**BONNEVILLE POWER ADMINISTRATION**

HUMAN RESOURCES

**PORTLAND, OREGON**

**PERSONNEL LETTER NO. 731-1 (Revised) DATE: July 2, 2004**

**SUBJECT**: Suitability Determinations

**I. PURPOSE OF ISSUANCE**

> Combined with relevant law, regulations, and case law, this issuance
> governs BPA's policy and provides management delegations in
> administering BPA's Suitability program. Consistent with Delegation
> Order No. 00-033-00A, signed by the Secretary of Energy on September
> 27, 2002, this issuance also exempts BPA from the provision of any
> related Department of Energy issuance, including DOE Order 3731.1,
> Suitability, Position Sensitivity Designations and Related Personnel
> Matters**.**
>
> OPM maintains authority for material intentional false statements and
> adjudication for employees.

## II. PURPOSE OF REVISION

> This letter replaces Personnel Letter 731-1, dated July 20, 1998 and
> includes new regulations as established by 5 CFR 731 that were
> effective March 30, 2001.

**III. REFERENCES AND RELATED INFORMATION**

A.  [Regulations]{.underline}

> 1\. 5 CFR, Part 5, Regulations, Investigations and Enforcement (RuleV)
>
> 2\. 5 CFR, Part 213. Excepted Service
>
> 3\. 5 CFR, Part 307, Veterans Readjustment Appointments
>
> 4\. 5 CFR, Part 315, Career and Career-Conditional Appointment
>
> 5\. 5 CFR, Part 316, Temporary and Term Employment
>
> 6\. 5 CFR, Part 731, Suitability
>
> 7\. 5 CFR, Part 752, Adverse Actions
>
> B. [Related Information]{.underline}
>
> 1\. BPA Manual Chapter 400/700A, Employee Relations Program
>
> 2\. Personnel Letter 315-2, Probationary and Trial Periods for New
> Employees
>
> 3\. Personnel letter 316-1, Temporary Limited Appointments
>
> 4\. Personnel Letter 752-1, Discipline, Adverse Actions and
> Alternative Discipline
>
> 5\. Management Assistance Services (MAS) Handbook, Chapter 3, Dealing
> with Employee Conduct Problems through Disciplinary Action
>
> 6\. MAS Handbook, Chapter 9, Termination During Probationary Periods

**IV. DEFINITIONS**

> A. [Applicant]{.underline}: A person being considered for Federal
> employment.
>
> B. [Appointee]{.underline}: A person who has entered on duty (EOD) and
> is in the first year of a subject-to-investigation appointment.
>
> C. [Background Investigation (BI)]{.underline}: Primarily conducted
> for High-Risk Public Trust positions. Coverage includes a personal
> subject interview, 5-year check on employment, 5-year check on
> education and highest degree verification, 3-year residence check,
> 5-year law enforcement check, 5-year court records check, and 7-year
> credit check.
>
> D. [Classified Information]{.underline}: Any information that requires
> protection against unauthorized disclosure in the interests of the
> national defense and security or foreign relations of the United
> States pursuant to U. S. Statute or Executive Order.
>
> E. [Employee]{.underline}: A person who has completed the first year
> of a subject to investigation appointment.
>
> F. [Material intentional false statement]{.underline}: A false
> statement capable of influencing or having a natural tendency to
> affect an official decision.
>
> G. [Minimum Background Investigation]{.underline} (MBI): Conducted for
> Moderate Public Trust positions. Coverage includes Personal Subject
> interview, 5-year check on employment, 5-year check on education with
> highest degree verification, 3-year check on residences and check
> references listed on application, 5-year check on law enforcement, and
> 7-year check on credit history.
>
> H. [National Agency Check and Inquires (NACI)]{.underline}: Minimum
> investigation required for low risk positions. Coverage includes:
> 5-year check on employment, 5-year check on education with highest
> degree verification, 3-year check on residence, 5-year check on law
> enforcement, and references listed on application will be checked.
>
> I. [Position Sensitivity Code]{.underline}: A code, established by the
> Office of Personnel Management (OPM), that is the result of risk level
> and security level determinations. The position sensitivity code
> determines the type of security investigation required before
> individuals can be assigned to sensitive positions and granted the
> applicable clearance level. The codes are established by the Office of
> Personnel Management and determine the investigation type and Security
> Clearance Level. (Reference Attachment A.)
>
> 0 -- Not designated
>
> 1 -- Nonsensitive National Security Risk/Low Risk Public Trust
> Position
>
> 2 -- Noncritical Sensitive National Security Risk
>
> 3 -- Critical Sensitive National Security Risk
>
> 4 -- Special Sensitive National Security Risk
>
> 5 -- Moderate Risk Public Trust Position
>
> 6 -- High Risk Public Trust Position
>
> J. [Risk Designation]{.underline}: An assessment that determines the
> potential for adverse impact to the integrity and efficiency of the
> service, and its effect on the Agency or program mission. The Agency's
> determination gives the position either a low, moderate, or high-risk
> level.
>
> K. [Security Clearance Level]{.underline}: The degree of access to
> information and materials.
>
> 1\. [Top Secret]{.underline}\--Access to national security information
> or material that requires the highest degree of protection, and for
> which unauthorized disclosure could reasonably be expected to cause
> exceptionally grave damage to the national security.
>
> 2\. [Secret]{.underline}\--Access to national security information or
> material that requires a substantial degree of protection, and for
> which unauthorized disclosure could reasonably be expected to cause
> serious damage to the national security.
>
> 3\. [Confidential]{.underline}\--Access to national security
> information or material that requires protection, and for which
> unauthorized disclosure could reasonably be expected to cause damage
> to the national security.
>
> L. [Suitability]{.underline}: An individual's character or conduct
> that may have an impact on the integrity and efficiency of the
> service.
>
> M. [Suitability Adjudicator]{.underline}: An individual(s) assigned
> responsibility for determining suitability of an applicant, appointee,
> or employee. The Adjudicator must have the same level of investigation
> as cases he or she handles. The Adjudicator must have attended an
> appropriate OPM training course in adjudication and be thoroughly
> familiar with laws, regulations, and criteria pertaining to
> suitability determinations. The Adjudicator must consider all the
> information of record, both favorable and unfavorable, and assess it
> in terms of its relevance, recency, and seriousness.

**V. RESPONSIBILITIES**

A. Security Officer (Manager, Security and Emergency Management):

> 1\. The Security Office is responsible for receiving completed
> investigation reports from OPM and controlling the cases for BPA. They
> are responsible for providing the completed investigation report to
> the Suitability Adjudicator.
>
> 2\. The Security Officer is responsible for preparing and processing
> security clearances on employees whose positions have been determined
> to be high-risk public trust duties.
>
> 3\. Security Officers must have a BI (5-year background
> investigation).

B. Manager, Human Resources, Diversity and EEO develops the policy for
Suitability and program requirements for BPA.

> C. Manager, Personnel Services, through delegation to subordinate
> supervisors and servicing Human Resources Specialists, shall**:**
>
> 1\. Assign responsibility for determination of risk, security, and
> position sensitivity levels.
>
> 2\. Assign responsibility for suitability adjudication.
>
> 3\. Ensure that staff assigned responsibility are knowledgeable of
> requirements, laws, and regulations and appropriately trained to make
> determinations.

**VI. COVERAGE\--PERSONNEL ACTIONS SUBJECT TO INVESTIGATION**

> A. All appointments in the Federal service require the person to be
> investigated. (E.O. 10450)
>
> B. All transfers, conversions, or similar types of appointments to BPA
> require the completion of a background investigation if one has not
> been completed.
>
> C. A position designation change that increases the risk level of the
> position requires an investigation.
>
> D. An investigation must be done at any time there has been a break in
> service of more than two years.
>
> E. Applicants for employment must complete the OF-306, Declaration for
> Employment, for a preliminary suitability determination.

**VII. POSITION RISK DESIGNATION**

A.  Proper risk level and position sensitivity designation is the
    foundation of an effective and consistent suitability program. It
    determines what type of investigation is required and how closely an
    individual is screened for a position. Additionally, as the level of
    authority and responsibility of a position increases, character and
    conduct become more significant in deciding whether employment or
    continued employment would protect the integrity and promote the
    efficiency of the Federal service. Designated Personnel Services
    staff determines the appropriate position risk level and security
    level in order to establish the position sensitivity designation.

> **B. Determining Risk Level:** Each position will be designated at the
> High, Moderate, or Low Risk level depending on the position's
> potential for adverse impact to the integrity and efficiency of the
> service (5 CFR 731.106). Positions at the High or Moderate risk levels
> are referred to as "Public Trust" positions. Positions may also be
> designated as Computer Risk and National Security risk.
>
> **1. Public Trust Position\--**Positions at the high or moderate risk
> levels are designated as Public Trust Positions. These positions
> usually involve policymaking, major program responsibility, public
> safety and health, fiduciary responsibilities, or other duties
> demanding a significant degree of public trust. Also includes
> positions involving access to or operation of control of financial
> records, with a significant risk for causing damage or realizing
> personal gain.
>
> **a. High Risk\--**Positions with the potential for exceptionally
> serious impact on the integrity and efficiency of the service. Duties
> involved are especially critical to the agency or program mission with
> a broad scope of responsibility and authority. Positions may involve:

(1) Policy making, policy determining, and policy implementing;

(2) Higher level management duties/assignments;

(3) Independent spokespersons or non-management position with authority
    for independent action;

> \(4\) Fiduciary, public contact, or other duties demanding the highest
> degree of public trust.
>
> **b. Moderate Risk\--**Positions with the potential for moderate to
> serious impact on the integrity and efficiency of the Agency's
> missions and services. Duties involved are considerably important to
> the Agency or program mission with significant program responsibility,
> or delivery of service. Positions may involve:

(1) Assistants to policy development and implementation;

(2) Mid-level management duties/assignments;

(3) Any position with responsibility for independent or semi-independent
    action;

(4) Delivery of service positions that demand public confidence or
    trust;

**c. Low Risk\--**Positions that involve duties and responsibilities of
limited relation to an agency or program mission, so the potential for
impact on the integrity and efficiency of the service is limited.

> **2. Computer/ADP position\--**Determining a computer/ADP position
> risk level is an adjustment factor for both uniqueness and uniformity
> and tends to raise the risk level designation.

a.  **High Risk\--**Positions with the potential for exceptionally
    serious impact involving duties especially critical to the agency
    mission, with broad scope and authority, with major program
    responsibilities, which affect a major Computer/ADP system.
    Positions may involve:

    1.  Responsibility for the development, direction, implementation
        and administration of agency computer security programs,
        including direction and control of risk analysis or threat
        assessment;

    2.  Significant involvement in life-critical or mission-critical
        systems;

    3.  Responsibility for preparing or approving data for input into a
        system which does not necessarily involve personal access to the
        system, but which creates a high risk for effecting grave damage
        or realizing significant personal gain;

> \(4\) Assignments associated with or directly involving the
> accounting, disbursement, or authorization for the disbursement from
> systems of amounts of \$10 million per year or greater, or lesser
> amounts if the activities of the individual are not subject to
> technical review by higher authority to insure the integrity of the
> system;
>
> \(5\) Major responsibility for the direction, planning, design,
> testing, maintenance, operation, monitoring, or management of systems
> hardware and software;

\(6\) Other positions as designated by the agency head that involve high
risk for effecting grave damage or realizing significant personal gain.

**b. Moderate Risk\--**Positions with the potential for moderate to
serious impact involving duties of considerable importance to the agency
mission, with significant program responsibilities that affect large
portions of a Computer/ADP system. Positions may involve:

(1) Accounting, disbursement, or authorization for disbursement from
    systems with amounts less than \$10 million per year;

(2) Responsibility for systems design, operation, testing, maintenance
    or monitoring that is carried out under technical review of higher
    authority at the High Risk level, to insure the integrity of the
    system'

(3) Access to or processing of proprietary data, Privacy Act of 1974,
    and government developed privileged information involving the award
    of contracts;

\(4\) Other positions designated by the agency head that involve a
degree of access to a system that creates a significant potential for
damage or personal gain than that in High Risk positions.

c.  **Low Risk\--**Includes all Computer/ADP positions not falling into
    the High or Moderate risk levels.

C. **Determining Sensitivity Level**: Sensitivity levels are used as an
adjustment in the Risk Designation system to arrive at a final position
designation based on an assessment of the degree of damage that an
individual could cause to the National Security.

1\. **National Security Position**\--Positions that require regular use
of, or access to classified information.

> **a. Special Sensitive**\--Any position an agency head determines to
> be at a higher level than Critical Sensitive due to special
> requirements that compliment EO 10450 and EO 12968.
>
> **b. Critical Sensitive**\--Potential for exceptional or grave damage
> to the national security. Positions may involve:

(1) Access to Top Secret classified information;

(2) Development or approval of plans that involve war;

(3) National security policy-making or policy determining positions;

(4) Investigative duties;

(5) Issuance of personnel security clearances;

(6) Duty on personnel security boards; or

> \(7\) Any other position related to national security requiring the
> same degree of trust.
>
> **c. Non-Critical Sensitive**\--Potential for significant or serious
> damage to the national security. Positions may involve:

(1) Access to Secret or Confidential classified information; or

> \(2\) Duties that may directly or indirectly adversely affect the
> national security operations of the Agency.

**VIII. PROCESSING NON-INVESTIGATED APPLICANTS**

> A. The Acquiring and Positioning Staff (A&P) is responsible for
> initiating suitability determinations of non-investigated applicants.
> Before making any applicant suitability determination, the A&P staff
> should first ensure the applicant is eligible for the position, among
> the best qualified, and/or within reach of selection. Because
> suitability issues may not be disclosed until late in the
> application/appointment process, only the best qualified should
> require a suitability determination.
>
> B. The A&P will review the application materials for disqualifying
> factors as described in section X of this PL (information will only be
> available if the employee has submitted an OF-306 or a SF-171). The
> application will also be reviewed for indications of merit fraud
> issues. If any factors are identified as minor or moderate, the A&P
> will make the determination as to suitability for employment. If any
> factors are identified at the substantial or major level, the
> application will be referred to the designated adjudicator in the
> MASEWE Staff. The adjudicator will determine whether the individual
> appears to be suitable for employment in the Federal Government in any
> position with the level of risk of the vacancy, or the particular
> position for which application has been made. If the applicant is
> found not to be suitable for employment with the Federal Government,
> the guidelines in section XII of this PL will be followed.
>
> C. If there is adverse information shown on the application papers but
> a positive determination has been made, the A&P staff must make a
> notation on the application form indicating that the application is
> acceptable from a suitability standpoint. The notation must include
> the initials of the staff person and the date the determination was
> made.

D.  Any 30% compensable disabled veterans must be referred to OPM for
    adjudication if there is a suitability concern.

**IX. BACKGROUND INVESTIGATION FOR APPOINTEES AND EMPLOYEES**

> A. The Employee Services Staff (ESS) is responsible for initiating
> background investigations for new appointments, appointees who become
> subject to investigation, and those individuals whose background
> investigation has not been completed (i.e., appointment, conversion,
> transfers from other agencies).
>
> B. Completion of a successful background investigation is a job
> requirement. Providing the information is voluntary, but if an
> appointee or applicant chooses not to provide the required
> information, they will not meet the requirements of the job and will
> be terminated from their appointment.
>
> C. In many cases, additional information is needed from the subject to
> initiate an investigation or resolve an issue. If so, the applicant
> should be given a reasonable and specific time frame to submit the
> requested information, with notice that failure to respond will result
> in a finding that the applicant is ineligible and will be terminated
> for failure to meet the requirements of the position.
>
> D. Background Investigation forms must be completed within seven (7)
> days of placement in a position.
>
> E. The following forms must be submitted to OPM:
>
> 1\. OF-306\--Declaration for Employment;
>
> Application or resume;
>
> 2\. SF-85\--Questionnaire for Non-Sensitive Positions,
>
> 3\. SF-85P\--Questionnaire for Public Trust Positions, or

4\. SF-86\--Questionnaire for National Security, Sensitive Positions;
and

> 5\. SF-87\--fingerprint chart
>
> The forms must be signed within 120 days of the date of submission to
> OPM. Submitted forms, which are not signed within 120 days, will be
> delayed or returned by OPM.

**X. SUITABILITY FACTORS**

> A. Any of the following reasons may be considered a basis for finding
> an individual unsuitable:
>
> 1\. Misconduct or negligence in employment.
>
> 2\. Criminal or dishonest conduct.
>
> 3\. Material, intentional false statement or deception, or fraud in
> the examination or appointment process.
>
> 4\. Refusal to furnish testimony as required by Civil Service Rule
> 5.4.
>
> 5\. Alcohol abuse of a nature and duration that suggests that the
> person would be prevented from performing the duties of the position
> or would constitute a direct threat to the property or safety of
> others.
>
> 6\. Illegal use of narcotics, drugs, or other controlled substances,
> without evidence of substantial rehabilitation. Knowing and willful
> engagement in acts or activities designed to overthrow the U. S.
> government by force.
>
> 7\. Any statutory or regulatory bar, which prevents the lawful
> employment of the person investigated in the position in question.
>
> B. In making a determination as to the conduct stated above, the
> adjudicator shall consider the following additional considerations to
> the extent they are pertinent to the individual case:
>
> 1\. Type of position including degree of public trust or risk in the
> position.
>
> 2\. Nature and seriousness of the conduct.
>
> 3\. Circumstances surrounding the conduct.
>
> 4\. Recency of the conduct.
>
> 5\. Age of the person at the time of the conduct.
>
> 6\. Social conditions at the time of the conduct.
>
> 7\. Rehabilitation or absence of rehabilitation.

**XI. INVESTIGATION NOTICES**

> A. OPM sends notices to the Security office about cases in process.
> Each notice includes the name of the agency requesting the
> investigation, the type and timeliness service of investigation, OPM
> case number, the name of the Subject of investigation, and the
> Subject's social security number, (SSN) and date of birth (DOB).
>
> B. An **Investigation Scheduled Notice** is sent to the Submitting
> Office to verify that the requested investigation has been scheduled
> by OPM. This notice is filed on the temporary side of the OPF.
>
> C. An **Unacceptable Case Notice** is sent to the Submitting Office to
> return case papers not completed correctly or missing essential
> information about the person to be investigated. The investigation has
> not been initiated, so the notice must be returned to OPM with the
> corrected case papers as soon as possible.
>
> D. A **Case in Process Notice** is sent to a Submitting Office when an
> investigation meeting or exceeding requirements of the requested
> investigation is already in process. If the case in process was
> requested by the same SON, it indicates that the second request was a
> duplicate. If the case in process is for another agency's security
> office identifier (SOI), a copy of the case will be sent to the second
> requester's SOI when it is completed.
>
> E. A **Closed-Discontinued Notice** is sent to the Security Office
> when the case has been discontinued at agency request. The notice
> should be forwarded to the Employee Services staff for filing on the
> permanent side of the OPF.
>
> F. A **Closed-Incomplete Notice** is sent to the Security Office to
> return case papers when OPM has not received a new fingerprint chart
> previously requested from the SON. The notice must be returned to OPM
> with the new fingerprint chart and the case papers. If the
> investigation is no longer required, the notice is filed on the
> permanent side of the OPF.
>
> G. A **Returned-Requirements Met Notice** is sent to the Security
> Office indicating that an investigation has recently been completed
> that meets requirements of the requested investigation. This notice
> should be filed on the permanent side of the OPF after adjudication.
>
> H. A **Certification of Investigation** is sent to the Security Office
> for closed- complete cases. The notice is completed by the suitability
> adjudicator and filed on the permanent side of the OPF.

**XII. ADVERSE SUITABILITY DETERMINATIONS**

> A. Investigative information will be handled in a manner that protects
> the privacy of individuals without compromising the capability of BPA
> officials to make informed suitability and security determinations.
> The information upon which these decisions are based is highly
> personal and properly restricted to BPA officials who have a need for
> it in performing their duties.
>
> B. The Personnel staff is responsible for ensuring the records used in
> making an adjudication are accurate, relevant, timely and complete to
> the extent reasonably necessary to assure fairness to the individual
> in any determination.
>
> C. Applicants and appointees are entitled to any administrative due
> process requirements as provided by law, rule, or regulation when an
> unfavorable action based on information regarding suitability issues
> has been determined.
>
> 1\. Appointees, when a removal is proposed for making false statements
> on applications (other than Material, intentional false statements),
> will be processed following the guidelines established in 5 CFR
> 315.805. Appointees are entitled to the following:
>
> \(a\) Notice of proposed action.
>
> \(b\) A reasonable time for filing a written answer.
>
> \(c\) A written decision.
>
> \(d\) Delivery of the decision at or before the time the action will
> be made effective.
>
> \(e\) Appeal rights to the MSPB for discrimination for partisan
> political reasons or marital status or improper procedure.
>
> 2\. Applicants who will not be considered for appointment, and
> appointees when their removal is proposed for factors listed in X of
> this PL, will be processed following the guidelines established in 5
> CFR 731.401. Applicants and appointees are entitled to the following:
>
> \(a\) Notice of proposed action.
>
> \(b\) A reasonable time for filing a written answer.
>
> \(c\) A written decision.
>
> \(d\) Must be removed from the rolls within 5 workdays of the final
> decision if an appointee.
>
> \(e\) Appeal rights to the MSPB for suitability reasons.

D. If MSPB finds that one or more charges under Part 731 are supported
by a preponderance of the evidence, it shall affirm the determination.
If the MSPB sustains fewer than all the charges, they shall remand the
case to the agency to determine whether the action taken is still
appropriate based on the sustained charge(s). The determination by BPA
of whether the action taken is appropriate shall be final without any
further appeal to the board.

> E. If adverse suitability information (other than merit fraud),
> surfaces after completion of a probationary or trial period, any
> action must be taken under the provisions of 5 CFR 752. This means
> that conduct that may be disqualifying from a suitability standpoint
> may not be sufficient grounds for separation under 5 CFR 752. As a
> result, it is critical that required investigations be conducted in a
> timely manner so any adverse suitability information can be discovered
> and acted upon during the first year of employment.

**XIII. DEBARMENT**

> When BPA finds a person unsuitable for factors listed in X of this PL,
> it may deny that person examination for, and appointment to all, or
> specific, positions within BPA for a period of not more than one year.
> OPM retains authority for debarment beyond one year.

**XIV. RELEASE OF INFORMATION**

> When a subject of investigation asks for a copy of his/her own
> investigative file, he/she should be advised that OPM provides a copy
> of the file under a Privacy Act request. The individual must make a
> written request for the file to OPM-FIPC, FOI/PS, PO Box 618, Boyers,
> PA 16018-0618. The request must include the full name, AKA's, SSN,
> DOB, POB, full address, location of present or former Federal
> employment and it must be signed by the requestor.

Godfrey C. Beckett

Manager, Human Resources, Diversity and EEO

**Attachment A**

+--------+---+------------+---+----------+------------+----------+-------+
| **RISK |   | **SEN      | * | **PO     | **INVES    | **SE     | **FO  |
| L      |   | SITIVITY** | * | SITION** | TIGATION** | CURITY** | RMS** |
| EVEL** |   |            | = |          |            |          |       |
|        |   | **LEVEL**  | * | **SENSI  | **TYPE**   | **CLE    | **U   |
|        |   |            | * | TIVITY** |            | ARANCE** | SED** |
|        |   |            |   |          |            |          |       |
|        |   |            |   |          |            | *        |       |
|        |   |            |   |          |            | *LEVEL** |       |
+--------+---+------------+---+----------+------------+----------+-------+
| ### LO | * | ## NO      |   | **1**    | **NACI**   | **NONE** | **SF  |
| W RISK | * | NSENSITIVE |   |          |            |          | 85**  |
|        | + |            |   |          |            |          |       |
|        | * |            |   |          |            |          |       |
|        | * |            |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+
|        |   | **NON      |   | **2**    | **ANACI**  | **CONF   | **SF  |
|        |   | CRITICAL** |   |          |            | IDENTIAL | 86**  |
|        |   |            |   |          |            | OR       |       |
|        |   | **S        |   |          |            | SECRET** |       |
|        |   | ENSITIVE** |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+
|        |   | **         |   | **3**    | **SSBI**   | **TOP    | **SF  |
|        |   | CRITICAL** |   |          |            | SECRET** | 86**  |
|        |   |            |   |          |            |          |       |
|        |   | **S        |   |          |            |          |       |
|        |   | ENSITIVE** |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+
|        |   | *          |   | > **4**  | **SSBI**   | **SCI**  | **SF  |
|        |   | *SPECIAL** |   |          |            |          | 86**  |
|        |   |            |   |          |            |          |       |
|        |   | **S        |   |          |            |          |       |
|        |   | ENSITIVE** |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+
| **MO   | * | **NONS     |   | **5**    | **MBI**    | **NONE** | **SF  |
| DERATE | * | ENSITIVE** |   |          |            |          | 85P** |
| RISK** | + |            |   |          |            |          |       |
|        | * |            |   |          |            |          |       |
|        | * |            |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+
|        |   | # **NON    | # | # **2**  | **MBI**    | **CONF   | **SF  |
|        |   | CRITICAL** |   |          |            | IDENTIAL | 86**  |
|        |   |            |   |          |            | OR       |       |
|        |   | **S        |   |          |            | SECRET** |       |
|        |   | ENSITIVE** |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+
|        |   | **         |   | **3**    | **SSBI**   | **TOP    | **SF  |
|        |   | CRITICAL** |   |          |            | SECRET** | 86**  |
|        |   |            |   |          |            |          |       |
|        |   | **S        |   |          |            |          |       |
|        |   | ENSITIVE** |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+
|        |   | *          |   | **4**    | **SSBI**   | **SCI**  | **SF  |
|        |   | *SPECIAL** |   |          |            |          | 86**  |
|        |   |            |   |          |            |          |       |
|        |   | **S        |   |          |            |          |       |
|        |   | ENSITIVE** |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+
| **HIGH | * | **NONS     |   | **6**    | **BI**     | **NONE** | **SF  |
| RISK** | * | ENSITIVE** |   |          |            |          | 85P** |
|        | + |            |   |          |            |          |       |
|        | * |            |   |          |            |          |       |
|        | * |            |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+
|        |   | **NON      |   | **2**    | **BI**     | **CONF   | **SF  |
|        |   | CRITICAL** |   |          |            | IDENTIAL | 86**  |
|        |   |            |   |          |            | OR       |       |
|        |   | **S        |   |          |            | SECRET** |       |
|        |   | ENSITIVE** |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+
|        |   | **         |   | **3**    | **SSBI**   | **TOP    | **SF  |
|        |   | CRITICAL** |   |          |            | SECRET** | 86**  |
|        |   |            |   |          |            |          |       |
|        |   | **S        |   |          |            |          |       |
|        |   | ENSITIVE** |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+
|        |   | *          |   | **4**    | **SSBI**   | **SCI**  | **SF  |
|        |   | *SPECIAL** |   |          |            |          | 86**  |
|        |   |            |   |          |            |          |       |
|        |   | **S        |   |          |            |          |       |
|        |   | ENSITIVE** |   |          |            |          |       |
+--------+---+------------+---+----------+------------+----------+-------+