Burden Calculation Tables

2677t01.xlsx

NESHAP for Carbon Black Production (40 CFR part 63, subpart YY) (Proposed Rule)

Burden Calculation Tables

OMB: 2060-0738

Document [xlsx]
Download: xlsx | pdf

Overview

Inputs
YR1
YR2
YR3
Respondent Summary
EPA_YR1
EPA_YR2
EPA_YR3
EPA Summary
O&M Costs


Sheet 1: Inputs


All facilities


Number of Existing Facilities 15


Number of New Facilities 0


Total 15






















Industry Wages



May 2019 National Industry-Specific Occupational Employment and Wage Estimates



Sectors 31, 32, and 33 - Manufacturing



Category Occupation Code Title 2019 Wage Loaded Wage
Technical 17-2081 Architecture and Engineering Occupations 48.4 101.64
Clerical 43-6014 Office and Administrative Support Occupations 22.65 47.57
Managerial 11-9041 Management Occupations 66.36 139.36





https://www.bls.gov/oes/current/naics4_3250A1.htm#11-0000








EPA Wages




Hourly Mean Wage With Fringe & Overhead

(GS- 12, step 1) - Tech. 30.9 $49.44

(GS- 13, step 5) - Mgmt. 41.64 $66.62

(GS-6, step 3) - Cler. 16.72 $26.75






This ICR uses rates are from the Office of Personnel Management (OPM) General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.

https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2019/GS_h.pdf

or https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/









Sheet 2: YR1

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Carbon Black Production RTR - Year 1
Burden Item (A)
Respondent Hours per Occurrence (Technical hours)
(B)
Non-Labor Costs Per Occurrence
(C)
Number of Occurrences Per Respondent Per Year
(D)
Technical Hours per Respondent Per Year
(A X C)
(E)
Number of Respondents Per Year
(F)
Technical Hours per Year
(D X E)
(G)
Clerical Hours per Year
(F X 0.1)
(H)
Management Hours per Year
(F X .05)
(I)
Total Hours per Year
(F + G + H)
(J)
Total Labor Costs Per Year
(K)
Total Non-Labor Costs Per Year
(B x C x E)
(L)
Total Number of Responses per Year
(C X E)
Footnotes
1. Applications NA












2. Surveys and Studies NA












3. Reporting Requirements













A. Read Rule 8 $0 1 8 15 120 12 6 138 $13,604 $0 0 a
B. Required Activities













1. Initial Performance Tests 0 $21,350 1 0 15 0 0 0 0 $0 $320,250 0 b, c
2. Periodic 5-year Performance Testing 0 $15,241 1 0 3 0 0 0 0 $0 $45,723 0 d, e
C. Create Information Inc. in 3B












D. Gather Information Inc. in 3E












E. Report Preparation












1. Report of Initial Perfromance Test Results (Applicability Assessment) 4 $0 1 4 15 60 6 3 69 $6,802 $0 15 b, c
2. Report of Periodic Performance Test Results 8 $0 1 8 3 24 2 1 28 $2,721 $0 3 d, e
3. Notification of Performance Test Dates 1 $0 1 1 18 18 2 1 21 $2,041 $0 18

4. Notification of Compliance Status













a. Initial Boiler Tune Up 3 $0 1 3 15 45 5 2 52 $5,101 $0 15 f, h
b. Initial Performance Test (Applicability Assessment) Incl. in E.1 b,c
5. Periodic Reports


a. Periodic 5-Year Performance Test Results Incl. in E.2 d,e
b. Subsequent Boiler Tune Up 1 $0 0 0 0 0 0 0 0 $0 $0 0 f, h
Reporting Subtotal




267 27 13 307 $30,269 $365,973 51

4. Recordkeeping Requirements













A. Read Instructions Inc. in 3A












B. Plan Activities See 3B












C. Implement Activities See 3B












D. Develop Record System NA












E. Record Information













1. Performance Test Report Records 0.5 $0 1 0.5 18 9 1 0 10 $1,020 $0 0
2. Boiler Tune-Up Records/Reports 2 $0 1 2 15 30 3 2 35 $3,401 $0 0

F. Train Personnel

1. Understand Requirements and Adjust Compliance Plan 20 $0 1 20 15 300 30 15 345 $34,010 $0 0 g
G. Audits NA









0

Recordkeeping Subtotal




339 34 17 390 $38,431 $0 0

TOTAL




606 61 30 697 $68,700 $365,973 51































Footnotes:













(a) We have included all 15 carbon black major sources, with no additional new or reconstructed sources becoming subject to the rule over the next three years. This is a one-time cost incurred in the first year.

(b) This is a one-time cost incurred only in year 1 as the rule requires facilities to perform initial performance testing on vents downstream the main unit filter (MUF) to determine applicability. Respondent labor hours per occurence accounts for on-site contractor support/review of testing/report.
(c) The nonlabor estimated cost of the initial performance test is estimated to be $21,350 (included in O&M costs for contractor to conduct performance test/prepare of a performance test report).













(d) All costs related to periodic testing (requirement to repeat tests every 60 months) assumes that the periodic performance testing/reporting conducted by an emissions testing contractor and facility personnel will work on-site to assist the contractor. Responded labor hours per occurence assume that 20% of the source category facilities will conduct this test annually.

(e) The nonlabor estimated cost of periodic testing is estimated to be $15,241 ((included in O&M costs for contractor to conduct performance test/prepare of a performance test report). For purposes of this burden estimate, it is assumed that 20% of the source category facilities will conduct this test annually.
(f) Includes labor hour to document initial/subsequent boiler tune-up requirements for facilities that comply with the rule by venting tail gas to process boilers for use as fuel gas.

(g) This is a one-time cost incurred in the first year.

(h) Cost estimates taken from the 2010 Control Cost Memo dicussing Boiler tune-up anticipated costs.



































































Sheet 3: YR2

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Carbon Black Production RTR - Year 2
Burden Item (A)
Respondent Hours per Occurrence (Technical hours)
(B)
Non-Labor Costs Per Occurrence
(C)
Number of Occurrences Per Respondent Per Year
(D)
Technical Hours per Respondent Per Year
(A X C)
(E)
Number of Respondents Per Year
(F)
Technical Hours per Year
(D X E)
(G)
Clerical Hours per Year
(F X 0.1)
(H)
Management Hours per Year
(F X .05)
(I)
Total Hours per Year
(F + G + H)
(J)
Total Labor Costs Per Year
(K)
Total Non-Labor Costs Per Year
(B x C x E)
(L)
Total Number of Responses per Year
(C X E)
Footnotes
1. Applications NA












2. Surveys and Studies NA












3. Reporting Requirements













A. Read Rule 8 $0 1 8 0 0 0 0 0 $0 $0 0 a
B. Required Activities













1. Initial Performance Tests 0 $21,350 1 0 0 0 0 0 0 $0 $0 0 b, c
2. Periodic 5-year Performance Testing 0 $15,241 1 0 3 0 0 0 0 $0 $45,723 0 d, e
C. Create Information Inc. in 3B












D. Gather Information Inc. in 3E












E. Report Preparation












1. Report of Initial Performance Test Results (Applicability Assessment) 4 $0 1 4 0 0 0 0 0 $0 $0 0 b, c
2. Report of Periodic Performance Test Results 8 $0 1 8 3 24 2 1 28 $2,721 $0 3 d, e
3. Notification of Performance Test Dates 1 $0 1 1 3 3 0 0 3 $340 $0 3

4. Notification of Compliance Status













a. Initial Boiler Tune Up 3 $0 0 0 0 0 0 0 0 $0 $0 0 f, h
b. Initial Performance Test (Applicability Assessment) Incl. in E.1 b,c
5. Periodic Reports


a. Periodic 5-Year Performance Test Results Incl. in E.2 d,e
b. Subsequent Boiler Tune Up 1 $0 1 1 15 15 2 1 17 $1,700 $0 15 f, h
Reporting Subtotal




42 4 2 48 $4,761 $45,723 21

4. Recordkeeping Requirements













A. Read Instructions Inc. in 3A












B. Plan Activities See 3B












C. Implement Activities See 3B












D. Develop Record System NA












E. Record Information













1. Performance Test Report Records 0.5 $0 1 0.5 3 2 0 0 2 $170 $0 0
2. Boiler Tune-Up Records/Reports 2 $0 1 2 15 30 3 2 35 $3,401 $0 0

F. Train Personnel

1. Understand Requirements and Adjust Compliance Plan 20 $0 1 20 0 0 0 0 0 $0 $0 0 g
G. Audits NA












Recordkeeping Subtotal




32 3 2 36 $3,571 $0 0

TOTAL




74 7 4 85 $8,332 $45,723 21
















Footnotes:













(a) We have included all 15 carbon black major sources, with no additional new or reconstructed sources becoming subject to the rule over the next three years. This is a one-time cost incurred in the first year.

(b) This is a one-time cost incurred only in year 1 as the rule requires facilities to perform initial performance testing on vents downstream the main unit filter (MUF) to determine applicability. Respondent labor hours per occurence accounts for on-site contractor support/review of testing/report.
(c) The nonlabor estimated cost of the initial performance test is estimated to be $21,350 (included in O&M costs for contractor to conduct performance test/prepare of a performance test report).













(d) All costs related to periodic testing (requirement to repeat tests every 60 months) assumes that the periodic performance testing/reporting conducted by an emissions testing contractor and facility personnel will work on-site to assist the contractor. Responded labor hours per occurence assume that 20% of the source category facilities will conduct this test annually.

(e) The nonlabor estimated cost of periodic testing is estimated to be $15,241 ((included in O&M costs for contractor to conduct performance test/prepare of a performance test report). For purposes of this burden estimate, it is assumed that 20% of the source category facilities will conduct this test annually.
(f) Includes labor hour to document initial/subsequent boiler tune-up requirements for facilities that comply with the rule by venting tail gas to process boilers for use as fuel gas.

(g) This is a one-time cost incurred in the first year.

(h) Cost estimates taken from the 2010 Control Cost Memo dicussing Boiler tune-up anticipated costs.


Sheet 4: YR3

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Carbon Black Production RTR - Year 3
Burden Item (A)
Respondent Hours per Occurrence (Technical hours)
(B)
Non-Labor Costs Per Occurrence
(C)
Number of Occurrences Per Respondent Per Year
(D)
Technical Hours per Respondent Per Year
(A X C)
(E)
Number of Respondents Per Year
(F)
Technical Hours per Year
(D X E)
(G)
Clerical Hours per Year
(F X 0.1)
(H)
Management Hours per Year
(F X .05)
(I)
Total Hours per Year
(F + G + H)
(J)
Total Labor Costs Per Year
(K)
Total Non-Labor Costs Per Year
(B x C x E)
(L)
Total Number of Responses per Year
(C X E)
Footnotes
1. Applications NA












2. Surveys and Studies NA












3. Reporting Requirements













A. Read Rule 8 $0 1 8 0 0 0 0 0 $0 $0 0 a
B. Required Activities













1. Initial Performance Tests 0 $21,350 1 0 0 0 0 0 0 $0 $0 0 b, c
2. Periodic 5-year Performance Testing 8 $15,241 1 0 3 0 0 0 0 $0 $45,723 0 d, e
C. Create Information Inc. in 3B












D. Gather Information Inc. in 3E












E. Report Preparation












1. Report of Initial Perfromance Test Results (Applicability Assessment) 4 $0 1 4 0 0 0 0 0 $0 $0 0 b, c
2. Report of Periodic Performance Test Results 8 $0 1 8 3 24 2 1 28 $2,721 $0 3 d, e
3. Notification of Performance Test Dates 1 $0 1 1 3 3 0 0 3 $340 $0 3

4. Notification of Compliance Status













a. Initial Boiler Tune Up 3 $0 15 45 0 0 0 0 0 $0 $0 0 f, h
b. Initial Performance Test (Applicability Assessment) Incl. in E.1 b,c
5. Periodic Reports


a. Periodic 5-Year Performance Test Results Incl. in E.2 d,e
b. Subsequent Boiler Tune Up 1 $0 1 1 15 15 2 1 17 $1,700 $0 15 f, h
Reporting Subtotal




42 4 2 48 $4,761 $45,723 21

4. Recordkeeping Requirements













A. Read Instructions Inc. in 3A












B. Plan Activities See 3B












C. Implement Activities See 3B












D. Develop Record System NA












E. Record Information













1. Performance Test Report Records 0.5 $0 1 0.5 3 2 0 0 2 $170 $0 0
2. Boiler Tune-Up Records/Reports 2 $0 1 2 15 30 3 2 35 $3,401 $0 0
F. Train Personnel

1. Understand Requirements and Adjust Compliance Plan 20 $0 1 20 0 0 0 0 0 $0 $0 0 g
G. Audits NA












Recordkeeping Subtotal




32 3 2 36 $3,571 $0 0

TOTAL




74 7 4 85 $8,332 $45,723 21
















Footnotes:













(a) We have included all 15 carbon black major sources, with no additional new or reconstructed sources becoming subject to the rule over the next three years. This is a one-time cost incurred in the first year.

(b) This is a one-time cost incurred only in year 1 as the rule requires facilities to perform initial performance testing on vents downstream the main unit filter (MUF) to determine applicability. Respondent labor hours per occurence accounts for on-site contractor support/review of testing/report.
(c) The nonlabor estimated cost of the initial performance test is estimated to be $21,350 (included in O&M costs for contractor to conduct performance test/prepare of a performance test report).













(d) All costs related to periodic testing (requirement to repeat tests every 60 months) assumes that the periodic performance testing/reporting conducted by an emissions testing contractor and facility personnel will work on-site to assist the contractor. Responded labor hours per occurence assume that 20% of the source category facilities will conduct this test annually.

(e) The nonlabor estimated cost of periodic testing is estimated to be $15,241 ((included in O&M costs for contractor to conduct performance test/prepare of a performance test report). For purposes of this burden estimate, it is assumed that 20% of the source category facilities will conduct this test annually.
(f) Includes labor hour to document initial/subsequent boiler tune-up requirements for facilities that comply with the rule by venting tail gas to process boilers for use as fuel gas.

(g) This is a one-time cost incurred in the first year.

(h) Cost estimates taken from the 2010 Control Cost Memo dicussing Boiler tune-up anticipated costs.


Sheet 5: Respondent Summary

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the Carbon Black Production RTR
Year Technical Hours Clerical Hours Management Hours Total Labor Hours Labor Costs Non-Labor (Annualized Capital/Startup and O&M) Costs Total Costs
1 606 61 30 697 $68,700 $365,973 $434,673
2 74 7 4 85 $8,332 $45,723 $54,055
3 74 7 4 85 $8,332 $45,723 $54,055
Total 753 75 38 866 $85,364 $457,419 $542,783
Average 251 25 13 289 $28,455 $152,473 $180,928








Year Number of Respondents Number of Responses Reporting Hours Recordkeeping Hours Total Hours Hours per Response Hours Per Respondent
1 15 51 307 390 697 14 46
2 15 21 48 36 85 4 6
3 15 21 48 36 85 4 6
Total 45 93 404 462 866 9 19
Average 15 31 135 154 289 9 19

Sheet 6: EPA_YR1

Table 5 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Carbon Black Production RTR - Year 1





(A) (B) (C) (D) (E) (F) (G) Footnotes
Burden Item Number of Occurrences Per Year Technical Hours Per Occurrence Tech Hours Per Year
(C=A x B)
Management Hours Per Year
(D = C x 0.05)
Clerical Hours Per Year
(E = C x 0.1)
Total Hours Per Year (C+D+E) Total Cost Per Year
1. Applications


not applicable
2. Read and Understand Rule Requirements


10 8 80 4 8 92 $4,436 a
3. Required Activities




C. Create Information




1. Initial Performance Testing (Applicability Assessment)

1.5 5.5 8.25 0.41 0.83 9.5 $457 b, c


2. Periodic (Every 5 Years) Performance Testing

0.3 8 2.4 0.12 0.24 2.76 $133 b, d

D. Gather Information

not applicable

E. Report Reviews



1. Notification of Performance Test Dates
18 0.5 9 0 1 10 $499

2. Review Report of Initial Performance Test
15 10 150 8 15 173 $8,317 c

3. Report of Periodic 5-year Performance Testing


3 20 60 3 6 69 $3,327 d
4. Review of Notification of Compliance Status Report
15 1 15 0.75 1.50 17 $832
5. Review Periodic Report



30 1 30 1.50 3.00 35 $1,663 e

F. Prepare annual summary report

1 4 4 0 0 5 $222

TOTAL




359 18 36 412 $19,886













Footnotes:
(a) Number of occurrences is the number of states and EPA Regions with affected sources (6 states + 4 EPA regions = 10 respondents).
(b) Assumes that agency personnel will choose to observe 10 percent of performance tests conducted.

(c) This rule requires facilities to perform initial performance testing (conduct an applicability assessment) on process vents downstream of the main unit filter (MUF) to determine applicability. Assumes 10 hours for initial performance test report (applicability assessment) review.
(d) The EPA is requiring periodic performance testing once every 5 years, with the first periodic performance test required within 3 years of the promulgation date of the final rule. Assumes 20 hours for periodic performance test report review.
(e) Assumes periodic reports will be submitted for review two times per year per facility (15 facilities).

Sheet 7: EPA_YR2

Table 6 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Carbon Black Production RTR - Year 2





(A) (B) (C) (D) (E) (F) (G) Footnotes
Burden Item Number of Occurrences Per Year Technical Hours Per Occurrence Tech Hours Per Year
(C=A x B)
Management Hours Per Year
(D = C x 0.05)
Clerical Hours Per Year
(E = C x 0.1)
Total Hours Per Year (C+D+E) Total Cost Per Year
1. Applications


not applicable
2. Read and Understand Rule Requirements


0 8 0 0 0 0 $0 a
3. Required Activities




C. Create Information




1. Initial Performance Testing (Applicability Assessment)

0 5.5 0 0 0 0 $- b, c


2. Periodic (Every 5 Years) Performance Testing

0.3 8 2.4 0.12 0.24 2.76 $133 b, d

D. Gather Information

not applicable

E. Report Reviews



1. Notification of Performance Test Dates
3 0.5 2 0 0 2 $83

2. Review Report of Initial Performance Test
0 10 0 0 0 0 $0 c

3. Report of Periodic 5-year Performance Testing


3 20 60 3 6 69 $3,327 d
4. Review of Notification of Compliance Status Report
0 1 0 0 0 0 $0
5. Review Periodic Report



30 1 30 1.50 3 35 $1,663 e

F. Prepare annual summary report

1 4 4 0 0 5 $222

TOTAL




98 5 10 113 $5,428













Footnotes:
(a) Number of occurrences is the number of states and EPA Regions with affected sources (6 states + 4 EPA regions = 10 respondents).
(b) Assumes that agency personnel will choose to observe 10 percent of performance tests conducted.
(c) This rule requires facilities to perform initial performance testing (conduct an applicability assessment) on process vents downstream of the main unit filter (MUF) to determine applicability. Assumes 10 hours for initial performance test report (applicability assessment) review.
(d) The EPA is requiring periodic performance testing once every 5 years, with the first periodic performance test required within 3 years of the promulgation date of the final rule. Assumes 20 hours for periodic performance test report review.
(e) Assumes periodic reports will be submitted for review two times per year per facility (15 facilities).

Sheet 8: EPA_YR3

Table 7 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Carbon Black Production RTR - Year 3





(A) (B) (C) (D) (E) (F) (G) Footnotes
Burden Item Number of Occurrences Per Year Technical Hours Per Occurrence Tech Hours Per Year
(C=A x B)
Management Hours Per Year
(D = C x 0.05)
Clerical Hours Per Year
(E = C x 0.1)
Total Hours Per Year (C+D+E) Total Cost Per Year
1. Applications


not applicable
2. Read and Understand Rule Requirements


0 8 0 0 0 0 $0 a
3. Required Activities




C. Create Information




1. Initial Performance Testing (Applicability Assessment)

0 5.5 0 0 0 0 $- b, c


2. Periodic (Every 5 Years) Performance Testing

0.3 8 2.4 0.12 0.24 2.76 $133 b, d

D. Gather Information

not applicable

E. Report Reviews



1. Notification of Performance Test Dates
3 0.5 2 0 0 2 $83

2. Review Report of Initial Performance Test
0 10 0 0 0 0 $0 c

3. Report of Periodic 5-year Performance Testing


3 20 60 3 6 69 $3,327 d
4. Review of Notification of Compliance Status Report
0 1 0 0 0 0 $0
5. Review Periodic Report



30 1 30 1.50 3 35 $1,663 e

F. Prepare annual summary report

1 4 4 0 0 5 $222

TOTAL




98 5 10 113 $5,428













Footnotes:
(a) Number of occurrences is the number of states and EPA Regions with affected sources (6 states + 4 EPA regions = 10 respondents).
(b) Assumes that agency personnel will choose to observe 10 percent of performance tests conducted.
(c) This rule requires facilities to perform initial performance testing (conduct an applicability assessment) on process vents downstream of the main unit filter (MUF) to determine applicability. Assumes 10 hours for initial performance test report (applicability assessment) review.
(d) The EPA is requiring periodic performance testing once every 5 years, with the first periodic performance test required within 3 years of the promulgation date of the final rule. Assumes 20 hours for periodic performance test report review.
(e) Assumes periodic reports will be submitted for review two times per year per facility (15 facilities).

Sheet 9: EPA Summary

Table 8 - Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the Cyanide Chemicals Manfufacturing RTR
Year Technical Hours Management Hours Clerical Hours Total Hours Labor Costs Non-Labor Costs Total Costs
1 359 18 36 412 $19,886 $0 $19,886
2 98 5 10 113 $5,428 $0 $5,428
3 98 5 10 113 $5,428 $0 $5,428
Total 554 28 55 638 $30,742 $0 $30,742
Average 185 9 18 213 $10,247 $0 $10,247

Sheet 10: O&M Costs

(A)
Testing
(B)
Cost, Annualized
(C)
Number of Respondents
(D)
Total Cost, Annualized
(B X C)
Footnotes
Periodic 5-Year Test


a
Method 25A $9,145 9 $82,305 b
New Initial Performance Testing


c
Method 25A $7,117 15 $106,755 d
TOTAL - 24 $190,000





Footnotes:
(a) Assumes 20% (3) of the total source category will annually perform the Periodic 5 -year test. Or 60% (9) in the 3 years of this ICR
(b) The estimated cost of this test would be $21,350 but is only required once. To determine annual cost we took the one time cost divided by the 3 year period of this ICR
(c) This rule requires facilities to perform initial performance testing on vents downstream the main unit filter (MUF) to determinate applicability.
(d) The estimated cost of this test would be $15,241 and is required once every 5 years. To determine annual cost we took the test cost divided by 5 to determine the cost over the 5 year period between tests. We then took that value and multiplied it by 3 to represent the 3 years of this ICR.





(A) (B) (C) (D) Footnotes
Testing Cost Per Test Total Number of Respondents Over 3-Year Period Total Cost



(B X C)
Periodic 5-Year Test


a
Method 25A $15,241 9 $137,169 b
New Initial Performance Testing


c
Method 25A $21,350 15 $320,250 d
TOTAL
24 $457,419
AVERAGE
8 $152,473
Footnotes:



(a) Assumes 20% (3) of the total source category will annually perform the Periodic 5 -year test. Or 60% (9) in the 3 years of this ICR
(b) The estimated cost of this test would be $15,241 and is required once every 5 years. We estimated that 20 percent of existing facilities (3 facilities) will need to performance these tests every year.
(c) The proposed rule requires all existing facilities (15 facilities) to perform initial performance testing on vents downstream from the main unit filter (MUF) to determinate applicability within the first year of the promulgated amendments.
(d) The estimated cost of this test would be $21,350 but is only required once in the three-year period.
*Memorandum. SC&A Incorporated to Korbin Smith, U.S. EPA/OAQPS/SPPD. Cost Estimates for Carbon Black Production National Emission Standards of Hazardous Air Pollutants (NESHAP) Risk and Technology Review(RTR) – Proposed Rule. October 2020.


















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