Steven
I’ve always been a proponent of “know your steel” before hardening. Now, if I remember correctly, Winchester's Smokeless steel had around .30 % carbon, which puts it into the med carbon zone… but just.
Winchester actually did Case Harden the models 1886, 1892 & 1894 that were made of Smokeless steels. Not many, but it was a factory option.
Minimize time at carburizing temp, blocking on the inside channel to mitigate carbon migration, quench at a temp well below hardening temp and normalize after hardening and I think you would be well in the “safe zone” esp. with a low power cog as a 22 lr.
Your reference to the Ruger #1, yes, 4140 quenched at 1400 deg f…just asking for trouble.
V/R
Mike