NC0090239_Application_20230406

/1COovo9
March 20, 2023
RECEIVED
Mr. Sergei Chernikov APR 03 2023
Division of Water Resources
Water Quality Permitting Section - NPDES NCDEQ/DWR/NP�ES
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Individual NPDES Permit Application
Eli Lilly and Company - Concord
1420 Concord Parkway South, Concord, North Carolina 28027
Dear Mr. Chernikov:
Eli Lilly and Company (Lilly) is pleased to submit this NPDES permit application for the
proposed discharge of HVAC condensate comingled with stormwater that meets no exposure
certification requirements from Lilly's Concord facility (Facility) located at 1420 Concord
Parkway South, Concord, NC, in Cabarrus County. This facility will be a manufacturing facility
for pharmaceutical products, and operations will include filling syringes with formulated
product and assembling devices for parenteral products. The construction of the facility
utilities is estimated to be completed by end of October 2023. HVAC testing is expected to
begin in March 2024, with a full-scale HVAC operation starting in August 2024, however,
syringe filling activities will not begin until early 2025 and device assembly and packaging
will start in mid-2024.
All process wastewater (non -contact cooling water, equipment wash water, etc.) and
sanitary wastewater will be discharged to Cabarrus County's municipal sewer system under
Lilly's Industrial User Permit (IUP) to be issued by Cabarrus County. In addition, the IUP
permit must be issued based on no clean condensate being present, which is strictly
prohibited by the Sewer Use Ordinance of Cabarrus County (Section 2.1.b.14). The only
wastewater proposed for NPDES permit coverage will be the clean condensate from the
building HVAC systems, which will be mixed with onsite stormwater which NCDEQ staff
should be able to determine the site would be eligible for a "no exposure" determination.
Lilly does not use any chemical additives for the HVAC systems that generate the condensate
that will be discharged under this permit. Clean condensate will be discharged to the site
stormwater sewer system, and flow to an existing stormwater retention basin with normal
hydraulic capacities of approximately: BMP1 - 105,821 ft3 COMM gallons), BMP2 - 320,735
ft3 (2.4M gallons), and BMP3 - 864,174 ft3 (6.5M gallons) for a total of 1,290,730 cubic feet
(9.7 million gallons). Any rainfall will cause the ponds to discharge water to the wetlands
as they are not designed to permanently store rainwater, only to release the runoff slowly to
the wetlands which subsequently discharges to Coddle Creek. The designed minimum
holding time for HVAC condensate in the retention basin is approximate 560 days. In
addition, this facility is designed and constructed to meet the North Carolina stormwater no

Page 2 of 2
NPDES Permit Application
exposure standard. Based on a telephone conversation with you on December 7, 2022, Lilly
is providing the following information in the Permit Application Package:
• EPA Form 1 with facility location map.
• EPA Form 2E.
• EPA Form 2F with stormwater drainage (Sheet C6.30) and retention basin design
(Sheets C.24-26)
• Engineering Alternative Analysis for the proposed discharge.
• A check in the amount of $860 for a new Category -A Minor Individual NPDES permit
application fee.
Thank you in advance for your assistance in processing this permit application. If you have
any questions regarding the information provided, please contact Jamie Hunter, Eli Lilly and
Company Concord Site HSE Director at 980-356-0790 or by email at jamie.hunterPlilly.com.
Very truly yours,
Eli Lilly and Company + n
Rosa Manso __ 71I - Cl1Ly ��Z
Site Head, Eli Lilly and Company Concord
cc: Jamie Hunter - HSE Director, Eli Lilly and Company Concord
Brian Griesemer, PE - HSE Senior Associate, Eli Lilly and Company, Indianapolis, IN

EPA Identification Number
NPDES Permk Number
Facility Name
Form Approved 03/05/19
N/A
N/A
Eli Lilly and Company - Concord
OMB No. 2040-0004
Form
U.S. Environmental Protection Agency
1
�i►EPA
Application for NPDES Permit to Discharge Wastewater
NPDES
GENERAL INFORMATION
SECTION•
r
1.1
IApplicants Not Required to Submit Form 1
1 1 1
Is the facility a new or existing publicly owned
1.1.2
new or existing treatment works
treatment works?
stic sewage?
If yes, STOP. Do NOT complete 0 No
o NOT No
=2S.
Form 1. Complete Form 2A.
1. Complete
1.2
Applicants Required to Submit Form 1
1.2.1
Is the facility a concentrated animal feeding
1.2.2
Is the facility an existing manufacturing,
€
g
operation or a concentrated aquatic animal
commercial, mining, or silvicultural facility that is
production facility?
currently discharging process wastewater?
cYes
4 Complete Form 1 0 No
Yes 4 Complete Form 0 No
z
and Form 28.
1 and Form 2C.
A
1.2.3
Is the facility a new manufacturing, commercial,
1.2.4
Is the facility a new or existing manufacturing,
01
mining, or silvicultural facility that has not yet
commercial, mining, or silvicultural facility that
commenced to discharge?
Yes + Complete
discharges only nonprocess wastewater?
Form i No
Yes Complete Form No
b
and Form 2D.
1 and Form 2E.
1.2.5
Is the facility a new or existing facility whose
discharge is composed entirely of stormwater
a
associated with industrial activity or whose
discharge is composed of both stormwater and
non-stormwater?
Yes 4 Complete Forth 1 No
and Form 2F
unless exempted by
40 CFR
122.26(b)(14)(x) or
b 15.
�ECTION
2. NAME,
MAILING ADDRESS, AND LOCATION (40 CIFIR 122.21(f)(2))
2.1
Facility Nan*
Eli Lilly and Company - Concord
`g
2.2
EPA Identification Number
N/A
v
is
2.3
Facility Contact
d
Name (first and last)
Title
Phone number
Q
Rosa Manso
Site Head - Ell Lilly - Concord
[phone]
Email address Y)Ii2Vr'o+c— C-o'M-vC+ ' 'QyrliG iir tVlfe i1
[e-mail] seolar ji l i CC:fV Y C7'F 1--Icd-t?iYi 6"V i
,Sd t Vl76'1 i'vi
E
2.4
Facility Mailing Address 0r0ie'0ucTtcr@_bfly, c-om cl$p- SLO.p4gp
z
Street or P.O. box
PO Box 5070
City or town
State
ZIP code
Concord
North Carolina
28027
EPA Fonn 3510-1 (revised 3-19) Page 1

EPA Identification Number
NPDES Permit Number
Facility Name
Form Approved 03/05/19
N/A
N/A
Eli Lilly and Company - Concord
OMB No. 2040-0004
a d
2.5
Facility Locadon
v `
Street, route number, or other specific identifier
a to
rn
142O Concord Parkway South
$
County name
County code (if known)
Cabarrus
E
City or town
State ZIP code
z m
Concord
North Carolina 28027
SECTION•
NAICS CODESr
3.1
SIC Codes)
Description (optional)
2834
Pharmaceutical Preparations
N
N
a
0
c�
N
V
z
a
3.2
NAICS Code(s)
Description (optional)
c
325412
Pharmaceutical Preparation Manufacturing
ca
4.1
Name of Operator
Eli Lilly and Company
4.2
Is the name you listed in Item 4.1 also the owner?
❑ Yes ❑ No
4.3
Operator Status
❑ Public —federal ❑ Public —state ❑ Other public (specify)
c
0 Private ❑ Other (specify)
4.4
Phone Number of Operator
[phone]
4.5
Operator Address
°
Street or P.O. Box
d
PO Box 5070
City or town
State
ZIP code
c
$ V
C
Concord
North Carolina
28027
g
Email address of operator
0
SECTION•
.
Is the facility located on Indian Land?
c
❑ Yes ❑� No
EPA Form 3510-1 (revised 349) Page 2

EPA ldenfificadon Number NPDES Permit Number Facility Name Form Approved 03/05119
N/A N/A Eli Lilly and Company- Concord OMB No. 2040-0004
SECTION• I
6.1 Existing Environmental Permits (check all that apply and print or type the corresponding permit number for each)
E®
NPDES (discharges to surface
❑ RCRA (hazardous wastes)
❑ UIC (underground injection of
E
water)
fluids)
c
o
❑ PSD (air emissions)
❑ Nonahainment program (CAA)
❑ NESHAPs (CAA)
c
M
❑ Other (specify)
❑ Ocean dumping (MPRSA)
❑ Dredge or fill (CWA Section 404)
SECTIONr
7.1
Have you attached a topographic map containing all required information to this application? (See instructions for
a
specific requirements.)
A
❑✓ Yes ❑ No ❑ CAFO—Not Applicable (See requirements in Form 2B.)
SECTION
8. NATURE
OF BUSINESS (40 CFR 122.21(fl(8))
8.1
Describe the nature of your business.
This facility will manufacture pharmaceutical products by filling syringes with formulated product and will assemble
2
devices for parenteral products. All process wastewater will be discharged to Cabarrus County's sanitary sewer
0
system under an Industrial User Permit (IUP) issued by Cabarrus County. Surface discharge from the facility only
consists of HVAC condensate and stormwater runoff from the site that meets the no exposure certification
m
requirements. No additives are used in the HVAC systems.
0
m
m
2
SECTION••
r
9.1
Does your facility use cooling water?
d
❑� Yes ❑ No 4 SKIP to Item 10.1.
9.2
Identify the source of cooling water. (Note that facilities that use a cooling water intake structure as described at
o w
40 CFR 125, Subparts I and J may have additional application requirements at 40 CFR 122.21(r). Consult with your
— „
O Y
NPDES permitting authority to determine what specific information needs to be submitted and when.)
u
The source water for the cooling tower system is municipal potable water supply; the cooling water system is not
subject to 316(b) rule. Cooling water will be discharged to Cabarrus County Sanitary Sewer System via the facility's
Industrial User Permit issued by Cabarrus County.
SECTION•
1 r
10.1
Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)? (Check all that
u
apply. Consult with your NPDES permitting authority to determine what information needs to be submitted and
d
when.)
d
❑ Fundamentally different factors (CWA ❑ Water quality related effluent limitations (CWA Section
d
Section 301(n)) 302(b)(2))
A
❑ Non -conventional pollutants (CWA ❑ Thermal discharges (CWA Section 316(a))
Section 301(c) and (g))
❑Q Not applicable
EPA Form 3510-1 (revised 3-19) Page 3

EPA Idenfifiabon Number NPDES Permit Number Facility Name
Fonn Approved 03/05/19
N/A N/A Eli Lillyand Company -Concord
OMB No. 2040-0004
SECTION•
CERTIFICATION STATEMENT (40
11.1
In Column 1 below, mark the sections of Form 1 that you have completed and are submitting with your application.
For each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note
that not all applicants are required to provide attachments.
Column I
Column 2
❑� Section 1: Activities Requiring an NPDES Permit
❑ wl attachments
❑� Section 2: Name, Mailing Address, and Location
❑ w/ attachments
❑✓ Section 3: SIC Codes
❑ wl attachments
❑� Section 4: Operator Information
❑ w/ attachments
❑✓ Section 5: Indian Land
❑ wl attachments
Section 6: Existing Environmental Permits
❑ w/ attachments
d
d
Section 7: Map
❑ w/ additional
n
matopographic
attachments
o
Section 8: Nature of Business
❑ w/ attachments
.7;;
w
Section 9: Cooling Water Intake Structures
❑ w/ attachments
r
a
a
❑� Section 10: Variance Requests
❑ w/ attachments
c
_�
❑� Section 11: Checklist and Certification Statement
❑ wl attachments
Y
r
11.2
Certification Statement
U
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision
in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significantpenalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Name (print or type first and last name)
Official title
Rosa Manso
Site Head - Eli Lilly - Concord
Signature
Date signed
I
�- JA
Z q -Mar 202- C1
EPA Form 3510-1(revised 3-19) Page 4

EPA Identification Number
NPDES Permit Number
Fadlity Name
Forth Approved 0305119
OMB No. 2040-0004
U.S. Environmental Protection Agency
FORM
2E
Application for NPDES Permit to Discharge Wastewater
NPDES
ISEPA
MANUFACTURING, COMMERCIAL, MINING, AND SILVICULTURAL FACILITIES WHICH
DISCHARGE ONLY NONPROCESS WASTEWATER
SECTIONOUTFALL
LOCATIONr
1.1 Provide information
on each of the fadli 's outfalls in the table below.
0
Numllr
be
Receiving Water Name
Latitude
Longitude
J
1
Wetlands to Coddle Creek
35' 23 27.0• N
-so* 38 6.3" W
2
Wetlands to Coddle Creek
35" 23 29.1" N
-80" 37' 40.7" W
O
3 Wetlands to Coddle Creek 35° 23 32.7" N -80" 37• 59.3" W
SECTIONDISCHARGE
s• I
2.1
Are you a new or existing discharger (Check only one response.)
Lm
c
1 [a New discharger ❑ Existing discharger 4 SKIP to Section 3.
H
2.2
Specify your anticipated discharge date:
is06/30/2023
1
SECTIONr
3.1
What types of wastes are currently being discharged if you are an existing discharger or will be discharged if you are a
new discharger? (Check all that apply.)
❑ Sanitary wastes 0 Other nonprocess wastewater (describe/explain
❑ Restaurant or cafeteria waste directly below)
❑ Non -contact cooling water HVAC condensate mixed with stormwater
3.2
Does the facility use cooling water additives?
m
a
❑ Yes No + SKIP to Section 4.
3
3.3
List the cooling water additives used and describe their com
Dosition.
Cooling Water Additives
Composition of Additives
list
davailable to u
No additives added to HVAC systems
No additives added to HVAC systems
SECTIONr
4.1
Have you completed monitoring for all parameters in the table below at each of your oulfalls and attached the results to
this application package?
❑� Yes New Discharge No; a waiver has been requested from my NPDES permitting authority
attach waiver request and additional information 4 SKIP to Section 5.
4.2
Provide data as requested in the table below.' See instructions
fors specifies.)
Number of
Maximum Daily
Average Daily
Source
Parameter or Pollutant
Analyses
Discharge
Discharge
(Use codes
(if actual data
s units)
(specifi units
per
Malta
Conc.
Mass
Conc.
reported)
mstructlons)
tBiochemical
oxygen demand (BOD5)
N/A
N/A
N/A
2-Estimated
Total suspended solids (TSS)
N/A
N/A
N/A
2-Estimated
Oil and grease
N/A
< 5 mg/L
<5 mg/L
2-Estimated
Ammonia (as N)
N/A
N/A
N/A
2-Estimated
Discharge flow
N/A
8622 GPO
4-Estimated
pH (report as range)
N/A
6.0-9.0 su
4-Estimated
Temperature (winter)
N/A
< 28 degrees C
4-Estimated
Temperature (summer)
N/A
<32 degrees C
4-Estimated
Samplino shall be conducted accordine to sultldentN sensitive test procedures
fi.e.. methods) mmmved
under an r.FR 11A s,rrhos"swds
"r,,.,m,m"k,..,•,.m,w•„
parameters or required under 40 CFR chapter I, subchapter N or 0. See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2E (revised 3.19) Page 1

EPA Identification Number
NPDES Permit Number
Facility Name
Form Approved 03105/19
OMB No. 2D40-0004
4.3
Is fecal coliform believed present, or is sanitary waste discharged (or will it be discharged)?
❑ Yes No 4 SKIP to Item 4.5.
4.4
Provide data as requested in the table below.'
See instructions forspecifics.)
Number of
Maximum Daily
Average Daily
Source
Parameter or Pollutant
Analyses
Discharge
Discharge
(use codes
(aactualdae
units
units
per
Mass
I Cone.
Mass
I Cone.
reported)
Instructions.)
Fecal colifonn
E soli
e'
Enlerocecci
3
4.5
Is chlorine used (or will it be used)?
i;
❑ Yes ❑ No + SKIP to Item 4.7.
4.6
Provide data as requested in the table below.t See instructions forspecifics.)
Number of
Maximum Daily
Average Daily
Source
rParameter
or Pollutant
Analyses
Discharge
Discharge
(use codes
=
(t actual data
units
units
per
Mass
Cone.
Mass I Cone.
c
reported)
instructions)
Total Residual Chlorine
w
4.7
Is non -contact cooling water discharged (or will it be discharged)?
❑ Yes ❑� No 4 SKIP to Section 5.
4.8
Provide data as requested in the table below.t
See instructions forspecifics.)
Number of
Maximum Daily
Average Daily
Source
Parameter or Pollutant
Analyses
Discharge
Discharge
(use codes
(e actual data(specify
units
eci units
per
Mass I
Cone.
Mass I Cone.
reported)
instructions)
Chemical oxygen demand (COD)
Total organic carbon (TOC)
SECTION•
r
5.1
Except for stormwater water runoff, leaks, or spills, are any of the discharges you described in Sections 1 and 3 of this
application intermittent or seasonal?
[0 Yes 4 Complete this section. ❑ No 4 SKIP to Section 6.
5.2
Briefly describe the frequency and duration of flow.
LL
HVAC condensate will flow to the on -site stormwater retention basin with a hydraulic capacity of approximate
1,290,730 cubic feet (9.65 million gallons). When the water depth in the stormwater retention basin reaches 7.5 (XxxX)
feet, discharge will occur to wetlands that eventually discharges to Coddle Creek. Daily volume of condensate is
dependent on ambient temperature and humidity fluctuations, expected to be higher in the summer months. The
ralniUtad minimum hnldina times fnr NVAr rnndpncatp in the ratantinn hacin is S6n davc IM
SECTIONI
E
6.1
Briefly describe any treatment system(s) used (or to be used).
&
There is no treatment system for HVAC condensate at the site. The condensate does discharge
�+
through the site stormwater retention basin.
sampling snap De conaucted according to sumdently sensitive test procedures (i.e.. methods) approved under 40 CFR 136 for the analysis of pollutants or pollutant
parameters or required under 40 CFR chapter I, subchapter N or 0. See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2E (revised 3-19) Page 2

EPA
Identification
Number NPDES Permit Number Facility Name Form Approved 03/05/19
OMB No. 2040-0004
7.1
Use the space below to expand upon any of the above items. Use this space to provide any information you believe the
reviewer should consider in establishing permit limitations. Attach additional sheets as needed.
c
The HVAC condensate is generated by the condensation of water vapor (humidity) on the outside of the HVAC cooling
a
coils. The maximum flow rate of HVAC condensate to the stormwater retention pond is 8,622 GPD. The hydraulic
•�
capacity of the stormwater retention basin is 1,290,730 cubic feet (9.65 million gallons), with a 154,284 square feet of
surface area. The maximum hydraulic retention time of HVAC condensate in the basin is 1,120 days, using a safety
o
factor of 2, the estimated minimum hydraulic retention time of HVAC condensate in the basin will be approximately
005
560 days before discharge to wetlands that eventually releases to Coddle Creek
SECTION
8. CHECKLIST
AND CERTIFICATION STATEMENT (40 CFR 122.22(a) and (d))
6.1
In Column 1 below, mark the sections of Form 2E that you have completed and are submitting with your application.
For each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note that
not all applicants are required to provide attachments.
Column 1
Column 2
❑� Section 1: Outfall Location
wl attachments (e.g., responses for additional outfalls)
❑✓ Section 2: Discharge Dale
❑ w/ attachments
❑� Section 3: Waste Types
❑ w/ attachments
❑� Section 4: Effluent Characteristics
Elw/ attachments
E
❑� Section 5: Flow
❑ wl attachments
to
o
❑✓ Section 6: Treatment System
❑ wl attachments
`��—_
❑✓ Section 7: Other Information
❑ w/ attachments
c
d
c
❑� Section 8: Checklist and Certification Statement
❑ w/ attachments
w
8.2
Certification Statement
a
Y
1 certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete.) am aware that there are significant penalties for submitting false information, including the
possibility of fine and imprisonment for kno wing violations.
Name (print or type first and last name)
Official title
Rosa Manso
Site Head, Eli Lilly and Company - Concord
Signature
Date signed
Ilk
EPA Form 3510-2E (revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
OMB No. 2040-0004
Form U.S Environmental Protection Agency
2F 10ht�\�� EPA Application for NPDES Permit to Discharge Wastewater
NPDES STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
SECTIONOUTFALL LOCATIONr
1.1 Provide information on each of the facili 's outfalls in the table below
Number Receiving Water Name Latitude Longitude
1 Wetlands to Coddle Creek 35` 23 27.0" N -80° 38' 6.3" W
c
0
2 Wetlands to Coddle Creek 35' 23 29.1" N -80° 37' 40.7" W
0
J
3 Wetlands to Coddle Creek 35° 23 32.7" N -80. 37 59.3" W
0
2.1 Are you presently required by any federal, state, or local authority to meet an implementation schedule for constructing,
upgrading, or operating wastewater treatment equipment or practices or any other environmental programs that could
affect the discharges described in this application?
❑ Yes ❑� No 4 SKIP to Section 3.
2.2 Briefly identify each applicable project in the table below.
Brief Identification and Affected Outfalls Final Compliance Dates
Description of Project (list outrall numbers) Sources) of Discharge
Required Projected
E
m
a
E
2.3 Have you attached sheets describing any additional water pollution control programs (or other environmental projects
that may affect your discharges) that you now have underway or planned? (Optional Item)
❑ Yes ❑ No
EPA Form 3510-2F (Revised 3-19) Page 1

EPA Identlfication Number NPDES Permit Number Facility Name Form Approved 03/05/19
OMB No. 2040-0004
SECTIONDRAINAGE MAP 140
3.1 Have you attached a site drainage map containing all required information to this application? (See instructions for
specific guidance.)
70T11
® Yes ❑ No
4.1 1 Provide information on the facility's pollutant sources in the table below.
Outhill
Impervious Surface Area
Total Surface Area Drained
Number
(whin a mile radius of the Wily)
(within a mile radius of the facility)
spec fy units
specify units
1
1.96
Acres
13.13
Acres
specify units
ape* units
2
12.91
Acres
21.13
Acres
specify units
spa* units
3
12.97
Acres
22.52
Acres
specify units
specify units
specifyunds
specify units
specify units
specify units
4.2
Provide a narrative description of the facility's significant material in the space below. (See instructions for content
requirements.)
No raw materials to be stored outside.
d
0
N
G
O
a
4.3
Provide the location and a description of existing structural and non-structural control measures to reduce pollutants in
stornwaler runoff. See instructions for specificguidance.)
Stormwater Treatment
Codes
Ofa
from
umbber
Control Measures and Treatment
Exhibit
2F-1
001
Stormwater retention basin
1-U
002
Stormwater retention basin
1-U
003
Stormwater retention basin
1-U
EPA Form 3510-2F (Revised 3-19) Page 2

Form Approved 03/05/19
OMB No. 2040-0004
5.1 11 certity under penalty of law that the outfell(s) covered by this application have been tested or evaluated for the
presence of non-stormwater discharges. Moreover, 1 certify that the outfalls identified as having non-stormwater
discharges are described in either an accompanying NPDES Form 2C 2D or 2E application
Name (print or type first and last name) Official title 1
Rosa Manso
Site Head, Eli Lilly and Company - Concord
signed
N
o+ 5.2 Provide the testing information requested in the table below. Not Applicable. This is a new discharge.
y Outlall nsite Drainage Poir
c Number Description of Testing Method Used Details) of Testing Directly Observed
During Test
w
3
0
iq
C
O
2
6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years.
a
.Q Not applicable. This is a new facility with production activities expected to begin in 2024. This facility is designed
y and constructed to meet the North Carolina stormwater no exposure standard, and all industrial activities will occur
Yindoors. If any leak or spill occurs, materials will be retained inside the building and will not be exposed to stormwater.
m
m
J
qC
Y
r
C
See the instructions to determine the pollutants and parameters you are required to monitor and, in turn, the tables you must
o com lets. Not all applicants need to complete each table.
€ 7.1 1 Is this a new source or new discharge?
c 0 Yes + See instructions regarding submission of ❑ No + See instructions regarding submission of
o estimated data. actual data.
A Tables A, B, C, and D
_ 7.2 Have you completed Table A for each outfall?
Je
0 Yes No
EPA Form 3510-2F (Revised 3-19) Page 3

EPA Identification Number
NPDES Permit Number
Facility Name
Fonn Approved 03/05/19
OMB No. 2040-0004
7.3
Is the facility subject to an effluent limitation guideline (ELG) or effluent limitations in an NPDES permit for its process
wastewater?
❑ Yes ❑ No + SKIP to Item 7.5.
-you
7.4
Have Table B by providing data oe pollutants that are (1) limited either directly or
indirectly in an ELG and/or (2) subject to effluent limitations in an NPDES permit for the facility's process wastewater?
❑ Yes ❑ No
7.5
Do you know or have reason to believe any pollutants in Exhibit 2F-2 are present in the discharge?
❑ Yes ❑� No 4 SKIP to Item 7.7.
7.6
Have you listed all pollutants in Exhibit 2F-2 that you know or have reason to believe are present in the discharge and
provided quantitative data or an explanation for those pollutants in Table C?
❑ Yes ❑ No
7.7
Do you qualify for a small business exemption under the criteria specified in the Instructions?
❑ Yes +SKIP to Item 7.18.❑ No
7.8
Do you know or have reason to believe any pollutants in Exhibit 2F-3 are present in the discharge?
❑ Yes ❑� No 4 SKIP to Item 7.10.
d
7.9
Have you listed all pollutants in Exhibit 2F-3 that you know or have reason to believe are present in the discharge in
'e
Table C?
❑ Yes ❑ No
s7.10
Do you expect any of the pollutants in Exhibit 2F-3 to be discharged in concentrations of 10 ppb or greaten
o
❑ Yes 0 No 4 SKIP to Item 7.12.
7.11
Have you provided quantitative data in Table C for those pollutants in Exhibit 2F-3 that you expect to be discharged in
IRM
concentrations of 10 ppb or greaten
W
a
❑ Yes ❑ No
7.12
Do you expect acrolein, acrylonitrile, 2,4-dinitrophenol, or 2-methyl-4,6-dinitrophenol to be discharged in concentrations
of 100 ppb or greaten
❑ Yes ❑ No 4 SKIP to Item 7.14.
7.13
Have you provided quantitative data in Table C for the pollutants identified in Item 7.12 that you expect to be
discharged in concentrations of 100 ppb or greaten
❑ Yes ❑ No
7.14
Have you provided quantitative data or an explanation in Table C for pollutants you expect to be present in the
discharge at concentrations less than 10 ppb (or less than 100 ppb for the pollutants identified in Item 7.12)?
❑ Yes ❑� No
-reason
7.15
Do you know or have to believe any pollutants in Exhibil2F-4 are present in the discharge?
❑ Yes ❑✓ No 4 SKIP to Item 7.17.
7.16
Have you listed pollutants in Exhibit 2F4 that you know or believe to be present in the discharge and an
provided
explanation in Table C?
❑ Yes ❑ No
7.17
Have you provided information for the storm event(s) sampled Te D?
❑ Yes No
EPA Form 3519-2F (Revised 3-19) Page 4

EPA Identification Number
NPDES Permit Number
Facility Name
Form Appmwd 03/05/19
OMB No. 2040-0004
$
Used or Manufactured Toxics
7.18
Is any pollutant listed on Exhibits 2F-2 through 2F-4 a substance or a component of a substance used or
gmanufactured
as an intermediate or final product or byproduct?
o
❑ Yes © No 4 SKIP to Section 8.
7.19
List the pollutants below, including TCDD if applicable.
c
1. 4. 7.
d
rn
A
2. 5. 8.
L
U
N
0
3. 6. 9.
SECTIONBIOLOGICAL
T• D. t
8.1
Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on
any of your discharges or on a receiving water in relation to your discharge within the last three years?
c
Yes ❑ © No 4 SKIP to Section 9.
_
N
~
8.2
Identify the tests and their purposes below.
Test's)
Purpose of Tesl(s)
Submited to NPDESPermitNn Auth
Date Submitted
0
❑ Yes ❑ No
o
0
❑ Yes ❑ No
m
❑ Yes ❑ No
SECTION•
• • •r
9.1
Were any of the analyses reported in Section 7 (on Tables A through C) performed by a contract laboratory or
consulting firm?
❑ Yes © No + SKIP to Section 10.
9.2
Provide information for each contract laboratory or consulting firm below.
Laboratory Number 1
Laboratory Number 2
Laboratory Number 9
Name of laboratorytfirm
c
0
w
Laboratory address
w
a
A
c
Q
w
0
Phone number
t�
Pollutant(s) analyzed
EPA Form 3510-2F (Revised 3.19) Page 5

EPA Idiii ! ;atbn Number NPDES Permit Number Facility Name
Fonn Approved 03/05/19
OMa No. 2040-0004
10.1
In Column 1 below, mark the sections of Form 2F that you have completed and are submitting with your application. For
each section, specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note that not
all applicants are re uired to com late all sections or provide attachments.
Column 1
Column 2
Section 1
❑ w/attachments (e.g., responses for additional oulfalis)
❑ Section 2
❑ w/ attachments
0Section 3
w/ site drainage map
0 Section 4
❑ wl attachments
0 Section 5
❑ w/ attachments
w
❑� Section 6
❑ w/ attachments
EE,
ID Section 7
❑ Table A ❑ w/small business exemption request
�
rn
o
❑ Table B ❑ w/ analytical results as an attachment
3
❑ Table C ❑ Table D
r
tom'
❑ Section 8
❑ wlattaohments
a
c
b
❑ Section 9
❑ w/attachments (e.g., responses for additional contact laboratories or firms)
Y
t
R1 Section 10
❑
ca
10.2
Certification Statement
1 certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible
for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine
and imprisonment for knowing violations.
Name (print or type first and last name)
Official title
Rosa Manso
Site Head, Eli Lilly - Concord
Signature
Date signed
202.q
RECEIVE®
APR 03 2023
NCDEQ/DWR/NPDES
EPA Form 3510.21F (Revised 3-19) Page 6

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Engineering Alternatives Analysis (EAA)
This document is prepared for the evaluation of technologically feasible alternatives and economics of the
proposed discharge, as required by North Carolina Division of Water Resource.
1. Eligibility of NPDES Coverage
The proposed wastewater discharge from the site will solely consist of clean HVAC condensate mixed with
stormwater. The site does not use any additives for the building HVAC system, and the HVAC condensate
will be discharged to the existing stormwater retention basin via the stormwater sewer system. The site
and buildings were designed and constructed to meet the stormwater no exposure standard, therefore,
no industrial activities will occur outside the building and the site plans to apply for a stormwater No
Exposure Certification (NEC) when productions start in 2024.
In accordance with 15A NCAC 02H .0127 and G.S. 143.215.1 (b)(3) and (4), both condensate wastewater
and stormwater are eligible for NPDES permit coverage. Therefore, the proposed HVAC condensate (i.e.,
atmospheric condensed water from air conditioning systems) wastewater mixed with stormwater is
allowed to be discharged, and applicable for coverage under NPDES Permit.
2. Alternatives Analysis
The Alternatives to Direct Discharge Evaluation required by G.S. § 143-215.1 (b)(5)(a) and 15A NCAC 02H
.0105JcJMJ provided below addresses the feasibility of implementing each of the following discharge
alternatives:
A) Connection to a Municipal or Regional Sewer Collection System
B) Subsurface Seepage and Atmospheric Evaporation disposal
C) Wastewater Reuse for Irrigation
D) Off -Site Spray Irrigation
E) Direct Surface Discharge through NPDES permit
This analysis for prepared for the proposed discharge of clean condensate from air conditioning systems
associated with HVAC systems. Soil information is provided in Attachment B. It should also be noted that
the site was encouraged in its building plans approved by Durham County to utilize a low -volume irrigation
system, such as drip or bubble systems to conserve water use. Details of each alternative are described
as follows:
Alternative A - Connection to a municipal or regional sewer collection system
The Sewer Use Ordinance from both Cabarrus County (Section 2.1.b.14) and City of Concord (Section 62-
191.(b)(14)) prohibits the discharge of clean condensate to the municipal sewer system. Therefore, it is
deemed not feasible to discharge the proposed clean condensate to municipal sewer system, and no
costing analysis was prepared for this alternative. In addition, the site's connection permit (Industrial User
Permit) to be issued by Cabarrus County was based on no condensate being present. Therefore, it is not
feasible to discharge the proposed condensate to a municipal sewer collection system.
Alternate B - Subsurface Seepage and Atmospheric Evaporation disposal
It is estimated that the average condensate generation rate is 4,311 gallons per day, and the peak rate is
8,622 gallons per day. The calculated total annual volume of condensate estimated to be generated at the
site is 1,172,636 gallons.

To evaluate this alternative for discharge of the proposed clean condensate, the evaporative and seepage
rates were estimated using the Food and Agriculture Organization of the United Nations (FAO) calculation
methods (link) and Class A Pan Evaporation Station information form the National Oceanic and
Atmospheric Administration station in Chapel Hill North Carolina (link). This was done because the system
already takes up a significant amount of land and accomplishes percolation into soil similarly like drip
irrigation and subsurface systems.
To calculate the land required for subsurface seepage, the most conservative average seepage loss rate
of 2.625 mm/day recommended by the FAO was used.
Land required for seepage disposal:
A=
Volume
Seepage rate x 365
11172,636 gallons
year
_ = 49,871.4 sq ft (or 1.2 acres)
2.625 day x 365 year
To calculate the land required for atmospheric evaporation disposal, the annual Class A Pan Evaporation
rate of 46.45 inches (1,180 mm) per year recommended by NOAA and the FAO recommendation of using
only 75% of that evaporation rate was used.
Land required for atmospheric evaporation disposal:
Volume
1,172,636 gallons
A = = year = 53,992.5 sq f t (or 1.3 acres)
mm
Evap rate 1,180 year x 0.75
The site does not have a single 1.5 acre tract of land available for subsurface seepage or surface
evaporation within the "Limit of Disturbance" allowed for construction. In order to handle all the
condensate, additional acreage land would need to be purchased/leased adjacent to the site. The adjacent
land is not suitable for a subsurface seepage field.
Based on the adjacent property costs, collection system size, the distance to and size of subsurface
seepage field, it is estimated that the total capital and installation cost of the collection system will be at
minimum $512,000, and the annual operating and maintenance (O&M) cost would be $22,500. The
calculated 20-year present value of costs (PV) assuming a 5.625% discount rate would be:
PV = $742,000 + $22,500 x [1.98/0.168] _ $1,007,179
Given this information, a subsurface seepage is not considered feasible for discharge of the proposed
condensate.
T = $1,007,179 - $5,820 = 173 years
Alternative C - Wastewater Reuse for irrigation
Currently the site does not have any irrigation system designed for wastewater reuse. To reuse the
proposed condensate for irrigation, it will require a condensate collection system with a minimum storage

capacity of 60,356 gallons (assuming 1 week of storage at the maximum condensate generation rate of
8,622 gallons per day). Annual operational costs were based on the average calculated generation rate of
4,311 gallons per day.
Based on the volume of the collection system, it is estimated that the total capital and installation cost of
the collection system will be at minimum $262,000, and the annual operating and maintenance (O&M)
cost would be $22,500. The calculated 20-year present value of costs (PV) assuming a 5.625% discount
rate would be:
PV = $262,000 + $22,500 x [1.98/0.168] _ $527,179
If the site was approved by Cabarrus County to utilize low -volume irrigation system, such as drip or bubble
systems to conserve water use it is estimated that on average 500,000 gallons of water would be needed
for onsite irrigation every year, with the current water fee of $11.64 per 1,000 gallons in Cabarrus County,
annual cost for irrigation water would be $5,260. Total payback time for the wastewater reuse irrigation
time would be:
T = $527,179 _ $5,820 = 91 years
In addition, since only 500,000 gallons of water is needed for irrigation, an excess volume of 672,636
gallons of condensate still needs to be hauled offsite for properly disposal. Therefore, it is not feasible to
reuse the condensate wastewater for irrigation on site.
Alternative D - Off -Site Spray Irrigation
This alternative will require a condensate collection system (evaluated in Alternative C) and an additional
tank trailer loading station for hauling condensate off -site to be spray irrigated.
In addition to the cost estimate provided in Alternative C for condensate collection system, the tank trailer
loading station itself will require an estimated total capital and installation cost of $512,000 and O&M
cost of $416,613. Using these assumptions, we estimated the overall present value of costs (PV) for the
collection system and tank trailer loading station for a 20-year period is estimated to be:
PV = $512,000 + $85,502 x [1.98/0.168] _ $1,523,234
The total payback time for the wastewater reuse for off -site spray irrigation would be:
T = $5,422,079 - $5,820 = 173 years
Therefore, off -site spray irrigation with the proposed condensate is not considered a feasible alternative.
Alternative E— Direct Surface Discharge under NPDES Permit
We evaluated the possibility of a combination of wastewater alternatives that would minimize or
eliminate a direct discharge alternative. For example, we considered whether the facility could operate
a land application system during the dry season when stream flows are at their lowest and provide less
dilution, and operate an NPDES discharge system during the wet season when soils may not be as
amenable to land application and the receiving stream provides its greatest dilution. The issue we found
with this approach was that capital costs would still be high as shown in Alternative D.

Since the site already has a large stormwater retention basin for collection and management of
stormwater designed, there will not be any additional cost for discharging the clean condensate to the
stormwater retention basin. This stormwater retention basins have a surface area of approximate 154,284
square feet (See Attachment B). When the water depth in this BMP1, BMP2, and BMP3 reaches 9, 12,
and 9 feet, respectively a discharge will occur to the nearby wetlands which subsequently discharges to
an Coddle Creek. As such, the overall cost will be negligible for discharge the condensate to the
stormwater basin and then ultimately to the nearby wetlands which subsequently discharges to Coddle
Creek. This option is also the least energy intensive operation with smallest capital project impact for
conveyance of the storm water and condensate by relying on gravity transfers and existing sewers.

3. Alternatives Analysis Conclusion
A summary table of alternative analysis on the five evaluated alternatives is depicted as below:
Alternatives
20-Year Present
Pay -back
Environmental
Feasibility
Value of Cost
period
Footprint/Impact
Determination
Alternative A
Not feasible — not
Connection to
allowed by local
municipal sewer
N/A
N/A
N/A
ordinance (see
system
references in
Alternative A
above)
Alternative 8
Subsurface Seepage
$1,847,179
351 Years
High
Low feasible
and Atmospheric
Evaporation disposal
Alternative C
Wastewater Reuse for
$527,179
100 Years
Moderate
Least feasible
Irrigation
Alternative D
Off -Site Spray
$5,422,079
1,031 Years
High
Least feasible
Irrigation
Alternative E
Negligible, using
Direct Surface
existing
Lowest — least
Discharge through
stormwater
N/A
capital and
Most feasible
NPDES
retention pond
energy intensive
Based on the Alternative Analysis Results, direct surface discharge through NPDES permit is the most
economical feasible and environmentally friendly alternative for the disposal of clean atmospheric
condensate from the site.