20070812 Ver 1_Alcoa Conditions Comments_20070827

ALCOA
August 24, 2007
Alcoa Power Generating Inc.
Yadkin Division
PO Box 576
Badin, North Carolina 28009-0576
Tel: [phone]
Fax: [phone]
www. a l co a. co m/yad ki n
Mr. John Dorney
North Cazolina Department of Environment and Natural Resources
Division of Water Quality
2321 Crabtree Blvd
Raleigh, NC 27604
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C)trws~ ~ `J1A7~~R C1UAL(lY
~ETLAt~U:; A:J(? ST,'x~F,~sy~1T~ BRAA~CH
Re: Proposed Condition in 401 Water Quality Certification for FERC Project No. 2197
Yadkin Hydroelectric Project No. 2197
Stanly County
DWQ # 2007-0812
Dear Mr. Dorney:
Thank you for your August 8, 2007 letter on behalf of the North Carolina Division of Water
Quality (DWQ) regarding Alcoa Power Generating Inc.'s (APGI) application for Clean
Water Act (CWA) Section 401 certification of its Yadkin Hydroelectric Project, and for the
opportunity to respond to the points raised therein. APGI appreciates the time and effort that
you and other DWQ staff have invested in the relicensing of the Yadkin Project and the
negotiation of the Yadkin,Relicensing Settlement Agreement (RSA). As you may recall, the
Yadkin RSA was filed with the Federal Energy Regulatory Commission (FERC) on May 7,
2007 as an offer of settlement of the relicensing issues on behalf of APGI and twenty-two
other settling parties, including the North Carolina Department of Environment and Natural
Resources. One non-settlor, the City of Salisbury, provided comments to DWQ on APGI's
certification application via a July 18, 20071etter urging DWQ to condition APGI's
certification on the implementation of certain flooding and sediment mitigation measures,
among other things. APGI agrees that many elements of the RSA, such as reservoir levels,
minimum flow releases and water quality improvements, are appropriately addressed in
DWQ's certification. APGI also agrees with DWQ's tentative conclusion that flooding is not
a 401 issue because flooding has never "interrupted water supply use" and the effects of
flooding are a property damage issue and not a water quality issue. However, for the reasons
outlined below, APGI respectfully disagrees with DWQ'S tentative conclusion that
sedimentation is a certification issue for the Yadkin Project.
1. DWQ Lacks Authority under the CWA to Certify Compliance with CWA Standards
at the Salisbury Public Water Supply Intakes
Section 401 of the CWA specifically allows States to certify whether "discharges" from
federally-licensed projects like the Yadkin Project will comply with State water quality
standards. The Salisbury intakes are approximately 19 miles upstream of the nearest point of
discharge at the Yadkin Project, i.e., the tailrace of the High Rock Dam, and there is no

finding by DWQ that the discharge affects that upstream sedimentation. Rather, DWQ cites
a finding by USGS that posits that the resence of the dam has "likely" caused an increase in
sedimentation at the upper end of High Rock Reservoir to a degree that the USGS analysis
does not attempt to define. Furthermore, DWQ staff stated at Yadkin relicensing meetings
that they would only address water quality impacts at the tailraces (such as certain dissolved
oxygen issues which were part of the RSA negotiations and are appropriately addressed in a
certification). APGI agrees with that DWQ staff interpretation of DWQ's responsibilities and
concurs that certification conditions for hydroelectric projects should be focused on water
quality issues at the tailraces.
2. DWQ Has Not Identified a Specific State Water Quality Standard That Has Been
Violated
Your letter refers generally to the "water supply use by the City of Salisbury" without
referring to a particular State standard that DWQ asserts has been violated because of the
operation of the Yadkin Project. APGI has reviewed the water quality standards adopted by
North Carolina pursuant to the CWA and does not believe that they lend themselves to
application against a downstream hydroelectric project that has not added any pollutants to
the waterbody.
3. DWQ Has Not Identified When or How a Specific State Water Quality Standard Has
Been Violated
As in the case of flooding, sedimentation has never "interrupted water supply use". No
evidence is presented in your letter to indicate that the deposit of sediment in the Yadkin
River -whether because of the presence of the dam or any other of a number of well-
documented natural processes and manmade obstacles - at or near the Salisbury's facilities
has actually caused a violation of North Carolina's water supply use standard or standards.'
Furthermore, neither of the USGS findings you cite in your letter concludes that the
presence or operation of Yadkin's Project has caused any violation of any standards. Finally,
your letter states that "sediment deposition resulting, at least in part, from the presence of
High Rock dam ~ remove the use of the water for water supply since the sediment could
make the intake inoperable..." (emphasis added). APGI believes this speculative finding
does not provide the basis for certification conditions.
4. DWQ Is Currently Relying on a Draft Report by the U.S. Geological Survey that
Does Not Evaluate the Most Current Information to Support a Sedimentation Article
in its Certification
The June 24, 2007 draft USGS report does not list APGI's most recent filing addressing
sedimentation, namely its "Answer and Reply Comments of Alcoa Power Generating Inc to
Comments, Recommendations Terms and Conditions, and Prescriptions Filed In Response
to Notice Of Application Ready For Environmental Analysis" (filed with FERC on June 25,
2007), in its list of references.
5. DWQ Is Currently Relying on a Draft Report by the U.S. Geological Survey that
includes Technical and Logical Flaws in it Summary and Recommendations to
Support a Sedimentation Article in its Certification
Your letter refers to the "uncertainties in the models used and the analysis thereof', which
APGI believes provides a sufficient justification for the State to forgo proposing
` APGI is unaware of any casein which the City of Salisbury has been unable to provide its citizens with
drinking water meeting State standards because of the quantity of sediment near its intakes.

certification conditions for upstream sedimentation issues. The State has an affirmative
obligation to find conclusively that a certification condition for sediment is technically
warranted before applying license conditions that will impose costs on APGI.
While the USGS study is generally well presented, its conclusions do not seem to follow the
analysis in the body of the report. Our specific concerns with USGS's findings include the
following:
(a) Under Purpose and Scope (USGS p.l), USGS states that the objective of the
study was to "clearly demonstrate that the presence of High Rock Dam has led to an
increase in water levels at Salisbury facilities.... [or] has not had an effect...". USGS later
states (USGS p.12, bullet 1) that the "actual increase in sediment deposition in the reach of
the Yadkin River between High Rock Dam and RM 19.4 attn~uted to the presence of the
dam cannot be determined from Copeland's results." Also, in its Summary and
Recommendations, USGS states that "the degree to which the dam and changes to the
bathymetry have affected flood levels... relative to the pre-impoundment conditions is open
to dispute... "(page 14, bullet 3). Taken together, these USGS statements mean that it is not
clear that the Dam has led to an increase in water levels; therefore the objective of the U5GS
study has not been or could not be achieved.
(b) USGS found that the Stone and Webster conclusion that "the water level at RM
19.4 was independent of the lake level at High Rock Dam," was "reasonably supported"
(USGS p. 5). USGS also found that FERC's modeling conclusions "were essentially the
same as for Stone and Webster" (USGS p. 9). However, in its Summary and
Recommendations (USGS p. l4, bullet 2}, U5GS only cites the results of the Hazen and
Sawyer report, which found an increase in the water levels due to the presence of the dam,
without referring to the contrary findings of the Stone and Webster or FERC report results.
(c) USGS found that the Hazen and Sawyer report was "poorly documented" (USGS
p. 10) and not "calibrated or compared to observed conditions", but then concludes that it
"seems tQ indicate ... increased water elevations" (USGS p. 14, bullet 2). Such a conclusion
can not be reached without fully understanding how the model was put together, what
assumptions were made, and without confirming the validity of the model in comparison to
observed data.
(d) Throughout the report, USGS emphasizes that there has not been a no-dam
condition modeled to determine the effects of High Rock Dam versus what could have
happened under natural conditions. Yet later USGS states (USGS p. 14, bullet 5) that the
Copeland report "provides a good understanding of the expected growth of the sediment
delta in the upper end of High Rock Lake". Without "no-dam" modeling this expected
growth cannot all be attributed to the presence of the Dam-in fact, the size of the sediment
delta may be no different than what would have occurred had the Dam never been built.
If DWQ elects to propose certification conditions for sedimentation in spite of the legal and
technical problems summarized above, APGI notes that it is a matter of public record that
APGI and the City of Salisbury have entered into a series of binding contracts that define
our respective responsibilities with regard to dredging and sedimentation around the City's
drinking water intakes. In those contracts, the City has agreed to forego holding APGI
responsible for any sedimentation around its intakes. Yet, notwithstanding the lack of any
legal obligation to do so, as DWQ notes in its letter, APGI, through a contract with Carolina

Sand Inc., a local dredging operation, has arranged to keep the area around the intakes
clear.2 To the extent that DWQ chooses to propose sedimentation language in its
certification, it should be consistent with those existing contracts in order not to frustrate
those agreements or otherwise interfere with the private arrangements between the parties
regarding sedimentation issues. Those agreements are attached as Attachments 1 and 2.
Thank you again for your willingness to solicit APGI's thoughts on DWQ's tentative
certification findings for the Yadkin Project. APGI is willing to continue to work with DWQ
on a certification that is grounded in good science, reflects the findings in the Yadkin
relicensing record and is consistent with the RSA. s
Sincerely,
V U
William Bunker
V.P. APGI Hydro Operations
Attachment 1: Alcoa Salisbury Agreement October 1927
Attachment 2: Alcoa Salisbury Agreement July 1969
cc without attachments:
Gene Ellis, APGI
D. Randall Benn, LLGM
Jim Mead, DWR
Marc Bernstein, NC AG
Darlene Kucken, DWQ
Matt Berhardt, SRU
Randall Tinsley, Brooks, Pierce
z To our knowledge there has only been one instance in the seventy-year history of the Yadkin Project when
the intakes were sufficiently clogged to require additional cleaning, and that event required only a few bows of
City employee time to remedy and did not cause a failwe by the City to provide potable water meeting all State
standards to its citizens. (Personal communication between Salisbwy Regional Utilities staff and APGI staff.
3In the alternative, it appears that DWQ may have already waived its certification authority in this proceeding.
APGI filed its application for CWA 401 certification with DWQ on May 10, 2007, and yow letter is dated
August 8, 2007. DWQ's regulations are clear that, subject to certain exceptions which do not appear to be
applicable here, all applications for certificafion shall be granted or denied within 60 days alter receipt at the
offices of the Director in Raleigh (see 15A NCAC 02H .0507}. APGI reserves its right to raise any and all legal
arguments in the event that it deems an appeal of a final certification is necessary.

---_~ _ __
l~~tT~ CA~t~~,I~t~i
~a~4RT (~~?U~iTy
T~S~ A~GI~~;R1~T, 'ac~c~ arhd entered. 3r~~o th~:~- the ~.~.,, da~r
o~ ~-~a.~ .+.., 197, b~ anii bet~ae~- ~I~'1C 0~' SAL~,~~'R'~'„ a
~un~,cipa3. Gor~porc~tion of the Mete of Forth Ca~o3lna., of t~ first
part. ~d ~AI.:C.,A~.~ PEAR Cfl,~iY, a Qorporation organised
e~cisting undor the 1s~~e of ~e t~tate oi' North Ca.rol4ua, wSth its
px°ineipa2 ofi'~.ee at Berlin, Alorth Garo3.ins,, oft' tie s®Conc~ pa~-ts

~~IBA~ , it ~ri13. bc~ n.e+ce°a~ary to m$~a cert~aia r~hanges ig
thy: City of dal isbury,s pixg I~1ant can acct off' t}ae crea6iau of
the high Rock Reeervo3r; and,
3~~I3,R~:A~, .t~~e Cit~- a~ Salisbury -anal the ~rtllaeaee PoN-er
Company have ~;reee~ upon ~.s terms hereinafter met .forth. with re-
sped to ~ertare ck~ss that ~y be neeeasary~ on asetrunt t3~iercof~
Nom, TH:1~f~Z~FORF~, in csQ~sideraton. of the pr+e~misea, the ~i
of ~a3.iabury dues Yierebg gxt to th+~ ~allaessee Power Com~ny, for
itsel;C~ its sursQeasore and. as~si~~s., th~a right to itspd water to
e.levatian ~t i'e~-t, 'i"a3laesee ~'aw®r Compaa~y c~atuan, ~-n s .and o2'
the City .Qf ~a2lsbu~r upon ^~ieh is a 3tuated its Ptping Plant at
~unctio~ oP the Borth and ~tru.th Fars of the Yadkin River.
Tl~.e ~a~.iaasee ~©vuer Compan;~, ~'or its4lf, its successora.
e.nd aes~L~s, before impouxulin~ wester on fihe p'umFi~ plant prop~e-rtYr
does hereby agree as i'olio~r~r
(a) To ra3.se the walls ans~ ot~t~rr~is~~~- r!~r-r~q„i±ann nP..t"~a-.
© reservo~r-s
(b1 To reconstruct the r©ad 1.cm~din~ to. the pumping Plant
so '~~~ t it wild, be above tl~e normal. w€~ter ieval in the res®rvo3r;
~~.-
i

(~) 7'A raiae t~~ Pik lip a~te~xd in,~ from #;ha ~3rag
p~.ax~t to tlys rave ,~r~ter ttk ~:o a~ ele~vs.t3.on s.bove the nr~x3, water
level in then r~sorvr~3.r.
~ die ~a~.lassee ~fl~asr Company far itse~.f, Sts sueaesso~~s
sand aasipns, does h©reb~ furth+sr s~,ree that, after tie high Ronk
re,~t~rtr~ar sha~:l ha~.ve beexi fii.lad with water,. it will s
{m) ~a such further changes, from t3am3 to tame ~d as
aa~a~ier~ stay regtt3:rr+s, 1n the Pi p1~t atzd water s~a.~apl:y ~# the
intak® ar~d P~Pi plant as m~ be ~aeoe~ssary to aeoura opasat~,rig oon-
d.itiwa~ts cvm~abxe tc~ and. a~ eft'icient 3.n ~a rapin#on tit' the City
Anil or other :gavern.~.~ bey ref the qty of ~tli$burs, Dlorth
Caraiit'~t, ae t'ho~l nom obts.ir~r,; a~ f~:trthar saw '~h+e : C~.t~" of
:~alis~ hsr.eas Prtam and ~.c~$s or dam~.~e Qf any rat ~tiats~iever
to said puffipi p~.ant and waiter ~Pl~' that may be ~ eared by ~~
e7~ettn at' the H3~h Rpt~k dam, ~e cr~at3on and ~a.iatenauce t~f the
impaun:~:i reeerv+~ir, and. axz~ acst,s or x~e~lect in the rat3+~t reb~
of the ~a~.3.aes~ dower Coatpang., its s~cessvrs or assis,-
(b) Keep tbe. Pi Piaxst intake free from trastruetious
due to ~31t, sand or debris o~ecasi.+©nsd by im;iound#aag water iat die
sa3.d reservoir.
(c) ~,.ou1d, the City of ~r~~.iebrury inaPeaaee the CaPac~ty ref
its P'umPing :plant by flee addit~.on of ~w unit,e thex+eto, at a tine
when the water in the hi~Ya; RQCk r~s+srvoir 3s above a ~rea~nt
normal ~~.evati42'~ Cif tY]:6 Ytat~r Sxa tine rSver $t t~2$ :l6~Piz~3saat:
TaYlsssee ~ar~er. Cox~paoy will. re~.mburse the G~,ty. cf " ~alis F for the
ea<oese coat s~f such a®tstguct3ons wh~,ch may be due to wetsr- 3u~-~it~nded.
in lei x°eee~ro3.r,
It !~s i'urther m~xtu$lly agreed urad~rr~tccrd; b~* atul betwe~in
the parties ha~to t3~t all oi` the above ~rark done an+~ t© be dc~e
b8 the ~g~.lassetr dower Cempax~y i.s to be dranw in a first oiass
~ror~arx~-like a~r~nr~or, at t~.e eacpense of the `:~a13.asaoe Pow~rr Ccmzpax~`,
and ~r3thout cost to the City of'~aligbury, and. t4 the satistaetien
of the City Counc3:1 or oth.®r governing bflt~y of the ~it3r df Falisburyr
Paarth Ga.rolina; andd 3.t 3s further agreed that in o.sae of any
emergency requi~"in~; immediate attention or wox-k, the City of Sa3.~.sbur~
., ,_. , _ 4_ _.,
!f. • _ J _ A:1 X11
Powor Con~aany, and cl~.rge the coat of sziczh wow to the ss.3d ..
Tal~.assee }"awex° tiompany.
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piiE7ARY pUd1.lG
~J1Y ~OMMIS5iQN EX?iR:i
~A~uARY 2u, ieso
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19~, by and bet~rien `fad?:in, Inc. , a corpcration organized and
existing under and by virtue of tble laws of the State of lZorth
Carolina, herein}after called "Yadkin", and the City of Salisbury,
a municipal. corporation located in Rowan County, North Carolina,
hereinafter called "Salisbury"; ',?3ITNESSETH:
WHEP.EAS, under an easement granted to Salisbury en
August 23, 1.916, by C. P1. Stewart and wife, Laura A. Stevrart,
recorded in Deed. Book 23, page 187, Davie County Registry,
Salisbury oanstructed and has maintained a twenty-inch water
rota;:e pipe across lands acquired by Yadkin from C. Yt. Step*art
and wife, Laura A. Stewart; and whereas, Salisbury now desires
to constru;,t two nezy intake pipes across the lands owned by
Yadkin;
NOT~d, iHEREEORE, in consideration of the premises,
Yadkin hereby does give and grant to•Salisbury a right of way
and easement across, over and: under its lands in Davie C:,uaity
on the South Yadkin and Yadkin Rivers for_the purpose of
constructing, maintaining, operating, inspecting, protecting,
repairing, or adding to twc new thirty-inch raw water intake
pipes and a nest intake station in the Yadkin :fiver at the
locations described as foI-lows:
TRACT 1: BEGINNING at contour elevation 555,.
Yadkin, Inc.datuni, on the west side of the South
Yadkin River and 15 feet on contour below the center
line of the existing Salisbury water intake pipe;
' thence No rthwardly~along contour elevation 655,
Yadkin, Inc. datum, ,100 feet, more or less, to a
point 15 feet above the center line of -the northern-
most proposed thirty.-inch water intake pipe; t:nence
parallel to and I5 feet Northwrardly fron the canter
line of the northernmost proposed pipe, crossing
the South Yadkin River, to a point on the eastern
side of tii~ South Yadkin River on cor_tour elevation
b5:,, Yacixin, Inc. datum; thence- following contour
elevation 655, Yadkin, Inc. datum,: in a Southzrardly
direction a distance of 100 feet, more-or Iess, to
a point 15 feet belc~~ the center line of the
existing twenty-inch pipe; thence in a Westwardly
direction parallel to and 15 feet Southwardly of the
existing ttrenty-inch-.pipe across the South Yadkin
River to the point o'f beginning, as outlined in rid
on Exhibit '_~:" which is~ attached hereto and Made a
rant hereiT_

i1-ne of the present Salisbury twenty-inch pipe; Lhencev-
- along contour elevation 655, Yadkin, Inc. datum, in a
- Northwardly direction 100 feet,- more or less, to a
point 20 feet above the center line of the northernmost
propesed thirty-inch pipe; thence in an Eastwardly
direction .into the Yadkin River parallel with and 20
feet above the center line of the northernmost proposed '
• thirty-inch pipe to a point approximately 45 feet into i
the Yadkin River; thence in a Southwardly direction
about •100 feet, more or less, to a point 15 feet below
- the present twenty-inch pipe; thence parallel with and
15 feet beloyr th,e present twenty-inch pipe in a ~-
Westwardly direction to the beginning, as outlined is `
red on Exhibit "A" which is attached hereto and made
a part hereof. i
This right of way and easement cover an area of
100 feet, more or less, along the west bank of the
Yadkin River and out into said river approximately
45 feet.
The rights herein granted to Salisbury are subject to
the license far Project No. 2197 granted by the Federal Power. ~.-
Commission under the Federal Power Act by order issued May 19, •
1958, to Carolina Aluminum Company and to any lawful require-•
ments of said Federal' Power Commission thereunder insofar as r~-
said easement affects the property within the boundaries of
Project No. 2197 and to any and all rights in and of the~Federal
Power Commission, Yadkin, its successors or assigns, or any
other party arising out of or granted by said license.
The rights herein granted to Salisbury are limited
to the purposes and uses set forth below and are subject to
and conditioned upon the limitations, covenants and conditions
set forth herein.
1. Salisbury may enter upon said easement areas to
construct, maintain, operate, repair, remove or add to, within
the limits 'of the same in a pxoper manner, a raw water intake,
the present twenty-inch raw water pipe, and two new• thirty-inch
xaw water pipes. The easement is granted solely for these
purposes, and the areas may rot ~e~entcred.for any other
purpose nor used ire any other manner than set forth in this
paragraph.

3. The parties agree that neither the easement granted
hereby nor any thing contained herein shall vest in Salisbury
the right ~at any time to interfere with,- restrict or in any
manner limit Yadkin's operations, rights, interests, privileges
and easements, including its rights and privileges of ownership
.. ..
and possession o£ its lands and water rights in, along and
contiguous t~o the South Yadkin and Yadkin Rivers in Worth
Cax'olina, the right to operate and maintain or abandon its
reservoirs, dams and electric generating facilities, or any
of them, in such~~manner and to such extent as in its discretion
may seem~proper,or be.deemed desirable, Lhe right to impound
waters in the reservoirs and maintain the same at any elevation E_
by~means of the existing dams, or as~said dams hereafter may
be~rebuilt or increased or decreased in height or capacity,
and the right to release and discharge or impound water from-
sai.d reservoirs at any time in the operation of its dams. and
hydro-electric generating facilities.
4. Yadkin reserves unto itself the right to use the
areas covered by this easement for any purpose it desires
which shall not prevent the full use and enjoyment by Salisbury
of the easement herein granted.
5. Salisbury shall defend; indemnify and save harmless
Yadkin, its successors and assigns, from all liabilities, losses,
damages, expenses, claims, demands, actions, or causes of actions
by reason of any injury ox damage to any person or to the property
of any person, firm or corporation, including the property of
Salisbury, and including officers, employees and citizens of
Salisbury, which injury or damage may in any manner whatsoever
arise out of or be connected with the construction, location,
operation, maintenance, flooding, clogging, or obstruction of

to obtain sufficient tti~atex from said Yadkin River for any
persons.
6. Salisbury will indemnify and save harmless Yadkin,.
its successors and assigns, from and against any and all claims
for liabilities for injury, including. death, to the person or
damage to the property of all parties whomsoever, when such
claims for liabilities arise Exam the use and enjoyment of the
easement granted herein or from the exercise by Salisbury of
the rights granted herein in connection therewith.
7. It is expressly understood and agreed by Salisbury
that the easement granted is partially within Yadkin's High
Rock Reservoir, and that the wader in said reservoir will be
subject~to the natural variations. caused by the rise and fall
in the Yadkin River, and subject further to such rise and fall
as the operation of all of Yadkin's water power developments
on the Yadkin River now constructed or that may hereafter be
,- constructed, may make ~necessaxy or desirable; and Salisbury
hereby covenants to and with Yadkin, its successors and assigns,
and. it hereby does absolve, .acquit and release Yadkin, its
successors and assigns, from any and all liability for injury
~or damage~to persons or property of Salisbury of those claiming
through or under Salisbury, arising from such rise and.fall
or from flooding to any elevation of the lands in which the
above-mentioned rights are granted.
~8. Notwithstanding anything contained in this agree-
- meat, Yadkin hereby unconditionally xeserves to itself, its
successors and assigns, the right to use the above-described
lands for all purposes of Project No. 2197.
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use of-Project No. 2197, and that this covenant shall run
with the rights herein granted..
10. Salisbury hereby agrees that it will make such
reasonable modifications in the. operation of its waterlines
for the protection of fish and wildlife resources in the High
Rock Reservoir as may be proposed from time to time by the
Federal Power Commission, and that it will operate such water
lines so as to conform to State and Federal water quality
standards .
11. It is understood and agreed that should Salisbury
.at-any time after the execution of this agreement fail to
use -for a continuous period of ,one year this easement, then
in that event, the easement herein granted shall terminate,
and Salisbury shall execute and deliver to Yadkin a written ~ '
..release in recordable'foYm. Salisbury, in addition to
executing the above-required .re'aease, shalh remove its
facilities at Salisbury's expense within one hundred twenty
days after the delivery of said release.-
.12. By the acceptance of the easement hereby granted,
Salisbury agrees that notwithstanding anything herein contained
or anything contained in that. certain agreement dated the
6th day of October, 1927, between the city of Salisbury and
Tallassee Power Company, that none of the obligations of
Tallasse~ Power Company (now named Yadkin, I-nc.) as set
forth in said agreement dated the 6th day of October 1927,
shall apply to or b8 of any force ~or effect insofar as they
might relate to or be: construed as relating to the new intake
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~-
properly authorized officers to subscribe and seal this
instrument, the day and year first above written.
YADKIN, INC.
(Corporate -Seal) ~'BY- ~ lgi ~ r,~_ ~~-r: ~'j'~;~~_,,_
~''~~ PresiZent JEP
HLH

J. E~.-rierryina.n- - ' ' ' - ' ' - ' ' - personally came before me Chas
day and acknotrledged that he is ~&
Secretary of Yadkin,
Inc., a corporation, and that by.authoxity duly given and as
the act of the corporation, the foregoing instrument was
signed. in its name by its Vice -Fresxdent, sealed with its
- corporate seal, and attested by himself as its Assistant
Secretary. .
WITNESS m hand and notarial seal the --31st
- day of
......Tnly ........ ~ 19- 69 .
SEAL
~~ ~ *~T~~ SnGan F~ Gotaizzi
NOTARX PUBLIC
.
Nlrs. Sa~a~ F. Cotatal, M~tarlr -.b11c
riy C Omml S 5 1 On e X 1 re's . . . . . . Pittsburpri, Anegbenr c.a~ir, Papna.
p _~ a r ~ h ? ~y 19 71 9Ay CMM~Oissia+ E,yaras
IMIIIM t~, tYri
NORTH CAROLINA
DAVIE .COUNTY
The foregoing certificate of ~~~ "
' ,
a Notary Public of the Commonwealth of Pennsylvania, Allegheny
County, is certified to be correct.
DATED ~~-....... .~ 19
REGISTER OF DEEDS

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