Are on-site areas with unrestricted access considered public receptors?
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. If a stationary source has a baseball field on site to which non-employees have unrestricted access, does that field constitute a "public receptor"?
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." Areas within a facility boundary are considered "offsite" if the public has routine and unrestricted access during or outside normal business hours (40 CFR §68.3). A baseball field to which the public has unrestricted access is therefore considered to be a public receptor if people using the field could be exposed to toxic concentrations, radiant heat, or overpressure as a result of an accidental release.