246 
of a prudent and feasible alternative may be interpreted several 
ways. One interpretation would require only that an alternative 
exists and has an adverse environmental impact equal to or less 
than ocean dumping. This could disregard effects which directly 
impact human health and could certainly lead to the expenditure of 
millions of dollars with little, or no, positive environmental 
result. Also, on a alternative disposal method may exist, but may 
not be legal as a result of air quaility violations, RCRA conflicts 
or other laws. In such situations would ocean dumping be allowed or 
prohibited? 
The draft Amendment has added the consideration of: (1) bioaccumu- 
lation of unspecified constituents from "the effects of the dumping," 
(2) the composition and vulnerability of biological communities that 
"may be exposed to dumped materials," 
and (3) effects of dumping "in 
conjunction with all existing and projected pollutant sources on 
human health SEER marine environment." Consideration can no 
longer be given to the need to dump or the anticipated impacts of 
aternative disposal methods, therefore a meaningful balancing of 
factors will no longer be possible. 
Disposal of any material in the environment should be permitted only 
after using optimization or cost-effectiveness assessments to choose 
the disposal option with the Veastioveuels risk. The eventual solu- 
tion should have the optimum combination of highest Eocied accepta- 
bility, minimal human health and environmental risk, and most reason- 
11 
