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APPENDIX X

APPENDIX X

It is also important to place the NBS contribution to the national safeguards research and development program in proper context. Certainly continued NBS participation in the national effort is highly desirable. Its loss as a source of national standards, which are used as the basis for special nuclear material (SNM) measurements, would require that an alternate and less acceptable source be established to meet national and international needs. We desire a continued NBS role and, in fact, by an October 29, 1979, letter to NBS (enclosed) indicated our interest in not only continuing support through FY 1981 but, also, our willingness to increase funding in light of NRC's election to terminate support. In spite of this valid and useful role, GAO should properly state in the report that NBS is but one of several DOE-funded organizations involved in the development of standards, measurement techniques, and other methods for assuring that SNM is adequately safeguarded. Regarding the evaluative methodology work, a number of national laboratories and private contractors have been working to develop such facility evaluation tools for a number of years. The GAO should, thus, exercise caution in describing the effect on the Nation's safeguards programs associated with a reduction in NBS funding.

In the first paragraph on page 9, it is stated that "the NBS program has not been funded as planned" and "the expected annual funding level of $2.5 million has not been realized". The report notes fiscal year 1979 and 1980 funding shortfalls in an aggregate sense. OSS feels it would be helpful to indicate such shortfalls by sponsoring agency, which we believe will give a clearer picture of our support. As presently stated, it appears that all funding agencies have reneged on the 1977 agreement. Such has not been the case with respect to DOE.

The last sentence on page 9 indicates that "several activities which have been identified as key elements of nuclear safeguards have received no funding at all". There is no indication of what these activities might be or how they were identified as "key elements of nuclear safeguards". It would be appropriate to clarify and substantiate this statement.

In summary, we strongly support the NBS role in the Nation's safeguards research and development effort and recognize its numerous, valuable contributions. However, this effort must be viewed in the context of the entire breadth and scope of ongoing safeguards research and development activities. For objectivity, unnecessarily strong statements about the significance of this role should be avoided.

Sincerely,

Amen

George Weisz
Director

Office of Safeguards and Security

GAO note: The page numbers referred to in this letter do not correspond with the page numbers in this report. Revisions as suggested have been made where appropriate.

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This is in reply to your letter of November 16, 1979, requesting comments on the draft report entitled "National Bureau of Standards Information For Use In Reauthorizing

Its Activities."

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We have reviewed the enclosed comments and believe they are responsive to the matters discussed in the report.

Sincerely,

Mary Bass

Mary P. Bass
Inspector General

Enclosure

APPENDIX XI

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APPENDIX XI

The

problems confronting NBS in carrying out its mission. revisions have been developed cooperatively by NBS and the Department.

Sincerely,

Green

Francis W. Wolek

Acting Assistant Secretary for Science and Technology

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Attachments

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20548

Thank you for the opportunity to review and comment on a draft
General Accounting Office report entitled, "National Bureau of
Standards Information for Use in Reauthorizing Its Activities."
The report focuses on several important issues of concern to the
Senate Committee on Science, Commerce and Transportation and its
Subcommittee on Science, Technology and Space.

One such issue is the effects of the Administration's "lead agency"
policy on the programs of the National Bureau of Standards (NBS).
Since NBS is recognized as the central Federal agency for the
development of reference measurements, methodologies, and standards,
other Federal agencies often request NBS to develop, on a reimbursable
basis, the reference measurements, methodologies and standards
needed for their respective programs. The performance of work on
a reimbursable basis rather than through direct appropriations is the
very essence of the "lead agency" concept. One agency is given
fiscal and management control over all elements necessary to accomplish
a mission including that which needs to be performed by another
agency such as NBS. Although I endorse the need for and desirability
of the "lead agency" concept in principle, NBS does encounter
difficulties with its implementation. Agencies sponsoring work
at NBS sometimes alter their respective priorities causing the
funding for NBS to be reduced or terminated altogether. Additionally,
the magnitude of the level of support that one agency provides NBS
for a particular project is generally not sufficient to be treated
as a line item in that agency's budget request. Because of this,
budget personnel of other agencies, when formulating their budget
proposals are unaware that work NBS is performing for their agency
is an integral part of that agency's overall program. We are currently
working with the Office of Management and Budget in an effort to
resolve this problem.

Attached are recommended changes to the draft report. These changes will clarify what, I feel, are misunderstandings and inaccuracies. I believe the changes are necessary to more closely portray the

APPENDIX XI

APPENDIX XI

Recommended Changes to Draft GAO Report on National Bureau of Standards Information For Use in Reauthorizing its Activities

Page 3 paragraph 1 - Recommend that the paragraph be changed to
reflect the September 30, 1979 actual employment by
substituting "On September 30, 1979, the National Bureau
of Standards (NBS) had 3,120 full-time permanent
employees of which approximately 2,740 were at
Gaithersburg, Maryland and 380 at Boulder, Colorado.
The scientific staff including other than full-time
permanent employees consisted of:

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Page 6 paragraph 2 - Description of the lead agency concept
should more clearly indicate the Administration's intent
to provide the lead or mission agency the authority and
control over the resources and efforts for which it has
responsibility.

Page 7 last paragraph - Recommend substituting the following for
the last sentence of the paragraph. "As part of the OMB
decision to remove the funding from the NBS budget, NBS
understood that the Environmental Protection Agency (EPA)
was, in turn, directed to provide the necessary support, on
a reimbursable basis, for continuing NBS efforts in the
development of standard reference measurements, methodologies,
and materials needed by EPA to carry out its regulatory
responsibility and ensure the ability of industry to comply
with the regulations."

Page 8 paragraph 1 - Recommend substituting the following for the
first three sentences, "In assessing their needs, EPA
determined that some of the work at NBS needed to be
refocused to insure the development of measurement methods
that are of greatest urgency to meet EPA's regulatory
needs. This resulted in the expansion or initiation of
several efforts while others of lower priority to EPA
were terminated. However, EPA did not receive the
increases from the Congress that were requested by the
President in support of the NBS program.

Page 9 Nuclear Safeguards Program - It is important to point
out that this problem described in this section differs
from the other examples of lead agency implementation
problems. The Nuclear Regulatory Commission (NRC) and
others have for two years provided a significant level
of funding to the NBS program. The NRC now wants to
unilaterally terminate the agreement in violation of the
conditions of that agreement. It is also important to

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