U.S. DEPARTMENT OF TRANSPORTATION 

OFFICEOFHEARINGS REcE···tvEo 

FEDERAL AVIATION ADMINISTRATION · . . 

AUG 1 4 2013 

HEARING DOCKET 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

vs. 

LIBERTY FOUNDATION, 

Respondent. 

Docket No. F AA-20 12-04 77 

FAA Case No. 2011GL03007Q?. ~.~ .. ,., 

Judge Sullivan 

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MOTION FOR SUMMARY 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 summary judgment in this matter. No genuine 

issue of material fact exists to be determined, and the Administrator is entitled to judgment as a 

matter of law. As grounds for the motion, the Administrator states the following. 

STATEMENT OF 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 of the aluminum shells that had been protecting the bladder fuel tanks, and returned the 

aircraft to service; (2) that this constituted a major alteration; (3) that none of the appropriate 

approval were obtained for a major alteration; (4) that the alteration left N390TH unairworthy (5) 

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Respondent operated N390TH after these actions; (6) in June 2011, one of the 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 of the aircraft. Respondent does 

not dispute the underlying facts of this case, but does dispute the regulatory consequences of 

these actions - whether the replacement of the fuel tanks constituted a major alteration, whether it 

rendered the aircraft unairworthy, whether the repair in June 2011 was proper, and whether 

Respondent is responsible for the various violations that took place. 

STATEMENT OF 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 of the 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 of the summer 

tour season in 20 I 0, Respol}dent chose to winter N390TH is the vicinity of Atlanta, Georgia, so 

that new Director of Maintenance, 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. 

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At the time of its manufacture, at the time of its 2004 restoration, and also at the time 

immediately prior to the winter of 2010-11, 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 of thick, 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 of the wing via a number of straps, and other components of the 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 of the 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 of the straps and lines. Attachment B ~ 15; Attachment Cat 15-16; 

Attachment GG ~ 8; Attachment HH ~ 8; Attachment C at 9-1 0; Attachments D, E, F 

(photographs of an aluminum shell prior to alteration) 1

• One end of each shell was removable, so 

that the shell and the bladder fuel tank could be handled separately. Attachment B ~ 15, 

Attachment Cat 26; 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 

1 Although the photographs have an electronic date-stamp for the year 2005, they were actually taken during the 

course of the work performed during the winter of 2010-11. See Attachment C at 27. 

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Director/Chief Pilot, Ray Fowler, and one of Respondent's pilot's, Cullen Underwood, executed 

this plan. See Attachment 8 ~~ 9, 11; Attachment C at 11; Attachment Rat 6, 12-17. 

Attachments were fabricated to replace the links between the bladder fuel tank and the 

rest of the 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 of the aircraft had once run through the shells. Attachments H, J, K, L, M, P; 

see also Attachments N, 0. Finally, the removable end of each of the 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 Erection Manual, 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 

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~ 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 operated the aircraft repeatedly between that date and June 11, 2011. 

On or before June 11, 2011, the welding failed on one of the 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 Cat 45, 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 of this 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 of thing."); see Attachment T at 193-214; Attachment 

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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 of violation, 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 of the 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 of this 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 of an Inspection 

Authorization, despite the lack of a Form 337, despite the lack of approved technical data, and 

despite the lack of a maintenance log entry describing the work performed. An alteration is a 

major alteration if it "might appreciably affect weight, balance, structural strength, performance, 

powerplant operation, flight characteristics, or other qualities affecting airworthiness." 14 C.F.R. 

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1.1 (emphasis added). Here, we know that the airworthiness of the 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 of the 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 of fuel tanks out of the 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 a previous 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 of the 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 

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flight stress differently than the original configuration, included newly-fabricated components, 

and involved heavy welding of questionable quality. Further, as the Administrator has previously 

determined, any alteration of a fuel tank is a major alteration. 

As discussed in Part V, the "major" nature of the alteration had immediate regulatory 

consequences. Respondent's Director of Maintenance 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 when the 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) ofthe Federal 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. 

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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 of the aircraft is amply 

demonstrated by the brisk failure of the 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 order to 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 a result, Respondent violated§§ 43.I3(a), (b). 

As discussed in Part XI, the June 20II repair was a major repair. Any repair to a fuel tank 

is a major repair. As with the February 20I1 alteration, the "major" status of the repair results in 

numerous regulatory requirements applying, none of which 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 of the June I3, 20 II, 

flight. In addition to the unairworthiness caused by the February 2011 alteration, the June 2011 

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repair introduced new problems- 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 on the representations of an 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 if such a representation was made. 

ARGUMENT 

"A party may make a motion for decision, regarding all or any part of the proceedings, at 

any time before the administrative law judge 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 law judge has 

officially noticed, or evidence introduced during the hearing show that there is no genuine issue 

of material fact and that the party making the motion is entitled to a decision as a matter of law. 

The party making the motion for decision has the burden of showing that there is no genuine 

issue of material fact disputed by the parties." 14 C.F.R. § 13.218(£)(5). 

I. Respondent Is Responsible For the Actions oflts Director of Maintenance 

The regulations at issue in this case fall into two categories. The first category IS 

regulations that apply to a person performing 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 

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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 not recorded) 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 of Agency for guidance in application of vicarious liability). 

It would appear obvious on the face of things that when an aircraft operator designates an 

individual as the entity's Director of Maintenance 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 of Maintenance, 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 of its violations of the 

operational regulations, but that is a distinct matter addressed in Part XIV below. 

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Maintenance, Schneider was in charge of all work during the winter of 201 0-211, 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 

of Maintenance included signing off work on the 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 Chief Pilot, Ray Fowler, was personally involved in the decision-making 

r process. See Attachment B ~~ 8, 11; Attachment C at 18. The Director of Maintenance 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 of the 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, 16-1 7. 

Respondent's Director of Maintenance was not an independent force who was making 

decisions outside of the control of Respondent, 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 on N390TH. This is true for both the February 

2011 alteration of the aircraft, and the June 2011 repair of the fuel leak. Further, with regards to 

the February 2011 alteration, much of the 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 

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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 of Suspension 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, 

20 11, maintenance log entry for this alteration in an incomplete and misleading way such that the 

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 

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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 of the 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 of signoffs) for that work. The FAA is entitled to judgment as a matter of law, and summary 

judgment is 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 of what work was performed on N390TH over 

the winter of 2010-11, culminating in the February 24, 2011, maintenance record entry and 

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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 of the wing), that the removable end of the 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, but the 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 of an aircraft. C.A.R. §§ 18.3, 18.4. 

The work performed here was manifestly an alteration. Attachment B ~ I8; Attachment 

GG ~ II; Attachment HH ~ 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, but had a completely different kind of fuel 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; Attachment HH ~ I1. 

3 Respondent may disagree with the particular wording 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 of holding fuel, fabricated attachments, welded various 

things onto the aluminum shells, and then installed them as fuel tanks on the aircraft. 

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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 of law. It is clear that the work performed was not a mere restoration of the 

aircraft to its prior form, but a change in the design of the aircraft - therefore, the work was an 

alteration, not a repair. The Administrator is entitled to judgment as a matter of law on this point. 

III. The February 24, 20I I, Maintenance Record Entry Did Not Describe The Work 

Performed 

The February 24, 20 I I, maintenance record entry made concerning the actions taken on 

the fuel tanks in the winter of 20 I 0-I I did not describe the work actually performed. 

Section 43.9(a) of the 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 of that equipment containing a description of the 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, of this 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 of that aluminum shell, and 

then installing the welded-aluminum shell as fuel tanks. Attachment C at I 7, 26; Attachments G, 

H, I, J, K, L, M, 0, P. 

The maintenance record entry made by Mr. Schneider, on the other hand, stated: 

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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-1 7 

Maintenance and Erection Manual, pages 196-199. 

Attachment Qat 4 (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 of individual 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 of the 

major alteration performed on N390TH. 

As a result, § 43.9(a) was violated when Respondent's Director of Maintenance 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 of fact on this matter - the nature of the 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 summary judgment, and the Administrator is entitled to judgment as a matter of law on 

this point. 

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IV. The February 24,2011, Alteration Was A Major Alteration, Not A Minor Alteration 

The February 24, 2011, alteration was·~ majo~ alteration, not a minor alteration. An 

alteration is a minor alteration if it is not capable of affecting any characteristic of the 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 of the aircraft, it did 

affect the airworthiness of the aircraft. It was, additionally, not performed according to accepted 

practices or with only elementary operations. Accordingly, it was a major alteration. 

The Definitions section ofthe Federal Aviation Regulations provides that: 

Major alteration means an alteration not listed in the aircraft, aircraft engine, or 

. propeller specifications-· 

( 1) That 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 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 of this definition, the bar to jump from a minor alteration to a 

major alteration is a very low one. Indeed, the vast majority of alterations 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 of the aircraft - in order to be a 

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mmor alteration an alteration must be incapable of affecting any quality that affects the 

airworthiness of the aircraft. 

There are three ways in which an alteration can be a major alteration - ( 1) the alteration 

might affect a quality of the 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 of the aircraft. 

The first is that the alteration did affect the airworthiness of the aircraft. In June 20 II, 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 of an 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 of the aircraft, even though the alteration did 

affect a quality affecting the airworthiness of the aircraft. There can be no genuine dispute of fact 

on this subject, and the application of the legal definition of a "major alteration" is clear. 

A second reason why the alteration was a major alteration is that the Administrator has 

already determined that any alteration consisting of new 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 

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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 of reasons - 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 new welded-aluminum fuel tanks had a higher fuel capacity than 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 of the 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 of the major alterations job aid in effect at 

the time of the February 20 II alteration. The only material change to the job aid since that time has been an increase 

in the level of scrutiny given to fuel tank alterations, with field approvals no longer being permitted. 

19 
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The newly-fabricated attachments and fittings were, instead of being 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 on the 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 of corrosion; 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 of the 

fuel tanks. Indeed, as discussed above, the welding did, in fact, cause one of the 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 of the above-listed items are ways in which the 

alteration might have affected qualities affecting the airworthiness of the aircraft - in order for 

20 

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the FAA's claim to fail, a finding would have to be entered that it was not possible for any of the 

above considerations to affect any quality affecting the airworthiness of the aircraft. 

In addition to affecting qualities affecting the airworthiness of the aircraft, the alteration 

ofN390TH was a major alteration because it was not done in accordance with accepted practices 

or done with elementary operations. Fabricating a fuel tank out of an 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 of new fuel tanks out of the 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; Attachment HH ~ 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 of a new fuel system component, is a major alteration. 

There are more than half a dozen ways in which the installation of the new welded-aluminum 

tanks could affect qualities affecting the airworthiness of the 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 of the aircraft, even though it did 

have an effect. Additionally, the alteration was not done in accordance with accepted practices, 

and was not done with elementary operations. There is no dispute as to the facts of the work that 

was done on N390TH, and as a matter of law that alteration was a major alteration. The FAA is 

entitled to judgment as a matter of law on this point. 

21 
V. Immediate Regulatory Consequences Of Being A Major Alteration 

Having established that the alteration completed in February 2011 was a major alteration, 

it may be helpful to examine what the immediate regulatory consequences of this distinction are. 

There are two prominent ones. First, because the alteration was a major alteration, Schneider had 

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 FAA before operating the 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 - except for 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 of the Federal 

Aviation Regulations provides, in pertinent part, that no person may return an aircraft or 

component thereof to service except for the Administrator, or a person 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 a person authorized under§ 43.7 of this chapter." 14 C.F.R. § 91.407(a)(l). 

At no time material herein did Respondent's Director of Maintenance, 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 of Maintenance 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 had been no authorized return to service. 

Additionally, because the alteration was a major alteration, section 43.9(d) requires that 

"major repairs 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 of Form 337). No FAA Form 337 was ever completed for the February 

24, 20 II, alteration. As a result, Respondent, through its Director of Maintenance, violated 

§ 43.9(d). 

Respondent, through its Director of Maintenance, 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 Administrator has been executed in the manner prescribed by the Administrator. 

I4 C.F.R. § 43.5(b). N390TH was returned to service on February 24, 20II, without the formFAA Form 337- having been executed. 

VI. The Alteration Was Not Properly Performed 

The alteration of N390TH 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]ach person maintaining or altering, or performing preventive maintenance, shall do 

that work in such a manner and use materials of such a quality, that the condition of the 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 the requirements of Part 43 

because they are performed in accordance with a maintenance manual system published by the 

manufacturer of the 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 

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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 of this litigation, Respondent has been 

unable to identify a legitimate reason to believe that its alteration ofN390TH was performed in a 

manner acceptable to the Administrator. 

On a basic level, the FAA's burden of persuasion on this point is minimal- if the FAA, 

as the enforcement agency for this regulation, under powers delegated by the Administrator, says 

that the methods, techniques, and practices are not acceptable, then this, if unrebutted, is in and 

of itself sufficient to establish that the methods, techniques, or practices 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 43.13-1 B, but that AC says nothing about this sort of alteration. 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. Numerous potential problems with 

the new tanks are outlined in Part IV, above. In addition to the existence of all of these 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 
• 

of the 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 of an 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 of the 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 this judgment motion, but 

no "expert" opinion on this position can survive the simple, undisputed fact that one of the 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 on this point, and the 

FAA is entitled to judgment as a matter of law. Accordingly, summary judgment is appropriate. 

26 

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VII. N390TH Was Not In An Airworthy Condition After the February 2011 Alteration 

Because It Did Not Meet Its Type Certificate or Type 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 or type design, or when it is not in a condition for safe operation. !d. 

The concept of an 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, or when the 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 brief and lack details due to the age of the design and due to the nature of the 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 of compliance with the type 

certificate because the type certificate expressly states that for any repair or alteration of the 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 of original bladder fuel 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 of these 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) if the 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 of explanation 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 of which failed after less than four months, were the equals of the 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 of fact at all. The FAA is 

entitled to judgment as a matter of law as to the conclusion that N390TH was unairworthy after 

the February 2011 alteration, and summary judgment is appropriate. 

VIII. N390TH Was Not In An Airworthy Condition Because It Was Unsafe For Flight 

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, Order 20 I 0-9. 

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 
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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 of the -. ·- - . 

aircraft. 

Based on disclosures during discovery, it is possible that Respondent will submit an 

expert report asserting that the welding was of high 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 summary judgment. The Administrator is entitled to judgment as a matter 

of law, and summary judgment should be granted on this point. 

IX. The Violations Described Above All Occurred Even If The 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 this potential dispute. 

Mr. Norville's opinion is in error- as discussed above in Part II, the work performed on 

N390TH over the winter of2010-11 was an alteration. Mr. Norville further asserts that, not only 

6 Respondent originally identified additional expert witnesses, but has since withdrawn them. 7 It is unclear to what extent, if any, Mr. Norville is actually an expert on the issues in this case. According to his 

deposition testimony, his opinions, as presented in his report, were formed with no knowledge whatsoever of what 

work had actually been done on N390TH, but rather based exclusively on an assessment of the 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. If the work was a repair, it was a major repair, 

and all of the legal consequences described above still flow from Respondent's actions. 

According to the Definitions section of the Federal Aviation Regulations: 

Major repair means a repair: 

(1) That, if improperly 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 or cannot be 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 following parts of an 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 of these regulations is that it flatly contradicts Mr. Norville's 

opinion that the work, if it 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 of major repair almost exactly tracks the definition of major 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 

of the 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 of the 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 not restore the aircraft to its original or properly altered condition. 

The bulk of the discussion on this matter is repetitive of Part 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 

20 II alteration, Respondent has declined to identify any basis for the assertion that the June 

20II repair was performed in manner acceptable to the Administrator, or that 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 of any 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 or properly 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 of time 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 Cat 48-49; Attachment GG ~ 34; Attachment HH ~ 34. Removing the fuel tank from 

the aircraft would have permitted the sealant to be applied to the inside of the 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 of material 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 of the 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 of the 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 of material fact on this point, and the FAA is entitled to 

judgment as a matter of law. Accordingly, summary judgment is appropriate. 

XI. The June 2011 Maintenance Was A Major Repair, But No 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 

matter of law. Summary judgment on these 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. Schneider has 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 § 4 3. 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, of this 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 Cat 45. As a result, Respondent violated§ 43.5(a) and§ 91.407(a)(2). 

There are no disputes of material fact on these issues, and the Administrator is entitled to 

judgment as a matter of law. Accordingly, summary judgment is appropriate on these points. 

35 
• 

XIII. N390TH Was Unairworthy At The Time OfThe June 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, 

N3 90TH was unairworthy as a result of the 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 or type 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 when it 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 of material fact for purposes of defeating 

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 of law on these points, and summary judgment is appropriate. 

36 

I 

I 

~ 

r 
XIV. Respondent's First Affirmative Defense Fails 

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 of the reasons discussed in Part I above 

-Mr. Schneider was not some outside mechanic, he was Respondent's Director of Maintenance. 

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 of the 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 itself from regulatory liability for its unsafe conduct. The FAA is 

entitled to judgment as a matter of law, and summary judgment is appropriate. 

XV. Respondent's Second Affirmative Defense Fails 

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 how to 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 of David Alderman)~ 3; Attachment B ~ 12. This will, presumably, be 

a factual dispute. 

It is not, however, a material dispute of fact 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 of this 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 of Data, Major Alterations, and 

Repairs") at § 302(b) ("If your 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 on the information provided in your request."). 

Even taking all the facts in favor of the Respondent, Respondent's affirmative defense 

fails because even if two FAA inspectors orally opined to Respondent that the February 20 II 

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 

judgment is 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 of this 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 20 II fuel leak. Instead, Respondent primarily disputes the legal 

consequences of these events- was the February 20II alteration an alteration or a repair, was it a 

39 
minor alteration 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 of fact, but none that are material- none that preclude finding of violation as laid out in 

the Complaint. 

WHEREFORE, Complainant respectfu11y request~ that the Judge grant Summary Judgment and 

affirm the Amended Complaint in its entirety. 

{.,(~~ Respectfully submitted this __ day of August, 2013. 

CHRISTOPHER R. STEVENSON 

Attorney 

Office of the Regional Counsel 

40 
CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Motion for Summary Judgment was sent: 

Original and one copy via Federal Express to: 

Federal Aviation Administration 

800 Independence A venue, S. W. 

Washington, D.C. 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

One copy via Federal Expres to: 

The Honorable I.E. Sullivan 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200NewJersey Avenue, 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 of the Regional Counsel 

AUG 1 4 2013 

Dated 

41 
........ r '!!· 

c...- .·, '- UNllED Of AMERlCA 

. .•> 

DEPARTMENT OF TRANSPORTATION- FEDERAL AVIATION ADMINISTRA

SPECIAL AIRWORTHINESS CERTIFICATE 

A CATEGORY /DESIGNATION LIMITED 

. PURPOSE DNA 

8 MANU- NAME 'BOEING (VEGA) FACTURER ADDRESS DNA 

c FROM DNA FLIGHT TO DNA 

0 N- 390TH SERIAL NO. 44-8

I BOEING (VEGA) B-

I BUILDER MODEL 

DATE OF ISSUANCE 03 MAX 2005 EXPIRY DNA 

OPERATING LlMITAJ)(SNS A PART OF TH

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SIGNATURE OF FAA "j_,/ ;'15::7::. DESIGNATION OR 

K . S0-29 

I 

.alteration, reproducti_on or misuse of this certificate may be punishable by a fine not 

1mpnsonment not exceedtng 3 years. or both. THlS CERTIFICATE MUST BE DISPLAYED I

ACCORDANCE WITH APPLICABLE FEDERAL AVIATION REGULATIONS. 

'I'I:A A .::nRM 8130-7 (10/82) 

CMDB.S,IG0-7U03tt 

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i 
U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINJSTRA TION 

FEDERAL A VIA Tl ON 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 over the age of 18 and I understand the obligations of an oath. 

2. I am currently employed as an aviation mechanic at Bode Aviation in Albuquerque, New 

Mexico. Prior to working at Bode Aviation I served as a police officer for 2 5 years. 

3. I hold a Mechanic Certificate with Airframe and Powerplant Ratings, and have done so 

since 2006. I have held an Inspection Authorization since 2009. I also hold a Commercial Pilot 

Certificate with an Instrument Rating. I have held a pilot certificate since 1982. 

4. The aircraft involved in this case is a Boeing B-170, serial number 44-85734, registered 

as civil aircraft N390TH. 

5. I first became involved with N390TH in the spring of2007, serving as a mechanic. 

Shm1ly thereafter, the Director of Maintenance 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 I provided a copy of them for TLF. 

I GOVERNMENT 

; EXBBIT 

i· _· .... -·• ,. __ .....,. 
6. In the summer of2007, TLF designated me as its Director of Maintenance. As the 

Director of Maintenance, I oversaw the maintenance for N390TH, including ensuring that all 

inspections were timely performed and that all Airworthiness Directives were complied with. As 

Director of Maintenance I worked with Scott Maher, 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 of Maintenance, I had authority within TLF to 

manage the maintenance of the aircraft, except for work that would require major expenses, 

which had to be authorized by Scott Maher or Ray Fowler, TLF's Chief Pilot. 

7. In total, I performed 45 phase inspections on N390TH, where each cycle of 4 phase 

inspections constituted a full inspection of the 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 in Albuquerque in 2007-08 and the first half of the 

winter of 2009-10, 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 determined that the existing bladder fuel tanks on N390TH should be 

replaced (I am unsure of when the tanks were made, but it is my belief that the bladder fuel tanks 

in N390TH were OEM fuel tanks from the 1940s or 1950s). Replacement with new bladder fuel 

tanks had been discussed, and it was detennined that the cost of around $50,000 for new bladder 

tanks. Replacing the bladder tanks with custom-fabricated solid metal fuel tanks with dedicated 

engineering specifications was also discussed between me, Ray Fowler, and Don Brooks (the 

founder of TLF). Ray stated that he wanted to winter the aircraft in Georgia in order to reduce 

costs, and he and Scott Maher ultimately decided to winter the aircraft in Georgia. Because I felt 

that I would not be able to properly supervise the maintenance being perfom1ed in Georgia, I 

resigned as Director of Maintenance. 

9. I had minimal contact about N390TH during the winter of 20 I 0-11, but was contacted by 

Scott Maher and Ray Fowler in early March 2011. They indicated that the aircraft was in 

Houston, and asked me to perform a phase inspection on one of the wings. Before I agreed to 

perform the inspection, I contacted Rod Schneider, who had succeeded me as Director of 

Maintenance, to ask about the maintenance performed on N390TH that winter. Schneider 

informed me that, among other things, they had ultimately decided to replace the bladder fuel 

tanks by modifying the existing aluminum bladder holders. I asked Schneider ifhe could provide 

me with a copy of the engineering documents and FAA Form 337 for the alteration. Schneider's 

response was vague, but he indicated that Cullen Underwood and one of his employees (Paul 

White) were working on the paperwork. 

I 0. After this conversation with Rod Schneider, I called FAA Aviation Safety Inspector 

David Miller of the Nashville FSDO, who I knew had 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, I received a call from Ray Fowler, who indicated that he 

knew I had been asking about the tanks, and that he wanted to bring me up to date. Fowler 
indicated that TLF had modified the bladder holders to serve as fuel tanks by welding them up. 

Fowler indicated that TLF had hired a DER to engineer new tanks, but that this process had been 

abandoned as too expensive. Fowler opined that what TLF had done was only a minor alteration 

because some B-17s had been manufactured with solid aluminum tanks. This made me very 

uncomfortable, because the extensive welding meant that this was not at all like what any B-17 

had been manufactured with - even if the bladder holder had actually been 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 bladder holders seemed too thin to serve as fuel tanks and also 

because TLF had not installed baffles in such large metallic fuel tanks. Fowler told me that he 

had just consulted with David Miller, and that Miller had 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 that this 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 left me very uncomfortable. In particular, it was clear that TLF 

had failed to follow proper approval policies, especially because the aircraft had already been 

operated at the time these conversations were taking place. I declined to perform any further 

maintenance work for TLF. 

14. I spoke with Scott Maher the 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. I presumed that TLF would later complete a 337. However, I later learned that TLF 

had not obtained an engineering approval or completed 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 of the wing by a 

number of straps. Each bladder fuel tank was also supported by an aluminum shell around the 

fuel tank. All attachments between the fuel tank and the rest of the fuel system were fixed 

directly into the bladder fuel tank. In order to accommodate the straps and various attachments 

and fittings, numerous holes were present in the aluminum shell. Additionally, one end ofthe 

aluminum shell was removable, so it could be taken on or off the bladder fuel tank. 

16. I have been informed that, in general terms, the work on the fuel system of N390TH that 

culminated in the return to service date February 24, 20 II, consisted of removing the bladder 

fuel tanks entirely, fabricating new attachments and plates, welding those attachments and plates 

onto the aluminum shell, welding shut the removable end of the 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 of an aluminwn shell 

with holes that had been plugged by welding a variety of fabricated attachments and plates to the 

shell, or a 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 of the aircraft to an undamaged state. 
19. The alteration was a major alteration. As stated in section 1.1 of the Federal Aviation 

Regulations (Definitions): 

Major alteration means an alteration not listed in the aircraft, aircraft engine, or 

propeller specifications-

(I) That 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 or cannot be done by 

elementary operations. 

20. There are several reasons why the alteration was a major alteration. Within four months 

of the alteration, the welding cracked in one of the new tanks, resulting in a fuel leak. This was 

an appreciable effect on a quality affecting the airworthiness of the aircraft. Thus, the alteration 

was a major alteration. 

21. Additionally, even setting aside the fuel leak, the removal of the bladder fuel tank could 

have had an appreciable effect on the airworthiness of the aircraft and its fuel system. The 

alteration increased the fuel capacity of the aircraft, affecting weight and balance and possible 

stresses placed on the wing structure. The new aluminum 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 way to the stresses of the in-flight motion of thousands of pounds of aviation 

fuel as a semi-rigid bladder tank would. The newly fabricated fixtures and attachments may or 

may not have been of equal quality with the components they were replacing. The fabricated 

fixtures and attachments, even assuming that they were of equal quality to the parts they were 

replacing, had changed from being attached to the semi-rigid bladder tank to being attached to 

the rigid aluminum tank, which could impact how they responded to stress during flight. All of 

these problems are exacerbated because the aluminum tanks were not simply solid, formed 

aluminum tanks, but had been extensively welded, introducing numerous potential weaknesses 

into the system- as can be seen by the cracking that developed in one of the fuel tanks in less 

than four months, the weld seams are a source of structural weakness and can make the tank 

more susceptible to issues with vibration and stress. The weaknesses that can be introduced by 

welding are highlighted by the B-170 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 permissible under appropriate circumstances, the same potential weaknesses in the 

resulting component are present and must be accounted for. All of these potential issues were 

ways in which the alteration might have affected qualities affecting the airworthiness of the 

aircraft, and required a proper engineering or other authorization. 

22. Further, the fabrication of new fuel tanks out of the ahm1inum shells was a major 

alteration because fabricating components and welding of this nature are not an elementary 

operation. 
23. I am aware of the provision in Appendix A of Part 43 of the Federal Aviation Regulations 

that lists changes in the basic design of a fuel system as an example of a major alteration. The 

replacement of the bladder fuel tanks with fabricated aluminwn fuel tanks was a change in the 

basic design of the fuel system. While someone could mechanically list dozens of components 

that were not replaced in replacing the fuel tanks, this does not mean that the replacement of the 

fuel tanks was not a change in the basic design of the fuel system. Fuel tanks, and their ability to 

perform properly, are absolutely vital to the safe functioning of a fuel system and aircraft- not 

the least because a fuel leak can have disastrous consequences. The change in the fuel capacity 

of the tanks also makes it a change in the basic design, and could affect the fuel pickups at 

different attitudes of flight. 

24. Each ofthe reasons 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 a repair. However, if it was a repair, it would be a major repair. As stated in 

section 1.1 ofthe Federal Aviation Regulations (Definitions): 

Major repair means a repair: 

(I) That, if improperly 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 or cannot be done by 

elementary operations. 

26. The distinction between a major repair and minor repair largely tracks the distinction 

between a major and minor alteration. As such, all but one of the reasons discussed above as to 

why the alteration was a major alteration are also reasons why this would be a major repair, if it 

had been a repair. 

27. The one exception is regarding the example in Appendix A about how a change in the 

basic design of the fuel system is a major alteration. This example is not applicable to repairs. 

However, Appendix A also provides that every repair of a fuel tank is a major repair. 

28. Each of the reasons identified above, standing alone, would render the work a major 

repair, if it was a repair. 

29. The alteration ofN390TH is not described in any maintenance manual or instructions for 

continued airworthiness for the B-1 7G. 

30. N390TH did not meet its type certificate or design and was unairworthy after the 

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 after the 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 of the shells, was too much 

for the shells to serve as appropriate fuel tanks. 

32. I am familiar with the repairs done on N390TH's fuel tanks from speaking with Chuck 

Geese, a mechanic who had seen the repair. The maintenance performed was not contained in the 

aircraft's maintenance manuals. The maintenance performed was not contained in any 

instructions for continued airworthiness for the aircraft. 

33. The June 201 1 maintenance on the fabricated fuel tanks was not appropriate because the 

fuel tank was an unapproved part that should never have been installed on the aircraft. 

34. The June 201 1 repair was a major repair. In addition to the reasons stated above 

concerning the February 201 1 alteration, N390TH did not meet its type certificate or type design 

and was unairworthy after the June 2011 repair because TLF had failed to execute an FAA Form 

337 r the repair. 

Sworn and subscribed before me this q-hA day of August, 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 7 
Rodney 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. 

PageS 
Rodney 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? 

A. It looks right side up as shown. 

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

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Rodney Schneider In Re: Liberty Foundation April30, 2013 

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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? 

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Rodney Schneider In Re: Liberty Foundation April 30, 20I3 

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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? 

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Rodney Schneider In Re: Liberty Foundation April30, 2013 

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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 

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Rodney Schneider In Re: Liberty Foundation Apri130, 2013 

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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 

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Rodney Schneider In Re: Liberty Foundation April30, 2013 

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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 

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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? 

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Rodney Schneider In Re: Liberty Foundation April 30, 2013 

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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. 

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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? 

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Rodney Schneider In Re: Liberty Foundation April30, 2013 

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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? 

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Rodney 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 

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Rodney Schneider In Re: Liberty Foundation April 30, 2013 

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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 

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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 

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Page36 
Rodney 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. 

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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 

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Rodney 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 

actions did you take to address this situation? 

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. 

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Page 42 
Rodney 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? 

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Rodney Schneider In Re: Liberty Foundation April 30, 2013 

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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. 

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Rodney Schneider In Re: Liberty Foundation April30, 2013 

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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? 

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Rodney Schneider In Re: Liberty Foundation April 30, 2013 

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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? 

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Rodney Schneider In Re: Liberty Foundation April 30, 2013 

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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. 

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Rodney Schneider In Re: Liberty Foundation April 30, 2013 

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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 wan ted 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? 

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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 
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Aircraft Record General Information 

Manufacturer :P-o~ I U (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 SIN 4485734 

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 cover paneL 

Replaced #4 upper outboard cowl segment with a serviceable part. 

Replaced all 4 fuel shutoff valves with original type solenoid valves. 

Remove #4 engine SIN SW-042700 and installed engine SIN 010995, 0 

hours SMOH. See engine log for details. 

I certifY that this airframe was inspected in accordance with a ·'O" check 

inspection as per FAA Approved Inspection Program and was found to 

be in airworthy condition. Next inspection is due at 1503.7 hours 

AP 

Rodney 

2649010 

SchneiderL ~ 

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 Hobbs Time: 1478.7 ACTT:2474.7 

N390lli Boeing B-17G S/N4485734 

Removed all srx fuel tanks. Removed bladder lrners from the tanks and ----

repaired the aluminum tanks by welding. Ref: AC 43-13 section 8-32. 

Fuel tanks are made of aluminum sheet, II 00 ~ 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-1 7 

Maintenance and Erection manual, pages 196-199 

AP 

Rodney 

2649010 

Schneider ."h., Q ~ 

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 right main gear lower limit switch per the field 

maintenance manual and performed a gear swing for proper operation. IA W B-17G Field 

Service manual page 206- 215 

Installed landing gear motor 

PIN 1073-1-B 

SIN 7305 

David Alderman 

A &P 3100592 

I FG~:::. OFf'ICIAL USE ONLY EXHIBIT -----
YEAII: RECORDING 

TACH 

TIME 

DATE 

TODAYS TOTAL Description of Inspections, Tests, Repairs and Alterations 

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 Hobbs Time: 1505.9 ACTT: 2501.9 

N390TH Boeing B-17G SIN 4485734 

Performed "'A" Check Inspection on this airframe. Lubed RIH MLG 

screw jack. Replaced broken comm antenna. Replaced #3 Main Tank 

fuel boost pump. Inspected # 1 and #3 oil cooler shutter linkage for ----

possible binding. Adjusted oil pressure relief on #1 and #3 engine one · __ 

turn increase. 

I certify that this airframe was inspected in accordance with an .. A" 

check inspection per the FAA approved inspection program and was 

found to be in airworthy condition. Next inspection is due at 1530.9 

hours. 

Rodney 

AP 2649010 

Schneider ~ 0 ~ 

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 FAA approved inspection program and was found to be in airworthy 

---4-- condition. Next inspection is due at 1558.6 hours. 

---+--

AP2649010 

Rodney Schneider X U ~ -

ons 

of 

es.) 

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

-----1- May 14. 2011 Hobbs Time: 1556.7 ACTT: 2552.7 

N390TH Boeing B-17G SIN 44-85734 

-----1-

------J'-- Performed a '"C' check inspection on this airframe. 

------J- I certify that this airframe was inspected in accordance with a --c· check inspection 

per the FAA approved 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. 

--- 1 certii}' 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. 

--

___ 

AP26490 

Rodney Schneider 

I 0 

7~ 

June 13,2011 

rations 

nber of 

entries.) 

Repaired a fuel leak at the bottom, inboard end of#] main tank with sealer PR-2001 ___ _ 

--Class B- 112, reference 43.13-1-B. Section 2, Paragraph 8-32. Fueled tank with 250 

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

--Rodne)' Schneider -;:/ ---4L-----

AP 2649010 

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 

404-321-3333 
Ray 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. 

Page6 
Ray Fowler In Re: Liberty Foundation April 30, 2013 

1 Q. You mentioned that you had discussed 

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 

10 to have a director of maintenance by any regard. We 

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 10 
Ray 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 11 
Ray 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 12 
Ray 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 14 
Ray 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? 

4 I don't recall. 

5 

A. 

Q. Do you have any idea how many of those 

6 conference calls there were? 

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

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 -BRENT ANO, INC. 

Page 15 
Ray 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 16 
Ray 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 17 
Ray 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 -BRENT ANO, INC. 

Page 19 
Ray 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. 

Page 20 
Ray 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 

A. Yes, sir. 

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. 

Page 34 
Ray 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 

I GOVERNMENT 

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 

Inner Wing 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 

Flap Controls Motor Unit Assembly. . . . . . . . 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 

RH Wing Oil System. . . . . . . . . . . . . . . . . . . 54 

Engine Oil Tank and Oil Transmitter ..... ·. . 56 

Oil Temperature Regularor. . . . . . . . . . . . . . 58 

Oil Dilurion and Oil Surge Valves ......... 59 

LH Wing Supercharger Lubricacing Oil Syscem 60 

RH Wing Supercharger Lubricaring Oil 

System ........................... 61 

Supercharger System-Inboard ........... 62 

Supercharger System-Outboard . . . . . . . . . . 64 

. Supercharger Air Filter and fnrercooler. . . . . . 66 

Supercharger Air Filter Relief Valve 

Assemblies . . . . . . . . . . . . . . . . . . . . . . . . 68 

lnrercooler Temperature Control-Wing .... 70 

Supercharger Oil Tank and Tank Supporrs. . . 71 

lH Wing Supercharger Regulator Tubing 

_and Controls . . . . . . . . . . . . . . . . . . . . . . . 7 2 

RH Wing Supercharger Regulator Tubing 

and Controls . . . . . . . . . . . . . . . . . . . . . . . 7 4 
ll 

RESTR!CT::D 

AN 01-20~G~4 

~~~-~sv·~·,·.·.~ 

.. --~~!:':-<·: ·--~--:. . ,::~:_;:;,,_·:>-:_:~ 

LH Supercharger 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 Trim Tab Control ............... 106 

Rudder Trim Tab Control. .............. 107 

Fuselage 

Nose Assembly ....................... 108 

Forward Secrion Windows ............... 110 

· Forward Seer ion Flooring Spt-eial Firrings .... 112 

Pilar's Cockpit Windows 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 Stet ion Misceilaneous Fircings ..... 122 

Bomb Doors and Bomb Rail Support ....... 123 

Forward Entrance Door and Camera Door ... 1 2 4 

Wing Srub Filice Fairing and Compression 

Srrur Ficrings ...................... 126 

Rear Section Bulkhe-ad Fittings ............ 127 

Top Gun Emplacement Windows ......... 128 

\Y/aisr Gun Windows ................... 130 

Main Entrance and Emergency Exic D00rs 

and Releases ....................... 13 2 

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 ..... · ................. 15 2 

Rudder Pedals ....................... 154 . . 

Brake Ccnrrol ........................ 156 

Aileron Tab Conrrol Assembly ............ 15 7 

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 Tab Unit. ................ 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 Instrument Board ...... 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 

Vacuum Selector and 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 ......................... 23 7 

Cheek Guns and Equipment .............. 238 

Radio Compartment Gun ............... 240 

Power Turrets ........................ 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 

Bomb Door Controls Screw Assembly ....... 2 52 

Bomb Door Conrrol Gear Assembly ........ 25.4 

Bomb Door Limit Switch ................ 256 

Bomb Control Unit Assembly ............ 25 7 

Bomb Rack and Door Control ............ 25 8 

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 Bomb Shackle 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 

Landing Gear 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 

LH Ourboard and RH Inbo~rd Engine 

Oil System ........................ 304 

LH Inboard and RH Outboard 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 

Eleva cor 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 ......................... 3 12 

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 ............. 3 16 

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 

2 Fl-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!)·-ou tboard 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 49 
Section 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 AN HOI-I 12 PDl:!H:! IJ RG4-1:10-2 H ~01(;7 

I~ 41ll-4A 

312 

1234567 

FUNCTIONAL SYSTEMS 

I 

'' , . ..::::,.. ' '---

2 5 

Figure l 98-Fuel System 

Fuel System 

Nomenclattue 

\ 

\ 

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

Valve Assernbl.v-Transfer control ffienison) GF£ (see fiq. Zl l __ ... _. _ .. _ ... _. ___ . __ . _ 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 shu t-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 

I GOVERNMENT . 

i EXHIB.IT 

1-:--..;1'", '·~· >~, ,:,~,·· 
RESTRICTED 

AN 01-20EG-2 

Table of Contents 

TABLE OF CONTENTS 

Section Page 

I Description, Dimensions and leading 

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 Handling and General Maintenance 

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. Taper Pin Joints. . . . . . . . . . . . . . . . . . 54 

c. Skin Patches and Stringer Splices. . . 54 

2. Wing Group....................... 54 

a. General . . . . . . . . . . . . . . . . . . . . . . . . . 54 

b. Inboard Wing Panel. . . . . . . . . . . . . . 58 

c. Outboard Wing-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. Power Plant Group .................. 101 

a. Engine and Accessories ............ 101 

b. Trouble Shooting ......... : . . . . . . 113 

c. Replacement of Parts and 

Minor Repair . . . . . . . . . . . . . . . . . 116 

Section Page 

d. Adjustments .................... 131 

e. Removal, Disassembly, Assembly, 

and Installation of Complete 

Engine Section. . . . . . . . . . . . . . . 13 2 

f. Exhaust, Air Induction and Turbo 

Systems ....................... 140 

g. Power Plant Controls . . . . . . . . . . . . . 154 

h. Propeller System . . . . . . . . . . . . . . . . . 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. Surface Control Systems . . . . . . . . . . . 220 

c. Hydraulic System ................ 253 

d. Electrical System ................. 271 

e. Communications Equipment ...... 318 

f. Fuselage Furnishings . . . . . . . . . . . . . 332 

g. Heating and Ventilating Equipment. 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. Gunnery Equipment .............. 378 

V Useful or Military load. . . . . . . . . . . . . . . . . . 407 

1. Bomb loading ..................... 407 

2. Ammunition loading .............. 407 

VI Materials of Construction . . . . . . . . . . . . . . . . 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. Tubing Material .................... 431 

IX Charts and Tables ...................... 432 

1. Manufacturer's Flexible Cable Chart. . . 432 

2. Wrench Torque Valves for-Bolts and 

Nuts . . . . . . . . . . . . . . . . . . . . . . . . . . 432 

X Service Inspections . . . . . . . . . . . . . . . . . . . . . 441 

Alphabetical Index ........................... 514 

RESTRICTED 
RESTRICTED 

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 ADJUSTING AI!M (Sf-METAl ElfMENn 

OIL RELIEF PASSAGE VALVE :S:S:EM~S:LY~-:~:~~~~:=====rr::~~~;~;~~~=~~~!~~~= (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 TREA TMENT.-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 completely evaporated 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 ALLA TION.-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. 

The cells in each wing are divided into two groups, each 

of which acts.as a feeder tank for one of the main tanks. 

The four inboard cells tie into the feeder tanks through a 

1-1/4-ioch inside diameter self-sealing hose and an E-5 

or D-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 of hydraulic 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 193 
Section 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 I ANK 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 VAl VI' 

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 VAl VI' 

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-IANK DRAIN VAlVE 

Z -FUEl QUANTITY GAGE 7-llf 

board cells in each group at their forward ends by 

internal hoses and connecting these outboard cell group 

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 

( 

(( 

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( 

\ 
• 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 195 
Section IV 

Paragraph 6 

RESTRICTED 

. AN 01-20EG-2 

Figure 20 J -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 RESTRICTED 
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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 to place jacks 

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 the ga.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 the remaining fuel lines. Remove the liquidometer fuel transmitter gage before attempting to remove 

tanks rrom wing. · 

c. In removing engine No. 1 and engine No. 

4 tanks and engine No. 2 and engine No. 3 feeder tanks, 

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 

vapor removal lines at the top outboard end of the tank; 

then lower the tank. Follow the same procedure for 

removal of engine No. 2 and engine No. 3 tanks except the forward end of the tank should be supported on 

the wing structure and the aft end lowered·far enough to 

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 no cradles for the outer wings are available. 

b. Drain fuel tanks and place jacks under Figure 204-FuefTank Installation-Outboard 

RESTRICTED 197 
Section 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 T ANKS.-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 or hoist, then release them by operating the emergency release mechanism. Lower the tanks to the ground 

carefully ro avoid damage from contact with the surrounding structure. 

(c) ASSEMBLY AND INSTALLATION. 

1. MAIN FUEL TANKS. 

a. Replace all bonding carefully tO avoid the 

possibility of electrical 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 

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_ ..... / 

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 199 
Section 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 the undersurface of the wing between stations 20 and 

24 aft of the rear 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 

cell with a piece of dural 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 continuous link between the adjacent undamaged cells. 

The rwo cells with filler necks cannot be bypassed if 

damaged. They must be removed and repaired or replaced. Do not delay in making repairs to cells any more 

than with the main fuel tanks. Residual gasoline will 

continue its action although the cell 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 

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RESTRICTED 

AN 0 1-20EG-2 

Section IV 

Paragraph 6 

removing the poppet from the plugged port. 

This condition arises when the bomb bay tanks 

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 the tank through 

a screened outlet. This pump is designed to produce a 

discharge pressure against a closed port of eight pounds 

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 201 
Section IV 

Paragraph 6 

RESTRICTED 

AN 01-20EG-2 

Figure 216-Bomb Bay Fuel Tank Installation (Bottom View) 

to protect the leakproof bag. After removal of the pump 

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 of spare 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.-If the booster pump does 

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 leading edge 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) INSTALLA TION.-Replace mounting bolts; 

connect fuel lines and electrical leads. Seal fuel lines as 

per Specification AN-G-14. 

(5) FUEL STRAINER. 

(a) GENERAL-A fuel strainer is mounted on 

the forward inboard side of each fire wall. The primer 

202 RESTRICTED 

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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. 

figure 217 -Bomb Bay Fuel Tank Installation Procedure 

RESTRICTED 203 
Section 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 

of No. 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 

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AN 01-20EG-2 

Section IV 

Paragraph 6 

sure gage. Adjustment is accomplished by removing the 

hex head cap on the upper portion of the 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 ALLA TION.-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 panel on 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 ALLA TIQN.-Replace the mounting 

screws and connect fuel lines. Seal fuel lines as per Specification 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 of the catwalk truss. The pump 

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 has come to rest. 

(b) REMOVAL. 

WARNING 

Remove the motor fuse first. 

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 205 
Section 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.-Two transfer selector valves are 

mounted on the rear side of bulkhead 4, one on either 

TANK PORT - side of the door, and the control 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 to any tank on the opposite side. A transfer between 

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 

( 

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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 pump motor at the time any valve port 

is opened. This eliminates possible damage to the valve 

from pump pressure against a closed port. 

(b) REMOV AL.-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. J8A61 JJ 

MANIFOlD B.A..C. 3-13662 

FitTER * AN5822-1 

RATE Of CliMe INDICA TOR * AN5825-2 

AIR SPEED PITOT TUBE 

Figure 227-F/ight Instruments Diagram 

RESTRICTED 

TH 

El&OW 

VAC. TUBING ... 

PilOT PRESS. 

TUSING 

STAOC TUBING 

ORAIH 

207 
Section 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 >-M 76 

~>----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 

0.1 ~-CARS. t~~~ M99-< D 

MPERATURE 28B CARBURETOR AIR TENP. INDICATOR o 

N!OO-< A 

.2 CARS. PERATURE • D 

~•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" ... I() r7j 

9 CARBURETOR AIR 

TEMP. INDICATOR 

0198-

I 

9 93 

412 BUL 8-110.3 OIL 

MPERATURE 

M~-<hl 

M87-<~ 

T,E 

+-

408 BUL 8 • N0.4 OIL TEM PERATURE 

+- Ml!l3-<~ 

MOe-<~ 

Mill-<~ 

M95-<~ 

• N0.3 CARS 

+- 287 BULB 

AIR TEN PERATURE 

286 BULB • N0.4 CARS AIR TE NPERATURE 

112-<F=;l 

.......... 92-<~ 

BAC WIRING DIAGRAM 9-6848 AAF 42-31032 AND ON 

-<::>- STAKON SPLICE 

Figure 228-lnstruments Circuit (A & M} 

208 RESTRICTED 

( 

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( 
RESTRICTED 

AN 01-20EG-2 

Section IV 

Paragraph 7 

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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's compartments, 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 static air pressure to the other. The diaphragm is connected to the 

pointer by a linkage and gear system and movement of 

the diaphragm is thus translated into pointer movement. 

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 209 
Section 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 pointer movement. 

' 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-The rate of climb indicator operates by quickly and accurately measuring the difference in atmospheric pressure as altitude changes, 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 pressure differential 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 

connections are pulling on instrument. 

Adjust regulator. 

Check calibration of 

gage. 

Rep a i c 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 the case is securely mounted on 

the panel. If the instrument still doesn't work, replace it. 

Do not attempt to adjust 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· 

ment should 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. 

Incorrect gage 

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 INDICA TOR. 

See "Autopilot," paragraph 7. b. (10) (a). 

(10) OIL TEMPERATURE INDICA TOR. 

(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 special resistance 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 check a temperature instrument 

circuit: 

1. Disconnect the power by pulling the fuse or 

removing the indicator receptacle. 

210 RESTRICTED 

I 

; 

'. 

( 

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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 erminol AN 669. the assembly length includes full length of ti!:rminal1o. 

Poulwn and Nor don Boll and Strop, and AmeriCan Chain oncJ Coble Boll and 

may be·uw:d in place of Standard AN ~7 and AN 668 Swage!'d T 

Figure 230-lnstrument Vacuum Control System 

WARNING 

Always remove the 15-ampere thermometer 

fuse in the station 4 fuse shield or disconnect 

the indicator receptacle before disconnecting a 

temperature bulb. An open bulb. circuit with 

power on 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 bulbs are approximately as follows: 

Air Temperature 

-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 an ohmmeter or a "cold" wire test 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 the p<>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· 

trical p<>tential (voltage) is set up across the bond. When 

two such bonds at two different temperatures are connected with ammeter in the line, an electrical current 

RESTRICTED 211 
Section 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 

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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. No reading at any of the six positions of the 

selector switch may indicate a blown fuse, a poor connection at the indicator, a break in wire M33, or a defective indicator. 

2. No reading on one setting indicates 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, 

adjustment of the full and empty limits, tightening connections and replacing the units. 

(15) FUEL AND OIL PRESSURE GAGES. 

(a) GENERAL.-These instruments consist of 

transmitting and indicating units. Fuel or oil pressure 

acting on a diaphragm transit p~essure through a liquid 

(AN-VV-C-551) on the other side 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 213 
Section IV 

Paragraph 7 

RESTRICTED 

AN Ol-20EG-2 

(c) TROUBLE SHOOTING. 

Trouble 

Does nor regISter. 

Pointer fails to 

cetu en 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 two bellows are connected by a spacer. One of the 

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 the rotating magnetic field and in turn drive a 

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 INDICA TOR. 

(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 the position 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 electromagnet for 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 the other south at the same time, the magnets repel 

each other in a rotary direction due to the triangular 

shape, causing the pointer to indicate the strength of the 

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 

four generators. Current through a pivoted coil rotating 

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 

I GOVERNMENT 

;. EX~--

10 A.PRil 1943 

REVISED lS AUGUST 1956 
T.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 J 509. 

;-------------- 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 of Latest Page Date of Latest Page Date of Lates; 

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 

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33 .......................... 25 May 1944 96 .......................... 25 May 1944 165 .................... 25 October 1944 

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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 1956 
T.O. 1B-17G-3 

LIST OF REVISED PAGES ISSUED (Continued) 

• Page Dale of Latest Page Date of Latest 

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 

2 30 ........................ 25 May 1944 

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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 ........................ 2 5 May 1944 

245 ........................ 25 May 1944 556 ........................ 2 5 May 1944 

246 ........................ 25 May 1944 

247 ........................ 25 May 1944 

248 ........................ 25 May 1944 

249 ··········:············· 25 May 1944 

250 ........................ 25 May 1944 

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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 

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'i35 ........................ 25 May 1944 

Revised 15 ·August 1956 
T. 0. No. 0 1-20E-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 1945 
T. 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) DRILLJNG AND REAMING 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 1fa 2 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 

I and 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 VA LUES. 

(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: 

Bolt Size 

10-32 

%-28 

:X 6-24 

o/s-24 

Tor que, Inch-Pounds 

20 to 25 , 

50 to 70 

100 to 140 

170 to 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 two gases, 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 a blow 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 1 temperature 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 melting 
T. 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-
.. 

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FIELD SERVICE 

SECTIONS 

MANUAL 

...,.__,._,.,...--..,-........,- ~-~, .... 

f'

.,:· . . .•:-> ·'?: . . 

t. . •' . );-_!~ • -~ -~' •• ~ 

l. FORTRESS ~AeTS. · .. · 

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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 open to 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., red page); "In 

Ai:" (flight charts and check list, blue page): _ 

Dut:;," (orange page). From the chapter index you caii. 

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 system to which it belongs; 

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· 

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i 

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1-

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STRUCTURt 

··.·.' 

.·' 1 

.EQUIPMENT 21 

.FLIGHT ~ND ENGINE c:;ONTROlS ----- 21 

ENGINE_ AND ACCIS$Q.!UES ·· 65 

PllOPE~ERS ... JI 1111!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.., 

.· .. - .. ;-~~/ ·,~ ~-;· ~~~~ 

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.. 
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w 

... 

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------·· 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.HU J.Qff VAl Vf 

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 .. l VE-TRANSFE" SERIES A 

W-CONTROl-REMOTf MANUM 

X-SYPHON 

y •. JANK OR .. IN VAlVE 

Z -FUEl QUANTITY GAGE 

1fo * tiS[O ON f.ARU1R 

MODt:l l! !]C.'S 

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~PfCIFICATION 

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FUEl SYSTEM DIAGRAM-LEGEND 

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,,. 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 1 7 l'~3J. 

4. Tighien h,~Jt;; tn"•.5nly wlwn il•st<.>]JinrJ booster 

pump. Thi" j->11.!\'' 11\:·, da;n,JGG !c illt0 l 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 booster pump 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 matter from the fuel. 

Locution-On the forward side of nacelle 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 allows fuel to pass 

diJectly throuc_~h the? primer to the engine selected. Rememhe;! A leak ill<; pz ime1 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 evil nterclockwise 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 be transferred. 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 the pump rUn after the tank is emptied. Let 

· @ the pump motor s~op before reversing it. 

~ E Service Information-Replace the pump motor 

...: brushes when worn 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 eliminatiag possible 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 J ANI':: 

1 TWO 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 of pluqi]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 control units are on the forward bulkhead of the 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-S fuel valve .. This pressure overrides the 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 sealed in, constant pressure fluid. · · 

\ 

t 

\ 

l 

I 

Service Information-If an,y part o,f. this uliit, ).s 

damaged, the two sylphons (actuati,ng bellows}~d : 

the connecting fluid tub.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 

.OJ f. 

.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!t ictor titling at the oil dilu· 

lion solenoid has been reven;ed to allow a 

larger pressure 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 drops per minute ar JG PSI d;Jtc:rential pressure. 

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 dilut~on. This will dilute the oil in the Ieath . 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 cock in \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 VALVE 
Q 

-------·------------·· 

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 

the metal tube. 

~ 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 

switches 

that 

are 

the 

"oli" 

master 

before 

battery 

you attempt 

and ign:tio;·, 

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 

becoming cloqged. 

NOTE-Keep all cell openings covered while 

ceiis are out of airplane. 

7. Note position of tank before removal to helf• 

in reinstallation. 

8. Release tank straps and remove tank. 

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 hat hom 

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-INST A LUNG 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 if possible. 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 

I 
and 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 

collapsed position. 

NOTE-Cell must not mmain collapsed for 

more than 30 minutes. Cells must not be 

piled on top of one 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. 

cell before 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 of . stall sway blocks a. 0:.,c.m.,. the 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 inspection hole in ~ach cle~ns. These 

beams must be installed w1th the nvet manu· 

factured heads up. 

CAUTION-Too much contact pressure between the rail pads and the tank will tend to 

make the tank hang up instead of dropping 

out when the emergency release 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 doors for 

hand holds. Do nol allow cells to rest en fittings. 2. if Dgllts 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 bomb release 

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 .· -·-d 
TROUBLE 

A. No pressure. 

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. 

Correct lines. 

Open valve. 

1. Fuel pump balance line Remove restriction; tighten plugged or fittings loose. Httings. 

2. Delective fuel 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. Pressure adjustment 'faulty. Adjust fuel pump to .15 PSI 

D. No pressure to primer. ·---------- 2. Oil dilution valve operating. Turn off oil dilution valve. 

l. Booster pump not operating. Replace or repair. 

2. No.3 fuel strainer plugged. 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 or broken. Tighten, repair, or replace. 

•;· engine selected. 2. Lines crossed. Correct. 

3. Distributor fitting plugged. Clean fitting. 

----

11 G. Transfer pump inoperative. 

F. Shut-off valve inoperative. 

l. Damaged solenoid. Replace valve. 

2. Fuse blown. Replace fuse. 

1. Damaged switch or arm. Replace pump. 

2. Damaged switch arm. Straighten. r' 3. Motor or pump damaged. Replace. 1 

4. Fuse blown.(30 amp). · }lep.lace fus~. v -. -----_,__..:_:__.....___;;_~,___,__---'------

~ ........................................................... -. .. ~--~~--~---- fUEl SYSTEM 

... ·· ~ . 

i 

.... -

, ... 

,· ~ . .~ ., . c",.t • 

NOTES 

t ~ . 

0 

... 

... 

v 

"' .... 

"' w 

a: 
U.S. Department 

of Transportation 

Federal Aviation 

Administration 

In Reply Refer To: AGL-7J 

2011-GL-03-0057 

Great Lakes Region 

2300 East Devon Avenue 

Des Plaines, Illinois 60018-4696 

Telephone: 84 7/294-7109 

CERTIFIED/FIRST CLASS MAIL 

January 31,2012 

Mr. Rodney Dean Schneider 

150 Woods Court 

Ball Ground, GA 30107 

WITHDRAWAL OF EMERGENCY ORDER OF REVOCATION 

AND 

REPLACEMENT WITH 

ORDER OF SUSPENSION 

On August 22, 2011, an Emergency Order of Revocation was issued to you, from which you filed 

an appeal to the National Transportation Safety Board (NTSB). After further consideration of 

material and evidence presented by your counsel, and in consideration of your withdrawal of your 

appeal to the NTSB and the settlementreached, it has been determined that withdrawal of the 

August 22, 2011 Emergency Order of Revocation and replacing it with the following Order of 

Suspension is appropriate. 

THEREFORE, the August 22, 2011 Emergency Order ofRevocation is hereby withdrawn and the 

following Order of Suspension issued and served in its place. 

ORDER OF SUSPENSION 

It has been determined by the Administrator of the Federal Aviation Administration, acting by 

and through his Regional Counsel, that on the basis of all available information, you violated the 

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 Powerplant ratings. 

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 of another, which included the 

removal and replacement of all six fuel tanks (the maintenance). 

3. Rather than replace the bladder fuel tanks that you removed with appropriate 

replacem~nt parts, you fabricated aluminum tanks without the benefit of approved 

data, an appropriate field approval, or any other engineering data acceptable to the 

Administrator. 

4. The replacement of the bladder fuel 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 or any 

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 

of aluminum sheet, 11 00!1.! 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 Erection Manual, pages 196-199. 

6. Following the entry set forth in paragraph 5 above, you typed your name, affixed 

your signature, and included your certificate number, AP264901 0, indicating that 

you performed the maintenance described in the entry, that the work was 

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 not repair aluminum tanks, but instead you fabricated aluminum 

tanks from the aluminum shells that had previously provided support and 

protection for the bladder tanks that you removed from N390TH. 

8. Your fabrication of the aluminum tanks and your installation of these tanks in 

N390TH resulted in a major alteration ofN390TH as that term is used in 14 

C.F.R. Part 43 and its appendices. 

9. Your incomplete and misleading description of the work performed on the 

fuel system concealed the major alteration ofN390TH. 

2 
10. The alwninum fuel tanks that you fabricated and installed in N390TH did 

not conform to the type design or type certificate ofN390TH and rendered 

N390TH unairworthy. 

11. The methods and techniques you used to fabricate the aluminum fuel tanks 

was so far below the standards acceptable in aviation that installation of 

these tanks would never have been approved by competent authority. 

Count II 

12. On or about June 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 inspection program for N390TH requires the use of three jacks to 

be used when a landing gear check is performed on N390TH. A landing gear 

check is required as part ofthe "D" check inspection per the FAA approved 

inspection program. 

14. On or about June 10, 2011, when you performed the inspection, you did not use 

three jacks when you performed the landing gear check required by the "D" check 

inspection per the FAA approved inspection program. 

15. After you completed the 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, you typed your name, affixed 

your signature, and included your certificate number, AP264901 0, indicating that 

you performed the maintenance described in the entry, that the work was 

performed satisfactorily, and that you approved N390TH for return to service for 

the work performed. 

17. When you performed the inspection you failed to use the methods, techniques, 

and practices prescribed 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 of the work 

in accordance with accepted industry practices. 

3 
Count III 

18. On or about June 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 of the fuel tanks that 

you fabricated in February of2011, as described more fully in Count I above. 

20. After completing the 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#! main tank 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 the repair 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 certificate number, AP26490 10, indicating that 

you performed the maintenance described in the entry, that the work was 

performed satisfactorily, and that you approved N390TH for return to service for 

the work performed. 

22. When you repaired the # 1 tank 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, or other 

methods, techniques, and practices acceptable to the Administrator. 

23. When you repaired the # 1 tank you failed to do that work in such a manner and 

use materials of such a quality, that the condition of the aircraft would be at least 

equal to its original or properly altered condition (with regard to structural 

strength, resistance to vibration and deterioration, and other qualities affecting 

airworthiness). 

24. When you approved N390TH for return to service following the June 13,2011 

maintenance, you knew that the aircraft and its fuel system had been improperly 

altered by you and that, following your repair, N390TH was not in a condition 

equal to its original or properly altered condition and was unairworthy. 

By reason of the foregoing facts and circumstances as described in Count I, you violated the 

following Federal Aviation Regulations: 

a. Section 43.13(a), which states that each person performing maintenance, 

alteration, or 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 

4 
Airworthiness prepared by its manufacturer, or other methods, 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 

performing preventive maintenance, shall do that work in such a manner and use 

materials of such a quality, that the condition of the aircraft or airframe, 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). 

c. Section 43.9(a) and (d), which states that, 

(a) each person who maintains, or alters an aircraft, airframe, or component part 

shall make an entry in the maintenance record of that equipment containing the 

following information 

(1) A description (or reference to data acceptable to the Administrator) of work 

performed. 

(2) The date of completion of the work performed. 

(3) The name of the person performing the work if other than the person specified 

in paragraph (a)(4) of this section. 

(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, 

appliance, or component part has been performed satisfactorily, the signature, 

certificate number, and kind of certificate 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 entry required by paragraph (a) of this section, major repairs 

and major alterations shall be entered on a form, and the form disposed of, in the 

manner prescribed in appendix B, by the person performing the work. 

By reason of the foregoing facts and circumstances as described in Count II, you violated the 

following Federal Aviation Regulations: 

a. Section 43.13(a), which states that each person performing maintenance, 

alteration, or preventive maintenance on an aircraft, 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. He shall use the tools, equipment, and test apparatus 

necessary to assure completion of the work in accordance with accepted industry 

practices. If special equipment or test apparatus is recommended by the 

manufacturer involved, he must use that equipment or apparatus or its equivalent 

acceptable to the Administrator. 

5 
By reason of the 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 person performing maintenance, 

alteration, or 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. I 6. 

b. Section 43.13(b), which states that each person maintaining or altering, or 

performing preventive maintenance, shall do that work in such a manner and use 

materials of such a quality, that the condition of the 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). 

By reason of the foregoing, the Administrator has determined that safety in air commerce and the 

public interest require the suspension of your Airman Mechanic Certificate Number 0026490 I 0 

certificate. 

NOW, THEREFORE, IT IS ORDERED, pursuant to the authority vested in the Administrator of 

the Federal Aviation Administration by Title 49 of the United States Code, Section 44 709 ( 49 

U.S.C. §44709), that 

(1) All airman mechanic certificates now held by you, including your Airman 

Mechanic Certificate number 0026490IO with Airframe and Powerplant ratings 

are suspended; 

(2) Such suspension became effective on August 22, 20 I I, and shall continue in 

effect for a period of270 days, ending at midnight on May 17, 2012. 

(3) This Order of Suspension has been issued based on an agreement and settlement 

reached on January 30, 20 I 2 wherein you have waived notice and all rights to 

appeal or contest this Order of Suspension. 

Jeffrey A. Klang 

Regional ounsel 

6 
cc: Stuart A. Goldstein, P. A. 

9350 South Dixie Highway, lOth Floor 

Miarrii, Florida 3 3156 

7 
a. _r -a·t • , ."' .... 

Photograph of Boeing Model B-17G, N390TH, Serial Number 44-85734 after an in-flight 

fire in the left inboard wing caused an emergency off-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), Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance), 

dated 5/21187, is canceled. 

3. RELATED REGULATIONS. Title 14 ofthe Code 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 serves two main purposes: 

(1) To provide aircraft owners and operators with a record of major 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 paper or by using the electronic FAA Form 337. 

Information can be found online at http://eformservice.faa.gov/eForm337.aspx or by contacting 

your local FSDO. ~-

5. ELECTRONIC FORMAT. 

a. Electronic Tracking Number. In the upper right corner of the form's header, there is a 

block titled "Electronic Tracking Number." This block is used only in the electronic version to 

automatically apply a number that identifies and retrieves forms electronically. Further 

information on the use of this number is supplied in training material at the Web site provided in 

paragraph 4b of this document. 

--------------------------.. ~'GOVERNMENT. 

i EXHIBIT 

i J ·. 
AC 43.9-1F 1/25/07 

b. Watermark. Under current policy, the header block titled "For FAA Use Only" has no 

official use except as a watermark applied automatically to indicate submittal when using 

electronic media. 

6. FORM INSTRUCTIONS. The person who performs or supervises a major repair or major 

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 1 through 8 of 

the form as illustrated in Appendix 1. The terms "Item" and "Block" are used synonymously in 

FAA documents relating to data collection 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 of Aircraft 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 of a specific model. Proper 

segregation of the 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, it is validated by matching the registration "N" number 

with the serial number. If an application for a change to the "N" number has 

been made, it is important for the submitter to receive verification of the 

change from the FAA registry with a new AC Form 8050-3. If the Form 337 

must be submitted before receipt of the new registration then the old "N" 

number must be used. 

b. Item 2- Owner. Enter the 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 major repair or major alteration is made to a component 

part, items 1, 2, and in some cases 5 will be left blank and the original and 

duplicate copies of the form will remain with the part until it is installed on 

an aircraft. After entering the required information in items 1, 2, and if 

appropriate, 5, the person who installed the part will give one form to the 

owner/operator and forward the duplicate copy to the FAA registry within 

48 hours after the aircraft is approved for return to service. If a component 

part of an airframe, powerplant, propeller, or appliance is repaired or 

altered and the unit identification information is not known, it is appropriate 

to apply the preceding procedure and leave item 5 blank until the airframe, 

powerplant, propeller or appliance is installed on the aircraft. 

c. Item 3- For FAA Use Only. Indicate approval in item 3 when the FAA determines that 

data used to perform a major repair or major alteration conforms to accepted industry practices 

and is in compliance with current guidance and regulatory requirements. Approval is indicated 

by one ofthe following methods. (See paragraph 7, Administrative Processing, for further 

details.) 

Page 2 Par 5 
1/25/07 AC 43.9-lF 

(1) Approval of Data by Examination Only. Enter the following statement on 

Form 337 when the data package is reviewed and a data approval is completed: 

"The data identified herein complies with the applicable airworthiness 

requirements and is approved for the above described aircraft, subject to 

conformity inspection by a person authorized in section 43.7." 

(2) Approval of Data by Physical Inspection. Enter the following statement on 

Form 337 when a physical inspection, demonstration, or other type of test of an aircraft is 

satisfactorily performed and an installation approval is completed: 

"Approval by Physical Inspection, Demonstration, Testing, etc.-One Aircraft: 

The alteration or repair identified herein complies with the applicable 

airworthiness requirements and is approved for the above described aircraft, 

subject to 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 of Completeness. 

Authorized designee certification of data indicates that the data in item 8, Description of Work 

Accomplished, comes from FAA-approved sources and addresses all the original certification 

requirements for the aircraft described in item I. It does not constitute a field approval or 

approval of the data. Enter the following statement when an authorized designee has reviewed 

and certified the alteration data package 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 of the 

alteration(s) are compatible and eligible for use on the above described aircraft, 

subject to conformity inspection by a person authorized in § 43. 7." 

(Order 8300.10, vol. 2, ch. I, section I, paragraph I5c.) 

(4) Overweight Aircraft Operating Under a Special Flight Permit. Enter the 

following statement as part of the recordkeeping requirements for overweight flight permits 

contained in the current edition ofF AA Order 8130.2, Airworthiness Certification of Aircraft 

and Related Products: 

"No person may operate this aircraft, as altered herein, unless it has within it an 

appropriate and current special flight permit issued under part 2I." 

(Order 8130.2F, paragraph 196b.) 

d. Item 4- Type. Enter a checkmark in the appropriate column to indicate whether the unit 

was repaired or altered. Use only one "Type" line per form. 

e. Item 5- Unit Identification. Use the information blocks under item 5 to identify the 

airframe, powerplant, propeller, or appliance that has been repaired or altered. It is only 

necessary to complete the blocks for the unit repaired or altered. The procedure for repair or 

Par 6 Page 3 
AC 43.9-1F 

alteration of a component part when the unit identification is unknown is detailed in 

paragraph 6b above. Use only one "Unit Identification" line per form. 

NOTE: A component of an airframe, powerplant, propeller, or appliance 

repaired or altered must be clearly identified in item 8 listing the part 

number, serial number, and any other descriptive information as applicable. 

f. Item 6- Conformity Statement. 

1/25/07 

(1) "A"- Agency's Name and Address. Enter the name of the certificated person or 

entity accomplishing the repair or alteration. Mechanics should enter their name and permanent 

mailing address. Manufacturers, repair stations, and certificated maintenance organizations 

should enter the name and address under which they are certificated. 

(2) "B"- Kind of Agency. Check the appropriate box to indicate the type of person or 

organization that performed the work. 

NOTE: For the purposes of this form, a Canadian Approved Maintenance 

Organization is considered a foreign mechanic. 

(3) "C"- Certificate Number. Enter the appropriate certificate number for the "Kind 

of Agency" entered in item 6b of the form. Mechanics should. enter their mechanic's certificate 

number. Certificated maintenance organizations and repair stations should enter the number 

referenced on the air carrier, air operator, or air agency certificate issued by the FAA as 

appropriate. Manufacturers should enter their Production Certificate or Supplemental Type 

Certificate number as appropriate. When repairing or altering articles, manufacturers holding 

Technical Standard Orders (TSO) approvals should enter the TSO number of the affected article. 

(4) "D"- Conformity Statement. Use this space to certify that the repair or alteration 

complies with 14 CFR part 43. When work was performed or supervised by certificated 

mechanics, they should enter the completion date of the repair or alteration and sign their full 

name. Repair stations and maintenance organizations are permitted to authorize their employees 

to date and sign this conformity statement to comply with their FAA-approved program. 

(5) Fuel Tank Modification. For modifications involving installation of extended range 

fuel tanks in the passenger or baggage compartment as described in part 43, appendix B, check 

the box provided to indicate the modification. 

NOTE: In this instance, one copy of Form 337 must be placed on board the 

aircraft as specified in 14 CFR part 91, § 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 or major alterations to airframes, powerplants, propellers, and appliances 

may be approved for return to service. This portion of the form is used to indicate approval or 

rejection of the repair or alteration and to identify the person or agency making the airworthiness 

determination. 

Page 4 Par 6 
1/25/07 AC 43.9-IF 

(1) Check the "approved" or "rejected" box to indicate the finding. Rejected forms will 

be returned to the person who made the modification, as identified in item 6, for correction. 

Approved forms will be completed, signed, and submitted to the aircraft registry. 

(2) Check the appropriate box to indicate who made the finding. Use the box labeled 

"other" to indicate a finding by a person other than those listed. This box 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's name should also be typed or 

printed below their signature and the appropriate certificate or designation number should be 

entered. If an aviation safety inspector (ASI) signs item 7, the ASI's office identifier is placed in 

the certificate or designation number block. 

(3) Before approving Form 337, it is the responsibility of the person returning the 

product to 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) If the 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 of Work Accomplished. 

(1) Enter a clear, concise, and legible statement describing the work accomplished in 

item 8 on the reverse side ofForm 337. It is important to describe the location of the repair or 

alteration relative to the aircraft or component. If making 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 spar 49 inches from the tip in accordance with ... " and 

continue with a description of the repair. If the 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 certificate number 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 of the repair or alteration. Forms of 

FAA-approved data are contained in Order 8300.10 and AC 43-210, Standardized Procedures for 

Requesting Field Approval of Data, Major Alterations, and Repairs. 

NOTE: Supplemental data such as stress analyses, test reports, sketches, or 

photographs are often proprietary and not intended as part of the item 8 

description. Supplemental data submitted as part of the item 8 description 

should be identified as an attachment to the form using the following 

procedure. 

(3) If additional space is needed to describe the repair or alteration for item 8, check the 

"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 attachments to 

item 8 must be submitted on 8 'li- by I l-inch paper to allow for proper processing into the 

aircraft historical record at the aircraft registry. If attachments to Form 337 are received by the 

Par 6 Page 5 
AC 43.9-IF 1/25/07 

FAA in a format larger than an 8 !h- by 11-inch page then the submission will be returned to the 

person identified in item 7 for correction and resubmission. 

(4) Showing weight and balance computations under item 8 is not required but it may be 

done. If weight and balance of the aircraft are affected by the work described on Form 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 337 will be executed in duplicate with one 

signed copy given to the aircraft owner and one copy forwarded to the FAA within 48 hours after 

the airframe, aircraft engine, propeller, or appliance is installed on an aircraft and approved for 

return to service. FAA processing ofthe forms and their supporting data will depend on whether 

approved or unapproved data is used. 

a. Approved Data. Complete the form as instructed in this AC, excluding item 3, and 

ensure that items 6 and 7 have been properly executed. Give a copy of the form to the aircraft 

owner/operator and 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. Complete the form as instructed in this AC, leaving items 6 and 7 

blank. Both copies of the form and any supplemental data will be sent to the local FAA district 

office. When the FAA determines that the 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 applicant will give one of 

the completed forms to the aircraft owner/operator and submit the other completed form to the 

FAA Aircraft Registration Branch for inclusion in the aircraft records. 

NOTE: The electronic FAA Form 337 allows for electronic approvals and 

processing of Form 337 from the time it is 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 ·or the two processes. If Form 337 

is started in the electronic format, it must be completed that way and cannot 

be completed using the paper process. Further information is supplied at the 

Web site shown in paragraph 4(b). 

c. Signatures of Form 337. 

(1) An FAA inspector's signature in item 3 indicates approval of the data described in 

that section for use in accomplishing the work described in item 8 of the form. The statement of 

completeness in item 3 by an appropriately rated designee is a "certification of completeness" of 

required data. It is not a field approval or approval of data. 

Page 6 

NOTE: Signatures in item 3 count as data approval or completeness of 

approved data only and do not indicate the approval for return to service for 

the work in item 8. 

Par 6 
1/25/07 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 or Designee constitutes 

an authorized return to service. A signature is not an approval of data. 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 conforms to FAA-approved data and is performed in 

compliance with part 43. 

(4) If engineering assistance was requested, written Aircraft Certification Office 

concurrence (e.g., memo or e-mail) becomes an attachment to 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 or a foreign civil 

air authority if it is requested as a record of work performed and should be completed following 

part 43 and this AC. A note on the fol11'i should inform the U.S. Military or foreign 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, PO Box 25504, Oklahoma City, 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 REPAIR AND AL TERA noN 

-~ I"'T.....,_ ic-Ho.21:NGZO 

ua~ ............. ..., ol1--

_...._ !Airframe, Powerplant, Propeller, or Appliance) 

~-

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 lot IN!oCh 

IIICh vlllllltlon (40 U.S.C. §-4Q01 (8)) 

~-- • Mllrll !&NISI NO • 

1. Alrc:taft ~ ~ ,s.1 .. 

~-(As a/laM'! on ~onl»>lllDUUJ ~t(Aa-011 crtllatl.e) 

...,_ 

2.0wn ... ca, ..... z., a-.,. 

3. For FAA UN Onlv 

4.Type !. Unllldltnllflca1lon 

R..,.r Alanlllon u ... Malia Model Serial No. 

0 0 AIRFRAME (As dNctb«<ln H8111 1 •bow) 

0 D POWERPI..AHT 

0 D PROPEllER 

p 

-..... 

0 D APPLIN«:E 

~-

& Conronn_llte...,.,. 

14.. A(Jroc(l Name and AddNas 8. Knd Ill Aoetq 

- us.~-- ,_ - Faoigol~-nic c. Cwtlicale No. 

a. - c..-~rS1olicn 

"' 0....0, Oo-.,M8nton_O __ 

D. I Wilily 11\at the lwpK 8nd'ao" ~~~~.ration mat. to the unt(t) ldlndied n l*t S llllOIM and dela'l>ed on the _.,..or alllachmtntl hemo 

have bNn made WI acoDidllnce wth the recpnw!W1b ol ~ 43111the U.S. Feder'~~ Aviation Rllgulllllons and thai the lttonnation 

bnii'*IJwMIIINe lnl Cllmld to the~ Ill my~· 

e..nded -ve fuel ' ol Aulfla'1fed lhdi'IIIIUII 

pw 14 CFR Pa1t 43 0 App.B 

7. ••rovallllr ltelum 10 a..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 ~ 

FM At Stardanta Manuradlnt Mainlolnance O'llllf'IZallln 1 Pot..,..sApp-byc.-n 

ln8pec:tlr ~ofTr.-..port 

BY OCMI'~ 

FMO.IgNe Repar&Mion Inspection Aulhoftzation 

~tlaDot ~ ol Aulhaized lnci'IIIIUII 

DesliJ'III!On No. 

FAA Form S3711CHIII 

Page 1 
AC 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 of Fittings. All fittings 

are to be compatible with their mating parts. 

Although various types of fittings appear to be 

interchangeable in many cases they have different thread pitch or minor design differences 

which prevent proper mating and may cause 

the joint to 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 of the 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 

supported by 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 

I GOVERNMENT 

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 than the 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 of tanks. 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 of clamps 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 of fuel/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 cleaning procedures. 

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 chapter 4, 

Metal Structure, Welding and Brazing of this 

AC . 

9/8/98 

c. Removal of Flux After Welding. It is 

especially important, after repair by welding, 

to completely remove all flux in order to avoid 

possible corrosion. Promptly upon completion 

of welding, wash the inside and outside of the 

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. If the 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 of the cleaning operation by 

applying some acidified 5 percent 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 of deterioration. 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 of the 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 

limit a tiona: 

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, Major Alterations Job Aid 

NOTE: Aviation Safety Inspectors (ASI) should see guidance in Figure 4-68 to 

determine when additional coordination with a Designated Engineering 

Representative (DER) or the Aircraft Certification Office (ACO) may be 

necessary. 

1. The following lists indicate which method(s) may be used for approving major .xlt"P·r<>t"t 

TC'd and STC'd products. These lists are not all-inclusive, and each alter£!-tion .... v ......... 

evaluated on a case-by-case basis. Consult each section that concerns your pnoduct. 

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 

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Check with FSIMS to verifY current version before using 

an STC, 

automatically 

determine if the 
7/28/09 8900.1 CHG 71 

Figure 4-68, Major Alterations Job Aid (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 (EV AS). 

Global positioning system (GPS) or Global 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 of an atmo 

control system of aircraft interior compartments. 

Changes in engine and propeller combination 

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 

Changes to landing gear and 

length, geometry of .......... ..., .... ~ 

such as internal parts of shock struts, EVL 

systems, or additions. 

drains, or battery vents. (Applicable to EVL 

engine.) 

(LOX) or onboard generating systems. ENG 

, auxiliary power unit (APU) ram air, nacelle blowout ENG 

raulic, Pneumatic, and Fuel Lines, or Systems That Affect Their 

Installation and Flammability Requirements, such as: 

of hoses and/or hose fittings that may not meet installation requirements, ENG 

flow rate and flammability requirements. 

Changes to fuel dump valves. EVL 

New oil/fuel/hydraulic line materials beyond the scope of AC 43.13-1, Acceptable EVL 

Methods, Techniques, and Practices- Aircraft Inspection and Repair (current edition). 

Change to, or addition of, permanent fuel tanks or fuel system components, including EVL 

22 

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7/28/09 8900.1 CHG 71 

Figure 4-68, Major Alterations Job Aid (Continued) 

sealants. 

Changes in Fixed Fire Extinguisher or Detector Systems That Affect the System's 

Effectiveness or Reliability, such as: 

Relocating discharge nozzles, detector units, or fixed fire extinguisher bottles. 

Using new or different detector components. 

Decreasing the amount or changing the type of extinguishing agents. 

Changes that include substituting airframe materials that affect structural 

lightning protection, or flight characteristics. 

Alterations or Repairs That Include: 

Use of synthetic covering materials. 

New titanium applications. 

Ceramic coatings. 

Use of synthetic coatings. 

Use of new plated coatings. 

Crashworthiness. 

Changes to the aircraft structure, relocation. 

Changes that affect emergency 

jumping). 

ROTORCRAFT. 

EVL 

ENG 

ENG 

ENG 

ENG 

EVL 

ENG 

The following section 

earlier equivalents. 

with a certification basis of 14 CFR parts 27, 29, or the 

W&B. 

maximum weight limits affecting structural, STC 

and so forth (for example, increases in the maximum 

takeoff weight, or landing weight). 

ated center of gravity range limits (for example, decreasing the STC 

increasing the aft limit). 

increase the operational limits (maximum speed limits such as VA, V FE, STC 

speed limitations such as stall speed, increases in service ceiling, and so 

forth). 

Structural Strength. 

Changing primary structures (structures that carry flight, ground, or pressure loads as defined in 

AC 25.571-1 Damage Tolerance and Fatigue Evaluation of Structure) as well as the following 

additional modifications or structural members: 

23 

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7/28/09 8900.1 CHG 71 

Figure 4-68, Major Alterations Job Aid (Continued) 

Anti-terrorism countermeasures, including flares. 

Airworthiness. 

Changes to Systems, such as: 

Relocation of exterior fuel vents or battery vents. 

Crew or passenger LOX or onboard generating systems. 

External critical access doors, APU ram air, nacelle blowout doors, and fuel 

Changes to Oil, Hydraulic, Pneumatic, and Fuel Lines, or Systems or 

That Affect Their Operation or Installation and Flammability 

New types of hoses and/or hose fittings that may not meet 

such as those of flow rate and flammability. 

Changes to fuel dump valves. 

New oil/fuel/hydraulic line materials. 

Changes in Fixed Fire Extinguisher or 

Effectiveness or Reliability, such as: 

Changes that include su 

integrity, lightning ..,.,.,..,,,.~, 

at Affect the System's 

STC 

ENG 

EVL 

EVL 

EVL 

ENG 

ENG 

ENG 

ENG 

Changes that alter 

damage •vH.JiaJ.J'-''-'· 

of rotorcraft, such as loads, vibration, fatigue, STC 

characteristics of main or tail rotor system, 

veshafts, driveshaft support bearings, and main and 

STC 

aircraft to an all-cargo or combination configuration. STC 

that may require a human factors compliance finding (for example, in flight STC 

deck instrumentation and controls). 

Flight deck lighting changes to support night vision goggle use, or any approvals STC 

related to night vision goggles. 

Changing or substituting engine/aircraft instrumentation required by a unique STC 

26 

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I 

' I 

7/28/09 8900.1 CHG 71 

Figure 4-68, Major Alterations Job Aid (Continued) 

TCAS I or TASs (see InFO 08047). EVL 

TCAS II. STC 

APs. STC 

FDRs. 

GPWSs. 

EFISs (see InFO 08047). 

TAWS-A (see InFO 08047). 

TA WS-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 of members, 

such as internal parts of shock struts, ENG 

systems, or additions. 

EVL 

generating systems. ENG 

APU ram air, nacelle blowout doors, and fuel drain. ENG 

lie, Pneumatic, and Fuel Lines, or Systems or Their Components 

or Installation and Flammability Requirements, such as: 

and/or hose fittings that may not meet the installation requirements, ENG 

and flammability requirements. 

ENG 

· line materials. ENG 

New flammable fluid tanks or system components. STC 

Change to, or addition of, permanent fuel tanks or fuel system components, including ENG 

sealants. 

29 

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l 

.. 

US Deportment 

of Transportation 

Federal Aviation 

Administration 

Advisory 

Circular 

AC 43-210 

DATE: 2/17/04 

STANDARDIZED PROCEDURES FOR 

REQUESTING FIELD APPROVAL OF 

DATA, MAJOR ALTERATIONS, AND 

REPAIRS 

Initiated by: AFS-340 
AC 43-210 

NOTE: The substitution of solid rivet fasteners with blind rivet fasteners in 

airframe structures may reduce the structural fatigue life of an airframe. 

These repairs should be evaluated and, when appropriate, authorized by 

either the manufacturer or a representative of the 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. If your alteration or repair 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 of data 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. It is a tool to ensure 

that you have everything you need. Appendix 2 has a copy of the checklist and the instructions 

for completing it. 

c. Review FAA Order 8310.6, Airworthiness Compliance Check Sheets Handbook. 

This order contains a variety of checklists that can help you determine if all of the 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 of compliance are addressed. For determining 

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 after the alteration or repair is 

completed and inspected for conformance. AC 43.9-1, Instructions for Completion ofF AA 

Form 337 (OMB No. 2120-0020), Major Repair and Alteration (Airframe, Powerplant, 

Propeller, or Appliance), as amended, provides guidance on how to complete this form.) Block 8 

documents the alteration/repair and is the permanent record of the alteration/repair. This entry 

should be as complete as possible and contain all of the data that you have developed to 

substantiate the alteration or repair. 

Page 10 Par 301 
EXPERT 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 of the 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 

I O,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 That Will 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 1 0 years: None 

I hold FAA Airframe and Powerplant licenses with Inspection Authorization. 

I have not testified 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 

I GOVERNMENT 

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? 

A. No. Just Mr. Goldstein. 

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. 

Page8 
Gary 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 -BRENT ANO, INC. 

Page 9 
Gary 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 -BRENT ANO, INC. 

PageiO 
Gary 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 II 
1 

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 12 
Gary 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 2 011? 

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 24 
Gary 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 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

vs. 

LIBERTY FOUNDATION, 

Respondent. 

Docket No. FAA-2012-0477 

FAA Case No. 2011 GL030070 

Judge Sullivan 

AFFIDAVIT OF DAVID ALDERMAN 

STATE OF TENNESSEE 

COUNTY OF DAVIDSON 

HAVING COME before the undersigned Notary dulyaJJthorized to administer oaths, David 

Alderman, did state under oath after being properly sworn, that the following statement is true 

and accurate: 

l. I am over the age of 18 and I understand the obligations of an oath. 

2. I am currently employed with the Federal Aviation Administration as an Aviation Safety 

Inspector (Airworthiness)- Principal Maintenance Inspector (PMI) at the Nashville Flight 

Standards District Office (FSDO) in Nashville, Tennessee. 

3. I did interact with Rodney Schneider concerning the maintenance log entry returning 

N390TH to service on February 24, 201 I. This interaction did not occur until after the aircraft 

had been returned to service and operated by The Liberty Foundation. At that time, Mr. 

Schneider showed me the February 24,2011, maintenance log entry, and after reviewing the 

entry I indicated to him that it was acceptable. At the time, I had no knowledge of the work that 

had actually been performed, only what was stated in the logbook entry. 

4. I flew on N390TH, and performed maintenance on N390TH, after the February 24,2011, 

return to service. However, I had no occasion to view the fuel tanks, and remained unaware of 

the true nature of the work performed. 

5. At the present time, I have been informed that TLF's work on the fuel tanks consisted of 

removing the bladder fuel tanks, fabricating attachments, welding those attachments onto the 

I GOVERNMENT 

j EXHIBIT 

i FF-
aluminum support shells, welding plates over existing holes in the shells, and welding shut the 

removable ends of the sheHs. I was not aware of this when Mr. Schneider spoke with me about 

the fuel tanks in early 2011. 

6. Knowing now what TLF did with the fuel tanks on N390TH, I do not believe that the 

February 24, 2011, maintenance log entry presented to me by Mr. Schneider accurately describes 

the work performed. 

7. The work performed by Mr. Schneider onN390TH'sfuel tanks over the winter of2010-

11, was a "major;, and a Form 33 7 should have been completed. 

Further affiant sayeth naught. 

I hereby swear or affirm that the above is accurate and true to the best of my knowledge. 

Sworn and subscribed before me this (lfltray of August, 2013. 

Notary Publtc · · 

My Commission Expires: ~ \~ \0 \ d-0 ll 
U.S. DEPARTMENT OF THANSPORTAT[ON 

OJ!'J(ICE OF HEARINGS 

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' OF TUOA:l.t.\S,SOE!RENS 

STAT'EOF IlLINOIS 

COUNTY OF 

HAVING COME bef(m= the m1dersigned Notr~ryduly auUmrized to administer on.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 . I am ov~r 1 be n.ge of 1:8 and l understand tl1e o bli gat ions of an nat h. 

2. Jam currently employed ·wirh the Federal Aviation.Admia~isGndion ~1s a Principa~ 

t\irworthi nc.Ss I nspecto:r- M~tanten::tnec (P~ofl) at the Du:Page PD i gilt S•~nd.;mfs [)~strict 0 fll.ce 

(FSDO} in We~f f..:hi.l.'~gc>~ Illinois .. 

3. J have served at i.he Federal A vcation Adminisfrn[ i 01) <l$ fUi A.i;roN·onhincss/1\.{ai t:Hetl<l:flCC 

lnspe>e,A)r for {lVer 23 years. 

4. J have hetd •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 a pnlot 

~crtifict~tc since 1974. l'rior t<;' my servi¢c \\~.th the PAA~ [spent I 7 yeats working in privalcsector· aviation maintet1tance, fltst ,:~s ~ij line mechanic and later .as a Director of Mainc~mrtnce for a 

14 C.F.R. Part 135 Air C~uricr:,. a Ch1cflnspectorf.or ~ 14 C.F..R. Part 145 Repair Station, 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 20 J 0 throt~gh <:arly 20 t i , c.u!mirmtiog in a Ftl!bruary 24, 20 l 1, return to 

scrviccj and aJso conc{:mtillg the June 0, 20'11, .li:1ci leak in one ofN390TH's nc\V fuel tanh. 

The material I luwc reviewed tndudes the tli.:p-osition ofthe mcchnok who pcrform.ed lhe work 

in <H~csti!iJn, photo graphs etf (he \Vi rue:- 20 l Q. t I \Vnrk .it~ iP•tOgress •. photo ;graphs and \' idt.·i) of the 

Ji,!inc 201 1 fuel J cak, applica;blc por~ions ofthc m~hHena:nce rc.cords; for NJ 90TJ [, applkabtc 

portions ofthe B-l 7G stnrct~E~ml repair handbook, m~intcuance and ;£:rec.tiolll.l:mndbook; an~ pMts 

~ist, and certificaHo:n and rcgistrati.Oo irtformatao.n for N390TI t 

6. I am famiH~1r with the 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 of six t;ihick~ sclf·se1:1nng blnc.kh:r fuel tanks; 

three in 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 was attached to t)lc interior of the wing hy straps, 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 Jt could he 

taken fl'tl or orr fhc 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:h poi11t, a tl1e! boost pump attach poi.rlil on fiJur of the six fuel tanks, a· j~lcl 

quantity trnnsducer mtnmning poh:u, fuel system nne attadn:nents mld p]all~s. to scallhe fm•mer 

fuel hladder mot.mting points, 'Neldblg thost~ rrttaclnnents and ptalc.s <Onto the almnin~rms.h'.:ll, 

'"'{:]ding shut the remov.aihlc end oftbc sheH,and cozmec1i:n.g each of tile six shells into ~he 

,existing fuel system us fuel tanks, 

10. l ,.Yl.'IS ut~stJJeces$Hll in ~ucaHng anothe-r B~l7cutrcnHy inus.c that f1ad heen convt~rted ~o a 

sand meta!J ie liln:k system c<::ms]sting of an ahltnimrm shd I ,,vith hclles that h;~d hcco plugged by 

\veldit~g ~t v~~rk:iy of fabricated auach:ments ;md plates to tEle sheik ·Or (t manufacturc,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 it changed lhe' design of rhe 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]att ion 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. ·or other qualh3es 

affecting ainvorthint!ss:~ ·Or 

{2) That is l'llot done accordi~g W a<:ccptcd practices .or· ca1,rw•. be don:c by 

clcm<:ntary operac!ons. 

13. There are several nu.~som. v,.;hy the a1temti (m. l,lifftS a nilajor alteration. With[n four months 

of the .alteration~ the \'vclding crnc!ked in one of the nc'~v tanks, resulting in (t fuel lc-~k Tihis \Vas 

an apprt:<:ittblc effect on a quality aflectbtg ~he ainvorthiness ohhe nlrcmfl Thus; the altcratirm 

wns a major aHcrnti.m1. 

14. Addijci:onally .• even setting: as1de the fud teak, tbc removal of the bl~dd·cr fuc.~[ il.3nk co:ulci 

bave had an appreciable effe~t on the airwu.rlhincss of the airc.t'aft. anti its fuel 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 a bi(tc.idcr ft1d 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 of aviarlon 

fuel as~~ scnli-rigid bladder· tank "''Olitd- bn:fillc.s should have. been Jncorpor.atcd into any h~~rdshdl 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 lhat they were of <:q:t.lul·quality to the, parts they 'Ncrc 

rcp]aciog.; had changed fto:m being attached lo ·the scml~r£gid bluddc:r tanJ~ 10, being ~ttacbcd to 

the. rigid aluminum Cank. \:\.flich coukl imp~~~• how they responded to stress during llighL All of 

,fhcse problems ~t~c cx.ac~crba.ted because the ulumimnn tmnks \il,"t:ru not s}:mpty so[id. fot·tuct[ 

atmninun; tnnlk.s, btU. hnd been exteo~ivcly >'\•clded,. introd udng mJn'lcrous potential ''i<'C~tknC'.SS(~s; 

int(1lhe sy.s:tcm ~·us can he seen by 1hc <:racking that developed in one. of a he thelta:nh i,n kss 

than four months, tbe wc[J sc::rms arc a tiource <Of sCructLmJl 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 be in•roduccd by \\'elding art:' highlighted by the: B-170 

Stnlctur.a] Repair Hand boc.J:k 's prohibition on ~A<e.lding al omirunn stmcC mal me.m hers - while !he 

fuel rank is not a strcnelurtt! component, and we~ding a fuc[ tank is per,miss.ihlc l.CUidcr appropriate. 

circumstm:tccs. fhe: same potential wcakt.~cs.scs in the tcsul~ing comp(lncnt aro stitl pres.et1t ullid 

musl be accounted for. 

[5. Also, any alteratiC)n of a 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 in the pcrfom1ru1cc oftllcit duties. One of the 

fl<Jssib!c duties of an AS r Is field approvals of maj:or aheralion:s ... l\e(,"'ruingly, oinc of tbe j o'b 4!MS 

in th£ 8900.1 is a n.s.t nf major ~dtcraci.ons; ;J~nd '''h-olher the. required uppro\•al can be a Held 

approval, rQt,J.SliJc nn engine-ering approval, or requires n SuppJcmcntal Type CertHicnle. On the 

list nf :majcJr ~1ltcr:::~tions is any chmtg:c itJ a p~'Tll'HUlcnf fud tank, or in.sta['].i:11ion of n nc\v fuel umk. 

[ 7, Further~ the fabrka~joil of ~lC""' fud t:.tnks om oflhe aBurtrirmn1 shcHs was a .major 

aHcr::1tion because 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 A of Part 43 of the F ""<feral Avintkut Regulat]ons 

that iists changes in tbc basic design ()f ~t Jucl system as an exampl c of a major altt't.Utuon. Tihe 

rcpi~1cemcnt of the bladder fueJ laJ:1ks with fab:ricatr.:d ntmninu:m fillet tanks -vvas :it change tn the 

tKtS[c design of tlte J'\tel sys~ean. \Vbi!e someofle CtJr . .dd mccJmni call y list dozens of co~npom.:nts 

iJ:tnt lV£fe not repl-aced in rcpl~cing the fuel tanks:,, this does: nol mc~m lhat the te~~lflCCltiCnl of the 

fuel t<~mks -.-vas not a change in the basic: dcsJgn oftJ1e fuel system. Fue] tanks. artdi their ahil i(y to 

pcrform properly, ttre absolu~~dy vita~ tD the safe Junciionrng of a fuel system and aircrafl- not 

the least because a fuel leak c'Zin have dfsasc.rnus consequences f4)r ~m aircraft The i mport'*nce of 

the ftJcl t,unks- to the fuel system c~n be seen in guidance provided 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 experience as a mechanic ~md an FAA t::mi}l (l)'ec ~ it is my 

opinion that fabt.ieating 'l fud lank out of an nh1minum sJvdl by \Veld1ng (111 aU~chments and 

metal plates ((H;losc openings is m1t a"tl iJG·cepicd practice, . .us that term is used in ~he FAR U 

dt,:dinlticm;s Qf major alteratiotl and major repaur. · 

19. Each of the :n:.;nsons dcsc:dhed above~ standing a[onc, Wfftli!d n:ndc:r the ahe ratkm t1 muj or 

alterat\cm. 

20. The work p.:.:rformcd that cuhnina(ed in the February 24,201 I; rc.furn to servi-ce was ;,m 

pJter~l~ton. not a rcp.ak lhYV.'eVCr, iflt '\vas a repair. it w~Ytdd be a majo: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:pui r: 

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:dltics affeeting ~lt\vtlrlhjm:ss~ m 

{2) Tbal is nut done acc·ordit1g 10 ncccptcd practices or cannot 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 of the reasons dl:scusstco,:,l abuvc as t<J 

why tbc alteration 'vas a m~lior ai:LcmHon are nls(l reasons ,,.,·hy.this \Vould he~- major repair, if it 

had been a r-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 (Jttilc fue] system is a ml]!jor, a[~cmfion. This example is :tl{)C. lllppficable to repairs, 

Hov;I·CV<.~r, Appendix A also pr<WEdes ~hat cm::h and every repair of a fud tank is a major repair.. 

23. E:;u::h <.tnhc rcas;.)ns ickntit1ed lJlb(JVc, :standing a:lon:e, would render the \V.C)rk a mojor 

t>epai r', if r¢ ·was a repair. 

24. The ahemtl()11 ofN390TH is .not de.seribcd i.rn any maintcM!lc.e rn~mu~d or instructto1t:> f{.fr 

continued airwnrthincss for the B~ I 7G. 
2.5. The rnc!hQds, techtliqucs:, a:r1~ practices \JSOO by RcsJ}()t11det11t ht i:tlteriing Ute alrcmfc are not 

ncoe:ptubl c to the Adin1 nlstmtor, Retpondent' s ahcnuion in trod u-r:e{E numcro us potem1al- and 

aciua] -weaknesses [nto the atrcrafr:, mrnd did not incf!.lde che sort of inspeci:ions: necessarJt t<-1 

verify that the new fu.e) :(~mks w·cre capable of wi.uhstond.iJjg the stresses. of flight 

26. The aJ teratim1 afNJ9HTI"f w.ll!S not chnc in sucl1 a ·way as ·fo resto:re the cond.ihun of the 

aircmil to at !c-ast its origlt:Jat Qr properly aUerod condition \\1th :t~Sflett h) rc::si.sh:moc to ,·ibrnticm 

and detcJ:ior~tion ,t\jJd other qltalitics affcc;t]ng airwnnhiness, All ofthc factors :rnendoned itl 

paragr41ph 14 are pc:rtincnt her£, 11m exrensive wcldln:g on the ncvt ft1el tank~ made lilcm 

V!1] ocr•~b]c to (be stresses of fHgjlt jr~ Wfl)"Slh<ti the migfna[ t<mks \'VCJ'e not, f.lil1d !his rc:mitcd in 

the rapid failm.e- of one 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 not l(;onfbrm to hs C}':pe ocrtificarc or tYfle M.sltgtt because rhe B··i 70's 

design never corHcmp)1).ted taking an ah:uuinum shell! ·with numerous holes in i~, fi:lht&e~ting 

componenM: .}iJld welding them onto that she!]., .!Jind them using lt as a 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.1r 2'eflatffl or 

modi.11cataons nat Jislcd in tile :Jircrafi's nt..'linEt.~t'liilt:!Ce m.anmds, the rt~pair or modJUcaJion must 

fir"l be presented to Civil Am'Onanti-cs Adminislnd:ion (now the. Federa~ Avim1ou 

Administr.at~on). 

28. Tile aircraft did not confonn 11.0 .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;sc the 'thcration performed! w::J.$ .nol .an appmved .C)r- acceptl':!hlc 

fonn of -alteration. lhe mircraft did not conform to i.E:s type certificate or 1Yfl.Z: desigo because Ml'. 

Schneider d.id not lba:ve the lnspect'ion A uthoriza1£on r-cqurroli ln reu.u·n lhe ~i~cm:f!t ~.o scrv.ice after 

a major nheratron. The aircraft dic1 ilOt. conform to its type: certifief,ltc or type design bee:a~ no 

FAA Fonn .337 w·as executed for !he maJor aheratJ(iU. Tbe <lirtraflt djd 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:rac ton. 

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"rtHicntc or type design:. 

30. The aircraft ':v'as unalrwonhy a1ler the February 24, 2011, alt.cmlion because it \'Vas not in 

a condition for s~fe ;opernJion. lmproper fuel tanks presenl. numerous hazards to .gn Jllir.ct~tfi -

most J1ota.b3y,. leaking fuel c~n result in h)S:S: of engine power and 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 of the l:;-ebrnnry 24, 20'11 .alteration ofahe aircn1ft. For Chc r-easons d·esc:rthed above. 

\'~icJding can inCJ't)L"hJce- numerous \Vcaknc~scs inti! an ol.umi:num component, :md ~he. safdy •Of 

such a heavlfi)' weldt;:d Jiucl tank '-"'as a[ ways questiolti1hlc. That the weldi.t1g fi:tUed S(l {luiGikly 

det~l.Otlstrnces Httlt the polcntaal weaknesses had~ in fad; been introduced. His my opinion that, 

bectt.usc- of the :impropm· alteratiot::~. NJ90TH was not in a coa)dusion for safe operation after lhe 

jnstaUacion ofrhe. a! urntnum fuei trm.ks. 
( 

31. I have rcvie:\1\.'e.d the, m<rilltetKl1lCC rc.cord:s for N3 90TH pe:rtai ning. to the F c brt)iiTY 24. 

:2 01 t , . .allemdon. No !::',A..A F onu 3 3 7 '\'aS ,complet·ed for this work. 

3 2. r ha·ve feviev•ed Mr. Sdtneic.k't' s description of the l111aimenarlc~ ·work. perf•)rmed on UK~ 

June 2Dll fuel ~eak. The mainlemmc.>t: performed was not ccmtaioed ln the Hircr~1ft maintenance 

mmmal. The maintenance perfonued ·wns not CQndOllned ii~ any instrm:tio(]s for con~:irnued 

airworthiness for the aircrall, 'H,e Jrtl'l:intenn.nce performed \Vas nof other.:,risc accep~able t{tt ~he 

/\dm i nistrntor. 

33. The June 20 l t maintenance on the fabric:~1<:d fuel ~<Hlks ·was not othcn:..,ise acceptahlc: to 

the Administrn:tG"~r due to •he natutC of111tc componcillt being n:pa3red. Th:e fuel tank wa.~:; ati 

unappr()\;ed (NUll. tM~ shou !d never luwc been installed on the a1 rcr-aft. Thc.·tc w-ere no methods.~ 

techniquc..s~ or practices acceptable to d1e, Administr.alor for rcpt~iring 1hc fuel tanks becau.s.>e th-e 

fuel umks themselves ·were ui'laccepf~tbie. 

34. Un addition+ even if the nature of the t\lel tedlt:s \>tas set aside~ the. repair v;ould not h•wc 

been pet·forme-<1: ush~g n~elhods, ltXImigm;s~ or prac:tkcs acceptable to the 1\(hnintslm~.or. As Mr. 

Schneider itltiki~tcs in his deposition, the Wt1rk c~llld have beenl1clitC in a less riskx manner, but 

he: chose to opt for a quick flx u~1 ordc-.r co meet. a :schedule rather than the safe,. pmp.cr repair. Tbc 

fuel tMks should hnvc been removed frmn the ai rCJ'.tlft j~)r ~he rcp21i r1 but. were not. Se.alant shrmld 

h21vc boc:n applied from the: Ln.side, but was h~stcad applied from the outside of the 1n11kapplying the secnl.t~m •o ~he i;n.s'idc of tbc tank em:ure;s, that the pressure, (lf !he fm:l in the hmk: 

serves to p1JSh ~he sealant into ~my cracks, rather than push 1hc $/Ca[an~ out Mr. Schneider 

performed only :a J imhed •Asual i t1spec~!on t)t11 Chc repair duo ugh the boost rmrup access door .• 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~ l d h(~Vc been a.cti vatcd). 

3.5. In. <lddition to the unainvorthiness: cauSt::d by the Fchm~try 24; 2011. altermion, N390lH 

\\'U:S tutairwortby when it opm;aled on June 13. 2011,. because ofthc hnprop~r matmen;)ncc 

pcrfcmned by Mr. Schneider. Not ooly '"'aS the n: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"fCs type C(:rti~icatc. Further; it \vas a majm· :repair und :Mr. Schneider did not hold the 

lnspcc1:ion Aulhoriz.ation requir€!d to r.ehtm thc ~ircrnft to service after the resl~i1·,. and t~(l f'AA 

F•Ol'tl1 337 W<~S C::Xt:'Ct!'lc<i. 

Furth-er amant saye1b nat~ght 
.. 
U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

vs. 

LIBERTY FOUNDATION, 

Respondent. 

Docket No. 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 administer oaths, Donald 

Victor Dodge, did state under oath after being properly sworn, that the following statement is 

true and accurate: 

1. I am over the age of 18 and I understand the obligations of an oath. 

2. I am currently employed with the Federal Aviation Administration as a Regional 

Specialist (Maintenance) at the Southern Regional Office in College Park, Georgia. 

3. I have 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 

Certificate with Airframe and Powerplant Ratings since 1976, an Inspection Authorization since 

1979. I have also held a pilot certificate since 1972. From 1976 through 1997 I worked at, 

owned, and operated Dodge Aircraft, a fixed-base operator performing general aviation 

maintenance and alteration services, including regular work on vintage and classic aircraft. 

5. I am familiar with the facts of this case, concerning the work performed on N390TH's 

fuel system in late 2010 through early 2011, culminating in a February 24,2011, return to 

service, and also concerning the June 13,2011, fuel leak in one ofN390TH's new fuel tanks. 

The material I have reviewed includes the deposition ofthe mechanic who performed the work 

in question, photographs of the winter 2010-11 work in progress, photographs and video of the 

~GOVERNMENT 

i EXHIBIT 

i Htl 
June 2011 fuel leak, applicable portions of the maintenance records for N390TH, applicable 

portions of the B-170 structural repair handbook, maintenance and erection handbook, 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 of six thick, self-sealing bladder fuel tanks, 

three in each wing. Each bladder fuel tank was installed in an aluminum shell that surrounded the 

bladder tanks and was attached to the interior of the wing by straps. All attachments between the 

fuel tanks and the rest of the 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 of the aluminum shells was removable, so it could be 

taken on or off the bladder fuel tank. 

9. In general terms, the work on the fuel system ofN390TH that culminated in the February 

24, 2011, return to service consisted of removing the bladder fuel tanks entirely, fabricating a 

filler neck attach point, a fuel boost pump attach point on four of the six fuel tanks, a fuel 

quantity transducer mounting point, fuel system line attachments and plates to seal the former 

fuel bladder mounting points, welding those attachments and plates onto the aluminum shell, 

welding shut the removable end of the shell, and connecting each of the six shells into the 

existing fuel system as fuel tanks. 

10. Although some B-17 aircraft were manufactured with solid metallic tanks, N3 90TH was 

not. Further, no B-17 was manufactured with a solid metallic tank consisting of an aluminum 

shell with holes that had been plugged by welding a variety of fabricated attachments and plates 

to the shell, or a manufactured with a removable end that was then welded closed. 

11. This work was an alteration, not a repair, because it changed the design of the aircraft and 

its components, and was not simply a restoration of the aircraft to an undamaged state. 

12. The alteration was a major alteration. As stated in section 1.1 ofthe Federal Aviation 

Regulations (Definitions): 

Major alteration means an alteration not listed in the aircraft, aircraft engine, or 

propeller specifications-

(1) That 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 or cannot be done by 

elementary operations. 

13. There are several reasons why the alteration was a major alteration. Within four months 

of the alteration, the welding cracked in one of the new tanks, resulting in a fuel leak. This was 

an appreciable effect on a quality affecting the airworthiness of the aircraft. Thus, the alteration 

was a major alteration. 

14. Additionally, even setting aside the fuel leak, the removal of the bladder fuel tank could 

have had an appreciable effect on the airworthiness of the aircraft and its fuel system. The 

alteration increased the fuel capacity of the aircraft, affecting weight and balance and possible 

stresses placed on the wing structure. The new aluminum 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 way to the stresses of the in-flight motion of thousands of pounds of aviation 

fuel as a semi-rigid bladder tank would- baffles should have been incorporated into any hardshell fuel tank design for tanks of these sizes. The newly fabricated fixtures and attachments may 

or may not have been of equal quality with the components they were replacing. The fabricated 

fixtures and attachments, even assuming that they were of equal quality to the parts they were 

replacing, had changed from being attached to the semi-rigid bladder tank to being attached to 

the rigid aluminum tank, which could impact how they responded to stress during flight. All of 

these problems are exacerbated because the aluminum tanks were not simply solid, formed 

aluminum tanks, but had been extensively welded, introducing numerous potential weaknesses 

into the system - as can be seen by the cracking that developed in one of the fuel tanks in less 

than four months, the weld seams are a source of structural weakness and can make the tank 

more susceptible to issues with vibration and stress. Welding can also increase the possibility of 

corrosion. The weaknesses that can 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 permissible under appropriate 

circumstances, the same potential weaknesses in the resulting component are still present and 

must be accounted for. 

15. Also, any alteration of a fuel tank is a major alteration. FAA Order 8900.1 provides 

extensive guidance to Aviation Safety Inspectors in the performance oftheir duties. One ofthe 

possible duties of an ASI is field approvals of major alterations. Accordingly, one of the job aids 

in the 8900.1 is a list of major alterations, and whether the required approval can be a field 

approval, must be an engineering approval, or requires a Supplemental Type Certificate. On the 

list of major alterations is any change in a permanent fuel tank, or installation of a new fuel tank. 

17. Further, the fabrication of new fuel tanks out of the aluminum shells was a major 

alteration because fabricating components and welding are not an elementary operation. 

18. I am aware ofthe provision in Appendix A of Part 43 ofthe Federal Aviation Regulations 

that lists changes in the basic design of a fuel system as an example of a major alteration. The 

replacement of the bladder fuel tanks with fabricated aluminum fuel tanks was a change in the 

basic design of the fuel system. While_ someone could mechanically list dozens of components 

that were not replaced in replacing the fuel tanks, this does not mean that the replacement of the 
fuel tanks was not a change in the basic design of the fuel system. Fuel tanks, and their ability to 

perform properly, are absolutely vital to the safe functioning of a 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 by the Administrator to 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 

opinion that fabricating a fuel tank out of an 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. 

19. Each of the reasons described above, standing alone, would render the alteration a major 

alteration. 

20. The work performed that culminated in the February 24,2011, return to service was an 

alteration, not a repair. However, if it was a repair, it would be a major repair. As stated in 

section 1.1 ofthe Federal Aviation Regulations (Definitions): 

Major repair means a repair:. 

(I) That, if improperly 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 or cannot be done by 

elementary operations. 

21. The distinction between a major repair and minor repair largely tracks the distinction 

between a major and minor alteration. As such, all but one of the reasons discussed above as to 

why the alteration was a major alteration are also reasons why this would be a m~or repair, if it 

had been a repair. · 

22. The one exception is regarding the example in Appendix A about how a change in the 

basic design of the fuel system is a major alteration. This example is not applicable to repairs. 

However, Appendix A also provides that each and every repair of a fuel tank is a major repair. 

23. Each of the reasons identified above, standing alone, would render the work a major 

repair, if it was a repair. 

24. The alteration ofN390TH is not described in any maintenance manual or instructions 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 -weaknesses into the aircraft, and did not include the sort of inspections necessary to 

verify that the new fuel tanks were capable of withstanding the stresses of flight. 
26. The alteration ofN390TH was not done in such a way as to restore the condition of the 

aircraft to at least its original or properly altered condition with respect to resistance to vibration 

and deterioration and other qualities affecting airworthiness. All of the factors mentioned in 

paragraph 14 are pertinent here. The extensive welding on the new fuel tanks made them 

vulnerable to the stresses of flight in ways that the original tanks were not, and this resulted in 

the rapid failure of one of the tanks. 

27. N390TH was unairworthy because it did not conform to its type certificate or type 

design. The aircraft did not conform to its type certificate or type design because the B-17G's 

design never contemplated taking 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 now the type certificate for the aircraft, requires that for repairs or 

modifications not listed in the aircraft's maintenance manuals, the repair or modification must 

first be presented to Civil Aeronautics Administration (now the Federal Aviation 

Administration). 

28. The aircraft did not conform to its type certificate or type design because it had not been 

restored to its original or properly altered condition. The aircraft did not confo_rm to its type 

certificate or type design because the alteration performed was not an approved or acceptable 

form of alteration. The aircraft did not conform to its type certificate or type design because Mr. 

Schneider did 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 or type design because no 

FAA Form 337 was executed for the major alteration. The aircraft did not conform to its type 

certificate or type design because no approved technical data was used in performing the 

alteration. 

29. Each of the above reasons, standing alone, meant that N390TH was unairworthy because 

it did not conform to its type certificate or type design. 

30. The aircraft was unairworthy after the 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 can result in loss of engine power and is also a severe fire hazard. As 

described by Mr. Schneider in his deposition, the fuel leak that occurred in June 2011 was a 

direct result of the February 24, 2011 alteration of the aircraft. For the reasons described above, 

welding can introduce numerous weaknesses into an aluminum component, and the safety of 

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 opinion that, 

because of the improper alteration, N390TH was not in a condition for safe operation after the 

installation of the aluminum fuel tanks. 

31. I have reviewed the maintenance records for N390TH pertaining to the February 24, 

2011, alteration. No FAA Form 337 was completed for this work. 

32. I have reviewed Mr. Schneider's description of the maintenance work performed on the 

June 2011 fuel leak. The maintenance performed was not contained in the aircraft maintenance 
manual. The maintenance performed was not contained in any instructions for continued 

airworthiness for the aircraft. The maintenance performed was not otherwise acceptable to the 

Administrator. 

33. The June 2011 maintenance on the fabricated fuel tanks was not otherwise acceptable to 

the Administrator due to the nature of the component being repaired. The fuel tank was an 

unapproved part that should never have been installed on the aircraft. There were no methods, 

techniques, or practices acceptable to the Administrator for repairing the fuel tanks because the 

fuel tanks themselves were unacceptable. 

34. In addition, even if the nature ofthe fuel tanks was set aside, the repair would not have 

been performed using methods, techniques, or practices acceptable to 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 order to meet a schedule rather than the safe, proper repair. The 

fuel tanks should have been removed from the aircraft for the repair, but were not. Sealant should 

have been applied from the inside, but was instead applied from the outside of the tankapplying the sealant to the inside of the tank ensures that the pressure of the 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 repair through the boost pump access door, but 

the inspection should have been more extensive (for example, the fuel system should have been 

pressurized and the boost pumps should have been activated). 

35. In addition to the unairworthiness caused by the February 24, 2011, alteration, N390TH 

was unairworthy when it operated on June 13, 2011, because of the improper maintenance 

performed by Mr. Schneider. Not only was the repair improperly performed, it was also a repair 

that was not listed in the maintenance manual and was therefore not permitted under the 

aircraft's type certificate. Further, it was a major repair and Mr. Schneider did not hold the 

Inspection Authorization required to return the aircraft to service after the repair, and no FAA 

Form 337 was executed. 

Further affiant sayeth naught. 

I hereby swear or affirm that the above is accurate and true to the best of my knowledge. 

My Commission Expires: