DEPARTMENT OF DEFENSE
         DEFENSE OFFICE OF HEARINGS AND APPEALS
          
            
In the matter of: )
)
) ISCR Case NO. 15-03742
)
)
Applicant for Security Clearance )
Appearances
For Government: Benjamin Dorsey, Esq., Department Counsel
For Applicant: Greg F. Greiner, Esq.
                                                                            
______________
Decision
______________
LYNCH, Noreen, A., Administrative Judge:
The Department of Defense (DOD) issued a Statement of Reasons (SOR) to
Applicant alleging security concerns arising under Guideline G (Alcohol Consumption),
and Guideline J (Criminal Conduct), The SOR was dated November 1, 2015. The
action was taken under Executive Order 10865, Safeguarding Classified Information
within Industry (February 20, 1960), as amended; Department of Defense Directive
5220.6, Defense Industrial Personnel Security Clearance Review Program (January 2,
1992), as amended (Directive); and the Adjudicative Guidelines (AG) implemented in
September 2006. 
Applicant timely answered the SOR and requested a hearing before an
administrative judge. I received the case assignment on August 12, 2016. DOHA issued
a notice of hearing on November 3, 2016, for a hearing scheduled on January 19, 2017.
The hearing was postponed and rescheduled for February 10, 2017. Government
Exhibits (GX) 1-3 were admitted into evidence without objection. Applicant testified, and
submitted Applicant Exhibits (AX) A-D. I held the record open and Applicant submitted
another document, which was marked as AX E, and entered into the record without
objection. The transcript was received on February 21, 2017. Based on a review of the
1
pleadings, testimony, and exhibits, eligibility for access to classified information is
denied.
Findings of Fact
In her answer to the SOR, Applicant admitted the factual allegations under
Guideline G (Alcohol Consumption) and Guideline J (Criminal Conduct) with detailed
explanations.  1
Applicant is a 42-year-old employee of a defense contractor. She is divorced and
has no children. Applicant obtained her undergraduate degree in 1998. She has worked
for her current employer since 2015. (AX B) However, she has worked as a defense
contractor for a number of years.  She has held a security clearance since 2006. (Tr.19)
Alcohol Consumption
Applicant admitted her arrests and convictions for driving while intoxicated in
March 1998, June 2002, August 2004, and October 2012. The three earlier charges
related to drinking and driving when Applicant was much younger and still living where
she went to college.
Applicant’s first incident (SOR 1.a) in 1998 was dismissed in February 1999. (GX
3) She explained that she had been drinking at her boyfriend’s house, had an argument
with him and left to go home early. She was stopped for a traffic violation and
acknowledged her drinking to the officer. She paid the assessed fines and fees. (Tr. 21)
In June 2002, Applicant was arrested and charged with driving while intoxicated.
(SOR 1.b) She was stopped for speeding near her apartment. She was questioned
about drinking and acknowledged that she had perhaps two glasses of wine at a happy
hour. (Answer to SOR; Tr. 22) She admits speeding so that she could arrive at another
function timely. The court dismissed the charge. (GX 3) In her answer, Applicant stated
that she “fully recognizes her issues with alcohol use”. She stated that she was going to
counseling”. 
In August 2004, Applicant was arrested and charged with driving while
intoxicated. (SOR 1.c) She left a wedding reception, where she had been drinking. She
stated that she recognized that she had too much to drink. (Tr.23) She did not dispute
the charge and was found guilty of driving while intoxicated -1st offense. (GX 3)
Applicant paid fees, fines and completed probation. (Tr. 24; AX C) At that time, she was
in her 30's. In her answer to the SOR, she stated that her actions were irresponsible
and that she made a bad choice. She completed the sentencing order, payment of fines
and community service.  She stated that she deeply regretted drinking and driving. She
again stated that she recognized her issues with alcohol use. (Answer to SOR)
The SOR Answer signed by Applicant on 12/17/15, swore that “she was abstaining permanently from      1
alcohol use, and volunteered for random urinalysis testing.
2
In 2007, Applicant left her college town and moved to another state where she
had family. A period of five years passed, and Applicant did not have another incident
with drinking and driving. (Tr. 28) She was gainfully employed.
  In October 2012, Applicant was arrested and charged with (1) felony hit and
run, personal injury, (2) driving while under the influence of alcohol, and (3) refusal to
take a breath test. The court found Applicant guilty of driving while intoxicated. She was
sentenced to 180 days incarceration, with 170 days suspended. The court ordered a
fine of $1,500, with $1,000 suspended, fees of $806, and further ordered that her
driver’s license be suspended for 12 months. She was also ordered to enter and
complete the alcohol awareness program (ASAP) program. (AX C) On her own, she
sought out counseling. (Tr. 31) She reported the incident to her facility security officer (
FSO). (Tr. 53)
Applicant’s explanation included the fact that it was an “incredibly stressful year”
and that she was required to travel for work every two weeks. (Tr. 29) When she
disclosed the incident on her current security clearance application, she stated that she
was looking down for her phone and she misjudged the distance between her car and
the one in front of her. (GX 1) She explained that she tapped his bumper and she exited
her car. She reported that the man was very agitated and began yelling at her. They
exchanged insurance information. The man wanted a police report as there was a
scrape on his bumper. (GX 1) Applicant agreed that they call the police, but they
wanted to move their cars our of the middle of an intersection. (Tr. 29) In her answer to
the SOR, Applicant stated that the man got back into his car and left the area. She
parked her car on the side street, and she waited for about 20-30 minutes. According to
Applicant, the police did not report nor could she find the man in the car. She was near
her apartment complex and decided to park in the complex garage. Applicant reports
that the police came to her apartment and she denied initially that she had been
drinking. She admitted that she had wine at dinner. She refused a breath test and a
field sobriety test. 
Applicant does not recall if she had any alcohol evaluations or counseling after
the first three alcohol driving incidents. After the 2012 conviction, she was referred for
an alcohol evaluation and followup treatment. On November 5, 2012, upon the advice
of an attorney, she presented for a substance abuse evaluation. (AX A) 
A substance abuse and treatment report, dated February 5, 2013 by a licensed
professional counselor (LPC), notes that Applicant started drinking at the age of 19 in
college. After turning 21, Applicant’s alcohol use increased to three or four drinks about
two or three times monthly. Applicant abstained from drinking for one year after the
1998 alcohol incident. Applicant acknowledged that she resumed drinking after that
period of time. The report also states that Applicant abstained from drinking after the
2004 alcohol charge for about eight months and completed educational classes and
counseling. (AX A)
 The February 5, 2013 report section noting clinical impressions and
recommendations noted that Applicant did not meet the DSM-IV criteria for any
3
diagnosis. It went on to say that “however, it was of clinical concern that Applicant had
two previous alcohol-related driving offenses, and recommended that Applicant remain
abstinent and complete an outpatient treatment plan”. Applicant successfully complete
the treatment plan.  Applicant reported abstinence with no difficulty since the offense in 
October 2012 (at that time four months ago).
Applicant, at the suggestion of her current attorney, contacted a licensed clinical
psychologist (Dr.M) in December 2015 for a mental health-substance abuse evaluation.
The report, dated December 8, 2015, states that Applicant did so as part of her
response to a notice of possible loss of her security clearance. (AX A) Dr. M.
interviewed Applicant on two separate days in December.  Dr. M. considered his two2
interviews, review of the case and presented his opinions and recommendations for
Applicant. He noted that Applicant was forthcoming during the interviews, is taking the
situation seriously, and is concerned about her job.  She reported the facts about the
latest 2012 alcohol incident as consistent with her other evaluation interview in 2012.
Applicant reported stable employment and a promotion. She is taking steps to focus on
her career, change her environment, and receive family support. 
Dr. M’s report noted that Applicant was abstinent since receiving her notice of a
security clearance issue, except for a Thanksgiving dinner with her family. Applicant
was candid when she revealed to Dr. M. that she had wine with her family and prior to
the notice from DOD, she reported drinking two to three times per week, somewhere
between two and four drinks. Dr. M. gave Applicant the screening test for alcohol
problems, resulting in three out of four positive indicators of difficulties. He noted that
Applicant was in an inpatient treatment program for alcohol dependence after the 2004
alcohol incident. “She remained abstinent for about six months after that time. Applicant
attended counseling in 2012 and group therapy and the LCP at the time noted that
Applicant’s insight was improving.” She also participated in AA. From 2004 until 2012
there were no issues involving alcohol reported. She was progressing in her career. (AX
A) She noted that she was very proud of her job, and does not want to lose it. She went
on to say “abstinence is the only way.” She went on to admit that counseling was not
enough. “Without abstinence I don’t see how there is going to be a level of trust by
DOD.” She stated she was always willing to undergo random urinalysis.
Dr. M. indicated in his December 2015 report that Applicant’s family is aware and
valued supportive system. Applicant was engaged, but the relationship recently ended.
She was divorced in 2006. In summary, Dr. M. stated in the report that it would appear
that Applicant has an alcohol use disorder. “She is now beginning to abstain, which is a
first step on the road to a fuller recovery.” Dr. M. reinforced Applicant’s belief that due to
stress about possibly losing her job, that abstinence is the only option for her both
personally and in terms of a plan to re-establish a level of trust regarding the security
clearance for her work.” Dr. M. recommended AA, a course of regular counseling, and a
sponsor. (AX A)
Dr. M’ s credentials include 38 years of clinical work in substance abuse largely with young adults. He is      2
the director of a counseling center, a professor in a college department of psychiatry, and his own private
practice.
4
Finally, Dr. M. reported that, with vigilance, abstaining from all alcohol use, with a
support network, Applicant could establish credibility for her security clearance. He
noted that she has a great respect for having a security clearance. (AX A)
Applicant followed Dr. M’s recommendation for therapy and counseling. She had
an initial intake in January 2016 and attended weekly individual therapy sessions. In a
February 29, 2016 report, written by a CSAC, Applicant was described as having
gained insight into her decision making skills, specifically the use of alcohol as a coping
mechanism. She expressed great regret for the alcohol incidents. This abuse counselor
stated in the report letter that Applicant does meet diagnostic criteria under the DSM-IV
for Alcohol Use Disorder, in early remission. The counselor stated that “continued work
in therapy and continued abstinence indicate a positive prognosis.” (AX A)
In a February 6, 2017 letter from the same CSAC, the counselor repeated the
same information about Applicant’s participation in therapy and insights into her
behavior.  She again noted that Applicant meets the DSM-5 diagnostic criteria of an
Alcohol Use Disorder. Applicant noted that she would subject herself to on-going
scrutiny to further reinforce a positive diagnosis. However, she did not state that she
would refrain from drinking alcohol. (AX A)
At the hearing, Applicant expressed her remorse, love of work, support system
and sense of rehabilitation. She is active in her community and on the Homeowner’s
Board. (Tr.40) She purchased a home and has many activities. (Tr. 41) She has
continued family support. Also at the hearing, Applicant was candid when asked about
her current use of alcohol. She stated that she is not currently abstaining from alcohol
use. She drinks socially with friends. She may have a drink at home or on weekend with
friends. (Tr.44) She may drink two or three glasses of wine. She noted that despite the
counseling and recommendations for abstinence from alcohol, she feels that she is in
control and if there is a social event she will drink. (Tr. 45) She acknowledged that she
abstained from using alcohol after each incident for a period of time. (Tr. 46) For the
last incident in 2012, she abstained for the court-ordered period of time.
Applicant was clear that she has since evaluated things. She has made an
investment in regular personal counseling. (Tr. 46) She continues the counseling.
Applicant denied that her current counselor advised her to abstain from drinking
alcohol. (Tr. 47) After looking at the various letters and reports, Applicant agreed that
she had been advised to abstain from drinking alcohol. However, she went on to clearly
explain that after self-reflection, she feels that she is in control of that use. (Tr. 51) She
does not want that issue to affect her career. She reluctantly agreed that in her
investigative interview, she told the investigator that she planned to abstain from
drinking alcohol. (Tr. 53) She stated that everyone knows that she drinks and
associates with people who drink regularly; i.e, with colleagues after work.  (Tr. 56) She
does not consider herself alcohol dependent. (Tr. 54) She has had no further arrests
since 2012.
Applicant does not believe she has a problem with alcohol, and she does not
drink and drive. She does believe that she used to rely on alcohol when stressed. She
5
reflected on the advice about abstinence, but responded when questioned that she
enjoys socializing and having a glass of wine. (Tr. 60) She attributes the three earlier
alcohol incidents to living in a college town and an active social life. (Tr. 61) She stated
that the 2004 DUI changed her and she knew that was not the path for her. When
asked if she would abstain to keep her clearance, her response was “Yes.”  But she
restated that she is in control. (Tr. 64) 
Applicant submitted 18 letters of recommendation. She received letters of
appreciation from her employer. Each letter attests to her character, dedication, and
strong sense of integrity. Her brother praises her unwavering work ethic. Her father
states that she is a capable individual. An attorney wrote that Applicant had a mistake
in judgment but no criminal intent with her alcohol incidents. (AX D)
A post-hearing submission letter, dated February 10, 2017, from an SES
professional who has worked with Applicant since 2007 states that Applicant maintains
the character requirements needed to perform a highly sensitive and pressure oriented
job. She shared her current situation and he believes that she demonstrates the
responsibility and character required to hold a security clearance. (AX E)
Criminal Conduct
The security concerns for alcohol consumption and criminal conduct are the
same. They are cross-referenced in 2.a - that information as set forth in  subparagraphs
1.a through 1.d above. Applicant admitted the allegation in 2.a
Policies
When evaluating an applicant’s suitability for a security clearance, an
administrative judge must consider the adjudicative guidelines (AG). In addition to brief
introductory explanations for each guideline, the adjudicative guidelines list potentially
disqualifying conditions and mitigating conditions. These guidelines are not inflexible
rules of law. Instead, recognizing the complexities of human behavior, they are applied
in conjunction with the factors listed in the adjudicative process. An administrative
judge’s overarching adjudicative goal is a fair, impartial, and commonsense decision.
Under AG ¶ 2(c), this process is a conscientious scrutiny of a number of variables
known as the “whole-person concept.” An administrative judge must consider all
available, reliable information about the person, past and present, favorable and
unfavorable, in making a decision.
The protection of the national security is the paramount consideration. AG ¶ 2(b)
requires that “[a]ny doubt concerning personnel being considered for access to
classified information will be resolved in favor of national security.” In reaching this
decision, I have drawn only those conclusions that are reasonable, logical, and based
on the evidence contained in the record. Likewise, I have avoided drawing inferences
grounded on mere speculation or conjecture.
6
The Government must present evidence to establish controverted facts alleged
in the SOR. An applicant is responsible for presenting “witnesses and other evidence to
rebut, explain, extenuate, or mitigate facts admitted by applicant or proven by
Department Counsel. . . .”  The burden of proof is something less than a3
preponderance of evidence.  The ultimate burden of persuasion is on the applicant.  4 5
A person seeking access to classified information enters into a fiduciary
relationship with the Government based on trust and confidence. This relationship
transcends normal duty hours and endures throughout off-duty hours. The Government
reposes a high degree of trust and confidence in individuals to whom it grants access to
classified information. Decisions include, by necessity, consideration of the possible risk
the applicant may deliberately or inadvertently fail to protect classified information. Such
decisions entail a certain degree of legally permissible extrapolation of potential, rather
than actual, risk of compromise of classified information.
 
Section 7 of Executive Order 10865 provides that decisions shall be “in terms of
the national interest and shall in no sense be a determination as to the loyalty of the
applicant concerned.”  “The clearly consistent standard indicates that security clearance6
determinations should err, if they must, on the side of denials.”  Any reasonable doubt7
about whether an applicant should be allowed access to sensitive information must be
resolved in favor of protecting such information.  The decision to deny an individual a8
security clearance does not necessarily reflect badly on an applicant’s character. It is
merely an indication that the applicant has not met the strict guidelines the President
and the Secretary of Defense established for issuing a clearance.
Analysis
.
Guideline J, Criminal Conduct
AG ¶ 30 expresses the security concern pertaining to criminal conduct, “Criminal
activity creates doubt about a person's judgment, reliability, and trustworthiness. By its
very nature, it calls into question a person's ability or willingness to comply with laws,
rules and regulations.”
 See also ISCR Case No. 94-1075 at 3-4 (App. Bd. Aug. 10, 1995).      3
 Department of the Navy v. Egan, 484 U.S. 518, 531 (1988).      4
 ISCR Case No. 93-1390 at 7-8 (App. Bd. Jan. 27, 1995).      5
 See also EO 12968, Section 3.1(b) (listing multiple prerequisites for access to classified or sensitive      6
information), and EO 10865 § 7.
 ISCR Case No. 93-1390 at 7-8 (App. Bd. Jan. 27, 1995).      7
 Id.      8
7
AG ¶ 31 describes conditions that could raise a security concern and may be
disqualifying:
(a) a single serious crime or multiple lesser offenses;
(b) discharge or dismissal from the Armed Forces under dishonorable
conditions;
(c) allegation or admission of criminal conduct, regardless of whether the
person was formally charged, formally prosecuted or convicted;
(d) individual is currently on parole or probation; and
(e) violation of parole or probation, or failure to complete a court-
mandated rehabilitation program.
Applicant’s admissions and the evidence of alcohol-related arrests and
convictions from 1998 to 2012 are sufficient to raise security concerns under AG ¶¶
31(a) and (c).
AG ¶ 32 provides four conditions that could mitigate security concerns:
(a) so much time has elapsed since the criminal behavior happened, or it
happened under such unusual circumstances that it is unlikely to recur
and does not cast doubt on the individual's reliability, trustworthiness, or
good judgment;
(b) the person was pressured or coerced into committing the act and
those pressures are no longer present in the person's life;
(c) evidence that the person did not commit the offense; and
(d) there is evidence of successful rehabilitation; including but not limited
to the passage of time without recurrence of criminal activity, remorse or
restitution, job training or higher education, good employment record, or
constructive community involvement.
After reviewing the mitigating conditions, I find that Applicant’s behavior occurred
between 1998 and 2012. Despite the fact that there were two dismissal of criminal
charges and five years since her latest 2012 alcohol conviction, the criminal incidents
are alcohol related. Five years have elapsed since the last incident. Applicant provided
information with her counseling and her success in her work. She claims that she does
not drink and drive. All the criminal charges are interrelated with the alcohol
consumption. The fact that Applicant still drinks casts doubt and she failed to show that, 
despite the passage of time, a similar incident is unlikely to recur. AG 32(d) partially
applies. She has not mitigated the criminal conduct security concerns. 
8
Guideline G, Alcohol Consumption
AG ¶ 21 expresses the security concern pertaining to alcohol consumption,
“Excessive alcohol consumption often leads to the exercise of questionable judgment or
the failure to control impulses, and can raise questions about an individual's reliability
and trustworthiness.”
AG ¶ 22 describes conditions that could raise a security concern and may be
disqualifying:
(a) alcohol-related incidents away from work, such as driving while under
the influence, fighting, child or spouse abuse, disturbing the peace, or
other incidents of concern, regardless of whether the individual is
diagnosed as an alcohol abuser or alcohol dependent;
(b) alcohol-related incidents at work, such as reporting for work or duty in
an intoxicated or impaired condition, or drinking on the job, regardless of
whether the individual is diagnosed as an alcohol abuser or alcohol
dependent;
(c) habitual or binge consumption of alcohol to the point of impaired
judgment, regardless of whether the individual is diagnosed as an alcohol
abuser or alcohol dependent;
(d) diagnosis by a duly qualified medical professional (e.g., physician,
clinical psychologist, or psychiatrist) of alcohol abuse or alcohol
dependence;
(e) evaluation of alcohol abuse or alcohol dependence by a licensed
clinical social worker who is a staff member of a recognized alcohol
treatment program;
(f) relapse after diagnosis of alcohol abuse or dependence and
completion of an alcohol rehabilitation program; and,
(g) failure to follow any court order regarding alcohol education,
evaluation, treatment, or abstinence.
Applicant admits the history of alcohol-related incidents from 1998 to 2012. The
record reflects that she was evaluated by a licensed clinical psychologist and certified
abuse counselors. She was diagnosed with an alcohol disorder. She has been advised
for a positive prognosis to abstain from alcohol. After each incident, she did abstain for
a period of time. Applicant stated to an investigator that the plan was to abstain from
alcohol. She values her job and her security clearance and takes that seriously.
However, now Applicant states that she is in control and despite the fact that she has
been consistently advised to refrain from drinking, she drinks. She stated that she does
not drink and drive. However, it is troubling that she feels that despite the counseling
9
and advisements, she need not abstain from alcohol. She does not feel that she has a
problem with alcohol.
AG ¶ 23 provides conditions that could mitigate security concerns:
(a) so much time has passed, or the behavior was so infrequent, or it
happened under such unusual circumstances that it is unlikely to recur or
does not cast doubt on the individual's current reliability, trustworthiness,
or good judgment;
(b) the individual acknowledges his or her alcoholism or issues of alcohol
abuse, provides evidence of actions taken to overcome this problem, and
has established a pattern of abstinence (if alcohol dependent) or
responsible use (if an alcohol abuser);
(c) the individual is a current employee who is participating in a counseling
or treatment program, has no history of previous treatment and relapse,
and is making satisfactory progress; and,
(d) the individual has successfully completed inpatient or outpatient
counseling or rehabilitation along with any required aftercare, has
demonstrated a clear and established pattern of modified consumption or
abstinence in accordance with treatment recommendations, such as
participation in meetings of Alcoholics Anonymous or a similar
organization and has received a favorable prognosis by a duly qualified
medical professional or a licensed clinical social worker who is a staff
member of a recognized alcohol treatment program.
 Applicant admitted her alcohol-related incidents. She was ordered several times
to complete programs, but she does not attend AA. She has a support system and is in
counseling. She admits that she has turned to alcohol in difficult times. Despite the
numerous advisements to refrain from drinking alcohol, she has only abstained each e
for limited periods of time. She agreed at one time to abstain, but she has changed her
plan.  She does not believe that she has an alcohol problem at this time.  I have  doubts
about her judgment and reliability. After considering the mitigating conditions outlined in
AG ¶ 17, I conclude Applicant has not mitigated the security concern under alcohol
consumption.
Whole-Person Concept
Under the whole-person concept, the administrative judge must evaluate an
applicant’s eligibility for a security clearance by considering the totality of an applicant’s
conduct and all the circumstances. The administrative judge should consider the nine
adjudicative process factors listed at AG ¶ 2(a): 
10
(1) the nature, extent, and seriousness of the conduct; (2) the
circumstances surrounding the conduct, to include knowledgeable
participation; (3) the frequency and recency of the conduct; (4) the
individual’s age and maturity at the time of the conduct; (5) the extent to
which participation is voluntary; (6) the presence or absence of
rehabilitation and other permanent behavioral changes; (7) the motivation
for the conduct; (8) the potential for pressure, coercion, exploitation, or
duress; and (9) the likelihood of continuation or recurrence. 
Under AG ¶ 2(c), the ultimate determination of whether to grant eligibility for a
security clearance must be an overall commonsense judgment based upon careful
consideration of the guidelines and the whole-person concept. As noted above, the
ultimate burden of persuasion is on the applicant seeking a security clearance. 
I considered the potentially disqualifying and mitigating conditions in light of all
the facts and circumstances surrounding this case, as well as the whole-person factors.
Applicant has worked in the defense industry for many years. She has held a security
clearance since 2006. She has no noted security violations. She has had accolades
from her various employers. She performs exceptional work. After her youthful alcohol
related incidents in 1998, 2002, and 2004, she had eight years without incident.  After
the 2012 conviction, she obtained substance abuse evaluations and attended
counseling. She continues with individual personal counseling. Despite her concerns
about her job and keeping a security clearance, Applicant has decided not to follow the
advice that she has been given by several professionals to abstain from drinking
alcohol. She has been given a diagnosis of alcohol disorder. Granted there were many
years between the first three incidents and the 2012. However, her change of plan not
to abstain from alcohol is troubling given the circumstances of the case. There have
been no incidents since 2012. The criminal conduct is interrelated with the alcohol
consumption security concerns. I conclude that she has not mitigated the concerns
under the criminal conduct guideline or the alcohol consumption guideline. I have many
doubts about her issue of control concerning the use of alcohol given the diagnoses. 
Applicant has agreed to monitoring by way of random urinalysis, but believes she
has no alcohol problem and everything is in control. Any doubts must be resolved in
favor of national security. Applicant has not met her burden in this case under the
alcohol consumption guideline or the criminal conduct guideline. Clearance is denied.
Formal Findings
Formal findings for or against Applicant on the allegations set forth in the SOR,
as required by section E3.1.25 of Enclosure 3 of the Directive, are:
Paragraph 1, Guideline G: AGAINST APPLICANT
Subparagraphs 1.a-1.d: Against Applicant
Paragraph 2, Guideline J: AGAINST APPLICANT
11
Subparagraph 2.a: Against Applicant
Conclusion
In light of all of the circumstances presented by the record in this case, it is not
clearly consistent with the national interest to grant Applicant a security clearance.
Clearance is denied. 
                                                     
NOREEN A. LYNCH
Administrative Judge
12