Fenwal Blood Technologies, Maricao PR 2007 APR View/Print

OMB No. 2010-0032
Expiration Date 01/31/2010

2007 Performance Track Annual Performance Report

Fenwal Blood Technologies, Maricao PR
A020056
Year 2 Annual Performance Report
Member Since 2003 (2nd Member Term)

SECTION A: GENERAL FACILITY INFORMATION

A.1

Name of your facility:

Fenwal Blood Technologies, Maricao PR

A.2

Name of your parent company:

Fenwal International Inc.

A.3

Facility contact person for the Performance Track program:

Name:	Mr. Noel Toledo
Title:	EHS Manager
Phone:	(787) 838-3000-Ext 6505
Fax:	(787) 838-2110
Email:	noel.toledo.mercado@fenwalinc.com

A.4

Facility location:

Facility Address

Street Address:	Road 357 km 0.8
Address Cont:
City:	Maricao
State:	PR
Zip Code:	00606

Mailing Address

Street Address:	PO Box 832
Address Cont:
City:	Maricao
State:	PR
Zip Code:	00606

If your facility has multiple street addresses, please list any other addresses for its sites or buildings.

A.5

Facility's website address (if any):

http://www.fenwalinc.com

A.6

Number of employees (full-time equivalents) who currently work in the facility:

500-1,000

A.7

For the purposes of where your facility would be listed in our Member Directory, please list the North American Industrial Classification System (NAICS) Code(s) that is (are) used to classify business at the facility:

Primary	Secondary	Tertiary	Quaternary	Quinary
325412

A.8.a

List the activities, products, or services that take place at your facility:

Our facility manufacture Blood Pack Units for blood collection. It are manufactured from vynil material and is distributed all around the world.

A.8.b

Provide the size and general description of your site:

Our facility is located in Maricao, Puerto Rico. We are occupying four building leased to Puerto Rico Industrial Company. Two of these buildings are for manufcaturing operations, which are a total of 106,155 square feet. Our operations include the preparation of the raw material cutting it to size for the sealing operation using RF equipments. And the extrusion of the PVC tubing that are going to be included in the blood pack unit to collect and dispense the blood. The second part of the assembly operations includes the addition of anti-coagulant solution, sterilization and packing process. It completes the assembly process, allowing our product to be ready for the customer.
The remain two buildings we have a space of 33,560 square feet for storage of raw material, finish good and MRO material for the operation.

A.9

Have the environmental requirements applicable to your facility changed during this reporting period?

SECTION B: ENVIRONMENTAL MANAGEMENT SYSTEM

B.1.a

Is your facility certified to ISO 14001?

Yes

B.2

Performance Track members must have their EMS assessed by an independent party at least once every three years. Please indicate the details of the most recent independent assessment conducted at your facility. If your most recent independent assessment did not cover all EMS elements and business areas, please use the "Add Assessment" button to indicate the additional partial assessments.

Independent EMS Assessment #1

When was this EMS assessment?

February 2007

What protocol was used?

ISO 14001 Standards
Specify:

Who conducted the audit?

Name:	Mr. Steve Ellis
Title:	ERM/CVS Lead Assessor
Organization:	ERM/CVS

Which EMS elements were included in the audit?

Policy, Planning, Implementation, Checking, Management

Did the assessment cover the entire facility or part of the facility?

Entire Facility

Which business areas were included in the audit?

B.3

EPA recommends that Performance Track members conduct an internal EMS assessment (partial or complete) every year. Did you conduct one in calendar year 2007?

Yes

Internal EMS Assessment #1

When was this EMS assessment?	October 2007
Which EMS elements were included in the audit?	Policy, Planning, Management
Did the assessment cover the entire facility or part of the facility?	Entire Facility

B.4

EPA recommends that Performance Track members conduct a regulatory compliance audit every year. Did your facility conduct any audits in calendar year 2007 to verify compliance with regulatory statutes?

Yes

Regulatory Compliance Audit #1

When was this regulatory compliance audit?	October 2007
Which regulations were included in the audit?	Clean Air Act (CAA) Clean Water Act (CWA) National Pollutant Discharge Elimination System (NPDES) Resource Conservation and Recovery Act (RCRA)

B.5

Note: Facility will be asked to report other audits and inspections in their 3rd reporting year.

B.6.a

Has your facility corrected all instances of potential non-compliance and EMS non-conformance identified during your audits and other assessments?

Yes

B.6.b

Performance Track members should have a Senior Management Review of their EMS every year. Did this review take place in calendar year 2007?

Yes

Who was the senior manager present at the review?

Name: Mr. Luis M. Carrillo

Title: General Manager

B.6.c

Performance Track members should conduct a systematic identification and/or review of their environmental aspects at least once every two years. When was your last one conducted?

December 2006

SECTION C: ENVIRONMENTAL PERFORMANCE RESULTS

Goal 1: Fenwal Blood Technologies, Maricao PR's first goal is to reduce the facility's total water use.
This is a challenge goal.
C.1.a	Briefly describe your activities and achievements related to this goal or, if relevant, any circumstances that delayed progress this year.
	-Waterless hand sanitizer were completely implemented in all the gowning areas. We are encouraging our employees to use this process as the primary hand cleaning process in our dressing and GMP code and regulation. - Correction of water loss through pipes from the main line.
	Activities Conducted During 2006:
	- Were substitute seven (7) regular urinals for waterless units to reduce the water usage for this activity. - Correction of water loss through pipes from the fire system. - Use of waterless hand sanitazer
C.1.b	Describe the data collection process and data source(s) that you used to measure progress towards this goal.
	We are monitoring the monthly water usage from our city water and the well water. This information is part of our monthly metrics that are discussed within the staff. The normalization of this total with the Single Pack Unit provides the final number against our goal.
C.1.c	Please report your facility's actual performance.

Performance Data
	Baseline	Year 1	Year 2	Year 3	Perform.
Calendar Year	2005	2006	2007	2008	Goal	Units
Actual Quantity (per year)	27,555,170	21,156,464	22,135,339		n/a	Gallons Specify other:

C.1.d

Normalized progress toward goal.

Normalized Total	Baseline	Year 1	Year 2	Year 3	Perform. Goal	Units
Normalizing Factor	1.0	0.92	0.97
Normalized Quantity	27,555,170	22,996,156.52	22,819,937.11		23,400,000	Gallons Specify other:
Basis for your Normalizing Factor:	The normalizing factor is based total production activity of single pack unit produced in our manufacturing area during the year.

Goal 2: Fenwal Blood Technologies, Maricao PR's second goal is to reduce the generation of, and improve the management of, the facility's non-hazardous waste.
C.2.a	Briefly describe your activities and achievements related to this goal or, if relevant, any circumstances that delayed progress this year.
	- We are reinforcing the importance for recycling, re-using, repairing through the introduction of additional points of collections of the recycle material through out the facility. Supervisors are engage in the program and are subject to inspections to assured they ahve the corresponding collecting container in use. - We are increasing the volume of material recycled, wet PVC, through the addition of a shredder machine. This equipment allowed to our recycling team to process more quickest the collected material and for the recycler to have a better way to handle it. We have eliminated the need to send to the landfill this material, in a 100%.
	Activities Conducted During 2006:
	-We have identified a recycling market for finished good plastic materials. Before, this material was disposed in the landfill. - Part of the waste reduction was due to product quality improvement. We provide employee awareness related to recycling material and waste generated from our operations, and emphasize to re-use any material for other activities. This materials includes cardboard and polyethilene, that some of this material have been dumped into the non-hazardous waste compactor for disposal in the landfill. In addition we have reduced waste to landfill by identifying a recycling broker that is receiving our stainless steel needle contaminated with plastic covers.
C.2.b	Describe the data collection process and data source(s) that you used to measure progress towards this goal.
	-Material recycled are weight before send it to the recycling company on monthly basis and records are maintained in an excel spreadsheet. - Cardboards are compacted in bundle of 600 lbs, this is an standard size using a vertical compactor. - Same process is used to manage the recycled plastic and poliethylene material. - Shredded material are manage in bags that weight 35 lbs, that is managed by the recycling personell, collected in a trailer of 40 feet and mainatained in our facility untilit is fill-up. -All data collected is audited by our facility and the recycler company that revise the documents and the weight of the bags randomly. -Dry PVC material are weighted using the in-house sclae in the warehouse area. This equipment is also used to weight our finish product for delivery purposes and a claibration program does exist to comply with standards. -Data is communicated to the staff on monthly basis. - Domestic waste is contained in two 40 yds containers that are moved from our facility on bi-monthly and some times every three month, depend upon our activity. Because we are collecting the domestic waste in these two containers and the service is on-call, we maintained our service tickets and called them to have the information of the weight related to this container. This information is maintained in our internal data base in the excell spreadsheet.
C.2.c	Please report your facility's actual performance.

Performance Data
Waste Management Method	Baseline	Year 1	Year 2	Year 3	Units
Waste Management Method	2005	2006	2007	2008	Units
Landfill Specify other:	248	159	124		Tons Specify other:
Reused/recycled off-site Specify other:	1,100	675	857		Tons Specify other:
Specify other:					Specify other:
Specify other:					Specify other:
Specify other:					Specify other:

C.2.d

Summarized progress toward goal.

Actual Total	Baseline	Year 1	Year 2	Year 3	Perform. Goal	Units
Total Non Hazardous Waste	1,348.00	834.00	981.00		n/a	Tons Specify other:

Normalized Total	Baseline	Year 1	Year 2	Year 3	Perform. Goal	Units
Normalizing Factor	1.0	0.92	0.97
Total Non Hazardous Waste	1,348.00	906.52	1,011.34		1,140.00	Tons Specify other:
Basis for your Normalizing Factor:	The normalizing factor is based total production activity of single pack unit produced in our manufacturing area during the year.

Goal 3: Fenwal Blood Technologies, Maricao PR's third goal is to reduce the facility's total (non-transportation) energy use.

C.3.a Briefly describe your activities and achievements related to this goal or, if relevant, any circumstances that delayed progress this year.

-New technology and process has been identified and bought a power generator and air compresssor tyo increase energy efficiency.
-Both of this new equipments has been received but equipment certification was not completed by end of year 2007 as it was scheduled.

Activities Conducted During 2006:

- Activity identified as the major contributor on energy use was the A/C units. For it evaluated and change the room temperature to estabilized it and assure confort and compliance with our process resulting on reduction of energy consumption.
- Were also identified equipment that were maintained running 24 hrs where the area do not required them, and was establish a timer to turn them off.
- Office light switchs were change for photo cells to assured that are off whenever no one is in the room.
- We have in use 3 boilers that consume diesel to produce water vapor. A new technoligy consisting in the use of magnets to improve the fuel efficiencty was incorporated in our system reducing the diesel consumption in 10% from previous year.
- Has been incorporate solar water heaters to avoid the usage of power to maintain hot water in the cleaning room to clean the hands process prior to enter to the clean room.
- We are validating the usage of Cal-Stat, a germicide, to reduce the dependence from the water to clean the hands prior to enter to the clean room.

Note: 2005 and 2006 data were revised on September 17, 2007 to correctly report electricity use. Previously 16.21 Mwh and 14.55 Mwh were reported instead of 16,212,340 Kwh and 14,551,020 Kwh. 2005 data was also previously updated to include diesel fuel and propane consumption and to remove fuel oil, which should have been reported as diesel.

C.3.b Describe the data collection process and data source(s) that you used to measure progress towards this goal.

-Data for the electricity from utility are collected using the electricity bill.
-Diesel consumption data is maintained whenever we receive a truck to fill our tanks. It is also used for the air emmisssion records and report to local agency, Environmental Quality Board.
-Propane gas data is collected in the same way as the diesel, whenever a delivery occurred.

C.3.c Please report your facility's actual performance.

Energy Generated Off-Site

Baseline Year 1 Year 2 Year 3 Units

Calendar Year 2005 2006 2007 2008

Electricity Purchased

Electricity from Grid/Utility 16,212,340 14,551,020 15,608,340 Kwh

Specify:

Electricity from Off-Grid Renewable Sources 0 0 Kwh

Specify:

Total Electricity Purchased 55,316.50 49,648.08 53,255.66 MMBtus

If your facility purchases electricity from the grid, please confirm that the electricity geographic region shown below is correct. If incorrect, please contact the Performance Track Information Center.
Puerto Rico

Steam

EPA will be determining the greenhouse gases associated with the generation of the steam that you purchase. We will be contacting you for additional information regarding the source of the steam generated.

Specify:

Total Energy Generated Off-Site 55,316.50 49,648.08 53,255.66 MMBtus

Sources of Energy Generated On-Site

Baseline Year 1 Year 2 Year 3 Units

Calendar Year 2005 2006 2007 2008

Coal

Specify:

Natural Gas

Specify:

Crude Oil

Specify:

Fuel Oil

Specify:

Diesel 42,947.3 39,914.9 39,154 MMBtus

Specify:

Propane/LPG 320.544 285.768 310.390 MMBtus

Specify:

Gasoline

Specify:

Hydrogen Powered Fuel Cells

Specify:

Natural Gas/Methane Powered Fuel Cells

Specify:

Biomass

Specify:

Biodiesel

Specify:

Solar

Specify:

Wind

Specify:

Landfill Gas

Specify:

Geothermal

Specify:

Hydroelectric

Specify:

Tire Derived Fuel

Specify:

Other Fuel or Source
Specify:

Specify:

Total Energy Generated On-Site 43,267.84 40,200.67 39,464.39 MMBtus

C.3.d Total energy use and associated greenhouse gas emissions.

Actual Energy Use Total Baseline Year 1 Year 2 Year 3 Perform.
Goal Units

Total Renewable Energy Use 553.17 496.48 532.56 n/a MMBtus

Total Non-Renewable Energy Use 98,031.18 89,352.27 92,187.49 n/a MMBtus

Total Energy Use 98,584.34 89,848.75 92,720.05 n/a MMBtus

Metric Tons of CO₂ Equivalents 16,227.77 14,661.74 15,467.86 n/a MTCO2E

Metric Tons of CO₂ Equivalents Offset due to Investments in Green Energy, e.g. green tags 0 MTCO2E

Net Metric Tons of CO₂ Equivalents 16,227.77 14,661.74 15,467.86 n/a MTCO2E

Normalized Energy Use Total Baseline Year 1 Year 2 Year 3 Perform.
Goal Units

Normalizing Factor 1.0 0.92 0.97

Total Energy Use 98,584.34 97,661.68 95,587.68 95,693.22 MMBtus

Specify other:

Net Metric Tons of CO₂ Equivalents 16,227.77 15,936.67 15,946.25 15,539.73 MTCO2E

Specify other:

Basis for your Normalizing Factor:
The normalizing factor is based total production activity of single pack unit produced in our manufacturing area during the year.

Progress Towards Other Significant Aspects of your EMS

In the table below, please provide a narrative summary of progress made toward EMS objectives and targets other than those reported as Environmental Performance Goals. You may limit the summary to environmental aspects that are significant and towards which progress has been made during the reporting year.

Do you have additional environmental aspects to report? Yes

Environmental Aspect Progress Made This Year (e.g., quantitative or qualitative improvements, activities conducted)

Noise exposition Audit and monitoring was performed in all areas that are within the hearing conservation program. Have been demonstrate that noise decibels have not been increased, and we still in the need to continue with this program.

Non-Ionizing radiation exposition Monitoring for the exposition of non-ionizing radiation was conducted on Novemeber 2007. This monitoring has demonstrate that all equipments are performing under the exposure limits according to the regulation.(IEEE C95.1-1991/ANSI C95.1-1992 limits Head and Groin area readings multiplied by the duty factor to a maximum of : E-Field = 1.22 mW/cm2 H-Field = 13 mW/ cm2 Induced Current = 200mA )

SECTION D: PUBLIC OUTREACH AND PERFORMANCE REPORTING

D.1.a Please describe your process to identify potential community environmental concerns.

We have sponsored the effort from public school in their reforestation projects.
-Actively participate with local goverment activities and meeting for the emergency response plan.
-Support local emergency agencies providing absorbent material and support in the process to dispose some of the absorbent material used to collect used oil.

D.1.b If you identified community environmental concerns, how did you respond to them?

- We maintain close relation with the Municipal recycling department and help them through the collection of material to improve their performance, establishing our committment in the environment concern.
- Contacting the team leader for the school or the community committe and be part of the solution, providing knowledge, material and human resources from our labor force.

D.1.c Please describe how you informed the community about environmental matters related to your facility.

-We have environmental fair in our facility and invite the community to receive information from them.

D.2 Please indicate which of the following methods your facility plans to use to make its Performance Track Annual Performance Report available to the public. Please check all that apply.

Open House, Meetings, Community Advisory Panel, Building Lobby, Environmental Fairs

OMB No. 2010-0032
SECTION E: SELF-CERTIFICATION OF CONTINUED PROGRAM PARTICIPATION FOR ANNUAL PERFORMANCE REPORT
The U.S. Environmental Protection Agency is not yet in a position to accept electronic signatures and therefore requests a faxed, signed copy of the Section E page. Please complete Section E online, then print Section E using the link on the Overview page. Section E should be signed by the senior manager of your facility and faxed it to the Performance Track Information Center at (617) 354-0463.
On behalf of Fenwal Blood Technologies, Maricao PR, I certify that: I have read and agree to the terms and conditions as specified in the National Enviromental Performance Track Program Guide. This facility, to the best of my knowledge, continues to meet all program criteria; I have personally examined and am familiar with the information contained in this Annual Performance Report. The information contained in this report is, to the best of my knowledge and based on reasonable inquiry, true, accurate, and complete; My facility has an environmental management system (EMS), as defined in the Performance Track EMS criteria, including systems to maintain compliance with all applicable federal, state, tribal, and local environmental requirements, in place at the facility, and the EMS will be maintained for the duration of the facility's participation in the program; My facility has conducted an objective assessment of its compliance with all applicable federal, state, tribal, and local environmental requirements; and the facility has corrected all identified instances of potential or actual noncompliance; and Based on the foregoing compliance assessments and subsequent corrective actions (if any were necessary), my facility is, to the best of my knowledge and based on reasonable inquiry, currently in compliance with applicable federal, state, tribal, and local environmental requirements. I agree that EPA's decision whether to accept participants into or remove them from the National Environment Performance Track is wholly discretionary, and I waive any right that may exist under any law to challenge EPA's acceptance or removal decision. I am the senior manager with responsibility for the facility and am fully authorized to execute this statement on behalf of the corporation or other legal entity whose facility is part of the National Environmental Performance Track program.
Signature/Date:	______________________________________________________
Name:	Mr. Luis M Carrillo
Title:	Plant Manager
Facility Name:	Fenwal Blood Technologies, Maricao PR
Facility Street Address:	Road 357 km 0.8 Maricao, PR 00606
Mailing Address:	PO Box 832 Road Maricao , PR 00606
Performance Track ID#:	A020056

Goal 3: Fenwal Blood Technologies, Maricao PR's third goal is to reduce the facility's total (non-transportation) energy use.
C.3.a	Briefly describe your activities and achievements related to this goal or, if relevant, any circumstances that delayed progress this year.
	-New technology and process has been identified and bought a power generator and air compresssor tyo increase energy efficiency. -Both of this new equipments has been received but equipment certification was not completed by end of year 2007 as it was scheduled.
	Activities Conducted During 2006:
	- Activity identified as the major contributor on energy use was the A/C units. For it evaluated and change the room temperature to estabilized it and assure confort and compliance with our process resulting on reduction of energy consumption. - Were also identified equipment that were maintained running 24 hrs where the area do not required them, and was establish a timer to turn them off. - Office light switchs were change for photo cells to assured that are off whenever no one is in the room. - We have in use 3 boilers that consume diesel to produce water vapor. A new technoligy consisting in the use of magnets to improve the fuel efficiencty was incorporated in our system reducing the diesel consumption in 10% from previous year. - Has been incorporate solar water heaters to avoid the usage of power to maintain hot water in the cleaning room to clean the hands process prior to enter to the clean room. - We are validating the usage of Cal-Stat, a germicide, to reduce the dependence from the water to clean the hands prior to enter to the clean room. Note: 2005 and 2006 data were revised on September 17, 2007 to correctly report electricity use. Previously 16.21 Mwh and 14.55 Mwh were reported instead of 16,212,340 Kwh and 14,551,020 Kwh. 2005 data was also previously updated to include diesel fuel and propane consumption and to remove fuel oil, which should have been reported as diesel.
C.3.b	Describe the data collection process and data source(s) that you used to measure progress towards this goal.
	-Data for the electricity from utility are collected using the electricity bill. -Diesel consumption data is maintained whenever we receive a truck to fill our tanks. It is also used for the air emmisssion records and report to local agency, Environmental Quality Board. -Propane gas data is collected in the same way as the diesel, whenever a delivery occurred.
C.3.c	Please report your facility's actual performance.

Energy Generated Off-Site
	Baseline	Year 1	Year 2	Year 3	Units
Calendar Year	2005	2006	2007	2008	Units
Electricity Purchased
Electricity from Grid/Utility	16,212,340	14,551,020	15,608,340		Kwh Specify:
Electricity from Off-Grid Renewable Sources		0	0		Kwh Specify:
Total Electricity Purchased	55,316.50	49,648.08	53,255.66		MMBtus
	If your facility purchases electricity from the grid, please confirm that the electricity geographic region shown below is correct. If incorrect, please contact the Performance Track Information Center. Puerto Rico
Steam EPA will be determining the greenhouse gases associated with the generation of the steam that you purchase. We will be contacting you for additional information regarding the source of the steam generated.					Specify:
Total Energy Generated Off-Site	55,316.50	49,648.08	53,255.66		MMBtus

Sources of Energy Generated On-Site
	Baseline	Year 1	Year 2	Year 3	Units
Calendar Year	2005	2006	2007	2008	Units
Coal					Specify:
Natural Gas					Specify:
Crude Oil					Specify:
Fuel Oil					Specify:
Diesel	42,947.3	39,914.9	39,154		MMBtus Specify:
Propane/LPG	320.544	285.768	310.390		MMBtus Specify:
Gasoline					Specify:
Hydrogen Powered Fuel Cells					Specify:
Natural Gas/Methane Powered Fuel Cells					Specify:
Biomass					Specify:
Biodiesel					Specify:
Solar					Specify:
Wind					Specify:
Landfill Gas					Specify:
Geothermal					Specify:
Hydroelectric					Specify:
Tire Derived Fuel					Specify:
Other Fuel or Source Specify:					Specify:
Total Energy Generated On-Site	43,267.84	40,200.67	39,464.39		MMBtus

Actual Energy Use Total	Baseline	Year 1	Year 2	Year 3	Perform. Goal	Units
Total Renewable Energy Use	553.17	496.48	532.56		n/a	MMBtus
Total Non-Renewable Energy Use	98,031.18	89,352.27	92,187.49		n/a	MMBtus
Total Energy Use	98,584.34	89,848.75	92,720.05		n/a	MMBtus
Metric Tons of CO₂ Equivalents	16,227.77	14,661.74	15,467.86		n/a	MTCO2E
Metric Tons of CO₂ Equivalents Offset due to Investments in Green Energy, e.g. green tags		0				MTCO2E
Net Metric Tons of CO₂ Equivalents	16,227.77	14,661.74	15,467.86		n/a	MTCO2E

Normalized Energy Use Total	Baseline	Year 1	Year 2	Year 3	Perform. Goal	Units
Normalizing Factor	1.0	0.92	0.97
Total Energy Use	98,584.34	97,661.68	95,587.68		95,693.22	MMBtus Specify other:
Net Metric Tons of CO₂ Equivalents	16,227.77	15,936.67	15,946.25		15,539.73	MTCO2E Specify other:
Basis for your Normalizing Factor:	The normalizing factor is based total production activity of single pack unit produced in our manufacturing area during the year.

D.1.a	Please describe your process to identify potential community environmental concerns.
	We have sponsored the effort from public school in their reforestation projects. -Actively participate with local goverment activities and meeting for the emergency response plan. -Support local emergency agencies providing absorbent material and support in the process to dispose some of the absorbent material used to collect used oil.
D.1.b	If you identified community environmental concerns, how did you respond to them?
	- We maintain close relation with the Municipal recycling department and help them through the collection of material to improve their performance, establishing our committment in the environment concern. - Contacting the team leader for the school or the community committe and be part of the solution, providing knowledge, material and human resources from our labor force.
D.1.c	Please describe how you informed the community about environmental matters related to your facility.
	-We have environmental fair in our facility and invite the community to receive information from them.
D.2	Please indicate which of the following methods your facility plans to use to make its Performance Track Annual Performance Report available to the public. Please check all that apply.
	Open House, Meetings, Community Advisory Panel, Building Lobby, Environmental Fairs

SECTION A: GENERAL FACILITY INFORMATION

SECTION B: ENVIRONMENTAL MANAGEMENT SYSTEM

SECTION C: ENVIRONMENTAL PERFORMANCE RESULTS

SECTION D: PUBLIC OUTREACH AND PERFORMANCE REPORTING

SECTION E: SELF-CERTIFICATION OF CONTINUED PROGRAM PARTICIPATION FOR ANNUAL PERFORMANCE REPORT