R’ Zilberstein brings that R’ Chaim Kanievsky held that there is no proof from Moshe Rabbeinu. He brings the Yalkut Shimoni (Vo’eschanon, remez 811) which says that there are ten expressions of tefillah, and one of them is צעקה, therefore, it is likely that Moshe Rabbeinu never screamed and raised his voice, rather he davened a certain special type of tefillah known as צעקה.
We find in Shmuel (1, 15:11): ויזעק אל ה 'כל הלילה - “They cried out to Hashem the entire night” – Is it possible for a person to scream with a loud voice the entire night? No, rather we see from here that זעקה is at type of tefillah, and the reason it is referred to as, זעקה, is because it comes from the depths of the heart, however, it doesn’t refer to screaming with a loud voice.
Based on the above, we have no proof from Moshe Rabbeinu. In fact, if there is a loud outside noise one can read krias shema and it’s considered that one can hear the words, as even Moshe Rabbeinu himself when davening by the Plague of the Frogs never shouted in a loud voice – rather, he davened a special type of tefillah, which came from the depths of his heart. Therefore, R’ Zilberstein concludes, that bedieved one can fulfil his duty when reciting krias shema, berachos, shemonah esrei etc. in such a situation and there is no need to repeat. He then cites that the sefer “Leket HaKemech HaChodosh” also concludes like this.
