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Chapter b SLUDGE AND ASH §2523(c) and (d)of the "Discharges of Waste to Land"regulations in Subchapter 15 indicate that dewatered sewage and water treatment sludges and incinerator ashes "may W discharged to a Class III landfill if the Department of Health Services determines that the waste need not be managed as 'hazardous waste and,for sludges,if certain moisture controlling conditions are met in the landfill This wording appears to preclude the classification of these wastes as 'designated wastes'. However,legal staff of the State Water Resources Control Board has stated that Regional Boards may classify these wastes as 'designated' if they determine that it is necessary to protect water quality 32 Concurrence is found in§2510(a) of Subchapter 15, which states: "Requirements of this subchapter are minimum standards for proper management of each waste category. Regional boards may impose more stringent requirements to accommodate regional and site-specific conditions." Concurrence is also found in recent correspondence from the Executive Office of the State Water Resources Control Board,which states: - "...the Regional Boards may, on a case-by-case basis,determine that certain nonhazardous sewage sludges must be discharged to a Class II landfill. Such sludges must meet the criteria of a designated waste as stated in Section 2522(a) of the regulations on waste discharge to land." A memorandum from the Executive Director of State Board to the Regional Board Executive Officer04 states "Until we more thoroughly understand what occurs in waste management units as a — -result of.;:ongoing studies and-monitoring—we should o6�n—dFu to allow disposal of - _ municipal wastewater-sludge in those Class III waste management units-where problems=- S are not evident or evidence does not exist that a particular problem is likely to occur. Exceptions must be justified on the basis of specific technical evaluations of the site and the waste in accordance with the present language of Subchapter 15." The Designated Level Methodology can provide this technical waste-and site-specific evaluation. Where the evaluation indicates that waste constituents have the potential to -t- --------cause-water-quality degradation,-non-hazardous ashes-and sludges should-be classified as - - 'designated wastes' As explained in Chapter 3 of this report, the classification would apply specifically to a particular waste and a particular site. Thus,not all sludges and ashes are expected to be classified as 'designated waste's' under this methodology and what is classified as 'designated' may not be so classified at a different disposal site that is more protective of water quality. As shown in Chapter 7 below,disposal in a Class I or Class II L unit is not the only option for the discharge of a sludge or ash waste that is classified as 'designated'. • Designated Level Methodology Page 43