Relating to notification procedures concerning groundwater contamination.

Contracts

• Vendor MSAs: Update indemnification clauses with contractors handling hazardous materials. Indemnity must now cover reputational damages and crisis management costs, not just physical cleanup, as a contractor's spill will trigger state-sponsored public alarms.
• M&A Due Diligence: Purchase agreements for industrial sites must account for "One-Mile Risk." Buyers must assess not just the cost of remediation, but the liability of a mandatory neighborhood notification upon deal closure if TCEQ obtains "new" knowledge of legacy issues.

Hiring/Training

• Crisis Management: Environmental Health & Safety (EHS) and Public Relations teams must run joint tabletop exercises simulating a "Notice Event."
• Community Liaison: Designate a specific point of contact to handle inquiries from residents. Do not rely on general counsel to field angry neighbor calls; use a trained communications specialist.

Reporting & Record-Keeping

• GIS Mapping: Create and maintain an internal GIS layer identifying all residential addresses within one mile of your facility's boundary. You must know the recipient list *before* the TCEQ mails the notices.
• Timeline Tracking: Rigorously document the exact timestamp of any contamination report submitted to TCEQ. The 30-day clock for public notification begins immediately upon their receipt of this data.

Fees & Costs

• Insurance Premiums: Expect upward pressure on Pollution Legal Liability (PLL) premiums.
• Defense Costs: Budget for increased third-party claims. The state's notification acts as a de facto "class assembly" mechanism for plaintiff attorneys.