ML20149H977

Informs That Gunsights Acceptable for Licensing Purposes, Per Addl Info Received on 831103

ML20149H977
Person / Time
Issue date:	01/06/1984
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: ML20149H587 ML20149H977 ML20149H994
References
FOIA-87-790 16232, NUDOCS 8802220225
Download: ML20149H977 (3)

Text

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UNITED STATES l-  %,F',

NUCLEAR REGULATORY COMMISSION WASHINGTON. O. C. 20555

, January 6,1984 v

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. (CONTROL NO. 16232) REQUEST FOR EXEMPT DISTRIBUTION OF LUMIN0US GUNSIGHTS Per the additional information we received on November 3,1983, we have determined that the gunsightsare acceptable for licensing purposes in accordance with the enclosed registration sheet.

If you have any questions, please call me. My extension is 74240.

9 i g 45 -

teven L. Baggett Material Certification and Procedures Branch Division of Fuel Cycle and Material Safety, NMSS

Enclosure:

Certificate No. NR-418-D-101-E 8802220225 880217 PDR FDIA REIDYB7-790 PDR

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/ 6 Lb I3 S sc rion A-A 3 1 2 4 Item Part Material Finish Item Part Material Finish Number . Number 1 Body Aluminum Anodise' 15 Light Source Retainer Steel Black Oxide 2 Lens Circlip Steel 16 Dome Seal Synthetic Rubber Molded 3 lens Seal Retainer Steel Black Oxide 17 Dome Polycarbonate Molded 4 Lens Seal Synthetic Rubber Molded 18 Dome Circlip Steel Black Oxide 5 Lens Glass Coated 19 Adhesive Loctite 271 6 Lens Seat Synthetic Rubber Molded 20 Spring Circlip Steel Black Oxide 7 Mount Aluminum Anodise 21 Spring Retainer Steel Black Oxide 8 Mount Screw Steel Black Oxide 22 Spring Seal Synthetic Rubber Molded 9 Plunger Brass 23 Spring Stainless Steel .

10 Adjuster Seal Syntheitic Rubber Molded 24 Reticle Housing Aluminura Anodise 11 Adjuster Circlip Steel Black Oxide 25 Reticule Copper Black Oxide 12 Adjuster Brass 26 Light Source Acrylic Molded 13 Knob ScreM Steel Black Oxide 27 Tritium Lamp See speification Pa in* ed u 1

14 Knob Class Filled Nylon Molded 28 Adhesive Silicone Rubber RTV 102 ARMSON SALES = ="*"'"=== m ,aMn October 19, 1983 TELEPHONE: 713512 TELEX: 625235 DESIGNERS & MANUF ACTURERS UNIT 3 - 49 HENWOOD ROAD OF AIMING OFVICES & MOUNTING SYSTEMS NFW GERM ANY

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Item Pa rt Material Finish Body Aluminum Anodise 2 1 Lens Glass Coated 'Y t

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4 1 Lens Ring Glass Filled Nylon Molded 5 2 Cirelip Steel Black Oxide E 6 1 Light Source g, ,,,,N DEV CES & M UNT NG SYSTEMS Ac rylic , flourescent Molded 7 - Adhesive Silicone Rubber RTV 108 8 2 Tritium Lamp See Specification Painted l 9 1 Adjuster Spring Stainless Steel  !

10 1 Light Source Cap Glass filled Nylon Molded 11 1 Housing Class filled Nylon Molded g 12 1 Dome Polyca rbona te Molded - P.O. 80X 426 NEW GERMANY 3620

-j) 13 1 Housing Cover Glass filled Nylon Molded

• NATat south AFRICA y 14 2 0-Ring Neoprene Molded Red rawn TELEPHONE: 713512 Q 15 2 Adjuster Knob Glass filled Nylon Molded October 19, 1983 TELEX: 625235 i'O 16 2 Lock Screw Steel Black Oxide UNIT 3 - 49 HENWOOO ROAD 17 2 Adjuster Brass ""U "*"

18 2 Push Rod Brass 19 1 Reticule Copper Black Oxide

ARMSON, INC.

ARMS N O.E.G. P. o. Box 2130 OAY/ NIGHT / LOW LIGHT INCREDIBLY FAST GUNSIGHT Farmington Hills, Michigan 48018 7

January 3, 1984 ..

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, jf Initk'5&ak"l88NiearRegulatoryCommiseion 7915 Eastern Avenue Vilste Building Silver Springs

'. MD 20901 Rapifax 301 + 427 4298 (verification 301+427-4287)

Re: 15437

Dear Mr. Baggett:

Thank you for your telephone call today regarding your need for more detailed quality control information on the Armson 0.E.G. gunsight license application.

In a December 9,1983 telephone call, your Mr. John Hickey had mentioned this item as a possible deficiency. The enclosed report was obtained from Armson Sales (pty) Ltd in order to prepare for the possible deficiency.

In addition to their stated procedure which we hereby make part of our license application, we can also provide the following information. All the critical dimentions relating to the fit of parts together in the reticle assembly and mounting are 100% inspected. The function of the adjusting mechanism vill be impaired if parts are out of tolerance. The final assembly of the reticle assembly in.to the gunsight provides a check of the parts. Undersize parts vould allow outside light to leak into the gunsight and would impair operation.

Oversize parts vould either not fit into the assembly, or would fit poorly so that the adjustmant mechanism would not work properly. Final inspection includes tha functional check of the adjustment mechanism.

Vith respect to the licensing of the alternate construction referred to in my November 9,1983 letter to your Mr. John Hickey, we can supply the iollowing additional information.

Page 7 shows the current design (now generally licensed) upon which all the prototype tests were conducted. The proposed alternate construction is shown on page 8. Additional copies of these two pages are attached for convenience.

. Both designs use the same size and shape of gaseous tritium light source (GTLS)

. Both designs have the same size, shape and orientation of the cavity into which the GTLS is mounted.

. Both designs use molded acrylic plastic as the lamp holder.

. Both designs use RTV 102 silicone rubber for adhesive and light couplirg of the GTLS.

. Both designs use a thin copper reticule.

. Both designs restrain the lamp holder axially by means of flat surfaces anchored firmly to the main housing (body). o

. Both designs have a pair of adjustment screws at 90 apart which are opposed by a spring which bisects the angle between the two screvs.

. Both lamp holders have a daylight acrylic needle portion which is protected by a polycarbonate dome held in place by a steel snap ring, j/ . ~

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. All of the engineering matwrials, surfaces in stress or bending are judged to be equal or better with respect to the ability of the housings to contain the GTIS safely.

. Both designs use an extruded aluminum alloy main housing (body).

.The alternate design is slightly smaller than the original design and should

• fare better in some of the more severe tests like the ANSI N540 level 4 drop tests.

On the basis of these engineering aspects of the two designs, we believe that we have demonstrated equivalency between the two designs obviating the need for extensive prototype testing.

i This letter with 7 pages of attachments (9 pages total) are being sent to you electronically by Rapifax with a confirming copy by regular mail. We would sincerely appreciate every effort to expedite the final action on this exempt license application.

Yours sincerely,

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$-Q 7Q Glyn A.J. Bindon President

M EC5W5@ %#54  % 2 M L . E Q 'LTo' NATAL SOUTH AFRICA TELETHONE: 713512 TELEX: 625235 DESIGNERS & MANUF ACTURERS UNIT 3 49 HENWOOD ROAD OF AIMING DEVICES & MOUNTING SYSTEMS NEW GERM ANY H5NILING PIO3DUIE MD QtEITl CINTRE 'OF TRETHE IRPS

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1. APRIVAL 5 'Ibe lanps are air freighted frce Switzerland and i

chlivered by our clearing agents. ,

2. PACKING

'Ibe lanps corre packed in accordance with intematicnal rules for the transportaticn of radioactive nuclides i.e.

in sealed netal cans, in a cartboard carten, with relevant markings.

3. LNPACKING Y The cartcn is unpacked by the assembly worker who is the cnly perscn who handles the tritiun lanps intil after they are encapsulated in the light sources. He renoves the sealed cans from the cartcn and takes them to the assenbly rocm which is closed off frce the rest of the factory and equipped with a fu:n cabinet and extractors vented through the roof, to specificaticns laid cbwn by the A.E.C. A ccnsignnent is usually 2000 lanps in two cans 1000 per can. Cne can is placed in a safe which is in the assembly rocm. 'Ihere are two keys; cne held by V.F. Milligan, the other by J.P. Benniscn, who are the two perscns ncminated by the A.E.C. as respcnsible for the lanps.

4. Quantity Check 'and First Inspecticn the em is cpened in the fure cabinet and the lartps crntained in 4 packets, 250 per packet, are renoved. 'Ihe lanps are then placed cn 4 special boards covered with cling film (to prevent the lanps sliding about) in 5 rcws of 50 Imps.

'Ihis gives a pcsitiw quantity hc eck.

'Ibe lights in the assenbly rocm are then extinguished and t% lanps can be seen gicwing. As the lange are pressurised a fractured laap would be significant*y dimrer than a good lanp or would not gicw at all. 'Ihis visual check is omrseen by either V.F. Milligan or J.P. Ibnniscn. No lanps ham failed this inspecticn in the last 3 years.

5. Painting 'and Insertion 'into ~ Light Source bbulding

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hhilst the lanps are still cn the boards the tpper face is painted with white plastic enanel and are left for cre hour to dry.

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Five special boards :ich containing 100 li@t source ar=MMngs 4

4:: which have been cheded md clemed of dust are placed in the

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fute cabinet. 'Ihe 11@t source has two oevities to accept two v., lanps. 'these cavities are 0,5am bigger than the laps to ensure adequate space for the shod absorbing siliocne r&ber shesive T-and so that the lanps win fit without exerting pressure cm them.

& To ==aarrMa the 11$t source a qumtity of siliocne rdber a&esive

%: is asplied to the omvaties and the two Imps inserted.After

% ensuring that the lamps are well below the face of the li$t

] source, 'Ihe stb-assenbly is placed bad cm the board. Periodio inspecticns by V.F. ML111gan takes place during this and an subsequmt stages of assenbly. When the last' board is ocmpleted the lights are again tumed off md the lamps which cm be clearly seen are checked for briiuLi mss. 'Ihis ched is always overseen by V.F. ML111 gen or J.P. Ruiniscn. 'Ihere have been no rejects in 3% years. By the time the last board is, ocupleted the first board is rea% for the next stage.

6. ASSDBLY CF LIGfr SX13G ED IETIC11E IKLIER sy< 500 Anodised aluntniun reticule h)1ders and 500 ccpper reticules

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which have been cheded md clemed are brought to the fute cabinet. 'Ibe reticule fonowed by the li@t source are inserted

.' into the holder and this assenbly held in a specially desicped clanp. Cyanoacrylate a&esive is applied arotnd the edge of the holder which, due to capillary acticn, penetrates between the light source and holder to form a pemenent bcmd. 'Ihis assenbly

' s. is passed through gauges to ched the overall length 5.hich has

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• a tolerance of +0.0 -0,1 nm. 'Ihe units are placed in trays of 100 with the plastic face typenrest and the lights turned off.

'Ibe lamps can be seen glowing through the plastic and faulty 1

Imps would be detected. 'Ihis ched is again stpervised as  ;

previously. 'Ihere has not been a reject in Sh years. Since no  ;

' dmage can be cine to the lanps after this stage short of cushing ,

the entire u11t (which would render it trmsable for installaticn in the sight) no further che&s cm the lanps are carried out. Encep-

, sulaticn of the trititrn lanps is new ocmplete.

At the end of each wotLng day all langs or sub-assenblies not installed

.in finished sights are placed in the safe.

As can be seen fran the abcme the tritium latps indergo a stpervised 1004 inspectico three tires during assenbly.

4 Although no failures have occured in recent years this procedure is not reland aid should a fracture of lange occur a wash cbwn procedure j would he put into effect.

g We take great pride in our record for the use of trititan lanps without breakages and win always strive to maintain it.

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ATOOMENERGIEKORPORASIE

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OF SOUTH AFRICA LIMITED

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AUTHORITY 549/1983

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In terms of sec.tlon 50 of the Nuclear Energy Act,19s2 RNo. 92 of 1982), -

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. Armson Sales (Pty) Ltd

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is hereby authorised to POSSESS. and USE at any given time .not'more than the quantitles set out in the attached annexure, and DISPOSE of.

CONVEY and CAUSE TO CONVEY, subject to the Conditions for the Acquisition, Possession, Disposal, importation, Export, Use and Con-veyance of Radioactive Nuclides, promulgated by Government Notice No. R2410 of 28 November 1900 such radioactive nuclides.

The possession, use and disposal of the ' Gaseous Lt.ght Sottrees are

'. subject to the following additional conditions: ,

1. The light sources shall only be used forf the.' manuladture of Armson occluded eye gunsights.

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2. The maximum activity ' df FI per gunsight shall '.not. ; exceed 160 millicurles. , . 4.K ,. ,

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3. A record shall be kept of the quantity of light sourcec: . "

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(11) is being kept in stock; and N 1

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(iii) has been mounted in gunsights. ,t 9 .

4. A record must be kept of: .' ,/?

.: t' ., c (a) the quantity of gunsights fitted with radioactivi ~ sources

, (, indicating serial numbers of gunsights; andn T* -

(b) the names and addresses of customers. *

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5. Copies of t'.e record called for under conditions 3 and 4 must be

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'E Responsible Person: Mr V F Milligan .

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, Alternate to the responsible person: Mr J P Rennison O .

ISSUED at PELINDABA on this tt.e 22nd day of September 1983 f

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for CROUP GENERAL MANAGER: LICENSING s; .

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. .*NNEX1mE TO Alml0RITY 549/1933 4000 x 80 mci H - . . Gaseous Light Sources

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, ,Q Item Part Material Finish  ! Iten Part Naterial Ntsnber Finish 1 Body Altaninum f Niaber Anodise' 15 Ligi.t Source Retainer Steel Black Oxide 2 Lens Circlip Steel 16 Dome Seal hyathetic P.ubber Molded 3 lene Seal Retainer Steel Black Oxide 17 Dome Polyc.a rbonate Molded 4 Les:s Seal Synthetic Rubber Molded 18 Dome Circlip Steel Black Oxide 5 Iens Glass Cceted 19 Adhesive Ioctice 271 6 Lene Seat Synthetic Rubber Molded 20 Spring Circlip 7

Steel Black Oxide .

liount Altninum f.r.odis e 21 Spring Retainer Steel Elack Oxide 8 Mount Screw Steel Black Oxide 22 Spring Seal Synthetic Rubber Molded 9 Plunger. Bra s s 23 Spring Stainless Steel 10 Adjuster Seal Syntheitic Rubber Molded 24 Reticle Housing , Altaminum Anodise 11 Adjuster Circlip Steel Black Oxide 75 Reticule Copper Black Oxide 12 Adjuster Brass -

26 Light Source Acrylic Molded I '* Knob Screw Steel Black Oxide 27 Tritium Lamp See spelfication Painted w 14 Knob Glass Fille'd 1Y1ovi Molded 28 Adhesive Silicone Rubber RTV 102 ARMSON SALESi= = "'"~ = "2 a TELEPHONE: 713512 Redra n EO *# *I TELEX: 625235 DESIGNtRS & '.8ANUFACMfRS UNIT 3 - 49 HENVtO30 ROAO i

OF AIMING CEvlCES % MOUNT NG *:YSTFMS NFW CFRM A'dY '

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Item Part Material Finish Body Aluminum 2 1 Anodise Lens Class coated (TT 3 3 0-Ring Neoprene Molded 4 1 Lens Ring Class Filled Nylon Molded 5 2 Circlip Steel 6 1 Light Source Black Oxide ,

DESIGNERS "

Acrylic, flourescent g, ,,,,, gg CE & $Y TE M 7 - Molded Adhesive Silicone Rubber RTV 108 8 2 Tritium Lamp See Specification 9 1 Painted Adjuster Spring Stainless Steel 10 1 Light Source Cap Glass filled Nylon 11 1 Molded .

Housing Glass filled Nylon Molded 12 1 Dome Polycarbonate P.O. sox 426 NEW GERMANY 3620 Molded 13 1 Housing Cover Glass filled Nylon NATAL south AFRICA 14 2 Molded 0-Ring Neoprene Molded Red rawn TELEPHONE: 713512 15 2 Adjuster Knob Glass filled Nylon October 19, 1983 TELEX: 625235 16 2 Molded Lock Screv Steel Black Oxide 17 2 Adjuster UmT 3 - 49 HENWOOO ROAD Brass " 6" 18 2 Push Rod Brass 19 1 Reticule Copper Black Oxide

m n _. 5, AR M SON, INC.s- 150u

' ARMSS N, O.E.G.*

P. O. Box 2L30 DAY. YN T/ LOW UGHT INCREDtBLY FAST.GUNSIGHT Farmington Hills, Michigan 48018 g,gg November 18, 1983 Mr. John W. N. Hickey, Section Leader Industrial Section Material Licensing Section D NOV 23 M :05 Division of Fuel Cycle and Material Safety United States Nuclear Regulatory Co:::aission i Washington

DC 20555

Dear Mr. Hickey:

Re: 15437 This refers to our telephone conversation of today in which we discussed the earnpling wipo and scintillation counting that we conduct on all gunsights under our present general license. We understand that it is possible that this requirement can be deleted.

We request that in our July 27, 1983 application for exec 2ption, section 6 page 2 paragraph 2.7 be deleted as a requirement for an.captance tests on production lots and only be used for prototype tests. -

This request is based also on many hundreds of wipe tests conducted on production lote, always reporting no contamination problems.

Yours sincerely,

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Glyn A. . Bindon President O

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Date Cn u .. R P. O. Box 2130 neceived 6 /

DAY / NIGHT / LOW LIGHT INCREDIBLY FAST GUNS GHT '

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armi lgton Hills. Michigan 48018 November 9,1983 @ 15 P3 @5 ieIephone.(3.13) A73 2 4 Mr. John W. N. Hickey, Section Leader < Date. , , l ! .h,I. ..

Industrial Section 5 1.cg.. . W/

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Material Licensing Section . ..

Division of Fuel Cycle and Material Safety '

By.......

United States Nuclear Regulatory Commission Washington O n, g . T o . . . . . . . . . . . . , , ,

DC 20555 Action Compl. g . . . , , .

Dear Mr. Hickey:

Re: 15437 .

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This refers to your letter of October 11, 1983 and our pending application for distribution licensing of tritium gunsights to exempt persons. Please complete action on our application using the information supplied below and in the attachments. The items below refer to the 8 items in your letter.

1. We have reviewed our current license no. 21-19874-01 and we attach executed copies of NRC-313 as an a=endment to this license. This amendment changes the company name to Armson, Inc. with the P.O. Box 2130 mailing address. It also adds the alternate of M.B. Microtec for the tritium lamps, and increases the possession quantity to 5,000 gunsights (800 curies) maximum. Please include all other pertinent portions of the pending application so that the possession license, which we will maintain, will cover use for distribution under either license. We enclose the appropriate atendment fee of $40.00 herewith.

2. The expected useful lif e of the gunsight is 10 years at which tice the user may return it to us to install a new reticle assembly with new lamps. At that same time we would also install a new label. We currently use a vinyl self-t dhesive label, samplefof which are in your possession. The new label will be

.af the same material which would have a lif e approaching 10 years under optical storage conditions. However, the label manuf acturer cannot guaruntee the label f or 10 years dufto the unknowns of customer useage. Most gunsights would be stored indoors under optimum conditions most of the time. They would also be exposed to gun oils and propellant solvents f rom time to time.

Upon discussion of these facts with your Mr. Steve Baggett, we understand that it is preferred to keep the full wording of the labeling, and that vinyl can be approved since it is also in use on other exempt tritium devices. We also understand that if we are able to metal impression stamp the same wording onto the guasight at a later date, this upgrade of labeling would be permitted.

3. Our application refers to one type of gunsight with 13 dif ferent mountings of the same gunsight. This gunsight has been subjected to all the required prototype testing and found to properly contain radioactive caterial. The standard model is mounted on sporting rifles using rings of many dif ferent designs which clamp onto the one-inch diameter of the gunsight and attach it to many different rifles. The other 12 types listed, ( and others may be added in the future ) are special clamps for certain rifles. These special mounts are attached to the same standard model gunsight using screws. The presence of dif f erent montings does not alte'r the ability of the gunsight to contain.

radioaetive materia 1.

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4. Enclosed are two copies of the user instruction manual shipped with each gunsight. On page 9 the following statement is found:

Warning: No attempt must be made to dismantle the sight. If the sight develops a f ault you must return in to the f actory.

5. The manufacturer's Quality Control procedures are described in the attached copy of their October 24, 1983 letter. .

6. We enclose a detail copy of M B Microtec drawing for their part number T 4304-1 tritium lamps which we would like to be approved as an alternate source.

7. We currently expect to distribute 1,200 gunsights or 192 curies of tritium a nnually . During the license period this quantity could increase to 800 curies of tritium annually.

8. A clear reproducible copy of the gunsight diagram on 8 1/2 x 11 inch paper is attached.

We note the reducelreporting requirements shown in the revised copy of 10 CFR 32.25 that you sent us. We will comply with this reporting schedule.

We also attach on page 8 an alternate construction of the gunsight which is proposed to be adopted in the future. This construction is very similar to the existing gunsight as can be seen from comparing the two diagrams. The lamps are the same and are contained and mounted in the same way. The entire gunsight is a sealed chamber and would also use alternate mounting methods. Please approve this alternate construction as part of this application. If you cannot approve the alternate construction, please specify if it could be treated subsequently as an amendment to the pending application.

Yours sincerely, L

Glyn A.J. Bindon President be 9

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Femu NRC 313 l U.S. NUCLE AR REGUL ATORY COMMLSSION (1 79) 1. APPLICATION FOR:

to CP R 30 (Check end/or compatte at approprioted APPLICATION FOR BYPRODUCT MATERIA 1.1.lCENSE INDUSTRIAL e. NEW LICENSE

& See atteched instrueriens ter detsit

6. AMENDMENT TO:

LIC E Ns NVMBER Centered oopticotions are filed in ducheste with the Division of furt CycIt and Materio! Safety, X 21~198I ~0E Of!*cr of NucItsr Motorial $sfety, and Sofeguerds, U.S. Nveleer Reguistory Convnission, -

>%hington, DC 20$$$ or applications may be filed in person at @r Convnission's office et

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!?t? H Street, NW, Washington, D. C. or 1915 Eastern Avenue, Sitre Spring, Marytend.

2. APPLIC ANT'S N AME I/nstitution, I,rm, person, etc.)

3. NAME OF PERSON TO BE CONTACTED RECARDING THis APPLICATION Artnson' Inc.

Glyn A.J. Bindon, President TELEPMoNE NVMSE R: ARE A Coot - NUMBE M E XTENslON TELEPMoNE NUMSER: ARE A COct - NUMBER EXTENEION (313) 478-2577 (313) 478-2577

4. APPLIC ANT'S MAILING ADDRESS (Inewe lip Cooe)

5. STREET ADDRESS WHERE LICENSED MATERIAL WILL SE USED P.O. Box 3120 I'ne w ' Zia C'd'l Fartnington Hills, 25304 Farmington Road Michigan 48018 Farmington Hills Michigan 48018 (IF MORE SPACE IS NEEDED FOR ANY ITEM. USE ADDITIONAL PROPERLY KEYED PAGES.)

6. INDIVIDUAL (S) WHO WILL USE OR DIRECTLY SUPERVISE THE USE OF LICENSED MATERIAL tsee troms 16 ed 17 ror reevard ten nino ed esperoence or rech indivaruernamed senoe) o FULL NAME TITLE

.. Glyn A.J. Bindon President

n. Carolyn R. Bindon Vice-President t

7. RADI ATION PROTECTION OF FICER I A ttach e ressme o f person's treen.np ead esperience es esthned an items G1yn A.J. Bindon I ct and tr end descr.se has responseiht.on under trem 15.

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8. LICENSED MATERIAL L ELEMENT CH EMIC AL NAME OF MANUF ACTURER MAXIMUM NUMBER OF 1 AND A N DIOR AND MILLICURIES AND/OR SEALED N M ASS NUMBE R PHYSICAL FORM MODEL NUMsER SOURCES AND MAXIMUM ACTI-E (If Seaw Source) VITY PER SOURCE WHICH WILL BE POSSESSED AT ANY ONE TV. ale N O. A 3 C l D l g, Hydrogen (1) Gas 1. Saunders-Roe 60 milli-curies per

! Tritium Tsetere H3 ,_ Developments Ltd ~ amp, two lamps per l

tiodel PRH 880/G/200'gunsight, 5,UUU (2) or maximum number

2. M.B. Microtec A.G, possessed at any one (31 Model No. T4303-1 time. (800 curies)

The two tritium lamps shown are alternate sources of supply, both meeting

I the same dimensional and ANS N540 requi rements.

DESCRIBE USE OF LICENSED MATERIAL E

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, TELEPHONE: 713512 TELEX: 625235 DE51GNER$ & M ANUF ACTURERS UNIT 3 49 HENWOOD ROAD OF AIMING DEVICES & MOUNTING SYSTEMS NEW GERM ANY 24 Octcher 1983

• Annscn Inc.

P.O. Box 2130 Fanningtcn Hills Michigan 48018

. USA .

Dear Sirs In respcnse to ycur questicns regarding quality ecntrol, all Aunscn sights are rnanufactured to SA IEF STD 05/21 which w believe is equivalent to ce better than your FED Std 368.

All materials, ccnpcnent parts and assably procedures are the sane for both military and ccrmercial custcrers. We 63 not

, hcwever issue quality assurance certificates to camercial custcrers.

'Ihe tritiun imps we use (drawing and specificaticn is being sent) are ccnmen to all cur prcducts and are the cnly devices we use er pcssess.

Our use of tritiun lags is ccntrolled by the Atanic Energy Ccrporaticn of South Africa - cur authority no 549/1983. Our prerises are inspected annually by the corporaticn's inspectors, all perscnnel involved in assmbly must submit to annual medicals, we rust prcvide a bi-annual return of all mits manufactured and their distributicn.

During this tire there has been no ccntzrninaticn of cur premises, equipnent or perscmel. We balieve you have had sirilar results with your wipe test in the USA. We wculd like to add that no wipe

- tests or labeling are required in SA, the thited Kingdczn, Australia or any other country to which we enort and in view of the 100%

negative results cbtained so far in the LSA v3 hcpe that ycur NBC may ncw ocnsider relaxing these centrols.

We should like to point out that the mique chsign of cur light source allcws us the traximtra benefit fran the nininun ancmt of tritiun used in the safest way and as we handle these chvices in

, large quantities no cne is more ocnscious of the care required than we are.

We hcpe the abcree inforraticn will prcne useful to support your latest license appl.icaticn.

Ycurs faithfully for and cn behalf of f

Arnscn Sales:

V.F. MILLICM

-,_ _ _ _ ( . . . _ .

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- 1 GLASS : Boros///cate 2 COLOUR : green -

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3 I I l 1 3 TRITIUM CONTENT : 80 md rrulx  !

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i 4 BRIGHTNESS : min. 100jel  ;

i 5 CLOSURE BY : laser seal i

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TEST REQUIREMENTS: AMS l N F4 o, 8 2,,y I l  ;- i

' 7. r>e t g cct s : Isoo M r- l 1 l ,' i 2 AN51N64o CLASSlFi M h

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TRASER GASEOUS TRITlUM """-

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LIGHT SOURCE (GTLS? _

mo-microtec og T 4303 -1

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J FCHL:JH 00 t y 1983 (15437) 030-20771 Armson, Inc.

also dba Leadership Keys, Inc.

P.O. Box 2130 Farmington Hills, MI 48018 Gentlemen:

This refers to your application dated July 22, 1983, requesting a license for distribution of tritium gunsights to exempt persons. As we have discussed with you and your attorney several times on the telephone, your application is being reviewed against 10 CFR Section 32.22-25, a completely separate regulation from 10 CFR 32.51 which -

covers distribution to general licensees. The following additional infomation is needed to support your application:

1. Please review your current license no. 21-19874-01 for correct  ;

name and mailing address. You should plan to submit any corrections or amendments to that license when we take final action on your pending application. Please note that your pending application covers distribution only. Your current license will have to be mainta< ned to cover possession of tritt a devices.

! 2. Please state the expected useful life of the gunsight. Please describe the material of which the label will be made, and confine that its expected useful Mfe-is at least equal to that of the gunsight.

3. Your application refers to 13 different gunsights. Please clarify whether the basic designs of these models differ,

particulary with respect to their ability to withstand proto-type tests and contain radioactive material. If so, please 4

provide design infomation and prototype test data for each model.

! 4. Please provide a copy of revised user instructions. In i

particular, the instructions (or label) should advise users not l to disassenble the device.

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Annson, Inc.

dba Leadership Keys. Inc.  ; 5. Please provide a copy of the manufecturer's quality control procedures to be followed in the fabrication of production lots and the quality control standards the product will be required to meet.

6. We have no information in our files about the MB Microtec A.G.

T43031 source. Please provide a legible, reproducible drawing of the source, showing the materials of construction. Alternatively, you may delete this source from your application.

7. Please state the total quantity of tritium expected to be distributed annually.

8. Please provide a legible, reproducible diagram of the gunsight on 81/2" x 11" paper.

Please note that reporting requirements for distribution of exem t products have been reduced. (See enclosed 10 CFR Section 32.25.

i f We will complete action in your application upon receipt of the

! requested information. Please reply in duplicate within 30 days and I

reference control no. 15437. You should allow at least 30 days

! after you submit your reponse for us to complete action.

Sincerly, John W. N. Hickey Section Leader Industrial Section Material Licensing Branch i Division of Fuel Cycle and l Material Safety

Enclosure:

10 CFR Part 32 lf I' DISTRIBUTION i JHickey FCML r/f FC Central File NMSS r/f j

t i i !L I' _

g OF FICE ) FCit!

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