# CALNRG OPERATING, LLC — Warning Letter

- **operation:** document
- **citation:** CPF 52024005WL
- **title:** CALNRG OPERATING, LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-05-21
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.9(d)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-52024005wl.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-52024005wl.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-52024005wl
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/52024005WL
**body:**

Warning Letter involving CALNRG OPERATING, LLC. PHMSA's enforcement data identifies the cited regulation as 192.9(d)(2). The case was opened on 2024-05-21 and is reported as closed as of 2024-05-21. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

52024005WL_Warning Letter_05212024_(23-264044).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52024005WL/52024005WL_Warning%20Letter_05212024_(23-264044).pdf

52024005WL_Warning Letter_05212024_(23-264044)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52024005WL/52024005WL_Warning%20Letter_05212024_(23-264044)_text.pdf

52024005WL_Warning Letter_05212024_(23-264044)_text.pdf

WARNING LETTER
VIA ELECTRONIC MAIL TO: clif.simonson@calnrg.com
May 21, 2024
Mr. Clif Simonson
President/COO
California Natural Resources Group (CalNRG)
1746-F South Victoria Avenue #245
Ventura, CA 93003
CPF 5-2024-005-WL
Dear Mr. Simonson:
From November 13 through 17, 2023, representatives of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),
inspected the CalNRG Type B Gas Gathering (GG) inspection system located in Ventura
County, California.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected
and the probable violation is:
1. § 192.9 What requirements apply to gathering pipelines?
(a) . . . .
(d) Type B lines. An operator of a Type B regulated onshore gathering line must
comply with the following requirements:
(1) . . . .
(2) If the pipeline is metallic, control corrosion according to requirements of subpart
I of this part applicable to transmission lines, except the requirements in §§



192.461(f) through (i), 192.465(d) and (f), 192.473(c), 192.478, 192.485(c), and
192.493;
CalNRG failed to comply with all Type B gas-gathering metallic pipeline corrosion control
requirements pursuant to §192.9(d)(2).
Specifically, CalNRG failed to demonstrate adequate levels of cathodic protection (CP) as
required by §192.463(a). CalNRG did not collect instant-off (IR free) measurement data while
performing 2022 CP Annual Surveys on PL-8396-2, PL-8402, PL-8403, PL-8444, and PL-8540.
Additionally, the November 6, 2023 CP Annual Survey results for PL-8444 did not meet the
-0.85 V instant off (IR free) or any other Appendix D criteria.
Accordingly, CalNRG failed to demonstrate that each cathodic protection system provided a
level of cathodic protection that complies with one or more of the applicable criteria contained in
Appendix D of Part 192 as required by § 192.9(d)(2) & § 192.463(a).
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to 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 violation 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 violation
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 violation 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 violation
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 violation 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. For violation
occurring on or after November 27, 2018, and before July 31, 2019, the maximum penalty may
not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.
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 you to correct the item identified in this letter. Failure to do so will result in
California Natural Resources Group (CalNRG) being subject to additional enforcement action.



No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 5-2024-005-WL. 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).
Sincerely,
Dustin Hubbard
Director, Western Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 M. Mulligan, M. Flaherty (#23-264044)
Matt Pearson – CalNRG Facilities Manager, matt.pearson@calnrg.com
Sarah D’Avella – DOT Contractor, sarah@specterandcypress.com
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