Dear Commissioners,

Please DENY Application No. 9-19-0194 for the onshore portion of decommissioning of Units 2 and 3 at San Onofre Nuclear Generating Station. In light of serious, documented defects with its dry storage system, Southern California Edison must not be granted a permit to destroy its Spent Fuel Pools (SPF), as they are presently the only option for containing a damaged canister. According to the recent Nuclear Waste Technical Review Board (NWTRB) report from September, 2019, the existing canisters will likely need to be replaced. Without having a SPFs available on site, a "Hot Cell" would need to be constructed for the same purpose. Stranding the nuclear waste on the coast would be a direct violation of the terms upon which the California Coastal Commission approved the plans for the interim dry storage facility in 2015.

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