The Social Costs of Closed-Cycle Cooling

According to the proposed rule, “the Director may reject an otherwise available technology as BTA standards for entrainment mortality if the social costs of compliance are not justified by the social benefits… ((§125.98(e) p. 22,288).”  Regardless of whether the facility could afford to install cooling towers or would prematurely retire rather than retrofit, prop­erly identifying and quantifying the social costs of cool­ing towers will play a compelling role in strategic com­pliance that goes beyond the results of a ledger-based comparison of engineering costs and fishery benefits.  This presentation describes the difference between engineering costs and social costs and considers important social costs that may accompany closed cycle cooling conversion requirements.  These include the social costs of both shutdowns and conversions.  For both cases, important social costs considered include system-level efficiency and air pollution impacts as well as those arising from the loss of winter fisheries and flushing flows.  For shutdowns, additional social costs covered include asset loss, reliability impacts, and local economic impacts.  For conversions, additional social costs covered include unit efficiency/capacity reductions and system level air pollution impacts that result from them.  These also include important social costs of the towers themselves such as viewshed impacts to property values.