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j&_bre <br /> & associates <br /> /�/ ltants in acoustics <br /> P.O. Box 6748 •Aubum,California 95604 <br /> 263 Nevada Street•Auburn, California 95603 <br /> p.530.823.0960 £530.823.0961 • www.jcbrennanassoc.com <br /> October 13,2010 <br /> Mr. Tom Tcrpstra <br /> Law Office of Thomas H. Terpstra <br /> 578 N. Wilma Avenue,Suite A <br /> Ripon,CA 95366 <br /> Subject: Review of Munn & Perkins Increased Nighttime Operations Environmental <br /> Noise Assessment <br /> Dear Mr.Terpstra: <br /> j.c. brennan & associates, Inc. has reviewed the Revised Environmental Noise <br /> Assessment for the above referenced project. The analysis was conducted by Bollard <br /> Acoustical Consultants (BAC), dated August 23, 2010. The revisions are in response to <br /> several letters sent by San Joaquin County Community Development Department and the <br /> Senior Code Enforcement Officer, Mr. Rick Matuska, outlining the noise complaints <br /> which had been received since 2003 with regards to the excessive noise coming from the <br /> plant due to plant operations after the approved operating hours, and on nights that were <br /> not approved for night operations. <br /> We have provided reviews of two previous draft reports dated October 7, 2009 and July <br /> 1, 2010. For the most part, the final analysis does not deviate in methods, procedures or <br /> even conclusions from the previous reports. This review will provide comments on <br /> specific flaws which we have found in the report, and will detail the pages of the report <br /> where they occur. However, it may be useful to summarize the major flaws in the report <br /> prior to providing detailed comments. <br /> SUMMARY OF MAJOR TECHNICAL PROBLEMS WITH THE REPORT <br /> A. The report provides a discussion on the effects of single event noise, primarily <br /> due to increased truck traffic on local roadways. The discussion centers around <br /> the potential for sleep disturbance, and utilizes the Federal Interagency <br /> Committee on Aviation Noise (FICAN) report which estimated a 5 — 10% of the <br /> population is affected when interior SEI, noise levels are between 65 and 81 dB, <br /> and few sleep awakenings (less than 5%) are predicted if the interior SEL is less <br /> than 65 dB. This procedure does not account for the number of events. <br /> However, most recent research and procedures for evaluating sleep disturbance <br /> are based upon the American National Standards Institute (ANSI) which has <br /> developed procedures for evaluating the potential for sleep disturbance. The <br /> Procedure ANSI/ASA S12.9-2008 / Part 6 sets for the procedures for evaluating <br /> I <br />