# GOLDEN TRIANGLE STORAGE, LLC — Warning Letter

- **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:** Not available
- **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.

Official case documents:

12026045WL_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

12026045WL_Warning Letter_04082026_(25-330068).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026045WL/12026045WL_Warning%20Letter_04082026_(25-330068).pdf

12026045WL_Warning Letter_04082026_(25-330068)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026045WL/12026045WL_Warning%20Letter_04082026_(25-330068)_text.pdf

12026045WL_Warning Letter_04082026_(25-330068)_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
WARNING LETTER
VIA EMAIL TO: drm@calichestorage.com
April 8, 2026
Dave Marchese, CEO
Golden Triangle Storage, LLC
919 Milam Street, Suite 2425
Houston, TX 77002
CPF 1-2026-045-WL
Dear Mr. Marchese:
On November 16, 2025, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), Eastern Region, pursuant to Chapter
601 of 49 United States Code (U.S.C.), inspected Golden Triangle Storage, LLC’s (GTS or
Respondent) Underground Natural Gas Storage Facility (UNGSF) in Houston, Texas.
As a result of the inspection, it is alleged that GTS has committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR) Part 192. The item
inspected and the probable violation is:
1. § 192.12 Underground natural gas storage facilities.
Underground natural gas storage facilities (UNGSFs), as defined in § 192.3, are not
subject to any requirements of this part aside from this section.
(a) Salt cavern UNGSFs.
(1) …
(3) Each UNGSF that uses a solution-mined salt cavern for natural
gas storage and was constructed on or before July 18, 2017, must meet
the provisions of API RP 1170 (incorporated by reference, see § 192.7),
sections 9, 10, and 11, and paragraph (c) of this section, by January 18,
2018, and must meet all provisions of section 8 of API RP 1171
(incorporated by reference, see § 192.7) that are applicable to the
physical characteristics and operations of a solution-mined salt cavern
UNGSF, and paragraph (d) of this section, by March 13, 2021.



GTS failed to meet all provisions of section 8 in API RP 1171 that are applicable to the physical
characteristics and operations of a solution-mined salt cavern UNGSF for its UNGSF that uses a
solution-mined salt cavern for natural gas storage and was constructed on or before July 18, 2017,
in accordance with section 192.12(a)(3). Specifically, GTS failed to assess threat and hazard
interaction in accordance with API RP 1171 section 8.3.2.
Section 8.3.2 in API RP 1171 required the operator to use available information to assess threat
and hazard interaction. During the inspection, PHMSA reviewed GTS’s Cavern Integrity and Risk
Management Plan (October 2025) (Risk Management Plan). Section 4.1.1 in the Risk
Management Plan stated that GTS uses available information to assess threat and hazard
interaction. However, during the record review, GTS’s Risk Assessment Model lacked any threat
and hazard interaction assessment. In addition, GTS noted that it failed to meet this requirement
in the Cavern Annual Risk Assessment Form completed on November 10, 2025, which stated, "it
is understood that the model employed does not perform an interactive threat analysis that would
further characterize facility and operational risk."
Therefore, GTS failed to meet all provisions of section 8 in API RP 1171 that are applicable to the
physical characteristics and operations of a solution-mined salt cavern UNGSF for its UNGSF that
uses a solution-mined salt cavern for natural gas storage and was constructed on or before July 18,
2017, in accordance with section 192.12(a)(3).
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, Respondent is subject to a civil penalty not to
exceed $272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for
a related series of violations. For violations occurring on or after December 28, 2023 and before
December 30, 2024 the maximum penalty may not exceed $266,015 per violation per day the
violation persists, up to a maximum of $2,660,135 for a related series of violations. For violations
occurring on or after January 6, 2023 and before December 28, 2023 the maximum penalty may
not exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627
for a related series of violations. For violations occurring on or after March 21, 2022 and before
January 6, 2023 the maximum penalty may not exceed $239,142 per violation per day the violation
persists, up to a maximum of $2,391,142 for a related series of violations. For violations occurring
on or after May 3, 2021 and before March 21, 2022 the maximum penalty may not exceed
$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related
series of violations. For violations occurring on or after January 11, 2021 and before May 3, 2021
the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to
a maximum of $2,225,034 for a related series of violations. For violations occurring on or after
July 31, 2019 and before January 11, 2021 the maximum penalty may not exceed $218,647 per
violation per day the violation persists, up to a maximum of $2,186,465 for a related series of
violations.
We have reviewed the circumstances and supporting documents involved in this case and have
decided not to conduct additional enforcement action or penalty assessment proceedings at this
time. We advise Respondent to correct the item identified in this letter. Failure to do so will result
in Golden Triangle Storage, LLC being subject to additional enforcement action.
2



No reply to this letter is required. If Respondent chooses to reply, in Respondent’s correspondence
please refer to CPF 1-2026-045-WL. Be advised that all material Respondent submits in response
to this enforcement action is subject to being made publicly available. If Respondent believes that
any portion of its responsive material qualifies for confidential treatment under 5 U.S.C. § 552(b),
along with the complete original document, Respondent must provide a second copy of the
document with the portions it believes qualify for confidential treatment redacted and an
explanation of why Respondent believes the redacted information qualifies for confidential
treatment under 5 U.S.C. § 552(b).
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Darrell Hall, VP of Operations, GTS, dhall@calichestorage.com
Afton Sterling, VP of Regulatory, Environmental, Health & Safety, GTS,
asterling@calichestorage.com
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