Q358. If we have an MSW landfill with other types of landfills (e.g., a C&D portion) at our facility, do we have to count those other non-MSW landfill portions towards our methane generation?

A358. “MSW landfill means an entire disposal facility in a contiguous geographical space where household waste is placed in or on land. An MSW landfill may also receive other types of RCRA Subtitle D wastes (40 CFR 257.2) such as commercial solid waste, nonhazardous sludge, conditionally exempt small quantity generator waste, and industrial solid waste. Portions of an MSW landfill may be separated by access roads, public roadways, or other public right-of-ways. An MSW landfill may be publicly or privately owned”. Unless these “other types of landfills” are considered completely separate landfill facilities that receive absolutely no household waste, then these “other types of landfills” cannot be excluded from the various requirements of the rule.