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Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) February 26, 2026 Water NPDES Stormwater/CWA 402 Company Name(s): Facility Name: Facility Physical Location: (city, state, zip code) Mailing address (1): (city, state, zip code) Mailing address (2): (city, state, zip code) County/Parish: Facility Phone Number Facility Contact 1: Facility Contact 2: Facility Contact 3: The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing Southeast Corner Phase 1 - Kroger 651 Southeast Corner of Rosamond Parkway and US Highway 75 Anna, TX 75409 The Ridgemont Company: 1520 West Walnut Hill Lane Irving, TX 75038 Kroger Texas L.P.: 751 Freeport Parkway Coppell, TX 75019 Collin 817-366-9400 Brian Kirby General Superintendent (The Ridgemont Company) bkirby@ridgemont.com, 817-366-9400 Craig Winkler Dallas Regional Construction Manager (Kroger) craig.winkler@kroger.com, 281-905-4275 Mike Wofford Environmental Services Manager (Cardinal Strategies) mike.wofford@cardinalstrategies.com, 972-679-5721 FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110071959579, 110071961723 TXR1573UZ, TXR1597UX N/A 445110, 452319 5411, 5331 Personnel participating in inspection: Destinee Agwuna ECADWA Kamilah Hutchinson ECADWA Brian Kirby The Ridgemont Company Inspector Inspector General Superintendent EPA Lead Inspector Signature/Date DESTINEE AGWUNA Date: 2026.04.02 10:18:16 -05'00' Digitally signed by DESTINEE AGWUNA Destinee Agwuna Date Supervisor Signature/Date ANTHONY LOSTON Anthony Loston Digitally signed by ANTHONY LOSTON Date: 2026.04.10 08:54:44 -05'00' Date 6ENFORM-019-R9 (02/27/2025) 1 Section I - INTRODUCTION The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 PURPOSE OF THE INSPECTION U.S. EPA Region 6 inspectors Destinee Agwuna and Kamilah Hutchinson arrived at Rosamond Crossing Southeast Corner Phase 1 - Kroger 651 (herein after referred to as "Kroger" or "site") in Anna, TX on February 26, 2026, at approximately 11:45 AM for an announced Compliance Evaluation Inspection (CEI). Upon arrival, the inspectors met Brian Kirby (General Superintendent) of The Ridgemont Company at the construction trailer to conduct an opening conference. Both inspectors presented their credentials to Mr. Kirby and informed him that a random stormwater inspection was being performed to determine compliance with the Texas Pollutant Discharge Elimination System (TPDES) program and the Construction General Permit (CGP), in accordance with the Clean Water Act (CWA). After discussing the purpose and procedures for the inspection, Mr. Kirby accompanied the inspectors for the duration of the inspection. Before leaving the site, the EPA inspectors conducted a closing conference with Mr. Kirby informing him of the Areas of Concern (AOC) observed on-site (See Section III of this report). The Storm Water Pollution Prevention Plan (SWPPP) review was performed at a later date and its associated AOCs were discussed by email with the operators (The Ridgemont Company and Kroger Texas L.P.) as detailed in Section III and IV of this report. The generation of this report is based on information supplied by The Ridgemont Company and Kroger Texas L.P. representatives (the permittees), observations made by the inspectors, and records and reports maintained by the permittees, the state of Texas, and the U.S. EPA. FACILITY DESCRIPTION Kroger is a commercial construction site co-owned by Kroger Texas L.P. (primary operator, TCEQ Permit # TXR1597UX) and SGI Anna SEC - I, LLC (secondary operator). Kroger Texas L.P.'s responsibilities include implementing and managing the site's SWPPP program, hiring and overseeing Cardinal Strategies (environmental consultants) who perform the site's stormwater inspections, and performing their own monthly inspections of the site to ensure SWPPP compliance. The Ridgemont Company (primary operator, TCEQ Permit # TXR1573UZ) is the general contractor responsible for day-to-day construction activities, best management practices (BMP) installation and maintenance, corrections of deficient BMPs, and ensuring subcontractors are adhering to the SWPPP through project completion. Both primary operators are discussed in this report since they both actively contribute to managing and implementing the site's SWPPP. Kroger is located at the southeast corner of Rosamond Parkway and US Highway 75 in Anna, TX (denoted in Aerial Image 1 below) with coordinates in the vicinity of Latitude 3321'43.9" North, Longitude 9634'51.2" West. The project site totals 36.55 acres and discharges into Throckmorton Creek in the City of Anna's Municipal Separate Storm Sewer System (MS4). 2 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 Aerial Image 1: The Kroger commercial construction site. The site is located within the approximate blue boundary lines depicted above. Section II - OBSERVATIONS The following points of discussion are derived from on-site visual observations on February 26, 2026: The site was in the land development phase of construction, consisting mostly of exposed sediment. Silt fence was installed along the eastern and southern perimeters of the site (Appendix 1, Photos 1-2). The silt fence along the northern perimeter of the site had recently been removed with the stakes still in place (Appendix 1, Photo 3). Mr. Kirby advised that they were grading and the silt fence would be re-installed by the following Friday (March 6, 2026). The western perimeter was stabilized by vegetation/sod, a rock/gravel construction entrance, and was sloped towards the interior of the site (Appendix 1, Photo 4). Rock check dams were observed along the western perimeter ditch (Appendix 1, Photo 5). Two (2) permanent sedimentation basins (ponds) were observed on-site. One sediment basin was located near the west perimeter of the property (Appendix 1, Photo 5) and receives water from the area drains (as the site progresses most inlets will tie into this pond). The second sediment basin was observed along the southeast perimeter (Appendix 1, Photo 6) of the site and primarily collects surface water. A material storage area, roll-off dumpster, street sweeper, two (2) fuel storage containers, and one (1) concrete washout was observed on-site (Appendix 1, Photos 7-8 and 10). Potential pollutants in the material storage area were mostly stored off the ground on pallets. There was no evidence of spillage or leakage near the fuel storage containers or the concrete washout area. 3 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 Inlet protection was observed on the inlets throughout the site (Appendix 1, Photo 11). Section III - AREAS OF CONCERN The following areas of concern are derived from on-site observations from the February 26, 2026, Compliance Evaluation Inspection (CEI): Site Conditions: 1. The Construction Site Notices (CSNs) were not posted on-site at the time of the inspection (Appendix 1, Photo 12). 2. Silt fence along the east perimeter of the site had sediment buildup (in excess of 50%), was not properly installed (not trenched), and was damaged with holes and tears in multiple areas (Appendix 1, Photos 1 and 13-14). 3. Sediment buildup (in excess of 50%) was observed along the southern perimeter silt fence near the southwest corner of the site (Appendix 1, Photo 2). 4. Slurry was observed discarded directly on the sediment where piers had recently been poured (Appendix 1, Photo 15). 5. KleenDef was stored directly on the ground near the fuel storage containment (near the northern perimeter of the site) and trash was discarded in a pile nearby (Appendix 1, Photos 8-9). Note: AOCs 1-5 were addressed by The Ridgemont Company on or around March 3, 2026, with photo evidence provided by Mr. Kirk as illustrated in Appendix 2 of this report. SWPPP Review: I performed a detailed off-site SWPPP review after receiving digital copies of the site's documentation by email on March 13, 2026. The following errors and missing information were identified: 6. Dates for major grading activities and BMP installation schedule were missing. 7. The permit number was listed incorrectly multiple times throughout the SWPPP. Note: AOCs 6-7 were addressed on March 25, 2026, when Mark Costilla of Kroger Texas L.P. emailed the missing documentation and illustrated that all necessary information was now included in the SWPPP. Section IV - FOLLOW UP The following information was received by the U.S. EPA after leaving the site on February 26, 2026: On March 3, 2026, Mr. Kirby emailed photos illustrating that AOCs 1-5 had been addressed (See Appendix 2). On March 10, 2026, I contacted Mr. Craig Winkler of Kroger Texas L.P. to determine if the SWPPP and associated documentation that he emailed me prior to the February 26, 2026, inspection was up-to-date. On March 13, 2026, Kyle Trzupek of Cardinal Strategies emailed me the up-to-date SWPPP for review. 4 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 On March 23, 2026, I contacted Mr. Craig, Mr. Costilla, Mr. Kirby, and Mr. Wofford by email requesting additional information regarding AOCs 6-7 in Section III of this report. On March 25, 2026, missing documentation was provided and errors corrected as illustrated through an updated SWPPP sent by Mr. Costilla via email. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 15 photos taken 2/26/2026 Appendix 2 - Corrected Deficiencies Photo Log - 8 pages of photos provided by The Ridgemont Company on 3/3/2026 5 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 Appendix 1 Photograph Log 6 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 1 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Holes/tears in SF Holes/tears in SF Description: Silt fence (SF) installed along the eastern perimeter of the site. The silt fence had holes/tears in multiple areas. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 7 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 2 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Silt fence installed along the southern perimeter of the site. Sediment buildup (in excess of 50%) was observed along the silt fence. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 8 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 3 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: The northern perimeter of the site. No silt fence is present and black stakes are still installed along the road. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 9 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 4 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: The western perimeter stabilized by vegetation/sod, a rock/gravel construction entrance, and sloped towards the interior of the site Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 10 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 5 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Rock check dams along the western perimeter ditch. Also pictured is a sediment basin (pond) that receives water from the site's area drains. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 11 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 6 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: The second sediment basin observed on-site near the southeast perimeter that primarily collects surface water. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 12 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 7 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Fuel storage tank Street sweeper Roll-off dumpster Drums on pallets Description: A material storage area, roll-off dumpster, street sweeper, and a double walled fuel storage container located east of the construction trailer. Potential pollutants (drums) were stored off the ground on pallets. There were no signs of spillage or leakage near the fuel storage tank. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 13 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 8 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: A second fuel storage container located near the north perimeter of the site with KleenDef stored on the ground directly next to it. No evidence of spillage/leakage was observed near the tank. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 14 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 9 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Blowable trash observed in a pile near the fuel storage container near the north perimeter of the site. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 15 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 10 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Concrete washout located east of the construction trailer. No evidence of leakage/spillage was observed. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 16 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 11 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Inlet protection installed around one of the interior inlets. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 17 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 12 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Missing CSNs near the construction entrance off of North Central Expressway. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 18 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 13 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Damaged/torn SF Damaged SF Description: Damaged silt fence (SF) with areas of sediment buildup (in excess of 50%) and holes/tears along the eastern perimeter of the site. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 19 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 14 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Untrenched SF Description: Improperly installed (not trenched) silt fence (SF) along the eastern perimeter of the site. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 20 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 15 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Slurry discarded directly onto the sediment where piers had recently been poured on-site. Date of Photo: 2/26/2026 Photographer: Destinee Agwuna 21 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 Appendix 2 Photograph Log: Corrected Items 22 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photo Log Photo no. 1 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Photo provided by Mr. Kirby illustrating that the CSNs had been posted and the area around the fuel containment had been cleaned. Photos Received: 3/3/2026 Photographer: The Ridgemont Company Representative 23 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photo Log Photo no. 2 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Photos provided by Mr. Kirby illustrating that the KleenDef containers had been moved and the area cleaned. Photos Received: 3/3/2026 Photographer: The Ridgemont Company Representative 24 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photo Log Photo no. 3 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Photos provided by Mr. Kirby illustrating that the drums/potential pollutants in the material storage area are being properly stored (off ground and covered). Photos Received: 3/3/2026 Photographer: The Ridgemont Company Representative 25 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photo Log Photo no. 4 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Photo provided by Mr. Kirby showing that the silt fence along the northern perimeter of the site has been re-installed. Photos Received: 3/3/2026 Photographer: The Ridgemont Company Representative 26 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photo Log Photo no. 5 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Additional photos provided by Mr. Kirby illustrating that the northern perimeter silt fence has been re-installed. Photos Received: 3/3/2026 Photographer: The Ridgemont Company Representative 27 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photo Log Photo no. 6 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Photos provided by Mr. Kirby illustrating that the eastern perimeter silt fence had been replaced. Photos Received: 3/3/2026 Photographer: The Ridgemont Company Representative 28 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photo Log Photo no. 7 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Photos provided by Mr. Kirby showing that the eastern perimeter silt fence and southern perimeter silt fence have been replaced and excess sediment buildup removed. Photos Received: 3/3/2026 Photographer: The Ridgemont Company Representative 29 The Ridgemont Company & Kroger Texas L.P. Rosamond Crossing SE Corner Phase 1 - Kroger 651 Permit #: TXR1573UZ, TXR1597UX Inspection Date: 2/26/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photo Log Photo no. 8 Location: Southeast Corner of Rosamond Parkway and US Highway 75 City: Anna County: Collin State: TX Description: Photos provided by Mr. Kirby showing that the sediment buildup along the southern perimeter silt fence has been removed and the slurry near where the piers were recently poured has been cleaned. Photos Received: 3/3/2026 Photographer: The Ridgemont Company Representative 30