A process covered under 40 CFR Part 68 is eligible for Program 1 requirements if it meets all of the criteria listed at 40 CFR §68.10(b). One of those criteria is that the distance to a toxic or flammable endpoint for a worst-case release assessment is less than the distance to any public receptor. Are roads covered as "public receptors?"
No. Public receptor is defined at 40 CFR §68.3 to include "offsite residences, institutions (e.g., schools, hospitals), industrial, commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at any time without restriction by the stationary source where members of the public could be exposed to toxic concentrations, radiant heat, or overpressure, as a result of an accidental release." Roads are not included as public receptors.
Another criterion for Program 1 eligibility, however, is the requirement that emergency response procedures have been coordinated between the stationary source and local emergency planning and response organizations (40 CFR §68.10(b(3)). Although roads surrounding a stationary source need not be addressed as public receptors, they should be considered when coordinating with emergency planners and responders.