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

party submissionOfficial PDF12026025NOA_Operator Response to Notice_03122026_(25-340130).pdf#

12026025NOA_Notice of Amendment_02132026_(25-340130)_text.pdf, page 1Official PDFU.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.#

12026025NOA_Notice of Amendment_02132026_(25-340130)_text.pdf, page 2CPF 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#

12026025NOA_Notice of Amendment_02132026_(25-340130)_text.pdf, page 3CPF 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, page 1Official PDFU.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#