# CENTRAL VALLEY GAS STORAGE (CVGS), LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 12026025NOA
- **title:** CENTRAL VALLEY GAS STORAGE (CVGS), LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2026-02-13
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.12(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026025noa.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026025noa.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026025noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12026025NOA
**body:**

Notice of Amendment involving CENTRAL VALLEY GAS STORAGE (CVGS), LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2026-02-13 and is reported as closed as of 2026-04-29. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12026025NOA_Closure Letter_04292026_(25-340130).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026025NOA/12026025NOA_Closure%20Letter_04292026_(25-340130).pdf

12026025NOA_Closure Letter_04292026_(25-340130)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026025NOA/12026025NOA_Closure%20Letter_04292026_(25-340130)_text.pdf

12026025NOA_Notice of Amendment_02132026_(25-340130).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026025NOA/12026025NOA_Notice%20of%20Amendment_02132026_(25-340130).pdf

12026025NOA_Notice of Amendment_02132026_(25-340130)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026025NOA/12026025NOA_Notice%20of%20Amendment_02132026_(25-340130)_text.pdf

12026025NOA_Operator Response to Notice_03122026_(25-340130).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026025NOA/12026025NOA_Operator%20Response%20to%20Notice_03122026_(25-340130).pdf

12026025NOA_Notice of Amendment_02132026_(25-340130)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, NJ 08628
609.771.7800
NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: drm@calichestorage.com
February 13, 2026
Dave Marchese
Chief Executive Officer
Caliche Development Partners, LLC
919 Milam Street, Suite 2425
Houston, TX 77002
CPF 1-2026-025-NOA
Dear Mr. Marchese:
From March 10 to 21, 2025, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted
an inspection of Central Valley Gas Storage LLC’s (CVGS) procedures in Colusa County,
California.
As a result of the inspection, PHMSA has identified an apparent inadequacy found within the
CVGS’s plans or procedures. The alleged inadequacy and proposed revision is described below:
1. § 192.12 Underground natural gas storage facilities.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness
and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator
must have written procedures in place before commencing operations
or beginning an activity not yet implemented.



CPF 1-2026-025-NOA
CVGS’s written procedures for conducting operations, maintenance, and emergency preparedness
and response activities were inadequate to ensure safe operation of a pipeline facility in accordance
with section 192.12(c). Specifically, CVGS’s Integrity and Risk Management Plan (12/30/24)
(I&R Plan) failed to include a requirement to review and update its operations and maintenance
procedures (manuals) at intervals not exceeding 15 months, but at least once each calendar year,
in accordance with section 192.12(c).
During the inspection, PHMSA reviewed the CVGS I&R Plan and determined that the procedures
failed to include requirements that CVGS operations and maintenance procedures be reviewed and
updated at intervals not exceeding 15 months, but at least once each calendar year, they instead
required annual reviews in section 5.1.2.
Therefore, CVGS’s written procedures for conducting operations, maintenance, and emergency
preparedness and response activities were inadequate to ensure safe operation of a pipeline facility
in accordance with section 192.12(c). PHMSA proposes that CVGS revise its procedures to
address the inadequacy noted above.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part
of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement
Proceedings.
Please refer to this document and note the response options. Be advised that all material you submit
in response to this enforcement action is subject to being made publicly available. If you believe
that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. §
552(b), along with the complete original document you must provide a second copy of the
document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment under
5 U.S.C. § 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under 49 CFR § 190.211. If you do not respond within 30
days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in
this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged
in this Notice without further notice to you and to issue an Order Directing Amendment. If your
plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend
your plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting
this Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Central Valley Gas Storage LLC maintain documentation of
the safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to the Director, Eastern Region,
Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety. In
Page 2 of 3



CPF 1-2026-025-NOA
correspondence concerning this matter, please refer to CPF 1-2026-025-NOA and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
Page 3 of 3

12026025NOA_Closure Letter_04292026_(25-340130)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, New Jersey 08628
609.771.7800
VIA ELECTRONIC MAIL TO: drm@calichestorage.com
April 29, 2026
Dave Marchese
Chief Executive Officer
Caliche Development Partners, LLC
919 Milam Street, Suite 2425
Houston, TX 77002
RE: CPF 1-2026-025-NOA
Dear Mr. Marchese:
From March 10 to 21, 2025, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) conducted
an inspection of Central Valley Gas Storage LLC’s (CVGS) procedures in Colusa County,
California. As a result of the inspection, PHMSA identified an apparent inadequacy found within
CVGS’s plans or procedures.
CVGS submitted its amended procedures on March 12, 2026. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
cc: Afton Sterling, Vice President of Regulatory, Environmental, Health & Safety,
asterling@calichestorage.com
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