### Cover Letter

{XXX} Document Control Officer Office of Pollution Prevention and Toxic Substances 7407 US EPA, 1200 Pennsylvania, NW Washington, D.C. 20460
Dear Sir/Madam: This letter is to inform you of our submission of a Premanufacture Notice (PMN) under Section 5 (a) of the Toxic Substance Control Act. We certify that we have remitted the fee specified in 40 CFR 700.45. The User Fee Identification number is TS P9536S and check number is 0000861488. The notified substance {XXX}, is a new developed {XXX}. It will be manufactured outside of the US and the annual import quantity is expected to about 1000 kg. In addition, this PMN is being filed as a "Sustainable Futures" submission. A completed SF Summary Assessment Worksheet can be found as a PMN attachment. {XXX} is an EPA SF training graduate. Should you have any questions regarding our PMN, please contact me at {XXX}.

Sincerely,
{XXX}

Page 1 SANITIZED SUBMISSION0000861488 FRET141223133822651
P9536S

X X X X X

X

X

Page 2 SANITIZED SUBMISSIONX



### X

Page 3 SANITIZED SUBMISSIONXXX XXX XXX XXX XXX XXX XXX XXX XXX

XXX XXX XXX XXX XXX XXX XXX XXX
XXX XXX 

### X

X

X X

X

X

Page 4 SANITIZED SUBMISSION

### X

XXX 

### X

XXX


### X 386622-1 &

387425 IES Report__PMN 14-9536 sanitized.pdf C13H20O

chemcial structure -- PMN 09-0536.jpg

Page 5 SANITIZED SUBMISSIONPage 6 SANITIZED SUBMISSIONPage 7 SANITIZED SUBMISSIONPage 8 SANITIZED SUBMISSIONOctahydro-4,7-methano-1H-indene propanal (isomer mix)

(3aS,7aR)-1-ethyloctahydro-1H-4,7-methanoindene 1.4
3-[(3aR,7aS)-3a,4,5,6,7,7a-hexahydro-1H-4,7-methanoinden-3-yl]propanal 1.7 3-[(3aR,7aS)-3a,4,5,6,7,7a-hexahydro-1H-4,7-methanoinden-2-yl]propanal 1.1

Page 9 SANITIZED SUBMISSION1000 1000



### X

Fragrance ingredient for use in fragrances for soaps, detergents, cleaners and other personal care & household products 100 2.5 0 100 0 0



### X

Page 10 SANITIZED SUBMISSIONPart I, Section C, 2.a. Additional Consumer Use Text

Category of Use Fragrance ingredient for use in fragrances for soaps, detergents, cleaners and other personal care & household products: The notified substance will be used as a fragrance ingredient, being blended (mixed) with other fragrance ingredients to make fragrance oils that will be sold to industrial and commercial customers for their incorporation into soaps, detergents, cleaners and other similar household and consumer products. It can be incorporated into cosmetic products as well. The anticipated typical percentage of the notified substance that wll be used in these fragrance formulations will no be more than 2.5%. The 99th% maximum level of fragrance oil used in soaps, detergents, and other similar consumer products is 5%. Therefore, the maximum concentration of the notified substance in these final consumer products is 0.125%. The notified substance is not anticipated to undergo any chemical reactions in the fragrance formulation or in the consumer products that will cause the notified substance to lose its identity.

Page 11 SANITIZED SUBMISSION

### X

5 4 200 

### 1

See continuation page. id: <P8SB1bC1> XXX

XXX XXX XXX XXX 

### X

Page 12 SANITIZED SUBMISSIONCompounding Process_PMN 14-9536.jpg

Page 13 SANITIZED SUBMISSIONP8SB1bC1 Part II, Section A, 1.d. Process Description Optional Text

The compounding process is strictly a blending of the notified substance with other fragrance ingredients. The notified substance will be blended with other ingredients to make finished fragrance oil that will be sold to industrial and commercial customers for their incorporation into soaps, detergents, cleaners and other similar household and consumer products. The blending operation is an open system. The blending vessels used are typically covered in the workplace but not sealed and rest on an electronic scale. In general, fragrance ingredients are pumped or gravity fed into the vessel until the desired weight is achieved. When all the ingredients are added, the mixture is stirred until the blending operation is complete (there is no chemical reaction taking place). The finished blended fragrance oil is then pumped into an appropriate delivery vessel(s). Worker exposures are limited to those situations when materials are being added or transferred, not during the mixing process, and are estimated to be 0.5 hour of the approximate 4 hours to prepare a typical batch. The total annual quantity used for compounding is anticipated to be about 1000 kg for the notified substance, which will be stored in 4-6 drums. Once the drums are emptied, they are transported (with other empty used drums) via approved transport to an approved drum reconditioning contractor* who cleans, crushes and shreds the containers. The scrap metal is then recycled. Drum wash water is sent to the Middlesex County Utility Authority, PO Box 159, Main St. Sayrevile, NJ (NJPDES# NJ0020141). Average number of empty drums used to transport and store the notified substance (100%) will be 5 per year. Typically the residue of the notified substance in the empty drums is anticipated to be 0.18% (IFF internal survey for drum residue for finished fragrance oil via pouring). *Approved contractor for drum removal: Recycle Inc, East 20-A Harmich Rd South Plainfield, NJ 07080 (908) 756-2200 EPA ID#: NJ000007153 If the notified substance was to be used at the anticipated maximum level of 2.5% in a fragrance oil, the maximum amount of the notified substance blended in a typical batch of 200kg would be 5kg. Assuming 5kg of the notified substance per batch, and a total annual quantity for processing to be 1000kg, the total number of batches per year estimated to contain the notified substance is 200. Assuming each batch process time is 4hr, total process time involving the notified substance will be 800hr (= 34 days). The activities that are related to worker exposure and environmental release/disposal include: 1)	unloading the notified ingredient from drum 2) empty drum wash and disposal (5 drums per year) 3)	chemical blending and equipment washes after blending (total of 34 days per year) 4)	sampling liquid product 5) loading finished fragrance compound to drum The typical percentage of the notified substance that will be used in the fragrance oil will be 2.5%. The 99th% maximum level of fragrance oil used in soaps, detergents, and other similar consumer products is 5%. Therefore, the maximum concentration of the notified substance in these consumer products is 0.125%. The notified substance is not anticipated to undergo any chemical reactions in the fragrance formulation or in the consumer products that will cause the notified substance to lose its identity.

Page 14 SANITIZED SUBMISSIONchemical blending chemical resistant gloves, proper clothing, safety glasses, local exhaust ventilation liquid, 2.5% or less 1 0.5 200

connecting/disconnecting transfer lines chemical resistant gloves, proper clothing, safety glasses, local exhaust ventilation liquid, 2.5% or less 1 0.5 200

equipment washes at compounding site chemical resistant gloves, proper clothing, safety galssess, local exhaust ventilation liquid, 2.5% or less 1 0.5 200

Page 15 SANITIZED SUBMISSION

### X Bayshore Regional Sewerage Authority, Union Beach, NJ NJ0024708

1 none 0.625kg/da y for 5 days/yr POTW See continuation page. id: <P9ASA3(5a)C1R1> undetectab le

1 none trace Fugitive Air Biofilter undetectab le

2 none 0.01

kg/batch for 200 POTW wastewater treatment plant with efficiency >90% (EpiSuite V 4.10) undetectab le

2 none trace Fugitive Air biofilter undetectab le

3 none trace Fugitive Air biofilter undetectab le

Page 16 SANITIZED SUBMISSIONP9ASA3(5a)C1R1 Part II, Section A, B.(5a) Control Technology & Efficiency, Row 1

off-site wastewater treatment plan with NJPDES#NJ0020141 with wastewater removal treatment efficiency > 90% (EpiSuite V4.10)

Page 17 SANITIZED SUBMISSION25

Operation in sites controlled by others_PMN 14-9536.jpg We anticipate that we will have approximately 25 customers, but each customer may have multiple sites where they use the notified material. Therefore we can not specifically identify the location of the sites of our potential customers. The diagram above represents our expectation of the manufacturing practices of our customers. These practices are anticipated to be similar to the practices of the processing of fragrance oils by International Flavors & Fragrances Inc. Domestic production of household consumer products is anticipated to be automated to a higher degree and worker exposure limited mainly to line connections, equipment maintenance and cleaning. Any worker exposure will be incidental. Standard workplace practices include use of chemical resistant gloves, proper clothing, goggles or face shields when eye contact may occur and the use of NIOSH approved respirators when appropriate. Exposure to the environment would occur from line cleaning or washing. Domestic consumer product manufacturers likely employ the most effective manufacturing cost reduction and environmental programs, and will focus on limiting loss of the fragrance oil and other ingredients to the environment.

Page 18 SANITIZED SUBMISSIONA 50 0.25 200 Liquid chemical resistant gloves, safety glasses 2.5 0.125

1 none trace fugitive air, biofilter, water, POTM B 50 0.25 200 Liquid, powder, solid. Chemical resistant gloves, safety glasses 0.125 0.125

2 none trace fugative air, biofilter, water, POTW

Page 19 SANITIZED SUBMISSIONOn Site Treatment: all industrial wastewaters that exit the compounding facility (Hazlet, NJ) are pretreated via a permitted, Sequencing Batch

Reactor (SBR), waste activated sludge facility and then discharged to the local POTW. Off Site Treatment: the wastewater enters the POTW (Bayshore Regional Sewerage Authority (BRSA), NPDES# NJ0024708), a 16 million gallon per day (MGD) capacity treatment facility. The typical daily flow through the BRSA facility is 8-10 MGD. The treated effluent from the POTW is combined with the wastewaters from other municipalities. This total flow is then managed and discharged through the Monmouth County Bayshore Outfall Authority into the Atlantic Ocean, approximately 2,000 feet offshore.

Page 20 SANITIZED SUBMISSION001 chemical structure chemcial structure -- PMN 09- 0536.jpg Pt.I, Sec.B, 1e. 1

002 IES reprot sanitized IES Report__PMN 14-9536 sanitized.pdf Pt.I, Sec.B, 1c. 2

003 MSDS for combined constituents MSDS_PMN 14-9536.pdf 8

004 compounding process Compounding Process_PMN 14- 9536.jpg Pt.2, Sec.A, 1d. 1

005 Operations in sites controlled by others Operation in sites controlled by others_PMN 14-9536.jpg Pt.2, Sec.B, 1a. 1

006 Analytical results for PMN 14-9536 Analytical Results_PMN 14- 9536.pdf Worksheet: Spectra 16

007 Physical-chemical properties Physico-Chemical Report_PMN 14-9536.pdf See continuation page. id: <P12007> 34

008 Report from E-FAST General evaluation E-FAST_General_PMN 9536_v2.pdf 19

009 Combined HRIPT reports for FRET 09-0536 and vehicle control FRET 09-0536_Combined HRIPT 30

010 KeratinoSens Assay Report 7560 keratinosens final report.pdf 38

011 Direct Peptide Reactivity Assay final report IFF_ 9320-101114_DPRA Sensitization Screen Final 15

012 in vitro chromosome aberration report 205292_504372_FRET 09- 33
013 Ames Study report 205292 _504369_FRET 09- 0536_WIL_Ames OECD 38

014 Ready Biodegradability Report Ready Biodegradability Report_OECDTG301D_PMN 14- 38

015 EpiSuite Results for PMN 14-9536 Episummary_CAS 1464989-16- See continuation page. id: <P12015> 3

016 ECOSAR Results for PMN 14-9536 ECOSAR_CAS 1464989-16- 9.pdf 2

017 ChemSTEER Results for PMN 14-9536 ChemSTEER CAS 1464989-16- 9.rtf.pdf 8

018 PBT Results for PMN 14-9536 PBT Profiler_PMN14-9536.pdf 2

019 Oncologic report for dermal exposure Oncologic Report_FRET 09- 1

020 Oncologic report for inhalation exposure Oncologic Report_FRET 09- 0536_Inhalation Exposure.pdf 1

021 Draft report for Acute Fish Toxicity test of FRET Draft Fish Acute Toxicity 25 

### X

Page 21 SANITIZED SUBMISSION

### (1)

022 E-Fast Down-the-Drain Summary E-FAST_Down the Drain_PMN 9536.pdf 2

023 E-Fast Bar Soap Summary E-FAST_cem Bar Soap_PMN 9536.pdf 2

024 E-Fast General Purpose Cleaner Summary E-FAST_cem General Purpose Cleaner_PMN 9536.pdf 3

025 E-Fast Laundry Detergent Summary E-FAST_cem Laundry Detergent_PMN 9536.pdf 3

026 Sustainable Futures Summary Document SF Summary Assessment_CAS 1464989-16-9 & 1467039-69- 14

Page 22 SANITIZED SUBMISSIONP12007 List of Attachments, Associated PMN Section No., ID: 007

Worksheet: Vapor Pressure | Worksheet: Solubility In Water | Worksheet: Melting temp | Worksheet: Octanol / water partition coefficient

Page 23 SANITIZED SUBMISSIONP12015 List of Attachments, Associated PMN Section No., ID: 015

Worksheet: Boiling / sublimation temp | Worksheet: Henrys Law Const | Worksheet: Adsorption / Coefficient

Page 24 SANITIZED SUBMISSION

### X 007 

### X 1.4E-2 Measured 25

007 

### X 0.0134 Measured 20

007 

### X -82 Measured

015 

### X 269.89 Estimate 

### X 006 Measured



### X 007 3.9 - 4.8 Measured 

### X 015 1.169E-4 Estimate



### X 015 2.591 Estimate

Page 25 SANITIZED SUBMISSION

### ATTACHMENT HEADER SHEET

Attachment Number 001
Attachment Name chemical structure


### Associated PMN Section Number

Pt.I, Sec.B, 1e.

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 002
Attachment Name IES reprot sanitized


### Associated PMN Section Number

Pt.I, Sec.B, 1c.

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 003
Attachment Name MSDS for combined constituents


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 004
Attachment Name compounding process


### Associated PMN Section Number

Pt.2, Sec.A, 1d.

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 005
Attachment Name Operations in sites controlled by others


### Associated PMN Section Number

Pt.2, Sec.B, 1a.

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 006
Attachment Name Analytical results for PMN 14-9536


### Associated PMN Section Number

Worksheet: Spectra

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 007
Attachment Name Physical-chemical properties


### Associated PMN Section Number Worksheet: Vapor Pressure | Worksheet: Solubility In Water | Worksheet: Melting temp | Worksheet: Octanol / water partition coefficient

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 008
Attachment Name Report from E-FAST General evaluation


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 009
Attachment Name Combined HRIPT reports for FRET 09-0536 and vehicle control



### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 010
Attachment Name KeratinoSens Assay Report


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 011
Attachment Name Direct Peptide Reactivity Assay final report


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 012
Attachment Name in vitro chromosome aberration report


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 013
Attachment Name Ames Study report


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 014
Attachment Name Ready Biodegradability Report


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 015
Attachment Name EpiSuite Results for PMN 14-9536


### Associated PMN Section Number Worksheet: Boiling / sublimation temp | Worksheet: Henrys Law Const | Worksheet: Adsorption / Coefficient

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 016
Attachment Name ECOSAR Results for PMN 14-9536


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 017
Attachment Name ChemSTEER Results for PMN 14-9536


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 018
Attachment Name PBT Results for PMN 14-9536


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 019
Attachment Name Oncologic report for dermal exposure


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 020
Attachment Name Oncologic report for inhalation exposure


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 021
Attachment Name Draft report for Acute Fish Toxicity test of FRET 09-0536


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 022
Attachment Name E-Fast Down-the-Drain Summary


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 023
Attachment Name E-Fast Bar Soap Summary


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 024
Attachment Name E-Fast General Purpose Cleaner Summary


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 025
Attachment Name E-Fast Laundry Detergent Summary


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651

### ATTACHMENT HEADER SHEET

Attachment Number 026
Attachment Name Sustainable Futures Summary Document


### Associated PMN Section Number

N/A

Does not contain CBI 

### Report Number FRET141223133822651