Transcript Document

Federal Aviation
Administration
Fuel Tank Safety
Briefing
Developed By:
Mario L. Giordano, Aircraft Maintenance Division
FAA National Headquarters, Washington, DC
Updated: August 25, 2008
Fuel Tank Safety Overview
•
SFAR 88 mandated the manufacturers conduct a safety review of the
applicable airplanes to determine that the design meets requirements
of CFR 25.901 and 25.981(a) and (b).
•
If the current design does not meet those requirements, they must
develop all design changes to the fuel tank system (FTS) that are
necessary to meet those requirements.
•
Additionally, the manufacturers must develop all maintenance and
inspection instructions necessary to maintain the design features
required to preclude the existence, or development of an ignition
source within the fuel tank system of each applicable airplane.
•
The operators of these airplanes are then responsible to address these
potential ignition sources by complying with the manufacturer’s, FAA
Engineering approved design changes and repetitive
maintenance/inspection tasks.
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Fuel Tank Safety Overview
•Some of the manufacturer’s fuel tank system repetitive inspections currently
being accomplished under the zonal concept will become stand alone inspections.
•Additionally, new repetitive fuel tank system inspection tasks have been developed
by the manufacturers.
•Some repetitive inspection tasks will be included in the applicable ALI section
(MPD section 9, or SCI document) .
•ADs will mandate the new ALI’s that must be added to maintenance program.
•Some repetitive inspection tasks may be included in the applicable routine
maintenance program document (MRB or MID).
•FAA concurs with the industry that the repetitive inspection tasks, ALI, or
otherwise, should coincide with the operator’s current Maintenance Program
intervals if the SFAR 88 safety review analysis supports the existing maintenance
intervals. (Intent to minimize tank entries)
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Fuel Tank Safety Overview
• As defined in FAA Engineering Policy Statement ANM 112-05001 dated October 6, 2004, the aviation authorities and airplane
manufacturers agreed to analyze the potential ignition sources
and place them into two specific categories:
“ Unsafe Condition”
“No Unsafe Condition”
• Understanding the operator’s implementation responsibilities
regarding FTS tasks in these categories for TC and “applicable”
STC’s is the main objective of this presentation.
• Refer to AC 120-97 dated 6/18/08 for further details regarding
“Incorporation of Fuel Tank System Instructions for Continued
Airworthiness into Operator Maintenance or Inspection
Programs”
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“Unsafe Condition” Category
Encompasses:
• FTS Design Changes – Service Bulletins/Instructions mandated by
AD to be incorporated by the operator – Various compliance dates.
• FTS Repetitive Maintenance/Inspection Tasks – CFR 25.981 and
H25.4 mandates these FTS tasks be included in the Manufacturer’s
Airworthiness Limitations Section.
– Be incorporated into the operator’s program via AD by December 16, 2008.
• FTS Critical Design Configuration Control Limitations (CDCCL) CFR 25.981 and H25.4 mandates CDCCL items be included in the
Manufacturer’s Airworthiness Limitations Section.
– Be incorporated into the operator’s program via AD by December 16, 2008.
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Examples of FTS Design Changes
• Electric Fuel Boost Pumps – Incorporation or modification of
automatic shut off systems to prevent dry running.
• Electric Fuel Boost Pumps – Incorporation of Ground Fault
Interrupter (GFI) devices or Arc Fault Circuit Breakers.
• Electric Fuel Boost Pumps - Power supply conduit
replacement.
• Physical wire separation in certain airplanes at critical
locations.
• Additional bonding leads inside and outside fuel tanks.
• FQIS - Transient Suppression Devices (TSD)-limited use.
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Critical Design Configuration
Control Limitations (CDCCL’s)
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•
•
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The maintenance and inspection instructions must include
CDCCL’s as well as the routine maintenance and inspection
tasks and frequencies, where applicable.
CDCCL’s will be included in the ALI section and will include any
information necessary to maintain those design features that
have been defined as needed to preclude development of
ignition sources. (CDCCL’s do not have frequencies)
An example of a CDCCL is maintaining wire separation
between FQIS wiring and other high power electrical circuits.
Another example is an external bond attached to a fuel pump.
The manufacturer must design a method to ensure that this
essential information will be evident to those that may perform
and approve repairs and alterations throughout the operational
life of the airplane.
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“No Unsafe Condition” Category
•
The FTS repetitive maintenance/inspection tasks in this category will
be handled by the industry in the traditional manner using MSG
analysis, or an equivalent process.
•
For example, these tasks will be analyzed as Maintenance Significant
Items (MSI’s) by the manufacturer, FAA AEG, and FAA Engineering.
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FAA Engineering will approve each FTS task and interval.
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The manufacturer will then release those FTS Instructions for
Continued Airworthiness ICA in a single document such as a MRBR
or a MID document revision.
•
The operators will then be responsible to incorporate those ICA into
their maintenance program with FAA Flight Standards approval in
accordance with the operational rule requirements by December 16,
2008.
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•
Some manufacturers elected not to analyze their FTS tasks in the manner
that would separate them into the two categories. Consequently, they have
placed all their FTS repetitive tasks into their respective ALI Section.
•
Some manufacturers for consistency elected to place all their FTS repetitive
tasks into one place, their respective ALI section.
•
The majority of manufacturers followed written policy and separated their
FTS tasks into the two categories. Consequently, these manufacturer’s FTS
tasks will be located in their respective ALI sections and their routine
maintenance program documents.
•
This non standardized approach to categorizing FTS tasks will result in
operator and FAA inspector confusion regarding December 16, 2008,
compliance procedures.
•
The FTS handbook guidance scheduled for release in September 2008 will
provide specific information regarding each manufacturers method(s) of
compliance, and describe the use of new Ops Specs for operator
implementation.
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Applicable Fuel Tank Safety STC’s
• The final number of “applicable” STC’s is now limited to five (5).
The list, provided on the following page is also located in AC
120-97, Appendix 2.
• None of the “applicable” STCs are Auxiliary Fuel Tank
Installations – Auxiliary fuel tanks will be addressed via AD.
• The applicable operators must incorporate all the STC ICA
located in the respective amended STC’s into their maintenance
program in accordance with the operational rules by December
16, 2008.
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Page 1 (and 2) Note: page 2 is blank in AC
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STC Auxiliary Fuel Tanks
Rogerson, Southeast Aero-Tek and DTAA Installations:
–
AD’s have been issued to mandate operators to deactivate their tanks with FAA
engineering approved procedures by December 16, 2008, or provide system design
review, design changes, and repetitive inspection tasks for approval.
Boeing Installations:
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Operators can continue using the tanks – AD action may occur in the future.
Pats Installations:
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AD released - 47 public comments received indicating operators require these tanks for
their operations.
AMOC criteria currently being developed to allow tank use beyond December 16, 2008;
however, at a date yet to be determined system design changes and repetitive inspections
will be mandated.
Issuance of the final rule is targeted for August 2008.
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Compliance Timelines
TC Holder Conduct “Safety Review”
Compliance Date - December 6, 2002
Applicable STC holders now 5 (130)
Conduct “Safety Review”
Compliance Date - June 6, 2003
Phase One -SFAR 88 –TC/STC Holder
Responsibility
Phase Two – Operator Responsibility
Unsafe Condition
Operator Implementation: Design Changes
ALI’s (including CDCCL’s)
Comply with Airworthiness Directives Various compliance dates
Comply with Airworthiness Directives – December 16, 2008
91.1507 121.1113 125.507 129.113
CFR Parts 91.410(b), 121.370(b), 125.248(b), 129.32(b)
Operator implementation of maintenance
amended to require instructions for maint and
Program changes via operational rules.
inspection of the fuel tank system be FAA approved
and incorporated into the operators maintenance
program by December 16, 2008 (originally Dec 2004)
No Unsafe Condition.
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EAPAS/FTS Operational Rule
Clarifications
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FAA addressed industry confusion with intent of “actual configuration” in EAPAS NPRMAlso, removed the term in revised ops rules
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–
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only “applicable” STCs and field approved Aux Tanks must be considered.
No need to physically check wire routing etc. unless mandated via AD.
FAA addressed industry confusion regarding when FAA Engineering reviews/approves the
operator’s proposed FTS program-Engineering not involved unless operator requests deviation
from manufacturer’s baseline program.
Operators Must:
–
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Incorporate FAA Engineering approved ICA including those developed for STC aux tanks, if any, for
installed tanks – There Is no STC aux tank ICA- now covered via AD.
Determine if any auxiliary fuel tanks are installed via “Field Approval”
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Conduct safety assessment per SFAR 88 by June 16, 2008
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•
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Identify any design changes needed
Develop maintenance instructions
Gain FAA engineering approval for design changes and maintenance program
Incorporate FAA Engineering’s approved plan for continued revenue service.
Deactivation/Removal of these tanks with FAA engineering approved data is an option.
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121.1113 Fuel tank system maintenance program.
(a) Except as provided in paragraph (g) of this section, this section applies to transport category, turbine-powered
airplanes with a type certificate issued after January 1, 1958, that, as a result of original type certification or later increase
in capacity, have—
(1) A maximum type-certificated passenger capacity of 30 or more, or
(2) A maximum payload capacity of 7500 pounds or more.
(b) For each airplane on which an auxiliary fuel tank is installed under a field approval, before June 16, 2008, the
certificate holder must submit to the FAA Oversight Office proposed maintenance instructions for the tank that meet the
requirements of Special Federal Aviation Regulation No. 88 (SFAR 88) of this chapter.
(c) After December 16, 2008, no certificate holder may operate an airplane identified in paragraph (a) of this section unless
the maintenance program for that airplane has been revised to include applicable inspections, procedures, and limitations
for fuel tanks systems.
(d) The proposed fuel tank system maintenance program revisions must be based on fuel tank system Instructions for
Continued Airworthiness (ICA) that have been developed in accordance with the applicable provisions of SFAR 88 of this
chapter or §25.1529 and part 25, Appendix H, of this chapter, in effect on June 6, 2001 (including those developed for
auxiliary fuel tanks, if any, installed under supplemental type certificates or other design approval) and that have been
approved by the FAA Oversight Office.
(e) After December 16, 2008, before returning an aircraft to service after any alteration for which fuel tank ICA are
developed under SFAR 88 or under §25.1529 in effect on June 6, 2001, the certificate holder must include in the
maintenance program for the airplane inspections and procedures for the fuel tank system based on those ICA.
(f) The fuel tank system maintenance program changes identified in paragraphs (d) and (e) of this section and any later
fuel tank system revisions must be submitted to the Principal Inspector for review and approval.
(g) This section does not apply to the following airplane models:
(1) Bombardier CL–44
(2) Concorde
(3) deHavilland D.H. 106 Comet 4C
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Operational Rule Compliance
Process
“Baseline” Program Implementation:
• TC, STC holders develop and submit all their FTS maintenance and inspection
requirements to FAA Engineering in accordance with SFAR 88
• FAA Engineering with AEG assistance reviews and approves submitted data.
• TC, STC holders incorporate approved data into their respective documents, such
as the MRBR or MID and into their maintenance manuals, and task cards as
applicable.
• Operators incorporate manufacturers “baseline” program into their own specific
maintenance program documents including applicable manuals, and task cards.
• Operators submit their proposed FTS Program to their Principal Airworthiness
Inspector for review and approval.
• The Principal Airworthiness Inspector reviews and approves the operator’s
program implementation via aging airplane D070 operations specifications.
(Available Sept 08)
Note: D070 Table 1 used for TC baseline implementation
Table 3 used for STC baseline implementation
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Operational Rule Compliance
Process
Alternate Program Implementation:
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•
•
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Operators that propose FTS task or frequency deviations for TC or STC’s
submit their request through their Principal Airworthiness Inspector to FAA
Engineering for their review and approval.
Upon FAA Engineering approval, the operators incorporate the alternate
program into their own specific maintenance program documents including
applicable manuals and task cards.
Operators submit their proposed FTS program to their Principal
Airworthiness Inspector for review and approval.
The Principal Airworthiness Inspector reviews and approves the operator’s
program implementation via aging airplane D070 operations specifications
Note: D070 Table 2 used for TC alternate implementation
Table 4 used for STC alternate implementation
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Operational Rule Compliance
Process
Field Approved Auxiliary Fuel Tank Program Implementation:
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Operators must perform a design review and develop ICA in accordance with
SFAR 88 requirements. (Should have been accomplished by June 16, 2008)
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Operators must submit this data through their Principal Airworthiness
Inspector to FAA Engineering for their review and approval.
•
Upon FAA Engineering approval the operators must incorporate the
approved ICA program into their own specific maintenance program
documents including applicable manuals, and task cards.
•
Operators must submit their proposed FTS program to their Principal
Airworthiness Inspector for review and approval.
•
The Principal Airworthiness Inspector reviews and approves the operator’s
program implementation via aging airplane D070 operations specifications.
Note: D070 Table 5 used for field approved aux tank program implementation
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Operator Compliance Plan
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The ultimate goal is for each operator to achieve FTS compliance
prior to December 16, 2008.
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In order to achieve timely compliance the FAA and the operators
should review AC 120-97 and consider using an “Operator
Compliance Plan” as described in paragraph 207.
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Each operator and cognizant FAA Flight Standards Certificate
holding office must work together to facilitate incorporation of these
new vitally important fuel tank safety objectives.
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