Subject: Due Diligence Northwest Natural Gas Company-Summary


As per your request, an environmental due diligence was completed of the  assets and outstanding issues of Northwest Natural Gas Company (NWNG), a  local distribution company  (LDC), with its corporate headquarters located in  Portand, Oregon.
This  due diligence, which was conducted on August 7-9,  2001,  was performed to determine the environmental liabilities and exposures  which may be associated with  NWNG and identify and evaluate the  environmental risks associated with each issue.
A relative risk number  between 0 and 3 has been assigned to each discipline to evulate the potential  risk impact.
A rating of "0" indicates that there is no risk associated with  this regulation or issue and a rating of "3" indicates a major problem or an  issue that has a potential long term risk or exposure.
An approximate cost   value has also been assigned to each discipline.
It is to be understood and  explicitly stated that in the calculation of each cost, conservative  estimates were used to determine a dollar value to repair, remediate or  formally close each issue.
Presented below, by discipline, are the environmental activities which impact  and affect NWNG.
The evualtion and written discussion of each disicpline is  based upon the availability of records, documents and discussions with NWNG  personnel.
Therefore, this summary report is limited to the availability of  information presented.
General Pipeline Characteristics ;  This is a dry pipeline system.
No pipeline liquids are generated, only small  volumes of compressor oils are collected.
All cast iron pipe has been removed from the system.
There is still approx.
100 miles of steel pipe which will be repalced in the near future.
The only location where horsepower and compression exists is at Mist Storage,  and underground injection and storage reservoir (10.5 bcf storage capacity).
this is a non Title V major source.
NWNG is planning additional property acquisitions to increase their  underground storage capacity.
NWNG is planning a 60 mile pipeline construction project to begin in fall of  2002.
All environmental studies have been completed and sumbmitted to the  agencies.
Landslide hazards appear to be the biggest pipeline safety concern.
NWNG has  completed a study to locate and identify high potential landslide areas.
Environmental Procedures Manual.
The NWNG environmental procedures manual   appeared to be comprehensive and in a easily understood format.
The topics  covered in the manual addressed all environmenatl issues that the company  appeared to be involved with.
The manual addressed waste management,  permitting,  disposal and environmetal stewardship.
There was also a written  statement from management supporting and attesting to NWNG's commitment to  enhancing and promoting a clean environment in all activities by NWNG.
Risk: 0  Cost: $0  Notices of Violation (NOV)/Notices of Noncompliance (NON).
In a summary  page provided by NWNG, a list of all state and federal agency actions against  the company was available.
Although the company had received a few  notices  (<10), they were of a very minor nature and involved mostly small  recordkeeping and right of way issues.
There were no outstanding judgements,  NOVs, NONs or pending agency actions or  issues to be resoved.
Risk: 0  Cost: $0   PCBs.
In interviews with NWNG, they attested to the fact that they have  never used PCBs on their pipeline and that PCBs have never been detected.
Although NWNG is an LDC and receives its gas from Northwest Pipeline Company,  the status of PCBs on the Northwest pipeline system  was unknown.
Risk:  1  Cost: $0          Mercury.
Mercury was used on the NWNG system, but only in monometers and  not in natural gas metering equipment.
A decision was made by environmental  management of NWNG in 1986-87 to remove mercury manometers.
An investigation  has never been initiated to determine mercury releases from broken manometers  or potential mercury releases from old historic mercury containing equipment  which may have been used.
Risk:  1  Cost:  $3,000-$40,000  Onsite Disposal.
Other than the issues surrounding the manufactured gas  plants, in interviews with NWNG's environmental management, they were not  aware of any onsite waste disposal of any hazardous, toxic or non hazardous  waste.
Risk:   1  Cost:   undefined  Hazardous Waste.
There is only one location where hazardous waste is  generated and this location is a service center where a small parts washer is  used.
This site is classified as a conditionally exempt small quantity  generator.
The remainder of the NWNG system is a non generator of hazardous  waste.
Risk: 0  Cost:  0   NORMS.
The environmental management of NWNG has stated that natrually  occurring radioactive materials (NORMS) are not a problem in the pipeline  system.
Tesing has not been completed to verify or confirm this, nor does  NWNG have evidence to determine NORM status from Northwest  Pipeline Company.
Risk:  1  Cost:  $500  Underground Storage Tanks (UST).
There is only one regulated underground  storage tank (UST) remaining on the NWNG system (Albany), and this tank is in  complance with the UST regualtions for monitoring, testing and  recordkeeping.
All other underground tanks have been removed.
At one of the  tank removal sites, there exists  an active remediation in progress.
Closure  of this site is expected in the near future.
Risk: 1  Cost: $500  LNG plants.
In interviews with NWNG environmental management, there are no  histoirc or present outstanding environmental issues at the liquified natural  gas (LNG)  plants.
The exception to this is a historic site of a  manufactured gas plant (Linnton site) which underlies the LNG plant.
This  issue will be addressed under the section of the Linnton Manufactured Gas  Plant.
Risk: 0  Cost:  $0  Manufactured Gas Plants.
NWNG owned and operated  a number of manufactured  gas plants (MGPs).
Presented below are the MGP sites that NWNG owned or had  operating interest in for which there are associated liabilites and risks.
Eugene Water and Electrical Board.
The City of Eugene has determined that  a  parcel of property within the city has been contaminated by   numerous  responsible parties of which NWNG owned and operated a MGP during the time  period of 1958-1976.
The Eugene Water and Electrical Board  (EWEB), which is  the regulatory agency in Eugene,  has determined that the total cost to clean  the entire area will be approximately $1,300,000, of which  the EWEB has  indicated that NWNGs responsibility will be $93,750.
NWNG has offered to pay  compensation damages in the amount of $70,000-90,000 to  be relaesed from all  liability and damages associated with the contamination impacts to the City  of Eugene.
The environmental management of NWNG  has stated that the EWEB  has verbally and in principal agreed with the NWNG  offer of approximately  $94,000.
Risk: 1-2 Cost:  $94,000   Salem Site.
According to NWNG management, this historic MGP site has been  remediated and formally closed by the City of Salem, which is the    regulatory agency with jurisdiction over this site.
NWNG has received  endemnification and written closure from the City of Salem for this feature.
Risk: 1   Cost: $0   Manufactured Gas Plant.
This site, which ceased operation in the early  1900's, was dismantled and  abandoned.
From the time the facility ceased   operations, untill the present, a railroad has constructed a steel rail  bridge over the site and the City of Portland and constructed a city park.
The site is  immediately adjacent ot he Wilammette River, a major perennial  watercourse in Oregon.
There have been no soil, groundwater or river/ river  sediment   studies  completed  to determine potential environmental impacts.
NWNG environmental personnel have stated that the site was insured by Lloyds  of  London.
The insurance policies were not available at the time of this  due diligence to determine policy applicability and coverage amounts for this  site.
Risks: 2-3 Costs: 0-$300,000,000  Portland Harbor Superfund Site.
The Environmetnal Protection Agency has  determined that the Portland Harbor, on the Wilammette River,  has received  contamination of a sufficient nature and magnitude to warrent and classify  the 6.7 miles of the Harbor as a Superfund site.
This superfund site extends  for a distance of 6.7 miles and includes the Linnton and Wacker sites,  originally owned by NWNG.
The EPA has designated approximately 69 primary  responsible parties  which are directly or indirectly involved in the  contamination of this section of the Willamette River.
NWNG has been  identified as a contributing member to the contamination.
Linnton MGP/Wacker Site.
The Linnton MGP and Wacker Site, has 47 acres of  water front exposure on the Wilammette River and is included in the  Portland  Harbor Superfund Site.
The Linnton facility, which originally included the  Wacker Site,  initiated operation in 1913 and ceased operation in 1956.
During the operation of the  facility operation,  various organic coal tar  wastes, comprised of light non aqueous phase liquids (LNAPLs) and dense non   aqueous phase liquids (DNAPLs) were generated.
Characteristically these  waste products include: polynuclear aromatic hydrocarbons (PAHs), BTEX  and  cyanide.
During the early stages of facility operation, these wastes  were  originally directly deposited into the Willammette River, and then later, in   1941 unlined ponds were constructed at the facility.
Preliminary  investigation reports of the volumes of regulated waste from the facility  operations which  were released either directly or indirectly into the soil  underlying the facility or into the Wilamette  River were in excess of 4.6  million gallons or 23,000 cubic  yards.
It was also estimated from these  reports that there is approximately 250,000 cubic yards of tar and tar mixed  with soil underlying the historic tar  ponds.
Negotiations for cleanup and closure of this site may take up to 20 or more  years.
NWNG has stated that it has insurance policies from Lloyds of  London   which they feel will cover all costs assciated with NWNG's portion  of this superfund responsibility.
The policies were not availble during the  due diligence  to verify or confirm the amount of coverage.
Additionally,  because the horizontal and vertical extent of the contamination in the  subsurface soil,   groundwater and in the Willamette River sediments has not  been determined, it seems unlikely that insurance coverage can adequatley be  evaluated.
It  should also be mentioned that because the proportionate  extent of NWNGs contamination responsibility is not known, adequate insurance  coverage  appears to be somewhat premature.
Risk:  3  Cost:  $50,000,000-300,000,000