### U.S. DEPARTMENT OF TRANSPORTATION OFFICEOFHEARINGS 

# REcE···tvEo FEDERAL AVIATION ADMINISTRATION · . . 

## AUG 142013 HEARING DOCKET FEDERAL AVIATION ADMINISTRATION, Complainant,
vs. LIBERTY FOUNDATION, Respondent. DocketNo. FAA-2012-0477 FAA Case No. 2011GL03007Q?.**~.~**..,., 

### Judge Sullivan 

# ·o MOTIONFORSUMMARY JUDGMENT Pursuant to 14 C.P.R. § 13.218(£)(5), and Rule 56(c) of the Federal Rules of Civil Procedure, the Administrator hereby moves for summaryjudgment in this matter. No genuine issue ofmaterial fact exists to be determined, and the Administrator is entitled tojudgment as a matter oflaw. As grounds for the motion, the Administrator states the following. STATEMENTOF THE CASE On June 5, 2012, the FAA issued a Final Notice of Proposed Civil Penalty against Respondent. Respondent timely appealed, and the Final Notice was filed as the Complaint. The Complaint, as amended, includes makes 18 factual allegations, plus subparts, and a half-dozen allegations of regulatory violations. In short, the Amended Complaint charges that (1) 

### in February 2011, Complainant's Director of Maintenance, Rodney Schneider, removed the existing bladder fuel tanks from civil aircraft N390TH, then fabricated and installing new fuel tanks out ofthe aluminum shells that had beenprotecting the bladder fuel tanks, and returned the aircraft to service; (2) that this constituted a major alteration; (3) that none ofthe appropriate approval were obtained for a major alteration; (4) thatthe alteration leftN390TH unairworthy (5) \. 

# I 

# I I r

### Respondent operated N390TH after these actions; (6) in June 2011, one ofthe fuel tanks leaked, and was repaired by Mr. Schneider; and (6) this repair was improperly performed and no maintenance entry was made for the repair prior to the aircraft's next flight, which terminated when an on-board fire resulted in a forced landing and the loss ofthe aircraft. Respondent does not dispute the underlying facts of this case, but does dispute the regulatory consequences of these actions

- whether the replacement ofthe fuel tanks constituted a major alteration, whetherit rendered the aircraft unairworthy, whether the repair in June 2011 was proper, and whether Respondent is responsible for the various violations that took place. STATEMENTOF THE FACTS Civil aircraft N390TH was a World War 11-era Boeing B-17G bomber, serial number 44- 85734. See 

### Complaint**~** 

### 1; Answer**~** 

### 1; Attachment A (Special Airworthiness Certificate for N390TH). N390TH was operated by Respondent pursuant to an FAA exemption. See 

### Complaint**~** 

### 2; Answer**~** 

### 2. Respondent used the aircraft to tour the country and conduct demonstration flights for members ofthe public. Prior to the events at issue in this case, the maintenance for N390TH was supervised by Respondent's then-Director of Maintenance, Timothy Bourgoine. Attachment B (Timothy Bourgoine Affidavit)**~~5-8.** 

### However, after the close ofthe summer tour season in 20I0, Respol}dent chose to winter N390TH is the vicinity ofAtlanta, Georgia, so that new Director ofMaintenance, Rodney Schneider, could perform the work on the aircraft to address the aging bladder fuel tanks. Attachment B**~** 

### 8; Attachment C (Deposition of Rodney Schneider) at 7-8, 21. Schneider did not hold an Inspection Authorization, and was not authorized to return an aircraft to service after a major alteration or repair. Attachment GG**~~** 

### 28, 35; Attachment HH**~~** 

### 28, 35.

2

### At the time of its manufacture, at the time ofits 2004 restoration, and also at the time immediately prior to the winter of2010-11, N390TH was equipped with six bladder fuel tanks, three in each wing. See Attachment B**~** 

### 15; Attachment GG**~** 

### 8; Attachment HH**~** 

### 8; see also Attachment S at 48-49 (B-170 Parts Catalog listing Goodyear tanks). These bladders were constructed ofthick, rubberized canvas, and were designed to be self-sealing in order to better withstand anti-aircraft fire. See Attachment GG**~** 

### 8; Attachment HH**~** 

### 8. Each fuel tank was connected to the interior ofthe wing via a number of straps, and other components ofthe fuel system were directly attached to the fuel tanks. Attachment B**~** 

### 15; Attachment C at 15-16; Attachment GG**~** 

### 8; Attachment HH**~** 

### 8. Each bladder fuel tank was supported and protected by
an aluminum shell, through which all ofthe straps and fuel lines passed. Attachment B**~** 

### 15; Attachment C at 15-16; Attachment GG**~** 

### 8; Attachment HH**~** 

### 8. There were numerous holes in the shells to permit transit ofthe straps and lines. Attachment B**~** 

### 15; Attachment Cat 15-16; Attachment GG**~** 

### 8; Attachment HH**~** 

### 8; Attachment C at 9-10; Attachments D, E, F (photographs ofan aluminum shell prior to alteration) 1• 

### One end ofeach shell was removable, so that the shell and the bladder fuel tank could be handled separately. Attachment B**~** 

### 15, Attachment Cat26; Attachments D, G; Attachment GG**~** 

### 8; Attachment HH**~** 

### 8. Respondent considered replacing the bladder fuel tanks with new bladders, and also considered hiring an outside company to manufacture new, solid-shell fuel tanks to replace the bladders. Attachment B**~** 

### 8. However, Respondent instead opted to remove the bladder fuel tanks and use the existing aluminum shells to fabricate new fuel tanks. Attachment B**~** 

### 1. Respondent's Director of Maintenance, in conjunction with Respondent's Executive

1Although the photographs have an electronic date-stamp for the year 2005, they were actually taken during the course ofthe work performed during the winter of2010-11. See Attachment C at 27. 

### 3...


### Director/ChiefPilot, Ray Fowler, and one ofRespondent's pilot's, Cullen Underwood, executed this plan. 

### See Attachment 8**~~** 

### 9, 11; Attachment C at 11; AttachmentRat 6, 12-17. Attachments were fabricated to replace the links between the bladder fuel tank and the rest ofthe fuel system. Attachment C at 17. These attachments were welded onto the aluminum shells. Attachment C at 17; Attachments G, H, I, J, K, P. Additionally, metal plates had to be welded onto the shells to cover the holes where the support straps between the bladder fuel tanks and the structure ofthe aircraft had once run through the shells. Attachments H, J, K, L, M, P;



### see also Attachments N, 0. Finally, the removable end ofeach ofthe shells was welded shut. Attachment C at 26. The shells were then installed on the aircraft to be used as fuel tanks. No baffles were installed in the new fuel tanks. No vibration testing was performed on the new metallic tanks. Attachment C at 26. In a maintenance log entry dated February 24, 2011, Respondent's Director of Maintenance signed off on the work and returned the aircraft to service. That maintenance log entry read: Removed all six fuel tanks. Removed bladder lines from the tanks and repaired the aluminum tanks by welding. Ref: AC-43 section 8-32. Fuel tanks are made of aluminum sheet, 1100 

### \12 hard. Reinstalled the original aluminum tanks using the original mounting methods and the original fuel line, boost pump, fuel cap, vent line, and level transmitter mounting locations and methods. The tanks were leak checked and operationally checked with no discrepancies found. Ref. 8-17 Maintenance and ErectionManual, pages 196-199. Attachment 

### Q at 4 (February 24, 2011, maintenance log entry). The work performed by Mr. Schneider is not described in any maintenance handbook for the 8-17. Attachment 8**~** 

### 32; Attachment Cat 36-37; Attachment T (8-170 Maintenance and Erection Manual) at 193-214; Attachment V (8-170 Field Service Manual) at 137-160; Attachment 00**~** 

### 24; Attachment HH

4**~** 

### 24. At no time was an FAA Form 337 completed for the work on the fuel tanks. See 

### Attachment B**~** 

### 14; Attachment GG**~** 

### 31; Attachment HH**~** 

### 31. Respondent then operatedthe aircraft repeatedly betweenthat date and June 11, 2011. On or before June 11, 2011, the welding failed on one ofthe new fuel tanks, causing a substantial fuel leak. Attachment C at 40-42. Respondent flew Mr. Schneider from Atlanta to Illinois in order to repair the leak. Attachment C at 40. Although it would have been safer to
remove the fuel tank from the aircraft and seal it from the inside, Respondent's Director of Maintenance chose not to because he knew it was important for the aircraft to fly to another city the next day. Attachment C at 48-50. Instead, Schneider left the fuel tank in the aircraft, applied sealant to the outside of the tank, and then bolted a C-channel around the repair work. Attachment C at 42-43. The next day, Schneider put some fuel in the tank, performed a limited visual inspection through an access door, and returned the aircraft to service without making a maintenance log entry. Attachment Cat45, 47. The aircraft was then flown by Respondent, and during that flight there was an on-board fire and the aircraft made a forced landing and burned to the ground. See 

### Attachment X (photograph of N390TH after fire and forced landing). After the loss of the aircraft, Mr. Schneider made a back-dated maintenance log entry for the June 13, 2011, return to service. Attachment C at 45. No Form 337 was ever completed for the repair of the fuel tank. See 

### Attachment GG**~** 

### 35; Attachment HH**~** 

### 35. No maintenance manual included provisions for a repair ofthis nature. Attachment C at 44-45 ("We looked through the maintenance and erection manual, field service [manual], and SRM [Structural Repair Manual] and there was nothing in them that even remotely covered this sort ofthing."); see 

### Attachment T at 193-214; Attachment

5

# ..
U (B-17 Structural Repair Handbook); Attachment V at 137-60; Attachment GG**~** 

### 32; Attachment HH**~** 

### 32. A certificate action was initiated against Mr. Schneider, during which he was represented by opposing counsel, and which concluded in an agreed order making a number of factual findings and findings ofviolation, including that findings that Schneider had (1) fabricated the aluminum fuel tanks without any approved data, field approval, or engineering approval; (2) performed a major alteration on the fuel system; (3) made the February 24, 2011, maintenance log entry for this alteration in an incomplete and misleading way such that the major alteration was concealed; (4) used methods and techniques in constructing the fuel tanks that were so far below the standards acceptable in aviation that no competent authority would have approved them; (5) left N390TH in, an unairworthy condition because of the alteration; (6) improperly performed the June 13, 2011 repair; (7) had left N390TH in an unairworthy condition because of the June 13, 2011 repair; and (8) by reason of the above, violated §§ 43.9(a), 43.9(d), 43.13(a), and 43.13(d) ofthe Federal Aviation Regulations. Attachment W. SUMMARY OF THE ARGUMENT The replacement ofthe bladder fuel tanks in N390TH with fuel tanks fabricated from the aluminum shells was a major alteration that rendered the aircraft unairworthy. The central dispute ofthis case is Respondent's contention that this was not a major alteration and, therefore, it was permissible to return the aircraft to service and operate it despite the lack ofan Inspection Authorization, despite the lack ofa Form 337, despite the lack ofapproved technical data, and despite the lack of a maintenance log entry describing the work performed. An alteration is a major alteration ifit 

### "might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness." 14 C.F.R.



### 6

--------------------------

### 1.1 (emphasis added). Here, we know 

### that the airworthiness ofthe aircraft was affected by the alteration because the welding failed and resulted in a substantial fuel leak. Accordingly, in order to find that the alteration was a minor alteration, as Respondent proposes, a finding would have to be made that it was not possible for the alteration to affect the airworthiness ofthe aircraft,
even though it did. As discussed m Part I, Respondent is responsible for the actions of its Director of Maintenance. Respondent had established a long-term, in-house position charged with aircraft maintenance, and then Respondent's Executive Director was directly involved with and informed about all of the maintenance and alterations at issue in this case. Respondent is not only responsible for all of the operational violations described below, but for the improper maintenance itself. As discussed in Part II, the February 2011 fabrication offuel tanks out ofthe aluminum shells was an alteration, not a repair. The change from self-sealing bladder fuel tanks to weldedaluminum fuel tanks was a design change, not a mere restoration to aprevious functioning status. As discussed in Part III, the February 24, 2011, maintenance log entry did not describe the work performed in fabricating the fuel tanks

- it inaccurately presented the alteration as a minor repair to existing metallic fuel tanks, and made no mention of fabrication. Section 43.9(a)(l) was violated by the improper maintenance log entry, and § 91.407(a)(2) was violated by the subsequent improper operation ofthe aircraft. As discussed in Part IV, the February 2011 alteration was a major alteration, not a minor alteration. The alteration did not use accepted practices, was not performed with elementary operations, and affected qualities of the aircraft affecting airworthiness

- it changed the fuel capacity, changed the weight and balance, used materials that would respond to vibration and

7

### flight stress differently than the original configuration, included newly-fabricated components, and involved heavy welding ofquestionable quality. Further, as the Administratorhas previously determined, any alteration ofa fuel tank is a major alteration. As discussed in Part V, the "major" nature of the alteration had immediate regulatory consequences. Respondent's Director ofMaintenance did not hold an Inspection Authorization, and was not authorized to return an aircraft to service after a major alteration. Also, an FAA Form 337 was required by §43.9(d). Section 43.7(a) was violated when the aircraft was returned to service by an unauthorized person, §43.9(d) was violated by the failure to complete a Form 337, §43.5(b) was violated whenthe aircraft was returned to service without completing a Form 337, and §91.407(a)(l) was violated when Respondent operated the aircraft without a proper return to service. As discussed in Part VI, the alteration was improperly performed. The alternation was not contained in any applicable manual, it was not performed in a manner acceptable to the Administrator, and it did not restore the aircraft to its original or properly altered condition. The alteration violated§§ 43.13(a) and (b) oftheFederal Aviation Regulations. As discussed in Part VII, N390TH was unairworthy after the February 2011 alteration because it did not meet its type certificate or type design. The aircraft's limited type certificate explicitly requires that any newly-designed repair or alteration first be presented to the FAA along with evidence that it was an appropriate one - a step which did not happen here. Additionally, the alteration rendered the aircraft unairworthy because it was returned to service by an unauthorized individual, no FAA Form 337 was executed, and the aircraft was not restored to its original or properly altered condition. As a result, Respondent violated § 91.7 when it subsequently operated N390TH in an unairworthy condition.

8

### •



### As discussed in Part VIII, N390TH was unairworthy after the February 2011 alteration because it was not in a condition for safe operation. The unsafe condition ofthe aircraft is amply demonstrated by the brisk failure ofthe improperly altered fuel tanks. As a result, Respondent violated§ 91.7. As discussed m Part IX, all of the violations described above occurred even if the alteration is considered a repair

- it would still be a major repair, not a minor repair, and all of the same regulations would apply. As discussed in Part X, the June 2011 repair was improperly performed. First, there is no such thing as a properly performed repair on a component that should not exist in the first place. Second, as was admitted by Respondent's Director of Maintenance during his deposition, the repair was performed in a more risky manner in orderto get it finished in time for the aircraft to fly the next day (the flight during which the aircraft was lost). Respondent should have removed the fuel tank to properly place sealant inside the tank, and should have performed a more thorough inspection after the repair. As aresult, Respondent violated§§ 43.I3(a), (b). As discussed in Part XI, the June 20II repair was a majorrepair. Any repair to a fuel tank is a majorrepair. As with the February 20I1 alteration, the "major" status ofthe repair results in
numerous regulatory requirements applying, none ofwhich were followed

- Schneider did not have an Inspection Authorization and no Form 337 was completed. As discussed in Part XII, no maintenance record entry was made for the June 2011 repair before the aircraft operated, and was lost, on June 13, 2011. The failure to make the entry violated §43.5(a) and the subsequent operation violated §9I.407(a)(2). As discussed in Part XIII, N390TH was unairworthy at the time ofthe June I3, 20II, flight. In addition to the unairworthiness caused by the February 2011 alteration, the June 2011



### 9

'-----------------------------

--

### •

repair introduced newproblems- the repair was improperly performed, there was no FAA Form 337, and there was no authorized return to service. Respondent violated 

### §91.7(a) by operating the aircraft in an unairworthy condition. As discussed in Part XIV, Respondent's first affirmative defense fails. Respondent has presented no legal 'Or factual basis to be excused from liability for its violations based on the notion that it simply relied onthe representations ofan outside mechanic. As discussed in Part XV, Respondent's second affirmative defense fails. Respondent has presented no legal or factual basis to be excused from liability for its violations based on an oral representation from an FAA inspector, even ifsuch

### a representation was made. ARGUMENT "A party may make a motion for decision, regarding all or any part ofthe proceedings, at any time before the administrative lawjudge has issued an initial decision in the proceedings. The administrative law judge shall grant a party's motion for decision if the pleadings, depositions, answers to interrogatories, admissions, matters that the administrative lawjudge has officially noticed, or evidence introduced during the hearing show that there is no genuine issue ofmaterial fact and that the party making the motion is entitled to a decision as a matter oflaw. The party making the motion for decision has the burden of showing that there is no genuine issue ofmaterial fact disputed by the parties." 14 C.F.R. § 13.218(£)(5). I. 

### Respondent Is Responsible Forthe Actions oflts Director ofMaintenance The regulations at issue in this case fall into two categories. The first category IS 

### regulations that apply to a personperforming maintenance and alterations, returning an aircraft to service, recording maintenance and alterations, and the like. The second category is regulations that apply to persons operating an aircraft. Respondent admits that it operated N390TH after the

10

### maintenance and alterations at issue in this case, and there is no dispute that these regulations apply to Respondent. 2 

### Respondent does dispute, however, whether the Part 43 regulations apply to it. Because all of the maintenance and alterations at issue in this case were personally performed by Respondent's Director of Maintenance, Rodney Schneider, Respondent is liable for those maintenance violations, which have already been established in prior litigation. Further, especially with regards to the winter 2010-11 work, Respondent's Executive Director was directly involved in the decisionmaking process regarding the repairs and alterations, and how they were to be recorded (or notrecorded) in the aircraft's maintenance records. The common law principles of 

### respondeat superior are fully applicable m FAA proceedings in front of the Department of Transportation. 

### See FAA v. Jules Aircraft Service, FAA Docket No. CP07SW0004 (2008); 

### Riverdale Mills Corporation, FAA Order No. 2003-10 (2003). This most typically occurs in the context of an employee/employer relationship, but 

### respondent superior applies to relationships of agency, which extend beyond simple employer/employee relationships. 

### See Riverdale Mills, Order 2003-10 (referencing the Restatement Second ofAgency for guidance in application ofvicarious liability). It

### would appear obvious on the face ofthings that when an aircraft operator designates an individual as the entity's Director ofMaintenance and that individual personally performs the work in question, the individual is acting within the scope of his agency, and the operator is responsible for any ensuing violations. As Director ofMaintenance, Mr. Schneider was charged by Respondent with the maintenance ofN390TH. 

### See Attachment B**~** 

### 6; Attachment Rat 10-11. Indeed, the Director of Maintenance position was directly modeled after the Director of Maintenance position at a Part 121 or Part 13

### 5 air carrier. Attachment R at 10-11. As Director of

2 Respondent does assert that affinnative defense that it should not be held liable for any ofits violations ofthe operational regulations, but that is a distinct matter addressed in Part XIV below. 

### 11 

# I

I

## •

Maintenance, Schneider was in charge ofall work during the winter of2010-211, and was later flown by Respondent from Atlanta to Chicago in June 2011 to address the problem with the leaking fuel tank. 

### See Attachment B**~~** 6, 8; Attachment C at 40. Schneider's duties as Director ofMaintenance included signing offwork onthe aircraft. 

### See Attachment Cat 48; Attachment Q at 3-4, 6-8. Further, with regards to the work performed over the winter of 2010-11, Respondent's Executive Director and ChiefPilot, Ray Fowler, was personally involved in the decision-making

r process. 

### See Attachment 

### B**~~** 8, 11; Attachment C at 18. The Director ofMaintenance had to

check with higher-ups at Respondent for any work that would incur a substantial expense. 

### See Attachment 

### B**~** 6. Not only was Fowler directly involved in the decision to use the cheaper and less safe welding alteration, Attachment C at 18; Attachment R at 13-15; 

### see also Attachment R at 19-20, he was also directly involved in discussions about how to record the work in the aircraft's maintenance records. 

### See Attachment Cat 17; Attachment Rat 13-14, 19. Additionally, much ofthe actual welding to fabricate aluminum fuel tanks was conducted by Cullen Underwood, who is a pilot for Respondent. Attachment C at 11, 23-24; 

### see Attachment R at 12-13, 16-17. Respondent's Director ofMaintenance was not an independent force who was making decisions outside ofthe control ofRespondent, such that Respondent could escape liability for his actions. Rather, the Director of Maintenance was an agent acting within the scope of his agency in performing maintenance and alterations onN390TH. This is true for both the February 2011 alteration ofthe aircraft, and the June 2011 repair ofthe fuel leak. Further, with regards to the February 2011 alteration, much ofthe work was done by one of Respondent's pilots, the decision about how to do the alteration was made by the Executive Director, and the decision

12

### •

about how to record the work was made with his full knowledge. With regards to the June 2011 repair, the Executive Director was personally present with the aircraft. Attachment C at 51; Attachment Rat 34-35. At all times material, Rodney Schneider was the Director of Maintenance for Respondent, and it is liable for the maintenance violation's he committed. As admitted by Schneider and outlined in the Order ofSuspension against him, this improper conduct included 

### (1) fabricating aluminum fuel tanks without any approved data, field approval, or engineering approval; (2) performing a major alteration on the fuel system; (3) making the February 24, 2011, maintenance log entry for this alteration in an incomplete and misleading way suchthatthe major alteration was concealed; (4) using methods and techniques in constructing the fuel tanks that were so far below the standards acceptable in aviation that no competent authority would



## - -.. '• 

### have approved them; (5) altering N390TH such that it was in an unairworthy condition; (6) improperly performing the June 13,2011 repair; (7) repairing N390TH such that it was in an unairworthy condition; and (8) by reason ofthe above, violating§§ 43.9(a), 43.9(d), 43.13(a), 43.13(d). Attachment W. On the uncontested facts presented about Schneider's role as Director of Maintenance with Respondent, and the Executive Director's direct involvement in these matters, Respondent is liable for the improper maintenance and alterations performed and the improper signoffs (or lack ofsignoffs) for that work. The FAA is entitledtojudgment as a matter oflaw, and summary judgmentis appropriate. II. The Work on N390TH That Concluded In The February 24,2011, Return to Service Was An 

### Alteration There is no dispute as to the material facts ofwhat work was performed onN390TH over the winter of 2010-11, culminating in the February 24, 2011, maintenance record entry and
13

### •

return to service. 

### It is undisputed that N390TH was equipped with bladder fuel tanks supported by aluminum shells, that the bladder fuel tanks were removed and discarded, that fittings were fabricated and welded onto the shell, that aluminum plates were welded onto the shell to cover the holes in the shell (the shell had holes for the straps that ran from the bladder tanks to the interior structure ofthe wing), that the removable end ofthe aluminum shell was welded shut, and that the newly created components were installed on the aircraft and used as fuel tanks.3 

### Virtually the same regulatory violations follow from Respondent's conduct whether this work
was an alteration or a repair, butthe work was an alteration. The Federal Aviation Regulations do not contain a definition of"repair" or "alteration." See I4 C.F.R. 

### 1.1. However, the older Civil Aviation Regulations defined a "repair" as an operation required to restore an aircraft to a condition for safe operation, including mending or replacement of damage or broken parts, and an "alteration" as any appreciable change in the design ofan aircraft. C.A.R. 

### §§ 18.3, 18.4. The work performed here was manifestly an alteration. Attachment B**~** 

### I8; Attachment GG**~** 

### II; AttachmentHH**~** 

### II. Before the work, the aircraft had bladder fuel tanks, supported by aluminum shells. Attachment B**~IS;** 

### Attachment GG**~** 

### 8; Attachment HH**~** 

### 8. After the work, the aircraft had no bladder fuel tanks, buthad a completely different kind offuel tank. This is an appreciable change in the design of an aircraft, not a mere mending of an existing component (such as mending the bladder fuel tanks), or the replacement of an existing component (e.g., removing the existing bladder fuel tanks and installing new bladder fuel tanks). Attachment B**~** 

### 18; Attachment GG**~** 

### 11; AttachmentHH**~** 

### I1.

3 Respondent may disagree with the particularwording choices, but there is no dispute as to the underlying work performed. For example, Respondent denied allegations in the Complaint that it "fabricated" fuel tanks, but there is no dispute that it took aluminum shells that were not capable ofholding fuel, fabricated attachments, welded various things onto the aluminum shells, and then installed them as fuel tanks on the aircraft. 

### I4

### •

There is no dispute of fact on this point, only a dispute of into which regulatory classification the undisputed facts place the work performed. Such a dispute is not a dispute of fact, but a dispute oflaw. It 

### is clear that the work performed was not a mere restoration ofthe aircraft to its prior form, but a change in the design ofthe aircraft

- therefore, the work was an alteration, not arepair. The Administratoris entitled tojudgment as a matter oflaw on this point. III. The February 24, 20I I, 

### Maintenance Record Entry Did Not Describe The Work Performed The February 24, 20II, maintenance record entry made concerning the actions taken on the fuel tanks in the winter of20I0-I I did not describe the work actuallyperformed. Section 43.9(a) ofthe Federal Aviation Regulations provides, in pertinent part, that each person performing maintenance or an alteration on an aircraft, airframe, or component shall make an entry in the maintenance record ofthat equipment containing a description ofthe work performed. I4 C.F.R. § 43.9(a)(I). "No person may operate an aircraft that has undergone maintenance, preventative maintenance, rebuilding, or alteration, unless
... (2) The maintenance record entry required by §43.9 or §

### 43.I I, as applicable, ofthis chapter has been made." I4 C.F.R. § 91.407(a)(2). As discussed above, the actual work performed on this aircraft was to perform an alteration of the aircraft by removing and discard the existing bladder fuel tanks, fabricating attachments, welding those attachments onto an aluminum shells, welding aluminum plates to fill up holes in the aluminum shells, welding shut the removable end ofthat aluminum shell, and then installing the welded-aluminum shell as fuel tanks. Attachment C at I7, 26; Attachments G, H, I, J, 

### K, L, M, 0, P. The maintenance record entry made byMr. Schneider, onthe otherhand, stated:



### I5

### •

Removed all six fuel tanks. Removed bladder lines from the tanks and repaired the aluminum tanks by welding. Ref: AC-43 section 8-32. Fuel tanks are made of aluminum sheet, 1100 

### Yz hard. Reinstalled the original aluminum tanks using the original mounting methods and the original fuel line, boost pump, fuel cap, vent line, and level transmitter mounting locations and methods. The tanks were leak checked and operationally checked with no discrepancies found. Ref. B-17 Maintenance and ErectionManual, pages 196-199. Attachment Qat4 (February 24, 2011, maintenance log entry). The maintenance entry does not accurately and completely describe the work performed. It

### refers to a repair, when there was an alteration. It

### refers to repairing aluminum tanks and then reinstalling the "original" aluminum tanks when, in fact, there had never been aluminum tanks installed on N390TH. It 

### fails to mention the fabrication ofindividual attachments to be welded onto the new fuel tanks, much less that the fuel tanks themselves had been fabricated and were
new. The incomplete and misleading maintenance log entry served to conceal the nature ofthe major alteration performed on N390TH. As a result, §43.9(a) was violated when Respondent's Director ofMaintenance failed to make the required maintenance entry describing the work actually performed, and Section 91.407(a)(2) was violated repeatedly when Respondent subsequently operated the aircraft. There is no genuine dispute offact on this matter
- the nature ofthe work performed is undisputed, and the maintenance entry that was made is also undisputed. The disparity between them is evident

- while Respondent may argue that the description in the entry is complete and accurate, any such dispute is not a genuine one. Argument for argument's sake is insufficient to defeat summaryjudgment, and the Administrator is entitled to judgment as a matter oflaw on this point.

16

# ..

IV. The February 24,2011, Alteration Was AMajor Alteration, NotA Minor Alteration The February 24, 2011, alteration

### was·~**majo~** alteration, not a minor alteration. An alteration is a minor alteration ifit is not capable ofaffecting any characteristic ofthe aircraft relating to airworthiness, is performed according to ·accepted practices, and is performed with only elementary operations. The replacement of the bladder fuel tanks with the weldedaluminum fuel tanks was not only capable of affecting the airworthiness ofthe aircraft, it did 

### affect the airworthiness ofthe aircraft. It

### was, additionally, not performed according to accepted practices or with only elementary operations. Accordingly, it was a major alteration. The Definitions section oftheFederal Aviation Regulations provides that: Major alteration 

### means an alteration not listed in the aircraft, aircraftengine, or

. propeller specifications-·

(1) That might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, orotherqualities affecting airworthiness; or (2) That is not done according to accepted practices or cannot be done by elementary operations. 14 C.F.R. 1.1 (emphasis in original). Although the term is no longer used in the regulations, the term "minor alteration" refers to any alteration other than a major alteration. See 

### C.A.R. §§ 18.40, 18.41 (defining a "minor alteration" as any alteration not capable of affecting the airworthiness of the aircraft, and defining a "major alteration" as any alteration that is not a minor alteration). As is apparent on the face ofthis definition, the bar tojump from a minor alteration to a major alteration is a very low one. Indeed, the vast majority ofalterations one could perform on
an aircraft are major alterations. In order to be major alteration, it need only be the case that the alteration might 

### affect any quality affecting the airworthiness ofthe aircraft

- in order to be a

17

### mmor alteration an alteration must be incapable of affecting any quality that affects the airworthiness ofthe aircraft. There are three ways in which an alteration can be a major alteration - (1) the alteration might affect a quality ofthe aircraft affecting airworthiness; (2) the alteration is not performed in accordance with accepted practices; and (3) the alteration cannot be completed with elementary operations. See 14 C.F.R. § 1.1. The alteration ofN390TH is a major alteration under all three standards. First, there are, broadly speaking, three reasons why the alteration might affect a quality affecting the airworthiness ofthe aircraft. The first is that the alteration did affect the airworthiness ofthe aircraft. In June 20II,

### the welding on one of the welded-aluminum fuel tanks failed, causing a substantial fuel leak. Attachment C 

### at 40-42. Whether or not fuel leaks out ofan aircraft at a rapid pace such that the aircraft cannot be safely flown is manifestly a quality affecting airworthiness. See Attachment B**~** 

### 24; Attachment GG**~** 

### 13; Attachment HH**~** 

### 13. In order to find that the alteration ofN390TH
was a minor alteration, the Judge would have to find that the alteration was not capable of affecting any quality affecting the airworthiness ofthe aircraft, even though the alteration 

### did affect a quality affecting the airworthiness ofthe aircraft. There can be no genuine dispute offact
on this subject, and the application ofthe legal definition ofa "majoralteration" is clear. A second reason why the alteration was a major alteration is that the Administrator has already determined that any alteration consisting ofnew fuel tank, or a change to an existing fuel tank, is a major alteration. Attachment BB 

### (FAA Order 8900.1, Change 71) at Figure 4-68 (Major Alterations Job Aid) at 22-23 (general aviation aircraft), 26 (rotorcraft), 29 (transport

18 I' I

# ..

category airplanes);4 

### see also Attachment GG

### ~ 15; Attachment HH

### ~ 15. Changing or installing
new fuel system components- especially fuel tanks- is a major alteration. The Administrator's interpretation of his regulation is binding and, as a matter of law, requires a finding that the alteration here was a major alteration. A third reason - or, more properly speaking, set ofreasons - why the alteration was a major alteration is the myriad ways in which the alteration might have appreciably affected qualities ofthe aircraft affective airworthiness. These reasons include: The newwelded-aluminum fuel tanks had a higher fuel capacitythan the original bladder fuel tanks

- this affects flight characteristics in and of itself, but also has secondary effects; The higher fuel capacity could affect the weight and balance ofthe aircraft; The higher fuel capacity could affect the stress placed on the wing structure by the fuel tanks, 

### see 14 C.F.R. § 25.963(a) (requiring that fuel tanks must be able to withstand the vibration, inertia, fluid loads, and structural loads placed upon it); This was exacerbated because there were no baffles included in the welded-aluminum tanks. There were no baffles in the original rubber fuel tanks, but a fully rigid shell of welded-aluminum does not respond in the same way to the force of the shifting of thousands of pounds of aviation fuel as the bladder did, 

### see 14 C.F.R. § 25.965(a) (requiring testing of the tanks ability to withstand fluid pressures under adverse flight circumstances);

4 Change 71 was implemented on July 28, 2009, and remained the version ofthe major alterationsjob aid in effect at the time ofthe February 20II alteration. The only material change to thejob aid since that time has been an increase in the level ofscrutiny given to fuel tank alterations, with field approvals no longer being permitted. 

### 19

# ..

The newly-fabricated attachments and fittings were, instead ofbeing attached to a semirigid bladder fuel tank, attached to a fully rigid welded-aluminum fuel tank, which could impact how the fuel system was able to cope with physical stress onthe system; The welded-aluminum tanks were susceptible to vibration in ways that the bladder fuel tanks were not; indeed, rigid metallic fuel tanks are subject to certification testing requirements concerning vibration that non-metallic tanks are not, see 

### 14 C.F.R. § 25.965(b); Welding aluminum can increase the possibility ofcorrosion; and Welding can introduce weaknesses into an aluminum component being welded. 

### It can make the component more vulnerable to stresses from vibration and force. For these reasons, the B-170 structural repair manual expressly forbids welding of aluminum structural components. See 

### Attachment U. 

### While the fuel tank on a B-170 is not a structural component, and so welding on a the fuel tank of a B-170 is not flatly prohibited, the same vulnerabilities would be present, and could affect the integrity ofthe fuel tanks. Indeed, as discussed above, the welding did, in fact, cause one ofthe fuel tanks to fail. Attachment B 

### ,-r 21; Attachment 00

### ,-r 14; Attachment HH**~** 

### 14. It

### is worth noting again here that the standard for whether an alteration is a major alteration or a minor alteration is simply whether the alteration might 

### affect a quality affecting airworthiness. 14 C.F.R. § 1.1. The FAA need not show that the alteration would have affected the airworthiness of the aircraft (although, as discussed above, there can be no genuine dispute about the fact that it did), but only that it might 

### affect a quality affecting the airworthiness. All ofthe above-listed items are ways in which the alteration might have affected qualities affecting the airworthiness ofthe aircraft

- in order for


### 20 I i

### the FAA's claim to fail, a finding would have to be entered that it was 

### notpossible for any ofthe above considerations to affect any quality affecting the airworthiness ofthe aircraft. In addition to affecting qualities affecting the airworthiness ofthe aircraft, the alteration ofN390THwas a major alteration because it was not done in accordance with accepted practices
or done with elementary operations. Fabricating a fuel tank out ofan aluminum shell by welding
on attachments and metal plates to close openings is not an accepted practice, as that term is used in the FAR 1.1 definitions of major alteration and major repair. Attachment GG**~** 

### 18; Attachment HH**~** 

### 18. And the fabrication ofnew fuel tanks out ofthe aluminum shells was a major alteration because fabricating components and this sort of extensive welding are not elementary operations. 

### See Attachment B**~** 

### 22; Attachment GG**~** 

### 17; AttachmentHH**~** 

### 17. Each of the reasons discussed above, standing alone, means that the alteration of N390TH was a major alteration, not a minor one. 

### See Attachment B**~** 

### 24; Attachment GG**~** 

### 19; Attachment HH**~** 

### 19. The Administrator has previously determined that any permanent change to a fuel system component, or addition ofa new fuel system component, is a major alteration. There are more than halfa dozen ways in which the installation ofthe new welded-aluminum tanks could affect qualities affecting the airworthiness ofthe aircraft, including the possibility that the welding could fail and cause a fuel leak - a failure that actually happened. A finding that the February 2011 alteration was a minor alteration requires a finding that it was not possible for the alteration to affect any quality relating to the airworthiness ofthe aircraft, even though it did have an effect. Additionally, the alteration was not done in accordance with accepted practices, and was notdone with elementary operations. There is no dispute as to the facts ofthe work that
was done on N390TH, and as a matter oflaw that alteration was a major alteration. The FAA is entitled tojudgment as a matter oflaw on this point.

21

### V. Immediate Regulatory Consequences OfBeing A MajorAlteration Having established that the alteration completed in February 2011 was a major alteration, it may be helpful to examine what the immediate regulatory consequences ofthis distinction are. There are two prominent ones. First, because the alteration was a major alteration, Schneiderhad
no authority to return N390TH to service after the alteration. Second, because the alteration was
a major alteration, Respondent was required to complete an FAA Form 337 and obtain authorization from the FAAbefore operatingthe aircraft. Holding a mechanic certificate authorizes an individual to perform (most) maintenance and alterations on an aircraft, but does not authorize returning aircraft to service. 14 C.F.R. §

### 65.81(a). Holding an airframe rating authorizes a mechanic to return an aircraft to service after airframe maintenance or an alteration

- 

### exceptfor major repairs and alterations. 14 C.F.R. 

### §65.85(a). In order to return an aircraft to service after a major repair or alteration, a mechanic must also hold an Inspection Authorization. 14 C.F.R. 

### §65.95(a)(l). Section 43.7 ofthe Federal Aviation Regulations provides, in pertinent part, that no person may return an aircraft or componentthereofto service except for the Administrator, or aperson expressly authorized to do
so in the regulations. 14 C.F.R. 43.7(a). "No person may operate any aircraft that has undergone maintenance, preventative maintenance, rebuilding, or alteration unless

- (1) 

### it has been returned to service by aperson authorized under§ 43.7 ofthis chapter." 14 C.F.R. § 

### 91.407(a)(l). At no time material herein did Respondent's DirectorofMaintenance, Rodney Schneider, hold an Inspection Authorization. Accordingly, Schneider could not return N390TH to service after the major alteration of the aircraft in February 2011. As a result, Respondent violated 

### §43.7(a) when its Director ofMaintenance returned N390TH to service after a major alteration

22 

# I

### despite not being authorized to do so. Additionally, Respondent then repeatedly violated §

### 9I.407(a)(l)by operating N390TH when there hadbeen no authorized return to service. Additionally, because the alteration was a major alteration, section 43.9(d) requires that "majorrepairs and alterations shall be entered on a form, and the form disposed of, in the manner described in Appendix B, by the person performing the work." I4 C.F.R. §

### 43.9(d). Appendix B to Part 43 requires that an FAA Form 337 be executed. I4 C.F.R. Part 43, App. B(a). Notably, completing the Form 337 requires obtaining written approval from the FAA or an appropriate engineering authority for the major repair or alteration. 

### See Attachment Y (Advisory Circular 43.9-IF, including a copy ofForm 337). No FAA Form 337 was evercompleted for theFebruary 24, 20II, alteration. As a result, 

### Respondent, through its Director of Maintenance, violated §

### 43.9(d). Respondent, through its Director ofMaintenance, also violated 

### §43.5(b), which provides that no aircraft may be returned to service after an alteration unless the form authorized by or furnished by the Administratorhas been executed in the mannerprescribed by the Administrator. I4 C.F.R. §

### 43.5(b). N390TH was returned to service on February 24, 20II, without the formFAAForm 337- having been executed. VI. The Alteration Was Not Properly Performed The alteration ofN390TH in February 20II did not comply with the requirements of§ 43.13 of the Federal Aviation Regulations

- the methods used were not acceptable to the Administrator, and the results did not restore the aircraft to its original or properly altered condition. Section 43.13 ofthe Federal Aviation Regulations contains the basic general performance rules for maintenance ·and alterations. "[E]ach person performing maintenance, alteration, or

23

### preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator, except as noted in 43.16." 14 C.F.R. 43.13(a). "[E]achperson maintaining oraltering, orperforming preventive maintenance, shall do that work in such a manner and use materials ofsuch a quality, that the condition ofthe aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness)." 14 C.F.R. §43.13(b). Most maintenance and alterations performed on aircraft fulfill therequirements ofPart 43 because they are performed in accordance with a maintenance manual system published by the manufacturer ofthe aircraft, or in accordance with a supplemental document approved by the Administrator, such as a Supplemental Type Certificate or an Airworthiness Directive. Here, however, Respondent came up with its own alteration, and cannot take shelter behind any of these standards

- it is undisputed that the alteration was not contained in any maintenance manual, Instructions for Continued Airworthiness, or other document approved by the Administrator. 

### See Attachment T (B-17G Maintenance and Erection Manual) at 193-214; Attachment V (B-17G Field Service Manual) at 137-160; Attachment GG (Affidavit ofThomas Soerens)

### ~ 24; Attachment HH (Affidavit ofDonald

### Dodge)~ 24. 5 

### Accordingly, in order for Respondent to have complied with § 43.13(a), it needs to have performed the alteration on N390TH using "other methods, techniques, and practices acceptable to the Administrator." 

### See 14 C.F.R. § 43.13(a). Given that it is the FAA bringing a Complaint

5 The FAA anticipates submitting a fourth, consistent expert affidavit from Thomas Duellman. However, Inspector Duellman is currently suffering from pneumonia and, accordingly, the affidavit is not yet available. 

### 24 

## I !'

### alleging that the work was not performed in an acceptable manner, this places the Respondent in
a rather awkward position. And, indeed, during the course ofthis litigation, Respondent has been unable to identify a legitimate reason to believethat its alteration ofN390TH was performed in a
manner acceptable to the Administrator. On a basic level, the FAA's burden ofpersuasion on this point is minimal- ifthe FAA,
as the enforcement agency for this regulation, underpowers delegated by the Administrator, says that the methods, techniques, and practices are not acceptable, then this, ifunrebutted, is in and ofitselfsufficient to establish that the methods, techniques, orpractices were not acceptable. The way in which a Respondent would typically attempt refute this would be to point to
some document issued by the Administrator indicating that a particular method, technique, or practice was acceptable. Respondent is unable to do that here, however, because there is no such document

- no Advisory Circular or FAA Order has ever indicated that an appropriate way to address a problem with existing fuel tanks is fabricate new ones by spot-welding a piece of aluminum that is riddled with holes into a fuel tank. Respondent's Director of Maintenance points to Advisory Circular 43.13-1B, but that AC says nothing about this sort ofalteration. See 

### Attachment C at 37; Attachment 

### Q at 4; Attachment Z (AC 43.13-IB) at § 8-32. Indeed, Respondent has been unable to provide any reason whatsoever to conclude that this alteration
was performed in a manner acceptable to the Administrator. Beyond this, however, there are several reasons why the alteration as performed was unacceptable. See 

### Attachment GG**~** 

### 25; 

### Attachment HH**~** 

### 25. 

### Numerouspotential problems with the new tanks are outlined in Part IV, above. In addition to the existence ofall ofthese potential (and actual) weaknesses, the methods used by Respondent were unacceptable in that they did not include appropriate inspections and references necessary to ensure the airworthiness and safety

25

### •



### ofthe new fuel tanks. Attachment GG**~** 

### 25; Attachment HH**~** 

### 25. No inspection was performed to see how the new metallic tanks would withstand vibration or other flight stresses. Attachment C at 26. No technical data exists on the newly-fabricated tanks. These sorts of checks are a necessary part ofan appropriate procedure for performing an alteration. The alteration did not comply with§ 43.13(a). Additionally, the alteration did not restore the aircraft to a condition "at least equal to its original or properly altered condition." 

### See14 C.F.R. 43.13(b). There are, again, all of the problems identified in Part 

### IV above. And, again, it is manifest that the February 2011 alteration introduced new weaknesses into the aircraft because the failure ofthe fuel tanks in June 2011

- caused by the welding

- was one that would not, and could not, have occurred had the aircraft been in its original or properly altered condition. Attachment GG**~** 

### 26; Attachment HH**~** 

### 26. Respondent, therefore, violated 14 C.F.R. 

### §43.13(b). There is no genuine issue of material fact that the February 2011 alteration was not performed in accordance with §

### 43.13. Throughout this litigation, Respondent has been unable to identify any fact or explanation in support of the notion that the alteration was properly performed. One presumes it will muster something new in response to thisjudgment motion, but
no "expert" opinion on this position can survive the simple, undisputed fact that one ofthe new fuel tanks failed less than four months after it was fabricated

- no component that was properly altered·, using proper methods as described in§ 43.13(a), and to proper standards as described in 

### §43.13(b), would fail so quickly. There is no.genuine issue ofmaterial fact onthis point, and the FAA is entitled tojudgmentas a matter oflaw. Accordingly, summaryjudgmentis appropriate.

26 i. I I

!

### •
VII. N390TH Was Not In An Airworthy Condition After the February 2011 Alteration Because It DidNotMeet Its Type Certificate orType Design The installation of the welded-aluminum tanks in N390TH rendered the aircraft unairworthy, both because it was no longer in conformance with its type certificate or type design and because it was no longer in a condition for safe operation. The latter will be discussed below. The former will be discussed here. An aircraft may not be operated unless it is airworthy. 14 C.F.R. § 91.7. In order for an aircraft to be airworthy, it must be in conformance with its type certificate or type design (and any applicable Airworthiness Directives and Supplemental Type Certificates), and in a condition for safe operation. 

### In re Husted, FAA Order 2010-9. An aircraft is unairworthy when it does not meet its type certificate ortype design, orwhen it is not in a condition for safe operation. 

### !d. The concept ofan aircraft not meeting its type certificate or type design is a broad one. For example, an aircraft ceases to conform to its type certificate or type design when it is repaired with a method that has not been approved or accepted by the Administrator, when the aircraft is not in its original or properly altered condition, when it is returned to service by an unauthorized person, !d., when a required component is replaced with an improper substitute, In


### re Rushmore Helicopters, FAA Order 2012-8; when a component is cracked, orwhenthe aircraft has any unresolved maintenance discrepancies or is overdue for a required inspection, In 

### re Whitley; FAA Order 2009-4. An aircraft's airworthiness certificates cease to be effective when the aircraft is not maintained in accordance with Part 43 and Part 91. 14 C.F.R. § 21.181(a)(l). Here, N390TH did not meet its type certification or type design. First, the aircraft did not meet the particular language listed in its type certificate. The limited type certificate for the B17G is briefand lack details due to the age ofthe design and due to the nature ofthe aircraft as a purpose-built bomber that was only later given a limited civilian certification. 

### See Attachment
27

### •


### AA (B-17G Limited Type Certificate). However, despite the general lack of specificity in the type certificate, the February 2011 alteration still left N390TH out ofcompliance with the type certificate because the type certificate expressly states that for any repair or alteration ofthe B17G that is not done in accordance with the applicable repair manual, the proposed maintenance
or alteration must be presented to the Civil Aeronautics Administration (now the Federal Aviation Administration) along with evidence demonstrating that the repair or alteration IS 

### appropriate. Attachment AA at 1, n.3; Attachment GG**~** 

### 27; Attachment HH**~** 

### 27. It IS 

### undisputed that Respondent made no attempt to make a demonstration to the FAA that the alteration was appropriate, much less obtained an agreement from the FAA that they had presented evidence establishing that the alteration was appropriate. Accordingly, after the February 2011 alteration, N390TH did not meet its type certificate or type design. N390TH failed to meet its type certificate or type design for many other reasons. As discussed in Part VI above, it was altered in a manner that was not acceptable to the Administrator. Attachment GG**~** 

### 28; Attachment HH**~** 

### 28. No approved data was used in performing the alteration, a requirement for a major alteration. Attachment GG**~** 

### 28; Attachment HH**~** 

### 28. As no authorization was ever obtained for the welded-aluminum fuel tanks, N390TH
was not restored to its original or properly altered condition after the fuel tank replacement

- the welded-aluminum tanks manifestly did not equal the characteristics oforiginal bladderfuel tanks that related to airworthiness, such as resistance to vibration and other stresses of flight. Attachment GG**~** 

### 28; Attachment HH**~** 

### 28. As discussed in Part V above, because the alteration
was a major alteration, Schneider was not authorized to return the aircraft to service. Attachment GG**~** 

### 28; Attachment HH**~** 

### 28. Each ofthese reasons, standing alone, can render an aircraft

28

### unairworthy. 

### See Husted, FAA Order 2010-9, 

### Rushmore Helicopters, Order 2012-8; 

### see also Attachment GG**~** 

### 29; Attachment HH**~** 

### 29. While Respondent will, presumably, protest, there is no genume Issue fact on these points. Respondent did not seek authorization before performing an alteration outside of the aircraft's manual system. Respondent insists that the alteration complied with §

### 43.13(a), but because the alteration was not contained in any manual or Instructions for Continued Airworthiness, Respondent could only comply with 

### §43.13(a) ifthe alteration was performed with other techniques and methods acceptable to the Administrator

- but, during the course of this litigation, Respondent has been unable to produce any sort ofexplanation or facts supporting the notion that this alteration was done in a way acceptable to the Administrator. Nor has Respondent provided any explanation or facts supporting the notion that these new fuel tanks,
one ofwhich failed after less than four months, were the equals ofthe originals when it came to qualities affecting airworthiness. Since the alteration was a major alteration, it follows as a matter of law that Schneider, lacking an Inspection Authorization, could not validly return the aircraft to service. On some of these issues, there has been no 

### genuine dispute of fact, only Respondent's unsupported denials. On other issues, there is no dispute offact at all. The FAA is entitled tojudgment as a matter oflaw as to the conclusion that N390TH was unairworthy after the February 2011 alteration, and summaryjudgmentis appropriate. VIII. N390TH Was Not In An Airworthy Condition Because It

### Was Unsafe ForFlight In addition to not meeting its type certificate or type design, N390TH was unairworthy because it was not in a condition for safe operation. 

### See Husted, Order20I0-9. The February 24, 2011, alteration involved replacing bladder fuel tanks with aluminum fuel tanks with extensive welding of new components and plates, and welding shut the

29

# ..
previously-removable ends of the shells. Less than four months later, the welding failed, resulting in a substantial fuel leak. As common sense would indicate, and as discussed in the attached affidavits, this demonstrates that N390TH was not in a condition for safe operation after the February 24, 2011, alteration. 

### See Attachment B**~** 

### 31; Attachment GG**~** 

### 30; Attachment HH**~** 

### 30. Simply put, an aircraft is unsafe for flight when it has installed on it six poorly-fabricated fuel tanks that may crack open at any moment and·begin spewing fuel into the interior ofthe

-.·- 

# -

. 

### aircraft. Based on disclosures during discovery, it is possible that Respondent will submit an expert report asserting that the welding was ofhigh quality, introduced no flaws into the fuel tanks, and that aircraft was perfectly safe to fly as altered. However, an "expert" opinion that seeks to flatly contradict observed reality does not create the genuine issue of material fact necessary to preclude summaryjudgment. The Administrator is entitled tojudgment as a matter oflaw, and summaryjudgment should be granted onthis point. IX. The Violations Described Above All Occurred Even IfThe February 2011 Work Was A Repair During the course of this litigation, Respondent has refused to indicate whether it believes the work was an alteration or a repair. However, Respondent's onll "expert"7 

### witness, Gary Norville, asserts that the work was a repair. Attachment EE at 10-12. Accordingly, the FAA will address thispotential dispute. Mr. Norville's opinion is in error- as discussed above in Part II, the work performed on N390TH overthe winter of2010-11 was an alteration. Mr. Norville further asserts that, not only

6 Respondent originally identified additional expertwitnesses, buthas since withdrawn them. 7 It is unclearto what extent, ifany, Mr. Norville is actually an expert on the issues in this case. Accordingto his deposition testimony, his opinions, as presented in his report, were formed with no knowledge whatsoever ofwhat work had actually been done on N390TH, but rather based exclusively on an assessment ofthe February 24, 2011, maintenance log entry. See Attachment EE at 8-10. 

### 30

### was the work a repair, it was a minor repair rather than a major repair. 

### See Attachment DD at 1; Attachment EE at 12. This opinion is also in error. Ifthe work was a repair, it was a majorrepair, and all ofthe legal consequences described above still flow from Respondent's actions. According to the Definitions section ofthe Federal AviationRegulations: Majorrepair means a repair: (1) That, ifimproperly done, might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other
. qualities affecting airworthiness; or (2) That is not done according to accepted practices orcannotbe done by elementary operations. 14 C.P.R. 1.1. Additionally, the examples provided in Appendix A to Part 43 explicitly states that "Repairs to the followingparts ofan airframe
... are major repairs
... Repairing, including rebottoming, of removable or integral fuel tanks and oil tanks." 14 C.P.R. Part 43, App A(b)(1

### )(xxviii). The first noteworthy aspect ofthese regulations is that it flatly contradicts Mr. Norville's opinion that the work, ifit was a repair, was not a major repair- any repair to a fuel tank is a major repair. 

### See 14 C.P.R. Part 43, App A(b)(l)(xxviii). Additionally, it is noteworthy that the definition ofmajor repair almost exactly tracks the definition ofmajor alteration

- even setting aside Appendix A, the "repair" of the fuel tanks was a major "repair" for all of the reasons described above in Part IV. 

### See Attachment B**~~** 

### 26-28; Attachment GG**~~** 

### 21-23; Attachment HH**~~** 

### 21-23. Furthermore, the same regulatory consequences follow regardless of whether the work

was a repair or an alteration. Just as Mr. Schneider, lacking an Inspection Authorization, could not return the aircraft to service after a major alteration, he could not return it to service after a major repair, and without a proper return to service, Respondent could not operate the aircraft.
31

### See 

### 14 C.F.R. §§ 

### 14.7, 65.85(a), 65.95(a)(1), 91.407(a)(l). An FAA Form 337 is required for major repairs as well as major alterations. 14 C.F.R. §

### 43.9(d). The deficiencies in the alteration ofthe aircraft are deficiencies whether it is labeled an alteration or a repair, and section 43.13 applies either way. See 

### 14 C.F.R. §43.13(a), (b). Whether the work is labeled a repair or an alteration, the aircraft did not meet its type certificate or type .design for all ofthe reasons listed in Part VII above. Whether the work is labeled a repair or an alteration, the aircraft was not in a condition for safe operation, as described in Part VIII, and so was unairworthy. Either way, the aircraft was unairworthy, and Respondent violated 14 C.F.R. §91.7. Indeed, the 

### only difference would be that the maintenance record entry is less inaccurate, in that it uses the word "repair" rather than "alteration"

- although it is still inaccurate because it does not describe the work performed (as discussed in Part Ill). There would still be a violation of 14 C.F.R. §43.9(a) for the failing to make a proper maintenance record entry, and repeated violations of 14 C.F.R. § 

### 91.407(a)(2) for operating the aircraft without a proper maintenance record entry. X. 

### The June 2011 Maintenance Was Improperly Performed The repair ofN390TH in June 2011 did not comply with the requirements of§ 43.13 of the Federal Aviation Regulations- the methods used were not acceptable to the Administrator, and the results did notrestore the aircraftto its original orproperly altered condition. The bulk ofthe discussion on this matter is repetitive ofPart VI above, and will not be repeated here. As with the February 24, 2011 alteration discussed in Part VI, the June 13, 2011 repair was is not contained in any maintenance manual, instructions for continue airworthiness, airworthiness directive, or other document approved or accept by the Administrator. See 

### Attachment 

### B ,-r 32; Attachment C at 36-37; Attachment T at 193-214; Attachment 

### U;

32

### Attachment Vat 137-60; Attachment GG**~** 

### 32; Attachment HH**~** 

### 32. And, as with the February 20II alteration, Respondent has declined to identify any basis for the assertion that the June 20II repair was performed in manner acceptable to the Administrator, orthat it restored the fuel tank to a condition equal to its original or properly altered condition. Respondent identified only Mr. Norville to testify that this repair was appropriate, but his witness report simply stated that the repair was appropriate, without giving any reasons why

- and then, during deposition, Mr. Norville indicated that he had not reviewed anything about the June 2011 repair and that he had
no opinion as to it. 

### See Attachment 

### DD at I; Attachment EE at 24-25. In addition, there are distinct affirmative reasons that the repair was not done m 

### an appropriate manner. As a basic matter, there is no such thing as an acceptable repair on the welded-aluminum fuel tanks

- the part should never have been in use in the first place, and no repair ofany sort could change that. 

### See Attachment B**~** 

### 33; Attachment GG**~** 

### 33; Attachment HH**~** 

### 33. Additionally, since the welded-aluminum configuration was, as discussed at length above, not a proper alteration, restoring the fuel tank to the improperly altered condition was, by definition, a failure to restore it to the original orproperly altered condition. Even setting aside the bars to the possibility of compliance with §§ 43.13(a), (b), the repair was not properly performed. As Schneider notes in his deposition, he did the repair in a risky manner because oftime constraints. Attachment C at 48-50. This is unacceptable. The fuel tank should have been removed from the aircraft so that a better repair could be performed. 

### See Attachment Cat48-49; Attachment GG**~** 

### 34; Attachment HH**~** 

### 34. Removingthe fuel tank from the aircraft would have permitted the sealant to be applied to the inside ofthe tank, where fuel pressure would help keep the sealant in place in the crack. Attachment C at 43, 48-49; Attachment GG**~** 

### 34; Attachment HH**~** 

### 34. After the patch was completed, an appropriate repair

33

### would have required a better inspection of the tank, including at a mrmmum a full visual inspection with the fuel tank pressurized and the boost pumps activated, not simply a limited visual inspection through a small hatch. Attachment GG**~** 

### 34; Attachment HH**~** 

### 34. There is no genuine issue ofmaterial fact that the June 2011 repair was not performed in accordance with §43.13. Throughout this litigation, Respondent has been unable to identify any fact or explanation in support ofthe notion that the repair was properly performed. This repair
was not contained in any maintenance manual

- indeed, it could not have been, because these fuel tanks were nowhere to be found in any manual or other appropriate document. There was no possible way to repair the fuel tank in a manner acceptable to the Administrator, and thus a violation of§ 43.13(a) is present. Even a "full" restoration ofthe improperly altered fuel tank could not have restored the tank to its original or properly altered condition, and so§ 43.13(b)
was violated. There is no genuine issue ofmaterial fact on this point, and the FAA is entitled to judgment as a matter oflaw. Accordingly, summaryjudgment is appropriate. XI. The June 2011 Maintenance Was A Major Repair, ButNo Form 337 Was Completed For 

### It It is undisputed that Mr. Schneider performed a repair on N390TH and returned it to service on June 13, 2011, and then Respondent operated the aircraft that same day. It 

### is also undisputed that no Form 337 was ever created or submitted for this repair. As discussed in Part IX above, the Federal Aviation Regulations explicitly provide that any repair to a fuel tank is a major repair. 

### See 14 C.F.R. Part 43, App. A(b)(l). As also discussed in Part IX above, Mr. Schneider does not have an Inspection Authorization, and may not return
an aircraft to service after a major repair. 

### See 14 C.F.R. §§ 65.85(a), 65.95(a)(l). As a result, Respondent violated § 14.7 when it returned the aircraft to service after a major repair, violated §43.9(d) when it did not complete a Form 337 for the repair, violated§ 43.5(b) when it returned 34

### the aircraft to service after a major repair without completing the Form 337, and then violated 

### §91.407(a)(l) by operating the aircraft because the aircraft had not been returned to service by a qualified individual. See 

### 14 C.P.R.§§ 43.5(b), 43.7(a), 43.9(d), 91.407(a)(l). There is no dispute of fact on these issues, and the FAA is entitled to judgment as a matteroflaw. Summaryjudgment onthese points is, therefore, appropriate. XII. No Maintenance Record Entry Was Made For The June 2011 Maintenance Before The Aircraft Was Operated It 

### is undisputed that Mr. Schneider performed a repair on N390TH and returned it to service on June 13, 2011. And it is undisputed that Mr. Schneider made a maintenance log entry describing that June 13, 2011 maintenance. However, as Mr. Schneiderhas admitted, he did not make that maintenance log entry until several days later, after

### N390TH had been flown and lost. "No person may approve for return to service any aircraft, airframe, aircraft engine, propeller, or appliance, that has undergone maintenance, preventative maintenance, rebuilding,
or alteration, unless

- (a) the maintenance record entry required by §

### 43.9 or §

### 4 3.11, as applicable, has been made." 14 C.F.R. §43.5(a). "No person may operate an aircraft that has undergone maintenance, preventative maintenance, rebuilding, or alteration, unless
... (2) The maintenance record entry required by§ 43.9 or§ 43.11, as applicable, ofthis chapter has been made." 14 C.P.R. §

### 91.407(a)(2). Mr. Schneider did not make the maintenance record entry for the June 13, 2011, repair until several days after the aircraft had flown and then lost to an onboard fire later on June 13, 2011. Attachment Cat45. As a result, Respondent violated§ 43.5(a) and§ 91.407(a)(2). There are no disputes ofmaterial fact on these issues, and the Administrator is entitled to judgment as a matter oflaw. Accordingly, summaryjudgmentis appropriate onthese points.

35

## •

XIII. N390TH Was Unairworthy At The Time OfTheJune 13,2011, Flight As discussed in Parts VII and VIII above, N390TH was unairworthy at all times after the February 24, 2011, alteration. In addition to reasons relating to the February 24, 2011, alteration, N390TH was unairworthy as a result ofthe June 13, 2011, repair. As discussed in Part VII above, an aircraft is unairworthy if it fails to meet its type certificate or type design, and there are numerous ways in which an aircraft can fail to meet its type certificate ortype design. As discussed in Parts X and XI above, the June 13, 2011 repair was improperly performed, no FAA Form 337 was completed, and the aircraft was returned to service by a mechanic who was not authorized to do so. Either the improper repair or unauthorized return to service are sufficient, standing alone, to render N390TH unairworthy. 

### See Husted, Order 2010-9 (holding that an aircraft is unairworthy when it is repaired with a method that has not been approved or accepted by the Administrator or whenit is returned to service by an unauthorized person); Attachment GG**~** 

### 35; Attachment HH**~** 

### 35. As discussed in Part X above, Respondent formally disputes whether it properly performed the fuel tank repair. However, Respondent has not
- and cannot- present any relevant evidence on this point to make that a genuine dispute ofmaterial fact for purposes ofdefeating summary judgment. There is, likewise, no dispute of fact with regards to Schneider being unauthorized to return the aircraft to service after a major repair. The Administrator is entitled to judgment as a matter oflawon these points, and summaryjudgmentis appropriate.

36 

# I I

## ~ 

# r

### XIV. Respondent'sFirst Affirmative DefenseFails Respondent presents two affirmative defenses. First, that it justifiably relied on Mr. Schneider. Second, that it relied on the advice of two FAA Aviation Safety Inspectors. Both defenses fail. Respondent's first affirmative defense fails for all ofthe reasons discussed in Part I above -Mr. Schneider was not some outside mechanic, he was Respondent's Director ofMaintenance. Further, multiple other persons with the Liberty Foundation, including Ray Fowler and pilot Cullen Underwood, were heavily involved in the decision-making process about making the alterations to N390TH, what to say in the maintenance record entry about that alteration, and the decision to ignore the regulatory requirements on major alterations (and major repairs). A pilot who does not know what is occurring with the maintenance of the aircraft, and could not reasonably have known, may lack the knowledge to be liable for a regulatory violation. Even taking all facts in favor ofthe Respondent, however, that is simply not the case here. Having directly made the decisions about the alterations and repairs as charged in the Complaint

- and then the decisions to operate the aircraft after those repairs and alterations

- Respondent cannot now excuse itselffrom regulatory liability for its unsafe conduct. The FAA is entitled tojudgment as a matter oflaw, and summaryjudgmentis appropriate. XV. Respondent's Second Affirmative DefenseFails Respondent's second affirmative defense fails because it is without legal or factual basis. Contrary to Respondent's asserted defense, an oral opinion from a friend who happens to be an FAA employee does not give an operator 

### carte blanche to perform improper maintenance and alterations, and then operate the subject aircraft, without any consequences for its actions.



### 37

### Respondent represents that it telephonically conferred with two FAA Aviation Safety Inspectors

- David Alderman and David Miller- about howto classify the work Respondent had performed on N390TH in February 2011. According to Respondent, it was told that the work
was a minor repair. According to others involved in these conversations, this did not occur, and the Respondent misrepresented to the FAA Inspectors what it had done with the aircraft. See 

### Attachment**F~_(Affidavit** 

### ofDavid**Alderman)~** 

### 3; Attachment B**~** 

### 12. This will, presumably, be
a factual dispute. It 

### is not, however, a 

### material dispute offact because, even if Respondent's version of events is accurate, these events would not form a defense to the violations charged. Respondent has, during the course ofthis litigation, not identified any legal basis for the notion that the oral representation of an employee of the FAA forms a complete bar on a subsequent finding of violation. Simply put, the individual opinion of an individual employee does not give a Respondent 

### carte blanche to perform improper maintenance and operate unairworthy aircraft. See 

### Attachment R at 16 (Respondent's Executive Director opining that the two FAA inspectors
were "obviously not working in an official FAA capacity" during their interactions with Respondent). This is especially true where, as here, the Administrator has laid out a specific policy whereby a mechanic or aircraft owner can submit a potentially major repair or alteration to the FAA and receive a written determination that it is or is not a "major." See 

### Advisory Circular 43- 210 ("Standardized Procedures For Requesting Field Approval ofData, Major Alterations, and Repairs") at 

### § 302(b) ("Ifyour alteration or repair does not require a field approval or STC, the [Aviation Safety Inspector] will explain that your approval request is not necessary. He or she

38

### will also provide you with a letter stating that your alteration or repair does not require FAA approval based onthe informationprovided in yourrequest."). Even taking all the facts in favor ofthe Respondent, Respondent's affirmative defense fails because even iftwo FAA inspectors orally opined to Respondent that the February 20II major alteration was really a minor repair, that oral opinion does not shield the Respondent from liability for its violations. The FAA is entitled to judgment as a matter of law, and summary judgmentis appropriate. CONCLUSION In February 20I1, Respondent, through its Director of Maintenance, performed an unauthorized major alteration on N390TH, removing the existing bladder fuel tanks and replacing them by fabricating new fuel tanks out of the existing support shells via extensive welding. After performing this major alteration, the aircraft was returned to service by an unauthorized mechanic, no logbook entry was made describing the work performed, and no FAA Form 337 was completed. Respondent instead chose to treat the major alteration as a minor repair, and proceeded to fly N390TH. Within a few months, in June 20II, the improper alteration failed, and Respondent proceeded to perform an improper major repair on the leaking fuel tank- again using a mechanic who was not authorized and again not completing a Form 337. On its next flight, the aircraft caught fire and was lost. There is no dispute as to the underlying facts ofthis case - no dispute as to the work performed, no dispute that no Form 337 was ever completed, no dispute that no authorization
was obtained for a major alteration or repair, no dispute that the February 201I alteration failed and resulted in the June 20II fuel leak. Instead, Respondent primarily disputes the legal consequences ofthese events- was the February 20II alteration an alteration or a repair, was it a

39

### minoralteration or a major alteration, do the failure to use an appropriate mechanic and complete the appropriate paperwork render the aircraft unairworthy, is Respondent liable for operating N390TH in such a deficient state? Ail of these are legal questions that can be resolved on summary judgment based on the undisputed facts. Respondent wi11, presumably, generate disputes offact, but none that are material- none that preclude finding ofviolation as laid out in the Complaint.

WHEREFORE, Complainantrespectfu11y

### request~ that the Judge grant Summary Judgment and affirm the Amended Complaint in its entirety.

### {.,(~~ Respectfully submitted this
__day ofAugust, 2013.

CHRISTOPHER 

### R. STEVENSON Attorney Office ofthe Regional Counsel

40

### CERTIFICATE OF SERVICE Ihereby certify that the foregoing Motion for Summary Judgment was sent: Original and one copy via Federal Express to: Federal Aviation Administration 800 Independence Avenue, S.W. Washington, D.C. 20591 Attention: Hearing Docket Clerk, AGC-430 Wilbur Wright Building- Suite 2Wl000 One copy via Federal Expres to: The Honorable I.E. 

### Sullivan Administrative LawJudge Office ofHearings, M-20 U.S. Department ofTransportation 1200NewJerseyAvenue, SE(Ell-310) Washington, DC 20590 facsimile: (202) 366-7536 Stuart A. Goldstein, P.A. 9350 South Dixie Highway, I oth 

### Floor Miami, FL 33156 Facsimile: (305) 670-7065

# ~~~ Legal Assistant Office ofthe Regional Counsel 

### AUG 1 4 2013 Dated

41........r'!!·c...-.·,'-UNllEDOfAMERlCA..•>DEPARTMENTOFTRANSPORTATION-FEDERALAVIATIONADMINISTRATIONSPECIALAIRWORTHINESSCERTIFICATEACATEGORY/DESIGNATIONLIMITED.PURPOSEDNA8MANU-NAME'BOEING(VEGA)FACTURERADDRESSDNAcFROMDNAFLIGHTTODNAI0N-390THSERIALNO.44-85734IBOEING(VEGA)B-17GIBUILDERMODELDATEOFISSUANCE03MAX2005EXPIRYDNAOPERATINGLlMITAJ)(SNSAPARTOFTHISCERTlFlCATEIESIGNATUREOFFAA"j_,/;'15::7::.DESIGNATIONOROFFICENO..K.S0-29·-·I.alteration,reproducti_onormisuseofthiscertificatemaybepunishablebyafinenotexceeding$1.000or1mpnsonmentnotexceedtng3years.orboth.THlSCERTIFICATEMUSTBEDISPLAYEDINTHEAIRCRAFTJNACCORDANCEWITHAPPLICABLEFEDERALAVIATIONREGULATIONS.·'I'I:AA.::nRM8130-7(10/82)SEEREVERSESIDECMDB.S,IG0-7U03tt.iG)01.;,CDz) -i:.!""1m·70RUSEONL_Yl•Zj.-t.i

### U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS FEDERAL AVIATION ADMINJSTRATION

FEDERAL AVIATlON ADMINISTRATION,. Complainant,

vs. Docket No. FAA-2012-0477 FAA Case No. 2011GL030070 LIBERTY FOUNDATION, Respondent. Judge Sullivan


### AFFIDAVIT OF TIMOTHY BOURGOINE STATE OF NEW MEXICO COUNTY OF HAVING COME before the undersigned Notary duly authorized to administer oaths, Timothy Bourgoine, did state under oath after being properly sworn, that the following statement is true and accurate: 1. 

### i am overthe age of 18 and I understand the obligations ofan oath. 2. I am currently employed as an aviation mechanic at Bode Aviation in Albuquerque, New Mexico. Priorto working at Bode Aviation Iserved as a police officerfor 2 5 years. 3. Ihold a Mechanic Certificate with Airframe and Powerplant Ratings, and have done so since 2006. Ihave held an InspectionAuthorization since 2009. I also hold a Commercial Pilot Certificate with an Instrument Rating. I have held apilot certificate since 1982. 4. The aircraft involved in this case is a BoeingB-170, serial number44-85734, registered as civil aircraftN390TH. 

### 5. I first became involved with N390TH in the spring of2007, servingas a mechanic. Shm1ly thereafter, the DirectorofMaintenance at the time left The Liberty Foundation (TLF) due to an internal dispute, and TLF began using additional mechanics to perform inspections on N390TH. TLF was lacking req1,1ired maintenance manuals for the aircraft, and I acquired a set of manuals for the aircraft, and Iprovided a copy ofthem for TLF. 

# I GOVERNMENT 

# ; EXBBIT 

# i· _·....-·• ,. __.....,.

### 6. In the summer of2007,TLF designated me as its DirectorofMaintenance. As the DirectorofMaintenance, I oversaw the maintenance for N390TH, including ensuring that all inspections were timely performed and that all Airworthiness Directives were compliedwith. As DirectorofMaintenance I worked with ScottMaher, the tour coordinator, to identify where the aircraft would be to receive needed maintenance, and to identify where additional mechanics would need to be brought in to assist. As Director ofMaintenance, I had authority within TLF to manage the maintenance ofthe aircraft, except for work that would require majorexpenses, which had to be authorized by Scott Maher or Ray Fowler, TLF's ChiefPilot. 7. In total, Iperformed45 phaseinspections on N390TH, where each cycle of4 phase inspections constituted a full inspection ofthe entire aircraft, including the wing fuel tanks. I also performed additional squawk maintenance and third crew member services as necessary for more than three years. When the aircraft wintered inAlbuquerque in 2007-08 and the first halfofthe winter of2009-10, I perfonned all maintenance on the aircraft. The aircraft was in North Carolina in the winter of2008-09, when I spent one week a month with the aircraft. In total, I spent more than 2900 hours working on N390TH. 8. In 2010, it was determinedthatthe existing bladderfuel tanks onN390TH should be replaced (I 

### am unsure ofwhen the tanks were made, but it is my beliefthat the bladderfuel tanks in N390TH were OEM fuel tanks from the 1940s or 1950s). Replacement with new bladder fuel tanks had been discussed, and 

### itwas detennined thatthecost ofaround $50,000for new bladder tanks. Replacing the bladdertanks with custom-fabricated solid metal fuel tanks with dedicated engineering specifications was also discussed between me, Ray Fowler, and Don Brooks (the founder ofTLF). Ray statedthat he wanted to winterthe aircraft in Georgia in orderto reduce costs, and he and Scott Maher ultimately decided to winterthe aircraft in Georgia. Because I felt that I would not be able to properly supervise the maintenance being perfom1ed in Georgia, I resigned as DirectorofMaintenance. 9. Ihad minimal contact about N390TH during the winterof20I0-11, but was contacted by 

### Scott Maher and Ray Fowlerin early March 2011. They indicatedthat the aircraft was in Houston, and asked me to perform a phase inspection onone ofthe wings. Before I agreed to perform the inspection, I contacted Rod Schneider, who had succeeded me as Director of Maintenance, to ask about the maintenanceperformed on N390TH that winter. Schneider informed me that, among otherthings, they had ultimately decided to replace the bladder fuel tanks by modifying the existingaluminum bladderholders. I asked Schneiderifhecould provide me with acopy ofthe engineering documents and FAA Form 337 for the alteration. Schneider's response was vague, buthe indicated that Cullen Underwood and one ofhis employees (Paul White) were working on the paperwork. I0. Afterthis conversation with Rod Schneider, Icalled FAA Aviation Safety Inspector David Miller ofthe Nashville FSDO, who Iknewhad been involved with TLF and N390TH. Miller said that he had not seen any paperwork about the alteration, but that he would check into it. 11. Sho1tly after that conversation, Ireceived a call from Ray Fowler, who indicated that he knew Ihad been asking about the tanks, and that he wanted to bring me up to date. Fowler

### indicated that TLF had modified the bladderholders to serve as fuel tanks by welding them up. Fowler indicated that TLF had hired a DER to engineernew tanks, but that this processhad been abandoned as too expensive. Fowleropined that what TLF had done was only a minoralteration because some B-17shad been manufactured with solid aluminum tanks. This mademe very uncomfortable, because the extensive welding meant that this was not at all like what anyB-17 had been manufactured with

- even ifthe bladderholderhad actuallybeen a fuel tank at some point in the past, 

### it would not be returned to its original state by welding on extensive patches. I was also disturbed because the bladderholders seemed too thin to serve as fuel tanks and also because TLF had not installed baffles in such large metallic fuel tanks. Fowlertold me that he hadjustconsulted with David Miller, and that Millerhad said they were OK to resolve it as a minor alteration. 12. I then spoke with Miller again and I explained to Miller what had been done to the tanks. Miller indicated thatthis had not been his understanding after the conversation with Fowler, and agreed that what had been done with the tanks was a major alteration. 13. The above circumstances leftme very uncomfortable. In particular, it was clearthat TLF had failed to follow properapproval policies, especially because the aircraft had alreadybeen operated at the time these conversations were taking place. Ideclined to perform any further maintenance work forTLF. 14. I spoke with Scott Maherthe next day and he informed me that Rocky Howard, a DER who had previously worked for TLF, would be completing an engineering authorization for the alteration. Ipresumed thatTLF would later complete a 337. However, I later learned that TLF had not obtained an engineering approval orcompleted a 337. 15. When N390TH was restored in**2004~** 

### it was equipped with six thick, self-sealing fuel tanks, three in each wing. Each bladder fuel tank was attached to the interior ofthe wing by a numberofstraps. Each bladder fuel tank was also supported by an aluminum shell around the fuel tank. All attachments between the fuel tank and the rest ofthe fuel system were fixed directly into the bladderfuel tank. In orderto accommodate the straps and various attachments and fittings, numerous holes were present in the aluminum shell. Additionally, one end ofthe aluminum shell wasremovable, so it could betaken on oroffthe bladder fuel tank. 16. Ihave been informed that, in general terms, the work onthe fuel system ofN390TH that culminated in the return to service date February 24, 20II, consisted ofremoving the bladder fuel tanks entirely, fabricating new attachments and plates, welding those attachments and plates onto the aluminum shell, welding shut the removable end ofthe shell, and hooking the shell into the existing fuel system as a fuel tank. 17. No B-17 was manufactured with a solid metallic tank consisting ofan aluminwn shell with holes that had been plugged by welding avariety offabricated attachments and plates to the shell, ora manufactured with a removable end that was then welded closed. 18. This work was an alteration, not a repair, because it changed the design ofthe aircraft and its components, and was not simply a restoration ofthe aircraft to an undamaged state.

### 19. The alteration was a majoralteration. As stated in section 

### 1.1 ofthe Federal Aviation Regulations (Definitions): Major alteration means an alteration not listed in the aircraft, aircraft engine, or propellerspecifications- (I)That might appreciably affect weight,balance, structural strength, performance, powerplant operation, flight characteristics, orotherqualities affecting airworthiness; or (2) That is not done according to accepted practices orcannot be done by elementary operations. 20. There are several reasons why the alteration was a major alteration. Within four months ofthe alteration, the welding cracked in one ofthe new tanks, resulting in a fuel leak. This was an appreciable effect on a quality affectingthe airworthiness ofthe aircraft. Thus, the alteration was a major alteration. 21. Additionally, even setting aside the fuel leak, the removal ofthe bladderfuel tank could havehad an appreciable effect onthe airworthiness ofthe aircraft and its fuel system. The alteration increased the fuel capacity ofthe aircraft, affecting weight and balance and possible stresses placed on the wing structure. Thenewaluminum fuel tanks were susceptible to vibrational stresses in ways that a bladder fuel tank was not. An aluminum fuel tank would not respond the same wayto the stresses ofthe in-flight motion ofthousands ofpounds ofaviation fuel as a semi-rigid bladdertank would. Thenewly fabricated fixtures and attachments may or may not have been ofequal quality with the componentsthey werereplacing. The fabricated fixtures and attachments, even assuming thatthey were ofequal quality to the parts they were replacing, had changed from being attached to the semi-rigid bladdertank tobeing attached to the rigid aluminum tank, which could impact howthey responded to stress during flight. All of these problems are exacerbated becausethe aluminum tanks were not simply solid, formed aluminum tanks, but had been extensively welded, introducing numerouspotential weaknesses into the system- as can be seen bythe cracking that developed in one ofthe fuel tanks in less than four months, the weld seams are a source ofstructural weakness and can make the tank more susceptible to issues with vibration and stress. The weaknesses that canbe introduced by welding are highlighted bythe 

### B-170 Structural Repair Handbook'sprohibition on welding aluminum structural members- while the fuel tank is not a structural component, and welding a fuel tank is permissible underappropriate circumstances, the samepotential weaknesses in the resulting component are present and must be accounted for. All ofthese potential issues were ways in which the alteration mighthave affected qualities affecting the airworthiness ofthe aircraft, and required a properengineering orother authorization. 22. Further, the fabrication ofnew fuel tanks out ofthe ahm1inum shells was a major alteration because fabricating components and welding ofthis nature are not an elementary operation.

### 23. Iam aware ofthe provision in Appendix A ofPart 43 ofthe Federal Aviation Regulations that lists changes in the basic design ofa fuel system as an example ofa major alteration. The replacement ofthe bladderfuel tanks with fabricated aluminwn fuel tanks was a change in the basic design ofthe fuel system. While someone could mechanically list dozens ofcomponents that were not replaced in replacing the fuel tanks, this does not mean that the replacement ofthe fuel tanks was not a change in the basic design ofthe fuel system. Fuel tanks, and theirability to perform properly, are absolutely vital to the safe functioning ofa fuel system and aircraft- not the least because a fuel leak canhave disastrous consequences. The change in the fuel capacity ofthe tanks also makes it a change in the basic design, and could affect the fuel pickups at different attitudes offlight. 24. Each ofthereasons described above, standing alone, would render the alteration a major alteration. 25. The work performed that culminated in the February 2011 return to service was an alteration, not arepair. However, ifit was a repair, it would be a majorrepair. As stated in section 1.1 oftheFederal Aviation Regulations (Definitions): Major repair means a repair: (I)

### That, ifimproperly done, might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, orother qualities affecting airworthiness; or (2) That is not done according to accepted practices orcannot be done by elementary operations. 26. The distinction between a major repair and minor repairlargely tracks the distinction between a majorand minoralteration. As such, all but one ofthe reasons discussed above as to why the alteration was a majoralteration are also reasons why this would bea major repair, ifit had been a repair. 27. The one exception is regarding the example in Appendix A about howa change in the basic design ofthe fuel system is a major alteration. Thisexample is not applicableto repairs. However, Appendix A also provides that every repair ofa fuel tank is amajorrepair. 28. Each ofthe reasons identified above, standing alone, would render the work a major repair, ifit was a repair. 29. The alteration ofN390TH is not described in any maintenance manual or instructions for continued airworthiness for the 

### B-17G. 30. N390TH did not meet its type certificate ordesign and was unairworthy afterthe February 2011 alteration because TLF had failed to execute an FAA Form 337 or obtain engineering authorization for the alteration.

### 31. Based on the information presented to me, as described above, 

### it is my opinion that the aircraft was unairworthy afterthe February 201 I alteration because 

### it was not in a condition for safe operation. As discussed above, welding can introduce significant weaknesses into a system, and the welding here, combined with the relatively thin construction ofthe shells, was too much for the shellsto serve as appropriate fuel tanks. 32. I am familiar with the repairs done on N390TH's fuel tanks from speaking with Chuck Geese, amechanic who had seen the repair. Themaintenance performed was not contained in the aircraft'smaintenance manuals. The maintenance performed was not contained in any instructions for continued airworthiness for the aircraft. 33. The June 201 1maintenance on the fabricated fuel tanks was not appropriate because the fuel tank was an unapproved part that should neverhave been installed onthe aircraft. 34. The June 201 1repair was a majorrepair. In addition to the reasons stated above concerning the February 201 1alteration, N390TH did not meet its type certificate ortype design and was unairworthy afterthe June 2011 repair because TLF had failed to execute an FAA Form 337 r the repair.

Sworn and subscribed before me this 

# q-hAday ofAugust, 2013.



### My Commission Expires:

### U.S. DEPARTMENT OF TRANSPORTATION Office of Hearings

Washington, D.C.
In the Matter of: Docket No. FAA-2012-0477 LIBERTY FOUNDATION, INC., Case No. GL-03-0070 Respondent.

DEPOSITION OF RODNEY SCHNEIDER Monday, April 30, 2013 8:53 a.m. 1701 Columbia Avenue College Park, Georgia Renda K. Cornick, RPR, CCR-B-909

REGENCY-BRENTANO, INC. Certified Court Reporters 13 Corporate Square

- Suite 140 Atlanta, Georgia 30329 404-321-3333



# I GOVERNMENT ¥! 

### EXHIBIT 

### I 

# L 

# I

.Rodney Schneider In Re: Liberty Foundation April30, 2013


### 1 

### 2 3 4 

### 5 6 7 8 9 

### 10 them?

### A. 

### Q. Oh, yes. How did you come to get involved with

A. I discovered the B-17 parked at a local airport and have always been interested 

### in war birds. I contacted them and asked them if they needed any volunteer help. They set me up with the fellow that
was director of maintenance at that time and started helping him out there. 

### Q. And when you say help, what sort of help 11 did you provide? 12 

### 13 A

.. 

### Mechanical work on the airplane, whatever he needed done. He would 

### give me a list of things to 14 do for that day or whatever. 

### 15 16 17 18 19 20 21 

### 22 23 Q. Was there ever a time when you became director of maintenance or had any sort of role of authority 

### in the company? A. Yes. They asked me if I would take that position in fall of 2010, I believe. 

### Q. When you say that position, you mean director of maintenance? A. Yes, 

### sir, director of maintenance. 

### Q. When you say fall, what

-- can you be 24 more 

### 25 A. I think it may have been about October,

REGENCY-BRENTANO, INC. Page 7Rodney Schneider In Re: Liberty Foundation April30, 2013
1 

### 2 3 

### maybe. 

### Q. A. Okay. September, October, somewhere in that 4 timeframe. 5 

### Q. Now, as you are aware, there are issues 6 involved in this case relating to the fuel tanks on 7 the aircraft. Could you tell me how you first became 

### B aware that there was a problem with the fuel tanks on 9 the Liberty Belle that you needed to address. 

### 10 11 

### 12 13 14 15 16 17 

### 18 19 20 21 

### 22 23 

### 24 A. Well, ever since I have been involved with the airplane I know we had some issues being able to sump the tanks properly in some cases, general

-- just general concern about the condition of the liners in the tanks, their age and whatnot. We didn't really have any big issues except we knew we were getting
some debris from them and it was hard to sump some of them because the liners were swollen or whatever. 

### Q. Tell me about the fuel tanks on the Liberty Belle as they were when you started working at The Liberty Foundation. How does that system set up? 

### A. Q. A. As far as the construction of them? Let's start with that. The airplane had metal, metal tanks with rubber bladder liners in them. There are a total of 25 six on the airplane, three on the left wing, three on

REGENCY-BRENTANO, INC. PageSRodney Schneider In Re: Liberty Foundation April30, 2013


### 1 the right wing; and then the associated plumbing. 

### 2 3 4 5 6 7 8 9 

### 10 11 12 

### 13 14 15 16 

### 17 

### Q. Now, when you say metal tanks, describe what you are referring to when you say metal tanks. A. Well, it was a metal container made out of aluminum that had a bladder liner in it. They are separate from the airplane. unit. They are removable as a
(Government Exhibits 1 through 6 were marked for identification.) MR. STEVENSON: I have a photograph that I previously marked as Deposition Exhibit 1. think you are familiar with these, Stuart. I



### MR. GOLDSTEIN: Why don't we just mark the exhibit Deposition 1, et cetera, through all these depositions. Is that okay with you? MR. STEVENSON: Yes. 

### Q. (By Mr. Stevenson) Do you know what is in 18 this photograph? 19 A. Looks like one of the tank shells. 

### 26 Q. And in this photograph, the aluminum shell 21 is resting on a pallet. Is this tank upside down or 

### 22 23 24 25 not? If this is installed on the aircraft, which is the top and which is the bottom? It looks right side up as shown. 

### A. Q. What are the holes that we can see in the

REGENCY-BRENTANO, INC. 

### .... · . .,..

Page9Rodney Schneider In Re: Liberty Foundation April30, 2013


### 1 2 

### shell in this photograph? A. Well, several different things. One of 3 them is where the vent fitting came through the tank. 4 Another one is the fuel fill and another one is the 5 fuel level sending and then the slots are places where 6 the bladder liner was supported to keep it from 7 falling in when the tank was empty. 8 9 

### Q. You mentioned several kinds of

-- I see several round holes and I see the slots. Would it be 10 fair to say these slots are the bladder liner strap 11 supporters? 12 

### 13 A. 

### Q. Yes. Could you tell me individually what each 14 of these round holes are? 

### 15 A. The only thing I can tell you for sure is 16 this one is the vent. 17 

### 18 Q. A. Okay. I couldn't tell you which one of these for 19 sure on top was fuel level and which was fuel fill. 20 

### Q. Okay. 

# Now, a decision was made at some 21 point to get rid of the bladders entirely; is that 22 

### correct? 

### 23 24 25 Yes. 

### Q. Could you tell me how that first came to be discussed in The Liberty Foundation?

REGENCY-BRENTANO, INC. Page 10Rodney Schneider In Re: LibertyFoundation April 30, 20I3
1 

### 2 3 4 5 6 7 8 9 

### 10 11 

### 12 13 A. discussed. I am not sure how it first came to be

MR. GOLDSTEIN: That's the answer. Don't guess. Q. 

### (By Mr. Stevenson) How was it first brought to your attention? A. Discussion I had with Cullen Underwood about possibilities of what we could do to make the tanks better. 

### Q. A. Who is Cullen Underwood? Cullen is one of the volunteer pilots for the organization. He is also a personal friend of mine. He also runs a plastic injection molding 14 company in Woodstock and is

-- he is just a good 15 friend of mine. 

### 16 17 

### 18 19 20 

### 21 22 

### 23 Q. Is Mr. Underwood a mechanic in addition to being a pilot? A. He does not have an A&P. 

### Q. And why was just a -- why was one of the pilots of the aircraft the person bringing this to your attention? A. I couldn't really tell you for sure why. I couldn't tell you for-sure. 24 

### Q. Was it normal for Mr. Underwood to suggest 25 maintenance to you?

REGENCY-BRENTANO, INC. Page IIRodney Schneider In Re: Liberty Foundation April30, 2013


### 1 2 

### away. 

### Q. Was that after the actual work had been 3 done and you just had paperwork left? 4 A. After a portion of the work had been done. 5 The tanks had been welded up. We were in the process 6 of installing them in the airplane. 7 

### Q. I am going to go back to the photograph we 8 have in front of us that has been marked as Exhibit 1. 9 You indicated that you didn't know for sure which of 10 these circular holes were what sort of connections. 11 Can you tell me how the bladder fuel tank was 12 connected to the various fuel lines in its original 13 configuration? 14 15 16 

### 17 18 19 20 

### 21 22 

### 23 

### 24 25 

### MR. GOLDSTEIN: I am going to object to the characterization you made in your question. I don't think it is entirely what he said. Go ahead and answer the question. THE WITNESS: Well, the vent line had a nipple coming out of the bladder with the metal fitting coming out of it that went to the flex hose. The fuel filler as I recall screwed into the top of the bladder. There was a metal ring that was a part of the bladder, the same with the fuel level sender. And the same with the boost pump on the bottom. Fuel feed line was also the

REGENCY-BRENT ANO, INC. Page 15Rodney Schneider In Re: Liberty Foundation Apri130, 2013


### 1 2 3 4 5 6 

### same way. 

### Q. (By Mr. Stevenson) Now, aluminum shell and you did not alter able to serve as a fuel tank? Define alter. if you took this it, would it be



### A. Q. Alter as it is used in the Federal 7 Aviation Regulations. If you do not
-- I mean, 8 change, modify. There are holes in this. 9 

### 10 A. 

### Q. Correct. If you put it in an airplane and you 11 filled it up with fuel, it could not function at all 12 as a fuel tank. 

### 13 14 

### 15 16 tank?

### A. Q.

A. It would be very leaky, yes. Were there baffles inside the bladder
No, sir. 17 

### Q. Did you personally observe that? 18 A. Yes. I did when we took the bladder 19 liners out. 20 Q. You had mentioned that you interacted with 21 two FAA inspectors, Dave Miller and Dave Alderman, 

### 22 23 24 25 correct?

them?

### A. 

### Q. Yes, sir. What sort of discussions did you have with

REGENCY-BRENTANO, INC. Page 16Rodney Schneider In Re: Liberty Foundation April30, 2013
1 

### 2 3 4 5 6 7 8 9 

### A. I had a conference call with the two of them plus Ray Fowler who is our chief pilot. We just talked about what we had done, what did we need to do to get a signoff done properly and so I told him what
we had done to the airplane. They asked me a few questions and then told me, that's just a minor change. Any A&P can sign it off. Here is how we need to word the signoff. 

### Q. How did you describe what you had done to 10 them? 11 

### A. I told them that we had removed the tank 12 assemblies from the airplane. We had removed the 13 bladder liners from the shells. We then welded up the 14 shells so they would be fueltight and also added the 15 fittings needed to mount the**v~rious** 

### components back 16 on, then we were going to reinstall them back in the 17 airplane. 18 19 20 

### Q. Where did you get the fittings to weld onto the tank? A. Cullen Underwood came up with those. Some 21 of them were purchased from various supply houses. I 22 couldn't tell you which ones for sure. A couple of 23 them he made. He had a machine shop. 24 Q. Now, you mentioned Ray Fowler. 

### Am I 25 correct in understanding that's the chief pilot for

REGENCY-BRENT ANO, INC. Page 17Rodney Schneider In Re: Liberty Foundation April 30, 2013
1 2 3 4 5 6 7 8 9 

### 10 11 

### 12 13 14 15 16 17 

### 18 19 20 

### 21 22 

### The Liberty Foundation? A. Yes, sir. 

### Q. At what point did he become involved**~n** 

### the process of working on these tanks? 

### A. I don't know for sure. He and Cullen had talked about it previous. 

### Q. Do you know if it was before or after you started work on them? A. I don't know for sure. I couldn't tell you. 

### Q. Had you spoken to Mr. Fowler about this about the work on the tanks before the conference call?A. 

### Q. No, I don't think so. Who authorized you to 

### go ahead and perform this work on the fuel tanks? A. I don't recall there was ever a formal authorization. 

### Q. A. Q. 

### A. Whose decision was it to do this work? I believe it was probably Cullen and Ray. So it was not your decision? I am not the one that said, okay, let's do 23 this. 24 

### Q. Prior to work starting on the tanks, had 25 you spoken to anyone but Mr. Underwood about it?

REGENCY-BRENTANO, INC. Page 18Rodney Schneider In Re: Liberty Foundation April 30, 2013
1 2 3 

### getting the paperwork done properly. I was looking to them for guidance because they had more experience. 

### Q. Was it your idea to have that conference 4 call, then? 5 A. Yes. 6 

### Q. Why were those two particular FAA 7 inspectors called? 8 A. They volunteer with Liberty Foundation. 9 

### Q. Were you already the director of 10 maintenance at The Liberty Foundation when 11 Mr. Underwood first suggested to you removing the 12 bladder tanks?· 

### 13 14 15 16 17 

### 18 19 20 21 22 

### 23 24 25 

### A. Q. I don't believe so. You indicated that you became the director of maintenance in the fall of 2010 and the aircraft
was returned to service with tanks reinstalled in February of 2011. So would it be fair to say that you became the director of maintenance

-- let me say that again. Do you recall if you became the director of maintenance before the existing tanks were removed from the aircraft? A. Yes. 

### Q. You were the director of maintenance at that point in time? 

### A. Yes, sir.

REGENCY-BRENT ANO, INC. Page 21 J .C\1-·Rodney Schneider In Re: Liberty Foundation April30, 2013


### 1 aluminum tank for the aircraft? 

### 2 3 

### A. Q. Oh, yes. Do you know why it was decided not to go 4 that route? 5 6 

### was A. My understanding is the DER that Cullen working with made the suggestion to go ahead, plan 7 on going ahead and use the existing shells that you 8 have because you know they fit and it would save a lot 9 of fabrication time. 10 

### Q. Do you know how much the work that was 11 done on the tanks, you know, the shell and the bladder 12 13 14 

### 15 16 17 18 tank and everything, how much did that cost? A. I don' t know. Q. 

### What' work did you personally do for the removal and eventual installation of the tanks? A. Holy crow. There was a group of us that removed the tanks from the airplane. took the bladders out of the tanks. And Cullen and I And then I was 19 there when they were doing some of the welding, not 20 all of it. Mainly to show the proper fittings went in 21 

### 22 23 24 25 the proper locations. 

### Q. Did you personally do any of the welding? A. No, sir. 

### Q. Do you have any personal experience welding?

REGENCY-BRENT ANO, INC. Page23Rodney Schneider In Re: Liberty Foundation April30, 2013
1 

### 2 3 

### A. 

### Q. A. Yes, sir. What is your personal experience welding? Way back in A&P school. I had a welding 4 course at Delta Air Lines some years back and I have 5 

### done some personal. 6 

### Q. When you say some personal welding, what 7 8 9 

### do you mean by that? A. I have an oxyacetylene rig. I have a home-built airplane. I had to do some welding with 10 it. 11 

### Q. You said that you were trained at Delta 12 

### 13 14 15 about welding. Do you remember when that was? A. Not for sure. 

### Q. A. Do you remember what decade it was in? It was probably around 1989, 1990. 16 

### Q. Did you end up doing any welding on Delta 17 aircraft or components? 18 19 A. No, sir. shortly after that. They changed their policy

20 

### Q. You had indicated you didn't personally do 21 the welding on the shell but you had observed some of 22 it, correct? 23 A. Yes, sir. 

### 24 

### Q. What work did you personally do on the new 25 tank after the welding was completed?

REGENCY-BRENT ANO, INC. Page24Rodney Schneider In Re: Liberty Foundation April 30,2013


### 1 standpoint? 2 Q. 

### From any standpoint. 3 A. We leak checked them after we put them in. 4 Q. 

### That would be the sort of thing. Okay. 5 6 7 8 9 

### Did you do anything else? A. 

### No. 

### Q. Was any sort of vibration testing performed on the new tank? A. 

### No. 10 

### Q. After all of the welding was completed

-- 11 let me back that up. In this photograph, I can see 12 one of the short ends of the aluminum shell. 

### 13 14 A. Q. Uh-huh. And I know that can be removed. What is 

### 15 involved in removing that? 

### 16 17 18 

### A. 

### Q. A. 

### That end is 

### welded from Boeing. Okay. The other end is 

### removable. There is 

### a 19 series of bolts around the end you take out and it 20 slides out from inside the tank. 21 Q. What I am going to do so that we have all 22 these pictures and you explaining these things can be 23 made easier, I have five other photographs that have 24 been marked as Exhibits 2 through 6. 25 MR. GOLDSTEIN: These are photos we gave

REGENCY-BRENTANO, INC. Page26Rodney Schneider In Re: Liberty Foundation April 30, 2013
1 

### 2 3 4 5 

### you. MR. STEVENSON: Yes. These are photos you have seen before. had them. I just wanted to make sure we

Q. (By Mr. 

### Stevenson) In-the photograph 6 marked as Deposition Exhibit 4, it looks to me like 7 8 9 

### there is an open end on the tank.
were referring to earlier? 

### A. Yes, yes. Is that what you



### 10 Q. 

### In that photograph I can also see two 11 

### circular holes in the bottom of the tank. I think you 

### 12 said this before, but what were those? What are the 13 

### holes in the bottom for? 

### 14 A. One of them would have been the boost 

### 15 pump. The second hole, there was -- I think the 16 

### second hole was not used. 

### 17 Q. I can see on these photographs there is 

### 18 something that looks like a date stamp that says 

### 2005. 19 

### Is that the actual time that these photographs were 

### 20 taken? 

### 21 22 23 24 

### 25 A. Apparently not. 

### Q. Do you recognize where this shell is from these photographs? 

### A. This looks like it is at Cobb Industrial Fabricators. They are the people that did the welding

REGENCY-BRENT ANO, INC. Page 271 2 

### 3 4 5 6 7 8 9 

### 10 Rodney Schneider In Re: Liberty Foundation April30, 2013
Q. 

### This maintenance entry references Advisory Circular 4313, Section 8 to 32. Did you review that advisory circular while this work was being done? A. Yes. I read it. 

### Q. Did you also look at the B-17 erection and maintenance manual? 

### A. 

### Q. manual? 

### A. Yes. What is the B-17 maintenance and erection

It is one of the maintenance manuals for 11 

### the airplane. 

### 12 

### Q. When you say it is one of the maintenance 13 manuals for the airplane, what are the other 14 

### 15 16 maintenance manuals for the airplane? A. Field service manual, structural repair manual. Those are the main ones for the airframe. 17 

### Q. Did any of those manuals describe the work 

### 18 that you did or that was done with the welding on 19 

### these tanks? 20 

### 21 22 23 

### 24 A. Not with the welding, no. Q. Are you aware of any maintenance manual of any sort that describes how to do this? 

### A. Q. No. Are you aware of any instructions for 25 continued airworthiness that tell you how to do this

REGENCY-BRENTANO, INC. Page36Rodney Schneider In Re: Liberty Foundation Apri130, 2013


### 1 A. Cullen would know. 2 

### Q. Now, I would like to ask you about June of 3 

### 2011.- Am I correct in saying that there was an 4 5 

### 6 7 8 9 

### 10 11 

### 12 13 14 

### 15 16 

### 17 18 19 

### 20 21 22. 

### 23 

### 24 25 incident in June of 

### 2011 when one of these fuel tanks started leaking? A. Yes.**Q~** 

### Can you tell me about that. A. Just from what I know, the airplane was in Aurora for a tour weekend and I got a phone call from Cullen saying he had gotten a phone call we had a fuel leak on one of the tanks and we probably needed to go up and look at it to see what was going on.

leak?

### Q. A. 

### Q. A. 

### Q. Did you, in fact, go and look at it? Yes, we did. Is "we" you and Mr. Underwood? Yes. He and I flew up in his T-6. And what did you observe about the fuel

A. When we got there, they had the lower stress panel off the airplane so we could look at the tank and we put a little bit of fuel in the tank to
see where it was coming out of, discovered a crack in the weld roughly 5 inches long, maybe 6. 

### Q. A. In which of the fuel tanks was this? No. 1, main.

REGENCY-BRENTANO, INC. Page 40Rodney Schneider In Re: Liberty Foundation April30,2013
1 

### 2 3 4 5 6 7 8 9 

### 10 11 

### 12 

### 13 14 

### Q. Now, which tank is the No. 1 tank, just to be clear? A. There are three tanks in the**w~ng,** 

### in each wing. No. 1 main tank is between No. 1 and 2 in the cells, just after the front spar. Behind it is No. feed tank. And inboard of No. 2 is No. 2 main tank. 2


### Q. And is 1 and 2 the left wing or the right wing?

### A. 

### Q. the weld. 1 and 2 of the left wing. Now, you said that there was a crack in What exactly do you mean by crack in the weld? I am sorry. When you say in the weld, is that

-- okay, let's go back and look at one of these pictures. When I look at
-- which

-- was it one of 15 the slots? 16 17 

### 18 19 A. end cap. It was the end cap, the bottom edge of the


### Q. Okay. that the end that So when you say the end cap, is
was welded shut that comes from the 20 manufacturer welded shut by Boeing or is that the new 21 weld? 

### 22 A. This would have been the new weld. And 23 when you say -- when I look at one of these weldings, 24 I would see a -- there is going to be two pieces of 25 metal and then there is going to be the welding

REGENCY-BRENTANO, INC. Page41Rodney Schneider In Re: Liberty Foundation April 30, 2013


### 1 material that kind of creates a raised line usually. 2 The end caps are a little bit different from these 3 patches. On the end caps you have a flange formed by 

### 4 the two pieces of metal. They were edge welded around 

### 5 the end edge of the weld. The bolt holes were also 6 

### welded. 7 8 9 

### 10 

### 11 12 13 14 

### 15 16 17 18 19 

### Q. And again, I 

### know you have seen this, is a little obvious. So it literally was a crack the new welding material and the fuel was coming through that. A. Right along the edge, yes. 

### Q. A. And what caused that crack? I don't know. 

### Q. And having observed this crack; what situation? actions did you take to address this A. 

### A group of us that were up there got it in

together and discussed how we were going to fix it and
came up with a repair scheme for it and it involved using some tank**seale~** 

### to pack into the crack. We 20 drilled out about four or five of the bolt hole plug 21 welds to install bolts in them to ensure we could get 22 beyond the edges of the crack and it would be 23 

### mechanically held. Also used an aluminum U channel or 24 C channel and fit it over the edge with sealer, just 25 to help, mainly help hold the sealer.

REGENCY-BRENT ANO, INC. Page42Rodney Schneider In Re: Liberty Foundation April 30, 2013
1 Q. 

### So as I am trying to picture that, when 2 you say a C channel, is that another piece of metal 3 that you are putting over the crack? 4 5 6 

### A. 

### Q. Yes. Piece of aluminum extrusion. And on Exhibit 7 on Page 8, there is a June 13th, 2011, entry. Is this the entry that was 

### 7 made about the repair we have been talking about? 8 9 

### 10 

### A. Q. A. Yes. What is PR 2001? It is a two-part fuel tank sealer made'by 11 PRC DeSoto. 12 13 

### 14 15 

### 16 17 18 

### 19 20 

### Q. A. in a tube. 

### Q. the tank, A. 

### Q. be packed 

### A. What are the two parts? There is a base and a catalyst. You mix it. Was that applied inside the tank, both? We packed it in from the outside. Did you discuss whether or not it from the insi,de or the outside? It comes

outside

should
Well, ideally we would have done it from 21 the inside, but access at that point did not allow us 22 to do that. 23 24 

### Q. You said access at that point wouldn't allow you to do that. Was there some other point in 25 time you would be able to do that?

REGENCY-BRENTANO, INC. Page 43Rodney Schneider In Re: Liberty Foundation April 30, 2013


### 1 2 3 4 5 6 7 B. 9 

### A. I don't know that you could actually reach that far with the tank removed or not through one of the other holes, not having tried it. 

### Q. So this was done with the tank, the tank
was still in the aircraft the whole time, correct? A. Yes, sir. 

### Q. Now, you said that a group of you came up with the repair scheme. Who was in that group? A. It was myself, Chuck Giese who is also an 10 A&P, John Hess who is also an A&P and a B-17 pilot, 11 and Cullen Underwood. 12 13 

### 14 Q. 

### A. Q. It was Chuck Giese? Yes, sir. Did Mr. Giese and Mr. Hess work with 15 The Liberty Foundation as well? 

### 16 17 A. Q. 

### Yes, they do. Were they already in Aurora or did they 18 fly in like you did? 19 20 

### A. Q. 

### They were in Aurora. When the group of you were coming up with 21 how to do this repair, did you consult any sort of 22 manuals on how to do that? 

### 23 A. We looked through the maintenance and 24 erection, field service, and SRM and there was nothing 25 in them that even remotely covered this sort of thing.

REGENCY-BRENTANO, INC. Page 44Rodney Schneider In Re: Liberty Foundation April30, 2013


### 1 

### 2 3 4 5 

### 6 7 8 

### Q. Did you consult any instructions for continued airworthiness of any sort in doing the repair in June of 2011, any sort? It may have an obvious answer, but I still have to ask the question. A. There was nothing we could find written on how to do a repair of this kind. 

### Q. 4313-1-B, In this log entry it says reference Section 2, Paragraph 832. What are you 9 referring to there? 10 A. I can't quote you the text or anything. 11 This entry was also done as a result of a call with 12 myself and Dave Miller on how we should sign this off. 13 

### Q. Did you make this entry
-- did you have 14 that call and make this entry before the plane left or 15 afterwards? 

### 16 A. No. It was afterwards. I did not have 17 the logbooks with me up in Aurora. 18 Q. 

### So at the time that you made the repair 19 and were consulting with Mr. Underwood and Mr. Giese 20 and Mr. Hess, did you actually look at the document 21 referenced here? 

### 22 23 

### A. 

### Q. No. I did not have that with me. Beyond because Dave Miller said so, do you 24 know why you wrote
-- why this particular reference 25 was made in this log entry?

REGENCY-BRENTANO, INC. Page45Rodney Schneider In Re: Liberty Foundation April 30, 2013
1 

### 2 3 

### according to Google. THE WITNESS: Okay. Q. 

### (By Mr. Stevenson) How long was there 4 between when you made the zepair and when the plane 5 flew? 6 7 8 9 

### 10 11 

### 12 

### 13 14 A. Well, we finished sealing the repair on Sunday evening around 6:00 o'clock. Then the airplane set overnight. The next morning we fueled it I want to say sometime between 6:30 and 7:00 a.m. 

### Q. What time, do you know what time the plane left?A. Around 9:00 o'clock, maybe. I can't remember for sure. It was sometime mid-morning. 

### Q. When the log entry says you leak checked 15 the repair area, did that consist of something other 16 than looking at it and smelling it? 17 A. Well, we put 250 gallons in the tank 18 Monday morning first thing and let it sit for a while 19 while we buttoned up the rest of the airplane. We do 20 have access into the wing fairly well. I couldn't 21 touch it, but I could get within a couple of feet of 22 it and see it. We did a visual and didn't see any 23 fuel, didn't smell any odors of fuel. 24 

### Q. Whose idea was it to do the repair in the 25 way that you did?

REGENCY-BRENTANO, INC. Page47Rodney Schneider In Re: Liberty Foundation April 30, 2013
1 2 3 4 5 6 

### A. I don't recall anyone really specifically saying let's do it this way. at it. We just kind of arrived


### Q. Why were you chosen as the person out of the group of you to do the signoff? A. 

### Since I was the maintenance director. 7 Q. 

### If you were going to go back and do 

### 8 that if you were able to go back now and address 9 

### that leak situation again, would you do anything 10 

### different? 11 

### 12 13 

### 14 15 16 

### 17 18 19 20 

### MR. GOLDSTEIN: Objection. One, it calls for speculation; two, you are asking him what he knew then, if it is based on what he knew then? That's the basis for my objection. It is speculative. Calls for speculation. MR. STEVENSON: I will let the question stand. MR. GOLDSTEIN: If you can, answer it. THE WITNESS: I don't know. 

### Q. (By Mr. Stevenson) What other options for 

### 21 repairing the leak did the four of you discuss? 22 A. There was a lot of things talked about. 23 The biggest other thing would have been we talked 24 about dropping the tank and having it purged and 25 rewelded.

REGENCY-BRENTANO, INC. Page48Rodney Schneider In Re: Liberty Foundation April 30, 2013


### 1 2 3 

### Q. And why did you decide that that was not the appropriate course of action? 

### A. I don't know for sure why we chose one 4 over the other except a certain amount was time, a 5 desire to get the airplane to the next location; but 6 we wanted to do it in**~** 

### good manner. 7 8 9 

### 10 

### Q. Do you remember any other repair options that you discussed? 

### A. 

### Q. Not specifically. Would it be fair to say that

-- based on 11 your earlier testimony is it fair to say that ideally 12 you would have applied sealer internally but that you 13 didn't have access at that point in time? 14 A. Yeah. If I had had the access; that would 15 

### 16 17 have been the preferred way of doing it for me. 

### Q. Why is it preferable to apply the sealer internally? 18 A. You have a better chance of success with 19 it that way. 20 

### Q. Would you be able to
-- how much better a 21 chance at success? 22 A. I couldn't tell you. 23 

### Q. Do you know or were there passengers 24 scheduled to fly on the Liberty Belle that Monday 25 morning?

REGENCY-BRENTANO, INC. Page 491 

### 2 3 4 5 6 7 8 Rodney Schneider In Re: Liberty Foundation


### A. There were not any paying passengers. sometimes carry some friends or whatever when we do repositioning flights. 

### Q. So when you say the term repositioning flight, does that mean that there were going to be paying passengers at the destination? A. Yeah. The next tour stop. 

### Q. And was that the reason why there was a April30, 2013


### We

9 time issue? 10 11 

### 12 

### 13 14 

### 15 16 17 18 

### 19 20 21 

### 22 23 

### 24 25 A. Well, I mean, don't want you to think I this, we got to do this. thinking a little bit. when I say time issue, I
was being told we got to do But it does factor into your
Q. 

### If we go back to the February 2011, did you do any sort of inspection on the welding work to
see if it had been done properly? A. We did a visual on the welds, yes. 

### Q. A. When you say we, who 

### is that? Well, I looked at them. I know Cullen looked at them. 

### Q. Other than the conference call with the Daves, did you speak with Mr. Fowler

-- did you have any other conversation with Mr. Fowler directly about the work on the tank prior to returning it to service? MR. GOLDSTEIN: Are we talking about June

REGENCY-BRENTANO, INC. Page 50

# .{jJ!t~\: ·-' .·.< t

;GOVERNMENT

-- EXOIT.3
0**.~** Q 0 ''

!) 

### o,g 

# ... "if

0

0 'o

. '·'<'1>**~_,~** <::.'" 

# .,

e '

t:J) o· 

# i GOVERNMENT 

## i EXHIBIT lr-o 

# I ,--0 "'! 0 0

11
0

# ~**~** 

# @?)

# -~ 0**~** 0 0 Q oo 0 o, 0

### ~ 0**~ ~**  o• 0 '

# ..**}~"** 0 Q**~** 0**~**
Q 0 0**~**

# .. 0**~** 0 0 0 • 0**~** 

# .
..... 0**~** 

### .;**~** 

## :

# ·'-'.

0 '**~ ~**  0 0 0**~00** 0**-~·** 

### .· s <l' 0 % \,

### "' ll

# . 0 0**~**

GOVERNMENT**E~~BIT** 

# r= 0fl 0 

# I

0 ,..... 

# -**~** 0 Q..**'~** ,. ' ,,1
.. :.

### ~**i.~~f~·-.~**

# ·:

.**;;~.**

# ~:~**~;:::** ·t:J

GOVERNMENT EXHIBIT

### '-~<I> 

# \

"

0

CL 

# \.

Q 0 0

GOVERNMENT EXHIBIT



# j'-

# ,

-:i:., :•• .: j**~ia\Gt!**

### '\.;t~, 

# 'CD 0

....... 0 .=. c....**~GOVERNMENT** 

## i EXHIBIT 

# MGOVERNMENT EX 

# NIT0

-:r?. ,,, "'

.**""~ ~** 

0

c.**~** co 0 ....., 0

g:**~** GOVERNMENT 

## i EXHIBIT 

# DAircraft Record General Information

Manufacturer

# :P-o~IU(p

# [Jet'A)
Serial 

# '4-f973±: Model

# ---'-"'!3~-~/~].._6- _______ _ Registration Number

# _,_N
__ 3-=-_CJ
__ O
__ T}/.

___ _ Date of Manufacture---------------------------------- Engine(s) currently installed: Manufacturer--------- Model

___________ Serial

__________ _ Manufacturer--------- Model

___________ Serial------,----- Propeller(s) currently installed: Manufacturer

________________ Model

_________________ ___ HUB Model---------- Serial
----------- Serial----------- Blade Model

__________ Serial

______ Serial

______ Serial

_____ _ Blade Model

__________ Serial

______ Serial

______ Serial

_____ _



## EXHIBIT 1


# -----YEAR: 1\cCORDIN&., TDDAYS -1-.**T~CH** FUGHT**ror~1 Descri9tion~f**  Inspections, Te!l<ts, Repairs and Alterations Entries must be endorsed with Name. Rating and Certificate Number of Technician or Repair Facility. (See back pages for other spec1fic entries.) TIME DATE TJM::IIf

# -- SERVICE 

### February 24,2011 Hobbs Time: 1478.7 ACTT: 2474.7 N390TH Boeing B-17G 

### SIN4485734 Performed "D'' Check Inspection on this airframe. All four Prop Domes removed, inspected, and desludged. Replaced plywood floor panels in the nose section and aft 

### cockpit 

### area Wtring in both wings inspected tor chaffing and condition and replaced/secured as needed. All four oil coolers removed, overhauled, and reinstalled. Low Voltage warning light installed on the pilots instrument panel. Hydraulic reservoir removed, flushed, and leaks repaired by welding. Removed and resealed #4 cowl tlap actuator. Replaced right wingtip to wing attach coverpaneL Replaced #4 upper outboard cowl segment with a serviceable part. Replaced all 

### 4 fuel shutoffvalves with original type solenoid valves. Remove #4 engine 

### SIN SW-042700 and installed engine 

### SIN 010995, 0 hours SMOH. See engine log for details. IcertifY that 

### this airframe was inspected in accordance with a ·'O" check inspection as per FAAApproved Inspection Program and was found to be in 

### airworthy condition. Next inspection is due at 1503.7 hours Rodney SchneiderL

# ~ AP 2649010



## EXHIBIT
__ _lS YEAR: RECORDING TACH TIME DATE TODAYS TOTAL Description of Inspections,Tests, Repairs and Alterations FLIGHT TIME IN Entnes must be endorsed with Name, Rating and Certificate Number of SERVICE Technician or Repair Facility. (See back pages for other specifiC entries.)
February 24, 2011 HobbsTime: 1478.7 ACTT:2474.7 N390lli Boeing B-17GS/N4485734 Removed all srx fuel tanks. Removed bladderlrners from thetanks and

---- repaired the aluminum tanks by welding. Ref: AC43-13 section 8-32. Fuel tanks are made ofaluminum sheet, II00**~** hard. Reinstalled the original aluminumtanksusing the original mountingmethodsand the original fuel line, boost pump, fuel cap, vent line, and level transmitter mounting locationsand methods. Thetanks were leak checked and operationally checked 

### with no discrepancies found. Ref. B-1 7 Maintenance and Erection manual, pages 196-199 Rodney Schneider

# ."h., 

# Q**~** AP 2649010

r- 

# i.v: :_-: :.**~-=- Ic;.~-~-~** **I'~;= ~~~-:LT~**  

## EXHIBIT
__ _YEAR:· RECORDING TODAYS TACH FUGHT TIME DATE 3/13/2011 TOTAL TIME IN SERVICE Description of Inspections, Tests, Repairs and Alterations Entnes must be endorsed w1th Name. Rating and Certificate Number of Techn1c1an or Repair Facility. (See back pages for other spec:fic entries.)

-- Removed rt. main landing gear motor disconnecting three main electrical leads and ground wire. Removed 4 attach bolts and one clamp. Installed serviceable landing gear motor attaching it with 4 bolts with standard torque and one clamp reconnected electrical leads and ground wire. Jacked aircraft and adjusted the rightmain gear lower limit switch perthe field maintenance manual and performed a gear swing for proper operation. IAW B-17G Field Service manual page 206- 215

Installed landing gear motor PIN 1073-1-B 

### SIN 7305

DavidAlderman A 

### &P 3100592



# I**FG~:::.** OFf'ICIAL USE ONLY 

## EXHIBIT



# -----YEAII: RECORDING TACH TIME DATE TODAYS TOTAL Description of Inspections,Tests, Repairs andAlterations FUGHT TIME IN Entries must be endorsed with Name, Rating and Certificate Number of SERVICE Technician or Repair Facility. (See back pages for other specific entries.)



### March 25, 2011 HobbsTime: 1505.9 ACTT: 2501.9 N390TH Boeing B-17G SIN 4485734 Performed "'A"

### Check Inspection onthis airframe. Lubed RIH 

### MLG screwjack. Replaced broken comm antenna. Replaced #3 Main Tank fuel boost pump. Inspected # 1and #3 oil cooler shutter linkage for

---- possible binding. Adjusted oil pressure reliefon #1 and #3 engine one · __ turn 

### increase. I 

### certify that this airframe was inspected 

### in accordance with an ..A" 

### check inspection perthe FAA

### approved inspection program and was found to be in airworthy condition. Next inspection is due at 1530.9 hours. Rodney Schneider

## ~ 

# 0**~** AP2649010

I ! -,'" ··.•··. ·-····..**-~-~** . ., ,.. '.--:- ,. .,. :- • .. ... I. ---·**--~~---~-** ----- 

### .. -------·--- 

# EXHIBIT
__ _YEAR: R ----···· I

. r. April21, 2011 Hobbs Time: 1533.6 ACTI: 2529.6 r N390TH Boeing B-17G 

### SIN 4485734 DATE Performed a "'B" check inspection on this airframe. Adjusted the oil cooler shuner ---1- linkage on #4 engine. ---1-- 

### I certifY that this airframe was inspected in accordance with a ·'B'. check inspection per the FAAapproved inspection program and was found to be in airworthy ---4-- condition. Next inspection is due at 1558.6 hours.

---+-- Rodney Schneider

# X U**~** 

# - AP2649010 ons of es.)

-------------
-----1- May 14. 2011 HobbsTime: 1556.7 ACTT: 2552.7 N390TH Boeing B-17G 

### SIN 44-85734 -----1- ------J'-- Performed a '"C' check inspection onthis airframe. ------J- 

### I certify that this airframe was inspected in accordance with a 

## --c· check inspection perthe FAAapproved inspection program and was found to 

### be in airworthy ----+- condition. Next inspection is due at 1581.7 hours.

---+- Rodney Schneider

## /t;:.::_:.:z_.sr,~~ .....

## ~~~C..C::::::::--­ AP2649010

## ---~- 

# I 

# -,,-----r,----------

EXHIBIT
__ _YEAR:
DATE June 10. 2011 Hobbs Time: 1583.0 ACTT: 2579 N390TH Boeing B-17G 

### SIN 4485734 

### "D" Check inspection performed on this airframe.

--- 1certii}' that 

### this airframe was inspected in accordance with a "D'. check inspection

___ perthe FAA approved inspectionprogram and was found to be in airworthy

--- condition. Next inspection is due at 1606.7 hours.

___ Rodney Schneider

## 7~

-- AP26490

### I0

June 13,2011 rations nber of entries.)

Repaired a fuel leak atthe bottom, inboard end of#] main tank with sealerPR-2001
___ _

-- Class 

### B- 112, reference43.13-1-B. Section 

### 2, Paragraph 

### 8-32. Fueled tank with 

### 250

-- gallons and leaked checked the repair area. No leaks noted visually orby smell.

-- Rodne)' Schneider -;:/ 

# ---4L----- AP2649010



# I I I I

EXHIBIT
__ _YEAR: RECORDING TODAYS TOTAL Description of Inspections, Tests, Repairs and Alterations TACH FLIGHT TIME IN Entries must be endorsed with Name. Rating and Certificate Number of TIME SERVICE Technician or Repa1r Facility. (See back pages for other specific entries.) DATE

-



## r------------------------------**FG;~ Gl~2T2:AL**  

### USE**Gl·'~JL'"rJ** 

## EXHIBIT
__ _

### U.S. DEPARTMENT OF TRANSPORTATION Office of Hearings

Washington, D.C.

In the Matter of: Docket No. FAA-2012-0477 LIBERTY FOUNDATION, INC., Case No. GL-03-0070 Respondent.

DEPOSITION OF RAY FOWLER Wednesday, May 1, 2013 9:20 a.m. 1701 Columbia Avenue College Park, Georgia Renda K. Cornick, RPR, CCR-B-909

REGENCY-BRENTANO, INC. Certified Court Reporters 13 Corporate Square

- Suite 140 Atlanta, Georgia 30329 404-321-3333Ray Fowler In Re: Liberty Foundation April 30, 2013
1 2 

### 3 4 5 6 7 8 9 

### 10 

### A. Yes, sir. I have 20 plus years in World War II flying experience, a combined civilian and military background. Currently serve as a pilot with Delta Air Lines. I 

### am also 15-year military, still active with the Air National Guard, 187th Fighter Wing as an F-16 pilot. Varied civilian and military background. with Boeing B-17. Just long-standing involvement


### Q. When did you become involved with The Liberty Foundation? 11 A. From day one. I 

### did the test flights in 12 December of 2004. I 

### have been involved every day 13 14 15 16 since. 

### Q. Are you currently the chief pilot of Liberty Foundation? 

### A. Yes, sir. I 

### am the executive director 17 with Liberty Foundation, but I 

### serve in the capacity 18 as chief pilot even though chief pilot is 

### not required 

### 19 per operation. I 

### am the self-proclaimed chief pilot, 20 involved with all the pilots and overall operation of 21 the aircraft. 22 

### Q. Have you been the executive director and 23 chief pilot since day one as well? 24 25 

### A. 

### Q. Yes, sir. Now, it is 

### my understanding that in 2010

REGENCY-BRENTANO, INC. Page6Ray Fowler In Re: Liberty Foundation April 30, 2013 

### Q. You mentioned that you had discussed 1 

### 2 3 4 

### earlier with Tim Bourgoine but when you put it down Atlanta you mentioned discussing it with Rodney in

Schneider. Had he replaced Tim Bourgoine as the 5 director of maintenance at that point in time? 6 

### A. Yes, sir, he had. That's based on just 

### 7 the geography of having the airplane winter based 

### 8 versus having the airplane in Albuquerque. 

### 9 I 

### do want to clarify, we are not required to have a director of maintenance by any regard. We 

### 10 11 

### are a Part 91 operation. So this is kind of from a 12 professional standpoint. And I 

### have had a 

### 13 long-standing operational relationship with the 

### 14 Atlanta FSDO as a proficiency examiner. 

### I kind of 

### 15 have modeled it after a 

### 135 or after a 121 obviously 

### 16 17 from our operations and responsibilities. But we are not required to have a director of maintenance. I 

### 18 just want someone in the position that would basically 19 

### 20 keep up with the records and make sure everything done since we are not I am not trained in the 21 aspects of, you know, what is responsible for the 22 maintenance. So that's why we have always used is

23 outside folks to do that type of maintenance and work. 24 So again, that is I assign somebody, call them the 25 title of director of maintenance, but that is not

REGENCY-BRENTANO, INC. Page 10Ray Fowler In Re: Liberty Foundation April 30, 2013
1 2 3 4 5 6 7 8 

### required per se for our operation. That**~s** 

### just kind of self-imposed that I personally did, if that makes
sense. 

### Q. Sure. Would it be fair to say that The Liberty Foundation conducts operations that would otherwise require an air carrier certificate but you are operating under an exemption? 

### A. Well, no. That's not the case at all. 9 

### The exemption itself-- we are 100-percent Part 91. 10 The exemption was actually created out of the fact 11 that museums were flying public basically for 12 donations and there was no real oversight of that. 13 I was involved when this happened 20 years ago, when 14 they created the exemption for the sole purpose of 15 having some FAA oversight over the.fact that So

16 museums -- and I think there are 19 exemption holders 17 that are allowed to fly the public

-- they wanted some 18 avenue to where they could actually, you know, have 19 some oversight, FAA oversight into those operations 20 for flying. 21 So it is not required per the exemption 22 whatsoever, you know, to have any director of 23 maintenance, you know, in any regard. It is just 24 something that I have personally imposed on our 25 operation.

REGENCY-BRENTANO, INC. Page 11Ray Fowler In Re: Liberty Foundation April 30, 2013
1 

### Q. Now, when the plane was put down for 2 winter maintenance in 2010, had it already been 3 decided at that point what you were going to do about 4 the tanks or was that decision made after it was put 5 down for maintenance? 6 7 8 9 

### 10 11 

### 12 

### 13 14 

### 15 16 17 18 19 20 

### A. It was around that same period of time that the decision was made. 

### Q. And when you were making that decision, describe the decision-making process. A. Well, I was advised by Rodney Schneider and the group that he was working with that the best option for that was to remove the self-sealing tanks and to create
-- my understanding was it was going to be a complete fabrication of new aluminum tanks. That
was my understanding, that we were going to replace the self-sealing tanks with the same system with an aluminum tank. That is the way it was briefed to me originally before the work was being performed. Q. When you say, you refer to Rodney Schneider's group, who is in that? 21 A. Well, he is involved with other people 22 there. I mean, I know he is an accomplished guy with 

### 23 Delta Air Lines, retired. He has several other people 24 he works with there; Cullen Underwood being one which 25 was involved, Paul White which is an IA which is

REGENCY-BRENTANO, INC. Page 12Ray Fowler In Re: Liberty Foundation April 30, 2013


### 1 2 3 4 

### involved. I mean, there is people that he worked with. Again, I was on conversations with FAA inspectors as well which I just listened in. Again, this is not my area of expertise. But I sat through 5 and listened to some conversations they had with Dave 6 Miller, Dave Alderman, on that about what js the best 7 way to go about replacing the tanks. 8 Again, when we started the process it was 9 with, you know, we wrote a check to go to a DAR to go 10 down the path like we have done previously because we 11 already have a modified fuel system in that airplane. 12 So when the airplane was certified, the fuel system 13 was modified. It was a major alteration. We went 14 through the paperwork, the flight testing; when we 15 replaced our tail wheel, same thing. We have always 16 gone through the proper path of if there is any 17 changes or modifications to that fuel system or to the 18 tail wheel, we have always gone through and done the 19 paperwork and the testing and had the paperwork 20 associated with that. 21 22 23 winter. We originally did the same path over the So we wrote a check to a DAR. They submitted paperwork for that. And then at some point the 24 decision was made that this was not going to 25 constitute a major alteration because it didn't modify

REGENCY-BRENT ANO, INC. Page 13

### 1 2 3 4 5 6

-- 

### 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ray Fowler In Re: Liberty Foundation April 30, 2013


### the basic design from changing from.self-sealing tanks to aluminum tanks. So that was briefed to me as well and I was on those conversations. However, I don't recall exactly when that decision was made or, you know, the decisions when they were made in place to, you know, use the existing components in the fuel tank. But I was briefed on that. Again, those decisions were made outside of me and the foundation when we contracted to have the work done. 

### Q. When you said you were briefed on that, who was briefing you on that? A. The conference call between Rod Schneider
was on the call and I believe Cullen Underwood was on that call. And again, there has been multiple conversations in between that we discussed, you know, even, you know, just me trying to learn what was going
on with the airplane, what decisions were made because they were making them and I have to ultimately brief those back to the foundation of what changes we are doing to the airplane. That was over the winter when the work was being done. 

### Q. Before the work had started, you mentioned
a conference call with or possibly

-- was there one conference call with FAA inspectors or more than one? A. There was more than one.

REGENCY-BRENTANO, INC. Page 14Ray Fowler In Re: Liberty Foundation April 30, 2013


### 1 

### Q. Okay. Was the first of those conference 2 calls before the work started or after the work 3 started? I don't recall. 4 5 

### A. 

### Q. Do you have any idea how many of those 6 conference calls there were? 

### A. I really don't. But several. 7 8 

### personally was on several calls, you know. I mean, But I 9 would say at least five different calls that we I



### 10 just as the work was being done, you know, just to 11 brief us on how, you know, what the process was and 12 what they were doing from·a standpoint of, you know, 13 getting the airplane back in the air. 

### 14 Q. 

### And was Mr. Schneider involved in all of 15 those calls? 

### 16 

### A. I believe so, but I am not sure if he was 17 on every call. 

### 18 19 20 

### 21 22 

### 23 24 Q. calls? 

### A. Q. calls? 

### A. 

### Q. Was Mr. Underwood involved in all of those

He was. Were there any designees involved in those
Designees? Designated airworthiness representatives 25 or designated engineering representatives.

REGENCY-BRENTANO, INC. Page 15Ray Fowler In Re: Liberty Foundation April30, 2013
1 A. 

### Again, the conversatidns between 2 Mr. Miller, Mr. Alderman, you know, they have come out 3 

### and been volunteers with the airplane. They are 4 familiar with our aircraft, obviously not working in 5 an official FAA capacity although I know you are 6 

### always on duty with FAA. But we did look to their 7 counsel for, you know, what was the best path to go 

### 8 about making these repairs to the tanks. 9 

### Again, I 

### did talk to them personally



# . 10 about, you know, this; and I was on the calls when 11 

### they were discussing, you know, how the changes were 12 

### going to be and the write-ups, whenever the decision 

### 13 was made to not go down the major alteration path with 

### 14 the 

### 37, that it was not going to be a design change of 

### 15 the system. But 

### I don't recall who was on that 16 

### conversation. It has just been too long ago. 

### 17 

### Q. Did you ever have a conversation with a 18 

### DER or DAR? 19 A. I personally did not. 

### 20 Q. 

### Do you know if anyone involved with 21 

### The Liberty Foundation did? 22 A. I 

### do. I 

### know that Cullen Underwood spoke 

### 23 to them originally. Cullen is one of our pilots as 

### 24 well. So he is a rated captain, but he was involved 

### 25 with several aspects of that. He originally had the

REGENCY-BRENT ANO, INC. Page 16Ray Fowler In Re: Liberty Foundation April30, 2013
1 

### conversation and sent documents to a DAR. And again, 2 we wrote a check to start the process for that because 3 that was the original path that we were going to
-- 4 that we were planning to go down because that was the 5 path we had gone down with pretty much every other**~** 

### 6 modification or alteration we had made to the 7 airplane. 8 Q. 

### Why did you decide to go down a different 9 path? 10 

### A. Well, I didn't decide to go down a 11 

### different path. At some point the decision was made 12 that the changes that they were going to do which was 13 going to be keep the aluminum shells and to keep the 14 same fittings, same design did not constitute a major 

### 15 alteration. So every component of the fuel system 16 they said was the same, the fact that just the 17 self-sealing bladders were not there with the aluminum 18 

### tanks. We were advised this obviously was, you know, 19 this was happening with other platforms as the 20 self-sealing tank issue came about and that this was 21 not
-- again, from my small brain, it made total sense 22 from an operational side that, you know, all we were 23 doing was basically removing those self-sealing tanks· 24 and having aluminum tanks in their replacement, that 25 it was not a modification of the fuel system because

REGENCY-BRENTANO, INC. Page 17Ray Fowler In Re: Liberty Foundation April30, 2013


### 1 2 3 4 5 

### made based on cost. 

### Q. Were you ever involved in a conference call with FAA inspectors about what the maintenance entry would need to say after this? A. I believe I was. I was on a call where 6 they were discussing it, but I don't remember the 7 exact contents or verbiage of what it would say 8 afterwards. But I do recall being on a call where 9 they were discussing the entries for the logbook. 10 Again, I can't speak to the specifics of that. 11 

### Q. Were you ever involved in conference calls 12 where the details of the actual work to be performed 13 were discussed? 

### 14 15 16 

### 17 18 MR. GOLDSTEIN: Do you mean with FAA inspectors? 

### Q. A. (By Mr. Stevenson) With anyone. Yes, I was. Not just conference ·calls but I was on site. The work was done in Cherokee County. 19 So when the tanks were coming out of the airplane, I 20 mean, I was standing there when they were looking over 21 the work to be done. So again, yes, sir, I was 22 through

-- they were briefing me on what work was 23 24 

### 25 being done when the tanks came out, when it went to the fabrication shop where the work was actually performed on the tanks. So yes, sir, I was involved

REGENCY-BRENTANO, INC. Page 19Ray Fowler In Re: Liberty Foundation April 30, 2013


### 1 with pretty much every decision that they made for 2 that. 3 4 5 

### 6 7 8 9 

### 10 11 12 13 14 15 16 Q. I understand that you are not a mechanic. You are not a mechanic, right? A. I am not a mechanic, no. 

### Q. What is your understanding of what was actually physically done with these, with the shell, to make it into the tank? A. Sure. The original system had a shell, aluminum shell that encased the self-sealing tanks. So each B-17 is a little different in that regard. Some of them just have straps that hold the self-sealing tanks within the system. If you were to pull the panels down and look at the tanks, you would physically see the actual self-sealing tank that is held within the straps. Ours had a full shell, 17 aluminum shell that encased the self-sealing tanks 18 that at some point

-- at the end they were put in 19 there, then they were welded in there with the holes 20 where the fittings came out of the tank. So from the 21 top of the fuel filler, all the vent lines, 22 connections, boost pumps on the bottom. 23 So those aluminum tanks that were Boeing 24 tanks at some point that came out of the airplane, 25 they fit back into our airplane so, again, it is

REGENCY-BRENTANO, INC. Page20Ray Fowler In Re: Liberty Foundation April 30, 2013
1 

### A. No, sir. 2 

### Q. I would like to ask you about June of 3 2011. I am sure you recall an incident on I think it 4 was around June 12th, where there was a fuel leak that 5 had to be addressed. 6 7 8 9 

### 10 Yes, sir. 

### A. Q. A. Can you tell me what happened with that. I 

### was there. There was a fuel leak in the No. 1 

### tank. I was actually there with a P-40. I 

### knew they had the leak. Mr. Schneider and Again,

11 Mr. Underwood both flew up from Atlanta to look at the 12 13 14 15 16 17 airplane. So again, it was a fuel leak. You know, we grounded the airplane at that point. They came up to look at it. The fuel was transferred out of that tank. And they made the decision to make the repair
on site with the tank. Again, we were already doing an 18 inspection, I think it was a D inspection up there for 19 the week prior. And so we had, you know, three 20 mechanics there and an IA was there to do the work. 21 So they flew up. 22 Again, I wasn't directly involved, but I 23 knew that the work was being done there at the time. 24 

### Q. Was the repair discussed with you at the 25 time?

REGENCY-BRENTANO, INC. Page34Ray Fowler In Re: Liberty Foundation April 30, 2013

1 2 3 

### A.
Q. It was. Yes, sir. MR. GOLDSTEIN: When you say at the time. (By Mr. Stevenson) At the time, on that 4 day or the next, you know, before the plane flew 5 again. 6 7 8 9 

### 10 11 

### 12 13 

### 14 A. Yes, it was. Again, with the repair itself, again, they came up with

-- they brought equipment up to look at the tank and to
-- and they told me what they were planning to do with where the leak was, that one of the welds in the tank, to go through to make that repair so they told me what they
were planning, Rod did. And again, it was at the time, you know, they just briefed me on it. I didn't think anything as far as other than the fact that we 15 consider a fuel leak to be, you know, a serious issue 16 with the airplane. So, you know, we had multiple 17 people up looking at the airplane as far as the repair 18 of the tank at that point. 19 Q. If you turn to Page 8 of Deposition 20 Exhibit 7, is the June 13th, 2011, entry, would you 21 agree this is the entry about the repair we have been 22 discussing? 23 A. Yes. 

### 24 

### Q. I am sorry, who flew the Liberty Belle 25 after the repair?

REGENCY-BRENTANO, INC. Page 35

## PARTS CATALOG

'.'
·--

-·- · .. i .__,. 

## USAF SERIES 

# B-17G

AIRCRAFT**LAT~ST** 

### R:EVlSED PAGES**SU?~:15ED~** 

### THE SAME

## PAG~S Or PREVIOUS DATt Insert revised pages into basic publication. Destroy superseded pages.

PUBLISHED UNDER AUTHORITY OF THE SECRETARY OF THE AIR FORCE AND THE CHIEF OF THE BUREAU OF AERONAUTICS

# ~A~F~-W-P--Q-.f-6_5E_P_S2--5,-JOO-----------------~----------------~----------_j~ 1**SEPTH~BER** 

## l94S

REVISED 8 AUGUST W-52 

# IGOVERNMENT 

### i EXHIBIT 

# s ;

_______

### ··~ . 

### !I"·

. . .. .**·.~~-:;** 

### ",.;,_ /**RESTRICT~O** AN 01-20EG·4



### I INTRODUCTION. 

# ,..-..:-: ·• 0 '1

.**-~-·** - -- ....--- '

-- -· ...... ....o.:-. .·-

## -~-**i::_rj___~_** 

## 1_! '_: l_\_ 

# 't' -.. .

How to find the number of a part. ............ . How to find a part when the number is known
...................................... . How to find a missing part. ................. ·.· .·**~ ~**  : : ................................. . 

### 3 

### 3 3 3 4 5 8 ............. 0
......................... . How to order Vendor's list : : : ............................................. : .................. .

............. - •• 0 ................... 0. 0. 0 ....... 0 .................. 0 ... 0 ••• 0 .. Usage code index

.............. 0
.......... 0 •• 0 0 Major components index. ......................................................... .

• 0 •• 0 •••••••••• 0 ............................ .. 

### II GROUP ASSEMBLY PART§ LIST

0 ••• 0 • 0 ••• 0 •• 0

- ....... 0 0
............. 0 0 0 ••• 0
... . 

### 9 Wing Wing Index
......... , , . . . . . . . . . . . . . . 10 Outer Wing Panel Details.
. . . . . . . . . . . . . . 12 Wing Gap Cover
...................... 14 Outer Wing Panel Access Provisions.
. . . . . . 15 Outer Wing Panel Aileron Provisions.
. . . . . 16 Fabric Covered Aileron Assembly.
. . . . . . . . 18 Wing Flap Assembly.
. . . . . . . . . . . . . . . . . . 19 Inner Wing Assembly.
. . . . . . . . . . . . . . . . . 20 InnerWing Arraching Terminals.
. . . . . . . . . 22 Inner Wing Access Provisions.
. . . . . . . . . . . 24 Trailing Edge Assembly
................. 26 Inboard Nacelle Structure and Fit.tings.
. . . . . 28 Inboard Nacelle Miscellaneous Supporrs.
. . . . 30 Outboard Nacelle



### ..................... 32 Inboard Exhaust Shrouds and Supercharger Cooling Duces
. . . . . . . . . . . . . . . . . . . . . 34 Exhaust Collecror -Tailpipes.
. . . . . . . . . . . . . 36 Landing Gear Support
............... : . . 38 FlapControls Motor UnitAssembly.
. . . . . . . 39 Wing Flap Control.
. . . . . . . . . . . . . . . . . . . 40 Outboard Fuel Tubing
.................. 42
RESTRICTED Outboard Fuel Tubing
.................. 

## 44 Inboard Fuel Tubing.
. . . . . . . . . . . . . . . . . . 46 Wing Fuel Tanks
..................... 48 Wing Tank Supporrs
................... 50 LH Wing Oil System.
. . . . . . . . . . . . . . . . . . 52 RHWingOil System.
. . . . . . . . . . . . . . . . . . 54 Engine Oil Tank and Oil Transmitter
..... ·. . 56 Oil Temperature Regularor.
. . . . . . . . . . . . . 58 Oil Dilurion and Oil Surge Valves
......... 59 LHWingSuperchargerLubricacing Oil Syscem 60 RHWing Supercharger Lubricaring Oil System
........................... 61 Supercharger System-Inboard
........... 62 Supercharger System-Outboard
. . . . . . . . . . 64

.SuperchargerAirFilter and fnrercooler.
. . . . . 66

Supercharger Air Filter ReliefValve Assemblies
. . . . . . . . . . . . . . . . . . . . . . . . 68 lnrercooler Temperature Control-Wing
.... 70 SuperchargerOil Tank and Tank Supporrs.
. . 71 lHWing Supercharger Regulator Tubing

_and Controls
. . . . . . . . . . . . . . . . . . . . . . . 7 2 RH Wing Supercharger Regulator Tubing and Controls
. . . . . . . . . . . . . . . . . . . . . . . 7 4ll RESTR!CT::D AN**01-20~G~4 ~~~-~sv·~·,·.·.~** 



# ..**--~~!:':-<·: ·--~--:.**  

# .**,::~:_;:;,,_·:>-:_:~**
LHSupercharger Control Bracker.
. . . . . . . . . 76 RH Supercharger Control Bracker.
. . . . . . . . 77 Turbo-elt-ccric Regulator-Wing
.......... 78 Wing Elt-errical
. . . . . . . . . . . . . . . . . . . . . . SO Nacelle Elt-errical
. . . . . . . . . . . . . . . . . . . . . 82 Nacelle. Solenoid and Shields.
. . . . . . . . . . . . 84 Srorage Barrt-ry Comparrmenr
....,, . . . . . . . 85 Wing and Naceile Hydraulic Sysrem
....... 86 Propeller Anri-icer-Wing
.............. 87 Wing De-icer System.
. . . . . . . . . . . . . . . . . . 88 Engine Fire Extinguisher-Wing
.......... 90 Vacuum Sysrem-Wing
................ 91 Hearing and De-icing System-Wing
....... 92 Glycol Sysrt-m
. . . . . . . . . . . . . . . . . . . . . . . . 94 Pressure Relief Valve Assembly and Purolaror Assembly
. . . . . . . . . . . . . . . . . 96 Cabin Hear Conrrol Bracker.
. . . . . . . . . . . . . 97 Cabin Hear Control.
. . . . . . . . . . . . . . . . . . . 98 Tail Tail Surfaces
.........· ................ 100 Tail Surfaces Derails
................... 102 Tail Surfaces Fairings and Gap Covers
...... 104 Tail De-icer
..........· ............... 105 Elevator TrimTabControl
............... 106 Rudder Trim Tab Control.
.............. 107 Fuselage Nose Assembly
....................... 108 Forward Secrion Windows
............... 110

· Forward Seerion Flooring Spt-eial Firrings
.... 112 Pilar's CockpitWindows and Windshield
.... 114 NavigJ.mr's and Pilot"s Scacion Bt:;lkhead Fittings
............... , .......... 116 RJ.dio Compartment Bulkhead Fittings
...... 118**Rt:ST;~ICIE!l** Forward Sccrion Bulkhead Doors
.......... 120 Forward Stetion Misceilaneous Fircings
..... 122 Bomb Doors and Bomb Rail Support
....... 123 Forward Entrance Door and Camera Door
... 124 Wing Srub 

### Filice Fairing and Compression Srrur Ficrings
...................... 126 RearSection Bulkhe-ad Fittings
............ 127 Top Gun Emplacement Windows
......... 128 \Y/aisr Gun Windows
................... 130 Main Entrance and Emergency Exic D00rs and Releases
....................... 132 Rear Section Miscellaneous Ficrings
........134 Rear Gun Mounc and Tow Targer Release
... 136 Tail Gunner's \Y/indow Enclosure
......... 138 Life Raft Doors and R;tfr .Amom?.ric Ejeccc.:
.. l40 Sears Index
.......................... 142 Pilar's and Co-pilot's Sear
................ 144 Windshield Wipers
................... 146 Windshield \Viper Cor.vercer·
............. 147 Aileron Conrrols-Fuselage
.............. 148 Eleva

### cor Conrrols-Fusebge
......... , ... 149 Rudder Conrrols-Fuselage
.............. 150 Tab Conrrols-Fuselage
................ 151 Control Column
.....· ................. 152 Rudder Pedals
....................... 154

. . Brake Ccnrrol
........................ 156 Aileron Tab Conrrol Assembly
............ 157 Tail Wheel and Surface Concrol LocksFuselage
.......................... 158 Rudder and Elc:varor Lock Units
........... 159 Wing.Fb.p Concrol Me-chanism
........... 160 Auromaric Flight Comrol Equipment
....... 161 Engine Conrrols-Fuselage
..........· .... 162 Engine Conrrol Stand
.................. 163 Concrol Stand Mixture Cancro! Levers
...... 164 I ' '/

...

### ___ RESTRICTED AN Ot-20!:G·4

Throtde Levers and Propeller Lock
........ 166 Elevaror Trim TabUnit.
................ 168 Engine Control Stand Lower Pulley Rack
.... 170 Fuselage Fuel System
................... 171 Auxiliary Fuel Tank Kit Assembly and Fuel Transfer Selecror Valve
............... 172 Pilot's Instrument Tubing
............... 175 Instrument Equipment
................. 176 Pilot's and Co-pilar's InstrumentBoard
...... 178 Nose Section Electrical
.................. 180 Pilot's Compartment Elecrrical Equipment.
.. 1H2 Central Control Board and Pilar's Control Panel
...................... 185 Forward Center Fuselage Electrical Equipment
........................ 186. Aft Cemer Fuselage Eiectricai Equipment
.... i 88 Aft Fuselage Electrical Equipment
......... 190 Bomber's Conrrol and Instrument Panel
..... 192

. Auxiliary Control Board Panel
............ 194

Switch Panel and Formation Srick Equipment. 195 Turbo-electric Regularor-Fuselage
........ 196 Inrercooler Temperature Control Stand Assembly
........ , ................ 197 Fuselage Hydraulic System
............... 198 Cowl Flap System-Fuselage
....... _.....200 Accumularor and Reservoir Tank
..........202 Hydraulic Hand Pump
.................203 Hydraulic Valve Assemblies
..............204 Motor Driven Gear Pump
...............205 Radio Antenna
.......................206 Radio Antenna (Special)
...............208 Forward Fuselage Radio Equipment
........209 Miscellaneous Oxygen Equipment.
........218 Engine Fire Extinguisher and Control-Fuselage
..................220 Vacuum System-Fuselage
........ .'
.....222 VacuumSelectorand Safery Valve Assemblies. 224 Propeller Anti-icer-Fuselage
............225 Fuselage De-icer System
.................226 Forward Fuselage Hearing and De-icing System
...........................228 Hearing and De-icing System-Fuselage Aft..230 Fuselage Forward Hearing and Ventilating System
...........................232 Hearing and Ventilating SystemFuselage Afr
.......................234 Cabin Hear Srand
................ : ....236 Chin Turret
.........................237 Cheek Guns and Equipment
..............238 Radio Compartment Gun
...............240 PowerTurrets
........................242 Waist Guns
.........................243 Waist Guns
.........................244 Tail Gun Equipment
...................246 Tail Gun Sighting Equipment
............248 Bombardier's Stand Assembly
............249 Bomb Door Control
...................250 BombDoorControls Screw Assembly
.......252 Bomb Door Conrrol Gear Assembly
........25.4 Bomb Door Limit Switch
................256 Bomb Control Unit Assembly
............257 Bomb Rack and Door Control
............258 Internal Bomb Hoist
...................260 Internal Bomb Rack-Outboard
...........262 Special Radio Equipment
................212 Inrernal Bomb Rack-Inboard
............264 Radio Inrerphone
. . . . . . . . . . . . . . . . . . ..214 Protective Armor
.....................266 Radio Equipmem-Aft
.................210
Oxygen System Control Panels
............216 D6 BombShackle Adapter
...............26R RESYRICTEO iii**R~STRICTED** AN 0**1-20~G-4**

Alighting Gear fnboard Engine Controls
................301 Universal Drag Link Assembly
............269 lanJi11g Gear anJ Brakc:s
................270 LandingGear Strut Asstmbly
.............272 Rerracring Gear Mc:chanism Asstmbly.;
....274 Landing Gear Hand Retracting Control
.....276 Brake Return Valve Assembly
............**~78** Tail Gear Brake and Lock Assemblies
.......279 LH Outboard and Inboard Engine Fuel System
.......................302 RH Inboard and Outboard Engine Fuel System
.......................303 LHOurboard and RH**Inbo~rd** Engine Oil System
........................304 LH Inboard and RHOutboard Engine Oil System
..........· ..............305 Tail Gtar
...........................280 Cowl F!ap Cylindtr Assembly
............306 Tail Gear Oleo Assembly
................282 Tail Gtar Retracting Assembly
...........283 Tail Gear Rerracting Assembly
...........284 Power Plant Functional Systems Rudder Control System
.................307 Elevacor Control System
.................308 Aileron Control System
.................309 Cowl Ami-drag Ring
...................285 Tab Control System
....................310 Engine Accessories
....................286 Intercooler Temperarure Control
..........311 Exhaust Manifold Assemblies
.............288

.Fuel System
.........................312 Engine Dynafocal Mount Assembly
........290 Hydraulic System
.....................313 .Engine Dynafocal Mount Assembly
........291 Cowl Flap System
.....................314 Cowling Flaps
.......................292 

### De:icer System
.......................3 15 Cowl Flaps Operating Mechanism
.........294 Heating and De-icing System
.............316 Fixed Cowling and Shrouds
..............296 Hearing and Ventilating System
...........317 Engine Starter Control and Support
........298 Propeller Anri-icer System
...............318 Engine Starter Control and Support
........299 Engine Fire Extinguisher Sysrem
..........319 Outboard Engine Controls
...............300 Vacuum System
......................320 

### Ill NUMERICAL PARTS LIST ....................................................321 IV STANDARDS PARTS LIST.................... ; ...............................391 

### V SERVICE TCOLS

.........................· .............·.......................393 Engine and Wing Panels Hoisting Slings
................................................394 Fuselage HoistiP.g Slings
............................................................395 Ground Handling Equipmenc
........................................................396 Service Tools
....................................................................397 Service Tools
....................................................................398 Service Tools
....................................................................399 Service Tools
............................ : ..•.........·...........................400 Service Tools
......................... _.....·......................................401 Operational S<juadron Tool Kit Assembly
...................·............................402 Service Squadron Tool Kir Assembly
...................................................403 Major Overhaul Tool Kit Assembly
....................................................404

lV RESTRICT[;D I

/



### J -_,/, Section I I RESTRICTED AN Ol-20EG-4 Group Assembly Parts List WING


## /'**j~** / 

# --**:~>/** 

### / 

### \.--=-:---**Fiqur~** 6 Index No.

24-1

2

3

4

5

48 / /

Pdrt Number

15-10390 15-10390-1 15-10391 15-10391-1 

### /

. 15-13711 15-13711-1 2Fl-6-2S31 2F1-6-2831-l 2F1-6-72-t1 2F1-6-7241-I 15-10392 15-10392-1 15-13712 15-13412-1 2FJ-6-2832 2Fl-6-2832-I 2F1-6-7242 2FI-6-7242-1 15-10393 !5-10393-1 J!i-n713 15-13713-1 2FI-6-28.13 2Fl-6-2B:!3-l 2Fl-6-7243 2Fl-6-7:!-t:J-l 15-103!)-l !5-JOJ!l-l-1 15-13714 1:'>-13714-1 2Fl-6-2S.14 2FJ-G<!S:I4-1 2Fl-G-72·H 2Fl-6-72-l<l-1 1:'>-10.1!•5**15~10J!l:'>-l** 15-13715 !!'>-J:!71 !i-1 2Fl-6-26:15 2**~-1-G<!I->:15-1** 2Fl-ti-7:!45 2Fl-ii-7:!45-l 15-lft,!Hi tS-Jtl:l!u:-t 1!'>-1:1716 ' 15-13716-1 Figure 24-Wing Fuel Tanks Wing Fuel Tanks 1234567 Nomenclature Wing Fuel Tanks
..______ ..._..._..._.._.....__ ·-_.-·---·__ ._-------:___ --------------

Installation--outboard winlt tank <LH>. _. __ ..._-------- ---·.__ ---------- _--- _------ Installation--outboard wins tank <RHl.:
.........._...__ . _..___ . _. _. ___ •_________ •_

Tank Assembly-Outboud wing fuel <LHL.:
............-------------------------- Tank Assembly--0utboard wing !uel <RH>
..._____ . __ ....._____ ------------- _____ _ Tank Assembly-Outboard -.,·ing fuel (LH)
....._.._____ ...______ . _____________ •.__ _**T~:n~(ilr>bl~~~-~~~r~. ~~i~-g** **t~_e_'_ ~<:~>_-_** **~:::::::::** ::::::::·:::::::::::::::::::::**:gg~** 

### l!m**~g~~~~~:n:::::::::::::::::::**

### ::::::::::::::::::::::::::::::::·:::::::

Tank <RHl <Goodye:>.rl.
................._. _. ___ .. -------.__ -------- ______ . ------ Tank Assembly--outboard u·ing fuel**<LH>-----····-------------------~------------** Tank Assembly-Outboard wing fuel <RHl
..._.._______________ . _________________ _ Tank Assembly-Outboard wing fl.iel (LH)
......___ . ________ . ___ . ____ ..________ .__ _ Tank Assembly-outboard wing fuel (RHl_. _..._______ ...__ ...._____ ------ ______ .

Tank (LHl**<Good~·earJ.** .......__ . _.......__ . _...__ . _..._.._____________________ _ Tank (RHl <Goodyear)
......_. ___ . ____ . ______ ....___ ._____ . ___ . ___ . _. _________ _ Tank !LH) !Good)·cnr)_
......._. ______ :._____ . -------- ___ .________ . ___________ . _ Tank CRHl <Goodn"rl.
......_....___ .....__ . ___ . _, ______ . ___ ..______ . ___ . _____ _ Tank**!l.ssembly--0utboa~d** wing fuel (LH).
____ ..__ .._.....__ . ------- ___ . __________ Tank !l.ssembly-Outhoarcl•.vinl: fuel <RHl
... --------····------------------------- Tank**Ass~mbly-Outboacd win~;**  iuel <LHl.
..._. __ ....._.._____ . _..___ ..__ . _. _____ _ Tank Assemb!)·-Outbc:trd wing fuel tRH>-
____ .....__ ...._..__ . __ . ______ . _______ .

Tank CLHJ !Good)·earl ·····--······-------------------------------------------- Tank (RHl !Gool.ln:\rl

--------------------------------------------------------- Tank fLHl**(tiocd~'e<!r)** ... ------·······-·····--·-------------------------------- Tank !RH)**((joodl'~.u)** .... ···-·········--------------------------------------·- Tnnk**Ass~m**b!)·-outboard wing !uel (LP.l
....__ .........._.,. _. _. ____ ......___ . _. __ Tank**As~cmbly-Outl>o.trLl** wing fuel CR!Il
..._.........._..._......._. ___ ..______ _ Tank Assembly-Outhoard wing iuel <LH>---··-···-···········-------·····------- Tank**As~crnbil·-Outbo:ud** "·ing tuel <RIO
......._.._._ ..._..._.._..........__ . __ _

Tank (LH> <Goortl'Carl
........_....__ ..___________ ------· ---------------- _______ Tank (HI{) (Gooiln•arl.
.............................................------------ Tank <LHJ ({i<HHI>ear).
.... ····· ..................................--------------- Tank !RHI <Goortno.rl
.............. ----------------------------------------- Tank Assemhly-Outboard "·inJ: fuel fLHl
.......... ··----------------------------- Tank Assembly-Outhnard winR**iu~l** <RHl
................._...._.....__ ...._. _. __ Tank**As~embl;---Outhnard** win.: iuel (L!IJ
....---··········--·······--------------- Tank**A~st•m**biY-Outl>nan!**win~;** iuel <RH).
_...._.. _. ............._......._. _..__ _

Tank !LIIJ ((;oori)·ear)
......... ·-------------------------------------------- Tank tH.H> {(ioo(l:;t·a!'")

_ ..... -----------------------------·------------- Tank (Lll>**((i,Jt~tb·,·;...r)** . --------------------------------------- Tank lfHII ((;<><•·l.,·•·arJ
.. . ... . ..........................----···-------- Tank A!-l;o;cruhl:t-Out:ward·.\·in.'!: iucl (Lll>
...............-----------------------··· Tank AS!'t't:thh·-(iutbn;lrd win.t!: fu<'l ntH)
--------------- Tunk
.**.o\~:-:cruhly-Outt,•,ard** winJ.: tud (LH>
__ . _...._______ . ______ ...._ Tunk**Assembly-()u~hoan!** win.: ful'l IKH)..
. ....... ·············-------------- RESTRICTED Us.aqe Code All All CD CD LQ LQ CD CD LQ LQ CD CD LQ LQ CD CD LQ LQ CD CD LQ LQ CD CD LQ LQ CD CD LQ LQ CD CD LQ LQ CD CD LQ LQ CD CD LQ LQ CD CD LQ LQ C-ll•l

Units Per Assy. NP NP

I 1 1 1 1 I 1 1 1 I I 1 I 1 I 1 I I I 1 I I 1 1 I I 1 I I 1 I I I I I 1 1 I I I 1 I I 1 I l

\

### -~**Fiqur~** &**lnd~x** No. 24-6
7 8 9 IO 11 I2 I3 14

I5

IG

I7
I8 

## g
2I 22 23 24. 25

26

27

28
29 30 3I 32 33 34 35 36 37 38 39 40 41 42 4:1 Part Number 2Fl-6-2S.16 2Fl-G-2S36-1 2Fl-6-7246 !!Fl-6-7246-1 1-27173 1-27173-1 3-13613-12 1-20016 6-13153 6-13153-1 3-9351 3-19046 3-!9030 3-20757-7 3-20757-3 15-103!>0-2 15-10390-3 15-10400 15-10400-1 15-3097 15-3097-1 15-13717 15-1:3717-1 2Fl-6-2S37 2Fl-6-2S37-1 2Fl-6-7247 2Fl-6-724i-1 15-10398 15-10398-1 15-13718 15-13718-1 2Fl-6-2838 2Fl-6-2838-1 2Fl-5-7248 2F1-G-7248-1 15-10399 15-1039!>-1 15-13719 15-137Hl-1 2F1-6-2839 2F1-6-2839-1 2Fl-6-7249 2Fl-6-7::!49-l 1-12713-1**~-H~!~-11** 4-'-VV..I.U 6-13153 6-13153-1 3-9351 3-19046 3-19030 3-20757-7 15-10400-2 15-10400-3 15-10408 15-10408-1 9-5327 9-5327-1 15-13050 15-13050-! 2F1-6-3602 2F1-6-3602-l 2F1-6-7153 2F1-6-7153-l 9-3769 9-3769-1 15-13049 15-13049-1 2F1-6-l426 2F1-6-!426-1 2F1-G-7154 2F1-&-7154-1 9-5326 9-5326-1 15-13048 15-13048-1 2F1-6-3G03 2Fl-6-3G03-1 2Fl-G-7152 2Fl-G-7152-1 6-14061 6-l4Q(j1-l 6-14061-2 3-9287 1-20016 3-13Gl3-13 3-!3613-12 3-l:lGU-11 3-20757 3-20757-1 3-20757-2 3-!lJal AN884-I0-84**15-70"~!1-!1** 15-IWOl!-6**ANS~-I0-80** 15-llJ.IIIS-J**15-71T~!I-)6** 15-11408-2 15-7fT.!!J-18 ANS.'I1-l<,-n**15-7Cr.!~•-!•** 15-7!T.!!I-ll RESTRICTED AN Ol-20EG-4 Section ll Group Assembly Ports List WING Wing Fuel Tanks 234567 Nomenclature-**Usaq~** Unjts Code Per Assy. Tank CLH> <Goodyear)
.._....__ . ___ ------- ____ . _________ ...____________________ _ Tank CRH> CGoodnar)
... _..........___ ..______ . ___ ........___ ........._. _...__ . Tank C LHJ CGood.;-ear>
...._. _. ______ . ____ ..__ .._ .___ .._.______ . ________ ._____ .__ Tank CRH> <GoodYe«rl._. ___ ...____________________________________________ _ Tube-Interconnector..
. . __ .....__ . _..._...._.__ . ________ . _____________________ _ Tube-Intcrconnector.
.. _____ . ______ . _____________ ..___ . ____ . __ .._______________ _ Nut Assembly-Tank tiller unit
.._________________________________ .._____________ . Gtisket-Annular.
_... __ ........_____________ ------- ___ ------------------- __ ..__ _ Adapter Assembly-Q;·crtlow CLR).
_______________ .._____________________ . ________ _ Adapter Assembly-Q;·errtow CRH>-
.. ___ . _...___· ____ ..._______ . ___________________ Clamp Assembly-Q;·errtow pan adapter.
...________ ..___ .......__ ......__ . __ ._._ Adapter-0>err\ow pan..................--------------- __________ ----- _________ _ Pan Assembly-Fuel tank·ovenlov.-.
______ . ___ . ___ ..______ . _.___________________ . Cap .4.ssemblY-Filler ur.it.
....._._..______ ------ _______ . _______________________ . _ Cap Assembl:.·-Filler unit
..__ . ______ --------------------------- ______ . ______ ._. __ Tube (o>errtov: drain> CLH)
.___ ........______ . ____ --------- .._____ . _______ .. _____ _ Tube coverrto,.· drain) <RH>.....
. ...._. _. ____ . _. _._______**~** ...___ . _....._._.______ _ Installation-Inboard wing tank CLH)
....________________ ..______________ . _________ _ Install:ttion-Int:<Jard ,.-ing rank CRH>.
..________ . ______________ . ______________ . ____ _

Tank Assernbly-In!:Joard wing fuel CLH)._. _..___ . __ ...._____ . _.......___ . _______ _ Tank Assembly-Inboard wing tuel CRH)
..______________ . __________ .._____ . ______ _ Tan:< Assembly-Outboard wing iuel (LH)
.....____ -------.------- _.. , ..._________ _ Tank Asse:nhly-Qutboard wing iuel CRH)
.. _._____ ...._________ . ___ ..__ . ___ . ____ _

Tank CLH) <Goodyear)
..________________ ..________________ .._______________ .___ _ Tank CRH) <Goodyear)._.
__ ....__ . __ . ______ . __ ..___________ ._._.____________ . __ _ Tank (LH) <Good:.-ear).
.....__ . _________________________________________________ Tank CRHl <Goodyear)
......._... _________________ ..._______ . __________________ _ Tank Assembly-Inboard wi!1g fuel <LHL
.._. ___ ..__ . ____ .._. _____ . _. __ . _....____ _ Tank Assembly-Inboard wing fuel CRHL
________________________________________ _ Tank Assembly-Outboard wing fuel CLH>-----
___ . _____ ------ ____ ..___ ..._. ___ ..._ Tank Assembly-outboard wing fuel (RH).
__________ ....________________ ._______ _

Tank CLHJ <Goodyear)
..................._.__ .._..._..___ ........___ ..._..._..._ Tank <RH) (Gooct:.-ear>-
_...____ ----- __ ------- __ --------------- _________________ _ Tank CLHl <Goodyear)
...._...._____________ ------- ..__________________________ _ Tank CRHJ <Goodyear>.
___________________ . __ . _________ . ________________________ Tank Assembl:.--In!:>oard wing fuel (LHL
____________ ------- _____________________ _ Tank Assembly-inboard '''in;; fuel CRHJ.
___ . ________ ..__ ----- _______ ..____ . _____ _ Tank Assembly-Qutboard wing fuel CLHL
....___ ...____ .._. ______________________ Tank Assembly-Qutboard wing fuel CRH)
..__________________________. ___________ _ Tank <LH> <Goodyear)
..... ____ .----- __________ ------ _____________ ----- ___ ..___ _ Tank CRHJ (Goodyear).
.............__ .....____________ ..___ . __ .._______ . _______ Tank CLH> (Goodyear>._
...._._ ......__ ._ ..____ ..______________________________ _ Tank (RH) (Good:;ear)
....._.._...__ ....._.....__ ....___ ...__ . __ ..__ ...________ _ Tube-Interconnecror
.....___ ...._______ . _____ . ______ . _____ .._. _________________ _

### ~~i<~i~Tr~r~~-:_;~n-~ tiller_un1t

### ~: ::::::::::::::::::::::::::::::::::::::::::::::::: Adapter Assembiy-Overtlow CLHL
........__ . , _____ ....__ ----- ______ . _____________ Adapter Assemb!Y-Over!low <RH>----
..__ ...____ .._____ . ______ ....___ . _____ . _...__

Clamp Assemb!Y-Overrtow pan adapter
..________ . _______ . __ . ____________ ....__ _**Adapter-Over~0"-** pan...._____ .._____ ..__________ . ____________________________ _ Pan Assemblr-Fuel tlil!k overflow
.........__ .______ . __________________________ _ Cap Assembly-Fil!er unit.
..______ ..._.....___**.-------------------~--------_.** ___ _ Tube (overflow drain) <LH>.
__ ......_________ --------------- __ . ____ . ---- ___ .....__ Tube (overflow drain) (RHL
......__ ....__ ....------------- ...______ ..______ . _.___ _ Installation-Wing**fu~l** tank CLHL
_____ . _____ . ______ -------- _________ . ____ . _____ . _. Installation-Wing ft.:el tank <RHL
.. _. _____ . _____ .•: _______________________________

Tank Assernbi:.·-En;:ine no. I fuel..
__ -·--- ....___ -------.___ ..____ . _______________ Tank**AssemblY-En~::ne** no. 4 fuel.
_________________________ ..___________________ _ Tank Assembly-Engine no. 1 fuel.
.._. ___ . ________ .._____ . ______________________ _ Tank AssemblY-Engine no. 4 fuel._.
____ .._. ________ ...------ ___________________ _

Tank CLH> (Goodnar).
..._. __ . ___ . ___ ..___ ..------------ ..._____ .._________ .__ _ Tank CRH> (Goodyear)_._
.._. ____ ...._. ___ ... ____ ....____ ..._. ___ ......__ . __ . __ _ Tank CLH> CGood;-ear).
..._....__ ...........__ ..---- ...............---- ......... Tank CRH> <Goodyear)
..__ ._.__ ...__________________________ . __ .._. ________ .... . Tank Assembly-Engine no. 2 fuel.
_...._..._..........._...._....._._..._..- ...._ Tank Assembll:-Eng!ne no. 3 fuel..
______ . __ ._____ ----- ___ .....___ ..__ ----- _____ _ Tank Assembly-Engine no. 2 fuel
..._____ ._.______ ....____ .._____________________ Tank Assembly-Engine no. 3 fuel.
...____ . ______ . _.___ .._.____ ._..__ ._._._. _...__

Tank CLH) (Goodyear)
....._. ____ ....._____ . ___ ..........------- ___ ----- ___ ... __ Tank <RH> CGood;-ear)
......_..._...___ .._..____ ....._____ ....___ ....___________ Tank (LH) (Goodyear)
...._____ ..___ ..__________ . ___________ ------.______ ._ ..... Tank CRH> (Goodnar)
........._. _. __ . ----- ________ . __ ..____ .....__ ---- ... _...__ Tank Assembly-Fuel ieeder CLH)
......__ ..........................-- ..____ .- ..... Tank Assembly-Fuel feeder CRH>.
...____ . ___________________ :_____ ..____________ _ Tank Assembly-Fuel feeder CLH>-----
____________ . ____________ ---. ________ . ____ .. Tank Assembly-Fuel iceder <RH)
....._... _. __ ..___ . __ ..____ . __ . ______ ..______ ..__ _

Tank <LH> <Goodrear>
. _______ . ________________ -------- _______ ----------------. Tank CRH) <Goodnarl..
_________ .._______ . _____ ..._. _____ . _--- __________ . ____ . _ Tank CLH> CGood.vear>. _. __ ......._. ------- ..__ . ---------- ................_ ..... Tank CRHJ <Goodnar>.
. _.. .__ ....___ .._...._................._......._. _ ..... Installation-Tank Iiller cap (eng no. 2 & 3 tank)
... __ ..._.__ ._.-----_.__ . ____ . __ .. Install«tion-Tank tiller cao (eng :10. 1 & 4 tank>-.
_________ . ____________ .._______ _ Installation-Tank tiller rao (fuel feeder tank)._._
.....____ .....___ ..._____ ._ ..__ _

Pan Assembly-Fuel tank overr1ow
___ ..__ ........._.._......._.__ ......._____ .._ Gasket-Annular.. . . _ _ _ __. __ ..__ . _________ .__ . ________ ...____ . _________ ..__ _ Nut Assy-Tank Iiller ur!it <eng no. 2 & 3 tank>---------------------------------- Nut Assy-Tnnk tiller unit**(en~:** no. l &**~** tank)
.._. __ .___ ....._. ___ .._______ . _.._ Nut Assy-Tank f.ller unit (iuel feeder tank)
.......___ .........__ ..____ ... _.___ . Cap Assy-Tank nllcr urtit**(en~:** no. :.! & 3 tank).._
........................__ .._.. Cap**A~s:.•-Tank** tiller unit <eni no. l & 4 t11nk>.
..... ______ ... ______ ------- _. ___ _ Cap Assy-Tank r\ller unit (fuel feeder tank)
......_...._..............._.. - ..... Cl:J.mp**A~sembly-Q;·er~ow** pan adapter
............................: .......__ ..... Hose-Resistunt sntthetic
...._......._................._..._..._........... - ..... Tubc--Overrtow..
. . ....___ . _. __________ . ________ ..._____ . ________________ .__

### ~~~:=-~~~~~~~~·t.**~l;nthetiC**_·: ·

### ~ :::::::::::::::::::::::::::::::::::::::::::::::::::: Tube Asscmhl:.·-OrPrllow CLH). _. _. ....___ ----- __ . ----- ..............__ ....__ Tube-Q;·errlnw <H.II> _ . . . . ___ .__ . _ _ ...._____ .___ . ______ . _______ ..____ .._. _ Tube Asseltthl;--O,·nf1ow CLH)
...._ ...._. _........._.._........._..............- Tuh.,.--Ovcr!lo;o; (!U{). . . . _.. __ . ____ . ___ ... ____ ... _______ •. _. _ ..... _ ... ____ .... . Hose-Resist:mt syllrhetlc.
__ -----._....___ . _.._______ ----- ..__ ..____ .. ----._ .... . Tuhe-Qverrtuw
.. Tuhe--<Jver!low
.. CD I CD I LQ 1 LQ l CD 4 LQ 4 All 1 All 1 All 1 All I All 1 All 1 All I DC 1 00 1 Al: 1 All l All NP All NP CD 1 CD 1 LQ I LQ 1 CD 1 CD 1 LQ 1 LQ I CD I CD 1 LQ 1 LQ I CD 1 CD 1 LQ 1 LQ 1 CD 1 CD I LQ 1 LQ 1 CD I CD l· LQ I LQ 1 All 2 All 1 All 1 All 1 All 1 All I All 1 All 1 All 1 All 1 All 1 All NP All NP ZA I ZA 1 VK 1 VK I ZA 1 ZA 1 VK 1 VK 1 ZA I ZA 1 VK 1 VK 1 ZA I ZA 1 VK I VK 1 ZA I ZA 1 VK 1 VK 1 ZA 1 ZA 1 VK I VK 1 All**~** All NP All !>'P All I All 1 All I All I All 1 All I All I All 1 All 3 All I QB 1 XM I All 1 All 1 All 1 All 1 .All 1 All 1 All I All 1 RESTRICTED 49Section I I RESTRICTED AN 01-20EG-4 Group Assembly Parts List

£jqure 6 Index No. Part Number

19S-I AS55KX AS5S!'<X AR35RX 2 13!lti0-3 3 2Go0 4 TFD!::!OOO 5 NO NU!11BER 6 M44l.M:! UCI070 7 £Al5-10 £Al5\V s £Al5-ll £AI5\V 9**EA15-l~** £Al5W 10 11 ANHOI-I 12 PDl:!H:! IJ RG4-1:10-2 H**~01(;7 I~**  41ll-4A

312 1234567 FUNCTIONAL SYSTEMS

I '' ' ,...::::,.. '--- 2 5 Figure l98-Fuel System Fuel System

Nomenclattue 

### \ 

### \

Fuel System
................ _____ ........__ ....___ ...___ .., .._...__ . ___ . _____ ..____ . __

Valve Assernbl.v-Transfer control ffienison) GF£ (see fiq. Zll
__ ... _. _.._..._. ___ . __ . _ Valve AssemblY-Transfer control <E-5) !Denison) GF£ (see liq. 21)
.................. . Valve Asscmbly-Transfe: cor:trol CD-5J <Denison) GFE (see Sq. 22)
... __ ....._______ _ Strainer**Assen_lbly-T~-~** C--1 L\.ero Supply) (see liq. 23) . _...._. _.. ___ ..___ ..___ . __ .. Vah·c**AssembJ:,·~Fuel** shut-0rf (F:lectnmatit:l (see liq. 23)
.. _.. _.. _........___ ..... __ . Pump Assemhly-Fud t.>noster !Thomosonl (see T.O. O:J-IOEC--1) (see fiq. 23)
____ . _... Tran$mittcr-Pressure n·:.·ne .-\.-1) <Socc :?7;;8:3-Al GFE (see fiq. 23>
. _____ . _. ___ _ Valve**Ass~·-Oil** dilution ;olenoid (Air Assoc.) (see T.O. 03-15-17) (see fiq. 30)
.. __ .•. __ _ Vah·e-Soknoid <Unite<! Aircraft) rsee T.O. O.l-15-24) (see 5 11 • 30)_
..... _......... __ .. . Unit Assembb·-Fuel "ace < LiQuic!omcter> (see fiq. 25)
.._.._.... _...._....___ . __ ..__ Unit Assembly-Fuel**"~<:e** <LiQuinometer) (see fiq. 25).
. . . . __ ...__ ..._...____ ... Unit Assembb•-Fud "a.:e CLiQuidometerJ <•ee liq. 25)
.. _....____ ........_.....____ _ Unit Asst-Jllbb·-Fuel**c~<.:e** <LinUidometer> <••• fiq. 25)
.... __ ......._......_.... ____ .. Unit Assembly-Fuel;::"-"" (Linuid0meter) (see 6q. 25)
... _...... ____ ................ . Unit Assembly-Fuel 

### """t < Liuu•dometerJ (see fiq. 25) •... ____ .. _ ...•... __ .•_ ......•. Winlt Fuel Tanks (soe fig. 24)
. . . .._. · .... _.... _. _. _... _____ .._...__ ...___ ..· Punn>--Powcr driven ful:! CT.voe G-9) GFE (see Sq. 177)
_ _ _ _ .. _..____ ..._..__ Cartmretor (Stromher;:J rrurn!sllcd \\·ith**cn~ine).** . ............................. . Pumn Assembly-Fuel tr"-ll.,fcr <HoP.lCc) (see fiq. 105)
. Valve-Fuel frans. sci**CT:;r,~** PG-4J C.-\.ero Suoply) (see A!-<03-10-39) (oee Sq. 106). Primer .'l.ssy--4 eng lU<:l <Parker) (see ANOJ-lll-:1:!) (aee fiq. 105).

RESTRICTED 

### ' 

### \ 

## \

Usaqe Units Code Per Assy. 0 Ret ££ Ref PJ Ref All Ret All Ret All Ref All Ret RA Ret SJ Ret RF Ref K Ref NG Ret T Ret DG Ret s Ret "-.._.__./ All Ref All Ret All Ref All Ret All Ref

### ' 

# '

... -· 

# AN Ol-20EG-2 HANDBOOK ERECTION AND MAINTENANCE INSTRUCTIONS



## USAF SERIES 

# B-17G

AIRCRAFT

LATEST REVISED PAGE.S SUPERSEDE THE SAME PAGES OF PREVIOUS DATE Insert revised pages into basic publication. Destroy superseded pages.

I'UIIUSHED UNDER AUTHORITY Of THE SECRETARY OF THE AIR FORCE AND THE CHIEF OF THE BUREAU OF AERONAUnCS**--------------~--------** 

## ------

.. ,R FORCE (OPS, OGDEN. UTAH)**~.100** 

## 25 AUGUST 1944 REVISED ! AIIGIIST 191i:l 

# IGOVERNMENT

. 

### i EXHIB.IT 

# 1-:--..;1'",

# '·~·**>~, ,:,~,··** RESTRICTED AN 01-20EG-2 Table of Contents



### TABLE OF CONTENTS Section Page I Description,Dimensions andleading Particulars . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. Description . . . . . . . . . . . . . . . . . . . . . . . . 1 2. Principal Dimensions . . . . . . . . . . . . . . . 1 3. Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 4. Senings and Ranges of Movement of Control Surfaces . . . . . . . . . . . . . . . . . 3 5. landing Gear . . . . . . . . . . . . . . . . . . . . . . 3 6. Engines . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 7. Propeller . . . . . . . . . . . . . . . . . . . . . . . . . . 3 8. Tank Capacities . . . . . . . . . . . . . . . . . . . . 3 II Shipment and Erection Procedure. . . . . . . . . 5 1. Shipment of Aircraft . . . . . . . . . . . . . . . 5 2. Erection Procedure . . . . . . . . . . . . . . . . . 5 _III Handlingand GeneralMaintenance Instructions . . . . . . . . . . . . . . . . . . . . . . . . . 9 1. Access a.nd Inspection Provisions. . . . . . 9 2. Ground Handling . . . . . . . . . . . . . . . . . . 9 3. Ground Operating Instructions.
. . . . . . 38 IV Major Component Parts and Installations.
. 54 1. General
. . . . . . . . . . . . . . . . . . . . . . . . . . . 54 a. Scope
. . . . . . . . . . . . . . . . . . . . . . . . . . 54 b. TaperPinJoints.
. . . . . . . . . . . . . . . . . 54 c. Skin Patches and Stringer Splices.
. . 54 2. WingGroup....................... 54 a. General
. . . . . . . . . . . . . . . . . . . . . . . . . 54 b. Inboard Wing Panel.
. . . . . . . . . . . . . 58 c. OutboardWing-Panel..........
. . . 59 d. Wing Tips
. . . . . . . . . . . . . . . . . . . . . . 63 e. Ailerons
. . . . . . . . . . . . . . . . . . . . . . . . 63 

### f. Wing Flaps
. . . . . . . . . . . . . . . . . . . . . 64 3. Empennage (Tail Group)
. . . . . . . . . . . . 65 a. General
. . . . . . . . . . . . . . . . . . . . . . . . . 65 b. Horizontal Stabilizer
. . . . . . . . . . . . . 67 c. Elevator
. . . . . . . . . . . . . . . . . . . . . . . . 68 d. Vertical Fin
. . . . . . . . . . . . . . . . . . . . . 68 e. Rudder .· . . . . . . . . . . . . . . . . . . . . . . . . 69 

### f. Elevator Trim Tab
. . . . . . . . . . . . . . . 70 4. Fuselage
. . . . . . . . . . . . . . . . . . . . . . . . . . . 70 a. General
. . . . . . . . . . . . . . . . . . . . . . . . . 70 b. Removal and Disassembly.
. . . . . . . . 75 c. Replacements
. . . . . . . . . . . . . . . . . . . 77 d. Adjustments
.....·.. . . . . . . . . . . . . . . 80 5. landing Gear
. . . . . . . . . . . . . . . . . . . . . . 82 a. Main landing Gear. , . . . . . . . . . . . . . 82 b. Tail Gear Installation............. 95 6. PowerPlantGroup
.................. 101 a. Engine and Accessories
............ 101 b. Trouble Shooting
......... : . . . . . . 113 c. ReplacementofPartsand Minor Repair
. . . . . . . . . . . . . . . . . 116 Section Page d. Adjustments
.................... 131 e. Removal, Disassembly, Assembly, and Installation of Complete

Engine Section.
. . . . . . . . . . . . . . 132 

### f. Exhaust, Air Induction and Turbo Systems
....................... 140 g. Power PlantControls
. . . . . . . . . . . . . 154 h. PropellerSystem
. . . . . . . . . . . . . . . . . 171 '· Starting System
. . . . . . . . . . . . . . . . . . 177 j. Cowling
. . . . . . . . . . . . . . . . . . . . . . . . 182 k. Oil System
. . . . . . . . . . . . . . . . . . . . . . 187 l. Fuel System
..... : . . . . . . . . . . . . . . . 193 7. Fixed Equipment Group
............. 207 a. Instruments and Instrument Panels. 207 b. SurfaceControl Systems
. . . . . . . . . . . 220 c. Hydraulic System
................ 253 d. ElectricalSystem
................. 271 e. Communications Equipment
...... 318 

### f. Fuselage Furnishings
. . . . . . . . . . . . . 332 g. Heatingand VentilatingEquipment. 341 h. Deicer and Anti-icer Equipment.
. . . 347 1. Oxygen Equipment
. . . . . . . . . . . . . . . 354 1· Photographic Equipment
......... 357 k. Pyrotechnic Equipment
........... 357 l. Bombing Equipment
............. 357 m. GunneryEquipment
.............. 378 V Useful orMilitary load.
. . . . . . . . . . . . . . . . . 407 1. Bomb loading
..................... 407 2. Ammunition loading
.............. 407 VI MaterialsofConstruction
. . . . . . . . . . . . . . . . 416 VII Finish
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 419 1. Cleaning and Inspection
............. 419 2. Refinishing
........................ 421 VIII Tubing Chart
...........................428 1. General
. . . . . . . . . . . . . . . . . . . . . . . . . . . 428 2. Tubing Identification
. . . . . . . . . . . . . . . 428 3. Tube Sizes and Lengths
. . . . . . . . . . . . . . 428 4. Tube Template
. . . . . . . . . . . . . . . . . . . . 428 5. Tube Cutting
. . . . . . . . . . . . . . . . . . . . . . 429 6. Tube Bending.
. . . . . . . . . . . . . . . . . . . . . 429 7. Flared Tube End
. . . . . . . . . . . . . . . . . . . 429 8. Installing a Tube
. . . . . . . . . . . . . . . . . . . 430 9. Tube leaks and Failures; Causes, Remedies, and Prevention
......... 430 10. TubingMaterial
.................... 431 IX Charts and Tables
...................... 432 1. Manufacturer's Flexible Cable Chart.
. . 432 2. WrenchTorqueValvesfor-Bolts and Nuts
. . . . . . . . . . . . . . . . . . . . . . . . . . 432 X Service Inspections
. . . . . . . . . . . . . . . . . . . . . 441 Alphabetical Index
........................... 514 RESTRICTEDRESTRICTED AN 0.1-20EG-2 Section IV Paragraph 6

--------SPRING (PISTON RETURN)

PILOT VALVE MUff FLOW POSITION (SHUn£R CLOSED) VALVE UNDER HIGH PRESSURE-LOW TEMPERATURE

PILOT VAlVE 

# ADJUSTINGAI!M(Sf-METAlElfMENn

RELIEF

# VALVE

# :S:S:EM~S:LY~-:~:~~~~:=====rr::~~~;~;~~~=~~~!~~~= OIL PASSAGE (PILOT VALVE TO PISTON) BLEED PORTS

CORE FLOW POSITION (SHUnER OPEN) VALVE UNDER LOW PRESSURE-REGULATING TEMPERATURE Figure 198-0il Temperature Regulator Valve solder flow. If concentrated hydrochloric acid is used, flush it off as soon as practical. Test the oil temperature regulator again as in paragraph 2. 4. FINAL TREATMENT.-Afrer final testing, flush all the oil coolers inside and out with hot running water and then steam for 1/2 hour, aflowing the condensate to leave from the bottom of the regulator. Thoroughly dry the oil cooler by heating it in an oven for approximately one hour at 12l-l35°C {250- 2750F) until all moisture has evaporated and then reinstall oil temperature regulator. If an oven is not available or if storage of the oil cooler is desired, perform a hot oil treatment to remove moisture and give corrosion protective oil coating in accordance with following instructions: a. Immerse the oil cooler in a tank of clean, light, neutral lubricating oil (SAE 20), Federal Specification No. VV-0-496, at approximately 121°C (250°F) and shake the oil cooler until all bubbling ceases, indicating that the water has completelyevaporated and the

.oil coating is complete. b. Drain the oil cooler and then either reinstall it on the airplane or place in stock. (c) ADJUSTMENTS.-See figure 198. (d) ASSEMBLY AND INST ALLATION.-Reverse the removal procedure. h. FUEL SYSTEM. (1) GENERAL-The fuel system is composed of four independent fuel supplies, each feeding one engine. Each outboard engine is fed from a 425 U. S. (354 Imperial) gallon tank and each inboard engine is fed from a 213 U. S. (177.4 Imperial) gallon tank having in addition a feeder tank of 212 U. S. (176.6 Imperial) gallons, making 425 gallons for each engine. B-17G airplanes have a supplemental fuel supply carried in collapsible self-sealing fuel cells installed in the wing between the ribs outboard of the existing maio tanks. The installation includes nine cells with permanent aromatic resistant liners in each wing, providing additionaJ capacity of approximately 1,080 gallons or an increase of 270 gallons per engine. Thecells ineach wing are divided into two groups,each of which acts.as a feeder tank for one of the main tanks. Thefour inboardcellstie intothefeeder tanksthrougha 1-1/4-ioch inside diameter self-sealing hose and an E-5 orD-5 valve. This valve is controlled from the rear bulkhead of the bomb bay compartment or the forward bulkhead of the radio compartment: by a self-contained hydraulic system. When the valve is OFF, accidental loss ofhydraulic fluid or pressure will cause the valve to open, permitting delivery of fuel from the outer wing tanks. The five outboard cells are provided with a similar connection to the engine No. 1 and No. 4 tanks. Venting is accomplished by interconnecting the outRESTRICTED 193Section IV Paragraph 6

TANK CAPACITIES
TANKS
NO. I & < ENGINE NO. 2 & 3 ENGINE FEEDER OUTBD. WING 1·5(TOTAl) INIID. WING 6-9 (TOTAl) TOTAl FUEl (OVERlOAD) 80MB BAY EXTRA TOTAl fUEl (SPECIAl) 425 213 717 270 270 <10 H< 177 177 225 225 341 850 708 •26 35• •H 35< HO •so 5<0 450 2780 2316 820 682 3600 2998 RESTRICTED AN 01-20EG-2

UNE SYMIIOU FUEl fEED AND TRANSfER liNES 

### ============> DRAIN AND Vl'NT LINES

----------- ENGINE PRESSURE PRIMER AND BAlANCE LINES 

### --=--o--=--=--=--=---=- HYDRAUliC liNES -=-=--=-=-.,_oc:o Oil DilUTION AND fUEl PRESSURE TRANSMimR liNES**~-----** ---- ElECTRICAl CONNECTIONS LINE SIUS FUEl PUMP TO CARBURETOR FEEDER TANK TO NO.2-& 3 ENGINE TANK OUTBD. WING TANKS 1·5 TO NO. I & 4 ENGINE TANK INIID. WING TANKS 6-9 TO FEEDER TANK 3/4" I. D. I 1/•" I. D. 1 1/•· 1. D.

, l/4· 1. D. VENT TANK NO.8 TO TANK NO.9 fEEDER TO 2 & 3 3/4" ·1. D. VENT liNES NO. 1 & 6 TANKS TO UNDER SIDE OF WING 1 1/ • • 0.D. VENT liNES ENGINE 1 & 4 TANKS TO NO. I TANK 1. 0. D. FEEDER IANK TO NO. 6 TANK I· 0. D. VENT INIERCONNECTORS TANKS NO. 1-9 1 V•• 0. D. PRIMER PRESSURE liNES 1/•· 0. D. FUEl VAPOR REMOVAl liNES 1/4" 0. D. All OTHER liNES I" I. D. Figure 199-Fuel System Diagram SWITCH

CONTROl CABIN

REAR DOOR

A-NO. I & 4 ENGINE TANK 8-NO. 7 & 3 ENGINE TANK (-FEEDER TANK D-BOOSTER PUMP E-FUEl STRAINER f -ENGINE fUEl PUMP G-fUEl PRESSURE TRANSMmER H-Oil DilUTION VAlVI' 1-CARSURETOR J-FUEl TRANSfER SElECT VAlVE K-TRA.NSFER PUMP l-BOMB BAY FUEl TANK M-PRIMER N-RESTRICTION FITTING 0-TANK VENT5-UNDER SIDE Of WING P-FUEl SHUT-OfF VAlVI' 0-TANK FillER NECK R-Oll DRAIN COCK ASSY. S-DRAIN COCK T-OIJTBD. WING TANKS NO. 1- 6 U-INBD. WING TANKS NO. 7-9 V-VAlVE-TRANSfERSERIES A W-CONTROl-REMOTE MANUAl X-SYlPHON Y-IANKDRAIN VAlVE Z-FUEl QUANTITY GAGE 7-llf

board cells in each group at their forward ends by internal hoses and connecting these outboard cellgroup vents ro the line from the corresponding inboard tank. Venting is accomplished by interconnecting the outboard cells in each group at their forward ends by internal hoses and connecting these outboard cell group vents co the line from the corresponding inboard tank. The vent lines then pass from the most outboard cell of each group to the vent manifo1& Two additional filler necks are provided, one at the most outboard tank for filling the outboard cell group, and one at the first cell inboard of the station· 19,_(dl. The filler caps for thE outboard cells are sealed with copper asbestos gaskets against the upper wing surface, while the filler pans are so vented through the bottom of the wing as to provide a ram during flight. These vents also act as filler pan drains during replenishing operations. This vent-drain arrangement eliminates the possibility of fuel loss during flight maneuvers. A wing nut, bolt, gasket, and spring, which, when tightened, will cause a positive pressure seal between the neoprene gasket in the cap and the filler neck flange, are installed at the main tank filler caps to prevent fuel loss due to the static pressure head created by fuel in the outboard cells. To.further increase the fuel supply, two tanks of 410 gallons each are suspended in the bomb bay. These tanks are· releasable in the same manner as bombs, when the switches in the bomb bay**a~e** on. All fuel feed lines, transfer lines, and vent lines arc of self-sealing or leakproof construction, and are designed to accommodate aromatic fuels. The primer, vapor removal and balance lines are aluminum tubing, while the oil dilution line 194 RESTRICTED 

# (

((

\



## ( \• OUTBOARD OUT£-. WING TANKS

... INBOARD OUTE!It WING TAN.C:S 8B CHECK YALYE ION SOME AIRPLANES, AAROW INOtCATES FLOW)



## * RESTRICTED AN 01-20EG-2

tQOKIH' AfT Section IV

7-320

NOTES: DIRECT TRANSFER CAN ONLY BE MADE ACROSS CENTERLINE OF AIRPLANE. DOTTED LINES INDICATE FUEL FLOW IN INSTALLATIONS WITHOUT CHECK VALVES, PERMITTING FUEL TRANSFER TO OUTER. WING TANKS.

DESIRED TRANSFER

LEFT HAND TO RIGHT HAND TANK**~** FROM LEFT HANO BOMB BAY TO ENGINE NO. 4 TANK

LEFT HAND TO LEFT HAND TANK I TwO TRANSFERS REQUIRED)

FROM LEFT HAND BOMB BAY TO ENGINE NO. I TANK BY WAY Of RIGHT HANO BOMB BAY TANK

RIGHT HAND TO LEFT HAND TANK**~** FROM RIGHT HAND BoMB BAY TO ENGINE NO. 2 TANK

RIGHT HAND TO RIGHT HAH0 TANK I TWO TRANSFERS REQUIRED)

fROM ENGINE NO. 3· TO ENGINE NO. 4 TANK BY WAY OF ENGINE NO. I TANK R.H. VALVE SWITCH L.H. VALVE FLOW PATTERN OPERATION OF CONTROLS

Figure 200-Fuel Transfer Operation Diagram RESTRICTED 195Section IV Paragraph 6 RESTRICTED

.AN 01-20EG-2

Figure 20J-Fuel Transfer Units Installed is copper. In disconnecting any fuel line it is recommended that the open ends be securely plugged to eliminate the entrance of foreign matter. In removing the leakproof hoses from metallic conneccors it is mandatory that the hoses be protected from damage due to rough handling. Disassembly of any of the units comprising the fuel system will not be artempted without the approval of the resident engineering officer, or without access to pertinent Technical Orders. In the absence of either of the above sources of information, the unit should be removed from the airplane and referred to the proper repair depot. Electric driven fuel booster pumps are installed at the outlets of the main tanks to eliminate vapor lock between the tanks and the engine fuel pumps. An electrically controlled fuel shut-off valve is installed in the line after the fuel booster pump to prevent fuel loss through a severed gasoline line. From the shut-off valve the fuel passes through a strainer located on the forward side of the fire wall and enters the engine-driven fuel pump. Fuel may be transferred from one main tank to another by the fuel transfer system which consists of two selector valves and an electrical transfer pump. For further Information see figure 200. (2) TANKS.

(a) GENERAL.-The mam fuel tanks and the feeder tanks are retained by heavy metal straps riveted to the spars and the upper wing surface. These tank supporting straps are formed aluminum-alloy channel sections with neoprene pads and are held in place by bolts at either end. No. 1 and No. 4 main tanks are located between rib stations 6 and 12, directly behind the front spar in the left- and right-hand wings. No. 2 and No. 3 main tanks are located between rib stations 1 and 4, between the spars in the right and left wings. The feeder tanks for the No. 2 and No. 3 main tanks are located between rib stations 6 and 12 directly in front of the rear spar. The outer wing tanks are comprised of self-sealing cells placed between wing ribs outboard of main tanks. These cells are interconnected to act as four units. The outboard group of outer wing tanks is 1 comprised of the five outermost cells located between ( rib stations 20 and 25. The inboard is comprised of · the four inboard cells located between rib stations 16 and 20. Two auxiliary tanks may be hung in the bomb bay by slings which are attached with type B-7 bomb shackles. These tanks are releaseable in the same manner as bombs. Westinghouse metallic leakproof bomb bay tanks may be used interchangeably with Goodyear and U. S. Rubber non-metallic leakproof tanks. All tanks are self..sealing and carefully bonded to the structure. The outer wing tanks rest on micarta abrasion strips on the lower wing surface, and being collapsible, have their upper portions tied secure to the adjacent wing ribs with scout cotton cord. 1. 

### A small drain valve· is provided on the bottom of the feeder tanks and each outboard engine tank. This valve is attached ro the leakproof liner, and consequently must be operated with extreme care. 2. The bomb bay tanks are of non-metallic leakproof construction. Two types may be installed interchangeably; the Goodyear Rubber Co. type, constructed of a non-metallic shell with an integral rubber

Figure 202-Fue/ Tank Installation-Inboard 

### ( 

# '



# (

196 RESTRICTEDRESTRICTED AN 01-20EG-2 Section IV Paragraph 6

TOP VIEW BOTTOM VIEW

Figure 203-Fuel Tank-Inboard lining, and the U. S. Rubber Co. type, constructed of a non-metallic shell with a replaceable leakproof bag. (b) REMOVAL AND DISASSEMBLY. 1. MAIN TANKS.

a. There are three removable panels in the bottom of each wing for access to the fuel tanks. These panels are held in place by washer head screws and gang nuts riveted inside the door frames. Since the skin is subjected to structural loads, it is necessary toplacejacks at the outboard nacelles to relieve torsional stresses before removing the tank doors. Before attempting to remove a fuel tank, booster pump, or any other electrical mechanism associated with the fuel system, make sure that the airplane master switch, battery switches, and external power are "OFF," and that the airplane is completely grounded. 

### WARNING The mechanic must repeatedly make contact with the airplane structure AWAY from possible gasoline or fumes tO be certain that his electrical potential remains the same as that of the airplane. It is possible that static charges will exist in the airplane or in his body which may ignite thega.Soline fumes. This is very important when outside temperatures are around -6.7°C (20°F) or below, as the fuel is very explosive in these temperature ranges. the outboard nacelle jack pads. Remove the tank access doors, fuel lines, and electrical connections to booster pumps. Remove the booster pumps, all electrical bonding, and theremaining fuel lines. Removetheliquidometer fuel transmitter gage before attempting to remove tanks rrom wing. · c. In removingengine No. 1 andengineNo. 4 tanks and engineNo. 2 and engineNo. 3 feedertanks, remove the tauk straps and support the outboard end of the tank on the wing structure. Lower the inboard end far enough to permit disconnecting all vent and vaporremoval lines atthetopoutboard end ofthe tank; then lower the tank. Follow the same procedure for removal of engine No. 2 and engine No. 3 tanks exceptthe forward endofthetankshouldbesupportedon thewingstructureand theaftend lowered·farenoughto disconnect the vent and vapor removal lines. Connections are made between the outer wing tanks and the main and feeder tanks through an access door located aft of the rear spar just outboard of the outboard nacelle. 2. OUTBOARD WING TANKS (TOKYO TANKS).-To remove the outer wing tank cells, first remove the outer wing panel (refer to section IV, paragraph 2. b.) and detach the leading edge. Disconnect all fuel lines and bonding on both fore-and-aft ends of cells tO be removed. (Cells must be withdrawn successively.) Remove the round access doors in the forward ends of the cells and remove the cell interconnecrors. Untie the cords which secure the cells to the upper part of the wing ribs. Collapse the cells in paper bag fashion and tie securely. A pair of one-inch web scraps about five or six feet long wil! prove very useful for chis operation. Do not attempt to collapse the cells while they are cold and stiff. Remove the cells through the ribs, being very careful not to damage the cells on sharp edges chat may exist within the wing. It is not recommended that cells be removed through a tank bay, but chis method can be resorted co in an emergency where nocradles for the outer wings are available.

b. Drain fuel tanks and place jacks under Figure 204-FuefTank Installation-Outboard RESTRICTED 197Section IV Paragraph 6 RESTRICTED AN 01-20EG-2

TOP VIEW

; .

.BOOSTER • PUMP FlANGE
'!. ·.· FUEl TRANSFER NIPPLE ' TANK DRAIN

•ACCESS DOOR Figure 205-Fuel Tank-Outboard (Forward) CAUTION Support the tanks rigidly at all times to avoid damage from falling or contact with airplane structure. 3. BOMB BAY TANKS.-For removal of the bomb bay tanks, follow the same precautionary measures as given for removal of wing fuel tanks. Open the bomb bay doors and drain the tanks. Disconnect the fuel line's and support the tanks on a temporary platform orhoist, then release them by operating the emergencyrelease mechanism. Lower thetanksto theground carefully ro avoid damage from contact with the surrounding structure. (c) ASSEMBLY AND INSTALLATION. 1. MAIN FUEL TANKS.

a. Replace all bondingcarefully tO avoid the possibility ofelectrical charges remaining on the cell or on the leakproof hoses. It is particularly important that all the metal tank fittings be provided individually with a good electrical ground. b. When replacing the wing tank doors, do not use the dowel pins to force the doors in place. The doors will fit satisfactorily if the nacelle jacks are adjusted properly co relieve the torsion loads in the wing surfaces.
c. The self-locking gang nuts used to attach

Figure 206-Fue·l Tank-Outboard (Aft) 198 RESTRICTED 

# (

(

(_ .....

/ RESTRICTED AN Ol-20EG-2 Section IV Paragraph 6 the fuel tank doors in rhe wing may nor Jock securely after several cycles of removal and replacement of rhe screws. If necessary, give rhern a light tap with a wooden mallet ro compress the f1ber inserts and force the screw to cut a new thread. 2. OUTBOARD WING TANKS. (TOKYO TANKS) a. To install the outer wing cells, all access doors on the cop of the tanks must be securely lock

Figure 207-Typica/ Fuel Tank Installation Supports

## ~~W:}8L'6~[;':'~~¥'~.ocDNr>_.·f~~K··,-P_@?~:1~;-~~.sV~f~~;:l~

. :.-**:-~~·-·**

Figure 209-0IJter Wing Tank Installation (Step 2) wired and pressure sealed. The forward doors need be held in place only by two or three nuts during this procedure. Collapse the cells by kneeling on them and strapping flat. A vacuum not to exceed three pounds per square inch as supplied by a vacuum cleaner facilitates this process if the openings are covered during the deflation. Push the cells, one at a time, out into the wing, through the rib struCture adjacent to the front spar. The aft end of the cell must lead, for it will be twisted and turned into place in the bay in which it is located. Leave the cell in the collapsed condition in the wing, while the tie-up cords are made fast ro the upper rib chord, adjacent ro the outboard side of the cell, and threaded

Figure 208-0uter Wing Tank Installation (Step J) RESTRICTED 199Section IV Paragraph 6 RESTRICTED AN 01-20EG-2

figure 270-0uter Wing Tank Installation (Step 3)

figure 211-0uter Wing Tank Installation (Step 4) through the tie-up loops on the celL itself. After this, the straps can be released and the cell will expand to its normal shape. The tie-up cords should then be stretched tight and made fast to the upper rib chord adjacent to the inboard side of the cell. Extreme care must be taken to see that any protruding molded rubber nipples are nor pulled or severely rwisted. Nor should cells ever be allowed to stand or rest on any protruding molded fittings. Do not keep cells in a collapsed condition for more than 15 ro 20 minutes at a time because they have a tendency to take a permanent set. Cells should be collapsed at room temperature or above; under no circumstances should cells be collapsted at freezing temperature. b. At the No. 1 cell, which is farthest outboard, the filler overflow drain tube should be installed after the tank is lashed in place and before installing the other cells. It is necessary to install the farthest outboard first and then insrall each succeeding cell progressing inboard. This may be done by removing the outboard wing panel and working through the wing opening, or by removing the engine No. 1 or No. 4 tank or the feeder tank. In any case it is necessary to remove the leading edge of the outboard wing to connect the vents. Cells cannot be installed through the front spar. After the cells are installed and lashed, the forward access doors may be removed and the vent lines connected. Connect the fuel lines, and install the filler necks and the forward vent access doors to complete the installation. c. Installation or servicing of the vent lines requires removal of the outboard wing leading edge. Servicing the fuel lines from each cell group is accomplished by opening the access doors which are located on theundersurface ofthe wing betweenstations 20 and 24 aftoftherear spar. d. The system does permit bypassing a damaged cell. To do so, remove the lower surface access door and replace the tee in the fuel hose at the damaged cellwith a pieceofdural tubing or plug the tank end of the tee. Except in emergency, a vent must be provided running ali the way through the damaged cell making a continuouslinkbetweenthe adjacentundamagedcells. The rwo cells with filler necks cannot be bypassed if damaged. They must be removed and repaired or replaced. Do notdelay in making repairs to cells any more than with the main fuel tanks. Residual gasoline will continue itsaction although thecell has been drained. 3. BOMB BAY TANKS.-When installing the bomb bay fuel tanks, check to insure clearance with the landing gear hand retracting crank. CAUTION Do not operate the fuel transfer pump with any selector valve ports plugged without

figure 212-Left Hand Outer Wing Tanks 200 RESTRICTED 

# (

(r
\



# (RESTRICTED AN 0 1-20EG-2 Section IV Paragraph 6 removing the poppet from the plugged port. Thiscondition ariseswhen the bombbaytanks are not installed. It is recommended that a six-inch length of hose, plugged at the outer end, be attached rather than removing the poppet valve and plugging the port. (3) FUEL BOOSTER PUMP (Thompson TFD 12,000. (a) GENERAL-A fuel booster pump assembly, consisting of an electric motor and an impeller type pump, draws fluid from the bottom of thetankthrough a screened outlet. This pump is designed to produce a discharge pressure against a closed portofeightpounds per square inch, and with the engine pump operating, should develop a pressure of approximately six pounds per square inch. The clearance between the impeller blades and the housing is sufficient to permit fuel flow to the engine when the booster pump is inoperative. (b) REMOVAL. 

### WARNING Before attempting to remove a fuel booster pump, make certain the master battery switches in the cockpit are "OFF" or remove the booster pump fuses in the station 4 fuse panel. The pump assemblies are very well halSECURE COLLAPSED POSITION WITH WEB STRAI'S

AFT END OF CELL

CELL BEING TURNED INTO ITS. OWN BAY Figure 2l4-left Bomb Bay Fuel Tank anced and operate so quietly that it is possible to remove them without observing that they are operating. With power on, removal of the as.;emblies from the airplane would result in breaking the electrical circuit at the most likely location for explosion or ignition of gasoline. The fuel booster pump and screen may be removed as a unit through the opening in the fuel tank door on the lower surface of the wing. The pump assembly and opening are normally covered by a streamlined fairing hinged at the forward end and held in place by three Dzus fasteners. Drain the fuel tank and disconnect the hoses and electrical leads. In removing the bolts in the mounting flange take every precaution

Figure 2l5-Bomb Bay Fuel Tank Installation Figure 2l3-0uter Wing Tank Installation Procedure (Interior View) RESTRICTED 201Section IV Paragraph 6 RESTRICTED AN 01-20EG-2

Figure 216-Bomb Bay Fuel Tank Installation (Bottom View) to protect the leakproofbag. After removal ofthepump assembly close the opening with a suitable stopper or cover plate for protection against entrance of foreign matter. (c) MINOR REPAIRS AND REPLACEMENTS.-One set ofspare brushes for each fuel booster pump is supplied with the airplane. Replace the booster pump brushes when the brush tension has been reduced to two-thirds of the original tension. Brush replacement must be determined in conjunction with other necessary maintenance operations. (d) AD JUSTMENTS.-Iftheboosterpumpdoes not deliver sufficient pressure, check the voltage and inspect the motor brushes for full contact on the commutator. If this does not correct the pressure, remove the pump and inspect the inlet screen for foreign particles and see that the impeller turns freely. (e) INSTALLATION.-Install new gasket and replace the four mounting bolts. Connect the hose and electrical lead. (4) FUEL**SHUT~OFF** VALVE (Electrimatic No. 2660). (a) GENERAL-A solenoid operated fuel shutoff valve is installed in the line between the booster pump and the fuel strainer. The valve controlling the flow from the inboard tank is mounted directly aft of the tank, whereas the valves in the main tank line (engines l and 4) are-lecated in the wing leadingedge near the inboard oil cooler. Note Fuel shut-off valves are to be used in emergencies, such as a severed fuel line or fire. The valves are spring loaded and are normally open. They are closed by an electric solenoid, and remain closed only as long as the current 1s on.

(b) REMOVAL-With the inboard _wing tank installed, the fuel shut-off valve is reached through the access door in the lower portion of the wing. Disconnect the electrical leads and the fuel lines and remove the mounting bolts at the base. Stop all fuel lines with a suitable plug, and tape the ends of the electrical connections. (c) INSTALLATION.-Replace mountingbolts; connect fuel lines and electrical leads. Seal fuel lines as per Specification AN-G-14. (5) FUELSTRAINER.

(a) GENERAL-A fuel strainer is mounted on the forward inboard side of each fire wall. The primer 202 RESTRICTED 

# (



# (

(RESTRICTED AN 01-20EG-2 Section IV



# s, 6

7-345

INSTALLATION PROCEDURE L Install tank cradles. Cradles should be interchangeable, but

after airplane has been in service may not always be interchangeable. 2. Install two pads on each bomb raiL Adjust pads parallel with

rail and with 1/8" clearance between rail and back of pad, except for !:>ottom pad on each outboard raiL Adjust this pad with 1/8" clearance at top and no clearance at bottom. Apply vaseline to surface of pads. 3. Attach beam assemblies to type B-7 bomb shackles and insta 1

at bottom stations on racks. Keep bomb release handle in "locked" position. 4. Remove aft sway block at top of bomb bay fuel rank and lift

rank into place, raking care to avoid contact between the tank and sharp corners at the bottom of the bomb rails. Adjust tank position so that the forward sway block rests against the side of the af£ cradle and so that the tank seats against all four pads on the cradles. 5. Engage turnbuckles to connect the srraps between the beams and before tightening fully, replace the aft sway block at the top of the tank, and install sway blocks at beams. 6. Tighten and lockwire turnbuckles. 7. Install fore and aft beam assemblies and tighten to a snug

fie Be sure that rod end extends past inspection hole in each clevis. These beams must be installed with the rivet manufactured heads up. 8. The two upper pads on the inboard rails may be adjusted

if necessary for full contact with the tank. CAUTION: Too much concacc pressure between the rail pads and the rank will tend to make the tank hang up instead of dropping our when the emergency release is operated. 9. Install sight gage, vent line and fuel transfer line. The hose

connection at the selector valve must be finger tight only, as the hose goes with the tank when released. figure217-BombBayFuel Tank Installation Procedure RESTRICTED 203Section IV Paragraph 6 RESTRICTED AN 01-20EG-2

_.------------SOLENOID COVER
ElECTRICAL SOLENOID COIL (24 VOLTS.OC)

CORE

Figure 21 8-Fuel Shut-Off Valve
PRIMER liNE PORT ----------.. (N0.3 NACELLE)

"OUT" PORT ------..., TO FUEL PUMP

CENTER SCREEN

GASKET------' Figure 219-Fuel Strainer UPPER THIMBLE
COn WASHER
SPRING
SET SCREW

SPACER

ASSEMBLY

WJNG NUT VANE (5)-----------

SPRING

LINER--------------_;**rnn--------~** DRAIN PLUG (4) '-------- CUP**~---REliEf** VALVE ,--------BY-PASS COVER

Figure 220-Engine Fuel Pump system is fed from the fuel strainer on the inboard side ofNo. 3 engine. (b) REMOVAL-The screens may be removed for cleaning without disconnecting the fuel tubing. Removal of the entire unit is accomplished by disconnecting the fuel lines at the strainer and loosening the mounting bolts. On the No. 3 engine fuel strainer the primer line must also be disconnected. (c) INSTALLATION.-Replace· the mounting bolts and connect the tubing. Seal fuel lines as per Specification AN-G-14. (6) ENGINE-DRIVEN FUEL PUMP.

(a) GENERAL-The fuel from the fuel strainer is directed to a type G-9 sliding vane fuel pump located on the right side of each engine accessory housing. An adjustable relief valve is incorporated in the unit to maintain a constant differential between the fuel pressure and the pressure in the carburetor intake duct. (b) REMOVAL-The fuel pump is mounted on the right accessory pad of each engine. Its removal requires disconnecting the fuel lines and the balance line to the intake duct. The unit is removed after taking out the cap screws in the accessory pad. (c) ADJUSTMENTS.-The fuel pressure regulating valve should be adjusted to maintain 12 to 16 pounds per square inch, as indicated by the fuel pres204 RESTRICTED 

# (

(



# (RESTRICTED AN 01-20EG-2 Section IV Paragraph 6
sure gage. Adjustment is accomplished by removing the hex head cap on the upperportion ofthe fuel pump and rotating the adjusting screw clockwise to increase the fuel pressure or counterclockwise to decrease the pressure. The pressure variation is approximately two turns per pound. After the adjustment is made, securely lock the adjusting screw and replace, and lockwire the cap screw. (d) INST ALLATION.-Replace the cap screws in the accessory pad and connect the fuel lines and the balance lines to the intake duct. Seal fuel lines as per Specification AN-G-14. (7) HAND PRIMER.

(a) GENERAL-A hand priming pump is mounted on the floor near the right sidewall beside the copilot. A selector valve is incorporated in the unit which directs priming fuel (drawn from engine No. 3 fuel strainer) to any desired engine. (b) REMOVAL.-The fuel lines to the primer unit are disconnected through the access panelon the right side of the fuselage. The mounting screws are removed within the cockpit. Refer to section IV, paragraphs 6. a. and 6. e. for further information on the priming system. (c) INST ALLATIQN.-Replace the mounting screws and connect fuel lines. Seal fuel lines as perSpecification AN-G-14.

PACKING CAP -----------.,
PACKING CAP SPRING ------J

PANEL MOUNTING -------'

INTAKE FROM NO. 3 ENGINE FUEL STRAINER
OUTLET ------L-./ BODY
VACUUM CHECK PISTON
VACUUM CHECK SPRING
VACUUM CHECK INSERT

BLEEDER HOUS ----...

PLUG SPRING -------"
INlET CHECK INSERT -----_./ (8) FUEL TRANSFER PUMP (Romec RG 4420). (a) GENERAL-An electrically driven vane type fuel transfer pump is mounted in the bomb bay beneath the forward end ofthecatwalktruss. Thepump has a capacity of approximately 900 gallons per hour, discharging against a pressure of five pounds per square inch. The motor is reversible, explosion-pr<><?f, and designed to operate satisfactorily at altitudes up to 35,000 feet. CAUTION The transferred fuel lubricates the pump; therefore, the pump should not be left running after the tank upon which it has been drawing is emptied. Do not reverse the pump motor before it hascome torest. (b) REMOVAL. 

### WARNING Remove the motorfusefirst. Turn the fuel transfer valve controls on the rear bulkhead of the pilots' compartment to "OFF." In order to0remove both the pumps and the motor, disconnect and plug the lines to the pump and disconnect the pump drain tube. If it is not necessary to remove the pump, leave the fuel lines connected and disconnect the pump from the motor housing. Then disconnect all

PISTON CHAMBER PISTON KEY ,--------- PACKING WASHER**~--------PACKING**

,---- PACKING FOllOWER
HANDLE SPRING

PANEl MOUNTING HOLE
'------PACKING CAP SPRING
'----------------PIN
'----------------PLUG
Figure 22

### r-Engine Primer RESTRICTED 205Section IV Paragraph 6

Figure 222-Fuel Transfer Pump RESTRICTED AN 01-20EG-2

Figure 224-E-5 Fuel Shut-Off Valve electric wires. The motor leads must be disconnected at the control switch because no junction is provided. Remove the four motor mounting bolts from the support and take the motor out toward the left side of the airplane. (c) ADJUSTMENTS.-One set of spare brushes for the fuel transfer pump 

### is supplied with the airplane. Replace the booster pump brushes when the brush tension has been reduced to two-thirds of the origin:tl tension. The fuel transfer pump is a shunt wound motor, which naturally has poor starting characteristics under load, and brush replacement must be determined in conjunction with other necessary maintenance operations. (d) INSTALLATION.-Install the motor and connect the fuel lines, pump drain line and electric leads. Seal the fuel lines as }>er Specification AN-G-14. Connect the electric leads at the control switch. Replace the motor fuse. (9) TRANSFER SELECTOR VALVE.

(a) GENERAL.-Twotransferselector valves are mounted on the rear side of bulkhead 4, one on either
TANK PORT - sideofthedoor, and thecontrol handles are mounted on the forward wall. These valves are designed to direct fuel from any tank on one side of the airplane center line toany tankon the opposite side. A transferbetween two tanks on the same side of the airplane center line

TANK PORT PlUNGER GllfOf CAM. P'lUNGU ------'

...AFT

_____ ____J INlET FROM PUMP -----'
Figure 223-Fuel Transfer Selector Valve 206 RESTRICTED Figure 225-Fuel Shut-Off Valve Control Unit Installation 

# (

(_/· RESTRICTED AN 01-20EG-2 Section IV Paragraph 7 must first be routed to a tank on the opposite side and then returned to the desired tank. As a safety feature, a switch is installed on each valve handle which closes the circuit to the pumpmotor at the time any valve port is opened. This eliminates possible damage to the valve from pumppressure against a closed port. (b) REMOVAL.-Removal of the transfer valve body requires disconnection of the control handle, the electrical leads to the unit, and the fuel lines. The assembly may then be removed from the airplane by disassembling the mounting bracket on the rear side of bulkhead 5. (10) SHUT-OFF VALVES.-This D-5 or E-5 series "D" valve is controlled from the rear bulkhead of the bomb bay compartment or from the forward bulkhead of the radio compartment by a self-contained hydraulic system. When the valve is OFF, accidental loss of hydraulic fluid or pressure will cause the valve to open, permitting delivery of fuel from the outer wing tanks. 7. FIXED EQUIPMENT GROUP.

a. INSTRUMENTS AND INSTRUMENT PANELS. Figure 226-E-5 Fuel Shut-Off Valve (Installed) (1) GENERAL.-The flight and engine instruTURN AND SANK * AN582().2 TURN INDICATOR * AH.5Tl5-2 ALTIMETER * AN5760-< SELECTOR VALVE WEATHERHEAD AN58Jl-l AIR SPEED INDICATOR * 07 SPEC 94-27953 VALVE B.A.C. A.C. J8A61JJ MANIFOlD B.A..C. 3-13662 FitTER * AN5822-1 RATE Of CliMe INDICATOR * AN5825-2 AIR SPEED PITOT TUBE

Figure 227-F/ight Instruments Diagram RESTRICTED TH El&OW VAC. TUBING 

# ... PilOT PRESS. TUSING STAOC TUBING ORAIH

207Section IV

>-.&24 >-.121-+
40B BULB·N TEMPER r;:::::;l">- M 74**~>-M73** 0.1 OIL ATURE -+

.2 OIL ATURE 412 BULB-NO TEMPER r;:::::;l >-M76**~>----t-478**

## .... A2.6-A21!1-< 0 431 FLAP POSITION A INDICATOR [ oow 429

# t""~~ 

# ... M80-< C. OIL TEMP. 43 T INDICATOR D WB9-< A
• D M77-< E··. C

# ~-**t~~~** 0.1 CARS. M99-< D MPERATURE 28B CARBURETOR AIR TENP. INDICATOR o N!OO-< A .2 CARS. • D PERATURE**~•o** IOO-< E ·,**~>-M(08 ~>-"ro&-+**  286 BULB· N AIR TE
287 BULB· NO AIR TEM**~>-<.oro ~>----MIO,...**  RESTRICTED AN 01-20EG-2



### t 

### • "'**~**



### " 

### " :**~**

# :=.,~ 

# I.J

I 81 OIL TEMP. 36 INDICATOR >-M86-

. M92 

# I"

... r7j I() 9 CARBURETOR AIR

TEMP. INDICATOR 0198- I 9 93 412 BUL8-110.3 OIL MPERATURE**M~-<hl M87-<~**  T,E +-

408 BUL8 • N0.4 OIL PERATURE TEM

+-**Ml!l3-<~ MOe-<~** **Mill-<~ M95-<~**  • N0.3 CARS +- 287 BULB AIR TENPERATURE
286 BULB• N0.4 CARS NPERATURE AIR TE 112-<F=;l

..........**92-<~**

BAC WIRING DIAGRAM 9-6848 AAF 42-31032 AND ON

-<::>- STAKON SPLICE

Figure 228-lnstruments Circuit (A & M} 208 RESTRICTED 

# (

(



# (RESTRICTED AN 01-20EG-2 Section IV Paragraph 7

COLOII 10£1fTIFICATIOII**~** ......**UCS·L..-TIUM:·ftU..OIII'·L*'~** "'""',......
..... ·a,.t,gl P1TfJI ITATIC u•a · u.ft' Ml.lJI•IL..JriCI: ..aa.-**~** . -n:. LMMf --·**~......** ·UM'TIMC•

................**~** • ...,. ••UMJ lUI[ 

# ......... ........

A. ,ILTIJII.M-.: •


## ..

# -. <. .... .

# ...

.

### .........

D. IUCT.a.

........ SWITQI**~** t. '"' U.I Dll**~­** P
... o..D..l•Nn.•

.. .,.0.
......**~** M. ,... 1£1 14 P'lLih.LI 110..: .1• .,_ La.I II 11\.Uik.I MDII ll.. Ste La.& II ...aJUa& 110M L
... La.l 14 ft.Vllll..l MDSI • lA La.I 14 "-Pikl ..oM 

# ·-- ALL .t.&...U*II
..... ALLO't' n.•••l II l*AMOOIUO. ALL .U..IJ.ItlfiUII au..O'f n.IMI IS tS**uz•t.:-~ww•T·Ta.** AI..L KilO ft&DII IIIUST af: ntlltf:! TIWS nc TUef 0.0

Figure 229-Pilots' Instrument Tubing Diagram ments, on panels in the pilots' and bombardier-navigator'scompartments, are of four main types: electrical, picot and static pressure, gyroscopic and magnetic Do not attempt to repair the instruments themselves unless you are a specialist. Internal and external circuits of all electrical instruments are shown on figure 387. The circuits should always be checked thoroughly before replacing an instrument. (2) AIRSPEED INDICATOR.

(a) GENERAL.-The air speed indicator operates by measuring the difference in pressure between ram air (air pressure built up by the airplane's speed) and static pressure (atmospheric pressure). The pitot static system supplies these pressures. The ram air is directed tO one side of a diaphragm and the staticair pressure to the other. The diaphragm is connected to the pointer by a linkage and gear system and movement of thediaphragmisthus translated intopointermovement. The gage is calibrated in MPH. (b) TROUBLE SHOOTING. Trouble Pointer fails to respond.
Pointer vibrates.

Other troubles. Probable Cause Pitot pressure line improperly connected or clogged. Excessive vibration of instrument board. Excessive vibration of cubing.
Any. Remedy Check tubing connection and leaks. Blow out to remove foreign matter from lines. Replace worn mounting units holding instrument board. Connect about 10 inches of non-magnetic flexible cubing between the indicator and each solid airspeed line. Replace instrument. (3) TURN AND BANK INDICATOR. (a) GENERAL.-The turn and bank indicator is really two separate instruments in the same case. The "turn" indicator contains an air driven turbine which acts as a gyro. The air stream which drives the turbines is pulled into the instrument from the outside air through a filter and screen by an engine driven suction RESTRICTED 209Section IV Paragraph 7 RESTRICTED AN 01-20EG-2 pump. Suction is maintained at two inches Hg. below atmospheric pressure. The gyro, connected ro the pointer by a simple linkage, remains in position while the airplane turns around it and this relative change is translated, through the linkage, into pointermovement. ' The "bank'' indicatOr shows the movement of the air·

plane about an axis parallel with the line of flight. Ir consists of a ball in a curved tube containing liquid. The liquid smooches our the movement of the ball. When the airplane banks during a turn centrifugal force tends to drive the ball in the opposite direction from the turn. When the correct angle of bank is used, the forces equalize and the ball remains in the center of the tube. (If the ball is driven outward, the bank is too shallow; if pulled down, the bank is too steep.) (b) TROUBLE SHOOTING. Trouble Pointer fails to respond. Other troub!e. ·Probable Cause No vacuum. Any. Remedy Check vacuum lines and instrument filters. Replace instrument. (4) RATE OF CLIMB INDICATOR.

(a) GENERAL-Therate ofclimb indicatoroperates by quickly and accurately measuring the difference in atmosphericpressureas altitudechanges, and by recording this pressure change. This is done by measuring the pressure drop between the outside (atmospheric) air pressure and the air pressure in a sealed chamber (instrument case). A "calibrated and compensated diffuser" (leak) permits outside pressure changes to enter the sealed chamber. The pressure change in the sealed chamber lags behind the outside change and the differential pressure causes movement in the pressure diaphragm which is magnified and translated mechanically to a pointer which indicates the pressuredifferential in terms of feet per minute. (5) TURN INDICATOR.

(a) GENERAL-St>e turn and bank indicator (uses revolving dial instead of pointer). (b) TROUBLE SHOOTING. Trouble Excessive drift on either direc· tion.

Any other. Probable Cr•ue Excessive vibration.

Insufficient vacuum; if below 3-% inches Hg. check as fol· lows: Suction regulator impcopecly adjusted. [ncocrecc gage reading. Pump failure. Improper function· ing of vacuum line. Any. (6) ALTIMETER. Remedy Test with vibro· meter. Examine shock mountings and note whether connectionsarepulling on instrument.

Adjust regulator. Check calibration of gage. Repa ic oc replace pump. Check foe kinks, leaks or collapsed inner wall. Replace instrument. (a) GENERAL.-The altimeter, like an aneroid barometer measures the outside (atmospheric) air pressure. It is vented to the atmosyhere through the static system. This pressure moves a diaphragm which is connected to the pointer by a balanced linkage. The dial is calibrated in terms of feet. (b) TROUBLE SHOOTING.-If the instrument is not working properly, check the lines for leaks and obstructions and see**~hat** thecase is securely mounted on thepanel. Ifthe instrument stilldoesn't work, replace it. Do not attempttoadjust irs mechanism. (7) GYRO HORIZON.

(a) GENERAL-This is a gyro instrument. The gyro is vacuum driven (4 ± .25 inches Hg.) and is so mounted as co retain its upright position regardless of the airplane's movement. The white horizontal line on the dial face is held in position by the gyro while the airplane and calibrated portions of rhe instrument are fastened to the panel and moved in relation to the line as the airplane changes its horizontal axis. The instru· mentshould be caged if acrobatics or violent maneuvers are anticipated. (b) TROUBLE SHOOTING. Trouble Bar fails to respond. Bar fails to respond (high vacuum). Bar fails to respond (low vacuum).

Instrument trouble. Probable Cause lnstrumenc caged. Air filter dirry.
Suction regulator improperly adjusted. Incorrectgage reading. Pump failure.

Any. Remedy Uncage. Clean filter. Adjust suction regulator. Check calibration of gage. Repair or replace pump. Check lubrication. Check for collapsed inner wall of flexible hose. Replace instrument. (8) RADIO COMPASS INDICATOR.

See "Communication Equipment," pantgraph 7. e. (1) (c). (9) PILOT**~!RECTOR** INDICATOR.

See "Autopilot," paragraph 7. b. (10) (a). (10) OIL TEMPERATURE INDICATOR.

(a) GENERAL-Current flows through a wire in universe proportion to the temperature. The hotter the wire, the less the current flow. Direct current flow from the airplane electrical system flows through a specialresistance wire in the temperature bulb and actuates an ammeter calibrated in degrees Centigrade on rhe instrument panel to indicate the temperature of the medium surrounding the bulb. (b) TESTS.-To checka temperature instrument circuit: 1. Disconnect thepower bypulling thefuse or removing the indicator receptacle. 210 RESTRICTED I ; '. 

# (

(RESTRICTED AN 01-20EG-2 Section IV Paragraph 7

TOTAl CABLE TRAVEL CABLE DRUM ANGULAR MOTION 90 0 RIGGING TENSIONS AT 70 F. POINTS OF MEASUREMENT ARE APPROX. TURNBUCKLES IDENTIFICATION COLORS: YELLOW-RED CABLES SHOWN IN MID,TRAVEL POSITION INSTAll TURNBUCKLES WITH R.H. THREADS UP, TO THE REAR OR TO THE RIGHT EXCEPT AS NOTED. TERMINAL TYPE TURNBUCKLE 7. 7 AN b69-L3LH AN 155-16L 50.6 7. 7 AN669-L3LH AN l55-16L 24.0 7•7 AN 668-3 24.0 7x7 AN 668-3 For Terminal AN 668, the Coble**Anemb~y** length is measured to center of bolt hole. For T erminolAN 669.the assembly lengthincludes full length of ti!:rminal1o. Poulwn and Nordon Boll and Strop, and AmeriCan ChainoncJ Coble Boll and may be·uw:d in placeof Standard AN**~7** and AN 668 Swage!'d T Figure 230-lnstrument Vacuum ControlSystem 

### WARNING Always remove the 15-ampere thermometer fuse in the station 4 fuse shield or disconnect the indicatorreceptacle beforedisconnecting a temperature bulb. An open bulb.circuit with poweron will burn out the indicator. ·

.2. Disconnect the bulb and allow it to cool to room temperature.**~-** Test the bulb with an ohmmeter. The resistances for good bulbsareapproximately as follows:

AirTemperature -50°C (-58°F) -20°C ( -4°F) 0°C (. 32°F) 20°C ( 68°F) 40°C ( 104°F) Bulb Resistance 74ohms 84ohms 90ohms 97 ohms 105 ohms 4. Check the wiring (indicator receptacle disconnected) with anohmmeterora "cold" wiretest light (see "Electrical Trouble Shooting"). 5. If the circuit is faulty and both bulb and wiring check all right, replace the indicator. Do not attempt to repair the indicator or the bulb. 6. Connect the bulb before connecting the indicator, and rurn on thep<>wer last. (11) FREE AIR TEMPERATURE INDICATOR. (a) GENERAL.-The indicator on the copilot's instrument panel is controlled by an electric resistance bulb in the right wing gap. The bombardier bas a selfcontained type C-13A bi-metallic thermometer in the Plexiglas nose. (b) TESTS.-See paragraph (10) (b) preceding. (12) CARBURETOR AIR TEMPERATURE INDICATOR. (a) GENERAL-Two dual indicators are mounted on the copilot's instrument**pa~el,** and an elec· tric resistance bulb is installed in each carburetor air duct forward of the fire wall. (b) TESTS.-See paragraph (10) (b) preceding. (13) CYLINDER HEAD TEMPERATURE INDICATOR. (a) GENERAL.-The thermocouples are selfgenerating electrical instruments and do not receive p<>wer from the airplane electrical system. When any two dissimilar metals are joined, a difference in elec· tricalp<>tential (voltage) issetupacross thebond.When two such bonds at two different temperatures are connected with ammeter in the line, an electrical current RESTRICTED 211Section IV Paragraph 7 RESTRICTED AN 01-20EG-2

Figure 231-Pilots' Instrument Panel (Front View) will flow which will be measured by the ammeter and can be calibrated in degrees Centigrade. The thermocouple consists of an iron and constantan bond connected through accurately calibrated wires to the indicator on the instrument panel. The thermocouple on the engine is the "hot junction," and the "cold junction"**i~** in the indicator. (b) MINOR REPAIRS AND REPLACEMENTS. 1. Do not repair any thermocouple wires if replacements are available, since the indicator will then read incorrectly. Replace the wires in accordance with the Ml through M24 wires in the wire table. 2. If replacements are not available, the wires can be repaired by stripping the insulation from the broken ends of the wire, looping the protruding portion, laying the two ends together, and clamping them tightly between two washers with a No. 6 bolt and a fiber locknut. Tape and shellac the joint to prevent a short circuit. This type of splice has a minimum effect on the instrument reading. 3. Engine vibration and air blast occasionally cause chafing through the thermocouple lead insulation where the leads enter the engine conduit. The insulation wear can be prevented by sliding the conduit away from the spark plug connection and wrapping the leads with tape so that when the conduit is replaced, approximately one-half inch of taped lead is packed firmly inside it. (14) FUEL QUANTI1Y GAGE.

(a) GENERAL.-The transmitter in each of the 212 RESTRICTED 

# (

(



# (RESTRICTED AN 01-20EG-2 Section IV Paragraph 7 six main tanks consists-of a simple float-actuated rheostat with adjustable end taps to set the full and empty limits. The indicator includes an ammeter and a six-position switch which connects the ammeter to the desired transmitter and at the same time rotates the corresponding dial mask into view behind the pointer. Twenty-four volt direct current flowing through the transmitter rheostat causes the ammeter to indicate the remaining gallons of gasoline in the tank on the calibrated dial mask. (b) TROUBLE SHOOTING. I. Noreadingat anyofthe sixpositionsofthe selector switch may indicate a blown fuse, a poor connection at the indicator, a break in wire M33, or a defective indicator. 2. Noreadingon one settingindicates a faulty connection at the respective transmitter. 3. A center reading at one setting indicates the wire to the "C" terminal of the transmitter is broken. 4. A high or low reading at one, at several, or at all settings, may indicate, respectiyely, that the wire to the "B" terminal of the transmitter, the branching wire to several transmitter "B" terminals, or wire M35 is broken.

INSTRUMENT PANEL
TO AIR SUPPLY VAlliE

"HYDRAULIC ACCUMULATOR

MASTER GAGE UNIT FROM THE G-1 INSTRUMENT f'IELO TEST SET ALTERNATE f'IWNG MEANS 7-388 5. Service is limited to repair of broken wires, adjustmentof the full and empty limits, tighteningconnections and replacing the units. (15) FUEL ANDOIL PRESSURE GAGES.

(a) GENERAL.-These instruments consist of transmitting and indicating units. Fuel or oil pressure actingon a diaphragm transit**p~essure** through a liquid (AN-VV-C-551) on the otherside of the diaphragm to a Bourdon tube in the indicator. As varying pressures induce movement in the Bourdon tube they are transmitted to the indicator pointer through linkages. (b) MINOR REPAIR.-Add AN-VV-C-551 (compass fluid) to the system through the port in the lower side of the transmitter. Fluid must be under 25 PSI. Don't let filling pressure exceed the maximum gage reading. I. Be sure the system is completely filled or the reading will be low. 2. During replenishing, loosen the locknut and tighten the diaphragm locking screw to avoid damage to the diaphragm. 3. Due to the weight of the fluid the dialwill read less than "0" when the engine is not running. Correct this by removing the instrument from the case and setting the pointer up 1.2 pounds with the adjusting screw.

SYSTEM SHOWN WITH CONNECTIONS IN PLACE FOR FILLING WITH PRESSURE TRANSFER LIQUID

Figure 232-Fuel and Oil Pressure Gage System RESTRICTED 213Section IV Paragraph 7 RESTRICTED AN Ol-20EG-2 (c) TROUBLE SHOOTING. Trouble Does nor regISter. Pointer fails to cetuen to "0." Probable Came Pressure line plug· ged. Foreign matter in line on engine side of transmitter. Remedy Remove din from line and tighten connec· rions and fittings. Clean line. (16) MANIFOLD PRESSURE GAGE.

(a) GENERAL.-The instrument contains two flexible metallic bellows equal in cross section area. These twobellowsare connected by a spacer. Oneofthe bellows is evacuated and the other is connected by a tube to the source of manifold pressure. The ends of the bellows unit are fastened to the base and thus any increase or decrease in manifold pressure acting on the bellows moves the spacer connecting the two bellows. This spacer movement is registered on a dial calibrated in terms of inches Hg. (b) TESTS.-Check against altimeter for correct setting. (17) TACHOMETERS.-The lachometers are selfgenerating electrical instruments and are not connected to the airplane electrical system. A permanent magnet driven from a geared shaft on the engine sets up electrical currents proportional to the speed of rotation in three field windings. The field windings are connected to similar windings in a synchronous motor in the indicator, where the currents set up a rotating magnetic field. A four-pole magnet and a lag disk are carried around by therotatingmagneticfield and inturndrivea split magnet assembly. A drag disk, which is connected to the pointer and restrained by coil springs, is located between the halves of the split magnet assembly and is pulled around against the springs by the magnetic field. Two such synchronous motors are combined in one indicator and are geared to rhe rwo concentric pointer shafts. (18) WING FLAP POSITION INDICATOR.

(a) GENERAL.-The Autosyn transmitter consists of a simple armature rotor and a three-phase field winding. The rotor is connected by levers to the wing flap. Alternating current, 26 volts, 400 cycle, from the airplane's inverter, is passed through the windings of the two pole rotor. A current is induced in each of the three field windings in proportion to theposition of the rotor. The three unequal currents are carried to three respective field windings in rhe indicator where their magnetic fields act on the indicator rotor and cause it to assume rhe same position as the transmitter rotor. The indicator rotor could be a permanent magnet, bur is an electromagnetfor simplified production. A pointer is attached to the indicator rotor. (b) MINOR REPAIRS.-A broken or shorted wire in the field circuits will cause the pointer to move part of a turn when the flap is operated anci suddenly snap to a new position where it will probably oscillate. Note Only authorized instrument shops may repair autosyn instruments. (19) AC VOLTMETER-The voltmeter consists of a cylindrical, hollow coil in which are a fixed, triangular soft iron magnet and a pivoted, triangular soft iron magnet to which the pointer is attached. Alternating current Bowing through the coil sets up north and south magnetic poles which also appear on the soft iron magnets. Since one end of both magnets is north and theother south at the same time, the magnets repel each other in a rotary direction due to the triangular shape,causingthepointerto indicatethestrengthofthe alternating current. Alternating polarity in the field alternates the north and south poles in both magnets at the same rime so the direction of current flow makes no difference. (20) DC VOLTMETER-A five-position (OFF-1- 2-3-4) selector switch below the voltmeter connects the voltmeter ro the positive "B" terminal of each of the fourgenerators. Current through a pivoted coilrotating in a permanent magnet field against coil springs causes a pointer to indicate the strength of the current which is a measure of rhe voltage. (21) INVERTERS. (a) GENERAL. 1. Either inverter is turned on by a bar toggle switch on the pilot's control panel. In the "NORMAL" position, the switch turns on the inverter under the pilot's seat. In case of failure of the normal inve::ter, the switch should be turned to "ALTERNATE" to employ the inverter under the copilot's seat. 2. The inverter consists of a governor-controlled DC motor, two AC field windings, and a radio

Figure 233-Pilot's Compass Panel 214 RESTRICTED 

# (

(



# (

# ••

• __________________________*

___________________________ T. 0..1B-17G-3 (FORMERLY T.O. No. Ol-20E.3) 

## HANDBOOK STRUCTURAL REPAIR INSTRUCTIONS



## USAF SERIES 

# B-17E, F, G, RB-17E AND QB-17G AIRCRAFT

PUBLI5H£D UNDER AUTHOP.ITY OF THE SECRETAP.Y OF THE AIR FORCE AND THE CHIEF Qf THE BUREAU Of AERONAUTICS



# __________________________*
__________________________J

. AIR FORCE (DPS**:oCO(.~~j** .UlAr·d 500 

# IGOVERNMENT 

### ;.

# EX~-- 10 A.PRil 1943 REVISED lS AUGUST 1956T.O. 1B.J7G.3 Reproduction for non-military use of the information or illustrations contained in this publication is not permitted without specific approval of the issuing service (BuAer or AMC). The policy for use of Classified Publications is established for the Air Force in AFR 205-1 and for the Navy in Navy Regulations, Article J509.
;-------------- LIST OF REVISED PAGES ISSUED ---------------:

A INSERT LATEST REVISED PAGES. DESTROY SUPERSEDED PAGES. NOTE: Th.e ponion of**th~** text**affecr:~** by rhe curr.eot revision is indicart'd by a verdcal Jine in rhe outer mar&ins ol the pase. Page Date ofLatest Page Date ofLatest Page Date ofLates;**N~ Rems~**  No. Remsion**N~** Remsion • B
...................l5 August 1956 58
.......................... 25 May 1944 128
.......................... 25 May 1944 i

........................25 March 1945 59
....................25 October 1944 129
.......................... 25 May 1944 !...

....................... 25**~y** 1944 61..
........................ 25 May 1944 132
.......................... 25 May 19¥ 2
.................... 15 October 1954 62
.......................... 25 May 1944 133
.......................... 25 May 1944 8
.......................... 25 May 1944 63
.......................... 25 May 1944 136
.......................... 25 May 1944 17
....................25 October 1944 64
.......................... 25 May 1944 137
.......................... 25 May 1944 18
....................25 October 1944 65
.......................... 25 May 1944 139
....................25 October 1944 19
.......................... 25 May 1944 66
.......................... 25 May 1944 141..
........................ 25 May 1944 20
.......................... 25 May 1944 67
.......................... 25 May 1944 142
.......................... 25 May 1944 21..
........................ 25 May 1944 68
.......................... 25 May 1944 143
.......................... 25 May 1944 22
.......................... 25 May 1944 70
.......................... 25 May 1944 144
.......................... 25 May 1944 23•..•...•..•...•........... 25 May 1944 26
.......................... 25 May 1944 27
.......................... 25 May 1944 72
.......................... 25 May 1944 74
.......................... 25 May 1944 75
.......................... 25 May 1944 146
....................25 Octobei 1944 146.1\
..................25 October 9944 156
....................25 October f944 28
.......................... 25 May 1944 76
.......................... 25 May 1944 158
.......................... 25 May**~,944** 29
.......................... 25 May 1944 30
.......................... 25 May 1944 77
.......................... 25 May 1944 81..
........................ 25 May 1944 159
.......................... 25 May**~44** 16o
.......................... 25 May**~44** 31
.......................... 25 May 1944 85
................15 september 1944 164
.......................... 25 May 1944 32
.......................... 25 May 1944 87
.......................... 25 May 1944 164.1\
........................25 May 1944 33
.......................... 25 May 1944 96
.......................... 25 May 1944 165
....................25 October 1944 34
.......................... 25 May 1944 97
.......................... 25 May 1944 169
.......................... 25 May 1944 35
.......................... 25 May 1944 98
........................... 25 May 1944 170
.......................... 25 May 1944 36
.......................... 25 May 1944 100
.......................... 25 May 1944 171
.......................... 25 May 1944 37
.......................... 25 May 1944 102
.......................... 25 May 1944 174
.......................... 25 May 1944 38
.......................... 25 May 1944 103
.......................... 25 May 1944 175
.......................... 25 May 1944 39
.......................... 25 May 1944 104
.......................... 25 May 1944 176
.......................... 25 May 1944 40
.......................... 25 May 1944 105
.......................... 25 May 1944 177
.......................... 25 May 1944 41
.......................... 25 May 1944 107
.......................... 25 May 1944 178
.......................... 25 May 1944 42
.......................... 25 May 1944 108
.......................... 25 May 1944 186
.......................... 25 May 1944 43
.......................... 25 May 1944 109
.......................... 25 May 1944 186A
........................25 May 1944 44
.......................... 25 May 1944 111.
......................... 25 May 1944 189
.......................... 25 May 1944 45
.......................... 25 May 1944 114
.......................... 25 May 1944 190A
........................ 25 May 1944 46
.......................... 25 May 1944 47
.......................... 25 May 1944 116
.................:........ 25 May 1944 117
.......................... 25 May 1944 191..
.............. 15 September 1944 192..
........................ 25 May l944 48
.......................... 25 May 1944 118
................ 25 November 1944 194
................ 15 September 1944 49
.................. 1 September 1954 118.1\
..............25 Nonmber 1944 195
................ 15 September 1944 51..
........................ 25 May 1944 119
..............:<:......... 25 May 1944 197
.......................... 25 May 1944 52
.......................... 25 May 1944 120
.......................... 25 May 1944 198
.......................... 25 May 1944 53
................ 15 September 1944 122
.......................... 25 May 1944 202
.......................... 25 May 1944 55
.......................... 25 May 1944 123
.......................... 25 May 1944 204
.......................... 25 May 1944 56
.......................... 25 May 1944 124
.......................... 25 May 1944 207
.......................... 25 May 1944 57
................ 15 September 1944 125
.......................... 25 May 1944 208
.......................... 25 May 1944

• The asterisk**iadicat~** p..**~** reviled, added or delet<!d by the currenr revision.

ADDITIONAl COPIES OF THIS PUIUCATION MAY IE OITAINED AS FOllOWS: USAF ACTIVITIES.-ln accordance wid> Tecbaical**Ord~r** 00-S-2 USAF NAVY ACTIVJTIES.--Submir requesr ro nearest supply poiar lisred below, usins form NavAer-140; NASD, Philadelphia, Pa.; NAS, Alameda, Calif.; NAS,**JacbonYill~.** Pia.; NAS. Norfolk. Va.; NAS, San Dieso, Calif.; NAS,**Seanl~.** Wash.; ASD, NSC. Guam. for**listin~** of ••ailable rnarrrial and de-rails of distribution tc"e N:aval Aeronautics Puhlicarions Index NaYAer 00-500. Revised 15 August 1956T.O. 1B-17G-3 LIST OF REVISED PAGES ISSUED (Continued) 

# • Page Dale ofLatest Page Date ofLatest No. Revision No. Revisio" 209 ···········-··········· 25 May 1944 536 ························ 25 May 1944 210
........................ 25 May 1944 · 537
........................ 25 May 1944 215 ···········-··········· 25 May 1944 538
........................ 25 May 1944 216
........................ 25 May 1944 539
........................ 25 May 1944 218
........................ 25May 1944 540
........................ 25 May 1944 223
........................ 25 May 1944 226
........................ 25 May 1944 228
........................ 25 May 1944 230
........................ 25 May 1944 231
........................ 25 May 1944 541 ························ 25 May 1944 542
........................ 25 May 1944 543
........................ 25 May 1944 544
........................ 25 May 1944 233 .......•................ 25 May 1944 545
........................ 25 May 1944 234A
.................. 25 March 1945 546
........................ 25 May 1944 234B
.................. 25 March 1945 547
........................ 25 May 1944 235
.................... 25 March 1945 548 ························ 25 May 1944 236
........................ 25 May 1944 549
........................ 25 May 1944 237
........................ 25 May 1944 550
........................ 25 May 1944 238
........................ 25 May 1944 551
........................ 25 May 1944 239
........................ 25 May 1944 240 ···········-··········· 25 May 1944 242
........................ 25 May 1944 243
........................ 25 May 1944 552
........................ 25 May 1944 553
........................ 25 May 1944 554
........................ 25 May 1944 244
........................ 25 May 1944 555
........................ 25May 1944 245
........................ 25 May 1944 556
........................ 25 May 1944 246
........................ 25 May 1944 247
........................ 25 May 1944 248
........................ 25 May 1944 249 ··········:············· 25 May 1944 250
........................ 25 May 1944 251
........................ 25 May 1944 252
........................ 25 May 1944 253 ························ 25 May 1944 254 Deleted
.......... 25 May 1944 255 Deleted
.......... 25 May 1944 256 Deleted
.......... 25 May 1944 257
........................ 25 May 1944 •258
............ 15 August 1956

263
........................ 25 May 1944 271
.....··················· 25 May 1944 275
........................ 25 May 1944 276
........................ 25 May 1944 280 ························ 25 May 1944 281
....................... 25 May 1944 282
.....··················· 25 May 1944 283
.... ··················· 25 May 1944 498
........................ 25 May 1944 499 Deleted
.......... 25 May 1944 500 Deleted
.......... 25 May 1944 501 ························ 25 May 1944 532 Deleted
.......... 25 May 1944 533
........................ 25 May 1944 534 ························ 25 May 1944 'i35
........................ 25 May 1944
Revised 15 ·August 1956T. 0. No. 01-20E-3



### TABLE OF CONTENTS
Section Page I Introduction and Preliminary Instructions...... 1 I. Description of the Structure.......................... 1 2. General Repair Instructions.......................... 2 3. Use of the Handbook.................................. 2 4. Handling and Reconditioning Procedures.. 20 II Body
.................................................................... 47 I. Description
.......:............................................ 47 2. Negligible Damage
...................................... 48 3. Reparable Damage
........................................ 51 4. Damage Requiring Replacement
..................119 HI Wing
..................................................................122 1. Description
....................................................122 2. Negligible Damage
......................................123 3. Reparable Damage
............................:...........124 4. Damage Requiring Replacement
..................180 IV Nacelle
................................................................189 1. Description
..........................................:.........189 2. Negligible Damage
......................................189 3. Reparable Damage ··································:·····190 4. Damage Requiring Replacement
................207 V Empennage
........................................................209 I. Description
....................................................209 2. Negligible Damage
......................................209 3. Reparable Damage
........................................210 4. Damage Requiring Replacement...
...............230 Section Page VI Landing (;ear
....................................................234 1. Description
....................................................234 2. Negligible Damage
......................................234 

# I 3. Reparable Damage
....................................234A 4. Damage Requiring Replacement
..............234A 5. Repair Bushings
........................................234B VII Miscellaneous Repair Information
....................236 I. Rivets and Bolts,
...........................................236 2. Welding
........................................................240 3. Balancing Movable Control Surfaces
..........242 4. Fabric Repair
................................................257 5. Plastic Window Repairs
..............................260 6. Terminal and Taper Pin Joints
..................266 7. Seam Sealing
................................................267 8. Corrosion Resistance
....................................269 9. Electrical Bonding
........................................273 VIII Tables
................................................................275 I. Decimal Equivalents
....................................275 2. Conversion Table of Sheet Metal Gages
....276 3. Die Numbers for BAC Sections
..................276 4. Heat Treated Parts
........................................280 5. Material Specifications
................................282 6. Body Materials and Replacement Parts
......282 7. Wing Materials**a~d** Replacement Parts
....363 8. Nacelle Materials and Replacement Parts
..430 9. Empennage Materials and Replacement Parts
..............................................................468 Appendix I
......................................................................501 Appendix I
..............,.,:.....................................................533

f!evised 25 March 1945T. 0. No. 01-20E-3
gang channel nut plates used for the fuel tank door con· nections in the wing, for example, transmit•shear load but negligible tensil·e loads. Thick self-locking nut plates under bolt tension loads are rated at one-half the bolt's rated tension strength but must not be used in structural members or joints. Replace damaged nut plates with the same, or equivalent, type during nonstructural repair work. (2) DRILLJNGANDREAMING PROCEDURES. -Care must be exercised when drilling and reaming for light drive fit holes. Less than .00025 inch from the proper amount of overlapping will destroy a light drive fit condition. Drill and ream procedures for light drive fit bolts are as follows: 

### 7i 6 • to 1,4-inch diameter bolts with tolerance of 

## +-000, -.005 Drill 

### % 4 inch under final ream si,ze, Ream -.001 inch under the**ma~mum** bolt diameter.**~i** 6 • and %-inch diameter bolts with tolerance of 

## +-0000, -.0005 Drill 

### Ya 2 inch under final ream size,
. Ream -.001 inch under the maximum bolt diameter:**~~** 6- to %-inch diameter bolts with tolerance of 

## +-000, -.001 Drill 1fa2 inch under final ream size, Ream -.002 inch under the maximum boJt diameter. Ream sizes are to be as follows: 

# I**~)** 11 to %-inch diameter:-.001 on the maximum bolt diameter with tolerance of +.0000, --:--0005. 

### y; 11 - to %-inch diameter: -.002 on the maximum boll diameter with tolerance of 

## +-0000, -.0005. (3) BOLT SELECTION.

(a) Do not use steel bolts smaller that 10-32. Bolts may be substituted for rivets of e<juivalent size, provided holes are reamed for a light drive fit and the hole is never enlarged more than 

### Ya 2-inch diameter over the original manufactured value. Greater enlargement will necessitate replacement of the complete part to avoid dangerous weakening due to loss of material. (h) When AN bolts are replaced by NAS dose tolerance bolts, use the next larger size close tolerance bolt and ream to fit. When rivets are removed for at· taching gussets, <IS in the case of wing spars (figures 88 

# Iand 89), they are to be replaced by either AN steel

bolrs or NAS steel close tolerance bolts of the next larger size provided -they do not exceed the 1/32-inch 

# I diameter enlargement limit. Ream the holes to a light drive fit and replace the rivets with the same number of steel bolts. Rivets removed in anticipation of this operation must be extracted carefully so that the holes are not deformed in any way. (c) Bolts that will be used in making repairs 

# I will be the AN 3 to 16 series or the NAS 53 to 66 series. If a close tolerance bolt must be removed and the hole is slightly damaged in the procedure, a 1/64-inch over· size or a 1/32-inch oversize close tolerance bolt may be used by rereaming the hole to fit the oversize bolt. (J) Bolts selected for a connection must have unthreaded shanks long enough that no threads will be subjected to bearing or shear by the material through which the bolts pass. At the same time, sufficient threads must be provided so that nuts may be drawn up tightly without fear of jamming, or lessening either bolt or nut effectiveness. To accomplish this, in some cases, it may be found desirable to insert washers between the nut and the surface against which the nut is to bear. However, no more than two washers may be u6ed in this manner for any specific instance. (4) TORQUE VALUES.

(a) Torque values (wrench forces) for tightening nuts on steel repair bolts are often required in structural assemblies. The following tabulation lists acceptable torque values for such applications: BoltSize

10-32 %-28 

### :X 6-24

o/s-24 Torque, Inch-Pounds 20 to 25 , 50 to 70 100 to 140 170to 280 (b) These values can only be applied where the bolts penetrate solid material, such as a round or square tube containing a filler block, castings, and forgings. Shims and fillers must be used wherever necessary to prevent distortion of the joined members. (5) TENSILE STRENGTH VALUES.-The tensile strength values of steel and aluminum-alloy bolts, in conjunction with thick self-locking nuts (AC365), or castle nuts (AN310), are listed in figure 18. 2. WELDING.

The succeeding discussion p(·rtains only to steel parts in this airplane, since welding of structural aluminum· alloy parts is prohibited. All stress-approved applications of welding are discussed in section IV. Other repairs requiring welds probably will not return the full
Revised 25 May 1944 -240-T. 0. No. 01-20E-3 strength of the original part. Therefore, welding of members other than described in section IV is to be considered as an extreme emergency operation and cannot be recommended for permanent repairs. Greaf care must be taken that the welding process does not further weaken the part rather than strengthen it.

a. ARC \\'ELDING.-In electric arc welding, the metal pieces to be joined are brought to the proper welding temperature, at the point of contact, by the heat liberated at the arc terminals and in the arc steam. The electric arc is a sustained spark across two terminals, or electrodes, current for which is usually supplied by an independent generator, either electrically or mechanically driven. By this process the metals are completely fused with each other and solid!fy into a single homogeneous mass.

b. GAS WELDING.-In gas or oxyacetylene welding, a high temperature flame is produced by igniting a mixture of twogases, usually oxygen and acetylene, in the correct proponions and at proper pressures. The gas welding process re<juires a separate supply of oxygen and acetylene, a torch with coo'trol valves for adjusting the mixture and regulating its flow, and vari?us minor accessonc:s. c. WELDING TLCHNJQUE. ( 1) Before a satisfactory weld can be accomp'lished, the materials t::> be joined must be preheated in the vicinity of the weld. This precaution tempers and pre· pares the metal $0 that warping, and local internal strains due to the intense welding heat, will be minimized. The temperature for preheating X4130 steel should be about 233°C (450°F), and may range as high as 288°C (550°F). In the case of torch welding, preheating may be easily carried out with the torch itself, before commencing dose welding operations on the connection.**Howt~ver,** for arc-welding opt:rations some extraneous source of heat such as ablow torch will be re<juired. (2) All welds must have physical properties which comply with the minimum process <jualification**req:..~ire·** mems for welders (AAF Specification No. 20013). The welded section should be homogeneous with low porosity, free from cracks, blow holes, or slag inclusions, and the finished product should be smooth without excessively large ridges or craters at either end of the weld. Undercutting of the base metal at the edge of the weld is prohibited for all aircraft uses. Welds that show overlap, which is the extension of weld metal beyond the limits of fusion, are nor acceptable. Fillet welds in X4130 steel should be convex, humped, or flat. A conca,·e-dished contour is not considered good p.ractice for this application.

- 241 - (3) All points in the weld should have good penetration, which is thorough fusion between the base metal and the metal added from the weld rod or elec· trode. The welding operation must be performed ar :'( speed slow enough to insure complete melting of the base metal, because the success of any weld depends upon perfect admixing of filler metal and parent metal. Filler metal must never be placed in a joint without thoroughly welding it in place. Welding should not be done with the joint under tension, or the metal may crack after cooling.

d. WELDING PROCEDURE. ( 1) Prior to welding an assembly the operator should know the exact welding sequence, as determined by previous experience, and the anticipated results. He should then follow tbis procedure exactly, observing the direction of welds, starting and stopping poinrs, and sequence of passes. The parts to be welded must be properly prepared before the welding takes place, and the usual processes of cleaning the parts of all dirt, rusr, scale, or grease arc to be observed. Sand or stef:! blasting is recommended for**cleanin~** X4130 steel parts. The parts should be supported firmly, but not too rigidly, because expansion and contraction should be allowed ro take place without undue restriction. Preheating is then applied to the surfaces to be joined, in the**ma.t~N~e/** previously described, and the welding operation**i~** subsequently carried out. The work should not be pur uncle! stress, unril gradual cooling has lowered the 1temperature to normal. In some applications it may be\desirable to grind or otherwise finish the weld after it has cooled ro give a smooth continuous surface. (2) When welding is accomplished electrically, the arc is formed between the work to be welded and an electrode damped in a suitable holder. The instant tht' arc is formed; the temperature of the work at the weJJ. ing point, and at the welding electrode, rises <juickly from normal to approximately 3,600°C (6,500c'F). This high temperature is concentrated at the welding poir.t and on the end of the electrode, thus melting a small pool of metal in the work, while any additional metal that may be required is obtained from the metallic elec· trade. In case a nonmetallic electrode is used, a filler rod is fed into the arc and thereupon melted and deposited. Filler rod may be used with either metallic or carbon electrodes. (3) The gas welding procedure is begun by preheating, with the torch flame,**th~** contact points of the metal pieces to be joined. \X'hen the base metal is at molten temperature, the weld metal is added by meltingT. 0. No. 01-20E-3

a filler rod of suitable composition at the point of contact. Gas welding is a "puddling"**proces~,"**that is, the molten metal forming the weld is in a small pool over which the flame is constantly played. Making a weld by this process consists largely of causing the pool to progress across the welded area by melting metal ahead

.of the pool, and allowing cooling of the metal behind the pool. Maintain complete control of the flame, and keep it as nearly neutral as possible. However, because of the difficulty in maintaining a neutral flame, it is generally operated at a harmless, slightly reducing condition. A neutral flame contains a balanced amount of oxygen and acetylene. It is characterized by a maximum length of the inner cone of flame without a white "feather" at the tip. A reducing flame contains a slight excess of acetylene in the gas mixture, and may be recognized by a small white "feather" at the tip of the inner cone. An over-excess of acetylene causes the steel to pick up carbon, resulting in a brittle weld which**m:~y** be further weakened by cooling cracks during contraction. (4) Air should never be allowed to come in contact with the molten metal because the resulting. oxidation greatly reduces the strength of the weld. Wherever possible, it is good practice to weld in a reducing atmosphere, preferably that of a hydrogen fiamt. This practice aids in preventing oxidation, and improves the strength of the welded pans by eliminating localized air hardening adjacent to the weld. 3. BALANCING MOVABLIE CONTROL SURFACES.

a. GENERAL ( l) It is important char any movable ·control sur· face be balanced. A control surface char has had a major repair, several minor repairs, or has been recovered or repainted must be checked for balance. (2) Figure 152B sheets IX & X show details of the jig used in balancing control surfaces. b. CHECKING PROCEDURE. (l) Mount the control surface in the balancing jig without the auaching cables, locks, rorque tube, etc., at the hinge points indicated and in the position shown 10 the Mounting Diagram (Fig. 152A). (2) To hold the control surface in this posicion, ir is necessary to apply a fofl:e, in pound:;, at the trail· ing edges of rhe ruJder and elevawrs and at the·balance weight of the ailerons. (3) The Mounting Diagram (fig. 152A) indicates the direction of rotation for a positive (

## +) and a negative (-) unbalanced weight. (4) When the direction of rotation for the rudder and elevators is positive (

# +), the weight of the balancing cone must be subtracted from the scale reading co obtain the unbalanced positive (

### +) net weight. When the direction of rotation for the rudder and elevators is negative (- ), place an object directly over the balancing cone point of enough known weight to cause the control surface to rotate in a positive (

## +) direction. Add the weight of the object and the weight of the balancing cone and from this sum subtract the scale reading. The result is rhe unbalanced negative (-) net weight. (5) When the direction of rotation is negative (-) for the ailerons, subtract the weight of the balancing cone from the scale reading to obtain the un· balanced negative (-) net weight. When the direction of rotation is positive (

## +) for the·. ailerons, place an object directly above rhe balancing cone point of enough known weight co cause tht: !lileron co rotate in a negative (-) direction. Add the**~eight** of the object and the weight of the balancing cone and from this sum subtract the scale reading. The result is the unbalanced positive (

## +) net weight. (6) The unbalanced net weight, in pounds, times its distance, in inches to the nearest tenth, from the hinge line is the unbalance moment in ipound inches. (7) Compare the calculated unbalanced moment, (positive (

## +) or negative (- ), with the graph corresponding co the concrol surface and make rhe ad· justment in weight if an adjustment is necessary. A variable of ± .75 pounds will be allowed in the weight and the unbalanced moment will still be within the tolerance.

c. ELEVATORS WITH FABRIC ATTACHMENT REWORK. (1) Figure l52B sheets Ill and IV are graphs for the elevators that have not had the fabric auachment reworked. These elevators may be recognized by the clip fabric attachment. The reworked fabric attachment is a channel fastened with screws. d. GEARED TRIM TAB CONTROLS. (I) Figure 152B sheet V is the graph for the rudders that have the geared trim tab controls. Tab controls should be absent during rhe check of the rudder balance.

Revised 25 May 1944 -242-

### .. 

### '· 1' :.,;.**~::.·. -~-**  

# f:'
.. ..**~** :·**-~** •)' ;.)' 0**·J..~** :- '-

### ..} o::**~** t!i ;J

..**~** . I I



## FIELD SERVICE



# SECTIONS MANUAL

...,.__,._,.,...--..,-........,-**~-~,** .... 

### f'.,:· . . 

### .•:-> ·'?:

. . 

## t.
.•'

.**);-_!~** •**-~ -~'**  ••**~** 

## l. FORTRESS**~AeTS.** 

## · ..· ; : '·.

.;..

# :,,~**~; J~fj~itf:":** 

# •.**:i.,.""n~\** ': •**,~** .·"**,,¥~\·: "·i·[.;;~-"** **~~-** ·, • , ,

### ~

# .:..t:.oH'

# ·!ra&n.tif£·:··:.. ·

:.... ·'

.**.~· :'···~** 

'' .;->. ••



## f.:

# ~ "/.·

# ri~·~rir:·

# .~·~11ti~:-:.~~**~":?.**...·:-· ' ·,"b.-.VIIi:.J.-V:Q
..:·Da'I;Jt,,r.,··"'1• · 

## l.:.; ;j.::-::-:- !',**'~<{,~··::7**

## ,.;::.{**~** 

## .'·

GOVERNMENT EXHIBIT 

# 1--v
__

### HOW TO VSB THIS BOOK

.. :t**~~** ...



## F 

## 0 

## B T 

## B B

...

# -

...**~··--·**

___..

## ---··- 

# s You will find the complete alphabetical the end of this manual useful for finding lncuv;,,M;:; i1ems, while the tabular index, with a'little**ptaLC:tii!~** will become the quickest way to locate a use the tabular index, first opento the chapter for the proper section. The chapter indexes colored pag0s as follows; "Fortress Facts" tenance. information, yellow page); "On the (ground hnndling, lubrication, etc., redpage); "In Ai:" (flight charts and check list, blue page):
_ Dut:;," (orange page). Fromthe chapterindexyoucaii. ind the desired chapter by following the black down to· the corresponding black marks on the edges. A special effort has been made to give you tical electrical information. The "Electrical · Shooting" chapter contains general information, the "DC Power" chapter covers the main

- circuits. All other electrical information with the systemto which itbelongs; feathering pump circuit is in the j.;'VJ'CJ.'neuer ter, etc.**-~~**··(
. ,,_,.,, ·' Trouble charts are**gi"{E;tri:·_tor·A:;ml~-~** terns. They are placed 

### at_'the Note 

### also that**then~·** is**mu~h** 

# v.,....**~,..~-.J"'7i'T\''"''""'=-·** the "Useful

### Data" section. 

### Look:



# -- 

# ----

s F Jl 

# c T 

# s

,.....

# -

\ 

# -·- -"i·**~.** i l 1- 

### ')'O_RT.RESS STRUCTURt ··.·.' .·' 1 .EQUIPMENT 21 .FLIGHT

### ~ND ENGINE c:;ONTROlS
----- 21 ENGINE_ AND ACCIS$Q.!UES ·· 65**PllOPE~ERS** ... JI1111!1 .......... _____ _.. TURBOSUPERCHARGER 

### AND' SYStSM·•·......

. . . ' fUlL SYSTEM· •.•.---------· '**-~** OIL

## SYSlEfA~ --------.. -.-..161

### HYDRAU.U~_SYSTEM·•

## ---11111!111111!111111! . .-...-· F 

### Jl C 'I' 

### S ·

## LANDJ~G. <:;EAR: •.--------· .. VACUUM AND**DEIC~R** SYS_TEM ·-11111!11111!11111!111111! ' lNSTRUMENT$ ' 

### . '

. HEATI""G**~D.** VENTILATINc:,;
............ .

· .

## OXYGE~ .SYSTEM

---------

ARMAMENT Ea..

## ~-~-------· eLECTRICAL 'TROUBI$

### ·sHOOTING

------ 379 D. C. POWER 391 liGHTING .· ·.·411

# ...J

.. ' . .**~**

# ~APIO ------------•. •.419..,



### .· ..- ..

# ;-~~/**·,~ ~-;·** **~~~~ ~--·---~-·-·~·~-**  _.**~~**

# ·~~ .

' 

## .f

# ~ t t**·~<.':l{l!;l~Jfl!!f~,'.''~J{;'1~'t'**'\• , '":**~**• ' "\"'**~.1)**·< r:**~**1>" :,tn
....**~~** ., l-'
..,"'
..,.**~·~"o;;;"··...** 

### \·
......**-~h:~. """"'tt:~::\"'>i~"""**  ;;**~** _.,U Sflf..sfALIN'G HOSE SHALl 8( IN ACCORO)I.NCE WHH AIR ,**~'f~ CO~S**  51'f.C. 26j87 AND SHAll**SAfiSfACJO~IlY** RESIST O[Tf.**~""'-.:':i==d 7~'**  Rto'unON FltOM AROMATIC FUEL WIJH A**CON.PO~ITION** Of
• p 60, 100 OCT.ANE GASOt!Nf. 10•"' TOlUF.NE. 15•
.. X"t'tf.NE ANO 5'- BENZfNt. TVI!IING COlO!:.' IO[NliFI(AliON. R(O



## ..

### •-

0 w 

## ... v 

# "'
.... 

## "' w 

## ... ------·· 1ART 

### --·--·--·---·

.A-NO.1 A.; ENGINE TANK a-NO. '2 & 3 ENGINE TANk C
..FfEOEP T}.NK o-S0051ER PUMP [-fUEl STRAINER f-ft-IGINE FUEl PUMP G
..·flJEl PPfSSUR£ TRANSMilftR H-Oil OflUTION VALVf t-..C.ARBURETOP J-fUfl HMNSffP. SHfCr VAlVf. K-TRANSFER PUMP t-BOMB BAY fl)fl tANK M-PRIMfR**N-IU~TRICliON** fiTTING Q-TANK'VENlS- UNDER SIOF. OF WING p-FUEl s.HUJ.Qff VAlVf 0-T

..NK fillER NECK R-<lll DRAIN COCK ASSY S-DRAIN COCK T-.OUTBD. WING T"'NKS NO.1· U-INBD. WING V.NKS NO.6 ·9 V-V

..lVE-TRANSFE" SERIES A W-CONTROl-REMOTfMANUM X-SYPHON y•.JANK OR

..IN VAlVE Z-FUElQUANTITY GAGE 1fo* tiS[O ON f.ARU1R MODt:l l! !]C.'S

• e 1.G**!l~lil!.~·**

IMPHHAl GAllONS ·&Ol!NG**~PfCIFICATION** DfiAWING. LINE SillS fU£l p.,,.....P t{) ( .'..;ttUJ<£ TOS**ff~l)ff.** : ...N), I(• ND :'**.~.** J FNGINf !:,!..<!>: Q1Jlr.1o v.:iNC·**~A·..!(~** I •; H) N() I/'...! F.NC.H.Jf lt.o-.:•· INI\D '-''iNG fA'l;.::, (..-9**~()** UtDt:q VNY. v{N; 1A.rJr !<fJ 5 TO lMollt NO Q rE£O[R iO 2 E. \'f.NI**u:,;f~,** t.;C• ! 6o c- TAN"S TO IJNtl(k ;tOf. OF wq-Mj**\.'~NI ~·N[)** **(!.OL·I~~** ; S. .c T
...**N~:i** HJ NO i**t~~oHJ.** 1Httt.2**~Ar·l!<** i(; NO**~-** ;t.:./;, VENi lt4:1 '.·r.**U:-1<'1~0:·1·~~:, ~/•N•;S**  NO I 9**P~t~·.!'t: rsa~~,t•;.:(** **tl:-11.~** ruh VA.PC>V.**~J ·.~Q\'4;**  iltJlS f,ll OlHtR ll"lf.';

FUEl SYSTEM DIAGRAM-LEGEND : ,l

.... ; 1.i.t ' 

### ,,**~/~** ' ·' 1/.t. ' L 1/•l



### .. '< IJ

## " .:) 

### " ' ·J ,., 

### ,, " '··

# . r; ') ,,. C• !i

FUEL SYSTEM**--~.** 

# -----**-=~:**

# \ FUEL SYSTEM Each engine has an independent fuel supply. TJ1e outboard engine supply (engines l or 4) consists of a main lank. and five wing tanks ("1" to "5"). The inboard engine supply (engine>s 2 or 3) consists of a main tank, a Ieeder tank and iou.r wing tanks ("6" to "9"), The wing t.lllks (also called "Tokyo" tanks) are collapsible. In addition to lh•,.se, ihe airplane can carry two auxiliary**relea;;abh~** bomb bay tanks similar in construction to the main tanks. The iuel in any engine supply or bomb bc-.y tank can be transferred to the supply ol any other engine or the other bomb bay tank by the fuel Transfer System. All tanks are the self-sealing type with non-metailic shells. When damaged, the tanks must be replaced, or repaired per T.O. 03-10-26, and T.O. 03-1-15. A booster pump, a solenoid fuel shut-off valve and a strainer are used in each engine's fuel system between the main tank and the pump. There are drain '· alves in the bottom of the inboard engine feeder tank and the main outboard en· gine tank. NOTE-To prevent injury to leakproof lining when draining, hold base of valve with a wrench while opening drain
. fVEL SYSTEM - ----- PI!OP£lUt

----MOUNTING fl""t!

WATER DRAIN PlUG
SEAl OR

..IN PlUG-----'
CONDENSER-----------'
MOTOR (ElECTRIC}--------'
RECEPTACLE------------../ FIGURE 89-BOOSTER PUMP 

# \ 

# t •I t •

.,. BOOSTER pUMP Thompson TFD 12000 Purpose- !. To insure fuel 1;: :he engine luel pump.

FIGURE 90-BOOSTER PUMP CIRCUIT M ., \I ) /**~II OU<BO~R.O** 

will nliow tho p.,ckins n. <h,;Dr:e to !So<Jk up.) 3. Cht>ck the**l.•o•.>:>H~J** pump rr<?ssurc. it should

not E'X•'oed 17**l'~3J.** 4. Tighien**h,~Jt;;** tn"•.5nly wlwn il•st<.>]JinrJ booster

pump. Thi" j->11.!\'' 11\:·, da;n,JGG !c illt 0l i<n•k. fUEl SHUT-OFF VAi.VE Elec!rimatic 7660 Purpose--To shut ofi ll1E'**Pl"•SJlJJ·~** .supply J! 1he fuel line is severed. Location--Valves im tanks No. l and No. 4 are forward of the tanks between the oil coolers. Valves for tanks No. 2 and No. 3 are between the tank and the rear spar. Operation-This is a solenoid valve. When the swilch is closed, the solenoid overcomes the spring holding the disk against the seat, and shuts off the fuel flow. The four switches are on the pilot's central control panel just forward of the "boost pump" switches. Remember, no power-no fuel shutoff! Service Information-Inboard tank valves are accessible through access doors aft of the inboard superchargers. The outboard valves can be reached fUEL SYSTEM 2. To p•<lvent any vapor locks in the· fuel lines at hi(jlt altitudes. 3. To pro·.ride gasoline to the carburetor when starling the engines. NOTE-The No.3 boosterpump supplies fuel for priming all engines. location--At the outlet under each of the four main fuel tanks. Operation-The centrifugal type booster pumps are controlled by four toggle switches on the central control stand. Fuel is drawn from the bottom of each main tank through a screened outlet. It is delivered to the engine fuel pump at 6 to 12 PSI. which is sufficient for starting. A drain is provided for any surplus fuel that leaks past the pump chamber. These pumps have enough blade clearance (.08 to .12) so that the fuel flows through freely when they are not runnina. Service Information- !. Replace motor brushes when they are worn down to 5.'16" (1;2" original length). Check often. 2. Replace the pump if it leaks fuel in excess of ten drops per minute. (New pumps often leak -allow the pump to run for hall an hour.This FUEL SYSTEM

··-- - !.01t:NO!D CG'/tli**fH.<.l~ltAt ~t)\f.llf.H~**  ':Oil**~14 VVn~tY:i**  I\)'. ( ·IJPPE'!**"IH:r~.(tf CO~£**  ·- lOWF.R llilMBlf ------·..··- Til ROO
...**-----·----.;.,.;~~~-**

FIGURE 91-fUEl SHUTOFF VAlVE 0

.... .... u Ci t; w 

### "' 

# .

l 

# \**~MH-** J'N.' _rl:t'**-~\-** •· "'f4;/-1f



# I 

# LJ**~,____** ---- WING NUT .FIGURE 92-FUEL STRAINER

l - t" 1 ,-.r·' H tht:' !·, t r**(~** 1 n \,**~:** Gl't\:?f!fl bt'corncs ! lt:-".:' Oll
. t t.

1 J the fue::-J**flo\v~** thr·:,uqh i:tc**CL'1l1~~·,ll** cen:.v;**c:oggP~. ~**  screel1 and ouL Service lnfonnotion --l'J,,;n**:~tr~llll<'l:'>** eilcL <:iay and cJe,1n every 25 hours.**\\'i~en** the sCJcerw become:· dirty. the eniiJ€ screen ...-,;;**~;1dV** l.H' Jii(,,.,_; out anr' cleaned. NOTE-The lockvnrcc; v ..·ir;(: :1u: .:JJ IIl<' ci·'InP lvhich h:Jlds the scrPr·n :r**iJ~,_:, ~-;7:~i;IJcr**  hou.s:- ing. should be onlr f;n<yl ;!qht CJ'IGINE FUEL PUMP Type G-9, Spec. 28339 Pu1pose-To supply fuel at a predetermined pressure to the carburetor. Location-On the right-hand engine accessory pad.Operation--The vane type, engine-driven pump supplies fuel at 14 to 16 PSI. This is a differential pressure between the carburetor air pressure and the fuel pressure at the carburetor. The correct pressure is maintained by an adjustable relief valve in the
0 pump and a balance line connecting this valve to the

.... ti carburetor air intake. Until the engine pump starts,**~** fuel under pressure is for.ced through the pump by-**~** pass to the carburetor by the booster pump. FUEl SYSTEM 1\}:,.(l,'jtj{J
.... :·..:.< 

### ,. 'fiJH**t;.Htlt(,.~J:: ~W1':'C.t-4f',**  lt;l

r· ,_. tf1 :,.,.·

. Pl Xl'.X!K**~~. -~•**  j D JJ 1: • C 8-" U :::.:;.

SA 

### I
I f>'26 "UN DC FIGURE 93-FUEL SHUTOFF VALVE CIRCUIT through access doors in the underside of the leading edge between the oil coolers. Cap the fuel line on removal of valve_ Check valve by noting pressure drop when the valve is shut off. The solenoid is designed to hold the valve closed indefinitely without failing. FUEL STRAINER-TYPE C-4 Aero Supply 13960-3 Purpose---To remove foreign matterfrom thefuel. Locution-Ontheforward side ofnacelle firewall. Operation-The fuel enters the "in" port circulates through the strainer screen and leaves through

,,,,

OVT

.. DRAIN P!J.iG**'-~** \ 

### ___ l fUil SYSTEM**~El\Ef '1J..1.~**  

# r**~''~;u**

I, \ \ \j ''OltMU**~~~------PIJ.lt** I L -- 0\Afli'IAG" I**~---m** 

### L --RE'i.ltf Y.t.t\tt**r-·---------S>.\>A~C~U**

'------- REliEF VAL¥< CO'Iil L-------------HOUSING FIGURE 94-ENGINE FUEL PUMP'


### ... ; 1

I


### ... ' v•:uu... CKECr. 5r.ltNG

ow:; Si'IINC -----" "------PlUG IIO!U CHECK lNS£P.T ----' '-----ZAll VAlVf FIGURE 95-ENGINE PRIMER

CAUtiON --Do not l•.!•WC: )Jandlo or plungei in the out pr,sition as tllis allowsfuel to pass diJectly**throuc_~h** the? primer to the engine selected. Rememhe;! A leakill<; pzime1 can calise a d.wge;ous liqwd lod: and a damaged e11gine. Check f01 p:**irm~r** leaks i'il eac-h engine start o.nd a; c:,1ch 25 hour inspL'ClicJl. FUEL TRANSFER PUMP Romec RG-4430-2 Purpose--To tJc.nde: h:e: frm:! OJJ.G tank io another. Service Information- -To adjust fuel pressure-- ]. Run :;acpne at 1000 RPM. 2. Loos•.:r1 the lock nut on the rear of the pump. Turn tl: · ?.djustment screw clockwise to raise and evilnterclockwise to lower pressure (abom 2 turns per pound). CAUTION-When pressure is adjusted tighten and lockwire the locknut.
ENGINE PRIMER Parker Appliance 401-4A Purpose-To prime the engine during starting.**~'** location-On the floor at the right hand side wall in the pilot's compartment. Operation-The fuel is supplied the primer by the No. 3 booster pump, and is forced into the top 5 cylinders of the engine selected. Service Information-To remove the primer, open the access panel on the right hand side of the body and disconnect the five "IJ4" fuel lines. Remove the mounting scre.;.s from within the compartment. If fuel leaks around the plunger, tighten cap. FUEl SYSTEM

Location-In the iorward end oi :he bomb bay on**sF~,..,c,** top of the catwalk. Operation-The pump is driven by a reversible electric motor. The switch. on the forward side of Bulkhead 4, is lhrov;n in the direction in which the fuel is to betransferred. The pump can transfer about 900 GPH at sea level. The electric motor is explosion proof and is designed to operate at altitudes up to 35,- 000 feet. The transferred fuel lubricates the pump. Do not let thepumprUn after the tank is emptied. Let · @ the pump motor**s~op** before reversing it.**~** 

## E Service Information-Replace the pump motor ...: brushes whenworn to a length of '1. inch. FUEL SYSTEM FIGURE 96-FUEL TRANSFER PUMP 0 w 

## ...**~** "" ,_ 

### "' w <X

# r.
. ' SNAPRit'O -·- -·---·-- SPIOfR
·• -··· ---- SPSUNG FUEL TRANSFER SELECTOR VAlVES Boeing 9-3663 l

# .**Jf';~"'!ooo""---** ------------ V/l.lVE

SPRING !At<K PORI PlUI<GEA CUIDf (.I.JI.. l'lUNGH ---··J SHAfT 1NLETflK>M I'UMP

---- w,r.SIIfl AND SNAPRING**----------~ TAP~**  PIN (----··-**~PRING** 1 

# r·--- T """ .0., ) I ) /

FIGURE 97-FUil TRANSFER SELECTOR VALVE

C•·!a**0~** ( _•. V.:..l\'f .+..

r--"'- • I 

## I Purpose-To direct fuel from one tank to another. Location-On the bomb bay forward bulkhead beneath the door. The control handles are on the forward side of the same bulkhead near the floor. Operation---When the shaft is turned, the cam depresses one ol the cam plungers and opens a pori. Both of the selector valves must be set. one far the tank from which the fuel is taken and the other for the tank where the fuel is to be sent. When the pump is started the fuel enters at the port next to the tar.k from which fuel is taken and exits through the port connected to the transfer tank. A safety switch on the transfer valves prevents the pump from running unless the ports are open thus eliminatiagpossible damage to the valves. NOTE--To transfer fuel from one tank to another tank on the same side of the airplane you must first transfer it to a tank on the other side of the body and then transfer it back to the proper .tank. (See Fuel Transfer Operation Diagram.) Service Information-Check operation at preflight inspection by "feeling" the flow in the line. fUEL SYSTEM 

# ••

NOTE, DIREO TRANSFER C"N ONlY B! MAD! ACROSS CENTER LINE OF AIRPLANE**,-----r-----------------------~** DESIR£0 TRANSF!I**J------0-P!~R-AT_Ic:N:::::O:-:F**_co_N_TTR_OL_s

_____**~**
lEFT KANO TO RIGHT HAND TANK**~XAMP!E:**

FROM l!FI HAND BOMB BAY

TO ENGINE NO. • TANK

FUEl SY!>TEM R.H. IIAlV! SWITCH FlOW PATTERN l.H. VALVE

FIGURE 98-FUEL TRANSFER OPERATION DIAGRAM-StfT.**-~.** 

## ... ·U ii ' 

### ....



### "' ·w I>! LEfT HAND TO lEft ti.A.ND JANI':: 1TWO fRANSffRS REOUIRE'OI

EXAMPlE

RIGHT HAND TO**~ffT** d.AND TANK fXAMrLE fROM RIGHT H.t.ND 80MB !lAY

TO fNGINE NO 7 TANK

JUGHT HAND TO lUCHT HANfi T.ANK iTWO TRANSFERS RI:QUIRf.tii

EXAMPL£ FROM ENGINE NO. J TO ENGINE NO. 4 TANK DY wAY Of £NGINE NO. I TAN< FlOW PAnERN

0 w ti ii 

### ,_ "' w 

### "'
FIGURE 99-FUEL TRANSFER OPERATION OIAGRAM-SHT. 2 fUEl SYSTEM

Cover the bomb bay l<:nk ports o.n the selector vah'e with 6" length ofpluqi]Gcl hose •vlwn the bomb hay tanks are disconnected. CAUTION-·--Do ret ';:: ;; seh?ctm vaive to bomb bar tanks u:•''·· ,_.,.. '.k';· a;'·' cvr:ncc!ed. E-5 FUEl**VAlVES-SERif:~** 0 CR ['

..5 VALVE Denison Purpose-To confzol**trc;nst~·r** of lv.el between the wing (Tokyo) tanks and the m;Jin fuel system. Location-The E·S vaives are near the centerline of the outboard nacelles, one just behind the front spar, and one just forward of the rear spar, in each wing. The manual control units are in the bomb bay on Bulkhead No. S (two on each side of the body centerline). The D-5 controlunits are ontheforward bulkhead ofthe radio compartment. Operation-This spring loaded hydraulic valve is normally open. When the control handle on the manual control unit is turned, a sylphon (actuating bellows) is**compressed~** This transmits pressure through the pressure line to another sylphon in the .E-Sfuel valve
.. Thispressure overridesthe spring and se.ats the valve thlli3 .closing the fuE!l line-between the EZ



### ' t

FUEL flOW ------' FIGURE 100-E-5 FUEL SHUTOFF VALVE wing (Tokyo) tanks and the main tanks. The unit·isa completely independent self contained**hydr~ulic** system with a sealedin, constantpressurefluid. ·· 

# \ 

# t \ l

## I

Service Information-If an,y part o,f. this uliit, ).s damaged, the two sylphons (actuati,ng**bellows}~d** : the connecting fluidtub.e must be repiaced

## a;; a**~t** .:,

. .:.• '

. . :'-'•

. ..•**"""~,** i 

# ·-·

# ~-- ..

# ·~**.:~·~I::dJ**0 "' 

## ... v 

# "' ... "' w <>< SETUP INSTRUCTIONS FOR StRitS •o• VAlVE L TURN HANDlE COUNlER-ClOCXWISf

UNnl HANDlE IS**~ll** THE WAY our. 2 MEASUC!t: DISTANCE

### 0 WHJlE HOtC· INC HANDlE: IN TH( OUT POSITION. 3. TURN HANOlf:: ClOO:WtSE UNTil All SLACK HAS SEEN' TAt<.£:t-1 UP. (.**MEA!~U~f** DISTANU:(f) VIH1LE HOtO· lNG H.l.NOU**1:~** TttA.T POSITION. iHE DIFFFirf=NU 01 TriC: tWO**F-IGURE~** NOT't:**~S** THE- SElVP**LiiMf!l·lSiOI~.** 5£TTIHG T£MPfRAT\IRE FOUNO AS FOI.tOWSl I 7tu..:li..Y.f'.llot "i C:l 11-lt !+;o.t;U1.t C()r.J'f'')t 2**~**..**~TEMP.** It-: ·r· (J!- 1Hl ).ll.tNSHR .,,.,tVf. .:SO**~:''** + ..50 h =**~l** T"1**::.:!.~ lE~t-.fl:JM":U::t** **SETT~NC.** TlMPE.A.Att!RE
i**~tC·** l2P 110 10C 9-'"J**~·** 70 '0 5Ci •o JO 70 10 0 .10 ·10 -30 CONTROL .JO s•:.-ur**DIM.lN~ION** (';:\·:·.COO**~-.MO**

.OOo .Q20 .OJf. .050 .065

.000 MJ .1!'2 17Y .l.olb ,10.1 .180 ,197 • 21<1 .231 .1JB .765 .282 FIGURE 101-E-5 FUEL SHUTOFF VALVE ADJUSTMENT

drop of hom 9-11 PSI at start o1 dilution indi· cates that the res!tictor titling at the oil dilu· lion solenoid has been reven;ed to allow a largerpressure drop. This is O.K. After dilution. the fue] pressare should im)nHdiatciy rise to normal. 11 !he fuel**press\:r•~** does not rise at once, rem0\'8 tho dilution liue from tht-: "Y" drain cock. If fuel continnw; to 1ur
.. fro<:: this line the dilution valve k no! cb!Sed. NOTE--The oil dilution \'aive mu:<;t not Je,1Y. more than 6 dropsper minute ar JG PSI d;Jtc:rentialpressure. 2. If the flow exceeds 6 drops per minute tu the oil dilution switch on and off

## s~ver~ times and observe the flow. 3. If the valve still fails to close, tap it lightly. Great care must be taken not to damage the valve. 4. If the**fu~J** continues to flow after completing the preVIous steps. install a new valve.**~O~E~Be** sure to operate the propeller**~at en~g**  button several times during dilu**t~on.** This willdilute the oil in theIeath
. lme fS 

### w· . . enng

. ee mtenzatiOn for actual dilution procedures and times.)

· FUEl SYSTEM



# --- .---

# ..•**~~-** Check the valve for**tempcr~hlrc** setting hy loosening the nut on the bottom of the rnanual control unit to give the proper handle clearance as sho>vn ir: the aceompanying i1l1Jstn1tion (fig. 101). OIL DILUTION VA\.Vf:. Air Ass'n. Inc. N'.-441--42 Purpose-To**c~·:.:.~.J1** the How of {uel \c.· t!l<: •::i·: system for dilutinc; the '"nqine oil whon cole**Wfo,.·.t~1r.':** starting is anti<::ip<>ted. Locolioo·--On**th~** (on>'ofd side d.nd a\**th~** 10p ei each nacelle 1irew:>il. Operotion·---An elec\ric solenoid unseats <; bc1l1 valve in a fuel line hom the carburetor to the "'I" drain cockin \htl oii system. Four i.0{1gle switches o·n the co-pilot's auxilictry c:onttoi

### panel~permit separale control of each valve. or rJl four may be actuated**<~t** once by a gang ba.r ncrcss the togqles
. WARNING-Do not dilute over 4 minutes. Service Information···-Be sure the oil dilution valve is closed after dilution. Check as follows1. Note fuel pressure before starting oil dilution
. Fuel pressure should drop between 2 and 3 PSI when dilution is started. A fuel pressure FUEl 5YSTEM 0 w 

## ... v 0:


## ... "' w "'

. 

# .._...,.....
fl{-C)ql(.',.J.**~~~··t-INt CliO~'-·~** 

&All VAL'IE- -

VAlVE SEAT

PlUNGER---------'

fUEL fROM ;'-,/**---ElECTP.IC~I** CONNEClo3.t \ • l

'-- 

# ·--.: \:.**'--··-------·-U<SUt~TE!>** S>0o, 

## t**~~&----·--··-- ~IENOID**  COl f 

# 1

FIGURE 102-0IL DILUTION VALVEQ 

### -------·------------·· 

# I I

_____ j**-----~---·--·** ..

FIGURE 104-FUEL TRANSFER PUMP CIRCUIT

NOTE-A crew of SPvPral llll'll rs**necr~ssary** to remove the tanks**sa!Gl~··** SUGGESTED METHOD 01' REMOVING OUTEf.' WING CELLS J. Drain fuel from cells. To drain ,;fdls ! to 5. disconnect "T" fi:t'll?, at the Jl1••' vf the No. "5" ceiL To drain ,:-,,iJs 6 !o S di:><:r:,llnect "T' fitting at the rear of tl:e No. ·2· r:·dl. 2. To remove any of the cut-=r wmy cells, it JS first necessary to remove the entire outer wing assembly. However. before removing this assembly. disconnect the outlet, vent fittings. and ground wires on the No. 6 celL Also remove the No. 6 and No. 7 cell front doors and disconnect the vent interconnector between them. Disconnect the vent lines for cells 1 through 5 at the connection where the outer wing joins the main wing. NOTE-If a metal connection sticks, do not use a sharp instrument to pry on a rubber fitting. Loosen by squirting benzine around themetaltube.**~** 

### B u efore removing any cell. untie all cords which**~** fasten cell to the top inner wing structure. Pull the**~** cords through the top loops. When the cell has been fUEL SYSTEM REMOVAL OF MAIN FUEl TANKS L Drain tanks before starting**n~moval** operation. 2. Place body jacks and jacks at the firevrail**~f** the outboard nacelle before removing pa.neJt>. (Panel sk-h Is designed to carry its share of the struc:uni load.) 3. Remove the fuel tank access panels. .i'hr!·r are fastened by washer head screws. 

# - 4. See that the master battery and ign:tio;·, switches are "oli" before you attempt to re- move anv electrical equipment**r;onne•:t,~d** with the -fuel system. Ground the airplane completely. 5. Ground the deicer booi.s. (See Service Information.) 6. Disconnect all fuel lines and connecti.or.s and plug all open fuel lines to prevent them from becomingcloqged. NOTE-Keep all cell openings covered while ceiis are out ofairplane. 7. Note position of tank before removal to helf• in reinstallation. 8. Release tank strapsandremovetank. FUEl S'I'STEM 

# At**Nrn~wed.** c:,cil the**c~rds an~**  lay them in the top C<lrf11. 

### t rJahon rea<•)' !o1 remstallahon.
.**~** Lift the**N~l.** 6 cell out. This cell remains out "llntil \ you are re;Jdy \o re-assemble the wing unit. (Whell..**~** you**re-ir.:t~ ~!**  the _No. 6 tank, collapse**th~ bo~lom**  il\)- \ w<Hd**anc~** ho\J w1th wooden blocks. Th1s w1U allO'II \ worn ioi rearning and installing taper pins on the**~** diaqon.ll ili station 19 when the outboard wing is \ r

nL:;;ta11ecl. t 

# \ Alway» disconnect outlets, vent fittings. ground wires; remove front doors and interconnectors of preceding cells before you remove the specific cells. 3. The inboard wing now holds cells 7. 8 and 9. To remove any cell in this section. first remove the cells with lower numbers. (Be sure to disconnect the overflow and filler hathom No. 7 before trying to remove celL) NOTE-Remove the leading edge ot the "outer" wing assembly before removing cells I to 5. 4. The outboard wing holds cells l to 5 inclusive to remove a cell, first remove all higher numbered cells. (Example: To remove No. 1, !Ust remove 5, 4, 3, and 2.) Be sure to**disco~ed** the overflow and filler hat on No. 1 beforerem'oving it. t 

# I 1

·I 

## .,

### r L H Oli160.AoRD fNGf:'-1£ FlllF::t •14.? 

## I

,----·- -·---· ---· J. u • ltlStALL£0 cnu**LM_:_:_~,N~.** Nl>CILLI TO WING JO [.)flAil KffP I!ADIU5 Of 8ENI:' AS lARGE A5 1'0\SIO:f 

# w-ll

0 "" G ;;< INSEP.l C,[tl ON SA..ME.**A.t~(ioll** ...**~** Ej W;"-10**~.1\;** S1'(.UT Af! [f'j0 fik-::,T a::: RGURE lOs-INSTALUNG OUTER WING CELLS FUEl SYSTEM

Collapse the wing cells (1 to 9**exc~pt** 6) bcS. fore removal. Two men inside the wmg

### pla~e straps around both ends ai1d**t~~** middle! of the cell, then pull it down into pos1hon, and fasten the straps. NOTE-Do no/ use 10pes to collapse cells. Suction can be used to collapse them. 6. Turn the collapsed cell on its side with**th;:~** bottom (the side which has no filler nccb; or doors) toward the worker. It takes nne rnan inside the wing and two at the f01ward t>nd oi the wing to do this. The man inside the win9 then handles the aft end and helps the other two work the cell. forward end firsl, thwugh each section at the large, lower strut triangle location (see diagram) until the cell is re· moved from its location. 7. Examine each cell carefully. COLLAPSING CELLS FOR INSTALLATION NOTE-Warm cell to room temperature (65°**~** F. to 100°F.) before collapsing ifpossible. v 

### ·f l. .Place three web straps under cell. l3 • -2. Press one knee to the side and end of the cell FUEL SYSTEM

..:-· FIGURE 106-COLLAPSING OUTER WING CElLS i Iand push down on the top wHlJ the left hand, and at the same time fold the aft end of the cell in toward the center. 3. Fold foiWard end. 4. The cell should thEn be strapped down in the collapsedposition. NOTE-Cell must not mmain collapsed for more than 30 minutes. Cells must not be piled on top ofone another without support. INSTALLING CELLS Except as follov,•s,**lh~** installc:.tion of cei!s is the reverse of their removal. I. Insert the collapsed ce:ll, aft end first, through the large lower strut triangle at an angle to conform with the triangle. Don't push the cell until you are sure !he forward end clears the strut. 2. When aft end of cell is turned into its respective bay, a man should be inside the wing to guide the cell and prevent it from binding while it is changing direction. 3. Connect the overflow and filler hat on No. cellbefore starting on No. 2.

bl ck D at the top of the 4. Remove the aft! swaky 1od lift tank into place. b b fue tan al bom ay h the sharp corners of 't let the tank louc · h Don
. Ad"ust tank position so 1 e the bomb raJJs. l · t the side of block rests agams forward sway d the tank seats against the aft cradle an so all four pads on the cradles. kl F 10 connect the straps J: 5 E gage turnbuc es . . • 11 b and before t1qhknmg

between the earns. '
. h ft sway block D at**thr~** top fully, replace t e a t ,_**-·~** ,. k d . stall sway blocks a. 0:.,c.m.,. ofthe tan . an Ill 6. Tighten and lockwire turnbuckles F. 7. Install fore and all beam assemblies G and lighten lo a snug fit. Be sure the**ro~** extends past the inspectionhole in**~ach cle~ns.**  These beams must be installed w1th the nvet manu· factured heads up. CAUTION-Too much contact pressure between the railpads and the tank will tend to make the tank hang up instead of dropping out when the emergencyrelease is operated. 8. Install sight gage, vent line, and fuel transfer line. Selector valve hose clamp must be**o~ly** finqertight. 4. Be sure cells and comp<n!me!1!s are clean when installation is complete. CAUTION-· 1. Do not use fiHings or doorsfor hand holds. Do nol allow cells to rest en fittings. 2. ifDgllts are used inside the cells be sure they <ue safety lightr;.**NOTE--Ho~e** clamps must be tight Lui not so tight a:; to injure tile rub.ber. BOMB BAY l"ANI< INSTAlLATION 1. Install tank cradles A. (They should be int<:r· changeable hut**af!e~** airplane has been in service may not alwo.ys be so.) 2. Install two pads B on each bomb rail. Apply vaseline to surface of pads. 3. Attach beam i1ssemblies to type B-7 or B-8 bomb shackles C. and install at bo1tom stations on bomb racks. (Keep !he bombrelease handle in the sc.fe position for those ahplanes so equipped.) NOTE-The bomb bay selec:to.r switch on the side in which a tank is installed must be turned off to prevent accidental release during normal bomb release, and must be turned on again when the bomb bay lank is removed.
FUEl SYStEM 

# ;-·- r·· ----G I 

### I 

### r-·--® 

## I I I

## ··v··-~;;-_··

# .**..Jn:-~** 

## -. !Jr\1**~~-~~-'='·** ;,·-·

### ~il.**~,.;;** ., ',**~==!.. ,;~/**  

# a I

,Q w ....**~** "' .... "' w 0:

FIGURE 107-BOMB BAY TANK INSTAllAliON .· -·-

# dTROUBLE A. Nopressure.
B. Erratic pressure. FUEL SYSTEM**T~OUBLE** CHART
PROBABLE CAUSE REMEDY 1. Shaft sheared on fuel pump. 2. Dil. and pres. lines crossed. 3. Fuel shut-ofl valve closed. Replace arm. Correctlines. Openvalve. 1. Fuel pump balance line Remove restriction; tighten

plugged or fittings loose. Httings. 2. Delectivefuel pump. Replace.

_______ 3:.:. Leak in fue_l_l_in_e_.
________ H
__

ep_ai:r_o_r_r:-_p_la_:_e_.--------·· 

### c. Pressure too low or ioo high. 1. Pressureadjustment 'faulty. Adjust fuel pump to .15 PSI 2. Oil dilution valve operating. Turn off oil dilution valve. 

# ·---------- D. No pressure to primer. l. Boosterpump notoperating. Replace orrepair. 2. No.3 fuel strainerplugged. Clean fuel strainer. 

# ----------------------------3.**~~rplu~g~g~e~d_l_il_l_e_.**____

## ~---R=~ep_a_ir_o_r __

## re_.p_~Ja._c_e_l_i__

## ne~.--------- E. No pressure from primer to l. Line loose orbroken. Tighten,repair, orreplace. •;· engineselected. 2. Linescrossed. Correct. 3. Distributorfitting plugged. Cleanfitting. 

# ----

11 G. Transfer pump inoperative. F. Shut-off valve inoperative. l. Damaged solenoid. Replace valve. 2. Fuse blown. Replacefuse. 1. Damaged switch or arm. Replacepump. 2. Damaged switch arm. Straighten. 

# r' 3. Motor or pump damaged. Replace. 1 4. Fuseblown.(30 amp). · }lep.lace

# fus~. 

# v-.

# -----_,__..:_:__.....___;;_~,___,__---'------

# ~ ........................................................... -. ..

# ~--~~--~---- fUEl SYSTEM

...··**~** . i



### .... -

,

### ...
,·**~**.**.~** ., . c",.t • NOTES

t**~** . 0 

## ... 

## ... v 

# "' .... "' w a:U.S. Department ofTransportation FederalAviation Administration In Reply Refer To: AGL-7J 2011-GL-03-0057 Great Lakes Region 2300 East Devon Avenue Des Plaines, Illinois 60018-4696

Telephone: 847/294-7109 CERTIFIED/FIRSTCLASS MAIL January 31,2012 Mr. Rodney Dean Schneider 150 Woods Court Ball Ground, GA 30107 WITHDRAWAL OFEMERGENCYORDEROFREVOCATION AND REPLACEMENTWITH ORDEROFSUSPENSION On August22, 2011, an Emergency OrderofRevocation was issued to you, from which you filed an appeal to the National Transportation Safety Board (NTSB). Afterfurther consideration of material and evidencepresented by your counsel, and inconsideration ofyour withdrawal ofyour appeal to theNTSB and the settlementreached, ithasbeendeterminedthatwithdrawal ofthe August 22, 2011 Emergency OrderofRevocation and replacing it with the following Orderof Suspension is appropriate. THEREFORE, the August 22, 2011 Emergency OrderofRevocation is herebywithdrawn and the following OrderofSuspension issued and served 

### in its place. ORDEROF SUSPENSION It has beendetermined bythe Administrator ofthe Federal Aviation Administration, acting by and through his Regional Counsel, that on the basis ofall available information, you violatedthe Federal Aviation Regulations in the following respects: I. You now hold and at all times relevant hereto, held Airman Mechanic Certificate number 002649010 with Airframe and Powerplantratings.



## I**~OVERNMENT** 

# I**~H\BIT** 

# jW ""'Count I 2. On or about February 24, 2011, you performed maintenance on a Boeing Model B-17G, registered as N390TH, the property ofanother, which included the removal and replacement ofall six fuel tanks (the maintenance). 3. Ratherthan replace the bladderfuel tanks that you removed with appropriate**replacem~nt** parts, you fabricated aluminum tanks withoutthe benefit ofapproved data, an appropriate field approval, or any otherengineering data acceptable to the Administrator. 4. The replacement ofthe bladderfuel tanks with the aluminum tanks that you fabricated was a major alteration ofN390TH without approved data, an appropriate field approval, and without a supplemental type certificate orany other engineering data acceptable to the Administrator. 5. Upon completing the maintenance, you made the following entry in the maintenance log ofN390TH. Removed all six fuel tanks. Removed bladder liners from the tanks and repaired the aluminum tanks by welding, Ref: AC 43-13 section 8-32. Fuel tanks are made ofaluminum sheet, 1100!1.! hard. Reinstalled the original aluminum tanks using the original mounting methods and the original fuel line, boostpump, fuel cap, vent line, and level transmittermounting locations and methods. Thetanks were leak checked and operationally checked with no discrepancies found. Ref. B-17 Maintenance and ErectionManual, pages 196-199. 6. Following the entry setforth inparagraph 5 above, youtyped your name, affixed your signature, and includedyour certificate number, AP2649010, indicating that you performed the maintenance described in the entry, that the workwas performed satisfactorily, and that you approved N390TH for return to service for the work performed. 7. Your entry, as set forth in paragraphS above, was incomplete and misleading, in that you did notrepair aluminum tanks, but instead you fabricated aluminum tanks from the aluminum shells thathadpreviously provided support and protection for the bladdertanks that youremoved from N390TH. 8. Your fabrication ofthe aluminumtanks and your installation ofthese tanks in N390TH resulted in a major alterationofN390TH asthatterm is used in 14 C.F.R. Part 43 and its appendices. 9. Your incomplete and misleading description ofthe workperformed on the fuel system concealedthe major alteration ofN390TH.

210. The alwninum fuel tanks that you fabricated and installed in N390TH did not conform to the type design ortype certificate ofN390TH and rendered N390TH unairworthy. 11. Themethods and techniques you used to fabricate the aluminum fuel tanks was so far belowthe standards acceptable in aviation that installation of these tanks would never have been approved by competent authority. Count II 12. On or aboutJune 10, 2011, you performed maintenance on N390TH, including what you described as a "D"check inspection per the FAA approved inspection program. (the inspection) 13. The approved inspectionprogram for N390TH requires the use ofthreejacksto be used when a landing gearcheck is performed onN390TH. A landing gear check is required as part ofthe "D"check inspection perthe FAA approved inspection program. 14. On or about June 10, 2011, when you performed the inspection, you did not use threejackswhen you performed the landing gear check required by the "D" check inspection per the FAA approved inspectionprogram. 15. After you completedthe inspection, you made the following entry in the maintenance log ofN390TH, "D"check inspection performed on this airframe. I certify that this airframe was inspected in accordance with a "D"check inspection per the FAA approved inspection program and was found to be in airworthy condition. Next inspection is due at 1606.7 hours. 1.6. Following the entry set forth in paragraph 15 above, youtyped your name, affixed your signature, and included your certificate number, AP2649010, indicating that youperformed the maintenance described in the entry, thatthe work was performed satisfactorily, and that you approved N390TH for return to service for the workperformed. 17. When you performed the inspection you failed to use the methods, techniques, andpracticesprescribed in the current manufacturer's maintenance manual or other methods, techniques, and practices acceptable to the Administrator, and you failed to use the tools and equipment necessary to assure completion ofthe work in accordance with accepted industry practices.

3CountIII 18. On oraboutJune 13, 2011, you performed maintenance on N390TH, specifically you addressed a fuel leak in the #I main fuel tank (the #1 tank). 19. On June 13, 2011, the #1 tank installed in N390TH was one ofthe fuel tanks that you fabricated in February of2011, as describedmore fully in Count I above. 20. Aftercompletingthe June 13, 2011 maintenance on the #1 tank you entered the following statement in maintenance log ofN390TH, Repaired a fuel leak at the bottom, inboard end of#! maintank with sealer PR2001 Class B- 1 

### h, reference 43.13-1-B, Section 2, Paragraph 8-32. Fueled tank with 250 gallons and leaked checked therepair area. No leaks noted visually or by smell. 21. Following the entry set forth in paragraph 20 above, you typed your name, affixed your signature, and included your certificatenumber, AP2649010, indicating that you performed the maintenance described in the entry, that the work was performed satisfactorily, and that you approved N390TH for returnto service for the work performed. 22. When yourepaired the # 1tank you failed to use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, orother methods, techniques, and practices acceptableto the Administrator. 23. When yourepaired the # 1tank you failed to do that work in such a manner and use materials ofsuch a quality, that the condition ofthe aircraft would be at least equal to its original orproperly altered condition (with regard to structural strength, resistance to vibration and deterioration, and otherqualities affecting airworthiness). 24. When you approved N390TH for return to service following theJune 13,2011 maintenance, you knew that the aircraft and its fuel system had been improperly altered by you and that, following yourrepair, N390TH was not in a condition equal to its original orproperly altered condition and was unairworthy. By reason ofthe foregoing facts and circumstances as described in CountI, you violated the following Federal Aviation Regulations:
a. Section 43.13(a), which states that eachpersonperforming maintenance, alteration, orpreventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued 4Airworthiness prepared by its manufacturer, orothermethods, techniques, and practices acceptable to the Administrator, except as noted in §43.16. b. Section 43.13(b), which states that each person maintaining or altering, or performingpreventive maintenance, shall do that work in such a manner and use materials ofsuch aquality, thatthe condition ofthe aircraft or airframe, worked on will be at least equal to its original orproperly altered condition (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness).
c. Section 43.9(a) and (d), which states that, (a) each person who maintains, oralters an aircraft, airframe, orcomponent part shall make an entryin the maintenance record ofthat equipment containing the following information (1) A description (or reference to data acceptable to the Administrator) ofwork performed. (2) The date ofcompletion ofthe work performed. (3) The name ofthe personperforming the work ifotherthan the person specified in paragraph (a)(4) ofthis section. (4) Ifthe work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component parthas been performed satisfactorily,the signature, certificatenumber, and kind ofcertificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed
.... (d) In addition to the entryrequired by paragraph (a) ofthis section, major repairs and major alterations shall be entered on a form, and the form disposed of, in the mannerprescribed in appendix B, by the person performing the work. By reason ofthe foregoing facts and circumstances as described in Count II, you violated the following Federal Aviation Regulations:
a. Section 43.13(a), which states that eachperson performing maintenance, alteration, orpreventive maintenance on an aircraft, shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual orInstructions for Continued Airworthiness prepared by its manufacturer, orother methods, techniques, and practices acceptable to the Administrator, except as noted in §43.16. He shall use the tools, equipment, and test apparatus necessaryto assure completion ofthe work in accordance with accepted industry practices. Ifspecial equipmentortest apparatus is recommended by the manufacturerinvolved, he must use that equipment or apparatus orits equivalent acceptable to the Administrator.

5By reason ofthe foregoing facts and circumstances as described in Count III, you violated the following Federal Aviation Regulations:
a. Section 43.13(a), which states that each personperforming maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practicesprescribed in the current manufacturer's maintenancemanual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to theAdministrator, except asnoted in §43.I6. b. Section 43.13(b), which states that each personmaintaining oraltering, or performing preventive maintenance, shall do that work in such a manner and use materials ofsuch a quality, that the condition ofthe aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition (with regard to aerodynamic function, structural strength, resistanceto vibration and deterioration, and other qualities affecting airworthiness). Byreason ofthe foregoing, the Administratorhas determined that safety in air commerce and the public interest require the suspension ofyourAirman Mechanic CertificateNumber0026490I0 certificate. NOW, THEREFORE, IT IS ORDERED, pursuant to the authority vested in the Administrator of the Federal Aviation Administration by Title49 ofthe United States Code, Section 44709 ( 49 U.S.C. §44709), that (1) All airman mechanic certificates nowheld by you, including yourAirman Mechanic Certificate number 0026490IO with Airframe and Powerplantratings are suspended; (2) Such suspension became effective on August 22, 20II, and shall continue in effect for aperiod of270 days, ending at midnight onMay 17, 2012. (3) This Order ofSuspension has been issued based on an agreement and settlement reached on January 30, 20I2 wherein you have waived notice and all rights to appeal orcontestthis OrderofSuspension. Jeffrey A. Klang Regional ounsel

6cc: Stuart A. Goldstein, P. A. 9350 South DixieHighway, lOth Floor Miarrii, Florida 33156

7

# a. 

# _r -a·t • , ."'
....



### Photograph ofBoeingModel B-17G, N390TH, Serial Number44-85734 after an in-flight fire in the left inboard wing caused an emergencyoff-airport landing.

. 

### --- ...

## ---------

---------- 

## EXHIB**~GOVERNMENT** 

## i EXHIBIT 

# j 

# X

# Advisory Circular

Subject: Instructions for Completion of FAA Form 337 Date: 1/25/07 Initiated by: AFS-350 AC No: 43.9-1 F


### 1. PURPOSE. This advisory circular (AC) provides instructions for completing Federal Aviation Administration (FAA) Form 337, Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance). 2. CANCELLATION.AC 43.9-1E, Instructions for Completion ofFAA Form 337 (OMB No. 2120-0020), MajorRepair and Alteration (Airframe, Powerplant, Propeller, orAppliance), dated 5/21187, is canceled. 3. RELATEDREGULATIONS.Title 14 oftheCode ofFederaiRegulations (14 CFR) part 43, §§ 43.5, 43.7, 43.9, and appendix B. 4. INFORMATION. FAA Form 337 is free and available at all FAA Manufacturing Inspection District Offices, Flight Standards District Offices (FSDO), International Field Offices, Certificate Management Offices, and online at http://forms.faa.gov/forms/faa337.pdf.
a. The form servestwo main purposes: (1) Toprovide aircraft owners and operators with a record ofmajor repairs and major alterations indicating the details and approvals. (2) To provide the FAA with a copy ofthe form for inclusion in the aircraft records at the FAA Aircraft Registration Branch, AFS-750. b. This form can be completed on paperor by using the electronic FAA Form 337. Information can be found online at http://eformservice.faa.gov/eForm337.aspx orby contacting your local FSDO.**~-** 5. ELECTRONIC FORMAT.
a. ElectronicTrackingNumber. In the upper right corner ofthe form's header, there is a block titled "ElectronicTrackingNumber."This block is used only in the electronic version to automatically apply a numberthat identifies and retrieves forms electronically. Further information on the use ofthis number is supplied in training material atthe Web site provided in paragraph 4b ofthis document.

--------------------------..

### ~'GOVERNMENT. i EXHIBIT 

# i 

# J·.AC 43.9-1F 1/25/07 b. Watermark. Under current policy, the header block titled "ForFAA Use Only" has no official use except as a watermark applied automatically to indicate submittal when using electronic media. 6. FORMINSTRUCTIONS. The person who performs orsupervises a majorrepair ormajor alteration must prepare Form 337. The form is executed at least in duplicate and is used to record major repairs and major alterations made to an aircraft, airframe, powerplant, propeller, appliance, or a component part thereof: The following instructions apply to items 1through 8 of the form as illustrated in Appendix 1. Theterms "Item" and "Block" are used synonymously in FAA documents relating to datacollection on Form 337.
a. Item 1-Aircraft.The "Nationality and Registration Mark" is the same as shown on Aircraft Certification (AC) Form 8050-3, Certificate ofAircraft Registration. An "N"prefix denotes the nationality for U.S. registered aircraft. Information to complete the "Make," "Model," and "Serial Number" blocks is found on the aircraft manufacturer's identification plate. A "Series" block has been provided to further identifY the series ofa specific model. Proper segregation ofthe model and series will be useful in collecting data for safety related issues. NOTE;..;When the aircraft registry receives a completed Form 337 for the official aircraft file, itis validated by matching the registration "N" number with the serial number. Ifan application for a changeto the "N" numberhas been made,itis importantfor the submitterto receive verification ofthe change from theFAA registrywith a new AC Form 8050-3. IftheForm 337 must be submitted before receipt ofthe new registration then the old "N" number must be used. b. Item 2- Owner.Enterthe aircraft owner's complete name and address as shown on AC Form 8050-3. When work is performed during a change in ownership, it is permissible to use the name and address shown on AC Form 8050-1, Aircraft Registration Application. NOTE: When a majorrepairormajoralteration is madeto a component part,items 1, 2, and in some cases 5 will be left blankand the original and duplicatecopies ofthe form will remain with the partuntil itis installed on an aircraft. Afterenteringthe required information in items 1, 2, and if appropriate, 5, the person who installed the partwill give one form tothe owner/operatorand forward theduplicatecopy to theFAAregistrywithin 48 hours afterthe aircraftis approved for return to service. Ifa component partofan airframe, powerplant,propeller,orapplianceis repaired or altered and the unitidentification information is notknown, it is appropriate to applythe precedingprocedure and leave item 5 blankuntil the airframe, powerplant, propellerorapplianceis installed on the aircraft.
c. Item 

### 3- ForFAA Use Only. Indicate approval in item 3 when the FAA determines that data used to perform a majorrepair or major alteration conforms to accepted industry practices and is in compliancewith currentguidance and regulatory requirements. Approval is indicated by one ofthe following methods. (See paragraph 7, Administrative Processing, for further details.)
Page 2 Par51/25/07 AC 43.9-lF (1) Approval ofData by Examination Only. Enterthe following statement on Form 337 when the datapackage is reviewed and a data approval is completed: "Thedata identified herein complies with the applicable airworthiness requirements and is approved for the above described aircraft, subjectto conformity inspection by a person authorized in section 43.7." (2) Approval ofData by Physical Inspection. Enterthe following statementon Form 337 when a physical inspection, demonstration, orothertype oftest ofan aircraft is satisfactorily performed and an installation approval is completed: "Approval by Physical Inspection, Demonstration, Testing, etc.-OneAircraft: The alteration orrepair identified herein complieswith the applicable airworthiness requirements and is approved for the above described aircraft, subjectto conformity inspection by a person authorized in section 43.7." (Order 8300.10, vol. 2, ch. 1, section 2, paragraph 5d(3).) (3) Designated Airworthiness Representative Statement ofCompleteness. Authorized designee certification ofdata indicates thatthe data in item 8, Description ofWork Accomplished, comes from FAA-approved sources and addresses all the original certification requirements for the aircraft described in item I. Itdoes not constitute a field approval or approval ofthe data. Enterthe following statement when an authorized designee has reviewed and certified the alteration datapackage by signing, dating, and entering its designee authorization number in item 3: "The alteration identified herein has been reviewed and found to be complete with appropriate Designated Engineering Representative approvals. All aspects ofthe alteration(s) are compatible and eligible for use on the above described aircraft, subjectto conformity inspection by a person authorized in §43.7." (Order 8300.10, vol. 2, ch. I, section I, paragraph I5c.) (4) Overweight Aircraft OperatingUnder a Special Flight Permit. Enterthe following statement as part ofthe recordkeeping requirements for overweight flight permits contained in the current edition ofF AA Order 8130.2, Airworthiness Certification ofAircraft and Related Products: "No person may operate this aircraft, as altered herein, unless it haswithin it an appropriate and current special flight permit issued underpart 2I." (Order 8130.2F, paragraph 196b.) d. Item 4- Type. Entera checkmark in the appropriate column to indicate whetherthe unit was repaired or altered. Use only one "Type" line perform.
e. Item 5- Unit Identification. Usethe information blocks under item 5 to identify the airframe, powerplant, propeller, or appliancethat has been repaired oraltered. It is only necessary to complete the blocks for the unit repaired oraltered. The procedure for repair or

Par 6 Page 3AC 43.9-1F
alteration ofa componentpart when the unit identification is unknown is detailed in paragraph 6b above. Use only one "Unit Identification" line per form. NOTE: A component ofan airframe, powerplant, propeller, orappliance repaired oraltered must be clearly identified in item 8 listing the part number, serial number, and any otherdescriptive information as applicable. f. Item 6- Conformity Statement. 1/25/07

(1) "A"- Agency's Name and Address. Enterthe name ofthe certificated person or entity accomplishing the repair or alteration. Mechanics should entertheirname and permanent mailing address. Manufacturers, repair stations, and certificated maintenance organizations should enterthe name and address underwhich they are certificated. (2) "B"- Kind ofAgency. Check the appropriate box to indicate the type ofperson or organization that performed the work. NOTE: Forthe purposes ofthis form, a Canadian Approved Maintenance Organization is considered a foreign mechanic. (3) "C"- CertificateNumber. Enterthe appropriate certificate number for the "Kind ofAgency" entered in item 6b ofthe form. Mechanics should.entertheirmechanic's certificate number. Certificated maintenance organizations and repair stations should enterthe number referenced on the air carrier, air operator, or air agency certificate issued by the FAA as appropriate. Manufacturers should entertheir Production Certificate or Supplemental Type Certificate number as appropriate. When repairing oraltering articles, manufacturers holding Technical Standard Orders (TSO) approvals should enterthe TSO number ofthe affected article. (4) "D"- Conformity Statement. Use this space to certify thatthe repair or alteration complies with 14 CFRpart 43. When work was performed or supervised by certificated mechanics, they should enterthe completion date ofthe repair or alteration and sign their full name. Repair stations and maintenance organizations are permitted to authorizetheir employees to date and sign this conformity statement to comply with theirFAA-approved program. (5) FuelTankModification. For modifications involving installation ofextended range fuel tanks in the passengerorbaggage compartment as described in part43, appendix B, check the boxprovided to indicatethe modification. NOTE: In this instance, one copy ofForm 337 must be placed onboard the aircraft as specified in 14 CFR part91, 

### § 91.417 when the aircraft is returned to service. g. Item 7- Approval for Return to Service. Part 43 establishes the conditions under which major repairs ormajor alterationsto airframes, powerplants, propellers, and appliances may be approved for return to service. This portion ofthe form is used to indicate approval or rejection ofthe repairoralteration and to identify the person or agency making the airworthiness determination.
Page 4 Par 61/25/07 AC 43.9-IF (1) Checkthe "approved"or "rejected"boxto indicate the finding. Rejected forms will be returned to the person who madethe modification, as identified in item 6, for correction. Approved forms will be completed, signed, and submitted to the aircraft registry. (2) Check the appropriateboxto indicate who made the finding. Usethe box labeled "other" to indicate a finding by a person otherthan those listed. Thisbox is reserved for any entity, not otherwise identified, that the FAA may authorize to perform that function. The person who made the finding should sign and date the form. The person'sname should also be typed or printed belowtheir signature and the appropriate certificate or designation number should be entered. Ifan aviation safety inspector (ASI) signs item 7, the ASI's office identifier is placed in the certificate ordesignation number block. (3) Before approving Form 337, it is the responsibility ofthe person returning the productto service to ensure that all the work described in item 8 matches approved data and that the information presented on the form is complete. (4) Ifthe form is not accepted by the aircraft registry for any reason, it will be routed through the FAA regional office back to the return to service agent identified in item 7. 

### h. Item 8- Description ofWorkAccomplished. (1) Enter a clear, concise, and legible statement describing the work accomplished in item 8 on the reverse side ofForm 337. It is importantto describe the location ofthe repair or alteration relative to the aircraft or component. Ifmaking a repair to a buckled spar, the description entered in item 8 might begin by stating, "Removed wing from aircraft and removed skin from outer 6 feet. Repaired buckled spar49 inches from the tip in accordance with
..." and continue with a description ofthe repair. Ifthe repair or alteration can be concealed by skin or another structure then an authorized individual should make a pre-closure certification statement. This statement includes a signature and certificatenumber and says that a pre-closure inspection was made and that covered areas were found satisfactory. (2) The description should refer to all applicable 14 CFR sections and to the FAA-approved data used to substantiate the airworthiness ofthe repair oralteration. Forms of FAA-approved data are contained in Order 8300.10 and AC 43-210, Standardized Procedures for Requesting Field Approval ofData, MajorAlterations, and Repairs. 

### NOTE: Supplementaldata such as stress analyses, test reports, sketches, or photographs areoften proprietary and not intended as partofthe item 8 description. Supplementaldata submitted as part ofthe item 8 description should beidentified as an attachmentto the form using thefollowing procedure. (3) Ifadditional space is needed to describe the repair oralteration for item 8, checkthe "Additional Sheets Are Attached"box at the bottom ofthe page. Attach sheets showing the aircraft nationality, registration mark, and the date the work was completed. All attachmentsto item 8 must be submitted on 8 

### 'li- by Il-inchpaperto allow for proper processing into the aircraft historical record at the aircraft registry. Ifattachments to Form 337 are received bythe

Par 6 Page 5AC 43.9-IF 1/25/07
FAA in a format largerthan an 8 !h- by 11-inch page then the submission will be returned tothe person identified in item 7 for correction and resubmission. (4) Showing weightand balance computations under item 8 is not required but it may be done. Ifweight and balance ofthe aircraft are affected by the work described onForm 337, the changes should be entered in the aircraft weight and balance records with the date, signature, and reference to the form. 7. ADMINISTRATIVE PROCESSING. Form 337will be executed in duplicate with one signed copy given to the aircraft ownerand one copy forwarded to the FAA within 48 hours after the airframe, aircraft engine, propeller, orappliance is installed on an aircraft and approved for return to service. FAAprocessing ofthe forms and their supporting data will depend on whether approved orunapproved data is used.
a. Approved Data. Completethe form as instructed in this AC, excluding item 3, and ensure that items 6 and 7 have been properly executed. Give a copy ofthe form tothe aircraft owner/operatorand send a duplicate copy to the FAA Aircraft Registration Branch within 48 hours after the airframe, aircraft engine, propeller, or appliance is installed on an aircraft and approved for return to service. b. Unapproved Data. Completethe form as instructed in this AC, leaving items 6 and 7 blank. Both copies ofthe form and any supplemental data will be sentto the local FAA district office. When the FAA determinesthatthe major repair or major alteration data complies with regulations and conforms to accepted industry practices, data approval will be recorded by entering an appropriate statement in item 3. Both forms and any supplemental data will be returned to the applicant who will then complete items 6 and 7. The applicantwill give one of the completed forms to the aircraft owner/operator and submitthe other completed form tothe FAA Aircraft Registration Branch for inclusion in the aircraft records. NOTE: The electronic FAAForm 337 allows for electronic approvals and processing ofForm 337 from the time itis used to describe the alteration or repair until it is forwarded to the FAA Aircraft Registration Branch. At this time the FAA does not allow for the mixing·orthe two processes. IfForm 337 is started in the electronic format, it must be completed thatway and cannot be completed using the paper process. Furtherinformation is supplied at the Web site shown in paragraph 4(b).
c. Signatures ofForm 337. (1) An FAA inspector's signature in item 3 indicates approval ofthe datadescribed in that section for use in accomplishing the work described in item 8 ofthe form. The statement of completeness in item 3by an appropriately rated designee is a "certification ofcompleteness" of required data. It is not a field approval or approval ofdata.

Page 

### 6 NOTE: Signatures in item 

### 3 count as data approval orcompleteness of approved data only and do not indicatethe approval for return to service for thework in item 

### 8.

Par 61/25/07 AC 43.9-1F

· (2) A signature in item 6 is a certification by the person performing the work that the work complies with all applicable airworthiness requirements and FAA-approved data. The certification is only applicable to the work described in item 8 or attached sheets. (3) A signature in item 7 by an FAA Flight Standards Inspector orDesignee constitutes an authorized return to service. A signature is not an approval ofdata. Data approval procedures are performed in item 3 by an authorized individual and further defined in Order 8300.10 and AC 43-210. Other persons listed in item 7 are authorized to "approve for return to service" ifthe major repair or major alteration uses and conformsto FAA-approved data and is performed in compliance with part 43. (4) Ifengineering assistance was requested, written Aircraft Certification Office concurrence (e.g., memo or e-mail) becomes an attachmentto Form 337. d. U.S. Military and Foreign Use. Form 337 is not authorized for use with aircraft not registered in the United States. The form may be provided to the U.S. Military ora foreign civil air authority ifit is requested as a record ofwork performed and should be completed following part 43 and this AC. A note on the fol11'i should inform the U.S. Military orforeign authority that the form is not an official record and that the FAA aircraft registry will not record it.
e. Completed Forms. Completed forms should be submitted to the Aircraft Registration Branch, AFS-750, POBox 25504, OklahomaCity, Oklahoma 73125. Electronic forms are submitted automatically through the website at: http://eformservice.faa.gov/eForm337.aspx.
ORIGINAL SIGNED by Roger Forshee James 

### J. Ballough Director, Flight Standards Service

Par 7 Page 7

### 1125/07 APPENDIX 1. FAA FORM 337 AC 43.9-lF 

### Appendix 1 

# 0 MAJOR REPAIRANDALTERAnoN**-~** 

# I"'T.....,_ ic-Ho.21:NGZO**ua~** 

# ................, ol1-- !Airframe, Powerplant, Propeller, orAppliance) 

## _...._**~-** INSTRUCTIONS: Pmt ct**~** 81 entrlat. See Tile 14 CFR §43.0, Pall 43 ApplndiJC 8, and N; 43.9-1 (ct IUbeequent IWIIIIion lhwed} lot hltudlona and dllpodlon**Ill~** fonn. lhll rwpoot II reqUMcl**~law** (49 U.S.C. f«701). Fabeto rwportcan ,_.n • clvl pena1y lotIN!oCh IIIChvlllllltlon (40U.S.C. §-4Q01(8))**~--** • Mllrll !&NISINO• 1. Alrc:taft**~ ~**  

### ,s.1
..**~-(As**a/laM'!on**~onl»>lllDUUJ ~t(Aa-011**  crtllatl.e) 

# ...,_ 2.0wn
... ca, 

# ..... z., a-.,. 3. ForFAAUNOnlv

4.Type !.Unllldltnllflca1lon R..,.r Alanlllon 

### u ... Malia Model SerialNo. 

### 0 0 AIRFRAME (As dNctb«<lnH8111 1•bow) 

### 0 

### D POWERPI..AHT 

### 0 

### D PROPEllER p

-..... 

### 0 

### D APPLIN«:E**~-** &Conronn_llte...,.,. 14.. A(Jroc(l NameandAddNas 8. Knd IllAoetq 

# -**us.~--** 

# ,_ 

# -**Faoigol~-nic** c. CwtlicaleNo. a. 

# -**c..-~rS1olicn** 

# "' 0....0, Oo-.,M8nton_O
__ D. IWilily 11\atthe lwpK8nd'ao"**~~~~.ration**mat.to theunt(t)ldlndied n l*t S llllOIM and dela'l>edonthe

# _.,..or alllachmtntl hemo havebNnmadeWI acoDidllncewththerecpnw!W1b ol**~**43111the U.S.**Feder'~~** Aviation Rllgulllllonsandthaithe lttonnation bnii'*IJwMIIINelnlCllmldto**the~** Ill**my~·** e..nded-vefuel 'olAulfla'1fed lhdi'IIIIUII pw 14CFRPa1t43 

### 0 App.B 7.••rovallllrltelum10a..w.**P~ru~nt** tB 111e euhtl)' g1wn**~** ..-&d below, the una idenlfild 1n t.m s- npectect 1n the mamer**P~WCtlbld ~** **~~e**

Admlnlltr8torotthe Fedwll Aviation**.t.drrntra~~on** and• 

### D**~** 

### D**~** FMAt Stardanta Manuradlnt MainlolnanceO'llllf'IZallln 

# 1 Pot..,..sApp-byc.-n ln8pec:tlr**~ofTr.-..port** BY**OCMI'~** FMO.IgNe Repar&Mion InspectionAulhoftzation**~tlaDot ~**  olAulhaized lnci'IIIIUII DesliJ'III!OnNo.

FAAForm S3711CHIII 

### Page 1AC 43.9-lf 

### Appendix 1

Page 2 1125/07


### APPEND\X '\.FAA FORM 337 (Continued)I
9/8/98 AC 43.13-18 

### SECTION 2. FUEL SYSTEMS 

### 8-30. GENERAL. Maintain, service, and adjust aircraft fuel systems and fuel system components in accordance with the applicable manufacturer's maintenance instructions. Certain general fuel system maintenance principles are outlined in the following paragraphs
.. 

### 8-31. FUEL LINES AND FITTINGS. When fuel system lines are to be replaced or repaired, consider the following fundamentals in addition to the applicable airworthiness requirements. Additional inspection and repair practices for aircraft tubing systems may be found in the Chapter 9, Aircraft Systems and Components.


### a. Compatibility ofFittings. All fittings are to be compatible with their mating parts. Although various types offittings appear to be interchangeable in many cases they have different thread pitch or minor design differences which prevent proper mating and may cause thejointto leak or fail. 

### b. Routing. Make sure that the line does not chafe against control cables, airframe
· structure, etc., or come in contact with electrical wiring or conduit. Where physical separation ofthe fuel lines from electrical wiring or conduit is impracticable, locate the fuel line below the wiring and clamp it securely to the airframe structure. In no case should wiring be supportedby the fuel line.


### c. Alignment. Locate bends accurately so that the tubing is aligned with all support clamps and end fittings and is not drawn, pulled, or otherwise forced into place by them. Never install a straight length of tubing between two rigidly-mounted fittings. Always incorporate at least one bend between such fittings to absorb strain caused by vibration and temperature changes.

Par 8-30 

# IGOVERNMENT 

### I EXHIBIT


# . -z_ j.-....·

-- d. Bonding. Bond metallic fuel lines at each point where they are clamped to the structure. Integrally bonded and cushioned line support clamps are preferred to other clamping and bonding methods.


### e. Support of Line Units. To prevert possible failure, all fittings heavy enough to cause the line to sag should be supported by means other thanthe tubing. 

### f. Support clamps. (1) 

### Place support clamps or brackets for metallic lines as follows. Approximate Tube O.D. distance between supports 1/8"-3/16"--------------------------------- 9" 1/4"-5/16"
--------------------------------- 12" 3/8"-1/2"
----------------------------------- 16" 5/8"-3/4"
----------------------------------- 22" 1

"-1 1/4"----------------------------------- 30" 1 1/2"-2"----------------------------------- 40" 

### (2) 

### Locate clamps or brackets as close to bends as possible to reduce overhang. (See figure 8-12.) 

### 8-32. FUEL TANKS AND CELLS. Welded or riveted fuel tanks that are made of commercially pure aluminum, 3003, 5052, or similar alloys, may be repaired by welding. Tanks made from heat-treatable aluminum alloys are generally assembled by riveting. In case·it is necessary to rivet a new piece in a tank, use the same material as used in the tank undergoing repair, and seal the seams with a compound that is insoluble in gasoline. Special sealing compounds are available and should be used in the repair oftanks. Inspect fuel tanks and cells for general condition, security of attachment, and evidence of leakage. Examine fuel tank or cell vent line, fuel line, and sump drain attachment fittings closely. Page 8-19

### AC 43.13-18

OVERHANG

FIGURE 8-12. Location ofclamps at tube bends. 

### CAUTION: Purge de-fueled tanks of explosive fuel/air mixtures in accordance with the manufacturer's service instructions. In the absence of such instructions, utilize an inert gas such as C02 as a purgative to assure the total deletion offuel/air mixtures.
a. Integral Tanks. Examine the interior surfaces and seams for sealant deterioration and corrosion (especially in the sump area). Follow the manufacturer's instructions for repair and cleaningprocedures. b. Internal Metal Tanks. Check the exterior for corrosion and chafing. Dents or other distortion, such as a partially-collapsed tank caused by an obstructed fuel tank vent, can adversely affect fuel quantity gauge accuracy and tank capacity. Check the interior surfaces for corrosion. Pay particular attention to the sump area, especially for those of which sumps are made of cast material. Repairs to the tank may be accomplished in accordance with the practices outlined in the chapter4, Metal Structure, Welding and Brazing of this AC
. 

### 9/8/98
c. Removal ofFlux After Welding. It 

### is especially important, after repair by welding, to completely remove all flux in orderto avoid possible corrosion. Promptly upon completion ofwelding, wash the inside and outside ofthe tank with liberal quantities of hot water and then drain. Next, immerse the tank in either a 5 percent nitric or 5 percent sulfuric acid solution. Ifthe tank cannot be immersed, fill the tank with either solution, and wash the outside with the same solution. Permit the acid to remain in contact with the weld about one hour and then rinse thoroughly with clean water. Test the efficiency ofthe cleaning operationby applying some acidified 

### 5percent silver nitrate solution to small quantity of the rinse water used last to wash the tank. If a heavy white precipitate is formed, the cleaning is insufficient and the washing should be repeated. d. Flexible Fuel Cells. Inspect the interior for checking, cracking, porosity, or other signs ofdeterioration. Make sure the cell retaining fasteners are properly positioned. If repair or further inspection is required, follow the manufacturer's instructions for cell removal, repair, and installation. Do not allow flexible fuel cells to dry out. Preserve them in accordance with the manufacturer's instructions. 8-33. FUEL TANK CAPS, VENTS, AND OVERFLOW LINES. Inspect the fuel tank caps to determine they are the correct type and size for the installation, and that "0" 

### rings are in good condition.
a. Unvented caps, substituted for vented caps, will cause fuel starvation and possible collapse ofthe fuel tank or cell. Malfunctioning of this type occurs when the pressure within the tank decreases as the fuel is withdrawn. Eventually, a point is reached where the fuel will no longer flow, and/or the outside atmospheric pressure collapses the tank. Thus,



### ......... P•a•g•e•8-•2•0
..............................

# ------------------------------P~ar8-32

### ...**~Op!tS:** Boeinq (Army) B-17P, B-17G (ApproYed 12/2/Q6) SP!CIPICATIOI "U!B!R: L-1-J (Bolder of**L~ted** Type**Cer~1f1cate:** Tranacontinental and leatern Air, Inc., laabinqton, D.C.) lnqinea ruel lnqine limita
Propellers

Airspeed lilllita

11aaimu11 weiqht e.G. range**Da~um** !lAC Other operatinq

limitationa: Certification basis Production basi• Eaport eliqibility ' lrigbt cyclone• 11820-97 100**~ini~~~** octane (CPI) aYiation grade qaaoline !aaimua, eacept tate-off (lov blower plua turbo),

39.5 in. Bg., 2300**rp~a** (1000 bp) (aea lenl to 25,000 ft.) Take-off (fiYe ainutea),**~5** in. Rq.,**2~00 rp~**  (1200 bp) 1. Hamilton Standard 23!50 bub, 6153A-18 bladea

(for interchanqeable bladea see Aircraft Propeller**Specifica~ion** lo. 603, lOTI 6). and GoYernor -111, or 2. Hamilton Standard 23150 bub, 6477A-O bladea

(for interchangeable blad
.. see Aircraft Propeller Specification Mo. 603, MOT! 6), and GoYernor 4G8. LeYel fliqht or climb

- 225 mph True Ind. Glide or diYe

- 27'**~aph** true Ind. !aziaum flap speed:

with power off

- 1•4 mph True Ind. with power on - 106 Mph Trae Ind. 59,000 lba. (See JOT! 6) 20 percent !AC to 32 percent "AC Leading edqe wing at root chord (196.16 in. from

nose section) 117.5 in. L.!. "AC (+JO.l) Army T.O. Mo. AI01-20!P-1 ("odel B-17P); A101-201G-1 f"odal B-17G) (S.e lOTI 2) Limited Type**Cer~ificate** lo. 1 (CAR 9 effectiYe

11/21/46) Bone may be produced under this approYal lot eliqible for a certificate of Airworthiness

for**!zpor~.** EQOIP"!I!: lo equipment other than engines and propellers are specified. HoweYer, the equipment required by CiYil Air Requlations Part 43.30 for lc aircraft for the proper operation of the aircraft must be installed. In addition, the aircraft may incorporate such military equipment**(6acep~ armamen~)**  as vas oriqinally incorporated in the**typ~** for military or naval serYice. Additional equipment may be installed when it is substantiate4 that it presents no hazard to safetr. HOT! 1. Weiqht and Balance Report including list of equipment included in the certificated empt7 weight must be obtained for each aircraft. Army or JaYJ weight records, vhen aYailable and in reasonably current condition, mar be submitte4 in lieu of an actual weiqbt. The equipment list need include no more than the following: (a) Required eqaip1118nt as defined under "IQOIP5!NT" aboYe. (b) Additional items as may be reasonably considered remoYable and arc so located or of such veigbt that their remoYal or addition could noticeably**affec~** the weight and balance of the aircraft. Items built into tbe aircraft structure need not be listed. The equipment list must be prepare4 by the applicant for tbe approYal of the certificating c.A.A. representatiYe and in such form that it can be attached to tbe c.A.A. Operation Limitations. HOTE 2. the following statement must appear on the Operation Limitations: "This airplane**mus~** be operated**a~** all times vithin tbe limitations set forth in T.O. AN01-EP-1 (for**~odel** B-17n or r.o. AMOI-!G-1 (for Kodel B-17G) eacept in cases of mazimum loadinqa and airspeed lilllita in which cases tbe Yalues giYen in Aircraft Specification No. AL-1 must be obserYed. A copy of the T.O. and**th~** aircr1ft specification must be carried in the aircraft during flight.• In all cases it vill be the responsibility of the applicant to secure a copy of the correct T.O. The C.A.A.**does~** haYe these documents aYailable for distribution. liOTB 3. •U.l structural repairs should be made in accordance vitb l'.rmy T.o. Mo. 01-20!-l. If any repairs or modifications (other than those covered in the pertinent ArNf or laYy repair manual) are made prior to or subsequent to ML certification, it is tbe responsibility of the owner to furnish sufficient eiYdence to a CiYil Aeronautics**A~ministration** representatiYe to show that the modified airplane ;naintains the same degree of airworthiness as the original. The C.A.A. can qiYe no technical assistance on such matters since complete structural data for liL aircraft are not required by Part 9 and therefore are not aYailable in the C.A.A. NOT!**~.** The following placard should be prominently displayed in the



### I GOVERNMENT 

### i!

.

## E>CH'(!t'r-· 

# •**\~!tit\** 

# i

.**~** 

# '"'passenger compartment: "This is a military type aircraft and onder the C1Y11 Air Regulations shall not be used for ths carriage of passengers or cargo for compensation or hire." NOT! 5. Deleted. HOT! 6. !ligible !or 59,000 poonds with outer wing tanks filled (Tokyo tanks). lith outer wing tanks empt1 maximum weight limited to 54,000 pounds. lith ooter wing tanks partially filled use a straight line variation of weight between sq,ooo and 59,000 pounds. NOT! 7. For certification for night flying tbe following must be accomplished: (a) Replace the ving position lights vith certificated units or satisfactorily modify the lights if pertinent. {Type A-9 ving position lights (A!-3033-5 through -8) may be satisfactorily modified by painting the inside of the frosted coYer black. Type A-9 (AS-3033-1 through -ql are satisfactory withoot modification. (b) Replace the tail light with a certificated unit. (c) If "Bright and Dim" conditions are proYided for tbe position lights, either the resistors should be disconnected from the circuits and a single-pole-single-throw switch should be used to replace the two single-pole-doable-throw switches presently installed for wing-tip and tail lights, or the switches should be placarded to indicate that only the "bright condition" should be used. In either case the tail light and wing-tip lights should operate on one switch. Mo original NL airworthiness certificates mar be issued after 6/31/qS. The list of mandatorr changes required prior to original certification may be obtained from CAA Aircraft Service, Washington, D.c. Attn: A-298.

### 7/28/09 8900.1 CHG 71 

### Figure 4-68, MajorAlterationsJob Aid NOTE: Aviation Safety Inspectors (ASI) should see guidance in Figure 4-68 to determine when additional coordination with a DesignatedEngineering Representative (DER) orthe Aircraft Certification Office (ACO) may be necessary. 1. The following lists indicate which method(s) may be used for approvingmajor .xlt"P·r<>t"t 

### TC'd and STC'dproducts. These lists are not all-inclusive, and each alter£!-tion
....v ......... 

### evaluated on a case-by-case basis. Consult each sectionthat concerns yourpnoduct. ASis should review current bulletins, ACs, etc., for specific types ofinstallati identified as candidates for field approval. The legend is as follows: 2. Items with the letters STC require an STC.

19 UNCONTROLLED COPY WHEN DOWNLOADED Check with FSIMS to verifY currentversion before using an STC, automatically determine ifthe

### 7/28/09 8900.1 CHG 71 

### Figure4-68, MajorAlterations JobAid (Continued) Flight data recorders (FDR). Ground proximity warning systems (GPWS). 

# I Electronic flight instrument systems (EFIS) (see InFO 08047). Terrain Awareness and Warning Systems (TAWS-A) (see InFO 08047). Terrain Awareness and Warning Systems (TAWS-B) (see InFO 08047). Emergency Vision Assurance Systems (EVAS). Global positioning system (GPS) orGlobal Navigation Satellite System I (see InFO 08047). NOTE: ASis should also review current guidance for been identified as candidates for field approval. Changes that increase the differential pressure limits ofan atmo control system ofaircraft interior compartments. Changes in engine and propellercombination Any alteration that requires flight testing to applicable to operational flights conducted Anti-terrorism countermeasures, 

### Airworthiness. the regulations (not 91' §

### 91.407(b)). 

### STC STC STC

ENG ENG ENG 

### STC Changesto landing gear and length, geometry of
.............,....**~** 

### such as internal parts ofshock struts, EVL systems, or additions. drains, orbattery vents. (Applicable to EVL engine.) (LOX) oronboard generating systems. ENG

, auxiliary powerunit (APU) ram air, nacelle 

### blowout ENG 

### raulic, Pneumatic,andFuelLines, orSystems ThatAffect Their Installation and FlammabilityRequirements, such as: ofhoses and/orhose fittings that may not meet installation requirements, ENG flow rate and flammability requirements. Changesto fuel dump valves. EVL New oil/fuel/hydraulic 

### line materials beyond the scope ofAC 43.13-1,Acceptable EVL Methods, Techniques, and Practices- Aircraft Inspection and Repair (current edition). Change to, or addition of, permanent fuel tanks orfuel system components, including EVL 22 UNCONTROLLED COPYWHEN DOWNLOADED Check withFSIMS to verify current version before using

### 7/28/09 8900.1 CHG 71 

### Figure4-68, MajorAlterationsJobAid (Continued) sealants. 

### Changes in Fixed Fire ExtinguisherorDetectorSystemsThatAffectthe System's Effectiveness orReliability, such as: Relocating discharge nozzles, detectorunits, or fixed fire extinguisherbottles. Using new or different detector components. Decreasingthe amount or changing the type ofextinguishing agents. Changes that include substituting airframe materials that affect structural lightning protection, orflight characteristics. 

### Alterations orRepairsThatInclude: Use ofsynthetic covering materials. Newtitanium applications. Ceramic coatings. Use ofsynthetic coatings. Use ofnewplated coatings. 

### Crashworthiness. Changes to the aircraft structure, relocation. Changesthat affect emergency jumping). 

### ROTORCRAFT. 

### EVL ENG ENG ENG ENG 

### EVL ENG

The following section earlierequivalents. with a certificationbasis of 14 CFRparts 27, 29, orthe 

### W&B. maximum weight limits affecting structural, 

### STC and so forth (for example, increases in the maximum takeoffweight, or landing weight). ated center ofgravity range limits (for example, decreasing the 

### STC increasing the aft limit). increasethe operational limits (maximum speed limits such as 

### VA, VFE, 

### STC

speed limitations such as stall speed, increases in service ceiling, and so forth). 

### StructuralStrength. Changing primary structures (structures thatcarry flight, ground, orpressure loads as defined in AC 25.571-1 DamageTolerance and Fatigue Evaluation ofStructure) as well as the following additional modifications or structural members: 23 

### UNCONTROLLED COPY WHEN DOWNLOADED CheckwithFSIMS to verify current versionbefore using

### 7/28/09 8900.1 CHG 71 

### Figure 4-68, MajorAlterationsJobAid (Continued) Anti-terrorism countermeasures, including flares. 

### Airworthiness. Changes to Systems, such as: Relocation ofexteriorfuel vents orbattery vents. Crew orpassengerLOX oronboard generating systems. External critical access doors, APU ram air, nacelle blowoutdoors, and fuel 

### Changes to Oil, Hydraulic, Pneumatic, and Fuel Lines, orSystems or ThatAffect TheirOperation orInstallation and Flammability Newtypes ofhoses and/orhose fittings thatmay not meet such as those offlow rate and flammability. Changes to fuel dump valves. New oil/fuel/hydraulic line materials. 

### Changes in Fixed FireExtinguisheror Effectiveness orReliability, such as:

Changes that include su integrity, lightning**..,.,.,..,,,.~,** 

### atAffect the System's STC

ENG EVL EVL EVL

ENG ENG ENG ENG Changes that alter damage •vH.JiaJ.J'-''-'· 

### ofrotorcraft, such as loads, vibration, fatigue, 

### STC characteristics ofmain ortail rotor system, veshafts, driveshaft supportbearings, and main and



### STC aircraftto an all-cargo orcombination configuration. 

### STC
that may require a human factors compliance finding (forexample, in flight 

### STC deck instrumentation and controls). Flight deck lighting changes to supportnightvision goggle use, orany approvals 

### STC related to night vision goggles. Changing or substituting engine/aircraft instrumentation required by a unique 

### STC 

### 26 UNCONTROLLED COPYWHEN DOWNLOADED Checkwith

### FSIMS to verify currentversionbefore using

### I 

# '
I 7/28/09 8900.1 CHG 71 

### Figure4-68, MajorAlterationsJobAid (Continued) TCAS I orTASs (see InFO 08047). 

### EVL TCAS II. 

### STC APs. 

### STC FDRs. GPWSs. EFISs (see InFO 08047). TAWS-A (see InFO 08047). TAWS-B (see InFO 08047). EVAS. 

### STC GPS or GNSS (see InFO 08047). 

### EVL NOTE: ASis should also review current guidance for specific types been identified as candidates for field approval. Any alteration that requires flight testing to applicable to operational flights conducted the regulations (not ENG Anti-terrorism countermeasures, 

### STC Airworthiness. Changes to landing gear and length, geometry ofmembers, such as internal parts ofshock struts, ENG systems, oradditions. 

### EVL generating systems. ENG APU ram air, nacelle blowout doors, and fuel drain. ENG 

### lie, Pneumatic, and FuelLines, orSystems orTheirComponents orInstallation and FlammabilityRequirements, such as: and/orhose fittings that may not meetthe installationrequirements, ENG and flammability requirements. ENG

· line materials. ENG Newflammable fluid tanks or system components. 

### STC Change to, or addition of, permanent fuel tanks orfuel system components, including ENG sealants.
29 UNCONTROLLED COPY WHEN DOWNLOADED Check with FSIMS to verify currentversionbefore usingl 

# ..

USDeportment ofTransportation FederalAviation Administration 

# Advisory 

# Circular

AC43-210 DATE: 2/17/04 

# STANDARDIZEDPROCEDURESFOR REQUESTINGFIELDAPPROVAL OF DATA, MAJORALTERATIONS,AND REPAIRS

Initiated by: 

## AFS-340AC 43-210 NOTE: Thesubstitution ofsolid rivet fasteners with blind rivet fasteners in airframe structures may reduce the structural fatigue life ofan airframe. These repairs should be evaluated and, when appropriate, authorized by either the manufacturerora representative ofthe FAA. 302. What alterations and repairs do not require a field approval? 2/17/04

a. Some alterations and repairs do not require a field approval, and requests for such unnecessary approvals will be denied. The following alterations and repairs do not require a field approval: (1) Alterations and repairs that are not "major" do not require a field approval or STC, and such requests for FAA approval are unnecessary. (2) Alterations and repairs that are fully supported by sufficient previously approved DER-approved data do not require further approval. See FAA Order 8110.45 for additional information. 

### b. Ifyour alteration orrepair does not require a field approval or STC, the ASI will explain that your approval request is not necessary. He or she will also provide you with a letter stating that your alteration or repair does not require FAA approval based on the information provided in your request. 303. How do I create the data package? a. Gather data. Gather and/or organize the data that describes your proposed alteration or repair. Review Chapter 2 to see what types ofdata may be used. b. Complete the Field Approval Checklist (optional). The checklist is one way of organizing your data and information before you request a field approval. Itis a tool to ensure that you have everything you need. Appendix 2 has a copy ofthe checklist and the instructions for completing it. c. Review FAA Order 8310.6, Airworthiness Compliance Check Sheets Handbook. This order contains a variety ofchecklists that can help you determine ifall ofthe applicable rules and regulations have been considered. This document does not contain every possible alteration, but includes many common ones. The compliance checklist specifies each certification rule and the method by which compliance is shown (e.g., analysis, structural test, ground test, flight test, and so forth). It provides a concise, easily-reviewed list to help ensure that relevant certification rules and their means ofcompliance are addressed. Fordetermining design loads, review AC 43.13-2, Chapter I, Structural Data. d. Complete FAA Form 337. Complete FAA Form 337, with the exception ofthe signatures in blocks 6 and 7.· (The signatures are entered afterthe alteration or repair is completed and inspected for conformance. AC 43.9-1, Instructions for Completion ofFAA Form 337 (OMB No. 2120-0020), Major Repair and Alteration (Airframe, Powerplant, Propeller, orAppliance), as amended, provides guidance on how to completethis form.) Block 8 documents the alteration/repair and is the permanent record ofthe alteration/repair. This entry should be as complete as possible and contain all ofthe data thatyou have developed to substantiate the alteration orrepair. Page 10 Par 301EXPERT REPORT OF GARY NORVILLE This report is prepared at the request of The Llbetiy Foundation Inc ('TLF' or 'Foundation"). in conn"ection with a civil penalty proceeding brought by the Federal Aviatron Administratron ("FAA') against TLF in Docket No. FAA-2012-0477. In connection with making lhrs Report. I have reviewed the FANs Complaint and TLF's Answer And Affirmative Defenses so that I am familiar with the issues in the case. I have also had conversations with the Foundation's attorney, Stuart A. Goldstein, about the case. f am Gary Norville. owner of American Aero Services in New Smyrna Beach Florida, which has been in business restoring and maintaining warbrrd a1rcratt for over twenty years. My Opinions: I am of the opinion that the use of aluminum fuel tanks in N390TH was not a major repair or major alternation since the fuel system was not modified in its intended performance. On page 2, para 2, sub para a, T. 0. 01-20E-3. Structural Repair Instructions for the B-17G, it states leeway is provided during certain conditions. Original self-sealing fuel tanks are no longer available and if they are available, they are usually cracked opening the self-sealing compound which the fuel activates. The use of the aluminum fuel tanks did not change the basic design of the of the fuel system. which is the definition of a "major alteration." I am also of the opinion that N390TH was properly returned to service in accordance with applicable Federal Aviation Regulations after maintenance in February. 2011 and June, 2011. I am also ofthe opinion that TLF exercised due diligence in its oversight of the above-referenced maintenance.

GG90-SG1r98S S8::llt\.18C:: 018\-f U8::J1.18LU\-f

# IO,Q_VERNMEN:t.· 

### I**EXHI~IT·** ., 

# ; D 1P
.. j ..,.,.,,._. ' '

# ...

Facts Or Dafa I Considered In Forming 

### My Opinions: In reaching my opinions expressed above. I reviewed and/or considered the following: (1) the FAA's Complaint: (2) Federal Aviation Regulations in Part 43: (3) maintenance log entries made after maintenance 1n February, 2011: and (4) T_ 0. 01- 20E-3 Structural Repair. My opin1ons are also based on my 

### 20 years of experience in aviation and, in particular, my experience with 8-17 aircraft Exhibits ThatWill Be Used To Summarize Or Support My Opinions: Maintenance Log Entries dated February 24, 2011. FAR Part 43 Sections 43.5, 43.9; Appendices A and B. 

### T. 0. 01-20E-3 Structural Repair. My Qualifications: Publications in the last 10 years: None I hold FAA Airframe and Powerplant licenses with Inspection Authorization. I have nottestified as an expert in the last four years. Compensation: $300.00 per day.

Gary Norville Date

### U.S. DEPARTMENT OF TRANSPORTATION Office of Hearings

Washington, D.C.

In the Matter of: Docket No. FAA-2012-0477 LIBERTY FOUNDATION, INC., Case No. GL-03-0070 Respondent.

DEPOSITION OF GARY NORVILLE Wednesday, May 1, 2013 10:26 a.m. 1701 Columbia Avenue College Park, Georgia Renda K. Cornick, RPR, CCR-B-909

REGENCY-BRENTANO, INC. Certified Court Reporters 13 Corporate Square

- Suite 140 Atlanta, Georgia 30329 404-321-3333 

# IGOVERNMENT 

### i

. EXH,T_ 

# i- fi

.... •Gary Norville In Re: Liberty Foundation May1,2013

1 

### those are the FAA's complaint, the Part 43 of the 2 3 4 5 6 7 8 9 

### 10 Federal Aviation Regulations, the maintenance log entries in February of 2011 on the Liberty Belle and particular portions of the structural repair document? A. Yes. 

### Q. In coming to your opinion or in drafting this expert report, were there any other documents that you reviewed or considered? A. No. 

### Q. It references on the first page of this 11 

### that you had conversations with the foundation's 12 attorney Stuart Goldstein about this case. Have you 13 ever had a conversation with anyone other than 14 

### 15 16 Mr. Goldstein about this case? No. Just Mr. Goldstein. 

### A. Q. Have you ever spoken with Mr. Schneider 17 about this case? 18 A. 

### No. 19 

### Q. Have you ever spoken with Cullen Underwood 20 about this case? 21 A. 

### No. 22 

### Q. Other than what is written in the 23 February 24, 2011, maintenance entry which is the 24 third page of this exhibit, although again I 25 understand you did not attach that, have you

REGENCY-BRENT ANO, INC. Page8Gary Norville In Re: Liberty Foundation May1,2013
1 2 

### 3 4 

### actually, that's the other February 24th entry. MR. GOLDSTEIN: Right. Q. 

### (By Mr. Stevenson) Other than the February 24th, 2011, entry about the work on the fuel 5 tanks, do you have any knowledge of

-- and the fact 6 you heard Mr. Fowler testifying about it earlier this 7 morning, do you have any knowledge of what work was 8 done on the aircraft? 9 

### 10 

### A. 

### Q. No. Given that your knowledge of the work that 11 was done on the aircraft at the time you wrote this 12 expert report consisted of reviewing the February 24, 13 2011, entry, would it be fair to say that you could 14 not have an opinion as to whether or not that 15 maintenance entry accurately reflects what was 16 actually done on the aircraft? 

### 17 A. I don't know what work was performed. 18 

### Q. So let me know if all the answer you can 19 give is to read back the maintenance entry. But what 20 was your understanding of the work that was done on 21 the Liberty Belle on these fuel tanks in the months 22 leading up to this February 24, 2011, return to 23 service? 24 If you need, I can give you a copy of the 25 return to service we are talking about.

REGENCY-BRENTANO, INC. Page 9Gary Non'ille In Re: Liberty Foundation May I, 2013
1 

### 2 3 A. 

### service. 

### Q. Let me see a copy of the return to

The return to service we are discussing**~s** 

### 4 Page 4 of what has been marked as Exhibit 7 for this 5 6 7 8 9 

### deposition. In your own words, how would you describe the work that was done on the fuel tanks in 

### 390 Tango Hotel? 

### A. I don't know if I would form an opinion of 

### 10 what work was done except for what I am reading in the 11 12 

### logbook entry. Q. 

### Okay. That's fine. If your answer is 13 

### I mean, when I ask you a question, I want you to give 

### 14 me an honest answer. If all you can say is what is 15 there, don't worry about what I am looking for or want 16 

### to hear. 

### 17 A. No. What I am reading here as the logbook 18 entry is the most I know. 19 

### Q. Based exclusively on this logbook entry is 20 it your opinion the work described is a repair or 21 

### alteration? 22 A. It was a repair. 23 

### Q. Why do you believe 

### 24 25 MR. GOLDSTEIN: Can I have the question read back, please.

REGENCY-BRENTANO, INC. PageiOGary Norville In Re: Liberty Foundation May I, 2013
1 

### 2 3 4 5 6 7 8 9 

### 10 11 

### Q. A. 

### (The record was read by the reporter.) (By Mr. Stevenson) Why is that? The self-sealing bladder was no longer able to sustain holding fuel. Originally in the early B-17s there were aluminum tanks. Then as the war came about, they had to go ahead and put self-sealing tanks in the aluminum tanks to make them combat ready. So the way of repairing the self-sealing would be to go ahead and make the aluminum tank integral again to where it could hold fuel. There is no repair for self-sealing tanks 12 that is economical or the process is out there 13 anymore. 14 Q.. 

### Again, it may seem repetitive but for the 15 purposes of comprehensiveness, so I asked you based 16 exclusively on this logbook entry, do you have any -- 17 18 19 20 21 22 23 24 25 if you considered everything that you know about the work that was done on this tank to the extent that that includes anything beyond this logbook entry, would that change your opinion that this was a repair, not an alteration? A. It wasn't a major alteration because it didn't alter the design of the system. 

### Q. Well, I am asking you now if you think it
was a repair or an alteration.

REGENCY-BRENTANO, INC. Page II1 

### 2 Gary Non'ille


### A. 

### Q. In Re: Liberty Foundation May I, 2013


### A repair. Okay. And again for clarity, considering 3 everything you know, you believed it was a repair. 4 5 6 7 8 9 

### 10 11 

### 12 13 

### 14 15 16 17 A. 

### Q. A. Q. repair? 

### A. Yes. And do you believe it was a major repair? No. And why do you think it was not a major

Because it was not a structural component, there was no structural damage. The damage was repaired by welding, not riveting. 

### Q. Anything else? A. 

### That's it. 

### Q. Are you familiar with the regulatory definition of what makes a repair a major repair? A. 

### Q. Not verbatim. Generally, are you familiar with it 18 generally? 19 20 21 22 

### 23 24 25 A. Q. Yes. What was your understanding in general terms of what makes a repair a major repair? A. If there is structural damage. 

### Q. And are you familiar generally under the Federal Aviation Regulations what makes an alteration
a major alteration?

REGENCY-BRENT ANO, INC. Page 12Gary Norville In Re: Liberty Foundation May 1, 2013
1 2 3 4 5 6 7 8 9 

### 10 11 

### 12 

### Q. I noticed that although everything we have talked about what you reviewed has to do with the work in February or the return
-- the work that led up to the return to service in February of 2011, it also says in your expert report that I am also of the opinion that the Liberty Belle was properly returned to service in accordance with the applicable FARs after maintenance in February of 2011 and June 2011. Have you reviewed the June 2011 maintenance entries as well? MR. GOLDSTEIN: Entries or entry? 

### Q. (By Mr. Stevenson) Have you reviewed 13 anything in June of 2011? 

### 14 A. Yes. January, February, March. 15 

### Q. I think by the eighth page we get to 16 June 2011, the eighth page of Deposition Exhibit 7. 17 If you haven't reviewed these, that's fine. 18 19 

### 20 21 22 

### 23 

### 24 gave

looks
one. 

### Q. MR. GOLDSTEIN: It is not in the copy you me. MR. STEVENSON: Exhibit 7. Sorry. THE WITNESS: The June one, the June lOth familiar. June 13th, I don't remember that
(By Mr. Stevenson) Okay. So it would be 25 fair to say that you do not have an opinion as to the

REGENCY-BRENT ANO, INC. Page 24Gary Norville In Re: Liberty Foundation May I, 2013

1 2 3 4 5 

### June 13th entry or the repair work that it describes. A. Well, restate your 

### Q. Okay. I correctly understood you said you
are not familiar with the June 13th, 2011, entry. A. I don't remember seeing that one, no. 6 Q. 

### Okay. Given that you don't remember, 

### 7 would it be fair to say you do not have any opinions 8 

### about it one way or another? 9 

### A. No. It is a logbook entry that a repair 10 was made. 11 

### Q. Okay. And also again just because I have 12 to ask, do you have any knowledge of the underlying

-- 13 not just the entry but of the underlying work that the 14 entry is describing? 

### 15 16 

### 17 18 

### 19 20 

### A. No. Q. 

### Do you have any opinions about

-- and therefore you do not have any opinions about that work, either. A. 

### No. That's just a logbook entry. 

### Q. I am going to go back to the question 21 of

-- I know you said you thought this was a repair. 22 But you have an opinion

-- but you do opine that this 23 would not constitute a major alteration, correct? 24 

### 25 A. 

### Q. Correct. And 

### in your reference

-- I am referencing

REGENCY-BRENTANO, INC. Page 25( 

# .

U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS FEDERAL AVIATION ADMINISTRATION

FEDERALAVIATION ADMINISTRATION, Complainant,
vs. LIBERTYFOUNDATION, Respondent. DocketNo. FAA-2012-0477 FAACaseNo. 2011GL030070
Judge Sullivan


### AFFIDAVIT OF DAVID ALDERMAN STATE OF TENNESSEE COUNTY OF DAVIDSON HAVING COME beforetheundersignedNotary dulyaJJthorizedto administer oaths, David Alderman, did state under oathafterbeingproperlysworn, thatthe following statementistrue and accurate: 

### l. I am overthe age of 18 andI understandtheobligations ofan oath. 2. I am currently employed with the FederalAviation Administration as anAviation Safety Inspector (Airworthiness)- Principal Maintenance Inspector (PMI) atthe NashvilleFlight Standards District Office (FSDO) inNashville, Tennessee. 3. I did interact with Rodney Schneiderconcerningthe maintenance logentryreturning N390THto service onFebruary 24, 201 I. This interaction did not occuruntil afterthe aircraft hadbeenreturned to serviceand operatedbyThe Liberty Foundation. At thattime, Mr. Schneider showed me theFebruary 24,2011, maintenance logentry, and afterreviewing the entry Iindicated to himthatit was acceptable. Atthe time, Ihad no knowledge ofthe work that had actually beenperformed, only what was statedinthe logbookentry. 4. I flew onN390TH, andperformedmaintenanceon N390TH, afterthe February 24,2011, returnto service. However, Ihadno occasionto viewthefuel tanks, and remained unaware of the truenature oftheworkperformed. 5. Atthepresenttime, I havebeeninformedthatTLF's work onthefuel tanks consisted of removing the bladderfuel tanks, fabricating attachments, welding those attachments ontothe 

# I GOVERNMENT 

# j EXHIBIT 

# i FF-aluminum support shells, weldingplatesoverexistingholes in the shells, andwelding shut the removableendsofthe sheHs. I was not awareofthis when Mr. Schneider spoke with me about the fuel tanks in early 2011. 6. Knowingnow whatTLF did withthefuel tanks onN390TH, I do notbelievethat the February 24, 2011, maintenance log entrypresented to me 

### by Mr. Schneider accurately describes the work performed. 7. The workperformedbyMr. SchneideronN390TH'sfueltanks overthe winterof2010- 11, was a "major;, and a Form 337 shouldhavebeencompleted. Further affiant sayethnaught. I hereby swear oraffirm thatthe above is accurate and true to the best ofmy knowledge.

Sworn and subscribed before methis (lfltrayofAugust, 2013.
Notary Publtc · · My CommissionExpires:

## ~**\~** 

## \0\d-0

## llU.S. DEPARTMENT OF THANSPORTAT[ON 

### OJ!'J(ICE 

### OFHEARINGS**lii;:Jn~HAL** 

### .t\.V[ATlON Al>l\UNmSTRA'fiON



### FEDERAL A\.r.I.ATION ADNUNJSTRATION, Compla1n::mt, \IS. 

### Docket No. FAAM20J2

..

### 0477 Ft\11. Case No. 201l0Ul3007Q 

### I,mERTY FOUNDATION, 

### Judge 

### SuiJ**~V41n** 

### AFJ?JDAVJ1' OFTUOA:l.t.\S,SOE!RENS 

### STAT'EOF IlLINOIS COUNTY OF 

### HAVING COMEbef(m= the m1dersigned

### Notr~rydulyauUmrized 

### to administeron.tHls; 

### Thomas Soorens, did $laic::**~ut~cr o~~.h**  

### after bdng

### pro.petly**s,.;.·om~** that

### J.he

### foltowirlg**s.r.at~nsH.:nt** 

### h true an:d accurate: 

### I
. 

### Iam**ov~r** 1 

### be n.ge of1:8 and l understand

### tl1e o bligations ofan nat

### h. 2. 

### Jam currently

### employed ·wirh the Federal**Aviation.Admia~isGndion ~1s** 

### a**Principa~** 

### t\irworthinc.Ss I nspecto:r-**M~tanten::tnec (P~ofl)**  at 

### the Du:Page PDi

### gilt**S•~nd.;mfs [)~strict** 

### 0 

### fll.ce (FSDO} 

### in**We~f f..:hi.l.'~gc>~**  

### Illinois
.. 

### 3. Jhave servedat i.he Federal Avcation Adminisfrn[i01) <l$ fUi 

### A.i;roN·onhincss/1\.{ait:Hetl<l:flCC 

### lnspe>e,A)r

### for{lVer23 years. 

### 4. Jhavehetd •1 

### Mechahic Cert:ifitatc v.,·ith Airfnmle-and f':owcrphmt Rartlngs fm over'4Cl yeo.rs. sinec .i**972~** 

### and have 

### held an 

### Inspec-tion**A~Uhori7** 

### ...ation 

### since 19'75_ .I 

### have 

### also held apnlot**~crtifict~tc** 

### since 1974. l'rior t<;' myservi¢c**\\~.th** 

### the**PAA~** [spent 

### I

### 7yeats working inprivalc

### sector·aviation maintet1tance, fltst**,:~s ~ij**  

### linemechanic and later.as a

### Directorof**Mainc~mrtnce** 

### fora 14 C.F.R. Part 135 Air**C~uricr:,.**

### a Ch1cflnspectorf.or**~** 

### 14 C.F..R. Part 145 RepairStation, and as**lechnida~l** 

### and**Qut:~lity** Inspector

### :for Wag Aero

### Group•.My

### .:.whttion 

### mafntc.nanoee 

### cxpcric.ucc includes \\"<Jrki:n:g 

### an scv·cral 

### ''··arbird ailfC.tafl inehiding ah·cmft

### associated with lhc 

### Expcrimcnt3il 

### .Aircmft Association.

; GOVERNMENT 

# i EXHIBIT 

# I 

# G-G--" I

### l•m Hunmar ,,,:ith the faJ;:ls oftnlscase;.c(ltl:eerning**~he** 

### w·ork 

### J>Ctfonncd on

### N390TB's

### f\~c.:l sy:stcm illi 

### late 20J 

### 0**throt~gh** <:arly 20t i ,

### c.u!mirmtiog in a Ftl!bruary 24, 

### 20l 1, return 

### to scrviccj and aJso conc{:mtillg the June 

### 0,20'11, 

### .li:1ci leak 

### in one ofN390TH'snc\V 

### fuel 

### tanh. 

### The material 

### Iluwc reviewed tndudes 

### thetli.:p-osition ofthe

### mcchnok who

### pcrform.edlhe work 

### in**<H~csti!iJn,** photographs 

### etf(he \Vi

### rue:- 20lQ.

## tI \Vnrk

### .it~ 

### iP•tOgress•.photo;graphs 

### and \'idt.·i) 

### ofthe 

### Ji,!inc201 1fuel J 

### cak, applica;blc**por~ions** 

### ofthc**m~hHena:nce**

### rc.cords; for

### NJ90TJ[, applkabtc portionsofthe B-l7G

### stnrct~E~ml repair

### handbook,**m~intcuance**and

### ;£:rec.tiolll.l:mndbook;**an~** pMts**~ist,** 

### and certificaHo:nand 

### rcgistrati.Oo irtformatao.n forN390TIt 

### 6. Iam

### famiH~1r

### withthe Fcder.al Avlaticm Regulations 

### illld polky documents issued by

### the**Admini~~t.rllt)r**conccrn]ng repairs.,**~Jtcn1tio:ns,** maJor

### repair$, tt1ajor**al~eraHons,** and\vhat

### sorls of**'W~)rk** 

### on**<'lin.~:ran** 

### fa.l! imo 

### \tvhich ;:;:ntt.:gory.. 

### 7. The: aircraft 

### lnvolvecl**it1tb1s.CftS~:; ist~BodnfrB~l7G,**  

### st::rraU**numbcr44~8:5734,** regisiercd 

### as civil.airc:r.atl

### NJ90TJil**~t** 

### NJ90TH "'l.3S**buH~** 

### ·w[d:Ui.H:ltanocs c{}nsisling

### ofsix**t;ihick~** 

### sclf·se1:1nng blnc.kh:rfuel 

### tanks; threein each 

### v•titlg.**E~4r:h** 

### bladder O.tel**tank\\'~ ir~st~dkd**  

### in**~m** 

### alum:im.tm 

### shell 1hat 

### surrounde<l**tJH~**

### b~adder 

### M;;'ks 'md wasattached to t)lc 

### interiorof

### the wing hystraps, AU

### <tttadunctlt~

### bctvveen the

### liiell~nks amd the rest ofthe

### dbd sy:stcm \vcrc fixerl dhcctly into

### the:bJadder

### fuel 1anks. Jn

### ordt~r tt;,1**~~ccommodate**

### the**strap~** 

### nnd various**auachtner~~s {~r:Kl**  

### fiJtings,**numermL~** 

### ho.lcs were present in the aluminum :shells, A•iditionally; one emf

### nfthc altlminum shells**w~ts** 

### removable, so 

### Jtcould

### he taken fl'tl 

### or

# orrfhc bladder**fue~** 

### tank:, 

### 9. ln getbe.t·a.l tenns. inc \Vork

### em the ntel**~ys~\!:m**

### ofN39(ffH that 

### culmirmtcd :in the Februar:y 24, 201 I, mu1rn (O 

### &crvtcc consisled**ofr~;1uoving**

### the bladder

### fud 

### tanks cnf.irdy, titbrkath1,g 

### n fi

### U.er

### nec-k aWJK:hpoi11t, a

### tl1e! 

### boostpump attach poi.rlil

### on fiJur ofthe six 

### fuel tanks, 

### a·**j~lcl** 

### quantity 

### trnnsducer mtnmningpoh:u, fuel 

### system

### nne attadn:nents

### mld**p]all~s.**

### to scallhefm•mer fuel 

### hladdermot.mting points, 

### 'Neldblg**thost~** 

### rrttaclnnents 

### and 

### ptalc.s<Onto the**almnin~rms.h'.:ll,** 

### '"'{:]ding shutthe 

### remov.aihlc

### end oftbc

### sheH,and

### cozmec1i:n.g eachoftile six shells into**~he** 

### ,existingfuel system us fueltanks, 

### 10. 

### l ,.Yl.'IS**ut~stJJeces$Hll** 

### in**~ucaHng** 

### anothe-r**B~l7cutrcnHy**

### inus.c that

### f1ad heen**convt~rted ~o**  

### a sand

### meta!Jie 

### liln:k system

### c<::ms]sting of

### an ahltnimrm 

### shdI,,vith

### hclles that**h;~d** hcco plugged by**\veldit~g ~t** **v~~rk:iy** 

### offabricated 

### auach:ments ;md platesto tEle sheik

### ·Or (tmanufacturc,dl 

### with a r<:movabtc end

### that was

### then w.cJ,dcd closed. ll. This work**w~~s** an ahe:mtton, not a**rcp~~ir.**bct:iULSC itchangedlhe'design ofrhe 

### aircrafl and 

### its componeJlts, and

### \l.'aS 

### not .simply a rcslor.ntion ofthe

### aircroft 1(l 

### an 

### tnl:darnagt:cl state. 

### 12. The**~H¢ralioil** 

### was: a maim al**ter.;~tlOJt** 

### As s(ntcd 

### in section E.

### J 9f

### the F(Xknll A v]attion**l~egublions** (Definitions): 

### Mnjor**<llten~•ion** 

### m4.:ans an**u~tcretion** 

### not**ltste~l** 

### in the 

### aircraft. a]rcrnft cuglne,or prop(.!ilcr s;pccitications..-..

### (1} ·nmt 

### m.ight appreciably 

### affect 

### weigltt, bal:.mcc. stmcturf!l S(rcngth, 

### perfomtru1cc; powerpl:mt

### Cl:PCnillion. flight

### cha:t·.nc:terislics. ·orother

### qualh3es affecting**ainvorthint!ss:~**

### ·Or 

### {2) That isl'llot done**accordi~g** Wa<:ccptcd 

### practices

### .or·

### ca1,rw•. bedon:c by 

### clcm<:ntary 

### operac!ons. 13. There are several**nu.~som.**

### v,.;hy the 

### a1temti (m.l,lifftS

### a nilajoralteration. 

### With[n four

### months ofthe**.alteration~** 

### the \'vclding

### crnc!ked in 

### one ofthe**nc'~v**

### tanks, resulting in (t 

### fuel**lc-~k** 

### Tihis 

### \Vas an apprt:<:ittblc effect on aquality aflectbtg**~he** 

### ainvorthiness 

### ohhenlrcmflThus; the 

### altcratirm wns a major aHcrnti.m1. 

### 14. Addijci:onally.•even setting:as1de 

### the fud teak, tbc removal 

### ofthe**bl~dd·cr fuc.~[**  

### il.3nkco:ulci 

### bave had

## an appreciable**effe~t**

### on

## the airwu.rlhincss of

### the

### airc.t'aft. anti itsfuel**sys~em.** The alteration**incr~a$ed ~be**  

### fuel tapa<e]ty of!he aircraft,**~ffeccing** wcighl

### :<md hahmoc**~nd** 

### rJOssiblc 

### stresses**pl<~ced** 

### on the \"ling structure. The HC'\V

### ahnniruJJm**fuc~** 

### tanks were SliS<.:cptihle 

### to vibruHonal stresses in ways

### that abi(tc.idcrft1d 

### tank was not.. An almninum fuel tank wo:mi'd not 

### respond lhe same**\.\~ly** 10 

### the**s~rcsscs** 

### of

### the in.·:fHgbt mutiol'il 

### ofthousands ofpomtds

### ofaviarlon 

### fuel**as~~** 

### scnli-rigidbladder·tank "''Olitd- 

### bn:fillc.s should 

### have.been Jncorpor.atcd into any**h~~rd** 

### shdl fuel tank design

### for 

### ((tnks.oflhcsc

### s[z-es. The 

### newly :n.tbricatcd fixQures 

### and attat:llmcnts may or ma>' 

### not h4li'.'C been of**~qual** 

### quality wilh**4h~ c-omponen~s**  

### they

### \Vere**repl~cing.** 

### Th.c fabricated 

### tixhtrC!Hmd attaclunenlc;., 

### even nssmning lhatthey were 

### of<:q:t.lul·quality tothe,parts

### they 'Ncrc 

### rcp]aciog.; had changed

### fto:m beingattached lo

### ·the**scml~r£gid** bluddc:r**tanJ~** 10,being**~ttacbcd** 

### to the.rigid aluminum Cank. 

### \:\.flich coukl**imp~~~•** 

### howthey responded 

### to stress during 

### llighL All

### of ,fhcse problems**~t~c cx.ac~crba.ted**  

### becausethe 

### ulumimnn tmnks\il,"t:ru not s}:mpty 

### so[id. fot·tuct[ 

### atmninun; tnnlk.s, btU.hnd 

### been**exteo~ivcly**

### >'\•clded,. 

### introdudng

### mJn'lcrouspotential**''i<'C~tknC'.SS(~s;** 

### int(1lhe sy.s:tcm**~·us** 

### can he 

### seen by 

### 1hc<:rackingthat developed in one. ofa he thelta:nh

### i,n kss than fourmonths, tbe wc[J 

### sc::rms arcatiource

### <OfsCructLmJl**w~.akness** 

### and**c~ua** 

### make the tank 

### mort! susceptible

### co issu'Cs \Nith 

### v3brntkm and stress. W'dding.

### c.an also hicrcm:;c

### the possibiHty

### of con-o!>ion. The "'rcakncss.es that 

### cn11 

### bein•roduccd by \\'elding

### art:' highlighted bythe: 

### B-170 Stnlctur.a] Repair

### Handboc.J:k

## 's prohibitionon**~A<e.lding** 

### alomirunn stmcC

### mal me.m

### hers

- while 

### !he 

### fuel rank is

### not a

### strcnelurtt! component, 

### and**we~ding** 

### afuc[ tank is 

### per,miss.ihlc l.CUidcr appropriate. 

### circumstm:tccs. fhe: same

### potential**wcakt.~cs.scs** 

### inthe**tcsul~ing**

### comp(lncnt 

### aro stitl pres.et1t

### ullid musl beaccounted

### for. [5. Also, 

### any alteratiC)n 

### ofa 

### fuel lank

### is a

### n1ajrm·;ahcr411iott FAA Order 

### 8.90CJ.I ji:rovides e.xtensivc**gui.dn~nc:e**

### to Aviation 

### Safety**Jt~specCor..s**

### inthe

### pcrfom1ru1cc 

### oftllcitduties. One

### ofthe fl<Jssib!c duties 

### ofan AS

## rIs

### field approvals 

### of

### maj:oraheralion:s
...l\e(,"'ruingly, oinc oftbe

### jo'b4!MS 

### in th£ 8900.1 is a 

### n.s.t nfmajor**~dtcraci.ons; ;J~nd**  '''h-olher

### the.required 

### uppro\•alcanbe

### aHeld approval, rQt,J.SliJc 

### nn 

### engine-ering approval, 

### orrequires 

### nSuppJcmcntal Type

### CertHicnle. Onthe list nf:majcJr**~1ltcr:::~tions**

### isany chmtg:c 

### itJ 

### a**p~'Tll'HUlcnf** 

### fud tank, or in.sta['].i:11ion 

### ofnnc\v 

### fuel umk. [7,**Further~** 

### the**fabrka~joil** of**~lC""'** 

### fud t:.tnks omoflhe

### aBurtrirmn1 shcHs 

### wasa 

### .major aHcr::1tionbecause**fahdca~h;g**

### c;cJmp<Jncnts

### nn<l \'r'eld1ng 

### are n.vt**~m** dcmcntm')'

### openuimt**I~.** 

### [am a\v.are (lf

### the proYisicrn in Appendix AofPart43 ofthe 

### F""<feral Avintkut

### Regulat]ons that iists 

### changes in tbcbasic 

### design ()f**~t** 

### Jucl 

### systemas an examplcofa major

### altt't.Utuon. Tihe**rcpi~1cemcnt** 

### of

### the bladderfueJ laJ:1ks with fab:ricatr.:d ntmninu:mfillet tanks -vvas :it 

### change

### tnthe tKtS[c

### design of

### tlte

### J'\tel**sys~ean.** 

### \Vbi!e 

### someofle CtJr
. 

### .ddmccJmnically

### list dozens of**co~npom.:nts** iJ:tnt lV£fe

### not repl-aced in**rcpl~cing**

### the fuel tanks:,,thisdoes: 

### nol**mc~m** 

### lhatthe**te~~lflCCltiCnl** of

### the 

### fuel**t<~mks**

### -.-vas not a change inthe basic: 

### dcsJgn 

### oftJ1efuel system. Fue] tanks. artdi their 

### ahili(y

### to pcrformproperly, 

### ttre**absolu~~dy vita~**  tD 

### the safeJunciionrng

### ofa

### fuel system and

### aircrafl- not the least because

### afuel leak 

### c'Zin have 

### dfsasc.rnus consequences 

### f4)r**~m** aircraft 

### The 

### import'*nce of the ftJcl t,unks-to the fuel 

### system**c~n** 

### be 

### seen in 

### guidanceprovided hy

### the,**Administn:l~or**to 

### FAA inspectors 

### in

### the 8900.1. \Vhcre allaltc:r.nti<'!Jl:S

### to fuel 

### tanks are classJHed us major

### alterations. 1**~,** 

### .Additionally, based-£)ttl my

### experienceasa 

### mechanic**~md** 

### an 

### FAA t::mi}l(l)'ec**~** 

### it ismy 

### opinion thatfabt.ieating 'l

### fud lankoutofan nh1minum sJvdl by

### \Veld1ng (111**aU~chments**

### and metal plates ((H;losc

### openingsis

### m1t a"tl 

### iJG·cepicd practice,
.

### .us that 

### term is used in**~he** 

### FAR U 

### dt,:dinlticm;s 

### Qfmajor alteratiotl 

### and majorrepaur. · 19. Each ofthe 

### :n:.;nsons dcsc:dhed**above~** 

### standing a[onc, Wfftli!d n:ndc:r the aheratkm t1 

### mujor alterat\cm. 

### 20. The work p.:.:rformcd that 

### cuhnina(ed 

### in the 

### February 24,201I; rc.furn to 

### servi-ce was 

### ;,m**pJter~l~ton.** 

### notarcp.ak 

### lhYV.'eVCr, 

### iflt'\vas

### arepair. 

### it**w~Ytdd**

### be

### amajo:r t'Cp,ilit. 

### As**sita~cd** in 

### ,section 1.1 ofthc**l~ edcral**  

### Aviation

### Re-gulations (Dcfinit]ons): Mujor

### repair**m~ans** fl 

### re:puir: 

### 0)

### Tliat,

### ifhnprnperly done, might**f~ppn.::ciably**affect

### weight,**lx:~J:mcc,** 

### structl;l:rnt strt:l:Jgth.performance,**pO~\.rt;<rp]ant** 

### operation, flighl clHtractcristi.c.s., or(llber 

### qlti:dlticsaffeeting**~lt\vtlrlhjm:ss~** 

### m {2) Tbal 

### is nut done

### acc·ordit1g 10 

### ncccptcdpractices 

### orcannot be done

### by elementary opemtktt\S. 

### 2L The dishnction betw>een a tlH'JjVrrepair

### and minnr· repair**l~qrgdy ~racks**  

### the dis1in'..:lion 

### het\vce:n .::1**m~~jor ~nd**  

### minnr-**ahen~~ion**..

### As such, all hut one 

### ofthe reasons

### dl:scusstco,:,l abuvc

### as t<J why

### tbc alteration 

### 'vas a**m~lior**

### ai:LcmHonarenls(l 

### reasons ,,.,·hy.this 

### \Vould**he~-** 

### majorrepair, ifit 

### had been ar-epair. 22. The-one

### exception is regarding

### the**e:x~rnple** in./\ppcndix

### A about h<w"' 

### u**dHm~c** in

### the ba.;;;ic: design (Jttilcfue] 

### system is aml]!jor,**a[~cmfion.** 

### This example is :tl{)C. lllppficable to 

### repairs,**Hov;I·CV<.~r,** 

### Appendix A 

### alsopr<WEdes**~hat**

### cm::h 

### and every

### repairofafud

### tankis amajorrepair.. 23. E:;u::h 

### <.tnhc rcas;.)ns ickntit1ed lJlb(JVc, 

### :standinga:lon:e, would renderthe \V.C)rk 

### a mojor 

### t>epair', if

### r¢ ·was a repair. 24. Theahemtl()11 ofN390TH is .not de.seribcd i.rn any maintcM!lc.e**rn~mu~d** 

### orinstructto1t:> 

### f{.fr continuedairwnrthincss forthe**B~**I7G.

### 2.5. The rnc!hQds, techtliqucs:,**a:r1~** 

### practices \JSOO by 

### RcsJ}()t11det11t ht

### i:tlteriing Ute alrcmfc are not 

### ncoe:ptublcto theAdin1nlstmtor, Retpondent'sahcnuion introdu-r:e{E 

### numcrous potem1al-and aciua] -weaknesses 

### [nto the atrcrafr:, mrnddid 

### not incf!.lde 

### chesort of

### inspeci:ions:necessarJt t<-1 

### verifythatthe new fu.e)**:(~mks** 

### w·cre 

### capable of

### wi.uhstond.iJjgthe stresses.offlight 

### 26. TheaJteratim1 

### afNJ9HTI"fw.ll!S 

### not

### chnc in sucl1 a·way as·fo 

### resto:re the cond.ihun 

### ofthe aircmilto at !c-astits 

### origlt:Jat Qrproperly 

### aUerod condition

### \\1th**:t~Sflett** h) 

### rc::si.sh:moc to ,·ibrnticm 

### and**detcJ:ior~tion**

### ,t\jJd otherqltaliticsaffcc;t]ng 

### airwnnhiness, All ofthcfactors

### :rnendoned itl 

### paragr41ph 14 arepc:rtincnt her£, 11m

### exrensive wcldln:g onthe 

### ncvtft1el**tank~** 

### made lilcm V!1]**ocr•~b]c** 

### to (be 

### stresses offHgjlt**jr~** Wfl)"Slh<ti 

### the 

### migfna[ t<mks \'VCJ'e 

### not, f.lil1d !his rc:mitcd in the rapid failm.e- ofone of

### the 1anks. 27. N:l90TH**\Vf~S** 

### unuirworthy

### he,cauw it 

### di.d t'l<)t 

### confom1 to its 

### type c.cr.t:ific.afc or 'type 

### design. The.aircraft did notl(;onfbrm 

### to hs 

### C}':pe ocrtificarc

### ortYfle 

### M.sltgtt because

### rhe B··i

### 70's design 

### never corHcmp)1).ted 

### taking an ah:uuinum

### shell! 

### ·with numerousholes 

### in**i~, fi:lht&e~ting**  componenM:.}iJld 

### weldingthem onto that 

### she!].,.!Jind them 

### using lt

### asa fuel t.rll'lk. 

### N3·90TH'.s specification sheet, \\1lic.h**i.~** 

### no;,.v 'Inc type 

### certificate 

### il1r**d:J~e: ~jr.-cr.afit,**  

### requires

### that 

### fi.1r2'eflatffl or modi.11cataons 

### natJislcd in tile :Jircrafi's**nt..'linEt.~t'liilt:!Ce** 

### m.anmds, the**rt~pair**

### or modJUcaJionmust fir"l

### be 

### presented to 

### Civil Am'Onanti-cs Adminislnd:ion 

### (now the.**Federa~** 

### Avim1ou**Administr.at~on).** 28. 

### Tile aircraft did notconfonn 1 1.0 

### .its iypc 

### certificate 01'

### type design 

### because it

### had no·L 

### IJc:.en**r~storcd** to its

### original or pt(}pcdy**~~ltcrcd** 

### condition. The aircraft did not 

### con1tmn to its**~~·'J}C** ·**ce!1ifioc~tc**or

### type design bec;iAu;scthe 'thcration

### performed! w::J.$ .nol .an appmved.C)r-acceptl':!hlc 

### fonn of-alteration. lhemircraft did

### not

### conformto i.E:s 

### typecertificateor1Yfl.Z: 

### desigo because Ml'. Schneiderd.idnot lba:ve

### the lnspect'ionA

### uthoriza1£onr-cqurroli 

### lnreu.u·n 

### lhe**~i~cm:f!t ~.o** 

### scrv.iceafter 

### amajornheratron. 

### Theaircraft 

### dic1 ilOt. 

### conform to 

### its type:

### certifief,ltcortype design**bee:a~** 

### no FAA Fonn .337 w·as executedfor !he maJoraheratJ(iU. Tbe<lirtrafltdjd not

### conform to**i~s** type ccrtiii:e.ate or

### WPC**~fc':li.gn** because nn 

### approved**techn.ka~** data\Vall 

### us-ed in

### p(.'ffomling the 

### ahe:racton. 29. Ea<:ih ofHtc

### ii!OOvc reasons, 

### smnd:ing**alone~** meant

### that

### N3-90TH '"'<.1S unliliirwmthy

### because 

### it did not conform. to its 

### type eC"rtHicntcor

### typedesign:. 

### 30. The aircraft ':v'as 

### unalrwonhy a1lerthe February 24, 2011, 

### alt.cmlionbecause it\'Vas 

### not in acondition 

### for**s~fe**

### ;opernJion. lmproperfuel 

### tankspresenl. numerous hazardsto

### .gn**Jllir.ct~tfi** 

### - most J1ota.b3y,. 

### leaking fuel**c~n** 

### result in h)S:S:ofengine 

### powerand 

### is also a severe 

### fire 

### ha7..ard. As described 

### by Jvfr. Sc11ncidcr

### in his

### deposHlurt, Htc 

### fuel k,ak 

### that (lccurred in June

### 2011 \\'as a 

### dir-ect result ofthe 

### l:;-ebrnnry 24, 20'11 .alterationofahe 

### aircn1ft. 

### ForChc

### r-easons d·esc:rthed 

### above.**\'~icJding**

### can inCJ't)L"hJce- 

### numerous**\Vcaknc~scs** inti!

### an ol.umi:numcomponent, :md**~he.** 

### safdy•Of 

### such aheavlfi)'weldt;:d 

### Jiucl tank '-"'as a[waysquestiolti1hlc. That the weldi.t1g 

### fi:tUed S(l 

### {luiGikly**det~l.Otlstrnces** 

### Httltthe 

### polcntaal 

### weaknesses**had~** 

### in 

### fad; been introduced. 

### His my

### opinion

### that, 

### bectt.usc-ofthe 

### :impropm·**alteratiot::~.** 

### NJ90THwas not

### ina

### coa)dusion forsafe operation after lhe 

### jnstaUacionofrhe.

### a! urntnum 

### fuei trm.ks.

# ( 31. Ihave

### rcvie:\1\.'e.d the, m<rilltetKl1lCC 

### rc.cord:s 

### forN390TH pe:rtaining.to the Fc brt)iiTY 

### 24. 

### :201 t,.

### .allemdon. No !::',A..AF onu 

### 3 3 7 '\'aS

### ,complet·ed for 

### this work. 32. 

## rha·ve

### feviev•ed Mr. 

### Sdtneic.k't'sdescription ofthe**l111aimenarlc~** 

### ·work. perf•)rmed on**UK~** 

### June 

### 2Dll fuel**~eak.** 

### The 

### mainlemmc.>t: performed was

### notccmtaioed

### ln 

### the**Hircr~1ft** 

### maintenance mmmal. 

### Themaintenanceperfonued ·wns 

### not CQndOllned**ii~** 

### any instrm:tio(]s for**con~:irnued** 

### airworthinessfor

### the aircrall,

## 'H,eJrtl'l:intenn.nce performed\Vas 

### nof

### other.:,risc**accep~able** t{tt**~he** 

### /\dm

### inistrntor. 33. The June 20l

## t maintenance on the**fabric:~1<:d** 

### fuel**~<Hlks** 

### ·was not 

### othcn:..,ise acceptahlc:

### to 

### the**Administrn:tG"~r**

### due 

### to •henatutC of111tccomponcillt 

### beingn:pa3red. Th:e fuel tank**wa.~:;** ati 

### unappr()\;ed (NUll.**tM~** 

### shou!d 

### neverluwc

### beeninstalledon the

### a1rcr-aft.

### Thc.·tc w-ere no**methods.~ techniquc..s~** 

### orpractices acceptable to d1e,

### Administr.alorfor**rcpt~iring** 

### 1hc fuel tanks becau.s.>e th-e fuel umks themselves ·were**ui'laccepf~tbie.** 34. Un addition+even

### ifthenature

### ofthe 

### t\lel

### tedlt:s\>tas set**aside~** the. repairv;ould

### noth•wc been pet·forme-<1:**ush~g n~elhods,** **ltXImigm;s~** 

### orprac:tkcs acceptable

### to the**1\(hnintslm~.or.** 

### As Mr. Schneider**itltiki~tcs** 

### in his deposition,

### theWt1rk**c~llld** 

### have beenl1clitC 

### ina less riskx

### manner, but he: chose

### to 

### opt

## fora quick

## flx**u~1** 

## ordc-.rcomeet.a 

### :schedule rather thanthe safe,.

### pmp.crrepair. Tbc fuel tMks 

### shouldhnvc 

### been removed frmnthe airCJ'.tlft**j~)r ~he** 

### rcp21ir 1

### but. were not. Se.alant shrmld 

### h21vc boc:n applied from the: Ln.side, but was**h~stcad** 

### applied from the outside

### ofthe 1n11k

### applying the**secnl.t~m** 

### •o**~he**

### i;n.s'idc

### oftbctank em:ure;s,that the

### pressure, (lf

### !he fm:l in the hmk: 

### serves to p1JSh**~he** 

### sealant 

### into**~my**

### cracks, 

### ratherthanpush 1hc**$/Ca[an~** 

### outMr. 

### Schneider performed 

### only:a J 

### imhed •Asual i**t1spec~!on** t)t11 

### Chc 

### repairduough 

### theboost rmrup 

### accessdoor.• 

### bm the 

### ,inspection should hi:1ve been mm-e e;.xtensi\'e (fiJT**~xamplc~** 

### ihc 

### fue.l system should have:**b~"Cn** 

### pressurized.;:md 

### the hoost flUUlJ')S**sh(H~**

### ld**h(~Vc**

### been a.cti

### vatcd). 

### 3.5. 

### In. <lddition to theunainvorthiness:

### cauSt::d bythe**Fchm~try** 

### 24; 2011. altermion, 

### N390lH \\'U:S tutairwortby 

### when it opm;aled onJune 13.

### 2011,. because ofthc**hnprop~r**

### matmen;)ncc pcrfcmned by 

### Mr. 

### Schneider. Not 

### ooly '"'aS 

### then:p;air 

### fmpro]>erly performed, 

### it v•:c1S tdsn

### a rcprdr**~hat**

### ·\vas not

### ltsted in tbe 

### maint-cmmce m::uwal ::utd was tberefnre H(nt 

### pcrmiClt;.·d 

### under

### the 

### oirc;r"fCstype**C(:rti~icatc.** 

### Further; it\vas

### amajm·

### :repairund :Mr. Schneider

### didnothold the lnspcc1:ionAulhoriz.ation

### requir€!dto r.ehtm 

### thc**~ircrnft**

### to service afterthe**resl~i1·,.** 

### and**t~(l** 

### f'AA F•Ol'tl1 

### 337**W<~S** C::Xt:'Ct!'lc<i. 

### Furth-eramant saye1b**nat~ght**

# ..

### U.S. DEPARTMENT OF TRANSPORTATION OFFICE OFHEARINGS FEDERALAVIATION ADMINISTRATION



### FEDERAL AVIATION ADMINISTRATION, Complainant,
vs. LIBERTY FOUNDATION, Respondent. DocketNo. FAA-2012-0477 FAA Case No. 2011GL030070
Judge Sullivan
AFFIDAVIT OF DONALD DODGE 

### STATE OF GEORGIA COUNTY OF FULTON HAVING COME before the undersigned Notary duly authorized to administeroaths, Donald Victor Dodge, did state under oath afterbeingproperly sworn, that the following statement is true and accurate: 1. I am overthe age of18 and I understand the obligations ofan oath. 2. I am currently employed with the Federal AviationAdministration as a Regional Specialist (Maintenance) at the Southern Regional Office in College Park, Georgia. 3. Ihave 16 years' experience at the Federal Aviation Administration, first serving as an Aviation Safety Inspector (Airworthiness) then later as a Regional Specialist. 4. I have more than 37 years' experience as an aviation mechanic, having held a Mechanic CertificatewithAirframe and PowerplantRatings since 1976, an Inspection Authorization since 1979. Ihave also held apilot certificate since 1972. From 1976 through 1997 I worked at, owned, and operated Dodge Aircraft, a fixed-base operatorperforming general aviation maintenance and alteration services, including regular work on vintage and classic aircraft. 5. I am familiar withthe facts ofthis case, concerningthe work performed onN390TH's fuel system in late 2010 through early 2011, culminating in a February 24,2011,returnto service, and also concerning the June 13,2011, fuel leak in one ofN390TH'snewfuel tanks. The material Ihavereviewed includes the deposition ofthemechanicwho performedthe work in question, photographs ofthe winter 2010-11 work in progress, photographs and video ofthe**~GOVERNMENT** 

## i EXHIBIT 

# i Htl

### June 2011 fuel leak, applicable portions ofthe maintenance records for N390TH, applicable portions ofthe B-170 structural repairhandbook, maintenance and erectionhandbook, and parts list, and certification and registration information for N390TH. 6. I am familiar with the Federal Aviation Regulations and policy documents issued by the Administrator concerning repairs, alterations, major repairs, major alterations, and what sorts of work on aircraft fall into which category. 7. The aircraft involved in this case is a Boeing B-170, serial number 44-85734, registered as civil aircraft N390TH. 8. N390TH was built with fuel tanks consisting ofsix thick, self-sealing bladder fuel tanks, three in each wing. Each bladder fuel tank was installed in an aluminum shell that surroundedthe bladdertanks and was attached to the interior ofthe wing by straps. All attachments between the fuel tanks and the rest ofthe fuel system were fixed directly into the bladder fuel tanks. In order to accommodate the straps and various attachments and fittings, numerous holes were present in the aluminum shells. Additionally, one end ofthe aluminum shells was removable, so it could be taken on or offthe bladder fuel tank. 9. In general terms, the work on the fuel system ofN390THthat culminated in the February 24, 2011, return to service consisted ofremoving the bladder fuel tanks entirely, fabricating a filler neck attach point, a fuel boostpump attachpoint on four ofthe six fuel tanks, a fuel quantity transducermounting point, fuel system line attachments andplatesto seal the former fuel bladder mountingpoints, weldingthose attachments and plates ontothe aluminum shell, welding shut the removable end ofthe shell, and connectingeach ofthe six shells into the existing fuel system as fuel tanks. 10. Although some B-17 aircraft were manufactured with solid metallic tanks, N390TH was not. Further, no B-17 was manufactured with a solid metallic tank consisting ofan aluminum shell withholes that had beenplugged by welding a variety offabricated attachments and plates to the shell, ora manufactured with a removable endthat was then welded closed. 11. This work was an alteration, not a repair, because it changedthe design ofthe aircraft and its components, and was not simply a restoration ofthe aircraftto an undamaged state. 12. The alteration was a major alteration. As stated in section 1.1 ofthe Federal Aviation Regulations (Definitions): Majoralterationmeans an alterationnot listed inthe aircraft, aircraft engine, or propeller specifications- (1) 

### That might appreciably affectweight, balance, structural strength, performance, powerplant operation, flight characteristics, orotherqualities affecting airworthiness; or

### (2) That is not done according to acceptedpractices or cannotbe done by elementary operations. 13. There are several reasons why the alteration was a major alteration. Within four months ofthe alteration, the welding cracked in one ofthe newtanks, resulting in a fuel leak. This was an appreciable effect on a quality affecting the airworthiness ofthe aircraft. Thus, the alteration was a majoralteration. 14. Additionally, even setting aside the fuel leak, the removal ofthe bladder fuel tank could have had an appreciable effect onthe airworthiness ofthe aircraft and its fuel system. The alteration increased the fuel capacity ofthe aircraft, affecting weight and balance and possible stressesplacedonthe wing structure. The new aluminum fuel tanks were susceptible to vibrational stresses in ways that a bladderfuel tank was not. An aluminum fuel tankwould not respond the same way to the stresses ofthe in-flight motion ofthousands ofpounds ofaviation fuel as a semi-rigidbladdertank would- baffles should have beenincorporated into anyhardshell fuel tank design for tanks ofthese sizes. The newly fabricated fixtures and attachments may ormay nothave been ofequal quality with the components they were replacing. The fabricated fixtures and attachments, evenassuming that they were ofequal quality to the parts they were replacing, had changed from being attached to the semi-rigid bladdertank to being attached to the rigid aluminum tank, which could impacthowthey responded to stress during flight. All of these problems are exacerbated because the aluminum tanks were not simply solid, formed aluminumtanks, but had been extensively welded, introducing numerous potential weaknesses into the system
- as canbe seen by the crackingthat developed in one ofthe fuel tanks inless than four months, the weld seams are a source ofstructural weakness and canmake the tank more susceptibleto issues with vibration and stress. Welding can alsoincrease the possibility of corrosion. The weaknesses thatcan be introduced by welding are highlighted by the B-17G Structural Repair Handbook's prohibition on welding aluminum structural members- while the fuel tank is not a structural component, and welding a fuel tank is permissibleunder appropriate circumstances, the same potential weaknesses in the resulting component are still present and mustbe accounted for. 15. Also, any alteration ofa fuel tank is a major alteration. FAA Order 8900.1 provides extensive guidance to Aviation Safety Inspectors inthe performance oftheirduties. Oneofthe possibleduties ofan ASI is field approvals ofmajor alterations. Accordingly, one ofthejobaids in the 8900.1 is a list ofmajor alterations, and whetherthe required approval canbe a field approval, mustbe an engineering approval, orrequires a Supplemental Type Certificate. Onthe list ofmajoralterations is any change in a permanentfuel tank, or installation ofa newfuel tank. 17. Further, the fabrication ofnewfuel tanks out ofthe aluminum shells was a major alterationbecause fabricating components and welding are not an elementary operation. 18. I amaware oftheprovision in Appendix A ofPart43 oftheFederalAviation Regulations thatlists changes in the basic design ofa fuel system as anexample ofa majoralteration. The replacement ofthe bladderfuel tanks with fabricated aluminum fuel tanks was a change in the basic design ofthe fuel system. While_someone could mechanically list dozens ofcomponents that were not replaced in replacing the fuel tanks, this does not meanthat the replacement ofthe

### fuel tanks was not a change in the basic design ofthe fuel system. Fuel tanks, and their ability to perform properly, are absolutely vital to the safe functioning ofa fuel system and aircraft- not the least because a fuel leak can have disastrous consequences for an aircraft. The importance of the fuel tanks to the fuel system can be seen in guidance provided bythe Administratorto FAA inspectors in the 8900.1, where all alterations to fuel tanks are classified as major alterations. 18. Additionally, based on my experience as a mechanic and an FAA employee, it is my opinionthat fabricating a fuel tank out ofan aluminum shell by welding on attachments and metal plates to close openings is not an accepted practice, as thatterm is used in the FAR 1.1 definitions ofmajor alteration and major repair. 19. Each ofthe reasons described above, standing alone, would renderthe alteration amajor alteration. 20. The work performed that culminated in the February 24,2011, return to service was an alteration, not arepair. However, ifit was arepair, it would be a major repair. As stated in section 1.1 oftheFederal Aviation Regulations (Definitions): Majorrepairmeans a repair:. (I) That, ifimproperly done, might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, orother qualities affecting airworthiness; or (2) That is not done according to accepted practices or cannot be done by elementary operations. 21. The distinction between amajorrepair and minor repair largely tracks the distinction between a major and minoralteration. As such, all but one ofthe reasons discussed above as to why the alteration was a major alteration are also reasons why this would be a**m~or**

### repair, ifit had been a repair. · 22. The one exceptionis regardingthe example inAppendix A abouthow a change in the basic design ofthe fuel system is amajor alteration. This example is not applicable to repairs. However, Appendix A also provides that each and every repair ofa fuel tank 

### is a majorrepair. 23. Each ofthe reasons identified above, standing alone, would render the work a major repair, ifit was arepair. 24. The alteration ofN390TH is not described in any maintenance manual orinstructions for continued airworthiness for the B-17G. 25. The methods, techniques, and practices used by Respondent in altering the aircraft are not acceptable to the Administrator. Respondent's alteration introduced numerous potential

- and actual -weaknessesinto the aircraft, and did not include the sort ofinspections necessary to verify that the newfuel tanks were capable ofwithstanding the stresses offlight.

### 26. The alteration ofN390THwas not done in such a way as to restore the condition ofthe aircraft to at least its original orproperly altered condition withrespect to resistance to vibration and deterioration and otherqualities affecting airworthiness. All ofthe factors mentioned in paragraph 14 are pertinenthere. The extensive welding on the newfuel tanks made them vulnerable to the stresses offlight in ways that the original tanks were not, and this resulted in the rapid failure ofone ofthe tanks. 27. N390TH was unairworthy because it did not conform to its type certificate ortype design. The aircraft did not conform to its type certificate ortype design becausethe B-17G's design never contemplatedtaking an aluminum shell with numerous holes in it, fabricating components and welding them onto that shell, and then using it as a fuel tank. N390TH's specification sheet, which is nowthe type certificate for the aircraft, requires that for repairs or modifications not listed in the aircraft's maintenance manuals, the repair ormodification must first be presented to Civil Aeronautics Administration (now the Federal Aviation Administration). 28. The aircraftdid not conform to its type certificate ortype design because it had not been restored to its original orproperly altered condition. The aircraft did not confo_rm to its type certificate ortype design because the alteration performed was not an approved or acceptable form ofalteration. The aircraft did not conform to its type certificate ortype design because Mr. Schneiderdid not have the Inspection Authorization required to return the aircraft to service after a major alteration. The aircraft did not conform to its type certificate ortype design because no FAA Form 337 was executed for the major alteration. The aircraft did not conform to its type certificate ortype design because no approved technical data was used in performingthe alteration. 29. Eachofthe above reasons, standing alone, meant thatN390TH was unairworthy because it did not conformto its type certificate ortypedesign. 30. The aircraftwas unairworthy afterthe February 24, 2011, alteration because it was not in a condition for safe operation. Improper fuel tanks present numerous hazards to an aircraft

- most notably, leaking fuel canresult in loss ofengine powerand is also a severe fire hazard. As described by Mr. Schneider in his deposition, the fuel leak that occurred in June 2011 was a directresult ofthe February 24, 2011 alteration ofthe aircraft. Forthe reasons described above, welding can introduce numerous weaknesses into an aluminum component, and the safetyof such a heavily welded fuel tank 

### was always questionable. That the welding failed so quickly demonstrates that the potential Weaknesses had, in fact, been introduced. It

### is my opinionthat, because ofthe improper alteration, N390TH was not in a condition for safe operation afterthe installation ofthe aluminumfuel tanks. 31. Ihavereviewed the maintenance records forN390TH pertaining to the February 24, 2011, alteration. No FAAForm 337 was completed for this work. 32. Ihave reviewed Mr. 

### Schneider's description ofthe maintenance work performed onthe June 2011 fuel leak. The maintenanceperformed was not contained inthe aircraft maintenance

### manual. The maintenanceperformed was not contained in any instructions for continued airworthiness for the aircraft. The maintenanceperformed was not otherwise acceptable to the Administrator. 33. The June 2011 maintenance on the fabricated fuel tanks was not otherwise acceptable to the Administratordue to the nature ofthe component being repaired. The fuel tank was an unapproved part that should never have been installed on the aircraft. There were no methods, techniques, orpractices acceptable to the Administrator for repairingthe fuel tanks because the fuel tanks themselves were unacceptable. 34. In addition, even ifthe nature ofthefuel tanks was set aside, the repair would not have been performed using methods, techniques, orpractices acceptableto the Administrator. As Mr. Schneider indicates in his deposition, the work could have been done in a less risky manner, but he chose to opt for a quick fix in orderto meet a schedule ratherthan the safe, properrepair. The fuel tanks shouldhave beenremoved from the aircraft for the repair, but were not. Sealant should have been applied from the inside, but was instead applied from the outside ofthe tankapplying the sealantto the inside ofthe tank ensures that the pressure ofthe fuel in the tank serves to push the sealant into any cracks, rather than push the sealant out. Mr. Schneider performed only a limited visual inspection on the repairthrough the boost pump access door, but the inspection should have been more extensive (forexample, the fuel system shouldhave been pressurized and the boost pumps shouldhave been activated). 35. In additionto the unairworthiness causedby the February 24, 2011, alteration, N390TH was unairworthy when it operated onJune 13, 2011, because ofthe impropermaintenance performed by Mr. Schneider. Not only was the repairimproperly performed, it was also a repair that was not listed in the maintenance manual and was therefore notpermitted underthe aircraft's type certificate. Further, it was a majorrepair and Mr. Schneiderdid not hold the Inspection Authorizationrequired to returnthe aircraft to service afterthe repair, and no FAA Form 337 was executed. Further affiant sayeth naught. I hereby swearoraffirm that the above is accurate and true to the best ofmyknowledge.

MyCommission Expires: