ML13322B079

Certifies That Util Implemented fitness-for-duty Program at Plant Which Meets Requirements of 10CFR26.List of Util Substance Screening & 10CFR26 & Initial cut-off Levels Encl

ML13322B079
Person / Time
Site:	San Onofre
Issue date:	01/03/1990
From:	Rosenblum R Southern California Edison Co
To:	NRC/IRM
References
NUDOCS 9001110012
Download: ML13322B079 (4)

Text

Southern California Edison Company 23 PARKER STREET IRVINE, CALIFORNIA 92718 R.M.ROSENBLUM January 3, 1990 TELEPHONE MANAGER OF (714) 587-5420 NUCLEAR REGULATORY AFFAIRS U. S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C.

20555

Subject:

Docket Nos. 50-206, 50-361 and 50-362 Fitness-For-Duty Programs, 10 CFR 26 San Onofre Nuclear Generating Station Units 1, 2 and 3

Reference:

Final Rule Fitness-For-Duty Programs, 10 CFR 26.73(d)

This letter provides 1) certification that Southern California Edison (SCE) has implemented a fitness-for-duty program at San Onofre which meets the requirements of 10 CFR Part 26 and 2) a listing of substances and cut-off levels more stringent than required by 10 CFR 26.

This certification and list of substances/cut-off levels are required by 10 CFR 26.73(d).

SCE has had a drug testing program, including an employee assistance program, in place at San Onofre since September 1984. During 1989 relatively minor changes were made to the SCE program to bring it into full compliance with 10 CFR 26.

Full compliance with 10 CFR 26 was verified by SCE through an independent audit which was completed on December 20, 1989. The only item identified for clarification from the independent audit was compliance with 10 CFR 26.23.

10 CFR 26.23 is satisfied by SCE's policy that all contractors and vendors who perform work within the scope of 10 CFR 26 at San Onofre fall completely within SCE's fitness for duty program. In addition, for those contractors and vendors currently performing work within the scope of 10 CFR 26 at San Onofre, notifications were sent which informed them of changes in SCE's fitness for duty program. For those with which SCE has a contract, contract changes incorporating 10 CFR 26.23 requirements were initiated which require written acceptance. Written acceptances of these contract changes are expected by the end of February 1990.

The testing program includes screening for all substances required by 10 CFR 26 Appendix A (Guidelines For Nuclear Power Plant Drug And Alcohol Testing Programs), Section 2.1 and several additional substances. Further, the cut-off levels used to determine a positive test result for screened 9001110012 900103 i

PER ADOCK 05000206 F'

PDC

Bocument Control Desk January 3, 1990 substances for both initial and confirmatory tests meet or are more stringent than required by Sections 2.7(e) and (f) of the NRC guideline. Enclosures 1 and 2 provide a listing of substances screened by the San Onofre fitness-for duty program and a comparison to the 10 CFR 26 cut-off levels for initial and confirmation tests, respectively.

If you have any questions or need additional information on the San Onofre fitness-for-duty program, please let me know.

Very truly yours, Enclosures cc:

J. B. Martin, Regional Administrator, NRC Region V C. Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3

ENCLOSURE 1 SONGS SUBSTANCE SCREENING AND 10 CFR 26 CUT-OFF LEVELS INITIAL TEST CUT-OFF LEVELS (NG/ML)

ANALYTE SONGS 10 CFR 26 AMPHETAMINES 1,000 1,000 BARBITURATES Amobarbital 2,000 N/A Butabarbital 1,000 N/A Butalbital 3,000 N/A Pentobarbital 1,000 N/A Secobarbital 300 N/A Phenobarbital 3,000 N/A MARIJUANA METABOLITES 50 100 COCAINE METABOLITES 300 300 OPIATES METABOLITES 300 300 PHENCYCLIDINE 25 25 BENZODIAZEPINE 300 N/A METHADONE 300 N/A METHAQUALONE 300 N/A PROPOXYPHENE 300 N/A ALCOHOL 0.04% BAC 0.04% BAC

ENCLOSURE 2 SONGS SUBSTANCE SCREENING AND 10 CFR 26 CUT-OFF LEVELS CONFIRMATION TEST CUT-OFF LEVELS (NG/ML)

ANALYTE SONGS 10 CFR 26 AMPHETAMINES Amphetamine 500 500 Methamphetamine 500 500 BARBITURATES Amobarbital 200 N/A Butabarbital 200 N/A Butalbital 200 N/A Pentobarbital 200 N/A Secobarbital 200 N/A Phenobarbital 200 N/A MARIJUANA METABOLITE*

10 15 COCAINE METABOLITE**

150 150 OPIATES Morphine 150 300 Codeine 150 300 PHENCYCLIDINE 25 25 BENZODIAZEPINE 300 N/A METHADONE 200 N/A METHAQUALONE 200 N/A PROPOXYPHENE 200 N/A ALCOHOL 0.04% BAC 0.04% BAC

• Delta-9-tetrahydrocannabinol-9-carboxylic acid.

Benzoylecgonine.