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Goodrich Corporation 

Sensors and Integrated Systems

100 Panton Road 

Vergennes, Vermont 05491

Tel: 802-877-2911

Fax: 802-877-4444

www.goodrich.com

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 for 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 Airplane Maintenance Manual Supplement 

5). T3070-0005-0101 revision B, dated April 10, 2009. Instructions for Continued 

Airworthiness for the Computerized Retrofit 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 Retrofit 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 accordance 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 recent Boston ACO FAA approval of updated Instructions 

for Continued Airworthiness that include approved CDCCLs 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, 2009
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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 alternate 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 wires 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 level 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/overhauling 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 tank 
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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 request. 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 

Tel: 802-877-4580 Tel: 802-877-4303 

Fax: 802-877-4276 Fax: 802-877-4276