Best Available Techniques (BAT)

efforts - the additional need for “vertical” alignment across the levels in Figure 1.6.

Decisions at higher levels should propagate down the hierarchy, whereas information about the current state of affairs should propagate up the hierarchy. These interdependencies across levels of the hierarchy are critical to the successful functioning of a system as a whole. Even if researchers do an excellent job at conducting horizontal research on a particular topic, they may have little impact on reducing risk unless vertical integration is also achieved.

Unfortunately, the holy grail of vertical integration is becoming more important yet more difficult to achieve. As shown on the right of Figure 1.6, the various layers of a complex socio-technical system are increasingly subjected to external disruptive forces. In today’s dynamic society, these external forces are stronger and change more frequently than ever before. When different levels of the system are being subjected to different pressures, each operating at different time scales, it is imperative that efforts to improve safety within a level be coordinated with the changing constraints imposed by other levels.

Rasmussen’s framework can be used to identify why accidents occur and it outlines a number of broad system design implications that can be adopted to reduce risk in complex socio-technical systems, thereby safeguarding the public and the environment.

1.6 Best Available Techniques (BAT)

The Environmental Protection Act 86/2000 [12] states that within industrial operations, where contamination of the environment is possible (as indeed it always is at petrol stations), Best Available Techniques (BAT) should be applied. According to this act [12] 43 §, the granting of environment permits must be based on BAT and according to the act [12] 9 §, the applicant must also demonstrate familiarity with the principles of BAT. In other words; an application must include an evaluation of how BAT will be applied in the circumstances for which the permit is being sought.

The Environmental Protection Act 86/2000 [12] 3 § defines BAT as follows:

“Best available technique refers to methods of production and treatment that are as efficient and advanced as possible and technologically and economically feasible, and to methods of designing, constructing, maintenance and operation with which the pollutive effect of activities can be prevented or most efficiently reduced.”

Further, the Environmental Protection Decree 169/2000 [13] stipulates that, when evaluating the contents of BAT according to Environmental Protection Act [12] 37 §, the following issues must be addressed:

- reduction of the quantity and harmful impact of waste,

- the hazard level of employed substances and the scope for using less hazardous alternatives,

- the scope for recovery and re-use of substances used and waste generated in production processes,

- the quality, quantity and impact of discharges,

- the quality and consumption of raw materials used,

- energy efficiency,

- prevention of operational risks and the risks of accident, and damage limitation in the event of an accident,

- the time needed for introducing the best available techniques and the importance of the planned time for launching operations, plus the costs and benefits of limiting and preventing discharges,

- all impacts on the environment,

- all the methods in use on an industrial scale for production and for controlling discharges,

- developments in technology and natural science and

- information on best available techniques published by the Commission of the European Communities or international bodies.

No BAT Reference Document (BREF) or national BAT-report has yet been drafted for petrol stations in Finland although BREF’s have been issued for oil refineries. At petrol station construction projects, BAT has to be applied according to the Environmental Protection Act [12]. BREF’s do not contain regulations or restrictions as such, but do include information on the technology used in the branch of the industry concerned, as well as levels of consumption and emissions.

As already mentioned, another sector of the oil industry, fuel storage, has come under the eye of the regulators. In November 2004, the European Integrated Pollution Prevention and Control Bureau (EIPPCB) produced the Final Draft Reference Document on Best Available Techniques on Emissions from Storage [18].

After approval by the European Commission it is scheduled to become the accepted BREF-document. However, despite the fact that petrol stations also form part of the oil industry, this BREF cannot be applied to petrol stations notwithstanding the technological comparability of these sectors of the oil industry.

Though BAT principles do not play a fundamental role in this study, their significance is that they provide a useful means for evaluating and comparing Finnish environmental protection levels. As already stated, according to Environmental Protection Act [12], BAT has been applied in all branches whenever an environment permit is being sought. From the list of recommendations presented above, taken from the Environmental Protection Decree [13], the following issues are the most relevant here for the application of BAT-principles:

- the quality, quantity and impact of discharges,

- prevention of operational risks and the risks of accident, and damage limitation in the event of an accident and

- overall impact on the environment.

For the purposes of the present study, BAT-principles are interpreted in environmental terms as meaning that a worse and/or more dangerous technical

solution should be always rejected whenever there exists a better alternative which is economically feasible. However, it is still the case that BAT-principles have no authority to enforce the use of any particular type of technology. This means that technological suitability is determined according to levels of consumption and releases. Furthermore, in evaluating BAT, factors such as local conditions, size of location and lifetime must also be taken into account. This may even require expensive solutions in certain special environmental circumstances.

In the opinion of the author, economic feasibility corresponds to a maximum of an additional 20 % of the total cost of the constructed petrol station. In practice, installation of 2-wall tanks instead of 1-wall tanks and equipping the petrol station with vapour recovery stage 2-system will only increase costs by 2-10 % depending on the size of the petrol station.