ML20155H449
| ML20155H449 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/11/1988 |
| From: | Bouliane T CAVANAUGH TOCCI ASSOCIATES, INC., MASSACHUSETTS, COMMONWEALTH OF |
| To: | |
| Shared Package | |
| ML20155H431 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 OL-1, NUDOCS 8810200198 | |
| Download: ML20155H449 (39) | |
Text
{{#Wiki_filter:, _ _. _ ____ _-__________ i 4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: Sheldon J. Wolfe, Chairman Emmeth A. Luebke Dr. Jerry Harbour
)
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket No.(s) NEW HAMPSHIRE, ET AL. ) 50-443/444-OL-1 (Seabrook Station, Units 1 and 2) ) On-site EP
) October 11, 1988
)
b EEI RAVJI_QE_ Ilio MA S_G_ JD U_LlAt1 E I, Thomas G. Bouliane, being under oath, depose and say as follows:
- 1. I am a Principal Consultant at Cavanaugh Tocci Associates, Inc., an acoustical coi.sultino firm in Sudbury, Massachusetts. A statement of my professional qualifications is attached hereto as Appendix 1. The acoustic analysis set forth in this affidavit was done by me under the guidance and review of Gregory C. Tocci, the president of Cavanaugh Tocci Associates, Inc. A statement of his professional qualifications is attached hereto as Appendix la.
- 2. The purpose of this affidavit it to address issues raised in the September 17, 1988 affidavits of Messrs. Faix, h$k SOO h3 0
G O Keast, Kryter, and Sutherland regarding New Hampshire Yankee's public alert and notification system and its ability to meet the design objectives described in NUREG-0654, FEMA-REP-1, Rev. 1 "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," and FEMA-REP-10 "Guide for the Evaluation vf Alert and Notification Systems for Nuclear Power Plants." D as i s_A ,.1 : Siten_CQzarJ:ute B asis _A,.B : S.ond__Ineg ulailli.es
- 3. New Hampshire Yankee has described the siren loudspeakers to be employed in the Massachusetts portion of the Seabrook Station EPZ.(1,2)
NOTE: All references are noted in Appendix 2, attached.
- 4. Mr. Sutherland, describing the performance of these siren loudspeakers, states:
"No ' gaps in the coverage' of the dual (deletion) sirens are anticipated since, due to rotation, they will eacn be capable of radiating a broad siren tone pattern whose axis of symmetry slowly rotates over 360 degrees ensuring coverage at all angles."(3)
- 5. Sutherland does, however, indicate that some variation l
i in siren coverage will occur:
"As t he s i r en colates , a listener at any point in spece will experience a varying sound level ranging from a maximum value that occurs when the siten is pointing generally in his or her direction to a minimum value that occurs when the siren is pointing away."[4] [ Emphasis in the original)
- 6. Wyle Laboratories made rudimentary measurements of this siren loudspeaker to determine its directional characteristics ir. the horizontal plane.[5] The data from three measurements are shown in Wyle Test Report 88-10(R), Figure 3 and are used in Table 7 {6,7]:
Listen _ Angle Sirsn_Angla D_LQela1 0.000 00 0.0 dB 11.250 00 - 4.7 dB 22.500 00 -11.3 dB
- 7. Wyle extended this limited information mathematically to estimate the horizontal distribution of the loudspeaker's siten signal output over angles beyond those measured.(8)
- 8. Cavanaugh Tocci Associates, Inc. (CTA) illustrates the Wyle loudspeaker directivity estimate in more conventional "polar" form in its Drawing 1.{9, attached hereto as Appendix
- 3) This drawing sets the loudspeaker's primary output axis to 0
0 and the maximum output to O dB and shows the level variations which occur as the observer moves to either side of the primary axis: klatener Angle Relallye Leyc1 0.000 0 dB , 11.250 - 4.7 dB 22.500 -11.3 dB ; 33.750 -16 dB 45.000 -19 dB 56.250 -21 dB 67.500 -23 dB 78.750 -25 dB 90.C00 -26 dB 3 -
O
- 9. It is apparent from CTA Drawing 1 that the siren loudspeaker has definite directional characteristics; that the loudspeaker produces its maximum signal output along its primary output axis (0 ) and that the loudspeaker's output diminishes as the angular offset from the primary axis increases.
- 10. New Hampshire Yankee also states that the VANS sirens are to oscillate back and forth through 360U arcs during their operation.(10)
- 11. Dr. Kryter describes twc siren systems (11), one of which Keast confirms (12) is the sireg New Hampshire Yankee proposes for use in the (Massachusetts) VANS portion of the i
public alert and notification system. Kryter's description defines the Massachusetts VANS siren oscillation rate at 2.5 times per minute.
- 12. The siren levels heard by the Massachusetts populace will be influenced as shown in CTA Drawing 2 (13, attached as Appendix 4} when the sirens are oscillated as described by New Hampshire Yankee and Kryter. This drawing show: .no relative signal levels which will be distributed to listeners who are situated at angles offset by 0 , 45 ,900, 135 , and
- 180 from the siren's stop position. The maximum signal level the listeners will receive when in alignment with the siren's primary output axis is shown as "REF." The signal level variations over time resulting from the siren's directional output pattern are also shown.
-4 -
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- 13. New Hampshire Yankee has submitted a map showing the alert and notification system siren coverage they expect in Massachusetts.[14]
- 14. The 60 dB(C) and 70 dB(C) siren _ overage contours shown on the New Hampshire Yankee map are seen to be generally circular. The variations shown relate only to barrier effects caused by changing ground elevations. !
- 15. A siren's signal output can extend to the coverage circles shown on the map only along the siren's primary output axis as shown on CTA Drawing 1. Since the sirens oscillate 0
about 360 arcs, the circular shapes on the map can only represent the siren outputs over all angular positions of oscillation when considered simultaneously. Since the sirens cannot be in all positions at once, the map misrepresents the siren coverage at any given time.
- 16. The sum of coverage resulting from all VANS sirens operating concurrently will, in fact, vary randomly over time due to the directional characteristics of the loudspeakers in combination with inevitable differences in VANS vehicle orientation and siren stop positions, and the differences in siren starting times and rates of siren oscillation among vehicles. The siren c0verage to be expected at any given time is better represented on CTA Drawings 3 and 4.(15,16 attached as Appendices 5 and 6]. These drawings rotate siren primary output axes randomly and superimpose the resulting siren coverage patterns over the New Hampshire Yankee map.
- 17. Since the 60 dB(C) and 70 dB(C) levels shown as circular patterns on New Ha?pshire Yankee's map can be achieved only along the siren primary output axes, and since off-axis siren levels diminish by 26 dB during oscillation, it follows that the siren levels heard by listeners will often drop to as little as 34 dD(C) and 44 dD(C) respectively. The sirens will in fact achieve the r2 quired 60 dB(C) and 70 dB(C) levels at locations on the map contours only during the brief periods illustrated on CTA Drawing 2 where the curve meets the "REF" level; signal levels will be less at all other times.
- 18. The public alert and notification system proposed by -
New Hampshire Yankee for use in Massachusetts appears therefore not to meet the NUREG-0654, FEMA-rep-1, Rev. I requirement that
"(t]he siren signal shall be a 3 to 5 minute steady signel...."[17]
- 19. Further, the proposed system appears not to meet the FEMA-rep-10 requirement that "... (t]he expected siren sound pressure level generally exceeds 70 dBC where the population exceeds 2,000 persons per square mile and 60 dBC ir. other inhabited areas."(18]
Basis A.7: Maximum permissible Sound Levels
- 20. Sutherland, the Chief Scientist of Wyle Research and i
apparently relying on data from various Wyle Laboratories reports, states that: 6-
l l
. i
"...I have determined that with the siren 25 feet above ground level, the maximum sound level at 5 feet above the around (i.e., at ear level) is 131 dB(C) which occurs about 90 feet from the siren.
With the siren 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."(19]
- 21. Sutherland reiterates his remarks by saying:
"As the siren elevates, the sound pressure levels on the ground decrease (e.g., the sound pressure level at 90 feet from the siren decreases from 4
'31 dB(C) to 122 dB(C) and the sound pressure level at 200 feet decreases from 127.5 dB(C) to 124 dB(C)...."[20]
- 22. Wyle Laboratories acknowledges that only "(a] small amount of data relating to the vertical directivity of the siren is presented..."(21]
- 23. Notwithstanding the limitations of their measurements, Wyle uses this data and another set of data:
...to provide the illustration of the 123dB(C) sound envelope shown in Figure 4 (22] which identifies the contour in a vertical plane of the manimum level to whicn people near the siren would be exposed."(23]
- 24. The limited siren loudspeaker information W'fle presents in its test reports, the only information available describing the performance characteristics of Nevi Hampshire Yankee's proposed siten, is insufficient to draw firm conclusions as tc its directional properties or the siren ,
levels to which nearby listeners will be exposed. Wyle's presentation is in broad variance with the recommendations of the Audio Engineering Society and the American flational
Standards Institute (24, attached as Appendix 7] which describe the r;tui.ements for clear, unambiguous reportage of loudspeaker performance.
- 25. Faix repvrts that:
"There are structures located less than 100 feet from each of the t'ao acoustic locations that are co-located at the VAN staging areas.
These structures are part of their respective staging areas. Provisions will be made by New Hampshire Yankee to inform people in these structures prior to siren activation."(2s]
- 26. Faix does not report that the VANS will be parked in close proximity to private residences during their operation:
VANC Nearest L2 cation Residence (approximate) VL3 180 ft. VL4 300 ft. VL12 250 ft. VL13 180 ft. VLl65 150 ft. I made these approximate measurements when I visited the locations on October 3, 1988.
- 27. The siren sound which reflects from these buildings will sum with the sound arriving directly from the VANS sirens to elevate the listener levels near the buildings by as much as an additional 3 dB.
- 28. Based upon Wyle Laboratories' reported 9:ximum siren sound level of 134 dB at 100 ft. and the level losses resulting from geometric spreading alone, I estimate that siren levels in proximity to nearby residences will be as great as 133 dB when building reflection effects are taken into account.
- 29. Gales, in the Handb.q9)Lof Noise Control, a standard reference work in the field of acoustics, defines the threshold of listener discomrort caused by sound pressure levels as 120 dB. lie f u rther shows that sound levels in the region of 120 dB to .140 dB can be literally felt as tactile sensations.[26]
Appendix 8 is Figure 8.2 from Gale's book depicting the discomfort threshold.
- 30. My estimate of 133 dB listener levels substantially surpasses Gale's 120 dB threshold of discomfort and leads to che conclusion that the public alert and notification system proposed by New Hampshire Yankee for.use in Massachusetts will not meet the NUREG-0654, FEMA-REP-1, Rev. 1 requirement that
"[t}he maximum sound levels received by any member of the public should be lower than 123 dB, the level which may cause discomfort to individuals."(27]
- 31. If it is assumed that the sirens should operate at 123 dB at 100 feet, the extent of sound coverage in the Massachusetts EpZ is significantly diminished from that which would occur with New Hampshire Yankee's assumed output of 134 dB at 100 feet. Appendices 9 and 10 are maps depicting the extent of coverage at 123dB at 100 feet for 60 dB and 70 dB coverage, respectively.
- 32. On July 25, 1938, I visited the Seabrook Station premises and observed the setup procedure of a prototype VANS truck. Appendices 11 and 12 are photographs of the truck with 9 -
i its outriggers extended and Appendix 13 is a photograph of the instructions for crane operation on the VANS truck prototype. i'
\ #
) ' a Thomas /G #/ Bouliane The above-subscribed Thomas G. Bouliane appeared before me and made oath that he had read the foregoing affidavit and that the statements set forth therein are true to the best of his kr.ow l ed g e .
i., /# t ~ < .s No'tary Public My Commission Expires: ' ~~ f l 10 -
l l 4 1 Bouliane Affidavit Appendices 5, 6, 9, and 10 Contain Information Covered By Protective Order 1 And Have Been Provided Only To The Board, The ! NRC Sta:f And The Applicants i ,I l,
Acpsr i . THOMAS G. BOULIANE Principal Consultant Cavanaugh Tocci Associates, Inc 327F Bosten Post Road Sudbury, Massachusetts 01776 (508) 443-7871 Education: State University of New York at Buffalo, physics and mechanical engineering, 1960-1963 Professional Employment: 1974-1980 Seneca Sound, Inc. Tenawanda, New York 1980-1982 Audio Contractors, Inc. Buffalo, New York 1982-1983 Cramer Video, Inc. Needham Heights, Massachusetts 1983-1988 Sesco, Inc. ! Boston, Massachusetts 1988-Pres. Cavanaugh Tocci Associates, Inc. . Sudbury, Massachusetts Professional Memberships: National Council of Acoustical Consultants Acoustical Society of America , Audio Engineering Society ; National Sound & Communications Association Construction Specifications Instituto Professional Papers: "A Calculator Progran for Predicting Sound Syste.- Performance," presented at the 70th Convention Of the Audio Engineering Society, New York, 1991 "Intelligibility Mapping through Array Ferspecti.'e ' Analysis," presented at the 72nd Convention of tne Audio Engirieering Society, Los Angeles, 1932 Professional Article: "Calculating Sound System Performance," Souni inj Corrunications, March 1982 Relevent Projects: Mosque of the Holy Prophet, Medina, Saudi Aracia { Speech reinforcement and minaret sound syste- , Holy Haram, Mecca, Saudi Arabia Speech reinforcement and minaret sound syste-m
Appendix la GRE'JC RY C . TOCCI Education: Tufts University, 3.S., 1970 Massachusetts Institute of Technology, M.S., 1972 Professional Member, Acoustical Society of America Affiliations: Past Cha i rma n , Greater Besten Chapter of the Acoustical Scciety of America President, National Council Of Accustical Consultants Member, Institute of Noise Control Engineering Member, American Society cf Heating, Refrigerating and Air COnditiening Engineers Editorial Advisory Scard, Noise C : r t r '. Enqineerinc Journal Registration: Professional Engineer in Massachusetts Civic: Member, Board of Trustees Mentrose School, Westwood, MA Faculty Adjunct Faculty Pesitions: New England Sch0ol of Art and Design { 1979 - 1937 . Guest f.ecturer Harvard School of Public Health 1933 - Present Experience: Summers 1966, 67, 68 Alonzo 3. Reed Inc. HVAC System Cesigner/Draf tsman l While attending Tufts University, Mr. Tocci worked as an HVAC System Designer /Craf tsman and was respcnsible for the preparation of building project drawings for a nunber of educati0nal and cc :ercial office buildings. June 1970 - August 1971 U.S. Army Materials and Mechanics { Research Laboratory Mechanical Engineer Mr. Tecci was involved with the analysis of tne ballistic impact properties of fabrics. His werk involved ballistic test design and theoreti;3. and numerical analysis of ballistic /farr;; impacts. September 1971 - February 1973 Massachusetts :nstituta of Techn010sy Research Assistant L I7
, .. ,, . __ =. . . .= .-
While earning a Masters of Scienc e Degree a: :ne Massachusetts Institute of Techno1cgy, Mr. Tec : was awarded a research assistarr. ship in the Acoustics laboratory of the' Mechanical ! Engineering Department. His research activities > were supported by the National Science-Foundati0n ; and involved exploring the use of geometric l acoustics in architectural flanking sound transmission problems and the use of aut; correlation for measuring sound absorptive properties of surfaces. February 1973 - December 1974 k Cambridge Collaborative, Inc. Staff Consultant t While with Cambridge Collaborative, Mr. Tocci assisted in several engineering research projects in the transportation and industrial accustics areas. Among the programs in which he provided ; assistance area state-of-the-art evaluation of
- floating slab techniques for structureborne sound '
isolation of rail transit lines, assess =ent of sound radiation from elevated rail structures, and noise control for a commercial newspaper I i folding machine. Mr. Tocci's respot.oibilities included designing L and =anaging acoustical measurement pr grams and l assisting in data analysis and report preparation. , l January 1975 - August 1975 i Cavanaugh Copley Associates , Staff Consultant 1 Cavanaugh copley Associates was a joint venture between two individual consultants. Mr. Tec t
- was employed to manage all technical and i financial aspects of projects awarded to the l
- partnership. Among the projects in which he was [
involved were the preparation of an environmental ' l J impact statement for the Interstate 93 extensien
- through Franconia Notch, NH the environmental impact report for the extension of the MBTA
! t Crange Line to Reading, MA, and mechanical system I noise and vibration control for the University cf a Minnesota Health Science Expansion. ! J [ j September 1975 - Present i i Cavanaugh Tecci Associates, Inc. ; Fresident/ Principal Consultant i 4 l 1 , l l l . - - - - . [
m 9 Mr. Tocci and Mr. William J. Cavanaugh, after the disassociation of Cavanaugh Copley Associates, joined together to form Cavanaugh Tccci Associates in September 1975. Since this time, the firm has provided engineering consulting in a wide range of architectural, environmental, and industrial acoustics projects. Besides having full responsibility for all technical aspects and communications concerning projects, Mr. Tecci manages all business matters for Cavanaugh Tccci Associates, Inc. Among the variety of projects which he has managed are the following: Codex Corporation Headquarters canton, MA (General office Building, Mechanical System Noise and Vibration Studies) Animal Research Facilities Massachusetts Institute of Technology Cambridge, MA (Provided construction noise impact assessment for audiogenic seizure prone laboratory animals) Miscellaneous studies for compliance with HUD Site Acceptability Standards for residential construction i MBTA Track Rehabilitation Program Boston, MA (Noise and vibration impact analysis and recommendations for track rehabilitation en ) 40% of the MBTA system) Seven Schools Noise Abatement Program 4 Logan International Airport, Boston, MA (The development of noise centrol recommendations and review of design, shop drawings, and installation of glazing and other treatments for schools affected by 1 aircraft noise) Construction Noise and Vibration Contr:1 Studies MBTA Red Line Extension Northwest, Besten, MA (Development of recommendations for controlling construction noise as required by the MBTA Construction Noise Control J Specification in the project documents) James River Graphics Hadley, MA (Ceveloped rec 0mmendations for the 0:ntr:1 Of ) noise and vibration needed to reduce c:ating chatter) L.l:
Lecture Presentations: Among the presentations he has made to socie:, and corporate groups are the following:
"Fundamentals of Glazing Sound Isolation and Product line Review" January 27, 1388 Fullerton, CA "Design Concepts for Sound Isolation Glazing" California Association of Window Manufacturers June 12, 1987 Sacramento, CA "Glazing Products and Sound Isolation Perf ormance" EFCO Corporation Engineering Staff Seminar June 11, 1987 Monet, MO Glazing Sound Transmission Loss Studies Paper 07, 111th meeting of the Acoustical Society of America May 14, 1987 Cleveland, OH "Topics in Rooftop Mechanical System Vibration Isolation" Boston Chapter /American Society of Heating, Refrigerating and Air Conditioning Engineers January 28, 1987 Medford, MA "Concepts in Speecn Privacy" GF Business Equipment National Meeting of General Managers July 26, 1983 Youngstown, OH "Open Plan Speech Privacy Analysis" Philadelphia Electric Company Facilities Department February 9, 1983 Philadelphia, PA "Wind Farm No taa" Paper A8, 101 meeting of the Acoustical Society of America M0y 19, 1981 Ottawa, Ontario, Canada "Protecting Ha rva rd "niversity Suildings fr:m Construction Noise" Paper JJ10, 99th meeting O f the Acoustical Society of America April 25, 1980 Atlanta, OA L IJ
"Construction Noise Control for a Major U r b a .-
Rai.'. Rapid Transit Line Extension" Paptr P7, 98th meeting of the Acoustical Society of America November 29, 1979 Salt Lake City, Utah General Electric Company Plant Manager Seminar Harvard School of Public Health June 28, 1979 Boston, MA 02115 "Acoustic Modeling of 'Close-Proximity' Rai Transit Noise Barriers" Paper DDS, 94th meeting of the Acoustical Society of America December 15, 1977 Miami, FL US Department of Health Education Welfare Prcgram Tufts University November 4, 1976 Medford, MA "Noise Prepagation in Corridors" Paper D9, 83rd Meeting of the Acoustical Society of America April 9, 1972 Buffalo, NY Publications: "A Comparison of STC and EWR for Rating Gla: ng Noise Reduction," Gregory C. Tocci, Sound and Vibratiqn, V.21, No. 10, October 1987.
"Monsanto Accustical Gla ing Design Guide" Monsanto Polymer and Chemical Co., St. Louis, MO "Acoustic Performance of a 're-entrant' Axial Fan Intake Silencer" Gregory C. Tocci and Douglas H. Stur:
Noise C.qn U Ereceedinos Cambridge, MA "A Parametric Evaluation of Wind Turbine Noise" Gregory C. Tecci and Edward N. Marcus Internoise 12 Proceedinos San Francisco, CA "Practical Applications of outdcor Noise Contr:1 Barriars" Gregory C. Tocci and William H. Pickett Sound and Vibration, V13, No.6, June 1973 (Selected for the Vibraphonic Award for best paper published in Sound and Vibration in 1??3 cy Celawars Chapter of the Acoustical Scciety :f America L I:7
i "Paper Cutting Noise: Source Identifica icn i Techniques in' Newspaper Folding Machines" Jeffery Fredberg and Gregory Tocci Internoise la Proceedinas Washington, DC l
"Measurement and analysis of noise radiation from a slab on steel beam rapid transit structure" i Gregory Tocci, Jeffery Fredberg, and Nagabhusan Senapati Znternoise 21 Proceedines Washington, DC "Ballistic Impact of Textile Structures" I David Roylance, Anthony Wilde, and Gregory Tocci Textile Research Journal, Volume 43, Number 1, i January 1973 '
Personal: Mr. Tocci resides in Franklin, MA with his wife, Colleen M. (McHugh) Tocci, RN and their four a children. i i 1 ' l } 4 ) I t i I I
g - Appendix 2 SFIERERCES (1) New Hampshire Yankee FEMA-REP-10 Design Report, pp. 2-14 througnt 2-16. (2) Ibid., lable -1, pp. 2-31 through 2-33. [3] Sutherland, Affidavt, September 17, 1988, p. 5. [4] Ibid., p. 4 (5) Wyle Laboratories Test Report 88-10(R), "Measurement of Speech Intelligibility Range of the WS 4000 Electronic Siren," April 1988, p. 3. [6] Ibid., "Directivity of WS 4000 Electronic Siren at a Frequency of 550 Hz in th's Horizontal Plane," Fig. 3, p. 18. [7] Ibid., "Coverage of WS 4000 Siren (Dual) for speech at Various Distances and Listener Angles," Table 7,
- p. 14.
[8] Ibid., "Directivity. . ., " Fig. 3, p. 18. [9] Cavanaugh Toccit Associates, Inc., "Wheland Dual WS 4000 Loudspeaker Horizontal Output Distribution," Drawing 1, September 6, 1988. (10] New Hampshire Yankee, ibid., p. 2-16. [11] Kryter, Affidavit, September 17, 1988, pp. 3, 4. [12] Keast, Affidavit, September 17, 1988, p. 4. , (13] Cavanaugh Toccit Associates, Inc., "Siren Level ! Variatior.s Due to Rotation," Drawing 2, September 23, 1988. [14] New Hampshire Yankee, ibid., "Seabrook Station - Siren Coverage for the public Alert and Notification l System in Massachusetts," Fig. 2-2, p. 2-37. l l (15] C av anaugh *i'occi As socia tes , Inc., "Representative Siren Coverage, 60 dB Contours" Drawing 4, October 6, 1988.
(16) Cavanaugh Tocci Associates, Inc., "I.epresentative Siren Coverage, 70 dB Contours" Draving 4, October 6, 1988. (17) flUREG-0654, FEMA-REP-1, rEV. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of fluclea r Power Plants," p. 3-12.
, (18] FEMA-REP-10, "Guide for the Evaluation of Alert and flolification Systems for llaclear Power Plants,"
flovember 1985, p. E-8. (19] Sutherland, ibid., p. 3. [20] Ibia. l (21] Wyle Research Test Report 88-10(R), ibid., p. 3. l (22) Ibid., "Illustration nf the Approximate Envelope of the 123 dB(C) Sound Field for the WS 4000 (Dual) Siran," Figure 4, p. 19. [23) Ibid., p. 4. , [24} Audio Engineering Society, "AES Recommended Practice, Specification of Loudspeaker Components Used in Professional Audio and Sound Reinforcement," AES2-1984 (AtlSI S4.26-1984). [25] Faix, Affidavit, September 17, 1988, p. 4. [26) R. S. Gales, "Hearing Characteristics," Handborh_01 "O i s e CoJ11Lol, ed . C . M. Harris, Second Edition (tiew York: McGraw-Hill, 1979), "The auditory sensation area," Fig. 8.2, p. 8-4. [27) 11UREG-0654, FEMA-REP-1, Rev. 1, ibid., p. 3-8. i
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UNITED STATES OF AMERICA ~* NUCLEAR REGULATORY COMMISSION
'88 OCT 13 P2 :19
) GD t .
In the Matter of ) i;0D,! j ,
)
PUBLIC SERVICE COMPANY OF NEW ) Docket No.(s) HAMPSHIRE, et a_1. ) 50-443/444-OL-1
. (Seabrook Station, Units I und 2) ) (On-site EP)
)
____ ) CERTIFICATE OF SERVICE I, Stephen A. Jonas, hereby certify that on October 11, 1988, I made service of the within Answer of Massachusetts Attorney General in Opposition to Applicants' Motion for Summary Disposition of Amended Contention on Notification System, Statement of Material Facts in Dispute, and Affidavits of Stephen A. Jonas, Nancy A. Mason, and Thomas G. Boulf ne, by first class mail to the parties listed below. The Affidavits of Nancy A. Mason and Thomas G. Bouliane contain information covered by the Board's Protecti"e Order, i Full copies of tho affidavits and attachments thereto have been sent to the Board, the Applicants, the NRC Staff, and FEMA. Copies to the remaining individuals on the service list do not include Protective Order information. Sheldon J. Wolfe, Chairperson Dr. Emmoth A. Luebke 1110 Wimbledon Drive 5500 Friendship Boulevard McLean, VA 22101 Apartment 1923N Chevy Chase, MD 20815 Dr. Jerry Harbour Gregory Berry, Esq. Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Office of General Counsel Commission Washington, DC 20555 Washington, DC 20555
11 . Joseph Flynn, Esq. Stephen E. Merrill Assistant General Counsel Attorney General Office of General Counsel George Dana Bisbee Federal Emergency Management Assistant Attorney General Agency Office of the Attorney General 500 C Street, S.W. 25 Capitol Street Washington, DC 20472 Concord, NH 03301 Docketing and Service Paul A. Fritzsche, Esq. U.S. Nuclear Regulatory Office of the Public Advocate Commission State House Station 112 Washington, DC. 20555 Augusta, ME 04333 Roberta C. Pevear Ms. Diana P. Randall State Representative 70 Collins Street Town of flampton Falls Seabrook, Nil 03874 Drinkwater Road flampton Falls, Nil 03844 Atomic Safety & Licensing Robert A. Backus, Esq. Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P. O . Box 516 Washington, DC 20555 Manchester, NH 03106 Atomic Safety 0 Licensing Jane Doughty Board Panel Seacoast Anti-Pollution League U.F. Nuclear Regulatory 5 Market Street Commission Portsmouth, NH 03801 Washington, DC 20555 Matthew T. Brock, Esq. Mr. J. P. Nadeau Shaines & McEachern Board of Selectmen 25 Maplewood Avenue 10 Central Road P.O. Box 360 Rye, NH 03870 Portsmouth, NH 03801 Ms. Sandra Gavutis, Chairperson Mr. Calvin A. Canney , Beard of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street ' Kensington, NH 03827 Portsmouth, NH 03801 Senator Gordon J. Humphrey Mr. Angelo Machiros, Chairman U.S. Senate Board of Selectmen Washington, DC 20510 25 Hiah Road (Attn: Tom Burack) Newbury, MA 10950 Senator Gordon J. Humphrey Edward Molin 1 Eagle Square, Suite 507 Mayor Concord, Nil 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Donald E. Chick Mr. William Lord Town Manager Board of Celectmen Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03833 Amesbury, MA 01913
Brentwood Board of Selectmen Gary W. Holmes, Esq. RFD Dalton Road Holmes & Ellis Brentwood, !1H 03833 47 Winnacunnet Road llamp ton, 11H 03841 philip Ahrens, Esq. Diane Curran, Esq. Assistant Attorney General Harmon & Weiss Department of the Attorney Suite 430 General 2001 S Street, fl . W . State House Station #6 Washington, DC 20009 Augusta, MC 04333 Kathryn Selleck, Esq. Richard A. Hampe, Esq. Thomas C Dignan, Esq. Hampe & Mctlicholas Ropes & G*ay 35 Pleasant Street 225 FranL'in Street Concord, NH 03301 Boston, MA 02110 Beverly lloflingworth Ashad A. Amirian, Esq. 209 Winnacunnet Road 376 Main Street Hampton, !1H 03842 Haverhill, MA 01830 William Armstrong Michael Santosuosso, Chaitman Civil Defense Director Board of Selectmen Town of Exeter Jewell Street, RFD 2 10 Front Street South flampton, 11H 03827 Exeter, 11H 03833 Robert Cartigg, Chairman Anne E. Goodman, Chairperson Board of Selectmen Board of Selectmen Town Office 13-15 tiewmarket Road Atlantic Avenue Durham, 11H 03824 North Hampton, NH 03862 Allen Lampert Ivan W. Smith, Chairman Civil Defenae Director Atomic Safety and Licensing Town of Brentwood Bor.s4 Panel 20 Franklin Struet U.S. Nuclear Regulatory Commission Exeter, 11H 03833 Washington, DC 20555 Charles P. Graham, Esq. Judith H. Mizner, Esq. Murphy & Graham Lagoulis, Clark, Hill-Whilton 33 Low Street & McGuire Newburyport, MA 01950 79 State Street tiewbu r ypo r t , MA 01950 Sherwin Turk, Esq. Office of General Counse U.S. tiuclear Regulatory Commission Washington, DC 20555 1 m si i s i
t R. Scott flill-Whil&;n, Esq. Barbara A. St. Andre, Esq. Lagoulic: Cla r'n , liill-Whilton Kopelman & Paige, P.C.
& McGuire 77 Franklin Street 79 State Street Boston, MA 02110 tiewburyport, MA 01950 Sheldon J. Wolfe, Chairperson U.S. 11oclear Regulatory Commission Washington, DC 20555
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Stephen A. Jonas Assistant Attorney General Deputy Bureau Chief Public Protection Bureau Department of the Attorney General One Ashburton Place Boston, MA 02108 (617) 727-2200 1 Dated: October 11, 1988
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