ML20149H994
| ML20149H994 | |
| Person / Time | |
|---|---|
| Issue date: | 10/05/1983 |
| From: | Steven Baggett NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20149H589 | List: |
| References | |
| FOIA-87-790 15437, NUDOCS 8802220235 | |
| Download: ML20149H994 (2) | |
Text
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umrao states NUCLEAR REGULATORY COMMisslON h o s, j
.c WASHINGTON, D. C. 20555
%..../ OCT 5 1983 MEMORANDUM FOR: John Hickey Material Licensing Branch Division of Fuel Cycle and Material Safety FROM: Steven L. Baggett
'. Material Certification and Procedures Branch Division of Fuel Cycle and Material Safety
SUBJECT:
ARMSON,INC.(FORMERLYLEADERSHIPKEYS,INC.) CONTROL N0. 15437 Per your request dated August 22, 1983, we have reviewed the submitted data. To complete our review, we will need Armson, Inc. to supply additional infor-mation or clarification on the following items:
- 1. We need to know if the proposed label will remain legible for the useful life of the gunsight.
- 2. Armson, Inc made reference to a standard model sight and 12 other sight models that fit different weapons. If these 12 models are in fact a different sight, provide descriptive data on each. Additionally, evaluate each sight to determine that they meet the safety criteria of Section 32.23,10 CFR Part 32 and prototype testing requirements.
- 3. Since the sight is intended for exempt distribution, we need a copy of your revised user instructions.
- 4. We need a copy of your quality control procedures. If the sights are to be manufactured by Armson, Inc., in South Africa, we would need a copy of their quality control pro-cedures.
- 5. To augment your statement about the safety of the sight, we need a description that clearly demonstrates that the gun sight design meets the safety criteria in Section 32.23, 10 CFR Part 32. .
- 6. Explain the degree of access of human beings to the sources, within the product, during normal handling and use.
g 7. To keep our files current, we would like additional descrip-
.. tive and prototype test data about both light sources.
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- 8. We need an estimate of how many sights would be distributed i g annually and an approximate cost of a sight.-
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- 9. We need a clearer diagram of the gunsight.
- 10. Section 32.25, 10 CFR Part 32 requires that you file a 4
transfer report with the N'tC. 'Please note the reporting " time . interval'has 'been cht.nged from one year to five years. We suggest that you revise your reporting requirement pro-cedure to reflect this change. If the applicant has any questions, you may have them call me directly at t (301)427-4240. If you have any questions, please contact me. gc.
,'S even L Baggett Material Certification and Procedures Branch Division of Fuel Cycle and Material Safety, NMSS f
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ARMSON, INC. ARMS N O.E.G. P. o. Box 2130 DAY / NIGHT / TOW ttGHT INCREDIBtY FAST GUNSIGHT Farmingtogills, Michigan 48018 7 July 27,1983 h Division of Fuel Cycle and Material Safety, Of fice of Nuclear Material Safety, and Safeguards, Et U.S. Nuclear Regulatory Commission, C Washington, DC 20555 G
. Ret Applicatio,n, f or Exemption _o_f,, Optical Gunsight Containing Tritium
Dear Sir:
Pursuant to the Commission's order of June 30, 1983 in the matter oi Self-Powered Lighting, Inc. this application is for a new byproduct mat erials license to possess and distribute optical type gunsights to persons execpt from requirements for a license pursuant to 10 CFR 30.19. Leadership Keys, Inc. has changed its name to Armson, Inc. and has filed the name change in the state of Michigan. Leadership Keys. Inc. will continue to be an assumed name under the c orpo ra tion. This application restates certain portions of the September 23, 1981 application of Leadership Keys, Inc. including correspondence, tests and data which 'resulted in the issuance of materials license number 21-19874-01 and the "Registry of Radioactive Sealed Sources and Devices, Safety Eval ation of Device" Ho. NR418D101G by your Mr. Earl G. Wright. 34 g Pursuant to 10 CFR 32.22 we provide complete information below and to attachments. Fee paye.ent is included. This application consists of this letter and two copies of each of the following attachments:
- 1. Completed form NRC-3131.
- 2. License the amount of $950.00.
- 3. fees,s,heets, Supplemental our check #2735 indexed to in[f orm NRC-3131.
- 4. Qualification Test Report by Environmental Research Group, Inc. (ERG)
- 5. Qualification test Specification.
- 6. Acceptance Test Specification.
- 7. Sample Acceptance Test Report by ERG.
- 8. Assembly Control Drawing, model type description and labeling.
- 9. Failure Mode and Effects Analysis.
- 10. Worst Case Studies.
- 11. Statement of Understa'nding.
Ve believe that this application with the attachments enumerated above constitute all the requirements for issuance of the requested license. Since this new license is primarily concerned with regulatory issues for the same gunsight now generally licensed, we earnestly request your most expeditious treatment of this application. Yours truly,
/ ' 'Vk e 4"/// - ^
Clyn A. . indon P residept _ , 7 , y g" ;. s
$ fr~h.A Y [ Y
l sc:u NRC 313 l U.S. NUCLE AR REOULATORY COMMISSION 1. APPLICATION FOR: U 791 * (Check end/or complete es sporoproste) 10 C o R 3 0 APPLICATION FOR BYFRODUCT MATERIAL LICENSE INDUSTRIAL X e. NEW LICENSE See etteched mstructions for ##tavs. b.AMENDMENTTO: LIGEN5E NVMBEM Comp 4ted applications are foled on duplicate wrth the Division of fuel Cycle and Meteris! Safoty. Offoce of Nuclese Material Safety, and SofePuerds U.S. Nucles< Regulatory Commission, Woshmston. OC 20$$$ or applocatoons unay be filed on person at the Corninission's office at
~ '*# N*l,j ,g n ggp Ill? H Street. NW. Washington, O. C or 191$ Esstern Avenue, Silver Spring, Maryland,
- 2. APP LIC ANT *$ N AME (Institution, firm, person, etc.) 3. NAME OF PERSON TO BE CONTACTED REOARDINO THi$
APPLICATION Armson, Inc. Glyn A.J. Bindon d(/f TE LEPHoNE NUMBER: ARE A CODE - NUMBE R EXTENSloN TELEPHONE NUMBER: ARE A CoOE - NUMBE R EXTENSION (313) 478-2577 (313) 478-2577
- 4. APPLIC ANT'S MAILINO ADDRESS (lactude lip Code /
- 5. STREET ADDRESS WHERE LICENSED MATERIAL WILL BE USED P.O. Box 2130 I'ac'ud' l'8 Cod'>
[3J/y Famington Hills, 25304 Famington Road, hichigan 48018 Farmington Hills, Michigan 48018 (lF MORE SPACE l$ NEEDED FOR ANY l'(EM, USE ADDITIONAL PROPERLY KEYED PAGES.)
- 6. INDIVIDUAL (5) WHO WILL USE OR DIRECTLY SU"ERVISE THE USE OF LICENSED MATERIAL (See items 16 end 11 for required traoning and esperience of each ondovsdualnamed below) *
FULL N AME i O ld i, TITL EMJLi .N < ,,,._ r
- Glyn A.J. Bindon C sident '
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- b. Carolyn R. Binde> 0 0 /F [fh . resident ug.h ,
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- 7. RADIATION FROTECTIOh W M k .hdtp i
Of HOW(td Oy x a.iresume dFA "' : R%' of person's trauis'<brMspetoe >ca ps,outlened m itims I 16 an<r 11 and describe hos te se under item 18. * * * *
- Glyn A.J. Bindon l "' D - lf". lcd.s
- 8. LICEN3ED MATERIAL ~~~- / '
L ELEMENT CHEMICAL NAME OF MANUF ACTURER MAXIMUM NUMBER OF i AND AND/OR AND MILLICURIES AND/OR SEALED N MASS NUMBE R PHYSICAL FORM MODEL NUM8ER SOURCES AND MAXIMUM ACTI. E (if Sealed Source) VITY PER SOURCE WHICH WILL DE POSSESSED AT ANY ONE TIME NO. A B C D Uydrogen (1) 1. Saunders-Roe 80 milli-curies per "I Tritium Isotope R3 Gas Developments Ltd. lamp, two lamps per Model PRH 880/G/20) gunsight, 5,000 (2) or maximum number
- 2. M.B. Microtec A.G. possessed at any one (3) . Model No. T4303-1 time. (800 curies)
"he two tritium lamp types shown above are alternate sources of supply, both meeting
- 14) the same dimensional and ANS N540 requirements.
DESCRIBE USE OF LICENSED MATERI AL E The two tritium lamps are used to illuminate a small peice of colored l 0) ac rylic plastic inside the reticle assembly. The reticle assembiv is positioned ' in a closed and sealed chamber behind a magnifying lens system to comprise an (2) optical sighting means for small arms. A nunsinht with a retiele illuminated by tritium lamps. Additional detail is shown on the assembly drawing in the other (31 attachments. (4) eoRM hac 3131 0 79) f-l
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- 9. STOR AGE OF SE ALED SOURCES I
N C5NTAINER AN;/Z DEVICE IN WHICH EACH SE ALED SOURCE WILT. BE STORED OR USED. NAME OF MANUFACTURER MODEL NUMBER No. A. S. C. ggi Armson 0.E.G. Occluded Eye Gunsight Armson Sales (Pty) Ltd. Standard .and p.n. nnv MA .ava rmi nn % . i (2) New Germany mountings'as 1A70 shnwn in the v g33 South Africa attachments (4)
- 10. R ADIATION DETECTION INSTRUMENTS TYPE M ANU F ACTU RE R'S MODEL NUMSER R ADI ATION SEN81TIVITY Y OF NAME NUMSER AV AIL AB L E DETECTED RANGE N INSTRUMENT lotphs. beto, (mollaroentgens/ hour
- E gO. ******"***"I *'***"'#l**""'*I A B C D E F
,,, Describe in at :achment 3, sec tion 10 (2)
(3) (4)
- 11. CALIBRATION OF INSTRUMENTS LISTED IN ITEM 10 C o. C ALIBR ATE D BY SERVICE COMPANY , Ob. CAllBRATED BY APPLICANT NAME, ADDRESS, AND FREQUENCf Attach a seesrete sheet cesersbong method, frequency and standards Used fo! Colobleting onstruments.
attachment 3, section 11
- 12. PERSONNEL MONITORING DEVICES TYPE S UPPLIE R (Serroce Companyl EXCHANGE FREQUENCY (Check and/or comyte es opproproote 1 C O(1) FILM BADGE O MONTHLY O(2) THE RMOLUMINESCENCE O QUARTERLY DOSIMETE R (TLD)
O (3) OTH E R (Specotv): O OTHER (Specoty):
- 13. F ACILITIES AND EQUIPMENT (Check were appropriate and attach annotated sketch (es) and description (s).
Oe L ABOR ATORY F ACILITIES. PL ANT F ACILITIES, FUME HOODS flacAude fortretion. sf eart ETC. O b. STOR AGE F ACILITIES. CONTAINE RS, SPE CI AL SHIE LDING (/,med and/or temporaryl, E TC. Oc REMOTE H ANDLING TOOLS OFl kOUIPMf NT. ETC. attachment 3, section 13 Od RESPIRATORY PROTECTIVE EQUIPMENT. ETC.
- 14. WASTE DISPOSAL e.NAME OF COMMERCIAL WASTE DISPOSAL SERVICE EMPLOYED attachment 3, section 14 t>. lF COMMERCIAL WASTE DISPOSAL SERVICE l$ NOT EMPLOYED SUBMIT A DETAILED DESCRIPTION OF METHODS WHICH WILL BE USED FOR DISPOSING OF RADIOACTIVE WASTES AND ESTIMATES OF THE TYPE AND AMOUNT OF ACTIVITY INVOLVED.lF THE APPLICATION IS FOR SE ALED SOURCES AND DEVICES AND THEY WILL BE RETURNE D TO THE MANUF ACTURER.SO STATE
_ .~
- O RM N RC 313 I (179)
l INFORMATION REQUIRED FOR ITEMS 15,16 AND 17 Describe in detail the information required for items 16,16 and 17. Begin each item on a separate page and key to the application as follows: , 15. RADIATION PROTECTION PROGRAM. Describe the radiation protection program as appropriate for the material to be used including the duties and responsibilities of the Radiation Protection Offimr. control measures, bloessay procedures (/f needed), day to day general safety instruction to be followed, etc. If the application is for sealed source's also submit leak testing procedures, or if leak testing will be performed using a leek test kit, specify manufacturer and model number of the leak test kit.
- 16. FORMAL TRAINING IN RADIATION SAFETY. Attach a resume for each individual named in
; Items 6 and 7. Describe individual's formal training in the following areas where applicable, include the name of person or institution providing the training, duration of training, when training was received, etc.
- a. Principles and practices of radiation protection,
- b. Radioactivity measurement standardization and monitoring techniques and instruments.
- c. Mathematics and calculations basic to the use and measurement of radioactivity,
- d. Biological effects of radiation.
- 17. EXPERIENCE. Attach a resume for each individual named in items 6 and 7. Describe ind.ividual's work experience with radiation, including where experience was obtained. Work experience or on.
tha job training should be commensurate with the proposed use. include list of radioisotopes and maximum activity of each used, see attachment 3, sections 15,16 and 17.
- 18. CERTIFICATE IThe otem must be compMted by sophcat)
The applicent and any Official executing tMr certificere on behalf of the applicent named in from 2, certify that this application is propered an conformity with Title 10. Code of Federal naeulations. Port 30, and that att unformat,on co*steined Mreas, onclud.ng any supplements artached hereto. is true and correct to the best of our knowkdge and behef. G1: llV 82 W (8. WARNING.-18 USC.. Section f001: Act of June 25.194a; 42 Stat. 749; makes it e criminal off ense to nahe a willfully f alse statement or representation to any department or seeney of the United States as to any matter within its jurisdiction,
- s. Lli.;ENSE FEE REQUIRED b. CE RTIFYI OF FICI AL Sanneverel tsee sect on 110.31, 10 cFn trol Sn if, J tx
$950.00 c, N A M E (Trpe' t g yn A.J. Bindon (1) LICENSE FEE CATEGORY: 3}{ d. TITLE president e.DATE (2) LICENSE FEE ENCLOSED: $ 950.00 July 27, 1983 FOmh4 seRC 313 I (179)
e Attcchment 3, page 1 NRC-3131 Supplemental Information Section 22, Radiation Protection Of ficer Glyn A.J. Bindon operates as the radiation protection officer. He has received guidance in the past f rom Dr. Henry Grif fin, Ph.D. during his association with Environmental Research Group, Inc. (ERG) Although Dr. Grif fin is no longer associated with ERG, he is still in the Department of Chemistry at the i University of Michigan, and is available to Armson, Inc. on an as required consulting basis. Dr. Richard Copeland is now associated with ERG, and is also available for c onsult a tion. ERG continues to conduct tests and make reports as described in this application. Section 14. Waste Disposal Armson, Inc. vil) only handle complete reticle assemblies in its vaste disposal program. Old reticle assemblies would be tMken out of service af ter about 10 years of use. This would be done by Armson Inc. only, and when a customer returns his gunsight f or a new reticle. Any reticle assemblies found to be def ective for other reasons such as an out of shape dot or a broken daylight collecting rod, vill also be included in the vaste disposal program. Old and def ective reticles vill be sent to Saunders-Roe Developments, Inc. in Winston-Sales NC for inclusion in their vaste disposal program. This disposal action vill be done when 100 such reticle assemblies are collected, or at the end of 10 years, whichever occurs first. A commercial carrier vill be used to transport , the vaste to the disposal site. Section 15. Radiation Protection Program Armson, Inc. personnel vill continue to be informed that reticle assemblies vill not be disassembled. They will continue to be inf ormed that tritium is a radio-active substance, and that the reticle assemblies should be handled with care. Section 16. Formal Training in Radiation Safety Formal training in radiation safety is not required. Section 17. Experience Glyn A.J. Bindon and Carolyn R. Bindon now have more than one year of experience in oeeting the requirements of an NRC general license. 1
s Attachment 3, page 2
.( ,
ERG SUPPLEMENT TO ATTACHMENT 3 Section 10 Radiation Detection Instruments
; Scintillation counter, Beckman, LS 3150, beta radiation detected, '
background 20 counts per minute. Section 11 Calibration of Instruments Listed in Section 10
- a. Calibrated by service company.
University of Michigan Radiation Control Service Ann Arbor, Michigan 48104 Once per year Section 13 Facilities and Equipment
- a. Laboratory facilities, plant facilities, fume hoods, etc.
ERG is a fully equipped environmental testing lab. Dispensing of scintillation fluid for wipe tests is performed in a fume hood,
- b. Storage facilities, containers, special shielding, etc.
ERG has a storage area underneath a fume bood for any l radioactive material, l l
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. Attcchmert 3, p:ge 4
' ERG Supplement to attachment 3, section 17 7 EEREESs10gA( 3[10g[
NAME: Henry C. Griffin EDUCATION: Ph.D. , Nuclear Chemistry, M. I.T. B.S. Chemistry, Physics & Mathematics, Davidson College POSITION: Manager, Nuclear Studies Department i CADABILITIES: e Nuclear Chemistry e Radiation Measurements e Nuclear Systems e Background Radiation Studies e Computer Applications EXPERIENCE: Environmental Research Group, Inc2 Directs and supervises all of ERG's nuclear studies throughout the United States. Responsible for develop-ment of low level background measurement systems and computerization of ERG s nuclear chemistry facilities. - Broad experience in fission chemistry and analytical i analysis or plutonium isotooes. Department of Chemistry, University of Michigan Assistant Professor, 1964-70, Associate Professor, 4 from 1970 on; Director of Freshman Studies, 1974-78. Department of Nuclear Engineering, University of California (Berkeley) Visiting research engineer (with S.G. Prussin) 1978-79. Lawrence Livermore Laboratory; Nuclear Chemistry Division Sumer 1978. Swiss Federal Reactor Institute Wurlenlinger, Switzerland Guest scientist (with H.R. von Gunten) 1971-72. Argonne National Laboratory Research associate, chemistry division, 1962-64 (with L.E. Glendenin), guest scientist, sumers 1965, 1966, 1967, January-August 1968. E NVIR ONME NT AL Ri$l ARCM GROUP. INC.
Attachment 3. Date s
- Ilenry C. Griffin ,
(. Resume ! Page Two i 4 PUBLICATIONS: Over 40 publications from 1961 to the present dealing ' with all phases of nuclear chemistry and computerization of nuclear measurement systems, i AFFILIATIONS: American Chemical Society A;nerican Physical Society American Association for the Advancement of Science Recognized in American Men & Women of Science 14 ed. 1979. 0 i I 1 i ! t l ( E NvimoNut NT AL mtst AmCM cmoVP. INC. i
a tachment 3, page 6 PR0FESSIONAL RESUME ! MAME: Richard A. Copeland v EDUCATION: Post Doctoral Research, Aquatic Chemistry. University of Michigan Ph.D., Environmental Chemistry, Massachusetts Institute of Technology B.S., Geology and Chemistry, University of California at Berkley POSITION: Vice Chainnan of the Board of Directors Nuclear Studies Manager CAPABILITY: o Management and Control of Larger Projects o Management of Research and Development Programs o Environmental Impact Assessment o Unique Nuclear Chenistry Background for Nuclear Activation Analy'. EXPERIENCE: Environmental Research Group, Inc. ' President and Senior Program Manager, problem identification and problem solving. Responsible for guiding the growth of ERG from its inception to one of the nation's leading environmental analytical firms. Currently responsible for developing the company's new product and service areas and directing the Nuclear Studies Program. Specialist in environmental measurements, air, surface and subsurface processes, and problems associa'.ed with hazardous wastes. 4 Great Lakes Research Division i The University of Michigan Ann Arbor, Michigan Assistant Research Chemist responsible for major project ' to analyze the effect of atomic power plant effluent in
! the Great Lakes Region. Measuring, tracing and monitoring utility air quality.
Department of Earth & Planetary Science l Massachusetts Institute of Technology i Cambridge, Massachusetts Served in a variety of teaching and research positions in , j the field of geochemistry.
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tachment 3, page 7 RESUME Richard A. Copeland Page Two PUBLICATIONS: Over 15 publications / presentations including three ERG special reports published in collaboration with other staff members and consultants. The latter constitute significant contributions to environmental research as conducted under his jurisdiction. i AFFILIATIONS: Director, Association of Environmental Laboratories Sigma Xi American Association for the Advancement of Science 1 l I 1
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- AttacF nt 3, page 8 PROFESS 10NAL RESUNE
- NAME
- David R. Bowman EDUATION: The University of Michigan Expected Date of Graduation April 1984 Bachelor of Science in Chemistry c
POSITION: Nuclear Analyst EXPERIENCE: Responsible for preparation and performance of all standard radiochemical procedures: gross alpha, gross beta, radium-226, radium-228, and strontium-90 analysis; conducts Haloscans, T0X by Dohrmann, Tritium, and a full-scan Neutron Activation analyses. Prepares and checks all standard solutions for calibration of methods, prepares spikes, and maintains electronic equipment. I i e
Aichment 4, page 1 I 1 ATTACHMENT 4 t ERG Test Report L
- 1. Introduction
^
it was required to subject the Armson 0.E.G. Day / Night gunsight to stress tests in accordance with applicable portions of American National Standard N540--Classification of Radioactive Self-Luminous Light Sources, and procedures developed by leadership Keys, Inc.
- 11. Test procedures A. Life Cycling The test was carried out according to the procedure developed by Leadership Key's, Inc. described in Attachment 5.
The test gunsight was fired 1000 rounds on a Colt 45 pistol with , weaver grip and wipe tests were performed on the sight. The gunsight was then installed by a gunsmith onto a Colt 45 oistol, and fired 500 rounds at a temperature of 66-70'F. , Wipe tests, in accordance with section D of this attachment, were perfomed after each 100 rounds, and the source was visually y tested for loss of luminosity in a dark room af ter each 100 rounds. B. Thermal Shock Test The test was carried out in accordance with ANS N540, paragraph ! 7.4. The test gunsight was heated to a temperature of +80'C in a drying oven, and was held at that temperature for 15 minutes. The test gunsight was transferred within 15 seconds to an insulated chamber containing a block of dry ice. The gunsight was allowed to reach a temperature of -55'C and remain there for 15 minutes. The test gunsight was then allowed to return to room temperature in a desiccator, 4nd a wipe test was performed in accordance with section D of this attachment. The source was visually tested for
. loss of luminosity in a dark room C. Reduced Pressure Test The test was carried out in accordance with ANS N540, paragraph 7.5. ,
The test gunsight was placed in a chamber at ambient temperature and the pressure was reduced to 175 m Hg (absolute) and kept ; constant for 15 minutes. The pressure was then restored to ' ambient. This :ycle was repeated three more times.
; i%vimosui stat aise anew cace. mc. l l
A chment 4, pane 2 f The test gunsight was visually inspected for luminosity in a dark room, and a wipe test was done in accordance with section - 0 of this attachnent. L
- 0. Wipe Test Procedure Wipe tests were done using dry filter paper following tests described in paragraph A and using filter paper moistened with isopropyl alcohol following tests described in paragraphs i B and C. Each of the 5 access holes were wiped and placed in scintillation vials, and the standard test Method of ANSI / ASTM D 2476-77, as applicable, was conducted.
111. Test Report No luminosity loss was cbserved at any point during the testing, and all wipe test results were at background levels. IV. Radiation Safety Report In reference to 32.23 safety criteria, there would be no external radiation dose from the tritium in normal use, and the ;eits conducted demonstrate that the gunsight would remain undamaged during normal use. Even in the unlikely event that the lamps were damaged and the tritium escaped, only a small fraction of the gaseous tritium 'r;uld be inhaled by any persons in the area. l ' (Nvim0 Nut NT AL mtst sacM cmoyo, ..;;, a
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.c tach:nent 4, py.,e 3 l'
I 9 4 January 11, 1982 Mr. John W.M. Hickey, Section Leader Industrial Section Material Licensing tranch > Division of Fuel Cycle and hterial Safety United States Nuclear Regulatory Commission Washington, DC 20555 l
Dear Mr. Hickey:
l As requested by Leadership Keys, Environment,al Research Group, Inc. (ERG) performed an !spact Test on the Armson 0.E.G. gunsight. In order to expedite receipt of hig license, Mr. Sindon has requested that we i send a report directly to you. The reference number to which this report applies is #09045, tritium gunsight. Thank you for your consideration, i Sincerely, N ey Barker helear Studies Enclosure MB/sek 4 I f -,5$ \ ' m{'T f n igyd j (,/ /
P 6 s - Attachment 4, page 4
- / l i
IMPACTTESk . 4 An impact test was performed on gunsicht serial number 001276 in accord-ance with ANSI 7.6 table 2, level 4, < The sight, sounted on a M-16 rifle, was dropped 20 times in a randosi manner onto a steel plate on a concrete floor from a height of 1 meter.
; it was then dropped tuo timet onto the steel plate frai a height of 2 i meters, I wipe test with glycerol and a visual inspection for luminosity was performed af ter the 1-aater drops, and again af ter the 2-eater drops.
The gunsight was than taken of f the gun, and the same test performed, one of the drops at nach of the two heights being oriented directly onto the plastic dome, A report of observations is on tha next page of this report. All wipe test results were <0.005 uCl.and all visual inspections showed luminosity to be unaf fected.
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Attachanit 4, page 5
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IMPACT TEST s Observations During Impact Test. ^ At the third drop, the bolt-cecking handle of the M-16 broke off. At the fifth through seventh drops, the mount for the gunsight broke off. The bolt was found to have only 1/8" thread engagement into the i mount. . A longer bolt was installed before the eighth drop. At the twilf th drop, the daylight collector acrylic tslade portion of l ites 26 ' light soJrce" bro 4 4t 4he transitian from the small 1 x 2 mm rectangular sectio' to thg tritium lamps. The sight was still functional .
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At the seventeenth 4r'op, the itens 17 ' deme", item 18 'done circlip", item 16 ' dome seal", and item 15 ' retainer
- came out of the body. The broken blade portion of item 26 cree out alse. The item 26 "light source" remained in tM gunsight. The gunsight was still functional; a wipe test was conducted. Using a snap-ring plier, the same parts were replaced onto the gansight and the test resumed.
At the twentieth drop, the gun stock broke of f. It was re-installed and held in place with duct tape. Observation's Upon Completion of Impact Test - Ends of gunsight dented (flattened corners of aluminum hexagonal shape). Glass lens was still int 6ct. Dome remained intact during drops of sight alone. Up/down knob edge chipped. At least four burrs on front edge of dome. l I l l l
n Attachrent 5, p ge 1 Qualification Test Specification v 1.0 APPLICATION This Qualification Test Specification describes the performance and life requirements for Occluded Eye Gunsights. This specification adopts the applicable portions of ANSI H540-1975, American National Stantard N540; Classification of Radioactive Self-Luminous Light Sources, Ref.10 CFR 32.22
,, 2(xi).
2.0 SELECTION pF, TESTS The selection of tests, test levels, cyclic life and performance requirements shall be selected on the basis of a reasonable and documented study of market place use, worst case studies and failure mode and effects analysis. The purpose of this test will be to demonstrate acceptable life for most cus tome rs and to show that the design achieves the ever present objective of keeping radiotoxicity as low as practical. Separate reports on Worst Case Studies and Failure Mode and Effects Analysis are considered a part of this specification. 3.0 SAMPLE SIZE One sample guusight, representative of a production sample, made on production tools, either a prototype or an actual production sample shall complete all of the tests of this procedure, and shall comply with the listed perf ormance r equi rement s. 4 '
.40 TEST JCOUENCE The gunsight shall complete each of the tests below in the sequence listed.
4.1 ACCEDTANCE TEST The test gunaight shall meet all the requirements of the Acceptance Test Specification. If all of the acceptance tests have been performed, they need not be repeated. If the prototype or production sample gunsight has any test not completed, they shall be completed at this point. 4.2 LIFE CYCLING l The test sample shall be mounted on a Colt .45 Automa tic Pis tol. The mounting shall be made to the slide portion of the gun. The initial mounting, which involves drilling and tapping holes in the slide, shall be done by a competant gu nsmi th. Subsequent repeated installations may be done by the test operator. j ' The gun shall be fired 100 times with 230 grain maximum f actory loaded a mmunit ion. The ambient temperature shall be recorded. The gun may be sighted i in with slow fire, or used in any sequence of target or competitive shooting. i Af ter 100 cycles of firing, the night lamp shall be checked for befug lit. The l opertator shall enter a dark area no lighter than shaded ooonlight. The dot shall be visible to an unaided normal eye within 10 minutes of entering the dark nrea. The glycerol wet vipe test for liquid scintillation counting (wipe test)
i l i Atte ament 5, page 2
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as specified in paragraph 2.7 of the Acceptance Test Specification shall be performed. After the lamp lit and wipe test has been done, the gun shall repeat the 4 sequence of 100 cycles of firing, lamp lit and wipe tests four additiocal times, f or a total of 500 cycles of firing. 4.3 THERMAL SHOCK The thermal shock test of ANSI N540 shall be conducted to test level 4, -55 degrees C and 80 degrees C. i tests as in paragraph 4.2 shallAfbe terconducted. the thermal shock test, the lamp lit and wipe 4.4 ALTITUuE The abs. reduced pressure test of ANSI N540 shall be conducted to level 4, 87mm Hg Af ter the reduced pressure test, the lamp lit and wipe tests as in paragraph 4.2 shall be conducted. 4.5 LMPACT TEST The impact test of ANSI N540 7.6, table 2, level 4 shall be conducted on the gunsight. The gunsight shall be mounted on an M-16 rifle or a rifle which is a replica of the M-16 in weight and structure. The gun and gunsight asseably. shall be dropped ir; a random manner onto a steel plate on a concrete floor. The operator shall orient the drops so that the gunsight hits first on at least one drop from each of the 1 meter and 2 meter heights. After the twenty-two drops, the lamp lit and wipe tests of paragraph 4.2 shall be conducted. The gunsight shall be removed f rom the gun and the same drop test sequence repeated on the gunsight by itself. It shall be dropped in a random fashion except that the operator shall orient the drop so that at least one hit from each of the 1 meter and 2 meter heights occurs on the polycarbonate f ront dome of the gunsight. After the second series of twenty-two drops, the lamp lit and wipe tests of paragrapn 4.2 shall be conducted. 5.0 EVALUATION The gunsight shall pass the requirements of this specification if the lamp remains lit and the results of liquid scintillation counting is less than 5 nano-curies for each of the wipe tests. The test sample shall be kept ,available for inspection for a period of one year f rom the date of this test. Revised January 8,1982 to include imapet test
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Attachment 6, page 1 ACCEPTANCE TEST SPECIFICATION 1.0 APPLICATION 4 This specification identifies the minimum requirements for occluded eye gunsights. The gunsight must comply with all portions of this specification. The information in this specification is confidential, and its use is restricted to those persons and agencies authorized by Armson, Inc. 2.0 REQUIREMENTS The gunsight must conform to the package dimensions shown on the applicable Package Envelope Control Drawings. The gunsight must contain all of the elements listed on the bill of material assembled cs shown on the Assembly Control Drawing. Each shipment must be certified to comply with all of the requirments of the ARMSON 0.E.G. Quality Control Procedure. 2.1 ENGINEERING AND DESIGN TEST STANDARDS 2.1.1 REGULATORY REQUIREMENTS Regulatory requirements are corporate interpretations of legal requirecents based on f ederal and state regulations. These requirements are mandatory and deviations are not permitted. U.S. Nuclear Regulatory Cocmission (NRC) . requirements are an example of regulatory requirements. Reference 10 CFR 32.22 and 32.25. 2.1.2 CORPORATE REQUIREMENTS Corporate requirements are critical, important or highly desirable features or needs which, if not met, could be expected to result in definite customer dissatisf action and/or unacceptable function. Deviations require the approval of the President of Armson, Inc. 2.1.3 RECOMMENDED PRACTICES Recommended practices are design guidelines, the deviation from which could result in mild customer dissatisf action and/or functional compromise, Deviations to recommended practice are permitted at the discretion of the President of Armson Sales (Pty) Ltd. provided notice of such deviations are sent to Armson, Inc. for concurrence along with a shipment which contains such deviations. 2.2 APPEARANCE The exterior body color finished in a flat black shall be tccommended practice f or all the police and military applications. A shiny black anodized finish shall be recommended practice for hunting rifle applications on the standard model. The front plastic dome of frosted polycarbonate plastic shall be recommended practice. Clear domes shall not be recommended practice. A small red and white logo, formed in appearance like the markings on the shipping cartons, and reading "ARMSON 0.E.G." with a solid red 0 in Armson attached pecmanently to the gunsight shall be recommended practice. When and if a United States Trademark is approved f or the logo, the addition of a small encircled R to the logo would be a corporate requirement.
Attschment 6, psgo 2 2.3 _ RETICLE ADJUSTMENT The gunsight shall have separate controls for windage and elevation. A means to lock said adjustment to prevent inadvertent aisadjustment and to discourage
- tampering shall be recommended practice.
-L Reticle adjustment shall be provided to allow plus or minus 0.75 degrees (plus or minus 45 Minutes Of Arc, MOA) f rom the centered position for both windage and elevation. 2.4 LENS MAGNIFICATION AND FOCUS i Recommended practice for the lens system shall be to provide an aiming dot of 8 plus or minus 1 MOA. The dot shall be circular ard focused at a distance of 20 f eet or further. The dot shall be orange when illunicated by daylight. 2.5 NIGHT RETICLE The night reticle may be red in color. The dot shall be visible to an unaided normal eye within 10 minutes of the person and the gunsight being enveloped in darkness no lighter than shaded moonlight. The requirements of this paragraph shall be recommended practice. 2.5.1 NIGHT RETICLE ILLUMINATION The se e dot as observed in the daylight function of paragraph 2.4 shall be illuminated by tritium lamps for night use. Two lamps, each of 80 milli-curies each shall be used. The lamps shall be of the sealed glass design, internally coated with phosphor and containing tritium gas. Sauders-Roe Developments Ltd. Betalight part number PRH 880/G/200 or M.B. Kicrotec A.G. No. T4303-1 shall be used. The two lamps shall be mounted as shown on the Assembly Control Drawing. The requirements of this paragraph shall be a regulatory requirement. 2.6 LAMP LIT QUALITY CONTRO,L_ The lamp lit function shall be visually inspected at each stage of manuf acture of the gunsight. Both lamps must be verified by visual inspection 24 hours af ter the acrylic light collector is attached to the aluminum reticle holder. This inspection shall be done before the black-out paiut is applied. Any reticle with a lamp that is not lit shall be rejected. The details of Armson Sales (Pty) Ltd. Quality Control Proedure as they relate to the installation of the lamps, and all of the requirements of this paragraph snall be a regulatory requirement. , 27 LIQUID SCINTILLATION COUNT ON_ FINAL ASSEMBLY Standard model gunsights have 5 access holes which are sealed. In addition to these, other mounting styles usually have two holes in which threaded screws attach the va rious mounts. Each of these 5 or 7 holes as applicable shall be wiped with a small piece of filter paper wet with glycerol or deionized water. The residue from the wet wipe shall be placed in the counting vial. The standard test method of ANSI / ASTM D 2476-77 as applicable shall be conducted. The results of the liquid scintillation counting shall be less than 5 nano-curies for each sample. This test shall be perf ormed per sampling in 10 CFR 32.110 table (3), 2% def. After the counting test of this paragraph, the units shall be placed inside individual
s..cachment 6, page 3 cartons destined for the final consumer. The requirements of this paragraph shall be a regulatory rquirement.
)
2.8 REPORTING AND RECORD KEEPING ,
" Each production unit shall have a unique serial number. Shipping invoices shall indicate the serial numbers of the units contained in the shipment. Units subjected to the tests of paragraph 2.7 shall be recorded on the test report.
The records of the tests shall be maintained for a period of two years from the date of the test.
,. 2.9 . QUALIFICATION TESTS AND DESIGN CRANGES l The design submitted for approval shall complete the Qualification Test Specification requirements. Design changes which affect the completeness of the qualification testing shall be cause for a repeat of the qualification testing.
Such repeat testing shall be cause for the filing of an ammendment to the NRC license. The requirements of this paragraph shall be a regulatory requirement. 3.0 LABELING AND DISTRIBUTION REPORTS Each gunsight shall be labeled in accordance with 10 CFR 32.25 (b). The label I shall bear the following information: ) "ARMSON 0.E.G. Contains tritium. The purchaser is exempt f rom any regulatory l responsibilty. Arcson, Inc. , P.O. Box 2130, Fa rmington Hills, Michigan 48018." Armson, Inc. , shall make annual reports of distribution per 10 CFR 32.25 (c) within 30 days of June 30 each year. The annual report shall be filed with the Director of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington DC 20555 with a copy to Region III, USNRC. 799 Roosevelt Road, Glen Ellyn, IL 60137. l
a mt 6, paga 4
. Environmental Research Group Nuclear Studies Department Wipe Procedure - Tritium v 1. Dampen 1/4 section of Whatman #40 filter with D.I. H20.
- 2. Wipe sample surface thoroughly.
- 3. Place filter in centrifuge tube along with 11/2 ml of 0.I. H 20.
- 4. Shake capped tube for 24 hours.
- 5. Remove 1 ml of H 2 O from tube, add 10 ml !..S.C. and count along with standards (1 ml standard 8H water solution) and blanks (blank filter extracted with 1 1/2 ml D.I. water - count 1 ml + cocktail)
- 6. Report results as:
nCi in sample = (cts smp - cts bik) cts std nCiinstd] 0.667 (detection limit for leadership project is 5 nCi) l \ .
AP chment 7, page 1 PROJE T 0247 l (( { REPORT DATE 01-17-83 ENVIRONMENTAL RESEARCH GROUP,INC.
/-" 117 N. FIRST ANN ARBOR. MICHIGAN 48104 (313) 662-3104 1
" CLIENT P.O . GLYN BINDON SAMPLES RECVD: 01 3 REPORT: 10497 l REFER TECHNICAL QU TO: DR. RICHARD C CLIENT:
' LEADERSHIP KEYS, INC. APPROVED: .4d J I^^^
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PO BOX 2130 j i FARMINGTON HILLS,MI 48204 ese i RESIDUAL SA. LE WILL ATTENTION: GLYN BINDON BE HELD FOR WO WEEKS see i CLIENT I . D. . 002847 REMINGTON SG ERG SAMPLE NO: 01/083759 MATRIX: SOLID PARAMETER RESULTS UNITS g WIFE TEST - RADIATION (SOLIDS) <5 nCi i CLIENT ID 002E55 REMINGTON SG l ERG SAMPLE NO 01/033760 MATRIX SOLID l
- PARAMETER RESULTS UNITS WIPE TEST -
RADIATION (SOLIDS) <S nCi CLIENT I. D . 002822 REMINGTON SG EFAG SAMPLE NO: 01/083761 MATRIX- SOLID PARAMETER RESULTS UNITS WIPE TEST - RADIATION (SOLIDS)
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; CLIENT ! . D. . 2837 H & K G3 ERG SAMPLE NO: 01/083842 MATRIX: SOLID PARAMETER RESULTS UNITS WIPE TEST - RADIATION (SOLIDS) <S nCi DESORPTION EFFICIENCY FOR BOTH CCMPOUNOS WAS 1.00 i.
l 1 l FR - SEE FIELD REPORT FOR RESULT NA - NOT APPLICABLE TO TEST REQUESTED ND - NONDETECTED, DETECTION LIMIT IN () SD - SAMPLE DAMAGED I SR
< - SEE ATTACHED REPORT FOR RESULT
- POSITIVE RESULT BUT AT UNQUANTIFIABLE CONCENTRATION BELOW INDICATED LEVEL l THANK YOU FOR YOUR BUSINESS ?
l PAGE 18 LAST PAGE
n - r AR e 'SA*ES tw 9 ~g'* .j'.'. /I,I L L e# ( u rs .r.c4 T , P.O. BOX 426. NEW GERMANY 3620. TEL: 713512
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D':achment 8, page 2 ARMS N O.E G, ARMSON, INC. P. O. Box 2130 OAY/MGHT/ LOW LIGHT INCREO!BLY FAST GUNSIGHT Farmington Hills, Michigan 48018
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r T l ; u u u Standard Model shown full size above. Other models with integral mounts as listed below. Model A3X505 0 3.G. Binocular gunsights Description, Sight with mount fort St anda rd A1-15 Fits 1-inch ring mounts, rings not included Mini-14.180 Fastens to Colt A1-15 or M-16 with one out Mini-14,Ill& luger Mini-14, gunsmithing on all models Berette Ruger Mini-14 and AC $56, modsis 181 6 sub. A-301, A302 12 sauge shotsva Browning Auto-3 12 gauge shotgun Mossberg t emingt on Model 500 and 600 12 gauge shotgun tandgun Models 1100 and 8 70,12 gauge, Catil Vith adapter to fit Bushnell Fhantos, note FE-FAL
.223 6 .308 semi & full auto rifles, NEW In c lud e s dia a t cove r f o r F5 -1.k.1, s e e no t e I&K Models 91, 93, C-3, MP-3 etc.
U21 tan Seal Auto model A,8 or full suto $2 1abeling: See Attachment 6, page 3, parra 3.0
Failure Mode and Effects Anal. .s (FMEA) 8' 1.0 PURPOSE . Considering 10 CFR 32.22 2 (v) and (xi), the purpose of this study is to examine possible w:ys that the reticle assembly could be damaged and therefore cause lamp breakage and subsequent loss of tritium gas. The reticle assembly and its mounting were studied in detail for possible modes of failure. i !
2.0 DESCRIPTION
- RETICLE ASSEMBLY l l
ne d9scription here is made in conjunction with the annotated assembly drawing of cttcchment 8, page 1. The reticle assembly consists of two tritium lamps (27) each measuring .24 inches long, .12 inches wide and .06 inches thick. The lamps are { surrounded on five of the six sides by the acrylic ambient light collector (26) which is a single injection molded part. n e lamp is held in this cavity by snicone elastomeric type of adhesive (28). The sixth side of the lamp is covered by - e thin brass plate (25) which forms the small aperture objective of the lens system. i Tha cerylic collector (26) is held into the aluminum holder (24) using silicone ' l cdhssive.
3.0 DESCRIPTION
- RETICLE ASSEMBLY MOUNTING I
Tha reticle assembly is restrained axially by a rear face in the aluminum body (1) and l by e steel plate (15), an elastomer seal ring (16), a polycarbonate dome cover (17), l and a snap ring (18) uhich is installed in a groove in the same aluminum housing (1). ! The raticle assembly is restrained laterally by a three point radial contact system. Two threaded brass studs (9) at 90 degrees to each other radially are in contact with tha nacked down portion of the aluminum holder (24). These are the screws that permit adjustment of the gunsight for windage and elevation. At an angle of 135 degrees to both brass studs (9) is a stiff stainless steel spring (23). The brass studs pass through a square hole in the aluminum body (1) and into a brass retainer (12) which hos en 0-ring seal (10) and a snap ring (11) which holds the brass retainer (12) in the l cluminum body (1) . The brass retainer (12) is turned by a plastic knob (14) with l engegsment tabs that fit into a slot in the brass retainer (12). The plastic knob is locked to the brass retainer with a threaded screw (13). The lens system (5) is i mountsd I ring in aa rubber (2) and washerspecial seat (6) and a seal (4) and held in the body (1) by a snap (3). The stainless steel spring (23) is guided in a hole in the l body (1), preloaded by a steel place (21) resting against a snap ring (20) which fits in c groove in the body (1). The steel plate (21) is sealed by an o-ring (22). This complates the description of the standard models. The models with special mounts i hava various mounts (7), nade of aluminum extrusions and attached to the body with two i scrsws (8) . The standard models do not have the screw holes. l 4.0 ANALYSIS Each of the component parts 6f the reticle assembly were accurately weighed, m Accolerations were calculated based on part weights and forces that could cause i failure. The results are tabulated on page 2 of this attachment. I
5.0 CONCLUSION
Shock loading from firing a gun would produce accelerations along the axis of the gunsight because it is aligned with the bore of the gun in order to serve its sighting purposo. Analysis indicates that bending of the steel plate (15) would occur at loads in excess of 4,113 "G". At a "G" load 34 times higher, 142,000 "G" is the next n2arest failure mode of another part. From actual test firings, no such damage was sasn. It is concluded that the tritium lamps are safely contained and satisfy the requirements of 10 CFR 32.22 2 (xi). In addition, based on the opinions of several experts in the firearms field, the shock load f rom firing the gun is much more severethan the shock loads produced by a drop test. For this reason a drop test is not necessarv,
,..s _ . . , , _
Worst Case Studies ' 1.0 PURPOSE ' f i In consideration of 10 CFR 32.22 2(xi), a worst case study was undertaken in addition to consulting with many experts in the firearms field. There exists a very large number of different firearms that could be tested. The worst case study method enables of potential the applications. logical choice of testing the worst case and satisfying the entire population l l 2.0 DESCRIPIION OF WORST CASE STUDY l Two methods of comparison were used. ! FIRST: The maximum acceleration in "G" units was calculated from the theoretical recoil force divided by the weight against which the acceleration force acts. SECOND: The theoretical recoil energy felt by the person using the gun. Ihe 10 sample calculation are chosen to represent the entire field of handheld small arms. Based on expert opinion, the other calibers can be shown to be less severe i l and/or in between those shown on the chart of page 2 of this attachment. l The calculation method of the chart is self - explanatory when studies in conjunction with the footnotes to the chart which are on pages 3 and 4 of this attachment. The Colt .45 ACP is chosen as the worst case based on the very high calculated acceleration of 4,478 "G". This calculation is borne out by actual tests by Colt. Mr. Jim Taylor of Colt Firearms Division of Colt Industries reprts measuring 5,000 "G" on the slide of a Colt .45 ACP. This choice is supported by many other experts. The total calculated recoil energy of very large bore hunting rifles is damaging to the shooter's shoulder, not the gunsight.
3.0 CONCLUSION
The Colt 45 ACP (Automatic Pistol) should be used for qualification testing. The test gunsight should be mounted on the slide of the pistol in support of the calcule* - worst case method. 1 1
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- Att chment 10, paga (21 308 12 357 44 45 30-06 300 3 75 458 Win. gauge Magnum Rem. ACP Win. H&H Win. .
7.72 nun Shotgun Magnum Magnum Magnum Magnum NATO Auto. Auto. Revolver Revolver Auto. Auto. Auto. Bolt Bolt Rifle Shotgun Handgun Handgun Pistol Rifle Rifle Rifle Rifle 20 8 2 a/ a/ a/ a/ a/ a/
.308 .729 .357 .429 .451 .308 .308 .3 75 .458 .0745 .4174 .1001 .1445 .1598 .0745 .0745 .1104 .1647 52,000 12,500 46,000 43,500 19,900 50,000 54,000 53,000 53,000 3874 5217 4605 6288 3179 3725 4023 5854 8732 9.56 e/ 7.20 f/ 2.40 g/ 3.15 h/ 1.42 1/ 7.90 J/ 8.90 k_/ 9.02 m/
9.02 1_/ 405 725 1,919 1,996 2,239 472 452 64 9 968 810 1,450 1,919 1,996 ( f) 944 9 04 649 968 2620 1560 1235 1410 851 2700 3000 2530 2110 2743 2364 535 1060 372 2913 3597 4263 5041 180 438 158 240 230 180 180 300 510 51 36 17.8 24.7 10.2 60 86 86 86 16.5 26.0 6.9 15.4 5.1 23.8 35.0 45.7 68.3 l
s . Morst Case Studies .ittachm2nt 10, p:ge 3 COMPARISON CHART FOOTNOTES [ The calibers chosen for study in these worst case studies represent two main groupings. The first grouping is based upon the projected sales volume of the gunsights. The first four columns show 98 per cent of the anticipated volume, The other calibers have been chosen based upon the opinion of experts that these represent heavy recoil high powered calibers, a/ These are very small anticipated volumes, but are applications that could be used. b/ This is an industry standard. SAAMI is the abbreviation for: Sporting Arms and Ammunition Manufacturers Institute, P.O. Box 218, Wallingford, CT 06492 Telephone (203) 265-3232 c/ The theoretical peak recoil force obtained from multiplying the bullet cross sectional area by the SAAMI pressure. The following gun weights were obtained from published data or from actual sample weighing. d/ .223 Rem. Auto loading military type rifles Gun Weight Gunsight Combined Colt AR-15 and M-16 7.35 Ruger Mini-14 and AC 556 .34 7.69 6.80 .38 7.18 Heckler & Koch HK 93 8.07 .48 8.55 e/ .308 Nato auto loading rifles, military type Heckler & Koch HK 91 10.32 Fabrique Nationale FN-LAR .48 10.80 9.94 .36 10.30 Springfield Armory M1-M1A 8.94 .62 9.56 f/ Auto loading 3 inch magnum shotguns Beretta A-301 Browning Auto-5 6.88 .32 7.20 Remingon Model 1100 8.62 .32 9.94 8.00 .32 8.32 Pump action 3 inch magnum shotguns Mossberg Model 500 ATP SP 7.25 .32 7.57 Remington Model 870 pump 8.00 .32 8.32 g/ .357 Magnum revolvers Smith & Wesson Model 19 1.94 Colt I.awman Mk III .46 2.40 Ruger Security 6 2.00 46 2.46 2.09 .46 2.55 Dan Wesson Model 15 . 2.00 .46 2.46 hl .44 Magnum revolvers Smith 6 Wesson model 29 2.69 Ruger Blackhawk 46 3.15 3.00 .46 3.46 1/ 45 ACP automatic pistol Colt Gold cup National Match Model Mk IV 2.41 .33 2.74 Colt slide and barrel only portion 1.09 .33 1.42 J/ 30-06 Auto loading rifles Remington Model 7400 Browning auto rifle 7.50 .52 8.02 7.38 .52 7.90 k/ .300 Win Magnum rifles, auto loading Browning auto rifle 8.38 .52 8.90
en
- Woyst Coso Studies At g ae.hmen t 10, page 4
. C_0MPARISON. CHART FOOTNOTES (continued) g 1/ .375 H & H magnum bolt action rifles Remington Model 700 Gun Weight Gunsight Combined Winchester M/70 XTR Magnum 9.00 .52 9.52 8.50 .52 9.02 '
m/ .458 Win. Magnum bolt action rifles Remington Model 700 9.00 .52 9.52 Winchester M/70 African 8.50 .52 9.02 Item 10, Calculated acceleration, from the recoil force divided by the gun weight .
; Item 11, Calculated acceleration with slap factor.
slap factor of two applied to the acceleration obtained in item 10.All autoRevolvers loading guns ha and bolt action rifles have no slap factor applied. The remaining items in the chart are the items which lead up to the sensation of felt recoil in a firearm. 0 0 l 1
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At hment 11, page 1 i STATEMENT OF UNDERSTANDING This license application is for a new exempt license for the same now under the general license to Leadership Keys, Inc. gunsigh s sold #
; gunsights can continue to be sold under the generalWe understand that-license providedthe that reporting and all other regulatory matters are adhered to.
Upon begin toissuance of en txept license as herein applied for, distribution could persons exempt. exempt license is issued can be completed either way.It is expected that o We understand that the aplicable to both licenses.saf ety inspection procedures of the liquid scinti Under the conditions imposed by the general license, it 25304 Farmington Road, Farmington Hills, Michigan could only46018be used at except being
- 10) permitted to taken to temporary job sites anywhere in the US for 15 gunsights We understand that under the exempt .
(Condition temporary job sites anywhere in the US. license, any quantity may be taken to
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