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INTRODUCTION 
The Marine Protection, Research, and Sanctuaries Act (MPRSA) of 1972, 
as enacted, is "[A]n Act to regulate the transportation for dumping, 
and the dumping of materials into ocean waters..." The Act establishes 
a national policy that ocean dumping must be strictly regulated to ensure 
that such disposal activities would not adversely affect human health, 
the marine environment, or economic potentialities. In 1977 Congress 
amended the Act to require the EPA Administrator to deny permits for the 
ocean dumping of harmful sewage sludge after 31 December 1981 and, at the 
same time, defined such sludge as the waste material generated by a muni- 
cipal wastewater treatment plant, that when dumped into the ocean would 
"unreasonably degrade or endanger" human health, the marine environment, 
or economic potentialities. EPA was delegated the task of regulating 
ocean dumping and was further directed to establish and apply Ge ieeers 
for reviewing and evaluating ocean dumping permit applications to deter- 
mine whether such dumping would result in unreasonable degradation. 
EPA has rather strict criteria for evaluating permit applications and in 
designating acceptable locations for ocean dumping. As directed by the 
Act, these ocean dumping criteria include consideration of the "need" to 
ocean dump, which first and foremost involves consideration of the human 
health and environmental risks of land-based alternatives for waste 
disposal or recycling, as eine as the costs associated with such alterna- 
tives. Under the present regulatory framework, unreasonable degradation 
can only be determined after consideration of all available waste dis- 
posal mediums, including the ocean. An optimal mode of disposal can 
