The benefits of performing a Human Health Risk Assessment (HHRA) are often underestimated or overlooked entirely when landowners or even potential landowners are making decisions regarding an appropriate path forward for their Site. Whether it’s during a Phase II Environmental Site Investigation (ESA) or through a Pennsylvania Department of Environmental Protection Agency (PADEP) Land Recycling Program (Act 2) Cleanup, HHRA’s can be a time- and cost-effective tool for ensuring that current and/or future receptors are protected from contaminated media.
When can an HHRA benefit your project?
- Has a soil boring investigation indicated that contamination exists within your property? Rather than implement burdensome institutional and engineering controls or perform a costly soil excavation, the performance of an HHRA may eliminate the need for these measures all together. Site-specific considerations employed in an HHRA (i.e., time spent on Site or child versus adult receptors) are oftentimes far less restrictive than the assumptions built into PADEP screening criteria. Application of realistic exposure assumptions may show that Site soil contamination does not result in adverse health effects to receptors, eliminating the need for remediation measures.
- Are you seeking an Act 2 Relief of Liability for a Site that also has potentially complete surface water and sediment exposure pathways? Although surface water and sediment may exist on your Site, the PADEP does not allow for relief of liability for these media without the performance of an HHRA to ensure the safety of receptors now and in the future. Assumptions built into a surface water and sediment HHRA evaluation are far less conservative than those for soil and groundwater, particularly when a Site exists within an urban area where the likelihood of recreational use is minimal to none. As surface water and sediment are also not amenable to remediation or off-Site disposal, an HHRA evaluation is critical in successfully bringing a project to close within the Act 2 program.
- Has the implementation of a soil cap been a primary means for addressing Site soil contamination? Performing an HHRA is typically overlooked as a cost-effective means for “remediating” a Site. Often a soil cap is recommended as a simple remedy for soil contamination, particularly when paved parking lots are already part of future Site development. The future ongoing cost and burden placed on property owners, however, far exceed those necessary to perform an HHRA upfront. The need for a Post-Remedial Care Plan that includes an Environmental Covenant, reporting requirements to the PADEP, and ongoing inspection costs to ensure the integrity of the cap can all be avoided with the evaluation of HHRA that eliminates the need for a cap in the first place.
Whether it’s for adequate data needs for incorporation into an HHRA or the need for an HHRA at all, Brickhouse Environmental’ s in-house Risk Assessment capabilities can assist early in the decision-making process to save both time and money throughout the lifespan of your project.