CrF Questionnaire General Instructions

OMB Control No. 2040-NEW

OMB Approval Date: [Date]

OMB Approval Expires: [Date]

GENERAL INSTRUCTIONS

Read these instructions completely before beginning your facility’s questionnaire.

REQUIREMENT TO RESPOND

The United States Environmental Protection Agency (EPA) Office of Water is administering this questionnaire to the subset of metal finishing and electroplating facilities engaged in specific chromium-related metal finishing and electroplating activities that EPA has determined may use and/or discharge per- and polyfluoroalkyl substances (PFAS). The chromium finishing operations that are the focus of this data collection effort include chromium plating, chromium anodizing, chromic acid etching, chromate conversion coating, and any other metal finishing or electroplating process that deposits a layer of chromium on any base metal/material or uses chromium materials in the fabrication of a metal product. This questionnaire is being conducted under the authority of Section 308 of the Clean Water Act (Federal Water Pollution Control Act, 33 USC § 1318).

All facilities which receive the notification letter are required to complete the questionnaire regardless of size, geography, classification as a captive facility or job shop, or other characteristics. Completion and timely submission of the questionnaire is required by federal law. Failure to respond, late filing, or failure to comply with the instructions may result in fines, civil penalties, and other sanctions, as provided by law. Moreover, it is in the industry's best interest to ensure that the information on which EPA will base its evaluation presents an accurate and representative picture of the industry.

EPA mailed a notification letter to each facility required to respond to the questionnaire. Companies operating multiple applicable facilities are required to complete and submit a questionnaire for each individual facility. If your company operates any facilities in the United States that currently or previously conducted these chromium finishing operations and these facilities did not receive a notification letter, contact the EPA Chromium Finishing Questionnaire Helpline (Helpline) to request copies of the questionnaire for these facilities. If you believe the questionnaire is not applicable to your facility, you cannot access the questionnaire using the Questionnaire ID and entry code provided in the notification letter mailed to you from EPA, or you received multiple notification letters for the same facility, contact the Helpline.

The response to this questionnaire is due [INSERT DUE DATE THAT ENSURES FACILITIES WILL HAVE AT LEAST 60 DAYS TO RESPOND AFTER NOTIFICATION]. If you wish to request an extension, you must do so in writing before [INSERT DATE 15 DAYS PRIOR TO THE DUE DATE]. Written requests may be emailed (preferred) or mailed to the Helpline (refer to QUESTIONNAIRE ASSISTANCE for contact information). Extension requests will be evaluated on a case-by-case basis. Submittal of an extension request to EPA does not alter the due date of your questionnaire unless and until EPA agrees to the extension and establishes a new date.

The questionnaire consists of the following sections, and they all must be completed as directed before submittal:

Section 1: General Facility Information

Section 2: Facility Operations and PFAS Use

Section 3: Wastewater Generation

Section 4: Wastewater Flow Diagram

Section 5: Wastewater Management and Treatment

Section 6: Permit Requirements and Monitoring Data

Section 7: Environmental and Other Information

Section 8: Financial Information

Not all questions will apply to every facility. Complete all questions as directed.

For information on how EPA plans to use data obtained from each question, see the document titled “Information Collection Request (ICR) Supporting Statement Part A for the EPA Chromium Finishing Industry Data Collection (2^nd Federal Register Notice)” at EPA Docket ID No. EPA-HQ-OW-2022-0869.

RESPONDING TO THE QUESTIONNAIRE

Unless internet access is not available at your facility, complete and submit the questionnaire in Qualtrics Survey Software (Qualtrics). Qualtrics-based questionnaires may be completed via a computer (e.g., laptop) or mobile device (e.g., smart phone, tablet) with internet access. The notification letter mailed to each facility discusses how to access and complete the Qualtrics questionnaire. EPA recommends reviewing an unofficial PDF copy of the questionnaire, available for download on the EPA Chromium Finishing Questionnaire webpage (https://www.epa.gov/eg/chromium-finishing-questionnaire), and using it to collect relevant information and data before entering your responses into the Qualtrics site. You are required to complete and submit the questionnaire in Qualtrics; do not submit a completed copy of the unofficial PDF questionnaire.

You do not need to complete the online questionnaire in one sitting. Qualtrics will save your responses and you may return as many times as needed to complete your response, using your Questionnaire ID and entry code to log in each time via the link to Qualtrics on the EPA Chromium Finishing Questionnaire webpage. Each Questionnaire ID is unique to the facility to which it is assigned. Companies managing multiple questionnaires for multiple facilities should organize these Questionnaire IDs to ensure the correct response is provided for each facility. Within Qualtrics, the Questionnaire ID used to log in as well as the facility name, city, and state are presented in the upper right corner of each webpage of the questionnaire as a reminder for which facility a response is being provided.

EPA recommends one person be responsible for all data entry into Qualtrics using the unofficial PDF questionnaire to facilitate data collection from collaborators. Although multiple collaborators can contribute to a single questionnaire in Qualtrics (using the Questionnaire ID to log in), collaborators must coordinate distinct work times as only one person may work on a facility’s Qualtrics questionnaire at a time. Simultaneous collaboration in Qualtrics will result in response data being lost and questions to be unintentionally skipped. More details on navigating and submitting your questionnaire are included in the instructions within Qualtrics.

If your facility lacks internet access or cannot complete the Qualtrics questionnaire, contact the Helpline to request hardcopy materials be mailed to you. EPA will allow facilities that cannot complete the Qualtrics questionnaire to complete a hardcopy version of the questionnaire and mail back the completed questionnaire, signed certification statement, and requested attachments/supplemental files. You must request an official hardcopy version of the questionnaire from the Helpline.

QUESTIONNAIRE ASSISTANCE

If you have any questions about your facility’s questionnaire, consult the List of Frequently Asked Questions (FAQs) on the EPA Chromium Finishing Questionnaire webpage or request assistance from the Helpline. The Helpline is operated by ERG, an EPA contractor, Monday to Friday. Both phone lines require you to leave a voicemail, and Helpline staff will respond to your inquiry as soon as possible. When contacting the Helpline, include your name, business phone number or email address, the name and Questionnaire ID of your facility, and a detailed description of your inquiry in your voicemail or email.

EPA Chromium Finishing Questionnaire Helpline
Email	PFAS308help@erg.com
Phone Numbers	Local: 703-633-1692 Toll-free: 1-844-585-1101
Mailing Address	United States Environmental Protection Agency c/o ERG Chromium Finishing Questionnaire 14555 Avion Pkwy, Suite 200 Chantilly, VA 20151-1102

EPA does not accept confidential business information (CBI) information through email; therefore, do not submit information that is CBI to the Helpline via email.

CONFIDENTIAL BUSINESS INFORMATION

A business (“you”) may not withhold information from EPA on the grounds that it may be confidential business information (CBI). You may, however, if you desire, assert a business confidentiality claim covering part or all of the information that you furnish to EPA. Information claimed as CBI will be treated in accordance with the procedures for handling CBI under 40 CFR Part 2, Subpart B, and will be disclosed to the extent, and by means of procedures, set forth in Subpart B.

If you wish to assert a CBI claim for any of the information submitted in response to this questionnaire, you must do so at the time you submit the questionnaire to EPA. If no CBI claim accompanies the information when it is received by EPA, EPA may make the information available to the public without further notice. See 40 CFR § 2.203(a), 41 Fed. Reg. 36,907. Furthermore, generally, effluent data and information already available to the public is not entitled to confidential treatment and will be made available to the public without further notice to you. See 40 CFR §§ 2.201(g), 2.302(I) and 2.302(f); 40 CFR § 403.14. Any knowing and willful misrepresentation is subject to criminal penalty pursuant to 18 USC § 1001. 

In the hardcopy questionnaire, identify responses and comments which contain CBI by checking the corresponding CBI checkboxes. The hardcopy version of the questionnaire includes a CBI checkbox for each question and each comment row in Section 9 (Comments). You may claim a response or comment, including any submitted files, as CBI by checking the corresponding checkbox next to the question or comment. Any response or comment where “Claim Question # response as CBI” is not individually checked will not be considered confidential and EPA may make the information available to the public without further notice to you.

In the Qualtrics questionnaire, at the end of each questionnaire section you will see a summary of your response to each question in the previous section and be instructed to assert whether each response contains CBI. You may claim a response as CBI by selecting “Yes” in the dropdown menu that appears after each question response and comment field. Your response, comment, and submitted file(s) for any question where “Claim Question # response as CBI” is not individually marked “Yes” will not be considered confidential and EPA may make the information available to the public without further notice to you.

You do not need to print or include “Confidential Business Information” or “CBI” on documents or files submitted in response to a specific question. By checking the corresponding checkbox in the hardcopy questionnaire or marking “Yes” in the Qualtrics questionnaire for that question, the associated documents and files are claimed CBI. Only supplemental files not associated with a question need to be marked with “Confidential Business Information” or “CBI” to be claimed.

FILES SUBMITTED WITH THE QUESTIONNAIRE

For certain questions, you will be asked to provide copies of documents, diagrams, or completed workbooks. Additional questions provide template Microsoft Excel workbooks and ask you to download, complete, and then submit the workbooks as responses. These template files are available for download in Qualtrics from the corresponding questions or can be downloaded from the EPA Chromium Finishing Questionnaire webpage. When you request a hardcopy questionnaire from the Helpline, these files are included in the materials emailed or physically mailed by the Helpline.

When responding in Qualtrics, you may need to scan or digitize hardcopy files to prepare them for upload. Each question provides instructions on the type(s) of files accepted (e.g., PDFs, graphic files, workbooks) and how you should title each file for upload (e.g., ‘CRF####_Question #_File Description’). Only one file can be uploaded per question, limited to less than 100 MB in size. Once uploaded to Qualtrics, a file cannot be removed; however, it may be replaced with a different file.

Where multiple files are needed to fulfill the request, combine all files into a single PDF or create a zipped folder of the files to create one file for upload. If a file is over 100 MB, you may zip (compress) it to decrease its size. Follow these steps to zip or compress a file or folder:¹

1. Identify the file or folder that you want to zip. If you need to combine multiple files, move them into the same folder.

2. In Microsoft Windows™, right-click the file/folder, select “Send to,” and then select “Compressed (zipped) folder.” A new zipped folder with the same name will be created in the same location.

On an Apple Mac™ device, control-click the file/folder or tap it using two fingers, then select “Compress.” If you compress a single item, the compressed file has the name of the original item with the .zip extension. If you compress multiple items at once, the compressed file is called “Archive.zip.”

3. To rename the new folder according to the question directions, right-click/control-click the folder, select “Rename,” and then type the new name.

Supplemental files that are not requested for a particular question but may provide insight or data relevant to a facility’s response are welcomed. If these files contain CBI, you should mail these supplemental files to the Helpline either as hardcopies or electronic files on removable media. Non-CBI supplemental files may be emailed to the Helpline.

1 The Qualtrics-based questionnaire may be completed and files may be uploaded using a mobile device (e.g., smart phone, tablet) with internet access; however, the procedures for zipping/compressing and uploading files may vary by device and operating system.

2