Bermuda Fts

Government of Bermuda DCA Fuel Tank System Safety
Module 6 Len Arnot-Perrett AVISA
fuel tank system safety
Overview for managers of airworthiness & maintenance
Welcome to the course

Course objectives
Familiarise candidates with the elements of Fuel Tank System Safety Issues Enable candidates to understand the historical background and elements requiring consideration in relation to fuel system safety Equip candidates to understand and use the language of fuel system safety issues Allow candidates to understand and interpret fuel system safety issues from regulatory and manufacturers maintenance publications Satisfy Parts M & 145 Amendments on fuel system safety Note: this course covers level 1 requirements
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Fuel tank system safety the beginning?
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Fuel tank system safety the beginning?
TWA Flight 800 crashed at 20.30 on July 17 1996
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Fuel tanks system safety the end?
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Fuel tank system safety introduction for managers of airworthiness & maintenance
Neither the beginning nor the end!
The investigations surrounding the accident led to many basic design and certification assumptions about installed fuel tank system safety to be substantially revised. What have design and certification assumptions got to do with in-service continuing airworthiness management and maintenance of aircraft?
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All of the continuing airworthiness processes could be affected! covers all of the processes ensuring that at any time in their operating life, all aircraft comply with the airworthiness requirements in force and are in a condition fit for safe operation.
Regulation 2042/2003 Article 2 - Definitions
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AD Flight Manual Modifications Repairs MMEL Life Limits Airworthiness Limitations C of A
Records Maintenance Programme Maintenance Standards Reliability Programme Certification Maintenance Requirements Weight & Balance 10 10 Occurrence Reporting
As you can see, these processes are those associated with the operation, continuing airworthiness and maintenance of aircraft. In the global fleet of aircraft all of the processes have been affected
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We all accept that aviation fuel is dangerous when handling the fuel: but it has mostly been safe inside aircraft installations.
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Or has it been safe?
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Or has it been safe? A global review of in-service fuel tank safety data demonstrated that fuel tank safety does not meet contemporary standards for system safety targets
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In the period 1960 1996 17 fatality events due to fuel tank system events! Let us consider a sample relevant to today.....
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8 December 1963 Pan Am B707 9 May 1976 Iranian Air Force B747 22 August 1985 BA Air Tours B737 11 May 1990 Philippine Air Lines B737 17 July 1996 TWA 800 B747 3 March 2001 Thai Airways B737 5 September 2001 BA B777 20 August 2007 China Air B737
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Is this a Boeing problem? Not exclusively! Boeing had flown approximately 70% of large commercial airplane flights in 2000 It is a matter of exposure then.
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1990 - B-737-300 Manila, Philippines Almost new airplane Air Conditioning Packs running during Ground Operations Empty CWT explosion during pushback from gate CWT pumps operating at time of explosion 8 fatalities Jet-A fuel, approx. 95 degree F ambient temp.(35C) NO IGNITION SOURCE IDENTIFIED 1996 - B-747, TWA 800, JFK 25 year old airplane Air Conditioning Packs running during Ground Operations Empty CWT explosion during climb 2001 - B-737-400 Bangkok Thailand 10 year old airplane Air Conditioning Packs running during Ground Operations Empty CWT explosion minutes after refueling CWT pumps operating at time of explosion 1 fatality Jet-A1 fuel, approx. 97 degree F ambient temp.(36C) NO IGNITION SOURCE IDENTIFIED
230 fatalities Jet-A fuel, approx. 120 degree F tank temp.(49C) NO IGNITION SOURCE IDENTIFIED
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10 9 8
-8
ARAC ~10E
Cumulative Accidents
7 6 5
Bangkok
4 3
Manila
New York
2 1 0
10E Extremely improbable not anticipated to occur in the life of the fleet
-9
1990
1995
2000
2005
Year
2010
2015
2020
Systemic Change Needed
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CS25.1309 AMC 1309

Figure 1 - Relationship between Probability and Severity of failure Condition
JAR 25 PROBABILITY
PROBABLE
IMPROBABLE
EXTREMELY IMPROBABLE
CLASSIFICATION OF FAILURE CONDITIONS
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10-3 MINOR
10-5 MAJOR
10-7
10-9 CATASTROPHIC
HAZARDOUS
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Investigations revealed that the CWT were heated to a greater extent than previously believed - 140f peak recorded on one aircraft type High temperature leads to high flammability High flammability means that ignition source energy required to initiate event is much 24 lower than previously calculated
Prevent fuel system accidents through ignition source elimination and flammability reduction
Ignition
Oxygen
Flammability Reduction
Fuel Vapor
Heated tanks
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Fuel tank system safety introduction for managers of airworthiness & maintenance Fuel Tank Flammability Exposure Worldwide Fleet Average
Main Tanks 2-4% Tail Tanks 2-5%
Body Tanks
Pressurized <5% Un-pressurized >20%
Heated Center Wing Tank 15-30%

Un-heated Center Wing Tanks 2-6%
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Fuel Tank Safety Module 2

Flammability Envelope vs. Ignition Energy, Flash Point and O2 Level
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Altitude 1000's ft.
Flammable Zone
LFL
UFL
30 20 10 0 -50 0 50 100 150 200

Temperature Deg F
Heated CWT Profile Unheated Wing Tank Profile Pointer
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Reinvestigation of design certification standards also led to need to review all tank installations including un-heated tanks Special Federal Aviation Rulemaking SFAR 88
FAA AC 25.981.1(b) FAA AC 25.981.2
JAA INT/POL/25/12
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SFAR 88 Initiated in 2001 assessment stage Existing fleet in Europe and North America All basic airplane design configurations and supplemental Designs affecting the fuel system
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CDCCL and Fuel System Airworthiness Limitation Items to be identified to comply with SFAR 88 Implementation aimed for 2004 Differences between EASA & FAA on Flammability Reduction Systems delay implementation
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Full reinvestigation of design fuel tank systems require DAH to identify Fuel Tank Airworthiness Limitation Items including Critical Design Configuration Control Limitations Airworthiness Limitation inspections Airworthiness Limitation modifications
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SFAR 88 (AC 25.981.1c) & JAA TGL 47 and INT/POL/25/12 Critical Design Configuration Control Limitation (CDCCL): A fuel system feature the design integrity of which must be maintained to ensure that an unsafe condition does not develop. Features in an aircraft system or component. May exist in fuel system but may also be features in systems or assemblies that interact or cross-couple with fuel systems 32
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SFAR 88 (AC25.981.1c) & JAA TGL 47 and INT/POL/25/12 Examples of CDCCL:Bonding feature attaching to component and tank Separation of fuel gauge wiring from other high power wiring Fuel pump configuration Wire support for high power wiring near to tank We will later look at some characteristic CDCCL from TC Holders
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SFAR 88 (AC25.981.1c) & TGL 47 and INT/POL/25/12 Fuel Tank System Airworthiness Limitation Items (ALI) Fuel System Mandatory Instructions can include Design changes Maintenance Inspections Procedures
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SFAR 88 (AC25.981.1c) & TGL 47 and INT/POL/25/12 Fuel Tank System Airworthiness Limitation Items (ALI) Those items necessary to ensure that
Unsafe conditions do not arise in the fuel system throughout the service life of the airplane ALI to be mandated by AD and included in the Airworthiness Limitations Section of ICAW 35
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Fuel tank system safety introduction for managers of airworthiness & maintenance SFAR 88 (AC25.981.1c) & JAA TGL 47 and INT/POL/25/12
For the identification and management of CDCCL

Related tasks highlighted by TCH in AMM/CMM Airworthiness management procedures put in place Ensure features are protected during repair/changes
Ensure maintenance organisation is aware Implement training programmes
Remember, the feature itself may not be directly related to the fuel system and also may be at component level 36 36 e.g. fuel pump!
Identification and management of CDCCL at a component level
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SFAR 88 (AC25.981.1c) & JAA TGL 47 and INT/POL/25/12 For the identification and management of CDCCL
If fuel pump configuration is to be identified as a CDCCL, how will the operator control the CDCCL? Pool parts Component suppliers
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SFAR 88 (AC25.981.1c) & JAA TGL 47 and INT/POL/25/12 continued 24 For the identification and management of CDCCL
Fuel Pump CDCCL management:This will be a challenge for the operators EASA Part 145 Form 1, FAA 8130-3 Contracts will need to specify CDCCL managed and complied with during MRO activity box 13(?) CAME procedure in place Maintenance procedure for MRO
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Fuel tank system safety introduction for managers of airworthiness & maintenance CRD-22-2005
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An ALI could be a modification/change:EASA AD 2006-0191 A330-200, A340 200/300 aircraft
Air Conditioning prevention against fuel explosion risks installation of heat shields in belly faring
HO2
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Boeing Airplane MPD already published with ALI/CDCCL
e.g. B767 MPD

AWL No. 28-AWL-01: Task ALI detailed inspection of wire bundles over CWT 12y/36000H AWL No. 28-AWL-02: CDCCL External Wires over CWT maintain existing wire bundle routing and clamping
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Boeing Airplane MPD already published with ALI/CDCCL

e.g. B767 MPD AWL No. 28-AWL-03: CDCCL Lightning protection Engine fuel feed line - verify electrical fay surface bond from bulkhead fitting to structure 0.5 milliohms or less AWL No. 28-AWL-04: CDCCL Lightning protection Hydraulic line fuel tank penetration bond checks on heat exchanger and lines to structure and in-line connectors
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Operator required to maintain integrity of CDCCL throughout operation and maintenance of airplane. This could be a challenge
Airworthiness management processes including modification, repair & ARC Maintenance procedures Component maintenance
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FAA Aviation Rulemaking Advisory Committee ARAC studies heating effects on fuel Tanks 1998. External heat sources to be avoided for the future! Flammability suppression guidance developed
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Industry Fuel Tank System Safety programme commenced in 1998 Sample surveys of aircraft in-service fleets
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Industry Fuel System Safety Programme Survey was not conclusive but there were findings Bonding provisions missing Swarf and contamination in tanks Damaged components Evidence of overheated pumps Wiring problems Vent systems incorrectly assembled
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Bonding straps in tanks

Straps missing, broken, loose Straps frayed/worn as a result of wing movement Corroded straps and attachment points Lightning strikes have resulted in the loss of aircraft due to poor bonding! Poor/missing bonds are often caused by maintenance error! You may be only 1 fault away from an unsafe condition!
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Another Survey finding that was very relevant to the future was the relatively high level of maintenance error induced occurrences in fuel tank system installations UK study of B747 occurrences showed 16% maintenance error correlation over a 20 year period! Another relevant finding was the comparative seriousness of the fuel tank system related occurrences
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Maintenance error? Serious occurrences? Most regulatory systems had provisions for flying control system maintenance to reduce the likelihood of maintenance error induced occurrences Required Inspection Items Duplicate Inspections Independent Inspections Perhaps we need to build similar defences for fuel system maintenance?
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Another finding was that Zonal Inspection Programmes were not proving as effective as they ought to be Problems with Mechanic licensing schemes Training of Inspectors at MRO Poor maintenance at component organisations
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Mechanic licensing schemes, Training of Inspectors at MRO Poor maintenance at component organisations? Licensing schemes are not able to adequately address all inspection standards and licensing schemes do not exist at a component level
e.g. Zonal Inspection standard could be

General Visual Surveillance
What do they mean? How are they applied?

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MSG3 Definition: General Visual Inspection:A visual examination from arms length that will detect obvious unsatisfactory conditions/ discrepancies. This type of inspection may require removal of fillets, fairings, access panels / doors, etc. Workstands, ladders etc. may be required to gain proximity.
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Mechanic licensing schemes, Training of Inspectors at MRO Poor maintenance at component organisations? General Visual Inspection requires the identification of obvious signs of deterioration: the Part 66/A&P examinations are not able to test the applicants knowledge to that extent! This determination requires visual parameters.
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Mechanic licensing schemes, Training of Inspectors at MRO Poor maintenance at component organisations? How are the MROs meant to deal with this?
Part 145 requires organisation training for issue of authorisations this would include the need to ensure that relevant inspection standards were covered at an airplane as well as a component level! Continuation training Pictures of inspection findings
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Mechanic licensing schemes, Training of Inspectors at MRO Poor maintenance at component organisations?
Some of the problems uncovered were probably due to poor installation standards during modification activities!
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Wiring problems were being investigated by the Ageing Transport Systems Rulemaking Advisory Committee (ATSRAC) study going on in parallel with SFAR 88 ATSRAC set up by FAA to study ageing effects in systems focuses on wiring systems Produces rule making Enhanced Airworthiness Programme for Aircraft 62 Systems/Fuel Systems (EAPAS)
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2000 - ARAC 2 set up to look into requirements for Flammability Reduction Systems FRS to significantly reduce the development of flammable vapours Workable and economically viable on-board system developed by FAA Technical Centre
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ARAC Flammability Reduction Study Manila 1990 1991 1992 1993 1994 New York 1995 1996 1997 1998 1999 SFAR NPRM SFAR 88 Assessment SFAR 88 Implementation Bangkok 2000 2001 2002 2003 2004+
NTSB recommendations
Industry Fuel Systems Safety FAA Task to Industry Program based on NTSB Recommendations
NGS Development ARAC Inerting Study
Industry and Regulatory consensus: Reducing flammability would provide major benefit to enhancing fuel tank safety
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What has happened since 2004? Things have moved slowly!
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March 2007 EASA Agency Decisions 2007/01R, 2007/02R and 2007/03R issued on Fuel system safety Part 145 organisations component and airplane level Part M airworthiness Management organisations Part 66 Licensing NPA 2008-19 to change rules still not closed!
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2007 Flammability Reduction System certified by FAA/EASA for Boeing products Boeing introduce production cut-ins for current models and proposals for fitment to existing fleets
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Why bother with FRS? FAA estimate that in order to obtain the order of magnitude change required to obtain the required level of safety Ignition Source Suppression on its own required to be at least 75% effective.
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Malaysian Register 727 tank explosion due to wiring failure in wing fuel pump supply wire. B777 CWT fuel leak during TO panel left off after maintenance Airbus FQIS lightning protection failures Ignition source suppression cannot be guaranteed to be wholly effective!
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October 22 2007 FAA issue final rule Enhanced Airworthiness Programme for Airplane Systems/Fuel Tank Safety (EAPAS/FTS) This rulemaking was part of the ATSRAC rulemaking relating to airplane wiring systems and included fuel tank system installations
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What is EAPAS and what has EAPAS got to do with Fuel Tank System Safety? Wiring problems connected with Fuel Tank Safety were delegated to Ageing Transport System Rulemaking Advisory Committee ATSRAC who developed EAPAS.
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July 21 2008 FAA issue final rule Reduction of Fuel Tank Flammability in Transport Category Airplanes
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What do the FAA Rules do and will they affect me?
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Any differences between European/US implementation could affect

Insurance Premiums Lease arrangements operator/operator Lease arrangements operator/leasing company Transfer/Export of Airplanes Airbus/Boeing will be required to meet FAA production cut-in targets production aircraft will be standard In addition - an operator operating an airplane in accordance with Part 129 would obviously be affected!
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The FAA final rule RIN 2120-A123 simultaneously introduces a number of FAA rule changes applicable to US Design Approval Holders (DAH) and operators of US Register airplanes
Introduces Part 26 for DAH to harmonise with EASA(?) Part 121 - Domestic, Flag and Supplemental Operations Part 125 Airplanes seating cap. 20+ pax. Or payload>6000lbs. Part 129 Foreign Air Carriers and Foreign Operators of US Register Airplanes Engaged in Common Carriage
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A detailed knowledge of the FAA rulemaking is not necessary for a non-US register aircraft operator We include a brief summary of the rule making however since there will almost certainly be a need to understand the basics due to the continuing movement of aircraft ownership across international boundaries
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FAA Final Rule summary Introduction of FAR 26 requirements fuel tanks within the fuselage contour flam>7%, all other tanks flam>7%
DAH to assess fleet average flammability exposure to be complete within 150 days following 19 September 2008 Fleet average flammability exposure target <7% Flammability Reduction Means (FRM) to be identified if exposure>7% fuselage contour tanks (AC 25.981-2) Ignition Mitigation Means (IMM) to mitigate ignition sources in tanks (AC 25.981-1) September 20 2010 DAH to submit FRM ICAW including CDCCL 79 September 20 2010 DAH to submit FRM ALI 79
FAA Final Rule summary Introduction of FAR 26 requirements

ALI Airworthiness Limitation Items CDCCL Critical Design Configuration Control Limitations
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FAA Final Rule summary Part 121 by September 20 2010 new production airplanes FRM, to be operational Ignition Mitigation Means (IMM) to be implemented
B747 Series B737 Series Series B777 Series B767 Series Airbus A 318, A 319, A320,A321 series Airbus A 330, A 340
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FAA Final Rule summary Part 121 Retrofit

50% of US operators fleet to have installations required by Part 26 by 2014 100% of US operators fleet to have installations required by Part 26 by 2017 Installations to be operational The flammability targets will effectively result in FRM for most Airbus and Boeing types in current airline 82 use 82
FAA Final Rule summary Part 121 Maintenance Programmes

Type specific ALI and CDCCL mandated by AD Maintenance Programmes must be revised to take into account modifications required by Part 26 Compliance dates for Maintenance Programme changes may be extended subject to use of ground air conditioning for B737, 747, 757, 777, 767 and A300, A310, A318, A319, A320, A321, A330, A340.
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29 May 2008 EASA issue NPA No 2008-16 Fuel Tank Safety incorporation of the Critical Design Configuration Control Limitations (CDCCL) into Acceptable Means of Compliance for Part-M, Part-145 and Part 66 17 July 2008 EASA issue NPA N0 2008-19 Fuel tank flammability reduction this is equivalent to FAA FAR 25 and AC 25.981-1 and AC 25.981-2 this is a design and certification
code for future airplanes and is not retrospective FAA FAR 26 is!
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The EASA change to CS 25 will not result in retrospective implementation to existing fleets and will probably only come into effect for A350 and B787
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EASA rule making will not implement requirement for retro-fit of flammability reduction systems whilst FAA rule will.
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EASA has issued ADs for Airbus fleet ALI and CDCCL Will result in need for changes in maintenance and airworthiness management organisations Part 145 and Part M
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Changes to airworthiness management and maintenance procedures

Task card development Maintenance Procedures including verification tasks tank closure Repairs/changes Maintenance Programme development ARC issue MEL management Occurrence reporting standards Training Quality Audit
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Government of Bermuda DCA Fuel Tank System Safety

Module 6 Len Arnot-Perrett AVISA

fuel tank system safety

Overview for managers of airworthiness & maintenance

Welcome to the course

Fuel tank system safety the beginning?

Fuel tank system safety the beginning?

TWA Flight 800 crashed at 20.30 on July 17 1996

Fuel tanks system safety the end?

Neither the beginning nor the end!

AD Flight Manual Modifications Repairs MMEL Life Limits Airworthiness Limitations C of A

Or has it been safe?

Or has it been safe?

Or has it been safe?

Systemic Change Needed

CS25.1309 AMC 1309

CLASSIFICATION OF FAILURE CONDITIONS

Heated Center Wing Tank 15-30%

Fuel Tank Safety Module 2

30 20 10 0 -50 0 50 100 150 200

Heated CWT Profile Unheated Wing Tank Profile Pointer

For the identification and management of CDCCL

Identification and management of CDCCL at a component level

An ALI could be a modification/change:EASA AD 2006-0191 A330-200, A340 200/300 aircraft

Boeing Airplane MPD already published with ALI/CDCCL

e.g. B767 MPD

Boeing Airplane MPD already published with ALI/CDCCL

Bonding straps in tanks

e.g. Zonal Inspection standard could be

What do they mean? How are they applied?

NGS Development ARAC Inerting Study

What has happened since 2004? Things have moved slowly!

What do the FAA Rules do and will they affect me?

Any differences between European/US implementation could affect

FAA Final Rule summary Introduction of FAR 26 requirements

FAA Final Rule summary Part 121 Retrofit

FAA Final Rule summary Part 121 Maintenance Programmes

Changes to airworthiness management and maintenance procedures

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