OpPl-200(,-G=/ 

-crowellr`moring 

Warren U. Lehrenbaum 

202.624.2755 

3 03, S 1~ `~ l 

1001 Penn lvania Avenue, NW, Washington, DC 20004-2595 " p202 624-2500 " f202 628-5116 

-- lS~f, 

J ~ . . 

November 2, 2010 

t~~f~{~ 

rv 

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 20460 

Re: Docket No. EPA-HQ-OPPT-2006-0621; 

2010/2015 PFOA Stewardship Program 

Dear Dear Sir or Madam: 

(? 

C'4 

-, r--; 

_... ,~ ~. 

rv 

rv 

0 

I am writing on behalf of Asahi Glass Co. Ltd. and AGC Chemicals Americas, Inc. 

(together, "Asahi") to provide you with Asahi's annual progress reports under the 2010/15 PFOA 

Stewardship Program. Asahi is proud of its continued participation in the voluntary Stewardship 

Program, and is very pleased to provide EPA with 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Consistent with EPA's Draft Guidance on Reporting Emissions and Product Content 

(October 2006) and EPA's September 2007 supplemental guidance (together, the "Draft 

Guidance"), Asahi is providing EPA with 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 : 

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

"Appendix F" in EPA's Draft Guidance), covering all of the Asahi-affiliated facilities 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 NO Ce! 

Crowell & Moring LLP . www.crowell .com . Washington, DC . New York . California . Anchorage . London . Brussels 
Document 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" One Emissions Report (designated "Appendix C" in EPA's Draft Guidance) and one 

Product Content Report (designated "Appendix D" in EPA's Draft Guidance) for the 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, 

from which all CBI has been deleted. In addition, as directed in the Draft 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. 

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. 

If you have any questions regarding this submission, or if you require any additional 

information, please do not hesitate to contact me at 202-624-2755 . 

Enclosures 

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

CrowSiCVWoriVg 1LP . www.crowell .com . Washington, DC . New York . California . Anchorage . London . Brussels