ML20195G050
| ML20195G050 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/13/1998 |
| From: | Mueller J NIAGARA MOHAWK POWER CORP. |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NMP1L-1381, NUDOCS 9811200174 | |
| Download: ML20195G050 (12) | |
Text
NiagarahMohawk'
^
John H. Mueller Phone: 315.349.7907 Senior Vice President and rex;31s.34g_1331 Chief Nuclear Officer e-mait muenerj@nimo.com November 13,1998 NMPIL 1381 Director Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555 RE:
Nine Mile Point Unit 1 Nine Mile Point Unit 2 Docket No. 50-220 Docket No. 50-410 DPR-63 NPF-69
Subject:
Guarantee ofRetrospective Premium Gentlemen:
Pursuant to the Commission's requirements stated in 10 CFR 140.21, enclosed are:
- 1. Consolidated Balance Sheets for Niagara Mohawk Power Corporation (NMPC) and its subsidiary companies for periods ending September 30,1998 and December 31,1997
- 2. Consolidated Statements of Income for NMPC and its subsidiary companies for periods ending September 30,1998 and September 30,1997
- 3. The 1998 internal cash flow projection for Nine Mile Point Units 1 and 2, which has been prepared in the format suggested in NRC Regulatory Guide 9.4
- 4. A narrative statement addressing cash flow, as certified by William F. Edwards, NMPC's Senior Vice President & Chief Financial Officer.
D l
981L200174 981113 ~*
PDR ADOCK 05 20 20005S Nme Mde Point Nuclear Station P0. Box 63, tycoming, New York 13093-0063
l l
l Page 2 If there are any questions on this material, we will be pleased to provide additional information.
l Very truly yours, John H. Mueller Senior Vice President and Chief Nuclear Officer JHM/Imc Enclosures xc:
Mr. H. J. Miller, Regional Administrator, Region I Mr. S. S. Bajwa, Director, Project Directorate I-1, NRR.
Mr. G. K. Hunegs, Senior ResiJent Inspector Mr. D. S. Hood, Senior Project Manager, NRR Document Control Desk Records Management i
l I
i NIAGARA MOHAWK POWER CORPORATION AND SUBSIDIARY COMPANIES l
CONSOLIDATED BALANCE SHEETS l
1 i
September 30, 4
1998 December 31, (Unaudited) 1997 (In thousands of dollars)
Utility plant:
l Electric plant 8
8,768,644 S
8,752.865 Nuclear fuel 598,888 577,409 Gas plant -
1,136,313 1,131,541 Common plant 322,042 319,409 Construction workin progress 522,688 294,650 Total utility plant 11,34s,ssa 11.075.874 Less - Accumulated depreciation and amortization 4,475,732 4,207,830 Net utility plant 5,sss,s33 6.868,044 Other property and investments 400,815 371,709 Current assets:
Cash, including temporary cash investments 1
of $219,307 and $315,708, respectively 266.946 378,232 Accounts receivable (less allowance for doubtful accounts of $51,100 and $62,500 respectively) 426,249 492,244 Materials and supplies, at average cost:
Coal and oil for production of electricity 27,607 27,642 Gas storage 41,800 39p7 Other 117,866 118,3w Prepaid taxes 58,066 15,518 Other 21,550 20,309 9ss,101 1,091,700 i~
Regulatory assets (Note 3):
MRA regulatory asset 4,133,521 7,516 Regulatory tax asset 406,424 399,119 Deferred finance charges 239,880 Deferred environmental restoration costs (Note 2) 220,000 220,000 Unamortized debt expense 51,814 57,312 Postratirement benefits other than pensions 53,642 56,464 Other 118,886 196,533 4 ss3,4s7 1,176,824 Other assets 129.114 75,864 S
13,341,330 9,584,141 i
i The accompanying notes are an integral part of these financial statements L
i 6
-. - -. - ~.. _. - -
f NIAGARA MOHAWK POWER CORPORATION AND SUBSIDIARY COMPANIES l
l CONSOLIDATED BALANCE SHEETS i
September 30, 1990 December 31, (Unaudited) 1997 (in thousands ofdonnes)
Capitalization:
Common stockholders' equity:
Common stock $1 par value; authonzed 250,000,000 and 185.000.000 shares, respectively; issued 187.364,863 and 144.419.351, respectuely 187,366 144,419 Capasi stock premium and expense 2,336,917 1,779,688 Retaned eemings 672,497 803.420 3,195,((W 2,727,527 Cumulative preferred stock, authortaed 3,400,000 shares, $100 per value:
Non-redeemmole (optionally redeemable), issued 2,100,000 shares 210,000 210,000 Redeemable (mandstanly redeemable), issued 204,000 and 222.000 shares, respectnely 18,600 20,400 Cumulative preferred stock, authorized 19,000,000 shares, $25 per value:
Non-redeemable (optonelly redeemebie), issued 9,200,000 shares 230,000 230,000 Redesmable (mandstoni redeemabie), issued 2.248,403 and f
2,581,204 shares, respectuely 50,390 56,210 505,www 515,610 Long-term debt 6,414,340 3,417,381 Total capitalization 10.12U.1Us 6,661,515 Currentliabilities:
Long-term debt due uthin one year 306,466 67,095 Sinking fund requirements on redeemable preferred stock 7,620 10,120 Accounts payable 163,076 263,095
' Payable on outstandmg bank checks 68,224 23,720 Customers' deposits 18,606 18,372 Accrued taxes 76,677 9,005 Accrued interest 128,260 62,643 Accrued vacabon pay 38,178 36,532 Other 79,822 64,756 574,U35 555,335 Regulatory and other liabilities (Wto3):
239.880 Deferred finance charges Accumulated deferred income taxes 1,491,176 1,387,032 Employee pensen and other benents 238,096 240,211 Deferred pension seesment gain 3,178 12,430 12,962 43,281 Untxiled revenues 381,796 224,443 Other -
2,127,195 2,147,285 Comenitments and contingencies (Notes 2 and 3):
220,000 220,000 Listakty for envronmental restorsbon l
13,341,330 9,584,141 L-I The accompanying notes are an integral part of these financial statements l
7
~
Note 2. Contingencies Environmental issues: The public utility industry typically utilizes and/or generates in its operations a broad range ofhazardous and potentially hazardous wastes and by-products.
The Company believes it is handling identified wastes and by-products in a manner consistent with federal, state and local requirements and has implemented tn environmental audit pmgram to identify any potential areas ofconcern and aid in compliance with such requirements. The Company is also cunently conducting a pmgram to investigate and remediate, as r+:-ty to meet current environmetal standards, certain properties associated with former gas manufacturing and other properties wid:S the Company has learned may be contaminated with industrial waste, as well as investigadng identified industrial waste sites as to which it may be determined that the Company contributed. The Company has also been advised that various federal, state or local a8cncies believe certain properties require investigation and has prioritized the sites based on available information in order to enhance the management ofinvestigation and remediation,ifnecce y.
The Company is currently aware of 125 sites with which it has been or may be associated, including 78 which are Company-owned. With respect to non. owned sites, the Company may be required to contribute some proportionate share ofremedial costs. Although one party can, as a matter orlaw, be held liable for all ofthe remedial costs at a site, regardless offault, in practice costs are usually allocated among PRPs.
Investigations at each of the Company-owned sites are designed to (1) determine if environmental contamination problems exist, (2) ifnecessary, determine the appropriate rW*1 actions and (3) where hypuriate, identify other parties who should bear some or all of the cost ofremediation. Legal action against such other parties will be initiated where appropriate. After site investigations are completed, the Company expects to determine site speciSc remedial actions and to estimate the Mae costs for restoration.
However, since investigations are ongoing for most sites, the estimated cost of remedial action is subject to change.
Einim=+a of the cost of remediation and post-remedial monitoring are based upon a variety of factors, including identified or potential contaminants; location, size and use of the site; proximity to sensitive resources; status ofregulatory investigation and knowledge of activities at similarly situated sites. Additionally, the Company's estimating process includes an initiative where these factors are developed and reviewed using direct input and support obtained from the New York State Department ofEnvironmental Conservation ("DEC"). Actual Company s++#mmes are dependent upon the total cost ofinvestigation and remediation and the ultimate determination of the Company's share of responsibility for such costs, as well as the financial viability ofother identified responsible parties since clean-up obligations arejoint and several. The Company has denied any responsibility at certain ofthese PRP sites and is contesting liability accordingly, 10
As a consequence of site characterizations and assessments completed to date an negotiations with PRPs, the Company has accmed a liability in the amount of$220 million, which is reflectai in the Company's Coesolidated Balance Sheets at 1998 and December 31,1997 The potential high end ofthe range is p.t ely esti at approximately $650 million, including approximately $285 million in the u the Company is required to assume 100% responsibility at non-owned sites. The 4
accrued at June 30,1998 and December 31,1997 low.yereies a change in the method used to estimate the liability for 27 ofthe Cn=paay's largest sites to mly upon a dec analysis appenach. This method includes developing several twinian approaches i
each ofthe 27 sites, using the factors previously described, and then assigning a probability to each approach. The probability represents the company's best estimate o the likelihood ofthe approach occurring using input received directly Som the DEC. Th probable costs for each approach are then calculated to arrive at an expected value. W t
this approach +Wes a range ofoutcomes for 'ench site, the Company has accrued the sum ofthe =paM values for these sites. The amount accmed for the Company's remaining sites is drw Jr.ed through feasibility studies or engineering estimates, the Ceg
/s estimated share ofa PRP allocation or where no better estimate is available the low end of a ran8e ofpossible outcomes is used. In addition, the Company has re. Ai a ra-"W~y asset swi=4--g the ren=Iwinn obligations to be recovered from ratepayers. PowerChoice provides for the continued gy;kek-ofdeferral accounting for cost differences resultin8 rom this efrort.
f In October 1997, the Company submitted a draR feasibility study to the DEC, which included the Company's Harbor Point site and five surrounding non owned sites. The i
study indicates a range ofviable remedial approaches, however, a final determination has not been made concerning the remedial approach to be taken. This range consists of a end of 522 million and a high end of$230 million, with an expected value calculation of
$51 million, which is included in the amounts acaued at June 30,1998 and D=-x 1997. The range represents the total costs to remediate the properties and does not consider contributions from other PRPs. The Company anticipates receiving comments fkom the DEC on the draft feasibility study by the summer of 1999. At this time, the Company cannot definitively predict the' nature ofthe DEC proposed remedial act or the range ofremediation costs it will require. While the Company does not expect responible for the entire cost to re--he these properties, it is not possible at this time to determine its share of the cost ofreamewton. In May 1995, the Company filed a comp 1=l* pursuant to applicable Federal and New York State law, in the U.S. District Court ibt the Northern District ofNew York against several defendants seeking re ofpast and fbture costs associated with the investigation and remediation of the Harbor Point and surrounding sites. The New York State Attomey General moved to dismiss the Company's claims against the State ofNew York, the New York State Department of Transportation and the Thruway Authority and Canal Corporation under the Comprehensive Environmental Response, Cn=padon and Dability Ad. &
Company opposed this motion. On April 3,1998, the Court denied the New York State Attomey General's motion as it W.s to the Thruway Authority and Canal Corporation, and granted the motion relative to the State ofNew York and the D@e.ar; of Tmr+c-ution. N case management order presendy calls for the close of dracovery on Dw.ukr 31,1998. As a result, the Company cannot predict the outcome ofthe pending 11
i l
i litigation against the defendams or the allocation of the Company's share of the costs to I
remedises the Harbor Point and autounding sites.
I Where approprima, the Ce=; y has provided notices ofinsurance claims to carriers with i
nspect to the investigmion and remediation costs for manufhetured gas plant, industrial i
waste shes and shes for which the Company has been identified as a PRP. To date, the Company has reached settlements with a number orineurance carriers, resulting in l
payments to the Company of approximstely $37 million, not of costs incurred in pursuing recovenes. Under PowerChoice approximately $33 million related to the electric i
business will be amortized over 10 years. Amd "y 34 million relates to the gas business and is being dad over the three year estatement period. hel====a j
l i
reesived during the PowerChence and gas settlement periods will be deferred, net ofcosts, and used to ofeet future costs ofenh r /.al remediation.
t l
l Tax amassaments: The Internal Revenue Service (" IRS") has conducted an examination of the Company's federal income tax returns for the years 1989 and 1990 and issued a Ravenue Agents' Report (RAR). The IRS has raised an issue concerning the daherihility l
of paymess made to IPPs in accordance with certain contracts that include a provision ihr s tracking accoum. A tracking account represents amounts that these mondmed contracts j
required the Cvy to pay IPPs in excess of the Company's avoided costs, including a j
w.rjks charge 'Ihe IRS proposes to disallow a current deduction for amounts paid in l
excess of the avoided costs of the Company. Akhough the Cornpany believes that any such disallowances for the years 1989 and 1990 will not have a material impact on its l
fkancial posidon or resuhs of operations, it believes that a disallowance for these above.
market payments for the years subsequent to 1990 could have a material adverse affect on its cash flows. To the exters that contracts involving tr.Lg accounts were terminated or restated or amended under the MRA wkh IPP Partiec as described in Note 3, the essets of l
any proposed disallowance has been climinated with respect te de IPP Parties covered i
under the MRA fbr periods subsequem to June 30,1998, h Companyisviguously j
deGending its position on this issue. hIRS also conducted an examination ofthe Company's federal income tax returns for the years 1991 through 1993 and recently issue i
a RAR. Based upon the Cvy's review of the report (which did not raise the IPP
(
trarking aeoours issue, akhough the issue could still be raised), the company does not believe that the findags will have a meterial impact on hs financial position or results of I
l CPersion.
I Note 3. Rate and Regelstery Issues and Contingencies The Company's financial staammama conform to GAAP, including the accounting pancipise for ramsulmed mahles wkh rapea to ita nsulatas op-tions. As diseumd below, the Company discontinued application of resulatory accounting pnnciple.t to the Company's fbesil and hydro
='=_ business. Substantively, SPAS No. 71 permits a public utility, regulated on a coster-service basis, to defer consin costs which would otherwise be charged to p=, when authorised to do so by the regulator. These 4
i defened costs me known as regulatory assets, which in the case of the Company are i
approximately 54,853 million at June 30,1998. These regulatory assets are probable of j
recovery. The portion ofthe $4,853 million which has been allarmad o the nuclear t
j 1
12 l
I 4
j
-~
j.,
i 1
genersdon and electric transmission and diaribution business is approximatel mima. Rasui.=y.s a anoemed to the rm.neulated sas diaribution businom are s98 million. As discussed below, the increase in the Commpany's regulatory aseats is attrib i
l to theMRA Regulatory Asset of $4,003 million. Generally, regulatory assets and liabilities were allocated to the portion of the business that incurred the underlying i
j treamarrian that resulted in the recognition ofthe regulatory ase:t or liability. The allocation n-+hade used between eleccic and ses are eensimes with those und in prior i
l regulatory proceedings.
8 The PSC, in its written order issued March 20,1998 approving PowerChance, determ to limit the estimmed value of the MRARegulatory Asset that can be recovered from i
customers to,, -M"y 54,000 mihn. As ofJune 30,1998, the Company had recorded an MRA Regulatory Asset ef 34,003 million, which repreents the recoverable J
i costs of the h0tA consisting of: (a) the cash @ of $3,631 million paid to the IPP Parties; (b) the issuance of 42.9 million shares of common stod valued at an i
aggregase of $343.6 million or $8.00 per share, based on the limitation on th l
the MRARegulatory Asast, as set forth in the PSC Order; and (c) expenses of t23.4 l
million related to the MRA. As a result of the PSC Order limitation, the Company recorded a noer. cash PowerChelee charge to semings of5263.2 niillion, or 31.15 per l
share, in the second quarter of 1998, upon the closing of the MRA, which represents man ci(1) the difttrence between the nst proceeds fhun the public sole of 22.4 million shares or 3303.7 million and the 38 per share mukiplied by 22.4 million shares or $179.2 j
million and (2) the diftbrance between the Caaa==y's common stock price of $14.75 at the time ofissuance and $3 per share nadtiplied by the 20.5 million shares issued.
Under PowerChoice, the Company's remaining electric business (nuclear generation l
electric transmission and distribution business) will continue to be _.-# *d o cou of-service basis and, E.,0. gly, the Company a=*huma to apply SFAS No. 71 to i
thesebusinesses. Also,theCompany'sIPPcontracts,includingthoserestructuredunde the MRA, will==* hum to be the obligations ofthe dd business. Under 4
Powercheiee, the Company is required to not certain regulatory assses and liabilities.
l l
Ah h the Company has not yet implemented the tartfB reisted to PowerChoice, it ha t
reflected these changes in its June 30,1998 hal==a= sheet.
4 i
The ETF ofthe FASB ranched a consensus onIssus No. 97 4 " Deregulation of the Pricing ofElectricky -Issues Related to the Application of SFAS No. 71 and SFA 10l* in July 1997. ET797-4 does not require the Company to earn a return on re
==== that ades tom a dersplating transaion plan in assessing the appbcability c(SFA l
No. 71. 'Ibe Company believes that the regulated cash flows to be derived from p J
i will charge ihr electric service over the next to years, inchaling the Competitive Transition Charge ("CTC") assuming no unforeseen reduction in demand or by l
CTC or scit fees, will be sufficient to recover the MRA Regulatory Asset and to recovery of and a return on the remainder ofits assets, as appropriate. In the e Company determines, either as a result oflower than aspemed revenues or h amar**d costs, that its net regulatory asues are not recoverable, it een no lon j
principals of SFAS No. 71 and would b*s regered to record en sitar tax non se againa income fbr any remaining unamortiasd regulatory assets and liabilities. I l
!L-
Company could no longer apply SFAS No. 71, the resuking charge would be material to the Company's reported financialMan and resuha ofoperations and adversely effect the Company's ability to pay dividends. It is expected that the PowerChance agreement, while having the effinct of substantially depressing earnings during its five year term, will substantially improve w iri cash flows.
With the implementation of FewerChoice, specifically the separation ofnon nuclear generation as an entity that would no longer be cost-of eervice regulated, the Company is requand to assess the carrying amounts of ks long-lived assets in accordance with SFAS No.121. SFAS No.121 requires long-lived assets and certain identianhie intangibles held and used by an anary to be reviewed fbr impairment whenever events or changes in circumstances indicate that the carrying amount of an amet may not be recoverable or when assets are to be disposed of. In perfbrains the review for recovaability, the Cm is required to aminuta future imdi-mead cash flows expected to resuk from the use of the asset and/or its disposition The Cmy has determined that there is no impairment of such assets The Company plans to divest its ibseil and hydro generating assets. In the event the proceeds resuking froen the sale of the fossil and hydro assses are not sufficient to avoid a loss, under the terms ofFowerChoice the C~-- y would be able to recover such loss through the CTC. The PowrChoice agreemsat provides for defbmd and fbture recovery oflosses, if any, resulting from the sale orthe non-nuclear generating assets. The Company believes that h will be permitted to record a regulatory asset for any such loss in accordance with EITF 97 4. The C~aaaay's fossil and hydro e
'y $1.1 billion at June 30, generation plant assets had a net book value ofigr 1993. (See hem 2. h's;=r's Discussion and Anc)ysis ofFinancial CW% and ResuksofOperations "PowerChoice Ayum").
14
. i__
1 l
l NIAGARA MOHA WK POWER CORPORA TION rmanouAnresarronr CONSOLIDATED STATEMENTS OF INCOME 6 thousense of Womers Three Morens Ended Nine Monme Ended Twehas Monme Ended Negere Monswe Power Cor=eremon Septenter 30.
Sesteneer 30, Seeteneer 30 and Subsurery Comparwes tunauoded) ites teef 1000 19e7 stes tee 7 OPERATWO REVENUES:
Ewina Cae.
$400.007
$427.007
$2.800.M8
$2.500,003
$3,3es.000
$3.333.618 71.e34 es 473 433.303 4es.4e7 8e4.30s e43see e30.e31 8e0.570 2.eSe est 3 00s.100 3.teeJ48 3 e77.20e OPERATWO EXPENSES:
Fuse for esectnc generemon-et.Me
$4.474 17eA33 127,331 23e,887 147,187 Elecceny purchased.
240.000 2e3.324 ses 877 ese.125 1,143,ees 1.247,567 Gas surcnased 30.700 41.e25 214.372 253.140 300,083 320.360 Other operemon and meneenance empena==.
222Aet toe.cos 007,707 808.282 e37,0e7 ese se4 Amerhtshon of the MRA regulatory aseet,
32,104 32,1M 33,104 PowerChodce charge...
2e3,337 303,337 Oeprooshon and amortarshop 88.707 e5.144 204.ee0 254.100 30s.412 337.315 Othertanes.
114.830 112.820 300.001 354 21e 474.212 400.051 e20.344 1e8 300 2.070.101 2.S33.2es 3.7e4.43 t 33ee.6 ~50 OPERATWO INCOME..-
110,287 110.174 e3.700 472.815 140,704
$90.047 Other meome.
48 e24 7.444 47.eSe 20 tes 81,764 41 tit WCOME BEPORE INTEREST CHARGES...
100,311 117.e68 111,300 4e3.300 3e1,048 031,758 Inserest enareas...
133.000 es 300 240,100 206.280 333.70s 274.078 WCOME (LOSSI BEPORE PSOERAL & POREION INCOtet TAXES....-..
21,es3 40.270 (103.72e) 2ee.404 (133,307) 357.000 Federal a foreign income taxes...
4.see 17.599 fee.3371 112.e64 (38.eest 140.470 INCOME (LOSS) SEPORE EXTRAOROWARY lTEM.-
17,e83 31,083 (103.382) 175.454 (98,811) 217.010 Estraorenery morn for the desconenuance of regulatory accounhng pntco6es, not of ecome teses of $3e.273 (67.384)
NET INCOME (LOSS).
17,e83 31,083 (103,3e3) 175,454 (98,811) 140.044 Dividonos on prodened stock..
e.137 e 363 27.831 28.1e1 38.707 37.882 SALANCE AVA8LASLE POR COMe00N STOCK.
$8.814
$22.330 (8134.8231
$147.203 (1132270)
$11Isee Oversee numeer of sharea of commen stock outstanding (In thousaneet 107,3ee 144.417 tet.see 144.300 104,383 144.3e1 Seate and diluted earnence (lese) pet eversee ehese of common eteek before omtresseenery===
leas
$0.t 8 (98,et)
$102 (St.es)
$1.25 Estraereinery leem...
(10 47)
Basis and 440sted semines (tesel per overses ehese of esamen e*-a 30.00
$0.15 (84A21
$102 (etAsl
$0.7e Other Operatene Date:
Eamenge before ireareat charges, interest income, income tanos. doorecionen and amoreesson, and other reqpetory adsueeneres (ESITDA)
$330,40s
$738,339
$e81.707 Net caen mierest
$138,288
$231,3e1
$3s7,00s Rate of ESITDA to not cash meerest 2.4 3.1 3.1 Netos:
- The abow miermanon to not gnen m connocean with any sase or o#er to sea or twy any geock or escunty.
- The Company slee genoeic resorte sureuere to the Secunhoe Exchange Act of 1934. Accareerigly, with respect to me Ananoisi informanon est form ebew. you are requested to refer to sucm Sings for more esteend mdormenon l
l
NIAGARA MOHAWK POWER CORPORATION 1998 INTERNAL CASH FLOW PROJECTION, cubmittid as guirantxs l
of payment of retrospective premiums for Nine Mlle 1 and Nine Mlle 2 Nuclear Power Stations j
increase (Decrease)in Cash L
(in Thousands of Dollars) i 1997 1998 Actual (P_rojected)
Netincome
$183,335
($112,544) l Less: Dividends Paid 37,397 34,548 l
Retained Earnmes
$145,938 (149,112)
Adjustmentsi PowerChoice charge 0
263,227 Amortization of MRA regulatory asset 0
122,184 Depreciation and amortization 339,441 331,854 Amortization of nuclear fuel 25,241 34,528 Provision for deferred income taxes 44,994 (74,942)
Changes in other assets and liabilities (57,636) 118,712 l-
. Total Adjustments 354,240 795,563 Intemal Cash Flow Provided by Operating Actmties
$500,178
$646451_
Average Quarterly Cash Flow -
$125,045
$161613_
1 Nuclear Units Operated:
Nine Mile No.1 Nine Mile No. 2 Mr.ximum Total Annual Contmgent Uability
$20,000 l-i
. =.
~
It is Niagara Mohawk's view that the curtailment ofcapital expenditures to ensure payment of possible retrospective premiums of up to $20 million would not be a material problem as this amount represents only about 7.0% of currently scheduled construction
- expenditures, net of Allowance for Funds Used During Construction (AFC) for the year 1998.
Date: November 4,1998 CERTIFIED:
NIAGARA MOHAWK POWER CORPORATION fA v
William F. Edwa'rds Senior Vice President and Chief Financial OfTicer 1
l
-,