Executive Board 

President 

HARRY PRICE 

Fairfield-Suisun Sewer District 

Secretary-Treasurer 

TOM SELFRIDGE 

Truckee Sanitary District 

1st Vice President 

RONALD E. YOUNG 

Elsinore Valley Municipal 

Water District 

2nd Vice President 

WYATT TROXEL 

Inland Empire Utilities Agency 

KAMIL S. AZOURY 

Goleta Sanitary District 

GARY DARLING 

Delta Diablo Sanitation District 

MICHAEL DUNBAR 

South Coast Water District 

JEFFERY G. HANSEN 

Dublin San Ramon 

Services District 

JOHN E. HOAGLAND 

Rancho California Water District 

BARBARA HOCKETT 

Central Contra Costa 

Sanitary District 

STEVE HOGG 

City of Fresno 

.TACKlE KEPKE 

CH2M Hill 

DA VID WILLIAMS 

East Bay Municipal Utility District 

CATHERINE SMITH 

Executive Director 

MICHAEL F. DILLON 

Lobbyist 

GREG KESTER 

Biosolids Program Manager 

ROBERTA LARSON 

Director of Legal and 

Regulatory Affairs 

ERIC SAPIRSTEIN 

Federal Legislative Advocate 

CALIFORNIA ASSOCIATION of SANI TION AGENCIES 

1215 K Street, Suite 2290· Sacramento, CA 95814' TEL: (916) 446-0388 - FAX: (916) 231-2141 • www.casaweb.org 

February 2, 2009 

Attention Docket ID No. EPA-HQ-RCRA-2008-0329 

Submitted via email to: rcra-docket@eRa.gov 

Regarding the United States Environmental Protection Agency's "Advanced Notice of Proposed 

Rulemaking" (ANPRM) -Identification of Non-Hazardous Materials that Are Solid Waste 

To Whom It May Concern: 

The California Association of Sanitation Agencies (CASA) is pleased to provide comments on the 

advanced notice of proposed rulemaking for the Identification of Non-Hazardous Materials that 

are Solid Waste. CAS A represents more than 90% of the sewered population of California and has 

been a proactive leader on wastewater, recycled water, and biosolids issues for years. 

As a general comment, CASA agrees with the Agency's concept of promoting the use of secondary 

fuels for energy production and as a replacement for primary fuel. Specific comments include the 

following: 

Section V.A.2. & 3. Sewage sludge should be excluded from the definition ofsolid waste because it 

meets the criteria of this section as an alternative fuel that has not been previously discarded, and 

as a legitimate alternative fuel. Increasingly in California and elsewhere, sewage sludge is being 

treated in Class A thermal drying systems and other processes for the purpose of primary fuel 

replacement in the cement and other industries. This classifies it as a legitimate recycled fuel 

source. Such biosolids may also be recycled as a fertilizer or soil amendment. Similarly sewage 

sludge incinerators should remain excluded from the definition of solid waste since they can 

recover heat and energy from their combustion, have not been discarded, and are a legitimate 

alternative fuel. Further the current definition of Solid Waste under RCRA should continue its 

exclusion of " ..... but does not include solid or dissolved material in domestic sewage, ...... subject to 

permits under section 402 of the Federal Water Pollution Control Act, ... ". Consequently, it is highly 

recommended that sewage sludge incinerators remain regulated as they are under 40 CFR part 

503. 

Section VI. D. Anaerobic digestion at wastewater treatment plants is commonly used to reduce 

solids mass, kill pathogenic organisms, provide stabilization, and to produce methane. The 

methane is commonly used to power stationary combustion engines, fuel cells, and/or 

microturbines. FOG and other organic material are often introduced into such digesters to increase 

the gas production. The methane generated should be considered as renewable fuel. 

Please feel free to contact me with any questions or for further clarification. 

Sincerely, 

Greg Kester 

Biosolids Program Manager 

gkester@casaweb.orE Tel: (916) 844-5262 

Ensuring Clean Water for California