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# Comment Response to Comment <br /> not obvious in the Investigation and figures. However, even if monitoring event and data gaps investigation will be included in <br /> they were non-detect in previous sampling events, appropriate the Annual Monitoring Report that will be submitted following <br /> upgradient, cross-gradient, and downgradient wells still need to completion of the data gaps investigation in accordance with the <br /> be included on a monitoring and reporting program to evaluate 2018 GMWP. <br /> plume migration. <br /> Recommended Action: If the wells that were only sampled for <br /> depth to water measurements can be sampled for COC analysis, <br /> Central Valley Water Board staff recommend the Port sample <br /> select wells to address Central Valley Water Board comments <br /> below where applicable. Furthermore, if these wells can be <br /> sampled,the select wells should be added to the monitoring and <br /> reporting program for appropriate plume migration assessment. <br /> 2 Issues: Central Valley Water Board staff identify an additional See response to DTSC General Comment 3a. <br /> data gap on the upgradient, southeast corner of the contaminant <br /> plume at Site 3 (Figure 3). <br /> Recommended Actions: An additional grab groundwater <br /> sample(s) should be advanced to the southeast of EW-003 and <br /> EW-004 to adequately delineate the maximum horizontal and <br /> vertical boundary of the contaminant plume on the upgradient <br /> side. <br /> 3 Issues: The modeled contaminant plume geometry expressed in See response to DTSC General Comment 3b. <br /> Figure 4 of the Investigation suggests a diving plume to the <br /> east. However, additional data gap samples are not proposed on <br /> the eastern boundary to delineate the maximum horizontal and <br /> vertical extent. Existing wells that were sampled in the Q3 2018 <br /> are too shallow to define the extent of a deeper plume on the <br /> eastern boundary. Furthermore, Figure 4 on the 14 December <br /> 2018 Constituents of Concern Evaluation Report depicts an <br /> inferred contaminant boundary on the northeastern edge of the <br /> cic-1,2-DCE plume near the railroad tracks. Consequently,the <br /> 6 08 03 201 1> <br />