Q512. Does Subpart W require reporting of emissions during the salt dome mining process to create an underground natural gas storage facility or does reporting start only when natural gas is introduced for load balancing or storage?

A512. Under 98.230(a)(5) reporting is only required for “…salt dome caverns that store natural gas…” Methane emissions from building of a storage facility are not included in the reporting for subpart W.  Emissions reporting is required when the storage facility is operational.