Southern California Edison Company

23 PARKER STREET

IRVINE, CALIFORNIA 92718

F. R. NANDY April 24, 1991 TELEPHONE MANAGER, NUCLEAR LICENSING (714) 454-4504

U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Dear Sir or Madam:

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: Department of Health & Human Services "Notice to All DHHS/NIDA Certified Laboratories" dated December 19, 1990

This letter is to inform the NRC of a change to the substances screened in the confirmatory analysis testing phase of the San Onofre Fitness For Duty Program and a clarification of the cut-off levels for initial Barbiturate tests.

The confirmatory analysis and reporting requirements for Metham phetamine were changed by the Department of Health and Human Services (DHHS) and the National Institute on Drug Abuse (NIDA) effective December 21, 1990 by the above Reference. To report a Methamphetamine positive result (i.e., confirmation test result at a concentration equal to or greater than 500 ng/ml) the specimen must also contain the metabolite of Methamphetamine, AMPHETAMINE, (determined by Gas Chromatography/Mass Spectrometry analysis) at a concentration equal to or greater than 200 ng/ml. If this criterion is not met, the specimen must be reported negative for Methamphetamine.

The enclosed table also shows an apparent reduction in five of the six initial test cut-off levels for Barbiturates. However, we have not changed the San Onofre test procedure or instructions to the laboratory. This apparent reduction in initial test cut-off levels-is due to using Secobarbital as a reference standard for detecting Barbiturates as a class of drugs. The initial test will be positive when Secobarbital is greater than or equal to 300 ng/ml. This initial test is also positive for Amobarbital, Butabarbital, Butalbital, Pentobarbital, Phenobarbital, and Talbutal at concentrations ranging from

9105030357 910424 PDR ADOCK 05000206 P DPDR Document Control Desk 2

1000 to 3000 ng/ml. However, the initial test cut-off level for Secobarbital has been and remains 300 ng/ml. The enclosure has been simplified to show only the 300 ng/ml cut-off level for Barbiturates to avoid further confusion. Finally, Talbutal has been added to the test panel because it is detected when using Secobarbital as the reference standard. Therefore, a replacement table of the initial and confirmatory test panels is enclosed with the changes discussed above identified with a bar in the margin. This table replaces the initial test panel and cut-off level table submitted to the NRC by our January 3, 1990 letter and the confirmatory test panel and cut-off level table submitted to the NRC by our September 24, 1990 letter.

If you have any questions or would like additional information on this subject, please let me know.

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

SAN ONOFRE SUBSTANCE SCREENING INITIAL AND CONFIRMATION TEST CUT-OFF LEVELS (NG/ML)

ANALYTE INITIAL 'CONFIRMATION TEST TEST

AMPHETAMINES Amphetamine 1000 500 Methamphetamine and 1000 500 Amphetamine * 200

BARBITURATES 300 200 Amobarbital Butabarbital Butalbital Pentobarbital Secobarbital Phenobarbital Talbutal

MARIJUANA METABOLITE ** 50 10

COCAINE METABOLITE *** 300 150

OPIATES Morphine 300 300 Codeine 300 300

PHENCYCLIDINE 25 25

BENZODIAZEPINE 300 300

METHADONE 300 200

PROPOXYPHENE 300 200

ALCOHOL 0.04% BAC 0.04% BAC

* Amphetamine is the metabolite of Methamphetamine. ** Delta-9-tetrahydrocannabinol-9-carboxylic acid. *** Benzoylecgonine.