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able economic cost. This draft Amendment, by prohibiting certain 
options and being overrestrictive with others, makes a realistic 
consideration of disposal options impossible. 
Proper balancing of criteria should be used in selecting the best 
disposal option for a particular waste. Unreasonable restrictions 
on available disposal options often result in both higher costs and 
risks. It also is contrary to common sense, and not a socially or 
economically acceptable route, to environmental regulation. As tech- 
nology improves and more information is available, the optimal dis- 
posal method may change. However, to force selection of waste dis-— 
posal options without due consideration and balancing of pertinent 
criteria is overly restrictive, unreasonable, and may result in 
unacceptably high risk to human health. 
ADDITIONAL IMPLICATIONS 
The bill includes language which indicates an increased awareness of 
the complexity of determining environmental impacts. However, this 
awareness did not extend to the difficulty in making the assessments 
that the new provisions would require. The Administrator of EPA may 
designate sites only after an analysis of environmental effects 
resulting from dumping and the Administrator must now specifically 
investigate the assimilative capacity of the waters at the dumpsite: 
",.othe ability of the waters at the site to disperse, detoxify or 
Neutralize the materials and sustain a normal ecosystem..." 
[Subsection 102(c)(1)], as well as other site-specific 
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