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10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />87. Vibration is sound radiated through the ground. Groundborne noise is rumbling <br />sound caused by the vibration of room surfaces. According to the EPA's technical guideline on <br />vibrations, the dental office constitutes a "critical area" that requires lower vibration levels to be <br />acceptable. The preferred values for Petitioner Choe's office are: 0.0050 (z-axis), 0.0036 (x- and <br />y-axes), with maximum values of 0.010 (z-axis), 0.0072 (x- and y-axes). Petitioner Choe stated in <br />her written comments opposing the Car Wash Project, that her medical/dental machinery and <br />equipment and highly sensitive hand pieces such as the drill for nerve treatment, will cease to <br />function even at very low vibration levels. <br />88. The vibrations generated by the car wash are "serious environmental impacts" that <br />Respondents should have evaluated in a subsequent environmental review document when they <br />revised the Original Project to include a car wash. This is particularly true because of the unique <br />location of the 4,354 square -foot car wash tunnel on 301 N. Tustin Avenue, only inches from the <br />dental office building on 171 N. Tustin Avenue, and the opening of the tunnel towards the <br />sidewalk and professional business uses across the street. (See supra, site plan image, p. 5.) A <br />vibration impact assessment needed to be performed and considered before the Revised Project <br />was approved. Similarly, the extremely close proximity of the car wash tunnel to the Petitioner <br />Choe's building is unusual and thus mandates further assessment and evaluation so that mitigation <br />measures may be incorporated into the project, including for construction, if possible, and as <br />conditions to any project approvals. The vibration and noise disturbance Petitioner Choe suffered <br />during the restaurant demolition at 301 N. Tustin Avenue, which was significantly further away <br />from her building than the mere inches to the tunnel of the new car wash, evidences the unusual <br />circumstances of the Revised Project and need for these evaluations prior to any approvals for the <br />Project. <br />89. The Revised Project will have a significant impact on noise by the addition of a <br />massive, automated car wash. According to the Environmental Protection Agency ("EPA"), Noise <br />levels are generally considered low when they are below 45 dBA, moderate in the 45 to 60 dBA <br />range, and high above 60 dBA. The car wash will operate from 7:00 am to 7:00 or 8:00 pm, seven <br />days per week, and will service up to 30,000 cars per month. Prior to its demolition in 2019, 301 <br />PETITION FOR WRIT OF MANDATE <br />