Fuel Tank Safety Briefing 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.

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)

Fuel Tank Safety Overview “ Unsafe Condition” “No Unsafe Condition” As defined in FAA Engineering Policy Statement ANM 112-05-001 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”

“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.

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.

Critical Design Configuration Control Limitations (CDCCL’s) 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.

“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. FAA Engineering will approve each FTS task and interval. 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.

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.

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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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: Operators can continue using the tanks – AD action may occur in the future. Pats Installations: 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.

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 Operator Implementation: Design Changes ALI’s (including CDCCL’s) No Unsafe Condition. Operator implementation of maintenance Program changes via operational rules. Unsafe Condition 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) amended to require instructions for maint and inspection of the fuel tank system be FAA approved and incorporated into the operators maintenance program by December 16, 2008 (originally Dec 2004)

EAPAS/FTS Operational Rule Clarifications FAA addressed industry confusion with intent of “actual configuration” in EAPAS NPRM- Also, removed the term in revised ops rules 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: 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” Conduct safety assessment per SFAR 88 by June 16, 2008 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.

 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

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

Operational Rule Compliance Process Alternate Program Implementation: 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

Operational Rule Compliance Process Field Approved Auxiliary Fuel Tank Program Implementation: Operators must perform a design review and develop ICA in accordance with SFAR 88 requirements. (Should have been accomplished by June 16, 2008) 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

Operator Compliance Plan The ultimate goal is for each operator to achieve FTS compliance prior to December 16, 2008. 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. 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.