N.A.R. Environmental Consultants Inc.

August 25, 1998

Memorandum 

To:         Jim Taylor, Blackstone Development Inc.
From:     Brad Bowman, Senior Environmental Scientist
Re:         Review and Comments, Remedial Assessment Options, Temiskaming Testing Laboratory

Further to your request, the author has undertaken a brief review of the following documents to assess the remedial requirements required in purchasing the former Ministry of Northern Development and Mines Temiskaming Testing Laboratory (TTL):

• a report by Trow Consulting Engineers entitled "Geotechnical Assessment of the Temiskaming Testing Laboratory Site, Cobalt, Ontario", dated March, 1993;

• a Summary Report (and Annex A) prepared by Be-ak Consultants Ltd. entitled "Evaluation of Remedial Options for the Temiskaming Testing Laboratory" dated April, 1995: and;

• correspondence prepared by Mr. Robert Rice entitled "Review of Toxic Waste at TTL". undated.

Blackstone Development Inc., as one of a number of firms who propose to co-operatively aquire the subject property, have retained NAR Environmental Consultants Inc. to undertake a third party review of the site assessments completed by Trow Consulting Engineers and Beak Consultants Ltd. for the Ministry of Northern Development and Mines and the Ontario Realty Corporation, respectively.

The general objectives of the review were:

a) to assess the technical adequacy of the Phase I/II/III site assessment studies completed by MNDM/ORC's consultants; and

b) to assess the practicality of remediating the site either via (i) encapsulation or (ii) on-site processing of the subject wastes.

Technical Review

Trow Report

In general, Trow's report meets industry norms for a Phase II/III site assessment. In that MOE's guidelines have been revised subsequent to Trow's original assessment, the worse-case soil chemistry data for the above borehole and test pits was summarized and is presented in Table 1, as well as MOE's applicable Guideline for Use (Table B: Non-potable groundwater setting; industrial-commercial land use; fine textured parent soils).

In general, the new guidelines do not impact on the main conclusion of the report i.e. the historic usage has contaminated both the site and the adjoining properties. In general, the highest level of contaminated soils are on the subject property that the client proposes to purchase.

Based on the soil testing results for borehole (BH-2) and test pits (S5,1, S5,2, S13.1 and S13.2), the material on-site would be considered to be leachate toxic in accordance with Ontario Regulation 347 (formerly Regulation 309) and should be remediated in accordance with MOE's current guidelines if the waste are resulting in "un-acceptable off-property impacts".

The available groundwater quality data for the site is summarized and presented in Table 2, as welt as MOE's applicable groundwater criteria. Groundwater, as well as aeolian (airborne) transport, are considered to be the predominant off-property flux mechanisms associated with the subject property.