ML20237E514
| ML20237E514 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/17/1987 |
| From: | Sutherland L PUBLIC SERVICE CO. OF NEW HAMPSHIRE, WYLE LABORATORIES |
| To: | |
| Shared Package | |
| ML20237E487 | List: |
| References | |
| OL-1, NUDOCS 8712290040 | |
| Download: ML20237E514 (15) | |
Text
_ _ - _ _ _ _ _ _
Dated: December 17, 1987
.e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of
)
)
Docket Nos. 50-443-OL-1 PUBLIC SERVICE COMPANY OF
)
50-444-OL-1 NEW HAMPSHIRE, et al.
)
On-Site Emergency
)
Planning issues (Seabrook Station, Units 1 and 2)
)
)
AFFIDAVIT OF LOUIS C. SUTHERLAND Louis C. Sutherland, being on oath, deposes and says as follows:
1.
I am Deputy Director and Principal Scientist at Wyle Laboratories, El Segundo, California. A statement of my professional qualifications is attached hereto.
2.
We have reviewed the affidavit of Gregory C. Tocci dated November 9,1987, and are providing the following response.
3.
The following addresses the use of a helicopter airborne notification system for the residents of Newburyport, Massachusetts in the event of a radiological emergency. Expected system performance is based on a design model that was validated by actual field data obtained near Seabrook Station on November 4th and 5th, 1987. The data provided verification and experimental determination of the following key system performance parameters:
Loudspeaker output at 100 f t and its directivity pattern Masking noise generated by helicopter in flight Voice levels on the ground during flyby Speech intelligibility in terms of modified rhyme test scores versus ratio,in decibels, of voice level to total masking noise level 4.
Table 1 details these parameters and compares them with the values referenced in the affidavit of Gregory C. Tocci (the "Tocci Affidavit"), dated November 9,1987.
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Table 1 Comparison of Airborne Alert and Notification System Parameters Tested by PSNH and as Assumed in the Affidavit of Gregory C. Tocci, dated 11/9/87 PSNH
Tocci Af fidavit --
Parameter System item Paragraph Aircraf t Type Helicopter Fixed Wing or Helicopter 2-9 Aircraf t Speed 40 mph 80 mph 3
/#
Aircraf t Altitude 500 f t 2,000-10,000 ft 3,4 Loudspeaker Model AEM 3150 watt Whelen WS-3000 2
Loudspeaker Axis 90 to lef t Along Flight Path 3
Direction re:
Flight Direction
-5 down
-90 down 3
/1
+ 28
/6
~
45 x 19.5 Coverage Angle 15, /2 1
I (121)l3 Loudspeaker Output Tone - 115 dB
@ 680 Hz Level at 100 f t Voice - 120 dB(A)
Area to be covered 4.6 sq. miles 8.3 sq. miles 4
Notes:
j 1) 1 28 = "3 dB down" coverage V angle in plane containing helicopter flight l
path and observer.
2) 2 15 = "3 dB down" coverage B angle in vertical plane containin6 speaker axis.
3) 121 dB implied by data in the Tocci Affidavit.
4)
Aircraf t altitudes for various loudspeaker orientations assumed in the Tocci Affidavit.
5)
The 115 dB level of the siren fundamental tone at 680 Hz corresponds to a C-weighted level of approximately 120 dB(C).
6)
Presumed coverage angles in two orthogonal planes through speaker axis according to Tocci's affidavit. - _ - _ _ _ _ _ _
3.
Based on the results of the verification tests conducted on Novernber 4th and 5th,1987, expected system performance can be summarized as follows.
6.
Since the loudspeaker array axis is aimed to the left of the helicopter path and slightly down (-5 ) from the horizontal, its coverage can be best defined in terms of the lateral width of the band to the left side of the helicopter for which the tone or voice signal exceeds a criterion level, and the duration for which this condition occurs. The expected system performance in terms of these parameters is listed in Table 2.
Table 2 Anticipated Performance of Airborne Alerting System as Tested Ambient Width of Level Criterion Level Exceeded Coverage Duration i
Signal dB(A) by Signal Band,ft sec.
i
/I Tone 60 70 dB(C) 2,700 26-40 (680 Hz) 50 60 dB(C) 4,900 32-76 Lnoise + 10 dB 2,700 18-80 I3
/
Voice 60 S/N 214 dB 2,700 25 *
/
4,900 25
- Message 50 Notes:
Range of signal duration for lateral positions at inner (lowest duration) 'I 1) and outer edge of coverage band.
2)
Average (ambient + helicopter) noise level (L,9) in 630 Hz one-third octave band.
3)
Signal-to-noise (S/N) ratio, in decibels, required to achieve 87 percent score in Modified Rhyme Test based on field measurements at Seabrook and corresponding 95 percent Intelligibility of Known x
Sentences based on ANSI S3.5.
)'
4)
Duration for two successive presentations of emergency message at outer edge of coverage band.
, I
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Based on fg performance sumrrarized in Table 2 and a helicopter ground
.7.
speed of 40 mph,9kthould be possible to cover the required area (4.6 square miles) within the City of Newburyport which is not already covered by the existing siren.
i.
i system, within about: 15 minutes. This time periodGpplies to the' flight path ' i
. scenario by a single helicopter for either a tone alert signal mr voice instructional message.
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8.
By using actual, rather,? nan assumed, PSNH Jystem design parameters, g 4
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conclusions different from thyo reached by Gregqv C. Tocci,in his Affidavit L
dated November 9,1987 are established.
x h'!'
m 9.
As utilized herein for Table 2, siren signalile.'ls ex6ed 60 dB(C) in low s.
4 s
Q3 dB(C)l n high density
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i density areas (less than 2,000 people per square mi i'
l areas (more than 2,000 people per square mile)., Th 's;ren signal levels ale' iso i
's i.
expected to provide a signal level ecra(.,to pr greaterQhan 10 dB above fe total
? masking noise in the one-third octave band containing the. siren tor.e.
This i/[ '
. expected perfornfelce is consistertt EIS FEMA requiremepu. in this. case, the i
total masking nch is the combinatijo of ambient.bac gro'tf d noise and the self-noise generateh h,Q7 el,1 copter propulsion system.
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level (i.e., the sound level exceeded 90% ot e!;ime) is
,e.
10.
ormalp, the L90 an accepted noie aescriptor for defining the my, king noise level in ths 90e-third
,e octave band containing the fundamental frequs,,cy for fixed sirens. For this case, L.
where the helicopter self4oise must,tiso be considered, the (energy) average noise t
level (L,q) of the combination' his'Leen employed to define the total masking noise
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of both the ambient background and the helicopter noise.
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~s Our analysis of the daytime amtient background noise levels.tnd helicopter self-noise levels indicates the follob g.
From a daytime ambient noise level 9
t measurement in the center of Nes.oyyport, where te population density can be expected to be highest, the (energy}uwk age daytimoise level (Lg) in the one-
!j
.y third octave band was abod50 dB. At the.nner edke of the coverage band (i.e.,
y J
800 ft from the ground trek) where the helicopter noise domind.es the masking
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,1 noise, the siren tone is expected to exceed the masking noise levgf by 10 dB or
[
. more for the minimum duration indicated in the last column in Table'2 and [also expected to exceed a level of 75 dB(C). At the outer edge of the covera [e band r
.b where the ambient' background noise tends to dminate the masking noise level, the I; \\ '
siren tone. is expected to exceed the 70 dB(C)lor 60 dB(C) criterion' levels for the maximuin durations indicated in the last column in Table 2.
At these! latter x,-
1 positiiss, the siren tone also shou $d exceed th'e 10 dB signal-to-noisicriterion for h
even longer periods.
12.
Aht:ordingly, the siren signal meets the signal level criterion based on: a conservogve interpretation of the 10 dB signal-to-noise ratio requirement, the yr
'vi.1 70 dB(C) si'ren level requirement.for/high density areas and the 60 dB(C) level requir~nent for low density aren.
\\,.,
13.
A huficated by FEMA-REP-10 { paragraph E.6.2.2), the system design report should include "... a discussion of lhow a vehicle's planned speed provides an d
effective signal duration toJalert~ the intended population..."
Based on our analysis of the expected tds alert pen'or'mynce of the airborne system defined in Table 2, the system is expected to be effective in alerting the intended population.
r 14.
The Tocc! Affidavity Paragraph 7, specifies required speech lpels in terms of C-weighted sound levels. The use of C-weighted levels is rqt ekiropriate when evaluating signal-to-noise ratio in decibels of speech sigriah and masking noise y levels for assessment of speech intelligibility. C-weighted levels do not properly accounk for the importance of frequency or pitch,stdrimination of the human ear.
This discrimination is a vital element in assessing intelligibd/ty.of speech in the t
presence of masking noise.
The intelligibility of speech; sounds is strongly 1
deperident on the mid-frequency range (i.e., 500-4000 Hz) which is more accurately
- )
-lt
's assessed with. the use of A-u.eighted speech le9els (in lieu ' f a more detalled c
s
[
spectruq(analysis often employedofor analyses of speech intelligibility under
~
laboratory conditions). The field tests of intelligibility of speehh signals that were n
conducted at the Seabrook plant on November 5,1987 successic!!y utillzed the signal-to-noise ratio of A-weighted sound levels as the hidependent partmeter which governed speech intelligibility.
! l b
s --
}
15.
At the outer edge of the land area covered by the loudspeaker, the speech I
signal level satisfies the criterion signal-to-noise ratio (i.e.,14 dB according to our actual field tests) for a period of 25 seconds, equal to twice the expected duration
.of the alerting message. At the inner edge of the band (i.e.,800 f t to the side), the 1 3:
signal exceeds the criterion.for approximately 13 seconds, long enough to hear all parts of the message one time. However, for this condition, the maximum speech je level is expected to reach a value corresponding to a signal-to-noise ratio of 19 dB, which is expected to compensate for the shorter duration. At a slightly greater sideline distance of 1100 f t, the signal-to-noise ratio exceeds the criterion level of i
14 dB for 25 seconds and reaches a maximum of about 22 dB.
16.
In paragraph 10 of Tocci's affidavit, the speech levels are again inappropri-l ately evaluated in terms of C-weighted levels, as discussed in paragraph 13 above.
l Furthermore, the estimated C-weighted helicopter sound. levels of 80 to 85 dB(C) at 2000 f t, in the frequency range of 250 to 4000 Hz, as cited in the affidavit, are not consistent with our own measurements. Our measurements of the helicopter sound levels, over a full frequency range of 20 to 8000 Hz, indicate that 60 dB(A) is a correct estimate for the A-weighted sound level of the helicopter at a slant range of 2000 f t. The corresponding C-weighted level would be about 70 dB(C).
\\
17.
In summary, the field tests of the airborne alert and notification system designed for use for the City of Newburyport has demonstrated that application of this technique should be able to satisfy the alert and notification system require-ments in NUREG 0654 and FEMA-REP-10 in the event of a radiological emergency.
9, stat T.ou' C. Sutherfand
/
STATE OF CALIFORNIA The above-mentioned Louis C. Sutherland appeared before me and made oath that he has read the foregoing affidavit and that the statements set forth therein are true to the best of his knowledge.
Before me,
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M4 9
Notary PMblic
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My Commission Expires:
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s _ -___-__-____-_-__ - _ _ _ - _ - _-_- _ -
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4,
i LOUIS C. SUTHERLAND POSITION:
Deputy Director and Principal Scientist 3OINED WYLE: 1964 PRINCIPAL DUTIES AND RESPONSIBILITIES:
Responsible for overall technical direction of Wyle Research, providing specific technical guidance and consulting in the areas.of community noise, aircraf t/ airport noise, applied vibroacoustic, psychoacoustics, electroacoustic, and noise control.
BACKGROUND:
Wyle Laboratories, El Segundo, California.
Engaged in research and consulting in the evaluation, prediction and measurement of community and aircraf t noise, human response to noise, sound propagation, struc-tural dynamics, and related areas in the environmental sciences. Principal investi-gator on diverse projects such as a pilot study for a national survey of outdoor noise environments, cost-effectiveness evaluation of community noise countermeasures, airport noise reduction at the nation's airports, evaluation of human response to impulse noise, measurement of sound absorption on air and review of community noise surveys. Editor for a comprehensive engineering design manual for NASA on sonic and vibration environment problems for ground facilities. Provided technical guidance and input to Research Staff effort on NASA research programs on vibroacoustic of space vehicle structure, sound propagation, and psychoacoustic studies for response of humans to low frequency noise and vibration.
The Boeing Company, Seattle, Washington, Research Specialist, Acoustics and Vibration Group - 9 years. Technical supervisor of small engineering group on all acoustic and vibration environment p)roblems for Dyna-Soar, Saturn C-5 and acceleration booster concepts (Hi-Bex. Other work included technical support for study of acoustic modeling techniques and for development of B-52 jet engine noise suppressor.
University of Washington, Department of Speech, Seattle, Washington - 5 years.
Research Engineer responsible for electroacoustic equipment used in speech and hearing research and testing, including design and construction of speech audiometer system for Children's Orthopedic Hospital.
University of Washington, Engineering Experiment Station, Seattle, Washington -
2 years. Research in experimental and theoretical program on heat transfer for a ground heat pump system.
EDUCATION:
University of Washington, M.S., Electrical Engineering,1954.
University of Washington, B.S., Electrical Engineering,1946.
Post-Graduate Studies, University of Loughborough.
M LASORA70m45
______________________a
9 LOUIS C. SUTHERLAND PROFESSIONAL MEMBERSHIPS:
Acoustical Society of America (Fellow), Member of SI-2 Committee on Sound Propagation; Chairman 12-9 Committee on Annoyance Response to Impulsive Noise Institute of Electrical and Electronics Engineers, ASSPS American Institute of Aeronautics and Astronautics Society of Automotive Engineers, A-21 Committee on Aircraf t Noise; Co-Chairman, Noise Metrics Subcommittee U. S. Representative, ISO Working Group on Sound Propagation Registered Professional Engineer, State of California PUBLICATIONS: Numerous Reports and Papers including:
" Sonic and Vibration Environments for Ground Facilities - A Design Manual." Wyle Research Report WR 68-2, March 1968. Editor and Principal Author.
" Fourier Spectra of Transient Excitations and Maximum Residual Response of an Undampened Single Degree of Freedom System - A Generalized Approach." Wyle Research TM 67-4, October 1968.
" Analysis of Hydraulic Exciters and Servo Amplifier Systems with Multiple Feedback Control Driving Complex Dynamic Loads." Wyle Laboratories Research Report WR 68-19, November 1968. Co-author.
" Preliminary Criteria for Internal Acoustic Environments of Orbiting Space Stations." Wyle Laboratories Research Technical Memo TM 69-2, May 1969. Co-author.
" Transportation Noise and Noise from Equipment Powered by Internal Combustion Engines."
U.S.
Environmental Prdection Agency, Report NTID300.13, December 31,1971. Co-author.
" Prediction Methods for Near Field Noise Environments of VTOL Aircraf t."
Air Force Flight Dynamics Laboratory, Wright Patterson Air Force Base, Ohio, Report No. AFFDL-TR-71-180, May 1972.
"A Program for the Measurement of Environmental Noise in the Community and its Associated Human Response.
Vol. I -A Feasibility Test of Measurement Techniques.
Vol. II - A Plan for a National Program."
U.S.
Department of Transportation. Report Nos. DOT-TST-74-5 and -6, December 1973.
" Airport Noise Reduction Forecast. Vol.1 - Summary Report for 23 Airports." U.S.
Co-Department of Transportation, Report No. DOT-TST-75-3, October 1974.
author.
" Community Noise Countermeasures Cost-Effectiveness Analysis." Wyle Research Report No. WCR 75-2. Prepared for the Motor Vehicle Manuf acturers Association, March 1975. Co-author.
" National Measure of Aircraf t Noise Impact Through the Year 2000."
Wyle Research Report No. WCR 74-13. Prepared for the U.S. Environmental Protection l
Agency,1975. Co-author.
M LA80mATORG
1 LOUIS C. SUTHERLAND "A Study of Air-to-Ground Sound Propagation Using an Instrumented Meteorological Tower." Wyle Research Report No. WRH-75-2. NASA CR 2617.
Prepared for NASA, Langley Research Center, March 1975. Co-author.
" Review of Experimental Data in Support of a Proposed New Method for Computing Atmospheric Absorption Losses." Wyle Research Report No. WCR 75-7. U.S. Dept.
of Trans. Report No. DOT-TST-75-87, May 1975.
l
" Costs and National Noise Impact of Feasible Solution Sets for Reduction of Airport Noise."
Wyle Research Report WR 75-9.
For U.S. Environmental Protection Agency, February 1976. Co-author.
" Noise Impact of Air Carrier Operations for the Nation." Paper presented at the 91st Meeting, Acoustical Society of America, Washington, D.C., April 5-9,1976.
" Annoyance, Loudness, and Measurement of Impulsive Noise Sources."
Wyle Research Report for the U.S.
Environmental Protection Agency, Report N o.
EPA 550/9-79-103, April 1976. Co-author.
" Community Noise Monitoring - A Manual for Implementation." Wyle Research Report WR 76-8. For the U.S. Environmental Protection Agency, July 1976. Co-author.
" Laboratory Measurements of Atmospheric Absorption in Air." Paper presented at the 92nd Meeting, Acoustical Society of America, San Diego, California, November 15-19, 1976. Co-author.
" Construction Noise Monitoring Techniques." Paper presented at FHWA Symposium on Highway Construction, Denver, Colorado, February 1-2, 1977. Co-author.
" Evaluation of Spatial Sampling Techniques for Community Noise Sources." Wyle Research Report WR 77-5. Prepared for the U.S. Environmental Protection Agency, March 1977. Co-author.
"An Attitudinal Assessment of Community Noise. Vol.1 - A Critique of Selected Noise-Related Attitudinal Surveys." Wyle Research Report No. WR 77-4, for U.S.
EPA, February 1977. Co-author.
" Spatial and Temporal Sampling Methods for Community Noise Surveys." Paper presented at 93rd Meeting, Acoustical Society of America, University Park, Pennsylvania,6-10 June,1977.
" Review of Noise Propagation in the Atmosphere," 3. Acoust. Soc. Am. 61(6), 1403-1418, June 1977. Co-author.
" Insulation of Buildings Against Highway Noise," Wyle Research Report WR 77-10, U.S. Department of Transportation, Federal Highway Administration, FHWA-TS 202,1977. Co-author.
" Scaling Law for Estimating Liquid Propellant Explosive Yields," 3. Spacecraft and Rockets, Vol. 15, No. 2,124-125, March-April 1978.
" Temporal Fluctuation in Community Noise Levels - A Brief Review."
Paper presented at 96th Meeting, Acoustical Society of America, Honolulu, Hawaii, 27 November-1 December,1978. Co-author.
M LABORATO8hES
LOUIS C. SUTHERLAND
" Indoor Noise Environments Due to Outside Noise Sources," Noise Control Engineering 11(3),124-137, Nov.1978.
" Influence of Atmospheric Absorption on the Propagation of Bands of Noise," J.
Acoust. Soc. Am. 66(3), 885-894, 1979. Co-author.
" Recommended Test Plan for Static Measurement of Excess Ground Attenuation at Wallops Island."
Wyle Research Report WR 79-24 for NASA Langley Research Center,1979. Co-author.
" Correction Procedures for Aircraf t Noise Data - Volumes II, III, and V."
Wyle Research Report for the Federal Aviation Administration, Report No.
F A A-EE-80-1,1979.
" Systems Analysis to Develop Future Civil Aircraf t Noise Reduction Alternatives."
Wyle Research Report for the Federal Aviation Administration, Report N o.
FAA-EE-82-2, 1980.
" Low Frequency Response of Structures."
Wyle Research Report WR 82-18 for Construction Engineering Research Laboratory, U. S. Army, May 1982.
" Preliminary Evaluation of Low Frequency Noise and Vibration Reduction Retrofit Concepts for Wood Frame Structures."
Wyle Research Report WR 83-26, for Construction Engineering Research Laboratory, U. S. Army, June 1983. Co-author.
" Ambient Noise Survey of John Redmond Reservoir." Wyle Research Report WTN 84-2 for Kansas Gas & Electric Co., February 1984. Co-author.
" Development and Application of Acoustic Tests for Large Space Payloads." Wyle Research Report WR 84-11 for C. Itoh, February 1984.
" Review of Criteria for Acceptable Speech Signal-to-Noise Ratios for Paging System Design." Wyle Research Report WTN 84-4, April 1984.
"A Review of Legal Decisions Concerning Night Curfews for Airport Noise Abate-ment." Wyle Research Report WTN 84-5, August 1984.
"Some Design Consideratiorys for Acoustic Test Facilities." Wyle Research Report for C. Itoh, WTN 84-6, September 1984. Co-author.
" Message Intelligibility Design Goal for Paging Systems." Wyle Research Report WTN 84-7, September 1984.
" Refinements to STI Model." Wyle Research Report for Consolidated Edison Co.,
January 1985.
" Reanalysis of Laboratory Data on Air Absorption to Simultaneously Define Self-Consistent Values for Oxygen and Nitrogen Relaxation Frequencies."
Paper presented at Symposium / Workshop on Long Range Sound Propagation, New Orleans, February 1985.
"Sumrnary of Progress to Date on Reanalysis of Air Absorption Data."
Report presented to 150 TC43/SC1/WG24, Budapest Hungary, April 1985.
" Predicted Response of Sound Level Meters to Sonic Booms." Wyle Research Report for SRL, WTN 85-5, April 1985.
" Program Management Plan for Study of Sonic Boom Effects and Measurement."
Wyle Research Report for Dynamac, WTN 85-10, September 1985.
M LASORATOmlES E____
4' LOU 5 C. SUTHERLAND
" Noise Impact of Military Training Routes, Preliminary Considerations."
Wyle Research Report for AAMRL, WTN 85-12, December 1985.
" Design Criteria for TRW Test Facility." Wyk Research Report WR 85-34(R) for TRW, December 1985. Co-author.
" Study of the Effects of Exposure to Sonic Booms on Human Health, Vol.1 - Sonic Boom Environments." Wyle Research Report WR 86-1 for SRL, February 1986. Co-author.
" Detailed Research Plan for a Study of Aircraft Noise and Sonic Boom Effects and Measurements - Vol. I through VI."
Wyle Research Report 86-3, Vol. I-VI, for Dynamac, March 1986. Co-author.
"High Power Laser Noise Flash Vibration Reduction Program."
Wyle Research Report WR 86-8 for U.S. Air Force, May 1986.
" Correct Form for Critical Radius for Modulation Transfer Function."
Wyle Research Report WTN 86-6, August 1986.
" Design Guide for the Enhancement of Paging Intelligibility of Public-Address Systems." Wyle Research Report WR 86-4 for Coned of N.Y., September 1986. Co-author.
" Formulation and Application of Community Noise Assessment Procedures." Key-note address at Community Noise Conference sponsored by the Australian Acousti-cal Society, Toowoomba Australia, October 1986.
" Environmental Impact Assessment Procedures for Aircraf t Noise and Sonic Booms -
Current Status and Future Needs." Paper presented at Community Noise Con-ference sponsored by the Australian Acoustical Society, Toowoomba Australia, October 1986.
" Exterior Wall Rating (EWR), a Single Number Index for Rating the Sound Trans-mission Loss of A-Weighted Sound Levels for Exterior Facades." Paper presented at the ll2th Meeting of the Acoustical Society of America, Anaheim, California, Fall 1986. Co-author.
" Exploratory Study of the Potential Effects of Exposure to Sonic Boom on Human Health."
Paper presented at the ll2th Meeting of the Acoustical Society of America, Anaheim, California, Fall 1986. Co-author.
'! Development of Improved Methods for Computing Air Absorption Losses, Vol. I -
Evaluation of Vibrational Frequencies for Laboratory Data." Wyle Research Report WR 86-22 for FAA, December 1986.
" Sonic Boom Considerations for High-Speed Civil Transport Aircraft."
Wyle Research Report WR 87-4, for Douglas Aircraft Company, June 1987. Co-author.
" Environmental and Cumulative Impact of Noise from Major Wind Turbine Generator Developments in Alameda and Riverside Counties - Literature Review and Measurement Procedure Development." Wyle Research Report WR 87-8, for Alameda and Riverside Counties, September 1987. Co-author.
" Sound Propagation and Community Noise Exposure Considerations for Enroute Soise of Advanced Turboprop Aircraf t."
Paper presented at il4th Meeting of the Acoustical Society of America, Miami, Florida, November 1987. Co-author.
M.
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I I
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LOUIS C. SUTHERLAND
" Design of Alert and Notification Systems." Paper presented at 114th Meeting of the Acoustical Society of America, Miami, Florida, November 1987. Co-author.
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LAaOflAT08 tit $
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4 CERTIFICATE OF SERVICE I, Thomas G.
Dignan, Jr.,
one of the attorneys for the Applicants herein, hereby certify that on December 18, 1987, I made service of the within document by mailing copies thereof, postage prepaid to:
Alan S.
Rosenthal, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeal Panel U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Mr. Ed Thomas.
-Appeal Panel FEMA, Region I U.S. Nuclear Regulatory 442 John W. McCormack Post Commission Office and Court House Washington, DC 20555 Post Office Square Boston, MA 02109 Administrative Judge Sheldon J.
Robert Carrigg, Chairman Wolfe, Esq., Chairman Board of Selectmen Atomic Safety and Licensing Town Office Board Panel Atlantic' Avenue U.S. Nuclear Regulatory North Hampton, NH 03861 Commission Washington, DC 20555 Judge Emmeth A.
Luebke Diane Curran, Esquire Atomic Safety and Licensing
-Andrea C.
Ferster, Esquire Board Panel' Harmon & Weiss 5500 Friendship Boulevard Suite 430 Apartment 1923N 2001 S Street, N.W.
Chevy Chase, MD 20815 Washington, DC 20009 Dr. Jerry Harbour Stephen E. Merrill, Esquire Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee, Esquire U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General Washington, DC 20555 25 Capitol Street Concord, NH 03301-6397 Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory
~ Washington, DC 20555 Commission Washington, DC 20555
i Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S.
Nuclear Regulatory 116 Lowell Street Commission P.O.
Box 516 i
Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Mr.
J.
P.
Nadeau Assistant 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 Matthew T.
Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney 25 Maplewood Avenue General P.O.
Box 360 One Ashburton Place, 19th Flr.
Portsmouth, NH 03801 Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A.
Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Kensington, NH 03827 126 Daniel Street Portsmouth, NH 03801 Senator Gordon J. Humphrey Mr. Angie Machiros U.S.
Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn:
Tom Burack)
Town of Newbury Newbury, MA 01950 Senator Gordon J.
Humphrey Mr. Peter S. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall fittn:
Herb Boynton)
Newburyport, MA 01950 Mr. Thomas F.
Powers, III Mr. William S.
Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.
Washington, DC 20472
-2
7-l.t 4
Gary.W.' Holmes, Esquire Richard A.
Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301
-Judith H. Mizner, Esquire Charles P. Graham, Esquire Silverglate, Gertner, Baker McKay,. Murphy and Graham Fine, Good &.Mizner 100 Main Street 1.~
- 88 Broad Street Amesbury, MA 01913 Boston, MA 02110 W' ~ ^
- ( [ ;- g ? '
Thomas Cl. 61gnan, Jr.
-3
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