Q359. If the landfill accepts only incinerator ash (inert) and does not generate gas, should we consider reporting the quantities of ash?

A359. See the definition of an MSW landfill in the rule. If the landfill has only accepted incinerator ash, it would not meet the definition of an MSW landfill as this waste would not generally be considered ‘household waste.’ Furthermore, if a landfill receives only inert wastes, even if the wastes are considered household wastes, the MSW landfill facility would not be expected to exceed the reporting threshold in the rule. If an MSW landfill (required to report under subpart HH) receives a segregated inert waste stream (such as incinerator ash), this waste quantity is considered to be included in Equation HH-1 and the quantity of inert waste would need to be reported as required in §98.346(a).