-containing wastes at the Oakdale disposal site from 1956 to 1960 (3M, 1980 [3MA01248573]). Elevated levels of PFCs were found near the waste disposal trenches and with buried drums at this disposal site. There is no indication that the waste disposal areas were lined or otherwise designed to prevent infiltration of contaminants into the soil and groundwater (3M, 2011 [3M_MN01362671, -685]; Weston, 2007 [3M_MN04969186] (pp. 4-1 to 5-2); Weston, 2008 [3M_MN00116060] (pp. 2-9 to 3-1)). W oodbury. 3M disposed of acid tars from its Cottage Grove facility at the Woodbury site from 1960 to 1963. From 1960 to 1966, 3M disposed of various industrial wastes at the Woodbury site referred to by 3M as "wet scrap." These wastes contained PFCs. Although some trenches at the Woodbury disposal site were lined beginning in 1962, observers noted that the clay liners did not prevent the seepage of wastes into the soil. Elevated levels of PFOS, PFOA, and PFBA were detected at the Woodbury site (3M, 2010 [3M_MN00826383]; Weston, 2008 [STATE_07240271] (pp. 4-10 to 4-14); Kiester, 2017 (pp. 26-27)). W ashington C ounty Landfill. 3M disposed of wastes including wastewater treatment plant sludge and incinerator ash from 1971 to 1974, at the Washington County Landfill, which was a former sand and gravel quarry. There is no indication that the disposal locations were lined or otherwise designed to constrain the migration of PFCs into the soil and groundwater. Elevated levels of PFOS, PFOA, and PFBA have been detected at the site (MPCA, 2008 [CHARTIS00009805]). - 16 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 2.5 Bioaccumulation of PFCs 3M knew and was well aware that PFCs accumulated in humans and animals since the mid-1950s. Early research with PFC derivative compounds demonstrated a strong association between the perfluorocarbon carboxylic acids and proteins. Specifically, PFOA was found to bind and coagulate serum proteins to precipitate these biological compounds from solution (Klevens and Ellenbogen, 1954). Essentially, this means that PFCs would precipitate as solids in the blood and remain in the body, and would likely be collected in the liver. Further research revealed that longer PFCs would cause greater precipitation of proteins. As described in further research by Klevens, the formation of complexes between PFCs with proteins and polypeptides suggested the interaction between polar groups on the proteins and the PFC compound. As the length of the fluorocarbon chain increased, the greater the activity of the PFC as a protein coagulant (Klevens, 1955). Accordingly, longer-chain PFCs--such as PFOA and PFOS--would be expected to cause greater precipitation of proteins. Additional work by Nordby and Luck at Stanford University, using PFCs supplied by 3M, demonstrated that human blood proteins and other proteins of the human body were bound to and precipitated by PFCs. These precipitated proteins, which when bound to the PFCs, were filtered from the bloodstream by the kidneys and liver of the individual. Once removed from the bloodstream, the precipitated proteins collected, particularly in the liver, where the PFCs accumulated (Nordby and Luck, 1956). 3M thus knew that PFCs accumulated in living organisms by 1956. By the early 1970s, clinical trials by Leland Clark and his coworkers at the Children's Hospital Research Foundation found that the straight-chain PFCs were deposited in the liver and remained in the liver for the lifetime of the animal (Clark et al., 1973). As acknowledged in the research publications, the PFCs used in the above cited research were provided to the researchers by 3M. Since the research was published in the open scientific literature, and 3M provided the PFCs, 3M knew or should have known, the results of the research, namely, that PFCs accumulated in living organisms. 3M's own research in the mid- and late-1970s quantified the extent that various PFCs bioaccumulated in various animals, confirming 3M's awareness of this basic fact about PFCs (Purdy, 2017 (rough tr. pp. 35-38)). In 1978, 3M researchers reported the uptake and accumulation FM-3422, a PFC compound that metabolizes and releases PFOS. The report concluded that FM-3422 bioaccumulated in channel catfish, with bioconcentration factors in excess of 1,000 for the brain and gastrointestinal tract (3M, 1978 [3MA00326803]). Similarly, a 1979 study, citing research in 1975 and 1977, indicated "that fluorochemicals can bioaccumulate in fish in a laboratory environment." This report determined that fish caught in the Tennessee River near 3M's Decatur, Alabama plant had detectable levels of fluorochemicals. 3M's study concluded that the three fluorochemicals tested bioaccumulated in the gastrointestinal tract, reproductive system, and fat of channel catfish (3M, 1979 [3MA01409559]). - 17 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN In a 1978 study, rhesus monkeys were fed subacute doses of FC-143 for 90 days. At the higher dosage levels, the monkeys were adversely affected with no survival in the highest test group and only limited survival in the second highest test group. In all test groups, both genders were found to accumulate FC-143 in the liver (3M, 1978 [3M_MN02343997, -4000, -4001]). Similarly, in a 1978 feeding study with FC-95, rhesus monkeys were fed subacute doses for 90 days. After 90 days, all test animals survived except the subjects in the highest test group. In all test cases, FC-95 was found to accumulate in the liver of the test animals (3M, 1978 [3M_MN02343995, -996]). Beginning in 1976, 3M conducted blood testing of employees to ascertain the levels of PFCs in their workers' blood (3M, 1977 [3M_MN00000479, -481]; 3M, 1977 [3MA10035028, 029]). Blood serum concentrations in the some of the earliest samples were characterized as high in comparison to a Red Cross plasma sample (3M, 1977 [3M_MN00000296]). Later samples that year identified plant personnel with up to 300 times normal levels of PFCs in blood (3M, 1977 [3M_MN00000479, -481]). By June 1976, a 3M analysis of previously exposed laboratory personnel "indicate[d] that organically based fluorine remains in the blood for an indefinite period." (3M, 1977 [3MA10035028, -29]). Later testing and analysis led to the conclusion that many PFCs accumulated in humans with a half-life for elimination of four years or more (3M, 2002 [3M_MN02334814]). - 18 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 2.6 Toxicity and Ecotoxicity of PFCs My independent review of the scientific literature and 3M's internal studies indicated that, by the early 1960s, 3M knew that PFOS, PFOA, and PFBA pose a potential harm to human health and pose a significant threat to the environment. E arly literature. A review of scientific literature demonstrated that 3M knew by the early 1960s that PFCs were harmful. In the years following World War II, the scientific literature documented that the replacement of hydrogen with fluorine in organic compounds would produce physiological and even toxic responses in tested subjects. As an example, fluoroacetate was lethal to dogs and lower animals even at very low doses (Peters, 1951; Saunders, 1961; Hodge et al., 1963). The toxic responses due to methylfluoroacetate and other fluorine-substituted compounds were the basis for much of the research on new chemical warfare agents at the Army Chemical Center during World War II (Hodge et al., 1963). By the early 1960s, the toxic effects of a number of fluorinated compounds were published in the scientific literature: Early research by B.C. Saunders demonstrated that a variety of fluorinated compounds exhibited toxic effects. As stated by Saunders, "certain compounds have greatly altered physiological action when hydrogen is replaced by fluorine." Some of the adverse physiological effects noted from the testing of fluorocarbon compounds include anesthesia, depression, enzyme inhibition, and metabolic effects. Other pharmacological responses reported by Saunders include (1) a blood pressure effect; (2) a membrane transfer of tetraethylammonium derivatives; (3) a depression of adrenal ascorbic acid content; and (4) sympathetic nervous system blockage (Saunders, 1961). Writing in 1963, J.M. Hamilton concluded that fluorocarbons "ha[ve] been found to run a complete gamut of toxicity, ranging from entirely innocuous to the quickly lethal" (Hamilton, 1963). Similarly, in a 1963 discussion on the biological effects of organic fluorides, for example, Dr. H.C. Hodge explained, "[t]he toxic effects of the organic fluorine compounds are unlike those of inorganic fluoride; in general, the effects are not consequent on the liberation of the fluoride ion. ... [A] variety of biological effects has been noted in experimental animals following acute administration of organofluorine compounds" (Hodge et al., 1963). Likewise, Taylor and Kent presented additional results in 1965 demonstrating that the substitution of fluorine in biomolecules can alter the function of those molecules, resulting in various--and in some cases, adverse--physiological effects. They wrote: "Interest has centered mainly around the fact that the hormonal activity of certain steroids, notably corticoids, is often enhanced by the replacement by fluorine of a hydrogen atom. ... It is now clear, however, that a wider range of structural modifications, with retention or enhancement of biological activity, is possible than was previously considered to be the case" (Taylor and Kent, 1965). - 19 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN From this early scientific literature, it is plainly evident that fluorocarbon compounds hold the potential to produce physiological, and even toxic responses in living organisms. 3 M research . Beginning in 1950, 3M's research confirmed the toxicity of many PFCs: In 1950, 3M conducted acute toxicity studies of PFBA and concluded that a dose of 804 mg/kg administered orally to rats was lethal to fifty percent of the tested animals by the end of one week. In the same test, LD50 values7 of 435 mg/kg and 755 mg/kg, respectively, were determined for the intraperitoneal and intravenous injections of PFBA in mice after 24 hours (3M, 1950 [3MA02497530]). In 1954, an acute oral toxicity study of the potassium salt of PFOA on mice found a lethal dose 500 mg/kg. The sodium salt of PFOA was found to have an approximate LD50 value of 400 mg/kg when administered as a single dose to Sprague Dawley rats by feeding tube (3M, 1954 [3MA01828941]). In 1956, a feeding study of the lithium salt of PFOS was found to have a lethal concentration of 500 mg/kg when administered as a single dose to rats. A separate 1956 study determined the "minimal lethal dosage" of 260 mg/kg for the intravenous injection of PFOA into mice (3M, 1954 [3MA01828941, -942]). In a 1963 sales brochure for its fluorochemical surfactants, 3M described FC-95 (the potassium salt of PFOS) as "moderately toxic," with an acute toxicity of 450 mg/kg in rats. The brochure characterized other PFC surfactants as "slightly toxic to moderately toxic." (3M, 1963 [3MA01201629]). In 1966, 3M contracted with Industrial Bio-Test Laboratories, Inc. for the study of the acute oral toxicity in albino rats for two of its PFOS derivative compounds. The two fluorochemicals, L-1931 and L-1932, were found to have acute LD50 values of 2600 mg/kg and 900 mg/kg, respectively, following a single administered dose (3M, 1966 [3MA01789595]; 3M, 1966 [3MA01789592]). After discovering PFCs in human blood in 1976, 3M launched a more detailed toxicological investigation. By 1978, 3M had conducted numerous studies that confirmed the toxicity of its PFCs, including PFOS and PFOA: A 90-day subacute toxicity study, conducted on Rhesus monkeys in 1978, determined that feeding FC-95 at a rate of 4.5 mg/kg/day caused all test animals to die within the first few days of the feeding study. In the highest two test groups, FC-95 was found to substantially bioaccumulate in the livers of test animals post-mortem (3M, 1978 [3M_MN02343995]; 3M, 1978 [3MA10032058, -059-60]). 7 The quantity of a compound that is lethal to fifty percent of tested subjects is sometimes listed as the "LD50" for that compound. - 20 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN A 90-day subacute toxicity study conducted on Rhesus monkeys in 1978, determined that feeding FC-143 (a salt of PFOA) resulted in death of all test subjects at the feeding rate of 100 mg/kg/day and the death of three out of four test subjects at a feeding rate of 30 mg/kg/day (3M, 1978 [3M_MN02343997]). In a 90-day feeding study with FC-95 on rats, all test subjects died prior to termination of the study at dosage levels of 300 mg/kg/day and above (3M, 1992 [3M_MN02252650]). In a Range-Finding and Definitive Teratology Study in rabbits, the study results indicated a 56% survival rate for female rabbits fed with 96% lithium perfluorooctanesulfonate, a salt of PFOS, at a rate of 4 mg/kg/day (3M, 1992 [3MA01405447, -448]). By 1980, at least two tests concluded that certain PFCs were teratogenic, in that these PFCs produced malformations in developing rat fetuses (Butenhoff, 2017 (pp. 142-46)). FM3422, when given to pregnant rats, caused changes to rat fetuses such as "cleft palate, blood in the kidney parenchyma and sternebrae malformations" (3M, 1981 [3MA00326722]). A salt of PFOS caused "[significant increases in external and visceral anomalies [in the high dose group] includ[ing] subcutaneous edema, cleft palate, and cryptorchism, as well as "delays in skeletal system ossification" (3M, 1983 [3M_MN02456142]; 3M, 2000 [3MB00023926]). Further studies confirmed that PFCs also posed a significant danger to aquatic life and the environment. Indeed, 3M even used the known physiological effects of fluorochemical compounds to develop new products from their PFC derivatives (Guenthner a n d Vietnor, 1962; Bryce, 1964). These new products included microbiocides, compounds that kill microbes, demonstrating obvious toxic effects on living organisms. As observed by Dr. B ryce (1964): "Fluorocarbon compounds have shown some interesting microbiocidal activity. As might be expected, the fluorocarbon portion of the molecule is physiologically inert; but by varying the functional group, some compounds have shown to have unusually high activity as bactericides and algaecides." In 1970, a technical journal published a letter warning of the toxicity of 3M's Light Water product. The author reported, based on rigorous testing, that the compound's effects were "highly derogatory to marine life and the entire test program had to be abandoned to avoid severe local stream pollution." At concentrations as low as 4 ppm, he added, the survival time of the fish tested was less than seven days. At all concentrations tested, the fish exhibited "erratic motion, loss of stability and other visibly odd effects" (3M, 1970 [3M_MN02267863]). 3M's own testing in the early 1970s confirmed the toxicity of FC-95, a salt of PFOS, to bluegill sunfish (1972), water flea and scud (1973), mummichog, grass shrimp, and fiddler crab (1974), algae (1974), and Atlantic oysters (1974) (3M, 2000 [3M_MN00436402]; 3M, 2000 [3M_MN01656831]; 3M, 2000 [3M_MN00437323]; 3M, 2000 [3M_MN00436466]; 3M, 2000 [3M_MN00437343]). Concerns about the environmental effects of fluorocarbons compelled 3M to initiate the Fate of Fluorochemicals project, which was designed to further understand the environmental impact of perfluorocarbon compounds. Subsequent studies established the toxic - 21 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN effects of various PFCs on organisms such as the bluegill sunfish by 1979 (3M, 1979 [3M_MN02854547]; 3M, 1979 [3M_MN02854512]; 3M, 1979 [3M_MN02255655, -657]). Additional studies in the late 1970s and early 1980s continued to confirm the impacts of PFCs on the environment (3M, 1979 [3M_MN00000151]; 3M, 1979 [3M_MN00000745]; 3M, 1979 [3MA01410327]). 3M researchers analyzing these findings in 1983 noted that "[i]n the case of fluorochemicals, structure considerations and test results to date give rise to concern for environmental safety. . . . These concerns give rise to legitimate questions about the persistence, accumulation potential, and ecotoxicity of fluorochemicals in the environment" (3M, 1983 [3MA10065465]). - 22 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 2.7 3M's Unique Awareness of the Environmental and Health Risks of PFCs Since the acquisition of the patents, 3M developed an extensive, proprietary body of knowledge about PFCs and their properties. It acquired the patents related to the electrochemical fluorination process from Dr. Simons, who subsequently collaborated with 3M employees such as T.J. Brice, H.G. Bryce, and W. H. Pearlson, and conducted additional research with 3M support (Simons et al., 1949). As demonstrated in the previous subsections of this report, 3M's researchers conducted or commissioned a series of studies on the chemical properties, fate and transport, and toxicological properties of PFCs. Many of these studies were not shared in a timely manner with regulators or other interested parties or used to improve 3M's handling of PFC-containing wastes. 3M's understanding of PFCs eclipsed that of regulators and outside researchers. For example: Properties. The early work of Simons, Brice, and Bryce, among others, demonstrates 3M's early mastery of the properties of PFCs. Their publication of chapters in the multivolume Fluorine Chemistry and articles in Scientific American illustrate that they were at the forefront of this emerging area of research (Simons, 1949; Simons et al., 1949; Brice, 1950; Pearlson, 1950; Simons and Brice, 1954; Bryce, 1964). M an u factu rin g P rocess a n d Wastes. 3M used Simons' electrochemical fluorination process to manufacture PFCs after acquiring the patent from Simons. 3M's Cottage Grove facility, which began the commercial manufacture of PFCs in 1951, was the first of its kind (Simons and Brice, 1954). In addition, 3M employed numerous chemists and engineers who specialized in the development and production of PFCs. As a result, 3M had unique knowledge of the process and the wastes it produced, and regulators were dependent to a significant degree on 3M to disclose important facts about the manufacturing process and wastes. B ioaccum ulation. 3M's understanding of the properties of PFCs, together with their in-house research capabilities, gave 3M extensive insight into the question of whether and how PFCs bioaccumulated in living organisms. In addition, at least one of the researchers obtained the PFCs directly from 3M (Nordby and Luck, 1956). R isks to H u m an H ealth a n d th e E nvironm ent. Here as well, 3M's extensive resources and in-house research capabilities meant that 3M was better situated than regulators or outside researchers to understand the potentially harmful properties of PFCs. By the 1960s, 3M had accumulated lethal dose data on a variety of PFCs that were likely unknown to regulators and others. Following the environmental testing of its PFCs, 3M had a better grasp of the fate and mobility of PFCs than USEPA or Minnesota regulators (3M, 1979 [3M_MN00000151, -159-160]; 3M, 1979 [3M_MN00000745, -752 -753]; 3M, 1979 [3MA01410327, -333 -336]). A n a lytica l Capabilities. By the 1970s, 3M had the instrumentation and technical knowledge to rival any public universities and private laboratories. The Central Research Analytical division at 3M, and later the Environmental Laboratory division, - 23 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN was constantly developing new and better techniques to quantify their products, including PFCs. For example, in 1976, Central Research Analytical isolated and characterized PFOA from the blood of a Chemolite supervisor (3M, 1977 [3MA10035028, -029]). By November 1977, 3M had the capabilities to determine both total fluorine and inorganic fluorine in whole blood, plasma, serum, and liver samples down to concentrations of 0.01 parts per million (3M, 1977 [3MA00016495, -496]). As indicated in the 1978 report on organic fluorine in blood, 3M stated that its laboratory was one of "only three or four other laboratories in the world are currently able to measure organic fluorine in blood plasma or serum" (3M, 1978 [3MA10067017, -019]). By 1979, 3M could quantify PFOS and PFOA at parts-perbillion levels (3M, 1979 [3MA00639014]). Similarly, its testing of wastewater from its Decatur facility in 1980 demonstrates that 3M had an early ability to detect and quantify certain PFCs, such as PFOA, in water at parts-per-billion levels (3M, 1980 [3MA01406743, -744]). G eology a n d H ydrology. By the 1960s, 3M had a full geology department, which was quite unusual for a manufacturing company that produced consumable goods such as tape and sandpaper. Members of 3M's geology department had a thorough knowledge of the movement of liquids through porous media, namely soils. From its geology department, 3M understood the infiltration and movement of water into the underlying soils as well as the movement of soluble components in their wastes disposed above these soils (3M, 1960 [3M_MN00000135, -137]). Further, the geology department members had the forethought to install test borings to ascertain the subsurface conditions and to recommend observation wells for reference prior to the disposal of wastes at the Woodbury site (3M, 1960 [3M_MN00001421, -422]; 3M, 1960 [3M_MN00000231, -232]). 3M also had, by the 1960s, a sanitary engineering department with extensive knowledge of the subject (Kiester, 2017 (pp. 96-98)). Knowing that components of their waste would leach with the infiltrating water, 3M completed three soil borings, in 1962, to study the degree of penetration of its waste chemicals in the underlying soils and groundwater at the Woodbury site. Samples from the borings were analyzed for volatile organic compounds, including ethanol, heptane, acetone and methyl ethyl ketone, which had reached the level of the groundwater in one of the three borings (3M, 1962 [3M_MN00000220]). To my knowledge, this assessment of organic compounds in the groundwater below a disposal site was one of the first of its kind. It wasn't until years later that scientific publications reported the presence of organic contaminants from landfills had contaminated the groundwater (Brown and Donnelly, 1988). More broadly, 3M had extensive experience in industrial waste disposal and its potential environmental effects. In 1970, President Nixon appointed Bert Cross, then Chief Executive Officer of 3M, as the chairman of the National Industrial Pollution Control Council. The Council was an advisory body comprised of "industrial leaders" established to provide a mechanism for "business and industry to actively and visibly support the drive to abate pollution from industrial sources." The appointment of 3M's chief executive to this important post recognized 3M's advanced knowledge of how improper waste disposal practices could cause - 24 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN lasting harm to the environment (Weekly Compilation of Presidential Documents, 1970 (p. 502)). However, as discussed in Section 3.2 and elsewhere in this report, 3M failed to use this knowledge to avoid ongoing harmful waste disposal practices. - 25 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 3. OPINIONS AND BASIS FOR OPINIONS 3.1 3M's Disposal of PFC-Containing Waste Contaminated the Groundwater By the early 1950s, 3M knew or should have known that pollutants from landfilled industrial wastes would reach the groundwater beneath its disposal sites and would pose a potential threat of harm to human health and the environment and harm the State's natural resources. By the early 1960s, 3M knew that groundwater beneath at least two of its disposal sites was contaminated with industrial organic chemicals that were components of its waste. A number of technical investigations and public health crises in the early- to mid twentieth century made clear that the disposal of wastes by landfilling could lead to the contamination of groundwater. 3M documents show that it was keenly aware of the potential for groundwater pollution, and 3M studies of potential disposal sites reflect an awareness that certain choices could slow the rate of contamination. By the early 1960s, 3M engineers had conclusively demonstrated that landfilled wastes from 3M disposal sites had polluted the groundwater in the East Metro area. Information Generally Available from Technical Literature and Media Reporting Long before 3M began producing PFCs and their derivative compounds, Dr. L.A. Richards proved the theory of liquid flow through unsaturated porous media (Richards, 1931). Plainly speaking, liquids will flow downward through the soil under the force of gravity and hydraulic potential. Further, in a presentation before the New York State Sewage Works Association in 1932, A.F. Dappert demonstrated that "chemical pollution can be carried for a long distance through fine sand even when the rate of groundwater flow is fairly slow" (Dappert, 1932). In applying the work of Richards and others from the U.S. Department of Agriculture, the California State Water Pollution Control Board (SWPCB) commissioned a series of field investigation studies to determine the effects of different forms of waste disposal on groundwater quality. In 1952, one such study demonstrated that the infiltration and percolation of precipitation through an incinerator ash dump will leach soluble components from the dump. The soluble components will move with the infiltrating water downward under the force of gravity to the groundwater (SWPCB, 1952). A related study demonstrated the following year that wastewater containing soluble chemical compounds, when placed on the soil surface, can infiltrate the surface soil and transport the dissolved chemical compounds to subsurface soils and the groundwater (SWPCB, 1953). A 1961 SWPCB study showed that water applied to the surface of a refuse disposal site may infiltrate the fill and cause the leaching and transport of soluble components in the fill downward to reach the groundwater (SWPCB, 1961). - 26 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Thus, by the 1950s, widely available scientific and technical literature contained much information related to the movement of soluble compounds from disposed waste through the surrounding soil and into the groundwater. Therefore, 3M--as a sophisticated company with significant scientific resources--knew or should have known that compounds from its landfilled wastes could contaminate the groundwater. In addition, 3M should have been aware by the 1950s of public health crises arising from the contamination of groundwater. For example, 3M should have been aware of a number of cases of methemoglobinemia attributed to the presence of nitrates in the groundwater. Methemoglobinemia, a very serious condition in young children often referred to as "blue baby syndrome," results from the ingestion of water containing high concentrations of nitrate. The occurrence of many observed cases of methemoglobinemia during the period from 1947 to 1949 led to national media coverage of the disease, including further investigations conducted by the Minnesota Department of Health in 1951 (Minneapolis Star, 1948; Schmidt, 1956). The 1951 Minnesota Department of Health study, and at least one more conducted in the decade that followed, indicated the high concentrations of nitrate in the groundwater resulted from the transport of soluble nitrates from agricultural chemicals applied to the surface soils and the disposal of industrial wastes containing nitrogen (Schmidt, 1956; Woodward et al., 1961). The 1951 study showed that domestic water supplies in Renville, Nobles, Rock, and Mower Counties--three counties in southwestern and south central Minnesota in close proximity to 3M's Minnesota facilities--were impacted by nitrates in the shallow groundwater (Schmidt, 1956). Sampling of shallow groundwater wells demonstrated high concentrations of nitrate due to the infiltration and downward migration of the stable nitrate ion into the groundwater (Schmidt, 1956). Further, a 1959 survey of the water wells in the Village of Coon Rapids indicated that nitrates from sewage treatment had impacted groundwater to the extent that concentrations of nitrates in the groundwater posed a threat to infant health (Woodward et al., 1961). The fact that these groundwater contamination incidents involved nitrate compounds is particularly significant because nitrate compounds are analogous to PFCs in certain respects relevant to groundwater contamination. Nitrate compounds are highly soluble due in part to the high stability of the nitrate ion in aqueous solution. The nitrate species is analogous to PFOA and PFOS in that each of these compounds exists as highly stable and highly soluble anions in aqueous solution. When dissolved in water, PFCs including the PFC acids and acid derivatives (including PFOS, PFOA, and PFBA), dissociate to form soluble anions. With negative charges, the soluble anions are repelled by the soil particles and flow freely with the water, through both the saturated and unsaturated zone. Therefore, 3M would have been able to logically conclude that the environmental behavior of the PFCs would have been similar to that of nitrates and that PFCs would be leached from the wastes, entering into the soils and groundwater. 3M's Research and Deliberations 3M's internal documents from the early 1960s leave no doubt that it was aware of the potential for and actual contamination of groundwater as a result of its waste disposal practices. A review of these documents demonstrates that 3M understood the potential for that - 27 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN contamination to endanger human health and the environment as well as harm the State's natural resources. In the early 1960s, for example, 3M's deliberations about the location of a new disposal site reflected an acute awareness of the potential for contaminants to reach the groundwater. In a July 13, 1960 memo from John A. Brow n of the Geology Department to H ans W essel of the Engineering Department at 3M, discussing the location of the new waste disposal site at Woodbury, Brown stated: From a geological standpoint this area would not be ideal in our opinion; however, from the other merits of this location we feel it should satisfy our demands. If there is a large volume of acid waste dumped, it would be better if the area were immediately underlain by a thick formation of limestone or dolomite. This would help neutralize the acid before getting into the groundwater. . . Other wet wastes, not neutralized nor deposited within rock or soil pore spaces, will eventually reach the water table and pollute domestic wells (3M, 1960 [3M_MN00000135]). 3M's deliberations thus reflected awareness that--absent special geological conditions-- the wastes it landfilled would reach the groundwater. Unfortunately, 3M was not committed to avoiding groundwater contamination caused by its wastes. Instead, as the following quotation from B row n's memo indicates, 3M focused on the factors that would determine how quickly pollution would accumulate: Eventual pollution of adjacent domestic wells will depend on time, geological conditions and rate of wet waste dumping. When waste seepage reaches the water table certain solids by that time may be rendered harmless while others will remain to pollute wells. . . . The other factor, rate of dumping, will hasten or prolong pollution. Degree of pollution will in turn indicate the time when dumping should cease. It may be that other factors will signify a time to abandon the site prior to maximum pollution (3M, 1960 [3M_MN00000135]). Further memos by Brown during this period make clear that although 3M hoped to avoid rapid aquifer pollution, it clearly understood that "eventual pollution" was inevitable and the extent of it would "depend on time, rate, and the care that is exercised in dumping" (3M, 1960 [3M_MN00001421]). This report, as well as relevant deposition testimony from a 3M employee, clearly indicated that 3M knew that the underlying aquifer would, sooner or later, become polluted by dumping the wastes in open trenches (Kiester, 2017 (pp. 24-25)). Additional 3M documents show that 3M understood that its various disposals of wastes at other sites could contaminate the groundwater. A 1969 3M document, for example, related to the disposal of wastewater treatment plant sludge at Cottage Grove noted that one of the "limitations" associated with landfilling the sludge was that "organic contaminants from the sludge may leach into the ground water at the present dumping site" (3M, 1969 [3MA00456474, -475]). Similarly, in 1970, a 3M "Authority for Expenditure" document sought permission to purchase sludge dewatering equipment in part because "[t]he present method of dumping wet sludge into landfill areas on the site cannot be continued because . . . of the potential pollution - 28 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN from organic contaminants leaching into the underground water supply . . . ." (3M, 1970 [3MA00456507]). Just as important, 3M had the understanding and resources to confirm whether its wastes were reaching the groundwater beneath Woodbury and the other sites. In July 1960, Brown and R.C. Collins--recounting a meeting including at least four other 3M employees--stated that the attendees were "again warned of the problem of polluting the underground water and it was recommended that before this site is developed, observations wells into the St. Peter and Jordan formations should be drilled and tested . . . periodically" (3M, 1960 [3M_MN00000231]). A 1962 memo likewise considered the possibility of installing a shallow boring down-slope of the first trench to "see if we are getting any subsurface pollution" (3M, 1961 [3M_MN00000138]). 3M clearly understood that borings or monitoring wells could be used to sample groundwater to analyze it for the presence of contaminants from industrial waste. 3M's Discovery of Contaminants in Groundwater Beneath Its Disposal Sites Analytical testing performed by 3M in 1960 and 1962 confirmed that contaminants from its industrial wastes had reached the groundwater beneath two of 3M's Minnesota disposal sites. At Cottage Grove, where 3M waste disposal began shortly after 3M built the facility there in 1947, 3M's "monthly well water sampling program" was expanded in November 1960 to include "pollution indicators such as phenol, fluorides, chlorides, surfactants, etc." A "main purpose" of the newly expanded "Monthly Water Report" was to "gain the necessary information about the spreading of contamination from local pollution sources to different wells so that sufficient warning can be obtained and adequate measures can be provided in time to assure a continuous supply of good quality process water." Laboratory services for the effort were furnished by "[t]he analytical section of [3M's] Central Research" department. Copies of the November 1960 report were apparently provided to at least 39 other 3M employees (3M, 1960, [3M_MN00052163]). The results of the monthly analysis in November 1960 suggest that its waste disposal practices at Cottage Grove resulted in groundwater contamination at the site, and the author-- Dr. Joseph Ling--explicitly acknowledges the possibility in his memo. "It has been suspected that Well No. 1 has become contaminated because of the continuous increase of alkalinity and hardness in the well water. It is also suspected that the contamination is coming from the waste disposal pond." Although the memorandum concludes that "no conclusive statement can be made" at that point regarding the exact cause of the contamination, it does cite a finding of 0.3 ppm of "surfactant as ABS" in Well No. 1 as "positively confirming] that Well No. 1 was definitely polluted" (3M, 1960, [3M_MN00052163, -164]). Other documents from this period definitively confirm that 3M understood the connection between its waste disposal practices at Cottage Grove and groundwater contamination: An August 1960 memorandum by Allan E. M iller an dR .C . C ollins of the 3M Geology Department described efforts to "determine the source of the pollution of the #1 Jordan well." It noted that "we all felt [the well] is within the sphere of activity of - 29 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN our Chemolite plant." The same memo stated that a visit to a site adjacent to "the previous two settling ponds along the Bulrington [sic] railroad tracks" revealed "a spring with an organic smell and appearance oozing from the gravel strata" there (3M, 1960 [3MA00335929]). A December 1961 memorandum by a 3M employee acknowledged that the wastewater pond contributed to groundwater contamination at the Cottage Grove site. H. S. Parkinson, citing a report by Dr. L ing dated July 31, 1961, indicated that "the pond does not remove any BOD and its leakage is a contributing factor to the contamination of the Chemolite well water" (3M, 1961 [3MA00456329]). A 3M document entitled "Phase One: Chemolite Waste Disposal Program" from no later than 1963 noted that "[e]vidence . . . indicated that the present waste pond has contaminated a nearby water supply well at our Chemolite plan site. We are convinced that contamination will gradually spread to other wells if no corrective measure is taken soon" (3M, 1962 [3MA00456330, -331]).8 Similarly, at Woodbury, 3M detected contamination in the groundwater beneath its disposal site no later than 1962. In spite of the warnings from the Geology Department, waste disposal began in 1960 with the disposal of wet scrap waste from 3M in earthen trenches at the site. In the spring of 1962, 3M conducted an investigation to determine the degree of penetration of contaminants from the disposed waste into the underlying soil. The investigation found that acetone had reached 75 feet below the surface--the level at which groundwater was located. Ethanol, heptane, acetone, ethyl acetate, and methyl ethyl ketone had reached 64 feet below ground surface. Dr. Ling, the author of the investigation report concluded that "some of our liquid waste chemicals have reached 75' below ground within about one year of operation." He concluded that "[i]t is our opinion the waste disposal problem has reached the point where some immediate action should be taken" (3M, 1962 [3M_MN00000220, -221]). Other documents from the period of 3M disposals at Woodbury from 1960 to 1966 clearly indicate 3M's awareness that contaminants from its waste were polluting the groundwater. A May 1962 memorandum by R.C. Collins stated in connection with an engineering study of the Woodbury dump site that "[i]t is the consensus of the Geology Department in regard to safeguarding the underground water supply of the area, that the company seriously consider the installation of an incinerator or other means, whereby this wet waste material will not have an opportunity to seep into the soil" (3M, 1962 [3M_MN00000380, -381]). A July 1963 memorandum by K.R. K noblock regarding waste disposal at Woodbury described visual evidence that clay liners used by 3M in some trenches as a seal to retard seepage did not prevent the infiltration of liquids into the soil. "It appears to 8 Certain elements of the document's text suggest that it was written no later than 1963. For example, the author notes that certain wastewater treatment experiments "will be continued until 1963" (3M, 1962 [3MA00456330, -331]). - 30 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN the writer that this seal is ineffective," he wrote. "[A] truck driver pointed out the fact that as soon as the waste was dumped it seeped into the ground" (3M, 1963 [3M_MN00000379]; Kiester, 2017 (pp. 55-56). A separate July 1963 memorandum by M .C. Goldsm ith and K.R. K noblock described the conclusion of a meeting of 3M employees during a visit to the Woodbury site as follows: "Those present concluded that steps must be taken to protect 3M interests and township residents by reducing the danger of ground water pollution by more efficient means of waste disposal" (3M, 1963 [3M_MN00000717]). In all of these documents, there was no indication that 3M believed the groundwater would not become contaminated. To the contrary, these documents clearly acknowledge that the groundwater would be contaminated. The variety of authors and recipients of these internal correspondences show that this fact was widely understood within 3M. Finally, given 3M's awareness of its own PFC manufacturing and disposal practices of large quantities of PFC-containing wastes, 3M's sampling data from the 1960s should have alerted 3M that PFCs from its PFC-containing wastes were reaching the groundwater. Even if 3M lacked the analytical ability to quantify the presence of specific PFCs, its employees observed two indicators of possible PFC contamination of the groundwater--detections of surfactants and observations of foaming: Surfactants were detected in the water beneath Cottage Grove and Woodbury in the 1960s. The November 1960 monthly water report for Cottage Grove, described above, noted detections of "[s]urfactants as ABS" in "Well No. 1," "Spring," and "Pond" at levels of 0.3, 1.3, and 1.2 ppm, respectively (3M, 1960 [3M_MN00052163, -168]). Similarly, an April 1969 3M report on the Woodbury water problem found surfactants at the level of 0.07 ppm (3M, 1969 [3MA00335191, -199]). At Woodbury, a 1967 investigation of the groundwater revealed the water had a "sweet, antiseptic" odor and "created a noticeable foam." The foaming of groundwater is an important indication that surfactants, such as 3M's fluorochemical surfactants, were potentially present. The same report concluded that "[t]he investigative work undertaken in the past eight months indicates that chemicals similar to those placed in the pits [at Woodbury] have been identified approximately 3/4 of a mile in a westerly direction from the waste pits," at a private well (3M, 1967 [3MA00286007]). The presence of surfactants and foaming in the groundwater--together with 3M's knowledge that its wastes contained fluorochemical surfactants--should have alerted 3M to the strong possibility that its PFCs had reached the groundwater. While in isolation these facts would not put one on notice of PFC contamination, 3M was obviously aware that it was manufacturing large quantities of PFCs and disposing of them along with other waste in and around these sites. 3M also knew that PFCs have surfactant qualities and create foam when exposed to water. Given this knowledge, 3M knew or should have known that its PFCcontaining wastes were reaching the groundwater. - 31 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 3.2 3M's Failure to Exercise Reasonable Care When Disposing of Its PFCContaining Wastes 3M failed to exercise reasonable care in connection with its disposal of PFCs and PFC-containing wastes because it disposed of them without regard for the risk of harm to human health and the environment. Further, 3M failed to exercise reasonable care by failing to prevent the continued release of PFCs into the groundwater and the Mississippi River after they were disposed of at 3M's Minnesota sites. Counsel has informed me that in Minnesota, companies must exercise reasonable care to adequately prevent or mitigate the harm to others foreseeable from their conduct. Counsel has also informed me that the degree of care required to satisfy that standard depends in part on all of the facts and circumstances, and must be commensurate with all known or reasonably foreseeable dangers. In my professional opinion, 3M failed to meet the standard of care needed to protect human health and the environment. As the documents discussed in this report indicate, 3M knew or should have foreseen the dangers of its PFC-disposal practices. A producer of such wastes, exercising a reasonable degree of care, would not have disposed of them in the manner that 3M disposed of them. Up to 1974 (and even later, at the Cottage Grove site), 3M disposed of PFCcontaining wastes at Minnesota disposal sites despite having sufficient information that PFCs could reach the groundwater, accumulate in the environment, and cause significant harm. After 1974, at which point many of 3M's disposals at the Minnesota sites had ended, 3M did nothing to prevent the continued releases of PFCs into the groundwater from its disposal sites. 3M did not provide full and candid disclosures to regulators of the presence of PFCs in the 3M wastes, nor did 3M disclose the risks posed by its disposal of PFCs. 3M's Disposal of Industrial Waste at the Four Disposal Sites (1947-1974, 1978-1980) 3M repeatedly failed to address the readily foreseeable harms resulting from the disposal of its industrial wastes, including PFC-containing wastes, at Cottage Grove, Oakdale, Woodbury, and the Washington County Landfill from 1947 to about 1974 and at Cottage Grove from 1978 to 1980. C o n tin u ed D isp o sa l D esp ite O bservation s o f C ontam ination. 3M knew the characteristics of the PFCs that they were manufacturing, including the reactivity, thermal stability, solubility, and resistance to biodegradation while disposals at the Minnesota disposal sites were taking place. From the beginning of production, 3M knew that the wastes generated from the production operations contained PFCs. By the mid-1950s, 3M knew or should have known that PFCs had the potential to bioaccumulate in living organisms. By the early 1970s, 3M knew that PFCs bioaccumulated in living organisms. By the 1960s, 3M knew that the organic components of their wastes had infiltrated into the groundwater. In 1976, PFCs were found in human blood samples and by the late 1970s, PFCs were found to accumulate in Humans. In 1983, 3M conducted a study that demonstrated the teratogenic mutations in mice by PFCs. Following 3M's early knowledge of these characteristics and impacts of PFCs, subsequent studies confirmed the early findings. - 32 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Despite this knowledge, 3M continued the disposal of wastes notwithstanding evidence that 3M knew the PFCs in the wastes would leach into and migrate with the groundwater. Further, 3M knew that the PFCs leaching from their wastes would cause harm to human health and the environment. Despite this knowledge, 3M landfilled PFC-containing wastes in Minnesota through 1974 and again from 1978 to 1980. During this period, 3M did not attempt actions to prevent the release and movement of PFCs in the groundwater. In addition, 3M did not adequately notify the regulatory authorities of the presence of PFCs in their wastes. An example of 3M's failure to exercise reasonable care during this period comes from its conduct at the Woodbury site, where it continued to dispose of its wastes even though it knew or should have known that PFCs could reach the groundwater. Despite the warnings from the Geology Department that wet scrap wastes and waste solvents would reach the groundwater, 3M began waste disposal at the Woodbury disposal site during the winter of 1960. Wet scrap waste and waste solvents along with acid-containing HF tars from 3M were disposed in open trenches at the site. In the spring of 1962, 3M conducted an investigation to determine the degree of penetration of the disposed waste leachate into the underlying soil and concluded that "some of our liquid waste chemicals have reached 75' below ground within about one year of operation" (3M, 1962 [3M_MN00000220]). As described above, investigations at the Woodbury disposal site in the late 1960s provided more evidence that PFCs had likely migrated to the groundwater beneath the site. A 1967 3M report concluded that "[t]he investigative work undertaken in the past eight months indicates that chemicals similar to those placed in the pits [at Woodbury] have been identified approximately 3/4 of a mile in a westerly direction from the waste pits," at a private well. That investigation of the groundwater revealed "isopropyl ether or a compound similar to it" and observed that the water had a "sweet, antiseptic" odor and "created a noticeable foam" (3M, 1967 [3MA00286007]). The foaming of groundwater is an important indication that surfactants, such as 3M's fluorochemical surfactants, may be present. Despite this evidence, 3M continued to dispose of PFC-containing wastes at the Cottage Grove facility and other waste disposal sites. Further, 3M made no attempt to investigate the PFC contamination in the groundwater, much less remediate the groundwater once it knew the groundwater was likely contaminated with PFCs. Confronted with strong evidence suggesting that toxic contaminants from its industrial wastes had reached the groundwater, 3M should have--at a minimum--halted further disposals until such time as it could confirm that there was no significant risk to human health or the environment. Its failure to do so disregarded known risks to human health and the environment. 3M continued to landfill its PFC-containing wastes in Minnesota disposal facilities incapable of handling such dangerous wastes until at least 1974, and again from 1978 to 1980. See Section 2.4, above. Throughout this period, 3M continued to receive reports from researchers and other interested parties suggesting that its PFCs were capable of causing toxic effects. For example, a researcher wrote the editor of the Fire Journal in 1970 to describe the results of toxicity testing of 3M "Light Water" Film Forming Foam, which contained PFC surfactants. In his letter, the researcher described the testing of hardy fish with aqueous concentrations of "Light Water" ranging from 2.0% (1,250 ppm) to 0.002% (1 ppm) in ten-gallon tanks and reported that the 3M - 33 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN product was "highly derogatory to marine life." At concentrations greater than 0.006% (4 ppm), the survival time of the fish was observed to be seven days or less. The researcher concluded that "at all [tested] concentrations (including . . . 1 part per million) erratic motion, loss of stability and other visibly odd effects were present" (3M, 1970 [3M_MN02267863, -864]). L a ck o f can dor w ith regulators. During the period from 1947 to 1974, 3M displayed a lack of candor with state regulators and failed to cooperate in good faith with those regulators in matters relating to its waste disposal methods and related risks to human health and the environment. A producer of industrial wastes exercising reasonable care would not have hidden information from regulators, because regulators need sufficient information about waste disposal practices in their jurisdiction to assess environmental risks and prioritize resources for investigation and enforcement. 3M developed extensive knowledge of the physical and chemical properties of PFCs that would control the fate and mobility of PFCs in the environment. In addition, 3M developed information regarding the bioaccumulation and toxicity of these compounds during this period, but did not adequately disclose this information to any Minnesota regulator. As a result, regulators were not properly equipped to assess the potential harm to human health and the environment posed by 3M's waste disposal practices. 3M's failure to keep regulators effectively informed about the potential for harmful effects of its wastes amounted to a failure to exercise due care. 3M disposed of fluorochemical wastes at the Oakdale site from 1956 to 1960, but as discussed more fully below, 3M did not disclose its disposal practices to regulators during this period, even after 3M's investigations at its other disposal sites revealed extensive groundwater contamination. 3M's Failure to Address Continued PFC Releases (After 1974) F ailure to R em ediatefo r PF C s in Face o f M ounting Evidence o f Contamination. Even after 3M shifted many of its disposals away from the four Minnesota sites, 3M's failure to address past and continuing releases of PFCs from the disposal sites unreasonably disregarded known dangers to human health and the environment. During this period, as Section 2.6 demonstrates, 3M's knowledge of the harmful effects of PFCs continued to develop: A "Fate of Fluorochemicals" research project undertaken by 3M from 1976 to 1979 studied the effects of four important 3M fluorochemicals on aquatic life and their susceptibility (if any) to degradation by microorganisms, among other things. 3M researchers reviewing these results in 1983 and recommending additional testing concluded that "[i]n the case of fluorochemicals, structure considerations and test results to date give rise to concern for environmental safety. . . . These concerns give rise to legitimate questions about the persistence, accumulation potential, and ecotoxicity of fluorochemicals in the environment" (3M, 1983 [3MA10065465, -471, -476]). 3M had the capabilities to analyze groundwater sampled for PFCs in the late 1970s and early 1980s, yet they failed to analyze samples suspected of containing PFCs at - 34 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN any of their disposal sites during this period (3M, 1979 [3MA00639014]; 3M, 1980 [3MA01406743, -744]). Further testing in 1978 on mammals such as monkeys and rats confirmed the toxicity of PFOS and PFOA (3M, 1978 [3M_MN02343995]; 3M, 1992 [3M_MN02252650]; 3M, 1978 [3M_MN02343997]). Despite this and other evidence concerning the fate of PFCs in the environment and the risks that they posed, I have seen no evidence that 3M took any meaningful steps to reduce the risk posed by releases of PFCs from its landfilled wastes into the groundwater before the 2000s. In my opinion, 3M's inaction, while PFCs it had landfilled continued to contaminate the environment, was not an adequate response to the known risks to human health and the environment. By allowing leachate to continue to contaminate groundwater, 3M failed to exercise reasonable care. In com plete a n d M isleadin g D isclosu res to R egulators. On many occasions, 3M scientists and other employees provided misleading or incomplete information to regulators and independent researchers. By failing to provide information about PFCs or disposal practices, 3M frustrated outsiders' ability to determine the nature of the harms resulting from PFCs and address their causes. For example: 3M made a number of incomplete disclosures to the Minnesota Pollution Control Agency (MPCA) regarding its disposal practices at the Oakdale site. 3M disposed of its wastes at Oakdale from 1956 to 1960. State regulators learned about 3M's disposal of wastes there from area residents--not from 3M--some 18 years later, in 1978 (3M, 1980 [3M_MN00001391]; 3M, 1984 [3MA00296731, -732]). The MPCA requested additional information from 3M, but was told only that "the history of the site is vague" and that 3M believed that "the materials disposed of at this site were discarded product, such as rolls of tape, `Scotchbrite', and some waste materials such as hardened resins and miscellaneous scrap" (3M, 1979 [3MA00284889]). A follow up letter sent by the agency requested a response "more specific than the letter [previously] sent to the Agency" (3M, 1980 [3M_MN00000351]). Ultimately, the MPCA's investigation determined--with little help from 3M--that a number of 55gallon drums with chemical waste were buried on site and that there were not just one, but two, disposal sites at the Oakdale site (3M, 1980 [3M_MN00001391, -393 94]). This delay in providing relevant information to the MPCA impaired regulators' ability to assess and respond to potential environmental harm resulting from 3M's waste disposal practices. 3M likewise failed to adequately disclose the nature and extent of its waste disposal activities at the Cottage Grove site. In 1981, the MPCA requested information about 3M's hazardous waste disposal practices at the Cottage Grove site with respect to a variety of materials, including "fluorocarbons" (3M, 1981 [3M_MN00000218]). 3M's response provided information about other wastes but omitted any information about fluorocarbons (3M, 1981 [3M_MN00000143]). Similarly, the remedial investigation reports submitted by 3M's contractor did not adequately disclose the - 35 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN nature of the wastes landfilled at Cottage Grove. The 1986 final report provided a list of twenty chemicals "historically used at the Chemolite Plant" and noted that "[i]t could be expected . . . that wastes disposed of at the Chemolite Center are either combinations of these chemicals or the products of reacting two or more of these chemicals." But none of those chemicals were PFCs or even contained fluorine (3M, 1986 [3MA00364082, -101-02]). Throughout this period, 3M failed to adequately disclose the results of its internal research on PFCs to federal regulators, contrary to section 8(e) of the Toxic Substances Control Act (TSCA) and other provisions of federal law. Enacted in 1976, TSCA required manufacturers to provide all information that "reasonably supports the conclusion" that a chemical "presents a substantial risk of injury to health or the environment." In many important respects, however, 3M failed to meet this obligation. In April 1978, for example, 3M conducted tests on monkeys and rats lasting up to 90 days to determine the effects of exposure to FC-95, FC-143, FM3422 (PFOS, PFOA, and N-EtFOSE, which metabolizes to PFOS, respectively). In light of the studies' "indisputable" findings of "liver toxicity in the rat" and "GI toxicity in the monkey," 3M researchers concluded that "[t]hese compounds are by no means biologically inert." (3M, 1979 [3MA00967577]). Despite these findings, 3M decided in May 1978 not to immediately report these results to the EPA under TSCA section 8(e) (3M, 1978 [3MA10066961]). Indeed, in an August 21, 2000 letter from 3M's Katherine Reed to Jesse Baskerville of USEPA, Dr. Reed disclosed that 3M had identified approximately 30 studies or pieces of information as a supplement to the TSCA section 8(e) dockets for PFOS and related fluorochemicals (3M, 2000 [3MA00847625, -626]; Reed, 2017 (pp. 88-109)). 3M ultimately paid a fine of over $1.5 million to resolve USEPA's allegations that 3M failed to notify USEPA of new chemicals it was manufacturing, failed to timely report substantial risk information, and other reporting violations. The USEPA noted that "several of the violations concerned reporting on perfluorinated compounds," and that the previously unreported information was "valuable" and would "help the scientific community to better understand the presence of toxic substances in the environment" (USEPA, 2006). In com plete a n d M isleadin g D isclosu res to O ther Stakeholders. In addition, 3M failed to adequately disclose important information about its PFCs to other stakeholders such as outside researchers, 3M workers, and customers. In 1975, 3M employee G. H. Crawford reported that he had received a second telephone call from Dr. William Guy with the College of Medicine at the University of Florida concerning his findings of fluorocarbon carboxylic acids (that is, PFOA) in human blood samples. Dr. Guy was trying to understand how PFCs appeared in human blood and wanted to know whether "3M's fluorocarbon carboxylic acids . . . were present in `Scotchgard' or other items in general use by the public." Despite 3M's broad use of PFOA and related chemistries, Crawford said "we plead ignorance but advised him that `Scotchgard' was a polymeric material not a FC acid" (3M, 1975 [3MA10034962, -962-63]). Therefore, Crawford misled the researcher to prevent the - 36 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN discovery that 3M's fluorochemicals could be a source of PFCs in human blood. 3M's failure to disclose to researchers that fluorocarbon acids manufactured by 3M were indeed in wide use prevented researchers from developing an understanding of the presence of those compounds in blood samples. 3M demonstrated a lack of candor to its own employees as well. As a result of others finding PFCs in human blood, 3M developed an accurate analytical method to determine the concentration of organic fluorine in blood samples in early 1976 and began testing of blood samples for employees at the Chemolite plant shortly thereafter. In the annual report to the Corporate Responsibility Committee in November 1976, 3M's Central Research Analytical Department reported the concentrations of organic fluorine compounds in Cottage Grove personnel at up to 1,000 times the concentrations found in the general population (3M, 1977 [3M_MN00000479]). Yet in the minutes from a 1978 3M Fluorochemicals Technical Review Committee meeting, the committee recommended that chemical workers should not be informed until after other pertinent information including "a detailed plan for all other work related to trace fluorochemicals in blood" is completed (3M, 1978 [3MA10067042]). It was not until May 1980, however, that 3M finalized plans for informing employees, customers, regulatory bodies and other appropriate entities, were approved and set in action (3M, 1980 [3M_MN00000756]). For those who had to wait years to learn the outcome of the blood testing, 3M's actions demonstrated a careless attitude about the health and well-being of its employees as well as other stakeholders. Finally, 3M made a number of false representations regarding the properties of its PFC-containing products to 3M customers. For example, 3M falsely represented for years that the fluorochemical surfactants in 3M's Aqueous Film Forming Foam were biodegradable. In a 1989 Technical Information bulletin for FC-783, a variety of AFFF, 3M described the substance as biodegradable and low in toxicity. The bulletin further stated that the 3M AFFF could be treated in a biological treatment system and encouraged environmentally-conscious customers to disperse this material into the environment (3M, 1989 [3M_MN02369894, -895]). In June 1988, 3M was confronted on this issue by Boots & Coots Protective Equipment, a frustrated purchaser from California (3M, 1988 [3M_MN01315290]). Boots & Coots noted its "surprise and total shock" upon learning that the Aqueous Film Forming Foam it had purchased from 3M was not, in fact, biodegradable, causing it "embarrassment and credibility loss." Even after 3M scientist E ric Reiner challenged his colleagues to stop "perpetuating the myth" that fluorochemical surfactants are biodegradable later in 1988, 3M continued to advertise Aqueous Film Forming Foam as biodegradable in its 1989 Technical Information Sheet (3M, 1988 [3MA10035965]; 3M, 1989 [3M_MN02369894]). Even as late as 1994, 3M continued encouraging its customers to use AFFF while privately acknowledging that it was not biodegradable. In a 1994 trip report from a meeting with representatives at the Texas A&M Fire Training school, the fire training school representatives expressed concerns over wastewater treatment and discharge of the training wastes. The representatives also expressed concerns about persistent foam that formed in the aeration pond, which 3M attributed - 37 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN in an internal memorandum to "the non-degradable or slowly degradable surfactants in AFFFs" (3M, 1994 [3M_MN02470154, -155]). Each of these examples illustrates a way in which 3M withheld relevant information from interested third parties. Due to the nature of the industry, producers of industrial products and waste like 3M often possess information that is not generally available, such as information about the producer's manufacturing process and waste streams, the properties of its products and wastes, and its waste disposal practices. 3M's non-disclosure of that information to outside researchers or regulators prevented them from discovering or assessing risks to the environment and human health and thus fell short of the standard of reasonable care. V iolations o f E n viron m en tal Perm its. Even after 3M relocated many of its waste disposal activities away from the four Minnesota sites, it violated permits related to the handling of hazardous wastes. For example, in 1978, after the Pine Bend landfill refused to accept wastewater treatment plant sludge and incinerator ash from the Cottage Grove plant, 3M began disposing of the sludge and ash on the Cottage Grove site without MPCA approval. Wastewater treatment plant sludge was disposed of at Cottage Grove until at least 1979 and incinerator ash until at least 1980. 3M was eventually fined in 1984, following repeated warnings, for "constructing and improperly operating a hazardous waste storage pile without a state and federal permit" (3M, 1984 [3MA00282920]; Santoro, 2017 (pp. 87-90)). In sum, 3M failed to exercise reasonable care by dumping harmful PFC-containing wastes in a manner that would allow them to contaminate the groundwater and the Mississippi River. 3M's violations of permit limitations, lack of candor with regulators and outside researchers, and failure to adequately divulge the characteristics of these wastes were further violations of the standard of care. Finally, as evidence of the dangers of PFCs mounted, 3M declined to take any meaningful steps to prevent continued releases from its landfilled wastes into the environment. Its refusal to adequately respond to a known risk of harm is another, independent failure to act reasonably. - 38 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Signed on this ^ ^ v d a y of September, 2017 in C ) k U ? b 9 T f \ \ l Pflf T R - 39 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 i f 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN DOCUMENTS CITED 1948. The M inneapolis S ta r: 24. September 17. 1970. Weekly Compilation of Presidential Documents, 6(15): 487-513. April 13. 3M Company. 1949. Heptafluorobutyric Acid. [3M_MN03109500 - 3M_MN03109519] 3M Company. 1950. Perfluorobutyric Acid. October 1. [3MA02497530] 3M Company. 1954. Potassium perfluorooctanoic. [3MA01828941 - 3MA01828943] 3M Company. 1958. 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Letter to Louis Breimhurst Regarding Response to Request for Information on Waste Disposal at Chemolite Plant from 1950 to 1955. May 29. [3M_MN00000143 3M_MN00000144] 3M Company. 1981. Letter to R. Susag Regarding Information Request Concerning Alleged Disposal Site at Chemolite Plant Along the Mississippi River. May 4. [3M_MN00000218 3M_MN00000219] 3M Company. 1983. Fate of Fluorochemicals - Phase II. May 20. [3MA10065465 3MA10065579] 3M Company. 1983. Rat Teratology Study T-3351 Final Report. December 19. [3M_MN02456142 - 3M_MN02456222] 3M Company. 1983. Technical Report Summary Regarding Environmental Aspects of POSF. September 1. [3M_MN02571703 - 3M_MN025727] 3M Company. 1984. Email from J. E. Gagnon to D. M. Schnobrich Regarding Oakdale Incinerator Ash Oil & Grease Extracts (PN 83-6896). June 24. [3MA00300324] 3M Company. 1984. Letter from L. Christensen to J. Ling Regarding Notice of Violation, U.S. Environmental Protection Agency and Minnesota Pollution Control Agency Hazardous Waste Violations. January 11. [3MA00282920 - 3MA00282921] 3M Company. 1984. Remedial Actions to Alleviate Groundwater Pollution from a Former Industrial Waste Disposal Site. September 30. [3MA00296731 - 3MA00296741] 3M Company. 1986. Final Remedial Investigation Report For the 3M Chemolite Center, Cottage Grove, Minnesota. February. [3MA00364082 - 3MA0036440] 3M Company. 1986. Letter from Solid Waste Division to Metropolitan Waste Management Advisory Committee Regarding Application for Reissuance of Permit SW-224 and Landfill Expansion: 3M Chemolite Insert Landfill. November 3. [3MA00294816 - 3MA00294820] 3M Company. 1988. Letter from D. Ricker Regarding FC-129 Biodegradability. December 30. [3MA10035965 - 3MA10035966] 3M Company. 1988. Letter from J. Deyonshire Regarding Foam Systems Testing, Beale A.F.B. California. June 3. [3M_MN01315290 - 3M_MN01315292] - 44 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 3M Company. 1989. 3M Brand Technical Information - AFFF FC-783. September. [3M_MN02369894 - 3M_MN02369895] 3M Company. 1992. Letter from P. M. Pesik to A. Costello Regarding Draft Summary Data for Clinical Observations. November 12. [3MA01405447 - 3MA01405448] 3M Company. 1992. Product Toxicity Summary Sheet Fluorad Brand Fluorochemical Surfactant FC-95. June 5. [3M_MN02252650 - 3M_MN02252659] 3M Company. 1993. 3M Cottage Grove Plant Chemical Plant Factory Operating Procedure. July 22. [3MA00206150 - 3MA00206162] 3M Company. 1994. Memo from R. Howell Regarding Trip Report - Texas A&M Fire Training School. May 5. [3M_MN02470154 - 3M_MN02470156] 3M Company. 1996. Email from E. Reiner to K. Wakui Regarding Re: Hydrogen Fluoride Toxicity for Plants. June 6. [3M_MN04747296 - 3M_MN04747299] 3M Company. 1999. Products of Incomplete Combustion of POSF Based Fluorochemicals. June 6. [3MA01412204 - 3MA01412208] 3M Company. 2000. Acute Toxicity to Aquatic Invertebrates (Daphnia Magna). June 27. [3M_MN01656831 - 3M_MN01656840] [AR 226-0718] 3M Company. 2000. Acute Toxicity to Aquatic Invertebrates (Eastern Oyster). June 28. [3M_MN00437343 - 3M_MN00437350] [AR 226-0786] 3M Company. 2000. Acute Toxicity to Fish (Bluegill Sunfish). June 27. [3M_MN00436402 3M_MN00436411] [AR 226-0716] 3M Company. 2000. Acute Toxicity to Invertebrates (Grass Shrimp). June 28. [3M_MN00437323 - 3M_MN00437332] [AR 226-0784] 3M Company. 2000. Algicidal Activity. June 27. [3M_MN00436466 - 3M_MN00436475] [AR 226-0721] 3M Company. 2000. Letter to Jesse Baskerville Regarding 3M Company TSCA Section 8(e) Compliance Audit (April 11, 2000). August 21. [3MA00847625 - 3MA00847632] 3M Company. 2000. Sulfonated Perfluorochemicals in the Environment: Sources, Dispersion, Fate and Effects. March 1. [3MA00045043 - 3MA00045093] 3M Company. 2000. Voluntary Use and Exposure Information Profile Perfluorooctane Sulfonic Acid and Various Salt Forms. April 27. [3MA00001260 - 3MA00001289] 3M Company. 2002. Determination of Serum Half-Lives of Several Fluorochemicals. January 11. [3M_MN02334814 - 3M_MN02334835] [AR 226-1086] - 45 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 3M Company. 2004. Facility Wide Fluorochemical (FC) Investigation Work Plan. December. [3MA00722658 - 3MA00722712] 3M Company. 2007. Remedial Investigation Report Phase 2: Fluorochemical (FC) Data Assessment Report for the Cottage Grove, MN Site. June. [3M_MN01483002 3M_MN01483167] 3M Company. 2007. Remedial Investigation Report Soil Supplemental Fluorochemical Data Assessment - Addendum 1. June. [3M_MN04969186 - 3M_MN04969371] 3M Company. 2007. Report on the Manufacture, Use, and Releases of PFCs At the 3M Cottage Grove Facility. November 30. [3MA02527087 - 3MA02527101] 3M Company. 2008. Feasibility Study Oakdale Site. January 24. [3M_MN00116060 3M_MN00116183] 3M Company. 2008. Remedial Investigation/Feasibility Study Woodbury Site. February 18. [STATE_07240271] 3M Company. 2010. Construction Completion Report Former Main Disposal Area - Woodbury Site. June. [3M_MN00826383 - 3M_MN00826398] 3M Company. 2011. Construction Completion Report (RA Implementation Report). December. [3M_MN01362671 - 3M_MN01362775] 3M Company. Monthly Operating Summary of Chemolite Plant Wet Scrap Incinerator Permit NO. SW9. [3MA00276845 - 3MA00276848] 3M Company. Technical Information by Russell H. Susag, Ph. D, P.E. Manager of Environmental Affairs. [3MA00281033- 3MA00281036] Allen, S., 1984. 3M Waste Burning Test Fails. Metro/Region: Section D. March 11. [3MA00382051 - 3MA00382082] Bacon, D.. Deposition Transcripts. August 3, 2017. 1-172. Brice, T. J. et al., U.S. Patent No. 2,732,398. January 24. Brice, T. J., 1950. Fluorocarbons - Their Properties and Wartime Development. Fluorine Chemistry, 1(13): 423-462. Brown, K. W. et al., 1988. An Estimation of the Risk Associated with the Organic Constituents of Hazardous and Municipal Waster Lnadfill Leachates. Hazardous Waste & Hazardous Materials, 5(1): 1-30. Bryce, H. G., 1964. Industrial and Utilitarian Aspects of Fluorine Chemistry. Fluorine Chemistry. 5(4): 295-498. Butenhoff, J. L.. Deposition Transcript. September 8, 2017. 1-201. - 46 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Clark, L. C. et al., 1973. PFCs Having a Short Dwell Time in the Liver: Science. 18(4100): 680 682. Dappert, A. F. 1932. Public Health Engineering: The Travel of Pollution Underground: Public Health Engineering: 989-994. Dworak, D.. Deposition Transcript. February 24, 2012. 1-261. Grosse, A. V. et al., 1947. Properties of Fluorocarbons. Industrial and Engineering Chemistry, 39(3): 367-374. March. Guenthner, R. A., et al., 1962. Surface Active Materials From Perflurocarboxylic and Perfluorosulfonic Acids, 1(3): 165-168. Hamilton, J. M., 1963. The Organic Fluorochemicals Industry. Advances in Fluorine Chemistry, 3: 117-180. Hodge, H. C. et al. 1963. Biological Effects of Organic Fluoride. Fluorine Chemistry, 3: 1-55. Kiester, C.. Deposition Transcript. September 14, 2017. 1-246. Klevens, H. B. et al., 1954. Protein-Fluoroacid Interaction Bovine Serum AlbuminperfluoroOctanoic Acid. Discussions of the Faraday Society, 18: 227-287. August 20. Klevens, H. B., 1955. Formation of Complexes of Fluorocarbons and Fluorocarbon Derivatives with Polar Hydrocarbons, Polar Polymers, Proteins and Polypeptides, Nature, 176 (4488): 879 880. November 5. Lewis, C. R. et al., 1976. Incineration of Industrial Wastes at a Large Multi-Product Manufacturing Plant: 292-299. MPCA. 2008. Minnesota Pollution Control Agency Remedy: Decision Document - Washington County Landfill - Lake Elmo, Minnesota. June 18. [CHARTIS00009805 - CHARTIS00009812] Nordby, G. L, et al., 1955. Perfluorooctanoic Acid Interactions With Human Serum Albumin. Journal of Biological Chemistry, (219): 339-404. August 1. Pearlson, W. H., 1950. Fluorocarbons Derivatives. Fluorine Chemistry, 1(14): 463-522. Pearlson, W. H., 1986. The Simons Electrochemical Fluorination Process. Journal of Fluorine Chemistry, 32(1): 29-40. Peters, R. A., 1951. Croonian Lecture - Lethal synthesis: Proceedings of the Royal Society of London. Series B, Biological Sciences, 139(895): 143-170. February 28. Purdy, R.. Deposition Transcript (Rough). September 22, 2017. Reed, K.. Deposition Transcript. August 31, 2017. 1-213. - 47 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Reich, C.. Deposition Transcript. August 30, 2017 . 1-158. Richards, L. A., 1931. Capillary Conduction of Liquids Through Porous Mediums. Physics, 1: 318-333. November. Santoro, M.. Deposition Transcript. September 15, 2017. 1-194. Saunders, B.C., 1961. The Physiological Action of Organic Compounds Containing Fluorine. Advances in Fluorine Chemistry, 2: 183-210. Schmidt, E. L., 1956. Soil Nitrification and Nitrates in Water. Public Health Report, 71(5): 497 503. May. Scholberg H. M. et al., U.S. Patent No. 2,717,871. September 13. Simons, J. H., 1948. U.S. Patent No. 2,447,717. August 24. Simons, J. H., 1949. Fluorocarbons. Scientific American, Inc., 181(5): 44-47. Simons, J. H., 1950a. U.S. Patent No. 2,519,983. August 22. Simons, J. H., 1950b. Fluorocarbons and Their Production. Fluorine Chemistry, 1(12): 401-422. Simons, J. H. et al., 1949. The Electrochemical Process for the Production of Fluorocarbons. Journal of Electrochemical Society, 95(2): 47-67. February. Simons, J. H. et al., 1954. Fluorocarbon Chemistry. Fluorine Chemistry, 2(6): 333-448. SWPCB. 1952. Report on the Investigation of Leaching of Ash Dumps: 3-87. SWPCB. 1953. Field Investigation of Waste Water In Relation to Ground Water Reclamation: 3 124. SWPCB. 1961. Effects of Refuse Dumps on Ground Water Quality. Taylor, N. F. et al., 1965. Structural Aspects of Monofluoro-Steroids. Advances in Fluorine Chemistry, 4: 113-141. Van Noordwyk, et al., 1978. Minnesota Mining and Manufacturing Company's Hazardous Waste Program. Environmental Health Perspectives, 27: 245-249. December. Weum, G. Deposition Transcript. August 28, 2017 . 1-206. Woodward, F. L. et al., 1961. Experiences with Ground Water Contamination in Unsewered Areas in Minnesota. A.J.P.H. 51(8): 1130-1136. - 48 - CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 ATTACHMENT 1 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Materials Considered Document Name/Description Academic Article Overview of analytical methods for fluorine in air, water, soil, vegetation, body fluids and tissues Pyrolyses of the Salts of the Perfluoro Carboxylic Acids by J.D. LaZerte, L.J. Hals, T S. Reid and G.H. Smith Bates Number 3MA10017409 3M_MN03412159 "Fluorocarbons" by J.H. Simons "Fluorocarbons - Their Properties and Wartime Development" by T.J. Brice "Industrial and Utilitarian Aspects of Fluorine Chemistry" by H.G. Bryce "Fluorocarbons and Their Production" by J.H. Simons "Properties of Fluorocarbons" by A.V. Grosse and G.H. Cady "The Electrochemical Process for the Production of FLuorocarbons" by J.H. Simons and Coworkers "Fluorocarbon Chemistry" by J.H. Simons and T J. Brice "Protein-Fluoroacid Interaction Bovine Serum Albuminperfluoro-Octanoic Acid" by H.B. Klevens and E. Ellenbogen "Formation of Complexes of Fluorocarbons and Fluorocarbon Derivatives with Polar Hydrocarbons, Polar Polymers, Proteins and Polypeptides" by H.B. Klevens "Perfluorooctanoic Acid Interactions with Human Serum Albumin" by G.L. Nordby and J.M. Luck Croonian Lecutre - "Lethal synthesis" by R.A. Peters "The Physiological Action of Organic Compounds Contianing Fluorine" by B.C. Saunders "Biological Effects of Organic Fluorides" by H.C. Hodge "Structural Aspects of Monofluorosteroids" by N.F. Taylor and P.W. Kent "Public Health Engineering: The Travel of Pollution Underground" by A.F. Dappert Peters, 1951 (Croonian Lecture - Lethal synthesis) Richards 1931 (Capillary Conduction of Liquids Through Porous Mediums) "On the Incinerability of Highly Flurinated Organic Compounds" W. Tsang, D.R. Burgess Jr. and V. Babushok 3MA00832686 Book Hamilton,1963 (Advances in Fluorine Chemistry - The Organic Fluorochemicals Industry) Simons & Brice, 1954 (Fluorocarbon Chemistry) Simons et al, 1949 (The Electrochemical Proc. for the Prod. of Fluorocarbons) Simons, 1950a (Fluorocarbons and Their Production) SWPCB, 1952 (Report on the Investigation of Leaching of Ash Dumps) SWPCB, 1953 (Field Investigation of Waste Water In Relation to Ground Water Reclamation) SWPCB, 1961 (Effects of Refuse Dumps on Ground water Quality) Taylor, 1965 (Advances in Fluorine Chemestry - Structual Aspects of Monofluoro-Steroids) Correspondence Letter/Summary by/from F. Griffith & J. Long Letter from L. Magill to Document Control Officer Memo from W. McCormick to F. Ubel re Fluorochemical Testing 1980-1981 Memo from S. Sorenson to File re Meeting with Don Hagen, Central Research Letter from L. Magill to Document Control Officer Memo from A. Norberg to L. Krogh re FC Consultant Marshall Johnson Briefing on Teratology Studies 3M_MN02323623 3M_MN02327300 3M_MN02345153 3M_MN02743375 3M_MN02327291 3M_MN02350899 Memo from W. McCormick to D. Ricker re Final Report on R-3116 (Crude C.F. Cof, T-2540CoC) and FM-3452 (POSF 3M_MN02534652 C8F17SO@F, T-2541CoC) In Vitro Letter from W. Weppner to K. Krause 3M_MN01251204 Letter from P. Willard to E. Machuga re Food Additive Petition No. OB4197 3MA00257245 3M Interoffice Memo from H. Bryce to R. Adams re Ecological Aspects of Fluorocarbons - your memo 7/14/71 3MA02496587 3M Interoffice Correspondence from J. Todd to R. Prokop re Photolysis Studies of FC-95, FC-143 and FM-3422 3MA01409604 3M Internal Correspondence from A. Welter to D. Ricker re Product Environmental Assessment Email from G. Garner to V. Batroot Re: Fw: Cottage Grove drinking water - need history Email from D. Graham to T. Baltutis re F-6002 waste water Memo from L. Hoffmeier to R. Libey, J. Webster, & P. Riehle re Treatment of Fluorinated Wastes at Chem.Ctr. Incinerator Memo from G. Hohenstein to Chemolite Center Plant Managers re pH control in the Phase I (inorganic) WWT System Memo from HJVN to meeting attendees re Incinerator Ash and Wastewater Treatment Sludge Disposal 3MA00176780 3M_MN00906201 3M_MN02465688 3MA00067382 3MA00067419 3MA00282200 Letter from M. Ayers to R. Susag Letter from D. Schnobrich to J. Braun re Oakdale Disposal Sites Remedial Action Plan: Contaminated Soils Treatment Submittal 3MA00284881 3MA00285022 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Date of Document May-82 1/14/1953 1949 1950 1964 1950 Mar-47 Feb-49 1954 8/2/1954 11/5/1955 1956 1951 1961 1963 1965 1932 2/28/1952 4/16/1931 12/5/1997 1963 1954 1949 1950 1952 1953 1961 1965 11/19/1980 6/25/1980 2/22/1982 11/19/1980 11/3/1982 8/20/1979 10/8/1999 9/13/1971 1/22/1979 6/22/1979 2/13/2008 5/26/1999 7/13/1984 11/2/1984 3/22/1978 6/5/1980 3/30/1984 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Letter from D. Schnobrich to J. Braun re Oakdale Disposal Sites Remedial Action Plan: February, 1984, Work Summary Letter from R. Susag to M. Ayers Memo from J. McComas to EPCRA Coordinators & Environmental Operations Contacts Letter from T. Fasking to M. Rys re Oakdale Disposal Site Letter from J. M. Osborne to T. Clark re Chemolite Incinerator Ash Out-Of-State Disposal Letter from R. Susag to L. Breimhurst Memo from G. Hohenstein to M. Hill re Chemolite Phase III Sludge Disposal Memo from J. Pilney to M. Santoro re Chemolite - Discovery of New Waste Disposal Site Email from D. Schnobrich to S. Etheir re Results of APE Testing Memo from J. Allison to Multiple Recipients re URGENT NOTICE - James E. St. John, Jr. vs. 3M Company, Morgan County, Alabama Circuit Court Civil Action No. CV-02-408-SWB Memo from P. Book to T. Fasking re Barrel Reconditioning Cottage Grove Letter from D. Schnobrich to J. Braun re Oakdale Disposal Sites Remedial Action Plan: March, 1984, Work Summary Status of the Granular activated Carbon (GAC) Email from D. Schnobrich to T. Ashenmacher re C4 Manufacturing Plan Email from D. Schnobrich to S. Etheir re Effectiveness of Activated Carbon at Cottage Grove Email from D. Schnobrich to T. Galloway Re: CG NPDES question Email from T. Galloway to D. Schnobrich re FC Screen Preliminary Results Email from T. Baltutis to D. Schnobrich re CG NPDES FC - April Report Email from M. Gaetz to R. Paschke RE: cg fc rpt revisions Email from W. Nelson to B. Bachmeier re 3M Waste Timeline - Approximate Email from F. Luden to K. Reed re Fw: Cottage Grove Email from W. Neumann to G. Hohenstein Re: CG Bldg. 75 GAC System Email from G. Hohenstein to T. Galloway Re: CG Station 4 FC Summary Email from G. Hohenstein to G. Garner Re: Fw: website Email from D. Krueger to G. Hohenstein Re: FC's at 3M Cottage Grove Email from M. Gaetz to G. Hohenstein & R. Paschke re Cottage Grove Sludge Email from G. Garner to F. Luden re Fluorinated Wastes Email from D. Schnobrich to E. Reiner Re: Incineration of Perfluorochemicals Email from D. Schnobrich to S. Ethier Re: Waste Treatment FC Analysis Email from D. Schnobrich to S. Ethier re FC-95 Process Definition Email from D. Schnobrich to T. Galloway Re: next cg fc question Email from D. Schnobrich to D. Krueger Re: mid-year CG FC review Email from T. Brooks to T. Ashemacher Re: Activated Carbon Disposal Email from T. Flicker to G. Hohenstein Re: CF Bldg. 75 GAC system Memo from D. Comeau & P. Book to T. Fasking re Cottage Grove Catio nion Analyses Summary Letter from D. Anderson to D. Comeau re Lab Project Number: 1077316 Email from S. Ethier to R. Paschke, G. Hohenstein, & K. Reed re Fw: MPR Comment from Website Memo from G. Hohenstein to B. Bracht & G. Weum re Incineration of Chlorinated, Fluorinated, and Corrosive Materials at the Chemolite Incinerator Memo from R. Susag to R. Svanda re 3M Chmolite Plant NPDES Permit Letter from B. Brott to J.M.Osborne re Interim Storage of 3M Chemolite Waste Letter from T. Nunno to J. M. Osborne re Request for Additional Information on 3M Process Operations 3MA00285042 3MA00325986 3MA00328955 3MA00348164 3MA00456698 3MA00456743 3MA00456787 3MA00456822 3MA00471586 3MA00479320 3MA00606880 3MA00611644 3MA00617291 3MA00827155 3MA00827375 3MA00827778 3MA00827783 3MA00827891 3MA00845425 3MA00846332 3MA00847418 3MA00864929 3MA00864994 3MA00864995 3MA00866425 3MA00866656 3MA00886769 3MA00915146 3MA00915884 3MA00915944 3MA00917579 3MA00919094 3MA00921154 3MA00923323 3MA00948041 3MA00948045 3MA01242570 3MA01542140 3MA01934191 3MA01934299 3MA01936472 Letter from R. Susag to L. Breimhurst Letter from A. Thomas to J. Pilney Letter to J. Pileny of Weston Memo from J. Gagnon to D. Schnobrich re Oakdale Incinerator Ash Oil & Grease Extracts Memo re FC Investigation Memo re Algal Bioassays Memo re Product Environmental Assessment Envir. Assess. Inq. #81439 Letter from Dohrmann Division (Xertex) to Wade Scheil Inq. 84048 Inq. 84049 Inq. 84050 Inq. 84047 Memo re Biodegradability of Fluorochemicals 3M Internal Correspondence re Fate of fluorochemicals project Letter re Environmental Concerns of Air Force Fire TRaining Facilities Memo from M. Elnabarawy re Chemolite Center Environmental Monitoring Study (EMS) Memo from C. Olson re Meeting Notice Memo from R. Howell to C. Burton re Environmental Concerns with Fluorochemicals Memo from J. Mandel to C. Burton re Medical Department projects for assessing human health effects (DRAFT) 3M-BARR00017068 WE10268751 WE10268951 3MA00300324 3MA00057517 3MA00248138 3MA10078364 3MA01409737 3MA10082799 3MA10082807 3MA10058791 3MA10082793 3M_MN01429707 3M_MN01429711 3M_MN01315488 3MA00281846 3MA00751848 3MA00323897 3MA00323895 Letter from P. McKee Pesik to A. Costello Letter from P. McKee Pesik to A. Costello Letter from S. Leahy to Document Processing Center re TSCA 8(E) Substantial Risk Notice on: Lithium Perfluorooctane Sulfonate CAS #29457-72-5 Confidential Memo from C. Burton re Fluorochemical Technical Advisory Committee Meeting - 11/12/92 3MA10064529 3MA01405447 3MA10063562 3M_MN00047274 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 3/15/1984 7/11/1980 3/26/2001 7/26/2004 4/2/1979 5/29/1981 4/21/1982 12/20/1982 1/31/2002 10/9/2002 5/24/2004 4/10/1984 10/16/2001 3/20/2002 11/20/2002 12/26/2002 5/7/2003 7/22/2003 1/26/2005 8/29/2005 4/4/2005 4/6/2005 4/6/2005 7/18/2005 8/4/2005 1/14/2005 4/25/2001 8/28/2001 9/20/2001 11/21/2002 7/9/2003 9/27/2004 4/5/2005 3/21/2006 9/10/2003 2/23/2005 7/16/1984 11/16/1976 5/2/1978 10/12/1983 5/21/1982 5/20/1983 7/28/1981 6/27/1984 12/15/1981 1/6/1982 1/6/1982 6/29/1982 8/10/1984 8/10/1984 8/10/1984 8/17/1984 5/22/1989 3/8/1991 6/6/1991 2/26/1992 6/1/1992 9/15/1992 11/9/1992 11/12/1992 11/30/1992 12/1/1992 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Memo from J. Marhevka to Attached List re FTAC-What Needs to be Done Letter from G. Adams to Document Processing Center re TSCA 8(E) Substantial Risk Notice on: Lithium Perfluorooctane Sulfonate CAS #29457-72-5 Supplement Letter from 3M to J. Gillett Letter from R. Howell to J. Gillett Memo from C. Burton re Fluorochemical Technical Advisory Committee Meeting - 2/16/93 Memo from S. Gordon to C. Burton re FC-10 Health Hazard Summary Memo from S. Gordon to C. Burton re Revised FX-12 Health Hazard Summary Memo from C. Burton re Meeting Minutes - Fluorochemical Technical Advisory Committee - 9/9/93 Memo from C. Burton re Meeting Minutes - Fluorochemical Technical Advisory Committee - 2/22/94 3MA00638311 3MA10061964 3MA01453009 3MA10073673 3MA00244742 3MA00621678 3MA10016783 3MA10016191 3MA01329221 Memo from C. Burton re Meeting Minutes - Fluorochemical Technical Advisory Committee - 4/18/94 3MA00323864 Memo from S. Gordont o C. Burton re Health Hazard Summary of FC-810, FX-845 and Related Materials 3MA10036988 Memo from S. Gordon to C. Burton re Health Hazard Summary of FC-120 3MA10065317 Memo from C. Burton re Meeting Minutes - Fluorochemical Technical Advisory Committee - 6/27/94 - FC-95 3MA01329219 Review Memo from C. Burton re Meeting Minutes - Fluorochemical Technical Advisory Committee - 7/12/94 - FC-120, FC- 3MA00323833 810, FX-845 Reviews Letter from J. Giesy to R. Howell 3MA10056607 Attachments to Letter to C. Auer dated May 25, 2000 Toxicology Studies and Other Information on PFOA 3MA00345264 Memo from J. Jensen to Recipients of the 1990 Guide of Records Retention re Guide to Records Retention 3MA00474147 Memo from J. Jensen to Recipients of the 1991 Guide of Records Retention re Guide to Records Retention 3MA00474224 Memo from J. Jensen to Recipients of the 1992 Guide of Records Retention re Guide to Records Retention 3MA00474297 Memo from J. Jensen to Recipients of the 1993 Guide of Records Retention re Guide to Records Retention 3MA00474375 Memo from J. Jensen to Recipients of the 1994 Guide of Records Retention re Guide to Records Retention 3MA00474456 Email from D. Schnobrich to L. Zabel re Cordova FC Waste Management Review Exhibit 186 - Email from M. Gravdahl to D. Schnobrich Re: PFOA Production Exhibit 189 - Memo from T. Shannon to D. Dworak re Chemolite HF Tar Disposal -- Final Report Exhibit 193 - Memo from W. Myers to G. Hohenstein re Building 15 Acid Drops to Sewer 8/27/1984 - 9/6/1984 3MA00000982 3MA00044477 3MA01201767 3MA00067163 Exhibit 195 Memo from J. Eberlin to J. Krall re Recovery of Perfluorooctanoic Acid (FC-26) Bottoms (FZ-155) 3MA00082742 Exhibit 196 - Memo re Meeting Minutes re Processing of Fluorochemical Salts 3MA00967725 Exhibit 197 - Memo from J. Krall re Status of FC-26 via POSF/I2 3MA00080881 Exhibit 200 - Memo from R. Johnson to R. Ahlness & C. Hanson re No Subject 3MA10035104 Exhibit 201 - 3M Interoffice Correspondence re Meeting Minutes from R. Prokop 3MA00967681 Exhibit 202 - Email from D. Dworak to L. Zabel Re: C-8 Acid Scotch Guard, etc. 3MA00184620 Exhibit 203 - Memo from L. Zabel to J. Gregory re: Testing issues Cottage Grove 3MA00241504 Exhibit 204 - Email from P. Logan to J. Mulhausen, S. Kruse & L. Zabel re Union/Mgmt meeting concerning Bldg 15 3MA00198032 (C8 acid) Memo re Meeting Minutes June 1976 3M_MN00055527 Memo re Meeting Minutes - Fluorochemicals Technical Review Committee 3M_MN00055530 Memo from L. Krogh re No Subject 3M_MN00055534 Memo from R. Bohon to J. Lazerte re Fate of Fluorochemicals Phase II 3M_MN00055558 Memo from R. Howell to C. Olson re Fluorochemicals in the Environment 3M_MN00055574 Email from R. Renner to J. Mandel re Cottage Grove Water Visuals 3M_MN00055780 Email from M. Santoro to K. Reed re Meeting with MPCA Commissioner 3M_MN00055813 Memo from S. Corrigan re Notes from the April 17 Meeting on Land Use Planning for the Former Woodbury 3M_MN00055814 Landfill Site Email from G. Olsen to J. Mandel re Re: Discussion 3M_MN00055852 Email from M. Santoro 3M_MN00055853 Memo from T. Baltutis to J. Webster re Surfactants in Wastewater 3M_MN00055857 Written letter to Bill 3M_MN00055858 Email from D. Sanders re Meeting Minutes - FC Initiative Core Team - March 1, 2002 3M_MN00055859 Letter from R. Bilott to M. Santoro & L. Zobel 3M_MN00055869 Memo from R. Alsup to R. Anderson re Disposal of Solid "Teflon" Wastes Containing C-8 APFC AR226-1444 Memo from J. Higginbothaim to B. Herbert & More re "Teflon" Scrap AR226-1445 Memo from A. Playtis to C. Alt and more re C8 at Dry Run AR226-1475 Email from B. Reilly re May AR226-1477 Memo from J. Brown to H. Wessel re Proposed Dump Site 3MA00335961 3M Internal Memo from D. Siddoway, R. Rosen & B. Fong re attached report summary 3MA01201774 Letter from 3M to EPA re Section 8( e ) Toxic Substances Control Act (TSCA) Perfluoralkane Carboxylic Acids and 3MA01934985 Corresponding Ammonium Carboxylates Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 12/15/1992 12/29/1992 1/26/1993 2/2/1993 2/17/1993 7/13/1993 8/6/1993 9/20/1993 3/12/1994 4/19/1994 5/26/1994 6/7/1994 6/28/1994 7/18/1994 3/20/1995 5/25/2000 Jan-90 Jan-91 Jan-92 Jan-93 Jan-94 11/9/2001 5/7/2003 11/18/1976 9/11/1984 9/4/1981 7/12/1978 4/22/1976 7/1/1977 9/22/1977 6/7/2000 1/17/2000 6/19/2000 6/22/1976 4/12/1978 10/19/1977 5/25/1983 2/5/1992 3/19/2002 3/3/2004 4/21/1997 1/10/2000 11/23/2005 6/3/1996 3/13/2002 9/7/2001 8/31/1966 10/28/1966 4/12/1990 5/7/2001 7/13/1960 7/8/1974 3/20/1981 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 3M Internal Memo from R. Howell to C. Olson re Fluorochemicals in the Environment Letter from 3M to EPA re Section 8 ( e ) Toxic Substances Control Act Potassium Salt of Perfluoralkyl Sulfonates 3MA10065446 3M_MN01254205 Letter from J. Osborne (3M) to J. Hansmeyer (MPCA) re requested data for the boiler ash iron oxide sludge at Chemolite Letter from H. Noordwyk (3M) to C. Perket re Incinerator Ash and Waste Water Treatment Sludge Analyses 3MA00276835 3MA00296672 Request for Information Pursuant to Section 104(e) of CERCLA for the 3M Company in Cottage Grove, Minnesota 3MA00277303 Letter to Michael Ayers, MPCA, re: Disposal of 3M Waste Materials at Oakdale, Minnesota Letter to Russell Susag, 3M, re: Request for 3M Participation in Hydrogeologic Study at Oakdale, Minnesota 3MA00284486 3MA00284871 Proposed Outline for Hydrogeologic Study at Oakdale, Minnesota Letter to Michael Ayers, MPCA, re: Oakdale discussion on 11/05/80 Letter sent to Russell Susag, 3M, re: Land Owner Request for Surface and Ground Water Monitoring Program 3MA00284872 3MA00284875 3MA00284876 Letter to Ruth Mancos, USPCA, re: Correspondence on Accidental Release at Cottage Grove 10/25/91 3MA00294048 Letter to 3M re: Request for Information Concerning Release to Environment 12/10/92 Letter to Michael Ayers, MPCA, from Oakdale Active Citizens Group re: Public Meeting Letter to Russell Susag, 3M, re: Complaint Concerning the Chemolite Dump Site Letter to Shawn Ruotsinoja, MPCA, re: Comments to Washington County Landfill - MPCA Proposed Remedy 3MA00294059 3MA00610626 3MA01094939 3MA02655957 E-mail of notice for Fluorochemical Steering Committee meeting 12/15/97 and agenda Minutes of Fluorochemical Steering Committee Meeting of December 15, 1997 Memo to DL Bacon, 3M re: Approach to Development of Documents on Fluorochemical Findings Internal Correspondence re: December 10th Federal Government Affairs Planning Session with attachment 3MA00001846 3MA02607004 3MA01452321 3MA02512422 Email Correspondence re: Environmental Testing For PBSF (C4F9S02F) and Derivatives - Redacted Email to Bill Weppner, 3M, re: Phaseout of PFOS Email to Bill Weppner, 3M, re: Phaseout of PFOS Email Correspondence re: EPA says it pushed 3M over Scotchgard risk Email to Maruoka Kuniaki, 3M, re: Guidance for your meeting with MHW and MITI Thursday Email Correspondence to 3M Specialty Materials Group re: Businessweek Article Internal Correspondence re: Question & Answers from 5/16 & 5/18 Plant Meetings Email Correspondence to Shawn Kruse and Tim Johnson re: PFOA Management Options Email Correspondence re: PreNotice Meeting C4 Surfactants Announcement - Phase out of 3M products - Decatur Plant Letter to Charles Auer, EPA, re: Phase-out Plan for POSF-Based Products Science Advisory Panel (SAP) Meeting Minutes, Washington, DC, June 21, 2000 Internal Correspondence re: Meeting Minutes - FC Initiative Core Team Meeting - June 26, 2000 Internal Correspondence re: SMMD Bi-Weekly Manager's Meeting Minutes for August 4, 2000 Letter to Jesse Baskerville, EPA, re: 3M Company TSCA Section 8(e) Compliance Audit - (04/11/00) Memo to Karen Lannon, EPA re: Domestic Manufacturers or Importers of PFOS Chemicals Other than 3M 3MA01212211 3MA00660232 3MA00748534 3MA01623168 3MA00231908 3MA01166197 3MA01623195 3MA00198086 3MA00728130 3MA01629628 3M_MN01101973 3MA10084718 3MA01405013 3MA01146584 3MA00847675 3MA00847666 Internal Correspondence re: Meeting Minutes - FC Initiative Core Team Meeting - 08/31/00 Email Correspondence to Teresa Borzcik, 3M, re: PPE for new C-4 NSF intermediates/products Email Correspondence to Charles Auer, EPA, re: Production of PFOS Derivatives Email Correspondence re: Scotchgard Update - STP Pioneer Press Email Correspondence to Jeffrey Rageth, 3M, re: 3M Story Email Correspondence to Patrick Thornton, 3M, re: FC Phase-Out Email Correspondence to Bill Nelson, 3M, re: FC Phase-Out Email Correspondence to Tracy Baysinger, 3M, re: FC Phase-Out Email Correspondence to Tracy Baysinger, 3M, re: FC Phase-Out Email Correspondence to Bill Nelson, 3M, re: Lake Elmo Well Results Comments Memo to Douglas Day, MPCA, re: Revised Selection of Remedy for Upgrade of the Ground Water Treatment System at the Washington County Landfill Email Correspondence to Kurt Werner, 3M, re: USEPA PFOA Stewardship Initiative Email Correspondence to Howard Bergman et. al., 3M, re 3M Cottage Grove Fish Data - News Email Correspondence re: Question following presentation on 3M PFC facts Letter to Minnesota Department of Health re: ATSDR Public Health Assessment - Lake Elmo and Oakdale, Washington County. MN Letter to Gary Hohenstein, 3M, re: 3M Grant to MPCA for Implementing Remedial Actions at the Washington County Landfill Related to Perfluorochemicals, Settlement Agreement and Consent Order Dated May 22, 2007 3MA00470649 3MA00730723 3M_MN01022848 3MA01196565 3MA00496145 3MA01152146 3MA01152147 3MA01152149 3MA01152153 3MA02608880 STATE_02832319 3MA00872619 3MA01250192 3M_MN00567710 3M_MN00049463 3MA02647222 Letter to Kirk Mills, 3M, re: MPCA Comments to Review of Groundwater Quality Data, 3M Chemolite Plant, Cottage Grove, MN Letter to Russell Susag, 3M, re: Request for Information on 3M Waste Disposal Practices at Chemolite Site 3M_MN00000797 3M_MN00048827 Letter to Louis Breimhurst, MPCA, re: Information on Alleged Disposal of Industrial Wastes at the 3M Chemolite 3M_MN00048829 Plant in Cottage Grove, MN Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 2/5/1992 11/19/1980 4/27/1978 8/19/1977 3/15/1993 7/11/1980 11/14/1980 11/10/1980 11/6/1980 9/26/1980 4/16/1993 3/1/1993 11/20/1980 5/12/1981 3/14/2008 12/8/1997 1/9/1998 6/15/1998 12/4/1998 5/5/1999 5/16/2000 5/16/2000 5/23/2000 5/24/2000 5/26/2000 6/20/2000 6/28/2000 6/28/2000 7/5/2000 7/7/2000 7/17/2000 7/19/2000 8/4/2000 8/21/2000 8/31/2000 9/13/2000 12/14/2000 3/2/2001 5/28/2003 11/1/2004 12/14/2004 12/14/2004 12/14/2004 12/15/2004 3/29/2005 12/13/2005 2/1/2006 3/13/2006 1/9/2008 5/21/2008 6/25/2008 5/30/1995 5/4/1981 5/29/1981 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Letter to Jack Braun, EPA, re: Amendment to Oakdale Remedial Action Plan Submittal Internal Correspondence re: F1uorochemical Steerinq Cmte Mtg Minutes 11/08/93 Email Correspondence to Vickie Batroot, 3M re: Analytical Results of Disposal Areas and Cove Letter to Randy Minobe, 3M, re: Pollution Liability Insurance Coverage for Oakdale Site Letter to Mary Fortado, AIG, re: Insurance Coverage for Claims Related to Oakdale Site - Redacted Letter to Scott Stevenson, 3M, re: Insurance Coverage Related to Oakdale Site - Redacted Email Correspondence to Dana Schnobrich et. al., 3M, re: FC Waste Initiative Email Correspondence to Lynn Runnings, 3M, re: FC Waste Profile Review Meeting Minutes Email Correspondence to Brad Fong, et al., re: Drying Team Meeting Minutes Internal Correspondence to Bob Paschke, 3M, re: Woodbury Site Update Internal Correspondence to D.W. Johnson, 3M, re: Landfill Dry Scrap Project Letter to David Champion, Wash. Cnty. Admin., re: Routine Investigation of Washington County Landfill 3M_MN00049037 3M_MN00055864 3M _MN00996241 3M_MN01313140 3M_MN01313152 3M_MN01313348 3MA00000974 3MA00000978 3MA00056860 3MA00264370 3MA00276827 3MA00276884 Office Memo: 3M Chemolite File re: Review of Remedial Investigation to Evaluate individual Waste Disposal Sites 3MA00279473 Interoffice Correspondence to R.O. Laine, 3M, re: Permit to Landfill Chemolite Sludge 3MA00280233 Internal Correspondence, 3M, re: Meeting with MPCA And Phoenix, Inc. Relative To Disposal of Chemolite Sludge 3MA00280406 at the Pine Bend Landfill Letter to James Hansmeyer, MPCA, re: Disposal of Wastewater Sludge and Incinerator Ash on the Chemolite Plant 3MA00280988 Site Letter to Russell Susag, 3M, re: Request for Information on 3M Waste Disposal Practices at Chemolite Site 3MA00282605 Letter to Jack Braun, EPA, re: Oakdale Disposal Sites Remedial Action Plan: June, 1984, Work Summary 3MA00284932 Letter to Jarle Leirfallom, Commissioner of Conservation, re: Application for Permit to Appropriate Water from 3M Property in Woodbury Village, Minnesota Letter to Jack Braun, EPA, re: Oakdale Disposal Sites Remedial Action Plan: August, 1984, Work Summary 3MA00286355 3MA00611787 Interoffice Correspondence to J.A. Brown, 3M, re: Methods of Improving Waste Disposal Operations at the Woodbury Township Dump Site Interoffice Correspondence to J.A. Brown, 3M, re: Inspection Report of Woodbury Township Dump Site 3MA00335827 3MA00335828 Interoffice Correspondence to J.A. Brown, 3M, re: Crop Effects Due to Acid Waste Fumes at Woodbury Township 3MA00335831 Dump Site Interoffice Correspondence to J.A. Brown, 3M, re: 07/09/63 Inspection of Woodbury Township Dump Site 3MA00335832 Interoffice Correspondence to Geology Dept., 3M, re: Pond Sealant Study Interoffice Correspondence to D.H. Cochran re: Waste Disposal Problem at Woodbury Dump Site Correspondence to Hans Wessel, 3M, re: Results of Dump Site Test Borings and Recommendations Memo to R.C. Johnson, 3M, re: Daily Discharge to Chemical Sewer Interoffice Memo to C.W. Bentz, 3M, re: Input to Chemical Sewer Internal Chemical Operations Interoffice Correspondence to H. Parkinson, 3M, re: Disposal of Sludge from Existing Waste Pond - Phase 1 Chemolite Waste Disposal Program Memorandum re: Chemical Waste Disposal Facilities Interoffice Correspondence to D.R. Guthrie, 3M, re: Proceed to Construct Phase II - Waste Water Treatment Facilities at Chemolite Interoffice Correspondence to D.E. Peterson, 3M, re: Pond Sludge Cleaning Chemolite Interoffice Correspondence to Chemolite Sludge File re: Chemolite Landfill Meeting Minutes and Status Report 3MA00335853 3MA00335855 3MA00335938 3MA00456289 3MA00456322 3MA00456347 3MA00456352 3MA00456431 3MA00456546 3MA00456626 Letter to Paul Brandt, Wash. Cnty, re: Chemolite Sludge Disposal Letter to Paul Smith, Metropolitan Council, re: Chemolite Sludge Disposal Letter to Michael Ayers, MPCA, re: Response to Information Request on Past 3M Chemolite Disposal Sites 3MA00456710 3MA00456730 3MA00456747 Letter to Fred Robinette, 3M, re: NOV at the Chemolite Boiler Ash Disposal Area Internal Correspondence to L.H. Hoffmeier, 3M, re: Chemolite Boiler Ash Landfill Email Correspondence to Fred Palensky, 3M, re: Lake Elmo Backgrounder Letter to Aaron Moran, EPA, re: Oakdale Disposal Sites Remedial Action Plan: November-December, 1984, Work Summary Email Correspondence to Jerry Walker, 3M, re: Cottage Grove FC Wastes Internal Correspondence to D.E. Pederson, 3M, re: Chemolite Wastewater Sludge Letter to Robert Lockyear, Wash. Cnty., re: Amendment of Waste Disposed Letter to Louis Breimhurst, MPCA, re: Status Report on 3M Program to Develop a Long-Range Plan for Chemolite Waste Disposal Email Correspondence to Gary Kruger, MPCA, re: 3M waste disposal activities at the Commercial Chemical Company/ Pollution Controls, Inc. sites Interoffice Correspondence to T.E. Shannon, 3M, re: Cell Tar Disposal Letter to Paul Brandt, Wash. Cnty., re: Notification of Phase I Sludge to Pine Bend and Phase III Sludge to Chem Waste Mgmt Milwaukee Interoffice Correspondence to H.G. Bryce, 3M, re: Comments on "The Ecological Aspects of Fluorocarbons" 3MA00456827 3MA00456910 3MA00550094 3MA00611843 3MA00616209 3MA00722190 3MA00722959 3MA00722981 3MA00866215 3MA01201771 3MA01934698 3MA02496585 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 1/30/1984 11/17/1993 12/3/2008 3/15/2006 5/8/2007 6/5/2007 10/11/2001 10/20/2001 8/16/1999 12/16/1992 4/24/1974 3/20/1974 3/13/1995 9/27/1974 10/24/1979 9/14/1978 5/4/1981 7/26/1984 6/26/1967 9/26/1984 7/30/1963 7/26/1963 7/10/1963 7/10/1963 5/15/1962 5/14/1962 7/26/1960 9/13/1960 9/26/1960 8/17/1962 11/21/1962 8/16/1966 5/25/1973 5/8/1978 2/19/1980 7/28/1980 7/28/1981 3/15/1983 7/17/1984 8/10/2005 1/25/1985 10/5/2001 5/22/1979 9/2/1983 2/7/1979 6/22/2005 5/12/1976 1/3/1980 8/31/1971 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Letter to Jack Braun re: Oakdale Disposal Sites Remedial Action Plan: Land Incorporation of Soils Decontaminated 3M-BARR00015110 in the Chemolite Incinerator Letter from to Harvey Rogers, Minnesota State Board of Health 3M_MN00000713 Correspondence with Mr. Johannes, State Water Pollution Control Board, re: Discussion of Chemolite wastes 3M_MN00000414 Interoffice Correspondence to C.B. Sampair, 3M, re: Status report, St. Paul, Chemolite and Hutchinson waste 3M_MN00000715 disposal. Interoffice Correspondence to J. A. Brown, re: Possible Improvements to Woodbury Township Site 3M_MN00000142 Interoffice Correspondence to J. A. Brown, re: Possible Improvements to Woodbury Township Site 3M_MN00000718 Letter to Robert LaBrosse, Cottage Grove Township, re: Notification of Intent to Install and Operate a Waste 3M_MN00001428 Disposal Facility at Chemolite Plant Interoffice Correspondence to J.A. Brown, 3M, re: Request for Temporary Approval of Wet Scrap Dumping Permit 3M_MN00001429 at Woodbury Dump Site Interoffice Correspondence re: Water Pollution Control, State of Minn. Notice to Discontinue Acid Disposal at 3M_MN00000727 Woodbury Letter to Harold Jones, Woodbury, re: Temporary Use of Woodbury Site 3M_MN00001431 Letter to John Pilney, 3M, re: Response Actions at the Chemolite Site 3M_MN00000277 Interoffice Correspondence to All 3M Lab Personnel, re: Disposal of Waste Solvents Down the Sinks 3M_MN00001432 Letter to Lyle Smith, MDOH, re: Disposal of Liquid Wastes 3M_MN00001433 Interoffice Correspondence to H.S. Parkinson, 3M, re: Well water Pollution-Woodbury Township Dump Site Area 3M_MN00000164 Interoffice Correspondence to H.S. Parkinson, 3M, re: Well water Pollution-Woodbury Township Dump Site Area 3M_MN00001435 Interoffice Correspondence to H.S. Parkinson, 3M, re: Well Water Problem at Woodbury Dump Site Letter to O.M. Bielenberg, Chairman, Woodbury Township Board, re: Testing of Water Samples and Cessation of Dumping Interoffice Correspondence re: Meeting with State Health Dept. Officials on Woodbury Well Water Problem 3M_MN00001437 3M_MN00001438 3M_MN00001439 Interoffice Correspondence re: Woodbury Township Meeting to Discuss Well Water Problem Interoffice Correspondence to D.R Guthrie, 3M, re: Residence Well Water Sampling in Woodbury Township and Cottage Grove Village Letter to O.M. Bielenberg, Chairman Woodbury Township, re: Well Water Problem in Woodbury Township 3M_MN00001441 3M_MN00000728 3M_MN00001445 Letter from to Lyle Smith, MDOH, re: Progress on Well Water Problem in Woodbury Township Interoffice Correspondence to H.J, Wessel, 3M, re: Comparison of Stratigraphic Columns at the Abresch Dump Site and 3M Woodbury Disposal Area Letter from to Lyle Smith. MDOH, re: Progress Report - Well Water Problem in Woodbury Township 3M_MN00001447 3M_MN00001450 3M_MN00001451 Interoffice Correspondence to W.W. Watson, 3M, re: Wet and Dry Scrap Disposal at 3M Plants Letter to J T. Ling, 3M, re: Approval to Discharge Water to Mississippi River with Attached Permit Interoffice Correspondence re: Meeting Minutes Open Field Burning for Wet Scrap Accumulation at Woodbury 3M_MN00000383 3M_MN00001455 3M_MN00000731 Interoffice Correspondence re: Open Cell Burning at 3M Disposal Site in Woodbury Village Memorandum to C.E. Kiester, 3M, re: Woodbury Questions with attached List of Possible Questions 3M_MN00001460 3M_MN00000469 Letter to Harold Kernkamp, Mayor, Village of Cottage Grove re: Request for Approval, Open Cell Burning at 3M Disposal Site in Woodbury Village Letter to Orville Bielenberg, Mayor, Village of Woodbury re: Request for Approval, Open Cell Burning at 3M Disposal Site in Woodbury Village Letter to C.E. Kiester, 3M, re: Pumping Test on Woodbury Well No. 1 and Conclusions Letter to John Badalich, MPCA, re: Open Cell Burning at 3M Disposal Site in Woodbury Village Letter to 0. Bielenberg, Mayor, Woodbury Village re: Open Cell Burning at 3M Disposal Site in Woodbury Village with attached Report Interoffice Correspondence to D.R. Guthrie, 3M, re: Progress Report on Groundwater Problem at Woodbury Site 3M_MN00001461 3M_MN00001464 3M_MN00001467 3M_MN00001475 3M_MN00001476 3M_MN00001484 Interoffice Correspondence to D.R. Guthrie, 3M, re: Progress Report No. 2 on Groundwater Problem at Woodbury 3M_MN00000735 Site Letter to R.D. Miller, MPCA re: Effluent Quality from 3M Chemolite Treatment Plant 3M_MN00001501 Interoffice Correspondence to H.G. Bryce, 3M, re: Comments on "The Ecological Aspects of Fluorocarbons" 3M_MN00000145 Interoffice Correspondence to R.M. Adams, 3M, re: "Ecological Aspects of Fluorocarbons- -your memo 7/14/71" 3M_MN00000147 Letter to C.E. Kiester, 3M, re: Sludge from the 3M Incinerator Plant Residue Interoffice Correspondence to D.E. Pederson, 3M, re: Disposal of Dewatered Sludge, 3M Chemolite Letter to David Champion, Wash. Cnty. Admin., re: Routine Investigation of Washington County Landfill 3M_MN00001520 3M_MN00001521 3M_MN00000327 Interoffice Correspondence to L.C. Krogh, 3M, re: Record of Telephone Conversation with William Guy, UF Fluorocarbons in Human Blood Plasma Interoffice Correspondence to J D. La Zerte, 3M, re: Fluorocarbons in Human Blood Plasma Letter to Richard Svanda, MPCA, re: 3M Chemolite Plant NPDES Permit 3M_MN00000293 3M_MN00000741 3M_MN00000742 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 10/8/1984 6/12/1958 8/26/1958 6/19/1961 7/30/1963 7/30/1963 11/26/1963 12/5/1963 1/6/1964 1/7/1964 2/6/1964 3/2/1964 3/30/1964 5/5/1966 5/5/1966 6/1/1966 7/22/1966 8/11/1966 8/23/1966 10/18/1966 12/20/1966 12/22/1966 1/3/1967 2/2/1967 3/3/1967 4/17/1967 11/30/1967 1/9/1968 1/11/1968 1/11/1968 1/11/1968 1/25/1968 1/31/1968 1/31/1968 5/2/1969 11/7/1969 8/12/1970 8/31/1971 9/13/1971 10/1/1971 10/5/1971 3/20/1974 8/20/1975 9/23/1975 11/16/1976 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Interoffice Correspondence re: Report to Corporate Responsibility Committee on Progress - Fluorochemicals in 3M_MN00000744 Blood Internal Correspondence to F A. Ubel, 3M, re: Serum Sample Results - Trace Fluorochemicals 3M_MN00000296 Interoffice Correspondence re: Chemolite Landfill Meeting Minutes and Status Report 3M_MN00000354 Interoffice Correspondence, Memo to File, re: Visit to duPont Haskell Laboratories and Present 3M's Findings with 3M_MN00000477 Respect to Levels of Fluorochemicals in the Blood of Personnel Letter to Jeff Harthum, MPCA, re: Response to Request for Information related to Disposal of Wastes in Oakdale, 3M_MN00000353 Minn. Internal Correspondence, 3M, re: Meeting Minutes from 07/20/79 meeting with DuPont in Chicago on 3M_MN00000290 Fluorochemical Exposure on Employees Letter to Arthur Potthoff, OCAW Union, re: 3M Medical Department Programs for Production and Maintenance 3M_MN00001525 Workers MPCA Office Memorandum re: Meeting with 3M Representatives Concerning the Oakdale Dump 3M_MN00000348 Interoffice Correspondence to F.A. Udel, 3M, re: OSHA Inspection of Chemolite 03/20/80 3M_MN00001526 Interoffice Correspondence to F.A. Udel, 3M, re: OSHA Inspection of Chemolite 04/03/80 3M_MN00001528 Memorandum to Steve Mackay, OSHA Investigation of Chemolite Plant 3M_MN00001530 Internal Correspondence to R. L. Ahlness, 3M, re: OSHA Closing Conference 05/16/80 3M_MN00001531 Letter to Russell Susag, 3M, re: Request for Disposal Information from 3M at Oakdale Site 3M_MN000000351 Internal Correspondence to John Verstraete, 3M, re: Disposal Information by 3M at Oakdale Site 3M_MN00000474 Letter to Russell Susag, 3M re: Transmittal of Draft Report for 3M Woodbury Disposal Pits 3M_MN00000758 Phone Conversation notes with Paul Hoff, MPCA, re: Release of Information to News Media 3M_MN00000333 Letter to EPA re: Section 8(e) Toxic Substances Control Act - Potassium Salt of Perfluoroalkyl Sulfonates 3M_MN00001533 Letter to Terry Hoffman, MPCA, re: Selection of Barr Engineering for Geohydrological Study at Oakdale Site 3M_MN00001536 Letter to Russell Susag, 3M, re: Confirmation of Barr Engineering for the Geohydrological Study at Oakdale Site 3M_MN00001538 Internal Correspondence to R.A. Paschke, 3M, re: Release of Barr Engineering Draft Work Plan to Newspapers and 3M_MN00000782 Oakdale Active Citizens Organization Letter to T. Sherkenbach re: Notice of Future Report on 3M Composition of Wastes Disposed at the Oakdale Site. 3M_MN00000350 Internal Correspondence to J.D. LaZerte, 3M, re: Meeting Minutes with DuPont in Chicago 01/16/81 concerning 3M_MN00000288 Toxicology Information - Redacted Single Page - Letter to EPA re: Section 8(e) Toxic Control Substances Act - Perfluoroalkane Carboxylic Acids and 3M_MN00000783 Corresponding Ammonium Carboxylates Letter to Russell Susag, 3M, re: Information Request Concerning Alleged Disposal Site at Chemolite Plant Along 3M_MN00001539 the Mississippi River Letter to Louis Breimhurst, MPCA, re: Response to Request for Information on Waste Disposal at Chemolite Plant 3M_MN00001542 from 1950 to 1955 Letter to Michael Ayers, MPCA, re: Water Well Locations, Groundwater Hydrology, and Well Construction at the 3M_MN00001544 Chemolite Plant Internal Correspondence to J.J. Verstraete, 3M, re: Meeting on 10/01/81 concerning 3M Future Policy on Oakdale 3M_MN00000343 Disposal Site Problem Internal Correspondence, 3M, re: Oakdale Newspaper Clippings/Sound Clips 3M_MN00000376 Letter to Michael Ayers, MPCA, re: Work Plan - Hydrogeological Investigation of Disposal Areas at the 3M 3M_MN00001563 Chemolite Plant Internal Correspondence to R.A. Paschke, 3M, re: Oakdale Industrial Waste Sites: A Selected Chronology of Events 3M_MN00000207 Letter to R. Rakshpal, EPA, re: Rat Fetus Eye Lens Change Not Due to Fluorochemicals Letter to Michael Ayers, MPCA, re: 3M Chemolite Hydrogeologic Investigation Letter to R.A. Paschke, 3M, re: Request for Plan for Further Study and Remedial Action at Oakdale Disposal Sites 3M_MN00001570 3M_MN00001572 3M_MN00001610 Letter to Louis Breimhurst, MPCA, re: 3M Agreement to Fund Additional Study 3M_MN00001613 Letter to Russell Susag, 3M, re: MPCA Confirmation of Additional Study with Addendum at Oakdale Disposal Sites 3M_MN00001616 Letter to Gary Paulson, resident Lake Elmo, re: Analytical Testing of Water Samples 3M_MN00001618 Letter to Franklin Griffith, 3M, re: Review of Developmental Toxicology Safety Evaluation Studies of FC143 in Rats 3M_MN00001622 Internal Correspondence to L.W. Lehr, 3M, re: Response to Request for Status Report on Oakdale Dump Situation 3M_MN00000345 Letter to Russell Susag, 3M, re: Draft Consent Order and Stipulation Agreement for Oakdale Disposal Sites 3M_MN00001624 Letter to Gary Paulson, resident Lake Elmo, re: Proposed Market Value Reduction for Homes in Landfill Area 3M_MN00000508 Letter to Michael Ayers, MPCA, re: 3M Chemolite Hydrogeological Investigation Letter to Robert Lockyear, Washington Cnty Planning Dept., re: Disposal of Dry Scrap from 3M Facilities 3M_MN00001631 3M_MN00000329 Letter to J. Michael Osborne, 3M, re: Request for Additional Information on 3M Process Operations Internal Correspondence, 3M, re: Oakdale Newsletter to be Published on Monthly Basis Letter to Craig Mattson, City of Oakdale, re: Confirmation of Meeting with MPCA concerning Current Status of Oakdale Disposal Site Remedial Action Program 3M_MN00001657 3M_MN00002866 3M_MN00001666 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 10/18/1977 11/21/1977 5/8/1978 6/1/1978 6/25/1979 8/28/1979 12/28/1979 11/10/1980 3/24/1980 4/4/1980 5/15/1980 5/19/1980 6/5/1980 6/27/1980 8/11/1980 10/10/1980 11/19/1980 12/12/1980 12/22/1980 1/15/1981 1/27/1980 1/30/1981 3/20/1981 5/4/1981 5/29/1981 7/28/1981 9/21/1981 10/21/1981 11/17/1981 12/1/1981 2/12/1982 3/18/1982 5/6/1982 5/21/1982 6/8/1982 6/25/1982 11/10/1982 1/21/1983 4/20/1983 6/20/1983 7/13/1983 9/2/1983 10/12/1983 2/17/1984 6/5/1984 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Oakdale Disposal Site Newsletter Vol 1, No. 11 3M_MN00002890 Letter to J. Liefert, MPCA, re: Air Permit Application for 3M Chemolite Building 15 New Fluorochemical Distillation 3M_MN00001667 System Letter to L.F. Ludford, 3M, re: Appreciation for Communications activities to Keep Citizens Informed 3M_MN00000785 Memorandum to F.T. Vikingsta, 3M, re: Recovery Unit Justification 3M_MN00000463 Letter to Residents within the SW-1 Advisory Area re: Recent Developments with Groundwater Contamination 3M_MN00000786 from the SW-1 Landfill Memo to H J. Wessel, 3M, re: Results of Dump Site Test Borings and Recommendations 3M_MN00001423 Internal Correspondence to R.A. Paschke, et al., 3M, re: Woodbury Update Report 3M_MN00039613 Internal Correspondence to R.H. Susag, et al., 3M, re: Woodbury Update Report 3MA00262822 Letter to Thomas Aschenmacher, 3M, re: Review of CRA Proposed Work Plan for the Woodbury Site 3MA00264445 Letter to Bruce Liesch, CPG, re: Termination Notice for Work Associated with the Woodbury Site 3MA00264276 Internal Correspondence to R.H. Susag and M.C. Goldsmith, 3M, re: Response to MPCA Request for Historical 3MA00285582 Information for Woodbury Email Correspondence to B.E. Hartz et al., 3M, re: Response to Pioneer Press Article and Water Treatment System 3MA01956169 Carbon Changeout Email Correspondence to John Pilney et al., 3M, re: Notes from Meeting to Discuss the Issue of Managing 3MA00994711 Fluorochemicals at the Corporate Incinerator Email Correspondence to D.M. Schnobrich et al., 3M, re: FC Waste Initiative 3MA01196704 Email Correspondence to L.M. Zabel and A.E. Short, 3m, re: Disposal of Fluorochemicals at Rosemount Landfill 3MA01166950 Letter to Gerald Stahnke, MPCA, re: Transmittal of 3M's Woodbury Site History, 3MA00846469 Internal Correspondence to B.H. Davis, et al., 3M, re: Topics for Discussion for Meeting on Woodbury 07/15/92 3MA00285593 Internal Correspondence to M.A. Beattie et al., 3M, re: Notes of Meeting to Discuss Short and Long Range Plans for Woodbury Site Email Correspondence to T J. Flick et al., 3M, re: Spent Phase III Carbon Email Correspondence to M.A. Santoro, et al., 3M, re: FC Emission Reduction Efforts Email Correspondence to Thomas Ashenmacher, 3M, re: Misidentified Waste from Decatur Chemical 3MA00269058 3MA01048747 3MA00044076 3MA01634182 Email to E. Reiner re: Draft Procedure for Disposal and Handling of FC Wastes Email Correspondence to Larry Zobel, 3M, re: Establishment of a Trace Fluorine Analytical Laboratory at 3M 3MA01410733 3MA00032535 Internal Correspondence to W.H. Pearlson re: Examination of Plant Personnel for Distribution of Fluorinated Organics Email Correspondence String to Dana Schnobrich, 3M, re: Oxy-pyrohydrolysis Method for Breaking C-F Bonds in FC Wastes Email Correspondence to S.P. Brinduse et al., 3M, re: Fluorochemical Test Results Internal Correspondence to C.W. Hansen, 3M, re: Notice of Meeting to Discuss Levels of FC in Workers 3MA00057895 3MA01167230 3MA00756954 3MAS00058191 Internal Correspondence, 3M, re: Meeting to Finalize Plans for Informing Individual and Parties of 3MA00047850 Fluorochemicals in Blood Situation Email Correspondence to Laura Solem and Summer Streets, MPCA, re: FW PFC Information STATE_1167661 Email Correspondence to Todd re: Soil Stockpile Info 3M_MN00714454 Memorandum to Mark Gaetz, 3M, re: 3M Water Supply Evaluation 3MA00048481 Letter to David Douglas, MPCA, re: 3M Chemolite Facility, Cottage Grove, Minnesota 3MA00607370 Memorandum to Mark Gaetz and Todd Fasking, 3M, re: Data Quality Objectives (DQO)-Cottage Grove FC Disposal 3MA00275887 Area Email Correspondence to Todd Fasking and Tina Galloway, 3M, re: Cottage Grove Sludge Sample Results 3MA01326865 FC Team Meeting Notes from 04/28/09 Email Correspondence String to Nathan Briffett, 3M, re: Use of Carbon Treatment for PFOS at 3M Gorseinon 3M_MN00996381 3MA01835241 Email Correspondence to Todd Fasking, 3M re: CG Carbon Email Correspondence to B.A. Gibson and H.H. Harapan, 3M, re: Building 15 Roof Removal Email Response to Tina Berg, 3M, re: Draft SD003 PFOS Limit Email Correspondence to R. A. Paschke, 3M, re: Cottage Grove/Woodbury Update Email Correspondence to Mark Gaetz, 3M, re: 3M CG Fire Training Pond Liner Issues Internal Correspondence to C.W. Olson, 3M, re: Fluorochemicals in the Environment Email Correspondence to W.D. Hirsh et al., 3M, re: List of Potential Products on EPA Hit List Email Correspondence to R.D. Howell, 3M, re: FC-143 Issues Interoffice Correspondence to H.G. Bryce, 3M, re: Comments on "The Ecological Aspects of Fluorochemicals" 3MA00948245 3M_MN00705018 3M_MN00703594 3M_MN00585512 3M_MN00707240 3M_MN00047092 3M_MN00017226 3M_MN00047228 3M_MN00047231 Interoffice Correspondence to R. M. Adams, 3M, re: Ecological Aspects of Fluorocarbons - your memo 7/14/71 3M_MN00047234 Internal Correspondence to Craig Burton, 3M, re: Environmental Concern with Fluorochemicals Internal Correspondence to S.M. Leahy, 3M, re: Fluorochemical Steering Committee Meeting Concerning Technical Sub-Committee Letter to J.W. Gillett re: Request for Review and Comment on "Projects to Investigate Fluorochemicals in the Environment" 3M_MN00047239 3M_MN00047270 3M_MN00047331 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Nov-84 6/10/1985 1/30/1987 9/13/1989 11/15/1989 7/26/1960 12/16/1992 1/21/1993 2/18/1992 8/24/1993 10/13/1992 9/17/2006 8/11/1999 10/11/2001 5/1/2001 8/20/1992 7/10/1992 5/8/1995 5/17/2005 8/17/2001 11/19/2004 9/12/1996 11/16/2000 7/7/1983 11/7/2002 3/17/2005 5/5/1980 6/3/1980 5/20/2010 11/8/2001 8/20/2001 4/20/2001 7/9/2002 8/2/2005 4/29/2009 3/15/2007 1/26/2004 9/11/2008 9/29/2010 3/17/2004 4/7/2010 2/5/1992 5/16/1991 11/18/1991 8/31/1971 9/13/1971 9/15/1992 7/22/1992 2/2/1993 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Internal Correspondence to Robert Howell, et al., 3M, re: Fluorochemical Technical Advisory Committee Meeting 02/16/93 concerning Preparing Proposals for Priority 1 and 2 Studies Internal Correspondence to C. Bros et al., 3M, re: Transmittal of Materials Distributed at the 10/7/92 Fluorochemical Technical Advisory Committee Meeting Internal Correspondence to C. Bros et al., 3M, re: Transmittal of Materials Distributed at the 10/7/92 Fluorochemical Technical Advisory Committee Meeting Email Correspondence to Jess Eldridge, 3M, re: Well Sampling At Woodbury Internal Correspondence to C. Bros et al., 3M, re: Review of Draft Health Hazard Summary for FC-143 3M_M N00047360 3M_M N00047369 3M_M N00047399 3M_MN00047472 3M_MN00047474 Email Correspondence to S. Beach, 3M, re: TSCA 8(e) on FC-143 Memorandum to D.L. Bacon, 3M, re: Performance Evaluation of Robert Howell Email Correspondence to Lael Pickett, 3M, re: J.F. Colbert File Notes from DuPont/3M Teleconference 1/31/97 3M_MN00047478 3M_MN00047520 3M_MN00047598 Email Correspondence to Al Zeitz and Marylee Maendler, 3M, re: Preparation for DuPont Tox/Env'tl Meeting 3M_MN00047601 Email Correspondence to William Weppner, 3M, re: Tox/Env'tl Issues - DuPont Risk Assessment Letter to Roger Zipfel, DuPont, re: Confirmation of Term and Conditions for Analytical Testing Services by 3M to DuPont Email Correspondence to Jean Sweeney, 3M, re: Recommendation for Appointment of James Kotsmith to Manager Health Safety and Environmental (Level 14) Email Correspondence to Robert Paschke, 3M, re: Brief Timeline Concerning Waste Disposal Email Correspondence to Robert Junnier, Weston Solutions, re: Oakdale RD/RA - Disposal Locations 3M_MN00047604 3M_MN00047612 3M_MN00375304 3MA01249333 3MA02662302 Memorandum to Robert Criswell, MPCA, re: Response to Comments on SW-383 Permit Reissuance Application and Addendum for the 3M Waste Containment Vault Email Correspondence to Cliff Jacoby et al, 3M, re: Oakdale Combined Discharge Sampling for June 09 3M_MN00568252 3M_MN00575950 Email Correspondence to Gary Hohnstein, 3M, re: Ozone Treatment of Wastewater Email Correspondence to Nate Arthur, Wash Cnty, re: Conference Call Information Concerning 3M PFC Wastes 3M_MN00506797 3M_MN00582326 Email Correpondence to R. Paschke, 3M, re: CEP Priorities Email Correspondence to D. Stang et al., 3M, re: Agenda for the Consent Order Management Team Meeting 06/17/08 Letter to K. Haberman re: Investigation Report 3M Company Woodbury Minnesota 02/1994 Email Correspondence to Tom Ashenmacher, 3M, re: Landfill Question related to Woodbury FC Soils 3M_MN00696812 3MA02631291 3M_MN00001678 3M_MN00583859 Email Correspondence to K.M. Winogrodzki re: 3M Disposal at Woodbury 3M_MN00585503 Email Correspondence to Gary Hohenstein, 3M, re: Request by MPCA to Add FC to Annual Sampling at Woodbury 3MA01544777 Email Correspondence to Robert Paschke, 3M, re: Historical Woodbury Residential Well Sampling Email Correspondence to James Kotsmith, 3M, re: Woodbury Update Email Correspondence to Justin Pettinelli, 3M, re: EPM - Task Addition 3M Internal Correspondence to Paul Ackerman, et al., 3M, re: Fluorochemical Steering Committee Meeting Minutes Email Correspondence to Robert Paschke, 3M, re: Brief Timeline for 3M Waste Disposal Defendant 3M Company's Corrected Non-confidential Memorandum in Support of its Motion for Summary Judgement on Plaintiffs' Negligence, Nuisance, Trespass and Punitive Damages Claims Letter from S.Kalkstein to The editor of the Fire journal of the NFPA Letter from H. Bryce & J. Long to C. Babcock Memo from F. Junghans to L. Nelson Letter from R. Wands Memo re Teratogenicity of Two Fluorochemical Compounds in Rats (Study Numbers 980TR0008 and 680TR0010 3MA00555642 3M_MN00568709 3M_MN00896478 3MA00323846 3M_MN00002947 3M_MN00020069 3M_MN02267863 3M_MN02267865 3MA00077798 3MA00214098 3M_MN02327312 Letter from M. Osborne to J. Hansmeyer re requested leachate and composition date for the boiler ash and iron 3M_MN00000166 oxide sludge Memo from R. Susag re Meeting Notice for 9:30 AM Wednesday, April 5 3MA00281185 Memo re Minutes of the Chemolite Waste Diposal and Water Conservation Committee Meeting 3MA00456259 Memo from JMO to MJB re Encapsulation of Hazardous Material 3MA00280412 Letter from J. Menter to R. Susag re 3/7/1979 discussions 3MA00280898 Meeting Memorandum - Wednesday, December 19, 1973, 8:15 AM, 42-5W (Meeting Minutes Chemolite Sludge 3MA00456549 Thickening Project) Memo from M. Goldsmith & K. Knoblock to J. Brown re Woodbury Township Dump Site 3M_MN00048254 Memo from K. Knoblock to J. Brown re Woodbury Township Dump Site 3M_MN00048258 Memo from C. Kiester to J. Ling re Woodbury DIsposal Site 3MA00336067 Letter from M. Santoro to M. Ayers re 3M Chemolite Hydrogeologic Investigation 3MA00067546 Internal Correspondence from G. Hohenstein to L. Hoffmeier re Chemolite Phase I Sludge 3MA00854462 Memo from C. Kiester re Investigation of Woodbury Dump Site 3M_MN00000140 Letter re Response to the July 12, 2007 MPCA Request for Information on Historical Operations at the 3M Cottage 3M_MN01392934 Grove Facility Letter to Document Processing Center of Office of Pollution Prevention and Toxics at EPA from W. Weppner re 3M_MN00439748 Information on Perfluorooctane Sulfonates and Related Compounds Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 2/17/1993 3/18/1993 3/18/1993 4/12/1994 4/14/1994 7/19/1995 2/28/1996 2/13/1997 2/14/1997 2/27/1997 4/17/1997 10/19/2009 1/26/2005 1/19/2009 6/20/2008 5/22/2009 12/23/2008 11/3/2008 2/11/2011 6/16/2008 2/25/1994 8/18/2009 7/10/2003 3/6/2006 4/13/2005 6/30/2008 12/21/2010 11/17/1993 1/26/2005 12/10/2008 6/15/1970 ND 9/14/1964 11/24/1961 11/12/1980 4/27/1978 3/28/1978 6/9/1959 6/27/1979 3/9/1979 12/20/1973 7/10/1963 7/26/1963 4/26/1973 11/17/1981 5/26/1982 12/5/1963 11/30/2007 12/22/2000 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Letter to R. Taber from H. Birnbaum Letter to H. Hays (National Research Council) from R. Wands PFOA M/S & E - 9b: Blood Levels of RF/F In Selected Employees Internal Correspondence to L. Krogh from L. Ludford Email to J. Butenhoff et al from R. Purdy re Risk to the environment due to the presnce of PFOS Interoffice Correspondence from J. Belisle re Fluorochemicals in Blood Memo of Meeting - July 12, 1978 re Fluorochemicals in Blood Interoffice correspondence re Meeting re Results of Animal Studies at I.R.D.C. Interoffice correspondence re Meeting Mintes re Fluorochemicals Technical Review Committee Interoffice Correspondence from J. Belisle re Fluorochemicals in Blood Letter from A. Boyden (Minnesota Mining and Manufacturing Company) Letter from L. E. Rinehart (3M) re Ignition of Woodbury Liquid Trenches Letter from F.A. Ubel regarding Fluorocarbons with article attachments Letter from R.H. Susag to Louis Breimhurst Letter to Metropolitain Waste Management Advisory Committee re Application for Reissuance of Permit SW-224 and Landfill Expansion: 3M Chemolite Intert Landfill Interoffice correspondence re Meeting Minutes regarding Incinerator Ash and Wastewater Treatment Sludge Disposal Interoffice Correspondence from H.A. Birnbum to R.R. Burford (Chemical Division) Attachment to Letter of December 22, 2000 Supplemental Submission - Toxicology and Medical Surveillance 3M_MN01314624 3M_MN01314847 3M_MN01692291 3MA00065421 3MA00242692 3MA00967424 3MA10034915 3MA10066961 3MA10066974 3MA10067224 3M_MN01002429 3MA00337738 3M_MN00057505 3MA00364080 3MA00294816 3M_MN00052172 3MA01789592 3MB00023926 Memo from J A. Brown to H. Wessel re Proposed Dump Site Field Letter of R. C. Collins et al. re: Meeting to Discuss Merits of Woodbury Dump Site Field Letter of R. C. Collins et al. re Woodbury Land Fill Dump and Pollution Prevention Field Letter of Allan E. Miller and R.C. Collins Memo from C. Houdek re Rebuildng and Relocation of Sewage Pond - Chemolite Plant Interoffice Correspondence to D. H. Cochran, 3M, re: Waste Disposal Woodburv Dump Site Interoffice Correspondence to J.A. Brown, 3M re: Bentonite Lined Trench at Woodbury Township Dump Site 3M_MN00000135 3M_MN00000231 3M_MN00000138 3MA00335929 3MA00456329 3M_MN00000220 3M_MN00000379 Memo to J.A. Brown, 3M, re: Acid Disposal Pit at Woodbury Township Dump Site Interoffice Correspondence re: Meeting with State Health Officials relating to Woodbury Dump Site 3M_MN00000717 3M_MN00001425 Letter from R. Bohon (3M) to C. Alig (Naval Ship R&D) re FC-206 Handwritten Letter regarding "ongoing situation at Cottage Grove" Internal Correspondence from T. Baltutis re Surfactants in Wastewater Memo from T. Baltutis to J. Webster re Surfactants in wastewater Letter from H. Rogere (Dept of Health) to F.B. Richerson (Minnesota Mining & Manufacturing) Memo re Meeting with State Health Officials Woodbury Dump Site Interoffice Correspondence re Investigation of Woodbury Dump Site Letter from John Jenson (Crookston Clinic) to Minnesota Mining & Manufacturing Letter to J. Jensen (Crookston Clinic) from H. Birnbaum Letter from J. West (Veterans Administration) to 3M General Offices Letter from H. Birnbaum to J. West (Veterans Administration) Letter to H. Birnbaum from L. Johns (Veterans Administration Hospital) Handwritten Letter to 3M Chemical Division Letter to J. Harthum re: Response to Request for Information Pertaining to Disposal of Materials at Oakdale, Minnesota Letter to R. Susag re: 3M Disposal at Oakdale Site Letter to R. Susag re: Information Request Concerning Alleged Disposal Site at Chemolite Plant Along the Mississippi River Letter to L. Breimhurst, MPCA, re: Response to Request for Information on Waste Disposal at Chemolite Plant from 1950 to 1955 Letter to J. Baskerville re: 3M Company TSCA Section 8(e) Compliance Audit - (04/11/00) Interoffice Correspondence from G.H. Crawford re Fluorocarbons in Human Blood Plasma Interoffice Correspondence to J.D. La Zerte, 3M, re: Presentation to Corporate Responsibility Committee on Progress - Fluorochemicals in Blood Memo from R. Prokop to those present re Meeting Minutes - Fluorochemicals Technical Review Committee 3M_MN01316603 3MA00243643 3M_MN00040517 3MA00457772 3MA00456232 3MA00336224 3MA00335790 3M_MN01314620 3M_MN01314619 3M_MN01314623 3M_MN01314622 3M_MN01314621 3M_MN01235364 3MA00284889 3M_MN00000351 3M_MN00000218 3M_MN00000143 3MA00847625 3MA10034962 3M_MN00000479 3MA10067042 Internal Correspondence, 3M, re: Meeting to Finalize Plans for Informing Individual and Parties of Fluorochemicals in Blood Situation Email from D. Kriens to D. Douglas and M. Rys re 3M-PFOS and related compounds in discharge MPCA letter from L. Christensen to J. Ling re Notice of Violation, U.S. Environmental Protection Agency and Minnesota Pollution Control Agency Hazardous Waste Violations Notice of Violation from R. Massey (MPCA) to J. Ling (3M) Letter from T. Dellenbach (Washington County Department of Public Health) to G. Hohenstein (3M) Letter G. Wegwart (MPCA) to J. M. Osborne (3M) Letter from B. Thompson (MPCA) to G. Hohenstein (3M) Letter from T. Kelley (MPCA) to R. Bringer (3M) Letter from Eric Reiner to Wakui Katsuhiro, re: Hydrogen Fluoride Toxicity for Plants Bacon, Exhibit 03 - Meeting Minutes re: International Surfactant Regulations Bacon, Exhibit 04 - FC-129 Biodegradability 3M_MN00000756 3M_MN00043945 3MA00282920 3MA00611640 3MA00296018 3MA00296010 3MA00278295 3MA00370602 3M_MN04747296 3M_MN03423961 3MA10035965 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 6/7/1966 12/19/1963 6/20/1978 9/8/1981 12/4/1998 11/3/1977 7/14/1978 5/10/1978 5/12/1978 7/29/1977 5/11/1962 11/30/1964 8/25/1997 5/21/1982 11/3/1986 3/22/1978 10/7/1966 12/22/2000 7/13/1960 7/28/1960 4/20/1961 8/9/1960 12/1/1961 5/14/1962 7/26/1963 7/10/1963 11/8/1963 6/25/1976 5/30/1990 11/29/1994 6/3/1996 7/15/1958 11/8/1963 12/5/1963 11/10/1967 11/27/1967 6/12/1967 6/21/1967 8/14/1967 2/22/1969 6/25/1979 6/5/1980 5/4/1981 5/29/1981 8/21/2000 8/20/1975 10/19/1977 4/12/1978 6/3/1980 6/28/2005 1/11/1984 4/3/1984 8/14/1987 8/21/1987 7/1/1988 9/19/1988 6/6/1996 1/21/1976 12/30/1988 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Bacon, Exhibit 06 - Meeting Minutes Bacon, Exhibit 07 - Brand Transmittal Memo from Dale Bacon to John Butenhoff Bacon, Exhibit 10 - Memo from Robert Howell re: Trip Report - Texas A&M Fire Training School Bacon, Exhibit 12 - Letter from C. Reich re TSCA Section 8e Decision Bacon, Exhibit 13 - Memo from Donald Theissen re: Fluorochemical Steering Committee Meeting Minutes 3MA10066616 3M_MN03108995 3M_MN02470154 3MA10064459 3MA00323646 Bacon, Exhibit 15 - Email from Donna Mandel re: Scientific Publication Strategy Bacon, Exhibit 17 - Email from David Sanders re Manuscript Bacon, Exhibit 18 - Email from Dale Bacon re: Comments on Canadian Document Bacon, Exhibit 19 - Email from Dale Bacon re: Comments on Canadian Document Bacon, Exhibit 21 - Email from Eric Reiner re Articles Added to Fluorochemical Bibliography Bacon, Exhibit 22 - Email from Dale Bacon re Planning Document Bacon, Exhibit 23 - Email from Dale Bacon re Stuff (attachment: the Discovery of a new class of POP) 3MA00467427 3MA00198538 3MA001095838 3MA01095856 3M_MN03426043 3MA00546050 3MA00186126 Bacon, Exhibit 24 - Email from J. Giesy re Avian Toxicity Reference Values 3M_MN03014876 Bacon, Exhibit 25 - Email from J. Giesy to D. Bacon re Chironomid Study 3MA01320495 Bacon, Exhibit 27 - Memo from John Giesy to Dale Bacon re Follow up to February 2, 2006 meeting (revised 3MA01320414 memo) Bacon, Exhibit 28 - Email from J. Giesy to D. Bacon re ES&T paper 3MA01320043 Bacon, Exhibit 29 - Email from J. Giesy re paper on human blood 3MA00194174 Bacon, Exhibit 30 - Email from William Nelson to Dale Bacon re PFOS in fish blood 3MA01320249 Bacon, Exhibit 31 - Email from J. Giesy to D. Bacon re PFOS in the Environment 3M_MN01093981 Bacon, Exhibit 32 - Email from Susan Beach to J. Giesy re Review on Reporton PFCs in Minnesota 3MA01420224 Bacon, Exhibit 33 - Email from J. Giesy re Looking for a post-doc candidate 3M MN03016361 Bacon, Exhibit 34 - Email from Joe Otterstetter to Rosalie Joyce re Testing 3MA00472514 Bacon, Exhibit 35 - Email from Dale Bacon to Kathy Reed re Request for analysis of human blood samples of PFOS 3MA00186222 Falco, Exhibit 02 - Email from Frances Shipman re 3M Phasing Out Some of Its Specialty Materials Falco, Exhibit 04 - Letter from Larry Wendling re Environmental, Health And Safety Measures Relating To Perfluorooctanoic Acid And Its Salts (PFOA) Falco, Exhibit 06 - Email from Michael Falco to Michael Nash re Assessment of Long Chain Fluorochemical Use 3MA01630642 3M_MN02377792 3M_MN04836974 Falco, Exhibit 07 - Email from Gary Hohenstein to Falco re SOT Poster - Red Cross Blood Survey Falco, Exhibit 11 - Memo re FC Customer Letter Falco, Exhibit 12 - FC Customer Letter 1 Falco, Exhibit 13 - Email from Peter Koelsch re Customer Letter on PFOS and PFOA Falco, Exhibit 16 - Email from Linda Zabel to M. Falco re Minutes from conference with Cottage Grove and Cordova Falco, Exhibit 18 - Email from M. Falco to Paul Johnson re Chemical Action Plan for long-chain PFCs leads to regulatory review of TSCA regulatory options, including Section 6 rulemaking Falco, Exhibit 19 - Memo from D. Roach to P. Riehle re Organic Fluorine Levels Falco, Exhibit 20 - - Email from M. Falco re AFFF test results-query Falco, Exhibit 23 - Email from Chetan Jariwala to Dan Hakes re Report on POPS Falco, Exhibit 24 - Email from Mark Morken re SCA 8(e) final report transmittal - 05-200, MTDID 6285, PFBF 3M_MN04834654 3M_MN04738077 3M_MN04738078 3M_MN04777459 3MA00956222 3M_MN00848407 3M_MN03269963 3M_MN02369801 3M_MN03005883 3M_MN00848670 Reiner, Exhibit 02 - Letter from H. Butcher re Predisposal Treatment Requirements for Deluge Fluids 3M_MN01235852 Reiner, Exhibit 03 - Letter from Jim Deyonshire re Foam Systems Testing, Beale A.F.B. California 3M_MN01315290 Reiner, Exhibit 09 - Email from Eric Reiner to Dale Bacon re HFE-7100 Hydrolysis Study 3M_MN01432228 Reiner, Exhibit 10 - Memo from Eric Reiner to Chou Chow re Disposal of Scrap FC Electrolyte 3MA01400474 Reiner, Exhibit 11 - Email from Eric Reiner to V. Pothapragada re Questions of Fluorochemicals 3MA00967645 Reiner, Exhibit 13 - ACT 603 Activated Sludge Calculators 3M_MN01433334 Reiner, Exhibit 17 - Memo from R. Bohon to J. Lazerte re Fate of Fluorochemicals Phase II 3MA10065463 Reiner, Exhibit 18 - Email from Eric Reiner to Misao Shiba re RCRA 3M_MN04741336 Reiner, Exhibit 20 - Email from Richard Purdy re Rich Purdy's resignation 3M_MN01427584 Letter to DCO re EPA Docket ID Number OPPT-2004-0001 - Laboratory-Scale Incineration Testing of Fluorotelomer- Based Polymers 3M_MN03192380 Court Filings 3M's Amended Answers Attachment 1 Defendant Responses to Plaintiff First Request for Production of Documents 3M's Answers to First Set of Interrogatories 3M-Responses to First Set of Requests for Admissions 3M's Responses to State's Second Set of RFAs 3M's Responses to 2d RFPs 3M's Responses to State's Third Set of RFAs 3M's Responses to Fourth Set of Requests for Admission 3M's Responses to State's Third Set of Interrogatories and Fourth Set of Requests for Production of Documents Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 6/9/1976 12/30/1992 5/5/1994 3/20/1998 11/17/1993 11/23/1999 9/9/2000 2/7/2003 2/10/2003 8/1/2005 1/23/2006 12/26/2000 3/13/2007 2/21/2006 2/17/2006 2/12/2006 4/7/2003 2/14/2006 7/25/2003 6/27/2006 4/3/2007 3/11/2002 3/11/2002 5/16/2000 3/13/2003 1/3/2013 3/9/2011 2/11/1999 9/26/2007 5/11/2005 4/21/2010 8/31/1984 11/18/2009 6/18/2013 3/10/2008 4/25/1985 6/3/1988 9/12/1996 12/30/1988 8/6/1980 3/17/1997 5/25/1983 9/17/1996 3/28/1999 12/22/2008 5/17/2011 5/24/2011 12/5/2011 1/9/2012 3/9/2012 3/28/2012 6/6/2012 10/2/2012 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 3Ms Responses to Second Set of Interrogatories and Third Set of Requests for Production of Documents 3M's Answers to the State's 4th ROGS and 5th RFPs-c Plaintiff State of Minnesota's Sixth Set of Requests for Production of Documents 3M's Responses to the State's Fifth Set of ROGs and Seventh Set of RFPs Defendant 3M Company's Objections and Responses to Plaintiff State of Minnesota's Third Set of Requests for Admission Opening Statements - Paulson et al., v. 3M Company Closing Statements - Paulson et al., v. 3M Company Defendant 3M Company's Answer to Plaintiffs' First Set of Interrogatories and Response to Plaintiffs' Third Set of 3M_MN00029316 Requests for Production of Documents Defendant 3M Company's Second Amended Answers to Plaintiffs' Third Set of Interrogatories 3M_MN00031192 Defendant 3M Company's Sixth Supplemental Answers to Plaintiffs' First Set of Interrogatories 3M-MN00031772 Trial Testimony of Gary Hohenstein Trial Testimony of Charles Kiester, Parts I & II Trial Testimony of Katherine Reed, Parts I & II Trial Testimony of Michael Santoro Part I Trial Testimony of Michael Santoro Part II Deposition Deposition of Dean Dworak Vol. 1 Michael A. Santoro Deposition Transcript Vol. 2 Michael A. Santoro Deposition Transcript Deposition of Thomas Ashenmacher Deposition of Thomas Ashenmacher, Vol I in Maslowski et al. v 3M Company Deposition of Thomas Ashenmacher, Vol II in Maslowski et al. v 3M Company Deposition of Venkateswarlu Pothapragada Deposition of Mark Gaetz Deposition of Robert Howell Deposition of James Kotsmith Deposition of Katie Winogrodzki Paulson Deposition of Donny Kriens Transcript of Dale Bacon Deposition Transcript of Eric Reiner Deposition Transcript of Michael Falco Deposition Transcript of Gordan Weum Deposition Transcript of Linda Zabel Deposition Transcript of Larry Zobel Deposition Transcript of Deanna Luebker Deposition Transcript of Kathy Reed Deposition Transcript of Charles Reich Deposition Transcript of John Butenhoff Deposition Transcript of Susan Beach Deposition Transcript of Charles Kiester Deposition Transcript of Geary Olsen Deposition Transcript of Michael Santoro Deposition Transcript of David Richfield Deposition Transcript of William Reagen Deposition Rough Transcript of Richard Purdy Deposition 3M_MN00055483 3M_MN00055743 3M_MN00039333 3M_MN00039629 3M_MN00047014 3M_MN00048652 Dissertation Harvard Ellenbogen dissertation Presentation Perfluooctane Sulfonate (PFOS) in the Environment Manufacturing Drying Team Review Basic 3M Presentation to the Cottage Grove Planning and Zoning Commission Cottage Grove Wastewater Carbon Study Cottage Grove FC Initiative Presentation to Minnesota Pollution Control Agency Meeting Presentation on PFOS Preliminary Draft Rough Outline for Presentation to EPA Presentation - #1 Operational Priority - Redacted Board of Directors Presentations November 9, 1991 FC Issues 3M or 3M-Sponsored Peer-Reviewed Scientific Publications/Presentations Prior to the Phase-Out Announcement (1978-2000): Presentation to Plant Employees - Redacted 3M TSCA Section (e) Compliance Audit - Meeting with EPA Toxics and Pesticides Enforcement Division 3M_MN02252789 3M_MN02851125 3MA00281029 3MA00617241 3MA00904546 3M_MN00055818 3MA10070188 3MA10054319 3M_MN00055734 3M_MN00041056 3MA00401223 3MA01620983 3MA00229897 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 10/3/2012 10/10/2016 10/11/2016 12/20/2016 3/28/2012 5/11/2009 6/16/2009 9/2/2005 10/10/2006 9/21/2007 ND ND ND ND ND 2/24/2012 9/19/2006 9/22/2006 3/7/2012 12/7/2012 12/8/2012 4/17/2012 4/6/2012 11/15/2007 2/9/2012 2/22/2012 11/14/2006 8/3/2017 8/1/2017 8/23/2017 8/28/2017 8/15/2017 8/22/2017 8/29/2017 8/31/2017 8/30/2017 9/8/2017 9/15/2017 9/14/2017 9/8/2017 9/15/2017 8/14/2012 9/18/2017 9/21/2017 May-49 ND 11/19/1999 7/24/1978 8/13/2004 8/4/2000 10/15/2004 ND 4/15/1998 ND 11/9/1998 ND ND 9/11/2000 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Calendar Entry Appointment - Presentation by Mike Santoro (Director EHS & Regulatory Affairs) focused on the Fluorochemical Initiative FC Communications Update Meeting, Conference Call & Net Meeting, U S. and Europe PFC Exposure Reduction Activities at 3M and Dyneon LLC Fluorochemicals of Interest Presentation "Trace Fluorine Analysis" Presentation - Informational Meeting Cottage Grove Site Remedial Investigation (RI) & Feasibility Study 3M_MN00063561 3MA01071082 3M_MN00413227 3M_MN00565758 3M_MN00000444 3M_MN01126135 Presentation entitled "Fluorine Health/Environmental Concerns" Presentation entitled "Environmental Fate and Effects of Fluorochemicals" Presentation entitled "Biotransformation of Perfluorooctanoate" Working Draft - Oakdale RI/FS Presentation Presentation tiltled "Fluorochemical Decomposition Processes - Quantification and Assessment" Bacon, Exhibit 16 - FC Environmental Strategy Falco, Exhibit 03 - PPT: A 3M Core Technology Falco, Exhibit 08 - Presentation to EHS Minichapter Falco, Exhibit 09 - FC Management Update Corporate EHS Committee Falco, Exhibit 10 - Fluorochemical EHS Background Falco, Exhibit 17 - 2012-2016 FC Reduction Targets Falco, Exhibit 21 - Dyneon APFO Replacement Program Falco, Exhibit 25 - Environmental Health and Safety profile of new Perfluorinate building block versus phased out chemistry Reiner, Exhibit 15 - Environmental Assessment Team 3M_MN00047260 3M_MN00047522 3M_MN00047555 3M_MN00569903 3M_MN04734885 3MA00554962 3M_MN00838987 3M_MN02373078 3M_MN02375543 3M_MN03639885 3M_MN04834485 3M_MN02372412 3MA01870640 3MA01405333 Public Materials Article in St. Paul Sunday Pioneer Press "3M waste burning test fails" by Allen Short EPA Headquarters Press Release 3M and the Withdrawal of PFOS: TSCA, Product Liability, and the Precautionary Principle. 33 ELR 10062 3MA00382051 3M_MN01095149 3MA00255530 The Path to a Painful Choice. June 5, 2000 Article Entitled "Fine against 3M eyed for dumping coal ash" Article titled 'Woodbury Grants Permit for Dump" Newspaper Article - "3M Transfers Technician to Avoid Fluorochemicals" Article "Dumpsite Excavation Poses No Danger to Residents, 3M Says" Article " Nearby Dumpsite Chills Sales of Oakdale Homes, Owners Say" Article "Oakdale Cleanup Is Two Years Ahead of Schedule" 2006-04-25 Consent Agreement 2006-04-25 Press Release 2006-04-25 TSCA Audit "'Potential exposure' forces 3M transfer" St. Paul Dispatch Weekly Compilation of Presidential Documents EPA News Release: EPA Settles Case Involving 3M Voluntary Disclosures of Toxic Substances Violations 3MA01169364 3MA00281006 3M_MN00001424 3M_MN00001541 3M_MN00000378 3M_MN00000346 3M_MN00000784 3MA10035803 Brice and Trott (U.S. Patent Office: Fluorocarbon Sulfonic Acids and Derivatives) Scholberg, et al. (U.S. Patent Office: Electrochemical Production of Fluorocarbon Acid Fluoride Derivatives) Clark et al., 1973 (PFCs Having a Short Dwell Time in the Liver) Dappert, 1932 (Public Health Engineering - The Travel of Pullution Underground) Grosse & Cady, 1947 (Properties of Fluorocarbons) Guenthner & Vietor, 1962 (Surface Active Materials from Perfluorocarboxylic & Acids) Klevens & Ellenbogen, 1954 (Protein Fluoroacid Interaction - Bovin Fluoroacid Interaction) Klevens, 1955 (Formation of Complexes of Fluorocarbons) Lewis et. al., 1976 (Incineration of Industrial Wastes at a Large Multi-Product Manufacturing Plant) Minneapolis Star, 1948 Nordby & Luck, 1956 (Perfluorooctanoic Acid Interactions With Human Serum Albumin) Schmidt, 1956 (Soil Nitrification & Nitrates in Water) Simons, 1948 (US Patent 2447717) Simons, 1949 (Fluorocarbons) Simons, 1950b (US Patent 2519983) Van Noordwyk & Santoro, 1978 (Minnesota Mining and Manufacturing Company's Hazardous Waste Program) Woodward et al, 1961 (Experiences with Ground Water Contamination in Unsewered Areas in Minnesota) Spreadsheets AOI Info Compilation Volume treated Phase 1/2 September-October Data Spreadsheet N-EtFOSE Alcohol Bibligraphy 3MA00046813 3MA00865752 3MA00917580 3MA02497423 3MA00491366 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 3/11/2004 10/26/2004 ND ND ND 1/31/2008 ND ND 11/11/1996 5/12/2008 4/27/2000 10/11/2004 3/11/2004 8/2/2010 Aug-16 Sep-07 3/11/1984 5/16/2000 Jan-03 5/26/2000 8/22/1978 8/10/1960 5/22/1981 2/8/1984 2/15/1984 7/18/1984 3/9/2006 4/25/2006 6/7/1999 5/22/1981 4/13/1970 4/25/2006 1/24/1956 9/13/1955 1973 1932 1947 1962 1954 1955 1976 1948 8/1/1955 1956 8/24/1948 1949 8/22/1950 1978 1961 ND ND ND ND ND CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 3M Phase Out Product and Division Table 3M Phase Out Product and Division Table Table containing Years 2001-2002 Production Totals for Proposed Extended Phase-Out Applications Table containing Proposed Extended Phase-Out Use Distribution and Obligation Analysis Table containing Year 2000 Production Base-Line for Phase-Out Table containing Year 2000 Production Base-Line for Phase-Out Current CG FC Waste Status Draft - Off-Site Waste Disposal Locations - 3M Cottage Grove, Minnesota Off-Site Waste Disposal Locations - 3M Cottage Grove, Minnesota Chemolite Waste Survey Operation Data for Building 15 Chemolite Waste Survey Operation Data for Building 15 3M Cottage Grove FC Analysis from SD 001 Off-Site Waste Disposal Locations - 3M Cottage Grove, Minnesota Test Data for Samples Taken from Plaintiffs' Properties Chemolite Phase III Sludge - Composition: Analytical Data 1979 - 1982 Chart Bacon, Exhibit 22A - Lead the Science: 2006 Project Plan Falco, Exhibit 15 - Manufacturing Site C8 Emission/Exposure 3M_MN00845627 3MA01620760 3M_MN01101911 3M_MN01101917 3M_MN01101919 3MA00723879 3MA00043765 3MA00344394 3MA00401867 3MA00456294 3MA00456295 3MA00918294 3MA01243198 3M_MN00000712 3M_MN00000439 3M_MN00067393 3MA00546051 3MA00955859 Report Todd Tech Report - FC 95 Photolysis Study Using Simulated Sunlight 01-09-1979 Elnabarawy Tech Report Bioconcentration of FM 3422 in Bluegill 5-17-1977 Mendal A. Technical Report - Analytical Methodology and Support 1-17-1979 Mendal A. Technical Report - Analytical Method FM 3422 11-15-1977 Welsh Tech Report Adsorption of FC 95 and FC 143 02-27-1978 Welter Tech Report - Bioconcentration 8-16-1978 Environmental Engineering Laboratory Aquatic Toxicity Data Sheet Protocol for Oral Teratology Study of ... In Rats Central Analytical Laboratory re Characterization of Decatur RF Values Report by C. Hutt & S. Nash Technical Report Summary re Trace Fluorochemicals in the Environment Extent and Route of Excretion and Tissue Distribution of Total Carbon-14 in Rats after a single Intravenous Dose of FC-95-14C D-1, D-2, Disposal Areas D-9 3M Cottage Grove Wastewater Treatment System Technical Report Summary re Drug Metabolism Department PFOA and Associated Salts Technical Report Summary re Commercial Chemicals Technical Report Summary re Summary Report Technical Report Summary re Metabolism of Fluorochemicals Acute Oral Toxicity Screen with T-2714CoC in Albino Rats Ten Most Common Questions or Concerns on Fluorad Surfactants The Science of Organic Fluorochemistry A Review of the Environmental Fate and Effects of Sulfonyl Based Fluorochemicals Exposure Assessment Planf or Fluorochemical Products Version 2 Sulfonated Perfluorochemicals in the Environment: Sources, Dispersion, Fate and Effects Sulfonated Perfluorochemicals: U.S. Release Estimation - 1997 Part 1: Life Cycle Waste Stream Estimates 3M_MN00063785 3M_MN00429098 3M_MN01645178 3M_MN01666463 3MA10036129 3MA10078436 3M_MN02255659 3M_MN02327303 3M_MN02327314 3M_MN02327394 3M_MN02343992 3M_MN02345360 3M_MN02559482 3M_MN02789765 3M_MN02855552 3M_MN01692418 3M_MN02255655 3M_MN02468412 3M_MN02855523 3M_MN02900994 3M_MN02909630 3M_MN02931918 3M_MN00041116 3M_MN00043464 3M_MN00473634 3M_MN03269947 Fluorochemical Use, Distribution and Release Overview Final Report: Summary of Estimated FC Waste Streams Based on 1997 Sales in the U S. (PFOS equivalents in lbs /yr.) Listing of Human Health Assessments on Perfluorooctane Sulfonate and Perfluorooctanoic Acid Summary Report Fluorochemicals in Populations and the Environment Fate of Fluorochemicals in the Environmental Chemical Oxygen Demand of FM 3925 Acute Toxicity to Fish (Bluegill Sunfish) Acute Toxicity to Aquatic Invertebrates (Daphnia Magna) Algicidal Activity Extent and Route of Excretion and Tissue Distribution of Total Carbon-14 in Male and Female Rats after a Single IV Dose of FC-143-14C Biodegradation Soil Absorption Acute Toxicity to Invertebrates (Grass Shrimp) Acute Toxicity to Invertebrates (Fiddler Crab) Enhanced Elimination of FC-95-14C and FC-143-14C in Rats with Cholestyramine Treatment Bioconcentration Aquatic Toxicity Testing: L-4640, NB 53415-34, L.R. 53988 Solubility of FM 3925 The Effects of Continuous Aqueous Exposure to 78 01 on Hatchability of Eggs and Growth and Survival of Fry of Fathead Minnow 3MA00243308 3MA00470322 3MA00600322 3MA01453915 MN.045.0012 000123 3MA10078711 3M_MN00436402 3M_MN01656831 3M_MN00436466 3MA10053361 3MB00008226 3MB00019021 3M_MN00437323 3M_MN00437333 3MA00828756 3MB00008292 3MA10036797 3MA00176732 3MA10054960 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN ND ND 7/8/2000 7/8/2000 7/8/2000 7/11/2000 8/21/2000 ND ND 12/4/1960 1/12/1961 ND ND ND ND ND 2006 ND 1/9/1979 1/17/1979 5/18/2000 2/27/1978 8/16/1978 12/2/1978 7/25/1980 10/4/1979 12/18/1981 8/4/1978 12/28/1979 5/16/1974 9/16/2004 5/12/1982 5/21/1979 8/28/1981 9/28/1979 2/20/1980 4/8/1977 2/5/1999 11/18/1998 5/18/1998 3/1/2000 4/21/2000 5/26/1999 4/21/2000 6/25/1998 8/12/1979 1/8/1979 6/27/2000 6/27/2000 6/27/2000 1/30/1980 5/17/2000 5/25/2000 6/28/2000 6/28/2000 5/5/1980 5/18/2000 3/14/1980 1/8/1979 6/1/1978 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Acute Toxicity to Aquatic Invertebrates (Eastern Oyster) 3M_M N00437343 FC-95/Photolysis Study using Simulated Sunlight 3MA01409805 Aquatic Fate of a Fluorochemical: FM 3422 3MA10054996 Acute Toxicity to Aquatic Invertebrates (Daphnia Magna) 3M_MN00437351 Acute Toxicity to Aquatic Invertebrates (Scud) 3M_MN00437359 Distribution Coefficient of FM 3925 in n-Octanol/Water 3MA00176756 Summary of Histopathological Examinations of Fathead Minnow (pimephales promelas) Exposed to 78 01 for 30 3MB00008518 days Aquatic Toxicity Studies: FM 3925 3MA00176748 Analytical Methodology and Support 3MA00176700 Biodegradation (Warburg) 3M_MN00432788 Biodegradation (ABS/LAS Shake Culture Test) MET 0408060 Aquatic Toxicity Testing: FC-143 (Lot-37) L.R. 5625 S 3MA01410233 Toxicity to Aquatic Plants (E.G., Algae) MET 0398747 Detection of Fluorochemicals in Decatur Wastewater 3MA01409767 FC-143 Photolysis Study Using Simulated Sunlight 3MA00248157 3M Report: Bioaccumulation Studies 3M_MN00370746 Photodegradation Study on FM-3925 3MA00176662 Soil Absorption 3MB00008571 Absorption of FM-3925 on Soil 3MA10054768 Chronic Toxicity to Fish 3M_MN01645082 Photolysis of FM3925 in Aqueous Solutions 3MA00176671 FC-171 (Lots 1 & 2): Aquatic Testing Results 3MA01334870 Summary of Histopathological Examinations of Fathead Minnow (Pinephales promelas) exposed to 78 02 for 30 3MA01251950 days Analysis for Fluorochemicals in Bluegill Fish 3MA00717678 Aquatic Toxicity Testing: CS-2070 3MA00718407 Request for Laboratory Work Final Report 3MA01409771 FC-171: Aquatic Testing Results 3MA01334859 Absorption of FC-807-14C in Rats After a Single Oral Dose 3MA00397045 Synthesis and Characterization of FC-807-14C 3MA10053439 Evaluation of the Biconcentration Potential of FM 3422 3MA10036483 Acute Toxicity to Aquatic Invertebrates (Eastern Oyster) 3M_MN01656900 Acute Toxicity to Fish (Mummichog) 3MB00020385 Acute Toxicity to Aquatic Invertebrates (Grass Shrimp) 3M_MN00436480 Extent and Route of Excretion and Tissue Distribution of Total Carbon-14 in Rats after a Single Intravenous Dose 3MA00251159 of FC-807-14C Synthesis and Characterization of FC-95-14C 3MA01405916 Photolysis of FM 3422 on Soil 3MA10036575 Fluorochemicals in Tennessee River Fish 3MA01409555 Extent and Route of Excretion and Reissue Distribution of Total Carbon 14 in Rats after a Single Intravenous Dose 3MA00725668 of FC-95-14C Absorption of FC-143-14C in Rats After a Single Oral Dose 3MA10014647 Synthesis and Characterization of FC-143-14C 3MA10017301 Report on Land Acquisitions for 3M Woodbury Site Woodbury, Minnesota 3M_MN00000222 The Beginnings of "The Fluorochemicals in Blood Program" (A Brief Outline) 3M_MN00000415 Draft 11/15/02 3M_MN01526194 Ecotoxicology and Environmental Fate Testing of Short Chain Perfluoroalkyl Compounds Related to 3M 3M_MN01537089 Chemistries Summary for Work Performed for the German Government Agency for Military Technology and Procurement on 3M_MN01657796 fire extinguishing foam compounds from multiple companies Environmentally Responsive Functional Fluorochemicals 3M_MN02470086 Figure 2-3 Feed Systems 3MA00108307 Hydrogeologic Investigation Phase I & II - Final Report 3MA00342318 3M Waste Stream Profile Request 3MA00465637 Central Analytical Laboratory report number 7448 3MA00525628 Calendar Entry Meeting re Discuss Off-site Disposal Practices for PFOA containing wasates- Location: 3MA00731685 Teleconference and Net Meeting 3M Cottage Grove FC Analysis from SD 001 3MA00827784 D8 Waste Disposal 3MA00839823 Analytical Report Fluorochemical Characterization of Aqueous Samples Oakdale NRG Sampling (E04-0561) Exygen 3MA00853087 Research Laboratory Report No. L0003120 3M Cottage Grove Facility 3MA00948357 Woodbury 3MA00948358 Draft Water Quality Values for PFOS for the Protection of Aquatic Organisms as determined under EPA's Final 3MA01095950 Water Quality Guidance for the Great Lakes System PFOS - General Talking Points 3MA01243195 Products of incomplete combustion of POSF Based Fluorochemicals 3MA01412209 DRAFT Fluorochemical (FC) Investigation Data Assessment Report for the 3M Cottage Grove, MN Facility 3MA01546555 3M Woodbury Water Line Evaluation 3MA01646790 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 6/28/2000 1/9/1979 10/14/1977 6/28/2000 6/28/2000 1/10/1979 Sep-78 1/8/1979 1/17/1979 5/16/2000 5/25/2000 5/5/1980 5/3/2000 6/23/1980 2/2/1979 3/8/1993 8/9/1980 5/17/2000 3/22/1979 5/25/2000 11/7/1980 5/21/1979 Dec-79 5/1/1979 11/19/1980 12/2/1980 6/29/1979 7/10/1979 8/9/1979 8/16/1979 6/27/2000 6/27/2000 6/27/2000 9/28/1979 11/2/1979 12/10/1979 12/28/1979 12/28/1979 12/28/1979 12/28/1979 11/15/2002 2008 6/26/2000 Mar-82 10/19/2001 3/3/1981 4/1/2004 May-00 9/30/1999 Apr-06 Jul-07 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Analytical Report Fluorochemical Characterization of Facility Wastewaters Cottage Grove Stat.4 Composites (E01- 3MA01854588 0007A) Centre Analytical Laboratory Report No. L30257 Section C Waste Characteristics 3MA01936610 Fluorochemical Characterization Program SMD Manufacturing Facilities 3MA10071071 Waste Disposal History Cottage Grove, Minnesota WE10336340 Comparison of Lipid Peroxidation by Perfluoro-octanoic acid or CCL4 3M_MN00050924 Products of incomplete combustion of POSF Based Fluorochemicals 3MA01412204 3M Communications Regarding Fluorochemicals and the Cottage Grove Plant Through 1989 3MA01934998 Fate of Fluorochemicals - Phase II 3MA10052935 DRAFT Proposal to Further Evaluate the Environmental Risk of 3M Cluorochemicals - Part II 3MA10063232 Preliminary Report of FC-807-14C 3MA00251204 Daphnid Bioassay CS-2070, Lot 3 (LR-64575) 3MA00718424 Solubility Measurements on FC-95 3MA01409760 FC095 Solubility Envir. Assess. Inq. #80021 3MA00326782 Annual Project Progress Report - 1980 3MA00398305 Synthesis and Characterization of FC-807-14C 3M_MN03112787 FC-117 MSD and PED Sheets 3M_MN01429695 First Trimester Report - 1981 3MA10023958 Technical Report re Biodegradation Studies on CS-81210. LR 6589S 3M_MN01049898 Technical Report re Chemical Oxygen Demand o(CS-81210, LR 6589S 3M_MN01049892 Technical Report re Fathead Minnow Bioassay CS-81210, LR 6589s 3M_MN01049942 Technical Report Summary re Second Trimester - 1981 3MA10044295 Technical Report Summary re FM-3422 Photolysis Study Using Simulated Sunlight 3MA00717332 Technical Report re Environmental Risk Assessment on CS-81210 3M_MN01049882 Technical Report re Acute Effects of CS-2070 on Microbial Respiration 3MA00718413 Technical Report re Biosorption of CS-2070 3MA00718437 Technical Report re Chemical Oxygen Demand of CS-2070 3MA00718419 Technical Report re Biodegradation of CS-2070 3MA00718421 Technical Report re Environmental Risk Assessment on CS-2070 3MA00718429 Technical Report re Summary of Environmental Testing 3M_MN00565018 Technical Report re Multi-Phase Exposure Recovery Algal Assay Test Method 3MA01409742 Technical Report re Multi-Phase Algal Assay Test Method 3MA00829896 Absorption and Biotransformation of N-Ethyl POSE 3MA00257617 Biotransformation of C-N-Ethyl FOSE in Rats 3MA00257559 Pilot Study Oral Absorption of 14C Ammonium 3M_MN02255693 Technical Report re First Trimester -1983 3MA10044302 Fate of Fluorochemicals - Phase II 3MA01400357 Extent and Route of Excretion of Total Carbon-14 in Pregnant rats 3MA10014682 Questions and Answers on the Need for the Fate of Fluorochemicals 3MA01531583 Technical Report re Quatic Toxicity Testing FC-600 3M_MN02255766 Draft of Meeting Minutes 8-16-83 Presentation of the Fate of Fluorochemicals Phase II, Proposa 3MA10063227 Technical Report re Second Trimester -1983 3MA10035756 Technical Report re Reapraisal of POSF Environmental Fate 3MA01409593 Technical Report re Effect of Potassium Perfluorooctanesulfonate on Survival 3MA01409725 Modified OECD Screening Test on FC-203, FC-203a, and FC-600 MET 0413641 Technical Report re Third Trimester - 1984 3MA10063401 Technical Report re First Trimester -1985 3MA10044331 Technical Report re Second Trimester - 1985 3MA10044326 Acute Toxicity of FC-171 to Mysid Shrimp 3MA01334953 BOD and COD Testing of L-9684 3M_MN01054408 Technical Report re Analytical Results for FM-3923 Chronic Toxicity Study 3MA00735651 Acute Toxicity of GX-07 1 to Daphnia magna 3MA10000737 Industrial Hygiene Survey 3M_MN02743547 Acute Toxicity of GX-07 I to Rainbow Trout 3MA10000735 MBAS of FC-95 and Sultone Foamer Request No. 01827 3MA01251877 MBAS of FC-95 and Sultone Foamer Request No. 01828 3MA01409712 Statis Acute Toxicity of FX-1003 to the Fathead Minnow, Pimephales promelas 3MB00019289 Acute Toxicity to Aquatic Invertabrates (Daphnia Magna) 3M_MN01655814 Technical Report re Method for analysis of perfluorooctane sulfonate by thermospray mass spectrometry 3M_MN02468678 Technical Report re Analysis of K-salt by thermospray mass spectrometry in the negative ion mode Fluorochemicals in the Environment Acute Toxicity of FC-171 to the Mysid, Mysidopsis bahia Memo from S. Gordon to C. Burton re FC-807 Health Hazard Summary Guidelines for the environmentally friendly use of foaming extinguishing agents FC-10 Fluorochemical Alcohol Commercial Chemicals Division Fluorad Brand Luorochemical Alcohol FC-10* Restricted Health Hazard Summary of Ammonium salts of Mono-, Di- and Tri[N-ethyl(perfluorooctane) sulfonamidoethyl]phosphates as Represented by FC-807 M.S.I. Report No. 1B363(2) G Ready Biodegradability Test of D-1 M.S.I. Report No. 4B223-4B227 Determination of Physico-chemical Properties of Sample D-1 3M_MN02855910 3MA00720928 3M_MN01236002 3MA10082587 3M_MN01315001 3M_MN02513958 3MA00829891 3MA10065265 3MA10018681 3MA10018736 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 3/20/1987 6/6/1999 Jun-07 5/20/1983 12/3/1982 1/13/1981 2/5/1981 2/6/1981 2/16/1981 2/16/1981 2/23/1981 3/10/1981 4/29/1981 6/19/1981 6/29/1981 6/30/1981 8/3/1981 8/11/1981 8/20/1981 8/24/1981 8/25/1981 8/31/1981 8/31/1981 9/4/1981 12/11/1981 12/16/1981 12/30/1981 1/19/1983 1/28/1983 1/28/1983 4/20/1983 5/20/1983 6/30/1983 7/13/1983 7/21/1983 8/16/1983 2/11/1986 4/18/1986 9/28/1988 4/12/1988 9/29/1988 6/21/1989 8/4/1989 3/15/1990 8/9/1990 10/26/1993 11/19/1993 12/3/1992 12/31/1981 10/31/1995 2/14/1996 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Bibliography Technical Report re Soil Absorption of Fluorochemical Surfactants Photolysis of FM 3422 on Soil Progress Report Aquatic Toxicity Studies: FM 3925 Analytical Methodology and Support Final Comprehensive Report: FC 95 Solubility of FM 3925 Final Comprehensive Report on FM 3422 Adsorption of FM-3925 on Soil Photolysis of FM3925 in Aqueous Solutions Extent and Route of Excretion and Tissue Distribution of Total Carbon-14 in Rats after a Single IV Dose of FC-9514C Perfluorooctane Sulfonic Acid - A Rat-Liver AR No. 7474 - Metabolite of FM-3422 Absorption of FC-95-14C in Rats after a Single Oral Dose Absorption of FC-95-14C in Rats after a Single Oral Dose Perfluorooctane Sulfonic Acid - A Rat-Liver AR No. 7474 - Metabolite of FM-3422 Analysis of Chemolite HF Cell Tar Leachates Analysis of Chemolite HF Cell Tar Leachates 3M Technical Reports Pertaining to Environmental Issues of Fluorochemicals 1977 Summary 1977 Summary Final Comprehensive Report on FM 3422 FC-95/Photolysis Study using Simulated Sunlight Photolysis of FM3925 in Aqueous Solutions FM-3422 Photolysis Study Using Simulated Sunlight N-EtFOSE Alcohol Bibligraphy POSF Index of 3M AR-226 Docket Submissions by AR-226 Docket Number and 3M CD Number Index Fathead Minnow Bioassay: CS-81210, L.R. 6589S Fathead Minnow Bioassay: CS-81210, L.R. 6589S Fathead Minnow Bioassay: CS-81210, L.R. 6589S Fathead Minnow Bioassay: CS-81210, L.R. 6589S Fathead Minnow Bioassay: CS-81210, L.R. 6589S Fathead Minnow Bioassay: CS-81210, L.R. 6589S AR No. 7717 - Extraction of Scotchpak Film 113 - January 3, 1983 Compatibility of FC-600 with Biological Waste Treatment FC-171 (Lots 1 & 2): Aquatic Testing Results Compatibility of FC-600 with Biological Waste Treatment Compatibility of FC-600 with Biological Waste Treatment Compatibility of FC-600 with Biological Waste Treatment Summary of Environmental Testing on CS-8161 Analytical Results for FM-3923 Chronic Toxicity Study The complete titles of the 8 reports reviewed by Dr. Stephen A. Boyd are: 3M Technical Reports Pertaining to Environmental Issues of Fluorochemicals POSF AR No. 7474 - Perfluorooctane Sulfonic Acid - Rat-Liver Metabolite of FM-3422 - June 9, 1981 Absorption of FC-95-14C in Rats after a Single Oral Dose Index of 3M AR-226 Docket Submissions by AR-226 Docket Number and 3M CD Number Chemolite Process Engineering Report, November 1979 First Triannual Report - 1982 Enhanced Elimination of FC-95-14C and FC-143-14C in Rats with Cholestyramine Treatment Extent and Route of Excretion and Tissue Distribution of Total Carbon-14 in Male and Female Rats after a Single IV Dose of FC-143-14C Second Trimester - 1981 Third Trimester - 1982 Environmental Effects of Fluorinerts FC-48 and FC-78 Aquatic Toxicity Studies: FC-232 Lot 610 Aquatic Toxicity Studies: FC-214-30 Lot 566 L-4380: Results of Aquatic Toxicity Testing Environmental Aspects of POSF Environmental Aspects of POSF Environmental Evalu8ation of FC/Linseed Fatty Acid Ester Compatibility of FC-600 with Biological Waste Treatment 3rd Quarter Report - 1977 Biodegradation Studies of Fluorocarbons First Quarter Report, 1969 Fourth Quarter Report, 1966 3MA10065715 3MA01406796 3MA10078609 3MA10078629 3MA10078650 3MA10078668 3MA10078679 3MA10078682 3MA10078695 3MA10078734 3MA10078740 3MA10078983 3MA10079057 3MA10079060 3MA10079098 3MA10079117 WE10267965 WE10268876 3M_MN00001297 3M_MN00048382 3M_MN00053051 3M_MN00053120 3M_MN00063772 3M_MN00063804 3M_MN00063817 3M_MN00063838 3M_MN00565433 3M_MN00565443 3M_MN00604181 3M_MN01031646 3M_MN01049943 3M_MN01050155 3M_MN01050284 3M_MN01050416 3M_MN01050623 3M_MN01050861 3M_MN01235281 3M_MN01235823 3M_MN01236050 3M_MN01236069 3M_MN01236076 3M_MN01246087 3M_MN01429692 3M_MN01429701 3M_MN01429728 3M_MN02345179 3M_MN02345298 3M_MN02345336 3M_MN02345341 3M_MN02359405 3M_MN02468382 3M_MN02468419 3M_MN02468556 3M_MN02468592 3M_MN02468624 3M_MN02468631 3M_MN02514018 3M_MN02514027 3M_MN02514036 3M_MN02514047 3M_MN02571703 3M_MN02571728 3M_MN02853966 3M_MN02853973 3M_MN02853994 3M_MN02853997 3M_MN02854112 3M_MN02854195 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 12/10/1979 8/30/1978 1/8/1979 1/17/1979 3/15/1979 1/8/1979 2/7/1979 3/22/1979 11/7/1980 12/28/ 6/9/1981 10/26/1979 10/26/1979 6/9/1981 4/4/1984 4/4/1984 11/30/1977 11/30/1977 2/7/1979 1/9/1979 11/7/1980 8/11/1981 6/30/1981 6/30/1981 6/30/1981 6/30/1981 6/30/1981 6/30/1981 1/3/1983 12/29/1977 5/21/1979 12/29/1977 12/29/1977 12/29/1977 12/11/1981 6/4/1986 6/9/1981 10/26/1979 12/26/1979 5/18/1982 3/5/1980 1/30/1980 8/3/1981 1/4/1983 12/27/1978 1/17/1979 2/16/1979 6/14/1979 8/17/1983 12/29/1977 10/13/1977 8/12/1976 4/21/1969 1/20/1967 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 NMR Analysis of the Photolysis Reaction of a Perfluorosuccinyl Fluoride Hexafluoropropylene Oxide Monomer 3M_MN02854349 Stability and Quality Control of L-1913 AR No. 7166 - FC-143 Inhalation Study - Analysis for F and RF Bioassay Techniques in Aquatic Environments and Soil-Plant Systems Environmental Effects in Aquatic & Soil- Plant Systems 1st Quarter Report - 1979 4th Quarter Report - 1979 3rd Quarter Report - 1981 Modified OECD Screening Test on FC-203, FC-203a, and FC-600 Determination of Biodegradability of FattyAcid/FC Alcohol FC-509, Lot 2 (FC 6254, cc 791-2) Aquatic Testing Solubility of FM 3925 Distribution Coefficient of FM 3925 in n-Octanol/Water Chemical Oxygen Demand of FM 3925 FC-171: Aquatic Testing Results Biodegradation of "LIGHT WATER" Products in OECD Test Aquatic Toxicity Testing: FC-246 (F-6437 Lot 4) LR 5884S Bioassays on Leachate of FC-2174, Lot 905 Biodegradation Studies on CS-81210, LR 6589S Bioassays on Cured and Uncured Fluoroelastomer Leachate Biodegradation of FC-807 Treated Cardboard Aquatic Toxicity Testing: FC-5158(cc817-11) Lot 689 LR 7460 Concentration and Toxicity of FC-2152 Leachate Environmental Aspects of POSF Biodegradation Study of FX-229, NB 65368-52 Leaching Studies on Vapor Suppressant Foams Made Using 3 Foaming Agents Multi-Phase Exposure/Recovery Algal Assay Test Method Effect of Potassium Perfluorooctanesulfonate on Survival, etc. Progress Report Inhibitory Effect of Fluorinerts to Beckman's Microtox Third Quarter Report, 1968 3rd Quarter Report - Applications Group Final Report, 1969 First Quarter Report, 1973 Second and Third Quarter Report, 1973 - Organic Second Quarter Summary, 1973 - Organic Research Third Quarter Summary, 1973 - Organic Research Chemolite Process Engineering Report, January 1978 Chemolite Process Engineering Report, February 1978 Chemolite Process Engineering Report, October 1978 Chemolite Process Engineering Report, May 1979 Chemolite Process Engineering Report, December 1979 Chemolite Process Engineering Report, March 1980 Chemolite Process Engineering Report, August 1980 Absorption and Biotransformation of N-Ethyl FOSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed Third Trimester -1983 Al Antistat/PET Compounding Experiment Third Trimester Report -1987 Development of LZ-13053 (FC-280-X) as VOC free FC-1800 and FX-819 replacement product directed at the medical nonwovens market IRDC 137-088: FM-3422/Monkey Analysis of Rat Serum for C8F17CH2CH2OH and Metabolites - March 3, 1981 Biotransformation of 14C-N-Ethyl FOSE in Rats After Administration in Feed for One Week Absorption of FC-9807-14C in Rats After a Single Oral Dose Extent and Route of Excretion and Tissue Distribution of Total Carbon-14 in Rats after a Single IV Dose of FC-80714C IRDC 137-088: FM-3422/Monkey IRDC 137-092: FC-95/Monkey Perfluorooctane Sulfonic Acid - A Rat-Liver AR No. 7474 - Metabolite of FM-3422 Biotransformation of 14C-N-Ethyl FOSE in Rats After Administration in Feed for One Week Fourth Quarter Report, 1973 Third Quarter Summary Report, 1973 Second Quarter Report, 1973 Rate Studies of Tetrahydrofuran Polymerization Catalysts FX-361 Process Development Flammability of Fluorocarbons and Chlorofluorocarbons in Gas Mixtures Containing Fluorine Process Hazard Analysis for Fluorine Pilot Plant POSF Hydrolysis Photolysis of FM3925 in Aqueous Solutions 3M_MN02854395 3M_MN02854409 3M_MN02854444 3M_MN02854458 3M_MN02854462 3M_MN02854466 3M_MN02854470 3M_MN02854474 3M_MN02854491 3M_MN02854542 3M_MN02854567 3M_MN02854574 3M_MN02854585 3M_MN02854589 3M_MN02854643 3M_MN02854711 3M_MN02854716 3M_MN02854725 3M_MN02854768 3M_MN02854773 3M_MN02854783 3M_MN02854791 3M_MN02854794 3M_MN02854809 3M_MN02854818 3M_MN02854832 3M_MN02854864 3M_MN02854893 3M_MN02854955 3M_MN02855043 3M_MN02855048 3M_MN02855053 3M_MN02855064 3M_MN02855074 3M_MN02855086 3M_MN02855094 3M_MN02855103 3M_MN02855113 3M_MN02855170 3M_MN02855225 3M_MN02855267 3M_MN02855291 3M_MN02855345 3M_MN02855401 3M_MN02855556 3M_MN02855899 3M_MN02856108 3M_MN02856146 3M_MN03111855 3M_MN03112073 3M_MN03112655 3M_MN03112860 3M_MN03112905 3MA00013123 3MA00013128 3MA00057821 3MA00057869 3MA00077944 3MA00077956 3MA00077964 3MA00079989 3MA00085704 3MA00090261 3MA00090488 3MA00176624 3MA00176641 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 12/1/1986 6/16/1971 6/20/1979 4/4/1978 1/25/1979 4/17/1979 1/16/1980 9/23/1981 7/20/1984 8/17/1983 3/16/1979 1/8/1979 1/10/1979 1/8/1979 6/29/1979 6/30/1980 8/20/1980 11/17/1980 6/19/1981 9/29/1981 4/22/1980 2/1/1982 6/28/1983 9/14/1983 2/28/1985 4/8/1986 11/16/1981 2/27/1984 8/30/1978 6/24/1985 Dec-68 12/31/1969 Aug-69 Sep-73 Oct-73 Jun-73 Sep-73 2/13/1978 3/15/1978 11/15/1978 6/20/1979 1/23/1980 4/14/1980 10/1/1980 3/9/1983 2/3/1984 3/21/1990 1/13/1988 1/26/1994 8/16/1978 1/28/1983 7/10/1979 9/28/1979 8/16/1978 8/4/1978 6/9/1981 1/28/1983 3/7/1974 9/21/1973 7/12/1973 9/7/1965 10/24/1990 1/26/1990 8/18/1993 Jun-84 11/7/1980 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Chemical Oxygen Demand of FM 3925 Adsorption of FM-3925 on Soil Environmental Aspects of POSF POSF FM-3422 Photolysis Study Using Simulated Sunlight POSF POSF Analysis of Chemolite HF Cell Tar Leachates Volatilization of Organics from Pumpout Wells Final Comprehensive Report: FC 95 Feasibility Study for Treatment and Disposal of Abresch Site Pumpout Water Concentration of Isopropyl Ether (IPE) from Water Feasibility Study for Treatment and Disposal of Abresch Site Pumpout Water AR No. 7230 - Characterization of Decatur RF Values POSF IRDC 137-092: FC-95/Monkey IRDC 137-088: FM-3422/Monkey Absorption and Biotransformation of N-Ethyl FOSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed IRDC 137-092: FC-95/Monkey Analysis of Fluorochemicals Environmental Aspects of POSF Absorption and Biotransformation of N-Ethyl FOSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed AR No. 7166 - FC-143 Inhalation Study - Analysis for F and RF Feasibility Study for Treatment and Disposal of Abresch Site Pumpout Water AR No. 7230 - Characterization of Decatur RF Values Photolysis of FM 3422 on Soil Evaluation of the Bioconcentration Potential of FM 3422 Biodegradation Studies of Fluorocarbons Progress Report Bioconcentration of FM 3422 in Bluegill Sunfish and in Channel Catfish Analytical Methodology on FM 3422 Absorption of FM-3422 on Soil Final Comprehensive Report on FM 3422 Synthesis and Characterization of FC-95-14C IRDC 137-092: FC-95/Monkey Third Trimester Report - 1979 Synthesis and Characterization of FC-95-14C Third Trimester - 1981 First period Report -1979 Evaluation of the Bioconcentration Potential of FM 3422 First Trimester Report - 1978 FC in Blood FC in Blood IRDC 137-092: FC-95/Monkey IRDC 137-085: FC-95/Rat IRDC 137-088: FM-3422/Monkey FC in Blood Analysis of 3M Cordova Serum AR No. 7128 - PAK-79 Series: Analysis for RF and F AR No. 7104 - Original Chemolite Series: Analysis for RF and F IRDC 137-088: FM-3422/Monkey FC in Blood Multi-Phase Exposure/Recovery Algal Assay Test Method Solubility Measurements on FC-95 Final Comprehensive Report: FC 95 Analytical Methodology and Support Progress Report Biodegradation Studies of Fluorocarbons - III Photolysis of FM3925 in Aqueous Solutions AR No. 7230 - Characterization of Decatur RF Values Progress Report AR No. 7194 - Analysis of Decatur Employee Serum for Total Fluoride AR No. 7230 - Characterization of Decatur RF Values AR No. 7230 - Characterization of Decatur RF Values Method for analysis of perfluorooctane sulfonate (FC-95) by thermospray mass spectrometry Fluorochemicals in Tennessee River Fish Bioaccumulation of Fluorochemicals in Tenn. River Fish Analysis for Fluorochemicals in Bluegill Fish Effect of Potassium Perfluorooctanesulfonate on Survival, etc. 3MA00176744 3MA00176762 3MA00193738 3MA00195570 3MA00248675 3MA00251500 3MA00254287 3MA00291556 3MA00300995 3MA00326771 3MA00332466 3MA00336015 3MA00343070 3MA00351914 3MA00353521 3MA00396333 3MA00396336 3MA00396988 3MA00398295 3MA00398300 3MA00467562 3MA00509359 3MA00525616 3MA00613495 3MA00639013 3MA00717355 3MA00717371 3MA00717554 3MA00717567 3MA00717588 3MA00717602 3MA00717635 3MA00717665 3MA00725649 3MA00760307 3MA00828153 3MA00828709 3MA00829144 3MA00829248 3MA00891985 3MA00967457 3MA00967478 3MA00967480 3MA00967482 3MA00967485 3MA00967488 3MA00967511 3MA00967515 3MA00967521 3MA00967524 3MA00967560 3MA00967562 3MA01251896 3MA01251912 3MA01251917 3MA01251928 3MA01251957 3MA01252000 3MA01334666 3MA01400241 3MA01400320 3MA01400732 3MA01400737 3MA01400740 3MA01404520 3MA01404987 3MA01404990 3MA01405000 3MA01406143 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 1/8/1979 3/22/1979 9/14/1983 8/11/1981 4/4/1984 8/9/1984 3/15/1979 8/30/1984 12/12/1980 8/30/1984 10/4/1979 8/4/1978 8/16/1978 1/19/1983 8/4/1978 5/4/1977 9/1/1983 1/19/1983 6/20/179 8/30/1984 10/4/1979 12/10/1979 8/16/1978 8/12/1976 8/30/1978 5/17/1977 11/15/1977 9/1/1978 2/7/1979 11/2/1979 8/4/1978 12/18/1979 11/2/1979 2/17/1982 5/16/1979 8/16/1978 5/4/1978 8/1/1978 8/1/1978 8/4/1978 8/4/1978 8/16/1978 11/3/1978 1/17/1979 4/4/1979 4/6/1979 8/16/1978 8/1/1978 12/16/1981 2/6/1981 3/15/1979 1/17/1979 8/30/1979 7/19/1978 11/7/1980 10/4/1979 8/30/1979 7/30/1979 10/4/1979 10/4/1979 7/9/1991 12/28/1979 5/22/1979 5/1/1979 2/13/1984 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Multi-Phase Exposure/Recovery Algal Assay Test Method Solubility Measurements on FC-95 Analysis for Fluorochemicals in Bluegill Fish Final Comprehensive Report: FC 95 Analytical Methodology and Support Progress Report Biodegradation Studies of Fluorocarbons - III Biodegradation Studies of Fluorocarbons Biodegradation Studies of Fluorocarbons Adsorption of FC 95 and FC 143 on soil Review of Technical Report Summary Adsorption of FC 95 and FC 143 in Soil Biodegradation Studies of Fluorocarbons - III Multi-Phase Exposure/Recovery Algal Assay Test Method Effect of Potassium Perfluorooctanesulfonate on Survival, etc. Review of Technical Report Summary Adsorption of FC 95 and FC 143 in Soil Review of Technical Report Summary Adsorption of fm-3422 on Soil Review of Technical Report Summary Analytical Methodology and Support Review of Technical Report Summary Final Comprehensive Report FC 95 Review of Technical Report Summary Adsorption of FM 3925 on Soil Review of Technical Report Summary Photolysis of FM 3422 on Soil Review of Technical Report Summary Biosorption of CS 2070 Absorption and Biotransformation of N-Ethyl POSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed Absorption of FC-807-14C in Rats after a Single Oral Dose Absorption of FC-95-14C in Rats after a Single Oral Dose Analysis of Decatur, AL. Soil for Fluorine Content Review of Technical Report Summary Adsorption of FC 95 and FC 143 in Soil Adsorption of FC 95 and FC 143 on soil Final Comprehensive Report: FC 95 Progress Report Review of Technical Report Summary Adsorption of FC 95 and FC 143 in Soil Adsorption of FC 95 and FC 143 on soil Multi-phase exposure/recovery algal assay test method Detection of Fluorochemicals in Decatur Wastewater FC-143 Photolysis Study using simulated sunlight FC-143 Photolysis study using simulated sunlight Progress Report Analysis of Decatur, AL. Soil for Fluorine Content Aquatic Fate of a Fluorochemical: FM 3422 Biotransformation of 14C-N-Ethyl FOSE in Rats After Administration in Feed for One Week Perfluorooctane Sulfonic Acid - A Rat-Liver AR No. 7474 - Metabolite of FM-3422 Index of 3M AR-226 Docket Submissions by AR-226 Docket Number and 3M CD Number E03-0833 Technical Reports Journal Articles First Trimester Report - 1981 Absorption and Biotransformation of N-Ethyl FOSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed AR No. 7166 - FC-143 Inhalation Study - Analysis for F and RF AR No. 7166 - FC-143 Inhalation Study - Analysis for F and RF Absorption and Biotransformation of N-Ethyl FOSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed 3M Technical Reports Pertaining to Environmental Issues of Fluorochemicals Absorption and Biotransformation of N-Ethyl FOSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed Absorptioni of FC-95-14C in Rats after a single oral dose Synthesis and Characterization of FC-95-14C IRDC 137-088: FM-3422/Monkey IRDC 137-092: FC-95/Monkey AR No. 7166 - FC-143 Inhalation Study - Analysis for F and RF Annual Project Progress Report - 1980 First Trimester - 1982 First Quarter Report - 1980 Second Quarter Report - 1980 Third Trimester Report -1979 IRDC 137-085: FC-95/Rat IRDC 137-088: FM-3422/Monkey IRDC 137-092: FC-95/Monkey IRDC 137-085: FC-95/Rat Effect of Potassium Perfluorooctanesulfonate on Survival, etc. POSF Hydrolysis Environmental Aspects of POSF Environmental Aspects of POSF 3MA01406157 3MA01406173 3MA01406182 3MA01406189 3MA01406200 3MA01406229 3MA01406279 3MA01406316 3MA01406676 3MA01406689 3MA01406703 3MA01406705 3MA01406748 3MA01406764 3MA01406781 3MA01406783 3MA01406786 3MA01406788 3MA01406790 3MA01406792 3MA01406793 3MA01407593 3MA01407649 3MA01408546 3MA01409570 3MA01409683 3MA01409685 3MA01409792 3MA01410003 3MA01410146 3MA01410148 3MA01410207 3MA01410244 3MA01410264 3MA01410277 3MA01410349 3MA01410370 3MA01452750 3MA01452988 3MA01453004 3MA01797544 3MA02346021 3MA10000020 3MA10009071 3MA10014707 3MA10020163 3MA10025386 3MA10027511 3MA10029365 3MA10029868 3MA10029902 3MA10032054 3MA10032058 3MA10033278 3MA10033280 3MA10035324 3MA10035423 3MA10035466 3MA10035530 3MA10035576 3MA10035583 3MA10035587 3MA10035597 3MA10035953 3MA10035974 3MA10035977 3MA10035994 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 12/16/1981 2/6/1981 5/1/1979 3/15/1979 1/17/1979 8/30/1978 7/19/1978 8/12/1976 8/12/1976 2/27/1978 7/19/1978 12/16/1981 2/13/1984 1/19/1983 7/10/1979 10/26/1979 6/6/1978 2/27/1978 3/15/1979 8/30/1978 2/27/1978 11/16/1981 6/23/1980 2/2/1979 2/2/1979 8/30/1978 6/6/1978 10/14/1977 1/28/1983 6/9/1981 4/29/1981 1/19/1983 6/20/1979 6/20/1979 1/19/1983 1/19/1983 10/26/1979 11/2/1979 8/16/1978 8/4/1978 6/20/1979 2/16/1981 5/12/1982 3/5/1980 7/23/1980 12/18/1979 8/4/1978 8/16/1978 8/4/1978 8/4/1978 2/13/1984 Jun-84 9/1/1983 9/1/1983 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Aquatic Fate of a Fluorochemical: FM 3422 Analytical Methodology on FM 3422 1977 Summary Biodegradation Studies of Fluorocarbons - II Biodegradation Studies of Fluorocarbons - II Comments on the 3M Technical Report "Adsorption of FC 95 and FC 143 on soil" Comments on the 3M Technical Report "Adsorption of FC 95 and FC 143 on soil" Adsorption of FM-3422 on soil FC-95/Photolysis Study using Simulated Sunlight Comments on the 3M Technical Report "Adsorption of FC 95 and FC 143 on soil" Final Comprehensive Report on FM 3422 Final Comprehensive Report: FC 95 Adsorption of FM-3925 on Soil Comments on the 3M Technical Report "Adsorption of FC 95 and FC 143 on soil" Adsorption of FM-3925 on soil Evaluation of the Bioconcentration Potential of FM 3422 Attached comments on the 3M Technical Report "Photolysis of FM-3422 on Soil" Extent and Route of Excretion and Tissue Distribution of Total Carbon-14 in Male and Female Rats after a Single IV Dose of FC-143-14C Enhanced Elimination of FC-95-14C and FC-143-14C in Rats with Cholestyramine Treatment Photolysis of FM3925 in Aqueous Solutions Annual Project Progress Report - 1980 Multi-phase exposure/recovery algal assay test method Multi-phase Algal Assay Test Method Effect of Potassium Perfluorooctanesulfonate on Survival, etc. Effect of Potassium Perfluorooctanesulfonate on Survival, etc. AR No. 7194 - Analysis of Decatur Employee Serum for Total Fluoride Absorption and Biotransformation of N-Ethyl FOSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed Biotransformation of 14C-N-Ethyl FOSE in Rats After Administration in Feed for One Week Absorption of FC-95-14C in Rats after a Single Oral Dose Absorption and Biotransformation of N-Ethyl FOSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed Absorption and Biotransformation of N-Ethyl FOSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed Absorption of FC-95-14C in Rats after a Single Oral Dose Absorption and Biotransformation of N-Ethyl FOSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed Biotransformation of 14C-N-Ethyl FOSE in Rats After Administration in Feed for One Week Enhanced Elimination of FC-95-14C and FC-143-14C in Rats with Cholestyramine Treatment Extent and Route of Excretion and Tissue Distribution of Total Carbon-14 in Male and Female Rats after a Single IV Dose of FC-143-14C Synthesis and Characterization of FC-143-14C Third Trimester - 1982 Second Trimester - 1983 Biotransformation of 14C-N-Ethyl FOSE in Rats After Administration in Feed for One Week Perfluorooctane Sulfonic Acid - A Rat-Liver AR No. 7474 - Metabolite of FM-3422 Absorption of FC-95-14C in Rats after a Single Oral Dose Third Trimester -1982 Third Trimester - 1981 Absorption and Biotransformation of N-Ethyl FOSE and Tissue Distribution and Elimination of Carbon-14 after Administration of N-Ethyl FOSE-14C in Feed Biotransformation of 14C-N-Ethyl FOSE in Rats After Administration in Feed for One Week Environmental Aspects of POSF Effect of Potassium Perfluorooctanesulfonate on Survival, etc. Multi-phase exposure/recovery algal assay test method Solubility Measurements on FC-95 Photolysis of FM3925 in Aqueous Solutions Final Comprehensive Report: FC 95 Final Comprehensive Report on FM 3422 FC-143 Photolysis Study Using Simulated Sunlight Distribution Coefficient of FM 3925 in n-Octanol/Water FC-95/Photolysis Study using Simulated Sunlight Solubility of FM 3925 Biodegradatioin Studies on FM 3925 Adsorption of FM-3422 on Soil Adsorption of FC 95 and FC 143 on Soil Biodegradation Studies of Fluorocarbons - II Biodegradation Studies of Fluorocarbons FC-143 Photolysis Study Using Simulated Sunlight Final Comprehensive Report: FC 95 3MA10036008 3MA10036017 3MA10036027 3MA10036052 3MA10036092 3MA10036126 3MA10036280 3MA10036283 3MA10036301 3MA10036327 3MA10036379 3MA10036406 3MA10036417 3MA10036428 3MA10036431 3MA10036485 3MA10036573 3MA10036691 3MA10036735 3MA10036813 3MA10036841 3MA10036843 3MA10036859 3MA10036945 3MA10037533 3MA10043619 3MA10043632 3MA10043693 3MA10043715 3MA10043783 3MA10043840 3MA10043897 3MA10043965 3MA10044085 3MA10044146 3MA10044193 3MA10044230 3MA10044306 3MA10044321 3MA10046201 3MA10049593 3MA10049596 3MA10053139 3MA10053149 3MA10053186 3MA10053418 3MA10053569 3MA10054690 3MA10054702 3MA10054719 3MA10054724 3MA10054779 3MA10054790 3MA10054803 3MA10054817 3MA10054823 3MA10054836 3MA10054843 3MA10054859 3MA10054946 3MA10054976 3MA10055010 3MA10059113 3MA10061032 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 10/14/1977 11/15/1977 11/30/1977 1/9/1978 1/9/1978 5/19/1993 5/19/1993 9/1/1978 1/9/1979 5/19/1993 2/7/1979 3/15/1979 3/22/1979 5/19/1993 3/22/1979 8/16/ 5/19/1993 1/30/ 3/5/1980 11/7/1980 2/16/1981 12/16/1981 12/30/1981 2/13/1981 2/13/1984 7/30/1979 1/19/1983 1/28/1983 10/26/1979 1/19/1983 1/19/1983 10/26/1979 1/19/1983 1/28/1983 3/5/1980 1/30/ 12/28/1979 12/28/1982 8/19/1983 1/28/1983 6/9/1981 10/26/1979 12/28/1982 2/17/1982 1/19/1983 1/28/1983 9/1/1983 2/13/1984 12/16/1981 2/6/1981 11/7/1980 3/15/1979 2/7/1979 2/2/1979 1/10/1979 1/9/1979 1/8/1979 1/8/1979 9/1/1978 2/27/1978 1/9/1978 8/12/1976 2/2/1979 3/15/1979 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Solubility Measurements on FC-95 Multi-Phase Exposure/Recovery Algal Assay Test Method Absorption of FC-95-14C in Rats after a Single Oral Dose Third Trimester - 1983 First Triannual Report - 1983 Third Trimester - 1982 Third Trimester - 1981 Second Trimester - 1981 First Trimester Report - 1981 First Trimester - 1982 First Quarter Report - 1980 Evaluation of the Bioconcentration Potential of FM 3422 Final Comprehensive Report on FM 3422 Biotransformation of 14C-N-Ethyl FOSE in Rats After Administration in Feed for One Week Review of Technical Report Summary Adsorption of FC 95 and FC 143 in Soil Review of Technical Report Summary Adsorptoin of FM-3422 on Soil Review of Technical Report Summary Analytical Methodology and Support Review of Technical Report Summary Final Comprehensive Report FC 95 Reivew of Technical Report Summary Adsorption of FM 3925 on Soil Review of Technical Report Summary Photolysis of FM 3422 on Soil Review of Technical Report Summary Biosoprtion of CS 2070 Biotransformation of 14C-N-Ethyl FOSE in Rats After Administration in Feed for One Week FC-95/Photolysis Study using Simulated Sunlight Final Comprehensive Report: FC 95 Multi-Phase Exposure/Recovery Algal Assay Test Method Multi-Phase Exposure/Recovery Algal Assay Test Method Adsorption of FC 95 and FC 143 on Soil Solubility Measurements on FC-95 Biodegradation Studies of Fluorocarbons - III Analytical Methodology and Support Final Comprehensive Report: FC 95 Final Comprehensive Report: FC 143 Final Comprehensive Report: FC 143 FM-3422 Photolysis Study Using Simulated Sunlight A Thesis Submitted to the Faculty of the Graduate School of the University of Minnesota By Frank Davis Gilliland 3MA10061043 3MA10061048 3MA10062597 3MA10063406 3MA10063417 3MA10063422 3MA10063430 3MA10063435 3MA10063444 3MA10063450 3MA10063480 3MA10066619 3MA10066644 3MA10070335 3MA10073686 3MA10073688 3MA10073691 3MA10073693 3MA10073695 3MA10073697 3MA10073698 3MA10074659 3MA10078173 3MA10078186 3MA10078206 3MA10078222 3MA10078238 3MA10078254 3MA10078314 3MA10078331 3MA10078353 3MA10078384 3MA10078407 3MA10078523 3M_MN03112178 3M Communications Regarding Fluorochemicals and the Cottage Grove Plant Through 1989 Notebook 1 of 7 3MA01933733 Part B RCRA Permit Application Combined Air and Hazardous Waste Permit Renewal Volume 1 Chemolite Wastewater Treatment System User's Manual Construction Completion Report D9 Area Exhibit 190 - Document regarding the adequate disposal of hydrofluoric acid containing tars Exhibit 191 - Chemolite Resources Division Chemolite Plant Facory Operating Standard Exhibit 192 - Factory Operating Procedure Exhibit 194 - Factory Experiment Exhibit 198 - Attachment 3 Typical PFOA Flowsheet Exhibit 199 - Attachment 2 Typical Flowsheet for PFOS 3M FC Committees Chart Organic Fluorine in Blood Minutes of Fluorochemical Steering Committee Meeting, 12/15/1997 Estimation of "Safe" Reference Level (ppb) of PFOS in Plasma EPA Communication Plan FDA Communications Plan Memo from C. Reich re TSCA Section 8 Decision Fluorochemical Exposure Assessment Team Meeting - 7/9/1998 Ground-Water Investigative Program at Woodbury, Minnesota MPCA PFC Lateral Team Meeting Occupational Medicine/Epidemiology Targeted (as of 10/6/99) Fluorochemical Research Publications Submitted by Geary Olsen & Jeff Mandel Perfluorobutanc sulfonate Perfluorobutane carboxylate EPA Communication Plan Meeting Notes 3M Risk Assessment Council February 11, 2000 Program HF Tars Appendix A Chemolite Incinerator Test Burn Results Appendix B Refactory Evaluation for HF Resistance Dry Run Landfill: C-8 History Summary Reference Information organic Fluorine in Blood Walk through Survey Report of 3M Company Cottage Grove, Minnesota Health Hazard Summaries and Proposed Testing Program for Several 3M Fluorochemicals 3MA00152550 3MA00288649 3MA00316856 3M_MN00716872 3MA01201775 3MA10064412 3MA00206150 3MA00057505 3M_MN00473624 3M_MN00473622 3M_MN00055518 3M_MN00055541 3M_MN00055707 3M_MN00055708 3M_MN00055709 3M_MN00055711 3M_MN00055729 3M_MN00055730 3M_MN00055783 3M_MN00055817 3M_MN00055848 3M_MN00055855 3M_MN00055856 3M_MN00055862 3M_MN00055866 3MA01201784 3MA01201787 3MA01201793 AR226-1476 3MA10067017 3MA00282171 3MA10066666 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 2/6/1981 12/16/1981 10/26/1979 12/15/1983 4/20/1983 12/28/1982 2/17/1982 8/3/1981 4/29/1981 5/12/1982 3/5/1980 8/16/1978 2/7/1979 1/28/1983 1/28/1983 1/9/1979 3/15/1979 12/16/1981 12/16/1981 2/27/1978 2/6/1981 7/19/1978 1/17/1979 3/15/1979 3/23/1979 3/23/1979 8/11/1981 Oct-92 Dec-88 9/24/1993 Mar-87 1/18/2011 12/22/1981 7/22/1993 1/26/1978 2/8/1978 12/15/1997 3/20/1998 7/9/1998 Jan-67 4/26/2005 10/6/1999 2/15/2000 7/26/1974 3/28/1973 2/8/1978 Jun-82 9/6/1994 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 SCD Strategic Plan Key Action for Obstacle #1 Attachment 2 3MA00089191 Fluorochemicals in Food Packaging 3MA01213953 Draft Issues and Trends Analysis - Redacted 3MA10072863 Draft Fluorochemicals in Human Blood - Redacted 3MA10082645 POSF Exposure Working Group Meeting Minutes February 26, 1998 Meeting 3M_MN00000502 Fluorochemical EHS&R Initiative The Business Decision Process 3M_MN00055713 Additional Information - Redacted 3MA10068892 Summary Report on the Detection of Fluorochemicals in Human Blood Samples 3MA01453966 Draft - Summary Report Fluorochemicals in Populations and the Environment 3MA01453890 Draft - General Stand by Statement 3MA02599026 Science Publication Strategy including Key Studies and Reports Available - Redacted 3MA00729193 Problem Formulation and Analysis Plan for the Fluorochemicals Ecological Risk Assessment 3MA01404217 PFOS Sera (blood) Comparisons 3MA00988684 Call Center Script: 3MA01169513 3M Fluorochemicals EHS&R Initiative Fact Sheet 3MA01932164 EHS C8 Acid Action Plan for Cottage Grove 3MA00197794 FC Issue - Investor Relations 3MA02497202 Announcement - 3M Phasing Out Some of its Specialty Materials 3M_MN00000419 Announcement - Advanced Search EPA and 3M Announce Phase Out of PFOS 3M_MN00001690 3M to Pare Scotchgard Products. Washington Post 5/16/00 3MA00723597 Background on 3M' s Phase Out of Perfluorooctane Sulfonate (PFOS) Chemistry 3MA01418356 Announcement - 3M Phasing Out Some of its Specialty Materials 3MA01620966 Announcement - 3M Phasing Out Some of its Specialty Materials 3MA02497199 Remarks - 3M Investor Teleconference, May 16, 2000 3MA02513595 Fluorochemical Chemistry, Use, Distribution And Release Overview 3MA00348502 Meeting Minutes from Fluoropolymer Manufacturers Group Meeting 06/09/00 3MA00471502 Talking Points: 3M Specialty Fluids/Gases Not Included in Perfluorooctanyl Phase-out 3M_MN00847488 Notes from discussion between Charlie Auer and American Chemistry Council 3MA00256125 Draft - Pre-Notice Communcation Concerning New Perfluoroalkylsulfonated Polymeric Surfactants 3MA01325530 PFOS Assessment Approach in OECD 3MA00256126 Phase-Out: Overview of 3M's Proposed Critical Uses to be continued beyond 12/31/00 3M_MN01095150 Annex 1 3MA00245812 Fluorochemical Initiative Environmental Status Report August 31,2000 3MA00470654 Draft SIDS Initial Assessment Report Perfluorooctane Sulfonate 3MA00721974 Unresolved Issues and Potential Research Projects Perfluorinated Compounds in the Environment 3MA00744259 Perfluoroalkyl Sulfonates; Significant New Use Rule; Final Rule and Supplemental Proposed Rule Federal Register 3MA01224627 Vol. 67, No. 47 pg. 11008 Initial Assessment Report Perfluorooctane Sulfonic Acid and Its Salts 3MA01448650 Draft Statement for Cottage Grove Workers (if needed) 3MA01146953 Draft Final Report - Descriptive Analysis of Serum PFOA and PFOS Concentrations of Antwerp Employee 3MA00411515 Participants from the 2003 Fluorochemical Medical Surveillance Program Draft Content for 3M FC Web Site 3MA02601379 PFOS Talking Points - September 2005 - Redacted 3MA01149040 Washington County Landfill containment remedy MPCA Recommended alternative 3M-BARR00008888 Remedy Feasibility Assessment, Washington County Landfill, Lake Elmo, Minnesota 3M-BARR00008945 Summary of Comments Received Washington County Landfill Remedy Selection Public Comment Period (Feb. 14 - STATE_01202590 March 15, 2008) Public Health Assessment for Perfluorochemical Contamination in Oakdale, Washington County 3M_MN00050617 FC Talking Points Summary - Investment Community Talking Points. April 2007.doc 3M_MN00381094 Communications Options 3MA00989751 Draft Content for 3M FC Web Site 3MA00990181 Perfluorooctyl Sulfonates; Proposed Significant New Use Rule 3MA01094262 Fluorochemical Customer Fact Sheet 3MA01618108 Communications Update 3MA02496618 PFBS Talking Points 3MA02526979 Geology Department, Minnesota Mining & Mfg. Co. Report No. 60-11 re: Test Borings on the Rahn Farm in 3M_MN00001422 Woodbury Township, Washington County, Minnesota Chronological History: St.Paul - Chemolite - Hutchnson Wet Scrap Disposal 3M_MN00045673 Present Operations re: 3M Company waste Materials Composition 3M_MN00048397 Waste Disposal Timeline Approximate -Dates not Verified w/ Legal - East Metro Landfill Timeline.doc 3M_MN00049958 Preliminary Assessment: Potential Exposure Pathways Related to the 3M-Woodbury Disposal Site FC Data Assessment Report Table 5-1 Off-Site Waste Disposal Locations - 3M Cottage Grove, Minnesota 3M_MN00585673 3M_MN00696962 Appendix A Chronology of Waste Excavation and Disposal Activities 3M_MN00887623 Schematic Drawing - 3M Cottage Grove Wastewater Treatment System 3M_MN00967585 Disposal Site Locations for Cottage Grove 3M_MN01000755 Investigation of Waste Disposal Areas at the 3M Chemolite Plant Cottage Grove, Minnesota - Phase I Final Report 3M_MN01010049 Phase II Site Characterization Work Plan NPDES Permit Application for CG Plant 3MA00110720 Cottage Grove Incinerator Shipout Locations 3MA00223376 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 12/14/1995 ND ND ND ND ND ND 6/12/1998 7/2/1998 11/5/1998 12/10/1998 10/27/1999 ND ND ND 5/10/2000 ND 5/16/2000 5/16/2000 5/16/2000 ND 5/16/2000 5/16/2000 5/16/2000 5/26/2000 7/16/2000 ND 6/13/2000 6/14/2000 6/15/2000 6/23/2000 ND 8/31/2000 9/1/2000 10/8/2000 3/11/2002 6/24/2002 3/10/2003 7/8/2003 7/29/2005 Sep-05 Feb-07 11/15/2007 ND 5/21/2008 ND ND ND ND ND ND Mar-04 7/22/1960 12/2/1966 ND ND 11/14/2006 ND ND ND ND Mar-82 ND ND CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Picture Log without photos Technical Information Meeting With Engineering Management on August 10, 1973 to Review the Disposal Procedure for Stockpiled Extra Hazardous Waste Chronological History Woodbury Disposal Site Meeting and Discussion at Woodbury Landfill Dump Meeting Results on Geology and Drilling Program at Woodbury Township Dump Site Authority for Expenditure: Construction of wells and pipeline to control migration of contaminated groundwater 3MA00276830 3MA00281033 3MA00282230 3MA00285902 3MA00335913 3MA00335935 3MA00337585 Hydrogeologic Investigation Phase Ill Final Report Oakdale Disposal Sites Site Background for Oakdale and Washington County Landfill Phase One Chemolite Waste Disposal Program Schematic for Waste Incineration Schematic for Waste Incineration Chronological History Woodbury Disposal Site Chronological History St. Paul - Chemolite - Hutchinson Wet Scrap Disposal Report 1 - Preliminary Evaluation of Soil and Groundwater Analytical Data and Report 2 - Proposed Work Plan for Evaluation of Drum Site Location, Chemolite Plant Analytical Results for 3M Company 3M Waste Stream Profile Program - Profile Report (w3522) for 3M Decatur Plant Oakdale Disposal Site Summary Background Information on PFOS and PFOA Oakdale Disposal Sites Hydrogeologic Investigation Phase I & II Final Report Facility-wide Fluorochemical (FC) Investigation Work Plan 3M Company, Cottage Grove, Minnesota Facility 3MA00342074 3MA00348466 3MA00456330 3MA00456379 3MA00456380 3MA00456432 3MA00456433 3MA00456836 3MA00456848 3MA00464679 3MA00511331 3MA00550095 3MA00614048 3MA00722658 Chemolite Wastewater Treatment System Qualitative Risk Analysis 3M Company Woodbury, Minnesota Site History Summary Of 3M Waste Handling Practices Waste Disposal History Cottage Grove, Minnesota Fluorochemical Characterization of Facility Wastewaters Cottage Grove Stat.4 Composites (E01-0007) Centre Analytical Laboratory Report No. L30205 Draft - 3M Cottage Grove Historic Waste Disposal PCI - Newport Site Waste Disposal Timeline Approximate - Dates not Verified w/ Legal Backgrounder - 3M Woodbury Disposal Site Waste Disposal Interview Responses of William Lundquist, 3M retired Waste Disposal Interview Responses of Delphine Noack, 3M retired Waste Disposal Interview Responses of Frank O'Neill, 3M retired Waste Disposal Interview Responses of A.E. (Tim) Raymond, 3M retired Waste Disposal Interview Responses of Norman Iverson, 3M retired Waste Disposal Interview Responses of Phil Morrow, 3M retired Waste Disposal Interview Responses of Kenneth Klein, 3M retired Waste Disposal Interview Responses of Henry Karner, 3M retired Waste Disposal Interview Responses of Harold Zeman, 3M retired Waste Disposal Interview Responses of Frank Vogel, 3M retired Waste Disposal Interview Responses of John LaBore, 3M retired Waste Disposal Interview Responses of Al Boese, 3M retired Waste Disposal Interview Responses of George Netherly, 3M retired Waste Disposal Interview Responses of Robert Harshberger, 3M retired Interview with Bob Durdin Interview with Erwin Ulrich Interview with Lloyd Johnson Waste Disposal Interview Responses of Arthur Ratecher, 3M retired Waste Disposal Interview Responses of Joe Juettner, 3M Waste Disposal Interview Responses of George Sorenson, 3M retired Waste Disposal Interview Responses of John Knowlivet, 3M retired Waste Disposal Interview Responses of Ken Keim, 3M retired Waste Disposal Interview Responses of Harold Relafeld, 3M retired Waste Disposal Interview Responses of Harold Splittstoesser, 3M retired Waste Disposal Interview Responses of Gil Gehrenbeck, 3M retired Waste Disposal Interview Responses of William Rither, 3M retired Waste Disposal Interview Responses of Harold Schon, 3M retired Waste Disposal Interview Responses of Bernard Bierski, 3M retired Waste Disposal Interview Responses of Ed Wilkerson, 3M retired Administrative Order by Consent and Response Order by Consent Investigation of Waste Disposal. Minnesota Mining & Manufacturing Company, Chemolite Plant, Washinqton County Handwritten notes from MPCA Meeting, re: Oakdale Disposal Sites Geology Department, Report No. 61-22, Supplement re: Pond Sealant study Report from 3M to Woodbury Town Board Handwritten notes captioned 'Woodburv event" Chronological History SL Paul - Chemolite -Hutchinson Wet Scrap Disposal 3MA00886671 3MA01243252 3MA01334414 3MA01830813 3MA01840761 3MA01849899 3MA01930111 3MA01946422 3MA02512645 3MA02512651 3MA02512657 3MA02512663 3MA02512666 3MA02512672 3MA02513504 3MA02599359 3MA02599365 3MA02599377 3MA02599383 3MA02599389 3MA02599401 3MA02599407 3MA02599419 3MA02599420 3MA02599421 3MA02599426 3MA02599438 3MA02599444 3MA02599450 3MA02599456 3MA02599468 3MA02599480 3MA02601663 3MA02601752 3MA02601764 3MA02601800 3MA02601842 3M-BARR00013953 3M_MN00001396 3M_MN00000337 3M_MN00000380 3M_MN00000719 3M_MN00000466 3M_MN00000382 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN ND ND 8/10/1973 12/28/1966 4/20/1961 4/28/1960 8/2/1967 Apr-83 ND Apr-62 ND ND 12/28/1966 Dec-66 ND 3/23/1983 12/6/1995 ND 8/9/2005 Mar-82 Dec-04 ND Aug-92 ND Mar-05 1/26/2001 1/26/2007 ND 11/3/1980 11/3/1980 10/31/1980 11/3/1980 10/30/1980 10/29/1980 10/30/1980 10/25/1980 11/3/1980 11/3/1980 10/30/1980 10/30/1980 10/31/1980 10/29/1980 10/29/1980 11/6/1980 11/11/1980 11/5/1980 10/30/1980 10/31/1980 10/31/1980 11/3/1980 10/30/1980 10/30/1980 11/3/1980 11/3/1980 10/30/1980 10/30/1980 10/31/1980 11/3/1980 ND 9/22/1958 10/13/1960 5/15/1962 12/2/1963 6/10/1966 12/2/1966 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Ground-Water Investigative Program at Woodbury, Minnesota 3M_MN00002251 Preliminary Evaluation Minnesota Mining and Manufacturing Co., Woodbury Open Burninq Project 3M_MN00001469 Operating Permit for Air Pollution Control Equipment 3M_MN00001503 Air Pollution Control Equipment Installation Permit 3M_MN00001522 Technical Report Summary to R.A. Prokop, 3M, re: Final Comprehensive Report: FC 95 3M_MN00000745 Technical Report Summary to B. W Nippoldt, 3M, re: 1977 Summary 3M_MN00000535 Basic 3M Position 3M_MN00000342 Oakdale Newspaper Clippings and Sound Clips 3M_MN00000391 Progress Report - December 1982. Oakdale Disposal Site Investigation 3M_MN00001623 Health Risk Assessment of Groundwater and Soil Contamination at Oakdale Disposal Sites 3M_MN00001110 Questions and Answers on the Need for the Fate of Fluorochemicals Phase II Study 3M_MN00000204 Public Notice to Oakdale Area Residents re: Notice of Oakdale City Council Meeting on 07/20/83 3M_MN00001656 Photos Taken at the Oakdale Site Groundbreaking - Redacted 3M_MN00000558 Redacted - Photos from Oakdale Cleanup 3M_MN00000560 Final Report Multi-Aquifer Well Program Oakdale Disposal Sites 3M_MN00002883 Letter to R.A. Paschke, 3M, re: MPCA Review and Approval of Final Feasibility Study Report for 3M Chemolite Site 3M_MN00001669 3M Technical Reports Pertaining to Environmental Issues of Fluorochemicals Authorization For Expenditure Executive Summary - Woodbury Disposal Site 3M Woodbury - Site Characterization Health and Safety Plan for Soil Cap Construction (Interim Remedy) 3M - Woodbury Site Soil Cap Construction (Interim Remedy) 3M - Woodbury Site Meeting Minutes Note to File re: Drums Found at Woodbury Site Waste Stream Profile Disposal Cost Optimization - SMMD Meeting Notification to Discuss Off-site Disposal Practices for PFOA Containing Wastes Waste Water Treatment Proposals 1&2 - Dehalogenation Technique for Handling FC Wastes and Oxypyrohydrolysis of FC Wastes Analytical Laboratory Report on the Analyte-specific Analysis of Fluorochemical Components in Ground Water 3M_MN00000234 3MA00263177 3MA00263553 3MA00269009 3MA00268819 3MA00268842 3MA00001054 3MA00732685 3MA00501783 3MA00858905 3m Cottage Grove Facility Health and Safety Plan Subsurface Observations Figure 2-3 Well Locations Cottage Grove Site Facility-wide Fluorochemical (FC) Investigation Work Plan 3M Company Cottage Grove, Minnesota Facility 3M_MN00714495 3M_MN00416057 3MA01462056 Analytical Report Fluorochemical Characterization of Water Samples Cottage Grove Potable Water Evaluation 3M_MN00040540 (E01-0812) Analytical Report Fluorochemical Characterization of Water Samples Cottage Grove Groundwater Evaluation (E01- 3MA01171269 1154) Construction Completion Report D1 and D2 Areas Cottage Grove Site Cottage Grove, Minnesota 3M_MN00711102 Health and Safety Plan, Carl Bolander and Sons Company 3M Cottage Grove Disposal Site Soil Removal Project 3M_MN00381356 Cottage Grove, Minnesota Excerpt From Uapproved Minutes of the Planning Commission Meeting on April 25, 2011 3M_MN00709442 Final Report PFOA and PFOS Analysis of Cottage Grove Building 25 Roofing Rock 3M_MN00705011 Final Report PFOA and PFOS Screening Analysis of Cottage Grove Building 15 High Performance Cloth Wipes 3M_MN00705140 (Revised) Projects to Investigate Fluorochemicals in the Environment - Summary List 3M_MN00047244 3M Technical Reports Pertaining to Environmental Issues of Fluorochemicals 3M_MN00047278 Excerpt on History and Literature Search of Fluorocarbons 3M_MN00047302 Fluorochemical Project with Listing of Proposed Studies to be Developed 3M_MN00047363 Summary of the Soil Adsorption Study of the Potassium Salt of Perfluorooctanesulfonic Acid 3M_MN00047423 3M Woodbury - Site Characterization 3M_MN00047462 Environmental Laboratory Status Report - FC-143 and Related Products Ecotox Work 3M_MN00047481 3M Environmental Laboratory Contract Laboratory Work Order By Sample 3M_MN00047484 Fluorochemical Fate and Effects Studies 3M_MN00047487 Environmental Testing PFOS Products 3M_MN00047545 Environmental Discussion with 3M 11/11/96 3M_MN00047548 Handwritten Notes re: 3M Discussions on Environmental Persistance 3M_MN00047550 Environmental Questions re: DuPont in Parkersburg WV 3M_MN00047606 Rough Draft of Minutes: 3M-DuPont Meetings 03/12-13/97 3M_MN00047608 Results from Analyses of Soil and Groundwater Samples from the E. I. DuPont de Nemours and Company Facility 3M_MN00047615 In Parkersburg, West Virginia Draft Guiding Principles 3M_MN00047740 Environmental Incidents Database - Environmental Spill Report re: Release of Light Water AFFF at Saint Paul 3M_MN00471667 Holman Field Hanger Figure 3 Locations of Barrel Piles and Trenches Determined from Historical Aerial Photographs at the Oakdale MN.103.0677 000043 Disposal Site Remediation Project Archive Request re: Woodbury Addendum 2 to the Feasibility Study Notes Version 3M_MN0102817 3M Environmental Laboratory Report Request re: Woodbury Soil Vapor Extraction System Emissions Measurements Remedial Investigation/Feasibility Study Woodbury Site Vol. I 3M_MN00512307 3M_MN00413595 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 1/1/1967 1/31/1968 3/10/1971 5/1/1974 3/15/1979 11/30/1977 10/16/1980 11/14/1980 1/14/1983 Jul-83 7/13/1983 7/18/1983 ND ND 12/12/1984 8/11/1986 9/15/1998 4/13/1993 9/7/1993 9/15/1995 10/4/1995 10/2/1995 ND 4/1/2004 4/10/2000 2/9/2000 May-00 12/31/2008 Dec-04 6/19/2001 8/31/2001 Jul-10 12/9/2009 4/25/2011 8/25/2008 10/30/2008 ND ND ND 2/16/1993 ND 9/28/1993 10/10/1995 11/27/1995 2/7/1996 ND 11/11/1996 11/11/1996 ND 3/13/1997 11/13/1997 ND 9/20/2007 ND 1/9/2009 ND Feb-08 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Annual Report NPDES/SDS General Storm Water Permit MNG611000 for Industrial Activity 01/01/01 to 12/31/01 3M_MN00588390 for Woodbury Site Remedial Design/Response Action Plan Woodbury Site 3M_MN00997125 Minutes of Meeting, Weekly Construction Meeting 3M Woodbury Soils Excavation Project 3M_MN00584830 Untitled Project Notebook 3M_MN01112030 Redacted - Untitled Project Notebook 3M_MN01111786 Redacted - Untitled Project Notebook 3M_MN0111898 Final Remedial Investigation Report For the 3M Chemolite Center, Cottage Grove, Minnesota 3M_MN00001758 3M Woodbury Site Characterization 3MA00115693 Sulfonated Perfluorochemicals in the Environment: Sources, Dispersion, Fate and Effects 3MA00736677 Fluorochemical Use, Distribution and Release Overview 3MA10052166 Health Consultation 3M Chemolite - Perfluorochemical Releases at the 3M Cottage Grove Facility, City of Cottage 3M_MN00044780 Grove, Washington County, Minnesota Draft - SMMD EHSR Council Meeting Minutes 05/04-05/05 3MA01080223 Comment of 3M Company on Minnesota Department of Health's Draft Public Health Assessment on 3M_MN00697933 Perfluorochemicals in Southern Washington County, Northern Dakota County, and Southeast Ramsey County, Minnesota Acute Oral Administration of L-1760 to Rats 3MA01789580 Toxicity Screening 3MA10019350 Final Comprehensive Report on FM 3422 3MA00326828 Processing Engineering Report 3MA00077017 Oral Teratology Study of FM-3422 in Rats 3MA00326722 3M Waste Inventory Form 3MA01986534 Minnesota Mining and Manufacturing Company Geology Department Report No. 61-22 3MA00335895 3M Waste Inventory Form 3MA01986536 Supplementary Engineering Report of Sludge Disposal at Chemolite 3MA00456474 Final Comprehensive Report: FC 95 3MA00176880 Hydro-hygenic Valuation of Foam-Extinguishing AGents 3M_MN03407054 3M Internal Material Safety Data Sheet Product Code F-6915 FM-3108 3MA00085087 Disposal of Existing Stockpile of HF Tars 3MA00214086 3M Waste Inventory Form 3MA01986532 Some Probable Questions on 3M Fluorochemicals with Suggested Answers 3M_MN02345159 HF Cell Tar Leachate 3M_MN00720875 Investigation of Waste Disposal Areas at the 3M Chemolite Plant Cottage Grove, Minnesota 3MA00287960 3M Waste Inventory Form 3MA01986528 Work Plan Hydrogeological Investigationm of Disposal Areas at the 3M Chemolite Plant in Cottage Grove, 3MA00067548 Minnesota Minnesota Pollution Control Agency Complaint Report 3MA00456742 1984 Chemolite Water Report WE10267950 Chemical Waste Management: Generator's Waste Material Profile Sheet 3MA00280394 Chemical Waste Management: Generator's Waste Material Profile Sheet 3MA00280402 Table I Particle Sizing 3MA00280415 Table II Approximate Chemical Composition: Chemolite Incinerator Ash 3MA00280416 Table III Aproximate Chemical Composition: Chemolite Incinerator Sludge 3MA00280417 Incinerator Slude Tables 3MA00280484 Management Plan 3MA00280512 Chemolite Leachate Analysis: D. I. Water 3MA00281135 Extended Duration Slude - Trial Burn 3MA00456964 Fluorochemical (FC) Data Assessment Report 3M Company Cottage Grove, Minnesota Facility 3MA01551778 Attachment 1 - Sulfonated Perfluorochemicals in the Environment: Sources, Dispersion, Fate and Effects 3MA00043222 Attachment 3 - Typical PFOA Flowsheet Attachment 4 - Typical PFBA Flowsheet Attachment 5 - Cottage Grove PFC Manufacturing Facility Summary of Cell Output (1976-1998) Attachment 6 - Summary of Cottage Grove PFC Production Records Attachment 8 - 3M Cottage Grove PFC Air Permitting History Attachment 9 - Bibliography of Articles within 3M's Possession Related to Fluorochemical Atmospheric Fate & Transport Attachment 10 - Cottage Grove PFC Manufacturing Plant Industrial Hygiene Sasmpling Attachment 11 - Summary of Off-Site Waste Disposal Locations CG Site Summary Report: Remedial Activities Oakdale Disposal Sites Groundwater Data Assessment Report Fluorochemical (FC) Investigation - Oakdale Site Oakdale, Minnesota 3M_MN00115548 3M_MN00115550 3M_MN00115552 3M_MN00115554 3M_MN00473762 3M_MN00473770 3M_MN00473994 3MA02525222 3MA00113074 3MA01251515 Remedial Investigation Report [Soil Supplemental Fluorochemical Data Assessment - Addendum 1] Oakdale Site Oakdale, Minnesota Picture Log without photos (Day 1) Picture Log without photos (Day 2) Construction Documentation Report for Washington County Sanitary Landfill Relocation to Lined Landfill Lake Elmo, MN Chronological History: St.Paul - Chemolite - Hutchnson Wet Scrap Disposal Activated Sludge Respiration Inhibition Test Results 3MA01777961 3MA00276829 3MA00276832 STATE_04561142 3MA00512611 3MA00000819 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 3/21/2002 Apr-09 9/2/2009 2009 2011 2010 Feb-86 9/7/1993 3/1/2000 5/26/1999 2/18/2005 5/4/2005 10/12/2010 1/21/1966 3/4/1963 2/7/1979 Feb-71 2/18/1981 1/25/1980 12/13/1961 1/25/1980 7/22/1969 3/15/1979 9/24/1973 7/16/1984 1/25/1980 8/15/1980 4/4/1984 Mar-82 11/13/1984 ND 2/12/1981 ND 9/19/1979 9/19/1979 ND ND ND ND 1/22/1979 ND ND Apr-2006 3/1/2000 ND ND ND ND ND 11/13/2007 ND ND Mar-93 Jul-05 Jun-07 ND ND Jun-13 12/1/1989 2/20/1987 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 3M Technical Notebook Project No. 75-5392 26 3M Technical Notebook Project No. 75-6398 25 3M Technical Notebook Project No. 75-6398 25 Environmental Laboratory Summary Sheet Environmental Laboratory Summary Sheet Environmental Laboratory Work Sheet Phase III Waste Sludge Pile Estimate 3M Technical Notebook Warbug Data Form Some Probable Questions on 3M Fluorochemicals with Suggested Answers 3M Company Fluorochemicals: Heptafluorobutyric Acid THIRD DRAFT FC-143 Decatur Standby Press Statement Recommendation Regarding Fluorochemical Exposure to Females of Childbearing Potential An Epidemiologic Mortality Study of Employees at the Chemolite Plant Notes and Comments on the Meeting 12 Apirl 1979 at the Airport Hilton San Francisco Animal Exposure Chart Product Environmental Assessment Report: Assment #81439 Minnesota Decision Document: 3M Oakdale Disposal Site Investigation of Perfluorochemical (PFC) Contamination in Minnesota Phase One - Report to Senate Environment Committee by F. Oliaei, D. Kirens, and K. Kessler Solid Wast Perflourochemicals (PFCs) Evaluation Solid Waste Screening for Perfluorochemicals (PFCs) Chemical Resources Division Chemolite Plant Factory Experiment re Fractionated Perfluorobutyric Acid from Totally Condensed Cell Products Chemical Resources Division Chemolite Plant Factory Experiment re Aqueous Calcium Perfluorobutyrate 3M_MN03414182 3M_MN03414192 3M_MN03414196 3MA00000786 3MA00000805 3MA00000806 3MA00456833 3MA00717480 3MA01409894 3M_MN00000174 3M_MN03109500 3MA00047947 3MA00257790 3MA00638775 3MA00967577 3MA01483426 3MA10078365 STATE_01207681 3M_MN00601534 3M_MN00697716 3MA01839154 3MA00080762 3MA01199244 Chemical Resources Division Chemolite Plant Operating Standard re Perfluorobutyric Acid 3M Plan to Assess and Remediate the Source of PFBA PFBA Facts - 3M Appendix A - Production - A.R. Diesslin: Report for March 1958 and Plans for April 1958 Fluorochemicals Production Department Report for January, 1958 from A.R. Diesslin Flurorochemical Production and Pilot Plant Report of December, 1958 from A.R. Diesslin Report on the Manufacture, Use, and Releases of PFCs at the 3M CG Facility Technical Information 3M Brand Fluorochemical Surfactants Technical Report Summary Final Comprehensive Report on FM 3422 Technical Report Summary Biodegradation Studies of Fluorocarbons Technical Report Summary Biodegradation Studies of Fluorocarbons - II Technical Report Summary Biodegradation Studies of Fluorocarbons - III Voluntary Use and Exposure Information Profile Perfluorooctane Sulfonic Acid and Various Salt Forms 3MA01207023 3MA01929873 3MA02527581 3MA00076577 3MA00076599 3MA00076636 3MA02527087 3MA01201629 3M_MN00000151 3MA01252037 3MA00717615 3MA10054929 3MA00001260 Dictation Taken from R. Susag by Phone - Points to Describe 3M Involvement with Three Sites in Oakdale 3MA01248573 Sulfonated Perfluorochemicals in the Environment: Sources, Dispersion, Fate and Effects 3M Operation Experiences with A High Temperature Kiln Final Remedial Investigation Report For the 3M Chemolite Center, Cottage Grove, Minnesota Report on Investigation of Waste Disposal, 3M Chemolite Plant, Washington County Remedial Investigation Repot Phase 2 Fluorochemical (FC) Data Assessment Report for the Cottage Grove, MN Site Monthly Operating Summary of Chemolite Plant Wet Scrap Incinerator Permit No. SW9 Site No. 8, 3M Company - Woodbury, Minnesota Construction Completion Report D1 and D2 Areas Cottage Grove Site Cottage Grove, Minnesota Construction Completion Report (RA Implementation Report) Oakland Site Construction Completion Report Former Main Disposal Area Woodbury Site MPCA Remedy Decision Document Technical Report Summary re Evaluation of the Bioconcentration Potential of FM 3422 Technical Report Summary re Final Comprehensive Report on FM 3422 Technical Report Summary re Final Comprehensive Report: FC 143 Perfluorobutyrics Acid Potassium perfluorooctanoic Report to Minnesota Mining and Manufacturing Company Acute Oral Toxicity Studies on Two Materials 3MA00045043 MN.103.1002 000165 3MA00364082 3MA00456234 3M_MN01483002 3MA00276845 3MA01946427 3M_MN01533753 3M_MN01362671 3M_MN00826383 CHARTIS00009805 3MA00326803 3MA00176727 3MA01410316 3MA02497530 3MA01828941 3MA01789595 Central Analytical Laboratory Report No. 6967 Central Analytical Laboratory Report No. 6919 Product Toxicity Summary Sheet Fluorad Brand Fluorochemical Surfactant FC-95 Rat Teratology Study T-3351 Final Report Acute Toxicity to Fish (Bluegill Sunfish) Acute Toxicity to Aquatic Invertebrates (Daphnia Magna) Acute Toxicity to Invertebrates (Grass Shrimp) Algicidal Activity Acute Toxicity to Aquatic Invertebrates (Eastern Oyster) Technical Report Summary re Fc-389 (N.B. 50633-20-4): Aquatic Testing Results 3M_MN02343995 3M_MN02343997 3M_MN02252650 3M_MN02456142 AR 226-0716 AR 226-0718 AR 226-0784 AR 226-0721 AR 226-0786 3M_MN02854547 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 9/12/1975 10/13/1975 12/8/1975 1/28/1982 6/21/1979 6/20/1979 6/13/1983 9/22/1975 10/3/1975 8/15/1980 ND 4/15/1981 4/17/1981 Feb-80 4/12/1979 ND 1/20/1982 11/4/2008 Feb-06 2008 2001 7/17/1974 10/13/1969 3/22/1974 Feb-07 Mar-58 Jan-58 Dec-56 11/30/2007 6/15/1963 2/7/1979 8/12/1976 1/9/1978 7/19/1978 4/27/2000 12/8/1980 3/1/2000 ND Feb-86 9/22/1958 Jun-07 Jun-78 8/11/1980 Jul-10 Dec-11 Jun-10 6/18/2008 8/16/1978 2/7/1979 3/23/1979 1/10/1950 6/2/1954 9/21/1966 8/4/1978 5/16/1978 6/5/1992 12/19/1983 6/27/2000 6/27/2000 6/28/2000 6/27/2000 6/28/2000 3/22/1979 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Technical Report Summary re FC-5152 cc 7810-3: Results of Aquatic 96-Hr. LC50 Tests Fate of Fluorochemicals - Phase II Chronology - Fluorochemicals in Blood Geology Department Report No. 60-11 Authority of Expenditure Chemolite Sludge Dewatering Facility Chemolite Monthly Water Report Report No. 1 Progress Report on Ground Water Problem Woodbury, Minnesota Ground-Water Investigative Program at Woodbury, Minnesota Engineering Report on Waste Water Treatment and Disposal Facilities Technical Report Summary Final Comprehensive Report on FC 143 Technical Report Summary Final Comprehensive Report on FC 95 Technical Report Summary Analysis for Fluorochemicals in Blugill Fish Incident Report Chemolite enter Foaming From Chemolite Wastewater Effluent Report re Discussion of Chemolite Wastes with Mr. Johannes of the State Water Pollution Control Board 3M_MN02854512 3MA10065465 3MA10035028 3M_MN00001421 3MA00456507 3M_MN00052163 3MA00335191 3MA00286007 3MA00456411 3MA01410327 3MA10066577 3M_MN01639704 3MA00293930 3MA00456233 Status of Investigative Study Relating to an Industrial Waste Dump in Oakdale Minn. Remedial Actions to Alleviate Groundwater Pollution from a Former Industrial Waste Disposal Site Authorization to Discharge and the Construct Wastewater Treatment Facilities Under the National Pollutant Discharge Elimination System and State Disposal System Permit Program Authorization to Discharge and the Construct Wastewater Treatment Facilities Under the National Pollutant Discharge Elimination System and State Disposal System Permit Program US EPA Application for Permit to Discharge Wastewater Hazardous Waste Generator Inspection Report State Enforcement sheet Laboratory-Scale Thermal Degradation of Perfluoro-octanyl Sulfonate and Related Substances Incineration of Fluorochemicals with Perfluorooctanesulfonyl Moities Central Analytical Laboratory Report No. 7230 Products of incomplete combustion of POSF Based Fluorochemicals Bacon, Exhibit 01 - Interim Technical Report on Environmental Product Assessment of "Light Water" Agent 3M_MN00001391 3MA00296731 3MA00277403 MN.103.0969 000096 3MA00110772 3MA00296025 3MA00370749 3M_MN04748576 3M_MN04748860 3MA00639014 3M_MN04735973 3M_MN01235783 Bacon, Exhibit 02 - Technical Report Summary re Fate of Fluorochemicals in the Environment 3M_MN03424083 Bacon, Exhibit 08 - Technical Report Summary re Decatur, Alabama - Tennessee River Fish 3MA01409559 Bacon, Exhibit 09 - Technical Report Summary re Fate of Fluorochemicals 3MA01406743 Bacon, Exhibit 14 - An Introduction to Perfluorooctanesulfonic Acid and Its Salts 3MA00347660 Bacon, Exhibit 20 - Canadian Environmental Protection Act, 1999 (CEPA 1999):Ecological Screening Assessment 3MMN02513116 Report on Perfluorooctane Sulfonate Bacon, Exhibit 26 - Cost-benefit analysis of repeating the chronic study of the potential effects of 3MA02513752 PFOS on reproduction in quail Falco, Exhibit 05 - Environmental Matters and Litigation CHARTIS00021031 Falco, Exhibit 14 - FC Emisson Reduction Management Team 3M_MN02998909 Falco, Exhibit 22 - Port St. Lucie, Florida Water Resample andArea Investigation for the Empirical Human Exposure 3M_MN02375068 Assessment Multi-City Study Falco, Exhibit 26 - Acute Toxicity to Fish 3M_MN03641067 Falco, Exhibit 27 - FC Core Team 2004 - 2005 Project/Process Priorities 3M_MN00838661 Reiner, Exhibit 05 - Technical Report Summary re Commercial Chemical Division 3MA00467579 Reiner, Exhibit 06 - Chart 3MA10078794 Reiner, Exhibit 07 - Products of incomplete combustion of POSF Based Fluorochemicals 3MA01412201 Reiner, Exhibit 08 - Notes from the Environmental Science Information Meeting 3/8-9/00 3MA02512845 Reiner, Exhibit 12 - Technical Information AFFF FC-783 3M_MN02369894 Reiner, Exhibit 14 - Exposure Assessment Team 3MA01405574 Reiner, Exhibit 16 - FC Exposure Assessment Plan 3M_MN00046323 Expert Report of Charles Andrews Interim Report #2: Determination of Serum Half-Lives of Several Fluorochemicals AR226-1086 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 1/17/1979 5/20/1983 8/26/1977 7/22/1960 10/23/1970 11/3/1960 4/30/1969 Jan-67 Dec-65 3/23/1979 3/15/1979 5/1/1979 9/10/1984 8/26/1958 10/28/1980 9/30/1984 9/27/1985 6/6/1977 2/5/2002 6/24/1987 5/30/1989 7/3/2003 10/4/1979 9/30/1999 1/30/1973 1/9/1978 5/22/1979 6/23/1980 11/18/2003 Jun-16 1/24/2001 9/1/1983 6/2/1999 9/22/2017 1/11/2002 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 ATTACHMENT 2 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN K irk W. B row n, Ph.D . Biographical Data Principal Consultant; KW Brown, Environmental Consultant Bom: July 3, 1940; Bethlehem, PA Citizenship: U.S.A. Marital Status: Married No. of Children: 3 Education Ph.D., Agronomy, University of Nebraska, 1969 M.S., Agronomy/Plant Physiology, Cornell University, 1964 B.S., Agronomy, Delaware Valley College, 1962 Areas of Expertise Fate and Movement of Salt, Oil, Metals, Organic Chemicals, Gases, Nutrients, Pesticides and Pathogens in Soil, Air and Groundwater Environments; Remediation of Metal and Organic Chemical Contaminated Soils and Groundwater; Leachability and Translocation of Metals and Organic Chemicals in the Soil Profile; Fixation and Stabilization of Metals in the Environment; Characteristics of Hazardous and Municipal Wastes; Industrial Waste Stream Identification; Classification and Fingerprinting of Waste Materials; Disposal of Municipal, Industrial, and Hazardous Waste by Land Treatment and Landfilling; Land Treatment of Sewage Sludge, Industrial Wastewater and Sludge; Bioremediation of Polluted Soils; Vapor Extraction of Soils; Toxicity and Risk-based Assessment of Soil Contaminants to Plants and Animals; Flux o f Volatile Chemicals in Air; Air Dispersion Modeling; Influence of Chemicals on the Permeability of Landfill Liners; Sources and Transport o f Methane; Composting o f Municipal and Hazardous Waste; Design and Operation of Septic Systems; Nonpoint Source Pollution; Expansive Properties of Clay Soils; Soil Solution Sampling; Fate of Mutagenic Compounds in Soil; Mold and Fungal Growth; Reclamation of Drastically Disturbed Lands; Aerial Photo Interpretation; Soil Use and Suitability Classification; Agricultural Water Use Efficiency; Crop Water Stress; Golf Green and Athletic Field Construction; Use of Windbreaks; Soil Crusting; Gas Movement in Soil. A cadem ic Professor Emeritus, Soil and Crop Sciences, Texas A&M University, 2001-Present. Professor, Soil and Crop Sciences, Texas A&M University, 1981-2001. Associate Professor, Soil and Crop Sciences, Texas A&M University, 1973-1981. Assistant Professor, Soil and Crop Sciences, Texas A&M University, 1970-1973. Visiting Scientist, Center of Plant Physiological Research, Wageningen, Netherlands, August, 1969-July, 1970. Research Assistant, University of Nebraska, June, 1965-December, 1969. Teaching Assistant, Cornell University, September, 1964-June, 1965. COURSES TAUGHT Soil Physics (Undergraduate Course No. 445) 1970-2001. The practical aspects of soil texture, structure, water management, as well as the theoretical aspects of soil water potentials, and the movement of water, ions, gas, and heat in the soil. Advanced Soil Physics (Graduate Course No. 617) 1970-1988. An in-depth study of the physical properties of soil including basic principles which regulate the dynamics of soil, water and ion movement, soil aeration, and soil thermal relationships. Equations describing these processes are presented and references to current literature are provided for outside reading. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Reclamation of Drastically Disturbed Lands (Graduate Course No. 615) 1979-1986. Concepts influencing the reclamation, revegetation, and establishment of a stable ecological system on lands that have been drastically disturbed by strip mining, severe erosion, or toxic waste contamination. Land Disposal of Wastes (Graduate Course No. 616) 1987-2001. The theoretical and practical aspects of the land treatment and landfilling of a wide range of municipal, industrial, and hazardous wastes. Emphasis has been placed on the fate and mobility of various waste constituents in the soil and the influence of soil physical and chemical properties on constituent fate. Short Courses Taught Soil Science Institute (One month course) 1984, 1986, 1992, 1993 Land Treatment of Industrial Waste - Chemical Engineering Society, 1982, 1983. Landfill Liner Design, University of Texas - 1986, 1987. Society Memberships American Society of Agronomy, 1970-2001 Soil Science Society of America, 1970-2001 American Chemical Society, 1970-2001 International Society of Soil Science, 1970-2001 Editorial Board Environmental Engineering Science, formerly Hazardous Waste and Hazardous Materials. 1989-2001. Reviewed Papers For Soil Science Society of America Proceeding; Soil Science, Journal of Environmental Quality; Environmental Engineering Science, formerly Hazardous Waste and Hazardous Materials; ATSDR; American Petroleum Institute; Water, Air & Soil Pollution; Waste Management & Research, Water Pollution Control Federation; Water Research; Waste Management; Journal of Hazardous Materials; Archives of Environmental Contamination and Toxicology. Elected Positions Chairman, ASA Section A5, 1989-90 General program chairman for ASA meetings, 1973 Chairman, ASA Section A3, 1972 Committee Appointments National Academy of Sciences, National Research Council Committee on Environmental Technologies Subcommittee on Landfills (1995-1998). EPA Review for Risk Assessment for Petroleum Industry Hazardous Waste Listing Determination (Sept 1995). Environmental Geosciences Advisory Committee of the American Geological Institute representing the Soil Science Society of America (1993-2000). National Academy of Sciences (NRC) Committee on Remedial Action Priorities for Hazardous Waste Sites (1991-1994). Texas Natural Resource Conservation Commission Committee on rules on Wastewater Treatment Plant Sludge, Water Treatment Plant Sludge and Septic Tank Sludge Disposal (1992-1993). Texas Water Commission Committee to Develop Regulations on the Land Application of Sewage Sludge (1992-93). Faculty of Toxicology Executive Committee, Texas A&M University (1990-93). Texas Governor's Infrastructure Committee on Free Trade (1991). Oklahoma Corporation Commission on Land Application of Oil Field Drilling Waste (1990-1991). Texas Department of Health Ad Hoc Committee for Revising the Construction Standards for On-Site Sewage Facilities (1989-90). EPA Hazardous Waste Center Review Panel (1988). CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN National Science Foundation, Environmental Engineering Div., Review Panel (1987-1995). Texas Dept. of Health Septic Disposal Regulations Revision Panel (1987). Advisory Panel to Chicot Aquifer Management Project (Louisiana). McNeese State University, LA (1987-1990). ASA Editorial Committee "Reaction and Movement of Organic Chemicals in Soils" 1987. Advisory Panel to U.S. Congressional Office of Technology Assessment (OTA) on An Assessment of the Effectiveness of the EPA in Identifying, Prioritizing and Cleaning Up Hazardous Waste Sites (1987-1995). Organizing Committee for SSSA Workshop on Utilization, Treatment and Disposal of Waste on Land (1985). Panel to Write Research Needs for Hazardous Wastes Treatment and Disposal for National Science Foundation. Drexel University, PA (1986). EPA Technical Advisory Panel on the Adequacy of Ground Water Monitoring at Hazardous Waste Landfills (1985). Panel to Write the Mutagenicity Sample Preparation Protocol for EPA (1984). EPA Panel to Review the Acceptability of Landfill Disposal of Sewage Sludge (1984). Office of Water Regulations and Standards Committee on Municipal Sludge Landfilling to Advise EPA on the Pollutants which should be Regulated for Various Disposal Options and the Methods or Procedures to be Used for Regulating such Pollutants (1984). Advisory Panel to U.S. Congressional Office of Technology Assessment (OTA) to Determine the Effectiveness of Current Programs to Clean Up Uncontrolled Hazardous Waste Sites (1983-84). EPA Science Review Panel for Environmental Engineering Research Grants (1982-1998). United States Environmental Protection Agency Land Treatment Task Force (1981-1985). Significant Reports Resulting from Committee Assignments National Research Council. 1999. "Groundwater & Soil Cleanup, Improving Management of Persistent Contaminants". National Research Council. 1994. "Ranking Hazardous Waste Sites". Office of Technology Assessment, Congress of the United States of America. 1989. "Coming Clean, Superfund Problems Can be Solved". Office of Technology Assessment, Congress of the United States of America. 1985. "Superfund Strategy". University Committees Texas A&M University Environmental Safety and Health Committee (1987-90). Council of Principal Investigators, Texas A&M University (1986-1990). Texas Agricultural Experiment Station 5-Year Planning Board. Texas A&M University Faculty Forum (1979-82). Texas Agricultural Experiment Station Grant Support Committee (1976-77). Awards Texas A&M University College of Agriculture Award for Excellence in Teaching (1995) Texas A&M University System Award for Excellence in Graduate Teaching (1988) ASA Environmental Quality Research Award (1988) Fellow - Soil Science Society of America (1987) Fellow - American Society of Agronomy (1986) Distinguished Alumni Award, Delaware Valley College (1986) Superior Achievement Award for Research, Soil and Crop Sciences Department, Texas A&M University (1986) Pollution Engineering Magazine Award of Merit for Outstanding Editorial Contribution "The Case for Aboveground Landfills" (1984) Books Authored Hazardous Waste Land Treatment. 1983. Butterworth Publishers, 10 Tower Office Park, Woburn, MA 01801. Reactions and Movement o f Organic Chemicals in Soils. 1989. Sawhney, B. L. and K. W. Brown. SSSA/ASA Publishers, SSSA Special Publication No. 22, 494 pgs. Professional Experience Outside the United States Visiting Scientist at Center of Plant Physiological Research,Wageningen (1969-70). CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Testimony Before Legislative Bodies Texas House of Representatives - Environmental Affairs Committee, April 1987. Testified on the need for legislation to set up a waste management plan for the state. Texas Governor's Taskforce on Oil Spills, February 1985. Testified on the fate of oil spill debris and disposal technology options. Texas Governor's Taskforce on Hazardous Waste, November 1984. Testified on the effectiveness of landfills for disposal technology. Texas Governor's Taskforce on Hazardous Waste, June 1984. Testified on the impact of organic chemicals on the permeability of soils. U.S. House of Representatives - Science and Technology Committee, November 1982. Testified on the adequacy of EPA's liquid management system to protect groundwater at hazardous waste landfills. Texas House of Representatives - Environmental Affairs Committee, April, 1982. Testified on the impact of organic chemicals on the permeability of clay liners. Consulting Founder and President of K. W. Brown and Assoc., Inc., (1980- 1991). Chief technical consultant to K. W. Brown Environmental Services (1991-1999), SI Group, LP (2000-2009), TTI Environmental Consultants (2009-2011), and as an independent consultant (2011-Present). Past consulting activities have included assignments with Dupont, Alcoa, General Motors Corporation, Minnesota Mining & Manufacturing, WR Grace, Owens Corning, Union Pacific Railroad, Chevron, Shell, Exxon, Texaco, Arco, Sunoco, El Paso Products, New York Attorney General's Office, Illinois Attorney General's Office, Minnesota Attorney General's Office, Minnesota Pollution Control Administration, U.S. EPA, U.S. Army Corps of Engineers, and U.S. Dept. of Justice. Consulting activities have included consultations on the cleanup and disposal of wastes, the impacts of hazardous waste on the environment, assessment and remediation of exploration and production releases, the design of hazardous waste landfills and solid waste management units, and the fate and mobility of chemicals in the soil, groundwater, and air, as well as, providing expert testimony at permit hearings, mediation hearings, civil suits, and before legislative bodies on these topics. My expertise has been utilized for site assessments, data review and interpretation, the study of fate and transport of contaminants in the environment, waste management activities, historical oilfield and landfill operations, and other related environmental matters. I have reviewed and interpreted a large quantity of analytical data for air, soils and groundwater, as well as boring logs, field logs, technical reports, and other information related to the environmental conditions of a site. I have prepared and reviewed remedial action plans for hundreds of sites including sites contaminated with metals, organic chemicals, pesticides, biological pathogens and petroleum production wastes. I have designed and implemented remedial actions at numerous hazardous waste sites under the auspices of both state and federal regulatory authorities. As a consultant, I have evaluated or analyzed hazardous substances in industrial waste streams from numerous industries including the lumber and paper industries, the printing industry, chemical manufacturing industry, petroleum exploration, production, processing and refining industries, plastics and rubber products industry, leather tanning and finishing, metal smelting and finishing, electric utilities, and the electronic components manufacturing industry, among others. I have conducted extensive research on the hazardous substances contained in municipal and household waste with a special emphasis on the fate and mobility of these constituents in the environment after disposal in municipal solid waste landfills. I have provided evaluations and assessments for numerous waste disposal and landfill sites including the following: Love Canal Landfill, Lowrey Landfill, Helen Kramer Landfill, Junker Landfill, Lemberger Landfill, Laurel Park Landfill, Beacon Heights Landfill, RCA-Buzby Landfill, Valleycrest Landfill, Boarhead Farms, Pennsauken Landfill, Lone Pine Landfill, Ft. Bend County Landfill, and Sinton Landfill, among others. In addition, I have also provided expert testimony for civil actions involving the following Superfund sites: Hardage Criner, Montana Pole, National Gypsum, Brio/Dixie Oil Processors, Sikes' Pits, Turtle Bayou, Metal Bank of America, Tar Creek, and the West Dallas Lead Site. Guest Lectures Dewatering of confined dredge spoil areas. In: Second International Symposium on Dredging Technology. BHRA Fluid Engineering, Cranfield, Bedford, England. Paper G1:1-24. (1977). CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Revegetation of drastically disturbed lands. Texas A&M Lignite Symposium. April 17-18. (1980). Impact of surface mining on water quality. Texas A&M Lignite Symposium, April 17-18, 1980. Factors influencing the biodegradation of API separator sludges applied to soils. Presented at the Seventh Annual Research Symposium at Philadelphia, PA. March 16-18, 1981. Land treatment of industrial hazardous wastes. Presented at a Symposium and Workshop on Hazardous Waste Management. Louisiana State University, November 16-20, 1981. Effect of organic chemicals on clay liner permeability. A review of the literature. Presented at the Sixth Annual Research Symposium at Philadelphia, PA. 1981. Land disposal of oily wastes. Brest, France. August, 1982. Influence of organic liquids on the permeability of clay soils. Harwell, Great Britain. July, 1982. Use of sewage effluent for irrigation. Adelaide, Australia. June, 1982. Influence of organic liquids on the integrity of liners to pits, ponds, lagoons and landfills. Waste Water Analysts Assoc., Houston, TX. November, 1982 Reclamation of strip mined lands. Sierra Club, Austin, TX. November, 1982. Waste disposal on range land. Range Science Department, Texas A&M University. College Station, TX. November, 1982. The politics of hazardous waste disposal. Political Science Department, Texas A&M University. College Station, TX. October, 1982. The treatment and disposal of hazardous, industrial and toxic waste. American Society of Civil Engineers, Austin, TX. September, 1982. Effect of organic fluids on the permeability of clay soil liners. Presented at the Eighth Annual Research Symposium at Ft. Mitchell, Ky. March 8-10, 1982. The fate of mutagenic compounds when hazardous wastes are land treated. Presented at the Eighth Annual Research Symposium at Ft. Mitchell, Ky. March 8-10, 1982. The influence of chemicals on the permeability of clay liners. Presented at Hazardous Waste Conference, Chicago, Ill. June 28-29, 1983. Cleanup of chemicals spilled on soils. Presented at the Texas Agricultural Extension Service Conference, Houston, Texas. June 23, 1983. The reclamation of strip mined land. Presented at Texas Environmental Coalition in Austin, Texas Jan. 22, 1983. The influence of selected organic liquids on the permeability of clay liners. In: D. W. Shultz (ed). Land Disposal, Incineration, and Treatment of Hazardous Waste. Proceedings of the 9th Annual Research Symposium at Ft. Mitchell, Ky. May 2-4, 1983. Panel on land treatment of sewage sludge. EPA Workshop on Sewage Disposal, Denver, CO. March 1983. Land disposal of hazardous liquids. Waste Management Conference, Houston, TX. February 1983. Alternatives to land disposal of waste. Dept. of Agriculture Seminar, University of Houston. Sept. 10, 1984. How to write a successful research proposal. Soil Science Graduate Seminar, Soil & Crop Sciences Dept, Texas A&M University, Sept. 19, 1984. The advantages of above ground disposal. Waste Tech Conference, Houston, October 30, 1984. Potential groundwater implications of surface storage of toxic substances. Groundwater Symposium, Gunter Hotel, San Antonio, Texas. October 30, 1984. Clean up of spills; Alternative disposal methods. Geotechnical Engineering for Waste Disposal Symposium, University of Texas, Austin. November 2, 1984. The properties of soils and containment of waste. Environmental Engineering Seminar, Civil Engineering Dept., Texas A&M University, College Station, 1984. Carbon dioxide flux at the earth's surface. Texas A&M University, College Station, February 1984. Above ground landfills in hazardous waste management schemes. National Conference and Exhibition on Hazardous Waste and Environmental Emergencies. Houston, Texas, March 1984. Fate of mutagens applied to soil. Environmental Toxicology and Pharmacology Seminar. Texas A&M University, College Station, March, 1984. Permeability of compacted soils to solvents mixtures and petroleum products. Presented at the Tenth Annual Research Symposium at Cincinnati, Ohio, April 1984. Simulation of Potential Rainfall Conservation from Two Cross-Diked Furrow Bed Designs. Texas A&M University, College Station. February 1984. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN The soil scientist as a consultant. Soil Science Graduate Seminar, Panel Discussion. Soil & Crop Sciences Dept, Texas A&M University, Sept. 12, 1984. Land disposal of hazardous waste. Agricultural Engineering Dept. Graduate Seminar, Agricultural Engineering Dept., Texas A&M University. Sept. 13, 1984. Geotechnical engineering for waste disposal projects. University of Austin, Texas, October 1985. Monitoring the unsaturated zone. Presented at the National Specialty Conference. Land Treatment: A Hazardous Waste Management Alternative, April 16-18, 1985, Austin, Texas. Ability of sorbents to retain liquids in landfills, 10th Annual American Organization of Analytical Chemists' Spring Workshop, Dallas, Texas April, 9-11, 1985. Geotechnical engineering for waste disposal projects. University of Austin, Texas, October 1986. Potential health effects of hazardous waste contaminants in groundwater. Public Health Grand Rounds, University of Pittsburgh Graduate School of Public Health. January 23, 1986. Geotechnical engineering for waste disposal projects. University of Texas, Austin, October 1986. Influence of organic liquids on the hydraulic conductivity of soils. University of Cambridge, United Kingdom. September 9-11, 1987. Design and construction of the growth media in golf greens, Montreal, Canada, 1987. Groundwater pollution problems associated with fertilizers, pesticides, and leaking storage tanks. Pro Show, Dallas, November 1987. Mutagenic testing of hazardous waste sites. Southwest Environmental Mutagenic Society, Houston, November 1987. The use of lime for waste disposal and treatment of hazardous waste contaminated sites. National Lime Association, Phoenix, AZ, April 1987. A soil scientist as an expert witness - Presented to the Soil Survey and Land Resource Workshop. February 19, 1988. Guest lecture to Rio Brazos Audubon Society - May 2, 1988. Presentation to the Texas Association of Milk, Food and Environmental Sanitarians, June, 1988. Guest lecture to Range Science Ecology and Land Use class. Dept. of Range Science, Texas A&M University, Nov. 18, 1988. Hazardous Waste: A general overview. Agricultural Engineering, Environmental and Water Resources Engineering and Texas Water Resources Institute Seminar, Texas A&M University, College Station, TX. January 1989. The need for community recycling. Environmental Organization, Civil Engineering Dept., Texas A&M University, College Station, TX. February 1989. Superfund sites: The problems and the solutions. Industrial Hygiene Seminar, Texas A&M University, College Station, TX. February 1989. Hazardous waste disposal on the Gulf Coast Texas. Texas ASA Annual Meeting. Galveston, Galveston County, Texas, February 1989. New technologies for liners - Presented at the Conference on Prevention and Treatment of Groundwater and Soil Contamination in Petroleum Exploration and Production. Calgary, Alberta, Canada, May 9-12, 1989. Guest Lecture to Range Science Ecology and Land Use Class: Dept. of Range Science, Texas A&M University, College Station, TX. Oct. 4, 1989. Ongoing and future research in the geowaste area. Presented to the Geo Waste Group Meeting, Civil Engineering Dept. Texas A&M University, Nov. 1, 1989. Waste disposal: where do we go from here? Presented to the MSC Great Issues: Environmental Symposia. Texas A&M University, College Station. Nov. 7, 1989. Innovative technologies from the 1990s in environmental matters. Presentation to South Texas College of Law Environmental Law Symposium, January 17, 1990. Waste disposal, past, present, and future. Presented at the seminar entitled "Disposing of Hazardous Materials". MSC, Texas A&M University, College Station, TX January 1990. Panel discussion session at Vertisol Management Workshop: International Collaboration in Research, Training and Extension. Texas A&M University, College Station, June 25-29, 1990. Municipal waste disposal - where do we go from here. Presentation to Texas Environmental Action Coalition, Texas A&M University, College Station, TX. Sept. 5, 1990. Presentation to the Texas Section of American Society of Agricultural Engineers, College Station, TX. October 11, 1990. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Presentation on golf green construction at Canadian Golf Superintendents Association Conference, Montreal, Canada. Dec. 11, 1990. Environmental Soil Science and Technology. Presentation to the 1991 Texas Agric. Experiment Station Conference - Environmental Soil Science Session, College Station, TX. January 1991. Movement of pesticides to groundwater. Presentation to the Texas Association of Agricultural Consultants. Austin, Texas, January 21, 1991. Movement of pesticides to groundwater. Presentation to the Texas Agricultural Extension Service Conference for Producers, Austin, TX, January 25, 1991. Pesticide rinsate disposal options. Presentation to the Research Center Administrators Society meeting, Dallas, Texas February 3-5, 1991. Movement of pesticides to groundwater. Presentation to the Texas Agricultural Extension Service Conference for Grounds Keepers. Round Rock, Texas, February 21, 1991. Liners for Hazardous Waste Sites. Presented at the Hazardous Waste Management Division's Lecture Series. U.S. Environmental Protection Agency, Region 6, 1445 Ross Ave., Suite 1200, Dallas, TX. 1991. Decontamination of polluted soils. Presented at the Second International Conference on the Biogeochemistry of Trace Elements, Taipei, Taiwan, Republic of China. Sept. 5-10, 1993. Using plants to reclaim contaminated sites. Crop Science Seminar. Soil & Crop Sciences Dept., Texas A&M University, College Station, TX, October 24, 1994. Vadose zone modeling of the fate and movement of volatile contaminants, Geological Society of America, South central Section Conference, Austin, TX, March 12, 1996. Banning of liquid wastes from landfills - development of the technical data and the regulations, South Texas Environmental Conference, Corpus Christi, TX, March 29, 1996. The science behind RCRA/CERCLA enforcement (Part II), Science For Environmental Attorneys, Denver CO, November 6, 1997. Scientific Publications 1. Allen, L. H. and K. W. Brown. 1965. Shortwave radiation in a corn crop. Agron. J. 57:575-580. 2. Brown, K. W. and W. Covey. 1966. The energy budget evaluation of the micrometeorological transfer processes within a corn field. Agri. Meteoro. 3:73-96. 3. Brown, K. W. and L. J. Wright. 1967. Comparison of momentum and energy balance method of computing vertical transfer within a crop. Agron. J. 59:427-432. C701. 4. Brown, K. W. and N. J. Rosenberg. 1968. Errors in sampling and infrared analysis of CO2 in air and their influence in determination of net photosynthetic rate. Agron. J. 60:309-311. 5. Brown, K. W. 1969. A model of the photosynthesizing leaf. Phys. Plant 22:620-637. 6. Brown, K. W. and N. J. Rosenberg. 1969. Computer program for plotting time dependent meteorological data. Agric. Meteoro. 6:463-464. 7. Brown, K. W. and N. J. Rosenberg. 1970. Concentration of CO2 in the air above a sugar beet field. Mo. Weather Rev. 98:75- 82. 8. Brown, K. W. and N. J. Rosenberg. 1970. The influence of leaf age, illumination and upper and lower surface differences on stomatal resistance of sugar beet (Beta vulgaris) leaves. Agron. J. 62:20-24. 9. Brown, K. W. and N. J. Rosenberg. 1970. The effect of windbreaks and soil water potential on stomatal diffusion resistance and photosynthetic rate of sugar beets (Beta vulgaris). Agron. J. 62: 4-8. 10. Brown, K. W. and N. J. Rosenberg. 1970. Energy and CO2balance of an irrigated sugar beet (Beta vulgaris) field in the Great Plains. Agron. J. 63:207-213. 11. Brown, K. W. and N. J. Rosenberg. 1970. Shading inverted pyranometers and measurements of radiation reflected from an alfalfa crop. Water Res. Res. 6:1782-1786. 12. Rosenberg, N. J. and K. W. Brown. 1970. Improvements in the van Bavel-Myer automatic weighing lysimeter. Water Res. Res. 6:1227-1229. 13. Briggs, W. W., A. R. Edison, J. D. Eastin, K. W. Brown, J. W. Marenville, and M. D. Clegg. 1971. Photosynthesis light sensor and meter. Ecology 52:125-131. 14. Brown, K. W. and N. J. Rosenberg. 1971. Turbulent transport and energy balance as affected by a windbreak in an irrigated sugar beet (Beta vulgaris) field. Agron. J. 53:351-355. 15. Brown, K. W. and N. J. Rosenberg. 1971-2. Shelter-effects on micro-climate, growth and water use by irrigated sugar beets in the Great Plains. Agric. Meteoro. 9:241-263. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 16. Brown, K. W. and N. J. Rosenberg. 1973. A resistance model to predict evapotranspiration and its application to a sugar beet field. Agron. J. 65:341-347. 17. Duble, R. L. and K. W. Brown. 1973. Environmental concerns for the golf superintendent. USGA Green Section Record. 11:10-13. 18. Brown, K. W. 1974. Calculations of evapotranspiration from crop surface temperature. Agric. Meteoro. 14:199-209. 19. Holder, C. B. and K. W. Brown. 1974. Evaluation of simulated seedling emergence through rainfall induced soil crusts. Soil Sci. Soc. Amer. Proc. 38:705-710. 20. Brown, K. W., C. J. Gerard, B. W. Hipp and J. T. Ritchie. 1974. A procedure for placing large undisturbed monoliths in lysimeters. Soil Sci. Soc. Amer. Proc. 38:981-983. 21. Rosenberg, N.J. and K. W. Brown. 1974. "Self-checking" psychrometer system for gradient and profile determinations near the ground. Agric. Meteoro. 13: 215-226. 22. Spotts, J. W. and K. W. Brown. 1975. A technique for installing induction coils in a profile with minimum soil disturbance. Soil Sci. Soc. Amer. Proc. 39: 1006-1007. 23. Jordan, W. R., K. W. Brown and J. C. Thomas. 1975. Leaf age as a determinant in stomatal control of water loss from cotton during water stress. Plant Physiol. 56:595-599. 24. Brown, K. W. and R. L. Duble. 1975. Physical characteristics of soil mixtures used for golf green construction. Agron. J. 67:647-652. 25. Brown, K. W. 1975. A device for isolating soil columns with minimum disturbance. Soil Sci. Soc. Amer. Proc. 39:1008-1009. 26. Brown, K. W. and N. J. Rosenberg. 1975. Annual windbreaks boosts yields. Crop and Soils Magazine. p. 8-11. Apr-May, 1975. 27. Brown, K. W. 1976. Chapter II. 3. Sugar beet and potatoes. In: Vegetation and the Atmosphere. (J. L. Monteith, ed.). Academic Press, NY. p. 65-86. 28. Thomas, J. C., K. W. Brown and W. R. Jordan. 1976. Stomatal response to leaf water potential as affected by preconditioning water stress in the field. Agron. J. 68:706-708. 29. Deuel, L. E., Jr., K. W. Brown, F. C. Turner, D. G. Westfall and J. D. Price. 1976. Persistence of Propanil, DCA, and TCAB in soil and water under flooded rice culture. JEQ 6:127. 30. Brown, K. W., W. R. Jordan and J. C. Thomas. 1976. Water stress induced alteration in the stomatal response to leaf water potential. Phys. Plant. 37:1-5. 31. Chaudhari, K. G., K. W. Brown, and C. B. Holder. 1976. Reduction of crust impedance to emergence by the addition of manure. Soil Sci. 122:216-222. 32. Deuel, L. E., Jr., F. C. Turner, K. W. Brown and J. D. Price. 1977. Persistence and factors affecting dissipation of molinate under flooded rice culture. JEQ 7:373-377. 33. Brown, K. W. 1977. Chapter 19. Shrinking and swelling of clay, clay strength and other bulk properties of clay soils and clays. In Minerals in Soil Environments. (J. B. Dixon and S. B. Weed eds.). Soil Sci. Soc. of Amer., pp. 680-707, Madison, WI. 34. Brown, K. W., R. L. Duble and J. C. Thomas. 1977. Nitrogen losses from golf green, USGA Green Section Record. 15:5-7. 35. Brown, K. W., F. C. Turner, J. C. Thomas and M. E. Keener. 1977. Water balance of flooded rice paddies. J. of Agr. Water Use 1:277-291. 36. Deuel, L. E. Jr., K. W. Brown, J. D. Price and F. C. Turner. 1977. Persistence of carbofuran and its metabolities, 3-keto and 3-hydroxy carbofuran, under flooded rice culture, JEQ 8:23-26. 37. Brown, K. W., R. L. Duble and J. C. Thomas. 1977. Influence of management and season on fate of N applied to golf greens. Agron. J. 69:667-671. 38. Brown, K. W. and L. J. Thompson. 1977. Dewatering of Confined Dredge Spoil Areas. Second International Symposium on Dredging Technology. 2-4, November, 1977, Texas A&M University pp. G1-1-G1-24. 39. Shive, J. B. and K. W. Brown. 1978. Quaking and gas exchange in cottonwood (Populus deltoides, Marsh) leaves. Plant Physiol. 61: 331-333. 40. Duble, R. L., J. C. Thomas and K. W. Brown. 1978. Arsenic pollution from underdrainage and runoff from golf greens. Agron. J. 70:71-74. 41. Duble, R. L., K. W. Brown and J. C. Thomas. 1978. Increase fertilizer efficiency and reduce nutrient loss. Golf Superintendent 46:28-31. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 42. Jones, S. G., K. W. Brown, L. E. Deuel and K. C. Donnelly. 1978. Influence of rainfall on the retention of sludge heavy metals by the leaves of forage crops. JEQ 8:69-72. 43. Brown, K. W. and J. C. Thomas. 1978. Uptake of nitrogen by grass from septic fields in three soils. Agron. J. 70:1037-1040. 44. Brown, K. W., D. C. Anderson, S. G. Jones, L. E. Deuel, Jr., and J. D. Price. 1979. The relative toxicity of four pesticides in tap water and water from flooded rice paddies. Int. J. Env. Studies. 141:49-54. 45. Brown, K. W., H. W. Wolf, K. C. Donnelly and J. F. Slowey. 1979. The movement of fecal coliform and coliphage below septic lines. JEQ 8:121-125. 46. Wagner, T. L., J. A. Gagne, P. C. Doraiswamy, R. N. Coulson and K. W. Brown. 1979. Development time and mortality of Dendroctonus frontalis in relation to changes in tree moisture and xylem water potential. Environ. Entomol. 8: 1129-1138. 47. Brown, K. W. and D. C. Anderson. 1980. Effect of organic chemicals on clay liner permeability: A Review of the Literature. In: D.W. Shultz (ed.). Disposal of Hazardous Waste. Proceedings of the 6th Annual Research Symposium at Chicago, Illinois. EPA-600/9-80-010. pp. 123-134. 48. Brown, K. W. and L. E. Deuel. 1980. Revegetation of Drastically Disturbed Lands. Texas A&M Lignite Symposium, April 17-18, 1980. pp. 19.0-19.8 49. Brown, K. W., L. E. Deuel, Jr. and J. C. Thomas. 1980. Optimization of land cultivation parameters. In: D.W. Shultz (ed). Disposal of Hazardous Waste. Proceedings of the 6th Annual Research Symposium at Chicago, Illinois. EPA- 600/9-80-010. pp. 254-259. 50. Brown, K. W. and C. B. Holder. 1980. The relationship between oxygen and water uptake by roots of intact bean plants. Soil Sci. Soc. Amer. J. 44:21-25. 51. Brown, K. W., S. G. Jones, and K. C. Donnelly. 1980. The influence of simulated rainfall on residual bacteria and virus on grass treated with sewage sludge. JEQ 9(2):261-265. 52. Brown, K. W. and J. C. Thomas. 1980. The influence of the sand layer on available water retention in a golf green. USGA Green Section Record 18(6):5-7. 53. Brown, K. W. and J. C. Thomas. 1980. The influence of water stress preconditioning on dark respiration. Physiologia Plantarium. 49:205-209. 54. Brown, K. W., J. C. Thomas and A. Almodares. 1980. The necessity of the two-inch sand layer in greens construction. USGA Green Section Record 18(6): 1-4. 55. Brown, K. W., L. J. Thompson, K. W. Launius and L. E. Deuel, Jr. 1980. Physical properties of dredged materials. Soil Sci. 129(2):95-106. 56. Turner, F. T., K. W. Brown, and L. E. Deuel. 1980. Nutrients and associated ion concentrations in Irrigation Return Flow from Flooded Rice Fields. JEQ 9(2):256-260. 57. Deuel, L. E. and K. W. Brown. 1980. Impact of surface mining on water quality. Texas A&M Lignite Symposium, April 17-18, 1980. pp. 16.1-16.5. 58. Anderson, D. C., and K. W. Brown. 1981. Organic leachate effects on the permeability of clay liners. In: Proceedings of the 7th Annual Research Symposium at Philadelphia, PA. EPA-600/9-81-002b, pp. 119-130. 59. Anderson, D. C., K. W. Brown, and J. Green. 1981. Organic leachate effects on the permeability of clay liners. In: National Conference on Management of Uncontrolled Hazardous Waste Sites held at Washington, D.C. EPA 600/9-81-002B. pp. 223-229. 60. Brown, K. W., K. C. Donnelly, J. C. Thomas and L. E. Deuel, Jr. 1981. Factors influencing the biodegradation of API separator sludges applied to soils. In: D. W. Shultz (ed.). Land Disposal: Hazardous Waste. Proceedings of the 7th Annual Research Symposium at Philadelphia, PA. EPA- 600/9-81-002B. pp. 188-199. 61. Donnelly, K. C. and K. W. Brown. 1981. The development of laboratory and field studies to determine the fate of mutagenic compounds from land applied hazardous waste. In: D. W. Shultz (ed.). Land Disposal: Hazardous Waste. Proceedings of the 7th Annual Research Symposium at Philadelphia, PA., EPA-600/9-81-002B. pp. 224-239. 62. Huddleston, R. L., J. E. Rucker, K. W. Brown and L. E. Deuel. 1982. Evaluation of subsurface effects of long-term landfarming. In: D. W. Shultz (ed.). Land Disposal: Hazardous Waste. Proceedings of the 8th Annual Research Symposium at Ft. Mitchell, Ky. EPA-600/9-82-002, pp. 398- 446. 63. Anderson, D., K. W. Brown and J. Green. 1982. Effect of organic fluids on the permeability of clay soil liners. In: D. W. Shultz (ed.). Land Disposal: Hazardous Waste. Proceedings of the 8th Annual Research Symposium at Ft. Mitchell, Ky. EPA-600/9-82-002. pp. 179-190. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 64. Brown, K. W. 1982. Irrigation of recreational turf with sewage effluent. In: 7th National Turf Conference, S. Australia, June 6-11, 1982. pp. 73-83. 65. Brown, K. W. 1982. Quality of irrigation flow from flooded rice paddies. pp. 139-175. Proceedings of the Workshop on Agrichemicals and Estuarine Productivity. Duke University Marine Laboratory, Beaufort, North Carolina. 66. Brown, K. W., L. E. Deuel, F. C. Turner, and J. D. Price. 1982. Quality of irrigation return flow from flooded rice paddies. pp. 153-166. Proc. of National Conference on Irrigation Return Flow Quality Management. Colorado State University, Fort Collins, Co. 67. Brown, K. W., H. Brawand, J. C. Thomas and G. B. Evans. 1982. Impact of simulated land treatment with oily sludges on ryegrass emergence and yield. Agronomy J. 74:257-261. 68. Brown, K. W. and K. C. Donnelly. 1982. Mutagenic potential of water concentrates from the effluent of a waste oil storage pond. Bull. Environ. Contam. Toxicol. 28:424-429. 69. Brown, K. W., K. C. Donnelly and B. Scott. 1982. The fate of mutagenic compounds when hazardous wastes are land treated. In: D. W. Shultz (ed.). Land Disposal: Hazardous Waste. Proceedings of the 8th Annual Research Symposium at Ft. Mitchell, Ky. EPA-600/9-82-002, pp. 383-397. 70. Brown, K. W. and J. C. Thomas. 1982. Testing and construction of greens to USGA standards and procedures. In: 7th National Turf Conference, S. Australia-June 6-11, 1982, pp. 26-31. 71. Brown, K. W., J. C. Thomas and R. L. Duble. 1982. Nitrogen source effect on nitrate and ammonium leaching and runoff losses from greens. Agronomy J. 74(6):947-950. 72. Brown, K. W. 1983. Land Treatment of Hazardous Wastes. Chapter 36, pp. 449-474. In: Environment and Solid Wastes. Characterization, Treatment, and Disposal. C. W. Francis and S. I. Auerbach (eds.). Butterworths/Ann Arbor Science Book, Woburn, MA. 73. Brown, K. W. and L. E. Deuel, Jr., and J. C. Thomas. 1983. Land Treatability of Refinery and Petrochemical Sludges. Project Summary. EPA-600/S2-83-074. 74. Brown, K. W. and L. E. Deuel, Jr. 1983. An Evaluation of Subsurface Conditions at Refinery Land Treatment Sites. Project Summary. EPA-600/S2-83-096. 75. Donnelly, K. C., K. W. Brown, and B. Scott. 1983. pp. 59-78. The Use of Short-Term Bioassays to Monitor the Environmental Impact of Land Treatment of Hazardous Wastes. (Waters, M. D., S. S. Sandhu, J. Lewtas, L. Claxton, and N. Chernoff and S. Nesnow (eds.). The Application of Short Term Bioassays in the Fractionation and Analysis of Complex Environmental Mixtures. Plenum, New York. 76. Brown, K. W., J. W. Green and J. C. Thomas. 1983. The influence of selected organic liquids on the permeability of clay liners. In: D. W. Shultz (ed). Land Disposal, Incineration, and Treatment of Hazardous Waste. Proceedings of the 9th Annual Research Symposium at Ft. Mitchell, Ky. EPA-600/9-83-018, pp. 114-125. 77. Brown, K. W. and D. C. Anderson. 1983. Effects of Organic Solvents on the Permeability of Clay Liners. United States Environmental Protection Agency, EPA-600/2-83-016. 153 p. 78. Brown, K. W., J. C. Thomas and J. F. Slowey. 1983. The movement of metals applied to soils in sewage effluent. Water, Air, Soil Pollut. 19:43-54. 79. Brown, K. W. and K. C. Donnelly. 1983. Influence of soil environment in biodegradation of refinery and a petrochemical sludge. Environ. Poll. (Series B) 6:119-132. 80. Brown, K. W., J. C. Thomas and K. W. Launius. 1983. Distribution of Bermudagrass Roots in Native Soils and Reclaimed Lignite Spoil. Reclamation and Revegetation Research, 2, 139-153. 81. Donnelly, K. C., K. W. Brown, and R. M. Saltarelli. 1983. The Use of B. Subtilis in a Pre-Incubation Assay for the Detection of DNA-Modifying Agents. Research Communications in Chemical Pathology and Pharmacology Vol. 42:135-143. 82. Brown, K. W., K. C. Donnelly and L. E. Deuel, Jr. 1983. Effects of Mineral Nutrients, Sludge Application Rate, and Application Frequency on Biodegradation of Two Oily Sludges. Microb. Ecol. 9:363-373. 83. Brown, K. W., J. C. Thomas and J. F. Slowey. 1983. Metal Accumulation by Bermudagrass Grown on Four Diverse Soils Amended with Secondarily Treated Sewage Effluent. Water, Air, and Soil Pollution 20:431-446. 84. Brown, K. W., J. C. Thomas and L. E. Deuel, Jr. 1984. Physical and Chemical Properties of Gulf Coast Lignite Overburden. Reclamation and Revegetation Research 3:17-29. 85. Brown, K. W. and K. C. Donnelly. 1984. Mutagenic Activity of the Liquid Waste from the Production of Acetonitrile. Bull. Environ. Contam. Toxicol. 32:742-748. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 86. Brown, K. W., J. C. Thomas and J. F. Slowey. 1984. Extractability of Metals Applied to Soils in Sewage Effluent. Soil Sci. 138(6):423-431. 87. Brown, K. W., J. C. Thomas, and L. E. Deuel, Jr. 1984. Chemical Characteristics of Surface Runoff from Soils and Revegetated Lignite Mine Spoils. Journal of Soil & Water Conservation, 39(2):146-149. 88. Brown, K. W. and K. C. Donnelly. 1984. Mutagenic Activity of Runoff and Leachate Water from Hazardous Waste Land Q701 Treatment. Environmental Pollution (Series A) 35:229-246. 89. Brown, K. W., K. C. Donnelly, and J. C. Thomas. 1984. Use of Short- Term Bioassay to Evaluate Environmental Impact of Land Treatment of Hazardous Industrial Waste. Project Summary. EPA-600.S2-84-13 5. 90. Donnelly, K. C., K. W. Brown, J. C. Thomas, P. Davol, B. R. Scott, and D. Kampbell. 1984. Evaluation of the hazardous characteristics of two petroleum wastes. Hazardous Waste & Hazardous Materials, 2(2):191-208. 91. Brown, K. W., K. C. Donnelly, J. C. Thomas and J. F. Slowey. 1984. The movement of nitrogen species through three soils below septic fields. JEQ. 13(3):460-465. 92. Brown, K. W., J. C. Thomas and J. W. Green. 1984. Permeability of compacted soils to solvent mixtures and petroleum products. In: Land Disposal of Hazardous Waste. Proceedings of the 10th Annual Research Symposium at Ft. Mitchell, Kentucky, EPA 600/9-84-007, pp. 124-137. 93. Brown, K. W. and J. C. Thomas. 1984. Conductivity of Three Commercially Available Clays to Petroleum Products and Organic Solvents. Hazardous Waste. 1:545-553. 94. Crawley, W., K. W. Brown and D. Anderson. 1984. Inplace closure of previously backfilled and active surface impoundments. Proceedings of the 5th National Conf. on Management of Uncontrolled Hazardous Waste Sites. Nov. 7-9, l984. Houston, TX. pp. 185-188. 95. Brown, K. W., J. C. Thomas and K. W. Launius. 1984. Runoff water quality from fresh mine spoil. Environ. Pollution 8:119-131. 96. Brown, K. W., K. C. Donnelly, J. C. Thomas, P. Davol and B. R. Scott. 1985. Mutagenicity of three agricultural soils. Science of Total Environ. 41:173-186. 97. Brown, K. W., K. C. Donnelly, J. C. Thomas, P. Davol, and D. Kampbell. 1985. Degradation of Soil Applied Organic Compounds from Three Petroleum Wastes. Waste Mang. Res. 3:27-39. 98. Rubio-Montoya, D. and K. W. Brown. 1985. Erodibility of Strip-Mine Spoils. Soil Science, 138(5):365-373. 99. Brown, K. W., and K. C. Donnelly. 1985. Mutagenic Activity of Runoff Water from Simulated Hazardous Waste Landtreatment Facilities. In: Proceedings of the Second Conference on Management of Municipal, Hazardous, and Coal Wastes. S. Sengupta (ed.). Miami, Florida, December 5-7, 1983. pp. 185-195. 100. Brown, K. W., G. B. Evans, and J. C. Thomas. 1985. Increased Soil Water Retention by Mixing Horizons of Shallow Sandy Soils. Soil Science, 139(2):118-121. 101. Brown, K. W., L. E. Deuel, Jr., and J. C. Thomas. 1985. Distribution of inorganic constituents in soil following land treatment of refinery wastes. Water, Air, and Soil Pollution, 25:285-300. 102. Pinkerton, B. W. and K. W. Brown. 1985. Plant Accumulation and Soil Sorption of Cobalt from Cobalt-Amended Soils. Agron. J. 77:634-638. 103. Deuel, L. E. Jr., K. W. Brown, J. D. Price, and F. T. Turner. 1985. Dissipation of carbaryl and the 1-naphthol metabolite in flooded rice fields. JEQ. 14:349-354. 104. May, J. H., K. W. Brown, J. C. Thomas, and P. G. Malone. 1985. Use of x-ray radiographic techniques in the evaluation of soil liners. Misc. Paper GL-85-14. Prepared for Asst. Secretary of the Army, Dept. of the Army, Washington, D.C. 20315-1000. Project No. 4A161102A91D. 105. Brown, K. W., J. C. Thomas, and M. W. Aurelius. 1985. Collecting and testing barrel sized undisturbed soil monoliths. Soil Sci. Soc. Am. J. 49:1067-1069. 106. Anderson, D. C., K. W. Brown and J. C. Thomas. 1985. Conductivity of compacted clay soils to water and organic liquids. Waste Management & Research, 3:339-349. 107. Guth, D. L. and K. W. Brown. 1985. A comparison of the SAR and Vaneslow equations in three soils. Soil Science, 140:(5):356-361. 108. Hornby, W. J., K. W. Brown, and J. C. Thomas. 1986. Nitrogen mineralization potentials of revegetated mixed lignite overburden in the Texas Gulf Coast. Soil Sci. Soc. Am. J. 50:1484-89. 109. Brown, K. W. 1986. Monitoring the unsaturated zone. In: Land Treatment: A Hazardous Waste Management Alternative. R. C. Loehr and J. F. Malina, Jr. (eds.). Water Resources Symposium No. 13. pp. 171-185. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 110. Malone, P. G., J. H. May, K. W. Brown and J. C. Thomas. 1986. Use of x-ray radiographic methods in the study of clay liners. HMCRI's 3rd National Conference and Exhibition on Hazardous Wastes and Hazardous Materials. March 4-6, 1986, Atlanta, Georgia. 111. Barbee, G. C. and K. W. Brown. 1986. Comparison between suction and free-drainage soil solution samplers. Soil Sci., Vol. 141:149-153. 112. Barbee, G. C. and K. W. Brown. 1986. Movement of xylene through unsaturated soils following simulated spills. Water, Air, and Soil Pollution. 29:321-331. 113. Brown, K. W. and D. E. Daniel. 1986. Use of soils to retain waste in landfills and surface impoundments. In: Utilization, Treatment, and Disposal of Waste on Land. Proceedings of a Workshop held in Chicago, IL, 6-7 Dec. 1985. pp. 279-300. 114. Brown, K. W., K. C. Donnelly, J. C. Thomas and P. Davol. 1986. Mutagenic activity of soils amended with two refinery wastes. Water, Air, and Soil Pollution 29:1-13. 115. Brown, K. W., J. C. Thomas and J. W. Green. 1986. Field cell verification of the effects of concentrated organic solvents on the conductivity of compacted soils. Haz. Waste & Haz. Materials 3:1-13. 116. Brown, K. W. and D. E. Daniel. 1986. Potential groundwater implications of land disposal of toxic substances. In: Issues in Groundwater Management. E. T. Smerdon and W. R. Jordan (eds.). Water Resources Symposium No. 12, Center for Research in Water Resources Publishers. pp. 387-402. 117. Brown, K. W. 1987. Efficiency of Soil Core and Soil-Pore Water Sampling Systems. Project Summary, EPA/600/S2-86/083. 118. Donnelly, K. C., P. Davol, K. W. Brown, M. Estiri and J. C. Thomas. 1987. Mutagenic activity of two soils amended with a wood preserving waste. Environ. Sci. & Techn. 21:57-64. 119. Maggard, L. A., Brown, K. W, and K. C. Donnelly. 1987. The efficiency of two standardized procedures for extraction of mutagenic chemicals from soils. Chemosphere, 16:1243-1255. 120. Donnelly, K. C., K. W. Brown and D. Kampbell. 1987. Chemical and biological characterization of hazardous industrial waste. I. Prokaryotic bioassays and chemical analysis of a wood-preserving bottom-sediment waste. Mutat. Res 180:31-42. 121. Donnelly, K. C., K. W. Brown, and B. R. Scott. 1987. Chemical and biological characterization of hazardous industrial waste. II. Eukaryotic bioassay of a wood preserving bottom sediment. Mutat. Res. 180:43-53. 122. McBee, K., J. W. Bickham, K. W. Brown and K. C. Donnelly. 1987. Chromosomal aberrations in native small mammals (Peromyscus leucopus and Sigmodon hispidus) at a petrochemical waste disposal site. I. Standard karyology. Archives of Environmental Cont. and Tox. 16:681. 123. Brown, K. W. and J. C. Thomas. 1987. A mechanism by which organic liquids increase the hydraulic conductivity of compacted clay materials. SSSAJ, 51:1451-1459. 124. Cocke, C. L. and K. W. Brown. 1987. The effect of sewage sludge on the physical properties of lignite overburden. Reclamation and Revegetation Research, 6:83-93. 125. Smith, C., K. W. Brown and L. E. Deuel, Jr. 1987. Plant availability and uptake of molybdenum as influenced by soil type and competing ions. JEQ 16:4 377-382. 126. Davol, P., K. C. Donnelly and K. W. Brown. 1987. The use of short-term bioassays to assess clean-up operations of sites contaminated with hazardous Wastes. Proceedings of the 8th National Conference. Superfund 1987. November 16-18, 1987, Washington, D.C. pp. 66-71. 127. Brown, K. W., J. C. Thomas, R. L. Lytton, P. Jayawickrama, and S. C. Bahrt. 1987. Quantification of leak rates through holes in landfill liners. Project Summary. EPA/600/S2- 87/062. 128. Aurelius, M. and K. W. Brown. 1987. Fate of spilled xylene as influenced by soil moisture content. Water, Air, and Soil Pollution 36:23-31. 129. Brown, K. W. and D. E. Daniel. 1988. Influence of organic liquids on the hydraulic conductivity of soils. Chapt. 4.3. In: Land Disposal of Hazardous Waste. Engineering and Environmental Issues (J. R. Gronow, A. N. Schofield, R. K. Jain eds.). Ellis Horwood Publishers, Chickester, West Sussex, England. pp. 199-216. 130. Daniel, D. E. and K. W. Brown. 1988. Landfill liners: How well do they work and what is their future? In: Land Disposal of Hazardous Waste. Engineering and Environmental Issues (J. R. Gronow, A. N. Schofield, R. K. Jain eds.). Ellis Horwood Publishers, Chickester, West Sussex, England. pp. 235-244. 131. Brown, K. W. and K. C. Donnelly. 1988. An estimation of risk associated with the organic constituents of hazardous and municipal waste landfill leachates. Hazardous Waste & Hazardous Matls. 5:1-30. 132. Brown, K. W. and J. C. Thomas. 1988. Leak rates into drainage systems underlying lined retention facilities. Journal of Hazardous Materials 18, 179-188. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 133. Jayawickrama, P. W., K. W. Brown, J. C. Thomas and R. L. Lytton. 1988. Leakage rates through flaws in membrane liners. ASCE, J. Environmental Engineering Division, 114:1401-1420. 134. Donnelly, K. C., K. W. Brown and D. G. Digiullio. 1988. Mutagenic characterization of soil and water samples from a Superfund site. Nuclear and Chemical Waste Management 8:132-141. 135. Donnelly, K. C., K. W. Brown and C. P. Chisum. 1988. Mutagenic potential of municipal sewage sludge and sludge amended soil. In: Chemical and Biological Characterization of Sludges, Sediments, Dredge Spoils, and Drilling Muds. ASTM STP 976. J. J. Lichtenberg, J. A. Winter, C. I. Weber, and L. Fradkin, Eds., American Society for Testing and Materials, Philadelphia, pp. 288-299. 136. Brown, K. W. 1988. Review and Evaluation of the Influence of Chemicals on the Conductivity of Soil Clays. Project Summary. EPA/600/S2-88/016. 137. Donnelly, K. C., K. W. Brown, M. Estiri, D. H. Jones and S. Safe. 1988. Mutagenic potential of binary mixtures of nitro-polychlorinated dibenzo-p-dioxins and related compounds. J. Toxicology and Environ. Health, 24:345-356. 138. Brown, K. W. and D. C. Anderson. 1988. Aboveground Disposal. Section 10.7. In: Standard Handbook of Hazardous Waste Treatment and Disposal. H. M. Freeman (ed.). McGraw-Hill Book Company, N.Y. 139. Brown, K. W. and K. C. Donnelly. 1988. The Stability and Mobility of Mutagenic Activity from Wastewater and Sludge in Agricultural Soils. EPA/600/S1-88/002. 140. Brown, K. W. 1988. Fate and transport of pesticides used in rice production. In: Managing Texas Waters: Stewardship in a Regulatory Environment. Proceedings of the 22nd Water for Texas Conference. R. Jensen and C. Dunagan (eds). Texas Water Resources Inst., Texas A&M University, College Station, TX. pp. 128-134. 141. Davol, P., K. W. Brown, K. C. Donnelly, J. C. Thomas, M. Estiri and D. H. Jones. 1989. Mutagenic potential of runoff water from soils amended with three hazardous industrial wastes. Environmental Toxicology and Chemistry 8:189-200. 142. Brown, K. W. and J. C. Thomas. 1989. New technology for liners. Section 12. Proceedings, Conference on Prevention and Treatment of Groundwater and Soil Contamination in Petroleum Exploration and Production. May 9-11, 1989, Calgary, Alberta, Canada. 143. Donnelly, K. C., K. W. Brown and J. C. Thomas. 1989. Mutagenic potential of municipal sewage sludge amended soils. Water, Air, and Soil Pollution 48, 435-449. 144. Brown, K. W., and J. C. Thomas. 1990. The fate and mobility of pesticides: Lessons from the past, where to from here. Proceedings of Chemicals, Agriculture and Our Environment. January 21, 1990. Corpus Christi, Texas. Texas Agric. Extension Service, pp. 37-51. 145. Donnelly, K. C., K. W. Brown, and J. C. Thomas. 1990. Bacterial mutagenicity of leachate water from municipal sewage sludge-amended soils. Environ. Tox. & Chem. 8:443-451. 146. Brown, K. W., G. C. Barbee and J. C. Thomas. 1990. Detecting organic contaminants in the unsaturated zone using soil and soil-pore water samples. Hazardous Waste & Hazardous Materials 7:151. 147. Donnelly, K. C., K. W. Brown, C. S. Anderson, G. C. Barbee, and S. H. Safe. 1990. Metabolism and bacterial mutagenicity of binary mixtures of benzo(a)pyrene and polychlorinated aromatic hydrocarbons. Environ. & Molecular Mutagenesis 16:238-245. 148. Donnelly, K. C., J. C. Thomas. C. S. Anderson and K. W. Brown. 1990. The influence of application rate on the bacterial mutagenicity of soil amended with municipal sewage sludge. Environmental Pollution 68:147-159. 149. Brown, K. W., J. C. Thomas and M. Holder. 1990. The ability of sorbent materials to adsorb and retain organic liquids under landfill conditions. Hazardous Waste & Hazardous Materials 7:361-371. 150. Brown, K. W., C. P. Chisum, J. C. Thomas and K. C. Donnelly. 1990. A comparison of two different procedures for the extraction of organic mutagens from sewage sludge. Chemosphere 20:13-20. 151. Brown, K. W., J. C. Thomas and K. C. Donnelly. 1991. Bacterial mutagenicity of municipal sewage sludges. J. Environ. Sci. Health, A26 (3), 395-413. 152. Fiedler, D. A., K. W. Brown, J. C. Thomas, and K. C. Donnelly. 1991. Mutagenic potential of plants grown on municipal sewage sludge-amended soil. Arch. Environ. Contam. Toxicol. 20, 385-390. 153. Giam, C.S., T. L. Holliday, R. Evans, Y. Zheng, R. Li, K. W. Brown, K. C. Donnelly, and C. S. Anderson. 1991. Bioassay directed chemical characterization of hazardous organics in soil. In: Proceedings of Hazardous Materials Conference South '91, Houston, Texas, April 24-26, 1991, pp. 159-161. 154. Brown, K. W. 1991. The soil scientist as an expert witness. Soils, Sept.-Oct., p. 39. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 155. Anderson, D.C., M. J. Lupo, J. A. Rehage, J. O. Sai, R. L. Shiver, R. C. Speake, K. W. Brown and D. Daniel. 1991. Factors controlling minimum soil liner thickness. EPA/600/S2-91/008. USEPA, Risk Reduction Eng. Lab., Cincinnati, OH 45268. 156. Donnelly, K. C., K. W. Brown, C. S. Anderson and J. C. Thomas. 1991. Bacterial mutagenicity and acute toxicity of solvent and aqueous extracts of soil samples from an abandoned chemical manufacturing site. Environmental Tox. & Chem. 10:1123-1131. 157. Holder, M., K. W. Brown, J. C. Thomas, D. Zabcik, and H. E. Murray. 1991. Capillary-wick unsaturated zone pore water sampler. Soil Sci. Soc. Am. J. 55:1195-1202. 158. Brown, K. W., G. E. Schrab and K. C. Donnelly. 1991. Acute and genetic toxicity of municipal landfill leachate. Texas Water Resources Institute Publication TR-153, Texas A&M University, College Station. 91 pp. 159. Barbee, G. C., K. W. Brown and K. C. Donnelly. 1992. Fate of mutagenic chemicals in soil amended with petroleum and wood preserving sludges. Waste Management & Research 10:73-85. 160. McCarthy, K. P. and K. W. Brown. 1992. Soil gas permeability as influenced by soil gas-filled porosity. Soil Sci. Soc. Am. J. 56:997-1002. 161. Thomas, J. C. and K. W. Brown. 1992. Depth variations in hydraulic conductivity within a single lift of compacted clay. Water, Air, and Soil Pollution 65:371-380. 162. Safe, S., K. W. Brown, K. C. Donnelly, C.S. Anderson, K. V. Markiewicz, M. S. McLachlan, A. Reischl and O. Hutzinger. 1992. Polychlorinated dibenzo-p-dioxins and dibenzofurans associated with wood-preserving chemical sites: Biomonitoring with pine needles. Environmental Science & Techno. 26(2):394. 163. Donnelly, K. C., C. S. Anderson, J. C. Thomas, K. W. Brown, D. J. Manek and S. H. Safe. 1992. Bacterial mutagenicity of soil extracts from a bioremediation facility treating wood-preserving waste. J. Hazardous Materials 30:71-81. 164. Bloodworth, M.E., K. W. Brown, J. B. Beard and S. I. Sifers. 1993. A new look at the Texas-USGA specifications for root-zone modification. Grounds Maintenance, January 1993. 165. Donnelly, K. C., K. W. Brown, K. V. Markiewicz, C. S. Anderson, D. J. Manek, J. C. Thomas and C. S. Giam. 1993. The use of short-term bioassays to evaluate the health and environmental risk posed by an abandoned coal gassification site. Hazardous Waste & Hazardous Materials. 10:59-70. 166. Schrab, G. E., K. W. Brown and K. C. Donnelly. 1993. Acute and genetic toxicity of municipal landfill leachate. Water, Air, and Soil Pollution 69:99-112. 167. Donnelly, K. C., K. W. Brown, C. S. Giam and B. R. Scott. 1993. Acute and genetic toxicity of extracts of munitions wastewater contaminated soils. Chemosphere 27:1439-1450. 168. Brown, K. W. 1993. Municipal solid waste (MSW) disposal, past, present and future. Hazardous Waste & Hazardous Materials 10:105-106. 169. Brown, K. W. and L. D. Nelson. 1994. Sources of hazardous constituents in municipal solid waste and landfill leachate. In: 7th annual Municipal Solid Waste Management Conference, Vol. 1. Austin, Texas, January 19-21, 1994. 170. Prasad, T.V., K. W. Brown and J. C. Thomas. 1994. Diffusion coefficients of organics in high density polyethylene (HDPE). Waste Management & Research 12:61-71. 171. Brown, K. W. 1994. New Horizons in Soil Remediation. Geotimes, pp. 15-17. September 1994. 172. Prasad, T. V. and K. W. Brown. 1995. Permachor method to predict diffusivity coefficients of organics in aqueous solutions in flexible membrane liners. Waste Management & Research 13:47-53. 173. Brown, K. W. 1994. Lysimeters. Encyclopedia of Soil Science (in press). 174. Brown, K. W. 1994. Soil pore size distribution. Encyclopedia of Soil Science (in press). 175. Brown, K. W. 1995. Soil solution sampling. Encyclopedia of Soil Science (in press). 176. Brown, K.W. 1997. Decontamination of polluted soils. Remediation of Soils Contaminated with Metals. pp. 47-66. 177. Omidi, G.H., T.V. Prasad, J.C. Thomas and K.W. Brown. 1996. The influence of amendments on the volumetric shrinkage and hydraulic conductivity of compacted clays used in landfill liners. Water, Air, and Soil Pollution 86:263-274. 178. Donnelly, K.C., J.C. Thomas, K.W. Brown. 1995. Mutagenic potential of environmental samples before and after remediation of a solvent-contaminated site. Environmental Toxicology and Chemistry, Vol. 14, No. 8, pp. 1281-86. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 179. Brown, K.W., J.C. Thomas and O.J. Seago. 1995. Degradation of explosive propellants by in-vessel composting. BioCycle. pp. 56-58. 180. Spongberg, A.L. and Brown, K.W. 1995. Volatilization of toxic organic compounds during in-vessel composting of hazardous waste. Hazardous Waste & Hazardous Materials. 12:295-307. 181. Spongberg, A.L., J.C. Thomas, and K.W. Brown. 1996. Laboratory scale in-vessel composter designed for volatile emissions analysis. Journal Environmental Quality. 25:371-373. 182. Omidi, G.H., J.C. Thomas, and K.W. Brown. 1996. Effect of desiccation cracking on the hydraulic conductivity of a compacted clay liner. Water, Air, and Soil Pollution. 89:91-103. 183. Barbee, G.C., K.W. Brown, J.C. Thomas, K.C. Donnelly, and H.E. Murray. 1996. Mutagenic activity (Ames Test) of wood-reserving waste sludge applied to soil. Bull. Environ. Contam. Toxicol. 57:54-62. 184. Brown, K.W., J.C. Thomas, S. Friedman and A. Meiri. 1996. Wetting Patterns Associated With Directed Subsurface Irrigation. Pg. 806-811 In: C.R. Camp, E.J. Sadler, and R.E. Yoder (eds.) Evapotranspiration and Irrigation Scheduling Proceedings o f the International Conference. November 3-6, San Antonio, TX. Publ. by American Society of Agricultural Engineers. 185. Magnuson, C.E., T.P. Grundy, Z. Wang, M.J. Lupo, M.F. Conlin, D.F. Wunneburger, D. Rodriguez and K.W. Brown. 1996. A GIS application in a study involving a large number of residents with elevated VOC Exposures. pp. 334-345 In: Geographic Information Systems (GIS) in Environmental Resources Management. Proceedings of a Specialty Conference Sponsored by the Air & Waste Management Association, Reno, Nevada, March 13-15, 1996. 186. Donnelly, K.C., J.C. Chen, H.J. Huebner, K.W. Brown, R.L. Autenrieth and J.S. Bonner. 1997. Utility of four strains of white-rot fungi for the detoxification of 2,4,6-trinitrotoluene in liquid culture. Environmental toxicology and chemistry 16:1105-1110. 187. Brown, K.W., David C. Anderson, James C. Thomas. 1997. Above Ground Disposal. In Standard Handbook Of Hazardous Waste Treatment and Disposal, Second Edition:10.68-10.75. 188. Brown, K.W., J.C. Thomas and F. Whitney. 1997. Fate of volatile organic compounds and pesticides in composted municipal solid waste. Compost Science & Utilization, (1997), Vol. 5, No.4, pp. 6-14 189. Lupo, M.J., G.J. Moridis and K.W. Brown. 1998. Predicting the fate of trichloroethylene and its daughters in a heterogeneous environment. (In Press) 190. Lupo, M.J., K.W. Brown. 1998. Distinguishing the contributions of multiple sources from a gasoline release. (In Press) 191. Brown, K.W. and J.C. Thomas. 1998. A comparison of the convective and diffusive flux of organic contaminants through landfill liner systems. Waste Management & Research 16:296-301. 192. Rooney, D.J., K.W. Brown and J. C. Thomas. 1998. The effectiveness of capillary barriers to hydraulically Isolate salt contaminated soils. Kluwer Academic Publishers. 104: 403-411. 193. Brown, K.W. 1998. Composting of Hazardous Wastes and Hazardous Substances. In: Beneficial Co Utilization of Agricultural, Municipal and Industrial By-products. (S. Brown, J. S. Angle, and L. Jacobs eds.). Kluwer Academic Publishers, Netherlands. pp. 327-340. 194. West, M.E., K.W. Brown, and J.C. Thomas. 1998. Methane production of raw and composted solid waste in simulated landfill cells. Waste Management & Research 16:5:430-436. Miscellaneous Papers 1. Brown, K. W. 1983. Landfills of the future: Aboveground and aboveboard. Public Works, June 1983, p. 62. 2. Brown, K. W. 1982. Testimony before the House of Subcommittee on Natural Resources, Agriculture Research and Environment of the Committee on Science and Technology. Unpublished paper. Miscellaneous Reports 1. Brown, K. W. 1968. Experimental considerations for the measurement of photosynthetic rates by means of carbon dioxide exchange in leaf chambers. Dept. of Hort. and For., University of Nebraska. Progress Report No. 66. 2. Rosenberg, N. J., E. H. Hart and K. W. Brown. 1968. Evapotranspiration. A review of research. Nebr. Agric. Expt. Sta. MP-20. 3. Brown, K. W. and N. J. Rosenberg. 1969. Computer program for plotting time dependent data with instructions and examples. Nebr. Agric. Expt. Sta. MP-23. 35pp. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN 4. Brown, K. W. 1969. Mechanisms of windbreak influence on microclimate evapotranspiration and photosynthesis of the sheltered crop. Dept. Hort. and For., University of Nebraska, Proj. Report No. 71. Lincoln, Neb., 254 pp. 5. Rosenberg, N. J. and K. W. Brown. 1973. Measured and modeled effects of microclimate modification on evapotranspiration by irrigated crops in a region of strong sensible heat activation. Plant response to climate factors. UNESCO. Paris 539-546. 6. Brown, K. W., L. E. Deuel, Jr., F. C. Turner and J. D. Price. 1977. Quality of irrigation return flow from flood ed rice paddies. In Proc. of National Conf. on Irrigation Return Flow Quality Mgmt. Colorado State University. May 16-19, 1977. 7. Haliburton, T. Allan, Gary N. Durham, K. W. Brown, Robert E. Peters and Thomas B. Delaney, Jr. 1977. Effects of mechanical agitation on drying rate of fine-grained dredged material. Technical Report D-77-10. U. S. Army Eng. Waterways Exp. Sta., Vicksburg, Miss. 8. Brown, K. W., J. F. Slowey and H. W. Wolf. 1978. The movement of salts, nutrients, fecal coliform and virus below septic leach fields in three soils. In Proc. Nat. Home Sewage Treat. Symp. ASAE Publ. pp. 708-717. 9. Reddell, D. L., K. W. Brown and J. M. Sweeten. 1976. Land disposal of blood and paunch manure. In Proceedings of Management of Slaughterhouse and Meat Processing Wastes Seminar in Waco, Texas. 10. Deuel, L. E., Jr., K. W. Brown and J. C. Thomas. 1978. Soil disposal of API pit waste. Presented at the 85th National Meeting of the American Institute of Chemical Engineers. Philadelphia. June 8, 1978. 11. Brawand, H. and K. W. Brown. 1977. Tentative procedure for measuring bulk density and soil moisture criteria on undisturbed soil cores. Departmental Technical Report No. 55. Texas A&M University, Soil & Crop Sciences Department. College Station, Texas. 12. Brown, K. W. 1978. The fate of sewage effluent heavy metals in land wastewater disposal sites. In: State of Knowledge in Land Treatment of Wastewater. Volume 2 (H. L. Q701 McKim, Coordinator) Pub. by U. S. Army Corps of Engineers, Cold Regions Research and Engineering Laboratory, Hanover, New Hampshire. 13. Overcash, M. R., K. W. Brown and G. B. Evans, Jr., 1987. Hazardous Waste Land Treatment: A Technology and Regulatory Assessment. Technical Memo ANL/EES-TM-340. Argonne National Laboratory, Energy and Environmental Systems Division, 9700 S. Cass Avenue, Argonne, Ill 60439. 51 pp. 14. Brown, K. W. 1980. Clay Liners May be Unsafe for Hazardous-Waste Impoundments. Texas Agricultural Experiment Station Research Report, Texas A&M University. 15. Brown, K. W., J. C. Thomas and A. Almodares. 1981. Organic Matter Sources and Placements During Root Zone Modification as they Affect Seedling Emergence and Initial turf Quality - Preliminary Report. Texas Turfgrass Research - 1979-80. TAES Consolidated Report 3831-3851. 16. Brown, K. W. 1983. Landfills in the Future. Public Works, June 1983. 17. Brown, K. W. and D. C. Anderson. 1983. The Case for Aboveground Landfills. Pollution Engineering, November 1983. 18. Brown, K. W. and D.C. Anderson. 1984. Abovegrade Storage of Waste. Presented at the National Conference and Exhibition on Hazardous Waste and Environmental Emergencies, Houston, Texas, March 12-14, 1984. 19. Brown, K. W. 1985. Some Municipal Waste Landfills Rival Industrial Ones in Toxicity. Texas Agricultural Experiment Station Research Report, Texas A&M University, College Station. 20. Brown, K. W. 1986. Many Businesses and Individuals are hazardous Waste Generators. Texas Agricultural Experiment Station Research Report, Texas A&M University, College Station. 21. Brown, K. W. 1986. Underground Storage Tanks. Grounds Maintenance, July, 1986. p. 56. 22. Brown, K. W. 1986. Pesticide Rinse Water Disposal Options. Golf Course Management, p. 80. 23. Brown, K. W. and J. C. Thomas. 1986. Bunker sand selection. Golf Course Management, July, 1986, p. 64. Grant Projects: "An investigation of the maximum infiltration rate and the necessity of a sand layer in artificially constructed golf green." 1971-1972. Funded by the United States Golf Association Greens Section for $3,000. Final Report submitted December, 1972-1973. "An investigation of the return flow from irrigated land." 1972- 1973. Funded by OWRR for $31,200. Final Report submitted September, 1974. "Fate of metals applied in sewage to land wastewater disposal sites." 1973-1974. Funded by the U. S. Army Medical Corps for $137,780. Final Report submitted June, 1975. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN "Nutrient and pesticide retention in golf greens built to USGA Green Section specifications." 1972-1975. Funded by the U. S. Golf Association, Green Section for $21,000. Final Report submitted October, 1975. "An investigation of the feasibility of soil disposal of wastewater from Jefferson Chemical Co." 1975. Funded by the Jefferson Chemical Co. for $16,600. Final Report submitted October, 1975. "The influence of Petro S on the infiltration rate and water holding capacity of soil." 1974-1975. Funded by the Petro-chemical Co., Inc. for $8,280. Final Report submitted December, 1975. "The influence of trickle irrigation on the quality of irrigation return flow." 1973-1974. Funded by Office of Water Resources Research for $45,000. Final Report submitted March, 1976. "Analysis of overburden cores TPPI fuel deposit." 1976. Funded by the Texas Power Pool, Inc. for $24,500. Final Report submitted February, 1977. "Feasibility study of general crust management as a technique for increasing capacities of dredged material containment areas." 1975-1976. Funded by the U. S. Army Engineers Waterways Exp. Station, Corps of Engineers for $53,529. Final Report published April, 1977. "Analysis of four overburden cores." 1977. Funded by the Paul Weir Co. for $5,600. Final Report submitted July, 1977. "Accumulation and passage of pollutants in domestic septic tank disposal fields." 1973-1975. Funded by the U. S. Environmental Protection Agency for $294,864. Final Report submitted December, 1977. "Development of management guidelines to prevent pollution by irrigation return flow from rice fields." 1972-1975. Funded by U. S. Environmental Protection Agency for $197,850. Final Report published April, 1978. "Physiological model of plant growth and development of ecosystem simulation." 1975-1978. Funded by the National Science Foundation for $129,813. Final Report submitted June, 1978. "Evaluate the feasibility of revegetating mixed overburden at the proposed Angelina County lignite site." 1977- 1978. Funded by the Sunoco Energy Development Company for $46,031. Final Report submitted June, 1979. "Characteristics of overburden material and revegetation analysis for the Southwest Electric Power Company Deposit." 1977- 1978. Funded by the Southwest Electric Power Company for $53,600. Final Report submitted July, 1979. "The impact of surface lignite mining on surface and groundwater quality." 1978-1979. Funded by the Texas Energy Advisory Council for $61,022. Final Report submitted September, 1979. "Analysis of groundwater quality and the probable quality of leachate, TMPA Fuel Deposit, Grimes County, Texas." 1977. Funded by the Municipal Power Agency for $20,205. Final Report submitted November, 1979. "To investigate the feasibility of irrigation disposal of uranium stripping reclamation water." 1979. Funded by nine private companies for $9,869. Final Report submitted December, 1979. "Statistical and biophysical modeling of Dendroctonus frontalis-Host. tree dynamics: II. Physical models of Dendroctonies frontalis - Host tree systems." 1975-1979. Funded by the USFS-CSRS Expanded Southern Pine Beetle Program for $174,780. Final Report submitted December, 1979." "Investigate the concentration of heavy metals and other parameters in lignite overburden cores from Grimes County." 1978. Funded by Texas Municipal Power Agency for $7,192. Final Report submitted. "To investigate the feasibility of irrigation disposal of uranium stripping leach water. Phase II: Laboratory Study." 1979. Funded by Mobil Oil Corp. for $20,000. Final Report submitted January, 1980. "To investigate the necessity of a sand layer between the top mixture and gravel layer in golf green construction." 1978- 1979. Funded by the United States Golf Association, Greens Section for $3,220. Final Report submitted March, 1980. "To develop a plan to minimize the volume of runoff water which must be treated and disposed of and to assess the feasibility of land disposal of the runoff water and sludge." 1979-1980. Funded by Texas Engineering Extension Service for $11,058.40. Final Report submitted April, 1980. "Investigate the concentration of heavy metals and certain other physical and chemical properties - Gibbons Creek Lignite Mine." 1980. Funded by Texas Municipal Power Agency for $12,500. Final Report submitted April, 1980. "Improved water and nutrient management through high-frequency irrigation." 1977-1980. Funded by Texas Water Resources Institute for $179,435. Work completed June, 1980. "Environmental and safety aspects of the use of sulfur in highway pavements." 1980. Funded by the DOT-Federal Highway Administration for $38,951. Final Report submitted August, 1980. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN "Root distribution of bermudagrass grown on reclaimed lignite spoil." 1980-1981. Funded by the Center for Energy and Mineral Research for $12,590. Final Report submitted August, 1981. "A residual evaluation of the influence of chemicals on the permeability of soil clays." 1979-1980. Funded by the Environmental Protection Agency for $91,783. Report submitted December, 1981. "Investigate the influence of organic matter quality and placement on the establishment of grass and the physical properties of golf green mixes." 1979-1981. Funded by the U. S. Golf Association, Green Section for $10,177. Final Report submitted February, 1982. "Metal uptake by grasses grown on reclaimed lignite spoils." 1979-1980. Funded by the Center for Energy and Mineral Research for $13,100. "Soil disposal of API pit wastes." 1977-1980. Funded by the Environmental Protection Agency for $184,104. Final report submitted in 1981. "Evaluate subsurface landfarm contamination after long term use." 1980-1981. Funded by the American Petroleum Institute for $98,530. Final Report published in 1983. "The use of bioassays to evaluate the environmental impact of land treatment of hazardous industrial wastes." 1980-1983. Funded by the Environmental Protection Agency for $383,732. Final Report published in 1985. "A review and evaluation of the influence of chemicals on the permeability of soil clays." 1981. Funded by the Environmental Protection Agency for $339,056. Final report published in 1983. "Quantify leak rates through holes in landfill liners" 1983-1985. Funded by Environmental Protection Agency for $232,769. Final report submitted in 1986. "Efficiency of soil core and soil-pore liquid sampling systems". 1983-1985. Funded by Environmental Protection Agency for $101,766. Final report submitted in 1986. "Completion of Field Investigation and an Evaluation of Mechanisms by which Organic Liquids Alter the Permeability of Clay Soils". 1984-1985. Funded by EPA for $59,000. Final report submitted in 1986. "Mobility and Stability of Mutagenic Compounds in Municipal Sewage Sludge Amended Soil." 1984-1986. Funded by Environmental Protection Agency. for $281,800. "Development of a Capillary Wick Unsaturated Zone Pore Water Sampler." 1985-1986. Funded by Environmental Protection Agency for $236,353. "Evaluation of the Thickness of Clay Liners Required to Meet RCRA Requirements". Funded by Environmental Protection Agency. 1987-1989. First year funding $122,184. "Development of a Pesticide Rinse Water Digester". 1986-88. Funded by Texas Water Resource Institute for $58,000. "Determination of the optimum furrow dike size to minimize rainfall runoff". 1985. Funded by Texas Water Resource Institute for $17,500. "In situ vapor extraction of volatile contaminants at Superfund sites" 1987-88. Funded by Texas Water Resource Institute for $40,000. "Development of a comprehensive testing protocol to assess the hazard of an uncontrolled hazardous waste site". 1987- 89. Funded by Environmental Protection Agency for $315,897. "Evaluation of the Bacterial Mutagenicity and Chemical Characteristics of Municipal Landfill Leachate". 1988- 1990. Sponsored by Texas Water Resource Institute, $47,500. "Bioassay Directed Chemical Characterization of Hazardous Organic Chemicals in Waste Contaminated Environments". Funded by National Institute of Health, 1989-1992, $422,000. "The Use of Short-Term Bioassays to Assess the Human Health Hazard of Uncontrolled Hazardous Waste Sites". Funded by National Institute of Health, 1989-1992, $607,000. "In Situ Bioremediation of Hazardous Substances in the Vadose Zone". Funded by USEPA, 1988-1991, $341,164. "Effectiveness of Multiple Liner Systems for Hazardous Waste Containment Facilities". Funded by USEPA, 1988-1991, $387,203. "The Use of In-Vessel Composting as a Treatment Technology for Hazardous Waste Minimization". Funded by Gulf Coast Hazardous Substance Research Center, June 1, 1991-April 30, 1994, $107,471. "Site Assessment." Funded by NIH for $334,.650 for first 3 years. 1992-1996. "Demonstration of the Degradation of Toxic Organics in Composted Municipal Solid Waste." Funded by Texas Water Commission for $135,000 for two years, 1992-1994. "A Preliminary Demonstration of the Use of In-Vessel Composting for Degradation of Waste Propellants." Sponsored by Day & Zimmermann, Inc. 1993. Funds amounted to $18,138. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 Kirk W. Brown 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN "Water Use Efficiency and Wetting Patterns Associated with Directed Subsurface Irrigation." Sponsored by TexasIsrael Exchange Program through the Texas Department of agriculture 1995-1996 Funds amount to $27,770. CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 ATTACHMENT 3 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862 27-CV-10-28862 Filed in Fourth Judicial District Court 11/17/2017 7:07 PM Hennepin County, MN Listing of Trial or Deposition Testimony by K. W. Brown Since January 1, 2013 Cause No. 22052-10563, consolidated with Cause No. 22052-09367 and Cause No. 22052-09366; Corby Baker, et al., Plaintiffs, v. Fluor Corporation, et al., Defendants in the Missouri Circuit Court, Twenty-Second Judicial Court, State of Missouri. Case involved personal injury claims related to exposure to lead mining wastes. Retained by the Plaintiffs. Case No. 1:09-CV-0228, DNH-DRH, consolidated with Case No. 1:11-CV-006; Village o f Stillwater, et al., Plaintiffs, v. General Electric Co., Defendants in the United States District Court, Northern District of New York. Case involved contamination of the Hudson River with polychlorinated biphenyls. Retained by the Plaintiffs. Cause No. 052-09605; Charles A. Burnia, et al., Plaintiffs, v. Fluor Corporation, et al., Defendants in the Circuit Court of St. Louis, Twenty-Second Judicial Circuit, State of Missouri. Case involved personal injury claims related to exposure to lead mining wastes. Retained by the Plaintiffs. 4/23/14 4/16/14 8/19/13 CONFIDENTIAL - SUBJECT TO A PROTECTIVE ORDER ENTERED IN HENNEPIN COUNTY DISTRICT COURT, NO. 27-CV-10-28862