In addition to reviewing the model validation report, Stoller has examined newly collected water level data in multiple wells at the Shoal site. On the basis of these data and information presented in the report, we are currently unable to confirm that the model is successfully validated. Most of our concerns regarding the model stem from two findings: (1) measured water level data do not provide clear evidence of a prevailing lateral flow direction; and (2) the groundwater flow system has been and continues to be in a transient state, which contrasts with assumed steadystate conditions in the model. The results of DRI's model validation efforts and observations made regarding water level behavior are discussed in the following sections. A summary of our conclusions and recommendations for a path forward are also provided in this letter report. Background An underground nuclear test was conducted at the Shoal site in October 1963. Environmental restoration at the site has followed a process prescribed by the Federal Facility Agreement and Consent Order (FFACO) between the DOE, U.S. Department of Defense, and State of Nevada. Under the FFACO, two phases of well drilling and testing (in 1996 and 1999) contributed to site characterization, and DRI developed multiple models of groundwater flow and radionuclide D r a f t iii EXECUTIVE SUMMARY Environmental restoration at the Shoal underground nuclear test is following a process prescribed by a Federal Facility Agreement and Consent Order (FFACO) between the U.S. Department of Energy, the U.S. Department of Defense, and the State of Nevada. Characterization of the site included two stages of well drilling and testing in 1996 and 1999, and development and revision of numerical models of groundwater flow and radionuclide transport. Agreement on a contaminant boundary for the site and a corrective action plan was reached in 2006. Later that same year, three wells were installed for the purposes of model validation and site monitoring. The FFACO prescribes a five-year proof-of-concept period for demonstrating that the site groundwater model is capable of producing meaningful results with an acceptable level of uncertainty. The corrective action plan specifies a rigorous seven step validation process. The accepted groundwater model is evaluated using that process in light of the newly acquired data. The conceptual model of ground water flow for the Project Shoal Area considers groundwater flow through the fractured granite aquifer comprising the Sand Springs Range. Water enters the system by the infiltration of precipitation directly on the surface of the mountain range. Groundwater leaves the granite aquifer by flowing into alluvial deposits in the adjacent basins of Fourmile Flat and Fairview Valley. A groundwater divide is interpreted as coinciding with the western portion of the Sand Springs Range, west of the underground nuclear test, preventing flow from the test into Fourmile Flat. A very low conductivity shear zone east of the nuclear test roughly parallels the divi...