Northeastern Shaped Wire draws and rolls various compounds to create wires. An October 2, 2012 inspection and information submitted by Respondent thereafter revealed that Respondent violated Section 112(r)(1) of the Clean Air Act (the General Duty Clause )by failing to conduct a process hazard analysis ( PHA ) to identify and assess hazards arising from the Facility's use, storage, and handling of anhydrous ammonia. The order requires Respondent to conduct a PHA to identify ad assess those hazards.