Customer Services Directorate

A318 / A319 / A320 / A321

Fuel Airworthiness Limitations

 95A.1931/05

 26 Aug 2010

Issue 4

AIRBUS OPERATIONS SAS 2010. All rights reserved. Confidential and proprietary document. 

This document and all information contained herein is the sole property of AIRBUS OPERATIONS SAS. No 

intellectual property rights are granted by the delivery of this document or the disclosure of its content. This 

document shall not be reproduced or disclosed to a third party without the express written consent of AIRBUS 

OPERATIONS SAS. This document and its content shall not be used for any purpose other than that for which it 

is supplied
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AIRBUS OPERATIONS SAS 2010. ALL RIGHTS RESERVED. CONFIDENTIAL AND PROPRIETARY DOCUMENT

RECORD OF REVISIONS

Issue Date Reason for revision Approvedby EASA 

1

2

3

19 Dec 05

08 Jul 08

01 Mar 10

First Issue

Section 0: 

Document applicability updated to include 

A320-215 and A320-216

Section 1: 

Correction of Fuel ALI 281800-01-1 task title to 

be in line with AMM task title (deletion of the 

words ‘centre box’)

Applicability of both tasks clarified (it previously 

stated ‘ALL’). The words ‘(aircraft fitted with a 

centre wing tank)’ deleted from both task 

descriptions.

Section 2: 

Applicability of CDCCLs clarified by identifying 

applicability of individual ESPM, AMM and CMM 

references. 

CDCCL 2: Ref to ESPM 20-33-11 deleted.

CDCCL 3: Ref to 28-42-15 deleted. Ref to 28-

21-51, 28-22-51 and 28-42-47 added.

‘-400’ added to all AMM references. 

CDCCL 4: Applicability ‘ALL’ added.

Section 0 

The document introduction is extended to 

include the latest compliance requirement 

references for Ignition Prevention and for 

Flammability Reduction Systems.

References to Flammability Reduction 

requirements included.

Section 1:

Maintenance/Inspection Tasks 47-00-00-01-1, 

47-00-00-02-1, 47-00-00-03-1, 47-00-00-04-1 

and 47-00-00-05-1 added. 

Section 2:

CDCCL 3: Ref to 28-12-47, 28-21-43 and 28-

43-22 added

CDCCL 4: Ref to 28-20-40 and 28-24-11 added

CDCCL 5: New CDCCL added

CDCCL 6: New CDCCL added

CDCCL 7: New CDCCL added

Approved by EASA

under reference 

EASA.A.C.02456

on 14 Mar 2006

Approved by EASA 

under reference 

EASA.A.C.10876 

on 19-Dec-2008.

Approved by EASA 

under reference 

10029203 REV. 1 

on 22-Mar-2010
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AIRBUS OPERATIONS SAS 2010. ALL RIGHTS RESERVED. CONFIDENTIAL AND PROPRIETARY DOCUMENT

Issue Date Reason for revision Approved by EASA 

4 26 Aug 10 Section 0: 

Categories of Maintenance / Inspection tasks 

extended to include components having a life 

limitation. 

Section 1:

Table 1 added. Valve names in tasks 470000-

01/02/03/04-1 amended from Dual Flow Check 

Valves to Dual Flapper Check Valves. 

Applicability of tasks 470000-01/02/03/04/05-1 

amended.

Table 2 added. ASM included in Table 2.

Section 2:

CDCCL 6. Valve name amended from Dual 

Check Valve to Dual Flapper Check Valves.

Approved by EASA 

under reference 

EASA.A.C10031572 

on 26-Aug-2010.
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LIST OF EFFECTIVE PAGES

SECTION PAGE DATE

ROR 1 ROR 26-AUG-10

2 ROR 26-AUG-10

LEP 1 LEP 26-AUG-10

TOC 1 TOC 26-AUG-10

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2 26-AUG-10

3 26-AUG-10

4 26-AUG-10

5 26-AUG-10

6 26-AUG-10

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AIRBUS OPERATIONS SAS 2010. ALL RIGHTS RESERVED. CONFIDENTIAL AND PROPRIETARY DOCUMENT

TABLE OF CONTENTS

SUBJECT SECTION N

Introduction 0

Scope

Applicability

Criteria for identification

Handling of Fuel ALIs

Exceptional Short-Term Extensions

Maintenance / Inspection Tasks 1

Critical Design Configuration Control Limitations 2
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AIRBUS OPERATIONS SAS 2010. ALL RIGHTS RESERVED. CONFIDENTIAL AND PROPRIETARY DOCUMENT

SECTION 0 - INTRODUCTION

1. SCOPE

This document contains the Fuel Airworthiness Limitations that arise from compliance with 

JAA’s Interim Policy on Fuel Tank Safety (INT/POL/25/12), FAA’s Special Federal Aviation 

Regulation (SFAR) 88 and FAA’s 14 CFR 26.33. They have been derived in accordance with 

JAA’s draft Temporary Guidance Leaflet (TGL) 47, FAA’s Advisory Circular (AC) 25.981-1C

and FAA’s Advisory Circular (AC) 25.981-2A. The nomenclature and means of promulgation 

follow the FAA’s memorandum ref PS-ANM100-2004-10029 ‘Policy Statement on Process for 

Developing SFAR 88-related Instructions for Maintenance and Inspection of Fuel Tank 

Systems’. This latter document has been jointly developed between FAA and JAA to ensure a 

unified approach.

This document is referenced in the ALS Part 5 – Fuel Airworthiness Limitations, which, together 

with other ALS Parts, contributes to the demonstration of compliance with JAR 25, Appendix 

H25.

IMPORTANT: At first delivery of an aircraft configuration into an operator’s fleet, the 

requirements given in this document are mandatory, except in so far that 

interval escalations can be justified in accordance with the procedure stated 

herein. If a more restrictive Fuel ALI is issued on an aircraft configuration 

already in service, the requirement for existing operators to follow the revised 

FAL document will normally be mandated by Airworthiness Directive 

(Consigne de Navigabilité). 

Non-compliance suspends the validity of the Airworthiness Certificate.

The identification of Fuel Airworthiness Limitations in no way diminishes the importance of other 

tasks and practices associated with the fuel system. Changes to these are subject to normal 

practices and procedures between the operator and his national authorities.

This document does not take into account Airworthiness Directives (Consigne de Navigabilité) 

which, if issued against an existing Fuel Airworthiness Limitation, supersede the specific 

requirement given in this document.
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2. APPLICABILITY

The document covers the following A318/A319/A320/A321 models:

- A318-111 - A319-111 - A320-111 - A321-111

- A318-112 - A319-112 - A320-211 - A321-112

- A318-121 - A319-113 - A320-212 - A321-131

- A318-122 - A319-114 - A320-214 - A321-211

- A319-115 - A320-215 - A321-212

- A319-131 - A320-216 - A321-213

- A319-132 - A320-231 - A321-231

- A319-133 - A320-232 - A321-232

- A320-233

3. CRITERIA FOR IDENTIFICATION

Fuel Airworthiness Limitations are items arising from a systems safety analysis that have been 

shown to have failure mode(s) associated with an ‘unsafe condition’ as defined in FAA’s memo 

2003-112-15 ‘SFAR 88 – Mandatory Action Decision Criteria’. These are identified in Failure 

Conditions for which an unacceptable probability of ignition risk or an unacceptable increase in 

fuel tank flammability exposure could exist if specific tasks and/or practices are not performed in 

accordance with this document.

Having identified the need for the task through detailed systems analysis (including that required 

for JAR 25.1309 compliance), the repeat interval for any task required on a regular basis was 

determined through engineering judgment. This judgment was largely based on existing 

experience of the condition of the component and its installation combined with a desire to avoid 

tank entry specifically for the purpose of performing a Fuel ALI. 

Fuel ALIs fall into two categories:

3.1 Maintenance / Inspection Tasks

The repetitive tasks are similar to Certification Maintenance Requirements but since they have 

been identified after initial certification of the design, in accordance with EASA’s AMC 25-19 and 

FAA’s AC 25-19, they cannot be identified as CMRs. These tasks are listed in Table 1.

Fuel ALIs may include life limitations. These are associated with components that exhibit 

functional degradation characteristics at an identifiable age and whose failure could contribute to 

an unsafe condition of the aircraft or lead to an inability to maintain system performance to 

certification levels. These tasks are listed in Table 2, thus ensuring a common approach with 

those items with life limitations identified in ALS Parts 1 & 4.

These tasks must be included in an operator’s approved maintenance program/ schedule. The 

task interval may be quoted in a usage parameter (FH, FC or Calendar time) depending on the 

cause of potential degradation that, if not detected and addressed, could lead to an 

unacceptable risk.
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3.2 Critical Design Configuration Control Limitations (CDCCL)

A CDCCL is a limitation requirement to preserve either a critical ignition source prevention 

feature of the fuel system design or a critical design feature of the flammability reduction 

system that is necessary to prevent the occurrence of an unsafe condition.

The purpose of the CDCCL is to provide instructions to retain the critical ignition source 

prevention or critical flammability reduction feature during configuration change that may be 

caused by alterations, repairs, or maintenance actions. 

A critical ignition source prevention feature may exist in the fuel system and related 

installation or in systems that, if a failure condition were to develop, could interact with the fuel 

system in such a way that an unsafe condition would develop in the fuel system without this 

limitation.

A critical feature that contributes to the integrity of the flammability reduction system may exist 

in the fuel tank inerting system and related installation that, if not maintained, could 

compromise the design and lead to an unsafe condition in the fuel system.

4. HANDLING OF FUEL ALIs

4.1. Maintenance / Inspection Tasks

4.1.1 Table 1 - Repetitive Tasks

Unless otherwise stated, the tasks and intervals specified in Table 1 of the Fuel Airworthiness 

Limitation document are mandatory and cannot be changed, escalated or deleted without the 

concurrence of the Primary Certification Authority (EASA). 

Where explicitly stated, task intervals may be adjusted in accordance with an operator's 

approved escalation practices or an approved reliability program, but the task content may not 

be changed or deleted without prior Primary Certification Authority (EASA) approval. 

This statement has been agreed on the basis that operators with approved escalation 

practices or an approved reliability program make adjustments to their maintenance programs 

based on data collection and analytical techniques. It has been demonstrated that the use of 

such methods to manage a maintenance program does not give rise to undue escalation.

Furthermore, with respect to tasks requiring tank entry, the interval quoted in this document is 

intended to allow operators to perform the task during an extended hangar visit during which 

tank entry is already likely to be required for accomplishment of structural and zonal 

inspections. Tank entry specifically to accomplish a Fuel ALI should be avoided in view of the 

fact that degradation could be caused by the human intervention in a restricted zone. Such 

tank entries need to be kept to a minimum.
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4.1.2 Table 2 - Life Limits

For those Fuel ALIs associated with a component with a life limitation, listed in Table 2, the

recurrent maintenance requirements are applicable no later than the component, not the 

aircraft, reaching the airworthiness limitation.

In order to maintain aircraft airworthiness, it is mandatory to replace components/items listed 

in Table 2 at, or prior to, whichever of the life limitations occurs first (if applicable), after any 

necessary adjustment of the stated life limitations.

It is necessary therefore, to assure traceability and monitoring of the components/items listed 

in the Table 2.

Non-compliance with these requirements could suspend the validity of the Certificate 

of Airworthiness.

For a given component/item of the Table 2, new Part Numbers (PNRs) may be introduced in 

the future. These new PNRs may not be listed in the Table 2 of the current revision of the 

ALS Part 5. However, it is recommended to maintain traceability and monitoring of such 

components/items whatever their Part Number in case of future introduction in the ALS Part

5.

Note: In the context of the ALS Part 5, traceability means records that clearly 

demonstrate the history of components/items back to initial entry into service, so 

that airworthiness limitations are accurately applied. Traceability records may 

comprise, but are not limited to, the following:

Application history (aircraft type, model, WV, MSN i.e. Manufacturer Serial 

Number, etc),

Maintenance actions carried out (Airworthiness Directives, modifications, repairs, 

inspections, etc)

Life accumulation (accounting for any individual aircraft to which a component/an 

item may have been fitted).

4.2.1 CDCCLs

Operators are responsible for ensuring that their internal documentation is amended to reflect 

the data contained within this section and provides appropriate text to highlight the existence 

of each CDCCL. Such identification is necessary in the instructions used by the person 

performing an installation, alteration, repair or modification so as to minimize the risk that the 

work performed compromises the original design criteria.

Regulatory oversight of the operator’s compliance with this mandatory requirement is based 

on the appropriate identification of the CDCCL in the accomplishment instructions associated 

with the installation, alteration, repair or modification.
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5. EXCEPTIONAL SHORT-TERM EXTENSIONS

This paragraph addresses repetitive Maintenance/Inspection tasks identified in Table 1. It 

does not apply to component life limitations identified in Table 2.

Since Fuel ALI Maintenance / Inspection intervals listed in Table 1, are generally not 

determined from calculations in which failure rate data is known with a high level of 

confidence, an exceptional short-term extension for a specific Fuel ALI interval may be made 

on one aircraft for a limited period of time without jeopardising safety.

The term 'exceptional short-term extension' is defined as an increase in a Fuel ALI interval 

that may be needed to cover an uncontrollable or unexpected situation. Repeated use of such 

extensions, either on the same aircraft or on similar aircraft in the operator's fleet, should not 

be used as a substitute for good management practices.

Unless noted adjacent to the task, for all Fuel ALIs identified in this document, it has been 

accepted by the Primary Certification Office (EASA) that short-term extensions up to the 

following maximum values may be granted without consultation with that office. Requests for 

extensions in excess of these values must be submitted with full justification to the Primary 

Certification Office (EASA) such that approval, if granted, can be given prior to their use. 

5.1 Fuel ALIs controlled by Flight Hours (FH)

Extensions up to 10% or 500FH (whichever is the lesser) may exceptionally be granted on 

Fuel ALI intervals quoted in terms of flight hours.

5.2 Fuel ALIs controlled by Flight Cycles (FC or LDGS)

Extensions up to 5% or 250FC (whichever is the lesser) may exceptionally be granted on Fuel 

ALI intervals quoted in terms of flight cycles or landings.

5.3 Fuel ALIs controlled by Calendar Time (MTHS or MO)

Where the repeat interval is 12 months or less, extensions up to 10% or 1 month (whichever 

is the lesser) may exceptionally be granted on Fuel ALI intervals quoted in terms of months.

Where the repeat interval is greater than 12 months but less than 3 years, extensions up to 2 

months may exceptionally be granted.

Where the repeat interval is 3 years or greater, extensions up to 3 months may exceptionally 

be granted.

It is the operator's responsibility to identify appropriate procedures with his local regulatory 

authority for the control and development of his maintenance program.

This paragraph in the Fuel Airworthiness Limitation document is written to confirm to the local 

regulatory authority that exceptional short-term extensions of Fuel ALI intervals are 
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permissible. Approval of such extensions rests with the local authority in the same way as it 

does for any other scheduled maintenance task interval extension.
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SECTION 1

MAINTENANCE / INSPECTION TASKS

TABLE 1 – Repetitive Tasks

TASK REF TASK TITLE INTERVAL APPLICABILITY

1 281800-01-1 Functional check of tank vapour seal and vent 

drain system.

6 Years A318 ALL

A319 ALL

A320 Post 20024

A321 ALL 

2 281800-02-1 Detailed inspection of vapour seal. 6 Years A318 ALL

A319 ALL

A320 Post 20024

A321 ALL

3 470000-01-1 Operational Check of DFSOV, Dual Flapper 

Check Valves and NEA line for leaks.

12,000 FH Post 38062

Or

Post SB 47-1002

Or

Post SB 47-1004

4 470000-02-1 Operational Check of both Dual Flapper Check 

Valves for leaks.

60,000 FH Post 38062

Or

Post SB 47-1002

Or

Post SB 47-1004

5 470000-03-1 Operational Check of Dual Flapper Check Valves 

for reverse flow and NEA line for leaks.

12,000 FH Post SB 47-1001

Pre SB 47-1002

Or

Post SB 47-1003

Pre SB 47-1004
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MAINTENANCE / INSPECTION TASKS

TABLE 1 – Repetitive Tasks (continued)

In accordance with Section 0, para 4.1, it is herewith confirmed that the intervals of the tasks 

mentioned in the above table may be adjusted in accordance with an operator's approved 

escalation practices or an approved reliability program, but the task content may not be changed 

or deleted without prior Primary Certification Authority (EASA) approval.

TABLE 2 – Life Limits

TASK REF TASK TITLE INTERVAL APPLICABILITY

6 470000-04-1 Operational Check of Dual Flapper Check Valves 

for reverse flow

12,000 FH Post 38195

Pre SB 47-1002

Or

Post 38195

Pre SB 47-1004

7 470000-05-1 Remove ASM and return to Vendor for workshop 

check

4,000 FH Post 38062

Pre 151529

(SB 47-1005)

Or

Post SB 47-1002

Pre 151529

(SB 47-1005)

Or

Post SB 47-1004

Pre 151529

( SB 47-1005)

COMPONENT PART NUMBER

(P/N)

LIFE LIMITATION APPLICABILITY

Note: ‘XX’ at the end of the P/N stands for any number between 00 and 99

Air Separation 

Module (ASM)

2060017-1XX 27000 FH (component flying hours) Post 38062

Post SB 47-1002

Post SB 47-1004
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SECTION 2

CRITICAL DESIGN CONFIGURATION CONTROL LIMITATIONS

CDCCL Requirement Reference Applicability

1 Air gap between a 

fuel quantity 

indicating probe and 

the aircraft structure.

Critical to prevent spark generation during lightning 

strike conditions and must not be compromised 

The gap stated in the relevant maintenance 

procedure in the AMM must be achieved during 

installation of a fuel quantity probe.

AMM 

28-42-15-400 ALL

2 Separation of fuel 

quantity and level 

indicating system 

wiring from other 

wiring.

To prevent cross coupling of high voltage transients 

and thereby keep unsafe ignition energies from 

inside the tank it is required that operators obey the 

wire routing and separation standards given in the 

Electrical Standard Practices Manual (ESPM).

ESPM 

20-10-00

20-33-20

20-33-21

20-33-22

ALL

ALL

ALL

ALL

3 Direct bonding on 

items of equipment 

inside a fuel tank. 

Direct bonding is critical to prevent spark generation 

during component failure and lightning strike 

conditions and must not be compromised 

Direct bonding in fuel tanks must be carried out 

during component installation to the appropriate 

bonding method and standard stated within the 

installation procedure in the AMM.

AMM 

28-11-37-400

28-11-41-400

28-12-41-400

28-12-45-400

28-12-46-400

28-12-47-400

28-13-43-400

28-15-41-400

28-21-42-400

28-21-43-400

28-21-51-400

28-21-52-400

28-22-51-400

28-25-41-400

28-25-42-400

28-25-46-400

28-25-52-400

28-42-16-400

28-42-46-400

28-42-47-400

28-42-48-400

28-43-21-400

28-43-22-400

57-27-11-400

A321 Post 25453

ALL

ALL

ALL

ALL

ALL

ALL

ALL

ALL

ALL

ALL

ALL

ALL

ALL

ALL

ALL

ALL

A318, 19, 20

A321

A321

A321

ALL

ALL

ALL
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CDCCL Requirement Reference Applicability

4 Safety critical 

features of fuel 

pumps 

These features must be maintained throughout the 

full life of the fuel pump to avoid the possibility of 

generation of an ignition source by overheating or 

sparks caused by arcing, friction etc.

Repair and overhaul of fuel pumps must be carried

out in accordance with the equipment 

manufacturer’s maintenance instructions or other 

maintenance instructions acceptable to the 

certifying authority.

CMM 

28-20-40

28-21-51

28-22-19

28-24-11

A319, 20, 21 

(with ACT)

ALL

ALL

ALL

5 Centre fuel tank 

volume and 

ventilation flow rate

The volume of the centre fuel tank and the flow rate 

of the ventilation system must be maintained at 

values which, when used in the determination of the 

fuel tank flammability exposure, comply with the fuel 

tank inerting system requirements.

N/A Post 38062

Or

Post SB 47-1002

Or

Post SB 47-1004

6 Protective coating 

on fuel tank at the 

connection of fuel 

tank inerting system

A protective coating (Finch paint) is necessary at 

the connection between the centre fuel tank and the

dual flapper check valves’ housing of the Inert Gas 

Generating System (IGGS) to prevent fuel or fuel 

vapour leaks into an area containing ignition 

sources.

After maintenance of the dual flapper check valves

the protective coating must be restored to the 

appropriate standard using the method stated within 

the maintenance procedure in the AMM.

AMM

47-20-43-400

47-20-43-700

Post 38062

Or

Post 38195

Post 38196

Or

Post 150499

Post 150500

Or

Post SB 47-1001

Post SB 47-1002

Or

Post SB 47-1003

Post SB 47-1004

7 Warning Placards 

for areas that may 

contain oxygen 

depleted 

atmospheres.

Warning placards installed to ensure maintenance 

personnel are aware of areas that may be 

hazardous because of possible oxygen depleted 

atmosphere, must be ensured to be present in the 

designated positions

AMM

57-17-11-000

57-17-11-400

28-12-47-000

28-12-47-400

Post 150837