{"operation":"document","citation":"CPF 12026026WL","title":"CENTRAL VALLEY GAS STORAGE (CVGS), LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-02-13","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(1), 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026026wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026026wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026026wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026026WL","body":"Warning Letter involving CENTRAL VALLEY GAS STORAGE (CVGS), LLC. PHMSA's enforcement data identifies the cited regulations as 192.12(b)(1),  192.12(c). The case was opened on 2026-02-13 and is reported as closed as of 2026-02-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026026WL_Operator Response to Notice_03122026_(25-340130).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026026WL/12026026WL_Operator%20Response%20to%20Notice_03122026_(25-340130).pdf\n\n12026026WL_Warning Letter_02132026_(25-340130).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026026WL/12026026WL_Warning%20Letter_02132026_(25-340130).pdf\n\n12026026WL_Warning Letter_02132026_(25-340130)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026026WL/12026026WL_Warning%20Letter_02132026_(25-340130)_text.pdf\n\n12026026WL_Warning Letter_02132026_(25-340130)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\n609.771.7800\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: drm@calichestorage.com\nFebruary 13, 2026\nDave Marchese\nChief Executive Officer\nCaliche Development Partners, LLC\n919 Milam Street, Suite 2425\nHouston, TX 77002\nCPF 1-2026-026-WL\nDear Mr. Marchese:\nFrom March 10 to 21, 2025, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted\nan inspection of Central Valley Gas Storage LLC’s (CVGS) procedures in Colusa County,\nCalifornia.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\nCVGS failed to review and update its manuals of written procedures for conducting operations,\nmaintenance, and emergency preparedness and response activities at intervals not exceeding 15\n\n\n\nCPF 1-2026-026-WL\nmonths, but at least once each calendar year in accordance with section 192.12(c). Specifically,\nCVGS failed to review and update its procedure Management of Change (05/10/2021) (MOC\nProcedure) in 2022, 2023, and 2024.\n2. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed after July\n18, 2017, must meet all provisions of API RP 1171 (incorporated by\nreference, see § 192.7), and paragraphs (c) and (d) of this section, prior\nto commencing operations.\nCVGS failed to meet all provisions of API RP 1171 in accordance with section 192.12(b)(1).\nSpecifically, CVGS failed to revise its program documentation, framework, and procedures before\nchanges were implemented and failed to notify and train operating personnel before operating\nwells and reservoirs in accordance with sections 11.11.1 and 11.12.2, respectively.\nSection 11.11.1 states, in part, that “[r]evision of procedures and processes is an acceptable\npractice, but the operator shall require changes to be accomplished in a controlled manner. The\nprogram documentation, framework, and procedures shall be revised before the change can be\nimplemented.”\nSection 11.12.2 states, in part, that “[w]henever changes are made to the operating procedures\nspecified in 11.3, operating personnel shall be notified and trained as necessary in the changes and\ntraining documented before operating storage wells and reservoirs.”\nDuring the inspection, PHMSA reviewed Central Valley Gas Storage record Snubbing Workover\nProcedure, V1.4.1.4 (08/22/2024) (Snubbing Workover Procedure), which was a snubbing\nworkover procedure for well 1L and the associated Management of Change Form #2024-1L-3\n(08/22/2024) (MOCF). The MOCF has the description of change as “Remove X nipple from\nplanned 1-L completion. Change is required to enable retrieval of TRB plugs from below the\nplanned location of the X nipple.” MOCF, Section D (Safety & Health Review and Approval) and\nSection G (Final Request for Change Approval by Director or Designee) are both dated August\n23, 2024, meaning these reviews occurred after the Snubbing Workover Procedure was finalized.\nHowever, MOCF, Section B (Action Items with the boxes checked for “Operating Procedure\nChanges” and “Notification/Training of Employees Required (and Contactors if Applicable)”) are\nboth dated September 12, 2024. These dates indicate that the Notification/Training of Employees\nRequired (and Contractors if Applicable) was completed after work on the well began on August\n23, 2024.\nTherefore, CVGS failed to meet all provisions of API RP 1171 in accordance with section\n192.12(b)(1).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related\nPage 2 of 3\n\n\n\nCPF 1-2026-026-WL\nseries of violations. For violation occurring on or after December 28, 2023 and before December\n30, 2024, the maximum penalty may not exceed $266,015 per violation per day the violation\npersists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring\non or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023,\nthe maximum penalty may not exceed $239,142 per violation per day the violation persists, up to\na maximum of $2,391,142 for a related series of violations. For violation occurring on or after\nMay 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per\nviolation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July\n31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so may result in\nCentral Valley Gas Storage LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2026-026-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nPage 3 of 3","truncated":false,"body_characters":8407}