Relating to the use of reclaimed water that has been treated to meet certain standards as part of an aquifer storage and recovery project.

Contracts

• Water Supply Agreements: If purchasing reclaimed water for injection, amend agreements to include strict "Quality Guarantees." Suppliers must indemnify you if delivered water fails to meet injection standards, causing aquifer contamination liability.
• Vendor MSAs: Update engineering and geoscience contracts to require design compliance specifically with SB2885 and forthcoming TCEQ standards, rather than general ASR guidelines.
• Insurance Policies: Review Pollution Legal Liability (PLL) policies. Standard policies often exclude intentional injection of waste-derived fluids. You must secure endorsements specifically covering ASR operations using reclaimed water.

Hiring/Training

• Technical Staffing: Internal teams or external consultants must include licensed geoscientists capable of modeling complex confinement to prove injected water will not migrate to unauthorized zones.
• Operator Certification: Wastewater treatment plant operators feeding ASR wells must be trained on *continuous* compliance monitoring. Unlike discharge permits which often allow for averages, injection permits may require real-time adherence to Maximum Contaminant Levels (MCLs).

Reporting & Record-Keeping

• Chain of Custody: Implement rigorous documentation protocols for water transfer points, especially if the source water originates from a third-party WWTP.
• Continuous Monitoring: Prepare for data retention requirements regarding injectate quality (turbidity, pathogens, chemical constituents) to prove the water met standards *at the specific moment of injection*.

Fees & Costs

• Capital Expenditures: While the regulatory cost is low, the operational cost is high. Budget for advanced treatment technologies (e.g., Reverse Osmosis) if TCEQ mandates drinking water standards pre-injection.
• Permitting Fees: Anticipate standard Class V injection well permit fees, plus costs associated with major amendments if modifying existing permits.