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1001 Pennsylvania Avenue, NW, Washington, DC 20004-2595 p 202 624-2500 f 202 628-5116

CBIC Control Number 

# 362480 Warren U. Lehrenbaum (202) 624-2755 wlehrenbaurn@crowell.com P.) 

### October 31, 2014
BY HAND DELIVERY Document Control Office [7407M] Office of Pollution Prevention and Toxics (OPPT) U.S. Environmental Protection Agency EPA East Building, Room 6428 1201 Constitution Avenue, NW Washington, DC 20004 Attention: Docket No. EPA-HQ-OPPT-2006-0621 

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Si5P00001 OSIOR

Re: 2010/2015 PFOA Stewardship Program Annual Progress Reports

Dear Sir or Madam:
I am writing on behalf of Asahi Glass Co. Ltd. and AGC Chemicals Americas, Inc. (together, "Asahi" or "the company") to provide you with Asahi's annual progress reports under the 2010/15 PFOA Stewardship Program. Asahi was one of the original participants in the voluntary Stewardship Program, and the company is proud of its continued participation in the program and its longstanding commitment to reduce environmental loadings of PFOA, higher homologues and their precursors (hereinafter referred to as "long chain PFCs"). Over the past several years Asahi has made substantial investments in research and development and spent millions of dollars in capital expenditures in order to identify and bring to market newtechnologies and new chemistries that eliminate the use of long chain PFCs utilizing environmentallypreferable alternative, without sacrificing product perthrmance. As the attached progress reports reflect, these efforts have allowed Asahi to achieve dramatic reductions in both product content and emissions of PFOA and other long chain PFCs. Asahi is pleased to confirm again that the company is on track to meet its target for 2015 of practical elimination of PFOA and other long chain PFCs in both product content and facility emissions; this includes all isolated chemical intermediates sold or used on-site. As in previous years, the company remains concerned that in order to ensure the success of the Stewardship Program and assure the continued shift to alternative, non-PFOA, non-long chain PFC products, regulatory restrictions on long chain perfluorinated chemicals will be essential both globally and in the US. 

### Consistent with EPA's Draft Guidance on Reporting Emissions and Product Content (October 2006) and the Agency's supplemental guidance, Asahi is providing EPA with progress reports pertaining to the following facilities: (i) Bayonne (N,I); (ii) Hillhouse (UK); (iii) Chiba (japan); and (iv) Seimi Chemical Co. (Japan). Specifically, you should find the following reports enclosed:

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-A , Warren U. ehrenbaum Document Control Office [7407M] October 31, 2014 Page 2

• A Summary of Reductions in Emissions and Product Content Report (designated "Appendix

F" in EPA's Draft Guidance) as well as a summary of accomplishments table for 2013, covering all of the Asahi-affiliated facilities listed above;

• One Emissions Report (designated "Appendix C" in EPA's Draft Guidance) and one Product Content Report (designated "Appendix D" in EPA's Draft Guidance) fbr the Bayonne facility;

• One Emissions Report ("Appendix C") and one Product Content Report ("Appendix D") for the Hillhouse facility;

• Four Emissions Reports ("Appendix C") and four Product Content Reports ("Appendix D") for the Chiba facility; and

• Three Emissions Reports ("Appendix C") and three Product Content Reports ("Appendix D") fbr Seim i Chemical Co. For each report being submitted, we have provided a confidential version, containing confidential business information ("CBI"), and we have separately provided a sanitized version, from which all confidential business information has been deleted. In addition, as directed in EPA's guidance, we are providing electronic versions of these reports on CD. We have enclosed two CDs, one that contains the confidential versions of the reports, and one that contains the sanitized versions. Please ensure that all materials marked as containing CBI are protected against public disclosure. If you have any questions regarding this submission, or if you require any additional information, please do not hesitate to contact ine.

Enclosures

cc: Toni Krasnic (w/sanitized attachments) Nicholas Nairn-Birch (w/sanitized attachments)

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