ML20154L501

From kanterella
Jump to navigation Jump to search
Affidavit of LC Sutherland.* Addresses Allegations in Contention Bases A.7 & A.8 Re Hearing Damage to Anyone within 100 Ft of Siren During Operation.Certificate of Svc Encl
ML20154L501
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 09/17/1988
From: Sutherland L
PUBLIC SERVICE CO. OF NEW HAMPSHIRE, WYLE LABORATORIES
To:
Shared Package
ML20154K393 List:
References
OL-1, NUDOCS 8809260208
Download: ML20154L501 (11)
v • d • e


Text

_ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _

September 17, 1988 4

UNITED STATES OF AMERICA t NUCLEAR REGULATORY COMMISSION f L

before the ATOMIC SAFETY AND LICENSING BOARD [

i I

)

In the Matter of )

) ,

PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL-1 l NEW HAMPSHIRE, et al. ) 50-444*^L-1 l

) (On-fiite Emerge.ic!  !

j (Saabrook Station, Units 1 and 2) ) Planning and Safety l ) Isstes)

)  !

i AFFIDAVIT OF LOUIS C. SUTHERIAND j P

J I, Louis C. Sutherland, being on oath, depose and say as 6 i follows:

I

1. I am Deputy Director and Chief Scientist of Wyle Research, a division of Wyle Laboratories, El Segundo, California. A statement of my professional qualifica';1ons is attached hereto and marked "A".
2. The purpose of this affidavit is to address allegations in Contention Bases A.7 and A.8 regarding (1) hearing damage to anyone within 100 feet of the siren durirg its operation (Basis A.7); and (2) sound irregularities (Basis A.8).

3

t Basis A.7 Hearing Damage j 3. In response to Interrogatory No. 24 1, the Attorney General indicated that the basis for Contention Basis A.7 is ,

"Appendix 3 (at 3-8) of NUREG-0654, FEMA-REP-1, Rev. 1" which l t

states:  ;

"The maximum sound levels received by any member of ,

the public should be lower than 123 dB, the level which may cause discomfort to individuals." 'j l

4. The VANS siren is a dual siren  ;

i  !

system rated at 134 dB(C). This scund level is produced f

along tha siren Lystem centerline at a distance of 100 feet [

t from the siren. It also necessarily follows, that for sirens l elevated above ground level this sound level is produced at a distance 100 feet from the siren at the height of tho siren centerline above ground level (e.g., 134 dB(C) at 100 feet, 45 feet above ground level}. Since there are no permanent structures (except at the staging areas themselves) at or within 100 feet of the preselected siren locations (See Affidavit of Richard J. Faix atl11 12, 13) it is not possible for any member of the public to be subjected to a sound pressure level of 134 dB(C) (unless of course, they were elevated, by some means to a height of 45 feet above ground level).

I "Massachusetts Attorney General's Response to First set of Interrogatories Regarding the Massachusetts Attorney General's Arended Contention on Notification Systan," dated July 12, 1988.

2-

5. I have evaluated the data measured on the ground near the prototype dual and the single sirens to establish a near field directivity ' 'el for the dual in a vertical plane. Utilizing ti..

model, I have determined that with the siren 25 feet abr ground level, the maximum sound level at 5 feet above the ground (i.e., at ear level) is 131 dB(C) which cccurs abolit 90 feet from the siren. With the stren at the normal operating height of 45 feet above ground level, the maximum level at 5 feet above the ground is 124 dB(C) which occurs about 200 feet from the siren.

6. If the siren is activated at the 25 foot height, it will be in the process of being elevated to 45 feet. The siren elevates from 25 feet to 45 feet in less than 60 seconds. As the siren elevates,- the sound pressure levels on the ground decreace (e.g., the uound pressure level at 90 feet from the ciren decrcases from 131 dB(C) to 122 dB(C) and the sound pressure level at 200 feet decreases from 127.5 dB(C) to 124 dB(C); in less than 60 seconds).

Basis A.8: Sound Irregularities

7. In respor.se to Interrogatory No. 25,2 the Attorney General further defined gaps in sound coverage as nulls or "irregularities where the sound emitted by one speaker 2 "Massachusetts Attorney General's Response to First Set of In*1rrogatories Regarding the Massachuse' cts Attorney General's Amended Contention on Notification System," dated July 12, 1988.

_ _ _ . - . _ _ _ _ _ _ _ _ _ _ . _ _ _ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __ . __ a

i O

effectively cancels out the sound emitted from another speaker." The Attorney General goes on to claim that "with a t multiple speaker system like the multicellular device to be

[ implemented by the Applicants, acoustical interference among ,

the various speakers will result in a high degree of sound -

irregularity." In this response the Attorney General further states that "the likelihood of an acoustic null, where there is a total absence of output to the listener, is greatest

< where two loudspeakers are used, sucr. as the *,

system proposed for the VANS vehicles." <

8. Irregularities due to sound cancellation are theoretically possible only for stationary, pure tone, point sources in a laboratory environment.
9. For the dual siren system, which is

-4 a real, non-idealized sourc? of finite size; the theoretical difference between interference nulls and peaks (i.e., sound irregularity) is far less than for idealized point sources.

In real world applications even this theoretical acoustic .

phenomenon is overcome by atmospheric effects at typical listening distances. Therefore, this effect is practically ,

speaking not significant for the Seabrook siren system nor was it observed during testing of the siron. ,

10. Fu rthe rmore , for a rotating siren such as the dual ,.

system, angular irregularities are immaterial. As - __L the siren r2talfa, a listener at any point in space will >

J experience a varying sound level ranging from a maximum value ,

- 0 D

that occurs when the siren is pointing generally in his or her direction to a minimum value that occurs when the ciren is pointing away. In between these two extremes, the sound level at typical listening distances will vary in a complex way, depending more on atmospheric turbulence than on the

presence of interference puaks and nulls. Thus, angular irregularities in sound emission that may occur close to a siren have no relevance to the effective siren coverage of a rotating siren. No "gaps in the coverage" of ti
a dual sirens are anticipated since, due to rotation, they will each be capable of radiating a broad siren tone pattern whose axis of symmetry slowly rotates over 360 degrees ensuring coverage at all anglas. Furthermore, the Mass AG withdrew,3 ir. response to Interrogatory No. 27, the assertion that "the oscillation of the speaker assembly will cause gaps in coverage when the siren is used in its tonc alert mode."

3 "Massachusetts attorney Goncral's Response to First Set of Interrogatories Regarding the Massachusetts Attorney General's Amended Contention on Notification System," dated July 12, 1988.

1 -- _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _____ _ _ _ _ _ _ _ _ _ _ _

~ ^

's ,we s sLk < * *. g_ g.ao;lesJ4 FH;

  • A*"rM61 y 423 7841 + 08096 >3 i 97 gg 15 ,33 15: 35 PcE5 3 @M l f/fx.

couis c. sutgerland

/

STATE OF CALITORNIA Los Angeles, ss.

September 6, 1988 me and made oath that he had read ethe his knuviedge.ti.et the statements set forth therein are truand ore foregoing affida e to the best of Before me, fn. _ _ _

d O F F ICl ?. ' S F. A l ) '

,/

MARY D M -s y e' nouw rosu:C cmronAGOVERN

',4 h/

/ - Iw .

. /ly 4..-, 4 /' /

/

w v_v' -vi!Nm -> !UeNc3.1990

< W

[ Notary Publio Zm.<^ -'

Hy Commission Expirest y < <.

/,  ?'d i

s*s

Sutherland Attachment A, 1 of 1 Tj ..

1.0U!$ C. SUT11ERLAND ,,

POSITION: Depaty Olractor and Chief $clentist SolNED WYLE: 1964 Af PRINCIPAL DUDE 5 AhJ RESPONSIE!LITIES: .--

Overall technical direction of Wyle Research, providing soecific technh:a! guidance C '-

and consulting in applied acoustics, env!Jonmental noise, and noise control. D.

BACKGROUND: ,

i Wyle Laboratories, El Segundo, CA. Research and consulting in the evaluation, E prediction, and measure. mnt of community ar.d aircraf t nobe, human resoonse to i noise, sound propagatM , structural dynamics, and related areas in the environ- ,

l meatal sciences. Prin:ijalInvestigator on diverse projects such as a pilot study for -

a national survey of eatdoor r'o'.se environments, cost 4ffect,vene&s evaluatlon of community noisa coemarmeasures, airport noise reductler6 at the nation's airports, -? ~ .

evaluatton af human response to impulse noise, measurement of sound absorption in -

air, vibroacoustics of space vehicle structures, and psychoacoustic studies for '

response of humans to low-frequency noise and vibration. Editor for a comprehen-sive engineering desl6n manual for NASA on sonic and vibration env! onment problems for ground faellities. .s.

. e The Boeing Company, Seattle, WA (9 years) - ResearrA Specialist, Acoustice and -

Vibration Groupt Technical supervisor on all aceJstic and vibration env!ionment .?

problems for Dyna-Soar, Saturn C-5, and high acceluration booster concepts (H1-Bex). Acoustic modeling and development of B 32 Jet engine noise suppressor. ,.z r

University of Washingtcn, Department of Speech, Seattle, WA ($ years) - Research Engineer. Design of electroacoustic equipment used in speech and hearing research i anc testing.

EDUCATION:

M.S., Electrical Engineering, Univeralty of Weahington,1934. .~.

5.5., Electrical Engineering, University of Washington,1946 .y Post Graduate $tudies, University of Loughborough. ,

PROFESSIONAL MEMBERSHIP 5:

Acoustical Society of America (Fellow), Member of $12 Working Grcup on Sound eae Propagations Chairman 12 9 Committee on Annoyance Responw to impulsive -

Noise.

Institute of Electt: cal and Electronks Engineers, Acoustics, Speech, and Signal -

Processing Society.

American Institute of Aeronautics and Astronautics '

Society of Automotive Engineers, A-21 Commlttee on Alrcraf t Noise; Co-Chaltman, 5 Nolse Metrlca Subcommittee .

U.S. Representative,150 Worktr.g Group on Sound Propagation Registered Professional Engheer,5 tate of California Member,instituse nf Notse Control Engineering PUBLICATIONS:

Over 100 technical papers, reports, and presentations M

y. ,

.t)- , i 00(Kriu' UWC U

'88 SEP 22 P5 :36 September 17, 1988 0Fn.t . .tro '

UNITED $hTE;SslOFjASERIC1.

NUCLEAR REGULATORY CCNISSION before the ATOMIC SA}ETY AND LICENSING BOARD o

)

In the Matter of ) '

)

PUBLIC SERVICE COMPANY OF ) Dockot Nos. 50-443-OL-1 NEW HAMPCHIRE, et al. ) 50-444-OL-1

) (On-Site Emergency (Seabrook Station, Itnits 1 and 2) ) Planning and Cafety

, ) Issues)

)

CERTIFICATE OF SERVICE I, 7effrey P. Trout, onc of the attorneys for the r Applica,7ts herein, hereby certify that on September 17, 1988, I made service of the documents listed below by depositir.g copies thereof with Federal Express, prepaid, for delivery to (or where ir. dica?.ed, by dr. positing in the United States m'il, first class postage paid, addressed to) the individuals listed below:

1. Applicants' Motion for Summary Disposition on Ainended Contentien on Notification System of Attorney General far the Commonwealth of Massachusetts;
2. Memorandum in Support of Applicants' Motion for Sunmary Disposition or. Amended Contention on Notification System of Atto'cney General for the Commonwealth of Massachusetts;
3. Statement of Material Facts Not in Dispute;
4. Affidavit of Travis N. Beard;
5. Aff' davit of Sebastian N. Caruso;

~-. - - - _ , . _ , , , , _ . , _ _

_n- -- -

4 <

')

6. Affidavit of Gary J. Cataphno;
7. Affidavit of Edward W. Desmarias; f 8. Affidavit of Richard J. Faix;
9. Affidavit of Georga A. HLtper;
10. Affidavit of Lawrence M. Jacobson;
11. Affidavit of Donald Ee Johnson;
12. Affidavit of David N. Keast;
13. Affidavit of Edward G. Lieberman;
14. Affidavit of Joseph Story II;
15. Affidavit of Eric Stustsick; ar.d
16. Affidavit of Louis C. Sutherland.

Administrative Judga Sholdon J. Robert Carrigg, Cha trtan Wolfe, Esq., Chairman, Atomic Board of Selectmen Safety and Licensing Board Panel Town Office U.S. N Jclear Regulator;' Atluntic Avenue Comaission .

North Hampton, NH OJS62 East West Towers Bull. ding 4350 .fest West Highwcy Bethonda, MD 20814 Administrative Judge Emuteth A. Diane Curran, Esquire Luebke Andrea C. Ferster, Esquire 4515 Willard Avenue Hai' mon & Welus

, Chevy Chase, MD 20815 Suits 430 2001 8 Street, N.W.

Washington, DC 20009 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing AttcIney General Board Panel Georgo Dana Bisbee U.S. Nuclear Regulatory Assistant Atto~ney t General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway concord, NM 03301-6597 Bethesda, MD 20814 E

(;

e

A 9

Adjudicatory File Sherwin F. Turk, Esquite Atomic Safety and Licensing Office of General Counsel Board Pancl Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regalatory Coumis91on Commission One White Flint Norr.h, 15th Fl.

East West Towars Building 11555 Rockville Pike 4350 East West Highway Rockville, MD 10852 Scthesda, MD 20814

  • Atomic Safety and Licensing Robert A. Bcckus, Esquire Appeal 20ard Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 2 055 c' Manchester, NH 03105 Philip Ahrense Esquire Mr. J. P. Nadeau Assistarit Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Matthow T. Brcck, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02108 ,

Portsmouth, NH 03801 Mrs. Sandra Gav9 tis Mr. Calvin A. Canney Chairman, Board of Selectinen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Strast Konsington, NH 03827 Portsmouth, NH 03801

  • Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagonlis, Clark, Hill-Whil. ton &

Washington, DC 20510 McQuire (Attn: Tom Burack) 70 State Street Newburyport, MA 01950

  • Senator Gordon J. Ilumphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor Concord. NH 03301 City Hall (Attn: Harb Boynton) Newburyport, MA 01950 Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmon Town of Exeter Town Hall e Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833

-3 -

~

-?

H. Joseph Flynn, Esquire Charles P. Graham, Esquire Office of General Counsel Murphy and Graham rederal Emergency Management 33 Low Street Agency Newburyport, MA C1950 500 C Street, S.W.

Washinge.on, DC 20472 Gary W. Holmes, Esquire Richard A. Hampa, Esquire Holmes & Ells Hampe ar.d McNicholas 4? Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 C o n e .e r d , NH 03301 Mr. Richard R. Donovan Judith H. Mizner, Esquire Federal Emergency Management 79 State Street Agency Second Floor Federal Regional Center Newburyport, MA 01950 130 228th Strect, S.W.

Bothell, WA 98021-9796

~

,1 h  ;. . ...

?lfne o 1%l' Jeffrp? P. Trout

(*=0rdinary U.S. First Class Mail.)

_ _ _ _

Retrieved from "https://kanterella.com/w/index.php?title=ML20154L501&oldid=2952181"