Page 1 Goodrich Corporation Sensors and Integrated Systems

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### U. S. Department of Transportation

Federal Aviation Administration Seattle Aircraft Certification Office, ANM-100S Systems & Equipment Branch, ANM-130S 1601 Lind Avenue, SW Renton, WA 98055-4056

Attention: Manager, Seattle Aircraft Certification Office

Subject: Request for AMOC to Airworthiness Directive 2008-10-07

References: 1) Airworthiness Directive (AD) 2008-10-07. 2). Boston ACO approval of Instructions fo r Continued Airworthiness documentation (attached). 3). D6-13747-CMR dated March 2008, 747-100/ 200/300/SP Airworthiness Limitations (AWLs) and Certification Maintenance Requirements (CMRs) 4). PD 9603, revision 5, dated Jan 9, 2009 Ai rplane Maintenance Manual Supplement 5). T3070-0005-0101 revision B, dated April 10, 2009. Instructions for Continued Airworthiness for the Computerized Retr ofit Fuel Quantity Indicating System 6). STC No. ST00020BO.

Attachments: a) PD 9603, revision 5, dated Jan 9, 2009 Airplane Maintenance Manual Supplement. b). T3070-0005-0101 revision B, dated April 10, 2009. Instructions for Continued Airworthiness for the Computerized Retr ofit Fuel Quantity Indicating System c). Copy of Boston ACO approval of Instructions for Continued Airworthiness dated Jun 10,

2009.

Dear Sir,

This letter formally requests an Alternative Method of Compliance (AMOC) to AD 2008-10-07 applicable to Boeing Model 747-100/-200/-300/SP/SR airplanes that have the Goodrich Corporation Sensors and Integrated Systems (formally Fuel & Utility Systems) Replacement Computerized Fuel Quantity Indication System (FQIS) installed per STC No. ST00020BO in acco rdance with para. (k) of the AD (ref 1) and 14 CFR 39.19.. This AMOC request is specific to certain applicable sections of the Boeing D6-13747-CMR document called out in the AD. Detail of the AMOC request is provided below.

We are submitting this AMOC request based on recen t Boston ACO FAA approval of updated Instructions for Continued Airworthiness that include approved CDCCL s to maintain the continued airworthiness of the FQIS installation. A copy of the Boston ACO approval is attached to this submittal letter.

Applicable D6-13747-CMR Airworthiness Limitations Associated with this AMOC Request:

D6-13747-CMR lists a number of airworthiness limitations that are required to be followed as specified in Ref: LTR09-021 Sept 9, 2009Page 2 AD 2008-10-07 para. (g). Most of these limitations can be followed as stated in the D6 document without impact on the STC installation. There are, however, some differences that cannot be followed exactly as specified. It is these limitations, which are stated in Table 1, for which we are requesting an AMOC.

Table 1 details the D6-13747-CMR AWLs for which an AMOC is requested. Goodrich’s Instructions for Continued Airworthiness documents provide an alternat e method of maintaining the continued airworthiness of these parts of the installation. The specific ICA document addressing the AWL is listed in Table 1 along with a description. Some of the required actions are ALIs and some are CDCCLs.

Table 1. D6-13747-CMR AWL’s For Which an AMOC is Requested

AWL No. Type Brief Task Description & Issue Acceptable Alternate Method

28-AWL-02 CDCCL External wire s over Center Fuel tank.

At issue is item no. 2. Installation of new wire bundles cannot be done per Boeing SWPM

D6-54446. Installation of new center tank wire bundle must be done per FAA approved Goodrich AMM supplement (PD 9603) section 28-41-08/401 para 7.

28-AWL-03 ALI Out of tank wiring lightning shield to Ground

Termination.

At issue is item no. 2. A loop resistance test is not used to determine adequacy of shield to ground terminations. Adequacy of lightning shield to ground terminations of all out-tank wiring is done via bonding checks per FAA approved Goodrich AMM supplement (PD 9603) section 28-41- 08/601 at the frequency specified in T3070- 0005-0101 rev. B. This frequency is every 25,000 hrs.

28-AWL-04 CDCCL Out of tank wiring lightning shield to Ground

Termination.
At issue is item no. 2. Termination of shield ground is not done per SWPM 20-10-15. Termination of lightning shield ground is done per FAA approved Goodrich AMM supplement (PD 9603) section 28-41- 08/401 para. 8. This section defines the acceptable repair of these

terminations.

28-AWL-16 CDCCL Repair of In-Tank Wire Harness At issue is the req’t to use SWPM 20-14-12 for any wiring repairs. Also installation of spar penetration must be per Boeing AMM 28-41-

09. On the Goodrich replacement FQIS repair of intank wiring is not allowed. If damage to the wiring occurs the only option allowed operators is to replace the wiring harness. SWPM 20-14- 12 cannot be used to effect repairs.

Repairs to in-tank wiring harnesses are currently not allowed as stated in para. 1 of Goodrich AMM supplement (PD 9603) section 28-41-08/401. Operators are only allowed to replace damaged wire harnesses.

Installation of a new wiring harness (which includes the spar penetration connector) is done per FAA approved Goodrich AMM supplement (PD 9603) section 28-41-08/401 para. 6. These instructions require installation of new “O” rings and fillet sealant along with proper torque values. These instructions accomplish the same result as stated in Boeing

AMM 28-41-09.

Please note that Goodrich plans on updating our top le vel ICA document, T3070-0005- 0101 to include detail in section 10 on CDCCL for repairing our STC product. This information is currently not included in revision B but will be needed when repairing/overhauli ng in-tank components associated with this STC and to comply with the CDCCL requirements of 28-AWL- 15. The in-tank components affected are the tankPage 3 units, compensators and densitometers.

FAA Requested Action:

Please review this request for an AMOC to AD 2008- 10-07 for the AWLs listed in Table 1 above. If acceptable, please provide Goodrich with the required AMOC. All of the other AWLs mentioned in the Boeing D6-13747-CMR document are applicable to 747 airplanes equipped with the Goodrich ST00020BO equipment.

Thank you your attention to this re quest. If additional information is required, please contact the undersigned

or Mr. Rollin Brown.

Sincerely,

Les Blades cc: Rollin W. Brown Systems Engineer Manager, Engineering Programs FAA Designated Engineering Representative FAA Designated Engineering Representative les.blades@goodrich.com rollin.brown@goodrich.com

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