{"operation":"document","citation":"CPF 12026045WL","title":"GOLDEN TRIANGLE STORAGE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-04-08","effective_on":null,"summary":"CLOSED warning letter citing 192.12(a)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026045wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026045wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026045wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026045WL","body":"Warning Letter involving GOLDEN TRIANGLE STORAGE, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(a)(3). The case was opened on 2026-04-08 and is reported as closed as of 2026-04-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026045WL_Operator Response to Notice_05082026_(25-330068).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026045WL/12026045WL_Operator%20Response%20to%20Notice_05082026_(25-330068).pdf\n\n12026045WL_Warning Letter_04082026_(25-330068).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026045WL/12026045WL_Warning%20Letter_04082026_(25-330068).pdf\n\n12026045WL_Warning Letter_04082026_(25-330068)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026045WL/12026045WL_Warning%20Letter_04082026_(25-330068)_text.pdf\n\n12026045WL_Warning Letter_04082026_(25-330068)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\n609.771.7800\nWARNING LETTER\nVIA EMAIL TO: drm@calichestorage.com\nApril 8, 2026\nDave Marchese, CEO\nGolden Triangle Storage, LLC\n919 Milam Street, Suite 2425\nHouston, TX 77002\nCPF 1-2026-045-WL\nDear Mr. Marchese:\nOn November 16, 2025, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), Eastern Region, pursuant to Chapter\n601 of 49 United States Code (U.S.C.), inspected Golden Triangle Storage, LLC’s (GTS or\nRespondent) Underground Natural Gas Storage Facility (UNGSF) in Houston, Texas.\nAs a result of the inspection, it is alleged that GTS has committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR) Part 192. The item\ninspected and the probable violation is:\n1. § 192.12 Underground natural gas storage facilities.\nUnderground natural gas storage facilities (UNGSFs), as defined in § 192.3, are not\nsubject to any requirements of this part aside from this section.\n(a) Salt cavern UNGSFs.\n(1) …\n(3) Each UNGSF that uses a solution-mined salt cavern for natural\ngas storage and was constructed on or before July 18, 2017, must meet\nthe provisions of API RP 1170 (incorporated by reference, see § 192.7),\nsections 9, 10, and 11, and paragraph (c) of this section, by January 18,\n2018, and must meet all provisions of section 8 of API RP 1171\n(incorporated by reference, see § 192.7) that are applicable to the\nphysical characteristics and operations of a solution-mined salt cavern\nUNGSF, and paragraph (d) of this section, by March 13, 2021.\n\n\n\nGTS failed to meet all provisions of section 8 in API RP 1171 that are applicable to the physical\ncharacteristics and operations of a solution-mined salt cavern UNGSF for its UNGSF that uses a\nsolution-mined salt cavern for natural gas storage and was constructed on or before July 18, 2017,\nin accordance with section 192.12(a)(3). Specifically, GTS failed to assess threat and hazard\ninteraction in accordance with API RP 1171 section 8.3.2.\nSection 8.3.2 in API RP 1171 required the operator to use available information to assess threat\nand hazard interaction. During the inspection, PHMSA reviewed GTS’s Cavern Integrity and Risk\nManagement Plan (October 2025) (Risk Management Plan). Section 4.1.1 in the Risk\nManagement Plan stated that GTS uses available information to assess threat and hazard\ninteraction. However, during the record review, GTS’s Risk Assessment Model lacked any threat\nand hazard interaction assessment. In addition, GTS noted that it failed to meet this requirement\nin the Cavern Annual Risk Assessment Form completed on November 10, 2025, which stated, \"it\nis understood that the model employed does not perform an interactive threat analysis that would\nfurther characterize facility and operational risk.\"\nTherefore, GTS failed to meet all provisions of section 8 in API RP 1171 that are applicable to the\nphysical characteristics and operations of a solution-mined salt cavern UNGSF for its UNGSF that\nuses a solution-mined salt cavern for natural gas storage and was constructed on or before July 18,\n2017, in accordance with section 192.12(a)(3).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, Respondent is subject to a civil penalty not to\nexceed $272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for\na related series of violations. For violations occurring on or after December 28, 2023 and before\nDecember 30, 2024 the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violations\noccurring on or after January 6, 2023 and before December 28, 2023 the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violations occurring on or after March 21, 2022 and before\nJanuary 6, 2023 the maximum penalty may not exceed $239,142 per violation per day the violation\npersists, up to a maximum of $2,391,142 for a related series of violations. For violations occurring\non or after May 3, 2021 and before March 21, 2022 the maximum penalty may not exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related\nseries of violations. For violations occurring on or after January 11, 2021 and before May 3, 2021\nthe maximum penalty may not exceed $222,504 per violation per day the violation persists, up to\na maximum of $2,225,034 for a related series of violations. For violations occurring on or after\nJuly 31, 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 Respondent to correct the item identified in this letter. Failure to do so will result\nin Golden Triangle Storage, LLC being subject to additional enforcement action.\n2\n\n\n\nNo reply to this letter is required. If Respondent chooses to reply, in Respondent’s correspondence\nplease refer to CPF 1-2026-045-WL. Be advised that all material Respondent submits in response\nto this enforcement action is subject to being made publicly available. If Respondent believes that\nany portion of its responsive material qualifies for confidential treatment under 5 U.S.C. § 552(b),\nalong with the complete original document, Respondent must provide a second copy of the\ndocument with the portions it believes qualify for confidential treatment redacted and an\nexplanation of why Respondent believes the redacted information qualifies for confidential\ntreatment under 5 U.S.C. § 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Darrell Hall, VP of Operations, GTS, dhall@calichestorage.com\nAfton Sterling, VP of Regulatory, Environmental, Health & Safety, GTS,\nasterling@calichestorage.com\n3","truncated":false,"body_characters":7226}