ML20101F008

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Response to Summary Disposition Motions on Contention 57-C-3, Alerting/Notification During Normal Sleeping Hours 1 Am - 6 Am. Facts Alleged by Applicants & FEMA Do Not Adequately Support Summary Disposition
ML20101F008
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 12/21/1984
From: Eddleman W
EDDLEMAN, W.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20101F012 List:
References
CON-#484-768 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8412260476
Download: ML20101F008 (6)


Text

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f 21 December-1984 UNITED STATES OF AMERICA "'d NUCLEAR REGULATORY COMMISSION. M I6 M #039 Ch u . .rckt ,e BEFORE THE ATOMIC SAFETY AND LICENSING BO'ABD _ py'C Glenn Dr. O. Bri James H.ght Carpenter James L. Kelley, Chairman In the Matter of

) Docket 50 400 OL CAROLINA POWER AND LIGHT CO. et al. "

ar S Harris Nuclear Power Plant, ASLBP Ho. 82-h68-01 OL Wells Eddleman's Response to Summary Disposition Motions on Contention 57-C-3 (Alerting / Notification during Norinal Sleeping Hours lam-6am)

Both Applicants and FEMA fail to address at least two key issues in this contention, namely (1) assuring that people asleep between 1 a.m. and 6 a.m. in the Harris EPZ would be " timely awakened to take sheltering action", and (2) the effect of closed windows, air conditioners, etc. on the ability of alerting systems to awaken residents in the EPZ.

10 CPR 50 47 tb)(5) requires establishment of "means to l

provide early notification * *

  • to the populace within the plume exposure pathway Emergency Planning Zone (EPZ)" (emphasis added).

Notification is not provided to a person who doesn't hear it, or who l

OE is not awakened by it. (FEMA has neither received nor reviewed the Harris

$$' siren system design report -- Hoell affidavit 12/6/84, p.1)

8 Applicants' acoustics affiant, Dr. Bassiouni, testified on
  • 0 g such problems in the Catawba emorgency planning hearings in 1984.1 h@

n He said air conditioners can add 15 decibel (s) to the ambient (Tr.1852)

% and closed windows would produce a 15-20 decibel reduction (in signal) i EEo 1

,, ,3,g of relevant portions of that Catawba E.Pinn tranneript CDbb

(Tr. 1852-53; see also Tr. 1851: there is an indoor-outdoon sound difference). Dr. Bassiouni testified that there is a substantial probability that people indoors under closed window conditions, the air conditioner on, would not hear the siren. (Tr. 1853).

He also testified there is a possibility at both 60 and 70dB siren sound levels, that the siren would not be heard if the windows were open and the air conditioner on. (Tr.1852). There is nothirg in FEMA-43 (Quoted, Apps, p.6) exempting indoor areas from 60/10dB coveress, All of this is in the context of the same type of 125-dB (at 100 feet or 30 meters distance) sirens CP&L is using for Harris.

(See Catawba EP Tr. 1841-42; Applicants' Motion at 10). Dr. Bassiount testified in Catawba that in f act, these 125-dB rated sirens drop

-30 2 their noise level by 254 5 as they rotate (Tr. 184 -45), i.e. the 95-signal varies betweenx100 and 125 dB at 100 feet, and "at some location far from the siren, the 10 decibel ambient will not be met" (Tr.1844, witness Bassiouni).

acoush'c Assuming the 50dB a coverage of the narris rPz claimed by Applicants is correct (they do not provide their substantive analysis or data with the affidavits and Motion for Sunriary Disposition on 57-C-3), the drop of 15 dB associated with an air conditioner, as Dr. Bassiouni testified to in Catawba, would logically result in

-- not enough loudness to t 10 dB above coverage aj;See

(. 4only5835 dti.eg i 2-; 84(S<ow,.;, P F ambient noise leve s.j In a e osed building, the rop of 15-20 dB Dr. Bassiouni testified to in Catawba would logically have the same result; having the air conditioner on in the closed building would simply make it even harder to hear the siren. Although 100% siren notification is not required by NUREG-0654 (incorporated by reference into NRC rules 10 CFn 50 47 via a footnote), a " substantial probability" that persons would not hear the siren, which applies to many peonle its the EPZ (those sleeping in closed houses or with the air conditioner on) is not acceptable. The alerting must occur within 15 minutes within 5 miles of Harris (NUREG-0654) and the sirens are the only ivans

f .

, provided to do this (except in the unpopulated area of the plant itself, Zone A ) . As Applicants' Pugh affidavit shows, paragraphs 4-16, the (see Motion at 13: 20 to 45 minutes a rox.)

mobile siren notification can't be done in under 15 minute , Pugh also provides no assurance that such sireans will in fact wake people up.

It is common for emergency vehicles, sirens blaring, to pass in the night without awakening most people sleeping along their routes.

Motion at full speed (see Apps. Motion fn 5, p.1h) is required to cover these routes in the estimated times, and that cuts down on the time anyone not in a built-up area will be exposed to the mobile sirens.

Moreover, these times are estimates (Pugh affid paragraph 3, p.2) which have not been verified in practice yet (ibid.) and there is

'no basis for them given. ,

Pugh also states only his " confident" opinion as a basis for sufficient personnel and vehicles being available to cover these alerting routes at all times. And some routes may take more dann 45 minutes (see Pugh paragraph 4, p.3; paragraph 11 pp 6-7; paragraph 12, pp 7-8) based on the logically dubious assumption that all these mobile alerting units will not only be instantly available, but will be dispatched immediately upon siren activation (Pu3h paragraph 2, p.2).

The siren signal would have to be verified first, and the vehicles notified. This might only take a minute or two, but it would be more time than Pugh assumes.

  • Finally, this system is irrelevant for the reason advanced by Applicants, that it is not the primary alerting system. Moreover, it cannot meet the time requirements for the primary alerting system anywhere within 5 miles of the plant, and in some cases (see above) cannot aset the 45 minute limit within 10 miles of the plant for sono sones.

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Applicants' entire Mileti affidavit is likewise irrelevant becaus'e the " ripple effect* and other matters he talks about are not notifica-tion (alerting) provided by CP&L or the emergency response agencies.

Dr. Mileti gives no quantitative or Harris-specific data to show that enough people will in fact be awakened (between 1 a.m. and 6 a.n.

under accident conditions) to start the " ripple effect".

The clear intent of 10 CFR 50 47 and NUREG-0654 is for the alerting system to be designed to " provide early notification" (omnhasis added) to the populace within the 10-mile EPZ. 100%

coverage is not required, but design to cover essentially 100% is.

NUREG-0654 Appendix 3 requires notification systems to nrovide an alert signal "to the population . . . throughout the 10 mile EPZ, within 15 minutes". This clearly means essentially 100%, and this design objective is reconfirmed in Applicants ' own cite of NUREG-0654

p. 3-1 (Motion at 5), though it need not work in 100% of cases.

NUREG-0654 also requires the notification system " assure direct coverage of essentially 100% of the population within 5 miles of the site" (See Apps. Motion p.5), and that "Special arrangements will h made to assure 100% coverage within 45 minutes of the population who may not have received the initial notification" within the entire plume exposure FPZ. (emphasis added).

This last is the operative part re contention 5 7-c-3, for ,

as shown above (pp 1-3) Applicants' own affiant Bassiouni testified that for similar sirens there was a " substantial probability" that sleeping persons in closed buildings with air conditioners on, would not hear the siren alert, and there was a possibility for sleeners with open windows not to hear it, even with 60 or 70 dB above ambient coverage. (Harris coverage is 50 dB for the whole EPZ, 60-70 in most of it, according to Applicants -- see e.g. Apps Motion at 10. )

This is not 100% coverage as required, so special means e.g.

those advocated in the contention, must be used to give 100% c, overage.

1

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5 The special means have not been shown to cover 100% of the EPZ within 45 minutes even based on Applicants' Pugh affidavit, and its basis is very thin: only his confidence that adequate vehicles and personnel will be available to do the notification; assumed immediate start of l notification dien sirens sound; estimated route coverage times not confirmed; routes of ten traveled at full speed (50+ mph) limiting time persons are exposed to mobile sirens; no analysis of what it takes for these mobile sirens to wake people up. Telephone alerting or tone alert radios do not have these drawbacks.

Applicants and PTMA make much of FEMA-43's leaving the choice of notification system to Applicants. But PEMA-43 is NOT an NRC rule.

10 CPR 50.47 and NUREG-0654 are the rules, and they require that 100% notification be assured. If Applicants aren't in compliance with that (and there is clear doubt of it based on their own affidavits; FEMA's affidavit adds essentially nothing to Applicants'; Dr. Bassiouni's Catawba testimony clearly undermines Applicants' conclusions here, fatally), this Board clearly has power t'o order compliance. That is essentially what contention 57-C-3 seeks, and the contention should be tried to determine what notification systems are in fact required to provide the 100% notification NUREG-0654 requires.

$6 Wells Eddleman P.S. another logical problem can be shown with Applicants' siren coverage estimates: There are 62 sirens for 10 mile radius EPZ (Apps' Motion p.10), The EPZ area is thus 1007r snuare miles (314 sq mi).

That gives 1 siren for every 5 s uare miles. Thus the mean distance between sirens should be about miles, or 2.236 mi.,or 11,806 feet.

A siren rated 125 dB at 100 feet will put out only 1/10,000 as much energy at 10,000 feet (dropping off with square of distance), per unit area to be alerted. Since dB = 20 log (Pressure / Pressure g this is a drop of 80 dB (1/10000= 10-4, i.e. log y of1/10,0009p),4; s-

-4 x 20 is -80' dB), dropping the peak sound ko 45 dB at 10,000 feet.

When the siren rotates to face away from the target " hearer", it drops Catawba Tr.1842-h5), i.e.to 15-PO dB, another 25-30 dB (Bassiouni,5dB virtually inaudible. Even 4 is below the 50 dB required to have an audible alert tone in the Harris EPZ's low-noise areas.

. e STATEMENT OF FACTS IN DISPUTE s ON CONTENTION 57-C-3

1. There is no showing the crimary alerting system can alert essentially 100% of the EPZ populace within 15 minutes, particularly those sleeping in closed buildings, indoorp those with air conditioners on, and even those with open windows and an air conditioner, TV or stereo on (see Catawba Tr. 1853-54 In a fren'ote bm6/70dB 10N'aNeamYe'n'thcoe"ke*#'

. 2. There is no showing the mobile alerting system either (a) will wake

! up people sleeping indoors in closed buildings or otherwise as stated in Fact 1 above; nor (b) can accomplish this for the whole EPZ within 45 minutes as NURE-0654 requires.

i.

3 The " ripple effect" and other alerting actions not undertaken by 1

l nor controlled by Applicants and/or the emergency planning authorities

or emergency response authorities in the EPZ (& State of NC authorities) do not count as compliance with 50 47(b)(5) or NUREG-0654's notification
requirements.

4 The Harris sirens, as rated, may deliver signals below 45 dB, as low as 15-20 dB when rotating away from target " hearers", in signifi l cant parts of the EPZ..

1 j 5. The alerting provided, must satisfy the requirements of 10 CFR 50p 7 l (and NUMEG-0654 as incorporated by reference in that section), and that i

includes waking up sleepers -- you can't notify someone who is asleep.

6. The Board has authority to ensforce the provisions of 10 CPR $0 47, including authority to order the use of additional special alerting measures (e.g. tone alert radios, automatic ringdown telephones) to assure that the notification reqyirements of NUREG-0654, Appendix 3, and NUREG-0654 section E (including E 6) are met as required by 10 CFR 50 47.
7. The " facts" alleged by Applicants and FEMA do not adequately support susanary disposition of Contention 57-C-3.
8. FEMA has not yet received or reviewed the Harris siren system design l report (FEMA, Hoell affidavit, 12/6/84)

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(* NCCLEAR REGL LATORY Commission 540f

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In the matter of;

'8 DUKE POWER COMPANY, et al (Catawba Nuclear Station, **I"*yo,10-412 50-414 g Units 1 & 2)

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1 Locauon: Rock 11111, S. C.

9.L Pays 1816 - 19F8 Date: Friday, May 11, 1984 t )

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1'( i , inass 2 Panel of witnesses Direct Cross Redirect Recross Board 3 M. READA BASSIOUNI) 1821 1827 1942 1956 1942 (CESG)

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1963 5 J. T. PUGH, III ) (PA) (PA)  ;

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Description:

Identified Received '

I 19 Applicants' EP-17: Applican'ts' 1825 1825 Testimony on Emergency Planning i 20 Contention No. 9  ;

  • i EP-17 Thomas Portions 21 1829 1829  !

22 Intevenors' EP-39: Letter date 1917 1918 December 27, 1983 to Mr. Hampton, 23 Ouke Power Company, from Crowinds, emergency plan attached..

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, a 1841 4pbl 1 (, i BY MR. RILEY:

2 O I assume that you are familiar with the purchaso

a specifications of the sirons, Mr. Glover.

4 A (Witness Glover) I have reviewed it. I did not r 5 prepara it.

6 Q Do you know whether or not there's voltago gr . 7 sensitivity with respect to, one, frequency, and two, level 8 of output?

9 A I'm not aware.

10 .Q Well, hypothetically then, Dr. Bassiouni, if 11 ,the motor is voltage sensitivo, what happens to the pitch e

i 12 of the tono as the voltage increasos? What happens as it i

, is decreases, and also what hapoons to the output?

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5 is l A (Witness Bassiouni) What happo:*s is the siren l

is ' tone's fr,cquency will fluctuato betwoon 10 hortz on each to side of the tono. So for instance, if you're talkino about

,j 17 stron tono of 500, it could be 490 or it could bo 510.

8 O And what about the decibol output? ,

, "to A It absolutoly has no offect. It will be the g

20 namo decibol rating, as will be for this frequency.

h(l 21 As far as the sound propagation, the sensitivity q

22 of this frequency will have extremoly noolioibio offect.

23 Q We've just hoard from !!r. Glover that one of tho

,q 24 sirons rotatos 125 doqtbol lovel, and the other at 113, does

- 25 not. Is it correct to say that there is a horn associated ~

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I with the 125 docibol modol?

6 2 A Correct.

3 0 What is the function of that horn? '

4 A The function of Lho horn is to project the high 5 sound beam to a corLain location, and rotates in a low l 6 rotatio$ratotocovertheentiro360degroosaroundthe 1

7 stron.

l 8 0 Now that means if one were to survey at a uniform l 9 radius around that siren in the stacked position, one would 10 have different lovels of sound intensity, doponding on )

1 11 their position? i 12 A Correct. l 13 O And if one is to rotato C.o siron, and thoso -

Id airons do rotato, or measure somo fixed punition, one will '

i 15 find variations in sound pressure lovol, docilsel ratino. l

'o A correct.

17 O And that is shown in Piqure 4 of one of your l l

to exhihits. I bollavo Attachmont D. '

19 A I cannot recall the exact flouro number, but I 20 can check it riqht now.

21 JUDGE MARGULIES: libile the witness is checkina, 22 lot the record reflect that Mr. Droomo has assumed his 23 placo with the panol. Ito is available for cross-oxamination.

24 Prior to boino called on for cross'-examination, you may oo

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25 over with him the assumotion ot his testimony.

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1843 4pb1

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i Whereupon, -

1 2 LEWIS MAYNE BROOME 3 was called as a witness on behalf of the Applicant and, 4 havina been previously duly sworn, was examined and testified 3 further as follows:

4

, 6 MR. RILEY: I'm sorry. It's Appendix 4 that I

. 7 have reference to.

s WITNESS BASSIOUNI: 'Thank you, that's what I was 9 tryino to Check. Basically, Figure 4 is showing the sound, 10 sound pressure level variation with time. 'The X axis represer ti the sec,onds, the vertical access represents the decibel in 12 dbc.

, 13 BY MR. FILEY:

( I4 Q Would it be a fair approximation to the information is that you show for,six sirens in this Appendix 4, to say that to there is a difference of about 30 decibels between maximum 17 sound output and minimum sound output, as perceived at a is given point while the siren is rotating? .

~~

10 A (Witness Bassiouni) I would say a difference .

20 of 25 de'cibel, rather than 30.

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21 O Well, in looking at a numoer of these, I see ,

occasional minima 22 of 92 decibels, and correspondino maxima 23 of 125, 126. This is for siren 6. .

24 A If you takt.the extreme minimum and maximum, yes,

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25 that's correct. If you take the average for the minimum l -

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I e and the maximum, there will be between 20 and 25 decibel. -

t 2 Q In other words, you're saying, if you do a bit 3

g of smoothing in the curve?

4 A Right, exactly. ,

s O All right. Now, when you're in the vicinity for 6 a smooth value, would you say a minimum in the vicinity of 7I 95 decibels would be reasonable?

s A 95 to 100, I would say.

  • Q 95 to 100 would be reasonable. .

10 A Right.

Il 0- All right. Then that would be something like ,

12 25 decibels down from the peak intensity. And would it be 13l- inaudible in terms of the 10 decibel above criteria to catch 14 a person's attention?

15l A If the siren is directed to a listener at a certain location when it's off-phase, it means the horn is directed lal 17 in an opposite direction. At some location far from the is siren, the 10 decibel above the ambient will not be met. ,

19 Q Does not the guidance call for a steady siren .

20 signal? ,

21 A Yes. The siren signal is steady.

22 -Q But is not the important thing the perception of

-23 the siren signal? ,

24 A I think the guidelings-ere addressing the 3

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. 25 characteristic of the signal. So the signal in regards to i 7 .

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,( 1 location of niren is ntoady all the, time. The efteetivo 2' modulation of the signal up and lower would really have a 3 great offect on attracting people's attention. It's the 41 same way if in a room with a very loud sterco, after a few t

5 minutes you would not pay any attention to the stereo. i 1

6 Ifyougetsomebodyturningthestereoonandoff,j

,. 7 you will probably have a great deal of attention to the a signal. A:td 'that's the purpose of this siren. ,

9 Also, I would like to add that this concept has 10 been used for over 100 years. These sirens have been used i 11 for peace and war, and I guess the rotation of the siren has

12 a creat advantage of attracting people's attention. l J

13 i O In reading the relevant guidelines, is there any 14 qualification made that the steady slenal aptlies to what l 15 is generated, rather than to what is heard?

16 A '

I don't think it specifically addresses that; i7 if it is referrino to the way it is oenerated, or to the i is , way it is heard. -

19 0 *0n the 113 decibel siren, if I may use that 20 shortcut notation, there is no horn.

What sort of an outlet, 21 what sort of a sound" port is there in that siren?

, 22 A There is multiple horns arourd the siren. They 23 are located all around the circumference of the siren itself.

24 0 Do you know.how many horns there are?

25 A I don't recall exactly, but it could be 12 or 167

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1 A Yes, we will. I might mention our systems for

  • i 2 Oconee and McGuire are the same type of system as we have at 3 Catawba, and chose are based on four rpm. We are in the 4 process of changina over Catawba fron 2 rpm that we got from 3 5 the manufacturer, over to a 4 rpm rate.

6 O And if the decibel is 6 decibel down, the matter ,

  • 7 that I referred to earlier is translated to 4 rpm, then the a period of time in which the signal will be heard at this leve!

9 would bc of the order 2.4 to 5 seconds, is that correct?

10 A (Witness Bassiouni) Correct.

11 0 Why do you recommend 4 rpm?.

12 A It has been a common industry standard to use 4 rpm, 13 so basically the recommendation was just go and have it 4 rpm.;

14 ' O Do you Anow what the standard As based upon?

?

15 A Based on a pu're human judoment. '#e have donc some 16 experiments with different rpm. Mc not pcopic standing at a 17 different location and let them rate the -- or judge the .

18 signal, if we changed from 2 rpm to 3, to 4, to 5, to 6 ..?d 19 it was indicated that 4 is an optimum speed that mout of the ,

, 20 people say that tl.ey heard the siren very well at that speed.

i 21 Q Richt. We have already talked about the indoor -

. 22 outdoor dif ference. '."ho ambient sound level is a factor in 23 whether or not the outsi,de sound will be perceived.

24 Is that cpsdect? h 25 A Picht. Correct.

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't Q A'nd'An summertime in t.his p' art of the cou_ntry, is i

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..;d d it your understanding that,many bomes use air conditioning?

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3 i' A ' Yes.

4 Of f Do' air conditionuds crStribute to the ambient sound .

3 levei? , .:.

6 "A" Yes. <

y O Could you tell'us what decibel contribution they a make? .,

9 A They ca'n make an additional 15 decibel to the ambient, depending oE the type:of air conditioning used.

10 i

} ii Q That means that a likely hypothesis that the 12 air conditioner was on, the windows were open, the siren

, _ia signal would not be hear'd if it dere, say, at the 60 decibel ..

34 contour? '

15 A There is a possibility, yes, a O At the 70-lecibel contour?

37 A The 70 will be the chance, depending on the 3 s 18 [ background noise, there will be a cre.a.ter chance to be heard. .

i, O Now let's close the windows'in the house. P1 case 12g provida us with the decibel intensity reduction of outside 1

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l .1 4 it sound for a reasonable range of the structures that you will 22 ' find in this EPZ.

4

[2q , A The structures we'll find'in this EPZ probably 24 will have in the range of betweert 15 and 20 decibel reduction so if you are indoors moving froml outdoors to indoors, you 25 e

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2 Q Would it be fair to conclude then that there is 3 a substantial probability that people indoors under closed d window conditions, the air conditioner on, would not hear the f 5 signal?

6 A That is correct.

. 7 Q What about the contribution of normal household 8 activities like conversation. What sort of decibel levels 9 do we have there?

10 A It depends on the individual making the sound.

11 Q I agree.

f 12 A But I would say you could really produce a few I

13 decibels.

14 ! Q All richt.

, 15 Now obviously again it depends upon the settine of 16 the control, but what range of sound do we get from the t' 17 t'levision Set?

18 A Once again, it is just depending on how you set up I

to the volume for the TV set. i E>actly. But what is the range, please?

f. 20 Q

. 21 A I can make out of my 'V 110 decibel and I can 22 really make it as low as 55 decibel.

23 Q Right. Does ,that trean that ordinary listeners 24 might have it somewh.ere in the vicinity of 60 to 80?

l- 25 A Some, yes, depending on the age and the interest ,

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, 2 0

  • Could we say somethino similar about stereo
h. 3 equipment, sound cauipment.?

, 4 A Yes.

?

5 0 And this again would mean that there would be a 6

high probability -- I am saying high -- that an outdobY siren 7 signal would not be heard?

5. 8 A Yes, I agree.

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-4 Q On Page 7 of the attachment --

l 2 A Attachment B?  ;

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3 Q -- of Attachment B, you indicate that relative t .

  • d humidity has an effect on sound signals. Could you tell us t

3 what this effect of humidity is? Does it enhance or reduce 6 a given level of signal?

7

  • A Okay. It's really not a straight line relation-t 8 It's a combination between the relative humidity and ship.

' cemperature, sc you've got to look at the two cuantities -

10

( together. .

II Sometimes lower humidity and a certain range of

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12 temperature will reduce the sound propogation. Sometimes ,

higher humidity and a certain range of temperature will

'f 33 enhance the sound propogation.

[

[ 15 Q Now you are, of course, familiar with the usual 16 diurnal cycle in temperature and humidity where ordinarily

'7 humidity goes to a maximum in the early hours of the 18 morning, and then goes to a minimum towards the close of the ,

l' day. You are familiar with that?

20 A Yes, I am.

. 21 Q Ncsw since you used an average value for temperature 22 and humidity in your computer program, your computer program i 23 does not tell us about that variatign; is that correct?

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I, 24 A That's correct. Let me add something to here.

I l 25 Would you, please?

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, A In FEMA-43 that has been used as a guideline, it i '

2 specifically states on Page E-7, " Average summer daytime 3 weather conditions may be utilized."

It's the fourth line 4 from the top of Page E-7.

t 5 Q Right. You have certainly met the FEMA standard.

6 But what is the range in decibels between the maximum effect

  • l 7 of the combined te,mperature and humidity and the minimum 8 effect of the combined temperature and humidity?

9, A Okay. Specifically for Catawba? I 10 0 That would be fine.

11 A For average, I would say three to four decibels.

12 Q Good. Thank you.

13 Now what effect has rainfall on signal strength?

3 14 A Rainfall will also attenuate the sound by the same 15 kind of effect which probably you are talking about to the  !

i 16 order of two to three decibels. i 17 Q Right. Now when rain is striking a roof -- and, 18 of course it will depend upon c..plet size and frequency -- l 19 what sort of values of additional sound can we get?

2

. 20 A Okay. Basically that effect, the rain falling 21 will increase the ambient noise level. It will generate

" 22 noise.

23 . Q Right. How much?

24 A Okay. Icadnottellyou-howmuch. Depending on

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25 the surface, depending on other factors that you have to k

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2 Q Would you say up to, say, 80 or 90 decibels? l

3; A You mean additional? e l

4 Q Yes.

l

- 5 A No. I would say on the order of a fes decibels.

'6 Once again, it depends on the drop size,'and this will

[ 7 produce frequency in a range that is not included in the a signal frequency. For instance, you have a signal of 500.

9 Commonly, the rain will produce high ambient on the high

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10 frequency range which, in fact , would not affect your signal.

11 Q Have you of your own experience measured the .

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! 12 sound level increase..inside the house with open windows of .

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a heavy rain on an adjoining methl roof? Have you measured

. 13 14 it yourself?

i is A No, I haven't. .

s to Q What about rain striking foliage?

17 A It will also produce ambient noise. It will add to b

l 18 the ambient noise.  !, '

l i

19 0 What is the effect of falling snow?  !

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i 20 A Falling snow, because the ambient noise would not 4

21 be raised as much as rain, but it will add some effect to the .

22 damping of sound waves coming out of the source, which is the ,

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! 23 siren. ,

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24 Q Have you some information, whether yours or l..

literature information, on the absorption effect of f&lling  !

25

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3 i snow?

2 A Yes.

3

, O Could you tell us, please? l 1

A Snow, depending on the thickness of the layer of e 5 the snow, it doe's have what we call an acoustic impedence 6

absorption. And depending on your distance from the siren, 7

depending on the heigh of the receiver, elevation of the  !

8  !

receiver, you are~ basically talking about anywhere between -

one to two, six or seven decibel reduction. j 10 Q Let's talk about the six decibel contour. At the

' 60 decibel contour, how much attenuation? I 12 A You may get as much as six or seven decibels.- l

  • ' I3 MR. MC GURREN: Your Honor, for purposes of

\ 14 clarification, I am wondering myself, does the witness 15 understand that the snow has fallen, or is it in the process !

'* of falling?

37 18 Excuse the interruption. I just want the record 'l to be clear. *

" MR. RILEY: I welcome.the interruption, Judge.

- 20 '

I think it's a good distinction to make.

21 BY MR. RILEY: l 22 Q You are referring to snow on the ground; is that i 23 not correct? -

24 A (Witness Ba'ssiouni) Yes, I do. I 25 MR. MC GURREN: I thought your question was

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-8 3 falling gnow?

2 MR. RILEY: My question did, indeed, have to do

'3 with falling snow. There is some snow on the ground. There d is a heavy snowfall in progress.

5 BY MR. RILEY:

6 0 Do you have any information on that effect?

7 A (Witness Bassiouni) No. Falling snow, in the .

8 process of snowing, I don't. But the accumulation of snow

' on the ground, we do.

10 Q Would you expect there would be attenuation due 31 to snow particles in the air?

12 g -Yes. Very slight. It would not affect the j

' ~~

33 siren signal.

3d There is a discussion in both your Attachment B

! Q 15 and in CBG 1-17 of the effects of wind direction and to velocity on a siren signal. And as I understand it, in 17 positions that are upwind from the siren, the signal will is be deflected upward; is that correct' I' Correct.

A 20 Q Now your computer model, which shows 50, 60 and .

!j 21 70 decibel contours, is premised on a wind direction of --

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22 what is it? -- 6.7 miles per hour or thereabouts from the 23 southwest? Is it a 6.7, and it is from the southwest at 24 .a temperature of 77.4 degrees Fah' enheit and a relative _

25 humidity of 54 percent; is that correct?

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> A That's correct. And that's exactly what we 2

have on Pago E-7 from FEMA-43. .

These are the average summer !

3 daytime conditions.

i Q Right. But now we're concerned about whether or 5

not we're going to be able to alert 100 percent of the 6

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population by a siren signal within five miles within fifteen 7

minutes.

l 8

If the wind direction is from the northeast, that  !

will change all these contours?

10 A Correct.

O Are you aware that the second most prevalent 12 wind direction is from the northeast? .

- 13 A Yes.

O The wind velocity will be a factor, and the higher 15 the wind velocity, the larger the effect; is that correct?

30 i A That's correct. '

4

'7 Q Are you familiar with the average monthly maximum i-

'8 i wind velocities in this region, bouglas Municipal Airport?

I' A Yes.

20 Q Are you aware that they are on the order of 21 20 miles per hour?

22 A Yes.

23 Q That iaould produce a substantial effect, then?

24 '

A Yes.

, 25 0 And in terms of the documents we now have, a person

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. 4 1864 ..

6-10 1 who might, under the conditions of your study, be exposed -

, l 2 to a 60 decibel signal, might now be exposed to a 3 substantially smaller one?

d A It's a possibility.

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k. i 0 In the extreme case, how much lower? j 2 A I would say on the order of 10 decibels' lower.

l 3 A (Witness Glover) If I may make.a point on that, 4 Mr. Piley, what Mr. Bassiouni is not aware of is in this

. 5, case where you have winds blowing from the northeast and you 6 are considering those people up in that sector as to sound 7! reduction the real threat or the real need for people to be aware of that' situation is down in the other direct.on, in '

8 I

9 the southwest where the wind is blowing towards if you did  !

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to any particular concerns for an emergency at that time.

. ii so by the winds blowing down into that direction, 12 you arc actually enhancing the coverage of your system into l

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, la that area.

' 14 0 Thank you.

15 On nace 14, aaain of Attachment B, you describe 16 with par.icularity your technioue. I was just curious, what. l 17 .l was the source of the calibrations that you used in the field?l 18 A It is a standard calibrator.. It is a tone that i 19 is produced; the brand name is written right there i'n the

. 20 third paragraph. That produced a very accurate sional witiin t 21 .2 decibel.

22 Q Right.

23 I was wonder.i,ng whether it was also a pitch

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24 calibrator. .-

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25 A It is a pitch calibrator. i i

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