We appreciate the opportunity to comment on the draft GAO report entitled "National Bureau of Standards--Information for Use in Reauthorizing its Activities." Our comments are enclosed.

The section of the GAO Draft Report that describes the funding status of the "Nuclear safeguards program' at the National Bureau of Standards is in basic agreement with NRC's understanding of the situation. We do find two paragraphs in the referenced section that require clarification with respect to NRC's position. On the second page of the referenced section, the third paragraph, beginning "According to NBS. NRC discontinued its funding because ....". needs correction and amplification. Specifically, the NRC does not maintain. as stated in the paragraph, that "its responsibility for research is limited to the area of developing future regulations ...." The NRC does maintain that a Regulatory Agency should not directly fund a program whose major effort supports the regulated industry. In addition, because the Bureau's program, supported by NRC requires a considerable amount of direct interaction with our licensees, a conflict of interest situation easily can arise. Because of these considerations. the Commission made the decision to discontinue funding the NBS program in FY-1981.

The Commission has indicated its intent to encourage users of the Bureau's program to provide the funds previously supplied by NRC. Contrary to the contents of the last paragraph in the referenced section of the subject report, the Commission does not anticipate that the Bureau's program will be terminated with the subsequent waste of the monies already invested. We anticipate, instead. that DOE and the nuclear industry will provide the resources needed to complete the work.

GAO note:

Ковет В. Женазик

12/3/79

Robert B. Minogue, Director
Office of Standards Development

Revisions as suggested have been made where
appropriate.

I appreciate the opportunity to comment on your draft report.
to the Senate Committee on Commerce, Technology, and Space
concerning reauthorization of the activities of the National
Bureau of Standards.

The National Bureau of Standards is a valuable technical
resource available to all Federal Agencies. It provides
expertise in physical science and measurement methodology,
as well as providing essential testing services. It is
unfortunate that the lead agency concept may have led to
discontinuities in NBS programs.

The lead agency concept is a good one and serves as a step
forward in Federal program management. It provides for a
balancing of national needs against limited resources and
helps reduce overlap and unnecessary duplication of efforts.
More directly related to NBS, EPA has historically recognized
the value of NBS in the development of measurement methods
and will continue to coordinate our efforts with them.
Furthermore, we extend a great deal of joint. NBS-EPA effort
to assure tracebility of EPA methods to NBS standards. Our
experience in FY 79 has given EPA a heightened awareness of
NBS capabilities and we shall continue to consider and use
them as a source for our efforts to develop new, effective
measurement methods and systems.

However, there is an error in the GAO report as it relates to
EPA's Office of Monitoring and Technical Support program
with NBS. The third page of Chapter Two indicates that EPA
did not receive an increase in its FY 79 appropriation to
cover the NBS program. For FY 79, EPA received an additional

APPENDIX IX

APPENDIX IX

$1,000,000 in its appropriation for NBS work. An additional $700,000 in carry over funds were added to this New Obligational Authority to provide a total NBS program amounting to $1,700,000. In FY 80, EPA intends to provide $2,000,000 in New Obligational Authority to NBS to continue this effort. This money has

been earmarked for NBS from the begining of the FY 80 planning cycle.

I believe we have addressed the main issues of the GAO report.
on NBS reauthorization and we appreciate the opportunity
to provide such comments.

Sincerely yours,

William Drayton, Jr.
Assistant Administrator

for Planning and Management.

GAO note:

Revision as suggested has been made on p. 6 of

this report.

COMMENTS ON GAO DRAFT REPORT, "NATIONAL BUREAU OF STANDARDS--INFORMATION FOR USE IN REAUTHORIZING ITS ACTIVITIES--CHAPTER 2"

On December 4, 1979, Mr. Jay Stewart of my staff met with Mr. Jack Glick of your office to provide Department of Energy, Office of Safeguards and Security (OSS) comments regarding the subject GAO report. In that OSS had inadequate time to prepare a formal, written reply for the December 4 meeting, I would like to take this opportunity to provide the following comments for GAO consideration. These comments address only pages 8-10 of the report, "Nuclear Safeguards Program".

In general, it is not clear that reduced NBS funding would, in and of itself, seriously undermine national safeguards policies and programs. We believe, for example, that the top paragraph, page 10, overstates the impact of such a funding reduction on DOE's ability to safeguard nuclear materials. Specifically, the notion that a reduction of NBS program funding "can result in a dangerous flaw in the Nation's nuclear safeguards program" or that the safeguards decision-making process "will be based on the shaky foundation of unvalidated data" are examples of such overstate

ments.

While we agree conceptually that the "slowing of the NBS effort is negatively affecting the Nation's ability to accurately measure nuclear fuels", those effects are not as severe as suggested and most definitely not the central element to our current ability to provide effective protection against threats of theft or sabotage. Statements to such an effect do not place the role of a standards program in the proper perspective and do not take into account the other compensating elements of the overall, integrated nuclear safeguards and security program.