Respondent has a chemical and allied product merchant wholesalers process at the Facility, meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. 35. Respondent is a wholesale chemical distributor that primarily repackages, stores, and distributes industrial chemical raw materials and allied products. Hydrochloric acid (36%) is an extremely hazardous substance within the meaning of Section 112(r)(1) of the Act, due to its toxic and corrosive characteristics and propensity to volatilize in ambient air. From the time Respondent first produced, processed, handled, or stored EHS/listed substance at the Facility, Respondent was subject to the requirements of the General Duty Clause in Section 112(r)(1) of the CAA.