In my personal opinion, people might always know if they are hearing noise. How could that happen? IIRC, Vref (or AVCC) in a dac is convolved with the audio to produce the dac audio output. It there is noise on Vref, then it becomes part of the audio. The noise then goes up and down with the audio signal. In my personal view, there can be an audible effect, but I don't hear it as being like the way a stable noise floor sounds. Its may be more of a blur to the sound, at least to my personal perception. If my understanding is correct, similar kind of thing should be able to happen with clock phase noise, since it is also convolved with the audio inside the dac. Also, IIRC, ESS talked about noise that goes up and down with the audio in their modulator seminar from several years ago.