Document oD9Dr8evmVKMOpgVbJb7x25Oo

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) January 22, 2026 & February 5, 2026 Water NPDES Stormwater/CWA 402 Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact 1: Facility Contact 2: Facility Contact 3: Meritage Homes of Texas, LLC Morgan Farms Phase 1 & 2 Northeast of W Hubbard Road & County Road 642 Josephine, TX 75164 8840 Cypress Waters Blvd Ste 100 Coppell, TX 75019 Collin 972-580-6300 Soham Rawal Land Development Manager soham.rawal@meritagehomes.com, 214-606-5990 Martin Goldstein Land Development Manager martin.goldstein@meritagehomes.com, 667-447-7245 Eric Ortiz Environmental Consultant (Stormcon, LLC) eric@stormcon.us FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A TXR1566SV N/A 237210 6552 Personnel participating in inspection: Destinee Agwuna EPA Region 6 ECADWA Paul Juarez EPA Region 6 ECADWA Soham Rawal Meritage Homes Daniel Hibbs Stormcon, LLC Jeff McKenzie Stormcon, LLC Inspector Inspector Land Development Manager Environmental Consultant/Inspector Environmental Consultant/Inspector EPA Lead Inspector Signature/Date DESTINEE AGWUNA Date: 2026.03.10 07:44:40 -05'00' Digitally signed by DESTINEE AGWUNA Destinee Agwuna Date Supervisor Signature/Date ANTHONY LOSTON Date: 2026.03.13 08:42:26 -05'00' Digitally signed by ANTHONY LOSTON Anthony Loston Date 6ENFORM-019-R9 (02/27/2025) 1 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 Section I - INTRODUCTION PURPOSE OF THE INSPECTION U.S. EPA Region 6 inspectors Destinee Agwuna and Paul Juarez arrived at Morgan Farms Phase 1 & 2 in Josephine, TX on January 22, 2026, at approximately 1:05 PM for an announced Compliance Evaluation Inspection (CEI). Paul contacted the Meritage Homes Dallas corporate office on January 21, 2026, and left a voicemail notifying the operator of our upcoming inspection. However, he was unable to speak with a site representative prior to the inspection to confirm receipt of the voicemail. On January 22, 2026, we inspected Phase 1 while attempting to locate a construction trailer or site representative but were unable to do so. As a result, we concluded the inspection after Phase 1 and I (Destinee) conducted additional research to identify a contact person for Meritage Homes of Texas, LLC (herein after referred to as "Meritage Homes") and Chris Harp Construction Limited Liability Company (hereinafter referred to as "Chris Harp Construction"), who was also listed as an operator on the site's Construction Site Notice (CSN) during the January 22, 2026 inspection. On February 4, 2026, I provided a 24-hour notice by email to both operators for a second inspection to be conducted on February 5, 2026. Please note that after gathering more information, it was determined that Meritage Homes is responsible for the installation and maintenance of the site's BMPs and therefore, this report will focus on TCEQ Permit Number TXR1566SV held by Meritage Homes (as opposed to TCEQ Permit Number TXR1514SV held by Chris Harp Construction). On February 5, 2026, Destinee Agwuna arrived at Morgan Farms Phase 1 & 2 at approximately 9:25 AM and met with site representatives Soham Rawal (Land Development Manager) of Meritage Homes and Daniel Hibbs and Jeff McKenzie (Environmental Consultants/Inspectors) of Stormcon, LLC to conduct an opening conference. I presented my credentials to the site representatives and informed them 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. Rawal, Mr. Hibbs, and Mr. Knight accompanied me for the duration of the inspection. The generation of this report is based on information supplied by Meritage Homes representatives (the permittee), observations made by the inspector, and records and reports maintained by the permittee, the state of Texas, and the U.S. EPA. FACILITY DESCRIPTION Morgan Farms Phase 1 & 2 is a residential construction site operated by Meritage Homes. The site is northeast of West Hubbard Road and County Road 642 in Josephine, Texas (denoted in Aerial Image 1 below) with coordinates in the vicinity of Latitude 3304'01.1" North, Longitude 9619'12.4" West. The project site totals 86.98 acres and discharges into Sabine Creek (Segment #0507) in the City of Josephine's Municipal Separate Storm Sewer System (MS4). 2 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 Aerial Image 1: The Morgan Farms Phase 1 and 2 residential construction site. The site is located within the approximate blue and green boundary lines depicted above (northeast of Hubbard Road and County Road 642 in Josephine, TX). Section II - OBSERVATIONS The following points of discussion are derived from on-site visual observations on January 22, 2026, and February 5, 2026: At the time of the inspections Phase 1 and Phase 2 were in different phases of construction. Phase 1 had streets paved and utilities were being installed (no vertical construction was observed). Phase 2 was undeveloped, consisting of sediment and vegetation. The BMPs observed in Phase 1 include rock check dams along Co Rd 642, inlet protection, and a retention pond with erosion control blankets stabilizing the slopes near the southwestern corner of the site. The BMPs observed in Phase 2 include silt fence along some sections of the northern perimeter of the site. The CSN was observed near the northern construction entrance off of Co Rd 642 (Appendix 1, Photos 1 and 4). The CSN listed both Meritage Homes (TCEQ Permit Number TXR1566SV) and Chris Harp Construction (TCEQ Permit Number TXR1514SX) as operators of the site (Appendix 1, Photo 1). The site SWPPP indicates that Meritage Homes is responsible for the installation and maintenance of BMPs. Multiple Areas of Concern (AOCs) were observed as described below in Section III of this report with photos included in Appendix 1. 3 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 Section III - AREAS OF CONCERN The following areas of concern are derived from on-site observations from the January 22, 2026, and February 5, 2026, Compliance Evaluation Inspections (CEI): Phase 1: 1. Sediment and construction materials/debris were observed in the ditch along Co Rd 642 (Appendix 1, Photo 2). 2. The rock check dams along Co Rd 642 were covered with soil on January 22, 2026 (Appendix 1, Photo 3). On February 5, 2026, the accumulated sediment was no longer present. 3. The lots throughout Phase 1 had no BMPs installed, resulting in a significant amount of exposed soil throughout the site (Appendix 1, Photos 4-11). Sediment was observed on the streets and off-site in the ditch (Appendix 1, Photos 2, 4-5, 7, and 10-11). 4. Large stockpiles were observed near the curbs throughout the site (Appendix 1, Photos 3 and 56). No BMPs were observed around or near the stockpiles to indicate that they are contained when not in use, at the end of each workday, or during rain events. 5. Inlet protection was observed on the curb inlets throughout Phase 1. However, sediment buildup was observed on multiple inlets throughout the site (Appendix 1, Photo 7). 6. Mortar/concrete washout was discarded directly on the soil in multiple areas throughout Phase 1 (Appendix 1, Photo 8-9). 7. Blowable trash was observed in multiple areas on January 22, 2026. The trash was no longer present during the February 5, 2026, inspection. Phase 2: 8. Mortar/concrete washout was discarded directly on the soil (Appendix 1, Photo 12) near the northeast corner of Phase 2. 9. An area at a steep slope with no BMPs was observed along the northern perimeter of Phase 2 (Appendix 1, Photos 13-14). 10. During the inspection Daniel Hibbs (Inspector of Stormcon, LLC) advised that Phase 2 is not being inspected because the area is considered temporarily stabilized. This information was confirmed upon reviewing the SWPPP. However, large areas of exposed sediment, including along the perimeters, were observed during the inspection (Appendix 1, Photos 12-16). In its current state, Phase 2 must be inspected routinely as required by the CGP to ensure that sediment and other pollutants are properly contained. Note: AOCs 2-3 and 5-9 were addressed by Meritage Homes and were either observed as corrected by the inspector or photo evidence was provided by the operator on February 19, 2026, as illustrated in Appendix 2 of this report. SWPPP/Documentation Review: I performed a detailed off-site SWPPP review after receiving digital copies of the site's documentation by email on February 6, 2026. The following information was missing from the SWPPP: Dates of major grading activities 4 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 Dates when construction temporarily ceased for Phase 2. Credentials for Andy Walker and Daniel Hibbs to perform stormwater inspections for the site. Note: The missing SWPPP documentation was provided by Eric Ortiz of Stormcon, LLC on February 25, 2026. Section IV - FOLLOW UP The following information was received by the U.S. EPA after leaving the site on February 5, 2026: On February 6, 2026, a digital copy of the SWPPP, including the site map and inspection reports were emailed by Eric Ortiz. On February 19, 2026, Martin Goldstein emailed a response to the AOCs discussed with Soham Rawal during the February 5, 2026, inspection. The email included photos and descriptions of the corrective actions taken by Meritage Homes (See photos in Appendix 2, Photos 1-5). On February 25, 2026, Eric Ortiz emailed the missing SWPPP documentation discussed in Section III of this report. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 16 photos taken on 1/22/2026 and 2/5/2026 Appendix 2 - Corrected Items Photograph Log - 5 pages of photos provide by Meritage Homes on 2/19/2026 5 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 Appendix 1 Photograph Log 6 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 1 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: The Construction Site Notice (CSN) posted near the northern entrance off of Co Rd 642. Meritage Homes (TXR1566SV) and Chris Harp Construction (TXR1514SX) are both listed as primary operators. Date of Photo: 1/22/2026 Photographer: Destinee Agwuna 7 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 2 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Construction Site Construction Materials/Debris Description: Sediment and construction materials/debris (black pipe) in the ditch along Co Rd 642. Date of Photo: 2/5/2026 Photographer: Destinee Agwuna 8 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 3 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: A rock check dam along Co Rd 642 covered in sediment on January 22, 2026. The rock check dam was cleaned by the February 5, 2026, inspection. Also note the large stockpile with no BMPs near the construction entrance in the background. Date of Photo: 1/22/2026 Photographer: Destinee Agwuna 9 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 4 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Photo taken from the northern construction entrance off of Co Rd 642. The lots and western perimeter of the site have no BMPs installed, resulting in a significant amount of exposed sediment. Sediment was observed on the paved areas and in the ditch along Co Rd 642. Date of Photo: 1/22/2026 Photographer: Destinee Agwuna 10 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 5 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Exposed sediment and stockpiles along the northern lots of Phase 1, resulting in sediment in the street. Date of Photo: 1/22/2026 Photographer: Destinee Agwuna 11 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 6 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Exposed sediment and stockpiles with no BMPs along the interior lots of Phase 1. Date of Photo: 2/5/2026 Photographer: Destinee Agwuna 12 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 7 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Inlet protection requiring maintenance due to sediment buildup. Also pictured is exposed sediment along the lots and sediment on the street in Phase 1. Date of Photo: 1/22/2026 Photographer: Destinee Agwuna 13 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 8 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Mortar/concrete washout discarded directly on a lot near the southern perimeter of Phase 1. Also pictured is exposed sediment along the lots and sediment in the street. Date of Photo: 1/22/2026 Photographer: Destinee Agwuna 14 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 9 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Slurry mix washout discarded directly on a lot near the construction entrance (northern entrance off Co Rd 642). Also pictured is exposed sediment along lots that slope towards the street. Date of Photo: 2/5/2026 Photographer: Destinee Agwuna 15 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 10 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Exposed sediment along the lots and soil on the street near the western perimeter of Phase 1. Date of Photo: 2/5/2026 Photographer: Destinee Agwuna 16 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 11 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Exposed sediment along the lots and sediment track-out on the street near the southern perimeter of Phase 1. Date of Photo: 2/5/2026 Photographer: Destinee Agwuna 17 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 12 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Mortar/concrete washout discarded in the sediment near the northeastern perimeter of Phase 2. Also pictured is the large quantity of exposed sediment in this area and damaged silt fence in the background. Date of Photo: 2/5/2026 Photographer: Destinee Agwuna 18 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 13 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: A steeply sloped area along the northern retaining wall in Phase 2 requiring BMPs to minimize potential sediment discharge during a rain event. Date of Photo: 2/5/2026 Photographer: Destinee Agwuna 19 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 14 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Another view of the steeply sloped area along the northern retaining wall in Phase 2 requiring BMPs to minimize potential sediment discharge during a rain event. Also pictured are a large stockpile and exposed sediment at the top of the slope. Date of Photo: 2/5/2026 Photographer: Destinee Agwuna 20 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 15 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Photo taken standing at the northern perimeter of Phase 2, facing south. Phase 2 consisted of large quantities of exposed sediment intermingled with vegetation. The area closest to the northern boundary line consisted of primarily exposed soil and therefore does not appear to meet the definition of stabilized. Phase 2 in its observed state requires routine inspections. Date of Photo: 2/5/2026 Photographer: Destinee Agwuna 21 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 1: Photograph Log Photo no. 16 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Photo taken at the northern boundary line of Phase 2, facing east. Large areas of exposed sediment run along the property line. Date of Photo: 2/5/2026 Photographer: Destinee Agwuna 22 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 Appendix 2 Photograph Log: Corrected Items 23 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photograph Log Photo no. 1 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Photo of the construction entrance off Co Rd 642. Photo Received: 2/19/2026 Photographer: Meritage Homes Representative 24 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photograph Log Photo no. 2 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Aerial drone image of the site, illustrating that curlex was installed along the lots. Also noted in the photo description is that perimeter controls have been refreshed, streets swept, and storm drains cleaned. Photo Received: 2/19/2026 Photographer: Meritage Homes Representative 25 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photograph Log Photo no. 3 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Photo of lots with BMPs installed and inlet protection in effective operating condition. Photo Received: 2/19/2026 Photographer: Meritage Homes Representative 26 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photograph Log Photo no. 4 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Photo of the mortar/concrete mix cleaned up in Phase 2. Photo Received: 2/19/2026 Photographer: Meritage Homes Representative 27 Meritage Homes of Texas, LLC / Morgan Farms Phase 1 & 2 Permit #: TXR1566SV Inspection Dates: 01/22/2026 & 2/5/2026 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Appendix 2: Corrected Items Photograph Log Photo no. 5 Location: Northeast of W Hubbard Road & County Road 642 City: Josephine County: Collin State: TX Description: Photo of BMPs installed along the steep slope in Phase 2. Photo Received: 2/19/2026 Photographer: Meritage Homes Representative 28