Date: 201502
Local time of day: 1801-2400
Location: ZZZ.Airport, US
Light: Night
Aircraft: A300
Operator: Air Carrier
Operating under: Part 121
Flight plan: None
Mission: Cargo / Freight / Delivery
Flight phase: Parked
Aircraft component: Fuel Distribution System
Reporter organization: Air Carrier
Reporter function: Technician
Reporter qualification: Maintenance Airframe; Maintenance Powerplant
Human factors: Troubleshooting; Time Pressure; Communication Breakdown; Confusion
Second reporter function: Technician
Anomaly: Aircraft Equipment Problem Critical; Deviation / Discrepancy - Procedural Published Material / Policy; Deviation / Discrepancy - Procedural Maintenance; Deviation / Discrepancy - Procedural FAR
Detector: Person Maintenance
When detected: Pre-flight
Result: General Flight Cancelled / Delayed; General Maintenance Action
Contributing factors: Aircraft; Procedure; MEL; Human Factors; Environment - Non Weather Related
Primary problem: Human Factors

Narrative: These are the events as I; [Maintenance Controller X]; recall them for an A300 aircraft concerning deferrals MXXXX74 and DXXXX77. Maintenance Control was contacted by ZZZ Line maintenance to report the Scavenge Fuel Pump Control circuit breaker on panel 132VU at location K63 (FIN # 13QQ) was tripped.  My responsibility in these events was to approve the actions taken to address this issue by way of the completion of the Audit Process per Maintenance Control procedures 04.02.01.  My refusal to complete the audit process was based on the following:       1). Aircraft Maintenance Manual (AMM) 28-11-4-0401 for the replacement of the Fuel Scavenge Pump begins with a blanket warning that this is a Critical Design Configuration Control Limitation (CDCCL) item and 'You must keep all CDCCL items in the approved configuration'. The company's position to me was this CDCCL warning only applies to the replacement of this pump. I disagree. If you were to change the connector on this pump would not the CDCCL warning still apply?  This circuit breaker was powering the control relays that are external to the tank; but are they still not part of the Scavenge Fuel Pump System?  Is this system as a whole not part of the CDCCL concept?  Would not the same CDCCL warnings apply?  The CDCCL warnings in AMM 28-11-41-0401 do not identify the procedure of replacing the pump as the CDCCL concern. Rather; AMM 28-11-41-0401 says the procedure of replacing the pump 'USES' a fuel system 'ITEM' that is in a category known as CDCCL. The 'ITEM/SYSTEM' itself is the CDCCL concern. The deferrals MXXXX74 and DXXXX77 together; change the approved configuration of this CDCCL system.        2). In my view the actions taken were out of the scope of the General Maintenance Manual (GMM) 03.05.01 by using a simple 'D' item  and required an Engineering Order (EO) to address the issue. Per GMM 03.05.01; 'If the recommended action is not contained within an applicable manual it will be necessary to obtain concurrence and instruction from Engineering through the issuance of an EO.' What manual was produced by ZZZ Line Maintenance or Engineering allowing Maintenance Control to pull this circuit breaker or deviate from the CDCCL warning?      3). Per GMM 03.05.01; 'Additional engineering concurrence may be necessary'. What has developed out of this process is a pattern of Engineering telling Maintenance Control and Line Maintenance that the issue at hand can be handled using GMM 03.05.01 by 'just put a 'D' item on it per the GMM'.  This is an overreach by the Engineering Department. Per GMM 03.02.01; 'Maintenance Control will administer and control deferred items (MEL; CDL and DMI)'.   This GMM is clear that the responsibility for the legality of the deferral process is with Maintenance Control.  That decision may or may not require engineering concurrence. It may require the Engineering department to produce an EO to address the fault. Engineering should not be telling Maintenance Control what procedure is needed to defer any item.        4). What was causing the circuit breaker to trip?  Proper troubleshooting was not applied to find the root cause for the circuit breaker to trip.  Do we have a short?  Per Airbus A300 Electrical Standards Practices Manual (ESPM) Manual 20-10-00; Para 2; this is a violation.      Lastly I felt very pressured to agree to this process. Even more so after I expressed my concerns. I was told by the Maintenance Control management to work as directed and complete the audit process.  Under the threat of discipline I completed the audit process and submitted this report.  In the safety first environment of Maintenance Control; the pressure I felt to agree to these deferrals runs counterproductive and does not build bridges for better working relations. Aircraft delay. Fuel Distribution System. Fuel System: General.  Extreme Cold.


Second narrative: February 2015; I; Maintenance Controller Y; received a phone call from a Line Mechanic X in ZZZ on an A300 aircraft; that was scheduled to depart that night.  Line Mechanic said the crew found Circuit Breaker K63 (13QQ) on 132VU panel was tripped and would not reset.  The Circuit Breaker (K63) is part of the Water Scavenge System in the Aircraft fuel tanks and is deferrable as per A300 MEL 28-11-41 with a Dispatch Procedure (DP) of 28-11-14 to be accomplished; however the DP does not direct the mechanic to pull and collar this Circuit Breaker.  I conferenced us with Engineer X for a possible issuance of an Engineering Order (EO) to allow maintenance to pull and collar this Circuit Breaker due to the fact that the fuel tank Water Scavenge System is a system that is associated with (SFAR) 88 Critical Design Configuration Control Limitation (CDCCL) and has tripped and cannot be reset; and also being aware of the necessity to maintain design features that are critical to preventing ignition sources from developing within the fuel tank system.       After approx. 15 minutes researching Aircraft Wiring Manual (AWM) 28-11-01; Engineer X directed us to use new General Maintenance Manual (GMM) 03.05.01 and to pull and collar Circuit Breaker K63 (13QQ) and to defer the Water Scavenge System as per MEL 28-11-41.  I was reluctant to use the GMM 03.05.01 reference and would prefer an Engineering Order due to the involvement of a CDCCL system and the warnings issued in Aircraft Maintenance Manual (AMM) 28-11-41-0401; where it states 'You must keep all CDCCL items in the approved configuration.  Damage; wear; or changes to a CDCCL item can cause a possible fuel tank explosion.'  I felt that an Engineering Order would be a more suitable and appropriate direction to follow since I believe this to be a Safety Of Flight issue.  My fellow Controller that night on the Airbus desk; Controller X; concurred along with Maintenance Control Supervisor X; originally.  Engineer X however; insisted that GMM 03.05.01 was applicable and should suffice in this case; since K63 (13QQ) was only a control Circuit Breaker that went to relays; not to the fuel tank and that AMM 28-11-41-0401 just dealt with the bonding of the scavenge pump if it were to be replaced.  No Engineering Order was required or forthcoming.      I requested an aircraft swap so we can at least identify what was causing Circuit Breaker K63 (13QQ) to trip and not to reset; since this was associated with a sensitive CDCCL system.  Maintenance Control Manager X; Maintenance Control Supervisor Y and now Maintenance Control Supervisor X did not agree and instructed me to work as directed and to issue both deferrals and for Controller X to also audit both deferrals.  I contacted Tech Support Mr. X and Tech Support Supervisor X for further concurrence and both said it was OK to use GMM 03.05.01 and directed me to issue both deferrals against my better judgment. I issued both deferrals MXXXX74 and DXXXX77; reference Log page items #1 and #2 as directed by Maintenance Control management and submitted this report.  We instructed [Line] Mechanic X to also submit a report because Controller X and I would be submitting a report on this matter.       Several controllers have issued complaints to management in reference to the legality of GMM 03.05.01 with Safety OF Flight concerns.  For example; one step in this GMM; prior to issuing a deferral; states that 'Disconnecting and securing an electrical connector; draining and/or capping hydraulic; fuel; water; or pneumatic lines; pulling Circuit Breakers; and capping and stowing of electrical wires; provided there is: No effect on Flight Manual Supplements'; we cannot verify this step in Maintenance Control and no one seems to know how to access this information; therefore; I believe we should not be using this new GMM 03.05.01 reference.  I am aware of the complaint issued by our Air Carrier to allow GMM deviation from Dispatch Procedures; howeverthe deviation must be simple and routine in nature to rectify an unsafe condition of a component.  In the case with a sensitive CDCCL component; I believe an Engineering Order was required to assure continued Safety Of Flight.  In summary; our primary concern with the issuance of these two deferrals was the tripping of Circuit Breaker K63 (13QQ); which was from a CDCCL associated system.  The cause of the tripping Circuit Breaker was never addressed by Engineering.  In the past; before an Engineering Order was issued for a tripping Circuit Breaker; a cause ALWAYS needed to be addressed before an Engineering Order was issued; now with this new GMM reference a cause is no longer required.  WHY? What has changed?? Is a short in the aircraft wiring no longer important??  Task 28-00-00-840 Airworthiness Limitations Precautions states 'Strict adherence to configuration; methods; techniques; and practices as prescribed to make sure that the CDCCL is complied with.  Use of parts; methods; techniques or practices not contained in the applicable CDCCL must be approved by the FAA office that is responsible for the Aircraft model type certificate or applicable regulatory agency.'


Synopsis: Two Maintenance Controllers are directed under threat of discipline to issue two deferrals under their General Maintenance Manual (GMM) for a water scavenge system in an A300's aircraft fuel tank and a Scavenge Fuel Pump Control Circuit Breaker (CB) K63 that would not reset. Both Controllers believed an Engineering Order (EO) was required due to the scavenge pump control CB's association with Special Federal Aviation Regulation 88 and Critical Design Configuration Control Limitation (CDCCL). The Line Mechanic also requests clarification of the two contradicting statements in their GMM as to the necessity of an EO when deviating from an MEL.