Q508. Could EPA clarify that the natural gas stored in high pressure steel bottles at peak-shaving stations should NOT be considered an underground natural gas storage facility under Subpart W?

A508. High pressure steel bottles that store natural gas at peak-shaving stations without any subsurface storage per 40 CFR 98.230(a)(5) would not be considered underground natural gas storage under Subpart W.  However, if the high pressure steel bottles are located at an underground storage facility per 40 CFR 98.230(a)(5) then the equipment leak sources listed in 40 CFR 98.232(f)(5) would be subject to reporting.