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# -crowellr`moring

Warren U. Lehrenbaum 202.624.2755 

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rv HAND DELIVERY Document Control Office [7407M] Office of Pollution Prevention and Toxics (OPPT) U.S. Environmental Protection Agency EPAEast Building, Room6428 1201 Constitution Avenue, NW Washington, DC 20460 Re: Docket No. EPA-HQ-OPPT-2006-0621 ; 2010/2015 PFOAStewardship Program Dear Dear Sir or Madam : (?

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I am writing on behalf of Asahi Glass Co. Ltd. and AGCChemicals Americas, Inc. (together, "Asahi") to provide youwith Asahi's annual progress reports under the 2010/15 PFOA Stewardship Program

. Asahi is proud ofits continued participation in the voluntary Stewardship Program, and is very pleased to provide EPAwith the attached progress reports which document the significant reductions that Asahi has achieved in product content and facility emissions. Consistent with EPA's Draft Guidance on ReportingEmissions and Product Content (October 2006) and EPA's September 2007 supplemental guidance (together, the "Draft Guidance"), Asahi is providing EPAwith progress reports pertaining to the following four facilities: (i) Chiba (Japan) ; (ii) Seimi Chemical Co. (Japan) ; (iii) Bayonne (NJ) ; and (iv) Hillhouse (UK) . Specifically, you should find the following reports enclosed: " ASummary of Reductions in Emissions and Product Content Report (designated "Appendix F" in EPA's Draft Guidance), covering all oftheAsahi-affiliated facilities listed above; " Four Emissions Reports ("Appendix C") and four Product Content Reports ("Appendix D") for the Chiba facility; Four Emissions Reports ("Appendix C") and three Product Content Reports ("Appendix D") for Seimi Chemical Co. ; 

## CONTAINS NOCe! Crowell & Moring LLP . www .crowell .com . Washington, DC . New York . California . Anchorage . London . BrusselsDocument Control Office [7407M]

November 2, 2010 Page 2 " One Emissions Report (designated "Appendix C" in EPA's Draft Guidance) and one

Product Content Report (designated "Appendix D" in EPA's Draft Guidance) for the Bayonne facility; and " One Emissions Report ("Appendix C") and one Product Content Report ("Appendix D") for the Hillhouse facility. For each report being submitted, we have provided a confidential version, containing confidential business information ("CBI"), and we have separately provided a sanitized version, fromwhich all CBI has been deleted. In addition, as directed in the Draft Guidance, we are providing electronic versions ofthese reports on CD . We have enclosed two CDs, one that contains the confidential versions ofthe reports, and one that contains the sanitized versions. Please ensure that all materials marked as containing CBI are protected against public disclosure. Finally, please note that the emissions and product content information provided in the attached reports is based on normalized year-end run-rate data, which more accurately captures incremental emissions and product content reductions that have been achieved over the course of the year. Ifyou have any questions regarding this submission, or ifyou require any additional information, please do not hesitate to contact me at 202-624-2755.

Enclosures cc: Toni Krasnic (EPA) (w/o CBI)

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