6
may require additional time. The material also incorporates
information on suggested uses for mercury in refining processes
such as amalgamating gold or recovering gold from ores. The
amount and the grade of mercury to be supplied determined the
prices quoted by petitioner. The document states that base
prices for mercury on the west coast were related to, but not
necessarily governed by, the New York and German markets' spot
price. In 1985, petitioner incorporated within his sales
material procedures for dealing with a mercury spill, along with
other general health and safety hazard information.
On January 16, 1985, in response to a complaint alleging the
illegal storage, disposal and transportation of hazardous waste,
DHS conducted an inspection of petitioner’s shop and work
premises. After several inspections, DHS alleged that petitioner
violated environmental regulations. DHS alleged that paints,
thinners, solvents, oils, mercury batteries, acids, and caustics
were haphazardly stored in and around a large barn which
comprised petitioner’s work area. Large amounts of toxic ash
generated by petitioner’s reclamation of mercury were allegedly
also found on site. DHS alleged that these quantities of "army
surplus salvage" were a threat to public health and the
environment. On December 30, 1987, DHS served petitioner with a
remedial action order (RAO). The RAO provided that petitioner
was to perform certain enumerated remedial actions, and failure
to comply would result in DHS commencing proceedings to clean up
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