ML20154L333

Affidavit of Dn Keast.* Discusses Contention Bases A.7 Re Hearing Damage to Anyone within 100 Ft of Siren During Operation.Supporting Info Encl

ML20154L333
Person / Time
Site:	Seabrook
Issue date:	09/17/1988
From:	Keast D PUBLIC SERVICE CO. OF NEW HAMPSHIRE, WARNING SYSTEM SERVICES
To:
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References
OL-1, NUDOCS 8809260149
Download: ML20154L333 (16)

Text

7 September 17, 1988 l I

Ui4ITED STATES OF AMERICA NUCLEAR REGULATORY r:OMMISSION hefore the ATOMIC SAFETY AND LICENSING BOARD

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In the P.atter of )

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PUBLIC SERVICE COMPM'Y OF ) Do::ket Nos. 50-443-OL-1 NEW HAMPSHIRE, St al. ) 50-444-GL-1

) (On-Site Emergency ,

Planning and Safety (Seabrook Station, Units 1 and 2) )

Issues)

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AFFIDAtrIT OF DAVID N. KEAST I, David N. Kesst, being on oath, depose and say as fc. sws:

1. I am the owner and principal consultant of A

Warning System Services, Carlisle, Massachusetts.

statement of my professional qualifications is attached hereto and marked "A".

2. The purpose of this affidavit is to supply i

information pertinent to the allegation in Contention Basis A.7 regarding hearing damage to anyone within 100 feet of the siren during its operation.

8809260149 800917 PDR ADOCK 05000443 G F DH m 1

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3. 'In response to Interrogatory No. 241, the J

Attorney General indicated that the basis for contention Basis A.7 is "Appendix 3 (at 3-8) of KUREG-0654, FEMA-REP-1" which states:

"The maximum sound levels received by any member of the public should be lower than 123 dB, the level which may causa discomfort to individuals."

This 123 dB limit is taken from the 123 dB limit recommended to avoid hearing damage in FEMA publication number CPG 1-17, which source is cited on pp. 3-8, 3-9 (twice), 3-10, 3-11 and 3-12 of Appendix 3 of NUREG-0654.

4. I am the principal author of CPG 1-17, which I wrote under United States Government Contract No. DCPA-01 C-0329 while an employee of Bolt Baranex and Newman, Inc.

(BBN) in the early part of 1979. I wrote CPG 1-17 to be a simple, hon-technical "pra'ctical guide for public officials" such as fire chiefs planning to install a fire siren.

5. As the author of CPG 1-17, I derived the 123 dB limit "to assure that no person is likely to be subject to a sound level great enough to cause hearing damage" (CPG 1-17,

p. 8). The background document to CPG 1-17, BBN Report No.

3-4100, Which I also prepared and which is also cited on pp.

8 of Appendix 3 of NUREG-0654, points out that I chose the 123 d3 limit from Figure 3 of Karl D. Kryter, Hazardous l

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

Exposure to Intermittent and Steady-State Noise", Report of Working Group (WG) 46, National Academy of Sciences -

National Research Council (NAS-NRC), Committee on Hearing, Bioacoustics, and Biomechanics, January 1965. (This is referred to below as the "Kryter WG-46 Report".) The 123 dB limit applies to an almost daily exposure over about 10 years to 1-1\ minutes or less of a 1000 Hz tone.

6. Considering the wide usage and lay readership which I contemplated for CPG 1-17, 123 dB is appropriate as a general purpose limit. As indicated in BBN Report 4100, one thousand Hz "...is the highest fundamental frequency produced by any outdoor warning device... identified." Many communities briefly sound their fire sirens or horns once a day, such as at noon. Maintaining levels below 123 dB near the ground is easy to achieve with suitable mounting of any of the sirens or horns on the market in 1979.

7. Thus, the 123 dB limit was conridered a safe upper limit which would protect the public regardless of the frequency, duration or number of soundings. The goal of the 123 dB criterion was to provide a safe notification system.

This goal may also be achieved by varying other aspects of the design and use of the siren system.

8. In fact, I have reviewed the results of Dr.

Kryter's analysis of a 123 dB exposure to the sound from a b

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non-rotating siren operated for 3/1.5 2 minutes at 1000 Hz. l f

This siren system, contemplated by NUREG-0654, would affect 1 I

the average person's hearing by causing a temporary threshold ,

shift at 2 minutes after exposure (TTS2) of 18/12 dB. This effect would be minor and last only a short time. l 1 9. For comparison, Dr. Kryter also did a l calculation of the 134 dB rotating siren at 25 feet sounded for 3 minutes at 550 Hz, this being the siren system to be l used by the VANS as detailed in Louis Sutherland's affidavit

! and which I have personally inspected. This system will cause neither permanent hearing loss nor temporary threshold shift as determined by Dr. Kryter.

10. Further, a document provided by the Massachusetts Attorney General is consistent with the conclusion of Dr. Kryter. In a letter dated May 5, 1988, Gregory C. Tocci informed Mr. Steven Jonas of the Massachusetts Department of the Attorney General of the results of a discussion with Dr. Joseph Sataloff. With reference to the short-term exposure to VANS emergency i

! warning sound levels as high as 132 dBA, Dr. Sataloff stated, t

"that the likelihood of possible scaring damage under these

circumstances was not significant." (Copy of letter attached i

and marked "B".)

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2 Three minutes duration per NUREG-0654; One and one-half minutes duration per BBN Report 4100.

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11. Thus, the VANS siren system is a safe means of l notifying the public in terms of potential hearing damage, and in my opinion meets the safety criteria intended by NUREG-0654.

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David N. Kaast September _ , 1988 The above-subscribed David N. Keast 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 knowledge.

Before me, Notary Public My Commission Expires:

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[I-: y 1s 42 houg  %.,

/ David N. Keast September /I, 1988 The above-subscribed David N. Keast 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 knowledge. .

Before me, w_

W Notafy Publit:: f My Cymmissidn Expires:

MARY T. BATTAGLIA, Notan Public My Commission Egiros Septemtw 16,1994 l

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Koast Attachment A, 1 of 5

'/'!ARN!NG 3 /$ TEM SERVICES -- ---

RESUM E David N. Keast, Principal Consultant Warning System Services PROFESSIONAL EXPERIENCE Mr. Keast's expedence includes a wide range of pro) cts involving acoustics, communications, electronic instrumentation and computer applications. His specific ,

pro)ct responsibilities have involved research and consulting, lecturing, technical writing, serving as an expert witness, pro)ct management and general management. In general, Mr. Keast's work has been in the following areast o Design or performance analysis of mass public warning systems at over 28 locations in the United states near nuclear power plants, chemical facilities and downstream of hkjh-hazard dams, o Research on the propagation of sound out of doors over the ground, ,

and on how this propagation is affected by meteorological conditions.

Design and programming of algodthms to predict sound propagation.

o Measurement and analysis of ambient noise levels in communities, of the spatial and temporal vadability of these levels and of how people react to noise in their environment. l 4

o Studies of the attenuation of sound by building structu:es. i o Studies of the noticeability of noise and warning sounds by people, and of the intelligibility of speech signals under a vadety of conditions, o Design of electronic instrumentation and analog data analysis equipment. Electronic instrument manufacturing and marketing.

Genersi management of an electronic instrument company.

o Analysis of community, office-bunding and industrial noise problems; and the design of noise-cor. trol solutions for these problems.

f o Wdting of books, handbooks, guides, sponsored reports and technical '

paperar adknet lectures and expert testimony at civa trials and 1 administrative headngs.

EDUCATION ,

B.A., Amherst College o

o B.S., M.S. in Electdcal Ihgh.wdng, Massachusetts Institute of

Techno?ogy a

1 Kocst Attachmsnt A, 2 of 5

'[/,U Id M G .i/ U ,1 3 U W G -- - - - -

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PROE7,SSIONAL ACTIVITIES o Acoustical Society of Amedca, Fellow o Institute of Electrical and Electronic Engineers, Senior Member.

o Institute of Noise Control Engineering, Affiliate c Visiting lecturer 1 Massachusetts Institute of Technology, acoustic measurements; Battelle Pacific Northwest taboratodos workshape:

"Emergency Preparedness for Nuclear Power Facilities" and "Emergency Preparedness Plans and Programs"; The Harvard School of Public Health, "Planning for Nuclear Emergencies".

o National Science Foundation, review of grant proposals for research on outdoor sound propagation.

o Standards-writing committees for the Power Engineering Society, the 7.nstrument Society of America and the American Institute of Aeronautics and Astronautics.

o Invited technical papers before the Acoustical Society of America, the International Institute of Noise Control Engineering, the Institute of Electrical and Electronic Engineers, the American Society of hating, Refrkjerating and Air-Conditioning Engineers and the Air Pollution control Association o Sigcia X1, Eta Kappa Nu, Tau Beta Pi PREVIOUS POSITIONS 1983-1988 H MM Associates, Inc.: Vice President and Senior Pro)ct Manager, Acoustics, Emergency Warning Systems and Computer Suport.

1973-1983 Bolt Beranek and Newman, Inc.: Superybory Consultant and Manager of the Environmental Technologies Depc.:tment.

?971-1973 M.F.L Corix, ration: Vice president of Engineering.

1966-1971 Data Equipment Company Glolt Beranek and Newman): Divisional Vice President and General Manager.

1963-1966 Bolt Beranek and New man, Inc.: Manager of Instrumentation, t.os Angelse Office.

1954-1963 Bolt Beranek and Newman, Inc.: Acoustical Consultant.

3 of 5

//A?N!NG SWTW 73:wcg3 _ ._ yeastAttachmantA, PUBLICATIONS o Author or coauthor of over 100 books, papers and sponsored reports, including:

"Emergency Warning Systems: Your Last Line of Defense", Industdal Fire World 3, m.9-11 (February 1988)

"Outdoor sirens, how do they work for people indoors 7", J. Acoust. Soc. Amer. S47, p282 (1987)(A). An invited paper presented at the 114th meeting of the Acoustical Society of Amedca.

EU. S. requirements for public warning sirans near nuclear power plants",

Proceedings of InterNoise '87, Beijng,1, p.155 (September 1987).

"Emergency Warning SystenW', a CAER Program handbook published by the Chemical Manufacturers Association, Washington, DC,1987.

"Procedures for Analyzing the Effectivences of Siren Systems for Alerting the Pubilc", NUREG/CR-2654, PNL-4227, Battelle Northwest Laboratoder, Richland, WA, 1982. A companion report, "Eveluation of Prompt Alerting Syctems at Four Nuclear Power Stations", NUREG/CR-2655, PNL-4226, is available froin the same source.

"Electdcal substation design practice in the United States and its influence on transformer noise in surrounding communities", Proceedings of InterNoise "81, W.627 a981)

"The use of sound to locate infiltration openings in buildings", Proceedings of the ASHR AE/ DOE-ONRL Conference on Thermal Performance of Exterior Envelopes of Buildings, ASHR AE SP 28, p.85 G981)

"Outdoor Warning Systems Guide", CPG 1-17, Federal Emergency Management Agency, Washirgtcal, DC, March 1,1989. (Also BBN Report 4100 of the same title, as referenced in NUREG-0654).

Bdef articles on Weasurement apparatus in D1 cyclopedia of Science, McGraw-Hill Book Cotapany, New York, NY, 1968, 1965, 1980. ,

' Acoustic location of air-infiltration openings in Buildings", Proceedings of InterNoise '79, Warsaw (September 1979). An invited paper.

"Energy conservation and noise control in residences", SW Sound and Vibration _

w.18-22 (Atly 1979). Also presented at Noiserpo '79, Chicago, Apra,1979.

"Asasesing the impset of audible noise from AC transmission lines: a proposed Cethod", Paper F79237-9 Fresented at the IEEE Winter Power Meeting, New York (February 1979).

"Attenuation of northern dwellings to a linear source of noise" (with D. A. Ddscoll and J.P. Dulin), J. Acoust. Soc. Amer. 63 Suw.1 (1978)(A).

"Regulatory aspects of audible noise from EPV/1JHV transmission lines", an invited paper before the IEEE/ PEG meeting, South Bend, IN (September 1977).

Kaast Attachmsnt A, 4 Of 5

\//ARNING SYSTEM SEavtcEs -- -- --- -- - - - -

"Effectiveness of Audible Warning Devicee on Emergency vehicles" (with R.C. Potter, S. A. Fidell and M.M. Miles), DOT-TSC-OST-77-38, U.S. Department of Transportation, Washington, DC 29599 (August 1977).

"Some pitfalls of community noise measurement", J. Air Pollution Cont. Assn. 25(1),

pp.36-39 (January 1975).

"Development of a procedure for predicting noise environments around industrial sites", BBN Report 2987 prepared for the Long Island Lk 3hting company (September 1974).

"An instrument for automated community noise monitoring" (with B.E. Blanchard), an ,

invited paper presented before InterNoise '74, Washington, (September 1974).

"Ambient noise sttWes in suburban and rural areas (with E.W. WoM and J.D. Barnes),

Cn invited paper presented before InterNoise '74, Washington.(September 1974).

"Sammer acoustic environment of the Jamesport and 91oreham sitest", BBN Report 2656 prepared for the Long Island Lighting Company (October 1973).

Measurements In Mechanical Dynamics, McGraw-Hill Book Company, Inc., New York, NY, 1967.

"A survey of graphic input devices", Machine Design (August 1967).

"The noise environment of the California Cond<x", BBN Report 1259 (October 1965).

"Analog vs. digital data analysis: an introduction", SAE paper 650818 presented at the SAE National Aeronautics and Space Engineering and Manufactudng Conference, Los j Angeles (October 1965).  !

"Some studies of Titan II noise and vibration data" (with p. A. Franken), J. Acoust.

Soc. Amer. (1965)(A).

"Noise and vibration characteristics of large rocket motors with thrust vector control" (with P.A. Franken and D.E. Newborough), J. Acoust. Soc. Amer. (1964)(A).

"Digital computer proceesing of telemetered vibratien data" (with W.E. Fletcher and J. Gibbone), J. Acoust. Soc. Amer. 34 (1962)(A).

"Airborne vibration spectrum analysis: some techniques and limitations" (with J.

Gibbons and W.E Fletched, a paper presented at the 31'st Symposium on Shock, Vibration and Related Environments (October 1962).

"An analog system for the analysis of random data signals up to 10 Kilocycles", IRE Trans. on Instrumentation, I-ll, pp.52-57 (September 1962).

aMeasurement of rocket engine noise", Noise Control 7, p.25-36 (1961). (Also i presented as an invited paper at the 69th meeting of the Acoustical Society of A merica.)

"Basic Sound Meas' sing System", Chapter 5 of Noise Reduction, L. L. Beranek, ed.,

McGraw-Hill Bock Company, New York, NY,1968.

Koast Attcchment A, 5 of 5 WARNING SYSTEM SERVICES - - - - - - -

i "Acoustical reasurements in the 1/3-scale Minuteman missile silo", 29th Symprdum on I shock, vibration and Associated Environments (November 1968).

"Acoustic instrumentation for measurements in the Minuteman missile silo" (with G.W.

Kcaperman), J. Audio. Eng. Soc., pp.180-184 (1968).

"Experimental study of the propagation of sound over ground" (with F.M. Wiener), J. -

Acoust. Soc. Amer. 31, pp.724-733 (1959).

"Calibration of accelerometers in a almulated space environment", J. Acoust. Soc.

Amer. 31, pp.584-587 (1959). ,

"Equipment and procedures for field measurements of aircreft noise and flight paths" (with W.E Clark and W.J. Galloway), J. Acoust. Soc. Amer. 38, m.953 (1958)(A).

i "An empirical method for estimating wind profiles over open level ground" (with F.M.

Wiened, Trans. Am. Geophys. Union 39, pp.858-804 (1958).

"Instrumentation for the study of the propagation of Sound over Ground" (with F.M.

Wiener and K.N. Goff), _J. Acoust. Soc. Amer. 38, p.968-966 (1958).

"On the prediction of the attenuation of sound propagated over ground" (with F.M.

Wiened, J. Acoust. Soc. Amer. 29, p.1953 (1957)(A).

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Kor.st Attachmont B, 1 o f 3[ ' .

P mi CAVANAUCH TOCCI

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ASSOCIATES, INCORPORATED 327 F BOSTON POST ROAD SUDBURY. 51 ASS ACHUSETT5 0177? TELEPHONE 61P 443 7671 re. cre.ts srwa cossur4u asxt:4rroensuraus hitLt \\t I C 6 AN AUGH F414 K ANTilGS Y HOO\ ER RICH ARD G CANN Pf G8tr,ORY C TNCI Pf P?&JICf \T N '

D613 H K.O E f;\10tHYl ><x(kt$ THO\145 N $ttis SRION G l g ,s a0\ttvs rR<mn DONNA L R.4FL5 i

May 5, 1988 Mr., Steven Jonas 4 Department of the Attorney General

, one Ashburton Place Boston, MA 02108-1698 l

Dear Steve,

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About 2 weeks ago we discussed the possibility of hearing damage

associated with short term exposure to VANS emergency warning

sound levels cs high as a 132 dBA. At that time I indicated that even a single incident of brief exposure to sound this loud could I result in permanenC hearing damage. I also meni

ioned that j available criteria for permanent hearing threshold shifts, as '

l hearing damage is most commonly referred, are only available for 1 the work place where sound level exposure occurs on a day to day l basis. I also mentioned that we would pursue this further with

Dr. Joseph Sataloff, M.D. who is a well known expert in this l l area.

Tom Bouliane of our office discussed this matter with Dr.

2 Sataloff who responded with the attached letter dated April 29, 1988. Since his letter was rather vague with respect to criteria [

for hearing damage associated with single brief exposures to high l l sound levels, I called Dr. Sataloff to discuss this further. Dr.

i Sataloff was more specific when I spoke with him and indicated  ;

l that there are currently no available criteria upon which to base l the likelihood of permanent hearing threshold shifts as.oociated J with single, brief exposures to levels as high as those expected I to be produced by the VANS dystem. Moreover, Dr. Sataloff went further to say that the likelihood of possible hearing damage i under these circumstances was not significant.

Hence, we believe that the Dep'artment of Attorney General comments regarding hearing < age of the general populace resulting from the VANS systC_ should emphasize the need for prudence in the use of the syste:s and ask for clarification on procedures for avoiding excessive exposure.

t At E 5t B E R. N ATION A L COL NCIL OF ACOUSTIC AL CON SU LT ANTS

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Kaast Attcch:n nt B, 2 of- 3

$. Mr. Steven Jonas Page 2 If I can provide any further detail, please do not h9s.. ate contucting me.

Sincerely yours, CAVANAUGH TOCCI ASSOCIATES, INC.

d Gregor$ C. occi i

cct l encit  ;

GCT/alw/7233 1

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Koast Attachment B, 3 of 3 JOSEPH SATALOFF.M. D.

1721 81'44 STfttg?

PHit.AC4.#Hf A, PA 19103 218-MS 3322 April 29. '988 Thomas G. Bouliane Consultant Cavanaugh Tocci Associates. Inc.

327 F Boston Post Road Sudbury. MA 01776 Dear Mr. Boulianet Thank you for letting me review the information describias the -

VANS systes proposed to alert listeners to a threat to their safety. First I wocid preface my consent that the technical methods used for this alarm are somewhat surprising. There has been so much esperietce in the United States and London to alert individuals to air raids. I have seen auch more effective systems and I somewhat wonder about this rather strange idea.

If the ears of human beings are exposed to over 120 decibels (dB) over periods of time from a loud speaker system. there can result high frequency sensorineural hearing loss both temporarily and permanently. I do not believe the damage can be sovere but it can definitely be present and has been recorded in instancee 1 from exposure to rock and roll ausic of much lesser intensity.  :

but probably longer duration.

If such an alarm systen goes off during sleeping hours. it may not damage hearing quite as auch because individuals are a greater distance away. However. it can have a rather disturbing shock experience and I feel certain that there are other ways to resolve the situation besides this type of loud speaker system.

Thank you very much. I will be pleased to discuss it in greater detail with you.

Very sincerely.

• '** t u t no, ,,,,

Joseph Sataloff. M.D.

JS/rg ~ ~

Enclosure ~~-

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