U.S.

Department
of Transportation
Advisory
Federal Aviation
Administration Circular
Subject: Incorporation of Fuel Tank System Date: 4/11/17 AC No: 120-97A
Instructions for Continued Initiated by: AFS-300 Change: 1
Airworthiness into Operator
Maintenance and/or Inspection
Programs

1. PURPOSE. This advisory circular (AC) provides information regarding compliance with the
fuel tank system maintenance and inspection program requirements in Title 14 of the Code of
Federal Regulations (14 CFR) for parts 91 subpart K (part 91K), 121, 125, and part 129,
§ 129.14 foreign air carriers hereafter referred to as operators. Instructions for continued
airworthiness (ICA) (see Appendix 3, Definitions) include fuel tank system inspection tasks,
intervals, methods, instructions/procedures, airworthiness limitations, and fuel tank system
critical design configuration control limitations (CDCCL), which are a specific type of
airworthiness limitation.

2. PRINCIPAL CHANGES. This change updates guidance in paragraph 3-14 for Operations
Specification (OpSpec)/Management Specification (MSpec)/Letter of Authorization (LOA)
D097, Aging Aircraft Programs, removing the use of the “Free Text” area and changing how
D097 Table 1 will be used. The table signifies that the FAA has reviewed the operator’s
maintenance and/or inspection program(s) policy and procedures are in compliance with the
respective Aging Aircraft Program rules.

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John Barbagallo
Deputy Director, Flight Standards Service
4/11/17 AC 120-97A CHG 1

U.S. Department
of Transportation
Advisory
Federal Aviation
Administration Circular
Subject: Incorporation of Fuel Tank System Date: 5/25/12 AC No: 120-97A
Instructions for Continued Initiated by: AFS-300 Change:
Airworthiness into Operator
Maintenance and/or Inspection
Programs

On May 7, 2001, the Transport Airplane Fuel Tank System Design Review, Flammability
Reduction and Maintenance and Inspection Requirements Final Rule was published in the
Federal Register (FR). It has since been referred to as the 2001 Fuel Tank Safety (FTS) rule.
It adopted amendments to part 25, Special Federal Aviation Regulation (SFAR) 88 and operating
requirements related to SFAR 88. The operating requirements included requirements to
implement instructions for continued airworthiness (ICA) that design approval holders (DAH)
developed in compliance with SFAR 88. On November 8, 2007, the Federal Aviation
Administration (FAA) published the Enhanced Airworthiness Program for Airplane Systems
(EAPAS)/FTS Final Rule. The purpose of the rule is to help ensure the continued safety of
transport category airplanes by improving the design, installation, and maintenance of electrical
wiring systems. The EAPAS/FTS Rule amended the operating requirements to implement FTS
actions developed in accordance with SFAR 88. Integrating the incorporation of the fuel tank
system and electrical wiring interconnection system (EWIS) requirements helps to ensure
compatibility and to eliminate duplication. Additionally, the EAPAS/FTS Rule redesignates
(replaces) Title 14 of the Code of Federal Regulations (14 CFR) part 91, § 91.410(b); part 121,
§ 121.370(b); part 125, § 125.248(b); and part 129, § 129.32(b) of the FTS Rule. The new
sections are §§ 91.1507, 121.1113, 125.507 and 129.113. These new rules also clarify language
with reference to the approval process of the operator’s program. This advisory circular (AC)
only addresses the fuel tank system safety requirements and describes acceptable means of
compliance (AMC) accordingly. AC 120-102, Incorporation of Electrical Wiring Interconnection
Systems Instructions for Continued Airworthiness into an Operator’s Maintenance Program,
addresses EWIS requirements in the EAPAS/FTS Rule.
4/11/17 AC 120-97A CHG 1

CONTENTS
Paragraph Page

CHAPTER 1. GENERAL................................................................................................................1

1-1. Purpose..............................................................................................................................1
1-2. Applicability .....................................................................................................................1
1-3. Background .......................................................................................................................1
1-4. Related CFRs ....................................................................................................................2
1-5. Related ACs (current editions)..........................................................................................2
1-6. FAA Fuel Tank System Policy Statement ........................................................................3
1-7. Industry Reference ............................................................................................................3
1-8. The EAPAS/FTS Rule ......................................................................................................4
1-9. AC Feedback Form ...........................................................................................................4

CHAPTER 2. FUEL TANK SYSTEM REQUIREMENTS............................................................5

2-1. Requirements ....................................................................................................................5

2-2. Unsafe Condition ..............................................................................................................5
2-3. No Unsafe Condition ........................................................................................................5
2-4. Field-Approved Auxiliary Fuel Tanks ..............................................................................7
2-5. STC Auxiliary Fuel Tanks ................................................................................................7
2-6. Applicable FTS STCs .......................................................................................................7
2-7. History of Fuel Tank System Maintenance Practices .......................................................7

CHAPTER 3. DESIGN MAINTENANCE AND INSPECTION ...................................................9

3-1. Airplane Fuel Tank System ..............................................................................................9

3-2. DAH Fuel Tank Alterations ..............................................................................................9
3-3. Changes to Operators’ Fuel Tank System Tasks, Intervals, and
Instructions/Procedures .....................................................................................................9
3-4. Fuel Tank System Airworthiness Limitations ................................................................10
3-5. AD Requirements............................................................................................................12
Table 3-1. Airworthiness Limitation Table Example 1—ALI........................................14
Table 3-2. Airworthiness Limitation Table Example 2—CDCCL .................................14
3-6. Operator Compliance with Airworthiness Limitations ...................................................15
3-7. Operator-Developed Shop Instructions...........................................................................15
3-8. Exceptional Short-Term Extension of Fuel Tank System Airworthiness
Limitations ......................................................................................................................16
3-9. Changes in ICA Resulting from Alterations ...................................................................16
3-10. Fuel Tank System Ignition Prevention Training .............................................................17
3-11. Operator’s Maintenance Program Approval Under §§ 121.1113 and 129.113 ..............18
3-12. Operator’s Inspection Program Approval Under § 125.507 ...........................................18
3-13. Operator Inspection Program Approval Under § 91.1507 ..............................................18
3-14. Operators that are Authorized OpSpec/MSpec/LOA D097............................................18
Table 3-3. Sample D097 Table 1 – Aging Aircraft Maintenance Programs ..................19

Page iii
AC 120-97A CHG 1 4/11/17

CONTENTS (Continued)
Paragraph Page

APPENDIX 1. ACRONYMS (2 pages).........................................................................................1

APPENDIX 2. LIST OF APPLICABLE SUPPLEMENTAL TYPE
CERTIFICATES (2 pages) ..................................................................................1
APPENDIX 3. DEFINITIONS (6 pages)......................................................................................1
APPENDIX 4. FAA OVERSIGHT OFFICES BY AIRPLANE
MANUFACTURER (2 pages)..............................................................................1

Page iv
4/11/17 AC 120-97A CHG 1

CHAPTER 1. GENERAL

1-1. PURPOSE. This advisory circular (AC) provides information regarding compliance with
the fuel tank system maintenance and inspection program requirements in Title 14 of the Code of
Federal Regulations (14 CFR) for parts 91 subpart K (part 91K), 121, 125, and part 129,
§ 129.14 foreign air carriers hereafter referred to as operators. Instructions for continued
airworthiness (ICA) (see Appendix 3, Definitions) include fuel tank system inspection tasks,
intervals, methods, instructions/procedures, airworthiness limitations, and fuel tank system
critical design configuration control limitations (CDCCL), which are a specific type of
airworthiness limitation.

1-2. APPLICABILITY. This AC applies to operators of transport-category turbine-powered

airplanes with a type certificate (TC) issued after January 1, 1958, that, as a result of original
type certification or later increase in capacity, have a maximum TC’d passenger capacity of 30 or
more, or a maximum payload capacity of 7,500 pounds or more, and transport-category airplanes
that include 14 CFR part 25, § 25.981, amendment 25-102 or later, in the original certification
basis of the airplane or in the certification basis of modifications to the airplane.

a. Avoiding Compliance. In the past, some designers and operators avoided applying
requirements for airplanes over a specific capacity by getting a design change approval for
a slightly lower capacity. Referencing the capacity resulting from original certification removes
this means of avoiding compliance. Also, an airplane design could be originally certified with
a capacity slightly lower than the minimum specified in the rule, but through later design
changes, the capacity could be increased above this minimum. The reference to later increase in
capacity in the rule ensures that, if this occurs, the airplane would have to meet the requirements
of the rule.

b. FAA Oversight Office. The Aircraft Certification Office (ACO) or the office of the
Transport Airplane Directorate has oversight responsibility for the relevant TC or Supplemental
Type Certificate (STC), as determined by the Administrator. (See Appendix 4, FAA Oversight
Offices by Airplane Manufacturer.)

c. Required ICA. Operators are required to incorporate ICA into their maintenance or
inspection program that are required by Special Federal Aviation Regulations (SFAR) 88 or
§§ 25.1529, 25.1729, part 25 appendix H, and part 26, § 26.11, and that have been approved by
the FAA Oversight Office. Operators are not required to use the design approval holder’s (DAH)
fuel tank ICA. While we think it is likely that operators will use the DAH ICA, we acknowledge
that they are able develop their own or to contract with third parties to develop them.
Operator-developed ICA must be approved by the FAA Oversight Office.

1-3. BACKGROUND. Since 1959, there have been 18 fuel tank explosions on transport
category airplanes. Most notably, on July 17, 1996, a 25-year-old Boeing 747-100 series
airplane, operating as Trans World Airlines (TWA) Flight 800, was involved in an in-flight
breakup after takeoff from John F. Kennedy International Airport in New York, resulting in
230 fatalities. The National Transportation Safety Board (NTSB) determined the probable cause
of the TWA 800 accident was an explosion of the center wing fuel tank (CWT) due to ignition of
the flammable fuel vapor and air mixture in the tank. The source of ignition energy for the

Par 1-1 Page 1

AC 120-97A CHG 1 4/11/17

explosion could not be determined conclusively, though the NTSB determined that it was most
likely a combination of failures involving the wiring entering the fuel tank, such as the fuel
quantity indicator system (FQIS). FQIS or other wires entering the fuel tank (such as fuel level
sensor systems (FLSS), float switch, etc.) are designed to carry “intrinsically safe” levels of
electrical energy inside fuel tanks. Without an additional failure, a short of FQIS or other wires
entering the tank would not have sufficient energy to create an ignition source. The NTSB
determined the most likely ignition source was an existing FQIS failure inside the CWT and a
FQIS wiring failure outside the CWT. The internal failure created the condition for an ignition
source if high electrical energy was applied to the FQIS wiring inside the CWT. The external
failure applied excessive electrical energy on the FQIS or other wires that enter the CWT.

1-4. RELATED CFRs. The following 14 CFR parts and sections apply:

• Part 21, Special Federal Aviation Regulation No. 88—Fuel Tank System Fault
Tolerance Evaluation Requirements.
• Part 25, Airworthiness Standards: Transport Category Airplanes:
• Section 25.981, Fuel Tank Ignition Prevention.
• Section 25.1529, Instructions for Continued Airworthiness.
• Appendix H, Instructions for Continued Airworthiness.
• Part 26, Continued Airworthiness and Safety Improvements for Transport Category
Airplanes.
• Part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration:
• Section 43.13, Performance Rules (General).
• Section 43.16, Airworthiness Limitations.
• Part 91 Subpart E, Maintenance, Preventive Maintenance, and Alterations, § 91.403(c)
Airworthiness Limitations.
• Part 91 Subpart L, Continued Airworthiness and Safety Improvements, § 91.1507, Fuel
Tank System Inspection Program.
• Part 121 Subpart AA, Continued Airworthiness and Safety Improvements, § 121.1113,
Fuel Tank System Maintenance Program,
• Part 125 Subpart M, Continued Airworthiness and Safety Improvements, § 125.507,
Fuel Tank System Inspection Program,
• Part 129 Subpart B, Continued Airworthiness and Safety Improvements, § 129.113,
Fuel tank system maintenance program

1-5. RELATED ACs (current editions). The ACs listed below provide information that may
support the method of compliance established by this AC. An electronic copy of the following
ACs can be downloaded from the Internet at HHhttp://fsims.faa.gov/HH. The Regulatory and
Guidance Library (RGL) is a set of searchable databases that contain regulatory, guidance, and
aviation product information. The RGL contains certain CFRs and SFARs from 14 CFR in their
current version as well as historical versions. A paper copy may be ordered from the
U.S. Department of Transportation (DOT), Subsequent Distribution Office, M30, Ardmore
East Business Center, 3341 Q 75th Avenue, Landover, MD 20785.

• AC 25-8, Auxiliary Fuel System Installations.

• AC 25-19, Certification Maintenance Requirements.

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4/11/17 AC 120-97A CHG 1

• AC 25.981-1, Fuel Tank Ignition Source Prevention Guidelines.

• AC 25.981-2, Fuel Tank Flammability Reduction Means.
• AC 120-16, Air Carrier Maintenance Programs.
• AC 120-102, Incorporation of Electrical Wiring Interconnection Systems Instructions
for Continued Airworthiness into an Operator’s Maintenance Program.
• AC 121-22, Maintenance Review Boards, Maintenance Type Boards, and OEM/TCH
Recommended Maintenance Procedures.

1-6. FAA FUEL TANK SYSTEM POLICY STATEMENT. The FAA’s Transport Airplane
Directorate, in coordination with Flight Standards Service (AFS), other National Aviation
Authorities (NAA), and various industry representatives, developed FAA policy memorandum
ANM112-05-001, Policy Statement on Process for Developing SFAR 88-related Instructions for
Maintenance and Inspection of Fuel Tank Systems, dated October 6, 2004. This policy statement
provided standardized guidance to the DAH for developing maintenance instructions as a method
of compliance with SFAR 88.

a. Processes for Developing ICA. The policy identified two categories of potential
ignition source related ICA and provided two processes for developing those ICA:

(1) A safety critical action that is needed to address unsafe conditions is an

airworthiness limitation item (ALI). ALIs are maintenance and inspection instructions that must
be performed at the listed intervals and are adopted using the Airworthiness Directive (AD)
process. That process, used for SFAR 88, is described in part 5 of the policy statement.

(2) The remaining actions (that do not address unsafe conditions but are necessary to
maintain the continued airworthiness of the ignition source prevention features of the design) were
to be evaluated using a process based on the principles of Maintenance Steering Group-3rd Task
Force (MSG-3). That process is described in part 6 of the policy statement.

b. Categories of SFAR 88 ICA. These two categories of SFAR 88 ICA have been
42B

referred to as “Unsafe Condition” and “No Unsafe Condition” related ICA. The “Unsafe
Condition” ICA are incorporated in the applicable airplane Airworthiness Limitations Section
(ALS) mandated by AD. The “No Unsafe Condition” ICA are identified in the DAH
maintenance documents under Air Transport Association of America (ATA) i Spec 2200,
ATA 28 for the airplane.

c. Design Review. The policy could also be useful to an operator in performing a design
43B

review of any field-approved auxiliary fuel tank installations (see paragraph 2-4).

d. Paper Copy. A paper copy of the policy letter may be ordered from the FAA, Transport
4B

Airplane Directorate, Transport Standards Staff, Standardization Branch, ANM-113,

1601 Lind Avenue SW., Renton, WA 980057-3356. An electronic copy can be downloaded from
the Internet at http://www.fsims.faa.gov or http://rgl.faa.gov/.

1-7. INDUSTRY REFERENCE. The ATA MSG-3, Operator/Manufacturer Scheduled

Maintenance Program Development, and later revisions.

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AC 120-97A CHG 1 4/11/17

1-8. THE EAPAS/FTS RULE. The EAPAS/FTS Rule (72 Federal Register (FR) 63364
effective December 10, 2007) includes revisions to the operational requirements that were
originally adopted by the 2001 FTS Rule (66 FR 23085, effective June 6, 2001). This AC
describes a method of compliance with these revised FTS operational requirements.

a. 2001 FTS Rule. On June 6, 2001, the Transport Airplane Fuel Tank System Design
Review, Flammability Reduction and Maintenance and Inspection Requirements Rule became
effective. It is referred to as the 2001 FTS Rule. It amended part 21 and created Special Federal
Aviation Regulation (SFAR) 88. SFAR 88 required DAH to conduct a safety review of the
applicable airplanes identified in the rule to determine that their design meets the FTS ignition
requirements described in §§ 25.901 and 25.981(a) and (d). If their design was determined to not
meet those requirements, they were required to develop design changes for those non-compliant
designs that were determined to meet the unsafe condition criteria using FAA policy
memorandum 2003-112-15, SFAR 88 — Mandatory Action Decision Criteria. The FAA is
issuing ADs mandating those design changes.

b. Design Changes. Operators must comply with the DAH, and FAA Oversight
Office-approved design changes in accordance with the respective ADs. In some instances, an
interim repetitive maintenance or inspection task is required on specific airplanes allowing the
operator additional time to accomplish the design change.

c. Compliance Dates. These fuel tank system design change ADs, and any associated
repetitive maintenance and inspection tasks, have varying compliance dates. The operator must
track these dates using its currently established AD tracking system.

d. ICA for Preventing an Ignition Source. SFAR 88 also requires the DAH to develop
specific ICA needed to maintain design features that prevent the existence or development of an
ignition source within the fuel tank, which could be accomplished using policy memorandum
ANM112-05-001. The operator must incorporate FAA Oversight Office-approved ICA into their
maintenance or inspection program by the dates specified in the operational rule or AD. The
actions specified in the ICA must be accomplished in accordance with the times specified in
the ICA.

1-9. AC FEEDBACK FORM. For your convenience, the AC Feedback Form is the last page of
this AC. Note any deficiencies found, clarifications needed, or suggested improvements
regarding the contents of this AC on the Feedback Form.

Page 4 Par 1-8

5/25/12 AC 120-97A

CHAPTER 2. FUEL TANK SYSTEM REQUIREMENTS

2-1. REQUIREMENTS.

a. Fuel Tank System Program Requirements. This AC provides information to support

operators’ compliance with the fuel tank system maintenance and inspection program
requirements contained in the EAPAS/FTS Rule. The operational rules contained in §§ 91.1507,
121.1113, 125.507, and 129.113 require operators to incorporate FAA Oversight
Office-approved ICA into their maintenance or inspection program.

b. Types of ICA. In accordance with policy memorandum ANM112-05-001, DAH

identified two categories of maintenance and inspection instructions. For the purposes of this
guidance, we have simplified the descriptions of these types of ICA and have provided
two classifications: “unsafe condition” and “no unsafe condition” as defined below:

(1) Unsafe Condition. Those that are directly related to an unsafe condition and require
mandatory action.

(2) No Unsafe Condition. Those that do not have a direct adverse effect on operational
safety, but for which developing maintenance inspections, certain standard practices, or
procedural warnings can reduce the potential for an ignition source.

NOTE: See paragraph 1-6 for reference to ANM112-05-001.

2-2. UNSAFE CONDITION. The DAH are required to develop design changes and ICA to
address features of the fuel tank system design that are determined to meet the SFAR-88 unsafe
condition criteria, and mandated by AD. These AD-mandated actions could include design
changes, operational procedures, or ALIs containing repetitive maintenance and inspection
instructions, or all three. FTS airworthiness limitations include CDCCL, inspections, or other
procedures that are necessary to prevent development of ignition sources within the fuel tank
system. CDCCLs are a type of fuel tank system airworthiness limitation introduced by
§ 25.981(d) (see paragraph 3-4 for a detailed description of CDCCLs).

2-3. NO UNSAFE CONDITION. The DAH were also required to develop ICA for all
Safety-related Failure Effect Category (FEC) 5 and 8 tasks developed from analysis of
Maintenance Significant Items (MSI) that include those fuel tank system design features. These
tasks address those features of the fuel tank system design that are determined to be a no unsafe
condition but are necessary to maintain the continued airworthiness of the ignition source
prevention features of the fuel tank system. The DAH, through the Maintenance Review Board
(MRB) process, subjects these MSIs to maintenance program development logic using the latest
version of MSG-3. Inspection tasks, intervals, and task instructions/procedures are developed as
a result of this process. They are FAA Oversight Office-approved. They will normally be found
in the TC holder’s Maintenance Review Board Report (MRBR) or a source document required
by part 25 appendix H, § H25.5(b). AC 120-102, Incorporation of Electrical Wiring
Interconnection Systems Instructions for Continued Airworthiness into an Operator’s
Maintenance Program, provides information on the “source document.” The STC ICA will be
contained in the FAA-approved STC document.

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AC 120-97A CHG 1 4/11/17

NOTE: For administrative purposes, some DAH have put both the
“no unsafe condition” and the “unsafe condition” category ICA in their ALS
mandated by an AD. An operator’s AD tracking system must ensure it does
not make a distinction between categories such that one is tracked differently
from the other. Both are mandated by an AD and require the same level of
visibility and attention. Changes to either category must be approved by the
FAA Oversight Office as an alternative method of compliance (AMOC) to
the AD.

a. Operators Without MSG-3 Programs. The FAA recognizes that some operators may
not have MSG-3 maintenance programs. Those operators must still incorporate the
FAA-approved fuel tank system ICA into their maintenance or inspection program.

b. Inspection Tasks, Intervals, and Task Instructions/Procedures. The inspection

tasks, intervals, and task instructions/procedures are selected to ensure that fuel tank system
protective features are properly maintained while still allowing flexibility for the operators to
schedule maintenance tasks within their maintenance or inspection programs. The DAH will
make these inspection tasks, intervals, and task instructions/procedures available to the operators
for incorporation into their maintenance or inspection programs in the following manner.

c. FTS ICA or FTS/EWIS ICA. The fuel tank systems ICA are identified as FTS ICA, or
if the FTS ICA is also part of a EWIS ICA it may be identified as FTS/EWIS ICA. Both are FAA
Oversight Office-approved. AC 120-102 provides additional information on the FTS/EWIS ICA.
The DAH will sometimes identify a separate cross-referencing document where these fuel tank
systems ICA are located. While the FAA expects that the DAH fuel tank system ICA tasks will
be located in ATA, Chapter 28, Fuel Systems, some may also be located in other ATA chapters
such as Chapter 20, Standard Practices.

NOTE: The procedures to carry out the inspections such as access,

equipment removal, etc., should be contained in the DAH Aircraft
Maintenance Manual (AMM) as well as be included in their applicable
job/task cards.

d. FTS ICA. In accordance with the operational rules, operators must include fuel tank
system ICA in their maintenance or inspection program. Operators should have a tracking system
within their maintenance or inspection program so that they do not lose their identity as an FTS
ICA. Operator changes to FTS ICA must be in accordance with the guidance contained in this
AC. The operator should submit the data that supports any changes to approved ICA through the
principal inspector (PI), who may add comments and then forward them to the FAA Oversight
Office for approval.

e. Specific Instructions. The DAH no unsafe condition ICA will typically be in the form
of inspection tasks and intervals and task instructions/procedures. They may also be specific
instructions that are referenced in a task but are contained in other manuals such as the AMM,
the airplane standard wiring practice manual (SWPM), or in the STC holder’s manual that
contains the ICA for the STC. These DAH ICA are approved by the FAA Oversight Office.
The operator will submit to the PI for review the revisions to their maintenance and inspection

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4/11/17 AC 120-97A CHG 1

program incorporating the FAA Oversight Office-approved DAH ICA changes. When the review
is complete, the PI will issue or amend Operations Specification (OpSpec)/Management
Specification (MSpec) D097, Aging Aircraft Programs.

2-4. FIELD-APPROVED AUXILIARY FUEL TANKS. Per paragraph (b) of the operational
rules (refer to §§ 91.1507, 121.1113, 125.507, and 129.113) if an operator has any of these tanks
installed in their airplanes and chooses to continue operation with them installed, the operator
must perform a design review and develop ICA in accordance with the design review
requirements detailed in SFAR 88. The operator, being the DAH for these tanks, is in the best
position to develop ICA for them. The operator should submit proposed field-approved auxiliary
tank data through their PI to the FAA Oversight Office responsible for approving their airplane
type. After FAA Oversight Office approval, the operator will submit to the PI for review the
revisions to their maintenance and inspection program incorporating the FAA Oversight
Office-approved ICA changes. When the review is complete, the PI will issue or amend
OpSpec/MSpec D097. In the event the operator chooses to deactivate or remove a field-approved
auxiliary tank, such action can only be accomplished using approved data.

2-5. STC AUXILIARY FUEL TANKS. According to the operational rules, if an operator has
STC auxiliary fuel tanks installed in their airplanes, they must incorporate ICA meeting
SFAR 88, if any, into their maintenance or inspection program. If the FAA determines any
particular STC auxiliary tank installations pose a safety risk, the FAA will issue ADs mandating
such tanks be deactivated or removed in accordance with data submitted by the operators and
approved in accordance with the AD.

2-6. APPLICABLE FTS STCs. In order for an operator to incorporate all the applicable STC
ICA they must first establish what STCs are installed on their airplanes. An FAA
engineering-approved list of applicable STCs is provided in Appendix 2, List of Applicable
Supplemental Type Certificates. The operators should review this list and determine if any of the
applicable STCs are installed on their airplanes. Under normal circumstances a records review by
the operators should be sufficient to determine which of their airplanes has any of the applicable
STCs. If records are inadequate, it may be necessary to physically inspect airplanes to confirm
applicable STC installation; however, this should not entail physically checking the routing of
wiring, etc. The operator should provide the PI a list of airplanes that have any of the applicable
STCs installed and present their proposed STC ICA for review and approval.
(See paragraphs 3-10 through 3-14 for the review and approval process.)

2-7. HISTORY OF FUEL TANK SYSTEM MAINTENANCE PRACTICES. Most fuel

tank system maintenance involves zonal inspections to determine the condition of units or
systems with regard to continued serviceability. Corrective action is taken only when indicated
by the condition of a particular unit or system. The most common type of zonal inspection for
certain components of fuel tank systems is a general visual inspection (e.g., an examination of an
interior or exterior area, installation, or assembly to detect obvious damage, failure or
irregularity). Typically, operators conducted these general visual inspections as part of other
zonal inspections of the fuel tanks. A limitation of a general visual inspection of the fuel tank
system is that often the inspection does not provide sufficient information to determine continued
airworthiness of internal or hidden system components. This is because certain degraded
conditions or failures are difficult, or even impossible, to detect without extensive and detailed

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AC 120-97A 5/25/12

inspection or functional checks. Examples of such degraded conditions or failures are worn
wiring routed through conduit to fuel pumps, accumulated debris inside fuel pumps, corrosion of
bonding wire interfaces, and broken or missing bonding straps. As a result of the FTS review,
certain general visual inspections of the fuel tank system under the zonal inspection concept may
become detailed inspections, and may include specific pass/fail criteria.

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4/11/17 AC 120-97A CHG 1

CHAPTER 3. DESIGN MAINTENANCE AND INSPECTION

3-1. AIRPLANE FUEL TANK SYSTEM. The airplane’s fuel tank system is defined by the
airplane’s TC, amended type design changes, and any STC and field-approved auxiliary fuel
tank systems. The fuel tank system includes components necessary for the fuel tank system to
perform its intended function (e.g., pumps, fuel pump power supplies, fuel valves, fuel quantity
indication system probes, wiring, compensators, densitometers, fuel level sensors, etc.). The
safety assessment required to address potential fuel tank ignition sources includes both analysis
of the fuel tank system and analysis of other airplane systems that could affect the fuel tank
system.

3-2. DAH FUEL TANK ALTERATIONS. Generally, DAH-developed ICA do not apply to
portions of the airplane fuel tank system modified in accordance with an STC, or those that have
field-approved auxiliary fuel tanks. The FAA has defined field-approved auxiliary fuel tank
systems as design changes approved by an aviation safety inspector (ASI) on FAA Form 337,
Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance). DAH of auxiliary
fuel tanks are required to develop ICA, approved by the FAA Oversight Office, that meet the
requirements of SFAR 88 or § 25.1529 and part 25 appendix H, effective June 6, 2001.

3-3. CHANGES TO OPERATORS’ FUEL TANK SYSTEM TASKS, INTERVALS, AND

INSTRUCTIONS/PROCEDURES. Fuel tank system MSI tasks (FEC 5 and 8) resulting from
SFAR 88 safety reviews are unique to SFAR 88 since the FTS Rule (May 7, 2001) requires FAA
approval of any changes. These maintenance tasks (inspections intervals and task
instructions/procedures) are necessary to prevent the development of ignition sources inside the
fuel tanks. The fuel tank system FEC 5 and 8 tasks were derived by engineering judgment based
on the anticipated consequences of functional failures assessed under MSG-3 logic and therefore
changes to them may have a greater effect on safety than FEC 6, 7, and 9 tasks. The task
intervals are selected to ensure proper maintenance of fuel tank system protective features related
to ignition prevention. These intervals are also selected to allow flexibility for operators to
perform these maintenance tasks within their normal scheduled maintenance checks.

NOTE: For certification to § 25.981, Amendment 25-102, all CDCCLs,

inspections, or other procedures established to comply with § 25.981 must be
included in the ALS of the ICA required by §§ 25.1529, 25.1729, and 26.11
in accordance with Amendment 25-125, §§ 25.981(d) and H25.4,
Amendment 25-102.

a. Deleting or Changing a Task Requirement. A task requirement includes both the task
and the interval. Operators wanting to delete or increase a task/interval must first obtain approval
from the FAA Oversight Office through the PI if any escalation of the MRBR FEC 5
and 8 task/interval is needed to retain the task(s) in the check package. For example, when
an operator wants to escalate a normal scheduled maintenance check (e.g., “C” check package
that includes FEC 5 and 8 fuel tank system tasks/intervals) the operator has two options. In either
case there should be close coordination between the operator and the FAA.

(1) Option One. Obtain approval from the FAA Oversight Office through the PI to
escalate the FEC 5 and 8 task/interval.

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AC 120-97A 5/25/12

(2) Option Two. Identify the FEC 5 and 8 tasks/intervals and track them individually or
identify the FEC 5 and 8 tasks/intervals and place them in a more frequent package
(e.g., a 4A check).

b. Escalation of Fuel Tank System Task Requirement. Any proposed escalation of any
fuel tank system MSI tasks must include data and analysis that supports the proposed change.
The analysis should include reliability data from the operator’s fleet experience including fleet
operating hours and cycles for the airplane model, types of task-related failures experienced, and
the number of task-related failures. In addition, the operator should review all fuel tank system
issues/problems including unscheduled maintenance and feedback from airworthiness limitation
compliance.

c. Airplane Modifications and Operating Environment. Airplane modifications

incorporated after the airplane manufacture date could affect the data used in the analysis, so data
on those changes should be included in the submittal in support of the proposed change. The
model fleet operating environment could also affect the data. Any analysis that includes other
operator’s fleet experience should show that the data being used is from airplanes operated in an
environment consistent with the operating environment of the operator’s fleet. The operator may
want to get inputs from the manufacturer.

d. Fuel Tank System Maintenance Tasks Analysis. Additional information on

performing analysis of fuel tank system maintenance tasks and intervals is included in
AC 25.981-1, Fuel Tank Ignition Source Prevention Guidelines, and ANM112-05-001.
Operators should submit their request to the PI, who may add comments and then forward it to
the FAA Oversight Office for approval. Task intervals for FEC other than 5 and 8 may be
escalated through the normal operator and PI approval process.

e. Submitting Proposed Changes. Operators wanting to change FAA Oversight

Office-approved FEC 5 and 8 task instructions/procedures such as those contained in the MRBR
for the airplane, should submit their proposed changes through the PI, who may add comments
and then forward them to the FAA Oversight Office for approval. The PI may also want to
simultaneously coordinate the operators’ proposed change with the appropriate FAA Aircraft
Evaluation Group (AEG) Maintenance Review Board (MRB) Chairperson.

3-4. FUEL TANK SYSTEM AIRWORTHINESS LIMITATIONS. Fuel tank system

airworthiness limitations are FAA Oversight Office-approved mandatory CDCCLs, inspections,
or other procedures determined necessary to ensure that fuel tank ignition sources do not occur
and are not introduced into the fuel system as a result of maintenance actions, repairs, or
alterations throughout the operational life of the airplane. This requirement is similar to that
contained in § 25.571 for airplane structure and fuel tank system airworthiness limitations are
intended to be treated the same as airplane structure airworthiness limitations. Therefore,
Amendment 25-102 added a new requirement to part 25 appendix H to require including fuel tank
system airworthiness limitations in the ALS of the ICA. The purpose of the FTS airworthiness
limitations is to prevent the development of ignition sources in the fuel tank system. Fuel tank
system airworthiness limitations are required to ensure that unsafe conditions do not occur or are
not introduced into the fuel tank system as a result of configuration changes, repairs, alterations,
or deficiencies in the maintenance program throughout the operational life of the airplane.

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a. Fuel System ADs. While fuel system airworthiness limitations are developed as part of
the type certification process (new designs) in compliance with § 25.981, Amendment 25-102 or
later, in-service airplanes did not have this requirement for fuel system airworthiness limitations
in their certification basis. Therefore, SFAR 88 required DAH to develop fuel system
airworthiness limitations that the FAA then mandated with ADs. These fuel system ADs require
the operator incorporate the fuel system airworthiness limitations into their maintenance or
inspection program. A fuel tank system airworthiness limitation may be a mandatory
replacement time, related inspection, or procedures or a CDCCL.

b. Types of Fuel System Airworthiness Limitations. There are three types of fuel system
airworthiness limitations: inspections, procedures and CDCCL. One is an inspection that has a
specific task and interval (such as 10 years). A second type is procedures that could have specific
intervals. The third type is a CDCCL which has no interval but establishes configuration
limitations to maintain and to protect the “critical design feature” identified in the CDCCL.
CDCCLs can also include requirements to have placards on the airplane with information about
critical features. (Refer to AC 25.981-1 for additional information on CDCCLs.)

(1) The following is an example of a CDCCL critical design feature for a “Legacy
Airplane.”

(a) For an alternating current fuel pump fault current bonding strap installation, the
concern is the potential for fault current path through the pump motor housing to structure inside
the tank. Electrical faults internal to the fuel pump motor impeller are by design routed through
the motor impeller assembly to the bonding straps on the front face of the motor impeller
assembly to structure outside the tank. The bonding straps ensure that fault currents are
conducted to structure outside the tank until the circuit breaker and/or Ground Fault Interrupter
(GFI) has had time to remove power from the pump.

(b) The following features must be maintained during pump replacement per the
manufacturer’s AMM:

• Install two bonding straps between the pump motor impeller end-cap and
structure, and
• Verify that the motor impeller bonding resistance to structure is
0.0004 ohms (0.4 milliohms) or less.

(2) These CDCCLs must be incorporated and adhered to as written. Any proposed
operator changes to the CDCCL must be approved by the DAH Oversight Office.

c. Inspection in a Hangar Environment. Traditionally structural airworthiness

limitations have a specific task and interval and are performed as part of a scheduled inspection
in a hangar environment. Most fuel system airworthiness limitations will also involve access
requirements that are generally only available in a hangar environment during a scheduled
maintenance visit.

d. Critical Design Feature Maintenance. For example, there will also be times when a
fuel system CDCCL will involve unscheduled maintenance such as a fuel pump change due to

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AC 120-97A 5/25/12

pump failure at a line station overnight. The CDCCL requires that the critical design feature
identified in subparagraph 3-4b(1) above must be maintained during the fuel pump change.

e. Fuel System Airworthiness Limitations That Include CDCCLs. Accomplishment of

fuel system airworthiness limitations that include CDCCLs relates directly to safety of flight
similar to the Required Inspection Item (RII) requirement in the part 121 rule. Operators must
consider CDCCLs with the same safety consideration and emphasis, whether the work occurs
during scheduled or unscheduled maintenance, or it arises at an inconvenient time or location.

(1) Operators must have procedures in their maintenance program that ensure that any
airworthiness limitation critical design feature that is affected is maintained whether it’s during
scheduled or unscheduled maintenance.

(2) CDCCLs are intended to identify only critical features of a design that must be
maintained. For example, certain components of a fuel pump (or all components) may include
critical features that are identified as CDCCLs. These critical features would be identified in the
ALS of the ICA and in the component maintenance manual (CMM) as CDCCLs.

(3) Although not intended by the introduction of CDCCLs and other fuel system
airworthiness limitations, there are also DAH that have created certain airworthiness limitations
CDCCLs that include both the critical design feature as well as the tasks associated with
maintaining the CDCCL. Typically these airworthiness limitations require adhering to a specific
CMM at a specific revision level when repairing or overhauling fuel system components. In this
case, operators are required to adhere to all elements of the CMM specified in the CDCCL. Any
deviations from CMMs specified in the CDCCL, including using later revisions of those CMMs,
must be approved by the FAA Oversight Office. The operator should submit its proposed
changes through the PI, who may add comments and forward them to the FAA Oversight Office
for approval. Deviations from CMMs specified in the CDCCL may also involve an AMOC to an
AD. (See the CMM deviation definition in Appendix 3, Definitions.)

3-5. AD REQUIREMENTS. The AD requires the operator to incorporate fuel tank system
airworthiness limitations into their maintenance or inspection program.

a. Fuel Systems Airworthiness Limitations. The information in this paragraph and the
following subparagraphs 3-5b and 3-5c is based on a transport airplane Maintenance Planning
Data (MPD) ALS. Not all airplane manufacturers use the term MPD. It includes explanatory
language, which is also referred to as the program rules/front matter, about what the fuel system
airworthiness limitations are, their regulatory basis, and what they contain. It explains the
difference between an ALI and a CDCCL. Operators must incorporate this explanatory language
into their maintenance or inspection program. This includes appropriate manuals used in the
administration of the operator’s maintenance or inspection program. Any changes to these
program rules must be approved by the FAA Oversight Office and may also involve an AMOC
to an AD. The operator should submit any changes through the PI, who may add comments and
forward them to the FAA Oversight Office for approval.

b. Format of Airworthiness Limitations. This paragraph includes a format in terms of

airworthiness limitation number, task, interval, airplane applicability, and description. This is the

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5/25/12 AC 120-97A

format used by the DAH and included in the ALS of its maintenance manual. The operator can
use its own format but it must include the airworthiness limitation number, task, interval,
airplane applicability, and description in its maintenance or inspection program. This includes
appropriate manuals and documents such as engineering orders (EO) and job/work cards used in
the administration of the operator’s maintenance or inspection program. It is especially important
that this information be included on the operators job/work cards so that the person performing
the task knows the safety significance of the task.

c. Types of Airworthiness Limitations. This paragraph includes the airworthiness

limitations. Some DAH have separated fuel system airworthiness limitations into
two sub-categories: ALIs and CDCCLs. In this case, ALIs include only fuel tank airworthiness
limitation inspections and procedures. The description of the CDCCLs in some cases contains
references to the DAH AMM and the SWPM or equivalent. Unless otherwise noted, these
manuals’ references are incorporated by reference (IBR) and therefore are FAA Oversight
Office-approved. Any changes to these references in the AMM or the SWPM must be FAA
Oversight Office-approved before being used.

d. Work Instructions/Procedures. As stated in subparagraph 3-5c, AMM and SWPM

references in the airworthiness limitations are FAA Oversight Office-approved. The following
paragraphs should be used as guidance when complying with airworthiness limitations that
contain references to AMMs or SWPMs:

(1) When the words “in accordance with” or “per” are cited in the airworthiness
limitations, the procedures in the AMM or SWPM must be followed to ensure that the critical
design feature is maintained. Any changes to these procedures require FAA Oversight Office
approval before they are used. Proposed changes must be submitted through the PI, who may add
comments and forward them to the FAA Oversight Office for approval.

(2) When the words “refer to” are cited in the airworthiness limitation, the procedures
in the AMM or SWPM represent one method of complying with the airworthiness limitation.
An accepted alternative procedure may be developed by the operator in accordance with its
procedures in its maintenance program/manual. Prior FAA Oversight Office approval is not
required for this action. This does not preclude the PI from coordinating with the FAA Oversight
Office before concurring with the revision.

(3) Operators must include specific procedures in its maintenance program/manual that
identify fuel system airworthiness limitations that have AMM and SWPM procedures that are
FAA approved and can only be changed by the FAA Oversight Office, and those that can be
changed by the operator without prior FAA Oversight Office approval.

e. Example Airworthiness Limitation Identification Tables. The following tables are

examples of how two fuel tank system airworthiness limitations are identified; one as an ALI,
and the other a CDCCL. Table 3-1 identifies a portion of an airworthiness limitation in ATA
Chapter 28 for the fuel tank system. The task is identified as an ALI with an assigned interval,
airplane applicability, and a description of the airworthiness limitation task to be performed (not
shown). Table 3-2 identifies a portion of an airworthiness limitation with the task being a
CDCCL (the task is not shown). There is no assigned interval because a CDCCL is not an

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AC 120-97A CHG 1 4/11/17

inspection or procedure. It refers to information for maintenance personnel to follow when

performing maintenance and alteration to protect the critical design features of the fuel tank
system.

TABLE 3-1. AIRWORTHINESS LIMITATION TABLE EXAMPLE 1—ALI

AWL Number Task Interval Applicability Description

28-AWL 01 ALI 12 Yrs/36000 Hrs All Models External wires over center
fuel tank. Concern:
Potential for chaffing and
arcing to center fuel tank
upper panel.

TABLE 3-2. AIRWORTHINESS LIMITATION TABLE EXAMPLE 2—CDCCL

AWL Number Task Interval Applicability Description

28-AWL 02 CDCCL N/A All Models External wires over center
fuel tank. Concern:
Potential for chaffing and
arcing to center fuel tank
upper panel.

(1) An example of a CDCCL for current designs would be maintaining wire separation
between FQIS wiring and other high power electrical circuits. The original DAH defined a
method to ensure that this essential information will be evident to those who may perform and
approve repairs and alterations. The DAH provided visual means to alert maintenance personnel
of areas in the airplane where inappropriate actions may degrade the integrity of the design
configuration.

(2) The FAA Oversight Office approved the airworthiness limitations and the
information is communicated by statements in appropriate manuals such as Wiring Diagram
Manuals (WDM), AMMs, SWPMs, or the CMM. The FAA Oversight Office must approve any
operator changes to the airworthiness limitations or the manual following the process described
in subparagraph 3-5d.

(3) Operators must incorporate these CDCCLs in their maintenance or inspection

program; CDCCL instructions should be included in the operator’s manual and in the job/work
cards. Any changes that require approval by the FAA Oversight Office must be submitted by the
operator through the PI, who may add comments and then send them to the appropriate FAA
Oversight Office.

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3-6. OPERATOR COMPLIANCE WITH AIRWORTHINESS LIMITATIONS.

a. ALS Approved Under § 25.981. Section H25.4(a)(2), Amendment 25-102, requires

“Each mandatory replacement time, inspection interval, related inspection procedure, and all
critical design configuration control limitations approved under § 25.981 for the fuel tank
system” must be contained in a section of the ICA titled Airworthiness Limitations. The ALS is
FAA Oversight Office-approved and specifies maintenance required under §§ 43.16 and 91.403.
Simply stated, each operator must incorporate the ALS approved under § 25.981 for the fuel tank
system into its maintenance or inspection program. As stated in § H25.4(a)(2), the fuel tank
system must include the following under § 25.981 for fuel tank system:

• Mandatory replacement times,

• Inspection intervals,
• Related inspection instruction/procedures, and
• All CDCCLs.

b. Compliance with CDCCLs. All fuel tank system CMMs as specified in the CDCCLs
are FAA approved. Any changes must be submitted through the PI, who may add comments and
forward them to the FAA Oversight Office for approval. An example is provided as follows: If
required by CDCCLs, repair and overhaul of certain fuel system components must be “per” or
“in accordance with” the manufacturers’ CMM, or later revisions of these CMMs that have been
approved by the FAA Oversight Office. The operator must comply with the CMMs if required
by CDCCLs.

3-7. OPERATOR-DEVELOPED SHOP INSTRUCTIONS. In the past, CMMs were

accepted by the FAA, not approved. The FAA Oversight Office will approve certain CMMs and
certain parts of CMMs in accordance with the requirement in § 25.981(d) in establishing certain
CDCCLs.

a. CMM Example. An example is the CMM for overhauling or repairing fuel pumps. In
certain CDCCLs, the entire manual is FAA Oversight Office-approved and a statement is
contained in the manual to that effect. The FAA Oversight Office must approve any operator
changes to the CMM.

b. CDCCL Example. Another example is a CDCCL where the entire CMM is not FAA
Oversight Office-approved, but the CDCCL requires following specific FAA-approved data such
as maintenance instructions, inspections, and procedures in the CMM. This data will be flagged
as FAA-approved data in the CDCCL and CMM.

c. Identify FAA-Approved Data. Operators who develop their own shop manuals and
instructions need to ensure that the FAA-approved data used in their manuals and instructions are
identified as FAA-approved data. The FAA Oversight Office must approve any changes to the
FAA-approved data in the operators’ shop manuals or instructions.

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AC 120-97A CHG 1 4/11/17

3-8. EXCEPTIONAL SHORT-TERM EXTENSION OF FUEL TANK SYSTEM

AIRWORTHINESS LIMITATIONS.

a. Extension Without Approval. The FAA has determined that an operator may extend
certain fuel system airworthiness limitations by up to the maximum number of days specified in
the applicable ALS for a specific airplane without FAA Oversight Office approval. The FAA
Oversight Office-approved ALS includes a statement explaining that the exceptional short-term
extensions of fuel tank system airworthiness limitations, subject to the procedures in the
document, are FAA Oversight Office-approved. The FAA defines an exceptional short-term
extension as an increase in a fuel system ALI interval that may be used by the operator to cover
an uncontrollable or unexpected situation where the airworthiness limitation cannot be performed
within the ALI timeframe. For example, an operator’s airplane is scheduled for an airworthiness
limitation inspection but cannot enter the hangar bay because it is still occupied by another
airplane. In this case, the operator, in accordance with the procedures in the ALS must request
and have advance approval from the PI for the exceptional short-term extension. (For the
purposes of the FTS requirements and this AC, short-term escalation procedures authorized by
air carrier OpSpecs cannot be used for exceptional short-term extension of fuel tank system
airworthiness limitations.)

b. Repeated Use Prohibited. After an operator uses an exceptional short-term extension

of an FTS airworthiness limitation, that airworthiness limitation interval must revert back to the
original interval in the maintenance program. Extensions are only allowed on an individual
airplane. Under the procedures in the ALS, repeated use on the same airplane or on similar
airplanes in the operator’s fleet is not allowed.

c. Airworthiness Limitation Extension Requests. The extension request must be

submitted to the PI, who will forward the request along with comments to the FAA Oversight
Office for approval. Any such request must include substantiating data. After FAA Oversight
Office approval, the operator will submit to the PI for review the revisions to their maintenance
and inspection program incorporating the FAA Oversight Office-approved extension. (For the
purposes of the FTS requirements and this AC, short-term escalation procedures authorized by
air carrier OpSpecs cannot be used for exceptional short-term extension of a fuel tank system
airworthiness limitation.)

3-9. CHANGES IN ICA RESULTING FROM ALTERATIONS. The EAPAS/FTS Final

Rule requires that after December 16, 2008, before returning an aircraft to service after any
alteration for which fuel tank ICA are developed under SFAR 88, or § 25.1529 and part 25
appendix H (effective June 6, 2001), the operator must incorporate the fuel tank ICA into its
maintenance or inspection program.

a. Major Alterations. The only alterations for which fuel tank system ICA will be
developed are those for which compliance with either SFAR 88 or § 25.1529 must be shown.
These are major alterations approved under STCs or amended TCs.

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5/25/12 AC 120-97A

b. Scheduled Maintenance Visit/Check. These alterations would normally be scheduled

by an operator to occur during a period of allocated downtime such as a scheduled maintenance
visit/check. Operators should include in their maintenance planning for such modification actions
necessary to incorporate fuel tank ICA into their maintenance or inspection program.

3-10. FUEL TANK SYSTEM IGNITION PREVENTION TRAINING. The EAPAS/FTS

introduced new requirements that affect DAH and operators.

a. New Philosophical Approach. To fully realize the objectives of fuel tank system
ignition prevention, the operators need to rethink their current philosophical approach to
maintaining, inspecting, and altering aircraft wiring and systems that could affect the fuel tank
system ignition prevention features. This approach has begun at the airplane manufacturers with
maintenance program enhancements that address fuel tank system ignition prevention. It is
incumbent that the operators include these DAH fuel tank system maintenance program
enhancements into their respective programs. Furthermore, they should commit to training their
maintenance and inspection work force to understand the new philosophical approach to fuel
tank system ignition prevention.

b. New Procedures. In addition to CDCCLs, there will be new maintenance manual and
job card procedures, inspection devices, graphical information showing required tasks, or
changes in tasks such as wire splicing. Operators should provide training to maintenance,
inspection, and engineering personnel, including persons who write and edit job cards and EOs.
Heightened awareness of these critical areas is needed. Additionally, operators must have
procedures in place that ensure maintenance record entries for complying with a CDCCL are
consistent with §§ 43.9 and 43.11, or in accordance with the applicable provisions of part 121 or
part 129 and the operators’ manual.

c. Operator Training Program. The operator training program should emphasize the
importance of accomplishing the fuel tank system airworthiness limitations, CDCCLs,
inspections, and other procedures while accomplishing scheduled and unscheduled maintenance.
(See subparagraphs 3-4b, c, d, and e for further guidance on this subject.)

d. Critical Design Features. Maintenance and engineering personnel can ensure that the
fuel tank system airworthiness limitations are properly performed throughout the operational life
of the airplane by having a thorough understanding of the airplane fuel tank system critical
design features.

e. Manufacturer-Developed Training Programs. Operators should take advantage of

any airplane manufacturer-developed training programs that address fuel tank ignition
prevention.

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AC 120-97A CHG 1 4/11/17

3-11. OPERATOR’S MAINTENANCE PROGRAM APPROVAL UNDER §§ 121.1113

AND 129.113. OpSpec D097, Aging Aircraft Programs, signifies the FAA has reviewed the
certificate holder’s policies and procedures incorporated into their maintenance and/or inspection
programs for compliance with the Aging Aircraft Program rules. The operator will submit to the
PI for review the revisions to their maintenance and inspection program incorporating the FAA
Oversight Office-approved ICA changes. The PI will ensure the operator has incorporated FTS
ICA and any subsequent revisions in their maintenance and inspection programs. When the
review is complete, the PI will issue or amend OpSpec D097.

3-12. OPERATOR’S INSPECTION PROGRAM APPROVAL UNDER § 125.507.

Certificated part 125 operators will be issued OpSpec D097 and A125 Letter of Deviation
Authority (LODA) holders will be issued letter of authorization (LOA) D097, which signifies the
FAA has reviewed the certificate holder’s policies and procedures incorporated into their
maintenance and/or inspection programs for compliance with the Aging Aircraft Program rules.
The operator will submit to the PI for review the revisions to their maintenance and inspection
program incorporating the FAA Oversight Office-approved ICA. The PI will ensure the operator
has incorporated FTS ICA and any subsequent revisions into their maintenance and/or inspection
programs. When the review is complete, the PI will issue or amend OpSpec D097 or A125 LOA
D097.

3-13. OPERATOR INSPECTION PROGRAM APPROVAL UNDER § 91.1507. Part 91

and part 91K operators will be issued LOA/MSpec D097, which signifies the FAA has reviewed
the operator’s policies and procedures incorporated into their maintenance and/or inspection
programs for compliance with the Aging Aircraft Program rules. The operator will submit to the
PI for review the revisions to their maintenance and inspection program incorporating the FAA
Oversight Office-approved ICA. The PI will ensure the operator has incorporated FTS ICA and
any subsequent revisions into their maintenance and/or inspection programs. When the review is
complete, the PI will issue or amend LOA/MSpec D097.

3-14. OPERATORS THAT ARE AUTHORIZED OPSPEC/MSPEC/LOA D097. The

issuance of this OpSpec signifies the FAA has reviewed the operator/certificate holder/program
manager’s policy and procedures incorporated into their maintenance and/or inspection programs
for compliance with the Aging Aircraft Program rules. Table 1 of D097 will consist of
three columns that list:

• The Aging Aircraft Program rules;

• The manual and section where the policy and procedures are located for the applicable
Aging Aircraft Program; and
• The date of the manual and section where the current policy and procedures are located
for the applicable Aging Aircraft Program.

NOTE: Table 3-3 below illustrates a sample D097 Table 1 that lists the
various 14 CFR part rules. The operator/certificate holder/program manager
will have a specific OpSpec D097 template for their operation.

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TABLE 3-3. SAMPLE D097 TABLE 1 – AGING AIRCRAFT

MAINTENANCE PROGRAMS

Operator/Certificate
Holder/Program Manager’s
Maintenance and/or
Aging Aircraft Program Rules Date
Inspection Program
Procedures
(Manual and Section)
Repairs Assessment for Pressurized Fuselages —
§ 91.1505, § 121.1107, § 125.505, § 129.107
Supplemental Inspections — § 121.1109, § 129.109
Electrical Wiring Interconnection Systems (EWIS)
Maintenance Program — § 121.1111, § 129.111
Fuel Tank System Maintenance Program —
§ 121.1113, § 129.113
Flammability Reduction Means — § 121.1117,
§ 125.509, § 129.117
Fuel Tank System Inspection Program — § 91.1507,
§ 125.507

a. Submission to PI for Review. Initial submission and any subsequent revisions to these
policy and procedures sections must be submitted to the PI for review for compliance with the
Aging Aircraft Program rules.

b. FAA Oversight Office (ACO)-Approved ICAs. Any proposed revisions or deletions

of FAA Oversight Office (ACO)-approved ICAs must be coordinated with the PI for review and
concurrence. The PI will then forward the proposed revisions or deletions to the responsible
ACO for approval prior to implementation or incorporation into the maintenance and/or
inspection program.

c. Operator Action. An operator must have procedures to ensure that ICAs are
incorporated into their maintenance and/or inspection program.

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4/11/17 AC 120-97A CHG 1
Appendix 1
APPENDIX 1. ACRONYMS

14 CFR Title 14 of the Code of Federal Regulations

A4A Airlines for America
AC Advisory Circular
ACO Aircraft Certification Office
AD Airworthiness Directive
AEG Aircraft Evaluation Group
AFS Flight Standards Service
ALI Airworthiness Limitation Item
ALS Airworthiness Limitation Section
AMC Acceptable Means of Compliance
AMM Aircraft Maintenance Manual
AMOC Alternative Method of Compliance
ASI Aviation Safety Inspector
CAMP Continuous Airworthiness Maintenance Program
CDCCL Critical Design Configuration Control Limitations
CMM Component Maintenance Manual
CWT Center Wing Fuel Tank
DAH Design Approval Holder
DOT Department of Transportation
EAPAS Enhanced Airworthiness Program for Airplane
Systems
EWIS Electrical Wiring Interconnection System
EZAP Enhanced Zonal Analysis Procedure
ESPM Electrical Standard Practices Manual
FAA Federal Aviation Administration
FEC Failure Effects Category
FQIS Fuel Quantity Indicating System
FR Federal Register
FSU Fuel System Unit
FTS Fuel Tank Safety
HQ Headquarters
IBR Incorporated by Reference
ICA Instructions for Continued Airworthiness
LOA Letter of Authorization
LODA Letter of Deviation Authority

Page 1
AC 120-97A 5/25/12
Appendix 1

MPD Maintenance Planning Data

MRB Maintenance Review Board
MRBR Maintenance Review Board Report
MSG Maintenance Steering Group
MSI Maintenance Significant Items
MWG Maintenance Working Group
NAA National Aviation Authority
NTSB National Transportation Safety Board
OEM Original Equipment Manufacturer
OpSpec Operations Specification
PI Principal Inspector
RGL Regulatory and Guidance Library
RII Required Inspection Items
SFAR Special Federal Aviation Regulation
STC Supplemental Type Certificate
SWPM Standard Wring Practice Manual
TC Type Certificate
TSO Technical Standard Order
TWA Trans World Airlines
VTO Volumeric Top-off
WDM Wiring Diagram Manual

Page 2
5/25/12 AC 120-97A
Appendix 2
APPENDIX 2. LIST OF APPLICABLE SUPPLEMENTAL TYPE CERTIFICATES

Supplemental
Type
STC Holder Airplane Models Description Operator Actions
Certificate
(STC) Number
ST00069BO Goodrich DC8-62, -62F, Fuel quantity STC amended January 5, 2004.
Corporation -63F, -72, -72F, indicating system Operators must incorporate
-73F (FQIS) (external to instructions for continued
tank) airworthiness (ICA) T3068-0005-01,
Initial Issue, dated October 23, 2003
(or later version). (At “D” check
interval, inspections of flight deck
wiring and connectors.)
ST00020BO Goodrich B747-100, -100B, Retrofit of entire STC amended October 19, 2004.
Corporation -100B SUD, Fuel Quantity Operators must incorporate ICA
-200B, -200C, Gauging System T3070-0005-0101, Initial issue, dated
-200F, -300, July 2, 2004 (or later version). (At D
B747SP & check interval, inspections of wiring
B747SR separation, shielding, bonding.)
ST00142BO Goodrich B737-300 Isolation fuel STC amended February 10, 2004.
Corporation quantity transmitter Operators must incorporate ICA
system T3072-0005-0101, Revision A, dated
January 22, 2004 (or later version).
(Periodic inspections of wiring and
bonding)
SA298NE Goodrich B727-100, -200 Computerized STC amended April 19, 2004.
Corporation FQIS Operators must incorporate ICA
T3066-0005-0101, Revision D, dated
March 10, 2004 (or later version).
(Inspections to determine the condition
of the wiring and connector interfaces
every 16,000 flight hours.)
ST00053BO Goodrich B727, -100, -100C, FQIS indicators STC amended April 19, 2004.
Corporation -200, -200F, 727C with Volumetric Operators must incorporate ICA
Top-off (VTO) and T3065-0005-0101, Revision D, dated
optional fuel March 10, 2004 (or later version).
system unit (FSU), (Inspections to determine the condition
In-tank harnesses. of the wiring and connector interfaces
every 16,000 flight hours)

NOTE: These STCs have mandatory actions associated with them in

accordance with Title 14 of the Code of Federal Regulations (14 CFR)
part 91, § 91.1507; part 121, § 121.1113; part 125, § 125.507; and part 129,
§ 129.113. Other STCs may be addressed via Airworthiness Directives (AD).

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5/25/12 AC 120-97A
Appendix 3
APPENDIX 3. DEFINITIONS

a. Aircraft Evaluation Group (AEG). AFS representatives who know the operational
and maintenance aspects of the certification project and are responsible for determining the
operational acceptability and continuing airworthiness requirements of newly certified or
modified aircraft, engines, and propellers intended to be operated under the provisions of
14 CFR. This function includes providing the cognizant ACO support in the review and approval
of the initial and subsequent changes to the type design.

b. Aircraft Maintenance Manual (AMM). A manual developed by the manufacturer of a

particular airplane that contains information necessary for the continued airworthiness of that
airplane.

c. Airworthy. An aircraft, aircraft engine, or component that conforms to its type design
and is safe to operate.

d. Fuel System Airworthiness Limitation. An airworthiness limitation that contains

“each mandatory replacement time, inspection interval, related inspection procedure, and all
CDCCL approved under 14 CFR part 25, § 25.981 for the fuel tank system.”

e. Airworthiness Limitation. Mandatory maintenance of the fuel system that includes

CDCCL, inspections, or other procedures determined necessary to ensure that fuel tank ignition
sources do not occur and are not introduced into the fuel system as a result of maintenance
actions, repairs, or alterations throughout the operational life of the airplane.

f. Airworthiness Limitation Item (ALI). A term used by some DAH to group

maintenance/inspection type fuel tank airworthiness limitations separately from CDCCL type
fuel tank ALs.

g. Airworthiness Limitations Section (ALS). “Airworthiness Limitations” is the title

required by part 25 appendix H, § H25.4(a) and (a)(2) for the section of the ICA that contains
“each mandatory replacement time, inspection interval, related inspection procedure, and all
critical design configuration control limitations approved under Sec. 25.981 for the fuel tank
system.”

h. Auxiliary Tanks. Fuel tanks installed which make additional fuel available to increase
the flight range of that airplane and are secondary to the airplane’s main fuel tanks. Auxiliary
tanks have been installed in various locations including center wing structure, horizontal
stabilizers, wings, and cargo compartments.

i. AMOC. Alternative method of compliance.

j. Component Maintenance Manual (CMM). A manual developed by a manufacturer

that contains information necessary for the continued airworthiness of a particular component.

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AC 120-97A 5/25/12
Appendix 3
k. CMM Deviation.

(1) Term used for approval of changes to CMMs that are the subject of CDCCLs
adopted by a type design change.

(2) Term used for the approval of changes to CMMs referenced in CDCCLs that are
mandated by ADs, provided the CDCCL includes wording that allows use of “later approved”
CMMs. Otherwise, approval is granted as an AMOC to the AD. As with AMOC approvals, a
CMM deviation approval is by a letter from the FAA Oversight Office.

l. Continued Airworthiness. Certified aircraft, engines, propellers, and appliances are

safe to operate for the intended purpose; they are maintained safely throughout their service life;
the product meets its type design; and is in a condition for safe operation.

m. Critical Design Configuration Control Limitation (CDCCL). A CDCCL is an

airworthiness limitation required by §§ 25.981 and H25.4 that defines those parameters of the
design that must be maintained to ensure that ignition sources will not develop within the fuel
tank. CDCCLs include any information necessary to maintain those design features that have
been determined by analysis of the fuel tank system as needed to preclude development of
ignition sources. This information is essential to ensure that maintenance, repairs, or alterations
do not unintentionally violate the integrity of the original type design of the fuel tank system.

n. Design Approval Holder (DAH). The holder of any design approval, including TC,
amended TC, STC, amended STC, parts manufacturer approval, TSO authorization, letter of
TSO design approval, and field approvals (refer to FAA Form 337).

o. Exceptional Short-Term Extension. An increase in a fuel system ALI interval that

may be used by the operator to cover an uncontrollable or unexpected situation where the ALI
cannot be performed within the ALI timeframe.

p. Electrical Arc or Spark. The transfer of electrons across a gap.

q. Enhanced Zonal Analysis Procedure (EZAP). An analytical process for developing

maintenance and inspection instructions for the EWIS.

r. Electrical Wiring Interconnection System (EWIS). Any wire, wiring device, or

combination of these, including termination devices, installed in the airplane for transmitting
electrical energy between two or more termination points.

s. FAA Oversight Office. The ACO or the office of the Transport Airplane Directorate
having oversight responsibility for the relevant TC or STC as determined by the Administrator.
(See Appendix 4, FAA Oversight Offices by Airplane Manufacturer, for a list of FAA Oversight
Offices for certain transport airplane TC holders.)

t. Flammable. With respect to a fluid or gas, flammable means susceptible to igniting

readily or to exploding (refer to 14 CFR Part 1, Definitions and Abbreviations).

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5/25/12 AC 120-97A
Appendix 3
u. Failure Effect Category (FEC).

(1) Category 5. Functional failures that have evident safety effects.

(2) Category 6. Functional failures that have evident operational effects.

(3) Category 7. Functional failures that have evident economic effects.

(4) Category 8. Functional failures that have hidden function safety effects.

(5) Category 9. Functional failures that have hidden function non-safety effects.

v. Field Approval. A method for obtaining FAA approval of a design change to the
airplane. An FAA Flight Standards inspector can approve the design change using
FAA Form 337.

w. Flammable Fluid Leakage Zones. Any area where flammable liquids or vapors are not
intended to be present, but where they might exist due to leakage from flammable fluid carrying
components (e.g., leakage from tanks, lines). Examples of these areas include:

• The wing leading (including any adjacent compartment such as the strut) and
trailing edges;
• Fairings located below the fuel tanks;
• Wheel wells;
• Fuel pump enclosures;
• Unpressurized areas of the fuselage surrounding fuel tanks; and
• Areas containing flammable fluid lines or tanks.

x. Flight Standards Service (AFS). Offices located in FAA headquarters (HQ)

responsible for developing guidance and policy applicable to transport category airplanes for
AEG personnel and AFS field personnel (maintenance, avionics, and Operations ASI in the
conduct of their responsibilities.

y. Functional Failures. The failure of a component or subsystem to perform its intended

function within specified limits.

z. Hidden Failure. A failure whose presence may not be readily apparent to the
flightcrew or maintenance personnel.

aa. Hidden Functional Failure Safety Effect. A combination of a hidden (or latent)
functional failure and one additional failure of a system-related or backup function that will have
an adverse effect on operational safety.

bb. Hot Short. Electrical energy introduced into equipment or systems as a result of
unintended contact with a power source, such as bent pins in a connector or damaged insulation
on adjacent wires.

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AC 120-97A CHG 1 4/11/17
Appendix 3
cc. Instructions for Continued Airworthiness (ICA). The information developed in
accordance with applicable airworthiness requirements that include the applicable inspection
tasks, intervals, methods, processes, procedures, and airworthiness limitations to keep the
product Airworthy throughout its operational life.
dd. Maintenance and Inspection Instructions. Information that provides, for each part of
the airplane and its engine auxiliary power units, propellers, accessories, instruments, and
equipment, the recommended periods at which they should be cleaned, inspected, adjusted,
tested, lubricated, and the degree of inspection, the applicable wear tolerances, and work
recommended at these periods needed to provide for the continued airworthiness of the airplane.
The recommended overhaul periods and necessary cross-reference to the airworthiness ALS of
the manual are also included.
ee. Maintenance Planning Data (MPD). Data developed by the manufacturer of a
particular airplane that contain the information each operator of that airplane needs to develop a
customized, scheduled maintenance program.
ff. Maintenance Review Board (MRB). An FAA group that supports industry
development of the Maintenance Review Board Report (MRBR) and approves the final MRBR.
gg. Maintenance Review Board Report (MRBR). A report which contains the initial
minimum scheduled maintenance and inspection requirements for a particular transport category
airplane and on-wing engine program. Air carriers may use those provisions, along with other
maintenance information contained in the ICA, in the development of their maintenance
programs.
hh. Maintenance Significant Item (MSI).
(1) Under MSG – 3rd Task Force (MSG-3), items other than ALI that are identified by
the DAH whose failure could cause one of the following effects:
• It could affect safety on the ground or in flight,
• It could be undetectable during operations,
• It could have a significant impact on operations, or
• It could have a significant economic impact.
(2) In terms of development of maintenance and inspection instructions, MSIs include
systems, subsystems, modules, components, accessories, units, or parts.
ii. Maintenance Steering Group-3 (MSG-3). A voluntary structured process developed
by the industry and maintained by Airlines for America (A4A) to make decisions used to
develop maintenance and inspection tasks and intervals for an airplane.
jj. Maintenance Working Group (MWG). A working group of maintenance specialists
from participating operators, the prime manufacturer, and the regulatory authority whose
function is to develop airplane maintenance programs. The MWG should have representatives
knowledgeable about the fuel tank system under analysis and about the requirements of
SFAR 88.

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5/25/12 AC 120-97A
Appendix 3
kk. Mandatory Action Advisory Board. A committee composed of representatives from
the cognizant FAA Oversight Office and the Transport Airplane Directorate whose function was
to review the findings from the SFAR 88 safety review for determination of an unsafe condition
using the criteria in FAA policy memorandum 2003-112-15, SFAR 88—Mandatory Action
Decision Criteria.

ll. National Aviation Authority (NAA). The aviation authority responsible for the
certification and continued airworthiness of those airplanes having a U.S. TC within its state of
design as established in accordance with agreements with the United States.

mm. Products. Products are certified aircraft, engines, propellers, and appliances.

nn. Supplemental Type Certificate ICA. The STC holder ICA consists of the inspection
tasks, intervals, methods, processes, and procedures to keep an alteration affecting the fuel tank
system approved under an STC Airworthy throughout its operational life. The STC holder ICA
must meet the requirements of SFAR 88, or § 25.981 and part 25 appendix H, and be approved
by the FAA Oversight Office.

oo. Type Certificate Holder ICA. The TC holder ICA consists of the inspection tasks,
intervals, methods, processes, procedures to keep the product’s fuel tank system Airworthy
throughout its operational life. It is typically the result of the MRB process. During this process
the TC holder develops MSIs and subjects them to maintenance program development logic,
such as in MSG-3 or later revisions. The TC holder ICA must comply with the requirements of
SFAR 88, or § 25.981 and part 25 appendix H, and be approved by the FAA Oversight Office.

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Appendix 4
APPENDIX 4. FAA OVERSIGHT OFFICES BY AIRPLANE MANUFACTURER

Airplane Manufacturer FAA Oversight Office

ATR – GIE Avions de Transport Transport Standards Staff, International Branch
Régional (ANM-116)
Airbus Transport Standards Staff, International Branch
(ANM-116)
BAE Systems Transport Standards Staff, International Branch
(ANM-116)
Boeing—Seattle Area Seattle Aircraft Certification Office (ACO)
(ANM-100S) and/or Boeing Aviation Safety Oversight
Office (ANM-100B)
Boeing—Long Beach Los Angeles ACO (ANM-100L) and/or Boeing
(McDonnell-Douglas) Aviation Safety Oversight Office (ANM-100B)
Certification Office
Bombardier New York ACO
EADS CASA Transport Standards Staff, International Branch
(ANM-116)
de Havilland New York ACO
Dornier Transport Standards Staff, International Branch
(ANM-116)
Embraer Transport Standards Staff, International Branch
(ANM-116)
Fokker Transport Standards Staff, International Branch
(ANM-116)
Lockheed Martin Atlanta ACO
SAAB Transport Standards Staff, International Branch
(ANM-116)

Page 1 (and 2)
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new items/subjects to be added, you may let us know by contacting the Flight Standards
Directives Management Officer at [email protected].

Subject: AC 120-97A CHG 1, Incorporation of Fuel Tank System Instructions for Continued Airworthiness
into Operator Maintenance and/or Inspection Programs

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