A GENTLEMAN named Paul L. Bloom turns out to be the philanthropist of the transition. Mr. Bloom, special counsel in the Department of Energy, directed that a $4 million settlement payment from Amoco Oil on an overcharge case be converted into four million-dollar checks. These, in turn, he sent, apparently without either the knowledge or approval of then-DOE secretary Charles A. Duncan, to four organizations that aid the "truly needy."

Understandably, Mr. Bloom's actions ruffled some feathers among Reagan officials, who have demanded the return of any unspent portion of the $4 million while disclaiming any desire to play the Sheriff of Nottingham to his Robin Hood by hauling back the entire amount. In his ecumenical and evenhanded slicing of the Amoco pie to the Salvation Army, the National Council of Churches, the National Conference of Catholic Charities and the Council of Jewish Federations, Mr. Bloom had stipulated that the bonanza be used "as restitution for poor people to pay their overcharged fuel bills." The Reagan budget-cutters remain sufficiently sensitive to allegations of callous behavior that they will surely refuse to launch any major effort to recover the whole amount.

In Mr. Bloom's favor, it seems evident that the motives behind this $4 million misunderstanding were benign and that his instincts were admirably generous. He acted, moreover, with a decisiveness not always characteristic of the bureaucracy: "It seemed to me," he said, "that it was time the Department of Energy did something to help those individuals . . . who were most needy."

It should be kept in mind, too, that outgoing presidents and officials have used post-election opportunities to shift personnel, policies and available funds at least since John Adams' lame duck decision to appoint a last-minute batch of "midnight judges."

What makes Mr. Bloom's action noteworthy, therefore, apart from its stunning benevolence, is something else. L'affaire Bloom has dramatized, however inadvertently, one of the Reagan presidential campaign's central themes -- its portrayal of a runaway federal bureaucracy supposedly out of control by elected officials and their appointees. For whether or not Mr. Bloom had the legal authority to allocate the specific funds does not address the underlying administrative question. Did not simple courtesy or common sense suggest to him the virtues of informing Secretary Duncan? Apparently not.In his defense, Mr. Bloom points out: "I did not ask the secretary's permission when I brought the charges against Amoco. I did not ask his permission when I settled the claims."

L'etat bureaucratique , in short, c'est moi .